NC0086070_Fact Sheet_20201207

FACT SHEET FOR EXPEDITED PERMIT RENEWALS
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).
Basic Information for Expedited Permit Renewals
Permit Writer / Date
Brianna Young 12/7/2020
Permit Number
NCO086070
Facility Name / Facility Class
Western Justice Academy WWTP / WW-2
Basin Name / Sub -basin number
French Broad / 04-03-02
Receiving Stream / HUC
Lewis Creek / 060101050302
Stream Classification / Stream Segment
C; Tr / 6-55-11-6
Does permit need Daily Maximum NH3
limits?
Already present
Does permit need TRC limits/language?
Alread resent
Does permit have toxicity testing? IWC (%) if
so
N/A
Does permit have Special Conditions?
No
Does permit have instream monitoring?
Yes — fecal coliform, DO, temperature
Is the stream impaired on 303 d list)?
Yes - Benthos
Any obvious compliance concerns?
See Section 2 — numbers flow frequency
violations but all occurred during 1 month
Any permit mods since lastpermit?
None
New expiration date
11/30/2025
Comments on Draft Permit?
None
Section 1. Facility Overview:
Henderson County Utilities operates a WWTP with a permitted discharge of 0.010 MGD
and up to 0.030 MGD. This discharge is 100% domestic wastewater serving a school of
80 staff and students. The facility generates a continuous discharge. This facility utilizes
the following treatment technology:
• Bar screen and pumps
• Inlet flow control splitter box
• Flow equalization basin (7,300 gallon)
• Dual aeration basins (53,000 gallons total) designed to operate in series or parallel
with dual (250 scfm) blowers
• Dual clarifiers (2,430 gallons each) with return sludge
• Pre -filter tablet chlorinator
• Dual multi -media (sand & anthracite) tertiary filters (with a minimum of 10 sq ft
each)
• Clearwell (3,124 gallon)
• Post aeration with audible and visual alarms
• Continuous recording flow meter
Page 1 of 9

• Tablet chlorinator
• Chlorine contact chamber (625 gallon)
• Tablet dechlorinator
• Composite sampler
• Aerobic digester (5,000 gallon)
• Effluent pump station
With the renewal application, Henderson County is requesting to revise the NPDES
permit to allow the first -tier [A(1)] limits to be enforced until monthly flows exceed 0.01
MGD in 4 consecutive months, after which the second -tier [A(2)] limits would be
enforced. Per the permittee:
• Between April and June 2017 monthly average daily flows at the facility
exceeded 0.01 MGD. This far exceeded recorded average daily flows before and
since this period as demonstrated in Daily Monitoring Reports (DMRs). It was
determined that the elevated flow for this period was due to a combination of flow
meter errors and increased flow due to major events occurring on the JCA
campus. These issues have been addressed and future elevated flows are not
anticipated.
• After monthly average flows exceeded 0.01 MGD in three consecutive months
between April and June 2017, NCDEQ began reviewing the plant's historical flow
data and decided to enforce the second -tier permit starting July 2017. Although
average monthly flows have not exceeded 5,000 gpd since July 2017, the NPDES
permit does not revert to lower flow limits once the 10,000 gpd threshold is
passed.
• On Friday November 8, 2019 McGill Associates, on behalf of Henderson County,
met with DEQ staff at the Asheville Regional office. The DEQ Asheville
Regional Office was in support of changing the plant' s permit.
A review of DMR data shows a monthly average flow of approximately 0.00374 MGD
from September 2017 through August 2020. The monthly average flow from April 2017
and June 2017 was approximately 0.01465 MGD. Based on information available, DWR
agrees with the permittee's request to reinstitute the 0.010 MGD effluent table.
Section 2. Compliance History (October 2015 — October 2020):
• 1 NOV for BOD weekly avg exceedance
• 2 NOVs for flow monthly avg exceedances
• 1 NOV for ammonia nitrogen weekly avg exceedance
• 1 NOV for ammonia nitrogen monthly avg exceedance
• 1 NOV for TRC frequency violation
• 9 NOVs for flow frequency violations
Page 2 of 9

303(d) listing:
J �ewiaCreek
source to Clear Creek
issificafion r,Tr Length or Area II 4 units FW Miles Previous AU Numher
t Criteria Status Reason for Rating Parameter of Interest A Category
Criteria Fair Renthos (Nor, AL, FW)
Criteria Fair Renthos Mar, AL, FWI
Ammonia nitrogen evaluation:
Per 15A NCAC 02B .0404(c), winter limits shall not be more than 2 times those of
summer limits. The current permit contains ammonia nitrogen limits for winter
(November 1 - March 31) that are greater than 2 times those for summer (April 1 -
October 31). A review of discharge monitoring data from November 2015 to August
2020 shows that the permittee will be able to meet stricter limits in winter a majority of
the time. As such, the ammonia nitrogen limits for winter will be reduced per 15A NCAC
02B .0404(c).
Winter (November 1 - March 31) ammonia nitrogen data from November 1, 2015
through March 31, 2020:
• Maximum daily value = 5 mg/L
• Minimum daily value = < 0.1 mg/L
• Average daily value = 0.16 mg/L
Current permit limits:
Monthly Avg
Weekly Avg
NH3 as N C0610
(April 1 - October 31
7.0 mg/L
18.0 mg/L
NH3 as N C0610
November 1 - March 31
20.0 mg/L
35.0 mg/L
Proposed permit limits:
Monthly Avg
Weekly Avg
NH3 as N C0610
(April 1 - October 31
7.0 mg/L
18.0 mg/L
NH3 as N C0610
November 1 - March 31
14.0 mg/L
35.0 mg/L
Per WLA:
• If Allowable Conc > 35 mg/l, Monitor Only
• Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
• Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
Section 3. Changes from previous permit to draft:
• Updated eDMR footnote in A(1) and A(2) and language in A(3)
Page 3 of 9

• Updated outfall map
• Added facility grade in A(1) and A(2)
• Updated winter ammonia nitrogen monthly avg limit in A(1) per 15A NCAC 02B
.0404(c)
Section 4. Changes from draft to final:
• Updated language in A(3)
Section 5. Comments received on draft permit:
• None
Page 4 of 9

NPDES Implementation of Instream Dissolved Metals Standards - Freshwater
Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by
the NC Environmental Management Commission (EMC) on November 13, 2014. The
US EPA subsequently approved the WQS revisions on April 6, 2016, with some
exceptions. Therefore, metal limits in draft permits out to public notice after April 6,
2016 must be calculated to protect the new standards - as approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/l
(Dissolved)
Chronic FW,
µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW,
µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form.
Aquatic life standards for Mercury and selenium are still expressed as Total
Recoverable Metals due to bioaccumulative concerns (as are all human health
standards for all metals). It is still necessary to evaluate total recoverable aquatic
life and human health standards listed in 15A NCAC 213.0200 (e.g., arsenic at 10
µg/1 for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for
aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise
under 15A NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, /1
Cadmium, Acute
WER* 11. 136672-[ln hardness] (0.04183 8)1 e^{0.9151 [In hardness]-3.14851
Cadmium, Acute Trout waters
WER* {1. 136672-[ln hardness] (0.041838)} e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[1n hardness] (0.041838)} e^{0.7998[ln hardness]-4.4451}
Chromium III, Acute
WER*0.316 e^{0.8190[ln hardness]+3.72561
Chromium III, Chronic
WER*0.860 e^{0.8190[ln hardness]+0.68481
Page 5 of 9

Copper, Acute
WER*0.960 e^{0.9422[ln hardness]-1.7001
Copper, Chronic
WER*0.960 e^{0.8545[ln hardness]-1.7021
Lead, Acute
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-1.4601
Lead, Chronic
WER*11.46203-[ln hardness](0.145712)} • ell {1.273[In hardness]-4.705}
Nickel, Acute
WER*0.998 e^{0.8460[ln hardness]+2.2551
Nickel, Chronic
WER*0.997 e^{0.8460[ln hardness]+0.05841
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.591
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards.
However, application of the dissolved and hardness -dependent standards requires
additional consideration in order to establish the numeric standard for each metal of
concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream
(upstream) hardness and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR
122.45(c). The discharge -specific standards must be converted to the equivalent total
values for use in the RPA calculations. We will generally rely on default translator values
developed for each metal (more on that below), but it is also possible to consider case -
specific translators developed in accordance with established methodology.
RPA Permitting Guidance/WQBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each
metal of concern, based on recent effluent data, and calculate the allowable effluent
concentrations, based on applicable standards and the critical low -flow values for the
receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or
acute), the discharge has reasonable potential to exceed the standard, which warrants a
permit limit in most cases. If monitoring for a particular pollutant indicates that the
pollutant is not present (i.e. consistently below detection level), then the Division may
remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit
Writer compiles the following information:
Page 6 of 9

• Critical low flow of the receiving stream, 7Q10 (the spreadsheet
automatically calculates the 1 Q 10 using the formula 1 Q 10 = 0.843
(s7Q I0, CfS) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of
concern and for each individual discharge, the Permit Writer must first determine
what effluent and instream (upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test
results for any hardness data and contacts the Permittee to see if any additional
data is available for instream hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial
evaluation using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)).
Minimum and maximum limits on the hardness value used for water quality
calculations are 25 mg/L, and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal
showing reasonable potential, the permit writer contacts the Permittee and
requests 5 site -specific effluent and upstream hardness samples over a period of
one week. The RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as
follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) x (s7Q10, cfs *Avg. Upstream
Hardness, m_/g_L)
(Permitted Flow, cfs + s7Q 10, cfs)
The Combined Hardness for acute is the same but the calculation uses the IQ 10
flow.
3. The permit writer converts the numeric standard for each metal of concern to a
total recoverable metal, using the EPA Default Partition Coefficients (DPCs) or
site -specific translators, if any have been developed using federally approved
methodology.
Page 7 of 9

EPA default partition coefficients or the "Fraction Dissolved" converts the
value for dissolved metal at laboratory conditions to total recoverable metal
at in -stream ambient conditions. This factor is calculated using the linear
partition coefficients found in The Metals Translator: Guidance for
Calculating a Total Recoverable Permit Limit from a Dissolved Criterion
(EPA 823-B-96-007, June 1996) and the equation:
Cdiss = I
Ctotal I + { [Kpo] [SS(I+a)] [10-6] }
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L
used, and
Kpo and a = constants that express the equilibrium relationship between
dissolved and adsorbed forms of metals. A list of constants used for each
hardness -dependent metal can also be found in the RPA program under a
4. The numeric standard for each metal of concern is divided by the default partition
coefficient (or site -specific translator) to obtain a Total Recoverable Metal at
ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist
(ie. silver), the dissolved numeric standard for each metal of concern is divided by
the EPA conversion factor to obtain a Total Recoverable Metal at ambient
conditions. This method presumes that the metal is dissolved to the same extent as
it was during EPA's criteria development for metals. For more information on
conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total
allowable concentration (permit limits) for each pollutant using the following
equation:
Ca = (s7Q10 + Qw) (Cwgs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3*
(µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity
and human health through the consumption of water, fish, and shellfish from
noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background
concentrations
Flows other than s7Q 10 may be incorporated as applicable:
IQ 10 = used in the equation to protect aquatic life from acute toxicity
Page 8 of 9

QA = used in the equation to protect human health through the
consumption of water, fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each
pollutant of concern. Data entered must have been taken within four and one-half
years prior to the date of the permit application (40 CFR 122.21). The RPA
spreadsheet estimates the 95th percentile upper concentration of each pollutant.
The Predicted Max concentrations are compared to the Total allowable
concentrations to determine if a permit limit is necessary. If the predicted max
exceeds the acute or chronic Total allowable concentrations, the discharge is
considered to show reasonable potential to violate the water quality standard, and
a permit limit (Total allowable concentration) is included in the permit in
accordance with the U.S. EPA Technical Support Document for Water Quality -
Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules
in accordance with the EPA Headquarters Memo dated May 10, 2007 from James
Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent
chromium and hexavalent chromium Water Quality Standards. As a cost savings
measure, total chromium data results may be used as a conservative surrogate in
cases where there are no analytical results based on chromium III or VI. In these
cases, the projected maximum concentration (95th %) for total chromium will be
compared against water quality standards for chromium III and chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the
discharge, are inserted into all permits with facilities monitoring for hardness -
dependent metals to ensure the accuracy of the permit limits and to build a more
robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this
permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness
No RPA necessary
(mg/L)
N/A
Total as, CaCO3 or Ca+M
Average Upstream Hardness
No RPA necessary
(mg/L)
N/A
[Total as, CaCO3 or Ca+M ]
7Q10 summer cfs
N/A
No RPA necessary
1 10 cfs
N/A
No RPA necessary
Permitted Flow MGD
N/A
No RPA necessary
Page 9 of 9

STATE OF NORTH CAROLINA
HENDERSON COUNTY
CERTIFICATION OF PUBLICATION
I, Kathy Biltoft, affirming the following under the penalties of perjury
state:
I am employed by Times -News, an affiliate of Gatehouse Media, The
Times -News is a daily newspaper of general circulation published in the
city of Hendersonville, county of Henderson, and state of North
Carolina. I hereby certify that the advertisement annexed hereto was
published in the editions of The Times -News on the following date or
dates:
And that the said newspaper in which such notice, paper, document, or
legal advertisement was published was, at the time of each and every
publication, a newspaper meeting all of the requirements and
qualifications of Section 1-597 of the General Statutes of North Carolina
and was a qualified newspaper within the meaning of Section 1-597 of
the General Statutes of North Carolina.
i A
(Signed)
Kathy Biltoft
Swom to and subscribed before me,
t, day of November. 2020.
NlandyHbgsed 1
Notary Public for outh Carolina
My commission expires on: September 91", 2025
This document was notarized in South Carolina
_ i•a ptOTARy m'': c
a 1 pUBLiG f ? z
;ter`•. y `�:
fill
SOUT11'11G�P�``�`
10,31, 2020 I
106 Henderson Crossing Plaza • Hendersonville, NC 28 992
P. O. Box 490 • Hendersonville, NC 28793
828/692-0505 • FAX [phone] • 828/693-5581
www. blueridcenow. com

NH3/TRC WLA Calculations
Facility: Western Justice Academy WWTP
PermitNo. NC0086070
Prepared By: Brianna Young
Enter Design Flow (MGD): 0.01
Enter s7Q10 (cfs): 2
Enter w7Q10 cfs : 2.9
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
2
s7Q10 (CFS)
2
DESIGN FLOW (MGD)
0.01
DESIGN FLOW (MGD)
0.01
DESIGN FLOW (CFS)
0.0155
DESIGN FLOW (CFS)
0.0155
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
0.77
IWC (%)
0.77
Allowable Conc. (ug/1)
2211
Allowable Conc. (mg/1)
101.6
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
2.9
Monthly Average Limit:
200/100ml DESIGN FLOW (MGD)
0.01
(If DF >331; Monitor)
DESIGN FLOW (CFS)
0.0155
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
130.03 Upstream Bkgd (mg/1)
0.22
IWC (%)
0.53
Allowable Conc. (mg/1)
297.4
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Weaver, Charles
From: Boss, Daniel J
Sent: Wednesday, October 23, 2019 2:27 PM
To: Weaver, Charles
Subject: RE: tiered permit for the Western Justice Academy
Thanks Charles,
That's a good point about the flow meter argument, it's a double edged sword.
Daniel Boss
Environmental Specialist- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
From: Weaver, Charles
Sent: Wednesday, October 23, 2019 2:25 PM
To: Boss, Daniel J <[e-mail]>
Subject: RE: tiered permit for the Western Justice Academy
Dan — have them request the tiered flow arrangement with their permit renewal application. We might be able to re-
insert the lower flow at renewal, but not before then.
Also, the "maybe the flow meter was wrong" argument goes both ways — what if they've been under -reporting flow for
all this time, due to a faulty meter? If McGill thinks the meter was malfunctioning, they'd better be sure it's working
before they ask for a lower flow tier.
CHW
From: Boss, Daniel J
Sent: Wednesday, October 23, 2019 11:19 AM
To: Weaver, Charles <[e-mail]>
Subject: tiered permit for the Western Justice Academy
Hi Charles,
Western Justice Academy, NC0086070 has a tiered permit that is triggered when the monthly flow average gets above
0.010 MGD. That did happen April -June of 2017, but those months are definitely outliers and there is some question as
to whether the flow meter may have malfunctioned.
Julia Byrd from McGill Associates called asking me if there was any way to get the facility back under the lower flow
limits, since it has been two years without any flows close to April -June of 2017. 1 know that the permit is clear that
once the monthly flow average exceeds 0.010MGD then the tighter limits are supposed to be in effect until the permit

expiration, but as I said the high flows in spring of 2017 seem to be outliers and Julia seemed to believe the flow meter
may have been malfunctioning.
Thanks for any input/advice you can give.
Daniel Boss
Environmental Specialist- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778

MONITORING REPORT(MR) VIOLATIONS for:
Report Date:
10/13/2C Page
1 of 2
Permit:
nc0086070
MRS Betweel 0 - 2015 and10 - 2020
Region:
%
Violation Category:%
Program Category:
Facility Name: %
Param Nam(%
County:
%
Subbasin: %
Violation Action: %
Major Minor:
%
PERMIT: NCO086070
FACILITY: Henderson County Utilities -Western Justice Academy
COUNTY: Henderson
REGION: Asheville
WWTP
Limit Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT
OUTFALL
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
06 - 2019
001
Effluent
BOD, 5-Day (20 Deg. C) -
06/08/19
Weekly
mg/I
7.5 9.9
32
Weekly Average
Proceed to NOV
Concentration
Exceeded
04 - 2017
001
Effluent
Flow, in conduit or thru
04/30/17
Continuous
mgd
0.01 0.012
18.7
Monthly Average
Proceed to NOV
treatment plant
Exceeded
05-2017
001
Effluent
Flow, in conduit or thru
05/31/17
Continuous
mgd
0.01 0.015
48.4
Monthly Average
Proceed to NOV
treatment plant
Exceeded
10-2017
001
Effluent
Nitrogen, Ammonia Total (as
10/21/17
Weekly
mg/I
6 7.9
31.7
Weekly Average
Proceed to NOV
N) - Concentration
Exceeded
10-2017
001
Effluent
Nitrogen, Ammonia Total (as
10/31/17
Weekly
mg/I
2 2.04
1.9
Monthly Average
Proceed to NOV
N) - Concentration
Exceeded
Monitoring Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT
OUTFALL
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
11 -2016
001
Effluent
Chlorine, Total Residual
11/05/16
2 X week
ug/I
Frequency Violation
Proceed to NOV
10 -2015
001
Effluent
Flow, in conduit or thru
10/03/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
10 -2015
001
Effluent
Flow, in conduit or thru
10/04/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
10 -2015
001
Effluent
Flow, in conduit or thru
10/10/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
10 -2015
001
Effluent
Flow, in conduit or thru
10/11/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
10 -2015
001
Effluent
Flow, in conduit or thru
10/17/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
10 -2015
001
Effluent
Flow, in conduit or thru
10/18/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
10 -2015
001
Effluent
Flow, in conduit or thru
10/24/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant

MONITORING REPORT(MR) VIOLATIONS for:
Report Date:
10/13/2C Page
2 of 2
Permit: nc0086070
MRS Betweel 0 - 2015 ancI10 - 2020
Region:
%
Violation Category:%
Program Category: %
Facility Name: %
Param Nam(%
County:
%
Subbasin: %
Violation Action: %
Major Minor: %
PERMIT: NCO086070
FACILITY: Henderson County Utilities -Western Justice Academy
COUNTY: Henderson
REGION: Asheville
WWTP
Monitoring Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT OUTFALL
LOCATION PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
10 -2015 001
Effluent Flow, in conduit or thru
10/25/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
10-2015 001
Effluent Flow, in conduit orthru
10/31/15
Continuous
mgd
Frequency Violation
Proceed to NOV
treatment plant
Reporting Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT OUTFALL
LOCATION PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
11 -2016
12/31/16
Late/Missing DMR
No Action, Facility
Reporting Error
02-2017
03/31/17
Late/Missing DMR
No Action, Facility
Reporting Error

From: Boss, Daniel J
Sent: Wednesday, October 23, 2019 2:27 PM
To: Weaver, Charles
Subject: RE: tiered permit for the Western Justice Academy
Thanks Charles,
That's a good point about the flow meter argument, it's a double edged sword.
Daniel Boss
Environmental Specialist- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
From: Weaver, Charles
Sent: Wednesday, October 23, 2019 2:25 PM
To: Boss, Daniel J <[e-mail]>
Subject: RE: tiered permit for the Western Justice Academy
Dan — have them request the tiered flow arrangement with their permit renewal application. We might
be able to re-insert the lower flow at renewal, but not before then.
Also, the "maybe the flow meter was wrong" argument goes both ways — what if they've been under-
reporting flow for all this time, due to a faulty meter? If McGill thinks the meter was malfunctioning,
they'd better be sure it's working before they ask for a lower flow tier.
CHW
From: Boss, Daniel J
Sent: Wednesday, October 23, 2019 11:19 AM
To: Weaver, Charles <[e-mail]>
Subject: tiered permit for the Western Justice Academy
Hi Charles,
Western Justice Academy, NCO086070 has a tiered permit that is triggered when the monthly flow
average gets above 0.010 MGD. That did happen April -June of 2017, but those months are definitely
outliers and there is some question as to whether the flow meter may have malfunctioned.
Julia Byrd from McGill Associates called asking me if there was any way to get the facility back under the
lower flow limits, since it has been two years without any flows close to April -June of 2017. I know that
the permit is clear that once the monthly flow average exceeds 0.01OMGD then the tighter limits are
supposed to be in effect until the permit expiration, but as I said the high flows in spring of 2017 seem to
be outliers and Julia seemed to believe the flow meter may have been malfunctioning.
Thanks for any input/advice you can give.
Daniel Boss
file:///C/... OJustice%20Academy%20WWTP/RE%20tiered%20permit%20for%20the%20Western%20Justice%20Academy_Oct%202019.txt[12/7/2020 12:38:25 PM]

Environmental Specialist- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
file:///C/... OJustice%20Academy%20WWTP/RE%20tiered%20permit%20for%20the%20Western%20Justice%20Academy_Oct%202019.txt[12/7/2020 12:38:25 PM]

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Henderson County Utilities
Attn: Marcus Jones
191 Transfer Sta Dr
Hendersonvlle, NC 28791
Subject: Permit Renewal
Application No. NCO086070
Western Justice Academy WWTP
Henderson County
Dear Applicant:
NORTH CAROLINA
Environmental Quality
August 31, 2020
The Water Quality Permitting Section acknowledges the August 28, 2020 receipt of your permit renewal application and
supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting
branch. Per G.S. 150B-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deg.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
Sinc rely,
Wren The ford
Administrative Assistant
Water Quality Permitting Section
cc: Deborah Johnston -Johnston Environmental
ec: WQPS Laserfiche File w/application
\ North Cara ra Departrrert of Ewronm9atal Quo;Ry I D vson of Water Resou saes
D E I Ashev e Fi _gona� Off co- 1 2090 U.S. 70 Hghwa}- I Swar.pan oe, North Carona 28778

August 27, 2020
Ms. Wren Thedford
NCDEQ / DWR / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Renewal
Western Justice Academy WWTP
Edneyville, Henderson County, NC
Dear Ms. Thedford,
-JOHNSTON
EnuiRonmEnTflL
5 Squirrel Trail Court
Hendersonville, NC 28791
wwtiv.johnstonenv.corn
RECEIVED
AUG 2 8 2020
NCDEQ. DI v ;°y ODES
Johnston Environmental, PLLC (JE), on behalf of'Henderson County is submitting this National
Pollutant Discharge Elimination System (NPDES) permit renewal for the Western Justice
Academy'wastewater treatment plant (WJA WWTP). WJA WWTP currently discharges under
Permit NC0086070 which expires November 30, 2020.
In 2011, the North Carolina Department of Environmental Quality (NCDEQ) Division of Water
Resources (DWR) issued a modified NPDES permit to the WJA WWTP with a second -tier of
effluent limits and monitoring requirements (Part I A. (2)) which would take effect when
monthly average flows exceed 0.01 million gallons per day (MGD). The second -tier
requirements impose lower and seasonal effluent limits for monthly and weekly average BOD;
and ammonia (NH3 as N).
Between April and June 2017 monthly average daily flows at the facility exceeded 0.01 MGD.
This far exceeded recorded average daily flows before and since this period as demonstrated in
Daily Monitoring Reports (DMRs). It was determined that the elevated flow for this period was
due to a combination of flow meter errors and increased flow due to major events occurring on
the JCA campus. These issues have been addressed and future elevated flows are not
anticipated.
After monthly average flows exceeded 0.01 MGD in three consecutive months between April
and June 2017, NCDEQ began reviewing the plant's historical flow data and decided to enforce
the second -tier permit starting July 2017. Although average monthly flows have not exceeded
5,000 gpd since July 2017, the NPDES permit does not revert to lower flow limits once the
10,000 gpd threshold is passed.
On Friday November 8, 2019 McGill Associates, on behalf of Henderson County, met with
Environmental Specialist, Daniel Boss and Regional Engineer, Tim Heim of NCDEQ Water
Resources — Water Quality Regional Operations at the Asheville Regional NCDEQ office. The
DEQ Asheville Regional Office was in support of changing the plant's permit to revert to the
permit limits associated with flows under 0.01 MGD at permit renewal.
1

Henderson County is requesting to revise the NPDES permit to allow the first -tier Part A (1)
limits to be enforced until monthly flows exceed 0.01 MGD in consecutive 4 months. By then the
second -tier permit requirements would be enforced. These effluent limits are outlined in Table 1.
Table 1. NPDES Discharge Permit Requirements
Parameters Monthly Weekly- Daily Maximum
First -Tier, 0.01 MGD
Flow (MGD)
0.010
BOD5 (mg/L)
30.0
45.0
Total Suspended Solids, TSS
(mg/L)
30.0
45.0
NH3 as N- Summer (mg/L)
7.0
18.0
NH3 as N- Winter (mg/L)
20.0
35.0
pH (s.u.)
-
-
6.0-9.0
Coliform, Fecal (#/100 ml)
200
400
Total Residual Chlorine (µg/L)
-
-
28
Second-Tier,'0.03
MGD
Flow (MGD)
0.030
BOD5 - Summer (mg/L)
5.0
7.5
BOD5 — Winter (mg/L)
10.0
15.0
TSS (mg/L)
30.0
45.0
NH3 as N- Summer (mg/L)
2.0
6.0
NH3 as N- Winter (mg/L)
4.0
12.0
pH (s.u.)
6.0-9.0
Coliform, Fecal (#/100 ml)
200
400
Total Residual Chlorine (µg/L)
-
-
28
Sludge Management
The WJA WWTP builds sludge slowly, due to the low influent flow. Sludge accumulation is.
monitored by the facility ORC and wasted to the digester to optimize facility operation. As the
need for sludge removal becomes apparent, sludge will be wasted to the digester where it will be
in the digester, the sludge is reduced and thickened for cost effective hauling. The sludge is
removed under an annual contract by Mike's Septic (828-775-1658) and transported to MSD of
Buncombe County waste treatment facility for disposal and the cost is paid by Henderson
County. Should the flow (and sludge generation) increase at this facility, the permittee will
respond by increasing the frequency in hauling.
Sincerely,
Sion
Deborah T. Johnston, PE
Johnston Environmental
2

NPDES APPLICATION - FORM D
For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD
HMail the complete application to:
NC DEQ / DWR / NPDES
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit C0086070
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Henderson County
Western Justice Academy WWTP
3973 Chimney Rock Rd
Edneyville
NC 28791
[phone]
[phone]
[e-mail]
2. Location of facility producing discharge:
Check here if same address as above
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
Name of the firm, public organization or other entity that operates the facility. (Note that this is not
referring to the Operator in Responsible Charge or ORC)
Name
Jones Environmental
Mailing Address
45 Pleasant Court
City
Flat Rock
State / Zip Code
NC 28731
Telephone Number
[phone]
Fax Number
( )
e-mail Address
[e-mail]
1 of 4 Form-D 6/2017

NPDES APPLICATION - FORM D
For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD
4. Description of wastewater:
Facility Generating Wastewater (check all that apply):
Industrial
❑
Number of Employees
Commercial
❑
Number of Employees
Residential
❑
Number of Homes
School
®
Number of Students/Staff 80
Other
❑
Explain:
Describe the source(s) of wastewater (example: subdivision, mobile home park, shopping centers,
restaurants, etc.):
Wastewater flows from the residence hall and campus buildings to the WWTP. The campus buildings
include nine classrooms, a crime lab, an administration building, a gymnasium, a cafeteria, and an
indoor firing range.
Number of persons served: avg 80
5. Type of collection system
® Separate (sanitary sewer only)
6. Outfall Information:
Number of separate discharge points 1
Outfall Identification number(s) 001
❑ Combined (storm sewer and sanitary sewer)
Is the outfall equipped with a diffuser? ❑ Yes ® No
7. Name of receiving stream(s) (NEW applicants: Provide a map showing the exact location of each
outfall):
Lewis Creek
8. Frequency of Discharge: ® Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs: 7 Duration: continuous
9. Describe the treatment system
List all installed components, including capacities, provide design removal for BOD, TSS, nitrogen and
phosphorus. If the space provided is not sufficient, attach the description of the treatment system in a
separate sheet of paper.
The major components of the 0.030 MGD extended aeration facility are as follows:
■ Bar screen and pumps
• Inlet flow control splitter box
■ Flow equalization basin (7,300 gallon)
■ Dual aeration basins (53,000 gallons total) designed
to operate in series or parallel with dual (250 scfm)
blowers
■ Dual clarifiers (2,430 gallons each) with return sludge
■ Pre -filter tablet chlorinator
2 of 4 Form-D 6/2017

NPDES APPLICATION - FORM D
For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD
■ Dual multi -media (sand & anthracite) tertiary
filters (with a minimum of 10 sq ft each)
■ Clearwell (3,124 gallon)
■ Post aeration with audible and visual alarms
■ Continuous recording flow meter
• Tablet chlorinator
■ Chlorine contact chamber (625 gallon)
■ Tablet dechlorinator
■ Composite sampler
■ Aerobic digester (5,000 gallon)
■ Effluent pump station.
The monthly average effluent BOD & Total Suspended Residue concentrations shall not exceed
15% of the respective influent value (85% removal).
10. Flow Information:
Treatment Plant Design flow .030 MGD
Annual Average daily flow .003 MGD (for the previous 3 years)
Maximum daily flow .023 MGD (for the previous 3 years)
11. Is this facility located on Indian country?
❑ Yes ® No
12. Effluent Data
NEW APPLICANTS: Provide data for the parameters listed. Fecal Coliform, Temperature and pH shall be grab
samples, for all other parameters 24-hour composite sampling shall be used. If more than one analysis is reported,
report daily maximum and monthly average. If only one analysis is reported, report as daily maximum.
RENEWAL APPLICANTS: Provide the highest single reading (Daily Maximum) and Monthly Average
nuer the nest .36 months fnr rnnrnmPters r:jrrPnthi in unvr r omit Mnrk nthor rnnrnmotorc "N/A"
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BOD5)
9.9
1.6
Mg/L
Fecal Coliform
12
1
#COL/ 100ml
Total Suspended Solids
5.2
2.6
Mg/L
Temperature (Summer)
21
20.6
C
Temperature (Winter)
3
7
C
pH
7.8
7.1
SU
13. List all permits, construction approvals and/or applications:
Type Permit Number Type
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA)
NPDES
PSD (CAA)
Non -attainment program (CAA)
NC000086070
Ocean Dumping (MPRSA)
Dredge or fill (Section 404 or CWA)
Other
Permit Number
3 of 4 Form-D 6/2017

NPDES APPLICATION - FORM D
For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD
14. APPLICANT CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Printed name of Person Signing Title
Signature of
to
North Carolina Ge ral Statute 143-215.6 (b)(2) states: Any person who knowingly makes any false statement representation, or certification in any
application, r d, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management
Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be
guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001
provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.)
4 of 4 Form-D 6/2017