NC0088307_Fact Sheet_20240731

NCDEQ/DWR
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO088307
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:
Cape Fear Public Utility Authority / Richardson WTP
Applicant Address:
235 Government Center Drive; Wilmington, NC 28403
Facility Address:
637 Groundwater Way, Wilmington, NC 28411
Facility Class/Permit Status:
Physical- Chemical Not Classified WPCS / Renewal
Contact Emails
[e-mail]; [e-mail];
[e-mail]; carel.vanderme
den cfpua.org
Permitted Flow
(as built)
Max Monthly
Avg -
1.33 MGD
Type of Waste
100% Industrial
Wastewater from cartridge and
nano membrane filter concentrate
Avg Flow -
1 0.90 MGD
Receiving Stream
Intercoastal Waterway
Stream Class ID
SA; ORW 18-87- 11.5
River Basin
White Oak
Subbasin
03-06-24
HUC
030203020401
Quad/USG S Too
J27SE Scotts Hill
7Q10 Sum Win cfs
Tidal
3002 cfs
Tidal
Avg. Stream Flow cfs
Tidal
IWC % sum/win
100 %
County
New Hanover
Regional Office
WiRO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / May 28, 2024 updated July 29 2024
Does permit need daily max NH3-N limits?
No
Does permit need TRC limits/language?
No
Does permit have toxicity testing?
Yes - Already in permit
Does permit have Special Conditions?
WET Requirements; TMDL Re -Opener; Added
PFAS Requirements; Added Disposal of Spent
Membrane Cleaning Solution Condition
Does permit have instream monitoring?
No
Stream on 303 d List? For w arameter?
Statewide Mercury,
Any compliance concerns?
No Issues
Any modifications since last permit?
No modifications noted in the application, but a
subsequent email noted the facility expanding to a
potable capacity of 7 MGD in 2021.
New expiration date:
September 30, 2029
FACILITY OVERVIEW:
The Cape Fear Public Utility Authority (CFPUA) operates the Richardson WTP. The facility was previously
permitted as the Ogden Nanofiltration WTP but CFPUA staff noted during the review process (email on May 28,
2024) that with modifications in 2021 the facility is now referred to as the Richardson WTP. This plant
discharges wastewater from spiral wound cartridge filters and nanofiltration membranes used in the treatment
of raw water for potable water development. The water treatment plant currently has a design capacity of 7.0
MGD and a maximum monthly average wastewater discharge of 1.33 MGD (last three years of data). The plant
plans future expansion up to 9 MGD. This WTP facility is located at 637 Groundwater Way near Wilmington, in
New Hanover County.

Water and Wastewater treatment systems utilize:
■ Spiral wound cartridge filters
■ Nanofiltration membranes
■ Tray aeration
Chemicals added during process: anti-scalant; sodium hypochlorite; sodium hydroxide; fluoride, corrosion
inhibitor. Only anti scalant appears to be added to water prior to discharge at NPDES outfall.
Raw Water Treatment Process: (from application and historical documents)
The water treatment plant draws water from groundwater wells in the Castle Hayne and Pee Dee aquifers. The
pH of the raw water is adjusted and an anti-scalant is added. Water flows through spiral wound cartridge filters
and then through nanofiltration membranes. Permeate (treated water) from the process goes through tower
aeration and has sodium hypochlorite, sodium hydroxide, fluoride and a corrosion inhibitor added before going
to potable water storage and then to the distribution system.
Wastewater and Treatment Process: (from application, and historical documents)
Wastewater comes largely from the concentrate produced in the membrane treatment process but also may
include untreated raw water from the groundwater sources. There is no treatment of the wastewater prior to
discharge. The facility does have the ability to take wastewater from a portion of the Castle Hayne treatment
skid and send it to a POTW.
The outlet pipe is a significant distance to the east of the facility. Old documents in the file note a 5.1 mile, 16"
force main that transports the wastewater from the WTP to the discharge point at the Atlantic Intercoastal
Waterway near the bridge to Figure 8 Island on Bridge Road. The outfall has a diffuser with four 8" ports
discharging at a depth of around 12 feet. The ports are distributed over a 12 square foot base.
APPLICATION
The Water Treatment Plant is operated by the Cape Fear Public Utility Authority (CFPUA). The application
outlines a treatment process as discussed above utilizing cartridge filtration and nanofiltration membranes to
produce potable water with wastewater from the membrane concentrate being discharged. Raw water is noted
as coming from wells from the Castle Hayne and Pee Dee aquifers. The application notes average flow from the
concentrate between 0.023 and 1.3 MGD (see further discussion under the flow parameter). The application
does indicate that flows may be higher during startup or shut down.
The facility provided monitoring data from the Tables in Form 2C and provided information on PFAS
parameters and other potential pollutants beyond the parameters in the tables. The data submitted has been
summarized by Division review staff in a spreadsheet attached to this Fact Sheet. The data results presented
were compared to standards or other water quality criteria where available to determine if any of the
parameters were of concern for the permit and needed to be monitored. The parameters from the 2C Tables
were either already addressed in the permit or did not appear to be of concern based on these reviews. The
same was true for parameters from the chemical addendum process.
For the reported PFAS data there were a number of detected parameters. The Division has determined that
facilities reporting detects for PFAS data at WTPs will be required to gather additional data on certain
parameters. EPA has recently (April 10, 2024) established drinking water individual Maximum Contaminant
Levels (MCLs) for five PFAS and per- and polyfluoroalkyl substances and one additional Hazardous Index MCL
accounting for combined levels of two or more of four PFAS substances. Where WTPs report detection of these
PFAS parameters they are being added to the monitoring requirements for the permit to gather additional
information. Monitoring will be quarterly and will begin when EPA has established the appropriate analytical
methods for analysis of these parameters under 40CFR Part 136. The parameters added are PFOA, PFOS,
PFHxS, PFNA, HFPO-DA and PFBS(part of the hazardous index determinations).
Richardson WTP Fact Sheet
NPDES Renewal 2024 — May 28, 2024 — updated July 29, 2024
Page 2

INSPECTION
The most recent inspection occurred on December 21, 2020. The inspection report did not note any problems
and the facility was in compliance.
COMPLIANCE:
This facility has not had any enforcement action with penalties. The facility has not had any NOVs or NODS.
There were some minor monitoring violations, but none that resulted in any Division actions.
MONITORING DATA REVIEW:
Parameter Units
Min
Max
Avg
Permit Limit
Comments
Flow (MGD)
0.42
1.92
0.87
Data for full permit cycle
Temperature (°C)
18.0
20.0
18.7
Not Required in Permit
Dissolved Oxygen (mg/L)
0.1
0.9
0.4
See discussion below
Salinity (ppth)
1.00
1.00
1.00
Conductivity (µmhos/cm)
527
2,460
1,849
TSS (mg/L)
1.25
29.50
3.00
20 MA
30 DM
TDS (mg/L)
291
1,940
1,494
pH (su)
6.60
7.70
N/A
2: 6.8 and :5 8.5
Turbidity (NTU)
0.34
170.00
31.60
-
Half of values over 25 NTU; see below
Total Copper (µg/L)
0.25
2.50
0.55
1.85 MA
2.90 DM
See RPA Discussion Below
Total Arsenic (µg/L)
0.13
5.00
0.65
-
See RPA Discussion Below
Total Chloride (mg/L)
62.00
130.00
96.28
-
See Discussion Below - remove
Total Zinc (µg/L)
2.50
5.00
3.92
See RPA Discussion Below; No Detects
Ammonia Nitrogen (mg/L)
0.52
2.93
1.17
Total N (mg/L)
0.59
1.8
1.2
-
Total P (mg/L)
0.07
1.44
0.52
-
Whole Effluent Toxicity
N/A
N/A
N/A
-
Passed all tests
MA - Monthly Average DM - Daily Max QA - Quarterly Average DA - Daily Average Summer- April through Oct Winter -Nov through March
Note: DMR values reported as "Less Than <" were included in the data analysis at lh the less than value. Minimum values shown may also be lh reported value.
The data reviewed for the renewal is from February 2018 through March 2024.
REVIEW OF PERMIT MONITORING AND LIMITS:
Flow - The maximum monthly average flow from the DMRs for the last three years (April 2021- March 2024)
was 1.33 MGD. The Division has determined that all WTPs should be given flow limits in order to provide
additional protection to receiving waters. These limits are to be based on the maximum monthly average flow
plus a 15% adjustment which would lead to a flow limit of 1.53 MGD implemented as a monthly average limit.
In previous permit cycles this permit has had an authorized expansion discharge of up to 2.0 MGD with effluent
limits and monitoring that were essentially the same as the lower flow. This expansion was removed by the
Division and considered unnecessary when flow limits were removed from WTPs. Since the CFPUA had
previously had this approved flow limit, with the same effluent conditions, the Division does not feel that it is
appropriate to establish a flow limit now that is lower than this previous expansion allowance. The permit
includes a flow limit of 2.0 MGD applied as a monthly average. Application information notes that flows may be
higher during startup or shut down than during regular discharge.
Whole Effluent Toxicity (WETS. - The facility has passed all WET tests in the most recent permit cycle. This is a
cartridge filter and nanofiltration WTP discharging to a tidal area. By WTP guidance these facilities should have
Richardson WTP Fact Sheet
NPDES Renewal 2024 - May 28, 2024 - updated July 29, 2024
Page 3

acute monitoring requirements. Permittee comments on the draft requested annual monitoring. Quarterly
monitoring maintained - see discussion on page 5 of the Fact Sheet.
TSS. TDS and Turbidity - TSS values have been well within acceptable ranges. TDS values are most likely within
expected levels for the characteristics of the discharge. Turbidity values have been a bit high. Around half of
the 149 data points for turbidity were above the coastal limit of 25 NTU. The receiving waters are not impaired
for turbidity or sediment related parameters so there is no turbidity limit in the permit, but this parameter
should continue to be evaluated.
Nutrients (TN and TP) - These values have not shown any potential issues.
Ammonia - Nitrogen (NH3-Nl - The NH3-N values reported do not appear to be excessively high. Since
monitoring values are > 1mg/L the WTP guidance calls for continued monthly monitoring.
pH - Values for pH are all within the acceptable range.
Dissolved Oxygen (DO) - Dissolved oxygen levels in the effluent continue to be at very low levels (average of 0.4
mg/L). These levels are consistent with those reported in the previous permit cycle. At that time the facility
conducted U/D monitoring that did not show impacts to the receiving water. No changes or additional
monitoring are proposed at this time.
Salinity and Conductivity - These reported values do not appear to be of concern given the nature and
characteristics of the discharge. Salinity monitoring removed after permittee comments on the draft- see
discussion on page 5 of the Fact Sheet.
Total Chloride - There is no saltwater standard for this parameter and the values reported appear to be very
low compared to expected saltwater values. This parameter has been removed from the monitoring
requirements for the permit.
Reasonable Potential Analysis (RPA) - An RPA analysis was performed for three parameters - Copper, Zinc and
Arsenic. In the 2018 permit renewal the RPA analysis showed reasonable potential for Cu and permit limits
were added to the permit. The permit limits for Cu became effective February 1, 2023. In the most recent
permit cycle all values for Cu have been below the permit limits. The facility has noted that they have been able
to stay within the Cu limits without taking additional actions or following through with a proposed dilution
study.
With the current RPA analysis none of these three parameters was shown to have reasonable potential to cause
an instream water quality issue. The following actions have been taken for these parameters based on the RPA
results:
Cu -The permit limit for Cu has been removed in this permit but monitoring will be maintained. While
there was only one value above detection, that value was more than 1/2 of the allowable maximum.
Monitoring frequency for Cu will be relaxed to quarterly.
Zn - All of the values for Zn were reported as below detection. Zinc monitoring will no longer be
required, and the parameter has been removed from the permit.
As - Three reported As values were above detection but none of the reported values were above 1/2 the
maximum allowable value. Monitoring will continue to be required for this permit cycle but monitoring
frequency has been reduced to quarterly. As monitoring removed after permittee comments on the draft
- see discussion on page 5 of the Fact Sheet.
HAS Parameters - See discussion above under Application.
Richardson WTP Fact Sheet
NPDES Renewal 2024 — May 28, 2024 — updated July 29, 2024
Page 4

NCG59 GENERAL PERMIT EVALUATION
The Richardson WTP does not utilize treatment technologies that are authorized under the NCG59 permit
coverage (membrane technology is not covered). In addition, the facility discharges to waters classified ORW
and the general permit is not allowed for discharges to these waters.
RESPONSE TO COMMENTS ON DRAFT PERMIT
The permittee - CFPUA - provided written comments to the draft permit on July 15, 2024. These comments
and the Division response is summarized below.
Arsenic - CFPUA commented that the data results for arsenic supported removal of monitoring for this
parameter. The Division has further reviewed the results for arsenic data. The reasonable potential
analysis does show that all reported values were less than 1/2 the allowable level. The Division agrees
with this request, and monitoring for this parameter has been removed from the permit.
Salinity - CFPUA comments requested removal of salinity due to the data results and that conductivity
monitoring was sufficient to evaluate impacts. The Division agrees with this request and salinity
monitoring has been removed from the permit.
Whole Effluent Toxicity - CFPUA requested reduction of toxicity monitoring from quarterly to annually.
Division staff for permitting and aquatic toxicology have reviewed this request. The concentrate being
discharged from your treatment plant has the potential to have a high content of several constituents
that can impact the water quality of receiving waters. With no treatment of the concentrate prior to
discharge the Division feels that more regular quarterly toxicity requirements are necessary in the
permit to avoid any potential impacts. Maintaining this monitoring is consistent with Division guidance
for your discharge. Quarterly monitoring has been maintained in the final permit.
FILE HISTORY REVIEW SUMMARY
• August 1, 2000 -Speculative Limits for New Hanover County WTP -The speculative limits were given for a
proposed WTP discharging to Pages Creek, an SA water, at a flow of 2.0 MGD. The letter outlined the need
for an Environmental Assessment for the project. Speculative limits were given as:
Effluent
Characteristics
Monthly
Avg
Daily Max
Effluent
Characteristics
Monthly Avg
Daily Max
Flow (MGD)
2.0
Total P m L
2 DM if polyphosphates added
TSS m L
20
30
Iron µ L
Monitor
SS ml L
0.1
0.2
TRC µ L
Monitor
Turbidity NTU
25Instream
Aluminum µ L
Monitor
H SU
6.8 to 8.5
1 Silver µ L
Monitor
Arsenic µ L
25
Zinc µ L
Monitor
Beryllium µ L
0.06
Copper µ L
Monitor
Cadmium µ L
IS
Salinit t
Monitor
Chromium µ L
10
Chloride µ L
Monitor
Cyanide µ L
0.5
TOC mg/LJ
Monitor
Mercury µ L
0.012
Fluoride µ L
Monitor
Nickle µ L
4.2
WET
Pass Fail
Selenium µ L
36
Lead µ L
12.5
December 14, 2004 - Speculative Limits for Proposed RO Discharge - These limits were established for a
discharge of up to 2.0 MGD of reverse osmosis reject water from a proposed WTP for a discharge location in
the Intercoastal Waterway - class SA ORW. The letter again noted the potential need for an Environmental
Assessment. The provided information noted a change in discharge location due to the potential impacts to
Pages Creek. The WTP was proposed to replace several private WTPs and would have a 6 MGD potable
water capacity. Speculative limits were given as:
Richardson WTP Fact Sheet
NPDES Renewal 2024 — May 28, 2024 — updated July 29, 2024
Page 5

Effluent
Characteristics
Monthly
Av
Daily Max
Effluent Characteristics
Monthly
Avg
Daily Max
Flow MGD
2.0
Temperature °C
Monitor E, U, D
H SU E, U, D
6.8 to 8.5
Salinity t
Monitor E, U, D
TRC L
17
Conductivity mhos cm
Monitor E, U, D
Arsenic L
Limit based on potential
DO m L
Monitor E, U, D
Copper L
Limit based on potential
TDS m L
Monitor
Chloride µ L
Limit based on potential
Total N m L
Monitor
Iron µ L
Limit based on potential
Total P m L
Monitor
Fluoride µ L
Limit based on potential
Zinc µ L
Limit based on potential
NH3-N µ L
Limit based on potential
• May 15, 2007 - Permit Issuance - The permit process included a public hearing because the discharge was
proposed to ORW waters. The proposed system is described as being a 6 MGD treatment facility that will be
expanded to 9 MGD. The system will treat water from wells in the Pee Dee and Castle Hayne aquifers. The
primary water treatment will be cartridge filtration and nanofiltration. The water from the Castle Hayne
aquifer is also proposed to have pretreatment of potassium permanganate and green sand filtration.
Following treatment permeate from all treatment trains is blended and has chemical addition of sodium
hypochlorite (disinfection), sodium hydroxide (pH adjustment) and corrosion inhibitor prior to going to
storage for distribution. Backwash water proposed to be clarified and then decanted to outfall along with
concentrate. Discharge is to the Atlantic Intercoastal Waterway (AIWW) through a 5.1 mile, 16" force main
discharging near the bridge at Figure 8 Island on Bridge Road. The outfall will have a diffuser with four 8"
ports installed at a 12 foot depth. Ports distributed over a 12 square foot base. The current discharge is
proposed to be 1.38 MGD with a final discharge of 2.0 MGD when the plant expands to 9 MGD.
The project produced an Environmental Assessment document that received a Finding of No Significant
Impact (FONSI). An EAA included with the application found the discharge option to be the most
economically feasible alternative. The application includes maps locating the outfall pipe and discharge
pipe, etc. The public hearing for the permit did result in comments that were addressed by hearing officer
recommendations and incorporated into the final conditions of the permit. The permit is set up to require
approval of an Authorization to Construct and construction prior to discharge. The permit conditions
included two effluent pages for phased discharge. The conditions were the same with the exception of the
flows being 1.38 and 2.0 MGD.
Flow
TSS
pH
TRC
Turbidity
Monitoring Parameters
MGD
m L
SU
L
NTU
1.38/
Temp, DO, Salinity & Conductivity - E,U1,U2,D
2.0
10 / 15
6.8 to 8.5
13
25 instream
TDS, Cyanide, Copper, Iron, Lead, Chloride, Zinc,
Fluoride, NH3-N, TN, TP, Aquatic Tox
The permit specified two upstream and one downstream sampling locations for parameters as noted above.
The permit included a Discharge Special Condition for the diffuser and a Special Condition requiring
evaluation of alternatives to discharge of the greensand filter backwash (0.1 MGD).
• October 3, 2007 - Authorization to Construct (ATC) - The ATC authorized the construction of the
concentrate discharge main and outfall including the piping, diffuser, anchor blocks, etc.
• May 5, 2008 - Name Owner Change - Permit modification to change the permit owner to Cape Fear Public
Utility Authority.
• May 8, 2008 - Permit Modification to change effective date of all CFPUA permits to July 1, 2008.
• August 10, 2009 - Permit Modification - This modification to remove instream monitoring requirements.
The CFPUA requested the modification because the conditions at the outfall make any data of little practical
use. The modification also added the TRC footnote on compliance level. Handwritten note on the letter
indicates the plant is still not operational.
• June 14, 2010 - Notification of future TSS limits changes. The Division letter alerted the permitee to future
changes based on the facility's discharge to HQW waters (SA waters are HQW by definition). The letter
Richardson WTP Fact Sheet
NPDES Renewal 2024 - May 28, 2024 - updated July 29, 2024
Page 6

outlined that the TSS limit for discharge other than greensand filter backwash would be set at 20 mg/L in
accordance with 213.0224. Changes would be implemented with permit renewal.
• October 2009 - The first DMR data appears in BIMS so it looks as if the plant is operational around October
2009.
• July 20, 2012 - Permit Renewal - The application cover letter noted that the final plant design changed and
removed the proposed greensand filters and associated chemical feed and waste tanks. This leaves
treatment processes that are the same for raw water taken from either the Pee Dee or Castle Hayne
aquifers. There are multiple trains of spiral wound cartridge filters and nanofiltration membranes.
The staff report from the WiRO for the permit renewal indicates some concerns for TSS and turbidity levels
which had been high for all DMRs since the facility began discharging. The TSS limit in the permit was not
applicable because it only applied to greensand filter backwash. The CFPUA indicated the high levels were
due to iron precipitating out before the samples were analyzed and not indicative of the discharge to the
surface water. The staff report suggested requiring the CFPUA to investigate and that the permit should
include a reopener clause for possible TSS and SS limits. These issues are not directly addressed in the Fact
Sheet but there is an added requirement for short term instream monitoring to assess receiving stream
impacts.
Changes in the final permit from the previous permit - TRC is removed because chlorinated water is not
used for backwash; some monitoring frequencies are changed based on Division policy; Monitoring
removed for iron (Division policy), lead & cyanide (monitoring results all below detect); Limited (4 month)
instream sampling for Temp, DO and TSS required to evaluate impact to receiving stream. The TSS limit is
set at 20 / 30 mg/L for all discharges and given a compliance period until September 2013. The permit
added a special condition for a re -opener for TMDL implementation. Permit Effluent Table Requirements:
Flow
TSS
pH
Total Cu
Turbidity
Monitoring Parameters
MGD
m L
SU
L
NTU
6g
Temp, DO, TSS - E, U, D (4 months)
1.38/2.0
20 / 30
5°
2 90/
25 instream
Salinity, Conductivity, TDS, turbidity, Copper, Chloride, Zinc,
Fluoride, NH3-N, TN, TP, Aquatic Tox
January 5, 2018 - Permit Renewal - The permit renewal included a number of changes/updates to permit
and footnote language and map components, addition of regulatory citations, parameter codes, etc. The
electronic DMR submittal language was added. Flow limits were removed consistent with WTP Guidance,
which resulted in the removal of the second effluent table associated with expansion. Short term instream
monitoring requirements were removed from the permit. Turbidity limit was removed, most likely because
the receiving stream isn't impaired for sediment issues. Monitoring for fluoride was removed because of no
saltwater standards. Total arsenic was added back based on WTP guidance. Limits were added for Total
Copper and a compliance schedule was included making the limits effective February 1, 2023. Conditions in
the permit:
Flow
TSS
pH
Total Cu
Monitoring Parameters
(MGD)
m L
SU
L
N/A
20 / 30
6.8 to 8.5
1.85 / 2.90
TDS, turbidity, Copper, Chloride, Zinc, NH3-N,
TN, TP, Aquatic Tox
The permit added a special condition for compliance with the Cu limit. This included submittal of a
Corrective Action Plan for meeting the limit and added the special condition for eDMR submittal.
May 11, 2018 - Model Plan for Dilution Study - As part of the CFPUA's requirements for a CPA they
submitted this plan for a dilution study. This plan was subsequently revised in a June 28, 2018 submittal.
July 16, 2018 - Email approval of the Modeling plan.
January 29, 2019 - Corrective Action Plan - In compliance with the permit the CFPUA submitted the CAP to
outline measures to meet the Cu limits. At the time of submittal, the CFPUA had found that the facility data
showed routine compliance with the limits, but they outlined measure for the next year to continue to
review additional data, well results and operational conditions to assure compliance.
Richardson WTP Fact Sheet
NPDES Renewal 2024 - May 28, 2024 - updated July 29, 2024
Page 7

PROPOSED PERMIT CHANGES:
• Plant name has been updated to Richardson WTP throughout documents.
• 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. The Supplement
also includes language requiring the approval of expansion to 9 MGD from the DWR Public Water Supply
Section.
• A flow limit has been added to the permit and set at 2.0 MGD. This value is consistent with expansion
limits that were previously given to this permittee.
• All parameters (TKN, NOs-N + NO2-N) for calculating TN have been added to the Effluent Table for
reporting on the eDMR.
• Salinity monitoring removed after CFPUA comments on draft (see discussion above).
• Based on the results of the RPA analysis the following changes have been made:
- Limits for Cu have been removed and monitoring frequency has been reduced to quarterly.
- Monitoring for Zn has been removed from the permit.
- Monitoring frequency for As has been reduced to quarterly. As monitoring removed after comments
from CFPUA (see discussion above)
• Based on data submitted with the application the permit includes monitoring to gather additional
information on certain PFAS parameters [Section A.(3.)].
• The language in the Effluent Table and Section A.(2) for WET requirements has been updated.
• Section A.(6.) has been added to address disposal of spent membrane cleaning solution.
• Permit map and descriptive information on the permit map have been updated.
• Expiration date has been changed to September 31, 2029, to allow for a nearly full five year permit term.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: June 11, 2024
Permit Scheduled Effective Date: October 1, 2024
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett at
[e-mail] .
Richardson WTP Fact Sheet
NPDES Renewal 2024 — May 28, 2024 — updated July 29, 2024
Page 8

LOCAL'190
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StarNews I The Dispatch
Times -News
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Deq-Division Of Water Res
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STATE OF NORTH CAROLINA, COUNTY OF NEW HANOVER
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the city of Wilmington, and of general circulation in the County of
New Hanover, State of North Carolina, and personal knowledge of
the facts herein state and that the notice hereto annexed was
Published in said newspapers in the issue dated:
06/14/2024
and that the fees charged are legal.
Sworn to and subscribed before on 06/14/2024
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Page 1 of 2

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
NC0088307 Richardson WTP-The North Carolina Envi-
ronmental 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 signifi-
cant 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: hffps:Hdeq.nc.gov/public-
notices-hearings,or by calling [phone]. Cape Fear
Public Utility Authority [235 Government Center Drive,
Wilmington, NC 284031 has requested renewal of NPDES
permit NC0088307 for the Richardson WTP, located in New
Hanover County. This permitted facility discharges treated
wastewater to the Atlantic I ntercoastal Waterway, a class
SA; ORW water in the White Oak River Basin. Some of the
parameters in the permit are water quality limited. This
discharge may affect future allocations in this segment of
the Atlantic I ntercoastal Waterway.
June 14 2024
LWLM0115375

Bennett, Bradley
From: Kenneth Waldroup <[e-mail]>
Sent: Wednesday, July 31, 2024 11:55 AM
To: Bennett, Bradley
Cc: Sydney Valliant; Craig Wilson; Beth Eckert; Ben Kearns
Subject: [External] RE: Final Permit for Richardson WTP - NCO088307
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.
Bradley,
It good to connect with you again and to see you are doing well. Thank you for providing the final issued permit for
the Richardson WTP— NC0088307. I am confirming that we received the attached permit document and that we
are able to open, view, download and print the document for our records.
-Ken
Kenneth Waldroup, P.E.
Executive Director
Cape Fear Public Utility Authority
o: 910-332-6669 1 c: 919-369-3240
235 Government Center Dr., Wilmington, NC 28403
www.cfpua.org I Facebook I Twitter
:M
�CaPe Fear
Fabl1c Ut111[Y Aulhorlty
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, July 31, 2024 10:49 AM
To: Kenneth Waldroup <[e-mail]>
Cc: Sydney Valliant <[e-mail]>; Carel Vandermeyden <[e-mail]>; Beth Eckert
<[e-mail]>
Subject: Final Permit for Richardson WTP - NCO088307
This Message Is From an External Sender
This email originated outside of CFPUA. Do not click links or open attachments unless you recognize the sender and know the
content is safe. If you have any doubt, report it to helpdesk.
Report Suspicious

Hey Kenny,
Hope you are doing well. Attached is the final issued permit for the Richardson WTP — NC0088307. In the cover
letter you will find our responses to your comments on the draft permit. This permit will become effective on
October 1, 2 2024. Until that time, please continue to meet the conditions of your existing permit. If you have any
questions, please feel free to contact me.
Please respond to this email to verify that you received the attached permit document and that you were able to
open, view, download and print the document for your records.
Thanks for all the help from various CFPUA staff in working through this renewal process!
::
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: Bennett, Bradley
Sent: Wednesday, July 31, 2024 11:06 AM
To: Lievre, Bryan K; Tharrington, Tom
Subject: Final Permit for Richardson WTP - NCO088307
Hey Guys,
The Richardson WTP permit — NCO088307 was signed today and it has been forwarded through email to the Cape
Fear Public Utility Authority. There were some changes in the final permit based on comments from the CFPUA
(we forwarded those to you earlier). We agreed to their requests to remove arsenic and salinity monitoring but we
did not agree on their request to reduce WET frequency. This permit will become effective October 1, 2024. We
will get it issued in BIMS in the next few days. The permit and fact sheet have been uploaded to Laserfiche.
:.
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

Bennett, Bradley
From:
Nicholson, Molly
Sent:
Wednesday, July 31, 2024 11:14 AM
To:
Bennett, Bradley
Cc:
Moore, Cindy
Subject:
RE: Final Permit for Richardson WTP - NC0088307
Hi Bradley,
Thank you for letting us know. Either an attached copy of a permit or a link to the permit on Laserfiche would be
great for me. I appreciate you asking.
Best,
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
molly.nicholson(a)deq.nc.gov
1621 Mail Service Center, Raleigh, NC 27699-1623
Submit AT Forms electronically to: [e-mail]
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, July 31, 2024 11:12 AM
To: ATForms.ATB <[e-mail]>
Cc: Moore, Cindy <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: Final Permit for Richardson WTP - NC0088307
Hey Guys,
The permit for the Richardson WTP— NC0088307 has been issued. The final permit is attached. I just wanted to
point out that we denied their request to reduce WET monitoring frequency and it remained at quarterly in the
permit. The final permit and cover letter are attached. The permit will be effective October 1, 2024.
Just a quick question —when the final permit is issued and I send you this notification, I usually attach a copy of the
permit in the email. However, the permit and fact sheet have usually been uploaded to Laserfiche by then
also. Would you prefer to continue to get a copy attached to the email or just download it from Laserfiche?
Thank for your help!
W.

Bennett, Bradley
From: Lievre, Bryan K
Sent: Tuesday, July 16, 2024 9:44 AM
To: Bennett, Bradley; Tharrington, Tom
Subject: RE: blic FW: [External] RE: Draft Permit for Richard
I don't have any comments, but thanks for sending the message Bradley.
Bryan Lievre, PE
Division of Water Resources - Wilmington Regional Office
Office of Continuous Improvement (OCI)
NC Department of Environmental Quality
Office: [phone]
Cellular: [phone]
o Get info on ARPA Project Permitting: ARPA Env. Permitting
o Search DEQ Permits: NC DEQ Permit Directory
o Apply for Funding: I Need Funding INC DEQ
4�.-; : :,. �.;- :h:. - � E
00"rgMenl o! FnWronrnbmal Ow,IdY
Email correspondence to and from this address is subject to the North
aroMa Public Records Lair and may be disclosed to third panties.
From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, July 16, 2024 9:00 AM
To: Tharrington, Tom <[e-mail]>; Lievre, Bryan K <[e-mail]>
Subject: blic FW: [External] RE: Draft Permit for Richard
Hey Guys,
Just anted to forward the comments I received from the Cape Fear Public Utility Authority on the Richardson WTP
(NC0088307) draft permit. Tae a look and let me know if you have any comments on their requested changes.
Thanks
W.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: brad ley.ben netta(�,deq. nc.gov
Raleigh, NC 27699-1617

Email correspondence to and from this address may be subject to public records laws
From: Sydney Valliant <[e-mail]>
Sent: Monday, July 15, 2024 12:06 PM
To: Bennett, Bradley <bradley.ben [e-mail]>
Cc: Beth Eckert <[e-mail]>; Ben Kearns <Ben.Kea [e-mail]>; Allan Upham
<[e-mail]>; Jill Deaney <[e-mail]>
Subject: RE: [External] RE: Draft Permit for Richard
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.
Bradley,
I have attached CFPUA's comment letter in response to the Drafted NPDES Permit NCO088307 for Richardson
WTP. Please let us know if you have any questions or concerns and we appreciate your help on getting the permit
drafted!
Thankyou,
Sydney R. Valliant
Environmental Regulatory Specialist
Cape Fear Public Utility Authority
0: 910-332-6554 1 C: 910-691-8797
637 Groundwater Way. Wilmington, NC 28411
Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to
third parties.
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Monday, July 15, 2024 9:41 AM
To: Sydney Valliant <[e-mail]>
Cc: Beth Eckert <[e-mail]>
Subject: RE: [External] RE: Draft Permit for Richard
This Message Is From an External Sender
Report Suspicious
This email originated outside of CFPUA. Do not click links or open attachments unless you recognize
content is safe. If you have any doubt, report it to helpdesk.
If you can get the comments to us today sometime that should be fine.

Bennett, Bradley
From: Moore, Cindy
Sent: Tuesday, July 16, 2024 8:19 AM
To: Bennett, Bradley; Nicholson, Molly
Subject: Re: Question from Permittee - Cape Fear Public Utility - Richardson WTP - NCOO883O7
The only time that I know DWR has reduced tox is when the facility was moved to a general permit or was
determined to be a 100% domestic facility. As you well know, not all facilities that are 100% domestic get reduced.
do not know of another instance where a tox requirement has been removed. This decision would be beyond
ATB's control.
Thx,
Cindy
From: Bennett, Bradley <bradley.ben [e-mail]>
Sent: Tuesday, July 16, 2024 8:03 AM
To: Moore, Cindy <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: Question from Permittee - Cape Fear Public Utility - Richardson WTP - NCOO883O7
The Richardson WTP (NCOO883O7) has been at public notice and the permittee—Cape Fear Public Utility Authority
sent in comments about the draft, including this comment about their tox requirements. I wanted to get your
thoughts on their request for annual tox. See their comments below:
"The toxicity tests during the monitoring period and those since submittal of the permit renewal
package have all passed. There has only been one failure since the discharge began. This failure
was on 4/7 /15. Based on the long history of compliance prior to that and since that event, we
feel the failure was an anomaly and are requesting a reduction to annual toxicity tests."
Let me know your comments on this request.
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
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: Sydney Valliant <[e-mail]>
Sent: Monday, July 15, 2024 12:06 PM
To: Bennett, Bradley
Cc: Beth Eckert; Ben Kearns; Allan Upham; Jill Deaney
Subject: RE: [External] RE: Draft Permit for Richard
Attachments: Richardson WTP NPDES Draft Permit Comment Letter_Signed_7.15.24.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.
Bradley,
have attached CFPUA's comment letter in response to the Drafted NPDES Permit NCO088307 for Richardson
WTP. Please let us know if you have any questions or concerns and we appreciate your help on getting the permit
drafted!
Thankyou,
Sydney R. Valliant
Environmental Regulatory Specialist
Cape Fear Public Utility Authority
0: 910-332-6554 1 C: 910-691-8797
637 Groundwater Way. Wilmington, NC 28411
Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to
third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Monday, July 15, 2024 9:41 AM
To: Sydney Valliant <[e-mail]>
Cc: Beth Eckert <[e-mail]>
Subject: RE: [External] RE: Draft Permit for Richard
This Message Is From an External Sender

This email originated outside of CFPUA. Do not click links or open attachments unless you recognize the sender and know the
content is safe. If you have any doubt, report it to helpdesk.
Report Suspicious
If you can get the comments to us today sometime that should be fine.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: brad Iey.ben nettaMeg.nc.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Sydney Valliant <[e-mail]>
Sent: Monday, July 15, 2024 9:39 AM
To: Bennett, Bradley <bradley.ben [e-mail]>
Cc: Beth Eckert <[e-mail]>
Subject: [External] RE: Draft Permit for Richard
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning, Bradley
Thank you for sending us the Richardson WTP NPDES Permit Draft. We do have a couple comments regarding the
draft permit and should have the letter sent your way sometime after lunch, please let me know if you need the
letter sooner and we will try our best to complete this.
Again, thank you for you help and we will be in contact shortly with the comment letter. Please feel free to call me
at 910-691-8797 with any questions,
Sydney R. Valliant
Environmental Regulatory Specialist
Cape Fear Public Utility Authority
0: 910-332-6554 1 C: 910-691-8797
637 Groundwater Way. Wilmington, NC 28411

Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to
third parties.
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Thursday, June 13, 2024 9:56 AM
To: Kenneth Waldroup <[e-mail]>; Beth Eckert <[e-mail]>
Cc: Sydney Valliant <[e-mail]>; Carel Vandermeyden <[e-mail]>
Subject: Draft Permit for Richard
This Message Is From an External Sender
This email originated outside of CFPUA. Do not click links or open attachments unless you recognize the sender and know the
content is safe. If you have any doubt, report it to helpdesk.
Report Suspicious
Attached is the draft permit for the Richardson WTP — NCOO883O7. This draft will be going to public notice this
week. If you have any comments on the draft, please let me know.
Please respond to this email to verify that you received the draft document and were able to download
open, save and print the document for your records.
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
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.

IMCOPO Fear
Public Utility Authority
Stewardship. Sustainability. Service.
July 15, 2024
NC DEQ Division of Water Resources
Water Quality Permitting Section
Attn: Bradley Bennett
1617 Mail Service Center
Raleigh, NC 27966-1617
Kenneth Waldroup
Executive Director
235 Government Center Dr.
Wilmington NC, 28403
910-332-6625
[e-mail]
SUBJECT: Drafted NPDES Permit NC0088307
Richardson WTP
Grade I Physical Chemical WPCS, New Hanover County
Section A(1.) Total Arsenic, Salinity, and Toxicity Monitoring Requirements
Dear Mr. Bennett,
Effluent Limitation and Monitoring Requirements for the above mentioned NPDES permit
requires grab samples of effluent from Outfall 001 for Total Arsenic (As) (quarterly) and Salinity
(twice per month). We are requesting both tests be removed from the permit effluent
monitoring requirements. We are also requesting the quarterly toxicity be reduced to annually.
Please see detailed justifications for each in the paragraphs below.
Per the Reasonable Potential Analysis (RPA) for metals submitted in the draft permit sent to us
on June 13, 2023, it states that "only one Ar value was detected" and that "monitoring
frequency for Ar has been reduced to quarterly". We believe Ar in the draft permit is referring
to Arsenic (As) rather than Argon (Ar). The data submitted for review show compliance with all
QA/QC requirements, and concentrations in the discharge are below DWR Lab's practical
quantitation limit (PQL) of 1.0 ug/L. A summary of the detections for As are below:
• 11/3/2020 — 0.42 ug/L
• 1/5/2021— 0.22 ug/L
• 2/2/2021— 0.13 ug/L
These values are all below the DWR Lab's PQL of 1.0 ug/L. Detection limits were 0.1 ug/L for
the three detections listed above. Routine detection limits for samples analyzed during this
timeframe (5/1/2019 — 5/31/2022) were 0.5 ug/L and 1.0 ug/L. If the contract lab running

these samples used the DWR Lab's PQL of 1.0 ug/L for the samples with As detections, they
would all be <1.0 ug/L. This discharge did have one result that was analyzed with a PQL of 2.0
ug/L which was on 8/5/2020. This sample was non -detect (ND) and reported as <2.0 ug/L.
Given the totality of the data during this reporting period and its comparison to NCDEQ's PQLs,
we are requesting Arsenic be removed from the permit effluent limitation and monitoring
requirements.
All salinity values for Richardson WTP Outfall 001 have been <2 parts per thousand since the
permit was issued on July 1, 2007. Conductivity and salinity are measured simultaneously;
conductivity is reported as µhoms and salinity as parts per thousand. We believe the
conductivity value is adequate to evaluate the quality of the discharge water due to the low
salinity levels in the water. We are requesting Salinity be removed from the permit effluent
limitation and monitoring requirements.
The toxicity tests during the monitoring period and those since submittal of the permit renewal
package have all passed. There has only been one failure since the discharge began. This failure
was on 4/7/15. Based on the long history of compliance prior to that and since that event, we
feel the failure was an anomaly and are requesting a reduction to annual toxicity tests.
CFPUA believes the issuance of a modified permit will maintain compliance with the NPDES
permit limits while also being protective of the receiving waters within the Atlantic Intracoastal
Waterway. If you have any further concerns, please feel free to contact me at 910-332-6625 or
Beth Eckert at 910-332-6646.
Sincerely,
Kenneth Waldroup
Executive Director
Cape Fear Public Utility Authority
CC: Helen Perez, NCDEQ
Kenneth Waldroup, Cape Fear Public Utility Authority
Beth Eckert, Cape Fear Public Utility Authority
Jill Deaney, Cape Fear Public Utility Authority
Ben Kearns, Cape Fear Public Utility Authority
Allan Upham, Cape Fear Public Utility Authority

Bennett, Bradley
From: Ward, Sara <[e-mail]>
Sent: Thursday, June 13, 2024 12:53 PM
To: Bennett, Bradley
Cc: Archambault, Jennifer M; Benjamin, Pete
Subject: Re: [EXTERNAL] Draft Permit Renewal for Richardson WTP - NCO088307
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.
Hi, Bradley.
I have taken a new role with FWS, so I've cc'd Pete Benjamin (Field Supervisor) and Jennifer Archambault
(deputy Field Supervisor) for their awareness and to provide a POC for future notices as needed.
Thank you, Sara
Sara Ward (she/her), Policy Analyst
On detail to the Office of Policy Analysis
U.S. Department of the Interior
U.S. Fish and Wildlife Service I Headquarters
100 Conservation Way / P.O. Box 1969
Manteo, NC 27954
703-615-1550 (mobile), sara [e-mail]
1yY" N A T 1 O N
WILDLI
0CCI I� C C V C
From: Bennett, Bradley <[e-mail]>
Sent: Thursday, June 13, 2024 9:56 AM
To: Ward, Sara <[e-mail]>
Subject: [EXTERNAL] Draft Permit Renewal for Richardson WTP - NCO088307
This email has been received from outside of DOI - Use caution before clicking on links, opening
attachments, or responding.
Attached is a draft permit for renewal of a WTP permit in New Hanover County for Richardson WTP —
NC0088307. This permit will be out a public notice this week. If you have any questions or comments please let
us know.

Thanks
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: Haines, Andrew
Sent: Thursday, June 13, 2024 11:05 AM
To: Bennett, Bradley; Humphrey, Jeremy; Bryan-Millush, Erin
Subject: RE: Draft Permit Renewal for Richardson WTP - NCO088307
Thank you for the opportunity to review, Bradley! We do not have any comments on this one. Have a good
afternoon
Andy
Andrew Haines
Environmental Program Supervisor
Division of Marine Fisheries — Shellfish Sanitation and Recreational Water Quality Section
Department of Environmental Quality
PO Box 769
Morehead City, NC 28557
252-515-5617 office
andrew.haines(cDdeg.nc.gov
Please note my new email address and new phone number. The old ncdenr.gov address and old phone number will
continue to work for a short period of time, but please update my contact information in your address book when you have
the opportunity.
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: Thursday, June 13, 2024 9:56 AM
To: Haines, Andrew <[e-mail]>; Humphrey, Jeremy <[e-mail]>; Bryan-Millush,
Erin <[e-mail]>
Subject: Draft Permit Renewal for Richardson WTP - NCO088307
Attached is a draft permit for renewal of a WTP permit in New Hanover County for Richardson WTP —
NC0088307. This permit will be out a public notice this week. If you have any questions or comments please let
us know.
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

Bennett, Bradley
From: Bennett, Bradley
Sent: Thursday, June 13, 2024 9:56 AM
To: Haines, Andrew; Humphrey, Jeremy; Bryan-Millush, Erin
Subject: Draft Permit Renewal for Richardson WTP - NCO088307
Attachments: NC0088307_Draft Permit and Cover Ltr_20240604.pdf
Attached is a draft permit for renewal of a WTP permit in New Hanover County for Richardson WTP —
NC0088307. This permit will be out a public notice this week. If you have any questions or comments please let
us know.
Thanks
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

Bennett, Bradley
From: Bennett, Bradley
Sent: Thursday, June 13, 2024 9:56 AM
To: Talbott, Jeffrey
Subject: Draft permit for Richardson WTP - NCO088307
Attachments: NC0088307_Draft Permit and Cover Ltr_20240604.pdf, NC0088307_Fact Sheet Binder_
20240604.pdf
Hey Jeff,
Here is a draft permit and fact sheet for this facility that is going to public notice this week. Let us know if you see
any issues with the draft.
Thanks
W.
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

Bennett, Bradley
From: Nicholson, Molly
Sent: Friday, June 7, 2024 3:27 PM
To: Bennett, Bradley; Moore, Cindy
Subject: RE: Draft Permit for Richardson WTP - NCO088307
Hey Bradley,
This looks great! I don't have any comments on this.
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. [e-mail]>
Sent: Monday, June 3, 2024 10:18 AM
To: ATForms.ATB <[e-mail]>; Moore, Cindy <[e-mail]>; Nicholson, Molly
<[e-mail]>
Subject: Draft Permit for Richardson WTP - NCO088307
Hey Guys,
Here is a draft for your review. I hope to go to notice with this one next week. Just a note, this one was previously
referred to as Ogden Nanofiltration WTP but is now Richardson WTP— NC0088307. Let me know if you have any
comments.
Thanks
BB
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: Lievre, Bryan K
Sent: Wednesday, June 5, 2024 11:51 AM
To: Bennett, Bradley; Tharrington, Tom
Subject: RE: Notice for Draft Permit for Richardson WTP - NCO088307
Sounds good, thank you.
Bryan Lievre, PE
Division of Water Resources - Wilmington Regional Office
Office of Continuous Improvement (OCI)
NC Department of Environmental Quality
Office: [phone]
Cellular: [phone]
o Get info on ARPA Project Permitting: ARPA Env. Permitting
o Search DEQ Permits: NC DEQ Permit Directory
o Apply for Funding: I Need Funding INC DEQ
4�.-; : :,. �.;- :h:. - � E
00"rgMenl o! FnWronrnbmal Ow,IdY
Email correspondence to and from this address is subject to the North
aroMa Public Records Lair and may be disclosed to third panties.
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, June 5, 2024 8:56 AM
To: Tharrington, Tom <[e-mail]>; Lievre, Bryan K <[e-mail]>
Subject: Notice for Draft Permit for Richardson WTP - NCO088307
Hey Guys,
This draft permit is scheduled for public notice next week. Just wanted to make you aware and go ahead and send
you the draft that will notice.
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

Bennett, Bradley
From: Deuterman, Sydney
Sent: Monday, June 3, 2024 4:42 PM
To: Bennett, Bradley
Subject: Re: One Last WTP Renewal for Review - CFPUA - Richardson WTP - NCO088307
Hey Bradley,
Well done on this one! Here are my comments from my review:
• Facility name in BIMS needs to be updated to Richardson WTP
Permit
• For this facility, do you think the max monthly avg flow still needs to be mentioned on the Supp. To Cover
Sheet? I also think that the line "Discharge shall not exceed a monthly average of 2.0 MGD" is not needed
since the limit is in the effluent table.
• "Grade I" should be changed to "Not Classified" for the facility classification in Section A. (1)
• Units are missing for Salinity, Conductivity, Arsenic, and Copper in the eff. Table
• The units for Total Dissolved Solids is missing the end )
• Since the WET testing condition already details how they can use another test organism, I would update
Footnote #3 to this:
"Acute Toxicity monitoring (Mysidopsis bahia) 24-hour Pass/Fail static test at 90% in January, April,
July, and October [see Section A. (2)]."
• Add [15A NCAC 02B .0200 et seq.] to the rule citation for WET testing (A (2))
• The map still references the old name of the facility
Fact Sheet
• In the Facility Info table, the facility class says "Grade I Physical Chemical" before "Not Classified". This is
contradictory, as it can't be both a Grade I and Not Classified. I would remove "Grade I"
• The Summary Data Table from Form 2C and the Chemical Addendum has the old name of the facility on it
Most of my notes are very minor things. Q
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.deutermanRdeq.nc.gov
1617 Mail Service Center
Raleigh, NC 27699-1617

e:, e—
NORTH D_E Q
Department of Environmental Duali�
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: Tuesday, May 28, 2024 12:37 PM
To: Deuterman, Sydney <[e-mail]>
Subject: One Last WTP Renewal for Review - CFPUA - Richardson WTP - NCO088307
Sydney,
Could you possibly look at this draft WTP renewal for me? This is one that you and I have been talking about so I
thought you would know a little about the process with this one and may be easier for you to get through. Also, it
seems like I keep getting more info on this one and have to go back and make adjustments, so you can only image
what types of mistakes I might have made. Since I know you are an excellent reviewer I was hoping you would walk
through it and help me make sure I have made all the needed adjustments in the right places.
MNC0088307 - CFPUA - Richardson WTP
Thanks
I.,
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: Beth Eckert <[e-mail]>
Sent: Tuesday, May 28, 2024 9:36 AM
To: Sydney Valliant; Bennett, Bradley
Cc: Kenneth Waldroup; Carel Vandermeyden
Subject: Re: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
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 a note - the increase in the WTP capacity did not require a increase in the NPDES permitted capacity.
Beth Eckert
Deputy Executive Director of Environmental Management and Sustainability
Cape Fear Public Utility Authority
o: 910-332-6646 1 c: 910-524-4133
235 Government Center Dr., Wilmington, NC 28403
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Sydney Valliant <[e-mail]>
Sent: Tuesday, May 28, 2024 9:21:17 AM
To: Bennett, Bradley <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>; Beth
Eckert <[e-mail]>
Subject: RE: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
Hey Bradley,
The facility was upgraded to 7MGD potable water design capacity in 2021 (see attached PWS approval letter). We still
plan on upgrading to a 9MGD capacity facility with no set project date at the moment and would need to pursue a PWS
approval in the future before the upgrade.
As for the name of the facility, Ogden Nanofiltration was the previous name before we altered treatment processes
from nanofiltration to reverse osmosis in 2020. After this switch, we changed the name to Richardson Water Treatment
Plant.
Thank you and let me know if you have any other questions,
Sydney R. Valliant
Environmental Regulatory Specialist
Cape Fear Public Utility Authority
0: 910-332-6554 1 C: 910-691-8797
637 Groundwater Way. Wilmington, NC 28411

Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to
third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, May 22, 2024 4:17 PM
To: Sydney Valliant <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>; Beth
Eckert <[e-mail]>
Subject: RE: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
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H i Syd n ey,
Sorry for all the questions on this renewal. As I am wrapping up the draft I just had a few questions. Is the Ogden
Nanofiltration facility still at the potable water design capacity of 6.0 MGD or has it been expanded to 9.0 MGD as
discussed in some previous permits? If the capacity is still at 6 MGD do you possibly already have PWS approval
for expansion to 9 MGD or is that something you would need to pursue to expand in the future?
Also, I was wondering if we have the wrong name referenced for this facility. I see at some places the facility
seems to be referred to as the Richardson WTP.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.bennett(a.deg.nc.pov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Sydney Valliant <[e-mail]>
Sent: Monday, May 20, 2024 8:48 AM
To: Bennett, Bradley <bradley. ben [e-mail]>; Beth Eckert <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>
Subject: RE: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307

ROY COOPER
Governor
DIONNE DELLFGATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Eavirawnental Quality
May 5, 2021
Cape Fear Public Utility
Attention: Carel Vandermeyden, Deputy Executive Director
235 Government Center Drive
Wilmington, North Carolina 28403
Re: Engineering Documents Approval
Groundwater System
Richardson WTP Capacity Increase to 7.0 MGD
CFPUA/NHC
Water System No.: NC0465232
New Hanover County
Serial No.: 21-00317
Dear Applicant:
Enclosed please find one copy of the "Application for Approval..." together with one copy
of the referenced engineering documents bearing the Division of Water Resources stamp of
approval for the referenced project. These engineering documents are approved under Division of
Water Resources Serial Number 21-00317, dated May 5, 2021.
Engineering documents prepared by Wesley Oehming Jr., P.E., document that the existing,
previously approved 6.0 MGD Richardson Water Treatment Plant located at 637 Groundwater
Way in Wilmington is designed and is capable of producing 7.0 MGD of finished water. The
existing treatment plant consists of two (2)- 2 stage nanofiltration membrane treatment PD and CH
trains.
PD treatment train consists of a raw water bypass line to bypass some of raw water
(approximately 1.4 MGD), a main treatment consisting of sulfuric acid (for pH adjustment) and
antiscale treatments before water enters the three (3) - 1,050 GPM capacity cartridge filters, three
(3) - 1,050 GPM, 100 HP capacity vertical turbine pumps, two (2)- 2 stage nanofiltration
membrane units with a recovery rate of 80% and a flux of 14.9 gpd/sf.
CH treatment train consists of sulfuric acid (for pH adjustment) and antiscale treatments
before water enters the three (3) - 1,300 GPM capacity cartridge filters, three (3) - 1,300 GPM,
100 HP capacity vertical turbine pumps, two (2)- 2 stage nanofiltration membrane units with a
recovery rate of 80% and a flux of 14.9 gpd/sf.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street i 1634 Mai[ Service Center i Raleigh, North Carolina 27699-1634
o ou
w.uua 919.707.9100

PD and CH treatment trains and PD bypass water is combined and treated with two (2) — 4
MGD capacity packed tower aerators (carbon dioxide and hydrogen sulfide removal) consisting
of three (3) — 9,075 SUM capacity blowers, injection of sodium hypochlorite (for disinfection),
corrosion inhibitor, sodium hydroxide (for pH adjustment) and fluorosilicic acid before water
enters the existing two (2) — 1 MG each circular prestressed concrete tanks. Then, water gets
pumped out into the distribution system with existing two (2) - 4 MGD, 150 HP and one (1) — 6
MGD, 250 HP finished water pumps. Concentrate from the membranes is discharged to the
intracoastal waterway via NPDES permit.
Wells that flow into the PD treatment train consist of. Castle Hayne Well J (600 GPM),
PeeDee Wells A (1000 GPM), B (900 GPM), C (570 GPM), F (570 GPM), G (350 GPM), H (450
GPM), I (570 GPM), J (350 GPM), K (475 GPM), L (475 GPM), Q (900 GPM) with a total 12-
hour pumping capacity of 5.19 MGD.
Wells that flow into the CH treatment train consist of. Castle Hayne Wells A (not used), B
(not used), C (600 GPM), F (600 GPM), G (500 GPM), H (600 GPM), I (400 GPM), K (200 GPM),
L (475 GPM) and PeeDee Wells M (450 GPM), N (450 GPM), O (400 GPM), P (600 GPM) with
a total 12-hour pumping capacity of 3.80 MGD.
These documents in the foregoing application are approved insofar as the protection of
public health is concerned as provided in the rules, standards and criteria adopted under the
authority of Chapter 130A-317 of the General Statutes. This approval does not constitute a
warranty of the design, construction or future operation of the water system.
One copy of the "Application for Approval..." and a copy of the engineering documents
with a seal of approval from the department are enclosed. One copy of the approved documents is
being forwarded to our Wilmington Regional Office. The third copy is being retained for our
permanent records.
If the Public Water Supply Section can be of further service, please call [phone].
Sincerely,
/for
Robert W. Midgette, P.E.
Chief, Public Water Supply Section
Division of Water Resources
RWM/SMB
Enclosures: Approval Documents
cc: Heidi Cox, Wilmington Regional Office
New Hanover County Health Department
HDR Engineering, Inc. of the Carolinas
Linda Raynor, Compliance Services Branch
North Carolina Department of Environmental Quality ( Division of Water Resources
5i2 North Salisbury Street 1 1634 Mail Service Center I Raleigh, North Carolina 27699-1634
• •t

Bennett, Bradley
From: Sydney Valliant <[e-mail]>
Sent: Monday, May 20, 2024 8:48 AM
To: Bennett, Bradley; Beth Eckert
Cc: Kenneth Waldroup; Carel Vandermeyden
Subject: RE: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Good morning, Bradley
I am emailing in response to the question regarding the reported values for Arsenic sent to us on May 15th. I reviewed
the Arsenic results with our Lab Manager, Jill Deaney, and she confirmed these numbers to be accurate.
Thank you and let me know if you have any questions,
Sydney R. Valliant
Environmental Regulatory Specialist
Cape Fear Public Utility Authority
0: 910-332-6554 1 C: 910-691-8797
637 Groundwater Way. Wilmington, NC 28411
Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to
third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Friday, May 17, 2024 5:24 PM
To: Beth Eckert <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>;
Sydney Valliant <[e-mail]>
Subject: RE: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
This Message Is From an External Sender
This email originated outside of CFPUA. Do not click links or open attachments unless you recognize
content is safe. If you have any doubt, report it to helpdesk.
Report Suspicious

Bennett, Bradley
From: Beth Eckert <[e-mail]>
Sent: Thursday, May 16, 2024 9:54 AM
To: Bennett, Bradley; Sydney Valliant; Kenneth Waldroup
Subject: Fwd: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
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.
See the email below.
Beth Eckert
Deputy Executive Director of Environmental Management and Sustainability
Cape Fear Public Utility Authority
o: 910-332-6646 1 c: 910-524-4133
235 Government Center Dr., Wilmington, NC 28403
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Sydney Valliant <[e-mail]>
Sent: Tuesday, April 30, 2024 1:02:18 PM
To: Bennett, Bradley <[e-mail]>; Beth Eckert <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>
Subject: RE: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
Hey Bradley,
I am responding to the email sent to Beth Eckert regarding the cleaning solution disposal practices for the NPDES permit
NC0088307.
The cleaning solution materials are not discharged through our NPDES outfall. Instead, they are directly piped into our
sewer system -- given the amount the solution is diluted after a cleaning, it does not prove to be an issue for our sewer
system. To answer the other questions asked for future reference, the facility cleans their RO trains every quarter which
equates to approximately 16 cleanings per year (4 RO trains x 4 times/year), using two cleaning solutions (one with a
high pH and the other with a low pH) which is then flushed into the sewer system, as previously discussed.
Thank you and let us know if you have any further questions,
Sydney R. Valliant
Environmental Regulatory Specialist
Cape Fear Public Utility Authority
0: 910-332-6554 1 C: 910-691-8797
637 Groundwater Way. Wilmington, NC 28411

Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to
third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Monday, April 29, 2024 3:17 PM
To: Beth Eckert <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>;
Sydney Valliant <[e-mail]>
Subject: RE: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307
This Message Is From an External Sender
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content is safe. If you have any doubt, report it to helpdesk.
Report Suspicious
Beth,
Thanks for your responses to my previous questions. I'm sorry I didn't acknowledge receipt of the info before now.
IN going through the application material I did have an additional question related to the Clean in Place process for
the facility. Is the cleaning solution for this process completely contained and recycled or is some material
discharged through the NPDES outfall. If there is a discharge then could you provide information on the cleaning
solution used, how often the cleaning takes place and how the spent cleaning solution is disposed of.
Thanks
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
From: Beth Eckert <[e-mail]>
Sent: Thursday, April 18, 2024 2:52 PM
To: Bennett, Bradley <bradley.ben [e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>;
Sydney Valliant <[e-mail]>
Subject: [External] RE: Question on Ogden Nanofiltration WTP Application - NCO088307

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.
Hi Bradley,
just left you a voicemail, but figured I would also respond to your email. The PFOS data is in ng/L (ppt). That is
correct.
As for the sampling locations, all our DMR reportable data is taken at the DEQ - NPDES approved sampling
Location and is reported on the eDMR. The process control site is a little upstream of the NPDES approved site at a
Location that DEQ approved as the "process control" sampling location. The samples taken at this site are not
required to be on the eDMR and not a lot of samples are taken at this location. However, since we were asked to
sample for anything that could reasonably be in our discharge during this permit cycle, we pulled all these extra
pollutants from that site. It is very reasonable to assume that if it is at this process control site, then it is in the
discharge when it gets to the compliance site. This is the same process we discussed with DEQ and followed for
these extra contaminants and contaminants of emerging concern when we completed our other NPDES permit
applications for our other WTP, and the 2 WWTPs.
If you have additional questions, please feel free to contact me.
Thankyou,
Beth Eckert
Deputy Executive Director
Linear Assets, Environmental Management, and Sustainability
Cape Fear Public Utility Authority
0: 910-332-66461 c: 910-524-4133
235 Government Center Drive
Wilmington, NC 28403
www.cfpua.org
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, April 17, 2024 12:18 PM
To: Beth Eckert <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>
Subject: RE: Question on Ogden Nanofiltration WTP Application - NCO088307
This Message Is From an External Sender
This email originated outside of CFPUA. Do not click links or open attachments unless you recognize the sender and know the
content is safe. If you have any doubt, report it to helpdesk.
Report Suspicious
Beth,

One other thing I forgot to ask. On the reported PFOS data there was no unit of measurement noted for the values
given. Where these ppt (ng/L) or something else?
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&deg.nc.gov
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Wednesday, April 17, 2024 10:34 AM
To: Beth Eckert <[e-mail]>
Cc: Kenneth Waldroup <[e-mail]>; Carel Vandermeyden <[e-mail]>
Subject: Question on Ogden Nanofiltration WTP Application - NCO088307
Hi Beth,
Sorry it has been a while since our last discussion on this renewal. I just had one quick question for now on the
application. You submitted some data where you indicated the data was obtained at the process control effluent
site rather than the NPDES location. Could you clarify for me where these samples were taken from?
Thanks
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradlev.bennett(@deg.nc.gov
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: Beth Eckert <[e-mail]>
Sent: Wednesday, April 26, 2023 1:43 PM
To: Bennett, Bradley
Cc: Carel Vandermeyden; Craig Wilson; Beth Eckert; Kathryn Pohlman; Kenneth Waldroup
Subject: [External] RE: Ogden Nanofiltration WTP Permit Renewal - NCO088307
IYou don't often get email from [e-mail]. Learn why this is important
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Hi Bradley,
It was good talking to you earlier today. As we discussed, we were pursuing a dilution study as a means of compliance
with the copper limit for the Ogden Nanofiltration facility. We pursued multiple paths to compliance at the same time,
this was one. Following this first phase of the study, the work being done internally by operations, tracking of trends in
the effluent when using various supply wells along with the substantial cost of the dilution study for this facility, we
decided to a not pursue the dilution study at that time. The model for the intercoastal where this facility discharges
would have been a very complex and costly endeavor, that given the compliance progress was not seen as a wise
investment of rate payer funds. As outlined in the cover letter for the permit renewal, we are in compliance with the
existing permit limits and have been for several years now. Furthermore, we are using lab methods and detection levels
that are sufficient to demonstrate such compliance.
In reference to the question regarding electronic submittals, we are in agreement with this means of delivery. I will
typically be the one that will be coordinating among our staff between the various departments to submit the NPDES
permit applications and responses. So please ensure the following CFPUA leadership and staff are copied on any
correspondence.
[e-mail]
[e-mail]
[e-mail]
Thanks, and if you have any additional questions please let me know and as a group we will ensure you get what you
need to move this permit forward.
Beth Eckert
Deputy Executive Director
Environmental Management and Sustainability
Cape Fear Public Utility Authority
0: 910-332-66461 c: 910-524-4133
235 Government Center Drive
Wilmington, NC 28403
www.cfpua.org
From: Kenneth Waldroup <[e-mail]>
Sent: Tuesday, April 25, 2023 3:23 PM

To: Beth Eckert <[e-mail]>; Kathryn Pohlman <[e-mail]>
Cc: Carel Vandermeyden <[e-mail]>; Craig Wilson <[e-mail]>
Subject: Re: Ogden Nanofiltration WTP Permit Renewal - NC0088307
Will you please respond to Bradley on our behalf? Please let him know I am in Washington for the National Water Policy
Fly -In and asked you to respond to avoid unnecessary delays.
Kenneth Waldroup, PE
Executive Director
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
From: Beth Eckert <[e-mail]>
Sent: Tuesday, April 25, 2023 3:15:19 PM
To: Kenneth Waldroup <[e-mail]>; Kathryn Pohlman <Kathryn.Pohl man @cfpua.org>
Cc: Carel Vandermeyden <[e-mail]>; Craig Wilson <[e-mail]>
Subject: Re: Ogden Nanofiltration WTP Permit Renewal - NC0088307
We were going to pursue a dilution study as a means to comply with the copper limit. However as outlined in our
annual reports on the compliance schedule within the permit we have been able to achieve compliance without the
dilution study which was very expensive.
As far as the electronic submittal of documents, that's good. I need to be on the list of people that receives those
documents though since I prepare all of the permit applications and compliance documents and strategy, I'd be the one
coordinating a response if needed and implementing new monitoring requirements.
Beth Eckert
Deputy Executive Director of Environmental Management and Sustainability
Cape Fear Public Utility Authority
o: 910-332-6646 1 c: 910-524-4133
235 Government Center Dr., Wilmington, NC 28403
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Kenneth Waldroup <[e-mail]>
Sent: Tuesday, April 25, 2023 3:03:31 PM
To: Beth Eckert <[e-mail]>; Kathryn Pohlman <[e-mail]>
Cc: Carel Vandermeyden <[e-mail]>; Craig Wilson <[e-mail]>
Subject: Fwd: Ogden Nanofiltration WTP Permit Renewal - NC0088307
Beth/Kat,
FYI..
Thoughts?
Kenneth Waldroup, PE
Executive Director
Cape Fear Public Utility Authority
235 Government Center Drive

Wilmington, NC 28403
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Tuesday, April 25, 2023 1:12 PM
To: Kenneth Waldroup <[e-mail]>
Subject: Ogden Nanofiltration WTP Permit Renewal - NCO088307
Caution: This email originated outside of CFPUA. Do not click links or open attachments unless you recognize the
sender and know the content is safe. If you have any doubt, report it to helpdesk.
Hey Kenny,
Hope you are doing well. It's been a while since I talked with you. I am now working part time with the DWR NPDES
permitting program and I will be looking at the permit renewal for this Water Treatment Plant. I just wanted to pass
along a few things to you about electronic submittal of permit documents and also ask for a little additional information
on one item after a quick review of some files.
Additional Information:
I noticed in the files back in 2018 that the CFPUA was working on a modeling plan for dilution analysis for this WTP and a
couple of other locations. I didn't see any further information on this in the files or in the renewal application. So I
wanted to check and see the CFPUA had completed this modeling effort to develop any dilution study results that
should be considered in this renewal review?
Electronic Transmission of Permit Document:
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 will
hopefully provide 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 any questions, please feel free to contact me.
Thanks, and I look forward to working with you on this renewal.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Saltwater RPA 95% Probablity/95% Confidence
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information Table 2. Parameters of Concern
Facility Name I Richardson WTP
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
PCNC
NC0088307
001
2.000
ICWW
SA; ORW
Tidal, IWC = 100%
Tidal, IWC = 100%
Tidal, IWC = 100%
Tidal, IWC = 100%
Tidal, IWC = 100%
Data Source(s) Flow -monthly max avg from last three years of
DMR data (April 2021 -March 2024) was 1.33
MGD but used the Flow Limit of 2.OMGD for
Flow. Parameter data -last 58 values submitted.
Saltwater streams are uaat resutnng to an iwc /° _ uu/°.
an approved model is conducted then a chronic dilution
factor is determined and can be applied to a discharge to
calculate its IWC % . If a stream is classified as a SA or
ORW then its is also classified as a HQW The appropriate
IWC % must be defined to properly calculate WQS-based
limits.
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Name w4s Type Chronic Modifier Acute PQL Units
Arsenic
Aquatic Life
C
36
SW
69
ug/L
Arsenic
Human Health
C
10
HH
ug/L
Cadmium
Aquatic Life
NC
7.9
SW
33.2
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
10
ug/L
Chromium VI
Aquatic Life
NC
50.4
SW
1107.8
ug/L
Chromium, Total
Aquatic Life
NC
N/A
SW
N/A
ug/L
Copper
Aquatic Life
NC
3.7
SW
5.8
ug/L
Cyanide
Aquatic Life
NC
1
SW
1
10
ug/L
Lead
Aquatic Life
NC
8.5
SW
220.8
ug/L
Mercury
Aquatic Life
NC
25
SW
0.5
ng/L
Molybdenum
Human Health
NC
2.0
HH
mg/L
Nickel
Aquatic Life
NC
8.3
SW
74.7
ug/L
Selenium
Aquatic Life
NC
71
SW
ug/L
Silver
Aquatic Life
NC
0.1
SW
2.2
ug/L
Zinc
Aquatic Life
NC
85.6
SW
95.1
ug/L
NOTE: The aquatic life chronic and acute WOS for several metals are calculated based on EPA conversi
see "Diss. SW stds. As TM" for more details and summary of calculated WOS..
NC0088307_9595 Final Saltwater RPA 2023_20240501,input
5/28/2024

REASONABLE POTENTIAL ANALYSIS - DATA
Arsenic
Values" then "COPY".
Maximum data points
= 58
Copper
Date
Data
BDL=1/2DL
Results
Date
Data
BDL=1/2DL
1
6/4/2019
<
1
0.5
Std Dev. 0.1144
1
4/6/2021
<
1
0.5
2
7/9/2019
<
1
0.5
Mean 0.4745
2
4/20/2021
<
1
0.5
3
8/6/2019
<
1
0.5
C.V. 0.2412
3
5/4/2021
<
1
0.5
4
9/10/2019
<
1
0.5
n 58
4
5/18/2021
<
1
0.5
5
10/8/2019
<
1
0.5
5
6/1/2021
<
1
0.5
6
11 /5/2019
<
1
0.5
Mult Factor = 1.0000
6
6/15/2021
<
1
0.5
7
12/3/2019
<
1
0.5
Max. Value 1.0 ug/L
7
7/13/2021
<
1
0.5
8
1/7/2020
<
1
0.5
Max. Pred Cw 1.0 ug/L
8
7/27/2021
<
1
0.5
9
2/4/2020
<
1
0.5
9
8/10/2021
<
1
0.5
10
3/3/2020
<
1
0.5
10
8/24/2021
<
1
0.5
11
4/7/2020
<
1
0.5
11
9/7/2021
<
1
0.5
12
5/5/2020
<
1
0.5
12
9/21/2021
<
1
0.5
13
6/2/2020
<
1
0.5
13
10/5/2021
<
1
0.5
14
7/7/2020
<
1
0.5
14
10/19/2021
<
1
0.5
15
8/5/2020
<
2
1
15
11 /2/2021
<
1
0.5
16
9/1/2020
<
0.5
0.25
16
11/16/2021
<
1
0.5
17
10/6/2020
<
0.5
0.25
17
12/8/2021
<
1
0.5
18
11/3/2020
0.42
0.42
18
12/21/2021
<
1
0.5
19
12/1/2020
<
1
0.5
19
1/4/2022
<
1
0.5
20
1/5/2021
0.22
0.22
20
1/18/2022
<
1
0.5
21
2/2/2021
0.13
0.13
21
2/1/2022
<
1
0.5
22
3/2/2021
<
0.5
0.25
22
2/15/2022
<
1
0.5
23
4/6/2021
<
0.5
0.25
23
3/1/2022
<
1
0.5
24
5/4/2021
<
0.5
0.25
24
3/15/2022
<
1
0.5
25
6/1/2021
<
1
0.5
25
4/5/2022
<
1
0.5
26
7/13/2021
<
1
0.5
26
4/19/2022
<
1
0.5
27
8/10/2021
<
1
0.5
27
5/3/2022
<
1
0.5
28
9/7/2021
<
1
0.5
28
5/17/2022
<
1
0.5
29
10/5/2021
<
1
0.5
29
6/7/2022
<
1
0.5
30
11/2/2021
<
1
0.5
30
6/21/2022
<
1
0.5
31
12/8/2021
<
1
0.5
31
7/12/2022
1.24
1.24
32
1/4/2022
<
1
0.5
32
7/26/2022
<
1
0.5
33
2/1/2022
<
1
0.5
33
8/9/2022
<
1
0.5
34
3/1/2022
<
1
0.5
34
8/23/2022
<
1
0.5
35
4/5/2022
<
1
0.5
35
9/6/2022
<
1
0.5
36
5/3/2022
<
1
0.5
36
9/20/2022
<
1
0.5
37
6/7/2022
<
1
0.5
37
10/4/2022
<
1
0.5
38
7/12/2022
<
1
0.5
38
10/18/2022
<
1
0.5
39
8/9/2022
<
1
0.5
39
11 /1 /2022
<
1
0.5
40
9/6/2022
<
1
0.5
40
11 /15/2022
<
1
0.5
41
10/4/2022
<
1
0.5
41
12/6/2022
<
1
0.5
42
11 /1 /2022
<
1
0.5
42
12/20/2022
<
1
0.5
43
12/6/2022
<
1
0.5
43
1/10/2023
<
1
0.5
44
1/10/2023
<
1
0.5
44
1/17/2023
<
1
0.5
45
2/7/2023
<
1
0.5
45
2/7/2023
<
1
0.5
46
3/7/2023
<
1
0.5
46
3/7/2023
<
1
0.5
47
4/4/2023
<
1
0.5
47
4/4/2023
<
1
0.5
48
5/2/2023
<
1
0.5
48
5/2/2023
<
1
0.5
49
6/6/2023
<
1
0.5
49
6/6/2023
<
1
0.5
50
7/11/2023
<
1
0.5
50
7/11/2023
<
1
0.5
51
8/8/2023
<
1
0.5
51
8/8/2023
<
1
0.5
52
9/5/2023
<
1
0.5
52
9/5/2023
<
1
0.5
53
10/3/2023
<
1
0.5
53
10/3/2023
<
1
0.5
54
11/7/2023
<
1
0.5
54
11/7/2023
<
1
0.5
55
12/5/2023
<
1
0.5
55
12/5/2023
<
1
0.5
56
1/9/2024
<
1
0.5
56
1/9/2024
<
1
0.5
57
2/6/2024
<
1
0.5
57
2/6/2024
<
1
0.5
58
3/4/2024
<
1
0.5
58
3/4/2024
<
1
0.5
✓alues" then "COPY1
Maximum data points
= 58
Results
-
Std Dev.
0.0972
Mean
0.5128
C.V.
0.1895
n
58
Mult Factor = 1.0000
Max. Value 1.24 ug/L
Max. Pred Cw 1.24 ug/L
NCO088307_9595 Final Saltwater RPA 2023 20240501,data
Date}

REASONABLE POTENTIAL ANALYSIS - DATA
Date
Data
BDL=1/2DL
1 6/4/2019
<
5
2.5
2 7/9/2019
<
5
2.5
3 8/6/2019
<
5
2.5
4 9/10/2019
<
10
5
5 10/8/2019
<
5
2.5
6 11 /5/2019
<
5
2.5
7 12/3/2019
<
5
2.5
8 1 /7/2020
<
5
2.5
9 2/4/2020
<
5
2.5
10 3/3/2020
<
5
2.5
11 4/7/2020
<
5
2.5
12 5/5/2020
<
5
2.5
13 6/2/2020
<
5
2.5
14 7/7/2020
<
5
2.5
15 8/5/2020
<
10
5
16 9/1/2020
<
5
2.5
17 10/6/2020
<
5
2.5
18 11 /3/2020
<
5
2.5
19 12/1 /2020
<
5
2.5
20 1 /5/2021
<
5
2.5
21 2/2/2021
<
5
2.5
22 3/2/2021
<
5
2.5
23 4/6/2021
<
5
2.5
24 5/4/2021
<
5
2.5
25 6/1/2021
<
5
2.5
26 7/13/2021
<
10
5
27 8/10/2021
<
10
5
28 9/7/2021
<
10
5
29 10/5/2021
<
10
5
30 11 /2/2021
<
10
5
31 12/8/2021
<
10
5
32 1 /4/2022
<
10
5
33 2/1/2022
<
10
5
34 3/1/2022
<
10
5
35 4/5/2022
<
10
5
36 5/3/2022
<
10
5
37 6/7/2022
<
10
5
38 7/12/2022
<
10
5
39 8/9/2022
<
10
5
40 9/6/2022
<
10
5
41 10/4/2022
<
10
5
42 11 /1 /2022
<
10
5
43 12/6/2022
<
10
5
44 1/10/2023
<
10
5
45 2/7/2023
<
10
5
46 3/7/2023
<
10
5
47 4/4/2023
<
10
5
48 5/2/2023
<
10
5
49 6/6/2023
<
10
5
50 7/11/2023
<
10
5
51 8/8/2023
<
10
5
52 9/5/2023
<
10
5
53 10/3/2023
<
10
5
54 11 /7/2023
<
10
5
55 12/5/2023
<
10
5
56 1 /9/2024
<
10
5
57 2/6/2024
<
10
5
58 3/4/2024
<
10
5
Values" then "COPY"
Maximum data points
= 58
Results
Std Dev.
1.2336
Mean
4.0086
C.V.
0.3077
n
58
Mult Factor =
1.0000
Max. Value
5.0 ug/L
Max. Fred Cw
5.0 ug/L
NCO088307_9595 Final Saltwater RPA 2023 20240501,data
Date}

Richardson WTP
NCO088307
Saltwater RPA 95% Probablity/95% Confidence
MAXIMUM DATA POINTS = 58
Qw (MGD) —
2.00
WWTP/WTP Class: PCNC
1Q10S (cfs) =
Tidal, IWC = 100%
TWC% @ 1Q10S = 100
7Q10S (cfs) —
Tidal, IWC = 100%
IWC% @ 7Q10S = 100
7Q10W (cfs) =
Tidal, IWC = 100%
IWC% @ 7Q10W = 100
30Q2 (cfs) —
Tidal, IWC = 100%
IWC% @ 30Q2 = 100
Avg. Stream Flow, QA (cfs) =
Tidal, IWC = 100%
IWC% @ QA = 100
Receiving Stream:
ICWW
Stream Class: SA; ORW
Outfall 001
Qw = 2 MGD
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS HOW OR ORW.
PARAMETER
INC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
TYPE
a
z
RECOMMENDED ACTION
Applied
Chronic Acute
D
n # Det. Max Pred Cw Allowable Cw
Standard
Acute (SW): 34.5
Salinity removed after permittee comments — see
Arsenic
C
18 SW(7Q10s) 34.5
ug/L
discussion on page # of the Fact -
58 3
1.0
_ _ _ _ _ —
Chronic (SW): — 18.0
-Sheet
— — — — — — — — — — — — —
No value > Allowable
Arsenic
C
5 HH(Qavg)
ug/L
Chronic (H_H): 5.0
No value > Allowable Cw
Acute: 2.89
No RPA, Predicted Max > 50% of Allowable
Copper
NC
1.86746988 SW(7Q10s) 2.89156627
ug/L
58 1
1.24
— — --
Cw - apply Quarterly Monitoring
-------------------------
Chronic: 1.87
No value > Allowable Cw
Acute: 47.6
No RPA, Predicted Max < 50% of Allowable Cw
Zinc
NC
42.8118393 SW(7Q10s) 47.5687104
ug/L
58 0
5
No Monitoring required
_ _ _ _ _
Chronic: — — 42.8 —
-------------------------
NO DETECTS
Max MDL = 10
Acute:
0 0
N/A
_ hron_ ic_
C:----------
— - — - — - — - — - — - — - — - — - — - — - — - — -
NCO088307_9595 Final Saltwater RPA 2023_20240729,rpa
Page 1 of 1 7/29/2024

Whole Effluent Toxicity Testing and Self Monitoring Summary
New Bern WWTP
NC0025348/001 County:
Craven
Region: WARO
Basin: NEU10 Mar Jun Sep Dec
Mysd24PF
Begin:
12/1/2013 Ac P/F Lim: 90% Mys +
NonComp: Single
7Q10: TIDAL
PF: 7.0 IWC: NA 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
-
2024
-
- Pass
- -
-
-
- -
-
New Hanover County WTP (CFPUA-Nano NCO088307/001 County:
New Hanover
Region: WIRO
Basin: CPF24 Jan Apr Jul Oct
Mysd24PF
Begin:
2/1/2018 Ac P/F Monit: 90% M
NonComp:
7Q10: N/A
PF: 1.38 WC: 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
- -
- -
-
-
- -
-
Newport WWTP
NC0021555/001 County:
Carteret
Region:
WIRO
Basin:
WOK03 Jan Apr Jul Oct
Ceri7dPF
Begin:
4/1/2013
Chr Lim: 82% T
NonComp:
7Q10: 0.4
PF: 1.2
IWC: 66.0 Freq: Q
J
F M
A M
J
J
A S
O
2020
Pass
- -
Pass -
-
Pass
- -
Pass
2021
Pass
- -
Pass -
-
Pass
- -
Pass
2022
Fail
INVALID >100 (P) >100 >100
Pass -
-
Pass
- -
Pass
2023
Pass
- -
Pass -
-
Pass
- -
Pass
2024
Pass
- -
- -
-
-
- -
-
Newton - Clark Creek
WWTP
NC0036196/001 County:
Catawba
Region:
MRO
Basin:
CTB35 Mar Jun Sep Dec
Ceri7dPF
Begin:
8/1/2021
chr lim: 56%@5MGD;
NonComp: Single
7Q10: 6.0
PF: 5.0
IWC: 56.32 Freq: Q
J
F M
A M
J
J
A S
O
2020
-
- Pass(s)
- >100(P)
Pass
-
- Pass >100(P)
-
2021
-
- Pass (S) Pass (S)
- -
Pass (S) Pass (S) >100 (F
-
- Pass (S) Pass (S)
-
2022
-
- Pass (S) Pass (S)
- -
Pass
(S) Pass (S)
-
- Pass Pass
-
2023
-
- Pass Pass
- -
Pass
Invalid Pass
-
- >100 Pass Pass
-
Norfolk Southern Railway
Co. -Linwood
NC0029246/011 County:
Davidson
Region:
WSRO
Basin:
YAD04 Mar Jun Sep Dec
Ceri24PF
Begin:
6/1/2014
Acu lim: 90%
NonComp: Single
7Q10: 1.2
PF: 0.317 IWC: 29.0 Freq: Q
J
F M
A M
J
J
A S
O
2020
-
- H
- -
-
-
- Pass
-
2021
Pass
- Pass
- -
H
-
- H
-
2022
-
- Pass
- -
H
-
- H
-
2023
-
- H
- -
H
-
- Pass
-
SOC JOC:
N
SOC JOC:
N
SOC JOC:
N
SOC JOC:
N
SOC JOC:
N
D
Pass
Pass
Pass
Pass
C
G
D
Pass
Pass (S) Pass (S)
>100 Pass Pass
Pass Pass
D
INVALID
H
Pass
H
Legend: P= Fathead minnow (Pimohales Dromelas). H=No Flow (facilitv is active), s = Split test between Certified Labs Page 72 of 111

Summary of Data Reported from Form 2C Tables and from Chemical Addendum including PFAS data
Cape Fear Public Utility Authority Richardson WTP Permit NC0088307
Discharge to Atlantic Intercoastal Waterway Class SA; ORW
Pollutant
Units
Daily Max
Average
Number
of
Samples
Standard/Criteria
Comments
Conventional and Non Conventional
BOD
mg/L
<2
1
5000 µg/L
HQW
COD
mg/L
65
1
N
Total Organi Carbon
mg/L
23.4
1
N
TSS
mg/L
28.4
2
161
20
HQW
Ammonia
mg/L
2.93
1.38
37
2000 µg/L
HQW
Temp (winter)
19
18
66
Temp (Summer)
20
19
95
pH minimum
SU
6.7
161
6.8 to 8.5
Saltwater Standards
pH maximum
ISU
1 7.6
161
Toxic Metals, Cyanide, Total Phenols & Organic Toxic Pollutants
Arsenic
µg/L
0.42
0.02
37
RPA
Copper
µg/L
0
0
74
RPA
Zinc
µg/L
0
0
37
RPA
Certain Conventional and Non Conventional Pollutants
Color
PCU
125
1
y
Fluoride
mg/L
0.425
1
N saltwater
Nitrate -Nitrite
mg/L
0.21
0.03
12
N
Total Organic Nitrogen
mg/L
1.8
1.4
12
?
Total Phosphorous
mg/L
0.72
0.4
12
?
Sulfate
mg/L
240
1
N
Barium
µg/L
30.7
1
2500 µg/L
SC Waters Instream Target
Boron
mg/L
0.12
1
N saltwater

Number
of
Pollutant
Units
Daily Max
Average
Samples
Standard/Criteria
Comments
Iron
µg/L
6340
1
N
Aquatic Standard removed
Magnesium
mg/L
30.8
1
N
Manganese
µg/L
157
1
N
human health standard removed
Titanium
µg/L
3.83
1
N
Chemical Addendum
1,4,Dioxane
µg/L
I <1
1
1 1
1 ?
Ivalue < reportable
PFAS - Parameters detected at least once. Number of Samples shows number with detection - Monitoring at process control effluent site
Not analyzed using EPA method. Excludes Parameters that showed no detect (ND) for all samples
NVHOS
ng/L
5.06
3.92
2 of 4
??
2,3,3,3-Tetrafl uoro-2-
(1,1,2,2,3,3,3-
heptafluoropro poxy)- propanoic acid or
ng/L
7.05
4.16
8 of 8
??
10 ppt MCL
Hexafluoropropyleneoxide dimer acid
(HFPO-DA or
PFPrOPrA or GenX)
Perfluoroctadecanoic acid (PFODA)
ng/L
1.33
1.33
1 of 7
??
Perfluorooctanesulfonate or
Perfluorooctane sulfonic acid
ng/L
4.95
3.30
8 of 8
??
4 ppt MCL
(PFOS)
N- methylperfluoro- 1-
octanesulfonamidoacetic
acid or N-
ng/L
0.06
0.06
1 of 8
??
Methylperfluorooctane
sulfonamido acetic acid
(NMeFOSAA)
Byproduct 4 ( BP4)
ng/L
6.54
4.44
4 of 7
??
Perfluoropentanoic acid
(PFPeA)
ng/L
4.72
4.17
2 of 8
??

Number
of
Pollutant
Units
Daily Max
Average
Samples
Standard/Criteria
Comments
Perfluoropentanesulfonate
or Perfluoropentane sulfonic
ng/L
0.47
0.38
3 of 8
??
acid ( PFPeS)
Fluorotelomer sulfonate 6: 2
or 1H, 1H, 2H, 2H-Perfluorooctane
sulfonic acid
ng/L
0.24
0.19
3 of 8
??
(6: 2 FTS)
FBSA
ng/L
0.11
0.10
2 of 4
??
Perfluorohexanoic acid
PFHxA)
ng/L
3.68
2.70
8 of 8
??
Perfluorooctanoic acid ( PFOA)
ng/L
3.97
3.20
8 of 8
??
4 ppt MCL
Perfluorohexanesulfonate or
Perfluorohexane sulfonic acid
ng/L
3.34
2.57
8 of 8
??
10 ppt MCL
(PFHxS)
Perfluorobutyric acid or
Perfluorobutanoic acid ( PFBA)
ng/L
4.64
4.64
1 of 8
??
Perfluorobutanesulfonate or
2000 ppt - Not MCL, but health
Perfluorobutane sulfonic acid
ng/L
3.33
2.80
5 of 8
??
based value used in Hazardous
(PFBS)
Index MCL
Perfluoroheptanoic acid
(PFHpA)
ng/L
2.14
1.61
8 of 8
??
Perfluoroheptanesulfonate
orPerfluoroheptane sulfonic
ng/L
0.20
0.14
3 of 8
??
acid ( PFHpS)
Perfluorononanoic acid
(PFNA)
ng/L
0.22
0.16
4 of 8
??
10 ppt MCL
Perfluoro( 3, 5- dioxahexanoic)
acid ( PFO2HxA)
ng/L
14.40
10.66
8 of 8
??
Perfluoro( 3, 5, 7-
trioxaoctanoic) acid ( PFO3OA)
ng/L
15.10
6.78
8 of 8
??

Pollutant
Units
Daily Max
Average
Number
of
Samples
Standard/Criteria
Comments
Perfluoro( 3, 5, 7, 9-
tetraoxadecanoic) acid
(PFO4DA)
ng/L
1.93
1.72
2 of 8
??
Perfluoro- 2- methoxyacetic
acid ( PFMOAA)
ng/L
370.00
159.96
8 of 8
??
Nafion Byproduct 2
ng/L
0.15
0.15
1 of 8
??
1, 1, 2, 2- Tetrafluoro- 2-( 1, 2, 2, 2-
tetrafluoroethoxy) ethane
sulfonic acid ( NVHOS)
ng/L
2.32
2.09
3 of 3
??
End of PFOS table gave Total of all
Compounds for 8 monitoring dates
Additional Pollutants measured by certified method, but obtained at the process control
sampling location not the NPDES location
Acidity
mg/L
52.6
1
N
Adsorbable Organic Halides
µg/L
450
1
N
Alkalinity
mg/L
950
1
N Saltwater
AOX Result 1
µg/L
480
1
N
AOX Result 2
µg/L
410
1
N
Aromatic (C11-C22)
µg/L
326
1
4000 µg/L
Instream Target for SC waters
Aromatic (C11-C22) adjusted
µg/L
315
1
4000 µg/L
Instream Target for SC waters
Barium
µg/L
30.7
1
2500 µg/L
SC Waters Instream Target
Boron
mg/L
0.12
1
N saltwater
Calcium
mg/L
458
1
N
COD
mg/L
65
1
N
Color
PCU
25
1
N
Fluoride
mg/L
0.425
1
N Saltwater
Hardness
mg/L
1270
1
N ?
Iron
µg/L
6340
1
N
Aquatic Standard removed
Magnesium
mg/L
30.8
1
N
Manganese
µg/L
157
1
1 N
1human health standard removed
Nitrate as N
mg/L
1.51
1
1 N Saltwater

Pollutant
Units
Daily Max
Average
Number
of
Samples
Standard/Criteria
Comments
Orthophosphate as P
mg/L
0.38
1
N
Potassium
mg/L
10.5
1
N
Silicon
mg/L
58
1
N
Sodium
mg/L
93.4
1
N
Strontium
µg/L
1280
1
40000 µg/L
Instream Target for SC waters
Sulfate
mg/L
240
1
N
Titanium
µg/L
3.83
1
N
TOC
mg/L
23.4
1
N
Total Organic Halides (TOX)
µg/L
45.2
1
N
Total Residue
mg/L
1700
1
N
Volatile Solids
mg/L
205
1
N