NC0026441_Permit Issuance_20140430

rCENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 30, 2014
Mr. Bryan Thompson
Town Manager
Town of Siler City
P.O. Box 769
Siler City, North Carolina 27344-0769
Subject: Renewal of Permit No. NCO026441
Siler City WWTP
Chatham County
Dear Mr. Thompson:
John E. Skvarla, III
Secretary
The Division of Water Resources (Division) personnel have reviewed and approved your application for
issuance of the subject permit renewal. Accordingly, we are forwarding the attached NPDES discharge
permit. It is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated
October 15, 2007, or as subsequently amended.
This permit renewal has the following changes from your current permit:
1. The permit expiration date has been changed to May 31, 2019 in order to provide a full 5 year
permit life. The next renewal in 2019 will likely be for a shorter time in order to get your permit
back on the Cape Fear basin schedule.
2. Removed old Condition A.(3) regarding Nutrient Optimization Plan, as it has been completed.
Replaced with a new Nutrient Reopener Condition (A.(3) with trigger mechanism for evaluation
of any future high nutrient -bearing industries.
3. Added a new Nutrient Water Quality Modeling Reopener Condition in accordance with the
Basin Plan. See Condition A.(4).
4. Added Monthly Monitoring for Cadmium with new Monthly Average and Daily Maximum
limits, based on statistical analysis of LTIVIP data. Cadmium had previously been monitored
only on the LTMP. Also included an 18 month Compliance Schedule to Effluent Sheet A(1) and
detailed in Condition A.(6).
5. Added a new Electronic DMR Submittal Requirement (Condition A(7)). This requirement is
being added to all NPDES permits upon renewal.
6. Updated language for Effluent Pollutant Scan -Condition A(9)- to require three scans in
specified years in accordance with EPA requirements. In addition, as a reminder added language
regarding additional toxicity testing data required by US EPA for submission with the next
permit renewal.
7. Copper, Zinc, and chloride data showed reasonable potential to exceed action level standards.
Per Action Level Policy, monitoring will remain in the permit with no limits, provided facility
continues to pass the toxicity test. Monitoring will be changed to quarterly in accordance with
the Division's Permitting Strategy for metals and toxicants
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper

Page 2 of 3
April 30, 2014
.j
8. There were some minor permit changes. Changed "Division of Water Quality" to "Division of
Water Resources" to reflect reorganization. On Supplement to Cover Sheet, updated the
equipment description on Permit. Some permit conditions were renumbered.
9. Added a new requirement A.(5) for a Mercury Minimization Plan (MMP) as required by the
Implementation Plan for the Statewide Mercury TMDL. The plan must be developed within six
months of the permit effective date.
10. Updated Chronic Toxicity language to current version (see Condition A(8))..
As indicated, an electronic DMR submission requirement was added to your permit. Proposed federal
regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the Environmental Protection Agency (EPA). The Division anticipates that these
regulations will be adopted and is beginning implementation. The requirement to begin 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 Special Condition A (7)] For
information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following
web page:
hU://portal.ncdenr.org/web/wg/admin/bog//ipu/edmr.
For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the following web site:
hU://www2.epa. ovg /compliance/proposed-npdes-electronic-reportin -rule.
During the public comment period, comments were received from community environmental groups (Friends
of Rocky River, Rocky River Heritage Foundation) as well as the North Carolina Wildlife Resources
Commission, expressing interests in protecting and restoring the downstream Rocky River ecosystem. These
waters are listed as impaired on the State 303(d) impaired waters list, and there are records for the federally
endangered Cape Fear shiner. Some concerns focused on the operation and maintenance of the wastewater
treatment plant. Please note that permit requirements specified in Part II, Section C(2) require the Permittee
to at all times properly operate and maintain all facilities and systems of treatment and control (and related
appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of the
permit. Some concerns also focused on nutrient loading from this wastewater treatment plant. The Division
recognizes that nutrient loading from this facility has decreased substantially with the closure of two poultry
operations. In that regard, a Nutrient Reopener Condition (A(3)) was added to address the possibility for
another high nutrient -bearing industry to relocate to this service area in the future. The Division also notes
that the Middle Cape Fear River has been identified as a site -specific high priority waterbody in the Draft
North Carolina Nutrient Criteria Development Plan (January 24, 2014), which will result in additional
nutrient studies and future nutrient management strategies.
The effective date of this permit is June 1, 2014
If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable,
you have the right to an adjudicatory hearing upon written request within thirty (30) days after receiving this
letter. Your request must take the form of a written petition conforming to Chapter 150B of the North
Carolina General Statutes, and must be filed with the Office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such demand is made, this permit remains final and
binding.
This permit is not transferable except after notifying the Division of Water Resources. The Division may
modify and re -issue, or revoke this permit. Please notice that this permit does not affect your legal obligation

Page 3 of 3
April 30, 2014
to obtain other permits required by the Division of Water Resources, the Division of Land Resources, the
Coastal Area Management Act, or other federal or local governments.
If you have questions, or if we can be of further service, please contact Tom Belnick at
[e-mail] or call [phone].
Sincerely,
omas A. Reeder, Director
Division of Water Resources, NCDENR
Attachments: NC0026441 Renewal
Hardcopy:
DWR/Raleigh Regional Office- Danny Smith
NPDES File
Central Files
Email Copy:
US EPA Region 4—[e-mail]
DWR/ESS/Aquatic Toxicology Unit- Attn: Susan Meadows
DWR/PERCS Unit - Sarah Morrison
NC WRC- Ms. Shari L. Bryant,- shari.bryant(@,ncwildlife.org
McGill Associates- Forrest Westall - [e-mail]
Mr. John D. Runkle, Attorney at Law - [e-mail]
Rocky River Heritage Foundation and Friends of the Rocky River- Mr. Sonny Keisler -
[e-mail]
Ms. Connie Allred - [e-mail]
[e-mail]
William Hendrick, SELC, [e-mail]

Permit NCO026441
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
NPDES PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PDES
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, the
Town of Siler City
is hereby authorized to discharge wastewater from a facility located at the
Town of Siler City WWTP
370 Waste Treatment Plant Road
Chatham County
to receiving waters designated as Loves Creek within the Cape Fear River Basin, in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, %III and IV hereof.
This permit shall become effective June 1, 2014.
This permit and authorization to discharge shall expire at midnight May 31, 2019.
Signed this day April 30, 2014.
( . M j
mas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission

Permit NCO026441
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any
previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this
facility arises under the permit conditions, requirements, terms, and provisions included herein.
The Town of Siler City is hereby authorized to:
1. Continue discharging 4.0 MGD of treated process and domestic wastewater from a treatment facility
consisting of
• Automatic and manual bar screens
• Grit collection unit
• Influent pump station
• Influent Equalization Basin (Zone 2)
• Dual oxidation ditches with surface jet aeration
• Flow Splitter Box
o Alum feed station
o Lime feed station
• Dual secondary clarifiers
• Dual Aerobic digesters
• Return Activated Sludge
• Sludge Transfer Station
• Dissolved Air Flotation Unit (Used as needed)
• Sludge Thickener Basin
• Influent equalization or Sludge Storage Basins (Zone 3 A & B used as needed)
• Four (4) tertiary filters
• Filter Backwash Basin
• Gaseous Chlorine Disinfection
• Chlorine contact chamber
• Gaseous Sulfur dioxide Dechlorination
• Step -Aeration
This facility is located at the Siler City WWTP at 370 Waste Treatment Plant Road near Siler City in Chatham
County.
2. Discharge from said wastewater treatment works through Outfall 001 into Loves Creek (see attached map), a
stream classified as C waters within the Cape Fear River Basin.
Page 2 of 10

Permit NCO026441
Part I
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
a. During the period beginning with the effective date and lasting until expiration, the Permittee is authorized to discharge
treated wastewater through Outfall 001. Such discharges shall be limited and monitored' by the Permittee as specified below:
PARAMETERS
EFFLUENT 111ZITS
MONITORING REQUIRE_ MENTS
Monthly
Average
;Weekly
Averse
Daily
Maximum
.Measurement ;
Fre uenc
,Sampley
Type e
'_-Sample
.-Locations f
Flow
4.0 MGD
Continuous
Recordingwent
or
Effluent
BOD, 5 day, 20°C
(April 1 thru October 31
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent and
Effluent
BOD, 5 day, 20°C
(November 1 thru March 31
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent and
Effluent
Total Suspended Solids3
30.0 mg/L
45.0 mg/L
Daily
Composite
Effluent nt d
NH3 as N
(April 1 thru October 31)
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
NH3 as N
ovember 1 thru March 31
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
Fecal Coliform
(geometric mean)
200/ 100 ml
400/ 100 ml
Daily
Grab
Effluent
Total Residual Chlorine (TRC)4
17 µg/L
Daily
Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
Dissolved Oxygen
Daily average > 6.0 mg/L
Daily
Grab
Effluent
pH
> 6.0 and < 9.0 standard units
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 + TKN)
.
Weekly
Calculated
Effluent
NO3 N + NO2 N (mg/L)
Weekly
Composite
Effluent
TKN (mg/L)
T
Weekly
Composite
Effluent
Total Phosphorus
(April 1 thru September 30
0.5 mg/L (quarterly average)
Weekly
Composite
Effluent
Total Phosphorus
October 1 througli March 31
2.0 mg/L (quarterly average)
Weekly
Composite
Effluent
Total Cadmium 6
2.1 µg/ L
15.5 µg/ L
Monthly
Composite
Effluent
Total Copper
Quarterly'
Composite
Effluent
.Total Zinc
Quarterly'
Composite
Effluent
Chloride
Quarterly
Composite
Effluent
Chronic Toxicity$
Quarterly
Composite
Effluent
Effluent Pollutant Scan
Monitor and Report
Footnote 9
Footnote 9
Effluent
Footnotes:
1. No later than March 1, 2015, begin submitting discharge monitoring reports electronically using NC DWR's eDMR
application system. See Condition A. (7).
2. Instream monitoring shall be performed in accordance with Condition A. (2).
3: The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15 % of the respective
influent value (i.e., 85% removal is required).
4. TRC limits and monitoring requirements apply only if chlorine or chlorine derivatives are used for disinfection. The
Permittee shall report all effluent TRC values reported by a NC -certified laboratory [including field -certified]. Effluent
values below 50 µg/L will be treated as zero for compliance purposes.
5. Compliance with the Total Phosphorus limits shall be based on a calendar -quarter average of weekly samples.
6. Total Cadmium limits become effective December 1, 2015. Monitoring shall begin on the effective date. See
Condition A. (6).
Page 3 of 10

Permit NCO026441
Footnotes A.(1) Continued:
7. Sample Quarterly in conjunction with Chronic Toxicity Test.
8. Chronic Toxicity (Ceriodaphnia) at 90 %; quarterly during March, June, September, December [see Condition A. (8)].
9. The permittee shall perform three Effluent Pollutant Scans during the term of this permit [see Condition A. (9)].
b. Effluent shall contain no floating solids or foam visible in other than trace amounts.
A. (2) INSTREAM MONITORING REQUIREMENTS
Parameter
Sample Type
Location
Measurement Frequency 2
Dissolved Oxygen
Grab
LCU, LCD, RRU, RRD
3/Week (June — September),
1/Week October -Ma
Temperature
Grab
LCU, LCD, RRU, RRD
3/Week (June — September),
l/Week (October -Ma
Total Phosphorus
Grab
LCU, LCD, RRU, RRD
Monthly
TKN
Grab
LCU, LCD, RRU, RRD
Monthly
NO3 N + NOZ N
I Grab
LCU, LCD, RRU, RRD
Monthly
Footnotes:
1. LCU - Loves Creek, upstream of the discharge; LCD - Loves Creek, downstream of the discharge and above the
confluence with the Rocky River; RRU — Rocky River, upstream of the confluence with Loves Creek; RRD — Rocky
River, downstream of the confluence with Loves Creek.
2. All monitoring is required to be performed at the above -mentioned monitoring locations. Instream Monitoring
may be performed by the Upper Cape Fear River Basin Association as outlined in the Memorandum of Agreement
(MOA) between the association and the permittee. If so, the data is to be collected and submitted to DWR in
accordance to the terms of the MOA. Should membership in this association terminate for any reason, the permittee
shall immediately notify the Division's NPDES Unit in writing and resume responsibility to monitor and report the
above parameters as specified in this permit.
A. (3) NUTRIENT REOPENER
In the event that Permittee proposes to accept future industrial process wastewater that is expected to contain
concentrations of Total Nitrogen (TN) and/ or Total Phosphorus (TP) greater than typical domestic wastewater
concentration (i.e. greater than 40.0 mg/ L TN or greater than 5.0 mg/ L TP), the Permittee shall notify the NPDES
Complex Permitting Unit of the Division at 1617 Mail Service Center, Raleigh, NC 27699 and the Raleigh
Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 within 30 days of knowledge that the town is
considering accepting new industrial process wastewater containing excess nutrients. The notification shall contain
information regarding the proposed discharge flow, composition and treatability in the Siler City WWTP. Changes
in effluent characteristics may require a permit modification, so notification should be at least 180 days prior to the
start of the proposed discharge.
Based on information provided by the Town regarding a potential new industrial process wastewater with high
nutrient concentration, and pursuant to N.C. General Statute Section 143-215.1 and the implementing rules found in
Title 15A of the North Carolina Administrative Code, Subchapter 2H, specifically, 15A NC AC 2H.0112(b) (1) and
2H.0114(a), and Part H, Sections B-12 and B-13 of this permit, the Director of DWR may then reopen this permit
to require supplemental nutrient limits for Total Nitrogen and/ or Total Phosphorus in accordance with the current
Basin Plan for the Cape Fear River Basin.
Page 4 of 10

Permit NCO026441
A. (4) NUTRIENT WATER QUALITY MODELING REOPENER
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 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 or modified in this permit upon renewal.
A. (5) MERCURY MINIMIZATION PLAN (MMP)
The permittee shall develop and implement a mercury minimization plan (MMP) during this permit term. The
MIVT shall be developed by December 1, 2014, 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
(http://portal.nedenr.or web/wq/swp/ps/npdes, under Model Mercury Minimization Plan). 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.
A. (6) COMPLIANCE SCHEDULE FOR TOTAL CADMIUM LIMITS
The effluent limits for Total Cadmium shall become effective on December 1, 2015. Monitoring shall begin on the
permit effective date. Effluent limits and monitoring may be deleted in the future upon written notification of the
Division, if the Permittee provides updated effluent data that shows no reasonable potential to exceed applicable
State water quality standards. Specifically, if 12 monthly data points for cadmium are all less than 2.0 µg/ L, then
the Permittee may petition the Division for removal of Total Cadmium limits and monitoring from the permit.
A. (7) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify
that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will
be adopted and is beginning implementation in late 2013.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
Page 5 of 10

Permit NCO026441
1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)1
Beginning no later than March 1, 2015, the permittee shall begin reporting discharge monitoring data
electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application,
unless a temporary waiver from eDMR requirements has been granted.
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 DENR / DWR / Information Processing Unit
ATTENTION: Central Files / eDMR
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.
Requests for temporary waivers from the NPDES electronic reporting requirements 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 using eDMR. Temporary waivers shall be valid for twelve (12) months and
shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the
permittee re -applies for and is granted a new temporary waiver by the Division.
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page:
http://portal.nedenr.or. web/wq/admin/bog/ipu/edmr.
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.
2. 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 II, Section B.
(I 1.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11.)(b). A
person, and not a position, must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and
login credentials to access the eDMR system. For more information on North Carolina's eDMR system,
registering for eDMR and obtaining an eDMR user account, please visit the following web page:
hiip://portal.ncdenr.org/web/wq/admin/boglipu/edmr.
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Permit NCO026441
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 qualifiedpersonnelproperly 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. "
3. Records Retention [Supplements Section D. (Q]
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].
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Permit NCO026441
A. (8) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to at an effluent
concentration of 90%.
The permit holder shall perform at a minimum, guarterlx monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions or "North Carolina
Phase H 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 NI DES 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 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 TGP3B for the pass/fail results and THP3B
for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental 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 Environmental 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 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.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such monitoring shall be
included in the calculation & reporting of the data submitted on the DMR & all AT Form submitted.
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 8of10

Permit NCO026441
A. (9) EFFLUENT POLLUTANT SCAN
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: 2016, 2017, and 2018. 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)
Trans-1,2-dichloroethylene
Bis (2-chloroethyl) ether
Chlorine (total residual, TRC)
1, 1 -dichloroethylene
Bis (2-chloroisopropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite
1,3-dichloropropylene
4-bromophenyl phenyl ether
Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Phosphorus
Methyl chloride
4-chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
1,1,2,2-tetrachloroethane
Di-n-butyl phthalate
Antimony
Tetrachloroethylene
Di-n-octyl phthalate
Arsenic
Toluene
Dibenzo(a,h)anthracene
Beryllium
1,1,1-trichloroethane
1,2-dichlorobenzene
Cadmium
1,1,2-trichloroethane
1,3-dichlorobenzene
Chromium
Trichloroethylene
1,4-dichlorobenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid -extractable compounds:
Diethyl phthalate
Mercury (EPA Method 1631 E)
P-chloro-m-cresol
Dimethyl phthalate
Nickel
2-chlorophenol
2,4-dinitrotoluene
Selenium
2,4-dichlorophenol
2,6-dinitrotoluene
Silver
2,4-dimethylphenol
1,2-diphenylhydrazine
Thallium
4,6-dinitro-o-cresol
Fluoranthene
Zinc
2,4-dinitrophenol
Fluorene
Cyanide
2-nitrophenol
Hexachlorobenzene-
Total phenolic compounds
4-nitrophenol
Hexachlorobutadiene
Volatile organic compounds:
Pentachlorophenol
Hexachlorocyclo-pentadiene
Acrolein
Phenol
Hexachloroelhane
Acrylonitrile
2,4,6-trichlorophenol
Indeno(1,2,3-cd)pyrene
Benzene
Base -neutral compounds:
Isophorone
Bromoform
Acenaphthene
Naphthalene
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chlorobenzene
Anthracene
N-nitrosodi-n-propylamine
Chlorodibromomethane
Benzidine
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3,4 benzofluoranthene
Pyrene
Dichlorobromomethane
Benzo(ghi)perylene
1,2,4-trichlorobenzene
1,1-dichloroethane
Benzo(k)fluoranthene
1,2-dichloroethane
Bis (2-chloroethoxy) methane
Reporting. Test results shall be reported on DWR Form -A NM PPA1 (or in a form approved by the Director) by
December 31" of each designated sampling year. The report shall be submitted to the following address: NC
DENR / DWR / Central Files,1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Page 9of10

Permit NCO026441
Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please notelhat 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). The US EPA requires four (4) toxicity
tests for a test organism other than the test species currently required in this permit. The multiple 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. These tests shall
be performed for acute or chronic toxicity, whichever is specified in this permit. The multiple species toxicity test
results shall be filed with the Aquatic Toxicology Branch at the following address:
North Carolina Division of Water Resources
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 10 of 10

Town of Siler City WWTP
Latitude:
35'43'45"N
State Grid/Quad:
E21NW/Siler Cily,NC
Longitude:
79025' 42" W
Permitted Flow:
4.0 MGD
Receiving Stream:
Loves Creek
Drainage Basin:
Cape Fear River Basin
Stream Class:
C
Sub -Basin:
03-06-12
IIUC:
030300030503
Facility
Location
rmV to -sau'Ib
North NPDES Permit No. NCO026441
Chatham Count

SUr1 ovfi11) MAAIW Z014 1K2n-eWA I
NCDENR/DWR
e
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NCO026441 Siler City WWTP
Facility Information
Facility Name:
SilerCityWWTP
County:__
Chatham County _..
Permuted Flow MGD:
4.0 MGD
Regional Office__
Raleigh
---.-.- _
Faculty Class
W W IV
USGS Topo Quad
E2INW
Pretreatment Program
--
Ful] LTMP
USGS Quad Name:
i Siler City
Permit Status:
- Expired/ Renewal
Stream Characteristics
_Receiving Stream:
Loves Creel:..
(Drainage Area (mi''):
''. 7.9
River Basin:
Cape Fear
Sub -basin: -
03-06 12
—
Summer7Qj_0Acfs):-1
0.25
Stream Assessment Unit
17 43 1Oc ..-.-..
Winter 7 10_(efsL
0 4
Stream Classdicatron:
I C
� 30Q2_(cfs):
303(d) Status:
Listed on Final 2012
Average Flow efs :
8.7
303(d) list for Aquatic life
1IWC %:
€ 96.1
- Impaired biological
;__ ..... ...... _.............................................
- — -
integrity Benthos.
HUC:
i 030300030503
Sumrnarv:
The Siler City WWTP is rated at 4.0 MGD. It is an activated sludge secondary treatment system with
tertiary filtration. The plant serves 7,877 people along with commercial and one SIU - Brookwood
Farms, Inc. Siler City has lost most of it's industries over the past few years, loosing two major chicken
processing facilities and one textile facility. The lost industry represented over 1 MGD of wastewater,
and five million dollars per year City Water demand. Loss of industries, and the population and
revenue from them, has severely impaired the Town's finances.
The WWTP discharges into Loves Creek, which is a tributary to Rocky River, which in turn flows into
the Deep River before it joins the Haw River to form the Cape Fear River. Loves Creek and Rocky
River have experienced problems with high nutrients, algae, Low Dissolved Oxygen and Periphyton for
many years. The Siler City WWTP is the only Major WWTP in this part of the Cape Fear basin, but it
is not the only source of nutrients, as Loves Creek is impaired above the discharge as well as below,
Rocky River is also impaired for chlorophyll- a above the confluence with Loves Creek.
The 2012 303(d) final list of Impaired Waters lists Loves Creek as Impaired for Ecological/ biological
Integrity Benthos from the source to Chatham Avenue. Loves Creek is listed as Impaired for Low
Dissolved Oxygen from Chatham Avenue to the Siler City WWTP, and is listed as Impaired for
Ecological] biological Integrity Benthos from the WWTP to Rocky River. The current Cape Fear Basin
Plan gives potential sources as stormwater (MS4 NPDES) and the WWTP. The basin plan goes on to
state "a stressor study completed in the Loves Creek watershed indicated toxic chemicals in runoff from
Siler City are the main stressors to the benthic community. Streambank erosion, sedimentation, and
excessive algal growth are also stressors. The WWTP was not the main stressor, and agricultural land
uses are also a source. The study noted runoff from animal operations in the upper watershed might be
contributing nutrients and bacteria to the creek." The basin plan recommends that the Division continue
r{ b p)_w - Final PFiotd wA� o✓limall) SA {o ✓goo�Jn o•4 3131/Z01`1; J,3,,j o�M{
'IU If✓M'� Wri}Ll�[M /1�c��t1 lt�5✓tNtsw��%rlq�l't✓MiT WGr ✓lo% I»Nrb(
Nhbl q/3of1A114 S;OM-(Shim{" rt Wf✓-f MOW, Ae,,/"ill A(L%dvltTv✓i�i►�
See (?Wei Le641 �6#14 PerMi1,-TOMBefhttK

NPDES Permit Fact Sheet Siler City WWTP
Page 2 NCO026441
to monitor the Loves Creek watershed and work with DSWC to evaluate if BMPs can be implemented
to reduce nutrients from animal operations in the watershed.
The 2012 303(d) final list of Impaired Waters lists Rocky River in the Upper Siler City Reservoir to the
dam as Impaired for Chlorophyll -a and Low Dissolved Oxygen. From the lower Siler City Reservoir
dam to Varnal Creek, Rocky River is listed as Impaired for Low Dissolved Oxygen. Rocky River is
listed as Impaired for Chlorophyll -a behind Woody's Dam. The current Basin Plan states "The Siler
City WWTP, as well as agriculture and residential activities, are potential sources of nutrients."
The Siler City WWTP currently has total phosphorus and ammonia limits that are more stringent than
those of many similar facilities statewide. Total Nitrogen and Nitrate -Nitrogen levels in the WWTP
effluent have decreased greatly after the closure of the two poultry processing plants in 2008 and 2011,
but remain higher than they should be. The facility has been encouraged to implement any simple
process changes to denitrify and reduce NO3-N in the effluent.
Data Review:
Monthly average DMR data was reviewed for the period of January 2011 through April 2013. That
data is summarized below in Table 1. Monthly average flows are at 39% of permitted capacity
with maximum monthly average flows at 54% capacity.
Table 1: Summary of Monthly Average DMR data-1/2011-4/2013
.
-
_
Eecali
L 1
a
rRaw
�p
c
x�r
TI S i
c J0a;
gym'
s�;:
r
,MG
y
F
.tl
r•
j
Avg
1.57
7.4
1.19
1.2
0.43
1.0
3.9
8.95
17
0.072
Max
2.15
8.3
3.0
4.1
1 1.22
3.6
25
10.90
30.2
0.644
Min
0.157
6.4
<10
0.1
0.04
0.1
1
6.90
8.4
0.005
Limit
4.0
6-9
17
5 (s)
1 (s)
30
200
> 6
0.5 (S)
10 (w)
2 (w)
—1
1 2.0 (W)
The facility had one permit limit violation during the review period, which was a failure of a WET
test in March, 2013. The facility had passed the 20 previous quarterly tests, and passed the two
subsequent tests.
RPA Analysis:
The facility is required to monitor for copper, zinc and chlorides as part of the NPDES permit, all
are considered as Action Level parameters. RPAs were performed for each of these parameters and
all showed reasonable potential to exceed action level standards. The facility has passed 22 of 23
Quarterly WET tests since 2008. One failure occurred in March, 2013, but the facility passed the 2
follow up tests, and passed the next 2 quarterly tests. No toxicity is caused; monitoring will remain
with no limits. Monitoring frequency will be changed to Quarterly from 2 per month in conjunction
with Chronic Toxicity testing in accordance with the Division's Permitting Strategy for metals and
toxicants.
The facility is also required to monitor for arsenic, cadmium, chromium, lead, molybdenum, nickel,
mercury and selenium as part of its pretreatment program. RPA of data showed only cadmium was
detected above the allowable concentration during the 2-yr data review period. The reported values

NPDES Permit Fact Sheet
Page 3
Siler City WWTP
NC0026441
were 3, 4, and 3 µg/L, compared to the allowable concentration of 2.1 µg/L. Limits and Monthly
Monitoring for cadmium were added to the permit as there was more than one value above the
allowable concentration. An 18 month compliance schedule has been added to provide time to
analyze 12 monthly samples. If none are greater than detect or if RPA shows no RP, the permittee
may petition the Division to remove the limits and monitoring from the permit. Monitoring would
still be maintained on the LTMP. If RP is determined, the limits will remain in the permit,
beginning on November 1, 2015.
Mercury data did not show reasonable potential to cause an exceedence of water quality standards.
'An analysis of mercury data according to the Statewide Mercury TMDL show that no mercury limit
is required, that three PPA analysis of mercury data will be sufficient, and that a Mercury
Minimization Plan is required.
Instream Data Review:
Siler City WWTP is a member of the Upper Cape Fear River Basin Association (UCFRBA). The
UCFRBA performs instream monitoring on the Rocky River at a station 900 feet upstream of the
confluence with Loves Creek, and another station 4 miles downstream. They also monitor Loves
Creek upstream and downstream of the discharge point. Instream data was reviewed for the period
of January 2011 through March 2013. A data summary is provided in tables 2 and 3. Based on this
data, it does appear that both Loves Creek and Rocky River are experiencing elevated nitrite/nitrate
levels, however the levels are greatly reduced from prior levels due to the closing of two poultry
processing facilities. Dissolved oxygen is better downstream than upstream in both streams.
Table 2: Summary of UCFRBA Data from 2011-March 2013 - Loves Creek
�.
1?u meter
i
'U sf eam�. 3s8� oaa,
. Rdwnst tm� B59260 Ot
r
;.
a
Agerg
'Max
a .:fin
DO (mg/L)
7.16
12.31
2.23
8.58
12.38
6.39
H (su)
6.91
7.61
6.23
7.55
8.07
6.71
SS (mg/L)
6.5
38
2.5
5.25
14
2.50
Turbidity (NTU)
9.9
49.8
1.7
4.9
37.5
0.6
NH3- N (mg/L)
0.06
1.41
0.02
0.18
1.75
0.02
KN N (mg/L)
0.56
1.41
0.29
0.67
2.61
0.20
O2/NO3 N (mg/L)
0.61
4.78
0.02
13.6
36.4
0.42
P (mg/L)
0.068
0.170
0.023
0.061
0.147
0.026
Table 3: Summary of UCFRBA Data from 2011- March 2013 - Rocky River
f M x
Prefer
U stceafpn�9QOb
77
Downstream598Q000
DO (mg/L)
6.00
12.53
1.62
6.92
12.09
4.18
pH (su)
6.66
7.33
5.84
6.98
7.42
5.95
SS (mg/L)
10.55
88
3
6.53
15
2.5
Turbidity (NTU)
8.48
34.3
3.3
7.05
21.7
1.9
NH3- N (mg/L)
0.12
0.67
0.02
0.06
0.2
0.02
KN N (mg/L)
1.02
1.42
0.56
0.84
1.51
0.02
O2/NO3 N (mg/L)
0.29
1.05
0.02
3.21
9.89
0.53
P (mg/L)
O.103
0.410
0.046
0.079
0.174
0.024

NPDES Permit Fact Sheet
Page 4
Siler City WWTP
NCO026441
WET Test Results:
Siler City WWTP has a chronic whole effluent toxicity testing requirement at 90% effluent
concentration. From March 2008 through September 2013 they have passed 22/23 WET tests. In
March 2013 there was one failure, which resulted in an NOV, but no enforcement taken. The
facility was required to test in the following two consecutive months and passed both of those tests,
and passed the next two scheduled tests in June and September 2013.
Correspondence File Review/Compliance History:
There have been no violations of the facility's permit limits (with the exception of the above
mentioned WET test failure) from January 2011 through September 2013. Inspection reports
indicate that the facility is properly maintained and has made efforts over the years to better
organize their filing systems. Several inspections did note, going back to 2004, that there is not
enough standby power to operate the entire facility. The generator can only operate the influent
pump station, bar screen, and grit removal processes. The inspectors recommend that the town
consider adding generator capacity to avoid a potential discharge of partially treated wastewater to
Loves Creek in the event of a power outage. The June 14, 2012 Compliance Inspection Report
states that Influent Equalization Basin 4 A & B are isolated and locked out of service due to severe
structural damage, and should be repaired. This repair should be completed prior to adding any
additional flow, regardless of nutrient loading. Excessive I & I seems to be a problem too. Flow
went from 1.625 MGD on June 5 to 3.022 MGD on June 6 to 6.365 MGD on June 7, 2013.
Permit History:
Refer to NCO026441 Attachment I Siler City NPDES Permit History.
Proposed Changes Incorporated into Permit Renewal
1. Changed "Division of Water Quality" to "Division of Water Resources" on Permit.
a. Changed Director to Thomas A. Reeder.
b. Changed expiration date to 4/30/2019 from the scheduled expiration date of
10/31/2016 in order to provide 5 full years of permit life, as the permit had expired
on 10/31/2011. This will put the permit out of synch with the other permits in the
subbasin, so renewal will be for a shorter time in order to get it back on schedule.
2. On Supplement to Cover Sheet, updated the equipment description.
3. On Sheet A.(1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS:
a. Moved pH and Dissolved Oxygen requirements up to the table and deleted their
footnotes.
b. Added Monthly monitoring for Total Cadmium to the permit with new Monthly
Average and Daily Maximum limits, based on statistical analysis of LTMP data.
Cadmium had previously been monitored only on the LTMP. A Compliance
Schedule of 18 months is provided. If 12 months of cadmium data shows no
detects, or if RPA shows no RP, the facility can petition the Division to remove
cadmium limits and monitoring from the permit. Cadmium monitoring would
remain in the LIMP. This would not require a public notice. If data do show RP,
the limits become enforceable on November 1, 2015 (18 months after permit
effective date).
c. Monitoring for Copper, Zinc and Chloride has been changed to Quarterly from
2 per week. See RPA Analysis:section above.
d. TN monitoring has been corrected to" Calculated" from "Composite".
4. Removed old Condition A.(3) Nutrient Optimization Plan as it has been completed.
5. Added new special condition A. (3) NUTRIENT REOPENER to require the Town to report any
plans to accept new industrial process wastewater with TN or TP concentrations higher

` NPDES Permit Fact Sheet Siler City WWTP
Page 5 NCO026441
than 40 mg/ L TN or 5 µg/ L TP. The Division could modify the permit according to the
changed characteristics of effluent, or add or change TN and/ or TP limits.
6. Renumbered existing Condition A.(4) Chronic Toxicity Permit Limit to A.(8) and updated
the language to the current version.
7. Added new Condition A.(4) NUTRIENT WATER QUALITY MODELING REOPENER
in accordance with the Basinwide Nutrient monitoring program.
8. Renumbered existing Condition A.(5) Effluent Pollutant Scan to A.(9). Updated permit
language to the current version, requiring 3 PPAs to be conducted in specified years.
9. Added new Condition A.(5) Mercury Minimization Plan (MMP) as required by the
Implementation Plan for Mercury TMDL. The plan must be developed by October 1, 2014
(six months after the permit effective date).
10. Added new condition A.(6) re cadmium compliance schedule.
11. Added new Condition A.(7) ELECTRONIC REPORTING OF DISCHARGE
MONITORING REPORTS in accordance with EPA requirements for electronic DMR
reporting. Electronic DMRs must be submitted starting on or before January 26, 2015 (270
days after the permit effective date.
Basis for Limits
• Flow limits in the permit are based on design capacity for the treatment system.
• Limits in the permit for Fecal Coliform, Total Residual Chlorine (TRC), pH and Dissolved
Oxygen (DO) are based on North Carolina water quality standards [15A NCAC 2B .0200].
• Limits in the permit for Total Suspended Solids (TSS) are based on requirements of 40
CFR 133.102.
• Limits in the permit for BOD and Ammonia — Nitrogen are based on the results of a water
quality model to protect instream dissolved oxygen, and to prevent ammonia toxicity to
aquatic life in the low flow stream (IWC = 96.1%).
• Limits for Total Phosphorus (TP) are based on an analysis of nutrients at Siler City WWTP
conducted by the Water Quality Section of the NC Department of Environment, Health and
Natural Resources in May 1991, which recommended summer limits of 0.5 mg/ L TP in the
effluent. This was augmented by the Hearing Officer's Report of the court case contesting
the 2007 renewal of the Siler City NPDES permit. He recommended adding a 2.0 mg/ L
TP limit in winter.
• Limits for Cadmium are based on an EPA approved statistical analysis of LTMP data
reported on DMRs, for Aquatic Life protection per NC WQS.
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: September, 2013
Permit Scheduled to Issue: March, 2014
State Contact Information
If you have any questions on any of the above information or on the attached permit, please contact
Tom Belnick at [phone], or by email at [e-mail].
NPDES Recommendation by:
Signature Prepared by Jim McKay Date 3/27/2014

NCO026441 Attachment I
Siler City NPDES Permit History
• The Rocky River and Loves Creek tributary have long been troubled by high nutrients, low DO, poor
benthics and high chlorophyll -a. Based on the 2012 Integrated Report:
a. Upper Rocky River Reservoir is impaired due to Chlorophyll -a standard violations and Low DO.
b. Rocky River (from dam at lower reservoir to Vernal Creek) is impaired for low Dissolved Oxygen.
c. Rocky River behind Woody's Dam is impaired for chlorophyll -a standards violation.
d. Loves Creek from Source to Chatham Avenue in Siler City is impaired for Benthic macroinvertabrates.
From Chatham Avenue to the Siler City WWTP it is impaired for low DO, and from the WWTP to
Rocky River, it is impaired for Benthic Macro invertabrates.
e. Tick Creek is impaired for Fish Community.
f. Bear Creek is impaired for Benthic macroinvertabrates.
• Both Loves Creek and Rocky River were impaired both upstream and downstream of the Siler City WWTP
discharge into Loves Creek, but the WWTP was suspected of causing the high nutrient problems and
impairments.
• Permit renewal application submitted April 25, 2006. A permit renewal draft was prepared and issued for
public review and comments September 12, 2007.
• Due to the many public comments and concerns, a public hearing was held on April 17, 2008. Based on
recommendations of the hearing officers, the division added to the permit:
a. Winter total Phosphorus (TP) limits of 2.0 mg/ L in addition to the existing summer limit of 0.5 mg/ L.
b. Increased frequency of effluent TN and TP monitoring to weekly from monthly.
c. Reporting of TN, NO2 and NO3, and TKN effluent concentrations in addition to parameters already
reported.
d. Instream monitoring on Loves Creek Upstream and Downstream of the discharge. Upstream and
Downstream monitoring on the Rocky River was already in the permit.
e. Development of a Nutrient Removal Optimization Plan was required within one year of the permit
effective date.
• The permit was issued on August 29, 2008, expiring on October 31, 2011.
• The Friends of Rocky River and the Rocky River Heritage Foundation contested the permit.
Administrative Law Judge Beecher R. Gray heard the proceedings during June, 2009. The A.L.J. issued a
decision recommending that the EMC affirm the reissuance of the permit. The EMC affirmed the renewal
of the permit on January 13, 2010.
• The permit was issued February 22, 2010, still expiring on October 31, 2011 with two changes:
a. The Permit effective date changed to April 1, 2010.
b. Footnotes on the Effluent Limitations and Monitoring Requirements sheet A.(1) were updated to
include revised TRC thresholds in keeping with Division permitting strategy for Total Residual
Chlorine.
• Siler City lost its two poultry processing industries. The first one in May, 2008, and the second in October,
2011. This caused the Total Nitrogen discharged in effluent to decline significantly.
• This permit expired on October 31, 2011. A renewal application was received in May, 2011.
• Due to staff constraints and a very heavy workload, renewal efforts were made as time allowed. The
renewal draft was issued for public comment on September 25, 2013. Numerous comments and requests
for changes were discussed with both Siler City and their consultants, and The Friends of Rocky River and
their attorney, and proposals and counterproposals made. The permit is finally ready to issue in March
2014.
Signed:P/Ytll
M L Date: 3 `/ I- s D E"t

Table 1. Project Information
❑ CHECK if HQW or ORW only
Facility Name
W WTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7010s (cfs)
70110w (ofs)
30Q2 (oft)
CIA (ofs)
1Q10s (cfs)
Data Source(s)
❑ CHECK for MODEL
Freshwater RPA
® REQUIRED DATA ENTRY
Siler CityWWTP
W W-4
NC0026441
001
4.0
Loves Creek
C
0.25
0.40
8.70 --
0.21
DMRs, LTMP, 3 PPAs
Follow directions for data entry. In some cases a
comment menu list the available choices ora
dropdown menu will provide a list you may select
from. Error message occur if data entry does not
meet input criteria.
Par01
Par02
Par03
Par04
0 Par05
Parts
Par07
Parts
Par09
ParIG
Parl1
Par12
Par13
Par14
Parts
Parts
Par17
Parts
Paris
Par20
Par21
Par22
Table 2. Parameters of Concern
Name Type Chronic Moefier Acute PQL
Arsenic
C
50
FW
ug/L
❑
Arsenic
C
10
HHANS
ug/L
Beryllium
NO
6.5
FW
ug/L
❑
Cadmium
NO
2
FW
15
uglL
❑
Chlorides (AL)
NO
230
FW
mg/L
❑
Chlorinated Phenolic Compounds
NO
1
A
ug/L
❑
Total Phenolic Compounds
NO.
300
A
ug/L
❑
Chromium
NO
50
FW
1,022
ug/L
❑
Copper (AL)
NO
7
FW
7.3
ug/L
❑
Cyanide
NO
5
FW
22
10
ug/L
❑
Fluoride
NO
1,800
FW
ug/L
❑
Lead
NO
25
PVd
33.8
ug/L
❑
Mercury
NO
12
PW
0.5
ng/L
❑
Molybdenum
NO
2,000
HH
ug/L
❑
Nickel
NO
88
FW
261
ug/L
❑
Selenium
NC
5
FW
56
ug/L
❑
Silver (AL)
NO
0.06
FW
1.23
ug/L
❑
Zinc (AL)
NO
50
FW
67
ug/L
❑
Chloroform
C
170
HH
pg/L
❑
Dichlorobromomethane
C
17
HH
ug/L
❑
El
NC0026441 RPA.xlsm, Input
1011712013

Siler City WWTP REASONABLE POTENTIAL ANALYSIS Outfall 001
NC0026441 Qw = 4 MGD
Qw (MGD) = 4.00
WWTP/WTP Class: WW-4
IQ I OS (cfs) = 0.21
IWC @ I Q I OS = 96.72%
7Q10S (cfs) = 0.25
IWC @ 7Q10S = 96.12%
7Q1OW (cfs) = 0.40
IWC Q 7QIOW = 93.94%
30Q2 (cfs) = NO 3002 DATA
1WC @ 30Q2 = NIA
Avg. Stream Flow, QA (cfs) = 8.70
1WC Qa QA = 41.61%
Receiving Stream: Loves Creek
Stream Class: C
CHRONIC TEST CONCENTRATION = DEFAULT %
=90%
PARAMETER
TYPE
& CRITERIA (2)
ASTANDARDS
N
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
(1)
no
�
NC WQS / Applied �/2 FAV /
n # Det. Max Pred Allowable Cw
Chronic Standard Acute
Cw
Acute: NO WQS
Arsenic
C
50 FW(7QIOs)
ug/L
8 0
16.7
Note: n < 9
Default C.V.
_ —_—__
Chronic: 52.0
_ _ _ _—__ _ __—_---__
No Detects, No RP. Continue to monitor via LTMP
Limited data set
No o value > Ali_ow_a_ble Cw-
----------------------------------
Arsenic
C
10 HH/WS(Qavg)
ug/L
8 0
16.7
Chronic: 24.0
No Detects, No RP. Continue to monitor via LTMP
Note: n < 9
Default C.V.
No value > Allowable Cw
Acute: 15.5
No RP , Predicted Max a 600/6 of Allowable Cw -
Cadmium
NC
2 FW(7QIOs) 15
ug/L
9 3
12.6
_
apply Quarterly Monitoring _ _ -
Note: n <_ 9
Default C.V.
Chronic: 2.1
RP.ior non -AL - apply Monthly Monitoring with Limit
Limited data set
3 values > Allowable Cw
Acute: NO WQS
Chlorides (AL)
NC
230 FW(7QIOs)
mg/L
56 56
302
___ _ _—__
Chronic 239
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
No value > Allowable Cw
Monitoring in conjunction with TOXTest
Acute: 1,056.7
No Detects, No RP. Continue to monitor via LTMP
Chromium
NC
50 FW(7QIOs) 1022
ug/L
9 0
2.5
Note: n <_ 9
Default C.V.
__—
Chronic_ 52.0
_ _ ___
No'Detects; No RP^Continue to:monitor via LTMP
Limited data set
No value > Allowable Cw
Acute: 7.5
RP for AL(Eu,Zn,Ag,Fe,CI) - apply Quarterly
Copper (AL)
NC
7 FW(7QIOs) 7.3
ug/L
56 40
71
Monitoring in conjunction with TOX Test
_ _ _ - — _ — _ _ _ - —
Chronic: 7.3
- — -
RP -for AL(Cu,Zn,Ag,Fe,C1)- apply Quarterly
15 value(s) > Allowable Cw
Monitoring In conjunction with TOX Test,
Acute: 34.9
No Detects, Igo RP. 'Continue to monitor via LTMP
Lead
NC
25 FW(7QIOs) 33.8
ug/L
9 0
15.8
Nate: n <_ 9
Default C.V.
Chronic: 26.0
No Detects, No RP_ Continue* to monitor via LTMP
Limited data set
No value > Allowable Cw
Acute: NO WQS
Mercury
NC
12 FW(7QIOs)
0.5
ng/L
9 8
13.0
Note: n :5 9
Default C.V.
_ _ _
Chronic 12.5
— _ _ _ _
Per TMDL No Llmit; MMP is Required. 3 PPAs +
Limited data set
No value > Allowable Cw
LTMP. monitoring, only.
Acute: NO WQS
Molybdenum
NC
2000 HH(7Q1Os)
ug/L
9 1
25.3
Note: n <_ 9
Default C.V.
Chronic: 2,080.7
N6,RP. Predicted Max < 6O% of�Allawable Cw -
Limited data set
No value > Allowable Cw
Cortiitus to monitor via LTt1Ap
Acute: 269.9
ND RP, Predicted Max.< b0°% of Allowable Cw -
Nickel
NC
88 FW(7QIOs) 261
ug/L
9 2
15.8
Co-niteto monitoruia LTMP
Note: n < 9
Default C.V.
_ ---- —
---- -- ---- -
Chronic: 91.6
No RPrPredided Max<50°i6 of Allowable Cw-
Limited data set
No value > Allowable Cw
Corttigueto monitor via:LTMP
NCO026441 RPA, rpa
Page 1 of 2 9/13/2013

Siler City WWTP REASONABLE POTENTIAL ANALYSIS Outfall 001
NCO026441 Qw = 4 MGD
Acute: 57.9
--------------------------
No Detects, No RP Continue to monitor via LTMP
Selenium
NC
5 FW(7QlOs) 56
ug/L
8 0
16.7
Note: n <_ 9
Default C. V.
- Chronic: 5.2
No Detects," llo` RP, Continue to monitor vie LTMP
Limited data se
No value > Allowable Cw
Acute: 69.3
No RP ; Predicted Max a 50°k of Allowable Cw -
Zinc (AL)
NC
50 FW(7Q 1 Os) 67
ug/L
56 48
68.9
_ _ - _ _ —
apply Quarterly Monitoring ' - _ _ -
_ — - —
Chronic 52.0
RP forAL(Cd.Zn Ag,Fe,CI) - apply Quarterly
No value > Allowable Cw
Monitoring In conjunction with TOX Test
Acute: NO WQS
Chloroform
C
170 HH(Qavg)
µg/L
3 3
106.970
_ _
Mote: n <_ 9
Default C.V.
_ _ _ - _ -
Chronic 408.556
No RP, Predicted Max < 50% of`Aliowable Cw - No
Limited data set
No value > Allowable Cw
Monitortng,rsquired
Acute: NO WQS
Dlchlorobromomethane
C
17 HH(Qavg)
µg/L
3 1
17.622
Note: n < 9
Default C.V.
Chronic: 40.856
[No RP, -Predicted Max < 50% of Allowable Cw - No
Limited data set
No value > Allowable Cw
onitoring required
NCO026441 RPA, rpa
Page 2 of 2 9/13/2013

REASONABLE POTENTIAL ANALYSIS
Arsenic
- FW Standard
Date
Data BDL=1/20L
Results
1
Std Dev.
2
Mean
3
Mar-11
<'. 10
5
C.V. (default)
4
n
5
6
Jun-11
Mutt Factor=
7
Max. Value
8
Max. Pred Cw
9
Sep-11
10
5
10
11
12
Dec-11
i. 2
1
13
14
15
Mar-12
2
1
16
17
18
Jun-12
10
5
19
20
21
Sep-12
< 10
5
22
23
24
Dec-12-<e
10
5
25
26
27
Mar-13
< 10
5
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
4.0000
0.6000
8
3.33
5.0 ug/L
16.7 ug/L
Arsenic - HH/WS Standards
Date
Data BDL=1/2DL
Results
1
Sttl Dev.
2
Mean
3
3/1/2011
< 10 5
C.V.(default)
4
n
5
6
Mutt Factor=
7
Max. Value
8
Max. Pred Cw
9
9/1/2011
< 10 5
10
11
12 12/i/2011 <
13
14
15 3/1/2012 <
16
17
18 6/1/2012 <
19
20
21 9/1/2012 <
22
23
24 12/1/2012 <
25
26
27 3/1/2013 <
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
2 1
2 1
10 5
10 5
10 5
10 5
4.0000
0.6000
8
3.33
5.0 ug/L
16.7 ug/L
2012 RPA-Freshwater b, data
9/13/2013

REASONABLE POTENTIAL ANALYSIS
Cadmium
Chlorides (AL)
Date
Data
BDL=1/2DL
Results
• •
Date Data
BDL=112DL
Results
1
"1
Std Dev.
1.4038
1
1/3/2011
134.0
134
Std Dev.
2
Mean
1,5722
2
1/18/2011
187.0
187
Mean
3
Mar-11
<
2
1
C.V.(default)
0.6000
3
2/7/2011
66.0
66
C.V.
4
n
9
4
2/21/2011
115.0
115
n
5
5
3/8/2011
93.8
93.8
6
Jun-11
<
2
1
Mutt Factor =
3.16
6
3/21/2011
122.0
122
Mult Factor=
7
Max. Value
4.0 ug/L
7
4/4/2011
161.0
161
Max. Value
8
Max. Pred Cw
12.6 ug/L
8
4/1812011
164.0
164
Max. Fred Cw
9
Sep-11
4
4
9
5/6/2011
127.0
127
10
10
5116/2011
110.0
110
11
11
6/7/2011
124.0
124
12
Dec-11
<
0.15
0.075
12
6/20/2011
118.0
118
13
13
7/512011
132.0
132
14
14
7/18/2011
124.0
124
15
Mar-12
<
0.15
0.075
15
8/1/2011
72.7
72.7
16
16
8/1512011
65.1
65.1
17
17
9/1312011
75.5
75.5
18
Jun-12
-<
2
1
18
9/2612011
26.7
26.7
19
19
10/10/2011
76.3
76.3
20
20
10/24/2011
57.9
57.9
21
Sep-12
3
3
21
1IM2011
94.7
94.7
22
_
22
11/20/2011
63.1
63.1
23
23
12/612011
61.0
61
24
Dec-12
2
1
24
12/19/2011
39.0
39
25
25
1/3/2012
37.9
37.9
26
26
1/17/2012
189.0
189
27
Mar-13
3
3
27
2/612012
103.0
103
28
28
2/20/2012
54.1
54.1
29
29
3/13/2012
42.1
42.1
30
30
3/26/2012
36.2
36.2
31
31
4/9/2012
27.3
27.3
32
32
4123/2011
29.5
29.5
33.
33
517/2012
41.0
41
34
34
5/21/2012
39.1
39.1
35
35
6/5/2012
40.0
40
36
36
6/18/2012
54.1
54.1
37
37
7/212012
52.6
52.6
38
38
7/16/2012
57.9
57.9
39.
39
8/612012
55.2
55.2
40
40
a/20/2012
63.1
63.1
41
41
9/11/2012
57.9
57.9
42
42
9/24/2012
55.0
55
43
43
10/8/2012
5Z9
57.9
44
44
10/22/2012
65.0
65
45
45
11/512012
53.8
53.8
46
46
11/19/2012
54.1
54.1
47
47
12/4/2012
52.6
52.6
48
48
12/17/2012 -
55.5
55.5
49
49
117/2013
40.0
40
50
50
1122/2013
48.8
48.8
51
51
2/4/2013
52.6
52.6
52
52
2/18/2012
43.1
43.1
53
53
3/12/2013
44.2
44.2
54
54
3/25/2013
54.1
54.1
55
55
41812013
36.0
36
56
56
4/22/2013
61.6
61.6
57
57
74.4
0.5484
56
1.6
189.0
302.4
2012 RPA-Freshwater b, data
-2- 9/13/2013

REASONABLE POTENTIAL ANALYSIS
mg/L
mg/L
Chromium
Copper (AL)
Date
Data
BDL=112DL
Results
• •
Date Data
BDL=112DL
1 Mar-11
.`-'';
5
2.5
Sid Dev.
0.0000
1
1/3/2011 '
7.0
7
2 Jun-11
:-E
5
2.5
Mean
2.5000
2
1/18/2011 '.
7.0
7
3 Sep-11
: ,'
5
2,5
C.V.
0.0000
3
2/7/2011
3.0
3
4 Dec-1 1
'a
5
2.5
n
9
4
2/21/2011 <<
2.0
1
5 Mar 12
g«
5
2.5
5
318/2011
2.0
1
6 Jun-12
5
2.5
Mult Factor =
1.00
6
3/21/2011
5.0
5
7 Sep-12
15k
5
2.5
Max. Value
2.5 ug/L
7
4/4/2011 f:<;,
2.0
1
8 Dec 12
"r-
5
2.5
Max. Fred Cw
2.5 ug/L
8
4/18/2011 <,.
2.0
1
9 Mar-13
':'
5
2.5
9
5/2/2011
13.0
13
10
10
5/16/2011 <
2.0
1
11
-
11
677/2011 <
2.0
1
12
12
6/20/2011 ;:_
7.0
7
13
13
7/5/2011 f
2.0
1
14
14
7/18/2011
5.0
5
15
15
8/1/2011
8.0
8
16
16
8/15/2011
8.0
8
17
17
9/13/2011
10.0
10
18
a! n
18
9/26/2011
5.0
5
19
19
10/10/2011
6.0
6
20
`J
20
10/24/2011
5.0
5
21
21
11/7/2011
5.0
5
22
)
22
11/20/2011
6.0
6
23
7x
23
1216/2011
4.0
4
24
24
12/19/2011
6.0
6
25
25
1/3/2012
5.0
5
26
26
1/17/2012
7.0
7
27
aif
27
2/6/2012
4.0
4
28
28
2/20/2012
9.0
9
29
29
3/13/2012
4.0
4
30
«"-'
30
3/26/2012
3.0
3
31
31
4/9/2012
6.0
6
32
32
4/23/2012
4.0
4
33
33
577/2012
8.0
8
34
34
5/21/2012
5.0
5
35
35
6/5/2012
10.0
5
36
36
6/18/2012
10.0
5
37
'£
37
7/2/2012 s<
10.0
5
38
38
7/16/2012 <'
10.0
5
39
i�
39
8/6/2012 Ki
10.0
5
40')
40
8/20/2012 °�<
10.0
5
41
EG'@
41
9/11/2012
10.0
5
42
42
9/24/2012 -�`;r
10.0
10
43
43
10/8/2012 <;
10.0
5
44
44
10/22/2012
10.0
5
45
-
45
11/5/2012 s
11.0
11
46
t{A-'1!
46
11/19/2012
37.0
37
47
#s I
47
12/4/2012
12.0
12
48
48
12/17/2012
8.0
8
49
{ f
49
1/7/2013
3.0
3
50
50
1/22/2013
8.0
8
51
�_-
51
2/4/2013
8.0
6
52
52
2/18/2013
8.0
8
53
<;.
53
3/12/2013
8.0
8
54
,-
54
3/25/2013
8.0
8
55
j
55
4/8/2013
7.0
7
56
56
4/22/2013
6.0
5
57
ti
57
Results �i -'-'
Std Dev. 5.0117
Mean 6.2143
C.V. 0.8065
n 56
Mult Factor = 1,91
Max. Value 37.0
Max. Fred Cw 70.7
-3-
2012 RPA-Freshwater b, data
9/13/2013

REASONABLE POTENTIAL ANALYSIS
ug/L
ug/L
Lead
Date
Data
13131.=1120L
Results
Mar-11
<
10
5
Std Dev.
2.0946
Jun-11
<
10
5
Mean
3.9444
Sep-11
<.
10
5
C.V. (default)
0.6000
Dec-11
<c
0.5
0.25
n
9
Mar-12
<
0.5
0.25
Jun42
<
10
5
Mult Factor =
3.16
Sep-12
<
10
5
Max. Value
5.0 ug/L
Dec-12
<
10
5
Max. Fred Cw
15.8 ug/L
Mar-13
<
10
5
Mercury
Date
Data
BDL=112DL
Results
1
Mar-11
1.4
1.4
Std Dev.
1.0198
2
Jun-11
1.2
1.2
Mean
1.5667
3
Sep-11
< 1
0.5
C.V.(default)
0.6000
4
Dec-11
1.1
1.1
n
9
5
Mar-12
1.4
1.4
6
Jun-12
1.9
1.9
Mult Factor =
3.16
7
Sep-12
1.1
1.1
Max Value
4.1
8
Dec-12
1.4
1.4
Max. Pred Cw
13.0
9
Mar-13
4.1
4.1
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
-4-
2012 RPA-Freshwater b, data
9/13/2013

REASONABLE POTENTIAL ANALYSIS
ng/L
ng/L
Molybdenum
Date Data
BDL=1/2DL
Results
1
Sul Dev.
2
Mean
3
Mar-11
5
2.5
C.V. (default)
4
n
5
6
Jun-11
5
2.5
Mult Factor=
7
Max. Value
8
Max. Pred Cw
9
Sep-11
8
8
10
11
12
Dec-11
2
1
13
14
15
Mar-12
2
1
16
17
18
Jun-12
5
2.5
19
20
21
Sep-12 <
5
2.5
22
23
24
Dec-12 4's
5
2.5
25
26
27
Mar-13 -
5
2.5
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
Nickel
• • Date Data BDL=112DL Results
2.0632 1 Std Dev.
2.7778 2 Mean
0.6000 3 Mar-11 < 10,00 5 C.V. (default)
9 4 n
5
3.16 6 Jun-11 < 10,00 5 Mull Factor=
8.0 ug/L 7 Max. Value
25.3 ug/L 8 Max. Fred Cw
9 Sep-11 < 10.00 5
10
11
12 Dec-11 200 2
13
14
15 Mar-12 3.00 3
16
17
18 Jun-12 < 10.00 5
19
20
21 Sep-12 < 10.00 5
22
23
24 Dec-12 < 10.00 5
25
26
27 Mar-13 < 10.00 5
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
5
2012 RPA-Freshwater b, data
-5- 9/13/2013

REASONABLE POTENTIAL ANALYSIS
4.4444
0.6000
9
3.16
5.0 ug/L
15.8 ug/L
Zinc (AL)
Date
Data
BDL=f/2DL
Results
• •
Date
Data
BDL=112DL
1 Mar-11
10
5
Sid Dev.
1.8516
1
1/3/2011
16.
16
2 Jun-11
10
5
Mean
4.0000
2
1/18/2011
24.
24
3 Sep41
10
5
C.V. (default)
0.6000
3
217/2011
18.
18
4 Dec-11
<
2
1
n
8
4
2/21/2011
24.
24
5 Mar-12
1
2
1
5
3/8/2011
13.
13
6 Jun-12
<
10
5
Mult Factor =
3.33
6
3/21/2011
31.
31
7 - Sep-12
10
5
Max. Value
5.0 ug/L
7
4/4/2011
23.
23
8 Dec-12
<
10
5
Max. Pred Cw
16.7 ug/L
8
4/18/2011
24.
24
9
9
515/2011
23.
23
10
10
5/16/2011
20.
20
11
11
6/7/2011
16.
16
12
12
6/20/2011
<
10.
5
13
13
7/5/2011
10.
10
14
14
7/18/2011
<
%
5
15
15
8/1/2011
14.
14
16
16
8/15/2011
<
10.
5
17
17
9/13/2011
40,
40
18
18
9/26/2011
7.
7
19
19
10/1012011
12.
12
20
20
10/24/2011
9.
9
21
21
11/7/2011
9.
9
22
22
11/20/2011
10.
10
23
23
12/6/2011
9.
9
24
24
12/19/2011
8.
8
25
25
1WO12
13.
13
26
26
1/17/2012
13.
13
27
27
2/6/2012
16.
16
28
28
2/20/2012
20.
20
29
29
3/13/2012
17.
17
30
30
3/26/2012
6.
6
31
31
4/9/2012
11.
11
32
32
4123/2011
<
10.
5
33
33
5(//2012
<
10.
5
34
34
6/21/2012
<
10.
5
35
35
6/5/2012
<
10.
5
36
36
6/18/2012
1&
15
37
37
7/2/2012
<
10.
5
38
38
7/16/2012
12.
12
39
39
8/6/2012
14.
14
40
40
8/20/2012
11.
11
41
41
9/11/2012
12.
12
42
42
9/24/2012
16.
16
43
43
10/8/2012
19.
19
44
44
10/22/2012
25.
25
45
45
11/5/2012
28.
28
46
46
11/19/2012
24.
24
47
47
12/4/2012
37.
37
48
48
12117/2012
42.
42
49
-
49
1/7/2013
36.
36
50
50
1/22/2013
26.
26
51
51
2/4/2013
41.
41
52
52
2118/2012
30.
30
53
53
3/1212013
37.
37
54
54
3/2512013
19.
19
55
-
55
4/8/2013
20.
20
56
56
4/22/2013
27.
27
57
57
Results
Sid Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
-6-
2012 RPA-Freshwater b, data
9/13/2013

REASONABLE POTENTIAL ANALYSIS
Chloroform
Dichlorobromomet
• •
Date
Data BDL=1/2DL
Results
• •
Date
Data
BDL-112DL
10.3301
1
Jan. 2007
17.9 17.9
Std Dev.
3.3650
1
Jan. 2007
1
0.5
17.6250
2
Jun 2009
19 19
Mean
16.5333
2
Jun 2009
1
0.5
0.5861
3Mar
2010
12.7 12.7
C.V.(default)
0.6000
3
Mar 2010
3.13
3.13
56
4
n
3
4
5
5
1.64
6
Mult Factor =
6.63
6
42.0 ug/L
7
Max. Value
19.000000 yg/L
7
68.9 ug/L
8
Max. Pred Cw
106,970 yg/L
8
9
9
10
10
11
1t
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
2012 RPA-Freshwater b, data
-7- 9/13/2013

REASONABLE POTENTIAL ANALYSIS
hane
Results
Sld Dev. 1.5184
Mean 1.3767
C.V. (default) 0.6000
n 3
Mult Factor= 5.63
Max. Value 3.130000 pg/L
Max. Fred Cw 17.622 pg/L
Results EMENK9
Std Dev. NO DATA
Mean NO DATA
C.V. NO DATA
n 0
Mult Factor = N/A
Max. Value N/A
Max. Fred Cw N/A
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
Date Data
-8-
2012 RPA-Freshwater It, data
9/13/2013

7/3/13
WQS= 12
ng/L
MERCURY WQBEL/TBEL EVALUATION V:2013-5
Facility Name:
Siler City W WTP NC0026441
No Limit Required
MMP Required
Total Mercury 1631E PQL = 0.5 ng/L
7Q10s = 0.250 cfs WQBEL = 12.48 ng/L
Date
Modifier Data Entry
Value
Permitted Flow = 4.000 47 ng/L
Mar-11
1.4
1.4
Jun-11
1.2
1.2
Sep-11
< 1
0.5
Dec-11
1.1
1.1
1.1 ng/L - Annual Average for 2011
Mar-12
1.4
1.4
Jun-12
1.9
1.9
Sep-12
1.1
1.1
Dec-12
1.4
1.4
1.5 ng/L - Annual Average for 2012
Mar-13
4.1
4.1
4.1 ng/L - Annual Average for 2013

NPDES Permitting for Mercury
Implementation of 2012 Statewide Mercury TMDL
NC0026411 - Town of Siler Citv W WTP 7/10/2013
Facility Type
Annual Average
Limit Required (see A)
Monitoring Frequency
(with 1631E analysis)
MMP Required (see B)
Major Muni (>1 MGD)
Yes
Quarterly
Yes(if> 2 MGD)
No
3 PPA only
Yes- if multiple detects
above 1 n I and > 2 MGD
Minor Muni (<1 MGD)
Yes
Quarterly
No
No
Once/5 years
No
Industrial
Yes
Quarterly
Yes
No
None in permit. Might be
required for EPA
application form.
No
A.Procedure to Determine if Annual Average Limit Required:
Step I- WQBEL Evaluation
• Evaluate need for Water Quality Based Effluent Limit (WQBEL)
• Calculate Allowable mercury concentration using dilution (12 ng/I x 7Q 10 dilution factor)
• Compare Annual effluent concentrations to Allowable Cone. for each of last 5 years
• If any Annual Avg> Allowable Cone., then add Annual Avg WQBEL.
Step 2- TBEL Evaluation
• Evaluate need for Technology Based Effluent Limit (TBEL)
• Compare all individual values to TBEL of 47 ng/I
• If any single value > 47 ng/l, then add Annual Avg TBEL of 47 ng/l.
Step 3- Compare WQBEL to TBEL
• If data triggers need for WQBEL and TBEL, select most stringent of the two limits.
• If data triggers need for only TBEL, add 47 ng/I annual average limit unless WQBEL <47 ng/l, in which
case annual avg limit should be set at WQBEL.
• Conclusion: the Annual Avg limit will range from 12 ng/I to upper cap of 47 ng/l.
Step 4- If NEW limit, delay effective date
• Addition of new limit will become effective in 5 h year of permit, with mercury minimization plan
development/implementation required for first 4 years (see MMP below).
B. Mercury Minimization Plan (MMP). If an MMP is required (note change to Major Municipal > 2MGD), add
the following Special Condition to the permit:
A(x). Mercury Minimization Plan (MMP). The permittee shall develop and implement a mercury minimization
plan 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 (hgp://Portal.ncdenr.org/web/wq/swl)/p-s/npdes, under
Model Mercury Minimization Plan). 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.
C. New/Expanding Dischargers- will be allowed as long as the overall aggregate point source load allocation is not
exceeded.
D. Special Situations- Additional site -specific information, such as fish tissue and water column data when
available, will be considered in assigning limits and MMP requirements. Also, limits> TBEL may be considered on
case -by -case basis due to extenuating circumstances
Version 06/13/2013 Prepared by: Tom Belnick Approved by Jeff Poupart

b,evf tzpiievil pf' Nu �vi en f ge ofen+� anelf-harl
Proposed Revisions to NCO026441— Siler City
Jim McKay 2-11-2014
A. (3) NUTRIENT REOPENER
In the event that Permittee proposes to accept future industrial process wastewater that is expected to
contain concentrations of Total Nitrogen (TN) and/ or Total Phosphorus (TP) greater than typical
domestic wastewater concentration (i.e. greater than 40.0 mg/ L TN or greater than 5.0 mg/ L TP), the
Permittee shall notify the NPDES Complex Permitting Unit of the Division at 1617 Mail Service Center,
Raleigh, NC 27699 and the Raleigh Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 within 30
days of knowledge that the town is considering accepting new industrial process wastewater containing
excess nutrients. The notification shall contain information regarding the proposed discharge flow,
composition and treatability in the Siler City WWTP. Changes in effluent characteristics may require a
permit modification, so notification should be at least 180 days prior to the start of the proposed
discharge.
Based on information provided by the Town regarding a potential new industrial process wastewater with
high nutrient concentration, and pursuant to N.C. General Statute Section 143-215.1 and the
implementing rules found in Title 15A of the North Carolina Administrative Code, Subchapter 2H,
specifically, 15A NCAC 2H.0I 12(b) (1) and 211.0114(a), and Part II, Sections B-12 and B-13 of this
permit, the Director of DWR may then reopen this permit to require supplemental nutrient limits for Total
Nitrogen and/ or Total Phosphorus in accordance with the current Basin Plan for the Cape Fear River
Basin.
A. (6) COMPLIANCE SCHEDULE FOR TOTAL CADMIUM LIMITS
The limits for Total Cadmium shall begin 18 months after the effective date of this permit. Monitoring
shall begin on the effective date. If 12 monthly data points are all less than detect, or a Reasonable
Potential to Exceed WQ standards analysis (RPA) indicates no potential, Permittee may petition the
Division for removal of Total Cadmium limits and monitoring from the permit. The Division will review
the petition and data. If the Division confirms that the results are all below detection levels, or if a
Reasonable Potential Analysis examination of the data shows no potential to exceed Water Quality
Standards, the Division will proceed with modification of the permit. Monitoring for Total Cadmium will
remain on the LTMP. If the Data are not all less than detect, and show Reasonable Potential to exceed
Water Quality Standards, the limigshall remain on the permit, effective on the above date. This limit
removal will not be considered a permit modification requiring public notice.

ry)d� 1/Z VM1 Mee 1-1,fl 6
Belnick, Tom {
From: Forrest Westall [[e-mail]]
Sent: Thursday, January 23, 2014 12:57 PM
To: Mckay,James
^� �S
Cc: Belnick, Tom /� q
Subject: RE: Redrafted Siler City NPDES Permit / 1
Hi,
I just received some influent data on TN. The TN concentrations for 2013 influent were:
Month
(mg/1)
March 2013
35.7
June 2013
0.787
September 2013
43.9
December 2013
38.8
TN
TP (mg/1)
3.2
9.37 [This is an extremely low number and was obviously affected by rainfall and W)
The average of the three "typical' TN numbers
Based on that I would revise my recommended
6.1
5.2
i
The average on TP using the "typical' numbers s 4.8 /I.
ie Nutrient Reopener to:
A. (3) Nutrient Reopener
In the event that the Permittee proposes to accept future industrial process wastewater that is expected to contain
Total Nitrogen (TN) and Total Phosphorus (TP) greater than typical domestic strength wastewater, the Permittee shall
notify the NPDES Complex Permitting Unit of the Division at 1617 Mail Service Center, Raleigh, INC 27699 and the
DWR Raleigh Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 within 30 days of knowledge that the Town is
planning to accept future industrial process wastewater. If possible, the Permittee should notify the Division at least
180 days prior to the start of the proposed discharge. For the purposes of comparison of the expected TN and TP of
the future industrial wastewater to typical domestic strength, values greater than 3040 mg/I TN and g 5 mg/I TP in
the proposed wastewater require notification of the Division in accordance with this permit condition. Any
notification submitted shall contain information regarding the proposed discharge flow, composition and treatability
in the Siler City WWTP. ,
From the data reviewed after the poultry operations closed, the TN influent is closer to the "medium" strength level
published by Metcalf and Eddy. It is strongly indicated that the facility is dealing with TN and TP levels consistent with
the numbers above. Any industry connecting with higher levels should be evaluated.
If we can discuss, I am still available on my home phone.
Thanks,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.

55 Broad Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com
From: Forrest Westall
Sent: Thursday, January 23, 2014 11:48 AM
To: [e-mail]
Cc: Belnick, Tom ([e-mail])
Subject: RE: Redrafted Siler City NPDES Permit
I'm checking with the Town on some TN and TP data. I will update my note below if the data is different than what I
used on the TN and TP triggers.
Thanks,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] ( Website: www.mceilleneineers.com
From: Forrest Westall
Sent: Thursday, January 23, 2014 11:29 AM
To: James.McKay(&ncdenr.gov
Cc: Belnick, Tom (tom.belnick(ancdenr.gov)
Subject: RE: Redrafted Siler City NPDES Permit
Hello Jim,
I spoke to you this morning and to Tom yesterday..You indicated he would be discussing this with Tom today. I have
worked on some background information and am providing some specific wording. Please give me a call when you both
have had an opportunity to review.
Based on our brief discussion this morning, I talked with one of our most experienced WWTP designer. Where definitive
data on a facility's influent nutrient content is not available, he refers to Metcalf and Eddy. For municipal type
wastewater the projected values are (4th Edition of Metcalf and Eddy):
Strength TN(mg/1) TP (mg/1)
High 70 12
Med 40 7
Low 20 4
Obviously, I & I as well as composition of the service area will be a huge factors. There is limited influent data on TN and
TP, even on larger facilities. When we were doing the design for the Statesville 3rd Creek WWTP, we had some data from
2007-2008. The average TN for 3rd Creek was 25.8 mg/I and the average for 4th Creek was 30.0. TP at 3rd Creek was 6.21
mg/I and 4th Creek was 5.89 mg/I. The service areas for Statesville 3rd and 41h Creek plants are larger than Siler City's.
True domestic strength effluent, without dilution, will likely be near the medium levels cited. You sent me some slides
the Division developed which generally shows that during the period that the poultry operations were active the plan
effluent TN varied generally between 10 and 65 mg/l. After closure of the poultry plants, the TN numbers varied from

approximately 10 to 35+ mg/I TN. It is fair to say that the typical strength coming to the facility varies with collection
system service profile, rainfall and collection system integrity. Because TN isn't expected to change through the WWTP
since it isn't designed for nitrogen removal, the effluent values for Siler City likely reflect generally what is coming into
the plant. Without actual influent data, the "expected" effluent value for TN and TP at Siler City has to be a BPJ
decision. I suggest that you use TN 30 mg/I and TP 6 mg/I. An industrial discharger with expected concentrations from
its process WW greater than these values may be considered as more concentrated than normal domestic strength
WW. On the basis of this and my earlier comments, I suggest the following wording:
A. (3) Nutrient Reopener
In the event that the Permittee proposes to accept future industrial process wastewater that is expected to contain
Total Nitrogen (TN) and Total Phosphorus (TP) greater than typical domestic strength wastewater, the Permittee shall
notify the NPDES Complex Permitting Unit of the Division at 1617 Mail Service Center, Raleigh, NC 27699 and the
DWR Raleigh Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 within 30 days of knowledge that the Town is
planning to accept future industrial process wastewater. If possible, the Permittee should notify the Division at least
180 days prior to the start of the proposed discharge. For the purposes of comparison of the expected TN and TP of
the future industrial wastewater to typical domestic strength, values greater than 30 mg/I TN and 6 mg/I TP in the
proposed wastewater require notification of the Division in accordance with this permit condition. Any notification
submitted shall contain information regarding the proposed discharge flow, composition and treatability in the Siler
City WWTP.
[Revise 2ond paragraph by adding this phrase before 'Pursuant to..."]
"Based on the information provided by the Permittee when notifying the Division of the future industrial wastewater
and"
Please note that I added a 30 day period from first knowledge because the notification includes the development of
expected wastewater characteristics and an evaluation of the treatability of the wastewater in the Town's plant. Two
weeks is too short a time to develop that information. The Town is certainly prepared to notify the Division as soon as
possible, but "requiring" a 180 day notice could put the Town in a real bind.
Relative to the compliance schedule for cadmium and the com s 1 senLyg�
working:
A. (6) Compliance Schedule for Cadmium Limits
Enforcement of Cadmium limits shall begin 18 months after
on the effective date. 112 monthly data points for cadmiw
skavd� Ak
I'll .Oe feA
iusly, I suggest the following
yz�eTfeE ' _#this permit. Monitoring shall begin
are less thari!.Tug)]. Permittee nuw-aetitkon the
' ' ' dmium limit and monitorinjfrom this permit:-1f-so modified, monitoring will remain
under the LTMP. The Division will review the petition and data. Provided that the Division confirms that all sampling
results are < 2.1 ug/I, the Division will proceed with modification of the permit.
considered a permit modification requiring public notice.
When you've had a chance to review this, please give me a call at 828.675.4159.
Thanks,
Forrest
Forrest R. Westall, Sr., PE
Principal
This limit removal will not be
CZ
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mceillengineers.com
cz:-:, /IS.
CZ.

From: Forrest Westall
Sent: Wednesday, January 22, 2014 8:30 AM
To: James. McKayC&ncdenr.gov
Cc: Belnick, Tom ([e-mail])
Subject: Redrafted Siler City NPDES Permit
Hello Jim,
On behalf of the Town of Siler City, I would like to address the proposed changes to the renewal NPDES permit for their
WWTP. The Town appreciates the consideration of the comments the Town previously submitted and the information
exchanged at the meeting the Town had with the Division on November 5, 2013. The following comments relate to the
draft submitted to the Town in your letter dated January 10, 2014.
The notification "trigger" included in the revised Nutrient Reopener language is of concern to the Town. The reopener
as revised:
A, (3) NUTRIENT 1tEOPENER
In the event that Permittee proposes to acceptWmeIndustrial wastewater that has the possibility to increi
Total Nitrogen Load and/ or Total Phosph rus ��u
harged above the 2012 -� 2013 average nutrient lo:
Permitter shall notify the NPDES Comptex Unitof the Division at ldli Mail Service Center, ]
NC 27699 and the Raleigh Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 at least 180 days pr
start of the proposed discharge. The notification shall contain information regarding, the proposed dischar
composition and treatability in the Siler CityVWTP.
Pursuant to N.C. General Statute Section 143 215.1 and the implementing rules found in Title i SA of the
Carolina Administrative Code, Subchapter M specifically, 1 SA NCAC 2H.0112(b) (1) and 2H.0114(a), i
11, Sections B-12 and 1B-13 of this permit; the Director of DWR may then reopen this permit to roquire
supplemental nutrient limits for Total Nitrogen and Total Phosphorus in accordance with the current Base
the Cape Fear River Basin.
The first sentence requires notification if a proposed industrial discharge has "the possibility t se the Total
Nitrogen Load and/or Total Phosphorus load discharged above the 2013-2013 average nutri t loads. If the term "load
discharged" means the effluent discharge load, then essentially any new discharger will have ability of increasing
the average nutrient load. Even if a new discharger discharges no higher levels of TN and TP to the collection system
that the current influent levels, then by mass loading the load to the plant would increase. In addition, if the discharge
of new industrial wastewater results in an increase in average discharge flow (which it would in any case) and the
effluent levels of TN and TP didn't change from the 2012-2013 period, notification is required. The Town's earlier
comments suggested a trigger that compared the TN and TP levels of a new industrial discharger to the levels expected
in domestic strength wastewater. The way the condition is written, it would essentially require the Town to notify the
Division of any new industrial discharger, even if nutrient levels of a new industrial discharger are low. The trigger
should be based on the proposed industrial wasterwater TN and TP concentrations as compared to a related baseline.
The notification timeline of "at least 180 days prior to the start of the proposed discharge" could prove a problem if a
new industry used an existing building in town and was able to start discharging quicker than 180 days. The Town
suggests that the wording reflect notification based on their knowledge of the proposed facility. Following the two
addresses the Town suggests the following wording, "...within two weeks of the Town's knowledge of the potential for a
new industrial discharger, and if possible, 3.80 days prior to the planned start of the proposed discharge."

The second paragraph of the Nutrient Reopener should include a reference to the Division's review of the information
provided by the Town relative to a potential new industrial discharger. Recommended that the phrase "Based on the
information provided by the Permittee on the identified future industrial wastewater and" before the beginning of the
second paragraph "Pursuant to...."
The Town also requests revision to the Cadmium compliance schedule special condition.
A. (b) COMPLIANCE SCHEDULE FOR CADMIUM LIMIT'S
Enforcement of Cadmium limits shall begin 18 months after the effective date of this permit, Monitoring s
begin on the effective date. If 12 monthly data points are all less than 2.1 pg/ L, Pennittee may petition the
Division for removal of Cadmium limits and monitoring from the permit. Monitoring will remain on the 1;
This limit removal will not be considered a permit modification requiring public notice.
The Town appreciates the opportunity to perform monitoring and provide a more complete data set, however, as the
condition is worded, there is no assurance that the Division will modify the permit even if the data shows that the level
of Cd is below 2.1 ug/I consistently. The Town must "petition" the Division on the basis of the additional monitoring, but
there is no indication that the Division will act on this request. The Town requests that the condition include a
commitment from the Division if the Town submits a petition,for revision of the Cd limit and monitoring.
I would like the opportunity to discuss these comments with your Your letter dated January I& requested any
comments by January 24th. Prior to preparation of a letter response, the Town requested that I talk with you first.
Thanks for your consideration.
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone:[phone] Fax: [phone]
Email: [e-mail] I Website: www.mceilleneineers.com

FA
A
IO ENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
55 Broad Street
Asheville, NC 28801
(Electronic Copy)
Dear Mr. Westall:
Division of Water Resources
Water Quality Programs
Thomas A. Reeder
Director
February 17, 2014
Subject: Revised Draft
John E. Skvarla, III
Secretary
Permit No. NCO026441
Siler City W WTP
Chatham County
Enclosed with this letter is a copy of the revised draft renewal permit for the Siler City W WTP, based on
review comments from McGill Associates, P.A. and Mr. John D. Runkle, Esq./ Friends of the Rocky
River.
This draft permit has the following changes from the last draft: I Q
Special Condition A. (3) NUTRIENT REOPENER
The special Condition for reopening the permit if nutrient disc rges are in eased has been
revised to further clarify the trigger mechanism. The Tow ill have to not DWR and the
Raleigh Regional Office within 30 days after learning of otential applicatio to receive
industrial process contact wastewater with Total Nitrog and/ or Total Phosp
concentrations higher than conventional domestic w i.e. greater than 40. µg/ L Total
Nitrogen and/ or Total Phosphorus greater than 5. µg/ L . As in the earlier a Town
must describe the proposed new wastewater stream composition and how well the
existing WWTP can handle the increased hydraulic load and nutrient input. The Division
will review the data and decide the best way of handling the situation. The Division is very
attuned to the nutrient problems in that area. We are starting to work on a Nutrient TMDL
for the Cape Fear River to study all the nutrient contributors to the river. The TMDL will be
a rigorous scientific evaluation of the nutrient handling capacity of the river basin, and
allocate allowable loads to each source of nutrients. This process is very involved, and will
take several years to complete and have EPA approval. Once it is completed, the Division
will have legal tools to impose appropriate limits on all dischargers, similar to the existing
Neuse River Basin.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] Fax: [phone]
Internet: vmv.nmatemualitv.oro

Special Condition A. (6) COMPLIANCE SCHEDULE FOR TOTAL CADMIUM LIMITS
• An 18 month compliance schedule is still provided before limits are effective. If 12 months of
data are all reported as "Less than detect" or if RPA conducted on 12 months of data with some
above detect limits show no RP, then the limits and monitoring will be removed from the permit;
monitoring will remain on the LTMP. If data show RP, then the Total Cadmium limits and
monthly monitoring will remain on the permit, effective on the date contained in the permit.
This is our normal practice when imposing new limits on an existing permit, in order to provide
time for the facility to make modifications required to meet the new limit and is acceptable to
EPA as complying with the Clean Water Act, and EPA requirements.
Please respond with any questions or comments by February 28, 2014.
Attachments: NC0026441 Revised Draft Renewal
Sincerely,
Jim McKay
Complex NPDES Permitting
Page 2 of 3

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
DRAFT PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PDES
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, the
Town of Siler City
is hereby authorized to discharge wastewater from a facility located at the
Town of Siler City WWTP
370 Wastewater Plant Road
Chatham County
to receiving waters designated as Loves Creek within 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 March 31, 2019.
Signed this day.
Thomas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission

Permit NCO026441
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any
previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this
facility arises under the permit conditions, requirements, terms, and provisions included herein.
The Town of Siler City is hereby authorized to:
1. Continue discharging 4.0 MGD of treated process -contact and domestic wastewater from a treatment
facility consisting of
• Automatic and manual bar screens
• Grit collection unit
• Influent pump station
• Influent Equalization Basin (Zone 2)
• Dual oxidation ditches with surface jet aeration
• Flow Splitter Box
o Alum feed station
o Lime feed station
• Dual secondary clarifiers
• Dual Aerobic digesters
• Return Activated Sludge
• Sludge Transfer Station
• Dissolved Air Flotation Unit (Used as needed)
• Sludge Thickener Basin
• Influent equalization or Sludge Storage Basins (Zone 3 A & B used as needed)
• Four (4) tertiary filters
• Filter Backwash Basin
• Gaseous Chlorine Disinfection
• Chlorine contact chamber
• Gaseous Sulfur dioxide Dechlorination
• Step -Aeration
This facility is located at the Siler City WWTP on Wastewater Plant Road near Siler City in Chatham County.
2. Discharge from said wastewater treatment works through Outfall 001 into Loves Creek (see attached map), a
stream classified as C waters within the Cape Fear River Basin.
Page 2 of 9

Permit NCO026441
Part I
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
a. During the period beginning with the effective date and lasting until expiration, the Permittee is authorized to discharge
treated wastewater through Outfall 001. Such dischames shall be limited and monitored' by the Permittee as specified below:
EFFLUENT LIMITS.
_.
M TO�iING
�tEQUi�tEMEN'�S
PARAMETERS
Monthly . _.
'Wee kly
Da11y '
1Vleasui'rement
Sample
Sample
-
Avera a :,
Avera e. -.
..Maximum
; ,Fre uenc
e. ; ,,
Location2:..,
Flow
4.0 MGD
Continuous
RecordingInfluent
or
Effluent
BOD, 5 day, 20°C
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent and
(April 1 thru October 31)
Effluent
BOD, 5 day, 20°C
(November 1 thru March 31)
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent and
Effluent
Total Suspended Solids3
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent and
NH3 as N
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
ril 1 thru October 31
NH3 N as
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
ove 1 thru March 31 }
Fecal Coliform
(geometric mean)
200/ 100 ml
4004 100 ml
Daily
Grab
Effluent
Total Residual Chlorine (TRC)4
17 µg/L
Daily
Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
Dissolved Oxygen
Daily average > 6.0 mg/L
Daily
Grab
Effluent
PH
> 6.0 and < 9.0 standard units
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 + TKN)
Weekly
Calculated
Effluent
NO3 N + NO2-N (mg/L)
Weekly
Composite
Effluent
TKN (mg/L)
Weekly
Composite
Effluent
Total Phosphorus
(April 1 thru September 30
0.5 mg/L (quarterly average)
Weekly
Composite
Effluent
Total Phosphorus
October 1 through March 31)
2.0 mg/L (quarterly average)
Weekly
Composite
Effluent
Total Cadmium 6
2.1 µg/ L
15.5 µg/ L
Monthly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Total Zinc
Quarterly'
Composite
Effluent
Chloride
Quarterly'
Composite
Effluent
Chronic Toxicity"
Quarterly
Composite
Effluent
Effluent Pollutant Scan
Monitor and Report
Footnote 9
Footnote 9
Effluent
Footnotes:
1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically
using NC DWR's eDMR application system. See Condition A. (7).
2. Instream monitoring shall be performed in accordance with A. (2).
3. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15 % of the respective
influent value (i.e., 85% removal is required).
4. The Permittee shall report all effluent TRC values reported by a NC -certified laboratory [including field -certified].
Effluent values below 50 µg/L will be treated as zero for compliance purposes.
5. Compliance with the Total Phosphorus limits shall be based on a calendar -quarter average of weekly samples.
6. Total Cadmium limits become effective 18 months after the effective date of this permit. Monitoring shall begin on the
effective date. See Condition A. (6).
7. Sample Quarterly in conjunction with Chronic Toxicity Test.
8. Chronic Toxicity (Ceriodaphnia) at 90 %; quarterly during March, June, September, December [see Condition A. (8)].
Page 3 of 9

Permit NCO026441
Footnotes A.(1) Continued:
9. The permittee shall perform three Effluent Pollutant Scans during the term of this permit [see Condition A. (9)].
b. Effluent shall contain no floating solids or foam visible in other than trace amounts.
A. (2) INSTREAM MONITORING REQUIREMENTS
Parameter.
Sample -Type _ ` `
Location . '
quench
Measuremen"t Fre``
Dissolved Oxygen
Grab
LCU, LCD, RRU, RRD
3/Week (June — September),
1/Week (October -May)
Temperature
Grab
LCU, LCD, RRU, RRD
3/Week (June — September),
1 /Week (October -Ma
Total Phosphorus
Grab
LCU, LCD, RRU, RRD
Monthly
TKN
Grab
LCU, LCD, RRU, RRD
Monthly
NO3-N + NOZ-N
Grab
LCU, LCD, RRU, RRD
Monthly
Footnotes:
1. LCU - Loves Creek, upstream of the discharge; LCD - Loves Creek, downstream of the discharge and above the
confluence with the Rocky River; RRU — Rocky River, upstream of the confluence with Loves Creek; RRD — Rocky
River, downstream of the confluence with Loves Creek.
2. All monitoring is required to be performed at the above -mentioned monitoring locations. Instream Monitoring
may be performed by the Upper Cape Fear River Basin Association as outlined in the Memorandum of Agreement
(MOA) between the association and the permittee. If so, the data is to be collected and submitted to DWR in
accordance to the terms of the MOA. Should membership in this association terminate for any reason, the permittee
shall immediately notify the Division's NPDES Unit in writing and resume responsibility to monitor and report the
above parameters as specified in this permit.
A. (3) NUTRIENT REOPENER
In the event that Permittee proposes to accept future industrial process wastewater that is expected to contain
concentrations of Total Nitrogen (TN) and/ or Total Phosphorus (TP) greater than typical domestic wastewater
concentration (i.e. greater than 40.0 mg/ L TN or greater than 5.0 mg/ L TP), the Permittee shall notify the NPDES
Complex Permitting Unit of the Division at 1617 Mail Service Center, Raleigh, NC 27699 and the Raleigh
Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 within 30 days of knowledge that the town is
considering accepting new industrial process wastewater containing excess nutrients. The notification shall
contain information regarding the proposed discharge flow, composition and treatability in the Siler City WWTP.
Changes in effluent characteristics may require a permit modification, so notification should be at least 180 days
prior to the start of the proposed discharge.
Based on information provided by the Town regarding a potential new industrial process wastewater with high
nutrient concentration, and pursuant to N.C. General Statute Section 143-215.1 and the implementing rules found
in Title I SA of the North Carolina Administrative Code, Subchapter 2H, specifically, 15A NCAC 2H.0112(b) (1)
and 2H.0I 14(a), and Part 11, Sections B-12 and B-13 of this permit, the Director of DWR may then reopen this
permit to require supplemental nutrient limits for Total Nitrogen and/ or Total Phosphorus in accordance with the
current Basin Plan for the Cape Fear River Basin.
Page 4 of 9

Permit NCO026441
A. (4) NUTRIENT WATER QUALITY MODELING REOPENER
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 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 or modified in this permit upon renewal.
A. (5) MERCURY MINIMIZATION PLAN (MMP)
The permittee shall develop and implement a mercury minimization plan (MMP) during this permit term. The
M1\4P 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 (http://portal.ncdenr.or web/wg/swp/ps/npdes, under Model Mercury
Minimization Plan). 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.
A. (6) COMPLIANCE SCHEDULE FOR TOTAL CADMIUM LIMITS
The limits for Total Cadmium shall begin 18 months after the effective date of this permit. Monitoring shall begin
on the effective date. If 12 monthly data points are all less than detect or a Reasonable Potential to Exceed WQ
standards analysis (RPA) indicates no potential, Permittee may petition the Division for removal of Total
Cadmium limits and monitoring from the permit. The Division will review the petition and data. If the Division
confirms that the results are all below detection levels, or if a Reasonable Potential Analysis examination of the
data shows no potential to exceed Water Quality Standards, the Division will proceed with modification of the
permit. Monitoring for Total Cadmium will remain on the LTMP. If the Data are not all less than detect, and
show Reasonable Potential to exceed Water Quality Standards, the limit shall remain on the permit, effective on
the above date. This limit removal will not be considered a permit modification requiring public notice.
A. (7) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify
that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will
be adopted and is beginning implementation in late 2013.
NOTE: This special condition supplements or supersedes the following sections within Part H of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
Page 5 of 9

Permit NC0026441
1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)1
Beginning no later than 270 days from the effective date of this permit, the permittee shall begin reporting
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 DENR / DWR / Information Processing Unit
ATTENTION: Central Files / eDMR
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.
Requests for temporary waivers from the NPDES electronic reporting requirements 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 using eDMR. Temporary waivers shall be valid for twelve (12) months and
shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the
permittee re -applies for and is granted a new temporary waiver by the Division.
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page:
httD://aortal.ncdenr.orp-/web/wa/admin/bop-/inu/edmr
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.
2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section
B. (11.)(a) or by a duly authorized representative of that person as described in Part H, 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://portal.ncdenr.org/web/wq/admin/bog/ip� u/edmr
Page 6 of 9

Permit NCO026441
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:
7 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. "
3. Records Retention [Supplements Section D. (6.)l
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 7 of 9

Permit NCO026441
A. (8) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to at an effluent
concentration of 90%.
The permit holder shall perform at a minimum, guarterly 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 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 TGP3B for the pass/fail results and THP311
for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental 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 Environmental 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 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.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such monitoring shall be
included in the calculation & reporting of the data submitted on the DMR & all AT Form submitted.
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 8 of 9

Permit NCO026441
A. (9) EFFLUENT POLLUTANT SCAN
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: 2016, 2017, and 2018. 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)
Trans-1,2-dichloroethylene
Bis (2-chloroethyl) ether
Chlorine (total residual, TRC)
1,1-dichloroethylene
Bis (2-chloroisopropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite
1,3-dichloropropylene
4-bromophenyl phenyl ether
Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Phosphorus
Methyl chloride
4-chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
1,1,2,2-tetrachloroethane
Di-n-butyl phthalate
Antimony
Tetrachloroethylene
Di-n-octyl phthalate
Arsenic
Toluene
Dibenzo(a,h)anthracene
Beryllium
1111,1-trichloroethane
1,2-dichlorobenzene
Cadmium
1,1,2-trichloroethane
1,3-dichlorobenzene
Chromium
Trichloroethylene
1,4-dichlorobenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid -extractable compounds:
Diethyl phthalate
Mercury (EPA Method 1631E)
P-chloro-m-cresol
Dimethyl phthalate
Nickel
2-chlorophenol
2,4-dinitrotoluene
Selenium
2,4-dichlorophenol
2,6-dinitrotoluene
Silver
2,4-dimethylphenol
1,2-diphenylhydrazine
Thallium
4,6-dinitro-o-cresol
Fluoranthene
Zinc
2,4-dinitrophenol
Fluorene
Cyanide
2-nitrophenol
Hexachlorobenzene
Total phenolic compounds
4-nitrophenol
Hexachlorobutadiene
Volatile organic compounds:
Pentachlorophenol
Hexachlorocyclo-pentadiene
Acrolein
Phenol
Hexachloroethane
Acrylonitrile
2,4,6-trichlorophenol
Indeno(1,2,3-cd)pyrene
Benzene
Base -neutral compounds:
Isophorone
Bromoform
Acenaphthene
Naphthalene
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chlorobenzene
Anthracene
N-nitrosodi-n-propylamine
Chlorodibromomethane
Benzidine
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3,4 benzofluoranthene
Pyrene
Dichlorobromomethane
Benzo(ghi)perylene
1,2,4-trichlorobenzene
191-dichloroethane
Benzo(k)fluoranthene
1,2-dichloroethane
Bis (2-chloroethoxy) methane
Reporting. Test results shall be reported on DWR Form -A MR-PPA 1 (or in a form approved by the Director) by
December 31' of each designated sampling year. The report shall be submitted to the following address: NC
DENR / DWR / Central Files,1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Page 9 of 9

Mckay, James
From: Forrest Westall <[e-mail]>
Sent: Monday, February 24, 2014 5:53 PM
To: Mckay, James
Subject: RE: Revised Draft Siler City WWTP, NCO026441
Hi Jim,
Just to let you know, I've sent the redraft and your letter to me to the Town and asked them to send you a note
confirming that they have reviewed the redraft and that it addresses the issues they raised. Hopefully they can e-mail
you an acknowledgement in the next couple of days.
Thanks for all your help.
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] l Fax: [phone]
Email: forrest.westallC&mc ile lengineers.com l Website: www.mc il� lengineers.com
From: Mckay, James [mailto James.mckay(&ncdenr.gov]
Sent: Monday, February 17, 2014 4:08 PM
To: Forrest Westall
Subject: RE: Revised Draft Siler City WWTP, NCO026441
Thanks,
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] — Voice/ [phone] — Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Forrest Westall [mailto:Forrest.Westall@)Mc ilclllengineers.Com]
Sent: Monday, February 17, 2014 4:01 PM
To: Mckay, James
Subject: RE: Revised Draft Siler City WWT'P, NCO026441
Thanks Jim. Check your cover letter. Your summary of the nutrient reopener references the TN and TP trigger levels as
ug/I . These should be mg/I. The permit itself has them as mg/I.
If you will send me the updated cover letter, I will get it to the Town for review and response.
Thanks again,
1

Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: forrest.westall(camcgillengineers.comlWebsite: www.mcgillengineers.com
From: Mckay, James fmailto:james.mckay(alncdenr ci
Sent: Monday, February 17, 2014 3:27 PM
To: Forrest Westall
Subject: Revised Draft Siler City WWTP, NCO026441
Forrest,
Attached is a copy of the revised Siler City draft permit. Please send any questions or comments by 2/28/2014. 1 hope
to issue this the first week in March, if possible.
Thanks,
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] —Voice/ [phone] — Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

Mckay, James
From: Mckay, James
Sent: Monday, October 21, 2013 2:31 PM
To: 'Forrest Westall'
Cc: Mike Apke; [e-mail]; Belnick, Tom
Subject: RE: Draft Renewal NPDES Permit for Siler City, NC0026441
Attachments: EMC Rocky River informational Item Jan 2011 final.pdf
Forrest:
Attached is the presentation to the EMC by Nora Deamer of Planning, January 2010. Note slide 19, " DWQs Next Steps",
first bulleted item regarding Total Nitrogen Limitation plans. Before the two poultry plants closed, the Division had
planned to add BAT limits on TN on this permit renewal, but due to the closing of the SIUs, resultant drop in TN
discharged, and consideration of the Town's fiscal problems, it was decided to add a reopener clause instead of adding
stringent TN limits at this time.
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] — Voice/ [phone] — Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Forrest Westall rmailto:Forrest.Westall(alMcaillenaineers.Com1
Sent: Friday, October 18, 2013 7:02 PM
To: Mckay, James
Cc: Mike Apke; [e-mail]; Belnick, Tom
Subject: RE: Draft Renewal NPDES Permit for Siler City, NC0026441
Thanks Jim. I appreciate the additional information. I hope you are having a good weekend.
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail]: www.mcgillengineers.com
From: Mckay, James rmailto:james.mckayAncdenr.govl
Sent: Friday, October 18, 2013 2:27 PM
To: Forrest Westall
Cc: Mike Apke; tgreen(cbsilercitv.org; Belnick, Tom
Subject: RE: Draft Renewal NPDES Permit for Siler City, NC0026441
Forrest:

1
Attached are a few files regarding nutrient problems and concerns in Love Creek and Rocky River. There is also a
presentation to the NPDES Committee by Nora Deamer in 2011. She is out today, I will try to get a copy Monday when
she is back.
Best regards,
Jim McKay
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] — Voice/ [phone] — Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Forrest Westall [mailto:[e-mail]]
Sent: Thursday, October 17, 2013 10:43 AM
To: Mckay, James
Cc: Mike Apke; [e-mail]; Belnick, Tom
Subject: Draft Renewal NPDES Permit for Siler City, NC0026441
Hi Jim,
The Town of Siler City has asked McGill Associates to assist them with the review of the subject draft renewal permit for
the Town's WWTP. The Town appreciates the opportunity to provide comments on the Draft and desires to work with
you and the Division in finalizing the conditions of this renewal permit. In reviewing the cover letter dated September
25, 2013 and the attached draft NPDES Permit, we noted that a copy of the Fact Sheet wasn't included. On behalf of the
Town, we request that a copy of the Fact Sheet for this draft be submitted via e-mail to us. I have included the
Town's Director of Public Works and Utilities, Terry Green, on the cc list of this e-mail, so please copy him and Mike
Apke on any follow-up e-mails. We also request that you forward any additional supporting information used to
develop the proposed changes in the current permit. We particularly would like to review background information you
and the Division used to propose revisions to permit conditions with respect to Cadmium, Mercury, and Nutrients
(reopener clause reference to the potential connection to the system of "nutrient discharging industry" and general
references in the cover letter to a "future TMDL for nutrients" that could require "very strict" TN limits).
It is the Town's intention to provide comments on the Draft Permit within the timeframe referenced in the September
25th cover letter. This is why I am asking for an e-mail response so that we can complete our review and provide timely
input to the Division before you proceed with reissuance this permit.
Thank you for your attention to this request and your assistance. If I can answer any questions, please let me know.
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] l Fax: [phone]
Email: [e-mail] l Website: www.mceillengineers.com

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SILER CITY. NORTH CAROLINA 27344-0769
P. O. BOX 769
311 N. SECOND AVE.
October 25, 2013
Mr. Jim McKay
Complex NPDES Permitting
North Carolina Division of Water Resources
1617 Mail Service Center
Raleigh, NC 21604
Submitted via First Class Mail and E-mail
Subject: Town of Siler City's Comments
Draft Renewal NPDES Permit
Town of Siler City W WTP
NPDES Permit Number, NCO026441
Dear Mr. McKay:
PHONE: [phone]
FAx: [phone]
The Town of Siler City appreciates the opportunity to comment on the subject renewal NPDES Permit for
our Wastewater Treatment Plant. In accordance with your letter transmitting the Draft, the Town is
submitting these comments within 30 days following our receipt of the Draft Permit. We also want to
thank you for the supplemental information that you have provided via a -mails on October 17'h, 18ie and
21". This additional information was provided in response to a request submitted to you by our
consultant, McGill Associates, on behalf of the Town.
On the basis of our review of the transmittal letter, the Draft Permit, and preliminary review of the
supplemental information provided, it is clear to the Town that you and the Division have considered a
significant amount of information in developing the proposed renewal that we have had limited
opportunity to review. Because of the significance of the changes you have proposed in this Draft
Renewal as compared to our current permit, we believe it is appropriate to delay issuance of this
permit until we have an opportunity to more completely review the basis the agency used for
proposing these changes and to work with DWR to resolve concerns we have about some of these
proposed changes. We believe that addressing these concerns prior to issuance of the renewal is the
most effective way to complete this permit renewal process. Because the Town is committed to
continuing its consistent compliance with the NPDES Permit, it is essential that we understand the basis

% r,
of these proposed changes, are clear on the approach the agency will use to regulate these conditions, and
that these conditions are appropriate for our facility.
In preparation for further discussion with you and the Division, I am providing comments for your
consideration. The summary comments below address important issues reflected in the transmittal letter,
including the letter's description of proposed permit revisions:
Page 1 Paragraph 2 Transmittal Letter. Concerns related to excess nutrients in Loves Creek and the
Roc , River. The Town acknowledges that monitoring and evaluation of these waters have indicated
increased growth of attached and suspended algae. However, data available shows that nutrient
contributions from the entire watershed are resulting in these conditions. Excessive aquatic vegetative
growth is occurring above and below the treatment system discharge. The Town's WWTP is one source
of nutrients in the watershed, but there are many others. There doesn't appear to be any definitive
technical conclusion about how nutrient loading should be addressed at this point.
Page 1. Paragraph 2. Transmittal Letter. Nutrient Reopener Clause trig eg red by connection o "a new
nutrient discharging industrv" allowing the agencv to modifv the permit and add new limits, The Town's
e' WWTP capacity is 4.0 MGD and is permitted for this flow. Our average discharge flow is currently
approximately 1.5 MGD. The term "a new nutrient discharging industry" is nebulous. Virtually any new
discharger of wastewater to our system will contain some level of nutrients. Commercial and residential
wastewater can be expected to contain a certain "standard" level of nutrient content (TN and TP) and this
reopener would not apply to such additions. Even if such a reopener is appropriate (and we would like to
discuss that issue), more specific definition of how the reopener would be triggered is needed.
Page I. Paragraph 2. Transmittal Letter: Holdintt, nutrient loads constant ,for new or expanded
discharges. The Town has no current plans to expand the WWTP. While this point is noted in relation to
what may happen with future permit actions, it is not a factor for this renewal.
Page 1, Paragraph 3, Transmittal Letter: Compliance inspection issues. The Town would like to offer
some general comments on the four issues the letter raises:
1) Standby Rower capacity. DWR's inspections have noted that the current backup generator
cannot run all components of the facility in the event of a power outage. The system in place
was permitted by the agency at the time it was builtlinstalled and is consistent with that
authorization to construct. As a result, the current standby power capability is not a permit
compliance issue. The Town acknowledges that upgrade of the generator system would be a
desired action, however sewer service revenue (as the Division's Fact Sheet for the draft
renewal notes) has dropped dramatically. The Town has a capital improvements plan and
will continue to pursue improvements as resources allow. We would like to clarify that this
issue isn't a compliance problem under the Town's permit and existing agency approvals.
2) "Lock -out" of basins 4 A and B. The Town is well aware of its decision to remove these
basins from the treatment process. The action taken was to protect the treatment process and
avoid any issues with the management of flow within the plant. The remaining operational
treatment system components are capable of providing the necessary treatment function
properly at the plant's design capacity. Repair of the basin is a needed improvement, but not

essential to the current plant's treatment ability. Repair is a capital improvement objective,
but as noted in 1) above the Town has to be judicious in the use of its available resources.
This too is not a compliance issue under the permit.
3) Excessive I&I. Your letter refers to a specific three day period in June of this year. It is well
know that 2013, particularly in the first half of the year, has been a high rainfall year in NC.
It would not be difficult to look at virtually any municipal sewage collection systems in NC
within a specific few days in 2013 to find a significant increase in flow due to high
rainfall/stream flows. Standard I&I evaluations look at plant flows and rainfall conditions
over long periods to determine the relative role of infiltration and inflow to the collection
system to characterize it as "excessive" or "normal." The Town operates under an agency
issued system -wide collection system permit. We are doing our best to comply with the
collection system permit requirements, including inspections, improvements, and the
development and implementation of a capital improvements plan for the system. I&I is an
important consideration for the Town and we certainly are working to eliminate non -
wastewater flows to our system. The determination that I&I is "severe" or "normal" has to be
made on the basis of a more comprehensive evaluation. References to the benefits of I&I .
reduction by the agency are certainly valid, but the Town is certainly not ignoring this
important system management responsibility.
4) Process changes to reduce TN levels in the effluent. As your letter notes and as addressed in
the supplemental information you provided, the Town doesn't have a TN limit in its current
permit and a limit is not being proposed for this renewal. We acknowledge P gP a that the reduction P g
of nutrients in the Loves Creek/Rocky River watershed is an important objective. As noted in
my comments above relative to the proposed "reopener" on nutrients, the Town's discharge is
one source of nutrients in the watershed. The level of effort and cost associated with
significant process changes to our facility which could result in biological nutrient reduction
is a significant undertaking. While reductions are desirable, there are important regulatory
evaluations concerning the appropriate distribution of nutrient reduction goals by the several
categories of sources in the watershed. As noted, the Town will certainly undertake
improvements of our wastewater collection/treatment system as resources allow, based on
priority. Achieving treatment results beyond that required under the permit is always
considered a positive.
Page 2, Second Paragraph, Item 2, Transmittal Letter, Proposed Permit Revision for the Sunnlement to
Cover Sheet, updated equipment description. The Town would like to review with you the changes
proposed to the equipment list to make sure the list properly reflects the treatment train at the plant.
Page 2, Second Paragraph Item 3 b. Transmittal Letter. Proposed Permit Revision. addition of Cadmium
C4 monitoring and limit. The Town has reviewed the supplemental information you provided on your
Reasonable Potential Analysis (RPA) concerning Cadmium. You noted that the dataset you used was not
collected under the NPDES monitoring requirements. The data came from the Town's Pretreatment
Program Long Term Monitoring Plan (LTMP). The tabular presentation of the RPA you provided notes
that the data available is "a limited data set." The Town is concerned that the Division is proceeding
toward establishing a limit without sufficient data to confirm the need for a limit. The Town has no

information indicating that there are specific sources of Cadmium in our collection system. Before taking
the step of requiring an effluent limit, we believe it is prudent and reasonable to collect significantly more
data on which to base a limits decision.
N�l Page 2 Second Paragraph, Item 7 Transmittal Letter, Proposed Permit Revision, Nutrient Reopener
�6 l Clause. We addressed this issue in our comments on Paragraph 2 of Page 1 above. I want to reiterate
that we see this proposed condition as too "open-ended" and not specific enough to determine what would
trigger the application of this clause.
Page 2 Second Paragraph, Item 8 Transmittal Letter Proposed Permit Revision Mercury Minimization
QPlan (AMP). The Town would like to discuss this with the Division to clarify this requirement and to
more completely understand its application. under the State's Mercury TMDL.
Part I A. (6), Pollutant Scan, Drufi Permit: Effluent Pollutant Scan. This condition requires the
collection and analysis of a pollutant scan sample in 2014, 2015 and 2016. The permit is drafted to expire
P October 31 2016 and the renewal application must be submitted no later than 180 days nor to
> PP Y P
expiration. This doesn't give the Town much timing flexibility in securing the results of the 2016 sample
before the renewal application. Additionally, this condition requires the pollutant scan to be collected in
conjunction with a toxicity test and that each of the annual pollutant scan samples must be taken in a
different quarter. The Town would like to discuss how best to provide the necessary samples and to be
able to review and submit that data as part of the renewal package.
Again, I would like to express the Town's appreciation for the opportunity to review the Draft and to
provide comments prior to the agency's issuance decision. We look forward to being able to further
discuss our comments and to address those prior to renewal issuance. Please contact me with any
questions you may have and to schedule a follow-up meeting to go over the issues we have raised.
Sincerely,
Bryan Thompson
Town Manager

Belnick, Tom
From: Mckay, James
Sent: Friday, October 25, 2013 11:41 AM
To: Belnick, Tom
Subject: FW: Town of Siler City's Comments, Draft Renewal NPDES Permit Number NC0026441
Attachments: Draft Renewal NPDES Permit - Siler City Comments - October 25, 2013.pdf
This just came in.
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] — Voice/ [phone] — Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Bryan Thompson rmailto:bthompsonCcbsilercity.o[g]
Sent: Friday, October 25, 2013 11:19 AM
To: Mckay, James
Cc: Forrest.Westall(abMcgillengineers.Com; Terry Green; Siler City Waste Water; Mike.Apke(alMgglllengineers.Com
Subject: Town of Siler City's Comments, Draft Renewal NPDES Permit Number NC0026441
Dear Mr. McKay,
Please find attached to this message the Town of Siler City's comments respective of the Draft Renewal NPDES
Permit. A hardcopy of the same is being forwarded to you as well. Thank you in advance for your
consideration.
Best,
Bryan Thompson
Town Manager
Siler City, NC
[phone] office
[phone] cell
[e-mail]
ne

NC wR � (�Al (A &all PerM f
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® North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
u_ ueU:E1 Iu
TO: Jim McKay, Complex NPDES Permitting Unit
Division of Water Resources
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 24 October 2013
SUBJECT: NPDES Permit Renewal for Town of Siler City, Siler City Wastewater Treatment Plant,
Chatham County, NPDES Permit No. NC0026441
Biologists with the North Carolina Wildlife Resources Commission have reviewed the subject
document. Our comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), and
North Carolina General Statutes (G.S. 113-131 et seq.).
The Town of Siler City has applied for a renewal of their NPDES permit to discharge 4.0 million
gallons per day (mgd) of treated process -contact and domestic wastewater into Loves Creek in the Cape
Fear River basin. The draft permit identifies several operational problems including the need to upgrade
the emergency backup generator to prevent releases of untreated waste, Basins 4 A & B are locked out of
service and isolated due to structural damage, June 2013 DMR records seem to indicate severe inflow and
infiltration (I & I), and excess nitrogen still affects water quality in Loves Creek even though Total
Nitrogen in the discharge has declined appreciably. It is suggested that any process changes that can be
made to reduce Total Nitrogen will help improve water quality. Also, all of the operational problems
should be addressed prior to requesting an increase in permitted flow or for new nutrient discharges.
Loves Creek is a tributary to Rocky River in the Cape Fear River basin. The Rocky River
supports a diverse fishery and there are records for the federal and state endangered Cape Fear shiner
(Notropis mekistocholas); the federal species of concern and state endangered Carolina creekshell (Villosa
vaughaniana), brook floater (Alasmidonta varicosa), and Atlantic pigtoe (Fusconaia masoni); the state
threatened creeper (Strophitus undulatus); the state special concern notched rainbow (Villosa constricta);
and the state significantly rare Eastern creekshell (Villosa delumbis) in Rocky River. The Significant
Natural Heritage Area — Upper Rocky River Aquatic Habitat — is located downstream of the discharge.
Should the permit be renewed, we offer the following comments and recommendations to reduce
impacts to aquatic resources.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
24 October 2013
Siler City WWTP
NPDES Permit No. NCO026441
1. Due to the presence of several federal and state listed species downstream of the discharge it is
imperative the facility remain in compliance with its permit limits. This includes having an
appropriate and functional emergency backup generator to prevent releases of untreated waste.
2. The draft permit indicates Copper, Zinc, and Chloride data showed reasonable potential to exceed
action level standards. Monitoring for these parameters will be quarterly (in conjunction with
Chronic Toxicity) with no limits. The previous permit had no limits, but monitoring for each
parameter was twice per month. Based on our review of EPA's Enforcement & Compliance
History Online (ECHO) and discussions with the Division of Water Resources it appears that
recently each of these parameters has been at or below action level standards. We will not object
to the reduction in monitoring for these parameters provided the facility remains in compliance
with their permit limits, particularly Chronic Toxicity, and there are no significant increases in the
concentration of any of these parameters in the discharge. Should the facility start to fail Chronic
Toxicity, or should the concentration of any of these parameters increase significantly over the
action level standards, then we recommend measures are taken to reduce the concentration in the
discharge, monitoring twice per month is re-established, and permit limits are set.
3. Excessive algal blooms have been documented in Rocky River downstream of Loves Creek.
Nutrients such as nitrogen and phosphorus are a needed component of the food chain in aquatic
ecosystems; however, excess nutrients can lead to algal blooms that may be detrimental to aquatic
life. Excessive algal blooms can degrade water quality and increase stress on fish. Increased
stress can manifest as disease or in extreme cases as a fish kill. Nutrient increases in Rocky River
are a multi -faceted issue (i.e., wastewater discharge, agriculture, urbanization, low flows, etc.).
We recognize that nutrients, particularly nitrogen, in the discharge have decreased significantly
over the years; however, we support any process changes in the facility that would further reduce
Total Nitrogen or other nutrients in the discharge.
4. The facility uses chlorine disinfection. We suggest the applicant consider replacing chlorine
systems with ultraviolet light or ozone systems. Chlorine is acutely toxic to aquatic organisms
and can form secondary compounds that are detrimental to aquatic life. Valenti (2006) concluded
the impact of long term exposure to low doses of chlorine may impact juvenile mussels and
reduce the chance of them being recruited to the reproducing population.
5. The draft permit indicates a potential severe I & I problem. Excessive I & I can result in sewage
volumes that exceed the design capacity or may cause sanitary sewer overflows. We encourage
the Town to start addressing the I & I problem. If I & I starts to result in the discharge of
untreated or undertreated wastewater, then we recommend immediate measures are taken to
reduce I & I.
Thank you for the opportunity to comment on this permit renewal. If we can be of further
assistance, please contact our office at [phone] or shari.bryant0mcwildlife.org.
Literature cited
Valenti, T.W., D.S. Cherry, R.J. Currie, R.J. Neves, J.W. Jones, R. Mair, and C.M. Kane. 2006. Chlorine
toxicity to early life stages of freshwater mussels (Bivalvia: Unionidae). Environmental
Toxicology and Chemistry, 25(9):2512-2518.
ec: Ryan Heise, NCWRC
Sarah McRae, USFWS
Tom Augspurger, USFWS

Mckay, James
From: Mckay, James
Sent: Thursday, October 24, 2013 2:53 PM
To: Bryant, Shari L.
Subject: RE: NCO026441 Siler City WWTP
Shari,
Thank you for your very prompt review of the Siler City Renewal Draft.
I will emphasize the recommendations for UV instead of chlorination for disinfection, the backup power deficiency and I
& I concerns in the permit cover letter. The nutrient, metals and chloride issues will be followed through our normal
Discharge Monitoring Reporting system. We are starting to implement EPAs new electronic reporting requirements with
new and renewed permits. Electronic reports will make discharge data more quickly available in the future.
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] — Voice/ [phone] — Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Bryant, Shari L.
Sent: Thursday, October 24, 2013 2:21 PM
To: Mckay, James
Subject: RE: NCO026441 Siler City WWTP
Jim,
Thanks for sending me a copy of the draft permit and for answering all of my questions the other day. Please find
attached our comments.
Shari Bryant
N.C. Wildlife Resources Commission
P.O. Box 129
Sedalia, NC 27342-0129
336.449.7625
shari.bryantC-ncwildlife.org
Get NC Wildlife Update -- news including season dates, bag limits, legislative updates and more -- delivered to your
Inbox from the N.C. Wildlife Resources Commission.
From: Mckay, James
Sent: Friday, October 04, 2013 10:57 AM
To: Bryant, Shari L.
Subject: RE: NCO026441 Siler City WWTP
Shari,

Attached is an electronic copy of the Draft Siler City WWTP permit.
Please send any questions or comments to me.
Thank you,
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] — Voice/ [phone] — Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Bryant, Shari L.
Sent: Friday, October 04, 2013 9:00 AM
To: Mckay, James
Subject: NC0026441 Siler City WWTP
Jim,
Would you please send me a copy of the Siler City WWTP NPDES permit renewal (NC0026441). An electronic copy is
fine.
Thanks.
Shari Bryant
N.C. Wildlife Resources Commission
P.O. Box 129
Sedalia, NC 27342-0129
336.449.7625
[e-mail]
Get NC Wildlife Update -- news including season dates, bag limits, legislative updates and more -- delivered to your
Inbox from the N.C. Wildlife Resources Commission.
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
2

From: Deamer, Nora bol3
Sent: Thursday, September 19, 2013 1:33 PM
To: Mckay, James
Subject: RE: Draft of Siler City NPDES Permit Renewal, NCO026441
Hi Jim, In reviewing the draft permit information you provided, an impairment in the Rocky River, below the
confluence with Loves Creek is not included.
Rocky River [AU# 17-43-(8)b2] is impaired due to a chlorophyll a standards violation behind Woody's Dam. This
impairment should be included in the first paragraph on page 2 of the NPDES Permit Draft Fact Sheet and
included in the first bullet of the NCO026441 Attachment I, Siler City NPDES Permit History.
The chlorophyll a impairment is directly linked to elevated nutrient concentrations in this portion of the
watershed. The data we have currently indicates that the WWTP is a large contributing source of the total
nitrogen in this segment of the watershed. The Raleigh Regional Office completed a special watershed study in
2010 which was used to present the conditions and water quality improvement activities that are ongoing in the
Ricky River Watershed to the EMC in January 2011. The RRO reported that the mainstem Rocky River below the
confluence of loves Creek often (low flow/base flow conditions) exhibits nutrient concentrations consistent with
receiving streams dominated by an activated sludge waste water system. These conditions have improved
somewhat since the closure of the poultry plants in 2008 and 2011.
Please let me know if you need any other information.
Thanks
Nora
From: Mckay, James
Sent: Wednesday, September 18, 2013 3:39 PM
To: Smith, Danny
Cc: Romanski, Autumn; Deamer, Nora
Subject: Draft of Siler City NPDES Permit Renewal, NC0026441
Danny,
Attached is a copy of the Siler City draft renewal. Please call me to set up a meeting between RRO staff, Nora
Deamer and me. We can meet at your office or here in the Archdale building. Nora and I both are available all
day (until about 3:00 PM when Nora has to leave to pick up a child from school) on Thursday 9-19-2013, Friday
9-20-2013 and Monday afternoon 9-23-2013.
The primary thing I think we need to go over is the new A.(3) Reopener clause. The other major changes are to
add limits for cadmium due to RPA, and a Mercury Minimization Plan required by the new TMDL.
Please call me if you have any questions before we get together. I am hoping to send this out to draft and public
notice Tuesday 9-24-2013.
Thank you,
Jim McKay, Environmental Engineer
NC DENR / Division of Water Resources
Complex NPDES Permitting Unit
file://E:1NC002644112013 Renewal\RE Draft of Siler City NPDES Permit Renewal NC0026441.htm

1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6404 (work); 919/807-6489 (fax)
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and
may be disclosed to third parties.
file://E:1NC002644112013 RenewallRE Draft of Siler City NPDES Permit Renewal NC0026441.htm

NPDES/A uifer Protection Permitting Unit Pretreatment Information Request Form
PERMIT WRITER COMPLETES THIS PART:
Date of Request 7/2/2013
I PERMIT WRITERS - AFTER you get this form back
Check all that
municipal renewal
apply
x
from PERCS:
- Notify PERCS if LTMP/STMP data we said should be
on DMRs is not really then:, so we can get it for you
(or NOV POT".
- Notify PERCS if you want us to keep a specific POC
in LTMP/STMP so you will have data for next permit
renewal.. - Email PERCS tlmft permit, fact sheet, RPA.
- Send PERCS paper copy of permit (w/o NPDES
boilerplate), cover letter, final fact sheet. Email RPA if
changes.
Requestor
Jim McKay
new industries
Facility Name
Slier City W WTP
W WTP expansion
Permit Number
Region
Basin
NCO026411
Raleigh
Cape Fear
Speculative limits
stream reGass
oudall relocation
7Q10 chan a
other
other
check applicable PERCS staff:
Other Comments to PERCS:
X
BRD, CPF, CTB, FRB, TAR - Sarah Morison 807-6310
CHO, HIW, LUM. LTN, NES, NEW, ROA, YAD - Monti
Hassan 807-6314
PERCS PRETREATMENT STAFF COMPLETES THIS PART:
Status of Pretreatment Program (check all that apply)
2) facility has no SIU's, does not have Division approved Pretreatment Program
Xd1) facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE
X 3) facility has SIUs and DWQ approved Pretreatment Program (list "DEV" if program still under development)
3a) Full Program with LTMP
3b) Modified Program with STMP
4) additional conditions regarding Pretreatment attached or listed below
Flow, MGD
Permitted
Actual
ITime period for Actual
I
STMP time frame:
Industrial
0.038
1 0.691
1 Jan 2009-March 2010
Most recent:
li
Uncontrollable
n/a
1 1.808
1 Jan 2009-March
2010
Next Cycle:
u
,I's
c
x
Parameter of
Concern (POC)
Check List
POC due to
NPDES/Non-
Dlach Permit
Limit
Required by
EPA'
Requlred
by 605
Sludge"
POC due
to SIU'"
POTWPOC
(Explain
below)"
STMP
Effluent
Freq
LIMP
Effluent
Freq
Q= Quarterly
M = Monthly
X
BOD
X
X
M
X
TSS
X
X
M
X
NH3
X
M
X
Arsenic
X
M
Cadmium
X
I
I
M
Chromium -
M
Copper
X
M
Cyanide
M
Is all data on DMRs?
Lead
X
M
YES
X
Mercury
X
M
NO attach data
X
Molybdenum
X
M
Nickel
X
M
Silver
I M
X
Selenium
X
M
Zinc
X
M
Is data in s readsheet?
X
Total Nitrogen
M
YES email to writer
X
X
Phosphorus
X
M
NO
X Oil and Grease X M
X Chloride X M
`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 concern to POTW
Comments to Permit Writer (ex explanation of any POCs• Info you have on IU related investloations Into NPDES problems):
Townsends shut down their facility in Sept. 2011 and their permit was rescinded on December 27, 2012. Current permitted SIU flow is
.035 MGD for Brookwood Farms. Chloride and TN are monitor only parameters at the SIU. Oil and Grease is only sampled at the
Siler City NPDES PretreeMent request July 2013
Rewsed: July 24. 207

Ncn I 6 4Y l 3�ZolL
Belniek, Tom
From: Belnick, Tom
Sent: Thursday, March 15, 2012 4:53 PM Rglo C ��&q &a ✓t aAI {/�
To: Smith, Danny; Grzyb, Julie
Subject: RE: Siler City WWTP, Chatham Co data
Thanks Danny- looks like — 50% decrease in TN conc. and — 90% decrease in TP conc. I'll ask Julie to set up a meeting
when she gets to that permit renewal.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Smith, Danny
Sent: Thursday, March 15, 2012 2:47 PM
To: Belnick, Tom; Grzyb, Julie
Subject: Siler City WWTP, Chatham Co data
Tom
Per your request here is Siler City effluent analysis for flow, TN and TP. I have some thoughts on the Nutrient issues and
recommend that we talk it over when you get to this permit... Anyway.. I hope this is helpful ... If you have questions
please do not hesitate to call me... I will be happy to come over to discuss. (Sorry for the delay. I had difficulty getting
the data from RIMS.)
Danny

The below listed analysis are the effluent results from the Town of Siler City (January 2007 through
December 2011) for flow, TN, and TP. In addition, flow, TN, and TP distributions are further compared
with consideration to changes to industrial wastewater discharges to the POTW based on following
criteria:
January 2007 through July 2008: Two chicken processing plants (Significant Industrial Users),
Pilgrim's Pride Corporation and Townsend, discharge process wastewater to the POTW.
August 2008 through September 2011: Pilgrim's Pride no longer Discharges (SIU permit ended
July 2008). Townsend continues to operate and discharges to the POTW.
October 2011-December 2011: Townsend is no longer in operation and has stopped
discharging to POTW. (Both industries (currently)no longer discharge to the POTW).
Siler City WWTP: January 1, 2007— December 31, 2011
Box Plot
8
7
Descriptive Statistics
Flow 6
Ntean
2.196 5
Std. Dev.
.786
Std. Error
.018 4
Count
1826 3
Mnirrum
.838
2
N13xirtum
7.344
# Mssing
0 1
Variance
.618 0
Median
2.120
Flow

8
7
6
5
�4
3
2
1
0
Un ivariate Scatte rg ram
..1�..�}vl*-:J . }. • •..a...:...: s;�:.:.......s....:..;..: .... ....... �....... t.its`....
........................ S i• ~+f- ..: '•�' .; • , .�?' '.'- 7 , may.• t : ' f'• .�, _• :.
..r7 ,.J+sya; .:..., �s...:...i..:��..' `R—s•�7`.:..$r ' .,,::i. '' T :......
.»�..�...:.::....„s.....t...t....a:.:�t•Si.:.............:..:5....«1..........s..s_1:i....41*.sx�..k:�....{..t.�..:tr.•
P.
Observations
+1 SD
Mean
-1 SD

Descriptive Statistics
Flow Jan07-Jul 08
Flow AugO8-Sept2011
Flow Oct-Dec2011
8
7
6
5
4
�3
2
1
0
Man Slrl. rl�v Sfrl Frrnr rnnM Mnimim M vimim AMeeinn Kb i-
2.365
1 .797
.033
578
.974
7.3441
1248
.638
2.378
2.178
.748
.022
1156
.924
7.019
670
.560
2.088
1.381
.626
1 .0651
92
.8381
5.2561
1734
.391
1.224
Box Plot
8
7
6
5
4
3
2
1
0
5 0 N
? u
O L4.11
0Z
LL 2� 6
b
LL
Univariate Scattergram
Observations
Univarlat• Se rgram
5.5
5
4.5
4
3.5
3
2.5
2
1.5
1
5
OEservabons
• Flow Jan07-Jul 08
• Flow AugO8-Sept 2011
• Flow Oct-Deo2011

Descriptive
Nkan
Std. Dev.
Std. Error
Count
Mninum
Maxinum
# Mssing
Variance
Wedian
Statistics
TN 2007-2011
25.429
9.487
.688
190
1.940
64.100
1636
90.007
26.650
Univariate Scattergram
70
60
o50
N 40
ri
g 30
z
20
10
0
Box Plot
70
60
50
40
30
20
10
n
•
•
�.•
N b 0
•♦
•
Observations
•
+1 SD
Wan
-1 SD
Descriptive Statistics
Man Std. Dev. Std. Error Count Mninum Maximum # Mssino Variance Wdian
TNIan07-JUI08 133.3161 12.237 2.807 19 15.500 64.100 1807 149.746 33.100
TN4ug08-Sept2011 125.2131 8.646 .6881 158 1.9401 43.800 1668 74.749 26.850
TN Oct-Dec2011 16.534 5.496 1.524 13 8.240 28.700 1813 30.2101 15.500

70
60
50
40
30
20
10
0
Box Plot
L-
TWan07-JuIO8 TNAug08-Sep12011 TNOctDec2011
Univariate Scattergram
70
60
50
240
a
m
j 30
20
10
0
Observations
• TNJan07-JU108
• TNAug0S-Sept2011
• TN Oct-Dac2011
0 SD (TNJan07-Ju108)
%§R(fmmg4@~011)
awn (TNAu O&Sep 11)1)
MESED(IPIk SOtmii)
.1 SD(TN Oct-Dec2011)

Descriptive
Nban
Std. Dev.
Std. Error
Count
Mninum
Maximum
# Mssing
Variance
Median
Statistics
TP2007-2011
.889
1.264
.082
235
.020
4.950
1591
1.598
.210
6
5
4
3
2
1
0
_1
Box Plot
•
TP2007-2011
Univariate Scattergram
6
5 • •
4. j • •••
• ••I P
N 3 f •� •
n • •0 •
2-& ........... .................t......._.......... _...... _............. ...•.... .......... . +1 SD
H •
1.......... •—'---'---..—_.—...__.. Mean
0---.._-.._._................_.�_..
............_............................................................................................ _.._................._............ _1 SO
-1
Observations

Descriptive Statistics
Mean Sid. Dev. Std. Error Count Mnirrum Maximum # Mssino Variance Median
TPJan07-JulO8
TPAug08-Sept2011
TPOct-De02011
Box Plot
6
5 •
4-
3-
2-
1
0-
-1
1.3981
1.443
.1581
83
.0361
4.950
17431
2.084
.664
1.095
.093
139
.020
4.890
1687
1.198
;.0399
.044
.015
.004
13
.030
.076
1813
2.138E4
TPJan07-JulO8 TPAug08-Sept2011 TPOct-Dac2011
• TPJan07-JUI08
• TPAug08-Sept2011
• TPOct-Dec2011
+1 SD (TPJan07-Ju108)
+1 SD((TPAugg08- 12011)
Mean (TPJan07-Jul )
Nan (TPAug08-Sept2011)
-1 SD TPAug08-Se 011)
Observations

Affidavit Of Publication: Lee County, North Carolina
The Sanford Herald is a newspaper with a general circulation to actual paid subscribers admitted to the
United States mail in the Periodicals class in Lee County. The Sanford Herald has been published at least one
day in each calendar week for at least 25 of the 26 consecutive weeks immediately preceding the date of this
affidavit.
Holly Hight, Classified Advertising Representative of The Sanford Herald, a newspaper published in Lee
County in the state of North Carolina, being duly sworn, deposes and says: that the attached advertisement of
notice, in the action entitled:
was duly published in the aforesaid newspaper once a week for I consecutive weeks, beginning with
the issue dated thc')-2 day o , and ending with the issue dated thQD day of
apt 3.
Received of N `L� � (2 I I✓WQ I �j
$ 1 the cost of the above publication.
By:
Holly HigwKlaified Adve ising Representati
Sworn to and subscribed before e, this'( lay of
Notary
!�ia-(5
My Commission Expires

. 'MM
Public Notice
North Carolina 5nvironment-
al Manageme,d Commis-
sion/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
The North Carolina Environ-
mental Management Com-
mission proposes to issue a
NPDES wastewater dis-
charge permit to the
person(s) listed below. Writ-
ten comments regarding the
proposed permit will be ac-
cepted until 30 days after
the publish date of this no-
tice. The Director of the NC
Division of Water Re-
sources (DWR) may hold a
public hearing should there
be a significant degree of
Public interest. Please mail
comments and/or informa-
tion requests to DWR at the
above address. Interested
persons may visit the DWR
at 512 N. Salisbury Street,
Raleigh, NC to review in-
formation on file. Additional
information on NPDES per-
mits and this notice may be
found on our website:
httpl/portal ncdenr orp/web/
w sw.T✓Ps/npdes/ t n r,
orb calling (9191807-8390.
Town of Slier City reques-
ted renewal of permit
NCO026441 for Siler City
WWTP. This facility dis-
charges treated industrial
and domestic wastewater to
Loves Creek, Cape Fear
River Basin.