NC0089532_Fact Sheet_20210916

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
DENR/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0089532
Facility Information
Applicant/Facility Name:
Tuckaseigee Water and Sewer Authority (TWSA)
Applicant Address:
1246 West Main St., Sylva, NC 28779
Facility Address:
Highway 64, east of Cashiers
Permitted Flow
0.495 MGD
Type of Waste:
Domestic/commercial
Facility/Permit Status:
Grade 2/Minor/New
County:
Jackson
Miscellaneous
Receiving Stream:
Horsepasture River
Regional Office:
Asheville
Stream Classification:
C-Tr +
USGS Quad:
Big Ridge
303(d) Listed?
No
Permit Writer:
Emily DelDuco
Richards
HUC:
03060101
Date:
3/31/2021
Sub -basin
03-13-02
I Lat. 35° 07' 46" N Long. 83° 04' 00" W
Drainage Area (mi2):
3.9
Summer 7Q 10 (cfs)
2
Winter 7Q10 (cfs)
3
30Q2 (cfs)
4.3
Average Flow (cfs):
16
IWC (%):
27
SUMMARY
This facility is to provide supplemental flow capacity for the Cashiers WWTP. TWSA's Cashiers WWTP
has reached 90% of their capacity (0.200 MGD). Cashiers is unable to expand due to reclassification of its
outfall location (the Chatooga River) as ORW. Lack of adequate sewer service in the area is limiting
growth, as TWSA is needing to deny requests for sewer allocation. The 0.495 MGD additional flow for
TWSA #6 facility (to Horsepasture River) will allow for expansion in the Cashiers Commercial Area
(-50% commercial, —50% residential). The facility will use an advanced tertiary treatment process and
UV disinfection.
EAA
The Division issued speculative limits for 0.495 MGD in April 2014. TWSA developed an Engineering
Alternative Analysis (EAA) for the proposed discharge. The Cashiers WWTP currently serves
approximately 250 customers. Current flows average 0.102 MGD during high season. TWSA holds
requested allocations for connecting to the sewer system of 0.104 MGD. Future flow needs for the next
20 years were estimated based on requested allocations, planned development in the Cashiers Commercial
District service area and surveyed potential customers expressing desire to connect to the sewer system.
Currently most residential lots are serviced by individual septic systems, some of which are failing. The
flow projection for the 20 year period is 0.695 MGD. The existing WWTP has a capacity of 0.20 MGD,
the new plant will treat the remaining 0.495 MGD.
The permittee was required to re -submit an EAA because they allowed their permit to expire prior to
applying for an AtoC. According to 15A NCAC 02H .0318 (a), if an Authorization to Construct has not
been applied for during the term of the permit, the permit will be considered void upon expiration and
future actions must be considered as a new application. This EAA is being reviewed as a part of the "new
application" package. The original EAA for this facility was approved by DWR in 2015, so little is
changed in this updated version aside from more current population projections.
Fact Sheet
NPDES NC0089532
Page 1

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
The following alternatives were considered by TWSA:
1. No action — this alternative will not meet the growth and service needs of the area. Present Worth not
applicable.
2. Optimization of WWTP — the existing facility does not have the capabilities to treat flows in excess
of 0.2 MGD. This alternative is not feasible.
3. Land application — Based on local soils, hydrology and slopes a land application system in this
region of the mountains will require 60 days storage capacity and 140 acres for operation of a spray
system. The present worth of this alternative is $23,762,105.
4. Reuse system — There are not any industrial uses or golf courses in the service area that could use
reclaimed water from the treatment system. This alternative was not considered feasible.
5. New regional WWTP — The Town of Highlands is the close treatment system in the area. The
WWTP is 11 miles away. The Town of Highlands is not supportive of regionalizing their WWTP.
The present worth of this alternative is $23,830,610.
6. Upgrade existing plant to 0.695 MGD, discharge 0.0495 MGD to Horsepasture River — The existing
treatment system would be expanded to 0.695 MGD using a Membrane Bioreactor. Due to the
limitation of space it is the only technology that could be used for expansion. Under this alternative
0.2 MGD will be discharged to Chattooga River and 0.495 MGD to Horsepasture River. The present
worth of this alternative is $11,363,624.
7. New 0.495 MGD WWTP discharging to Horsepasture River — The existing WWTP discharges to the
Chattooga River which is classified as ORW. Under existing rules no expansions are allowed in
ORW waters. The proposed discharge is to Horsepasture River is downstream at the end of the
service area. The present worth of this alternative is $10,271,391.
The construction of a new 0.495 MGD WWTP discharging to Horsepasture River is the most
economically and environmentally feasible of the options evaluated. The preliminary treatment system
description includes equalization, tertiary treatment and UV disinfection.
RECEIVING STREAM
Horsepasture River is located within the Savannah River Basin, subbasin 03-13-02, stream index 4-13-
(0.5), HUC 03060101. Horsepasture River has a classification of C, TR +, which is subject to special
management strategy specified in 15A NCAC 2B .0225 (13), the Outstanding Resource Wastewater Rule.
PERMIT LIMITS AND CONDITIONS
As specified in 15A NCAC 2B .0225 (13) all new or expanding discharges to this section of Horsepasture
River shall comply with the following requirements:
(A) Oxygen Consuming Wastes: Effluent limitations shall be as follows: BOD = 5 mg/l, and NH3-N = 2
mg/l;
(B) Total Suspended Solids: Discharges of total suspended solids (TSS) shall be limited to effluent
concentrations of 10 mg/1 for trout waters and to 20 mg/l for all other waters except for mining
operations, which will be held to their respective NPDES TSS permit limits;
(C) Nutrients: Where nutrient overenrichment is projected to be a concern, effluent limitations shall be
set for phosphorus or nitrogen, or both; and
(D) Volume: The total volume of treated wastewater for all discharges combined shall not exceed 25
percent of the total instream flow in the designated ORW under 7Q10 conditions.
The limits for BOD, TSS and ammonia follow the requirements in the rule. At the designated ORW the
total volume of wastewater is 24%.
Other permit limits and conditions:
• WET: The draft permit will not include Whole Effluent Toxicity test since it is not required for
minor facilities.
• TRC: Since disinfection will be accomplished using UV no limit for total residual chlorine was
included.
• Instream monitoring: The permit includes instream monitoring for temperature and dissolved
oxygen as per 15A NCAC 2B .0200.
Fact Sheet
NPDES NC0089532
Page 2

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
• Mercury: Since this is a new facility and is less than 1 MGD the implementation guidance for the
statewide Mercury TMDL requires one sample every 5 years.
• The permit includes a special condition with requirements for submitting electronic DMRs.
Table 1. Summary of nronosed Hermit limits and monitorin
Parameters Affected
Permit Limit/Condition
Basis for Condition
Flow
0.495 MGD
Design flow; T15A 2B .0505
BOD5
5 mg/1 MA
7.5 mg/1 WA
Management Strategy from 15A NCAC 2B
.0225 (13)
NH3-N
2 mg/1 MA
6 mg/1 WA
Management Strategy from 15A NCAC 2B
.0225 (13)
TSS
10 mg/1 MA
15 mg/1 WA
Management Strategy from 15A NCAC 2B
.0225 (13)
Fecal coliform
200/100 ml MA
400/100 ml WA
State WQ standards, 15A 2B .0200
Dissolved Oxygen
6 mg/1 DM
State WQ standards, 15A NCAC 2B .0200
Temperature
Daily Monitoring
15A NCAC 02B .0508
Total Nitrogen/Total
Phosphorus
Monthly monitoring
15A NCAC 02B .0508
MA — Monthly Average WA — weekly average DM — Daily Maximum
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Emily D. Richards at [e-mail] or 919-707-9125.
Fact Sheet
NPDES NC0089532
Page 3

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
Invoice / Affidavit
Crossroads Chronicle
P.O. Box 1040 Cashiers North Carolina 28717
Phone: [phone]
Fax: [phone]
STATE OF NORTH CAROLINA
JACKSON COUNTY
AFFIDAVIT OF PUBLICATION Personally appeared before the undersigned, Rachel
Hoskins, who having been duly sworn on oath that she is Regional Publisher of
The Crossroads Chronicle, and the following legal advertisement was published
in The Crossroads Chronicle newspaper, and entered as second class mail in the
Town of Cashiers in said county and state; and 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
Crossroads Chronicle newspaper on the following dates:
WASTE WATER PERMIT TWSA
NC0089532
07/21/2021
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 the requirements and qualifications of
Section I-597 of the General Statues of North Carolina and was a qualified
newspaper within the meaning of the Section I-597 of the General Statues of
North Carolina.
Sworn to and subscribed before me this 21st day of July, 2021
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
NC0089532 TWSA WWTP #6
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. Additionai information on
NPDES permits and this notice
may be found on our website:
http://deq.nc.gov/about/divisions/
water-resources/water-resou roes -
perm its/wastewater-
b ranch/npdes-wastewater/public-
notices,or by calling (919) 707-
'3601. NPDES Permit Number
NC0089532: Tuckaseigee Water
and Sewer Authority (1246 West
Main Street, Sylva, NC) has
requested renewal of the permit
for its WWTP in Jackson County.
This facility will discharge treated
domestic wastewater to
Horsepasture River in the
Savannah River Basin. Currently,
BOD, Ammonia, and TSS are
water quality limited. This
discharge may affect future
allocations in this segment of
Horsepasture River.
07/21/21 #651007
Y ���2L /�K • Z-e"-;„My Commission Expires :1776,4 146 C2Lf, old .0
Notary Public
Filed with: NCDENR- DIV WATER RESOURCES
Address: 1617 MAIL SERVICE CENTER RALEIGH NC 27699
Date: 07/21/2021
TOTAL COST: $53.91

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Dan Harbaugh
Tuckaseigee Water and Sewer Authority
1246 W Main St
Sylva, NC 28779
NORTH CAROLINA
Environmental Quality
6/17/2020
Subject: Request for Additional Information
Draft NPDES Permit NC0089532
TWSA WWTP #6
Jackson County
Dear Mr. Harbaugh:
The Division has received and reviewed the request for the renewal of the NPDES wastewater permit
for Tuckaseigee Water and Sewer Authority's TWSA WWTP #6 facility in Jackson County. The
previous version of this permit, issued on July 6, 2015, required approval of a new Authorization to
Construct and submittal of a signed engineering certificate before any discharge of wastewater.
Review of our records indicated that an ATC Permit was not applied for or issued during the term of
this permit.
According to 15A NCAC 02H .0138 (a), for ATC permits the following is required:
(a) Required. After an NPDES permit has been issued by the Division of Environmental
Management in accordance with this Section, construction of wastewater treatment
facilities or additions thereto shall not begin until final plans and specifications have been
submitted to and an Authorization to Construct has been issued to the permittee by the
Division of Environmental Management. If an Authorization to Construct has not been
applied for in accordance with the requirements of the NPDES permit during the term of
the permit, the permit will be considered void upon expiration and future actions will be
considered as a new application.
Please submit an Authorization to Construct application for this facility to DWR before the
expiration of your permit on July 31, 2020.
Without an ATC Permit, this permit is considered void, and any application will be processed as a new
application. The term "New" is defined according to 15A NCAC 02H .0103 (16) as follows:
(16) "New", with respect to implementing the NPDES permitting program, means:
(a) Proposed facilities that do not have a NPDES Permit nor have any facilities constructed.
(b) Facilities which physically exist, however are illegally constructed, i.e., no required
agency approvals.
(c) Facilities which have received an NPDES Permit and have received an Authorization to
Construct but have not begun significant construction of any wastewater treatment facilities
within the term of the current permit.
Any increases in treatment plant hydraulic capacity, which has not received an
Authorization to Construct shall be considered new and new effluent limitations and other
requirements, if applicable, would be imposed for the entire facility.
D_EQ
e .rbn nt ofE aw
Oepnrhrtanl D<Envlommenlaf 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

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
In order to process this permit renewal application as a new permit application, the Division requires
an Engineering Alternatives Analysis (EAA). Given the many years passed since any alternatives to a
direct discharge have been evaluated for this facility, an updated EAA would be prudent. Economic
costs, best available technology, and availability of a connection to a POTW may have changed over
time.
The Division has reviewed your application and public comments for the draft permit. To enable us to
complete our review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 2H .0105, please provide
additional or revised information to address the following comments:
1. Complete an Engineering Alternatives Analysis (EAA): The Division requires applicants to
fully document and exhaust all alternatives to surface water discharge [G.S. § 143-215.1(b)(a)
and 15A NCAC 2H .0105 (c)(2)]. The EAA should include boring logs and/or other
information indicating that a subsurface system is neither feasible nor practical as well as
written confirmation indicating that connection to a POTW is not an option. For the non -
discharge alternatives, please demonstrate whether or not the physical size of the site is
prohibitive, and whether or not the resulting loading rate is prohibitive based on site specific
soil conditions. For your reference, the "Engineering Alternatives Analysis (EAA) Guidance
Document" is enclosed. Please complete and return Attachment A. Local Governments Review
Form (page 8). The EAA should also include a present value of costs analysis as outlined in the
Division's EAA guidance. Each alternative should be thoroughly evaluated and each
conclusion should be substantiated by appropriate documents and itemized budgets
demonstrating that alternatives are cost prohibitive.
If no response is received within 60 calendar days [per 15A NCAC 2H.0107(b)], the project will be
deactivated and withdrawn from our review process. If you have any questions, please contact Emily
DelDuco at 919-707-9125 or email at [e-mail].
ec: NPDES Program Files
DWR/ARO
Sincerely,
EDocuSigned by:
8328B44CE9EB4A1...
John E. Hennessy, Supervisor
Compliance & Expedited Permitting Unit
Division of Water Resources, NCDEQ
Page 2 of 2

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
Tuckaseigee Water & Sewer Authority
Serving Jackson County
1246 West Main Street
Sylva, NC 28779
Phone: [phone] • Fax: [phone]
February 25, 2021
Mr. John Hennessy, Supervisor
NPDES Compliance and Expedited Permitting Unit
Division of Water Resources
North Carolina Department of Environmental Quality
512 North Salisbury Street (9th Floor Archdale Building)
Raleigh, North Carolina 27604
RE: Response to Request for Additional Information
TWSA WWTP #6 (NPDES Permit NC0089532)
Tuckaseigee Water and Sewer Authority
Jackson County, North Carolina
Dear Mr. Hennessy,
Tuckaseigee Water and Sewer Authority (TWSA) is now in possession of your Request for
Additional Information regarding the renewal of NPDES Permit NC0089532 for WWTP #6 near
Cashiers in Jackson County. This letter, dated June 16, 2020 on the copy we were able to obtain,
was addressed to Dan Harbaugh, who left the role of Executive Director of TWSA in October of
2019. His duties were assumed by Interim Executive Director Dan Schaeffer, who was in turn
replaced by myself, Daniel Manring, in March of 2020.
We have searched our files and cannot find the June 16, 2020 letter or any record that the
Authority received this correspondence. No one at TWSA was aware that a Request for Additional
Information had been made until February 18, 2021, when our consultant, McGill Associates,
accessed NCDEQ's Laserfiche Document Center and saw that a new document, placed in the
center's database December 9, 2020, was available for viewing and download. Prior to this
discovery, the latest correspondence with NCDEQ regarding this application was a letter from
Wren Thredford dated April 15, 2020 stating that "Per G.S. 150B-3 your current permit does not
expire until a permit decision on the application is made." We considered this statement to
constitute an extension of the term of the NPDES permit pending processing of the renewal
application.
Mr. Thredford's notification and affirmation that the permit was still in effect was key to the timing
of our submittal of the Authorization to Construct application. We were unaware of your June 16,
2020 communication requesting that the Authorization to Construct application be submitted
before the original expiration date of the NPDES permit, July 31, 2020. We submitted the
application under the assumption that the term had been extended while the renewal application
was being processed. Authorization to Construct No. 089532A01 for WWTP #6 was approved on
January 7, 2021.

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
Mr. John Hennessy
February 25, 2021
Page 2 of 2
Given the operational difficulties experienced by both NCDEQ and TWSA due to the ongoing
pandemic and its impacts on mail delivery and other communications at both of our organizations
as well as TWSA's recent leadership transition, we ask for the Division's understanding and
request that our NPDES renewal application be considered active and under review pending our
response to your Request for Additional Information, which you will receive within 60 calendar
days of today's date.
TWSA expended considerable resources and undertook an exhaustive evaluation of alternatives
and a comprehensive public outreach process in securing the Horsepasture discharge permit.
Considering the miscommunication that has obviously occurred, it would be an unfair burden on
the Authority to have to undertake a "new" application process for our Horsepasture discharge. It
should also be considered that this project has been under development for over 15 years. The
Horsepasture WWTP is essential to the Cashiers area and its citizens. Potential customers for
this facility were identified over 10 years ago and we are receiving a significant number of requests
already for services this facility will provide.
Of additional importance is the fact that TWSA has secured funding for this project and a delay in
our ability to proceed could endanger that funding. We seek the Division's help in addressing this
important concern.
We would welcome the opportunity to discuss this situation and cooperatively seek a reasonable
solution to this issue. Please contact me to schedule a meeting to discuss this permit.
Sincerely,
Tuckaseigee Water and Sewer Authority
Daniel Manring
Executive Director
Ec: John Hennessy, john.hennessyncdenr.qov
Kyle Seaman, PE, kyle.seaman(a�mcgillassociates.com
Forrest Westall, PE, forrest.westall(a mcgillassociates.com
Tanya Tallent, thallla'�twsanc.us

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
Daniel Manring
Tuckaseigee Water and Sewer Authority
1246 W Main St
Sylva, N.C. 28779
Dear Mr. Manring:
NORTH CAROLINA
Environmental Quality
Subject: Letter Response: Request for Additional
Information
Draft NPDES Permit NC0089532
TWSA WWTP #6
Jackson County
Thank you for your response to the Division's request for additional information. Our rules
require that an Authorization to Construct must be applied for during the term of the permit [15A
NCAC 02H .0318]. An Authorization to Construct was not applied for prior to the permitted
expiration date (July 31, 2020), so your application must be treated as "new".
After reviewing the rules governing the issuance of NPDES permits, the Division has
determined that an Engineering Alternatives Analysis (EAA) must be submitted [G.S. § 143-
215.1(b)(a) and 15A NCAC 2H .0105 (c)(2)]. While we understand that communication was
complicated by a change in personnel, we are not able to waive this requirement.
Tuckaseigee Water and Sewer Authority last submitted an EAA for this facility in 2015.
Economic costs, best available technology, and availability of a connection to a POTW may have
changed over time. Please submit an updated EAA to accompany your application as soon as
possible so that the Division can proceed toward the issuance of this permit. When your complete
application package is received, the Division will make every effort to complete its review as
quickly as possible.
If you have any questions, please contact Emily DelDuco at [e-mail].
ec: NPDES Program Files
DWR/ARO
NORTH CAROLINAD_ E
Depamnent of Environmental flualiry
Sincerely,
John E. Hennessy, Supervisor
Compliance & Expedited Permitting Unit
Division of Water Resources, NCDEQ
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

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
Daniel Manring
Tuckaseigee Water and Sewer Authority
1246 W Main St
Sylva, N.C. 28779
Dear Mr. Manring:
NORTH CAROLINA
Environmental Quality
Subject: Letter Response: Request for Additional
Information
Draft NPDES Permit NC0089532
TWSA WWTP #6
Jackson County
Thank you for your response to the Division's request for additional information. In
accordance with 15A NCAC 02H .0318, an Authorization to Construct must be applied for during the
term of the permit. A complete review of files revealed that an Authorization to Construct was not
applied for prior to the permitted expiration date (July 31, 2020). Therefore, more information is
needed to continue processing your application.
In accordance with G.S. § 143-215.1(b)(a) and 15A NCAC 2H .0105 (c)(2), an Engineering
Alternatives Analysis (EAA) must be submitted. Tuckaseigee Water and Sewer Authority last
submitted an EAA for this facility in 2015. Economic costs, best available technology, and
availability of a connection to a POTW may have changed over time. Please submit an updated
EAA to accompany your application as soon as possible so that the Division can proceed toward
the issuance of this permit. When your complete application package is received, the Division will
make every effort to complete its review as quickly as possible.
If you have any questions, please contact Emily DelDuco at [e-mail].
ec: NPDES Program Files
DWR/ARO
NORTH CAROLINAD_ E
Depamnent of Environmental flualiry
Sincerely,
John E. Hennessy, Supervisor
Compliance & Expedited Permitting Unit
Division of Water Resources, NCDEQ
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

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
From: Xiao, Min
To: DelDuco, Emily
Cc: Hennessy, John; Weaver, Charles
Subject: RE: [External] NC0089532 TWSA No. 6 Horsepasture
Date: Thursday, February 18, 2021 12:35:30 PM
Attachments: imaoe003.onq
image004.pnq
imaae005.onq
NC0088901 Correspondence 20200730.pdf
Emily,
Thank you for responding to the email. I just got out of an EPA training.
McGill applied for an ATC in August 2020 on behalf of TWSA. I noticed that they had an expired
NPDES permit but had not applied for an ATC prior to the permit expiration date. Fortunately, I was
able to find a similar case in LF for NC0089532. Charles brought up a solution for the issue, which is
that the facility needs to apply for an ATC, then the permit can be renewed without starting from
scratch on the NPDES permit. Please see the attachment for more details.
Please let me know if we are doing this consistantly to other facilities with the similar issue (permit
expired but no ATC has been applied), since it appears we have 20+ facilities statewide having the
same issue.
Thanks,
Min Xiao, El
Environmental Engineer
NPDES Industrial Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919-707-3644
[e-mail]
512 North Salisbury St.
1617 Mail Service Center, Raleigh, NC, 27699-1617
DEQ4
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: DelDuco, Emily <[e-mail]>
Sent: Thursday, February 18, 2021 11:47 AM
To: Michael Whittenburg <[e-mail]>; Xiao, Min
<[e-mail]>
Cc: Kyle Seaman <[e-mail]>; Hennessy, John

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
<[e-mail]>
Subject: RE: [External] NC0089532 TWSA No. 6 Horsepasture
Hi Michael,
Your impression is correct. An Authorization to Construct was required prior to the expiration of
your permit, per 15A NCAC 02H .0138 (a):
a. Required. After an NPDES permit has been issued by the Division of Environmental
Management in accordance with this Section, construction of wastewater treatment
facilities or additions thereto shall not begin until final plans and specifications have been
submitted to and an Authorization to Construct has been issued to the permittee by the
Division of Environmental Management. If an Authorization to Construct has not been
applied for in accordance with the requirements of the NPDES permit during the term of
the permit, the permit will be considered void upon expiration and future actions will be
considered as a new application.
Your permit is considered void as of its expiration on July 31, 2020. In order to operate this WWTP,
you must submit a new application package. This includes an Engineering Alternatives Analysis to
evaluate feasibility of alternatives to direct discharge to surface water. The EAA that was originally
submitted to secure this permit will need to be updated to reflect current information, as economic
costs, available technology, and availability of a connection to a POTW may have changed over time.
Regards,
Emily DelDuco
Environmental Specialist II
Division of Water Resources
Department of Environmental Quality
919-707-9125
emily.delduco(ncdenr.gov
-'?Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Michael Whittenburg<[e-mail]>
Sent: Thursday, February 18, 2021 10:11 AM
To: Xiao, Min <[e-mail]>
Cc: DelDuco, Emily <Emily.DelDucoPncdenr.gov>; Kyle Seaman

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
<kyle.seaman@ mcgillassociates.com>
Subject: [External] NC0089532 TWSA No. 6 Horsepasture
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Min,
While researching another question I checked the LaserFiche for the Horsepasture WWTP
and I'm confused by what I am seeing.
From what I am reading, TWSA applied for permit renewal prior to expiration of their
discharge permit and were informed of what appear to be two conflicting pieces of
information:
• The current permit does not expire until a decision on the application is made.
• An Authorization to Construct application for the facility must be submitted before "the
expiration of your permit on July 31, 2020."
The A to C application was submitted on August 18, 2020. At that time a decision on the
application had not yet been made, which according to the attached letter dated April 15,
2020, indicates that the discharge permit was still in effect.
At this point in the process we appear to have Authorization to Construct, but no discharge
permit. I am hoping this impression is inaccurate.
What can you tell me about our current ability to bid, construct, and operate this WWTP?
Thank you,
mcgdl
Simpirq
Communities
T6geUxr
Michael Whittenburg, PE
Project Engineer
McGill Associates, P.A.
55 Broad Street, Asheville, NC 28801
T 828.252.0575 x177
D 828.412.4599
michael.whittenburg©mcgillassociates.com
mcgillassociates.com

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Tuckaseigee Water & Sewer Authority
Attn: Daniel Manring, Executive Dir.
1246 W Main St
Sylva, NC 28779
Subject: Permit Renewal
Application No. NC0089532
TWSA WWTP #6
Jackson County
Dear Applicant:
NORTH CAROLINA
Environmental Quality
April 15, 2020
The Water Quality Permitting Section acknowledges the April 15, 2020 receipt of your permit renewal application and
supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting
branch. Per G.S. 150E-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deq.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
ec: WQPS Laserfiche File w/application
Wren Thedford
Administrative Assistant
Water Quality Permitting Section
North Carol re Department of EnvronmeataQua'ty I D.vson of Water Resouroes
Ashev.:e Regan& Offoe 12090 U.S. 70 Highway I Snennanoa, North Carona 28778
828-296-4530

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
April 13, 2020
NCDENR / DWQ
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
To Whom It May Concern:
Water & Sewer
Authority
TUCKASEIGEE
SERVING JACKSON COUNTY
1246 West Main Street
Sylva, NC 28779
RECEIVED
APR 15 2020
NCDEQIDWRINPDES
I would like to take a moment to introduce myself and apologize for the TWSA #6 (NC0089532)
permit renewal application being late. My name is Daniel Manring and I was just recently hired
as the Executive Director here at Tuckaseigee Water and Sewer Authority (TWSA). For the past
six months, TWSA has been going through a transition of directors.
We apologize for letting this slip, but we hope you understand the circumstances and will renew
our permit for the TWSA #6 facility. If you have any questions or concerns, please feel free to
contact me at [e-mail] or 828-586-5189 ext. 203.
Sincerely,
Gv
i
Daniel Manring
Executive Director

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
TWSA # 6. NC0089532
FORM
2A
NPDES
PERMIT ACTION REQUESTED:
Ranewll
RIVER BASIN:
Savannah River Bain
NPDES FORM 2A APPLICATION OVERVIEW
APPLICATION OVERVIEW
Form 2A has been developed in a modular format and consists of a "Basic Application Information" packet
and a "Supplemental Application Information" packet. The Basic Application Information packet is divided
into two parts. All applicants must complete Parts A and C. Applicants with a design flow greater than or
equal to 0.1 mgd must also complete Part B. Some applicants must also complete the Supplemental
Application Information packet. The following items explain which parts of Form 2A you must complete.
BASIC APPLICATION INFORMATION:
A. Basic Application Information for all Applicants. All applicants must complete questions A.1 through A.8. A treatment works
that discharges effluent to surface waters of the United States must also answer questions A.9 through A.12.
Additional Application Information for Applicants with a Design Flow > 0.1 mgd. All treatment works that have design flows
greater than or equal to 0.1 million gallons per day must complete questions 6.1 through B.6.
Certification. All applicants must complete Part C (Certification).
SUPPLEMENTAL APPLICATION INFORMATION:
D. Expanded Effluent Testing Data. A treatment works that discharges effluent to surface waters of the United States and meets
one or more of the following criteria must complete Part D (Expanded Effluent Testing Data):
1. Has a design flow rate greater than or equal to 1mgd,
2. Is required to have a pretreatment program (or has one in place), or
3. Is otherwise required by the permitting authority to provide the information.
Toxicity Testing Data. A treatment works that meets one or more of the following criteria must complete Part E (Toxicity Testing
Data):
1. Has a design flow rate greater than or equal to 1 mgd,
2. Is required to have a pretreatment program (or has one in place), or
3. Is otherwise required by the permitting authority to submit results of toxicity testing.
Industrial User Discharges and RCRA/CERCLA Wastes. A treatment works that accepts process wastewater from any
significant industrial users (SIUs) or receives RCRA or CERCLA wastes must complete Part F (Industrial User Discharges
and RCRA/CERCLA Wastes). SlUs are defined as:
1. All industrial users subject to Categorical Pretreatment Standards under 40 Code of Federal Regulations (CFR) 403.6 and
40 CFR Chapter I, Subchapter N (see instructions); and
2. Any other industrial user that:
a. Discharges an average of 25,000 gallons per day or more of process wastewater to the treatment works (with certain
exclusions); or
b. Contributes a process wastestream that makes up 5 percent or more of the average dry weather hydraulic or organic
capacity of the treatment plant; or
c. Is designated as an SIU by the control authority.
. Combined Sewer Systems. A treatment works that has a combined sewer system must complete Part G (Combined Sewer
Systems).
ALL APPLICANTS MUST COMPLETE PART C (CERTIFICATION)
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 1 of 22

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
TWSA #6, NC0089532
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Savannah River
BASIC APPLICATION INFORMATION
PART A. BASIC APPLICATION INFORMATION FOR ALL APPLICANTS:
All treatment works must complete questions A.1 through A.8 of this Basic Application Information Packet.
A.1. Facility Information.
Facility Name TWSA Plant # 6-Horsepasture River WWTP
Mailing Address 1246 West Main St.
Sylva, NC 28779
Contact Person Stan Bryson
Title Wastewater Plant Operations Superintendent
Telephone Number [phone]
Facility Address Highway 64 East of Cashiers
(not P.O. Box) Sylva, NC 28779
A.2. Applicant Information. If the applicant is different from the above, provide the following:
Applicant Name I uckaseigee Water & Sewer Authority
Mailing Address Same as above
Contact Person Same as above
Title
Telephone Number ( )
Is the applicant the owner or operator (or both) of the treatment works?
X owner X operator
Indicate whether correspondence regarding this permit should be directed to the facility or the applicant.
0 facility X applicant
A.3. Existing Environmental Permits. Provide the permit number of any existing environmental permits that have been issued to the treatment works
(include state -issued permits).
NPDES NC 0089532 PSD
UIC Other
RCRA Other
A.4. Collection System Information. Provide information on municipalities and areas served by the facility. Provide the name and population of each
entity and, if known, provide information on the type of collection system (combined vs. separate) and its ownership (municipal, private, etc.).
Name Population Served Type of Collection System Ownership
Tuckaseigee Water & Sewer Auth. Est 100-1000
Total population served est 100-1000
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page 2 of 22

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
WSA #6, NG0089532
A.S. Indian Country.
PERMIT ACTION REQUESTED:
Renewai
RIVER BASIN:
Savannah River
a. Is the treatment works located in Indian Country?
Yes No •
b- Does the treatment works discharge to a receiving water that is either in Indian Country or that is upstream from (and eventually flows
through) Indian Country?
Yes No
A.6. Flow. Indicate the design flow rate of the treatment plant (i.e., the wastewater flow rate that the plant was built to handle). Also provide the
average daily flow rate and maximum daily flow rate for each of the last three years. Each year's data must be based on a 12-month time period
with the 12'h month of "this year" occurring no more than three months prior to this application submittal.
a. Design flow rate mgd
Two Years Ago Last Year This Year
b. Annual average daily flow rate 0.0 mgd 0.0 mqd 0.0 mqd
c. Maximum daily flow rate 0.0 mqd 0.0 mqd 0.0 mqd
A.7. Collection System. Indicate the type(s) of collection system(s) used by the treatment plant. Check all that apply. Also estimate the percent
contribution (by miles) of each.
Separate sanitary sewer
Combined storm and sanitary sewer
A.B. Discharges and Other Disposal Methods.
Ok
a. Does the treatment works discharge effluent to waters of the U.S.? Yes when operational No
If yes, list how many of each of the following types of discharge points the treatment works uses:
i. Discharges of treated effluent
ii. Discharges of untreated or partially treated effluent
iii. Combined sewer overflow points
iv. Constructed emergency overflows (prior to the headworks)
v. Other
b. Does the treatment works discharge effluent to basins, ponds, or other surface impoundments
that do not have outlets for discharge to waters of the U.S.? Yes
If yes, provide the following for each surface impoundment:
Location:
No
Annual average daily volume discharge to surface impoundment(s) mgd
Is discharge continuous or intermittent?
c. Does the treatment works land -apply treated wastewater? Yes No
If yes, provide the following for each land application site:
Location:
Number of acres:
Annual average daily volume applied to site:
Is land application
continuous or intermittent?
d. Does the treatment works discharge or transport treated or untreated wastewater to another
treatment works?
mgd
Yes No
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 3 of 22

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
TWSA #6, NC0089532
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Savannah River
If yes, describe the mean(s) by which the wastewater from the treatment works is discharged or transported to the other treatment works
(e.g., tank truck, pipe).
If transport is by a party other than the applicant, provide:
Transporter Name
Mailing Address
Contact Person
Title
Telephone Number j
For each treatment works that receives this discharge, provide the following:
Name
Mailing Address
Contact Person
Title
Telephone Number j
If known, provide the NPDES permit number of the treatment works that receives this discharge
Provide the average daily flow rate from the treatment works into the receiving facility. mgd
e. Does the treatment works discharge or dispose of its wastewater in a manner not included
in A.8. through A.8.d above (e.g., underground percolation, well injection):
If yes, provide the following for each disposal method:
Description of method (including location and size of site(s) if applicable):
❑ Yes X No
Annual daily volume disposed by this method:
Is disposal through this method continuous or I ] intermittent?
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page 4 of 22

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
TWSA #6, NC0089532
WASTEWATER DISCHARGES:
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Savannah River
If you answered "Yes" to question A.8.a, complete questions A.9 through A.12 once for each outfall (including bypass points) through
which effluent is discharged. Do not include information on combined sewer overflows in this section. If you answered "No" to question
A.8.a, go to Part B, "Additional Application Information for Applicants with a Design Flow Greater than or Equal to 0.1 mgd."
A.9. Description of Dutfall.
a. Outfall number
b. Location 28717
(City or town, if applicable) (Zip Code)
Jackson
(County)
NC
(State)
35° 07' 46" 83° 04' 00"
(Latitude) (Longitude)
c. Distance from shore (if applicable) ft.
d. Depth below surface (if applicable) ft.
e. Average daily flow rate mgd
f. Does this outfall have either an intermittent or a periodic discharge? Yes X No (go to A.9.g.)
If yes, provide the following information:
Number f times per year discharge occurs:
Average duration of each discharge:
Average flow per discharge: mgd
Months in which discharge occurs:
g. Is outfall equipped with a diffuser? ❑ Yes N/A
A.10. Description of Receiving Waters.
a. Name of receiving water Horseoasture River
b. Name of watershed (if known)
United States Soil Conservation Service 14-digit watershed code (if known):
03060101010020
c. Name of State Management/River Basin (if known): Savannah River
United States Geological Survey 8-digit hydrologic cataloging unit code (if known): 03060101
d. Critical low flow of receiving stream (if applicable)
acute cfs chronic cfs
e. Total hardness of receiving stream at critical low flow Of applicable): mg/I of CaCO3
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 5 of 22

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
TWSA #6, NC0089532
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Savannah River
A.11. Description of Treatment
a. What level of treatment are
Primary
Advanced
b. Indicate the following removal
Design BOD5 removal
Design SS removal
Design P removal
Design N removal
Other
c. What type of disinfection
provided? Check all that apply.
Secondary
Other. Describe:
rates (as applicable):
or Design CBOD5 removal
outfall? If disinfection
Plant has not yet been built and construction plans are not finalized.
varies
ok
%
ok
%
%
is used
have
for the effluent from this
by season, please describe:
Yes No
Yes No
If disinfection is by chlorination
Does the treatment plant
is dechlorination used for this outfall?
post aeration?
A.12. Effluent Testing Information.
parameters. Provide
discharged. Do not include
All Applicants that
the indicated effluent testing
information on combined
conducted using
other appropriate QA/QC
data must be based
discharge to waters of the US must provide
required by the permitting authority
sewer overflows in this section.
40 CFR Part 136 methods. In addition, this
requirements for standard methods for analytes
on at least three samples and must be no
effluent testing data for the following
for each outfall through which effluent is
All information reported must be based on data
data must comply with QA/QC requirements of
not addressed by 40 CFR Part 136. At a
more than four and one-half years apart.
collected through analysis
40 CFR Part 136 and
minimum, effluent testing
Outfall number:
PARAMETER
MAXIMUM DAILY VALUE
AVERAGE DAILY VALUE
Value
Units
Value
Units
Number of Samples
pH (Minimum)
s.u.
pH (Maximum)
s.u.
Flow Rate
0
Temperature (Winter)
0
Temperature (Summer)
0
' For pH please report a minimum and a maximum daily value
POLLUTANT
MAXIMUM DAILY
DISCHARGE
AVERAGE DAILY DISCHARGE
ANALYTICAL
METHOD
MLJMDL
Conc.
Units
Conc.
Units
Number of
Samples
CONVENTIONAL AND NON CONVENTIONAL COMPOUNDS
BIOCHEMICAL OXYGEN
DEMAND (Report one)
BOD5
0
CBOD5
0
FECAL COLIFORM
0
TOTAL SUSPENDED SOLIDS (TSS)
0
END OF PART A.
REFER TO THE APPLICATION OVERVIEW (PAGE 1) TO DETERMINE WHICH OTHER PARTS
OF FORM 2A YOU MUST COMPLETE
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page 6 of 22

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
WSA #6, NC0089532
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Savannah River
BASIC APPLICATION INFORMATION
PART B. ADDITIONAL APPLICATION INFORMATION FOR APPLICANTS WITH A DESIGN FLOW GREATER THAN OR
EQUAL TO 0.1 MGD (100,000 gallons per day).
All applicants with a design flow rate >_ 0.1 mgd must answer questions B.1 through B.6. All others go to Part C (Certification).
B.1. Inflow and Infiltration. Estimate the average number of gallons per day
gpd
that flow into the treatment works from inflow and/or infiltration.
area extending at least one mile beyond facility property boundaries. This
(You may submit more than one map if one map does not show the entire
the treatment works and the pipes or other structures through which
outfalls from bypass piping, if applicable.
that are: 1) within Y. mile of the property boundaries of the treatment
is stored, treated, or disposed.
under the Resource Conservation and Recovery Act (RCRA) by truck, rail,
the treatment works and where it is treated, stored, and/or disposed.
processes of the treatment plant, including all bypass piping and all
balance showing all treatment units, including disinfection (e.g.,
flow rates at influent and discharge points and approximate daily flow
diagram.
and effluent quality) of the treatment works the responsibility of a
and describe the contractor's responsibilities (attach additional
Briefly explain any steps underway or planned to minimize inflow and infiltration.
B.2. Topographic Map. Attach to this application a topographic map of the
map must show the outline of the facility and the following information.
area.)
a. The area surrounding the treatment plant, including all unit processes.
b. The major pipes or other structures through which wastewater enters
treated wastewater is discharged from the treatment plant. Include
c. Each well where wastewater from the treatment plant is injected underground.
d. Wells, springs, other surface water bodies, and drinking water wells
works, and 2) listed in public record or otherwise known to the applicant.
e. Any areas where the sewage sludge produced by the treatment works
f. If the treatment works receives waste that is classified as hazardous
or special pipe, show on the map where the hazardous waste enters
B.3. Process Flow Diagram or Schematic. Provide a diagram showing the
backup power sources or redunancy in the system. Also provide a water
chlorination and dechiorination). The water balance must show daily average
rates between treatment units. Include a brief narrative description of the
B.4. Operation/Maintenance Performed by Contractor(s).
Are any operational or maintenance aspects (related to wastewater treatment
contractor? Yes No
If yes, list the name, address, telephone number, and status of each contractor
pages if necessary).
Name:
Mailing Address:
Telephone Number: i L
Responsibilities of Contractor:
B.5. Scheduled improvements and Schedules of Implementation. Provide information on any uncompleted implementation schedule or
uncompleted plans for improvements that will affect the wastewater treatment, effluent quality, or design capacity of the treatment works. If the
treatment works has several different implementation schedules or is planning several improvements, submit separate responses to question B.5
for each. (If none, go to question B.6.)
a. List the outfall number (assigned in question A.9) for each outfall that is covered by this implementation schedule.
b. Indicate whether the planned improvements or implementation schedule are required by local, State, or Federal agencies.
Yes No
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page7of22

onouSignEnvelope ID: 74FAoC3B-211A-485soOo7-44uCC88ouro5
Permit NCO089632
Receiving Stream: HoresepastureKive
Drainage Basin: Savannah River Basin
Permitted Flow:
Latitude:
USGS Quad:
0125/025/0.495 [NGD
]5^O746"
Big Ridge &Cashiers
Stream Class: C Tr+
Sub -Basin:
HU[
U3'13-}
03060101
Fad|tvLocation
(not to scale)
NPQESPermit NCOO89S32—Jackson County
Page 8 of 8

DocuSign Envelope ID: 74FADC3B-211A-495B-BOD7-442CC98D27D5
FACILITY NAME AND PERMIT NUMBER:
TWSA # 6-Horsepasture River, NC0089532
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Savannah
BASIC APPLICATION INFORMATION
PART C. CERTIFICATION
All applicants must complete the Certification Section. Refer to instructions to determine who is an officer for the purposes of this
certification. All applicants must complete all applicable sections of Form 2A, as explained in the Application Overview. Indicate below which
parts of Form 2A you have completed and are submitting. By signing this certification statement, applicants confirm that they have reviewed
Form 2A and have completed all sections that apply to the facility for which this application is submitted.
Indicate which parts of Form 2A you have completed and are submitting:
Basic Application Information packet Supplemental Application Information packet:
L] Part D (Expanded Effluent Testing Data)
❑ Part E (Toxicity Testing: Biomonitoring Data)
❑ Part F (Industrial User Discharges and RCRA/CERCLA Wastes)
❑ Part G (Combined Sewer Systems)
ALL APPLICANTS MUST COMPLETE THE FOLLOWING CERTIFICATION.
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who
manage the system or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment
for knowing violations.
Name and official title Stan Bryson, WWTP Operations Supt.
Signature
Telephone number [phone]
Date signed 4/9/2020
Upon request of the permitting authority, you must submit any other information necessary to assure wastewater treatment practices at the treatment
works or identify appropriate permitting requirements.
SEND COMPLETED FORMS TO:
NCDENR/ DWQ
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 9 of 22