NC0021229_Fact Sheet_20200830

DENR/DWQ
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO021229
2020 Renewal
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns).
Facility and Stream Information
Applicant/Facility Name:
Town of Old Fort Old Fort WWTP
Applicant Address:
38 Catawba Avenue; Old Fort, NC 28762
Facility Address:
1174 E. Main Street; Old Fort NC
Facility Class Permit Status:
Grade II (0.5); III 0.9 Biological WPCS Renewal
Permitted Flow
0.5 MGD 0.9 Expansion
Type of Waste
Municipal < 1MGD
Receiving Stream
Curtis Creek
Stream Class ID
C; Tr 11-10
7Q10 Sum Win cfs
4.9 7.4
30Q2 cfs
10.5
Avg. Stream Flow cfs
30.6
IWC %
13.7 % 22.2
Subbasin
03-08-30
USG S Too
E10NW Old Fort, NC
County
McDowell
I Regional Office
ARO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / June 22, 2020
Does permit need daily max NHs limits?
Already included in existing permit
Does permit need TRC limits/language?
Already included in existing permit
Does permit have toxicity testing?
Not at this time but would for 0.90 MGD - see below
Does permit have Special Conditions?
Yes; Activation of 0.90 MGD and reo ener
Does permit have instream monitoring?
Yes - Hardness
Stream on 303(d) List? For w arameter?
No
Any compliance concerns?
See compliance discussion below
Any modifications since lastpermit?
None noted in application but email submitted
New expiration date:
January 31, 2025
FACILITY OVERVIEW:
This facility is municipal wastewater treatment plant with a recently re-established pretreatment program
(March 2020). The design capacity of the treatment system is 0.5 MGD with an expansion provision for 0.9
MGD. The system includes the following wastewater treatment components:
• Bar screen
• Influent pump station
• Influent flow meter
• Influent composite sampler
• Grit chamber
• One (1) flow equalization basin
• Two (2) 600,000-gallon aeration basins
• Splitter box
• Four (4) clarifiers (two offline)
• Chlorine disinfection with contact basin
• Dechlorination system
• Effluent flow meter
• Effluent composite sampler
• Two (2) 72,000-gallon sludge storage dewatering
tanks (one offline)
• Extended sludge dewatering and stabilization
treatment

No modifications were noted or proposed in the current application. Facility did send an email supplementing
the application in October 2019. In the email the Town requested that the permit reflect that some components
of the treatment system were not currently operations (two clarifiers and one sludge holding tank).
Most recent inspection (07/02/2019) found that the facility was generally well maintained and operated.
However, the inspection noted a number of system components that were at the end of their useful life or that
were not operational at the time of inspection. There were also comments that system redundancy was not in
place to assure adequate operation of the system long term. A conference call with ARO staff in December 2019
outlined issues with the treatment system. Over the years Old Fort has lost all of their industry, they continue
to operate a fairly large treatment system, but at a much reduced flow. The facility has been permitted for
flows up to 1.2 MGD in the past but has steadily reduced their permitted flow. The system is designed for the
1.2 MGD flow capacity (the 2011 Fact Sheet has a detailed discussion of permit changes over time). The facility
is currently permitted at 0.5 MGD and has an average flow of around 0.2 MGD. The region was concerned that
the treatment system components in the permit be more reflective of the system that was actually in operation.
A meeting with the town to discuss their system and their long term intentions was suggested.
The Asheville Regional Office and Central Office staff met with Town staff on 1/9/2020 to discuss the
treatment system. Staff outlined ongoing issues and the need for the permit to match what is being operated.
The town sees growth due to overflow from Asheville and Buncombe County and don't want to get rid of
capacity that they may need in the future. The town indicated they had a brewery that is coming and have
started discussions with the pre-treatment program. ARO advised that they should talk with the Town of
Ashville about their approach in dealing with breweries since they can create high BOD issues and issues with
solids, etc. They should keep ARO in the loop. The Town mentioned a former industrial area that had turned
into warehouse space but may have some new activity. The Town was asked to evaluate their anticipated
growth, look at needs in their treatment system, critical components, redundancy, I/I etc. and provide DWR
input on their assessment to help in the review of their renewal. See Tim Heim's summary email 1/9/2020.
Tony West, Town ORC, emailed on 3/16/2020 that the town was working with pretreatment to start their
program back up in order to accept discharge from Hillman Brewery. There had been no response from the
town on the items from the January meeting so a request was made for an update on the status. Mr. West
responded with an email on some efforts that have taken place over the last few months. Pretreatment has
talked with the NPDES program staff (Julie) and is moving forward on their approval. BOD and TSS will be the
main issues. Could also consider Turbidity and DO at 6 (Tr water). The pretreatment program approved the
restart of the town's program in a 3/23/2020 letter.
The restart of the town's pretreatment program will bring with it some changes to the proposed permit. These
changes are mainly reflected in monitoring adjustments in the permit. The pretreatment program has been
restarted due to the addition of non -domestic discharge from a brewery. The major potential impacts from this
discharge will be potential issues with BOD and TSS. BOD and TSS limits are already set at secondary standards
level for this facility based on a Level B model run in 1995 as part of a facility upgrade to 1.2 MGD. Fact Sheet
for 2011 renewal walks though detailed review of permit changes over time. Discussions with ARO indicate
that the facility should be able to meet requirements with the addition of the brewery and brewery standards to
control their solids, etc. Staff in the NPDES Unit, Aquatic Toxicology and the Regional Office were consulted in
making the proposed changes. The specific changes are discussed below in the monitoring data review section
of the Fact Sheet.
COMPLIANCE:
The facility had one enforcement case in 2018 for a bypass and discharge of partially treated wastewater. This
violation resulted in a penalty assessment of $1,500 and enforcement costs of $113.52. During the permit term
there was one NOD for a late/missing DMR in December 2019.
Old Fort WWTP Fact Sheet
NPDES Renewal 2020 — June 23, 2020
Page 2

MONITORING DATA REVIEW:
Parameter Units
Avg.
High
Low
Permit Limit
Comments
Flow (MGD)
0.20
2.08
0.00
0.5 MA
Avg. flow 40% of permitted flow
BOD (mg/L)
5.11
23.00
1.00
30 MA
No exceedances; Removal 97%
45 DM
TSS (mg/L)
11.25
31.00
1.25
30 MA
No exceedances; Removal 99%
45 DM
Temp (C)
16.77
25.00
7.00
-
Values in line w seasonal variation
200 MA
No exceedances; Month with 285 all
Fecal (#/100m1)
5.56
285
<1
400 WA
other values were < 1
pH (SU)
N/A
8.4
6.5
6 to 9
All values within range
5.9 MA
NH3-N (mg/L) summer
0.29
0.29
<0.2
17.7 WA
17.0 MA
NH3-N (mg/L) winter
0.11
0.70
<0.2
35.0WA
DO (mg/L)
8.22
10.90
6.00
>_ 5.0
All values 6 or above
TRC (µg/L)
21.65
49
7.00
28 DM
All values below 50 threshold
Total Cyanide (µg/L)
-
5.0
<5.0
All values but on < 5
Total N (mg/L)
8.98
14.88
3.46
Total P (mg/L)
2.69
7.21
0.70
57.71 MA
Limits effective 1/1/20; no values
Total Cooper (µg/L)
28.82
60
0.04
65.74 DM
exceeded the limits 2017 - 2020.
Total Mercury (ng/L)
4.52
8.52
1.60
Total Hardness (U)
9.55
14.00
5.00
Total Hardness (E)
71.25
90.00
60.00
MA - Monthly Average DM - Daily Max WA - Weekly Average
The data reviewed for the renewal is from January 2015 through February 2 02 0.
EFFLUENT POLLUTANT SCAN:
Current Requirement: Not required in the current permit
Proposed Requirement: Propose for both efluent pages and required three times over the
permit cycle.
With the addition of the pretreatment program the permit will require the Effluent Pollutant Scan.
This language is added under both effluent pages. This addition will give information to help with
proper characterization of the discharge for future permit renewals as the town adds discharges other
than domestic back into their system.
DISSOLVED OXYGEN (DO)
Current Requirement: DO is required to be >_ 5 mg/L.
Proposed Requirement: Set the DO level to be >_ 6 mg/L due to Trout water standards.
The Old Fort WWTP discharges to waters classified as trout waters (Tr). The instream water quality
standards for these classified waters set a Dissolved Oxygen standard of 6 mg/L. In order to maintain
this instream condition, the discharge from this facility should not exceed this standard. The DO
discharge standard has been increased to require that it be at least 6 mg/L for both effluent pages. In
review of the past discharge data it does not appear that meeting the 6 mg/L limit will be a major issue
for the facility. This has been verified with the permittee.
Old Fort WWTP Fact Sheet
NPDES Renewal 2020 - June 23, 2020
Page 3

WET MONITORING:
Current Requirement: Not required.
Proposed Requirement: Proposed addition to 0.90 MGD, Effluent Page
Whole Effluent Toxicity testing is not required in the current permit, but would usually be added required for a
facility with a pretreatment program. At this time it is proposed that WET monitoring be added with the
expansion to 0.90 MGD. The addition of three required Priority Pollutant Scans during the permit term will
give additional information on a variety of pollutants to help gauge whether there are toxicity issues. In
addition, this facility had previously had WET testing when they did have a pretreatment program and were a
much more heavily industrial system. In the last two permit cycles that required WET testing there was only
one failed WET test. With the added pollutant scan and past WET results it is reasonable to require the testing
if the facility expands further. A reopener clause has also been added to the permit to allow the Division to
move to modify the permit if any conditions show potential impacts [A. (4)].
AMMONIA NITROGEN (NH3-N) MONITORING:
Current Requirement: 2/Month monitoring in Current Permit. Permit has summer limits
and winter limits.
Proposed Requirements: Monitoring to remain at same frequency with only change being
adjustment of the winter limits in accordance with the applicable
rules
The summer and winter limits were set based on the mass balance waste load allocation. Recent
review by Division staff has noted that 15A NCAC 2B .O4O4(c) requires that winter waste load
allocations for oxygen consuming waste be no less stringent than 2 times the summer waste load limit.
To meet this rule requirement winter limits for NH3-N are being adjusted in the permit. These changes
will reduce the monthly average limit to 11.8 mg/L for the 0.50 MGD Effluent Limitations. The weekly
max of 35 mg/L will remain unchanged. For the 0.90 MGD Effluent Limitations the winter limits will
be reduced to 7.4 mg/L and 22.2 mg/L. A review of the monitoring data over the previous permit
cycle indicates that no winter NH3-N value has exceeded 0.70 mg/L, so the individual values are well
below the proposed values. Based on the data reviewed from the previous permit cycle it appears that
the proposed change in the winter limits will be well within the values that this treatment system
routinely attains.
COOPER CU MONITORING:
Current Requirement: Monthly monitoring with monthly average and daily max limits.
Schedule of compliance required compliance with limits by January
1, 2020.
Proposed Requirements: Maintain monthly monitoring with limits. Adjust limits as needed
in line with Reasonable Potential Analysis (RPA).
A reasonable potential analysis (RPA) was performed on data from the time period summarized above
for Cyanide, Mercury and Cooper. From this analysis (results attached to Fact Sheet) cyanide and
mercury did not show reasonable potential to exceed water quality standards, but the values were at
levels that warrant continued monitoring. No limits are set in this permit for these parameters.
Monitoring will remain at the frequencies established in the previous permit.
Old Fort WWTP Fact Sheet
NPDES Renewal 2020 — June 23, 2020
Page 4

Cooper data evaluated in the RPA review continue to show reasonable potential to exceed water
quality standards and will maintain limits. The limits for Cu under the 0.50 MGD flow will remain
unchanged. None of the reported values exceeded the daily max at the 0.50 MGD flow level. Analysis
for the expanded 0.90 MGD flow, however indicate the need for an adjustment of the water quality
based effluent limit. Based on this analysis the permit proposes a monthly average limit of 35.5 mg/L
and a daily max of 41.55 mg/L. The data evaluated did show five values that exceeded this daily max
within the last three years. Should the facility need to move to activate the 0.90 MGD flow special
attention should be given to consider actions that would assure compliance with the Cu limits.
The previous permit included a compliance schedule for meeting the Cu limits. That conditions
established that the limits would be met by January 1, 2020. The draft permit has removed this
compliance schedule.
PRETREATMENT REOPENER:
A reopener clause has been added to the permit [A. (4)] specifically related to the addition of industrial
discharges to the treatment system. If addition of industrial discharges are shown to have an impact
on the quality of the discharge form this facility, they Division may seek to re -open the permit and
address these issues with modified permit conditions. These potential changes may include additional
monitoring to access toxicity impacts or additions or changes to current monitoring requirements.
PROPOSED PERMIT CHANGES:
• Updated eDMR requirements
• Added regulatory citations throughout permit
• Updated parameter codes
• Added three perm term Effluent Pollutant Scan requirements to both effluent limits pages.
• Modified the dissolved oxygen limit to be set at 6 mg/L to be consistent with the trout designated
receiving waters.
• Added quarterly Whole Effluent Toxicity testing under the expanded (0.9 MGD) flow.
• Updated NH3-N effluent limits to set winter limits in both effluent pages to be in compliance with
rule 213.0404.
• Adjusted total cooper effluent limit under the 0.90 MGD discharge. The limit change is in keeping
with the results of the reasonable potential analysis performed on available data.
• Added Pretreatment Reopener to the permit.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: July 1, 2020
Permit Scheduled Effective Date: September 1, 2020
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett
at [phone].
Old Fort WWTP Fact Sheet
NPDES Renewal 2020 — June 23, 2020
Page 5

The McDowell News
Advertising Affidavit
PO Box 968
Hickory, NC 28603
NC DENR/DWQ
ATTN: WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
Account Number
3142720
Date
July 09, 2020
Date Category Description Ad Number Ad Size
07/09/2020 Legal Notices
Pullic Nette
Nod Cerepma Environmental Management Co mnission/180ES but
161711aDSenke Cede
paleigFa NC 2769M617
Notice of Intent toIssue a NPDESWashmalerPal NC002128 Old fat
WWrp
The North Carolina Environmental Management Commission proposes to
issue a NPDFS wastewater discharge permit to the persons) listed below.
Written comment regarding be proposed pnmit will be muted utNl
30 days after the puhl6h date of this rote The Director of the NC Mvp
sham of Water Resources (DWI) may hold a public hearing should there be
a significant degree of public interesL please mail rumment and/or mf r-
mation requests toOWRatthe someaddress Interested persons may vt-
it the DWR at 512 N. Salisbury Street Racigh, NC to review information
a file. Additional information on NPDES permit and this notice may be
found on or vounte: h:/tcPoetMov/aloout/divisions/waterresourtes
/waterresaurce�ermits/wastexa[er�bmncNnydeswastewater/ ihlir
RaticeAr by calling [phone]. Town of Old Fort has requested m
rival and modifimdon of permit NCO021229 for Old Fad WWTP in
McDowell County, this permitted dschame is treated wastewater to Cur.
tis Creek Catawba Ann Ruin
N6Eb:lulp9,2B21.
Public Notice North Carolina Environmental Management Coma 0000660382 2 x 26 L
Publisher of
The McDowell News
McDowell County
Before the undersigned, a Notary Public of Iredell County, North Carolina, duly
commissioned, qualified, and authorized by law to administer oaths, in said
County and State; that he/she is authorized to make this affidavit and sworn
statement; that the notice or other legal advertisement, a copy of which is attached
hereto, was published in the The McDowell News on the following dates:
07/09/2020
and that the said newspaper in which such notice, or legal advertisement was
published, was a newspaper meeting all the requirements and qualificati s of
Section 1-597 of the General Statutes of North Carolina.
air Assistant Bookkeeper
Newspaper reference: 0000660382
Swom to and subscribed before me, this 10 day of 2020
\ \\\\vsE�
LA Inhulrq /
Nora Public --—� PPO qO
ZZ
1 Notory Public
My Commission expires: Maul 'IQ arl1w = eC7ell Counyy c
20� P
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU

Reviewer notes to file
Response to Comments from Aquatic Tox Branch (ATB)
August 30, 2020
On July 15, 2020 the comments from ATB were discussed with Cindy Moore. It was explained that the
Old Fort facility had been permitted in the past at 1.21VIGD. However, the system is currently not
operated at this capacity and has a few components, as noted in the permit, which are currently off line.
The permit conditions for 0.9 MGD are accurate in the permit as is the 22% effluent concentration based
on the 0.9 MGD capacity.
DWR ATB pointed out that Chronic Toxicity sample type should be composite instead of grab. This
sample type has been changed in the final permit. In addition, a few corrections noted in the comments
for the Permit and Fact Sheet have been made.
The ATB also made comments about requirements for reopening the permit based on the addition of
other industrial users. After discussion of this issue ATB staff are in agreement that the language in the
draft permit is appropriate and not adjustments are needed. Language has stayed the same in the final
permit.

Draft NPDES 0021229 Review - DWR Aquatic Tox
Old Fort WWTP
McDowell County
1. Permit
a. Page 2 of 12 — Please correct that the facility is located in McDowell County.
b. Pages 4 and 5 of 12 — Chronic Toxicity
i. We have records that the sampling for WET testing was to be a composite
type sample at 1.2 MGD. Please explain the change to a grab sample being
collected at 0.9 MGD.
ii. We have records that testing was to be done at 28% at 1.2 MGD. Just want to
check that the 22% at 0.9 MGD is correct.
Please address the 22% on page 8 of 12 as well, if necessary.
c. Page 5 of 12 — A. (4) Pretreatment Reopener — ATB feels that WET testing should
be required if any new industrial discharge that is added to this system other than
the already planned for brewery prior to the expansion to 0.9 MGD.
2. Expedited Fact Sheet
a. Please capitalize the O in "old Fort" for the Applicant/Facility Name.
b. Facility Overview
i. Text states that "the design capacity of the treatment system is 0.5 MGD with
and [sic] expansion provision for 0.9 MGD."
Our records have the permitted discharge flow for this facility at 1.2 MGD.
Considering that there are two 600,000-gallon aeration basins, it appears that
there has been construction to allow this facility to operate at 1.2 MGD in a
future expansion.
There are also other statements in the Fact Sheet that state the system was
planned and designed for 1.2 MGD of discharge, even though the facility is
not currently operating at this level:
- "The facility has been permitted for flows up to 1.2 MGD in the past..."
- "The system is designed for the 1.2 MGD flow capacity."
- "Old Fort is planning for "growth due to overflow from Asheville and
Buncombe County and don't [sic] want to get rid of capacity that they
may need in the future."
Please clarify whether there is an expansion provision to 1.2 MGD for this
facility.
c. Proposed Permit Changes — Text stating "Added quarterly Whole Effluent
Toxicity testing under the expanded (0.0 MGD)" needs to be changed to 0.9
MGD.

8/30/2020
Mail - Bennett, Bradley - Outlook
[External] RE: Draft Permit Renewal - Old Fort WWTP - NCO021229
[e-mail] <[e-mail]>
Tue 7/7/2020 7:13 AM
To: Bennett, Bradley <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to [e-mail]
Bradley,
The Town of Old Fort has received, opened and downloaded the electronic version of its NPDES
permit. Thank you for your help.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W:828-668-4561
M:828-442-2343
--------- Original Message ---------
Subject: Draft Permit Renewal - Old Fort WWTP - NCO021229
From: "Bennett, Bradley" <[e-mail]>
Date: 7/6/20 2:04 pm
To: "[e-mail]" <[e-mail]>, "[e-mail]"
< [e-mail] >
Attached is the draft permit renewal for the Town's WWTP. There is a cover letter explaining the
proposed changes. This draft permit will be going to public notice later this week. In accordance
with your previous email we are sending this draft in electronic form only.
Please respond to this email to verify that your received the draft and could open, review and
download the file.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2

8/30/2020
Mail - Bennett, Bradley - Outlook
Email correspondence to and from this address may be subject to public records laws
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/2

8/30/2020
Mail - Bennett, Bradley - Outlook
[External] RE: Transmittal of Permit Documents Electronically
[e-mail] <[e-mail]>
Tue 6/30/2020 10:15 AM
To: Bennett, Bradley <[e-mail]>
Cc: [e-mail] <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to [e-mail]
Hi Bradley,
Electronic transmittal of the Town of Old Fort's permitting documents is acceptable.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W:828-668-4561
M:828-442-2343
--------- Original Message ---------
Subject: Transmittal of Permit Documents Electronically
From: "Bennett, Bradley" <[e-mail]>
Date: 6/30/20 10:06 am
To: "[e-mail]" <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Hi Tony,
We have the draft renewal for your permit ready for public notice. It should go to notice next
week. I wanted to touch base with you about transmittal of documents electronically. I have
also copied Mayor Hensley on this email. As the Responsible Official in our system for the permit
I also wanted him to see this request. Please review the information below and respond to me
as requested below.
In order to provide more convenience, control, and security to our permittees and assist
them in processing their transactions, The Division of Water Resources is currently
transitioning towards electronic correspondence. This will hopefully provide more efficient
service to our permittees and other partners and will allow us to more effectively process
and track documents. We are writing to ask you for your approval of the transmittal of
documents related to your permitting and related activities with the Division in an electronic
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2

8/30/2020 Mail - Bennett, Bradley - Outlook
format. Documents will be emailed to the appropriate contact person(s) in your organization
in a PDF format.
Please respond to me through email with verification that transmittal of your documents in
an electronic manner is acceptable to you. If you have any questions, please feel free to
contact me.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
https:Houtlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/2

Table 1
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
❑ Apply WS Hardness WCC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
CIA (cfs)
1Q10s (cfs)
Effluent Hardness
-------------
Upstream Hardness
Combined Hardness Chronic
-------------
Combined Hardness Acute
Data Source(s)
❑ CHECK TO APPLY MODEL
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Project Information
❑ CHECK IF HQW OR ORW WQS
Old Fort WWTP
Class III
NCO021229
001
0.500
Curtis Creek
0305010101
C; Tr
4.90
7.40
10.50
30.60
4.09 _
71.25 mg/L (Avg)
9.55 mg/L (Avg)
------- 25 mg/L----
------- 25 mg/L---
Par01
Par02
Par03
Par04
Par05
Par06E
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name WQS Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
0.5899
FW
3.2396
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/Li
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
117.7325
FW
905.0818
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
7.8806
FW
10.4720
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
2.9416
FW
75.4871
ug/L
Mercury
Aquatic Life
NCI
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
37.2313
FW
335.2087
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
0.2964
ug/L
Zinc
Aquatic Life
NC
126.7335
FW
125.7052
ug/L
9595 Final FW RPA_NC0021229_2020, input
6/23/2020

H1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
H2
Use 'PASTE SPECIAL
Effluent Hardness Values" then "COPY" Upstream Hardness
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
5/16/2017
74
74
Std Dev.
7/5/2017
89
89
Mean
10/3/2017
90
90
C.V.
1/2/2018
68
68
n
4/3/2018
85
85
10th Per value
7/3/2018
62
62
Average Value
10/2/2018
67
67
Max. Value
1/3/2019
60
60
4/2/2019
65
65
7/2/2019
65
65
10/1/2019
70
70
1/7/2020
60
60
10.9139 1
71.2500 2
0.1532 3
12 4
60.20 mg/L 5
71.25 mg/L 6
90.00 mg/L 7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Date
Data
BDL=1/2DL
Results
7/5/2017
9.5
9.5
Std Dev.
10/3/2017
10
10
Mean
1/2/2018
10
10
C.V.
4/3/2018
10
10
n
7/3/2018
10
10
10th Per value
10/2/2018
7.5
7.5
Average Value
1/8/2019
10
10
Max. Value
4/2/2019
5
5
7/2/2019
9
9
10/1/2019
10
10
1 /7/2020
14
14
Use 'PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
9.5455
0.2252
11
7.50 mg/L
9.55 mg/L
14.00 mg/L
-1-
9595 Final FW RPA_NCO021229_2020, data
6/23/2020

REASONABLE POTENTIAL ANALYSIS
Pall
Copper
Date
Data
BDL=1/2DL
Results
1
1/6/2015
25
25
Std Dev.
2
4/7/2015
60
60
Mean
3
7/7/2015
36
36
C.V.
4
10/6/2015
20
20
n
5
1/5/2016
20
20
6
4/5/2016
21
21
Mult Factor =
7
7/5/2016
31
31
Max. Value
8
1/17/2017
23
23
Max. Fred Cw
9
4/4/2017
26
26
10
5/16/2017
42
42
11
6/6/2017
55
55
12
7/5/2017
38
38
13
8/1/2017
39
39
14
9/5/2017
39
39
15
10/3/2017
30
30
16
11/7/2017
30
30
17
12/5/2017
32
32
18
1/2/2018
30
30
19
2/6/2018
42.3
42.3
20
3/6/2018
35.5
35.5
21
4/3/2018
36
36
22
5/15/2018
25.5
25.5
23
6/12/2018
23.5
23.5
24
7/3/2018
15.3
15.3
25
8/7/2018
17.4
17.4
26
9/4/2018
44.8
44.8
27
10/2/2018
32.1
32.1
28
11/6/2018
22.4
22.4
29
12/4/2018
27.2
27.2
30
12/ 18/2018
14.3
14.3
31
1/3/2019
15.7
15.7
32
2/5/2019
20.2
20.2
33
3/5/2019
21.2
21.2
34
4/2/2019
21.1
21.1
35
5/7/2019
31.9
31.9
36
6/4/2019
46
46
37
7/2/2019
18.9
18.9
38
8/6/2019
27.3
27.3
39
9/3/2019
26.5
26.5
40
10/1/2019
23.2
23.2
41
11/5/2019
49.3
49.3
42
12/ 10/2019
14.5
14.5
43
1/7/2020
20.1
20.1
44
2/4/2020
27.8
27.8
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL7
Values" then "COPY"
. Maximum data
points = 58
29.4773
0.3697
44
1.05
60.00 ug/L
63.00 ug/L
Date Data
1 1 /6/2015 <
2 4/7/2015 <
3 7/7/2015 <
4 10/6/2015 <
5 1 /5/2016 <
6 4/5/2016 <
7 7/5/2016 <
8 10/4/2016 <
9 1/17/2017 <
10 4/4/2017 <
11 7/5/2017 <
12 10/3/2017 <
13 1 /2/2018 <
14 4/3/2018 <
15 7/3/2018
16 10/2/2018 <
17 1 /3/2019 <
18 4/2/2019 <
19 7/2/2019 <
20 10/1/2019 <
21 1 /7/2020 <
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Cyanide
BDL=1/2DL
Results
i 5
Std Dev.
i 5
Mean
i 5
C.V.
i 5
n
i 5
5
Mult Factor =
i 5
Max. Value
i 5
Max. Fred Cw
i 5
i 5
i 5
5
i 5
i 5
i 5
5
i 5
i 5
i 5
i 5
i 5
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
5.00
0.0000
21
1.00
5.0 ug/L
5.0 ug/L
-2-
9595 Final FW RPA_NCO021229_2020, data
6/23/2020

REASONABLE POTENTIAL ANALYSIS
Par15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Mercury
Date
Data
BDL=1/2DL
1 /6/2015
6.13
6.13
4/7/2015
6.48
6.48
7/7/2015
3.38
3.38
10/6/2015
5.03
5.03
1 /5/2016
4.93
4.93
4/5/2016
1.89
1.89
7/5/2016
4.79
4.79
10/18/2016
2.58
2.58
1/17/2017
1.6
1.6
4/4/2017
7.26
7.26
7/5/2017
3.28
3.28
10/3/2017
8.52
8.52
1 /2/2018
6.55
6.55
4/3/2018
4.02
4.02
7/3/2018
3.92
3.92
10/2/2018
4.89
4.89
1 /3/2019
4.62
4.62
4/2/2019
3.49
3.49
7/2/2019
3.1
3.1
10/8/2019
4.13
4.13
1 /7/2020
4.36
4.36
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Results
Std Dev.
1.7410
Mean
4.5214
C.V.
0.3850
n
21
Mult Factor = 1.22
Max. Value 8.5 ng/L
Max. Fred Cw 10.4 ng/L
-3-
9595 Final FW RPA_NCO021229_2020, data
6/23/2020

Old Fort WWTP I Outfall 001
NCO021229 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 0.5 MGD
MAXIMUM
Qw (MGD) =
0.50
1Q10S(cfs)=
4.09
7Q10S (cfs) =
4.90
7Q10W (cfs) =
7.40
30Q2 (cfs) =
10.50
Avg. Stream Flow, QA (cfs) =
30.60
Receiving Stream:
Curtis Creek HUC 0305010101
DATA POINTS = 58
WWTP/WTP Class: Class III
IWC% @ 1Q10S = 15.93011305
TWC% @ 7QIOS = 13.65638767
IWC% @ 7Q10W = 9.480122324
TWC% @ 30Q2 = 6.873614191
IW%C @ QA = 2.470119522
Stream Class: C; Tr
COMBINED HARDNESS (mp-/L)
Acute = 25 mg/L
Chronic = 25 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION
TYPEApplied
J
a
D
Chronic Acute
ri # Det. Max Pred Cw Allowable Cw
Standard
Acute: 65.74
Copper
NC
7.8806 FW(7Q10s) 10.4720
ug; L
44 44
63.00
Chronic: -----57.71--- -------------------------
1 values > Allowable Cw
Acute: 138.1
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
21 1
5.0
Chronic: 36.6
No value > Allowable Cw
Acute: NO WQS
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
21 21
10.4
Chronic: 87.9
No value > Allowable Cw
Acute:
0 0
N/A
Chronic:
Acute:
0 0
N/A
Chronic:
9595 Final FW RPA_NC0021229_2020, rpa
Page 1 of 1 6/23/2020

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
WWTP/WTP Class
NPDES Permit
Outfal I
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
Old Fort WWTP
Class III
NCO021229
001
0.900
Curtis Creek
0305010101
C; Tr
❑ Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1 Q10s (cfs)
4.90
7.40
10.50
30.60
4.09
Effluent Hardness
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
71.25 mg/L (Avg)
I 9.55 mg/L (Avg)
I 25 m /L
I 25.24 m /L
------------
Data Source(s)
❑ CHECK TO APPLY MODEL
Par01
Par02
Par03
Par04
Par05
Par06E
Par07
ParOB
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Part B
Par19
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name WaS Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
0.5899
FW
3.2666
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/L
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
117.7325
FW
912.1554
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
lag/L
Copper
Aquatic Life
NC
7.8806
FW
10.5662
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
2.9416
FW
76.2995
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
37.2313
FW
337.9152
lag/L
Nickel
Water Supply
NC
25.0000
WS
N/A
lag/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
0.3013
ug/L
Zinc
Aquatic Life
NC
126.7335
FW
126.7217
ug/L
9595 Final FW RPA at 0.9_NC0021229_2020, input
6/23/2020

H1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
H2
Use 'PASTE SPECIAL
Effluent Hardness Values" then "COPY" Upstream Hardness
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
5/16/2017
74
74
Std Dev.
7/5/2017
89
89
Mean
10/3/2017
90
90
C.V.
1/2/2018
68
68
n
4/3/2018
85
85
10th Per value
7/3/2018
62
62
Average Value
10/2/2018
67
67
Max. Value
1/3/2019
60
60
4/2/2019
65
65
7/2/2019
65
65
10/1/2019
70
70
1/7/2020
60
60
10.9139 1
71.2500 2
0.1532 3
12 4
60.20 mg/L 5
71.25 mg/L 6
90.00 mg/L 7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Date
Data
BDL=1/2DL
Results
7/5/2017
9.5
9.5
Std Dev.
10/3/2017
10
10
Mean
1/2/2018
10
10
C.V.
4/3/2018
10
10
n
7/3/2018
10
10
10th Per value
10/2/2018
7.5
7.5
Average Value
1/8/2019
10
10
Max. Value
4/2/2019
5
5
7/2/2019
9
9
10/1/2019
10
10
1 /7/2020
14
14
Use 'PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
9.5455
0.2252
11
7.50 mg/L
9.55 mg/L
14.00 mg/L
-1-
9595 Final FW RPA at 0.9 NC0021229 2020, data
6/23/2020

REASONABLE POTENTIAL ANALYSIS
Pall
Copper
Date
Data
BDL=1/2DL
Results
1
1/6/2015
25
25
Std Dev.
2
4/7/2015
60
60
Mean
3
7/7/2015
36
36
C.V.
4
10/6/2015
20
20
n
5
1/5/2016
20
20
6
4/5/2016
21
21
Mult Factor =
7
7/5/2016
31
31
Max. Value
8
1/17/2017
23
23
Max. Fred Cw
9
4/4/2017
26
26
10
5/16/2017
42
42
11
6/6/2017
55
55
12
7/5/2017
38
38
13
8/1/2017
39
39
14
9/5/2017
39
39
15
10/3/2017
30
30
16
11/7/2017
30
30
17
12/5/2017
32
32
18
1/2/2018
30
30
19
2/6/2018
42.3
42.3
20
3/6/2018
35.5
35.5
21
4/3/2018
36
36
22
5/15/2018
25.5
25.5
23
6/12/2018
23.5
23.5
24
7/3/2018
15.3
15.3
25
8/7/2018
17.4
17.4
26
9/4/2018
44.8
44.8
27
10/2/2018
32.1
32.1
28
11/6/2018
22.4
22.4
29
12/4/2018
27.2
27.2
30
12/ 18/2018
14.3
14.3
31
1/3/2019
15.7
15.7
32
2/5/2019
20.2
20.2
33
3/5/2019
21.2
21.2
34
4/2/2019
21.1
21.1
35
5/7/2019
31.9
31.9
36
6/4/2019
46
46
37
7/2/2019
18.9
18.9
38
8/6/2019
27.3
27.3
39
9/3/2019
26.5
26.5
40
10/1/2019
23.2
23.2
41
11/5/2019
49.3
49.3
42
12/ 10/2019
14.5
14.5
43
1/7/2020
20.1
20.1
44
2/4/2020
27.8
27.8
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL7
Values" then "COPY"
. Maximum data
points = 58
29.4773
0.3697
44
1.05
60.00 ug/L
63.00 ug/L
Date Data
1 1 /6/2015 <
2 4/7/2015 <
3 7/7/2015 <
4 10/6/2015 <
5 1 /5/2016 <
6 4/5/2016 <
7 7/5/2016 <
8 10/4/2016 <
9 1/17/2017 <
10 4/4/2017 <
11 7/5/2017 <
12 10/3/2017 <
13 1 /2/2018 <
14 4/3/2018 <
15 7/3/2018
16 10/2/2018 <
17 1 /3/2019 <
18 4/2/2019 <
19 7/2/2019 <
20 10/1/2019 <
21 1 /7/2020 <
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Cyanide
BDL=1/2DL
Results
i 5
Std Dev.
i 5
Mean
i 5
C.V.
i 5
n
i 5
5
Mult Factor =
i 5
Max. Value
i 5
Max. Fred Cw
i 5
i 5
i 5
5
i 5
i 5
i 5
5
i 5
i 5
i 5
i 5
i 5
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
5.00
0.0000
21
1.00
5.0 ug/L
5.0 ug/L
9595 Final FW RPA at 0.9 NC0021229 2020, data
-2- 6/23/2020

REASONABLE POTENTIAL ANALYSIS
Par15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Mercury
Date
Data
BDL=1/2DL
1 /6/2015
6.13
6.13
4/7/2015
6.48
6.48
7/7/2015
3.38
3.38
10/6/2015
5.03
5.03
1 /5/2016
4.93
4.93
4/5/2016
1.89
1.89
7/5/2016
4.79
4.79
10/18/2016
2.58
2.58
1/17/2017
1.6
1.6
4/4/2017
7.26
7.26
7/5/2017
3.28
3.28
10/3/2017
8.52
8.52
1 /2/2018
6.55
6.55
4/3/2018
4.02
4.02
7/3/2018
3.92
3.92
10/2/2018
4.89
4.89
1 /3/2019
4.62
4.62
4/2/2019
3.49
3.49
7/2/2019
3.1
3.1
10/8/2019
4.13
4.13
1 /7/2020
4.36
4.36
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Results
Std Dev.
1.7410
Mean
4.5214
C.V.
0.3850
n
21
Mult Factor = 1.22
Max. Value 8.5 ng/L
Max. Fred Cw 10.4 ng/L
-3-
9595 Final FW RPA at 0.9 NC0021229 2020, data
6/23/2020

Old Fort WWTP I Outfall 001
NCO021229 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 0.9 MGD
MAXIMUM
Qw (MGD) =
0.90
1Q10S(cfs)=
4.09
7Q10S (cfs) =
4.90
7Q10W (cfs) =
7.40
30Q2 (cfs) =
10.50
Avg. Stream Flow, QA (cfs) =
30.60
Receiving Stream:
Curtis Creek HUC 0305010101
DATA POINTS = 58
WWTP/WTP Class: Class III
IWC% @ 1Q10S = 25.43299909
TWC% @ 7Q10S = 22.1604448
IWC% @ 7Q10W = 15.86128482
TWC% @ 30Q2 = 11.72761665
IW%C @ QA = 4.360056259
Stream Class: C; Tr
COMBINED HARDNESS (mp-/L)
Acute = 25.24 mg/L
Chronic = 25 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION
TYPEApplied
J
a
D
Chronic Acute
ri # Det. Max Pred Cw Allowable Cw
Standard
Acute: 41.55
Copper
NC
7.8806 FW(7Q10s) 10.5662
ugL
44 44
63.00
Chronic: -----35.56--- -------------------------
12 values > Allowable Cw
Acute: 86.5
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
21 1
5.0
Chronic: 22.6
No value > Allowable Cw
Acute: NO WQS
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
21 21
10.4
Chronic: 54.2
No value > Allowable Cw
Acute:
0 0
N/A
Chronic:
Acute:
0 0
N/A
Chronic:
9595 Final FW RPA at 0.9_NC0021229 2020, rpa
Page 1 of 1 6/23/2020

8/30/2020
Mail - Bennett, Bradley - Outlook
[External] RE: Transmittal of Permit Documents Electronically
[e-mail] <[e-mail]>
Tue 6/30/2020 10:15 AM
To: Bennett, Bradley <[e-mail]>
Cc: [e-mail] <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to [e-mail]
Hi Bradley,
Electronic transmittal of the Town of Old Fort's permitting documents is acceptable.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W:828-668-4561
M:828-442-2343
--------- Original Message ---------
Subject: Transmittal of Permit Documents Electronically
From: "Bennett, Bradley" <[e-mail]>
Date: 6/30/20 10:06 am
To: "[e-mail]" <[e-mail]>
Cc: "[e-mail]" <[e-mail]>
Hi Tony,
We have the draft renewal for your permit ready for public notice. It should go to notice next
week. I wanted to touch base with you about transmittal of documents electronically. I have
also copied Mayor Hensley on this email. As the Responsible Official in our system for the permit
I also wanted him to see this request. Please review the information below and respond to me
as requested below.
In order to provide more convenience, control, and security to our permittees and assist
them in processing their transactions, The Division of Water Resources is currently
transitioning towards electronic correspondence. This will hopefully provide more efficient
service to our permittees and other partners and will allow us to more effectively process
and track documents. We are writing to ask you for your approval of the transmittal of
documents related to your permitting and related activities with the Division in an electronic
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8/30/2020 Mail - Bennett, Bradley - Outlook
format. Documents will be emailed to the appropriate contact person(s) in your organization
in a PDF format.
Please respond to me through email with verification that transmittal of your documents in
an electronic manner is acceptable to you. If you have any questions, please feel free to
contact me.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
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8/30/2020
Mail - Bennett, Bradley - Outlook
RE: Re: [External] town of old fort wwtp permit renewal NCO021229
[e-mail] <[e-mail]>
Mon 6/15/2020 8:58 AM
To: Bennett, Bradley <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to [e-mail]
Bradley,
We have had one clarifier repaired, so we have two available now. The flow is usually too low for both
clarifiers to operate so we rotate them now (or use them both during and after high flows due to rain
1/1. We still have only one sludge holding tank in operation. This hasn't been a problem for normal
operation, but it does require more planning to paint the existing holding tank. No plans or money
for any repairs that I know of.
The WWTP does a good job handling the flows we receive, high or low, mainly due to the complete
mix 0.6 MG aeration tank (half of the available aeration tank). And even with two breweries coming on
line, we don't anticipate large increases in flows for the near future.
Thanks for your help. Let me know if you have more questions or concerns.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W:828-668-4561
M:828-442-2343
--------- Original Message ---------
Subject: Re: [External] town of old fort wwtp permit renewal NCO021229
From: "Bennett, Bradley" <[e-mail]>
Date: 6/15/20 8:08 am
To: "[e-mail]" <[e-mail]>
Tony,
Back in October you had forwarded this email about components in your treatment system. I
just wanted to make sure that you still want to make adjustments in the permit related to these
items or if there have been any changes to this request. What we can do is to note in the permit
list of of components that these components are currently inactive if you still want to address
this.
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8/30/2020
Mail - Bennett, Bradley - Outlook
Thanks for your help.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
Email correspondence to and from this address may be subject to public records laws
From: [e-mail] <[e-mail]>
Sent: Monday, October 7, 2019 9:06 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Cc: Weaver, Charles <[e-mail]>; Heim, Tim <[e-mail]>
Subject: [External] town of old fort wwtp permit renewal NCO021229
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]
Mr. Bennett,
The Town of Old Fort has submitted its application for its WWTP permit renewal. We would
like to request two changes be made in the permit concerning the components of the
treatment system. Due to financial difficulties, the Town's WWTP now has only one (1)
working 72000 gal sludge storage unit, and only two (2) working clarifiers. The air system for
the sludge holding tank is need of replacement and cannot be used without it. Of the Town's
four clarifiers, one is working, one is scheduled for repair, one is beyond repair and abandoned,
and one could be repaired but there are no plans or funds available to. These difficulties are
due to many years of financial issues and have not been addressed due to other needed
repairs. The Town would appreciate it if these changes could be included in the renewed
permit. If you have any questions, please contact me. Thank you for your help.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W:828-668-4561
M:828-442-2343
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4/7/2020 Mail - Bennett, Bradley - Outlook
RE: Questions on Old Fort
Weaver, Charles <[e-mail]>
Tue 3/31/2020 11:56 AM
To: Bennett, Bradley <[e-mail]>
Yes, it's in the fee statute. I thought I had a copy of that ... but I don't.
Sorry.
CHW
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Tuesday, March 31, 2020 11:39 AM
To: Weaver, Charles <[e-mail]>
Subject: Re: Questions on Old Fort
Is there something in the fee statute that I can point them to about the fee increase? I can pull that up
and check, but thought you might know. I'm sure they will probably want some reference on that.
:.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: brad ley. ben [e-mail]
Email correspondence to and from this address may be subject to public records laws
From: Weaver, Charles <[e-mail]>
Sent: Tuesday, March 31, 2020 11:36 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: RE: Questions on Old Fort
The classification won't change unless their treatment equipment does.
The draft doesn't need to go to EPA — still a minor permit.
CHW
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Tuesday, March 31, 2020 11:35 AM
To: Weaver, Charles <[e-mail]>
Subject: Re: Questions on Old Fort
Couple more questions if I you don't mind.
Would any of this impact their classification?
Would the draft need to go to EPA for review?
Thanks
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2

4/7/2020
Mail - Bennett, Bradley - Outlook
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: brad ley. ben [e-mail]
Email correspondence to and from this address may be subject to public records laws
From: Weaver, Charles <[e-mail]>
Sent: Tuesday, March 31, 2020 11:21 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: RE: Questions on Old Fort
Tell them that their annual fee will change from Minor to Major, because they have PT.
They will remain a minor facility, because their permitted flow is <1 MGD.
They will need to do 3 PPAs over the permit cycle.
You might want to check with Aquatic Tox. They don't have a tox test currently, but they might need one if they
are accepting PT wastewater.
CHW
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Tuesday, March 31, 2020 11:17 AM
To: Weaver, Charles <[e-mail]>
Subject: Questions on Old Fort
Charles,
Okay, Old Fort has a lot of questions but I'll leave it to one basic one for today. Old Fort just had a
brewery in their area that is going to start discharging to their system. They have restarted their pre-
treatment program (Vivian sent an approval last week). So does this impact their current status as a
minor facility since they have PT? I guess I would need to add in the PPA for them? Any other things to
add?
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: brad ley. ben [e-mail]
Email correspondence to and from this address may be subject to public records laws
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4/7/2020 Mail - Bennett, Bradley - Outlook
RE: Permit Renewal Questions
Coco, Nick A <[e-mail]>
Tue 3/31/2020 10:04 AM
To: Bennett, Bradley <[e-mail]>
Bradley,
I'll do my best here:
• The plant is already limited for BOD and TSS at secondary standards' levels. I'd recommend looking into the
history of the permit to see if this is the result of a model (Level B is most likely). If this is the result of a
model, then the facility has been cleared to discharge up to that concentration without having adverse
impacts on DO levels in the stream. As long as the plant can handle the waste stream from the brewery
and maintain BOD and TSS concentrations at or below those levels consistently, while also achieving 85%
removal (per our rules) then they should be ok.
I'd go ahead and add turbidity and DO limits to the permit at the expanded flow, based on the 2B
standards. We consider plant's "grandfathered" into their existing limits in cases like these. Since they are
expanding, we add the limit to the expanded flow tier. We want to make sure we are being protective
though, so I'd definitely recommend adding them.
I'm not entirely sure that the pretreatment program makes them automatically a major. I know they do
have to fill out EPA Form 2A from now on. However, I believe that in our agreement with EPA, drafts for
pretreatment plants do need to be sent to region 4. 1 may be wrong, so I'd recommend checking our MOA.
You will also have to work with PERCS from now on to just get an update on the facility's PT program. We
have a form for this that you fill out and send to PERCS. It's a easy process. Depending on what the PT
program has them sample, you may have additional information for your reasonable potential analysis.
Also, keep in mind the plant's hardness now. Our guidance states that all pretreatment municipalities need
to conduct quarterly hardness sampling both upstream and in their effluent. Lastly, check into how a
pretreatment plant affects facility grade. I believe it's based on flow, but is worth double checking.
I'd really suggest reaching out to Vivien to get her take on everything, but I believe most of this is covered. You
may want to look deeper into whether or not a pretreatment program makes a facility a major.
Hope this helps a little.
-Nick
From: Bennett, Bradley <brad ley. ben nett@ ncden r.gov>
Sent: Tuesday, March 31, 2020 9:33 AM
To: Coco, Nick A <[e-mail]>
Subject: Re: Permit Renewal Questions
Hey Nick,
So here is a little more information on this permit. It is the Town of Old Fort and there are a number of
issues with them. They have an old plant and are only running a portion of it right now. The issues Julie
mentioned to Vivian with the brewery and restart pre-treatment are listed below.
• Main issue with breweries are BOD and TSS. Both are limited by the WWTP design. So my
question is should there be any review of these limits? They are currently at 30 & 45. Which I
think are the municipal levels set in the 2B rules?
• Julie mentioned that Turbidity (10 NTU for TR waters) and DO (>6) could also be considered for
the 0.9 MGD level in the permit. The permit is currently issued for 0.5 MGD and also includes a
0.9 MGD effluent limits page that they can operate at with approval. Neither of these currently
include Turbidity or DO limits.
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4/7/2020 Mail - Bennett, Bradley - Outlook
Last question - with them restarting their pre-treatment program will this permit automatically
now become a Major? If so, what other considerations does that bring? Requirements for PPA?
EPA review, etc?
Thanks for any help you can give. If a call would be easier we can set that up. Julie also told Vivian that
she could discuss this with me. I haven't reached out to her yet.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: brad ley. ben [e-mail]
Email correspondence to and from this address may be subject to public records laws
From: Coco, Nick A <[e-mail]>
Sent: Monday, March 30, 2020 4:15 PM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: Re: Permit Renewal Questions
Hi Bradley,
I'll help as best I can but I'm not entirely sure what considerations Julie would have mentioned, so I may
not be any help at all.
-Nick
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Monday, March 30, 2020 1:51 PM
To: Coco, Nick A <[e-mail]>
Subject: Permit Renewal Questions
Hey Nick. I may want to talk with you sometime soon about a permit renewal I have. They have a
brewery that is going to start discharging to their system and they also just restarted their pre-treatment
program because of this. The pre-treatment group talked with Julie a little about their permit and she
mentioned some things that should probably be considered in the permit renewal and I may want some
input from the NPDES group about this.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: brad ley. ben [e-mail]
Email correspondence to and from this address may be subject to public records laws
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RE: Re: [External] town of old fort (NC0021229) - pretreatment program startup
[e-mail] <[e-mail]>
Wed 3/18/2020 9:58 AM
To: Bennett, Bradley <[e-mail]>
Cc: Heim, Tim <[e-mail]>; Wiggs, Linda <[e-mail]>; Zhong, Vivien <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
HI Bradley,
I'll try to address all of the items from Tim's meeting notes. Any questions, just contact me the most convenient
way.
1. We now have 2 of the 4 clarifiers operational and the splitterbox valves are also all operational. This has
improved our flexibility and capacity.
2. The EQ basin is operational, however it has only one of two pumps operational. It still needs new valves and
check valves. Along with the barscreen refurbishing, this is the next needed repair item.
3. There are 3 of 3 floating aerators operational in one side of the aeration tank (the side currently being used)
and one floating aerator in the other side of the tank. Side 2 has never been needed for treatment. We will need
to purchase replacement aerators but because they are oversized we can function with no problem with two. Each
side is designed for 0.6 MGD, but can realistically treat 0.9 MGD for short periods of time.
4. Using DWR's smoke machine, we found some issues in the sewer system causing I/I. The biggest problems are
3 streets with storm drains tied to the sewer, and a manhole with a large amount of infiltration. Town
maintenance will work on running a camera on the 3 streets and detecting the tie-ins if possible. This will take
weeks/months. The manhole is probably beyond the Town's capability.
5. There currently are no plans for Old Fort Finishing plant, with none in the foreseeable future.
6. One brewery is ready to start up this month. Their estimated discharge is 4000 gpd and in a couple of years
would not grow past 8000 - 10000 gpd if all goes well. They are planning on removing the large majority of
solids from their discharge and giving those to a farmer. With the capacity of our WWTP, I don't foresee their
discharge being a problem especially if we stay alert in monitoring at the plant and the brewery.
7. Another small brewery is planning to start up in fall of 2020, but they will be less than half the size of the first.
While the Town does need to spend money to keep functioning down the road, the work we've just completed
has been a big help and is probably our biggest expense ($200,000) for a while. the other items will be in the
$50,000 range.
I have no engineering data to back my beliefs, but I think the plant as is can treat 0.7 to 0.8 over short periods of
time (a couple of weeks) and less than that with no problem.
I have included Vivien Zhong on this email. If you would please let her know your thoughts on the Town's permit
renewal so we can proceed with Pretreatment program issues. Thank you very much for your help.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762

W:828-668-4561
M:828-442-2343
--------- Original Message ---------
Subject: Re: [External] town of old fort (NC0021229) - pretreatment program startup
From: "Bennett, Bradley" <[e-mail]>
Date: 3/17/20 3:14 pm
To: "[e-mail]" <[e-mail]>
Cc: "Heim, Tim" <[e-mail]>, "Wiggs, Linda" <[e-mail]>
Hey Tony,
Hope you are doing okay in these strange times!
I just wanted to touch base on your email. Thanks for letting me know what is going on. I did want to check
in with you and see if the Town has made any progress looking at some of the issues we discussed back in
January about the Towns treatment system. We have been holding off on work on your permit renewal until
we get some updated information based on those discussions. It will help us to better know how to
structure your permit and be consistent with the treatment system that the Town will actually be operating.
Please take a look at the summary email that Tim Heim emailed out on January 9th and give us some
updates when you can.
In case you need to get in touch, email is the best option for me right now since I am working from home,
but we can possibly set up a call if needed.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: [e-mail] <[e-mail]>
Sent: Monday, March 16, 2020 7:04 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: [External] town of old fort (NC0021229) - pretreatment program startup
CAI, i'ION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hi Bradley,

I'm working with Vivien Zhong in Raleigh PERCS branch as we start up Old Fort's pretreatment program
for a new brewery in town. Hillman Beer is wanting to start discharging this month, so I'm hurrying to
submit everything required to Vivien. She wanted me to let you know what's going on. I know Old Fort's
NPDES permit is being renewed, so if you have any questions please contact me. Thank you for your help.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W: 828-668-4561
M:828-442-2343

DocuSign Envelope ID: 45AF501F-33B1-4595-9653-2242328C5616
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Sent via email ([e-mail])
Mr. Anthony West
Pretreatment Coordinator
Town of Old Fort
38 Catawba Ave.
Old Fort, NC 28762
NORTH CAROLINA
Environmental Quality
March 23, 2020
Subject: Final Approval of Pretreatment Program
Town of Old Fort, NPDES Permit Number: NCO021229
McDowell County
Dear Mr. West:
The Division of Water Resources has received the request, dated March 16, 2020, for the approval of Town
of Old Fort's Pretreatment Program. The Town of Old Fort has successfully completed the required
activities established by the Division's Pretreatment, Emergency Response and Collection Systems (PERCS)
Unit for the development of a Division of Water Resources approved Pretreatment Program. With
consideration of the successful completion of the required activities, the Pretreatment Program for the
Town of Old Fort is approved as of March 23, 2020.
Your NPDES permit contains pretreatment program requirements in Part IV (Special Conditions for
Municipal Facilities) under Section D (Pretreatment Programs) that are an important and enforceable part
of your Delegated Pretreatment Program.
The Town of Old Fort's Pretreatment Program is considered to be a Modified Pretreatment Program.
Modified Pretreatment Programs must send in a Pretreatment Annual Report (PAR) or call to schedule a
meeting with the Division's Pretreatment Staff by March Is' of every year. The compliance status for each
industrial user must be judged for each six-month period (January 1—June 30 and July 1— December 31),
and appropriate enforcement actions initiated in accordance with the Enforcement Response Plan
approved by the Division.
Guidance on Pretreatment Program elements may be found in the Comprehensive Guide and on the
PERCS website. Please refer to our website periodically for program updates and additional information:
https:Hdeg.nc.gov/about/divisions/water-resources/water-resources-permits/peres/pretreatment-
ep rmits.
Please submit the documentations of the Sewer Use Ordinance council adoption no later than May 31,
2020. Please start the short term monitoring the second quarter of 2020 and update the site specific HWA
by June 1, 2021. The due date for IWS is June 1, 2024.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1650 Mail Service Center I Raleigh, North Carolina 27699-1650
mo
m )ry rN c. itiA
o.�ro�em or Ew�����a�:r� �./� 919.707.9000

DocuSign Envelope ID: 45AF501F-33B1-4595-9653-2242328C5616
We look forward to working with the Town of Old Fort in its role as a local control authority of the
pretreatment program. Should the Town require assistance or information regarding Part IV, Section D
of your NPDES permit or implementation of its pretreatment program, then please feel free to call Vivien
Zhong [email: [e-mail]] of the Division's Central Office Pretreatment Staff at (919) 707-
3627, or Tim Heim [email: [e-mail]] of the Division's Asheville Regional Office at (828) 296-
4500.
Sincerely,
E DacuSigned by:
r6l '
8F619B6490D2478...
Jeff Poupart
Water Quality Permitting Section Chief
vz/Old Fo rt_progra m_a pprova I
EC: Mr. David Phillips, EPA Region IV
Central Files (LF)
NPDES Files
PERCS Files
Tim Heim, ARO

RE: Re: [External] town of old fort (NC0021229) - pretreatment program startup
Zhong, Vivien <[e-mail]>
Fri 3/20/2020 12:13 PM
To: Bennett, Bradley <[e-mail]>; Heim, Tim <[e-mail]>; Wiggs, Linda <[e-mail]>
Hi,
I talked with Julie this morning. For breweries the main concerns are BOD and TSS, and both are limited by the
design of the WWTP. As long as the plant are designed to be able to handle them, there should not be a problem.
So I am going to proceed with their pretreatment program.
Julie had also mentioned that the turbidity requirement in trout streams is 10 NTU, and DO should be greater than
6 mg/L according to the 213 rules. You might want to consider adding these requirements at their 0.9 MGD tier. She
also said that she would be happy to discuss with you if needed.
Vivien
From: Zhong, Vivien
Sent: Wednesday, March 18, 2020 11:34 AM
To: Bennett, Bradley <bradley. ben [e-mail]>; Heim, Tim <[e-mail]>; Wiggs, Linda
<[e-mail]>
Subject: RE: Re: [External] town of old fort (NC0021229) - pretreatment program startup
I am down with a phone call. On the pretreatment side, Julie Grzyb told me they would do a RPA including the
industrial data and see whether the downstream is impaired or nutrient sensitive. I don't know the details. I emailed
Julie and John about the issue Monday, have not heard anything back yet.
From: Bennett, Bradley
Sent: Wednesday, March 18, 2020 10:28 AM
To: Heim, Tim <[e-mail]>; Wiggs, Linda <[e-mail]>; Zhong, Vivien <vivien.zhong,@ncdenr.gov>
Subject: Fw: Re: [External] town of old fort (NC0021229) - pretreatment program startup
Hey Guys,
When you get a chance maybe we can talk abut Tony's response and figure how or if we think we can use this in
moving forward with a renewal. Also, I hav never dealt with a pre-treatment permitting process so I'm not sure if
this renewal would in any way hold that up? I would think not and they should be able to move ahead with the pre-
treatment process.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: [e-mail] <[e-mail]>
Sent: Wednesday, March 18, 2020 9:57 AM

To: Bennett, Bradley <bradley. ben [e-mail]>
Cc: Heim, Tim <[e-mail]>; Wiggs, Linda <[e-mail]>; Zhong, Vivien <vivien.zhong,@ncdenr.gov>
Subject: RE: Re: [External] town of old fort (NC0021229) - pretreatment program startup
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[e-mail]
HI Bradley,
I'll try to address all of the items from Tim's meeting notes. Any questions, just contact me the most convenient way.
1. We now have 2 of the 4 clarifiers operational and the splitterbox valves are also all operational. This has improved
our flexibility and capacity.
2. The EQ basin is operational, however it has only one of two pumps operational. It still needs new valves and
check valves. Along with the barscreen refurbishing, this is the next needed repair item.
3. There are 3 of 3 floating aerators operational in one side of the aeration tank (the side currently being used) and
one floating aerator in the other side of the tank. Side 2 has never been needed for treatment. We will need to
purchase replacement aerators but because they are oversized we can function with no problem with two. Each side is
designed for 0.6 MGD, but can realistically treat 0.9 MGD for short periods of time.
4. Using DWR's smoke machine, we found some issues in the sewer system causing I/I. The biggest problems are 3
streets with storm drains tied to the sewer, and a manhole with a large amount of infiltration. Town maintenance will
work on running a camera on the 3 streets and detecting the tie-ins if possible. This will take weeks/months. The
manhole is probably beyond the Town's capability.
5. There currently are no plans for Old Fort Finishing plant, with none in the foreseeable future.
6. One brewery is ready to start up this month. Their estimated discharge is 4000 gpd and in a couple of years would
not grow past 8000 - 10000 gpd if all goes well. They are planning on removing the large majority of solids from
their discharge and giving those to a farmer. With the capacity of our WWTP, I don't foresee their discharge being a
problem especially if we stay alert in monitoring at the plant and the brewery.
7. Another small brewery is planning to start up in fall of 2020, but they will be less than half the size of the first.
While the Town does need to spend money to keep functioning down the road, the work we've just completed has
been a big help and is probably our biggest expense ($200,000) for a while. the other items will be in the $50,000
range.
I have no engineering data to back my beliefs, but I think the plant as is can treat 0.7 to 0.8 over short periods of time
(a couple of weeks) and less than that with no problem.
I have included Vivien Zhong on this email. If you would please let her know your thoughts on the Town's permit
renewal so we can proceed with Pretreatment program issues. Thank you very much for your help.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W: 828-668-4561
M: 828-442-2343
--------- Original Message ---------
Subject: Re: [External] town of old fort (NC0021229) - pretreatment program startup
From: "Bennett, Bradley" <[e-mail]>
Date: 3/17/20 3:14 pm

To: "[e-mail]" <[e-mail]>
Cc: "Heim, Tim" <[e-mail]>, "Wiggs, Linda" <[e-mail]>
Hey Tony,
Hope you are doing okay in these strange times!
I just wanted to touch base on your email. Thanks for letting me know what is going on. I did want to check
in with you and see if the Town has made any progress looking at some of the issues we discussed back in
January about the Towns treatment system. We have been holding off on work on your permit renewal until
we get some updated information based on those discussions. It will help us to better know how to
structure your permit and be consistent with the treatment system that the Town will actually be operating.
Please take a look at the summary email that Tim Heim emailed out on January 9th and give us some
updates when you can.
In case you need to get in touch, email is the best option for me right now since I am working from home,
but we can possibly set up a call if needed.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: [e-mail] <[e-mail]>
Sent: Monday, March 16, 2020 7:04 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: [External] town of old fort (NC0021229) - pretreatment program startup
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hi Bradley,
I'm working with Vivien Zhong in Raleigh PERCS branch as we start up Old Fort's pretreatment program for
a new brewery in town. Hillman Beer is wanting to start discharging this month, so I'm hurrying to submit
everything required to Vivien. She wanted me to let you know what's going on. I know Old Fort's NPDES
permit is being renewed, so if you have any questions please contact me. Thank you for your help.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W: 828-668-4561

From: [e-mail]
To: Bennett, Bradley
Cc: Weaver, Charles; Heim, Tim
Subject: [External] town of old fort wwtp permit renewal NCO021229
Date: Monday, October 7, 2019 9:07:15 AM
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Mr. Bennett,
The Town of Old Fort has submitted its application for its WWTP permit renewal. We would
like to request two changes be made in the permit concerning the components of the treatment
system. Due to financial difficulties, the Town's WWTP now has only one (1) working
72000 gal sludge storage unit, and only two (2) working clarifiers. The air system for the
sludge holding tank is need of replacement and cannot be used without it. Of the Town's four
clarifiers, one is working, one is scheduled for repair, one is beyond repair and abandoned, and
one could be repaired but there are no plans or funds available to. These difficulties are due to
many years of financial issues and have not been addressed due to other needed repairs. The
Town would appreciate it if these changes could be included in the renewed permit. If you
have any questions, please contact me. Thank you for your help.
Tony West
Town of Old Fort Water & Wastewater Treatment
38 Catawba Ave
Old Fort, NC 28762
W: 828-668-4561
M: 828-442-2343

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 IF I 3 I NC0021229 111 12 I 19/07/02 I17
18 [S j 19 L G j 201
211111 I I I I I I II I I I I I I I I I I I I I I I I I
I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating 131 QA
---------------------- Reserved -------------------
671
I 71 I JI 72 I r I
70 Iu it LJ
73 I I 174 751 I I I I I I I80
I I i
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
08:30AM 19/07/02
17/06/01
Old Fort WWTP
Catawba Ave US Hwy 70
Exit Time/Date
Permit Expiration Date
Old Fort NC 28762
12:OOPM 19/07/02
20/01/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Anthony Glenn West/ORC/828-668-4561/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Asley Wooten,60 E Ct St Marion NC 28752//828-652-7121/
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Operations & Maintenance 0 Pollution Prevention 0 Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Date
Timothy H Heim DWR/ARO WQ/828-296-4665/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO021229 I11 121 19/07/02 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Tim Heim of the Asheville Regional Office performed a routine Compliance Evaluation Inspection of the
facility on July 2, 2019. Tony West (ORC) assisted with the records review and facility inspection.
The following items are non -compliant with NPDES Permit NC0021229:
The splitter box between the aeration basins and secondary clarifiers is non -operable. This is a critical
piece of equipment for plant operations and redundancy.
Of the 4 clarifiers listed in the permit, 1 is completely decommissioned (likely un-repairable) and 2 are
non -operable and require significant maintenance. At least one additional clarifier should be restored to
operating condition as soon as is practicable to provide redundancy. While it is recognized that the
facility experiences significantly reduced flow due to loss of industry, the permit description of the
facility should be revised to include only the number of clarifiers that will be operated.
In addition, the following items of significance were noted during the inspection and should be
addressed:
The EQ basin diffuser piping appears to have reached the end of its design life and should be
evaluated for replacement.
While Aeration Basin 1 is operating adequately, the floating aerators appear to have reached the end of
their design life and should be evaluated for replacement. Aeration Basin 2 is not operated as the ORC
states the capacity is not needed. Additionally, the facility should maintain at least one backup aerator.
Page#

Permit: NCO021229 Owner - Facility: Old Fort WWTP
Inspection Date: 07/02/2019 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The facility was generally clean and well organized at the time of the inspection.
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Pump Station - Influent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
0
❑
❑
❑
Is the wet well free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
0
❑
❑
❑
Are float controls operable?
0
❑
❑
❑
Is SCADA telemetry available and operational?
0
❑
❑
❑
Is audible and visual alarm available and operational?
0
❑
❑
❑
Comment:
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Page# 3

Permit: NCO021229 Owner - Facility:
Inspection Date: 07/02/2019 Inspection Type:
Old Fort WWTP
Compliance Evaluation
Secondary Clarifier
Yes No NA NE
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
0
❑
❑
❑
Comment: The above pertain only to the sinale operatina clarifier. Of the 4 clarifiers listed in the Dermit
1 is completely decommissioned (likely un-repairable) and 2 are non -operable and require
significant maintenance. At least one additional clarifier should be restored to operating
condition as soon as is practicable to provide redundancy. While it is recognized that the
facility experiences significantly reduced flow due to loss of industry, the permit description
of the facility should be revised to include only the number of clarifiers that will be operated.
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: The EQ basin diffuser piping appears to have reached the end of its design life and should
be evaluated for replacement.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
E
❑
❑
❑
Are surface aerators and mixers operational?
0
❑
❑
❑
Are the diffusers operational?
❑
❑
0
❑
Is the foam the proper color for the treatment process?
0
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
❑
❑
Page# 4

Permit: NCO021229
Inspection Date: 07/02/2019
Aeration Basins
Owner - Facility: Old Fort WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: While Aeration Basin 1 is operatina adeauatelv. the floatina aerators appear to have reached
the end of their design life and should be evaluated for replacement. Aeration Basin 2 is not
operated as the ORC states the capacity is not needed. Additionally, the facility should
maintain at least one backup aerator.
The ORC stated that the splitter box between the aeration basins and secondary clarifiers is
non -operable. This is a critical piece of equipment for plant redundancy and should be
repaired.
Disinfection -Liquid Yes No NA NE
Is there adequate reserve supply of disinfectant?
0
❑
❑
❑
(Sodium Hypochlorite) Is pump feed system operational?
0
❑
❑
❑
Is bulk storage tank containment area adequate? (free of leaks/open drains)
0
❑
❑
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
Comment:
Page# 5