NC0036196_Fact Sheet_20240805

Fact Sheet
NPDES Permit No. NCO036196
Permit Writer/Email Contact:Nick Coco,[e-mail]
Date: 7/31/2024
Division/Branch:NC Division of Water Resources/NPDES Municipal Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑ Renewal
❑ Renewal with Expansion
❑ New Discharge
N Modification(Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers,EPA Form 2A or 2D requirements,Engineering Alternatives Analysis,Fee
• For Existing Dischargers (POTW),EPA Form 2A, 3 effluent pollutant scans,4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW),EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable,enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name: City of Newton/Clark Creek Wastewater Treatment Plant(WWTP)
Applicant Address: PO Box 550,Newton,NC 28658
Facility Address: 1407 McKay Road,Newton,NC 28658
Permitted Flow: 5.0 MGD with expanded flow tier 7.5 MGD
Facility Type/Waste: MAJOR Municipal; 97.8%domestic,2.2%industrial*
Facility Class: Grade IV Biological Water Pollution Control System
Treatment Units Influent pump station,mechanical screen,two aerated grit chambers, lime
addition,two primary clarifiers, four aeration basins,three secondary
clarifiers,two dual media filters, dual chlorine contact basins, dechlorination,
two gravity sludge thickeners,two centrifuge sludge thickeners,post aeration,
standby generator
Pretreatment Program(Y/N) Y; LTMP
County: Catawba
Region Mooresville
*Based on permitted flows.
Briefly describe the proposed permitting action and facility background: The City of Newton has applied
for NPDES permit modification on May 20,2024 requesting re-evaluation of existing aluminum limits, as
they are believed to be calculated in error. The only pollutant being addressed with this modification is
aluminum.
As the calculation has been found to be based on an outdated and invalid EPA Nationally Recommended
Water Quality Criterion,the major modification fee has been waived. Please see Water Quality-Based
Effluent Limitations (WQBELs) and Antibacksliding Review for more information.
Page 1 of 4

2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s): Outfall 001 —Clark Creek
Stream Segment: 11-129-5-(0.3)b
Stream Classification: C
Drainage Area(mi): 29.3
Summer 7Q10(cfs): 6.0
Winter 7Q10(cfs): 10.0
30Q2 (cfs): -
Average Flow(cfs): 35.0
IWC (%effluent): 56%at 5.0 MGD, 66%at 7.5 MGD
2022 303(d) listed/parameter: Yes—exceeding criteria for Benthos
Subject to TMDL/parameter: Yes- State wide Mercury TMDL implementation.
Subbasin/HUC: 03-08-35/03050102
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of September 2019 through February
2024.
Table 1. Effluent Data Summary Outfall 001
Parameter Units Average Max Min
Flow MGD 3.0 10.9 1.3
Aluminum ug/L 78 1140 6
MA-Monthly Average,WA-Weekly Average,DM-Daily Maximum,DA=Daily Average,QA= Quarterly Average
4. Compliance Summary
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 17 of 17 quarterly chronic toxicity tests as well as 3 of 3 second species
toxicity tests from March 2020 to March 2024.
5. Water Quality-Based Effluent Limitations (WQBELs)
The current permit contains aluminum limits based on an outdated and invalid EPA Nationally
Recommended Water Quality Criteria(NRWQC)for total aluminum is 87 ug/L for waters with a pH
within the range of 6.5 to 9.0 standard units. In 2018,prior to the 2021 permit renewal, EPA provided an
updated NRWQC for aluminum for the protection of aquatic life. This updated NRWQC is calculation-
based and considers site-specific information regarding water chemistry parameters that have the greatest
impact on aluminum's bioavailability(dissolved organic carbon,pH and hardness), and should have been
used when assessing need for effluent aluminum requirements during the 2021 renewal process.
The Division has calculated derived numeric criteria for total aluminum in accordance with 15A NCAC
02B .0208 for the protection of human health. Division staff have reviewed the need for total aluminum
limits based on human health criteria in the attached Reasonable Potential Analysis (RPA). As the
demonstrated no reasonable potential for an excursion above the total aluminum human health criterion,a
permit limit is not required.
However,the derived human health criterion does not consider protection of aquatic life. The Division's
Standards Branch has been informed of the gap in availability of an aquatic life protection-based derived
criterion for aluminum and has informed the NPDES staff that this is in queue for development. As this
Page 2 of 4

process can be lengthy and is not expected to begin shortly,use of the EPA NRWQC has been deemed
appropriate.
As no upstream data are available for dissolved organic carbon(DOC) and higher dissolved organic
carbon reduces bioavailability because Aluminum is bound to DOC,making the aluminum less
bioavailable to aquatic organisms, an evaluation of the criteria could not be sufficiently made.
To provide sufficient inputs for the EPA NRWQC calculation,upstream monitoring for DOC and pH has
been added to the permit at a quarterly frequency.Upstream hardness sampling is currently required at a
quarterly frequency.
Total aluminum limits have been removed from the permit and monitoring has been reduced from
monthly to quarterly. Quarterly monitoring for effluent total aluminum and upstream DOC,pH and
hardness shall be conducted in conjunction with quarterly chronic toxicity testing. The permit may be
reopened to re-evaluate the need for further aluminum actions upon collection of sufficient data.
6. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4)of the CWA and federal regulations at 40 CFR 122.44(1)prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit,with some exceptions where limitations
may be relaxed(e.g.,based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit(YES/NO):YES
If YES, confirm that antibacksliding provisions are not violated: During the 2021 renewal, an outdated
EPA NRWQC was used for assessment of need for total aluminum limitations. As the EPA revised their
NRWQC in 2018,the outdated value should not have been used. The use of the outdated value is
considered a"technical mistakes or mistaken interpretations of law"and is an exception to the
antibacksliding rule per 40 CFR 122.44(1)(2)(i)(13)(2). The limits in the permit have been removed. To
evaluate total aluminum in accordance with the 2018 EPA NRWQC, quarterly monitoring for upstream
pH and DOC has been added to the permit. Total aluminum monitoring is required in the permit at a
quarterly frequency. Monitoring for upstream hardness,pH and DOC and effluent total aluminum shall be
conducted in conjunction with quarterly chronic toxicity testing.
7.Summary of Proposed Permitting Actions:
Table 2. Current Permit Conditions and Proposed Changes Outfall 001
Parameter Current Permit Proposed Change Basis for Condition/Change
Total @ 5.0 MGD: Both flow tiers: For evaluation of 2018 total aluminum
Aluminum MA 154.3 µg/l Monitor and report EPA NRWQC. Incorrect value used
DM 154.3 µg/l quarterly—coincide during 2021 renewal, anti-backsliding
Monthly monitoring with toxicity testing exception—technical mistake
@ 7.5 MGD:
MA 131.9 µg/l
DM 131.9 µg/l
Monthly monitoring
Upstream Both flow tiers: Both flow tiers: For evaluation of total aluminum EPA
monitoring Quarterly monitoring for Add quarterly NRWQC
total hardness monitoring for DOC
and pH—coincide
with toxicity testing
MGD—Million gallons per day,MA- Monthly Average,WA—Weekly Average,DM—Daily Max
Page 3 of 4

8. Public Notice Schedule:
Permit to Public Notice: 6/13/2024
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice.Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
9. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit,please
contact Nick Coco at(919) 707-3609 or via email at [e-mail].
10. Fact Sheet Addendum (if applicable):
The draft permit modification was submitted to the City of Newton,EPA Region IV, and the Division of
Water Resources' Mooresville Regional Office for review.
On July 15, 2024,the Catawba Riverkeeper submitted comments requesting the permit include
monitoring and reporting of PFAS,E. coli, a compliance schedule to limit violations of fecal coliforms
from I/I. As these requests are outside of the scope of the modification,they are noted but have not been
included in the final permit modification.
In addition,the Catawba Riverkeeper requested the Division implement increased monitoring frequency
of upstream DOC,hardness,pH and effluent aluminum, increase in frequency of chronic toxicity testing,
and the inclusion of a limit for total aluminum based on human health. Division staff have reviewed the
need for total aluminum limits based on human health criteria in the attached RPA and determined that a
permit limit is not required. As no human health criterion-based permit limit is required,but the Division
is evaluating the total aluminum EPA NRWQC based on aquatic life,monitoring has been maintained.
However,monitoring for aluminum has been reduced to quarterly from monthly,which is consistent with
the RPA procedure for parameters of concern which do not demonstrate RP.
As total aluminum monitoring is to be conducted quarterly,the remaining parameters which inform the
Division on the allowable discharge concentration for total aluminum based on the EPA NRWQC have
been required at a quarterly frequency. As such,no changes are proposed.
Were there any changes made since the Draft Permit was public noticed(Yes/No):NO
If Yes, list changes and their basis below:NA
11. Fact Sheet Attachments (if applicable):
• Request for Modification
• Fact Sheet: Final 2018 Aquatic Life Ambient Water Quality Criteria for Aluminum in
Freshwaters
• Whole Effluent Toxicity Summary
• Catawba Riverkeeper Comments
• Aluminum Human Health RPA
Page 4 of 4

AFFP
NPDES Wastewater Permit 613
Affidavit of Publication
Public Notice
STATE OF NORTH SS
S
STATE } North Carolina Environmental Management Commission/NPDES Unit
CARO1617 Mail Service Center
COUNTY OF CATAWBA) Raleigh,NC 27699-1617
Notice of Intent to Issue a NPDES Wastewater Permit The North Carolina
Environmental Management Commission proposes to issue a NPDES wastewater
Cindy Abel, being duly sworn, says: 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
That she is Cindy Abel of the Observer News Enterprise, a hearing should there be a significant degree of public interest.Please mail
daily newspaper of general circulation, printed and comments and/or information requests to DWR at the above address.Interested
published in Newton, Catawba County, North Carolina; persons may visit the DWR at 512 N.Salisbury Street,Raleigh,NC 27604 to review
that the publication, a copy of which is attached hereto, the information on file.Additional information on NPDES permits and this notice may
be found on our website:https://deq.nc.gov/public-notices-hearings,or by calling
was published in the said newspaper on the following [phone].The City of Newton[PO Box 550,Newton,NC 28658]has
requested modification of NPDES permit NCO036196 for its Clark Creek Wastewater
June 13, 2024 Treatment Plant,located in Catawba County.This permit modification is for the
reevaluation of total aluminum permit requirements.This permitted facility
discharges treated municipal wastewater to Clark Creek,a class C water in the
Catawba River Basin.This discharge may affect future allocations in this segment of
Clark Creek
Publish:June 13,2024
That said newspaper was regularly issued and circulated
on those dates.
SIGNED:
Cindy Abel
Subscribed to and sworn to me this 13th day of June
2024.
Danny Wray, Notary, Catawba County, North Carolina
My commission expires: October 17, 2026
01122514 00175870
Wren Thedford
NCDEQ-Division of Water Resources (27)
1617 Mail Service Center
Raleigh, NC 27699-1617

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information Table 2. Parameters of Concern
❑ CHECK IF HQW OR ORW WQS Name WQs Type Chronic Modifier Acute PQL Units
Facility Name Clark Creek WWTP Par01 Arsenic Aquactic Life C 150 FW 340 ug/L
WWTP/WTP Class IV Par02 Arsenic Human Health C 10 HH/WS N/A ug/L
Water Supply
NPDES Permit NCO036196 Par03 Beryllium Aquatic Life NC 6.5 FW 65 ug/L
Outfall 001 Par04 Cadmium Aquatic Life NC 1.8281 FW 12.3832 ug/L
Flow, Qw (MGD) 7.500 Par05 Chlorides Aquatic Life NC 230 FW mg/L
Receiving Stream Clark Creek Par06 Chlorinated Phenolic Compounds Water Supply NC 1 A ug/L
HUC Number 03050102 Par07 Total Phenolic Compounds Aquatic Life NC 300 A ug/L
Stream Class C Par08 Chromium III Aquatic Life NC 401.5308 FW 3189.1072 ug/L
❑ Apply WS Hardness WQC Par09 Chromium VI Aquatic Life NC 11 FW 16 pg/L
7Q10s (cfs) 6.000 Par10 Chromium, Total Aquatic Life NC N/A FW N/A pg/L
7Q10w (cfs) 10.00 Par11 Copper Aquatic Life NC 28.3452 FW 44.5956 ug/L
30Q2 (cfs) 6.00 Par12 Cyanide Aquatic Life NC 5 FW 22 10 ug/L
QA(cfs) 35.00 Par13 Fluoride Aquatic Life NC 1,800 FW ug/L
1Q10s (cfs) 4.99 Par14 Lead Aquatic Life NC 15.4514 FW 413.9976 ug/L
Effluent Hardness 150.38 mg/L (Avg) Par15 Mercury Aquatic Life NC 12 FW 0.5 ng/L
------------- ----------------------
Upstream Hardness 37.12 mg/L (Avg) Par16 Molybdenum Human Health NC 2000 HH ug/L
------------- ----------------------
Combined Hardness Chronic 111.82 mg/L Par17 Nickel Aquatic Life NC 132.2198 FW 1231.2009 pg/L
------------- ----------------------
Combined Hardness Acute 116.36 mg/L Par18 Nickel Water Supply NC 25.0000 WS N/A pg/L
Data Source(s) —CD—ri ——um—eri—c Crit—er—ia f—or—A—lum—in—
um based on Par19 Selenium Aquatic Life NC 5 FW 56 ug/L
❑ CHECK TO APPLY MODEL Human Health used. Par20 Silver Aquatic Life NC 0.06 FW 4.1745 ug/L
Par21 Zinc Aquatic Life NC 450.9465 FW 462.6315 ug/L
Par22 Aluminum Aquatic Life NC 8000 FW pg/L
Par23
Par24
36196 RPA, input
8/5/2024

REASONABLE POTENTIAL ANALYSIS
H2
Use"PASTE SPECIAL
Upstream Hardness Values"then"COPY"
Maximum data
points=58
Date Data BDL=1/2DL Results
1 7/5/2017 36 36 Std Dev. 6.4796
2 11/2/2017 46 46 Mean 37.1176
3 2/8/2018 32 32 C.V. 0.1746
4 3/5/2018 42 42 n 34
5 4/3/2018 46 46 10th Per value 29.20 mg/L
6 5/2/2018 36 36 Average Value 37.12 mg/L
7 6/5/2018 18 18 Max. Value 46.00 mg/L
8 8/1/2018 20 20
9 9/4/2018 44 44
10 1/2/2019 32 32
11 2/6/2019 40 40
12 3/6/2019 36 36
13 4/3/2019 36 36
14 5/1/2019 36 36
15 6/4/2019 44 44
16 7/2/2019 42 42
17 8/6/2019 40 40
18 9/3/2019 40 40
19 10/2/2019 44 44
20 11/6/2019 36 36
21 12/5/2019 40 40
22 1/2/2020 40 40
23 2/12/2020 28 28
24 3/4/2020 36 36
25 4/1/2020 40 40
26 5/6/2020 40 40
27 6/2/2020 36 36
28 7/1/2020 40 40
29 8/5/2020 32 32
30 9/2/2020 28 28
31 10/6/2020 40 40
32 11/5/2020 44 44
33 12/2/2020 36 36
34 1/13/2021 36 36
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
36196 RPA, data
- 1 - 8/5/2024

REASONABLE POTENTIAL ANALYSIS
Par22
Use"PASTE SPECIAL
Aluminum Values"then"COPY"
Maximum data
points=58
Date Data BDL=1/2DL Results
1 3/11/2020 67 67 Std Dev. 181.1352
2 6/11/2020 6 6 Mean 76.1282
3 9/24/2020 80 80 C.V. 2.3793
4 12/9/2020 58 58 n 39
5 3/9/2021 67 67
6 6/8/2021 56 56 Mult Factor= 1.31
7 8/10/2021 60 60 Max. Value 1140.0 tag/L
8 9/14/2021 52 52 Max. Pred Cw 1493.4 Ng/L
9 10/12/2021 45 45
10 11/9/2021 < 50 25
11 12/14/2021 < 50 25
12 1/11/2022 54 54
13 2/8/2022 < 50 25
14 3/9/2022 129 129
15 4/12/2022 51 51
16 5/11/2022 59 59
17 6/15/2022 73 73
18 7/12/2022 63 63
19 8/10/2022 72 72
20 9/14/2022 62 62
21 10/11/2022 32 32
22 11/9/2022 37 37
23 12/7/2022 23 23
24 1/10/2023 22 22
25 2/8/2023 17 17
26 3/15/2023 39 39
27 4/12/2023 22 22
28 5/10/2023 12 12
29 6/7/2023 23 23
30 7/11/2023 18 18
31 8/9/2023 25 25
32 9/13/2023 28 28
33 10/10/2023 27 27
34 11/9/2023 16 16
35 12/14/2023 20 20
36 1/10/2024 1140 1140
37 2/14/2024 13 13
38 3/13/2024 294 294
39 4/9/2024 32 32
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
36196 RPA, data
-2 - 8/5/2024

Clark Creek WWTP > Outfall 001
NCO036196 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 7.5 MGD
MAXIMUM DATA POINTS = 58
Qw (MGD) = 7.5000 WWTP/WTP Class: IV COMBINED HARDNESS (mg/L)
1Q10S (cfs) = 4.99 IWC% @ 1Q10S = 69.96689738 Acute = 116.36 mg/L
7Q10S (cfs) = 6.00 IWC% @ 7QIOS = 65.95744681 Chronic= 111.82 mg/L
7QIOW (cfs) = 10.00 IWC% @ 7Q10W= 53.75722543
30Q2 (cfs) = 6.00 IWC% @ 30Q2 = 65.95744681
Avg. Stream Flow, QA(cfs) = 35.00 IW%C @ QA= 24.93297587
Receiving Stream: Clark Creek HUC 03050102 Stream Class: C
PARAMETER NC STANDARDS OR EPA CRITERIA J co REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION
TYPE Aplied Chronic Standa d Acute D n #Det. Max Pred Cw Allowable Cw
Acute: NO WQS
Aluminum NC 8000 FW(7Q I Os) µg/L 39 36 1,493.40000
Chronic: 12129.032 [No RP shown-see Fact Sheet
No value >Allowable Cw
36196 RPA, rpa
Page 1 of 1 8/5/2024

CATAW BA
RIVERKEEPER®
July 151h 2024
NCDEQ-DWR
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Water Quality Permitting Section,
The Catawba Riverkeeper Foundation is a member-funded environmental nonprofit that educates,
advocates, and protects the Catawba-Wateree River and all its tributaries. Our organization represents
over 8,400 active members who rely on the watershed for drinking water, recreation, and electricity. Clark
Creek is a class C tributary to the South Fork Catawba River and it is currently impaired for benthos. We
appreciate the opportunity to comment on the City of Newton's Clark Creek Wastewater Treatment Plant
NPDES permit(NC0036196). We make the following recommendations:
Monitor and report PFAS
• Clark Creek is designated as a class C surface water and is a major tributary of the South Fork
Catawba River. Low but detectable amounts of PFAS have been found just downstream in the
South Fork Catawba River. The South Fork serves as a drinking source for the Town of
Lincolnton, Town of High Shoals, and the Town of Dallas before flowing into Lake Wylie. We
recommend adding language similar to Special Condition A.(8.)from the recently issued Sugar
Creek WRRF (NC0024937) permit. Downstream users on the South Fork deserve the same
levels of protection.
Monitor discharge of E. coli in addition to fecal coliform and addressing limit violations
• For the last 38 years, the EPA has recommended using E. coli instead of fecal coliform as an
indicator of pathogens. The information would provide users with a better indicator of risk and
water quality.
Create a compliance schedule to limit violations of fecal coliforms from I&I
• A notice of violation was issued on February 9, 2024 (NOV-2024-LV-0137)for a fecal coliform
exceedance due to increased inflows during a rainfall event. According to the state climatologist,
heavy precipitation events are becoming more frequent. We recommend that Clark Creek WWTP
implements a preventative plan that will prevent future exceedances during these high flow
events.
Increase monitoring frequency of upstream of dissolved organic carbon (DOC), hardness, pH, and
effluent Aluminum and chronic toxicity from quarterly to monthly
• Greater data resolution will allow for quicker compliance with the updated 2018 EPA NRWQC
guidelines and allow a more accurate determination of seasonal changes.
• Data on DOC, Upstream hardness, pH and aluminum information is needed to input into the EPA
NRWQC for aluminum and should be collected swiftly to set a standard for aluminum.
• A notice of violation was issued on May 10, 2024 (NOV-2024-LV-0401)for aluminum (AI)
exceeding the Permit Daily Maximum of 154.30 ug/I and exceeding the Permit Monthly Maximum
of 154.30 ug/l.
A WATERKEEPER ALLIANCE° Member
102 Main St Suite 100 McAdenville NC 28211
Phone: [phone] Fax:[phone]
www.catawbariverkeeper.org

CATAW BA
RIVERKEEPER®
Limit Aluminum based on calculated human health criteria
• Limit Al limit based on human health in accordance with 15A NCAC 02B .0208 until DEQ staff
have enough data to calculate the aquatic life.
For the River,
Brandon Jones
Catawba Riverkeeper
A WATERKEEPER ALLIANCE° Member
102 Main St Suite 100 McAdenville NC 28211
Phone: [phone] Fax:[phone]
www.catawbariverkeeper.org

®1®
3aIiuGIIM!I."i— 611GA I IJIUdi
P.O. Box 550* Newton, N.C. 28658*[phone]
May 20, 2024
Michael Montebello
NPDES Branch Chief
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NOV's for Aluminum and removal of parameter limits from permit
Mr. Montebello,
The City of Newton is asking that the Aluminum limits that are currently on our Wastewater Permit be
removed because we feel that the limits were calculated in error and removing them wouldn't trigger a
backslide.
We also ask that you waive the Major Modification fee on this as well as modify our permit and remove
the limits on this parameter and allow us to monitor them quarterly.
We acknowledge the NOV's but understand that the monetary fines will be rescinded.
Thank you for your consideration on these issues.
Since ely,
Eric J n s
WWT Superintendent
City of Newton

Office
UnitedASK •nmental ProtectionEPA 00
Agency December 2018
Fact Sheet: Final 2018 Aquatic life Ambient Water
Quality Criteria for Aluminum in Freshwaters
Summary What is Aluminum and How Does It Enter
The EPA has published final updated aquatic life the Water?
ambient water quality criteria recommendations for Aluminum is found in most soils and rocks. It is the
aluminum in freshwater under Section 304(a)(1) of third most abundant element and the most common
the Clean Water Act to reflect the latest scientific metal in the earth's crust. Aluminum can enter the
knowledge. There are not enough data to support water via natural processes, like weathering of rocks.
the development of estuarine/marine aluminum Aluminum is also released to water by mining,
criteria at this time. Aluminum can inhibit an aquatic industrial processes using aluminum, and in waste
organism's ability to regulate salt concentrations and water and drinking water treated with alum, an
clog fish gills, potentially resulting in death or aluminum compound.
affecting growth and reproduction.
States and authorized tribes can adopt these criteria How Does Aluminum Affect Aquatic Life?
into their water quality standards or can adopt other Aluminum is considered a non-essential metal
aluminum criteria that is scientifically defensible because fish and other aquatic life do not need it to
based on local or site-specific conditions. These final function. Elevated levels of aluminum can affect
criteria are not a regulation, nor do they impose a some species' ability to regulate ions, like salts, and
legally-binding requirement. These criteria provide inhibit respiratory functions, like breathing.
information for states to develop science-based Aluminum can accumulate on the surface of a fish's
standards that reflect site-specific factors and are gill, leading to respiratory dysfunction, and possibly
protective against the effects of aluminum on death. Aquatic plants are generally less sensitive to
aquatic life. aluminum than fish and other aquatic life.
Background What is a Water Chemistry Parameter and
The EPA first published criteria for aluminum in Why is it Important?
1988.The updated aluminum criteria better reflect Bioavailability is the measure of whether a substance
the latest science. Studies have shown that three in the environment is available to affect living
water chemistry parameters— pH, total hardness, organisms, like fish.The bioavailability of aluminum
and dissolved organic carbon (DOC)—can affect the is dependent on the chemistry of the water. The
toxicity of aluminum by affecting the bioavailability more bioavailable the aluminum is, the more likely it
of aluminum in the water to aquatic species. Unlike is to cause a toxic effect. The water chemistry
the fixed acute and chronic values found in the 1988 parameters that have the greatest impact on
criteria recommendation, these final 2018 aluminum's bioavailability are pH, total hardness,
recommended criteria provide users the flexibility to and DOC.
develop site-specific criteria based on local water ■ pH: a low pH generally makes it easier for
chemistry. aluminum to be dissolved, and therefore more
The EPA released a draft of this criteria in 2017 for bioavailable. At higher pH, aluminum speciation
public comment and has reviewed the comments changes make it more bioavailable.
and updated the document. ■ Hardness: generally, higher hardness values
mean there are more ions present.These ions

compete with aluminum and make aluminum Where can I find more information?
less bioavailable.
For more information and to view the aluminum
■ DOC: higher dissolved organic carbon reduces criteria document and the criteria calculator, please
bioavailability. Aluminum is bound to DOC, visit EPA's website at www.epa.gov/wgc/aquatic-
making the aluminum less bioavailable to aquatic life-criteria-aluminum or email Diana Eignor at
organisms.
[e-mail].
What are the Recommended Criteria for
Aluminum in Freshwater for the Protection
of Aquatic Life?
The recommended aquatic life criteria for aluminum
in freshwater depend on a site's water chemistry
parameters. Unlike the fixed values found in the
1988 criteria document,these criteria use Multiple
Linear Regression (MLR) models to normalize the
toxicity data and provide a range of acceptable
values. The criteria are calculated based on a site's
pH, total hardness, and DOC. See Table 1 for a
comparison of 2018 and 1988 criteria values.
For freshwater criteria, users can enter their site's
water quality parameters into the Aluminum Criteria
Calculator V.2.0.x1sm or use the lookup tables in the
criteria document's appendix. The resulting acute
criterion indicates that freshwater organisms would
be protected if the one-hour average concentration
is not exceeded more than once every three years
on average. The chronic criterion indicates that
freshwater organisms would be protected if the
four-day average concentration is not exceeded
more than once every three years on average.
Table 1: Comparison of the EPA's 2018 and 1988 National Recommended Aquatic Life Criteria for
Aluminum
Freshwater Acute' Freshwater Chronic'
(1 hour, (4-day,
Version total recoverable aluminum) total recoverable aluminum)
2018 Criteria 1-4,800 µg/Lb 0.63-3,200 jig/Lb
(vary as a function of a site's pH,total hardness,and DOC)
1988 Criteria 750 µg/L 87 µg/L
(pH 6.5—9.0,across all total hardness and DOC ranges)
'Values are recommended not to be exceeded more than once every three years on average.
b Values will be different under differing water chemistry conditions.

Whole Effluent Toxicity Testing and Self Monitoring Summary
Newport WWTP NCO021555/001 County: Carteret Region: WIRO Basin: WOK03 Jan Apr Jul Oct SOC JOC:
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 N D
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 NCO036196/001 County: Catawba Region: MRO Basin: CTB35 Mar Jun Sep Dec SOC JOC:
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 l A S O N D
2020 - - Pass(s) - >100(P) Pass - - Pass>100(P) - - Pass
2021 - - Pass(S)Pass(5) - - Pass(s)Pass(s)>100(F - - Pass(S)Pass(5) - - Pass(S)Pass(S)
2022 - - Pass(S)Pass(5) - - Pass(5)Pass(S) - - Pass Pass - - >100 Pass Pass
2023 - - Pass Pass - - Pass Invalid Pass - - >100 Pass Pass - - Pass Pass
2024 - - Pass Pass>100 - - - - - - - - -
Norfolk Southern Railway Co.-Linwood NCO029246/011 County: Davidson Region: WSRO Basin: YAD04 Mar Jun Sep Dec SOC JOC:
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 I J A S O N D
2020 - - H - - - - - Pass - - INVALID
2021 Pass - Pass - - H - - H - - H
2022 - - Pass - - H - - H - - Pass
2023 - - H - - H - - Pass - - H
2024 - - H - - - - - - - - -
Norman H.Larkins WPCF NCO020117/001 County: Sampson Region: FRO Basin: CPF19 Mar Jun Sep Dec SOC JOC:
Ceri7dPF Begin: 2/1/2012 chr lim:90% NonComp: Single 70.10: 0.0 PF: 5.0 IWC: 100 Freq: Q
J F M A M J J A S O N D
2020 - - Pass - - Pass - - Pass - - Pass
2021 - - Pass - - Pass - - Pass - - Pass
2022 - - Pass - - Pass - - Pass - - Pass
2023 - - Pass - - Pass - - Pass - - >100(P)Fail
2024 >100(P)>100 >100(P)>100 >100(P)Pass - - - - - - - - -
North Cary WRF NCO048879/001 County: Wake Region: RRO Basin: NEU02 Feb May Aug Nov SOC JOC:
Ceri7dPF Begin: 1/1/2019 chr lim:90% NonComp: Single 7Q10: 0.30 PF: 12.0 IWC: 90 Freq: Q
J F M A M J J A S O N D
2020 - Pass - - >100(P)Pass - - Pass - - Pass -
2021 - Pass 97.5(P) - - Pass - - Pass - - Pass -
2022 - Pass - - >100(P)Pass - - Pass - - Pass -
2023 - Pass - - Pass - - >100 Pass - - Pass -
2024 - Pass - - Pass - - - - - - -
Leeend: P=Fathead minnow(PimDhales Dromelas).H=No Flow(facilitv is active).s=Solit test between Certified Labs Page 74 of 113