NC0037834_Fact Sheet_20240311

NC0037834
Fact Sheet
NPDES Permit No. NCO037834
Permit Writer/Email Contact: Gary Perlmutter, [e-mail]
Date: March 8, 2024
Division/Branch: NC Division of Water Resources/NPDES Compliance and Expedited Permitting Unit
Fact Sheet Template: Version 08Sept2016
Permitting Action:
N Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
City of Winston Salem / Archie Elledge WWTP
Applicant Address:
P.O. Box 2511, Winston-Salem, NC 27102
Facility Address:
2801 Griffith Rd, Winston-Salem, NC 27103
Permitted Flow:
30.0 MGD
Facility Type/Waste:
MAJOR Municipal / 91.5% domestic; 8.5% industrial'
Facility Class:
Grade IV
Treatment Units:
Bar screens, grit basins, primary clarifiers, aeration basins, final
clarifiers, sodium hypochlorite and bisulfite feed for disinfection and
dechlorination, lime magnesium hydroxide blend and caustic feed for
alkalinity control, centrifuges with screw conveyors, sludge digestion,
polymer and iron salt feed, odor control systems, sludge drying facility,
waste sludge lagoons, instrument flow meter
Pretreatment Program (Y/N)
Yes, active
County:
Forsyth
Region:
Winston-Salem
Footnote.
1. Based on a total permitted SIU flow of 2.54 MGD.
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NC0037834
Briefly describe the proposed permitting action and facility background: The City of Winston-Salem has
applied for NPDES permit renewal for its Archie Elledge WWTP and submitted a renewal application dated
December 17, 2021, received December 28, 2021. Review of the application found it incomplete with
chemical addendum lacking. In response to the Division's request for a Chemical Addendum, the facility's
lab supervisor stated that no additional pollutants are expected, nor were any sampled. PPAs were sampled
in October 2017, April 2019, June 2019, and January 2021; 2nd species tests were conducted in April 2018,
July 2019, October 2020, and November 2021.
At the time of application submission, the facility served a population of—92,000 residents including the
City of Winston-Salem (-86,000), Town of Walkertown (-4000) and unincorporated Forsyth County
(-2000). The Town has an active pretreatment program, with 27 Significant Industrial Users (SIUs), 10 of
which are categorical SIUs (CIUs). Prior to the renewal application submittal, the City had proposed in
February 2021 to include additional SIUs in the South Fork Basin split their pretreated effluent flow to
Archie Elledge WWTP and Muddy Creek WWTP (NC0050342), identified as 25% and 75%, respectively.
As a result, Archie Elledge WWTP is sharing receiving wastewater with Muddy Creek WWTP from an
additional 9 SUIs beginning 2020 as noted in their renewed Industrial User Permits (IUPs), all effective
7/1/2022.One SIU, Dormakabe has been dropped from the program in June 2019 due to its closing; another,
Environmental Relief Technologies (ERT) has closed and ceased operations in May 2022.
Inflow & Infiltration (I&I). Current I&I flow is reported at 4.3 MGD in the permit renewal application. The
City reports that improvements with its collection system are underway with lines inspected and cleared
annually and several rehabilitation projects underway.
Sludge management. According to the sludge management plan submitted with the permit renewal
application, sludge is anaerobically digested and with the digested sludge pumped from Muddy Creek
WWTP is sent to two blending tanks at Archie Elledge WWTP. At Archie Elledge WWTP the sludge is
blended with the latter WWTP's sludge, then centrifuged to create pellets which are then land applied as
Class A biosolids under permit number WQ0029804 or disposed of by other approved methods.
The facility has three lagoons for holding liquid centrate from the sludge pelletizing process. Through
instream monitoring, high Fecal Coliform counts were found in the upstream location, which lies
downstream of the lagoons. Investigation by the City in summer 2023 has found that leakage from Lagoon
#2's embankment was entering Salem Creek. As part of the investigation, the City has also collected
groundwater data from monitoring wells surrounding the lagoons, finding levels of Ammonia and Fecal
Coliform exceeding their respective groundwater standards (Table 1). The City plans to renovate Lagoon 1
and likely renovate Lagoon 2 for redundancy, and close Lagoon 3. A special condition for lagoon closure
and associated groundwater monitoring was added to the permit.
Table 1. Lagoon Groundwater Data Summary, July 2022 — May 2023.
Parameter
Units
Average
Maximum
Minimum
Standard
Ammonia
mg/L
24.1
164
< 0.1
1.5
Fecal Coliform
#/100 mL
5.8
5000
< 1
1
(geomean)
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NC0037834
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 / Salem Creek (Middle Fork Muddy Creek)
Stream Segment:
12-94-12-(4)c
Stream Classification
C
Drainage Area (mi2):
67.3
Summer 7Q 10 (cfs)
15
Winter 7Q 10 (cfs):
18
Average Flow (cfs):
65
IWC (% effluent):
76
2022 NC 303(d) listed/parameter:
Turbidity, Benthos, Copper, Zinc
Subject to TMDL/parameter:
Statewide Mercury TMDL
Basin/HUC:
Yadkin -Pee Dee / 03040103
USGS Topo Quad:
Winston-Salem West, NC
The receiving stream segment 12-94-12-(4)c stretches 2.6 river miles from SR 1120 (West Clemmonsville
Rd) to the confluence of Salem Creek with Muddy Creek, and is impaired for Turbidity, Benthos, Copper
and Zinc. Turbidity was found to exceed the stream standard of 50 NTU in 2022. Benthos assessments have
consistently resulted in Fair bioclassifications from 1996 through 2016 at Benthos Station Q13167, -1.9
miles downstream of the outfall. Copper and Zinc impairments are from Legacy Category 5 Metals
Assessment in 2008. The stream segment immediately upstream, 12-94-12-(4), is impaired for Fish
Community from an assessment in May 2016 at Fish Community Station QF65, -1.0 mile upstream of the
discharge, resulting in a Fair bioclassification.
3. Effluent Data Summary
Effluent data are summarized below for the period January 2019 through June 2023.
Table 2. Effluent Data Summary.
Parameter
Units
Average
Max
Min
Limits 1
Flow
MGD
20.45
78.29
11.86
MA = 30.0
BOD5
mg/L
7.5
55.0
1.7
MA = 21.0
(Apr 1-Oct 31)
WA = 31.5
BOD5
mg/L
10.4
I+_ -
2.0
MA = 30.0
(Nov 1-Mar 31)
WA = 45.0
BOD removal
%
97.6
99.0
93.5
> 85
FTss
mg/L
7.6
106.0
2.5
MA = 30.0
WA = 45.0
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NCO037834
TSS removal
%
97.6
99.0
93.9
> 85
NH3-N
(Apr 1-Oct 31)
mg/L
0.50
600
< 0.02
MA = 1.2
WA = 3.6
NH3-N
(Nov 1-Mar 31)
mg/L
'1.70
4.Sr
< 0.02
MA = 2.4
WA = 7.2
DO
mg/L
6.5
> 6.5
Fecal Coliform
(geometric mean)
#/100 mL
8
> 2420
< 1
MA = 200/ 100
WA = 400/100
Total Residual
Chlorine (TRC)
µg/L
20
30
< 20
DM = 22.5 2
Total Nitrogen
mg/L
15.1
44. �
8.8
Monitor & Report
Total Phosphorus
mg/L
1.82
15.22
0.16
Monitor & Report
Temperature
°C
21
29
12
Monitor & Report
Conductivity
µmhos/cm
600
939
339
Monitor & Report
Total Zinc
µg/L
64
93 -7
46
Monitor & Report
Total Cadmium
µg/L
All < 0.15
Monitor & Report
Total Cyanide
µg/L
19
20
5
Monitor & Report
pH
SU
7.0
7.6
6.2
6.0-9.0
Dichlorobromomethane
µg/L
10.7
23.1
< 1.0
Monitor & Report
Chlorodibromomethane
µg/L
4.5
12.2
< 1.0
Monitor & Report
Total Hardness
mg/L
56
80
26
Monitor & Report
Footnotes.
1. MA = Monthly Average; WA = Weekly Average; DM = Daily Maximum.
2. Compliance level = 50 µg/L
The highest annual average flow was 21.43 MGD (71% of the limit) in calendar year (CY) 2021.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when
model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify
model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream
concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions
established in several basins that conduct instream sampling for the Permittee (in which case instream
monitoring is waived in the permit as long as coalition membership is maintained).
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): Yes.
Name of Monitoring Coalition: Yadkin -Pee Dee River Basin Association (YPDRBA).
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NC0037834
If applicable, summarize any instream data and what instream monitoring will be proposed for this permit
action: The current permit requires instream monitoring for BOD, Ammonia, Dissolved Oxygen (DO),
Fecal Coliform, Temperature, Conductivity, and Total Hardness. The upstream location is Salem Creek
—1300 ft above NCSR 1120 (West Clemmonsville Rd), —1750 ft above the outfall. Downstream locations
are: (1) Salem Creek at NCSR 2991 (Fraternity Church Rd), —2 miles from the outfall; (2) Muddy Creek at
NCSR 1493 (Frye Bridge Rd), —4.9 miles from the outfall; and (3) Muddy Creek at NCSR 1485 (Hampton
Rd), —7.7 miles from the outfall. The nearest water supply watershed downstream of the outfall is the
Yadkin River (Davidson County), whose WS-IV boundary lies —7.8 miles from the discharge. Hardness is
sampled upstream for calculation of dissolved to total metals for hardness -dependent metals, including
Copper, and is addressed in the Reasonable Potential Analysis (RPA) portion of Section 6 - Water Quality -
Based Effluent Limits (WQBEL). The permit has a special condition exempting instream sampling at times
when flow conditions are unsafe; this condition has been maintained.
Since the City is a YPDRBA member, instream sampling is provisionally waived. Instream monitoring is
performed by the coalition at stations Q2540000 Salem Cr at SR 1120 (upstream) and Q2570000 - Salem
Cr at SR 2991 (same as downstream 2 in the permit). Instream data collected from January 2019 —
December 2022 were obtained from the Division's monitoring coalition database for the above stations for
review. Data were compared against corresponding instream water quality standards and between stations
as well as concurrent effluent data for assessment of effluent impacts. Averages were compared using
Student's t-tests with levels of significant differences set at p = 0.05. For fecal coliform geomeans, t-tests
were run on the log -transformed data. Summary data are in Table 3.
Table 3. Instream monitoring averages and ranges (in parentheses) of permit -required parameters.
*Statistically different from Upstream.
Parameter
Upstream
Downstream
Standard'
BODs, mg/L
Not monitored by YPDRBA
NA
Ammonia (NH3-N), mg/L
Avg = 0.21
Avg = 0.19
NA
(0.02-0.60)
(0.02-0.98)
Dissolved Oxygen (DO), mg/L
Avg = 8.6
Avg = 7.9*
DA = 5.0
(6.4-14.0)
(4.9-11.7)
Instant = 4.0
Temperature, °C
Avg = 19.2
Avg = 20.4
29.0
(6.2-28.9)
(6.7-29.3)
Specific Conductance, µS/cm
Avg = 142
Avg = 284
NA
(64-220)
(51-496)
Fecal Coliform, cfu/100 mL
Geomean = 612
Geomean = 479
MA = 200
(geometric mean)
(50-9800)
(45-9400)
WA = 400
Total Hardness, mg/L
Avg = 49
NA
NA
(29-80)
Footnotes
1. DA = Daily Average; DM = Daily Maximum.
Biological Oxygen Demand (BOD) — Instream BOD is in the permit as a parameter of concern for aquatic
life as it is an oxygen -consuming waste. The YPDRBA does not monitor for this indirect parameter;
instream BOD data are not available for review.
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NC0037834
Ammonia (NH3-N) — Instream Ammonia is in the permit as a parameter of concern for aquatic life as it is
an oxygen -consuming waste and is toxic to aquatic life. Average downstream ammonia concentrations were
slightly lower than upstream, but not statistically significant.
Dissolved Oxygen (DO) — Instream DO remains in the permit as a parameter of concern for aquatic life.
Reviewed instream YPDRBA data revealed summer lows to be above the stream standard of 5.0 mg/L with
one downstream value below at 4.9 mg/L on 7/26/2022. A statistically significant difference was detected
between the two station DO averages with the downstream tested lower. Concurrent effluent DO data
appeared lower on average but with no values below 6.5 mg/L.
Temperature - Instream Temperature remains in the permit as a parameter of concern for aquatic life.
Upstream temperatures in both sites were below the standard of 29°C for upper piedmont and mountain
waters, but one value downstream, on 7/20/2022, exceeded the standard at 29.3°C. No statistically
significant differences were detected between the two station temperature averages. There were five
occurrences where the downstream temperature exceeded the water quality standard of 2.8 °C above the
natural water temperature when compared to upstream data. Concurrent effluent temperatures were higher
on average with winter lows substantially higher than those instream.
Specific Conductance — Specific Conductance (Conductivity at 25°C) is in the permit as an indicator of
industrial waste. The facility has a pretreatment program with several SIUs. Downstream average specific
conductivity has tested statistically significant as higher than upstream average specific conductivity with
the average twice that upstream.
Fecal Coliform — Fecal Coliform remains in the permit as a parameter of concern for aquatic life and human
health. The downstream geomean was substantially lower than that upstream with fewer monthly results
over 200 cfu/100 mL (40 upstream vs. 37 downstream). However, no statistical differences were detected
when log data were tested. Concurrent effluent Fecal Coliform counts were much lower by geomean than
either instream station. From these high counts the City has found the source to be a leaking embankment
from one of the facility's three sludge holding lagoons, which lies upstream of the outfall. The leaking
lagoon, Lagoon #2, has been placed out of service until repairs are made. See Section 1 above for more
information regarding lagoons.
In addition to the above permit -required parameters, the YPDRBA also monitors for Inorganic Nitrogen
(NO2+NO3), Total Kjeldahl Nitrogen (TKN), pH, Total Phosphorus and Turbidity. Monitoring data are
summarized and discussed below.
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NC0037834
Table 4. Instream monitoring averages and ranges (in parentheses) of additional, non permit -required
parameters. *Statistically different from Upstream.
Parameter
Upstream
Downstream
Standard
Inorganic Nitrogen (NO2+NO3), mg/L
Avg
= 1.06
Avg =
3.83 *
NA
(0.29-1.70)
(1.20-7.49)
Total Kjeldahl Nitrogen (TKN), mg/L
Avg
= 0.69
Avg = 1.23*
NA
(0.28-2.08)
(0.44-2.35)
Total Phosphorus, mg/L
Avg
= 0.06
Avg =
0.60*
NA
(0.02-0.35)
(0.02-3.25)
pH, SU
Avg
= 6.9
Avg
= 6.9
r
(5.2-7.3)
(6.4-7.4)
Turbidity, NTU
Avg
= 20.5
Avg
= 27.1
50
(2.3-110)
(3.6-170)
Review of the additional monitoring data found statistically significant increases in nutrient parameters
(NO2+NO3, TKN, TP), but not pH or Turbidity. Instream monitoring for nutrient parameters Total Nitrogen,
its components NO2+NO3, TKN, and Total Phosphorus has been added to the permit, each at a monthly
frequency.
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): From July 2018 through June
2023 the facility had reported no limit violations resulting in enforcement.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): The facility passed all 16 quarterly chronic toxicity tests, as well as all 4 second species chronic
toxicity tests. Second species tests were sampled in April 2018, July 2019, October 2020, and November
2021.
Summarize the results from the most recent compliance inspection: The most recent facility inspection, a
compliance inspection conducted on 6/29/2023, reported no issues or violations. In April 2022 a
pretreatment inspection was conducted and likewise found the program satisfactory.
6. Water Quality -Based Effluent Limitations (WQBELs)
6.1. Dilution and Mixing Zones
In accordance with 15A NCAC 213.0206, the following stream flows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA.
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA.
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6.2. Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD = 30 mg/L for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: Current BOD limits
are based on a 1991 QUAL2E model run using Ammonia and DO concentrations of 1.2 and 6.5 mg/L,
respectively, which are also placed as limits. These limits conserve instream DO protection while allowing
the facility to maintain compliance, as the original 1990 model results were 16 mg/L BOD (summer), 2
mg/L Ammonia (summer) and 6.0 mg/L DO (year-round), to which the City expressed concern being able
to meet the recommended 16 mg/L BOD limit.
6.3. Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/L (summer) and 1.8 mg/L (winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 µg/L) and capped at 28 µg/L (acute impacts). Due to analytical issues, all TRC values
reported below 50 µg/L are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: The current permit
has one set of summer Ammonia limits and two sets of winter Ammonia limits. The summer Ammonia
limits of are based on a 1991 QUAL2E model run to protect the stream DO and the latter set of winter limits
are based on protection against Ammonia toxicity, also established in 1991. The first set of winter limits
are interim limits with a compliance schedule to meet the latter limits by May 31, 2018.
Since the compliance date has passed, the interim winter Ammonia limits and the Ammonia compliance
schedule special condition will be removed from the permit. A Wasteload Allocation was conducted using
the permitted flow of 30 MGD, and 7Q10 low flows of 15 cfs (summer) and 18 cfs (winter). Upon review
of the WLA, the existing limits were found to be protective. The same WLA was run to calculate allowable
TRC concentrations, with results the same as the current permit limit. No changes were made.
6.4. Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of 1/2 detection limit for "less than" values; and 4) stream flows used for dilution
consideration based on 15A NCAC 213.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
Effluent and instream (upstream) Hardness monitoring is required in the current permit. Permittee-
submitted DMR Hardness data were used in the RPA for hardness -dependent metals.
A reasonable potential analysis was conducted on effluent toxicant data collected between January 2019
through June 2023. Pollutants of concern included toxicants with positive detections and associated water
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quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria: None.
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but
the maximum predicted concentration was > 50% of the allowable concentration: Total Cyanide,
Copper and Zinc.
o Cyanide — In 1996, the City had conducted a special study for Toal Cyanide, which
concluded that a 20 µg/L cyanide quantitation level was appropriate for the wastewater
matrix present, to which the Division accepted for the permit at that time. As analytical
technologies have improved since 1996 and in consultation with the Division's Laboratory
Certification Branch, the required PQL will be lowered to 10 µg/L and specified in a
footnote on the effluent sheet of the permit.
o Copper and Zinc both parameters are to be monitored quarterly because the receiving
stream is impaired for copper and zinc.
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was < 50% of the allowable concentration: Arsenic,
Beryllium, Cadmium, Chromium, Total Phenolic Compounds, Fluoride, Lead, Molybdenum,
Nickel, Selenium, Silver, Chlorodibromomethane, Dichlorobromomethane.
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern. Samples for the pollutant scans were collected in October 2017,
April 2019, June 2019, and January 2021. The following pollutants were detected: Antimony,
Chloroform.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: None.
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: None.
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
6.5. Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions.
The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits,
using single concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: This is a Major POTW with a chronic WET limit at 76%
effluent, monitored at a quarterly frequency. No changes were made.
6.6. Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
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wasteload allocation for point sources of 37 kg/year (81 lb/year) and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (> 1 ng/L) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/L) and/or if any individual value exceeds a TBEL value
of 47 ng/L.
Describe proposed permit actions based on mercury evaluation: The current permit requires a Mercury
Minimization Plan with a summary of actions to be submitted with the permit renewal application. The
City posts mercury minimization activities on their website; the link is provided here:
https://www.cityofws.org/2723/Dental-Amalgam-Discharges. Evaluated low level mercury data are in
Table 5 below.
Table 5. Mercury Effluent Data Summary
2019
2020
""""
""3
# of Samples
3
4
4
2
Annual Average Conc. Ng/L
1.6
1.0
2.5
1.1
Maximum Conc., ng/L
2.17
1.39
1.16
5.26
1.34
TBEL, ng/L
47
WQBEL, ng/L
15.9
Since no annual average mercury concentration exceeded the WQBEL, and no individual mercury sample
exceeded the TBEL, no mercury limit is required. However, since the facility is >2 MGD and reported
quantifiable levels of mercury (> 1 ng/1), a mercury minimization plan (MMP) is required and has been
maintained.
6.7. Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: Currently there is no nutrient management strategy in the watershed wherein the WWTP
discharges into; however, one is in development. The High Rock Lake Nutrient Strategy development
process had begun in September 2022, in response to the lake's designation as impaired for Chlorophyll -a
in 2004. The current permit has Nutrient Reopener for High Rock Lake special condition, which has been
maintained.
The current permit has monthly monitoring requirements for Total nitrogen (TN) and Total Phosphorus
(TP) of the effluent. To better understand the nitrogen in the discharge, monthly monitoring of Total
Kjeldahl Nitrogen (TKN) and Nitrate -Nitrite Nitrogen (NO3+NO2) has been added to the permit. In
addition, instream monitoring for the above nutrient parameters has been added based on coalition data
review (See Section 4 above).
6.8. Other WQBEL Considerations — Permit Limit Development
If applicable, describe any other parameters of concern evaluated for WQBELs: To address emerging
contaminants such as 1,4-Dioxane and PFAS, a Chemical Addendum to the application request was sent to
the ORC on 7/25/2023. In response, the ORC stated: "we did not expect any additional chemicals to be
present and did not analyze for any additional compounds outside our permit." Review of the City's
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pretreatment program found multiple metal finisher SIUs, which could use 1,4-Dioxane as a solvent
stabilizer and thus be a source of the pollutant in the effluent if detected. The facility discharges into a Class
C water at Outfall 001 with the nearest downstream water supply (WS-IV) watershed boundary located
—7.8 miles from the outfall. The calculated allowable effluent concentration to meet the WS derived
numeric criterion of 0.35 µg/L at the WS-IV boundary is 2.77 µg/L using RPA. Since no 1,4-Dioxane data
are available for evaluation, monthly monitoring for 1,4-Dioxane has been added to the permit with an
option to reduce monitoring frequency to quarterly after evaluation of 24 months of submitted data should
the Permittee request it. In addition, a reopener special condition for 1,4-Dioxane has been added to the
permit.
Based on the pervasive nature of PFAS chemicals in the environment plus the facility receiving wastewater
from seven (7) SIUs that are in categories recognized by the EPA as sources of PFAS chemicals, and the
discharge is upstream of a water supply watershed, monitoring for PFAS has been added to the permit. See
Section 10 below for details.
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2K 0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA.
7. Technology -Based Effluent Limitations (TBELs)
Municipals (if not applicable, delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg1L
BODS/TSSfor Monthly Average, and 45 mg/L for BODS/TSSfor Weekly Average). YES.
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BOD51TSS included in the permit? YES. Reviewed data found no
instances of removal rates below 85% for either BOD or TSS.
If NO, provide a justification (e.g., waste stabilization pond). NA.
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA.
Page 11 of 16

NCO037834
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): No, but quarterly monitoring
requirements for Cadmium, Dichlorobromomethane, and Chlorodibromomethane have been removed
based on RPA results from updated effluent and upstream hardness data finding no reasonable potential to
exceed the stream water quality standards.
If YES, confirm that antibackdiding provisions are not violated: NA.
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2) NPDES
Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced
Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional
Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered
effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding
prohibitions would not be triggered by reductions in monitoring frequencies.
The current permit has BOD, TSS, Ammonia and Fecal Coliform sampled at reduced monitoring
frequencies of 2/week. The Permittee requested that reduced monitoring for the above target parameters be
maintained via e-mail on 8/8/2023. Effluent data were evaluated for reduced monitoring frequencies and
found criteria met for all above parameters. Reduced monitoring for BOD, TSS, Ammonia and Fecal
Coliform at 2/week has been maintained in the permit.
As noted in Section 6.8 above, 1,4-Dioxane and PFAS monitoring have been added to the permit. Regarding
PFAS, grab samples shall be taken and analyzed using EPA Method 1633, which was finalized January
2024. Quarterly effluent monitoring will be implemented six (6) months after the permit effective date to
provide the City time to select a laboratory, develop a contract, and begin collecting samples. As the method
has not yet been published as a 40 CFR 136 method in the Federal Register, data will be reported using a
Division -approved form; once the method is approved, data will be submitted via eDMR.
In addition to monitoring at the WWTP, the City shall identify and monitor SIUs suspected of discharging
PFAS compounds [see A.(9.)(c.)(i.)] within six (6) months of the permit effective date. The City shall
update their Industrial Waste Survey (IWS) to identify indirect dischargers of PFAS contributing to
concentrations experienced at the Archie Elledge WWTP. A summary of information learned during this
process will be provided as part of the 2024 Pretreatment Annual Report (PAR). Within six (6) months of
completion of the IWS, the City shall begin sampling of indirect dischargers identified as potential PFAS
sources. Sampling conducted at SIUs and indirect dischargers shall also be conducted quarterly. For a
detailed outline of the specific PFAS requirements, see Special Condition A. (9.) PFAS Monitoring
Requirements.
Page 12 of 16

NC0037834
For instream monitoring, refer to Section 4.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit
additional NPDES reports electronically. This permit contains the requirements for electronic reporting,
consistent with Federal requirements.
12. Summary of Proposed Permitting Actions:
Current permit conditions and proposed changes are presented in Table 6.
Table 6. Current Permit Conditions and Proposed Changes.
Parameter
Current Permit'
Proposed Change 1
Basis for Condition/Change
Flow
MA = 30.0 MGD
Monitor continuously
No change
15A NCAC 2B .0505
Summer
MA = 21.0 mg/L
WA = 31.5 mg/L
No change in effluent
Winter
MA = 30.0 mg/L
limits or monitoring.
WQBEL. Based on protection of state
BODS
WA = 45.0 mg/L
DO standard. Criteria for reduced
Monthly 2/week
No change in instream
monitoring frequencies are met.
monitoring.
Monitor instream
weekly
MA = 30 mg/L
No change in limits or
TBEL. Secondary treatment standards,
TSS
WA = 45 mg/L
40 CFR 133. Criteria for reduced
Monitor 2/week
monitoring.
monitoring frequencies are met.
Summer
MA = 1.2 mg/L
WA = 3.6 mg/L
WQBEL. Summer limits to protect
Winter interim
No change in summer
stream DO water quality standard.
MA = 9.0 mg/L
limits.
WA = 27.0 mg/L
Winter limits to protect against
Winter final
Remove winter
ammonia toxicity via WLA analysis.
NH3-N
MA = 2.4 mg/L
interim limits and
WA = 7.2 mg/L
compliance schedule.
Compliance schedule expired on
Winter limit
5/31/2018.
compliance schedule
No change in
Monitor 2/week
monitoring.
Criteria for reduced monitoring
frequencies are met.
Monitor instream
weekly
Page 13 of 46

NC0037834
Parameter
Current Permit'
Proposed Change 1
Basis for Condition/Change
DA > 6.5 mg/L
WQBEL. Limits to protect stream DO
Monitor effluent daily
water quality standard in combination
DO
No change
with above BOD and NH3-N limits.
Monitor instream
Monitoring frequency based on 15A
3/week (Jun -Sep)
NCAC 02B .0500.
weekly (Nov -May)
MA = 200 / 100 mL
WA = 400 /100 mL
No change in limits or
Monitor 2/week
monitoring.
WQBEL. 15A NCAC 2B .0200, .0500.
Fecal Coliform
Criteria for reduced monitoring
Monitor instream
No change in instream
frequencies are met.
3/week (Jun -Sep)
monitoring.
weekly (Nov -May)
TRC
DM = 22.5 µg/L
No change
WQBEL. 15A NCAC 2B .0200, .0500;
Monitor daily
WLA results.
No change to effluent
15A NCAC 2B .0500
Total Nitrogen
Monitor monthly
Add monthly instream
Downstream increases detected by
monitoring
monitoring coalition data.
Add monthly effluent
To better understand effluent nutrient
Total Kjeldahl Nitrogen
No requirement
and instream
patterns for future evaluation.
(TKN)
monitoring
Downstream increases detected by
monitoring coalition data.
Add monthly effluent
To better understand effluent nutrient
Nitrate -Nitrite Nitrogen
No requirement
and instream
patterns for future evaluation.
(NO3+NO2)
monitoring
Downstream increases detected by
monitoring coalition data.
No change to effluent
To better understand effluent nutrient
Total Phosphorus
Monitor monthly
Add monthly instream
patterns for future evaluation.
Downstream increases detected by
monitoring
monitoring coalition data.
pH
Between 6 and 9 SU
Monitor daily
No change
WQBEL. 15A NCAC 2B .0200, .0500
Monitor daily
Temperature
Monitor instream
No change
15A NCAC 2B .0500
3/week (Jun -Sep)
weekly (Nov -May)
Conductivity
Monitor effluent and
instream monthly
No change
15A NCAC 2B .0500
Total Hardness
Monitor effluent and
instream (upstream)
No change
Revised WQS and EPA's guidelines on
quarterly
hardness -dependent metals.
Monitor quarterly with
Revise PQL to < 10
WQBEL. 15A NCAC 2B .0200. RP
Total Cyanide (CN)
PQL of < 20 µg/L.
µg/L as a footnote.
found. Agreed -upon PQL with Division
& EPA, 2002
Page 14 of 16

NCO037834
Parameter
Current Permit'
Proposed Change 1
Basis for Condition/Change
No reasonable potential to exceed
Total Cadmium
Monitor quarterly
Remove from permit
stream standard (RP) found, using
updated Hardness data.
Total Copper
No requirement
Add quarterly
Receiving stream is impaired for
monitoring
copper.
Total Zinc
Monitor quarterly
No change
Receiving stream is impaired for zinc.
Dichlorobromomethane
Monitor quarterly
Remove from permit
No RP found.
Chlorodibromomethane
Monitor quarterly
Remove from permit
No RP found.
Add quarterly
monitoring with
To gather data for evaluation as
PFAS
No requirement
pretreatment
multiple SIUs are potential sources;
requirements as
effluent discharge above water supply
Special Condition
Waters.
Add monthly
monitoring with
To gather data for evaluation as
1,4-Dioxane
No requirement
option to reduce to
multiple SIUs are potential sources;
quarterly. Add
effluent discharge above water supply
reopener condition
waters.
Chronic Toxicity Test
Chronic limit, 76%
effluent
No change
No in toxic amounts.
Monitor quarterly
15A NC B .0tox2
15A NCAC 2B .0200, .0500
Effluent Pollutant Scan
Three times per permit
Update sample years:
40 CFR 122
cycle
2025, 2026, 2027.
Lagoon closure /
rehabilitation with
No requirement
Add special condition
Lagoon embankment leakage caused
groundwater monitoring
instream fecal coliform levels to rise
Electronic Reporting
Special condition
Update special
In accordance with EPA Electronic
condition
Reporting Rule 2015.
Footnote.
1. MGD = million gallons per day, MA = monthly average, WA = weekly average, DM = daily maximum.
13. Public Notice Schedule:
Permit to Public Notice: 01/25/2024
Per 15A NCAC 21-1.0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the Director
within the 30 days comment period indicating the interest of the party filing such request and the reasons
why a hearing is warranted.
14. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit, please contact
Gary Perlmutter at [phone] or via email at [e-mail].
Page 45 of 16

NC0037834
15. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Copies of the draft
permit were sent to the EPA, Permittee, and various internal DWR contacts. The DWR Operator
Certification Program contact responded, noting that the current certification status of the facility grade is
in agreement with the designated in the draft permit. Similarly, the DWR Winston-Salem Regional Office
Public Water Supply contact responded, concurring with the draft permit as is. No other parties commented.
If Yes, list changes and their basis below:
• To allow for a full five-year permit cycle, the expiration date was revised to March 31, 2029. In
accordance with this change, the effluent pollution scan sampling years were adjusted to 2026,
2027, and 2028.
• Special Condition A.(9.) PFAS Monitoring and Pretreatment requirements was revised to reflect
the finalization of EPA Method 1633 in January 2024.
16. Fact Sheet Attachments (if applicable):
• Facility response e-mail to Chemical Addendum request
• NPDES Pretreatment POC review form
• Archie Elledge Water Quality Assessment Update (S&ME report, 9/2023) with updated Table 3
• 2022 303(d) list of impaired waters, page 176
• 2022 Integrated Report, page 1239
• Benthos Site Details page for Station QB 167 (downstream)
• Fish Community sample page for Station QF65 (upstream)
• Monitoring Report Violations report
• WET Testing Summary, page 113
• Inspection reports, 4/6/2022 (pretreatment), 6/29/2023 (compliance)
• 1991 Waste load Allocation
• Waste load allocations for TRC and NH3-N
• RPA Spreadsheet Summaries and dissolved to total metal calculator
• Dissolved Metals Implementation/Freshwater
• Mercury WQBEL/TBEL evaluation
• Chemical Addendum request response from ORC
• Request to maintain reduced monitoring from ORC
• Monitoring reduction evaluation
• Comments from DWR Certification Branch
• Comments from DWR regional PWS
Page 46 of 46

RE: [EXTERNAL] Additional information request
Bonnie McKee <[e-mail]>
Fri 7/28/2023 4:49 AM
To:Perlmutter, Gary <[e-mail]>
Cc:Keith Jones <[e-mail]>;Matthew Lavigne <[e-mail]>;Joel Freeman <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Good Morning Everyone,
We did not expect any additional chemicals to be present and did not analyze for any
additional compounds outside of our permit. The state website states "If there are no
additional pollutants to report, this form is not required to be included with your application."
How should we proceed?
Bonnie McKee
Archie Elledge WWTP
Utilities Plant Supervisor -Manson Meads Laboratory
2799 Griffith Rd.
Winston Salem, NC 27103
336.397.7618
[e-mail]
From: Matthew Lavigne <[e-mail]>
Sent: Tuesday, July 25, 2023 2:44 PM
To: Joel Freeman <[e-mail]>; Bonnie McKee <[e-mail]>
Cc: Keith Jones <[e-mail]>
Subject: FW: [EXTERNAL] Additional information request
Is this something you guys can help me with? I believe it is similar to the addition info requested for Muddy Creek
a few weeks back.
Matt Lavigne
Senior Utilities Plant Supervisor
Winston-Salem/Forsyth County Utilities
Archie Elledge WWTP
2801 Griffith Rd
Winston-Salem, NC 27103
0: 336-397-7600 M: 336-240-5738
[e-mail]
From: Perlmutter, Gary <garyperlmutter(@deq.nc.gov>
Sent: Tuesday, July 25, 2023 2:37 PM
To: Matthew Lavigne <mathewIPcityofws.org>
Subject: [EXTERNAL] Additional information request

CAUTION: `EXTERNAL SENDER *** STOP. EVALUATE. VERIFY. Were you expecting this
email? Does the content make sense? Can you verify the sender? If the email is suspicious: Do
not click links or open attachments. Click the Report Message button in Outlook to notify
Information Systems.
Dear Mr. Lavigne,
I am the assigned permit writer to your facility's NPDES renewal for Archie Elledge WWTP (NC0037834). From
reviewing the submitted application, I found that the required Chemical Addendum was not included. Please
compete the attached forms to document any additional chemicals, such as the emerging contaminants 1,4-
Dioxand and PFAS chemicals that you may expect to be in the effluent. The Chemical Addendum sheet is for
those parameters that have approved testing methods (e.g., 1,4-Dioxane) and the supplemental datasheet is for
those that currently lack approved methods (e.g., PFAS). More information can be found on the Division's
website: https://www.deq.nc.gov/about/divisions/water-resources/permittin gLnpdes-wastewater/npdes-
permitting=process npdes-individual-permit-applications
Feel free to contact me if you have any questions.
NPDES Individual Permit Applications I NC DE
NPDES Individual Permit Applications Renewing your existing permit? Federal [40 CFR 122] and
State [15A NCAC 02H .0105(3)] regulations require that permit
www.deq.nc.gov
Thank you,
Gary Perlmutter
Gary Perlmutter, MSc, Environmental Specialist II
NCDEQ / Division of Water Resources
NPDES Municipal Permitting Unit
919-707-3611 Office
919-306-1017 Cell
gary perlmutter@ eq.nc.gov
Physical Address: 512 N Salisbury St., Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
DEQ is updating its email addreses to @deq.nc.gov in phases from May 1st to June 9th. Employee email
addresses may look different, but email performance will not be impacted.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties.

Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an
authorized state official.

A B C I D I E I F I G I H I I I J K L I M N O P
NPDES/PT POC Review Form Version: 2022.06.22
2
1. Facility's General Information
3
Date of (draft) Review
7/12/2023
c. POC review due to:
e. Contact Information
4
Date of (final) Review
Municipal NPDES renewal
❑
Regional Office (RO) Forsyth
5
NPDES Permit Writer (pw)
Gary Perlmutter
HWA-AT/LTMP Review
ElRO
PT Staff Jenny Graznak RO NPDEB Staff Lon Snyder
6
Permittee-Facility Name
City of Winston-Salem Archie Elledge
WWTP
Nev Industries
❑
Facility PT Staff, email Joel Freeman <ioelfaciNOtws.om>
7
NPDES Permit Number
NCO037834
WWTP expansion
❑
f. Receiving Stream
8
NPDES Permit Effective Date
7/1/2017
Stream reclass./adjustment
❑
Outfall
9
Chemical Addendum Submittal Date
Outfall relocation/adjustment
❑
Receiving Stream:
Salem Cr (Middle
Fk Muddy Cr)
QA, cfs:
Tidal
10
NPDES Permit Public Notice Date
7010 update
❑
Stream Class
C
7Q10 (S), cfs:
320.7
11
eDMR data evaluated from:
to
Other POC review trigger, explain:
Oufall Lat.
38.01.04 N
OUtfall Lang.
80.15.54 W
12
3
a. WWTP Capacity Summary
Outfall 11
Current Permitted Flow, mgd
30.0 Designed Fes' 30.0
Receiving Stream:
OA, cfs:
14
Permitted SIU Flo+v, mgd
3.76
d. IU Summary
Stream Class
7Q10, cfs:
AN
15
b. PT Docs. Summary
# lus
Oufall Lat.
Outfall Long.
16
IW S approval date
9/2/2016
# SIUs
19
Is there a PW S dovnstream of the Facility's Outfall,? ❑' YES ❑ NO
17
USTMP approval date:
3/5/2019
# Clue
7
Comments:
18
19
d
3 HWA approval dale
'E
2/28/2018
# NSCIUs
# IUs /Local
Permits or Other
Tvpes
20
li
2. Industrial Users' Information.
21
lymj #
Industrial User (IU) Name
IU Activity
IU Non Conventional Pollutans 8 Toxic Pollutant IUP Effective Date
22
Z 1
See Tab 1.1. for complete list
23
a
24
a
25
4
26
5
27
6
28
29
a
30
31
9
Comment Facility has 22 SIUs, 9 of which are shared .. .iddy Cr WWTP (NC0050342). SIU Environmental Relief Technologies (ERT) closed and ceased operations I May 2022,
32
33
3. Status of Pretreatment Program (check all that apply)
Status of Pretreatment Program check all that apply)
34
77❑
❑
1) facility has no SIU's, does have Division approved Pretreatment Program that is
INACTIVE
2) facility has no SIU's, does not have Division approved Pretreatment Program
36
❑
3) facility has Sli and DWQ approved Pretreatment Program
37
0
3a) Full Program with LTMP
38
❑
31b) Modified Program with STMP
39
❑
4) additional conditions regarding Pretreatment
attached
or listed
below
40
❑
5) facility's sludge is being land applied or composted
41
❑
6) facility's sludge is incinerated (add Beryllium and Mercury sampling according
to 503.43
42
0
7) facility's sludge is taken to a landfill, if yes which landfill: unspecified
43
❑
8 other
44
45
46
Sludge Disposal Plan:
From plan submitted with NPDES permit renewal application: sludge is anaerobically digested and with the digested sludge pumped from Muddy Creek WWTP is sent to two blending tanks at Archie Elledge WWTP, At Archie
Elledge W WTP the sludge is blended with the latter W WTP's sludge, then centrifuged to create pellets which are then land applied as Class A biosolids under permit number W00029804 or disposed of by other approved
hods.
47
1 Sludge Permit No:
W00029804
Page 1 37834 POC Review Form

A 6 I C D I E I F I G I H J K L M IN P
48
4. LTMPISTMP and HWA Review
qg
PW: Find L/STMP document, HWA spreadsheet, DMR, previous and new NPDES permit for next section.
50
51
a
�Comment
�
U
O
n
Parameter of Concern
POC Check List
New
NPDES
POC
Previous
NPDES
POC
Required by
EPA PT 1
POC due to
Sludge 2
POC due to
SIU 3
POTW
POC 4
L/STMP
EffluentlFreg
NPDES
Effluent Freq
PQLs review
%
Removal
Rate
PQL from
L/STMP, ug/I
Required PQL
per NPDES
permit
Recomm.
PQL, ug/I
52
❑'
Flow
❑
❑'
❑'
❑
I Quarterly
Continuous
53
❑'
BOD
Li
❑'
X
❑+
❑
98
Quarterly
2/week
2 mg/L
54
❑'
TSS
❑
0
X
❑'
❑
98
quarterly
2/week
2 mg/L
55
El
NH3
❑
0
X
❑'
❑
98.5
Quarterly
2/week
56
❑'
Arsenic
❑
❑
X
0
❑'
❑
45
Quarterly
5.0
2.0
Lower PQL to recommended level
57
❑
Barium
❑
❑
❑
❑
❑
58
❑
Beryllium(5)
❑
❑
❑
❑
❑
59
0
Cadmium(1)
❑
❑+
❑'
❑'
❑i
❑
73.5
Quarterly
Quarterly
5.0
0.5
Lower PQL to recommended level
60
0
Chromium(1)
❑
1 ❑
❑i
❑
❑✓
❑
67.2
Quarterly
5.0
10.0
61
❑'
Copper(l)
❑
❑
El
❑+
❑i
❑
90
Quarterly
2.0
2.0
62
❑
Cyanide
❑
❑'
X
❑
Q
❑
-55.4
Quarterly
Quarterly
5.0
63
0
Lead(1)
❑
❑
❑
o
❑i
❑
92.6
Quarterly
10.0
2.0
Lower PQL to recommended level
64
❑'
Mercury(5)
❑
❑
X
0
ID
❑
98.4
Quarterly
0.001
0.001
65
❑'
Molybdenum
❑
❑
X
❑'
❑i
❑
50
Quarterly
5.0
10.0
66
❑'
Nickel(1)
❑
❑
o
o
El
❑
53.2
Quarterly
10.0
5.0
Lower PQL to recommended level
67
0
Selenium
❑
❑
X
❑'
❑+
❑
44.6
Quarterly
10.0
68
1 Silver
❑1
❑
X
❑
I❑'
❑
66.8
Quarterly
1.0
1.0
69
0
Ziri
❑
0
El
0
❑+
❑
68.8
Quarterly
Quarterly
10.0
10.0
70
0
Sludge Flow to Disposal
1E
❑
❑
Quarterly
71
P1
% Solids to Disposal
0
❑
❑
Quarterly
72
❑
Oil & Grease
❑
❑
73
❑'
TN
❑
❑+
❑+
❑
Quarterly
Monthly
100.0
74
❑'
TP
❑
0
❑+
❑
Quarterly
Monthly
10.0
75
❑'
Fluoride
❑
❑
❑'
❑
4.7
Quarterly
1or
76
❑'
Manganese
❑
1 ❑
❑i
❑
74.2
Quarterly
5.0
❑'
1,4-Dloxane
❑'
El
El
❑
Quarterly
1.0
Recommend addition; metal finishers area potential
.L7
78
79
❑
PFAS
❑
❑
❑
quarterly
Recommend addition as multiple SIUs are potential
8077-
❑
El
El
Li
81
❑
❑
❑
❑
❑
82
Footnotes:
83
(1) Always in the LTMP/STMP due to
EPA -PT requirement
84
(2) Only in LTMPISTMP if listed in sludge permit
85
(3) Only in LTMPISTMP while SIU still discharges to POTW
86
(4) Only in LTMP/STMP when pollutant is still of concern to POTW
87
(5) In LTMP/STMP, 0 sewage sludge is incinerated
88
Please use blue fora for the info updated by P.
89
Please use red font for POC that need to be added/modeled in DSTMP
sampling
plan
90
91
Blue shaded cell (D60:1182): Parameters usually included under that POC list
92
5. Comments
93
Facility Summary/background information/NPDES-PT regulatory action:
POC to be added/modified In USTMP:
94
95
gg
97
ORC's comments on IUIPOC:
POC submitted through Chemical
Addendum or Supplemental Chemical
Datasheet:
Additional pollutants added to USTMP due
to POTWs concems:
NPDES pw's comments an IUIPOC:
g8
6. Pretreatment updates in response
to NPDES permit renewal
gg
NPDES Permit Effective Date 180 days after effective (date): 1 Permit writer, please add list of required/recommended PT updates in NPDES permit cover letter.
Page 2 37834 POC Review Form

NORTH CAROLINA 2022 303(D) LIST
Upper Yadkin Yadkin -Pee Dee River Basin
AU Name AU Number Classification AU_LengthArea AU —Units
AU ID Description
Salem Creek (Middle Fork Muddy Creek) 12-94-12-(4) C 1.9 FW Miles
13698 From Burke Creek to SR1120
PARAMETER IR CATEGORY CRITERIA STATUS' REASON FOR RATING 303D YEAR
IBenthos (Nar, AL, FW) 5 l IExceeding Criteria Fair, Poor or Severe Bioclassification 2008
Copper (7 µg/I, AL, FW) 5 Exceeding Criteria Legacy Category 5 Total Metals 2008
Assessment
Zinc (50 µg/I, AL, FW) 5 Exceeding Criteria Legacy Category 5 Total Metals 2008
Assessment
Salem Creek (Middle Fork Muddy Creek) 12-94-12-(4)c C
13699 From SR1120 to Muddy Creek
PARAMETER IR CATEGORY CRITERIA STATUS
Turbidity (50 NTU, AL, FW miles) 5 Exceeding Criteria
Benthos (Nar, AL, FW) 5 Exceeding Criteria
Copper (7 µg/I, AL, FW) 5 Exceeding Criteria
Zinc (50 µg/I, AL, FW)
5 Exceeding Criteria
REASON FOR RATING
2.6 FW Miles
303D YEAR
2022
Fair, Poor or Severe Bioclassification 2008
Legacy Category 5 Total Metals 2008
Assessment
Legacy Category 5 Total Metals 2008
Assessment
Yadkin -Pee Dee River Basin
03040102
South&dkin
(Bear Creek
12-108-18-(3
WS-IV
8.6I IFW Miles
F_ 1452 From a point 0.2 mile downstream
of U.S. Hwy. 64 to South
Yadkin River
PARAMETER IR CATEGORY
CRITERIA STATUS
REASON FOR RATING
303D YEAR
Copper (7 µg/I, AL, FW) 5
Exceeding Criteria
Legacy Category 5 Total Metals
2010
Assessment
Fourth Creek
12-108-20a1
C
10.2 FW Miles
1459 From source to Morrison
PARAMETER IR CATEGORY
CRITERIA STATUS
REASON FOR RATING
303D YEAR
Fish Community (Nar, AL, FW) 5
Exceeding Criteria
Fair, Poor or Severe Bioclassification 20 88
Fourth reef k
12-10 028 a3
C
3.8 FW Miles
13578 From SR2316 to SR2308
PARAMETER IR CATEGORY
CRITERIA STATUS
REASON FOR RATING
303D YEAR
Benthos (Nar, AL, FW) 5
Exceeding Criteria
Fair, Poor or Severe Bioclassification 1998
Fish Community (Nar, AL, FW) 5
Exceeding Criteria
Fair, Poor or Severe Bioclassification 1998
6/7/2022 NC 2022 303d List- Approved by EPA 4/30/2022 Page 176 of 192

NORTH CAROLINA 2022 INTEGRATED REPORT
Upper Yadkin
Yadkin -Pee Dee River Basin
AU Name
AU Number Classification
AU LengthArea AU Units
AU ID Description
12-94-12-(4)c C
2.6 FW Miles
Salem Creek (Middle Fork Muddy Creek)
13699 From SR1120 to Muddy Creek
2022 Water Quality Assessments
WE
PARAMETER
IR CATEGORY
CRITERIA STATUS
Turbidity (50 NTU, AL, FW miles)
5
Exceeding Criteria
Water Temperature (322C, AL, LP&CP)
1
Meeting Criteria
Dissolved Oxygen (4 mg/I, AL, FW)
1
Meeting Criteria
pH (6 su, AL, FW)
1
Meeting Criteria
pH (9.0, AL, FW)
1
Meeting Criteria
Benthos (Nar, AL, FW)
5
Exceeding Criteria
Copper (7 µg/l, AL, FW)
5
Exceeding Criteria
Zinc (50 µg/I, AL, FW)
5
Exceeding Criteria
Fecal Coliform (GM 200/400, REC, FW)
3a
Data Inconclusive
Fecal Coliform (GM 200/400, REC, FW)
4t
Exceeding Criteria
Kerners Mill Creek
12-94-12-2-( WS-III
4.6 FW Miles
2129 From source to a point 0.1 mile downstream of 1-40
2022 Water Quality Assessments
PARAMETER
IR CATEGORY
CRITERIA STATUS
Benthos (Nar, AL, FW)
1
Meeting Criteria
6/7/2022 NC 2022 INTEGRATED REPORT -Category 5 Approved by EPA 4/30/2022 Page 1239 of 1346

7/26/23, 10:27 AM
NCDEQ-DWR :: Benthos Site Details
NC Division of Water Resources
Benthos Site Details
Waterbody
Location
Station ID
Date
Bloclasslflcatlon
SALEM CR
SR 2991
QB167
13 Jul 2016
Fair
County
8 digit HUG
Latitude
Longitude
Elevation (ft)
Forsyth
03040101
36.008333
-80.335833
677
Level IV Ecoregion
Drainage
Area (m12)
Stream Width (m)
Stream Depth (m)
Southern Outer Piedmont 69.3
20.0
0.8
Landuse Percentages
Year
Forest Developed
Impervious
Cultivation
Grass/Shrub
Wetland
Water Barren
2011
19.9
68.3
19.4
7.0
2.6/0.6
0.7
0.9 0.0
2006
20.7
67.1
18.6
7.6
2.6 / 0.5
0.7
0.9 0.0
2001
21.7
65.2
17.6
8.5
2.5 / 0.5
0.7
0.9 0.0
1992
1 33.2
51.4
13.3
/
0.6
1.1 0.4
Water Quality Parameters
2016
2011
2006 12001
1996 1982
Temperature (°G)
26.2
26.6
29.1 28.0
27.0 0.0
Dissolved Oxygen(mg/L)
6.6
5.9
6.0
8.0
6.5 0.0
Specific Conductance (pS/cm) 389.0
540.0
500.0
835.0
600.0 0.0
pH (s.u.)
7.2
6.8
7.1
7.9
7.1 0.0
ubstrate Percentages 2016
2011
2006
2001
1996 1982
oulder
5
10
30
0 0
obble
5
5
0
0 0
ravel
and
55
10
80
0
75
10
20
10 10
62 80
lit
10
5
0
411
25 10
ether 30
Habitat Assessment Scores (max score) 3
Water Clarity Clear
Sample Date
Sample ID
Method
ST
EPT
BI
6.53
EPT BI
5.90
6.04
6.07
6.21
6.00
Bioclossificotion
Fair
Fair
Fair
Fair
Fair
Poor
13 Jul 2016
12093
Full Scale 1 59 14
Full Scale 60 15
Full Scale 51 11
Full Scale 42 10
Full Scale 43 8
Full Scale 22 0
23 Aug 2011
11195
6.92
09 Aug 2006
06 Aug 2001
05 Aug 1996
10044
8544
7105
6.65
7.11
7.21
27 Sep 1982
2871
8.45
Print Page
https://www.ncwater.org/?page=672&SitelD=QB167 1/1

FISH COMMUNITY SAMPLE
Waterbody
Location
Station ID
Date
Bioclassification
SALEM CR
off SR 1120
QF65
05/10/16
Fair
County
8 digit HUC
Latitude
Longitude
Elevation (ft)
Reference Site
FORSYTH
03040101
36.039099
-80.304027
701
No
Level IV Ecoregion
Drainage Area (mi2)
Stream Width (m)
Stream Depth (m)
Southern Outer Piedmont
63.1
8
0.4
Upstream NPDES Dischargers (>_ 1 MGD or < 1 MGD and within 1 mile) NPDES Number Volume (MGD)
None
Landuse (%)
Forest
Developed
Impervious
Cultivation
Grass/Herb/Shrub
Wetland
Water
Barren
1992
31.1
55.1
no data
11.6
no data
0.6
1.1
0.4
2001
20.3
68.2
18.3
7.3
2.5
0.7
0.9
0.0
2006
19.2
70.0
19.3
6.4
2.7
0.7
0.9
0.0
2011
1 18.7
1 71.0
1 20.0
1 6.0
1 2.6
1 0.7
1 0.9
1 0.0
Water Quality Parameters
1900
2001
2016
Temperature (°C)
---
18.2
20.5
Dissolved Oxygen (mg/L)
---
8.7
7.3
Specific Conductance (pS/cm)
---
178
151
pH (s.u.)
I --
7.2
1 6.4
Habitat Assessment Scores (max score)
2016
Channel Modification (5)
4
Instream Habitat (20)
12
Bottom Substrate (15)
3
Pool Variety (10)
8
Riffle Habitat (16)
0
Bank Erosion (7)
5
Bank Vegetation (7)
6
Light Penetration (10)
6
Left Riparian Score (5)
3
Right Riparian Score (5)
3
Total Habitat Score (100)
50
Water Clarity JVery slightly turbid
SSubstrate = sand.
Sample Date
Sample ID
Species Total NCIBI Score
NCIBI Rating
05/10/16
2016-35
10 38
Fair
04/30/01
2001-30
8 30
Poor
Data
Watershed -- drains south-central Forsyth County, including the City of Winston-Salem metropolitan area; six NPDES dischargers upstream (Total Q. = 0.623
MGD); has the greatest percentage of impervious land (20%) in its watershed than any other fish community site sampled in 2016; tributary to Muddy Creek and
ultimately the Yadkin River. Habitat -- evidence of old channelization; narrow riparian zones; rip -rap along the right bank to protect the sewage lagoons beyond
the riparian zone; riffles absent; cans, bottles, and tires in the creek; evidence of high water from previous week's rains; Total Habitat Score in 2001 was 30.
Water Quality -- specific conductance elevated from urban point source discharges and nonpoint source stormwater runoff, was 178 pS/cm in 2001. 2016 -- 1
of only 4 sites where just 10 species of fish were collected; 1 of only 2 sites were no species of darters were collected; metrics scoring a "1" include Number of
Species of Darter (0), Number of Intolerant Species (0), and Percentage of Tolerant Fish (43%); Metrics scoring a "3" included Number of Species, Number of
Fish (n=143), Number of Species of Sucker (1), Percentage of Piscivores (0.7%), and Percentage of Species with Multiple Age Classes (50%); collectively these
metrics all scoring less than expected are evidence of a degraded fish community which is not unexpected considering the stream's watershed is more than 70%
developed; Rosefin Shiner, White Sucker, Warmouth, Redear Sunfish, Spotted Sucker, and Satinfin Shiner new to the site. 2001 & 2016 -- a species -poor
community given the size of the stream with only 14 species are known from the site, the fewest species of any site in 2016 and includes 5 exotic species, 0
intolerant, 0 darter, and 1 sucker species; no darters or Intolerant Species have ever been collected at this site; dominant species is the omnivorous Bluehead
Chub. Recommendation -- the likelihood that watershed and water quality enhancement projects would be implemented throughout the watershed are slim,
thus continued basinwide monitoring of this site in 2021 is unnecessary because no improvements are to be expected in the fish community.
Most Abundant Bluehead Chub (n=48, Non -indigenous Redear Sunfish, Rosefin Imperiled
o Shiner, and Spotted Bass None
Species 33/0) Species (n=11, 3, and 1, respectively). Species

MONITORING REPORT(MR) VIOLATIONS for:
Permit: NCO037834 MRS Betweel 7 - 2018 and 8 - 2023 Region: %
Facility Name: % Param Nam(% County: %
Major Minor: %
Report Date: 08/03/22 Page 1 of 1
Violation Category:Limit Violation Program Category: NPDES WW
Subbasin: % Violation Action:
PERMIT: NCO037834
FACILITY: City of Winston-Salem - Archie Elledge WWTP
COUNTY: Forsyth
REGION: Winston-Salem
Limit Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT
OUTFALL
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
07 - 2022
001
Effluent
BOD, 5-Day (20 Deg. C) -
07/09/22
2 X week
mg/I
31.5
33.75
7.1
Weekly Average
No Action, BPJ
Concentration
Exceeded
07 - 2018
001
Effluent
Chlorine, Total Residual
07/25/18
5 X week
ug/I
22.5
29
28.9
Daily Maximum
No Action, BPJ
Exceeded
11 -2018
001
Effluent
Chlorine, Total Residual
11/14/18
5 X week
ug/I
22.5
30
33.3
Daily Maximum
No Action, BPJ
Exceeded
04 - 2020
001
Effluent
Chlorine, Total Residual
04/02/20
5 X week
ug/I
22.5
30
33.3
Daily Maximum
No Action, BPJ
Exceeded
11 -2020
001
Effluent
Chlorine, Total Residual
11/19/20
5 X week
ug/I
22.5
26
15.6
Daily Maximum
No Action, BPJ
Exceeded

Whole Effluent Toxicity Testing and Self Monitoring Summary
Wilkesboro Cub Creek WWTP
NCO021717/001 County:
Wilkes
Ceri7dPF
Begin: 2/1/2016
chr lim: 3.7%; if PF 6.
NonComp:
Single
J
F M
A
M
2019
-
- >14.8(P) Pass
-
-
2020
-
- Pass
-
-
2021
Pass >14.8(P)
-
-
2022
-
- Pass
-
-
2023
-
- Pass
-
-
Williamston WWTP
NCO020044/001 County:
Martin
Ceri7dPF
Begin: 2/1/2019
chr lim: 2.0 MGD @ 0
NonComp:
Single
J
F M
A
M
2019
-
- Pass
-
-
2020
-
- Pass
-
-
2021
Pass >1.08(P)
-
-
2022
-
- Pass
-
-
2023
-
- Pass
-
-
Wilson -Hominy Crk WRF-Contentnea
NCO023906/001 County:
Wilson
Ceri7dPF
Begin: 3/1/2021
chr lim: 90%
NonComp:
Single
J
F M
A
M
2019
-
Pass -
-
>100(P) Pass
2020
-
Pass -
-
Pass
2021
ass -
-
Pass
2022
- >100 (P) Pass -
-
Pass
2023
-
Pass -
>100
INVALID Pass
Windsor WWTP
NCO026751/001
Ceri7dPF
Begin: 4/1/2019
Chr Lim: 90%
J
F M
2019
Pass
- -
2020
Pass
- -
2021
Pass
- -
2022
Pass
- -
2023
>100 Pass
- -
Winston-Salem Archie
Elledge WWTP
NCO037834/001
Ceri7dPF
Begin: 8/1/2017
chr lim: 76%
J
F M
2019
Pass
- -
2020
Pass
- -
2021
Pass
- -
2022
Pass
- -
2023
Pass
- -
Region:
WSRO
Basin:
YAD01
Mar Jun Sep Dec
7Q10: 196
PF: 4.9
IWC:
3.72 Freq: Q
J J
A
S O
Pass -
-
Pass -
Pass -
-
Pass -
Pass
>14.8(P) -
-
Pass >14.8(P) -
Pass -
-
Pass -
Region:
WARD
Basin:
ROA09
Mar Jun Sep Dec
7Q10: 1170
PF: 2.4
IWC:
0.26 Freq: Q
J J
A
S O
Pass -
-
Pass -
Pass -
-
>1.08(P) Pass -
>1.08 (P) Pass -
-
Pass -
Pass -
-
Pass -
Pass
Region:
RRO
Basin:
NEU07
Feb May Aug Nov
7Q10: 0.5
PF: 14.0
IWC:
97.37 Freq: Q
J J
A
S O
Pass
Pass
Pass
Pass
County: Bertie
Region: WARO
Basin: ROA10 Jan Apr Jul Oct
NonComp:
SINGLE
70.10: 0.0
PF: 1.15 IWC: 100 Freq: Q
A
M
J
J
A S
O
Fail
>100
>100
Pass
- -
Pass
Pass
-
-
Pass
- -
Pass
Pass
-
-
Pass
- -
Pass
Pass
-
>100 (P)
Pass
- -
>100 Pass
Pass
-
-
-
- -
-
County: Forsyth
Region: WSRO
Basin: YAD04 Jan Apr Jul Oct
NonComp:
ChV Avg
7Q10: 15.0
PF: 30 IWC: 75.6 Freq: Q
A
M
J
J
A S
O
Pass
-
-
Pass
- -
Pass
Pass
-
-
Pass
- -
Pass >96%(P)
Pass
-
-
Pass
- -
Pass
Pass
-
-
Pass
- -
Pass
Pass
-
-
-
- -
-
SOC JOC:
N
D
Pass
Pass
Pass >14.8 (P)
Pass
SOC JOC:
N D
Pass
0.76 (P) Pass
Pass
Pass
SOC JOC:
N D
Pass
Pass >100 (P)
Pass >100 (P)
Pass
SOC JOC:
N D
SOC JOC:
N
>96 (P)
C
Leeend: P= Fathead minnow (Pimohales Dromelas). H=No Flow (facilitv is active). s = Solit test between Certified Labs Page 113 of 115

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 2 u 3 I NC0037834 111 121 23/06/29 I17 18 LC] I 19 I s I 20L]
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I n, I 73 � I 74 79 I I I I I I I80
70 I I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 23/06/29
17/08/01
Archie Elledge WWTP
2801 Griffith Rd
Exit Time/Date
Permit Expiration Date
Winston Salem NC 271036417
12:30PM 23/06/29
22/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Matthew Richard Lavigne/ORC/336-397-7600/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jon M Southern,2801 Griffith Rd Winston Salem NC
271036417//336-397-7600/3366594320 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Operations & Maintenar 0 Records/Reports Sludge Handling Dispo:
Facility Site Review 0 Effluent/Receiving Wate
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Gary Hudson DWR/Division of Water Qua Iity/336-776-9694/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO037834 I11 12I 23/06/29 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
July 19, 2023 — Inspection Summary — NC0037834
On June 29, 2023, Division of Water Resources staff Gary Hudson conducted a routine compliance
inspection at the Archie Elledge WWTP. Bonnie McKee and Matthew Lavigne were present during the
inspection. A review of the October 2022, and April 2023 eDMR was compared to laboratory bench
sheets. No discrepancies were noted. During the inspection, no violations or items of concern were
noted. The following treatment components were inspected:
Permit
The permit became effective on August 1, 2017, and expired on June 30, 2022. A renewal application
was submitted on December 28, 2021.
Odor Control:
The Archie Elledge WWTP has six carbon air scrubbers for odor control. Four are located at the
influent/preliminary treatment, one is located at the primary clarifiers, and one is located at the sludge
thickener. Carbon is replaced yearly. All units were operating properly during the inspection.
Preliminary Treatment:
Preliminary treatment consists of two mechanical bar screens, two grit classifiers, and two cyclone grit
chambers. All six units are rated at a maximum capacity of 50 million gallons pr day (MGD). All units
were operating properly during the inspection.
Primary Treatment:
Primary treatment consists of four large primary clarifiers. All units were operating properly during the
inspection.
Secondary Treatment:
Secondary treatment consists of activated sludge basins, and six secondary clarifiers. All units were
operating properly during the inspection. Magnesium hydroxide is used for pH adjustment when
needed.
Final Effluent:
Sodium hypochlorite is used for disinfection and sodium bisulfate is used for de -chlorination. The
effluent composite sampler is set to collect 140 ml sample every 28 pulses. The refrigerator
temperature was 5 degrees centigrade.
Sludge Digestion:
Sludge digestion consists of six floating cover anaerobic digesters.
Sludge Handling and Disposal:
All sludge is run through a gravity belt thickener before it enters the anaerobic digesters. After
digestion, the sludge is run through a dryer and turned into pellets. All of the dried pellets are sold to
a private contractor to be used as fertilizer.
Page#

Permit: NCO037834 Owner -Facility: Archie Elledge WWTP
Inspection Date: 06/29/2023 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
0
❑
❑
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: The permit became effective on August 1, 2017, and expired on June 30, 2022.
A
renewal application was submitted on December 28, 2021.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Comment: Ms. McKee, Mr. Lavigne, and the rest of the staff do a very good lob with keeping
records.
A review of the October 2022, and April 2023 eDMR was compared to laboratory bench
sheets. No discrepancies were noted.
Page# 3

Permit: NCO037834
Inspection Date: 06/29/2023
Owner -Facility: Archie Elledge WWTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The WWTP appeared to be well operated and maintained. No discrepancies were
noted during the inspection.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Yes No NA NE
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: Preliminary treatment consists of two mechanical bar screens, two grit classifiers, and
two cyclone grit chambers. All six units are rated at a maximum capacity of 50 million
_gallons pr day (MGD). All units were operating properly during the inspection.
Grit Removal
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: The Archie Elledge WWTP has six carbon air scrubbers for odor control. Four are
located at the influent/preliminary treatment, one is located at the primary
clarifiers,
and one is located at the sludge thickener. Carbon is replaced yearly. All units were
operating properly during the inspection.
Primary Clarifier
Yes
No
NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Page# 4

Permit: NCO037834
Inspection Date: 06/29/2023
Owner -Facility: Archie Elledge WWTP
Inspection Type: Compliance Evaluation
Primary Clarifier
Yes
No
NA
NE
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/4
of the sidewall depth) ❑
❑
❑
Comment: Primary treatment consists of four large primary clarifiers. All units were operating
properly during the inspection.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0
❑
❑
❑
Are surface aerators and mixers operational?
❑
❑
0
❑
Are the diffusers operational?
0
❑
❑
❑
Is the foam the proper color for the treatment process?
■
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
❑
❑
Comment: Secondary treatment consists of activated sludge
basins, and six secondary clarifiers.
All units were operating properly during the inspection.
Magnesium hydroxide is used
for pH adjustment when needed.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
■
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
❑
❑
❑
Page# 5

Permit: NC0037834
Inspection Date: 06/29/2023
Secondary Clarifier
Owner -Facility: Archie Elledge WWTP
Inspection Type: Compliance Evaluation
Comment: All six secondary clarifiers appeared to be well maintained.
Anaerobic Digester
Type of operation:
Is the capacity adequate?
# Is gas stored on site?
Is the digester(s) free of tilting covers?
Is the gas burner operational?
Is the digester heated?
Is the temperature maintained constantly?
Is tankage available for properly waste sludge?
Comment: Sludge digestion consists of six floating cover anaerobic digesters.
Yes No NA NE
Yes
No
NA NE
Floating cover
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
❑
❑
❑
■
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
Page# 6

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 2 u 3 I NC0037834 111 121 22/04/06 I17 18 LC] I 19 I s I 20L]
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I n, I 73 � I 74 79 I I I I I I I80
70 I I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:OOAM 22/04/06
17/08/01
Archie Elledge WWTP
2801 Griffith Rd
Exit Time/Date
Permit Expiration Date
Winston Salem NC 271036417
12:30PM 22/04/06
22/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jon M Southern,2801 Griffith Rd Winston Salem NC
271036417//336-397-7600/3366594320 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Patricia Lowery DWR/WSRO WQ/336-776-9691/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO037834 I11 12I 22/04/06 117 18 1,1
lul
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On 4/6/2022, a Pretreatment Audit and PCI was performed by Tricia Lowery of the Winston-Salem
Regional Office. The purpose of the PCI and audit was to determine the effectiveness of the City of
Winston Salem's pretreatment program overall and their effectiveness in regard to SIU inspections,
which includes the initial interview, tour of SIU facility, sampling review, an exit interview.
Industrial Inspection Comments:
During the initial interview, a thorough review of records was conducted. Production rate, sampling,
updated contact information, monthly reports spill/slug plan, permits was reviewed. Discussion of new
reporting requirements to pretreatment programed was reviewed. Plant tour was systematic and
comprehensive, examining all paints, primers, multi -bond agents, and their containment, treatment
and/or disposal in production process. Additionally, pretreatment personnel checked for leaks,
condition of lines, machinery, and floor drains. Investigated industry's storage practices, spill
response kits, housekeeping practices etc. Inspection of pretreatment area revealed no issues or
concerns. Exit interview involved time for IU manager to ask questions or express any concerns and
for pretreatment personnel to assess and discuss plant inspection.
Background
The City of Winston Salem has 28 Significant Industrial Users (SIUs), of which 10 are categorical
users.
Pretreatment Program Interview
All files are in order. Since last PCI, the POTW has had no NPDES violations, and no problems
related to industrial discharges. No SNCs for reporting, however Bekaert, Suiza Dairy, ERT, Pepsi,
Clarios, Adele Knits, WestRock were in SNC for limits. All SNCs were appropriately published. ETR is
currently on compliance schedule/order.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on 10/2/2017. The HWA last approval date is
2/28/2018. The next HWA is due on 10/1/2022.
The last Industrial Waste Survey (IWS) was submitted on 6/30/2021. The IWS approval is pending.
The next IWS due date is pending.
The Sewer Use Ordinance (SUO) was approved on 2/9/2012.
The Enforcement Response Plan (ERP) was submitted on 1/13/2020 and approved on 2/5/2020.
The Long -Term Monitoring Plan (LTMP) was submitted on 12/20/2018 and approved on 3/5/2019.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the files for Hood Container (IUP #1042) revealed the monitoring data was well organized
and compliant.
A review of the files for Ardagh Packaging (IUP #3010) revealed the monitoring data was well
Page#

Permit: NCO037834
Inspection Date: 04/06/2022
organized and compliant.
Owner -Facility: Archie Elledge WWTP
Inspection Type: Pretreatment Audit
A review of the files for John -Deere Kernersville (IUP #2014) revealed the monitoring data was well
organized and compliant.
Action Items
No other action items were noted.
The pretreatment program is satisfactory
Page#

Permit: NC0037834
Inspection Date: 04/06/2022
Owner -Facility: Archie Elledge WWTP
Inspection Type: Pretreatment Audit
Yes No NA NE
Page#

WDES DOCUWENT SCANNING COVER SMEET
NPDES Permit:
NCO037834
Archie Elledge WWTP
Document Type:
Permit Issuance
/'Wasteload
Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 18, 1991
Thif docu eat 10 printed on reXXMe paper - i�;riore army
c4>1Mtet oIM the reireree Hide

a
DRAFT RF011FRTNPDES WASTE LOAD ALLOCATION
PERMIT NO.: NCO037834
PERMITTEE NAME: City of Winston-Salem/ Archie Elledge Wu�
Facility Status: Existing
Drainage Area (mil) (�� Avg. Streamflow (cfs): h
Permit Status: Renewal I I 7Q10 (cfs) I5 Winter 7Q10 (cfs)1_ 30Q2 (cfs)Iq
Major
Minor
Pipe No.: 001
Design Capacity: 30.0 MGD
Domestic (% of Flow): 77.6%
Industrial (% of Flow): 22.4 %
Comments: pretreatment information attached
RECEIVING STREAM: Salem Creek
Class: C
Sub -Basin: 03-07-04
Reference USGS Quad: C 17 SE (please attach)
County: Forsyth
Regional Office: Winston-Salem Regional Office
Previous Exp. Date: 10/31/91 Treatment Plant Class: Class IV
Classification changes within three miles:
none i,u LL
L01
Requested by:
Prepared by:.
Reviewed by:
Rosanne Barona Date: 3/12/91
Date:
Date:
' Toxicity Limits. IWC Ito % Acute/Chronic
Instream Monitoring: y
Parameters DD +ernQe(afuC,2 Crnr-A)c!-vih.J Fecal mI.G.-rri
Upstream � Location :f I G l too
+ ar lem a SI-;1,ni+
Downstream`/ (3 1��' Location lgcl3
3 ,�
Effluent Summer Winter
Characteristics
BODS (m ) f ;"
NH -N (mg/l) ')x.
3 1. Ar) Cso ZC
D.O. (mg/1) 0,5
TSS (mg/1) 30 20
F. Col. (/100 ml) 1100
000
pH (SU)
l l4
eccirrIum
QU4
n1 I .0 ' 9
read bu U 33 45
tq 0-A, nU e eaf»�rlf k7C_o r u CYO fU rnee C'
! �m mon`forrncbni4 � ;Um & 1 Q Fmm CfJe
r
Comments: 1;�rr)m wvirl ej
w
�etkJ1 . Cl\) Lrn.. 'I��Pped
i nd�-�Hicv I.63,d . C=k .:�Ago;_06 Cevl;�_i)c
TP
i, (:,
C�f�cg,
Modeler
r
Comments: 1;�rr)m wvirl ej
w
�etkJ1 . Cl\) Lrn.. 'I��Pped
i nd�-�Hicv I.63,d . C=k .:�Ago;_06 Cevl;�_i)c
TP
i, (:,
C�f�cg,
Modeler
Date Rec.

TO 19197339919 P.02
PUBLIC WORKS
DEPARTMENT
Cityof Winston-Salem
September 4, 1991
Ms. Ruth C. Swenek
Supervisor Instream Assessment Unit
N. C. Dept. of Environment, Health
and Natural Resources
512 North Salisbury Street
Raleigh, NC 27504
Dear Ms. Swanek:
This is in response to your letter July 24, 1991 regarding
the model rues for 14POES No. N00037834 for the Archie Elledge
Wastewater Treatment Plant. After careful review of plant perfor-
mance data, we feel the best overall limits for our facility would
be the following:
Model Run Ammonia (mg/1) D. 0. (mg/1) SOD 5 (mg/1)
4 1.2 6.5 21
Since we have chosen the ammonia toxicity limit which is the
most stringent, I understand the ammonia limit is a monthly aver-
age limit only. (There will be no weekly ammonia 1-Trnit). Since
our winter SOD limit would not be doubled under this scenario, I
would like consideration be given for a higher winter ammonia
limit greater than the 2.4 based on toxicity, if possible.
In addition, based on our telephone conversation August 28.
1991, I understand that our D. 0. limit for monitoring can be a
one time grab or the average of several grabs- during the day foil
reporting purposes. In regards to the metals limit, I feel it
would be in our best interests to accept a weekly average with a
weekly monitoring frequency.
Box 2511, Winston-Salem, North CarolMe 27102

v.
SEP-04-1991 08:59 FROM E r EDGE PLANT TO 19197339919 P.03
Me. Ruth C. Swanek
September 4, 1991
Page 2
I would like to thank you and your staff for your cooperation
and assistance in our requests during this renewal Process.
If there are -Further questions, please advise.
Sincerely,
Lee-B erly 714 dg- TP-superintendent
PC: Tom Sriff•in, Utilities Superintendent
Sarry Shearin, Utility Plants Engineer
Stan Webb, Muddy WTP Superintendent
lr
TOTAL P.03

RECFIVE0
N.C.NRCD
FACT SHEET FOR WASTELOAD ALLOCATIONS
Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
Request #
Winston-Salem/Archie Elledge WWTP
NCO037834
77.6% Domestic
Existing
Renewal
Salem Creek
C
030704
MAR 2 5 1.g91
Winston-Salem
6131 Regional Office
Forsyth Stream Characteristic:
WSRO USGS # 02115857
R. Barona Date: 1988
3/12/91 Drainage Area: 67.3
C17SE Summer 7Q10: 15
Winter 7Q 10: 18
Average Flow: 65
30Q2: 19
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
A QUALM model was developed in 1990 to determine if the existing BOD and NH3 limits are
adequate to protect the DO standard instream during critical low flow conditions. The modeling
results indicated that the Archie Elledge WWTP needs limits of 16 mg/1 BOD5, 2 mg/1 NH3, and 6
mg/1 DO to protect the DO standard. The modeling results were supported by 5 instream violations
ranging from 2.6 to 4.9 mg/1 during 1988. The City was informed of these limits changes in a
letter dated July 25, 1990. A copy of the modeling report can be obtained from the Technical
Support Branch.
Special Schedule Requirements and additional comments from Reviewers:
Recommended by: _Wk& C- Lel _4e. _ Date: 1�
Reviewed
Date:
Regional Supervisor: Dater l
Permits & Engineering: Date: `i! 3(4,
RETURN TO TECHNICAL SERVICES BY: APR 18 1991

CONVENTIONAL PARAMETERS
Existing Limits:
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1):
TSS (mg/1):
Fecal Col. (/100 ml):
pH (SU):
Oil & Grease (mg/1):
TP (mg/1):
TN (mg/1):
Recommended Limits:
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1):
TSS (mg/1):
Fecal Col. (/100 ml):
pH (SU):
Oil & Grease (mg/1):
TP (mg/1):
TN (mg/1):
Limits Changes Due To:
Instream Data
Ammonia Toxicity
Chlorine
Nutrient Sensitive Waters
HQW
New 7Q10 flow data
Special Modeling Studies
New facility information
Other
Monthly Average
Summer Winter
30
30
19
30
3
9
5
5
30
30
1000
1000
6-9
6-9
Monitor Monitor
Monitor Monitor
Monthly Average
Summer Winter
30
30
16
30
2
4
6
6
30
30
200
200
6-9
6-9
Monitor Monitor
Monitor Monitor
Parameter(s) Affected
BOD5, NH3, DO
NH3
BOD5,NH3,DO
City wanted to know how limits would change if it augmented flow through a minimum release
from Salem Lake. The model was insensitive to the upstream flow, and the only change which
would occur would be a 3 mg/l summer NH3 limit at a 7Q10 flow of 20 cfs.
Compliance data indicate that facility can meet proposed limits.

TOXICS
Toxicity Limit Monitoring Schedule
Mar, Jun, Sep, Dec
Existing Limit: None
Recommended Limit: Chronic Quarterly Ceriodaphnia tr7tQ�o)
Toxics or metals limi
Existine Limits:
Cadmium (ugh):
Chromium (ug/1): 62
Copper (ug/1): Monitoring
Nickel (ug/1): 66
Lead (ug/1):
Zinc (ug/1): Monitoring
Recommended Limits:
Weekly Avg
Daily Maximum
EHynm4,x at 7Q10
= 18 cfs
Cadmium (ug/1):
2.6
10
2.8
Chromium (ug/1):
66
264
69
Copper (ug/1):
Monitor
Monitor
Nickel (ug/1):
116
464
122
Lead (ug/1):
33
45
35
Zinc (ug/l):
Monitor
Monitor
Cyanide (ugh):
6.6
26
6.9
Limits Chang&s Due To: Parameter(s) Affected
New pretreatment information Cd, Cr, Ni, Pb, CN
Failing toxicity test
Other (onsite toxicity study, interaction, etc.) New Ni Standard
Additional Information on Above Limits:
Db-n%4x at 7Q11
= 20 cfs
2.9
72
Monitor
126
36
Monitor
7.1
The City of Winston-Salem submitted a letter on March 1 requesting that their metals limits be
weekly average. If the City chooses to monitor for metals daily, it can receive metals limits in
terms of both daily maximum and weekly average as given in the "Weekly Avg" and 'Daily Max"
columns in the above table. If the City chooses to monitor for metals weekly, it will be assigned
daily maximum limits equal to the "Weekly Avg" limits given in the above table. The City must
choose which monitoring frequency it prefers and this frequency will be set for the life of the
permit. The City will be sent a letter informing them of this option. If the City does not respond,
weekly monitoring will be assumed with the weekly average limits assigned as daily max. The last
two columns in the above Table are provided since the City also wanted to know how its limits
would change if stream flow was augmented through releases from Salem Lake. If the City
chooses to augment stream flow, they may monitor daily for metals and the limits given above
would be weekly average and new daily maximum values would be calculated per SOP.

MISCELLANEOUS .ANEOUS INFORMATION & SPECIAL CONDITIONS
Miscellaneous information pertinent to the renewal or new permit for this discharge. Include
relationship to the Basinwide management plan.
INSTREAM MONITORING REQUIREMENTS:
Upstream: Location: 1 Salem Ck at SR 1120
Downstream: Location: 3 Salem Ck at SR 2991, Muddy Ck at SR
1493, Muddy Ck at SR 1485
Parameters: DO, temperature, conductivity, fecal coliform
Special Instream monitoring locations or monitoring frequencies:
Instream monitoring location added at Muddy Ck at SR 1493 since pooling occurs in Muddy
Creek, and DO violations have been observed instream.
SPECIAL INSTRUCTIONS OR CONDITIONS
WASTELOAD SENT TO EPA?(Major) Y_ (Y or N)
(if yes, then attach schematic, toxics spreadsheet, copy of model, or
if not modeled, then old assumptions that were made, and description
of how fits into basinwide plan)
Modeling report submitted to EPA earlier.
Additional Information attached? (yes or no) If yes, explain attachments. Schematic, toxics
spreadsheet.

Y
w
w
cr
U
}
0
SC-
SC-5
SR 2991 Q
02.1 158.2500 (88)
DA-1IS MI
OA-I 12 CFS 02.1 158.5810(88)
S7010.12 CFS C-6 i0� DA-70.9 MI
W7010.27 CFS OA-69 CFS
3002 • 31 CFS S7010.16 CFS
SC-1
sR,� 1� ARCHI E ELLEDE WWTP SC-2
02.1 158.5710(88)
DA-67.30 MI
OA-65 CFS
S7010-15 CFS
W7010-18 CFS
3002.19 CFS
SC-7 W7010.19CFS
• SR 2995 3002.20 CFS
SC SR 290 K V- VN CREE
R3-- 1.3 MI 5 FOR CREEK
M��4E�REEK
C-9L-00'. FRy
RI
R4=0.4 MI
—0-
R5=0.3 MI 02.11594902(88)
SC-10 DA-11.6Ill
SR 1520 OA-II CFS
z - S7010.0.5 CFS
W7010.1.8 CFS
3002.2.6 CFS
kl 'Al
R/
02.1156.7980 �FR
DA=1943 MI
OA=1826 CFS
S7010=548 CFS
W70 I 0=1 102 CFS
FIGURE 2
R6=2.0 MI
R7=2.OM1
SC-12
I SR 1485
SC-11
SR 1493
02.1 139.6000 (88)
DA=260 MI
QA=247 CFS
S7010=65 CFS
W7010=92 CFS
3002=116 CFS
02.1 159.0200(88 )
DA-45.1 MI
OA-43 CFS
57010-7 CFS
W7010-14 CFS
3002.16 CFS

10/89
Facility Name Oiila -152km irCl2ie- ,7/ed ie ltkt) - Permit # W_DC137&3! f
CHRONIC TOXICITY TESTING REQUIREMENT (QR'1RLY)
The effluent discharge shall at no time exhibit chronic toxicity 'in any two consecutive toxicity tests,
using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is ](1-10 (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform guarterly monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed after thirty days from
issuance of this permit during the months of . Effluent
sampling for this testing shall be performed at the NPD9S permitted final effluent discharge below
all treatment processes.
All tnxiCity tectina recnitc renttirPrl ac nart of thic nPrmit r rNnrl;t;rnn will he PnterPri nn the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT-1(original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in -association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving strearn, this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, slrall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
7Q10 1 cfs
Permited Flow 3D MGD
IWC% -75,to
Basin & Sub -basin %d014
Receiving Stream SalenL Cz&Z
County Fnvmo_
Recommended by:
**Chronic Toxicity (Ceriodaphnia) P/Fat %, lYh�lUq&9, pm , See Part _, Condition _.

Facility Name n,�Irm - Avch, P / 0 ermit # AtCo.378� Pipe # Q(
CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
(**Chronic Toxicity (Ceriodaphnia) ChV at ]�%, /%lv un SeD , See Part Condition
The effluent discharge shall at no time exhibit 48 hour acute toxicity as lethality in an
effluent concentration of _% nor measure a quarterly arithmetic average chronic value
less than this same percentage of waste. The chronic value will be determined using the
geometric mean of the highest concentration having no statistically detectable impairment of
reproduction or survival and the lowest concentration that does have a statistically
detectable impairment of reproduction or survival. The presence of 48 hour acute toxicity
will be determined using Fisher's Exact Test at 48 hours from test initiation. Collection
methods, exposure regimes, and further statistical methods are defined in: The North
Carolina Phase IT Chronic Whole Effluent Toxicity Test Procedure (July, 1991) or
subsequent versions.
The permit holder shall perform at a minimum, quarterly monitoring using these procedures
to establish compliance with the permit condition. The first test will be performed after
thirty days from issuance of this permit during the months of Mar h��'O.�<
Effluent sampling for this testing 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 measures 48 hour acute
toxicity or a chronic value less than that specified above, then multiple concentration testing
shall be performed, at a minimum, in each of the two following months.
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 THP3B for the Chronic Value and TGA3B for the 48
hour Acute Toxicity measure (Pass/Fail). Additionally, DEM Form AT-3 (original) is to be
sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, NC 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response
data. Total residual chlorine of the effluent toxicity sample must be measured and reported
if chlorine is employed for disinfection of the waste stream.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Environmental Management indicate potential impacts to the receiving
stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate retesting (within 30 days of initial
monitoring event). Failure to submit suitable test results will constitute noncompliance
with monitoring requirements.
Permitted Flow _,�Q_ MGD Basin & Sub -basin 7(AU 04
7Q10 15 cfs Receiving Stream _5tlem Ci`.
IWC -75 U % County
Recommended by: l,(t t- . Date: J� W lq l
PIIQLR Version 7191

03/14/91 ver 3.1
Facility:
NPDES Permit No.:
Status (E, P, or M):
Permitted Flow:
Actual Average Flow:
Subbasin:
Receiving Stream:
Stream Classification:
7Q10:
IWC:
Stn'd / Bkg
Pollutant AL Cone.
(ug/1) (ug/1)
--------- -- -------- -------
Cadmium
S
2.0
Chromium
S
50.0
Copper
AL
7.0
Nickel
S
88.0
Lead
S
25.0
Zinc
AL
50.0
Cyanide
S
5.0
Mercury
S
0.012
Silver
AL
0.06
Selenium
S
5.00
Arsenic
S
50.00
Phenols
S
NA
NH3-N
C
T.R.Chlor.AL
17.0
Pollutant
Cadmium S 1
Chromium S 1
Copper AL I
Nickel S I
Lead S I
Zinc AL 1
Cyanide S I
Mercury S I
Silver AL I
Selenium S I
Arsenic S I
Phenols S I
NH3-N C I
T.R.Chlor.AL I
I
I
I
Allowable
Load
(0/d)
1.94
50.40
8.91
24.19
20.16
39.02
1.21
0.00
0.01
1.21
12.10
T 0 X I C S R E V I E W
Winston-Salem - Archie Elledge
NCO037834
E
30.0 mgd
19.3 mgd
030704
Salem Ck I--------- PRETREATMENT DATA -------------- I ---- EFLLUENT DATA---- I
C I ACTUAL PERMITTEDI I
15.0 cfs I Ind. + Ind. + I my, FREQUENCY 1
75.61 6 I Domestic PERMITTED Domestic I OBSERVED of Chronicl
I Removal Domestic Act.Ind. Total Industrial Total I Eflluent Criteria I
I Eff. Load Load Load Load Load I Conc. Violationsl
I % (#/d) (i/d) (4/d) (0/d) (4/d) I (ug/1) (fvio/4sam)I
I-------- -------- --------------------------------- I -------- --------- I
1 75% 0.90 2.23 3.13 0.45 1.350 I I
1 76% 3.67 4.45 8.12 2.89 6.560 1 17.0 0191 I I
I 818 13.72 11.26 24.98 8.68 22.400 I 60.0 2'9131 I N
1 12% 3.76 3.78 7.54 3.55 7.310 I 52.0 0131 I P
1 704 2.86 3.93 6.79 1.23 4.090 I I U
1 69% 23.20 33.12 56.32 2.45 25.650 1 215.0 25131 1 T
I 0% 0.97 0.970 1 I
I 0% I I S
1 04 0.35 0.350 I I E
I 016 I I C
I 0% I I T
I 08 I I 1
I 0% I I 0
I 08 I I N
I I I
I I I
I I I
ALLOWABLE PRDCT'D PRDCT'D PRDCT'D--------- MONITOR/LIMIT --------- 1--ADTN'L RECMMDTN'S--
Effluent Effluent Effluent Instream I Recomm'd
Cone. using using Cone. Based on Based on Based on I FREQUENCY INSTREAM
CHRONIC ACTUAL PERMIT using ACTUAL PERMITTED OBSERVED I Eff. Mon. Monitor.
Criteria Influent Influent OBSERVED Influent Influent Effluent I based on Recomm'd ?
(ug/1) (ug/1) (ug/1) (ug/1) Loading Loading Data 1 OBSERVED (YES/NO)
---------------------------------------------------------I--------- -
2.645 4.858 2.096 0.00 Limit Limit I
66.129 12.100 9.775 12.05 Limit Limit Limit I NCAC NO
9.258 29.469 26.425 45.37 Monitor Monitor Monitor I Weekly YES
116.387 41.197 39.941 39.32 Limit Limit Limit I NCAC NO
33.065 12.648 7.618 0.00 Limit Limit I
66.129 108.403 49.370 162.56 Monitor Monitor Monitor I Weekly YES
6.613 0.000 6.023 0.00 Limit I
0.016 0.000 0.000 0.00 I
0.079 0.000 2.173 0.00 Monitor I
6.613 0.000 0.000 0.00
66.129 D.000 0.000 0.00 I
0.000 0.000 0.000 0.00 I
0.000 0.00 1
22.484 0.00 I
I
I
I
(Cb,CA1
Obi. tPFlu.o.j'_f cfc f rmM z1go - ( jQ ( zM,2's. Facth1� mDn,1wt'i5 w eeVj for G, Cu, Nk zn
Ceh4al g(e,3 only had c�a back- t '71Go d, fuc�utn Cc i un& repecf� oral Se C%cf�„
`� y

W,(-dbn - Salem -Archie 011e-
Sa1eM_ Cf-
t_3o704
we , v e-d leffer
Qtt) - 13) �4bD _ 44015 CE 700 = 1 CP,s
G)d- !jrq},,5-t,L5
Cd W eeY-11. ._Av t a.0 � U_.
ti
(4)(C�p) � (C-0100)= - Cc�}(cad
lac
_CLUcued-. (S�( r,Atj 0c6
--W&l AV
a ll�;q �,�Wop
I2 F-fi V 4_� )?ij —
Pb
Cto S
Czu - (3t )(U (, 5�41�p, �{1.crr
Y((

�melot) fa f8 c�,s
03/14/91 ver 3.1
Facility:
NPDES Permit No.:
Status (E, P, or M):
Permitted Flow:
Actual Average Flow:
Subbasin:
Receiving Stream:
Stream Classification:
7Q10:
IWC:
Stn'd / Bkg
Pollutant AL Conc.
(ug/1) (ug/1)
---------
Cadmium
-- --------
S
2.0
Chromium
S
50.0
Copper
AL
7.0
Nickel
S
88.0
Lead
S
25.0
Zinc
AL
50.0
Cyanide
S
5.0
Mercury
S
0.012
Silver
AL
0.06
Selenium
S
5.00
Arsenic
S
50.00
Phenols
S
NA
NH3-N
C
T.R.Chlor.AL
17.0
Pollutant
Cadmium S I
Chromium S I
Copper AL I
Nickel S I
Lead S I
Zinc AL I
Cyanide S I
Mercury S I
Silver AL I
Selenium S I
Arsenic S I
Phenols S I
NH3-N C I
T.R.Chlor.AL I
I
I
I
Allowable
Load
(#/d)
2.06
53.77
9.51
25.81
21.51
41.63
1.29
0.00
0.02
1.29
12.90
T O X I C S R E V I E W
Winston-Salem - Archie Elledge
NC0037834
E
30.0 mgd
19.3 mgd
030704
Salem Ck 1--------- PRETREATMENT DATA -------------- I ---- EFLLUENT DATA---- I
C I ACTUAL PERMITTEDI I
18.0 cfs I Ind. + Ind. + I FREQUENCY 1
72.09 6 I Domestic PERMITTED Domestic I OBSERVED of Chronicl
I Removal Domestic Act.Ind. Total Industrial Total I Eflluent Criteria I
I Eff. Load Load Load Load Load I Conc. Violations)
I 6 (#/d) (#/d) (#/d) (#/d) (#/d) I (ug/1) (#vio/#sam)I
I-------- -------- --------------------------------- I -------- --------- I
I 75% 0.90 2.23 3.13 0.45 1.350 I I
I 768 3.67 4.45 8.12 2.89 6.560 I 17.0 I I
I 818 13.72 11.26 24.98 8.68 22.400 1 60.0 I N
I 12% 3.76 3.78 7.54 3.55 7.310 1 52.0 I P
1 70% 2.86 3.93 6.79 1.23 4.090 I I U
I 69% 23.20 33.12 56.32 2.45 25.650 I 215.0 I T
I 04 0.97 0.970 I I
I 096 I I S
I 0% 0.35 0.350 I I E
I 04 I I C
I 04 I I T
I of I I I
I of I I 0
I 0Pd I I N
I I I
I I I
I I I
ALLOWABLE PRDCT'D PRDCT'D PRDCT'D--------- MONITOR/LIMIT --------- 1--ADTN'L RECMMDTN'S--
Effluent Effluent Effluent Instream I Recomm'd
Conc. using using Conc. Based on Based on Based on I FREQUENCY INSTREAM
CHRONIC ACTUAL PERMIT using ACTUAL PERMITTED OBSERVED I Eff. Mon. Monitor.
Criteria Influent Influent OBSERVED Influent Influent Effluent I based on Recomm'd ?
(ug/1) (ug/1) (ug/1) (ug/1) Loading Loading Data I OBSERVED (YES/NO)
----------------------------------------------------------I---------------
2.774 4.858 2.096 0.00 Limit Limit I
69.355 12.100 9.775 12.26 Limit Limit Limit I NCAC NO
9.710 29.469 26.425 43.26 Monitor Monitor Monitor I Weekly YES
122.065 41.197 39.941 37.49 Limit Limit Limit I NCAC NO
34.677 12.648 7.618 0.00 Limit Limit 1
69.355 108.403 49.370 155.00 Monitor Monitor Monitor I Weekly YES
6.935 0.000 6.023 0.00 Limit I
0.017 0.000 0.000 0.00 I
0.083 0.000 2.173 0.00 Monitor I
6.935 0.000 0.000 0.00 I
69.355 0.000 0.000 0.00 I
0.000 0.000 0.000 0.00 I
0.000 0.00 I
23.581 0.00 I
I
I
I

-f Gu q� -P-10 > �o 20 Cja
03/14/91 ver 3.1
Facility:
NPDES Permit No.:
Status (E, P, or M):
Permitted Flow:
Actual Average Flow:
Subbasin:
Receiving Stream:
Stream Classification:
7Q10:
IWC:
Stn'd / Bkg
Pollutant AL Conc.
(ug/1) (ug/1)
---------
Cadmium
-- --------
S
2.0
Chromium
S
50.0
Copper
AL
7.0
Nickel
S
88.0
Lead
S
25.0
Zinc
AL
50.0
Cyanide
S
5.0
Mercury
S
0.012
Silver
AL
0.06
Selenium
S
5.00
Arsenic
S
50.00
Phenols
S
NA
NH3-N
C
T.R.Chlor.AL
17.0
Pollutant
Cadmium S I
Chromium S I
Copper AL I
Nickel S l
Lead S I
Zinc AL i
Cyanide S l
Mercury S I
Silver AL l
Selenium S I
Arsenic S I
Phenols S l
NH3-N C I
T.R.Chlor.AL I
I
I
Allowable
Load
(4/d)
2.15
56.02
9.91
26.89
22.41
43.37
1.34
0.00
0.02
1.34
13.44
T 0 X I C
S R E V
I E W
Winston-Salem - Archie Elledge
NC0037834
E
30.0
mgd
19.3
mgd
030704
Salem Ck
1--------- PRETREATMENT DATA --------------
I ---- EFLLUENT DATA----
I
C
I
ACTUAL
PERMITTEDI
I
20.0
cfa
I
Ind. +
Ind. + I
FREQUENCY
1
69.92
%
I
Domestic
PERMITTED
Domestic I
OBSERVED
of Chronicl
l Removal
Domestic
Act.Ind.
Total
Industrial
Total I
Eflluent
Criteria
I
1 Eff.
Load
Load
Load
Load
Load I
Cone.
Violationsl
I %
I--------
(4/d)
--------
(4/d)
--------
(4/d)
--------
(4/d)
---------
(4/d) I
-------- I
(ug/1)
--------
(4vio/4sam)l
---------
i 75%
0.90
2.23
3.13
0.45
1.350 1
I
1 76%
3.67
4.45
8.12
2.89
6.560 1
17.0
l I
I 81%
13.72
11.26
24.98
8.68
22.400 1
60.0
I N
I 12%
3.76
3.78
7.54
3.55
7.310 1
52.0
I P
I 70%
2.86
3.93
6.79
1.23
4.090 I
I U
I 6991
23.20
33.12
56.32
2.45
25.650 I
215.0
l T
I 095
0.97
0.970 I
I
I 0%
I
I S
I 0%
0.35
0.350 1
I E
I 0%
I
I C
I 0%
I
I T
I 0%
I
I 1
I 0%
I
I 0
I o%
I
I
I
I N
I
I
I
- ALLOWABLE PRDCT'D
PRDCT'D
PRDCT'D
I
I
--------- MONITOR/LIMIT ---------
I
I
1--ADTN'L RECMMDTN'S-- I
Effluent
Effluent
Effluent
Instream
I Recomm'd
I
Conc.
using
using
Conc.
Based on
Based on
Based on
I FREQUENCY
INSTREAM I
CHRONIC
ACTUAL
PERMIT
using
ACTUAL
PERMITTED
OBSERVED
I Eff. Mon.
Monitor. I
Criteria
Influent
Influent
OBSERVED
Influent
Influent
Effluent
i based on
Recomm'd ? I
(ug/1)
(ug/1)
(ug/1)
(ug/1)
Loading
Loading
Data
I OBSERVED
(YES/NO) I
--------
2.860
---------
4.858
--------
2.096
--------
0.00
--------
Limit
--------
Limit
---------I
---------
I
-------- I
I A
71.505
12.100
9.775
11.89
Limit
Limit
Limit
I NCAC
NO I N
10.011
29.469
26.425
41.95
Monitor
Monitor
Monitor
I Weekly
YES I A
125.849
41.197
39.941
36.36
Limit
Limit
Limit
I NCAC
NO I L
35.753
12.648
7.618
0.00
Limit
Limit
I
I Y
71.505
108.403
49.370
150.34
Monitor
Monitor
Monitor
I Weekly
YES I S
7.151
0.000
6.023
0.00
Limit
I
I 1
0.017
0.000
0.000
0.00
I
I S
0.086
0.000
2.173
0.00
Monitor
I
I
7.151
0.000
0.000
0.00
I
I R
71.505
0.000
0.000
0.00
i
I E
0.000
0.000
0.000
0.00
I
I S
0.000
0.00
I
I U
24.312
0.00
I
I L
I
IT
I
I
IS
I

Kul
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor
William W. Cobey, Jr., Secretary
July 24, 1991
Mr. Lee Byerly
Archie Elledge WWTP Superintendent
City of Winston-Salem
P.O. Box 2511
Winston-Salem, NC 27102
Subject: Items Discussed at July 9 meeting
Archie Elledge WWTP
NPDES No. NCO037834
Forsyth County
Dear Mr. Byerly:
George T. Everett, Ph.D.
Director
I am writing to follow up on several items discussed at our meeting on July 9. 1 have completed
further model runs to determine what your summer BOD5 limit will be under different effluent
ammonia and dissolved oxygen (DO) concentrations. The results are as follows:
Model Run Ammonia (mall)
1 2
2 1.2
3 2
4 1.2
5 1
7
20
7
24
6.5
18
6.5
21
6.5
21
You should note that 1.2 mg/l would be your ammonia limit if it were based on ammonia toxicity.
Please inform me of your preferred set of effluent limits by August 31. The corresponding
winter limits would be twice the summer limits, but the BOD5 limit cannot exceed 30 mg/I.
Since BOD5 would not be doubled under any of the scenarios, a higher ammonia limit could be
assigned if the model predicted that DO standard violations would not occur. However, for plant
design purposes, you should note that your winter ammonia limit based on toxicity would be 2.4
mg/I.
You were also concerned that dredging operations upstream of your downstream monitoring site on
Muddy Creek were influencing the dissolved oxygen concentrations. A review of the daily
monitoring reports (DMRs) indicated that there were elevated solids at the sampling station
located on Muddy Creek as compared to your downstream station on Salem Creek, but the solids
increase did not appear to be correlilei upoDnOPrevention Pays
F.O. Sox 29535. Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Since your cyanide limit was based on the permitted industrial load, and the data you provided at
the meeting indicate that cyanide is not present in your effluent, the limit will be replaced with a
monitoring requirement. However, the City should evaluate the permitted levels of cyanide and
revise its limits accordingly.
Our Pretreatment staff is reviewing the cadmium information which you provided to us, and a
dialog has been established with the State Pollution Prevention Program. It appears that
municipal or industrial pretreatment will not adequately address the problem given the relatively
low concentrations involved. Therefore, your efforts will likely need to focus on source
reduction at industries and at commercial establishments. It is my understanding that either
Pretreatment staff or representatives of the Pollution Prevention Program will contact the City
to discuss this matter further. Therefore, your limit will most likely be revised to a monitoring
requirement during an interim permit period with a plan of action outlined as a special permit
condition to come into compliance with final limits.
If you have any questions or comments, please contact me at [phone].
cc: Dale Overcash
Steve Mauney
Julia Storm
Central Files
Sincerely,
Wa;a C. d,)aAd
Ruth C. Swanek, Supervisor
Instream Assessment Unit
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

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NH3/TRC WLA Calculations
Winston-Salem -Archie Elledge WWTP
Permit No. NC0037834
Prepared By: Gary Perlmutter
Enter Design Flow (MGD): 30
Enter s7Q10 (cfs): 15
Enter w7Q10 (cfs): 18
Total Residual Chlorine (TRC)
Ammonia (Summer)
Daily Maximum Limit (ug/1)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS) 15
s7Q10 (CFS)
15
DESIGN FLOW (MGD) 30
DESIGN FLOW (MGD)
30
DESIGN FLOW (CFS) 46.5
DESIGN FLOW (CFS)
46.5
STREAM STD (UG/L) 17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1) 0
Upstream Bkgd (mg/1)
0.22
IWC (%) 75.61
IWC (%)
75.61
Allowable Conc. (ug/1) 22.5
Allowable Conc. (mg/1)
1.3
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
18
Monthly Average Limit: 200/100ml
DESIGN FLOW (MGD)
30
(If DF >331; Monitor)
DESIGN FLOW (CFS)
46.5
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF) 1.32
Upstream Bkgd (mg/1)
0.22
IWC (%)
72.09
Allowable Conc. (mg/1)
2.4
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis);
capped at 35 mg/I
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
❑ CHECK IF HQW OR ORW WQS
Archie Elledge WWTP
Grade IV
NCO037834
001
30.000
Salem Creek
03040103
C
❑ Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1 Q10s (cfs)
15.00
18.00
0.00
65.00
12.41
Effluent Hardness
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
55.7 mg/L(Avg)
I 49.45 mg/L (Avg)
I 54.18 m /L
54.38 m /L
Data Source(s)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Permittee-submitted DMRs and PPAs.
❑ CHECK TO APPLY MODEL
Follow directions for data entry. In some cases a
Par01
Par02
Par03
Par04
Par05
Par06E
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Parts
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Par25
Table 2. Parameters of Concern
Name WQs Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
1.0583
FW
6.3833
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/L
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
221.8075
FW
1710.5193
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
15.2604
FW
21.7798
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
6.9797
FW
179.8724
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
71.6237
FW
646.9472
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
1.1283
ug/L
Zinc
Aquatic Life
NC
244.0486
FW
242.8542
ug/L
Chlorodibromomethane
Human Health
C
21
HH
pg/L
Chloroform
Human Health
NC
2000
HH
pg/L
Dichlorobromomethane
Human Health
C
27
HH
pg/L
Antimony
Human Health
NC
640
HH
pg/L
37837 FW RPA 2023, input
3/8/2024

H1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
H2
Use "PASTE SPECIAL Use "PASTE SPECIAL
Effluent Hardness Values" then "COPY• Upstream Hardness Values" then "COPY"
. Maximum data . Maximum data
points = 58 points = 58
Date Data
BDL=1/2DL
1/2/2019
64
64
4/2/2019
44
44
4/3/2019
52
52
7/9/2019
56
56
10/14/2019
56
56
1/15/2020
60
60
4/9/2020
80
80
7/27/2020
52
52
10/27/2020
52
52
1/5/2021
26
26
1/6/2021
60
60
4/13/2021
52
52
7/15/2021
52
52
10/13/2021
52
52
1/12/2022
56
56
4/13/2022
60
60
7/20/2022
64
64
10/12/2022
60
60
1/11/2023
48
48
4/12/2023
68
68
Results
Std Dev.
10.5486
Mean
55.7000
C.V.
0.1894
n
20
10th Per value
47.60 mg/L
Average Value
55.70 mg/L
Max. Value
80.00 mg/L
Date Data
BDL=1/2DL
Results
1 8/14/2017
71
71
Std Dev.
11.5170
2 11/13/2017
36
36
Mean
49.4545
3 2/19/2018
60
60
C.V.
0.2329
4 5/14/2018
57
57
n
22
5 8/27/2018
57
57
10th Per value
37.10 mg/L
6 11/6/2018
48
48
Average Value
49.45 mg/L
7 2/5/2019
40
40
Max. Value
80.00 mg/L
8 5/21/2019
80
80
9 8/20/2019
39
39
10 11/12/2019
37
37
11 2/4/2020
46
46
12 5/5/2020
46
46
13 8/25/2020
48
48
14 11/10/2020
48
48
15 2/16/2021
38
38
16 5/4/2021
29
29
17 8/10/2021
50
50
18 8/10/2021
50
50
19 11/16/2021
56
56
20 2/22/2022
50
50
21 5/10/2022
51
51
22 5/10/2022
51
51
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
37837 FW RPA 2023, data
-2- 3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Date Data
1 1/16/2019 <
2 4/3/2019 <
3 5/8/2019 <
4 7/17/2019 <
5 10/16/2019 <
6 1/15/2020 <
7 6/18/2020 <
8 7/15/2020 <
9 10/14/2020 <
10 1/6/2021 <
11 1/13/2021 <
12 4/21/2021 <
13 7/21/2021 <
14 10/13/2021 <
15 1/12/2022 <
16 4/13/2022 <
17 7/20/2022 <
18 10/12/2022 <
19 1/11/2023 <
20 4/12/2023 <
21
22
23
24
25
26
27
28
29
3
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Arsenic
BDL=1/2DL
Results
2 1
Std Dev.
2 1
Mean
2 1
C.V.
2 1
n
2 1
2 1
Mult Factor =
2 1
Max. Value
2 1
Max. Fred Cw
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
Use "PASTE SPECIAL Par03
Values" then "COPY"
. Maximum data
points = 58
1.0000
0.0000
20
1.00
1.0 ug/L
1.0 ug/L
Use "PASTE SPECIAL
Beryllium Values" then "COPY"
. Maximum data
points = 58
Date
Data BDL=1/2DL Results
1 4/3/2019
< 0.5 0.25 Std Dev.
0.0000
2 1/6/2021
< 0.5 0.25 Mean
0.2500
3
C.V. (default)
0.6000
4
n
2
5
6
Mult Factor =
3.79
7
Max. Value
0.25 ug/L
8
Max. Fred Cw
0.95 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-3-
37837 FW RPA 2023, data
3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par04
Cadmium
Date
Data
BDL=1/2DL
Results
1
1 /2/2019
<
0.15
0.075
Std Dev.
2
1/16/2019
<
0.15
0.075
Mean
3
4/2/2019
<
0.15
0.075
C.V.
4
4/3/2019
<
0.15
0.075
n
5
5/8/2019
<
0.15
0.075
6
7/9/2019
<
0.15
0.075
Mult Factor =
7
7/17/2019
<
0.15
0.075
Max. Value
8
10/14/2019
<
0.15
0.075
Max. Fred Cw
9
10/16/2019
<
0.15
0.075
10
1/15/2020
<
0.15
0.075
11
4/9/2020
<
0.15
0.075
12
6/18/2020
<
0.15
0.075
13
7/15/2020
<
0.15
0.075
14
7/27/2020
<
0.15
0.075
15
10/14/2020
<
0.15
0.075
16
10/27/2020
<
0.15
0.075
17
1 /5/2021
<
0.15
0.075
18
1 /6/2021
<
0.15
0.075
19
1/13/2021
<
0.15
0.075
20
4/13/2021
<
0.15
0.075
21
4/21 /2021
<
0.15
0.075
22
7/15/2021
<
0.15
0.075
23
7/21/2021
<
0.15
0.075
24
10/13/2021
<
0.15
0.075
25
1/12/2022
<
0.15
0.075
26
4/13/2022
<
0.15
0.075
27
7/20/2022
<
0.15
0.075
28
10/12/2022
<
0.15
0.075
29
1/11/2023
<
0.15
0.075
30
4/12/2023
<
0.15
0.075
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL Pdr05
Values" then "COPY"
. Maximum data
points = 58
0.0750
0.0000
30
1.00
0.075 ug/L
0.075 ug/L
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Chlorides
Date Data BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Fred Cw
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points =
58
NO DATA
NO DATA
0
N/A
N/A mg/L
N/A mg/L
-4-
37837 FW RPA 2023, data
3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par06
Chlorinated Phenolic Compounds
Use "PASTE SPECIAL
valves" imthenum •copydata
. Max
Par07
Total Phenolic Compounds
points = 58
Date Data BDL=1/2DL Results
Date
Data BDL=1/2DL
Results
1
Std Dev.
NO DATA
1
4/2/2019
< 10 5
Std Dev.
2
Mean
NO DATA
2
1/5/2021
74 74
Mean
3
C.V.
NO DATA
3
10/3/2017
11 11
C.V. (default)
4
n
0
4
n
5
5
6
Mult Factor =
N/A
6
Mult Factor =
7
Max. Value
N/A ug/L
7
Max. Value
8
Max. Fred Cw
N/A ug/L
8
Max. Fred Cw
9
9
10
10
11
11
12
12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
30.0000
0.6000
3
3.00
74.0 ug/L
222.0 ug/L
37837 FW RPA 2023, data
-5- 3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par08
Chromium III
Date
Data BDL=1/2DL Results
1
Std Dev.
2
Mean
3
C.V.
4
n
5
6
Mult Factor =
7
Max. Value
8
Max. Fred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Pdr09
Use "PASTE SPECIAL
Values" then "COPY"
Chromium VI
. Maximum data
points = 58
Date
Data BDL=1/2DL Results
NO DATA
1
Std Dev.
NO DATA
2
Mean
NO DATA
3
C.V.
0
4
n
5
N/A
6
Mult Factor =
N/A Ng/L
7
Max. Value
N/A Ng/L
8
Max. Fred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY'
. Maximum data
points = 58
NO DATA
NO DATA
NO DATA
0
N/A
N/A Ng/L
N/A Ng/L
37837 FW RPA 2023, data
-6- 3/8/2024

Par10
Date Data
1 1/16/2019 <
2 4/3/2019 <
3 5/8/2019 <
4 7/17/2019 <
5 10/16/2019 <
6 1/15/2020 <
7 6/18/2020 <
8 7/15/2020 <
9 10/14/2020 <
10 1/6/2021 <
11 1/13/2021 <
12 4/21/2021 <
13 7/21/2021 <
14 10/13/2021 <
15 1/12/2022 <
16 4/13/2022 <
17 7/20/2022 <
18 10/12/2022 <
19 1/11/2023 <
20 4/12/2023 <
21
22
23
24
25
26
27
28
29
3
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
Pall
Use "PASTE SPECIAL Use "PASTE SPECIAL
Chromium, Total Values" then "COPY" Copper Values" then "COPY"
. Maximum data . Maximum data
points = 58 points = 58
BDL=1/2DL
Results
2 1
Std Dev.
2 1
Mean
2 1
C.V.
2 1
n
2 1
2 1
Mult Factor =
2 1
Max. Value
2 1
Max. Fred Cw
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
2 1
1.0000
0.0000
20
1.00
1.0 Ng/L
1.0 Ng/L
Date Data
BDL=1/2DL
Results
1
1/16/2019
6
6
Std Dev.
1.1786
2
4/3/2019
4
4
Mean
2.7800
3
5/8/2019
3
3
C.V.
0.4239
4
7/17/2019
3
3
n
20
5
10/16/2019 <
2
1
6
1/15/2020
3
3
Mult Factor =
1.26
7
6/18/2020
2
2
Max. Value
6.00 ug/L
8
7/15/2020
3
3
Max. Fred Cw
7.56 ug/L
9
10/14/2020
3
3
10
1/6/2021
3
3
11
1/13/2021
2
2
12
4/21/2021
4
4
13
7/21/2021
2
2
14
10/13/2021
2
2
15
1/12/2022
3.6
3.6
16
4/13/2022
3
3
17
7/20/2022
3
3
18
10/12/2022 <
2
1
19
1/11/2023 <
2
1
20
4/12/2023
3
3
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
37837 FW RPA 2023, data
-7- 3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par12
Cyanide
Date
Data
BDL=1/2DL
Results
1
1 /2/2019
<
20
10
Std Dev.
2
1/15/2019
<
20
10
Mean
3
4/2/2019
<
20
10
C.V.
4
5/7/2019
<
20
10
n
5
7/9/2019
<
20
10
6
7/16/2019
<
20
10
Mult Factor =
7
10/14/2019
<
20
10
Max. Value
8
10/15/2019
<
20
10
Max. Fred Cw
9
1/14/2020
<
20
10
10
6/16/2020
<
20
10
11
6/17/2020
<
20
10
12
7/14/2020
<
20
10
13
7/27/2020
<
20
10
14
10/13/2020
<
20
10
15
10/27/2020
<
20
10
16
1 /5/2021
<
20
10
17
1 /6/2021
<
20
10
18
1/12/2021
<
20
10
19
4/13/2021
<
5
5
20
4/20/2021
6
5
21
7/15/2021
<
20
10
22
7/20/2021
<
20
10
23
10/12/2021
<
20
10
24
1/11/2022
<
20
10
25
4/12/2022
<
20
10
26
7/19/2022
<
20
10
27
10/11/2022
<
20
10
28
1/10/2023
<
20
10
29
4/11/2023
<
20
10
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL Par13
Values" then "COPY"
. Maximum data
points = 58
9.66
0.1335
29
1.05
10.0 ug/L
10.5 ug/L
Use "PASTE SPECIAL
Fluoride Values" then "COPY"
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1/16/2019
550
550
Std Dev.
145.9743
2
5/8/2019
870
870
Mean
705.5556
3
7/17/2019
920
920
C.V.
0.2069
4
10/16/2019
970
970
n
18
5
1/15/2020
680
680
6
6/18/2020
710
710
Mult Factor =
1.14
7
7/15/2020
930
930
Max. Value
970.0 ug/L
8
10/14/2020
610
610
Max. Fred Cw
1105.8 ug/L
9
1/13/2021
600
600
10
4/21/2021
600
600
11
7/21/2021
610
610
12
10/13/2021
690
690
13
1/12/2022
620
620
14
4/13/2022
690
690
15
7/20/2022
810
810
16
10/12/2022
810
810
17
1/11/2023
540
540
18
4/12/2023
490
490
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
37837 FW RPA 2023, data
-8- 3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par14
Lead
Date
BDL=1/2DL
Results
1
1/16/2019
< 0.5
0.25
Std Dev.
2
4/3/2019
< 0.5
0.25
Mean
3
5/8/2019
< 0.5
0.25
C.V.
4
7/17/2019
0.5
0.5
n
5
10/16/2019
< 0.5
0.25
6
1/15/2020
< 0.5
0.25
Mult Factor =
7
6/18/2020
5.3
5.3
Max. Value
8
7/15/2020
1.1
1.1
Max. Fred Cw
9
10/14/2020
0.5
0.5
10
1 /6/2021
0.7
0.7
11
1/13/2021
< 0.5
0.25
12
4/21/2021
0.8
0.8
13
7/21/2021
< 0.5
0.25
14
10/13/2021
< 0.5
0.25
15
1 /12/2022
1.7
1.7
16
4/13/2022
< 0.5
0.25
17
7/20/2022
10
10
18
10/12/2022
< 0.5
0.25
19
1/11/2023
< 0.5
0.25
20
4/12/2023
< 0.5
0.25
21
22
23
24
25
26
27
28
29
3
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL Par15
Values" then "COPY"
. Maximum data
points = 58
1.1800
2.0085
20
2.04
10.000 ug/L
20.400 ug/L
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Mercury
Values" then "COPY"
. Maximum data
points = 58
Date Data BDL=1/2DL Results
Std Dev.
NO DATA
Mean
NO DATA
C.V.
NO DATA
n
0
Mult Factor =
N/A
Max. Value
N/A ng/L
Max. Fred Cw
N/A ng/L
-9-
37837 FW RPA 2023, data
3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par16
Date Data
1 1/16/2019 <
2 5/8/2019
3 7/17/2019
4 10/16/2019
5 1 /15/2020
6 6/18/2020
7 7/15/2020
8 10/14/2020 <
9 1/13/2021 <
10 4/21/2021
11 7/21/2021
12 10/13/2021 <
13 1/12/2022 <
14 4/13/2022 <
15 7/20/2022
16 10/12/2022 <
17 1 /11 /2023
18 4/12/2023 <
19
20
21
22
23
24
25
26
27
28
29
3
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Molybdenum
BDL=1/2DL
Results
2 1
Std Dev.
3 3
Mean
3 3
C.V.
2 2
n
2 2
7 7
Mult Factor =
4 4
Max. Value
2 1
Max. Fred Cw
2 1
2 2
2 2
2 1
2 1
2 1
2 2
2 1
2 2
2 1
Use "PASTE SPECIAL Par17 & Pdr18
Values" then "COPY" Nickel
. Maximum data
points = 58
2.0556
0.7363
18
1.51
7.0 ug/L
10.6 ug/L
Use "PASTE SPECIAL
Values " then "COPY"
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1/16/2019
3.1
3.1
Std Dev.
1.7358
2
4/3/2019
2.1
2.1
Mean
2.6600
3
5/8/2019
2.2
2.2
C.V.
0.6526
4
7/17/2019
2.2
2.2
n
20
5
10/16/2019
2
2
6
1/15/2020
3.3
3.3
Mult Factor =
1.40
7
6/18/2020
2.4
2.4
Max. Value
9.5 Ng/L
8
7/15/2020
2.2
2.2
Max. Fred Cw
13.3 Ng/L
9
10/14/2020
1.9
1.9
10
1 /6/2021
1.8
1.8
11
1/13/2021
1.7
1.7
12
4/21/2021
4.1
4.1
13
7/21/2021
9.5
9.5
14
10/13/2021
2.4
2.4
15
1/12/2022
2.3
2.3
16
4/13/2022
1.9
1.9
17
7/20/2022
2
2
18
10/12/2022
3.1
3.1
19
1/11/2023
1.5
1.5
20
4/12/2023
1.5
1.5
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
37837 FW RPA 2023, data
-10- 3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par19
Date Data
1 1/16/2019 <
2 4/3/2019 <
3 5/8/2019 <
4 7/17/2019 <
5 10/16/2019 <
6 1/15/2020 <
7 6/18/2020 <
8 7/15/2020 <
9 10/14/2020 <
10 1/6/2021 <
11 1/13/2021 <
12 4/21/2021 <
13 7/21/2021 <
14 10/13/2021 <
15 1/12/2022 <
16 4/13/2022 <
17 7/20/2022 <
18 10/12/2022 <
19 1/11/2023 <
20 4/12/2023
21
22
23
24
25
26
27
28
29
3
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Selenium
BDL=1/2DL
Results
2 1
Std Dev.
1 0.5
Mean
1 0.5
C.V.
2 1
n
1 0.5
1 0.5
Mult Factor =
1 0.5
Max. Value
2 1
Max. Fred Cw
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 1
Use "PASTE SPECIAL Par20
Values" then "COPY"
. Maximum data
points = 58
0.6000
0.3420
20
1.20
1.0 ug/L
1.2 ug/L
Use "PASTE SPECIAL
Silver Values" then "COPY"
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1/16/2019
<
0.5
0.25
Std Dev.
0.0000
2
4/3/2019
<
0.5
0.25
Mean
0.2500
3
5/8/2019
<
0.5
0.25
C.V.
0.0000
4
7/17/2019
<
0.5
0.25
n
20
5
10/16/2019
<
0.5
0.25
6
1/15/2020
<
0.5
0.25
Mult Factor =
1.00
7
6/18/2020
<
0.5
0.25
Max. Value
0.250 ug/L
8
7/15/2020
<
0.5
0.25
Max. Fred Cw
0.250 ug/L
9
10/14/2020
<
0.5
0.25
10
1/6/2021
<
0.5
0.25
11
1/13/2021
<
0.5
0.25
12
4/21/2021
<
0.5
0.25
13
7/21/2021
<
0.5
0.25
14
10/13/2021
<
0.5
0.25
15
1/12/2022
<
0.5
0.25
16
4/13/2022
<
0.5
0.25
17
7/20/2022
<
0.5
0.25
18
10/12/2022
<
0.5
0.25
19
1/11/2023
<
0.5
0.25
20
4/12/2023
<
0.5
0.25
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
37837 FW RPA 2023, data
3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par21
Par22
Use "PASTE SPECIAL
Use "PASTE SPECIAL
Zinc
values" then coPr'
Chlorodibromomethane
Values" then "COPY"
. Maximum data
. Maximum data
points = 58
points = 58
Date Data
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
1
1/2/2019
64
64
Std Dev.
12.4948
1
1/2/2019 <
1
0.5
Std Dev.
2.6874
2
1/16/2019
74
74
Mean
63.8667
2
4/2/2019 <
1
0.5
Mean
4.1505
3
4/2/2019
68
68
C.V.
0.1956
3
6/11/2019
5.66
5.66
C.V.
0.6475
4
4/3/2019
92
92
n
30
4
7/9/2019
5.43
5.43
n
20
5
5/8/2019
68
68
5
10/14/2019
4.56
4.56
6
7/9/2019
54
54
Mult Factor =
1.07
6
1/15/2020
3.38
3.38
Mult Factor =
1.39
7
7/17/2019
85
85
Max. Value
93.0 ug/L
7
4/9/2020
6.76
6.76
Max. Value
12.200000 Ng/L
8
10/14/2019
60
60
Max. Fred Cw
99.5 ug/L
8
7/27/2020
12.2
12.2
Max. Fred Cw
16.958000 Ng/L
9
10/16/2019
55
55
9
10/27/2020
5.22
5.22
10
1/15/2020
58
58
10
1/5/2021
1.94
1.94
11
4/9/2020
60
60
11
4/13/2021
3.09
3.09
12
6/18/2020
51
51
12
7/15/2021
7.19
7.19
13
7/15/2020
59
59
13
10/18/2021
4.27
4.27
14
7/27/2020
50
50
14
1/11/2022
2.5
2.5
15
10/14/2020
48
48
15
4/12/2022
4.3
4.3
16
10/27/2020
46
46
16
7/19/2022
3.89
3.89
17
1/5/2021
64
64
17
10/11/2022 <
10
5
18
1/6/2021
54
54
18
10/31/2022
3.45
3.45
19
1/13/2021
51
51
19
1/10/2023 <
2
1
20
4/13/2021
71
71
20
4/12/2023
2.17
2.17
21
4/21/2021
62
62
21
22
7/15/2021
86
86
22
23
7/21/2021
58
58
23
24
10/13/2021
59
59
24
25
1/12/2022
93
93
25
26
4/13/2022
66
66
26
27
7/20/2022
62
62
27
28
10/12/2022
62
62
28
29
1/11/2023
78
78
29
30
4/12/2023
58
58
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
37837 FW RPA 2023, data
-12- 3/8/2024

Par23
Date Data
1 10/3/2017
2 4/2/2019
3 6/11/2019
4 1 /5/2021
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
3
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
Use "PASTE SPECIAL Par24 Use "PASTE SPECIAL
Chloroform Values" then "COPY" Dichlorobromomethane Values" then "COPY"
. Maximum data . Maximum data
points = 58 points = 58
BDL=1/2DL
Results
20.3
20.3
Std Dev.
4.5144
11.5
11.5
Mean
14.5000
15.8
15.8
C.V. (default)
0.6000
10.4
10.4
In
4
Mult Factor = 2.59
Max. Value 20.300000 Ng/L
Max. Pred Cw 52.577000 Ng/L
Date Data
BDL=1/2DL
Results
1
1/2/2019
4.32
4.32
Std Dev.
6.2981
2
4/2/2019 <
1
0.5
Mean
10.4025
3
6/11/2019
14
14
C.V.
0.6054
4
7/9/2019
18.2
18.2
In
20
5
10/14/2019
16.2
16.2
6
1/15/2020
9.82
9.82
MultFactor=
1.37
7
4/9/2020
14.2
14.2
Max. Value
23.100000 Ng/L
8
7/27/2020
23.1
23.1
Max. Pred Cw
31.647000 pg/L
9
10/27/2020
17.1
17.1
10
1/5/2021
6.95
6.95
11
4/13/2021
7.6
7.6
12
7/15/2021
20.7
20.7
13
10/ 18/2021
12.7
12.7
14
1/11/2022
5.2
5.2
15
4/12/2022
7.57
7.57
16
7/19/2022
8.21
8.21
17
10/11/2022 <
10
5
18
10/31/2022
8.31
8.31
19
1/10/2023
2.12
2.12
20
4/12/2023
6.25
6.25
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-13-
37837 FW RPA 2023, data
3/8/2024

REASONABLE POTENTIAL ANALYSIS
Par25
Use "PASTE SPECIAL
Antimony
Values" then "COPY"
. Maximum data
points = 58
Date Data
BDL=1/2DL
Results
1
10/3/2017
1 1
Std Dev.
0.2887
2
4/2/2019
1 1
Mean
1.1667
3
1/5/2021
1.5 1.5
C.V. (default)
0.6000
4
n
3
5
6
Mult Factor =
3.00
7
Max. Value
1.500000 Ng/L
8
Max. Fred Cw
4.500000 Ng/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
37837 FW RPA 2023, data
- 14 - 3/8/2024

Archie Elledge WWTP
NCO037834
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD)
= 30.0000
WWTP/WTP Class: Grade IV
1Q10S (cfs)
= 12.41
IWC% @ 1Q10S = 78.93396707
7Q10S (cfs)
= 15.00
IWC% @ 7Q10S = 75.6097561
7Q10W (cfs)
= 18.00
IWC% @ 7Q10W = 72.09302326
30Q2 (cfs)
= 0.00
IWC% @ 30Q2 = 100
Avg. Stream Flow, QA (cfs)
= 65.00
IW°/uC @ QA = 41.70403587
Receiving Stream:
Salem Creek HUC 03040103 Stream Class: C
Outfall 001
Qw=30MGD
COMBINED HARDNESS (mg/L)
Acute = 54.38 mg/L
Chronic = 54.18 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
J
F
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
a
Applied
Chronic Acute
D # Det. Max Pred Cw Allowable Cw
Standard
Acute (FW): 430.7
Arsenic
C
150 FW(7Q10s) 340
ug/L
20 0
1.0
_ _ _ ___ _ ___
Chronic (FW) 198.4
_____________ _
Max MDL = 2
Arsenic
C
10 HH/WS(Qavg)
ug/L
NO DETECTS
_ _ _
Chronic (HH): 24.0
No detects - no monitoring or limits required
Max MDL = 2
Acute: 82.35
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
2 0
0.95
--Chronic:-----8.60 --
--------------------------
Note: n <9
C.V. (default)
No detects - no monitoring or limits required
Limited data set
NO DETECTS
Max MDL = 0.5
Acute: 8.087
Cadmium
NC
1.0583 FW(7Q10s) 6.3833
ug/L
30 0
0.075
_ _ _
Chronic: 1.400
No detects - no monitoring or limits required
NO DETECTS
Max MDL = 0.15
Acute: NO WQS
Chlorides
NC
230 FW(7Q10s)
mg/L
0 0
N/A
_ _
--Chronic: - -304.2
- - - - - - - - - - -
Acute: NO WQS
Chlorinated Phenolic Compounds
NC
1 A(30Q2)
ug/L
0 0
N/A
_ _ _
1.0-------------------------------
- Chronic: ------
Acute: NO WQS
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
3 2
222.0
Note: n < 9
C.V. (default)
___ _ ____ _ ___
Chronic: 300.0
_ _ _ _ _ _ _ _ _ _ _ ___
No RP for limited dataset (n<8 samples). No
Limited data set
No value > Allowable Cw
monitoring or limits required
Acute: 2,167.0
Chromium III
NC
221.8075 FW(7Q10s) 1710.5193
µg/L
0 0
N/A
_ _
--Chronic: ---- 293.4 --
--------------------------
Acute: 20.3
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
N/A
--Chronic:-----14.5 --
--------------------------
Chromium, Total
NC
µg/L
20 0
1.0
Max reported value = 1
No detects - no monitoring or limits required
NO DETECTS
Max MDL = 2
37837 FW RPA 2023, rpa
Page 15 of 16 3/8/2024

Archie Elledge WWTP -
NC0037834 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfall 001
Qw=30MGD
Acute: 27.59
Copper
NC
15.2604 FW(7Q10s) 21.7798
ug/L
20 17
7.56
--C_ _ - - - - --
--------------------------
hronic: 2_0.18_
Stream impaired for Copper -monitor quarterly
No value > Allowable Cw
Acute: 27.9
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
29 1
10.5
_ _ _
Chronic: 6.6
All but 2 data < 20 mg/L; add quarterly monitoring &
27 values > Allowable Cw,
report to lower PCIL
Acute: NO WQS
Fluoride
NC
1800 FW(7Q10s)
ug/L
18 18
1,105.8
_ _ _
Chronic: 2,380.E
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 227.877
Lead
NC
6.9797 FW(7Q10s) 179.8724
ug/L
20 8
20.400
_ _ _ _ _
Chronic: 9.231
No RP, Predicted Max < 50% of Allowable Cw - No
1 values > Allowable Cw
Monitoring required
Acute: NO WQS
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
0 0
N/A
_ _
-Chronic:---15.9
----------
Acute: NO WQS
Molybdenum
NC
2000 HH(7Q10s)
ug/L
18 10
10.6
Chronic: 2,645.2
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute (FW): 819.6
Nickel
NC
71.6237 FW(7Q10s) 646.9472
µg/L
20 20
13.3
Chronic (FW): 94.7
No RP, Predicted Max < 50% of Allowable Cw- No
No value >_Allow_able_Cw
Monitoring required
Nickel
NC
25.0000 WS(7Q10s)
µg/L
Chronic (WS)_33 1
No value > Allowable Cw
Acute: 70.9
Selenium
NC
5 FW(7Q10s) 56
ug/L
20 1
1.2
_ _ _
Chronic: 6.6
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 1.429
Silver
NC
0.06 FW(7Q10s) 1.1283
ug/L
20 0
0.250
_ _ _ _
Chronic: 0.079
No detects - no monitoring or limits required
NO DETECTS
Max MDL = 0.5
Acute: 307.7
Zinc
NC
244.0486 FW(7Q10s) 242.8542
ug/L
30 30
99.5
_ _
--Chronic: - - - - 3_22.8_ --
--------------------------
Stream impaired for Copper -monitor quarterly
No value > Allowable Cw
Acute: NO WQS
Chlorodibromomethane
C
21 HH(Qavg)
µg/L
20 16
16.95800
_
Chronic: 50.35484
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: NO WQS
Chloroform
NC
2000 HH(7Q10s)
µg/L
4 4
52.57700
Note: n < 9
C.V. (default)
Chronic: 2645.16129
No RP, limited dataset (n<8)
Limited data set
No value > Allowable Cw
Acute: NO WQS
Dichlorobromomethane
C
27 HH(Qavg)
µg/L
20 18
31.64700
_ _ _
Chronic: 64.74194
No RP, Predicted Max < 50% of Allowable Cw, - No
No value > Allowable Cw
Monitoring required
Acute: NO WQS
Antimony
NC
640 HH(7Q10s)
µg/L
3 3
4.50000
Note: n < 9
C.V. (default)
Chronic: 846.45161
No RP, limited dataset (n<8)
Limited data set
No value > Allowable Cw
37837 FW RPA 2023, rpa
Page 16 of 16 3/8/2024

FACILITY: Archie Elledge WWTP Outfall001
NPDES PERMIT: NCO037834
Dissolved to Total Metal Calculator
In accordance with Federal Regulations, permit limitations must be written as Total Metals per 40 CFR 122.45(c)
PARAMETER
Cadmium (d)
Cd -Trout stre.
Chromium III (d)(
Chromium VI (d)
Chromium. Total
Nickel(d)(h)
Ni - WS streams
Silver (d)(h,acut
Zinc (d)(h)
Beryllium
Arsenic (c
Receiving
Receiving
Rec. Stream
NPDES
Total Suspended
Combined
Combined
Instream Instream
Effluent
Stream
Stream
Solids
Hardness
Hardness
Upstream
Wastewater Wastewater
Hardness
1Q10
Flow Limit
Hardness
summer
summer 7Q10
-Fixed Value-
chronic
Acute
Concentration Concentration
Average (mg/L)
Average
7Q10 (CFS)
(MGD)
[MGD]
[MGD]
mg/L)
(mg/L)
(mg/L)
(Chronic) (Acute)
(mg/L)
15.0000
9.6774
8.0065
30.0000
10
54.177
54.384
75.6098 78.9340 49.454545
55.7
Upstream Hard Avg (mg/L) = 49.4545
EFF Hard Avg (mg/L) = 55.7
Dissolved Metals Criteria
US EPA
Total Metal Criteria
Total Metal =
COMMENTS (identify parameters to PERCS Branch to maintain in facility's LTMP/STMP):
after applying hardness
Translators using
Dissolved Metal
+Translator
equation
Default Partition
ChronicI
Acute
Coefficients
Chronic
Acute
lug/,
u /I
streams
rug/I
u /I
0.271
1.61
0.252
1.061
6.38
45
3461
0.202
221.81
1710.52
11
16
1.000
11.00
16.00
N/A
N/A
5.3
7.6
0.348
15.26
21.78
1.28
33
0.184
6.98
179.87
31
280
0.432
71.62
646.95
25 N/A
0.06
1.131
1.0001
0.061 1.13
70
701
0.2881
244.05 242.85
1.0001 • 6.5
1.000 150
(d) = dissolved metal standard. See 15A NCAC 02B .0211 for more information.
(h) = hardness -dependent dissolved metal standard. See 15A NCAC 02B .0211 for more information.
(t) = based upon measurement of total recoveable metal. See 15A NCAC 02B .0211 for more information.
The Human Health standard for Nickel in Water Supply Streams is 25 mg/L which is Total Recoverable metal standard.
The Human Health standard for Arsenic is 10 µg/L which is Total Recoverable metal standard.

Permit No. NC0037834
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as
approved.
Table 1. NC Dissolved Metals Water Q ality Standards/A uatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW, µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
213.0200 (e.g., arsenic at 10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.136672-[1n hardness] (0. 04183 8)) • e^{0.9151 [In hardness]-3.1485)
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness](0.041838)} • e^{0.9151[ln hardness] -3.623 6)
Cadmium, Chronic
WER*{1.101672-[ln hardness](0.041838)} • e^{0.7998[ln hardness]-4A45l)
Chromium III, Acute
WER*0.316 e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 e^{0.9422[ln hardness]-1.700)
Copper, Chronic
WER*0.960 e^{0.8545[ln hardness]-1.702)
Lead, Acute
WER*{1.46203-[ln hardness](0.145712)) • e^{1.273[ln hardness]-1.460)
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)) • e^{1.273[ln hardness]-4.705)
Nickel, Acute
WER*0.998 e^{0.8460[ln hardness]+2.255)
Nickel, Chronic
WER*0.997 e^{0.8460[ln hardness]+0.0584)
Page 1 of 4

Permit No. NCO037834
Silver, Acute
WER*0.85 • eA0.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

Permit No. NCO037834
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avfz. Effluent Hardness, mg/L)+s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q 10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1 Q 10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal 1 + { [Kpo] [ss('+a)] [10-6] }
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q 10 + Qw) (Cwgs)(s7Q 10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q 10)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q 10 may be incorporated as applicable:
1 Q 10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0037834
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness, mg/L
SS. 7
Permittee submitted DMRs
(Total as CaCO3)
Average Upstream Hardness, mg/L
49.45
Permittee submitted data
(Total as CaCO3)
7Q 10 summer (cfs)
15.0
Reported in previous permit Fact
Sheet
1 Q 10 (cfs)
65.0
Calculated in RPA spreadsheet
Permitted Flow (MGD)
30.0
Design flow
Date: August 7, 2023
Permit Writer: Gary Perlmutter
Page 4 of 4

3/8/24 WQS = 12 ng/L MERCURY WQBEL/TBEL EVALUATION V:2013-6
Facility Name Winston-Salem - Archie Elledge / NC0037834 No Limit Required
/Permit No.
MMP Required
Total Mercury 1631E PQL = 0.5 ng/L 7Q10s = 15.000 cfs WQBEL = 15.87 ng/L
Date Modifier Data Entry Value Permitted Flow = 30.000 47 ng/L
2/12/19
2.17
2.17
4/2/19
1.96
1.96
5/7/19
1.53
1.53
7/17/19
1.55
1.55
10/16/19
1.01
1.01
1.6 ng/L
- Annual Average for 2019
1/22/20
1.2
1.2
4/3/20
1.39
1.39
7/10/20
0.76
0.76
10/8/20
0.71
0.71
1.0 ng/L
- Annual Average for 2020
1/8/21
1.18
1.18
4/12/21
1.11
1.11
7/9/21 <
1.33
0.665
10/1/21
0.73
0.73
0.9 ng/L
- Annual Average for 2021
1/7/22
1.46
1.46
4/8/22
0.88
0.88
7/15/22
5.26
5.26
10/14/22
2.51
2.51
2.5 ng/L
- Annual Average for 2022
1/13/23
1.34
1.34
4/14/23
0.825
0.825
1.1 ng/L
- Annual Average for 2023

Winston-Salem /Forsyth County
UWattilities
er •Wastewater •Solid Waste
Wastewater Division, 2799 Griffith Road, Winston-Salem, NC 27103
O: 336-727-8000, F: 336-659-4320, wskutilities.org
August 8, 2023
Gary Perlmutter, MSc.
NCDEQ/Division of Water Resources
NPDES Municipal Permitting Unit
512 N Salisbury St.
Raleigh, NC 27604
Permit Renewal Reduced Monitoring Request —Archie Elledge WWTP NCO037834
Dear Mr. Perlmutter,
The City of Winston Salem would like to request reduced monitoring for the Archie Elledge WWTP
NCO037834 for the following parameters: cBOD, TSS, Ammonia, and fecal coliform. The following table
shows the 3 year mean for each.
Archie Elledge GEOMEAN
BOD
TSS
NH3
Fecal
Monthly Limit
Monthly Limit
Monthly Limit
Monthly Limit
21 m
30 m
1.2 m
200/100mL
8
7.4
0.5
16.9
The Archie Elledge facility has fulfilled all the approval criteria listed in the DWQ Guidance Regarding the
Reduction of Monitoring Frequencies in the NPDES Permits for Exceptionally Performing Facilities
October 22, 2012 document.
Sincerely,
Ozie Keith Jones
Assistant Utilities Plant Superintendent
City Coaneil: Mayor Allenloines; Denise D. Adams, Mayor Pro Tempore, North Ward; Barbara Hanes Burke, Northeast Ward; Robert C. Clark, West Ward;
John C. Larson, South Ward; Jeff Macintosh, Northwest Ward; Kevin Mundy, southwest Ward; Annette Rippio, East Ward; James Taylor,Jn, Southeast Ward;
City Manager: Lee D. Garrity
County Commissioners: Don Martin, Chair, Glade D. Whisenhunt, Vice Chair; Dan Besse; Richard V. Llnvllle;Tonya D. McDaniel; David R. PMer, Malishal
Call 311 or 336-727-8000 Woodbury; Ccunry Manager: Dudley Watts, Jr.
[e-mail] WNstomSalem/Forsyth County Utility Commission: L. Wesley Curtis, Jr., Chair, Chds Parker, Vice Chair; Simpson 0.Brown, Jr., Harold Eustache; Tom Grim.;
Yvonne H. Hines; Hugh W. Jernigan; Duane tong; Calvin McRae; Charles Wilson; Allan Younger

Reduction in Frequency Evalaution
Facility:
Archie Elledge WWTP
Permit No.
NC0037834
Review period
07/2020 - 06/2023
(use 3 yrs)
Approval Criteria: Y/N?
1. Not currently under SOC
Y
2. Not on EPA Quarterly noncompliance report
Y
3. Facility or employees convicted of CWA
violations
N
# of non -
Monthly
3-yr mean
# daily
# daily
Reduce
Weekly average
50%
200%
200%
monthly
# civil penalty
Data Review
Units
average
(geo mean
< 50%?
samples
<15?
samples
< 20?
> 2?
> 1?
Frequency?
limit
limit
MA
for FC)
MA
>200%
WA
>200%
limit
asessment
(Yes/No)
violations
BOD (Weighted)
mg/L
37.13
24.75
12
8.41
Y
49.50
0
Y
0
N
0
N
Y
TSS
mg/L
45.00
30.00
15
6.77
Y
60.00
0
Y
0
N
0
N
Y
Ammonia (weighted)
mg/L
5.10
1.70
0.9
0.33
Y
3.40
4
Y
0
N
0
N
Y
Fecal Coliform
#/100
400.00
200.00
1001
6.07
Y
800 1 Y
0
N
0
N
Y

RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Bickerstaff, Barry F. <[e-mail]>
Wed 11/8/2023 10:49 AM
To:Graznak, Jenny <[e-mail]>
Cc:Perlmutter, Gary <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Jenny,
Thanks for the follow up and I apologize for my slow response. I am still working a very limited schedule, and often
get behind in emails.
Yes I did see your email responses below, and find that the responses provide sufficient answers to all our
questions. We have also received responses from NC Dam Safety to our requests for clarifications presented to
them.
Given that we have received clarification responses from the appropriate regulatory agencies, the City has elected
to move forward with the lagoon rehabilitation project.
As noted in my separate email regarding the lagoons to remain in service, it is likely that at least two lagoons will
remain (Nos. 1 and 2) and one lagoon (No. 3) will be closed. Please note this decision is not yet final, however that
is the current thinking.
Thanks again for all your help! Hazen will keep you updated as we move forward with lagoon rehabilitation design.
Barry
From: Graznak, Jenny <[e-mail]>
Sent: Tuesday, November 7, 2023 12:19 PM
To: Bickerstaff, Barry F. <[e-mail]>
Cc: Perlmutter, Gary <[e-mail]>
Subject: FW: [External] Elledge WWTP - Updated Groundwater Quality Information
Hey Barry,
Just following up on this to make sure you saw it! Thanks.
Jenny Graznak
Assistant Regional Supervisor, Division of Water Resources
North Carolina Department of Environmental Quality
Winston-Salem Regional Office
Office: [phone] / Cell: [phone]
jenny
[e-mail]
NOR
ixpnuneRe m uwKonmenial Oual.ty
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.

From: Graznak, Jenny
Sent: Tuesday, October 31, 2023 10:48 AM
To: Bickerstaff, Barry F.<[e-mail]>
Cc: Perlmutter, Gary <garyperlmutterCcDdeq.nc.gov>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Barry,
I have been in discussions with Gary Perlmutter (copied on this email), who is the DWR Central Office permit
writer working on the reissuance of the NPDES permit for Archie Elledge WWTP. He has helped me verify some of
the answers here — please note that I answered your questions in red below. For the permit renewal, Gary will
need a map with all lagoons labeled and which one(s) the City intends to close, maintain as inactive and/or use.
This will help with the permit writeup. Additionally, the reissuance of the NPDES permit may require groundwater
monitoring based on 15A NCAC 02T .0108.
I hope this helps. Please let me know what else you may need to proceed with the City, thank you!
Jenny Graznak
Assistant Regional Supervisor, Division of Water Resources
North Carolina Department of Environmental Quality
Winston-Salem Regional Office
Office: [phone] / Cell: [phone]
jenny
[e-mail]
-a kplme .Oual�ty
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bickerstaff, Barry F.<[e-mail]>
Sent: Tuesday, October 24, 2023 2:28 PM
To: Graznak, Jenny <jenny,[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Jenny,
Thanks for the response below. You certainly addressed several questions, however I do have a few more:
If you recall, Lagoon # 2 has a leak in the embankment. The leak allowed wastewater to migrate to a
nearby stream. As indicated in the attached Bypass Report, the City removed Lagoon # 2 from service until
the embankment could be repaired. So, even though the 02L regulations do not require rehabilitation of
the lagoon, we understand that the plant's NPDES permit will require the lagoon embankment to be
repaired before the lagoon is retuned to service. Please confirm our understanding is correct. This is
correct. Sludge Lagoon #2 is incorporated into the component list of NPDES permit NCO037834 as "Waste
Sludge Lagoons" and shall be properly maintained if continuation of use is the intent of the City.
Also, we have the understanding that repairing the embankment of Lagoon # 2 will require that we
upgrade the lagoon to the current 02L and 02T regulatory standards. Please confirm our understanding is
correct. NCAC 2T .0505 - Design Criteria requires lining of lagoons in paragraph f, but applies to new and
expanding facilities in paragraph a. Therefore, if it's just a repair, they are "grandfathered" into their
current design. However, rehabbing the lagoon to current design standards is always a recommended
practice but not technically required in this instance since it is not new or expanding.

• Should the City decide not to repair Lagoon # 2, we understand that the lagoon cannot be abandoned.
Instead, the lagoon will need to be closed per a closure plan approved by NCDEQ / DWR. Please confirm
our understanding is correct. This is correct. See attached Lagoon conditions that would potentially be
added to the next issuance of the Archie Elledge NPDES permit. Guidelines for closure are also attached.
Similar to the above item, we understand that Lagoons 1 and 3 cannot be abandoned. Instead, the lagoons
must remain in service or be closed per a closure plan approved by NCDEQ / DWR. Please confirm our
understanding is correct. This is correct. Same as above.
Finally, we understand that your responses below are related to groundwater regulations and are not intended to
address NC Dam Safety regulations. Therefore, we are currently reaching out to NC Dam Safety to inquire about
lagoon rehabilitation that may be required to comply with their regulations.
Please let us know if our understanding as stated above is correct.
Thanks for all your help,
Barry
From: Graznak, Jenny <[e-mail]>
Sent: Tuesday, October 24, 2023 1:24 PM
To: Bickerstaff, Barry F.<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Barry,
As we discussed last week, I told you that I would confirm the information we provided to you during last week's
meeting with DWR Groundwater management staff and get back to you. Please accept this email as a follow up to
that meeting from 10/18/2023.
Based on data provided to us in early 2022, DWR asked the City to collect surface water data and install
compliance wells to determine if there was surface water or groundwater contamination outside the compliance
boundary for the facility. Based on results from that sampling, DWR is satisfied that there is no groundwater
contamination above the 2L Standards at or beyond the compliance boundary. Furthermore, since there are no
exceedances of 2L at the compliance boundary, there is no need for a Corrective Action Plan. If there were 2L
exceedances at the compliance boundary, then a formal Comprehensive Site Assessment would be required per
02L .0106(e)(4).
Also, none of our rules require the City to do the rehabilitations that they are proposing. However, if groundwater
contamination is detected at the compliance boundary in the future, then yes, 02L requires that the source be
removed or controlled, which could mean they would have to do some sort of institutional controls. It just
depends on how proactive they want to be. Of course, it is always in the best interest of the environment to do
the sorts of things they are proposing.
Along that same line, DWR does suggest that the City keep and maintain those monitoring wells for now.
Groundwater monitoring may be added to the NPDES permit the next time the permit comes up for renewal.
Perhaps semi-annual monitoring to keep tabs on any potential contaminant migration.
I hope this has answered some of your questions. Let me know if I can do anything to assist.
Thank you,
Jenny Graznak
Assistant Regional Supervisor, Division of Water Resources

North Carolina Department of Environmental Quality
Winston-Salem Regional Office
Office: [phone] / Cell: [phone]
jenny,[e-mail]
e::�,D—EQ>
oep.ronearm urvvomm�nfai ouau�
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bickerstaff, Barry F.<[e-mail]>
Sent: Friday, September 29, 2023 2:30 PM
To: Wang, Shuying <shuying.wang..@ eq.nc.gov>; [e-mail]; Bill Brewer <[e-mail]>;
Jordan Toney <[e-mail]>; Keith Jones <[e-mail]>; Matthew Lavigne
<mathewl @cityofws.org>
Cc: Knight, Everette <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<jenny,[e-mail]>; Babson, Aaron D <[e-mail]>; Borgmann, Ruth
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Shuying,
Please see the attachment for August 2023 sampling results from wells MW-8 and MW-9. Please note that the
attachment also includes field notes and lab reports.
As indicated by the results, the groundwater quality in the region surrounding the wells is generally compliant
with NCAC 02L Standards.
Given the results of samples collected on 2023, Hazen and S&ME consider that an appropriate level of assessment
has been performed. Therefore, we would like to arrange a meeting with NCDEQ, the City of Winston-Salem,
S&ME, and Hazen to discuss finalizing the Site Assessment Report.
Please let us know if you have any questions or comments regarding the August 2023 sampling results.
Also, let us know when you are available to meet.
Thanks,
Barry
From: Wang, Shuying <[e-mail]>
Sent: Monday, June 19, 2023 9:35 AM
To: Bickerstaff, Barry F.<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Thank you Barry!
From: Bickerstaff, Barry F.<bbickerstaff�hazenandsawyer.com>
Sent: Monday, June 19, 2023 9:10 AM

To: Wang, Shuying <[e-mail]>; Edmund Q B Henriques <EHenriques smeinc.com>; Bill Brewer
<[e-mail]>; Jordan Toney <jordant cityofws.org>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <[e-mail]>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Shuying,
Please see attached.
Let me know if you have any questions or need anything else.
Barry
From: Wang, Shuying <[e-mail]>
Sent: Monday, June 19, 2023 8:27 AM
To: Bickerstaff, Barry F.<[e-mail]>; Edmund Q B Henriques
<[e-mail]>; Bill Brewer <billb cityofws.org>; Jordan Toney <[e-mail]>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <jenny [e-mail]>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
You don't often get email from [e-mail]. Learn why this is important
Barry,
Great, thank you for the quick response!
If you don't mind, please just pass me a copy of the lab reports and field notes. Thank you!
Shuying
Shuying Wang
Hydrogeologisst, Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone] Mobile: [phone]
[e-mail]
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th.
Employee email addresses may look different, but email performance will not be impacted.
E Q:>
rvoH i r i -CAHriLlNA
Wp�rhtY� bf E�Yrirrinmental Quality
Email correspondence to and from this address is subject to the Nort
Carolina Public Records Law and may be disclosed to third Darties,

From: Bickerstaff, Barry F. <[e-mail]>
Sent: Saturday, June 17, 2023 8:48 AM
To: Wang, Shuying <[e-mail]>; Edmund Q B Henriques <EHenriques smeinc.com>; Bill Brewer
<[e-mail]>; Jordan Toney <jordant cityofws.org>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <jenny_.graznak deq.nc.gov>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
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Shuying,
Please see the attachment for the May 2023 sampling results from wells MW-8 and MW-9. As indicated by the
results, the wells appear to be in compliance.
Please let me know if you need anything else.
Barry
From: Wang, Shuying <[e-mail]>
Sent: Friday, June 16, 2023 3:24 PM
To: Bickerstaff, Barry F. <[e-mail]>; Edmund Q B Henriques
<EHen [e-mail]>; Bill Brewer <billb cityofws.org>; Jordan Toney <[e-mail]>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <jenny [e-mail]>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Some people who received this message don't often get email from [e-mail]. Learn why this is
important
Hi Barry,
As the last sampling of MW-8 and WM-9 was done on February 15th of this year and two additional quarterly
sampling events were recommended, I just wonder weather these two wells were sampled again in May, and
when we can expect to see the sampling result if they have been already sampled. Otherwise, you may want to
schedule the sampling event as soon as possible.
Thank you!
Shuying
Shuying Wang
Hydrogeologisst, Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone] Mobile: [phone]
[e-mail]
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th.
Employee email addresses may look different, but email performance will not be impacted.

I D E
Deparlmord of Environmental Quality
E mad correspondence to and from this address is subject to the Nort
Carolina Public Records Law and may be disclosed to tgird,carties.
From: Wang, Shuying
Sent: Friday, April 28, 2023 11:16 AM
To: Bickerstaff, Barry F.<[e-mail]>; Edmund Q B Henriques
<[e-mail]>; Bill Brewer <[e-mail]>; Jordan Toney <[e-mail]>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <jenny,[e-mail]>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Hi Barry,
Yes, as I mentioned, unless or until this office later finds any information contrary to the data received, which may pose an
unacceptable risk or a potentially unacceptable risk to human health or the environment.
Shuying
Shuying Wang
Hydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
N_ - C-
� Nothing Compares ,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Bickerstaff, Barry F. <[e-mail]>
Sent: Friday, April 28, 2023 10:56 AM
To: Wang, Shuying <[e-mail]>; Edmund Q B Henriques <[e-mail]>; Bill Brewer
<[e-mail]>; Jordan Toney <jordant cityofws.org>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <jenny,graznak ncdenr.ggv>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
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Shuying,
Thanks for the response! We appreciate your help and your attention to this project.
I do have one request — please confirm the only sampling required for the next two quarters is MW-8 and MW-9.
Thanks,
Barry
From: Wang, Shuying <shuying.wang ncdenngov>
Sent: Friday, April 28, 2023 10:19 AM
To: Bickerstaff, Barry F. <[e-mail]>; Edmund Q B Henriques
<[e-mail]>; Bill Brewer <billb cityofws.org>; Jordan Toney <[e-mail]>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <[e-mail]>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Hi Barry,
Sorry for not sending this message out to you yesterday as promised.
Here are our comments:
The written summary of the additional sampling conducted and associated findings indicates:
Fecal coliform concentrations for surface water monitoring locations SW-3 and SW -PIPE are lower than the
surface water standard set in 15A NCAC 02B and similar to the background concentration detected at SW-4,
which suggests that the highly elevated concentration previously detected in at SW-3 was more likely
contributed from animals rather than the lagoon.
No fecal coliform was detected at MW-8 and MW-9, during the February 15, 2023, sampling event or no exceedances
of the 15A NCAC 02L groundwater standards (2L Standard) were detected in these two wells.
Based on the findings above and the data/information provided previously, no additional assessments will be needed
for Salem Creek and its tributaries near/around the lagoons unless this office later finds any information contrary to
the data received, which may pose an unacceptable risk or a potentially unacceptable risk to human health or the
environment. However, for the groundwater, it looks necessary additionally to sample MW-8 and MW-9 for at least
another two consecutive quarters because these two wells are beyond the review boundary and ever detected 2L
exceedance although to install additional wells beyond these two well locations does not appear to be necessary.
Generally, it is considered necessary to obtain analytical results of groundwater samples collected over four
consecutive quarters, documenting no contamination above the 2L Standards.

If you disagree with us or if you have other things that we need to set a meeting to discuss, We will be happy to meet
you. Please give us a couple of choices regarding the meeting time and date if you determine that a meeting is
necessary. Otherwise, please continue sampling MW-8 and MW-9 quarterly for another two quarters and then finalize
the assessment report.
If you have any questions regarding this email, please feel free to contact me anytime.
Thank you!
Shuying Wang
Hydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
+; NoWng Compares. --,,—
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bickerstaff, Barry F.<[e-mail]>
Sent: Tuesday, April 25, 2023 9:43 AM
To: Edmund Q B Henriques <[e-mail]>; Wang, Shuying <[e-mail]>; Bill Brewer
<[e-mail]>; Jordan Toney <jordant cityofws.org>
Cc: Knight, Everette <[e-mail]>; Cody Austin McMechen <[e-mail]>;
Snider, Lon <[e-mail]>; Graznak, Jenny <jenny,[e-mail]>; Babson, Aaron D
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Shuying,
Attached is the written summary Ed mentions in the email below. The summary contains information on
additional surface water and ground water sampling performed on 2/15/23.
As indicated in the summary, the sampling shows fecal coliform concentrations for surface water monitoring
locations SW-3 and SW-4 to be lower than the surface water standard contained within 15A NCAC 02B. Note that
another sampling location labeled SW -PIPE was established, and this sample also demonstrated fecal coliform
counts that were lower than the regulatory standard.

In addition to the surface water locations noted above, monitoring wells MW-8 and MW-9 were also sampled.
The samples indicate that fecal coliform was non -detect at both of the monitoring wells.
The summary concludes with a recommendation for a meeting to establish an agreement that an appropriate
level of assessment has been completed, and the assessment report can now be finalized.
Please review the summary and let us know if you have any questions or comments.
Also, please let us know if you are agreeable to a meeting. If so, we will establish a date and time.
Thanks,
Barry
From: Edmund Q B Henriques <EHenriques smeinc.com>
Sent: Thursday, April 13, 2023 4:38 PM
To: Wang, Shuying <[e-mail]>
Cc: Bickerstaff, Barry F. <[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<jennygraznak ncdenr.gov>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Caution! External email — think before you click
Good afternoon Shuying. I did receive your email and needed to prepare a written summary of the additional
sampling conducted and associated findings. The summary was emailed to Barry and Everette this morning. After
their review I can email to you the summary, or they may elect to forward it directly.
Assessments of this scale and complexity, often take more time than expected. Substantial progress has been
made to date, and the City has been very proactive.
We appreciate your patience and assistance with this matter.
Kind Regards, Ed
Edmund Q.B. Henriques, L.G.
Principal Geologist
S&ME
8646 West Market Street, Suite 105, Greensboro, NC 27409
M: 336.312.3330 // 0: 336.288.7180
www.smeinc.com
From: Wang, Shuying <[e-mail]>
Sent: Thursday, April 13, 2023 4:17 PM
To: Edmund Q B Henriques <[e-mail]>
Cc: Bickerstaff, Barry F. <[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information

This message originated outside of S&ME. Please report this as phishing if it implies it is from an S&ME employee.
Hi Ed,
Did you got my message below I sent you two weeks ago?
Shuying
From: Wang, Shuying
Sent: Friday, March 31, 2023 11:37 AM
To: Edmund Q B Henriques <[e-mail]>
Cc: Bickerstaff, Barry F. <[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
Hi Ed,
It has been more than a month since your last email. Just wondering if any progress has been made.
Thanks!
Shuying Wang
Hyd rogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: Shuying.Wang,@ncdenr.gov
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
A - 0`_ -
­5 Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Wang, Shuying <shuying.wang@ncdenngov>
Sent: Tuesday, February 14, 2023 11:45 AM
To: Edmund Q B Henriques <[e-mail]>
Cc: Bickerstaff, Barry F. <[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<jenny [e-mail]>; Wang, Shuying <shuying.wang,@ncdenr.gov>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information

Hi Ed,
Sounds good to me. Please keep us informed if the process takes longer than a month.
Thank you!
Shuying Wang
Hydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Edmund Q B Henriques <EHenriques smeinc.com>
Sent: Tuesday, February 14, 2023 11:12 AM
To: Wang, Shuying <[e-mail]>
Cc: Bickerstaff, Barry F.<[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>; Snider, Lon <Ion.snider@ cdenr.gov>; Graznak, Jenny
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Good morning Shuying. The other day our client, Hazen and Sawyer received permission from the City of
Winston-Salem for S&ME to proceed with additional assessment activities, which include:
1. Resample monitoring wells MW-8 and MW-9.
2. An evaluation of potential animal contributions (vs Lagoon) for the fecal coliform previously detected at
surface water sample location SW-3 (2972 cfu/100 ml). There is visible evidence of an animal trail near
sample location SW-3. A large portion of this stream segment is piped underground between background
sample SW-4 and down -gradient sample SW-3. This makes it difficult to rationalize the higher fecal levels
reported at SW-3. To evaluate our theory, we plan to collect a sample at SW-4, collect a sample at the point
the water exits the piped segment, and a sample at SW-3.
While on -site for the above sampling activities, we will collect a comprehensive round of depth to
groundwater data for all the monitoring wells, including new well MW-11. Based on a groundwater
elevation at MW-11 calculated for November 30, 2022, and comparing it with the September 20, 2022,
elevation data for MW-1 and MW-2 on the opposite side of Salem Creek, the groundwater elevation was
higher at MW-11. The additional water level data to be collected will aid in verifying this finding.

I am working to get this additional field effort scheduled.
Call me on my cell (336-312-3330) if you have any questions. Thanks Ed
Edmund Q.B. Henriques, L.G.
Principal Geologist
S&ME
8646 West Market Street, Suite 105, Greensboro, NC 27409
M: 336.312.3330 // 0: 336.288.7180
www.smeinc.com
From: Wang, Shuying <shuying.wang@ncdenrgov>
Sent: Thursday, February 2, 2023 11:04 AM
To: Edmund Q B Henriques <[e-mail]>
Cc: Bickerstaff, Barry F. <[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
This message originated outside of S&ME. Please report this as phishing if it implies it is from an S&ME employee.
Hi Ed,
Just want to check (1) whether you have resampled MW-8 and MW-9 to see whether the concentrations has been
below 2L and (2) whether you have rechecked the SW-5 area to see whether it could be impacted by groundwater
discharge from lagoon 1 as we discussed during December 21, 2022 phone call. In addition, as we discussed, the
arithmetic means reported on table 4 you emailed me on December 21, 2022 need to be recalculated to
geometric means. Could you please give me an update about the issues? Furthermore, I would like to know
whether to submit a complete assessment report is still your plan? If yes, when we can expect to see the report?
Thank you in advance!
Shuying Wang
Hydrogeologisst, Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone] Mobile: [phone]
[e-mail]
vc-��D E
Department of Environmental Quality
Email correspondence to and from this address is subject to the Nort
Carolina Public Records Law and may be disclosed to third parties.

From: Edmund Q B Henriques <EHenriques smeinc.com>
Sent: Wednesday, December 21, 2022 11:27 AM
To: Wang, Shuying <[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Great. I have several meetings today, can I call you around 3 PM?
Thanks Ed
Edmund Q.B. Henriques, L.G.
Principal Geologist
S&ME
8646 West Market Street, Suite 105, Greensboro, NC 27409
M: 336.312.3330 H 0: 336.288.7180
www.smeinc.com
From: Wang, Shuying <[e-mail]>
Sent: Wednesday, December 21, 2022 11:26 AM
To: Edmund Q B Henriques <EHenriques smeinc.com>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
This message originated outside of S&ME. Please report this as phishing if it implies it is from an S&ME employee.
Yes, anytime. I am teleworking today, so you may call my cell:336-403-5429. I did not see table 4 until this email.
Give me a few minutes if you want to discuss it. Thank you! Shuying
From: Edmund Q B Henriques <[e-mail]>
Sent: Wednesday, December 21, 2022 11:18 AM
To: Wang, Shuying <shuying.wang.@ncdenrgov>
Subject: FW: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Good morning Shuying. Do you have a few minutes today to discuss Elledge WWPT? Also, I wanted to be sure
you had the attached Table 4 with sample locations shown on Figure 5.
Thanks Ed
Edmund Q.B. Henriques, L.G.
Principal Geologist
S&ME
8646 West Market Street, Suite 105, Greensboro, NC 27409
M: 336.312.3330 H 0: 336.288.7180

www.smeinc.com
From: Wang, Shuying <shuying.wang@ncdenrgov>
Sent: Tuesday, December 20, 2022 3:05 PM
To: Edmund Q B Henriques <[e-mail]>
Cc: Bickerstaff, Barry F.<[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<[e-mail]>
Subject: RE: [External] Elledge WWTP - Updated Groundwater Quality Information
This message originated outside of S&ME. Please report this as phishing if it implies it is from an S&ME employee.
Hi Ed,
I just reviewed the sampling result from the additional well, MW-11 installed at the review boundary across Salem
Creek, which indicates that no 2L groundwater quality exceedances were detected from MW-11. Now, we look
forward to seeing an interpretive final site assessment report which integrates all assessment data collected
around the lagoons at the facility and evaluates whether any further assessment is needed.
Please note that MW-8 and MW-9 may need to be resampled. As we discussed previously, MW-8 and MW-9
beyond the review boundary detected elevated level of fecal coliform. September 2022 Resampling results were
significantly lower, but still above the 2L. Therefore, it will be better to resample the wells again to see if the
concentrations are below 2L now. Otherwise, please provide lines of evidence to show that the elevated level of
fecal coliform is from the surface water recharge rather than the wastewater lagoon.
In addition, as discussed in my previous email, to determine whether the elevated levels of fecal coliform detected
in surface water samples are 2B violations, the surface water needs to be further sampled in accordance with 2B.
15A NCAC 02B .0211 FRESH SURFACE WATER QUALITY STANDARDS FOR CLASS C WATERS (7) indicates that fecal
coliform shall not exceed a geometric mean of 200/100ml (MF count) based upon at least five samples taken over
a 30-day period, nor exceed 400/100ml in more than 20 percent of the samples examined during such period. All
coliform concentrations shall be analyzed using the membrane filter technique. If high turbidity or other
conditions would cause the membrane filter technique to produce inaccurate data, the most probable number
(MPN) 5-tube multiple dilution method shall be used. Therefore, the surface water needs to be further assessed.
As of today, we have not seen such results. Please include the results, if the data have already been collected into
the final site assessment report; otherwise, please resample the surface water as outlined here before you finalize
the final report. We definitely need to see the results to determine whether there is any 2B violation.
If you have any questions or concerns, please email or call me anytime.
Shuying Wang
Hydrogeologisst, Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone] Mobile: [phone]
[e-mail]

m�E
W/P)
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subiect to the Nort
Carolina Public Records Law and may be disclosed to third parties.
From: Edmund Q B Henriques <[e-mail]>
Sent: Thursday, December 15, 2022 10:55 AM
To: Wang, Shuying <[e-mail]>
Cc: Bickerstaff, Barry F.<[e-mail]>; Knight, Everette <[e-mail]>;
Cody Austin McMechen <[e-mail]>
Subject: [External] Elledge WWTP - Updated Groundwater Quality Information
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Good morning Shuying, I hope all is well. Appended is Table 3 which presents groundwater quality data for the
Elledge WWTP groundwater assessment. Table 3 has been updated with analytical data for new monitoring well
MW-11 installed on the opposite side of Salem Creek (see appended Figure 4). Formal survey of the new well
location and top of casing elevation are pending. I have also attached the boring log for MW-11 along with the
corresponding Well Construction Record.
I am pleased to report that there were no 2L groundwater quality exceedances at MW-11.
If you have any questions or comments, please let me know.
Kind Regards, Ed
Edmund Q.B. Henriques, L.G.
Principal Geologist
SWE
8646 West Market Street, Suite 105, Greensboro, NC 27409
M: 336.312.3330 // 0: 336.288.7180
www.smeinc.com
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an
authorized state official.

RE: [External] Archie Elledge Permit
Keith Jones <[e-mail]>
Mon 12/11/2023 3:01 PM
To:Perlmutter, Gary <[e-mail]>
Cc:Matthew Lavigne < [e-mail] >;Bonnie McKee <[e-mail]>;Montebello, Michael J
<[e-mail]>;Graznak, Jenny <[e-mail]>;Kristopher Petree
< [e-mail] >
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Gary,
The City plans to renovate Lagoon #1 and probably Lagoon # 2 (for redundancy). For Lagoon # 3, the City intends
to close this lagoon, utilizing guidance provided by NCDEQ. While this is the current plan, the project is just now
entering the design phase. So, implementation of the plan (i.e., completion of construction) is approximately
three years away. The goal of the lagoon project is to comply with the latest 15A NCAC 2T and NC Dam Safety
regulations. I would also like you to know we have been conducting groundwater sampling under the guidance of
DEQ Groundwater folks.
Thanks
Keith Jones
Superintendent of Wastewater
Winston-Salem/Forsyth County Utilities
Manson Meads Complex
2799 Griffith Road
Winston-Salem, N.C. 27103
0: 336-397-7625, M: 336-345-7277
Keith)@cityofws.org
From: Perlmutter, Gary <[e-mail]>
Sent: Friday, December 8, 2023 10:42 AM
To: Kristopher Petree <[e-mail]>
Cc: Keith Jones <[e-mail]>; Matthew Lavigne <[e-mail]>; Bonnie McKee
<[e-mail]>; Montebello, Michael J <[e-mail]>; Graznak, Jenny
<[e-mail]>
Subject: Re: [External] Archie Elledge Permit
Hi Heath,

CAUTION:*'F*EXTERNAL SENDER *** STOP. EVALUATE. VERIFY. Were you expecting this
email? Does the content make sense? Can you verify the sender? If the email is suspicious: Do
not click links or open attachments. Click the Report Message button in Outlook to notify
Information Systems.
Thank you for reaching out and your inquiry. The Archie Elledge WWTP permit renewal is awaiting a
decision from the City regarding use of its three lagoons, one of which is damaged as I am aware. I
intend to add conditions to the permit for their maintenance and/or closure. Can you give me a status
regarding this decision?
Thanks,
Gary
From: Kristopher Petree <[e-mail]>
Sent: Friday, December 8, 2023 10:29 AM
To: Perlmutter, Gary <[e-mail]>
Cc: Keith Jones <[e-mail]>; Matthew Lavigne <[e-mail]>; Bonnie McKee
<BON N I E M @cityofws.org>
Subject: [External] Archie Elledge Permit
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Greetings Gary,
My name is Heath Petree. I am the new Supervisor/ORC here at the Archie Elledge WWTP. I wanted to take this
time to introduce myself, and check on the status of the permit. If you have any specific questions please reach
back out to me, and I will be glad to help the best I can.
K. Heath Petree
Senior Utilities Plant Supervisor
Winston-Salem/Forsyth County Utilities
Archie Elledge WWTP
2801 Griffith Rd
Winston-Salem, NC 27103
O: 336-397-7600
kristopherp�@_cityofws.org
City of Winston-Salem
ONE TEAM
Committed to Excellence
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Carolina Public Records Law.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an
authorized state official.

RE: Archie Elledge draft permit (NC0037834)
Talbott, Jeffrey <[e-mail]>
Mon 2/19/2024 9:52 AM
To:Perlmutter, Gary <[e-mail]>
Hello Gary -
Operator certification notes that this facility is classified as a WW-IV, with the ORC and all Backup ORC's active and
in good standing with the program.
We have no comments at this time.
Thank you.
Jeff Talbott
Supervisor, NC Operator Certification Program
Division of Water Resources
Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
---------------------------------------------------------------------------------
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Perlmutter, Gary <[e-mail]>
Sent: Monday, January 29, 2024 2:02 PM
To: Kristopher Petree <[e-mail]>; Bonnie McKee <[e-mail]>; Keith Jones
<[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny <[e-mail]>;
Talbott, Jeffrey <[e-mail]>; Vander Borgh, Mark <[e-mail]>; Mcgee,
Keyes <[e-mail]>; Hudson, Eric <[e-mail]>
Subject: Archie Elledge draft permit (NC0037834)
Dear everyone,
Attached is the draft permit and fact sheet that has was sent to Public Notice on January 25. Feel free to
contact me if you have any questions.
Thank you,
Gary Perlmutter
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an
authorized state official.

FW: Archie Elledge draft permit (NC0037834)
Kirby, Ben <[e-mail]>
Tue 2/6/2024 2:08 PM
To:Perlmutter, Gary <[e-mail]>
Cc:Fox, Shawn <[e-mail]>
2 attachments (2 MB)
37834 Draft Permit pkg 2024_signed.pdf; 37834 Draft Fact Sheet_2024.pdf;
Good afternoon,
The Public Water Supply Section concurs with the issuance of this permit provided the facility is
operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge
does not contravene the designated water quality standards.
Thanks,
Ben Kirby (he/him/his)
Assistant Regional Engineer, Winston-Salem Regional Office
Division of Water Resources, Public Water Supply Section
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105
[e-mail]
e:,�e
NORTH CAROUNAD_E Q
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Perlmutter, Gary <garyperlmutter(@deq.nc.gov>
Sent: Monday, January 29, 2024 2:02 PM
To: Kristopher Petree <kristopherp cityofws.org>; Bonnie McKee <BONNIEM(@cityofws.org>; Keith Jones
<keithj cityofws.org>; Snider, Lon <lon.snider(@deq.nc.gov>; Graznak, Jenny <jenny graznakPcleq.nc.gov>;
Talbott, Jeffrey <jeffrey.talbottPdeq.nc.gov>; Vander Borgh, Mark<mark.vanderborgh(aDdeq.nc.ggv>; Mcgee,
Keyes <keyes.mcgee deq.nc.gov>; Hudson, Eric <eric.hudson(@deq.nc.gov>
Subject: Archie Elledge draft permit (NC0037834)
Dear everyone,
Attached is the draft permit and fact sheet that has was sent to Public Notice on January 25. Feel free to
contact me if you have any questions.
Thank you,
Gary Perlmutter

Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an
authorized state official.