NC0044423_Renewal (Application)_20200929

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Secretary ', �,
S.DANIEL SMITH NORTH CAROL.INA
Director Environmental Quality
September 29, 2020
Appalachian State University
Attn: Patrick Brittain, Asst. Dir. Facilities Operations
ASU Box 32105
Boone, NC 28607
Subject: Permit Renewal
Application No. NC0044423
Appalachian State WTP
Watauga County
Dear Applicant:
The Water Quality Permitting Section acknowledges the September 25, 2020 receipt of your permit renewal application
and supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW
permitting branch. Per G.S. 150B-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://dea.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
Sincerely,
aCtim,
ci
Wren Thedford
Administrative Assistant
Water Quality Permitting Section
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September 17,2020 Appalachian
STATE UNIVERSITY
Joe R.Corporon,L.G Facilities Operations
Water Quality Permitting Section-NPDES ASU Box 32105
Boone,NC 28608-2105
Division of Water Resources,NCDEQ 828-262-3190
512 N Salisbury Street facilitiesoperations.appstate.edu
Raleigh,NC 27604
Re: NPDES Permit No.NCoo44423 RECEIVED
Permit Renewal Application SEP 2 5 2020
Mr.Corporon,
NCDEOgVVR/NPDES
The NPDES permit NCoo44423 for the Appalachian State University(ASU)Water Treatment Plant
(WTP)will expire on March 31,2021.Enclosed is the Form C renewal application and associated
attachments to apply for renewal of the NPDES permit.
The NPDES permit issued April 1,2017 includes numerical limits for copper,zinc,and turbidity with a
compliance schedule for the copper and zinc limits to become effective January 1,2021.As required by the
permit,ASU has submitted an annual Corrective Action Plan(CAP)to document actions taken to achieve
compliance with the limits.
As part of the CAP,ASU has executed a sampling program from July 2019—July 2020 to characterize the
constituent balance around the facility.The attached Corrective Action Plan Sampling Program Data
Summary Memorandum summarizes the data collected during the CAP Sampling Program and builds on
the most recent CAP submitted to the NCDEQ on March 24,2020.
As detailed in the attached memo,data collected during the CAP Sampling Program indicates that the
ASU WTP is on net removing zinc and copper from the Norris Branch Reservoir and indicates that the
WTP is discharging a lower mass of metals than is withdrawn in the intake.The zinc and copper are
present in the source water withdrawn from the same body of water the compounds are being discharged
back into.It is ASU's opinion that the NPDES limit Reasonable Potential Analysis methodology should
not be applied to a discharger that is withdrawing the compounds from the same water body to which they
discharge them.In particular in the case when the mass being discharged is less than the mass withdrawn.
With respect to the turbidity limit,we understand the NC DEQ Changes to Water Treatment Plant
Strategy(October 2009)states that"turbidity will not be limited except for facilities that discharge to a
receiving stream which is impaired for turbidity".Norris Branch Reservoir is not included in the 3o3d
Impaired Water Bodies List,therefore a numerical turbidity limit is not consistent with NC DEQ's
published strategy.In addition,the io NTU limit is based on the instream water quality standard for
Trout Waters and is being applied directly to the effluent with no allowance for the dilution which occurs
in the reservoir. Turbidity data collected indicates that the reservoir is predominately below the instream
standard and the WTP discharge does not have a meaningful impact on the reservoir turbidity even when
the effluent exceeds the io NTU numerical limit.
Considering the data presented in the attached memorandum,Appalachian State University requests the
removal of copper,zinc,and turbidity numerical effluent limits from the NPDES permit.ASU requests
that the limits are replaced with once quarterly monitor and report requirements for the effluent and
within the reservoir.Monitoring data can be used to continue to demonstrate that the WTP returns less or
equal mass of metals compared to what is withdrawn in the intake and that the reservoir turbidity
concentration continues to be below the instream standard.
Should you have any questions,comments,or require additional information please do not hesitate to
contact me.
A MEMBER INSTITUTION OF THE UNIVERSITY OF NORTH CAROLINA AN EQUAL OPPORTUNITY EMPLOYER

Mr.Joe R. Corporon
August 31,2020
Sincerely,
Patrick Brittain, PE
License No.022085
Asst.Director Facilities Operation and Maintenance
Cc. Lon Snider,PE,Regional Supervisor,NCDEQ
Jenny Graznak, Environmental Specialist,NCDEQ
Gary Carter, PE, Director Physical Plant,ASU
Leigh-Ann Dudley, PE, Engineering Consultant, Dewberry

Dewberry'
MEMORANDUM
To: Mr. Patrick Brittain, PE
Appalachian State University Assistant Director Facilities Operations
Date: August 31, 2020
From: Leigh-Ann Dudley, PE RECEIVED
Re: Appalachian State University Water Treatment Plant SEF' 2 5 7020
NPDES Permit No. NC0044423
Corrective Action Plan Sampling Program Data Summary NCDEQ/DWR/NPDES
Purpose of the Memorandum
The purpose of this memorandum is to summarize the data collected during the Corrective Action Plan
Sampling Program from July 2019 through June 2020.This memorandum will build on the Corrective
Action Plan letter submitted by Appalachian State University(ASU)to Mr. Corporon of the North
Carolina Department of Environmental Quality(NCDEQ) on March 24, 2020,which summarized results
of the sampling program from July 2019 through January 2020.
Background
The Appalachian State University(ASU)Water Treatment Plant(WTP) discharges filter backwash to the
Norris Branch Reservoir, also known as the Appalachian State Reservoir, and is regulated under NPDES
permit NC0044423.The source water for the ASU WTP is also the Norris Branch Reservoir.The Norris
Branch Reservoir is subject to stringent water quality standards due to its classification as a Water
Supply II,Trout, and High-Quality Water.
The current NPDES permit is due for renewal on March 31, 2021. New NPDES permit limits for total
copper and total zinc are scheduled to take effect on January 1, 2021.An effluent limit for turbidity
became effective July 1, 2019 and is set at 10 Nephelometric Turbidity Units(NTU). NC0044423 includes
the following numerical effluent limits for total copper and total zinc which become effective January 1,
2021:
Table 1. Future Effluent Limits
Analyte Monthly Average, µg/I Daily Maximum, WI
Total Copper 4 5.2
Total Zinc 63 63
Historical monitoring indicates at times the effluent concentrations exceed the numerical limits for
copper and zinc for both the monthly average and daily maximum. Per Condition A(3) of NPDES Permit
No. NC0044423,Appalachian State University(ASU)Water Treatment Plant (WTP)was required to
submit a Corrective Action Plan (CAP) annually"summarizing actions to be taken to achieve compliance
with Total Copper,Total Zinc, and Turbidity at Outfall 001."This requirement necessitated further
characterization and evaluation of the discharge,which included a Corrective Action Plan Sampling
Program.
1

Mr.Patrick Brittain,PE
August 24,2020
On March 24, 2020,ASU submitted a Corrective Action Plan to the NCDEQ summarizing results and
providing an evaluation of a sampling program from July 2019—January 2020.The analysis, performed
by Dewberry,found that for both zinc and copper a higher mass was being drawn into the WTP than was
being discharged back to the reservoir.The data for turbidity indicated that the water quality within the
reservoir meets the stream standard even when the turbidity of the WTP effluent exceeds the standard.
The minimal impact of the effluent turbidity on the reservoir turbidity is likely due the particulates
contributing to turbidity in the effluent are from particulates that are being withdrawn from the
reservoir and rejected by the WTP membrane system.To further analyze zinc, copper and turbidity
trends, data collection continued through June 2020.This memorandum presents an evaluation of the
entire dataset from July 2019 through June 2020.
Sampling Program
Monthly effluent monitoring was conducted in accordance with the requirements of this permit.ASU
conducted additional monitoring from July 2019 through June 2020 to characterize the background
concentrations from the intake water and the concentrations in the reservoir upstream and
downstream of the intake and discharge. Sampling locations are shown in Figure 1. All of the data
collected during the sampling program is provided in the attached Table 2 and discussed below.
Copper
The mass of copper withdrawn from the reservoir through the WTP raw water intake and the mass of
copper discharged back to the reservoir in the WTP effluent is presented on Figure 2.At every sampling
event,a higher mass of copper was being withdrawn by the WTP intake than was being discharged back
into the reservoir. For results below the method detect limit, the method detection limit value of 1 µg/I
was used for mass calculations.
Figure 2. Mass of Copper in WTP Raw Water Intake and Effluent
5.0
4.5
4.0
3.5
3 3.0 - �.
�, 2.5
o 2.0
1.5
1.0
0.5
0.0 • • r • • • �{• • • •
..0 � p
'1S''��9 B�"f9 9119 7 00 1,1 1 ° �, , s1.0 O sob rO 61'ems 1,020
—0--Raw Water Intake f WTP Effluent
The difference in the mass of copper in the intake and the mass of copper in the effluent is presumed to
be present in the sludge which is disposed offsite. Sludge is sampled when it is removed from the facility
2

Mr.Patrick Brittain,PE
August 24,2020
for off-site disposal, which occurs very infrequently.Sludge was removed on February 21 and 22, 2020
and was sampled once each day.The average copper concentration in the sludge was 574 µg/I.
Copper sampling was also performed within the reservoir to evaluate the potential impact of the
discharge on instream water quality. Figure 3 presents the concentration of copper in the reservoir
upstream of the intake, in the reservoir downstream of the intake, and in the WTP effluent. Both
samples with results below the method detection limit and samples that were non-detect are plotted as
values equal to the method detection limit.
The upstream and downstream copper concentration trends correlate well, with the downstream
concentration often being a lower concentration that upstream. One exception,on November 6, 2019,
the downstream copper concentration was 614 µg/l.This is suspected to be an anomaly.This data
indicates that the effluent discharge is not having a negative impact on instream copper concentration.
Figure 3.Copper Concentration in the Reservoir and Effluent
200
180 November 6,2019
I ■ 614 µ6/I(anomaly)
160 ,
7, 140 ,
120 --
67, 100 : _. ■
0 80 —
60
40
0 {�
1�10�-0\'�� 9 1,0° 911°jl�,lOS191��>(L �1)(19. 0 31�� O c,r6P- 1'1�1(01P-
—4,—Reservoir Upstream —4—Reservoir Downstream —0—WTP Effluent
Zinc
The mass of zinc withdrawn from the reservoir through the WTP raw water intake and the mass of zinc
discharged back to the reservoir in the WTP effluent is presented on Figure 4.At every sampling event,
with the exception of October 8, 2019, a higher mass of zinc was being withdrawn by the WTP intake
than was being discharged back into the reservoir. For results below the method detect limit,the
method detection limit value of 1 µg/I was used for mass calculations.
3

Mr.Patrick Brittain, PE
August 24,2020
Figure 4. Mass of Zinc in WTP Raw Water Intake and Effluent
3.0
2.5 —
2.0
1.5 -
C
N
1.0
0.5 ) 4
'
A • • • • •
O.O ,.gyp9.
11 6�.0S 81P1,9 91'1,t Y0
.0 4Ce1.0.16A 19011.'bV , 111°10 413y1°10
.411I o 4 y(Oc t°5I161 10 01511p10
-�- Raw Water Intake WTP Effluent
The difference in the mass of zinc in the intake and the mass of zinc in the effluent is presumed to be
present in the sludge which is disposed offsite.The average zinc concentration in the sludge was 556
µg/I.
Sampling was also performed within the reservoir to evaluate the potential impact of the discharge on
instream water quality. Figure 5 presents the concentration of zinc in the reservoir upstream of the
intake, in the reservoir downstream of the intake, and in the WTP effluent. Both samples with results
below the method detection limit and samples that were non-detect are plotted as the method
detection limit.
The upstream and downstream concentrations trend very well together. On November 6, 2019,when
the downstream concentration was much higher than the upstream,the effluent concentration was 48
ug/L, below the future limit.This data indicates that the effluent discharge is not impactful on instream
zinc concentration.
4

Mr.Patrick Brittain,PE
August 24,2020
Figure 5.Zinc Concentration in the Reservoir and Effluent
4000
3500
3000 _.___
? 2500
a 2000
V
_C
H 1500 _ _
1000 '
500
lark"
0
�°1�°9il°0o9a1 1°91�1 aPN
,$)v- �h� �t��y�,'f���4' 11 C 19� �4) 'g 414 (,10�1116�o
Reservoir Upstream -4 -Reservoir Downstream -f-WTP Effluent
Turbidity
Effluent monitoring data collected in accordance with the permit indicates the effluent turbidity at times
exceeds the numerical limit.The NC DEQ Changes to Water Treatment Plant Strategy(October 2009)
states that"turbidity will not be limited except for facilities that discharge to a receiving stream which is
impaired for turbidity". Norris Branch Reservoir is not included in the 303d Impaired Water Bodies List.
The 10 NTU limit is based on the instream water quality standard for Trout Waters and is being applied
directly to the effluent with no allowance for the dilution which occurs in the reservoir.
Turbidity data collected within the reservoir from July 2019 through June 2020 indicates the water
quality within the reservoir is below the 10 NTU stream standard, even when the turbidity in the WTP
effluent exceeds the instream standard.The upstream and downstream turbidity data trend correlate
well, indicating the WTP discharge does not have a meaningful impact on the turbidity even when the
effluent exceeds the 10 NTU numerical limit. Based on this recent data, it appears the ASU WTP
discharge is not increasing the instream turbidity above natural background conditions or the instream
water quality standard. Figure 6 presents a summary of the data collected.
5

Mr.Patrick Brittain,PE
August 24,2020
Figure 6.Turbidity Data
30
25
s 20 i.
.t 15
10
5 --
7/1/2019 8/30/2019 10/29/2019 12/28/2019 2/26/2020 4/26/2020 6/25/2020
f-Reservoir Upstream Reservoir Downstream
—Water Quality Standard-♦—WTP Effluent
Conclusions
Data collected during the Corrective Action Plan Sampling Program from July 2019 through June 2020
indicates that the ASU WTP is net removing metals zinc and copper from the Norris Branch Reservoir as
the mass of metals in the intake is greater than the mass of metals being discharged back to the
reservoir. In addition, copper and zinc are not identified on the SDS compositions for any of the
chemicals used at the facility.As such there is no known source of copper and zinc in the effluent
besides that in the intake.The data also indicates that WTP discharge is not impactful on instream
copper and zinc concentrations. Generally, upstream copper concentrations are higher than
downstream concentrations.The upstream and downstream zinc concentrations trend very well
together. On occasions where the downstream zinc concentrations exceeded those of the upstream,
WTP effluent concentrations were significantly below the proposed permit limits, suggesting other
influences contributed to the elevated concentrations.
The NC DEQ Changes to Water Treatment Plant Strategy(October 2009) states that "turbidity will not be
limited except for facilities that discharge to a receiving stream which is impaired for turbidity". Norris
Branch Reservoir is not included in the 303d Impaired Water Bodies List.Turbidity data collected within
the reservoir from July 2019 through June 2020 indicates the water quality within the reservoir is below
the 10 NTU stream standard, even when the turbidity in the WTP effluent exceeds the instream
standard.
6

NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
MailService Center, Raleigh,1617Ma g , NC 27699-1617
NPDES Permit Number NC0044423
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name Patrick Brittain R C F��.,/ED
c
Facility Name Appalachian State University WTP G '' Th?f
SEP y
Mailing Address 265 Dale Street
NCDEQ1DvvitiNPDES
City Boone
State / Zip Code NC
Telephone Number 828 262-8787 Facilities Office 828 262-3197 Water Plant
Fax Number 828 2624017
e-mail Address brittainps(;appstate.edu [e-mail]
2. Location of facility producing discharge:
Check here if same as above ❑
Street Address or State Road 800 Rainbow Trail
City Boone
State / Zip Code NC
County Watauga
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name Jeremy Johnson
Mailing Address 265 Dale Street
City Boone
State / Zip Code NC
Telephone Number 828 262-3197
Fax Number 828 262-4017
4. Ownership Status:
Federal ❑ State ® Private ❑ Public ❑
Page 1 of 3 Version 5/2012

NPDES PERMIT APPLICATION - SHORT FORM C - WTP
' For discharges associated with water treatment plants
5. Type of treatment plant:
❑ Conventional (Includes coagulation, flocculation, and sedimentation, usually followed by
filtration and disinfection)
❑ Ion Exchange (Sodium Cycle Cationic ion exchange)
❑ Green Sand Filter (No sodium recharge)
® Membrane Technology (RO, nanofiltration)
Check here if the treatment process also uses a water softener ❑
6. Description of source water(s) (i.e. groundwater, surface water)
Surface Water, Norris Branch Reservoir
7. Describe the treatment process(es) for the raw water:
Raw water is pumped from the lake to a basin where it is pre-chlorinated prior to membrane
filtration. A small percentage of the water is backwashed and returned to the source water.
8. Describe the wastewater and the treatment process(es) for wastewater generated by the
facility:
The backwash is treated with sodium thiosulfate to begin oxidation of the chlorine residual and
flows by gravity to a containment facility where is stored until it is suitable for discharge.
Over the last 12 months (July 2019 -June 2020) the plant has averaged a daily raw water
withdrawal of 233,400 gallons with an average daily wastewater discharge of 12,000 gallons.
This 0.012 MGD backwash is discharged 2-3 times monthly.
9. Number of separate discharge points: 1
Outfall Identification number(s) C
10. Frequency of discharge: Continuous ❑ Intermittent IZ
If intermittent:
Days per week discharge occurs:2-3 times monthly Duration: 2 hrs
11. Plant design potable flowrate 2 MGD
Backwash or reject flow .08 MGD
12. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Norris Branch Resevoir
13. Please list all water treatment additives, including cleaning chemicals or disinfection
treatments, that have the potential to be discharged.
Alum / aluminum sulfate Yes No X
Page 2 of 3 Version 5/2012

NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Iron sulfate / ferrous sulfate Yes No X
Fluoride Yes No X
Ammonia nitrogen / Chloramines Yes No X
Zinc-orthophosphate or sweetwater CP1236 Yes No X
List any other additives below:
Chlorine
Sodium Hypochlorite
Sodium Hydroxide
14. Is this facility located on Indian country? (check one)
Yes ❑ No
15. Additional Information:
> Provide a schematic of flow through the facility, include flow volumes at all points in
the water treatment process. The plan should show the point[s] of addition for
chemicals and all discharges routed to an outfall [including stormwater].
• Solids Handling Plan
16. NEW Applicants
Information needed in addition to items 1-15:
• New applicants are highly encouraged to contact a permit coordinator with the
NCDENR Customer Service Center.
Was the Customer Service Center contacted? ❑ Yes ® No
Analyses of source water collected
• Engineering Alternative Analysis
Discharges from Ion Exchange and Reverse Osmosis plants shall be evaluated using a
water quality model.
17. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Patrick Brittain Assistant Director, Facilities Operations
Printed name of Person Signing Title
09/08/2020
Signature of Applicant Date
North Carolina General Statute 143-215.6(b)(2)provides that:Any person who knowingly makes any false statement representation,or certification in any application,
record,report,plan,or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that
Article,or who falsifies,tampers with,or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21
or regulations of the Environmental Management Commission implementing that Article,shall be guilty of a misdemeanor punishable by a fine not to exceed$25,000,or by
imprisonment not to exceed six months,or by both. (18 U.S.C.Section 1001 provides a punishment by a fine of not more than$25,000 or imprisonment not more than 5
years,or both,for a similar offense.)
Page 3 of 3 Version 5/2012

Raw Water Treated Water Waste Water 12 Month 12 Month
Date Backwash
(MG) (MG) (MG) Rolling Total Daily Avg
Jan-19 8.585 8.055 0.53 6.17%
Feb-19 10.387 9.659 0.728 7.01%
Mar-19 8.712 8.205 0.507 5.82%
Apr-19 10.345 9.848 0.497 4.80%
May-19 6.532 6.238 0.294 4.50%
Jun-19 5.046 4.828 0.218 4.32%
Jul-19 6.707 6.417 0.29 4.32%
Aug-19 9.637 9.231 0.406 4.21%
Sep-19 11.968 11.485 0.483 4.04%
Oct-19 9.926 9.506 0.42 4.23%
Nov-19 8.443 8.009 0.434 5.14%
Dec-19 5.549 5.189 0.36 6.49%
Jan-20 7.581 7.068 0.513 6.77% 5.150 0.014
Feb-20 10.006 9.281 0.725 7.25% 5.147 0.014
Mar-20 5.148 4.831 0.317 6.16% 4.957 0.014
Apr-20 2.239 2.104 0.135 6.03% 4.595 0.013
May-20 3.515 3.328 0.187 5.32% 4.488 0.012
Jun-20 4.475 4.261 0.214 4.78% 4.484 0.012

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Sludge Management Plan
Solids/Sludge generated from waste water is pumped from the clarifying facility every two years or as
needed and transferred to the local wastewater treatment facility.

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Facility Information Facility -
Latitude: 36°14'13" Sub-Basin: 05-07-01 Location
Longitude: 81°40'20"
Quad Name: Boone -0§),,
Stream Class: WS-II Trout CA
Receiving Stream: Norris Branch Appalachian State University WTP
North NC0044423
W County
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