NC0021229_SPECULATIVE LIMITS_19990621

MPDES DOCYNEMT SCA►NMIM6 COVER SHEET
NPDES Permit: NCO021229
Old Fort WWTP
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Engineering Alternatives Analysis
201 Facilities Plan
Instream Assessment (6713)
Speculative Limits
Permit
History
Document Date: June 21, 1999
Ttais document its printed oa reuse paper-ignore any
coateat on tlae reverse side

State of North Carolina
-" Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
June 21, 1999
The Honorable Wayne S. Stafford, Mayor
Town of Old Fort
P.O. Box 520
Old Fort, North Carolina 28762-0520
Subject: Speculative Limits for Old Fort WWTP
NPDES Permit No. NCO021229
McDowell County
Dear Mayor Stafford:
This letter responds to.the request of Mr. Michael Waresak of McGill and Associates for
speculative effluent limits for the expansion of the Old Fort WWTP. The design flows of 1.6
and 2.0 MGD were targeted. The staff of the NPDES Unit of the Point Source Branch has
reviewed this request.
Please be advised that response to this request does not guarantee that the Division will
issue an NPDES permit to discharge treated wastewater into these receiving waters. It should be
noted that new and expanding facilities, involving an expenditure of public funds or use of public
(state) lands, will be required to prepare an environmental assessment (EA) when wasteflows: 1)
exceed or equal 0.5 MGD, or 2) exceed one-third of the 7Q10 flow of the receiving stream.
DWQ will not accept a permit application for a project requiring an EA until the document has
been approved by the Department of Environment and Natural Resources and a Finding of No
Significant Impact (FONSI) has been sent to the state Clearinghouse for review and comment.
The EA should contain a clear justification for the proposed facility and an analysis of
potential alternatives, which should include a thorough evaluation of non-discharge alternatives.
Nondischarge alternatives or alternatives to expansion, such as spray irrigation, water
conservation inflow and infiltration reduction or connection to a regional treatment and disposal
system, are considered to be environmentally preferable to a surface water discharge. to
accordance with the North Carolina General Statutes, the practicable waste treatment and
disposal alternative with the least adverse impact on environment is required to be implemented.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone[phone] FAX[phone]
An Equal Opportunity Affirmative Action Employer Internet: http://h2o.enr.state.nc.us/

i
Proposed Old Fort WWTP
Page 2
If the EA demonstrates that the project may result in a significant adverse affect on the quality of
the environment, an Environmental Impact Statement would be required. The Division of Water
Quality's Planning Branch can provide further information regarding the requirements of the
N.C. Environmental Policy Act.
The Town of Old Fort will continue to discharge into Curtis Creek. This segment of the
river has a stream classification of C-Trout. The best usage of waters is for aquatic life
propagation and maintenance of biological integrity, including fishing and fish, wildlife,
secondary recreation, agriculture and any other usage except for primary recreation or as a
source of water supply for drinking, culinary, or food processing purposes. Trout waters should
have conditions that sustain and allow for trout propagation and survival of stocked trout on a
year round basis. The discharge point in Curtis Creek has a drainage area of 17 square miles,
with an estimated average flow of 31 cfs, a summer 7Q10 of 4.9 cfs and a winter 7Q10 of 7.45
cfs.
Based on available information, the tentative effluent limits for oxygen consuming
constituents of the Old Fort WWTP at the expansion flows of 1.6 and 2.0 MGD are included on
the attached effluent sheets. The requirement for quarterly chronic toxicity testing will remain a
condition of the NPDES permit. Individual chronic toxicity limits for 1.6 MGD and 2.0 MGD
will be 33% and 38% respectively. A complete evaluation of limits and monitoring requirements
for metals and other toxicants will be addressed at the time of formal permit application.
The Division of Water Quality is requiring chlorine limits for all new or expanding
dischargers proposing the use of chlorine for disinfection. The process of
chlori n ati on/dechlori nation or an alternate form of disinfection, such as ultraviolet radiation,
should allow the facility to comply this requirement.
Final NPDES effluent limitations will be determined after a formal permit application has
been submitted to the Division. If there are any additional questions concerning this matter,
please feel free to contact Jackie Nowell of my staff at [phone] (ext. 512).
Respectfully,
D� �•r�
David A. Goodric
NPDES Unit Supervisor
DAG/JMN
Attachments
cc: Larry Coble
Bobby Blowe
Michael Waresak: McGill & Associates, Inc.
Central Files
NPDES Permit File

A (1). SPECULATIVE SUMMER EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NCO021229
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number
001. Such discharges shall be limited and monitored by the Permittee asspecified below:
:EFFLUENT CHARACTERISTICS MONITORING REQUIREMENTS
s � u, � i �y- �ri � , C Yrtc;n�lx+�;� ,( M + ,'�"a +� :�• ! `a - . .
Wey. jDally'Maxlmilmll Vi Measurement Sample Sample
ekly,
Q„Kr' ,, """;AveraM e�� r-u-t�-r �',v,e' ,.;'v. li "4Fre uenc`:,{ >wv:,.,''Type,, • +, �Locatibn7 .
vera e1 „ " :>;,. „fir,+ Y o
Flow 1.6 MGD Continuous Recording I or E
BOD5 z 30.0 mg/I 45.0 mg/I 3Meek Composite E
BOD52 3/Week Grab I
Total Suspended Solidsz 30.0 m /I 45.0 m /I 3/Week Composite E
Total Suspended Solids2 3/Week Grab I
NH3-N 2.5 mg/I 3/Week Composite E
Dissolved Oxygen3 3/Week Grab E,U,D
Fecal Coliform 2001100 ml 400/100 ml 3/Week Grab E,U,D
H4 3/Week Grab E
Total Residual Chlorines 28 u /I 3Meek Grab E
Temperature Daily Grab E,U,D
Total Nitrogen Monthly Composite E
Total Phosphorus Monthly Composite E
Conductivity 3/Week Grab E,U,D
Chronic Toxicity6 Quarterly Composite E
Cadmium Weekly Composite E
Cyanide Weekly Composite E
Copper 2/Month Composite E
Zinc 2/Month Composite E
Notes:
t Sample Locations: E- Effluent, I - Influent, U—Upstream of discharge location, D—Downstream at the mouth of Curtis Creek. Upstream and downstream samples shall
be grab samples. Stream samples shall be collected three times per week during June,July, August, and September and once per week during the remaining months of
the year.
2 The monthly average BOD5 and Total Suspended Residue concentrations shall not exceed 15%of the respective influent value (85% removal).
3 The daily average dissolved oxygen effluent concentrations shall not be less than 5 mg/I.
4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
s Monitoring requirement applies only if chlorine is added for disinfection.
6 Chronic Toxicity(Ceriodaphnia) P/F @ 33%; March,June, September, December. See Special Conditions of the Supplement to Effluent Limitations.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A (2). SPECULATIVE WINTER EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NCO021229
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number
001. Such discharges shall be limited and monitored by the Permittee asspecified below:
EFFLUENT CHARACTER IST_ICS LIMITS �1. �'' i MONITORINGAEOUIREMENTS'
axe Mb ad 41 i .ia�l w
uMonthly xh Weeklyl Daisy Maximum ,Measurement , Sample Sample
A'vera e,� 7- >,-Avera e,„zr. • „�_ ',*t� + ?� �+,{ ��f%Fre uenc .n , '.T e� �' Location,
Flow 1.6 MGD Continuous Recording I or E
BOD52 30.0 mg/1 45.0 mg/I 3/Week Composite E
BOD52 3/Week Grab I
Total Suspended SolidS2 30.0 mg/I 45.0 m /I 3/Week Composite E
Total Suspended SolidSz 3/Week Grab I
NH3-N 6.5 mg/I 3/Week Composite E
Dissolved Oxygen 3/Week Grab E,U,D
Fecal Coliform 200/100 ml 400/100 ml 3/Week Grab E,U,D
H3 3/Week Grab E
Total Residual Chlorine4 28 u /I 3/Week Grab E
Temperature Daily Grab E,U,D
Total Nitrogen Monthl Composite E
Total Phosphorus Monthly Composite E
Conductivity 3/Week Grab E,U,D
Chronic Tox1city5 Quarterly Composite E
Cadmium Weekly Composite E
Cyanide Weekly Composite E
Copper 2/Month Composite E
Zinc 2/Month Composite I E
Notes:
t Sample Locations: E - Effluent, I - Influent, U—Upstream of discharge location, D—Downstream at the mouth of Curtis Creek. Upstream and downstream samples shall
be grab samples. Stream samples shall be collected three times per week during June,July,August,and September and once per week during the remaining months of
the year..
2 The monthly average BOD5 and Total Suspended Residue concentrations shall not exceed 15%of the respective influent value (85% removal).
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 Monitoring requirement applies only if chlorine is added for disinfection.
5 Chronic Toxicity (Ceriodaphnia) P/F @ 33%; March,June, September, December. See Special Conditions of the Supplement to Effluent Limitations.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A (3). SPECULATIVE SUMMER EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NC0021229
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number
001. Such discharges shall be limited and monitored by the Permittee asspecified below:
!,EFFLUENT CHARACTERISTICS; r '".r' !z ' t r; ,' c r nm, LIMITS; r a` �' ° "`" r x MONITORING REQUIREMENTS,:
� x t raw u '� + Rt I n M if Mr i r n.r_s a w
r +r,f '% ,T y -rd aJ i91 ✓? 1 n r 4 rr r x'"+n3t!ni4�r+tr!
7
ij Weeklyrr 'DailyMax�Myrn�upm ';Measurement Y ",Sample Sample
„ri,Avera etv . Ave"ra Location?
Flow 2.0 MGD Continuous Recording I or E
BOD5 z 30.0 mg/I 45.0 mg/I 3/Week Composite E
BODaz 3/Week Grab I
Total Suspended Solids2 30.0 m /I 45.0 m /I 3/Week Composite E
Total Suspended Solidsz 3/Week Grab I
NH3-N 2.2 mg/I 3/Week Composite E
Dissolved Oxygen3 3/Week Grab E,U,D
Fecal Coliform 2001100 ml 400/100 ml 3/Week Grab E,U,D
H4 3/Week Grab E
Total Residual Chlorines 28 u /I 3/Week Grab E
Temperature Daily Grab E,U,D
Total Nitrogen Monthly Composite E
Total Phosphorus Monthly Composite E
Conductivity 3/Week Grab E,U,D
Chronic Toxicity6 Quarterly Composite E
Cadmium Weekly Composite E
Cyanide I Weekly Composite E
Copper 2/Month Composite E
Zinc 2/Month Composite E
Notes:
t Sample Locations: E- Effluent, I - Influent, U—Upstream of discharge location, D—Downstream at the mouth of Curtis Creek. Upstream and downstream samples shall
be grab samples. Stream samples shall be collected three times per week during June,July,August, and September and once per week during the remaining months of
the year.
2 The monthly average BOD5 and Total Suspended Residue concentrations shall not exceed 15%of the respective influent value (85% removal).
3 The daily average dissolved oxygen effluent concentrations shall not be less than 5 mg/I.
4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5 Monitoring requirement applies only if chlorine is added for disinfection.
6 Chronic Toxicity (Ceriodaphnia) P/F ® 38%; March,June, September, December. See Special Conditions of the Supplement to Effluent Limitations.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A (4). SPECULATIVE WINTER EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NCO021229
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number
001. Such discharges shall be limited and monitored by the Permittee asspecified below:
EFFLUENT CHARACTERISTICS �; ^ c�' _ ,LIMITS "'
:S r� ,R MONITORINGEQUIREMENTS
sut za rrfi " �i ' wfar ,
r'�., %.'2 . ,.1i",t'•.'.i.,r ` '" e u,. .
+' '". Monthl ' ` �L Weekl ���' Dail Maximum' "Measurement r". ' Sam le -
��'6aj Yew+Ha %.. y, n,,wYiRdjpU " my'ryy� s ,,." P $a(nP1E
''Avers e,,v�1. "'. :Avers a a,K ak,,=.r ? >;, T e. , ,:Locetiont.
Flow 2.0 MGD Continuous Recording I or E
BOD52 30.0 mg/I 45.0 mg/I 3/Week Composite E
BOD52 3/Week Grab I
Total Suspended Solids2 30.0 m /I 45.0 m /I 3/Week Composite E
Total Suspended Solids2 3/Week Grab I
NH3-N 5.6 mg/I 3/Week Composite E
Dissolved Oxygen 3/Week Grab E,U,D
Fecal Coliform 2001100 ml 400/100 ml 3/Week Grab E,U,D
H3 3/Week Grab E
Total Residual Chlorine4 28 u /I 3/Week Grab E
Temperature Daily Grab E,U,D
Total Nitrogen Monthly Composite E
Total Phosphorus Monthly Composite E
Conductivity 3/Week Grab E,U,D
Chronic Toxicity5 Quarterly Composite E
Cadmium Weekly Composite E
Cyanide Weekly Composite E
Copper 2/Month Composite E
Zinc 2/Month Composite E
Notes:
i Sample Locations: E- Effluent, I - Influent, U—Upstream of discharge location, D—Downstream at the mouth of Curtis Creek. Upstream and downstream samples shall
be grab samples. Stream samples shall be collected three times per week during June,July,August, and September and once per week during the remaining months of
the year..
2 The monthly average BOD5 and Total Suspended Residue concentrations shall not exceed 15%of the respective influent value (85% removal).
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 Monitoring requirement applies only if chlorine is added for disinfection.
5 Chronic Toxicity(Ceriodaphnia) P/F @ 38%; March,June, September, December. See Special Conditions of the Supplement to Effluent Limitations.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Old Fort WWTP
Residual Chlorine Ammonia as NH3
(summer)
7010 (CFS) 4.91 7010 (CFS) 4.91
DESIGN FLOW (MGD) 1.6 DESIGN FLOW (MGD) 1.6
DESIGN FLOW (CFS) 2.48 DESIGN FLOW (CFS) 2.48
STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0
UPS BACKGROUND LEVEL ( 0 UPS BACKGROUND LEVEL 0.22
IWC (%) 33.56 IWC (%) 33.56
Allowable Concentration (ug 50.66 Allowable Concentration (rr 2.54
Ammonia as NH3
(winter)
7010 (CFS) 7.45
Fecal Limit 200n00ml DESIGN FLOW (MGD) 1.6
Ratio of 2.0 :1 DESIGN FLOW (CFS) 2.48
STREAM STD (MG/L) 1.8
UPS BACKGROUND LEVEL 0.22
IWC (%) 24.97
Allowable Concentration (n 6.55
5/24/99
JMN NC0021229

Facility: old fort wwtp
NPDES#: NCO021229
Receiving Stream: Curtis Creek
Comment(s):
gage number not available
Low Flow Record Station Number:
Hydrologic Area Number: HA10
Drainage Area Low Flow Record Station:
Qave Low Flow Record Station:
s7Q10 Low Flow Record Station:
w7010 Low Flow Record Station:
3002 Low Flow Record Station:
must be<400 sq.miles
Drainage Area New Site: 17.00 sq. miles
MAR New Site: 1.8
Qave per Report Equation: 31 cfs
s7010 per Report Equation: 4.91 cfs
w7Q10 per Report Equation: 7.45 cfs
30Q2 per Report Equation: 10.53 cfs
Continue
Drainage Area Ratio: #VALUE!
[new DA/Da at gage #VALUE!
Weighted Ratio: #VALUE!
Over-ride Inappropriate Site (y ):
Drainage Area New Site: 17.00 miles squared
MAR New Site: 1.8
Weighted Qave per Report Equation: #VALUE!
Weighted s7Q10 per Report Equation: #VALUE!
Weighted w7Q10 per Report Equation: #VALUE!
Weighted 30Q2 per Report Equation: #VALUE!

SUMMER
EXPANSION TO 1 . 6 MGD, BODS=
30, NH3=2 . 5 , DO=5
- - ------- - MODEL RESULTS ---- - - ----
Discharger OLD FORT WWTP
Receiving Stream CURTIS CREEK
- - --- ----- --- - - - ------ -------- - - - -- - --- - --- ----- - -
The End D.O. is 7 . 92 mg/l .
The End CBOD is 8 . 21 mg/l .
The End NBOD is 1 . 98 mg/l .
--- - -- - --- - ----- - ---- ----- - --- ---- - ------- --- ---- - - - ------- - ----------
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (m(3/1) (mg/1) (mgd)
--- --- ------ -- - - -- - --- - --- -- -- -- - - - --- - ---
Segment 1 6 . 62 0 . 00 1
Reach 1 60 . 00 11 . 25 5 . 00 1 . 60000
Reach 2 0 . 00 0 . 00 0 . 00 0 . 00000
Reach 3 0 . 00 0 . 00 0 . 00 0 . 00000

*** MODEL SUMMARY DATA ***
Discharger OLD FORT WWTP Subbasin 030830
Receiving Stream CURTIS CREEK Stream Class : C-TR
Summer 7Q10 4 . 91 Winter 7Q10 7 . 45
Design Temperature : 25 . 0
LENGTH SLOPE VELOCITY I DEPTH Kd Kd Ka Ka KN
mile ft/mi fps ft design @20° Idesigni @200 design
--- - -- ------ - -- - - -- -- --- --- - -- -- - -- --- - -- ----- ------ --- - -- --------- - -- ----- ----
Segment 1 0 . 20 36 .40 0 . 476 1 . 02 0 . 54 0 . 43 34 . 74 31 . 16 0 . 73
Reach 1
- -- ----------- ---- ------ - --- - - - -- - -- --- --- ----- ------- -- ---- ---- ---- -- - ---- - ----
Segment 1 0 . 90 17 . 40 0 . 505 1 . 56 0 . 38 0 . 30 12 . 75 11 . 43 0 . 44
Reach 2
- ------------- --- -- ---- - - ----- --- - -- - - ---- - --- - - ----- - -- - --------- ---- - ----- ----
Segment 1 1 . 60 17 . 40 0 . 516 1 . 59 0 . 38 0 . 30 13 . 01 11 . 67 0 . 44
Reach 3
- - --- - -------- --- - ---- - -------- -- - - - --- - - --- -- - - - ----- --- ---------- --- - - ---- - ---
Flow CBOD I NBOD D.O .
cfs mg/l mg/l mg/l
Segment 1 Reach 1
Waste 2 . 480 60 . 000 11 . 250 5 . 000
Headwaters 4 . 900 2 . 000 1 . 000 7 . 440
Tributary 0 . 000 2 . 000 1 . 000 7 . 440
* Runoff 0 . 000 2 . 000 1 . 000 7 . 440
Segment 1 Reach 2
Waste 0 . 000 0 . 000 0 . 000 0 . 000
Tributary 10 . 800 2 . 000 1 . 000 7 . 440
* Runoff 0 . 370 2 . 000 1 . 000 7 . 440
Segment 1 Reach 3
Waste 0 . 000 0 . 000 0 . 000 0 . 000
Tributary 0 . 720 2 . 000 1 . 000 7 . 440
* Runoff 0 . 290 2 . 000 1 . 000 7 . 440
* Runoff flow is in cfs/mile

SUMMER
EXPANSION TO 1 . 6 MGD, BOD5=
30 , NH3=2 . 5 , DO=5
Seg # Reach # Seg Mi D .O. CBOD NBOD Flow
1 1 0 . 00 6 . 62 21 , 49 4 . 44 7 . 38
1 1 0 . 01 6 . 67 21 . 48 4 . 44 7 . 38
1 1 0 . 02 6 . 72 21 . 46 4 . 44 7 . 38
1 1 0 . 03 6 . 77 21 . 45 4 . 43 7 . 38
1 1 0 . 04 6 . 82 21 . 43 4 . 43 7 . 38
1 1 0 . 05 6 . 86 21 . 42 4 . 42 7 . 38
1 1 0 . 06 6 . 90 21 , 40 4 . 42 7 . 38
1 1 0 . 07 6 . 95 21 . 39 4 . 42 7 . 38
1 1 0 . 08 6 . 98 21 . 37 4 . 41 7 . 38
1 1 0 . 09 7 . 02 21 . 36 4 . 41 7 . 38
1 1 0 . 10 7 . 06 21 . 34 4 . 40 7 . 38
1 1 0 . 11 7 . 09 21 . 33 4 . 40 7 . 38
1 1 0 . 12 7 . 12 21 . 31 4 . 39 7 . 38
1 1 0 . 13 7 . 15 21 . 30 4 . 39 7 . 38
1 1 0 . 14 7 . 18 21 . 28 4 . 39 7 . 38
1 1 0 . 15 7 . 21 21 . 27 4 . 38 7 . 38
1 1 0 . 16 7 .24 21 . 25 4 . 38 7 . 38
1 1 0 . 17 7 . 27 21 . 24 4 . 37 7 . 38
1 1 0 . 18 7 . 29 21 . 22 4 . 37 7 . 38
1 1 0 . 19 7 . 31 21 . 21 4 . 37 7 . 38
1 1 0 . 20 7 . 34 21 . 19 4 . 36 7 . 38
1 2 0 . 20 7 . 40 9 . 79 2 . 36 18 . 18
1 2 0 . 30 7 . 47 9 . 73 2 . 35 18 . 22
1 2 0 . 40 7 . 53 9 . 67 2 . 33 18 . 25
1 2 0 . 50 7 . 58 9 . 61 2 . 32 18 . 29
1 2 0 . 60 7 . 62 9 . 55 2 . 30 18 . 33
1 2 0 . 70 7 . 66 9 .49 2 . 29 18 . 36
1 2 0 . 80 7 . 70 9 .43 2 . 27 18 . 40
1 2 0 . 90 7 . 72 9 . 37 2 . 26 18 . 44
1 2 1 . 00 7 . 75 9 . 32 2 . 25 18 .48
1 2 1 . 10 7 . 77 9 . 26 2 . 23 18 . 51
1 3 1 . 10 7 . 76 8 . 99 2 . 18 19 . 23
1 3 1 . 20 7 . 78 8 . 94 2 . 17 19 . 26
1 3 1 . 30 7 . 80 8 . 88 2 . 16 19 . 29
1 3 1 . 40 7 . 82 8 . 83 2 . 15 19 . 32
1 3 1 . 50 7 . 83 8 . 78 2 . 13 19 . 35
1 3 1 . 60 7 . 85 8 . 73 2 . 12 19 . 38
1 3 1 . 70 7 . 86 8 . 69 2 . 11 19 .41
1 3 1 . 80 7 . 87 8 . 64 2 . 09 19 .44
1 3 1 . 90 7 . 88 8 . 59 2 . 08 19 . 46
1 3 2 . 00 7 . 89 8 . 54 2 . 07 19 . 49
1 3 2 . 10 7 . 89 8 .49 2 . 06 19 . 52
1 3 2 . 20 7 . 90 8 .44 2 . 04 19 . 55
1 3 2 . 30 7 . 91 8 . 39 2 . 03 19 . 58
1 3 2 . 40 7 . 91 8 . 35 2 . 02 19 . 61
1 3 2 . 50 7 . 92 8 . 30 2 . 01 19 . 64
1 3 2 . 60 7 . 92 8 . 25 2 . 00 19 . 67
1 3 2 . 70 7 . 92 8 . 21 1 . 98 19 . 70
Seg # Reach # Seg Mi D.O. CBOD NBOD I Flow

WINTER
OLD FORT @ 1 . 6 MGD, BOD5=30,
NH3=6 . 5 , NO EFF . DO LIMIT
- - --- --- - - MODEL RESULTS - - -- --- - --
Discharger : OLD FORT WWTP
Receiving Stream : CURTIS CREEK
- -- -- - - --- - - - - --- - ------- - - - - ----- -- ---- --- - - --- ----- ------ - --- ------ -
The End D.O. is 10 . 01 mg/l .
The End CBOD is 7 . 89 mg/l .
The End NBOD is 3 . 94 mg/l .
-- --- ----- -- - - -- -------- - -- - --- -------- - --- - - -- - ---- - - ----- --- - - - -----
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd)
-- - --- ---- - - -- - ----- -- ---- ---- - - - - - ---- ---
Segment 1 6 . 96 0 . 00 1
Reach 1 60 . 00 29 . 47 0 . 00 1 . 60000
Reach 2 0 . 00 0 . 00 0 . 00 0 . 00000
Reach 3 0 . 00 0 . 00 0 . 00 0 . 00000

*** MODEL SUMMARY DATA ***
Discharger OLD FORT WWTP Subbasin 030830
Receiving Stream CURTIS CREEK Stream Class : C-TR
Summer 7Q10 4 . 91 Winter 7Q10 : 7 . 45
Design Temperature : 14 . 0
LENGTHI SLOPEI VELOCITY DEPTH Kd Kd Ka Ka KN
mile ft/mi fps ft design @20° design @20° design
Segment 1 0 . 20 36 . 40 0 . 594 1 . 06 0 . 36 0 . 48 34 . 16 38 . 92 0 . 32
Reach 1
--- - - -- -- --- ---------- -- - -- ----- ---- ----- ------ - --- --- ---- ----- - - - - ----- --- ---- -
Segment 1 0 . 90 17 . 40 0 . 557 1 . 58 0 . 24 0 . 31 11 . 06 12 . 60 0 . 19
Reach 2
----- -- ------ - --------- ------ -- ----- --- - ----------- -------- ------- ------ --- -----
Segment 1 1 . 60 17 . 40 0 . 566 1 . 61 0 . 24 0 . 31 11 . 23 12 . 80 0 . 19
Reach 3
- --- - -- -- ---- ------------- - -- --- - --- - - ----- ----- ---- --- - --- - - ------------ --- - ---
Flow CBOD NBOD D.O.
cfs mg/l mg/l mg/l
Segment 1 Reach 1 ,
Waste 2 . 480 60 . 000 29 . 470 0 . 000
Headwaters 7 . 450 2 . 000 1 . 000 9 . 280
Tributary 0 . 000 2 . 000 1 . 000 9 . 280
* Runoff 0 . 000 2 . 000 1 . 000 9 . 280
Segment 1 Reach 2
Waste 0 . 000 0 . 000 0 . 000 0 . 000
Tributary 10 . 800 2 . 000 1 . 000 9 . 280
* Runoff 0 . 370 2 . 000 1 . 000 9 . 280
Segment 1 Reach 3
Waste 0 . 000 0 . 000 0 . 000 0 . 000
Tributary 0 . 720 2 . 000 1 . 000 9 . 280
* Runoff 0 . 290 2 . 000 1 . 000 9 . 280
* Runoff flow is in cfs/mile

WINTER
OLD FORT @ 1 . 6 MGD, BOD5=301
NH3=6 . 5 , NO EFF. DO LIMIT
Seg # Reach # Seg Mi D .O. CBOD NBOD Flow
1 1 0 . 00 6 . 96 16 . 49 8 . 11 9 . 93
1 1 0 . 01 7 . 07 16 . 48 8 . 11 9 . 93
1 1 0 . 02 7 . 17 16 . 47 8 . 11 9 . 93
1 1 0 . 03 7 . 27 16 . 47 8 . 10 9 . 93
1 1 0 . 04 7 . 37 16 . 46 8 . 10 9 . 93
1 1 0 . 05 7 . 46 16 . 45 8 . 10 9 . 93
1 1 0 . 06 7 . 55 16 . 45 8 . 09 9 . 93
1 1 0 . 07 7 . 64 16 . 44 8 . 09 9 . 93
1 1 0 . 08 7 . 72 16 . 44 8 . 09 9 . 93
1 1 0 . 09 7 . 80 16 . 43 8 . 09 9 . 93
1 1 0 . 10 7 . 88 16 . 42 8 . 08 9 . 93
1 1 0 . 11 7 . 96 16 . 42 8 . 08 9 . 93
1 1 0 . 12 8 . 03 16 . 41 8 . 08 9 . 93
1 1 0 . 13 8 . 10 16 . 41 8 . 08 9 . 93
1 1 0 . 14 8 . 17 16 . 40 8 . 07 9 . 93
1 1 0 . 15 8 . 23 16 . 39 8 . 07 9 . 93
1 1 0 . 16 8 . 29 16 . 39 8 . 07 9 . 93
1 1 0 . 17 8 . 36 16 . 38 8 . 07 9 . 93
1 1 0 . 18 8 .41 16 . 37 8 . 06 9 . 93
1 1 0 . 19 8 .47 16 . 37 8 . 06 9 . 93
1 1 0 . 20 8 . 53 16 . 36 8 . 06 9 . 93
1 2 0 . 20 8 . 92 8 . 88 4 . 38 20 . 73
1 2 0 . 30 9 . 05 8 . 84 4 . 37 20 . 77
1 2 0 . 40 9 . 16 8 . 81 4 . 35 20 . 80
1 2 0 . 50 9 . 26 8 . 77 4 . 34 20 . 84
1 2 0 . 60 9 . 35 8 . 74 4 . 32 20 . 88
1 2 0 . 70 9 . 43 8 . 71 4 . 31 20 . 91
1 2 0 . 80 9 . 50 8 . 67 4 . 29 20 . 95
1 2 0 . 90 9 . 57 8 . 64 4 . 28 20 . 99
1 2 1 . 00 9 . 62 8 . 60 4 . 26 21 . 03
1 2 1 . 10 9 . 67 8 . 57 4 . 25 21 . 06
1 3 1 . 10 9 . 66 8 . 35 4 . 14 21 . 78
1 3 1 . 20 9 . 70 8 . 32 4 . 13 21 . 81
1 3 1 . 30 9 . 74 8 . 29 4 . 12 21 . 84
1 3 1 . 40 9 . 78 8 . 26 4 . 10 21 . 87
1 3 1 . 50 9 . 81 8 . 23 4 . 09 21 . 90
1 3 1 . 60 9 . 84 8 . 20 4 . 08 21 . 93
1 3 1 . 70 9 . 87 8 . 17 4 . 07 21 . 96
1 3 1 . 80 9 . 89 8 . 15 4 . 05 21 . 99
1 3 1 . 90 9 . 91 8 . 12 4 . 04 22 . 01
1 3 2 . 00 9 . 93 8 . 09 4 . 03 22 . 04
1 3 2 . 10 9 . 94 8 . 06 4 . 02 22 . 07
1 3 2 . 20 9 . 96 8 . 03 4 . 00 22 . 10
1 3 2 . 30 9 . 97 8 . 00 3 . 99 22 . 13
1 3 2 . 40 9 . 98 7 . 97 3 . 98 22 . 16
1 3 2 . 50 9 . 99 7 . 95 3 . 97 22 . 19
1 3 2 . 60 10 . 00 7 . 92 3 . 96 22 . 22
1 3 2 . 70 10 . 01 7 . 89 3 . 94 22 . 25
Seg # Reach # Seg Mi D.O. CBOD NBOD Flow

Old Fort WWTP
Residual Chlorine Ammonia as NH3
(summer)
7Q10 (CFS) 4.91 7Q10 (CFS) 4.91
DESIGN FLOW (MGD) 2 DESIGN FLOW (MGD) 2
DESIGN FLOW (CFS) 3.1 DESIGN FLOW (CFS) 3.1
STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0
UPS BACKGROUND LEVEL ( 0 UPS BACKGROUND LEVEL 0.22
IWC (%) 38.70 IWC (%) 38.70
Allowable Concentration (ug 43.93 Allowable Concentration (n 2.24
Ammonia as NH3
(winter)
7Q10 (CFS) 7.45
Fecal Limit 200n00ml DESIGN FLOW (MGD) 2
Ratio of 1.6 :1 DESIGN FLOW (CFS) 3.1
STREAM STD (MG/L) 1.8
UPS BACKGROUND LEVEL 0.22
IWC (%) 29.38
Allowable Concentration (n 5.60
5/24/99
JM N NC0021229

SUMMER
EXPANSION TO 2 . 0 MGD, BODS=
30 , NH3=2 . 2 , DO=5
-- MODEL RESULTS ------ - - - -
Discharger OLD FORT WWTP
Receiving Stream CURTIS CREEK
- --- -- - ----------- - --- - -- ------- - - - - ------ ----- ----- ------- - --- ----- --
The End D.O. is 7 . 89 mg/l .
The End CBOD is 9 . 59 mg/l .
The End NBOD is 2 . 05 mg/l .
--- --- ----- - ---- -- --- - --------- ---- ------ - ---- -------- ----- - ------- - --
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd)
Segment 1 6 . 49 0 . 00 1
Reach 1 60 . 00 9 . 90 5 . 00 2 . 00000
Reach 2 0 . 00 0 . 00 0 . 00 0 . 00000
Reach 3 0 . 00 0 . 00 0 . 00 0 . 00000

*** MODEL SUMMARY DATA ***
Discharger : OLD FORT WWTP Subbasin 030830
Receiving Stream : CURTIS CREEK Stream Class : C-TR
Summer 7Q10 : 4 . 91 Winter 7Q10 7 . 45
Design Temperature : 25 . 0
LENGTHI SLOPEI VELOCITY I DEPTHI Kd Kd Ka Ka KN
mile I ft/mij fps I ft design @200 design @20° design
Segment 1 0 . 20 36 . 40 0 . 505 1 . 03 0 . 56 0 .44 36 . 90 33 . 10 0 . 73
Reach 1
-- - ------------- - -- - ----- - --------------------- - - - ----------- - --------- ----- - ---
Segment 1 0 . 90 17 . 40 0 . 518 1 . 56 0 . 38 0 . 31 13 . 07 11 . 72 0 . 44
Reach 2
- ------- - ---- - - - --- --- - - ---------- ---- ----- ----- -- -- -- --- - ------ - ------ ---------
Segment 1 1 . 60 17 . 40 0 . 528 1 . 59 0 . 38 0 . 31 13 . 32 11 . 95 0 . 44
Reach 3
- ------- ---- - - - - -- -- ----- --------- -- -- ---- ------ - -- - - ---- - --- ---- - ----- - ----- ---
Flow CBOD NBOD D.O.
cfs mg/1 mg/l mg/l
Segment 1 Reach 1
Waste 3 . 100 60 . 000 9 . 900 5 . 000
Headwaters 4 . 900 2 . 000 1 . 000 7 .440
Tributary 0 . 000 2 . 000 1 . 000 7 .440
* Runoff 0 . 000 2 . 000 1 . 000 7 .440
Segment 1 Reach 2
Waste 0 . 000 0 . 000 0 . 000 0 . 000
Tributary 10 . 800 2 . 000 1 . 000 7 .440
* Runoff 0 . 370 2 . 000 1 . 000 7 .440
Segment 1 Reach 3
Waste 0 . 000 0 . 000 0 . 000 0 . 000
Tributary 0 . 720 2 . 000 1 . 000 7 . 440
* Runoff 0 . 290 2 . 000 1 . 000 7 . 440
* Runoff flow is in cfs/mile

SUMMER
EXPANSION TO 2 . 0 MGD, BODS=
30, NH3=2 . 2 , DO=5
Seg # Reach # Seg Mi D .O. CBOD NBOD Flow
1 1 0 . 00 6 . 49 24 . 48 4 . 45 8 . 00
1 1 0 . 01 6 . 55 24 . 46 4 . 44 8 . 00
1 1 0 . 02 6 . 61 24 . 44 4 . 44 8 . 00
1 1 0 . 03 6 . 66 24 . 43 4 . 44 8 . 00
1 1 0 . 04 6 . 71 24 . 41 4 . 43 8 . 00
1 1 0 . 05 6 . 76 24 . 39 4 .43 8 . 00
1 1 0 . 06 6 . 80 24 . 38 4 . 43 8 . 00
1 1 0 . 07 6 . 85 24 . 36 4 . 42 8 . 00
1 1 0 . 08 6 . 89 24 . 34 4 .42 8 . 00
1 1 0 . 09 6 . 93 24 . 33 4 .41 8 . 00
1 1 0 . 10 6 . 97 24 . 31 4 .41 8 . 00
1 1 0 . 11 7 . 00 24 . 29 4 .41 8 . 00
1 1 0 . 12 7 . 04 24 . 28 4 .40 8 . 00
1 1 0 . 13 7 . 07 24 . 26 4 . 40 8 . 00
1 1 0 . 14 7 . 10 24 . 24 4 . 39 8 . 00
1 1 0 . 15 7 . 13 24 . 23 4 . 39 8 . 00
1 1 0 . 16 7 . 16 24 . 21 4 . 39 8 . 00
1 1 0 . 17 7 . 19 24 . 20 4 . 38 8 . 00
1 1 0 . 18 7 . 22 24 . 18 4 . 38 8 . 00
1 1 0 . 19 7 . 24 24 . 16 4 . 37 8 . 00
1 1 0 . 20 7 . 27 24 . 15 4 . 37 8 . 00
1 2 0 . 20 7 . 37 11 . 42 2 . 43 18 . 80
1 2 0 . 30 7 .44 11 . 35 2 . 42 18 . 84
1 2 0 . 40 7 .49 11 . 28 2 . 40 18 . 87
1 2 0 . 50 7 . 54 11 . 22 2 . 39 18 . 91
1 2 0 . 60 7 . 59 11 . 15 2 . 37 18 . 95
1 2 0 . 70 7 . 63 11 . 08 2 . 36 18 . 98
1 2 0 . 80 7 . 66 11 . 01 2 . 34 19 . 02
1 2 0 . 90 7 . 69 10 . 94 2 . 33 19 . 06
1 2 1 . 00 7 . 71 10 . 88 2 . 31 19 . 10
1 2 1 . 10 7 . 73 10 . 81 2 . 30 19 . 13
1 3 1 . 10 7 . 72 10 . 49 2 . 25 19 . 85
1 3 1 . 20 7 . 74 10 . 43 2 . 24 19 . 88
1 3 1 . 30 7 . 76 10 . 37 2 . 23 19 . 91
1 3 1 . 40 7 . 78 10 . 31 2 . 21 19 . 94
1 3 1 . 50 7 . 80 10 . 26 2 . 20 19 . 97
1 3 1 . 60 7 . 81 10 . 20 2 . 19 20 . 00
1 3 1 . 70 7 . 82 10 . 14 2 . 17 20 . 03
1 3 1 . 80 7 . 83 10 . 09 2 . 16 20 . 06
1 3 1 . 90 7 . 84 10 . 03 2 . 15 20 . 08
1 3 2 . 00 7 . 85 9 . 97 2 . 14 20 . 11
1 3 2 . 10 7 . 86 9 . 92 2 .12 20 . 14
1 3 2 . 20 7 . 86 9 . 86 2 . 11 20 . 17
1 3 2 . 30 7 . 87 9 . 81 2 . 10 20 . 20
1 3 2 . 40 7 . 87 9 . 75 2 . 09 20 . 23
1 3 2 . 50 7 . 88 9 . 70 2 . 07 20 . 26
1 3 2 . 60 7 . 88 9 . 64 2 . 06 20 . 29
1 3 2 . 70 7 . 89 9 . 59 2 . 05 20 . 32
Seg # Reach 4 Seg Mi D.O. CBOD NBOD Flow

WINTER
OLD FORT @ 2 MGD, BOD5=30 ,
NH3=5 . 6 , NO DO LIMIT
-- - ---- -- - MODEL RESULTS ---- -- - ---
Discharger OLD FORT WWTP
Receiving Stream CURTIS CREEK
-- ------- -- ------ - -- - - ---- --- -- ----
The End D. O. is 9 . 97 mg/l .
The End CBOD is 9 . 20 mg/l .
The End NBOD is 4 . 05 mg/l .
--- - --- -------- -- --- -- - ----- - --- - - ----- -- -- - - - ----- - ---- ----- - --- - ----
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd)
-- ---- - --- -- --- ------ - - --- - - - - -- -- -- - ---- -
Segment 1 6 . 55 0 . 00 1
Reach 1 60 . 00 25 . 20 0 . 00 2 . 00000
Reach 2 0 . 00 0 . 00 0 . 00 0 . 00000
Reach 3 0 . 00 0 . 00 0 . 00 0 . 00000

*** MODEL SUMMARY DATA ***
Discharger OLD FORT WWTP Subbasin 030830
Receiving Stream CURTIS CREEK Stream Class : C-TR
Summer 7Q10 4 . 91 Winter 7Q10 7 . 45
Design Temperature : 14 . 0
LENGTH SLOPE VELOCITY I DEPTH Kd Kd Ka Ka KN
mile ft/mi fps ft design @20° designj @200 Idesignj
Segment 1 0 . 20 36 .40 0 . 622 1 . 06 0 . 37 0 . 49 25 . 82 29 . 42 0 . 32
Reach 1
- --- ------ --- - - - --------- - ------ --- -- ------ ----- ------ --- ---- - ----- - - --- - -------
Segment 1 0 . 90 17 .40 0 . 570 1 . 59 0 . 24 0 . 31 11 . 31 12 . 88 0 . 19
Reach 2
---- --------- -- - -- - --------------- - ---- ---- ----- - - ---- - -- --- - ----- - - - ---- - ---- --
Segment 1 1 . 60 17 . 40 0 . 578 1 . 62 0 . 24 0 . 31 11 . 47 13 . 07 0 . 19
Reach 3
--------- --- - - -- -- - ------ ---- -- - ----- - ---- ----- -- -------- --- ------- ------ - ---- --
Flow CBOD NBOD D.O.
cfs mg/1 mg/1 mg/1
Segment 1 Reach 1
Waste 3 . 100 60 . 000 25 . 200 0 . 000
Headwaters 7 . 450 2 . 000 1 . 000 9 . 280
Tributary 0 . 000 2 . 000 1 . 000 9 . 280
* Runoff 0 . 000 2 . 000 1 . 000 9 . 280
Segment 1 Reach 2
Waste o . 000 o . 000 o . 00b 0 . 000
Tributary 10 . 800 2 . 000 1 . 000 9 . 280
* Runoff 0 . 370 2 . 000 1 . 000 9 . 280
Segment 1 Reach 3
Waste 0 . 000 0 . 000 0 . 000 0 . 000
Tributary 0 . 720 2 . 000 1 . 000 9 . 280
* Runoff 0 . 290 2 . 000 1 . 000 9 . 280
* Runoff flow is in cfs/mile

WINTER
OLD FORT @ 2 MGD, BODS=30 ,
NH3=5 . 6 , NO DO LIMIT
Seg # Reach # Seg Mi D.O. CBOD NBOD Flow
1 1 0 . 00 6 . 55 19 . 04 8 . 11 10 . 55
1 1 0 . 01 6 . 64 19 . 04 8 . 11 10 . 55
1 1 0 . 02 6 . 72 19 . 03 8 . 11 10 . 55
1 1 0 . 03 6 . 80 19 . 02 8 . 10 10 . 55
1 1 0 . 04 6 . 88 19 . 01 8 . 10 10 . 55
1 1 0 . 05 6 . 96 19 . 01 8 . 10 10 . 55
1 1 0 . 06 7 . 03 19 . 00 8 . 10 10 . 55
1 1 0 . 07 7 . 10 18 . 99 8 . 09 10 . 55
1 1 0 . 08 7 . 17 18 . 99 8 . 09 10 . 55
1 1 0 . 09 7 . 24 18 . 98 8 . 09 10 . 55
1 1 0 . 10 7 . 31 18 . 97 8 . 09 10 . 55
1 1 0 . 11 7 . 38 18 . 97 8 . 08 10 . 55
1 1 0 . 12 7 .44 18 . 96 8 . 08 10 . 55
1 1 0 . 13 7 . 50 18 . 95 8 . 08 10 . 55
1 1 0 . 14 7 . 57 18 . 95 8 . 08 10 . 55
1 1 0 . 15 7 . 62 18 . 94 8 . 07 10 . 55
1 1 0 . 16 7 . 68 18 . 93 8 . 07 10 . 55
1 1 0 . 17 7 . 74 18 . 92 8 . 07 10 . 55
1 1 0 . 18 7 . 79 18 . 92 8 . 07 10 . 55
1 1 0 . 19 7 . 85 18 . 91 8 . 06 10 . 55
1 1 0 . 20 7 . 90 18 . 90 8 . 06 10 . 55
1 2 0 . 20 8 . 60 10 . 35 4 . 49 21 . 35
1 2 0 . 30 8 . 76 10 . 31 4 . 47 21 . 39
1 2 0 .40 8 . 91 10 . 27 4 . 46 21 . 42
1 2 0 . 50 9 . 03 10 . 23 4 . 44 21 . 46
1 2 0 . 60 9 . 15 10 . 19 4 . 43 21 . 50
1 2 0 . 70 9 . 25 10 . 15 4 . 41 21 . 53
1 2 0 . 80 9 . 34 10 . 11 4 . 40 21 . 57
1 2 0 . 90 9 . 41 10 . 07 4 . 38 21 . 61
1 2 1 . 00 9 . 48 10 . 03 4 . 37 21 . 65
1 2 1 . 10 9 . 55 9 . 99 4 . 36 21 . 68
1 3 1 . 10 9 . 54 9 . 74 4 . 25 22 . 40
1 3 1 . 20 9 . 59 9 . 70 4 . 23 22 . 43
1 3 1 . 30 9 . 64 9 . 67 4 . 22 22 . 46
1 3 1 . 40 9 . 69 9 . 63 4 . 21 22 . 49
1 3 1 . 50 9 . 73 9 . 60 4 . 20 22 . 52
1 3 1 . 60 9 . 76 9 . 56 4 . 18 22 . 55
1 3 1 . 70 9 . 80 9 . 53 4 . 17 22 . 58
1 3 1 . 80 9 . 82 9 . 50 4 . 16 22 . 61
1 3 1 . 90 9 . 85 9 . 46 4 . 15 22 . 63
1 3 2 . 00 9 . 87 9 . 43 4 . 14 22 . 66
1 3 2 . 10 9 . 89 9 . 40 4 . 12 22 . 69
1 3 2 . 20 9 . 91 9 . 36 4 . 11 22 . 72
1 3 2 . 30 9 . 92 9 . 33 4 . 10 22 . 75
1 3 2 . 40 9 . 94 9 . 30 4 . 09 22 . 78
1 3 2 . 50 9 . 95 9 . 27 4 . 07 22 . 81
1 3 2 . 60 9 . 96 9 . 23 4 . 06 22 . 84
1 3 2 . 70 9 . 97 9 . 20 4 . 05 22 . 87
Seg # Reach # Seg Mi D.O. CBOD NBOD Flow

1
1
a
PRELIMINARY ENGINEERING REPORT
AND ENVIRONMENTAL ASSESSMENT
WASTEWATER COLLECTION AND
TREATMENT SYSTEM IMPROVEMENTS
TOWN OF OLD FORT, NORTH CAROLINA
MICHAEL J. WARESAK, P.E.
ASSOCIATES
Engineering • Planning • Finance
' Post Office Box 2259
Asheville, North Carolina 28802
' JANUARY, 1999
96338.00

1
1
a TABLE OF CONTENTS
SECTION DESCRIPTION PAGE NO.
Section I Introduction 1
' Section II Existing Conditions 3
Section III Estimated Wastewater Flows 7
Section IV Sewer System Alternatives 8
' Section V Recommendations and Conclusions 14
Environmental Assessment
Appendix
Speculative Permit Limits
Letters from Local Industries
' Civil Penalty Letter
1
1

1
1
SECTION ' • D •
aThe Town of Old Fort is located in western McDowell County in the western
section of North Carolina at the foot of the Blue Ridge Mountains as shown on Figure 1-1.
The Town is approximately ten (10) miles southeast of the City of Marion, the county
' seat, in the Catawba River Basin. McDowell County's southern boundary is with
Rutherford County, on the western boundary is Buncombe County, on the eastern
boundary is Burke County, and the northern boundary is adjacent to Yancey, Mitchell,
and Avery Counties. The Town of Old Fort has approximately 1,050 residents.
The Town of Old Fort authorized McGill Associates, P.A. to prepare this
Preliminary Engineering Report (PER) which evaluates alternatives for providing
' additional sewer service to,an-expanding-textile-facility-Excel-Finishing;Inc., located on
the northwestern side of Interstate 40 within the Town limits. ,Excel-Einishing-employs
approximately_eighty_(80)_people=from=the Town_of=Old=Fort and-surrounding-areas.
Excel Finishing has expressed a need to expand their textile dyeing operation, which will
result in approximately 60 new jobs and additional wastewater flows. �E--xcel-Finishing-has
requested-that-the Town-of-Old-Fort-allow-forthe-expansion-by_providing=approximately
c275,000-GPD of additional wastewater treatment capacity. Written requests from Excel
are provided in the Appendix.
The Town of Old Fort recently completed a 0.4 million gallon per day (MGD)
expansion of their wastewater treatment plant which provided the Town with a current
reserve capacity of 0.4 MGD. In order to accommodate the textile facility expansion as
well as other future expans ion, it-is.recommended-that-the Town-of-Old-Fort-expand-the if
existing-wastew.ater_treatment--plant-from-1:2-million-gallons-per-day-to-1-6-MGD,r In
addition, the existing 12-inch gravity sewer line that transports the majority of the Town's
ePage 1 of 15

Ili
wastewater to the treatment facility does not have the hydraulic capacity to handle
' existing peak flows which has resulted in several recent sewer overflow violations.
eThe purpose of this Preliminary Engineering Report is to describe and evaluate the
Town of Old Fort's alternatives in providing wastewater treatment to the existing textile
facility and address the problem with the existing sanitary sewer collection system. The
report.will=evaluate-Old=Fortis-existing-wastewater=system's_ability-to-accept-additional
' wastewater-flows-from-the-textile-facility-Every alternative will be discussed from both a
technical and economic viewpoint. Specific recommendations will be made to allow The
' Town of Old Fort to accommodate the desired expansion of a valuable industrial
customer.
FIGURE 1-1
LOCATION MAP
THE TOWN OF OLD FORT
11e3
B• L
r ,, twill all'
J / 111 FFFhhY IaM � - .+ BO
BlR tsmile r •,Pii. '"`l ' I.Hs'�111e
e
- .n. 23 18 f 221 L
.tM 197
•C.lo �`
IC.I. lz.rbna
M III Bq
hall m
s
12
s
t
to/" airnBn.m f n
23 r' Gp -
.ee o
e.aneery ..mill. Jo
on
J
eAer WykMawn` �'
• Jr1cHr.a1 —
hav Ile.---J0
ck
21
The Town oFOld Fort
10
hd'er 5 L _ W
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opl Rrus/ Mon I C
�y Roo
nMMer to In{r.
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�• SFina. Bostic p
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Page 2 of 15

e
e
eSECTION 11 EXISTING CONDITIONS
SANITARY SEWER SYSTEM
eThe existing sewer system provides service to residential, commercial, and
eindustrial users, with industry supporting most of the Town's economy. The major users
are Excel Finishing, Ethan Allen, Collins and Aikman, Parker Hosiery, and Janesville
eProducts.
Sewer Collection System
The existing sewer collection system consists of a network of approximately,
26,000 linear feet of 6, 8, 10, and 12-inch diameter vitrified clay, PVC, and ductile iron
egravity sewer lines serving the Town and the immediate surrounding area to the west,
e including several industries. There are currently no pump stations in use within the
collection system. The system collects the wastewater and transports it by gravity to
e the Town's wastewater treatment plant located on the west bank of Curtis Creek, just
east of Town, as shown in Figure II-2. There are adjacent areas not yet developed.
e However, the system is such that the existing collector lines can be extended into these
outlying areas as the need arises.
The majority of the Town's wastewater ultimately flows through approximately
a7,600 lineal feet of 12-inch diameter trunk line prior to reaching the Town's wastewater
treatment facility also shown in Figure II-2. This line is constructed of vitrified clay, a
ematerial that is no longer recommended in construction of new sanitary sewer lines.
Recent line cleaning and smoke testing by the Town has revealed that the line has
major root problems and severe groundwater infiltration. North Carolina regulations
require sewer lines be designed flowing half full, at the average daily wastewater flow.
e
ePage 3 of 15

' Thus, the capacity of the existing 12-inch gravity sewer line flowing half full is
' approximately 550,000 GPD and, according to the Town the line currently receives
peak flows over 1 .0 MGD. ,During_peri"o"ds of-peak-flow-the-sewer-line-cannot-accept
Othis-amount-of:,wastewater-flow,—thus-the-line-has-experienced-several-recent-sewer
overflows out of=manholes? Due to these sewer overflows, the Town received several
state violations and has been placed under a moratorium, which prevents the Town
from accepting any additional residential, commercial, or industrial customers. Also, the
groundwater infiltration increases the quantity of wastewater, as well as overall
treatment cost.
Wastewater Treatment
All sewage carried by the collection system enters the wastewater treatment
plant by gravity. The original plant was completely reconstructed in 1987 to a capacity.
' of 800,000 gallons per day (GPD) and upgraded again in 1996 to a total capacity of 12
million gallons per day (MGD). Currently the plant receives an average daily flow
during the week of approximately 800,000 GPD. The facility's biological treatment
consists of an extended aeration process using floating aerators and also includes a
' bar screen, influent pump station, grit removal, and solids removal by three (3) clarifiers.
Treated effluent is chlorinated, dechlorinated, and discharged into Curtis Creek. Solids
are pumped from the clarifiers to one of two (2) sludge holding tanks before being
pasteurized and stabilized with quicklime to produce a Class A biosolids product. The
pprocessed residual solids are then distributed to local farmers under the Town's
residuals distribution permit issued by North Carolina Department of Environment and
eNatural Resources (NCDENR).
1
aPage 4 of 15

1
The existing NPDES permit for the Town of Old Fort Wastewater Treatment Plant
has the following monthly discharge limitations:
Q TABLE II-1
EXISTING NPDES DISCHARGE LIMITS
THE TOWN OF OLD FORT WASTEWATER TREATMENT FACILITY
Description Quanta � �" T,
� Sample+ yT
.: {Ly{e
`-r.•'., w.• ;..s:..-. r ..:.. v-•.- .•• ..4.±x +.k. :.3,:< yc..s.;..v".'u 2.F. w4.,.iaiv"�+>.a�u^.T'S:-'FS..uVr� -- cfrceu.
' Flow 1.2 MGD Monthly Average
BOD5 30 mg/I Monthly Average
TSS 30 mg/I Monthly Average
NH3 3.0 mg/I Monthly Average
1 Fecal Coliform 200 mg/I Monthly Average
1
a
1
aPage 5 of 15

FIGURE 11-2 �j
THE 0WN`OF OLD FORT
The Town of Old Fort
_. 70 ,
l� > .?' r :gyp .,,` • � �:�}l
a p�'
70 ,
EXISTING 12;GRAVITY,
�Exc el Finishing In SANITARY SEWER LINE
E
'.Attu USA�1 1iw '
Page 6 of 15

1 SECTIONESTIMATED
WASTEWATER FLOWS
WASTEWATER FLOWS
a
The Town of Old Fort's wastewater treatment facility has a permit to
discharge 1.2 MGD to Curtis Creek. Currently, the was tewater_treatment facility
discharges-approximately-0:8-MGD-with;daily_peak_flows--as=highas 1-3-MGD. The
' Town has recently met with the major industrial users and requested that they provide
flow equalization and stagger their peak discharges to lessen the wastewater surges
to the trunk line.
.Excel=F-inishing currently discharges approximately 375,000-gallon. s_per_day'
and requested=that_the Town=provide=2=75;000=GP_D=of=additional_wastewatec-.--=
treatment capacity_to-allow-for-expansion:of:the:textile:facility. This expansion would
increase the average daily flow to 1.1 MGD, which is over 90% of their existing
treatment capacity. State regulations require all wastewater treatment facilities to
present a "Plan of Action" when the average daily flow reaches 80% of the permitted
treatment capacity. When any treatment facility reaches 90% of the permitted
treatment capacity, regulations require the treatment facility be placed under
moratorium until drawings and specifications are submitted for construction of an
expansion.
An expansion of the existing wastewater treatment facility is recommended in
aorder to process the existing peak flows as well as the proposed additional
wastewater flows. An_expansion=to 1-6=MGD=would=allow=the Town_to-treat=peak
' wastewater-flows-and-the-additional-_flow currently_propos__ed:by-Excel-.Finishing-Inc
as_well.as-provide-reserve_capacity-at the.plantrforfuture:indu`stfial user expansion
o�r-._new=industries=0
Page 7 of 15

e
e
e ; SECTION
ALTERNATIVES
This section of the report presents alternatives to provide additional sanitary
esewer service to the expanding Excel Finishing textile plant and address the problem
with the existing sanitary sewer collection system.
1
eSewer Collection System
e As stated in Section Il, .the=existing 1.2=inch=gravity=sewer=line- which
transports the majority of wastewater to the treatment facility does=not_have=they
e hydra au_ Iic-capacityto.handle-peak_flows 9During the peak flow conditions, the sewer
line has overflowed which resulted in violations from the North Carolina Department
of Environment and Natural Resources (NCDENR). Current average daily flows are
higher than the design capacity of the sewer line when flowing half full. Also, they
poor;condition_of-the=sewer-line-allows-infiltration-of-groundwater_into_the_collection
,sy` stem_which-increases-the-amount_of_wastewaterthat_must=be-processed_at=theme
e ,_treatment"facilityv
eAlternative 1
e One alternative is to continue to use the existing sewer line without any
improvements, limit the flow from existing industries and not allow future expansion.
e This alternative would not require capital expenditures, however, the Town's
revenue and overall economy would suffer because this would seriously restrict job
e creation and economic growth. Furthermore, the poor condition of the trunk line
would continue to deteriorate, causing additional maintenance problems and
eincrease the risk of sanitary sewer overflows. This alternative is not feasible or
compliant with the Town of Old Fort's long term goals.
1
Page 8 of 15

' Alternative 2
' Another alternative is to construct a new 18" gravity sewer line parallel to the
existing sewer line to carry the majority of wastewater flow and rehabilitate the
' existing sewer line to increase its useful life and carry the peak flows. Both sewer
lines, the new and the existing, would transport wastewater to the wastewater
Q treatment plant. However, because this alternative would continue to use the
existing sewer line, the Town would likely have increased maintenance costs due to
' the additional length of sewer line required to maintain. A cost estimate for this
alternative is provided in the following Table IV-1:
eTABLE IV-1
SEWER COLLECTION SYSTEM IMPROVEMENTS
ALTERNATIVE 2 - PROJECT COST ESTIMATE
4Descn hon Y Quaiit►ty Umt V--.1M e1 Cos�t:i
' P
Mobilization 1 LS $16,000 $30,000
18" sanitary sewer 7,650 LF $60 $459,000
12" sanitary sewer slip lining 7,650 LF $55 $420,750
Manhole rehabilitation 25 EA $700 $17,500
25 Manholes 25 EA $1,800 $45,000
Railroad Bore and Jack 300 LF S150 $45,000
' Road Bore and Jack 50 LF S150 $7,500
Connection to 12" Overflow 1 LS $2,000 $2,000
' �~ SSiibtotalinfItit, $1,026,750
R
10%Construction Contingency $102,675
sstTotal Construchon'.Costzlt r, $1,129,425
Engineering $80,600
Q Construction Administration $37,200
LegaVAdministration $15,000
i �1;2627225.;
1 Page 9 of 15

Alternative 3
The final alternative consists of constructing-a-new_24-Lgravity-sewer-line
parallel-to-t_ h� a_xisting-sewer_lineMith-enough-hydraulic ccapacity_to-handle-existing—o
' peak-flow-as-well_as_additional-capa city-for-future-industrial 'residential-an¢
comm�ercial_expansion-� Upon completing constructing of the new gravity sewer line,
Q the existing sewer line would then be abandoned. This new sewer main would be
sized to meet the following design criteria, and would be constructed to prevent the
' infiltration of groundwater.
1 . Design gravity sewer system to carry the average daily flow with pipeline
flowing half (1/2) full.
2. Pipe lines shall be sized utilizing Manning's equation with n=.013.
3. Minimum velocity in sewer lines shall be 2.0 feet per second to prevent
settling of suspended solids.
Preliminary construction costs for these improvements are provided on the
following table IV-2:
1
' Page 10 of 15

TABLE IV-2
' SEWER COLLECTION SYSTEM IMPROVEMENTS
PROJECT COST ESTIMATE - ALTERNATIVE 3
Descriptions <° ;. Quantity Umt, 'Unit{Pnce 4Cost
Mobilization 1 1 LS $20,600 $20 600
a 24" sanitary sewer 7.400 LF $75 $555,000
25 Manholes 25 EA $2,000 $50,000
Railroadan Roadore an Jack > > 1 ,> >
' Sanitary Service Taps c EA 500
Abandon xistmg an o es 19A
e Asphalt Kepairs 1 $10,000
Relocate 6-inch Water Line 1 LS $5,000 $51000
r' Subtotal _ p 3 y $705,975
10% Construction Contingency $70,598
` Total Coastcvctton Cost moqd, t} $776,573
r x
Engineering $56;600
Construction Administration $28,300
0 Legal/Administration $15,000
' Alternative 3 is the most cost-effective alternative for the Town of Old Fort
and is, therefore, the recommended alternative. As discussed previously, the new
24-inch gravity sewer main would meet all the design criteria as specified by
NCDENR. A 24-inch gravity sewer line constructed at minimum grade has a
capacity to handle peak flows over 4.4 MGD, with scouring velocities near two feet
per second at average daily flow. The proposed 24-inch sewer main would provide
the Town of Old Fort the ability to accept additional flow and expand their sewer
collection system to new areas as future growth warrants.
Page 11 of 15

Wastewater Treatment Facility
' Excel Finishing requested that the Town of Old Fort allow for the expansion of
their textile dyeing operation by providing approximately 275,000 GPD of additional
' wastewater treatment capacity. Excel Finishing has stated this expansion would
result in approximately 60 new jobs at their Old Fort Facility.
' One alternative is to restrict Excel Finishing to their existing wastewater
discharge limit. Due to the negative long-term affect to the Town's economy, this
Qalternative has been rejected.
Another alternative is to require Excel Finishing to construct a private
wastewater treatment facility to process all wastewater generated from the textile
' plant. This solution would not only dramatically reduce the Town's revenue, but i1
would also be far more expensive to construct, maintain, and operate the new
wastewater treatment facility than to upgrade the Town's existing facility. This
alternative would also add one more wastewater discharge point into Curtis Creek,
ewhich could have a negative impact on the environment. It is unlikely that the State of
North Carolina would allow a second discharge in close proximity to the Town's
existing discharge.
' The final alternative that would allow for expansion of Excel Finishing Inc., is
to upgrade the Town of Old Fort's existing wastewater treatment facility from 1.2
MGD to 1.6 MGD. This upgrade would provide enough wastewater treatment
' capacity for the immediate expansion of Excel Finishing as well as reserve capacity
for future industrial, commercial, and residential growth. The wastewater treatment
' facility improvements would generally consist of an additional aeration basin, new
clarifier, new sludge holding, as well as expansion of the chlorine contact basin and
' residual solids storage area. The following Table IV-2 provides a preliminary cost
estimate for this alternative:
Page 12 of 15

1 TABLE IV-2
PROJECT COST
1 ALTERNATIVE 2
� � `�•. ,.Utllt z1..IR1t.PP1CC^ : � COSt� .�•.-'
Mobilization 1 LS $36,000 $36,000
New Headworks Facility 1 EA $500,000 $500,000
1 New 24" Influent Line 75 LF $80 $6,000
Aerated Grit Removal 1 LS $150,000 $150,000
Influent Pump Station Piping Modifications 1 LS $25,000 $25,000
Flow Equalization Basin Improvements 1 LS 1 $35,000 $35,000
Aeration Basin Expansion 1 LS $320,000 $320,000
O 60' Dia Steel Clarifier 1 LS $170,000 $170,000
One New Return Sludge Pump 1 LS $20,000 $20,000
Upgrade Chemical Feed Equipment 1 LS $2,000 $2,000
t Chlorine Contact Basin Expansion 1 LS $24,000 $24,000
10-inch Piping to Aeration Basin Addition 120 LF $30 $3,600
Relocate 2-Inch Water Line 200 LF $6 $1,200
' 12-Inch Aeration Basin Effluent 100 LF $36 $3,600
Clarifier Splitter Box Expansion 1 LS $8,000 $8,000 _.
12-In. Line (Flow Splitter Box to New 135 LF $36 $4,860
Clarifier)
8-Inch Clarifier Effluent Line 250 LF $24 $6,000
e 8-Inch Return Sludge/Scum Piping 300 LF $24 $7,200
75,000 Gallon Sludge Holding 1 LS $100,000 $100,000
' Connection to New Sludge Holding 1 LS $7,500 $7,500
Connection to Return Sludge Wetwell 1 LS $500 $500
Miscellaneous Piping 1 LS $10,000 $10,000
' Additional Final Product Storage (Covered) 1600 SF $40 $64,000
Spreader Truck for Biosoloids Disposal 1 EA $50,000 $50,000
' Land Acquisition 1 LS $10,000 $10,000
Paving 200 SY $30 $6,000
Sitework 1 LS $5,000 $5,000
Electrical 1 LS $160 000 $160,000
w
$1,735,460
10% Construction Contingency _ $173,546
s U ! -4 '` $1 909 006
.TOtal-CRSt[RChOR COStas:�'�.. f >
Engineering $128,800
Construction Administration $49,300
Legal/Administration $5,000
t $2 092 106
t TOTAL PROJECT COSTt� w �_ >
I�'a sSe
' Page 13 of 15

` \� WASTEWATER TREATMENT
V--
_ ______ PLANT EXPANSION
PROPOSED -
��
TOWN OF 01D FORT
CHAIN LINK �;t•; �
FENCE
1 \��� ��� � MGDOWELL COUNTY, NORTH CAR01.1r1A
1 It
- t - �..
--- _ ` PLAN
---_ _ ------ ,�-- <�
- PROPOSED 3 ' r ' ' ----- - :* ♦ >:, \ �� s \ —
��� AERATION BASIN 1 cRf � SCALE: 1' 4p'
117,x48.5
If q
PROPOSED
CLmln IFlER No.3 'a '' \ CHLORINE CONTACT
Box „�/ <o/ a,, \�.
AERAOcIN BASIN / BASIN EXPANSION
AERATION'.
HA9N
_ \ 71_�^^S \ I , 11 / 117•a57'
\ IJk�j\v_VA/ 4 1 , 0.8 MCO
TArDGE HOLDIN( ' ' �/ O CLARIFER No.2` �♦( - x Y - E&s /
4 ir, i, ;� N / •• 1,cc gy
`\� \\ o 1 11 I , Y �g-'' R " meA 1 /• ' S C
41
,iI I , / mRalip-
_ r / ;,ti `�' /. a PROPOSED
IVo ;O �� I / ; RETURPY SLUDGE
R g� PC CLARIFIER No.l PUMP STATION
IMPROVEMENTS
I ,••. ,wN °
SLUDGE c �LT4fq k5 '
HOLDING ..�,_,��_.-1
Y BASIN NO.2 y = / ' !: PROPOSED
`� INFLUENT PUMP STATION
,` /-�
// HOLDING �! / 37 �, W IMPROVEMENTS
' l \ ••` i v;,.. BASIN N0.1
RESIDUALS e \' , /\�y � / .' i /'� 11 °' � /�' � i /' ' -
r MANAGEMENT /f ' PROPOSED -
mow. m y REF'CACE EXISTING BAR
FACILITY ��� i«Ey � �. \ ,i ` w U �o 11,14
I \\
/ ✓ a / �; ` y �� a� SCREEN BUILDING
11 .�'
____ • / / If
-
\
It
\ ASPHALT SURFACE
/i
. PROPOSED
cGill FLOW EQUALIZATION
BASIN PUMP STATIONM
PROPOSED IMPROVEMENTS /
A S S 0 C I A T E S RESIDUALS STORAGE TIER EKE IN UP
ENGINEERING•PIANNING•FINANCE SLAB - '3M.50"

' SECTION V RECOMMENDATIONS
AND CONCLUSIONS
This Preliminary Engineering Report has evaluated the Town of Old Fort's
alternatives in providing the textile facility, Excel Finishing Inc., additional wastewater
treatment as well as alternatives to resolve the current problems with the gravity sewer
trunk line.
To avoid future sewer overflows, the current problem with the sanitary sewer
trunk line should be resolved as quickly as possible. As described in the previous
section, we recommend the construction of a new 24-inch gravity sewer line and the.
abandonment of the existing 12-inch trunk line. This is the most cost-effective
alternative to increase the capacity of sewer collection system and reduce
' groundwater infiltration. As detailed in Table IV-2, the estimated cost for the
recommended alternative is $876,473.
' In order to allow Excel to proceed with their expansion, we recommend the
Town of Old Fort upgrade the wastewater treatment facility from 1.2 MGD to 1.6 MGD
at an estimated cost of $2,092,106. Without this increase in capacity, the requested
flow from Excel would increase the average daily flow to over 90% of the treatment
plant's current design flow. At this point the Town would be placed under a
moratorium until the design of an upgrade of the treatment plant capacity was
complete. This problem would be avoided by expanding the Town of Old Fort's
wastewater treatment facility.
' The total estimated cost for the recommended improvements is $2,968,579.
Page 15 of 15
0

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1 ENVIRONMENTAL ASSESSMENT
WASTEWATER COLLECTION AND
TREATMENT SYSTEM IMPROVEMENTS
TOWN OF OLD FORT
1 McDOWELL COUNTY, NORTH CAROLINA
i
e
1
1 MICHAEL J. WARESAK, P.E.
qMcGM
A S S O C I A T E S
Engineering • Planning • Finance ° .•;` '
Post Office Box 2259
iAsheville, North Carolina 28802
JANUARY, 1999
1 96338.00
i
1

1
1
i
1 TABLE OF CONTENTS
SECTION I EXISTING ENVIRONMENT............................................................................3
SECTIONII NEED FOR PROJECT .......................................................................................4
SECTION III ALTERNATIVE ANALYSIS ............................................................................5
SECTION IV ENVIRONMENTAL CONSEQUENCES........................................................12
SECTION V MITIGATIVE MEASURES.............................................................................17
SECTION VI MAP OF PROJECT AREA..............................................................................19
1
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1 - 2 -
1

�1
ENVIRONMENTSECTION I EXISTING
1
The Town of Old Fort is located in McDowell County in western of North Carolina at the foot of
the Blue Ridge Mountains. The Town is located in the Catawba River Basin. McDowell County
borders Rutherford County to the south, Buncombe County to the west, Burke County to the
east, and Yancey, Mitchell, and Avery Counties to the north. The Town of Old Fort has
approximately 1,050 residents. Interstate 40, a primary east-west travel corridor, forms a portion
of the southern Town boundary.
The Town of Old Fort currently operates a 1.2 million gallon per day (MGD) wastewater
treatment plant (WWTP) with the discharge of treated wastewater to Curtis Creek under NPDES
Permit Number NC0021229. Curtis Creek is classified C-Trout and is located in the Catawba
River Basin. The WWTP was completely reconstructed in 1987 to a capacity of 0.8 MGD. The
facility was upgraded to a capacity of 1.2 MGD in 1996. The WWTP utilizes the extended
Q aeration biological treatment process. The existing facilities include an influent bar screen,
influent pump station, grit removal, flow equalization, aeration, clarification, effluent
1 chlorination and dechlorination, sludge holding tanks, and a sludge pasteurization and
stabilization facility.
IThe WWTP site property encompasses approximately four acres on the west side of Curtis Creek
1 near Interstate 40. The area immediately adjacent to the WWTP site is a mix of industrial sites and
agricultural production. The existing WWTP site will contain all expanded treatment facilities and
I the discharge location will remain unchanged. The topography in the area of the WWTP site is
generally flat. The topography of the Town of Old Fort in general varies from relatively flat to
steep and mountainous due to the location at the base of the Blue Ridge Mountains.
The Town also operates a sewer collection system consisting of approximately 26,000 linear feet
of 6inch, 8-iinch, 10-inch, and 12-inch gravity sewer. The main interceptor that transports the
1 majority of the Town's wastewater to the treatment facility is a 12-inch vitrified clay pipe sewer.
1 3

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SECTION 11 NEED O . PROJECI
1
The Town of Old Fort currently has a 0.4 MGD wastewater treatment reserve capacity. A local
textile facility, Excel Finishing, Inc., has expressed a need to expand their textile dyeing operation.
This expansion will result in approximately 60 new jobs and additional 0.275 MGD wastewater
aflow discharged to the Town of Old Fort sewer system. In order to accommodate the Excel
facility expansion as well as provide a reserve capacity for future industrial and commercial
growth, the Town of Old Fort desires to expand their existing wastewater treatment plant from 1.2
million gallons per day to 1.6 MGD.
The existing 12-inch gravity sewer interceptor transports the majority of the Town's wastewater to
the treatment plant. Current average daily flows exceed the design-basis one-half-full-pipe
capacity of the line. The line does not have the hydraulic capacity to handle existing peak waste.
flows. The interceptor has also been shown to have major root intrusion and severe groundwater
infiltration. The occurrence of groundwater infiltration not only further reduces the available "
wastewater carrying capacity of the interceptor but also increases the volume of wastewater that
must be treated at the wastewater plant.
1
The interceptor_has_been-the_source_of_several-recent-sewer overflows.The-overflows-have
' resulted_in the_assessment-of-civil-penalties-by-the_North_Carolina-Department-of_Environment
and Natural_Resources-(NC-DE_NR)zfor, violations of the Town's NPDES permit and State
' environmental regulations. The violations have causedcaused�NC-DENR to-place-the-Town_under-aa
sewer-connection-moratoriu_7The moratorium prevents the Town from accepting any additional
residential, commercial, or industrial wastewater, including the increase requested by Excel
Finishing, Inc, into the collection system. The Town desires to replace the existing 12-inch
vitrified clay pipe interceptor with a 24-inch PVC interceptor. This will provide adequate capacity
1 for current peak flows and future growth, allowing not only Excel Finishing, Inc. but also other
industries and commercial establishments to expand. An evaluation of the alternatives considered
1 is presented in the following section of this report.
i _ 4 _
1

1
SECTION III ALTERNATIVE ANALYSIS
This section of the report presents the alternatives considered in an effort to provide additional
sanitary sewer service to the expanding Excel Finishing textile plant and to address the problem
with the existing sanitary sewer collection system. Three alternatives are presented for the sewer
collection system improvements and four alternatives are included for the wastewater treatment
eplant expansion project.
Sewer Collection System Alternatives
As discussed previously in this report, the Town of Old Fort main sewer interceptor has been the
source of untreated wastewater overflows and is limiting the ability of the Town to provide
increased sewer service to Excel Finishing and all other industrial, commercial, and residential
customers. The lack of increased service to Excel Finishing is hampering the efforts of the
industry to expand operations at the Old Fort facility. The expanded operations would create
approximately 60 new jobs and benefit the Old Fort and McDowell County economies. The
following alternatives are considered in an effort to allow the Town to accept additional waste
flows from Excel Finishing and other industrial, commercial, and residential customers within
the sewer service area.
Alternative 1 — "Do Nothing"
This alternative consists of continuing to utilize the existing 12-inch sewer line with no
improvements, limit the flow from existing industries, businesses, and residences to keep the
flow within the capacity of the line, and not allow future expansion. This alternative would not
require capital expenditures; however, the Town's revenue and overall economy would suffer
because this would seriously restrict job creation and economic growth. Furthermore, the
0 condition of the trunk line would continue to deteriorate, allowing increases groundwater
infiltration and causing additional maintenance problems and increasing the risk of sanitary
sewer overflows. This alternative is not feasible or compliant with the Town of Old Fort's long
term goals.
- 5 -

1
Alternative 2 — Construct Additional Parallel Interceptor
This alternative consists of the construction of a new 18" gravity sewer interceptor parallel to the
existing 12-inch interceptor. The new line would be designed to carry the majority of
wastewater flow. The existing 12-inch line would be rehabilitated to increase its useful life and
allow it to carry peak flows in excess of the capacity of the new 18-inch line. Both sewer lines,
the new and the existing, would transport wastewater to the wastewater treatment plant.
aHowever, because this alternative would continue to use the existing sewer line, the Town is
expected have increased maintenance costs due to the double length of sewer line to be
maintained and the less than ideal condition of the existing 12-inch line. Table III-1 presents a
cost estimate for this alternative.
Table III-1
Project Cost Estimate
Alternative 2—New Parallel Interceptor
k '--'" --- Descr►ptlUn�.n a` s �%
ifiaG.P.r.r QUantl Unit' =lC'te k ax�Cy
Mobilization 1 LS $16,000 $30,000
18" sanitary sewer 7,650 LF $60 $459,000
12" sanitary sewer slip lining 7,650 LF $55 $420,750
Manhole rehabilitation E50
EA $700 $17,500
. 25 Manholes EA $1,800 $45,000
Railroad Bore and Jack LF $150 $45,000
' Road Bore and Jack LF $150 $7,500
Connection to 12" OverflowLS $2,000 $2,000
El. 11,026,750
3 1? a SaJD'dr =-KY _2M1 J4 F: r-'ti� "Qh¢...'fMiuSro .vw_A ='CAL ".a Ki�"NJ
10% Construction Contingency $102,675
Total Corist"ruchoniCos $1,129,425
h Engineering $80,600
Q Construction Administration $37,200
Legal/Administration $15,000
1

Alternative 3 — New 24-Inch Replacement Interceptor
The final alternative consists of constructing a new 24" gravity sewer line parallel to the existing
' sewer line. The new line would be constructed with sufficient hydraulic capacity to carry
existing peak flow as well as additional capacity for future industrial, residential and commercial
expansion. Upon completion of construction of the new 24-inch interceptor, the existing 12-inch
line would be abandoned. The new sewer interceptor would be designed utilizing current design
ecriteria including the ability to carry the average daily waste flow while only flowing one-half
full and maintaining minimum velocities of two (2) feet per second to prevent solids deposition
and would be constructed to prevent the excessive infiltration of groundwater. A preliminary
construction cost estimate for the proposed 24-inch interceptor is presented in Table III-2.
Table III-2
Project Cost Estimate
Alternative 3 —New 24-inch Replacement Interceptor
D'escnpttoi Quantityt +Unit `dUn►tPnce' Costr '
Mobilization 1 LS $20,600 $20,600
24" sanitary sewer 7,400 LF $75 $555,000
25 Manholes 25 EA $2,000 $50,000
Railroad and Roadore and Jack
tSanitary Service I aps A
Abandon xisting Manholes A ,5
00
' Asp a t epairs
Relocate 6-inch Water Line 1 LS $5,000 $5,000
° sSabtotal y "� t $705,975
10% Construction Contingency $70,598
To'taltConstruction Gosh $776,573
7 fi=rk-'�'a.4>s��_ta-.. v�iro'�'F' a _. -=a." ::.2 •az+� z*rR� s^s5srr4t, fi
Engineeringy $56,600
Construction Administration $28,300
QLegaUAdministration $15,000
,„•.r icYy. 'te a '� H 9 t i 9 a .sa"; cw t .. 1,•.^ 'rt"s T{r 7 7
$_"3`t.aG F"T 2c1'�x,..S.'�Y>-a:�'..w-.^.'c. �r,'-crf . x:C•> ,.5....s1e '_:t• .-E",. �u"-.it"" '?
- 7

1
Alternative 3 is the most cost-effective and the most operationally desirable alternative for the
Town of Old Fort and is, therefore, the recommended alternative. As discussed previously, the
' new 24-inch gravity sewer main would meet all the design criteria as specified by NCDENR. A
24-inch gravity sewer line constructed at minimum grade has a capacity to handle peak flows
over 4.4 NIGD, with scouring velocities near two feet per second at average daily flow. The
proposed 24-inch sewer main would provide the Town of Old Fort the ability to accept
aadditional flow and expand their sewer collection system to new areas as future growth warrants.
' Wastewater Treatment Plant Alternatives
Excel Finishing requested that the Town of Old Fort allow for the expansion of their textile dyeing
operation by providing approximately 275,000 GPD of additional wastewater treatment capacity.
Excel Finishing has stated this expansion would result in approximately 60 new jobs at their Old
Fort facility. The following alternatives are considered in an effort to meet this request while-
maintaining sufficient wastewater treatment reserve capacity to allow continued industrial,
commercial, and residential within the area served by the Town of Old Fort W WTP.
D
Alternative I —"Do Nothing"
This alternative consists of either restricting Excel Finishing and other wastewater dischargers to
' their existing wastewater discharge limits or allowing only minimal increases in wastewater flows.
This action would hamper industrial, commercial, and residential growth. Due to the negative long-
term affect to the Town's economy, this alternative is not considered feasible.
' Alternative 2 — Excel Finishing to Construct Private WWTP
Implementation of this alternative would require Excel Finishing to construct a private wastewater
treatment facility to process all wastewater generated from the textile plant. This solution would not
only dramatically reduce the Town's revenue, but it would also be far more expensive to construct,
1 maintain, and operate the new wastewater treatment facility than to upgrade the Town's existing .
facility. This alternative would also add an additional wastewater discharge point into Curtis Creek,
8

1
' which could have a negative impact on the environment. It is unlikely that the State of North
Carolina would allow a second discharge in close proximity to the Town's existing discharge.
Alternative 3 — Expanded Town of Old Fort WWTP and Discharge
The alternative consists of upgrading the Town of Old Fort's existing wastewater treatment
facility and surface water discharge from 1.2 MGD to 1.6 MGD. This upgrade would provide
aenough wastewater treatment capacity for the immediate expansion of Excel Finishing as well as
reserve capacity for future industrial, commercial, and residential growth. The wastewater
' treatment facility improvements would generally consist of an additional aeration basin, new
clarifier, new sludge holding, as well as expansion of the chlorine contact basin and residual
solids storage area. Table 111-3 provides a preliminary cost estimate for this alternative: (see
following page)
1
e
t
t

1
' Table III-3
Project Cost Estimate
' Alternative 3 - Expanded Town of Old Fort WWTP and Discharge
t =Descnption e = w 1Quant ty; Untt UnrtiPrice � t'iCast
Mobilization 1 LS $36,000 $36,000
New Headworks Facility 1 EA $500,000 $500,000
New 24" Influent Line 75 LF $80 $6,000
Aerated Grit Removal I LS $150,000 $150,000
Influent Pump Station Piping Modifications 1 LS $25,000 $25,000
Flow Equalization Basin Improvements 1 LS $35,000 $35,000
Aeration Basin Expansion I LS 1 $320,000 $320,000
60' Dia Steel Clarifier 1 LS $170,000 $170:000
One New Return Sludge Pump 1 LS $20,000 $20,000
Upgrade Chemical Feed Equipment 1 LS $2,000 $2,0,00
Chlorine Contact Basin Expansion I LS $24,000 $24,000
' 10-inch Piping to Aeration Basin Addition 120 LF $30 $3,600
Relocate 2-Inch Water Line 200 LF $6 $1,200
12-Inch Aeration Basin Effluent 100 LF $36 $3,600
Clarifier Splitter Box Expansion 1 LS $8,000 $8,000
12-In. Line (Flow Splitter Box to New Clarifier) 135 LF $36 $4,860
e 8-Inch Clarifier Effluent Line 250 LF SD $6,000
8-Inch Return Sludge/Scum Piping 300 LF $24 $7,200
75,000 Gallon Sludge Holding I LS $100,000 $100,000
Connection to New Sludge Holding 1 LS $7,500 $7,500
Connection to Return Sludge Wetwell 1 LS $500 $500
Miscellaneous Piping 1 LS $10,000 $10,000
' Additional Final Product Storage (Covered) 1600 SF $40 $64,000
Spreader Truck for Biosoloids Disposal 1 EA $50,000 $50,000
Land Acquisition 1 LS $10,000 $10,000
i Paving 200 SY $30 $6,000
Sitework 1 LS $5,0)0 $5,000
Electrical I LS $160 000 $160,000
rty ., e: wSxsfi� ar S'utitotal� xa ,ems. $1,735,460
"4's `1.L��' :A "+,Y."wr_"g„,^.."-S�tt;x:;V_: 'd°_ '.:, 3z;: ... v. A' ' .n .
10% Construction Contingency $173,546
Q r t jTotal n trueho ost� . �? $1,909,006
Co
.....ls. +. ._ x
Engineering $128,800
Construction Administration $49,300
Legal/Administration $5,000
TOTALPROJEGTC®ST � ' $2,092,1N.
06
' - 10 -

Alternative 4 - Expanded Town of Old Fort WWTP and With Land Application
' The alternative consists of upgrading the Town of Old Fort's existing wastewater treatment
facility from 1.2 MGD to 1.6 MGD and utilizing land application disposal for the additional 0.4
MGD of treated wastewater. This upgrade would also provide enough wastewater treatment
capacity for the immediate expansion of Excel Finishing as well as reserve capacity for future
eindustrial, commercial, and residential growth. The wastewater treatment facility improvements
required would be the same as those for Alternative 3 and would generally consist of an
additional aeration basin, new clarifier, new sludge holding, as well as expansion of the chlorine
contact basin and residual solids storage area. In addition to the treatment facilities required, a
suitable-land-application-area-and-application-apparatus (subsurface pipelines or spray or drip
irrigation equipment) would-be�jrequired. J-he-land-area-required to dispose of the 0.4 MGD of
' additional waste flow would be from '),I-acres-for-an-optimistic-application-rate-of0.3-gallons-perp
daycper-square-foot-to-91-acres-for-a.more.conservative application-rate.of-0-l-gallons perldayyper:a
' vquare-foot. The required area would be further increased by the requirement for buffer areas.
and to allow for unsuitable areas within the disposal site. In addition,�wet weather_holding-basins-
with-at-least-l-�_days:storage-would-be-required-to-store-the-effluent during:adverse-weathera
conditions. It is very_unlikely_that_tHiT much=land-could-be-o obYained_witfiin_any feasonabley
' �proxi_mity_to-the-treatment-plant: Furthermore, as described above, the cost of this alternative
would include the cost of the treatment facilities included in Alternatives 3 plus the cost of the
' application area and all associated application apparatus. Clearly this cost will significantly
exceed the cost of Alternative 3 and is therefore-not-considered-practical.
Alternative 3, expansion of the existing treatment facilities and the surface water discharge to 1.6
MGD is the most cost-effective alternative available to the Town of Old Fort and is the
Qrecommended alternative.
' - 11 -

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ENVIRONMENTAL ,SECTION IV
CONSEQUENCES-
Since there is already an existing wastewater treatment facility on the site, the primary
environmental consequence to be considered is the affect the increased discharge will have on
athe receiving stream and the wildlife in the area.
' Changes In Land Use
Both the proposed sewer interceptor and wastewater treatment plant improvements are to be
constructed in close proximity to existing sewer lines and treatment works. Construction of the
water and sewer lines would not alter the present land use either during or after construction.
' Wetlands and Floodplains
No known wetlands will be impacted by the construction of any of the proposed facilities or the
increased discharge. All facilities will either be constructed above the 100-year flood plain or
eprotected by appropriate devices such as watertight manhole covers and elevated vents. This
will assure that there will be no significant adverse impacts to flood plain areas.
1 Prime or Unique Agricultural Lands
' There are no known prime or unique agricultural lands in the project area.
Public Lands
With the exception of the wastewater treatment plant site, no portion of the project will be
constructed on public land.
Scenic and Recreational Areas
No scenic or recreational areas will be impacted by the project.
- 12 -

1
Areas of Archeological or Historical Value
The construction of this project adjacent to existing sewer lines and within the confines of the
existing plant site is not expected to impact any areas of archaeological or historical significance.
Air Quality
This project does not involve the discharge of any vapor or particulates in to the air. No air
quality impacts are anticipated.
1 Groundwater Quality
' All water discharges associated with the project will be in the form of treated wastewater effluent
' to a receiving stream. No groundwater quality impacts are anticipated.
Nuisance Conditions
The proposed projects will not significantly altar the noise and odor conditions found at the
existing wastewater treatment site. The treatment plant will be constructed to minimize any
odors and is located in a remote area so as to reduce any potential nuisance conditions.
Water Supplies
No known water supply intakes are located immediately downstream of the existing discharge.
The proposed flow increase is not expected to have any impact on any public or private water
supplies.
QShellfish or Fish and Their Habitats
' The North Carolina Department of Environment and Natural Resources (DENR), Division of
Parks and Recreation (DPR) has also reviewed the proposed project scope. DPR indicated that
the Natural Heritage Program database contains a record for the Santee chub (Cyprinella
zanema) from the reach of the Catawba River just downstream of the Town of Old Fort. The
13 -

1
Santee-chub-is:a;fish classified.as.significantly-rare-in-North-Carolina. iDRR:iecomme
u
' dechlorination-st-Cr�be pproyided�in the-wastewater-treatment-process-and-that-ultraviolet
disi nnfection`methods,be_considered-p
rThe proposed project does provide for dechlorination of the wastewater effluent prior to
discharge to the receiving stream. D-echlocination=will_he_accomplished_by_the-introductiontof,
sulfur dioxide-at the—end=of--the=chl_orine-contact-basin,= Ultraviolet disinfection has been
considered for use in the proposed project but was deemed inappropriate because of the presence
of a large volume of textile dying waste in the Town's waste stream. To be effective, the
ultraviolet disinfection process requires a high light transmisivity in the effluent. Textile dying
waste typically reduces the light transmisivity of the effluent to the point that ultraviolet
' disinfection is not satisfactorily effective. In fact,,the-WWTP_did-h'ave_an ultraviolet.radiation
syst�one time,'but due to ineffectiveness, r_was-repl""aced witha.chlorination%dechlorinationbp
Gystem=Tihe existing-l-2-MGD-treatment-process_utilizes-chlorine-disinfection-followed-bY.ice
{dechlorination oof-[he.effluent`Th'e proposed project will continue the same process and is not -
Qexpected to have any additional impact on the Santee chub or other aquatic resources in the
Catawba River basin.
Wildlife and Their Habitats
tAs discussed above, the North Carolina Wildlife Resources Commission has reviewed the
proposed scope of the project and has determined that potential project impacts to fish and
wildlife habitats are primarily related to surface waters and associated wetlands. No significant
impacts to wildlife and wildlife habitats are anticipated.
1
Introduction of Toxic Substances
t'T�treated-effluent-is-not-expected=to=contain_toxic_levels_of any substances. No toxic
' substances are introduced during the wastewater treatment process except during the chlorination
step of the process. The chlorine is subsequently neutralized by the introduction of sulfur
' dioxide. Toxic substances can occur in the incoming sewage but are normally removed during
the wastewater treatment process. The NPDES permit for the existing 1.2 MGD discharge
14

1
includes a residual chlorine limitation and whole effluent toxicity testing on a quarterly basis. As
' discussed below in the Receiving Water section, DENR has indicated that the increased
discharge will also be subject to a chlorine limit and toxicity testing. The chlorine residual
limitation and whole effluent toxicity testing contained in the NPDES permit will insure that
toxic substances are not discharges in quantities that will have significant adverse impact on the
receiving stream or surrounding environment.
' Receiving Waters
O The existing 1.2 MGD wastewater treatment plant discharges the treated effluent to Curtis Creek,
a Class C-Trout stream in the Catawba River basin. The proposed 1.6 MGD flow (0.4 MGD
flow increase) will also be discharged to Curtis Creek via the existing outfall pipeline.
Speculative NPDES effluent limitations for a total discharge of 1.5 MGD were received from
' DENR in May of 1997. Ammonia limitations for the discharge of 1.6 MGD are expected to be
similar to, but slightly more restrictive than, the speculative limits provided for the 1.5 MGD'
Qdischarge. It is expected that BOD and TSS limits will remain at 30 mg/l, therefore, tertiary
treatment will not be required. Speculative limits for the 1.6 MGD discharge have been
requested from DENR and will be incorporated in the final design of the facility. The
speculative limits provided for the 1.5 MGD discharge are provided below.
Parameter SiiiitmecrtLunit WWinter j,
BOD5 (1119/1) 30 30
NH3-N (mg/1) 2.6 6.8
Dissolved Oxygen (mg/l) 5 (minimum) No Limit
TSS (mg/1) 30 30
Fecal Coliform (#/100ml) 200 200
pH (SU) 6-9 6-9
1 Chlorine (µg/l) 28 28
' The discharge will also be subject to continued chronic toxicity testing. The test would be
conducted at 32% effluent concentration for a 1.5 MGD discharge. The proposed 1.6 MGD
discharge will be subject to testing at a slightly higher concentration.
- 15 -

The operation of the WWTP and discharge of the treated effluent will be subject to the
requirements in the NPDES permit and regulations implemented to protect the water quality of
the receiving stream. No significant adverse impacts on the water quality of the receiving water
or on other characteristics are expected.
Indirect or Secondary Impacts
' Only limited indirect and secondary impacts are expected in response to the proposed projects.
Established industrial sources comprise the majority of the Town of Old Fort's waste stream.
aThe flow expansion is proposed to allow increased service to an existing industry and the sewer
interceptor replacement is needed to alleviate existing sewer deficiencies. The proposed projects
' are not expected to spur extensive growth in or around the Town but are needed to serve the
existing industrial, commercial, and residential base and allow moderate expansion in all sectors._
' Completion of the projects is not expected to cause changes in the historical development
patterns in or around the Town of Old Fort. No significant impacts to natural or environmental•
Dresources are expected as a result of the expansion of the Town of Old Fort wastewater treatment
plant or the replacement of the existing sewer interceptor. The local economy and employment
opportunities in western McDowell County are, however, expected to be positively impacted by
the creation of additional jobs and the subsequent flow of the additional income into the local
teconomy.
16 -
1

SECTION V MITIGATIVE MEASURES
While no significant adverse environmental impacts are anticipated, various mitgative measures
will be included in the design, construction. and operation of the proposed sewer interceptor and
wastewater treatment plant expansion projects. These measures will further reduce or eliminate
any impacts to the environmental and natural resources in proximity to the proposed projects.
All applicable erosion control measures will be incorporated into the design and construction of
0 all facilities. Silt fences, check dams, settling basins, and prompt seeding, among other
measures, will be utilized to insure that construction activities do not pose an erosion or siltation
hazard.
' The wastewater treatment facility will be designed to achieve compliance with all NPDES permit
conditions and other applicable regulations and will be operated in a manner consistent with the
goal of minimizing environmental impacts.
e
t
i
t
t
' - 17 -

1
1
SECTION VI MAP OF PROJECT AREA
The following maps show the location of the Town of Old Fort and specific locations of the
proposed projects.
Figure VI-1
Location Map
Town of Old Fort, North Carolina
ti j'� vill 1 � 1
y I W
rM y
BUr ISY1110 `.• a Pne �tlff�ll e
M vi0lt t8 g 21 S
C to the lmlaM S� f J +� _
M ill ( 8
1
ha0 ee
aville �y
In
ro Dlllirpnam
pvilla 7
J '
eAer WalkMovm /��
e �• -Dieu _ ® GlmwcvG
hev Us aex
d The Town of Old Fort
. o
5 ]4 %
_ sn
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_ f e
onl
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her( dten „aorta
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lly S"", •''n Y
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lerawo ,imimw.��
S rsamlle -!
D
D
19 -
i

' Figure VI-2
Project Location Map
' Town of Old Fort, North Carolina
FIGURE I1-2 V
THE TOWN_OF-OLD FORT'
The Town of Old Fort WWTP 'J
1 _ 70
r,��'"� �` r
70d ,,
EXISTING 12 GRAVITY:
w`T Excel Finishing In N SANITARY SEWER LINE
b � x
2'
1p .t
.Aau USA '--1 —,•�?�L., - .._ r�J"'..i
1
' 20

TOWN OF OLD FORT ID : 704-668-2007 MAY 27 '97 15 :55 No . 002 P .02
State of North Carolina IT
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor M�
Jonathan B. Howes, Secretary at
A. Preston Howard, Jr., P.E., Director
May 22, 1997
eThe Honorable Wayne S. Stafford
Mayor of Old Fort
P,O. Box 520
Old Fort, N.C. 28762-0520
Subject: SNPPDESrpermit No, NCO0212291d Fort WWTP
1 McDowell County
i)ear Mr. Stafford:
This letter is in response to Mr. Mike Parker of the Asheville Regional Office's
request for speculative effluent limits for Old Fort W WTP's proposed expansion from 1.2
MGD to 1.5 MGD. This request has been reviewed by the staff of the Instream
Assessment Unit of the Technical Support Branch,
Please be advised that response to a speculative request does aZ guarantee that the
Division will issue an NPDES permit to discharge treated wastewater. In accordance with
the North Carolina General Statutes,the practicable waste treatment and disposal alternative
with the least adverse impact on the environment is required to be implemented.
' Nondischarge alternatives, such as spray irrigation or connection to is regional treatment
and disposal system, are considered to be environmentally preferrable to a discharge.
Therefore,prior to submittal of an NPDES application,a detailed alternatives analysis must
be prepared to assure that the environmentally sound alternative was selected from the
reasonable cost effective options. In order to receive final permit limits,a formal
application indicating the proposed WWTP design capacity and a justification for the
facility will have to be submitted to the Division's Permits and Engineering Unit.
Based on available information, the tentative limits for conventional constituents for
the Old Fort WWTP at the expansion flow of 1.5 MGD are:
Summer Winter
BOD5(mg/1) 30 30
NH3-N(mg/1) 2.6 6.8
Dissolved Oxygen (mg/1) 5 nr
Q TSS (mg/I) 30 30
Fecal Cobform (#/100ml) 200 200
PH (SU) 6.9 6-9
Chlorine (99n) 28 28
It should be toted that the summer and winter NH3-N I'vnits recornrricnded for this
plant are based on protec ting the receiving stream against instream toxicity. North Carolina
is evaluating all NPDES dischargers for ammonia toxicity following the Environmental
P.O. Box 29535, Raleigh, NoAh Carolina 27626-0535 Telephone
19-733-post-consumer FAX [phone]
An Equal opportunity Affinnauve Action Employer recycled/

tTOWN OF OLD FORT ID : 704-668-2007 MRY 27 '97 15 : 56 No . 002 P -03
' Letter to Mr. Stafford
-page 2 -
Protection Agency(EPA) guidance to Protect the waters for an instream criteria of 1 mg/l in
the summer and I.R mg/l in the winter, under 7Q10 flow conditions.
The Division of Water Quality (DWQ)is requiring chlorine limits and
dec:hlorination for all new or expanding dischargers proposing the use of chlorine for
disinfection. The process of chlonnation/dechlorinstion or an alternate form of
the total
disinfection,such as ultraviolet radiation, should allow the facility to comply
residual chlorine limits recommended above.
' A chronic toxicity testing requirement at 32% with quarterly monitoring will remain
a condition of the NPDES permit. A complete evaluation of limits and monitoring
requirements for metals and other toxicants will be addressed at the time of fomral Permit
' application.
DWQ is currently on its second round of implementation of a basinwide water
quality management initiative for the Catawba River Basin. our next installment of ft
attempt
' Catawba River Basin plan is scheduled for publication in the year 20M • P
to further address all sources of point and nonpoint pollutants where deemed necessary to
protect or restore water quality standards, in addressing interaction of sources,wasteload
allocations may be affected, Those facilities that already have committed to high levels of
treatment technology arc least likely to be affected.
Final NPDES effluent limitations will be determined after a formal perMI'l
application has been submitted to the Division. If there are any additional questions
en 5n2)g wry staff this
a leas OR3
feel free to contact Ruth Swanek (ext. 503) or Jackie Nowell
( t
Sincerely,
Wald L• S 4effo
Assistant Ch
' Water Quality Section
Q DLS/JMN
cc: Forrest Westall
Michelle Suverkrubbe
a Bobby Blowe
Central Files
WLA File
1

TO-ON OF OLD FORT ID : 704-668-2007 MRY 27197 15 :55 No .002 P .01
iim P.O. SOX5" /� �/
' y OLD FORT.NORTH C,AROMM 28762 orce i 8�theiMnyor
244
Fax [phone]
1 FAX COVER SHEET
FAX NO. . DATE : ,S .�27 I7
ATTN : �►
'SUBJECT :
kENDER
kUMBER OF PAGES : COV
ER E}-7 SHEET + PAGES
1
Q
i . .
1

' TOWN OF OLD FORT ID 704-668-2007 DEC 11 '98 16 29 No .006 P .02
Excel Street
Inc.
1Water
1 Waterr
p 139.0. Box 130
Phd704 650-001 Pori. North Carolina
Faa 704-668 90aZ
FINIiFYNC,Me.
Mr. Wayne Stafford
Mayor of Old Dort
e P.O, Box 520
Old Fort, N.C. 28762
December 9, 1998
Dear Mayor Stafford,
As you know Excel Finishing,lnc. has expanded recently and continues to
' grow. We are presently developing new processes that should increase our production
dramatieully. We are also concentrating our sales marketing to increase our dyeing
production. The results of these efforts will be u substantial increase in our water
' consumption and wastewater discharge,
As we look to meet these challenges, one of our concerns is that The Tuwn of
Old Fort may not be able to meet this increasing sewer requirement, To ensure our
continued growth I therefore request (hat additional flow allowance for Excel be made
avaiI able.LBT__December_oof_1:999:we_wilLaveragc.600,000_gaUilay—_widl.peek d"e_mtitid
iof 750;000 gal/day..-Please let Inc know when you curt increase our permitted flow
limit.Thank 1'or your cooperation in this matter,
Sincerell
Gene Young
President, Excel Finishing, Inc.
e
0

' Dec-zc-96 1z : 14P P . OZ
I Wa orStraleg,Inc
1.O.Bo Street
P.O.Box 170
Old Fort North Carolina 28752
)4A1rEL Ph 7 04 6 6 8-9 0 91 Fm m4AW4M7
AN'I�HINC,Ne.
' .dAOM.'21MfCiiOYTbCfwII�Tw'YNCVI,�JTt M9Y.4YVNMYaI.n��:/aryTM+..TrimNsurn[n,.i�YY+me�.WYl.:ybw:�.n.'•tli�.�:m.:o.Yvsa.r✓.r.vue@a:!
Mr. Wayne Stafford
Mayor of Old Fort
e P.O. Box 520
Old Fort,N.C. 28762
December 20, 1996
Dear Mayor Stafford,
This is to inform you of the future effect of our ongoing expansion at Excel
' Finishing Inc. As you work at upgrading Old Fort's water and sewer system to meet
our needs you can be satisfied to know it4 impact on your town's job market.
Our expansion will directly create 60 new jobs as we add equipment to our
' new dyehousc. Associated textilc manufactwing as the result of Excel's expansion
should be coming online in 1997. This new manufacturing should create another 40
new jobs.
If you have any questions concerning these develnpments or need any help
with your projects do not hesitate to contact me.
Sincerely
Gene Young '
President, Excel Finishing, Inc.
0
0

' State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
' Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director D E N R
aSeptember 23, 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
The Honorable Wayne S. Stafford
Town of Old Fort
P. O. Box 520
Old Fort, NC 28762
' SUBJECT: Assessment of Civil Penalties for Violation(s) of
NPDES Permit NCO021229 and 15A NCAC 2H .0900
Town of Old Fort
McDowell County
File No. PC 98-009
eNPDES Permit Number NCO021229
Dear Mayor Stafford:
This letter transmits notice of a civil penalty assessed against the Town of Old Fort in the
amount of$13,625.25, including $1,625.25 in enforcement costs.
Attached is a copy of the assessment document explaining this penalty. This action was
taken under the authority vested in me pursuant to delegation provided by the Secretary of the
Department of Environment and Natural Resources. Any continuing violation(s) may be the
' subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
P.O. Box 29535 .
OR Raleigh, North Carolina 27626-0535
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
' An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper

i 1 ,
2. Submit a written request for remission or mitigation including a detailed
justification for such request.
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment letter.
Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation that there are no factual or legal issues in dispute. You
must execute and return to this office the attached waiver and stipulation form and
a detailed statement which you believe establishes whether:
' (a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
0 from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
' Ms. Coleen Sullins
Water Quality Section Chief
0 Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Please note that all information presented in support of a request for remission
must be submitte3in writing. The Director of the Division of Water Quality will
review the information during a bimonthly dnforcement conference and inform
' you of his decision in the matter of the remission request. His response will
provide details regarding case status, directions for payment and provision for
further appeal of the penalty to the Environmental Management Commission's
' Committee on Civil Penalty Remissions. Please be advised that the Committee
cannot consider information that was not part of the original remission request
considered by the Director and therefore, it is very important that you prepare a
complete and thorough statement in support of your request for remission.
or
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
' administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must

File your original petition with the
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
and
Mail or hand-deliver a copy of the petition to
Mr. Dan McLawhorn
General Counsel
Department of Environment and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Failure to exercise one of the options above within thirty days as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter
' being referred to the Attorney General's Office with a request to initiate a civil action to collect
the penalty. Please be advised that additional assessments may be levied for future violations
which occur after the review period of this assessment.
' If you have any questions concerning this matter, please contact Mr. Bob Sledge at (919)
733-5083. extension 233.
pSincerely,
�. Preston Howard, Jr., P.E.
Attachment
cc: Regional Supervisor w/attachments
Compliance/Enforcement File w/attachments
Central Files w/attachments
r

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF
' IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
' OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
PERMIT NO. ) STIPULATION OF FACTS
FILE NO.
Having been assessed civil penalties totaling for
' violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated , the undersigned, desiring to seek remission of the civil
0 penalties, does hereby waive the right to an administrative hearing in the above-stated matter and
does stipulate that the facts are as alleged in the assessment document.
This the day of 19
BY
ADDRESS
f
TELEPHONE

1
STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
' COUNTY OF MCDOWELL COMMISSION
File No. PC 98-009
IN THE MATTER OF )
TOWN OF OLD FORT )
' )
FINDINGS AND DECISION
FOR VIOLATIONS OF THE15A ) AND ASSESSMENT OF
N. C. ADMINISTRATIVE CODE ) CIVIL PENALTIES
2H .0900 PRETREATMENT )
PROGRAM REGULATIONS AND )
PART III, B., 9. OF THE )
PRETREATMENT PROGRAM )
e REQUIREMENTS OF NPDES )
PERMIT NO. NC00021229 BY )
FAILING TO IMPLEMENT THE )
ENFORCEMENT RESPONSE )
PLAN. )
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources, I, A. Preston Howard, Jr., P.E., Director of the Division
of Water Quality (DWQ), make the following:
aI. FINDINGS OF FACT:
A.. The Town of Old Fort (Town) is a municipality organized and existing under the laws
of the State of North Carolina.
B. The Town operates a 1.2 MGD wastewater treatment plant in the Town of Old Fort,
North Carolina.
C. The Town was issued NPDES Permit No. NCO021229 on April 28, 1995, with an
expiration date of April 30, 2000.
' D. Part III, B. 5. of said permit states that the permittee shall, in accordance with NCGS
143-215.1, issue to all significant industrial users, permits for operation of
pretreatment equipment and discharge to the permittee's treatment works.
E. Part III, B. 9. of said permit states that the permittee shall enforce and obtain
appropriate remedies for violations of all pretreatment standards promulgated pursuant
' to section 307(b) and (c) of the Clean Water Act (40 CFR 405 et. seq.), prohibitive
discharge standards as set forth in 40 CFR 403.5 and 15A NCAC 2H .0909, and
specific local limits. It further states that all enforcement actions shall be consistent
with the Enforcement Response Plan (ERP) approved by the Division.

1
F. Part III, B. 12. of said permit states that the permittee shall retain for a minimum of
three years records of monitoring activities and results, along with support information
including general records, water quality records, and records of industrial impact on
the POTW.
1 G. The Town of Old Fort issued Industrial User Pretreatment Permits (IUPs) to Excel
Finishing and Collins & Aikman effective May 1, 1994. The IUPs expire April 31,
1999. The IUPs includes a daily maximum flow limit of 0.150 million gallons per day
1 (MGD) and 0.03 million gallons per day (MGD), respectively.
H. The Town of Old Fort intentionally and willfully gave verbal permission to Excel
1 Finishing to exceed its flow limit from the period January 1, 1997, through June 26,
1998. No written record of this permission was maintained and the IUP was not
modified to include the new flow limit requirements.
I. The Town of Old Fort failed to judge compliance with flow limits for Excel and
Collins & Aikman for the period January 1, 1997 through May 31, 1998, and failed to
etake enforcement as outlined in the POTW's Enforcement Response Plan (ERP).
J. Review of the Asheville Regional Office's records from January 7, 1998 through March
1 23, 1998 revealed the Town had twenty-three (23) sewer overflows as described in
Attachment A. Ten (10) of these sewer overflows reached surface waters of the State._
K. The Town of Old Fort has stated that the flow limit violations by Excel Finishing were a
definite contributing factor to the sewer line overflows.
1 L. The Town had no valid permit for the above described discharges.
' M. This is the first enforcement case against the Town of Old Fort for failure to
implement the pretreatment program requirements.
1 N. The cost to the State of the enforcement procedures in this matter totaled $1625.25.
1 Based upon the above Findings of Fact, I make the following:
' II. CONCLUSIONS OF LAW:
1 A. The Town of Old Fort is a "person" within the meaning of G.S.143-215.6A pursuant
to G.S. 143-212(4).
1 B. The Catawba River constitutes waters of the State within the meaning of G.S. 143-
215.1(a)(1) pursuant to G.S. 143-212(6).
i
1

1
C. The Town of Old Fort's failure to issue or modify an Industrial User Pretreatment
Permit (IUP) allowing the change in the flow limit for Excel Finishing violated Part
III, B., 5. of the Pretreatment Program Requirements of NPDES Permit No.
NC00021229 and the 15A N. C. Administrative Code 2H .0916 and .0917
Pretreatment Program Regulations.
D. The Town of Old Fort's failure to enforce and obtain appropriate remedies for Excel
Finishing's violations of their pretreatment limits in their Industrial User Pretreatment
' Permit violated Part III, B., 9. of the Pretreatment Program Requirements of NPDES
Permit No. NC00021229 and the 15A N. C. Administrative Code 2H .0900
Pretreatment Program Regulations.
' E. The Town of Old Fort's failure to keep adequate records of the change in the flow
limit for Excel Finishing violated Part III, B., 12. of the Pretreatment Program
Requirements of NPDES Permit No. NC00021229 and the 15A N. C. Administrative
Code 2H .0900 Pretreatment Program Regulations.
eF. The above-cited violations of Old Fort's Pretreatment Program significantly
contributed to unpermitted discharges that constitute making an outlet to waters of the
State for purposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S.
143-215.1
G. The Town of Old Fort may be assessed civil penalties in this matter pursuant to G.S.
143-215.6A(a)(2), which provides that a civil penalty of not more than ten thousand
dollars per violation may be assessed against a person who is required but fails to
Oapply for or to secure a permit required by G.S. 143-215.1.
H. The State's enforcement costs in this matter may be assessed against the Town of Old
' Fort pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
I. The Director, Division of Water Quality, pursuant to delegation provided for by the
Secretary of the Department of Environment and Natural Resources, has the authority
to assess civil penalties in this matter.
' Based upon the above Findings of Fact and Conclusions of Law, I make the following:

III. DECISION:
Accordingly, the Town of Old Fort is hereby assessed a civil penalty of:
$ I - O O D for__L of I violations of Part III, B., 5. of the
' Pretreatment Program Requirements of NPDES Permit
No. NC00021229 and the 15A N. C. Administrative
Code 2H .0916 and .0917 Pretreatment Program
Regulations by failing to issue Industrial User
Pretreatment Permits with appropriate pretreatment
limits.
' $ I n I D O O for L— of /do violations of Part III, B., 9. of the
Pretreatment Program Requirements of NPDES Permit
No. NC00021229 and the 15A N. C. Administrative
Code 2H .0900 Pretreatment Program Regulations by
e failing to enforce and obtain appropriate remedies for
Excel Finishing's violations of their pretreatment limits
in their Industrial User Pretreatment Permit.
$ 1 .0000 for of_J_ violations of Part III, B.,12. of the
Pretreatment Program Requirements of NPDES Permit:
No. NC00021229 and the 15A N. C. Administrative
Code 2H .0908(f), .0916 and .0917 of the Pretreatment
Program Regulations by failing to maintain adequate
D record of the flow limit requirements for Excel
Finishing. ,
$ 7. t DO o TOTAL CIVIL PENALTY, which is r�2- percent of the
maximum penalty authorized by G.S. 143-215.6A.
$ 1625.25 Enforcement costs
' $ 13 , &zs 2 S TOTAL AMOUNT DUE
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1 As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.1(b), which are:
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(1) The degree and extent of harm to the natural resources of the State, to the public
1 health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by non-compliance;
(6) Whether the violation was committed willfully or intentionally;
1 (7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
e 1 Z3_gg
(Date) Preston Howard, Jr., P.E., Director
1 u Division of Water Quality
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