NC0071323_Fact Sheet_20210526

DENR/DWQ
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO071323
2021 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:
Etowah Sewer Company Etowah Sewer Company WWTP
Applicant Address:
c/o KACE Environmental, Inc.; 2905 Wood Road; Mooresboro NC 28114
Facility Address:
Off US 64 Highway
Facility Class Permit Status:
Grade II Biological WPCS Renewal
Permitted Flow (as built)
0.5 MGD 0.125 MGD
Type of Waste
100% Domestic
Receiving Stream
French Broad River
Stream Class ID
WS IV; B 6- 47.5
River Basin
French Broad
Subbasin
04-03-02
HUC
060101050404
USGSToo
Horse Shoe FBSE
7Q10 Sum Win cfs
226 277
30Q2 cfs
317
Avg. Stream Flow cfs
1046
IWC %
0.34 0.09 as built
County
Henderson
I Regional Office
ARO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / March 23, 2021
Does permit need daily max NHs limits?
No; Dilution high so WLA #s are very high,
Does permit need TRC limits/language?
Included
Does permit have toxicity testing?
No
Does permit have Special Conditions?
No
Does permit have instream monitoring?
No
Stream on 303 d List? For w/parameter?
None other than statewide mercury listing
Any compliance concerns?
Six enforcement actions; See compliance
discussion below
Any modifications since lastpermit?
None noted in application.
New expiration date:
November 30, 2025
FACILITY OVERVIEW:
This facility is 100% domestic waste. Facility serves a number of residential and commercial developments
and individual locations as a regionalized plant. The facility is permitted at 0.50 MGD and currently built at
capacity of 0.125 MGD. The treatment system consists of the following wastewater treatment components:
• Influent lift station
• Bar Screen
• Flow equalization chamber with flow control box
• Dual train aeration basins
• Dual train clarifiers
• Tablet feed chlorinators
• Chlorine contact chamber
• Tablet feed dechlorinators
• Effluent flow meters
• Sludge holding chamber

The Etowah Sewer Company has a number of permits under the sewer and collection system permitting
program as well. No modifications were noted or proposed in the current application.
Ownership - The application and BIMS indicate a consultant - Ken Deaver with Kace environmental - is the
owner of the facility. There is no documentation in the files or in Laserfiche of an ownership change. There is
information in the file that in 2016 the City of Hendersonville was working to buy the system. Further review
of this sale found online documentation that the County Commissioners did not approve this sale.
Documentation of the Company with the Secretary of State's website does not include Mr. Deaver in any of the
officer positions for the company. ARO staff contacted Mr. Deaver to discuss the ownership situation and found
that Etowah is a private utility owned by multiple stakeholders. Mr. Deaver is the General Manager of the
Etowah Sewer Company and indicated all correspondence should come to him.
INSPECTION
The most recent inspection (3/20/2019) found that the facility was operated well. Some issues were pointed
out, including rusting and collapsed grating and alarms that needed to be repaired. These issues did result in
the issuance of a Notice of Deficiency.
COMPLIANCE:
During the permit cycle this facility had twelve (12) NOVs and two (2) NODs. A majority of the notices were for
limits violations for BOD and Fecal but there were also notices for TSS, flow and inspection issues. There were
six (6) enforcement actions taken for limits violations with total assessment of $3,591.12 ($2,900 in penalties).
There have been no enforcement actions since 2018 and four (4) compliance actions in the last two years.
MONITORING DATA REVIEW:
Parameter Units
Avg.
High
Low
Permit Limit
Comments
1 MA violation in 2 02 0; 6 of 12 MA
Flow (MGD)
0.082
0.40
0.01
0.125 MA
in 2020 were > 0.10 80% of flow)
BOD (mg/L)
12.28
70
2
30MA
3 MA > 30 and 7 DM > 45
45DM
TSS (mg/L)
8.25
62
2.5
30MA
1MA > 30 and 2 DM >45
45DM
Fecal Coliform (#/mL)
30.9
600
0.5
200MA
6 DM > 400
40ODM
pH (su)
n a
9.4
6
6 to 9
1 Value > 9 9.4
TRC (µg/L)
13.95
14
0.14
28 DM
No exceedances
Temp (C)
17.13
27
4
-
NHs-N (mg/L)
3.20
26
0.10
-
4 of 11 values > 20 one very high
Total Nitrogen (mg/L)
51.57
404
2.08
-
404
Total Phosphorus (mg/L)
3.6
6.4
0.81
-
9 of 11 values > 2
MA - Monthly Average DM - Daily Max Daily Average
The data reviewed for the renewal is from February 2016 through December 2020.
In review of the data it was found that a majority of the violations occurred early in the permit cycle. Only three
(3) of the monitoring violations noted in the table occurred over the last two years. As mentioned in that table
comments nutrient values were high but probably do not raise any instream concerns. Over the last year
(2020) half of the monthly flow values were at or above 80% of the as built flow. This may be an issue for the
regional office and the facility to keep an eye on.
Ltovyah Scvycr Company, w'w'T[ Fact Shcct
NPDLS Renewal 2021 — March'_ 3. 2021
Pa(e 2

FILE HISTORY REVIEW SUMMARY
• The Etowah Sewer System mad application for a discharge permit in 1987 to regionalize
several package plants and eliminate some failed septic systems. The 1987 Waste Load
Allocation (WLA) was evaluated for a permitted flow of 0.125 and a design flow of 0.06 MGD.
The discharge at this time was to Gash Creek. Limits were set for BOD 20/30 (s/w); NH3-N
4/11; DO of 5; TSS 30/30; fecal at 1,000 and pH 6-9. Instream monitoring was required for
Temp, DO, fecal and conductivity.
• 1988 Authorization to Construct (ATC) issued January 9, 1988 for 0.06 MGD facility.
• 1992 WLA - Toxicity limits (@71%) were added to address toxicity issues. Fecal limt changed
to 200, dechlorination added to the permit along with monitoring for total residual chlorine,
total phosphorus and total nitrogen.
• 1995 WLA - The 1995 application included a request to move the discharge point to the French
Broad River. This change would address compliance issues in Gash Creek. Gash Creek had a
golf course that was removing a significant amount of flow for irrigation purposes creating
issues for the discharge. While discharging to Gash Creek the limits remained the same except
toxicity was evaluated at 54%. With the future move to discharge to the French Broad, limits
were modified: BOD 30/45; TSS 30/45; pH 6-9; monitoring for - NH3-N, temperature, TN and
TP. Instream monitoring was included for fecal, temp, DO and conductivity.
• April 2O, 2001 - ATC issued for expansion to 0.125 MGD capacity.
• 2002 Permit Renewal - The facility relocated their discharge to the French Broad River January
25, 2002 and began operating their upgraded treatment system February 8, 2002 prior to the
issuance of the renewal in June 2002. There had been some concerns raised by environmental
groups about the discharge and it's impact on Gash Creek but these issues were resolved with
the move of the discharge. The renewed permit eliminated all required instream monitoring
('95 WLA and consistent with 100% domestic strategy).
• 2006 Permit Renewal - French Broad River classification changed to WS-IV; B. Total Residual
Chlorine limit of 28 µg/L added effective September 2007.
• 2008 Permit Modification - The permit was modified to add phased expansion to 0.5 MGD.
Review of Engineering Alternatives Analysis and Level B model resulted in no changes to the
permit limits.
• 2010 Permit Renewal - no changes.
• 2016 Permit Renewal - No changes other than the addition of eDMR requirements and rule
citations.
PROPOSED PERMIT CHANGES:
Updated eDMR requirements to be consistent with final EPA rule.
Added regulatory citations throughout permit as needed.
Correct location coordinates for outfall.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: April 5, 2021
Permit Scheduled Effective Date: June 1, 2021
Etowah Sewer Company WWTP Fact Sheet
NPDES Renewal 2021— March 23, 2021
Page 3

STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett
at [phone].
Etowah Sewer Company WWTP Fact Sheet
NPDES Renewal 2021 — March 23, 2021
Page 4

LOCAU10
StarNews I The Dispatch PO Box 631245 Cincinnati, OH 45263-1245
Times -News
PROOF OF PUBLICATION
Ncdenr-Div. Of Water Resources
Ncdenr-Div. Of Water Resources
1617 MAIL SERVICE CENTER
RALEIGH NC 27699
STATE OF NORTH CAROLINA, COUNTY OF HENDERSON
The Hendersonville Times -News, a newspaper printed and
published in the city of Gastonia, and of general circulation in the
County of Henderson, State of North Carolina, and personal
knowledge of the facts herein state and that the notice hereto
annexed was Published in said newspapers in the issue:
04/08/2021
and that the fees charged are legal.
Sworn to and subscribed before on 04/08/2021
my commision expires
Publication Cost: $89.15
Order No:
5736698 # of Copies
Customer No:
489035 1
PO #:
NCO071323
THIS IS NOT
AN INVOICE!
Please do not use this form for payment remittance.
VICKY FELTY
Notary Public
State of Wisconsin
Public Notice
North Carolina Environmental
Management Commis-
sion/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
NCO071323 Etowah Sewer
Company WWTP The North
Carolina Environmental
Management Commission
proposes to issue a NPDES
wastewater discharge permit
to the person(s) listed below.
Written comments regarding
the proposed permit will be
accepted until 30 days after the
publish date of this notice. The
Director of the NC Division of
Water Resources (DWR) may
hold a public hearing should
there be a significant degree of
public interest. Please mail
comments and/or information
requests to DWR at the above
address. Interested persons
may visit the DWR at 512 N.
Salisbury Street, Raleigh, NC
27604 to review information on
file. Additional information on
NPDES permits and this notice
may be found on our website:
http://deq.nc.gov/about/division
s/water-resources/water-
resou rces-per m i is/wastewate r-
branch/npdes-waste-
water/public-notices,or by call-
ing [phone]. The Etowah
Sewer Company [2905 Wood
Rd, Mooresboro, NC 281141
requested renewal of permit
NCO071323 for the Etowah
Sewer Company WWTP in
Henderson County. This
permitted facility discharges
treated wastewater to the
French Broad River within the
French Broad River Basin.
Currently Total Residual Chlo-
rine is water quality limited.
This discharge may affect
future allocations in this
portion of the French Broad
River.
4/8/2021 5736698
C Pagel of 1

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 5, 2020
MEMORANDUM
To: Kimberly Barnett
NC DEQ / DWR / Public Water Supply
Asheville Regional Office
From: Bradley Bennett
Compliance and Expedited Permitting Unit
Subject: Review of Draft NPDES Permit NCO071323
Etowah Sewer Company WWTP
Henderson County
Please indicate below your agency's position or viewpoint on the draft permit and
return this form by May 7, 2021. If you have any questions on the draft permit,
please contact me via e-mail [[e-mail]].
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained
F—xl properly, the stated effluent limits are met prior to discharge, and the discharge does not
contravene the designated water quality standards.
nConcurs with issuance of the above permit, provided the following conditions are met:
F-1
Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signed Z!?d& q4&jL69 Date: 4 13 21
D Q
�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NOR NCAROL.INA -
Doi' m.mtof EnWmnmn., o..,dy 919.707.9000

5/26/2021
Mail - Bennett, Bradley - Outlook
Re: [External] Re: Permit Renewal for Etowah Sewer Company WWTP - NCO071323
Ken Deaver <guppy0751 @gmail.com>
Tue 4/6/2021 12:25 PM
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 Report Spam.
You might include Kevin Griffin and Rachael Kramer.
Sent from my Whone
On Apr 6, 2021, at 10:36 AM, Bennett, Bradley <[e-mail]> wrote:
Thanks Ken. I will make sure to include all of the indicated addresses in email
correspondence. Just to check, should any of the others indicated be included as
contacts/owners, etc. in our permit database?
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: Ken Deaver <[e-mail]>
Sent: Tuesday, April 6, 2021 10:32 AM
To: Bennett, Bradley <bradley. ben nett@ ncden r.gov>
Subject: [External] Re: Permit Renewal for Etowah Sewer Company WWTP - NCO071323
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.
Hi Bradley,
Email will be ok as long as you send it to all concerned,
Ken Deaver- g2ppy0751 gmail.com
Rachael Kramer- [e-mail]
Kevin Griffin- kevinCa)hialtarealestate.com
Jeanne Dressback-jeannePhialtarealestate.com
Vincent Edwards- [e-mail]
https://outlook.office365.com/mail/deeplink?popoutv2=1 &version=20210517003.13 1/3

5/26/2021
Mail - Bennett, Bradley - Outlook
Thank You,
Ken Deaver
On Mon, Apr 5, 2021 at 11:21 AM Bennett, Bradley <bradley.bennettC-ncdenr.gov> wrote:
Mr. Deaver,
Thanks for talking with our regional Office staff about the owner issue. I did want to
check with you again on the electronic transmittal of documents mentioned in the email
below. We will be noticing the draft permit later this week and if you are okay with the
use of electronic transmittal of the documents, please respond to let me know.
Thanks
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: Bennett, Bradley <brad ley. ben nett@ ncden r.gov>
Sent: Monday, March 22, 2021 2:53 PM
To: Ken Deaver <ken kaceinc.com>
Subject: Re: Permit Renewal for Etowah Sewer Company WWTP - NCO071323
Hi Mr. Deaver,
I just wanted to touch base again on the issues in the attached email from last week. I am
working on the draft permit and would like to get some feedback on these issues.
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: Bennett, Bradley
Sent: Tuesday, March 16, 2021 3:32 PM
To: Ken Deaver <ken kaceinc.com>
Cc: [e-mail] <[e-mail]>
Subject: Permit Renewal for Etowah Sewer Company WWTP - NCO071323
Mr. Deaver,
https://outlook.office365.com/mail/deeplink?popoutv2=1 &version=20210517003.13 2/3

5/26/2021
Mail - Bennett, Bradley - Outlook
I am currently working on the review of the permit renewal request for the Etowah Sewer
Company WWTP (NC0071323). I hope to have a draft permit ready for public notice
soon. In my review of the renewal request I did have one question that I can hopefully
get information from you on. In our permit database you are currently listed as the
Owner of this system. Is this accurate, or is there another Owner of the Etowah Sewer
Company, and you are delegated signature authority? If you are not the actual owner, we
would like to have a contact person for our records with the Company.
Also, I wanted to pass along information about the Division's current efforts to handle a
good bit of our contact and correspondence in electronic format. 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 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://outlook.office365.com/mail/deeplink?popoutv2=1 &version=20210517003.13 3/3

4/4/2021
Mail - Bennett, Bradley - Outlook
RE: Etowah Sewer Company Question - NCO071323
Boss, Daniel J <[e-mail]>
Mon 3/29/2021 9:31 AM
To: Weaver, Charles <[e-mail]>; Bennett, Bradley <[e-mail]>
Hi guys,
I would add that in the month of Feb 2020 the WWTP exceeded 100% of the monthly permitted flow, and that one day
of that month the daily flow was more than double the permitted flow for the WWTP.
This does indicate an I&I problem, which is common. I don't know if they are doing anything to combat it.
Daniel Boss
Assistant Supervisor- 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: Monday, March 29, 2021 9:18 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: RE: Etowah Sewer Company Question - NCO071323
I would put a reference to the rule in the cover letter:
15A NCAC 02T .0118, "Demonstration of Future Wastewater Treatment Capacities," was adopted by the Environmental
Management Commission to ensure that wastewater treatment systems do not exceed their hydraulic treatment
capacities. This Rule specifies that publicly -owned facilities exceeding 80% of their hydraulic treatment capacity must
conduct evaluations of future wastewater treatment needs.
While this rule does not apply to your facility, we have noted several months where your monthly average flow has
exceeded 80% of design capacity. This poses a risk that your facility will become noncompliant with its effluent
limitations. We urge you to evaluate the cause[s] for these high flows and take the necessary steps to keep your facility
in compliance. Operating at such a high percentage of design flow is not sustainable, and increases wear on the
treatment components.
Dan —feel free to add anything you think needs adding.
CHW
From: Bennett, Bradley <[e-mail]>
Sent: Monday, March 29, 2021 8:30 AM
To: Weaver, Charles <[e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: Re: Etowah Sewer Company Question - NCO071323
Thanks Charles,
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/3

4/4/2021
Mail - Bennett, Bradley - Outlook
Catching up on emails from the end of last week and it does look like the ARO does want to mention this. Do
you have any example language you could pass along for this? Since they aren't subject to the 80/90 rule is
there anything I should reference in terms of what they should be doing at this point?
::
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: Weaver, Charles <[e-mail]>
Sent: Monday, March 29, 2021 8:15 AM
To: Bennett, Bradley <bradley.ben [e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: RE: Etowah Sewer Company Question - NCO071323
Bradley— Etowah Sewer is a private utility and thus not subject to the 80/90 rule, which applies to:
"wastewater treatment systems owned or operated by municipalities, counties, sanitary districts or public utilities" (15A
NCAC 02T.0118)
Dan — any idea why Etowah Sewer is having high flows — apart from the heavy rain all winter? If you'd like Bradley to
address their flow issues in the draft permit cover letter, let him know.
CHW
From: Bennett, Bradley <[e-mail]>
Sent: Sunday, March 28, 2021 7:54 PM
To: Weaver, Charles <[e-mail]>
Subject: Etowah Sewer Company Question - NCO071323
Hey Charles,
In preparing the draft for this one and looking at the data I noticed that in 2020 this one had six monthly
average flows that were at or above 80% of their flow. I'm not exactly sure how we do the 80/90 stuff. I know
there was some discussion at the staff meeting about it being time to do any letters. Anyway, I wanted to
check with you and see if this indicates something that I should mention in the cover letter for the draft or
should it be handled some other way? Maybe the time period I noted wasn't enough to get them on the
80/90 watch.
Thanks for your input on this. If I should mention it I'd appreciate any example language you could provide
me.
Thanks
::,
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/3

4/4/2021
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... 3/3

4/4/2021
Mail - Bennett, Bradley - Outlook
RE: Draft Permit for Etowah Sewer Company WWTP - NCO071323
Boss, Daniel J < clan [e-mail]>
Thu 3/2S/2021 2:01 PM
To: Heim, Tim <[e-mail]>; Bennett, Bradley <[e-mail]>
Hi Bradley,
I agree with Tim, please mention that they are approaching 80% of flow capacity. They do seem to have an I&I problem
from looking over their monitoring reports. No evidence of any I&I repair.
Thanks,
Daniel Boss
Assistant Supervisor- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: daniel.boss(@ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
From: Heim, Tim
Sent: Thursday, March 25, 2021 12:10 PM
To: Bennett, Bradley <bradley. ben [e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: RE: Draft Permit for Etowah Sewer Company WWTP - NCO071323
No additional changes (in addition to the ownership items Dan responded to).
I would cite the 80% flow, as that indicates they are close to having to take action per the 80/90 rule (unless there was a
significant I&I defect that was repaired etc). Dan, do you know anything more on that?
From: Bennett, Bradley
Sent: Tuesday, March 23, 2021 9:01 AM
To: Heim, Tim <[e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: Draft Permit for Etowah Sewer Company WWTP - NCO071323
Hey Tim,
Attached is the draft permit for Etowah. Take a look and let me know if you have any changes or questions.
One remaining issue is making sure about the ownership issue. Is it Deaver or is really someone else. Dan is
going to check with Ken Deaver and try and figure this all out. We can make adjustments to the draft if we
need to after I hear back from Dan. The renewal application is in Laserfiche if you need to see that.
One other thing to mention. I noted in the Fact Sheet that in 2020 they had six months where their monthly
flow was at 80% (0.10MGD) or more. If you think I should mention anything about this in the cover letter let
me know and I can add some language. Of course, I'm guessing you guys stay on the 80/90 stuff so there may
not be a need to mention it.
Thanks
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Ni1 hNGU4LTY3M2El ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1 /2

4/4/2021
Mail - Bennett, Bradley - Outlook
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://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/2

4/4/2021
Mail - Bennett, Bradley - Outlook
RE: Draft Permit for Etowah Sewer Company WWTP - NCO071323
Boss, Daniel J < clan [e-mail]>
Tue 3/23/2021 10:48 AM
To: Bennett, Bradley <[e-mail]>
Cc: Heim, Tim <[e-mail]>
Hi Bradley,
I spoke with Mr. Deaver just now. Etowah Sewer Company is a private utility owned by multiple stockholders. Mr.
Deaver is not the owner, he is the general manager of the Etowah Sewer Company. Mr. Deaver said that all
correspondence should go to him.
Please let me know if you need more clarity on this, thanks.
Daniel Boss
Assistant Supervisor- 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: Bennett, Bradley
Sent: Tuesday, March 23, 2021 9:01 AM
To: Heim, Tim <[e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: Draft Permit for Etowah Sewer Company WWTP - NCO071323
Hey Tim,
Attached is the draft permit for Etowah. Take a look and let me know if you have any changes or questions.
One remaining issue is making sure about the ownership issue. Is it Deaver or is really someone else. Dan is
going to check with Ken Deaver and try and figure this all out. We can make adjustments to the draft if we
need to after I hear back from Dan. The renewal application is in Laserfiche if you need to see that.
One other thing to mention. I noted in the Fact Sheet that in 2020 they had six months where their monthly
flow was at 80% (0.10MGD) or more. If you think I should mention anything about this in the cover letter let
me know and I can add some language. Of course, I'm guessing you guys stay on the 80/90 stuff so there may
not be a need to mention it.
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
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1 /1

NH3/TRC WLA Calculations
Facility: Etowah Sewer Company
PermitNo. NCO071323
Prepared By: Bradley Bennett
Enter Design Flow (MGD): 0.125 0.5 <= Permitted Flow if Different from Design
Enter s7Q10 (cfs): 226
Enter w7Q10 (cfs): 277
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/1)
IWC (%)
Allowable Conc. (ug/1)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Design
226
0.125
0.19375
17.0
0
0.09
19847
Permitted
226
0.5
0.775
17
0
0.34
4974
Design Permitted
Not Required'; 200I100mi
1167.45 292.61
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/1)
IWC (%)
Allowable Conc. (mg/1)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
w7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/1)
IWC (%)
Allowable Conc. (mg/1)
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, 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)
Design Permitted
226
226
0.125
0.5
0.19375
0.775
1.0
1.0
0.22
0.22
0.09 `:
0.34
910.8
228.5
Design
277
0.125
0.19375
1.8
0.22
0.07
2260.7
Permitted
277
0.5
0.775
1.8
0.22
0.28
566.5

4/5/2021
Mail - Bennett, Bradley - Outlook
Re: Permit Renewal for Etowah Sewer Company WWTP - NCO071323
Bennett, Bradley <[e-mail]>
Mon 3/22/2021 2:S3 PM
To: Ken Deaver <[e-mail]>
Hi Mr. Deaver,
I just wanted to touch base again on the issues in the attached email from last week. I am working on the
draft permit and would like to get some feedback on these issues.
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: Bennett, Bradley
Sent: Tuesday, March 16, 2021 3:32 PM
To: Ken Deaver <[e-mail]>
Cc: [e-mail] <[e-mail]>
Subject: Permit Renewal for Etowah Sewer Company WWTP - NCO071323
Mr. Deaver,
I am currently working on the review of the permit renewal request for the Etowah Sewer Company WWTP
(NC0071323). I hope to have a draft permit ready for public notice soon. In my review of the renewal request
I did have one question that I can hopefully get information from you on. In our permit database you are
currently listed as the Owner of this system. Is this accurate, or is there another Owner of the Etowah Sewer
Company, and you are delegated signature authority? If you are not the actual owner, we would like to have a
contact person for our records with the Company.
Also, I wanted to pass along information about the Division's current efforts to handle a good bit of our
contact and correspondence in electronic format. 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 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
NC Division of Water Resources
Phone: [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email: [e-mail]
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Ni1 hNGU4LTY3M2El ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1 /2

4/5/2021
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