NC0088200_Fact Sheet_20240603

NCDEQ/DWR
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO088200
2024 Renewal
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns).
Facility and Stream Information
Applicant/ Facility Name:
City of Thomasville / Thomasville WTP
Applicant Address:
PO Box 368, Thomasville, NC 27361
Facility Address:
200 Old Lexington Road, Thomasville, NC 27360
Facility Class/Permit Status:
Grade I Physical -Chemical WPCS / Renewal
Permitted Flow
t
(as built)
Monthly
Avg
0.234 MGD
Type of Waste
100% Industrial
Wastewater from filter backwash
and Alum Lagoon.
Avg Flow -
0.139 MGD
Receiving Stream
UT to Rich Fork Creek
Stream Class ID
C 12-119-7
River Basin
Yadkin Pee -Dee
Subbasin
03-07-07
HUC
030401030203
Quad/USGS Topo
D18SW / Lexington East
7Q10 Sum Win cfs
0
30Q2 cfs
0
Avg. Stream Flow cfs
0
IWC % sum/win
100 %
County
Davidson
Regional Office
WSRO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / April 8, 2024
Does permit need daily max NH3 limits?
No
Does permit need TRC limits/language?
Yes - Already in permit
Does permit have toxicity testing?
Yes - Already in permit
Does permit have Special Conditions?
WET Requirements;
Does permit have instream monitoring?
No - discharge to zero flow
Stream on 303(d) List? For w/parameter?
Statewide Mercury, Fish Community (Biological
Integrity)
Any compliance concerns?
No Issues
Any modifications since last permit?
No modifications noted. Facility is in stage of
drying and maintaining lagoon so no discharge at
this time.
New expiration date:
July 31, 2029
FACILITY OVERVIEW:
The City of Thomasville operates a conventional water treatment plant with a discharge of wastewaters
generated during the flocculation and sedimentation process and from filter backwash. 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 on Old Lexington Road, near
Thomasville, in Davidson County.

Water and Wastewater treatment systems utilize:
■ Flow meter
■ Raw Water pump station
■ Flash mixer
■ Flocculator
■ Sedimentation basins and filters
■ Post chemical mixing box
Chemicals added during process:
■ Potassium Permanganate
■ Alum
■ Caustic Soda
■ Chlorine
■ Clearwells
■ Sludge pumping building
■ Alum sludge settling lagoon
■ Dechlorination
■ Decanting structure
■ Screen on discharge
■ Fluoride
■ Polyphosphate
■ Sodium bisulfate
Raw Water Treatment Process: (from application and historical documents)
The water treatment plant draws water from Lake Thom-a-Lex and adds alum and sometimes potassium
permanganate prior to flocculator, sedimentation basins and filters. Treatment then adds chlorine, fluoride
phosphate and caustic prior to clearwells and flow to elevated tanks for distribution.
Wastewater and Treatment Process: (from application, and historical documents)
Wastewater comes from flocculation process, sediment basins and backwash for conventional filters. The
wastewater goes alum sludge lagoon and has chlorine removed from the waste stream with ascorbic acid.
There is no further treatment of the waste at the lagoon other than detention and settling of the waste. A screen
is in place at the discharge pipe to keep large debris such as leaves from getting into the flow meter.
The outlet pipe is a significant distance to the west of the facility. Old documents in the file note 14,000 foot
pipe.
APPLICATION
The Water Treatment Plant is operated by the City of Thomasville. The application outlines a treatment process
as outlined above utilizing flocculation sedimentation, and filtration (conventional) to produce potable water
with wastewater and sediments going to an Alum Sludge Lagoon. Raw water is noted as coming from Lake
Thom-A-Lex. The application notes average flow from the alum lagoon being 0.129 to 0.136 MGD. The larger
value is noted as inaccurate due to one very large reading of over 7 MGD attributed to small fish getting past the
screen and impacting the flow meter. The application notes the following parameters as "Believed Present" Cu,
Zn, TRC, Fluoride, TN, TP, Sulfite and Al.
The application notes that the alum sludge lagoon is currently being dried and dredged with solids being
stockpiled in the lagoon until they can be disposed of at the Davidson County Landfill. During this period
wastewater from the WTP is redirected to the WWTP.
After completion of the dredging process the city expects that they can get approximately 5 - 6 more years of
use of the lagoon before it must be drained and partially dredged again. It takes about a year for solids to dry
enough to be dredged each time this occurs. Disposal of the solids from the dredging will be budgeted prior to
the expected occurrence. During the draining and dredging process alum wastes from the WTP are temporarily
diverted to the WWTP through the sewer system and solids generated from that are disposed of with WWTP
solids. Once dredging is completed alum wastes will be sent back to the lagoon.
The city indicates that preliminary planning is in the process for constructing a solids handling facility at the
WTP. It is as undetermined as to whether this might be a belt press or a centrifuge system. It is possible that
some other system might also be developed such as replacing the current lagoon with a new dual channel lined
lagoon that would allow one side to be used while one was being drained and dredged. Until this solids
Thomasville WTP Fact Sheet
NPDES Renewal 2024 — April 8, 2024
Page 2

handling facility can be designed, funded and built the alum lagoon will continue to be operated in the cycle of
use/ dredge with WWTP disposal/ use.
INSPECTION
The most recent inspection occurred on January 16, 2020. The inspection report noted the need for proper
procedures for calibrating the closed channel flow measuring device.
COMPLIANCE:
This facility has not had any enforcement action with penalties since 2008. The facility had two (2) NODs
during the permit cycle, one for a TRC violation and one for frequency violations for TP and Al monitoring. The
facility also shows as having Late/Missing GW Reports in BIMS, but the GW monitoring was previously removed
from the permit and should be taken out of BIMS.
MONITORING DATA REVIEW:
The facility has indicated no flow on their DMRs since March 2023. DMRs also indicate that the lagoon was
removed from service March 1, 2022 for maintenance and repairs - to dry sludge in preparation for sludge
removal from the lagoon. The application notes issues with inaccuracy of flow data for the February 2022
monitoring period which showed a very large flow of 7.05 MGD. The city felt the flow was impacted by small
fish that made it into the flow meter as the lagoon was being drawn down. There were a few other months of
data reported between February 2022 and March of 2023 but the permit writer has excluded these values
because they don't appear to be representative of the regular discharge. Some (April 2022) was taken directly
from the lagoon and some was discharge to remove accumulated rainwater. Data reviewed was reported
between September 2019 and January 2022.
Parameter Units
Min
Max
Avg
Permit Limit
Comments
Flow (MGD)
0.0030
2.70
0.139
-
TSS (mg/L)
< 2.5
17.30
2.94
30 MA
45 DM
pH (su)
6.30
7.70
N/A
>_ 6 and <- 9
TRC (µg/L)
7.40
53.70
26.79
17 DM
45 exceedances but only one > 50
Turbidity (NTU)
0.50
30.30
3.25
-
Total Copper (µg/L)
< 2.0
< 2.0
< 2.0
10.45 MA
14.30 DM
All values reported < 2.0
Total Aluminum (µg/L)
165.00
331.00
226.80
-
Total Fluoride (mg/L)
0.2
300.00
117.31
-
5 of 11 values converted from mg/L
Total Zinc (µg/L)
< 5.0
7.00
2.95
All but one value reported as < 5.0
Hardness (mg/L) - Effluent
28.00
44.00
35.60
-
Zero flow stream so no upstream
Total N (mg/L)
0.340
1.2
0.6
-
Total P (mg/L)
0.01
0.03
0.02
-
Whole Effluent Toxicity
N/A
N/A
N/A
-
All Tests passed
MA - Monthly Average DM - Daily Max QA -Quarterly Average DA - Daily Average Summer - April through Oct Winter - Nov through March
The data reviewed for the renewal is from September 2019 through January 2022.
REVIEW OF PERMIT MONITORING AND LIMITS:
Flow - The maximum monthly average flow from the DMRs ( sept 2019 - Jan 2022) was 0.234 MGD. This value
has been noted in the Supplement to Cover Page.
Thomasville WTP Fact Sheet
NPDES Renewal 2024 - April 8, 2024
Page 3

Whole Effluent Toxicity (WET) - The facility failed its last WET test before the last permit renewal, but passed
all tests in the most recent permit cycle. This is a conventional WTP. By WTP guidance and discussions with AT
staff these facilities should have pass/fail limit requirements. These changes have been made in the permit.
TSS and Turbidity - TSS and turbidity values have been well within acceptable ranges.
Nutrients (TN and TP) - These values have not shown any potential issues.
TRC - The facility has had a large number of TRC values that have exceeded the 17 µg/L limit, but only one
reported value has exceeded the compliance value of 50 µg/L.
Reasonable Potential Analysis (RPA) - An RPA analysis was performed for three parameters - Copper, Zinc and
Fluoride. In the 2019 permit renewal the RPA analysis showed reasonable potential for Cu and a permit limit
was added to the permit. In the most recent permit cycle all values for Cu have been reported at < 2.0 µg/L.
With the RPA analysis none of these three parameters was shown to have reasonable potential to cause an
instream water quality issue. The permit limit for Cu has be removed in the permit and monitoring frequency
for Cu will be relaxed to quarterly. Due to treatment processes, chemicals used and previous monitoring
results, monitoring for all three of these parameters will be maintained in the permit. Monitoring data for
Fluoride was reported for five (5) of eleven (11) data points as mg/L. These values were changed to µg/L for
the data and RPA evaluations and the cover letter for the draft notes the need to assure all parameters are
reported in the appropriate units.
NCG59 GENERAL PERMIT EVALUATION
The Thomasville WTP could possibly be considered for coverage under the general permit. It is a conventional
treatment system and does not technically have any of the exclusions that would restrict general permit
coverage. However, the Division notes that the facility has had failed WET results (2019) and has had reported
high Cu values in the past. It seems appropriate to maintain individual permit coverage for the facility for at
least another permit cycle to assure that general permit coverage is applicable and could be offered to the City.
FILE HISTORY REVIEW SUMMARY
May 9, 2006 - Initial NPDES Permit Issuance - The facility apparently had originally been permitted as a
non -discharge system since 1985 (WQ000O425). The non -discharge permit was for a 2.3 acre lagoon and
4.2 acre area for decant. It appears, however, that the system had never been operated this way and instead
the decant had been directly discharged. A consultant noted to the City that they could not discharge under
the non -discharge permit and the City came to the Division and ultimately made application for coverage
under an NPDES permit.
The permit had effluent conditions as follows:
Flow
TSS
SS
TRC
pH
Monitoring Parameters
MGD
m L
mL L
µ L
Standard Units
Total Iron, Total
0.2
30 / 45
0.1 / 0.2
17
Between 6 & 9
Aluminum
The facility was given 18 months to meet the TRC limit.
November 21, 2007 - Permit Modification - This modification added components to the treatment system
section including three groundwater monitoring wells, 14,000 linear feet of 8" force main to the alum
lagoon and clarified that supernatant lagoon as being proposed. Permit also added a Special Condition
section for monitoring well requirements. These changes were made to transfer conditions from the
WQ0000425 permit as it was being rescinded.
June 11, 2009 - Permit Reissuance - This permit renewal included further expansion of the components of
the treatment system and included chemical additives in the process. The permit requirements removed
Settleable Solids monitoring requirements and added a number of other parameters for monitoring and
reporting as noted in the table below:
Flow I TSS I TRC I pH Monitoring Parameters
Thomasville WTP Fact Sheet
NPDES Renewal 2024 — April 8, 2024
Page 4

0.3 30 / 4S 17 Between 6 & 9 NH3-N, Calcium, Mg, Mn, Total Zn, Fluoride, Total
Cu, Total Fe, Total Al, TN, TP and WET
The application noted that there had been no discharge from the facility since 2008. Wastewater had been
directed to the WWTP rather than the lagoon.
September 11, 2015 - Correspondence from DWR to the City advising that groundwater monitoring was no
longer required for this facility and the wells were to be abandoned according to the administrative code
requirements (2C .0113).
November 29, 2016 - Permit Renewal -This renewal included a number of permit modifications. The limit
for flow was removed and because flow is greater then 0.05MGD it was changed to continuous monitoring.
A number of monitoring requirements were removed: groundwater monitoring, Pb, Mg, Mn and Calcium
(no water quality standard); Zn and NH3-N (don't use chemicals that would introduce). Monitoring
frequency for fluoride and Cu reduced to quarterly to match WET frequency. Turbidity monitoring added to
meet US EPA requirements and effluent hardness was added (no instream due to zero flow receiving
stream. The permit also added the electronic DMR submittal requirements. The permit noted the WTP
potable water capacity of 6.0 MGD and maximum monthly discharge of 0.177 MGD. The RPA analysis was
done for Cu, Zn and Fluoride but with a very limited data set. Cu did show RP but all parameters were just
included for monitoring due to the limited data.
August 16, 2019 - Permit Renewal - The permit updated language on eDMR, outfall map, supplement to
permit cover and the system components list. Monitoring changes included reduction of frequency for
turbidity monitoring, adding Zn back to the permit based on potential for zinc orthophosphate use. The
RPA analysis showed that Cu had reasonable potential so limits were added (10.45 MA and 14.30 DM) to the
permit for Cu and monitoring increased to monthly.
PROPOSED PERMIT CHANGES:
• Updated eDMR requirements to be consistent with final EPA rule.
• Added regulatory citations throughout permit as needed.
• 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 discharge.
• Based on the results of the RPA analysis the limits for Cu have been removed and monitoring frequency
has been reduced to quarterly.
• In accordance with WTP Guidance the WET conditions for Conventional WTP should be pass/fail limited
requirements. The language in the Effluent Table and Section A.(2) for WET requirements has been
updated accordingly.
• Permit map and descriptive information on the permit map have been updated.
• Expiration date has been changed to July 31, 2029 to allow for a nearly full five year permit term.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: April 16, 2024
Permit Scheduled Effective Date: August 1, 2024
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett at
bradley.bennettPdeq.nc.gov. .
Thomasville WTP Fact Sheet
NPDES Renewal 2024 — April 8, 2024
Page 5

70097050 70939600
AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA LEXINGTON, NC April 18, 2024
DAVIDSON COUNTY
I, Lynn Bowers OF THE DISPATCH, A NEWSPAPER PUBLISHED IN THE CITY OF LEXINGTON, COUNTY AND STATE
AFORESAID, BEING DULY SWORN, SAYS THE FOREGOING LEGAL OF WHICH THE ATTACHED IS A TRUE COPY,
WAS PUBLISHED IN SAID NEWSPAPER ONCE A WEEK FOR 1 WEEK, BEGINNING THE 18th DAY OF April, 2024
PUBLICATION FEE: $ 97.74
(SEAL)
SWORN TO AND SUBSCRIBED BEFORE ME, THIS /.Yfh DAY OF .fie,, I 902q
MY COMMISSION EXPIRES ,Mo✓ch(,, a0�� �-"�OTg9`1.
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Ad Copy:
Public Notice
North Carolina
Environmental Management Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue NPDES Wastewater Permit NCO088200 - City of Thomasville WTP
The North Carolina Environmental Management Commission proposes 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 after 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 interest. Please mail comments and/or information requests to DWR at the above address. Interested persons
may visit the DWR at 512 N. Salisbury Street, Raleigh, NC 27604 to review the information on file. Additional information on
NPDES permits and this notice may be found on our website: https://deq.nc.gov/public-notices-hearings,or by calling (919)
707-3601. The City of Thomasville [PO Box 368, Thomasville, NC 27361] has requested renewal of NPDES permit NCO088200
for the City of Thomasville WTP, located in Davidson County. This permitted facility discharges treated wastewater to a UT to
Rich Fork Creek, a class C water in the Yadkin -Pee Dee River Basin. Some of the parameters in the permit are water quality
limited. This discharge may affect future allocations in this segment of Rich Fork Creek.
April 18, 2024

Bennett, Bradley
From:
Talbott, Jeffrey
Sent:
Wednesday, April 17, 2024 11:27 AM
To:
Bennett, Bradley
Subject:
RE: Draft Permit - Thomasville WTP - NCO088200
Morning Bradley —
Operator certification notes that this facility is classified as a PC -I, with the ORC and all Backup ORC's active and in good
standing with the program.
We have no comments at this time.
Thank you.
Jeff Talbott
Supervisor, NC Operator Certification Program
Division of Water Resources
Department of Environmental Quality
Phone: [phone]
Email: Jeff rey.TalbottPdeq.nc.gov
--------------------------------------------------------------------------------
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Monday, April 15, 2024 8:41 AM
To: Talbott, Jeffrey <[e-mail]>
Subject: Draft Permit - Thomasville WTP - NCO088200
Hey Jeff,
Hope you are doing okay. Here is a draft permit for your review. It is for the Thomasville WTP — NCO088200 —in
Davidson County. Permit and Fact Sheet are attached.
Thanks
::
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
1

Bennett, Bradley
From: Conder, Misty <[e-mail]>
Sent: Tuesday, April 16, 2024 2:18 PM
To: Bennett, Bradley
Subject: [External] Re: Draft Permit for Thomasville WTP - NCO088200 - To Notice This Week
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.
Thanks Bradley!
I've gotten the file. Good to lose limits for a change instead of getting them added!
Misty
Misty Conder I Laboratory Supervisor — Pretreatment Coordinator
P 336-475-4246 ext 2
City of Thomasville
Hamby Creek WWTP, 110 Optimist Park Rd, Thomasville, NC 27360
P.O. Box 368, Thomasville, NC 27361-0368
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110RIH CAR0LIhA
PUBLIC UT LIT] ES
From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, April 16, 2024 9:32 AM
To: Conder, Misty < Misty. Conde [e-mail]>; Brandt, Michael <[e-mail]>
Subject: Draft Permit for Thomasville WTP - NCO088200 - To Notice This Week
***EXTERNAL SENDER ALERT*** This email is not sent from The City of Thomasville, NC, and its authenticity has not
been independently verified. Be vigilant and do not disclose sensitive information, click on unfamiliar links, or
download attachments unless you are certain of the sender's identitv and intentions.
Attached is the draft permit for your Thomasville WTP — NC0088200. This permit will be noticed in a local paper
this week. Please review the draft and let me know if you have any questions or comments.
Please respond to this email to verify that you received the attached file and that you can open, view,
download and print the file for your records.
Misty —Thanks for your help in the renewal process!
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617

Bennett, Bradley
From: Conder, Misty <[e-mail]>
Sent: Tuesday, April 16, 2024 2:18 PM
To: Bennett, Bradley
Subject: [External] Re: Draft Permit for Thomasville WTP - NCO088200 - To Notice This Week
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.
Thanks Bradley!
I've gotten the file. Good to lose limits for a change instead of getting them added!
Misty
Misty Conder I Laboratory Supervisor — Pretreatment Coordinator
P 336-475-4246 ext 2
City of Thomasville
Hamby Creek WWTP, 110 Optimist Park Rd, Thomasville, NC 27360
P.O. Box 368, Thomasville, NC 27361-0368
Ni
, V !
;;�' �� �l
110RIH CAR0LIhA
PUBLIC UT LIT] ES
From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, April 16, 2024 9:32 AM
To: Conder, Misty < Misty. Conde [e-mail]>; Brandt, Michael <[e-mail]>
Subject: Draft Permit for Thomasville WTP - NCO088200 - To Notice This Week
***EXTERNAL SENDER ALERT*** This email is not sent from The City of Thomasville, NC, and its authenticity has not
been independently verified. Be vigilant and do not disclose sensitive information, click on unfamiliar links, or
download attachments unless you are certain of the sender's identitv and intentions.
Attached is the draft permit for your Thomasville WTP — NC0088200. This permit will be noticed in a local paper
this week. Please review the draft and let me know if you have any questions or comments.
Please respond to this email to verify that you received the attached file and that you can open, view,
download and print the file for your records.
Misty —Thanks for your help in the renewal process!
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617

Bennett, Bradley
From: Graznak, Jenny
Sent: Sunday, April 14, 2024 11:24 AM
To: Bennett, Bradley
Subject: RE: Draft Permit for Thomasville WTP - NCO088200
Ok, thank you!
Jenny Graznak
Assistant Regional Supervisor, Division of Water Resources
North Carolina Department of Environmental Quality
Winston-Salem Regional Office
Office: [phone] / Cell: [phone]
[e-mail]
D_E Q>
ftp-Mm 11 uI EnY1'p1'1 fl1al Oualdy
Email correspondence to and from this address is subject to the North
Carolina Public Records taw and may be disclosed to third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Monday, April 8, 2024 8:50 AM
To: Graznak, Jenny <[e-mail]>
Subject: Draft Permit for Thomasville WTP - NCO088200
Hey Jenny,
Here is the draft permit for the Thomasville WTP — NC0088200. Let me know if you have any comments. I hope to
send this one to notice next week. I did write it up to stay as an individual permit as we discussed. The draft permit
and fact sheet are attached. Application information can be found in Laserfiche.
Thanks
::
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: brad ley.ben nettjndeq. nc.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Bennett, Bradley
From: Nicholson, Molly
Sent: Monday, April 8, 2024 12:20 PM
To: Bennett, Bradley
Cc: Moore, Cindy
Subject: RE: Draft Permit for Thomasville WTP - NCO088200
Hi Bradley,
Everything looks great. Thank you.
Molly Nicholson
Environmental Specialist II - Compliance and Enforcement
Aquatic Toxicology Branch
N.C. Division of Water Resources - Water Sciences Section
N.C. Department of Environmental Quality
Please note that my phone number has changed:
919-743-8424 Office
[e-mail]
1621 Mail Service Center, Raleigh, NC 27699-1623
Submit AT Forms electronically to: [e-mail]
From: Bennett, Bradley <[e-mail]>
Sent: Monday, April 8, 2024 11:15 AM
To: Nicholson, Molly <[e-mail]>
Cc: Moore, Cindy <[e-mail]>
Subject: RE: Draft Permit for Thomasville WTP - NCO088200
Hey Molly,
Here is the permit with the WET requirements updated. Hopefully I got all the changes correct.
::
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradley.bennett(aMeg.nc.pov
Email correspondence to and from this address may be subject to public records laws
From: Nicholson, Molly <[e-mail]>
Sent: Monday, April 8, 2024 10:29 AM
To: Bennett, Bradley <bradley.ben [e-mail]>

Cc: Moore, Cindy <[e-mail]>
Subject: RE: Draft Permit for Thomasville WTP - NCO088200
Everything else looks great, but I am happy to take another look at it once the updated toxicity requirement is added.
Thanks,
Molly Nicholson
Environmental Specialist II - Compliance and Enforcement
Aquatic Toxicology Branch
N.C. Division of Water Resources - Water Sciences Section
N.C. Department of Environmental Quality
Please note that my phone number has changed:
919-743-8424 Office
[e-mail]
1621 Mail Service Center, Raleigh, NC 27699-1623
Submit AT Forms electronically to: [e-mail]
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Monday, April 8, 2024 10:17 AM
To: Moore, Cindy <[e-mail]>; ATForms.ATB <[e-mail]>
Cc: Nicholson, Molly <molIV. [e-mail]>
Subject: RE: Draft Permit for Thomasville WTP - NCO088200
Thanks Guys. I will make that change. I'll update the language in the effluent page and in the Special
Condition. Let me know if you see any other issues in the permit.
Thanks!
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett(o)deg.nc.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Moore, Cindy <[e-mail]>
Sent: Monday, April 8, 2024 10:15 AM
To: Bennett, Bradley <bradley.ben [e-mail]>; ATForms.ATB <[e-mail]>
Cc: Nicholson, Molly <molIV. [e-mail]>
Subject: RE: Draft Permit for Thomasville WTP - NCO088200
Hey Bradley,
This conventional plant should be moved to a pass/fail limit. Molly and I look at this specific issue this morning. She will
review the rest of the permit language.

Thx
cindy
From: Bennett, Bradley <bradley. ben [e-mail].t;ov>
Sent: Monday, April 8, 2024 8:55 AM
To: ATForms.ATB <[e-mail]>
Cc: Moore, Cindy <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: Draft Permit for Thomasville WTP - NCOO882OO
Hey Guys,
Here is the draft permit and Fact Sheet for the Thomasville WTP — NCOO882OO. This one has had WET
requirements that are monitoring requirements. It is a conventional WTP and in the past there was discussion of
moving all of these to Pass/Fail limited requirements. Could you verify that this is what needs to be done. If so, I
will make the change. I'd like to send this one to notice next week if you guys are able to review and comment on
this one before then I'd appreciate it.
Thanks
::
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: brad ley. ben nett ,deq.nc.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Bennett, Bradley
From: Deuterman, Sydney
Sent: Friday, April 5, 2024 5:03 PM
To: Bennett, Bradley
Subject: Re: Draft For Review - Thomasville WTP - NCO088200
Hey Bradley,
Most of these are minor formatting things I have noted for Sara & Caroline during my recent reviews of their WTP draft
permits. Great job on this renewal!
Permit:
• I've been removing the sub -basin from the first page of the permit, but keeping it on the Supplement to Cover
Sheet where the other stream specifics are detailed. The Basin Planning Branch apparently no longer uses the 6-
digit sub -basin code system.
• Sara & Caroline have been putting John's full name and title on the signature page, so I've been following suite.
They've used "John E. Hennessy, Section Chief Regional Operations.
• Again, super minor, but I italicize the paragraph directly under the "Supplement to Permit Cover Sheet" header,
and then bold the Permittee name
• Citation for the Physical -Chemical facilities is 08G .0306
• Cindy (ATB) has said all conventional WTPs should be moved to Pass/Fail limit instead of monitoring only,
regardless of compliance history, so update the TOX condition and make sure the effluent table says Pass/Fail in
place of Monitor & Report.
RPA:
• Their Fluoride values seem all over the place, ranging from 300 ug/L to < 0.1 ug/L. I pulled the DMR data and it
looks like the super low values didn't get converted from mg/L to ug/L for the RPA. I would re -run the RPA with
those values corrected. I doubt they'll have RP, but just to make sure!
Hope you have a great weekend! I'm keeping all fingers and toes crossed for tomorrow's game!
Sydney Deuterman (she/her)
Environmental Specialist II
Compliance and Expedited Permitting Unit
Division of Water Resources
N.C. Department of Environmental Quality
Office: 919-707-3712
sydney.deutermanOdeq.nc.gov
1617 Mail Service Center
Raleigh, NC 27699-1617
E'_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, April 3, 2024 4:40 PM
To: Deuterman, Sydney <[e-mail]>
Subject: Draft For Review - Thomasville WTP - NCOO882OO
Hey Sydney,
Here is a draft permit for your review. I have two others that are waiting for more information so I can finish them
and get them to you. Seems like it has been awhile since I sent you a draft for review. That can only mean that this
one may have lots of issues!
EINCOO882O0 City of Thomasville WTP
Thanks for being a Pack fan this weekend!
M.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Bennett, Bradley
From:
Conder, Misty <[e-mail]>
Sent:
Wednesday, April 3, 2024 11:38 AM
To:
Bennett, Bradley
Cc:
Brandt, Michael M
Subject:
[External] Thomasville Contacts Form
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.
Mr. Bennett,
The PDF you sent regarding contacts for the new permit was correct, as far as it goes, except for one
item. When Thomasville submitted the ownership change form from Kelly Craver to Michael Brandt, you
evidently changed everything except the permit billing contact e-mail. The correct Permit Billing Contact
Person email should be [e-mail] to match the owner's name.
In addition to the correction of e-mail contact for billing, there are several contact points missing.
First, for the Facility Contact Person you can use the following: Jeff Dennard, Plant Superintendent (for the
Water Plant) PO BOX 368, Thomasville, NC 27361, 336-475-4247, no FAX, jef£dennard@thomasville-
nc.gov. For the Lagoon operations, you can use Leigh Conder, ORC, PO BOX 368, Thomasville, NC 27361,
336-475-4246, no FAX, [e-mail].
For the Permit Contact Persons, you can use the following as I was the one to complete the permit application:
Leigh Conder, ORC, PO BOX 368, Thomasville, NC 27361, 336-475-4246, no FAX,
[e-mail]. Otherwise, Michael Brandt could also be included here since he signed the
application.
Also, in May of 2019, Kelly Craver submitted the electronic signature agreement for me to have signatory
authority (yes, my legal name is Leigh A. Conder) for the EDMR. That is not reflected under the Persons with
Signatory Authority section of your form. Should it be listed there or are you only looking for the owner for
permit renewal purposes? Does that form have to be updated now that we have a new City Manager?
Otherwise, as the Owner, Michael Brandt should be listed there.
Let me know if you need confirmation of this e-mail from Mr. Brandt.
Thanks,
Misty
Misty Conder I Laboratory Supervisor— Pretreatment Coordinator
P 336-475-4246 ext 2
City of Thomasville

Hamby Creek WWTP, 110 Optimist Park Rd, Thomasville, NC 27360
P.O. Box 368, Thomasville, NC 27361-0368
U01
NDRIR CAR0LIN
PUBL.1(7 UTII..ITIES
Pursuant to North Carolina General Statutes, Chapter 132, Public Records, this e-mail and any
attachments, as well as any e-mail messages(s) that may be sent in response to it, may be considered
public records and therefore are subject to public records requests for review and copying.
4

Bennett, Bradley
From: Bennett, Bradley
Sent: Wednesday, April 3, 2024 10:06 AM
To: Brandt, Michael M; Conder, Misty
Subject: Permit Renewal for Thomasville WTP - NCO088200
Attachments: NCO088200_WW Permit Contact Repo rt_20240403.pdf
We have been working on the draft permit for the renewal of your Water Treatment Plant's NPDES discharge
permit. We hope to have the permit ready for public notice within the next few weeks. In going thorough this
process we had a few items that we want to contact you about and get your review/response. Please see the
items below.
Review of Permit Contact Information:
Attached is a pdf file with information on contacts that we currently have in our permitting database for this
facility. Could you please review the information and let us know if we need to make any corrections/additions or
deletions in the information to keep or database up to date.
Electronic Submittal of Permitting Documents:
In order to provide more convenience, control, and security to our permittees and assist them in processing their
transactions, The Division of Water Resources is currently transitioning towards electronic correspondence. This
hopefully provides more efficient service to our permittees and other partners and will allow us to more effectively
process and track documents. We are writing to ask you for your approval of the transmittal of documents related
to your permitting and related activities with the Division in an electronic format. Documents will be emailed to
the appropriate contact person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an electronic
manner is acceptable to -you. If -you have an-yauestions, please feel free to contact me.
Thanks
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
Email correspondence to and from this address may be subject to public records laws

North Carolina Department of Environmental Quality
Division of Water Resources
Permit Number: NCO088200
Permit Type: Water Plants and Water Conditioning Discharge
Facility Name: Thomasville WTP
Facility Addressl: 200 Old Lexington Rd
Facility Address2:
City, State & Zip: Thomasville, NC 27361-0368
Owner Information Details:
MUST submit a Change of Name/Ownership form to DWR to make any changes to this Owner information.
(Click Here for "Change of Name/Ownership"Form)
Owner Name: City of Thomasville
Owner Type: Government - Municipal Owner Type Group: Organization
*** Legally Responsible for Permit ***
(Responsible corporate officer/principle executive officer or ranking elected official/general partner or proprietor;
or any other person with delegated signatory authority from the legally responsible person.)
Owner Affiliation: Michael Brandt Title: City Manager
Addressl: PO Box 368
Address2:
City, State & Zip: Thomasville, NC 27361-0368
Work Phone: [phone] Fax: [phone]
Email Address: [e-mail]
Owner Contact Person(s)
Contact Name Title Address Phone Fax Email
Morgan Draper 1106 S Fulton St, Salisbury, NC 336-475-4220 morgan.huffman@thoma
Huffman 28144-6469 sville-nc.gov
Facility Contact Person(s)
Contact Name Title Address Phone Fax Email
Permit Contact Person(s)
Contact Name Title Address Phone Fax Email
Permit Billing Contact Person(s)
Contact Name Title Address Phone Fax Email
Michael Brandt PO Box 368, Thomasville, NC 336-475-4220 336-475-4283 kelly.craver@thomasville-
27361-0368 nc.gov
Persons with Signatory Authority
Type Contact Name Title Address Phone Fax Email
4/3/2024 Page

Permit Number: NCO088200
Permit Type: Water Plants and Water Conditioning Discharge
Facility Name: Thomasville WTP
Facility Addressl: 200 Old Lexington Rd
Facility Address2:
City, State & Zip: Thomasville, NC 27361-0368
Designated Operators
If the designated operators listed below are incorrect or no longer associated with the collection system, the information can be updated by 6
"Operator Designation Form" (Click Here for ORC Des/gnat/on Form). P/ease provide specific details as to the changes requested, including th
designated operators. For all other operator questions or issues, please call 919-807-6353.
Facility Classification: PC1
Operator Name
Role
Cert Type
Cert Status
Cert #
Effective Date
Leigh A Conder
ORC
PC-1
Active
988641
1/22/2008
Morgan Draper Huffman
Backup
PC-1
Active
988621
1/22/2008
4/3/2024 Page 2

Bennett, Bradley
From: Graznak, Jenny
Sent: Tuesday, April 2, 2024 12:32 PM
To: Bennett, Bradley
Subject: RE: Starting Review of Renewal for Thomasville WTP - NCO088200
think keeping them under the individual permit for the next permit cycle is the safest strategy. I like your idea to
change the Cu monitoring back to quarterly.
Sorry for late reply — I was out on vacation last week!
Jenny Graznak
Assistant Regional Supervisor, Division of Water Resources
North Carolina Department of Environmental Quality
Winston-Salem Regional Office
Office: [phone] / Cell: [phone]
[e-mail]
Nf�FiTl I C:AAc�. ll�_� � Q�iS'
Oepnbnenl of Fawlmnmontal ©ual�� Y
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <bradley. [e-mail]>
Sent: Thursday, March 28, 2024 1:12 PM
To: Graznak, Jenny <[e-mail]>
Subject: RE: Starting Review of Renewal for Thomasville WTP - NCO088200
Hey Jenny,
As I have gotten into this renewal I have come across something I wanted to touch base with you on.
They area conventional system. In the last renewal they had just had a WET test failure and they had shown
Reasonable Potential for Cu violations, so they ended up with a permit limit for Cu. Over the permit cycle since
then they have passed all their WET requirements and all their Cu numbers have been below detection, so the Cu
Limit could be removed in this renewal. They currently aren't discharging because their alum lagoon is full, and
they are discharging to the WWTP while they wait for the material to dry so they can dredge the lagoon out.
This permit could potentially qualify for the NCG59 permit coverage. Since they have had WET and Cu issues in
the past (actually only one WET failure and a couple of high Cu values) and discharge to a water body impaired for
biological integrity I am considering keeping them in the individual permit coverage at least for this cycle. We
would takeout the Cu limits and change that monitoring back to quarterly. I wanted to see how you guys felt
about this in the region. Do you think we should stick with the individual coverage at least for this permit cycle or
do you think we should offer them the GP coverage?
If you want to discuss this, we can set up a Teams call.
Thanks

W.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradley.ben nett(o)deg.nc.gov
Email correspondence to and from this address may be subject to public records laws
From: Graznak, Jenny <][e-mail]>
Sent: Tuesday, March 5, 2024 1:47 PM
To: Bennett, Bradley <bradley.ben [e-mail]>
Subject: RE: Starting Review of Renewal for Thomasville WTP - NC0088200
Hey there,
am pretty sure this one is on our list for inspection this year. But we only have two NPDES inspectors right now, so
not sure when will get to it. I do not know anything about this one, but let me know if I can help do some sleuthing
foryou!
Jenny Graznak
Assistant Regional Supervisor, Division of Water Resources
North Carolina Department of Environmental Quality
Winston-Salem Regional Office
Office: [phone] / Cell: [phone]
[e-mail]
o OFU nm m Em1r m Ul Dual
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Tuesday, March 5, 2024 11:58 AM
To: Graznak, Jenny <[e-mail]>
Subject: Starting Review of Renewal for Thomasville WTP - NC0088200
Hey Jenny,
Hope you are doing well. Just wanted to let you know I am starting the permit renewal review for this one. It looks
like they haven't discharged since around the middle of last year as they are preparing to clean out the
lagoon. There was no information in the application about their timeframe for that. I guess they are sending their
discharge to the WWTP. Let me know if there is any info you need to discuss or pass along about this one.
Thanks
An.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Phone: [phone]
Email: bradley.bennetto)deg.ncgov

Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 15t to June 91" 2023.
Employee email addresses may look different, but email performance will not be impacted.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Bennett, Bradley
From: Conder, Misty <[e-mail]>
Sent: Tuesday, October 24, 2023 10:20 AM
To: Bennett, Bradley
Subject: [External] Revised Thomasville WTP NPDES permit application
Attachments: Thomasville Form 1 - signed 10-24-23.pdf, Thomasville Form 2c - signed 10-24-23.pdf
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.
Mr. Bennett,
Please find attached the revised Thomasville NPDES permit application for the Water Plant's alum lagoon. Mr.
Brandt had been out of the office so it took a bit to get it signed, and then I didn't hear that he had signed it for a
bit after. I'm emailing the scanned copy, but I'm also putting a hard copy in the mail to Ms. Thedford as
requested.
Thanks,
Misty Conder
Misty Conder I Laboratory Supervisor — Pretreatment Coordinator
P 336-475-4246 ext 2
City of Thomasville
Hamby Creek WWTP, 110 Optimist Park Rd, Thomasville, NC 27360
P.O. Box 368, Thomasville, NC 27361-0368
At
%%,K= 0 M a SV P,
H0RIR C A R 0 L I I
PUBLIC UTILITIES
Pursuant to North Carolina General Statutes, Chapter 132, Public Records, this e-mail and any
attachments, as well as any e-mail messages(s) that may be sent in response to it, may be considered
public records and therefore are subject to public records requests for review and copying.

Bennett, Bradley
From: Bennett, Bradley
Sent: Monday, October 2, 2023 3:32 PM
To: Conder, Misty
Subject: RE: [External] Re: Thomasville Water Treatment Plant Permit Application - NCO088200
Within the last few years EPA has required that we use specific forms for our dischargers rather than the forms we had
created and utilized in the past. I know that there are a few more things to work through on these but its is a
requirement that we have to meet. Sorry for the additional steps, we wish the process was a little different as well.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023.
Employee email addresses may look different, but email performance will not be impacted.
From: Conder, Misty <[e-mail]>
Sent: Monday, October 2, 2023 3:25 PM
To: Bennett, Bradley <[e-mail]>
Subject: Re: [External] Re: Thomasville Water Treatment Plant Permit Application - NCO088200
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.
Just curious, why EPA Form 2C? A water plant is neither a manufacturing facility, commercial, mining nor a
silvicultural operation. Unless you are calling water treatment manufacturing because they make water safe to
drink?
NCShort form 2C was much more concise, to the point and seemed to address and provide all the needed
information without needing reams of paper for a lot of unneeded information. Just glancing at this thing it
looks like a lot of no's or do not apply.
Misty
Misty Conder I Laboratory Supervisor— Pretreatment Coordinator
P 336-475-4246 ext 2
City of Thomasville

Hamby Creek WWTP, 110 Optimist Park Rd, Thomasville, NC 27360
P.O. Box 368, Thomasville, NC 27361-0368
ti�s�� I l
FAIN
omas �lle
NDRIH CAR0LIhA
PUBLIC UT LIT ES
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Monday, October 2, 2023 11:13 AM
To: Conder, Misty <[e-mail]>
Subject: RE: [External] Re: Thomasville Water Treatment Plant Permit Application - NCO088200
***EXTERNAL SENDER ALERT*** This email is not sent from The City of Thomasville, NC, and its authenticity has not been
independently verified. Be vigilant and do not disclose sensitive information, click on unfamiliar links, or download attachments
unless you are certain of the sender's identitv and intentions.
Sorry about the misunderstanding there. Thanks for your help on this!
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben netto-)deg.nc.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023.
Employee email addresses may look different, but email performance will not be impacted.
From: Conder, Misty <[e-mail]>
Sent: Monday, October 2, 2023 11:13 AM
To: Bennett, Bradley <bradley.ben [e-mail]>
Subject: [External] Re: Thomasville Water Treatment Plant Permit Application - NCO088200
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.
Thanks for the corrected documents. I had asked Trica Lowery, with the WS-Regional office if the one I used
was still the form being used and she said yes. I'll get the new forms completed and sent in.
Thanks again,
Misty
Misty Conder I Laboratory Supervisor— Pretreatment Coordinator
P 336-475-4246 ext 2
Cityof Thomasville Thomasville
FEI

Hamby Creek WWTP, 110 Optimist Park Rd, Thomasville, NC 27360
P.O. Box 368, Thomasville, NC 27361-0368
tirs�� II ll
o m a svMlle
NDRIH CAR0LIhA
PUBLIC UT LIT ES
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Monday, October 2, 2023 10:59 AM
To: Conder, Misty <[e-mail]>; Brandt, Michael <Michael.Bra ndt@thomasviI le-nc.gov>
Subject: Thomasville Water Treatment Plant Permit Application - NCO088200
***EXTERNAL SENDER ALERT*** This email is not sent from The City of Thomasville, NC, and its authenticity has not been
independently verified. Be vigilant and do not disclose sensitive information, click on unfamiliar links, or download attachments
unless you are certain of the sender's identitv and intentions.
Ms. Conder,
Our office recently received the permit renewal application for the Thomasville WTP — NC0088200. The application was
received on an old application form that is no longer used. Permittees are now required to use specific EPA forms for
their NPDES permit applications. Additional information on the required forms for different discharges can be found on
our website at: https://www.deg.nc.gov/about/divisions/water-resources/permitting/npdes-wastewater/npdes-
permitting-process/npdes-individual-permit-applications. For Water Treatment Plants the forms needed are EPA Form
1 and EPA Form C. You can find these on the website mentioned above, but they are also attached here for your
convenience.
Please complete these forms and return a signed hard copy to our Division at the address below. You can also submit an
electronic copy do me at this email but will still need to submit a signed hard copy as well. Please note that the forms
must be signed by an entity with authorization to sign for the Town. Mr. Brandt is listed as the current Owner with
authority to make permit decisions in our system. In order for you to sign the forms as you did on the previous
submittal Mr. Brandt will need to delegate signature authority to you.
Submit Signed Hard Copy to:
Wren Thedford
NC Division of Water Resources
Water Quality Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Thanks for your help on this.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradlev.bennett(@deg.nc.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023.

Employee email addresses may look different, but email performance will not be impacted.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
Pursuant to North Carolina General Statutes, Chapter 132, Public Records, this e-mail and any attachments, as well as
any e-mail messages(s) that may be sent in response to it, may be considered public records and therefore are subject to
public records requests for review and copying.
Pursuant to North Carolina General Statutes, Chapter 132, Public Records, this e-mail and any attachments, as well as
any e-mail messages(s) that may be sent in response to it, may be considered public records and therefore are subject to
public records requests for review and copying.

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
❑ Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1 Q10s (cfs)
_Effluent Hardness
Upstream Hardness
_Combined Hardness Chrc_ oni
Combined Hardness Acute
Data Source(s)
❑ CHECK TO APPLY MODEL
❑ CHECK IF HQW OR ORIN WQS
Thomasville WTP
Class I P/C
NCO088200
001
0.234
UT to Rich Fork Creek
030401030203
C
0.00
0.00
0.00
0.00
0.00
35.6 mg/L (Avg)
25 mg/L (Avg)
-------- 35_6 mg/L --
35.6 mg/L
- - - - - - - - - - - - - -
Partll
Par02
Par03
Par04
Partly
Par06E
Par07
Partl8
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name WQs Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Trout
NC
1.3074
TR
2.7033
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/L
Chlorinated Phenolic Compounds
Water supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
157.2611
FW
1208.9616
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
10.6595
FW
14.6105
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
4.3740
FW
112.2432
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
50.2086
FW
452.0482
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
0.5444
ug/L
Zinc
Aquatic Life
NC
170.9859
FW
169.5986
ug/L
NCO088200_9595 Final FW RPA w_changes from 20231121_2024, input
4/3/2024

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
Use"PASTE SPECIAL
Effluent Hardness Values"then"COPY
Maximum data points
= 58
Date Data
BDL=1/2DL
Results
10/8/2019
44
44
Std Dev.
6.3805
1/7/2020
32
32
Mean
35.6000
4/7/2020
32
32
C.V.
0.1792
7/9/2020
36
36
n
10
10/8/2020
36
36
10th Per value
28.00 mg/L
1/5/2021
28
28
Average Value
35.60 mg/L
4/6/2021
28
28
Max. Value
44.00 mg/L
7/7/2021
44
44
10/7/2021
44
44
1/18/2022
32
32
NC0088200_9595 Final FW RPA w_changes from 20231121_2024, data
- 1 - 4/8/2024

REASONABLE POTENTIAL ANALYSIS
Pall
Copper
Date
Data
BDL=1/2DL
Results
1
9/6/2019
<
2.00
1
Std Dev.
2
10/8/2019
<
2.00
1
Mean
3
11/27/2019
<
2.00
1
C.V.
4
12/16/2019
<
2.00
1
n
5
1 /7/2020
<
2.00
1
6
2/5/2020
<
2.00
1
Mult Factor =
7
3/4/2020
<
2.00
1
Max. Value
8
4/7/2020
<
2.00
1
Max. Pred Cw
9
5/8/2020
<
2.00
1
10
6/15/2020
<
2.00
1
11
7/9/2020
<
2.00
1
12
8/12/2020
<
2.00
1
13
9/22/2020
<
2.00
1
14
10/8/2020
<
2.00
1
15
11 /20/2020
<
2.00
1
16
12/15/2020
<
2.00
1
17
1 /5/2021
<
2.00
1
18
2/4/2021
<
2.00
1
19
3/9/2021
<
2.00
1
20
4/6/2021
<
2.00
1
21
5/27/2021
<
2.00
1
22
6/15/2021
<
2.00
1
23
7/7/2021
<
2.00
1
24
8/10/2021
<
2.00
1
25
9/20/2021
<
2.00
1
26
10/7/2021
<
2.00
1
27
11 /4/2021
<
2.00
1
28
12/17/2021
<
2.00
1
29
1/18/2022
<
2.00
1
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL Par13
Values" then "COPY".
Maximum data points
= 58
1.0000
0.0000
29
1.00
1.00 ug/L
1.00 ug/L
Use "PASTE SPECIAL
Fluoride Values" then "COPY".
Maximum data points
= 58
Date
Data
BDL=1/2DL
Results
1
10/8/2019
300
300
Std Dev.
111.0494
2
1/7/2020
130
130
Mean
117.3109
3
4/7/2020
130
130
C.V.
0.9466
4
7/9/2020
0.22
0.22
n
11
5
10/8/2020
0.2
0.2
6
12/21/2020
<
100
50
MultFactor=
2.11
7
1/5/2021
<
100
50
Max. Value
300.0 ug/L
8
4/6/2021
<
100
50
Max. Pred Cw
633.0 ug/L
9
7/8/2021
280
280
10
10/7/2021
250
250
11
1/18/2022
<
100
50
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
-2-
NCO088200_9595 Final FW RPA w_changes from 20231121_2024, data
4/8/2024

Thomasville WTP
NCO088200
Freshwater RPA - 95%
Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD)
= 0.2340
WWTP/WTP Class: Class I P/C
1Q10S (cfs)
= 0.00
IWC% @ 1Q10S = 100
7Q10S (cfs)
= 0.00
IWC% @ 7Q10S = 100
7Q10W (cfs)
= 0.00
IWC% @ 7Q10W = 100
30Q2 (cfs)
= 0.00
IWC% @ 30Q2 = 100
Avg. Stream Flow, QA (cfs)
= 0.00
TW%C @ QA = 100
Receiving Stream: UT to Rich Fork Creek
HUC 030401030203 Stream Class: C
Outfall 001
Qw = 0.234 MGD
COMBINED HARDNESS (mg/L)
Acute = 35.6 mg/L
Chronic = 35.6 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
F
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
a
Applied
Chronic Acute
ri # Det. Max Pred Cw Allowable Cw
Standard
Acute: 14.61
No detects; Maintain Quarterly Monitoring
Copper
NC
10.6595 FW 14.6105
ug/L
29 0
1.00
_ _ _ _ ___
Chronic: 10.66
_ _ _ _ _ _ _ _ _ _ _______
No detects; Maintain Quarterly Monitoring
NO DETECTS
Max MDL = 2
Acute: NO WQS
Fluoride
NC
1800 FW
ug/L
11 7
633.0
_
Chro_ _ _ _ _
nic: 1,800.0
_ _ _ _ _ _ _ _ _ _ _ _ _
No RP; Use Fluoride so continue monitoring
No value > Allowable Cw
Acute:
0 0
N/A
_ _ _
Chronic:----------
— - — - — - — - — - — - — - — - — - — - — - — - — - —
NCO088200_9595 Final FW RPA w_changes from 20231121 2024, rpa
Page 1 of 1 4/8/2024

NORTH CAROLINA 2022 303(D) LIST
Lower Yadkin
AU Name
AU ID Description
Abbotts Creek (including Lexington -Thomasville
Water Supply Reservoir at normal reservoir
elevation, Tom-A-Lex Lake)
831 99 From Yokely Road to Dam
PARAMETER
Chlorophyll a (40 µg/I, AL, NC)
Abbotts Creek
12986 From SR1243 to185
PARAMETER
[Benthos (Nar, AL, FW)
Yadkin -Pee Dee River Basin
AU Number Classification AU_LengthArea AU —Units
12-119-(4.5)b WS-III;CA 34.8 FW Acres
IR CATEGORY CRITERIA STATUS
5 lExceeding Criteria L
12-119-(6)b
REASON FOR RATING 303D YEAR
2018 ■
1.6 FW Miles
IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
5 -1lExceeding Criteria Fair, Poor or Severe Bioclassification 2004
Hunts Fork
1581 From source to Rich Fork
12-119-7-3
7.1 FW Miles
PARAMETER IR CATEGORY CRITERIA STATUS � REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW) 5 J lExceeding Criteria Fair, Poor or Severe Bioclassification 1998
North Hamby Creek
1584 From source to Hamby Creek
PARAMETER R CATEGORY
Benth so (Nar, AL, FW) 5
12-119-7-4-1 C �5.8 FW Miles
CRITERIA STATUS REASON FOR RATING 303D YEAR
JExceeding Criteria Fair, Poor or Severe Bioclassification 1998
Hamby Creek 12-119-7-4b
13313 From North Hamby Creek to Rich Fork
PARAMETER IR CATEGORY CRITERIA STATUS
Copper (7 µg/I, AL, FW)
;h Fork
13225 From Payne Creek to SR1790
PARAMETER
Fish Community (Nar, AL, FW)
6 44 FW Miles
REASON FOR RATING 303D YEAR
5 ilExceeding Criteria Legacy Category 5 Total Metals
Assessment
12-119-7b1
IR CATEGORY CRITERIA STATUS
1998
3.8 FW Miles
REASON FOR RATING 303D YEAR
5 _]lExceeding Criteria Fair, Poor or Severe Bioclassification 1998
Rich Fork 12-119-7b2 C 8.3 FW Miles
13314 From SR1790 to Abbotts Creek
PARAMETER IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
(Fish Community (Nar, AL, FW) 5 Exceeding Criteria Fair, Poor or Severe Bioclassification
6/7/2022 NC 2022 303d List- Approved by EPA 4/30/2022 Page 182 of 192

Whole Effluent Toxicity Testing and Self Monitoring Summary
City of Thomasville WTP
NCO088200/001
County:
Davidson
Region:
WSRO
Basin:
YAD07
Jan Apr Jul Oct
Ceri7dPF
Begin:
9/1/2019
Chr Monit: 90%
NonComp:
7Q10:
PF: 0.30
IWC:
Freq: Q
J
F M
A M
J
J
A
S
O
2020
Pass
- -
Pass -
-
Pass
-
-
Pass
2021
Pass
- -
Pass -
-
Pass
-
-
Pass
2022
Pass
- -
Pass -
-
H
-
-
H
2023
H
- -
Pass -
-
H
-
-
H
2024
H
- -
- -
-
-
-
-
-
CK 525 South Tryon TIC, LLC
NCO089885/001
County:
Mecklenburg
Region:
MRO
Basin:
CTB34
Fthd48Ac
Begin:
2/1/2020
NonComp:
7Q10:
PF:
IWC:
Freq: M
J
F M
A M
J
J
A
S
O
2020
H
H H
H H
-
-
-
-
-
Claremont North WWTP
NCO032662/001
County:
Catawba
Region:
MRO
Basin:
CTB32
Jan Apr Jul Oct
Ceri7dPF
Begin:
1/1/2016
chr lim: 13%
NonComp: Single
7Q30: 1.0
PF: 0.10
IWC: 13
Freq: Q
J
F M
A M
J
J
A
S
O
2020
Pass
- -
Pass -
-
Pass
-
-
Pass
2021
Pass
- -
Pass -
-
Pass
-
-
Pass
2022
Pass
- -
Pass -
-
Pass
-
-
Pass
2023
Pass
- -
Pass -
-
Pass
-
-
Pass
2024
Pass
- -
- -
-
-
-
-
-
Clariant Corp. -Mt. Holly East Plant
NC0004375/001
County:
Mecklenburg
Region:
MRO
Basin:
CTB34
Mar Jun Sep Dec
Ceri7dPF
Begin:
1/1/2018
Chr Lim: 0.8
NonComp: Single
7Q10: 329
PF: 3.9
IWC: 1.8
Freq: Q
J
F M
A M
J
J
A
S
O
2020
-
- Pass
- -
Pass
-
-
Pass
-
2021
-
- Pass
- -
Pass
-
-
Pass
-
2022
-
- Pass
- -
Pass
-
-
Pass
-
2023
-
- Pass
- -
Pass
-
-
Pass
-
ClarktonWWTP
NCO021610/001
County:
Bladen
Region:
FRO
Basin:
LUM58
Jan Apr Jul Oct
Ceri7dPF
Begin:
6/1/2010
chr lim: 90%
NonComp: Single
7Q10: 0.0
PF: 0.24
IWC: 100
Freq: Q
J
F M
A M
J
J
A
S
O
2020
Pass
- -
Pass -
-
Pass
-
-
Fail
2021
Pass
- -
Pass -
-
Pass
-
-
Pass
2022
Pass
- -
Pass -
-
Pass
-
-
Pass
2023
Pass
- -
Pass -
-
Pass
-
-
Pass
2024
Pass
- -
- -
-
-
-
-
-
Clayton WWTP-
Little Creek WRF
NCO025453/001
County:
Johnston
Region:
RRO
Basin:
NEU02
Mar Jun Sep Dec
Ceri7dPF
Begin:
5/1/2014
chr lim: 2.0% @2.5
M
NonComp: Single
7Q10: 186
PF: 2.5
IWC: 1.6
Freq: Q
J
F M
A M
J
J
A
S
O
2020
-
- Pass
- -
Pass
-
-
Pass
-
2021
-
- Pass
- -
Pass
-
-
Pass
-
2022
-
- Pass
- -
Pass
-
-
Pass
-
2023
-
- >8 Pass
- -
Pass>8
-
-
Pass>8
-
Legend: P=
Fathead minnow
(Pimohales
oromelas). H=No Flow (facilitv is active), s = Split test between Certified
Labs
Page 20 of 107
SOC JOC:
N D
SOC JOC:
N D
SOC JOC:
N D
SOC JOC:
N
D
Pass
Pass
Pass
SOC JOC:
N D
>100 >100
SOC JOC:
N D
Pass
Pass
Pass