NC0000078_Fact Sheet_20210809

Fact Sheet
NPDES Permit No. NC00078
Permit Writer/Email Contact Julia Byrd, [e-mail]
Date: June 2, 2021
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 10_2020
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Davidson River Village (formerly Ecusta Mill)
Applicant Address:
PO Box 880 Pisgah Forest, NC, 28768
Facility Address:
121 Ecusta Road, Brevard, NC, 28712
Permitted Flow:
None
Facility Type/Waste:
Major/ 60% leachate 40% stormwaters
Facility Class:
Class III
Treatment Units:
Bar screen, grit removal, transfer pump station, two 3.35 MG clarifiers,
75-acre aerated stabilization pond, effluent weir
Pretreatment Program (Y/N)
N
County:
Transylvania
Region
Asheville
Page 1 of 11

Briefly describe the proposed permitting action and facility background:
Davidson River Village, LLC intermittently discharges accumulated stormwater, groundwater, and landfills
leachate wastewater from a 75-acre aerated stabilization basin (ASB), formerly part of the RFS
Ecusta/Glatfelter Paper Mill industrial 27.5 MGD treatment facility. Industrial activity ceased permanently
in 2005. Except for a pump station, clarifier (currently surplus, not used), effluent metering system with
composite sampler, ASB surface aerators (currently surplus, not used), and effluent acid addition system,
all other treatment components have been removed.
Ecusta Business Development Center, LLC purchased the mill in 2003 but the permit ownership change
was delayed because of financial liabilities issues until 2006 when the NCDENR General Counsel
concurred issuing an ownership change was acceptable. As part of the 2007 permit renewal, a modification
was issued which added a new interim 13 MGD limitations and requirements tier page for Outfall 001,
added mercury monitoring to Outfalls 002 and 003, and converted all limits to concentration —based. USGS
stream data (1993) was used to calculate the new tier IWC of 12% and other related dilution factors. In
addition, special conditions for conducting fish tissue studies, Dam integrity inspections, and submitting an
EAA by the new owner were added.
The site was part of an approved brownfield multi -phase, multi -agency, clean up action to facilitate safe
development of the property for commercial, residential, and industrial uses. The main industrial area clean
up phase was completed in 2011. Several landfills were constructed on site as part of the cleanup and remain
the property of Glatfelter (former Ecusta owner). Per Davidson River Village LLC under the current
agreement, Davidson River Village LLC is obligated to accept landfills leachate, on -site stormwater runoff,
and other on -site generated dewatering wastewater streams into its permitted treatment facility.
Discharges are manually controlled by an adjustable weir gate, and in several months no discharge occurred.
The ASB effluent enters a closed channel that drains via a submerged diffuser into the French Broad River,
a class B water (re-classified from C in 2002) in the French Broad River Basin.
After review from NCDENR General Counsel, a permit modification was issued in 2008 to reflect the
change to the current owner/developer Davidson River Village, LLC. A fish tissue and benthic stream
survey, and an ASB Management Plan were submitted to the Division later the same year. At the request
of the new owner, a permit modification to remove Outfalls 002 and 003 from the permit was approved and
a modified permit issued in 2009.
The current permit, issued September 1, 2015, included a special condition (A. (6)) which required the
permittee to construct two new monitoring wells and conduct groundwater monitoring associated with the
ASB regulatory boundary to determine compliance with groundwater standards per 15A NCAC 2L .0200.
The condition also specified that two existing monitoring wells be abandoned upon completion of the new
wells. The 2020 renewal application included verification that the new wells were constructed, approved
by the Division, and ground water monitoring has been conducted in accordance with the permit. The
existing wells remain in use by the owner/operator of the former landfills, Glatfeller, pursuant to
requirements of the Solid Waste Section of the Division of Waste Management.
The Division requested DRV to complete an assessment of sludge depths in the ASB, to confirm sufficient
remaining volume to support future sludge generation. The results are reported in the 2020 renewal
application and demonstrate that sufficient capacity is available.
Page 2 of 11

2. Receiving Waterbodv Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
001 French Broad River
Stream Segment:
04-03-01; Index 6-34-(21)
Stream Classification:
B
Drainage Area (mi2):
221
Summer 7Q10 (cfs)
154
Winter 7Q10 (cfs):
189
30Q2 (cfs):
-
Average Flow (cfs):
740
IWC (% effluent):
2.9%
303(d) listed/parameter:
No
Subject to TMDL/parameter:
Statewide Mercury TMDL
Basin/Sub-basin/HUC:
French Broad River Basin/06010105
USGS Topo Quad:
F8SW Pisgah Forest, NC
Page 3 of 11

3. Effluent Data Summary
Effluent data for Outfall 001 summarized below is for the period of January 2017 to February 2021
Table 3.1. Effluent Data Summary Outfall 001
my
Units
Average
Max
Min
Permit Limit
Flow'
MGD
0.37
7.61
<0.0001
None
BOD5
mg/1
2.74
8.7
2
MA 30
DM 45
NH3N
mg/1
0.144
0.46
0.1
None
Turbidity
NTU
4.30
9
1.3
Total Suspended Solids
mg/I
5.9
12
3.1
MA 30
DM 45
pH
SU
-
8.8
7.2
6.0>pH<9.0
Dissolved Oxygen
mg/1
7.32
9.5
5.91
DA >5.0
Conductivity
µmhos/cm
256.09
330
190
None
Temperature
° C
20.17
31
6.6
None
Total Nitrogen
mg/1
1.19
2.61
0.58
None
Total Phosphorus
mg/1
0.04
0.07
0.03
None
Total Mercury (1631 E)
ng/1
4.77
11.2
1.79
47 (annual avg)
2,3,7,8 Tetrachloro-
dibenzo-p-Dioxin
pg/1
0.69
1.24
0.032
DM 0.81
Chronic Toxicity
P/F
P/F @ 2.9%
AA- Annual Average, MA -Monthly Average, DM -Daily Maximum, DA-Daily Average
'Due to the large storage capacity of the ASB and manually controlled discharge, flow is averaged based
on the number of days of actual discharge. See the Outfall 001 Effluent Flow Statics summarized below.
Table: Outfall 001 Effluent Flow Statistics: January 2017 - February 2021
Total Number of Discharge Days
1269 days /1520 days, 83% of total available days
Range of Monthly Average Flow
0.08 (June) to 0.61 (Feb)
Max Monthly Average Flow
1.06 (May 2018)
Range of Monthly Max Day Flow
1.18 (June) to 7.62 (Dec)
Month with most discharge days and
highest monthly average
May 2018: 1.06 MGD
Estimated maximum average flow
1.1 MGD (BPJ)
Page 4 of 11

4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when
model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify
model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream
concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions
established in several basins that conduct instream sampling for the Permittee (in which case instream
monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this permit
action: Instream monitoring is not required in the permit. No changes are proposed.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): No
Name of Monitoring Coalition: NA
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): Since January 2017, the
permittee has received two notice of violations (NOVs). On May 9, 2017, the facility reported 1.24 pg/L of
2,3,7,8-tetrachlorodibenzo-p-dioxin, which exceeds the daily maximum permitted limit of 0.81 pg/L. The
second NOV in September 2019 was a monitoring frequency violation for Mercury.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): The facility passed 15 of the last 15 quarterly chronic toxicity tests reported. Since the current
permit was issued there were two quarters, January and August 2018, not reported due to no discharge.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
on August 8, 2020 by Tim Heim from the Asheville Regional Office. The inspection reported no significant
issues, and the facility is operated in compliance with the current permit.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: The permit limits for
BOD5 are based on secondary treatment standards, TBELs, outlined in 40 CFR 133.102. No changes are
proposed from the previous permit limits.
Page 5 of 11

Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: Based on results of
the waste load allocation review, the calculated allowable ammonia concentration is greater than 35 mg/L
therefore no limits are required, but monthly monitoring is required. The permittee does not utilize chlorine
for disinfection and does not store chlorinated substances on site, there are currently no limit or monitoring
requirements for TRC in the permit. There are no proposed changes.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of Y2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between January 2017
and January 2021. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria: None.
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but
the maximum predicted concentration was >50% of the allowable concentration: None.
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was <50% of the allowable concentration: Total
arsenic, copper, zinc.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions.
The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits,
using single concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: Quarterly chronic toxicity testing at an effluent concentration
of 2.9% is required in the current permit. No changes are proposed.
Page 6 of 11

Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year) and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will receive
an MMP requirement. Industrials are evaluated on a case -by -case basis, depending on if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value
of 47 ng/L.
Table. Mercury Effluent Data Summary
2017
2018
2019
2020
# of Samples
3
4
4
4
Annual Average Conc. ng/L
7.7
6.04
4.215
2.4225
Maximum Conc., ng/L
10.1
11.2
6.57
2.9
TBEL, ng/L
47
WQBEL, ng/L
409
Describe proposed permit actions based on mercury evaluation: Since no annual average mercury
concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury
limit is required. As a non -municipal facility, a Mercury Minimization Plan is not required. The Mercury
TMDL Evaluation conducted did not indicate limits or monitoring is needed.
The current permit includes a special condition to re -open the permit at the discretion of the Division for
analyses of fish tissue for mercury and/or tetrachloro-dibenzo-p-Dioxin (TCDD). No changes are proposed.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: No changes to the TN/TP monitoring requirements in the current permit are proposed.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: The current permit
includes daily maximum limits for 2,3,7,8 Tetrachloro-dibenzo-p-Dioxin (TCDD) of 0.81 pg/L, values
reported less than 10 pg/L are considered in compliance, with annual monitoring. Based on DMRs from
2017 to 2021, summarized below, the data show a reduction in dioxin levels detected. No changes are
proposed to the current permit limits and monitoring requirements.
Table: 2,3,7,8 Tetrachloro-dibenzo-p-Dioxin 2017- 2021
Date
Concentration (pg/L)
5/9/2017
1.24
1/9/2018
1.02
1/15/2019
0.0316
1/14/2020
0.779
1/12/2021
0.387
Page 7 of 11

If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Describe what this facility produces: There is currently no production. The permittee, Davidson River
Village, LLC accepts landfill leachate associated with a former paper mill, onsite stormwater runoff, and
wastewater generated from dewatering activities onsite to an aeration and stabilization pond which is the
primary secondary treatment process.
List the federal effluent limitations guideline (ELG) for this facility: 40 CFR 133.102.
If the ELG is based on production or flow, document how the average production/flow value was calculated:
NA
For ELG limits, document the calculations used to develop TBEL limits: The current permit limits
summarized below are based on the effluent guidelines in § 133.102 secondary treatment standards.
Table. TBELs per 40 CFR 133.102
Pollutant
Monthly Average
Daily Maximum
BODS
30.0 mg/L
45.0 mg/L
TSS
30.0 mg/L
45.0 mg/L
pH
between 6.0 — 9.0 SU
If any limits are based on best professional judgement (BPJ), describe development: NA
Document any TBELs that are more stringent than WQBELs: NA
Document any TBELs that are less stringent than previous permit: NA
Page 8 of 11

8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): Yes
If YES, confirm that antibacksliding provisions are not violated: NA
See section 6. WBELS, Mercury TMDL Evaluation. Based on results of the evaluation conducted with
this permit renewal, no limits or monitoring is required.
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES
Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced
Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional
Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered
effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding
prohibitions would not be triggered by reductions in monitoring frequencies.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. While NPDES regulated facilities would initially be required to submit additional NPDES
reports electronically effective December 21, 2020, EPA extended this deadline from December 21, 2020,
to December 21, 2025. The current compliance date, effective January 4, 2021, was extended as a final
regulation change published in the November 2, 2020 Federal Register This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
Page 9 of 11

12.Summary of Proposed Permitting Actions:
A. Table. Current Permit Conditions and Proposed Changes Outfall 001
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow, MGD
None
No change
WQBEL. State WQ standard,
15A NCAC 2B .0505
BOD, 5-day, 20°C
MA 30.0 mg/1
DM 45.0 mg/1
No change
TBEL. Secondary treatment standards/40
CFR 133 / 15A NCAC 2B .0406
Total Suspended
Solids
MA 30.0 mg/1
DM 45.0 mg/1
No change
TBEL. Secondary treatment standards/40
CFR 133 / 15A NCAC 2B .0406
pH
Not less than 6.0
nor greater than
9.0 S.U.
No change
TBEL. Secondary treatment standards/40
CFR 133 / 15A NCAC 2B .0406
Dissolved Oxygen
> 5.0 mg/L DA
No change
WQBEL. State WQ standard, 15A NCAC 2B
Total Mercury
(Method 1631E)
47 ng/L Annual
average
No requirement
2012 NC Mercury TMDL
2,3,7,8 Tetrachloro-
dibenzo-p-Dioxin
0.81 pg/L
No change
WQBEL. State WQ standard, 15A NCAC
02B .0211 (< 10 pg/L in compliance)
Temperature, °C
Monitor and
report
No change
WQBEL. State WQ standard, 15A NCAC 2B
Ammonia as
nitrogen, mg/L
Monitor and
report
No change
WQBEL. State WQ standard,
15A NCAC 02B .0500 et seq.
Turbidity, NTU
Monitor and
report
No change
WQBEL. State WQ standard,
15A NCAC 02B .0211
Conductivity,
µmhos/cm
Monitor and
report
No change
WQBEL. State WQ standard,
15A NCAC 02B .0500 et seq.
Total Nitrogen
(TN), mg/ L
Monitor and
report
No change
WQBEL. State WQ standard,
15A NCAC 02B .0508
Total Phosphorus
(TP), mg/L
Monitor and
report
No change
WQBEL. State WQ standard,
15A NCAC 02B .0508
Chronic Toxicity
(2.5%)
Quarterly
No change
WQBEL. State WQ standard, no toxics in
toxic amounts, 15A NCAC 02B .0200 et seq
Effluent Pollutant
Scan
Monitor and
report
No change
G.S. 143-215.1(b)
Total Hardness
No requirement
Quarterly
monitoring U and E
Hardness -dependent dissolved metals water
quality standards 2016
MGD — Million gallons per day, MA - Monthly Average, DM — Daily Max
Page 10 of 11

13. Public Notice Schedule:
Permit to Public Notice: 06/08/2021
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit, please
contact Julia Byrd via email at [e-mail].
15. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below:
1. Correction made to the facility classification, Grade I Biological WPCS
2. Correction made to Special Condition A.(2), to add the electronic submittal information
3. Correction made to exhibit A, the groundwater monitoring well identifications have been
updated. Two of the three well originally constructed for monitoring have since been replaced.
Current wells, and
16. Fact Sheet Attachments (if applicable):
• Compliance Inspection Report (2020)
• Monitoring Violations Report (2017-2021)
• WET Testing and Self -Monitoring Summary
• NH3/TRC WLA Calculations
• RPA Spreadsheet Summary
• NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards
• Mercury TMDL Calculations
• 2020 NPDES permit renewal application
• Affidavit of Public Notice Transylvania Times 06/23/2021
• DWR response to comments from Davidson River Village WWTP
• NC Operator Certification Program Letter: Facility Classification
Page 11 of 11

DocuSign Envelope ID: 8CBF588D-430C-424D-9CB3-6DE75FC1E9F8
United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 IN I 2 E 3 I NC0000078 111 121 20/08/18 117
Type
18 I j, I
IIIIIIIIIII
Inspector Fac Type
19 I S I 201 I
21IIIIII IIIIIIIIIIIIIIIIIII IIIIII
166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671
1 761 1 711
1 72 I N I 73 174 71
1
1 1 1 1 1 _I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Davidson River Village
One Ecusta Rd
Pisgah Forest NC 28768
Entry Time/Date
09:30AM 20/08/18
Permit Effective Date
15/09/01
Exit Time/Date
11:OOAM 20/08/18
Permit Expiration Date
20/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Bernard Matthew Kelly/ORC/828-884-5544/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Bernie Kelly, //828-884-5544/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Flow Measurement • Operations & Maintenar Records/Reports Facility Site Review
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/ 8/18/2020
r —DDocuSigned by:
082B1105A3CA418...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
D S,g Cby 8/20/2020
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

DocuSign Envelope ID: 8CBF588D-430C-424D-9CB3-6DE75FC1E9F8
31
NPDES yr/mo/day
N C0000078 111 121 20/08/18
I17
Inspection Type
18 [j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Tim Heim of the Asheville Regional Office performed a Compliance Evaluation Inspection of the facility
on August 8, 2020. Bernard Kelly (ORC) was present and assisted with the inspection.
No violations of the permit conditions or deleterious impacts to the receiving stream were observed at
the time of the inspection.
The facility is currently operating under the 2015 issued permit and the new permit is under review.
Special Permit Conditions were reviewed with the ORC as part of the inspection.
Page# 2

DocuSign Envelope ID: 8CBF588D-430C-424D-9CB3-6DE75FC1E9F8
Permit: NC0000078
Inspection Date: 08/18/2020
Owner - Facility: Davidson River Village
Inspection Type: Compliance Evaluation
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ • ❑
Page# 3

PERMIT MONITOR REPORT YEOUTFALUPPI/FIELDM LOCATION TYPE WELL ID LOCATION PARAMETER
NC0000078 2018 001 Outfall Effluent 2,3,7,8-Tetrachlorodibe
NC0000078 2017 ASB-02 Well BIMS047653 Manganese, Total (as 1\
NC0000078 2017 ASB-02 Well BIMS047653 Iron, Total (as Fe)
NC0000078 2017 MW1 Well CONV000176
NC0000078 2017 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2017 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2020 ASB-01 Well BIMS047652 Cobalt, Total (as Co)
NC0000078 2020 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2020 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2019 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2019 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2018 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2018 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2017 001 Outfall Effluent 2,3,7,8-Tetrachlorodibe
NC0000078 2017 ASB-02 Well BIMS047653 Manganese, Total (as 1\
NC0000078 2017 Q88V2 Well CONV000530 Chromium, Total (as Cr
NC0000078 2019 Q88V2 Well CONV000530 Iron, Total (as Fe)
NC0000078 2019 Q88V2 Well CONV000530 Chromium, Total (as Cr
NC0000078 2018 Q88V2 Well CONV000530 Manganese, Total (as 1\
NC0000078 2018 Q88V2 Well CONV000530 Iron, Total (as Fe)
NC0000078 2017 MW1 Well CONV000176
NC0000078 2017 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2017 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2020 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2020 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2020 ASB-01 Well BIMS047652 Cobalt, Total (as Co)
NC0000078 2019 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2019 001 Outfall Effluent Mercury, Total (as Hg)
NC0000078 2017 Q88V2 Well CONV000530 Iron, Total (as Fe)
NC0000078 2017 Q88V2 Well CONV000530 Chromium, Total (as Cr
NC0000078 2019 Q88V2 Well CONV000530 Chromium, Total (as Cr
NC0000078 2017 MW1 Well CONV000176
NC0000078 2017 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2017 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2020 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2020 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2020 ASB-01 Well BIMS047652 Cobalt, Total (as Co)
NC0000078 2019 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2019 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2018 ASB-01 Well BIMS047652 Manganese, Total (as 1\
NC0000078 2018 ASB-01 Well BIMS047652 Iron, Total (as Fe)
NC0000078 2019 001 Outfall Effluent Phosphorus, Total (as F
NC0000078 2019 001 Outfall Effluent Nitrogen, Total - Conce

VIOLATION DATE
01/09/2018
03/31/2017
03/31/2017
06/30/2017
03/31/2017
03/31/2017
03/31/2020
03/31/2020
03/31/2020
03/31/2019
03/31/2019
03/31/2018
03/31/2018
05/09/2017
07/31/2017
07/31/2017
07/31/2019
07/31/2019
07/31/2018
07/31/2018
10/30/2017
07/31/2017
07/31/2017
07/31/2020
07/31/2020
07/31/2020
07/31/2019
09/30/2019
11/30/2017
11/30/2017
11/30/2019
03/01/2018
11/30/2017
11/30/2017
11/30/2020
11/30/2020
11/30/2020
11/30/2019
11/30/2019
11/30/2018
11/30/2018
12/31/2019
12/31/2019
FREQUENCY
Annually
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
Annually
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
Quarterly
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
3 X year
Semi-annually
Semi-annually
UNIT OF MEASURE LIMIT
pg/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
pg/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ng/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
mg/I
mg/I
CALCULATED VALUE % OVER
0.8100 1.0200
50.0000 185.0000
300.0000 4500.0000
50.0000 2160.0000
300.0000 13800.0000
1.0000 4.3000
50.0000 1690.0000
300.0000 1400.0000
300.0000 1330.0000
50.0000 1660.0000
50.0000 1690.0000
300.0000 2080.0000
0.8100 1.2400
50.0000 81.1000
10.0000 13.5000
300.0000 608.0000
10.0000 118.0000
50.0000 1660.0000
300.0000 1700.0000
50.0000 1780.0000
300.0000 1840.0000
50.0000 1840.0000
300.0000 1480.0000
1.0000 4.5000
300.0000 2040.0000
300.0000 364.0000
10.0000 51.6000
10.0000 13.4000
50.0000 1710.0000
300.0000 2020.0000
50.0000 1690.0000
300.0000 626.0000
1.0000 4.7000
50.0000 909.0000
300.0000 592.0000
50.0000 179.0000
300.0000 1100.0000
26
270
1400
4220
4500
330
3280
367
343
3220
3280
593
53
62
35
103
1080
3220
467
3460
513
3580
393
350
580
21
416
34
3320
573
3280
109
370
1718
97
258
267
VIOLATION TYPE
Daily Maximum Exceed
Limit Exceeded
Limit Exceeded
Well Missing
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Daily Maximum Exceed
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Well Missing
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Limit Exceeded
Frequency Violation
Limit
Limit
Limit
We l l
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Limit
Exceeded
Exceeded
Exceeded
Missing
Exceeded
Exceeded
Exceeded
Exceeded
Exceeded
Exceeded
Exceeded
Exceeded
Exceeded
Frequency Violation
Frequency Violation

VIOLATION ACTION VIOLATION COMMEN"LAST UPDATED BY IDTIMESTAMP
No Action, BIMS Calcul Below DWQ Comp.Levjanet.cantwell 6/1/2018 2:47:32 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:53:33 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:53:33 PM
No Action, Invalid Pern Q88V3 and Q88V4 repl brett.laverty ##################
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:53:33 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:53:33 PM
None bimsprod.cron 4/14/2020 1:22:46 AM
None bimsprod.cron 4/14/2020 1:22:48 AM
None bimsprod.cron 4/14/2020 1:22:47 AM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:43:34 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:43:34 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:48:42 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:48:43 PM
Proceed to NOV janet.cantwell ##################
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:52:28 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 3:47:24 PM
No Action, BPJ continue to monitor brett.laverty 1/30/2020 9:32:50 AM
No Action, BPJ background well, continbrett.laverty 1/30/2020 9:31:41 AM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 3:43:45 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 3:43:45 PM
No Action, Invalid Pern Q88V3 and Q88V4 repl brett.laverty ##################
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:52:28 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:52:28 PM
None bimsprod.cron 8/21/2020 1:32:28 AM
None bimsprod.cron 8/21/2020 1:32:27 AM
None bimsprod.cron 8/21/2020 1:32:26 AM
No Action, BPJ spoke with consultant, : brett.laverty 9/24/2019 4:14:29 PM
Proceed to NOV tim.heim ##################
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 3:46:50 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 3:46:50 PM
No Action, BPJ continue to monitor brett.laverty 1/30/2020 9:30:56 AM
No Action, Invalid Pern Q88V3 and Q88V4 reps brett.laverty ##################
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:50:37 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:50:37 PM
None bimsprod.cron 1/13/2021 1:51:51 AM
None bimsprod.cron 1/13/2021 1:51:51 AM
None bimsprod.cron 1/13/2021 1:51:50 AM
No Action, BPJ continue to monitor brett.laverty 1/30/2020 9:30:56 AM
No Action, BPJ continue to monitor brett.laverty 1/30/2020 9:30:31 AM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:44:19 PM
No Action, BPJ Continued monitoring brett.laverty 5/28/2019 2:44:19 PM
None bimsprod.cron 1/3/2020 1:40:27 AM
None bimsprod.cron 1/3/2020 1:40:26 AM

NH3/TRC WLA Calculations
Facility: Davidson River Village WWTp
PermitNo. NC0000078
Prepared By: Julia Byrd
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
1.1
154
189
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
154
1.1
1.705
17.0
0
1.10
1552
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
91.32 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
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
154
1.1
1.705
1.0
0.22
1.10
71.5
189
1.1
1.705
1.8
0.22
0.89
176.9
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Davidson River Village, LLC
NC0000078
Freshwater RPA -
Qw (MGD) =
1Q10S (cfs) =
7Q1OS (cfs) =
7Q1OW (cfs) =
30Q2 (cfs) =
Avg. Stream Flow, QA (cfs) =
Receiving Strom
1.1000
125.32
154.00
189.00
NO 30Q2 DATA
740.00
French Broad River
HUG 06010105
95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: Grade I, Biological
IWC% @ 1Q10S = 1.342255462
IWC% @ 7Q1OS = 1.095019428
IWC%@7Q1OW= 0.894051021
IWC%@30Q2= N/A
IW%C @ QA = 0.229875759
Stream Class: B
Outfall 001
Qw= 1.1 MGD
COMBINED HARDNESS (mg/L)
Acute = 25 mg/L
Chronic = 25 mg/L
PARAMETER
TYPE
NC STANDARDS OR EPA CRITERIA
a
w
r
n
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Chronic Stanlied
d d Acute
11 # Dot. Max Prod Cw Allowable Cw
Arsenic
Arsenic
C
C
150 FW(7Q10s) 340
10 HH/WS(Qavg)
ug/L
ug/L
1 0
Note: n<9
Limited data set
N/A
Acute (FW): 25,330.5
Chronic (FW): 13,698.4
#VALUE! __4,3___ _ __
Chronic HIM: 50.2
#VALUE!
_ ______________________
No Data
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
0 0
N/A
Acute: 4,842.60
Chronic: 593.60
No Data
Cadmium
NC
0.5899 FW(7Q10s) 3.2396
ug/L
0 0
N/A
Acute: 241.356
Chronic: 53.869
No Data
Chlorides
NC
230 FW(7Q10s)
mg/L
0 0
I\: .0
Acute: NO WQS
__ _ -_- _ _ _
-Ch_
Chronic: 21,004.2
_________________________
Chlorinated Phenolic Compounds
NC
1 A(30Q2)
ue: L
0 0
N A
Acute: NO WQS
_ _
_-Chronic:-_-_ ZLi'C? -_
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
0 0
/0 .0
Acute: NO WQS
_ _
_-Chronic:-_-_ IWC? -_
Chromium III
NC
117.7325 FW(7Q10s) 905.0818
pg/L
0 0
/0 .0
Acute: 67,429.9
Chronic: 10,751.E
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
/0 .0
Acute: 1,192.0
Chromium, Total
NC
µg/L
0 0
I
Copper
NC
7.8806 FW(7Q10s) 10.4720
ug/L
1 1
Note: n<9
Limited data set
18.60
C.V. (default)
Acute: 780.18
Chronic: 719.68
No value > Allowable Cw
RP= NO, Predicted Max<50% Alloable Cw - No
monitodng required
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
0 0
N/A
Acute: 1,639.0
Chronic: 456.6
Fluoride
NC
1800 FW(7Q10s)
ug/L
0 0
/0 .0
Acute: NO WQS
__ _ -_- _ _ _
-Ch___-_-_-_-_-_-_-_-_-_-_-_-__
Chronic: 164,380.E
Lead
NC
2.9416 FW(7Q10s) 75.4871
ug/L
0 0
/00
Acute: 5,623.900
Chronic: 268.637
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
20 20
15.1
Acute: NO WQS
Chronic: 1,095.9
No value > Allowable Cw
RP= NO, Predicted Max <50% Alloable Cw
Molybdenum
NC
2000 HH(7Q10s)
ug/L
0 0
N/A
Acute: NO WQS
__ _ -_- _ _ _
-Ch___-_-_-_-_-_-_-_-_-_-_-_-__
Chronic: 182,645.2
Nickel
Nickel
NC
NC
37.2313 FW(7Q10s) 335.2087
25.0000 WS(7Q10s)
µg/L
µg/L
0 0
N/A
Acute (FW): 24,973.5
Chronic(FW): 3,400.1
Chronic(WS): 2,283.1
Selenium
NC
5 FW(7Q10s) 56
ug/L
0 0
/00
Acute: 4,172.1
Silver
NC
0.06 FW(7Q10s) 0.2964
ug/L
0 0
/00
Acute: 22.082
Chronic: 5.479
Zinc
NC
126.7335 FW(7Q10s) 125.7052
ug/L
1 1
Note: n < 9
Limited data set
93.0
C.V. (default)
Acute: 9,365.2
Chronic: 11,573.E
No value > Allowable Cw
RP=NO, max predicted < 50% Awe
Page 1 of 1
RPA, rya
6/14/2021

Permit No. NC0000078
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/1
(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
2B.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, µg/I
Cadmium, Acute
WER*{1.1366724ln hardness](0.041838)} - e^{0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness](0.041838)} - e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER* { 1.101672-[ln hardness](0.041838)} - e^{0.7998[ln hardness]-4.4451 }
Chromium III, Acute
WER*0.316 - e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 • e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 • e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 • e^{0.8545[ln hardness]-1.702}
Lead, Acute
WER*{1.462034ln hardness](0.145712)} • e^{1.273[ln hardness]-1.460}
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-4.705}
Nickel, Acute
WER*0.998 • e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 • e^{0.8460[ln hardness]+0.0584}
Page 1 of 4

Permit No. NC0000078
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
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:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, 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.
Page 2 of 4

Permit No. NC0000078
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) + (s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 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.
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 = 1
Ctotal 1 + { [Kpo] [SS(l+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 sheet labeled DPCs.
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) (Cwqs) — (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 s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0000078
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 (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25
Default, no data
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25
Default, no data
7Q10 summer (cfs)
154
NPDES Files
1Q10 (cfs)
125.32
Calculated in RPA
Permitted Flow (MGD)
1.1
No flow limit. Flow based on DMRs
Date: 06/07/2021
Permit Writer: Julia Byrd
Page 4 of 4

4/23/21 WQS = 12 ng/L
Facility Name Davidson River Village, LLC NC0000078
/Permit No. :
MERCURY WQBEL/TBEL EVALUATION V:2013-6
Total Mercury 1631E PQL = 0.5 ng/L 7Q10s =
Date Modifier Data Entry Value Permitted Flow =
1/5/2016
4/5/2016
9/13/2016
10/11/2016
5/9/2017
7/11/2017
10/10/2017
1/9/2018
4/3/2018
7/10/2018
10/2/2018
1/15/2019
4/2/2019
7/9/2019
10/1/2019
1/14/2020
4/7/2020
7/21/2020
10/13/2020
1/12/2021
5.14 5.14
3.57 3.57
7.2 7.2
2.27 2.27
8.13 8.13
10.1 10.1
4.87 4.87
5.94 5.94
11.2 11.2
4.14 4.14
2.88 2.88
6.57 6.57
5.79 5.79
1.79 1.79
2.71 2.71
2.9 2.9
2.53 2.53
1.97 1.97
2.29 2.29
2.54 2.54
No Limit Required
No MMP Required
154.000
1.100
cfs
WQBEL = 1095.87 ng/L
47 ng/L
5.3 ng/L - Annual Average for 2017
6.3 ng/L - Annual Average for 2018
6.0 ng/L - Annual Average for 2019
4.2 ng/L - Annual Average for 2020
2.9 ng/L - Annual Average for 2021

AFFIDAVIT OF PUBLICATION
CLIPPING OF LEGAL ADVERTISING
ATTACHED HERE
PUBLIC NOTICE
North Carolina
Environmental Management
Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
NC0000078 Davidson River
Village 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. SaIisbury 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/divisions/w ater-
resources/water-resources-
permits/wastewater-branch/
npdes-wastewater/public-
notices,or by calling (919)
707-3601. The Davidson
River Village, LLC 1121
Ecusta Road, Brevard, NC,
28712] has requested
renewal of NPDES permit
NC0000078 for its
Wastewater Treatment
Plant, located in
Transylvania County. This
permitted facility
discharges treated leachate
and stormwater to the
French Broad River, a class
B water in the French Broad
River Basin. Some of the
parameters in the permit are
water quality limited. This
discharge may affect future
allocations in this segment
of the French Broad River.
M6/14/1TC-76217
NORTH CAROLINA
TRANSYLVANIA COUNTY
Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified, and
authorized by law to administer oaths, personally
appeared Connie D. Case, who being first duly
sworn, deposes and says: that she is (Owner, partner,
publisher, or other officer or employee authorized to
make this affidavit) of The Transylvania Times,
published, issued, and entered as second class mail
in the Town of Brevard in said County and State;
that she is authorized to make this affidavit and
sworn statement; that the notice or other legal
advertisement, a true copy of which is attached
hereto, was published in The Transylvania Times on
the following dates:
June 14,2021
And that the said newspaper in which such notice,
paper, document, or legal advertisement was
published was, at the time of each and every such
publication, a newspaper meeting all of the
requirements and qualifications of Section I-597 of
the General Statutes of North Carolina and was
qualified newspaper within the meaning of Section
1-597 of the General Statutes of North Carolina.
Thi day of , 2021
Sworn
day of
D— (ak
(Signature of person making affidavit)
to and subscribed before me, this Z-3
, 2021.
Notary Public
BENJAMIN D. UPTON II
NOTARY PUBLIC
Transylvania County, IBC

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
July 15, 2021
Mr. Bernard Kelly, Site Manager
Davidson River Village, LLC
P.O Box 880
Pisgah Forest, North Carolina 28768
Subject: Response to Comments
Permit NC0000078
Davidson River Village WWTP
Transylvania County
Grade III Biological WPCS
Dear Mr. Kelly:
The Division received the letter from Davidson River Village, dated July 8,2021, regarding the
draft NPDES Permit NC0000078. Please see responses to the questions and comments
summarized below:
1. "First, Section I(A)(6)(a) of the Draft Permit discusses groundwater monitoring and
references a Sampling Plan attached as Exhibit A. This language is unchanged from the
previous permit, but the Draft Permit did not include the referenced Sampling Plan as
Exhibit A. First, DRV asks that any final permit include the referenced Exhibit A to ensure
there is no future confusion regarding its absence. Second, DRV would like to point out
one possible change to the Sampling Plan that was included with the prior permit. That
earlier Exhibit A identified three wells for sampling, two of which (designated Q88V3 and
Q88V4) have since been replaced by two new wells with different designations (ASB-02
and ASB-01). We have enclosed a new version of Exhibit A which identifies the new well
designations that correspond to the prior designations. DRV has corresponded with the
Groundwater Protection Branch to confirm that this version of the Sampling Plan
identifying the correct well designations remain approved. A copy of that correspondence
is enclosed. Based on that approval, DRV asks that a revised version of Exhibit A with the
new well designations be included with the final permit."
a. Exhibit A has been revised to reflect the current wells and the designations as
ASB-02 and ASB-01. Please see Attachment A, included in the reissued permit.
2. "Second, Section I(A)(1) of the Draft Permit continues to require monitoring for Chronic
Toxicity, and Section I(A)(2) of the Draft Permit sets a Chronic Toxicity Permit Limit. In
over 10 years of sampling DRV's monitoring has never shown a failure of the Chronic
Toxicity limit. As a result, no risk of Chronic Toxicity from DRV's effluent has been
NORTH CAROLINA
Department of Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

demonstrated by the available data, and DRV believes there is no reasonable basis for it to
be required to continue quarterly Chronic Toxicity testing as part of the renewed permit.
Accordingly, DRV asks that the Chronic Toxicity monitoring requirement and permit limit
be removed from the Draft Permit."
a. The Chronic Toxicity monitoring requirements and permit limits will remain in
the reissued permit based on the following:
i. Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at
40 CFR 122.44(1) prohibit backsliding of effluent limitations in NPDES
permits. These provisions require effluent limitations in a reissued permit
to be as stringent as those in the previous permit. There has been no
change in the type of discharge or dilution from the facility, removing the
Toxicity limits cannot justified.
ii. Per WET guidance (WET memo 8/2/199), all NPDES permits issued to
Major facilities or any facility discharging "complex" wastewater
(contains anything other than domestic waste) will contain appropriate
WET limits and monitoring requirements. If the facility's IWC is greater
than or equal to 0.25 percent, the facility will perform the "North Carolina
Ceriociaphnia Chronic Effluent Bioassay Procedure," Revised February
1998 December 2010, or subsequent versions or "North Carolina Phase II
Chronic Whole Effluent Toxicity Test Procedure," (Revised February
1998 Dec. 2010) or subsequent versions on a quarterly basis. The limit
will be stated as "shall at no time exhibit observable inhibition of
reproduction or significant mortality" at the effluent concentration
equivalent to the facility's IWC. The maximum permit limit will be 90
percent.
iii. Per 15A NCAC 02B .0508, "Specific test type, conditions, and limitations
shall be defined by permit. Toxicity limits shall be applied to all major
discharges and all discharges of complex wastewater. Toxicity limitations
and monitoring requirements may be applied to permits for other
discharges when such discharge may impair the best use of the receiving
water by the discharge of toxic substances in toxic amounts. Specific
frequency shall be defined by individual permit conditions. For most
facilities with continuous and regularly occurring discharges, frequency
will be defined as a minimum of quarterly."
NORTH CAROLIDEN
Department of Environmental ouar�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

North Carolina Department of Environmental Quality
Water Pollution Control Systems Operator Certification Commission
Roy Cooper W. Corey Basinger John Nicholson
Governor Chairman Interim Secretary
July 30, 2021
SENT VIA EMAIL TO:
Mr. Bernard M. Kelly
Davidson River Village LLC
P.O. Box 880
Pisgah Forest, North Carolina 28768-0880
Subject: Classification of Biological Water Pollution Control System
Davidson River Village WWTP
Permit Number: NC0000078
Transylvania County
Dear Mr. Kelly:
In accordance with North Carolina General Statute § 90A-37, the Water Pollution Control System Operators
Certification Commission is required to classify all water pollution control systems.
During our review of the recent draft version of this permit it was noticed that the classification in the database did
not match the classification on the draft permit sent to us for review. This led to further discussion and a review of
the records on hand. The additional documentation provided by Mr. David Franchina in a letter dated July 23, 2021
confirmed that this facility is a simple biological lagoon system and that the Operator Certification Program, in an
email dated April 15, 2014, agreed that the facility should be reclassified as a WW-I biological wastewater treatment
system. Based on this, the Water Pollution Control System Operators Certification Commission has determined that
the classification record be corrected. The subject facility is and continues to be classified a:
Grade I Biological Water Pollution Control System 15A NCAC 08G .0302(a)(2)
Effective Date: April 1, 2014
System owners of a classified system shall designate certified operators of the same type and grade as the classified
system; one ORC, and at least one backup ORC. [15A NCAC 08G .0201)
If the system owner (permittee) wishes to make any changes to the designated Operator in Responsible Charge
(ORC) or backup ORC for the subject facility, please submit an Operator Designation Form countersigned by the
appropriate operators and send it via email to: [e-mail]. Going forward, please be sure to identify
the correct classification when submitting designation forms or correspondence pertaining to this permit. A copy of
all correspondence will be placed in the permit classification file and the database corrected.
We apologize for the confusion and thank you for your prompt attention to this. If you have any questions
concerning this classification, please contact me at 919-707-9038, or via email at [e-mail].
Sincerely,
NC Operators Certification Program
ec: Landon Davidson, Supervisor, DWR, Asheville Regional Operations
Steve Reid, Supervisor, DWR Operator Certification Program
Tim Heim, DWR, Asheville Regional Operations
Charles Weaver, DWR, NPDES Permitting Unit
Doug Dowden, DWR NPDES Permitting Unit
Julia Byrd, DWR NPDES Permitting Unit
1618 Mail Service Center 1 Raleigh, North Carolina 27699-1618
919 807 6353 1 Fax [phone] http://deq.nc.gov/about/divisions/water-resources/operator-certification