NC0088200_Draft Permit_20240416

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Dfrector
Michael Brandt, City Manager
City of Thomasville
PO Box 368
Thomasville, NC 27361
Dear Mr. Brandt:
NORTH CAROLINA
Environmental Quality
April 16, 2024
Subject: Draft NPDES Permit NCO088200
Thomasville WTP
Grade I Physical Chemical WPCS
Davidson County
Attached 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. We
understand from your renewal application that there have been no treatment system changes. There are
a few changes in the draft attached here from the existing permit. These changes are summarized below.
• Regulatory Citations - Language has been added where necessary in the permit to provide regulatory
citations for permit requirements.
• Electronic Reporting - Permit language has been modified to be consistent with the finalization of
federal requirements for electronic reporting.
• Language on the Supplement to Permit Cover Sheet has been updated. This includes modification of
the treatment system components and update of the maximum monthly average flow.
• Total Copper - Your previous permit set permit limits for copper. The Reasonable Potential Analysis
(RPA) using data from this permit cycle showed no reasonable potential for the discharge to result in
water quality impacts. Based on the analysis the limits for copper established in the last permit have
been removed from the draft permit but monitoring requirements will remain.
• Whole Effluent Toxicity (WET) — Whole Effluent Toxicity testing has been changed from monitoring
to a Pass/Fail limit per the updated permitting strategy for water treatment plants. Language in the
Effluent Table and Section A.(2.) concerning these requirements has been updated. Please note the
requirements in Section A.(2.) for response to a failed test and parameter codes for reporting pass/fail
and chronic value results.
• Units of Measure — Please assure that your eDMR values are reported in the appropriate units of
measure as outlined in the permit [see Effluent Table Section A.(1)]. Over the previous permit cycle
some of your data for Fluoride, for example, was reported as mg/L rather than the required µg/L.
• Map Update — The permit map and descriptive information on the permit map have been updated.
• Permit Expiration — Date has been changed to July 31, 2029 to allow for a full permit term.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROONA
Depaft em919.707.9000

Michael Brandt
Thomasville WTP Draft Renewal
Page 2
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 I). The conditions are the same as in your current permit. The latest
version of the standard conditions is available at https://bit.ly/3k5NFaL and can be viewed online or
downloaded as a PDF file.
Concurrent with this notification the Division is publishing a notice in a newspaper having general
circulation in the Davidson County area soliciting public comments on this draft permit.
Please provide any written comments you may have to me no later than 30 days after receipt of this
draft permit.
Please note that the receiving stream, Rich Fork Creek, is listed as impaired in the 2022 NC 303(d)
Impaired Waters Integrated Report. Impairment is for Fish Community Bioclassification.
Addressing impaired waters is a high priority for the Division, and instream data will continue to be
evaluated. If there is noncompliance with permitted effluent limits and instream impairment can be
attributed to your facility, then mitigative measures may be required.
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 contact me by email at [e-mail]. At this time, contact by email is the most
effective method. If we need to set up a call to discuss any issues, we can set that up through email.
Sincerely,
2-1 1 1=1 I
Bradley Bennett
Compliance and Expedited Permitting Unit
cc: NPDES Files - electronic
Winston-Salem Regional Office / Water Quality — electronic
Operator Certification Program/Jeffrey Talbott — electronic
Aquatic Toxicology / Cindy Moore and Molly Nicholson - Electronic

Draft Permit NCO088200
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
NPDES
In compliance with the 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,
City of Thomasville
is hereby authorized to discharge wastewater from a facility located at the
Thomasville WTP
Old Lexington Road
Thomasville
Davidson County
to receiving waters designated as an unnamed tributary to Rich Fork Creek in subbasin 03-07-07 of the
Yadkin -Pee Dee 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 July 31, 2029.
If the permittee intends to continue discharging at the facility beyond the term of this permit, a renewal
application must be submitted no later than February 1, 2029 (180 days before the expiration of this permit)
Signed this day
John E. Hennessy
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 8

Draft Permit NCO088200
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 issuedpermit 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 Thomasville
is hereby authorized to:
Continue to operate a conventional water treatment plant with a discharge of wastewaters from filter
backwash generated during the flocculation process and settled in sedimentation basins. This water
treatment plant currently has a design potable flowrate of 6.0 MGD and a maximum, monthly
average wastewater discharge of 0.234 MGD. This facility is located at the City of Thomasville
WTP located on Old Lexington Road, near Thomasville, in Davidson County. Water and wastewater
treatment consists of:
■ Flow meter
■ Raw Water pump station
■ Flash mixer
■ Flocculator CN
■ Sedimentation basins and filters
■ Post chemical mixing box
■ Clearwells
■ Sludge pumping building
■ 14,000 ft of 8" force main
■ Alum sludge settling lagoon
■ Dechlorination
■ Decanting structure
■ Screen on discharge pipe
2. Discharge of filter -backwash wastewater from said treatment works via Outfall 001, at the location
specified on the attached map to an unnamed tributary to Rich Fork Creek [Stream Index: 12-119-7],
a waterbody currently classified C waters in subbasin 03-07-07 [HUC: 030401030203] of the
Yadkin -Pee Dee River Basin.
Page 2 of 8

Draft Permit NCO088200
PART I.
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 0213.0400 et seq., 15A NCAC 0213.0500 et seq.]
Grade I Physical Chemical WPCS [15A NCAC 08G .0306]
Beginning with the effective date of this permit and lasting until expiration, the Permittee is authorized to
discharge treated wastewater from Outfall 001. Such discharges shall be limited and monitored' by the
Permittee as specified below:
EFFLUENT CHARACTERISTICS
Parameter Code
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow (MGD) 50050
Monitor & Report
Continuous
Recording
Effluent
Total Suspended Solids C0530
30 mg/L
45 mg/L
2/Month
Grab
Effluent
pH 00400
>6.Oand <9.0
— —
standard units
2/Month
Grab
Effluent
Total Residual Chlorine 2 50060
117 pg/L
2/Month
Grab
Effluent
Turbidity (NTU) 00070
Monitor & Report
Monthly
Grab
Effluent
Aluminum (pg/L) 01105
Monitor & Report
Quarterly
Grab
Effluent
Total Copper 01042
Monitor & Report
Quarterly
Grab
Effluent
Fluoride (pg/L) 00951
Monitor & Report
Quarterly
Grab
Effluent
Total Zinc (fag/L) 01092
Monitor & Report
Quarterly
Grab
Effluent
Total Nitrogen (TN) (mg/L) C0600
Monitor & Report
Quarterly
Grab
Effluent
Total Phosphorus (TP) (mg/L) C0665
Monitor & Report
Quarterly
Grab
Effluent
Total Hardness (as CaCO3) (mg/L) 00900
Monitor & Report
Quarterly
Grab
Effluent
Whole Effluent Toxicity Testing 3 TGP3B
Pass/Fail
Quarterly
Grab
Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR
application system [see Section A. (3)].
2. 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.
3. Chronic Toxicity (Ceriodaphnia dubia) 7-day Pass/Fail test at 90% in January, April, July and October
[see Section A. (2)].
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER
THAN TRACE AMOUNTS.
Page 3 of 8

Draft Permit NCO088200
A. (2) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0200 et seq.] [15A NCAC 02B .0500 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," (Revised December 2010, or
subsequent versions) or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised December 2010, or subsequent versions). The tests will be performed during the months of
January, April, July, and October. These months signify the first month of each three-month toxicity
testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -December 2010, or subsequent versions).
All toxicity testing results required as part of this permit condition will be entered electronically using
the Division's eDMR system for the months in which tests were performed, using the parameter code
TGP313 for the pass/fail results and THP311 for the Chronic Value. Additionally, DWR Form AT-3
(original) is to be sent to the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Or, results can be sent to the email, ATForms.ATB(adeq.nc.gov.
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 4 of 8

Draft Permit NCO088200
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.
A. (3) 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 special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. The eDMR system may be
accessed at: https://deq.nc.gov/about/divisions/water-resources/edmr.
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
following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Page 5 of 8

Draft Permit NC0088200
Raleigh, North Carolina 27699-1617
See "How to Request a Waiver from Electronic Reporting" section below.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
reported via the eDMR system no later than the last calendar day of the month following the
completed reporting period. 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, 2025, 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.federalre ig ster.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 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
Page 6 of 8

Draft Permit NC0088200
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:
hllp://deq.ne.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit
the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
Page 7 of 8

City of Thomasville
Thomasville WTP
Receiving Stream:
UT to Rich Fork Creek Stream Class: C
River Basin:
Yadkin Pee -Dee Sub -Basin: 03-07-07
Outfall Latitude:
35' 52' 22" Outfall Longitude: 80' 09' 01"
Stream Segment
12-119-7 HUC#: 030401030203
Grid/Quad:
D185W / Lexington East County: Davidson
Facility
Location
(not to scale) r
North NPDES Permit NCO088200
Page 8