NC0026123_Fact Sheet_20230821 (2)

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Review Fact Sheet
NPDES Permit No. NCO026123
90 v ent 5/9/2019 (see Section 14. Fact
Permit Writer/Emailn?Contact: Nick Coco,nick.coco eq.nc.g°`
Date Initiated: August 29,2022; initial draft submitted for publiccomm
Sheet Addendum for more information)
Division/Branch:NC Division of Water ResourcesMPDE5 Municipal Permitting Unit
Fact Sheet Template:Version 091an201
Pennitting Action:
® Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification(Fact Sheet should be tailored to mod request)
Note: A complete application should include the following: ineerin Alternatives Analysis,Fee
• For New Dischargers,EPA Form 2A or 2D requirements,Eng g °a species WET
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans,
4 2
tests. EPA Form 2C with correct analytical requirements based
• For Existing Dischargers(Non-POTW),
on industry category.
Complete applicable sections below. If not applicable,enter NA.
1. Basic Facility information
Facility information
Cite of Ashcboio,,Asheboro WWTP
Applicant/Facility Name:
Applicant Address: P.O. Box 1106, 146 N Church Street,Asheboro,NC 2720
p
pp 1032 Bonkcmeyer Drive, Asheboro,NC 27203
Facility Address: 9.0 MGD
Permitted Flow:
Type/Waste: MAJOR Municipal;92.1%domestic,7.9%industrial
Facility Grade 1V
Facility Class:
Bar screen,Grit removal, Parshall flume,Primary clarifiers,Trickling
filters,Secondary clarifiers,chlorinattrification with ion,De-chlorination,aeration,
Ca Canal scade aerations
Treatment Units: Tertiary sand tilte .esters, Dewatering.
Sludge thickening, Dig
Yes
Pretreatment Program(Y/N) Randolph
County: Winston-Salem
Region
Footnote•
1. Permitted industrial tlow is 0.712 MGD.
Page 1 of 24

Briefly describe the proposed permitting action and lbcditr hackgrouind: The City of Asheboro has applied
for NPDES permit renewal, received by DWR Oil _ i16. A draft permit was public noticed in May
2018; comments were received, and the pen-nit 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 Irom 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 cons(ructed), 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 i (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-Tenn Monitoring Program (L.TMP) for its SiUs.
Solids management is handled via land application,permitted under WQ0001684.
2. Receiving Waterbody Information
Receiving Waterbody Information
Outlalls/Receiving Stream(s):
Uuttall 001/Hasketts Creek
Stream Segment:
17-12
Steam Classification: C
Drainage Area(mi2):
11.6
Summer 7Q10(cfs) 0
Winter 7Q10(cfs):
30Q2 (cfs):
0.2
Average Flow(cfs): 12
IWC(%effluent): 90
This stream segment is impaired for Copper and Benthos.
2022 303(d) listed/parameter: Hie 2022 Integrated Report also notes data inconclusive fcn
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 ma croin vertebrates, 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 lnstream 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 '
Flow' MGD 4.05 15.489 MA - 9.0
BOD summer mg/L 2.4 93 ii MA= 5.0
WA= 7.5
BOD winter mg/L 3.4 16.9 „ MA = 10.0
WA= 15.0
BOD Removal % 99.0 99.7 97.8 > 85
Total Suspended Solids mg/L 5.1 72 , < 2.0 MA = 30.0
(TSS) %VA =45.0
TSS Removal % 98.4 99.7 96.4 > 85
Ammonia(NH3-N) mg/L 0.15 t�, 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 9.2 10.71 6 DA > 6.0
(DO)
pH SU 7.0 7.63 0.0 Between 6.0 and 9.0
Fecal Coliforni #/100 mL 18 >4839 < 1 MA = 200
(geometric mean) WA =400
Total Residual fig/L 15.6 48.7 ., 15.0 DM = 17 3
Chlorine(TRC)
Temperature °C 20.6 28.7 9.4 Monitor& repoi
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/I_ 14.0 28.16 0.53 Monitor& report
Total Kjeldahl
Nitrogen(TKN) mg/L 1.65 5.16 I Monitor& report
Nitrate/Nitrite Nitrogen
(NO2+NO3) mg/L 12.6 25.00 0.53 Monitor& report
Total Phosphorus(TP) mg/L 0.35 1 01 < 0.05 \Ionitor& report
Dibromochloromethane µg/L 8.4 1 .? < 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 ftg/L 6.6 11.8 3.5 'Monitor& report
Total Zinc µg/L 23.2 100 < 10 Monitor& report
1,4-Dioxane 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 pennit as long as coalition membership is maintained).
If applicable,stonmarize any instream data and what instream monitoring will be proposed for 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) Istation locations
displayed in Figure 1, shown below]. Data Isom U and D2 were obtained from the Monitoring Coalition
Coordinator and span from.Tune 2017-.tune 2022;data from D1 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 l 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 #/100mI' (geomean) 12000 9 (geomean) 10000 35 (geomean) 11000 4
Coliform 465 333 176
*Data from.tune 2017-June 2022
Students (-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 O.xvgen (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/I. 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 pennit 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 coliforn as inconclusive with regard to detennination 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 coliforni at both downstream monitoring stations exists. Additionally,no
statistically significant difference was observed between fecal coliforn levels at both downstream sample
locations. As such, instream fecal colifonn monitoring has not been added.
Taal Cou)er: Hasketts Creek downstream of Asheboro is impaired for Total Copper(7 Pg/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 Di 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 lig/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.
Nutrients
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 patter 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+N0A Total Kjeldahl Nitrogen (TKN), Total Nitrogen (TN) and Total Phosphorous ('FP)
from data collected by the UCFRBA and AMS at the three instream locations.
Hasketts Cr Deep River
W Im aired:Senthos,Cu t Not Impaired
K ;mil:;,�•
:�••1 •�.A" Dow am'
~ # "� '.'sj Deep River ^r'
• Out fall 001 R ,:�?' Impaired:Chl-a
Upstream(U) 1':7
Downstream(D2)
�. S y Ana `1• ;A,'i�a
%
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/I .
Parameter Upstream(U) Effluent Downstream(DI) Downstream(D2)
Nitrate-Nitrite 0.24 12.6 7.5 0.87
(NO%+NO,) (0.02-1.63) (0.53-25.0) (0.53-19.0) (0.06-4.23)
1 otal Kjeldahl Nitrogen 0.72 1.66 1.1 0.85
( 1'KN) (0.20-4.74) (<1-5.16) (0.7-2.2) (0.20-2.88)
total Nitrogen('iN) 0.98 14 8.6 1.76
(0.022-6.31) (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) (0.024.31)
Total Phosphorus(I P) 0.05 0.35 0.24 0.09
(0.02-0.425) (<0.05-1.610) (0.03-).0) (0.038-0.179)
Based on this information,which includes monitoring coalition data,instream monitoring for TN,TP,TKN,
NO2+NO;, 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 (NCDif'R 2016: 1,4-Dioxane in the Cape
Fear River Basin of North Carolina: An Initial Screening and Source Identification Stull), which found
multiple sites with elevated concentrations. Among the highest concentrations detected were in Hasketts
Creek downstream of the Asheboro W WTP discharge with an average of 291 fig/L (range: 147-478 pg/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 No. Dates Sampled Average Nlininnnn Maximum
Samples
Hasketts Creek-upstream 9 Jun 2018-Apr 2019 1.3 0.54 ?.
Hasketts Creek -downstream 27 .Ian 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.
histream 1,4-dioxane sampling shall be conducted in concurrence with effluent 1,4-doxane sampling.
Page 7 of 24

Sampling for instream I A-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.fac•ilit),a member of a Monitoring Coalitio» ii,ith waived instream monitoring(YIN): YES
Name of Monitoring Coalition: Upper Cape Fear River Basin Association
5. Compliance Summary
Sunnmari_e the compliance record with permit effluent limits (past 5),ears): From August 2017 through
August 2022 the facility reported no limit violations.
Summarize the compliance record with aquatic toxicity test lintits 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 Mixing Zones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow(chronic Aquatic
Life;non-carcinogen HH); 30Q2 streamflow(aesthetics);annual average flow(carcinogen, HH).
If applicable, describe any other dilution factors considered(e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA
Oxygen-Consuming Waste Limitations
Limitations for oxygen-consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD=30 mg/L for Municipals)may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit 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 detennined 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 tng/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 pen-nit limit.
Describe amp 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 7Q 10 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 nmrnonia-N (NH3-N)
e, Wk Avg ♦ Mo Avg MA t imit WA I imit
••
0
1/10/2018 2/14/2019 3/20/2020 4/24/2021 5/29/2e22
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 Round 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 pennit 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 '/2 detection limit for "less than" values; and 4) strearnflows 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 pennitting actions are proposed for this
pen-nit:
• 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 µg1L), Silver(MA 0.06 µ 'L, DA1 2.4
ygll), 1,4-Dioxane (A1A 21.58 pg/L — See Other 1i'QBEL Considerations section fin- 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 detennined by the waste load allocation to be exceeded in a receiving
water by a discharge under the specified 7Q10 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 C hrU»111a7), Cyanide, Lead, Mol vbdennm, 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, Bei-vIliuln
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 i µg/1, 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 Dissoh,ed Metals
Implementation Fact Sheet.for.f-eshitater/saltiiater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipaliti,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 pen-nits
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 pen-nits,
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 1? 12 8
Annual Average Cone. ng/L 1.7 14 1.5 1.3 1.5
Maximum Conc.,ng/L 2.90 3.30 3.60 4.60
TBEL, ng/L 47
WQBEL,ng/L 12.0
Describe proposed permit actions based on inertia), 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
(> I ng/L), a mercury minimization plan(MMP) will be added to the permit.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe aurr,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 l 1 of 24

Basin, an area identified fbr nutrient criteria development in the North Carolina Nutrient Criteria
Development Plan, Version 2.0(NC'DWR 2014). The current permit has monthly monitoring requirements
for Total Nitrogen (TN), Nitrite-Nitrate Nitrogen (NO2-N + NO:-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 WOBEL Considerations
If applicable, describe anv other paramete,s of concern evaluated .for I,VQBELs: The emerging
contaminants 1,4-Dioxane and PFAS family of compounds were evaluated for potential WQBEI,s.
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).
Rely rences:
• 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 I A-Dioxane(with Inhalation Update)in Support of Summary
Information on the Integrated Risk Information System(IRIS). EPA 635-R-1 1-003F.
• EPA IRIS. 2013. 1,4-Dioxane(CASRN 123-91-1). www.eua.mov/iris/subst/0326.iitm.
An initial stream survey of the Cape Fear River Basin(NCDiI R 2016: 1,4-Dioxane in the Cape Fear River
Basin of North Carolina: An Initial Screening and Source l(lenti/ic•ation Stuc/r) 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 jig/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 jig/L).
The Division issued a letter to Asheboro requesting the City develop and submit a corrective action plan
for IA-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`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)(6) has not been applied. However,
should the facility pursue expansion, toxic substances shall be limited at % 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 I x 10-'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 jig/L.
The discharge detennination 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 jig/L
has been used in detennination 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 of0.35 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 IA-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 IA-Dioxane
at the water supply boundary.
Considering the existing effluent concentrations experienced at the facility, the first phased limit was
calculated to be the 50"' 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. 'file 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
fig/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 95`h percentile,
• MDL exceedance probability of 99`h percentile,
• A weekly sampling frequency(n=4hnonth).
The table yielded a multiplier of 2.29, which was applied to the average monthly limits of 55.7 fig/L, 35.0
lig/L, and 21.58 µg/L to obtain the Maximum daily limits of 127.6 µg/L, 80.2 pg/L, and 49.4 fig/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
00
C
O
1000. •• •
• •
a) • •
O • • • • •
100 •• • •• • • • •
X • • • • •55 7 µg/l
O •
O 21.58 µg/1
`r 10
U •
• •
Q 1
11/11/2011 12/1612018 1/20/2020 2/23/2021 3/30/2022
c
0
� flat c
• 1,4 dio>ane Effluent Data chased TaiE,o I NIA Fiiasvd Target II IAA. Fintil Phasfd Taigi l III t)--
Figure 3. Asheboro WWTP effluent Monthly Average 1,4-dioxane data versus three proposed phased
Monthly Average limitations
Page 14 of 24

Effluent data troln 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
�i
O 1000 4 •
100 • • ` • 127 6 µg/1
O •• • • • t �� •• • 7_
a) • '• �� ':•T:49 4 µp/I
X • ,*
0 10 •• •
p ••
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 11 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 revie\+ period where 1,4-dioxane concentrations greater than 1,000 ug/L were
observed in the Starpet effluent.
Asheboro WWTP vs Starpet Comparison
100000
J
OD
10000
O
1000 •
f •
. . i ti _ �r !�•w ••j
10 • . • •,% Mr r
1 •
9/26/2020 4/14/2021 10/31/2021 5/19/2022 12/5/2022
Date
•Asheboro WWTP Effluent •Starpet Effluent
1-igure 5. Comparison of Asheboro W W"l P 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 fellow a spiked event. Based on this review, it has
been concluded that either 1,4-dioxane is somehow being trapped in the components Asheboro W WTP'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 pennit.
See the three-phase compliance schedule incorporating the various phased limitations below:
NPDES Pennit 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 fig/L, based on the 50°i percentile
of reported effluent concentrations from January 2018 through September 2022, becomes
effective I year after the effective date of tite permit.
o Within I 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 111 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 pennit.
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 Maximum Minimum 2022 Updated Drinking Rater
Influent(ng/L) Influent(ng/L) Influent(ng/l.) Health Advisory(ng/L)
PFOS 19.11 19.8 18.8 interim'
PFOA 10.6 11.7 9.47 interim'
PFBS Non-detect Non-detect Non-detect 2.000
GenX' 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%201nterim%20Updated%20PFOA%20and,those%20EPA%20issued%20in%202016.
''During 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, PFI-IxS, PFBS and GenX.
To identify HAS 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 W WTP has a pretreatment program and has demonstrated influent HAS
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 ORIV) this receiving stream and classification shall
comply with in order to protect the designated waterbot v: NA
If applicable,describe any compliance schedules proposed far this permit renemal in accordance with 1 SA
NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Menro: 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.
Inapplicable, describe any water quality standards ya•iances proposed in accordance with NCGS 143-
21 S.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 nrg/L
BODs/TSS for Monthly Ave rage, and 45 nrg/L for BOD51TSS for [Feekh,Average). YES
IfNO,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., ivaste stabilization pon(l). 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 21-1.0105(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 Pennitting Actions
Table 4.Current Permit Conditions 1 and Pro osed Change
Parameter Current Permit Proposed Change Basis for Condition/Change
I I; MA 9.0 MGD No change I5A NCAC 2B .0505
Summer: WQBEL. Detennined via WLA
MA 5.0 mg/L conducted in 1995,and for protection
WA 7.5 mg/L of DO standard(15A NCAC 2B .0200).
BODs Winter: No change to limits; Monitor and )012 DWR Guidance Regarding the
MA 10 mg/L Report 2/Week Reduction of Monitoring Frequencies in
WA 15 mg/L NPDES Permits for Exceptionally
Monitor and Perfonning Facilities
Report Daily
TBEL. Secondary treatment standards/
MA 30 mg/1- 40 CFR 133/ 15A NCAC 2B .0406.
WA 45 mg/I. 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
Perfonning Facilities
WQBEL. Based on protection of State
Summer: Summer: A'Q criteria. 15A NCAC 2B.0200;
MA 2.0 mg/L MA 1.0 mg/L 1022 WLA review; 2012 DWR
WA 6.0 mg/L WA 3.0 mg/L Guidance Regarding the Reduction of
Winter: Winter: Monitoring Frequencies in NPDES
MA 4.0 mg/L MA 1.8 mg/L Permits for Exceptionally Perfonning
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 i/Month .onsistently. Based on instream Data
Summary
DO >6 mg/L No change WQBEL. For protection of the DO
standard. 15A NCAC 2B .0200.
WQBEL. WQ standard, 15A NCAC 2B
pH 6.0—9.0 SU No change .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
the Reduction of Monitoring
c'olifornt Monitor and Report 2/Week Frequencies in NPDES Permits for
Report Daily I.xceptionally Performing Facilities
I otal WQBE1._. Based on protection of State
4UQ criteria. 15A NCAC 2B.0200:
izesidual DM 17 µg/l. No change '022 WLA review
Chlorine
Surface Water Monitoring, 15A NCAC
I emperatul, Monitor daily No change 02B .0500
No change to effluent. 15A NCAC 2B.0500, added based on
Conductivity' Monitor effluent Add instream monitoring upstream mstream conductivity review
daily demonstrating effluent impact on
(U)and downstream (DI and U2) receiving stream.
Monitor Surface Water Monitoring, Based on
quarterly in RPA and 15A NCAC 2B.021 1 (22). RP
Chloride conjunction with No change shown; apply quarterly monitoring in
Chronic Toxicity conjunction with toxicity tests,per 15A
test NCAC 02B .021 1(22)
Surface Water Monitoring, Hardness-
I otal dependent dissolved metals water
I lardness No requirement Add quarterly effluent monitoring quality standards, approved in 2016;
upstream hardness not required due to
0cfs7Q10.
Focal MA=50 fig/I. No reasonable potential was found,
Chromium DM = 1033 µg/I_ Remove from permit maximum predicted value<Cr-VI
allowable concentration.
Surface Water Monitoring, Based on
RPA, 2022 303(d) listing and integrated
I otaI Copps, monitor No change Report: Receiving water is impaired
quarterly due to copper. No RP , Predicted Max
50%of Allowable C%a- apply
Quarterly Monitoring
Remove limits from permit.
Total MA = 12 ng/I. Add Mercury Minimization Plan Consistent with 2012 Statewide
Mercury DM = 36 ng/I. Mercury TMDL Implementation.
(MMP)
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
Selenium No requirement Quarterly monitoring at lower Surface Water Monitoring, Based on
reporting level of procedure RPA. No RP, Predicted Max > 50%
Page 20 of 24

Allowable Cw - apply Quarterly
Monitoring
Based on RPA. No reasonable potential
Monitor found in RPA, but maximum predicted
I otal Zinc quarterly Remove from permit value< 50%of the allowable
concentration.
Surface Water Monitoring, Based on
Dibromochlo Monitor RPA. No reasonable potential found in
No change RPA,but maximum predicted value>
rumethane quarterly
50%of the allowable concentration.
Bromodichlo Monitor MA = 31.6 µg/L WQBEL. Based on RPA for NC
Instream Target Value. RP shown-
romethane quarterly Monitor and report Monthly apply Monthly Monitoring with Limit
Surface Water Monitoring, 15A NCAC
1 otal Monitor monthly No change to effluent; Add 2B.0500; nutrient criteria development
Nitrogen instream monitoring I/Month in the Upper Cape Fear River Basin.
Based on Instream Data Summary
Surface Water Monitoring, 15A NCAC
Total No change to effluent; Add 2B.0500; nutrient criteria development
Kjeldahl Monitor monthly instream monitoring 1/Month in the Upper Cape Fear River Basin.
Nitrogen Based on Instream Data Summary
Surface Water Monitoring, 15A NCAC
Nitrate+ No change to effluent; Add 2B.0500; nutrient criteria development
Nitrite Monitor monthly instream monitoring 1/Month in the Upper Cape Fear River Basin.
Nitrogen Based on Instream Data Summary
Surface Water Monitoring, 15A NCAC
Total No change to effluent; Add 2B.0500; nutrient criteria development
hIv
Phosphorus - ins No montinstream 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 I Aveek grab Phased limitations based on 50"'
1,4-Dioxane per letter sent in percentile of effluent levels, FPA
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.
Quarterly \w'QBEL. No toxics in toxic amounts.
Chronic Ceriod(II)IInia No change 15A NCAC 2B.0200 and 15A NCAC
Toxicity duhia Pass/Fail at 2B.0500
90%effluent
Page 21 of 24

Effluent i'hree times per Update sampling years to 202�
Pollutant permit cycle 2026, 2027. 40 CFR 122
scan
Iectronic Add Electronic Reporting Special In accordance with EPA Electronic
Reporting No requirement Condition Reporting Rule 2015 and Phase 112020
update.
Nutrient
Reopen for Special No change Upper Cape Fear River nutrient strategy
IN and TP Condition requirement.
' 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& .011 1,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 tine reasons
why a hearing is warranted.
14. Fact Sheet Addendum (if applicable)
Were there amp 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 NI43 limits not inserted as requested as an alternative to concentration-based
limits? If►pass-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 1 1/29/2022 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(r•om previous public notice)and their basis below:
Note: This is not a comprehensive list of all changes fi-onn 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 IVQBEL Considerations section above.
• A three-phase five-year 1,4-Dioxane compliance schedule has been added. See Other IVQBEL
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 iVQBEL 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 BODS, NH,-N, Total
Suspended Solids and Fecal Coliform have been reduced to twice per week.
iVere there anv 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 pennit:
• 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

#'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
• 1learing 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-
Co hA0 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- i
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 30 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
nclk"L may be found on our website: ht-
Classified Rep tp:/ideq.nc,govlabout/divisions/wa
ter-resources/water-resources-
Subscribed to and sworn to me this 9th day of December permits/wastewater-branchinp-
2022. des-wastewateripublic-notices,or
by calling [phone] . The
City of Asheboro [P.O. Box 1106,
Asheboro, NC 27204) has re-
�.,La.. quested renewal of NPDES per-
Barbara M Daniels, Notary Guilford, County, NC mit NCO026123 for its Asheboro
Wastewater Treatment Plant, loc-
My commission expires: March 06, 2027 ated in Randolph County. This
permitted facility discharges
h 1 treated municipal and industrial
wastewater to Hasketts Creek, a
oC ,�� class C water in the Cape Fear
70083249 70540195 River Basin. Currently, BOD, am-
WREN dissolved oxygen, pH,
WREN fecal coliform, total residual chlor-
NCDEQ-DWR-NPDDWR-NPDES (ASH) Ine, total silver, bromodichloro-
1617 MAIL SERVICE CENTER methane and 1.4-dioxane are wa-
RALEIGH, NC 27699 1617 ter quality limited. This discharge
may affect future allocations in
this segment of Hasketts Creek.
1 L 12'9122

Notice of Public Hearing
AFFP PUBLIC NOTICE is hereby giv
en that the North Carolina De
Public Notice State of North parlrmenl OI Environmental
Quality's Division of Water Re-
sources will hold a public heat
mg from 6 p m to B p m on
Affidavit of Publication May 23.2023 for on on
lulion Discharge
a Elimination
System(NPDES)Wastewater
Discharge Permit NCO026123
The purpose of the hearing is to
give the opportunity to corn
merit on the draft NPDES per
mil
STATE OF NC ) SS
COUNTY OF } The City of Asheboro has ap
plied for a renewal of its NP
Ctrlt f�:r� h DES wastewater permit
T (NC00261231 for the Asheboro
Wastewater Treatment Plant
1032 Bonkemeyer Drive
Brenda Poole. being duly sworn, Says: Asheboro, NC 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-
newspaper of eneral circulation, printed and Rifts Creek in the Cape Fear
dailyg 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(w the Deep
boundary,located in
p River 43 5 mites
said newspaper on the following dates: downstream of the outlall was
considered during the develop-
ment of this permit. This dis-
April 20, 2023 charge may affect future alloca
Irons in this portion of the Cape
Fear River Basin The location
of the Outfatl is Latilude
35.46'00 N, Longitude
79.47'06-
The draft wastewater permit
and related documents are
available online at
hltos 'idea nc oovioubhc-no
That said newspaper was regularly issued and circulated (ices hearings. Panted copses
p g y 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
27105) To make an appoint
merit to review the documents
Classified Re please call Jenny Graznak.As
Rep 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
Wastewater Permitting Alin
✓�-� +"�•u� Asheboro-Asheboro WWTP
Barbara M Daniels, Notary Guilford, County, NC Permit. 1617 Marl Service Cen
let.Raleigh.N C.27699 1617
and must be postmarked no
later than May 24 2023 Public
My commission expires: March 06, 2027 comments may also be submit
led by email to bubliccom
ments(&ncdenr.aov Please in
clude'Asheboro WWTP'in the
email subject line Comments
will be accepted via email until
May 2C 2023.5 p m All com
70083249 70648070 ments will be considered m 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 r.' ,� ,)T � r� 23. 2023 at 6 p m to B p m
RALEIGH, NC 27699-1617 _ : Location corporate Training
rf '_ Center at the Randolph Com
muntly College 413 Industrial
;•� ! 4 r Park Avenue. Asheboro. NC
27205 Register Speaker regis
(ration opens at 5 30 p m
onsite via s,gn up sheet
11 4 20,2023

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/hirrn/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 kirby(a-)ncdenr.gov
450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105
D_E Q�
NORTH CARD,NA
a EmrlronmeMal Ouslltp
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.
i

Draft Permit: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2601378&dbid=0&repo=WaterResources
NPDES Standard Conditions: https://bit.ly/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 iil
NPDES Municipal Permitting Unit
NC DEQ/Division of Water Resources/Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but I 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
tc D�E
NORTH CAROLINA
DepaAmefrt 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.
z

DocuSign Envelope ID:6772C75B-lEB4-40CD-99D4-F3F8627845AE
ROY COOPER
Coverna
ELIZABETH S.BISER
Secretary 41D
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director EItY+I1DA11 ff"Q1 aft
July 3, 2023
Mr. Michael D. Rhoney, PE
Water Resources Director
City of Asheboro
P.O. Box 1106
146 N Church Street
Asheboro, North Carolina 27204
Subject: Study Plan Approval
Silver Water-Effect Ratio (WER)
Permit NCO026123
Asheboro WWTP
Randolph County
Dear Mr. Rhoney:
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(a)deq.nc.gov.
Sinccrck.
CDocuStpned by:
NwhIst,Uh
G645311316"FE...
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
\ord;(:arulina I)cp:ul:ncnl ul I:nvu'uumrmal l>u:du � U+r i.iuu of\\alcr Nr.ourcc:
Q�� 12\onh Snlisbun Stnrt I I61 I Mail Scr\uc(cmcr I lUlcich.\o:ih(a:nlu;a'7049-1u11
TM e=--'^D—E
91 Q 7117 9090
Wes+r xwrr.s:-x "

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
Gvpar"vm�i of onrvMRMla OuNltr
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,
%clraet?D. R4w#, ;Vg
Water Resources Director
Water Resources Division
336-626-1201, ext: 2358
www.asheboronc.gov
i

♦ Asheboro
Mum us
•POWNWIFENAn rW uv[:If,%11
1
North Carolina 1
MAIN STREET
Community 2016
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
Email wrespondence to and from this address may be subject to the North Garclina Public Records Law and may be disclosed to thrd parties by an a.4ho!eed
stale official.
2

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REASONABLE POTENTIAL ANALYSIS
H1 Use'PASTE SPECIAL H2Use"PASTE SPECIAL
Effluent Hardness Values"Maximum
coat/ Upstream Hardness va Maxes"mu coav
Maximum data Maximum data
points=58 points=58
Date Data BDL=112DL Results ___ Date Data BDL=112DL Results
1 6/8/2017 99.8 99.8 Std Dev. 13.0463 1 8/29/2016 106 106 Std Dev. 21.5387
2 7/12/2017 108 108 Mean 86.2455 2 911312016 40 40 Mean 51.9333
3 12/5/2019 86 86 C.V. 0.1513 3 10/19/2016 49 49 C.V. 0.4147
4 12/12/2019 76 76 n 11 4 11/2/2016 69 69 n 12
5 12119/2019 58 58 10th Per value 76.00 mg/L 5 12/6/2016 28 28 10th Per value 34.50 mg/L
6 12123/2019 94 94 Average Value 86.25 mg/L 6 1/11/2017 73 73 Average Value 51.93 mg/L
7 315/2020 84 84 Max.Value 108.00 mg/L 7 2/2/2017 39 39 Max.Value 106.00 mg/L
8 3/12/2020 88.2 88.2 8 3/7/2017 49 49
9 3/20/2020 84.3 84.3 9 4/11/2017 53 53
10 3/30/2020 79.4 79.4 10 5/10/2017 34 34
11 6/2412021 91 91 11 6/8/2017 43.7 43.7
12 12 7/12/2017 39.5 39.5
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
26123 FW RPA UPDATED.data
1- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Pdrl11 8 Par02
Use'PASTE SPECIAL
Arsenic Values"then"COPY"
Maximum data
points=58
Dale Data BDL=112DL Results _
1 1/23/2018 < 2 1 Std Dev. 0,5382
2 2/14/2018 < 2 1 Mean 1.1375
3 3/6/2018 4.2 4.2 C.V. 0.4731
4 4/18/2018 < 2 1 n 56
5 5/22/2018 < 2 1
6 6/5/2018 < 2 1 Mult Factor= 1.01
7 7/24/2018 < 2 1 Max.Value 4.2 ug/L
8 8/15/2018 < 5 2.5 Max.Pred Cw 4.2 ug/L
9 9/1312018 < 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 7125/2019 < 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 1113/2021 < 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 1113/2022 < 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 8111/2022 < 2 1
57
58
26123 FW RPA UPDATED,data
.2- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par03 Use"PASTE SPECIAL Par04 Use"PASTE SPECIAL
Beryllium Values"then"COPY' Cadmium Values"then"COPY'
Maximum data Maximum data
points=5F points=58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 3/17/2016 < 1 0.5 Std Dev. 0.0000 1 1/23/2018 < 0.5 0.25 Std Dev. 0.0334
2 12/5/2019 < 1 0.5 Mean 0.5000 2 2/14/2018 < 0.5 0.25 Mean 0.2545
3 3/5/2020 < 1 0.5 C.V.(default) 0.6000 3 3/6/2018 < 0.5 0.25 C.V. 0.1313
4 6/24/2021 < 1 0.5 n 4 4 4/18/2018 < 0.5 0.25 n 56
5 5 5/22/2018 < 0.5 0.25
6 Mult Factor= 2.59 6 6/5/2018 < 0.5 0.25 Mult Factor= 1.00
7 Max.Value 0.50 ug/L 7 7/24/2018 < 0.5 0.25 Max.Value 0.500 ug/L
8 Max.Pred Cw 1.30 ug/L 8 8/1512018 < 0.5 0.25 Max.Fred Cw 0.500 ug/L
9 9 9/13/2018 < 0.5 0.25
10 10 10/1712018 < 0.5 0.25
11 11 11/6/2018 < 0.5 0.25
12 12 12/4/2018 < 0.5 0.25
13 13 1/10/2019 < 0.5 0.25
14 14 2/12/2019 < 0.5 0.25
15 15 3/512019 < 0.5 0.25
16 16 4/16/2019 < 0.5 0.25
17 17 5/22/2019 < 0.5 0.25
18 18 6/4/2019 < 0.5 0.25
19 19 7/25/2019 < 0.5 0.25
20 20 8/6/2019 < 0.5 0.25
21 21 9/10/2019 < 0.5 0.25
22 22 10/10/2019 < 0.5 0.25
23 23 11/712019 < 0.5 0.25
24 24 12/5/2019 < 1 0.5
25 25 1/8/2020 < 0.5 0.25
26 26 211312020 < 0.5 0.25
27 27 3/5/2020 < 0.5 0.25
28 28 4/7/2020 < 0.5 0.25
29 29 5/20/2020 < 0.5 0.25
30 30 612/2020 < 0.5 0.25
31 31 7/14/2020 < 0.5 0.25
32 32 8/19/2020 < 0.5 0.25
33 33 9/15/2020 < 0.5 0.25
34 34 10/22/2020 < 0.5 0.25
35 35 11/11/2020 < 0.5 0.25
36 36 12/8/2020 < 0.5 0.25
37 37 1/1312021 < 0.5 0.25
38 38 2/16/2021 < 0.5 0.25
39 39 312/2021 < 0.5 0.25
40 40 4/14/2021 < 0.5 0.25
41 41 5/21/2021 < 0.5 0.25
42 42 6/24/2021 < 0.5 0.25
43 43 7/28/2021 < 0.5 0.25
44 44 8119/2021 < 0.5 0.25
45 45 9/14/2021 < 0.5 0.25
46 46 10/27/2021 < 0.5 0.25
47 47 11/10/2021 < 0.5 0.25
48 48 1217/2021 < 0.5 0.25
49 49 1113/2022 < 0.5 0.25
50 50 2/17/2022 < 0.5 0.25
51 51 3/8/2022 < 0.5 0.25
52 52 4/13/2022 < 0.5 0.25
53 53 5/12/2022 < 0.5 0.25
54 54 6/7/2022 < 0.5 0.25
55 55 7/18/2022 < 0.5 0.25
56 56 8111/2022 < 0.5 0.25
57 57
58 58
26123 FW RPA UPDATED,data
-3- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par05 Use"PASTE Par07 Use"PASTE
SPECIAL-Values" - - — _ SPECIAL-
Chlorides then-COPY' Total Phenolic Compounds Values"then
Maximum ddla
"COPY,.
points-..58 Maximum data
Date Data BDL=1/2DL Results _ Date Data BDL=1/2DL Results pomts=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 1218/2020 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 4114/2021 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 10127/2021 198 198 22
23 11/10/2021 189 189 23
24 12/712021 212 212 24
25 318/2022 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 Pall
_Use"PASTE SPECIAL Use"PASTE SPECIAL
Chromium,Total Values"then"COPY" COPpBf Values"then"COPY"
Maximum data Maximum data
points=58 points=58
Date Data BDL=112DL Results Date Data BDL=1/2DL Results
1 1/23/2018 < 5 2.5 Std Dev. 1.6920 1 1/23/2018 6.9 6.9 Std Dev. 1.5802
2 2/14/2018 < 5 2.5 Mean 3.0679 2 2114/2018 6.6 6.6 Mean 6.4946
3 3/6/2018 < 5 2.5 C.V. 0.5515 3 3/6/2018 8 8 C.V. 0.2433
4 4/18/2018 < 5 2.5 n 56 4 4/18/2018 6.7 6.7 n 56
5 5/22/2018 < 5 2.5 5 5/22/2018 5.4 5.4
6 6/512018 < 5 2.5 Mult Factor= 1.01 6 615/2018 7.2 7.2 Mult Factor= 1.00
7 7124/2018 < 5 2.5 Max.Value 10.7 Ng/L 7 7/24/2018 5.8 5.8 Max.Value 11.80 ug/L
8 8/15/2018 < 5 2.5 Max.Pred Cw 10.8 Ng/L 8 8/15/2018 6.2 6.2 Max.Pred Cw 11.80 uglL
9 9/13/2018 10.7 10.7 9 9/13/2018 7.5 7.5
10 10/17/2018 9.9 9.9 10 10/17/2018 6.1 6.1
11 11/6/2018 6.4 6.4 11 1116/2018 7.2 7.2
12 12/4/2018 < 5 2.5 12 12/4/2018 7.4 7.4
13 1/10/2019 5.8 5.8 13 1/10/2019 9.6 9.6
14 2/12/2019 < 5 2.5 14 2/12/2019 6.5 6.5
15 3/5/2019 < 5 2.5 15 3/5/2019 5.6 5.6
16 4/16/2019 < 5 2.5 16 4/16/2019 3.5 3.5
17 5/22/2019 5.1 5.1 17 5/22/2019 5.7 5.7
18 6/4/2019 < 5 2.5 18 6/4/2019 5.9 5.9
19 7/25/2019 < 5 2.5 19 7/25/2019 5 5
20 8/6/2019 < 5 2.5 20 8/6/2019 6 6
21 9/10/2019 < 5 2.5 21 9/10/2019 6.7 6.7
22 10/10/2019 5.4 5.4 22 10/10/2019 9.5 9.5
23 11/7/2019 < 5 2.5 23 11/7/2019 5.4 5.4
24 12/5/2019 6 6 24 12/512019 < 10 5
25 1/812020 < 5 2.5 25 1/8/2020 7.6 7.6
26 2/13/2020 < 5 2.5 26 2/13/2020 5.6 5.6
27 3/5/2020 < 5 2.5 27 3/5/2020 7 7
28 417/2020 < 5 2.5 28 4/7/2020 5.6 5.6
29 5/20/2020 < 5 2.5 29 5/20/2020 6.7 6.7
30 6/2/2020 < 5 2.5 30 6/2/2020 10.4 10.4
31 7/14/2020 < 5 2.5 31 7/14/2020 5.6 5.6
32 8/19/2020 < 5 2.5 32 8/19/2020 5.6 5.6
33 9/15/2020 < 5 2.5 33 9/15/2020 5.2 5.2
34 10/22/2020 < 5 2.5 34 10/22/2020 5.4 5.4
35 11/1112020 < 5 2.5 35 11/11/2020 4.6 4.6
36 12/8/2020 < 5 2.5 36 1218/2020 5.2 5.2
37 1/13/2021 < 5 2.5 37 1/13/2021 5.5 5.5
38 2/16/2021 < 5 2.5 38 2/16/2021 3.7 3.7
39 3/2/2021 < 5 2.5 39 3/2/2021 4.2 4.2
40 4/14/2021 < 5 2.5 40 4/14/2021 6.1 6.1
41 5/21/2021 < 5 2.5 41 5/21/2021 7.7 7.7
42 6/24/2021 < 5 2.5 42 6/24/2021 9 9
43 7128/2021 < 5 2.5 43 7/28/2021 7.7 7.7
44 8/19/2021 < 5 2.5 44 8/19/2021 6.7 6.7
45 9/14/2021 < 5 2.5 45 9/14/2021 7.9 7.9
46 10/27/2021 < 5 2.5 46 10/27/2021 11.8 11.8
47 11/10/2021 < 5 2.5 47 11/10/2021 6.9 6.9
48 12/7/2021 < 5 2.5 48 12/7/2021 9.1 9.1
49 1/13/2022 < 5 2.5 49 1/13/2022 7.3 7.3
50 2/17/2022 < 5 2.5 50 2/17/2022 6.2 6.2
51 318/2022 < 5 2.5 51 3/8/2022 5.4 5.4
52 4/13/2022 < 5 2.5 52 4/13/2022 5 5
53 5/12/2022 < 5 2.5 53 5/12/2022 6.1 6.1
54 6/7/2022 < 5 2.5 54 6/7/2022 5.3 5.3
55 7/18/2022 < 5 2.5 55 7/18/2022 6.2 6.2
56 8/11/2022 < 5 2.5 56 8/11/2022 6 6
57 57
58 58
26123 FW RPA UPDATED,data
-5- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Paf12 Paf14
Use"PASTE SPECIAL _ Use"PASTE SPECIAL
Cyanide Values"then"COPY" Lead Values"then-COPY"
Maximum data Maximum data
points a 58 points=58
Date Data BDL=112DL Results Date BDL=1/2DL Results _
1 3/6/2018 < 10 5 Std Dev. 0.0000 1 1/23/2018 < 2 1 Std Dev. 0,4316
2 615/2018 < 10 5 Mean 5.00 2 2/14/2018 < 2 1 Mean 1.1339
3 9/13/2018 < 10 5 C.V. 0,0000 3 316/2018 < 2 1 C.V. 0.3806
4 12/4/2018 < 5 5 n 26 4 4/1812018 < 2 1 n 56
5 3/5/2019 < 5 5 5 5/22/2018 < 5 2.5
6 6/4/2019 < 5 5 Mult Factor= 1.00 6 615/2018 < 2 1 Mult Factor= 1.01
7 9/10/2019 < 5 5 Max.Value 5.0 ug/L 7 7/24/2018 < 5 2.5 Max.Value 2.500 ug/L
8 12/5/2019 < 5 5 Max.Pred Cw 5.0 ug/L 8 8/15/2018 < 5 2.5 Max.Fred Cw 2.525 ug/L
9 3/5/2020 < 5 5 9 9/13/2018 < 5 2.5
10 4/7/2020 < 5 5 10 10/17/2018 < 2 1
11 9/15/2020 < 5 5 11 11/6/2018 < 2 1
12 12/8/2020 < 5 5 12 12/412018 < 2 1
13 1/13/2021 < 5 5 13 1/10/2019 < 2 1
14 2/16/2021 < 5 5 14 2/12/2019 < 2 1
15 3/212021 < 5 5 15 3/5/2019 < 2 1
16 4/14/2021 < 5 5 16 4/16/2019 < 2 1
17 5/21/2021 < 5 5 17 5/22/2019 < 2 1
18 6/24/2021 < 5 5 18 6/4/2019 < 2 1
19 7/28/2021 < 5 5 19 7/25/2019 < 2 1
20 8/19/2021 < 5 5 20 8/612019 < 2 1
21 9/14/2021 < 5 5 21 9/10/2019 < 2 1
22 10/27/2021 < 5 5 22 10/10/2019 < 2 1
23 11/10/2021 < 5 5 23 11/7/2019 < 2 1
24 12/7/2021 < 5 5 24 12/5/2019 < 5 2.5
25 3/8/2022 < 5 5 25 1/8/2020 < 2 1
26 6l7/2022 < 5 5 26 2/13/2020 < 2 1
27 27 3/5/2020 < 2 1
28 28 4/7/2020 < 2 1
29 29 5/20/2020 < 2 1
30 30 6/2/2020 < 2 1
31 31 7/14/2020 < 2 1
32 32 8/19/2020 < 2 1
33 33 9115/2020 < 2 1
34 34 10/22/2020 < 2 1
35 35 11/11/2020 < 2 1
36 36 12/8/2020 < 2 1
37 37 1/13/2021 < 2 1
38 38 2/16/2021 < 2 1
39 39 3/2/2021 < 2 1
40 40 4/14/2021 < 2 1
41 41 5/21/2021 < 2 1
42 42 6/24/2021 < 2 1
43 43 7/28/2021 < 2 1
44 44 8/19/2021 < 2 1
45 45 9/14/2021 < 2 1
46 46 10/27/2021 < 2 1
47 47 11/10/2021 < 2 1
48 48 12/7/2021 < 2 1
49 49 1/13/2022 < 2 1
50 50 2/17/2022 < 2 1
51 51 3/8/2022 < 2 1
52 52 4/13/2022 < 2 1
53 53 5/12/2022 < 2 1
54 54 6/7/2022 < 2 1
55 55 7/18/2022 < 2 1
56 56 8/11/2022 < 2 1
57 57
58 58
26123 FW RPA UPDATED,data
-6- 10/1312022

REASONABLE POTENTIAL ANALYSIS
Par16 Par17&Par18
Use"PASTE SPECIAL Use"PASTE SPECIAL
Molybdenum Values"then"COPY' Nickel Values'•then"COPY"
Maximum data .Maximum data
points=58 points=58
Date Data BDL=112DL Results Date Data BDL=1/2DL Results
1 1/2312018 35.9 35.9 Std Dev. 49.5015 1 1/2312018 < 2 1 Std Dev. 4.2677
2 2/1412018 169 169 Mean 51.7125 2 2/14/2018 2.3 2.3 Mean 3.5661
3 3/6/2018 123 123 C.V. 0.9572 3 3/6/2018 2.2 2.2 C.V. 1.1967
4 4/18/2018 21 21 It 56 4 4/18/2018 2.3 2.3 n 56
5 5/22/2018 29.3 29.3 5 5/22/2018 < 2 1
6 6/512018 67.4 67.4 Mull Factor= 1.02 6 6/5/2018 3.3 3.3 Mult Factor= 1.02
7 7/24/2018 59.8 59.8 Max.Value 272.0 ug/L 7 7/24/2018 < 5 2.5 Max.Value 33.0 Ng/L
8 8/15/2018 63.2 63.2 Max Pred Cw 277.4 ug/L 8 8/1512018 < 5 2.5 Max.Pred Cw 33.7 Ng/L
9 9/13/2018 272 272 9 9/13/2018 33 33
10 10/17/2018 59.9 59.9 10 10117/2018 9 9
11 11/6/2018 37 37 11 11/6/2018 4.7 4.7
12 12/412018 92.8 92.8 12 12/4/2018 3.8 3.8
13 1/10/2019 27.1 27.1 13 1/10/2019 64 6.4
14 2/12/2019 22.3 22.3 14 2/12/2019 6.3 6.3
15 3/5/2019 < 10 5 15 315/2019 2.9 2.9
16 4/16/2019 17.6 17.6 16 4/16/2019 2.3 2.3
17 5/22/2019 108 108 17 5122/2019 3.7 3.7
18 6/4/2019 25.1 25.1 18 6/4/2019 3.1 3.1
19 7125/2019 30.3 30.3 19 7/25/2019 3.8 3.8
20 8/6/2019 28.4 28.4 20 8/6/2019 3.7 3.7
21 9/10/2019 38.2 38.2 21 9/10/2019 4.5 4.5
22 10/10/2019 82 82 22 10/10/2019 3.9 3.9
23 11/7/2019 55.9 55.9 23 11/7/2019 3.5 3.5
24 12/5/2019 < 50 25 24 12/5/2019 < 10 5
25 1/8/2020 37.2 37.2 25 1l8/2020 2.3 2.3
26 2/13/2020 17.2 17.2 26 2/13/2020 2,5 2.5
27 3/512020 14 14 27 3/5/2020 5 5
28 4/7/2020 21.6 21.6 28 4l7/2020 2.8 2.8
29 5/20/2020 126 126 29 5/20/2020 2.5 2.5
30 6/2/2020 34.8 34.8 30 6/2/2020 2.8 2.8
31 7/14/2020 43.7 43.7 31 7/14/2020 3.9 3.9
32 8/19/2020 24 24 32 8/19/2020 2.9 2.9
33 9115/2020 159 159 33 9/15/2020 3.1 3.1
34 10/22/2020 28 28 34 10/2212020 4.7 4.7
35 11/11/2020 15.8 15.8 35 11/11/2020 3.3 3.3
36 12/8/2020 38.7 38.7 36 12/8/2020 < 2 1
37 1/13/2021 24.1 24.1 37 1/13/2021 2.4 2.4
38 2/16/2021 < 10 5 38 2/16/2021 2.1 2.1
39 3/2/2021 < 10 5 39 312/2021 < 2 1
40 4/1412021 17.8 17.8 40 4/14/2021 2.4 2.4
41 5/2112021 22.1 22.1 41 5/21/2021 2.8 2.8
42 6/24/2021 33 33 42 6/24/2021 4 4
43 7/28/2021 22.1 22.1 43 7/28/2021 3.6 3.6
44 8/19/2021 29.3 29.3 44 8/19/2021 < 2 1
45 9/14/2021 32.7 32.7 45 9/14/2021 2.9 2.9
46 10/27/2021 32.9 32.9 46 10/27/2021 3.3 3.3
47 11/10/2021 125 125 47 11/10/2021 2.8 2.8
48 12/7/2021 47.4 47.4 48 12/7/2021 3 3
49 1/13/2022 42.1 42.1 49 1/13/2022 2.6 2.6
50 2117/2022 30.3 30.3 50 2/17/2022 2.3 2.3
51 3/8/2022 28.5 28.5 51 3/8/2022 < 2 1
52 4/13/2022 43.2 43.2 52 4/13/2022 < 2 1
53 5/12/2022 83.7 83.7 53 5/12/2022 2.2 2.2
54 6/7/2022 151 151 54 6/7/2022 2.2 2.2
55 7/18/2022 25 25 55 7/18/2022 2.6 2.6
56 8/1112022 40.5 40.5 56 8/11/2022 < 2 1
57 57
58 58
26123 FW RPA UPDATED,data
-7- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par19 Par20 Use"PASTE
Use"PASTE SPECIAL-
Values"then"COPY". SPECIAL-Values'
Selenium Maximum oata points= Silver then"COPY"
58 Maximum data points
=58
Date Data BDL=1/2DL Results Date Data BDL=112DL Results
1 7/25/2019 1.5 1.5 Std Dev. 0.6416 1 7/25/2019 < 1 0.5 Std Dev. 0.3797
2 8/6/2019 < 1 0.5 Mean 0.9703 2 8/6/2019 < 1 0.5 Mean 0.5973
3 9/1012019 2.1 2.1 C.V. 0.6612 3 9/10/2019 < 1 0.5 C.V. 0.6357
4 10/1012019 2.6 2.6 n 37 4 10/10/2019 < 1 0.5 n 37
5 11/7/2019 < 1 0.5 5 11/7/2019 < 1 0.5
6 1/8/2020 < 1 0.5 Mult Factor= 1.14 6 1/8/2020 < 1 0.5 Mult Factor= 1.14
7 2/13/2020 < 1 0.5 Max.Value 2.6 ug/L 7 2/13/2020 < 1 0.5 Max.Value 2.600 ug/L
8 3/5/2020 < 1 0.5 Max.Fred Cw 3.0 ug/L 8 3/5/2020 < 1 0.5 Max.Fred Cw 2.964 ug/L
9 4/7/2020 1.2 1.2 9 4/7/2020 < 1 0.5
10 5120/2020 < 1 0.5 10 5120/2020 < 1 0.5
11 6/2/2020 < 1 0.5 11 6/2/2020 < 1 0.5
12 7/14/2020 < 1 0.5 12 7/14/2020 < 1 0.5
13 8/19/2020 < 1 0.5 13 8/19/2020 < 1 0.5
14 9/15/2020 < 1 0.5 14 9/15/2020 < 1 0.5
15 10/22/2020 < 1 0.5 15 10/22/2020 < 1 0.5
16 11111/2020 < 1 0.5 16 11/11/2020 < 1 0.5
17 12/8/2020 < 1 0.5 17 12/8/2020 < 1 0.5
18 1/13/2021 < 1 0.5 18 1/13/2021 < 1 0.5
19 2116/2021 < 1 0.5 19 2/16/2021 < 1 0.5
20 312/2021 < 1 0.5 20 3/2/2021 < 1 0.5
21 4/14/2021 1.2 1.2 21 4/14/2021 < 1 0.5
22 5/21/2021 1.4 1.4 22 5121/2021 < 1 0.5
23 6/24/2021 < 1 0.5 23 6/24/2021 < 1 0.5
24 7/28/2021 < 1 0.5 24 7/28/2021 1.2 1.2
25 8/19/2021 2.1 2.1 25 8/19/2021 1.3 1.3
26 9/14/2021 1.4 1.4 26 9/14/2021 < 1 0.5
27 10127/2021 < 1 0.5 27 10/27/2021 2.6 2.6
28 11/10/2021 < 1 0.5 28 11/10/2021 < 1 0.5
29 12/7/2021 2 2 29 12/7/2021 < 1 0.5
30 1/13/2022 1.9 1.9 30 1/13/2022 < 1 0.5
31 2/17/2022 < 1 0.5 31 2117/2022 < 1 0.5
32 3/8/2022 < 1 0.5 32 3/8/2022 < 1 0.5
33 4113/2022 1 1 33 4/13/2022 < 1 0.5
34 5/12/2022 2.1 2.1 34 5/12/2022 < 1 0.5
35 6/7/2022 1.6 1.6 35 6/7/2022 < 1 0.5
36 7/18/2022 1.3 1.3 36 7/18/2022 < 1 0.5
37 8/11/2022 1.5 1.5 37 8/11/2022 < 1 0.5
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
-8- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par21 Use"PASTE SPECIAL Par22 Use"PASTE SPECIAL
Zinc Values then"COPY" Bromodichloromethane Values"then"COPY"
Maximum data Maximum dal.
points=58 points=58
Date Data BDL=1/2DL Results _ Date Data BDL=112DL Results
1 1123/2018 24.6 24.6 Std Dev. 17.1465 1 3/8/2018 6.3 6.3 Sid Dev. 10.2278
2 2/14/2018 18.5 18.5 Mean 21.6804 2 6/512018 24.4 24.4 Mean 16.1456
3 3/6/2018 33.8 33.8 C.V. 0.7909 3 9/13/2018 18.6 18.6 C.V. 0.6335
4 4/18/2018 18.7 18.7 n 56 4 12/6/2018 < 5 2.5 n 18
5 5/22/2018 20.4 20.4 5 3/7/2019 < 5 2.5
6 615/2018 12.5 12.5 Mult Factor= 1.01 6 6/6/2019 20.6 20.6 Mull Factor= 1.44
7 7/2412018 < 20 10 Max.Value 100.0 ug/L 7 9/12/2019 26.6 26.6 Max.Value 36.000000 Ng/L
8 8/15/2018 < 20 10 Max.Pred Cw 101.0 ug/L 8 12/5/2019 8.94 8.94 Max.Fred Cw 51.840000 Ng/L
9 9/13/2018 < 20 10 9 3/512020 9.02 9.02
10 10117/2018 10.2 10.2 10 6/4/2020 19.4 19.4
11 11/6/2018 24.9 24.9 11 9/30/2020 17.4 17.4
12 12/4/2018 56.7 56.7 12 12/10/2020 11.7 11.7
13 1110/2019 82.9 82.9 13 3/4/2021 10.3 10.3
14 2/12/2019 53.1 53.1 14 6/24/2021 26.9 26.9
15 3/5/2019 35.1 35.1 15 9/30/2021 33.1 33.1
16 4/16/2019 20.5 20.5 16 12/9/2021 10.7 10.7
17 5/22/2019 16.9 16.9 17 3/10/2022 5.66 5.66
18 6/4/2019 < 20 10 18 6/9/2022 36 36
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 11/712019 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 5120/2020 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 10/2212020 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 7128/2021 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 11/1012021 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 7118/2022 < 10 5 55
56 8111Y2022 13.3 13.3 56
57 57
58 58
26123 FW RPA UPDATED,data
-9- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par23 Use"PASTE Par24 Use"PASTE
SPECIAL-Values" -- SPECIAL-Values"
Dibromochloromethane then"COPY" Chloroform then"COPY"
Maximum points=58 data Maximum data
Date Data BDL=112DL Results Date Data BDL=112DL Results points=58
1 3/8/2018 < 5 2.5 Std Dev. �5 1615 1 3/17/2016 13.4 13.4 Sid Dev. 8.4346
2 6/5/2018 7.4 7.4 Mean 6.6161 2 1215/2019 19 19 Mean 21.7250
3 9/13/2018 < 5 2.5 C.V. 0.7801 3 3/5/2020 21.1 21.1 C.V.(default) 0.60
4 12/6/2018 < 5 2.5 n 18 4 6/24/2021 33.4 33.4 n 4
5 3/7/2019 < 5 2.5 5
6 6/6/2019 6.26 6.26 Mull Factor= 1.54 6 Mult Factor= 2.59
7 9/12/2019 13 13 Max.Value 17.200000 pg/L 7 Max.Value 33.40 ug/L
8 12/512019 < 5 2.5 Max.Pred Cw 26.488000 pg/L 8 Max.Pred Cw 86.51 Vg/L
9 3/5/2020 < 5 2.5 9
10 6/4/2020 10.1 10.1 10
11 9/30/2020 5.55 5.55 11
12 12/10/2020 < 5 2.5 12
13 3/4/2021 < 5 2.5 13
14 6124/2021 12.2 12.2 14
15 9/30/2021 16.6 16.6 15
16 1219/2021 8.28 8.28 16
17 3/10/2022 < 5 2.5 17
18 6/9/2022 17.2 17.2 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
26123 FW RPA UPDATED.data
-10- 10/13/2022

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REASONABLE POTENTIAL ANALYSIS
1,4-Dioxane values^then"COPY"
Maximum data
points=58
Date Data BDL=1/2DL Results
1 7/8/2021 88.4 88.4 Std Dev. 123.1529
2 7/16/2021 153 153 Mean 83.7071
3 7/20/2021 34.2 34.2 C.V. 1.4712
4 7/23/2021 55.7 55.7 n 58
5 7/30/2021 115 115
6 8/6/2021 334.4 334.4 Mull Factor= 1.0000
7 8/1312021 25.2 25.2 Max.Value 636.0 pg/L
8 8120/2021 55.6 55.6 Max.Fred Cw 636.0 pg/L
9 8127/2021 64.6 64.6
10 9/1/2021 58.9 58.9
11 9/10/2021 70.2 70.2
12 9/17/2021 63.9 63.9
13 10/1/2021 37.5 37.5
14 10/812021 44.5 44.5
15 10/15/2021 114 114
16 10/21/2021 548 548
17 10/29/2021 636 636
18 11/19/2021 5.04 5.04
19 11/22/2021 10.3 10.3
20 11/5/2021 75.3 75.3
21 11/12/2021 3.82 3.82
22 11/19/2021 5.04 5.04
23 11/22/2021 10.3 10.3
24 12/3/2021 59.7 59.7
25 12/10/2021 2.7 2.7
26 12/17/2021 11.3 11.3
27 12/21/2021 2 2
28 1/7/2022 102 102
29 1/14/2022 26.9 26.9
30 1/20/2022 3.06 3.06
31 1/28/2022 25.2 25.2
32 2/4/2022 74.7 74.7
33 2/11/2022 107 107
34 2/18/2022 34.6 34.6
35 2/2512022 133 133
36 3/4/2022 25 25
37 3/11/2022 136 136
38 3/18/2022 44.3 44.3
39 3/25/2022 15.1 15.1
40 4/1/2022 46.3 46.3
41 4/8/2022 16.75 16.75
42 4/12/2022 28.7 28.7
43 4/22/2022 82.8 82.8
44 4/29/2022 11.3 11.3
45 5/6/2022 63.2 63.2
46 5/13/2022 22.8 22.8
47 5/20/2022 31.9 31.9
48 5/27/2022 135 135
49 61312022 21.9 21.9
50 6/10/2022 48.5 48.5
51 6/17/2022 20 20
52 6/24/2022 144 144
53 7/8/2022 149 149
54 7/22/2022 449 449
55 8/5/2022 66.8 66.8
56 8/12/2022 33.8 33.8
57 9/16/2022 45.9 45.9
58 9/23/2022 25.9 25.9
Copy of 9595 GENERIC RPA2018_01-1,4-Dioxane.data
1- 12/5/2022

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IWC Calculations
Facility: Asheboro WWTP
NCO026123
Prepared By: Nick Coco
Enter Design Flow (MGD): 9
Enter s7Q10 (cfs): 0
Enter w7Q10 (cfs): 0
Total Residual Chlorine (TRC) Ammonia (Summer)
Daily Maximum Limit (ug/1) 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: 200/100-, 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/l
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)

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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 15 ) 3 1 NC0026123 I11 12 22/05/10 17 18 L 19I � I 201 I
21111111111111111111111111111111111111111111 r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------- Reserved
67 70L J 71 Lj 72 LJ 73t t74 71 1 1 1 I 80
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 oermit Number) 10:OOAM 22/05/10 12/08/01
Asheboro WWTP
te
1032 Bonkemeyer Dr Exit Time/Da 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
John N Ogburn,PO Box 1106 Asheboro NC 272041106lCity Contacted
Manager/336-626-121313366261218 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# 1

NPDES yr/mo/day Inspection Type (Cont.) 1
31 NCO026123 I11 121 22/05/10 117 18 I p I
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# 2

Permit: NC0026123 Owner-Facility: Asheboro WWfP
Inspection Date: 05/10/2022 Inspection Type: Pretreatment Compliance
Yes No NA NE
Page# 3

Al8 C I D I E I F I G I H I I I J I K I L IM N1 O 1 F
I Pollutants of Concern(POC)Review Form V—exr 2022 OS 2.
2 1.Facility's General Information
3 Dale or I.Al Re...w C POC review due to a Contact Informalion
Dale of(1:ral)Rewuw r�.r�� KI-Pal NPDESrarrewel D Regional Daea(ROI Wrnc;Y,n$,titn
5 NPDES Pemel Wnl"(,-I N"A Cana -A ATITMP RL+Nesv Q RO PT Sian P.,"SP S
6 P-tl-Fecal,Name Asheboro WWTP Ncw Irdualnm 0 Fachly PT Sus.amml Sarah Laudtlin.dauaNlMdvd ssheloro nc
7 NPDES Pemllr Nurrlba N00026123 'WTPnpansrm 0 1 Receiving Stream
6 NPDES P"ml EhaWe Dale 1D'1 r2023 Sacam rKlm4leUlusNnnrl )] Curtail
9 C1111-Addadum Sabmalal Data P712022 Ibl rebcaaaJadluslmenl D Ft..W g Su- H.x,k-Cry,. CA.crs 1,2
10 NPDES Parma Pact,WIC,Dec 12112022,Rrblic Hearklg on 5.12.V20i'. 7010 update Q Sheam Claas C 7010(S).CIS 0
-WR desnal9aedhan Irutdla to NIrri+1] Mr PM nv4w bier","'Pe Nr' Qrfa.Lal U1100 11 QdaN Lag /9.47W
12 a.W WTP Capacity Summary
Outfall II
13 Cerenl Per--Fb mid 90 Dcsgned F1p" 5 n Ranag Scram OA cis
1a Pe MPP SIU Flex.mgd C 7 t2 d.IU Summary SP-Cu. 7010 its.
15 D.PT Docs.Summary 11u, polar La, Qarall Lag
16
11S Apxoval data S FL2G P. SIP. 14 IS In[xa a PW$,nlaku dewnslreaan N aw Facely's Out M(,)' D YES Q FIO
1]
LISTNIP epprmal dAlu 57r202C, gCIU. 7 Canm9ms
B
NSCIUS 7
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r-I,a Oil-
19
20 2.Industrial Users'Information. -
21 N --i U-ill)N,en dutm
e IU III,., IU Nar C—t-1l P.I-S S To-Pl IUP El--Dale
22
tl
COD h u.r„ 10(120
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23 fiw(2e1hy11ruy11 phlhelala palwvoY,oprmtl ICrma n-Decax Octade:arrn,2.1.b Trdllaa4raml
4 J Fr.ngee+hHMSWng PW rt SIC M92 PH.COO TKN M1WouryN,tkd(INanlresp,S-.wmhrg d hallar•m and 4NWy I.'a'Is) rWM2
( Uyj Lrarizor Maa4aWng Plait 2 SIC 3692 Clemunn Cyarvde Maga•ma Mercury NdU Sa.a Zrrm tlaarl rmpr,s4Ne Ia Lerk moe4achaxgl r,
25 LL
Z S -W Pxdic LLC SIC 2653 PH COD
26 Yll2J2
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29 _
Y Ia,'rlbu PLaa S SIC U 79 PH COD Crdmium Chn-I,,.C q Cv,-Ir Lead Nckal Saw.Zm 710 g-W20
3G
10 Re�IW:PIaM 6 51 YI r9 PH COD Crrdrrnum Clamrium CPPIP,C--La J IJNIreI$ilwe br TTO
I 9;'%!-1127
,f:1M firwae. SIC 2(u.r - -..
31 PH Cf3D 7'W2!12
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33
r3 R,rrdapiP;rAnq SIC 2011 r•r- •I. . '.Y,
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35
eommanl Rre::•n .+q w1dx.:
40
41 3.Status Of Pretreatment Program(check all that apply)
42 Status of Prelreatment Pro m_ check all that apply)
43 1 f8dinty,flag no SIDS,does have Orvrsion approved Prelfealment Pr ram that is INACTIVE
44 2)facility has no SIU'S.does not have Division approved Prelreatment Program I _ ---
45 3)fa has SIUs and DWO approved pretreatment Program -� -----
46 Sal Fug Program Will LTMP ---"--- -- - -- - -- - -
47 Q 3b)lMadified Program with STMP
4a a)elldi0oral oondllions regarding Pretreatment attached or listed below I - -- --'
49 5)Facility's sludge is being land applied or composted --- ------- --' -----
5GJ3 6)facility's sludge is incinerated(add Beryllium and Mercury sampling accad rI l0 503.43)
Si 7)faolitys sludge is taken to a landfill.4 Yes Which andfill r --------" -
52 6)other
53 Sludge Diapoael Plan[ IAM nPpq:.•hnr
v
55
56 Sludge Permit No; WODD01684
Pagc I PO(Rc:,lew turn.

A 8 C D I E I F I G I H I I I J K L M N O P
57 4.LTMPISTMP and HWA Review
58 PW Find USTMP document,HWA spreadsheet DMR,previous and new NPDES permit for next section
Parameter of Concern New Previous Required by POC due to POC due to POTW % LISTMP NPOES Comment
(POC)Check List NPDES NPDES EPA PT(i) Sludge(2) SIU(3) POC(4)Removal Effluent Freq. Effluent Freq.
H POC POC Rate POLs renew
c_
59 V
a- POL from Required POL Re.—
L/STMP.ugo per NPDES POL.ug/I
60 Permit
61 Flow 0 0 ❑ MPmnN Coalmuoa
62 Boo 12 DIwnmry 0a4v
fi3 ❑. TSS 0 0 ❑ Mpmnry OaiN
NH3 0 0 0 E3Monrnry Daily
65 Arsenic ❑ ❑ —hry 2.0
66 ❑ Barium 13 ❑ ❑ Mmm�N
67 0 Berylbum(5) El ❑ El D 13Montnry
68 0 Cadmium(1) MonmN os
69 0 Chmmium(i) ❑ 0 0 ® 0 ❑ M4nthN s.0
70 0 Copper(l) 00 0 0 MontnN Duan.,N 2.0
7.1 0 CyanWa O ❑ ❑ 0 ❑ Monthlv
-- (a Leadill ❑ ❑ o at 0 ❑ Mamh/y 2.0
73 M.—y(5) O 0 0 0 ❑ NfadhN 4001
74 0 Molybdenum ❑ 0 0 El 13 Mosthry 10.0
75 0 Nickel(l) ❑ ❑ 0 0 0 ❑ Meo"ly
76 selenium 0 ❑ 0 0 0 an.,ne:N 141' 2.0
77 Silver ❑ ❑ G 0MavnN M1'Nn11iN 1 WJt 10
76 0 Zinc(l) ❑ 0 0 0 ❑ MernnN To.o
79 0 Sludge Flow to Disposal 0 ❑ ❑ M,n1hN
BD 0 %Solids to Disposal 0 0 ❑ Men1nN
81 ❑ Oil t Grease ❑ ❑ —01,
82 TN 13 O ❑ —hry
83 ❑ TP IL
❑ 13 EJMPrrtnN
84 ❑ PFAS 1633 0 ❑ ❑ ❑ Momnly uuane,N
85 ❑ 1 4 Mo.— 0E3 :/wsel I ue/I
B6 Manganese D ❑ (3 0 13nwmmv
87 0 Chlorides 0 ❑ ❑ Duanv:N
88 ❑ ❑ ❑ ❑ :89
❑ ❑ ❑
90 ❑
91 Footnotes:
22 (1)Nwaysnaa,LTA1PISTMP tlnaro EPA-PT,cauew,enl
93 I2)Only in LTMP,STMPdsslWnslWgo pent
94 (3)Only in LTMP,STMP w W SIU SIU dacnages le POTW
55 (4)Only n LTMPGTMP Mh,pdfulad a of cdxdn b POTW
46 (S)In LIMPISTa1P 4 sewage sludge is Yxmdaletl
57 P ass me blue ford for IIM Into up—by pW',
98 Plesse uae red tom for POC me,rrW 1e be adileefw ME In USTMP aanpY ple. )
95 Pis.e.roe«erge4orw.r.IMrwreae«MrJ«PBG w.lwrara..enrn..aM.w1I6SY{+Veu;l..r....y.r.ro r.w. _
100 Blue shatlW ceA(IyGe.N8f I Persrelds usudly vaAltlOd antler Ihal POC 41
101 5.Comments
Facihty Summaryibackgfound mfoonal,mINPDES-PT regulatory action
PocrooeaatlW,madaed USTMP
.02
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Addlimal WOW S adddl Ip USTMP due
105 Ip POTws cmcdns
NPDES pw's mmnxnls a,ILJIPDC
1n; 6.Prelmtmenf upoates in response to NPDES permit renewal
10F NPDES Pen„11 EH-1—D.I. c c,Ir!.,r

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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 C 2.2 FW Miles
4126 From US 220 business to Subbasin 03-06-08 and 03-06-09 boundary
2022 Water Quality Assessments
:PARAMETER IR CATEGORY CRITERIA STATUS
Water Temperature (322C, AL, LP&CP) 1 Meeting Criteria
Dissolved Oxygen (4 mg/I, AL, FW) 1 Meeting Criteria
pH (6 su, AL, FW) 1 Meeting Criteria
pH (9.0, AL, FW) 1 Meeting Criteria
Turbidity (50 NTU, AL, FW miles) 1 Meeting Criteria
Chloride (230 mg/I, AL, FW) 3a Data Inconclusive
Flouride (1.8 mg/I, AL, FW) 3a Data Inconclusive
1,4-Dioxane in Water(80 µg/I, AL, FW) 3a Data Inconclusive
Fecal Coliform (GM 200/400, REC, FW) 3a Data Inconclusive
DEEP RIVER 17-(10.5)dl C 2.7 FW Miles
4128 From Haskett Creek to Gabriels Creek
2022 Water Quality Assessments
PARAMETER IR CATEGORY CRITERIA STATUS
Water Temperature (322C, AL, LP&CP) 1 Meeting Criteria
Dissolved Oxygen (4 mg/I, AL, FW) 1 Meeting Criteria
pH (6 su, AL, FW) 1 Meeting Criteria
�pH (9.0, AL, FW) 1 Meeting Criteria
Turbidity (50 NTU, AL, FW miles) 1 Meeting Criteria
Fecal Coliform (GM 200/400, REC, FW) 3a Data Inconclusive
Chlorophyll a (40 µg/I, AL, NC) 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 1N 1 2 15 1 3 I NCO026123 I11 121 22/01/27 I17 18n 19 L S f 20I I
211111 1 I I 1 1 I II 1 1 1 1 1 I I I I I I I I I I I I I I I I I I II 1 1 1 1 1 f6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 CA --- Reserved-------------------
67 70 u I I 711 L I 72 I r, I 73I I I74 751 I I I I I I I80
Section B: Facility Data LJ W 1
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 12l08/01
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 8 Maintenar N 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 DWRANSRO 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# 1

NPDES yr/mo/day Inspection Type (Cont.) 1
NC0026 I11 12I 22/01/27 117 18 ICI
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# 2

Permit: NCO026123 Owner-Facility: Asheboro WWTP
Inspection Date: 01/27/2022 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new 1:1 ❑ ❑ ❑
application?
Is the facility as described in the permit? 0 ❑ ❑ ❑
#Are there any special conditions for the permit? ❑ 0 ❑ ❑
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 Yes No NA NE
Are records kept and maintained as required by the permit? M ❑ ❑ ❑
Is all required information readily available, complete and current? 0 ❑ ❑ ❑
Are all records maintained for 3 years (lab. reg. required 5 years)? e ❑ ❑ ❑
Are analytical results consistent with data reported on DMRs? El ❑ ❑ ❑
Is the chain-of-custody complete? El ❑ ❑ ❑
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? M ❑ ❑ ❑
(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? 0 ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? 0 ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility 0 ❑ ❑ ❑
classification?
Is a copy of the current NPDES permit available on site? 11 ❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review? Q ❑ ❑ ❑
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",

Permit: NCO026123 Owner-Facility: Asheboro yWdTP
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? ❑ ❑ ❑ ❑
Is the screen free of excessive debris? ❑ ❑ ❑ ❑
Is disposal of screening in compliance? 0 ❑ ❑ ❑
Is the unit in good condition? 0 ❑ ❑ ❑
Comment:
Grit Removal YES No NFL. NF
Type of grit removal
a.Manual ❑
b.Mechanical ❑
Is the grit free of excessive organic matter? ❑ ❑ ❑ ❑
Is the grit free of excessive odor? ❑ ❑ ❑ ❑
# Is disposal of grit in compliance? ❑ ❑ ❑ ❑
Comment: Grit removal by vortex.
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional? ❑ ❑ ❑ ❑
Is sample collected above side streams? 11 ❑ ❑ ❑
Is proper volume collected? El ❑ ❑ ❑
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? ❑ ❑ ❑
Comment: Temperature of auto sampler kept below 6 C. Temperature reading last calibrated
March 12, 2021.
Equalization Basins Yes No NA NE
Is the basin aerated? N ❑ ❑ ❑
Is the basin free of bypass lines or structures to the natural environment? ® ❑ ❑ ❑
Is the basin free of excessive grease? ❑ ❑ ❑ ❑
Are all pumps present? © 0 11 ❑

Permit: NC0026123 Owner-Facility: Asheboro wwTP
Inspection Date: 01/27/2022 Inspection Type: Compliance Evaluation
Equalization Basins Yes No NA NE
Are all pumps operable? 0 ❑ ❑ ❑
Are float controls operable? ❑ ❑ ❑ ❑
Are audible and visual alarms operable? ❑ ❑ ❑ ❑
# Is basin size/volume adequate? ❑ ❑ ❑ ❑
Comment:
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ❑ ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ ❑ ❑
Are weirs level? ❑ ❑ ❑ ❑
Is the site free of weir blockage? ❑ ❑ ❑ ❑
Is the site free of evidence of short-circuiting? ❑ ❑ ❑ ❑
Is scum removal adequate? ❑ ❑ ❑ ❑
Is the site free of excessive floating sludge? ❑ ❑ ❑ ❑
Is the drive unit operational? ❑ ❑ ❑ ❑
Is the sludge blanket level acceptable? ❑ ❑ ❑ ❑
Is the sludge blanket level acceptable? (Approximately '/, of the sidewall depth) ❑ ❑ ❑ ❑
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? ❑ ❑ ❑ ❑
Are weirs level? ❑ ❑ ❑ ❑
Is the site free of weir blockage? ❑ ❑ ❑ ❑
Is the site free of evidence of short-circuiting? ❑ ❑ ❑ ❑
Is scum removal adequate? ❑ ❑ ❑ ❑
Is the site free of excessive floating sludge? ❑ ❑ ❑ ❑
Is the drive unit operational? ❑ ❑ ❑ ❑
Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ ❑
Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) F1 ❑ ❑ ❑
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? IM ❑ ❑ ❑
Is the filter free of leaks at the center column of filter's distribution arms? ❑ ❑ ❑ ❑
Is the distribution of flow even from the distribution arms? ❑ ❑ ❑ ❑
Is the filter free of uneven or discolored growth? ❑ ❑ ❑ ❑
Is the filter free of sloughing of excessive growth? ❑ ❑ ❑ ❑
Are the filter's distribution arms orifices free of clogging? ❑ ❑ ❑ ❑
Is the filter free of excessive filter flies, worms or snails? ❑ ❑ ❑ ❑
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? E ❑ ❑ ❑
Are surface aerators and mixers operational? ❑ ❑ ❑ ❑
Are the diffusers operational? ❑ ❑ ❑ ❑
Is the foam the proper color for the treatment process? ❑ ❑ ❑ ❑
Does the foam cover less than 25% of the basin's surface? ❑ ❑ ❑ ❑
Is the DO level acceptable? ❑ ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/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 NF
Is right of way to the outfall properly maintained? ❑ ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ ❑
Page# 6

Permit: NC0026123
Owner-Facility: Asheboro wWTP
Inspection Date: 01127/2022
Inspection Type: Compliance Evaluation
Effluent Pipe Yes No NA NE
If effluent (diffuser pipes are required) are they operating properly? N ❑ ❑ ❑
Comment: Flow over steps to aerate No residual foaming 150 feet downstream.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? N ❑ ❑ ❑
Is sample collected below all treatment units? M ❑ ❑ ❑
Is proper volume collected? 0 ❑ ❑ ❑
Is the tubing clean? M ❑ ❑ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 M ❑ ❑ ❑
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type N ❑ ❑ ❑
representative)?
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? ❑ ❑ ❑
Is flow meter calibrated annually? ❑ ❑ ❑
Is the flow meter operational? 0 ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ 0
Comment: Ultrasonic flow meter used as primary effluent flow recorder_.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
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]>
Weo 9/8/2021 11 29 AM
To: Perlmutter,Gary<[e-mail]>
Cc: Hill,David A<[e-mail]>;Kebede,Adugna<[e-mail]>;Montebello,Michael J<Michael Montebello @ncdenr.gov>;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 verily.Send all suspicious email as an attachment to ReR4Ct Se.am
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(brttps.//streamstats usg5,gQy[55[)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 flowestimates 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 riot 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 h9Pj1QubL0g5,9Qv/w5fl/2403/repot pdf. 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 tlUQ://nc.wa[er.usgL.gov/reports/wri014094/. 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
b11pj111ut"5g5.goy/sir/2015/5D01/. 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 sgmi)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 MOVER 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 MOVER 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-flaw 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 70110 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:
Drainage area 7Q10 30Q2 30Q2 W7Q10 W7Q10 7Q2 7Q2
USGS station (sqmi) (Cfs) 7Q10(cfsm) (cfs) (dsm) (cfs) (cfsm) (cfs) (dsm) 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.D461 50.0 0.0586 Low-flow yields pro-rated by
0210106600 859 19.5 0.0227 804 0.0936 42A 0.0494 49.8 0.0580 wised on MOVE.1 anaiysis�,
0210106600 859 19.4 0.0226 76 3 0.0888 36.2 0.D421 50.3 0.0586 Based on MOVE.1 analysis u
Average 19.5 0.0226 18.4 0.0y 1, 39.3 00456 50.1 00583
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,Ski jest to revision pending collection of future
data and further analylu.
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,
Thankyou
Curtis Weaver
3.Curtis Weaver,Hydrologist,PE Ema/l:J<weaver6usys.gov
USGS South Atlantic Water Science center Onifne:h�jRs://www.usas.gOv/centers/se-wa r
North Carolina-South Carolina-Georgia
3916 Sunset Ridge Road
Raleigh,NC 27607
Ph.-[phone] // Fav:[phone]
From:Albertin,Klaus P<klaus.albertin@ncdencgov>
Sent:Friday,August 13,2021 10:27 AM
To:Perlmutter,Gary<gary.perlmutter@ncdencgov>
Cc:Albertin,Klaus P<[e-mail]>;Hill,David A<[e-mail]>;[e-mail];Weaver,John C<[e-mail]>;Montebello,
https://outlook.office365.com/mail/inbox/id/AAQkADRjNGZkNGYwLWNjOTctNG04MSlhZD03LWJjMGMOYmRiN2M3NwAQADGLyKwk3UB4va/u2FIR ., 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 recelved from outside of D01-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:gd_ry;nerlmutter0ncdenr.9Qy
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
https://outlook.office365.00m/mail/inbox/id/AAQkADRjNGZkNGYwLWNjOTctNGQ4MS1 hZDQ3LWJjMGMOYmRiN2M3NwAQADGLyKwk3UB4v%2FIR... 3/3

Asheboro WWTP (NC0026123) Public Comments and Responses
Comments to the draft Asheboro WWTP NPDES permit(NC0026123)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 IVWTP/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 rf mass based
limits are not alloired. "
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./ailed toxicity based on the chronic results and has
had an excellent track recoi-d.forpassing toxicity testing. Explain what./actors, data and
calculations the Reasonable Potential Analysis are based on and confrrrn 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 Cvanide collected since 2010.
Dia-ing this time no samples ever resulted in above detect for the influent. However, a period of
seven dcrvs in September of 2015, three effluent samples resulted in a detection of<yanide. Upon
review o%'the lab bench sheets, the data indicates that there was an interference ivith the test
method in these samples and therefore these data points should have not been used or r-epor-ted. A
copy of relevant bench sheets ar-e attached irith this correspondence.All samples collected.fr•onr
March 2, 2010 to June 4, 2015 and after September 22, 2015 have been recorded as non-detects
<0.01 nrg/L(one was <0.005rng/L). The ma-vinn in 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 he 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 rear compliance schedule to
evaluate our disinfection process and determine how to effectively reduce our
bromodichloroniethane 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
bromodichloroniethane compliance schedule is no longer requested.
• Comment: "Asheboro staff is aware ofthe concern associated with 1,4 dioxane and will be able
to comphv with the terms of the three year compliance schedule. However, Asheboro is not
inclined to regulate an industry that ma>>be discharging 1,4 dioxane based on the inconclusive
data regarding the health effects of this parameter and the lack of enforceable stream standards.
lVe 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 rinds 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 fi-om 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 time applicable receiving stream's
Average Annual Flow(AAF),appropriate lnstream 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 i 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 pennitted 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 pennit. Please
see the fact sheet for additional information regarding 1,4-dioxane permitting actions.
• Comment: "Studhas discovered a NPDES perniii issued io DAK Americas (permit#NC0003719
—included with this correspondence)dated March 20, 2018 in the Cape Fear Ricer Basil?—
direct discharge to the Cape Fear River. This 1ndustiv has the potential to be a significant
discharger of 1,4 dioxane based on their manufacturing process as well as toxic review inventol•y
submitted annually to EPA. This industrn is only required to monitor annuall,and report
according to the newly issued permit. This appeals to be a discrepancy and Asheboro sta f does
not understand the diferenee in permit requirements Staff reels if we are held to this standard
then it should be included in the reasonable potential anal),sis 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
detennine 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 all explanation as to why the tern fin-this permit is only.four years.
AIPDES permits are typically written for 5 ye ar terms. It is understood that we hai,e been
operating oil all expired perinit,ol•some time bill shortening the terms of the new permit to./bur
rears is a hurden not only for riry personnel bur also DEC). "
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,tune 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 Ng/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 4of4

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
Flag Status: Flagged
CAUTION:External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Sparn.
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
slauahlin(d�ci.asheboro.nc.us
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] NCO026123 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/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-I E
t 4)f I T V I 1,4ir, IN Q
WWrIm�M of EnNroontantai n�.abry
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: 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
CAUTION:External email.Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
2

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&,�4d D. R"", ;D5
Water Resources Director
Water Resources Division
336-626-1201, ext: 258
www.asheboronc.qov
r
Asheboro
&AMMUaa
tg � „n u
4M. .%3
1
North Carol€ m
MAIN STREET
Community 2016
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:Nick.Coco ncdenr.gov]
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:
3

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 WER 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.pov/scitech/swpuidance/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 WER 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 I 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
4

..E
414i)Lif,
� Q
DWparbl"of EmArom"Ul M"Ift
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: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
CAUTION:External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
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 BromodichIoromethane 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.
5. 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).
6. 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.
5

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.
%c"D. ;P"". ;D5
Water Resources Director
Water Resources Division
336-626-1201, ext: 258
www.asheboronc.gov
f f Asheboro
i
tAll K.�t Al.l f A 7 t
North Carolina
MAIN STREET
Community 2016
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 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 l am available to talk by via Microsoft Teams"
6

Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
D�E
rll�017 k I(A Q
D�pMbtrM of EmlratwtNnbl Ouatty
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:Tuesday, November 29, 2022 2:08 PM
To: Coco, Nick A<Nick.Coco @ncdenr.gov>;Sarah Laughlin <[e-mail]>; Mike Wiseman
<[e-mail]>;Judy Smith<[e-mail]>
Cc: Montebello, Michael J <Michael.Montebello ncdenr.gov>
Subject: [External] RE: [External Sender] NC0026123 Asheboro WWTP Draft Courtesy Copy
CAUTION:External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Resort Spam.
Nick,
We finished our review yesterday. I hope to sit down this afternoon and summarize everything before the end of the
day.
V cl d D. R""' ;V5
Water Resources Director
Water Resources Division
336-626-1201, ext: 258
www.asheboronc.gov
�� d
Asheboro
0
+T1lM. eT�.l1A]!
North Curuffit x
MAIN STREET
Community 2016
7

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 1<[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 offline. 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 H/
NPDES Municipal Permitting Unit
NC DEQ/Division of Water Resources/Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but I 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 ":--�--
Dq�lbeMM Ol EMrhO1N1tMU1 Owh1Y
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
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,
8

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)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 140 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 Ill
NPDES Municipal Permitting Unit
NC DEQ/ Division of Water Resources/Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but I 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
z: DE
IW�/)
Department OI F(MrW~U1 04,xbty
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
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 NIA
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 -tinall 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
i d .
1.8 Certification Statement
/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 property 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.1 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.Ogbum,III City Manager
S19 r Date signed„ D-d 222.
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Asheboro WWTP Effluent Grab 1,4 Dioxane Data (ug/L)
Research & Analytical Meritech Inc. NC Pace Analytical NC NC DEQ DWR
Date Laboratories, Inc. NC 434 #165 412 *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
8/12/12020 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'
1212112020 <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/l/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/l/2022 Not Received Not Received

DARSWEIL L.ROGERS,COMMISSIONER _l,�✓ FAYETTEVILLE PUBLIC WORKS COMMISSION
WADE R.FOWLER,1R.,COMMISSIONER ([/J(T 955 OLD WILMINGTON RD
EVELYN 0,SHAW,COMMISSIONER P.O.BOX 1089
D.RALPH HUFF,III,COMMISSIONER H M E OWN UTILITY FAYETTEVILLE,NORTH CAROLINA 28302-1089
DAVID W.TREGO,CEO/GENERAL MANAGER TELEPHONE[phone]
WWW.FAYPWC.COM
June 8,2018
VIA EMAIL: g_ary.perlmutter ,ncdenr.Iaov
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 1A 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 Q. These numbers are based upon
the carcinogenicity of the compound from information obtained from the US EPA IRIS
database.
1,4-Dioxane in the Cape 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 cfs 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/L 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 to 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 HearinE
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
Concluding 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
A l 44-IL/
Mick Noland
Chief Operations Officer
Water Resources Division
Cc: Linda Culpepper
Shelia Holman

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

Water Resources Division Tel: [phone]os Ext. 258
146 N Church Street
PO Box i1o6 CIT-Y (-,)t ftl
Asheboro, NC 27204-11o6 AsHEBO
F : 336-626-i2i8
f�O
N O R 7 H C A R O L I N A
May 31,2018
Mr. Gary Perlmutter
NCDEQ—Division of Water Resources
Water Quality Permitting Unit RECEIVED/DENR/DWR
1617 Mail Services Center JUN 0 7 20}8
Raleigh, NC 27699-1617
Water Resources
Re: Comments for Draft Permit NC0026123 Permitting Section
Dear Mr. Perlmutter:
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<O.Olmg/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
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12/7/2010 <M01 <0.01
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6/7/20U _ <OA1 <O.01
7/14/2011 <0.01 <0.01
8/13/2011 01 <0.01
9/2212MI <0 01 <OAl
10/4/2011 <0.01 <0.01
W15/2011 <0.01 <0.01
12/6/2031 <0.01 <OM
1/10/2012 _ <0.01 <O.01
3/6/2012 <O.01 <M
6/12/2012 c0.01 <0.01
9/11/2012 <0.01 c0.01
12/4/2012 <0.01 <0.01
3/5/2013 c0.01 c0.01
6/4/2013 c0.01 c0.01
9/17/2013 <0.01 <0.01
12/12/2013 c0.01 <0.01
3/4/20i4 <0.01 <0.01
6/19/2014 <OAi <0.01
9/9/2014 <O.01 <0.01
12/4/2014 <0.01 <0.01
3/10/2015 <0.01 <Q01
3/24/201S <0.01 .�§ rl l'
6/2/2015 <0.01 <0.01
6/4/2015 I,, 'ri? <0.005
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9/22/2015;•w,yh .% 0.017
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12/8/201S c0.01 <0.01
1/13/2026 <0.01 <0.01
2/11/2016 <0.01 <O.01
3/14/2016 c0A1 <0.01
4/14/2016 <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
8/17/2016 <O.01 <0.01
9/13/2016 <0A1 _<0.01
10/19/2016 <0.01 <0.01
11/2/2016 <0.01 <0.01
12/6/2016 <0.01 <0.01
3/7/2017 <0.01 I <0.01
6/8/2017 C0.011 <OA1
9/19/2017 <0.01 c0.01
12/S/2017 <0.01 <0.01
3/6/2018 m.01 <0.01

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 terns. 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, /
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
AsHEBo�o

co
ROY COOPER
Governor G
MICHAEL S.REGAN �
r
LINDA CULPEPPER NORTH CAROLINA
Ddrertar Environmental QuaUty
July 22, 2019
Michael Rhoney
Water Resources Director
City of Asheboro
PO Box 1106
Asheboro, NC 27204
Subject: Additional Monitoring Requirements
Asheboro WWTP
NPDES Permit No. NCO026123
Dear Mr. Rhoney:
The City of Asheboro has been conducting effluent monitoring for 1,4-dioxane since December 2017 as part of
the Division's investigation into sources of this compound. Compliance with a set limit may or may not be
technologically feasible and it appears most of the reductions will have to be achieved at the industrial source.
As a result,the Division has developed a Management Strategy for emerging compounds to seek reductions
through Municipal pretreatment programs by requiring industrial users to reduce,treat, or eliminate
discharges of these compounds.This process is expected to take time given that these compounds have been
used and discharged for years as unregulated compounds.
The goal will be to seek reductions that will result in Water Supply stream concentrations below EPA
recommended health advisories and for Permittees to eventually attain or comply with any NC state criteria or
standards adopted by the state.
At this time the Division is requesting the City provide their corrective action plan for locating and reducing
sources of 1,4-dioxane. If you have already taken measures outline any past activities,the outcomes from
those activities and any future plans. Please submit your plan to the PERCS Branch by September 23,2019.
Please contact me at(919)707-3624 or Julie Grzyb at(919)707-3605 or via email
(firstname.lastname a,ncdenr.ko ) if you have any questions or concerns.
Si cerely,
Deborah Gore, PERCS Supervisor
Cc: Central Files
Regional Operations,WSRO
NPDES Permit File
North Carolina Department of Errvironmental Quality I Division of Water Resources
_E Q�� 512 North Salisbury Street 1 1617 Mall Service Center I Raleigh,North Carolina 27699-1617
"„*'� 919.707.9000

�b
10
ROY COOPER '` '' n
Governor
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
January 10, 2019
Mr. John N. Ogburn, III
City of Asheboro
P.O. Box 1106
146 N Church Street
Asheboro, NC 27204
Subject: Additional Nutrient Monitoring
Requirements
Asheboro WWTP
NPDES Permit No. NCO026123
Dear Mr. Ogburn:
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in Title
15A of the North Carolina Administrative Code, Subchapter 02H, specifically, 15A NCAC
02H .0112(b)(1) and 02H .0114(a), the Director of DWR may reopen a permit to require
supplemental nutrient monitoring of the discharge. Per this letter, the Director is requiring
additional nutrient monitoring at the subject facility's effluent as specified below:
• Monitoring for total phosphorus (TP), total nitrogen (TN), total Kjeldahl nitrogen (TKN),
and Nitrite+Nitrate (NO2+NO3) shall be increased to weekly starting on April 1, 2019
and lasting through December 31, 2020. Nutrient monitoring shall revert to sampling
requirements as specified in the facility's NPDES permit starting January 1, 2021. The
additional monitoring results shall be submitted in the Discharge Monitoring Reports.
The additional monitoring will be used to support water quality modeling efforts within the
Cape Fear River Basin. Specifically, the additional monitoring will help ensure that nutrient
loadings from permitted facilities are represented as accurately as possible in the model, which
will include both point and non-point sources.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh.North Carolina 2 76 9 9-16 11

For more information on the modeling project, please visit
https://deg.nc.gov/about/divisions/water-resources/planning/modeling-assessment/special-
studies#MCF. If you have any questions, please contact Pamela Behm, DWR Modeling and
Assessment Branch Chief([e-mail], [phone]).
Sincerely,
Jeff Poupart
Water Quality Permitting Section Chief
Division of Water Resources
Cc: NPDES File
DWR/Winston-Salem Regional Office/ Water Quality
DWR / Modeling & Assessment/ Pam Behm

DRAFT Permit NCO026441
A.(9.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS (cont.)
4. Signatory Requirements [Supplements Part II Section B WNW and Supersedes Section B (11 1(d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part 11,
Section B. (11)(a)or by a duly authorized representative of that person as described in Part I1,Section B.
(11)(b). A person, and not a position,must be delegated signatory authority for eDMR reporting
purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account
and login credentials to access the eDMR system. For more information on North Carolina's eDMR
system,registering for eDMR and obtaining an eDMR user account,please visit the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
5. Records Retention [Supplements Part II Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports,including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report.This
period may be extended by request of the Director at any time[40 CFR 122.41].
A.(10.) COMPLIANCE SCHEDULE FOR TOTAL NITROGEN LIMIT
[G.S. 143-215.1(b)]
a. The Permittee shall comply with the Total Nitrogen limits in Special Condition A.(1.)in accordance
with the following schedule. See also Condition A.(11.), Treatment Optimization-Total Nitrogen.
b. Schedule of Interim and Final Actions.
Due Date Due Date
(Optimization) (Upgrade) Scheduled Action
Start — Actual start date of Mountaire Farms discharge to Siler City WWTP.
Start + 3 months — Complete acclimation period, begin nitrogen optimization study.
Start+ 13 months — Complete nitrogen optimization study per Condition A.(11.).
Start+ 19 months — Evaluate results of study, prepare study report, including methods, findings,and
recommendations,and submit to DWR for review.
Start+ 22 months — Upon acceptance of report by DWR, implement optimization measures immediately per
DWR's written acceptance.
Altemative 1: If the accepted study concludes that optimization measures are sufficient to meet the TN limit in Condition
A.(1.)and plant improvements requiring an Authorization to Construct are not necessary, continue to implement optimization
measures as accepted and:
1/1/2023 Comply with the TN limit.
Comp/lance schedule ends,A/ternab've 1.
Alternative 2: If the optimization study indicates that plant improvements requiring an Authorization to Construct are
necessary to meet the TN limit in Condition A.(1.),continue to implement optimization measures as accepted and:
4/1/2021 Complete design of the improvements and apply for Authorization to Construct permit
from DWR&/or DWI.
Part 1,Page 9 of 11

DRAFT Permit NCO026441
Due Date Due Date Scheduled Action
(Optimization) (Upgrade)
8/1/2021 Obtain Authorization to Conshvct permit.
10/1/2021 Advertise and award contract
_ ...... _.._.... -
10/1/2022 Complete construction of Improvements.
1/1/2023 Comply with TN limits.
Compliance schedule ends,Alemadve 2.
C. No later than 14 calendar days following a due date in the above schedule of compliance,the Permittee
shall provide written notification of its progress to the Division of Water Resources.If an action is not
completed by the specified date,the Permittee shall also describe the cause of noncompliance and any
steps planned or taken to comply with the remainder of the schedule.
d. For the purposes of this condition,written submittals or notification to the Division should be sent to
the following addresses:
NC DEQ/ Division of Water Resources NC DEQ/ Division of Water Resources
NDPES Wastewater Programs Raleigh Regional Office
Attu Julie Grzyb,Supervisor Attn: Danny Smith,Supervisor
1617 Mail Service Center 3800 Barrett Drive
Raleigh,NC 27699-1617 Raleigh,NC 27609
A.(11.) TREATMENT OPTIMIZATION -TOTAL NITROGEN
[G.S.143-215.1(b)]
a. The Permittee shall undertake a study to evaluate the ability of operational changes and other low-cost
measures to reduce its TN discharge load when treating process wastewaters from the Mountaire Farms
facility along with its municipal wastes.
b. Performance Tarim. The initial aim of the study is to determine if optimization of the existing plant
can achieve an effluent TN concentration of 6.0 mg/L or less when treating process wastewaters from
Mountaire Farms.If the plant cannot consistently achieve 6.0 mg/L, the aim of the study will then be to
determine what concentration it can achieve;the working target in this case is 30%reduction of TN
loads through the plant.
C. The Permittee shall complete this study and submit a report to the Division according to the schedule in
Condition A.(10.),Compliance Schedule for Total Nitrogen Limit.
d. Study Report. The Permittee shall provide a brief written report of its findings to the Division at the
addresses below.The report shall include,at a minimum,the following information:
i. A description of the approaches chosen for evaluation and the rationale for their selection;
ii. A summary of the methods used and the findings of the study,including the effectiveness of each
alternative approach;
iii. A budgetary estimate of the potential costs of implementing each alternative found to be effective;
iv. The estimated effluent TN concentrations and loads that the existing plant can reasonably and
consistently achieve using these methods;and
V. A proposal describing the methods the Permittee proposes to use to minimize its effluent TN
loads and indicating whether plant improvements are necessary to meet its TN limits.
e. For the purposes of this condition,written submittals or notification to the Division should be sent to
the addresses in Condition A.(10.)(d.).
f. Upon the Divisions request,the Permittee shall make available any monitoring results or other
information relevant to this evaluation.
Part 1,Page 10 of I I

Asheboro
City of Asheboro fioOF„e,
All-America City 146 North Church Street o 9
r' Post Office Box 1106 a
Asheboro, North Carolina 27204-1106
PM ER 25 1
2016
H
G@ [EflW
8/1/2018
Linda Culpepper AUG - 6 2018
Interim Director
DIVISION OF WATE 1 RESOURCES
Division of Water Resources DIRECTOR'S OFFICE
1611 Mail Service Center
Raleigh, NC 27699-1611
Re: Contaminate of Emerging Concern 1,4 Dioxane
Dear Ms. Culpepper:
On behalf of the City of Asheboro, I would like to thank you for all the work that has been done
by you and your staff regarding all Contaminates of Emerging Concern. 1,4-Dioxane has become
a frontline issue and City of Asheboro staff has been working diligently to find a resolution that
will not only protect downstream families, communities, and recreational uses but also prevent
undue hardships on our City, industries, and families.
In March 2015, Asheboro began meeting with Greensboro and Reidsville Staff to discuss
similarities, potential sources, and brainstorm solutions. Asheboro employees began trunkline
monitoring to identify sources within the collection system. Asheboro staff reached out to all
industrial users. Starpet, Inc. was identified as a source. In an effort to continue their record of
environmental stewardship, they began discussions with the City and began researching
treatment options on their own accord. Unfortunately, 1,4-Dioxane is a by-product of their
manufacturing process so they cannot just simply stop a single product line or discontinue a
product use without shutting down the entire facility permanently.
Starpet, Inc. manufactures PET plastics from raw materials and is an EPA Categorical Significant
Industrial User, 40 CFR Part 414.40, under the City's pretreatment program. EPA has identified
this industry as a source of 1,4-Dioxane due to byproduct formation but has not set any
discharge limits under the pretreatment program. Starpet has an exceptional compliance
record and consistently works with Asheboro staff on any concerns or questions that arise.
Starpet employs 93 people and produces 1.6 million pounds of plastic resins daily. Their parent
company, Indorama Ventures, is the world's largest producer of PET.
Starpet has recently communicated their intent to install a treatment system to reduce their
1,4-Dioxane discharge. They have spent countless resources and traveled to other countries to
Phone: [phone] www.asheboronc.gov Fax: [phone]

find a treatment system that has been verified and will be a reliable solution. This treatment
system will cost them millions of dollars to install plus an annual operating cost that has yet to
be communicated but we understand to be significant. Starpet has chosen to install the best
available technology they could locate and they continue to research other technologies that
are being tested for their success rates. Asheboro commends them on their proactive approach
to lower their environmental impacts and our hope is that downstream communities will see
results from these efforts.
Considering all of this information, the treatment system can only decrease Starpet's discharge
to 1000 ug/L in optimal operating conditions. Downstream communities are fighting for their
drinking water to be 0.35 ug/L based on EPA 1 in 1,000,000 cancer risk guideline. Asheboro
understands the concerns and wants to be protective of downstream families. Aside from
shutting down a major industrial user who has done everything they can to be environmentally
responsible and potentially keeping new industries from coming to North Carolina, the
technology simply does not exist to get Asheboro wastewater discharge to that level.
Asheboro has already seen a 92% reduction in 1,4-Dioxane concentrations since monthly
sampling began in December 2017 and staff is confident they will see a further reduction once
Starpet gets treatment built, installed, and operational.
We all must work together to assess the immediate public health and environmental concerns
of 1,4 dioxane. We must also balance how the presence of 1,4-Dioxane in the environment
relates to the actual health risk and provide guidance to achieve customer buy-in that we are in
fact working to clean their drinking water. As technology advances we will be able to analyze
and find more pollutants that are in our nation's waters. Starpet has been manufacturing PET
plastics in their Asheboro location under various ownership since 1995 and has not changed
their process aside from expansion.
Therefore, Asheboro is asking that you leave the proposed limit of 149ug/L listed in the draft
permit with BMP practices pending federal leadership or the availability of new treatment
technologies.
Si c rely,
David H. Smith
Mayor

Asheboro WWTP (NC0026123) Public Comments and Responses
Comments to the draft Asheoro WWTP NPDES permit(NC0026123)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. A three-year compliance schedule will be
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: EPA is allowing the use of Action Level Policy for the Chloride standard for
protection of aquatic life.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 DWR's Action Level Policy for toxic substances(15A NCAC 2B .0200). Note: EPA has
requested the removal of implementation of the action level policy in conjunction with the
Chloride standard in the next NC Water Quality Standard Triennial Review.Therefore,Asheboro
will likely receive a limit of 230 mg/L in the next permit renewal. Asheboro should use this
permit cycle as an opportunity to assess sources of chloride and how it can reduce this pollutant
so that the limit 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
<0.01 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: Review of lab sheets by DWR Permitting and Inorganic Chemistry branches found no
definitive evidence of either presence or absence of sample interference.Because of the
possibility that there was no interference and that the abnormally high numbers(all slightly above
10 µg/L)are real,results of the RPA that included the detected values will remain and therefore
the limits for Cyanide in the draft will remain in 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 requested compliance schedule will be added to the permit.
• 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 µg/L limit in this draft permit."
Response: The limit of 149 µg/L for 1,4-Dioxane is based on a Reasonable Potential Analysis for
the human health criterion of 80 µg/L in non-water supply waters. The criterion is based on a
calculated 1 in 1,000,000 cancer risk from fish consumption per 15A NCAC 02B .0208.
DWR has consulted with Asheboro, who identified its industrial user Starpet Inc.,a
thermoplastics manufacturer,to be the major source of 1,4-Dioxane in the effluent.According to
Asheboro,the industry is pursuing treatment technology for 1,4-Dioxane in its waste stream;
Asheboro has offered alternate limits considered achievable based on the treatment technology.
DWR has evaluated the proposed alternate limits against the originally proposed limit,taking into
consideration of downstream user's comments(see below).
• Comment: "Staff has discovered a NPDESpermit 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 Stafffeels 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 process that has since changed. Asheboro has generated sufficient data
to perform an RPA,with concentrations in exceedences of the human health criterion of 80 µg/L
in non-WS waters.
Page 2 of 4

Asheboro WWTP(NC0026123) Public Comments and Responses
• Comment: "Staff would like an explanation as to why the term for this permit is only four years.
NPDESpermits 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: Permit terms are typically five years and are scheduled per river basin.The Cape Fear
River Basin permit renewal schedule is 2016, 2021, and 2026. DEQ has accumulated a backlog of
permit renewals in recent years,and Asheboro's permit was among those affected. Because of
this backlog, Asheboro permit renewals are currently off the basin schedule. To bring Asheboro
back in line with the basin schedule,permit cycles are adjusted to four-year terms:2016,2022,
and 2026. Once returned to the basin-schedule,permit terms will be readjusted to five years.
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: DWR has performed calculations to determine 1,4-doxane concentrations at the downstream
WS boundary using the mass-loading formula:
Load(lb/day)=Conc. (mg/L) x Flow(MGD) x 8.34(conversion factor).
The proposed limit of 149 µg/L would result in a concentration of 2.48 µg/L at the WS-IV boundary at
the Governors Creek confluence.To meet the 0.35 µg/L downstream WS criterion an effluent
concentration would need to be 20.6 µg/L or less, assuming no other potential sources were considered.
Recent collections by DWR Ambient Monitoring System revealed a concentration of 2.65 µg/L in the
Deep River below Randleman Lake and upstream of the Deep River's confluence with Hasketts Creek,
representing additional source(s)of the contaminant.Using the mass-loading formula,the 2.65 µg/L
concentration was calculated to be 0.74 µg/L at the WS-IV boundary,exceeding the 0.35 µg/L water-
supply criterion and thus leaving no allocation to Asheboro.The source of the Randleman Lake
concentration,which is also a WS-IV waterbody, is likely a combination of industrial users to an
upstream WWTP and leaching from the former Seaboard Corporation Superfund groundwater
remediation site.
Page 3 of 4

Asheboro WWTP(NC0026123)Public Comments and Responses
Based on Starpet's treatment estimates,technology-based limitations, including a 60 µg/L-based load
limit and a 97 µg/L monthly average concentration limit, were proposed by Asheboro to DWR for
evaluation. A load limit of 4.50 lb/day was calculated using the mass-loading formula. At the permitted
flow of 9.0 MGD,both the load limit and concentration limit resulted in downstream concentrations at the
WS boundary lower than those from the previously proposed limit 149 µg/L. Therefore, both proposed
limits will be placed in the permit based on Best Professional Judgement that provide greater downstream
protection that is reasonably achievable by Asheboro.
The 4.50 lb/day load limit aims to assure that as flow increases, 1,4-Dioxane concentrations will decrease,
thereby providing downstream water quality protection while allowing flexibility for the WWTP and its
industrial user to increase flow. The 97 µg/L monthly average limit aims to prevent load-based effluent
concentrations from rising with low flows to levels exceeding the 80 µg/L criterion at the receiving
stream(e.g., at 2 MGD, the 4.50 lb/day load maximum would yield an effluent concentration of 269
µg/L),thereby providing further protection of downstream water quality.
These revised 1,4-Dioxane limits are proposed with a compliance schedule ending December 15, 2020,
based on the SIU's proposed completion of treatment installation by the end of 2019. To further protect
downstream water, Starpet will be required to continue 1,4-Dioxane optimization after achieving
compliance to further reduce concentrations entering and passing through Asheboro WWTP.
Page 4 of 4

Perlmutter, Gary
From: Swanson, Beth
Sent: Thursday,June 14, 2018 11:59 AM
To: Perlmutter, Gary
Cc: Cumbus, Michael W;Ibrahim, Magdi; Byrd, Roy; Satterwhite, Dana
Subject: RE: Cyanide bench sheets
Mr. Perlmutter,
As Roy mentioned, he also submitted Asheboro's benchsheets to the laboratory certification branch to take a look at the
data. While it is true that the matrix spikes had acceptable recovery, there were some issues with the method they used
which could render that moot. First,they used 20 mL of sample and 20 mL of the standard to prepare the matrix spike.
This is an issue because it is diluting the sample matrix by half with a "clean" matrix, so interferences could presumably
be diluted out too. Second, they prepared the matrix spike after the sample went through distillation.The matrix spike is
to go through all sample preparation steps, including distillation. Interference during distillation could have been missed.
This is not to say that we are asserting there was interference, but we believe the data lends some question to the
possibility. I talked further with Bernadine so that we could fully understand what the benchsheets were showing us.
They did indeed believe that there was some interference from nitrate in their samples.While they did not get a terribly
high nitrate result on the sample (6 mg/L)they did note that even after adding sulfamic acid at differing volumes as a
troubleshooting aid, the nitrate strips that they use to check the samples prior to analysis kept showing some amount of
nitrate in the samples.
The following is found in Standard Methods 4500 CN B-2011 (3)(h):
Nitrite may form HCN during distillation in Methods C, G, and L through reaction with organic compounds. Nitrate also
may reduce to nitrite, which can react further with thiocyanate.Add at least 2 g sulfamic acid at time of sample
collection and before dechlorination or basification to avoid nitrite interference.
As I said, we cannot definitively say one way or the other whether this interference existed, but believe it bears
consideration when reviewing their permit.
Please let us know if you have any further questions.
Sincerely,
Beth
Beth Swanson
919 733 3908 x259 office
Technical Assistance/Compliance Specialist
Division of Water Resources- WW/GW Laboratory Certification
North Carolina Department of Environmental Quality
From: Byrd, Roy
Sent:Tuesday,June 05,2018 3:42 PM
To: Perlmutter, Gary<[e-mail]>
Cc:Cumbus, Michael W<[e-mail]>; Swanson, Beth <[e-mail]>; Ibrahim, Magdi
<[e-mail]>
Subject: RE: Cyanide bench sheets
Hi Gary,
1

I reviewed the data with my lead chemist in Wet Chemistry, Magdi Ibrahim,and found no evidence of interference.We
confirmed what you said about no designation for interferences in the "Checks"column. Furthermore, the sample from
9/15/2015 was duplicated and spike with acceptable results.The spike recovery was 96%,which is acceptable and
generally indicates no interference in the sample.
I have copied Michael Cumbus and Beth Swanson, auditors with our Laboratory Certification Branch.They may have
additional comments, since the lab is certified by our program.
Best Regards,
Roy Byrd
From: Perlmutter, Gary
Sent:Tuesday,June 05,201812:03 PM
To: Byrd, Roy<[e-mail]>
Subject: Cyanide bench sheets
Dear Roy,
Thanks for taking my request to look over bench sheets to see if the Permittee's claim of interference is accurate. The
permit I'm working on is Asheboro WWTP (NCO026123), whose draft is currently under Public Comment. The
Permittee's comments are as follows:
"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 <0.01 mg1L (one was <0.005mg1L). 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. "
I don't see evidence of interference, but perhaps I'm not reading the sheets right. I appreciate your lab's opinion.
Thanks again,
Gary Perlmutter
Gary B. Perlmutter, M.S.
Enivronmental Specialist II
NPDES Complex Permitting Unit
NC DEQ/ Division of Water Resources/Water Quality Permitting
919 807 6385 office
919 707 9000 main office
Qarv.Perlmutter(a)ncdenr.Qov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
2

DA DE R.F L.R ER,JR. COMMISSIONER ,�J FAYETTEVILLE PUBLIC WORKS COMMISSION
WADE R.FOWLER,1R.,COMMISSIONER 955 OLD WILMINGTON RD EVELYN 0.SHAW,COMMISSIONER P.O.BOX N RD D.RALPH HUFF,III,COMMISSIONER H M E OWN UTILITY FAYETTEVILLE,NORTH CAROLINA 28302-1089
89
DAVID W.TREGO,CEO/GENERAL MANAGER TELEPHONE(910)4UI401
WWW.FAYPWC.COM
June 8,2018
VIA EMAIL: gM.perimutterna ncdenr gov
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 1A 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

r
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 Q. These numbers are based upon
the carcinogenicity of the compound from information obtained from the US EPA IRIS
database.
1,4-Dioxane in the Cave 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 cfs From fact sheet
Instream criteria 80 µg/L To be met in mixing zone

Mr.Gary Perlmutter
Page 3
June 8,2018
Water Sunnly 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/L 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 µg/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 Hearin
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
Concluding 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
(_mil 44-IL/
Mick Noland
Chief Operations Officer
Water Resources Division
Cc: Linda Culpepper
Shelia Holman

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

J 0�4F •7 [phone]
P.O. Box 3729 Cyg9TERE0 0I" FAX: [phone]
Sanford, NC 27331-3729 Email: [e-mail]
llgifV vf*nfarb
Victor I. Czar, P.E.
Public Works Director
June 8, 2018
Julie A. Grzyb
1634 Mail Service Center
Raieign, ICIC 2 7 69 7-1634
Dear Ms. Grzyb,
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 91h, 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 Big 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.
RECEIVED
JUN 11 2018
NC FWS

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

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_ ., _

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
CAUTION: D. not click links or open attachments unless verified.Send all suspicious email as an attachment to 7
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 OfCARY
PO Box 8005 1 Cary, NC 27512-8005
1

316 N.Academy Street Cary, NC 27513
Office: [phone] Mobile: [phone]
Email:[e-mail]
E-mail sent to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
2

Perlmutter, Gary
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
CAUTION: External email. Do not click links or open attachments unless verified.Send all suspicious email as an attachment to
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
1

Cape Fear Public Utility Authority
910-332-6669
2

Water Resources Division t Tel: [phone] Ext. 258
146 N Church Street
PO Box iio6 CITY OF
Asheboro, NC 27204-1io6 AsHI:9 O �D
Fax. [phone]i8
N O R T H C A R O L I N A
May 31, 2018
Mr. Gary Perlmutter
NCDEQ—Division of Water Resources RECEIVED/DENR/DWR
Water Quality Permitting Unit
1617 Mail Services Center JUN 0 7 2018
Raleigh, NC 27699-1617
Water Resources
Re: Comments for Draft Permit NCO026123 Permitting Section
Dear Mr. Perlmutter:
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

r

e 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,
r
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
AsHEBOJU
WATER RESOURCES

Asheboro WWTP Cyanide
Date Influent Effluent
3/2/2010 <0.01
3/4/2010 <0.01
6/8/2010 <0.01 <0.01
9/14/2010 <0.01 <0.01
12/7/2010 <0.01 <0.01
1/18/2011 <0.01 <0.01
2/17/2011 <0.01 <0.01
3/3/2011 <0.01 <0.01
4/19/2011 <0.01 <0.01
5/11/2011 <0.01 <0.01
6/7/2011 <0.01 <0.01
7/14/2011 <0.01 <0.01
8/18/2011 <0.01 <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
1/10/2012 <0.01 <0.01
3/6/2012 <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
9/17/2013 <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
3/10/2015 <0.01 <0.01
3/24/2015 <0.01
6/2/2015 <0.01 <0.01
6/4/2015 ,% „hA <0.005
9/15/2015 <0.01 0.018 SI An W
9/1812015 0.012 Lab Data
9/21/2015 0.017 Sheeis
9J22/2015 !;;; <0.01
9/23/2015 <0.01
12/8/2015 <0.01 <0.01
1/13/2016 <0.01 <0.01
2/11/2016 <0.01 <0.01
3/14/2016 <0.01 <0.01
4/14/2016 <0.01 <0.01
5/5/2016 <0.01 <0.01
6/14/2016 <0.01 <0.01
7/14/2016 <0.01 <0.01
8/17/2016 <0.01 <0.01
9/13/2016 <0.01 <0.01
10/19/2016 <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
9/19/2017 <0.01 <0.01
12/5/2017 <0.01 <0.01
3/6/2018 <0.01 <0.01

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ROY COOPER
MICHAEL S. REGAN
Si i,nn z
LINDA CULPEPPER
Water Resources
ENVIRONMENTAL QUALITY
March 20, 2018
Mr. Matthew P. Hendrickson, Site Manager
DAK Americas
3216 Cedar Creek Rd.
Fayetteville, North Carolina 28302
Subject: Draft NPDES Permit Renewal
Permit NCO003719
DAK Americas WWTP
Cumberland County
Class 2 Facility
Dear Mr. Hendrickson:
Enclosed with this letter is a copy of the Draft NPDES permit renewal for your facility. Please
review this draft carefully to ensure thorough understanding of the requirements and conditions it
contains. The draft permit public noticed on October 31,2017 included TSS limits based on ELGs
and BPJ. The BPJ limits for BOD and TSS applicable to Clear Path Recycling were calculated
using 95%reduction within the treatment system. The Division acknowledges that this approach
was erroneous for calculating TSS limits and recalculated the TSS limits based on 85%reduction.
Since the TSS limits are less stringent than in the previous draft permit a second public notice is
needed.The draft permit includes the following changes from your previous permit:
• Limits for BOD, TSS and toxic pollutants for Outfall 002 were modified based on the
effluent guidance limits and the updated production flows for DAK Americas and Clear
Path Recycling.
• Requirements for Outfall 001 were modified to reflect typical cooling water monitoring
requirements. Although this is a combined outfall discharging cooling water and
stormwater it is considered a wastewater outfall for permitting purposes.
• Annual monitoring for mercury was added at outfall 002 in accordance with the
implementation of the 2012 Statewide Mercury TMDL.
• Annual monitoring for 1,4 Dioxane was added at outfall 002. 1,4 Dioxane is a pollutant
of concern in the Cape Fear River. The Division is implementing monitoring to gather
data on this pollutant.
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted
State of North Cam" I Emi vorntal Quality i Water Resources
16)7 Mal service Cemer I Raleigh,NorthCarulim 27699-1617
919 907 6300

r

Page 12
and became effective on December 21, 2015. The requirement to begin reporting
discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) intemet application has been added to your final NPDES
permit. [See Special Condition A. (7)]
For information on eDMR, registering for eDMR and obtaining an eDMR user account,
please visit the following web page: htt :!/deu.nc. ov/aboutldivisions/water-
resources/edmr.
For more information on EPA's final NPDES Electronic Reporting Rule, please visit the
following web site:
htti)s•//www federalregister.vov/documents/2015/10/22/2015-24954/national-pollutant-
dischars,e-elimination-system-npdes-electronic-reportin`rule.
• The NPDES Standard conditions(Parts Il, I1I, and IV) are not included with this draft.
They can be found at the following link to review them in conjunction with this draft
permit: baps://deq.nc.gov/penmittin -fg_orms.
Concurrent with this notification the Division is publishing a notice in a newspaper having
circulation in the general Cumberland County area,soliciting public comments on this draft
permit. Please provide any written comments you may have to the following: NCDEQ/DWR,
NPDES Permitting Branch, 1617 Mail Service Center, Raleigh,NC 27699-1617 no later than 30
days after receipt of this draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments
and take appropriate action prior to issuing a final permit. If you have questions concerning this
draft pen-nit, please call me at(919) 807-6387or by email at [e-mail].
Sincerely,
Teresa Rodriguez, Engineer
NPDES Complex Permitting Unit
Hardcopy: NPDES Files
Ecopy: US EPA Region 4
DWR/Wastewater Operator Certification/Maureen Kinney
DWR/Aquatic Toxicology Branch/Susan Meadows
DWR/Fayetteville Regional Office/Water Quality

NC0003719
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission,and the Federal Water Pollution Control Act,as amended,
DAK Americas LLC
is hereby authorized to discharge wastewater from a facility located at
DAK Americas LLC - Cedar Creek Site
3468 Cedar Creek Road, Fayetteville
Cumberland County
to receiving waters designated as the Cape Fear River in the Cape Fear River Basin in accordance with
effluent limitations,monitoring requirements and other conditions set forth in Parts I, II, III and IV
hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on October 31,2021.
Signed this day
Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of It

NC0003 719
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS OUTFALL 002
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.I
During the period beginntrig on the effective date of this permit and lasting until expiration,the Permittee is
authorized to discharge from Outfall 002.Such discharges shall be limited and monitored by the Permittee as
specified below:
Effluent Monitoring
ra Chacteristics Limits Rec ulrements
Monthly Daily Measurement Sample Sample
i Average Maximum Frequency Type Location t
Flow 0 500 MGD _ Continuous Recording I or E
Total Suspended Solids(TSS) 1821bs/day 347 lbs/day 1/Week Composite 2 E
BODs,200C 143 lbs/day 244 lbs/day 1/Week Composite 2 E
NH3-N(April 1.October 31) 13 lbs/day 26 lbs/day I/Week Composite 2 E
NH3-N(November 1-March 3I) 26 lbs/day 521bs/day I/Week Com to 2 E
Fecal Cohform(geometric mean) 1/Week Grab E
Total Residual Chlorine _ 28 2 1/Week Grab E
Temperature(°C)3 I/Week Grab E
Dissolved Oxygen 3,5 - - 1 1/Week Grab E
H _ ____ 6 to 9 S U I/Week Grab E
Total Nitrogen(NO2+NO3+Tl{N) 1/Quarter Composite 2 E
Total Phosphorus I/Quarter Composite 2 E _
Acute Toxicity 3,6 I/Quarter Composite 2 E
Dissolved Oxygen 7 1/Week Grab U&D
Temperature(°C)7 1/Week Grab U&D
Conductivity? —i _I/Week Grab U&D
Footnotes
1 E=Effluent,I=Influent,U=upstream 2 mi from Outfali D=downstream, 100 yards upstream of Lock and Dam#3
2. Composite samples must be refrigerated
3 The Permittee shall collect the effluent samples for dissolved oxygen,temperature and acute toxicity from the box
combining effluents of Outfalls 001 and 002
4 Total Residual Chlorine(TRC)-The Division shall consider all effluent total residual chlorine values reported below 50
µg/L to be in compliance with the permit However,the Permittee shall continue to record and submit all values
reported by a North Carolina certified laboratory(including field certified),even if these values fall below 50 µg/L
5 Effluent dissolved oxygen(DO)shall not fall below 5 mg/L
6 Whole Effluent Toxicity(WET)testing,acute toxicity P/F at 90%using Fathead Minnow WET tests shall be
conducted in February,May,August and November[See Part A (4)]
7 Receiving Stream Monitoring-As a member of the Middle Cape Fear River Basin Association,the Perrmttee's mstream
monitoring responsibilities are hereby waived by Memorandum of Agreement However,should this membership
terminate for any reason,the Permittee shall notify the Division immediately,and the Permittee shall immediately
resume instream monitoring requirements,as specified herein
The Permittee shall add no chromium,zinc,or copper to the treatment system except as pre-approved additives
to biocide compounds or those resulting from the normal degradation of process piping or equipment
The Permittee shall discharge no floating solids or foam visible in other than trace amounts
Page 3 of 11

NC0003719
i A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B
.0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration,the Permittee is
authorized to discharge from Outfall 002. Such discharges shall he limited and monitored by the Permittee for
OCPSF parameters, as specified below:
Effluent 1 `Monitoring --- -�
Characteristics Limits Requirements
DAILY MONTHLY Measurement Sample Sample
MAXIMUM ! AVERAGE Frequency Type Location
ounds/da� 1 ('unds/dav
Acenaphthene 0.062 0.023 ]/Year Grab Effluent
Acenaphthyiene 0.062 0.023 ]/Year Grab Effluent
Acrylonitrile _ 0.256 0,102 1/Year Grab Effluent
Anthracene _ 0.062 0.023 ]/Year Grab Effluent
Benzene 0.144 0.039 I/Year Grab Effluent
Benzo(a)anthracene 0.062 0.023 )Year Grab Effluent
3,4-Benzofluomnthene 0.065 0.024 ]/Year Grab Effluent
Benzo(k)fluoranthem 0.062 0.023 I/Year Grab Effluent
Benzo(a)pyrenel 0.726 µg/l 0.726 pg/l ]/Year Grab Effluent
Bis(2-ethythexyl)phthalate 0.296 0.109 ]Near Grab Effluent
Carbon Tetrachloride 0.40 0.019 1/Year Grab Effluent
Chlorobenzene 0.030 0.016 ]Near Grab Effluent
Chloroethane 0.284 0.110 )Year Grab Effluent
Chloroform i 0.049 0.022 I/Year Grab Effluent
2-Chlorophenol 0.104 0.033 ]Near Grab Effluent
Chrysene 0.062 0.023 ]/Year Grab Effluent
Di-n-butyl phthalate 0.060 0.029 _ ]/Year Grab Effluent
1,2-Dichlorobenzene 0.173 0,082 ]Near Grab Effluent
1,3-DicWorobenzene 0.047 0.033 ]/Year Grab Effluent
1,4 Dichlorobenzene 0.030 0.016 ]/Year Grab Effluent
1,1-Dichloroethane 0.062 0.023 ]/Year Grab Effluent
1,2-Diehloroethane 0.223 0.072 ]/Year Grab Effluent
1,1-Dichloroethylene _ 0.026 0.017 )Year Grab Effluent
1,2-trans-Dichloroethylene 0.057 0.022 ]/Year Grab Effluent
2,4-Dichlorophenol 0.119 0.041 ]/Year Grab Effluent
1,2-Dichloropropane 0.244 0.162 ]/Year Grab Effluent
1,3-Dich]oropropene 0.047 0.031 ]/Year Grab Effluent
Diethyl phthalate 0.215 0.086 I/Year Grab Effluent
2.4-Dimethylphenol 0.038 0.019 ]Near Grab Effluent
Dirnethyl phthalate 0.050 0.020 ]/Year Grab Effluent
4,6-Dinitro-o-cresol 0.293 0.083 1Near Grab Effluent
2,4-Dinitrophenol 0.130 _0.075 11Year Grab Effluent
2,4-Dinitrotoluene 0.302 0.120 ]!Year Grab Effluent
2,6-Dinitrotoluene 0.679 0.270 ]Near Grab Effluent
i
Ethylbenzene 0.114 0.034 ]/Year Grab Effluent
Fluoranthene 0.072 0.026 )[Year Grab Effluent
[Part A.(2.)continues on next page]
Page 4of11
t_

NCO003719
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(OCPSF-Continued) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Effluent Limits Monitoring Requirements
Characteristics
------ ---- - -DAILY MONTHLY
Measurement Sample Sample
MAXIMUM AVERAGE Frequency Type Location
(pounds/do%i 1 ,ounds/da
Fluorene 0.062 0.023 I/Year Grab Effluent
Hexachlorobenzene t 0.441 µg/L 0.441 µg/L I/Year Grab Effluent
Hexachlorobutadiene 0.052 0.021 I/Year Grab Effluent
Hexachloroethane 0.057 0.022 I/Year Grab Effluent
Methyl Chloride 0.201 0.091 1/year Grab Effluent
Methylene Chloride 0.094 0.042 I/Yew Grab Effluent
Naphthalene 0.062 0.023 I/Year Grab Effluent
Nitrobenzene 0.072 0.029 I/Year Grab Effluent
2-Nitrophenol 0.073 0.043 I/Year Grab Effluent
4-Nitrophenol 0.131 0.076 11year _- Grab Effluent
Phenanthrene 0.062 0.023 1NYear Grab Effluent
Phenol _ 0.028 0.016 I/Year Grab Effluent
Pyrene 0.071 0.026 I/Year Grab Effluent
Tetmehloroethylene 0.059 0.023 I/Year _ Grab Effluent
Toluene 0.085 0.028 I/Year Grab_ Effluent
1,2A-Trichlorobenzene 0.149 0.072 I/Year Grab Effluent
1.1,1-Trichlorocd am 0.057 0.022 I/Year Grab Effluent
1.1.2-Trichloroathane _ 0.057 0.022 I/Year Grab Effluent
Trichloroethvlene 0.057 0.02 I/Year Grab Effluent
Vinyl Chloride 0.476 0.110 I/Year Grab Effluent
Total PAH 173 7 173 ►g 1 !Near Grab Effluent
1 A Dioxane Monitor and Report 1 I/Year_ Grab Effluent
Mercu (Method 1631E) Monitor and Report(n -l) I I/Year Grab Effluent
Notes:
1. Water-quality based limit.
Page 5ofII

NC0003719
A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS OUTFALL 001
[1 SA NCAC 02B .0400 et seq.,02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until permit expiration,the Permittee is
authorized to discharge from outfa11001 (Non-Contact Cooling Water and Stotmwater). Such discharges shall be
limited and monitored by the pennittee as specified below:
Effluent Limits Monitoring
Characteristics Requirements
Monthly Daily Measurement Sample Sample
Average Maximum Frequency Type Location t
Flow _-- -—� MontWN Grab E
Total Suspended Solids 30 me 1 100 m 1 Montlil, Grab E
Oil&Grease Month1% Grab E
Total Residual Chlorine 28 Eg l MOnthl'. Grab E
pH 6 to 9 S.U. MonthlN Grab E
Notes:
1. Sample Location E- Samples to be collected before comingling with the WWTP effluent.
A. (4.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT(QUARTERLY) [15A NCAC 02B
.0200 et seq.]
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North
Carolina Procedure Document entitled"Pass/Fail Methodology For Determining Acute Toxicity In A
Single Effluent Concentration'(Revised December 2010 or subsequent versions).The monitoring shall
be performed as a Fathead Minnow(Pimephales promelas)24-hour static test.The effluent
concentration at which there may be at no time significant acute mortality is 90%(defined as treatment
two in the procedure document). The tests will be performed during the months of February,May,
August,and November. These months signify the first month of each three-month toxicity testing
quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed.Upon passing,this
monthly test requirement will revert to quarterly in the months specified above.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form(MR4) for the month in which it was performed, using the parameter code
TGE6C. Additionally,DWR Form AT-2 (original)is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Page 6ofII

NC0003719
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests,as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required,the permittee will complete the information located at the top of the aquatic toxicity(AT)test
form indicating the facility name,permit number,pipe number,county,and the month/year of the report
with the notation of"No Flow"in the comment area of the form.The report shall be submitted to the
Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed.Upon passing,
this monthly test requirement will revert to quarterly in the months specified above. Assessment of
toxicity compliance is based on the toxicity testing quarter,which is the three-month time interval that
begins on the first day of the month in which toxicity testing is required by this permit and continues
until the final day of the third month.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Resources indicate potential impacts to the receiving stream,this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls,shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.
A.(5.) BIOCIDE APPROVAL[G.S. 143-215, 143-215.1]
The Permittee shall obtain approval from the Division's Aquatic Toxicology Unit prior to discharging any biocide
(not previously approved by the Division)under this permit.Approval for use of any biocide not previously The
Permittee shall request approval of any new unauthorized biocide at least 90 days in advance of planned usage.
Contact the Aquatic Toxicology Unit for detailed instructions on requesting biocide approval:
NC DENR/DWR/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
A. (6.) LABORATORY TEST-METHOD QUANTITATION LEVELS AND COMPLIANCE
[G.S. 143-215.66]
For any given parameter,the Permittee must apply a state-certified analytical test method with a practical
quantitation level(PQL)at or below the NPDES permit limit.If such level of analytical sensitivity is not
technologically feasible,the Permittee shall employ a state-certified analytical method with the lowest available
test-method PQL,and values reported as"not detected"by this lowest available PQL shall be deemed
"compliant"with this permit.
Page 7 of 11

l

NC0003719
A. (7.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports(DMRs)and program reports.
The final NPDES Electronic Reporting Rule was adopted and became effective on December 21,2015.
I
NOTE: This special condition supplements or supersedes the following sections within Part 11 of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. ReportinL,Requirements ISu3ersedes Section D (2 )and Section E.(5 )(a)I
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report(eDMR)internet application.
Monitoring results obtained during the previous month(s)shall be summarized for each month and submitted
electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and
submit DMRs electronically using the intemet. Until such time that the state's eDMR application is
compliant with EPA's Cross-Media Electronic Reporting Regulation(CROMERR),permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be required
to complete the eDMR submission by printing,signing,and submitting one signed original and a copy of the
computer printed eDMR to the following address:
NC DEQ/Division of Water Resources/Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access,then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms(MR 1, 1.1, 2, 3)or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above. Sec "How to Request
a Waiver from Electronic Reporting"section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21,2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports;and
• Clean Water Act(CWA) Section 316(b)Annual Reports.
The permittee may seek an electronic reporting waiver from the Division(see"How to Request a Waiver
from Electronic Reporting"section below).
Page 8 of 1 l

NCO003719
2. Electronic Submissions
In accordance with 40 CFR 122.41(l)(9),the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial recipient
for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity(EPA or
the state authorized by EPA to implement the NPDES program)that is the designated entity for receiving
electronic NPDF..S data(see 40 CFR 127.2(b)J.
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of
electronic submission and for each state. Instructions on how to access and use the appropriate electronic
reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at:
htt, ://www2.e. a._ov/com,liance/final-national ollutant-dischar;e-elimination-s.stem-n des-electronic-
i
reporting-rule.
Electronic submissions must start by the dates listed in the"Reporting Requirements"section above.
3. How to Request a Waiver from Electronic Reportin-,
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver,a permittee must first submit an electronic reporting waiver request to the Division.
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty(60)days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and
shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re-applies for and is granted a new temporary electronic reporting waiver by the
Division. Approved electronic reporting waivers are not transferrable. Only permirtees with an approved
reporting waiver request may submit monitoring data and reports on paper to the Division for the period that
the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
lit( //dekl.nc.,ov/about/divisions/water-resources/edrnr
4. Si nator% Requirements ISutrplements Section B. ill.) (b)and Sut ersedes Section B. (11.) (dil
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section
B. (I 1.)(a)or by a duly authorized representative of that person as described in Part I1,Section B.(11.)(b). A
person,and not a position,must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions,the person signing and submitting the DMR must obtain an eDMR user account and
login credentials to access the eDMR system. For more information on North Carolina's eDMR system,
registering for eDMR and obtaining an eDMR user account, please visit the following web page:
lit,, ://de,,.nc.._ov/about/divisionsiwater-resources/edrnr
Page 9 of I I

NCO003719
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
V 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
evahiate 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.1 am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."
5. Records Retention ISupplements Section D.(6.1I
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These
records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may
be extended by request of the Director at any time [40 CFR 122.41 J.
Page 10 of 11
l

NC0003719
f r
"k Mitt
Hwy53 f� r` +
Outfall 001
Outfall002
_ \
_ 4t
-- 41
i
Ir
r a 1
�(
DAK Americas WWTP
Cumberland County Facility Location(not to scale)
Latitude: 34'58'08" N Permitted Flow: 0.5 MGO
Longitude: 78'46'S8' W Stream Class: C
Receiving Stream:Cape Fear River HUC:03030004
Drainage Basin:Cape Fear River Basin Sub-Basin:03-06-15 N
State Grid: H23NE NPDES Permit NC0003719
Page 11 of 11

The
Courier-Tribune Public Notice
North Carolina Environmental Management Commission/
Affidavit of Publication NPDES Unit
1617 Mail Service Center
State of North Carolina, Raleigh, NC 27699-1617
Randolph County Notice of Intent to Issue a
NPDES Wastewater Permit
To Whom It May Concern:
The North Carolina Environmental Management Commission
proposes to issue a NPDES wastewater discharge permit to the
This is to certify the person(s) listed below. Written comments regarding the proposed
advertisement attached permit will be accepted until 30 days after the publish date of this
notice. The Director of the NC Division of Water Resources(DWR)
hereto has been published in may hold a public hearing should there be a significant degree of
public interest. Please mail comments and/or information requests
The Courier Tribune to DWR at the above address. Interested persons may visit the DWR
on the following dates: at 512 N. Salisbury Street, Raleigh, NC to review information on
file. Additional information on NPDES permits and this notice may
be found on our website: http://deq.nc.gov/about/divisions/water-
resources/water-resources-permits/wastewater-branch/npdes-
wastewater/public-notices,or by calling [phone]. The City
of Asheboro has requested renewal of permit NCO026123 for its
Asheboro Wastewater Treatment Plant in Randolph County; this
/�,�� permitted discharge is for treated municipal and industrial
Sworn to on this` day wastewater to Hasketts Creek, in the Cape Fear River Basin.
of - 2018. It- 5/9/18
a"I em-
Courier-Tribune Representative
Sworn to and Subscribed
Before me this day
of�, 2018.
V, ffi-ae
otary blic
JOSEPHINE VIERA COOPER
Notary Public, North Carolina
Randolph County
My Co mi sion Expires

C���,
Y .. ._ __:

Public Notice
North Carolina Environmental
Management Commission/
NPDES Unit
1617 Mall Service Center
Raleigh,NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
The North Carolina Environmental
Management Commission propos-
es to issue a NPDES wastewater
discharge permit to the person(s)
listed below. Written comments
regarding the proposed permit
will be accepted until 30 days af-
ter the publish date of this notice.
The Director of the NC Division of
Water Resources(DWR)may hold
a public hearing should there be a
significant degree of public inter- 1 1A apt
est.Please mail comments and/or Cam,
information requests to DWR at
the above address.Interested per-
sons may visit the DWR at 512 N.
Salisbury Street,Raleigh,NC to re-
view information on file. Addi-
tional information on NPDES Per-
mits and this notice may be found
on our website:
httPVldeq.nc.gov/about/dlvisions
/water-resources/water-
resources-perm it s/wastewater-
b r a n c h / n p d e s -
wastewater/public-notices,or by
calling(919)807-6397. The City of
Asheboro has requested renewal
of permit NCO026123 for its Ashe-
boro Wastewater Treatment Plant
in Randolph County: this permit-
ted discharge Is for treated mu-
nicipal and industrial wastewater -
to Hasketts Creek, in the Cape
Fear River Basin.
It-5/9/18
I�+�n
�\ Le�.oa-

dim 4
ROY COOPER
Governor
MICHAEL S.REGAN
Secretory +�� +
LINDA CULPEPPER
Interim Director NORTH NA
Environmental Quality
Month xx, 2018
John N. Ogburn, III
City of Asheboro
P.O. Box 1106
146 N Church Street
Asheboro, NC 27204
Subject: Second Draft NPDES Permit Renewal
Permit NCO026123
Asheboro WWTP,
Grade IV Biological WPCS
Randolph County
SIC Code 4952
Dear Mr. Ogburn:
Enclosed with this letter is a copy of the second draft NPDES permit renewal for your facility.
This second draft is being sent for review and public comment in light of inserting compliance
schedules for Ammonia (NH3-N) and Bromodichloromethane, as well as substantial changes
regarding 1,4-Dioxane in response to comments to the first draft permit. Please review this draft
carefully to ensure thorough understanding of the requirements and conditions it contains.Ti ere-
-'ar*_ ra c anges The following changes were made to the first draft permit sent to you on May 9, 2018:
• Section A.-(1.) E_ ffl_uent L�— �
Monitoring Requirements has been modified to
insert interim - ma-_li_mits, plus footnotes for Ammonia and
Bromodic romethane compliance schedules. See Sectian-A:-0,),-EQ-Qtnotes 4 and 8.
• A three-year compliance schedule was added for meeting the more stringent NH3-N limits.
See Special Condition A. (6.).
• A two-year compliance schedule was added for meeting the Bromodichloromethane limit.
See Special Condition A. (7.).
• 1,4-Dioxane limits were revised from 149 µg/L Monthly Average to a 97 µg/L Monthly
Average with an average daily load limit of 4.50 lb/day not to be exceeded. These limits
are based on Best Professional Judgement from achievable levels that the WWTP has
proposed based on its industrial user's proposed treatment technology efficacy for 1,4-
Dioxane reduction.These limits are more stringent than that in the first draft permit in order
to better protect downstream water quality as well as taking into consideration other
sources of 1,4-Dioxane,which have been identified upstream of Hasketts Creek in the Deep
River.
o"—�D E Q-5
4./e�MlwYr�1Y O+ry�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 2 769 9-1611
919.707.3b01

• The 1,4-Dioxane compliance schedule was shortened from three years to a period ending
December 15, 2020 based on a proposed timeline to install treatment technology by the
industrial user identified as the primary contributor of 1,4-Dioxane to the WWTP. See
Special Condition A. (8.).
Sr • A footnote was added to the 1,4-Dioxane limits to require industrial users to continue
optimizing 1,4-Dioxane reduction in their effluent to the WWTP. See Section A. (1.),
Footnote 12.
• A special condition has been added instructing how to calculate 1,4-Dioxane loadings. See
Special Condition A. (9.).
• A reopener clause special condition has been added to modify 1,4-Dioxane monitoring,
treatment and/or compliance. See Special Condition A. (10.).
• Section A. (1.), Footnotes 13 and 14 regarding instream monitoring were inserted into
Footnote 2.
The first draft permit maintains the following significant changes identified in the letter sent on May
9,2018. S updated,_
• Regulatory citations have been added to the permit.
• Parameter codes have been added in Section A. (1.) Effluent Limitations and Monitoring
Requirements.
• The outfall map was updated to include instream monitoring station locations.
• Ammonia-Nitrogen (NH3-N) limitations have been decreased, based on wasteload
allocation (WLA) calculation. Limitations for NH3-N are based on protection of aquatic
life utilizing an EPA ammonia chronic criterion of 1.0 mg/L (summer) and 1.8 mg/L
(winter). The WLA results yielded NH3-N limitations that are more stringent than in the
current permit, as tabulated below:
Existing Proposed
Summer Winter Summer Winter
Monthly Average 2.0 mg/L 4.0 mg/L 1.0 mg/L 1.8 mg/L
Weekly Average 6.0 mg/L 12.0 mg/L 3.0 mg/L 5.4 mg/L
• Instream Conductivity monitoring was added to the permit, based on the presence of an
industrial pretreatment program as specified in Instream Conductivity and Fecal Coliform
Monitoring Guidance(NCDWQ internal memo,2002).However,the Permittees' sampling
requirement for this parameter is conditionally waived as long as the Permittee is a member
of the Upper Cape Fear River Basin Association.
• The NC 2007-2014 Water Quality Standard (WQS)Triennial Review was approved by the
NC Environmental Management Committee(EMC) on November 13, 2014. The US EPA
subsequently approved the WQS revisions on April 6,2016 with some exceptions.The NC
Division of Water Resources NPDES Permitting Unit is required to implement the new
dissolved metal standards in all permits public noticed after April 6, 2016. The new
standards for most metals include acute standards. Further, the freshwater standards for
several metals are expressed as the dissolved form of the metals, and seven metals have
Page 2 of 5

hardness-dependent equations. As a result, the NPDES Permitting Unit will need site-
specific effluent hardness data and instream hardness data, upstream of the discharge, for
each facility monitoring these metals in order to calculate permit limitations. Effluent
hardness sampling has been added to this permit at a quarterly monitoring frequency.
Upstream hardness sampling has not been added, in recognition of the receiving stream's
7Q10s of 0 cfs, which renders upstream hardness measurements irrelevant in dissolved
metals calculations. See Section A. (1.).
• As part of the NC 2007-2014 WQS Triennial Review, the Total Chromium WQS was
removed and replaced with trivalent chromium (Cr-III) WQS and hexavalent chromium
(Cr-VI) WQS. Total Chromium is made up of trivalent and hexavalent forms. The
reasonable potential analysis (RPA) using Asheboro's Total Chromium effluent data
showed potential to violate the new Cr-VI standard. As a result, Total Chromium limits
were removed from the permit; quarterly monitoring of Total Chromium and Cr-VI
were added to the permit. Sampling for hexavalent chromium and total chromium
together will ascertain if Cr-VI is present in the total chromium samples and thus the
effluent. If sampling for Cr-VI indicates that it is not present (i.e. non-detectable
concentrations at the lower reporting level of the procedure) after two years of sampling,
then the limits and monitoring requirements for Cr-VI in Section A. (L) can be reduced or
removed upon request. See Section A. (L), Footnote 7.
• Currently, EPA is allowing an action level for Chloride,but at the next permit renewal this
may not be the case. Your passing record for toxicity tests indicate that a limit for chloride
is not necessary at this time, but this may change in the future. Please note that the
allowable concentration for Chloride is 230 mg/L. The effluent average from January 2014
through December 2017 was 166 mg/L;and an RPA found a reasonable potential to exceed
the allowable concentration. As a result, quarterly monitoring for Chloride in conjunction
with toxicity tests is maintained in the permit.
• A monthly average limit of 5.0 µg/L and a daily maximum limit of 22.0 µg/L for Cyanide
have been added to the permit and samples shall be taken monthly. Results of an RPA on
submitted data indicated a reasonable potential to exceed the instream water quality
standards. A footnote has been added to the effluent limitations sheet stating that the
Division will consider all values reported below 10 µg/L to be compliant due to difficulties
in quantifying cyanide in wastewater, but the Permittee shall submit all Cyanide values
reported by a NC-certified laboratory, even if values are less than 10 µg/L. See Section A.
(L), Footnote 10.
• Quarterly monitoring for Total Zinc has been removed from the permit. Review of the data
revealed no reasonable potential to exceed water quality standards. Quarterly monitoring
shall be maintained per the facility's pretreatment Long Term Monitoring Program
(LTMP).
• Effluent Mercury data were reviewed from May 2012 to May 2017. The Permittee tested
effluent for Total Mercury using EPA test Method 1631 E throughout this period. In
accordance with the 2012 Mercury TMDL NPDES Guidance, the Permittee needs to show
annual average effluent concentrations below the Water Quality Based Effluent Limitation
(WQBEL) of 12.0 ng/L and no exceedance of the Technology Based Effluent Limitation
(TBEL) of 47 ng/L. A review of the data showed the annual averages were below the
WQBEL and all data were below the TBEL; therefore, no mercury limitation is required.
Page 3 of 5

As a result of the TMDL evaluation, the limits and monitoring of mercury have been
removed from Section A. (L). Sampling for mercury will be conducted during the three
(3) effluent pollutant scans [see Section A. (3.)] as well as the pretreatment LTMP using
EPA Method 1631 E.
Fifty-one(5 1)out of 71 low level effluent mercury samples collected were over 1 ng/L.
As a result, a Mercury Minimization Plan (MMP) requirement has been added in this
permit renewal [see Special Condition A. (4)]. Please note that the Permittee shall develop
and implement an MMP during this permit term. The MMP shall be developed within 180
days of the NPDES permit effective date; and it shall be available for inspection on-site. A
sample MMP was developed through a stakeholder review process and has been placed on
the Division website for guidance (https://deg.nc.g_ov/document/nc-model-mercury-
minimization-plan-dwr-npdes-swp-20130801).
• A monthly average limit of 31.6 µg/L for Bromodichloromethane has been added to the
permit and samples shall be taken monthly. Results of an RPA on submitted data indicated
a reasonable potential to exceed the instream water quality standards.
• Review of submitted effluent data showed all samples for Total Silver to be less than
detection at 5 µg/L. In accordance with 15A NCAC 2B .0500, all test procedures must
produce detection and reporting levels that are below the permit discharge requirements
and all data generated must be reported to the approved detection level or lower reporting
level of the procedure. Currently, DWR's laboratory identifies the Practical Quantification
Limit for Total Silver at< 1.0 µg/L. The allowable discharge concentration for Total Silver
at your facility is 0.06 µg/L as a monthly average. The Division recommends that the
Permittee improves and implements"clean"sampling techniques and analyzes Total Silver
to the lower reporting level of the procedure. Quarterly monitoring for Total Silver has
been added to the permit.
• Some of the wording has changed in Section A. (2.) Chronic Toxicity Permit Limit; please
review each paragraph carefully.
• Section A. (3.) Effluent Pollutant Scan has been modified to include the three specific years
in which the effluent pollutant scans shall be performed: 2019,2020,and 2021. In addition,
at the end of the Special Condition, 2"d species Toxicity Testing Requirements for
municipal permit renewals per Federal Regulations [40 CFR 122.210)(5)] have been
added.
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted
and became effective on December 21, 2015. 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 final NPDES
permit. See Section A. (11.).
For information on eDMR,registering for eDMR and obtaining an eDMR user account,
please visit the following web page: http://deq.nc.jov/about/divisions/water-
resources/edmr.
For more information on EPA's final NPDES Electronic Reporting Rule, please visit
the following web site: https://www.federalre ister.gov/documents/2015/10/22/2015-
24954/national pollutant-discharge-elimination-system-npdes-electronic-reporting-rule.
Page 4 of 5

The NPDES standard conditions(Parts Il, III, and IV) that are a part of the permit are not included
in this draft document (cover, map, and Part 1). The conditions are the same as in your current
permit except that agency and division names have been updated. The latest version is available at
https://bit.ly/2BZ4xxx and can be viewed online or downloaded as a PDF file.
Please note that the receiving stream is listed as impaired for Copper and Benthos on North
Carolina 2016 Final 303(d) Impaired Waters List. Addressing impaired waters is a high priority
with the Division, and instream data will continue to be evaluated. If there is noncompliance with
permitted effluent limits and the stream impairment can be attributed to your facility, then
mitigative measures may be required.
Concurrent with this notification the Division is publishing a notice in a newspaper having
circulation in the general Randolph County area, soliciting public comments on this second draft
permit. Please provide any written comments you may have to the following: NCDEQ/DWR,
NPDES Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 no later than 30
days after receipt of this draft permit.
Following the 30-day public comment period,the Division will review all pertinent comments and
take appropriate action prior to issuing a final permit. If you have questions concerning this draft
permit, please call me at [phone] or by email at [e-mail].
Sincerely,
Gary Perlmutter, Environmental Specialist II
NPDES Complex Permitting Unit
Hardcopy: NPDES Files
eCopy: US EPA Region 4
DWR/Winston-Salem Regional Office/Water Quality Operations
DWR/Wastewater Operator Certification Group/Maureen Kinney
DWR/WSS/Aquatic Toxicology Branch/Susan Meadows
DWR/Ecosystems Branch/Mark Vander Bourgh
City of Asheboro/Water Resources Director/Michael D. Rhoney, PE
Jean Zhuang, Southern Environmental Law Center
Geoff Gisler, Southern Environmental Law Center
Page 5 of 5

Permit NCO026123
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
City of Asheboro
is hereby authorized to discharge wastewater from a facility located at the
Asheboro Wastewater Treatment Plant
1032 Bonkemeyer Drive
Asheboro, NC 27203
Randolph County
to receiving waters designated as Hasketts Creek in the Cape Fear River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111 and IV
hereof.
This pen-nit shall become effective %lontli 18.
This permit and authorization to discharge shall expire at midnight on September 30, 2022.
Signed this day Month xx, 2018.
DRAFT
Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 16

Permit NCO026123
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as
of this issuance, any previously issued permit bearing this number is no longer effective. Therefore,the exclusive
authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and
provisions included herein.
The City of Asheboro is hereby authorized to:
l. Continue to operate and maintain the 9.0 MGD wastewater treatment plant with a discharge through
Outfall 001, consisting of the following components:
• Influent pump station with automatic bar screens and grit removal
• Influent ultrasonic flow meter
• Influent composite sampler
• Flow splitter box#1
• Seven (7)primary clarifiers; one (1)circular rated for 3.0 MGD, six (6) rectangular rated 1.0 MGD
each
• Trickling filter mixing/transfer pump basin
• Three(3) trickling filters, 140 feet diameter
• Recirculation box/valve vault and circulation pump basin#1
• Four(4) secondary clarifiers; 27,024 cu. ft. each
• Recirculation pump basin#2
• Nitrification mixing/transfer pump basin
• Flow splitter box#2
• Two (2) nitrification basins with mixing basin and blowers; 2,000,000 gallons each
• Flow splitter box#3
• Magnesium hydroxide chemical addition system
• Three(3) final clarifiers; 70,333 cu. ft. each
• Polymer chemical addition system
• One (1) Parkson Dynasand continuous flow tertiary filter
• Chlorine contact chamber with sodium hypochlorite addition for disinfection
• Sodium bisulfate addition for dichlorination
• Effluent flow meter
• Effluent composite sampler
• Cascade aeration basin
• Two (2) sludge digesters; 401,900 gallons each
• Drying beds, 105 ft. x 450 ft. total
• Sludge dewatering presses, thickener tanks, lime stabilization system, and solids storage
• Standby power generation
This facility is located at the Asheboro WWTP, 1032 Bonkemeyer Drive, Asheboro, in Randolph
County.
2. Discharge from said treatment works via Outfall 001, at the location specified on the attached map
into Hasketts Creek currently classified C waters in the Cape Fear River Basin.
Page 2 of 16

Permit NCO026123
PARAMETER CHARACTERISTICS EFFLUENT LIMITS
MONITORING REQUIREMENTS
Parameter code Monthly Weekly Daily Measurement Sample Sample
Average Average Maximum Frequency Type Location z
Total Chromium(Ng/L) 01034 Monitor and Report p Quarterly Composite Effluent
Chromium g/L) 7 01032 I'/ Monitor and Report_ Quarterly
-- _
Composite Effluent
Total Kjeldahl Nitrogen ----- __
(TKN)(mg/L) 00625 Monitor and Report Monthly Composite Effluent
Nitrite+Nitrate Nitrogen
(NO2+NO3)(mg/L) 00630 Monitor and Report Monthly Composite Effluent
Total Nitrogen(TN)
[TN=(NO2+NO3) +TKN] CO600 Monitor and Report Monthly
y Calculated Effluent
Total Phosphorus(TP)
(mg/L) CO665 Monitor and Report Monthly Composite Effluent
Dibromochloromethane
(Ng/L) 32105 Monitor and Report Quarterly Grab Effluent
Bromodichloromethane 8 38693 31.6 Ng/L
Monthly Grab Effluent
Chlorides(mg/L)9 00940 Monitor and Report p Quarterly Composite Effluent
Total Copper(Ng/L) 01042 Monitor and Report P Quarterly Composite Effluent
Total Cyanide 10 00720 5.0 Ng/L 22.0 Ng/L Monthly Grab
Effluent
Total Silver(Ng/L) 01077 Monitor and Report P Quarterly Composite Effluent
1,4-Dioxane 12 82388 97 pg/L
Monthly Grab Effluent
1,4-Dioxane Load 12 13 Daily average loading not to exceed
4.50lb/day Monthly Calculated Effluent
Chronic Toxicity 14 TGP3B Ceriodaphnia Pass/Fail at 90%effluent
Quarterly Composite Effluent
Effluent Pollutant Scan NC01 Monitor and Report P Footnote 15 Footnote 15 Effluent
Dissolved Oxygen(mg/L)2 00300 Monitor and Report P Variable 2 Grab U, D1, D2
Temperature(°C)2 00010 Monitor and Report P Variable" Grab U, D1, D2
Conductivity(pmhos/cm)2 00094 Monitor and Report Variable 2
Grab U, D1, D2
All footnotes are listed on the.following a e.
Page 4 of 16

Permit NCO026123
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (9.0 MGD)
[15A NCAC 0213.0400 et seq., 15A NCAC 0213.0500 et seq.] Grade IV Biological Water
Pollution Control System [I 5A NCAC 08G .0302]
a. During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge treated municipal and industrial wastewater from Outfall 001
Such discharges shall be limited and monitored' by the Permittee asspecified below:
EFFLUENT LIMITS MONITORING REQUIREMENTS
PARAMETER CHARACTERISTICS
Parameter Code Monthly Weekly Daily Measurement Sample Sample
Average Average Maximum Frequency Type Location z
Flow 50050 9.0 MGD Continuous Recording Influent or Effluent
BOD5(20°C)3 Influent and
(April 1 -October 31) C0310 5.0 mg/L 7.5 mglL Daily Composite Effluent
BOD5(20°C)3 Influent and
(November 1 -March 31) C0310 10.0 mg/L 15.0 mg/L Daily Composite Effluent
Total Suspended Solids Influent and
(TSS)3 C0530 30.0 mg/L 45.0 mg/L Daily Composite Effluent
Ammonia(NH3 as N)
(April 1 -October 31) C0610 2.0 mg/L 6.0 mg/L Daily Composite Effluent
Interim 4
Ammonia(NH3 as N)
(November 1 -March 31) C0610 4.0 mg/L 12.0 mg/L Daily Composite Effluent
interim 4
Ammonia(NH3 as N)
(April 1 -October 31) C0610 1.0 mg/L 3.0 mg/L Daily Composite Effluent
Final 4
Ammonia(NH3 as N)
(November 1 -March 31) C0610 1.8 mg/L 5.4 mg/L Daily Composite Effluent
final 4
Dissolved Oxygen(DO) 00300 Daily Average>6.0 mg/L Daily Grab Effluent
pH 00400 Between 6.0 and 9.0 standard units Daily Grab Effluent
Fecal Coliform 31616 200/100 mL 400/100 mL Daily Grab Effluent
(geometric mean)
Total Residual Chlorine 50060 17 pg/L Daily Grab Effluent
(TRC)s
Temperature(°C) 00010 Monitor and Report Daily Grab Effluent
Conductivity(Nmhos/cm) 00094 Monitor and Report Daily Grab Effluent
Total Hardness[as CaCO3] 00900 Monitor and Report Quarterly Composite Effluent
(mg/L)s
Page 3 of 16

Permit NC0026123
Footnotes:
1. Submit discharge monitoring reports electronically using the NC DWR's eDMR application system. See
Section A. (11.).
2. U = approximately 800 feet upstream of the discharge; D1 = downstream at NCSR 2128; and D2 =
downstream in the Deep River at NCSR 2261. The Permittee has deferred receiving-stream sampling to the
Upper Cape Fear River Basin Association by memorandum of agreement (MOA). Should this MOA
terminate for any reason, the Permittee shall immediately inform the Division in writing and immediately
resume instream monitoring in accordance with this permit. Instream samples shall be collected three times
per week from June 1 through September 30,and once per week from October 1 through May 31.
3. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15% of the respective influent
value(85%removal).
4. Interim Ammonia limits shall be effective during the period of the compliance schedule. Final Ammonia
limits become effective [within three(3)years of the effective date of this permit].The Permittee shall follow
the compliance schedule detailed in Section A. (6.).
5. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the
permit. However, the Pennittee shall continue to record and submit all values reported by a North Carolina
certified laboratory(including field-certified), even if these values fall below 50 µg/L.
6. Effluent Total Hardness sampling shall be conducted in conjunction with testing for hardness-dependent
metals(cadmium,chromium,copper, lead,nickel, silver and zinc).
7. If Chromium VI is not detected (i.e. non-detectable concentrations below the lower reporting level of the
procedure) after two years of sampling, the Permittee may request DWR to reduce or remove monitoring
requirements for Chromium VI in Section A. (L).
8. The Bromodichloromethane limit becomes effective [within two (2) years of the effective date of this
permit].The Permittee shall follow the compliance schedule detailed in Section A. (7.).
9. Chlorides will be monitored in conjunction with Chronic Toxicity tests.
10. Due to difficulties quantifying cyanide in a wastewater matrix,the Division shall consider all values reported
below 10 µg/L to be "compliant" with this permit. However, the Permittee shall submit to DWR all values
reported by a North Carolina-certified test method (even if values fall below 10 µg/L), and the Permittee
shall consider all reported values when calculating averages, if any, as required by this permit.
11. The Permittee should review and implement clean sampling techniques for Total Silver. The reporting
laboratory shall test to the lower reporting level of the procedure.
12. This limit becomes effective December 15, 2020. The Permittee shall follow the compliance schedule
detailed in Section A. (8.). Samples shall be collected monthly and analyzed using EPA Test Method 624.1;
both concentration and load shall be reported monthly. After the effective date, Starpet (industrial user
identified as the primary source of 1,4-Dioxane) shall continue to optimize treatment to further reduce
concentrations.
13. 1,4-Dioxane Load is the mass quantity discharged in a given period of time. See Section A. (9.) Calculation
of 1,4-Dioxane Loads.
14. Whole Effluent Toxicity samples shall be collected during the months of March, June, September, and
December. See Section A. (2.).
15. The Permittee shall preform three Effluent Pollutant Scans during the term of this permit. See Section A. (3.).
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 5 of 16

Permit NCO026123
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)—9.0 MGD
[15A NCAC 02B.0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase I1 Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
March, June, September and December. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
Chronic Value (ChV) below the permit limit, then multiple-concentration testing shall be
performed at a minimum, in each of the two following months as described in "North Carolina
Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised-December 2010) or
subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP313 for the pass/fail results and THP313 for the Chronic Value. Additionally, DWR Form AT-3
(original) is to be sent to the following address:
NC DEQ/DWR
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of"No Flow" in the comment area of the form. The report shall be submitted to the
Water Sciences Section at the address cited above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
Page 6 of 16

Permit NC0026123
testing quarter, which is the three-month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re-opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
Page 7 of 16

Permit NCO026123
A. (3.) EFFLUENT POLLUTANT SCAN (Municipal POTWs) [NCGS 143-215.1 (b)]
The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below.
One scan must be performed in each of the following years: 2020, 2021, and 2022. Analytical methods
shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether
parameters are present in concentrations greater than applicable standards and criteria. Samples should
be collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not
sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total
recoverable."
Ammonia(as N) C0610 1,2-dichloroethane 32103 Bis(2-chloroethoxy)methane 34278
Chlorine(total residual,TRC) 50060 Trans-1,2-dichloroethylene 34546 Bis(2-chloroethyl)ether 34273
Dissolved oxygen 00300 1,1-dichloroethylene 34501 Bis(2-chloroisopropyl)ether 34283
Nitrate 00620 1,2-dichloropropane 34541 Bis(2-ethylhexyl)phthalate 39100
Nitrite 00615 1,3-dichloropropylene 77163 4-bromophenyl phenyl ether 34636
Kjeldahl nitrogen 00625 Ethylbenzene 34371 Butyl benzyl phthalate 34292
Oil and grease 00556 Methyl bromide 34413 2-chloronaphthalene 34581
Phosphorus C0665 Methyl chloride 34418 4-chlorophenyl phenyl ether 34641
Total dissolved solids 70295 Methylene chloride 34423 Chrysene 34320
Hardness 00900 1,1,2,2-tetrachloroethane 81549 Di-n-butyl phthalate 39110
Antimony 01097 Tetrachloroethylene 34475 Di-n-octyl phthalate 34596
Arsenic 01002 Toluene 34010 Dibenzo(a,h)anthracene 34556
Beryllium 01012 1,1,146chloroethane 34506 1,2-dichlorobenzene 34536
Cadmium 01027 1,1,2-trichloroethane 34511 1,3-dichlorobenzene 34566
Chromium 01034 Trichloroethylene 39180 1,4-dichlorobenzene 34571
Copper 01042 Vinyl chloride 39175 3,3-dichlorobenzidine 34631
Lead 01051 Acid-extractable compounds: Diethyl phthalate 34336
Mercury(Method 1631E) COMER P-chloro-m-cresol 34452 Dimethyl phthalate 34341
Nickel 01067 2-chlorophenol 34586 2,4-dinitrotoluene 34611
Selenium 01147 2,4-dichlorophenol 34601 2,6-dinitrotoluene C0626
Silver 01077 2,4-dimethylphenol 34606 1,2-diphenylhydrazine 34346
Thallium 01059 4,6-dinitro-o-cresol 34657 Fluoranthene C0376
Zinc 01092 2,4-dinitrophenol 34616 Fluorene 34381
Cyanide 00720 2-nitrophenol 34591 Hexachlorobenzene C0700
Total phenolic compounds 32730 4-nitrophenol 34646 Hexachlorobutadiene 39702
Volatile organic compounds: Pentachlorophenol 39032 Hexachlorocyclo-pentadiene 34386
Acrolein 34210 Phenol 34694 Hexachloroethane 34396
Acrylonitrile 34215 2,4,64dchlorophenol 34621 Indeno(1,2,3-cd)pyrene 34403
Benzene 34030 Base-neutral compounds: Isophorone 34408
Bromoform 32104 Acenaphthene 34205 Naphthalene 34696
Carbon tetrachloride 32102 Acenaphthylene 34200 Nitrobenzene 34447
Chlorobenzene 34301 Anthracene CO220 N-nitrosodi-n-propylamine 34428
Chlorodibromomethane 34306 Benzidine 39120 N-nitrosodimethylamine 34438
Chloroethane 85811 Benzo(a)anthracene 34526 N-nitrosodiphenylamine 34433
2-chloroethyl vinyl ether 34576 Benzo(a)pyrene 34247 Phenanthrene 34461
Chloroform 32106 3,4 benzofluoranthene 34230 Pyrene 34469
Dichlorobromomethane 32101 Benzo(ghi)perylene 34521 1,2,4-tdchlorobenzene 34551
1,1-dichloroethane 34496 Benzo(k)fluoranthene 34242
Page 8 of 16

Permit NC0026123
Reporting. Test results shall be reported electronically via eDMR or on DWR Form — DMR-PPA1 (or
on a form approved by the Director) by December 3Is' of each designated sampling year. The report
shall be submitted to the following address: NC DEQ / DWR / Central Files, 1617 Mail Service
Center, Raleigh, North Carolina 27699-1617.
Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that
Municipal facilities that are subject to the Effluent Pollutant Scan requirements listed above are also
subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.210)(5)
and EPA Municipal Application Form 2A. The US EPA requires four (4) toxicity tests for a test
organism other than the test species currently required in this permit. The second species tests should be
conducted either quarterly for a 12-month period prior to submittal of the permit renewal application, or
four tests performed at least annually in the four and one-half year period prior to the application. The
second species tests must be multiple concentration (5 concentrations plus the control). These tests shall
be performed for acute or chronic toxicity, whichever is specified in this permit. POTWs performing
NPDES chronic Ceriodaphnia testing should perform chronic Fathead minnow testing. POTWs
performing NPDES acute Fathead Minnow testing should perform acute Ceriodaphnia testing. POTWs
performing NPDES chronic Mysid shrimp testing should perform chronic Silverside Minnow testing.
The second species toxicity test results shall be filed with the Aquatic Toxicology Branch at the
following address:
NC DEQ/ DWR
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Contact the Division's Aquatic Toxicology Branch at 919-743-8401 for guidance on conducting the
additional toxicity tests and reporting requirements. Results should also be summarized in Part E
(Toxicity Testing Data) of EPA Municipal Application Form 2A, when submitting the permit renewal
application to the NPDES Permitting Unit.
Page 9 of 16

Permit NCO026123
A. (4.) MERCURY MINIMIZATION PLAN (MMP) [NCGS 143-215.1 (b)]
The Permittee shall develop and implement a mercury minimization plan during this permit term. The
MMP shall be developed within 180 days of the permit effective date, and shall be available for
inspection on-site. A sample MMP was developed through a stakeholder review process and has been
placed on the Division website for guidance (https://deq.nc.gov/document/nc-model-mercury-
minimization-plan-dwr-npdes-swp-20130801). The MMP should place emphasis on identification of
mercury contributors and goals for reduction. Results shall be summarized and submitted with the next
permit renewal. Performance of the Mercury Minimization Plan will meet the requirements of the
TMDL (Total Maximum Daily Load) for mercury approved by USEPA on October 12, 2012, unless and
until a Waste Load Allocation specific to this facility is developed and this NPDES permit is amended to
require further actions to address the Waste Load Allocation.
A. (5.) NUTRIENT RE-OPENER [NCGS 143-215.1 (b)]
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North
Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part I1 sections B-12
and B-13 of this pennit, the Director of DWR may reopen this permit to require supplemental nutrient
monitoring of the discharge. The purpose of the additional monitoring will be to support water quality
modeling efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan
developed jointly by the Division and affected stakeholders. In addition, the results of water quality
modeling may require that limits for total nitrogen and total phosphorus be imposed in this pen-nit upon
renewal.
Page 10 of 16

Permit NCO026123
A. (6.) SCHEDULE OF COMPLIANCE FOR AMMONIA LIMITATIONS
[NCGS 143-215.1 (b)]
1. Within one (1) year from the effective day of the permit, the Permittee shall submit to the
Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to be
taken to achieve compliance with the Ammonia (NH3-N) limitations listed in Section A. (L),
which includes specific dates for completion or implementation of each action.
2. Within two (2) years from the effective date of the permit, the Permittee shall submit a report to
the Division summarizing actions taken during the previous year to achieve compliance with the
NH3-N limitations. The actions shall be in accordance with the Corrective Action Plan submitted
and approved by DWR.
3. The Permittee shall achieve compliance with the NH3-N limitations specified in Section A. (l.)
within three (3) years of the effective date of this permit.
Upon approval of the Corrective Action Plan by the Division, the report and actions become an
enforceable part of this permit. Any modifications to the schedule shall be requested to the Division at
least ninety (90) days before the deadline. Modifications to the schedule in excess of four (4) months
will be subject to public notice.
Corrective Action Plan and Reports shall include the owner's name, NPDES permit number and
Permittee contact person, and shall be submitted to:
(1) NCDEQ/ Division of Water Resources (2) NCDEQ/Division of Water Resources
NPDES Permitting Winston-Salem Regional Office
1617 Mail Service Center 450 West Hanes Mill Road, Suite 300
Raleigh, NC 27699-1617 Winston-Salem, NC 27105
Page 11 of 16

Permit NCO026123
A. (7.) SCHEDULE OF COMPLIANCE FOR BROMODICHLOROMETHANE LIMITATION
[NCGS 143-215.1 (b)]
1. Within six (6) months from the effective day of the permit, the Permittee shall submit to the
Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to be
taken to achieve compliance with the bromodichloromethane limitation listed in Section A. (1.),
which includes specific dates for completion or implementation of each action.
2. Within one (1) year from the effective date of the permit, the Permittee shall submit a report to
the Division summarizing actions taken during the previous six (6) months to achieve
compliance with the bromodichloromethane limitation. The actions shall be in accordance with
the Corrective Action Plan submitted and approved by DWR.
3. The Permittee shall achieve compliance with the bromodichloromethane limitation specified in
Section A. (L) within two (2) years of the effective date of this permit.
Upon approval of the Corrective Action Plan by the Division, the report and actions become an
enforceable part of this permit. Any modifications to the schedule shall be requested to the Division at
least ninety (90) days before the deadline. Modifications to the schedule in excess of four (4) months
will be subject to public notice.
Corrective Action Plan and Reports shall include the owner's name, NPDES permit number and
Permittee contact person, and shall be submitted to:
(1) NCDEQ/ Division of Water Resources (2) NCDEQ/Division of Water Resources
NPDES Permitting Winston-Salem Regional Office
1617 Mail Service Center 450 West Hanes Mill Road, Suite 300
Raleigh, NC 27699-1617 Winston-Salem, NC 27105
Page 12 of 16

Permit NCO026123
A. (8.) SCHEDULE OF COMPLIANCE FOR 1,4-DIOXANE LIMITATIONS
[NCGS 143-215.1 (b)]
1. Within six (6) months from the effective day of the permit, the Permittee shall submit to the
Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to be
taken to achieve compliance with the 1,4-Dioxane limitation listed in Section A. (L), which
includes specific dates for completion or implementation of each action.
2. Within eighteen (18) months from the effective date of the permit, the Permittee shall submit a
report to the Division summarizing actions taken during the previous year to achieve compliance
with the 1,4-Dioxane limitation. The actions shall be in accordance with the Corrective Action
Plan submitted and approved by DWR.
3. The Permittee shall achieve compliance with the 1,4-Dioxane limitations specified in Section A.
(L)by December 15, 2020 of the effective date of this permit.
Upon approval of the Corrective Action Plan by the Division, the report and actions become an
enforceable part of this permit. Any modifications to the schedule shall be requested to the Division at
least ninety (90) days before the deadline. Modifications to the schedule in excess of four (4) months
will be subject to public notice.
Corrective Action Plan and Reports shall include the owner's name, NPDES permit number and
Permittee contact person, and shall be submitted to:
(1) NCDEQ/Division of Water Resources (2) NCDEQ/ Division of Water Resources
NPDES Permitting Winston-Salem Regional Office
1617 Mail Service Center 450 West Hanes Mill Road, Suite 300
Raleigh, NC 27699-1617 Winston-Salem, NC 27105
A. (9.) CALCULATION OF 1,4-DIOXANE LOADS [NCGS 143-215.1 (b)]
a. The Permittee shall calculate average daily 1,4-Dioxane loads as follows:
i. Daily 1,4-Dioxane Load (lb/day) = 1,4-D (mg/L) X ADF x 8.34, where:
1,4-D = the average 1,4-Dioxane concentration (µg/L) of the grab sample collected during
the month x 1000 to convert it to mg/L;
ADF = the Average Daily Flow of wastewater discharged for the month of 1,4-Dioxane
sampling(MG/day); and
8.34 = conversion factor, from (mg/L x MG) to pounds
b. The Permittee shall report monthly 1,4-Dioxane results (µg/L and lb/day) in the appropriate
discharge monitoring report for each month.
Page 13 of 16

Permit NCO026123
A. (10.) 1,4-DIOXANE RE-OPENER [NCGS 143-215.1 (b)]
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North
Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part Il, Sections B-12
and 13-13 of this permit, the Director of DWR may reopen this permit to modify permit requirements to
address 1,4-Dioxane monitoring, treatment and/or compliance.
A. (11.) ELECTRONIC REPORTING OF MONITORING REPORTS [NCGS 143-215.1 (b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This Section supplements or supersedes the following sections within Part II of this permit
(Standard Conditions_for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reportinp_Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The Permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross-Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DEQ/DWR/Water Quality Permitting Section
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or
alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing
address above. See"How to Request a Waiver from Electronic Reporting" section below.
Page 14 of 16

Permit NC0026123
Regardless of the submission method, the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the Permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The Permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(l)(9), the permittee must identify the initial recipient at the time
of each electronic submission. The Permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at: https://www.federaire ister.jzov/documents/2015/10/22/2015-
24954/national-pollutant-discharge-elimination-system-npdes-electronic reporting rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The Permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to
the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary
waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports
shall be submitted electronically to the Division unless the permittee re-applies for and is granted a
new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers
are not transferrable. Only permittees with an approved reporting waiver request may submit
monitoring data and reports on paper to the Division for the period that the approved reporting
waiver request is effective.
Page 15 of 16

Permit NC0026123
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
http://deg.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part 11,
Section B. (11.)(a) or by a duly authorized representative of that person as described in Part 11,
Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North Carolina's
eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the
following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
V 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. 1
am aware that there are significant penalties for submitting false information, including the
possibility of f nes and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.)]
The Permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
Page 16 of 16

} .� � .�1' it ` � •- 1,• i �� `'-1J, ,;: t
t , i; � ,' �_r'i ��' •ille l/ � ` 7.� , ,_ _ .f Y ,�•Alillboro
Iz
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i
• \ Q 1 / �� A
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Downstream (D1) • �l �• I' `( '. j �,
84890000
r l IjA ashebo-ro WWTP r ,. Downstream (D2)nd Otfall 001 B4920000
LB4870000�'• am(U)
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City of Asheboro WWTP Facility X
NPDES Permit NCO026123 Location
a t 3S'46'00'N State Grid/ggo 0 19 SE 1 Randleman not to scale
Longitude_ 79'47'06- W Permitted Flowt 9.00 MGO
Receiving Strearnt HAMM Cr"k Orainaee ladnt Cape Fear River
sus► a cLea� C141t3d 3 C 4_ r 03.06.09 North 0measinn Randolph County

Fact Sheet
NPDES Permit No. NCOO26123
Permit Writer/Email Contact: Gary Perlmutter,[e-mail]
Date: Month xx, 2018
Division/Branch:NC Division of Water Resources/NPDES Complex Permitting Unit
Fact Sheet Template: Version 09Jan2017
Permitting Action:
® Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification(Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis,Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2' 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; 87%domestic, 13%industrial '
Facility Class: Grade IV
Bar screen,Grit removal,Parshall flume,Primary clarifiers,Trickling
Treatment Units: 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
' Percentages calculated from 2016 actual industrial and total average daily flows(0.478 and 3.630 MGD,
respectively). Permitted industrial flow is 0.832 MGD or 9.2%of total permitted flow.
Page 1 of 18

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. This facility serves a population of 25,676
residents and operates a pretreatment program with 15 Significant Industrial Users(SIUs), 6 of which are
Categorical Industrial Users(CIUs).
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), Matlab Plant 14 (CIU 433: metal finishing, dropped from the pretreatment
program in 2016),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).
In addition, the Asheboro WWTP is receiving 1,400 gpd wastewater from the Randolph County School
Bus Maintenance Garage groundwater remediation project. This is not an SIU according to ORC Ray
Wiseman.
The average industrial flow rate was 0.478 MGD from January through December 2016.The uncontrollable
flow was 3.152 MGD for that same period. The facility has a DWR-approved Full Pretreatment Program
with a Long-Term Monitoring Program(LTMP) for its SIUs.
2. Receiving Waterbody Information
Receiving Waterbody Information
Outfalls/Receiving Stream(s): Outfall 001 /Hasketts Creek
Stream Segment: 17-12
Stream Classification: C
Drainage Area(mi2): 11.6
Summer 7Q10(cfs) 0
Winter 7Q10(cfs): -
30Q2 (cfs): 0.2
Average Flow(cfs): 12
IWC (%effluent): 100
303(d) listed/parameter: This stream segment is impaired for Copper and Benthos on
the 2016 final 303(d) list.
Subject to TMDL/parameter: Statewide TMDL for Mercury
Subbasin/HUC: 03-06-09/03030003
USGS Topo Quad: D19SE Randleman, NC
Page 2 of 18

3. Effluent Data Summary
Effluent data is summarized below for the period January 2014 through December 2017 for Outfall 001.
Table 1. Effluent Data Summary
Parameter Units Average Max Min Permit Limit'
Flow MGD 3.63 13.46 1.27 MA= 9.0
BOD summer mg/L 2.4 > 8.7 < 2.0 MA= 5.0
WA= 7.5
BOD winter mg/L 3.4 13.6 1.9 MA= 10.0
WA= 15.0
BOD Removal % 99.0 99.7 98.0 >_ 85
Total Suspended Solids <4.8 51.5 < 2.0 MA= 30.0
(TSS) mg/L WA=45.0
TSS Removal % 98.7 99.7 96.7 > 85
Ammonia(NH3-N) mg/L <0.2 4.0 <0.1 MA= 2.0
summer WA= 6.0
Ammonia (NH3-N) mg/L < 0.9 29.5 <0.1 MA=4.0
winter WA= 12.0
Dissolved Oxygen mg/L 8.0 10.7 6.0 DA>6.0
(DO)
pH SU 6.9 7.9 6.0 Between 6.0 and 9.0
Fecal Coliform MA=200
(geometric mean) #/100 mL 6 >6000 < 1 WA=400
Total Residual µg/L < 15.6 48 < 15.0 DM = 17
Chlorine(TRC)
Temperature °C 20.5 29.7 9.5 Monitor only
Conductivity µmhos/cm 1016 1952 238 Monitor only
Total Chromium µg/L < 6.5 26.0 <5.0 MA= 50
DM= 1033
Total Mercury ng/L 1.7 8.5 0.8 MA= 12
DM = 36
Total Nitrogen(TN) mg/L 13.3 27.4 2.3 Monitor only
Total Kjeldahl mg/L 2.1 5.9 0.8 Monitor only
Nitrogen(TKN)
Nitrate/Nitrite Nitrogen mg/L 11.3 26.4 0.8 Monitor only
(NO2+NO3)
Total Phosphorus(TP) mg/L 0.38 1.81 0.08 Monitor only
Page 3 of 18

Dibromochloromethane µg/L < 8.3 20.4 <5.0 Monitor only
Bromodichloromethane µg/L < 11.7 362 <5.0 Monitor only
Chloride mg/L 166 300 68 Monitor only
Total Copper µg/L 4.7 15.0 2.0 Monitor only
Total Zinc µg/L 25.2 55.0 13.4 Monitor only
MA= Monthly Average, WA= Weekly Average, DA= Daily Average, DM = Daily Maximum.
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 in Hasketts Creek(U),one downstream in Hasketts Creek(D 1)and one
additional downstream in Deep River(D2).These locations correspond to the ambient monitoring stations
B4870000 (U), B4890000 (D1), and B4920000 (D2). Data from U and D2 were obtained from the
Monitoring Coalition Coordinator and span from January 2013—December 2016.Data from D 1 were from
the Ambient Monitoring System Coordinator and span from January 2013—July 2016. The Permittee is a
member of the Upper Cape Fear River Basin Association,and instream monitoring is provisionally waived
in light of their participation.
Dissolved Oxygen (DO) remains a parameter of concern for aquatic life. Instream data showed that the
standard of 5.0 mg/L was maintained at all stations with minima of 6.0 mg/L at U,6.5 mg/L at D1,and 5.4
mg/L at D2. Effluent averages for September 2013 through August 2017 also were above 5.0 mg/L. The
permit will continue to include instream DO monitoring.
Temperature remains a parameter of concern for aquatic life. The standard maximum of 29 °C for upper
piedmont and mountain waters was maintained at all stations. However, downstream temperatures
exceeded the water quality standard of 2.8 °C above the natural water temperature when compared to
upstream data from 2013-2016 with 8 instances of 29 measurements or 28%at D1 and 10 instances of 60
measurements or 17% at D2. Concurrent effluent temperatures appeared similar to the instream
temperatures, but with warmer winter minima. The permit will continue to include instream Temperature
monitoring.
Conductivity is a parameter of concern because of industrial discharges. The permit does not currently
require instream monitoring,but data were available from the three stations.The data analyzed indicate that
Conductivity was significantly higher at D2 than at U(t= -10.94,p<0.0001), and substantially higher at
D1.Averages are:U= 114 uS/cm,D1 =726 uS/cm,and D2=222 uS/cm.Concurrent effluent Conductivity
averaged 1037 uS/cm. Because the facility has a pretreatment program and the patterns noted above,
instream monitoring of Conductivity will be added to the permit.
Page 4 of 18

Instream Fecal Coliform monitoring is not required in the current permit.Division guidance(DWQ memo,
4/22/2002) states: "Instream monitoring for fecal coliform may be removed from municipal or domestic
wastewater permits (major or minor), unless the water body is impaired due to coliform or is a class B
waterbody." The receiving water, Hasketts Creek, is a Class C waterbody not impaired due to coliform,
thus justifying this parameter's absence from the permit instream monitoring requirements.
Analysis of loading for Copper was compared for the 303(d)-listing year of 2008 through 2016.Calculated
monthly average loadings(lb/day)from 2008 to 2016 show significant reduction over time(r2=0.485,p<
0.0001). Annual data tested statistically different among years with consistent decreases in yearly average
lbs/day of copper since 2008. See Stream Impairment Analysis for Copper in attachments for data and
graphs.
• Effluent Copper averaged 12.04 µg/L for 2008 and 5.67 µg/L in 2016 for average monthly samples.
Effluent Copper loading was 0.38 lbs/day in 2008 and 0.17 lbs/day in 2016.
• Annual average effluent Total Copper concentrations were below the 7 µg/L 303(d) listing level
since 2013.
Due to downstream impairment for Chlorophyll a exceedances in the Deep River [stream segment 17-
(10.5)dl], additional instream analysis was conducted for Inorganic Nitrogen (NO2+NO3), Total Kjeldahl
Nitrogen (TKN), Total Nitrogen (TN)and Total Phosphorous(TP). See attachments for instream nutrient
data summaries and graphs.
• Inorganic Nitrogen values were significantly higher at D2 than at U (t= -6.39,p < 0.0001), and
substantially higher at D1. Averages are: U= 0.17 mg/L, D1 = 6.95 mg/L, and D2 = 0.63 mg/L
NO2+NO3.Concurrent effluent NO2+NO3 data averaged 10.6 mg/L,indicating its influence on the
receiving stream.
• Total Kjeldahl Nitrogen values were significantly higher in D2 than in U (t= -3.32,p = 0.001),
and substantially higher at D 1.Average concentrations were:U=0.53 mg/L,DI = 1.27 mg/L,and
D2=0.69 mg/L TKN. Concurrent effluent TKN data averaged 2.1 mg/L, indicating its influence
on the receiving stream.
• Total Nitrogen values were significantly higher in D2 than in U (t = -6.54, p < 0.0001), and
substantially higher at D1.Average concentrations were: U=0.70 mg/L,D1 =8.22 mg/L,and D2
= 1.32 mg/L TN. Concurrent effluent TN data averaged 12.7 mg/L, indicating its influence on the
receiving stream.
• Total Phosphorus values were significantly higher in D2 than in U (t= -4.42,p < 0.0001), and
substantially higher at Dl. Averages were: U=0.06 mg/L,D1 =0.29 mg/L, and D2=0.10 mg/L
TP. Concurrent effluent TP data averaged 0.36 mg/L, indicating its influence on the receiving
stream.
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): The facility had no
enforcements during the prior permit cycle.The facility had one limit violation for N113-N monthly average
exceedance by 6.3% during the period from January 2013 through December 2017. This exceedence
resulted in a Notice of Deficiency(NOD).
Page 5 of 18

Summarize the compliance record with aquatic toxicity test limits and any second species test results(past
5 years): The facility passed 16 of 16 quarterly chronic toxicity tests from 2014 through 2017, as well as
all four (4) second species chronic toxicity tests, sampled on 12/8/2013, 9/8/2014, 5/31/2015, and
3/14/2016,as well as one sampled on 6/5/2017.
Summarize the resultsfrom the most recent compliance inspection: The most recent compliance evaluation
inspection,conducted on March 13, 2017, found the facility to be well operated and maintained.
6. Water Quality-Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non-carcinogen HH); 30Q2 streamflow(aesthetics); annual average flow(carcinogen, HE).
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.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: Limitations for BOD
are based on a Streeter Phelps model (Level B) for instream DO protection. No changes are proposed.
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: W LA calculations
were run using the annual 7Q10 of 0.0 cfs for both the summer and winter values.The resulting TRC limit
is 17 µg/L, and will be maintained in the permit.The WLA resulted in more stringent ammonia limits than
in the current permit (Table 2).
Table 2. Proposed Ammonia-N Limits(mg/L).
Season Monthly Average Weekly Average
Summer 1.0 3.0
Winter 1.8 5.4
Page 6 of 18

Review of DMR data from January 2014 through December 2017 revealed a few isolated exceedences with
proposed monthly and weekly winter average limits(Fig. 1),suggesting upset conditions.The City expects
to be able to comply with the new NH3-N limitations, but requested a compliance schedule to ensure
compliance.
Asheboro WWTP Effluent NH3-N (proposed limits)
• Eff WA Eff MA MA Limit — — — WA Limit
10
9
8 w
7 •
6
ob 5 —
E 4 1 I I • I I
1 I
I
3 •f- - - - I I - - - - - - I- - - -
2 "o•
1 • • •I f •
0
C5K1 A\N
Figure 1. Asheboro WWTP effluent monthly average(MA) and weekly average
(WA)concentrations(mg/L)with their respective proposed limits for potential
compliance evaluation.
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 May 2014 and
May 2017 for the following parameters: arsenic, cadmium, chlorides, total chromium, copper, cyanide,
lead, molybdenum, nickel, selenium, silver, dibromochloromethane, bromodichloromethane, and zinc.
After review of the 3 effluent pollutant scans, the RPA was expanded to include chloroform. 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: Cyanide, Bromodichloromethane
• 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
Page 7 of 18

the maximum predicted concentration was > 50% of the allowable concentration: Chlorides,
Copper, Total Chromium, Chromium VI, Silver, Dibromochloromethane
o Chlorides will maintain a quarterly monitoring requirement to coincide with toxicity
testing, since the EPA is currently allowing an action level for this parameter.
o Total Chromium will maintain a monthly monitoring requirement but limits will be
removed as the maximum predicted value is greater than the Cr-VI allowable concentration
but less than the Cr-VI detection level (Instream Dissolved Metals Guidance memo,
6/10/2016, pages 7-9).
o Chromium VI will receive a quarterly monitoring requirement for 2 yrs,to be continued if
detected.
o Total Silver will receive a quarterly monitoring requirement with samples analyzed to the
lower reporting level of the procedure.
• 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, Lead, Molybdenum, Nickel, Selenium, Zinc and Chloroform
• 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
As part of the NC 2007-2014 Water Quality Standard (WQS) Triennial Review the total Chromium NC
WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality
Standards. The reasonable potential analysis using Asheboro WWTP's Total Chromium effluent data
showed reasonable potential to violate the new hexavalent chromium standard. Total Chromium is made
up of hexavalent and trivalent chromium. As a result, quarterly monitoring for Total Chromium and
Chromium VI will be added to the permit and the Total Chromium limits will be removed. If after two
years no detects of Chromium VI are found,then monitoring for that parameter will no longer be needed.
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: This 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
Page 8 of 18

industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-r2%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 2. Mercury Effluent Data Summary
2013 2014 2015 2016 2017
Number of Samples 12 1 12 12 12
Annual Average Conc.ng/L 2.0 1.6 1.1 l 1.3
Maximum Conc.,ng/L 5.8 3.5 2.2 .5
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 2).However, since the facility is greater than 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
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,Nitrate-nitrite Nitrogen,and Total Kjeldahl Nitrogen 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 will be
maintained. No changes are proposed.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: The contaminant 1,4-
Dioxane is a parameter of concern because it is characterized as a likely human carcinogen by the EPA. It
is a synthetic organic hydrocarbon that is highly miscible in water and does not readily biodegrade in the
environment. 1,4-Dioxane is primarily produced as a solvent stabilizer and used in a variety of industrial
processes. It is also often produced as a byproduct in industrial and manufacturing processes. As a result,
1,4-Dioxane has been found in ground and surface waters,potentially affecting drinking water.
The EPA requires public water systems to monitor finished drinking water for a list of unregulated
contaminants every five years under the 1996 Safe Drinking Water Act. In the Third Unregulated
Contaminant Monitoring Rule (UCMR3), 1,4-Dioxane was included in its nationwide monitoring effort.
Samples collected from 2013-2015 found elevated concentrations of 1,4-Dioxane in the Cape Fear River
Basin of North Carolina,which include some of the highest concentrations in the country.
The UCMR3 findings triggered the Division to conduct a multi-year monitoring study in the Cape Fear
River Basin. Objectives were to: 1) screen for 1,4-Dioxane across all seasons to identify sources with
Page 9 of 18

consistently elevated concentrations; 2) identify sources of 1,4-Dioxane, and 3) document changes in
concentration in response to municipal and industrial actions to reduce 1,4-Dioxane concentrations in their
discharges.The screening phase,conducted from October 2014—September 2015,identified four hotspots
in the Basin. One of these hotspots is located in Hasketts Creek downstream of Asheboro WWTP with
concentrations ranging from 147-478 µg/L. By contrast, samples collected in Hasketts Creek upstream of
the WWTP resulted below detection at < 3 µg/L. In the second phase of the study, wherein samples were
taken from October 2015—October 2016,elevated concentrations were confirmed in Hasketts Creek below
Asheboro WWTP, with concentrations ranging 69-614 µg/L. The third phase of the monitoring study is
currently underway.
During the first two study phases there was no EPA-approved test method for 1,4-Dioxane.Then the Clean
Water Act Methods Update Rule for the Analysis of Effluent, published August 8, 2017 and effective
September 27, 2017, expanded EPA Test Method 624.1 to include 1,4-Dioxane in its list of purgeables,
thereby approving this method for analysis of water samples for 1,4-Dioxane. In consideration of the high
concentrations found downstream of its discharge and the then newly accepted test method, the Division
sent a letter to Asheboro, dated October 31, 2017, requiring monthly monitoring for 1,4-Dioxane in its
effluent using EPA Test Method 624.1, beginning December 2017.
North Carolina rule 15A NCAC 02B .0208 allows the use of water quality criteria(WQC) in development
of permit limitations. The WQC for 1,4-Dioxane are 80 µg/L for fish consumption (i.e. non-water supply
waters, non-WS) and 0.35 µg/L for drinking water and fish consumption (i.e., water supply waters, WS).
In accordance with 15A NCAC 2B .0208, the Division used the non-WS WQC of 80 µg/L to establish a
permit limit of 149 µg/L monthly average for Asheboro's NPDES permit renewal. The draft permit was
sent to Public Notice on May 9,2018 with the proposed limit and a 3-year compliance schedule.The public
comment period ended on June 8, 2018.
Comments regarding the proposed 1,4-Dioxane limits and compliance schedule were received from the
City of Asheboro and several representatives of downstream public water utilities.The City questioned the
rule basis for establishing the proposed limit, to which is explained above. The remaining commenters
expressed three concerns: 1) downstream uses were not considered; 2) other sources of 1,4-Dioxane were
not considered; and 3)a request to shorten the compliance schedule.
Recent study data in the Deep River watershed, analyzed via EPA Test Method 624.1, were reviewed in
conjunction with Asheboro effluent data (Fig. 2). Background concentrations in Hasketts Creek upstream
of the WWTP were confirmed as below detection, at< 1 µg/L, as were other tributaries of the Deep River,
including the Rocky River. Elevated concentrations were found in the Deep River above the confluence of
Hasketts Creek: one at Worthville with an average of 2.57 µg/L and another further upstream at the
Randleman Lake water supply intake that measured 2.70 µg/L. The concentration at Worthville was
calculated to result in a concentration of 0.72 µg/L at the nearest downstream WS (i.e., WS-V) upper
boundary, located in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles downstream of the
POTW discharge. (Note: the WS segment is for the Goldston-Gulf water supply intake,currently inactive.)
This demonstrates that background levels alone exceed the river's ability to meet a downstream
concentration of 0.35 µg/L at the nearest downstream WS boundary.
North Carolina rule 15A NCAC 02B .0203 states:"Water quality based effluent limitations or management
practices for direct or indirect discharges of waste or far 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. " To date, no official impairment has been determined, but data has shown
levels of 1,4-Dioxane above the 0.35 µg/L WS-WQC in water supply segments of the Deep River.
However, DWR Public Water Supply Section has acknowledged best usage has not been impaired given
the EPA Drinking Water Health Advisory of 35 µg/L. (Note: the EPA Drinking Water Health Advisory
Page 10 of 18

and the NC WQC, the latter of which include fish consumption, are chronic values based on adult
consumption over a 70-year period.) Study data from July-August 2018 has shown concentrations of 1,4-
Dioxane in the Deep River nearest to the WS-V boundary to average 8.1 µg/L and in the river nearest its
mouth at the Cape Fear River averaged 1.4 µg/L (Fig. 2). Data from November 2017—August 2018 has
shown concentrations of 1,4-Dioxane at the Hoffer(Fayetteville)Water Treatment Plant intake in the Cape
Fear River to average 2.2 µg/L. All results in the Deep River were below the 35 µg/L EPA Drinking Water
Health Advisory level.
Figure 2. Average 1,4-Dioxane concentrations of DWR ambient monitoring stations in the Deep River
watershed, sampled December 2017—August 2018, analyzed using EPA Test Method 624.1. l
ntlun. ..in _ J larovr '^"�
a.m CPF089E4 High Point Lake •r � MCI—,.t.
!©}I 1,4-Dioxane<1 µg/L
'.
High Point CPFRD4 Randleman Lake Water Supply Intake
Eastside W WTP Rcmdlentair 1,4-Dioxane=2.70 µg/L
Lake
Asheboro WWTP 8480000 Deep River-Upstream
1,4-Dioxane=401 µg/L 1,4-Dioxane=2.57 µg/L
B6000000 Rocky River
62 Hasketts Cr—Upstream � f�
5 1,4-Dioxane<i µg/L
1,4-Dioxane<1 µg/L
•Goldston-Gulf Water
r upply Intake(inactive) 86040300 Deep River
B4890000 Hasketts Cr-Downstream �..� 1,4-Dioxane=1.38 µg/L
1,4-Dioxane=269 µg/LV�/ l
85190000 Deep River-Downstream
1,4-Dioxane=8.13 µg/L Sanford Water Supply Intake, -_
-'Cape Fear River r
WS-V upper boundary
In addition, 15A NCAC 02B .0216 for WS-IV waters states: "..the waters,following treatment required by
the Division, shall meet the Maximum Contaminant Level [MCL] concentrations considered safe for
drinking, culinary, or food processing proposes that are specified in the national drinking water
regulations and in the North Carolina Rules Governing Public Water Supplies, 15A NCAC 18C .1500."
To date, there is no MCL for 1,4-Dioxane. Protection of WS waters is achieved through protecting best
usage, which is the 35 µg/L Drinking Water Health Advisory.
The process of the indirect discharger Starpet Inc., an organic chemical, synthetic fibers and plastics
industry,has resulted in Asheboro discharging 1.4-Dioxane in concentrations ranging 48-1,100 µg/L from
December 2017—September 2018. The company has researched treatment options and has found a similar
facility in South Carolina that treats 1,4-Dioxane in its wastewater.This treatment will have to be modified
for the plant in Asheboro.
Page 11 of 18

Based on discussions with City officials who have worked with Starpet industrial representatives
investigating treatment alternatives, the City has agreed to the following measures in an effort to reduce
1,4-Dioxane as low as technology will allow. These measures include: a combination of concentration-
based and load-based limits; a shortened compliance schedule; and further optimization following
compliance.These measures would result in 1,4-Dioxane concentrations estimated to be less than 1.72 µg/L
(considering background concentrations)at the first WS upper boundary downstream of discharge, located
in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles downstream of the POTW discharge.
(See Evaluation of Alternative 1,4-Dioxane Limits for calculations.)
The agreed-upon technology-based Best Professional Judgement(BPJ) 1,4-Dioxane limitations are:
• Monthly Average limit of 97 µg/L
• Mass Loading limit of 4.50 lb/day based on the POTW's design flow at 9.0 MGD and a
concentration of 60 µg/L.
A combination of concentration and mass loading limits will ensure 1,4-Dioxane concentrations less than
1.72 µg/L at the nearest WS boundary both in the short term and in the long term as flow increases at
Asheboro WWTP. The City has also agreed to shorten the compliance schedule to a period ending
December 15,2020,based on Starpet's timeline to modify and install treatment technology. Given the new
technology, it is possible further optimization of treatment at Starpet can further reduce 1,4-Dioxane
concentrations.
Proposed permit changes regarding 1,4-Dioxane
Based on these considerations,the Division proposes the following changes to Asheboro's permit regarding
1,4-Dioxne:
• In Section A. (I.) Effluent Limitations and Monitoring Requirements, the monthly average 1,4-
Dioxane limit of 149 µg/L is replaced with a monthly average limit of 97 µg/L and an average daily
load limit not to exceed 4.50 lb/day,to become effective December 15, 2020.
• A footnote is added to the 1,4-Dioxane limitations in Section A. (1.) to require optimization upon
achieving compliance to further reduce effluent 1,4-Dioxane concentrations.
• The Special Condition specifying the 1,4-Dioxane compliance schedule is changed from three-
years to a final date of December 15, 2020. Annual milestones are adjusted to 6 months for the
corrective action plan, and 18 months for an action summary report.
• A new Special Condition is added for calculating and reporting daily average 1,4-Dioxane load
(lb/day), at a monthly frequency.
• A new Special Condition is added to reopen the permit to modify 1,4-Dioxane limits as
optimization is achieved.
As a separate note, the Division sent an administrative letter to High Point Eastside WWTP, which
discharges into the Deep River upstream of Randleman Lake (Fig. 2), requiring monthly 1,4-Dioxane
sampling beginning November 1, 2018. The Division will pursue separate actions to reduce background
levels of 1,4-Dioxane in the Deep River as additional sources are identified.
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 1 SA
NCAC 2H.01 07(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: A compliance schedule is proposed
for meeting the 1,4-Dioxane limit ending December 15, 2020. A two-year compliance schedule will be
added for meeting the bromodichloromethane limit; and a three-year compliance schedule will be added
for meeting the NH3-N limits.
Page 12 of 18

If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e)and 15A NCAC 2B.0226 for this permit renewal: NA
7. Technology-Based Effluent Limitations (TBELs)
Municipals
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg1L
BOD51TSS for Monthly Average, and 45 mg/L for BODs/TSS 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: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES
Guidance,Monitoring Frequency for Toxic Substances(7/15/2010 Memo); 3)NPDES Guidance,Reduced
Page 13 of 18

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.
No effluent parameters in the current permit have reduced monitoring frequencies.
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 3. Current Permit Conditions ' and Proposed 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
BODS WA 7.5 mg/L No change conducted in 1995,and for
Winter: protection of DO standard(15A
MA 10 mg/L NCAC 2B .0200).
WA 15 mg/L
MA 30 mg/L TBEL. Secondary treatment
TSS WA 45 mg/L No change standards/40 CFR 133 / 15A
NCAC 2B .0406.
Summer:
Summer: MA 1.0 mg/L
MA 2.0 mg/L WA 3.0 mg/L
NH3-N WA 6.0 mg/L Winter: WQBEL. Based on the current
Winter: MA 1.8 mg/L WLA for protection of aquatic life.
MA 4.0 mg/L WA 5.4 mg/L
WA 12.0 mg/L Add 3-yr compliance
schedule
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.
Fecal Coliform MA 200/100 mL No change WQBEL. WQ standard, 15A
WA 400 /100 mL NCAC 2B .0200.
Page 14 of 18

WQBEL. 15A NCAC 2B .0200-
Based on the current WLA for
Total Residual Chlorine DM 17 µg/L No change protection of aquatic life.Facility
is using chlorine disinfection.
WQBEL. 15A NCAC 2B .0200,
Temperature Monitor daily No change .0500
15A NCAC 2B.0500, added based
Add instream on the presence of an industrial
monitoring upstream pretreatment program and the 2002
Conductivity Monitor daily (U)and downstream Instream Conductivity and Fecal
(D1 and D2) Coliform Monitoring Guidance.
WQBEL. 15A NCAC 2B.0200.
Monitor quarterly in Reasonable potential found. EPA
Chlorides conjunction with No change allows action level,passing
Chronic Toxicity test chronic toxicity tests
WQBEL. 15A NCAC 2B.0200.
No reasonable potential was found,
MA 50 µg/L but maximum predicted value>
Total Chromium Quarterly monitoring DM 1033 µg/L Cr-IV allowable concentration.
NPDES permitting guidance for
dissolved metals.
WQBEL. 15A NCAC 2B.0200.
Quarterly monitoring Reasonable potential to exceed
Chromium VI No requirement for two years; to be WQS found in RPA. NPDES
continued if detected permitting guidance for dissolved
metals.
WQBEL. 15A NCAC 2B.0200.
No reasonable potential found in
Total Copper Monitor quarterly No change value b t maximum of the al edicte
wable
concentration.
WQBEL. 15A NCAC 2B.0200.
Cyanide No requirement DM 22.0 µg/L
MA .0 µg/L Reasonable potential to exceed
WQS found in RPA.
Remove from permit; WQBEL.Based on the statewide
MA 12 ng/L add Mercury 2012 TMDL; monitoring
Total Mercury DM 36 ng/L Minimization Plan conducted during PPAs and
(MMP) pretreatment LTMP.
Quarterly monitoring at WQBEL. 15A NCAC 2B.0200.
lower reporting level of No detects at<5 µg/L NPDES
Total Silver No requirement procedure for permitting guidance for dissolved
pretreatment LTMP metals
WQBEL. 15A NCAC 2B.0200.
Total Zinc Monitor quarterly Remove from permit No reasonable potential found in
RPA,but maximum predicted
Page 15 of 18

value< 50%of the allowable
concentration.
WQBEL. EPA Nationally
Recommended Water Quality
Dibromochloromethane Monitor quarterly No change Criteria(NRWQC). No reasonable
potential found in RPA, but
maximum predicted value<50%
of the allowable concentration.
MA 31.6 µg/L WQBEL. EPA NRWQC.
Bromodichloromethane Monitor quarterly Add 2-yr compliance Reasonable potential to exceed
schedule criterion found in RPA.
15A NCAC 2B.0500; nutrient
Total Nitrogen Monitor monthly No change criteria development in the Upper
Cape Fear River Basin.
15A NCAC 2B.0500; nutrient
Total Kjeldahl Nitrogen Monitor monthly No change criteria development in the Upper
Cape Fear River Basin.
Nitrate+Nitrite 15A NCAC 2B.0500; nutrient
Nitrogen Monitor monthly No change criteria development in the Upper
Cape Fear River Basin.
15A NCAC 2B.0500; nutrient
Total Phosphorus Monitor monthly No change criteria development in the Upper
Cape Fear River Basin.
MA 97 µg/L with a BPJ. Based on a review of
load limit not to exceed technologies used in organic
4.50 lb/day. chemical, synthetic fibers and
1,4-Dioxane No requirement Add compliance plastics industries and
schedule ending modifications necessary to treat the
December 15, 2020. specific industrial wastewater at
Continue optimization
Starpet.
upon compliance.
Quarterly WQBEL. No toxics in toxic
Chronic Toxicity Ceriodaphnia d ubia No change amounts. 15A NCAC 2B.0200 and
Pass/Fail at 90/0 15A NCAC 2B.0500
effluent
Effluent Pollutant Scan Three times per No change 40 CFR 122
permit cycle
Add quarterly effluent Revised water quality standards
Total Hardness No requirement and EPA's guidelines on hardness
monitoring dependent metals.
Add Electronic In accordance with EPA Electronic
Electronic Reporting No requirement Reporting Special Reporting Rule 2015.
Condition
Nutrient Reopener for Special Condition No change Upper Cape Fear River nutrient
TN and TP strategy requirement.
Page 16 of 18

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: xx/xx/2018
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 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
• 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,and the need to consider downstream water supply waters and any
additional sources in developing permit limits. 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.
If Yes, list changes and their basis below:
• A three-year compliance schedule was added for meeting the NH3 limits.
• A two-year compliance schedule was added for meeting the bromodichloromethane limit.
• 1,4-Dioxane limit was reduced from 149 µg/L monthly average to 97 µg/L monthly average with
a load limit not to exceed 4.50 lb/day.
• A footnote was added to 1,4-Dioxane limits in the Effluent Limitations and Monitoring
Requirements requiring optimization for further I A-Dioxane reduction upon compliance.
• A 1,4-Dioxane load calculation Special Condition was added to the permit.
• 1,4-Dioxane compliance schedule was reduced from three years to terminate on December 15,
2020.
• A reopener clause has been added to modify 1,4-Dioxane monitoring, treatment and/or
compliance.
Page 17 of 18

15. Fact Sheet Attachments (if applicable)
• Pretreatment Information Request form, completed
• Final 2016 NC 303(d) list,page 14(Hasketts Creek impairment)
• Effluent parameter trend charts and summary statistics
• Effluent BOD and TSS removal sheets
• Instream parameter trend charts and summary statistics(DO,Temp, Conductivity)
• DWQ guidance memo, 4/22/2002
• Effluent Copper Loading analysis
• Final 2016 NC 303(d) list,page 13 (Deep River chlorophyll a impairment)
• Instream parameter trend charts and summary statistics(nutrients)
• Monitoring Report (MR)Violations page
• Whole Effluent Toxicity and Self-Monitoring Summary,page 5
• Compliance Evaluation Inspection reports, March 13,2017
• IWC Calculations sheet(waste load allocation for TRC and N13-N)
• RPA Spreadsheet Summary and dissolved to total metal calculator
• NPDES Implementation of Instream Dissolved Metal Standards memo(6/10/2016). Pp 7-10
• Dissolved Metals Implementation—Freshwater Standards fact sheet memo
• Mercury WQBEL/TBEL evaluation
• Pages 12-13 of the North Carolina Nutrient Criteria Development Plan (DWR 2014)
• 1,4-Dioxane Monitoring in the Cape Fear River Basin (DWR 2017)
• Randleman Lake 1,4-Dioxane calculations
• 1,4-Dioxane alternate limit evaluation
Page 18 of 18

NPDES/A uifer Protection Permitting Unit Pretreatment Information Request Form
PERMIT WRITER COMPLETES THIS PART: PERMIT WRITERS-AFTER you get this form back
Check all that apply from PERCS:
-Notify PERCS if LTMP/STMP data we said should be
Date of Request 7/28/2017 municipal renewal x on DMRs is not really there,so we can get it for you
Re uestor Jennifer Busam new industries (or NOV POTW).
Facility Name Asheboro WWTP WWTP expansion -Notify PERCS if you want us to keep a specific POC
Permit Number NCO026123 Speculative limits in LTMP/STMP so you will have data for next permit
renewal.
Region Wiston-Salem stream reclass. -Email PERCS draft permit,fact sheet,RPA.
Basin Cape Fear outfall relocation -Send PERCS paper copy of permit(w/o NPDES
7010 chan e boilerplate),cover letter,final fact sheet. Email RPA if
other changes.
other
check applicable PERCS staff: Other Comments to PERCS:
X BIRD,CPF,CTB, FRB,TAR- Sarah Bass 807-6310
CHO,HIW,LTN,LUM,NES,NEW, ROA,YAD
Monit Hassan(807-6314)
PERCS PRETREATMENT STAFF COMPLETES THIS PART:
Status of Pretreatment Program(check all that apply)
1)facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE
2)facility has no SIU's, does not have Division approved Pretreatment Program
X 3)facility has SIUs and DWQ approved Pretreatment Program(list"DEV'if program still under development)
X 3a)Full Program with LTMP
3b)Modified Program with STMP
4)additional conditions regarding Pretreatment attached or listed below
Flow, MGD Permitted Actual Time period for Actual STMP time frame:
Industrial 0.832 0.478 1/2016- 12/2016 Most recent:
Uncontrollable n/a 3.152 1/2016- 12/2016 Next Cycle:
a POC due to
a Parameter of Required POTW POC STMP LTMP
NPDESI Non- Required by POC due
C Concern(POC) Disch Permit EPA` by 503 to SIU"' ( Plain Effluent Effluent
gU Check List Limit Sludge" below)"" Freq Freq
BOD X 4 M
TSS X 1 4 M Q=Quarterly
NH3 X 4 M M=Monthly
Arsenic X X 4 M
Cadmium J X X 4 M
v' Chromium X v X X 4 M
v Copper X v X X 4 M
Cyanide X 4 M Is all data on DMRs?
v Lead J X X 4 M YES X
Mercury X X X 4 M NO(attach data
Molybdenum X 4 M
v Nickel v X X 4 M
Silver X 4 M
Selenium X X 4 M
v' Zinc X vl X X 4 M Is data in spreadsheet?
Total Nitro en 4 1 YES email to writer)IX
Phosphorus 4 NO
Mn X 4 M
4
4
4
'Always in the LTMP/STMP "Only in LTMP/STMP if sludge land app or composte(dif POCs for incinerators)
"Only in LTMP/STMP while SIU still discharges to POTW ""Only in LTMP/STMP when pollutant is still of concem to POTW
Comments to Permit Writer(ex.,explanation of any POCs• info you have on IU related investigations into NPDES problems):
HWA last approved 6/30/2017 based on monthly data from 1/2016 through 12/2016;spreadsheet attached. Program has 14 SIUs.
NCO026123 NPDES_Pretreatment.request.07282017_completed
Revised July 24,2007

1C. Final 2016 Category 5 Assessments -303(d) List
EnWron"amtd Deep River Subbasin Cape Fear River Basin
QUONr
Assessment Unit Name Assessment Unit Description
Assessment Unit Number Water Quality Classification Length/Area Units
DEEP RIVER(including High Point L From source in backwaters of High Point Lake to dam at High Point
Lake(City of High Point water supply intake)
17-(1) WS-IV;CA:* 263.3 FW Acres
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria > 10%and>90 conf Chlorophyll a (40 µg/l,AL, NC) 5
East Fork Deep River From Thatcher Road to a point 0.4 mile downstream of Guilford County
SR 1541
17-2-(0.3)b WS-IV:* 4.8 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria Fair Benthos(Nar,AL, FW) 5
Haskett Creek From source to SR 2149
17-12a C 6.3 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria > 10%and >90 conf Dissolved Oxygen (4 mg/I,AL, FW) 5
Haskett Creek From SR 2149 to Asheboro WWTP Outfall
17-12b1 C 0.6 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria Poor Benthos (Nar,AL, FW) 5
Haskett Creek From Asheboro WWTP Outfall to Deep River
17-12b2 C 0.7 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria > 10%and >90 conf Copper(7 µg/I, AL, FW) 5
Hickory Creek From a point 0.6 mile upstream of mouth to Randleman Reservoir, Deep
River
17-8.5-(3) WS-IV;CA:* 0.9 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria Fair Benthos(Nar,AL, FW) 5
3/23/2018 Final 2016 NC Category 5 Assessments Page 14 of 196

� �
C

FO *
oro WWTP (NC0026123) - Flow
• Eff MA MA Limit
• • Summary Statistics
4.0 • • ••• • •• ••••• •• • ••• Average 3.631
2.0 ••••••• •••• ••• •• •• •••• Min 1.266
1.0 Max 13.463
0.0
1\��\�01� \tip\�oy� °yy �~\�°1�
F
ro WWTP (NC0026123) - BOD5
• Eff MA - - - WA Limit MA Limit
Summary Statistics
Winter
Average 3.4
Min 1.9
6 •• - - - - LJ74%6
- - - Max 13.6
4 • ; Summer
Average < 2.4
0 Min < 2.0
Max 8.7
1ti\tip \ti°\ \titi\ a\ti°\
Asheboro WWTP (NC0026123) - TSS
® Eff WA Eff MA WA Limit - - MA Limit
50
45 - - - - - - - - - - -
40 - Summary Statistics
35
30 Average <4.7
0 25 Min < 2.0
E 20 Max 51.5
15
10 j • Z •
5
0
01A 01h Sti\�o�° °yo o�� y� °1�
Eff= Effluent; MA = Monthly Average; WA=Weekly Average
Page 1 GB Perlmutter, rev. 10/1/2018

Asheboro WWTP (NC0026123) - NH3-N
• Eff WA Eff MA - - - WA Limit MA Limit
14 Summary Statistics
12 Winter
10 i i i i Average < 0.9
i i : i i i Min < 0.1
Max 29.5
E 6 = - - - -� ' I - - - i
i _ _ _ � � _ _ _. � � _ i
Summer
4 �.� Average < 0.2
2 , 1 Min <0.1
o Max 4.0
O,� O,b O,a 01h O,� O�� 6111 011 OtiO
4", 0\tip\~ �\O\'L 0\�~\T
Asheboro WWTP (NC0026123) - DO
• Eff Daily DA Limit
12
10
8 • Summary Statistics
� 6 • . • • Average 8.03
E Min 6.02
4 Max 10.70
2
0
O,� O O,b ON O O,b O,'` O,'` O,O
��'L (.\"OIL � ,\�'L A\*11 4,11'L �\1��'L 3\O�L 0�~~\~ b�10\~
Asheboro WWTP (NC0026123) - pH
• Eff Daily - -- Lo.Limit Up.Limit
10
9 - - - - - - - - - - - - - - - - - - - - - - - - -
8 Summary Statistics
j Average 6.9
Vi Min 6.0
6 - Max 7.9
5
4
O,A O,'\ O,�
4,11
Eff= Effluent; MA= Monthly Average; WA=Weekly Average; DA= Daily Average; Lo. = Lower; Up. = Upper
Page 2 GB Perlmutter, rev. 10/1/2018

Asheboro WWTP (NC0026123) - Fecal Coliform
• Eff WA . Eff MA WA Limit MA Limit
1000
J
E - - - - - - - - -. - - - - ` _- - - - - - - - - - - -
0
100 • Summary Statistics
• • •• .� Geometric
v • '�, �• , � ••�% Mean 6
10 • • .'' •:4 • • �� 1, T• j! '; Min < 1
o • • . :A ' l Max > 6000
� 1
�o\ti0\,LO,R14,LO,h '�ti\,L01�O 'y�\�O'y�O \`O\�O'y1 'L�\�O'y1 O\�0,0
Asheboro WWTP (NC0026123) - TRC
• Eff Daily Limit Compliant
60
50 •
40 • Summary Statistics
J •
30 •• Average < 15.6
• t • • Min < 15.0
zo _ _•i_-- Max 48.0
10
0
\•10,� ti01� LO,a ti01h L01(O y0y(O ti0y� ti01� ti0,�
1ti\titi \1�\ \gyp\
Asheboro WWTP (NC0026123) - Temperature
•Eff Daily
35
30
25
Summary Statistics
u 20VVVN Average 20.5
15 Min 9.5
10 Max 29.7
5
0
10,E LO,� L01� 6N Oti0 Otis 011 Oti1 Oti0
NI
Eff= Effluent; MA = Monthly Average; WA=Weekly Average
Page 3 GB Perlmutter, rev. 10/2/2018

Asheboro WWTP (NC0026123) - Conductivity
•Eff Daily
2,500
2,000
•. Summary Statistics
1,500 . �• Average 1016
E t �+ SD 285
1,000
3 f Min 238
500 •. !' • y Max 1952
0
oti3 otia otia oti� oti� oti� oti� oti� oti�
1y\11 IO\1o�ti ��\�,�\ti \1h�ti 1\�ti�ti �\���ti �\��ti �\�v�ti a\�6ti
Asheboro WWTP (NC0026123) - Total Chromium
—+—Eff Monthly MA Limit
60
50
40 Summary Statistics
Average < 6.5
u� 30 Min < 5.0
20 Max 26.0
10
0
O,O O,O
\ti ,��ti A\1h�ti y\�ti�ti �\1� �\�\ti
Asheboro WWTP (NC0026123) - Total Mercury
Eff Monthly MA Limit
14
12
10 Summary Statistics
8 Average 1.7
c 6 Min 0.8
4 Max 8.5
2
0
oti3 otia o1a oy� 01� oti� oy� oy� Oy�b
1y\�,v�ti \�o\ti 1�\^'I\ �h�ti 1\�ti�ti \���ti �\��ti \���ti a\yo\ti
Eff= Effluent; MA= Monthly Average
Page 4 GB Perlmutter, rev. 10/2/2018

Asheboro WWTP (NC0026123) - Nitrogen
TN -----TKN — — —NO2+NO3 Summary Statistics
TN
30 Average 13.3
25 Min 2.3
20
Max 27.4
� 15 TKN
10 ► ^t Min 0.8
Max 5.9
0 r I` Average 11.3
Min
\titi\�°y� \ti°\T \tip\T \ti`'\T°~h \�ti\ \tip\ � 1� \ti°\�°y� Max 20.4
titi ti
Asheboro WWTP (NC0026123) - Phosphorus
Eff Monthly TP
2
1.8
1.6 Summary Statistics
1.4 Average 0.38
J 1.2
1 Min 0.08
E 0.8 Max 1.81
0.6
0.4
0.2 AJU
0
°tip qz$ °,yb CP °,y0 °tip °y'� 53
ti1 °10
\yI SP ~titi\,,\\ \yh\� 1\� �\� \e\~ \�rff
Asheboro WWTP (NC0026123) Eff Quarterly
—,�Bromodichloromethane Dibromochloromethane
Summary Statistics
40 Bromodichloroomethane
35 Average < 11.7
30 Min < 5.0
25 Max 36.2
o 20 Dibromochloromethane
15 �� i `` Average <8.3
10 Min < 5.0
5 ♦— 'q- +— • ' Max 20.4
0
b 0x h p ° p p p
Eff= Effluent; TN = Total Nitrogen, TKN =Total Kjeldahl Nitrogen; NO2+NO3= Nitrite+ Nitrate;
TP =Total Phosphorus
Page 5 GB Perlmutter, rev. 10/1/2018

Asheboro WWTP (NC0026123) - Chloride
—0—Eff Quarterly
350
300
250 Summary Statistics
200 Average 166
E 150 Min 68
100 Max 300
50
0
O.y"i otia OtiD oyh oy� O,y�O O,y� O,y� O,y'b
Asheboro WWTP (NC0026123) - Total Copper
-v Eff Monthly
16
14
12 Summary Statistics
10 Average 4.7
$ Min 2.0
6 Max 15.0
4
2
0
O1� Oyb OyA OyS Oy(o Oti(o (SN O11 Oy4>
y1\��\ti o\moo\ti A\ti \1h\ti \��\ti \��\ti \o\ti \�v\ti a\moo\ti
Asheboro WWTP (NC0026123) - Total Zinc
- �--Eff Monthly
60
50 Summary Statistics
40 Average 25.2
Min 13.4
uo 30 Max 55.0
20
10
0
1�\titi o\tio\ 1�\,y�\
Eff= Effluent
Page 6 GB Perlmutter, rev. 10/1/2018

Output
Monthly BOD Average Result
Month Influent Effluent Removal Rate (%)
January-14 300.90 3.19 98.94
February-14 322.15 2.55 W21
March-14 238.10 3.60 98.49
April-14 237.29 1.91 99.20
May-14 335.71 1.74 99.48
June-14 388.33 1.55 99.60
July-14 355.77 1.63 99.54
August-14 387.71 1.40 99.64
September-14 399.14 2.18 99.45
October-14 382.48 2.67 99.30
November-14 414.67 3.21 99.23
December-14 379.90 3.80 99.00
January-15 270.05 4.36 98_39
February-15 256.65 3.69 98.56
March-15 231.00 3.63 98.43
April-15 257.33 3.11 98.79
May-15 284.65 2.05 99.28
June-15 313.82 1.52 99.51
July-15 311.36 1.73 99.44
August-15 264.10 1.82 99.31 Summary Statistics
September-15 278.48 1.93 99.31 average 99.04
October-15 227.32 2.36 98.96 max 99.65
November-15 172.37 2.49 98.56 min 98.04
December-15 205.81 2.26 98.90
January-16 204.26 3.65 98.21
February-16 191.38 2.98 98.44
March-16 269.18 3.14 98.83
April-16 306.90 3.23 gg 95
May-16 259.86 2.71 98.96
June-16 329.86 1.62 99.51
July-16 314.05 1.11 99.65
August-16 277.78 1.24 99.55
September-16 308.57 1.30 99.58
October-16 282.71 1.12 99.60
November-16 287.15 1.67 99.42
December-16 286.63 3.14 98.90
January-17 214.20 3.85 98.20
February-17 258.10 3.52 98.64
March-17 218.39 4.27 98.04
April-17 177.16 3.46 98.05
May-17 220.68 2.95 98.66
June-17 211.55 1.87 99.12
July-17 268.75 1.36 99.50
August-17 272.13 1.51 99.44
September-17 393.25 1.70 99.57
October-17 343.77 1.74 99.49
November-17 326.20 2.97 99.09
December-17 301.22 3.03 98.99
January-18
February-18

Output
Monthly TSS Average Result
Month Influent Effluent Removal Rate (%)
January-14 226.90 6.45 97.16
February-14 243.43 3.41 98.60
March-14 236.97 5.30 97.76
April-14 254.17 1.84 99.28
May-14 447.97 1.50 99.67
June-14 489.33 1.60 99.67
July-14 420.00 1.76 99.58
August-14 452.26 2.15 99.52
September-14 471.72 2.66 99.44
October-14 450.65 3.78 99.16
November-14 626.79 5.74 99.08
December-14 357.14 5.92 98.34
January-15 251.38 6.89 97.26
February-15 249.79 7.05 97.18
March-15 271.74 4.72 gg 26
April-15 289.34 4.06 98.60
May-15 305.77 1.93 99.37
June-15 334.00 1.37 99.59
July-15 345.30 1.44 99.58
August-15 317.00 1.66 99.48 Summary Statistics
September-15 314.24 1.91 99.39 average 98.67
October-15 285.16 4.89 98.29 max 99.69
November-15 211.64 5.76 97.28 min 96.68
December-15 322.50 3.59 98.89
January-16 298.66 5.21 98.25
February-16 300.38 5.26 98.25
March-16 491.57 5.37 98.91
April-16 533.50 6.58 98.77
May-16 470.57 6.27 gg 67
June-16 642.23 2.02 gg 69
July-16 411.40 1.54 99.63
August-16 471.23 1.58 99.66
September-16 390.62 2.13 99.45
October-16 329.32 4.52 98.63
November-16 341.93 4.83 98.59
December-16 339.75 6.67 98.04
January-17 309.07 10.25 96.68
February-17 358.14 6.35 98.23
March-17 307.48 10.02 96.74
April-17 282.10 7.83 97.22
May-17 309.40 6.05 98.05
June-17 301.33 3.27 gg 91
July-17 333.07 2.38 99.29
August-17 324.97 2.22 99.32
September-17 661.86 2.20 99.67
October-17 423.03 1.98 99.53
November-17 378.50 6.07 98.40
December-17 343.32
January-18
February-18

Asheboro WWTP (NC0026123)
Summary Statistics
Instream DO Upstream (U)
64870000(U) B4890000(D1) B4920000(D2) — ,Standard Average 8.83
14
Min 5.99
13 Max 12.70
12 • Dnstream (D1)
11 • Average 9.03
10
c� g •• • Min 6.50
E 8 Max 12.30
7 • •
6
Dnstream (D2)
5 Average 8.54
4 Min 5.39
1� 1� 111 1� 1� 1h Lh 1� y� 1� 1�O 'yro N", Max 12.10
sac PQc �J\ O� Nac PQc S°\ 0& Sac pL`
Asheboro WWTP (NC0026123)
Instream Temperature
Summary Statistics
—B4870000(U) B4890000(D1) B4920000(D2) Standard U-Dl Difference
35 Average 1.37
30 Min -4.20
25 �. VIV
Max 7.60
20 # > 2.8°C 8.00
15 U-D2 Difference
10 ••• /� Average 1.75
5
Min -2.60
0
Max 4.90
3 3 � 1 'y ;1 l a 'L a a �, �, �, c, #> 2.8°C 10
'L ;y 'y 1 1 ,1 1 1 'ti ,1 'b 1
sac pQ� lJ� p;` lac 0Q �� p;`
Asheboro WWTP (NC0026123)
Summary Statistics
Instream Conductivity Upstream (U)
B4870000(U) B4890000(D1) B4920000(D2) Average 114
lsoo
Min 51
1600 Max 176
1400 Dnstream (D1)
1200 Average 726
1000 Min 175
E 800 • • • •
• • ••
Max 1525
600
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DIVISION OF WATER QUALITY
April 22, 2002
To: Dave Goodrich, Supervisor
NPDES Unit
From: Susan A. Wilson, Environmental Engineer
NPDES Unit
Subject: Guidance Regarding Conductivity and Fecal Coliform Monitoring
INSTREAM CONDUCTIVITY AND FECAL COLIFORM MONITORING
GUIDANCE
Fecal coliform monitoring:
Instream monitoring for fecal coliform may be removed from municipal or domestic
wastewater permits (major or minor), unless the water body is impaired due to coliform
or is a Class B waterbody.
Conductivity monitoring:
Instream monitoring for conductivity may be removed from all 100% domestic
wastewater permits.
Instream conductivity monitoring must remain for industrial discharges and domestic
discharges that have a pretreatment program.
S:\SWP-Point Source\NPDES\Policies-NPDES pennits\fecal and conductivity monitoring.doc

Asheboro WWTP Stream Impairment Analysis-Copper Loading NCO026123
Stream Impairment Analysis_Loading of Copper
Asheboro W(Metal(mg/L))*(Average Monthly Flow(MGD))•8.34
Date Ibs/day Asheboro WWTP(NC0026123)-Copper Loading
1/1/2008 0.280962 0.6
2/1/2008 0.422838
3/1/2008 0.334693 0.5 00
4/1/2008 0.370026 • • , y=-R' 0.4 3.6591
R'=0.485
5/1/2008 0.465609 ji 0.4 • • • • S • •
6/1/2008 0.381747 • • • • •
7/1/2008 0.343704 v 0.3 •• •
8/1/2008 0.421656 • t ••• • • • •
9/1/2008 0.343747 oz • • • • �v
10/1/2008 0,347726 0 •_• . M •wA
11/1/2008 0.384829 0.1 • • •�` • •
12/1/2008 0,417656 i • • •
1/1/2009 0.350148 0
2/1/2009 0.347438
3/1/2009 0.382456 oi` F° °� °' a�` p°� off` �t'� 41 Few
4/1/2009 0.238171
5/1/2009 0.270553
6/1/2009 0.364765 SUMMARY OUTPUT
7/1/2009 0,34004
8/1/2009 0.312376 Regression Statistics
9/1/2009 0.329874 Multiple R 0.696443
10/1/2009 0.292935 R Square 0.485033
11/1/2009 0.513184 Adjusted R Square 0.480393
12/1/2009 0.393837 Standard Error 0.085818
1/1/2010 0.511838 Observations 113
2/1/2010 0.453534
3/1/2010 0.267241 ANOVA
4/1/2010 0.225457 d/ SS MS F Sig.F
5/1/2010 0.241303 Regression 1 0.769965 0.769965 104.5476642 1.08441E-17
6/1/2010 0,384227 Residual 111 0.817485 0.007365
7/1/2030 0.350973 Total 112 1.58745
8/1/2010 0.355897
9/1/2010 0.308855 Coeff. Std Error t5tot P-Value Lower95% Upper95% Lower95.0% Upper95.0%
30/1/2010 0.217312 Intercept 3.659062 0.334727 10.93149 2.54038E-19 2.995778593 4.322345 2.995779 4.322345
11/1/2010 0.243844 Date -8.31E-05 8.13E-06 -10.22486 1.08441E-17 -9.92565E-05 -6.7E-05 -9.93E-05 -6.7E-05
12/1/2010 0.243935
1/1/2011 0.443038
2/1/2011 0.454056
3/1/2011 0.359743
4/1/2011 0.208424
5/1/2011 0.255516
6/1/2011 0,331518
7/1/2011 0.363712
8/1/2011 0.244871
9/1/2011 0.224974
10/1/2011 0.251417
11/1/2011 0.279935
12/1/2011 0.389994
1/1/2012 0.373326
2/1/2012 0.30992
3/1/2012 0.313798
4/1/2012 0.310404
5/1/2012 0,263889
6/1/2012 0.089338
7/1/2012 0.061608
8/1/2012 0.160065
9/1/2012 0.128875
10/1/2012 0.128774
11/1/2012 0.069486
12/1/2012 0.16747
1/1/2013 0.233361
2/1/2013 0.218829
3/1/2013 0.086559

Asheboro W WTP Stream Impairment Analysis-Copper Loading NCO026123
4/1/2013 0.123756
5/1/2013 0.187932
6/1/2013 0.147835
7/1/2013 0.201933
8/1/2013 0,382838
9/1/2013 0.098034
10/1/2013 0.045751
11/1/2013 0.072582
12/1/2013 0.159494
1/1/2014 0.170238
2/1/2014 0.154681
3/1/2014 0.166178
4/1/2014 0.118978
5/1/2014 0.094831
6/1/2014 0.077775
7/1/2014 0.074932
8/1/2014 0.106265
9/1/2014 0,076372
10/1/2014 0.047492
11/1/2014 0.104604
12/1/2014 0.398585
1/1/2015 0.119319
2/1/2015 0.124265
3/1/2015 0.116243
4/1/2015 0.237268
5/1/2015 0.086641
6/1/2015 0.076642
7/1/2015 0.073262
8/1/2015 0.071935
9/1/2015 0.128704
10/1/2015 0.216012
11/1/2015 0.198129
12/1/2015 0.267959
1/1/2016 0.208727
2/1/2016 0.200008
3/1/2016 0.200499
4/1/2016 0.215037
5/1/2016 0.251682
6/1/2016 0.105692
7/1/2016 0.140616
8/1/2016 0.163066
9/1/2016 0.152323
10/1/2016 0.121075
11/1/2016 0.149333
12/1/2016 0.154724
1/1/2017 0.291416
2/1/2017 0.147792
3/1/2017 0.165248
4/1/2017 0.149029
5/1/2017 0.119455

' Final 2016 Category 5 Assessments -303(d) List
Env&vnmwtW Deep River Subbasin Cape Fear River Basin
Assessment Unit Name Assessment Unit Description
Assessment Unit Number Water QualityClassification
Length/Area Units
Cotton Creek From Otts Lake to SR 1369
17-26-5-3b2 WS-III
0.5 FW Miles
Assessment Criteria Status Reaso�for ating Parameter of Interest
IR Category
Exceeding Criteria >10% conf Copper(7 µg/I,AL, FW)
5
Cotton Creek From SR 1369 to SR1371
17-26-5-3b3 WS-III
1.4 FW Miles
[Assessment Criteria Status Reason for Rating Parameter of InterestIR Category
eeding Criteria > 10%and>90 conf Copper(7 µg/I, AL, FW)
5
Cotton Creek From SR 1371 to Cabin Creek
17-26-5-3c WS-III
3.7 FW Miles
[Assessment Criteria Status ReasonforRating Parameter of InterestIR Category
ceeding Criteria > 10%and>90 conf Copper 7
( µg/I,AL, FW) 5
DEEP RIVER From dam at Randleman Reservoir to US 220 Business
17-(10.5)a
1.6 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest
IR Category
Exceeding Criteria Fair Benthos(Nar,AL, FW)
5
DEEP RIVER From Haskett Creek to Gabriels Creek
17-(10.5)d1
2.7 FW Miles
Assellnconclus=iveNot
nt Criason for Rating Parameter of Interest
IR Category
Data assessed 40 a Chlorophyll
( µg/I,AL, NC) 5
DEEP RIVER From Gabriels Creek to Brush Creek
17-(10.5)d2
18.2 FW Miles
Assessm=Criteria <
for Rating Parameter of Interest
IR Category
Exceed Copper(7 µg/l,AL, FW) 5e
3/23/2018 Final 2016 NC Category 5 Assessments
Page 13 of 196

Asheboro WWTP (NC0026123) Summary Statistics
Instream Inorganic Nitrogen Upstream (U)
Average 0.
ve 17
B4870000(U) B4890000(D1) B4920000(D2) AveMin 0.02
17
25.0 Max 0.37
Dnstream (D1)
20.0
� Average 6.95
15.0 Min 0.69
o - Max 23.00
? 10.0 •
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Z 5.0 • •• i • • Average 0.63
• • __ ��• •/� - = Min 0.12
0.0
tih tih ti� ti� ti� Max 1.85
�P ,b 'o
Asheboro WWTP (NC0026123)
Instream Total Kjeldahl Nitrogen Summary Statistics
Upstream (U)
Bas70000(u) B4890000(D1) B4920000(D2) Average 0.53
Min 0.20
2.5
Max 1.11
2.0 Dnstream (D1)
• •• Average 1.27
�15 1.5 •
•• Min 0.79
Y 1.0 _ AA •• • �
Max 2.30
•
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0.5
Average 0.69
0.0 Min 0.20
3 3 3 o ,,a a a h h
1 Max 1.20
lac �, ,.QQ�'y 'J\,O� ,a ti PQ�1 ,J�'ti O`'y
Asheboro WWTP (NC0026123) Summary Statistics
Instream Total Nitrogen Upstream (U)
B4870000(U) B4890000(D1) B4920000(D2) Average 0.70
Min 0.23
30.0 Max 1.39
25.0 Dnstream (Di)
20.0 Average 8.22
Min 1.63
E 15.0 Max 24.80
z 10.0 Dnstream (D2)
5.0 �••• •• � ® Average 1.32
Min 0.37
0.0
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Asheboro WWTP (NCOO26123) Summary Statistics
Instream Total Phosphorus Upstream (U)
64870000(U) 84890000(D1) 64920000(D2)
Mean 0.06
Min 0.02
1.4 Max 0.29
1.2 Dnstream (D1)
1.0 Mean 0.29
J
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0.5 Max 1.20
~ 0.4 W Dnstream (D2)
0.2 Mean 0.10
0.0 `�
Min 0.04
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PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
Water Resources S. JAY ZIMMERMAN
ENVIRONMENTAL QUALITY Director
March 13,2017
Mr.John N. Ogburn, City Manager
City of Asheboro
P.O. Box 1106
Asheboro,NC 27204 RECEIVE^IN'MEQIDWR
SUBJECT: Compliance Evaluation Inspection(CEI) MAR 21 2017
City of Asheboro Wastewater Treatment Plant Watet Quality
NPDES Permit#N00026123 F'ermitiir�yS ction
Randolph County
Dear Mr. Ogburn:
A Compliance Evaluation Inspection was performed on the subject facility by April Norton of the Winston-
Salem Regional Office on March 9, 2017 at 10:00 am. Mr. Michael Wiseman, Operator in Responsible
Charge(ORC),was present for the inspection.The inspection is comprised of an overall evaluation in order
to document compliance and noncompliance of facilities equipment,capability to meet effluent limits,and
terms&conditions with the National Pollutant Discharge Elimination System(NPDES)permit.
Permit
The NPDES permit became effective August 1,2012 and expired September 30,2016. Per NPDES Permit
NC0026123, Section B, General Conditions:
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information,forms,
andfees as are required by the agency authorized to issue permits no later than 180 days prior to expiration
date unless permission for a later date has been granted by the Director.
Records&Reports
All process controls,site observations, and maintenance records are maintained on site.
All records are kept for 3 years and sludge for 5 years.All laboratory records are kept for 5 years.
Facility Site Review
The facility consists of 9.0 million gallons per day (MGD) wastewater treatment plant containing the
following components: six rectangular primary clarifiers, three trickling filters, four secondary clarifiers,
two aeration basins,tertiary sand filter, and three final clarifiers.
The wastewater in the aeration basins appeared to be a nice, healthy brown color. The wastewater at the
clarifiers appeared to be clear, some floating solids(grease)were present.
Eftluent/Receivine Waters
The effluent to Haskett Creek, flows into the Cape Fear River Basin, Class C waterbody, appeared clear
with no visible foam or sheen.
Flow Measurement
The NPDES permit requires continuous flow recording and an annual calibration. The flow measuring
State of North Carolina I Environmental Quality I Water Resources
450 West Hanes Mill Road,Suite 300,Winston-Salem,NC 27105
Phone:[phone] intemet:www.ncdenr.gov

device was last calibrated January 26, 2017 by Instrumentation Services, Inc. The next calibration is due
April 30, 2017
Self-Monitoring Program
There were not any permit limit violations within the last 12 months.
Laboratory data verification was performed on June 2016 Discharge Monitoring Report (DMR). There
were no errors noted.
Laboratory
The City of Asheboro has an on-site laboratory for most services. Additional laboratory services are
conducted by Meritech.
Operations& Maintenance
There did not appear to be any operation and maintenance issues at the time of the inspection.
Sludge Handling/Disposal
Solids from the anaerobic digester are dewatered by the on-site belt press prior to land application covered
under WQ0001684.
Compliance Status
The compliance evaluation inspection is satisfactory. Mr. Wiseman and his staff operate the facility in an
excellent manner.
Should you have any questions concerning this report, please contact April Norton or me at (336) 776-
9800.
Sincerely,
Fcr%
/Sherri V Knight, PE, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
cc: Michael Wiseman(e-copy)
Central Files
WSRO Files

United States Environmental Protection Agency
EPA Form Approved.
Washington,D.C.2t)460
Water Compliance Inspection Report OMB No.2040-0057Approval expires 8-31-98
Section A:National Data System Coding(i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type
� YP Inspector Fac Type
1
2 IJ 3 I NC0026123 I11 12 17/03/13 17 18�,.I 19 1 G ) 20I J
211I11 I I I I I I I II I L I I I r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1
67 CIA -----------Reserved-----------
70 71 yD I„ t 72 I „u t 73 L I I74 75H 80
LJ Section B:Facility Data
I I
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)
Asheboro WWTP 10:00AM 17/03/13 12/08/01
1032 Bonkemeyer Or Exit Time/Date Permit Expiration Date
Asheboro NC 27203 11:30AM 17/03/13 16/09/30
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Michael Ray Wiseman/ORC/336-672-0892/
Name,Address of Responsible Official/Title/Phone and Fax Number
John N Ogburn,PO Box 1106 Asheboro NC 272041106/City Contacted
Manager/336-626-1213/3366261218 No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
Permit 0 Flow Measurement N Operations&Maintenance N Records/Reports
Self-Monitoring Program 0 Facility Site Review 0 Effluent/Receiving Waters
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
April Norton I WSRO WQ//336-776-9800/
rgn:t reof Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type 1
31 NCO026123 I11 12 17/03/13 17 18 ICI
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Page# 2

Permit: NCO026123 Owner-Facility: Asheboro WWTP
Inspection Date: 03/13/2017 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new 0 11 El ❑
application?
Is the facility as described in the permit? ■ ❑
El 0
#Are there any special conditions for the permit? ■
Is access to the plant site restricted to the general public? M El M El
Is the inspector granted access to all areas for inspection? ■ El 7 ❑
Comment:
Effluent Samplinq Yes No NA NE
Is composite sampling flow proportional? ■
Is sample collected below all treatment units? El 1:1■ ❑
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 D El
representative)?
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years(lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete? ■ ❑
11 El
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?
Page# 3

Permit: NCO026123 Owner-Facility: Asheboro WWTP
Inspection Date: 03/13/2017 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator N ❑ ❑ ❑
on each shift?
Is the ORC visitation log available and current? 0 ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? N ❑ ❑ ❑
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? M ❑ ❑ ❑
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? N ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO. Sludge Judge, and other that are applicable?
Comment:
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting? 0 ❑ ❑ ❑
Is flow meter calibrated annually? 0 ❑ ❑ ❑
Is the flow meter operational? N ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ 0
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris? N ❑ ❑ ❑
Is the screen free of excessive debris? M ❑ ❑ ❑
Is disposal of screening in compliance? ❑ ❑ 0 ❑
Is the unit in good condition? ❑ ❑ ❑
Comment:
Grit Removal Yes No NA NE
Type of grit removal
Page# 4

Permit: NC0026123 P
Owner-Facility.. Asheboro WWr
Inspection Date: 03/13/2017
Inspection Type: Compliance Evaluation
Grit Removal
a.Manual Yes No NA NE
b.Mechanical ❑
Is the grit free of excessive organic matter? •
Is the grit free of excessive odor? ❑ El ❑
#Is disposal of grit in compliance? El El El
Comment:
Primary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑ ❑ 0 ❑
Are weirs level?
Is the site free of weir blockage? El ❑ El
Is the site free of evidence of short-circuiting? 1:1 El El
Is scum removal adequate? El ❑ ❑
Is the site free of excessive Floating sludge?
Is the drive unit operational?
Is the sludge blanket level acceptable?
Is the sludge blanket level acceptable?(Approximately Y.of the sidewall depth)
El El El 0
❑ ❑ ❑
Comment:
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
El El El
Are weirs level? ❑ ❑ ❑
❑Is the site free of weir blockage? ❑ ❑
Is the site free of evidence of short-circuiting? El 1:1
Is scum removal adequate? ❑ ❑ ❑
Is the site free of excessive floating sludge?
Is the drive unit operational? El ❑ ❑
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable?(Approximately'/,of the sidewall depth)
■ ❑ ❑ ❑
Comment:
Page# 5

Permit: NCO026123 Owner-Facility: Asheboro WWTP
Inspection Date: 03/13/2017 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? E ❑ ❑ ❑
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? E ❑ ❑ ❑
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? ❑ ❑ 0 ❑
Are the diffusers operational? N ❑ ❑ ❑
Is the foam the proper color for the treatment process? E ❑ ❑ ❑
Does the foam cover less than 25%of the basin's surface? 0 ❑ ❑ ❑
Is the DO level acceptable? N ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/1) 0 ❑ ❑ ❑
Comment:
De-chlorination Yes No NA NE
Type of system ? Liquid
Is the feed ratio proportional to chlorine amount(1 to 1)? ❑ 0 ❑ ❑
Is storage appropriate for cylinders? ❑ ❑ N ❑
#Is de-chlorination substance stored away from chlorine containers? ❑ ❑ E ❑
Comment: 10:1 chlorine to de-chlor
Are the tablets the proper size and type? ❑ ❑ N ❑
Are tablet de-chlorinators operational? ❑ ❑ 0 ❑
Number of tubes in use? 0
Comment: no comment
Page# 6

Permit: NC0026123
Owner-Facility: Asheboro WWTP
Inspection Date: 0 311 3/2 01 7
Inspection Type: compliance Evaluation
Disinfection-Liquid Yes No NA NE
Is there adequate reserve supply of disinfectant? M ❑ ❑ ❑
(Sodium Hypochlorite)Is pump feed system operational? M ❑ ❑ ❑
Is bulk storage tank containment area adequate?(free of leaks/open drains) 0 ❑ ❑ ❑
Is the level of chlorine residual acceptable? ❑ ❑ ❑ M
Is the contact chamber free of growth, or sludge buildup? M ❑ El ❑
Is there chlorine residual prior to de-chlorination? ❑ El 0
Comment:
Page# 7

IWC Calculations
Facility: Asheboro WWTP
NC0026123
Prepared By: Jennifer Busam
Enter Design Flow (MGD): 9
Enter s7Q10 (cfs): 0
Enter w7Q10 (cfs): 0
Total Residual Chlorine (TRC) Ammonia (Summer)
Daily Maximum Limit(ug/1) 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
W,4
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform w7Q10 (CFS) 0
Monthly Average Limit: 200/100m1 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
�/4 =
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); 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)
NPDES Server/Current Versions/WLA; TB 1/16/2009

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REASONABLE POTENTIAL ANALYSIS
Hi
"PASTE SPECIAL H2 L
TE SPECIAL
Effluent Hardness lues"then"COPY Upstream Hardness hen"COPY.Maximum data um datapoints=58 ts-58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 10/7/2016 120 120 Std Dev. 21.2350 1 8/29/2016 106 106 Std Dev. 21.5387
2 10/13/2016 98 98 Mean 114.2614 2 9/13/2016 40 40 Mean 51.9333
3 10/19/2016 135 135 C.V. 0,1858 3 10/19/2016 49 49 C.V. 0.4147
4 10/25/2016 118 118 n 57 4 11/2/2016 69 69 n 12
5 11/2/2016 128 128 10th Per value 90.00 mg/L 5 12/6/2016 28 28 10th Per value 34.50 mg/L
6 11/10/2016 110 110 Average Value 114.26 mg/L 6 1/11/2017 73 73 Average Value 51.93 mg/L
7 11/18/2016 145 145 Max.Value 166.00 mg/L 7 2/2/2017 39 39 Max.Value 106.00 mg/L
8 11/21/2016 141 141 8 3/7/2017 49 49
9 11/30/2016 120 120 9 4/11/2017 53 53
10 12/6/2016 88 88 10 5/10/2017 34 34
11 12/14/2016 108 108 11 6/8/2017 43.7 43.7
12 12/19/2016 112 112 12 7/12/2017 39.5 39.5
13 12/29/2016 144 144 13
14 1/5/2017 102 102 14
15 1/11/2017 110 110 15
16 1/17/2017 96 96 16
17 1/23/2017 90 90 17
18 2/2/2017 78 78 18
19 2/10/2017 108 108 19
20 2/15/2017 86 86 20
21 2/21/2017 90 90 21
22 3/7/2017 97.9 97.9 22
23 3/15/2017 100 100 23
24 3/23/2017 116 116 24
25 3/29/2017 110 110 25
26 4/3/2017 93.8 93.8 26
27 4/11/2017 89.8 89.8 27
28 4/19/2017 106 106 28
29 4/27/2017 95.9 95.9 29
30 5/2/2017 110 110 30
31 5/10/2017 129 129 31
32 5/18/2017 153 153 32
33 5/26/2017 104 104 33
34 5/31/2017 144 144 34
35 6/8/2017 99.8 99.8 35
36 6/15/2017 108 108 36
37 6/22/2017 81.1 81.1 37
38 6/30/2017 93.6 93.6 38
39 7/6/2017 104 104 39
40 7/12/2017 108 108 40
41 9/7/2017 112 112 41
42 9/13/2017 94 94 42
43 9/19/2017 110 110 43
44 9/28/2017 104 104 44
45 10/3/2017 104 104 45
46 10/11/2017 98 98 46
47 10/19/2017 114 114 47
48 10/27/2017 100 100 48
49 11/2/2017 131 131 49
50 11/8/2017 148 148 50
51 11/14/2017 133 133 51
52 11/20/2017 154 154 52
53 11/30/2017 166 166 53
54 12/5/2017 149 149 54
55 12/13/2017 141 141 55
56 12/21/2017 141 141 56
57 12/28/2017 143 143 57
58 58
NCO026123 RPA_2018a,data
1- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Per01&Per02 Uw"PASTE SPECIAL Par03 Lu
E SPECIAL
Arsenic Values"then"copy Beryllium en"COPY"
.Maximum data m data
points=SB s-58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 5/20/2014 < 5 2.5 Std Dev. .6546 1 12/12/2013 < 1 0.5 Sid Dev. 0.0000
2 6/1912014 < 5 2.5 Mean 2.1182 2 6/19/2014 < 1 0.5 Mean 0.5000
3 7/15/2014 < 5 2.5 C.V. 0,3090 3 3/17/2016 < 1 0.5 C.V.(default) 0.6000
4 8/20/2014 < 5 2.5 n 44 4 n 3
5 9/9/2014 < 5 2.5 5
6 10/14/2014 < 5 2.5 Mult Factor= 1.04 6 Mult Factor= 3.00
7 11/4/2014 < 5 2.5 Max.Value 2.5 ug/L 7 Max.Value 0.50 ug/L
8 12/4/2014 < 5 2.5 Max.Fred Cw 2.6 ug/L 8 Max.Fred Cw 1.50 ug/L
9 1/14/2015 < 5 2.5 9
10 2/3/2015 < 5 2.5 10
11 3/10/2015 < 5 2.5 11
12 4/7/2015 < 5 2.5 12
13 5/13/2015 < 5 2.5 13
14 6/2/2015 < 5 2.5 14
15 7/7/2015 < 5 2.5 15
16 8/13/2015 < 5 2.5 16
17 9/15/2015 < 5 2.5 17
18 10/21/2015 < 5 2.5 18
19 11/17/2015 < 5 2.5 19
20 12/8/2015 < 5 2.5 20
21 1/13/2016 < 5 2.5 21
22 2/16/2016 < 5 2.5 22
23 3/17/2016 < 5 2.5 23
24 4/14/2016 < 5 2.5 24
25 5/6/2016 < 5 2.5 25
26 6/14/2016 < 5 2.5 26
27 7/14/2016 < 5 2.5 27
28 8/17/2016 < 5 2.5 28
29 9/13/2016 < 5 2.5 29
30 10/19/2016 < 5 2.5 30
31 11/2/2016 < 5 2.5 31
32 12/6/2016 < 5 2.5 32
33 1/11/2017 < 2 1 33
34 2/2/2017 < 2 1 34
35 3/7/2017 < 2 1 35
36 4/11/2017 < 2 1 36
37 5/10/2017 < 2 1 37
38 6/8/2017 < 2 1 38
39 7/12/2017 < 2 1 39
40 8/17/2017 < 2 1 40
41 9/19/2017 < 2 1 41
42 10/11/2017 2.2 2.2 42
43 11/8/2017 < 2 1 43
44 12/5/2017 < 2 1 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
NCO026123 RPA_2018a,data
-2- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par04 Par05
Use"PASTE SPECIAL Use"PASTE SPECIAL
Cadmium Values"then"COPY Chlorides Values"then"COPY"
.I.taximum data Maximum data points=
points=SE 58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 5/20/2014 < 0.5 0.25 Std Dev. 0.0892 y 1 3/4/2014 138 138 Std Dev. 60.6764
2 6/19/2014 < 0.5 0.25 Mean 0.2739 2 4/15/2014 114 114 Mean 166.0
3 7/15/2014 < 0.5 0.25 C.V. 0.3259 3 6/19/2014 230 230 C.V. 0.3656
4 8/20/2014 < 0.5 0.25 n 44 4 9/9/2014 150 150 n 25
5 9/9/2014 < 0.5 0.25 5 12/4/2014 300 300
6 10/14/2014 < 0.5 0.25 Mull Factor= 1.04 6 3/10/2015 68 68 Muit Factor= 1.2
7 11/4/2014 < 0.5 0.25 Max.Value 0.600 ug/L 7 6/2/2015 150 150 Max.Value 300.0 mg/L
8 12/4/2014 < 0.5 0.25 Max.Fred Cw 0.624 ug/L 8 9/15/2015 241 241 Max.Pred Cw 351.0 mg/L
9 1/14/2015 < 0.5 0.25 9 12/8/2015 130 130
10 2/3/2015 < 0.5 0.25 10 1/13/2016 135 135
11 3/10/2015 < 0.5 0.25 11 2/16/2016 122 122
12 4/7/2015 < 0.5 0.25 12 3/17/2016 185 185
13 5/13/2015 < 0.5 0.25 13 4/14/2016 220 220
14 6/2/2015 < 0.5 0.25 14 5/6/2016 186 186
15 7/7/2015 < 0.5 0.25 15 6/14/2016 169 169
16 8/13/2015 < 0.5 0.25 16 7/14/2016 240 240
17 9/15/2015 < 0.5 0.25 17 8/17/2016 178 178
18 10/21/2015 < 0.5 0.25 18 9/13/2016 160 160
19 11/17/2015 < 0.5 0.25 19 10/19/2016 100 100
20 12/8/2015 < 0.5 0.25 20 11/2/2016 180 180
21 1/13/2016 < 0.5 0.25 21 12/6/2016 117 117
22 2/16/2016 < 0.5 0.25 22 3/7/2017 77 77
23 3/17/2016 < 0.5 0.25 23 6/8/2017 128 128
24 4/14/2016 < 0.5 0.25 24 9/19/2017 137 137
25 5/6/2016 < 0.5 0.25 25 12/5/2017 294 294
26 6/14/2016 < 0.5 0.25 26
27 7/14/2016 < 0.5 0.25 27
28 8/17/2016 < 0.5 0.25 28
29 9/13/2016 < 0.5 0.25 29
30 10/19/2016 < 0.5 0.25 30
31 11/2/2016 < 0.5 0.25 31
32 12/6/2016 < 0.5 0.25 32
33 1111/2017 < 0.5 0.25 33
34 2/2/2017 < 0.5 0.25 34
35 3/7/2017 < 0.5 0.25 35
36 4/11/2017 < 0.5 0.25 36
37 5/10/2017 < 0.5 0.25 37
38 6/8/2017 0.6 0.6 38
39 7/12/2017 0.6 0.6 39
40 8/17/2017 < 0.5 0.25 40
41 9/19/2017 0.6 0.6 41
42 10/11/2017 < 0.5 0.25 42
43 11/8/2017 < 0.5 0.25 43
44 12/5/2017 < 0.5 0.25 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
NCO026123 RPA_2018a.data
-3- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par06 Par07
Use"PASTE SPECIAL Use"PASTE SPECIAL
Chlorinated Phenolic Compounds Values"then"COPY• Total Phenolic Compounds Values"then"COPY"
.Maximum data .Maximum data
points=53 points=5E
Date Data BDL=112DL Results Date Data BDL=1/2DL Results
1 Std Dev. NO DATA 1 12/12/2013 < 5 2.5 Std Dev. 0.0000
2 Mean NO DATA 2 6/19/2014 < 5 2.5 Mean 2.5000
3 C.V. NO DATA 3 3/17/2016 < 5 2.5 C.V.(default) 0.6000
4 n 0 4 n 3
5 5
6 Mult Factor= N/A 6 Mult Factor= 3.00
7 Max.Value N/A ug/L 7 Max.Value 2.5 ug/L
8 Max.Pred Cw N/A ug/L 8 Max.Fred Cw 7.5 ug/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
NCO026123 RPA_2018a,data
4- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
ParOB Paf09 Uss"PASTE SPECIAL
Use"PASTE SPECIAL
Chromium III Values"men"COPY Chromium VI Values"then"COPY"
Maximum data Maximum data
points=58 points-58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 Std Dev. NO DATA 1 Std Dev. NO DATA
2 Mean NO DATA 2 Mean NO DATA
3 C.V. NO DATA 3 C.V. NO DATA
4 n 0 4 n 0
5 5
6 Mult Factor= N/A 6 Mult Factor= N/A
7 Max.Value N/A pg/L 7 Max.Value N/A pg/L
8 Max.Pred Cw N/A pg/L 8 Max.Fred Cw N/A pg/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
NCO026123 RPA_2018a,data
-5- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par10 Pall
Use"PASTE SPECiAll
"PASTE SPE
Chromium,Total Values"then"C Copper lues"then"COP
Maximum data .Maximum data
points=58 points a 58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 5/20/2014 < 5 2.5 Std Dev. 4.3051 1 5/20/2014 3 3 Std Dev. 2.1845
2 6/19/2014 8 8 Mean 5.1705 2 6/19/2014 3 3 Mean 4.7791
3 7/15/2014 7 7 C.V. 0.8326 3 7/15/2014 3 3 C.V. 0.4571
4 8/20/2014 10 10 n 44 4 8/20/2014 4 4 n 43
5 9/9/2014 6 6 5 9/9/2014 3 3
6 10/14/2014 < 5 2.5 Mult Factor= 1.10 6 10/14/2014 2 2 Mult Factor= 1.07
7 11/4/2014 12 12 Max.Value 26.0 pg/L 7 11/4/2014 4 4 Max.Value 15.00 ug/L
8 12/4/2014 26 26 Max.Fred Cw 28.6 Ng/L 8 12/4/2014 15 15 Max.Pred Cw 16.05 ug/L
9 1/14/2015 8 8 9 1/14/2015 4 4
10 2/3/2015 7 7 10 2/3/2015 4 4
11 3/10/2015 < 5 2.5 11 3/10/2015 3 3
12 4/7/2015 < 5 2.5 12 4/7/2015 6 6
13 5/13/2015 < 5 2.5 13 5/13/2015 3 3
14 6/2/2015 < 5 2.5 14 6/2/2015 3 3
15 7/7/2015 < 5 2.5 15 7/7/2015 3 3
16 8/13/2015 9 9 16 8/13/2015 3 3
17 9/15/2015 7 7 17 9/15/2015 5 5
18 10/21/2015 7 7 18 10/21/2015 7 7
19 11/17/2015 6 6 19 11/17/2015 5 5
20 12/8/2015 5 5 20 12/8/2015 6 6
21 1/13/2016 < 5 2.5 21 1/13/2016 6 6
22 2/16/2016 < 5 2.5 22 2116/2016 5 5
23 3/17/2016 6 6 23 3/17/2016 6 6
24 4/14/2016 8 8 24 4/14/2016 7 7
25 5/6/2016 11 11 25 5/6/2016 7 7
26 6/14/2016 < 5 2.5 26 6/14/2016 4 4
27 7/14/2016 10 10 27 7/14/2016 6 6
28 8/17/2016 7 7 28 8/17/2016 6 6
29 9/13/2016 5 5 29 9/13/2016 5 5
30 10/19/2016 < 5 2.5 30 10/19/2016 4 4
31 11/2/2016 < 5 2.5 31 11/2/2016 6 6
32 12/6/2016 < 5 2.5 32 12/6/2016 6 6
33 1/11/2017 < 5 2.5 33 1/11/2017 8 8
34 2/2/2017 < 5 2.5 34 2/2/2017 5.4 5.4
35 3/7/2017 < 5 2.5 35 3/7/2017 6 6
36 4/11/2017 < 5 2.5 36 4/11/2017 4.2 4.2
37 5/10/2017 < 5 2.5 37 5/10/2017 3.6 3.6
38 6/8/2017 < 5 2.5 38 6/8/2017 2.8 2.8
39 7/12/2017 < 5 2.5 39 7/12/2017 2.1 2.1
40 8/17/2017 < 5 2.5 40 8/17/2017 3 3
41 9/19/2017 < 5 2.5 41 9/19/2017 3.8 3.8
42 10/11/2017 < 5 2.5 42 10/11/2017 4.8 4.8
43 11/8/2017 < 5 2.5 43 12/5/2017 4.8 4.8
44 12/5/2017 < 5 2.5 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
NC0026123 RPA_2018a,data
-6- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par12 Uso"PASTE SPEC Par13 L-PASTESPECIAL
Cyanide values"then"COP FIUOrld@ COP.Maximum data data
points=58 58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 6/19/2014 < 10 5 Std Dev. 3.5305 1 Std Dev. NO DATA
2 9/9/2014 < 10 5 Mean 6.19 2 Mean NO DATA
3 12/4/2014 < 10 5 C.V. 0.5708 3 C.V. NO DATA
4 3/10/2015 < 10 5 n 27 4 n 0
5 6/2/2015 < 10 5 5
6 9/15/2015 18 18 Mult Factor= 1.23 6 Mult Factor= N/A
7 9/18/2015 12 12 Max.Value 18.0 ug/L 7 Max.Value N/A ug/L
8 9/21/2015 17 17 Max.Pred Cw 22.1 ug/L 8 Max.Pred Cw N/A ug/L
9 9/22/2015 < 10 5 9
10 9/23/2015 < 10 5 10
11 12/8/2015 < 10 5 11
12 1/13/2016 < 10 5 12
13 2/11/2016 < 10 5 13
14 3/1412016 < 10 5 14
15 4/14/2016 < 10 5 15
16 5/6/2016 < 10 5 16
17 6/14/2016 < 10 5 17
18 7/14/2016 < 10 5 18
19 8/17/2016 < 10 5 19
20 9/13/2016 < 10 5 20
21 10/19/2016 < 10 5 21
22 11/2/2016 < 10 5 22
23 12/6/2016 < 10 5 23
24 3/7/2017 < 10 5 24
25 6/8/2017 < 10 5 25
26 9/19/2017 < 10 5 26
27 12/5/2017 < 10 5 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
NCO026123 RPA_2018a,data
-7- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Pdi14 Par15
Use"PASTE SPECIAL Vse"PASTE SPECIAL
Lead Values"then"COPY" Mercuryvalues"then 'COPY"
Maximum data Maximum data
points=58 points=58
Date BDL=1/2DL Results Date Data BDL=1/2DL Results
1 5/20/2014 < 5 2.5 Std Dev. 0.6758 1 Std Dev. NO DATA
2 6/19/2014 < 5 2.5 Mean 2.0909 2 Mean NO DATA
3 7/15/2014 < 5 2.5 C.V. 0.3232 3 C.V. NO DATA
4 8/20/2014 < 5 2.5 n 44 4 n 0
5 9/9/2014 < 5 2.5 5
6 10/14/2014 < 5 2.5 Mult Factor= 1.04 6 Muit Factor= N/A
7 11/4/2014 < 5 2.5 Max.Value 2.500 ug/L 7 Max.Value N/A ng/L
8 12/4/2014 < 5 2.5 Max.Fred Cw 2.600 ug/L 8 Max.Fred Cw N/A ng/L
9 1/14/2015 < 5 2.5 9
10 2/3/2015 < 5 2.5 10
11 3/10/2015 < 5 2.5 11
12 4/7/2015 < 5 2.5 12
13 5/13/2015 < 5 2.5 13
14 6/2/2015 < 5 2.5 14
15 7/7/2015 < 5 2.5 15
16 8/13/2015 < 5 2.5 16
17 9/15/2015 < 5 2.5 17
18 10/21/2015 < 5 2.5 18
19 11/17/2015 < 5 2.5 19
20 12/8/2015 < 5 2.5 20
21 1/13/2016 < 5 2.5 21
22 2/16/2016 < 5 2.5 22
23 3/17/2016 < 5 2.5 23
24 4/14/2016 < 5 2.5 24
25 5/6/2016 < 5 2.5 25
26 6/14/2016 < 5 2.5 26
27 7/14/2016 < 5 2.5 27
28 8/17/2016 < 5 2.5 28
29 9/13/2016 < 5 2.5 29
30 10/19/2016 < 5 2.5 30
31 11/2/2016 < 5 2.5 31
32 12/6/2016 < 5 2.5 32
33 1/11/2017 < 2 1 33
34 2/2/2017 < 2 1 34
35 3/7/2017 < 2 1 35
36 4/11/2017 < 2 1 36
37 5/10/2017 < 2 1 37
38 6/8/2017 < 2 1 38
39 7/12/2017 < 2 1 39
40 8/17/2017 < 2 1 40
41 9/19/2017 < 2 1 41
42 10/11/2017 < 2 1 42
43 11/8/2017 < 2 1 43
44 12/5/2017 < 2 1 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
NCO026123 RPA_2018a,data
-8- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par16 p"PASTE SPECIAL Par17&Par18 Use"PASTE SPECIAL
Molybdenum ues"then"COPv Nickel Values"then"COPY'
.Maximum data Maximum data
points=56 pomts=58
Date Data BDL=1/2DL Results _ Date Data BDL=112DL Results __
1 8/13/2015 < 50 25 Std Dev. 28.3210 1 5/20/2014 < 5 2.5 Std Dev. 0.7143
2 9/15/2015 85 85 Mean 32.5310 2 6/19/2014 < 5 2.5 Mean 2.3773
3 10/21/2015 150 150 C.V. 0.8706 3 7/15/2014 < 5 2.5 C.V. 0,3005
4 11/17/2015 < 50 25 n 29 4 8/20/2014 < 5 2.5 n 44
5 12/8/2015 < 50 25 5 9/9/2014 < 5 2.5
6 1/13/2016 < 50 25 Mult Factor= 1.30 6 10/14/2014 < 5 2.5 Mult Factor= 1.04
7 2/16/2016 < 50 25 Max.Value 150.0 ug/L 7 11/4/2014 < 5 2.5 Max.Value 5.8 Ng/L
8 3/17/2016 < 50 25 Max.Fred Cw 195.0 ug/L 8 12/4/2014 < 5 2.5 Max.Pred Cw 6.0 yg/L
9 4/14/2016 < 50 25 9 1/14/2015 < 5 2.5
10 5/6/2016 < 50 25 10 2/3/2015 < 5 2.5
11 6/14/2016 67 67 11 3/10/2015 < 5 2.5
12 7/14/2016 58 58 12 4/7/2015 < 5 2.5
13 8/17/2016 < 50 25 13 5/13/2015 < 5 2.5
14 9/13/2016 < 50 25 14 612/2015 < 5 2.5
15 10/19/2016 < 50 25 15 7/7/2015 < 5 2.5
16 1112/2016 < 50 25 16 8/13/2015 < 5 2.5
17 12/6/2016 < 50 25 17 9/15/2015 < 5 2.5
18 1/11/2017 18 18 18 10/21/2015 < 5 2.5
19 2/2/2017 13.6 13.6 19 11/17/2015 < 5 2.5
20 3/7/2017 17.4 17.4 20 12/8/2015 < 5 2.5
21 4111/2017 21.8 21.8 21 1/13/2016 < 5 2.5
22 5/10/2017 21.2 21.2 22 2/16/2016 < 5 2.5
23 6/8/2017 11.8 11.8 23 3/17/2016 < 5 2.5
24 7/12/2017 22.1 22.1 24 4/14/2016 < 5 2.5
25 8/17/2017 60.1 60.1 25 5/6/2016 < 5 2.5
26 9/19/2017 13.5 13.5 26 6/14/2016 < 5 2.5
27 10/11/2017 21.8 21.8 27 7/14/2016 < 5 2.5
28 11/8/2017 26.4 26.4 28 8/17/2016 < 5 2.5
29 12/5/2017 10.7 10.7 29 9/13/2016 < 5 2.5
30 30 10/19/2016 < 5 2.5
31 31 11/2/2016 < 5 2.5
32 32 12/6/2016 < 5 2.5
33 33 1/11/2017 < 2 1
34 34 2/2/2017 2 2
35 35 3/7/2017 < 5 2.5
36 36 4/11/2017 < 2 1
37 37 5/10/2017 2.4 2.4
38 38 6/8/2017 < 5 2.5
39 39 7/12/2017 5.8 5.8
40 40 8/17/2017 2.3 2.3
41 41 9/19/2017 < 2 1
42 42 10/11/2017 < 2 1
43 43 11/8/2017 < 2 1
44 44 12/5/2017 2.1 2.1
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
NCO026123 RPA_2018a,data
-9- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par19 Per20
"PASTE SPECULL Use"PASTE SPECIAL
Selenium aues"then"Iopy- Silver Values^then"COPY'
.Maximum data .Maximum data
points=5E points=SE
Date Data BDL=1/2DL Results Date Data BDL=112DL Results
1 5/20/2014 < 10 5 Std Dev. 0.0000 1 5/20/2014 < 5 2.5 Std Dev. 0.0000
2 6/19/2014 < 10 5 Mean 5.0000 2 6/19/2014 < 5 2.5 Mean 2.5000
3 7/15/2014 < 10 5 C.V. 0.0000 3 7/15/2014 < 5 2.5 C.V. 0.0000
4 8/20/2014 < 10 5 n 44 4 8/20/2014 < 5 2.5 n 44
5 9/9/2014 < 10 5 5 9/9/2014 < 5 2.5
6 10/14/2014 < 10 5 Mult Factor= 1.00 6 10/14/2014 < 5 2.5 Mult Factor= 1.00
7 11/4/2014 < 10 5 Max.Value 5.0 ug/L 7 11/4/2014 < 5 2.5 Max.Value 2.500 ug/L
8 12/4/2014 < 10 5 Max.Fred Cw 5.0 ug/L 8 12/4/2014 < 5 2.5 Max.Pred Cw 2.500 ug/L
9 1/14/2015 < 10 5 9 1/14/2015 < 5 2.5
10 2/3/2015 < 10 5 10 2/3/2015 < 5 2.5
11 3/10/2015 < 10 5 11 3/10/2015 < 5 2.5
12 4/7/2015 < 10 5 12 4/7/2015 < 5 2.5
13 5/13/2015 < 10 5 13 5/13/2015 < 5 2.5
14 6l2/2015 < 10 5 14 6/2/2015 < 5 2.5
15 7/7/2015 < 10 5 15 7/7/2015 < 5 2.5
16 8/13/2015 < 10 5 16 8/13/2015 < 5 2.5
17 9/15/2015 < 10 5 17 9/15/2015 < 5 2.5
18 10/21/2015 < 10 5 18 10/21/2015 < 5 2.5
19 11/17/2015 < 10 5 19 11/17/2015 < 5 2.5
20 12/8/2015 < 10 5 20 12/8/2015 < 5 2.5
21 1/13/2016 < 10 5 21 1/13/2016 < 5 2.5
22 2/16/2016 < 10 5 22 2/16/2016 < 5 2.5
23 3/17/2016 < 10 5 23 3/17/2016 < 5 2.5
24 4/14/2016 < 10 5 24 4/14/2016 < 5 2.5
25 5/6/2016 < 10 5 25 5/6/2016 < 5 2.5
26 6/14/2016 < 10 5 26 6/14/2016 < 5 2.5
27 7/14/2016 < 10 5 27 7/14/2016 < 5 2.5
28 8/17/2016 < 10 5 28 8/17/2016 < 5 2.5
29 9/13/2016 < 10 5 29 9/13/2016 < 5 2.5
30 10/19/2016 < 10 5 30 10/19/2016 < 5 2.5
31 11/2/2016 < 10 5 31 11/2/2016 < 5 2.5
32 12/6/2016 < 10 5 32 12/6/2016 < 5 2.5
33 1/11/2017 < 10 5 33 1/11/2017 < 5 2.5
34 2/2/2017 < 10 5 34 2/2/2017 < 5 2.5
35 3/7/2017 < 10 5 35 3/7/2017 < 5 2.5
36 4/11/2017 < 10 5 36 4/11/2017 < 5 2.5
37 5/10/2017 < 10 5 37 5/10/2017 < 5 2.5
38 6/8/2017 < 10 5 38 6/8/2017 < 5 2.5
39 7/12/2017 < 10 5 39 7/12/2017 < 5 2.5
40 8/17/2017 < 10 5 40 8/17/2017 < 5 2.5
41 9/19/2017 < 10 5 41 9/19/2017 < 5 2.5
42 10/11/2017 < 10 5 42 10/11/2017 < 5 2.5
43 11/8/2017 < 10 5 43 11/8/2017 < 5 2.5
44 12/5/2017 < 10 5 44 12/5/2017 < 5 2.5
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
NCO026123 RPA_2018a,data
-10- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par21 Par22
Use"PASTE SPECIAL Athen
Zinc values men copy Dibromochloromethane Values"Maximum data points=5S
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 5/20/2014 23 23 Std Dev. 11.0282 1 6/19/2014 < 5 2.5 Std Dev. 6.1196
2 6/19/2014 22 22 Mean 23.0822 2 9/16/2014 17.3 17.3 Mean 6.8875
3 7/15/2014 52 52 C.V. 0.4778 3 12/4/2014 6.7 6.7 C.V. 0.8885
4 8/20/2014 21 21 n 45 4 3/5/2015 < 5 2.5 n 16
5 9/9/2014 30 30 5 6/4/2015 20.4 20.4
6 10/14/2014 20 20 Mult Factor= 1.06 6 9/17/2015 10.5 10.5 Mull Factor= 1.70
7 11/4/2014 30 30 Max.Value 55.0 ug/L 7 12/10/2015 < 5 2.5 Max.Value 20.400000 pg/L
8 12/4/2014 41 41 Max.Pred Cw 58.3 ug/L 8 3/17/2016 < 5 2.5 Max.Pred Cw 34.680000 Ng/L
9 1/14/2015 17 17 9 3/17/2016 < 5 2.5
10 2/3/2015 17 17 10 6/16/2016 < 5 2.5
11 3/10/2015 23 23 11 9/15/2016 11 11
12 4/7/2015 30 30 12 12/8/2016 < 5 2.5
13 5/13/2015 22 22 13 3/9/2017 < 5 2.5
14 6/2/2015 23 23 14 6/15/2017 < 5 2.5
15 6/4/2015 28 28 15 9/19/2017 6.7 6.7
16 7/7/2015 < 20 10 16 12/5/2017 15.1 15.1
17 8/13/2015 32 32 17
18 9/15/2015 < 20 10 18
19 10/21/2015 27 27 19
20 11/17/2015 20 20 20
21 12/8/2015 < 20 10 21
22 1/13/2016 23 23 22
23 2/16/2016 25 25 23
24 3/17/2016 24 24 24
25 4/14/2016 38 38 25
26 5/6/2016 < 20 10 26
27 6/14/2016 38 38 27
28 7/14/2016 < 20 10 28
29 8/17/2016 < 20 10 29
30 9/13/2016 < 20 10 30
31 10/19/2016 < 20 10 31
32 11/2/2016 < 20 10 32
33 12/6/2016 32 32 33
34 1/11/2017 41 41 34
35 2/2/2017 55 55 35
36 3/7/2017 32.4 32.4 36
37 4/11/2017 20.2 20.2 37
38 5/10/2017 22 22 38
39 6/8/2017 16 16 39
40 7/12/2017 23.3 23.3 40
41 8/17/2017 18.5 18.5 41
42 9/19/2017 13.4 13.4 42
43 10/11/2017 15.3 15.3 43
44 11/8/2017 20.1 20.1 44
45 12/5/2017 13.5 13.5 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
NC0026123 RPA_2018a,data
11- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
PaR3 PaR4
Use"PASTE SPECIAL Use"PASTE SPECIAL
Bromodichloromethane Value:-then"copy Chloroform Values"then"COPY"
.Maximum data Maximum data
points=58 points=58
Date Data BDL=1/2DL Results Date Data BDL-1/2DL Results
1 6/19/2014 < 5 2.5 Std Dev. 11.2703 1 6/19/2014 < 5 2.5 Std Dev. 15.834
2 9/16/2014 < 5 2.5 Mean 11.6824 2 6/4/2015 33.7 33.7 Mean 16.5333
3 12/4/2014 < 5 2.5 C.V. 0.9647 3 3/17/2016 13.4 13.4 C.V.(default) 0.6000
4 3/5/2015 < 5 2.5 n 17 4 n 3
5 6/4/2015 < 5 2.5 5
6 6/4/2015 20.4 20.4 Mult Factor= 1.70 6 Mult Factor= 3.00
7 9/17/2015 < 5 2.5 Max.Value 36.200000 pg/L 7 Max.Value 33.700000 pg/L
8 12/10/2015 7.3 7.3 Max.Pred Cw 61.540000 pg/L 8 Max.Pred Cw 101.100000 pg/L
9 3/17/2016 7.9 7.9 9
10 3/17/2016 13.4 13.4 10
11 6/16/2016 < 5 2.5 11
12 9/15/2016 36.2 36.2 12
13 12/8/2016 8.5 8.5 13
14 3l9/2017 10.4 10.4 14
15 6/15/2017 34.9 34.9 15
16 9/19/2017 22.1 22.1 16
17 12/5/2017 20 20 17
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
NCO026123 RPA_2018a,data
-12- 10/1/2018

REASONABLE POTENTIAL ANALYSIS
Par25
Use"PASTE SPECIAL
1,4-Dioxane Values"then"COPY,
.Maximum data
points=58
Date Data BDL=1/2DL Results
1 12/7/2017 89 89 Std Dev. 380.4190
2 1/11/2018 937 937 Mean 379.3400
3 2/1/2018 1011 1011 C.V. 1.0028
4 3/1/2018 212 212 n 10
5 4/5/2018 397 397
6 5/9/2018 75.7 75.7 Mult Factor= 2.30
7 6/13/2018 77.7 77.7 Max.Value pg/L
8 7/17/2018 48 48 Max.Pred Cw >#####t Ug/L
9 8/22/2018 764 764
10 9/11/2018 182 182
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
NCO026123 RPA_2018a,data
3 10/1/2018

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S`C(� S
Page 17 � � w2 N1End, 6 (0 -"Lok6)
However, if 2 or more reported values are greater than the Total allowable concentration add
permit limits for the hardness-dependent metal and monthly monitoring. For cadmium and silver
read the guidance in Sections VII and VIII before adding a limitation. In addition,add effluent
hardness and upstream hardness sampling at a frequency of quarterly along with a footnote to
sample in conjunction with effluent metals sampling.The new hardness-dependent metal limits
should be effective immediately,unless a compliance schedule is deemed appropriate(see
paragraph G below).
F. No RP (Predicted Max>50% of Allowable)
If the hardness dependent metal is not showing reasonable potential but the predicted max is>50%
of the allowable concentration-add quarterly monitoring for the metal of concern. In addition,add
effluent hardness and instrea n hardness sampling,upstream of the discharge,at a quarterly
frequency with a footnote to sample in conjunction with effluent metals sampling. In accordance
with RPA procedures,metal sampling can be deferred to the Pretreatment LTMP/STMP but
hardness sampling must be included in the permit even if the metal sampling requirement is
deferred to the Pretreatment Program.
G. No RP(Predicted Max<50%of Allowable)
If the hardness dependent metal is not showing reasonable potential and the predicted max is
<50%of the allowable concentration—no monitoring or effluent limitations are required.
However, as discussed in Section IV,all Pretreatment POTWs sampling for hardness-dependent
metals(as part of their Pretreatment LTMP or STMP)shall get quarterly monitoring requirements
for effluent hardness and instream hardness,upstream of the discharge,unless the Permittee has a
zero low flow 7Q 10,then upstream hardness sampling is not necessary.
H. Compliance Schedules:
Sometimes a permittee cannot immediately comply with new or newly applied Water Quality-
Based Effluent Limits(WQBELs)upon the effective date of the permit because the permittee
needs time to consider its situation and evaluate its options, such as implementing source controls
or making substantial modifications to its facility or processes in order to meet the new limits.
Depending upon the circumstances,NPDES permits may include a series of required steps and
deadlines(i.e., a compliance schedule),which upon completion,enables the permittee to meet the
permit's water quality-based effluent limits(see 40 CFR § 122.47). If this is the case, be sure to add
a footnote by the new WQBEL giving an effective date of YY years after the permit becomes
effective(XXXX) and reference the addition of Section A.(X.). Compliance Schedule for Hardness
Dependent Metals. Each permit writer will be responsible for developing a compliance schedule
specific to each Permittee's circumstances keeping in mind that a particular compliance schedule
requires compliance with the WQBEL"as soon as possible." See Section X for more details on
Compliance Schedules.
VI. Chromium
To protect aquatic life,the 2007-2014 Triennial Review rules included numeric criteria for chromium VI
in freshwater and saltwater and a hardness-dependent standard for chromium III in freshwater.The
standard for Total Chromium was removed.
Parameter Acute FW,ug/l Chronic FW,ug/1 Acute SW,ug/1 Chronic SW,ug/1
(Dissolved) (Dissolved) (Dissolved) (Dissolved)
Chromium III Calculation Calculation --- ---
Chromium VI 16 1 11 1100 50

a - a 18
A. Key Issues:
Laboratories typically report chromium as total chromium, unless analysis for chromium VI is
requested.
Total chromium consists primarily of trivalent (III)and hexavalent (VI) forms. Hexavalent forms
which are generally produced by industrial sources are considered to be more toxic than trivalent
forms which typically come from natural sources(ATSDR. Toxicological Profile for Chromium.
See: http://www.atsdr.edc.gov/toxprofiles/tp.asp?id=62&tid=17)
In the situation where only total chromium effluent data are available, results are compared to the
most stringent applicable standard for either chromium III or chromium VI. In this particular case,
chromium VI will be the most stringent standard in either freshwater or saltwater environments.
This is conservative and represents toxicity based on chromium VI criteria when the water sample
may be primarily comprised of chromium III.
Chromium III and VI are not currently listed in Appendices D or J of 40 CFR 122 and are not
required as part of the federally mandated priority pollutant scan.
B. Recommended Analytical Method:
The recommended analytical method for total chromium is EPA Method 200.8. The recommended
analytical method for chromium VI is EPA Method SM3500-Cr B-2009. There is no recognized
analytical method for chromium III; therefore,chromium III should be determined from the
calculated difference of chromium VI from total chromium.
Chromium VI is sampled in the dissolved form and has a Practical Quantitation Limit(PQL) of 50
ug/L. Total Chromium can be sampled as a total recoverable metal and has a PQL of 10 ug/L.
C. Implementation Instructions:
As a cost savings measure,total recoverable chromium data results may be used as a conservative
surrogate in cases where there are no analytical results based on chromium III or VI. Permittees
with total chromium effluent samples showing no reasonable potential to exceed either the
chromium VI or the chromium III total allowable concentrations (permit limits)do not need
to continue to monitor for total chromium unless it is required by federal categorical
regulations or as part of their Pretreatment LTMP/STMP.
The total allowable concentrations(permit limits)for chromium III and chromium VI will be listed
in the RPA sheet after the appropriate input data is entered. Since chromium III and VI now have
state water quality standards, in the event the projected maximum concentration for total chromium
exceeds the standard for either chromium III or chromium VI, limits and monitoring should be
considered using the following guidance.
1. In the event where monitoring for chromium VI is indicated(total chromium projected max is
greater than the total allowable chromium VI permit limit), staff have the following options:
a) Add limitations and monitoring for chromium VI.
b) Require monitoring and analysis of total chromium in lieu of chromium VI.The permit
writer may choose this option when there is no chromium VI TBEL requirement for this
facility and:

1�IP9C-S (MP�c,-�c-,� c,�� o�i OF �c�s`��ear� Q,ss, J1ti�AL S�9S
Page 19 0 C-10 -26 10
(1) All total chromium effluent samples are consistently below the detection level for
chromium VI(50 ug/L).
(2) The Permittee has documented that chromium VI is not present*in the wastewaters
discharged. If total chromium is being reported at concentrations>50 ug/L the
permittee should supply dissolved chromium VI sample results to support this claim.
*Generally, a pollutant is"known"to be present in the effluent due to factors such
as source water contamination, industrial sources within the collection area,listing
status of the receiving water body,or inclusion in a pretreatment program.
2. In the event where monitoring for chromium III is indicated(total chromium projected max is
greater than the total allowable chromium III), staff have the following option:
a) Add limitations for Cr III and Cr VI and under Sample Type put"Calculate"for
chromium III. This will require the determination of the concentrations for total chromium
and chromium VI. The difference between these two values will be assumed as the
concentration of chromium III and will then be used for determining reasonable potential
and compliance with WQBELs already introduced.A footnote stating Cr III=Total Cr—
Cr VI should be added to the Cr III limitation.
VII. Cadmium
A. Given the new WQS for cadmium, it is likely that the RPA may determine a cadmium chronic
permit limit less than 1.0 µg/L for Permittees without much dilution. It is important that these
Permittees show that they are reporting cadmium down to the PQL(recognized as 0.5 µg/L in
March 2013 by DWR). Since not all Permittees are monitoring cadmium down to the lower PQL,
look at the Permittee's"cadmium effluent data"and consider the following guidance:
1. For Permittees reporting cadmium effluent values at levels<0.05 µg/L for the past year and
< 1 µg/L for previous years,the permit writer can consider this representative of all non-
detects.No limits or monitoring for cadmium required.
2. For Permittees reporting cadmium effluent values at levels< 1 µg/L or<2 µg/L for the past
several years,add or maintain quarterly monitoring but do not require an effluent limit,and
require that the Permittee have the lab test to the lower reporting level.
3. For Permittees reporting one or two cadmium effluent values as 1 µg/L instead of< 1 (and
possibly 2 µg/L instead of<2 before 2013),add or maintain quarterly monitoring,and require
that the Permittee have the lab test to the lower reporting level. State in the cover letter and fact
sheet that the Permittee should review and implement clean sampling techniques and spilt
cadmium samples with another lab. If hits continue,the Permittee should look at SIU's or
perform a collection system survey to look for possible sources. State that a limit will be put in
the permit during the next permit renewal if effluent levels show reasonable potential or exceed
the Total allowable concentration of xx.
VIII. Silver
EPA disapproved the Action Level policy for permitting silver. It is important that the Permittee show
that they are reporting silver down to the PQL(recognized as 1 µg/L in March 2013 by DWR)unless the
current reporting detection level demonstrates that the facility's discharge is less than the total allowable
concentration(permit limit). Note that the PQL for silver was 5 µg/L prior to 2013.
A. Given the aquatic life silver chronic standard of 0.06 µg/L,the best most Permittees can do is
demonstrate that the facility's discharge is less than the PQL. In general, a Permittee requiring a
limitation for silver will clearly show reasonable potential(i.e., effluent samples>5 µg/L). Look at
the Permittee's"silver effluent data"and consider the following guidance:
1. For Permittees reporting silver effluent values at levels< 1 µg/L for the past year and

� 10
< 5 µg/L for previous years,the permit writer can consider this representative of all non-
detects. No limits or monitoring for silver required.
2. For Permittees reporting silver effluent values at levels<5 µg/L for the past several years,do
not require an effluent limit but add or maintain quarterly monitoring and require that the
Permittee have the lab test to the lower PQL level.
3. For Permittees reporting one or two low silver effluent values as a positive detection (e.g., 1
instead of< 1 ug/L), add or maintain quarterly monitoring and require that the Permittee have
the lab test to the lower reporting level. State in the cover letter and fact sheet that the
Permittee should review and implement clean sampling techniques and spilt silver samples
with another lab. If hits continue the Permittee should look at SIU's or perform a collection
system survey to look for possible sources. State that a permit limit will be put in the permit
during the next permit renewal if effluent levels show reasonable potential or exceed the Total
allowable concentration of xx.
IX. Zinc
The hardness-dependent water quality standard for zinc typically results in a more stringent permit limit
for the acute total allowable metal verses the chronic. In this situation, use the acute total allowable metal
concentration(permit limit)as the limitation for the Daily Maximum and the Monthly Average.
X. Compliance Schedules
Before writing a Compliance Schedule please review the EPA Headquarters Memo dated May 10,2007
from James Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements. Some
important things to note from the memo—
Factors relevant to a conclusion that a particular compliance schedule requires compliance with the
WQBEL"as soon as possible,"as required by 40 CFR 122.47(a)(1)include: consideration of the steps
needed to modify or install treatment facilities, operations or other measures and the time those steps
would take. The permitting authority should not simply presume that a compliance schedule be based on
the maximum time period allowed by a State's authorizing provision.
Compliance Schedules that are longer than one year in duration must set forth interim requirements and
dates for their achievement. 40 CFR 122.47 (a)(3).
Any Compliance schedule contained in an NPDES permit must include an enforceable final effluent
limitation and a date for its achievement that is within the timeframe allowed by the applicable State or
federal law provision authorizing compliance schedules as required by CWA sections 301(b)(1)(C)....and
EPA regulations at 40 CFR 122.2, 122.44(d)and 122.44(d)(1)(vii)(A).
Therefore,permits must contain annual milestones and a final date to comply with the WQBEL. If it is
clear the Permittee will need to seek source reduction from SIU's or install equipment at the WWTP to
meet limits the permit writer should work with the Permittee to develop an appropriate schedule that
considers the relevant factors.
Milestones can be such things as—Identify sources of the pollutant,perform a collection system sewer
survey, evaluate source reduction alternatives, submit a Corrective Action Plan(i.e. Improving treatment
at the WWTP or moving the discharge to a larger stream), perform a dilution study,or issue revised
permits to SIU's to enforce limits and achieve compliance with the limitation(s), etc...
Some Permittee's may opt to perform a Water Effects Ratio(WER) study. This should not be part of the
compliance schedule. If they choose to do a WER,the Permittee should first submit the WER study plan
to DWR for approval. Once the Permittee receives approval from DWR on the WER study,the Permittee
can proceed.The WER study itself, may take about 18 months. The Permittee is responsible for
submitting the results to DWR and requesting a permit modification based on the findings.Note, a WER
study has to be re-evaluated and reconfirmed every five years.

Permit No. NC0026123
NPDES Implementation of Instream Dissolved Metals Standards- Freshwater Standards
The NC 2007-2015 Water Quality Standard(WQS)Triennial Review was approved by the NC
Environmental Management Commission(EMC)on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards -as
approved.
Table 1. NC Dissolved Metals Water alitv Standards/A vatic Life Protection
Parameter Acute FW, µg/1 Chronic FW, µg/I Acute SW, µg/I Chronic SW, µg/1
(Dissolved) (Dissolved) (Dissolved) (Dissolved)
Arsenic 340 150 69 36
Beryllium 65 6.5 --- ---
Cadmium Calculation Calculation 40 8.8
Chromium III Calculation Calculation --- ---
Chromium VI 16 11 1100 50
Copper Calculation Calculation 4.8 3.1
Lead Calculation Calculation 210 8.1
Nickel Calculation Calculation 74 8.2
Silver Calculation 0.06 1.9 0.1
Zinc Calculation Calculation 90 81
Table I Notes:
1. FW=Freshwater, SW= Saltwater
2. Calculation= Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
213.0200(e.g., arsenic at 10 µg/l for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness-Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph(11)(d)
Metal NC Dissolved Standard, µg/I
Cadmium,Acute WER*{1.136672-[/n hardness](0.041838)) •e^{0.9151 [In hardness]-3.1485}
Cadmium,Acute Trout waters WER*11.136672-[ln hardness](0.041838)} -e^10.9151[In hardness]-3.6236}
Cadmium,Chronic WER*{1.101672-[ln hardness](0.041838)} -e^{0.7998[ln hardness]-4.4451}
Chromium III,Acute WER*0.316 e^{0.8190[/n hardness]+3.7256}
Chromium III,Chronic WER*0.860 e^{0.8190[ln hardness]+0.6848}
Copper,Acute WER*0.960 e^{0.9422[ln hardness]-1.700}
Copper,Chronic WER*0.960 e^{0.8545[ln hardness]-1.702}
Lead, Acute WER*{1.46203-[In hardness](0.145712)} • e^{1.273[ln hardness]-1.460)
Lead, Chronic WER*{1.46203-[In hardness](0.145712)} • e^{1.273[In hardness]-4.705}
Nickel,Acute WER*0.998 e^{0.8460[ln hardness]+2.255}
Nickel,Chronic WER*0.997 eA10.8460[ln hardness]+0.0584}
Page 1 of 4

Permit No. NCO026123
Silver,Acute WER*0.85 •e^11.72[ln hardness]-6.59}
Silver,Chronic Not applicable
Zinc,Acute WER*0.978 e^10.8473[ln hardness]+0.8841
Zinc,Chronic WER*0.986 a^10.8473[In hardness]+0.8841
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness-dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness-based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case-by-case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge-specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below),but it is also possible to consider case-specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness-Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low-flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value(chronic or acute), the
discharge has reasonable potential to exceed the standard,which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present(i.e. consistently below
detection level),then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness-dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q 10 (the spreadsheet automatically calculates
the 1 Q 10 using the formula 1 Q 10=0.843 (s7Q 10,cfs)"'
• Effluent hardness and upstream hardness, site-specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness-dependent metal of concern and for
each individual discharge,the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans,and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values,upstream of the discharge.
If no hardness data is available,the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L(CaCO3 or(Ca+Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L,respectively.
If the use of a default hardness value results in a hardness-dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site-specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

Permit No. NC0026123
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness(chronic)
_(Permitted Flow, cfs *Ave Effluent Hardness mg/L)+ WO 10, cfs *Avg Upstream Hardness mg/L)
(Permitted Flow, cfs+s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the IQ 10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients(DPCs)or site-specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the"Fraction Dissolved"converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in-stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996)and the
equation:
Cdiss - 1 7 ll
Ctotal 1 + { [Kp.] [ss'l+a'] [101) J
Where:
ss=in-stream suspended solids concentration [mg/1],minimum of 10 mg/L used,
and
Kpo and a=constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness-dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient(or
site-specific translator)to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist(ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca= 07O10+Owl (Cwgs)—07O10)(Cb)
Qom,
Where: Ca=allowable effluent concentration(µg/L or mg/L)
Cwqs=NC Water Quality Standard or federal criteria(µg/L or mg/L)
Cb=background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw=permitted effluent flow(cfs, match s7Q10)
s7Q 10= summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens(cfs)
*Discussions are on-going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
IQ 10=used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0026123
QA=used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2=used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application(40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations,the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit(Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality-Based Toxics Control published in 1991.
7. When appropriate,permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10,2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure,total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases,the projected maximum concentration(95th%) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge,are
inserted into all permits with facilities monitoring for hardness-dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter Value Comments(Data Source)
Average Effluent Hardness(mg/L) 114.26 2016-2017 Permittee files
(Total as, CaCO3)
Average Upstream Hardness(mg/L) 51.93 2016-2017 Permittee files
(Total as, CaCO3)
7Q10 summer(cfs) 0 BIMS and project files
1Q10 (cfs) 0 RPA, calculations memo 21412010
Permitted Flow(MGD) 9.0 BIMS and project files
Date: 1 a • ( L
Permit Writer:
Page 4 of 4

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Central Portion of the Cape Fear River Basin
4. Rivers/Streams - Central portion of Cape Fear River Basin
North Carolina has approximately 63,000 miles of rivers and streams. The central portion of the Cape
Fear River basin contains approximately 6,050 miles of rivers and streams and is defined from below the
B. Everett Jordan Reservoir dam along the Haw River, and below the Randleman Lake dam along the
Deep River to Lock and Dam #1 (Figure 3). This area has been identified as a priority for nutrient
management since the early 2000s. This is one of the fastest growing regions of the state, and there will
be a need to determine allocations for waste assimilation, assess the effects and management of
nutrients discharged from point and non-point sources, and develop new drinking water sources in this
region.
The central portion of the Cape Fear River has a history of high nutrients. Algal blooms and high
chlorophyll-o concentrations occur behind Buckhorn Dam and Lock and Dams 1, 2 and 3, particularly
during years with low precipitation. Nutrients have been an item of discussion within each of the three
monitoring coalitions in the Cape Fear basin:the Upper Cape Fear River Basin Association, the Middle
Cape Fear Basin Association and the Lower Cape Fear River Program. Additionally, the Rocky River
Heritage Foundation4 6,The Nature Conservancy, North Carolina State University and the University of
North Carolina—Wilmington have expressed interest in nutrients.
Several municipalities have water supply intakes on this portion of the river. Algal blooms have
increased drinking water treatment costs for the City of Wilmington; hence, there is a high level of
stakeholder interest in this region. The Nature Conservancy is trying to start a process for addressing
nutrients; additionally,the Middle Cape Fear Basin Association has expressed interest in working with
the DWR on nutrient issues. Researchers from the University of North Carolina—Wilmington have also
been studying the algal blooms and algal toxins along portions of the middle and lower Cape Fear River6.
These events have stimulated considerable stakeholder interest regarding the effects of nutrients and
nutrient management.
Impairments: Portions of the Rocky River are listed as impaired for chlorophyll-o.
httP://Www.rockvriverchatham.org
s htt www.rockvriverchatha„ org/files/RRPost Mara 20 a
2 odf
6Isaacs,J.D.et al. 2014. Microcystins and two new micropeptin cyanopeptides produced by unprecedented Microcystis
aeruginosa blooms in North Carolina's Cape Fear River. Harmful Algae 31:82-86
htto://www sciencedirect com/science/article/oii/S15F
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12

Central Portion of the Cape Fear River Basin
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for which nutrient criteria are proposed. L&D=Lock and Dam)
Notes: The subwatersheds in gray either have nutrient management plans(i.e.,Jordan Lake and
Randleman Lake)or are areas that have streams draining to the portion of the Cape Fear River
downstream of Lock and Dam 1 (i.e., Lower Cape Fear). Thus, the areas in gray are not in the area
designated as the Central portion of the Cape Fear River Basin. The subwatersheds in color are either
listed as impaired for chlorophyll-a, or are of concern for nutrient over enrichment and comprise the
"Central Portion of the Cape Fear River Basin."
13

i
ROY COOPER
Governor
MICHAEL S. REGAN
Water Resources Sectcrarr
Environmental Quality S.JAY ZIMMERMAN
Director
February 22,2017
To: Jay Zimmerman, Division of Water Resources Director
Through:Cyndi Karoly, Water Sciences Section ChiefK
From: Brian Wrenn, Ecosystems Branch Supervisor
Tammy Hill, Water Quality Analyst
RE: DWR results from a 2-year study on 1,4-dioxane in the Cape Fear River Basin
Attached please find the final report for second year of the Division of Water Resources' study on 1,4-
dioxane in the Cape Fear River basin. Data contained in this report were collected from October 2014
through October 2016. Please contact Tammy Hill(919-743-8412 or tammv I hillCa�ncdenr eov)
questions. with any
cc:Jessica Godreau
Rebecca Sadosky
Jeff Manning
Connie Brower
Jeff Poupart
Julie Grzyb
Chris Johnson
Danny Smith
Trent Allen
Jim Gregson
Sherri Knight
-'Nothing Compares
Stale of North Carolina I Environmental Quality.t Water Sciences Section
1621 Mail Service Center I Raleigh,North Carolina 27699-1621
919-743.8400

1,4-Dioxane Monitoring in the Cape Fear
River Basin of North Carolina
An Ongoing Screening, Source Identification, and Abatement Verification Study
!'---Nothing Compares�.

Department of Environmental Quality
Prepared by:
The North Carolina Department of Environmental Quality
Division of Water Resources
Water Sciences Section
For more information on the 1,4-dioxane study and electronic copies of this publication:
http//deq ric gov/about/divisions/water resources/water-resources-data/water-sciences-home-page
Suggested citation:
North Carolina Division of Water Resources. 2017. 1,4-dioxane monitoring in the Cape Fear River basin
of North Carolina:An ongoing screening, source identification, and abatement verification study.
Raleigh, North Carolina: North Carolina Department of Environmental Quality.
North Carolina Department of Environmental Quality
Division of Water Resources
Water Sciences Section Mission Statement:
The mission of the Water Sciences Section is to provide the Division with accurate information
pertaining to waters of the state. Excellent service along with water quality monitoring and certification
programs and analytical laboratory analyses that provide scientifically defensible data are the section's
main avenues for accomplishing this mission.These activities support the management and protection
of North Carolina's water resources for the health and welfare of the citizens of North Carolina and the
economic well-being of the state.

Abstract
1,4-dioxane is an emerging contaminant of concern that was recently monitored in drinking water
throughout the United States as part of the U.S. Environmental Protection Agency's Third Unregulated
Contaminant Monitoring Rule. Results indicated the presence of 1,4-dioxane in three North Carolina river
basins,with the highest concentrations measured in the Cape Fear River basin in central North Carolina.
In October 2016, the North Carolina Division of Water Resources completed the second year of a study
designed to examine ambient concentrations, identify potential sources, and document water quality
improvements due to abatement efforts of 1,4-dioxane in major surface waters of the Cape Fear River
basin. Four primary areas of elevated 1,4-dioxane were identified in the upper portion of the basin. Three
of these areas were located immediately downstream of domestic wastewater treatment facilities,
indicating that these facilities were likely conduits for 1,4-dioxane from industrial sources into surface
water. The fourth was located further downstream of a wastewater facility, as well as in proximity to
potential legacy sources of the contaminant.
These findings were communicated to effected municipalities,project partners,and the interested public.
During the second year of the study, quarterly sampling indicated a reduction of 1,4-dioxane
concentrations in many areas of the basin. Further reductions will be necessary to achieve federal and
state health advisory levels for 1,4-dioxane in drinking water supplies. The Division of Water Resources
study will continue in the Cape Fear River basin and expand into the Yadkin and Neuse River basins during
2017-2018.
Keywords
1,4-Dioxane; Dioxane; Drinking water; Surface water; Wastewater; Cape Fear River basin; Unregulated
Contaminant Monitoring Rule; UCMR3; Emerging contaminants;Water quality; Water resources
1

Introduction
1,4-Dioxane (C4H8O2, CAS#123-91-1) is a clear liquid that is highly miscible in water(ATSDR, 2012; Mohr,
2010). It has historically been used as a solvent stabilizer, and is currently used for a wide variety of
industrial and manufacturing purposes. The compound can be found in industrial solvents,paint strippers,
and varnishes and is often produced as a by-product of chemical processes to manufacture soaps,plastics,
and other consumer products (Stepien,et aL, 2014; U.S. EPA, 2015; Water Research Foundation, 2014).
The United States Environmental Protection Agency (U.S. EPA) does not have an established maximum
contaminant level for 1,4-dioxane in drinking water. However,the U.S. EPA has characterized 1,4-dioxane
as "likely to be carcinogenic to humans" and has established a drinking water health advisory with an
associated estimated lifetime cancer risk of one in one million at a concentration of 0.35 µg/L (U.S. EPA,
2012). North Carolina has a calculated human health criterion for 1,4-dioxane of 0.35 µg/L in water
supplies and 80 µg/L in all other waterbodies (15A NCAC 026.0208).
Due to its physiochemical properties, 1,4-dioxane has a high mobility and is interminable in the
environment. As a water quality contaminant, its persistence is due to an "indefinite solubility in water"
(Stepien, et al., 2014). Conventional drinking water treatment mechanisms have been found to be
ineffective at removing 1,4-dioxane from source water. However, it can be removed via advanced
oxidation processes applying a combination of hydrogen peroxide and other factors(Stepien,et aL,2014;
Water Research Foundation, 2014).
Under the 1996 Safe Drinking Water Act, the U.S. EPA requires public water systems to monitor a list of
up to 30 unregulated contaminants in finished drinking water every five years. The data collected from
these monitoring exercises are one of the primary sources of occurrence and exposure data that the U.S.
EPA uses to determine regulations on these contaminants (UCMR3, 2012). The Third Unregulated
Contaminant Monitoring Rule(UCMR3)included 1,4-dioxane in the list of over 20 chemicals to be sampled
and evaluated, using specific analytical methods,during January 2013—December 2015 at all water utility
systems serving more than 10,000 people. These chemicals,as well as two viruses, were also collected at
a representative sample of smaller public water systems (U.S. EPA, 2016).
The surface waters of the Cape Fear River basin supply drinking water to many counties in North Carolina
(NC). According to UCMR3 data, this basin also exhibits some of the highest measured concentrations of
1,4-dioxane in finished drinking water in NC and the U.S. Therefore,it was the initial focus of a 1,4-dioxane
monitoring study by the North Carolina Division of Water Resources NC DWR) with three successive
objectives:
1. Screen for ambient 1,4-dioxane concentrations in surface waters of the basin during all seasons
to identify areas with consistently elevated results,
2. Identify sources and provide information to appropriate NC DWR staff, municipalities and other
interested parties,
3. Document changes in concentration in response to municipal and industrial actions to reduce 1,4-
dioxane discharges.
2

At the time of this report,the first objective has been completed, while the latter two have become part
of an ongoing,iterative process that will continue into the third year of monitoring in 2017 as 1,4-dioxane
abatement efforts progress.
Methods
Timeframe and Study Area
From October 2014—October 2016, the study progressed through three phases, aligned with the study
objectives. The initial screening study included monthly sampling during Year 1 (October 2014 —
September 2015)at twelve stations throughout the Cape Fear River basin to capture seasonal and spatial
variability in constituent concentrations. By May 2015,sufficient data were available to recognize distinct
areas where 1,4-dioxane concentrations were elevated,and seven monitoring stations were added to the
monthly monitoring schedule from June — September 2015 to assist with source identification. In
September 2015,the first full year of sampling was completed. Monitoring locations were adjusted and
sampling frequency was reduced to quarterly for Year 2 of the study (13 months from October 2015 —
October 2016;station information and location details in Appendix A)to continue to document the spatial
distribution of 1,4-dioxane, as well as surface water quality changes resulting from 1,4-dioxane source
remediation and abatement efforts in the basin.
Field Sampling and Procedure
Sampling was conducted according to methods described in North Carolina's Ambient Monitoring System
(AMS) Quality Assurance Project Plan (QAPP) (NCDENR, 2014, Section B.2 and Appendices 7 and 8) and
instructions provided by the contract laboratory for 1,4-dioxane sample collection and preservation. All
samples were collected as near-surface(i.e.0.1-meter depth)grab samples.
One sample was collected monthly or quarterly, depending on the study phase, for the analysis of 1,4-
dioxane at each site. Quality assurance(QA)samples,including duplicates,matrix spikes,and matrix spike
duplicates were collected quarterly at each of the stations on a rotating basis (two to four stations per
quarter), in accordance with the AMS QAPP(NCDENR, 2014).
During each sampling event, a multi-parameter meter(e.g.YSI Pro Plus with Quatro cable or similar)was
used in situ to measure instantaneous water temperature,pH,specific conductance,and dissolved oxygen
values.
Laboratory Procedure and Quality Control
Due to the absence of a U.S. EPA-approved analytical method for 1,4-dioxane in surface water or
wastewater, solid waste analysis methods, rather than finished drinking water methods, were chosen to
account for matrix interferences that may exist in stream samples. During the first year of the study,
method SW-846 8270 SIM (selected ion monitoring)with a practical quantitation limit(PQL)of 3 µg/L was
used to evaluate 1,4-dioxane. In December 2015, the analytical method was changed to SW-846 8260B
to support smaller sample volumes and a lower PQL of 2 µg/L. CIA samples were analyzed with both
methods to confirm that the change did not substantially alter results.
As mentioned above, QA samples included duplicates, matrix spikes, and matrix spike duplicates.
Duplicates were analyzed to evaluate reproducibility of results. Matrix spikes were analyzed to evaluate
surface waters receiving different types of inputs, including domestic wastewater effluent, dam release,
3

urban stormwater, and swamp waters, in which the potential for various types of interferences existed.
Matrix spike duplicates were analyzed to evaluate reproducibility of spiked samples.
Data Analysis
Data analysis was performed on NC DWR sample results to determine ambient concentrations of 1,4-
dioxane in surface waters throughout the Cape Fear River basin, to compare results with calculated
evaluation levels, and to identify areas that may be contributing to the exceedance of evaluation levels
throughout the basin.
Concentration results were reviewed monthly, then summarized on an annual basis to determine the
mean, median, maximum, and minimum concentrations. Monthly and summary results were plotted on
an ArcGIS Online map (http://arch is/1dJa1Ng)to identify potential areas of concern. The map was used
to examine areas of high concentrations as well as possible sources of 1,4-dioxane, including:
• Domestic and industrial point-source discharges,
• Active and inactive hazardous waste facilities,
• Active, inactive, and pre-regulatory landfills,
• Known 1,4-dioxane contaminated groundwater plumes,
• Wastewater outfalls from groundwater remediation sites,
■ Permitted non-discharge facilities, and
• Airports.
Additionally, where available,stream flow data from United States Geological Society(USGS) gages at or
near sampling stations were downloaded as an explanatory variable. Surface discharge appears to be
inversely related to 1,4-dioxane concentration in some cases.
Results
During the first year of the study, four areas of high 1,4-dioxane concentration were identified. Three of
the four areas were located immediately downstream of domestic wastewater treatment facilities
(WWTF), and one was further downstream of a WWTF, as well as downstream of an inactive textile
manufacturing site and other possible legacy sources. In Year 1,these areas had maximum concentrations
ranging from 171 to 1030 µg/L and mean concentrations from 43 to 351 pig/L. During Year 2, the same
areas returned maximum values of 20 to 614 µg/L and means of 11 to 260 µg/L.
Results in excess of the calculated criteria have been documented throughout the Haw, Deep, and Cape
Fear Rivers, with the highest 1,4-dioxane values during both study years from the upper watersheds of
the Haw and Deep Rivers. Decreases in mean 1,4-dioxane concentration from Year 1 to Year 2 of the
study were observed at all monitoring stations. During the second year of the study, the four Cape Fear
River stations below Jordan Lake routinely returned results at or below the laboratory PQL of 2 µg/L. Year
1 results for these stations averaged 4 to 6 µg/L.
Summarized results for the twelve stations monitored during both study years are provided in Appendix
B. Results for stations monitored only during Year 1 can be found in the initial study report (NC DWR,
2016).
4

Discussion
As an emerging contaminant of concern, municipal water and wastewater treatment facilities are
generally not equipped to remove 1,4-dioxane through their treatment processes. Due to the high
aqueous solubility and resistance of 1,4-dioxane to biodegradation,conventional treatment processes are
generally ineffective at removal (Zenker, et aL, 2003). Installation and operation of advanced treatment
processes, such as those using hydrogen peroxide, ozone, and/or ultraviolet photo-oxidation, shown to
be effective for 1,4-dioxane removal at WWTFs or drinking water systems are anticipated to be
prohibitively expensive for local governments and the citizens served by public utilities (Ibid). Therefore,
the most prudent approaches to reducing 1,4-dioxane concentrations in surface water and drinking water
are likely to be reduction, elimination, and/or capture and treatment at industrial sources using or
generating the compound.
It has been found that certain industrial processes are more likely to utilize 1,4-dioxane or to create it as
a by-product, such as esterification and subsequent polycondensation used to create polyethylene
terephthalate (PET) plastics (Popoola, 1991) or the synthesis of those plastics in the manufacturing of
polyesters (Zenker, et aL, 2003). Therefore, WWTFs with such industries discharging to their collection
system may expect to see greater loading of this contaminant in both their influent and effluent streams.
During the first year of the study, the highest measured concentrations were observed below WWTFs.
1,4-dioxane is not used in or created by wastewater treatment processes, suggesting that the most
significant contributions were constituents of industrial waste streams that were passing through WWTF
treatment processes with varying levels of removal efficiency prior to entering surface waters. These
findings were communicated to the affected municipalities to support their pretreatment programs.
The second study year included quarterly sampling which yielded a sample size too small to draw
definitive conclusions. Measured 1,4-dioxane concentrations generally decreased throughout the basin,
suggesting potential improvement in water quality which may have been due to actions taken by the
municipalities (and/or their contributing industries) whose WWTFs were receiving industrial effluent
containing 1,4-dioxane. NC DWR's ongoing monitoring study will provide more data to determine actual
water quality improvements, inform 1,4-dioxane reduction efforts, and document surface water
outcomes over time.
Management Implications and Future Actions
Successful abatement of 1,4-dioxane in Cape Fear River basin drinking water sources will require
continued partnerships between the Division, project partners, municipal utility departments, and
industries within the basin. Further research into options for replacement of 1,4-dioxane-containing
compounds in industrial processes, as well as capture and treatment technologies that could be
implemented in industrial and domestic wastewater treatment systems, is warranted. Such research has
already begun locally through studies funded by the National Science Foundation, Water Resources
Research Institute, and Urban Water Consortium.
The NC DWR is developing a study plan to continue monitoring 1,4-dioxane concentrations at selected
locations within the Cape Fear River basin during 2017-2018 with the objectives of further understanding
fluctuations in concentrations, identifying sources, and documenting in-stream responses to source
abatement efforts. Also in 2017-2018,the study will be expanded into the Neuse and Yadkin River basins
5

in areas that returned UCMR3 1,4-dioxane results above the calculated human health criterion for water
supply waterbodies.
Acknowledgements
appreciate the support of our colleagues within this Section and also within the
This research was supported by the Public Water Supply Section of the No PI
This Carolina DWR. We, Permitting and
Water Sciences Sections, who provided their insight and expertise to assist with this study.
The upcoming expanded study will be funded under a grant from the National Fish and Wildlife
Foundation. We thank the Foundation and our Water Sciences Section colleagues who will be
contributing to the monitoring efforts, optimizing instrumentation, and developing methods to expand
the NC DWR Chemistry laboratory's capacity to analyze 1,4-dioxane in water.
We recognize Dr. Detlef Knappe and his graduate students at the North Carolina State University
Department of Civil, Construction, and Environmental Engineering for their assistance with study design,
sample collection, and sample analysis.
Finally, we acknowledge and commend the efforts of the Cape Fear River basin municipalities that strive
to safeguard and provide high-quality public services to their constituents.
6

References
All hyperlinks accessible as of November 17, 2016.
(ATSDR) Agency for Toxic Substances and Disease Registry. 2012. Public health statement: 1,4-dioxane,
CAS# 123-91-1. Atlanta, Georgia: U.S. Department of Health and Human Services. Available at
http://www.atsdr.cdc.govlloxProfiles/tpl87-cl-b.pd .
Knappe,D.2014.Sources of 1,4-dioxane in the Cape Fear River watershed of North Carolina and treatment
options for 1,4-dioxane control. Raleigh, NC: NC State University. Study details available at
htt w NW.nsf. ov awardsearch showAward?AWD ID=1449768&HistoricalAwards=false.
Mohr,T.K.2010. Environmental Investigation and Remediation: 1,4-dioxane and other solvent stabilizers.
CRC Press. In 1,4-Dioxane White Paper. 2014. Water Research Foundation. Available of
http//www waterrf ore/resources/StateOfTheScienceReports/1 4-dioxane.pdf.
(NCDENR) North Carolina Department of Environment&Natural Resources, Division of Water Resources,
Environmental Sciences Section, Ecosystems Branch. 2014. Ambient Monitoring System (AMS):
Quality Assurance Project Plan,version 1.2.Available at
https //dea nc gov/about/divisions/water resources/water-resources-data/water-sciences-
home page/ecosystems branch/ams-quality-assurance-project-plan.
(NC DWR) North Carolina Division of Water Resources. 2016. 1,4-dioxane in the Cape Fear River basin of
North Carolina:An initial screening and source identification study.Raleigh,North Carolina: North
Carolina Department of Environmental Quality. Available as a link from
https://deq nc gov/about/divisions/water-resources/water-resources-data/water-scignces-
home-page/1-4-dioxane.
Popoola, A.V. 1991. Mechanism of the reaction involving the formation of dioxane byproduct during the
production of poly(ethylene terephthalate). Journal of Applied Polymer Science 43, 1875-1877.
Available at
http//oniinelibrary wiley com/doi/10 1002/app 1991 070431011/abstract.
Stepian, D.K., Diehl, P., Helm, J., Thomas, A. and Puttmann, W. 2014. Fate of 1,4-dioxane in the aquatic
environment: From sewage to drinking water.Water Research 48,406-419.Available at
http://dx.doi.org/10.1016/*.watres.2013.09.057,
(UCMR3) Revisions to the Unregulated Contaminant Monitoring Rule (UCMR3)for Public Water Systems.
77 Federal Register 26,072(May 2, 2012).Available at https://www.gpo.gov/fdsys/pkg/FR-2012-
05-02/htmI/2012-9978.htm.
(U.S. EPA) U.S. Environmental Protection Agency, Office of Water. 2012. 2012 Edition of the Drinking
Water Standards and Health Advisories(EPA 822-5-12-001). Washington, DC: U.S. Environmental
Protection Agency.Available at http://www.epa.gov/nscep(search for"822512001").
(U.S. EPA) U.S. Environmental Protection Agency.2016.Third Unregulated Contaminant Monitoring Rule.
Available of http //water epa govZlawsregs/ruIesregslsdwa/ucmr/ucmr3/basicinformation.cfm.
7

(U.S. EPA) U.S. Environmental Protection Agency, Office of Chemical Safety and Pollution Prevention.
2015. TSCA Work Plan Chemical Problem Formulation and Initial Assessment (EPA 740-131-5003).
Washington, DC: U.S. Environmental Protection Agency. Available at http://www.eDa.gov/nsce
(search for"740R15003').
Water Research Foundation. 2014. 1,4-Dioxane White Paper.Available at:
htt www.waterrf org/resources/StateOfTheScience Reports/1 4 dioxane pdf.
Zenker, M.J., Borden, R.C., Barlaz, M.A. 2003. Occurrence and treatment of 1,4-dioxane in aqueous
environments. Environmental Engineering Science 20(5),423-432.Available at
http://online liebertpub com/doi/abs/10.1089/109287503768335913.
8

APPENDIX A
NC DWR Monitoring Station Locations
Station Location County Latitude Longitude Stream Monitoring
Class Dates
Haw River above Reedy Fork
B4 Haw River at Troxler Mill Road near Rockingham 36.2329 -79.5588 WS-IV NSW Jun 2015-
Reidsville Oct 2016
B1 Haw River at SR 1712(Brooks Oct 2014-
Guilford 36.2219 -79.5456 WS-V NSW Oct 2016
Bridge Road)
B0210000 Haw River at SR 1561 Hub Mill Oct 2014-
Road Alamance 36.1786 79.5042 WS V NSW Oct 2016
Buffalo Creek and Reedy Fork
B0750000 South Buffalo Creek at SR 2821 at Oct 2014-
Guilford 36.1128 -79.6718 WS-V NSW Oct 2016
McLeansville
B6 Reedy Fork at NC-61 near Ossipee Guilford 36.1792 -79.5763 WS-V NSW Jun 2015-
Oct 2016
Oct 2014-
B0840000 Reedy Fork at NC-87 at Ossipee Alamance 36.1730 -79.5103 WS-V NSW Oct 2016
Hasketts Creek
NCSU24 Haskett Creek at WOW Road near Randolph 35.7681 -79,7790 C Jun 2015-
Asheboro Oct 2016
Haw River below Reedy Fork
B2100000 Haw River at SR 1713 near Bynum Chatham 35.7717 79.1450 WS IV NSW Oct 2014-
(near Pittsboro intake) Oct 2016
Cape Fear River
B8 Cape Fear River at Harnett County Harnett 35.4092 -78.8189 WS-IV CA Oct 2014-
Public Utilities intake Oct 2016
Cape Fear River at US-401 at Oct 2014-
66370000 Harnett 35.4065 78.8135 WS IV Oct 2016
Lillington
Cape Fear River at Hoffer WTP Oct 2014-
67480000 intake at Fayetteville Cumberland 35.0825 78.8638 WS IV CA Oct 2016
Oct 2014-
B8350000 Cape Fear River at Lock 1 near Kelly Bladen 34.4038 -78.2932 WS-IV Sw Oct 2016
1NC Stream classifications at study locations included Water Supplies(WS-IV and WS-V)and Critical Areas(CA)near drinking water intakes,
Nutrient Sensitive Waters(NSW),waters protected for aquatic life and secondary recreation(C)and Swamp waters(Sw).
9

APPENDIX B
NC DWR 1,4-Dioxane Monitoring Results
Station Location Stream ELl Year 1,4-Dioxane Concentration(µg/L)3
Class (µg/L) (n)Z Min Median Max Mean
Haw River above Reedy Fork
Haw River at Troxler Mill Road WS-IV 1(4) 35 169 1030 351
B4 near Reidsville NSW 0.35 2(6) <2 4 46 11
Haw River at SR 1712(Brooks WS-V 1(13) <3 33 149 46
B1 Bridge Road) NSW 80 2(5) <2 5 54 14
B0210000 Haw River at SR 1561 Hub Mill WS-V 80 1(13) <3 38 100 42
Road NSW 2(5) <2 7 51 14
Buffalo Creek and Reedy Fork
South Buffalo Creek at SR 2821 WS-V 1(15) 9 25 543 80
60750000 Harvest Road at McLeansville NSW 80 2(6) 7 12 86 28
Reedy Fork at NC-61 near WS-V 1(4) 11 20 45 24
B6 Ossipee NSW 80 2(5) 9 9 62 20
B0840000 Reedy Fork at NC-87 at Ossipee NSW WS-V 80 1(13) 7 45 100 43
2(5) 7 10 20 12
Hasketts Creek
NCSU24 Hasketts Creek at W.O.W. Road C 80 1 (4) 147 269 478 291
2(5) 69 169 614 260
Haw River below Reedy Fork
B2100000 Haw River at SR 1713 near WS-IV 0.35 1(13) <3 13 66 18
Bynum(near Pittsboro intake) NSW 2(5) <2 8 14 8
Cape Fear River
Cape Fear River at Harnett WS-IV 1(13) <3 5 15 6
B8 County Public Utilities intake CA 0.35 2(5) <2 <2 <2 <2
B6370000
Cape Fear River at US-401 at WS-IV 0.35 1(15) <3 4 15 6
Lillington 2(5) <2 2 3 2
B7480000 Cape Fear River at Hoffer WTP WS-IV 0.35 1(12) <3 3 11 4
intake at Fayetteville CA 2(5) <2 <2 <3 <2
68350000
Cape Fear River at Lock 1 near W5-IV 0.35 1(12) <3 3 11 4
Kelly Sw 2(5) <2 2 3 2
Notes:
'The evaluation level(EL)for 1,4-dioxane is based on stream classification. The water supply EL is 0.35 µg/L,
except WS-V in the Jordan Lake watershed. The EL for Jordan Lake WS-V and all other waters is 80 jig/L.
2The Year 1 summary includes monitoring results from October 2014-September 2015. The Year 2 summary
includes monitoring results from October 2015-October 2016. "n" is the number of results during the study year.
3 Median and mean values may be inflated for stations with results below the contract lab PQL of 3 µg/L(in 2014-
2015)and 2 µg/L(in 2016). For summary calculations,non-detect results are set equal to the PQL in place at the
time of analysis. When a minimum or all values were below the PQL,a "<"sign is used.
11

APPENDIX A
NC DWR Monitoring Station Locations
Reidsville
B4
BI
Greensboro •
B0750000gurlington
High Point' /f —�'~^�fir' 60210000
r _ Durham �B6
B0840000
NCSU24 ��B2 000
1
Asheboro
A
'O
0
t B8
Fayetteville B748 0 t
is
NC DWR 1 ,4-Dioxane
Monitoring Stations
in the
Cape Fear River Basin
October 2014 October 2016
L. r
N
A
Legend B8350000
` DWR 1,4-Dioxane Monitoring Sites Wilmington
Major Riven A— I
Deep,Haw and Cape Fear Rivers
Reservoirs
Major Municipal Areas 0 10 20 40 Miles
Jordan Lake Watershed
10

APPENDIX B
NC DWR 1,4-Dioxane Monitoring Results
1,
t•M
•6/
1 21
OB21000M
:cgcnd
yy GcN!ba rw 7l+un l,�
` j l - •- n'Ir9/l) Mu.DnO..d C.- Wrrn
�` • W.M.sm ,W.M.•
' r
b 6v... / 5� WS it,
f,� • J7b70
J WS ry
--- T _ • 10 10]7 A'S V
-t 1c' Ckem
t 'A�:dM:! •--- tbcc■and l W--
fat
-f� ♦r:MNn
( / • Je.d.n lake WIenA•d
1 >IC!la 3!1
• >SC to 3CC
R�r. � •
ZS
_tz.]
12

Randleman Lake 1,4-Dioxane Calculation
The concentration of 1,4-Dioxane at WS-V boundary in Deep River resulting from 2.65 µg/L in Deep River
above confluence with Hasketts Cr(Station B4800000) is calculated using the mass-loadingformula:
m ula:
Load (lb/day) = Concentration (mg/L) x Flow(MGD) x 8.34, where
8.34 is a conversion factor.
Downstream Randleman Lake (station B4800000) concentration = 2.57 µg/L (0.00257 m L
Flow at station B4800000= 233.6 cfs/1.55 conversion factor= 150.7 MGD g/ )
Flow is calculated via yield:
Drainage area (DA) at station = 235 miz (delineated using StreamStats)
DA at Streamgage 02100500=349 miz (USGS 2012 Low Flow report)
Avg Ann flow (QA) at Streamgage 02100500= 347 cfs (USGS 2012)
Yield =QA/DA= 347/349 = 0.994
QA at station = Yield x DA at station =0.994 x 235 =233.6 cfs
Flow at WS boundary=838 cfs/1.55 conversion factor= 540 MGD
Flow was similarly calculated via yield with a nearby streamgage.
1,4-Dioxane load below Randleman Lake =0.00257 mg/L x 150.7 MGD x 8.34 = 3.23 lb/day
1,4-Dioxane conc. at at the WS bounds
ry= 3.231b/day/(8.34x540MGD)x1000=0.7
n La.r l
CO - ,r. n In.lrr..r. I.Yt. I+rrr.r .reedl
nu.rr
Randleman 1,4-Dioxane= 2.57 ug/L
Lake -
Al— -
ti
USGS Sta 0 �
2100500
DA= 349 mil r�
QA=347
USGS Sta 02102000
.�r.... DA= 1410 miz
WS-V QA= 1380 cfs1 `
DA= 853 miz
QA=838 cfs
G.B. Perlmutter, 10/11/2018

Evaluation of Alternative 1,4-Dioxane Effluent Limitations for Asheboro WWTP (NC0026123)
From consultation with the SIU Starpet in September 2018, the City of Asheboro proposed to DWR two
potential 1,4-dioxane effluent limits: a concentration-based Monthly Average limit of 97 µg/L, and a
loading limit based on 60 µg/L concentration. These proposed limits were evaluated via calculation of
their concentrations at the nearest downstream WS water upper boundary and compared against that
from the 149 µg/L monthly average limit proposed in the first draft permit. Calculations were made
using the mass-loading formula:
Load (lb/day) = Concentration (mg/L) x Flow (MGD) x 8.34, where
8.34 is a conversion factor.
Given:
WWTP design flow = 9.0 MGD
Downstream WS flow = 540 MGD extrapolated using USGS StreamStats
Alternative 1• Monthly Average Limit of 149 ug/L based on RPA calculation (i.e., reference scenario):
Applicable Human Health criterion at discharge = 80 ug/L (non-WS)
0.149 mg/L x 8.34 x 9 MGD = 11.18 Ib/d at design flow
11.18 Ib/d /(8.34 x 540 MGD downstream flow) x 1000 = 2.48 ug/L at the downstream WS boundary
WS
For actual load under current average discharge flow of 3.5 MGD:
0.149 mg/L x 8.34 x 3.5 MGD =4.35 Ib/d
4.35 Ib/d /(8.34 x 540 MGD) x 1000 =0.96 ug/L at WS
This option was proposed in the draft permit and is presented here as reference for comparison.
Alternative 2• Mass loading limits based on 60 ug/L effluent concentration
0.060 mg/L x 8.34 x 9 MGD = 4.5036 Ib/d load limit at 9 MGD design flow
4.5036 Ib/d /(8.34 x 540 MGD) x 1000= 1.00 ug/L at WS
For actual load under current average discharge flow of 3.5 MGD:
0.060 mg/L x 8.34 x 3.5 MGD = 1.7514 Ib/d load
1.7514 Ib/d/ (8.34 x 540 MGD) x 1000= 0.39 ug/L at WS
Page 1 of 3

Evaluation of Alternative 1,4-Dioxane Effluent Limitations for Asheboro WWTP (NC0026123)
Alternative 3: Mass loading using 97.0 ug/L Monthly Average limit at 9 MGD design flow
0.097 mg/L x 8.34 x 9 MGD design flow= 7.28 Ib/d load
7.28 Ib/d/ (8.34 x 540 MGD) x 1000 = 1.60 ug/L at WS
For actual load under current average discharge flow of 3.5 MGD:
0.097 mg/L x 8.34 x 3.5 MGD actual average flow = 2.83 Ib/d load
2.83 Ib/d/ (8.34 x 540 MGD) x 1000= 0.63 ug/L at WS
Summary Chart
2.51 Avg at Hoffer WTP(Fayetteville) Intake along Cape Fear R
2.48 based on RPA-based Mo. Avg. limit of 149 ug/L at 9 MGD 11.18 N
-- o
U
c
o
i 1.60 based on 97.0 ug/L Mo. Avg. limit at 9 MGD 7.28 9-
n
C p�
O (D
Ln
1.00 based on 60 ug/L-derived load limit at 9 MGD -- 4.S0
Q
0.63 based on 97 ug/L Mo. Avg. limit at 3.5 MGD — 2.83
Recommendation: Based on the results of this evaluation, both the 60 µg/L-based load limit and the
97.0 µg/L Monthly Average concentration limit were found to protect the downstream water quality
better than does the RPA-based Monthly Average concentration limit proposed in the draft permit. A
combined 1,4-Dioxane limit of 97.0 µg/L monthly average with a load limit not to exceed 4.50 lb/day is
recommended for Asheboro's permit, as they represent best achievable treatment technology proposed
by the SIU Starpet Inc., identified as the primary source of 1,4-Dioxane to the POTW. The loading limit
will assure that as flow increases, 1,4-Dioxane concentrations will decrease, thereby providing
downstream water quality protection while allowing flexibility for the WWTP and its SIU to increase
flow. The concentration limit will prevent load-based effluent concentrations from rising indefinitely
with low flows (e.g., at 2 MGD, the maximum load would yield an effluent concentration of 269 µg/L,
which exceeds the 80 µg/L criterion at the receiving stream), thereby providing further protection of
downstream water quality.
Estimated concentration at WS-Boundary(next page)
Page 2 of 3

Evaluation of Alternative 1,4-Dioxane Effluent Limitations for Asheboro WWTP (NC0026 123)
Estimated concentration at WS-Bounda
ry
Taking into consideration of the background loading from Randleman Lake, 1,4-Dioxan
at the WS-V upper boundary is per the recommended loading limit is calculated as follows:concentration
Asheboro load limit of 4.50 lb/day+ upstream Deep River load* of 3.23 lb/d = 7.73 lb/d 7.73 lb/day/(8,34 x 540 MGD)x 1000= 1.716 ay
*See Randleman Lake 1,4-Dioxane Calculations ug/L' rounded to 1.72 µg/�
heet
Page 3 of 3

' ROY COOPER
cove,nor
MICHAEL S. REGAN
Water Resources secrerur y
Environmental Quality LINDA CULPEPPER
/nlerim Director
May 1, 2018
John N. Ogburn, III
City of Asheboro
P.O. Box 1106
146 N Church Street
Asheboro, NC 27204
Subject: Draft NPDES Permit Renewal
Permit NCO026123
Asheboro WWTP, Grade IV
Randolph County
SIC Code 4952
Dear Mr. Ogburn:
Enclosed with this letter is a copy of the draft NPDES permit renewal for your facility. Please
review this draft carefully to ensure thorough understanding of the requirements and conditions it
contains. There are several changes from the existing permit, including the following:
• Regulatory citations have been added to the permit.
• Parameter characteristic codes have been added in Section A. (1.). — Effluent Limitations
and Monitoring Requirements.
• An updated outfall map with instream monitoring station locations has been included.
• Ammonia-Nitrogen (NH3-N) limitations have been decreased, based on wasteload
allocation (WLA) calculation. Limitations for NH3-N are based on protection of aquatic
life utilizing an EPA ammonia chronic criterion of 1.0 mg/L (summer) and 1.8 mg/L
(winter). The WLA results yielded NH3-N limitations that are more stringent than in the
current permit, as tabulated below:
Existing Proposed
Summer Winter Summer
Winter
Monthly Average 2.0 mg/L 4.0 m L �L 1.0 mg/L 1.8 mg/L
Weekly Average 6.0 m
12.0 mg/L 3.0 mg/L 5.4 mg/L
" —Nothing Compares
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh,North Carolina 27699-1611
919-707-9000

• Instream Conductivity monitoring has been added to the permit, based on the presence of
an industrial pretreatment program as specified in Instream Conductivity and Fecal
Coliform Monitoring Guidance(NCDWQ internal memo,2002). However,the Permittees'
sampling requirement for this parameter is conditionally waived as long as the Permittee
is a member of the Upper Cape Fear River Basin Association.
• The NC 2007-2014 Water Quality Standard(WQS)Triennial Review was approved by the
NC Environmental Management Committee(EMC) on November 13, 2014. The US EPA
subsequently approved the WQS revisions on April 6,2016 with some exceptions.The NC
Division of Water Resources NPDES Permitting Unit is required to implement the new
dissolved metal standards in all permits public noticed after April 6, 2016. The new
standards for most metals include acute standards. Further, the freshwater standards for
several metals are expressed as the dissolved form of the metals, and seven metals have
hardness-dependent equations. As a result, the NPDES Permitting Unit will need site-
specific effluent hardness data and instream hardness data, upstream of the discharge, for
each facility monitoring these metals in order to calculate permit limitations. Effluent
hardness sampling has been added to this permit at a quarterly monitoring frequency.
Upstream hardness sampling has not been added, in recognition of the receiving stream's
7Q10s of 0 cfs, which renders upstream hardness measurements irrelevant in dissolved
metals calculations. See Section A. (1.).
• As part of the NC 2007-2014 WQS Triennial Review, the Total Chromium WQS was
removed and replaced with trivalent chromium (Chromium III) WQS and hexavalent
chromium (Chromium VI) WQS. Total Chromium is made up of hexavalent and trivalent
forms. The reasonable potential analysis using Asheboro's Total Chromium effluent data
showed potential to violate the new Chromium VI standard. As a result,Total Chromium
limits were removed from the permit; quarterly monitoring of Total Chromium and
Chromium VI were added to the permit. Sampling for hexavalent chromium and total
chromium together will ascertain if hexavalent chromium is present in the total chromium
samples and thus the effluent. If sampling for hexavalent chromium indicates that
hexavalent chromium is not present (i.e. non-detectable concentrations at the lower
reporting level of the procedure)after two years of sampling,then the limits and monitoring
requirements for hexavalent chromium in Section A. (l.) can be reduced or removed upon
request. See Section A. (1.), Footnote 6.
• Currently, EPA is allowing an action level for Chloride,but at the next permit renewal this
may not be the case. Your passing record for toxicity tests indicate that a limit for chloride
is not necessary at this time, but this may change in the future. Please note that your
allowable concentration for Chloride is 230 mg/L. Your effluent average from January
2014 through December 2017 was 166 mg/L; and a reasonable potential analysis found a
reasonable potential to exceed the allowable concentration. As a result, quarterly
monitoring for Chloride in conjunction with toxicity tests is maintained in the permit.
• A monthly average limit of 5.0 µg/L and a daily maximum limit of 22.0 µg/L for Cyanide
have been added to the permit and samples shall be taken monthly. Results of a reasonable
potential analysis on submitted data indicated a reasonable potential to exceed the instream
Page 2 of 5

Silver to the lower reporting level of the procedure. Quarterly monitoring for Total Silver
has been added to the permit.
• A monthly average limit of 149 µg/L for 1,4-Dioxane has been added to the permit. 1,4-
Dioxane is listed as a likely human carcinogen by the EPA. A basinwide survey of the Cape
Fear River has found elevated concentrations of 1,4-Dioxane just downstream of the
Asheboro WWTP discharge. To allow time and actions toward meeting the new 1,4-
Dioxane limits, a three (3) year compliance schedule has been added to the permit with
annual milestones. See Section A. (6.). Three effluent samples collected since December
2017, using EPA Method 624.1, have exceeded the allowable discharge limitation of 149
µg/L. Therefore, a limit and monitoring for 1,4-dioxane has been added to the permit.
• Some of the wording has changed in Section A. 2.
please review each paragraph carefully. ( ) — Chronic Toxicity Permit Limit;
• Section A. (3.) — Effluent Pollutant Scan has been modified to include the three specific
years in which the Effluent Pollutant Scans shall be performed (2019, 2020, and 2021). In
addition, at the end of the Special Condition, 2°d species Toxicity Testing Requirements
for municipal permit renewals per Federal Regulations [40 CFR 122.210)(5)] have been
added.
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted
and became effective on December 21, 2015. 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 final NPDES
permit. See Section A. (7.).
For information on eDMR, registering for eDMR and obtaining an eDMR user account,
please visit the following web page: http://deg.nc gov/about/divisions/water
resources/edmr.
For more information on EPA's final NPDES Electronic Reporting Rule, please visit the
following web site: https://www federal register Gov/documents/2015110/22/2015
24954/national- ollutant-dischar e elimination-s stem-n des-electronic-re ortin -rule.
The NPDES Standard Conditions (Parts II, 111, and IV) are not included with this draft. They can
be found at the following link if you would like to review them in conjunction with this draft
permit.
http://ncdenr s3 amazonaws com/s3fs
ublic/Water%20 ualit /Surface%20Water%20Protection/NPDES/MISC/NPDES%20Standard
%20Conditions-Boile late-DWR-SWP-NPDES-20150410. df
Please note that the receiving stream is listed as impaired for Copper on North Carolina's Final
2014 303(d)Impaired Waters List.Addressing impaired waters is a high priority with the Division,
Page 4 of 5

water quality standards. A footnote has been added to the effluent limitations sheet stating
that the Division will consider all values reported below 10 µg/L to be compliant due to
difficulties in quantifying cyanide in wastewater,but the Permittee shall submit all Cyanide
values reported by a NC-certified laboratory, even if values are less than 10 µg/L. See
Section A. (1.).
• Quarterly monitoring for Total Zinc has been removed from the permit. Review of the data
revealed no reasonable potential to exceed water quality standards. Quarterly monitoring
shall be maintained per the facility's pretreatment Long Term Monitoring Program
(LTMP).
• Effluent Mercury data were reviewed from May 2012 to May 2017. The Permittee tested
effluent for Total Mercury using EPA test Method 1631E throughout this period. In
accordance with the 2012 Mercury TMDL NPDES Guidance, the Permittee needs to show
annual average effluent concentrations below the Water Quality Based Effluent Limitation
(WQBEL) of 12.0 ng/L and no exceedance of the Technology Based Effluent Limitation
(TBEL) of 47 ng/L. A review of the data showed the annual averages were below the
WQBEL and all data were below the TBEL; therefore, no mercury limitation is required.
As a result of the TMDL evaluation, the limits and monitoring of mercury have been
removed from Section A. (1.). Sampling for mercury will be conducted during the three
(3) effluent pollutant scans [see Section A. (3.)] as well as the pretreatment LTMP using
EPA Method 1631 E.
Fifty-one(51)out of 71 low level effluent mercury samples collected were over 1 ng/L. As
a result, a Mercury Minimization Plan (MMP) requirement has been added in this permit
renewal. See Section A. (4). Please note that the Permittee shall develop and implement a
MMP during this permit term.The MMP shall be developed within 180 days of the NPDES
Permit Effective Date, and shall be available for inspection on-site. A sample MMP was
developed through a stakeholder review process and has been placed on the Division
website for guidance(https•//deq_nc gov/document/nc-model-mercury-minimization-plan-
dwr-npdes-swp-20130801).
• A monthly average limit of 31.6 µg/L for Bromodichloromethane has been added to the
permit and samples shall be taken monthly. Results of a reasonable potential analysis on
submitted data indicated a reasonable potential to exceed the instream water quality
standards.
• Review of submitted effluent data showed all samples for Total Silver to be less than
detection at 5 µg/L. In accordance with 15A NCAC 2B .0500, all test procedures must
produce detection and reporting levels that are below the permit discharge requirements
and all data generated must be reported to the approved detection level or lower reporting
level of the procedure. Currently, DWR's laboratory identifies the Practical Quantification
Limit for Total Silver at< 1.0 µg/L.The allowable discharge concentration for Total Silver
at your facility is 0.06 µg/L as a monthly average. The Division recommends that the
Permittee improves and implements "clean" sampling techniques, and analyzes Total
Page 3 of 5

and instream data will continue to be evaluated. If there is noncompliance with permitted effluent
limits and the stream impairment can be attributed to your facility, then mitigative measures may
be required.
Concurrent with this notification the Division is publishing a notice in a newspaper having
circulation in the general Randolph County area, soliciting public comments on this draft permit.
Please provide any written comments you may have to the following: NCDEQ/DWR, NPDES
Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 no later than 30 days after
receipt of this draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments and
take appropriate action prior to issuing a final permit. If you have questions concerning this draft
permit, please call me at [phone] or by email at [e-mail].
Sincerely
Gary Perlmutter, Environmental Senior Specialist
NPDES Complex Permitting Unit
Hardcopy: NPDES Files
eCopy: US EPA Region 4
DWR/Winston-Salem Regional Office/Water Quality Operations
DWR/Wastewater Operator Certification Group/Maureen Kinney
DWR/WSS/Aquatic Toxicology Branch/ Susan Meadows
DWR/Ecosystems Branch/Mark Vander Bourgh
City of Asheboro/Water Resources Director/Michael D. Rhoney, PE
Page 5 of 5

Permit NCO026123
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
City of Asheboro
is hereby authorized to discharge wastewater from a facility located at the
Asheboro Wastewater Treatment Plant
1032 Bonkemeyer Drive
Asheboro, NC 27203
Randolph County
to receiving waters designated as Hasketts Creek in the Cape Fear River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, Il, III and IV
hereof.
This permit shall become effective Month 1, 2018.
This permit and authorization to discharge shall expire at midnight on September 30, 2022.
Signed this day Month xx, 2018.
DRAFT
Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 14

Permit NCO026123
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as
of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive
authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and
provisions included herein.
The City of Asheboro is hereby authorized to:
1. Continue to operate and maintain the 9.0 MGD wastewater treatment plant with a discharge through
Outfall 001, consisting of the following components:
• Influent pump station with automatic bar screens and grit removal
• Influent ultrasonic flow meter
• Influent composite sampler
• Flow splitter box#1
• Seven (7)primary clarifiers; one(1) circular rated for 3.0 MGD, six (6) rectangular rated 1.0 MGD
each
• Trickling filter mixing/transfer pump basin
• Three(3) trickling filters, 140 feet diameter
• Recirculation box/valve vault and circulation pump basin#1
• Four(4) secondary clarifiers; 27,024 cu. ft. each
• Recirculation pump basin#2
• Nitrification mixing/transfer pump basin
• Flow splitter box #2
• Two (2) nitrification basins with mixing basin and blowers; 2,000,000 gallons each
• Flow splitter box#3
• Magnesium hydroxide chemical addition system
• Three(3) final clarifiers; 70,333 cu. ft. each
• Polymer chemical addition system
• One(I) Parkson Dynasand continuous flow tertiary filter
• Chlorine contact chamber with sodium hypochlorite addition for disinfection
• Sodium bisulfite addition for dichlorination
• Effluent flow meter
• Effluent composite sampler
• Cascade aeration basin
• Two (2) sludge digesters; 401,900 gallons each
• Drying beds, 105 ft. x 450 ft. total
• Sludge dewatering presses, thickener tanks, lime stabilization system, and solids storage
• Standby power generation
This facility is located at the Asheboro WWTP, 1032 Bonkemeyer Drive, Asheboro, in Randolph
County.
2. Discharge from said treatment works via Outfall 001, at the location specified on the attached map
into Hasketts Creek currently classified C waters in the Cape Fear River Basin.
Page 2 of 14

Permit NCO026123
A. (1.) EFFLUENT LIMITATIONS AND MONK TORING RE UIRE
[I 5A NCAC 02B.0400 et seq., 15A NCAC 02B.0500 et se q MENTS
a. During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge treated municipal and industrial wastewater from outfall 001
this Grade IV facility. Such discharges shall be limited and monitored' by the Permittee ass specified
of
below: p red
PARAMETER CHARACTERISTICS EFFLUENT LIMITS
MONITORING REQUIREMENTS
Parameter Code Monthly Weekly Dail
Avera e y Measurement Sample Sample
9 Average Maximum Frequency Type Location 2
Flow BODs(20°C)3 50050 9.0 MGD
Continuous Recording Influent or Effluent
(April 1 -October 31) 80082 5.0 mg/L 7.5 mg/L
Daily Composite Influent and
BODs(20°C)3 Effluent
(November 1 -March 31) 80082 10.0 mg/L 15.0 mg/L
Daily Composite Influent and
Total Suspended Solids Effluent
(TSS)3 C0530 30.0 mg/L 45.0 mg/L
Daily Composite Influent and
Ammonia(NH3 as N) Effluent
(April 1 -October 31) C0610 1.0 mg/L 3.0 mg/L
Daily Composite Effluent
Ammonia(NH3 as N)
(November 1 -March 31) C0610 1.8 mg/L 5.4 mg/L
Daily Composite Effluent
Dissolved Oxygen(DO) 00300
Daily Average>6.0 mg/L Daily Grab
H Effluent
p 00400 Between 6.0 and 9.0 standard units
Daily Grab Effluent
Fecal Coliform
(geometric mean) 31616 200/100 mL 400/100 mL
Daily Grab Effluent
Total Residual Chlorine
(TRC)a 50060 17 u9/L
Daily Grab Effluent
Temperature(°C) 00010 Monitor and Report
Daily Grab Effluent
Conductivity(Nmhos/cm) 00094
Monitor and Report Daily Grab
Total Hardness[as CaCO3 Effluent
or(Ca+Mg)](mg/L)s 00900 Monitor and Report
Quarterly Composite Effluent
Total Chromium(Ng/L) 01034
Monitor and Report Quarterly Composite Effluent
Chromium VI(Ng/L) s 01032
Monitor and Report Quarterly
Total Kjeldahl Nitrogen Composite Effluent
(TKN)(mg/L) 00625 Monitor and Report
Monthly Composite Effluent
Nitrate/Nitrite Nitrogen
(NO3+NO2)(mg/L) 00 11 630 Monitor and Report
11 Monthly Composite Effluent
Page 3 of 14

Permit NCO026123
PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS
Monthly Weekly Daily Measurement Sample Sample
Parameter code Average Average Maximum Frequency Type Location 2
Total Nitrogen
[TN=(NO2+NO3)+TKN) C0600 Monitor and Report Monthly Calculated Effluent
(mg/L)
Total Phosphorus(mg/L) C0665 Monitor and Report Quarterly Composite Effluent
Dibromochloromethane 32150 Monitor and Report Quarterly Grab Effluent
(NgIL)
Bromodichloromethane 38693 ::31:6�pg/L Monthly Grab Effluent
Chlorides(mg/L)7 00940 Monitor and Report Quarterly Composite Effluent
Total Copper(NgIL) 01042 Monitor and Report Quarterly Composite Effluent
Total Cyanide a 00720 :5.0NgIL 22.0 NgIL Monthly Grab Effluent
Total Silver(Ng1L)s 01077 Monitor and Report Quarterly Composite Effluent
1,4-Dioxane 82388 149 NgIL' Monthly Grab Effluent
Chronic Toxicity" TGP3B Ceriodaphnia Pass/Fail at 90%effluent Quarterly Composite Effluent
Effluent Pollutant Scan NC01 Monitor and Report Footnote 12 Footnote 12 Effluent
Dissolved Oxygen(mg/L)13 00300 Monitor and Report Variable 14 Grab U,D1,D2
Temperature(°C)13 00010 Monitor and Report Variable 14 Grab U,D1,D2
Conductivity(Nmhoslcm)13 00094 Monitor and Report
Variable 14 Grab U,D1,D2
Footnotes:
1. Submit discharge monitoring reports electronically using the NC DWR's eDMR application system. See
Section A. (7.).
2. U = approximately 800 feet upstream of the discharge; DI = downstream at NCSR 2128; and D2 =
downstream in the Deep River at NCSR 2261.
entrations shall not exceed 15% of the respective influent
3. The monthly average effluent BOD5 and TSS conc
value(85%removal).
4. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the
permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina
certified laboratory(including field-certified),even if these values fall below 50 µg/L.
5. Effluent Total Hardness sampling shall be conducted in conjunction with testing for hardness-dependent
metals (cadmium, chromium,copper, lead,nickel, silver and zinc).
6. If Chromium V1 is not detected (i.e. non-detectable concentrations below the lower reporting level of the
procedure) after two years of sampling, the Permittee may request DWR to reduce or remove monitoring
requirements for Chromium VI in Section A. (1.).
7. Chlorides will be monitored in conjunction with Chronic Toxicity tests.
8. Due to difficulties quantifying cyanide in a wastewater matrix, the Division shall consider all values reported
below 10 µg/L to be "compliant" with this permit. However, the Permittee shall submit to DWR all values
Page 4 of 14

Permit NC0026123
reported by a North Carolina-certified test method (even if values fall below 10 µg/L), and the Permittee
shall consider all reported values when calculating averages, if any, as required by this permit.
9. The Permittee should review and implement clean sampling techniques for Total Silver. The reporting
laboratory should test to the lower reporting level of the procedure.
10. This limit becomes effective [within three (3) years of the effective date of this permit). The Permittee shall
follow the compliance schedule detailed in Section A. (6.).
11. Whole Effluent Toxicity samples shall be collected during the months of March, June, September, and
December. See Section A. (2.).
12. The Permittee shall preform three Effluent Pollutant Scans during the term of this permit. See Section A. (3.).
13. The Permittee has deferred receiving-stream sampling to the Upper Cape Fear River Basin Association by
memorandum of agreement (MOA). Should this MOA terminate for any reason, the Permittee shall
immediately inform the Division in writing and immediately resume instream monitoring in accordance with
this permit.
14. Instream samples shall be collected three times per week from June 1 through September 30, and once per
week from October 1 through May 31.
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 5 of 14

Permit NCO026123
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)—9.0 MGD
[15A NCAC 02B.0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
March, June, September and December. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
Chronic Value (ChV) below the permit limit, then multiple-concentration testing shall be
performed at a minimum, in each of the two following months as described in "North Carolina
Phase I1 Chronic Whole Effluent Toxicity Test Procedure" (Revised-December 2010) or
subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP313 for the pass/fail results and THP313 for the Chronic Value. Additionally, DWR Form AT-3
(original) is to be sent to the following address:
NC DEQ/DWR
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of"No Flow" in the comment area of the form. The report shall be submitted to the
Water Sciences Section at the address cited above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
Page 6 of 14

Permit NC0026123
testing quarter, which is the three-month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re-opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
Page 7 of 14

Permit NCO026123
A. (3.) EFFLUENT POLLUTANT SCAN (Municipal POTWs) [NCGS 143-215.1 (b)]
The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below.
One scan must be performed in each of the following years: 2019, 2020, and 2021. Analytical methods
shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether
parameters are present in concentrations greater than applicable standards and criteria. Samples should
be collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not
sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total
recoverable."
Ammonia(as N) C0610 1,2-dichloroethane 32103 Bis(2-chloroethoxy)methane 34278
Chlorine(total residual,TRC) 50060 Trans-1,2-dichloroethylene 34546 Bis(2-chloroethyl)ether 34273
Dissolved oxygen 00300 1,1-dichloroethylene 34501 Bis(2-chloroisopropyl)ether 34283
Nitrate 00620 1,2-dichloropropane 34541 Bis(2-ethylhexyl)phthalate 39100
Nitrite 00615 1,3 dichloropropylene 77163 4-bromophenyl phenyl ether 34636
Kjeldahl nitrogen 00625 Ethylbenzene 34371 Butyl benzyl phthalate 34292
Oil and grease 00556 Methyl bromide 34413 2-chloronaphthalene 34581
Phosphorus C0665 Methyl chloride 34418 4-chlorophenyl phenyl ether 34641
Total dissolved solids 70295 Methylene chloride 34423 Chrysene 34320
Hardness 00900 1,1,2,2-tetrachloroethane 81549 Di-n-butyl phthalate 39110
Antimony 01097 Tetrachloroethylene 34475 Di-n-octyl phthalate 34596
Arsenic 01002 Toluene 34010 Dibenzo(a,h)anthracene 34556
Beryllium 01012 1,1,146chloroethane 34506 1,2-dichlorobenzene 34536
Cadmium 01027 1,12-trichloroethane 34511 1,3-dichlorobenzene 34566
Chromium 01034 Trichloroethylene 39180 1,4-dichlorobenzene 34571
Copper 01042 Vinyl chloride 39175 3,3-dichlorobenzidine 34631
Lead 01051 Acid-extractable compounds: Diethyl phthalate 34336
Mercury(Method 1631E) COMER P-chloro-m-cresol 34452 Dimethyl phthalate 34341
Nickel 01067 2-chlorophenol 34586 2,4-dinitrotoluene 34611
Selenium 01147 2,4-dichlorophenol 34601 2,6-dinitrotoluene C0626
Silver 01077 2,4-dimethylphenol 34606 1,2-diphenylhydrazine 34346
Thallium 01059 4,6-dinitro-o-cresol 34657 Fluoranthene C0376
Zinc 01092 2,4-dinitrophenol 34616 Fluorene 34381
Cyanide 00720 2-nitrophenol 34591 Hexachlorobenzene C0700
Total phenolic compounds 32730 4-nitrophenol 34646 Hexachlorobutadiene 39702
Volatile organic compounds: Pentachlorophenol 39032 Hexachlorocyclo-pentadiene 34386
Acrolein 34210 Phenol 34694 Hexachloroethane 34396
Acrylonitrile 34215 2,4,6-hichlorophenol 34621 Indeno(1,2,3-cd)pyrene 34403
Benzene 34030 Base-neutral compounds: Isophorone 34408
Bromoform 32104 Acenaphthene 34205 Naphthalene 34696
Carbon tetrachloride 32102 Acenaphthylene 34200 Nitrobenzene 34447
Chlorobenzene 34301 Anthracene CO220 N-nitrosodi-n-propylamine 34428
Chlorodibromomethane 34306 Senzidine 39120 N-nitrosodimethylamine 34438
Chloroethane 85811 Benzo(a)anthracene 34526 N-nitrosodiphenylamine 34433
2chloroethyl vinyl ether 34576 Benzo(a)pyrene 34247 Phenanthrene 34461
Chloroform 32106 3,4 benzofluoranthene 34230 Pyrene 34469
Dichlorobromomethane 32101 Benzo(ghi)perylene 34521 1,2,4-trichlorobenzene 34551
1,1-dichloroethane 34496 Senzo(k)fluoranthene 34242
Page 8 of 14

Permit NCO026123
Reporting. Test results shall be reported electronically via eDMR or on DWR Form — DMR-PPA1 (or
on a form approved by the Director) by December 3111 of each designated sampling year. The report
shall be submitted to the following address: NC DEQ / DWR / Central Files, 1617 Mail Service
Center, Raleigh,North Carolina 27699-1617.
Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that
Municipal facilities that are subject to the Effluent Pollutant Scan requirements listed above are als j
subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.210)(5)
' S
and EPA Municipal Application Form 2A. The US EPA requires four (4) toxicity tests for a test
organism other than the test species currently required in this permit. The second species tests should be
conducted either quarterly for a 12-month period prior to submittal of the permit renewal application, or
four tests performed at least annually in the four and one-half year period prior to the application. The
second species tests must be multiple concentration (5 concentrations plus the control). These tests shall
be performed for acute or chronic toxicity, whichever is specified in this permit. POTWs performing
NPDES chronic Ceriodaphnia testing should perform chronic Fathead minnow testing. POTWs
performing NPDES acute Fathead Minnow testing should perform acute Ceriodaphnia testing. POTWs
performing NPDES chronic Mysid shrimp testing should perform chronic Silverside Minnow testing.
The second species toxicity test results shall be filed with the Aquatic Toxicology Branch at the
following address:
NC DEQ/DWR
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Contact the Division's Aquatic Toxicology Branch at 919-743-8401 for guidance on conducting the
additional toxicity tests and reporting requirements. Results should also be summarized in Part E
(Toxicity Testing Data) of EPA Municipal Application Form 2A, when submitting the permit renewal
application to the NPDES Permitting Unit.
Page 9 of 14

Permit NCO026123
A. (4.) MERCURY MINIMIZATION PLAN (MMP) [NCGS 143-215.1 (b)]
The Permittee shall develop and implement a mercury minimization plan during this permit term. The
MMP shall be developed within 180 days of the permit effective date, and shall be available for
inspection on-site. A sample MMP was developed through a stakeholder review process and has been
placed on the Division website for guidance (https://deg.nc.gov/docuinent/nc-model-mercury-
minimization-plan-dwr-npdes-swp-20130801). The MMP should place emphasis on identification of
mercury contributors and goals for reduction. Results shall be summarized and submitted with the next
permit renewal. Performance of the Mercury Minimization Plan will meet the requirements of the
TMDL (Total Maximum Daily Load) for mercury approved by USEPA on October 12, 2012, unless and
until a Waste Load Allocation specific to this facility is developed and this NPDES permit is amended to
require further actions to address the Waste Load Allocation.
A. (5.) NUTRIENT RE-OPENER [NCGS 143-215.1 (b)]
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North
Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II sections B-12
and B-13 of this permit, the Director of DWQ may reopen this permit to require supplemental nutrient
monitoring of the discharge. The purpose of the additional monitoring will be to support water quality
modeling efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan
developed jointly by the Division and affected stakeholders. In addition, the results of water quality
modeling may require that limits for total nitrogen and total phosphorus be imposed in this permit upon
renewal.
Page 10 of 14

Permit NC0026123
A.(6.) SCHEDULE OF COMPLIANCE FOR 1,4-DIOXANE LIMITATIONS
[G.S. 143-215.1(b)]
I. Within one (1) year from the effective day of the permit, the Permittee shall submit to the Division of
Water Resources a Corrective Action Plan summarizing the strategy or actions to be taken to achieve
compliance with the 1,4-Dioxane limitation listed in Section A. (L), which includes specific dates for
completion or implementation of each action.
2. Within two (2) years from the effective date of the permit, the Permittee shall submit a report to the
Division summarizing actions taken during the previous year to achieve compliance with the 1,4-Dioxane
limitation. The actions shall be in accordance with the Corrective Action Plan submitted and approved by
DWR.
3. The Permittee shall achieve compliance with the 1,4-Dioxane limitation specified in Section A. (L)
within three(3)years of the effective date of this permit.
Upon approval of the Corrective Action Plan by the Division, the report and actions become an enforceable part
of this permit. Any modifications to the schedule shall be requested to the Division at least ninety (90) days
before the deadline. Modifications to the schedule in excess of four(4)months will be subject to public notice.
Corrective Action Plan and Reports shall include the owner's name, NPDES permit number and Permittee
contact person, and shall be submitted to:
(1) NCDEQ/ Division of Water Quality (2) NCDEQ/Division of Water Quality
NPDES Permitting Winston-Salem Regional Office
1617 Mail Service Center 450 West Hanes Mill Road, Suite 300
Raleigh, NC 27699-1617 Winston-Salem, NC 27105
Page 11 of 14

Permit NCO026123
A. (7.) ELECTRONIC REPORTING OF MONITORING REPORTS [NCGS 143-215.1 (b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This Section supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements (Supersedes Section D. (2.) and Section E. (5 ) (a)l
The Permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross-Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DEQ/ DWR/ Water Quality Permitting Section
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or
alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing
address above. See"How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Page 12 of 14

Permit NCO026123
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The Permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time
of each electronic submission. The permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at: https://www.federalre ister mov/documents/2015/10/22/2015
24954/national-pollutant-discharge-elimination-system-npdes electronic reporting rule
Electronic submissions must start by the dates listed in the"Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The Permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to
the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary
waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports
shall be submitted electronically to the Division unless the permittee re-applies for and is granted a
new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers
are not transferrable. Only permittees with an approved reporting waiver request may submit
monitoring data and reports on paper to the Division for the period that the approved reporting
waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Page 13 of 14

Permit NC0026123
4. Signatory Requirements ISupplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part Il,
Section B. (I1.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North Carolina's
eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the
following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.)1
The Permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
Page 14 of 14

. .2, �. �� �s cam- `�• �_
Downstream(Dl)
Asheboro WWTp
' . ' • and Outfall 001
a� Downstream(D2)
00(
84920000
l , 0�
Upstream(U)
84870
City of Asheboro NVNV Wj
Tp
NPDES Permit NCO026123 Facility
Latitude- 35'45'58•N State Grid/Quad: 019 SE/Randleman Location
Loneitude 79-47'08• ;y PermitttedFl�,. g.yJh1Gp not t0 scale
treaRecemi ass am: Hasketts Creek Diinaee Basinaasin
Stream Class: Cape FearRiver
C Sub-Basin: 03-06-09
Alorth Randolph County

Fact Sheet
NPDES Permit No. NCO026123
Permit Writer/Email Contact: Gary Perlmutter, [e-mail]
Date: Month xx, 2018
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting Unit
Fact Sheet Template: Version 09Jan2017
Permitting Action:
M 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 2"d 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 W WTP
Applicant Address: P.O. Box 1106, 146 N Church Street,Asheboro, NC 27204
Facility Address: 1032 Bonkemeyer Drive, Asheboro, NC 27203
Permitted Flow: 9 MGD
Facility Type/Waste: MAJOR Municipal; 87%domestic, 13% industrial '
Facility Class: Class IV
Bar screen, Grit removal, Parshall flume, Primary clarifiers,Trickling
filters, Activated sludge, Secondary clarifiers, Nitrification with
Treatment Units: 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
' Percentages calculated from 2016 actual industrial and total average daily flows(0.478 and 3.627 MGD,
respectively). Permitted industrial flow is 0.832 MGD or 9.2%of total permitted flow.
Page 1 of 14

Briefly describe the proposed permitting action and facility background: The City of Asheboro has applied
for NPDES permit renewal,and submitted a renewal application dated March 21,2016.This facility serves
a population of 25,676 residents and operates a pretreatment program with 15 Significant Industrial Users
(SIUs), 6 of which are Categorical Industrial Users(CIUs).
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
(C1U 433: metal finishing), Matlab Plant 14 (CIU 433: metal finishing, dropped from the pretreatment
program in 2016),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).
In addition, the Asheboro WWTP is receiving 1,400 gpd wastewater from the Randolph County School
Bus Maintenance Garage groundwater remediation project. This is not an SIU according to ORC Ray
Wiseman.
The average industrial flow rate was 0.478 MGD from January through December 2016.The uncontrollable
flow was 3.152 MGD for that same period. The facility has a DWR-approved Full Pretreatment Program
with a Long-Term Monitoring Program(LTMP)for its SIUs.
2. Receiving Waterbody Information
Receiving Waterbody Information
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): 100%
303(d) listed/parameter: This stream segment is impaired for Copper(7 µg/L,AL,
FW)on the final 2014 and 2016 draft 303(d)lists.
Subject to TMDL/parameter: Statewide TMDL for Mercury
Subbasin/HUC: 03-06-09/03030003
USGS Topo Quad: D19SE Randleman,NC
Page 2 of 14

I Effluent Data Summary
Effluent data is summarized below for the period January 2014 through December 2017 for Outfall 001.
Table 1. Effluent Data Summary
Parameter Units Average Max Min Permit Limit '
Flow MGD 3.63 13.46 1.27 MA= 9.0
BOD summer mg/L 2.4 > 8.7 < 2.0 MA=5.0
WA
BOD winter mg/L 3.4 13.6 1.9 MA= 10.0
WA= 15.0
BOD Removal % 99.0 99.7 98.0 > S5
Total Suspended Solids MA= 30.0
(TSS) mg/L 4.8 51.5 < 2.0
WA=45.0
TSS Removal % 98.7 99.7 96.7 > 85
Ammonia(NH3-N) MA= 2.0
summer mg/L 0.2 4.0 <0.1
WA=6.0
Ammonia (NH3-N)
winter mg/L 0.9 29.5 <0 1 MA= 4.0
WA= 12.0
Dissolved Oxygen
(DO) mg/L 8.0 10.7 6.0 DA> 6.0
PH SU 6.9 7.9 6.0 6 - 9
Fecal Coliform
(geometric mean) #/100 mL 7 > 6000 < 1 MA=200
WA=400
Total Residual
Chlorine(TRC) µg/L 15.6 48 < 15.0 DM = 17
Temperature °C 20.5 29.7 9.5 Monitor only
Conductivity µmhos/cm 1016 1952 238 Monitor only
Total Chromium µg/L 6.5 26,0 <5 0 MA= 50
DM = 1033
Total Mercury ng/L 1.7 8.5 0.8 MA= 12
DM = 36
Total Nitrogen (TN) mg/L 13.3 27.4 2.3 Monitor only
Total Kjeldahl
Nitrogen(TKN) mg/L 2.1 5.9 0.8 Monitor only
Nitrate/Nitrite Nitrogen
(NO2+NO3) mg/L 11.3 26.4 0.8
Monitor only
Total Phosphorus (TP) mg/L 0.38 1.81 0.08 Monitor only
Page 3 of 14

Dibromochloromethane µg/L 8. 20.4 5.0 Monitor only
Bromodichloromethane µg/L 11.7 36.2 - 5.0 Monitor only
Chloride mg/L 166 300 68 Monitor only
Total Copper µg/L 4.7 15.0 2.0 Monitor only
Total Zinc µg/L 25.2 1 55.0 13.4 Monitor only
MA=Monthly Average, WA= Weekly Average, DA=Daily Average, DM=Daily Maximum.
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
concems.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 in Hasketts Creek(t>),one downstream in Hasketts Creek(D 1)and one
additional downstream in Deep River(132).These locations correspond to the ambient monitoring stations
B4870000 (U), B4890000 (D1), and B4920000 (D2). Data from U and D2 were obtained from the
Monitoring Coalition Coordinator and span from January 2013-December 2016.Data from D I were from
the Ambient Monitoring System Coordinator and span from January 2013 -July 2016. The Permittee is a
member of the Upper Cape Fear River Basin Association,and instream monitoring is provisionally waived
in light of their participation.
Dissolved Oxygen (DO) remains a parameter of concern for aquatic life. Instream data showed that the
standard of 5.0 mg/L was maintained at all stations with minima of 6.0 mg/L at U,6.5 mg/L at D 1, and 5.4
mg/L at D2. Effluent averages for September 2013 through August 2017 also were above 5.0 mg/L. The
permit will continue to include instream DO monitoring.
Temperature remains a parameter of concern for aquatic life. The standard maximum of 29 °C for upper
piedmont and mountain waters was maintained at all stations. However, downstream temperatures
exceeded the water quality standard of 2.8 °C above the natural water temperature when compared to
upstream data from 2013-2016 with 8 instances of 29 measurements or 28%at DI and 10 instances of 60
measurements or 17%at D2.The facility appeared to be contributing to increases in instream temperatures.
The permit will continue to include instream Temperature monitoring.
Conductivity is a parameter of concern because of industrial discharges. The permit does not currently
require instream monitoring,but data were available from the three stations.The data analyzed indicate that
Conductivity was significantly higher at D2 than at U (t= -10.94,p<0.0001), and substantially higher at
D1. Averages are: U= 114 uS/cm, DI = 726 uS/cm, and D2=222 uS/cm. Effluent Conductivity averaged
1037 uS/cm, indicating its influence on the receiving stream. Because the facility has a pretreatment
program and the patterns noted above, instream monitoring of Conductivity will be added to the permit.
Analysis of loading for Copper was compared for the 303(d)-listing year of 2008 through 2016. Calculated
monthly average loadings(lb/day)from 2008 to 2016 show significant reduction over time(r-2=0.485,p<
Page 4 of 14

facility appeared to be adequately operated and extremely well maintained. No concerns or problems were
noted during the April 1,2015 or April 10,2014 evaluations. One other inspection within the permit cycle,
conducted on April 3,2013,also found no concerns or problems.
6. Water Quality-Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations
Life; non-carcinogen HH); 30Q2 streamflow(aesthetics); annual average flow(carcinogen,
for development of WQBELs: 1 Q 10 streamflow(acute Aquatic Life); 7Q 10 streamflow(chronic Aquatic
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
Oxvgen-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.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: Limitations for BOD
are based on a Streeter Phelps model (Level B) for instream DO protection. No changes are proposed.
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: WLA calculations
were run using the annual 7Q 10 of 0.0 cfs for both the summer and winter values. The resulting TRC limit
is 17 µg/L, and will be maintained in the permit. The WLA resulted in more stringent ammonia limits than
in the current permit(Table 2).
Table 2. Proposed Ammonia-N Limits(mg/L).
Season !!2!M
Summer
Winter
Review of DMR data from January 2014 through December 2017 revealed a few isolated exceedences with
proposed monthly and weekly winter average limits(Fig. 1), suggesting upset conditions.The City expects
to be able to comply with the new NH3-N limitations.
Page 6 of 14

0.0001). Annual data tested statistically different among years with consistent decreases in yearly average
lbs/day of copper since 2008. See Stream Impairment Analysis for Copper in attachments for data and
graphs.
• Effluent Copper averaged 12.04 µg/L for 2008 and 5.67 µg/L in 2016 for average monthly samples.
Effluent Copper loading was 0.38 lbs/day in 2008 and 0.17 lbs/day in 2016.
• Annual average effluent Total Copper concentrations were below the 7 µg/L 303(d) listing level
since 2013.
Due to downstream impairment for Chlorophyll a exceedances in the Deep River [stream segment 17-
(10.5)dl], additional instream analysis was conducted for Inorganic Nitrogen (NO2+NO3), Total Kjeldahl
Nitrogen(TKN),Total Nitrogen (TN) and Total Phosphorous (TP). See attachments for instream nutrient
data summaries and graphs.
• Inorganic Nitrogen values were significantly higher at D2 than at U (t= -6.39,p < 0.0001), and
substantially higher at D1. Averages are: U= 0.17 mg/L, D1 = 6.95 mg/L, and D2 = 0.63 mg/L
NO2+NO3-Concurrent effluent NO2+NO3 data averaged 10.6 mg/L,indicating its influence on the
receiving stream.
• Total Kjeldahl Nitrogen values were significantly higher in D2 than in U (t= -3.32,p = 0.001),
and substantially higher at D 1.Averages are:U=0.53 mg/L,D 1 = 1.27 mg/L,and D2=0.69 mg/L
TKN. Concurrent effluent TKN data averaged 2.1 mg/L, indicating its influence on the receiving
stream.
• Total Nitrogen values were significantly higher in D2 than in U (t = -6.54, p < 0.0001), and
substantially higher at D l. Averages are: U = 0.70 mg/L, DI = 8.22 mg/L, and D2 = 1.32 mg/L
TN. Concurrent effluent TN data averaged 12.7 mg/L, indicating its influence on the receiving
stream.
• Total Phosphorus values were significantly higher in D2 than in U (t = 4.42,p < 0.0001), and
substantially higher at D1. Averages are: U = 0.06 mg/L, D1 = 0.29 mg/L, and D2 = 0.10 mg/L
TP. Concurrent effluent TP data averaged 0.36 mg/L, indicating its influence on the receiving
stream.
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): The facility had no
enforcements during the prior permit cycle.The facility had one limit violation for NH3-N monthly average
exceedance by 6.3% during the period from January 2013 through December 2017. This exceedence
resulted in a Notice of Deficiency(NOD).
Summarize the compliance record with aquatic toxicity test limits and any second species test results(past
5 years): The facility passed 16 of 16 quarterly chronic toxicity tests from 2014 through 2017, as well as
all four (4) second species chronic toxicity tests, sampled on 12/8/2013, 9/8/2014, 5/31/2015, and
3/14/2016,as well as one sampled on 6/5/2017.
Summarize the results from the most recent compliance inspection: The last facility compliance evaluation
inspection,conducted on March 13,2017,gave the facility a very reliable rating.One compliance issue was
noted for de-chlorination, where the facility was found to have a 10:1 chlorine to de-chlorination ratio.
Other compliance evaluation inspections, conducted on April 1, 2015 and April 10, 2014, found that the
Page 5 of 14

Asheboro WWTP Effluent NHS-N (proposed limits)
•10 Eff WA Eff MA
MA Lirinit WA Limit
9
8
7
6
4 I I I
1
• • •I
0 " •
1••
ti� a a
\�Q� ti�1�
a\tip\
Figure 1. Asheboro WWTP effluent monthly average
(MA)and weekly
(WA)concentrations(mg/L) with their respective Proposed 1d mi s for po ent ale
compliance evaluation.
Reasonable Potential Anal sis 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 waterquality
standards, a statistical evaluation that is conducted duringeve ent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d)utilizing the moTh The
RPA procedure utilizes the following: 1) 95% Confidence Level/95%Probability; 2)assumption of NC
background; 3) use of V2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC bean implementationp zero
dissolved metals criteria in the RPA process in accordance with
Instream Dissolved Metals Standards, dated June 10,2016, guidance titled NPDES Implementatr'on of
A reasonable potential analysis was conducted on effluent toxicant data collected between May 2014
May 2017 for the following parameters: arsenic, cadmium, chlorides, total chromium, co er, cyanide,
lead, molybdenum, nickel, selenium, silver, dibromochloromethane, bromodichloromethane, and
After review of the 3 effluent pollutant scans, the RPA was expanded to include chlorofo PP y lde,
concern included toxicants with positive detections and associated water quality standards/criteria. zinc.
rm. Pollutants of
on this analysis,the following permitting actions are Proposed for this Based
• Effluent Limit with Monitorin . The followin permit.
er quality-based
effluent limit(WQBEL)since they demonstratedrea parameters
potential al to exceed l receive a tapplicab a water
quality standards/criteria: Cyanide, Bromodichloromethane
• Monitor�pnly, The followin
did not demonstrate reasonable potential to exceed applicable water quality equiremen
parameters will receive a monitor-onlyr standards/ since they
the maximum predicted concentration was > 50% of the allowable concentration: Chlorides,
criteria,but
Copper, Total Chromium, Chromium VI, Silver, Dibromochloromethane
O Chlorides will maintain a quarterly monitoring requirement to coincide with toxicity
testing, since the EPA is currently allowing an action level for this parameter.
Page 7 of 14
a

o Total Chromium will maintain a monthly monitoring requirement but limits will be
removed as the maximum predicted value is>Cr-VI allowable concentration but<Cr-VI
detection level (Instream Dissolved Metals Guidance memo,6/10/2016).
o Chromium VI will receive a quarterly monitoring requirement for 2 yrs,to be continued if
detected.
o Total Silver will receive a quarterly monitoring requirement with samples analyzed to the
lower reporting level of the procedure.
• 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, Lead, Molybdenum, Nickel, Selenium, Zinc and Chloroform
• 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
As part of the NC 2007-2014 Water Quality Standard (WQS) Triennial Review the total Chromium NC
WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality
Standards. The reasonable potential analysis using Asheboro WWTP's Total Chromium effluent data
showed reasonable potential to violate the new hexavalent chromium standard. Total Chromium is made
up of hexavalent and trivalent chromium. As a result, quarterly monitoring for Total Chromium and
Chromium VI will be added to the permit and the Total Chromium limits will be removed. If after two
years no detects of Chromium VI are found,then monitoring for that parameter will no longer be needed.
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: This 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
protection. The TMDL established a
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health
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
Page 8 of 14

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 2. Mercury Effluent Data Summary
2013 2014 2015 2016 2017
Number of Samples 12 12 12 12 12
Annual Average Conc.ng/L 2.0 1.6 1.1 7 i1.3
Maximum Conc.,ng/L 5.8 3.5 2.2 2.7
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 2). However, since the facility is > 2 MGD and 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
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,Nitrate-nitrite Nitrogen,and Total Kjeldahl Nitrogen 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 will be
maintained. No changes are proposed.
Other WOBEL Considerations
Ifapplicable, describe any otherparameters ofconcern evaluatedfor WQBELs: The pollutant 1,4-Dioxane
is a likely human carcinogen that is highly mobile and does not readily biodegrade in the environment. It is
found in groundwater sites throughout the US, and a recent stream survey of the Cape Fear River Basin
found multiple sites with elevated concentrations. Elevated concentrations in that survey were found in a
site downstream of the Asheboro WWTP discharge at an average of 291 µg/L(range: 147-478 µg/L). As a
result, DWR had issued a letter, dated October 31, 2017, requiring monthly effluent monitoring, to
commence in December 2017 with samples analyzed using the recently EPA-approved method 624.L To
date, four data points were submitted, ranging from 89-1101 µg/L (mean = 562.3 µg/L), from which an
RPA found reasonable potential to exceed the NC calculated surface water criterion of 80 µg/L to protect
human health in non-water supply waters.Therefore,a monthly average limit of 149 µg/L will be added to
the permit with a three-year compliance schedule.
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 I5A
NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: A three-year compliance schedule is
proposed for meeting the 1,4-Dioxane limit.
Page 9 of 14

If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e)and 15A NCAC 2B.0226 for this permit renewal: NA
7. Technology-Based Effluent Limitations (TBELs)
Municipals
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/L
BOD51TSSfor Monthly Average, and 45 mg/L for BOD51TSSfor 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 2B.0201.Each applicant for a new/expanding NPDES permit must
document an effort to consider non-discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis(EAA)and any water quality modeling results: NA
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed(e.g.,based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit(YESINO): YES
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES
Guidance,Monitoring Frequency for Toxic Substances(7/15/2010 Memo); 3)NPDES Guidance,Reduced
Monitoring Frequencies for Facilities with Superior Compliance(10/22/2012 Memo);4)Best Professional
Page 10 of 14

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.
No effluent parameters in the current permit have reduced monitoring frequencies.
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 3. Current Permit Conditions ' and Proposed Changes
Parameter Current Permit Proposed Change Basis for Condition/Change
Flow MA 9.0 MGD No change g 15A NCAC 213 .0505
Summer:
MA 5.0 mg/L
BOD; WA 7.5 mg/L WQBEL. Based on 1995 WLA,
Winter: No change and for protection of DO standard
MA 10 mg/L (15A NCAC 2B .0200).
WA 15 mg/L
TSS MA 30 mg/L TBEL. Secondary treatment
WA 45 mg/L No change standards/40 CFR 133 / 15A
NCAC 213 .0406.
Summer: Summer:
MA 2.0 mg/L MA 1.0 mg/L
NHS-N WA 6.0 mg/L WA 3.0 mg/L WQBEL. Based on the current
Winter: Winter: WLA for protection of aquatic life.
MA 4.0 mg/L MA 1.8 mg/L
WA 12.0 mg/L WA 5.4 mg/L
DO > 6 mg/L No change WQBEL. For protection of the DO
standard (15A NCAC 213 .0200).
pH Between 6 and 9 SU No change WQBEL. WQ standard, 15A
NCAC 213 .0200.
Fecal Coliform MA 200/100 mL No ch
WQBEL. WQ standard, 15A
WA 400/100 mL ange
NCAC 213 .0200.
Total Residual Chlorine DM 17 µgiL No change WQBEL. 15A NCAC 213 .0200
Page 11 of 14

Temperature Monitor daily No change WQBEL. 15A NCAC 2B .0200,
.0500
Add instream 15A NCAC 2B.0500, added based
on the presence of an industrial
Conductivity Monitor daily monitoring upstream pretreatment program and the 2002
(DI and downstream Instream Conductivity and Fecal
(D1 and D2) Coliform Monitoring Guidance.
Monitor quarterly in WQBEL. 15A NCAC 2B.0200.
Chlorides conjunction with No change Reasonable potential found. EPA
Chronic Toxicity test allows action level,passing
chronic toxicity tests
MA 50 µg/L WQBEL. 15A NCAC 2B.0200.
Total Chromium DM 1033 µg/L Quarterly monitoring NPDES permitting guidance for
dissolved metals.
WQBEL. 15A NCAC 2B.0200.
Quarterly monitoring Reasonable potential to exceed
Chromium VI No requirement for two years; to be WQS found in RPA. NPDES
continued if detected permitting guidance for dissolved
metals.
WQBEL. 15A NCAC 2B.0200.
No reasonable potential found in
Total Copper Monitor quarterly No change RPA,but maximum predicted
value>50%of the allowable
concentration.
MA 5.0 µg/L WQBEL. 15A NCAC 2B.0200.
Cyanide No requirement DM 22.0 µg/L Reasonable potential to exceed
WQS found in RPA.
Remove from permit; WQBEL. Based on the statewide
Total Mercury MA 12 ng/L add Mercury 2012 TMDL; monitoring
DM 36 ng/L Minimization Plan conducted during PPAs and
(MMP) pretreatment LIMP.
Quarterly monitoring at WQBEL. 15A NCAC 2B.0200.
"Total Silver No requirement lower reporting level of No detects at<5 µg/L NPDES
procedure for permitting guidance for dissolved
pretreatment LTMP metals
WQBEL. 15A NCAC 2B.0200.
No reasonable potential found in
Total Zinc Monitor quarterly Remove from permit RPA,but maximum predicted
value<50%of the allowable
concentration.
WQBEL. EPA Nationally
Recommended Water Quality
Dibromochloromethane Monitor quarterly No change Criteria(NRWQC).No reasonable
potential found in RPA,but
maximum predicted value<50%
of the allowable concentration.
Page 12 of 14

Bromodichloromethane Monitor quarterly MA 31.6 /L WQBEL. EPA NRWQC.
µg Reasonable potential to exceed
criterion found in RPA.
Total Nitrogen Monitor monthly No change 15A NCAC 2B.0500; nutrient
g criteria development in the Upper
Cape Fear River Basin.
Total Kjeldahl Nitrogen Monitor monthl 15A NCAC 2B.0500; nutrient
Y No change criteria development in the Upper
Cape Fear River Basin.
Nitrate/Nitrite Nitrogen Monitor monthly No change 15A NCAC 2B.0500; nutrient
g criteria development in the Upper
Cape Fear River Basin.
Total Phosphorus Monitor monthly15A NCAC 2B.0500; nutrient
No change criteria development in the Upper
Cape Fear River Basin.
Limit based on NC calculated
surface water criterion to protect
1,4-Dioxane No requirement MA 149 µg/L human health in non-water supply
waters of 80 jig/L. Reasonable
potential to exceed criterion found
in RPA.
Quarterly
Chronic Toxicity Ceriodaphnia dubia WQBEL. No toxics in toxic
Pass/Fail at 90% No change amounts. 15A NCAC 2B.0200 and
effluent 15A NCAC 2B.0500
Effluent Pollutant Scan Three times per
permit cycle No change 40 CFR 122
Total Hardness No requirement Add effluent Revised water quality standards
's
monitoring and EPAguidelines on hardness
dependent metals.
Electronic Reporting No re uirement Add Electronic
q Reporting Special In accordance with EPA Electronic
Condition Reporting Rule 2015.
Nutrient Reopener for
TN and TP Special Condition No change Upper Cape Fear River nutrient
strategy requirement.
' MGD = Million gallons per day, MA=Monthly Average, WA=Weekly Average, DM=Daily Max.
13. Public Notice Schedule
Permit to Public Notice: mm/dd/2018
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
Page 13 of 14

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 Draft Permit was public noticed(Yes/No): NO
If Yes, list changes and their basis below: NA
15. Fact Sheet Attachments (if applicable)
• Pretreatment Information Request form, completed
• Effluent parameter trend charts and summary statistics
• Final 2014 NC 303(d) list,page 7
• Instream parameter trend charts and summary statistics
• Monitoring Report(MR)Violations page
• Whole Effluent Toxicity and Self-Monitoring Summary,page 6
• Compliance Evaluation Inspection reports,March 13,2017 and July 7, 2016
• IWC Calculations sheet(waste load allocation for TRC and N113-N)
• Ammonia-Nitrogen Effluent Evaluation chart
• RPA Spreadsheet Summary and dissolved to total metal calculator
• Effluent Copper Loading analysis
• Dissolved Metals Implementation—Freshwater Standards fact sheet memo
• Mercury WQBEL/TBEL evaluation
Page 14 of 14

ROY COOPER
MICHAFI- S. REGAN
Water Resources S. JAY 71 Al M F R 1�1 A N
L NVIRONMEN t AL DUAL'1y
October 31, 2017
Mr.John N. Ogburn, III
City Manager
City of Asheboro
P.O.Box 1106
146 N Church Street
Asheboro, NC 27204
Subject: Additional Monitoring Requirement
Asheboro WWTP
NPDES Permit No. NCO026123
Dear Mr. Ogburn,
As you are aware the state has been sampling and investigating sources of 1,4 dioxane in the
Cape Fear River Basin. Sampling performed downstream of the Asheboro WWTP has shown high levels
of this contaminant. Pursuant to 15A NCAC 02B .0505 and .0508 the Division is requiring permitted
POTWs to sample for 1,4 dioxane in their plants effluent once per month using the recently approved
EPA Test Method 624.1 promulgated in the 2017 Methods Update Rule.
Monthly effluent sampling for the Asheboro WWTP NCO047384 at Outfall 001 shall commence in
December 2017 and results shall be submitted on the POTW's Discharge Monitoring Reports.
To discuss test procedures and find a lab certified to perform this updated test method please contact
Dana Satterwhite, Environmental Program Supervisor III, at 919 733 3908 ext. 202 or via email at
dana.satterwhite(a,ncdenr eov.
If you have any questions,please contact me at [phone] or at my email address
jeff aoupart(a.=denr go%
Sincerely,
Jeff Poupart
Water Quality Permitting Section Chief
Division of Water Resources
cc: Jay Zimmerman, Director, DWR
Julie Grzyb,NPDES Complex Permitting, DWR
Mike Rhoney, Water Resource Director, Asheboro mrhoney(a,ciasheboro nc us
Michelle Dawes NII)AWES-a ci.ashebort).nc.us
Dana Satterwhite, Environmental Program Supervisor III, DWR dana.satterwhite(u ncdenr. rr
Chris Johnson, Water Sciences Section,DWR chris.iohnsoncu ncdenr %
George Smith, Assistant Regional Supervisor, DWR WSRO george.smith(aviicdenr go%
State of North Gerehr&—! Environmental Quality i Water Resources
1617 Mail Service Center Raleigh.Nonh Carolina 2 7699-1 6 1 7
919 707 9000

Weaver, Charles
From: Mike Wiseman <[e-mail]>
Sent: Friday, March 03, 2017 3:14 PM
To: Weaver, Charles
Subject: Re: likelihood of nutrient limits in NC0026123 renewal
Attachments: i mage001.png
Charles,
Thank you very much for looking in to this matter for me. The info you provided helps me out tremendously with future
planning. Hope you have a great weekend.
Thanks,
Mike Wiseman
Sent from my Verizon Wireless 4G LTE DROID
"Weaver, Charles"<[e-mail]>wrote:
Mike—I discussed the Cape Fear nutrient issues with Mike Templeton this morning. Mike is our in-house coordinator
for nutrient issues as they are handled in NPDES wastewater permits.
It is highly unlikely that the permit renewal for NC0026123 will contain nutrient limits. The existing nutrient rules were
challenged by the Legislature via HB 1030 last year, and the legal ramifications of that challenge have not been
resolved.. Furthermore, the Division's Scientific Advisory group is just now planning a review of Upper Cape Fear data.
The review may one day lead to a revised nutrient policy for the Upper Cape Fear, but not this year.
We commend you and your staff for the pilot nutrient removal program you have already attempted, and recommend
that you continue to explore means of nutrient reduction that can be achieved with the components already installed.
Let me know if you have additional questions.
Charles H. Weaver
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919-807-6391
[e-mail]<mailto:[e-mail]>
(physical address) 512 North Salisbury Street, Raleigh, NC 27604(mailing address) 1617 Mail Service Center, Raleigh, NC
27699-1617
[cid:image001.png@01D105A3.26AD88501
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
1

State of North Carolina
Division of Water Resources
Environmental Water Quality Regional Operations Section
Quality Staff Report
July 5,2016
To: NPDES Unit Permit No.: NCO026123
Attn: Charles Weaver Facility name: City of Asheboro
From: George Smith
Winston-Salem Regional Office R��IVED/NC�EQ/pyyR
JUL 12 2016
I. GENERAL AND SITE VISIT INFORMATION Pe water Qua1"
1. Was a site visit conducted?® Yes or No fmittin9 sect�lon
a. Date of site visit:June 29 2016
b. Site visit conducted by: George Smith&Justin Henderson
c. Inspection report attached? ® Yes or E3 No
d. Person contacted: Michael Wiseman contact information: (336)67_ 2-0892 ext.
e. Driving directions: H 421 220 south from Greensboro Pineview exit left on Pineview St., right at next
light, left on Hub Morris Rd left on Bonkemeyer Rd.
2. Discharge Point(s):
Latitude: 35'46' 0.4"N Longitude: 79'47' 5.8"W
3. Receiving stream or affected surface waters:
Classification: Haskett Creek, C
River Basin and Subbasin No.: Cape Fear; 03-06-09
Describe receiving stream features and pertinent downstream uses: Class C support use(rural use).
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: 4
(based on permitted flow)
Proposed flow: Does not apply. There are no new treatment units or modifications.
Current permitted flow: 9.0 MGD
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or® No
If no, explain: No new treatment units
3. Possible toxic impacts to surface waters: None
4. Pretreatment Program(POTWs only): Program is operated in an excellent manner. Coordinator is Michelle
Dawes
III.EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1• Are there appropriately certified Operators in Charge(ORCs) for the facility?® Yes ❑No N/A
ORC: Michael Wiseman Certificate#: 987680 Backup ORC: ChrSchad t Certificate #: 13500
FORM: WQROSSR 04-14
Pagel of 2

2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or❑No
If no,please explain:
Description of existing facilities: same as described in the current permit.
Proposed flow:N/A
Current permitted flow: 9.0 MGD
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know(i.e.,equipment condition, function, maintenance, a change in facility ownership,
etc.)
See attached CEI
3. Is the description of the facilities as written in the existing permit correct? ® Yes or❑No
If no,please explain: Check all that apply:
®No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑Notice(s)of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments(i.e.,NOV,NOD, etc.)
Attached CEI
4. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No ❑N/A
If yes, please explain:
5. Possible toxic impacts to surface waters:None
6. Pretreatment Program(POTWs only): operated in an excellent manner
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The facility is operated in an excellent manner.
V. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or® No
If yes,please explain:
2. Recommendation: ❑Hold, pending receipt and review of additional information by regional office
❑ Hold,pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
® Issue
❑ Deny(Please state reasons: )
3. Signature of report preparer:
Signature of regional supervisor:
Date: 7 G
FORM: WQROSSR 04-14 Page 2 of 2

PAT -Nf CRORY
DONALD R. VAN DER VAART
" �c�I:•r�r.
Water Resources S. JAY Z I M M E R M A N
ENVIRONMENTAL QUALITY
Pinc!nr
July 7, 2016
Mr. Michael D. Rhoney, Water Resources Director RECEIVED/NCDEQ1DWR
City of Asheboro
P.O. Box 1106 JUL 12 1016
Asheboro, NC 27204 Water oua►i
Permitting 8ect�
SUBJECT: Compliance Evaluation Inspection(CEI)
City of Asheboro WWTP
NPDES Permit No. NCO026123
Randolph County
Dear Mr. Rhoney:
On June 29, 2016, Justin Henderson and George Smith, both of this office, met with Mike
Wiseman,Operator in Responsible Charge(ORC),to perform a Compliance Evaluation Inspection
at the City of Asheboro's wastewater treatment facility. This type of inspection consists primarily
of two parts: an in-office review of facility files and self-monitoring data and an on-site inspection
of the facility and its files. This particular inspection evaluated nine (9) areas, and observations
from each area are addressed below:
Permit
A copy of the current NPDES permit was available on site for review during the inspection. The
current permit became effective August 1, 2012 and expires September 30, 2016.
The 9.0 MGD facility consists of six rectangular primary clarifiers, three trickling filters, four
secondary clarifiers, two aeration basins, a tertiary sand filter system, and three final clarifiers.
The plant has two anaerobic digesters, a sludge press, and drying beds. One circular primary
clarifier is used to store press filtrate. The facility has a 600kW generator that has capability to
operate the entire plant during a power outage. The generator is tested for one hour each month
under load. Asheboro is under a contract with Randolph Oil to supply fuel.
Self-Monitoring Program
Monthly Discharge Monitoring Reports (DMRs) were reviewed for the period November 2015
through March 2016. The facility was found to be in compliance with all effluent limits and
reporting requirements during this time period. All sampling was performed per the frequencies
specified in the permit. Daily composite sampling is required at this facility.
Flow proportioned composite samples are pumped directly into the laboratory where they are
collected into refrigerated containers at 4.6 'C. Effluent sampling is performed by a now
proportional method at 200 mL every 100,00 gallons (40 pluses).
State of North Carolina I Environmental Quality I Water Resources
450 West Hanes Mill Road.Suite 300,Winston-Salem,NC 27105
Phone:[phone] l Internet:www.ncdenr.gov

Data verification was performed for the effluent: BOD, Ammonia,Fecal Coliform on the January
2016 DMR. There were no errors.
Laboratory
The City of Asheboro has an on-site laboratory at the plant, which performs most of the analyses
for permitting purposes. Other parameters are performed by Pace Analytical (Chronic Toxicity)
and Environment One (annual pollutant analysis).
Flow Measurement
An ultrasonic meter is used to report effluent flow on the monthly DMRs. Instrumentation
Services, Inc. calibrates the effluent flow meter quarterly. The last calibration was performed on
April 7, 2016, and documentation was available upon request.
Operations & Maintenance
Operator in Responsible Charge is Mike Wiseman (Grade IV); Back-Up ORC is Chris Schadt
(Grade IV).
Sodium hypochlorite is added along the weirs of the final clarifiers. Sodium bisulfate is added in
the chlorine contact chamber for dechlorination prior to discharge.
The plant accepts process sugar water from Malt-O-Meal Brands (a local cereal manufacturer)to
assist with Biological Nutrient Removal.
The facility monitors the microorganisms on a frequent basis to documents the operations of the
plant.
The MLSS is approximately 2300 mg/L. The dissolved oxygen in the aeration basins is 1.25 to
1.758 mg/L. The blankets in the 15-foot deep clarifiers are 2 feet
The facility appeared to be competently operated and extremely well maintained. No concerns or
problems were noted.
Facility Site Review
There are two Archimedes screws at the influent lift station, both are operational. The Duperon
automatic 3/8 inch barscreen is working very well. Grit removal is consisting of a vortex with an
air lift to a hopper. All are in good working order.
The six (6)primary rectangular, which are sequentially scraped. They are on timers. There is one
(1) circular clarifier.
The three (3) trickling filters have a good coating of biological mass and there is an even
distribution of wastewater.

The secondary clarifiers are discharging a clear effluent with no solids. The effluent is pumped
with four 75 horse power pumps to the aeration basins. The pumps have no seal leaks and are in
good order.
The circular aeration basins have a traveling arm with fine bubble diffusers. There is no foam, no
odor, and good flocking.
The instantaneous flow at the time of the inspection was 3.1 MGD.
Records/Reports
The Discharge Monitoring Reports (DMRs), field sheets, chain of custody forms, and lab data are
kept and maintained according to the permit. All required information was readily available,
complete, and current.
The following logs are maintained: Operators,Preventive Maintenance,Lab Tests(time of sample
receipt/ analysis), Chemical Inventory, Process (documents performance of each treatment unit).
These are considered to be excellent forms of documentation.
The Annual Performance Report for calendar year 2015 was prepared as required, and a copy was
available during the inspection.
Effluent/Receiving Waters
The effluent is discharged into Hasketts Creek(Class C)in the Cape Fear River Basin. The effluent
appeared clear with no traceable solids. The creek appeared to have no impacts.
Sludge Handling & Disposal
Solids from the anaerobic digester are dewatered by the on-site belt press prior to land application
covered under permit WQ0001684. EMA Resources land applied residuals from the facility.
The inspected facility was found to be in compliance. Mr. Wiseman and his staff operate the
facility in an outstanding manner. Please refer to the attached checklist for specific details. If you
have any questions concerning this report, please contact Justin Henderson or me at (336) 776-
9800.
Sincerely,
CY �C� cal
'�/Sherri V Knight, PE, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
cc: WSRO Files
NPDES Unit—Charles Weaver

United States Environmental Protection Agency
EPAWashington,D.0 20460 Form Approved.
040-0057
Water Compliance Inspection Report OMB Approval
expires 8-3
p pproval expires 8-31-96
Section A: National Data System Coding(i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type
1 In' I P YP Inspector Fac Type
u 2 u 3 L NC0026123 I11 12 1s/os/z9 17 18 ,.i 19 t � , 20
21 Li
�J
I I1 1 1 1 1 1 1 1 1 1 1 16
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1
67 CIA — Reserved —
70 Idu 71 t I 72 t „ I 73I I I74 75 80
Section B: Facility yDData
u I I I
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date
POTW name and NPDES Permit Number) Permit Effective Date
Asheboro WWTP
08:15AM 16/06/29 12/08/01
1032 Bonkemeyer Dr Exit Time/Date Permit Expiration Date
Asheboro NC 27203 10.30AM 16/06/29 16/09/30
Name(s)of Onsite R epresentative(s)/Titles(s)/P hone and Fax Number(s)
Other Facility Data
Michael Ray Wiseman/ORC/336-672-0892/
Name,Address of Responsible Official/Title/Phone and Fax Number
John N Ogburn,PO Box 1106 Asheboro NC 272041106H336-626-1213/3366261218 Contacted
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
Permit Flow Measurement
Operations&Maintenanc6 Records/Reports
Self-Monitoring Program Facility Site Review
Effluent/Receiving Waters
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signatures)of Inspector(s)
Agency/Office/Phone and Fax Numbers Date
Justin L henderson WSRO WQ//336-776-9701/
Signature of Management Q A Reviewer
Agency/Office/Phone and Fax Numbers
Date
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

Permit: N00026123 Owner-Facility. RsheboroWWfP
Inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new M ❑ ❑ ❑
application?
Is the facility as described in the permit? 0 ❑ ❑ ❑
#Are there any special conditions for the permit? ❑ ❑ 0 ❑
Is access to the plant site restricted to the general public? M ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? M ❑ ❑ ❑
Is all required information readily available, complete and current? 0 ❑ ❑ ❑
Are all records maintained for 3 years(lab. reg. required 5 years)? 0 ❑ ❑ ❑
Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑
Is the chain-of-custody complete? M ❑ ❑ ❑
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? 0 ❑ ❑ ❑
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? 0 ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification? M ❑ ❑ ❑
Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑
Page# 3

Permit: NC0026123 Owner•Facility: Asheboro WWTP
Inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review?
Comment:
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting?
Is flow meter calibrated annually? 0 ❑ ❑
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter? El El El 0
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual ■
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance? El El 0 0
Is the unit in good condition?
Comment:
Grit Removal Yes No NA NE
Type of grit removal
a.Manual El
b.Mechanical
Is the grit free of excessive organic matter? 0
Is the grit free of excessive odor? 0
#Is disposal of grit in compliance?
Comment:
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? 0 El El 0
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level? ■
El El D
Page# 4

Permit: NC0026123 Owner-Facility: Asheboro WVVfP
Inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation
Primary Clarifier Yes No NA NE
Is the site free of weir blockage? N ❑ ❑ ❑
Is the site free of evidence of short-circuiting? ❑ ❑ ❑
Is scum removal adequate? ❑ ❑ ❑
Is the site free of excessive floating sludge? ❑ ❑ ❑
Is the drive unit operational? 0 ❑ ❑ ❑
Is the sludge blanket level acceptable? ❑ ❑ ❑
Is the sludge blanket level acceptable?(Approximately%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? M ❑ ❑ ❑
Are weirs level? M ❑ ❑ ❑
Is the site free of weir blockage? 0 ❑ ❑ ❑
Is the site free of evidence of short-circuiting? M ❑ ❑ ❑
Is scum removal adequate? M ❑ ❑ ❑
Is the site free of excessive floating sludge? 0 ❑ ❑ ❑
Is the drive unit operational? 0 ❑ ❑ ❑
Is the return rate acceptable(low turbulence)? ❑ ❑ ❑ M
Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑
Is the sludge blanket level acceptable?(Approximately%of the sidewall depth) 0 ❑ ❑ ❑
Comment:
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:
Page# 5

Permit: NCO026123 Owner-Facility: Asheboro WWTP
Inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation
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? ❑ ❑ 0 ❑
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? N ❑ ❑ ❑
Is the DO level acceptable? N ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/1) 0 ❑ ❑ ❑
Comment:
De-chlorination Yes No NA NE
Type of system ? Liquid
Is the feed ratio proportional to chlorine amount(1 to 1)? ❑ 0 ❑ ❑
Is storage appropriate for cylinders? ❑ ❑ 0 ❑
# Is de-chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑
Comment: 10:1 chlorine to de-chlor
Are the tablets the proper size and type? ❑ ❑ E ❑
Are tablet de-chlorinators operational? ❑ ❑ E ❑
Number of tubes in use? 0
Comment: no comment
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? ❑ ❑ ❑ 0
Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑
Is there chlorine residual prior to de-chlorination? ❑ ❑ ❑
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? N ❑ ❑ ❑
Page# 6

Permit: NCO026123 Owner-Facility: Asheboro WWTP
Inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Is sample collected below all treatment units? 0 ❑ ❑ ❑
Is proper volume collected? M ❑ ❑ ❑
Is the tubing clean? N ❑ ❑ ❑
#Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑
Celsius)?
Is the facility sampling performed as required by the permit(frequency, sampling type 0 ❑ ❑ ❑
representative)?
Comment:
Page# 7