NC0049409_Permit Modification_20120130

A
bENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Govemor Director Secretary
January 30, 2012
Fredrick L Baker, Director of Public Works
Town of Waynesville
PO Box 100
Waynesville, North Carolina 28786
Subject: Permit Modification
NPDES NC0049409
Waynesville WTP — Class 1
Haywood County
Dear Mr. Baker:
The Division of Water Quality (the Division) has decided to revisit the subject NPDES permit and
revise the permit monitoring conditions. We issue this permit modification 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 October 15, 2007, or
as subsequently amended.
The Division understands that you wish to continue to monitor wasteflow rate and duration
upstream of the sludge pond while collecting compliance samples for analysis downstream of the
pond. You have argued that upstream monitoring is more accurate because a), you combine and
sum two intermittent wasteflows, and b), the pond is both subject to stormwater surge along Allen
Creek and influenced by inflow/infiltration (I/I). Moreover, you wish to continue your current
regimen in order to save the expense of installing new/additional flow -metering equipment
downstream of the pond.
Your currently practiced flow -measurement protocol appears consistent with other NPDES
wasteflow measurements statewide. Considering this, and your assessment of existing site
conditions, the Division finds no reason to deny your request, provided that you continue to record
and report the sum of all wasteflows in compliance with the permit. Therefore, we have modified
this permit as follows:
1. Flow -monitoring has been modified from Continuous to Instantaneous, at a
frequency of 2/Month consistent with the current parameters most frequently
monitored (per WTP Policy 2009).
2. The Flow footnote requiring compliance with "Continuous" monitoring and implied
equipment installation has been revised.
Please find the attached permit change -pages. Please insert these pages into your existing permit
and discard the old pages.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
North
C1T011lla
7Vaturaiij

This permit is not transferable except after notifying the Division of Water Quality. The Division
may require permit modification, or revocation and re -issuance. Please note that this permit does
not affect your legal obligation to obtain other permits required by the Division of Water Quality,
the Division of Land Resources, the Coastal Area Management Act, or other federal or local
governments.
If you have questions or need assistance, please contact the Division's Asheville Regional Office
(ARO) at 828-299-7043, or if we can further assist you from the Central Office, please email Joe
Corporon at [ioe.corporon@a,ncdenr.gov] or call [phone].
Charles Wakild, P.E.
Enclosure: NPDES Permit NC0049409 (Modification FINAL)
hc: Central Files
NPDES Program Files
ARO/SWPS, Attn: Jeff Menzel; Chuck Cranford
ec: CG&L Attn: Kim Colson
Aquatic Toxicology Unit, Attn: Susan Meadows
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolina
Naturally

Permit NC0049409
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this 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 described herein.
Town of Waynesville
is hereby authorized to:
1. continue to operate an existing potable -water treatment plant (WTP) generating waists by applying
conventional water -treatment technology utilizing
• a sedimentation basin
• filters
• clearwell
• sludge pond
for coagulation, flocculation, pre -chlorination, sedimentation, filtration and disinfection utilizing
• chlorine,
• aluminum sulfate,
• sodium hydroxide,
• hydrofuorosilicic acid,
• orthophosphate (non -zinc), and
• calcium phosphate
• [ammonia not added]
located at the Waynesville WTP, 341 Rocky Branch Road, south of Waynesville, Haywood County,
and
2. discharge from said treatment works via Outfall 001, a location specified on the attached map, into
Allen Creek [stream segment 5-16-7-(8.5)] a waterbody currently classified C-Trout within subbasin
04-03-05 of the French Broad River basin.

Permit NC0049409
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting untilexpiration, the Permittee is
authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
-•• .
`MONITORING REQUIREMENTS
LIMJTS
EFFLUENT
Monthly
Average
Weekly
°Average -
.. Daily
� 1VIaxiinnan
Measurement..
- Frequency•
Sample.
Type
Sample:
Location ;
CHAR ACT ERISTICS
[Parameter Codes]
1
Flow 0050
[ ]
2/Month
Instantaneous
went
TSS
[00530]
30.0 mg/L
45.0 mg/L
2/Month
Composite
Effluent
pH
[00400]
[0
Not < 6.0 nor > 9.0 standard units
2/Month
Grab
Effluent
Total Residual Chlorine
[50060]
2
28 µg/L
2/Month
Grab
Effluent
Total Fluoride 3
[00951]
Quarterly
Grab
Effluent
Ammonia Nitrogen (NH3 as N) 4
[00610]
Quarterly
Grab
Effluent
Totluminum
[011055]]
Quarterly S
Grab
Effluent
Total [0 045] on
Quarterly 5
Grab
Effluent
CopperTotal
[01042]
Quarterly 5
Grab
Effluent
Total Manganese
[01055]
Quarterly 5
Grab
Effluent
Total Nitrogen (TN)
[00600]
Quarterly
Grab
Effluent
Total Phosphorus (TP)
[00665]
Quarterly
Grab
Effluent
Whole Effluent Toxicity (WET) 6
[TGP3B]
Quarterly
Grab
Effluent
Footnotes:
1. The Permittee shall record both flow -rate and discharge duration. Flow shall be reported as the sum of two effluents.
2. Total Residual Chlorine (TRC) — Monitor only if the facility adds chlorine or chlorine derivatives to water that is
eventually discharged. The Division shall consider all effluent TRC values reported below 50µg/L to be compliant
with this permit. However, the Permittee shall continue to record and submit all values reported by a North
Carolina -certified test methods (including field certified), even if these values fall below 50µg/L.
3. Total Fluoride - Monitor only if the facility back -washes with fluoridated finish water.
4. Ammonia Nitrogen - Monitor only if the facility uses chloramines [if NH3 is added] prior to filter back.
5. The Permittee shall monitor this parameter in conjunction with Whole Effluent Toxicity (WET) testing.
6. Chronic Toxicity WET Testing Quarterly P/F (Ceriodaphnia @ 90 %); see section A. (2.).
Condition: The Permittee shall discharge no floating solids or foam

MOD Fact Sheet, Jan20 . Town of Waynesville WTP —
NC0049409 - Joe Corporon, NPDE
Permit Modification at Permittee
Renewal History. Just after issuance
(
equest
ective August 1, 2011), the Permittee requested ARO to reinstate
some monitoring conditions previous permitted for this Conventional WTP. While the Permittee made this
request after the Draft Review peri : Roger Edwards (ARO) determined that their concerns were reasonable,
and asked the Central Office to agree to a modification, noting that the Permittee hinted at adjudication, if not
amended.
In the absence of flow data at the outfall, DWQ renewed the permit with a Special Condition that they
establish a monitoring station at 001, their final outfall to the environment (consistent with permits statewide);
DWQ gave them a compliance period of 18 months for new construction [ARO concurred). However, after
reviewing the flow -data collection regimen upstream, DWQ will revisit the permit.
The Permittee collects analytical samples downstream of the settling pond (designated Outfall 001). However,
they measure and record Flow upstream of the settling pond by adding two separate wasteflows together
[clear -well backwash and filter backwash - each to 0.250 MGD max]. They record and report rates and
discharge durations consistently, 10 times per month as [Weekly] Total Flow. Reported Total Flow averaged
0.115 MGD (2009 thru 2011) with a reported maximum 0.402 MGD [n = 882 (2006-2011)]. The Permittee
argues that these flow data are regular, accurate, and representative.
MOD Request. The Permittee wishes to continue to monitor wasteflow upstream, influent to the onsite
sludge pond. They contend that upstream monitoring is more accurate because the pond is subject to both
stormwater surge along Allen Creek and inflow/infiltration (I/1). Moreover, they wish to continue their current
regimen in order to save the expense of installing new/additional flow -metering equipment downstream of the
pond. The Permittee therefore requests modification to:
• retain previous sampling requirements [Weekly, Instantaneous];
• remove permit requirements for new facilities; and
• remove the construction -related compliance period.
DWQ MOD Justification. The Division sees no reason at this time to deny this request. The current
sampling protocol appears consistent with measurements statewide reported as "influent" wasteflow.
Therefore, this permit will be modified as follows:
1. The flow -monitoring will be modified from Continuous to Instantaneous, at a frequency of
2/Month consistent with the current parameters most frequently monitored (per WTP Policy
2009).
2. DWQ will remove the permit footnote implying flow -monitoring equipment installation.
3. DWQ agreed to wave the permit -modification fee.

Corporon, Joe
From: Menzel, Jeff
Sent: Friday, January 27, 2012 10:05 AM
To: Corporon, Joe
Cc: Hennessy, John; Cranford, Chuck
Subject: RE: Waynesville WTP MOD - NC0049409
Joe
They can accurately measure waste water discharges into the pond but the outfall is affected by inflow and infiltration
from wet weather and variations in the adjacent stream flow. The compliance sampling point is correctly located at the
outfall of the sludge pond and the pond itself is correctly sized to provide necessary detention time for removal of TSS
required by the permit limitations. The outfall and sampling point is correctly located and should not be moving.
Effectively we are moving the flow monitoring point upstream of the pond. This allows for the best accuracy for flow
measurement and calculation of mass balance for discharge.
Please let me know if anything needs further explanation.
Jeff
Jeff Menzel - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to
the North Carolina Public Records Law and may be disclosed to third parties.
From: Corporon, Joe
Sent: Friday, January 27, 2012 8:57 AM
To: Menzel, Jeff
Cc: Hennessy, John; Cranford, Chuck
Subject: Waynesville WTP MOD - NC0049409
Jeff— I'm drafting the subject permit MOD (see attached draft MOD docs).
We intend to let Waynesville continue to monitor upstream of the settling pond in lieu of installing new monitoring
equipment downstream, as they requested and we discussed.
Questions: Is it just the two wasteflows they collect above the pond, or do they collect their compliance samples
upstream as well? If so, are they not acknowledging that they do not need the settling pond to meet their limits? Are —
we not effectively moving their outfall upstream?
1

I contend we have no objections as long as they comply with the permit. Is this OK — shall I change the Map Lat/Long as
well? By the way, they mentioned that stormwater contributes to the pond. If this originates from offsite, is their pond
not Waters of the State?
Thanks. We're reviewing this next week. I'll touch base.
Respectfully,
Joe R. Corporon, L.G.
Environmental Specialist
NPDES Program
NCDENR/Division of Water Quality (DWQ)
Surface Water Protection Section
919-807-6394; FAX [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
2

Note to File
Waynesville WTP — Consideration of Request to MOD
NC0049409
Issued July 8, 2011
19Aug2011-- Joe Corporon (NPDES) called Jeff Menzel (ARO) to discuss MOD details. Joe and Jeff
discussed possible changes to the permit; the Permittee collects flow samples from two sources
upstream of the pond (see application site drawing), and then reports the two flows together.
In the apparent "absence" of flow data for renewal (BIMS download error), and after consulting with
Julie, Joe drafted the permit renewal to require installation of a flow meter, downstream of the settling
pond (w/ 18-month compliance period) to provide the "absent" flow data. After issuance, the Permittee
strongly objected to the requirement, sighting the cost to upgrade the pond to accommodate new
hardware. Just prior to the 30-day "objection" deadline, Roger Edwards (ARO) intervened to prevent
adjudication, and said DWQ would reconsider the issuance of July 8, 2011.
After a review of the corrected flow database (2006-2011), DWQ documents that the Permittee has in
fact reported flow (averaging 170 discharges per year); they document a regular discharge rate totaling
0.115 MGD or about 23% of permitted flow (database 2009 thru 2011). The two flows (basin wash
and filter backwash) are intermittent and discharge at irregular intervals, but the Permittee records both
the flow rate and duration upstream of the pond, adds these together for the monthly DMR. Moreover,
the settling pond does not discharge with each WTP flow event due to steady infiltration and
evaporation.
Permittee would like a waiver to retain "Instantaneous" sampling, instead of "Continuous" monitoring
required by Permitting Guidance (September 2009) of flow > 0.050 MGD to avoid installing a flow meter.
To comply with installation, they would have to upgrade the pond and the dam, or build facilities to
combine the discharges upstream of the pond.
tfev6\l�