NC0087866_Fact Sheet_20240820

NCDEQ / DWR / NPDES
EXPEDITED FACT SHEET - NPDES PERMIT RENEWAL
NPDES Permit NCO087866
Sara Bassett / Compliance & Expedited Permitting Unit / sara.bassett(kdeq.nc.gov / August 2024
FACILITY INFORMATION
Applicant/Facility Name
Gregory Flory / Manager and Owner
John F. Kime WTP
Mailing Address
P.O. Box 1326 Randleman, NC 27317
Facility Physical Address
7297 Adams Farm Road Randleman, NC 27317
Max, Monthly Avg Flow (MGD)
1.142 MGD
Type of Waste
Membrane and conventional discharge
Facility Class
PC-1
County
Randolph
Permit Status
Renewal
Regional Office
WSRO
STREAM CHARACTERISTICS
Receiving Stream
Deep River (Randleman
Lake)
Stream
Classification
WS-IV; CA:*
Stream Segment
17-(4)
Outfall Lat.
35.861806 N
7Q 10 - Summer (cfs)
7.7
Outfall Long.
79.822167 W
7Q10 -Winter (cfs)
-
Drainage basin
Cape Fear
30Q2 (cfs)
-
Subbasin
03-06-08
Average Flow (cfs)
-
HUC
0303000301
IWC (%)
100%
303(d) List
No
FACILITY SUMMARY
The John F. Kime WTP utilizes membrane and conventional technology. This water treatment plant
currently has a design potable flowrate of 14.7 MGD and a maximum, monthly average wastewater
discharge of 1.14 MGD.
The existing treatment components at the water treatment plant are the following:
• Equalization lagoon
• Gravity thickener
• Decant lagoon
• Discharge flume with flow measurement
• Belt filter press
• Dechlorination
• pH adjustment
• Dry polymer mixing and feed system — cationic polymer is currently used — Polytech 2160
• Processed Dried Sludge Storage Containment Areas
Chemical usage consists of:
• Potassium permanganate
• Ferric Sulfate
• Sodium Hypochlorite
• Fluoride
• Ammonia
• Calcium Thiosulfate
INFORMATION FROM PREVIOUS FACTSHEET
Fact Sheet for Permit Renewal
August 2024 - NPDES Permit NCO087866 - Page 1

1. The WTP has in the past been considered a conventional WTP for purposes of NPDES permitting.
However, it does use microfiltration, which would cause it to be permitted under a different WTP
permitting strategy, combining those requirements with those for a conventional WTP.
2. The permit was originally issued with a 23% concentration for its WET testing. This percentage was
based upon historical 7Q10 flow (7.7 cfs) at a gauging station on the Deep River downstream of the
discharge point near Randleman. This stream flow value was calculated based upon data collected prior to
construction of the Randleman Dam. The reservoir's tiered release program calls for a minimum release of
30 cfs from the dam except during drought conditions (20 cfs if reservoir drops to below 60% full; 10 cfs, if
it drops below 30% full). The lake was predicted to operate at over 60% full 90% of the time. All that
being said, the discharge from the WTP is not downstream of the release from the dam. As such, the correct
concentration for WET testing should be 90% as opposed to 23%, because the discharge is not to a free
flowing portion of the stream.
It pointed out that its use of microfiltration differed greatly from that of most other WTPs in North Carolina,
especially in terms of its source water and the concentrations of elements in the wastewater. It noted that in
terms of water treatment, it is considered a conventional WTP by the Public Water Supply Section. It
requested the permit be prepared pursuant to the Division's conventional WTP permitting strategy only.
It was decided to reissue the permit per the terms of the conventional permitting strategy, and not include
those associated with membrane treatment, as the facility is essentially a conventional WTP. It was also
decided that the WET test concentration should be modified to 90% because the discharge is to the lake
proper, and likely does not receive significant mixing. The PTRWA was advised that the Division may
change its stance regarding the permitting strategy at the next permit renewal should the facility begin to
fail its toxicity tests at the new concentration. (UPDATE June 2024: the facility has been failed 4 of 12
toxicity tests in the past three years, however, the Division decided to it was appropriate to maintain 90%
unless the facility decides to do dilution modeling)
RENEWAL SUMMARY
After discussion with Division management, it was concluded that use of 7.7 cfs for the 7Q10 in the WLA
calculations was appropriate in this renewal despite the fact that the receiving water is not free flowing.
The Division has also concluded that 90% will continue to be used for WET tests unless dilution monitoring
is completed. A reopener special condition has been added in response to the number of failed WET tests at
this concentration in the past permit cycle.
The first draft of this renewal contained the following changes:
• The Supplement to Cover Sheet has been updated with the new maximum monthly average
discharge.
• The facility grade has been added to Section A. (1).
• Section A. (5) has been updated regarding electronic submission of effluent data. Federal
regulations require electronic submittal of all discharge monitoring reports (DMRs).
• Section A (3) has been added due to a history of failed WET tests. The Division is aware the
facility is looking into this issue.
• The Whole Effluent Testing outlined in Section A. (4) has been updated to Pass/Fail per the
Division's 2020 strategy.
• The Wastewater Treatment Components listed on the Supplement to Permit Cover Sheet have
been updated per the facility contact.
• The outfall components on the map have been updated per the facility contact.
• Turbidity limits have been removed as the receiving waters are not impaired for turbidity.
Monitoring is retained.
• The parameters of Sulfate, Bromine, Chloroform, Quinoline, Strontium, Vanadium, and
Nitrate -Nitrite have been added for monitoring in section A. (1) due to being marked "believed
Fact Sheet for Permit Renewal
August 2024 - NPDES Permit NCO087866 - Page 2

present" in the application. These parameters will be reevaluated in the next permit cycle. If the
parameters have consistently produced no -detect results, this reevaluation may lead to removal
of the monitoring requirement for these parameters.
Following the first public notice, it was recommended that the following changes be made and that
the permit was sent back to public notice.
• Monitoring for Bromide, Chloroform, Sulfate, Quinoline, Strontium, and Vanadium: After a
minimum of 12 samples for each have been collected over a 36-month period the permittee may
request that the Division reevaluate monitoring frequencies for these parameters. If the parameters
have consistently produced no -detection results this reevaluation may lead to removal of the
monitoring requirement for these parameters.
• Total Kjeldahl Nitrogen and Nitrate + Nitrite monitoring has been added to Section A. (1).
• Total Nitrogen sample type has been changed to "calculated."
• The chemical usage list has been updated on the Supplement to Permit Cover Sheet.
• Hardness monitoring has been updated in Section A. (L).
COMPLIANCE HISTORY
No violations or enforcements in the last permit cycle other than WET (see below).
NCG59 GENERAL PERMIT ELIGIBILITY (FOR CONVENTIONAL & GREENSAND ONLY)
• This plant utilizes components not considered conventional water treatment.
• Conclusion: Ineligible for NCG59 General Permit.
WHOLE EFFLUENT TOXICITY (WET) TESTING
In accordance with current strategy, WET testing is required in this permit as Freshwater 7 day Chronic
[TGP3B] Pass/Fail Quarterly monitoring with Ceriodaphnia dubia at an effluent concentration of 90%.
This facility has failed four of 12 toxicity tests in the last three years. Section A. (3.) Permit Reopener:
Whole Effluent Toxicity has been added. Per the application, the permittee is aware of the issue and
looking into it.
REASONABLE POTENTIAL ANALYSIS
A reasonable potential analysis (RPA) was performed for a discharger going to a freshwater stream. A flow
(Qw) of 1.141612 MGD was used based on the maximum, monthly average flow between October 2020
and October 2023.
Based on this analysis, the following permitting actions are proposed for this permit:
Zinc — no reasonable potential to exceed water quality standards; maintaining quarterly monitoring
Fluoride — no reasonable potential to exceed water quality standards; maintaining quarterly
monitoring
Copper — no reasonable potential to exceed water quality standards; maintaining quarterly
monitoring
There was initially a discrepancy with the copper and zinc eDMR data from the date of 10/10/2023. The
facility reached out to the lab which reported that there was possible contamination of the sample during
digestion. The lab still had some of the original sample and was able to re -run it. The corrected values were
utilized in the RPA.
COMMENTS ON DRAFT PERMIT
Fact Sheet for Permit Renewal
August 2024 - NPDES Permit NCO087866 - Page 3

No concerns from aquatic toxicology, operator certification, public water supply, or Winston-Salem
Regional Office.
Several public comments were received and have been summarized and responded to as needed. (See
below). The only response action taken was to add a flow limit to this permit.
This permit will go through a second round of public notice due to changes to the sampling plan for several
of the parameters being added this cycle. New updated monitoring will be as follows:
• Monitoring for Bromide, Chloroform, Sulfate, Quinoline, Strontium, and Vanadium: After a
minimum of 12 samples for each have been collected over a 36-month period the permittee may
request that the Division reevaluate monitoring frequencies for these parameters. If the parameters
have consistently produced no -detection results this reevaluation may lead to removal of the
monitoring requirement for these parameters.
IN THE RESPONSE TO PUBLIC COMMENTS RECEIVED FOR THE JOHN F. KIME WTP:
Robert Frederick and Krisdena Reeser submitted public comments and requested a full public
hearing. Katie Gumerson submitted public comments.
No public hearing will be held per the review of Richard E. Rogers, Division of Water Resources
Director.
The following addresses the received concerns:
• Concerns expressed regarding potential increase of flow:
A maximum monthly discharge flow limit has been added to the permit of 1.31 MGD.
Concern regarding the Piedmont Triad Regional Water Authority (PTRWA) website, board
appointees, lack of access to board members, and future utilization of Reverse Osmosis
Treatment system:
The Division of Water Resources NPDES permitting has no authority over the Piedmont Triad
Regional Water Authority's website, board of directors, or public communication. For concerns
related to this, citizens will need to reach out directly to PTRWA. In the event that the PTRWA
seeks to modify or expand the facility treatment system in the future, proposed changes will be
reviewed by the Division.
Concern expressed due to the facilities past failed WET testing:
While this facility has a number of failed WET tests in the last permit cycle, they were only
required to utilize WET testing for monitoring purposes. In the proposed renewal, this facility will
have a Pass/Fail WET testing limit. A reopener condition has been added to the permit to address
the fact they have had WET failures recently. This allows the DWR to review the permit again prior
to their next renewal cycle:
"Whole Effluent Toxicity monitoring results indicating aquatic toxicity may result in the
Division of Water Resources re -opening this permit or requesting by letter that further
action be taken. Additional metals testing, a toxicity identification evaluation, a toxicity
reduction evaluation, and/or an assessment of discharge treatment alternatives may be
requested."
Concerns regarding the use of Meritech lab and concern of result accuracy:
This is a NC certified lab; parameter testing results are reported to the "practical quantitation limit."
Fact Sheet for Permit Renewal
August 2024 - NPDES Permit NCO087866 - Page 4

• Concerns about upstream WWTP and activity:
This renewal only addresses the discharge from John F. Kime WTP. It does not include review of
projected population increase, increased development, or concerns regarding other wastewater
facilities such as High Point Eastside WWTP.
• Questions about why the public notice system doesn't publish more broadly:
The public notice strategy outlines "publishing the notice one time in a newspaper having general
circulation in said county, in accordance with G.S. 143-215. 1 (c)(2)."
• Why aren't eDMR reports and information on Laserfiche more readily available to the
public:
Laserfiche is DWR's public facing server where files such as permits and applications can be
viewed. eDMR data can be requested through AcessDEQ on the North Carolina DEQ website by
filling out a Public Records Request Form.
• Questions about new parameter monitoring:
New parameters (sulfate, bromine, chloroform, quintoline, strontium, vanadium) were added
because the facility reported them as believed present in their renewal application citing previous
detects in raw water sampling in the reservoir. The DWR is therefore requiring them to monitor
these parameters throughout this next permit cycle. The data collected from their monitoring will be
used to inform a reasonable potential decision regarding these parameters in the next NPDES
renewal cycle for this facility.
Fact Sheet for Permit Renewal
August 2024 - NPDES Permit NCO087866 - Page 5