NC0037371_Permit (Issuance)_20040806

NPDES DOCUMENT !;CANNING COVER SHEET
NPDES Permit:
NC0037371
North Iredell High School WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
August 6, 2004
This document is printed on reuse paper - ignore any
content on the resrerse side

Michael F. Easley, Governor
State of North Carolina
Wiliam G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
August 6, 2004
Mr. Dennis Gryder
Iredell Statesville Schools
1147 Salisbury Road
Statesville, North Carolina 28625
Subject: Issuance of NPDES Permit
NC0037371
North Iredell High School WWTP
lredell County
Dear Mr. Gryder:
Division personnel have reviewed and approved your application for renewal of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9,1994 (or
as subsequently amended).
This final permit includes no changes from the draft permit sent to you on June 9, 2004.
This permit includes a TRC limit that will take effect on March 1, 2006. If you wish to install
dechlorination equipment, the Division has promulgated a simplified approval process for such projects.
Guidance for approval of dechlorination projects is attached.
if any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such
demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required. If you have any questions concerning this
permit, please contact Toya Fields at telephone number [phone], extension 551.
Sincerely,
ORIGINAL SIGNED BY
Tom Belnick
Alan W. Klimek, P.E.
cc: Central Files
Mooresville Regional Office/Water Quality Section
NPDES Unit
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

Permit NC0037371
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Iredell -Statesville Schools
is hereby authorized to discharge wastewater from a facility located at
North Iredell High School
156 Raider Road
Olin
Iredell County
to receiving waters designated as Patterson Creek in the Yadkin -Pee Dee River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth
in Parts I, II, III, and IV hereof.
The permit shall become effective September 1, 2004.
This permit and the authorization to discharge shall expire at midnight on March 31, 2009.
Signed this day August 6, 2004.
ORIGINAL SIGNED BY
Torn Belnink
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0037371
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit
issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to
operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included
herein.
Iredell — Statesville Schools is hereby authorized to:
1. Continue to operate an existing 0.0125 MGD wastewater treatment plant with the following
components:
• Bar screen
• Flow equalization basin
• Aeration basin with diffused air
• Final clarifier with return sludge
• Tertiary filters
• Aerated sludge holding tank
• Tablet chlorination/dechlorination
• Flow meter
This facility is located at North Iredell High School in Olin at 156 Raider Road in Iredell
County.
2. Discharge from said treatment works at the location specified on the attached map into
Patterson Creek, classified C waters in the Yadkin -Pee Dee River Basin.
Y:;

North Iredell High School - NC0037371
USGS Quad Name: Harmony
Receiving Stream: Patterson Creels
Stream Class: C
Subbasin: Yadkin -Pee Dee / 03-07-06
Lat.: 35°55'30"
Long.: 80°52'00"
1 N
Discharge
location
Facility
Location
Not to SCALE

Permit NC0037371
A.(1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall serial number 001. Such discharges shall be limited
and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTIC :
,•.ti
x, —
MONITORING REQ REMENTS
thly
fi: a
Weekly
Average
Daily
Maxi
Measurement
Frequency
i " '
` , h _ :
Sample
Location'
Flow
0.0125 MGD
Weekly
Instantaneous
I or E
BOD, 5 day, 20°C
30.0 mg/1
45.0 mg/1
Weekly
Grab
E
Total Suspended Solids
30.0 mg/1
45.0 mg/1
Weekly
Grab
E
NH3 as N
—
Weekly
Grab
E
Fecal Coliform
(geometric mean)
200 / 100 ml
400 / 100 ml
Weekly
Grab
E
Total Residual Chlorine2
28 µg/L
2 / Week
Grab
E
Temperature
Weekly
Grab
E
pH
Between 6 and 9 s.u.
Weekly
Grab
E
Total Nitrogen
(NO2 + NO3 + TKN)
Quarterly
Grab
E
Total Phosphorus
Quarterly
Grab
E
Notes:
1. Sample locations: E — Effluent, I - Influent.
2. TRC limit will take effect March 1, 2006. Limit only applies if chlorine is used for disinfection.
There shall be no discharge of floating solids or foam visible in other than trace amounts.

Published at the Crossroads of North Carolina where I-40 and I-77 Interchange
STATESVILLE RECORD & LANDMARK
Established in 1874 A MEDIA GENERAL NEWSPAPER
P.O. BOX 1071/PHONE: [phone]/STATESVILLE, NORTH CAROLINA 28687
June 30, 2004
Dear Advertiser,
Here are your tearsheets for ads that ran in the Statesville Record & Landmark and/or the
Mooresville Tribune. Your invoice will come from a different publication. Thank you
for advertising in our papers.
Sincerely,
a Q
Pamela Waddell
Business Department
BLIC NOTICE
STATE OF
NORTH CAROLINA
ENVIRONMENTAL .
MANAGEMENT
COMMISSION /NPDES UNIT
1617 MAIL SERVICE
CENTER .F, ..,. -ra„yvt>*:s+'!:^... .a:. -".._....-
RALEIGH, NC 27699-1617 . . 1
NOTIFICATION OF INTENT
TO ISSUE A NPDES
WASTEWATER PERMIT
the basis at thorough staff
w end application cif . NC
oral Statute 143.21, Public
92-500 and other lawful
ards and regulations. the
Cardin Environmental
gement Commission pry
es to issue a National Poi;'
t Discharge Elimination
ystem (NPDES) wastewater
scharge pemvi io the• par-
s} listed below effective 45
ays from Ihe publish date of
is notice.
Mien comments regarding
the proposed permit.will be ac-
cepted until 30 days alter the
pr>blish date of this notice. Ali
eoinments received prior. to
that date are considered in the
final determinations regarding
the proposed permit. The pi -
rector of the NC Divisiari`of
Water Quality may decide to
• hold a public meeting for pro-
posed permit: shoukf the Divi-
sion receive a significant de-
gree o1 pubic interest.
Copies of the draft and other
supporting intonation on file
used to determine conditions
present in the draft permit are
available upon request and
payment of the costs of repro-
duction. Mail commerrts an -
War requests for information to
the NC Division of Water
Quality at the above address
or call ms. Carolyn Bryant at
919.733.5083, aid 520. Please
include the NPDES permit
number (attached) in any Com-
munication. Interested per-
sons may also visit the DM -
Sion of Water Quality at 512 N.
Salisbury Street, Raleigh, NC
27604-1145 between the
hours of B:00ani and 5:00pm
to review information on file.
David L Millsaps (1124 Radio
Road, Statesville, NC 28677)
has applied for renewal of
NPDES permit NC0023191 for
the Seven Cedars Mobile
Flame Park WARP 'in Iredell
1.
Li •
it Li
2004
Cc .: L.',ALITY
County. This permitted facildy
discharges .010 MGD of treat-
ed wastewater to Third Creek
in the Yadkin -Pee River Basin.
Currently 60D and total re-
sidual chlorine are water quali-
ty limited This discharge may
affect future allocations in this
portion of tha Yadkin -Pee Dee
River Basin.
Iredell-Statesville Schools
(1147 Salisbury Road. States-
ville, NC 28625) has applied
for renewal of NPDES permit
NC0037371 for the North tra-
de!! High School WWTP in Ire-
det Cdrrdy. This permitted iaa
clity discharges'.0125 MGD of
treated wastewater to Patter-
son Creek in the Yadkin Pee
Dee River Basin. ' Currently
BOD, fecal'coliiorm and total
residual are water quality
' limited. This discharge may
affect future allocations in this
• portion of the Yadkin Pee Dee
' River Basin
I June 11
TF

Pt euc NOTICE
STATEQF
I t RTHCARCLIN4
e mirts,m3vri L
NAN4G6143VT
QOVMSSICN/AFCESUNT
1617MAIL SERVICE
CENTER
R4LBt- NC 27699-1617
NOTIFICATION QF INTENT
TO ISSUE AMES
WASTEWATERFEIT
Cn the basis of thorough staff
review and application of NC
General Statute 143.21, Public
law 92-500and other lawful
stendar:Is and reg*/a icns. the
Nbrth Carolina Enviraurental
Malaga -rent Carrrissicn pro-
poses to issue a National Pd-
lutant Discharge Birrination
System (WOES) wastewater
dscharge pewit to the per-
son(s) listed below effective 45
days from the publish date of
this notice
Witten comments rega riling
the proposed pewit we7! be ac-
cepted until 30days after the
put6 hdateofttisnotice. AN
comments received prior to
that date are considered in the
final deterrrinatiars regariing
the proposed perrrit. The CI -
rector of the NC Division of
Water Quality may deride to
hold a public meeting for pro-
posed pan* Auld the C vi-
slon receive a sig1frcant
gee of public lite:est.
Copies of the draft and oth er
supporting information on file
used to d terrine motions
present in the daft pemit are
available upon request and
payment of the costs d repro-
duction. Nbrl co(rrrents an-
dorrequests for information to
the NC Division of Water
Quality at the above address
or call ms. Carolyn tty ant at
919-733-5063, ext 522 Reese
include the NPDES permit
niter (attached) in anyoan-
munication. Intereste d per
sons tray also visit the Divf-
siardW6-terQ ftyet512N
Salisbury Street, Raleigh, AC
27604-1145 between the
hours of8:00amand 5:00pm
to review iwiorrration on Re.
David L Mllsaps (1124 Radio
Road, Statesville, NC 28677)
has applied for renewal of
NFOES permt 1uC0023191 for
the Seven Cedars Mobile
Home re Park WVVfPin lredell
Cavnt y. This perrritted facility
cfsdrarg es .010 MGD of treat-
ed wastewater to Third Creek
in the Yacidn-FIe RfverBasin.
CurrenUy BQD and total re-
sidd dionne are water quell-
ty United. This cishrargemay
affect future allocations in this
pc. .:n-Pee Dee
tZasin.
lredell-Statesville Schoo a
(1147SalisbtryRbad Sides -
Vile, NC 28625) has applied
for renewal of NPDESpemit
Np0037371 for the Nrth Ire-
call l fgh School WWTPin Ire -
dell County. Tlis permitted fa -
dilly d.0125 NXI d
treated wastewater to Patter-
son Creek in the Yadkin Pee
Dee River Basin. Curren tly
BOD, fecal coliform and total _
residual are water quail ty -
linited. This discharge may —
affed future allocations in this •
ion d the Yadkin Rae Dee
Basin
NORTH CAROLINA
IREDELL COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified,
and authorized by law to administer oaths, per-
sonally appeared Kimberly P. Ownbey who
being first duly sworn, deposes and says: that
she is an employee authorized to make this
statement by Media General Newspapers, Inc.
engaged in the publication of a newspaper
known as the Statesville Record & Landmark
published, issued, and entered as second class
mail in the city of Statesville in said County adn
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 Statesville
Record & Landmark on the following dates:
and that the said newspaper in which such
notice, paper, document, or legal advertisement
was published was at the time of each and every
such publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597
of the General Statues of North Carolina and was
a qualified newspaper within the meaning of
Section 1-597 of the Greater Statues of North
Carolina.
This \_ day , 20
0_4_
`ice
&LK-
(Signature bf person
making affidvit)
Sworn to and subscribed before me, this \-1
day of "Th—L-ks 20 hk-\
MI
�/1& ,
Notary ubli o
Commission expires: 5- ( . c O- 1

SOC PRIORITY PROJECT: Yes_ No X
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: April, 2004
NPDES STAFF REPORT AND RECOMMENDATION
County: Iredell
MRO# 04-22
Permit No. NC0037371
PART I - GENERAL INFORMATION
1. Facility and address: North Iredell High School
Iredell-Statesville Schools
1147 Salisbury Road
Statesville, North Carolina 28265
I
fl
2. Date of investigation: March 24, 2004
3. Report prepared by: Samar Bou-Ghazale, Env. Engineer.I
4. Persons contacted and telephone number: Mr. Steve Pope, ORC, [phone].
5. Directions to site: From Statesville travel north on I-77 to the intersection with SR1890
(Tomlin Mill). Turn west (left) on SR 1890 and proceed to the intersection with SR 1892
(Jennings Road) SR. Turn right north (right) on SR 1892 and proceed to the intersection
with SR 1953 (Raider Road). Turn west (left) on SR 1953 and travel approximately 0.2 mile
to facility located on left (south) side of the road.
6. Discharge point(s). List for all discharge points:
Latitude: 35° 55' 30" Longitude: 80° 52' 00"
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map.
USGS Quad No.: D 15 NE USGS Name: Harmony, NC
7. Site size and expansion area consistent with application?
Yes X No_ If No, explain:
8. Topography (relationship to flood plain included): Gently rolling with moderate slopes; the
facility is not located in a flood plain.

9. Location of nearest dwelling: None within 500 feet
10. Receiving stream or affected surface waters: Patterson Creek.
a. Classification: C
b. River Basin and Subbasin No.: Yadkin -Pee Dee & 03-07-06
c. Describe receiving stream features and pertinent downstream uses: The receiving
stream is about 30-35 feet wide with considerable flow and varying in depth from 6-
12 inches. Downstream uses are typical for class "C" waters.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted: 0.0125 MGD (Ultimate Design Capacity)
b. What is the current permitted capacity of the wastewater treatment facility? 0.0125
MGD
c. Actual treatment capacity of the current facility (current design capacity)? 0.0125
MGD
d. Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two years: N/A.
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: The existing facilitiy consists of a bar screen, flow equa11ation
basin, aeration basin, clarifier, sand filter, aerated sludge holding tank, tablet
chlorinator, and effluent flow meter with chart.
f. Please provide a description of proposed wastewater treatment facilities: N/A.
g. Possible toxic impacts to surface waters: Chlorine.
h. Pretreatment Program (POTWs only): N/A.
2. Residuals handling and utilization/disposal scheme:
Sludge is removed as necessary by Lentz Septic Tank Service and disposed at the Rocky River
WWI' located in Mooresville .
3. Treatment plant classification (attach completed rating sheet): Class II (no change of rating,
no rating sheet attached).
Page 2

4. SIC Code(s): 8211
Primary: 03 Secondary:
Main Treatment Unit Code: 06007
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? N/A.
2. Special monitoring or limitations (including toxicity) requests: TRC.
3. Important SOC, JOC or Compliance Schedule dates: N/A
4. Alternative Analysis Evaluation: (Has the facility evaluated all of the non -discharge options
available. Please provide regional perspective for each option evaluated): N/A
5. Air quality and/or groundwater concerns or hazardous materials utilized at this facility that
may impact water quality, air quality or groundwater? No known air quality, groundwater
or hazardous materials concerns.
PART IV - EVALUATION AND RECOMMENDATIONS
The permittee, Iredell-Statesville School System has requested renewal of its NPDES permit
to discharge treated domestic wastewater from the wastewater treatment system serving North Iredell
High School. The WWTP was in good operational conditions at the time of the investigation. It is
requested that the TRC be limited since the monitored TRC is shown to be around 1.6 mg/l. Please
note that a stream action level of 17 µg/1 has been established for TRC to protect the receiving stream
against chronic toxicity effects and 28 µg/1 has been set as the maximum allowable effluent TRC
concentration to protect against acute toxicity effects.
Upon resolution of the TRC concern, it is recommended that the permit be renewed.
Signature of Repor'reparer
Water Qua1i{�
4-//
Date
Regional Supervisor
Page 3

Iredell-Statesville Schools
Maintenance Department
1147 Salisbury Road, Statesville, NC 28625, Phone [phone], Fax: [phone]
January 22, 2004
To: Mrs. Valery Stephens
From: Dennis Gryder
Re: North Iredell High School Treatment Plant
Please accept this renewal package for North Iredell High School treatment plant, permit
#NC0037371. There have been no changes at the facility since last issuance. Any
questions or comments please call Dennis Gryder, 704-873-3'T, at the Iredell-
Statesville Schools Maintenance Department.
Thank you.
Dennis Gryder
Plumbing/Wastewatef Supervisor

NPDES APPLICATION FOR PERMIT RENEWAL- SHORT FORM D
To be filed only by privately -owned dischargers of 100% domestic wastewater (<1 MGD flow)
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
http://h2o.enr.state.nc.us/NPDES/
North Carolina NPDES Permit Number
1. Contact Information:
Facility Name
Owner Name
Street Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Operator Name
Street Address
City
State / Zip Code
County
Telephone Number
NC00 37..E-7
Please print or type
11f0a4k, I 1.4&1 cckevi
1 J 9-7 <;-1,6 12. tati 4t'
95 f�r !fit
&aG'
(70`) 973-�73;
���� f6pg
w'si-To-ccii911 ti:44(7
Lilo
tc.aRocc
/t rye
(`7e 4) - 53q3
2. Location of facility producing discharge:
Check here if same as above ❑
Facility Name (If different from above)
Street Address or State Road
City
State / Zip Code
County
3. Reason for application:
Expansion/Modification *
Renewal
--12a411 ce.-14o d
%/oA;cco-a_i9 �
,"4 � aRC. CO
?/-
=�l
Existing Unpermitted Discharge
New Facility
* Provide a description of the expansion/modification:
Page 1 of 3 Version 12/02

NPDES APPLICATION FOR PERMIT RENEWAL- SHORT FORM D
To be filed only by privately -owned dischargers of 100% domestic wastewater (<1 MGD flow)
4. Description of the existing treatment facilities (list all installed components with
capacities):
6AR (..i2a_31A, lowee
'Flour) tkAh.{244- l fOr= 01 (ten. I txo i'L
f a.1 O .t9A -1(1 ,a--- Moto 141 a.
CIIEVZ a 4061,16 ti.teg- 1101,04,b 3oc2cfrt.--
MAI I ns ^ 900,AL
Piz
5. Description of wastewater (check all that apply):
Type of Facility Generating Wastewater
Industrial Number of Employees
Commercial Number of Employees
Residential Number of Homes
School Number of Students/Staff
Other
Describe the source(s) of wastewater (example: subdivision, mobile home park, etc.):
6.110i) 1
6... List all permits, construction approvals and/or -applications (check all that apply):.
RCRA
UIC
NPDES
PSD
NESHAPS
Permit Number
Type
Non -Attainment
Ocean Dumping
Dredge/Fill Permits
Other
Permit Number
7. Number of separate wastewater discharge pipes (wastewater outfalls):
J
S. If the facility has multiple discharge outfalls, record the source(s) of wastewater for each
outfall:
Page 2 of 3 Version 12/02

NPDES APPLICATION FOR PERMIT RENEWAL- SHORT FORM D •
To be filed only by privately -owned dischargers of 100% domestic wastewater (<1 MGD flow)
9. Name of -receiving stream(s) (Provide a map showing the exact location of each ouifall):
10. Is this facility located on Native American lands? (check one)
YES ❑ NO IZ
I certify that I am familiar with the information contained in the application and that to
the best of my knowledge and belief such information is true, complete, and accurate.
4!-S 11).
Printed Name of Person Signing /
ladO 04462-1/4)fric
Title
- AZZ-OY
S' e o of Date Signed
North Carolina General Statute 143-215.6(b)(2) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or
imprisonment not more than 5 years, or both for a similar offense.)
Page 3 of 3 Version 12/02

Iredell-Statesville Schools
'my Maintenance Department
1147 Salisbury Road, Statesville, NC 28625, Phone [phone], Fax: [phone]
SLUDGE MANAGEMENT
Excess solids are measured in the clarifier. When the amount exceeds two feet, it is then
pumped to the sludge holding tank, which is a 3000 gallon concrete tank. There it is
dewatered with the superantant, pumped back into the flow equalization tank. When the
tank is approximately 3/4 full a certified septic hauler is called.
Lentz Septic Service, Inc. hauls and disposes of the sludge. Their permit number is NC
00147.

FACT SHEET FOR EXPEDITED RENEWAL
Permit Number
3 -7 37
Facility Name
N , retie (1 WS)
Reviewer
Si)e /-7et, w
Basin/Sub-basin
\AQ ce k tk ©S _ 0 7_ 0 (p
Receiving Stream
a s , CA
Stream Classification in permit
Stream Classification in BIMS
Is the stream impaired (listed on 303(d))?
PO
Is stream monitoring required?
N
Do they need NH3 limit(s)?
NO
Do they need TRC limit(s)?
YE c
Do they have whole -effluent toxicity testing?
MC
Are there special conditions?
IQ v
Any obvious compliance concerns?
we
Existing Expiration Date
3( LV1 d q
Proposed Expiration Date
i 01 ih' C f d 9
Miscellaneous Comments:
7d U iz7; ('o /r a vi7ce 5CA°c t l f'i d thi d tP
If expedited, is this
simpler permit or
a more difficult one?