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HomeMy WebLinkAboutNC0026123_Fact Sheet_20230821 (3)g/2izoz3 Review Fact Sheet NPDES Permit No. NCOO26123 Permit Writer/Email Contact: Nick Coco, nick.cocoLdeq.nc.gov Date Initiated: August 29, 2022; initial draft submitted for public comment 5/9/2018 (see Section 14. Fact Sheet Addendum for more information) Division/Branch: NC Division of Water Resources/NPDES Municipal Permitting Unit Fact Sheet Template: Version 09Jan2017 Permitting Action: M Renewal ❑ Renewal with Expansion ❑ New Discharge ❑ Modification (Fact Sheet should be tailored to mod request) Note: A complete application should include the following: • For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee • For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET tests. • For Existing Dischargers (Non-POTW), EPA Fonn 2C with correct analytical requirements based on industry category. Complete applicable sections below. If not applicable, enter NA. 1. Basic Facility Infonnation Facility Information Applicant/FacilityName: City ol'Asheboro/Asheboro WWTP Applicant Address: P.O. Box 1106, 146 N Church Street, Asheboro, NC 27204 Facility Address: 1032 Bonkemeyer Drive, Asheboro, NC 27203 Permitted Flow: 9.0 MGD Facility Type/Waste: MAJOR Municipal; 92. 1 % domestic, 7.9% industrial Facility Class: Grade IV Treatment Units: Bar screen, Grit removal, Parshall flume, Primary clarifiers, Trickling filters, Secondary clarifiers, Nitrification with aeration, Final clarifiers. Tertiary sand filters, Chlorination, De -chlorination. Cascade aeration, Sludge thickening, Digesters, Dewatering. Pretreatment Program (Y/N) Yes County: Randolph Region Winston-Salem Footnote, 1. Permitted industrial flow is 0.712 MGD. Page 1 of 24 Briefly describe the proposed perntitting action and facility background: I he City of Asheboro has applied for NPDES permit renewal, received by DWR on 3/21/2016. A draft permit was public noticed in May 2018; comments were received, and the permit was modified for a second public notice (see Sec[ 13 and 14 below). This facility serves a population of—25,676 residents and operates a pretreatment program with 15 Significant Industrial Users (S1Us), 7 of which are Categorical Industrial Users (CIUs). In addition, the Asheboro W W-rP is receiving 1,400 gpd wastewater from the Randolph County School Bus Maintenance Garage groundwater remediation project. However, this is not considered a SIU. CIUs include: Energizer Manufacturing. Inc. Plant 2 (CiU 461: battery manufacturing), Garco, Inc. (renamed Covanta Environmental Services, CIU 437: centralized waste management), Matlab, inc. Plant 4 (CIU 433: metal finishing, not yet constructed), Matlab Plant 5 (CIU 433: metal finishing), Matlab Plant 8 (CIU 433: metal finishing), Premier Powder Coating (CIU 433: metal finishing), and Slarpet, Inc. (CIU 414: organic chemical, synthetic fibers and plastics). Non-caleeorical SiUs include: Acme McCrary (renamed MAS US Holdings, textiles), Bossong Hosiery (textiles), Energizer Manufacturing, inc. Plant i (battery pars manufacturing), Georgia Pacific (corrugated paper products), Kayser Ruth (textiles), MOM Brands (food processing), Randolph Packing (meat processing), Wells Hosiery (textiles), and Waste Management of the Carolinas Great Oak Landfill (landfill leachate). The average industrial flow rate was 0.386 MGD from January 2021 through January 2022. The uncontrollable flow was 3.56 MGD for that same period. The facility has a DWR-approved Full Pretreatment Program with a Long -Term Monitoring Program (LTMP) for its SiUs. Solids management is handled via land application, permitted under W00001684. 2. Receiving Waterbody Information Receiving Waterbody Information Outfalls/Receiving Stream(s): Outfall 001/Hasketts Creek Stream Segment: 17-12 Stream Classification: C Drainage Area (mi2): 11.6 Summer 7Q10 (cfs) 0 Winter 7Q10 (cfs): - 30Q2 (cfs): 0.2 Average Flow (cfs): 12 IWC (% effluent): 90 2022 303(d) listed/parameter: This stream segment is impaired for Copper and Benihos. The 2022 Integrated Report also notes data inconclusive for 1,4-Dioxane and Fecal C'oliforn Subject to TMDL/parameter: Statewide TMDI, for Mercury Subbasin/HUC: 03-06-09 103030003 USGS Topo Quad: D19SE Randleman, NC Page 2 of 24 The Haskett Creek Watershed Action Plan notes that water quality data collected at ambient monitoring stations above and below the Asheboro W WTP over the past ten years suggests that stormwater runoff and other nonpoint sources of pollution are contributing to water quality impacts above the Asheboro W WTP. The two parameters of utmost concert are fecal coliform (a form of bacteria) and turbidity (water clarity), although high turbidity is likely leading to greater biological impacts. High turbidity and sedimentation can kill algae, which are a major food source for benthic macroinvertebrates, and smother benthic organisms and fish eggs. Potential sources of fecal coliform include stormwater runoff, pet or animal waste, or leaking sewage or septic systems, while high turbidity is most likely caused by stormwater runoff, soil erosion, and a lack of riparian vegetation. While point source pollution is not a major concern for the watershed, it is likely that this facility is contributing to some of the water quality impacts downstream. Water quality data collected below the Asheboro WWII' typically shows higher levels of conductivity and copper than those collected above the plant. Biological assessment samples also indicated a noticeable decline of benthic macroinvertebrates below the W WTP (See Instream Data Summary for additional data analysis). 3. Effluent Data Summary Effluent data is summarized below for the period January 2018 through August 2022 for Outfall 001. Table 1. Effluent Data Surnmary Parameter Units Average Max Min Permit Limit' Flow' MGD 4.05 15.488 1.655 MA = 9.0 BOD summer mg/L 2.4 9.3 < 2.0 MA = 5.0 WA = 7.5 BOD winter mg/L 3.4 16.9 < 2.0 MA = 10.0 WA = 15.0 BOD Removal % 99.0 99.7 97.8 > 85 Total Suspended Solids MA = 30.0 mg/L 1 72.7 < 2.0 (TSS) WA = 45.0 TSS Removal % 98.4 99.7 96A > 85 Ammonia (NH3-N) MA = 2.0 mg/L 0.15 2.03 0.1 summer WA = 6.0 Ammonia (NH3-N) MA = 4.0 mg/L 0.4 9.12 < 0.10 winter WA = 12.0 Dissolved Oxygen (DO) mg/L 8.2 10.71 6 DA > 6.0 pH SU 7.0 7.63 6.0 Between 6.0 and 9.0 Fecal Coliform MA = 200 (geometric mean) #/100 mL 18 > 4939 < I WA = 400 Total Residual Chlorine (TRC) µg/L 15.6 48.7 < 15.0 DM = 17' Temperature °C 20.6 28.7 9.4 Monitor & report Conductivity µmhos/cm 957 1760 239 Monitor & report Page 3 of 24 Total Chromium pg/L 5.3 10.7 < 5.0 MA = 50 DM = 1033 Total Mercury ng/l, 1.7 4.6 < 1.0 MA = 12 DM = 36 Total Nitrogen (TN) mg/L 14.0 28.16 0.53 Monitor & report Total Kjeldahl mg/L 1.65 5.16 < I Monitor & report Nitrogen (TKN) Nitrate/Nitrite Nitrogen mg/L 12.6 25.00 0.53 Monitor & report (NO2 + NOa) Total Phosphorus (TP) mg/L 0.35 1.61 < 0.05 Monitor & report Dibromoehloromethane µg/L 8.4 17.2 < 5.0 Monitor & report Bromodichloromethane µg/L 17.5 36 < 5.0 Monitor & report Chloride mg/L 159 247 71.5 Monitor & report Total Copper µg/L 6.6 11.8 3.5 Monitor & report Total Zinc µg/L 23.2 100 < 10 Monitor & report 1,4-Dioxane 4 µg/L 116 1011 < I Monitor & report Footnotes. I. MA = monthly average, WA = weekly average, DA = daily average, DM = daily maximum. 2. Average flow for CY2020 = 4.218 MGD, 47% of permitted flow. 3. Concentrations < 50 lug/L are considered compliant. 4. Monthly monitoring required beginning December 2017 per Division letter sent in October 2017 with increased monitoring beginning December 2020. Data are inclusive from January 2018 - September 2022. 4. Instream Data Summary Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when model results for instream DO are within 1 mg/L of instream standard at full perntted 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 Pennittee, 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). lfapplicable, sununarize any instream data and what instream monitoring will be proposed for this permit action: The current permit requires instream monitoring for Temperature and Dissohed Oxygen (DO) from three locations: one upstream approximately 800 feet above the outfall in Haskcits Creek (U), one cownstream at NCSR 2128, located in Ilasketts Creek (DI ) and one additional downstream at NCSR 2261, located in the Deep River (132). Instream monitoring is provisionally waived so long as the Permiltee maintains membership in the Upper Cape Fear River Basin Association (UCFRBA). The permit instream monitoring locations correspond to the ambient monitoring stations B4870000 (U). B4890000 (DI), and B4920000 (132) (station locations displayed in Figure 1, shown belowl. Data from U and D2 were obtained from the Monitoring Coalition Coordinator and span from June 2017- June 2022; data from DI were provided by the Ambient Monitoring System (AMS) Coordinator for the same period. While sampling ai both UCFRBA stations were conducted Page 4 of 24 on corresponding dates, AMS station data was typically collected within the same week as the I1CI'RBA samples. The data has been summarized in Table 2 below. Table 2. lnstream data summary Parameter Units Upstream Downstream 1 Downstream 2 Average Fax Min Average Max Min Average Max Min Temperature ° C 16.5 29.4 1 19.3 28.7 8.7 18.4 30.4 2.8 DO mg/1 9.1 13.1 4.8 9.2 11.97 6.4 9.4 13.8 6.4 Conductivity µmhos/cm 115 219 60 594 1095 267 170 350 96 Fecal Colifonn p/IOOntI. (geomean) 465 12000 9 (geomean) 333 10000 35 (geomean) 176 11000 4 'Data from June 2017— June 2022 Students 1-tests were run at a 95% confidence interval to analyze relationships between instream samples. A statistically significant difference is determined when the 1-test p-value result is < 0.05 Dissolved Oxvi!en (DO): DO did not drop below the instantaneous stream standard of 4 mg/L [per 15A NCAC 02B .0211 (6)] during the period reviewed at either downstream location. The daily average downstream DO was greater than 5 mg/1- for the period reviewed at both locations. It was concluded that no statistically significant difference between upstream DO and DO at both downstream monitoring stations exists. Additionally, no statistically significant difference was observed between DO at both downstream sample locations. lnstream DO monitoring has been maintained. Teniperanve: The standard maximum of 32°C for lower piedmont and coastal plain waters as defined in 15A NCAC 02B .02011 (18) was maintained at all stations. lnstream temperatures were not collected synchronously among the three sites, therefore assessing for compliance with the 2.8°C increase from up - to downstream standard (15A NCAC 2B .0211) is not practical. It was concluded that no statistically significant difference between upstream temperature and temperature at both downstream monitoring stations exists. Additionally, no statistically significant difference was observed between temperatures at both downstream sample locations. Instream temperature monitoring has been maintained. Conductivin is a parameter of concern because of industrial discharges. The permit does not currently require instream monitoring, but the facility has an active pretreatment program with multiple SIUs, and instream data are available from the three stations. The data analyzed indicate that a statistically significant difference exists between upstream and downstream conductivity. Concurrent effluent conductivity was observed as consistently greater than that of the upstream. As effluent conductivity appears to increase conductivity in the stream, effluent conductivity monitoring has been added to the pennit. Fecal Colilurm: The permit does not currently require instream monitoring, but the 2022 Integrated Report notes fecal coliform as inconclusive with regard to determination of impairment, and instream data are available from the three stations. It \vas concluded that no statistically significant difference between upstream fecal coliform and fecal coliform at both downstream monitoring stations exists. Additionally, no statistically significant difference was observed between fecal coliform levels at both downstream sample locations. As such, instream fecal coliform monitoring has not been added. Total Copper: Hasketts Creek do" mueam of Asheboro is impaired for Total Copper (7 µg/L standard for aquatic life in freshwater) per the 2022 NC Integrated Report. lnstream copper monitoring is not required in the permit, but data are available from DI as monitored by the DWR Ambient Monitoring System (AMS). Review of data from January 2020 — September 2022 found the average total copper concentration Page 5 of 24 (4.3 pg/1.) to be below the calculated hardness -dependent chronic standard of 5.12 (tg/L and the maximum total copper concentration (6.0 pg/l.) to be below the acute standard of 7.25 µg/l.. Instream total copper monitoring has not been added to the permit at this time but will continue to be monitored at the AMS station. Nutrients The Deep River stream segment 17-(10.5)dl from Hasketts Creek to Gabriels Creek is impaired for Chlorophyll a (exceeding 40 mg/l. standard for aquatic life), but the immediate stream segment upstream in the Deep River [I 7-(10.5)c] is not impaired according to the 2022 NC Integrated Report. This pattern of impairment suggests that sources in Hasketts Creek are contributing to the impairment in the Deep River (Fig. 1). Due to this downstream impairment, additional instream analysis was conducted for Inorganic Nitrogen (NO2+NO3), Total Kjeldahl Nitrogen (TKN), Total Nitrogen (TN) and Total Phosphorous (TP) from data collected by the UCFRBA and AMS at the three instream locations. Figure 1, Map of Asheboro W WTP with instream sampling locations and impainnent designations. Instream and effluent nutrient data have been summarized below in Table 3. While no statistically significant difference was observed between upstream TKN concentrations and TKN concentrations at either downstream location, the same cannot be said for NO3+NQ, TN, or TP. Instream patterns of nutrient concentrations were largely consistent among parameters: nutrient concentrations are lowest upstream, increase substantially just downstream of the discharge and decrease further downstream but still appear consistently elevated at D2 compared to upstream. These patterns indicate effluent impact on the instream. Page 6 of 24 Table 3. Instream and effluent nutrient concentration averages and ranges (in parentheses) from June 2017 - June 2022. Values are in me/L. Parameter Upstream (U) Effluent Downstream (DI) Downstream (D2) Nitrate -Nitrite 024 12.6 7.5 0.87 (NO3+NO.) (0.02-1.63) (0.53-25.0) (0.53-19.0) (0.06-4 23) l'otal Kjeldahl Nitrogen 0.72 1.66 1.1 0.85 CfKN) (020-4.74) (<1-5.16) (0.7-2.2) (020-2.88) N) l otal Nitrogen (1 0.98 14 8.6 1.76 (0.022-6.37) (0.53-28.16) (1.42-20.3) (0.62-4.62) 0.10 0.25 0.05 0.05 Ammonia (0.02-3.51) (0.1-9.12) (0.02-0.33) (0.02-0.31) final Phosphorus(TP) 0.05 0.35 0.24 0.09 (0.02-0.4251 (� 0.05-1.610) (0.03-2.0) (0.038-0.179) Based on this information, which includes monitoring coalition data, instream monitoring for TN, TP, TKN, NO,+NO,. and ammonia has been added at a frequency of I/month. 1.4-Dioxane 1,4-Dioxane is an emerging contaminant of concem, identified as a likely human carcinogen. Elevated concentrations of 1,4-Dioxane were found in the Cape Fear River Basin during the EPA'rhird Unregulated Contaminant Monitoring Rule sampling program from 2013-2015. In response to this finding, the Division conducted an initial stream survey of the Cape Fear River Basin (NCL)WR 2016: 1,4-Dioxane in the Cape Fear River Basin of North Carolina: An Initial Screening and Source Identification Study), which found multiple sites with elevated concentrations. Among the highest concentrations detected were in Hasketts Creek downstream of the Asheboro W WTP discharge with an average of 291 pg/L (range: 147-478 pg/1.) from samples collected June 2015-May 2016. Subsequent sampling within Hasketts Creek and the Deep River by AMS found continued elevated concentrations downstream of Asheboro WWTP discharge and delectable concentrations in upstream locations of both walerbodies (Table 4). lnstream samples were collected at Hasketts Creek locations U and D1. and at Deep River locations up- and downstream of the confluence with Hasketts Creek. The Deep River upstream location is at AMS station B4800000, 2.62 miles upstream of the confluence. The Deep River downstream location is located at AMS station B5100000, 13.7 miles downstream of the confluence and below the discharges of two other W WTPs. Table 4. Instream and effluent 1,4-Dioxane concentrations in Iasketts Creek and the Deep River, 2019-2022. Location No. Samples Dates Sampled Average Minimum Maximum Hasketts Creek - upstream 9 .tun 2018 - Apr 2019 1.3 0.54 22 Hasketts Creek - downstream 27 Jan 2020 - Sep 2022 1022 900 1.9 Deep Rig-er -upstream 3 Jul -Aug 2018 2.6 2.3 3.0 lleepRiver- downstream 3 All -Aug?018 12.8 3.4 23 Effluent 29 Jan 2018 - Sep 2022 213 ,. 1 1011 Based on resulting patterns indicating effluent impact on the receiving waterbodies and to assess background concentrations of 1,4-dioxane to better analyze the discharge, instream monitoring for 1,4- Dioxane has been added to the pennit. Instream 1,4-dioxane monitoring is to be conducted at a Monthly frequency and shall be conducted at previously established instream locations upstream and at DI and D2. Instream 1,4-dioxane sampling shall be conducted in concurrence with effluent 1,4-doxane sampling. Page 7 of 24 Sampling for instream 1,4-dioxane may be waived as long as the Monitoring Coalition samples 1,4-dioxane at the nearest upstream and downstream locations, at a minimum frequency of monthly, and the City has obtained approval from DWR - NPDES permitting Unit that the upstream and downstream stations being monitored by the Coalition are representative of the receiving stream for this discharge. if the Coalition terminates instream IA-dioxane sampling at either of the approved stations, the City will immediately notify The Division and resume sampling for instream 1,4-dioxanc. In addition to the instream sampling conducted by the City of Asheboro, the Division will conduct instream sampling at the nearest downstream WS-V boundary. Is this facili0y a member qfa Monitoring Coalition with waived instream monitoring (YIN): YES Name of Monitoring Coalition: Upper Cape Pear River Basin Association 5. Compliance Summary Summarize the compliance record with permit effluent limits (past 5 years): From August 2017 through August 2022 the facility reported no limit violations. Summarize the compliance record with aquatic toxicity test limits and any second species test results (past 5 years): The facility passed 18 of 18 quarterly chronic toxicity tests front March 2018 through June 2022, as well as all most recent four (4) required second species chronic toxicity tests, sampled September 2019, December 2019. March 2020 and June 2021. Summarize the results from the most recent compliance inspection: The most recent compliance evaluation inspection, conducted on January 27, 2022, found the facility to be well -operated and maintained. The inspection report has been attached. The most recent pretreatment inspection was conducted on May 10, 2022. also found the facility's pretreatment program in compliance. 6. Water Quality -Based Effluent Limitations (WQBELs) Dilution and Mixing Zones In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH). If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA Ifapplicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA Oxygen -Consuming Waste Limitations Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits (e.g., BOD = 30 mg/L for Municipals) may be appropriate if deemed more stringent based on dilution and model results. Ifpermit limits are more stringent than TBELs, describe bow limits were developed: Limitations for BOD are based on a 1994 wasteload allocation model for oxygen -consuming «•ante, which determined limitations based on zero flow streams. No changes are proposed. Page 8 of 24 Ammonia and Total Residual Chlorine Limitations Limitations for ammonia are based on protection of aquatic life utilizing an anunonia 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 Antonia -Nitrogen limits (2.0/6.0 ntg/1, monthly/weekly averages for summer; 4.0/12.0 mg/L monthly/weekly averages far winter) in the permit are based on a 1994 wastcload allocation model for oxygen -consuming waste, which determined limitations based on zero Flow streams. Toxicity -based Ammonia was reviewed in the attached Wasteload Allocation (WLA) sheet using the flow design of 9.0 MGD and receiving stream 7Q10 low flow of 0.0 cfs for both the summer and winter values. The resulting allowable concentrations were 1.0/3.0 mg/l, monthly average/weekly average for summer, and 1.8/5.4 mg/l. monthly average/weekly average for winter. Because the toxicity -based limits are more stringent, they were placed in the permit. Review of DMR data from January 2018 through August 2022 revealed that the facility has not demonstrated an exceedance of the proposed monthly and weekly winter average limits since January 2018 (Fig. 2). As such, it appears that the City can consistently meet the new limits and a compliance schedule is not necessary. Proposed Ammonia-N (NH3 N) • Wk Avg ♦ Mo Avg — — MALimit —WAtimit 4 can 3 E 2 G of 0 1/10/2018 2/14/2019 3/20/2020 4/24/2021 5/29/2022 Figure 2. Asheboro W WT P effluent monthly average (MA) and weekly average (WA) Ammonia-N concentrations (mg/L) with their respective proposed limits for potential compliance evaluation. The current TRC limit of 17 µg/L was revieted via the attached WLA spreadsheet and was found to be protective. The current TRC limit is maintained in the permit. Page 9 of 24 Reasonable Potential Analysis (RPA) for Toxicants If applicable, conduct RPA analysis and complete irforrnation 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 195% Probability; 2) assumption of zero background; 3) use of '/a detection limit for "less than" values; and 4) streamflows used for dilution consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation o% Instretmt Dissoh'ed Metals Standards, dated June 10, 2016. A reasonable potential analysis was conducted on effluent toxicant data collected between January 2018 and September 2022, Pollutants of concern included toxicants with positive detections and associated water quality standards/criteria. Based on this analysis, the following pennitting actions are proposed for this pennit: • Effluent Limit with Monitoring. The following parameters will receive a water quality -based effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water quality standards/criteria: Bromodichloromethane (AM 31.6 pg/l,), Silver (MA 0.06ltg/L, DM 2.4 pg/L), 1,4-Diovane (AIA 21.58 pg/L - See Otter JVQBEL Considerations section %r more information) • Monitoring Only. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the maximum predicted concentration was > 50%n of the allowable concentration: Chloride. Selenium. Dihrnnv,cblurnnu deuce, Copper o Chloride - Reasonable Potential (RP) was found. Rule 15A NCAC 02B .0211 (22) states that if chloride is determined by the waste load allocation to be exceeded in a receiving water by a discharge under the specified 7Q10 criterion for toxic substances, the discharger shall monitor the chemical or biological effects of the discharge. Monitoring is maintained in conjunction with toxicity tests. • No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they did not demonstrate reasonable potential to exceed applicable water quality standards / criteria and the maximum predicted concentration was < 50% of the allowable concentration: Arsenic, Cadmium. Total Chromium, Cyanide, Lend, Muh•bdemun, Nickel, Zinc. • POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for additional pollutants of concern. o The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with monitoring, since as part of a limited data set, two samples exceeded the allowable discharge concentration: NA o The following parameter(s) will receive a monitor -only requirement, since as part of a limited data set, one sample exceeded the allowable discharge concentration: NA o The following parameters will not receive a limit or monitoring, since as part of a limited data set, they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria and the maximum predicted concentration was <50% of the allowable concentration: Chloroform, Total Phenolic Compounds, Ben'llium Total Selenium and Total Silver had been sampled at PQLs of 10 µgil. and 5 µg/L, respectively, up until July 2019, after which the City achieved PQI.s of I µg/l, for both parameters. Data using the less sensitive test methods were not incorporated in the RPA, as sufficient samples were available using the lower PQL Page 10 of 24 methods. The City shall continue to test for total silver and total selenium using the lower, sufficiently sensitive test methods. If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program. Toxicity Testing Limitations Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test failure. Describe proposed toxicity test requirement: The facility is a Major POTW, and a chronic WET limit at 90% effluent will continue on a quarterly frequency. Mercury Statewide TMDL Evaluation There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and industrial facilities with known mercury discharges. Given the small contribution of mercury from point sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (> I ng/L) will receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL value (based on the NC WQS of 12 ng/L) and/or if any individual value exceeds a TBEL value of 47 ng/L. Table 5. Mercury Effluent Data Summary 2018 2019 2020 2021 2022 Number of Samples 12 13 12 12 8 Annual Average Cone. ng/L 1.7 2.4 1.5 1.3 1.5 Maximum Cone., ng/L 3.50 2.90 3.30 3.60 4.60 TBEL, ng/L 47 WQBEL, ng/L 12.0 Describe proposed permit actions based on mercury evaluations. Since no annual average mercury concentration exceeded the WQBEL. and no individual mercury sample exceeded the TBEL, no mercury limit is required (Table 5). Because the facility is > 2 MGD and has reported quantifiable levels of mercury (> I ng/L), a mercury minimization plan (MMP) will be added to the permit. Other TMDL/Nutrient Management Strategy Considerations Ifapplicable, describe ah>r other TMDLs/Nutrient Management Strategies and their implementation within this permit: 'Ihc receiving water lies in the Deep River section of the central portion of the Cape Fear River Page 11 of 24 Basin, an area identified for nutrient criteria development in the North Carolina Nutrient Cl iteriu Development Plan, Version 2.0 (NCDW R 2014). The current permit has monthly monitoring requirements for Total Nitrogen (TN), Nitrite -Nitrate Nitrogen (NO2-N i- NO,-N), and Total Kjcldahl Nitrogen (TKN) in recognition of a nutrient strategy for the Upper Cape Fear River in addition to surface water monitoring and reporting requirements under 15A NCAC 02B .0500. The current permit also has a nutrient re -opener Special Condition, which has been maintained. No changes were made regarding effluent limitations at this time. Other WOBEL Considerations If applicable, describe anp other parameters of concern evaluated for WQBELs: The emerging contaminants I A-Dioxane and PEAS family of compounds were evaluated for potential WQBELs. 1.4-Dioxane 1,4-Dioxane (CASRN 123-91-1) is a synthetic industrial chemical that is completely miscible in water. Synonyms include dioxane, dioxan, p-dioxane, diethylene dioxide, diethylene oxide, diethylene ether and glycol ethylene ether (EPA 2014). 1,4-Dioxane is an emerging cmnaminant considered to be a likely human carcinogen that is highly mobile and does not readily biodegrade in the environment. It is found in groundwater and swface water sites throughout the United States. EPA risk assessments indicate that the drinking water concentration representing a I x 10' cancer risk level for 1,4-Dioxane is 35 pg/L and I x 10" risk level for 1,4-Dioxane is 0.35 µg/L (EPA 2013, EPA IRIS 2013). Re/rrences: • EPA (U.S. Environmental Protection Agency), 2014. EPA Technical Fact Sheet- 1,4-Dioxane, January 2014, SDMS Doc ID 575107. • EPA. 2013. Toxicological Revicw of I A-Dioxane (with Inhalation Update) in Support of Summary Information on the Integrated Risk Information System (IRIS). EPA 635-R-I 1-003F. • EPA IRIS. 2013. I,4-Dioxane (CASRN 123-91-1). www.epa.uov/iris/subst/0326.litm. An initial stream survey of the Cape Fear River Basin (NCDIYR 2016: 1,4-Dioxane in the Cape Fear River Basin of North Carolina::fit Initial Screening and Source Identification Study) found multiple sites with elevated concentrations. Among the highest concentrations in that survey were found at Study Site NCSU24 in Hasketts Creek just downstream of the Asheboro WWTP discharge with an average of 291 pg/L (range: 147-478 pg/L) from data collected June 2015-May 2016. DWR issued a letter, dated October 31, 2017, requiring monthly effluent monitoring beginning December 2017 with samples analyzed using the recently approved EPA Method 624.1. From January 2018 through September 2022, a total of 123 effluent data points were submitted, with an average of 116 pg/L (range: a 1- 1011 pglL). The Division issued a letter to Asheboro requesting the City develop and submit a corrective action plan for 1,4-Dioxane reduction by September 23. 2019. The requested plan was submitted in a timely manner, received on August 1, 2019, outlining the ('iq's aim to continue monitoring and coordinating with industrial users toward reduction of 1,4-Dioxane entering the WWTP.'fhe SIU Starpel has been identified as a significant source of 1,4-Dioxane. In 2019 Starpet had requested an Authorization to Construct from the City to install a prebuilt KOCH Modular System consisting of a 72-foot long stripper column along with a reboiler, shell, and a tube condenser & heat exchanger. The treatment system was installed and implemented in November 2020 according to Asheboro's 2020 Pretreatment Annual Report. Division regulations applicable to 1,4-Dioxane limitations: • 15A NCAC 02B .0203 identifies that water quality -based effluent limits for direct dischargers -'shall be developed by the Division such that the water quality standards and best usage of receiving waters and all downstream waters will not be inilmirecl." Page 12 of 24 • 15A NCAC 02B .0206(a)(4)(B) identifies that for the flow design criteria for effluent limitations, the average annual flow for toxic substances shall be used to protect human health. • 15A NCAC 02B .0208(a)(2)(B) identifies for carcinogens, an unacceptable exposed risk level is 1 x 10 ' or greater. • 15A NCAC 02B .0216(4)(d) Fresh Surface Water Quality Standards for Class WS-IV Waters identifies that no discharge of sewage "...shall be allowed that have an adverse effect on human health or that are not treated in accordance with the permit or other requirements established by the Division..... 1,4-dioxane is completely miscible in water and resistant to biodegradation. The mass loading of 1,4- dioxane identified in the facility discharge to Hasketts Creek, a class C waterbody, is expected to persist downstream to the nearest water supply (WS-V) boundary, located in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles downstream of the oulfall, As such, allowable discharge concentrations were calculated for both the direct discharge to Class C Hasketts Creek and for the nearest downstream water supply (WS-V) boundary, and the more restrictive concentration was selected for protection of downstream uses. The water supply boundary is for the Deep River (Gulf- Cioldston) water supply watershed. Each allowable discharge concentration was calculated considering the applicable receiving stream's Average Annual Flow (AAF), appropriate Instream 'Target Value (ITV), and the facility's permitted design now. Note that the river segment at the WS-V boundary is also classified as High -Quality Waters (HQW). As the facility is neither new nor expanding, 15A NCAC 02B .0224(c)(G) has not been applied. However, should the facility pursue expansion, toxic substances shall be limited at 'h the normal standard at design conditions. For the direct discharge to Class C Hasketts Creek, an ITV of 80 µg/I. for non -water supply waters at an AAF of 12 cfs and a permitted design flow of 9.0 MGD (13.95 cfs) was considered. This calculation yielded a chronic allowable discharge concentration of 149 jig/L. When considering the downstream WS-V waters, a I x 10 ° risk level ITV of 0.35 fig/L for water supply waters at an AAF of 846 cfs (calculation estimated by USGS for the WS-V boundary of the Gulf-Goldston WS watershed) and a permitted design flow of 9.0 MGD (13.95 cfs) was considered. This calculation yielded a chronic allowable concentration of 21.58 µg/L. 'The discharge determination based on direct discharge to Class C Hasketts Creek is insufficiently protective of downstream water supply uses. As such, the chronic allowable discharge concentration of 21.58 fig/I. has been used in detennination of permitting actions. Based on a review of the effluent data, the W WTP demonstrates a reasonable potential to exceed the state water supply (WS) lTV of 0.35 pg/L for 1,4-Dioxane at the nearest downstream water supply boundary. Given the facility's effluent data, weekly monitoring and limits have been added to the permit. Recognizing that 1,4-Dioxane is an emerging contaminant and industrial users are in the process of adjusting to its impact and use in materials, a phased implementation compliance schedule has been included in the permit. In Asheboro's case, the future phase 1,4-Dioxane target must not cause violation of the ITV f'or 1,4-Dioxane at the water supply boundary. Considering the existing effluent concentrations experienced al the facility, the first phased limit was calculated to be the 50°i percentile value of the effluent data submitted from January 2018 through September 2022. This initial phased limit was calculated after removing detection values identified as outliers (Z score > 3 or < -3), resulting in a limit of 55.7 ltg/L. T'he second phase is set at the EPA Health Advisory Level H IAL) of 35 ftg/l-. The third and final phased limitation is set al 21.58 pg/L based on the ITV for 1,4-dioxane calculated at the water supply boundary. Daily maxima limitations have been calculated for each phase from the chronic monthly average limitations using EPA guidance. Derivation of the maximum daily limit is based on EPA's Technical Supporf Documew (TSD, USEPA 1991) recommendations. Page 13 of 24 According to the TSD, developing final permit limits for pollutants affecting human health is somewhat different from setting limits for other pollutants because the exposure period is generally longer than I mouth. Therefore, the EPA -recommended approach for setting water quality -based limits for human health protection with statistical procedures is as follows: • Set the AML (Average Monthly Limit) equal to the W LA (to meet the instream target value of 0.35 Itg/L) • Calculate the MDL (Maximum Daily Limit) based on effluent variability and the number of samples per month using the multipliers provided in TSD Table 5-3. This approach ensures that the instream criteria will be met over the long-term and provides a defensible method for calculating an MDL. The daily maximum final limit was developed using the recommended approach in TSD Section 5.4.4, for human health protection. Input variables for the multiplier table consulted (TSD Table 5-3) included: • A coefficient of variation (CV) of 0.8 based on the most recent 59 data points (July 2021 - September 2022) and after removing Z-score-identified outlier values, • AM I. exceedance probability of 95" percentile. • MDL exceedance probability of99"' percentile, • A weekly sampling frequency (n = 4hnonth). The table yielded a multiplier of 2.29, which was applied to the average monthly limits of 55.7 µg/L, 35.0 µg/L, and 21.58 jig/L. to obtain the maximum daily limits of 127.6 µg/L, 80.2 µg/L, and 49.4 µg1l_ respectively. Monthly averages for effluent data reported from January 2018 through September 2022 have been calculated and compared to the proposed monthly average phased limitations below in Figure 3 Proposed 1,4-Dioxane MA 10000 J m 7 C O 1000 •• • v 100 •• • • • • • x Ir • • • • • •55.7 µg/L o • 0 21.58 µg/L .a 10 m • 21 m a t, 13/11/2017 12/16/2018 1/20/2020 2/23/2021 3/30/2022 c Date • 1,4 dloxane Effluent Data —Phased Target I MA —PI a<-ed Target II Iv1A —Final Phased Target III MA Figure 3. Asheboro WWTP effluent Monthly Average 1,4-dioxane data versus three proposed phased Monthly Average limitations Page 14 of 24 Effluent data from January 2018 through September 2022 has been compared to the proposed daily maximum Dhased limitations below in Pieurc 4 Proposed 1,4-Dioxane DM 10000 m 1000 4► o 100 _ _ _ •W7. 9. 127.6 pg/l • • •.• + •-�• 49.4 Pg/t 0 10 • •o • i • S• 1 11/11/2017 12/16/2018 1/20/2020 2/23/2021 3/30/2022 Date • 1,4-dioxane Effluent Data —Phased Target I DM —Phased Target II DM urinal Phased Target III DM Figure 4. Asheboro WWTP effluent 1,4-dioxane data versus three proposed phased Daily Maximum limitations Effluent data has been submitted for both the Asheboro WWTP and Starpet ranging from December 2020 through September 2022. A visual representation of this data is provided in Figure 5, below. Please note that the 1,4-dioxane concentration axis was reduced in range for clarity of the graph. Four (4) Sampling events occurred during this review period where 1,4-dioxane concentrations greater than 1,000 ug/L were Asheboro WWTP vs Starpet Comparison 100000 J m 10000 • 0 1000 • • V 100 • • • • ♦ • A• j • • •/:• • loop• 0 00,•� % • , � loop 30o vo soso 0 30 • i0• Mr + • 1 • 9/26/2020 4/14/2021 10/31/2021 5/19/2022 12/5/2022 Date *Asheboro WWTP Effluent • Starpet Effluent Figure 5. Comparison of Asheboro W" TP and Starpet Effluent 1,4-dioxane Concentrations Page 15 of 24 Review of the data demonstrates instances where 1,4-dioxane was detected at a higher concentration in the Asheboro effluent than in the Starpet effluent. While some of these instances followed a large spike in Starpet effluent 1,4-dioxane, others do not appear to follow a spiked event. Based on this review, it has been concluded that either 1,4-dioxane is somehow being trapped in the components Asheboro WWTP's treatment works and released over time, leading to varying degrees of effluent spikes, or there exists another industrial user that is contributing to the 1,4-dioxane loading entering the Asheboro W WTP. The City has noted that an additional contribution of 1,4-dioxane to the plant's influent is coming from the Waste Management of the Carolinas Great Oak Landfill. Data provided from the landfill demonstrated 1.4-dioxane levels ranging from 26,000 ug/L to 66,300 ug/L (sampling conducted from April to July 2021). To better understand the influent 1.4-dioxane levels entering file facility, a requirement has been added that the City conduct an investigation into all potential sources of 1,4-dioxane and provide a report to the Division within 2 years of the effective date of the permit. See the three-phase compliance schedule incorporating the various phased limitations below: NPDES Permit limits have been calculated for a three-phase compliance schedule: • Phase I — Initial Limit: o Effluent MA limit of 55.7 Ing/L and DM limit of 127.6 µg/L, based on the 50°i percentile of reported effluent concentrations from January 2018 through September 2022, becomes effective 1 year after the effective date of the pennit. o Within I year of the permit's effective date. the Pennittee shall submit to DW R an Action Plan for Division approval, summarizing file strategy or actions to be taken to achieve compliance with the nitrate linnifations. This Action Plan shall include an assessment of identified 1,4-dioxane sources. Action Plan updates regarding actions taken to come into compliance with Phase II and M limitations shall be submitted to the Division annually. o Within 2 years of the permit's effective date, the Permittee shall submit to DWR a report of actions taken with regard to identified sources in order to achieve compliance with permit limits. Updates on actions taken shall be submitted to the Division annually. • Phase ❑ — Interim Limit: o Effluent MA limit of 35 fig/L and DM limit of 80.2 pg/L, based on the EPA Drinking Water IIAL value, becomes effective beginning three (3) years after the effective date of the permit. o Action Plan updates regarding actions taken to come into compliance with Phase III limitations shall be submitted to the Division annually. • Phase III — Final Limit o Effluent MA limit of 21,58 Itg/L and DM limit 49.4 pg/L, based on 1 x 10' risk level at the water supply boundary, becomes effective beginning five (5) years after the effective date of the permit. Implementing this phased Compliance Schedule, Monthly Average and Daily Maximum limits along with weekly monitoring, reporting and notification requirements have been added to the permit. Additionally, requirements for modification and reissuance of Industrial User Permits to ensure compliance with the interim and Final 1,4-dioxane limits as well as for the notification of downstream drinking water utilities when effluent 1,4-dioxane concentrations exceed the current interim limit have been added to the permit. PFAS Asheboro WWI P had participated in a basin -wide survey for the emerging contaminants PEAS chemical group in 2019. 'I hree rounds of influent sampling were conducted in July, August and September 2019. In ,tune 2022, EPA issued interim updated drinking water health advisories for PFOA and PFOS, and final drinking water health advisories for PFBS and GcnX. EPA's Health Advisory Levels (HALs) Ior PFAS are Page 16 of 24 non -enforceable and non -regulatory, and only provide technical information to stale agencies and other public health officials on health effects, analytical methods, and treatment technologies associated with drinking water contamination. The 2019 influent data collected at the Asheboro W WTP has been summarized below for PFOA, PFOS, PFBS and GenX and compared to the .Tune 2022 interim updated drinking water health advisories (See Table 7.). Table 7. 2019 Investigative Monitoring Influent PFAS Summary Parameter Average Influent (ng/L) Maximum Influent (ng/L) Minimum Influent (ng/L) 2022 Updated Drinking Water Health Advisory (ng/L) 13FOS 19.3 19.9 18.8 interim' PFOA 10.6 11.7 9.47 interim' PFBS Non -detect Non -detect Non -detect 2.000 GenX' Non -detect Non -detect Non -detect 10 'Interim PFOS and PFOA values can be found httt s://www.el)a.gov/sdwa/drinking-water-health-advisories-pfoa- and-pfos#:-: tex t=2022%20I nterim%20Umdated%20PFOA%20and. those%20 EPA%20issued%20in%202016. '-During the 2019 investigation, GenX analysis was only conducted in one of the three events. On March 14, 2023, EPA proposed Maximum Contaminant Levels (MCLs) for drinking water for PFOA, PFOS, PFNA, PFIixS, PFBS and GenX. To identify PFAS contamination in waters classified as Water Supply (WS) waters, monitoring requirements are to be implemented in permits with pretreatment programs that discharge to WS waters. While not immediately downstream, WS-V classified waters exist approximately 43.5 miles downstream of the discharge. As the Asheboro W WTP has a pretreatment program and has demonstrated influent PFAS levels greater than the interim updated drinking water health advisories, monitoring of PFAS chemicals will be added to the permit at a frequency of quarterly. Since an EPA method for sampling and analyzing PFAS in wastewater is not currently available, the PFAS sampling requirement in the Permit includes a compliance schedule which delays the effective dale of this requirement until the first full calendar quarter beginning 6 months after EPA has a final wastewater method in 40 CPR 136 published in the Federal Register. This date may be extended upon request and if there are no NC -certified labs. 1l'applicahle, describe any special actions (HQW or ORW) this receiving stream and classification shall comply with in order to protect the devignated waterbody: NA If applicable, describe any compliance schedules proposed, for• this permit renewal in accordance with 15A NCAC 211.0107(c)(2)(B), 40CFR 122.47, and EPA Mq1, 2007 Memo: A three-phase 5-year compliance schedule is proposed for 1,4-Dioxane limit followed by a final Ihnit. Per Pennittee request, a 3-year compliance schedule for total silver with a Water -Effect Ratio (WER) option has been added to the permit. The City informed the Division in an 11 /29/2022 email that they do not require a compliance schedule for bromod i c h I orom ethane. If applicable, describe am water quality standards variances proposed in accordance with NCGS 143- 215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA Page 17 of 24 7. Technology -Based Effluent Limitations (TBELs) Municipals Are concentration limits in the permit at least as .stringent as secondary treatment requirements (30 mg/L BODS/TSSfor Mmthly Average, and 45 mg/L for BODs/TSS fm- IVeekly Averag(,). YES /fNO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA Are 85% removal requirements for BOD51TSS inchtded in the permit? YES ifNO, provide a jusgfication (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 insuvam water uses and the level of water quality necessary to protect the existing use is maintained and protected. If applicable, describe the resrdts of the antidegradation review, including the Engineering Alternatives Analysis (EAA) and any water qualihl modeling results: NA 9. Antibacksliding Review: Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL limits, or WQBELs may be less stringent based on updated RPA or dilution). Are any e.1fluent limitations less stringent than previous permit (YES/NO): YES If YES, confirm that antibacksliding provisions are not violated: Based on the reasonable potential analysis (RPA) showing no reasonable potential to violate state water quality standards, the limits and monitoring requirements for total chromium and total zinc have been removed from the permit. Based on the Mercury TMDL evaluation showing no annual average mercury concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, the limits and monitoring requirement for total mercury have been removed from the permit. 10. Monitoring Requirements Monitoring frequencies for NPDES permitting are established in accordance with the following regulations and guidance: 1) Slate Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding prohibitions would not be triggered by reductions in monitoring frequencies. The City of Asheboro requested 2/week monitoring for BOD, ammonia, TSS and fecal coliform based on 2012 DWR Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Pennies for Exceptionally Performing Facilities on November 18, 2022. The last three years of the facility's data for these parameters have been reviewed in accordance with the criteria outlined in the guidance. Based on this Page 18 of 24 review, 2/week monitoring frequency has been added for BOD, ammonia, TSS and fecal colifonn. Please note that the proposed ammonia limitations were used when assessing ammonia criteria. For instream monitoring, refer to Section 4. 11. Electronic Reporting Requirements The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit additional NPDES reports electronically. This permit contains the requirements for electronic reporting, consistent with Federal requirements. 12. Summary of Proposed Permitting Actions Table 4. Current Pen -nit Conditions t and Pro osed Changes Parameter Current Permit Proposed Change Basis for Condition/Change Flow MA 9.0 MGD No change 15A NCAC 2B .0505 Summer: MA 5.0 mg/L WQBEL. Determined via W LA WA 7.5 mg/I, conducted in 1995, and for protection Winter: No change to limits; Monitor and of DO standard (15A NCAC 2B .0200). BODs MA 10 mg/1_ Report 2/Week 2012 DWR Guidance Regarding the WA 15 mg/L Reduction of Monitoring Frequencies in Monitor and NI DES Permits for Exceptionally Report Daily Performing Facilities TBEL. Secondary treatment standards MA 30 mg/L 40 CPR 133 / 15A NCAC 2B .0406. TSS WA 45 tng/L No change to limits; Monitor and 2012 DWR Guidance Regarding the Monitor and Report 2/Week Reduction of Monitoring Frequencies in Report Daily NPDES Permits for Exceptionally Perfoninne Facilities WQBEL. Based on protection of Statc Summer: Summer: WQ criteria. 15A NCAC 2B.0200; MA 2.0 mg/l. MA 1.0 mg/L 2022 WLA review; 2012 DWR WA 6.0 mg/L WA 3.0 ntg/L Guidance Regarding the Reduction of NH3 N Winter: Winter: Monitoring Frequencies in NPDES MA 4.0 mg/L MA 1.8 mg/L Permits for Exceptionally Performing WA 12.0 mg/L WA 5.4 mg/L Facilities; No compliance schedulc Monitor and Monitor and Report 2/Week facility meets revised limits Report Daily Add instream monitoring 1/Month consistently. Based on Instream Data Summary DO 6 mg/L No change WQBEL. For protection of the DO — standard. 15A NCAC 2B .0200. pH 6.0 — 9.0 SU No change WQBEL. WQ standard. 15A NCAC 211 .0200. Page 19 of 24 MA 200 /100 mL WQBEL. WQ standard, 15A NCAC 2B Fecal WA 400 /100 m1. No change to limits; Monitor and .0200. 2012 DWR Guidance Regarding Coliforn Monitor and Report 2/Week the RedUel1011 of Monitoring Report Daily Frequencies in NPDES Permits for Exceptionally Performing Facilities Total WQBEL. Based on protection of State Residual DM 17 µg/L No change WQ criteria. 15A NCAC 2B.0200; Chlorine 2022 WLA review Surface Water Monitoring, 15A NCAC Temperature Monitor daily No change 0213 .0500 No change to effluent. 15A NCAC 2B.0500, added based on Conductivity Monitor effluent Add instream monitoring upstream instream conductivity review daily (U) and downstream (DI and D2) demonstrating effluent impact on receiving stream. Monitor Surface Water Monitoring, Based on quarterly in RPA and 15A NCAC 213.0211 (22). R13 Chloride conjunction with No change shown; apply quarterly monitoring in Chronic Toxicity conjunction with toxicity tests, per 15A lest NCAC 02B .0211(22) Surface Water Monitoring, Ilardness- Total dependent dissolved metals water Hardness No requirement Add quarterly effluent monitoring quality standards, approved in 2016; upstream hardness not required due (o 0 cfs 7Q 10. Total MA = 50 µg/l. No reasonable potential was found, Chromium DM = 1033 µg/L Remove from permit maximum predicted value < Cr-VI allowable concentration. Surface Water Monitoring, Based on RPA, 2022 303(d) listing and Integrated Total Copper Monitor No change Report' Receiving water is impaired quarterly due to copper. No RP , Predicted Max 50% of Allowable Cw - apply Quarterly Monitoring Total MA = 12 ng/1. Renim e limits from permit. Consistent with 2012 Statewide Mercury DM = 36 ng1L � Add Mercury Minimization I Ian Mercury TMDL Implementation. (MMf ) MA = 0.06 ug/L DM = 2.4 ug/L Total Silver No requirement Monitor and report Monthly at WQBEL. Based on RPA. RI' ,heir n - lower reporting level of procedure apply Monthly Monitoring with Limit 3-year compliance schedule with WER option Total No requirement Quarterly monitoring at lower Surface Water Monitoring, Based on Selenium reporting level of procedure RPA. No RP. Predicted Max > 50% of Page 20 of 24 Allowable Cw - apply Quarterly Monitoring Based on RPA. No reasonable potential Total Zinc Monitor Remove fiom pennit found in RPA, but maximum predicted quarterly value < 50% of the allowable concentration. Surface Water Monitoring, Based on Dibromochlo Monitor No change RPA. No reasonable potential found in romethane quarterly RPA, but maximum predicted value > 50% of the allowable concentration. Bromodichlo Monitor MA = 31.6 ltg/L WQBEL. Based on RPA for NC romethane quarterly Monitor and report Monthly Instream Target Value. RP shown - apply Monthly Monitoring with Limit Surface Water Monitoring, 15A NCAC Total Monitor monthly No change to effluent; Add 2B.0500; nutrient criteria development Nitrogen instream monitoring 1/Month in the Upper Cape Fear River Basin. Based on Inslreant Data Summary Total Surface Water Monitoring, 15A NCAC Kjeldahl Monitor monthly No change to effluent; Add 213.0500; nutrient criteria development Nitrogen instream monitoring I /Month in the Upper Cape Fear River Basin. ,Based on Instream Data Summary Nitrate + Surface Water Monitoring, 15A NCAC Nitrite Monitor monthly No change to effluent; Add 213.0500; nutrient criteria development Nitrogen instream monitoring I /Month in the Upper Cape Fear River Basin. Based on Instream Data Summary Surface Water Monitoring, 15A NCAC Total Monitor monthly No change to effluent; Add 2B.0500; nutrient criteria development Phos p horns instream monitoring b 1/Month in the Upper Cape Pear River Basin. Based on Instream Data Summary WQBEL. 15A NCAC 02B and Add 3-phase compliance schedule protection of downstream water usage: Monitor monthly Monitor I/week grab Phased limitations based on 50°i 1,4-Dioxane per letter sent in percentile of effluent levels, EPA October 2017 Add monthly instream drinking water HAL of 35 Itg/L and NC monitoring. human health criterion of 0.35 lrg/L at downstream water supply water. Evaluation of PEAS contribution: Add quarterly monitoring with p1etreatment facility with downstream PEAS No requirement delayed implementation WS; Implementation delayed until after EPA certified method become available. Chronic Quarterly Ceriod aphnla WQBEL.. No taxies in toxic amounts. Toxicity dubio Pass/Fail at No change 15A NCAC 2B.0200 and 15A NCAC 90% effluent I 2B.0500 Page 21 of 24 Effluent Pollutant Scan Three times per permit cycle Update sampling years to 2025. 2026. 2027, 40 CFR 12_ In accordance with EPA Electronic Electronic No requirement Add Electronic Reporting Special Reporting Rule 2015 and Phase II 2020 Reporting Condition update. Nutrient Special Upper Cape Fear River nutrient slrateg� Reopener for Condition No change requirement. TN and TP MGD = Million Gallons per Day, MA = Monthly Average, WA = Weekly Average, DM = Daily Max. 13. Public Notice Schedule Permit to Public Notice: 05/09/2018 Permit to Second Public Notice: 12/6/2022 Public Hearing: 05/23/2023 (Hearing Officer's Report attached) Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following the publication date of the public notice. Any request for a public hearing shall be submitted to the Director within the 30 days comment period indicating the interest of the party filing such request and the reasons why a hearing is warranted. 14. Fact Sheet Addendum (if applicable) Were there any changes made since the First Draft Permit was public noticed fYes/Nol: Yes. Comments were received from the City of Asheboro (Pennittee), dated 5/31/2018.'These include: • Why were mass -based N 13 limits not inserted as requested as an alternative to concentration -based limits? If mass -based limits not allowed, then requested 3 yr compliance schedule. • Explain Chloride RPA factors and results. • Cyanide limits appeared to be based on lab data that were found to be resulting from instrument interference; requested removal of limits and monitoring • Requested 2-yr compliance schedule for bromodichloromethane (The City submitted a follow-up on 11/29/2022 informing the Division that this schedule is not necessary) • Explain legal basis and calculation of 1,4-dioxane limits • Explain discrepancy between Asheboro's limits and DAK America's monitoring only requirements for 1,4-dioxane • Explain shortened permit term (4 not 5 yrs) Comments were also received electronically on 6/8/2018 from multiple municipalities expressing water supply 1,4-Dioxane concerns, the need to consider downstream water supply waters and any additional sources in developing permit limits, and to reduce the 1,4-Dioxane compliance schedule. Comments were provided by the Fayetteville Public Works Commission, Cape Fear Public Utility Authority, City of Sanford, and Town of Cary. Comments and DW R responses are attached. Page 22 of 24 !f Yes, list changes (front previous public notice) and their basis below: Note: This is riot a comprehensive list of all changes from the current permit. • Based on the reasonable potential analysis (RPA) showing no reasonable potential to violate state water quality standards, total cyanide limits and monitoring requirements have not been added to the permit. • 1,4-dioxane limitations have been revised based on calculations pertaining to downstream WS water uses. See Other WQREL C'mnsiderations section above. • A three-phase five-year 1,4-Dioxane compliance schedule has been added. See Other 11'QBEL Considerations section above. • Chromium monitoring requirement was removed, based on an RPA with updated Total Chromium data not showing a reasonable potential to exceed the Chromium -VI water quality standard. • Copper monitoring will be maintained based on the reasonable potential analysis (RPA) predicting a maximum effluent total copper concentration that is greater than half of the allowable discharge concentration based on state water quality standards. • Based on the reasonable potential analysis (RPA) predicting a maximum effluent total selenium concentration that is greater than half of the allowable discharge concentration based on state water quality standards, quarterly monitoring for total selenium has been added to the permit. • Based on the reasonable potential analysis (RPA) showing reasonable potential to violate state water quality standards, total silver limits and monitoring requirements have been added to the permit. • To provide an opportunity for the City to develop a plan to assess sources of total silver in order to come in compliance with the proposed limits, schedules of compliance have been added to the permit. See Other IVQBEL Considerations section above. • Based on resulting patterns indicating effluent impact on the receiving waterbodies and to assess background concentrations of 1,4-dioxane to better analyze the discharge, instream monitoring for 1,4-Dioxane has been added to the permit. • Based on review of instream data, instream conductivity, TN, TKN, NO2+NO3, ammonia, and TP monitoring has been added to the permit • Based on NPDES guidance regarding the reduction of monitoring frequencies in NPDES pennits Far exceptionally perforining facilities, monitoring requirements for BODs, NHYN, Total Suspended Solids and Fecal Colifonm have been reduced to twice per week. Were there any changes made since the Second Draft Permit was public noticed (Yes/No): Yes. Comments were received from the Billowing parties regarding the December 2022 draft permit: • Crantill Sumner, LLP, attorney on behalf of the City of Reidsville, dated 1/5/2023 • City of Asheboro (Asheboro), dated 1 /9/2023 • Cape Fear Public Utility Authority (CFPUA) on 1/13/2023 • Fayetteville Public Works Commission (PWC) on 1/25/2023 • Brooks Pierce, attorney on behalf of the Cities of Greensboro and Asheboro, on 1 /26/2023 • Southern Fnvironmental Law Center on 1 /27/2023 A request for public hearing was made by Fayetteville PWC and Cranflll Sunnier, I.I.P. All sets of comments and Division responses have been attached. Division responses to comments can be found in the attached Hearing Officer's Report. Changes made as a result of the comments received have been summarized below. A technical proposal for the development of a silver WER, submitted by B'I' Solutions, LLC on behalf of the City of Asheboro, was received by the Division on May 16, 2023. Revisions to the technical proposal were received on .tune 30, 2023. The Division approved the revised technical proposal on July 3, 2023. Page 23 of 24 If Yes, list changes (from previous public notice) and their basis below: • Per request from downstream utilities and for the sake of redundancy in the event of staff turnover, the Utility List has been updated to include a secondary contact for each utility downstream of the Asheboro WWTP discharge. • As the expiration date has been changed to September 30, 2028, Special Condition A.(3.) has been modified to include the specific three years in which the Effluent Pollutant Scan shall be performed (2025, 2026, and 2027). • Special Condition A.(7.) PFAS Monitoring Requirements has been updated to include reference to the most recent 4th Draft of EPA Method 1633, released in July 2023. • Instream monitoring of 1,4-dioxane has been revised to occur monthly [See Special Condition A. (2.)]. Additionally, the Division is activating a monitoring station downstream at the WS-V boundary for sampling. 15. Fact Sheet Attachments (if applicable) • RPA Spreadsheet Summary • NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards • NH3lTRC WLA Calculations • BOD & TSS Removal Rate Calculations • Mercury TMDL Calculations • Pretreatment Information Form • Monitoring Frequency Reduction Assessment • WETTesting and Self -Monitoring Summary • Compliance Inspection Report • Chemical Addendum • Application Addendum • 2022 NC Integrated Report (Ilasketts Creek Listing) • USGS Flow Estimation for WS boundary • City of Asheboro 2020 Pretreatment Annual Report. page 7 • Public Comments • Hearing Officer's Report • Total Silver WER Study Proposal and Approval Page 24 of 24 Public Notice AFFP North Carolina Environmental Public Notice North Carolina Management Commission/ NPDES Unit 1617 Mail Service Center Affidavit of Publication Raleigh, NC 27699-1617 Notice of Intent to Issue a NP- DES Wastewater Permit STATE OF NC) SS NCO026123 Asheboro WWTP COUNTY OF } The North Carolina Environment- al Management Commission pro- poses to issue a NPDES Brenda Poole, being duly swom, says: wastewater discharge permit to the person(s) listed below. Writ - That she is Classified Rep of the The Courier -Tribune, a ten comments regarding the pro - daily newspaper of general circulation, printed and posed permit will be accepted un- published in Asheboro, County, NC: that the publication, a til 30 days after the publish date copy of which Is attached hereto, was published In the of this notice. The Director of the said newspaper on the following dates: NC Division of Water Resources December 09, 2022 (DWR) may hold a public hearing should there be a significant de- gree of public interest. Please mail comments and/or informa- tion requests to DWR at the above address. Interested per- sons may visit the DWR at 512 N. That said newspaper was regularly issued and circulated Salisbury Street, Raleigh, NC on those dates. 27604 to review the information SIGNED: on file. Additional information on NPDES permits and this notice may be found on our website: ht- Classified Rep tp://deq.nc.gov/about/divisions/wa ter-resources/water-resources- Subscribed to and sworn to me this 9th day of December permitslwastewater-branch/np- 2022. des-wastewater/public-notices,or by calling (919) 707-3601. The City of Asheboro [P.O. Box 1106, Asheboro, INC 27204] has re- quested renewal of NPDES per - Barbara M Daniels, Notary Guilford, County, NC mit NCO026123 for its Asheboro Wastewater Treatment Plant, loc- My commission expires: March 06, 2027' - = .•.�. ated in Randolph County. This ;!,- ;.�,,:,;, permitted facility discharges treated municipal and industrial _ = wastewater to Hasketts Creek, a �_.,y�� class C water in the Cape Fear 70083249 70540195 _.. River Basin. Currently, BOD, am - WREN wREN THED1=oRD monia, dissolved oxygen, pH, fecal coliforrn, total residual chlor- NCDEQ-DWR-NPDES (ASH) ine, total silver, brornodichloro- 1617 MAIL SERVICE CENTER methane and 1,4-dioxane are wa- RALEIGH, NC 27699.1617 ter quality limited. This discharge may affect future allocations in this segment of Hasketts Creek. 1 t:1219/22 Notice of Public Hearing AFFP PUBLIC NOTICE is hereby giv en that the North Carolina De. Public Notice State of North partmenl vEnvironmental Quality's Division of Water Re• sources will hold a public hear- ing from 6 p m. to B p.m. on A,ffidavit of Publication May 23. 2023. lot National Pol- lution Discharge Elimination System (NPDES) Wastewater Discharge Permit NCO026123 The purpose of the hearing is to give the opportunity to com ment on the draft NPDES per STATE OF NC } SS mit COUNTY OF } The City of Asheboro has ap• plied for a renewal of its NP- h DES wastewater permit anCie T (NC0026123) for the Asheboro Wastewater Treatment Plant. Brenda Poole, being duly swom, says: 1032 Bonkemeyer Drive Asheboro, NC, Randolph County. The facility will dis- That she is Classified Rep of the The Courier -Tribune, a charge treated municipal and industrial wastewater to Has- dailynewspaper of general circulation, printed and 9 p ketts Creek in the Cape Fear River Basin (Class C). The published in Asheboro, County, NC; that the publication, a ney rest do nst redarywatteer sou copy of which is attached hereto, was published in the in the Deep River 43.5 miles said newspaper on the following dates: downstream of the outfall, was considered during the develop- ment of this permit. This dis- Apd120, 2023 charge may affect future alloca- tions in this portion of the Cape Fear River Basin. The location of the Outfall is Latitude 35.46*00 N. Longitude 79.47*06' The draft wastewater permit and related documents are available online at tices-hearings. Printed copies That said newspaper was regularly issued and circulated of the draft permit and related on those dates. documents may be reviewed at the department's Winston - SIGNED: Salem Regional Office (450 .. West Hanes Mill Road. Suite / 300. Winston-Salem. NC ti 27105). To make an appoint. ment to review the documents. Classified Re p As - please call Jenny Graznak, As- sistant Regional Supervisor. at 336.776.9695. File materials Subscribed to and sworn to me this 20th day of April 2023 may not be removed from any DWR office; copy machines are available for use upon pay- ment of the cost thereof to DWR pursuant to O.S. 132.6.2 Public comments on the draft permit may be mailed to. Wastewater Permitting, Alin 1r.1 0&" Asheboro -Asheboro WWTP Barbara M Daniels, Notary Guilford, County, NC Permit, 1617 Mail Service Cen- ter, Raleigh, N.C., 27699.1617. and must be postmarked no My commission expires: March 06, 2027 later than May 24. 2023. Public comments may also be submit led by email to: 1jybliccom- ments0ncdenr.gov. Please in. clude `Asheboro WWTP' in the email subject line. Comments will be accepted via email until May 24. 2023. 5 p.m. All com- ments will be considered in the final determination regarding permit issuance and permit pro WREN THEDFORD visions. NCDEQ-DWR-NPDES (ASH) Public Hearing Details (IN - PERSON) Date- Tuesday. May 1617 MAIL SERVICE CENTER �, 23. 202 . tTraining 8 p m ��'1.� �� RALEIGH, NC 27699-1617 - Corporm Center at the. Randolph Com- :�•� munity College. 413 Industrial = Park Avenue. Asheboro. NC t� t"� .' 27205 Register Speaker regis- tration opens at 5-30 p.m . J onsite via sign-up sheet it. 410.12023 Coco, Nicl<A From: Kirby, Ben Sent: Tuesday, January 3, 2023 12:56 PM To: Coco, Nick A; Hudson, Eric Subject: RE: Draft Permit Asheboro WWTP, NPDES Permit Number NC0026123, SIC Code 4952 Follow Up Flag: Follow up Flag Status: Flagged Nick, Our Office concurs with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Thanks, Ben Kirby, E.I. (he/him/his) Assistant Regional Engineer, Winston-Salem Regional Office Division of Water Resources, Public Water Supply Section North Carolina Department of Environmental Quality Office: (336) 776-9668 1 Cell: (336) 403-1090 ben. kirbv(M ncdenr. gov 450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 uosaTM rim, wnD � ��� pyermsaaumuwwuwh� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Coco, Nick A <Nick.Coco@ncdenr.gov> Sent: Wednesday, December 7, 2022 4:13 PM To: Hudson, Eric <eric.hudson@ncdenr.gov>; Kirby, Ben <ben.kirby@ncdenr.gov> Subject: Draft Permit Asheboro W WTP, NPDES Permit Number NC0026123, SIC Code 4952 Hi Eric and Ben, Thank you again for your help in developing the contact list for utilities downstream of this facility. While this facility is not discharging into a WS water, we have developed limits for one of the parameters, specifically 1,4-dioxane, with consideration of the nearest downstream WS boundary. Please see the following links to review the draft permit and cover letter and draft fact sheet for NPDES permit NC0026123 for the Asheboro W WTP. I have also provided a link to the NPDES Standard Conditions for your reference. You have a 30-day period ending on 1/13/2023 to comment, ask questions, or request an extension to review this draft permit. Please contact me with any comments you might have. Draft Permit: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2601378&dbid=0&repo=WaterResources NPDES Standard Conditions: https://bit.IV/3k5NFaL Draft Fact Sheet: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2601402&dbid=0&repo=WaterResources Thanks and have a nice day. Nick Coco, PE (he/him/his) Engineer 111 NPDES Municipal Permitting Unit NC DEQ / Division of Water Resources / Water Quality Permitting Office: (919) 707-3609 nick.coco@ ncdenr.gov **Email is preferred but I am available to talk by via Microsoft Teams** Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604 Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617 NORTH CAgOLI EQom) Uee "ent W E Imnmendl Qml;\� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. DocuSign Envelope ID: 6772C75B-1EB4-40CD-9904-F3F8627845AE ROY COOPER Gore ELIZABETH S. BISER Sn ary RICHARD E. ROGERS, JR. olrera. Mr. Michael D. Rhoney, PE Water Resources Director City of Asheboro P.O. Box 1106 146 N Church Street Asheboro, North Carolina 27204 Dear Mr. Rhoney: NORTH CAROLINA Env7ranma iWQuaWry July 3, 2023 Subject: Study Plan Approval Silver Water -Effect Ratio (WER) Permit NCO026123 Asheboro WWTP Randolph County A technical proposal for the development of a silver WER, submitted by BT Solutions, LLC on behalf of the City of Asheboro, was received May 16, 2023, by the Division of Water Resources (Division). Submittal of this WER study plan is in accordance with Special Condition A.(4.) Schedule of Compliance for Total Silver Limitations, included in the draft permit NC0026123. With revisions to the technical proposal received on June 30, 2023, the final study plan has been reviewed and found to be satisfactory. Approval is hereby granted for the City to conduct a silver WER in accordance with the technical proposal received on June 30, 2023. Please note that NPDES permit NCO026123 for the Asheboro W WTP has not yet been re -issued, and the City may consider deferring action on conducting the WER until issuance of the final permit has occurred since we cannot determine the final NPDES permit wording until that action. We do request at the conclusion of the WER that the consultant provide the WER checklist which will expedite the overall staff review process. The issuance of this Letter of Approval for the Study Plan does not guarantee approval of the final WER itself, since EPA Region IV will review this as part of any future permit modification (if needed). If you have any questions concerning this letter, please contact Michael Montebello at (919) 707- 3624 or at michael.montebello(ci�deo.ne.eov. Sind' ekille4W CMacltiacl AUKJt]fWh G84631431'44Fe .. Michael Montebello, Branch Chief NPDES Municipal Permitting Unit Hardcopy: NPDES Files Ecopy: DWR/Winston-Salem Regional Office DWR(Aquatic Toxicology Branch BT Solutions, LLCBeth Thompson p NndliI urolimi Ucpaimsm ofammnnnnoil Q.;.It" I Dooioo of\\mer It en....... D Q�P 512 North Sabah., Sucet 11611 Mail Sen ice('anmi 1 Ral'iah. No, l h('amInto. 37oq'I-I611 wn 919.707!)II1111 Coco, Nick A From: Grzyb, Julie Sent: Wednesday, August 16, 2023 4:30 PM To: Montebello, Michael J; Coco, Nick A Subject: Fw: [External) 1,4 Dioxane Sampling Hardship FYI - Julie Julie A. Grzyb Deputy Director, Division of Water Resources North Carolina Department of Environmental Quality Office: (919) 707-9147 1 Cell: (336) 210-8454 julie.grzyb@deq.nc.gov please note new email address Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Michael Rhoney <mrhoney@ci.asheboro.nc.us> Sent: Wednesday, August 16, 2023 2:33 PM To: Grzyb, Julie <julie.grzyb@deq.nc.gov> Subject: [External) 1,4 Dioxane Sampling Hardship CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Julie, The City of Asheboro has incurred a significant increase in sampling costs for 1,4 Dioxane. This has been a burden for our sampling budget and we would appreciate DEQ's consideration to reduce our sampling requirements for this contaminant. Thank you, D. R . ;VS Water Resources Director Water Resources Division 336-626-1201, ext: 2358 www.asheboronc.gov North Carolina MAIN STREET Community Asheboro Mum m C" nulrTw cr�r ux i�- ,' I I Iel 2016 Email correspondence to and from this sender is subject to the North Carolina Public Records Low and may be disclosed to third parties. Erna) cciresponderice to and from this address maybe subject to the North Carolina Public Records Law and maybe disclosed to third parties by an urdhorized stale official. li Table 1 Facility Name W WTP/WTP Class NPDES Permit Outfall Flow, Qw (MGD) Receiving Stream HUC Number Stream Class ❑ Apply ws Hardness wQc 7010s (cfs) 7010w (cfs) 30122 lots) QA (cfs) 1Q10s (cfs) Effluent Hardness Upstream Hardness Combined Hardness Chronic Combined Hardness Acute Data Sourcels) CHECK TO APPLY MODEL Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY t Information ❑ CHECK IF HQW OR ORW WQS Asheboro W W TP Grade IV NCO026123 001 9.000 Hasketls Creek 03030003 C 0.00 0.00 0.20 12.00 86.25 mg/L (Avg) 51.93 mg/L (Avg) 86.25 art 86.25 mg/L fluent data from DMRs from January 2018 -Aug 22, three PPAs and Hardness data provided by Permittee. Rar01 Par02 Par03 Par04 Pipes Par06l♦ Par07 Par09 Par09 Earle Parll Part Par13 Par14 Parts Parts Par17 Par19 Par19 Par20 Par21 Par22 Par23 Par24 Table 2. Parameters of Concern Name 'Nos Type Chronic H4d1, Acute PQL Units Arsenic Aquacac❑fe C 150 FW 340 ug/L Arsenic Human Health Watereupply C 10 HH/WS NIA ug/L Berylllom Aquatic Life NC 6.5 FW 65 uo/L Cadmium Aquatic Life NC 1,5031 PN 9.540E ua/L Chlorides Aquatic Life NC 230 FW mN:. Chlorinated Phenolic Compounds Water supply NC 1 A ua/L Total Phenolic Compounds Aqualte Life NC 300 A ug/L Chromium III Aqualicwe NC 324.6023 FIN 2495.4158 ua/L Chromium VI Aquatic Life NC 11 FA` 16 u9/L Chromium. Total Aquatic Lae NC N/A FW N/A pg/L Copper Aquatic Life NC 22,7043 FW 316311 ua/L Cyanide Aquatc Life NC 5 FW 22 10 ug/L Fluoride Aquatic, Life NC 1,800 FW ualL Lead Aquatic Life NC 1t6442 FW 298.8096 ug/L Mercury Aquatic Life NC 12 FIN 0.5 ng/L Molybdenum Hunan Heaps NC 2000 HH ua/L Nickel Aquatic Lae NC 106.1413 FN! 955.6324 ug/L Nickel Water Suppiy NC 25.0000 WS N/A ug/L Selenium Aquatic Life NC 5 FW 56 uu/L Silver Aquatic Life NC 0.06 FW 2.4939 ug/L Zinc Aquarc Life NC 361.8812 FW 353.9451 ug/L Bromodichloromethane Human Health C n HH ug/L Dibromochloromethane Human Heanh C z1 HH pg/L Chloroform Human Health C 2000 HH pg/L 26123 FW RPA UPDATED, input 10/13/2022 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 Use "PASTE SPECIAL H2 Use -PASTE ePECI Effluent Hardness values' then 'COP,. Upstream Hardness Values" then 'COP . Maelmum dint. . Mnihnuen dicta points = 58 points = 58 Date Data BDL=1/2DL 6/8/2017 99.8 99.8 7/12/2017 108 108 12/5/2019 86 86 12/12/2019 76 76 12/19/2019 58 58 12/23/2019 94 94 3/5/2020 84 B4 3/12/2020 88.2 88.2 3/20/2020 54.3 84.3 3/30/2020 79.4 79.4 6/24/2021 91 91 Results Slid Dev. 13.0463 Mean 86.2455 C.V. 0.1513 n 11 101h Per value 76.00 mg/L Average Value 86.25 mg/L Max. Value 108.00 mgr. Date Data BDL=1/2DL Results I 1 8/29/2016 106 106 Sid Dev. 21.5387 2 9/13/2016 40 40 Mean 51.9333 3 10/1912016 49 49 C.V. 0.4147 4 1102016 69 69 n 12 5 12/6/2016 28 28 10th Per value 34.50 mg/L 6 1/11/2017 73 73 Average Value 51.93 ni 7 2/2/2017 39 39 Max. Value 106.00 mg/L 8 3/7/2017 49 49 9 4/11/2017 53 53 10 5/10/2017 34 34 11 6/8/2017 43.7 43.7 12 7/12/2017 39.5 39.5 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 26123 FW RPA UPDATED, data 1 - 10/13/2022 8 Par02 Date 1/23/2018 2/14/2018 3/6/2018 4/18/2018 5/22/2018 6/5/2018 7/2412018 8/15/2018 9/13/2018 10/17/2018 11/6/2018 12/4/2018 1/10/2019 2/1212019 3/512019 4/16/2019 5/22/2019 6/4/2019 7/25/2019 8/6/2019 9/10/2019 10/10/2019 11/7/2019 12/5/2019 1/8/2020 2/13/2020 3/512020 4/7/2020 5/20/2020 6/2/2020 7/1412020 8/19/2020 9/15/2020 10/22/2020 11/11/2020 12/8/2020 1/13/2021 2/16/2021 3/2/2021 4/14/2021 5/21/2021 6/24/2021 7/28/2021 8/19/2021 9/14/2021 10/2712021 11/1012021 12/7/2021 1/13/2022 2/17/2022 3/8/2022 4/13/2022 5/12/2022 6/7/2022 7/18/2022 8/11/2022 Data REASONABLE POTENTIAL ANALYSIS Arsenic BDL=1/2DL 1 1 4.2 1 1 1 1 2.5 2.5 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2.5 1 1 1 1 1 1 1 1 1 1 1 1 1 1 i 1 1 1 t t t 1 1 i 1 1 1 1 1 1 1 1 Use "PASTE aPEtl Ydlue5" lM1¢n "BOP . Maalmum Oala Points = 58 Results Sid Dev. 0.5382 Mean 1.1375 C.V. 0.4731 n 56 Mull Factor= 1.01 Max. Value 4.2 ug2 Max. Pred Cw 4.2 ug/L 3 26123 FW RPA UPDATED, data 10/13/2022 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 e "PASTESPECIAL Beryllium zWes•tnan"copr . Maalmum data points = 5a Date Data BDL=112OL Results 311712016 < 1 0.5 Sid Dev. 0,0000 12/5/2019 < 1 0.5 Mean 0.5000 3/5/2020 < 1 0.5 C.V. (default) 0.6000 6/24/2021 < 1 0.5 n 4 Mult Factor = 2.59 Max. Value 0.50 ug/L Max. Pred Cw 1.30 ug/L Par04 Use "PASTE SPECIAL Cadmium values'(nen-copV- . Maximum data points = 58 Dale Data BDL=I/2DL Results 1 1/23/2018 < 0.5 0.25 Sul Dev. 0.0334 2 2/14/2018 < 0.5 0.25 Mean 0.2545 3 3/6/2018 < 0.5 0.25 C.V. 0.1313 4 4/18/2018 < 0.5 0.25 n 56 5 5/22/2018 < 0.5 0.25 6 615/2018 < 0.5 0.25 Mult Factor = 1.00 7 7/2412018 < 0.5 0.25 Max. Value 0.500 ug/L 8 8/15/2018 < 0.5 0.25 Max. Pred Cw 0.500 ug/L 9 9/13/2018 c 0.5 0.25 10 10/17/2018 < 0.5 0.25 11 11/62018 < 0.5 0.25 12 12/4/2018 c 0.5 0.25 13 1/10/2019 < 0.5 0.25 14 2/12/2019 < 0.5 0.25 15 3/5/2019 < 0.5 0.25 16 4/16/2019 < 0.5 0.25 17 5/22/2019 < 0.5 0.25 18 6/4/2019 < 0.5 0.25 19 7/25/2019 < 0.5 0.25 20 8/6/2019 < 0.5 0.25 21 9/10/2019 < 0.5 0.25 22 10/10/2019 < 0.5 0.25 23 11/7/2019 < 0.5 0.25 24 12/5/2019 < 1 0.5 25 1/8/2020 < 0.5 0.25 26 2/13/2020 < 0.5 0.25 27 3/5/2020 < 0.5 0.25 28 4/7/2020 < 0.5 0.25 29 5/20/2020 < 0.5 0.25 30 6IM020 < 0.5 0.25 31 7/14/2020 < 0.5 0.25 32 8/19/2020 < 0.5 0.25 33 9/15/2020 < 0.5 0.25 34 1022/2020 < 0.5 0.25 35 11/1112020 < 0.5 0.25 36 12/8/2020 < 0.5 0.25 37 1/13/2021 c 0.5 0.25 3B 2/16/2021 < 0.5 0.25 39 3IV2021 < 0.5 0.25 40 4/14/2021 < 0.5 0.25 41 5/21/2021 < 0.5 0.25 42 624/2021 < 0.5 0.25 43 7/28/2021 < 0.5 0.25 44 8119/2021 < 0.5 0.25 45 9/14/2021 < 0.5 0.25 46 10127/2021 < 0.5 0.25 47 11/102021 < 0.5 0.25 48 12J7/2021 < 0.5 0.25 49 1M3/2022 < 0.5 0.25 50 2/17/2022 < 0.5 0.25 51 3/8/2022 < 0.5 0.25 52 4/1312022 < 0.5 0.25 53 5/12/2022 < 0.5 0.25 54 6/7/2022 < 0.5 0.25 55 7/18/2022 < 0.5 0.25 56 8/11/2022 < 0.5 0.25 -3- 57 58 26123 FW RPA UPDATED, data 10/13/2022 REASONABLE POTENTIAL ANALYSIS Chlorides -- -- use "PASTE SPECIAL -Valdes" msd -cony' Par07 Use "PASTE SPECIAL: Total Phenolic Compounds °e1UP5 '"en CnFV Maximumd t. Maximum Date Data BDL=1/2DL Results '.mm=5: Date Data BDL=112DL Results LPOWis= 3/612018 105 105 SW Dev. 45.1468 1 6124/2021 < 20 10 SW Dev. 3.1458 6/5/2018 154 154 Mean 160.9 2 3/17/2016 < 5 2.5 Mean 5.6250 9/13/2018 137 137 C.V. 0.2806 3 1215/2019 < 10 5 C.V. (default) 0.6000 12/4/2018 137 137 n 26 4 3/5/2020 < 10 5 n 4 3/5/2019 71.5 71.5 5 6/4/2019 150 150 Mull Factor = 1.1 6 Mult Factor = 2.59 9/10/2019 178 178 Max. Value 247.0 mg/L 7 Max. Value 10.0 ug/L 1215/2019 159 159 Max. Prod Cw 276.6 mg/L 8 Max. Pred Cw 25.9 ug/L 3/5/2020 182 182 9 417/2020 100 100 10 9/1512020 247 247 11 12)8/2020 177 177 12 1/13/2021 191 191 13 2/16/2021 83.2 83.2 14 3/2/2021 101 101 15 4/14/2021 197 197 16 5/21/2021 200 200 17 6/24/2021 152 152 18 7/28/2021 180 180 19 8119/2021 202 202 20 9114/2021 223 223 21 10/27/2021 198 198 22 11/10/2021 189 189 23 12/712021 212 212 24 3/8/2022 140 140 25 6`7/2022 118 118 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 26123 FW RPA UPDATED, data 4- 10/13/2022 REASONABLE POTENTIAL ANALYSIS Pall Use"PASTE SPECIAL Chromium, Total Values" then "COPY• Copper . Maxlmum data Points = 56 Date Data BDL=112DL 1 1123/2018 < 5 2.5 2 2/14/2018 < 5 2.5 3 3/6/2018 < 5 2.5 4 4/18/2018 < 5 2.5 5 5IW2018 < 5 2.5 6 6/5/2018 < 5 2.5 7 7/24/2018 < 5 2.5 8 8/15/2018 < 5 2.5 9 9/13/2018 10.7 10.7 10 10/17/2018 9.9 9.9 11 11/62018 6A 6.4 12 12/412018 < 5 2.5 13 1110/2019 5.8 5.8 14 2/12/2019 < 5 2.5 15 3/5/2019 < 5 2.5 16 4/16/2019 < 5 2.5 17 5/22/2019 5.1 5.1 18 6/4/2019 < 5 2.5 19 7/25/2019 < 5 2.5 20 6/6/2019 < 5 2.5 21 9/10/2019 < 5 2.5 22 10/10/2019 5.4 5.4 23 11/712019 < 5 2.5 24 12/5/2019 6 6 25 1/8/2020 < 5 2.5 26 2/13/2020 < 5 2.5 27 3/5/2020 < 5 2.5 28 4/7/2020 < 5 2.5 29 5/20/2020 < 5 2.5 30 602020 < 5 2.5 31 7/14/2020 < 5 2.5 32 8/19/2020 < 5 2.5 33 9/15/2020 < 5 2.5 34 10/222020 < 5 2.5 35 111112020 < 5 2.5 36 12/8/2020 < 5 2.5 37 1/13/2021 < 5 2.5 38 2/1612021 < 5 2.5 39 3/2/2021 < 5 2.5 40 4/14/2021 < 5 2.5 41 5/21/2021 < 5 2.5 42 6/24/2021 < 5 2.5 43 7/28/2021 < 5 2.5 44 8/19/2021 < 5 2.5 45 9/142021 < 5 2.5 46 10/272021 < 5 2.5 47 11/102021 < 5 2.5 48 12/7/2021 < 5 2.5 49 1/13/2022 < 5 2.5 50 2/17/2022 < 5 2.5 51 3/8/2022 < 5 2.5 52 4/13/2022 < 5 2.5 53 5/12/2022 < 5 2.5 54 6/7/2022 < 5 2.5 55 7/1812022 < 5 2.5 56 8/11/2022 < 5 2.5 57 58 Results Std Dev. 1.6920 Mean 3.0679 C.V. 0.5515 n 56 Mutt Factor = 1.01 Max. Value 10.7 pg/L Max. Fred LW 10.8 pg/L Date Data BDL=112DL 1 1/23/2018 6.9 6.9 2 2/14/2018 6.6 6.6 3 3/612018 8 8 4 4/18/2018 6.7 6.7 5 522/2018 5.4 5A 6 6/5/2018 7.2 7.2 7 7/24/2018 5.8 5.8 8 8/15/2018 6.2 6.2 9 9/13/2018 7.5 7.5 10 10/1712018 6.1 6.1 11 11/6/2018 7.2 7.2 12 12/4/2018 7A 7.4 13 1/10/2019 9.6 9.6 14 2M2/2019 6.5 6.5 15 3/5/2019 5.6 5.6 16 4/16/2019 3.5 3.5 17 5/22/2019 5.7 5.7 18 6/4/2019 5.9 5.9 19 72512019 5 5 20 8/612019 6 6 21 9/10/2019 6.7 6.7 22 10/10/2019 9.5 9.5 23 11/7/2019 5.4 5.4 24 12/5/2019 < 10 5 25 1/8/2020 7.6 7.6 26 2/13/2020 5.6 5.6 27 315/2020 7 7 28 417/202D 5.6 5.6 29 5/20/2020 6.7 6.7 30 602020 10.4 10.4 31 7/14/2020 5.6 5.6 32 8/19/2020 5.6 5.6 33 9/15/2020 5.2 5.2 34 10/22/2020 5.4 5.4 35 11/112020 4.6 4.6 36 12/812020 5.2 5.2 37 1/1312021 5.5 5.5 38 2116/2021 3.7 3.7 39 W2112021 4.2 4.2 40 4/14/2021 6.1 6.1 41 521/2021 7.7 7.7 42 6242021 9 9 43 7/28/2021 7.7 7.7 44 8/19/2021 6.7 6.7 45 9/14/2021 7.9 7.9 46 10/272021 11.8 11.8 47 111102021 6.9 6.9 48 1217/2021 9.1 9.1 49 1/13/2022 7.3 7.3 50 2M7/2022 6.2 6.2 51 3/8/2022 5.4 5.4 52 4/13/2022 5 5 53 5/12/2022 6.1 6.1 54 617/2022 5.3 5.3 55 7/18/2022 6.2 6.2 56 8/11/2022 6 6 57 58 .5- ____ _ Use"PASTE SPECIA L Values"then"COPY" . Maxlmum data points = 5a Results Sid Dev. 1.5802 Mean 6.4946 C.V. 0.2433 n 56 Mutt Factor = 1.00 Max. Value 11.80 ug/L Max. Fred Cw 11.80 ug/L 26123 FW RPA UPDATED, data 10/13/2022 REASONABLE POTENTIAL ANALYSIS Cyanide Date Data BDL=112DL 3/6/2018 < 10 5 6/5/2018 < 10 5 9/13i2018 < 10 5 1 W412018 < 5 5 31512019 < 5 5 6/4/2019 5 5 9/10/2019 < 5 5 12/5/2019 < 5 5 3/5/2020 < 5 5 40/2020 < 5 5 9/15/2020 < 5 5 12/8/2020 < 5 5 1/13/2021 < 5 5 2/16/2021 < 5 5 302021 < 5 5 4/14/2021 < 5 5 5/21/2021 < 5 5 62412021 < 5 5 728/2021 < 5 5 8/19/2021 < 5 5 9/14/2021 < 5 5 10/27/2021 < 5 5 11/10/2021 < 5 5 12/7/2021 < 5 5 3/8/2022 < 5 5 617/2022 < 5 5 V.WeV'tM1en"copy" . zlmum data points = 50 Results Std Dev. 0.0000 Mean 5.00 C.V. 0.0000 n 26 Mult Factor= 1.00 Max. Value 5.0 ug/L Max. Pred Cw 5.0 ug/L Us,e "PFl5111SpFCIP Valves'Wmi-Copy.. Lead .Maxi lurndA. dinlc = 50 Date BDL=112DL Results 1 1/23/2018 < 2 1 Std Dev. 0.4316 2 2/14/2018 < 2 1 Mean 1.1339 3 3/6/2018 < 2 1 C.V. 0.3806 4 4/18/2018 < 2 1 n 56 5 522/2018 < 5 2.5 6 6/5/2018 < 2 1 Mult Factor = 1.01 7 7/24/2018 < 5 2.5 Max. Value 2.500 ug/L 8 8/152018 < 5 2.5 Max. Fred Cw 2.525 ug/L 9 9/13/2018 < 5 2.5 10 10/17/2018 < 2 1 11 11/6/2018 < 2 1 12 12/4/2018 < 2 1 13 1/10/2019 < 2 1 14 2112/2019 < 2 1 15 3/5/2019 < 2 1 16 4/16/2019 c 2 1 17 5/22/2019 < 2 1 18 6/4/2019 < 2 1 19 7/25/2019 c 2 1 20 8/6/2019 < 2 1 21 9/10/2019 < 2 1 22 10110/2019 < 2 1 23 11/'7/2019 < 2 1 24 12/5i2019 < 5 2.5 25 1/8/2020 < 2 1 26 2/13/2020 < 2 1 27 3/5/2020 < 2 1 28 4/72020 c 2 1 29 5/20/2020 < 2 1 30 62/2020 < 2 1 31 7/14/2020 < 2 1 32 8/19/2020 < 2 1 33 9/15/2020 < 2 1 34 10/22/2020 < 2 1 35 11/112020 < 2 1 36 12/8/2020 < 2 1 37 1/13/2021 < 2 1 38 2/16/2021 < 2 1 39 3/2/2021 < 2 1 40 4/14/2021 < 2 1 41 5/2112021 < 2 1 42 6/2412021 < 2 1 43 728/2021 < 2 1 44 8119/2021 < 2 1 45 9/14/2021 < 2 1 46 10127/2021 < 2 1 47 11110/2021 < 2 1 48 12t7/2021 c 2 1 49 1/13/2022 < 2 1 50 2/17/2022 < 2 1 51 3/8/2022 < 2 1 52 4/13/2022 < 2 1 53 5/12/2022 < 2 1 54 68/2022 < 2 1 55 711 a12022 < 2 1 56 8111/2022 < 2 1 57 58 26123 FW RPA UPDATED, data - 6 - 10/13/2022 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 Date Data BDL=112DL 1/23/2018 35.9 35.9 2/14/2018 169 169 3/6/2018 123 123 4/18/2018 21 21 5/22/2018 29.3 29.3 615/2018 67.4 67.4 7/24/2018 59.8 59A 8/15/2018 63.2 63.2 9/13/2018 272 272 10117/2018 59.9 59.9 11/6/2018 37 37 12/4/2018 92.8 92.8 1/10/2019 27.1 27.1 2/12/2019 22.3 22.3 3/5/2019 < 10 5 4/16/2019 17.6 17.6 5/22/2019 108 108 6/4/2019 25.1 25.1 725/2019 30.3 30.3 8/6/2019 28.4 28.4 9/10/2019 38.2 38.2 10/10/2019 82 82 110/2019 55.9 55.9 12/5/2019 < 50 25 1/8/2020 37.2 37.2 2/13/2020 17.2 17.2 3/5/2020 14 14 4/7/2020 21.6 21.6 5/20/2020 126 126 6/2/2020 34.8 34.8 7/14/2020 43.7 43.7 8/1912020 24 24 9/15/2020 159 159 10/22/2020 28 28 11/11/2020 15.8 15.8 12/8/2020 38.7 38.7 1/13/2021 24.1 24.1 2/16/2021 < 10 5 3/2/2021 < 10 5 4/14/2021 17.8 17.8 5/21/2021 22.1 22.1 6/24/2021 33 33 7/28/2021 22.1 22.1 8/19/2021 29.3 29.3 9/14/2021 32.7 32.7 10/27/2021 32.9 32.9 11/10/2021 125 125 12/72021 47.4 47A 1/13/2022 42.1 42.1 2/17/2022 30.3 30.3 3/8/2022 28.5 28.5 4/13/2022 43.2 43.2 5/12/2022 83.7 83.7 6/7/2022 151 151 7/18/2022 25 25 8/11/2022 40.5 40.5 Uee'PASTE SPECIAL Values'tAen'COPY' .Wa Ihum data points = 58 Results Std Dev, 49,5015 Mean 51.7125 C.V. 0.9572 n 56 Mult Factor= 1.02 Max. Value 272.0 ug/L Max. Fred Cw 277.4 ug/L _7_ 1,17 8 Par18 _ Use "PASTE SPECIAL Nickel Val uesthen'COPY- . Ma%ITVT ddta points= 5a Dale Data BDL=1/2DL Results 1 1/23/2018 < 2 1 $td Dev. 4.2677 2 2/14/2018 2.3 2.3 Mean 3.5661 3 3/6/2018 2.2 2.2 C.V. 1.1967 4 4/18/2018 2.3 2.3 It 56 5 5122/2018 < 2 1 6 6/5/2018 3.3 3.3 Mult Factor = 1.02 7 7/24/2018 < 5 2.5 Max. Value 33.0 pg/L 8 8/15/2018 < 5 2.5 Max. Pred Cw 33.7 pg/L 9 9/13/2018 33 33 10 10/17/2018 9 9 11 1 V6/2018 4.7 4.7 12 12/4/2018 3.8 3.8 13 1/10/2019 6.4 6.4 14 2/12/2019 6.3 6.3 15 3/5/2019 2.9 2.9 16 4/16/2019 2.3 2.3 17 5/22/2019 3.7 3.7 18 6/4/2019 3.1 3.1 19 725/2019 3.8 3.8 20 8/62019 3.7 3.7 21 9/102019 4.5 4.5 22 10/102019 3.9 3.9 23 11/7/2019 3.5 3.5 24 12/5/2019 < 10 5 25 1/82020 2.3 2.3 26 2/13/2020 2.5 2.5 27 3152020 5 5 28 4/7/2020 2.8 2.8 29 520/2020 2.5 2.5 30 6/2/2020 2.8 2.8 31 7/14/2020 3.9 3.9 32 6/19/2020 2.9 2.9 33 9/15/2020 3.1 3.1 34 10/2212020 4.7 4.7 35 11/112020 3.3 3.3 36 12/812020 < 2 1 37 1/13/2021 2.4 2.4 38 2M6/2021 2.1 2.1 39 302021 < 2 1 40 4/14/2021 2A 2.4 41 5/21/2021 2.8 2.8 42 6/24/2021 4 4 43 7/28/2021 3.6 3.6 44 8/19/2021 < 2 1 45 9/14/2021 2.9 2.9 46 10/272021 3.3 3.3 47 11/10/2021 2.8 2.8 48 1PJ712021 3 3 49 1/1312022 2.6 2.6 50 2/17/2022 2.3 2.3 51 3/8/2022 < 2 1 52 4/13/2022 < 2 1 53 5/12/2022 2.2 2.2 54 6/7/2022 2.2 2.2 55 7/18/2022 2.6 2.6 56 8/11/2022 < 2 1 57 58 26123 FW RPA UPDATED. data 10/13/2022 REASONABLE POTENTIAL ANALYSIS Selenium Date Data BDL=112DL 1 7/25/2019 1.5 1.5 2 8/612019 < 1 0.5 3 9/10/2019 2.1 2.1 4 10/10/2019 2.6 2.6 5 1117/2019 < 1 0.5 6 1/8/2020 1 0.5 7 2/13/2020 < 1 0.5 8 3/5/2020 < 1 0.5 9 4/7/2020 1.2 1.2 10 5/20/2020 < 1 0.5 11 6IV2020 < 1 0.5 12 7/14/2020 < 1 0.5 13 8/19/2020 < 1 0.5 14 9/15/2020 < 1 0.5 15 10/2212020 < 1 0.5 16 11/11/2020 < 1 0.5 17 12/8/2020 < 1 0.5 18 1/13/2021 < 1 0.5 19 2/16/2021 < 1 0.5 20 3/2/2021 < 1 0.5 21 4/14/2021 1.2 1.2 22 5/21/2021 1.4 1.4 23 6/24/2021 < 1 0.5 24 7/2812021 < 1 0.5 25 8/19/2021 2.1 2.1 26 9/1412021 1.4 1.4 27 10/27/2021 < 1 0.5 28 11/10/2021 < 1 0.5 29 12/72021 2 2 30 1/13/2022 1.9 1.9 31 2117/2022 < 1 0.5 32 3/8/2022 < 1 0.5 33 4/13/2022 1 1 34 5/12/2022 2.1 2.1 35 617/2022 1.6 1.6 36 7/18/2022 1.3 1.3 37 8111/2022 1.5 1.5 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Uss'PAS1E SPECIAL Values then "COPY". Maximum data Points = a Results Std Dev. 0.6416 Mean 0.9703 C.V. 0.6612 n 37 Mutt Factor = 1.14 Max. Value 2.6 ug/L Max. Fred Cw 3.0 uglL ar[U Use"PASTE SPECIAL.Values' then'COPY'. Silver Maxmum dota pdin Date Data BDL=II2DL Results 5a 1 7/25/2019 < 1 0.5 End Dev. 0.3797 2 8/6/2019 < 1 0.5 Mean 0.5973 3 9/10/2019 < 1 0.5 C.V. 0.6357 4 10/10/2019 < 1 0.5 n 37 5 11/7/2019 < 1 0.5 6 1/8/2020 < 1 0.5 Mutt Factor = 1.14 7 2/1312020 < 1 0.5 Max. Value 2.600 ug/L 8 3/5/2020 < 1 0.5 Max. Pred Cw 2.964 ug1L 9 41`7/2020 < 1 0.5 10 520/2020 < 1 0.5 11 6/2/2020 < 1 0.5 12 7/14/2020 1 0.5 13 8/19/2020 < 1 0.5 14 9/15/2020 < 1 0.5 15 10/2212020 < 1 0.5 16 1Ill V2020 < 1 0.5 17 12/8/2020 < 1 0.5 18 1/13/2021 c 1 0.5 19 2/16/2021 < 1 0.5 20 3/2/2021 < 1 0.5 21 4/14/2021 < 1 0.5 22 521/2021 < 1 0.5 23 6/24/2021 < 1 0.5 24 7/28/2021 1.2 1.2 25 IV1912021 1.3 1.3 26 9114/2021 < 1 0.5 27 10/27/2021 2.6 2.6 28 11/10/2021 < 1 0.5 29 12/7/2021 c 1 0.5 30 1113/2022 < 1 0.5 31 2/17/2022 < 1 0.5 32 3/8/2022 < 1 0.5 33 4/13/2022 < 1 0.5 34 5/12/2022 < 1 0.5 35 6,712022 < 1 0.5 36 7/18/2022 < 1 0.5 37 8111/2022 < 1 0.5 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 26123 FW RPA UPDATED, data - B - 10/13/2022 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 Zinc flee "PASTE SPECIAL Values then 'COPY' Pd22 . Maximum data points = 50 Date Data BDL-112DL Results 1/2312018 24.6 24.6 Sul Dev. 17.1465 1 2/14/2018 18.5 18.5 Mean 21.6804 2 3/6/2018 33.8 33.8 C.V. 0.7909 3 4/18/2018 18.7 18.7 n 56 4 5/22/2018 20.4 20.4 5 6/5/2018 12.5 12.5 Mull Factor = 1.01 6 7/24/2018 < 20 10 Max. Value 100.0 ug/L 7 8/15/2018 < 20 10 Max. Prod Cw 101.0 ug/L 8 9/1312018 < 20 10 9 10/17/2018 10.2 10.2 10 11/6/2018 24.9 24.9 11 12/4/2018 56.7 56.7 12 1/10/2019 82.9 82.9 13 2/12/2019 53.1 53.1 14 3/5/2019 35.1 36A 15 4/16/2019 20.5 20.5 16 5/22/2019 16.9 16.9 17 6/4/2019 < 20 10 18 7/25/2019 16.7 16.7 19 8/6/2019 25.7 25.7 20 9/10/2019 27.4 27.4 21 10/10/2019 25.2 25.2 22 11/7/2019 17.8 17.8 23 12/5/2019 34 34 24 1/8/2020 32.9 32.9 25 2/13/2020 22 22 26 3/5/2020 29 29 27 4/7/2020 13 13 28 5/20/2020 16.9 16.9 29 6/212020 24.8 24.8 30 7/14/2020 15.7 15.7 31 8/19/2020 13 13 32 9/15/2020 15.3 15.3 33 10/22/2020 20.2 20.2 34 1 V11/2020 15.2 15.2 35 1 M2020 < 10 5 36 1/13/2021 11.3 11.3 37 2M6/2021 20.2 20.2 38 3/2/2021 11.7 11.7 39 4/14/2021 17 17 40 5/21/2021 100 100 41 6/24/2021 18 18 42 7/28/2021 19.9 19.9 43 8/19/2021 10.7 10.7 44 9/14/2021 14.2 14.2 45 10/27/2021 17.8 17.8 46 11/10/2021 16.1 16.1 47 12/7/2021 16.8 16.8 48 1/13/2022 36.9 36.9 49 2/17/2022 14.3 14.3 50 3/8/2022 11.1 11.1 51 4/13/2022 < 10 5 52 5/12/2022 11.2 11.2 53 6/7/2022 < 10 5 54 7/18/2022 < 10 5 55 8/11/2022 13.3 13.3 56 9- 57 58 Use"PASTE SPECI Bromodichloromethane Vahres"than 'COP . maximum data POIntS =58 Dale Data BDL=1/2DL 3/8/2018 6.3 6.3 6/5/2018 24.4 24.4 9/13/2018 18.6 18.6 12/6/2018 < 5 2.5 3/7/2019 < 5 2.5 6/6/2019 20.6 20.6 9/12/2019 26.6 26.6 125/2019 8.94 6.94 3/5/2020 9.02 9.02 6/4/2020 19.4 19.4 9/30/2020 17.4 17.4 12/10/2020 11.7 11.7 3/4/2021 10.3 10.3 6/24/2021 26.9 26.9 9/30/2021 33.1 33.1 12/9/2021 10.7 10.7 3/10/2022 5.66 5.66 6/9/2022 36 36 Results Std Dev. 10.2278 Mean 16.1456 C.V. 0.6335 n 16 Mutt Factor = 1.44 Max. Value 36.000000 pg/L Max. Pred w 51.840000 p9/L 26123 FIN RPA UPDATED. data 10/13/2022 REASONABLE POTENTIAL ANALYSIS Dibromochloromethane Date Data BDL=1/2DL 3/8/2018 < 5 2.5 6/5/2018 7.4 7.4 9/13/2018 < 5 2.5 12/6/2018 < 5 2.5 3/7/2019 < 5 2.5 6/6/2019 6.26 6.26 9/12/2019 13 13 12/512019 < 5 2.5 3/5/2020 < 5 2.5 6/4/2020 10.1 10.1 9/30/2020 5.55 5.55 12/10/2020 < 5 2.5 3/4/2021 < 5 2.5 6/24/2021 12.2 12.2 9/30/2021 16.6 16.6 12/9/2021 8.28 8.28 3/10/2022 < 5 2.5 6/9/2022 17.2 17.2 Results Sid Dev. Mean C.V. n Use -PASTE SPECIAL -Values - then "COPY". Maximum data prlyds = 58 5.1615 6.6161 0.7801 18 Mult Factor = 1.54 Max. Value 17,200000 pg/L Max. Pred Cw 26.488000 p9/L SPECIAL-VaI Chloroform then "COPY';. MalmmO data Date Data BD' =1/2DL Results points = 58 1 3/17/2016 13.4 13.4 Std Dev. 8.4346 2 12/5/2019 19 19 Mean 21.7250 3 3/5/2020 21.1 21.1 C.V.(default) 0.60 4 6/24/2021 33.4 33.4 n 4 5 6 Mult Factor = 2.59 7 Max. Value 33.40 pg/L 8 Max. Pred Cw 86.51 pg/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 26123 FW RPA UPDATED. date 10 - 10113/2022 Asheboro WWTP NCO026123 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators MAXIMUM DATA POINTS = 58 QwiMGDI- 9.0000 WW'TPACTP Class: Grade IV I QI OS (cfs)= 0.00 IWC'. 'e IQIOS = 100 7Q I OS Ids) 0.00 IWC% it 7Q10S= 100 7QIOWfcfsl- 0.00 IWC%4P,7QIOW= 100 30Q2 (efs)= 0.20 IWC%r)30Q2-' 98.58657244 Mg. stream Flow.QAiefs)= 12.00 IW%C @ CIA = 53.75722543 Receiving Stream: Hasketts Creek HUC 03030003 Stream Class: C Outfall 001 Qw = 9 M G D COMBINED HARDNESS(me/L) Acute - 86.25 m_wL Chronic = 86.25 mg/L PARAMETER NC STANDARDS OR EPA CRITERIA f2 REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE Chronic Acute If It Del Max Pied Cw Allmvable Cw Standard Acute WWI 340.0 Arsenic C I50 FW 340 ue/i. ---150.0-- % I 4.'_ Cironic Ill No value �_Allow_a_bl_e_C, ___ _ _ _ _ _ _ _ _ _ _ _ _ _ Arsenic C 10 HH7W'S ut;1 Chronic (fiH) 18.6 No RP, Predicted Max <50%of Allowable Cw-No No value - Allowable Cw Monitoring required Acute'. 65.00 Beryllium NC 6.5 FW 65 uC'L 4 0 1.30 ___ _ __ ___ ____ _ _ _ _ _ _ _ _ _ _ _ ___ Note: n<9 CV.(defaultI Chromc: 6.50 No detects at< 1 uglL. No monitoring or limits Limited data set No 00FC7S IMax MDL - I required. Acute 9541 Cadmium NC 15031 FW 9,5406 Ile'1, 56 0 0.500 Chronic: 1.503 No RP, Predicted Max <50%of Allowable Cw - No NO DIf7'E('7lC Max MDL = I Monitoring required Acute: NO WQS Chlorides NC 230 '. 1`, mg(L 26 26 276.6 _ _ _-_ ____ _______-_-_-_-___-_______ Chronic 230.0 RP shown; apply quarterly monitoring in con)uretlan I valuelsl, Allowable Cc with toxicity tests. per 15A NCAC 02B.0211(22) Acute: NO N'QS Total Phenolic Compounds NC 300 .A ug/L 4 0 25.9 ___ _ __ ___ _ __ _ _ _ _ _ _ _ _ _ _ Note: n<9 CV (default) Chronic 31W.3 No detects at<5,< t0ug/L and< 20ugfL. No Limited data set .NO DETECTS Max MDL=20 monitoring or limits required. Acute: 2A95.4 Chromium In NC 324.6023 144' _495.4158 pg/L 0 0 N/A ___ _ _ _ Chronic: 324.E Acute: 16.0 Chromium Vl NC 11 FW 16 pg/L 0 0 N/A _ ____ __ ________________ Chronic: 1 I.0 Tot Cr value(s) 5 but < Cr VI Allowable Cw a: No monitoring required if all Total Chromium Chromium, Total NC pg/L 56 7 10.8 Max reported value = 10.7 samples are < 5 P91L or Pred. max for Total Cr Is < allowable C. for Cr VI. Acute 33,63 Copper NC 22.7043 FW 33.6311 ur1L 56 55 11.80 _ __kN;w. ____________ic: �, 70 Predicted Max a 50% of Allowable Cw- No value ,Allowable Cw )uadedy Monitoring Page 1 of 2 26123 FW RPA UPDATED, ma 10/132022 Asheboro WWTP I Outfall 001 NCO026123 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 9 MGD Acute: 22.0 e...... NC e FW 22 10 uu4. 26 0 sp __ _ _ _ _ _ _ _ _ _ ____ _ Chronic: 5 0 All results < 10 uglL considered compliant. No NODE7/:('7S Max MDL=10 monitoring or limits required. Acute: NO WQS Fluoride NC 180f) FW ug9, 0 0 N/A _ --Chronic -_—I,SOD(1-- __--_-_-_-_-_---__-._-_._ - Acute: 298.910 Lead NC 116442 FW 298.8096 ug/L 56 0 2.525 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Chfonie. I I b44 No tleteds < 2 and <5 ug/L. No morrhmm or limns NO 7)L78('7S Max MDL=5 required. Acute: NO WQS Molybdenum NC 'Otto HH ugA. 56 52 277.4 _ __ _ _ _ _ _ _ _ _ Chronic: -0 No RP, Pretlitletl Max < 50%of Allowable C. -No No value - Allowable Cw Monitoring required Acute (FW): 955.6 Nickel NC I06.1413 FW 955.6324 pg/L _______ _____________ 56 45 337 _ Chronic (FW): I(16.1 No RP, Predicted Me. -50%of Allowable Cw - No No value'- Ailm,ahlc Co Monitoring required Nickel NC 25.0000 WS pg7L----------------------_--- 1 value. ACUICI `(10 Selenium NC 5 FW 56 ug/L 37 15 3.0 _ _ _ _ ----- _ _ _ _ _ _ _ _ _ _ _ __ _____ Chronic: 50 No RP.PredIcred Max 25ti%ofAllowableCw- No slue - Allowable C, apply Quarterly Monitoring Acme: 2,494 Silver NC 0006 FW 2.4939 ug/L 37 3 2.964 -- _ _ - - - _ _ _ -_- _-_-_-_-_-_-___-_-_-_-_-_ Chronic:0.060RP shown- apply Monthly Monitoring with Limit 37 valuet s) -- .Allowable Cw Acute. 358.9 Zinc NC 361 8912 FW 3589451 ug/L 56 48 101.0 _ _ _ __ ___ ____ Chronic: 3619 NO RP. Pretlictetl Max<50%ol Allowable Cw-No No value - Allowable Cw Monitoring squired Acute: NO WQS Bromodichloromethane C 17 HH pg7L 18 16 51.84000 _ _ _ _ _ _ _ _._-_-_-_-_-_-_-_-_-__ Chronic: 31.62366 RP shown- apply Monthly Monitoring with Umif j o valuetsl > Allowable Cw Acute NO WQS Dibmmoehloromethaoe C 1_I IiH pg/L 18 9 26,49800 _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Chrome: 39.06452 No RP , Prediced Max a 50%of Allowable Cw- No value - Allowable Cw apply Quadedy Monitohng Acute: NO WQS Chloroform C 1_000 HH pgfL 4 4 86.50600 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Note: n 5 9 C. V.(default) Chrom e: 37^_0.43011 NO RP. Pretlic[etl Max<50%of Allowable Cw-No Limited data set INo value, Allowable C. Meunoriu9 rcqubed 26123 FW RPA UPDATED, ma Page 2 of 2 10/13/2022 Table 1 Facility Name W WTPNJTP Class NPDES Permit Outfall Flow, ew (NIGD) Receiving Stream Stream Class HUC Number 7010s (cfs) 7Q10w (cfs) 3002 (cfs) CA lots) IEtas lots) WS Barrier Latitude Longitude Receiving Stream Stream Class 7Q1 as lots) 7010w (cfs) 3002 (cfs) CIA (cfs) 1 Q1gs (cfs) Data Source(s) I-1 CHECK TO APPLY MODEL 2018 Generic RPA - 95% Probability/95% Confidence MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY P t l f t Tahln 9 DarnmuTere of Cnnrnrn ro/ec n orma Ion CHECK IF HQW OR ORIN Asheboro WWTP Pam GradelV Pa02 NCO026123 PaN3 Out Pe e4 9.000 Pares Haske9s Creek Pares C Paro7 3030003 Pares 0.00 Pares 0.00 Paso 0.20 Padt 12.00 — Pad2 Pans Gulf-Goldston Watershed Pad4 34.48437 Parts -79.44746 Parts Deep River Pad? WS-V; HQW Fare N/A Pads N/A Paao NIA Paai 846.00 Paa2 ` Paa3 1 4-dioxane data from July 2021 - September 2022. Paao OA used was estimated by USGS for the downstream WS-V boundary of Gulf-Goldston WS Paas watershed. 1.4-dioxane biodegradation negligible. Paa6 and concentration discharged assumed equivalent Par27 direct discharge point and downstream WS; More restrictive Cw allowable based on downstream WS- Pacts V selected Paris Follow directions for data entry. In some cases a Par30 comment menu list the available choices or Par31 dropdmvn menu will provide a list yet, may select Par32 from. Error message occur iterate entry does not meet input criteria. Name Stream Class Type Chronic ummm Acute POL Ur 1.4-Dioxane C C 80 HH 1 p9/L 1 4-Dioxare WS C 0.35 WS 1 pglL Asheboro . �.._- WWTP ' tx. `J SileiWIry .p; Asheboro 902 A Goldston-Gulf WS-V boundary Copy of 9595 GENERIC RPA2018 01 - 1.4-Dioxane. input 12/5/2022 REASONABLE POTENTIAL ANALYSIS 1,4-Dioxane vawes-men-COPY• . Maximum data Points • So Date Data BDL=112DL Results - 1 7/8/2021 88A 88.4 Sld Dev. 123.1529 2 7/16/2021 153 153 Mean 83.7071 3 7/20/2021 34.2 34.2 C.V. 1.4712 4 7/23/2021 55.7 55.7 n 58 5 7/30/2021 115 115 6 8/6/2021 334.4 334.4 Mull Factor = 1.D000 7 8/13/2021 25.2 25.2 Max. Value 636.0 pg/L 8 820/2021 55.6 55.6 Max. Pred Cw 636.0 pglL 9 827/2021 64.6 64.6 10 9/1/2021 58.9 58.9 11 9/10/2021 70.2 70.2 12 9/17/2021 63.9 63.9 13 10/1/2021 37.5 37.5 14 10/8/2021 44.5 44.5 15 10/152021 114 114 16 10/212021 548 548 17 10/292021 636 636 18 11/19/2021 5.04 5.04 19 1122/2021 10.3 10.3 20 11/5/2021 75.3 75.3 21 11/12/2021 3.82 3.82 22 11119/2021 5.04 5.04 23 11 /22/2021 10.3 10.3 24 12/3/2021 59.7 59.7 25 12/10/2021 2.7 2.7 26 12/17/2021 11.3 11.3 27 12/2V2021 2 2 28 1/7/2022 102 102 29 1/142022 26.9 26.9 30 1/20/2022 3.06 3.06 31 1/28/2022 25.2 25.2 32 2/4/2022 74.7 74.7 33 2/11/2022 107 107 34 2/18/2022 34.6 34.6 35 2/25/2022 133 133 36 3/4/2022 25 25 37 3/11/2022 136 136 38 3/18/2022 44.3 44.3 39 3/2512022 15.1 15.1 40 411/2022 46.3 46.3 41 41812022 16.75 16.75 42 4/1212022 28.7 28.7 43 4/22/2022 82.8 82.8 44 4/29/2022 11.3 11.3 45 5/6/2022 63.2 63.2 46 5/13/2022 22.8 22.8 47 5/20/2022 31.9 31.9 48 5/27/2022 135 135 49 6/3/2022 21.9 21.9 50 6/10/2022 46.5 48.5 51 6/172022 20 20 52 624/2022 144 144 53 7/812022 149 149 54 722/2022 449 449 55 8/5/2022 66.8 66.8 56 8/12/2022 33.8 33.8 57 9/16/2022 45.9 45.9 58 923/2022 25.9 25.9 Copy of 9595 GENERIC RPA2018_01-1,4-Dioxane, data - 1 - 12/5/2022 Asheboro WWTP REASONABLE POTENTIAL ANALYSIS NCO026123 2018 Generic RPA - 95%Probability/95% Confidence MAXIMUM DATA POINTS = 58 Qw(MGDI= 9.0000 Qw(MGD)= 9.0000 WWTPM?P Class Grade IV IQIOS(cfs)= 0.00 IQIOS(efs)= NO 1010s DATA IWC% in11QIOS = 100 7QIOS(cfs)= 0.00 7QIOS(cfs)= NO 70105 DATA IWC% j-1?7Q I0S= 100 7QI0W(cfs)= 0.00 7QIOW(cfs)= N07Q10WDATA IW°/nC(d 7Q 10W= 100 30Q2 (cfs) = 0.20 30Q2 (cfs) = NO 30Q2 DATA IWC% n. 30Q2 = 98.5865724 Avg. Stream Flow. 12 00 Avg. Stream Flow. 646.00 IWC% Of QA = 53.7572254 QA (cfs)= QA(cfs)= ' Hasketts Deep River fiverStream Receiving Stream: Creek HUC Receiving Stream: HUC 3030003 Class: C 3030003 Outfall 001 Qw = 9 MGD WWTP/WTP Class: Grade IV IWC% n IQIOS = NIA IWC%f17QIOS= NIA IW%C n.. 7QIOW = NIA IWC% 0 30Q2 = NIA IWC% 0r QA= 1.622187336 Stream Class: WS-V; HOW PARAMETER NC STANDARDS OR EPA CRITERIA I REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE g n Chronic Applied Standard Acute D # Det. Max Pred Cw Allowable Cw Acute: NO WQS 1,4-Dioxane C 80 HH(Qavg) I Itg/L 58 58 636.0 _ _ _ ___ _____ _ _ _ Chronic' 148 82 Less stringent than protection M 6 valuel s)>Allowable Ca downstream water uses. Apply\NS Acute: NO WQS 1,4-Dtoxane C 0.35 WS(Qavg) 1 µg/L 58 58 636.0 _ _-_-_ _ ___ _ _ _-_-_ _ Chronic: 21.58 RP shown- apply limit wth Monthly 45 value s)> Allowable Cw Monitoring Copy of 9595 GENERIC RPA2018_01 - 1.4-Dioxone, rps Page i of 1 12/52022 Reduction in Frequency Evalaution Facility: Asheboro WWTP Permit No. NC0026123 Review period -: 08/2018 - 07/2021 (use 3 yrs) Approval Criteria: Y/W 1. Not currently under SOC 1W Y 2. Not on EPA Quarterly noncompliance report 3. Facility or employees convicted of CWA violations Weekly Monthly 50% 3-yr mean 200% p daily p dolly 200% it of non - monthly M civil penalty Reduce Data Review Units average limit average MA (geo mean < 50%7 MA samples <15? samples < 207 WA Ilatit > 2? asessment > 1? Frequency? limit for FC) >200% >200% (yes/No) violations BOD(weighted) mg/L 8.5 5.66667 2.8 1.8087015 Y 11.3 0 Y 0 N O 0- N N Y y TSS mg/L 45 30 15 0.6311432 Y 60 0 Y 0 N NH3 (weighted) mg/L 4 1.33333 0.7 0.1313479 Y 2.67 3 `! 0 N 0 N Y Fecal Coliform #/100 400 200 100 6.3818497 Y - __.. _- _. _ _ _ ., 800 0 1 v 0 N 0 N Y 10/13/22 WQS= 12 ng/L Facility Name Asheboro WWTP/ NC0026123 /Permit No. Total Mercury 1631E PQL = 0.5 ng/L Date Modifier Data Entry Value MERCURY WQBEL/TBEL EVALUATION V:2013-6 No Limit Required MMP Required 7Q10s = 0.000 cfs WQBEL = 12.00 ng/L Permitted Flow = 9.000 47 ng/L 1/11/18 < 1 0.5 2/8/18 3 3 3/8/18 1.1 1.1 4/5/18 1.2 1.2 5/3/18 2.8 2.8 6/7/18 1.6 1.6 7/12/18 1.6 1.6 8/9/18 1.2 1.2 9/13/18 3.5 3.5 10/4/18 1.8 1.8 11/8/18 1.7 1.7 12/6/18 < 1 0.5 1.7 ng/L - Annual Average for 2018 1/10/19 2.9 2.9 2/7/19 1.3 1.3 3/7/19 2.5 2.5 4/4/19 2.7 2.7 5/2/19 < 1 0.5 6/6/19 1.1 1.1 6/27/19 1.3 1.3 7/11/19 1.7 1.7 8/8/19 < 1 0.5 9/12/19 < 1 O.S 10/3/19 < 1 0.5 11/7/19 < 1 0.5 12/19/19 2.1 2.1 1.4 ng/L- Annual Average for 2019 1/9/20 1.7 1.7 2/6/20 2.3 2.3 3/5/20 2.3 2.3 4/9/20 1.5 1.5 5/7/20 < 1 0.5 6/4/20 3.3 3.3 7/9/20 2.6 2.6 8/6/20 < 1 0.5 9/17/20 1.4 1.4 10/8/20 < 1 0.5 11/5/20 1.1 1.1 12/10/20 < 1 0.5 1.5 ng/L - Annual Average for 2020 1/7/21 1.1 1.1 2/4/21 < 1 0.5 3/4/21 < 1 0.5 4/8/21 1.5 1.5 5/6/21 3.6 3.6 6/25/21 1.4 1.4 7/8/21 < 1 0.5 8/5/21 < 1 0.5 9/16/21 < 1 0.5 10/7/21 1.3 1.3 11/4/21 2.2 2.2 12/9/21 1.8 1.8 1.3 ng/L - Annual Average for 2021 1/13/22 1.4 1.4 2/3/22 1.3 1.3 3/10/22 1.8 1.8 4/7/22 < 1 0.5 5/5/22 4.6 4.6 6/9/22 < 1 0.5 7/7/22 < 1 0.5 8/4/22 1 1 1.5 ng/L - Annual Average for 2022 Asheboro WWTP / NCO026123 Mercury Data Statistics (Method 1631 E) 2018 2019 2020 2021 2022 # of Samples 12 13 12 12 8 Annual Average, ng/L 1.7 1.4 1.5 1.3 1.5 Maximum Value, ng/L 3.50 1 2.90 1 3.30 1 3.60 1 4.60 TBEL, ng/L 47 WQBEL, ng/L 12.0 IWC Calculations Facility: Asheboro WWTP NCO026123 Prepared By: Nick Coco Enter Design Flow (MGD): 9 Enter s7Q10 (cfs): 0 Enter w7Q10 cfs : 0 Total Residual Chlorine (TRC) Ammonia (Summer) Daily Maximum Limit (ug/1) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 0 s7Q10 (CFS) 0 DESIGN FLOW (MGD) 9 DESIGN FLOW (MGD) 9 DESIGN FLOW (CFS) 13.95 DESIGN FLOW (CFS) 13.95 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22 IWC (%) 100.00 IWC (%) 100.00 Allowable Conc. (ug/1) 17 Allowable Cone. (mg/1) 1.0 Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 0 Monthly Average Limit: 200/100mo DESIGN FLOW (MGD) 9 (If DF >331; Monitor) DESIGN FLOW (CFS) 13.95 (If DF<331; Limit) STREAM STD (MG/L) 1.8 Dilution Factor (DF) 1.00 Upstream Bkgd (mg/1) 0.22 IWC (%) 100.00 Allowable Cone. (mg/1) 1.8 Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Cone > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I 4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/l (winter) 5. BAT for Major Municipals: 1 mg/I (year-round) Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NCO026123 Asheboro WWTP 10/13/2022 BOD monthly removal rate TSS monthly removal rate Month RR (%) Month RR (%) Month RR (%) Month RR (%) January-18 97.82 July-20 99.30 January-18 96.47 July-20 99.02 February-18 97.96 August-20 99.25 February-18 97.29 August-20 99.04 March-18 97.92 September-20 99.34 March-18 97.50 September-20 98.89 April-18 98.69 October-20 99.23 April-18 98.24 October-20 99.01 May-18 99.04 November-20 99.13 May-18 98.71 November-20 99.01 June-18 99.27 December-20 98.63 June-18 99.07 December-20 98.44 July-18 99.44 January-21 98.92 July-18 99.43 January-21 98.73 August-18 99.22 February-21 98.40 August-18 99.30 February-21 97.50 September-18 98.97 March-21 98.50 September-18 98.20 March-21 97.74 October-18 98.98 April-21 98.61 October-18 98.02 April-21 97.96 November-18 98.59 May-21 98.77 November-18 97.53 May-21 97.72 December-18 98.36 June-21 99.14 December-18 96.89 June-21 98.60 January-19 98.63 July-21 99.25 January-19 97.09 July-21 98.75 February-19 98.20 August-21 99.29 February-19 97.45 August-21 99.22 March-19 98.16 September-21 99.26 March-19 97.45 September-21 99.03 April-19 98.90 October-21 99.26 April-19 98.31 October-21 98.79 May-19 99.19 November-21 99.33 May-19 99.03 November-21 98.20 June-19 99.16 December-21 99.09 June-19 99.16 December-21 97.81 July-19 99.26 January-22 98.34 July-19 99.25 January-22 96.50 August-19 99.32 February-22 98.88 August-19 99.35 February-22 98.15 September-19 99.40 March-22 98.44 September-19 99.36 March-22 96.85 October-19 99.33 April-22 98.92 October-19 99.24 April-22 98.36 November-19 99.14 May-22 99.20 November-19 99.11 May-22 98.79 December-19 98.80 June-22 99.36 December-19 97.42 June-22 99.27 January-20 98.48 July-22 99.63 January-20 96.59 July-22 99.44 February-20 97.82 August-22 99.53 February-20 96.13 August-22 99.44 March-20 98.35 September-22 March-20 97.04 September-22 April-20 98.74 October-22 April-20 97.57 October-22 May-20 98.73 November-22 May-20 97.33 November-22 June-20 99.14 December-22 June-20 98.36 December-22 Overall Boo removal rate 98.89 Overall TSS removal rate 98.21 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 1N 1 2 15 1 3 1 NCO026123 111 12 22/05/10 Pi 19 I s I 201 I 17 18 I 21111111 1 11111111 11 111 1111 1 1 11 111 111111111 1 1 r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA ------ ---------------- Reserved ------- ----------- 67 701 I 711 I 72 L ti j 73L I I74 79 I I I I I I I80 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 Dermit Number) 10:OOAM 22/05/10 12/08/01 Asheboro WWTP Exit Time/Date Permit Expiration Date 1032 Bonkemeyer Dr Asheboro NC 27203 12:OOPM 22/05/10 16/09/30 Name(s) of Onsite Representative(s)Mtles(s)/Phone and Fax Number(s) Other Facility Data 111 Name, Address of Responsible Official/Title/Phone and Fax Number Contacted John N Ogburn,PO Box 1106 Asheboro NC 272041106/City Manager/336-626-1213/3366261218 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Pretreatment Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Patricia Lowery DWR/WSRO WQ/336-776-9691/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO026123 I1 1 22/05/10 17 18 U Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On May 10, 2022, a Pretreatment Compliance Inspection (PCI) was performed by Tricia Lowery of the Winston-Salem Regional Office. Sarah Laughlin and Bobby Crandall was present for the inspection. The purpose of this inspection was to determine the effectiveness of the Asheboro's pretreatment program, which includes reviewing the files, POTW plant performance, industry monitoring data, and adherence to the enforcement response plan (ERP). Background This is a 9.0 MGD permitted facility. The city has 14 Significant Industrial Users (SIUs), 7 of which are categorical. The publicly owned treatment works (POTW) had no pretreatment related violations in 2021. POTW Interview There are no plant problems related to pretreatment issues. Weekly dioxane sampling with DEQ-DWR is ongoing and conducted every Friday. No SIU's were SNC for 2021. The pretreatment program has 33 dental offices and all in are compliance with program. Pretreatment Program Elements Review The Headworks Analysis (HWA) was last approved on 6/30/2017. The next HWA is due 6/l/2022. The IWS was last approved on 5/8/2018. The next IWS is due 4/15/2023. The Sewer Use Ordinance (SUO) was approved on 11/5/2012. The Enforcement Response Plan (ERP) was submitted on 1/12/2020 and approved on 2/5/2020. The Long -Term Monitoring Plan (LTMP) was submitted 2/18/2020 and approved on 5/7/2020. LTMP File Review The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies (2/year). Industrial User Permit (IUP) File Review A review of the file for Covanta (#5049) revealed that the monitoring data was well organized and compliant. A review of the file for Bossong (#0822) revealed that the monitoring data was well organized and compliant. A review of the file for Premier Power Coating (#3734) revealed that the monitoring data was well organized and compliant. The slug control plan for Covanta (#5049) was in good order. The slug control plan for Bossong (#0822) was in good order. The slug control plan for Premier Power Coating (#3734) was in good order. Action Items No other action items were noted. Page# 2 Permit: NC0026123 Owner - Facility: Asheboro WvvrP Inspection Date: O5/10/2022 Inspection Type: Pretreatment Compliance Yes No NA NE Page# 1 Pollutants of Concern (POC) Review Form^^•• • • n:.X 2 1. Facility's General lnlomallon J ualardO c— li R.11 G POC Tall —Ow lo: a Ctudci lulu ualn 4 OYed l4dl Pavax 0: 12L023 Nueciallul rvs1 0 MW:tl.'sel, WmbPSgmr SruiDlv nuv lRr) N. Cw.v 4.5TM1iMP Pwew Q PO PISW P--a Lernry OXIgEe AN Nra lure 6 a'l Nano 4ch .WN•R Nw FWs41¢ Q I., IR SM, m�Y Sar31 Lm:MyF. pxwJln6d 2 .PoCt Purl NunW N ctd 23 WiP nrmaYn 0 I. 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NC000O892/OO1 County: Chatham Region: RRO Basin: CPFO7 Feb May Aug Nov Ceri7dPF Begin: 7/1/2013 chr lim: 0.39% + NonComp: Single 7013O: 40.0 PF: 0.10 IWC: 0.39 Freq: Q J F M A M J 1 A S 0 2018 - Pass - Pass - Pass Pass M19 Pass - Pass - - Pass - M20 - Pass - Pass - - Pass - "n - Pass - Pass Pass 2022 Pass Pass - - - - Ardagh Glass NCOO83O38/OO1 County: Vance Region: RRO Basin: TARO2 Fthd24Ac Begin: 5/1/2015 ANNUAL: 24hr LC5O NonComp: 7Q1O: 0 PF: 0.50 IWC: 100.0 Freq: A J F M A M J J A S 0 2020 - - - H - - 2021 H 2022 H - Asheboro WWTP NCO026123/OO1 County: Randolph Region: WSRO Basin: CPFO9 Mar Jun Sep Dec Ceri7dPF Begin: 8/1/2012 chr lim: 9O% NonComp: Single 701O: 0.0 PF: 9.0 IWC: 100 Freq: Q J F M A M J I A S 0 pig - - Pass - Pass - - >100IPI Pass - 2019 - - Pass - - Pass - - Pass - N20 - Pa. 100(P) - - Pau - - Pass - 2021 - Pass Pass >100IPI - - Pass - W22 - Pass Pass - - - - Asheville DeBruhl WTP NCOO56961/001 County: Buncombe Region: ARO Basin: FR802 Jan AprJul Oct Ceri7dPF Begin: 4/11/2017 chr monit: 29%(Grab NonComp: Single 7Q1O: 1.1 PF: 0.1 IWC: 12.3 Freq: Q J F M A M J 1 A S O 2019 Pass Pass Pass - - Pass 2019 Pass - Pass Pass - - Pass 2020 Pass - Pa. Pass - - Pas 2021 Pass - - Pass Pass - - Pass 2022 Pass - Pass - Pass - - - Asheville Northfork WTP NCO035807/OO1 County: Buncombe Region: ARO Basin: FRBO2 Jan Apr Jul Oct Ceri7dPF Begin: 4/1/2017 chr Monit: 22% NonComp: Single 701O: 1.7 PF: 0.8 IWC: 42.2 Freq: Q J F M A M J J A S O "18 Pass - Pass - Pass Pass M19 pass - Pass - - Pass - Pass 2020 Pass Pass - Pass Pass 2021 Pass - - Pass - Pass - Pass 2022 Pass - Pass Pass - SOC_JOC: N D Pass Pass Pass Pass SOC JOC: N D SOC JOC: N D Pass Pass>100IPI Pau Pass SOC_JOC: N D SOC iOC: N D Legend: P= Fathead minnow IPimphales oromelas). H=No Flow (facility is active), 5 = Split test between Certified labs Page 5 of 117 NORTH CAROLINA 2022 INTEGRATED REPORT Deep Cape Fear River Basin AU Name AU Number Classification AU LengthArea AU Units AU ID Description DEEP RIVER 17-(10.5)b C 2.2 FW Miles 4126 From US 220 business to Subbasin 03-06-08 and 03-06-09 boundary 12022 Water Quality Assessments PARAMETER IRCATEGORY CRITERIA STATUS Water Temperature (329C, AL, LP&CP) 1 Meeting Criteria Dissolved Oxygen (4 mg/I, AL, FW) 1 Meeting Criteria pH (6 su, AL, FW) 1 Meeting Criteria pH (9.0, AL, FW) 1 Meeting Criteria Turbidity (50 NTU, AL, FW miles) 1 Meeting Criteria Chloride (230 mg/I, AL, FW) 3a Data Inconclusive Flouride (1.8 mg/I, AL, FW) 3a Data Inconclusive 1,4-Dioxane in Water (80 µg/I, AL, FW) 3a Data Inconclusive Fecal Coliform (GM 200/400, REC, FW) 3a Data Inconclusive — J DEEP RIVER 17-(10.5)dl C 2.7 FW Miles 4128 From Haskett Creek to Gabriels Creek 2022 Water Quality Assessments Water Temperature (322C, AL, LP&CP) Dissolved Oxygen (4 mg/I, AL, FW) pH (6 su, AL, FW) pH (9.0, AL, FW) Turbidity (50 NTU, AL, FW miles) Fecal Coliform (GM 200/400, REC, FW) (Chlorophyll a (40 µg/I, AL, NC) IR CATEGORY 1 1 1 1 1 3a 5 CRITERIA STATUS Meeting Criteria Meeting Criteria Meeting Criteria Meeting Criteria I Meeting Criteria Data Inconclusive Exceeding Criteria 6/7/2022 NC 2022 INTEGRATED REPORT -Category 5 Approved by EPA 4/30/2022 Page 108 of 1346 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN 1 2 U 3 I NCO026123 I11 121 22/01/27 117 18 I r, I 19 I S I 201 I 21I111II IIIIIII1lllIll IIII.I IIIIII IIIIII1IIII r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA-------------Reserved -- --------- ----- 6770 L_j 71 I I 72 I ti I 73I L J74 79 I I I I I I I80 ---- 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 uermit Number) 10:30AM 22/01/27 12/08/01 Asheboro WWTP Exit Time/Date Permit Expiration Date 1032 Bonkemeyer Dr Asheboro NC 27203 12:10PM 22/01/27 16/09/30 Name(s) of Onsite Representative(s)Mtles(s)/Phone and Fax Number(s) Other Facility Data 111 Name, Address of Responsible Official/Title/Phone and Fax Number Contacted John N Ogburn,PO Box 1106 Asheboro NC 272041106/City No Manager/336-626-1213/3366261218 Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit N Flow Measurement Operations & Maintenar N Records/Reports Self -Monitoring Progran 0 Facility Site Review Effluent/Receiving Wate Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Alex Lowe DWR/WSRO WQ/336-776-96891 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 (Cont.) NCO026123 I11 12 22/01/27 117 181C, Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On January 27, 2022, Alex Lowe of the WSRO conducted a routine Compliance Evalauation Inspection at the City of Asheboro VW TP. ORC Mike Wiseman was present throughout the inspection. In the interview with Mr. Wiseman, the state of the POTWs permit was discussed. A current permit is in administrative review, but is awaiting the results of the Cape Fear study. A review of three randomly chosen months of laboratory data and DMR submissions found all data to be properly reported. The POTW permit is currently expired, and the renewal application is under administrative review. It is not expected to be approved until the completion of the Cape Fear study on emerging contaminants. A tour of the facility with Mr. Wiseman demonstrated a well -maintained system, and no operational issues were uncovered. With influent flows of only 33%-50% of maximum design rate, proper steps are being made to ensure retention time and thorough treatment are being achieved. This facility was found to be in permit compliance. Page# Permit: NCO026123 Owner - Facility: Asheboro WVVrP Inspection Date: 01/27/2022 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new e ❑ ❑ ❑ application? Is the facility as described in the permit? M ❑ ❑ ❑ # 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? M ❑ ❑ ❑ Comment: Permit awaiting results from the Cape Fear study. Permit renewal underway. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 00011 Is all required information readily available, complete and current? M ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? M ❑ ❑ ❑ Is the chain -of -custody complete? M ❑ ❑ ❑ Dates, times and location of sampling ❑ Name of individual performing the sampling ❑ Results of analysis and calibration ❑ Dates of analysis ❑ Name of person performing analyses ❑ Transported COCs ❑ Are DMRs complete: do they include all permit parameters? 0 ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? M ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified M ❑ ❑ ❑ operator on each shift? Is the ORC visitation log available and current? 0 ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ■ ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility M ❑ ❑ ❑ classification? Is a copy of the current NPDES permit available on site? M ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? 0 ❑ ❑ ❑ Comment: All DMRs and lab data kept for at least five years (observed folders dated back to 2012). Random spot checks of DMRs and laboratory results for three months in 2021 demonstrates accurate reporting of effluent parameters. Page# 3 Permit: NCO026123 Owner - Facility: Asheboro WWTP Inspection Date: 01/27/2022 Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE Type of bar screen a.Manual ❑ b.Mechanical Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? M ❑ ❑ ❑ Is disposal of screening in compliance? M ❑ ❑ ❑ Is the unit in good condition? 0 01311 Comment: Grit Removal Yes No NA NE 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? 0 ❑ ❑ ❑ Comment: Grit removal by vortex. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected above side streams? 0 ❑ ❑ ❑ Is proper volume collected? ■ ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 0 ❑ ❑ ❑ degrees Celsius)? Is sampling performed according to the permit? N ❑ ❑ ❑ Comment: Temperature of auto sampler kept below 6 C. Temperature readinq last calibrated March 12, 2021. Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? M ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Page# 4 Permit: NC0026123 Inspection Date: 01/27/2022 Owner - Facility: Asheboro yW TP Inspection Type: Compliance Evaluation Equalization Basins Yes No NA NE Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 01300 Are audible and visual alarms operable? 0 ❑ ❑ ❑ # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment: Primary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? M ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? ❑ ❑ ❑ Is the site free of weir blockage? ❑ ❑ ❑ Is the site free of evidence of short-circuiting? M ❑ ❑ ❑ Is scum removal adequate? M ❑ ❑ ❑ Is the site free of excessive floating sludge? M ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? M ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) 0 ❑ ❑ ❑ Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? M ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? N ❑ ❑ ❑ Is the site free of evidence of short-circuiting? N ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? N ❑ ❑ ❑ Is the drive unit operational? N ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) N ❑ ❑ ❑ Comment: Three final clarifiers on site, only two running to increase retention time. Page# 5 Permit: NCO026123 Owner - Facility: Asheboro VWVrP Inspection Date: 01/27/2022 Inspection Type: Compliance Evaluation Trickling Filter Yes No NA NE Is the filter free of ponding? 0 ❑ ❑ ❑ Is the filter free of leaks at the center column of filter's distribution arms? 0 ❑ ❑ ❑ Is the distribution of flow even from the distribution arms? 0 ❑ ❑ ❑ Is the filter free of uneven or discolored growth? N ❑ ❑ ❑ Is the filter free of sloughing of excessive growth? N ❑ ❑ ❑ Are the filter's distribution arms orifices free of clogging? 0 ❑ ❑ ❑ Is the filter free of excessive filter flies, worms or snails? N ❑ ❑ ❑ Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? ■ ❑ ❑ ❑ Are surface aerators and mixers operational? 0 ❑ ❑ ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? N ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ Comment: Three 40 HP blowers on site for each aeration tank. All in working order at time of inspection. Disinfection -Liquid Yes No NA NE Is there adequate reserve supply of disinfectant? ❑ ❑ ❑ ❑ (Sodium Hypochlorite) Is pump feed system operational? ❑ ❑ ❑ ❑ Is bulk storage tank containment area adequate? (free of leaks/open drains) ❑ ❑ ❑ ❑ Is the level of chlorine residual acceptable? ❑ ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? ❑ ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ ❑ Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? N ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? N ❑ ❑ ❑ Page# 6 Permit: NCO026123 Inspection Date: 01/27/2022 Effluent Pipe Owner - Facility: Asheboro WVVTP Inspection Type: Compliance Evaluation If effluent (diffuser pipes are required) are they operating properly? Comment: Flow over steps to aerate. No residual foaming 150 feet downstream. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment: Ultrasonic flow meter used as primary effluent flow recorder. Yes No NA NE ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ■ ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Page# 7 9/8/2021 Mail - Perlmutter, Gary - Outlook USGS response to DWR USGS Low Flows request # 2021-145 (dated 2021/08/13) for Deep River Moore County... RE: [EXTERNAL] Low - Row request approval Weaver, John C <jcweaver@usgs.gov> Wed 9/B/2021 1129 AM To: PadmuMn Gary<gary.penmutter@mdenr.gw> Cc Hal, David A <daidhdllaincdenrgw>; Kebad4 Adugna <adugna.kebede@mder.gw>; Montebello, Michael I <MichaaLMontebello@ncdenrgw>; Do vdan, Doug <daug.doadem®nrtlercgw>; AIbe6A Klaus P lde.ftertmilmade.gw>; Weavar, Jahn C ckvinver®usgsgw> CALMOW Extemal email. Do not dick links or ones attachments unlesswu verity. Send all wspidoos email as an attachment to Mom Mile, Gary, In response to your Inquiry about the low -flow characteristics for a location on the Deep River adjacent to the end of NC Secondary Road 1617 (Trivett Road) near Glendon in northeast Moore County, the following Information Is provided: A check of the low -flow files here at the USGS South Atlantic Water Science Center (SAWSC, Raleigh office) does not indicate a previous low -flow determination for the point of Interest, Identified by the adjusted lat/long coordinates (35.48437,-79.44746) associated with the email dated 08/13/2021 from the DWR USGS Low Flow portal following your request submission. No USGS discharge records are known to exist for the point of interest In the absence of site -specific discharge records sufficient for a low -Flow analysis, estimates of low -flow characteristics at ungaged locations would be determined by assessing a range In the low -Flaw yields (expressed as flow per square mile drainage area, or cfsm) at nearby sites where estimates have previously been determined. A basin delineation completed using the online USGS StreamStats application for North Carolina (bites://streamstats.usgs,gov/S;Q Indicates the drainage area for the point of Interest (Stream5tats adjusted coordinates 35.48437,-79.44747 NAD83) is 853 sgml, which confirms the drainage area submitted as part of the request Information. For the record: (1) The low -flow estimates provided below are patterned after an Identical approach used earlier this year to respond (via emails dated February 23, 2021) to two separate low -flow requests (11108 and #110) for the Deep River. (2) The low -flow estimates provided below do not account for the presence of the upstream High Falls dam and the impounded reach on the Deep River upstream from this dam. Please be aware the USGS techniques used to provide estimated low -flow discharges for streams and rivers are not applicable to impounded reaches. The estimated low -flow discharges would not be meaningful for impounded reaches where the storage characteristics and circulation patterns of the Impoundment are additional components of the flow dynamics within these streams and rivers. For streams In northern Moore County, low -flow characteristics published by the USGS are provided In the following reports: (1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "low -Flow characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report Is available at bI1R:/LpgbylysgygDYLwsp/2403/rEpDMW. The report provides the low -flow characteristics (based on data through 1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sgmi and not considered or known to be affected by regulation and/or diversions. (2) The second is a basin -wide report for the Cape Fear River basin published in 2D01. it is USGS Water -Resources Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear River Basin, North Carolina, through 1998"(Weaver and Pope, 2001). An online version of the report is available through b(tn://nc.watecusgyggyLrgporU/wr'014094/. The report provides the low -flow characteristics (based on data through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The report also provides low -flow discharge profiles QQ10, 30Q2, winter 7Q10, and 7012) for the Cape Fear River and selected tributaries within the basin. (3) The third Is a statewide report published in March 2015. It Is USGS Scientific Investigations deport 2015-5001, "Low -flow characteristics and flow-0uration statistics for selected USGS continuous -record streamgaging stations in North Carolina through 2012" (Weaver, 2015). The report is available online at bttp;Upubs.usgs.gov/sid201S/5001/. The report provides updated low -flow characteristics and flaw -duration statistics for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum of 30 climatic years discharge records were available for flow analyses. Low -flow characteristics estimated for point of Interest: The USGS SAWSC currently operates two streamgages on the Deep River having long-term continuous records of discharge. The upstream active streamgage is an the Deep River at Ramseur In Randolph County (station id 021D0500, drainage area 349 sgmi) with discharge records dating back to the 1923 water year. The downstream active streamgage Is an the Deep River at Marcum in Lee County (station id 02102000, drainage area 1,434 sgmi) with discharge records dating back to the 1930 water year. The USGS also operated a discontinued continuous -record streamgage from July 1993 through September 1996 on the Deep River near Glendon In Lee County (station Id 0210106600, drainage area 859 sgml). Because of the short-term record avallable for this site, low -flow techniques applicable to continuous -record streamgages with a minimum of 10 climatic years record cannot be applied to this streamgage. However, low -flow techniques applicable to pardal-record sites are applicable to this streamgage. A MOVE.1 analysis (Helsel and Hirsch, USGS Techniques and Methods 4-A3, published 2020) can be completed for a correlation between two streamgages, In which discharge records at the short-term site are correlated with the discharge records at the long-term streamgage. (a) Two MOVE.1 analyses were completed. The first analysis correlated the daily mean discharges for July 1993 through September 1996 between the Ramseur and Glendon streamgages (correlation coefficient 0.9). The second analysis correlated the daily mean discharges for the same period between the Glendon and Moncure streamgages (correlation coefficient 0.963). httpsJ/oufiook.of w365,mnVmalllnboxRd/AAQkADRJNGZkNGYwLWNJGTctNGQ4MS1 hZDQ3LWJJMGMOYmRiN2M3NWAQADGLyKwk3UB4v%2FIR... 113 9/8/2021 Mail - Perlmutter, Gary- Outlook (b) Using the published low -flow characteristics (Weaver, 2015) at the Ramseur and Moncure streamgages, each of the MOVE.1 equations were used to compute the estimated low -flow characteristics for the discontinued Glendon streamgage. Using the respective drainage areas at the three streamgages, the equivalent low -flow yields(dsm) were then determined for the low -flow characteristics at the three streamgages. For the discontinued Glendon streamgage,the final provisional unit low - flow yields were averaged from the two separate MOVER analysis results, (c) The unit low -flow yields for the point of interest were then pro -rated on the basis of drainage area between the average yields at the discontinued Glendon streamgage and yields for the upstream Ramseur streamgage. (d) The drainage area for the point of Interest (853 sqmi) was then applied to pro -rated low -flow yields to determine the estimated low -flow discharges (in cubic feet per second, or cfs). The resulting low -flow discharges estimated for the point of interest are as follows: Annual 7Q10 discharge = 19.5 cis (equivalent to 0.0228 cis per sqmi) Annual 30Q2 discharge = 78.2 cis (equivalent to 0.0917 cfs per sqml) Winter 7Q10 discharge = 39.3 cis (equivalent to 0.0461 cfs per sqmi) Annual 7010 discharge = 50.0 cfs (equivalent to 0.0586 cfs per sqml) NOTE; Given the close proximity of the point of interest (853 sqmi) to the downstream discontinued continuous -record streamgage near Glendon (859 sqml), the above estimated low -flow characteristics are practically Identical to the low -flow characteristics determined for the streamgage. Reference table for above -described analysis steps: USGS station Drainage area (sqml) 7Q10 (Cfs) 7Qi0(dsm) 30Q2 I (cfs) 3OQ2 (cfsml W7Q10 (cfs) 'N7Q30 (cfsm) 7Q2 (d5l 7t12 (dsm) Comment 021DDSDD 349 13 0.0372 46 0.1318 26 0.0745 30 0.0860 USGS SIR 2015-5001(Weave, Point of Interest 853 19.5 0.0228 78.2 0.0917 39.3 0.D461 50.0 0.0586 Low -flow yields pro -rated by 0210106600 859 19.5 0.0227 80.4 0.0936 42A 0.0494 49.8 0.0590 Based on MOVE.1 analysis u 0210106600 859 19.4 0.0226 76.3 0.0988 36.2 0.0421 50.3 0.0586 Based on MOVE.1 analysis u. Average 195 0.0226 78A 0.0912 39.3 0.0458 50.1 0.0583 For the average annual discharge, an average unit flow was determined for the mean daily discharges published in Table 5 on page 77 of USGS SIR 2015-5001 for the six sites within the Deep River basin (site Index numbers 192, 193, 196, 197, 200, 202, and 203). The average unit flow was computed to he 0.9914 cis per sqmi drainage area. Average annual discharge = 846 cfs (equivalent to 0.9914 cis per sqmi) Please note: (1) The estimated flows are provided in units of cubic feet per second ids). (2) The Information provided In this message Is based on a preliminary assessment and considered provisional, subject to revision Wilding collection of future data and further analymi. These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between the USGS and the N.C. Department of Environmental Quality, Division of Water Resources. Hope this Information is helpful. Thankyou. Curtis Weaver 1. cuNY weaver, Hydmlo9Yp P6 Emtll:)ntna W. ps.por uses South U..U. Water 5dance Center MIMe: l:((nw//www.ya9p,f North Caroline - south Camene - Gaer9N 3916 Sunset Ald9e Raed NWO,dh,W 27697 Pomp: (111) 571-ae43 // fas: (910) 571 e"l From: Albertin, Klaus P <klaus.albertin@nctlencgov> Sent Friday, August 13, 202110;27 AM To: Perlmutter, Gary %ary.perlmutter@ncdenngov> Cc: Albertin, Klaus P <klauseIbertln@ncdenrgov>; Hill, David A <david.hlll@ncdencgov>; adugna.kebede@nodencgov; Weaver, John C gcweaver@usgs.gov>; Montebello, https://oubwk.ofice365.wm/mail/inboxAd/AAQkADRJNGZkNGYwLW NJOTctNGQ4MS1 hZDQ3LWJJMGMOYmRiN2M3NwAQADGLyKwk3UB4v%2FIR... 213 9/8/2021 Mail - Perlmutter, Gary- Outlook Michael J<Mlchael.Mordebello@ncdenr.govr, Bowden, Doug<doug.dowden@ncdencgov> Subject: (EXTERNAL) low -flaw request approval This emall has been received ftm outside of DOI -Use mudon before clicking on links, opening attaNnsuvis, or responding. Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 - 10 business days. Request Flow Statistic Approval Request ID: 145 Requestor. Gary Perlmutter Requestor e-mail: gajyR rim rtt.�aD@,acdd nrggy Requestor Phone: 919-306-1017 Loral Government Public Water Supply. Consultant Contact Reason: Permit River/Stream: Deep River Drainage Area (sq. mi.): 653 Latitude: 35.48437 Longitude:-79.44746 Other Information: Statististics: ["7Q10","30Q2","Average Annual',"7Q10 - Winter'] Approved by Cowden, Doug hftps://oudook.olfim365.mm/malVinboxhd/AAQkADRJNGZkNGYwLW NjOTc W GQ4M51 hZDQ3LWJJMGMOYmRiN2M3NwAQADGLyKwk3UB4v%2FIR... 313 Asheboro WWTP (NC0026123) Public Comments and Responses Comments to the draft Asheboro WWTP NPDES permit (NC0026123) were received from the City of Asheboro, dated 5/3 l /2018. Comments and responses are below: • Comment: "The WWTP staffr•equested mass based limits.fbr ammonia in lieu of concentration based limits daring the March 29, 2018 meeting at the WIFTP [site visit/. Upon review of historical data, mass based limits are attainable. What was the rationale for not using mass based limits in the draft permit? Asheboro is requesting a three year compliance schedule to research alternatnle treatment options that will allow./br consistent compliance if mass based limits are not allowed. " Response: Concentration -based limits are in the permit because EPA water quality criteria for ammonia (i.e., 1.0 mg/L summer, 1.8 mg/L winter) are expressed as concentrations, not mass, and are based on concentration -based toxicity studies. An updated review of effluent data shows that the Asheboro WWTP has not reported a weekly average or monthly average ammonia concentration that is greater than the proposed limits since January 2018. As the facility is consistently meeting the proposed limitations, a compliance schedule does not appear necessary and has not been added to the permit. • Comment: "Chloride has consistently been sampled in conjunction with Toxicity testing in previous permit cycles. Asheboro has never failed toxicity based on the chronic results and has had an excellent track record for passing toxicity testing. Explain what factors, data and calculations the Reasonable Potential Analysis are based our and con_fwin how this number is obtained. " Response: The RPA was conducted on 15 sample concentrations ranging from 68 to 300 mg/L, collected from March 2014 — December 2017. The RPA results showed that the chloride standard of 230 mg/L could be violated with a maximum predicted value of 351 mg/L. However, since Asheboro is passing toxicity tests, only monitoring is required. This is consistent with 15A NCAC 02B .0211 (22): If chloride is determined by the waste load allocation to be exceeded in a receiving water by a discharge under the specified 7Q 10 criterion for toxic substances, the discharger shall monitor the chemical or biological effects of the discharge - Monitoring will be maintained in conjunction with toxicity tests. Asheboro should use this pen -nit cycle as an opportunity to assess sources of chloride and how it can reduce this pollutant so that the allowable discharge concentration can be achieved in the next permit cycle. Comment: "Sla f rerieii,ed historical influent and erflruent data for- Cyanide collected since 2010. Din-ing this time no samples ever resulted in above detect for the influent. However, a period of seven days in September of 2015, three effluent samples resulted in a detection of cyanide. Upon review of the lab bench sheets, the data indicates that there was an interference with the test method in these samples and therefore these data points should have not been used or reported. A copy of relevant bench sheets a►-e attached ivith this correspondence. All samples collected.T-onr March 2, 2010 to June 4, 2015 and after September 22, 2015 have been recorded as non -detects <0.01rng/L (one was <0.0051ng1L). The maximum data point used to show reasonable potential for cyanide should not be considered in light of this inter fer-ence as it is not an accurate reflection of Asheboro WWT1' effluent. Asheboro requests the limit and monitoring i-equirements.for- cyanide be removed. " Response: A Reasonable Potential Analysis review has been conducted based on the last 4.5 years of effluent data (March 2018 — June 2022). Based on the reasonable potential analysis (RPA) showing no reasonable potential to violate state water quality standards, total cyanide limits and monitoring requirements have not been added to the permit. Page 1 of 4 Asheboro WWTP (NC0026123) Public Comments and Responses Comment: "Asheboro Staff 'is actively e: ploi•ing alternatives in how to meet the new boromodichloi-oinethane litnit. We would like to request a two year compliance schedule to evaluate our disinfection process and determine how to effectively reduce our bi-onlodichloroniethane concentrations but continue to properly disinfect the wastewater in order to continue to prolec•t the stream end enviromnenl. " Response: The City informed the Division via email notification on 11 /29/2022 that a bromodichloromethane compliance schedule is no longer requested. Comment: "Asheboro sluff is ini,are of the concern associated with 1,4 dioxane and ii,ill be able to comply with the terms of the tlu-ee_year compliance schedule. However, Asheboio is not inclined to regulate an industiy that may be discharging 1,4 dioxane based on the inconclusive data regarding the health effects of this parameter and the lack of enforceable streani standards. [Ve.feel identifying the sources of this contaminant is crucial. Howevei-, any soul-ces found should have ample opportunity to provide options of reducing oi- eliminating the contaminant while properly budgeting_firnds which are anticipated to be substantial. Asheboro believes after the solaces are identified, then a set of standards should be developed and limits applied. Stuff would like an explanation of the legal basis and calculations for the 149 µg/L liniil in this draft permit. " Response: Division regulations applicable to 1,4-Dioxane limitations: • 15A NCAC 02B .0206(a)(4)(B) identifies that for the flow design criteria for effluent limitations, the average annual flow for toxic substances shall be used to protect human health. • 15A NCAC 02B .0208(a)(2)(B) identifies for carcinogens, an unacceptable exposed risk level is 1 X 10-6 or greater. • 15A NCAC 02B .0216(4)(d) Fresh Surface Water Quality Standards for Class WS-IV Waters identifies that no discharge of sewage "...shall be allowed that have an adverse effect on human health or that are not treated in accordance with the permit or other requirements established by the Division..." The previously identified allowable discharge concentration of 149 µg/L for 1,4-Dioxane was based on a Reasonable Potential Analysis for the human health criterion of 80 µg/L in non -water supply waters. The non-WS criterion was based on a calculated 1 in 1,000,000 cancer risk from fish consumption per 15A NCAC 02B .0208. 1,4-dioxane is completely miscible in water and resistant to biodegradation. It is assumed that concentrations of 1,4-dioxane discharged from the WWTP will be equivalent at the direct discharge to Hasketts Creek, a class C waterbody, and the nearest downstream water supply (WS- V) boundary, located in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles downstream of the outfall. As such, in this reevaluation, allowable discharge concentrations were calculated for both the direct discharge to Class C Hasketts Creek and for the nearest downstream water supply (WS-V) boundary, and the more restrictive concentration was selected for protection of downstream uses. The water supply boundary is for the Deep River (Gulf- Goldston) water supply watershed, whose water supply intake is currently inactive. Each allowable discharge concentration was calculated considering the applicable receiving stream's Average Annual Flow (AAF), appropriate Instream Target Value (ITV) and the facility's permitted design flow. Page 2 of 4 Asheboro WWTP (NC0026123) Public Comments and Responses For the direct discharge to Class C Hasketts Creek, an ITV of 80 µg/L for non -water supply waters at an AAF of 12 cfs and a permitted design flow of 9.0 MGD (13.95 cfs) was considered. This calculation yielded a chronic allowable discharge concentration of 149 µg/L. When considering the downstream WS-V waters, a 1 x 10"6 risk level ITV of 0.35 µg/L for water supply waters at an AAF of 846 cfs (calculation estimated by USGS for WS-V boundary of Gulf- Goldston WS watershed) and a permitted design flow of 9.0 MGD (13.95 cfs) was considered. This calculation yielded a chronic allowable concentration of 21.58 µg/L. The allowable discharge determination based on direct discharge to Class C Hasketts Creek is insufficiently protective of downstream water supply uses. As such, the chronic allowable discharge concentration of 21.58 µg/L has been used in determination of permitting actions. Based on a review of the effluent data, the WWTP demonstrates a reasonable potential to exceed both the EPA drinking water heath advisory (HAL) of 35 µg/L and the state water supply Instream Target Value (WS ITV) of 0.35 µg/L for 1,4-Dioxane at the nearest downstream water supply boundary. As the reported effluent concentrations of 1,4-dioxane are greater than 35 µg/L, the facility discharges to non-WS waters with downstream WS waters, and reasonable potential to exceed applicable ITV at downstream WS boundary has been demonstrated. As such, weekly monitoring and limits have been added to the permit. Recognizing that 1,4-Dioxane is an emerging contaminant and industrial users are just now understanding its impact and use in materials, a phased implementation compliance schedule has been included in the permit. Please see the fact sheet for additional information regarding 1,4-dioxane permitting actions. Comment: "Sluff has discovered a NPDES per-nrit issued to DAK Americas (permit # NCO003719 — included with this correspondence) dated March 20, 2018 in the Cape Fear River Basin — direct discharge to the Cape Fear River•. This industry has the potential to be a significant discharger- of 1,4 dioxane based on their manufacturing process as well as toxic review inventor_>> submitted annually to EPA. This industry? is only required to monitor annually and report according to the nelt,ly issued permit. This appears to be a discrepancy and Asheboro staff does not understand the di ererrce in permit requirements Staff feels if we are held to this standard then it should be included in the reasonable potential analysis for all state rssited permits and all permit holders should be held to the same set of standars. " Response: The DAK Americas permit has a monitoring only requirement for 1,4-Dioxane to determine whether this facility discharges the contaminant in detectible amounts, given the concern of 1,4-dioxane in the Cape Fear River basin as a whole. The only historical 1,4-Dioxane data generated by the facility was in 2003, well before the implementation of EPA Test Method 164.1 in 2017, and under a process that has since changed. Asheboro has generated sufficient data to perfonn an RPA. • Comment: "Stuff would like an cgplanalion as to why the ier•nr fur this pernril is only four- years. NPDES permits are typicallt- written for S year terms. It is understood that we have been operating on an exprr'ed permit for'sorne time but shor-tening the term of the new per•rnit to 1bur years is a bin -den not only for city personnel bur also DEC). " Response: The permit term has been revised to be 5 years. Page 3 of 4 Asheboro WWTP (NC0026123) Public Comments and Responses Comments were received from Mick Noland (Fayetteville Public Works Commission, PWC), Jim Fletcliner (Cape Fear Public Utility Authority, CFPUA, Wilmington), Victor Czar (City of Sanford), and Jeff Adkins (Town of Cary) via e-mail on June 8, 2018. All commenters represent municipalities with water supply concerns of 1,4-Dioxane. Comments are summarized as follows: • All commenters ask the Division to consider the designated uses of the river downstream in 1,4- Dioxane limit development. • PWC, CFPUA and Sanford representatives request that other sources of 1,4-Dioxane be considered in developing limits. • CFPUA cites the EPA health advisory for 1 in 10,000 cancer risk of 35 µg/L in drinking water. • Sanford cites the water supply criterion of 0.35 µg/L and requests DEQ conduct an analysis to determine if the 149 µg/L limit is protective of the 0.35 µg/L criterion at the WS-IV classified water downstream at the confluence of Governors Creek with the Deep River. • CFPUA requests the compliance schedule be reduced; PWC and Sanford request a 2 yr compliance schedule • PWC requests a public hearing • PWC will consider legal action should DWR not consider downstream WS and other sources in limits development Response: Please see the response to the City of Asheboro's above comment and the revised Other WQBEL Considerations section of the fact sheet, with pages 16 and 17 focusing on the 1,4-doxane compliance schedule for more information. Page 4 of 4 Coco, Nick A From: Sarah Laughlin <slaughlin@ci.asheboro.nc.us> Sent: Monday, December 5, 2022 1:06 PM To: Coco, Nick A; mrhoney Cc: Montebello, Michael J; Mike Wiseman; Judy Smith Subject: RE: [External Sender] RE: [External Sender] [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft Courtesy Copy Follow Up Flag: Follow up Flag Status: Flagged CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Hi Nick, Thank you for taking time and meeting with me to discuss our permit further. The City of Asheboro is requesting the full 5 year compliance schedule for 1,4 dioxane. We believe Industry in Asheboro will need this time to investigate and install treatment units to reduce 1,4 dioxane discharges in order to meet the final compliance limits. Thank you, Sarah W. Laughlin Technical Services Manager Water Resources Division City of Asheboro (336) 672-0892 ext. 218 slaucghlin@ci.asheboro.nc.us Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Coco, Nick A [mailto:Nick.Coco@ncdenr.gov] Sent: Monday, December 5, 2022 10:36 AM To: Michael Rhoney <mrhoney@ci.asheboro.nc.us> Cc: Montebello, Michael J <Michael.Montebello@ncdenr.gov>; Sarah Laughlin <slaughlin@ci.asheboro.nc.us>; Mike Wiseman <mwiseman@ci.asheboro.nc.us>; Judy Smith <Judysmith@ci.asheboro.nc.us> Subject: RE: [External Sender] RE: [External Sender] [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft Courtesy Copy Hi Michael, We understand your concerns and have added some language to the footnote to allow for the sampling to be handled by the coalition (see below for footnote language). We do not have an issue with the coalition conducting the sampling, so long as we are receiving at least 1/month data. Additionally, if the coalition does not conduct sampling for the parameter, it will fall back on the City to resume sampling. "Instream 1,4-dioxane sampling shall be performed on concurrent days with effluent 1,4-dioxane sampling. If the Permittee is a member of the Monitoring Coalition Program, sampling for instream 1,4-dioxane may be waived as long as the Monitoring Coalition samples 1,4-dioxane at the nearest upstream and downstream locations, at a minimum frequency of monthly, and the Permittee has obtained approval from DWR - NPDES Permitting Unit that the upstream and downstream stations being monitored by the Coalition are representative of the receiving stream for this discharge. The Permittee is responsible for submitting instream 1,4-dioxane test results with its permit renewal application package. If the Coalition terminates instream 1,4-dioxane sampling at either of the approved stations, the Permittee will immediately notify the Division and resume sampling for instream 1,4-dioxane." Do you have time today for a quick MS Teams call? This would only take 10-15 minutes and is regarding the 1,4-dioxane compliance schedule. Thanks, Nick Coco, PE (he/him/his) Engineer III NPDES Municipal Permitting Unit NC DEQ/ Division of Water Resources / Water Quality Permitting Office: (919) 707-3609 nick.coco@ncdenr.gov "Email is preferred but I am available to talk by via Microsoft Teams** Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604 Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617 EQZ�/ Mp�nnwnt a Fnwa.rNN web\ / - Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Michael Rhoney <mrhonev@ci.asheboro.nc.us> Sent: Friday, December 2, 2022 11:02 AM To: Coco, Nick A <Nick.Coco@ncdenr.eov> Cc: Montebello, Michael 1<Michael.Montebello@ncdenr.gov>; Sarah Laughlin <slau¢hlin@ci.asheboro.nc.us>; Mike Wiseman <mwiseman@ci.asheboro.nc.us>; Judy Smith <iudvsmith@ci.asheboro.nc.us> Subject: RE: [External Sender] RE: [External Sender] [External] RE: [External Sender] NC0026123 Asheboro W WTP Draft Courtesy Copy CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Nick, Thank you for this response. We appreciate your cooperation as we continue this process. Your comments are satisfactory. However, we still have some concern with the 1,4-dioxane sampling requirements. We understand the importance of investigating background concentrations. Unless the samples are hydraulically paired, a grab sample on the same day as the effluent is immaterial. The samples aren't associative without hydraulically paring them. We have been completely receptive and cooperative with everything DEQ has requested of us concerning 1,4 but this sampling places somewhat of a burden on us. We aren't currently staffed to do this sampling and the two bridge sites aren't safe locations. The contract lab for the UCFRBA is already doing sampling at these sites and we would like to coordinate with them to do this sampling while they are there. You consideration of this request is greatly appreciated. Thank you, D. ;eluu", ;D Water Resources Director Water Resources Division 336-626-1201, ext: 258 www.asheboronc.aov North Carolina MAIN STREET Community Asheboro WORM Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Coco, Nick A [mailto:Nick.Coco@ncdenr.Rovl Sent: Thursday, December 1, 2022 3:04 PM To: Michael Rhoney <mrhonev@ci.asheboro.nc.us> Cc: Montebello, Michael J<Michael.Montebello@ncdenr.eov>; Sarah Laughlin <slauehlin@ci.asheboro.nc.us>; Mike Wiseman <mwiseman@ci.asheboro.nc.us>; Judy Smith <iudvsmith@ci.asheboro.nc.us> Subject: [External Sender] RE: [External Sender] [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft Courtesy Copy Hi Michael, Again, thank you very much for taking the time to review the draft permit and submit these comments. Please see below for responses to each: 1. The September 30 expiration is a remnant of the basinwide scheduling for NPDES permit renewals. I had it in as a placeholder, but will remove it and just have Month xx, 2027 for now to avoid confusion. The term of the permit is going to be 5 years. 2. That was an oversight on my part. I jumped the gun getting this out to you. Please see the revised version attached, which includes the reduced frequency. 3. Upstream hardness has not been added to the permit, for the reason you had listed. I will revise the language used in that email to remove reference to upstream hardness sampling when preparing the cover letter. 4. 1 will remove the compliance schedule for bromodichloromethane in the draft permit. Thank you for letting me know. 5. The instream 1,4-dioxane data will be used to understand background concentrations. I have changed the footnote language from "in conjunction with" to "on concurrent days with." The goal is to have the 2/month instream samples be taken on days where effluent samples are taken. This does not have to be down to the minute, but the concurrent data provides clearer conclusions. Please see response 1 for the 5-year term. 6. We will provide this as an attachment to the cover letter. 7. Permittees are responsible for tracking the Federal Register, but we will also be sending notifications to permittees with this requirement. 8. 15A NCAC 02B .0211 (11) (b) states, "With the exception of mercury, aquatic life standards for metals listed in this Sub -Item shall apply as a function of the pollutant's water effect ratio (WER). The WER shall be assigned a value equal to one unless any person demonstrates to the Division's satisfaction in a permit proceeding that another value is developed in accordance with the "Water Quality Standards Handbook: Second Edition" published by the US Environmental Protection Agency (EPA-823-B-12-002), which is hereby incorporated by reference, including subsequent amendments and editions, and can be obtained free of charge at http://water.epa.gov/scitech/swguidance/standards/handbook/. Alternative site -specific standards may also be developed when any person submits values that demonstrate to the Commission that they were derived in accordance with the "Water Quality Standards Handbook: Second Edition, Recalculation Procedure or the Resident Species Procedure", which is hereby incorporated by reference including subsequent amendments and can be obtained free of charge at http://water.epa.gov/scitech/swguidance/standards/handbook/." Additionally, as you had noted, 15A NCAC 02B .0211 (11) (c) (viii) [for chronic silver] as well as 15A NCAC 02B .0211 (11) (e) [for acute silver] incorporate the WER as a multiplicative factor when calculating the standards. DWR is also willing to consider other methods to achieve compliance with the proposed silver limits. Please confirm that the City believes a 5-year compliance schedule is necessary for achieving compliance with the proposed 1,4-dioxane effluent limitations. Please let me know if you would like to have a follow-up call to discuss any of these bullet items or would like further clarification on anything related to the draft permit. Best, Nick Coco, PE (he/him/his) Engineer Ill NPDES Municipal Permitting Unit NC DEQ / Division of Water Resources / Water Quality Permitting Office: (919) 707-3609 nick.coco@ncdenr.gov "Email is preferred but / am available to talk by via Microsoft Teams" Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604 Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617 Nr>irlr�rax:_��itrD E Q �� Mparlm�nl o14Mrmmnnlal Oual•� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties From: Michael Rhoney <mrhoney@ci.asheboro.nc.us> Sent: Tuesday, November 29, 2022 4:34 PM To: Coco, Nick A <Nick.Coco@ncdenr.¢ov> Cc: Montebello, Michael J<Michael.Montebello@ncdenr.sov>; Sarah Laughlin <slau¢hlin@ci.asheboro.nc.us>; Mike Wiseman <mwiseman@ci.asheboro.nc.us>; Judy Smith <]udysmith@ci.asheboro.nc.us> Subject: RE: [External Sender] [External] RE: [External Sender] NC0026123 Asheboro W WTP Draft Courtesy Copy CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Good afternoon, The City of Asheboro NPDES Permit Comments/Concerns are itemized below: 1. Please verify that this permit will be for less than 5 years based on the September 30, 2027 expiration date. 2. It doesn't appear that we were granted Reduction of Monitoring Frequencies for BOD, TSS, Ammonia and Fecal in NPDES permits for exceptionally performing facilities as requested. Was there an error in our request submission or was this just overlooked and didn't get changed? 3. The email on 11/21/2022 states upstream hardness sampling is required but Asheboro did not see it in the permit on A.(1.). Was it listed in another location? Asheboro has a 7Q10 of zero so upstream hardness testing is not needed or relevant to our site. 4. We would like to request the Bromodichloromethane compliance schedule be removed. We feel confident we have made enough internal operational changes since the last draft was published to meet the current limit and a compliance schedule is no longer necessary. 5. 1,4 Dioxane instream sampling — What is the data collected being used for? We would like to have the effluent and instream pairing requirement removed (footnote 13). This puts an undue hardship on our staff. Samples are not hydraulically paired when collected together so Asheboro does not understand the reasoning for this requirement. Please explain or remove the requirement for pairing. The 1,4 Dioxane final limit goes into effect at the end of year 5 but our permit isn't good for 5 years. Is that acceptable or was it an oversight (See comment 1 on less than 5 year permit). 6. We would like NCDEQto provide a list of Downstream Utilities and the CRC/Owner contact information for A.(6.) (g) notification requirement. 7. A.(8.) PFAS Monitoring Requirement — Will NCDEQ send a letter to notify permit holders once the method is approved or are we expected to track this internally and be aware. 8. According to 40 CFR 131.36, a WER does not change the Chronic Silver limit —See below. 15A NCAC 02B .0211 (11) (c) states chronic silver is WER time 0.06 ug/L. Can DEQ Staff confirm in writing that performing a WEIR will result in multiplying 0.06 ug/L times WER to result in a new NPDES silver limit? We need to know what our options are for a compliance schedule. Will DEQ consider other methods? I will be glad to discuss any of these items with you as needed. D. R. ;V£ Water Resources Director Water Resources Division 336-626-1201, ext: 258 www.asheboronc.gov North Carolina MAIN STREET Community Asheboro AN -A■ rb Cih 2016 Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Coco, Nick A [mailto:Nick.Coco@ncdenc¢ovl Sent: Tuesday, November 29, 2022 2:11 PM To: Michael Rhoney <mrhonev@ci.asheboro.nc.us> Cc: Montebello, Michael J<Michael.Montebello@ncdenr.gov>; Sarah Laughlin <slauehlin@ci.asheboro.nc.us>; Mike Wiseman <mwiseman@ci.asheboro.nc.us>; Judy Smith <]udysmith@ci.asheboro.nc.us> Subject: RE: [External Sender] [External] RE: [External Sender] NC0026123 Asheboro WWTP Draft Courtesy Copy Hi Michael, Thank you very much for the update. I look forward to seeing your summary. Best, Nick Coco, PE (he/him/his) Engineer /it NPDES Municipal Permitting Unit NC DEQ / Division of Water Resources / Water Quality Permitting Office: (919) 707-3609 nick,coco@ncdenr.gov "Email is preferred but I am available to talk by via Microsoft Teams" Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604 Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617 �,HC��IDiEQ�� 1. ,� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties From: Michael Rhoney <mrhonev@ci.asheboro.nc.us> Sent: Tuesday, November 29, 2022 2:08 PM To: Coco, Nick A <Nick.Coco@ncdenr.eov>; Sarah Laughlin <slauehlin@ci.asheboro.nc.us>; Mike Wiseman <mwiseman@ci.asheboro.nc.us>; Judy Smith <iudvsmith@ci.asheboro.nc.us> Cc: Montebello, Michael J <Michael.Montebello@ncdenr.eov> Subject: [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft Courtesy Copy CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Nick, We finished our review yesterday. I hope to sit down this afternoon and summarize everything before the end of the day. D. R . ;VS Water Resources Director Water Resources Division 336-626-1201, ext: 258 www.asheboronc.gov North Carolbila MAIN STREET Community, Asheboro Y-A■ein rs K NN.I Al UA]A IIII1.1 2016 Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Coco, Nick A [mailto:Nick.Coco@ncdenr.Rovl Sent: Tuesday, November 29, 2022 1:42 PM To: Michael Rhoney <mrhonev@ci.asheboro.nc.us>; Sarah Laughlin <slauehlin@ci.asheboro.nc.us>; Mike Wiseman <mwiseman@ci.asheboro.nc.us>; Judy Smith <iudysmith@ci.asheboro.nc.us> Cc: Montebello, Michael J <Michael.Montebello@ncdenr.gov> Subject: RE: [External Sender] NC0026123 Asheboro WWTP Draft Courtesy Copy Hi all, I just wanted to follow up on this to make sure that December 1 is still an attainable timeline for your review. With the holiday, I'm sure many folks were out of town or at the very least offline. Do you need a little bit more time to conduct your review and provide comments? If so, what would you say is a reasonable timeline for you? Thanks in advance, Nick Coco, PE (he/him/his) Engineer III NPDES Municipal Permitting Unit NC DEQ/ Division of Water Resources / Water Quality Permitting Office: (919) 707-3609 n i ck. co co @ n cd e n r. a ov "Email is preferred but I am available to talk by via Microsoft Teams** Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604 Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617 EQ:> Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties From: Coco, Nick A Sent: Monday, November 21, 2022 10:36 AM To: Michael Rhoney <mrhonev@ci.asheboro.nc.us>; slauehlin@ci.asheboro.nc.us; mwiseman@ci.asheboro.nc.us; iudvsmith@ci.asheboro.nc.us Cc: Montebello, Michael J<Michael.Montebello@ncdenr.gov>; Grzyb, Julie <]ulie.erzyb@ncdenr.gov>; Graznak, Jenny <iennv.eraznak@ncdenr.eov>; Snider, Lon <lon.snider@ncdenr.eov> Subject: NC0026123 Asheboro W WTP Draft Courtesy Copy Hi all, As we discussed on our call last Thursday, please see attached for a courtesy copy of the draft version of NPDES permit NC0026123 Asheboro WWTP. I've also listed below the changes being made to the permit, but please note that I am basing the changes off of the current active permit and not that first draft. The summary of changes: • Per the results of instream waste concentration (IWC)-based calculations for ammonia -nitrogen, ammonia nitrogen limits have been revised [See A.(1.)]. • Based on the reasonable potential analysis (RPA) showing no reasonable potential to violate state water quality standards, the limits and monitoring requirements for total chromium and total zinc have been removed from the permit [See A.(1)]. • Based on the reasonable potential analysis (RPA) showing reasonable potential to violate state water quality standards, total silver, bromodichloromethane, and 1,4-Dioxane limits and monitoring requirements have been added to the permit [See A.(1)]. • Based on the reasonable potential analysis (RPA) predicting a maximum effluent total selenium concentration that is greater than half of the allowable discharge concentration based on state water quality standards, quarterly monitoring for total selenium has been added to the permit [See A.(1)]. • To provide an opportunity for the City to develop a plan to assess sources of total silver and bromodichloromethane in order to come in compliance with the limits in Section A.(1.), schedules of compliance have been added to the permit [See Special Conditions A.(4.) and A.(5.)]. • To provide an opportunity for the City and their industries to develop a plan to assess sources of and implement technology to control discharges of 1,4-Dioxane in order to come in compliance with the limits in Section A.(1.), a preliminary 5-year phased schedule of compliance has been added to the permit [See Special Condition A.(6.) Schedule of Compliance for 1,4-Dioxane Limitations]. We do request that you confirm and provide additional information that the proposed 1,4 dioxane compliance schedule is consistent with EPA memo (related to compliance schedules) from James Hanlon (Office of Wastewater Management) dated May 10, 2007 (attached). • Based on the Mercury TMDL evaluation showing no annual average mercury concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, the limits and monitoring requirement for total mercury have been removed from the permit [See A.(1)]. • Based on Mercury TMDL evaluation showing mercury values reported at levels > 1 ng/L and since the permitted flow is greater than 2 MGD, Special Condition A.(7.) Mercury Minimization Plan (MMP) has been added to the permit. • Based on review of instream conductivity indicating the facility effluent appears to influence downstream conductivity levels, instream conductivity monitoring has been added to the permit [See A.(1.)]. The Permittees' instream sampling requirement for this parameter is provisionally waived as long as the Permittee is a member of the Upper Cape Fear River Basin Association. • Based on resulting patterns indicating effluent impact on the receiving waterbodies and to assess background concentrations of 1,4-dioxane to better analyze the discharge, instream monitoring for 1,4-Dioxane has been added to the permit [See A.(1.)]. • A special condition to monitor effluent PFAS chemicals quarterly has been added to the permit, to be effective six (6) months after EPA has a final wastewater method in 40 CFR136 method published in the Federal Register [See Special Condition A.(8.) PFAS Monitoring Requirements]. • The Division is implementing dissolved metals standards in all permits, per the 2016 revisions to State water quality standards. As such, the NPDES Permitting Unit will need site -specific effluent hardness data and instream hardness data, upstream of the discharge, for each facility monitoring these metals in order to calculate permit limitations. Effluent hardness and instream hardness sampling, upstream of the discharge, have been added to the permit at a monitoring frequency of quarterly [See A.(1.)]. • Some of the wording has changed in Special Condition A.(2.), Chronic Toxicity Permit Limit, please review each paragraph carefully. • Special Condition A.(3.) has been modified to include the specific three years in which the Effluent Pollutant Scan shall be performed (2024, 2025, and 2026). In addition, at the end of the Special Condition, 2nd species Toxicity Testing Requirements for municipal permit renewals per Federal Regulations [40 CFR 122.210)(5)] have been added. • A notation was made concerning the Electronic Reporting Rule — NPDES Electronic Reporting Rule — Phase 2 Extension. EPA extended the Phase 2 deadline to December 21, 2025. 9 • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The requirement to continue reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your NPDES permit [See Special Condition A.(10.)]. • Parameter codes have been added to the Effluent Limitations and Monitoring Requirements ( See A.(1.)]. Regulatory citations have been added to the permit. Please feel free to follow up with me with any questions. We are requesting that you submit any comments or provide any supplemental material regarding this draft permit by December 1, 2022. 1 appreciate your time and look forward to hearing from you after you have a chance to review. Best, Nick Coco, PE (he/him/his) Engineer 111 NPDES Municipal Permitting Unit NC DEQ / Division of Water Resources / Water Quality Permitting Office: (919) 707-3609 nick.coco@ncdenr.gov **Email is preferred but I am available to talk by via Microsoft Teams** Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604 Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617 Pr a D_E > Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 10 Attachment A —Request for Missing Information Table 2. EPA Application Form 2A Missing Information ,r 1.1 Email address of facaTity contact mrhoney@ci.asheboro.nc.us 1.2 Applicantemail address jogburn@ci.asheboro.nc.us 1.3 Email address of the organization transporting the discharge for treatment prior to discharge NIA 1.4 Email address of the organization receiving the discharge for treatment prior to discharge NIA 1.5 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(n)? (Check all that apply. Consult with your NPDES permitting authority to determine what information needs to be submitted and when.) Discharges into marine waters (CWA Section Water quality related effluent limitation (CWA El 301(h)) Section 302(b)(2)) Not applicable 1.6 Emall address of contractor responsible for operational or maintenance aspects of the treatment works •r 1,7 Indicate the number of SIUs and NSCIUs that discharge to the POTW. _ Number of SIUs T Number of CIUs 14 7 r 1.6 Certification Statement I certify under penalty oflaw that this document and all attachments were prepared under my direction orsupervislon in accordance with a system designed to assure that qualified personnel property gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the Information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibr7dy of fine and imprisonment forknowing violations. Name (print or type first and last name) Official fitie John N. Ogbum, III City Manager S slur Date signed] )-P L / f-2-2 . w,b.wmwn: wm m cam, «� ....W..„.,.....t nbp�[.MM4, rwwmwvr.m vein eW ,uv�wiWwwuMu :rn+.n roeera.uw nn nb fn[Wbu ,www�purw ry uaW Ww'ruruuu [nwwWrmW4xw nut. a rv. t^•I++w� W,.n rose.a.Yauwnw nn . ,rvu ivietl, v. rrr�.nau..innu.vr.. rb ae.mm. •.iM vmYY� � •wwov.una n,e arruNY.� �uweu3W :irvry �at�Wu n wvn w.o,.�mau...�.a rss wrw•uaw. .,[M e*b ufw Munw+wun�e n ... v. m: n.me�u.waw o,u. ,:uM uuiyW u�r [nn.ewea.+d+�e n.,. eWin�p.�^'�W nWMu nri .. u"^rMHuw ..u�: rv,.ner.umwiw�ia 9i ew �b .. .ngrw wee -.tee rmtt �`uf [ va no ou4yRurai,nl, ukm>munu u.en �4nuun evm�+w.Y.... rN r.rc. [awrmnn .v na rnM wi�un� run[ r e no Enter data ONLY in blue cells) POTWNarne: City of Asheboro P NPDES#: I N000261B Influent Grab (ng/L( CAS Number Analyse Name Acronym 7/10/2019 8/8/2019 9/5/2019 335-67-1 Perfivaroocianoic acid PROP, 9.42 10.6 11.2 1263-23-1 Perfluoroodanesulfonic acid PFOS 19.8 18.8 19.2 375 22 4 Perflucrabutanolc acid PFBA <254 U NO U ND 325-73-5 Perfluorobutanesulfonic acid PFBS <2.54 U NO U NO 335-72-3 Perfluorodecanesulfonic acid PFDS <2.54 U NO U 24.4 f- 335-76-2 Perfluorodecanoic acid PFDA 2.54 U NO U 4.51 302-55-1 Perfluarododecanoic acid PFDoA <2.54 U NO U 2.02 325-92-8 Perfluoroheptane5ulfonlc acid PFHPS <2.54 U NO U 2.03 325-85-9 Perfluoroheptanoic acid PFHpA 4.62 NO U 5.95 355 -46 Perfluorchexanesulfon¢ acid PFHxS <2.54 UMND U ND U 302.24-4 Perfluorohexanoic acid PFHxA B74 B 12.4 68259-12-1 Pe Hluoranonanesulfonic acid PFNS <2.54 UU 2.19 325-951 Per(luorononanmc acid PFNA <2.54 UU 3.87 254-91-6 PerNuorooctanesulfonamidc PFOSA <2.52 UU NO U 2991-506 2-(N-Ethvlperfluorooctanesulfonamldo) acetic acid N-EtFOSAA <2.54 VU 4.092355-319 2-IN-MethVipeHlmmocanesulfonamidof acetic acid N-MCFOSAA <2.54 UU NO u 2206914 PerfluoropentaneSulfOnlc acid PFPCS <2.54 UU ND U 2206-903 Perfluoronentanoic acitl PFPeA 25.9 U ND U 32606-7 Perfluorotetradecanoic acid PFTv.A <2.54 U NO U 11.4 22629 94-8 Perfluorotridecanoic acid PFTriA <2.54 U NO U 7.15 2058-94-8 Perfluoroundecanoic acid PFUPA <2.54 U NO U 5.04 62032-80-3 Gen-% HFPO-DA NO U ENTER OTHER PARAMETERS TESTED ENTER OTHER PARAMETERS TESTED ENTER OTHER PARAMETERS TESTED ENTER OTHER PARAMETERS TESTED Sum of PFOA and PROS 29.22 29.4 30.9 Total 69.43 42.9 121 Asheboro WWTP Effluent Grab 1,4 Dioxane Data (ug/L) Date Research & Analytical Laboratories, Inc. NC #34 Meritech Inc. NC #165 Pace Analytical NC #12 NC DEQ DWR *Not Certified* 12/7/2017 98.7 *Not Certified* 89.0 1/11/2018 937 1590 2/1/2018 882 1140 3/1/2018 212 4/5/2018 397 5/9/2018 75.7 6/13/2018 77.7 7/17/2018 48.0 8/22/2018 764 9/11/2018 182 10/25/2018 31.6 11/8/2018 58.3 12/6/2018 217 1/9/2019 167 2/5/2019 613 3/13/2019 159 4/17/2019 228 5/8/2019 37.0 6/4/2019 46.5 7/10/2019 49.2 8/22/2019 423 9/4/2019 18.2 10/22/2019 184 11/19/2019 64.7 12/10/2019 200 1/16/2020 166 2/19/2020 208 3/3/2020 571 4/1/2020 102 5/6/2020 149 6/9/2020 79.3 7/16/2020 120 8/12/2020 232 9/2/2020 199 10/8/2020 <2.0 11/17/2020 72.6 110* 12/2/2020 <1.0 12/9/2020 <1.0 12/15/2020 1.23 3.3* 12/21/2020 <1.0 12/29/2020 6.12 1/7/2021 3.05 1/13/2021 3.19 3.6* 1/21/2021 4.06 1/27/2021 8.21 2/2/2021 4.01 2/10/2021 31.4 2/16/2021 20.5 46.0* 2/25/2021 32.9 3/2/2021 18.1 3/10/2021 93.8 3/16/2021 145 200* 3/25/2021 133 3/30/2021 316 4/7/2021 77.2 4/15/2021 58.3 4/22/2021 14.1 15.0* 4/28/2021 20.8 5/5/2021 4.86 5/13/2021 19.7 5/19/2021 18.3 5/24/2021 147 290* 6/2/2021 27.2 6/9/2021 26.6 6/17/2021 143 6/22/2021 88.8 130* 6/29/2021 35.9 7/8/2021 88.4 7/16/2021 153 240* 7/20/2021 34.2 7/23/2021 55.7 82.0* 7/30/2021 115 220* 8/6/2021 34.4 64.0* 8/13/2021 25.2 25.0* 8/20/2021 55.6 82.0* 8/27/2021 64.6 96.0* 9/1/2021 58.9 120* 9/10/2021 70.2 100* 9/17/2021 63.9 83.0* 9/24/2021 98.6 140* 10/1/2021 37.5 38.0* 10/8/2021 44.5 68.0* 10/15/2021 114 270* 10/21/2021 548 920* 10/29/2021 636 940* 11/5/2021 75.3 130* 11/12/2021 3.82 6.0* 11/19/2021 5.04 1 7.2* 11/22/2021 10.3 12/3/2021 59.7 65.0* 12/10/2021 2.7 4.1* 12/17/2021 11.3 38.0* 12/21/2021 <2.0 1/7/2022 102 130* 1/14/2022 26.9 22.0* 1/20/2022 3.06 1/28/2022 25.2 22.0* 2/4/2022 74.7 110* 2/11/2022 107 180* 2/18/2022 34.6 74.0* 2/25/2022 133 190* 3/4/2022 25.0 33.0* 3/11/2022 136 190* 3/18/2022 44.3 Not Received 3/25/2022 15.1 Not Received 4/1/2022 Not Received Not Received DARSWEIL L ROGERS, COMMISSIONER ' / FAYEMVILLE PUBLIC WORKS COMMISSION WADE R. FOWLER, JR., COMMISSIONER C 955 OLD WILMINGTON RD EVELYN 0. SHAW, COMMISSIONER J P.O. BOX 1089 D. RALPH HUFF, III, COMMISSIONER H E OWN UTILITY FAYETTEVILLE. NORTH CAROLINA 28302.1089 DAVID W. TREGO, CEO/GENERAL MANAGER TELEPHONE (910) 483-1401 W W W.FAYPWC.COM June 8, 2018 VIA EMAIL: gary.perlmuner@ncdenr.gov Mr. Gary Perlmutter NCDEQ — Division of Water Resources 1612 Mail Service Center Raleigh, NC 27699-1612 Subject: Fayetteville Public Works Commission Comments on Draft NPDES Permit for City of Asheboro Wastewater Treatment Plant (NC0026123); Randolph County, NC Dear Mr. Perlmutter: The North Carolina Department of Environmental Quality — Division of Water Resources (DWR) issued a public notice of the draft NPDES permit for the City of Asheboro's Wastewater Treatment Plant (W WTP) on May 9, 2018 and the comment period is open through June 8, 2018. Located within the Cape Fear River basin, this facility discharges to Hasketts Creek which is a tributary of the Deep River. This WWTP has a pretreatment program for the applicable industries that discharge to its collection system. Fayetteville Public Works Commission (PWC) has a surface water intake on the Cape Fear River downstream of this discharge and is providing comments on this draft permit based on protecting its and other water systems water supplies. PWC has reviewed the draft permit considering the known levels of 1,4-dioxane, an emerging contaminant, in the Cape Fear River. PWC is providing relevant background information and presenting alternatives to the proposed permit limit for 1,4-dioxane. This is a very important public health issue for water supplies in the Cape Fear River basin and we believe a public hearing is appropriate to get additional public comment before issuance of the final NPDES permit. Background on 1,4 Dioxane Monitoring data in the Cape Fear River watershed collected by both DWR and a researcher at North Carolina State University (NCSU) has identified the presence of 1,4-dioxane. This chemical is most often used as a stabilizer in chlorinated solvents, paint strippers, and waxes. It is found as an impurity in antifreeze and aircraft deicing fluids, is a by-product in the manufacturing of polyethylene terephthalate (PET) plastics, and may be present in manufactured food additives, food packaging materials, and pesticides. It moves easily from soil to groundwater, as it does not stick to soil particles but is soluble in water. Environmental Protection Agency's (EPA) technical fact sheet for 1,4-Dioxane, dated November 2017, further characterizes it as completely miscible in water, making it highly mobile and not readily biodegradable in the water environment. Described by the (EPA) as a "likely human carcinogen," this chemical compound is also identified by the EPA as an emerging contaminant. The U.S. Department of Health and Human Services also considers 1,4-dioxane as "reasonably anticipated to be a human carcinogen." BUILDING COMMUNITY CONNECTIONS SINCE 1905 AN EQUAL EMPLOYMENT OPPORTUNITY EMPLOYER Mr. Gary Perlmutter Page 2 June 8, 2018 EPA's risk assessment resulted in a drinking water health advisory with an associated estimated lifetime cancer risk of one in one million at a concentration of 1,4-doxane of 0.35 µg/L. Human exposure may occur through ingestion of contaminated food (including fish from contaminated waterways) or water and through skin contact. Conventional WWTPs and water treatment plants are not capable of removing this compound. With these characteristics, PWC is concerned with how and where this compound enters the Cape Fear River watershed upstream of its drinking water intake. In accordance with the water quality standards regulations (15A NCAC 02B.0208), DWR calculated protective values for 1,4 Dioxane (CAS # 123-91-1) are 0.35 ug/L in Water Supply classified waters, and 80 ug/L in Class C waters. The calculation of 0.35 ug/L is protective of consuming water and consuming fish (WS Classified waters). The 80 ug/L is based upon the risk of consuming only potentially contaminated fish (Class Q. These numbers are based upon the carcinogenicity of the compound from information obtained from the US EPA IRIS database. 1.4-Dioxane in the Caue Fear River Monitoring of this compound in the Cape Fear continues to show its presence in both main tributaries, the Deep and Haw Rivers, as well as in the Cape Fear River. DWR completed a study from 2014 through 2016 on the Cape Fear River Basin and published results in February 2017. Monitoring is continuing and so far, four primary sources were identified, with three identified as municipal WWTPs. This further supports the premise that the municipal treatment facilities are not removing 1,4-doxane with current treatment practices, and sources are likely industrial facilities discharging to the WWTPs. This study includes conclusions that further reductions will be necessary to achieve federal and state health advisory levels in the Cape Fear River. City of Asheboro WWTP Draft NPDES Permit The City of Asheboro's draft NPDES permit includes a limit of 149 µg/L of 1,4-doxane with a compliance schedule of 3 years. Based on the information provided in the fact sheet for the draft NPDES permit, PWC believes this limit is not sufficient to protect downstream water supplies. Also, since downstream waters currently have 1,4-Dioxane levels above the water supply criterion, we believe the compliance schedule is too slow . Table 1 includes the data and parameters used by DEQ to arrive at a limit of 149 µg/L. Using the combined flows from the discharge and the annual average streamflow as reported in the fact sheet as well as the instream criteria of 80 µg /L, one can derive the calculated proposed permit of 149 µg/L. This calculation was made under the assumption that all Hasketts Creek loading of 1,4-doxane is entirely attributed to the Asheboro WWTP and there are no upstream sources. However, such an assumption seems to be inherently unreasonable in light of the information cited above. Table 1 City of Asheboro Draft NPDES permit parameters Parameter Units Permitted discharge 9 MOD, converted to 14 cfs From fact sheet Annual average streamflow 12 cfs From fact sheet Instream criteria 80 µg/L To be met in mixing zone Mr. Gary Perlmutter Page 3 .tune 8, 2018 Water Supply Watershed Considerations PWC is concerned that the approach used above to calculate the draft permit limit for 1,4- dioxane improperly considers only the Class C waters near the discharge and not the water downstream classified for water supply (WS) (as required by 15A NCAC 02B .0203 PROTECTION OF WATERS DOWNSTREAM OF RECEIVING WATERS). These concerns are outlined below for the Deep River water supplies as well as for PWC's water supply in the Cape Fear River further downstream. Deep River — The calculation of the Asheboro permit limit for 1,4-dioxane does not consider downstream WS waters nor other sources of this contaminant in the Deep River watershed. Hasketts Creek discharges into the Deep River and literature shows that 1,4-dioxane is not readily biodegradable in the water environment. Thus, the mass discharged can be assumed to move downstream with little or no losses through sedimentation or biodegradation. Sampling conducted by NCSU has detected low levels of 1,4-dioxane in the Deep River upstream of the confluence with Hasketts Creek. In addition, the water supply (WS) segment for former Gulf- Goldston Sanitary District intake and Lee County/Sanford is located on the Deep River before its confluence with the Haw River. At this location, the water supply criterion of 0.35 µg/L should be met. Using watershed size and the USGS gage at Moncure (downstream of the Lee County intake), it is estimated that the annual average stream flow is approximately 1,000 cfs. Using that as a dilution factor, the loading from the Asheboro WWTP alone would produce an instream concentration of 2.0 ug/L at the Gulf-Goldston and Lee County/Sanford (WS) segments. This value is well above 0.35 µg/L and would be much higher during low flow conditions that frequently occur. PWC has estimated the permit limit that would be necessary to meet the WS criterion at Gulf- Goldston. Using the estimated average annual stream flow of 1,000 cfs and a water supply criterion of 0.35 µg/L, the permit limit from Asheboro WWTP would need to be less than 15 µg/L if the Asheboro WWTP is the only source of 1,4-dioxane considered. DWR should also consider other sources of 1,4-dioxane which would lower this permit limit further. Cave Fear River PWC has also been conducting monthly monitoring for 1,4-dioxane upstream of its intake as well as at its intake. Data collected since May 2014 show an average instream concentration of 2.5 µg/L, as shown in Table 2 (at end of letter). This value is also above the water supply criterion of 0.35 µg/L. DWR monitoring results included in the 2-year report published in 2017 show similar levels, with most records between 2 and 4 jig/L. If Asheboro WWTP were the only 1,4-dioxane source at 149 µg/L at permitted flow contributing at PWC's intake, it is estimated that the concentration would still be above the water supply criterion at about 0.45 µg/L. This estimate was made using the average annual stream flow at Cape Fear River USGS gage 02104000 in Fayetteville. Under low flow conditions approaching the 7Q10 flow, the concentration would be above 4 ug/L at Asheboro's permitted flow and above 2 ug/L if they were discharging at 50 percent of their permitted flow. Clearly, DWR needs to consider downstream WS waters in calculating permit limitations for dischargers. Efforts are needed throughout the Cape Fear River basin to reduce discharges of 1,4-dioxane to receiving streams. Request for Public Hearing We believe the issue of 1,4-dioxane has been flying under the radar because of other emerging contaminant issues in the Cape Fear River and that many people are unaware of concerns over this contaminant. Since Asheboro is the first of several NPDES permits in the river basin that will have limitations for 1,4-dioxane, we believe DWR should conduct a public hearing to fully inform the public and get public and water utility concerns over their approach to regulating this contaminant. Mr. Gary Perlmutter Page 4 June g, 2018 Concludine Comments PWC appreciates your consideration of our requests for protection of, the Cape Fear River as a water supply source for PWC and many other communities in the Cape Fear River basin, through continued efforts to reduce 1,4-dioxane entering in the watershed. Clearly, the proposed permit limit included in Asheboro WWTP's draft NPDES permit is not low enough to protect downstream water supplies and should be reconsidered. Treatment technologies including oxidation approaches can be used by either the Asheboro WWTP or the industrial facilities discharging into the Asheboro WWTP to reduce 1,4-dioxane. We believe further efforts to inform the public and get input on this contaminant is necessary. Even with continued dilution downstream in the Cape Fear River, 1,4-dioxane inputs from the Deep River and Haw River are resulting in concentrations higher than the 0.35 µg/L water supply criterion at PWC's intake. PWC believes the situation in the river basin and the rules require that as other NPDES permits are renewed in the watershed, additional WWTPs will receive limits for 1,4-dioxane such that the combined discharges will not result in levels that are higher than the criterion at classified water supply segments. We also believe that an appropriate compliance schedule for meeting these requirements is 2 years, rather than the 3 years proposed in the Asheboro draft NPDES permit since current levels well exceed the 0.35 ug/L, water supply criterion. We believe expedient actions are needed to reduce 1,4-dioxane levels sufficiently to protect human health for drinking water supplies and that compliance can reasonably be achieved within 2 years. The cost of compliance should be home by either Asheboro or the industries that discharge into the Asheboro WWTP rather than the innocent downstream users.. If DWR does not begin to consider downstream water supply uses as well as the multiple sources of this pollutant in watershed in the development of NPDES permit limits, PWC will consider administrative and legal appeals to protect its water supply. If you have any questions or require further information concerning this letter please feel free to contact Mick Noland at (910) 223- 4733 and mick.nolandnaiavuwc.com. Respectfully submitted, Fayetteville Public Works Commission ,V(k� *&—,( Mick Noland Chief Operations Officer Water Resources Division Cc: Linda Culpepper Shelia Holman Table 2 Data Collected by Fayetteville PWC P.O. Hoffer WTF Intake OWL) 5/13/14 3.90 6/12/14 2.90 7/10/14 5.70 8/4/14 3.80 9/4/14 2.10 10/23/14 2.50 11/12/14 9.60 12/9/14 2.40 1/13/15 2.10 2/11/15 1.80 3/17/15 1.60 4/7/15 2.40 5/13/15 4.50 6116115 2.20 7/15/15 1.50 8/18/15 2.50 9/22/15 4.80 10/28/15 2.30 11/11/15 0.99 12/28/15 0.28 1/11/16 1.30 2/24/16 1.50 3/16/16 1.20 4/13/16 1.40 5/11/16 3.90 Table 2 Data Collected by Fayetteville PWC P.O. Hoffer 'WTF Intake (99/L) 6/14/16 1.80 7/20/16 2.90 8/23/16 0.59 9/20/16 1.50 10/26/16 0.67 11 /28/16 1.40 12/27/16 1.20 1/26/17 5.00 2/22/17 4.80 3/16/17 1.90 4/5/17 2.30 5/3/17 0.81 6/20/17 2.20 7/13/17 0.76 8/15/17 0.66 9/19/17 3.00 10/12/17 2.30 11/14/17 2.50 12/11/17 2.40 1/10/18 5.40 2/21/18 3.90 3/13/18 1.70 4/11/18 1.60 Note: Data collected by Fayetteville PWC Water Resources Division 146 N Church Street PO Box 1106 Asheboro, NC 27204-1106 May 31, 2018 CITY L-+ ASHEBOfu N O R T H C A R O L I N A Mr. Gary Perlmutter NCDEQ — Division of Water Resources Water Quality Permitting Unit 1617 Mail Services Center Raleigh, NC 27699-1617 Re: Comments for Draft Permit NCO026123 Dear Mr. Perlmutter. Tel: 336-626-i2o1 Ext. 258 Fax: 336-626-1218 RECEIVED/DENR/1)WR JUN 0 7 2018 Water Resources Permitting Section Thank you for your work in preparation of the above referenced permit. City of Asheboro Wastewater Treatment personnel have some questions and concerns regarding monitored contaminants and limits listed in the draft permit. Asheboro would like some modifications to the draft permit before final issuance. The following notes and requests should be considered before issuing the final NPDES permit. The WWTP staff requested mass based limits for ammonia in lieu of concentration based limits during the March 29, 2018 meeting at the WWTP. Upon review of historical data, mass based limits are attainable. What was the rationale for not using mass based limits in the draft permit? Asheboro is requesting a three year compliance schedule to research alternative treatment options that will allow for consistent compliance if mass based limits are not allowed. Chloride has consistently been sampled in conjunction with Toxicity testing in previous permit cycles. Asheboro has never failed toxicity based on the chloride results and has had an excellent track record for passing toxicity testing. Explain what factors, data and calculations the Reasonable Potential Analysis are based on and confirm how this number is obtained. Staff reviewed historical influent and effluent data for Cyanide collected since 2010. During this time no samples ever resulted in above detect for the influent. However, a period of seven days in September of 2015, three effluent samples resulted in a detection of cyanide. Upon review of the lab bench sheets, the data indicates that there was an interference with the test method in these samples and therefore these data points should have not been used or reported. A copy of the relevant bench sheets are attached with this correspondence. All samples collected from March 2, 2010 to June 4, 2015 and after September 22, 2015 have been recorded as non -detects <0.01mg/L (one was <0.005mg/L). The maximum data point used to show reasonable potential for cyanide should not be considered in light of this interference as it is not an accurate reflection of Asheboro WWTP effluent. Asheboro requests the limit and monitoring requirements for cyanide be removed. Asheboro Staff is actively exploring alternatives in how to meet the new bromodichloromethane limit. We would like to request a two year compliance schedule to evaluate our disinfection process Home of the NC Zoological Park Correloon Coefficient= >. ('BLW7 . Slopes 0.00I 06 City of d"heboro �oDatev `64Department - •► drWater Quality ty �.. Cyanide Standard Methods Date Semple SoUrce Chedcs lni" !Ck B Date Collected a b c �d I Pres. Dissgtled Flnel Absorb ml Absorbance ____— Method: 4500-CN- C E -1997 _ --' pH (MO SoPn (MO Reacted Reading ug CN AAm CN Remarks 0.447 0.0400 0.05 f `d C� � stt t�tcl 0. 00b _ �•R$ 6 15D gp 0.+1-7 O04- ' - ----- -- �! 10 l i 40 o. (OZ O.ol O.O 1 Z. — ( �; Iv G -- a � � f7U Id � SO Csn 40 0.03 0.DO � !16 G0-p 0 _ 0 � �-- �--- C��. �f 40 3Co o -00 3tj L 0.O t O -5c) �50 40 1 o. tom- 0•01(oO 0.02 r MhdL-V 40 -o.00j o.000 le-0.0(0 _ -&i ; 0.06vr�� ' (2 -- � 0• 4q3 . O. O YO - • InLa> eaoe C kOdM: e) Cbkrimk b) SuMbs. o) A2da5ydao d) Nh:atolNlub 10 ThQ C6mi- allowzMandw X 10 - M M PM =lode d>mtod to 1000 mt MgUUcd to male a 10 ppm stm.Wd CK M94 + (Mal + b) XZ X.W.wlrm X Y- Ag(NOa)z Check = ml Y o Or+� ad `°l bQ ° oramamw -`--�---• -'-._.�.. tQtt[OO�oocBo[ts ; = nonros Q l ania Dnn.s.A•,i.lA o�«......aw�.. CorreMon Coefficient= f },� �'i 010117 slope.. o.v�toss7 City of �heboro �.- y-Intercept O. DDp ! 2���}- Date verified = S.I�4 Department ov-Water Quality _ � Cyanid® standard Methods Method. 4500-CN- C E -1997 Sample Source Checks Pres. DisUiled Final Absorb n*d Absftance Date Int_ _ I Date Collected a 'b c • d pH (MI) SoPn (ml) Reacted Reading ug CN m CN pP Remarks 64 40 C4, PIZ5 S"-Pr4 570 40 t lr Q' . l o O.0loo o o 204 Zo 0.2$� __ -- --- _ ?--- " o.oso . .0305 ;= toll + Olt-S-4 W,2-4.(C. 0 Z5Z)7 X ZV�) �---- Lw x o _ Q SSA. Yn -1 E , Ictadae�oo am" b a) Q&rine. b) &ULdm o A Bh — -J ,4. (rC,(�(r IUC,�� Litt Ctt�c: cW.1QQQ�OI� X !0 d m!•1w0 ppm aoo6c diluted to IOOD ml nquaed to mates a 10 ppro rtiandaQd m1 A&toh ti:rar,t a i. aC.-IP CK man+ coat +b) XIQ x.Slt.wbm: t t °� x Y G X — abnarptiaa sadutioa. aA m — slope of nteodud own 2 C SC* = � m1 Y - otl&W sample, ml b - inte me;* an c axis .. ., _.a ....�..........e...�....�..:._ .�.,.. t jianntac nun Aarw%s*akjft ` Cerreloon Coefficient= SlopE t City of �,heboro y4nterc e t = - - - Department otWater Quality Date Verified = Standard Methods Cyanid® Method: 4500-CN- C E -1997 sample Source Checks Date Int. I C 8)► - Date Collected a b c d ' Pros. Distilled pH (lnl) Final Absorb Sorn (ml) ml Reacted Absorbance Reading ug CN ppm CN Remarks 5'?a 4-0 0.010 5a D.O� D.00l I 0,0co `Ao,oro �. 4 O-Lcl�s O - o C?so o. o ZZ 1 * � boo 4 a qgc5 o.o toy o.o5-o Oc��� �o, o v x �o.o�Z�c,?,o�s I -0\(t L_ t lwaft=mo s) Cat*, b) sWdffi 0) AUchyaes. d) Rtrft0/MftiW '["ciao Cbook orLi0g?4vq9X to - Q*1000 ppm mck to IODO act rogWrod to make a to Sao mndud ml A&NGjj duwd CK utaA + Oul + b) X 2 X-N . obese: X Y X - Wawpdat sotutka, ad m atopa of $ttaderd cum Ag(N%)2 Check = MI Y'- UMPk. a� ,- --� �_ b o iatareept on o wis 10 + a DMftfa fWR Ranmfahla paramoM.e ' corre+p"on coefficient-- DAM 91165 r 67 ro OJ y-Interoept = a ! Date verified =_ _ City of0heboro 'Department of Water Quality Cyanide Sample Source Checks Date int. C_k_ y Date Collected a b c d Pros. DlsdIled pH (ml) Final Absorb Scwn (MO � � � 5� i -t IAA led o._O S U -- -- _ ci�s 0-0450 50 sb . '-p-az�ogq 5bCqI 5 .S —f-- r— irel cb - wj 4�0 _. Standard Methods Method: 4500-CN- C E -1997 ml Absorbance Reacted ; Reading ttg C1d ppm CN Remarks 4.0 o.ov-7 0-040d'I'd 410- c010 44D 0. ysla o. oq C to 4. 05ZO = rO db 40 0. Wv 0.0400 0. 05VO 10004 0.525 0.0477 100% 43_. D.002-Z 40.010 40 O.OZ(O O.00rz5 `0- 010 40 0.0-31 ) ©.00Z$ c 0. o 10 4O 0.0% D -oosq- i O. O t0 j 40 O. S41 o-Ojg5, o.OlQb- K p 0.1063 O.OtZ(p 0. oz-zo;r -W*20 O-W% i i O-OZ150 0-a3S� O,p-649--r do" k.- P- - 40 �,�7� j. 0- e>o o 2 40.010 u ryi tst. ri rl b 2� 0.0301 ai T,161 d. O/ ZO O., 5Wdgg, r'1•I � i•F. � - O.•Ov y 0.0077 0-I'09)(i Co. q-t7 QwxUw a) b) snlff*s, o) j6 4)Vdrct*1Hftrk* rna Chwt v%U9QI X 10 o vat M ppm stock dilated to loco ml roquirca to mdw a 1 o ppm stmdard ml AS(t 03N fittast CK UWft +(c%al +b) X JQ X ja. v&uw. X Y X - ebwtptiaa sowtiaa. ml ra + slope of U=dud maw An(N() .l.. f :hw.k ml Y a arig nd s urA ad b- iCCOMPt as 0 23as -- asheeorowwrr(. iu - Date Influent Effluent 3 <0.01 3/4/2030 s0A1 ��Vi�d;Y.w 6/8/2010 <0A1 4=1 9/14/2010 <DA1 40.01 i2/7/2010 <0.01 <MM 1/13/20U <DJn <M 2/17/2011 <OAl <0A1 3/3/2011 <MMI <DAl 4/19/2011 40.01 mot 5/1112OU <0.01 <0.01 6/7/2011 <OM <OM 7/14/20U <0.01 <0.01 8/18/2011 <D.01 <OA1 9/22/2011 <0A1 <OA1 10/4/2011 <041 <0.01 11/ss/2011 4AO1 <0.01 12/6/2011 <M <0Ai IA012012 <D.01 <0.01 3/6/2012 <0.011 <ooi 6/12/2012 <&oi <0.01 9/11/2012 <0.01 <0.01 12/4/2012 <0A1 <0.01 3/5/2013 <0.01 <0.01 6/4/2013 <0.01 <0.01 9/17/2013 <0.01 <0.01 12/12/2013 aol <0.01 3/4/2014 <OM <0A1 6/19/2014 <O.01 <0.01 9/9/2014 <0.01 <0.01 12/4/2014 <0.01 <0.01 3/10/2015 <0.01 <0.01 3/24/2015 <0.01 6/2/2015 <0.01 <0.01 6/4/2015 ,y,'; yi? <0.005 9/15/2015 <DAL OA78 9/18/2015 'JAi %'- OAl2 _ 9/2%4M 1 oA17 9/22/2015 <0A1 9/23/2015 12/8/2015 <0.01 <0.01 <0.01 1/13/2016 <0.01 <0.01 2/11/2016 <0.01 <OA1 3/14/2016 <0.01 <0.01 4/14/2016 <0.01 <0.01 5/5/2016 <0.01 <0.01 6/14/2016 <0.01 <D.01 7/24/2016 <0.01 <0.01 8/17/2016 <0.01 0.01 9/13/2016 <0.01 <0.01 10/19/2016 <0.01 <0A1 11/2/2016 <0A1 <0.01 12/6/2016 <0A3 <0.01 3/7/2017 <0A1 <0.01 6/8/2017 <0.D1 <om 9/19/2017 <O.01 <0.01 _ 12/5/2017 <0.01 <0.01 3/6/2018 <0.01 <0.01 S-ARaarea Lab SIN[y13 NC 0026123 Draft Permit Comments 5/31/2018 Page 2 of 2 and determine how to effectively reduce our bromodichloromethane concentrations but continue to properly disinfect the wastewater in order to continue to protect the stream and environment. Asheboro staff is aware of the concern associated with 1,4 dioxanc and will be able to comply with the terms of the three year compliance schedule. However, Asheboro is not inclined to regulate an industry that may be discharging 1,4 dioxane based on the inconclusive data regarding the health effects of this parameter and the lack of enforceable stream standards. We feel identifying the sources of this contaminant is crucial. However, any sources found should have ample opportunity to provide options for reducing or eliminating the contaminant while properly budgeting funds which are anticipated to be substantial. Asheboro believes after the sources are identified, then a set of standards should be developed and limits applied. Staff would like an explanation of the legal basis and calculations for the 149 ug/L limit in this draft permit. Staff has discovered a NPDES permit issued to DAK Americas (permit # NC0003719 —included with this correspondence) dated March 20, 2018 in the Cape Fear River Basin — direct discharge to the Cape Fear River. This industry has the potential to be a significant discharger of 1,4 dioxane based on their manufacturing process as well as toxic review inventory submitted annually to EPA. This industry is only required to monitor annually and report according to the newly issued permit This appears to be a discrepancy and Asheboro staff does not understand the difference in permit requirements. Staff feels if we are held to this standard then it should be included in the reasonable potential analysis for all state issued permits and all permit holders should be held to the same set of standards. Staff would like an explanation as to why the term for this permit is only four years. NPDES permits are typically written for 5 year terms. It is understood that we have been operating on an. expired permit for some time but shortening the term of the new permit to four years is a burden not only for city personnel but also DEQ. Please carefully consider all of the above comments before issuing a final permit. Written clarification on all questions posed in this correspondence is requested. I will be glad to discuss any of these concerns with you and appreciate your prompt and thorough response to this matter. Respectfully, / Michael D. Rhoney, PE Water Resources Director Enclosures eCopy: Mr. Gary Perlmutter Ms. Julie Gmzyb Mr. Jeff Poupart Mr. John N. Ogburn, III OTYOF ASHERugfu ROY COOPER Gwrrnor MICHAEL S. REGAN secre@r LINDA CLILPEPPER Daector Michael Rhoney Water Resources Director City of Asheboro PO Box 1106 Asheboro, NC 27204 Dear Mr. Rhoney: NORTH CAROLINA awk%narrrtafQuaRtf July 22, 2019 Subject: Additional Monitoring Requirements Asheboro WWTP NPDES Permit No. NCO026123 The City of Asheboro has been conducting effluent monitoring for 1,4-dioxane since December 2017 as part of the Division's investigation into sources of this compound. Compliance with a set limit may or may not be technologically feasible and it appears most of the reductions will have to be achieved at the industrial source. As a result, the Division has developed a Management Strategy for emerging compounds to seek reductions through Municipal pretreatment programs by requiring industrial users to reduce, treat, or eliminate discharges of these compounds. This process is expected to take time given that these compounds have been used and discharged for years as unregulated compounds. The goal will be to seek reductions that will result in Water Supply stream concentrations below EPA recommended health advisories and for Permittees to eventually attain or comply with any NC state criteria or standards adopted by the state. At this time the Division is requesting the City provide their corrective action plan for locating and reducing sources of 1,4-dioxane. If you have already taken measures outline any past activities, the outcomes from those activities and any future plans. Please submit your plan to the PERCS Branch by September 23, 2019. Please contact me at (919) 707-3624 or Julie Grzyb at (919) 707-3605 or via email (Iirstname, last name ft ncdenr.goy) if you have any questions or concerns. S rely, Deborah,am`Gore, P`EE—Rllc,)CSS Supervisor Cc: Central Files Regional Operations, WSRO NPDES Permit File North Carolina Department ofpminn ntal Quality I Division of Water Resources �E 512 North Sallshury Street 11617Mail Service Center I Ralel9h. North Carolina 27699-1617 �\-Jpv 919.707.9000 ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. John N. Ogburn, III City of Asheboro P.O. Box 1106 146 N Church Street Asheboro, NC 27204 Dear Mr. Ogburn: NORTH CAROLINA Environmental Quality January 10, 2019 Subject: Additional Nutrient Monitoring Requirements Asheboro WWTP NPDES Permit No. NCO026123 Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in Title 15A of the North Carolina Administrative Code, Subchapter 02H, specifically, 15A NCAC 02H .0112(b)(1) and 02H .0114(a), the Director of DWR may reopen a permit to require supplemental nutrient monitoring of the discharge. Per this letter, the Director is requiring additional nutrient monitoring at the subject facility's effluent as specified below: Monitoring fortotal phosphorus (TP), total nitrogen (TN), total Kjeldahl nitrogen (TKN), and Nitrite+Nitrate (NO2+NO3) shall be increased to weekly starting on April 1, 2019 and lasting through December 31, 2020. Nutrient monitoring shall revert to sampling requirements as specified in the facility's NPDES permit starting January 1, 2021. The additional monitoring results shall be submitted in the Discharge Monitoring Reports. The additional monitoring will be used to support water quality modeling efforts within the Cape Fear River Basin. Specifically, the additional monitoring will help ensure that nutrient loadings from permitted facilities are represented as accurately as possible in the model, which will include both point and non -point sources. North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1611 Mall Service Center I Raleigh, North Carolina 27699-1611 For more information on the modeling project, please visit https:Hdeg.nc.eoy/about/divisions/Water-resources/r)lannin /modeline-assessment/special- studies#MCF. If you have any questions, please contact Pamela Behm, DWR Modeling and Assessment Branch Chief (pamela.behm@ncdenr.eov. (919) 807-3687). Sincerely, Jeff Poupart Water Quality Permitting Section Chief Division of Water Resources Cc: NPDES File DWR / Winston-Salem Regional Office / Water Quality DWR / Modeling & Assessment / Pam Behm DRAFT Pit NC0026441 A.(9.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS (conL) 4. Sfenatory Requirements iSupplements Part H, Section B. (11.)(b) and Supersedes Section B. (113(d)] All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11)(b). A person,, and not a position,, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR systems registering for eDMR and obtaining an eDMR user account, please visit thefollowing web page: http://deq.nc.gov/about/divisions/water-resources/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTTER STATEMENTS OF CERTIRCATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." 5. Records Retention (Supplements Part II, Section D. (6.)] The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. A.(10.) COMPLIANCE SCHEDULE FOR TOTAL NITROGEN LIMIT [G.S.143-215.1(b)] a. The Permittee shall comply with the Total Nitrogen limits in Special Condition A.(1.) in accordance with the following schedule. See also Condition A.(11.), Treatment Optimization - Total Nitrogen. b. Schedule of Interim and Final Actions. Due Date Due Date Scheduled Action (Optimiiatton) (Upgrade) Start — Actual start date of Mountalre Farms discharge to Slier ! WWTP. .-....._...__.......... _-- ..--_..........__._..... Start + 3 months — Complete acclimation period, begin nitrogen optimization study. ............_ ...__...__. _..._.._ ...__.... . _ _........_ _ . ......._ _.... _......_........_...._. . Start + 13 months — Complete nitrogen optimization study per Condition A.(11.). Start + 19 months — Evaluate results of study, prepare study report, lnduding methods, findings, and recommendations, and submit to DWR for review. Start + 22 months — Upon acceptance of report by DWR.. Implement optimization measures immediately per DWWs written acceptance. Alternative 1: If the accepted study concludes that optimization measures are sAdent to meet the TN limit in Condition A.(1.) and plant Improvements requiring an Authorization to Construct are not necessary, continue to implement optimization measures as accepted and: 1/1/2023 Comply with the TN limit. ........... ...._.__. .............._.._ ._...._. ___..................-.......___...._..._._ ___._...._ . __ ........__._... .. _._ . _..........._ ............. . Compliance schedule ends, Allemative J. Alternative 2: If the optimization study indicates that plant Improvements requiring an Authorization W Construct are necessary to meet the TN limit in Condition A.(i.), continue to Implement optimization measures as accepted and: 4/1/2021 fComplete design rom DWR &/or oft the Improvements and apply for Authorization to Construct permit Part I, Page 9 of 11 DRAFT PermitNC0026441 Due Date Due babe Scheduled Action. 1Qpdintization) �tlpgade) 8/1/2021 Obtaln Authorization to Construct permit. 10/1/2021_._._..__Advertise and award contract. 10/1/2022 Complete c%sUuaft of improvements. 1/1/2023 Comply with TN limits. Compllanae sdWyle ends, A/l .=#w 2. C. No later than 14 calendar days following a due date in the above schedule of compliance, the Permittee shall provide written notification of its progress to the Division of Water Resources. If an action is not completed by the specified date, the Permittee shall also describe the cause of noncompliance and any steps planned or taken to comply with the remainder of the schedule. d. For the purposes of this condition,, written submittals or notification to the Division should be sent to the following addresses: NC DEQ/ Division of Water Resources NC DEQ/ Division of Water Resources NDPES Wastewater Programs Raleigh Regional Office Attn: Julie Grzyb, Supervisor Attn: Danny Smith,, Supervisor 1617 Mail Service Center 3800 Barrett Drive Raleigh, NC 27699-1617 Raleigh, NC 27609 A.(11.) TREATMENT OPTIMIZATION - TOTAL NITROGEN [G.S.143-215.1(b)] a. The Permittee shall undertake a study to evaluate the ability of operational changes and other low-cost measures to reduce its TN discharge load when treating process wastewaters from the Mountaire Farms facility along with its municipal wastes. b. Performance Targets. The initial aim of the study is to determine if optimization of the existing plant can achieve an effluent IN concentration of 6.0 mg/L or less when treating process wastewaters from Mountaire Farms. If the plant cannot consistently achieve 6.0 mg/L, the aim of the study will then be to determine what concentration it can achieve; the working target in this case is 30% reduction of IN loads through the plant. C. The Permittee shall complete this study and submit a report to the Division according to the schedule in Condition A.(10.), Compliance Schedule for Total Nitrogen Limit. d. Study Report. The Permittee shall provide a brief written report of its findings to the Division at the addresses below. The report shall include, at a minimum, the following information: e. f. i. A description of the approaches chosen for evaluation and the rationale for their selection; ii. A summary of the methods used and the findings of the study, including the effectiveness of each alternative approach, iii. A budgetary estimate of the potential costs of implementing each alternative found to be effective; iv. The estimated effluent TN concentrations and loads that the existing plant can reasonably and consistently achieve using these methods; and V. A proposal describing the methods the Permittee proposes to use to minimize its effluent TN loads and indicating whether plant improvements are necessary to meet its TN limits. For the purposes of this condition, written submittals or notification to the Division should be sent to the addresses in Condition A.(10.)(d.). Upon the Division's request, the Permittee shall make available any monitoring results or other information relevant to this evaluation. Part I, Page 10 of 11 � III G^1h>R Asheboro � City of Asheboro All -America Cliy 146 North Church Street Post Office Box 1106 Asheboro, North Carolina 27204-1106 allM 8/1/2018 Linda Culpepper Interim Director Division of Water Resources — 1611 Mail Service Center Raleigh, NC 27699-1611 Re: Contaminate of Emerging Concern 1,4 Dioxane Dear Ms. Culpepper: C�C�C IWI AUG - 6 2018 D DIVISION OF WATER RESOURCES On behalf of the City of Asheboro, I would like to thank you for all the work that has been done by you and your staff regarding all Contaminates of Emerging Concern. 1,4-Dioxane has become a frontline issue and City of Asheboro staff has been working diligently to find a resolution that will not only protect downstream families, communities, and recreational uses but also prevent undue hardships on our City, industries, and families. In March 2015, Asheboro began meeting with Greensboro and Reidsville Staff to discuss similarities, potential sources, and brainstorm solutions. Asheboro employees began trunkline monitoring to identify sources within the collection system. Asheboro staff reached out to all industrial users. Starpet, Inc. was identified as a source. In an effort to continue their record of environmental stewardship, they began discussions with the City and began researching treatment options on their own accord. Unfortunately, 1,4-Dioxane is a by-product of their manufacturing process so they cannot just simply stop a single product line or discontinue a product use without shutting down the entire facility permanently. Starpet, Inc. manufactures PET plastics from raw materials and is an EPA Categorical Significant Industrial User, 40 CFR Part 414.40, under the City's pretreatment program. EPA has identified this industry as a source of 1,4-Dioxane due to byproduct formation but has not set any discharge limits under the pretreatment program. Starpet has an exceptional compliance record and consistently works with Asheboro staff on any concerns or questions that arise. Starpet employs 93 people and produces 1.6 million pounds of plastic resins daily. Their parent company, Indorama Ventures, is the world's largest producer of PET. Starpet has recently communicated their intent to install a treatment system to reduce their 1,4-Dioxane discharge. They have spent countless resources and traveled to other countries to Phone: (336) 626-1201 www.asheboronc.gov Fax: (336) 626-1218 find a treatment system that has been verified and will be a reliable solution. This treatment system will cost them millions of dollars to install plus an annual operating cost that has yet to be communicated but we understand to be significant. Starpet has chosen to install the best available technology they could locate and they continue to research other technologies that are being tested for their success rates. Asheboro commends them on their proactive approach to lower their environmental impacts and our hope is that downstream communities will see results from these efforts. Considering all of this information, the treatment system can only decrease Starpet's discharge to 1000 ug/L in optimal operating conditions. Downstream communities are fighting for their drinking water to be 0.35 ug/L based on EPA 1 in 1,000,000 cancer risk guideline. Asheboro understands the concerns and wants to be protective of downstream families. Aside from shutting down a major industrial user who has done everything they can to be environmentally responsible and potentially keeping new industries from coming to North Carolina, the technology simply does not exist to get Asheboro wastewater discharge to that level. Asheboro has already seen a 92% reduction in 1,4-Dioxane concentrations since monthly sampling began in December 2017 and staff is confident they will see a further reduction once Starpet gets treatment built, installed, and operational. We all must work together to assess the immediate public health and environmental concerns of 1,4 dioxane. We must also balance how the presence of 1,4-Dioxane in the environment relates to the actual health risk and provide guidance to achieve customer buy -in that we are in fact working to clean their drinking water. As technology advances we will be able to analyze and find more pollutants that are in our nation's waters. Starpet has been manufacturing PET plastics in their Asheboro location under various ownership since 1995 and has not changed their process aside from expansion. Therefore, Asheboro is asking that you leave the proposed limit of 149ug/L listed in the draft permit with BMP practices pending federal leadership or the availability of new treatment technologies. Si rely, David H. Smith Mayor y 4 Asheboro VVWTP (NC0026123) Public Comments and Responses Comments to the draft Asheoro WWTP NPDES permit (NC0026123) were received from the City of Asheboro, dated 5/31/2018. Comments and responses are below: • Comment: "The WWTP staff requested mass based limits for ammonia in lieu of concentration based limits during the March 29, 2018 meeting at the WWTP [site visit]. Upon review of historical data, mass based limits are attainable. What was the rationale for not using mass based limits in the draft permit? Asheboro is requesting a three year compliance schedule to research alternative treatment options that will allow for consistent compliance if mass based limits are not allowed. " Response: Concentration -based limits are in the permit because EPA water quality criteria for ammonia (i.e., 1.0 mg/L summer, 1.8 mg/L winter) are expressed as concentrations, not mass, and are based on concentration -based toxicity studies. A three-year compliance schedule will be added to the permit. • Comment: "Chloride has consistently been sampled in conjunction with Toxicity testing in previous permit cycles. Asheboro has never failed toxicity based on the chronic results and has had an excellent track record for passing toxicity testing. Explain what factors, data and calculations the Reasonable Potential Analysis are based on and confirm how this number is obtained. " Response: EPA is allowing the use of Action Level Policy for the Chloride standard for protection of aquatic life. The RPA was conducted on 15 sample concentrations ranging from 68 to 300 mg/L, collected from March 2014 — December 2017. The RPA results showed that the chloride standard of 230 mg/L could be violated with a maximum predicted value of 351 mg/L. However, since Asheboro is passing toxicity tests, only monitoring is required. This is consistent with DWR's Action Level Policy for toxic substances (15A NCAC 2B .0200). Note: EPA has requested the removal of implementation of the action level policy in conjunction with the Chloride standard in the next NC Water Quality Standard Triennial Review. Therefore, Asheboro will likely receive a limit of 230 mg/L in the next permit renewal. Asheboro should use this permit cycle as an opportunity to assess sources of chloride and how it can reduce this pollutant so that the limit can be achieved in the next permit cycle. • Comment: "Staff reviewed historical influent and effluent data for Cyanide collected since 2010. During this time no samples ever resulted in above detect for the influent. However, a period of seven days in September of 2015, three effluent samples resulted in a detection of cyanide. Upon review of the lab bench sheets, the data indicates that there was an interference with the test method in these samples and therefore these data points should have not been used or reported. A copy of relevant bench sheets are attached with this correspondence. All samples collected from March 2, 2010 to June 4, 2015 and after September 22, 2015 have been recorded as non -detects <0. 01 mg/L (one was <0. 005mg1L). The maximum data point used to show reasonable potential for cyanide should not be considered in light of this interference as it is not an accurate reflection of Asheboro WWTP effluent. Asheboro requests the limit and monitoring requirements for cyanide be removed. " Response: Review of lab sheets by DWR Permitting and Inorganic Chemistry branches found no definitive evidence of either presence or absence of sample interference. Because of the possibility that there was no interference and that the abnormally high numbers (all slightly above 10 µg/L) are real, results of the RPA that included the detected values will remain and therefore the limits for Cyanide in the draft will remain in the permit. Page 1 of 4 Asheboro WWTP (NC0026123) Public Comments and Responses • Comment: "Asheboro Staff is actively exploring alternatives in how to meet the new boromodichloromethane limit. We would like to request a two year compliance schedule to evaluate our disinfection process and determine how to effectively reduce our bromodichloromethane concentrations but continue to properly disinfect the wastewater in order to continue to protect the stream end environment. " Response: The requested compliance schedule will be added to the permit. Comment: "Asheboro staff is aware of the concern associated with 1,4 dioxane and will be able to comply with the terms of the three year compliance schedule. However, Asheboro is not inclined to regulate an industry that may be discharging 1,4 dioxane based on the inconclusive data regarding the health effects of this parameter and the lack of enforceable stream standards. We feel identifying the sources of this contaminant is crucial. However, any sources found should have ample opportunity to provide options of reducing or eliminating the contaminant while properly budgeting funds which are anticipated to be substantial. Asheboro believes after the sources are identified, then a set of standards should be developed and limits applied. Staff would like an explanation of the legal basis and calculations for the 149,ug/L limit in this draft permit. " Response: The limit of 149 µg/L for 1,4-Dioxane is based on a Reasonable Potential Analysis for the human health criterion of 80 µg/L in non -water supply waters. The criterion is based on a calculated 1 in 1,000,000 cancer risk from fish consumption per 15A NCAC 02B .0208. DWR has consulted with Asheboro, who identified its industrial user Starpet Inc., a thermoplastics manufacturer, to be the major source of 1,4-Dioxane in the effluent. According to Asheboro, the industry is pursuing treatment technology for 1,4-Dioxane in its waste stream; Asheboro has offered alternate limits considered achievable based on the treatment technology. DWR has evaluated the proposed alternate limits against the originally proposed limit, taking into consideration of downstream user's comments (see below). • Comment: "Staff has discovered a NPDESpermit issued to DAK Americas (permit # NC0003719 — included with this correspondence) dated March 20, 2018 in the Cape Fear River Basin — direct discharge to the Cape Fear River. This industry has the potential to be a significant discharger of 1,4 dioxane based on their manufacturing process as well as toxic review inventory submitted annually to EPA. This industry is only required to monitor annually and report according to the newly issued permit. This appears to be a discrepancy and Asheboro staff does not understand the difference in permit requirements Stafj`feels if we are held to this standard then it should be included in the reasonable potential analysis for all state issued permits and all permit holders should be held to the same set of standards. " Resyonse: The DAK Americas permit has a monitoring only requirement for 1,4-Dioxane to determine whether this facility discharges the contaminant in detectible amounts, given the concern of 1,4-dioxane in the Cape Fear River basin as a whole. The only historical 1,4-Dioxane data generated by the facility was in 2003, well before the implementation of EPA Test Method 164.1 in 2017, and under process that has since changed. Asheboro has generated sufficient data to perform an RPA, with concentrations in exceedences of the human health criterion of 80 µg/L in non-WS waters. Page 2 of 4 Asheboro WWTP (NC0026123) Public Comments and Responses • Comment: "Staff would like an explanation as to why the term for this permit is only four years. NPDES permits are typically written for S year terms. It is understood that we have been operating on an expired permit for some time but shortening the term of the new permit to four years is a burden not only for city personnel bur also DEQ. " Response: Permit terms are typically five years and are scheduled per river basin. The Cape Fear River Basin permit renewal schedule is 2016, 2021, and 2026. DEQ has accumulated a backlog of permit renewals in recent years, and Asheboro's permit was among those affected. Because of this backlog, Asheboro permit renewals are currently off the basin schedule. To bring Asheboro back in line with the basin schedule, permit cycles are adjusted to four-year terms: 2016, 2022, and 2026.Once returned to the basin -schedule, permit terms will be readjusted to five years. Comments were received from Mick Noland (Fayetteville Public Works Commission, PWC), Jim Fletchner (Cape Fear Public Utility Authority, CFPUA, Wilmington), Victor Czar (City of Sanford), and Jeff Adkins (Town of Cary) via e-mail on June 8, 2018. All commenters represent municipalities with water supply concerns of 1,4-Dioxane. Comments are summarized as follows: . • All commenters ask the Division to consider the designated uses of the river downstream in 1,4- Dioxane limit development. • PWC, CFPUA and Sanford representatives request that other sources of 1,4-Dioxane be considered in developing limits. • CFPUA cites the EPA health advisory for 1 in 10,000 cancer risk of 35 µg/L in drinking water. • Sanford cites the water supply criterion of 0.35 µg/L and requests DEQ conduct an analysis to determine if the 149 µg/L limit is protective of the 0.35 µg/L criterion at the WS-IV classified water downstream at the confluence of Governors Creek with the Deep River. • CFPUA requests the compliance schedule be reduced; PWC and Sanford request a 2 yr compliance schedule • PWC requests a public hearing • PWC will consider legal action should DWR not consider downstream WS and other sources in limits development Response: DWR has performed calculations to determine 1,4-doxane concentrations at the downstream WS boundary using the mass -loading formula: Load (lb/day) = Conc. (mg/L) x Flow (MGD) x 8.34 (conversion factor). The proposed limit of 149 µg/L would result in a concentration of 2.48 µg/L at the WS-IV boundary at the Governors Creek confluence. To meet the 0.35 µg/L downstream WS criterion an effluent concentration would need to be 20.6 µg/L or less, assuming no other potential sources were considered. Recent collections by DWR Ambient Monitoring System revealed a concentration of 2.65 µg/L in the Deep River below Randleman Lake and upstream of the Deep River's confluence with Hasketts Creek, representing additional source(s) of the contaminant. Using the mass -loading formula, the 2.65 µg/L concentration was calculated to be 0.74 µg/L at the WS-IV boundary, exceeding the 0.35 µg/L water - supply criterion and thus leaving no allocation to Asheboro. The source of the Randleman Lake concentration, which is also a WS-IV waterbody, is likely a combination of industrial users to an upstream WWTP and leaching from the former Seaboard Corporation Superfund groundwater remediation site. Page 3 of 4 A Asheboro WWTP (NC0026123) Public Comments and Responses Based on Starpet's treatment estimates, technology based limitations, including a 60 µg/L-based load limit and a 97 µg/L monthly average concentration limit, were proposed by Asheboro to DWR for evaluation. A load limit of 4.50 lb/day was calculated using the mass -loading formula. At the permitted flow of 9.0 MGD, both the load limit and concentration limit resulted in downstream concentrations at the WS boundary lower than those from the previously proposed limit 149 µg/L. Therefore, both proposed limits will be placed in the permit based on Best Professional Judgement that provide greater downstream protection that is reasonably achievable by Asheboro. The 4.50 lb/day load limit aims to assure that as flow increases, 1,4-Dioxane concentrations will decrease, thereby providing downstream water quality protection while allowing flexibility for the WWTP and its industrial user to increase flow. The 97 µg/L monthly average limit aims to prevent load -based effluent concentrations from rising with low flows to levels exceeding the 80 µg/L criterion at the receiving stream (e.g., at 2 MGD, the 4.50 lb/day load maximum would yield an effluent concentration of 269 µg/L), thereby providing further protection of downstream water quality. These revised 1,4-Dioxane limits are proposed with a compliance schedule ending December 15, 2020, based on the SIU's proposed completion of treatment installation by the end of 2019. To further protect downstream water, Starpet will be required to continue 1,4-Dioxane optimization after achieving compliance to further reduce concentrations entering and passing through Asheboro WWTP. Page 4 of 4 Perlmutter, Gary From: Swanson, Beth Sent: Thursday, June 14, 2018 11:59 AM To: Perlmutter, Gary Cc: Cumbus, Michael W; Ibrahim, Magdi; Byrd, Roy; Satterwhite, Dana Subject: RE: Cyanide bench sheets Mr. Perlmutter, As Roy mentioned, he also submitted Asheboro's benchsheets to the laboratory certification branch to take a look at the data. While it is true that the matrix spikes had acceptable recovery, there were some issues with the method they used which could render that moot. First, they used 20 mL of sample and 20 mL of the standard to prepare the matrix spike. This is an issue because it is diluting the sample matrix by half with a "clean" matrix, so interferences could presumably be diluted out too. Second, they prepared the matrix spike after the sample went through distillation. The matrix spike is to go through all sample preparation steps, including distillation. Interference during distillation could have been missed. This is not to say that we are asserting there was interference, but we believe the data lends some question to the possibility. I talked further with Bernadine so that we could fully understand what the benchsheets were showing us. They did indeed believe that there was some interference from nitrate in their samples. While they did not get a terribly high nitrate result on the sample (6 mg/L) they did note that even after adding sulfamic acid at differing volumes as a troubleshooting aid, the nitrate strips that they use to check the samples prior to analysis kept showing some amount of nitrate in the samples. The following is found in Standard Methods 4500 CN B-2011(3)(h): Nitrite may form HCN during distillation in Methods C, G, and L through reaction with organic compounds. Nitrate also may reduce to nitrite, which can react further with thiocyanate. Add at least 2 g sulfamic acid at time of sample collection and before dechlorination or basification to avoid nitrite interference. As I said, we cannot definitively say one way or the other whether this interference existed, but believe it bears consideration when reviewing their permit. Please let us know if you have any further questions. Sincerely, Beth Beth Swanson 919 733 3908 x259 office Technical Assistance/Compliance Specialist Division of Water Resources- WW/GW Laboratory Certification North Carolina Department of Environmental Quality From: Byrd, Roy Sent: Tuesday, June 05, 2018 3:42 PM To: Perlmutter, Gary <gary.perlmutter@ncdenr.gov> Cc: Cumbus, Michael W <Michael.Cumbus@ncdenr.gov>; Swanson, Beth <beth.swanson@ncdenr.gov>; Ibrahim, Magdi <m agd i. i bra h i m @ ncde n r.gov> Subject: RE: Cyanide bench sheets Hi Gary, I reviewed the data with my lead chemist in Wet Chemistry, Magdi Ibrahim, and found no evidence of interference. We confirmed what you said about no designation for interferences in the "Checks" column. Furthermore, the sample from 9/15/2015 was duplicated and spike with acceptable results. The spike recovery was 96%, which is acceptable and generally indicates no interference in the sample. I have copied Michael Cumbus and Beth Swanson, auditors with our Laboratory Certification Branch. They may have additional comments, since the lab is certified by our program. Best Regards, Roy Byrd From: Perlmutter, Gary Sent: Tuesday, June 05, 2018 12:03 PM To: Byrd, Roy <rov.bvrc1@ncdenr.Rov> Subject: Cyanide bench sheets Dear Roy, Thanks for taking my request to look over bench sheets to see if the Permittee's claim of interference is accurate. The permit I'm working on is Asheboro WWTP (NC0026123), whose draft is currently under Public Comment. The Permittee's comments are as follows: "Staff reviewed historical influent and effluent data far Cyanide collected since 2010. During this time no samples ever resulted in above detect for the influent. However, a period ofseven days in September of2015, three effluent samples resulted in a detection of cyanide. Upon review of the lab bench sheets, the data indicates that there was an interference with the test method in these samples and therefore these data points should have not been used or reported. A copy of relevant bench sheets are attached with this correspondence. All samples collected from March 1, 2010 to June 4, 2015 and after September 21, 2015 have been recorded as non -detects <0.01 mg/L (one was <0.005mg1L). The maximum data point used to show reasonable potential for cyanide should not be considered in light of this interference as it is not an accurate reflection of Asheboro WWTP effluent. " I don't see evidence of interference, but perhaps I'm not reading the sheets right. I appreciate your lab's opinion. Thanks again, Gary Perlmutter Gary B. Perlmutter, M.S. Enivronmental Specialist II NPDES Complex Permitting Unit NC DEQ / Division of Water Resources / Water Quality Permitting 919 807 6385 office 919 707 9000 main office gary. oerl m utterA ncd en r. gov Physical Address: 512 North Salisbury St., Raleigh, NC, 27604 Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. DARSWEIL L ROGERS, COMMISSIONER �S FAYETTEVILLE PUBLIC WORKS COMMISSION WADE R. FOWLER, IR., COMMISSIONER 955 OLD WILMINGTON RD EVELYN 0. SHAW, COMMISSIONER P.O. BOX 1089 D. RALPH HUFF, III, COMMISSIONER H ME OWN UTILITY FAYETTEVILLE. NORTH CAROLINA 28302-1089 DAVID W. TREGO, CEO/GENERAL MANAGER TELEPHONE (910) 483-1401 W W W FAYPWC.COM June 8, 2018 VIA EMAIL: g_ary.perlmutternancdenrg_ov Mr. Gary Perlmutter NCDEQ — Division of Water Resources 1612 Mail Service Center Raleigh, NC 27699-1612 Subject: Fayetteville Public Works Commission Comments on Draft NPDES Permit for City of Asheboro Wastewater Treatment Plant (NC0026123); Randolph County, NC Dear Mr. Perlmutter: The North Carolina Department of Environmental Quality — Division of Water Resources (DWR) issued a public notice of the draft NPDES permit for the City of Asheboro's Wastewater Treatment Plant (W WTP) on May 9, 2018 and the comment period is open through June 8, 2018. Located within the Cape Fear River basin, this facility discharges to Hasketts Creek which is a tributary of the Deep River. This WWTP has a pretreatment program for the applicable industries that discharge to its collection system. Fayetteville Public Works Commission (PWC) has a surface water intake on the Cape Fear River downstream of this discharge and is providing comments on this draft permit based on protecting its and other water systems water supplies. PWC has reviewed the draft permit considering the known levels of 1,4-dioxane, an emerging contaminant, in the Cape Fear River. PWC is providing relevant background information and presenting alternatives to the proposed permit limit for 1,4-dioxane. This is a very important public health issue for water supplies in the Cape Fear River basin and we believe a public hearing is appropriate to get additional public comment before issuance of the final NPDES permit. Backuound on 1.4 Dioxane Monitoring data in the Cape Fear River watershed collected by both DWR and a researcher at North Carolina State University (NCSU) has identified the presence of 1,4-dioxane. This chemical is most often used as a stabilizer in chlorinated solvents, paint strippers, and waxes. It is found as an impurity in antifreeze and aircraft deicing fluids, is a by-product in the manufacturing of polyethylene terephthalate (PET) plastics, and may be present in manufactured food additives, food packaging materials, and pesticides. It moves easily from soil to groundwater, as it does not stick to soil particles but is soluble in water. Environmental Protection Agency's (EPA) technical fact sheet for 1,4-Dioxane, dated November 2017, further characterizes it as completely miscible in water, making it highly mobile and not readily biodegradable in the water environment. Described by the (EPA) as a "likely human carcinogen," this chemical compound is also identified by the EPA as an emerging contaminant. The U.S. Department of Health and Human Services also considers 1,4-dioxane as "reasonably anticipated to be a human carcinogen." BUILDING COMMUNITY CONNECTIONS SINCE 1905 AN EQUAL EMPLOYMENT OPPORTUNITY EMPLOYER Mr. Gary Perlmutter Page 2 June 8, 2018 EPA's risk assessment resulted in a drinking water health advisory with an associated estimated lifetime cancer risk of one in one million at a concentration of 1,4-doxane of 0.35 µg/L. Human exposure may occur through ingestion of contaminated food (including fish from contaminated waterways) or water and through skin contact. Conventional WWTPs and water treatment plants are not capable of removing this compound. With these characteristics, PWC is concerned with how and where this compound enters the Cape Fear River watershed upstream of its drinking water intake. In accordance with the water quality standards regulations (15A NCAC 02B.0208), DWR calculated protective values for 1,4 Dioxane (CAS # 123-91-1) are 0.35 ug/L in Water Supply classified waters, and 80 ug/L in Class C waters. The calculation of 0.35 ug/L is protective of consuming water and consuming fish (WS Classified waters). The 80 ug/L is based upon the risk of consuming only potentially contaminated fish (Class Q. These numbers are based upon the carcinogenicity of the compound from information obtained from the US EPA IRIS database. 1.4-Dioxane in the Cape Fear River Monitoring of this compound in the Cape Fear continues to show its presence in both main tributaries, the Deep and Haw Rivers, as well as in the Cape Fear River. DWR completed a study from 2014 through 2016 on the Cape Fear River Basin and published results in February 2017. Monitoring is continuing and so far, four primary sources were identified, with three identified as municipal WWTPs. This further supports the premise that the municipal treatment facilities are not removing 1,4-doxane with current treatment practices, and sources are likely industrial facilities discharging to the WWTPs. This study includes conclusions that further reductions will be necessary to achieve federal and state health advisory levels in the Cape Fear River. City of Asheboro WWTP Draft NPDES Permit The City of Asheboro's draft NPDES permit includes a limit of 149 µg/L of 1,4-doxane with a compliance schedule of 3 years. Based on the information provided in the fact sheet for the draft NPDES permit, PWC believes this limit is not sufficient to protect downstream water supplies. Also, since downstream waters currently have 1,4-Dioxane levels above the water supply criterion, we believe the compliance schedule is too slow . Table 1 includes the data and parameters used by DEQ to arrive at a limit of 149 µg/L. Using the combined flows from the discharge and the annual average streamflow as reported in the fact sheet as well as the instream criteria of 80 µg /L, one can derive the calculated proposed permit of 149 µg/L. This calculation was made under the assumption that all Hasketts Creek loading of 1,4-doxane is entirely attributed to the Asheboro WWTP and there are no upstream sources. However, such an assumption seems to be inherently unreasonable in light of the information cited above. Table 1 City of Asheboro Draft NPDES permit parameters Parameter Units Permitted discharge 9 MGD, converted to 14 cfs From fact sheet Annual average streamflow 12 cfs From fact sheet Instream criteria 80 µg/L To be met in mixing zone Mr. Gary Perlmutter Page 3 June 8, 2018 Water Supply Watershed Considerations PWC is concerned that the approach used above to calculate the draft permit limit for 1,4- dioxane improperly considers only the Class C waters near the discharge and not the water downstream classified for water supply (WS) (as required by 15A NCAC 02B .0203 PROTECTION OF WATERS DOWNSTREAM OF RECEIVING WATERS). These concerns are outlined below for the Deep River water supplies as well as for PWC's water supply in the Cape Fear River further downstream. Deep River — The calculation of the Asheboro permit limit for 1,4-dioxane does not consider downstream WS waters nor other sources of this contaminant in the Deep River watershed. Hasketts Creek discharges into the Deep River and literature shows that 1,4-dioxane is not readily biodegradable in the water environment. Thus, the mass discharged can be assumed to move downstream with little or no losses through sedimentation or biodegradation. Sampling conducted by NCSU has detected low levels of 1,4-dioxane in the Deep River upstream of the confluence with Hasketts Creek. In addition, the water supply (WS) segment for former Gulf- Goldston Sanitary District intake and Lee County/Sanford is located on the Deep River before its confluence with the Haw River. At this location, the water supply criterion of 0.35 µg/L should be met. Using watershed size and the USGS gage at Moncure (downstream of the Lee County intake), it is estimated that the annual average stream flow is approximately 1,000 cfs. Using that as a dilution factor, the loading from the Asheboro WWTP alone would produce an instream concentration of 2.0 ug/L at the Gulf-Goldston and Lee County/Sanford (WS) segments. This value is well above 0.35 µg/L and would be much higher during low flow conditions that frequently occur. PWC has estimated the permit limit that would be necessary to meet the WS criterion at Gulf- Goldston. Using the estimated average annual stream flow of 1,000 cfs and a water supply criterion of 0.35 µg/L, the permit limit from Asheboro WWTP would need to be less than 15 µg/L if the Asheboro WWTP is the only source of 1,4-dioxane considered. DWR should also consider other sources of 1,4-dioxane which would lower this permit limit further. Cape Fear River PWC has also been conducting monthly monitoring for 1,4-dioxane upstream of its intake as well as at its intake. Data collected since May 2014 show an average instream concentration of 2.5 µg/L, as shown in Table 2 (at end of letter). This value is also above the water supply criterion of 0.35 µg/L. DWR monitoring results included in the 2-year report published in 2017 show similar levels, with most records between 2 and 4 µg/L. If Asheboro WWTP were the only 1,4-dioxane source at 149 µg/L at permitted flow contributing at PWC's intake, it is estimated that the concentration would still be above the water supply criterion at about 0.45 µg/L. This estimate was made using the average annual stream flow at Cape Fear River USGS gage 02104000 in Fayetteville. Under low flow conditions approaching the 7Q 10 flow, the concentration would be above 4 ug/L at Asheboro's permitted flow and above 2 ug/L if they were discharging at 50 percent of their permitted flow. Clearly, DWR needs to consider downstream WS waters in calculating permit limitations for dischargers. Efforts are needed throughout the Cape Fear River basin to reduce discharges of 1,4-dioxane to receiving streams. Request for Public Hearing We believe the issue of 1,4-dioxane has been flying under the radar because of other emerging contaminant issues in the Cape Fear River and that many people are unaware of concerns over this contaminant. Since Asheboro is the first of several NPDES permits in the river basin that will have limitations for 1,4-dioxane, we believe DWR should conduct a public hearing to fully inform the public and get public and water utility concerns over their approach to regulating this contaminant. Mr. Gary Perlmutter Page 4 June 8, 2018 Concluding Comments PWC appreciates your consideration of our requests for protection of, the Cape Fear River as a water supply source for PWC and many other communities in the Cape Fear River basin, through continued efforts to reduce 1,4-dioxane entering in the watershed. Clearly, the proposed permit limit included in Asheboro WWTP's draft NPDES permit is not low enough to protect downstream water supplies and should be reconsidered. Treatment technologies including oxidation approaches can be used by either the Asheboro WWTP or the industrial facilities discharging into the Asheboro WWTP to reduce 1,4-dioxane. We believe further efforts to inform the public and get input on this contaminant is necessary. Even with continued dilution downstream in the Cape Fear River, 1,4-dioxane inputs from the Deep River and Haw River are resulting in concentrations higher than the 0.35 µg/L water supply criterion at PWC's intake. PWC believes the situation in the river basin and the rules require that as other NPDES permits are renewed in the watershed, additional WWTPs will receive limits for 1,4-dioxane such that the combined discharges will not result in levels that are higher than the criterion at classified water supply segments. We also believe that an appropriate compliance schedule for meeting these requirements is 2 years, rather than the 3 years proposed in the Asheboro draft NPDES permit since current levels well exceed the 0.35 ug/L water supply criterion. We believe expedient actions are needed to reduce 1,4-dioxane levels sufficiently to protect human health for drinking water supplies and that compliance can reasonably be achieved within 2 years. The cost of compliance should be borne by either Asheboro or the industries that discharge into the Asheboro WWTP rather than the innocent downstream users.. If DWR does not begin to consider downstream water supply uses as well as the multiple sources of this pollutant in watershed in the development of NPDES permit limits, PWC will consider administrative and legal appeals to protect its water supply. If you have any questions or require fiuther information concerning this letter please feel free to contact Mick Noland at (910) 223- 4733 and mick.noland@ja)Twc.com. Respectfully submitted, Fayetteville Public Works Commission q Mick Noland Chief Operations Officer Water Resources Division Cc: Linda Culpepper Shelia Holman Table 2 Data Collected by Fayetteville PWC P.O. Hoffer WTF Intake cµg/L) 5/13/14 3.90 6/12/14 2.90 7/10/14 5.70 8/4/14 3.80 9/4/14 2.10 10/23/14 2.50 11/12/14 9.60 12/9/14 2.40 1/13/15 2.10 2/11/15 1.80 3/17/15 1.60 4/7/15 2.40 5/13/15 4.50 6/16/15 2.20 7/15/15 1.50 8/18/15 2.50 9/22/15 4.80 10/28/15 2.30 11/11/15 0.99 12/28/15 0.28 1/11/16 1.30 2/24/16 1.50 3/16/16 1.20 4/13/16 1.40 5/11/16 3.90 Table 2 Data Collected by Fayetteville PWC P.O. Hoffer WTF Intake (µ9/L) 6/14/16 1.80 7/20/16 2.90 8/23/16 0.59 9/20/16 1.50 10/26/16 0.67 11/28/16 1.40 12/27/16 1.20 1/26/17 5.00 2/22/17 4.80 3/16/17 1.90 4/5/17 2.30 5/3/17 0.81 6/20/17 2.20 7/13/17 0.76 8/15/17 0.66 9/19/17 3.00 10/12/17 2.30 11/14/17 2.50 12/11/17 2.40 1/10/18 5.40 2/21/18 3.90 3/13/18 1.70 4/11/18 1.60 Note: Data collected by Fayetteville PWC P.O. Box 3729 Sanford, NC 27331-3729 June 8, 2018 Julie A. Grzyb 1634 Mail Service Center Raleigh, NC 27699-i634 Dear Ms. Grzyb, CfV of snnfvrb (919) 775-8231 FAX: (919) 775-8179 Email: victor.czar@sanfordnc.net Victor I. Czar, P.E. Public Works Director The following is a statement of our concerns regarding the pending issuance of a discharge permit to the City of Asheboro, North Carolina. We received the Asheboro permit that is going to public notice on May 9th, 2019. As we understand it, the 1,4-dioxane limit of 149 ug/L is based on the 80 ug/L water quality criteria for Class C waters and the instream dilution factor to which they are entitled. We feel it's important to review this limit to make sure it is protective of downstream water uses. 15A NCAC 02B .0203 states "Water quality based effluent limitations or management practices for direct or indirect discharges of waste or for other sources of water pollution will be developed by the Division such that the water quality standards and best usage of receiving waters and all downstream waters will not be impaired." In reviewing the NC Surface Water Classifications map it appears there is a WS1 and WS IV classification just downstream of the confluence of the Deep River and Big Governors Creek, where the criteria for water supplies is 0.35 ug/L. As such, we feel DEQ should conduct some type of analysis to determine if the 149 ug/L limit is protective of the 0.35 ug/L criteria at the downstream water supplies. In developing permit limits to reduce 1,4-Dioxane in the Asheboro discharge, the Division of Water Resources (DWR) does not appear to have considered downstream water supply use in the river basin. Thus, the permit limit for 1,4-Dioxane appears to be at least 10 times higher than it should be to protect downstream water supplies. The calculation of the permit limit also did not consider other sources of 1,4-Dioxane in the river basin. Asheboro's NPDES permit is the first of several to be issued this summer in the river basin that will address 1,4-Dioxane levels. We believe it is important that DWR address this issue comprehensively with the perspective of water supply use throughout the Cape Fear River basin, and not just based on contaminant concerns near the point of discharge. Additionally, since the known sources of Dioxane have been aware of this problem for a number of years, the City of Sanford believes that compliance should be achieved in two years given the exposure of citizens located downstream that are drinking the water. RECEIVED JUN 1 1 Z018 NC PWS Thank you for your time concerning this matter. We look forward to your consideration. .ncerely, an Victor I. Czar, P.E. Director of Public Works Sanford, NC VC/vrc Cc: Jessica C. Godreau Perlmutter, Gary From: Jeff Adkins <Jeff.Adkins@townofcary.org> Sent: Friday, June 08, 2018 9:36 AM To: Perlmutter, Gary Cc: Jamie Revels Subject: [External] Comments on Draft NPDES Permit for City of Asheboro's Wastewater Treatment Plant Mr. Perlmutter, On behalf of the Town of Cary, I am submitting comment on the Division of Water Resources' (DWR) Draft NPDES permit for the City of Asheboro's Wastewater Treatment Plant. A public notice of the draft NPDES permit was posted May 9, 2018. The Town is interested in protecting water supplies which utilize the Cape Fear River and its tributaries. Cary has reviewed the draft permit considering the known levels of 1,4-dioxane, a contaminant of emerging concern, in the Cape Fear River. While Cary's water supply is Jordan Lake (Haw River Basin) and Asheboro's discharge does not directly impact the Town's water supply, adequate treatment for 1,4-dioxane is a very important public health issue for water supplies in the Cape Fear River basin, and the approach taken for Asheboro is likely to influence permit limits established for other discharges which would be upstream of Jordan Lake as well. DWR completed a study from 2014 through 2016 on the Cape Fear River Basin including monitoring for 1,4-Dioxane; the results were published in February 2017. Monitoring is continuing and so far, four primary sources were identified, with three identified as municipal WWTPs. It appears that municipal treatment facilities are not capable of removing 1,4- dioxane with current treatment practices, and sources are likely industrial facilities discharging to the WWTPs. This study includes conclusions that further reductions will be necessary to achieve federal and state health advisory levels in the Cape Fear River. One of the sources of 1,4-Dioxane in the Deep, Haw and Cape Fear Rivers is the City of Asheboro's wastewater treatment plant (W WTP) discharge into a tributary of the Deep River. We ask that DWR consider downstream water use in the river basin in developing permit limits to reduce 1,4-Dioxane in the Asheboro discharge. Asheboro's NPDES permit is the first of several to be issued this summer in the river basin that will address 1,4-Dioxane levels. We believe it is important that DWR address this issue comprehensively with the perspective of water supply use throughout the Cape Fear River basin, and not just based on contaminant concerns near the point of discharge. We appreciate DWR's efforts to ensure applications for NPDES discharge permits protect downstream water use and public health, and encourage you to further consider the appropriate limits to place on 1,4-Dioxane for this and similar discharge permits. Please feel free to contact me if you need additional information. Best Regards, Jeff Adkins C. Jeff Adkins, PE Water Resources Manager TOWN Of CARY PO Box 8005 1 Cary, NC 27512-8005 316 N. Academy Street Cary, NC 27513 Office: (919) 462-2066 Mobile: (919) 710-2335 Email: ieff.adkins@townofcarv.ore Email sent to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to third parties. Perlmutter, Gary From: Jim Flechtner <jim.flechtner@cfpua.org> Sent: Friday, June 08, 2018 12:07 PM To: Perlmutter, Gary Cc: Beth Eckert, Lindsey Hallock; Carel Vandermeyden; Frank Styers; Peg Hall Williams Subject: [External] Draft Permit Comment Mr. Perlmutter, Cape Fear Public Utility Authority (CFPUA) provides drinking water to approximately 200,000 people in the City of Wilmington and greater New Hanover County. We maintain and operate three drinking water systems, and our largest system uses the Cape Fear River as its source water. After reviewing the City of Asheboro's draft NPDES permit, we have concerns regarding the draft 1,4 Dioxane permit limit of 149 ug/L and its potential to impact our community's drinking water supply. The EPA has established a lifetime drinking water health advisory level for this compound of 200 ug/L and a health advisory for one in ten thousand cancer risk at 35 ug/L. While health advisory levels are non -enforceable, they are meant to provide public water suppliers with necessary guidance to ensure they are protecting public health to the best of their ability. Many water treatment plants are not able to remove 1,4 Dioxane. Others, such as our Sweeney Water Treatment Plant, remove approximately 66% (on average) of the concentration that enters our intake at Lock & Dam #1. As a result, many of the public drinking water intakes downstream of this segment of the basin will have the potential to be impacted by the discharge of this compound. In developing permit limits for 1,4-Dioxane in the City of Asheboro discharge, we ask that the Division of Water Resources (DWR) consider both the designated uses of the river downstream of this discharge location and other sources of this compound that may be affecting levels in the River. Treating for these compounds at the source, in a manner consistent with existing drinking water health advisory levels, will minimize impacts to downstream communities that may otherwise be required to install or increase treatment at the cost of their communities to ensure protection of public health. Additionally, because the existence of 1,4 Dioxane in wastewater discharge has been recognized for several years, we request the draft compliance timeline of three years should be reduced to ensure downstream exposure to this compound is minimized as quickly as possible. Asheboro's NPDES permit is the first of several that may be issued this summer that will address 1,4-Dioxane levels. We appreciate the efforts of DWR to communicate with other users of the River, and to issue limits for compounds such as 1,4-dioxane. CFPUA believes it is important to address this issue comprehensively by considering water supply uses throughout the Cape Fear River Basin. Regards, James R. Flechtner, PE Executive Director Cape Fear Public Utility. Authority 910-332-6669 2 Water Resources Division 146 N Church Street PO Box i1o6 Asheboro, NC 27204-11o6 May 31, 2018 it CITY OF AsHE3oIzo NORTH CAROLI NA Mr. Gary Perlmutter NCDEQ — Division of Water Resources Water Quality Permitting Unit 1617 Mail Services Center Raleigh, NC 27699-1617 Re: Comments for Draft Permit NCO026123 Dear Mr. Perlmutter: Tel: 336-626-1201 Ext. 258 Fax: 336-626-1218 RECEIVED/DENR OWR JUN 0 7 2018 Water Resources Permitting Section Thank you for your work in preparation of the above referenced permit. City of Asheboro Wastewater Treatment personnel have some questions and concerns regarding monitored contaminants and limits listed in the draft permit. Asheboro would like some modifications to the draft permit before final issuance. The following notes and requests should be considered before issuing the final NPDES permit. The WWTP staff requested mass based limits for ammonia in lieu of concentration based limits during the March 29, 2018 meeting at the WWTP. Upon review of historical data, mass based limits are attainable. What was the rationale for not using mass based limits in the draft permit? Asheboro is requesting a three year compliance schedule to research alternative treatment options that will allow for consistent compliance if mass based limits are not allowed. Chloride has consistently been sampled in conjunction with Toxicity testing in previous permit cycles. Asheboro has never failed toxicity based on the chloride results and has had an excellent track record for passing toxicity testing. Explain what factors, data and calculations the Reasonable Potential Analysis are based on and confirm how this number is obtained. Staff reviewed historical influent and effluent data for Cyanide collected since 2010. During this time no samples ever resulted in above detect for the influent. However, a period of seven days in September of 2015, three effluent samples resulted in a detection of cyanide. Upon review of the lab bench sheets, the data indicates that there was an interference with the test method in these samples and therefore these data points should have not been used or reported. A copy of the relevant bench sheets are attached with this correspondence. All samples collected from March 2, 2010 to June 4, 2015 and after September 22, 2015 have been recorded as non -detects <0.01mg/L (one was <0.005mg/L). The maximum data point used to show reasonable potential for cyanide should not be considered in light of this interference as it is not an accurate reflection of Asheboro WWTP effluent. Asheboro requests the limit and monitoring requirements for cyanide be removed. Asheboro Staff is actively exploring alternatives in how to meet the new bromodichloromethane limit. We would like to request a two year compliance schedule to evaluate our disinfection process Home of the NC Zoological Park NC 0026123 Draft Permit Comments 5/31/2018 Page 2 of 2 and determine how to effectively reduce our bromodichloromethane concentrations but continue to properly disinfect the wastewater in order to continue to protect the stream and environment. Asheboro staff is aware of the concern associated with 1,4 dioxane and will be able to comply with the terms of the three year compliance schedule. However, Asheboro is not inclined to regulate an industry that may be discharging 1,4 dioxane based on the inconclusive data regarding the health effects of this parameter and the lack of enforceable stream standards. We feel identifying the sources of this contaminant is crucial. However, any sources found should have ample opportunity to provide options for reducing or eliminating the contaminant while properly budgeting funds which are anticipated to be substantial. Asheboro believes after the sources are identified, then a set of standards should be developed and limits applied. Staff would like an explanation of the legal basis and calculations for the 149 ug/L limit in this draft permit. Staff has discovered a NPDES permit issued to DAK Americas (permit # NC0003719 — included with this correspondence) dated March 20, 2018 in the Cape Fear River Basin — direct discharge to the Cape Fear River. This industry has the potential to be a significant discharger of 1,4 dioxane based on their manufacturing process as well as toxic review inventory submitted annually to EPA. This industry is only required to monitor annually and report according to the newly issued permit. This appears to be a discrepancy and Asheboro staff does not understand the difference in permit requirements. Staff feels if we are held to this standard then it should be included in the reasonable potential analysis for all state issued permits and all permit holders should be held to the same set of standards. Staff would like an explanation as to why the term for this permit is only four years. NPDES permits are typically written for 5 year terms. It is understood that we have been operating on an expired permit for some time but shortening the term of the new permit to four years is a burden not only for city personnel but also DEQ. Please carefully consider all of the above comments before issuing a final permit. Written clarification on all questions posed in this correspondence is requested. I will be glad to discuss any of these concerns with you and appreciate your prompt and thorough response to this matter. Respectfully, / Michael D. Rhoney, PE Water Resources Director Enclosures eCopy: Mr. Gary Perlmutter Ms. Julie Grzyb Mr. Jeff Poupart Mr. John N. Ogbum, III CITY OF ASH"L- 0 0 WATER RESOURCES Asheboro W WTP Cyanide Date influent Effluent 3/2/2010 4 <0.01 3/4/2010 <0.011Y 6/8/2010 <0.01 <0.01 9/14/2010 <0.01 <0.01 12/7/2010 <0.01 <0.01 2/18/2011 <DA1 <0.01 2/17/2011 <0.01 <0A1 3/3/2011 <0.01 <0.01 4/19/2011 <0.01 <0.01 5/11/2011 <0.01 <0.01 6/7/2011 <0.01 <0.01 7/14/2011 <0.01 <D.01 8/18/2011 <0.01 <0.01 9/22/2011 <0.01 <0.01 10/4/2011 <0.01 <0.01 11/15/2011 <0.01 <0.01 12/6/2011 <0.01 <0.01 1/10/2012 <0.01 <0.01 3/6/2012 <0.01 40.01 6/12/2012 <0.01 <0.01 9/22/2012 <0.01 <0.01 12/4/2012 <0.01 <0.01 3/5/2013 <0.01 <0.01 6/4/2013 <0.01 <0.01 9/17/2013 <0.01 <0.01 12/12/2013 <0.01 <0.01 3/4/2014 <0.01 <0.01 6/19/2014 <0.01 <0.01 9/9/2014 <0.01 <0.01 12/4/2014 <0.01 <0.01 3/10/2015 <0.01 <0.01 3/24/2015 <0.01 6/2/2015 <0.01 <0.01 6/4/2015 <0.005 9/15/201s <0.01 0.018 9/18/2015 0.012 9/22/2015 0.017 9/22/2015 " <0.01 9/23/2015 <0.01 12/8/2015 <0.01 <0.01 1/13/2016 <0.01 <0.01 2/11/2016 <0.01 <0.01 3/14/2016 <0.01 <0.01 4/14/2016 <0.01 <0.01 5/5/2016 <0.01 <0.01 6/14/2016 <0.01 <0.01 7/14/2016 <0.01 <0.01 8/17/2016 <0.01 <0.01 9/19/2016 <0.01 <0.01 10/19/2016 <0.01 <0.01 11/2/2016 <0.01 <0.01 12/6/2016 <0.01 <0.01 3/7/2017 <0.01 <0.01 6/8/2017 <0.01 <0.01 9/19/2017 <0.01 <0.01 12/5/2017 <0.01 <0.01 3/6/2018 <0.01 <0.01 • Correlption Coefficient=-O oqi 381('7 . City off �heboro y-Intercept = . o o 12 'Department of Water Quality Date Verifieed = Cyanide Method: Methods kj- Method: 4500-CN- C E -1997 Sample Source Checks Pres. Date Int. Ck Date Collected a b c d H Y . _ __ - p Distilled (ml} Final Absorb Sol n ml ( } ml Reacted Absorbance Reading ug CN ppm CN Remarks arld 4 l led 4-0 0,00-7 0- Z7ooV 0. ea) 0 -- - __ . 0.0 5-0 d i s i t � j 0. �$ . !�. o'•i (to . O. a5�.o = l b� �G 0. 0 5a _ _ o 5'b 40 0. i(�a 0.040 0 .. 10 o4 5VO 0 ' 0.5ZS 0.0477 � . 9 $ 14444LaW- r ldo% -- - • S 4-0 O.O 3 0. 007 Z. 'e- 0.01 a i5b .40 n•o2( 0.0025 _ .40.0to 40 .0- tom 40. of �f�' o . or Q, -�e P� � S b 40 D.10�3 0. 0 t Z 4 0. c7Z20* � W S ;kb 20, 0--WC 0.OZ�jo o.1T351A. cA 5 -- _' 40 0. H 16 0- o 40 7 O .nsl • 00 rivr+ 1- - . j 2� O d l3S - t0, 0/ 2-0 4_O-3C� 1 Ck 1 � Strb 1 - 2 � - )J4 a 5-0 5D 40 O � 0 ,y 4W-71 O0 .d0, •�. 0t a • •An(Nf)..)- r:hcark = �_7(i ' ml latcrfctvacc Checks: a) Chlorioo, b) SulSdes, a) AbIdW&s, d) Nitutto/Nitritc • Thar Chock: ail 1000 Rpm standard X 10 s mt 11f00 ppm stock diluted to 1000 ad nequitcd to make a 10 ppm standard ml Ag(N(hh tittaut CN, mgA + (mal +b ) X LO0 X.N. where: X Y X a absotgtion solution, m1 to a slope of standard curve Y = arighw sample, mh b — itit reept on c axis .t new -a-- MILO > r%-_-.i->.._ w. Correlon Coefficient -- Slope.( y-Intercept = Date Verified = City of•�~-heboro Department otWater Quality Cyanide I Sample Source Checks Int. �C Date Pres. Distilled ' Final Absorb mi Absorbance _Date By Collected a b c d q. pH -(ml) Sol'n (ml) Reacted Reading 5-D . O.10Co1 I Con SD--� 50 . 4.0 . D-OZ` / � ' v 4 O,O c6 40 0.0,Z) COW 0-05 . 4 D. qqS 0. o. 0 V x Zp Z40.05Z KWD. U Ag(NO,)2 Check = I Standard Methods Method: 4500-CN- C E -1997 ug CN i ppm CN ( Remarks O--Oa%P -- -0-0• O l 0 —. r D• col � a.o t .� 0 010 -- 0,0023 < o.o 1 a Tom= 0% - D .00-r7 ; 4-o_ot o-- O. O C70 O- o ZZ - - � O_0g0Y O;OG'O 0006 i } b� 01 a --- __ - - I } 1 Interference Chocks: a) Chlorine. b) Sulfides, e) Aldehydes, d) NdratKTitnto Titer Chock: pal 1000 o w ; X 10 a ml- 1000 ppm stock dilated to 1000 ml required to make a 10 ppm standard ml Ag(NO3h titrant CN, mg%l + (mal + b) X 32 X 19, where: X Y X - absorption solution, ml m - slope of standard curve ml Y - original sample, ml b a intercept on c axis M = + Dannfas I f R RAnnrfshio parsimoto.o CorreJAon Coefficient=Q.Rq"l"l 010117 City of,�heboro �- Slope" : 0, 0q0 '�L+(0 y-Intercept = . d •VDO I4- Department OT-Water Quality Date Verified = 5• Standard Methods Cyanide Method: 4500-CN- C E -1997 Sample Source Checks Pros. Distilled Final Absorb ml Absorbance Date Int. Date Collected a b c * d pH (ml) I Soi'n (ml) Reacted Reading ug CN ppm CN Remarks —'. _ - �. -W" --�.-- 40 SW 0. 4 40 0 540- 0.0 0 5 0.0 0 1 caz PI?..3 0.299 E -�• + _ Sc� sa 40 i ° - ° s •�� _ .._._. o -�ZA O.Z��v.o 32/ o.Q=1D l Z o "IJ _ _ _ i23L�d• � oSY) c�.o�� d d O W 5' 107� r�-- • t b 0-IS-7 c9. o t L(3 4D.0171 , -02,&] 0 0 I'l ! -- - - .- - l 0 _S7 (0. 01-4�4 w,2±(O. iq 5D7 X Zlp t0. 055'ZI latafemnee Checks. a) Chlorine, b) Sulfides. e) Aldehydm. •d) Nitratc/Nitiite 4tercbeciL c&LIQQO prnn standard X 10 s mt IWO ppm stock diluted to 1000 ml sequined to make a 10 ppm standard ad Ag(N%)2 tirmn, /Vt C• � l� Cam/ 3�— + (mal + b) X a X M , where: ` X Y �X v absmvdoo solution. m1 m — slope of standard cur" 9 0 C eek = `� } Y - orig€nal sample ml b — irucrr~ fn.— axis s 2 ill + _ nanntac nup mono%reskie Ow•.w.,...:aw..^ Cor Slope C � �enot�--_&.q��3�S1t~7 (;ity O#•�,heboro P vG t, 1"" y-InterCe$t = _ DIM 017,, Lf64 Department 0"r Water Quality Date Verified - �a •1Gk Standard .Methods Cyanide Method: 4500-CN- C E -1997 Sample Source Checks Pres. Distilled F_inai Absorb ml Absorbance Date Mt. tic Date Colieded a b c d pH (MI) Sorn (ml) Reacted Reading ug CN ppm CN Remarks .9 . . . . . . . - 4 andiijted ---j — , " ti ski � - __ �.Oo3 O•cP)s oaf 4o o tot o.ot)q q 0.01 Z nit Aso 4o 0-0315 .dd ! �o•0to 1w 5-0 4D o• 1D% 0. ovga O •o t 2 n�� y '2 q.. - - . _54) 4� 0. 0 3(0 0.00 3v ; � o• 10 � Sze � ! o. i e 4- n• o 1 l0 8 1 o- O a l 40 D. 18Itev 0 - 't-vj 0 t s e4t LP 28g .40 - aoc-)j o.000 le.0-00 _ 4w a. - ' 2 o. W-3 0• 0 Lea 1O.-OSOS-1 0 T1,1116 Pw Chocks: a) Cxtlorine b) Sut&dm o) Aldahydaa. d) NitraWNibite Teter Check: col 1000 gpm standard X 10 - Mt IOib ppm stock ddutod to 1000 mt mquired to make a 10 ppm standard rat AS(140� titrant CN, m&4 + (mal + b) X SQ X 5O , where: X Y' X — absorption solution, ml m — stops of standard curve Ag(NO�,)2 Check = ml Y a oregmat , mt bz intercept o. c axes + = nanntoe nup po w#•shies (�w�.....w�w.... _ .. _ ---... - - - -•----L---..c._-........ .. . KZ Water Resources &KbMONNFNTAL OUALITY March 20, 2018 Mr. Matthew P. Hendrickson, Site Manager DAK Americas 3216 Cedar Creek Rd. Fayetteville, North Carolina 28302 Dear Mr. Hendrickson: ROY COOPER MICHAEL S. REGAN S """v' LINDA CULPEPPER Subject: Draft NPDES Permit Renewal Permit NC0003719 DAK Americas W W'IP Cumberland County Class 2 Facility Luninl Onram Enclosed with this letter is a copy of the Draft NPDES permit renewal for your facility. Please review this draft carefully to ensure thorough understanding of the requirements and conditions it contains. The draft permit public noticed on October 31, 2017 included TSS limits based on ELGs and BPJ. The BPJ limits for BOD and TSS applicable to Clear Path Recycling were calculated using 95% reduction within the treatment system. The Division acknowledges that this approach was erroneous for calculating TSS limits and recalculated the TSS limits based on 85% reduction. Since the TSS limits are less stringent than in the previous draft permit a second public notice is needed. The draft permit includes the following changes from your previous permit: • Limits for BOD, TSS and toxic pollutants for Outfall 002 were modified based on the effluent guidance limits and the updated production flows for DAK Americas and Clear Path Recycling. • Requirements for Outfall 001 were modified to reflect typical cooling water monitoring requirements. Although this is a combined outfall discharging cooling water and stormwater it is considered a wastewater outfall for permitting purposes. • Annual monitoring for mercury was added at outfall 002 in accordance with the implementation of the 2012 Statewide Mercury TMDL. • Annual monitoring for 1,4 Dioxane was added at outfall 002. 1,4 Dioxane is a pollutant of concern in the Cape Fear River. The Division is implementing monitoring to gather data on this pollutant. • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted Suae Of Nonh CMUM I Fmnm n•1Qu1ilyl% rRewlmxx 1617 Mail Servitt Ce r I Rakigk Nonh C Iim 27699.1617 919 a07 6300 Page 12 and became effective on December 21, 2015. The requirement to begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your final NPDES permit. [See Special Condition A. (7)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: htt ;ON.nc.aov/sbout/divisions/water- resources/edmr. For more information on EPA's final NPDES Electronic Reporting Rule, please visit the following web site: https://www.fedemlreizister.gov/documents/2015/10/22/2015-24954/national-pollutant- discharge-elimination-system-npdes-electronic-reportingrule. • The NPDES Standard conditions (Parts IL III, and IV) are not included with this draft. They can be found at the following link to review them in conjunction with this draft permit: https://degnc.govinenmitting farms. Concurrent with this notification the Division is publishing a notice in a newspaper having circulation in the general Cumberland County area, soliciting public comments on this draft permit. Please provide any written comments you may have to the following: NCDEQ/DWR, NPDES Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 no lager than 30 days after receipt of this draft permit. Following the 30-day public comment period, the Division will review all pertinent comments and take appropriate action prior to issuing a final permit. If you have questions concerning this draft permit, please call me at (919) 807-6387or by email at Teresa.rodriguez@ncdenr.gov. Sincerely, Teresa Rodriguez, Engineer NPDES Complex Permitting Unit Hardcopy: NPDES Files Ecopy: US EPA Region 4 DWR/Wastewater Operator Certification/Maureen Kinney DWR/Aquatic Toxicology Branch/Susan Meadows DWR/Fayetteville Regional Office /Water Quality NC0003719 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PDES) In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, DAK Americas LLC is hereby authorized to discharge wastewater from a facility located at DAK. Americas LLC - Cedar Creek Site 3468 Cedar Creek Road, Fayetteville Cumberland County to receiving waters designated as the Cape Fear River in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective This permit and authorization to discharge shall expire at midnight on October 31, 2021. Signed this day Linda Culpepper, Interim Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 11 NCO003719 PART I A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS OUTFALL 002 [I5A NCAC 02B .0400 et seq., 02B .0500 et seq.] Dung the period begummg on the effective date of this permit and lasting until expiration, the Permattee is aWwnzed to discharge fram3 OWsII 002. Such discharges shall be h=ted and monitored by the PermtUm as specified below: EffiaeYrt CharacbmMcs Monibaring ulreme�nts Mont*Daily Average Maximum Messar Frequency Sample Type Sample Location 1 Flow 0 300 MGD Continuous Recording I or E Total Suspended Solids CTss) 192 lbs /day 347 lbs/day I/Week Composite 2 E BOD3, 20°C 143 lbs /day 2441be /day 1/Week cbmposite2 E NH3 N (April 14)ctober 31) 13 lbs /day 261bs /day I/Week Composite 2 E NH3 N (November 1— March 31) 26 lbs /day 52 Is /da 1/Week Co 2 E Fecal Coliform c mean I/Week Grab E Total Residual C hlorme 28 1/Week Grab E Temperature 3 I/Week Grab E Dissolved mysm3,1 I/Week Grab E H 6 to 9 S U I/Week Grab E Total Nitrogen (NO2 + NO3 + TIN I/Quarter to 2 E Total Phosphorus 1/Quarter Composite 2 E Acute Toaimity 3,6 1/Quarter Composite 2 E Dissolved Oxygen? 1/Week Grab U & D T (°C) 7 1/Week Grab U & D conductivity7 1/Week Grab U & D Footnotes: 1 E w Effluent, I = Influent, U — upstream 2 mi from Outfall D - downstream,100 yards upstream of Lock and Dam #3 2. Composite samples must be refrigerated 3 The Pernuttm shall collect the effluent samples for dissolved oxygen, temperature and acute toxicity from the boa combining effluents of Outfalls 001 and 002 4 Total Residual Chknu CIRC:) • The Division shall consider all effluent total residual chlorine values reported below 50 µg)L to be in complince with the pernut However, the Permuttee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L 5 Efl3uent dissolved oxygen (DO) shall not fail below 5 mg/L 6 Whole Effluent Toxicity (WET) testing, acute toxicity PAP at 900/9 using Fathead Minnow WET tests shall be conducted in February, May, August and November [See Part A (4 )] 7 Recerving Stream Monitoring — As a member of the Middle Cape Fear River Basin Association, the Pernrttee's mstream momtorumg responsibilities are hereby waived by Memorandum of Agreement However, should this membership ternninate for any reason, the Permme shall notify the Division immediately, and the Permittee slush immediately resume unatream monitoring requirements, as specified herein The Pernuttee shall add no chromium, fine, or copper to the went system except as pre- approved additives to biocide compounds or those resulting from the normal degradation of process piping or equipment The Pennittee shall discharge no floating solids or foam visible to other than trace amounts Page 3 of 11 NC0003719 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 002. Such discharges shall be limited and monitored by the Permittee for OCPSF parameters, as specified below: Effluent Maracteristics Limes Monitoring Requirements DAILY irZAXll1+IUM tla MONTHLY AVERAGE urAWda M t Frequency Sample Type Sample Locaffon Amnq&thene 0.062 0.023 I/Year Grab Effluent Acenaphthylew 0.062 0.023 I/Year Grab Effluent Acrylonitrile 0.256 0.102 I/Year Grab Effluent Antimcene 0.062 0.023 I/Year Grab Effluent Benzene 0.144 0.039 ]/Year Grab Effluent Ben*a)antWuene 0.062 0.023 I/Year Grab Effluent 3,4-Benzofluoranthene 0.065 0.024 ]Near Grab Effluent Benzo(k)fluorandme 0.062 0.023 11Year Grab Effluent Benzo(a)pyrene' 0.726 µg/I 0.726 µg/1 ] /Year Grab Effluent is(2-ethylhexyl) phthalate 0.296 0.109 I/Year Grab Effluent Carbon Tetrachloride 0.40 0.019 I/Year Grab Effluent Chlorobenzene 0.030 0.016 I/Year Grab Effluent Chloroethane 0.284 0.110 I/Year Grab Effluent Chloroform 0.049 0.022 I/Year Grab Effluent 2-Chlorophenol 0.104 0.033 1/Year Grab Effluent Chrysene 0.062 0.023 I/Year Grab Effluent Di-n-butyl phthalate 0.060 0.029 I/Year Grab Effluent 1,2-Dichlorobenzene 0.173 0.082 I/Year Grab Effluent 1,3-DicWorobenzene 0.047 0.033 I/Year Grab Effluent 1,4-Dichlorobenzene 0.030 0.016 ]/Year Grab Effluent I,1 Dichloroethane 0.062 0.023 ]/Year Grab Effluent 1,2 Dichloroethane 0.223 0.072 I/Year Grab Effluent l,l-Dichloroethylene 0.026 0.017 ]]Year Grab Effluent 1,2-trans-Dich1oroethylene 0.057 0.022 I/Year Grab Effluent 2,4Dichlorcphenol 0.119 0.041 I/Year Grab Effluent 1,2-Dichloropropane 0.244 0.162 I/Year Grab Effluent 1,3-DicWoropropene 0.047 0.031 ]/Year Grab Effluent Diethyl phthalate 0.215 0.086 I/Year Grab Effluent '.4-Dimethylphenol 0.038 0.019 I/Year Grab Effluent Dimethyl phthalate 0.050 0.020 I/Year Grab Effluent 4,6-Dinitr+o-o-cresol 0.293 0.083 I/Year Grab Effluent 2,4-Dinitrophenol 0.130 0.075 I/Year Grab Effluent 2,4-Dinitrotoluene 0.302 0.120 I/Year Grab Effluent 2,6-Dinitrotoluene 0.679 0.270 ]/Year Grab Effluent Ethylbenzene 0.114 0.034 ] /Year Grab Effluent Fluomuthene 0.072 0.026 ]/Year Grab Effluent [Part A. (2.) continues on next page] Page 4 of 11 0 !1 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (OCPSF - Continued) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] �E�i�i��lyupent�.. Q fj.•;:i ��a ��1�a �iiW Limits Monitoring Requirements DAMY MAINIUM de(pounds/day)Frequency MONTMY AVERAGE Measurement Sample 'Type Sample Location Fluorene 0.062 0.023 l /Year Grab Effluent Heascblombenzene OA41 µg/L 0.441 µg/L 1/Year, Grab Effluent Hexachlorobutadiene 0.052 0.021 1/Year Grab Effluent Hexachloroethane 0.057 0.022 1/Year Grab Effluent Methyl Chloride 0.201 0.091 1/Year Grab Effluent Methylene Chloride 0.094 0.042 1/Year Grab Effluent Naphthalene 0.062 0.023 1/Year Grab Effluent Nitrobenzene 0.072 0.029 1/Year Grab Effluent 2 Nitmphenol 0.073 0.043 1/Year Grab Effluent 4-Nitcnphenol 0.131 0.076 1/Year Grab Effluent henantbrene 0.062 0.023 1/Year Grab Effluent Phenol 0.029 0.016 1/Year Grab Effluent Pyrene 0.071 0.026 1/Your Grab Effluent Tetrachloroethylene 0.059 0.023 1/Year Grab Effluent Toluene 0.085 0.028 I/Year Grab Effluent 1 2 4-Trichiorobenzene 0.148 0.072 1/Year Grab Effluent 1.11-Trichloroethane 0.057 0.022 1/Year Grab Effluent 1.12-Trichloroethane 0.057 0.022 1/Year Grab Effluent Trichloroeth lene 0.057 0.02 1/Year Grab Effluent Vinyl Chloride 0.476 0.110 1/Year Grab Effluent Total PAR 173 jtg4 173 guil 1/Year Grab Effluent 14 Dioxane Monitor and Report 1/Year Grab Effluent erc Method 1631E Monitor and Report n /1 1/Year Grab Effluent Notes: 1. Water -quality based limit. Page 5of11 NC0003719 NC0003719 A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS OUTFALL 001 (I5A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until permit expiration, the Permittee is authorized to discharge from outfall 001 (Non -Contact Cooling Water and Stormwater). Such discharges shall be limited and monitored by the permittee as specified below: Effluent Characteristics i`nmits Monitoring Requirements Monthly Average Daily Maaimnm Measurement Frequency Sample Type Sample Location 1 Flow Monthl Grab E Total Suspended Solids 30 m /1 100 m n Monthly Grab E Gil & Grease Mondil Grab E Total Residual Chlorine _ 6 to 9 28 'l Monthly Grab E H S.U. Monthly Grab E Notes: 1. Sample Location E- Samples to be collected before comingling with the WWTP effluent. A. (4.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY) [ 15A NCAC 02B .0200 et seq.] The permittee shall conduct acute toxicity tests on a augrjerly basis using protocols defined in the North Carolina Procedure Document entitled ' Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised December 2010 or subsequent versions). The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24-hour static test. The effluent concentration at which there may be at no time significant acute mortality is 90% (defined as treatment two in the procedure document). The tests will be performed during the months of February, May, August, and November. These months signify the first month of each three-month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE6C. Additionally, DWR Form AT-2 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Page 6of11 NCO003719 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 dosetresponse data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three-month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invatlid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A. (5.) BIOCIDE APPROVAL [G.S. 143-215,143-215.1 ] The Permittee shall obtain approval from the Division's Aquatic Toxicology Unit prior to discharging any biocide (not previously approved by the Division) under this permit. Approval for use of any biocide not previously The Permittee shall request approval of any new unauthorized biocide at least 90 days in advance of planned usage. Contact the Aquatic Toxicology Unit for detailed instructions on requesting biocide approval: NC DENR / DWR / Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 A. (6.) LABORATORY TEST -METHOD QUANTITATION LEVELS AND COMPLIANCE [G.S.143-215.66) For any given parameter, the Permittee must apply a state -certified analytical test method with a practical quantitation level (PQL) at or below the NPDES permit limit. If such level of analytical sensitivity is not technologically feasible, the Permittee shall employ a state -certified analytical method with the lowest available test -method PQL, and values reported as "not detected" by this lowest available PQL shall be deemed "compliant" with this permit. Page 7 of 11 NC0003719 A. (7.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215. 1 (b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Reuoartin , Regnirements ISupersedes Section D. (2.) and Section E. (5.) (a)l The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DEQ / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting" section below. Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring data and reports, when appl icable: i o Sewer Overflow/Bypass EvedReports; C Pretreatment Program Annual Reports; and o Clean Water Act (CWA) Section 316(b) Annual Reports. The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). Page 8of11 NC0003719 2. Electronic Submissions In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each electronic submission. The permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR l 27.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: http://www2.epa. , v/comrliancelfinai-national-pollutant-discharge-elimination-sN stem-npdes-electronic- Morting-rule. Electronic submissions must start by the dates listed in the "Reporting Requirements" section above. 3. How to Request a Waiver from Electronic Reporting The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data .and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: htGov/about/divisions/water-resources/edmr 4. Signaton- Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)i All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: htt j)://dei.nc. Lov/about/divisions/water-resou rces/edmr Page 9of11 NC0003719 Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qual fled personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submittingfalse information, including the possibility of fines and imprisonment for knowing violations." S. Records Retention iSuaalements Section D. (6.)l The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41 ]. Page 10 of 11 NC0003719 I It ., Hwy53 v_ / L l „x; R-.•Jt1j�PM., y _ y JIJ DAK Americas W WTP Cumberland County Facility Location (not to scale) Latitude: 34. 58' 08° N Permitted Flow: 0.5 MGD longltude: 78' 46' S8" W Stream Ciass: C . Remlving Stream: Cape Fear River HUC: 03030004 '- Drainage Basin: Cape Fear River Basin Sub -Basin: 03-06.15 N State Grid: H23NE NPDES Permit NC0003719 Page 11 of 11 The Courier -Tribune Public Notice North Carolina Environmental Management Commission/ Affidavit of Publication NPDES Unit 1617 Mail Service Center State of North Carolina, Raleigh, NC 27699-1617 Randolph County Notice of Intent to Issue a NPDES Wastewater Permit To Whom It May Concern: The North Carolina Environmental Management Commission proposes to issue a NPDES wastewater discharge permit to the This is to certify the person(s) listed below. Written comments regarding the proposed advertisement attached permit will be accepted until 30 days after the publish date of this notice. The Director of the NC Division of Water Resources (DWR) hereto has been published in may hold a public hearing should there be a significant degree of public interest. Please mail comments and/or information requests The Courier Tribune to DWR at the above address. Interested persons may visit the DWR on the following dates: at 512 N. Salisbury Street, Raleigh, NC to review information on file. Additional information on NPDES permits and this notice may q _ be found on our website: http://deq.nc.gov/about/divisions/water- L _ resources/water-resources-permits/wastewater-branch/npdes- wastewater/public-notices,or by calling (919) 807-6397. The City of Asheboro has requested renewal of permit NCO026123 for its Asheboro Wastewater Treatment Plant in Randolph County; this �,� permitted discharge is for treated municipal and industrial Sworn to on this"/ da Y wastewater to Hasketts Creek, in the Cape Fear River Basin. of V , 2018. It - 5/9/18 Courier -Tribune Representative Sworn to and Subscribed Before me this day of Pal 1, 2018. Aotaryblic JOSEPHlNi: ViERA COOPER Notary Public, North Carolina Randolph County My Co mi sion Expires M11"an_ Public Notice North Carolina Environmental Management Commission/ NPDES unit 2617 Mall Service Center Raleigh, NC 27699.1617 Notice of Intent to Issue a NPDES Wastewater Permit The North Carolina Environmental Management Commission propos- es to issue a NPDES wastewater discharge permit to the person(s) listed below. Written comments regarding the proposed permit will be accepted until 30 days af- ter the publish date of this notice. The Director of the NC Division of Water Resources (DWR) may hold a public hearing should there be a significant degree of public inter- est. Please mail comments and/or-- GZ information requests to DWR at the above address. Interested per- sons may visit the DWR at 512 N. Salisbury Street, Raleigh. NC to re- view Information on file. Addi- tional Information on NPDES per- mits and this notice may be found on our website: http✓/deq.nc.gov/aboutidivisions /water- reso u rces/water- resources-permits/wastewater- b r a n c h/ n P d e s- wastewater/publlo-notices.or by calling (919) 807-6397. The City of Asheboro has requested renewal of permit NCO026123 for its Ashe- boro Wastewater Treatment Plant In Randolph County: this permit- ted discharge Is for treated mu- nidpal and industrial wastewater to Hasketts Creek, in the Cape Fear River Basin. It - 5/9/18 I �n Al Ion, oa- ROY COOPER Governor MICHAEL S. REGAN secretary LINDA CULPEPPER Interim Director John N. Ogbum, III City of Asheboro P.O. Box 1106 146 N Church Street Asheboro, NC 27204 Dear Mr. Ogburn: NORTH CAROLINA Environmental Quaaty Month xx, 2018 Subject: Second Draft NPDES Permit Renewal Permit NCO026123 Asheboro WWTP, Grade IV Biological WPCS Randolph County SIC Code 4952 Enclosed with this letter is a copy of the second draft NPDES permit renewal for your facility. This second draft is being sent for review and public comment in light of inserting compliance schedules for Ammonia (NH3-N) and Bromodichloromethane, as well as substantial changes regarding 1,4-Dioxane in response to comments to the first draft permit. Please review this draft carefully to ensure thorough understanding of the requirements and conditions it contains. -There— r c angel The following changes were made to the first draft permit sent to you on May 9, 2018: • Section A.-( Effluent Limit i Monitoring Requirements has been modified to insert interim n rnenia_limits plus footnotes for Ammonia and Bromod ^i?'uethane compliance schedules. See eM.mrA '7� �Fototes 4 and 8. • A three-year compliance schedule was added for meeting the more stringent NH3-N limits. See Special Condition A. (6.). • A two-year compliance schedule was added for meeting the Bromodichloromethane limit. See Special Condition A. (7). • 1,4-Dioxane limits were revised from 149 µg/L Monthly Average to a 97 µg/L Monthly Average with an average daily load limit of 4.50 lb/day not to be exceeded. These limits are based on Best Professional Judgement from achievable levels that the WWTP has proposed based on its industrial user's proposed treatment technology efficacy for 1,4- Dioxane reduction. These limits are more stringent than that in the first draft permit in order to better protect downstream water quality as well as taking into consideration other sources of 1,4-Dioxane, which have been identified upstream ofHasketts Creek in the Deep River. North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611 919.707.3601 • The 1,4-Dioxane compliance schedule was shortened from three years to a period ending December 15, 2020 based on a proposed timeline to install treatment technology by the industrial user identified as the primary contributor of 1,4-Dioxane to the WWTP. See Special Condition A. (8.). s,- • A footnote was added to the 1,4-Dioxane limits to require industrial users to continue optimizing 1,4-Dioxane reduction in their effluent to the WWTP. See Section A. (1.), Footnote 12. • A special condition has been added instructing how to calculate 1,4-Dioxane loadings. See Special Condition A. (9.). • A reopener clause special condition has been added to modify 1,4-Dioxane monitoring, treatment and/or compliance. See Special Condition A. (10.). • Section A. (1.), Footnotes 13 and 14 regarding instream monitoring were inserted into Footnote 2. The first draft permit maintains the following significant changes identified in the letter sent on May 9, 2018. • Regulatory citations have been added to the permit. • Parameter codes have been added in Section A. (1.) Effluent Limitations and Monitoring Requirements. • The outfall map was updated to include instream monitoring station locations. • Ammonia -Nitrogen (NH3-N) limitations have been decreased, based on wasteload allocation (WLA) calculation. Limitations for NH3-N are based on protection of aquatic life utilizing an EPA ammonia chronic criterion of 1.0 mg/L (summer) and 1.8 mg/L (winter). The WLA results yielded NH3-N limitations that are more stringent than in the current permit, as tabulated below: . - - Suunnner v `VVnte� - - Sunn�ner- 'V�iter '_ 11onflily Average ~ 2.0 mg/L 4.0 mg/L 1.0 mg/L 1.8 mg/L Weekly Average 6.0 mg/L 12.0 mg/L 3.0 mg/L 5.4 mg/L • Instream Conductivity monitoring was added to the permit, based on the presence of an industrial pretreatment program as specified in Instream Conductivity and Fecal Coliform Monitoring Guidance (NCDWQ internal memo, 2002). However, the Permittees' sampling requirement for this parameter is conditionally waived as long as the Permittee is a member of the Upper Cape Fear River Basin Association. • The NC 2007-2014 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Committee (EMC) on November 13, 2014. The US EPA subsequently approved the WQS revisions on April 6, 2016 with some exceptions. The NC Division of Water Resources NPDES Permitting Unit is required to implement the new dissolved metal standards in all permits public noticed after April 6, 2016. The new standards for most metals include acute standards. Further; the freshwater standards for several metals are expressed as the dissolved form of the metals, and seven metals have Page 2 of 5 hardness -dependent equations. As a result, the NPDES Permitting Unit will need site - specific effluent hardness data and instream hardness data, upstream of the discharge, for each facility monitoring these metals in order to calculate permit limitations. Effluent hardness sampling has been added to this permit at a quarterly monitoring frequency. Upstream hardness sampling has not been added, in recognition of the receiving stream's 7Q10s of 0 cfs, which renders upstream hardness measurements irrelevant in dissolved metals calculations. See Section A. (L). • As part of the NC 2007-2014 WQS Triennial Review, the Total Chromium WQS was removed and replaced with trivalent chromium (Cr-III) WQS and hexavalent chromium (Cr-VI) WQS. Total Chromium is made up of trivalent and hexavalent forms. The reasonable potential analysis (RPA) using Asheboro's Total Chromium effluent data showed potential to violate the new Cr-VI standard. As a result, Total Chromium limits were removed from the permit; quarterly monitoring of Total Chromium and Cr-V1 were added to the permit. Sampling for hexavalent chromium and total chromium together will ascertain if Cr-VI is present in the total chromium samples and thus the effluent. If sampling for Cr-VI indicates that it is not present (i.e. non -detectable concentrations at the lower reporting level of the procedure) after two years of sampling, then the limits and monitoring requirements for Cr-VI in Section A. (1.) can be reduced or removed upon request. See Section A. (1.), Footnote 7. • Currently, EPA is allowing an action level for Chloride, but at the next permit renewal this may not be the case. Your passing record for toxicity tests indicate that a limit for chloride is not necessary at this time, but this may change in the future. Please note that the allowable concentration for Chloride is 230 mg/L. The effluent average from January 2014 through December 2017 was 166 mg/L; and an RPA found a reasonable potential to exceed the allowable concentration. As a result, quarterly monitoring for Chloride in conjunction with toxicity tests is maintained in the permit. • A monthly average limit of 5.0 µg/L and a daily maximum limit of 22.0 µg/L for Cyanide have been added to the permit and samples shall be taken monthly. Results of an RPA on submitted data indicated a reasonable potential to exceed the instream water quality standards. A footnote has been added to the effluent limitations sheet stating that the Division will consider all values reported below 10 µg/L to be compliant due to difficulties in quantifying cyanide in wastewater, but the Permittee shall submit all Cyanide values reported by a NC -certified laboratory, even if values are less than 10 µg/L. See Section A. (L), Footnote 10. • Quarterly monitoring for Total Zinc has been removed from the permit. Review of the data revealed no reasonable potential to exceed water quality standards. Quarterly monitoring shall be maintained per the facility's pretreatment Long Term Monitoring Program (LTMP). • Effluent Mercury data were reviewed from May 2012 to May 2017. The Permittee tested effluent for Total Mercury using EPA test Method 1631 E throughout this period. In accordance with the 2012 Mercury TMDL NPDES Guidance, the Permittee needs to show annual average effluent concentrations below the Water Quality Based Effluent Limitation (WQBEL) of 12.0 ng/L and no exceedance of the Technology Based Effluent Limitation (TBEL) of 47 ng/L. A review of the data showed the annual averages were below the WQBEL and all data were below the TBEL; therefore, no mercury limitation is required. Page 3 of 5 As a result of the TMDL evaluation, the limits and monitoring of mercury have been removed from Section A. (1.). Sampling for mercury will be conducted during the three (3) effluent pollutant scans [see Section A. (3.)] as well as the pretreatment LTMP using EPA Method 1631 E. Fifty-one (51) out of 71 low level effluent mercury samples collected were over 1 ng/L. As a result, a Mercury Minimization Plan (MMP) requirement has been added in this permit renewal [see Special Condition A. (4.)]. Please note that the Permittee shall develop and implement an MMP during this permit term. The MMP shall be developed within 180 days of the NPDES permit effective date; and it shall be available for inspection on -site. A sample MMP was developed through a stakeholder review process and has been placed on the Division website for guidance (https://deq.nc.gov/document/nc-model-mercury- minimization-plan-dwr-nodes-swp-20130801). • A monthly average limit of 31.6 µg/L for Bromodichloromethane has been added to the permit and samples shall be taken monthly. Results of an RPA on submitted data indicated a reasonable potential to exceed the instream water quality standards. • Review of submitted effluent data showed all samples for Total Silver to be less than detection at 5 µg/L. In accordance with 15A NCAC 2B .0500, all test procedures must produce detection and reporting levels that are below the permit discharge requirements and all data generated must be reported to the approved detection level or lower reporting level of the procedure. Currently, DWR's laboratory identifies the Practical Quantification Limit for Total Silver at < 1.0 µg/L. The allowable discharge concentration for Total Silver at your facility is 0.06 µg/L as a monthly average. The Division recommends that the Permittee improves and implements "clean" sampling techniques and analyzes Total Silver to the lower reporting level of the procedure. Quarterly monitoring for Total Silver has been added to the permit. • Some of the wording has changed in Section A. (2.) Chronic Toxicity Permit Limit; please review each paragraph carefully. • Section A. (3.) Effluent Pollutant Scan has been modified to include the three specific years in which the effluent pollutant scans shall be performed: 2019, 2020, and 2021. In addition, at the end of the Special Condition, 2nd species Toxicity Testing Requirements for municipal permit renewals per Federal Regulations [40 CFR 122.210)(5)] have been added. • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. The requirement to continue reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your final NPDES permit. See Section A. (11.). For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://deci.nc.pov/about/divisions/water- resources/edmr. For more information on EPA's final NPDES Electronic Reporting Rule, please visit the following web site: https://www.federalregister.gov/documents/2015/10/22/2015- 24954/national-pollutant-discharge-elimination-system-npdes-electronic-reporting-rule. Page 4 of 5 The NPDES standard conditions (Parts II, III, and IV) that are a part of the permit are not included in this draft document (cover, map, and Part 1). The conditions are the same as in your current permit except that agency and division names have been updated. The latest version is available at httys://bit.ly/2BZ4xxx and can be viewed online or downloaded as a PDF file. Please note that the receiving stream is listed as impaired for Copper and Benthos on North Carolina 2016 Final 303(d) Impaired Waters List. Addressing impaired waters is a high priority with the Division, and instream data will continue to be evaluated. If there is noncompliance with permitted effluent limits and the stream impairment can be attributed to your facility, then mitigative measures may be required. Concurrent with this notification the Division is publishing a notice in a newspaper having circulation in the general Randolph County area, soliciting public comments on this second draft permit. Please provide any written comments you may have to the following: NCDEQ/DWR, NPDES Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 no later than 30 days after receipt of this draft permit. Following the 30-day public comment period, the Division will review all pertinent comments and take appropriate action prior to issuing a final permit. If you have questions concerning this draft permit, please call me at (919) 707-3611 or by email at gary.perlmutter@ncdenr.gov. Sincerely, Gary Perlmutter, Environmental Specialist II NPDES Complex Permitting Unit Hardcopy: NPDES Files eCopy: US EPA Region 4 DWR / Winston-Salem Regional Office / Water Quality Operations DWR/ Wastewater Operator Certification Group / Maureen Kinney DWR / W SS / Aquatic Toxicology Branch / Susan Meadows DWR / Ecosystems Branch / Mark Vander Bourgh City of Asheboro / Water Resources Director / Michael D. Rhoney, PE Jean Zhuang, Southern Environmental Law Center Geoff Gisler, Southern Environmental Law Center Page 5 of 5 Permit NCO026123 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the City of Asheboro is hereby authorized to discharge wastewater from a facility located at the Asheboro Wastewater Treatment Plant 1032 Bonkemeyer Drive Asheboro, NC 27203 Randolph County to receiving waters designated as Hasketts Creek in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof This permit shall become effective Month xx, 2018. This permit and authorization to discharge shall expire at midnight on September 30, 2022. Signed this day Month xx, 2018. DRAFT Linda Culpepper, Interim Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 16 Permit NCO026123 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. The City of Asheboro is hereby authorized to: 1. Continue to operate and maintain the 9.0 MGD wastewater treatment plant with a discharge through Outfa11001, consisting of the following components: • Influent pump station with automatic bar screens and :grit removal • Influent ultrasonic flow meter • Influent composite sampler • Flow splitter box #1 • Seven (7) primary clarifiers; one (1) circular fated for 3.0 MGD, six (6) rectangular rated 1.0 MGD each • Trickling filter mixing/transfer pump basin • Three (3) trickling filters, 140 feet diameter • Recirculation box/valve vault and circulation pump basin #1 • Four (4) secondary clarifiers; 27,024 cu ft. each • Recirculation pump basin #2 • Nitrification mixng/transfer pump basin • Flow splitter box Q. • Two (2) nitrification basins with mixing basin and blowers; 2,000,000 gallons each • Flow splitter box #3 • Magnesium hydroxide chemical addition system • Three:,(3) final clarifiers,, 70,333 cu,y ft. each",,'', • Polymer chemical addition. system • One (1) Parkson Dynasand continuous flow tertiary filter • Chlorine contact chamber with sodium hypochlorite addition for disinfection • Sodium bisulfate addition for`:dichlorination • Effluent flow meter • Effluent composite sampler • Cascade aeration basin • Two (2) sludge digesters; 401,900 gallons each • Drying beds, 105 ft. x 450 ft. total • Sludge dewatering presses, thickener tanks, lime stabilization system, and solids storage • Standby power generation This facility is located at the Asheboro WWTP, 1032 Bonkemeyer Drive, Asheboro, in Randolph County. 2. Discharge from said treatment works via Outfall 001, at the location specified on the attached map into Hasketts Creek currently classified C waters in the Cape Fear River Basin. Page 2 of 16 Permit NC0026123 PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS Parameter code Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Total Chromium (Ng/L) 01034 Monitor and Report Quarterly Composite Effluent stte Effluent Chromiu ,.Monitor-and-R Total Kjeldahl Nitrogen 00625 (TKN) (mg1L) Monitor and Report Monthly Composite Effluent Nitrite + Nitrate Nitrogen 00630 (NO2+NO3) (mg/L) Monitor and Report Monthly Composite Effluent Total Nitrogen (TN) [TN = (NO2+NO3) +TKN] CO600 (mg/L) Monitor and Report Monthly Calculated Effluent Total Phosphorus (TP) (mglL) CO665 Monitor and Report Monthly Composite Effluent Dibromochloromethane 32105 WIL) Monitor and Report Quarterly Grab Effluent Bromodichloromethane a 38693 31.6 Ng/L Monthly Grab Effluent Chlorides (mg/L) 9 00940 Monitor and Report Quarterly Composite Effluent Total Copper (NgIL) 01042 Monitor and Report Quarterly Composite Effluent Total Cyanide 19 00720 5.0 Ng/L 22.0 NgIL Monthly Grab Effluent Total Silver (Ng/L)11 01077 Monitor and Report Quarterly Composite Effluent 1,44Dioxane 12 82388 97 NgIL I Monthly Grab Effluent 1,4-Dioxane Load 1z 13 Daily average loading not to exceed 4.50 lb/day Monthly Calculated Effluent Chronic Toxicity 14 TGP38 Ceriodaphnia Pass/Fail at 90% effluent Quarterly Composite Effluent Effluent Pollutant Scan NC01 Monitor and Report Footnote 15 Footnote 15 Effluent Dissolved Oxygen (mg/L) 2 00300 Monitor and Report Variable 2 Grab U, D1, D2 Temperature (°C) 2 00010 Monitor and Report Variable 2 Grab U. D1, D2 Conductivity (Nmhos/cm) 2 00094 Monitor and Report Variable 2 Grab U, D1, D2 All footnotes are listed on the followine naee. Page 4 of 16 Permit NCO026123 PART I A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (9.0 MGD) [15A NCAC 02B.0400 et seq., 15A NCAC 02B.0500 et seq.] Grade IV Biological Water Pollution Control System [I 5A NCAC 08G .0302] a. During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated municipal and industrial wastewater from Outfall 001 Such discharges shall be limited and monitored' by the Permittee as specified below: PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS , Monthly. Weekly Daily Measurement Sample Sample... Parameter Code _ Average Average Maximum Frequency Type Locate 2 ; Flow 50050 9.0 MGD Continuous Recording Influent or Effluent BODs (20°C) 3 C0310 5.0 m /L g 7.5 m IL . g Dail Y Composite p Influent and (April 1- October 31) Effluent BODs (200C) 3 C0310 10.0 mg/L 15.0 mg/L Daily Composite Influent and (November 1- March 31) s - r f Effluent Total Suspended Solids C0530 30.0 mg/L 45:0 mg/L Daily Composite Influent and (TSS) 3 Effluent Ammonia (NH3 as N) (April 1- October 31) C0610 2 0: mg/L 6.0"mg/L Daily Composite Effluent Interim 4 Ammonia (NH3 as N)" (November 1- March 31) C0610 4.0 mg/L 12.0 mg/L Daily Composite Effluent interim 4 Ammonia (NH3 as N (April 1- Octobo.31) C0610' 1.0 mg/L 3.0 mg/L Daily Composite Effluent Final 4 Ammonia (NH3 as N); ::, (November 1- March 31), C0610 1.8,n glL 5.4 mg/L Daily Composite Effluent final 4 Dissolved Oxygen (DO) 00300 Daily Average > 6.0 mg/L Daily Grab Effluent pH 00400 `Between 6.0 and 9.0 standard units Daily Grab Effluent Fecal Coliform 31616 (geometric mean) 200/100 mL 400/100 mL Daily Grab Effluent Total Residual Chlorine 50060 (TRC) s 17 /L N9 Dail Y Grab Effluent Temperature (°C) 00010 Monitor and Report Daily Grab Effluent Conductivity (Nmhos/cm) 00094 Monitor and Report Daily Grab Effluent Total Hardness [as CaCO3] 00900 (mg/L) 6 Monitor and Report p Quarters Y Composite P Effluent Page 3 of 16 Permit NCO026123 Footnotes: 1. Submit discharge monitoring reports electronically using the NC DWR's eDMR application system. See Section A. (11.). 2. U = approximately 800 feet upstream of the discharge; D1 = downstream at NCSR 2128; and D2 = downstream in the Deep River at NCSR 2261. The Permittee has deferred receiving -stream sampling to the Upper Cape Fear River Basin Association by memorandum of agreement (MOA). Should this MOA terminate for any reason, the Permittee shall immediately inform the Division in writing and immediately resume instream monitoring in accordance with this permit. Instream samples shall be collected three times per week from June 1 through September 30, and once per week from October 1 through May 31. 3. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 4. Interim Ammonia limits shall be effective during the period rof f.the compliance schedule. Final Ammonia limits become effective [within three (3) years of the effective .":Of this permit]. The Permittee shall follow the compliance schedule detailed in Section A. (6.). 5. The Division shall consider all effluent TRC values reported below ' 5'0„µg/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field -certified), even if these values fall below50 µg/L. 6. Effluent Total Hardness sampling shall be conducted in conjunction with testing for hardness -dependent metals (cadmium, chromium, copper, lead, nickel, saver and zinc): 7. If Chromium VI is not detected (i.e. non -detectable concentrations `below the lower reporting level of the procedure) after two years of sampling, the Permittee may", " uest DWR to reduce `or remove monitoring requirements for Chromium VI in Section 8. The Bromodichloromethane limit becomes.. effectrw.e [within two (2) years of the effective date of this permit]. The Permittee shall follow the compliance schedule detailed hi Section A. (7.). 9. Chlorides will be monitored n;conjunction with Chronic Toxicity tests..., 10. Due to difficulties quantifying cyanide in a wastewater imatrix,e Division shall consider all values reported below 10 µg/L to be "compliant" withthis permit; However, the'�Permittee shall submit to DWR all values reported by a North Carolina -certified test method (even if values fall below 10 µg/L), and the Permittee shall consider all reported values when calculating averages, if any, as required by this permit. 11. The Permittee should review and implement clean sampling techniques for Total Silver. The reporting laboratory, shall test -'to the lower reporting level of the procedure. 12. This limit,- becomes effective December 15, 200. The Permittee shall follow the compliance schedule detailed in Section A. (8.) Samples shall. be collected monthly and analyzed using EPA Test Method 624.1; both concentration and load shall be reported monthly. After the effective date, Starpet (industrial user identified as the;.primary source of 1,4-Dioxane) shall continue to optimize treatment to further reduce concentrations. 13. 1,4-Dioxane Load is the mass quantity discharged in a given period of time. See Section A. (9.) Calculation of 1,4-Dioxane Loads.- 14. Whole Effluent Toxicity samples shall be collected during the months of March, June, September, and December. See Section A 15. The Permittee shall preform three Effluent Pollutant Scans during the term of this permit. See Section A. (3.). b. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 5 of 16 Permit NCO026123 A. (2.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) — 9.0 MGD [15A NCAC 02B.0200 et seq.] The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions or "North Carolina Phase H Chronic Whole;, Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be performed during the months of March, June, September and December. These months signify the first month of each three-month toxicity testing quarter assigned to the facility. Effluent saml ling for gthis testing must be obtained during representative effluent discharge and shall be performed at'aTieNPDE$,permitted final effluent discharge below all treatment processes. If the test procedure performed as the first -west of any single quarter. results in a failure or mt, Chronic Value (ChV) below the permit li then multi )le-concentfation testing shall be performed at a minimum, in each of the two following months as described- .:in "North Carolina Phase II Chronic Whole Effluent. -. Toxiicity Test Procedure" (Revised December 2010) or subsequent versions. All toxicity testing results required as part of this ' permit condition will be entered on the Effluent Discharge Monitoring Form..(MR-1) for the months in virrhich tests were, performed, using the parameter code TGP3B for the pass/fail results and THP313 for the Chronic ,value. Additionally, DWR Form AT-3 (original) is to be sent to the following address: NC DEQ / DWR Water Sciences.-Section/Aquatic Toxicology Branch 1621 Mail Service Center " Raleigh; NC 27699-1621 Completed Aquatic:Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end ofthe reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data; and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the Permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity Page 6 of 16 Permit NC0026123 testing quarter, which is the three-month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate followrup testing to be completed no later than the last day of the month following the month of the initial monitoring. Page 7 of 16 Permit NCO026123 A. (3.) EFFLUENT POLLUTANT SCAN (Municipal POTWs) [NCGS 143-215.1 (b)] The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below. One scan must be performed in each of the following years: 2020, 2021, and 2022. Analytical methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether parameters are present in concentrations greater than applicable standards and criteria. Samples should be collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total recoverable." Ammonia (as N) C0610 Chlorine (total residual, TRC) 50060 Dissolved oxygen 00300 Nitrate 00620 Nitrite 00615 Kjeldahl nitrogen 00625 Oil and grease 00556 Phosphorus C0665 Total dissolved solids 70295 Hardness 00900 Antimony 01097 Arsenic 01002 Beryllium 01012 Cadmium 01027 Chromium MOM Copper 01042 Lead 01051 Mercury (Method 1631E) COMER Nickel 01067 Selenium 01147 Silver., 61077 Thallium �� 01069 , . Zinc 01092 . Cyanide 00720 Total phenolic compounds , 32730 Volatile organic compounds: Acrolein 34210 Acrylonitrile 34215 1. Benzene 34030' Bromoform 32104 Carbon tetrachloride 32102 Chlorobenzene 34301 Chlorodibromomethane 34306 Chloroethane 85811 2-chloroethyl vinyl ether 34576 Chloroform 32106 Dichlorobromomethane 32101 1,1-dichloroethane 34496 1,2-dichloroethane 32103 Trans-1,2-dichloroethylene 34546 1,1-ftlomethylene 34501 1,2-dichloropropane 34541 1,3-dichloropropylene , 77163 Ethylbenzene 34371 Methyl bromide 34413 Methyl chloride 34418 Methylene chloride 34423 1;1,2,2-tetrachloroethane - M49 Tetrachloroethylene 34475 Toluene 34010 1,1,1 trichloroethah6. 34506 1,1,2-trichl61roethane .34511 Trichloroethylene 39180. Vinyl chloride 39175 Acid -extractable corriaouhds: P-chloro-m-cresol 34452 2-chlorophenol 34586 2,4-dichlotophenol 34601 2,4-dimethylphenol 34606 4,6-dinitro-o-creso1 34657 2,4=dinitrophenol 34616 2-nitrophenol 34591 4-nitrophenol 34646 Pentachlorophenol 39032 Phenol 34694 2,4,6-t ichlorophenol 34621 Base -neutral compounds: Acenaphthene 34205 Acenaphthylene 34200 Anthracene CO220 Benzidine 39120 Benzo(a)anthracene 34526 Benzo(a)pyrene 34247 3,4 benzofluoranthene 34230 Benzo(ghl)perylene 34521 Benzo(k)fluoranthene 34242 Bis (2-chloroethoxy) methane Bis (2-chloroethyl) ether Bis (2-chlorolsopropyl) ether Bis (2-ethyihexyl) phthalate 4-bromophenyl phenyl ether Butyl benzyl phthalate 2416mnaphthalene 4-chlorop4enyl phenyl ether Chrysene Di-n-butyl phthalate`, Di-n-octyl phthalate Dibenzo(a,h)anthracene 1,2-dichlorobenzene 1,3-dichlorobenzene 14-dichlorobenzene 3,3-dichlorobenzidine Diethyl phthalate Dimethyl phthalate 2,4-dindrotoluene 2,6-dinitrotoluene 1,2-diphenylhydrazine Fluoranthene Fluorene Hexachlorobenzene Hexachlorobutadlene Hexachlorocyclo-pentadiene Hexachloroethane Indeno(1,2,3-cd)pyrene Isophorone Naphthalene Nitrobenzene N-nitrosodi-n-propylamine N-nitrosodimethylamine N-nitnuodiphenylamine Phenanthrene Pyrene 1,2,4-Mchlorobenzene 34278 34273 34283 39100 34636 34292 34581 34641 34320 39110 34596 34556 34536 34566 34571 34631 34336 34341 34611 C0626 34346 C0376 34381 C0700 39702 34386 34396 34403 34408 34696 34447 34428 34438 34433 34461 34469 34551 Page 8of16 Permit NCO026123 Reporting. Test results shall be reported electronically via eDMR or on DWR Form — DMR-PPA 1 (or on a form approved by the Director) by December 31 sl of each designated sampling year. The report shall be submitted to the following address: NC DEQ / DWR / Central Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that Municipal facilities that are subject to the Effluent Pollutant Scan requirements listed above are also subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.210)(5) and EPA Municipal Application Form 2A. The US EPA requires four (4) toxicity tests for a test organism other than the test species currently required in this permit. The second species tests should be conducted either quarterly for a 12-month period prior to submittaf of the permit renewal application, or four tests performed at least annually in the four and one-half year,.penod prior to the application. The second species tests must be multiple concentration (5 concentrations`plus the control). These tests shall be performed for acute or chronic toxicity, whicheveris specified in this permit. POTWs performing NPDES chronic Ceriodaphnia testing should perform chronic Fathead minnow testing. POTWs performing NPDES acute Fathead Minnow testa g�sbould perform acute Ceriodaphnia testing. POTWs performing NPDES chronic Mysid shrimp testing should perform chronic Silverside Minnow testing. The second species toxicity test results-, shall be filed with the Aquatic Toxicology Branch at the following address: NC DEQ / DWR ,. yater Sciences Section/Aquat c Toxicology Branch 4621 ail Service .Center . Raleigh, North Carolina 27699-1621 Contact the Division's Aquatic Toxicology. Branch at 919-743-8401 for guidance on conducting the additional toxicity tests and reporting requirements. Results should also be summarized in Part E (Toxicity Testing Data) of EPA Municipal Application "Form 2A, when submitting the permit renewal application to the NPDES Permitting Unit. Page 9 of 16 Permit NC0026123 A. (4.) MERCURY MINIMIZATION PLAN (MMP) [NCGS 143-215.1 (b)] The Permittee shall develop and implement a mercury minimization plan during this permit term. The MMP shall be developed within 180 days of the permit effective date, and shall be available for inspection on -site. A sample MMP was developed through a stakeholder review process and has been placed on the Division website for guidance O=s:Hdeg.nc.gov/document/nc-model-mercury- minimization-plan-dwr-npdes-swp-20130801). The MMP should place emphasis on identification of mercury contributors and goals for reduction. Results shall be summarized and submitted with the next permit renewal. Performance of the Mercury Minimization Plan will meet the requirements of the TMDL (Total Maximum Daily Load) for mercury approved by USEPA on October 12, 2012, unless and until a Waste Load Allocation specific to this facility is developed and this NPDES permit is amended to require further actions to address the Waste Load Allocation. A. (5.) NUTRIENT RE -OPENER [NCGS 143-215.1 (b)] Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North Carolina Administrative Code at 15A NCAC 21-1.0112 (b) (1) and 21-1.0114 (a) and Part H sections B-12 and B-13 of this permit, the Director of DWR may reopen this permit to require supplemental nutrient monitoring of the discharge. The purpose of the additional monitoring will be to support water quality modeling efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan developed jointly by the Division and affected stakeholders. In addition, the results of water quality modeling may require that limits for total nitrogen and total phosphorus be imposed in this permit upon renewal. Page 10 of 16 Permit NCO026123 A. (6.) SCHEDULE OF COMPLIANCE FOR AMMONIA LIMITATIONS [NCGS 143-215.1 (b)] 1. Within one (1) year from the effective day of the permit, the Permittee shall submit to the Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to be taken to achieve compliance with the Ammonia (NH3-N) limitations listed in Section A. (L), which includes specific dates for completion or implementation of each action. 2. Within two (2) years from the effective date of the permit, the Permittee shall submit a report to the Division summarizing actions taken during the previous. year to achieve compliance with the NH3-N limitations. The actions shall be in accordance.With=`the Corrective Action Plan submitted and approved by DWR 3. The Permittee shall achieve compliance withJh0 NH3-N limitations specified in Section A. (1.) within three (3) years of the effective date of this permit. Upon approval of the Corrective Action Plan by ,the Division,the report _ and actions become an enforceable. part of this permit. Any modifications to 'the schedule_ shall be requested to the Division at least ninety (90) days before the deadline , Modifications ,to the schedule in excess of four (4) months will be subject to public notice. Corrective Action Plan and Reports shall include the owner's riane, NPDES permit number and Permittee contact person, and shaltbe submitted to: (1) NCDEQ / Division of Water Resources (2) NCDEQ / Division of Water Resources NPDES Permitting Winston-Salem Regional Office 1617 Mail Service Center; 450 West Hanes Mill Road, Suite 300 Ralei ,z TC d 6994 617 Winston-Salem, NC 27105 Page 11 of 16 Permit NCO026123 A. (7.) SCHEDULE OF COMPLIANCE FOR BROMODICHLOROMETHANE LIMITATION [NCGS 143-215.1 (b)] 1. Within six (6) months from the effective day of the permit, the Permittee shall submit to the Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to be taken to achieve compliance with the bromodichloromethane limitation listed in Section A. (1.), which includes specific dates for completion or implementation of each action. 2. Within one (1) year from the effective date of the permit, the Permittee shall submit a report to the Division summarizing actions taken during the preaaious six (6) months to achieve compliance with the bromodichloromethane limitation. The actions shall be in accordance with the Corrective Action Plan submitted and approved by DVVR.. 3. The Permittee shall achieve compliance with .the: bromodichlaromethane limitation specified in Section A. (1.) within two (2) years of the effective date of this permit. Upon approval of the Corrective Action Plan by. -,the Division,, the report, and actions become an enforceable part of this permit. Any modifications to t.W-.schedule shall be requested to the Division at least ninety (90) days before the deadline:: Modifications to the 'schedule in excess of four (4) months will be subject to public notice. Corrective Action Plan and Reports shall = include the owner's name, NPDES permit number and Permittee contact person, and $6a11 be submitted to: (1) NCDEQ / Division: of Water Resources (2) NCDEQ / Division of Water Resources NPDES Permitting Winston-Salem Regional Office 1617 Mail Service Center,..,. 450 West Hanes Mill Road, Suite 300 Raleigh; NC 2769-1617 Winston-Salem, NC 27105 Page 12 of 16 Permit NCO026123 A. (8.) SCHEDULE OF COMPLIANCE FOR 1,4-DIOXANE LIMITATIONS [NCGS 143-215.1 (b)] 1. Within six (6) months from the effective day of the permit, the Permittee shall submit to the Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to be taken to achieve compliance with the 1,4-Dioxane limitation listed in Section A. (L), which includes specific dates for completion or implementation of each action. 2. Within eighteen (18) months from the effective date of the:permit, the Permittee shall submit a report to the Division summarizing actions taken during„the previous year to achieve compliance with the 1,4-Dioxane limitation. The actions shall be in accordance with the Corrective Action Plan submitted and approved by DWR. 3. The Permittee shall achieve compliance with the�1,4-Dioxane limitations specified in Section A. (1.) by December 15, 2020 of the effective, date -of this permit. Upon approval of the Corrective Action Plan by the Division, the report; ;and actions become an enforceable part of this permit. Any modifications to the schedule shall be requested to the Division at least ninety (90) days before the deadline. Modifications .:to..,. schedule in excess :,of four (4) months will be subject to public notice. f. Corrective Action Plan and Reports shall include the. owner's name, NPDES permit number and Penmittee contact person, and 0e submitted ,to: (1) NCDEQ / Division of Water Resources `"(2) NCDEQ / Division of Water Resources NPDES Permitting"°- Winston-Salem Regional Office 1617 Mail Service Center 450 West Hanes Mill Road, Suite 300 Raleigh, NC 27699-1617 Winston-Salem, NC 27105 A. (9.) CALCULATION OF 1794.-DIOXAN,E LOADS [NCGS 143-215.1 (b)] a. The Penmittee',$hall calculatekaverage daily 1,4-Dioxane loads as follows: i. Daily 1,4-Dioxane Load (lb/day) = 1,4-D (mg/L) x ADF x 8.34, where: 1,4-D = the average 1,4-Dioxane concentration (µg/L) of the grab sample collected during the month x 1000 to convert it to mg/L; ADF = the Average Daily Flow of wastewater discharged for the month of 1,4-Dioxane sampling (MG/day); and 8.34 = conversion factor, from (mg/L X MG) to pounds b. The Permittee shall report monthly 1,4-Dioxane results (µg/L and lb/day) in the appropriate discharge monitoring report for each month. Page 13 of 16 Permit NCO026123 A. (10.) 1,4-DIOXANE RE -OPENER [NCGS 143-215.1 (b)] Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part H, Sections B-12 and B-13 of this permit, the Director of DWR may reopen this permit to modify permit requirements to address 1,4-Dioxane monitoring, treatment and/or compliance. A. (11.) ELECTRONIC REPORTING OF MONITORING REPORTS [NCGS 143-215.1 (b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This Section supplements or supersedes;; the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting • Section D. (6.) Records Retention • Section E. 5. Monitoring R o#ts ( ) g �� 1. Reporting Requirements [Supersedes Section D (2.) and Section E. (5.) (mil The Permittee shall report -discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) Internet application. Monitoring results obtained during, the previous months) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DEQ / DWR / Water Quality Permitting Section Attn: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting" section below. Page 14 of 16 Permit NC0026123 Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the Permittee must electronically report the following compliance monitoring data and reports, when applicable: Sewer Overflow/Bypass Event Reports; Pretreatment Program Annual Reports; and Clean Water Act (CWA) Section 316(b) Annual Reports. The Permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). 2. Electronic Submissions In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each electronic submission. The Permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: https://www.federairegister.gov/documents/2015/10/22/2015- 24954/nationa l-pollutant-di scliarge-elimination-system-npdes-electronic-reporting-rule Electronic submissions must start by the dates listed in the "Reporting Requirements" section above. 3. How to Request a Waiver from Electronic Reaortin¢ The Permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Page 15 of 16 Permit NC0026123 Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: htti)://dgg.nc.gov/about/divisions/water-resources/edmr 4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)] All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (I1.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: hiip://dgq.nc.gov/about/divisions/water-resources/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility offines and imprisonment for knowing violations. " 5. Records Retention [Supplements Section D. (6.)] The Permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Page 16 of 16 ' I ' T lvs h •m I o 1 I hI •I 'I � .�4 III - Downstream Dl B4890000 Asheboro WWTP Downstream (D2) Outfall 001 ;// and B4920000 r 1 —J .. �. _ Upstream (U) .' � -e✓�/ - B4870000 i 1 1 I 1 I \ I ASTIFBORO - r,.:.: IX City of Asheboro WWTP Facility NPDES Permit NCO026123 Location Latitude: 3S' 46' 00- N state Grid/Ouad: D 19 SE / Randleman loneitude; 79' 47. 06' W Permitted Flow: 9.00 MOD Receivine streams Haiketts Creak Dralnaee easint Cape Fear River stream Class: C sae•Batin: 03.06.09 not to scale tNorth IL Randolph County Fact Sheet NPDES Permit No. NCOO26123 Permit Writer/Email Contact: Gary Perlmutter, gary.perlmutter@ncdenr.gov Date: Month xx, 2018 Division/Branch: NC Division of Water Resources/NPDES Complex Permitting Unit Fact Sheet Template: Version 09Jan2017 Permitting Action: ® Renewal ❑ Renewal with Expansion ❑ New Discharge ❑ Modification (Fact Sheet should be tailored to mod request) Note: A complete application should include the following: • For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee • For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET tests. • For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based on industry category. Complete applicable sections below. If not applicable, enter NA. 1. Basic Facility Information Facility Information Applicant/Facility Name: City of Asheboro/Asheboro W WTP Applicant Address: P.O. Box 1106, 146 N Church Street, Asheboro, NC 27204 Facility Address: 1032 Bonkemeyer Drive, Asheboro, NC 27203 Permitted Flow: 9.0 MGD Facility Type/Waste: MAJOR Municipal; 87% domestic, 13% industrial Facility Class: Grade IV Treatment Units: Bar screen, Grit removal, Parshall flume, Primary clarifiers, Trickling filters, Secondary clarifiers, Nitrification with aeration, Final clarifiers, Tertiary sand filters, Chlorination, De -chlorination, Cascade aeration, Sludge thickening, Digesters, Dewatering. Pretreatment Program (Y/N) Yes County: Randolph Region Winston-Salem Percentages calculated from 2016 actual industrial and total average daily flows (0.478 and 3.630 MGD, respectively). Permitted industrial flow is 0.832 MGD or 9.2% of total permitted flow. Page 1 of 18 Briefly describe the proposedpermittingaction andfacility background: The City of Asheboro has applied for NPDES permit renewal, received by DWR on 3/21/2016. This facility serves a population of 25,676 residents and operates a pretreatment program with 15 Significant Industrial Users (SIUS), 6 of which are Categorical Industrial Users (CIUs). CIUs include: Energizer Manufacturing, Inc. Plant 2 (CIU 461: battery manufacturing), Garco, Inc. (renamed Covanta Environmental Services, CIU 437: centralized waste management), Matlab, Inc. Plant 4 (CIU 433: metal finishing, not yet constructed), Matlab Plant 5 (CIU 433: metal finishing), Matlab Plant 8 (CIU 433: metal finishing), Matlab Plant 14 (CIU 433: metal finishing, dropped from the pretreatment program in 2016), Premier Powder Coating (CIU 433: metal finishing), and Starpet, Inc. (CIU 414: organic chemical, synthetic fibers and plastics). Non -categorical SIUs include: Acme McCrary (renamed MAS US Holdings, textiles), Bossong Hosiery (textiles), Energizer Manufacturing, Inc. Plant 1 (battery parts manufacturing), Georgia Pacific (corrugated paper products), Kayser Roth (textiles), MOM Brands (food processing), Randolph Packing (meat processing), Wells Hosiery (textiles), and Waste Management of the Carolinas Great Oak Landfill (landfill leachate). In addition, the Asheboro WWTP is receiving 1,400 gpd wastewater from the Randolph County School Bus Maintenance Garage groundwater remediation project. This is not an SITU according to ORC Ray Wiseman. The average industrial flow rate was 0.478 MGD from January through December 2016. The uncontrollable flow was 3.152 MGD for that same period. The facility has a DWR-approved Full Pretreatment Program with a Long -Term Monitoring Program (LTMP) for its SIUs. 2. Receiving Waterbody Information Receiving Waterbody Information Outfalls/Receiving Stream(s): Oud'all 001 / Hasketts Creek Stream Segment: 17-12 Stream Classification: C Drainage Area (mi2): 11.6 Summer 7Q10 (cfs) 0 Winter 7Q10 (cfs): 30Q2 (cfs): 0.2 Average Flow (cfs): 12 IWC (% effluent): 100 303(d) listed/parameter: This stream segment is impaired for Copper and Benthos on the 2016 final 303(d) list. Subject to TMDL/parameter: Statewide TMDL for Mercury Subbasin/HUC: 03-06-09 / 03030003 USGS Topo Quad: D19SE Randleman, NC Page 2 of 18 3. Effluent Data Summary Effluent data is summarized below for the period January 2014 through December 2017 for Outfall 001. Table 1. Effluent Data Summary Parameter Units Average Max Min Permit Limit Flow MGD 3.63 13.46 1.27 MA=9.0 BOD summer mg/L 2.4 > 8.7 < 2.0 MA = 5.0 WA = 7.5 BOD winter mg/L 3.4 13.6 1.9 MA = 10.0 WA = 15.0 BOD Removal % 99.0 99.7 98.0 >_ 85 Total Suspended Solids mg/L < 4.8 51.5 < 2.0 MA = 30.0 (TSS) WA = 45.0 TSS Removal % 98.7 99.7 96.7 > 85 Ammonia (NH3-N) mg/L < 0.2 4.0 < 0.1 MA = 2.0 summer WA = 6.0 Ammonia 3 mg/L < 0.9 29.3 < 0.1 winter WA = 12.0 Dissolved Oxygen mg/L 8.0 10.7 6.0 DA>_6.0 (DO) pH SU 6.9 7.9 6.0 Between 6.0 and 9.0 Fecal Coliform #/100 mL 6 > 6000 1 MA = 200 (geometric mean) WA = 400 Total Residual µ /L < 15.6 48 < 15.0 DM = 17 Chlorine (TRC) Temperature °C 20.5 29.7 9.5 Monitor only Conductivity µmhos/cm 1016 1952 238 Monitor only Total Chromium µg/L < 6.5 26.0 < 5.0 MA = 50 DM = 1033 Total Mercury ng/L 1.7 8.5 0.8 MA = 12 DM = 36 Total Nitrogen (TN) mg/L 13.3 27.4 2.3 Monitor only Total Kjeldahl mg/L 2.1 5.9 0.8 Monitor only Nitrogen (TKN) Nitrate/Nitrite Nitrogen mg/L 11.3 26.4 0.8 Monitor only (NO2 + NO3) Total Phosphorus (TP) mg/L 0.38 1.81 0.08 Monitor only Page 3 of 18 Dibromochloromethane µg/L < 8.3 20.4 < 5.0 Monitor only Bromodichloromethane µg/L < 11.7 36.2 < 5.0 Monitor only Chloride mg/L 166 300 68 Monitor only Total Copper µg/L 4.7 15.0 2.0 Monitor only Total Zinc I µg/L 25.2 55.0 13.4 Monitor only 'MA = Monthly Average, WA = Weekly Average, DA = Daily Average, DM = Daily Maximum. 4. Instream Data Summary Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when model results for instream DO are within 1 mg/L of instream standard at full permitted flow; 2) to verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in which case instream monitoring is waived in the permit as long as coalition membership is maintained). If applicable, summarize any instream data and what instream monitoring will be proposed for this permit action: The current permit requires instream monitoring for Temperature and Dissolved Oxygen (DO) from three locations: one upstream in Hasketts Creek (U), one downstream in Hasketts Creek (Dl) and one additional downstream in Deep River (D2). These locations correspond to the ambient monitoring stations B4870000 (U), B4890000 (DI), and B4920000 (132). Data from U and D2 were obtained from the Monitoring Coalition Coordinator and span from January 2013 — December 2016. Data from DI were from the Ambient Monitoring System Coordinator and span from January 2013 — July 2016. The Permittee is a member of the Upper Cape Fear River Basin Association, and instream monitoring is provisionally waived in light of their participation. Dissolved Oxygen (DO) remains a parameter of concern for aquatic life. Instream data showed that the standard of 5.0 mg/L was maintained at all stations with minima of 6.0 mg/L at U, 6.5 mg/L at Dl, and 5.4 mg/L at D2. Effluent averages for September 2013 through August 2017 also were above 5.0 mg/L. The permit will continue to include instream DO monitoring. Temperature remains a parameter of concern for aquatic life. The standard maximum of 29 °C for upper piedmont and mountain waters was maintained at all stations. However, downstream temperatures exceeded the water quality standard of 2.8 °C above the natural water temperature when compared to upstream data from 2013-2016 with 8 instances of 29 measurements or 28% at DI and 10 instances of 60 measurements or 17% at D2. Concurrent effluent temperatures appeared similar to the instream temperatures, but with warmer winter minima. The permit will continue to include instream Temperature monitoring. Conductivity is a parameter of concern because of industrial discharges. The permit does not currently require instream monitoring, but data were available from the three stations. The data analyzed indicate that Conductivity was significantly higher at D2 than at U (t =-10.94, p < 0.0001), and substantially higher at DI. Averages are: U = 114 uS/cm, D 1 = 726 uS/cm, and D2 = 222 uS/cm. Concurrent effluent Conductivity averaged 1037 uS/cm. Because the facility has a pretreatment program and the patterns noted above, instream monitoring of Conductivity will be added to the permit. Page 4 of 18 Instream Fecal Coliform monitoring is not required in the current permit. Division guidance (DWQ memo, 4/22/2002) states: "Instream monitoring for fecal coliform may be removed from municipal or domestic wastewater permits (major or minor), unless the water body is impaired due to coliform or is a class B waterbody." The receiving water, Hasketts Creek, is a Class C waterbody not impaired due to coliform, thus justifying this parameter's absence from the permit instream monitoring requirements. Analysis of loading for Copper was compared for the 303(d)-listing year of 2008 through 2016. Calculated monthly average loadings (lb/day) from 2008 to 2016 show significant reduction over time (r' = 0.485, p < 0.0001). Annual data tested statistically different among years with consistent decreases in yearly average Ibs/day of copper since 2008. See Stream Impairment Analysis for Copper in attachments for data and graphs. • Effluent Copper averaged 12.04 µg/L for 2008 and 5.67 µg/L in 2016 for average monthly samples. Effluent Copper loading was 0.38 lbs/day in 2008 and 0.171bs/day in 2016. • Annual average effluent Total Copper concentrations were below the 7 µg/L 303(d) listing level since 2013. Due to downstream impairment for Chlorophyll a exceedances in the Deep River [stream segment 17- (10.5)dl], additional instream analysis was conducted for Inorganic Nitrogen (NO2+NO3), Total Kjeldahl Nitrogen (TKN), Total Nitrogen (TN) and Total Phosphorous (TP). See attachments for instream nutrient data summaries and graphs. • Inorganic Nitrogen values were significantly higher at D2 than at U (t = -6.39, p < 0.0001), and substantially higher at D1. Averages are: U = 0.17 mg/L, D1 = 6.95 mg/L, and D2 = 0.63 mg/L NO2+NO3. Concurrent effluent NO2+NO3 data averaged 10.6 mg/L, indicating its influence on the receiving stream. • Total Kieldahl Nitrogen values were significantly higher in D2 than in U (t = -3.32, p = 0.001), and substantially higher at Dl. Average concentrations were: U = 0.53 mg/L, DI = 1.27 mg/L, and D2 = 0.69 mg/L TKN. Concurrent effluent TKN data averaged 2.1 mg/L, indicating its influence on the receiving stream. • Total Nitrogen values were significantly higher in D2 than in U (t = -6.54, p < 0.0001), and substantially higher at Dl. Average concentrations were: U = 0.70 mg/L, Dl = 8.22 mg/L, and D2 = 1.32 mg/L TN. Concurrent effluent TN data averaged 12.7 mg/L, indicating its influence on the receiving stream. Total Phosphorus values were significantly higher in D2 than in U (t = 4.42, p < 0.0001), and substantially higher at Dl. Averages were: U = 0.06 mg/L, Dl = 0.29 mg/L, and D2 = 0.10 mg/L TP. Concurrent effluent TP data averaged 0.36 mg/L, indicating its influence on the receiving stream. Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): YES Name of Monitoring Coalition: Upper Cape Fear River Basin Association 5. Compliance Summary Summarize the compliance record with permit effluent limits (past 5 years): The facility had no enforcements during the prior permit cycle. The facility had one limit violation for NH3-N monthly average exceedance by 6.3% during the period from January 2013 through December 2017. This exceedence resulted in a Notice of Deficiency (NOD). Page 5 of 18 Summarize the compliance record with aquatic toxicity test limits and any second species test results (past 5 years): The facility passed 16 of 16 quarterly chronic toxicity tests from 2014 through 2017, as well as all four (4) second species chronic toxicity tests, sampled on 12/8/2013, 9/8/2014, 5/31/2015, and 3/14/2016, as well as one sampled on 6/5/2017. Summarize the resultsfrom the most recent compliance inspection: The most recent compliance evaluation inspection, conducted on March 13, 2017, found the facility to be well operated and maintained. 6. Water Quality -Based Effluent Limitations (WQBELs) Dilution and Mixing Zones In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH). If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA Oxygen -Consuming Waste Limitations Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits (e.g., BOD = 30 mg/L for Municipals) may be appropriate if deemed more stringent based on dilution and model results. Ifpermit limits are more stringent than TBELs, describe how limits were developed: Limitations for BOD are based on a Streeter Phelps model (Level B) for instream DO protection. No changes are proposed. Ammonia and Total Residual Chlorine Limitations Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0 mg/L (summer) and 1.8 mg/L (winter). Acute ammonia limits are derived from chronic criteria, utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals. Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection of aquatic life (17 µg/L) and capped at 28 µg/L (acute impacts). Due to analytical issues, all TRC values reported below 50 µg/L are considered compliant with their permit limit. Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: WLA calculations were run using the annual 7Q 10 of 0.0 cfs for both the summer and winter values. The resulting TRC limit is 17 µg/L, and will be maintained in the permit. The WLA resulted in more stringent ammonia limits than in the current permit (Table 2). Table 2. Proposed Ammonia-N Limits (mg/L). Season Monthly Average Weekly Average Summer 1.0 3.0 Winter 1.8 5.4 Page 6 of 18 Review of DMR data from January 2014 through December 2017 revealed a few isolated exceedences with proposed monthly and weekly winter average limits (Fig. 1), suggesting upset conditions. The City expects to be able to comply with the new NH3-N limitations, but requested a compliance schedule to ensure compliance. Asheboro WWTP Effluent NH3 N (proposed limits) • Eff WA Eff MA — MA Limit — — — WA Limit 10 9 8 7 6 o� 5 E 4I • I I g dl _ — — — 2 ,�• 1 • •it 0 01� O~b 43 O O�6 1. 0•Y0 01^ Off^ 01� '\~y Figure 1. Asheboro WWTP effluent monthly average (MA) and weekly average (WA) concentrations (mg/L) with their respective proposed limits for potential compliance evaluation. Reasonable Potential Analysis (RPA) for Toxicants If applicable, conduct RPA analysis and complete information below. The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level / 95% Probability; 2) assumption of zero background; 3) use of '/2 detection limit for "less than" values; and 4) streamflows used for dilution consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of Instream Dissolved Metals Standards, dated June 10, 2016. A reasonable potential analysis was conducted on effluent toxicant data collected between May 2014 and May 2017 for the following parameters: arsenic, cadmium, chlorides, total chromium, copper, cyanide, lead, molybdenum, nickel, selenium; silver, dibromochloromethane, bromodichloromethane, and zinc. After review of the 3 effluent pollutant scans, the RPA was expanded to include chloroform. Pollutants of concern included toxicants with positive detections and associated water quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit: • Effluent Limit with Monitoring. The following parameters will receive a water quality -based effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water quality standards/criteria: Cyanide, Bromodichloromethane • Monitoring Only. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but Page 7 of 18 the maximum predicted concentration was > 50% of the allowable concentration: Chlorides, Copper, Total Chromium, Chromium VI, Silver, Dibromochloromethane o Chlorides will maintain a quarterly monitoring requirement to coincide with toxicity testing, since the EPA is currently allowing an action level for this parameter. o Total Chromium will maintain a monthly monitoring requirement but limits will be removed as the maximum predicted value is greater than the Cr-VI allowable concentration but less than the Cr-VI detection level (Instream Dissolved Metals Guidance memo, 6/10/2016,pages 7-9). o Chromium VI will receive a quarterly monitoring requirement for 2 yrs, to be continued if detected. o Total Silver will receive a quarterly monitoring requirement with samples analyzed to the lower reporting level of the procedure. No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they did not demonstrate reasonable potential to exceed applicable water quality standards / criteria and the maximum predicted concentration was < 50% of the allowable concentration: Arsenic, Cadmium, Lead, Molybdenum, Nickel, Selenium, Zinc and Chloroform POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for additional pollutants of concern. o The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with monitoring, since as part of a limited data set, two samples exceeded the allowable discharge concentration: NA o The following parameter(s) will receive a monitor -only requirement, since as part of a limited data set, one sample exceeded the allowable discharge concentration: NA As part of the NC 2007-2014 Water Quality Standard (WQS) Triennial Review the total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality Standards. The reasonable potential analysis using Asheboro WWTP's Total Chromium effluent data showed reasonable potential to violate the new hexavalent chromium standard. Total Chromium is made up of hexavalent and trivalent chromium. As a result, quarterly monitoring for Total Chromium and Chromium VI will be added to the permit and the Total Chromium limits will be removed. If after two years no detects of Chromium VI are found, then monitoring for that parameter will no longer be needed. If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program. Toxicity Testing Limitations Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test failure. Describe proposed toxicity test requirement: This is a Major POTW, and a chronic WET limit at 90% effluent will continue on a quarterly frequency. Mercury Statewide TMDL Evaluation There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and Page 8 of 18 industrial facilities with known mercury discharges. Given the small contribution of mercury from point sources (^-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (> 1 ng/L) will receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL value (based on the NC WQS of 12 ng/L) and/or if any individual value exceeds a TBEL value of 47 ng/L. Table 2. Mercury Effluent Data Summary 2013 2014 2015 2016 2017 Number of Samples 12 12 12 12 12 Annual Average Cone. ng/L 2.0 1.6 1.1 2.1 1.3 Maximum Cone., ng/L 5.8 3.5 2.2 8.5 17 TBEL, ng/L 47 WQBEL, ng/L 12.0 Describe proposed permit actions based on mercury evaluation: Since no annual average mercury concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury limit is required (Table 2). However, since the facility is greater than 2 MGD and has reported quantifiable levels of mercury (> 1 ng/L), a mercury minimization plan (MMP) will be added to the permit. Other TMDL/Nutrient Management Stratepy Considerations Ifapplicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within this permit: The receiving water lies in the Deep River section of the central portion of the Cape Fear River Basin, an area identified for nutrient criteria development in the North Carolina Nutrient Criteria Development Plan, Version 2.0 (NCDWR 2014). The current permit has monthly monitoring requirements for Total Nitrogen, Nitrate -nitrite Nitrogen, and Total Kjeldahl Nitrogen in recognition of a nutrient strategy for the Upper Cape Fear River in addition to surface water monitoring and reporting requirements under 15A NCAC 02B .0500. The current permit also has a nutrient re -opener Special Condition, which will be maintained. No changes are proposed. Other WOBEL Considerations If applicable, describe any other parameters of concern evaluated for WQBELs: The contaminant 1,4- Dioxane is a parameter of concern because it is characterized as a likely human carcinogen by the EPA. It is a synthetic organic hydrocarbon that is highly miscible in water and does not readily biodegrade in the environment. 1,4-Dioxane is primarily produced as a solvent stabilizer and used in a variety of industrial processes. It is also often produced as a byproduct in industrial and manufacturing processes. As a result, 1,4-Dioxane has been found in ground and surface waters, potentially affecting drinking water. The EPA requires public water systems to monitor finished drinking water for a list of unregulated contaminants every five years under the 1996 Safe Drinking Water Act. In the Third Unregulated Contaminant Monitoring Rule (UCMR3), 1,4-Dioxane was included in its nationwide monitoring effort. Samples collected from 2013-2015 found elevated concentrations of 1,4-Dioxane in the Cape Fear River Basin of North Carolina, which include some of the highest concentrations in the country. The UCMR3 findings triggered the Division to conduct a multi -year monitoring study in the Cape Fear River Basin. Objectives were to: 1) screen for 1,4-Dioxane across all seasons to identify sources with Page 9 of 18 consistently elevated concentrations; 2) identify sources of 1,4-Dioxane, and 3) document changes in concentration in response to municipal and industrial actions to reduce 1,4-Dioxane concentrations in their discharges. The screening phase, conducted from October 2014 — September 2015, identified four hotspots in the Basin. One of these hotspots is located in Hasketts Creek downstream of Asheboro WWTP with concentrations ranging from 147478 µg/L. By contrast, samples collected in Hasketts Creek upstream of the WWTP resulted below detection at < 3 jig/L. In the second phase of the study, wherein samples were taken from October 2015 — October 2016, elevated concentrations were confirmed in Hasketts Creek below Asheboro WWTP, with concentrations ranging 69-614 µg/L. The third phase of the monitoring study is currently underway. During the first two study phases there was no EPA -approved test method for 1,4-Dioxane. Then the Clean Water Act Methods Update Rule for the Analysis of Effluent, published August 8, 2017 and effective September 27, 2017, expanded EPA Test Method 624.1 to include 1,4-Dioxane in its list of purgeables, thereby approving this method for analysis of water samples for 1,4-Dioxane. In consideration of the high concentrations found downstream of its discharge and the then newly accepted test method, the Division sent a letter to Asheboro, dated October 31, 2017, requiring monthly monitoring for 1,4-Dioxane in its effluent using EPA Test Method 624.1, beginning December 2017. North Carolina rule 15A NCAC 02B .0208 allows the use of water quality criteria (WQC) in development of permit limitations. The WQC for 1,4-Dioxane are 80 µg/L for fish consumption (i.e. non -water supply waters, non-WS) and 0.35 µg/L for drinking water and fish consumption (i.e., water supply waters, WS). In accordance with 15A NCAC 2B .0208, the Division used the non-WS WQC of 80 µg/L to establish a permit limit of 149 µg/L monthly average for Asheboro's NPDES permit renewal. The draft permit was sent to Public Notice on May 9, 2018 with the proposed limit and a 3-year compliance schedule. The public comment period ended on June 8, 2018. Comments regarding the proposed 1,4-Dioxane limits and compliance schedule were received from the City of Asheboro and several representatives of downstream public water utilities. The City questioned the rule basis for establishing the proposed limit, to which is explained above. The remaining commenters expressed three concerns: 1) downstream uses were not considered; 2) other sources of 1,4-Dioxane were not considered; and 3) a request to shorten the compliance schedule. Recent study data in the Deep River watershed, analyzed via EPA Test Method 624.1, were reviewed in conjunction with Asheboro effluent data (Fig. 2). Background concentrations in Hasketts Creek upstream of the WWTP were confirmed as below detection, at < 1 µg/L, as were other tributaries of the Deep River, including the Rocky River. Elevated concentrations were found in the Deep River above the confluence of Hasketts Creek: one at Worthville with an average of 2.57 µg/L and another further upstream at the Randleman Lake water supply intake that measured 2.70 µg/L. The concentration at Worthville was calculated to result in a concentration of 0.72 µg/L at the nearest downstream WS (i.e., WS-V) upper boundary, located in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles downstream of the POTW discharge. (Note: the WS segment is for the Goldston-Gulf water supply intake, currently inactive.) This demonstrates that background levels alone exceed the river's ability to meet a downstream concentration of 0.35 µg/L at the nearest downstream WS boundary. North Carolina rule 15A NCAC 02B .0203 states: "Water quality based effluent limitations or management practicesfor direct or indirect discharges of waste orfor other sources of water pollution will be developed by the Division such that the water quality standards and best usage of receiving waters and all downstream waters will not be impaired. " To date, no official impairment has been determined, but data has shown levels of 1,4-Dioxane above the 0.35 µg/L WS-WQC in water supply segments of the Deep River. However, DWR Public Water Supply Section has acknowledged best usage has not been impaired given the EPA Drinking Water Health Advisory of 35 µg/L. (Note: the EPA Drinking Water Health Advisory Page 10 of 18 and the NC WQC, the latter of which include fish consumption, are chronic values based on adult consumption over a 70-year period.) Study data from July -August 2018 has shown concentrations of 1,4- Dioxane in the Deep River nearest to the WS-V boundary to average 8.1 µg/L and in the river nearest its mouth at the Cape Fear River averaged 1.4 µg/L (Fig. 2). Data from November 2017—August 2018 has shown concentrations of 1,4-Dioxane at the Hoffer (Fayetteville) Water Treatment Plant intake in the Cape Fear River to average 2.2 pg/L. All results in the Deep River were below the 35 µg/L EPA Drinking Water Health Advisory level. Figure 2. Average 1,4-Dioxane concentrations of DWR ambient monitoring stations in the Deep River watershed, sampled December 2017—August 2018, analyzed using EPA Test Method 624.1. G7 w - CPF089E4 High Point Lake -I�_ -- 1,4-Dioxane<1 pg/L High Point CPFRD4 Randleman Lake Water 7Supplyntake - EastsideWWTP Randleman 1,4-Dioxane = 2.70 pg/L I_'ake Asheboro WWTP B480000 Deep River - Upstream 1,4-Dioxane = 401 pg/L 1,4-Dioxane = 2.57 pg/L B6000000 Rocky River B2 Hasketts Cr—Upstream -.-_ 1,4-Dioxane < 1 pg/L 1,4-Dioxane < I pg/L G,otciston-Gulf Water ti upply Intake (inactive) r 86040300 Deep River B4890000 Hasketts Cr - Downstream 1,4-Dioxane = 1.38 pg/L 1,4-Dioxane = 269 pg/L 1 �1 B5190000 Deep River - Downstream 1,4-Dioxane=8.13 pg/L ;i.�1�, Sanford Water Supply Intake, _ l Cape Fear River - 1� .. .,.o.. ,,... WS-V upper boundary f` In addition, 15A NCAC 02B .0216 for W S-IV waters states: "..the waters, following treatment required by the Division, shall meet the Maximum Contaminant Level [MCL] concentrations considered safe for drinking, culinary, or food processing proposes that are specified in the national drinking water regulations and in the North Carolina Rules Governing Public Water Supplies, 15.4 NCAC 18C .1500." To date, there is no MCL for 1,4-Dioxane. Protection of WS waters is achieved through protecting best usage, which is the 35 µg/L Drinking Water Health Advisory. The process of the indirect discharger Starpet Inc., an organic chemical, synthetic fibers and plastics industry, has resulted in Asheboro discharging 1.4-Dioxane in concentrations ranging 48-1,100 µg/L from December 2017—September 2018. The company has researched treatment options and has found a similar facility in South Carolina that treats 1,4-Dioxane in its wastewater. This treatment will have to be modified for the plant in Asheboro. Page 11 of 18 Based on discussions with City officials who have worked with Starpet industrial representatives investigating treatment alternatives, the City has agreed to the following measures in an effort to reduce 1,4-Dioxane as low as technology will allow. These measures include: a combination of concentration - based and load -based limits; a shortened compliance schedule; and further optimization following compliance. These measures would result in 1,4-Dioxane concentrations estimated to be less than 1.72 µg/L (considering background concentrations) at the first W S upper boundary downstream of discharge, located in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles downstream of the POTW discharge. (See Evaluation of Alternative 1,4-Dioxane Limits for calculations.) The agreed -upon technology -based Best Professional Judgement (BPJ) 1,4-Dioxane limitations are: • Monthly Average limit of 97 µg/L • Mass Loading limit of 4.50 lb/day based on the POTW's design flow at 9.0 MGD and a concentration of 60 µg/L. A combination of concentration and mass loading limits will ensure 1,4-Dioxane concentrations less than 1.72 µg/L at the nearest WS boundary both in the short term and in the long term as flow increases at Asheboro WWTP. The City has also agreed to shorten the compliance schedule to a period ending December 15, 2020, based on Starpet's timeline to modify and install treatment technology. Given the new technology, it is possible further optimization of treatment at Starpet can further reduce 1,4-Dioxane concentrations. Proposed permit changes regarding I A-Dioxane Based on these considerations, the Division proposes the following changes to Asheboro's permit regarding 1,4-Dioxne: • In Section A. (L) Effluent Limitations and Monitoring Requirements, the monthly average 1,4- Dioxane limit of 149 µg/L is replaced with a monthly average limit of 97 µg/L and an average daily load limit not to exceed 4.50 lb/day, to become effective December 15, 2020. • A footnote is added to the 1,4-Dioxane limitations in Section A. (1.) to require optimization upon achieving compliance to further reduce effluent 1,4-Dioxane concentrations. • The Special Condition specifying the 1,4-Dioxane compliance schedule is changed from three - years to a final date of December 15, 2020. Annual milestones are adjusted to 6 months for the corrective action plan, and 18 months for an action summary report. • A new Special Condition is added for calculating and reporting daily average 1,4-Dioxane load (lb/day), at a monthly frequency. • A new Special Condition is added to reopen the permit to modify 1,4-Dioxane limits as optimization is achieved. As a separate note, the Division sent an administrative letter to High Point Eastside WWTP, which discharges into the Deep River upstream of Randleman Lake (Fig. 2), requiring monthly 1,4-Dioxane sampling beginning November 1, 2018. The Division will pursue separate actions to reduce background levels of 1,4-Dioxane in the Deep River as additional sources are identified. If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall comply with in order to protect the designated waterbody: NA Ifapplicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: A compliance schedule is proposed for meeting the 1,4-Dioxane limit ending December 15, 2020. A two-year compliance schedule will be added for meeting the bromodichloromethane limit; and a three-year compliance schedule will be added for meeting the NH3-N limits. Page 12 of 18 If applicable, describe any water quality standards variances proposed in accordance with NCGS 143- 215.3(e) and 15A NCAC 2B.0226for this permit renewal: NA 7. Technology -Based Effluent Limitations (TBELs) Municipals Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg1L BOD ,ITSSfor Monthly Average, and 45 mg/L for BOD 1TSS for Weekly Average). YES If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA Are 85% removal requirements for BODvTSS included in the permit? YES If NO, provide a justification (e.g., waste stabilization pond). NA 8. Antidegradation Review (New/Expanding Discharge) The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not degrade water quality. Permitting actions for new or expanding discharges require an antidegradation review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases, existing instream water uses and the level of water quality necessary to protect the existing use is maintained and protected. If applicable, describe the results of the antidegradation review, including the Engineering Alternatives Analysis (EAA) and any water quality modeling results: NA 9. Antibacksliding Review: Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.440) 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 uent limitations less stringent than previous permit (YES/NO): YES If YES, confirm that antibackslidingprovisions are not violated: NA 10. Monitoring Requirements Monitoring frequencies for NPDES permitting are established in accordance with the following regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Page 13 of 18 Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding prohibitions would not be triggered by reductions in monitoring frequencies. No effluent parameters in the current permit have reduced monitoring frequencies. For instream monitoring, refer to Section 4. 11. Electronic Reporting Requirements The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit additional NPDES reports electronically. This permit contains the requirements for electronic reporting, consistent with Federal requirements. 12. Summary of Proposed Permitting Actions Table 3. Current Permit Conditions I and Proposed Changes Parameter Current Permit Proposed Change Basis for Condition/Change Flow MA 9.0 MGD No change 15 A NCAC 2B .0505 Summer: MA 5.0 mg/L WQBEL. Determined via WLA BOD5 WA 7.5 mg/L No change conducted in 1995, and for Winter: protection of DO standard (15A MA 10 mg/L NCAC 2B .0200). WA 15 mg/L MA 30 mg/L TBEL. Secondary treatment TSS WA 45 mg/L No change standards / 40 CFR 133 / 15A NCAC 2B .0406. Summer: Summer: MA 1.0 mg/L MA 2.0 mg/L WA 3.0 mg/L NH3 N WA 6.0 mg/L Winter: WQBEL. Based on the current Winter: MA 1.8 mg/L WLA for protection of aquatic life. MA 4.0 mg/L WA 5.4 mg/L WA 12.0 mg/L Add 3-yr compliance schedule DO > 6 mg/L No change WQBEL. For protection of the DO standard (15A NCAC 2B .0200). pH 6.0 — 9.0 SU No change WQBEL. WQ standard, 15A NCAC 2B .0200. Fecal Coliform MA 200 /100 mL No change WQBEL. WQ standard, 15A WA 400 /100 mL NCAC 213.0200. Page 14 of 18 WQBEL. 15A NCAC 2B.0200. Total Residual Chlorine DM 17 µg/L No change Based on the current WLA for protection of aquatic life. Facility is using chlorine disinfection. Temperature Monitor daily No change WQBEL. 15A NCAC 2B.0200, .0500 Add instream 15A NCAC 2B.0500, added based on the presence of an industrial Conductivity Monitor daily monitoring upstream ( and downstream pretreatment program and the 2002 (DI and D2) Instream Conductivity and Fecal Coliform Monitoring Guidance. Monitor quarterly in WQBEL. 15A NCAC 2B.0200. Chlorides conjunction with No change Reasonable potential found. EPA Chronic Toxicity test allows action level, passing chronic toxicity tests WQBEL. 15A NCAC 2B.0200. No reasonable potential was found, Total Chromium MA 50 µg/L Quarterly monitoring but maximum predicted value > DM 1033 µg/L Cr-IV allowable concentration. NPDES permitting guidance for dissolved metals. WQBEL. 15A NCAC 2B.0200. Quarterly monitoring Reasonable potential to exceed Chromium VI No requirement for two years; to be WQS found in RPA. NPDES continued if detected permitting guidance for dissolved metals. WQBEL. 15A NCAC 2B.0200. No reasonable potential found in Total Copper Monitor quarterly No change RPA, but maximum predicted value > 50% of the allowable concentration. MA 5.0 µg/L WQBEL. 15A NCAC 2B.0200. Cyanide No requirement DM 22.0 µg/L Reasonable potential to exceed WQS found in RPA. Remove from permit; WQBEL. Based on the statewide Total Mercury MA 12 ng/L add Mercury 2012 TMDL; monitoring DM 36 ng(L Minimization Plan conducted during PPAs and (MMP) pretreatment LTMP. Quarterly monitoring at WQBEL. 15A NCAC 2B.0200. Total Silver No requirement lower reporting level of No detects at < 5 µg/L NPDES procedure for permitting guidance for dissolved pretreatment LTMP metals WQBEL. 15A NCAC 2B.0200. Total Zinc Monitor quarterly Remove from permit No reasonable potential found in RPA, but maximum predicted Page 15 of 18 value < 50% of the allowable concentration. WQBEL. EPA Nationally Recommended Water Quality Dibromochloromethane Monitor quarterly No change Criteria (NRWQC). No reasonable potential found in RPA, but maximum predicted value < 50% of the allowable concentration. MA 31.6 µg/L WQBEL. EPA NRWQC. Bromodichloromethane Monitor quarterly Add 2-yr compliance Reasonable potential to exceed schedule criterion found in RPA. 15A NCAC 2B.0500; nutrient Total Nitrogen Monitor monthly No change criteria development in the Upper Cape Fear River Basin. 15A NCAC 2B.0500; nutrient Total Kjeldahl Nitrogen Monitor monthly No change criteria development in the Upper Cape Fear River Basin. Nitrate + Nitrite 15A NCAC 2B.0500; nutrient Nitrogen Monitor monthly No change criteria development in the Upper Cape Fear River Basin. 15A NCAC 2B.0500; nutrient Total Phosphorus Monitor monthly No change criteria development in the Upper Cape Fear River Basin. MA 97 µg/L with a load limit not to exceed gpJ. Based on a review of 4.. technologies used in organic Adddd compliance chemical, synthetic fibers and 1,4-Dioxane No requirement schedule ending plastics industries and December modifications necessary to treat the Continue optimization zati specific industrial wastewater at upon compliance. Starpet. QuarterlyCerubia ail WQBEL. No toxics in toxic Chronic Toxicity Pass/Fail at 9 d at 90 /0 No change amounts. 15A NCAC 2B.0200 and effluent t effluent 15A NCAC 2B.0500 Effluent Pollutant Scan Three times per permit cycle No change 40 CFR 122 Add quarterly effluent Revised water quality standards Total Hardness No requirement monitoring and EPA's guidelines on hardness dependent metals. Electronic Reporting No requirement Add Electronic Reporting Special )n accordance with EPA Electronic Condition Reporting Rule 2015. Nutrient Reopener for Special Condition No change Upper Cape Fear River nutrient TN and TP strategy requirement. Page 16 of 18 MGD = Million Gallons per Day, MA = Monthly Average, WA = Weekly Average, DM = Daily Max. 13. Public Notice Schedule Permit to Public Notice: 05/09/2018 Permit to Second Public Notice: xx/xx/2018 Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following the publication date of the public notice. Any request for a public hearing shall be submitted to the Director within the 30 days comment period indicating the interest of the party filing such request and the reasons why a hearing is warranted. 14. Fact Sheet Addendum (if applicable) Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes. Comments were received from the City of Asheboro (Permittee), dated 5/31/2018. These include: • Why were mass -based NH3 limits not inserted as requested as an alternative to concentration - based limits? If mass -based limits not allowed, then requested 3 yr compliance schedule. • Explain Chloride RPA factors and results. • Cyanide limits appeared to be based on lab data that were found to be resulting from instrument interference; requested removal of limits and monitoring • Requested 2-yr compliance schedule for bromodichloromethane • Explain legal basis and calculation of 1,4-dioxane limits • Explain discrepancy between Asheboro's limits and DAK America's monitoring only requirements for 1,4-dioxane • Explain shortened permit term (4 not 5 yrs) Comments were also received electronically on 6/8/2018 from multiple municipalities expressing water supply 1,4-Dioxane concerns, and the need to consider downstream water supply waters and any additional sources in developing permit limits. Comments were provided by the Fayetteville Public Works Commission, Cape Fear Public Utility Authority, City of Sanford, and Town of Cary. Comments and DWR responses are attached. If Yes, list changes and their basis below: • A three-year compliance schedule was added for meeting the NH3 limits. • A two-year compliance schedule was added for meeting the bromodichloromethane limit. • 1,4-Dioxane limit was reduced from 149 µg/L monthly average to 97 µg/L monthly average with a load limit not to exceed 4.50 lb/day. • A footnote was added to 1,4-Dioxane limits in the Effluent Limitations and Monitoring Requirements requiring optimization for further 1,4-Dioxane reduction upon compliance. • A 1,4-Dioxane load calculation Special Condition was added to the permit. • 1,4-Dioxane compliance schedule was reduced from three years to terminate on December 15, 2020. • A reopener clause has been added to modify 1,4-Dioxane monitoring, treatment and/or compliance. Page 17 of 18 15. Fact Sheet Attachments (if applicable) • Pretreatment Information Request form, completed • Final 2016 NC 303(d) list, page 14 (Hasketts Creek impairment) • Effluent parameter trend charts and summary statistics • Effluent BOD and TSS removal sheets • lnstream parameter trend charts and summary statistics (DO, Temp, Conductivity) • DWQ guidance memo, 4/22/2002 • Effluent Copper Loading analysis • Final 2016 NC 303(d) list, page 13 (Deep River chlorophyll a impairment) • Instream parameter trend charts and summary statistics (nutrients) • Monitoring Report (MR) Violations page • Whole Effluent Toxicity and Self -Monitoring Summary, page 5 • Compliance Evaluation Inspection reports, March 13, 2017 • IWC Calculations sheet (waste load allocation for TRC and N113-N) • RPA Spreadsheet Summary and dissolved to total metal calculator • NPDES Implementation of Instream Dissolved Metal Standards memo (6/10/2016). Pp 7-10 • Dissolved Metals Implementation — Freshwater Standards fact sheet memo • Mercury WQBEL/TBEL evaluation • Pages 12-13 of the North Carolina Nutrient Criteria Development Plan (DWR 2014) • 1,4-Dioxane Monitoring in the Cape Fear River Basin (DWR 2017) • Randleman Lake 1,4-Dioxane calculations • 1,4-Dioxane alternate limit evaluation Page 18 of 18 NPDES/A uifer Protection Permitting Unit Pretreatment Information Request Form PERMIT WRITER COMPLETES THIS PART: Check all that Date of Request 7/28/2017 municipal renewal I PERMIT WRITERS - AFTER You get this form back apply X from PERCS: Notify PERCS if LTMP/STMP data we said should be on DMRs is not really there, so we can get it for you (or NOV POTW). - Notify PERCS if you want us to keep a specific POC in LTMP/STMP so you will have data for next permit renewal.ass. - Email PERCS draft permit, fact sheet, RPA. -Send PERCS paper copy of permit (w/o NPDES boilerplate), cover letter, final fact sheet. Email RPA if Ichanges. Requestor Jennifer Busam new industries Facility Name Asheboro W WTP W WTP expansion Permit Number Region Basin NCO026123 WiSton-Belem Cape Fear Speculative limits stream red outfall relocation 7Q10 thane otherl other check applicable PERCS staff: Other Comments to PERCS: X BRD, CPF, CTB, FRB, TAR - Sarah Bass 807.6310 I CHO HIW, LTN LUM NES NEW ROA, YAD - Monit Hassan 807-6314 PERCS PRETREATMENT STAFF COMPLETES THIS PART: Status of Pretreatment Program (check all that apply) 2) facility has no SIU's, does not have Division approved Pretreatment Program dX1) facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE X 3) facility has SIUs and DWQ approved Pretreatment Program (list "DEV' if program still under development) 3a) Full Program with LTMP 3b) Modified Program with STMP 4) additional conditions regarding Pretreatment attached or listed below Flow, MGDI Permitted I Actual jTime period for Actual STMP time frame: Industriall 0.832 1 0.478 1 112016-1212016 Most recent: Uncontrollable n/a 1 3.152 1 112016-1212016 Next Cycle: u c Y 01 7L Parameter of Concern (POC) Check List POC due to NPDESI Non. Disch Permit Limit Required by EPA' Required by 503 Sludge" POC due to SIU"' POTW POC (plain below)— STMP Effluent Freq LTMP Effluent Preq Q = Quarterly M = Monthly BOD X 4 M TSS X 4 M NH3 X 4 M Arsenic X X 4 M Cadmium I X X 4 M Chromium X X X 4 M Copper X X X 4 M Cyanide X 4 M Is all data on DMRs? Lead X X 4 M YES X Mercury X X X 4 M NO attach data Molybdenum X 4 M Nickel X X 4 M Silver X 4 M Selenium I X X 4 M Zinc X X X 4 M Is data in spreadsheet? Total Nitrogen - 4 YES email to writer)!X Phosphorus 4 NO Mn I X 4 M 4 4 4 `Always in the LTMP/STMP " Only in LTMP/STMP if sludge land app or composts (dif POCs for incinerators) — Only in LTMP/STMP while SIU still discharges to POTW — Only in LTMP/STMP when pollutant is still of concern to POTW Comments to Permit Writer (ex., explanation of any POCs: Info you have on IU related investigations into NPDES oroblems): HWA last approved 6130/2017 based on monthly data from 1/2016 through 12(2016; spreadsheet attached. Program has 14 SIUs. NCO026123 NPOES_Pravea"entrequest0728201] wmpleted Revises: Jury 24,2007 N, C. Final 2016 Category 5 Assessments-303(d) List enNroemrnml Deep River Subbasin Cape Fear River Basin Quaarr Assessment Unit Name Assessment Unit Description Assessment Unit Number Water Quality Classification Length/Area Units DEEP RIVER(including High Point L From source in backwaters of High Point Lake to dam at High Point Lake(City of High Point water supply intake) 17-(1) WS-IV;CA:* 263.3 FW Acres Issessment Criteria Status Reason for Rating Parameter of Interest IR Category Exceeding Criteria > 10% and >90 conf Chlorophyll a (40 µg/I, AL, NC) 5 East Fork Deep River From Thatcher Road to a point 0.4 mile downstream of Guilford County SR 1541 17-2-(0.3)b WS-IV:* 4.8 FW Miles Issessment Criteria Status Reason for Rating Parameter of Interest IR Category Exceeding Criteria Fair Benthos (Nar, AL, FW) 5 Haskett Creek From source to SR 2149 17-12a C 6.3 FW Miles Issessment Criteria Status Reason for Rating Parameter of Interest IR Category Exceeding Criteria > 10% and >90 conf Dissolved Oxygen (4 mg/I, AL, FW) 5 Haskett Creek From SR 2149 to Asheboro W WTP Outfall 17-12b1 C 0.6 FW Miles Issessment Criteria Status Reason for Rating Parameter of Interest IR Category Exceeding Criteria Poor Benthos (Nar, AL, FW) 5 Haskett Creek From Asheboro WWTP Outfall to Deep River 17-12b2 C 0.7 FW Miles Issessment Criteria Status Reason for Rating Parameter of Interest IR Category Exceeding Criteria > 10% and >90 conf Copper (7 µg/I, AL, FW) 5 Hickory Creek From a point 0.6 mile upstream of mouth to Randleman Reservoir, Deep River 17-8.5-(3) WS-IV;CA:* 0.9 FW Miles Issessment Criteria Status Reason for Rating Parameter of Interest IR Category Exceeding Criteria Fair Benthos (Nar, AL, FW) 5 3/23/2018 Final 2016 NC Category 5 Assessments Page 14 of 196 Asheboro WWTP (NC0026123) - Flow Eff MA —MA Limit 10.0 9.0 8.0 7.0 0 6.0 t7 5.0 • ••• •• • • 2 4.0 • • • • • ••• •• • ••• 3.0 N4•N• ••••• ••• •• •• b•• 2.0 1.0 0.0 Oyu O,tib Oyb Oyy Oyb Oy6 Oy^ O,^ oti0 yy\�ti�ti e�y�\v yry\ry��ti 1\yy�y y��y\v e�y\ry �\��ti e�yy\y A\1o�ti Asheboro WWTP (NC0026123) - BODS Eff WA I Eff MA WA Limit --- MA Limit 16 14 1 12 10 n� & a •• E •tj N z � • I • 0 Oyu O,yb 5V Oyy Oyb Oy6 Oy^ Oy1 oy� yy\vti�ti e\yo�y yy\vA�v 1\yy�ti y��y\ry e�y$\v 3\b�ti e�tiv\y a\yo�y Asheboro WWTP (NC0026123) -TSS Eff WA • Eff MA WA Limit — MA Limit 50 45 _.. .. ..._. _ - - - - - - - - - - - - - - - 40 35 30 m 25 E 20 is 10 f • t . ��yr +` 5 0 Oyu Oyb Oyb Oyh Oyb Oyb Oy^ Oy1 Oy4 L 1\y�\'L y\�y\'L $\y$\'L 4ry, t.\P Eff = Effluent; MA = Monthly Average; WA = Weekly Average Summary Statistics Average 3.631 Min 1.266 Max 13.463 Summary Statistics 4W17Iai Average 3.4 Min 1.9 Max 13.6 Summer Average < 2.4 Min < 2.0 Max 8.7 Summary Statistics Average < 4.7 Min < 2.0 Max 51.5 Page 1 GB Perlmutter, rev. 10/1/2018 14 12 10 J 8 E6 4 2 0 Asheboro WWTP (NC0026123) - NH3-N Eff WA Eff MA - - - WA Limit — MA Limit I I I I I I I I Oy0 Oyh O,b Oyy O,tiO O.yO Oy1 Oy^ Oy0 yy\ryti\ti e\yo\ti yry\rye\ti 1\yy\ti y\3y\ti $\yam\ti\6\ti C\ryti\ti a\yo\ti Asheboro WWTP (NC0026123) - DO • Eff Daily —DA Limit 12 10 8 o�u 6 E 4 2 0 'A y\�y\ryoy6 'b\y�\~oy6 \y\ryoy� 'L O t- Asheboro WWTP (NC0026123) - pH • Eff Daily --- Lo. Limit Up. Limit 10 g- - - - - - - - - _- - - - - - - - - - - - - - - - .. 8 omm 6 - s 4 ry\ryoy3 o\ryoya ^\voyo- \�oy5 \ryoyo \�oyd ryoy� �oyA Hoye Summary Statistics Winter Average < 0.9 Min < 0.1 Max 29.5 Summer Average < 0.2 Min < 0.1 Max 4.0 Summary Statistics Average 8.03 Min 6.02 Max 10.70 Summary Statistics Average 6.9 Min 6.0 Max 7.9 Eff = Effluent; MA = Monthly Average; WA = Weekly Average; DA = Daily Average; Lo. = Lower; Up. = Upper Page 2 GB Perlmutter, rev. 10/1/2018 Asheboro WWTP (NC0026123) - Fecal Coliform Eff WA - Eff MA WA Limit -------- MA Limit 1000 J 100 • • • • of • • As Ilk • 10 • •I ••�� • �i w .Mlii•go i Ot il� • • • • • 01� O•yA O,�A O�y OHO ON6 01^ Off^ OHO 1\��\'L ti\3,Y\'L $\L 3\6\'L 9�~ry\ry b�10V Asheboro WWTP (NC0026123) - TRC • Eff Daily — — —Limit -----Compliant 60 50 40 J • o 30 •• • • •• S zo-:'-'s----�-- --� .. 10 0 ti�tio~3 o�tioyp ��tio~b h�tio~y 6 ti�tio~6 w�tio~o�tioy^ ti�tio�^ o�tio1� 1y�ti 6�1 1ti\� Asti 411 0�1 '�� O�ti NV Asheboro WWTP (NC0026123) - Temperature • Eff Daily 35 30 25 u 20 15 10 5 0 O O,�p Oyb O,�h 0Si Oti6 011 011 oym A�ryry\� b�ti0\v Eff = Effluent; MA = Monthly Average; WA = Weekly Average Summary Statistics Geometric 6 Mean Min < 1 Max > 6000 Summary Statistics Average < 15.6 Min < 15.0 Max 48.0 Summary Statistics Average 20.5 Min 9.5 Max 29.7 Page 3 GB Perlmutter, rev. 101212018 Asheboro WWTP (NC0026123) - Conductivity • Eff Daily 2,500 2,000 t E • ••• N 1,500 i� 1,000 • _ •4 • • M 0 O,�'� OyP Oyb O•Yy Oy6 Oy6 Oyu Oyu Oy0 yy\�ti�ti 6\1o�ti yry\y��ti �\1��ti y��y\~ $\yeti �\b�ti a�ti�\ry b\yo�ti Asheboro WWTP (NC0026123) -Total Chromium -- Eff Monthly —MA Limit 60 50 40 n� 30 i 20 10 641111.0�� 0 Oyu Oyo- Oyo- O,y O•y(o Oyb O,1'` 0.1'` pyW yy\�ti�ti e\yo�ti yry\y^�ti ^\yh�ti y��y\ry e�y�\~ �\6�ti e�tiv\ry p\yo�ti Asheboro WWTP (NC0026123) -Total Mercury — — Eff Monthly ----- MA Limit 14 12 10 o� 8 6 4 2 0 Oyu OyP oyd O•yy Oyu Oyd Oy1 Oy1 Oy¢ yy\�ti�ti O\yo�ti yy\v^�ti ^\yeti y\�y�ti m�y$\y �\(0 \ryti�ti yo�ti Eff = Effluent; MA = Monthly Average Summary Statistics Average 1016 SD 285 Min 238 Max 1952 Summary Statistics Average < 6.5 Min < 5.0 Max 26.0 Summary Statistics Average 1.7 Min 0.8 Max 8.5 Page 4 GB Perlmutter, rev. 10/2/2018 Asheboro WWTP (NC0026123) - Nitrogen —TN -----TKN — — — NO2+NO3 30 2s 20 t % 0�15 10 5 ! l 0 Otis O~b 01b Otiy 010 O~(0 Oti1 011 OHO Asheboro WWTP (NC0026123)-Phosphorus — Eff Monthly TP 2 1.8 1.6 1.4 1.2 o� 1 E 0.8 0.6 0.4 0.2 0 O~b O•yy 016 O,b 011 O~1 O~$ Asheboro WWTP (NC0026123) Eff Quarterly —A Bromodichloromethane — • — Dibromochloromethane 40 35 30 J 25 20 15 10 / r �� A\ / 0 O,� 01A 01p O�h O~6 OHO O~1 O~1 0ti0 yry\ryIff 1�1h\ry 1�31\~ $\yO�n• �\b�ti 9�1~\~ P�10\ry Summary Statistics TN Average 13.3 Min 2.3 Max 27.4 TKN Average 2.1 Min 0.8 Max 5.9 NO2+NO3 Average 11.3 Min 0.8 Max 26.4 Summary Statistics Average 0.38 Min 0.08 Max 1.81 Summary Statistics Bromodichloroomethane Average < 11.7 Min < 5.0 Max 36.2 Dibromochloromethane Average < 8.3 Min < 5.0 Max 20.4 Eff = Effluent; TN = Total Nitrogen, TKN = Total Kjeldahl Nitrogen; NO2+NO3 = Nitrite + Nitrate; TP = Total Phosphorus Page 5 GB Perlmutter, rev. 10/112018 Asheboro WWTP (NC0026123) - Chloride —0 Eff Quarterly 350 300 250 200 E 150 100 50 0 lb 11\ryti\ti e\moo\ti �ry\ry,�\ti �\1y\ti �\�, \ti �\��\ti 3\6\ti �\ryti\ti a\1o\ti Asheboro WWTP (NC0026123) - Total Copper —0 Eff Monthly 16 14 12 10 i 8 6 4 2 0 11\ry,�\ti\y�\ti try\�,�\ti ^\1y\ti 1\�1\ti\1�\ti 3\b\ti 9 Asheboro WWTP (NC0026123) - Total Zinc Eff Monthly 60 50 40 o� 30 i 20 10 F — — 0 �•,� O,a O~a O.yh O,yto 016 p�^ pti1 Otis ^\,yc�\'L 1\,h�\'L \,Y�\'L C5\11'L Eff = Effluent Summary Statistics Average 166 Min 68 Max 300 Summary Statistics Average 4.7 Min 2.0 Max 15.0 Summary Statistics Average 25.2 Min 13.4 Max 55.0 Page 6 GB Perlmutter, rev. 10/1/2018 Output Monthly BOD Average Result Month Influent Effluent Removal Rate January-14 300.90 3.19 98.94 February-14 322.15 2.55 99.21 March-14 238.10 3.60 98.49 April-14 237.29 1.91 99.20 May-14 335.71 1.74 99.48 June-14 388.33 1.55 99.60 July-14 355.77 1.63 99.54 August-14 387.71 1.40 99.64 September-14 399.14 2.18 99.45 October-14 382.48 2.67 99.30 November-14 414.67 3.21 99.23 December-14 379.90 3.80 99.00 January-15 270.05 4.36 98.39 February-15 256.65 3.69 98.56 March-15 231.00 3.63 98.43 April-15 257.33 3.11 98.79 May-15 284.65 2.05 99.28 June-15 313.82 1.52 99.51 July-15 311.36 1.73 99.44 August-15 264.10 1.82 99.31 September-15 278.48 1.93 99.31 October-15 227.32 2.36 98.96 November-15 172.37 2.49 98.56 December-15 205.81 2.26 98.90 January-16 204.26 3.65 98.21 February-16 191.38 2.98 98.44 March-16 269.18 3.14 98.83 April-16 306.90 3.23 98.95 May-16 259.86 2.71 98.96 June-16 329.86 1.62 99.51 July-16 314.05 1.11 99.65 August-16 277.78 1.24 99.55 September-16 308.57 1.30 99.58 October-16 282.71 1.12 99.60 November-16 287.15 1.67 99.42 December-16 286.63 3.14 98.90 January-17 214.20 3.85 98.20 February-17 258.10 3.52 98.64 March-17 218.39 4.27 98.04 April-17 177.16 3.46 98.05 May-17 220.68 2.95 98.66 June-17 211.55 1.87 99.12 July-17 268.75 1.36 99.50 August-17 272.13 1.51 99.44 September-17 393.25 1.70 99.57 October-17 343.77 1.74 99.49 November-17 326.20 2.97 99.09 December-17 301.22 3.03 98.99 January-18 February-18 Statistics 99.65 Output Monthly TSS Average Result Month Influent Effluent Removal Rate (%) January-14 226.90 6.45 97.16 February-14 243.43 3.41 98.60 March-14 236.97 5.30 97.76 April-14 254.17 1.84 99.28 May-14 447.97 1.50 99.67 June-14 489.33 1.60 99.67 July-14 420.00 1.76 99.58 August-14 452.26 2.15 99.52 September-14 471.72 2.66 99.44 October-14 450.65 3.78 99.16 November-14 626.79 5.74 99.08 December-14 357.14 5.92 98.34 January-15 251.38 6.89 97.26 February-15 249.79 7.05 97.18 March-15 271.74 4.72 98.26 April-15 289.34 4.06 98.60 May-15 305.77 1.93 99.37 June-15 334.00 1.37 99.59 July-15 345.30 1.44 99.58 August-15 317.00 1.66 99.48 September-15 314.24 1.91 99.39 October-15 285.16 4.89 98.29 November-15 211.64 5.76 97.28 December-15 322.50 3.59 98.89 January-16 298.66 5.21 98.25 February-16 300.38 5.26 98.25 March-16 491.57 5.37 98.91 April-16 533.50 6.58 98.77 May-16 470.57 6.27 98.67 June-16 642.23 2.02 99.69 July-16 411.40 1.54 99.63 August-16 471.23 1.58 99.66 September-16 390.62 2.13 99.45 October-16 329.32 4.52 98.63 November-16 341.93 4.83 98.59 December-16 339.75 6.67 98.04 January-17 309.07 10.25 96.68 February-17 358.14 6.35 98.23 March-17 307.48 10.02 96.74 April-17 282.10 7.83 97.22 May-17 309.40 6.05 98.05 June-17 301.33 3.27 98.91 July-17 333.07 2.38 99.29 August-17 324.97 2.22 99.32 September-17 661.86 2.20 99.67 October-17 423.03 1.98 99.53 November-17 378.50 6.07 98.40 December-17 343.32 January-18 February-18 Summary Statistics average 98.67 max 99.69 min 96.68 Asheboro WWTP(NC0026123) Instream DO —B4870000(U) ._ B4890000(D1) — B4920000(D2) —Standard 14 13 12 11 10 E 9 8 7 6 5 4 ,y3 .Y3 ti3-ati?0 ti°' ti°' ti° ti°' tih tih tih tih ti( ti(0 tib 1�0 NO *5 l`�\ CP laK PQ� l�� 06 NO Vs 'oV Ob %0 VS log Ob Asheboro WWTP(NC0026123) Instream Temperature —84870000(U) • B4890000(D3) — B4920000(D2) —Standard 35 30 25 20 U 15 10 5 0 %a0 PQt ,O\ O& Sao PQf 'J\ 0'1 ,,a0 PQf 14\ 00� 124"VS Asheboro WWTP(NC0026123) Instream Conductivity —B4870000(U) 0 B4890000(D1)—B4920000(D2) 1800 1600 1400 • 1200 1000 • E 800 • 600 • 400 • • 200 o • • • of 1' ,y ,y ,y ,yb .yb ti5 1y 1y tih tib .yb dad A' �9 lac 40 IR lac 40 Sed Nab a� 49 Summary Statistics Upstream (U) Average 8.83 Min 5.99 Max 12.70 Dnstream (DI) Average 9.03 Min 6.50 Max 12.30 Dnstream (D2) Average 8.54 Min 5.39 Max 12.10 Summary Statistics U-DI Difference Average 1.37 Min -4.20 Max 7.60 # > 2.8"C 8.00 U-D2 Difference Average 1.75 Min -2.60 Max 4.90 # > 2.8'C 10 Summary Statistics Upstream (U) Average 114 Min 51 Max 176 Dnstream (Dl) Average 726 Min 175 Max 1525 Dnstream (D2) Average 222 Min 121 Max 400 DIVISION OF WATER QUALITY April 22, 2002 To: Dave Goodrich, Supervisor NPDES Unit From: Susan A. Wilson, Environmental Engineer NPDES Unit Subject: Guidance Regarding Conductivity and Fecal Coliform Monitoring INSTREAM CONDUCTIVITY AND FECAL COLIFORM MONITORING GUIDANCE Fecal coliform monitoring: Instream monitoring for fecal coliform may be removed from municipal or domestic wastewater permits (major or minor), unless the water body is impaired due to coliform or is a Class B waterbody. Conductivity monitoring. Instream monitoring for conductivity may be removed from all 100% domestic wastewater permits. Instream conductivity monitoring must remain for industrial discharges and domestic discharges that have a pretreatment program. S:\SWP-Point Source\NPDES\Policies - NPDES permits\fecal and conductivity monitoring.doc Asheboro WWTP Stream Impairment Analysis - Copper Loading N00026123 Stream Impairment Analysis Loading of Copper Asheboro W (Metal (mg/L))•(Average Monthly Flow(MGD))08.34 Date Ibs/day 1/1/2008 0.280962 2/1/2008 0.422838 3/1/2008 0.334693 4/112GOB 0.370026 5/1/2008 0.465609 6/1/2008 0.381747 7/1/2008 0.343704 811120M 0.421656 9/1/2008 0.343747 10/1/2008 0.347726 11/1/2008 0.384829 12/1/2008 0.417656 1/1/2009 0.350148 2/1/2009 0.347438 3/1/2009 0.382456 4/1/2009 0.238171 5/1/2009 0.270553 6/3/2009 0.364765 7/1/2009 0.34004 8/1/2009 0.312376 9/1/2009 0.329874 10/1/2009 0.292935 11/1/2009 0.513184 12/1/2009 0.393837 1/1/2010 0.511838 2/1/2030 0.453534 3/1/2010 0.267242 4/1/2010 0.225457 5/1/2010 0.241303 6/1/2010 0.384227 7/1/2010 0.350973 8/1/2010 0.355897 9/1/2030 0.308855 10/1/2010 0.217312 11/1/2010 0.2438" 12/1/2010 0.243935 1/1/2011 0.443038 2/1/2011 0.454056 3/1/2011 0.359743 4/1/2011 0.208424 5/1/2011 0.255516 6/1/2011 0.331518 7/1/2011 0.363712 8/1/2011 0,244871 9/1/2011 0.224974 10/1/2011 0.251417 11/1/2031 0.279935 12/1/2011 0.389994 1/1/2012 0.373326 2/1/2012 0.30992 3/1/2012 0.313798 4/1/2012 0.310404 5/1/2012 0.263889 6/1/2012 0.089338 7/1/2012 0.061608 8/1/2012 0.160065 9/1/2012 0.128875 10/1/2012 0.128774 11/1/2012 0.069486 12/1/2012 0.16747 1/1/2013 0.233361 2/1/2013 0.218829 3/1/1013 0.086559 Asheboro WWTP(NCO026123)- Copper Loading 0.6 os •• y=-9E-05x r 3.6591 W 0.435 y 0.4 , • •, • • S • • a 0.3 • 'e p • f • 0.2 `o • • ' , W 0.1 • .,,w • • q SUMMARY OUTPUT Regression 5tatistics Multiple R 0.696443 R Square 0.485033 Adjusted R Square 0.480393 Standard Error 0.085818 Observations 113 ANOVA df 55 MS F Sig. F Regression 1 0.769965 0.769965 104.S476642 1.08441E-17 Residual 111 0.817485 0.007365 Total 112 1.58745 CoeJf. Std Error tStar P-value mwer95% Uppe195% Lower95.0% Upper95D% Intercept 3.659062 0.334727 10.93149 2.54038E-19 2.995778593 4.322345 2.995779 4,322345 Date -8.31E-05 8.13E-06 -10.22486 1.08441E-17 -9.92565E-05 -6.7E-05 -9.93E-05 -6.7E-05 Asheboro WWTP Stream Impairment Analysts - Copper loading NCO026123 4/1/2013 0.123756 5/1/2013 0.187932 6/1/2013 0.147835 7/1/2013 0.201933 8/1/2013 0.382838 9/1/2013 0.098034 10/1/2013 0.045751 11/1/2013 0.072582 12/1/2013 0.159484 1/1/2014 0.170238 2/1/2014 0.154681 3/1/2014 0.166178 4/1/2014 0.118978 5/1/2014 0.094831 6/1/2014 0.077775 7/1/2014 0.074932 8/1/2014 0.106265 9/1/2014 0.076372 10/1/2014 0.047492 11/1/2014 0.104604 12/1/2014 0.398585 1/1/2015 0.119319 2/1/2015 0.124265 3/1/2015 0.116243 4/1/2015 0.237268 5/1/2015 0.086641 6/1/2015 0.076642 7/1/2015 0.073262 8/1/2015 0.071935 9/1/2015 0.128704 10/1/2015 0.216012 11/1/2015 0.198129 12/1/2015 0.267959 1/1/2016 0.208727 2/1/2016 0.200008 3/1/2016 0.200499 4/1/2016 0.215037 5/1/2016 0.251682 6/1/2016 0.105692 7/1/2016 0.140616 8/1/2016 0.163066 9/1/2016 0.152323 10/1/2016 0.121075 11/1/2016 0.149333 12/1/2016 0.154724 1/1/2017 0.291416 2/1/2017 0.147792 3/1/2017 0.165248 4/1/2017 0.149029 5/1/2017 0.118455 K, DO Final 2016 Category 5 Assessments-303(d) List Enriwam rw Deep River Subbasin Cape Fear River Basin Q-s+r Assessment Unit Name Assessment Unit Description Assessment Unit Number Water Quality Classification Length/Area Units Cotton Creek From Otts Lake to SR 1369 17-26-5-3b2 WS-III 0.5 FW Miles ssessment Criteria Status Reason for Rating Parameter of Interest IR Category Exceeding Criteria > 10% and >90 conf Copper (7 µg/I, AL, FW) 5 Cotton Creek From SR 1369 to SR1371 17-26-5-3b3 WS-III 1.4 FW Miles Cotton Creek From SR 1371 to Cabin Creek 17-26-5-3c WS-III 3.7 FW Miles DEEP RIVER From dam at Randleman Reservoir to US 220 Business 17-(10.5)a C 1.6 FW Miles DEEP RIVER From Haskett Creek to Gabriels Creek 17-(10.5)d1 C 2.7 FW Miles DEEP RIVER From Gabriels Creek to Brush Creek 17-(10.5)d2 C 18.2 FW Miles 3/23/2018 Final 2016 NC Category 5 Assessments Page 13 of 196 Asheboro WWTP(NC0026123) Instream Inorganic Nitrogen -B4870000(U) • B4890000(Dl)-B4920000(D2) 25.0 • J 20.0 15.0 o •• ? 10.0 N 0.0 ,y3 1'� .y3 ,YA 'yC` .yA .yh ye .,y tib tib 1�D Nap �aJ SeQ Nab �aJ �� ,aR jai 5e� sac �aa yet Asheboro WWTP (NC0026123) Instream Total Kjeldahl Nitrogen -B4870000(U) • B4890000(Dl)-B4920000(D2) 2.5 2.0 J ,�b 1.5 E Y 1.0 f- 0.5 p 'y'D 'Y'S p SP 1A ,tib 1b ye 1h by yh .y�c ti� ,�6 yb ,ac VO NJY OZ- ,ac PQ� �o� O -,a0 VSr %V 00` NO PQe %0 0& Asheboro WWTP(NC0026123) Instream Total Nitrogen -B487000o(U) 9 B4890000(D1) -B4920000(D2) 30.0 25.0 20.0 E 15.0 10.0 5.0 0.0 y3 ti� 1'h ,tib .tiM1 Nu 'rh .y9 ,yh 1�D .y0 y0 lac "aJ Summary Statistics Upstream (U) Average 0.17 Min 0.02 Max 0.37 Dnstream (DI) Average 6.95 Min 0.69 Max 23.00 Dnstream (D2) Average 0.63 Min 0.12 Max 1.85 Summary Statistics Upstream (U) Average 0.53 Min 0.20 Max 1.11 Dnstream (DI) Average 1.27 Min 0.79 Max 2.30 Dnstream (D2) Average 0.69 Min 0.20 Max 1.20 Summary Statistics Upstream (U) Average 0.70 Min 0.23 Max 1.39 Dnstream (D1) Average 8.22 Min 1.63 Max 24.80 Dnstream (D2) Average 1.32 Min 0.37 Max 3.05 Asheboro WWTP(NC0026123) Instream Total Phosphorus —B4870000(U) * B4890000(Dl) —B4920000(D2) 1.4 1.2 1.0 as as 0.8 E n 0.6 F 0.4 0.2 0.0 Kti� `tiA J`.�'9 Oy3 C J`,OZ` la yb ,yP C <7 0 \,yb lw pR 1 � .1 PQ QQ 8 .10 QQa N OL`. Summary Statistics Upstream (U) Mean 0.06 Min 0.02 Max 0.29 Dnstream (D1) Mean 0.29 Min 0.06 Max 1.20 Dnstream (D2) Mean 0.10 Min 0.04 Max 0.20 MONITORING REPORT(MR) VIOLATIONS for: Permit: NCO026123 MRS Between 1 - 2013 and 2 - 2018 Region: % Facility Name: % Param Name % County: % Major Minor: % PERMIT: NCO026123 FACILITY: City of Asheboro - Asheboro W WTP Report Dale: 02/19/18 Page: 1 of 5 Violation Category:Limit Violation Program Category: % Subbasin: % Violation Action: % COUNTY: Randolph REGION: Winston-Salem Limit Violation MONITORING REPORT OUTFALU PPI LOCATION PARAMETER VIOLATION DATE FREQUENCY UNIT OF MEASURE LIMIT CALCULATED VALUE % Over VIOLATION TYPE VIOLATION ACTION 01-2013 001 Effluent Chlorine, Total Residual 01/18/13 5 X week uge 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 02-2013 001 Effluent Chlorine, Total Residual 02/04/13 5 X week ug/1 17 18 5.9 Daily Maximum No Action, BPJ Exceeded 02-2013 001 Effluent Chlorine, Total Residual 0226113 5 X week ug8 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 03.2013 001 Effluent Chlorine, Total Residual 03/21/13 5 X week ug/I 17 38 123.5 Daily Maximum No Action, BPJ Exceeded 03-2013 001 Effluent Chlorine, Total Residual 0322113 5 X week ugll 17 27 58.8 Daily Maximum No Action, BPJ Exceeded 03-2013 001 Effluent Chlorine. Total Residual 03125/13 5 X week ugll 17 35 105.9 Daily Maximum No Action, BPJ Exceeded 03-2013 001 Effluent Chlorine, Total Residual 03/26/13 5 X week ug/I 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 03-2013 001 Effluent Chlorine, Total Residual 0328/13 5 X week ug/I 17 26 52.9 Daily Maximum No Action, BPJ Exceeded 04-2013 001 Effluent Chlorine, Total Residual 04/05/13 5 X week ug/I 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 04-2013 001 Effluent Chlorine. Total Residual 04/11/13 5 X week ug/I 17 18 5.9 Daily Maximum No Action, BPJ Exceeded 04-2013 001 Effluent Chlorine, Total Residual 04/15/13 5 X week ug4 17 26 52.9 Daily Maximum No Action, BPJ Exceeded 04-2013 001 Effluent Chlorine, Total Residual D4124113 5 X week ug/I 17 24 41.2 Daily Maximum No Action, BPJ Exceeded 04-2013 001 Effluent Chlorine, Total Residual 04/25/13 5 X week ug/I 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 04-2013 001 Effluent Chlorine, Total Residual 04/30/13 5 X week ug/I 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 05-2013 001 Effluent Chlorine, Total Residual 05/06/13 5 X week ug/I 17 45 164.7 Daily Maximum No Action, BPJ Exceeded MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/19/18 Page: 2 of 5 Permit: NCO026123 MRs Between 1 - 2013 and 2 - 2018 Region: % Violation Category:Limit Violation Program Category: Facility Name: % Param Name % County: % Subbasin: % Violation Action: % Major Minor: % PERMIT: NCO026123 FACILITY: City of Asheboro -Asheboro WWTP COUNTY: Randolph P REGION: Winston-Salem Limit Violation MONITORING OUTFAW VIOLATION UNITOF CALCULATED % REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION O6-2013 001 Effluent Chlorine, Total Residual 06/07/13 5 X week ugA 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 05-2013 001 Effluent Chlorine, Total Residual 05/09/13 5 X week ugA 17 33 94.1 Daily Maximum No Action, BPJ Exceeded 05-2013 001 Effluent Chlorine, Total Residual 05/16/13 5 X week ug/I 17 24 41.2 Daily Maximum No Action, BPJ Exceeded 05-2013 001 Effluent Chlorine, Total Residual 05/20/13 5 X weak ug/I 17 22 29.4 Daily Maximum No Action, BPJ Exceeded 05_2013 001 Effluent Chlorine, Total Residual 05/22/13 5Xweek ugA 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 05-2013 001 Effluent Chlorine, Total Residual 05/24/13 5 X week ugA 17 27 58.8 Daily Maximum No Action, BPJ Exceeded 08-2013 001 Effluent Chlorine, Total Residual 08/07/13 5 X week uga 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 08-2013 001 Effluent Chlorine, Total Residual 08/08/13 5 X week ug/I 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 09-2013 001 Effluent Chlorine, Total Residual 09/18/13 5Xweek ugA 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 09-2013 001 Effluent Chlorine, Total Residual 09/25/13 5 X week ugA 17 31 82.4 Daily Maximum No Action, BPJ Exceeded 09.2013 001 Effluent Chlorine, Total Residual 09/26/13 5 X week ugfl 17 34 100 Dally Maximum No Action, BPJ Exceeded 09-2013 001 Effluent Chlorine, Total Residual 09/27/13 5 X week ug/I 17 28 64.7 Daily Maximum No Action, BPJ Exceeded 11-2013 001 Effluent Chlorine, Total Residual 11/22/13 5 X week ugn 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 04-2014 001 Effluent Chlorine, Total Residual 04/17/14 5 X week ugA 17 25 47.1 Daily Maximum No Action, BPJ Exceeded 04-2014 001 Effluent Chlorine, Total Residual 04/22/14 5 X week ugA 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 04-2014 001 Effluent Chlorine, Total Residual 04/23/14 5 X week ugn 17 25 47.1 Daily Maximum No Action, BPJ Exceeded MONITORING REPORT(MR) VIOLATIONS for: Permit: NCO026123 MRS Between 1 - 2013 and 2 - 2018 Region: % Facility Name: % Person Name % County: % Major Minor. Report Date: 02/19/18 Page: 3 of 5 Violation Category:Limf Violation Program Category: Subbasin: % Violation Action: % PERMIT: NCO026123 FACILITY: City of Asheboro - Asheboro WWTP COUNTY: Randolph REGION: Winston-Salem Limit Violation MONITORING OUTFAW VIOLATION UNIT OF CALCULATED % REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 04-2014 001 Effluent Chlodne, Total Residual 04/26/14 5 X week ugA 17 37 117.6 Daily Maximum No Action, BPJ Exceeded 05-2014 001 Effluent Chlorine, Total Residual 05/01/14 5Xweek ugn 17 40 135.3 Daily Maximum No Action, BPJ Exceeded 05-2014 001 Effluent Chlorine, Total Residual 05/05/14 5 X week ug/I 17 48 182.4 Daily Maximum No Action, BPJ Exceeded 05-2014 001 Effluent Chlodne, Total Residual 05/06/14 5 X week ug/I 17 33 94.1 Daily Maximum No Action, BPJ Exceeded 05-2014 001 Effluent Chlodne, Total Residual 05/07/14 5 X week ugfl 17 34 100 Daily Maximum No Action, BPJ Exceeded 05.2014 001 Effluent Chlodne, Total Residual 05/08/14 5 X week ug/I 17 34 100 Daily Maximum No Action, BPJ Exceeded 05-2014 001 Effluent Chlodne, Total Residual 05/09/14 5 X week ug/I 17 18 5.9 Daily Maximum No Action, BPJ Exceeded 07.2014 001 Effluent Chlorine, Total Residual 07/17/14 5 X week ugll 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 08-2014 001 Effluent Chlorine, Total Residual 08/22/14 5 X week ugll 17 18 5.9 Daily Maximum No Action, BPJ Exceeded 08-2014 001 Effluent Chlorine, Total Residual 08/28/14 5 X week ugll 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 08-2014 001 Effluent Chlodne, Total Residual 08/29/14 5 X week ug/l 17 31 82A Daily Maximum No Action, BPJ Exceeded 09-2014 Got Effluent Chlodne, Total Residual 09/11/14 5 X week ug/I 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 09.2014 001 Effluent Chlodne, Total Residual 09/12/14 5 X week ug/I 17 29 70.6 Daily Maximum No Action, BPJ Exceeded 09-2014 001 Effluent Chlodne, Total Residual 09/19/14 5 X week ug/I 17 29 70.6 Daily Maximum No Action, BPJ Exceeded 10-2014 001 Effluent Chlodne, Total Residual 10/31/14 5 X week ug/I 17 23 35.3 Daily Maximum No Action, BPJ Exceeded 11.2014 001 Effluent Chlodne, Total Residual 11/17/14 5 X week ug/I 17 28 64.7 Daily Maximum No Action, BPJ Exceeded MONITORING REPORT(MR) VIOLATIONS for: Permit: NCO026123 MRS Between 1 - 2013 and 2 - 2018 Region: % Facility Name: % Param Name % County: % Major Minor: % Report Date: 02/19/18 Page: 4 of 5 Violation Category:Limit Violation Program Category: % Subbasir % Violation Action: % PERMIT: NCO026123 FACILITY: City of Asheboro -Asheboro WWTP COUNTY: Randolph REGION: Winston-Salem Limit Violation MONITORING OUTFALLI VIOLATION UNIT OF CALCULATED % REPORT ppi LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Mar VIOLATION TYPE VIOLATION ACTION 04.2015 001 Effluent Chlorine, Total Residual 04/08/15 5 X week ug4 17 24 41.2 Daily Maximum No Action, BPJ Exceeded 04-2015 001 Effluent Chlorine, Total Residual 04/15/15 5 X week ug/I 17 22 29.4 Daily Maximum No Action, BPJ Exceeded 04-2015 001 Effluent Chlorine, Total Residual 04/17/15 5 X week ug/I 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 12-2015 001 Effluent Chlorine, Total Residual 12/22/15 5 X week ug/I 17 23 35.3 Daily Maximum No Action, BPJ Exceeded 09-2016 001 Effluent Chlorine, Total Residual 09/19/16 5 X week ug/I 17 46 170.6 Daily Maximum No Action, BPJ Exceeded 09-2016 001 Effluent Chlorine, Total Residual 09/28/16 5 X week ug/l 17 27 58.8 Daily Maximum No Action, BPJ Exceeded 09.2016 001 Effluent Chlorine, Total Residual 09/29/16 5 X week ug/I 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 10-2016 001 Effluent Chlorine, Total Residual 10/13/16 5 X week ug/I 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 10-2016 001 Effluent Chlorine, Total Residual 10/14/16 5 X week ug/I 17 41 141.2 Daily Maximum No Action, BPJ Exceeded 10-2016 001 Effluent Chlorine, Total Residual 10/20/16 5 X week ug/I 17 22 29.4 Daily Maximum No Action, BPJ Exceeded 11-2016 001 Effluent ChloNne, Total Residual 11/04/16 5 X week ug/I 17 20 17.6 Dally Maximum No Action, BPJ Exceeded 11-2016 001 Effluent Chlorine, Total Residual 11/07/16 5 X week ug/I 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 11-2016 001 Effluent Chlorine, Total Residual 11/08/16 5 X week ug/I 17 22 29.4 Dally Maximum No Action, BPJ Exceeded 11.2016 001 Effluent Chlorine, Total Residual 11/30/16 5 X week ug/I 17 25 47.1 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/01/16 5Xweak ug/l 17 26 52.9 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/05/16 5 X week ug/l 17 40 135.3 Daily Maximum No Action, BPJ Exceeded MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/19/18 Page: 5 of 5 Permit: NCO026123 MRS Between 1 - 2013 and 2 - 2018 Region: % Violation Category:Limit Violation Program Category: Facility Name: % Param Name % County: % Subbasin:% Violation Action: % Major Minor: % PERMIT: NCO026123 FACILITY: City of Asheboro -Asheboro WWTP COUNTY: Randolph P REGION: Winston-Salem Limit Violation MONITORING OUTFALU VIOLATION UNIT OF CALCULATED % REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 12-2016 001 Effluent Chlorine, Total Residual 12/13/16 5 X week u9/1 17 22 29.4 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/15/16 5 X week ug/l 17 21 23.5 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/29/16 5 X week ugA 17 34 100 Daily Maximum No Acton, BPJ Exceeded 01 -2017 001 Effluent Chlorine, Total Residual 01/03/17 5 X week ugA 17 47 176.5 Daily Maximum No Action, BPJ Exceeded 01 -2017 001 Effluent Chlorine, Total Residual 01/23/17 5 X week ug4 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 02.2017 001 Effluent Chlorine, Total Residual 02/20/17 5 X week ugA 17 26 52.9 Daily Maximum No Acton, BPJ Exceeded 02.2017 001 Effluent Chlorine, Total Residual 02121/17 5 X week ugA 17 27 58.8 Daily Maximum No Action, BPJ Exceeded 02-2017 001 Effluent Chlorine, Total Residual 02/27/17 5 X week ugA 17 26 52.9 Daily Maximum No Action, BPJ Exceeded 04-2017 Got Effluent Chlorine, Total Residual 04/05/17 5 X week ugA 17 19 11.8 Daily Maximum No Acton, BPJ Exceeded 05-2017 001 Effluent Chlorine, Total Residual 05/25/17 5 X weak ugA 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 08.2017 001 Effluent Chlorine, Total Residual 08/04/17 5 X week ugA 17 19 11.8 Deily Maximum No Acton, BPJ Exceeded 01-2016 001 Effluent Nitrogen, Ammonia Total (as 01/31/16 5 X week mgA 4 4.25 6.3 Monthly Average Proceed to NOD N)- Concentration Exceeded Whole Effluent Toxicity Testing and Self Monitoring Summary Archer Daniels Midland-Southport/001 NCO027065/001 County: Brunswick Region: WIRO Basin: CPF17 Jan Apr Jul Oct SOC_JOC: Ceri7dPF Begin: 6/1/2012 Chr Lim: 0.3% NonComp: 70LO: TIDAL PF: 3.502 IWC: 0.3 Freq: Q J F M A A4 l l A S 0 N D 2014 Pass - - Pass - - Pass - - Pass - - 2015 Pass - - Pass - - Pass - - Pass - - 2016 Pass - - Pass - - Pass - - Pass - - 2017 Pass - - Pass - - Pass - - Pass - - Arclin USA Inc. NCOOD0892/001 County: Chatham Region: RRO Basin: CPF07 Feb May Aug Nov SOCJOC: Ceri7dPF Begin: 7/1/2013 chr lim: 0.39% + NonComp: Single 7Q30: 40.0 PF: 0.10 IWC: 0.39 Freq: Q I F M A M J J A S 0 N D 2014 - Pass - - Pass - - Pass - - Pass - 2015 - Fail >0.78 >0.78 Pass - - Pass - - Pass - 2016 - Pass - - Pass - - Pass - - Pass - 2017 - Pass - - Pass - - Fail >1.6 >1.6 Pass - Asheboro WWFP NOD026123/001 County: Randolph Region: WSRO Basin: CPFD9 Mar Jun Sep Dec SOC10c; Ceri7dPF Begin: 8/1/2012 chr lim: 90% NonComp: Single 7Q30: 0.0 PF: 9.0 IWC: 100 Freq: Q J F M A M J 1 A S 0 N D 6 a� SS 2014 - Pass - Pass - - Pass Pass b Q P 2015 - - Pass - - Pass>100(P) - - Pass - - Pass 2016 - - >100(P)Pass - - Pass - - Pass - - Pass 2017 - - Pass - - Pass >300(P) - - Pass - - Pass Asheville DeBruhl WfP NCO056961/DD1 County: Buncombe Region: ARO Basin: FRB02 Jan AprJul Oct SOC JOC: Ceri7dPF Begin: 6/1/2012 chr monit: 12%(Grab NonComp: Single 7Q10: 1.1 PF: 0.1 IWC: 12.3 Freq: Q J F M A M 1 J A S 0 N D 2014 Pass - - Pass - - Pass - - Pass - - 2015 Pass - - Pass - - Pass - - Pass - - 2016 Pass - - Pass - - Pass - - Pass - - 2017 Pass - - Pass - - Pass - - Pass - - Asheville Northfork WFP NOD035807/001 County: Buncombe Region: ARO Basin: FRB02 Jan Apr Jul Oct SOC_JOC: Ceri7dPF Begin: 7/1/2012 chr Monit: 42% NonComp: Single 7Q10: 1.7 PF: 0.8 IWC: 42.2 Freq: Q J F M A M J J A S O N D 2014 Pass - - Pass - - Pass - - Pass - - 2015 Pass - - Pass - - Pass - - Pass - - 2016 Pass - - Pass - - Pass - - Pass - - 2017 Pass - - Pass - - Pass - - Pass - - Associated Asphalt Greensboro(HRS) NCDO74241/001 County: Guilford Region: WSRO Basin: CPF08 SOC_JOQ Fthd24Ac Begin: 1/1/2012 24hr LC50 ac monit a NonComp: 7Q30: 0.0 PF: VAR IWC: 100 Freq: A J F M A M l J A S 0 N D 2014 >100 - - - - - - _ _ - 2015 - - >100- 2016 - >100 2017 >100 - Legend: P= Fathead minnow (Pimphales oromelas). H=No Flow (facility Is activel. s= Solit test between Certified Labs Page 5 of 105 Water Resources ENVIRONMENTAL QUALITY March 13, 2017 PAT MCCRORY Gowmor DONALD R. VAN DER VAART Secretary S. JAY ZIMMERMAN Dnl ,I.J Mr. John N. Ogbum, City Manager City of Asheboro P.O. Box 1106 Asheboro, NC 27204 RECEIVC" f NCDEOJDWR SUBJECT: Compliance Evaluation Inspection (CEI) MAR 21 P017 City of Asheboro Wastewater Treatment Plant Water Quality NPDES Permit # NCO026123 Fe invtiitiS`'cGii0P Randolph County Dear Mr. Ogburn: A Compliance Evaluation Inspection was performed on the subject facility by April Norton of the Winston- Salem Regional Office on March 9, 2017 at 10:00 am. Mr. Michael Wiseman, Operator in Responsible Charge (ORC), was present for the inspection. The inspection is comprised of an overall evaluation in order to document compliance and noncompliance of facilities equipment, capability to meet effluent limits, and terms & conditions with the National Pollutant Discharge Elimination System (NPDES) permit. Permit The NPDES permit became effective August 1, 2012 and expired September 30, 2016. Per NPDES Permit NC0026123, Section B, General Conditions: The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required by the agency authorized to issue permits no later than 180 days prior to expiration date unless permission for a later date has been granted by the Director. Records & Reports All process controls, site observations, and maintenance records are maintained on site. All records are kept for 3 years and sludge for 5 years. All laboratory records are kept for 5 years. Facility Site Review The facility consists of 9.0 million gallons per day (MGD) wastewater treatment plant containing the following components: six rectangular primary clarifiers, three trickling filters, four secondary clarifiers, two aeration basins, tertiary sand filter, and three final clarifiers. The wastewater in the aeration basins appeared to be a nice, healthy brown color. The wastewater at the clarifiers appeared to be clear, some floating solids (grease) were present. EffluentfReceivina Waters The effluent to Haskett Creek, flows into the Cape Fear River Basin, Class C waterbody, appeared clear with no visible foam or sheen. Flow Measurement The NPDES permit requires continuous flow recording and an annual calibration. The flow measuring Slate of North Caroline I Environmental Quality J Water Resources 450 West Hanes MITI Road, Suite 300, W nston-Salem, NC 27105 Phone: 336-776-9800 1 Internet w .nodenrgou device was last calibrated January 26, 2017 by Instrumentation Services, Inc. The next calibration is due April 30, 2017 Self-Monitorine Proeram There were not any permit limit violations within the last 12 months. Laboratory data verification was performed on June 2016 Discharge Monitoring Report (DMR). There were no errors noted. Laboratory The City of Asheboro has an on -site laboratory for most services. Additional laboratory services are conducted by Meritech. Operations & Maintenance There did not appear to be any operation and maintenance issues at the time of the inspection. Sludge Handline/Disposal Solids from the anaerobic digester are dewatered by the on -site belt press prior to land application covered under W00001684. Compliance Status The compliance evaluation inspection is satisfactory. Mr. Wiseman and his staff operate the facility in an excellent manner. Should you have any questions concerning this report, please contact April Norton or me at (336) 776- 9800. Sincerely, F�/Sherri V Knight, PE, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ cc: Michael Wiseman (e-copy) Central Files WSRO Files K CMG SS United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expiresB-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 U 2 L 3 1 NCO026123 I11 12 17/03/13 17 18 I C 19 J S j 20LJ 21111 1 1 1 1 1 1 1 11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 l� 1 1, r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67 7014 I 71 I„ I 72 LNJ 73 Lj_j74 751 1 I 1 Lj__U80 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 17103/13 12/08/01 Asheboro WWTP Exit Time/Date Permit Expiration Date 1032 Bonkemeyer Dr Asheboro NC 27203 11:30AM 17/03/13 16/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data 111 Michael Ray Wiseman/ORC/336.672-08921 Name, Address of Responsible Official/Title/Phone and Fax Number Contacted John N Ogbum,PO Box 1106 Asheboro NC 272041106/C4 Manager/336.626-1213/3366261218 NO Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance 0 Records/Reports Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signatures) of Inspector(s) Agency/Office/Phone and Fax Numbers Date April Norton WSRO WQ/1336-776-9800/ 3� l� Signa4,fMmanagement Q A Reviewer Agency/Office/Phone and Fax Numbers Date 10 9-1?-17 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES 31 NCO026123 I11 yr/mo/day Inspection Type 12 17/03/13 17 18 I C I Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checidists as necessary) Page# Permit: NCO026123 Owner - Facility: Asheboro WWTP Inspection Date: 03/13/2017 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 0 ❑ ❑ ❑ application? Is the facility as described in the permit? ❑ ❑ ❑ # 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? M ❑ ❑ ❑ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? M ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ [] Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type M ❑ ❑ ❑ representative)? Comment: Record Keepin4 Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? M ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ❑ ❑ ❑ Is the chain -of -custody complete? 0 ❑ ❑ ❑ Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ Page# 3 Permit NCO026123 Owner - Facility: Asheboro WWrP Inspection Date: 03/13/2017 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ ❑ 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? M ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? 0 ❑ . ❑ ❑ Comment: 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 M ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ ❑ ❑ Is flow meter calibrated annually? ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ M Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? ❑ ❑ ❑ Is the screen free of excessive debris? M ❑ ❑ ❑ Is disposal of screening in compliance? ❑ ❑ 0 ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Grit Removal Yes No NA NE Type of grit removal Page# 4 Permit: NC0028123 Inspection Date: 03/13/2017 Owner - Facility: Asheboro WWTP Inspection Type: Compliance Evaluation Grit Removal Yes No NA NE a.Manual ❑ b.Mechanical Is the grit free of excessive organic matter? 0 ❑ ❑ ❑ Is the grit free of excessive odor? M ❑ ❑ ❑ # Is disposal of grit in compliance? 0 ❑ ❑ ❑ Comment: Primary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ M ❑ Are weirs level? M ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) 0 ❑ ❑ ❑ Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? M ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? M ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? M ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) M ❑ ❑ ❑ Comment: Page# 5 Permit: NCO026123 Owner - Facility: Asheboro WWTP Inspection Date: 03/13/2017 inspection Type: Complianoe Evaluation Trlcklina Filter Yes No NA NE Is the filter free of ponding? 0 ❑ ❑ ❑ Is the filter free of leaks at the center column of filter's distribution arms? E ❑ ❑ ❑ Is the distribution of flow even from the distribution arms? E ❑ ❑ ❑ Is the filter free of uneven or discolored growth? N ❑ ❑ ❑ Is the filter free of sloughing of excessive growth? N ❑ ❑ ❑ Are the filter's distribution arms orifices free of clogging? 0 ❑ ❑ ❑ Is the filter free of excessive filter flies, worms or snails? N ❑ ❑ ❑ Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? N ❑ ❑ ❑ 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? ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mgA) 0 ❑ ❑ ❑ Comment: De -chlorination Yes No NA NE Type of system ? Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ 0 ❑ ❑ Is storage appropriate for cylinders? ❑ ❑ 0 ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑ Comment: 10:1 chlorine to de -color Are the tablets the proper size and type? ❑ ❑ ❑ Are tablet de -chlorinators operational? ❑ ❑ N ❑ Number of tubes in use? 0 Comment: no comment Page# 6 Permit: NC0026123 Owner - Facility: Asheboro VWVTP Inspection Date: 03/13/2017 Inspection Type: Compliance Evaluation Disinfection -Liquid Yes No NA NE Is there adequate reserve supply of disinfectant? 0 ❑ ❑ ❑ (Sodium Hypochlorite) Is pump feed system operational? 0 ❑ ❑ ❑ Is bulk storage tank containment area adequate? (free of leaks/open drains) M❑ ❑ ❑ Is the level of chlorine residual acceptable? ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ M Comment: Page# 7 IWC Calculations Facility: Asheboro WWTP NC0026123 Prepared By: Jennifer Busam Enter Design Flow (MGD): 9 Enter s7Q10 (cfs): 0 Enter w7Q10 cfs : 0 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/1) Ammonia (Summer) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 0 s7Q10 (CFS) 0 DESIGN FLOW (MGD) 9 DESIGN FLOW (MGD) 9 DESIGN FLOW (CFS) 13.95 DESIGN FLOW (CFS) 13.95 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22 IWC (%) 100.00 IWC (%) 100.00 Allowable Conc. (ug/1) 17 Allowable Conc. (mg/1) M A = 1.0 V)/ Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 0 Monthly Average Limit: 200/100ml DESIGN FLOW (MGD) 9 (If DF >331; Monitor) DESIGN FLOW (CFS) 13.95 (If DF<331; Limit) STREAM STD (MG/L) 1.8 Dilution Factor (DF) 1.00 Upstream Bkgd (mg/1) 0.22 IWC (%) 100.00 Allowable Conc. (mg/1) Mi° = 1.8 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/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I 4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter) 5. BAT for Major Municipals: 1 mg/I (year-round) Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NPDES Server/Current Versions/WLA; TB 1 /16/2009 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY Table 1. Project Information 01 IF HQW OR ORW WQS Facility Name Asheboro WWTP W WTPfWTP Class GRADE IV NPDES Permit NCO026123 Outfall 001 9.000 Flow, Qw (MGD) Hasketts Creek Receiving Stream HUC Number 0303000301 Stream Class C 0.00 ❑Apply WS Hardness WQC 7Q10s (cfs) 7Q10w (cfs) 0.00 30Q2 (cfs) 0.20 CIA (cfs) 12.00 1 Q10s(1 0.00 Effluent Hardness 114.26 mg/L (Avg) .____________ Upstream Hardness _________ 9 ( _—____ 51.93 m /L (Avg) Combined Hardness Chronic 114.26 mg/L Combined Hardness Acute 114.26 mg/L Three PPAs, DMR data from May 2014 - Dec 2017; Hardness data provided by the facility upon request. Data Source(s) ❑CHEIXTO APPLY MODEL Follow directions for data entry. /n some cases a Par01 Par02 Par03 Par04 Par05 Par06M Par07 Par09 Par09 Par10 Par11 Par12 ii Par14 Par15 Parl6 Par17 Parts Par19 Par20 Par21 Par22 Par23 Par24 Par25 Table 2. Parameters of Concern Name WQs Type Chronic Momfier Acute PQL Units Arsenic Aquactic Life C 150 FW 340 ug/L Arsenic Human Health Water Supply C 10 HHNVS N/A uglL Beryllium Aquatic Life NC 6.5 FW 65 ug/L Cadmium Aquatic Life INC 1.8581 FW 12.1886 ug/L Chlorides Aquatic Life NC 230 FW ni 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 408.6988 FW 3141.9169 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 28.8733 FW 43.8372 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 15.8177 FW 405.9101 ug/L Mercury Aquatic Life NC 12 FW 0.5 ng/L Molybdenum Human Health NC 2000 HH uglL Nickel Aquatic Life NC 134.6587 FW 1212.3864 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 4.0458 ug/L Zinc Aquatic Life NC 459.2774 FW 455.5510 ug/L Dibromochloromethane Human Health C 21 HH pg/L Bromodichloromethane Human Health C 17 HH pg/L Chloroform Human Health INC 2000 HH pg/L 1,4-Dioxane Human Health C 6o HH pg/L NCO026123 RPA_2018a, input 10/1/2018 REASONABLE POTENTIAL ANALYSIS EffluentHardness 11M•TIlp7E SPED VMues"then"COPY" — . Maximum data ,aWtas • W Date Data BDL=I2DL Results 1 1077/2016 120 120 Ste Dev. 21.2350 1 2 10/132016 98 98 Mean 114.2614 2 3 10/19/2016 135 135 C.V. 0.1858 3 4 1025/2016 118 118 n 57 4 5 1122016 128 128 10th Per value 90.00 mg/L 5 6 11/102016 110 110 Average Value 114.26 nigh. 6 7 11/182016 145 145 Max. Value 166.00 mg/L 7 8 1121/2016 141 141 8 9 11/302016 120 120 9 10 12/62016 88 Be 10 11 12/14/2016 108 108 11 12 12/192016 112 112 12 13 12292016 144 144 13 14 1/5/2017 102 102 14 15 1/112017 110 110 15 16 1/172017 96 96 16 17 W32017 90 90 17 18 2/2/2017 78 78 18 19 27102017 108 108 19 20 2/152017 86 86 20 21 2/212017 90 90 21 22 3/72017 97.9 97.9 22 23 3/152017 100 100 23 24 3/232017 116 116 24 25 3/2912017 110 110 25 26 4WO17 93.8 93.8 26 27 4/11/2017 89.8 89.8 27 28 4/192017 106 106 28 29 4/272017 95.9 95.9 29 30 SWO17 110 110 30 31 6/102017 129 129 31 32 5/182017 153 153 32 33 5/262017 104 104 33 34 5/312017 144 144 34 35 6/8/2017 99.8 99.8 35 36 6/152017 108 108 36 37 6222017 81.1 81.1 37 38 6/302017 93.6 93.6 38 39 7/6/2017 104 104 39 40 7/122017 108 108 40 41 977/2017 112 112 41 42 9/132017 94 94 42 43 9/192017 110 110 43 44 9/282017 104 - 104 44 45 10/32017 104 104 45 46 10/11/2017 98 98 46 47 10119QO17 114 114 47 48 1027/2017 100 100 48 49 11/22017 131 131 49 50 11/82017 148 148 50 51 11/14/2017 133 133 51 52 1120/2017 154 154 52 53 11/30/2017 166 166 53 54 12/52017 149 149 54 55 12/132017 141 141 55 56 12/21/2017 141 141 56 57 l22WD17 143 143 57 58 68 Upstream Hardness Ivaivea••men Maximum points = Date Data BDL=I2DL Results 6x—..—... _s.� 8/292016 106 106 Sitl Dev. 21.5387 9/132016 40 40 Mean 61.9333 10/192016 49 49 C.V. 0.4147 1122016 69 69 n 12 12/62016 28 28 10th Per value 34.50 mg/L 1/112017 73 73 Average Value 51.93 mg/L 2/2/2017 39 39 Max. Value 106.00 mg/L 3/7/2017 49 49 4/112017 53 53 5/10/2017 34 34 6/8/2017 43.7 43.7 7/122017 39.5 39.5 NC0026123 RPA_2018a, data 10/12018 REASONABLE POTENTIAL ANALYSIS Petrel & Par02 Date Data 1 5/20/2014 < 2 6/192014 < 3 7/152014 < 4 8/202014 < 5 9/9/2014 < 6 10/142014 < 7 11/42014 < 8 12/42014 < 9 1/142015 < 10 2/d/2015 < 11 3/10/2015 < 12 4172015 < 13 5/132015 < 14 6/2/2015 < 15 7/7/2015 < 16 8/132015 < 17 9/15/2015 < 18 1021/2015 < 19 11/17/2015 < 20 12/8/2015 < 21 1/132016 < 22 2/162016 < 23 3/172016 < 24 4/142016 < 25 5/8/2016 < 26 6/142016 < 27 7/142016 < 28 8/17/2016 < 29 9/132016 < 30 10/19/2016 < 31 112/2016 < 32 12/62016 < 33 1/112017 < 34 2/22017 < 35 3/72017 < 36 411l2G17 < 37 5/102017 < 38 6182017 < 39 7/122017 < 40 8/172017 < 41 9/192017 < 42 10/11/2017 43 11/8/2017 < 44 12/52017 < 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Arsenic Vote then"COPr e,,Z data IWints = W BDL=1/2DL Rasuits 2.6 Sul Day. 0.6546 2.5 Mean 2.1182 2.5 C.V. 0.3090 2.5 n 44 2.6 2.5 Mult Factor = 1.04 2.5 Max. Value 2.5 uglL 2.5 Max. Pmd Cw 2.6 ug& 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 1 1 1 1 1 1 1 1 1 2.2 1 1 Beryllium Date Data BDL-112DL 12/12/2013 < 1 0.5 6/192014 < 1 0.5 3/172016 < 1 0.5 Values- then "COPY ' . Maximum data Ppinis -M Results Std Dev. 0.0000 Mean 0.5000 C.V. (default) 0.6000 n 3 Mutt Factor = 3.00 Max. Value 0.50 ug/L Max. Pmd Cw 1.50 ug/L _2_ NCO026123 RPA_2018a, data 10/1/2018 REASONABLE POTENTIAL ANALYSIS Cadmium Iv.wes'tA.n'COPr . Mulmum date points = 50 Date Data BDL=112DL Results 5/20/2014 < 0.5 0.25 Sul Dev. 0.0892 61192014 < 0.5 0.25 Mean 0.2739 7/152014 < 0.5 0.25 C.V. 0.3259 8/202014 < 0.5 0.25 n 44 919/2014 < 0.5 0.25 10/142014 < 0.5 0.25 Mult Factor = 1.04 11I42014 < 0.5 0.25 Max. Value 0.600 ug/L 12/42014 < 0.5 0.25 Max. Fred Cw 0.624 ug/L 11142015 < 0.5 0.25 2/3/2015 < 0.5 0.26 3/102015 < 0.5 0.25 4/72015 < 0.5 0.25 5/132015 < 0.5 0.25 6122015 < 0.5 0.25 7/7/2015 < 0.5 0.25 8/132015 < 0.5 0.25 9/152015 < 0.5 0.25 1021/2015 < 0.5 0.25 11/172015 < 0.5 0.25 12/82015 < 0.5 0.25 1/132016 < 0.5 0.25 2/162016 < 0.5 0.25 3/172016 < 0.5 0.25 4/142016 < 0.5 0.25 5/62016 < 0.5 0.25 6/142016 < 0.5 0.25 7/14/2016 < 0.5 0.25 8/17/2016 < 0.5 0.25 9/132016 < 0.5 0.25 10/192016 < 0.5 0.25 1102016 < 0.5 0.25 12/62016 < 0.5 0.25 1/112017 < 0.5 0.25 2/22017 < 0.5 0.25 3/7/2017 < 0.5 0.25 4/112017 < 0.5 0.25 5/102017 < 0.5 0.25 6/8/2017 0.6 0.6 7/12/2017 0.6 0.6 8/1712017 < 0.5 0.25 9/192017 0.6 0.6 10/11/2017 < 0.6 0.25 11182017 < 0.5 0.25 12WO17 < 0.5 0.25 Uee "PASTE SPEGIAL- Chlorides +luas'N.n-co".- Malmum tl.te p.IniS = Date Data BDL=I2DL Results 3/4/2014 138 138 Std Dev. 60.6764 4/152014 114 114 Mean 166.0 6/192014 230 230 C.V. 0.3656 9/9/2014 150 150 n 25 12/42014 300 300 3/102015 68 68 Mult Factor = 1.2 6/212015 150 150 Max. Value 300.0 mg/L 9/152015 241 241 Max. Fred Cw 351.0 mg/L 12WO15 130 130 11132016 135 136 2116/2016 122 122 3/172016 185 185 4/142016 220 220 5/62016 186 186 6/142016 169 169 7/1412016 240 240 8/172016 178 178 9/132016 160 160 10/19/2016 100 100 11/2/2016 180 180 12/6/2016 117 117 3/7/2017 77 77 6/8/2017 128 128 9/192017 137 137 121MO17 294 294 NCO026123 RPA 2018a, data - 3 - 10/12018 REASONABLE POTENTIAL ANALYSIS Chlorinated Phenolic Compounds "Mpximuin aaW' Total Phenolic Compounds Mix1mum 0eur' pdhn =50 polnb•W Date Data BDL=1/2DL Results k Date Data BDL-12DL Results Sld Dev. NO DATA 1 12/12/2013 < 5 2.5 Sal Dev. 0.0000 Mean NO DATA 2 8/192014 < 5 2.5 Mean 2.5000 C.V. NO DATA 3 3/172016 < 5 2.5 C.V. (default) 0.6000 n 0 4 n 3 5 Mull Factor = N/A 6 Mult Factor = 3.00 Max. Value N/A ug/L 7 Max. Value 2.5 ug/L Max. Pred Cw N/A ug/L 8 Max. Pmd Cw 7.5 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 36 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 NCO026123 RPA_2018a, data - 4 - 10/1/2018 REASONABLE POTENTIAL ANALYSIS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Chromium 111 Value,"Wen"COPY" Chromium VI Yalues"then"COPY . Maximum Gate . Maximum polnts = 4a polms Dale Data BDL=1I2DL Results Date Data BDL=1/2DL Results _ Sid Dev. NO DATA 1 Std Dev. NO DATA Mean NO DATA 2 Mean NO DATA C.V. NO DATA 3 C.V. NO DATA n 0 4 n 0 5 Mult Factor = N/A 6 Mult Factor = N/A Max. Value N/A pg/L 7 Max. Value N/A U9/L Max. Fred Cum N/A pg/L 8 Max. Fred Cw N/A 49/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 NCO026123 RPA_2018a, data - 5 - 10/1/2018 REASONABLE POTENTIAL ANALYSIS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Uw "PASTE SPECUU Chromium, Total Values" Nen "COPY . Maximum data polnl = 5 Date Data BDL=I2DL Results 5/202014 < 5 2.5 Sol Dev. 4.3051 6/192014 8 8 Mean 5.1705 7/152014 7 7 C.V. 0.8326 8202014 10 10 n 44 9/92014 6 6 10/14/2014 < 5 2.5 Mutt Factor = 1.10 11142014 12 12 Max. Value 26.0 pg/L 12/42014 26 26 Max. Pred Cw 28.6 pg/L 1/142015 8 8 2/3/2015 7 7 3/102015 < 5 2.5 OU2015 < 5 2.5 5/132015 < 5 2.5 602015 < 5 2.5 7f7/2015 < 5 2.5 8/132015 9 9 9/152015 7 7 10212015 7 7 11/172015 6 6 12/8/2015 5 5 1/132016 < 5 2.5 2/162016 < 5 2.5 3/172016 6 6 4/142016 8 8 5/62016 11 11 6/142016 < 5 2.5 71142016 10 10 8/172016 7 7 9/132016 5 5 10/192016 < 5 2.5 1122016 < 5 2.5 12/62016 < 5 2.5 1/11/2017 < 5 2.5 2/22017 < 5 2.5 W72017 < 5 2.5 4/112017 < 5 2.5 5/102017 < 5 2.5 6IM017 < 5 2.5 7/122017 < 5 2.5 8/172017 < 5 2.5 9/192017 < 5 2.5 101112017 < 5 2.5 11/82017 < 5 2.5 12/52017 < 5 2.6 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 Copper Date Data BDL=I2DL 5/202014 3 3 6/192014 3 3 7/152014 3 3 8202014 4 4 9/92014 3 3 10/14/2014 2 2 11/42014 4 4 12/42014 15 15 1/142015 4 4 2/3/2015 4 4 3/102015 3 3 4/7/2015 6 6 5/132015 3 3 6/22015 3 3 7/7/2015 3 3 8/132015 3 3 9/152015 5 5 1021/2015 7 7 11/172015 5 5 12/82015 6 6 1/132016 6 6 2/162016 5 5 3/172016 6 6 4/142016 7 7 5/6/2016 7 7 6/142016 4 4 7/142016 6 6 8/172016 6 6 9/132016 5 5 10/192016 4 4 11/22016 6 6 1202016 6 6 1/11/2017 8 8 222017 5.4 5.4 3f72017 6 6 4/112017 4.2 4.2 5/102017 3.6 3.6 602017 2.8 2.8 7/122017 2.1 2.1 8/172017 3 3 9/192017 3.8 3.8 10/112017 4.8 4.8 12/52017 4.8 4.8 Values" Nen "COPY' . Maximum tlam poinu =54 Results Std Dev. 2.1845 Mean 4.7791 C.V. 0.4571 n 43 Mutt Factor = 1.07 Max. Value 15.00 ug/L Max. Fred Cw 16.05 ug/L -6- NC0026123 RPA_2018a, date 10/12018 REASONABLE POTENTIAL ANALYSIS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Cyanide Values" then "COPY' . Maximum tlafa points = 58 Date Data BDL=112DL Results 6/19/2014 < 10 5 Ste Dev. 3.5305 9/9/2014 < 10 5 Mean 6.19 12/4/2014 < 10 5 C.V. 0.5708 3/10/2015 < 10 5 n 27 6/2/2015 < 10 5 9/15/2015 18 18 Mult Factor = 1.23 9/18/2015 12 12 Max. Value 18.0 ug/L 9/21/2015 17 17 Max. Pred Cw 22.1 ug/L 9/222015 < 10 5 9/23/2015 < 10 5 12/8/2015 < 10 5 1/13/2016 < 10 5 2/112016 < 10 5 3/142016 < 10 5 4/142016 < 10 5 5/6/2016 < 10 5 6/142016 < 10 5 7/142016 < 10 5 8/17/2016 < 10 5 9/132016 < 10 5 10/19/2016 < 10 5 1122016 < 10 5 12WO16 < 10 5 317/2017 < 10 5 6/8/2017 < 10 5 9/192017 < 10 5 12/52017 < 10 5 Fluoride °a wes-me"-wT . Maxmum data points = M Date Data BDL=112DL Results Std Dev. NO DATA Alean NO DATA C.V. NO DATA n 0 Mult Factor = N/A Max. Value N/A ug/L Max. Pred Cw N/A ug/L -7- NCO026123 RPA_2018a, data 10/12018 REASONABLE POTENTIAL ANALYSIS Date 1 5/202014 2 6/192014 3 7/162014 4 8202014 5 9/9/2014 6 10/142014 7 11/4/2014 8 12/42014 9 1/142015 10 213/2015 11 3/102015 12 4/7/2015 13 5/132015 14 602015 15 717/2015 16 8/132015 17 9/152015 18 10212015 19 11/17/2015 20 12/62015 21 1/132016 22 2/162016 23 3/172016 24 4/142016 25 5/6/2016 26 6/142016 27 7/142016 28 8/172016 29 9/132016 30 10/192016 31 1122016 32 12/62016 33 1/112017 34 22/2017 35 3/7/2017 36 4/112017 37 5/102017 38 6/8/2017 39 7/122017 40 8/172017 41 '91192017 42 10/112017 43 11/82017 44 12/52017 45 46 47 48 49 50 51 52 63 54 55 56 57 68 use TASTE SPECIAL Lead Yelues"then"COPY' . Maximum date polnu = 58 BDL=1/2DL Results < 5 2.5 SW Dev. 0.6758�� < 5 2.5 Mean 2.0909 < 5 2.5 C.V. 0.3232 < 5 2.5 n 44 < 5 2.5 < 5 2.5 Mult Factor = 1.04 < 5 2.5 Max. Value 2.500 ug/L < 5 2.5 Max. Pmd Cw 2.600 uglL < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 5 2.5 < 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 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 Mercury mass men-wr* . Maximum date Poln%=58 Date Data BDL=1/2DL Results Sid Dev. NO DATA Mean NO DATA C.V. NO DATA n 0 Malt Factor = N/A Max. Value N/A ng/L Max. Pred Cw NIA ng/L -8- NC0026123 RPA_2018a, data 10/12018 REASONABLE POTENTIAL ANALYSIS Molybdenum vamas"Wen"Coax . Maximum data Palms - 58 Date Data BDL=I2DL Results i. 1 8/132015 < 50 25 Std Dev. 28.3210 2 9/152015 85 85 Mean 32.5310 3 10212015 150 150 C.V. 0.8706 4 11/172015 < 50 25 n 29 5 12/8/2015 < 50 25 6 1/13/2016 < 50 25 Mult Factor = 1.30 7 2/162016 < 50 25 Max. Value 150.0 ug/L 8 3/172016 < 50 25 Max. Fred Cw 195.0 ug/L 9 4/142016 < 50 25 10 5/6/2016 < 50 25 11 6/142016 67 67 12 7/142016 58 58 13 8/172016 < 50 25 14 9/132016 < 50 25 15 10/19/2016 < 50 25 16 1122016 < 50 25 17 12/62016 < 60 25 18 1/112017 18 18 19 2/2/2017 13.6 13.6 20 3/72017 17.4 17.4 21 4/112017 21.8 21.8 22 5/102017 21.2 21.2 23 6/82017 11.8 11.8 24 7/122017 22.1 22.1 25 8/172017 60.1 60.1 26 9/19/2017 13.5 13.5 27 10M12017 21.8 21.8 28 11/82017 26.4 26.4 29 1215NO17 10.7 10.7 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 68 & Par18 Use •'PASTE SPECIAL Nickel Values"Nen"COPY" . Maalmam data Paints = 58 Date Data BDL=I2DL Results r. 5/202014 < 5 2.5 Sul Dev. 0.7143 6/192014 < 5 2.5 Mean 2.3773 7/152014 < 5 2.5 C.V. 0.3005 8/202014 < 5 2.5 n 44 9/9/2014 < 5 2.5 10/14/2014 < 5 2.5 Mult Factor = 1.04 11/42014 < 5 2.5 Max. Value 5.8 pg/L 12/42014 < 5 2.5 Max. Fred Cw 6.0 pg/L 1/142015 < 5 2.5 M2015 < 5 2.5 3/10/2015 < 5 2.5 4172015 < 5 2.5 5/132015 < 5 2.5 6/2/2015 < 5 2.5 7172015 < 5 2.5 8/132015 < 5 2.5 9/152015 < 5 2.5 10/21/2015 < 5 2.5 11/17/2015 < 5 2.5 12/8/2015 < 5 2.5 1/132016 < 5 2.5 2/162016 < 5 2.5 3/172016 < 5 2.5 4/142016 < 5 2.5 5/6/2016 < 5 2.5 6/142016 < 5 2.5 7/142016 < 5 2.5 8/172016 < 5 2.5 9/13/2016 < 5 2.5 10/19/2016 < 5 2.5 11/2/2016 < 5 2.5 12/6/2016 < 5 2.5 1/11/2017 < 2 1 2/2/2017 2 2 3R12017 < 5 2.5 4/112017 < 2 1 5/102017 2.4 2.4 6182017 < 5 2.5 7/122017 5.8 5.8 8/17/2017 2.3 2.3 9/19/2017 < 2 1 10/11/2017 < 2 1 11/8/2017 < 2 1 12/5/2017 2.1 2.1 NC0026123 RPA_2018a, data - 9 - 10/1/2018 REASONABLE POTENTIAL ANALYSIS 'ar19 Par20 U."PASTE SPECIAL Use "PFSTE BPECIFL Selenium Values"then "COPY" $IIVef Veluas'"than"COPY' . Maximum dam . Maximum data points = 58 Points - 58 Data Data BDL=1/2DL Results _ Date Data BDL=1/2DL Results 1 5/20/2014 < 10 5 Std Dev. 0.0000 1 5/202014 < 5 2.5 Std Dev. 0.0000 2 6/192014 < 10 5 Mean 5.0000 2 6/192014 < 5 2.6 Mean 2.5000 3 7/15/2014 < 10 5 C.V. 0.0000 3 7/152014 < 5 2.5 C.V. 0.0000 4 8/20/2014 < 10 5 n 44 4 8/202014 < 5 2.6 n 44 5 9192014 < 10 5 5 9/9/2014 < 5 2.5 6 10/142014 < 10 5 Mult Factor= 1.00 6 10/142014 < 5 2.5 Mult Factor = 1.00 7 11/42014 < 10 5 Max. Value 5.0 tQ& 7 11/42014 < 5 2.5 Max. Value 2.500 ugA- 8 12/42014 < 10 5 Max. Pred Cw 5.0 ug/L 8 12/42014 < 5 2.5 Max. Fred Cw 2.500 ug/L 9 1/142015 < 10 5 9 1/142015 < 5 2.5 10 2/3/2015 < 10 5 10 2/3/2015 < 5 2.5 11 3/102015 < 10 5 11 3/102015 < 5 2.5 12 4/72015 < 10 5 12 4172015 < 5 2.5 13 5/132015 < 10 5 13 5/132015 < 5 2.5 14 6212015 < 10 5 14 6/22015 < 5 2.5 15 7172015 < 10 5 15 7172015 < 5 2.5 16 8/13/2015 < 10 5 16 8/132015 < 5 2.5 17 9/152015 < 10 5 17 9/152015 < 5 2.5 18 10M2015 < 10 5 18 1021/2015 < 5 2.5 19 11/172015 < 10 5 19 11/17/2015 < 5 2.5 20 12/82015 < 10 5 20 12MO15 < 5 2.5 21 1/132016 < 10 5 21 11132016 < 5 2.5 22 2/162016 < 10 5 22 2116/2016 < 5 2.5 23 3/172016 < 10 5 23 3/172016 < 5 2.5 24 4/142016 < 10 5 24 4/142016 < 5 2.5 25 5/6/2016 < 10 5 25 5/62016 < 5 2.5 26 6/142016 < 10 5 26 6/14/2016 < 5 2.5 27 7114/2016 < 10 5 27 7114/2016 < 5 2.5 28 8/172016 < 10 5 28 8/172016 < 5 2.5 29 9/13/2016 < 10 5 29 9/132016 < 5 2.5 30 10/192016 < 10 5 30 10/19/2016 < 5 2.5 31 1122016 < 10 5 31 11/22016 < 5 2.6 32 12/62016 < 10 5 32 12/62016 < 5 2.5 33 1111/2017 < 10 5 33 1/112017 < 5 2.5 34 2/22017 < 10 5 34 202017 < 5 2.5 35 3/72017 < 10 5 35 3/72017 < 5 2.5 36 4/112017 < 10 5 36 4/112017 < 5 2.5 37 5/102017 < 10 5 37 5/102017 < 5 2.5 38 6/8/2017 < 10 5 38 6/8/2017 < 5 2.5 39 7/122017 < 10 5 39 7/122017 < 5 2.5 40 8/172017 < 10 5 40 8/172017 < 5 2.5 41 9/192017 < 10 5 41 9/192017 < 5 2.5 42 10/11/2017 < 10 5 42 10/112017 < 5 2.5 43 11/8/2017 < 10 5 43 11/82017 < 5 2.5 44 12/5/2017 < 10 5 44 12/52017 < 5 2.5 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 NC0026123 RPA 201 Be, data to- 10/12018 REASONABLE POTENTIAL ANALYSIS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Zinc Valu Men "COPY .M2,nn data Poln%= 59 Date Date BDL=I2DL Results 5/202014 23 23 Std Dev. 11.0282 6/192014 22 22 Mean 23.0822 7/152014 52 52 C.V. 0.4778 8/202014 21 21 n 45 9/9/2014 30 30 10/142014 20 20 Mult Factor = 1.06 11/42014 30 30 Max. Value 55.0 ug/L 12/42014 41 41 Max. Pred Cw 58.3 ug/L 1/142015 17 17 2/3/2015 17 17 3/102015 23 23 4/7/2015 30 30 5/132015 22 22 6/2/2015 23 23 6/4/2015 28 28 79=15 < 20 10 8/132015 32 32 9/15/2015 < 20 10 1021/2016 27 27 11/17/2015 20 20 12/82015 < 20 10 1/132016 23 23 2/16/2016 25 25 3/172016 24 24 4I142016 38 38 5/6/2016 < 20 10 6/14/2016 38 38 7/142016 < 20 10 8/172016 < 20 10 9/132016 < 20 10 10/192016 < 20 10 112/2016 < 20 10 12/62016 32 32 1/112017 41 41 2/2/2017 55 55 3/7/2017 32.4 32.4 4/112017 20.2 20.2 5/102017 22 22 6/8/2017 16 16 7/122017 23.3 23.3 8/172017 18.5 18.5 9/192017 13.4 13.4 10/112017 15.3 15.3 11/82017 20.1 20.1 12/52017 13.5 13.5 Dibromochloromethane I Values' Men 'COP . Mmlmum data points • 58 Date Data BDL-12DL 6/192014 < 5 2.5 9/162014 17.3 17.3 12/42014 6.7 6.7 3/52015 < 5 2.5 6/4/2015 20.4 20.4 9/172015 10.5 10.5 12/102015 < 5 2.5 3/172016 < 5 2.5 3/172016 < 5 2.5 6/16/2016 < 5 2.5 9/152016 11 11 121WO16 < 5 2.5 3/9/2017 < 5 2.5 61IM017 < 5 2.5 9/192017 6.7 6.7 12/52017 15.1 15.1 Results_, Std Dev. 6.1196 Mean 6.8875 C.V. 0.8885 n 16 Mult Factor = 1.70 Max. Value 20.4000D0 pg/L Max. Pred Cw 34.680000 Vg/L NCO026123 RPA_2018a, data - 11 - 10/12018 Date 1 6/19/2014 2 9/16/2014 3 12/4/2014 4 3/5/2015 5 6/4/2015 6 6/4/2015 7 9/17/2015 8 12/10/2015 9 3/17/2016 10 3/17/2016 11 6/16/2016 12 9/152016 13 12/82016 14 3/9/2017 15 6/15/2017 16 9/19/2017 17 12/52017 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Data REASONABLE POTENTIAL ANALYSIS 6sa'YA57E 8PECULL Par24 Uaa "PASTE sPECI Bromodichloromethane valPas••uan "copr• Chloroform Values"Nen"COF . Maximum data . Maximum data points - 5a Points = 511 BDL=I2DL 5 2.5 5 2.5 5 2.5 5 2.5 5 2.5 20.4 20.4 5 2.5 7.3 7.3 7.9 7.9 13.4 13.4 5 2.5 36.2 36.2 8.5 8.5 10.4 10.4 34.9 34.9 22.1 22.1 20 20 Results Ill - SW Dev. 11.2703 Mean 11.6824 C.V. 0.9647 n 17 Mult Factor = 1.70 Mm. Value 36.200D00 pg/L Max. Pred Cw 61.540000 pg/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 Date Data BDL=I2DL Results mb 6/1912014 < 5 2.5 Std Dev. 15.8342 6/4/2015 33.7 33.7 Mean 16.5333 3/17/2016 13.4 13.4 C.V.(default) 0.6000 n 3 Mult Factor = 3.00 Mm. Value 33.700000 pg/L Max. Pred Cw 101.100000 pg/L _ 12. NCO026123 RPA_2018a, data 10/1/2018 REASONABLE POTENTIAL ANALYSIS 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 1,4-Dioxane Values"then "COPY . maximum data Points = 56 Date Data BDL=I2DL Results _ 12/7/2017 89 89 Ste Dev. 380.4190 1/11/2018 937 937 Mean 379.3400 2/1/2018 1011 1011 C.V. 1.0028 3/12018 212 212 n 10 4/5/2018 397 397 SM12018 75.7 75.7 Mult Factor = 2.30 6/13/2018 77.7 77.7 Max. Value pg/L 7/17/2018 48 48 Max. Fred Cw #9######## pg/L 8/22/2018 764 764 9/112018 182 182 -13- NCO026123 RPA_2018a, data 10/12018 Asheboro WWfP NCO026123 Freshwater RPA- 95a/o Probability/95% Confidence Using Metal Translators MAXIMUM DATA POINTS = 58 Qw (MGD) = 9.0000 W WTP/WTP Class: GRADE IV 1QIOS (cfs)= 0.00 IWC% @ IQIOS = 100 7Q10S(cfs)= 0.00 IWC%@71= 100 7QIow(nis)= 0.00 IWC%@7QIOW= 100 30Q2(cfs)= 0.20 IWC%@31= 98.58657244 Avg. Stream Flow, QA (cfs) = 12.00 IW%C @ QA = 53.75722543 Receiving Stream: Hasketts Creek HUC 0303000301 Stream Class: C Outfall 001 Qw=9 MGD COMBINED HARDNESS (mg(L) Acute = 114.26 mg(L Chronic = 114.26 mg/L PARAMETER NC STANDARDS OR EPA CRITERIA y REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE J a n Chronic Acute n # Det. Max Prod Cw Allowable Cw SAfapndm�+d Acute (FW): 340.0 Arsenic C 150 FW 340 ug/L 44 1 2.6 Chronic (FW) ]50.0 No value >_Allow_abl_e_Cw____ Arsenic C 10 HH/WS ug/L ChIonic(HH) 186 _ _ _ _ _ _ _ _ _ _ _ No RP, Predicted Max <50% of Allowable Cw - No No value> Allowable Cw Monitoring required Acute: 65.00 Beryllium NC 6.5 FW 65 us1. 3 0 1.50 Note: It <9 C.V. (default) Chronic: 6.50 No detections at < 1.0 uglL; no monitoring required Limited data set I NO DETEC7S Max MDL= 1 Acute: 12.189 Cadmium NC I.XSSl FW 12.1886 ug/L 44 3 0.624 ____ _ Chronic: 1.858 _ _ No RP, Predicted Max<50%a(Ali. wable Cw - No No value> Allowable Cw Monitoring required Acute: NO WQS Chlorides NC 130 FW mg/L 25 25 351.0 ____ _____________________ Chronic: 230.0 RP shown -apply OuaMRy Monitoring; EPA allows 4 values > Allowable Cw action level Acute: NO WQS Chlorinated Phenolic Compounds NC I A ug/L 0 0 N/A Acute: NO WQS Total Phenolic Compounds NC 300 A ug1L 3 0 7.5 Note: n < 9 C.V.(default) Chronic: — —304.3 -- —__ —__�——__;—__-------- No detections at<5.0 ug/L; no monitoring required Limiteddataset NODETEC7S Max MDL=S Acute: 3,141.9 Chromium 111 NC 408.6988 FW 3141.9169 ue'L 0 ll N/A Acute: 16.0 Chrmmmn Vl NC II FW 16 µg/L 0 0 N/A___ —_Chronic: 0 RP shown via Total Cr. Apply quarterly monitoring. I of ('r valuelsl>_ 5 with 2 Tot Cr value(s)>_ Cr VI Allowable Chromium, Total NC µg/L 44 19 28.6 Max reported value =26 Maintain Total Cr monitoring if all Total Cr samples are < 50 pg/L but > the Allowable Cw for Cr A i, NC0026123 RPA-2018a, rpa Page 7 of 3 10/1/21/2018 I �' Asheboro WWTP z Outfall 001 NCO026123 Freshwater RPA- 95% Probability/95% Confidence Using Metal Translators Qw = 9 MGD Acute: 43.84 Copper NC 28.8733 FW 43.9372 ug/L 43 43 16.05 _ _ ___ Chronic: 28.87 _ _ _ _ _ _ No RP, Predicted Maz z50%ofAllowableCw- No value> Allowable Cw apply Quarterly Monitoring Acute: 22.0 RP shown- apply Monthly Monitoring with Limit Cyanide NC 5 FW __ 10 ug/L 27 3 22.1 --------------------------------------------- Chronic: 5.0 RP shown- apply Monthly Monitoring with Limit 3 values > Allowable Cw Acute: NO WQS Fluoride INC 1800 FR, ur I_ 11 11 N/A —.Chronic: _—_-1,800.0__ Acute: 405.910 Lead INC 15.8177 12N 405 0101 ug/L 44 a 2.600 Chronic: 15.818 _ _ _ _ _ _ No _ detections_ at <5;ii fmm 2074-2076 aM at < 2 NODETECTS Max MDL=5 ug/L from 2017-2018; no monitoring required Acute: NO WQS Meroury NC 12 FW 0.5 ng/L 0 a N/A —.Chronic: 2_6 Acute: NO WQS Molybdenum NC _'000 11H ug/L 29 16 195.0 Chronic: 2,000.0 _ _ _ NO RP, Predicted Max_<50T iA_ owable Cw-No No value> Allowable Cw Monitoring required Acute (FW): 1.212.4 Nickel NC 134.6587 FW 1212.3864 pg/L _ _ _( _c _ax 44 5 6.0 FW)_ ree_M<_5%_of Allowable Cw-No No value> Allowabl_e_I Monitoring required Nickel NC 25.0000 WS pg/L _ Chronic(WS) 25.0 No value > Allowable Cw Acute: 56.0 Selenium NC 5 FW 56 ug/L 44 11 5.0 Chronic: 5.0 No detections at < 10 ug/L; no monitoring required. NO DETECTS Max MDL= 10 Acute: 4.046 Sliver NC 11.11( PVA 4.04�5 ug/L 44 II 2.$60 No detections at < 5.0 ug/L; PQL is < 1.0 ug/L. ___ Chronic: 0.060 _ _ _ _ nd_ Useoclean-_am; ;techniques9teslto lower NO DETECTS Maz MDL=5 detection level. Acute: 455.6 Zinc NC 459'_774 IlA' dis5510 uel. 45 36 58.3 Chr_onic: ___R,re_x<of Allowable Cw-No No value> Allowable Cw Monitoring required Acute: NO WQS Dibromochloromelhane C 21 fill uc l_ In 7 34.68000 ___ ____ Chronic: 39.06452 _ _ _ _ _ _ No RP ,Predicted Max z 50 % M Allowable Cw No value >Allowable Cw apply 6wrtedy Monitoring Acute: NO WQS Bromodichloromethane C 17 1111 p!YI_ 17 la 61.54000 _ _ _ _ _ _ _ _ _ _ _ Chronic: 31.62366 _ _ _ _ RP shown -apply Monthly Monitoring with Limit 2 values > Allowable Cw NCO026123 RPA_2018a, rpa Page 2 of 3 10/1/2018 Asheboro WWTP a Outfall 001 NCO026123 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 9 MGD Acute: NO WQS Chloroform NB 2000 Hil µg/L 3 2 101.10000 Note: a<9 C.V.(default) ___ _ ____ _ _ _ Chronic: 2000.00000 _ _ _ _ _ _ NO RP, Predicted Maz<50%ofAllowabla Cw-No Limited data set No value> Allowable Cw Monitoring required Acute: NO WQS 1,4-Dioxane C su HH ag/L 10 10 2,325.30000 Cbmnic: 148.81720 6 value(s)> Allowable Cw RP shown - apply Monthly Monitoring with Limit Pee 3 of 3 NCO026123 RPA_2018a, ma 0 10/1/2018 NPDES PERMIT: NCO026123 Dissolved to Total Metal Calculator In accordance with Federal Reg ulatlons, permit limitations must be written as Total Metals per 40 CFR 122.45(e) Racdung ReceMng Rec. Slraam NPDES Total Suspended Candnetl Canbinetl Instream InstreamM Effluent Slream Slreem Sditle Hardness Hemness wastewater wastewateresssummer summer7D10�Fized 1�10 Flow Limit Value- chmnic Acute ConceneaGon Concomemonge7D10(CFS) faGD) [MGDI [MGD] (mglL) (mg/L) (mgrL) (Chronic) (Pate) )0.0000 0.0000 0.0000 sODD0 10 114.261 114.261 100.OD00 10D.0000 61 Upstream Hard Avg (mglL) = 51.9333 EFF Hard Avg (mglL)= 114.261 eflar epplytnghaedness Translators using Total Mount Criteria Thal Metal= sns*WMed+Tr.a PARAMETER oly gon Default Partition Chronic Acute Coefficients I Chronic I Acute Lead 1.91 131 41 =dissolved metal standard See 15A NCAC 02B.0211 formoneInformation. =hardness-dependentdissolved metal standard. See 15A NCAC 02B.0211 for more Information. =based upon measurement of want recoveable metal. See i5A NCAC 02B .0211 for moreInformation. The Human Health standard for Nickel In Water Supply Streams is 25 mg/L which Is Total Recovemble mean] standard. The Human Health standard for Arsenic is 10 µg/L which Is Total Recoverable metal standard. P�� q C i D F k 5 i (l. E A n V S S I A F`CA.\_ sr 9 S Page 17 (IDWO- PnE-ndl6-(a-"Lok6) However, if 2 or more reported values are greater than the Total allowable concentration, add permit limits for the hardness -dependent metal and monthly monitoring. For cadmium and silver read the guidance in Sections VII and VIII before adding a limitation. In addition, add effluent hardness and upstream hardness sampling at a frequency of quarterly along with a footnote to sample in conjunction with effluent metals sampling. The new hardness -dependent metal limits should be effective immediately, unless a compliance schedule is deemed appropriate (see paragraph G below). F. No RP (Predicted Max >_ 50% of Allowable) If the hardness dependent metal is not showing reasonable potential but the predicted max is > 50% of the allowable concentration - add quarterly monitoring for the metal of concern. In addition, add effluent hardness and instream hardness sampling, upstream of the discharge, at a quarterly frequency with a footnote to sample in conjunction with effluent metals sampling. In accordance with RPA procedures, metal sampling can be deferred to the Pretreatment LTMP/STMP but hardness sampling must be included in the permit even if the metal sampling requirement is deferred to the Pretreatment Program. G. No RP (Predicted Max < 50% of Allowable) If the hardness dependent metal is not showing reasonable potential and the predicted max is < 50% of the allowable concentration — no monitoring or effluent limitations are required. However, as discussed in Section IV, all Pretreatment POTWs sampling for hardness -dependent metals (as part of their Pretreatment LTMP or STMP) shall get quarterly monitoring requirements for effluent hardness and instream hardness, upstream of the discharge, unless the Permittee has a zero low flow 7Q 10, then upstream hardness sampling is not necessary. H. Compliance Schedules: Sometimes a permittee cannot immediately comply with new or newly applied Water Quality - Based Effluent Limits (WQBELs) upon the effective date of the permit because the permittee needs time to consider its situation and evaluate its options, such as implementing source controls or making substantial modifications to its facility or processes in order to meet the new limits. Depending upon the circumstances, NPDES permits may include a series of required steps and deadlines (i.e., a compliance schedule), which upon completion, enables the permittee to meet the permit's water quality -based effluent limits (see 40 CFR § 122.47). If this is the case, be sure to add a footnote by the new WQBEL giving an effective date of YY years after the permit becomes effective (XXXX) and reference the addition of Section A.(X.). Compliance Schedule for Hardness Dependent Metals. Each permit writer will be responsible for developing a compliance schedule specific to each Permittee's circumstances keeping in mind that a particular compliance schedule requires compliance with the WQBEL "as soon as possible." See Section X for more details on Compliance Schedules. VI. Chromium To protect aquatic life, the 2007-2014 Triennial Review rules included numeric criteria for chromium VI in freshwater and saltwater and a hardness -dependent standard for chromium III in freshwater. The standard for Total Chromium was removed. Parameter Acute FW, ug/l (Dissolved) Chronic FW, ug/l (Dissolved) Acute SW, ug/l (Dissolved) Chronic SW, ug/l (Dissolved) Chromium III Calculation Calculation I --- I --- Chromium VI 16 11 11100 150 Page 18 A. Key Issues: Laboratories typically report chromium as total chromium, unless analysis for chromium VI is requested. Total chromium consists primarily of trivalent (III) and hexavalent (VI) forms. Hexavalent forms which are generally produced by industrial sources are considered to be more toxic than trivalent forms which typically come from natural sources (ATSDR. Toxicological Profile for Chromium. See: http://www.atsdr.ede.goy/toxprofiles/tp.aW?id=62&tid=171 In the situation where only total chromium effluent data are available, results are compared to the most stringent applicable standard for either chromium III or chromium VI. In this particular case, chromium VI will be the most stringent standard in either freshwater or saltwater environments. This is conservative and represents toxicity based on chromium VI criteria when the water sample may be primarily comprised of chromium III. Chromium III and VI are not currently listed in Appendices D or J of 40 CFR 122 and are not required as part of the federally mandated priority pollutant scan. B. Recommended Analytical Method: The recommended analytical method for total chromium is EPA Method 200.8. The recommended analytical method for chromium VI is EPA Method SM3500-Cr B-2009. There is no recognized analytical method for chromium III; therefore, chromium III should be determined from the calculated difference of chromium VI from total chromium. Chromium VI is sampled in the dissolved form and has a Practical Quantitation Limit (PQL) of 50 ug/L. Total Chromium can be sampled as a total recoverable metal and has a PQL of 10 ug/L. C. Implementation Instructions: As a cost savings measure, total recoverable chromium data results may be used as a conservative surrogate in cases where there are no analytical results based on chromium III or VI. Permittees with total chromium effluent samples showing no reasonable potential to exceed either the chromium VI or the chromium III total allowable concentrations (permit limits) do not need to continue to monitor for total chromium unless it is required by federal categorical regulations or as part of their Pretreatment LTMP/STMP. The total allowable concentrations (permit limits) for chromium III and chromium VI will be listed in the RPA sheet after the appropriate input data is entered. Since chromium III and VI now have state water quality standards, in the event the projected maximum concentration for total chromium exceeds the standard for either chromium III or chromium VI, limits and monitoring should be considered using the following guidance. 1. In the event where monitoring for chromium VI is indicated (total chromium projected max is greater than the total allowable chromium VI permit limit), staff have the following options: a) Add limitations and monitoring for chromium VI. b) Require monitoring and analysis of total chromium in lieu of chromium VI. The permit writer may choose this option when there is no chromium VI TBEL requirement for this facility and: ],�Po � lAf%-c-rxc-J-J-cA7 ►or3 of �0s-I(Lea rAQ►$s, 1'l��Ati �`C9S P a g e 19 Clow a, rn C- rl o C -14 - 26 J 6) (1) All total chromium effluent samples are consistently below the detection level for chromium VI (50 ug/L). (2) The Permittee has documented that chromium VI is not present* in the wastewaters discharged. If total chromium is being reported at concentrations >_ 50 ug/L the permittee should supply dissolved chromium VI sample results to support this claim. * Generally, a pollutant is "known" to be present in the effluent due to factors such as source water contamination, industrial sources within the collection area, listing status of the receiving water body, or inclusion in a pretreatment program. 2. In the event where monitoring for chromium III is indicated (total chromium projected max is greater than the total allowable chromium III), staff have the following option: a) Add limitations for Cr III and Cr VI and under Sample Type put "Calculate" for chromium III. This will require the determination of the concentrations for total chromium and chromium VI. The difference between these two values will be assumed as the concentration of chromium III and will then be used for determining reasonable potential and compliance with WQBELs already introduced. A footnote stating Cr III = Total Cr — Cr VI should be added to the Cr III limitation. VII. Cadmium A. Given the new WQS for cadmium, it is likely that the RPA may determine a cadmium chronic permit limit less than 1.0 µg/L for Permittees without much dilution. It is important that these Permittees show that they are reporting cadmium down to the PQL (recognized as 0.5 µg/L in March 2013 by DWR). Since not all Permittees are monitoring cadmium down to the lower PQL, look at the Permittee's "cadmium effluent data" and consider the following guidance: 1. For Permittees reporting cadmium effluent values at levels < 0.05 µg/L for the past year and < 1 µg/L for previous years, the permit writer can consider this representative of all non - detects. No limits or monitoring for cadmium required. 2. For Permittees reporting cadmium effluent values at levels < 1 µg/L or < 2 µg/L for the past several years, add or maintain quarterly monitoring but do not require an effluent limit, and require that the Permittee have the lab test to the lower reporting level. 3. For Permittees reporting one or two cadmium effluent values as 1 µg/L instead of < 1 (and possibly 2 µg/L instead of < 2 before 2013), add or maintain quarterly monitoring, and require that the Permittee have the lab test to the lower reporting level. State in the cover letter and fact sheet that the Permittee should review and implement clean sampling techniques and spilt cadmium samples with another lab. If hits continue, the Permittee should look at SIU's or perform a collection system survey to look for possible sources. State that a limit will be put in the permit during the next permit renewal if effluent levels show reasonable potential or exceed the Total allowable concentration of xx. VIII. Silver EPA disapproved the Action Level policy for permitting silver. It is important that the Permittee show that they are reporting silver down to the PQL (recognized as 1 µg/L in March 2013 by DWR) unless the current reporting detection level demonstrates that the facility's discharge is less than the total allowable concentration (permit limit). Note that the PQL for silver was 5 µg/L prior to 2013. A. Given the aquatic life silver chronic standard of 0.06 µg/L, the best most Permittees can do is demonstrate that the facility's discharge is less than the PQL. In general, a Permittee requiring a limitation for silver will clearly show reasonable potential (i.e., effluent samples > 5 µg/L). Look at the Permittee's "silver effluent data" and consider the following guidance: 1. For Permittees reporting silver effluent values at levels < 1 µg/L for the past year and Page 110 < 5 µg/L for previous years, the permit writer can consider this representative of all non - detects. No limits or monitoring for silver required. 2. For Permittees reporting silver effluent values at levels < 5 µg/L for the past several years, do not require an effluent limit but add or maintain quarterly monitoring and require that the Permittee have the lab test to the lower PQL level. 3. For Permittees reporting one or two low silver effluent values as a positive detection (e.g., 1 instead of < 1 ug/L), add or maintain quarterly monitoring and require that the Permittee have the lab test to the lower reporting level. State in the cover letter and fact sheet that the Permittee should review and implement clean sampling techniques and spilt silver samples with another lab. If hits continue the Permittee should look at SIU's or perform a collection system survey to look for possible sources. State that a permit limit will be put in the permit during the next permit renewal if effluent levels show reasonable potential or exceed the Total allowable concentration of xx. IX. Zinc The hardness -dependent water quality standard for zinc typically results in a more stringent permit limit for the acute total allowable metal verses the chronic. In this situation, use the acute total allowable metal concentration (permit limit) as the limitation for the Daily Maximum and the Monthly Average. X. Compliance Schedules Before writing a Compliance Schedule please review the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements. Some important things to note from the memo — Factors relevant to a conclusion that a particular compliance schedule requires compliance with the WQBEL "as soon as possible," as required by 40 CFR 122.47(a)(1) include: consideration of the steps needed to modify or install treatment facilities, operations or other measures and the time those steps would take. The permitting authority should not simply presume that a compliance schedule be based on the maximum time period allowed by a State's authorizing provision. Compliance Schedules that are longer than one year in duration must set forth interim requirements and dates for their achievement. 40 CFR 122.47 (a)(3). Any Compliance schedule contained in an NPDES permit must include an enforceable final effluent limitation and a date for its achievement that is within the timeframe allowed by the applicable State or federal law provision authorizing compliance schedules as required by CWA sections 301(b)(1)(C).... and EPA regulations at 40 CFR 122.2, 122.44(d) and 122.44(d)(1)(vii)(A). Therefore, permits must contain annual milestones and a final date to comply with the WQBEL. If it is clear the Permittee will need to seek source reduction from SIU's or install equipment at the WWTP to meet limits the permit writer should work with the Permittee to develop an appropriate schedule that considers the relevant factors. Milestones can be such things as — Identify sources of the pollutant, perform a collection system sewer survey, evaluate source reduction alternatives, submit a Corrective Action Plan (i.e. Improving treatment at the WWTP or moving the discharge to a larger stream), perform a dilution study, or issue revised permits to SIU's to enforce limits and achieve compliance with the limitation(s), etc... Some Permittee's may opt to perform a Water Effects�Ratio (WER) study. This should not be part of the compliance schedule. If they choose to do a WER, the Permittee should first submit the WER study plan to DWR for approval. Once the Permittee receives approval from DWR on the WER study, the Permittee can proceed. The WER study itself, may take about 18 months. The Permittee is responsible for submitting the results to DWR and requesting a permit modification based on the findings. Note, a WER study has to be re-evaluated and reconfirmed every five years. Permit No. NCO026123 NPDES Imulementation 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 Oualitv Standards/Aauatic Life Protection Parameter Acute FW, µg/1 (Dissolved) Chronic FW, µg/1 (Dissolved) Acute SW, µg/l (Dissolved) Chronic SW, µg/l (Dissolved) Arsenic 340 150 69 36 Beryllium 65 6.5 --- --- Cadmium Calculation Calculation 40 8.8 Chromium III Calculation Calculation --- --- Chromium VI 16 11 1100 50 Copper Calculation Calculation 4.8 3.1 Lead Calculation Calculation 210 8.1 Nickel Calculation Calculation 74 8.2 Silver Calculation 0.06 1.9 0.1 Zinc Calculation Calculation 90 81 Table 1 Notes: 1. FW= Freshwater, SW= Saltwater 2. Calculation = Hardness dependent standard 3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative concerns (as are all human health standards for all metals). It is still necessary to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at 10 µg/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-[In hardness](0.041838)) • e^(0.9151 [In hardness]-3.1485) Cadmium, Acute Trout waters WER* (1.136672-[In hardness](0.041838)) • e^(0.9151 [In hardness]-3.6236) Cadmium, Chronic WER* (1.101672-[In hardness](0.041838)) • e^(0.7998[In hardness]-4.4451) Chromium III, Acute WER*0.316 . e^(0.8190[ln hardness]+3.7256) Chromium III, Chronic WER*0.860 • e^ (0.8190[ln hardness]+0.6848 ) Copper, Acute WER*0.960 • e^(0.9422[ln hardness]-1.700) Copper, Chronic WER*0.960 • e^(0.8545[In hardness]-1.702) Lead, Acute WER*(1.46203-[In hardness](0.145712)) • eAl1.273[ln hardness]-1.460) Lead, Chronic WER* ( 1.46203-[In hardness](0.145712)) • eAl1.273[In hardness]-4.705) Nickel, Acute WER*0.998 - e^(0.8460[In hardness]+2.255) Nickel, Chronic WER*0.997 • e^(0.8460[In hardness]+0.0584) Page 1 of 4 Permit No. NCO026123 Silver, Acute WER*0.85 - e^(1.72[ln hardness]-6.59) Silver, Chronic Not applicable Zinc, Acute WER*0.978 - e^(0.8473[ln hardness]+0.884) Zinc, Chronic WER*0.986 - e^(0.8473[ln hardness]+0.884) General Information on the Reasonable Potential Analysis WA) The RPA process itself did not change as the result of the new metals standards. However, application of the dissolved and hardness -dependent standards requires additional consideration in order to establish the numeric standard for. each metal of concern of each individual discharge. The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness and so must be calculated case -by -case for each discharge. Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The discharge -specific standards must be converted to the equivalent total values for use in the RPA calculations. We will generally rely on default translator values developed for each metal (more on that below), but it is also possible to consider case -specific translators developed in accordance with established methodology. RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern, based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable standards and the critical low -flow values for the receiving stream. If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below detection level), then the Division may remove the monitoring requirement in the reissued permit. 1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the following information: • Critical low flow of the receiving stream, 7Q 10 (the spreadsheet automatically calculates the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 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. NCO026123 The overall hardness value used in the water quality calculations is calculated as follows: Combined Hardness (chronic) _ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q 10. cfs *Avg. Upstream Hardness, mgU (Permitted Flow, cfs + s7Q 10, cfs) The Combined Hardness for acute is the same but the calculation uses the IQ 10 flow. 3. The permit writer converts the numeric standard for each metal of concern to a total recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any have been developed using federally approved methodology. EPA default partition coefficients or the "Fraction'Dissolved converts the value for dissolved metal at laboratory conditions to total recoverable metal at in -stream ambient conditions. This factor is calculated using the linear partition coefficients found in The Metals Translator. Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the equation: _C iss = 1 Ctotal 1 + { [Kpo] [ss("')] [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 Jist 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 FPA 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 = (s7010 + 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: IQ 10 = used in the equation to protect aquatic life from acute toxicity Page 3 of 4 Permit No. NC0026123 QA = used in the equation to protect human health through the consumption of water, fish, and shellfish from carcinogens 30Q2 = used in the equation to protect aesthetic quality 6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern. Data entered must have been taken within four and one-half years prior to the date of the permit application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper concentration of each pollutant. The Predicted Max concentrations are compared to the Total allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds the acute or chronic Total allowable concentrations, the discharge is considered to show reasonable potential to violate the water quality standard, and a permit limit (Total allowable concentration) is included in the permit in accordance with the U.S. EPA Technical Support Document for Water Quality -Based Toxics Control published in 1991. 7. When appropriate, permit writers develop facility specific compliance schedules in accordance with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements. 8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data results may be used as a conservative surrogate in cases where there are no analytical results based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for total chromium will be compared against water quality standards for chromium III and chromium VI. 9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the accuracy of the permit limits and to build a more robust hardness dataset. 10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included: Parameter Value Comments (Data Source) Average Effluent Hardness (mg/L) (Total as, CaCO3) 114.26 2016-2017 Permittee files Average Upstream Hardness (mg/L) (Total as, CaCO3) 51.93 2016-2017 Permittee files 7Q10 summer (cfs) 0 BIMS and project files 1 Q 10 (cfs) 0 RPA, calculations memo 21412010 Permitted Flow (MGD) 9.0 BIMS and project files Date: 10 • PermitWriter: C"A%( Page 4 of 4 2/20/18 WQ5= 12 Facility Name: Asheboro WWTP Total Mercury 1631E PQL = 0.5 ng/L Date Modifier Data Er 1/10/13 3.8 2/7/13 5.8 3/7/13 2.2 4/4/13 2.6 5/9/13 3.1 6/6/13 < 1 7/11/13 1.6 8/8/13 1.2 9/12/13 1.1 10/3/13 < 1 11/7/13 < 1 12/12/13 1.5 1/16/14 2.9 2/6/14 1.6 3/6/14 1.2 4/10/14 < 1 5/8/14 < 1 6/19/14 1.1 7/10/14 < 1 8/7/14 1.5 9/11/14 3.5 10/9/14 2.4 11/6/14 3 12/4/14 < 1 1/8/15 < 1 2/5/15 1 3/5/15 < 1 ng/L Value 3.8 5.8 2.2 2.6 3.1 0.5 1.6 1.2 1.1 0.5 0.5 1.5 2.9 1.6 1.2 0.5 0.5 1.1 0.5 1.5 3.5 2.4 3 0.5 0.5 1 0.5 MERCURY WQBEL/TBEL EVALUATION No Limit Required MMP Required 7Q10s= 0.000 cfs WQBEL= Permitted Flow= 9.000 V:2017-1 12.00 ng/L 47 ne/L 2.0 ng/L - Annual Average for 2013 1.6 ng/L - Annual Average for 2014 4/9/15 < 1 0.5 5/7/15 1.4 1.4 6/4/15 < 1 0.5 7/9/15 0.844 0.844 8/6/15 < 1 0.5 09/17/15 1.3 1.3 10/08/15 1.6 1.6 11/12/15 1.8 1.8 12/10/15 2.2 2.2 1.1 ng/L- Annual Average for2015 01/07/16 2.5 2.5 02/04/16 1.9 1.9 03/17/16 < 1 0.5 04/07/16 3.1 3.1 05/05/16 < 1 0.5 06/16/16 1.3 1.3 07/14/16 1.8 1.8 08/04/16 1.5 1.5 09/15/16 1.2 1.2 10/06/16 < 1 0.5 11/10/16 8.5 8.5 12/08/16 2.4 2.4 2.1 ng/L - Annual Average for 2016 01/12/17 < 1 0.5 02/02/17 1.6 1.6 03/09/17 2.7 2.7 04/06/17 2.4 2.4 05/04/17 < 1 0.5 06/08/17 1.3 1.3 07/13/17 < 1 0.5 08/03/17 1 1 09/14/17 1 1 10/12/17 1.4 1.4 11/09/17 1.7 1.7 12/07/17 1 1 1.3 ng/L - Annual Average for 2017 Asheboro WWTP Mercury Data Statistics (Method 1631 E) 2013 2014 2015 2016 2017 # of Samples 12 12 12 12 12 Annual Average, ng/L 2.0 1.6 1.1 2.1 1.3 Maximum Value, ng/L 5.80 3.50 2.20 8.50—T 2.70 TBEL, ng/L 47 WQBEL, ng/L 12.0 J\Jby'4 Carda �Jfr'P_\+ Cr;%2r 1A (DtIle (aPtMevA+ Isla,\ ( Wa--2-0kI) Central Portion of the Cape Fear River Basin 4. Rivers/Streams - Central portion of Cape Fear River Basin North Carolina has approximately 63,000 miles of rivers and streams. The central portion of the Cape Fear River basin contains approximately 6,050 miles of rivers and streams and is defined from below the B. Everett Jordan Reservoir dam along the Haw River, and below the Randleman Lake dam along the Deep River to Lock and Dam #1(Figure 3). This area has been identified as a priority for nutrient management since the early 2000s. This is one of the fastest growing regions of the state, and there will be a need to determine allocations for waste assimilation, assess the effects and management of nutrients discharged from point and non -point sources, and develop new drinking water sources in this region. The central portion of the Cape Fear River has a history of high nutrients. Algal blooms and high chlorophyll -a concentrations occur behind Buckhorn Dam and Lock and Dams 1, 2 and 3, particularly during years with low precipitation. Nutrients have been an item of discussion within each of the three monitoring coalitions in the Cape Fear basin: the Upper Cape Fear River Basin Association, the Middle Cape Fear Basin Association and the Lower Cape Fear River Program. Additionally, the Rocky River Heritage Foundation 4,', The Nature Conservancy, North Carolina State University and the University of North Carolina —Wilmington have expressed interest in nutrients. Several municipalities have water supply intakes on this portion of the river. Algal blooms have increased drinking water treatment costs for the City of Wilmington; hence, there is a high level of stakeholder interest in this region. The Nature Conservancy is trying to start a process for addressing nutrients; additionally, the Middle Cape Fear Basin Association has expressed interest in working with the DWR on nutrient issues. Researchers from the University of North Carolina — Wilmington have also been studying the algal blooms and algal toxins along portions of the middle and lower Cape Fear Rivera. These events have stimulated considerable stakeholder interest regarding the effects of nutrients and nutrient management. Impairments: Portions of the Rocky River are listed as impaired for chlorophyll -a 4 htto://www.rockyriverchatham.or? 6 htto://www.rockyriverchatham.ora/files/RRPost Mar3 2013-2.odf 6 Isaacs, J.D. et al. 2014. Microcystlns and two new micropeptln cyanopeptides produced by. unprecedented Microcystis aeruginoso blooms in North Carolina's Cape Fear River. Harmful Algae 31:82-86 htto://www sciencedirect com/science/article/pii/5156898831300139X 12 Randleman Lake Jordan Lake Rocky Deep.,iver River Cape Fear L&D 3 Central Portion of the Cape Fear River Basin L&D 2 L&D 7 Lower Cape Fear Figure 3. Cape Fear River Basin. (Areas in color represent the Central portion of the Cape Fear River Basin for which nutrient criteria are proposed. L&D = Lock and Dam) Notes: The subwatersheds in gray either have nutrient management plans (i.e., Jordan Lake and Randleman Lake) or are areas that have streams draining to the portion of the Cape Fear River downstream of Lock and Dam 1(i.e., Lower Cape Fear). Thus, the areas in gray are not in the area designated as the Central portion of the Cape Fear River Basin. The subwatersheds in color are either listed as impaired for chlorophyll-o, or are of concern for nutrient over enrichment and comprise the "Central Portion of the Cape Fear River Basin." 13 1C. Water Resources Environmental Quality February 22, 2017 To: Jay Zimmerman, Division of Water Resources Director Through: Cyndi Karoly, Water Sciences Section Chief �K From: Brian Wrenn, Ecosystems Branch Supervisor Tammy Hill, Water Quality Analyst -A V� RE: DWR results from a 2-year study on 1,4-dioxane in the Cape Fear River Basin ROY COOPER Governor MICHAEL S. REGAN Secretary S. JAY ZIMMERMAN Director Attached please find the final report for second year of the Division of Water Resources' study on 1,4- dioxane in the Cape Fear River basin. Data contained in this report were collected from October 2014 through October 2016. Please contact Tammy Hill (919-743-8412 or tammv.l.hillOncdenr.eov) with any questions. cc: Jessica Godreau Rebecca Sadosky Jeff Manning Connie Brower Jeff Poupart Julie Grzyb Chris Johnson Danny Smith Trent Allen Jim Gregson Sherri Knight —/ Nothing Compares State of North Carolina I Environmental Quality / Water Seim= Section 1621 Mail Service Center I Raleigh, North Carolina 27699-1621 919-743-9400 1,4-Dioxane Monitoring in the Cape Fear River Basin of North Carolina An Ongoing Screening, Source Identification, and Abatement Verification Study I - C.. - 'Nothing Compares Department of Environmental Quality Prepared by: The North Carolina Department of Environmental Quality Division of Water Resources Water Sciences Section For more information on the 1,4-dioxane study and electronic copies of this publication: http://deg. nc.gov/a bout/divisions/water-resources/water-reso u rces-data/wate r-sciences-home-page Suggested citation: North Carolina Division of Water Resources. 2017.1,4-dioxane monitoring in the Cape Fear River basin of North Carolina: An ongoing screening, source identification, and abatement verification study. Raleigh, North Carolina: North Carolina Department of Environmental Quality. North Carolina Department of Environmental Quality Division of Water Resources Water Sciences Section Mission Statement: The mission of the Water Sciences Section is to provide the Division with accurate information pertaining to waters of the state. Excellent service along with water quality monitoring and certification programs and analytical laboratory analyses that provide scientifically defensible data are the section's main avenues for accomplishing this mission. These activities support the management and protection of North Carolina's water resources for the health and welfare of the citizens of North Carolina and the economic well-being of the state. Abstract 1,4-dioxane is an emerging contaminant of concern that was recently monitored in drinking water throughout the United States as part of the U.S. Environmental Protection Agency's Third Unregulated Contaminant Monitoring Rule. Results indicated the presence of 1,4-dioxane in three North Carolina river basins, with the highest concentrations measured in the Cape Fear River basin in central North Carolina. In October 2016, the North Carolina Division of Water Resources completed the second year of a study designed to examine ambient concentrations, identify potential sources, and document water quality improvements due to abatement efforts of 1,4-dioxane in major surface waters of the Cape Fear River basin. Four primary areas of elevated 1,4-dioxane were identified in the upper portion of the basin. Three of these areas were located immediately downstream of domestic wastewater treatment facilities, indicating that these facilities were likely conduits for 1,4-dioxane from industrial sources into surface water. The fourth was located further downstream of a wastewater facility, as well as in proximity to potential legacy sources of the contaminant. These findings were communicated to effected municipalities, project partners, and the interested public. During the second year of the study, quarterly sampling indicated a reduction of 1,4-dioxane concentrations in many areas of the basin. Further reductions will be necessary to achieve federal and state health advisory levels for 1,4-dioxane in drinking water supplies. The Division of Water Resources study will continue in the Cape Fear River basin and expand into the Yadkin and Neuse River basins during 2017-2018. Keywords 1,4-Dioxane; Dioxane; Drinking water; Surface water; Wastewater; Cape Fear River basin; Unregulated Contaminant Monitoring Rule; UCMR3; Emerging contaminants; Water quality; Water resources Introduction 1,4-Dioxane (C41-1e02, CAS p 123-91-1) is a clear liquid that is highly miscible in water (ATSDR, 2012; Mohr, 2010). It has historically been used as a solvent stabilizer, and is currently used for a wide variety of industrial and manufacturing purposes. The compound can be found in industrial solvents, paint strippers, and varnishes and is often produced as a by-product of chemical processes to manufacture soaps, plastics, and other consumer products (Stepien, et al., 2014; U.S. EPA, 2015; Water Research Foundation, 2014). The United States Environmental Protection Agency (U.S. EPA) does not have an established maximum contaminant level for 1,4-dioxane in drinking water. However, the U.S. EPA has characterized 1,4-dioxane as "likely to be carcinogenic to humans" and has established a drinking water health advisory with an associated estimated lifetime cancer risk of one in one million at a concentration of 0.35 µg/L (U.S. EPA, 2012). North Carolina has a calculated human health criterion for 1,4-dioxane of 0.35 µg/L in water supplies and 80 µg/L in all other waterbodies (15A NCAC 02B.0208). Due to its physiochemical properties, 1,4-dioxane has a high mobility and is interminable in the environment. As a water quality contaminant, its persistence is due to an "indefinite solubility in water' (Stepien, et aL, 2014). Conventional drinking water treatment mechanisms have been found to be ineffective at removing 1,4-dioxane from source water. However, it can be removed via advanced oxidation processes applying a combination of hydrogen peroxide and other factors (Stepien, et al., 2014; Water Research Foundation, 2014). Under the 1996 Safe Drinking Water Act, the U.S. EPA requires public water systems to monitor a list of up to 30 unregulated contaminants in finished drinking water every five years. The data collected from these monitoring exercises are one of the primary sources of occurrence and exposure data that the U.S. EPA uses to determine regulations on these contaminants (UCMR3, 2012). The Third Unregulated Contaminant Monitoring Rule (UCMR3) included 1,4-dioxane in the list of over 20 chemicals to be sampled and evaluated, using specific analytical methods, during January 2013 — December 2015 at all water utility systems serving more than 10,000 people. These chemicals, as well as two viruses, were also collected at a representative sample of smaller public water systems (U.S. EPA, 2016). The surface waters of the Cape Fear River basin supply drinking water to many counties in North Carolina (NC). According to UCMR3 data, this basin also exhibits some of the highest measured concentrations of 1,4-dioxane in finished drinking water in NC and the U.S. Therefore, itwas the initial focus of a 1,4-dioxane monitoring study by the North Carolina Division of Water Resources NC DWR) with three successive objectives: 1. Screen for ambient 1,4-dioxane concentrations in surface waters of the basin during all seasons to identify areas with consistently elevated results, 2. Identify sources and provide information to appropriate NC DWR staff, municipalities and other interested parties, 3. Document changes in concentration in response to municipal and industrial actions to reduce 1,4- dioxane discharges. At the time of this report, the first objective has been completed, while the latter two have become part of an ongoing, iterative process that will continue into the third year of monitoring in 2017 as 1,4-dioxane abatement efforts progress. Methods Timeframe and Study Area From October 2014 — October 2016, the study progressed through three phases, aligned with the study objectives. The initial screening study included monthly sampling during Year 1 (October 2014 — September 2015) at twelve stations throughout the Cape Fear River basin to capture seasonal and spatial variability in constituent concentrations. By May 2015, sufficient data were available to recognize distinct areas where 1,4-dioxane concentrations were elevated, and seven monitoring stations were added to the monthly monitoring schedule from June — September 2015 to assist with source identification. In September 2015, the first full year of sampling was completed. Monitoring locations were adjusted and sampling frequency was reduced to quarterly for Year 2 of the study (13 months from October 2015 — October 2016; station information and location details in Appendix A) to continue to document the spatial distribution of 1,4-dioxane, as well as surface water quality changes resulting from 1,4-dioxane source remediation and abatement efforts in the basin. Field Sampling and Procedure Sampling was conducted according to methods described in North Carolina's Ambient Monitoring System (AMS) Quality Assurance Project Plan (QAPP) (NCDENR, 2014, Section B.2 and Appendices 7 and 8) and instructions provided by the contract laboratory for 1,4-dioxane sample collection and preservation. All samples were collected as near -surface (i.e. 0.1-meter depth) grab samples. One sample was collected monthly or quarterly, depending on the study phase, for the analysis of 1,4- dioxane at each site. Quality assurance (QA) samples, including duplicates, matrix spikes, and matrix spike duplicates were collected quarterly at each of the stations on a rotating basis (two to four stations per quarter), In accordance with the AMS QAPP (NCDENR, 2014). During each sampling event, a multi -parameter meter (e.g. YSI Pro Plus with Quatro cable or similar) was used in situ to measure instantaneous water temperature, pH, specific conductance, and dissolved oxygen values. Laboratory Procedure and Quality Control Due to the absence of a U.S. EPA -approved analytical method for 1,4-dioxane in surface water or wastewater, solid waste analysis methods, rather than finished drinking water methods, were chosen to account for matrix interferences that may exist in stream samples. During the first year of the study, method SW-846 8270 SIM (selected ion monitoring) with a practical quantitation limit (PQL) of 3 µg/L was used to evaluate 1,4-dioxane. In December 2015, the analytical method was changed to SW-846 82608 to support smaller sample volumes and a lower PQL of 2 µ JL. QA samples were analyzed with both methods to confirm that the change did not substantially alter results. As mentioned above, QA samples included duplicates, matrix spikes, and matrix spike duplicates. Duplicates were analyzed to evaluate reproducibility of results. Matrix spikes were analyzed to evaluate surface waters receiving different types of inputs, including domestic wastewater effluent, dam release, urban stormwater, and swamp waters, in which the potential for various types of interferences existed. Matrix spike duplicates were analyzed to evaluate reproducibility of spiked samples. Data Analysis Data analysis was performed on NC DWR sample results to determine ambient concentrations of 1,4- dioxane in surface waters throughout the Cape Fear River basin, to compare results with calculated evaluation levels, and to identify areas that may be contributing to the exceedance of evaluation levels throughout the basin. Concentration results were reviewed monthly, then summarized on an annual basis to determine the mean, median, maximum, and minimum concentrations. Monthly and summary results were plotted on an ArcGIS Online map (htto://arcg.is/ldJa1Ng) to identify potential areas of concern. The map was used to examine areas of high concentrations as well as possible sources of 1,4-dioxane, including: • Domestic and industrial point -source discharges, • Active and inactive hazardous waste facilities, • Active, inactive, and pre -regulatory landfills, • Known 1,4-dioxane contaminated groundwater plumes, • Wastewater outfalls from groundwater remediation sites, ■ Permitted non -discharge facilities, and • Airports. Additionally, where available, stream flow data from United States Geological Society (USGS) gages at or near sampling stations were downloaded as an explanatory variable. Surface discharge appears to be inversely related to 1,4-dioxane concentration in some cases. Results During the first year of the study, four areas of high 1,4-dioxane concentration were identified. Three of the four areas were located immediately downstream of domestic wastewater treatment facilities (WWTF), and one was further downstream of a WWTF, as well as downstream of an inactive textile manufacturing site and other possible legacy sources. In Year 1, these areas had maximum concentrations ranging from 171 to 1030 µg/L and mean concentrations from 43 to 351 µg/L. During Year 2, the same areas returned maximum values of 20 to 614 µg/L and means of 11 to 260 µg/L. Results in excess of the calculated criteria have been documented throughout the Haw, Deep, and Cape Fear Rivers, with the highest 1,4-dioxane values during both study years from the upper watersheds of the Haw and Deep Rivers. Decreases in mean 1,4-dioxane concentration from Year 1 to Year 2 of the study were observed at all monitoring stations. During the second year of the study, the four Cape Fear River stations below Jordan Lake routinely returned results at or below the laboratory PQL of 2 µg/L. Year 1 results for these stations averaged 4 to 6 µg/L. Summarized results for the twelve stations monitored during both study years are provided in Appendix B. Results for stations monitored only during Year 1 can be found in the initial study report (NC DWR, 2016). Discussion As an emerging contaminant of concern, municipal water and wastewater treatment facilities are generally not equipped to remove 1,4-dioxane through their treatment processes. Due to the high aqueous solubility and resistance of 1,4-dioxane to biodegradation, conventional treatment processes are generally ineffective at removal (Zenker, et ak, 2003). Installation and operation of advanced treatment processes, such as those using hydrogen peroxide, ozone, and/or ultraviolet photo -oxidation, shown to be effective for 1,4-dioxane removal at WWTFs or drinking water systems are anticipated to be prohibitively expensive for local governments and the citizens served by public utilities (Ibid). Therefore, the most prudent approaches to reducing 1,4-dioxane concentrations in surface water and drinking water are likely to be reduction, elimination, and/or capture and treatment at industrial sources using or generating the compound. It has been found that certain industrial processes are more likely to utilize 1,4-dioxane or to create it as a by-product, such as esterification and subsequent polycondensation used to create polyethylene terephthalate (PET) plastics (Popoola, 1991) or the synthesis of those plastics in the manufacturing of polyesters (Zenker, et al., 2003). Therefore, WWTFs with such industries discharging to their collection system may expect to see greater loading of this contaminant in both their influent and effluent streams. During the first year of the study, the highest measured concentrations were observed below WWTFs. 1,4-dioxane is not used in or created by wastewater treatment processes, suggesting that the most significant contributions were constituents of industrial waste streams that were passing through WWTF treatment processes with varying levels of removal efficiency prior to entering surface waters. These findings were communicated to the affected municipalities to support their pretreatment programs. The second study year included quarterly sampling which yielded a sample size too small to draw definitive conclusions. Measured 1,4-dioxane concentrations generally decreased throughout the basin, suggesting potential improvement in water quality which may have been due to actions taken by the municipalities (and/or their contributing industries) whose WWTFs were receiving industrial effluent containing 1,4-dioxane. NC DWR's ongoing monitoring study will provide more data to determine actual water quality improvements, inform 1,4-dioxane reduction efforts, and document surface water outcomes over time. Management Implications and Future Actions Successful abatement of 1,4-dioxane in Cape Fear River basin drinking water sources will require continued partnerships between the Division, project partners, municipal utility departments, and industries within the basin. Further research into options for replacement of 1,4-dioxane-containing compounds in Industrial processes, as well as capture and treatment technologies that could be implemented in industrial and domestic wastewater treatment systems, is warranted. Such research has already begun locally through studies funded by the National Science Foundation, Water Resources Research Institute, and Urban Water Consortium. The NC DWR is developing a study plan to continue monitoring 1,4-dioxane concentrations at selected locations within the Cape Fear River basin during 2017-2018 with the objectives of further understanding fluctuations in concentrations, identifying sources, and documenting in -stream responses to source abatement efforts. Also in 2017-2018, the study will be expanded into the Neuse and Yadkin River basins 5 in areas that returned UCMR3 1,4-dioxane results above the calculated human health criterion for water supply waterbodies. Acknowledgements This research was supported by the Public Water Supply Section of the North Carolina DWR. We appreciate the support of our colleagues within this Section and also within the Planning, Permitting, and Water Sciences Sections, who provided their insight and expertise to assist with this study. The upcoming expanded study will be funded under a grant from the National Fish and Wildlife Foundation. We thank the Foundation and our Water Sciences Section colleagues who will be contributing to the monitoring efforts, optimizing instrumentation, and developing methods to expand the NC DWR Chemistry laboratory's capacity to analyze 1,4-dioxane in water. We recognize Dr. Detlef Knappe and his graduate students at the North Carolina State University Department of Civil, Construction, and Environmental Engineering for their assistance with study design, sample collection, and sample analysis. Finally, we acknowledge and commend the efforts of the Cape Fear River basin municipalities that strive to safeguard and provide high -quality public services to their constituents. 5 References All hyperlinks accessible as of November 27, 2016. (ATSDR) Agency for Toxic Substances and Disease Registry. 2012. Public health statement: 1,4-dioxane, CAS It 123-91-1. Atlanta, Georgia: U.S. Department of Health and Human Services. Available at http://www.atsdr.cdc.goy/ToxProfiles/tP187-cl-b.pd Knappe, D. 2014. Sources of 1,4-dioxane in the Cape Fear Riverwatershed of North Carolina and treatment options for 1,4-dioxane control. Raleigh, NC: NC State University. Study details available at http://www.nsf.pov/awardsearch/showAward?AWD ID=1449768&HistoricalAwards=false. Mohr, T.K. 2010. Environmental Investigation and Remediation:1,4-dioxane and other solvent stabilizers. CRC Press. In 1,4-Dioxane White Paper. 2014. Water Research Foundation. Available at http://www.waterrf.org/resources/StateOff heScienceReports/1.4-dioxane.pdf. (NCDENR) North Carolina Department of Environment & Natural Resources, Division of Water Resources, Environmental Sciences Section, Ecosystems Branch. 2014. Ambient Monitoring System (AMS): Quality Assurance Project Plan, version 1.2. Available at https://deo. nc.gov/about/divisions/water-resou rces/water-resou rces-data/water-sciences- home-page/ecosystems-bra nch/a ms-a ua lity-assura nce-project-pia n. (NC DWR) North Carolina Division of Water Resources. 2016. 1,4-dioxane in the Cape Fear River basin of North Carolina: An initial screening and source identification study. Raleigh, North Carolina: North Carolina Department of Environmental Quality. Available as a link from https://dea. nc.gov/about/divisions/water-resou rces/water-resources-data/water-sciences- home-page/1-4-dioxane. Popoola, A.V. 1991. Mechanism of the reaction involving the formation of dioxane byproduct during the production of poly(ethylene terephthalate). Journal of Applied Polymer Science 43, 1875-1877. Available at http://on linel ibrary.wiley.com/doi/10.1002/a pp.1991.070431011/a bstract. Stepian, D.K., Diehl, P., Helm, J., Thomas, A. and Puttmann, W. 2014. Fate of 1,4-dioxane in the aquatic environment: From sewage to drinking water. Water Research 48, 406-419. Available at http://dx.doi.org/10.1016/i.watres.2013.09.057. (UCMR3) Revisions to the Unregulated Contaminant Monitoring Rule (UCMR3) for Public Water Systems. 77 Federal Register 26,072 (May 2, 2012). Available at https://www.gpo.gov/fdsys/pkg/FR-2012- 05-02/html/2012-9978.htm. (U.S. EPA) U.S. Environmental Protection Agency, Office of Water. 2012. 2012 Edition of the Drinking Water Standards and Health Advisories (EPA 822-5-12-001). Washington, DC: U.S. Environmental Protection Agency. Available at http://www.epa.gov/nscep (search for 822S12001"). (U.S. EPA) U.S. Environmental Protection Agency. 2016. Third Unregulated Contaminant Monitoring Rule. Available at http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/ucmr3/basicinformation.cfm. (U.S. EPA) U.S. Environmental Protection Agency, Office of Chemical Safety and Pollution Prevention. 2015. TSCA Work Plan Chemical Problem Formulation and Initial Assessment (EPA 740-111-5003). Washington, DC: U.S. Environmental Protection Agency. Available at htto://www.epa.Rov/nscep (search for "740R15003). Water Research Foundation. 2014. 1,4-Dioxane White Paper. Available at: http://www.waterrf.org/resources/StateOf heScienceReports/1.4-dioxa ne.pdf. Zenker, M.1., Borden, R.C., Barlaz, M.A. 2003. Occurrence and treatment of 1,4-dioxane in aqueous environments. Environmental Engineering Science 20 (5), 423-432. Available at http://on I ine.l iebertpub.com/doi/abs/10.1089/109287503768335913. 8 F19740P1Ere1 NC DWR Monitoring Station Locations Station Location County Latitude Longitude Stream Monitoring Class Dates Haw River above Reedy Fork Haw River at Troxler Mill Road near Jun 2015 - B4 Rockingham 36.2329 -79.5588 WS-IV NSW Reidsville Oct 2016 Haw River at SR 1712 (Brooks Oct 2014 - Bl Guilford 36.2219 -79.5456 WS-V NSW Bridge Road) Oct 2016 Haw River at SR 1561 Hub Mill Oct 2014 - B0210000 Alamance 36.1786 -79.5042 WS-V NSW Road Oct 2016 Buffalo Creek and Reedy Fork South Buffalo Creek at SR 2821 at Oct 2014 - B0750000 Guilford 36.1128 -79.6718 WS-V NSW McLeansville Oct 2016 86 Reedy Fork at NC-61 near Ossipee Guilford 36.1792 -79.5763 WS-V NSW Jun 2015 - Oct 2016 B0840000 Reedy Fork at NC-87 at Ossipee Alamance 36.1730 -79.5103 WS-V NSW Oct 2014 - Oct 2016 Hasketts Creek NCSU24 Haskett Creek at WOW Road near Randolph 35.7681 -79.7790 C Jun 2015- Asheboro Oct 2016 Haw River below Reedy Fork Haw River at SR 1713 near Bynum Oct 2014 - B2100000 (near Pittsboro intake) Chatham 35.7717 -79.1450 WS-IV NSW Oct 2016 Cape Fear River Cape Fear River at Harnett County Oct 2014 - B8 Public Utilities intake Harnett 35.4092 -78.8189 WS-IV CA Oct 2016 Cape Fear River at US-401 at Oct 2014 - B6370000 Harnett 35.4065 -78.8135 WS-IV Lillington Oct 2016 Cape Fear River at Hoffer WTP Oct 2014 - B7480000 Cumberland 35.0825 -78.8638 WS-IV CA intake at Fayetteville Oct 2016 B8350000 Cape Fear River at Lock 1 near Kelly Bladen 34.4038 -78.2932 WS-IV Sw Oct 2014 - Oct 2016 INC Stream classifications at study locations included Water Supplies (WS-IV and WS-V) and Critical Areas (CA) near drinking water intakes, Nutrient Sensitive Waters (NSW), waters protected for aquatic life and secondary recreation (C) and Swamp waters (Sw). APPENDIX B NC DWR 1,4-Dioxane Monitoring Results Station Location Stream Class EL' (µg/L) Year (n) 1,4-Dioxane Concentration (µg/L)3 Min Median Max Mean Haw River above Reedy Fork B4 Haw River at Troxler Mill Road near Reidsville WS-IV NSW 0.35 1 (4) 35 169 1030 351 2 (6) <2 4 46 11 B1 Haw River at SR 1712(Brooks Bridge Road) WS-V NSW 80 1(13) <3 33 149 46 2 (5) <2 5 54 14 B0210000 Haw River at SR 1561 Hub Mill Road WS-V NSW 80 1 (13) <3 38 100 42 2 (5) <2 7 51 14 Buffalo Creek and Reedy Fork 80750000 South Buffalo Creek at SR 2821 Harvest Road at McLeansville WS-V NSW 80 1 (15) 9 25 543 80 2 (6) 7 12 86 28 B6 Reedy Fork at NC-61 near Ossipee WS-V NSW 80 1 (4) 11 20 45 24 2(5) 9 9 62 20 B0840000 Reedy Fork at NC-87 at Ossipee NSW 80 1 (13) 7 45 100 43 2(5) 7 10 20 12 Hasketts Creek NCSU24 Hasketts Creek at W.O.W. Road C 80 1(4) 147 269 478 291 2(5) 69 169 614 260 Haw River below Reedy Fork B2100000 Haw River at SR 1713 near Bynum (near Pittsboro intake) WS-IV NSW 0.35 1(13) <3 13 66 18 2 (5) <2 8 14 8 Cape Fear River BS Cape Fear River at Harnett County Public Utilities intake WS-IV CA 0.35 1 (13) <3 5 15 6 2 (5) <2 <2 <2 <2 B6370000 Cape Fear River at US-401 at Lillington WS-IV 0.35 1 (15) <3 4 15 6 2 (5) <2 2 3 2 87480000 Cape Fear River at Hoffer WTP intake at Fayetteville WS-IV CA 0.35 1 (12) <3 3 11 4 2 (5) <2 <2 <3 <2 B8350000 Cape Fear River at Lock 1 near Kelly WS-IV Sw 0.35 1(12) <3 3 11 4 2 (5) <2 2 3 2 Notes: 'The evaluation level (EL) for 1,4-dioxane is based on stream classification. The water supply EL is 0.35 µg/L, except WS-V in the Jordan Lake watershed. The EL for Jordan Lake WS-V and all other waters is 80 µg/L. 'The Year 1 summary includes monitoring results from October 2014-September 2015. The Year 2 summary includes monitoring results from October 2015-October 2016. "n" is the number of results during the study year. 3 Median and mean values may be inflated for stations with results below the contract lab PQL of 3 µg/L (in 2014- 2015) and 2 µg/L (in 2016). For summary calculations, non -detect results are set equal to the PQL in place at the time of analysis. When a minimum or all values were below the PQL, a "<" sign is used. 11 APPENDIX A NC DWR Monitoring Station Locations NC DWR 1,4-Dioxane Monitoring Stations in the Cape Fear River Basin October 2014 - October 2016 Major Rivera Deep, Haw and Cape Fear Rivers Reserroira Major Municipal graas Jordan Lake Watershed 10 APPENDIX B NC DWR 1,4-Dioxane Monitoring Results cape fear R—, 12 Randleman Lake 1,4-Dioxane Calculation The concentration of 1,4-Dioxane at WS-V boundary in Deep River resulting from 2.65 µg/L in Deep River above confluence with Hasketts Cr (Station B4800000) is calculated using the mass -loading formula: Load (lb/day) = Concentration (mg/L) x Flow (MGD) x 8.34, where 8.34 is a conversion factor. Downstream Randleman Lake (station B4800000) concentration = 2.57 µg/L (0.00257 mg/L) Flow at station B4800000 = 233.6 cfs / 1.55 conversion factor = 150.7 MGD Flow is calculated via yield: Drainage area (DA) at station = 235 miz (delineated using StreamStats) DA at Streamgage 02100500 = 349 mil (USGS 2012 Low Flow report) Avg Ann flow (Q4) at Streamgage 02100500 = 347 cfs (USGS 2012) Yield = QA/DA = 347/349 = 0.994 QA at station = Yield x DA at station = 0.994 x 235 = 233.6 cfs Flow at WS boundary = 838 cfs /1.55 conversion factor = 540 MGD Flow was similarly calculated via yield with a nearby streamgage. 1,4-Dioxane load below Randleman Lake = 0.00257 mg/L x 150.7 MGD x 8.34 = 3.23 lb/day 1,4-Dioxane conc. at at the WS boundary = 3.23 lb/day / (8.34 x 540 MGD) x 1000 = 0.72 u L hvN.n 0} ImmrvT AYM it - Uin,,m B4800000 Randleman 1,4-Dioxane = 2.57 µg/L Lake / y 1 - USGS Sta 02100500 DA = 349 miz QA = 347 cfs11 } �. USGS Sta 02102000 i, DA = 1410miz WS-V QA = 1380 cfs 1 "-' DA = 853 miz QA = 838 cfs J p Ilia G.B. Perlmutter, 10/11/2018 Evaluation of Alternative 1,4-Dioxane Effluent Limitations for Asheboro WWTP (NC0026123) From consultation with the SIU Starpet in September 2018, the City of Asheboro proposed to DWR two potential 1,4-dioxane effluent limits: a concentration -based Monthly Average limit of 97 µg/L, and a loading limit based on 60 µg/L concentration. These proposed limits were evaluated via calculation of their concentrations at the nearest downstream WS water upper boundary and compared against that from the 149 µg/L monthly average limit proposed in the first draft permit. Calculations were made using the mass -loading formula: Load (lb/day) = Concentration (mg/L) x Flow (MGD) x 8.34, where 8.34 is a conversion factor. Given: WWTP design flow = 9.0 MGD Downstream WS flow = 540 MGD extrapolated using USGS StreamStats Alternative 1: Monthly Average Limit of 149 ug/L based on RPA calculation (i.e., reference scenario): Applicable Human Health criterion at discharge = 80 ug/L (non-WS) 0.149 mg/L x 8.34 x 9 MGD = 11.18 Ib/d at design flow 11.18 Ib/d / (8.34 x 540 MGD downstream flow) x 1000 = 2.48 ue/L at the downstream WS boundary WS For actual load under current average discharge flow of 3.5 MGD: 0.149 mg/L x 8.34 x 3.5 MGD = 4.35 Ib/d 4.35 Ib/d / (8.34 x 540 MGD) x 1000 = 0.96 ug/L at WS This option was proposed in the draft permit and is presented here as reference for comparison. Alternative 2: Mass loading limits based on 60 ug/L effluent concentration 0.060 mg/L x 8.34 x 9 MGD = 4.5036 Ib/d load limit at 9 MGD design flow 4.5036 Ib/d / (8.34 x 540 MGD) x 1000 =1.00 ug/L at WS For actual load under current average discharge flow of 3.5 MGD: 0.060 mg/L x 8.34 x 3.5 MGD=1.7514 Ib/d load 1.7514 Ib/d / (8.34 x 540 MGD) x 1000 = 0.39 ug/L at WS Page 1 of 3 Evaluation of Alternative 1,4-Dioxane Effluent Limitations for Asheboro WWTP (NC0026123) Alternative 3: Mass loading using 97.0 ug/L Monthly Average limit at 9 MGD design flow 0.097 mg/L x 8.34 x 9 MGD design flow = 7.28 Ib/d load 7.28 Ib/d / (8.34 x 540 MGD) x 1000 =1.60 ug/L at WS For actual load under current average discharge flow of 3.5 MGD: 0.097 mg/L x 8.34 x 3.5 MGD actual average flow = 2.83 Ib/d load 2.83 Ib/d / (8.34 x 540 MGD) x 1000 = 0.63 ug/L at WS Summary Chart 2.51 —}— Avg at Hoffer WTP (Fayetteville) Intake along Cape Fear R ;. 2.48 based on RPA-based Mo. Avg. limit of 149 ug/L at 9 MGD 11.18 N 3 0 � a o 1.60 based on 97.0 ug/L Mo. Avg. limit at 9 MGD 7.28 cc M n =r c aU PQ o m 1.00 based on 60 ug/L-derived load limit at 9 MGD 4.50 a 0.63 based on 97 ug/L Mo. Avg. limit at 3.5 MGD 2.83 Recommendation: Based on the results of this evaluation, both the 60 µg/L-based load limit and the 97.0 µg/L Monthly Average concentration limit were found to protect the downstream water quality better than does the RPA-based Monthly Average concentration limit proposed in the draft permit. A combined 1,4-Dioxane limit of 97.0 µg/L monthly average with a load limit not to exceed 4.50 lb/day is recommended for Asheboro's permit, as they represent best achievable treatment technology proposed by the SIU Starpet Inc., identified as the primary source of 1,4-Dioxane to the POTW. The loading limit will assure that as flow increases, 1,4-Dioxane concentrations will decrease, thereby providing downstream water quality protection while allowing flexibility for the WWTP and its SIU to increase flow. The concentration limit will prevent load -based effluent concentrations from rising indefinitely with low flows (e.g., at 2 MGD, the maximum load would yield an effluent concentration of 269 µg/L, which exceeds the 80 µg/L criterion at the receiving stream), thereby providing further protection of downstream water quality. Estimated concentration at WS-Boundary (next page) Page 2 of 3 Evaluation of Alternative 1,4-Dioxane Effluent Limitations for Asheboro WWTP (NC0026123) Estimated concentration at WS-Boundary Taking into consideration of the background loading from Randleman Lake,1,4-Dioxane concentration at the WS-V upper boundary is per the recommended loading limit is calculated as follows: Asheboro load limit of 4.50 lb/day + upstream Deep River load* of 3.23 Ib/d = 7.73 lb/day 7.73 lb/day / (8.34 x 540 MGD) x 1000 =1.716 µg/L, rounded to 1.72 Ng/L *See Randleman Lake 1,4-Dioxane Calculation sheet Page 3 of 3 r'; ROY COOPER Governor MICHAEL S. REGAN Secretary Water Resources LINDA CULPEPPER Environmental Quality Interim Director May 1, 2018 John N. Ogburn, III City of Asheboro P.O. Box 1106 146 N Church Street Asheboro, NC 27204 Subject: Draft NPDES Permit Renewal Permit NCO026123 Asheboro WWTP, Grade W Randolph County SIC Code 4952 Dear Mr. Ogbum: Enclosed with this letter is a copy of the draft NPDES permit renewal for your facility. Please review this draft carefully to ensure thorough understanding of the requirements and conditions it contains. There are several changes from the existing permit, including the following: • Regulatory citations have been added to the permit. • Parameter characteristic codes have been added in Section A. (1.). — Effluent Limitations and Monitoring Requirements. • An updated outfall map with instream monitoring station locations has been included. • Ammonia -Nitrogen (NH3-N) limitations have been decreased, based on wasteload allocation (WLA) calculation. Limitations for NH3-N are based on protection of aquatic life utilizing an EPA ammonia chronic criterion of 1.0 mg/L (summer) and 1.8 mg/L (winter). The WLA results yielded NH3-N limitations that are more stringent than in the current permit, as tabulated below: Existing Proposed Summer Winter Summer Winter Monthly Average 2.0 mg/L 4.0 mg/L 1.0 mg/L 1.8 mg/L Weekly Average 6.0 mg/L 12.0 mg/L 3.0 mg/L 5.4 mg/L - 'Nothing Compares State of North Carolina I Environmental Quality 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 919-707-9000 • Instream Conductivity monitoring has been added to the permit, based on the presence of an industrial pretreatment program as specified in Instream Conductivity and Fecal Coliform Monitoring Guidance (NCDWQ internal memo, 2002). However, the Permittees' sampling requirement for this parameter is conditionally waived as long as the Permittee is a member of the Upper Cape Fear River Basin Association. • The NC 2007-2014 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Committee (EMC) on November 13, 2014. The US EPA subsequently approved the WQS revisions on April 6, 2016 with some exceptions. The NC Division of Water Resources NPDES Permitting Unit is required to implement the new dissolved metal standards in all permits public noticed after April 6, 2016. The new standards for most metals include acute standards. Further, the freshwater standards for several metals are expressed as the dissolved form of the metals, and seven metals have hardness -dependent equations. As a result, the NPDES Permitting Unit will need site - specific effluent hardness data and instream hardness data, upstream of the discharge, for each facility monitoring these metals in order to calculate permit limitations. Effluent hardness sampling has been added to this permit at a quarterly monitoring frequency. Upstream hardness sampling has not been added, in recognition of the receiving stream's 7Q l Os of 0 cfs, which renders upstream hardness measurements irrelevant in dissolved metals calculations. See Section A. (L). • As part of the NC 2007-2014 WQS Triennial Review, the Total Chromium WQS was removed and replaced with trivalent chromium (Chromium III) WQS and hexavalent chromium (Chromium VI) WQS. Total Chromium is made up of hexavalent and trivalent forms. The reasonable potential analysis using Asheboro's Total Chromium effluent data showed potential to violate the new Chromium VI standard. As a result, Total Chromium limits were removed from the permit; quarterly monitoring of Total Chromium and Chromium VI were added to the permit. Sampling for hexavalent chromium and total chromium together will ascertain if hexavalent chromium is present in the total chromium samples and thus the effluent. If sampling for hexavalent chromium indicates that hexavalent chromium is not present (i.e. non -detectable concentrations at the lower reporting level of the procedure) after two years of sampling, then the limits and monitoring requirements for hexavalent chromium in Section A. (L) can be reduced or removed upon request. See Section A. (L), Footnote 6. • Currently, EPA is allowing an action level for Chloride, but at the next permit renewal this may not be the case. Your passing record for toxicity tests indicate that a limit for chloride is not necessary at this time, but this may change in the future. Please note that your allowable concentration for Chloride is 230 mg/L. Your effluent average from January 2014 through December 2017 was 166 mg/L; and a reasonable potential analysis found a reasonable potential to exceed the allowable concentration. As a result, quarterly monitoring for Chloride in conjunction with toxicity tests is maintained in the permit. • A monthly average limit of 5.0 µg/L and a daily maximum limit of 22.0 µg/L for Cyanide have been added to the permit and samples shall be taken monthly. Results of a reasonable potential analysis on submitted data indicated a reasonable potential to exceed the instream Page 2 of 5 Silver to the lower reporting level of the procedure. Quarterly monitoring for Total Silver has been added to the permit. A monthly average limit of 149 µg/L for 1,4-Dioxane has been added to the permit. 1,4- Dioxane is listed as a likely human carcinogen by the EPA. A basinwide survey of the Cape Fear River has found elevated concentrations of 1,4-Dioxane just downstream of the Asheboro WWTP discharge. To allow time and actions toward meeting the new 1,4- Dioxane limits, a three (3) year compliance schedule has been added to the permit with annual milestones. See Section A. (6.). Three effluent samples collected since December 2017, using EPA Method 624.1, have exceeded the allowable discharge limitation of 149 µg/L. Therefore, a limit and monitoring for 1,4-doxane has been added to the permit. Some of the wording has changed in Section A. (2.) — Chronic Toxicity Permit Limit; please review each paragraph carefully. Section A. (3.) — Effluent Pollutant Scan has been modified to include the three specific years in which the Effluent Pollutant Scans shall be performed (2019, 2020, and 2021). In addition, at the end of the Special Condition, 2nd species Toxicity Testing Requirements for municipal permit renewals per Federal Regulations [40 CFR 122.210)(5)] have been added. Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. The requirement to continue reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your final NPDES permit. See Section A. (7.). For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://deg.nc.aov/about/divisions/water- resources/edmr. For more information on EPA's final NPDES Electronic Reporting Rule, please visit the following web site: https://www.federalregister.gov/documents/2015/10/22/2015- 24954/national-poll utant-discharge-elimination-system-npdes-electronic-reporting-rule. The NPDES Standard Conditions (Parts II, III, and N) are not included with this draft. They can be found at the following link if you would like to review them in conjunction with this draft permit. httv://ncdenr. s3.amazonaws.com/s3 fs- public/W ater%20Ouality/Surface%20W ater°/"20Protection/NPDES/MISC/NPDES%20Standard %20Conditions-Boilerplate-DWR-SWP-NPDES-20150410 2df Please note that the receiving stream is listed as impaired for Copper on North Carolina's Final 2014 303(d) Impaired Waters List. Addressing impaired waters is a high prioritywith the Division, Page 4 of 5 water quality standards. A footnote has been added to the effluent limitations sheet stating that the Division will consider all values reported below 10 µg/L to be compliant due to difficulties in quantifying cyanide in wastewater, but the Permittee shall submit all Cyanide values reported by a NC -certified laboratory, even if values are less than 10 µg/L. See Section A. (1.). • Quarterly monitoring for Total Zinc has been removed from the permit. Review of the data revealed no reasonable potential to exceed water quality standards. Quarterly monitoring shall be maintained per the facility's pretreatment Long Term Monitoring Program (LTMP). • Effluent Mercury data were reviewed from May 2012 to May 2017. The Permittee tested effluent for Total Mercury using EPA test Method 1631E throughout this period. In accordance with the 2012 Mercury TMDL NPDES Guidance, the Permittee needs to show annual average effluent concentrations below the Water Quality Based Effluent Limitation (WQBEL) of 12.0 ng/L and no exceedance of the Technology Based Effluent Limitation (TBEL) of 47 ng/L. A review of the data showed the annual averages were below the WQBEL and all data were below the TBEL; therefore, no mercury limitation is required. As a result of the TMDL evaluation, the limits and monitoring of mercury have been removed from Section A. (1.). Sampling for mercury will be conducted during the three (3) effluent pollutant scans [see Section A. (3.)] as well as the pretreatment LTMP using EPA Method 1631E. Fifty-one (51) out of 71 low level effluent mercury samples collected were over 1 ng/L. As a result, a Mercury Minimization Plan (MMP) requirement has been added in this permit renewal. See Section A. (4.). Please note that the Permittee shall develop and implement a MMP during this permit term. The MMP shall be developed within 180 days of the NPDES Permit Effective Date, and shall be available for inspection on -site. A sample MMP was developed through a stakeholder review process and has been placed on the Division website for guidance (httns://dgq.nc.gov/document/nc-model-mercury-minimization-plan- dwr-nodes-swp-2013 0801). • A monthly average limit of 31.6 µg/L for Bromodichloromethane has been added to the permit and samples shall be taken monthly. Results of a reasonable potential analysis on submitted data indicated a reasonable potential to exceed the instream water quality standards. • Review of submitted effluent data showed all samples for Total Silver to be less than detection at 5 µg/L. In accordance with 15A NCAC 2B .0500, all test procedures must produce detection and reporting levels that are below the permit discharge requirements and all data generated must be reported to the approved detection level or lower reporting level of the procedure. Currently, DWR's laboratory identifies the Practical Quantification Limit for Total Silver at < 1.0 µg/L. The allowable discharge concentration for Total Silver at your facility is 0.06 µg/L as a monthly average. The Division recommends that the Permittee improves and implements "clean" sampling techniques, and analyzes Total Page 3 of 5 and instream data will continue to be evaluated. If there is noncompliance with permitted effluent limits and the stream impairment can be attributed to your facility, then mitigative measures may be required. Concurrent with this notification the Division is publishing a notice in a newspaper having circulation in the general Randolph County area, soliciting public comments on this draft permit. Please provide any written comments you may have to the following: NCDEQ/DWR, NPDES Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 no later than 30 days after receipt of this draft permit. Following the 30-day public comment period, the Division will review all pertinent comments and take appropriate action prior to issuing a final permit. If you have questions concerning this draft permit, please call me at (919) 807-6385 or by email at gary.perlmutter@ncdenr.gov. Sincerely �� Gary Perlmutter, Environmental Senior Specialist NPDES Complex Permitting Unit Hardcopy: NPDES Files eCopy: US EPA Region 4 DWR / Winston-Salem Regional Office / Water Quality Operations DWR/ Wastewater Operator Certification Group / Maureen Kinney DWR / W SS / Aquatic Toxicology Branch / Susan Meadows DWR / Ecosystems Branch / Mark Vander Bourgh City of Asheboro / Water Resources Director / Michael D. Rhoney, PE Page 5 of 5 Permit NCO026123 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the City of Asheboro is hereby authorized to discharge wastewater from a facility located at the Asheboro Wastewater Treatment Plant 1032 Bonkemeyer Drive Asheboro, NC 27203 Randolph County to receiving waters designated as Hasketts Creek in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111 and IV hereof. This permit shall become effective Month 1, 2018. This permit and authorization to discharge shall expire at midnight on September 30, 2022. Signed this day Month xx, 2018. DRAFT Linda Culpepper, Interim Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 14 Permit NCO026123 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. The City of Asheboro is hereby authorized to: 1. Continue to operate and maintain the 9.0 MGD wastewater treatment plant with a discharge through Outfall 001, consisting of the following components: • Influent pump station with automatic bar screens and grit removal • Influent ultrasonic flow meter • Influent composite sampler • Flow splitter box #1 • Seven (7) primary clarifiers; one (1) circular rated for 3.0 MGD, six (6) rectangular rated 1.0 MGD each • Trickling filter mixing/transfer pump basin • Three (3) trickling filters, 140 feet diameter • Recirculation box/valve vault and circulation pump basin #1 • Four (4) secondary clarifiers; 27,024 cu. ft. each • Recirculation pump basin..#2 • Nitrification mixing/transfer pump basin • Flow splitter box #2 • Two (2) nitrification basins with mixing basin and blowers; 2,000,000 gallons each • Flow splitter box #3 • Magnesium hydroxide chemical addition system • Three (3) final clarifiers; 70,333 cu. ft. each • Polymer chemical addition system • One (1) Parkson Dynasand continuous flow tertiary filter • Chlorine contact chamber with sodium hypochlorite addition for disinfection • Sodium bisulfite addition for,dichlorination • Effluent flow meter • Effluent composite sampler • Cascade aeration basin • Two (2) sludge digesters; 401,900 gallons each • Drying beds, 105 ft. x 450 ft. total • Sludge dewatering presses, thickener tanks, lime stabilization system, and solids storage • Standby power generation This facility is located at the Asheboro WWTP, 1032 Bonkemeyer Drive, Asheboro, in Randolph County. 2. Discharge from said treatment works via Outfall 001, at the location specified on the attached map into Hasketts Creek currently classified C waters in the Cape Fear River Basin. Page 2 of 14 Permit NCO026123 PART I A. (l.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B.0400 et seq., 15A NCAC 02B.0500 et seq.] a. During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated municipal and industrial wastewater from outfall 001 of this Grade IV facility. Such discharges shall be limited and monitored' by the Permittee as specified below: PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS Monthly Weekly Daily Measurement Sample Sample Parameter Code Average Average Maximum Frequency Type Location z Flow 50050 9.0 MGD Continuous Recording Influent or Effluent BODs (20°C) 3 80082 5.0 mg/L 7.5 mg/L Daily Composite Influent and (April 1- October 31) Effluent BODs (20°C) 3 80082 10.0 mg/L 15.0 mg/L Daily Composite Influent and (November 1- March 31) Effluent Total Suspended Solids C0530 30.0 mg/L g 45.0 mg/L 9 Dail YEffluent Composite Influent and (TSS) 3 Ammonia (NH3 as N) C0610 .10 mg/L 3.0 mg/L Daily Composite Effluent (April 1- October 31) Ammonia (NH3 as N) C0616 1.8 mgl& ' 5.4 mg/L Daily Composite Effluent (November 1-March 31) Dissolved Oxygen (DO) 00300 1 Daily Average > 6.0 mg/L Daily Grab Effluent pH 06400 Between 6.0 and 9.0 standard units Daily Grab Effluent Fecal Coliform ' (geometric mean) 31616 200/100 mL. 4001100 mL _ Daily Grab Effluent Total Residual Chlorine 50060 17 N9 /L Dail Y Grab Effluent (TRC) 4 Temperature (°C) 00010 Monitor and Report Daily Grab Effluent Conductivity (Nmhos/cm) 00094 Monitor and Report Daily Grab Effluent Total Hardness [as CaCO3 00900 or (Ca + Mg)] (mg/L) 5 Monitor and Report p Quarter) y Composite p Effluent Total Chromium (Ng/L) 01034 Monitor and Report Quarterly Composite Effluent Chromium VI (Ng/L) 6 01032 Monitor and Report Quarterly Composite Effluent Total Kjeldahl Nitrogen 00625 (TKN) (mg/L) Monitor and Report Monthly Composite Effluent Nitrate/Nitrite Nitrogen 00630 (NO3+NO2) (mg/L) Monitor and Report Monthly Composite Effluent Page 3 of 14 Permit NCO026123 -PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORIKG REWIREMIENTS - - Parameter code Month Average Week Average DaI Maximum Measurement ` Frequency Sample Tl pe Sample _ Loedli 2 , Total Nitrogen [TN=(NO2+NO3)+TKN] C0600 (mg/L) Monitor and Report Monthly Calculated Effluent Total Phosphorus (mg/L) C0665 Monitor and Report Quarterly Composite Effluent Dibromochloromethane 32150 (N9/L) Monitor and Report Quarterly Grab Effluent Bromodichloromethane 38693 31.6 Ng/L Monthly Grab Effluent Chlorides (mg/L) 7 00940 Monitor and Report Quarterly Composite Effluent Total Copper (Ng1L) 01042 Monitor and Report Quarterly Composite Effluent Total Cyanide 8 00720 5.0 Ng/L 22.0 Ng/L Monthly Grab Effluent Total Silver (Ng/L) s 01077 ''Monitor,and Report Quarterly Composite Effluent 1,4-Dioxane 82388 149 Ng/L 10 Monthly Grab Effluent Chronic Toxicity 11 TGP3e Ceriodaphnia Pass/Fail at 90%o +effluent Quarterly Composite Effluent Effluent Pollutant Scan NC01 Monitor and Report ,° , Footnote 12 Footnote 12 Effluent Dissolved Oxygen (mg/L)13 00300 Monitor and Report Variable 14 Grab U, D1, D2 Temperature (°C)13 00010 Monitor and Report Variable 14 Grab U, D1, D2 Conductivity (µmhos/cm)13 00094 Monitor and Report Variable 14 Grab U, D1, D2 Footnotes: 1. Submit discharge monitoring reports electronically using the NC DWR's eDNM application system. See Section A. (7.). 2. U = approximately 800 feet upstream of the discharge; D1 = downstream at NCSR 2128; and D2 = downstream in the Deep River at NCSR 2261. 3. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 4. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field -certified), even if these values fall below 50 µg/L. 5. Effluent Total Hardness sampling shall be conducted in conjunction with testing for hardness -dependent metals (cadmium, chromium, copper, lead, nickel, silver and zinc). 6. If Chromium VI is not detected (i.e. non -detectable concentrations below the lower reporting level of the procedure) after two years of sampling, the Permittee may request DWR to reduce or remove monitoring requirements for Chromium VI in Section A. (1.). 7. Chlorides will be monitored in conjunction with Chronic Toxicity tests. 8. Due to difficulties quantifying cyanide in a wastewater matrix, the Division shall consider all values reported below 10 µg/L to be "compliant" with this permit. However, the Permittee shall submit to DWR all values Page 4 of 14 Permit NC0026123 reported by a North Carolina -certified test method (even if values fall below 10 µg/L), and the Permittee shall consider all reported values when calculating averages, if any, as required by this permit. 9. The Permittee should review and implement clean sampling techniques for Total Silver. The reporting laboratory should test to the lower reporting level of the procedure. 10. This limit becomes effective [within three (3) years of the effective date of this permit]. The Permittee shall follow the compliance schedule detailed in Section A. (6.). 11. Whole Effluent Toxicity samples shall be collected during the months of March, June, September, and December. See Section A. (2.). 12. The Permittee shall preform three Effluent Pollutant Scans during the term of this permit. See Section A. (3.). 13. The Permittee has deferred receiving -stream sampling to the Upper. Cape Fear River Basin Association by memorandum of agreement (MOA). Should this MOA terminate;` for any reason, the Permittee shall immediately inform the Division in writing and immediately resume-instream monitoring in accordance with this permit. 14. Instream samples shall be collected three times per week from JuneI .through September 30, and once per week from October 1 through May 31. b. There shall be no discharge of floating solids.: or visible foam in other .than trace amounts. Page 5 of 14 Permit NCO026123 A. (2.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) — 9.0 MGD [15A NCAC 02B.0200 et seq.] The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions or "North Carolina Phase H Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be performed during the months of March, .Tune, September and December. These months signify 'the first month of each three-month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES.permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter.: results in a failure or Chronic Value (ChV) below the permit limit, ` then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form. (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3 (original) is to be sent to the following address: NC DEQ / DWR Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, NC 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the Permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity Page 6 of 14 Permit NC0026123 testing quarter, which is the three-month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial:monitoring. Page 7 of 14 Permit NCO026123 A. (3.) EFFLUENT POLLUTANT SCAN (Municipal POTWs) [NCGS 143-215.1 (b)] The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below. One scan must be performed in each of the following years: 2019, 2020, and 2021. Analytical methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether parameters are present in concentrations greater than applicable standards and criteria. Samples should be collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total recoverable." Ammonia (as N) C0610 1,2-dichloroethane 32103 Bis (2-chloroethoxy) methane 34278 Chlorine (total residual, TRC) 50060 Trans-1,2-dichloroethylene 34546:-'-, Bis (2-chloroethyl) ether 34273 Dissolved oxygen 00300 1,1-dichloroethylene 34501 -` Bis (2-chloroisopropyl) ether 34283 Nitrate 00620 1,2-dlchloropropane 34541 Bis (2-ethyihexyl) phthalate 39100 Nitrite 00615 1,3-dichloropropylene 77163 4-bromophenyl phenyl ether 34636 Kjeldahl nitrogen 00625 Ethylbenzene 34371 Butyl benzyl phthalate 34292 Oil and grease 00556 Methyl bromide 34413 2-chtoronaphthalene 34581 Phosphorus C0665 Methyl chloride 34418 4-chlorophenyl phenyl ether 34641 Total dissolved solids 70295 Methylene chloride 34423 Chrysene 34320 Hardness 00900 1,1,2,2-tetrachloroethane 81549 Di n-butyl phthalate 39110 Antimony 01097 Tetrachloroethylene 34475 Di n-octyl phthalate 34596 Arsenic 01002 Toluene 34010 Dibenza(a,h)anthraoene 34556 Beryllium 01012 1,1,1-trichloroeihane 34506 1,2-dlchlorobenzene 34536 Cadmium 01027 1,1,2-trichloroethane ,34511 1,3-dichlorobenzene 34566 Chromium 01034 Tdchloroethylene 39180, 1,4-dichlorobenzene 34571 Copper 01042 Vinyl chloride 39175 . , . 3,3-dichbrobenzidine 34631 Lead 01051 Add -extractable compounds: Diethyl phthalate 34336 Mercury (Method 1631 E) COMER P-chloro-m-cresol ` 34452 Dimethyl phthalate 34341 Nickel 01067 2-chlorophenol 34586 2,4-dinitrotoluene 34611 Selenium 01147 2,4-dlchlorophenol 34601 2,6-dinitrotoluene C0626 Silver 01077 2,4-dimethylphenol 34606 1,2-diphenylhydrazine 34346 Thallium 61059 4,6-dinitro-o-cresol 34657 Fluoranthene C0376 Zinc 01092 2,4-dinitrophenol 34616 Fluorene 34381 Cyanide 00720 2-nitrophenol 34591 Hexachlorobenzene C0700 Total phenolic compounds 32730 4-nitrophenol 34646 Hexachlorobutadiene 39702 Volatile organic compounds. Pentachlorophenol 39032 Hexachlorocyclo-pentadiene 34386 Acroleln 34210 Phenol 34694 Hexachloroethane 34396 Acrytonitrile 34215 2,4,"chlorophenol 34621 Indeno(1,2,3-cd)pyrene 34403 Benzene 34030 ,Base -neutral compounds: Isophorone 34408 Bromoform 32104 Acenaphthene 34205 Naphthalene 34696 Carbon tetrachloride 32102 Acenaphthylene 34200 Nitrobenzene 34447 Chlorobenzene 34301 Anthracene CO220 N-nitrosodi-n-propylamine 34428 Chlorodibromomethane 34306 Benzidine 39120 N-nitrosodimethylamine 34438 Chloroethane 85811 Benzo(a)anthracene 34526 N-nitrosodiphenylamine 34433 2-chloroethyl vinyl ether 34576 Benzo(a)pyrene 34247 Phenanthrene 34461 Chloroform 32106 3,4 benzofluoranthene 34230 Pyrene 34469 Dichlorobromomethane 32101 Benzo(ghi)perylene 34521 1,2,4-tdchlorobenzene 34551 1,1-dichloroethane 34496 Benzo(k)fluoranthene 34242 Page 8of14 Permit NCO026123 Reporting. Test results shall be reported electronically via eDMR or on DWR Form — DMR-PPA1 (or on a form approved by the Director) by December 31 s' of each designated sampling year. The report shall be submitted to the following address: NC DEQ / DWR / Central Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that Municipal facilities that are subject to the Effluent Pollutant Scan requirements listed above are also subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.210)(5) and EPA Municipal Application Form 2A. The US EPA requires four (4) toxicity tests for a test organism other than the test species currently required in this permit. The second species tests should be conducted either quarterly for a 12-month period prior to submittal of the permit renewal application, or four tests performed at least annually in the four and one-half, year period prior to the application. The second species tests must be multiple concentration (5 concentrations plus the control). These tests shall be performed for acute or chronic toxicity, whichever is specified in this permit. POTWs performing NPDES chronic Ceriodaphnia testing should _perform chronic Fathead-: minnow testing. POTWs performing NPDES acute Fathead Minnow testing should perform acute Gvriodaphnia testing. POTWs performing NPDES chronic Mysid shrimp testing should perform :chronic Silverside Minnow testing. The second species toxicity test results shall be filed with the Aquatic Toxicology Branch at the following address: NC DEQ / DWR, Water: Sciences "Se Branch �1621-Mail Service. Center, Raleigh, North Carolina 27699-1621 Contact the Division's Aquatic Toxicology . Branch :at 919-743-8401 for guidance on conducting the additional toxicity ; tests and reporting requirements. Results should also be summarized in Part E (Toxicity Testing Data)" of EPA Municipal Application Form 2A, when submitting the permit renewal application to the NPDES Permitting Unit. Page 9 of 14 Permit NCO026123 A. (4.) MERCURY MINIMIZATION PLAN (MMP) [NCGS 143-215.1 (b)] The Permittee shall develop and implement a mercury minimization plan during this permit term. The MMP shall be developed within 180 days of the permit effective date, and shall be available for inspection on -site. A sample MMP was developed through a stakeholder review process and has been placed on the Division website for guidance (httt)s://dgq.ne.Lov/document/nc-model-mercuDL minimization-plan-dwr-npdes-swp-20130801). The MMP should place emphasis on identification of mercury contributors and goals for reduction. Results shall be summarized and submitted with the next permit renewal. Performance of the Mercury Minimization Plan will meet the requirements of the TMDL (Total Maximum Daily Load) for mercury approved by USEPA on October 12, 2012, unless and until a Waste Load Allocation specific to this facility is developed and this NPDES permit is amended to require further actions to address the Waste Load Allocation. A. (5.) NUTRIENT RE -OPENER [NCGS 143-215.1 (b)] Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II sections B-12 and B-13 of this permit, the Director of DWQ may reopen this permit to require supplemental nutrient monitoring of the discharge. The purpose of the additional monitoring will be to support water quality modeling efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan developed jointly by the Division and affected stakeholders. In addition, the results of water quality modeling may require that limits for total nitrogen and total phosphorus be imposed in this permit upon renewal. Page 10 of 14 Permit N00026123 A. (6.) SCHEDULE OF COMPLIANCE FOR 1,4-DIOXANE LIMITATIONS [G.S. 143-215.1(b)] 1. Within one (1) year from the effective day of the permit, the Permittee shall submit to the Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to be taken to achieve compliance with the 1,4-Dioxane limitation listed in Section A. (1.), which includes specific dates for completion or implementation of each action. 2. Within two (2) years from the effective date of the permit, the Permittee shall submit a report to the Division summarizing actions taken during the previous year to achieve compliance with the 1,4-Dioxane limitation. The actions shall be in accordance with the Corrective Action Plan submitted and approved by DWR. 3. The Permittee shall achieve compliance with the 1,4-Di6xane .limitation specified in Section A. (1.) within three (3) years of the effective date of this permit. Upon approval of the Corrective Action Plan by the Division, the report and actions_ become an enforceable part of this permit. Any modifications to the schedule shall ,be requested to the Division at least ninety (90) days before the deadline. Modifications to the schedule in excess :of four (4),months will be "subject to public notice. Corrective Action Plan and Reports shallinclude the owner's name, NPDES permit number and Permittee contact person, and shall be submitted to: (1) NCDEQ / Division of Water Quality (2) NCDEQ / Division of Water Quality NPDES Permitting, Winston-Salem Regional Office 1617 Mail Service "Gfenter 450 West Hanes Mill Road, Suite 300 Raleigh, NC 27699-1617 Winston-Salem, NC 27105 Page 11 of 14 Permit NCO026123 A. (7.) ELECTRONIC REPORTING OF MONITORING REPORTS [NCGS 143-215.1 (b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This Section supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Repordns Requirements (Supersedes Section; D. (2.) and Section E. f53 (a)1 The Permittee shall report discharge monitoring data electronically using theN, C DWR's Electronic Discharge Monitoring Report (eDMR) internet application; Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. `The'`,-eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required .to :submit all discharge monitoring data to the state electronically using `eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DEQ / DWRJ Water Quality Permitting Section Attn: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting" section below. Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring data and reports, when applicable: Page 12 of 14 Permit NC0026123 • Sewer Overflow/Bypass Event Reports; • Pretreatment Program Annual Reports; and • Clean Water Act (CWA) Section 316(b) Annual Reports. The Permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). 2. Electronic Submissions In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each electronic submission. The permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: https•//www federalre2ister gov/documents/2015/10/22/2015- 24954/national-pollutant-discharge-elimination-system-npdes-electronic-reporting-rule Electronic submissions must start by the dates listed in the "Reporting Requirements" section above. 3. How to Request a Waiver from Electronic Reaortina The Permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: http://deci.nc.gov/about/divisions/water-resources/edmr Page 13 of 14 Permit NCO026123 4. Sianatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)l All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (I1.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (I1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: btti)://deg.ne.gov/about/divisions/water-resources/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: V certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " 5. Records Retention [Supplements Section D. (6.)l The Permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Page 14 of 14 it 7 T L�. 11 /\ O \� J 7 :v i' +�s< r i v ( J Downstream (D1 B4890000 10 �1 '•� AsheboroWWiP j n and Outfall 001 " �t 4 Upstream (U) 84870000 ft U 7.4 Wes,, 1. Facility = , Location not to scale Lort I Randolph County Fact Sheet NPDES Permit No. NCOO26123 Permit Writer/Email Contact: Gary Perlmutter, gary.perlmutter@ncdenr.gov Date: Month xx, 2018 Division/Branch: NC Division of Water Resources/NPDES Complex Permitting Unit Fact Sheet Template: Version 09Jan2017 Permitting Action: ® Renewal ❑ Renewal with Expansion ❑ New Discharge ❑ Modification (Fact Sheet should be tailored to mod request) Note: A complete application should include the following: • For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee • For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 21 species WET tests. • For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based on industry category. Complete applicable sections below. If not applicable, enter NA. 1. Basic Facility Information Facility Information Applicant/Facility Name: City of Asheboro/Asheboro W WTP Applicant Address: P.O. Box 1106, 146 N Church Street, Asheboro, NC 27204 Facility Address: 1032 Bonkemeyer Drive, Asheboro, NC 27203 Permitted Flow: 9 MGD Facility Type/Waste: MAJOR Municipal; 87% domestic, 13% industrial Facility Class: Class IV Treatment Units: Bar screen, Grit removal, Parshall flume, Primary clarifiers, Trickling filters, Activated sludge, Secondary clarifiers, Nitrification with aeration, Final clarifiers, Tertiary sand filters, Chlorination, De - chlorination, Cascade aeration, Sludge thickening, Digesters, Dewatering. Pretreatment Program (Y/N) Yes County: Randolph Region Winston-Salem Percentages calculated from 2016 actual industrial and total average daily flows (0.478 and 3.627 MGD, respectively). Permitted industrial flow is 0.832 MGD or 9.2% of total permitted flow. Page 1 of 14 Briefly describe theproposed permitting action and facility background: The City of Asheboro has applied for NPDES permit renewal, and submitted a renewal application dated March 21, 2016. This facility serves a population of 25,676 residents and operates a pretreatment program with 15 Significant Industrial Users (SIUs), 6 of which are Categorical Industrial Users (CIUs). CIUs include: Energizer Manufacturing, Inc. Plant 2 (CIU 461: battery manufacturing), Garco, Inc. (renamed Covanta Environmental Services, CIU 437: centralized waste management), Matlab, Inc. Plant 4 (CIU 433: metal finishing, not yet constructed), Matlab Plant 5 (CIU 433: metal finishing), Matlab Plant 8 (CIU 433: metal finishing), Matlab Plant 14 (CIU 433: metal finishing, dropped from the pretreatment program in 2016), Premier Powder Coating (CIU 433: metal finishing), and Starpet, Inc. (CIU 414: organic chemical, synthetic fibers and plastics). Non -categorical SIUs include: Acme McCrary (renamed MAS US Holdings, textiles), Bossong Hosiery (textiles), Energizer Manufacturing, Inc. Plant 1 (battery parts manufacturing), Georgia Pacific (corrugated paper products), Kayser Roth (textiles), MOM Brands (food processing), Randolph Packing (meat processing), Wells Hosiery (textiles), and Waste Management of the Carolinas Great Oak Landfill (landfill leachate). In addition, the Asheboro WWTP is receiving 1,400 gpd wastewater from the Randolph County School Bus Maintenance Garage groundwater remediation project. This is not an SIU according to ORC Ray Wiseman. The average industrial flow rate was 0.478 MGD from January through December 2016. The uncontrollable flow was 3.152 MGD for that same period. The facility has a DWR-approved Full Pretreatment Program with a Long -Term Monitoring Program (LTMP) for its SIUs. 2. Receiving Waterbody Information Receiving Waterbody Information Outfalls/Receiving Stream(s): Outfall 001 / Hasketts Creek Stream Segment: 17-12 Stream Classification: C Drainage Area (mi2): 11.6 Summer 7Q10 (cfs) 0 Winter 7Q10 (cfs): - 30Q2 (cfs): 0.2 Average Flow (cfs): 12 IWC (% effluent): 100% 303(d) listed/parameter. This stream segment is impaired for Copper (7 µg/L, AL, FW) on the final 2014 and 2016 draft 303(d) lists. Subject to TMDL/parameter: Statewide TMDL for Mercury Subbasin/HUC: 03-06-09 / 03030003 USGS Topo Quad: D19SE Randleman, NC Page 2 of 14 3. Effluent Data Summary Effluent data is summarized below for the period January 2014 through December 2017 for Outfall 001. Table 1. Effluent Data Summary Parameter Units Average Max Min Permit Limit 1 Flow MGD 3.63 13.46 1.27 MA = 9.0 MA = BOD summer mg/L 2.4 = 8.7 < 2.0 7. WA = .5 MA = 10.0 BOD winter mg/L 3.4 13.6 1.9 WA= 15.0 BOD Removal % 99.0 99.7 98.0 >_ 85 Total Suspended Solids mg/L 4.8 51.5 < 2.0 MA = 30.0 (TSS) WA = 45.0 TSS Removal % 98.7 99.7 96.7 >_ 85 Ammonia (NH3-N) mg/L 0.2 4.0 < 0.1 MA = 2.0 summer WA = 6.0 Ammonia (NH3-N) mg/L 0.9 29.5 < 0.1 MA = 4.0 winter WA = 12.0 Dissolved Oxygen mg/L 8.0 10.7 6.0 DA > 6.0 (DO) pH SU 6.9 7.9 6.0 6-9 Fecal Coliforin #/100 mL 7 > 6000 < 1 MA = 200 WA = 400 (geometric mean) Total. Residual µg/L 15.6 48 < 15.0 DM = 17 Chlorine (TRC) Temperature °C 20.5 29.7 9.5 1 Monitor only Conductivity µmhos/cm 1016 1952 238 Monitor only MA = 50 Total Chromium µg/L 6.5 26.0 < 5.0 DM = 1033 MA = 12 Total Mercury ng/L 1.7 8.5 0.8 DM=36 Total Nitrogen (TN) mg/L 13.3 27.4 2.3 Monitor only Total Kjeldahl mg/L 2.1 5.9 0.8 Monitor only Nitrogen (TKN) Nitrate/Nitrite Nitrogen mg/L 11.3 26.4 0.8 Monitor only (NO2 + NO3) Total Phosphorus (TP) mg/L 0.38 1.81 0.08 Monitor only Page 3 of 14 Dibromochloromethane µg/L 8.3 20.4 < 5.0 Monitor only Bromodichloromethane µg/L 11.7 36.2 < 5.0 Monitor only Chloride mg/L 166 300 68 Monitor only Total Copper µg/L 4.7 15.0 2.0 Monitor only Total Zinc µg/L 25.2 55.0 13.4 Monitor only MA = Monthly Average, WA = Weekly Average, DA = Daily Average, DM = Daily Maximum. 4. Instream Data Summary Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when model results for instream DO are within 1 mg/L of instream standard at full permitted flow; 2) to verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in which case instream monitoring is waived in the permit as long as coalition membership is maintained). If applicable, summarize any instream data and what instream monitoring will be proposed for this permit action: The current permit requires instream monitoring for Temperature and Dissolved Oxygen (DO) from three locations: one upstream in Hasketts Creek (U), one downstream in Hasketts Creek (DI) and one additional downstream in Deep River (D2). These locations correspond to the ambient monitoring stations B4870000 (U), B4890000 (DI), and B4920000 (132). Data from U and D2 were obtained from the Monitoring Coalition Coordinator and span from January 2013 — December-2016. Data from DI were from the Ambient Monitoring System Coordinator and span from January 2013 — July 2016. The Permittee is a member of the Upper Cape Fear River Basin Association, and instream monitoring is provisionally waived in light of their participation. Dissolved Oxygen (DO) remains a parameter of concern for aquatic life. Instream data showed that the standard of 5.0 mg/L was maintained at all stations with minima of 6.0 mg/L at U, 6.5 mg/L at D1, and 5.4 mg/L at D2. Effluent averages for September 2013 through August 2017 also were above 5.0 mg/L. The permit will continue to include instream DO monitoring. Temperature remains a parameter of concern for aquatic life. The standard maximum of 29 °C for upper piedmont and mountain waters was maintained at all stations. However, downstream temperatures exceeded the water quality standard of 2.8 °C above the natural water temperature when compared to upstream data from 2013-2016 with 8 instances of 29 measurements or 28% at DI and 10 instances of 60 measurements or 17% at D2. The facility appeared to be contributing to increases in instream temperatures. The permit will continue to include instream Temperature monitoring. Conductivity is a parameter of concern because of industrial discharges. The permit does not currently require instream monitoring, but data were available from the three stations. The data analyzed indicate that Conductivity was significantly higher at D2 than at U (t =-10.94, p < 0.0001), and substantially higher at DI. Averages are: U = 114 uS/cm, D1 = 726 uS/cm, and D2 = 222 uS/cm. Effluent Conductivity averaged 1037 uS/cm, indicating its influence on the receiving stream. Because the facility has a pretreatment program and the patterns noted above, instream monitoring of Conductivity will be added to the permit. Analysis of loading for Copper was compared for the 303(d)-listing year of 2008 through 2016. Calculated monthly average loadings (lb/day) from 2008 to 2016 show significant reduction over time (r2 = 0.485, p < Page 4 of 14 facility appeared to be adequately operated and extremely well maintained. No concerns or problems were noted during the April 1, 2015 or April 10, 2014 evaluations. One other inspection within the permit cycle, conducted on April 3, 2013, also found no concerns or problems. 6. Water Quality -Based Effluent Limitations (WQBELs) Dilution and Mixing Zones In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH). If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA Oxygen -Consuming Waste Limitations Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits (e.g., BOD = 30 mg/L for Municipals) may be appropriate if deemed more stringent based on dilution and model results. If permit limits are more stringent than TBELs, describe how limits were developed: Limitations for BOD are based on a Streeter Phelps model (Level B) for instream DO protection. No changes are proposed. Ammonia and Total Residual Chlorine Limitations Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0 mg/L (summer) and 1.8 mg/L (winter). Acute ammonia limits are derived from chronic criteria, utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals. Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection of aquatic He (17 µg/L) and capped at 28 µg/L (acute impacts). Due to analytical issues, all TRC values reported below 50 µg/L are considered compliant with their permit limit. Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: WLA calculations were run using the annual 7Q 10 of 0.0 cfs for both the summer and winter values. The resulting TRC limit is 17 µg/L, and will be maintained in the permit. The WLA resulted in more stringent ammonia limits than in the current permit (Table 2). Table 2. Proposed Ammonia-N Limits (mg/L). Season Monthly Average Weekly Average Summer 1.0 3.0 Winter 1.8 5.4 Review of DMR data from January 2014 through December 2017 revealed a few isolated exceedences with proposed monthly and weekly winter average limits (Fig. 1), suggesting upset conditions. The City expects to be able to comply with the new NH3-N limitations. Page 6 of 14 0.0001). Annual data tested statistically different among years with consistent decreases in yearly average lbs/day of copper since 2008. See Stream Impairment Analysis for Copper in attachments for data and graphs. • Effluent Copper averaged 12.04 µg/L for 2008 and 5.67 µg/L in 2016 for average monthly samples. Effluent Copper loading was 0.38 lbs/day in 2008 and 0.17 lbs/day in 2016. • Annual average effluent Total Copper concentrations were below the 7 µg/L 303(d) listing level since 2013. Due to downstream impairment for Chlorophyll a exceedances in the Deep River [stream segment 17- (10.5)dl], additional instream analysis was conducted for Inorganic Nitrogen (NO2+NO3), Total Kjeldahl Nitrogen (TKN), Total Nitrogen (TN) and Total Phosphorous (TP). See attachments for instream nutrient data summaries and graphs. • Inorganic Nitrogen values were significantly higher at D2 than at U (t = -6.39, p < 0.0001), and substantially higher at DI. Averages are: U = 0.17 mg/L, Dl = 6.95 mg/L, and D2 = 0.63 mg/L NO2+NO3. Concurrent effluent NO2+NO3 data averaged 10.6 mg/L, indicating its influence on the receiving stream. • Total Kjeldahl Nitrogen values were significantly higher in D2 than in U (t = -3.32, p = 0.001), and substantially higher at DI. Averages are: U = 0.53 mg/L, DI = 1.27 mg/L, and D2 = 0.69 mg/L TKN. Concurrent effluent TKN data averaged 2.1 mg/L, indicating its influence on the receiving stream. • Total Nitrogen values were significantly higher in D2 than in U (i = -6.54, p < 0.0001), and substantially higher at DI. Averages are: U = 0.70 mg/L, Dl = 8.22 mg/L, and D2 = 1.32 mg/L TN. Concurrent effluent TN data averaged 12.7 mg/L, indicating its influence on the receiving stream. • Total Phosphorus values were significantly higher in D2 than in U (t = 4.42, p < 0.0001), and substantially higher at D1. Averages are: U = 0.06 mg/L, D1 = 0.29 mg/L, and D2 = 0.10 mg/L TP. Concurrent effluent TP data averaged 0.36 mg/L, indicating its influence on the receiving stream. Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): YES Name of Monitoring Coalition: Upper Cape Fear River Basin Association 5. Compliance Summary Summarize the compliance record with permit effluent limits (past 5 years): The facility had no enforcements during the prior permit cycle. The facility had one limit violation for NH3-N monthly average exceedance by 6.3% during the period from January 2013 through December 2017. This exceedence resulted in a Notice of Deficiency (NOD). Summarize the compliance record with aquatic toxicity test limits and any second species test results (past 5 years): The facility passed 16 of 16 quarterly chronic toxicity tests from 2014 through 2017, as well as all four (4) second species chronic toxicity tests, sampled on 12/8/2013, 9/8/2014, 5/31/2015, and 3/14/2016, as well as one sampled on 6/5/2017. Summarize the results from the most recent compliance inspection: The last facility compliance evaluation inspection, conducted on March 13, 2017, gave the facility a very reliable rating. One compliance issue was noted for de -chlorination, where the facility was found to have a 10:1 chlorine to de -chlorination ratio. Other compliance evaluation inspections, conducted on April 1, 2015 and April 10, 2014, found that the Page 5 of 14 Asheboro WWTP Effluent NH,-N (proposed limits) • Eff WA Eff MA —• MA Limit — - - WA Limit 10 9 8 7 6 o� S I I I E 4 1 I 1 I •I 2 •"• 0 �\ryO,ti•6 O\ryO,yA 1\ryO,tib y\vO,tiS ti�~O16 O��O~� d�tiO�^ \ryOti� O\ryoti. Figure 1. Asheboro WWTP effluent monthly average (MA) and weekly average (WA) concentrations (mg/L) with their respective proposed limits for potential compliance evaluation. Reasonable Potential Analysis (RPA) for Toxicants If applicable, conduct RPA analysis and complete information below. The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level / 95% Probability; 2) assumption of zero background; 3) use of V2 detection limit for "less than" values; and 4) streamflows used for dilution consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of Instream Dissolved Metals Standards, dated June 10, 2016. A reasonable potential analysis was conducted on effluent toxicant data collected between May 2014 and May 2017 for the following parameters: arsenic, cadmium, chlorides, total chromium, copper, cyanide, lead, molybdenum, nickel, selenium, silver, dibromochloromethane, bromodichloromethane, and zinc. After review of the 3 effluent pollutant scans, the RPA was expanded to include chloroform. Pollutants of concern included toxicants with positive detections and associated water quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit: • Effluent Limit with Monitoring. The following parameters will receive a water quality -based effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water quality standards/criteria: Cyanide, Bromodichloromethane • Monitoring Only. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the maximum predicted concentration was > 50% of the allowable concentration: Chlorides, Copper, Total Chromium, Chromium VI, Silver, Dibromochloromethane o Chlorides will maintain a quarterly monitoring requirement to coincide with toxicity testing, since the EPA is currently allowing an action level for this parameter. Page 7 of 14 o Total Chromium will maintain a monthly monitoring requirement but limits will be removed as the maximum predicted value is > Cr-VI allowable concentration but < Cr-VI detection level (Instream Dissolved Metals Guidance memo, 6/10/2016). o Chromium V1 will receive a quarterly monitoring requirement for 2 yrs, to be continued if detected. o Total Silver will receive a quarterly monitoring requirement with samples analyzed to the lower reporting level of the procedure. No Limit or Monitorine: The following parameters will not receive a limit or monitoring, since they did not demonstrate reasonable potential to exceed applicable water quality standards / criteria and the maximum predicted concentration was < 50% of the allowable concentration: Arsenic, Cadmium, Lead, Molybdenum, Nickel, Selenium, Zinc and Chloroform POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for additional pollutants of concern. o The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with monitoring, since as part of a limited data set, two samples exceeded the allowable discharge concentration: NA o The following parameter(s) will receive a monitor -only requirement, since as part of a limited data set, one sample exceeded the allowable discharge concentration: NA As part of the NC 2007-2014 Water Quality Standard (WQS) Triennial Review the total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality Standards. The reasonable potential analysis using Asheboro WWTP's Total Chromium effluent data showed reasonable potential to violate the new hexavalent chromium standard. Total Chromium is made up of hexavalent and trivalent chromium. As a result, quarterly monitoring for Total Chromium and Chromium VI will be added to the permit and the Total Chromium limits will be removed. If after two years no detects of Chromium VI are found, then monitoring for that parameter will no longer be needed. If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program. Toxicity Testing Limitations Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test failure. Describe proposed toxicity test requirement: This is a Major POTW, and a chronic WET limit at 90% effluent will continue on a quarterly frequency. Mercury Statewide TMDL Evaluation There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and industrial facilities with known mercury discharges. Given the small contribution of mercury from point sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (> 1 ng/L) will receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant Page 8 of 14 of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL value (based on the NC WQS of 12 ng/L) and/or if any individual value exceeds a TBEL value of 47 ng/L. Table 2. Mercury Effluent Data Summary 2013 2014 2015 2016 2017 Number of Samples 12 12 12 12 12 Annual Average Cone. ng/L 2.0 1.6 1.1 2.1 13 Maximum Cone., ng/L 5.8 3.5 2.2 8.5 2.7 TBEL, ng/L 47 WQBEL, ng/L, 12.0 Describe proposed permit actions based on mercury evaluation: Since no annual average mercury concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury limit is required (Table 2). However, since the facility is > 2 MGD and reported quantifiable levels of mercury (> 1 ng/L), a mercury minimization plan (MMP) will be added to the permit. Other TMDL/Nutrient Management Strategy Considerations Ifapplicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within this permit: The receiving water lies in the Deep River section of the central portion of the Cape Fear River Basin, an area identified for nutrient criteria development in the North Carolina Nutrient Criteria Development Plan, Version 2.0 (NCDWR 2014). The current permit has monthly monitoring requirements for Total Nitrogen, Nitrate -nitrite Nitrogen, and Total Kj eldahl Nitrogen in recognition of a nutrient strategy for the Upper Cape Fear River in addition to surface water monitoring and reporting requirements under 15A NCAC 02B .0500. The current permit also has a nutrient re -opener Special Condition, which will be maintained. No changes are proposed. Other WOBEL Considerations Ifapplicable, describe any otherparameters ofconcern evaluatedfor WQBELs: The pollutant 1,4-Dioxane is a likely human carcinogen that is highly mobile and does not readily biodegrade in the environment. It is found in groundwater sites throughout the US, and a recent stream survey of the Cape Fear River Basin found multiple sites with elevated concentrations. Elevated concentrations in that survey were found in a site downstream of the Asheboro W WTP discharge at an average of 291 µg/L (range: 147-478 µg/L). As a result, DWR had issued a letter, dated October 31, 2017, requiring monthly effluent monitoring, to commence in December 2017 with samples analyzed using the recently EPA -approved method 624. L To date, four data points were submitted, ranging from 89-1101 µg/L (mean = 562.3 µg/L), from which an RPA found reasonable potential to exceed the NC calculated surface water criterion of 80 µg/L to protect human health in non -water supply waters. Therefore, a monthly average limit of 149 µg/L will be added to the permit with a three-year compliance schedule. If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall comply with in order to protect the designated waterbody: NA If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: A three-year compliance schedule is proposed for meeting the 1,4-Dioxane limit. Page 9 of 14 If applicable, describe any water quality standards variances proposed in accordance with NCGS 143- 215.3(e) and 15A NCAC 2B.0226for this permit renewal: NA 7. Technology -Based Effluent Limitations (TBELs) Municipals Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg1L BOD51TSS for Monthly Average, and 45 mg/L for BOD51TSSfor Weekly Average). YES If NO, provide ajustifcation for alternative limitations (e.g., waste stabilization pond). NA Are 85%removal requirementsfor BOD51TSS included in the permit? YES If NO, provide a justification (e.g., waste stabilization pond). NA 8. Antidegradation Review (New/Expanding Discharge): The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not degrade water quality. Permitting actions for new or expanding discharges require an antidegradation review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases, existing instream water uses and the level of water quality necessary to protect the existing use is maintained and protected. If applicable, describe the results of the antidegradation review, including the Engineering Alternatives Analysis (EAA) and any water quality modeling results: NA 9. Antibacksliding Review: Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL limits, or WQBELs may be less stringent based on updated RPA or dilution). Are any effluent limitations less stringent than previous permit (YESINO): YES If YES, confirm that antibacksliding provisions are not violated: NA 10. Monitoring Requirements Monitoring frequencies for NPDES permitting are established in accordance with the following regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional Page 10 of 14 Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding prohibitions would not be triggered by reductions in monitoring frequencies. No effluent parameters in the current permit have reduced monitoring frequencies. For instream monitoring, refer to Section 4. 11. Electronic Reporting Requirements The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit additional NPDES reports electronically. This permit contains the requirements for electronic reporting, consistent with Federal requirements. 12. Summary of Proposed Permitting Actions Table 3. Current Permit Conditions I and Proposed Changes Parameter Current Permit Proposed Change Basis for Condition/Change Flow MA 9.0 MGD No change 15A NCAC 2B .0505 Summer: MA 5.0 mg/L WQBEL. Based on 1995 WLA, BODS WA 7.5 mg/L No change and for protection of DO standard Winter: (15A NCAC 2B .0200). MA 10 mg/L WA 15 mg/L MA 30 mg/L TBEL. Secondary treatment TSS WA 45 mg/L No change standards / 40 CFR 133 / 15A NCAC 2B .0406. Summer: Summer: MA 2.0 mg/L MA 1.0 mg/L NHs N WA 6.0 mg/L WA 3.0 mg/L WQBEL. Based on the current Winter: Winter: WLA for protection of aquatic life. MA 4.0 mg/L MA 1.8 mg/L WA 12.0 mg/L WA 5.4 mg/L DO > 6 mg/L No change WQBEL. For protection of the DO — standard (15A NCAC 2B .0200). pH Between 6 and 9 SU No change WQBEL. WQ standard, 15A NCAC 2B .0200. Fecal Coliform MA 200 /100 mL No change WQBEL. WQ standard, 15A WA 400 /100 mL NCAC 2B .0200. Total Residual Chlorine DM 17 µg/L No change WQBEL. 15A NCAC 2B .0200 Page 11 of 14 Temperature Monitor daily No change WQBEL. 15A NCAC 2B.0200, .0500 Add instream 15A NCAC 2B.0500, added based monitoring upstream on the presence of an industrial Conductivity Monitor daily (U) and downstream pretreatment program and the 2002 (D1 and D2) Instream Conductivity and Fecal Coliform Monitoring Guidance. Monitor quarterly in WQBEL. 15A NCAC 2B.0200. Chlorides conjunction with No change Reasonable potential found. EPA Chronic Toxicity test allows action level, passing chronic toxicity tests MA 50 µg/L WQBEL. 15A NCAC 2B.0200. Total Chromium DM 1033 µg/L Quarterly monitoring NPDES permitting guidance for dissolved metals. WQBEL. 15A NCAC 2B.0200. Quarterly monitoring Reasonable potential to exceed Chromium VI No requirement for two years; to be WQS found in RPA. NPDES continued if detected permitting guidance for dissolved metals. WQBEL. 15A NCAC 2B.0200. No reasonable potential found in Total Copper Monitor quarterly No change RPA, but maximum predicted value > 50% of the allowable concentration. MA 5.0 µg/L, WQBEL. 15A NCAC 2B.0200. Cyanide No requirement DM 22.0 µg/L Reasonable potential to exceed WQS found in RPA. Remove from permit; WQBEL. Based on the statewide Total Mercury MA 12 ng/L add Mercury 2012 TMDL; monitoring DM 36 ng/L Minimization Plan conducted during PPAs and (MMP) pretreatment LIMP. Quarterly monitoring at WQBEL. 15A NCAC 2B.0200. Total Silver No requirement lower reporting level of No detects at < 5 µg/L NPDES procedure for permitting guidance for dissolved pretreatment LTMP metals WQBEL. 15A NCAC 2B.0200. No reasonable potential found in Total Zinc Monitor quarterly Remove from permit RPA, but maximum predicted value < 50% of the allowable concentration. WQBEL. EPA Nationally Recommended Water Quality Dibromochloromethane Monitor quarterly No change Criteria (NRWQC). No reasonable potential found in RPA, but maximum predicted value < 50% of the allowable concentration. Page 12 of 14 WQBEL. EPA NRWQC. Bromodichloromethane Monitor quarterly MA 31.6 µg/L Reasonable potential to exceed criterion found in RPA. 15A NCAC 2B.0500; nutrient Total Nitrogen Monitor monthly No change criteria development in the Upper Cape Fear River Basin. 15A NCAC 2B.0500; nutrient Total Kjeldahl Nitrogen Monitor monthly No change criteria development in the Upper Cape Fear River Basin. 15A NCAC 2B.0500; nutrient Nitrate/Nitrite Nitrogen Monitor monthly No change criteria development in the Upper Cape Fear River Basin. 15A NCAC 2B.0500; nutrient Total Phosphorus Monitor monthly No change criteria development in the Upper Cape Fear River Basin. Limit based on NC calculated surface water criterion to protect 1,4-Dioxane No requirement MA 149 µg/L human health in non -water supply waters of 80 µg/L. Reasonable potential to exceed criterion found in RPA. Quarterly Ceriodaphnia ubia WQBEL. No toxics in toxic Chronic Toxicity d Pass/Fail at 90 /0 No change amounts. 15A NCAC 2B.0200 and effluent 15A NCAC 2B.0500 Effluent Pollutant Scan Three times per permit cycle No change 40 CFR 122 Add effluent Revised water quality standards Total Hardness No requirement and EPA's guidelines on hardness monitoring dependent metals. Add Electronic In accordance with EPA Electronic Electronic Reporting No requirement Reporting Special Reporting Rule 2015. Condition Nutrient Reopener for Special Condition No change Upper Cape Fear River nutrient TN and TP strategy requirement. MGD = Million gallons per day, MA = Monthly Average, WA = Weekly Average, DM = Daily Max. 13. Public Notice Schedule Permit to Public Notice: mm/dd/2018 Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following the publication date of the public notice. Any request for a public hearing shall be submitted to the Page 13 of 14 Director within the 30 days comment period indicating the interest of the party filing such request and the reasons why a hearing is warranted. 14. Fact Sheet Addendum (if applicable) Were there any changes made since the Draft Permit was public noticed (Yes/No): NO If Yes, list changes and their basis below: NA 15. Fact Sheet Attachments (if applicable) • Pretreatment Information Request form, completed • Effluent parameter trend charts and summary statistics • Final 2014 NC 303(d) list, page 7 • Instream parameter trend charts and summary statistics • Monitoring Report (MR) Violations page • Whole Effluent Toxicity and Self -Monitoring Summary, page 6 • Compliance Evaluation Inspection reports, March 13, 2017 and July 7, 2016 • IWC Calculations sheet (waste load allocation for TRC and NH3-N) • Ammonia -Nitrogen Effluent Evaluation chart • RPA Spreadsheet Summary and dissolved to total metal calculator • Effluent Copper Loading analysis • Dissolved Metals Implementation — Freshwater Standards fact sheet memo • Mercury WQBEL/TBEL evaluation Page 14 of 14 Water Resources ENVIRONMENT At OUSU tY Mr. John N. Ogbum, III City Manager City of Asheboro P.O. Box 1106 146 N Church Street Asheboro, NC 27204 ROY COOPER MICHAEL S. REGAN S. JAY ZIMMERMAN n;,, u. October 31, 2017 Subject: Additional Monitoring Requirement Asheboro WWTP NPDES Permit No. NCO026123 Dear Mr. Ogbum, As you are aware the state has been sampling and investigating sources of 1,4 dioxane in the Cape Fear River Basin. Sampling performed downstream of the Asheboro W WTP has shown high levels of this contaminant. Pursuant to 15A NCAC 02B .0505 and .0508 the Division is requiring permitted POTWs to sample for 1,4 dioxane in their plants effluent once per month using the recently approved EPA Test Method 624.1 promulgated in the 2017 Methods Update Rule. Monthly effluent sampling for the Asheboro W WTP NCO047384 at Outfall 001 shall commence in December 2017 and results shall be submitted on the POTW's Discharge Monitoring Reports. To discuss test procedures and find a lab certified to perform this updated test method please contact Dana Satterwhite, Environmental Program Supervisor III, at 919 733 3908 ext. 202 or via email at dana.satterwhite(�ncdenr, eov. If you have any questions, please contact me at (919) 807-6309 or at my email address 6eff poupartknedem.gov. Sincerely, Jeff Poupart Water Quality Permitting Section Chief Division of Water Resources cc: Jay Zimmerman, Director, DWR Julie Grzyb, NPDES Complex Permitting, DWR Mike Rhoney, Water Resource Director, Asheboro mrhoneyuuciasheboromc.us Michelle Dawes MDAWES(rdci.ashcboro.nc.us Dana Satterwhite, Environmental Program Supervisor III, DWR dana.sauerwhiteramcdem.¢ov Chris Johnson, Water Sciences Section, DWR chris.iohnson(ancdennuov George Smith, Assistant Regional Supervisor, DWR WSRO george.smith(a,,ncdenceov Sateaf NoMCamlin- Embannienral Quality l Water Resources 1617 Mail Service Center I Raleigh. North Carolina 27699.1617 9197079000 I I4J k �-- --r Weaver, Charles From: Mike Wiseman <mwiseman@ci.asheboro.nc.us> Sent: Friday, March 03, 2017 3:14 PM To: Weaver, Charles Subject: Re: likelihood of nutrient limits in NC0026123 renewal Attachments: image001.png Charles, Thank you very much for looking in to this matter for me. The info you provided helps me out tremendously with future planning. Hope you have a great weekend. Thanks, Mike Wiseman Sent from my Verizon Wireless 4G LTE DROID "Weaver, Charles" <charles.weaver@ncdenr.gov> wrote: Mike — I discussed the Cape Fear nutrient issues with Mike Templeton this morning. Mike is our in-house coordinator for nutrient issues as they are handled in NPDES wastewater permits. It is highly unlikely that the permit renewal for NC0026123 will contain nutrient limits. The existing nutrient rules were challenged by the Legislature via HB 1030 last year, and the legal ramifications of that challenge have not been resolved.. Furthermore, the Division's Scientific Advisory group is just now planning a review of Upper Cape Fear data. The review may one day lead to a revised nutrient policy for the Upper Cape Fear, but not this year. We commend you and your staff for the pilot nutrient removal program you have already attempted, and recommend that you continue to explore means of nutrient reduction that can be achieved with the components already installed. Let me know if you have additional questions. Charles H. Weaver Environmental Specialist N.C. Division of Water Resources N.C. Department of Environmental Quality 919-807-6391 charles.weaver@ncdenr.gov<mailto:charles.weaver@ncdenrgov> (physical address) 512 North Salisbury Street, Raleigh, NC 27604 (mailing address)1617 Mail Service Center, Raleigh, NC 27699-1617 [cid:image001.png@01D105A3.26AD8850] Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. .,; State of North Carolina Division of Water Resources Water Quality Regional Operations Section Environmental Staff Report Quality July 5, 2016 To: NPDES_Unit Permit No.: NCO026123 Attn: Charles Weaver Facility name: City of Asheboro From: George Smith Winston-Salem Regional Office I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? ® Yes or ❑ No a. Date of site visit: June 29, 2016 b. Site visit conducted by: George Smith & Justin Henderson c. Inspection report attached? ® Yes or ❑ No RECEIVE0/NCDE9/DWR d. Person contacted: Michael Wiseman contact information: (336) 672-0892 ext. JUL 12 1016 Water quality Permit ft Section e. Driving directions: Hwy 421 220 south from Greensboro, Pineview exit, left on Pineview St., riaht at next light, left on Hub Moms Rd, left on Bonkemever Rd. 2. Discharge Point(s): Latitude: 35' 46' 0.4" N Longitude: 79' 47' 5.8" W 3. Receiving stream or affected surface waters: Classification: Haskett Creek, C River Basin and Subbasin No.: Cape Fear, 03-06-09 Describe receiving stream features and pertinent downstream uses: Class C support use (rural use). H. PROPOSED FACILITIES: NEW APPLICATIONS 1. Facility Classification: 4 (based on permitted flow) Proposed flow: Does not apply. There are no new treatment units or modifications. Current permitted flow: 9.0 MGD 2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ® No If no, explain: No new treatment units 3. Possible toxic impacts to surface waters: None 4. Pretreatment Program (POTWs only): Program is operated in an excellent manner. Coordinator is Michelle Dawes III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A ORC: Michael Wiseman Certificate #: 987680 Backup ORC: Chris Schadt Certificate #: 13500 FORM: WQROSSR04-14 Page I oft 2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No If no, please explain: Description of existing facilities: same as described in the current permit. Proposed flow: N/A Current permitted flow: 9.0 MGD Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc.) See attached CEI 3. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No If no, please explain: Check all that apply: ® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC ❑ Notice(s).of violation ❑ Currently under SOC ❑ Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) Attached CEI 4. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑ Yes ®No ❑ N/A If yes, please explain: Possible toxic impacts to surface waters: None 6. Pretreatment Program (POTWs only): operated in an excellent manner IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS The facility is operated in an excellent manner. V. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No If yes, please explain: 2. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office ❑ Hold, pending review of draft permit by regional office ❑ Issue upon receipt of needed additional information ® Issue ❑ Deny (Please state reasons: ) 3. Signature of report preparer: Signature of regional supervisor: Date: 7 G 116 FORM: WQROSSR 04-14 Page 2 of 2 WarerResources ENVIRONMENTAL QUALITY Mr. Michael D. Rhoney, City of Asheboro P.O. Box 1106 Asheboro, NC 27204 July 7, 2016 Water Resources Director SUBJECT: Compliance Evaluation Inspection (CEl) City of Asheboro W WTP NPDES Permit No. NCO026123 Randolph County Dear Mr. Rhoney: PAT :MCCRoRY DONALD R. VAN DER VAART Ne"'I" S. JAY ZIMMERMAN Omvor ItECEI VED/NCDEQ/DWIZ JUL 12 2016 Water Quality Permitting Sectign On June 29, 2016, Justin Henderson and George Smith, both of this office, met with Mike Wiseman, Operator in Responsible Charge (ORC), to perform a Compliance Evaluation Inspection at the City of Asheboro's wastewater treatment facility. This type of inspection consists primarily of two parts: an in -office review of facility files and self -monitoring data and an on -site inspection of the facility and its files. This particular inspection evaluated nine (9) areas, and observations from each area are addressed below: Permit A copy of the current NPDES permit was available on site for review during the inspection. The current permit became effective August 1, 2012 and expires September 30, 2016. The 9.0 MGD facility consists of six rectangular primary clarifiers, three tackling filters, four secondary clarifiers, two aeration basins, a tertiary sand filter system, and three final clarifiers. The plant has two anaerobic digesters, a sludge press, and drying beds. One circular primary clarifier is used to store press filtrate. The facility has a 600kW generator that has capability to operate the entire plant during a power outage. The generator is tested for one hour each month under load. Asheboro is under a contract with Randolph Oil to supply fuel. Self -Monitoring Program Monthly Discharge Monitoring Reports (DMRs) were reviewed for the period November 2015 through March 2016. The facility was found to be in compliance with all effluent limits and reporting requirements during this time period. All sampling was performed per the frequencies specified in the permit. Daily composite sampling is required at this facility. Flow proportioned composite samples are pumped directly into the laboratory where they are collected into refrigerated containers at 4.6 'C. Effluent sampling is performed by a flow proportional method at 200 mL every 100,00 gallons (40 pluses). State of North Carolina I Enwonmental Quality I µlater Remurces 450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 Phone: 336-T75-98001 Internet .ncdenrgov Data verification was performed for the effluent: BOD, Ammonia, Fecal Coliform on the January 2016 DMR. There were no errors. Laboratory The City of Asheboro has an on -site laboratory at the plant, which performs most of the analyses for permitting purposes. Other parameters are performed by Pace Analytical (Chronic Toxicity) and Environment One (annual pollutant analysis). Flow Measurement An ultrasonic meter is used to report effluent flow on the monthly DMRs. Instrumentation Services, Inc. calibrates the effluent flow meter quarterly. The last calibration was performed on April 7, 2016, and documentation was available upon request. Operations & Maintenance Operator in Responsible Charge is Mike Wiseman (Grade IV); Back -Up ORC is Chris Schadt (Grade IV). Sodium hypochlorite is added along the weirs of the final clarifiers. Sodium bisulfate is added in the chlorine contact chamber for dechlorination prior to discharge. The plant accepts process sugar water from Malt-O-Meal Brands (a local cereal manufacturer) to assist with Biological Nutrient Removal. The facility monitors the microorganisms on a frequent basis to documents the operations of the plant. The MLSS is approximately 2300 mg/L. The dissolved oxygen in the aeration basins is 1.25 to 1.758 mg/L. The blankets in the 15-foot deep clarifiers are 2 feet The facility appeared to be competently operated and extremely well maintained. No concerns or problems were noted. Facility Site Review There are two Archimedes screws at the influent lift station, both are operational. The Duperon automatic 3/8 inch barscreen is working very well. Grit removal is consisting of a vortex with an air lift to a hopper. All are in good working order. The six (6) primary rectangular, which are sequentially scraped. They are on timers. There is one (1) circular clarifier. The three (3) trickling filters have a good coating of biological mass and there is an even distribution of wastewater. The secondary clarifiers are discharging a clear effluent with no solids. The effluent is pumped with four 75 horse power pumps to the aeration basins. The pumps have no seal leaks and are in good order. The circular aeration basins have a traveling arm with fine bubble diffusers. There is no foam, no odor, and good flocking. The instantaneous flow at the time of the inspection was 3.1 MGD. Records/Reports The Discharge Monitoring Reports (DMRs), field sheets, chain of custody forms, and lab data are kept and maintained according to the permit. All required information was readily available, complete, and current. The following logs are maintained: Operators, Preventive Maintenance, Lab Tests (time of sample receipt/ analysis), Chemical Inventory, Process (documents performance of each treatment unit). These are considered to be excellent forms of documentation. The Annual Performance Report for calendar year 2015 was prepared as required, and a copy was available during the inspection. Effluent/Receiving Waters The effluent is discharged into Hasketts Creek (Class C) in the Cape Fear River Basin. The effluent appeared clear with no traceable solids. The creek appeared to have no impacts. Sludge Handling & Disposal Solids from the anaerobic digester are dewatered by the on -site belt press prior to land application covered under permit WQ0001684. EMA Resources land applied residuals from the facility. The inspected facility was found to be in compliance. Mr. Wiseman and his staff operate the facility in an outstanding manner. Please refer to the attached checklist for specific details. If you have any questions concerning this report, please contact Justin Henderson or me at (336) 776- 9800. Sincerely, `/Sherri V Knight, PE, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ cc: WSRO Files NPDES Unit —Charles Weaver United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN 1 2 I!j 3 I N00026123 I11 12 16/06/29 17 18 L � j 19 [ s 1 20I ] 211_1_I_1_ I I I I I I 11 l a 1 1 l I I I I I I I 1 1 l l l l l I I I I 11 I I I I 1 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67 70 1aj 71 [2_j 72 I N I 73[I7475Ill 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Kermit Number) 08:15AM 16J06129 12/08/01 Asheboro WWTP 1032 Bonkemeyer Dr Exit Time/Date Permit Expiration Date Asheboro NC 27203 10:30AM 16/06/29 16/09/30 Names) of Onsite Representafive(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Michael Ray Wiseman/ORC/336-672-0892/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted John N Ogbum,PO Box 1106 Asheboro NC 272041106//336-626-1213/3366261218 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance E Records/Reports Self -Monitoring Program N Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Names) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Justin L henderson WSRO WQ11336-776-9701/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date 17 lr� EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# Permit: NCO026123 Owner - Facility: Asheboro WWTP Inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted'a new ❑ ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ M ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ❑ ❑ ❑ Is all required information readily available, complete and current? ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? M ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ 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? M ❑ ❑ ❑ 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? M ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? M ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? M ❑ ❑ ❑ Page# 3 Permit: NC0026123 Owner - Facility: Asheboro WWTP Inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? 0 ❑ ❑ ❑ Comment: Flow Measurement -.Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? M ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? N ❑ ❑ ❑ Is disposal of screening in compliance? ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Grit Removal Yes No NA NE Type of grit removal a.Manual ❑ b.Mechanical Is the grit free of excessive organic matter? ❑ ❑ ❑ Is the grit free of excessive odor? 0 ❑ ❑ ❑ # Is disposal of grit in compliance? M ❑ ❑ ❑ Comment: Primary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? M ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ 0 ❑ Are weirs level? 0 ❑ ❑ ❑ Page# 4 Permit: NC0026123 Owner - Facility: Asheboro WVVrP inspection Date: 06/29/2016 Inspection Type: Compliance Evaluation Primary Clarifier Yes No NA NE 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? ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? ❑ ❑ ❑ M Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) N ❑ ❑ ❑ Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? N ❑ ❑ ❑ Is the site free of evidence of short-circuiting? N ❑ ❑ ❑ Is scum removal adequate? M ❑ ❑ ❑ Is the site free of excessive floating sludge? M ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) 0 ❑ ❑ ❑ Comment: Trickling Filter Yes No NA NE Is the filter free of ponding? 0 ❑ ❑ ❑ Is the filter free of leaks at the center column of filter's distribution arms? 0 ❑ ❑ ❑ Is the distribution of flow even from the distribution arms? M ❑ ❑ ❑ Is the filter free of uneven or discolored growth? 0 ❑ ❑ ❑ Is the filter free of sloughing of excessive growth? 0 ❑ ❑ ❑ Are the filter's distribution arms orifices free of clogging? 0 ❑ ❑ ❑ Is the filter free of excessive filter flies, worms or snails? M ❑ ❑ ❑ Comment: Page# 5 Permit: NCO026123 Inspection Date: 06/29/2016 Owner - Facility: Asheboro WWTP Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? M ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ■ ❑ ❑ ❑ Comment: De -chlorination Yes No NA NE Type of system ? Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ 0 ❑ ❑ Is storage appropriate for cylinders? ❑ ❑ M ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑ Comment: 10:1 chlorine to de-chlor Are the tablets the proper size and type? ❑ ❑ 0 ❑ Are tablet de -chlorinators operational? ❑ ❑ 0 ❑ Number of tubes in use? 0 Comment: no comment Disinfection -Liquid Yes No NA NE Is there adequate reserve supply of disinfectant? M ❑ ❑ ❑ (Sodium Hypochlorite) Is pump feed system operational? 0 ❑ ❑ ❑ Is bulk storage tank containment area adequate? (free of leaks/open drains) 0 ❑ ❑ ❑ Is the level of chlorine residual acceptable? ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Page# 6 Permit: NCO026123 Inspection Date: 06/29/2016 Owner - Facility: Asheboro WWTP Inspection Type: Compliance Evaluation Effluent Sampling Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Yes No NA NE ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 7