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HomeMy WebLinkAboutNC0004812_Permit (Modification)_20060412NPDES DOCUWEMT SCAMMIMS COVER SHEET NPDES Permit: NC0004812 Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) C-115'e—rmit Modification Compliance 1 Enforcement Permit History Date Range: Corres ondence Document Date: April 12, 2006 TNIS DOCUMENT IS PRINTED ON REUSE PAPER - IGNORE ANY CONTENT ON THE REVERSE SIDE i ly.." -1 April 12, 2006 Mr. Mike Church Environmental Engineer Pharr Yarns 100 Main St. McAdenville, North Carolina 28101 Dear Mr. Church: Michael F. Easley, Govemor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality Subject: Permit Modification Permit NC0004812 Pharr Yarns WWI'P Gaston County The NPDES Unit has received your permit modification request concerning the effluent limitations for sulfide, phenols and total chromium in the January 21, 2005 permit. We have evaluated the information submitted and determined that limits for these parameters should be revised. Based on effluent guidelines from 40 CFR 410.70 Subpart G and a monthly average production value of 24000 lb/day (which will be used in the calculation of both daily maximum and monthly average limits), the revised limits are as follows: • Sulfide = 2.9 lbs/day (Monthly average); 5.8 lbs/day (Daily maximum) ■ Phenol = 1.4 lbs/day (Monthly average); 2.91bs/day (Daily maximum) • Total Chromium = 1.4 lbs/day (Monthly average); 2.9 lbs/day (Daily maximum) At this time, the Division is submitting a notice to the newspapers of general circulation in Gaston County, inviting comments from you or your representative, the public and other agencies on the draft permit. The notice should be published on or about April 12, 2006. Following a 30-day comment period, we will review all pertinent comments received and take appropriate action on the permit issuance upon submission of all required data. Please provide written comments on the draft permit no later than May 19, 2006. If you have any questions, please contact me at (919) 733-5083, extension 512. 512. If you have any questions or comments concerning this draft permit, contact me at 919-733-5083 ext. pectfully,) R, Jacglyn M. Now ll `E° NPIPES Western rogram Attachments cc: NPDES Files Mooresville Regional Office / Surface Water Protection Section PERCS Aquatic Toxicology Unit EPA Region IV/Marshall Hyatt A e DEH IV ` hCarolma 'aturallrm North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: www.ncwaterquality.ora Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax (919) 733-2496 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper lr f 3�41 lr's�;� �f?sa Permit NC0004812 6-j i STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY lum.0 ►viii1w TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Pharr Yarns, Incorporated is hereby authorized to discharge wastewater from a facility located at the Pharr Yarns Wastewater Treatment Plant 147 Willow Drive McAdenville Gaston County to receiving waters designated as the South Fork Catawba River in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective xxxxxxxxxxxxxxxxxx. This permit and authorization to discharge shall expire at midnight on January 31, 2009. Signed this day Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0004812 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Pharr Yarns, Inc. is hereby authorized to: 1. Continue to operate an existing 1.0 MGD wastewater treatment facility for the treatment of industrial and domestic wastewater consisting of an extended aeration basin, two clarifiers with alum and polymer addition, two return activated sludge pumps, three mixed media pressure filters, two filter pumps, an aerobic digester, sludge thickening tank, dewatering belt press, sludge storage and drying pad, tablet type chlorinator, and dual chlorine contact chamber located at Pharr Yarns Wastewater Treatment Plant, 147 Willow Drive, McAdenville in Gaston County, and 2. Discharge from said treatment works at the location specified on the attached map into the South Fork Catawba River, which is a classified WS-V waterbody in the Catawba River Basin. It is agreed that NPDES permit limits for 1-MGD will become effective upon achievement of both of the following conditions: • The monthly average effluent flow exceeds 0.5-MGD for the first time • Pharr Yarns, Inc. submits to DWQ's NPDES and Point Source Compliance and Enforcement Units a certified letter within 30 days following the first month that the average monthly effluent flow from the Pharr Yarns WWTP exceeds 0.5-MGD. N00004812- Pharr Yarns, Inc. Latitude: 35015'39" Sub -Basin: 03-08-36 Longitude: 81004'38" Quad #: F14SFJMount Holly, NC Stream Class: WS-V Receiving Stream: South Fork Catawba River Permitted Flow: 1.0 MGD Facility x Location Yams, North Gaston County County NCOOD4812 Permit NC0004812 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of this permit and lasting until the f rst time the monthly average flow exceeds 0.5 MGD, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT LIMITS MONITORING REQUIREMENTS CHARACTERISTICS Monthly Average Daily Max f num ' Measurement Sample Sample tocation, Fre uenc TYOO I -(ow 0.5 MGD Continuous Recording I Influent or Effluent BOD5, 20oC 113.4 lbs/day 181.0 lbs/day Weekly Composite Effluent Total Suspended Solids 147.7 lbs/day 249.7 lbs/day Weekly Composite Effluent COD 475.0 lbs/day 849.6 lbs/day Weekly Composite j Effluent Sulfide 2.9 lbs/day 5.8 lbs/day Weekly Composite Effluent Phenols 1.4 lbs/day 2.9 lbs/day Weekly Grab Effluent Total Chromium 1.4 lbs/day 2.9 lbs/day Weekly Composite Effluent Fecal Coliform (geometric mean) 2001100 mL 400/100 mL Weekly Grab Effluent, Upstream, Downstream' NH3-N Weekly Composite Effluent Dissolved Oxygen Weekly Grab Effluent, Upstream, Downstream' H2 Weekly Grab Effluent Temperature - Daily Grab Effluent Temperature Weekly Grab Upstream, Downstream Conductivity Weekly Grab Effluent, Upstream, Downstream' No Effluent Limitation (mg/L) Weekly Composite Effluent Total Nitrogen (NO2 + NO3 + TKN)3 No Effluent Limitation (lb/month) (3) Monthly Calculated Effluent 3 13,698 lb/year (annual mass loading) () Annually Y Calculated (Calculated) Effluent Total Phosphorus3 No Effluent Limitation (mg/L) Weekly Composite Effluent No Effluent Limitation (lb/month) (3) Monthly Calculated Effluent 1522 lb/year (annual mass loading) (3) Annually (Calculated) Effluent Color4 Monthly Composite Effluent Color4 Monthly Grab Upstream, Downstream' Chronic Toxicit s Quarterly Composite Effluent Total Residual Chlorines 28 /L Weekly Grab Effluent Notes: I Sample locations: Upstream - upstream 50 feet or more above the discharge point; Downstream - downstream at Highway 7 bridge. Instream monitoring shall be conducted 3/week from June through September and once per week the remainder of the year. 2 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units 3 The annual mass loading for total nitrogen and total phosphorus for Outfall 001 shall be monitored and calculated as prescribed in Part A.(5.). 4 See Special Condition A.(6.) for more information on the permit requirements associated with color. Effluent color samples shall be taken year round on a monthly basis. Instream sampling shall be performed on a monthly basis from April through October. 5 Chronic toxicity (Ceriodaphnia, P/F test at 0.62%) shall be performed in January, April, July and October. See Part A.(3.) 6 The TRC limit takes effect September 1, 2006. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC0004812 A.(2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the month following the first time the monthly average,flow exceeds 0.5- MGD and lasting until permit expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: CHARACTERISTICS Monthly Average Daily Maximum Measurement :Frequency Sample Type Sample Location' Flow 1.0 MGD Continuous Recording Influent or Effluent BODs, 20oC 204.7 lbs/day 318.0 lbs/day 3Meek Grab Effluent Total Suspended Solids 239.0 lbs/day 386.7 lbs/day 3Meek Grab Effluent COD 675.9 lbs/day 1150.9 lbs/day 3Meek Grab Effluent Sulfide 2.9 lbs/day 5.8 lbs/day Weekly Grab Effluent Phenols 1.4 lbs/day 2.9 lbs/day Weekly Grab Effluent Total Chromium 1.4 lbs/day 2.9 lbs/day Weekly Grab Effluent Fecal Coliform (geometric mean) 200/100 mL 400/100 mL 3Meek Grab Effluent, Upstream, Downstream' NH3-N 3/Week Composite Effluent Dissolved Oxygen 3Meek Grab Effluent, Upstream, Downstream' H2 3/Week Grab Effluent Temperature Daily Grab Effluent Temperature 3Meek Grab Upstream, Downstream Conductivity 3Meek Grab Effluent, Upstream, Downstream' No Effluent Limitation (mg/L) Weekly Composite Effluent Total Nitrogen No Effluent Limitation (lb/month) (3) Monthly (Calculated) Effluent (NO2 + NO3 + TKN)3 3 27397 lb/year (annual mass loading) (� Annually y Calculated ( ) Effluent No Effluent Limitation (mg/L) WeeklyComposite Effluent Total Phosphorus3 No Effluent Limitation (lb/month) (3) MonthlytCaI culated Effluent 3044lb/year (annual mass loading) (3) Annually (Calculated) Effluent Color4 Monthly Composite Effluents Color4 Monthly Grab Upstream, Downstreams Chronic Toxicit s FQuarterly Composite Effluent Total Residual Chlorines 28 /L I 3Meek Grab Effluent Notes: 1 Sample locations: Upstream - upstream 50 feet or more above the discharge point; Downstream - downstream at Highway 7 bridge. Instream monitoring shall be conducted 3/week from June through September and once per week the remainder of the year. 2 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units 3 The annual mass loading for total nitrogen and total phosphorus for Outfall 001 shall be monitored and calculated as prescribed in Part A. (5.). 4 See Special Condition A. (6.) for more information on the permit requirements associated with color. Effluent color samples shall be taken year round on a monthly basis. Instream sampling shall be performed on a monthly basis from April through October. 5 Chronic toxicity (Ceriodaphnia, P/F test at 1.2%) shall be performed in January, April, July and October. See Part A.(4.) 6 The TRC limit takes effect September 1, 2006. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC0004812 A. (3.) CHRONIC TOXICITY MONITORING/LIMIT — 0.5-MGD The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 0.62%. The permit holder shall perform at a minimum, quarteriu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0004812 A. (4.) CHRONIC TOXICITY MONITORING/LIMIT — 1.0-MGD The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 1.2%. The permit holder shall perform at a minimum, quarterlu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results, in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP313 for the pass/fail results and THP313 for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch. no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0004812 A.(5.) TOTAL NITROGEN AND PHOSPHORUS MONITORING The Permittee shall calculate the annual mass loading of total nitrogen as the sum of monthly loadings, according to the following equations: (a) Monthly Mass Loading (lb/mo.) = TN/TP x Q x 8.34 where: TN = the average total nitrogen concentration (mg/L) of the composite samples collected during the month at the outfall TP = The average total phosphorus concentration (mg/L) of the composite samples collected during the month at the outfall Q = the total wastewater flow discharged during the month at the outfall(MG/mo.) 8.34 = conversion factor, from (mg/L x MG) to pounds (b) Annual Mass Loading (lb/yr) = Y_ (Monthly Mass Loadings) for the calendar year The Permittee shall report the total nitrogen and total phosphorus concentration for each sample and the monthly mass loading in the appropriate self -monitoring report and the annual mass loading of total nitrogen and total phosphorus in the December self -monitoring report for the year. A (6). Color Permitting Requirements for Tier 1 Facility This facility has been classified as a Tier 1 color discharger. The permittee will conduct color monitoring of instream stations (upstream, downstream) on a monthly basis during summer season (April -October). The permittee will record whether a color plume was observed around the outfall pipe during the monthly instream sampling events, and include that information on the monthly discharge monitoring report. Effluent samples will be collected monthly for color on a year-round basis. Color samples will be analyzed for ADMI color at natural pH. Effluent samples will consist of 24-hour composites, while instream samples will be collected as grabs. Samples will be analyzed by a state certified laboratory. If data show that water quality standards for color are being violated by the discharge permitted by the terms of this permit, then the Director may reopen this permit for the purpose of imposing additional requirements pursuant to 15A NCAC 2H.0114. Alternatively, if future conditions change and color is no longer a component of the influent wastestream, then the permittee may request a permit modification to remove color permit requirements. SOC PRIORITY PROJECT: No To: Permits and Engineering Unit Water Quality Section Attention: Carolyn Bryant Date: February 7, 2005 NPDES STAFF REPORT AND RECOMMENDATIONS County: Gaston NPDES Permit No.: NC0004812 MRO No.: 04-71 PART I - GENERAL INFORMATION 1. Facility and address: Pharr Yarns WWTP 101 Main Street Post Office Box 1939 McAdenville, N.C. 28101 2. Date of investigation: January 13, 2005 3. Report prepared by: Michael L. Parker, Environmental Engineer II 4. Person contacted and telephone number: Mike Church, (704) 824-3551. 5. Directions to site: From the jct. of Hwy. 7 and I-85 in eastern Gaston County, travel south on Hwy. 7 z 0.2 mile and turn left on Dickson Drive (no SR number). The WWTP site is on the left side of Dickson Drive after traveling 0.2 mile. 6. Discharge point: Latitude: 350 15' 40" Longitude: 810 04' 39" Attach a USGS Map Extract and indicate treatment plant site and discharge point on map. USGS Quad No.: F 14 SE 7. Site size and expansion area consistent with application: Yes. Very limited area is available for expansion, if necessary. 8. Topography (relationship to flood plain included): The WWTP site did not appear to be located in the 100 year flood plain (many of the primary treatment units are elevated and protected from flooding by a concrete wall). 9. Location of nearest dwelling: Approx. 200f feet from the WWTP site. Page Two 10. Receiving stream or affected surface waters: South Fork Catawba River a. Classification: WS-V b. River basin and subbasin no.: Catawba 030834 C. Describe receiving stream features and pertinent downstream uses: Excellent flow in the receiving stream. Down stream uses are fish and wildlife propagation, secondary recreation, and agriculture. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater: 1.0 MGD (Design Capacity) b. What is the current permitted capacity: 0.50 MGD and 1.0 MGD. C. Actual treatment capacity of current facility (current design capacity): 1.0 MGD d. Date(s) and construction activities allowed by previous ATCs issued in the previous two years: There have been no ATCs issued to this facility in the past two years. e. Description of existing or substantially constructed WWT facilities: The existing WWT facilities consist of a bar screen followed by an aeration basin with fixed floating aerators, polymer and alum addition, two (2) clarifiers, flow measurement (continuous flow recording device with totalizer), three (3) mixed media pressure filters, a sludge thickening tank, an anaerobic sludge digester, a sludge centrifuge, a belt filter press, and tablet chlorine disinfection with contact basin. This facility has two power sources (Duke Power and the adjacent mill). f. Description of proposed WWT facilities: There are no proposed WWT facilities at this time. g. Possible toxic impacts to surface waters: Chlorine is added to the waste stream. This facility has consistently passed its toxicity testing. h. Pretreatment Program (POTWs only): Not Needed. 2. Residual handling and utilization/disposal scheme: Residuals are currently thickened and then processed in a belt filter press. From there they are stored on a concrete pad until such time as they are taken for disposal to the Gaston County Landfill. Several years ago, Pharr Yarns obtained approval to conduct a pilot study on static -pile composting of their residuals, however, they were unable to maintain the proper temperature to achieve the necessary pathogen reduction. 3. Treatment plant classification: Class II (based on current flow of 0.500 MGD) 4. SIC code(s): 2262 Wastewater code(s): 55 MTU code(s): 05602 Page Three PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? Public monies were not used in the construction of this facility. 2. Special monitoring or limitations (including toxicity) requests: None at this time. 3. Important SOC/JOC or Compliance Schedule dates: This facility is neither under an SOC nor is one being considered at this time. 4. Alternative analysis evaluation: There is no reasonable alternative for this facility. Municipal sewer of sufficient capacity to accept this waste flow is currently unavailable to this site. Spray/Drip Irrigation and/or subsurface disposal is not an option due to the lack of sufficient area. PART IV - EVALUATION AND RECOMMENDATIONS Pharr Yarns (PY) requests renewal of the subject Permit. There have been no changes to the existing WWT facility or the NPDES permit since the permit was last renewed. PY had previously been contacted by the Division regarding the possibility of nutrient limits being included in the permit upon renewal. As a result, PY evaluated their treatment process to determine whether the existing WWT facilities could comply with the anticipated nutrient limits (1.0 mg/l TP and 6.0 mg/l TN) without additional modifications and/or upgrade. Based on this evaluation, PY has concluded that additional modifications would be necessary in order to comply with the projected nutrient limits. Such being the case, if nutrient limits are to be incorporated into this permit at renewal, either a compliance schedule will need to be included in the NPDES permit or the nutrient limits will need to be phased in at a mutually acceptable time frame. Recent development plans in the Town of McAdenville area has prompted negotiations between the Town and PY about the possibility of PY accepting all the wastewater currently tributary to the Town's existing WWTP. The existing PY WWTP has the capacity to accept this additional wastewater, however, the Town has yet to commit to the connection to PY due to funding concerns. If development pressure continues in this area, elimination of the Town's WWTP by connecting to the PY WWTP may become a reality during the term of next NPDES permit. Pending recei t and approval of the WLA, it is recommended that the Permit be renewed as requested. Signature of Report Preparer Date 270T Water Quality Re tonal Supervisor Date hAdsr\dsr05\pharyam.dsr