NC0060534_Permit Issuance_20001129

•
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Mr. Donald G. Byers
City of Brevard
151 West Main Street
Brevard, North Carolina 28712
A7rA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 29, 2000
Subject:Issuance of NPDES Permit NC0060534
City of Brevard WWTP
Transylvania County
Dear Mr. Byers:
Division personnel have reviewed and approved your application for renewal o.f 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).
A.s in the draft, the only change from you previous permit is the addition of upstream/downstream
monitoring requirements for fecal coliform. This is in anticipation o.f the reclassification of the French Broad
River to Class B waters, which requires instream fecal coliform monitoring and limits.
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 Natalie Sierra at telephone number
[phone], extension 551.
Sincerely,
Original Signed By
David A. Goodrich
Kerr T. Stevens
cc: Central Files
Asheville Regional Office/Water Quality Section
LADES Unit
Point Source Compliance Enforcement Unit
EPA Region IV, Roosevelt Childress
Aquatic Toxicology Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit NC0060534
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,
City of Brevard
is hereby authorized to discharge wastewater from a facility located at the
Brevard Wastewater Treatment Facility
On NCSR 1540
Southeast of Brevard
Transylvania County
to receiving waters designated as the French Broad River in the French Broad River
Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective January 1, 2001.
This permit and authorization to discharge shall expire at midnight on September 30, 2005.
Signed this day November 29, 2000.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0060534
SUPPLEMENT TO PERMIT COVER SHEET
The City of Brevard is hereby authorized to:
1. Continue to operate an existing 2.5 MGD wastewater treatment system with the
following components:
Influent lift station
• Grit removal
Rotating Biological Contactors (RBCs)
Dual secondary clarifiers
• Aerobic digester
• Belt press
Chlorination
The facility is located southeast of Brevard at the Brevard Wastewater Treatment
Facility, on NCSR 1540 in Transylvania County.
2. Discharge from said treatment works at the location specified on the attached map
into the French Broad River, classified C waters in the French Broad River Basin.

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City of Brevard WWTP
Latitude: 35°15'05"
Longitude: 82°41'40"
Quad #: F8SW/Pisgah Forest
Stream Class: C
Receiving Stream: French Broad River
Permitted Flow: 2.5 MGD
Sub -Basin:
04-03-01
City of Brevard
NC0060534
Brevard WWTP

Permit NC0060534
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of the permit, the Permittee is authorized to
discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Measurement
Frequency
Sample Type
Sample Location
Flow
2.5 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day (20°C)'
30.0 mg/I
45.0 mg/I
Daily
Composite
Influent, Effluent
Total Suspended Residue'
30.0 mg/I
45.0 mg/I
Daily
Composite
Influent, Effluent
NH3 as N
3/Week
Composite
Effluent
Fecal Coliform (geometric
mean)2
200/100 mL
400/100 mL
Weekly2
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
Daily
Grab
Effluent
Total Nitrogen (NO2+NO3+TKN)
Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent
Temperature (°C)
Daily
Grab
Effluent
Chronic Toxicity3
Quarterly
Composite
Effluent
pH4
3/Week
Grab
Effluent
Footnotes:
1. The monthly average effluent BOD5 and Total Suspended Residue shall not exceed 15% of the
respective influent value (85% removal)
2. Monitoring of fecal coliform should be performed three times a week during the months of June,
July, August and September. Weekly monitoring should be done at all other times during the
year (Administrative Code 2B.0508).
3. Whole effluent toxicity shall be measured using the chronic toxicity (Ceriodaphnia) P/F test at
2.4%. Tests should be performed in January, April, July and October.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be
monitored daily at the effluent by grab sample
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/1.

Permit NC0060534
A. (2.) CHRONIC TOXICITY TESTING (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 2.4%.
The permit holder shall perform at a minimum, auarterI i monitoring using test procedures outlined in the `North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of January, April, July and October. Effluent
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

AFFIDAVIT OF PUBLICATION
CLIPPING OF LEGAL ADVERTISING
ATTACHED HERE
PUBLIC NOTICE
STATE OF NORTH
CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION/NPDES. UNIT
1617 Mail Service Center
Raleigh, N.C. 28699-1617
NOTIFICATION OF INTENT
TO ISSUE A NPDES
WASTEWATER PERMIT
On the basis of thorough
staff review and application of
N.C. General Statute 143.21,
Public law 92-500 and other
lawful standards and
regulations, the North Carolina
Environmental Management
Commission proposes to issue a
National Pollutant Discharge'
Elimination system (NPDES)
wastewater discharge permit to
the person (s) listed on the
attached pages effective 45 days
from the publish date of this
notice.
Written comments regarding
the proposed permit will be
accepted -di -tiff 30 days after the
publish date of this notice. All
comments received prior to that,
date arc considered in the final
determinations regarding the
proposed permit. The Director
of the N.C. Division of Water
Quality may decide to hold a
public meeting for the proposed
permit should the Division
receive a significant degree of
public interest.
Copies of the draft permit
and other supporting
information on file used to
determine conditions present in '
the draft permit are available
upon request and payment of
the costs of reproduction. Mail
comments and/or requests for
information to the N.C.
Division of Water Quality at the
above address or call Ms.
Christie Jackson at 919-733-
5083, extension 538. Please]
include the NPDES permit
number (attached) in any
communication. Interested
persons may also visit the
Division of Water Quality at
512 N. Salisbury Street,
Raleigh, N.C. 27604-1148
- between the hours of 8:00 a.m.
and 5:00 p.m. to review`
information on file.
NPDES Permit Number
NC0060534, Brevard, City of
WWTP, 151 W. Main Street,
Brevard, NC.28712 has applied
for a facility located in
Transylvania County
discharging wastewater into
French Broad River in the
French Broad River Basin.
Currently are water quality
. limited. This discharge may
affect future allocations in this
portion of the receiving stream.
m10/16/ltc
NORTH CAROLINA
TRANSYLVANIA COUNTY
Before the undersigned, a Notary Public of said
County and State, duty commissioned, qualified, and
authorized by law to administer oaths, personally
appeared David Phillips who being first duty sworn,
deposes and says: that he (she) is Advertising
Manager (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 he (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:
October 16, 2000
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
I-597 of the General Statutes of North Carolina.
This `J day of N./et& Ititi- 20 �.
Sworn to
day of,
(Signature of person making affidavit)
d subscri
d before me, this
, 20 1
v
Notary Public
My Commission expires: d -f �4

V4t)
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
SS.
NORTH CAROLINA
I PUBLIC NOTICE
STATE OF
NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION
NPDES UNIT
1617 MAIL SERVICE
CENTER
RALEIGH, NC 27699-1617
NOTIFICATION
OF INTENT TO ISSUE
A NPDES
WASTEWATER PERMIT
On the basis of thorough
staff review and ano i-
cation of NC General
Statute
92-500 and Public
lawful standards and
regulations, ibe North
CarolinaEnvi
mental. Management
Commission
aSNationalPPollut
Pollut-
ant Discharge Elimina-
tion System (NPDES)
wastewater discharge
permit to the persons(s)
listed on the attached
Pages effective 45 days
from the publish date of
this notice.
Written comments re-
garding the proposed
permit will be occept#d
unti 130 days after the pub-
lic date of this notice. All
comrilet its received prior
to that date are consid-
ered In the final determi-
nation regarding the pro -
Posed permit. The Direc-
tor of the NC Division of
Water Quality may de- i
Silt klo rN I[i-, -1
Quality at the above ad-
dress or call Ms.
Christie Jackson re-
quests for information
1 to the NC Division of
I Water Quality at the
above address or call
Ms. Christi Jackson at
[phone], extension
Plans include i (atiadedDS)in wit)/ commJ-
the
niaation. Interested Persons
mw also visit the Division
af W2 N.
iry Sl Quality Raleigh.
NC Dop6f0f4-1148hours between fhe
to rediew8:�am nfoxrtion on
file.
NC00 Permit Number
CITY OF WWTP,,151RWe
MAIN STREET, BRE-'
YARD, NC 28712 has ap-
plied for a facility located
in TRANSYLVANIA
County discharging
wastewater
into
In � FRENCH BROAD
Ry
pareewcrteer equality limited.
This discharge may af-
fect portion ofuture f the receiv-
ing
stream.
October 14, 2000
(2431)
Itiop;10°
O9
GEf, . ;T; r; L y
POIN1 ;c EFt:9,w'C,H
Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified and
authorized by law to administer oaths, personally
appeared Bethany Chandler, who, being first duly
sworn, deposes and says: that he (she) is the Legal
Billing Clerk of TheAsheville Citizen -Times
Company, engaged in publication of a newspaper
known as The Asheville Citizen -Times, published,
issued, and entered as second class mail in the City
of Asheville, in said County and State; that he (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 Asheville Citizen -
Times on the following dates: October 14,
2000And that the said newspaper in which said
notice, paper, document or legal advertisement were
published were, at the time of each and every
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 General Statues of North Carolina.
This i 9th day of October
(Signature of person making affidavit)
Sworn to and subsc>Jed before me the 19th day of
October
:1-iiicuLev:Wt
(Notary Pl ic)
My Commission expires the 20th day of June of �,,,,.........,M,.,
2005. ,,,•`'‘R1�
,c0kY
�o kk

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0060534
Facility Information
Applicant/Facility Name:
City of Brevard Wastewater Treatment Plant
Applicant Address:
151 West Main Street; Brevard, North Carolina 28712
Facility Address:
NCSR 1540 southeast of Brevard, North Carolina
Permitted Flow
2.5 MGD
Type of Waste:
100% Domestic
Facility/Permit Status:
Class IV /Active; Renewal
County:
Transylvania County
Miscellaneous
Receiving Stream:
French Broad
River
Regional Office:
Asheville
Stream Classification:
(_'
State Grid / USGS Quad:
F8SW / Pisgah
Forest, NC
303(d) Listed?
No
Permit Writer:
Natalie Sierra
Subbasin:
04-03-01
Date:
040ct00
Drainage Area (mi2):
220
�
, r
Lat. 35° 15' 05"N Long. 82° 41' 40" W
Summer 7Q10 (cts)
161
Winter 7Q 10 (cts):
30Q2 (cis)
Average Flow (cis):
750
IWC (%):
2.5%
BACKGROUND
Brevard's WWTP (Class IV) has a permitted flow of 2.5 MGD. Actual discharge has averaged
1.38 MGD over the last three years (or about 55% of permitted capacity). The facility discharges
into the French Broad River, which is currently being reconsidered for reclassification to B
waters. The facility's compliance record is good, with few violations and positive inspection
reports.
Brevard uses rotating biological contactors (RBCs) for nutrient removal, which achieves
acceptable levels of nutrient removal. There are currently no nutrient limits in the permit.
Brevard uses chlorination to reduce fecal coliform numbers. Unfortunately, no dechlorination is
in place and the effluent chlorine values are exceedingly high.
Instream Monitoring and Verification of Existing Conditions and DMR Data Review.
The facility monitors for NH3, total residual chlorine (TRC), temperature, total nitrogen, total
phosphorus and chronic toxicity. The total residual chlorine concentrations in the effluent are
very high, averaging 1.24 mg/L. This value is nearly double the allowable concentration. The
average values for total nitrogen and total phosphorus are 14.8 mg/L and 2.20 mg/L,
respectively. This should not create problems, given the low instream waste concentration of
2.5%.
Correspondence: The Asheville Regional Office (ARO) conducted several site visits within the
past three and half years. The inspection reports reveal the facility to be in compliance, but
having periodic problems with I/I. The facility has received one notice of violation (NOV) each
for BOD, chronic toxicity and fecal coliform over the past four years.
PERMITTING STRATEGY
Waste Load Allocation (WLA). The Division prepared the last WLA in 1995. The previous
and current effluent limits were based on guidelines and water quality standards. The Division
has judged previous parameters and limits to be appropriate for renewal.
Fact Sheet
NPDES NC0060534 Renewal
Page I

The only proposed modification is a monitoring requirement for fecal coliform. It has been
• proposed that the French Broad River be reclassified to B waters. This would mean that in
addition to the existent limit in the permit, upstream and downstream monitoring would be
required. Unfortunately, a TRC limit cannot be imposed, despite the high effluent TRC levels.
Should the facility decide to expand, this should be instilled.
SUMMARY OF PROPOSED CHANGES
At this time, the only change that will be made is the addition of an upstream/downstream monitoring
requirement for fecal coliform. This addition is in anticipation of the reclassification of the French
Broad River to Class B waters.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: October 11, 2000
Permit Scheduled to Issue: December, 2000
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Natalie Sierra at [phone] ext. 551.
NAME: DATE:
Fact Sheet
NPDES NC0060534 Renewal
Page 2

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Page Two
8/00
French Broad Permits
The following facilities need permit adjustments:
Facility/Class
NC0021946/II
(Rosman)
Exp.8/2000
NC0060534/IV
(Brevard)
Exp. 8/2000
Requested Permit Modification
Upstream/Downstream Fecal Coliform Monitoring
Upstream/Downstream Fecal Coliform Monitoring
NC0057541/II Fecal Coliform Effluent
(Maston O'Neal) Fecal Coliform Effluent
Exp.9/2000 Upstream/Downstream Fecal
NC0076708/II
(Riverwind)
Exp.9/2000
NC0073741/11
(Mtn.Valley)
Exp.9/2000
NC0024911/IV
(MSD)
Exp.9/2000
Fecal Coliform Effluent
Fecal Coliform Effluent
Upstream/Downstream Fecal
Fecal Coliform Effluent
Fecal Coliform Effluent
Upstream/Downstream Fecal
Limits
Monitoring
Coliform Monitoring
Limits
Monitoring
Coliform Monitoring
Limits
Monitoring
Coliform Monitoring
Indicate on permit U,D, currently only E listed
NC0020478/II Fecal Coliform Effluent
(Lake Powhatan) Fecal Coliform Effluent
Exp.9/2000 Upstream/Downstream Fecal
Chlorine Residual Monito
NC0021733/III
(Marshall)
Exp.10/2001
NC25836/II
(Hot Springs)
Exp.10/2001
Fecal Coliform Effluent
Fecal Coliform Effluent
Upstream/Downstream Fecal
Fecal Coliform Effluent
Fecal Coliform Effluent
Upstream/Downstream Fecal
Limits
Monitoring
Coliform Monitoring
ring
Limits
Monitoring
Coliform Monitoring
Limits
Monitoring
Coliform Monitoring
River/Classification
FrB/Proposed "B Tr"
FrB/Proposed "B"
FrB/Proposed "B"
FrB/Proposed "B"
FrB/proposed "B"
FrB/Proposed "B"
Bent Crk/Proposed "B Tr"
FrB/Proposed "B"
FrB/Proposed "B"

BILL HOLMAN
SECR ETARY
MEMORANDUM
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
August 1, 2000
TO: Dave Goodrich \IJ`
THROUGH: Forrest Westal
FROM: Linda Wiggs
SUBJECT:
CENR - Fl,:7ER DUALITY
PO:NT SOi•RCE BRANCH
French Broad River Reclassification and
Affected Facilities
A use attainability study was recently performed on
several rivers in the French Broad River Basin. A report
submitted to the Planning Branch in April 2000 recommends
reclassification from class "C" to class "B" waters for
several of these rivers, documenting the extensive
recreational use in these mountains streams. Of these rivers,
the French Broad River and Bent Creek have permitted NPDES
dischargers that do not disinfect their wastewater. In
addition, several dischargers are not required to monitor up
and downstream of their discharge. To protect the existing
swimming use in these rivers, the Asheville Regional Office
is requesting that the NPDES group review the following
facilities whose permits are up for renewal and require Fecal
Coliform effluent limits as well as upstream and downstream
monitoring. Please refer to page 16 of 15A NCAC 2B.0500
regarding monitoring requirements in all appropriate
situations. Also note that the classes of facilities are
provided on the attachment. Notification has been sent to
these facilities to inform them of the coming permit changes.
We will work with the NPDES group to develop compliance
schedules.
Thank you for your assistance with this matter. If you
have any questions or would like more information on the
study, please feel free to contact me.
FIIsr
eu ANSF-14A
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 28801-2414
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

City of Brevard
NORTH CAROLINA
Utilities Department
Donald G. Byers
DIRECTOR
Mr. Charles H. Weaver, Jr.,
NC DENR/Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Request for Renewal of NPDES NC0060534
Brevard Wastewater Treatment Plant
Transylvania County
Dear Mr. Weaver,
The purpose of this letter is to request renewal of the City of Brevard's NPDES Permit
#NC0060534. This permit if for the operation of a wastewater treatment facility that
discharges into the French Broad River.
There have been no major changes in this facility since the last permit was issued in
1995.
A narrative description of our sludge management plan is enclosed, along with NPDES
application — Standard Form A.
If you should have any questions on the operation of this facility of this application
packet, please feel free to call me @ 828-883-8461.
Donald G. Byers
Utilities Director
City of Brevard
North Carolina
MAR 2 7 2000
DENR - WATER QUALITY
POINT SOURCE BRANCH
151 West Main Street
Wilson Road Brevard, North Carolina 28712
828-883-8461
Fax [phone]

Stationary Screens
Description
Four stationary screens are provided as shown in Figure 3-7. Two of the screens
(#1 and #2) were installed at an existing plant that was abandoned and the screens were
moved to the new Brevard WWTP. The other two screens (#3 and #4) are new screens.
The screens each have a capacity of approximately 1.152 MGD and treat the following
flows depending on the number of screens in use.
Screen Capacities
No. Screens in Service Max. Flow Capability (MGD)
l 1.152
2 2.304
3 3.456
4 4.608
Each screen consists of a metal frame and a type 316 stainless steel screen with
0.06 inch openings.
Wastewater arrives at the plant in a 14" force main from Pump Station #2. The
force main is provided with two 14" gate valves, as shown in Figure 3-6, which control
the flow of influent into the plant. Under normal operating conditions valve #F1 should
be open and valve #F2 should be closed. This will permit the incoming flow to pass onto
the stationary screens. If it becomes necessary to bypass the screens, valve #F1 should be
closed and valve #F2 should be opened. The wastewater will then pass into manhole #1
and will be discharged from that manhole directly to the RBC unit.
The 14" line passes between the screens as shown in Figure 3-7, and 10" lines
stub off to feed the individual screens. Each feed line is provided with a 10" gate valve
that controls the flow to the screens. Wastewater from the lines flows down over the
screens and the large particles are separated from the liquid portion of the wastewater.
These particles, called screenings, fall off the screens onto screw conveyors that extend
across the bottom of the screens. The conveyors consist of 12" diameter horizontal
screws mounted in troughs.
Screw conveyor #1 is a new unit and is driven by a 3/4 HP motor. Coneyor #2 was
relocated from an existing wastewater treatment plant and is driven by a 1-1/2 HP, 230 V,
single phase motor. Controls consist of a "H-O-A" selector switch and a time clock to
control operation of the conveyors. In addition, a thermostat switch is provided that will
close when the temperature falls to 35 degree F. This will cause the screws to operate
continuously at low temperature in order to keep the screw mechanism from freezing.
The liquid fraction of the wastewater flows down through the screens into a sump
located below the screens. Wastewater flows from the sump in a 24" line that discharges
into manhole #1. A second 24" line exits the manhole and transports the flow to the RBC
unit. Under normal operating conditions valve #F1 should be opened and #F2 should be
closed so that raw wastewater will pass through the screens before going to the RBC
units.

Rotating Biological Contractors (RBCs)
Description
The RBC process is a secondary biological wastewater treatment system
consisting of large -diameter corrugated plastic media which are slowly rotated in a tank
with approximately 40% of the media surface area submerged in the wastewater.
Organisms naturally present in the wastewater adhere to the rotating surfaces and
multiply until the entire surface area is covered with a thin layer of biomass. There are 8
horizontal RBC shafts installed at the Brevard WWTP and the discs mounted on these
shafts provide approximately 1,072,000 square feet of surface area. The plant is designed
as a single -stage process and is primarily intended to achieve BOD removal. That is to
say the plant is not designed to achieve nitrification.
The thin layer of biomass that develops on the discs contains a concentration of
50,000 to 100,000 mg/1 of suspended solids. This high concentration of microorganisms
achieves a high degree of treatment in a relatively short retention time. The growth on
the media is very filamentous and has a shaggy appearance. This provides an active
biological surface area which is much larger than the surface area of the media.
In rotation, the media carries a film of wastewater into the air. As the wastewater
trickles down the surface if absorbs oxygen from the air. Organisms in the biomass
remove both dissolved oxygen and organic materials from this film of wastewater.
Further removal of dissolved oxygen and organic materials occurs as the media continues
rotation through the bulk of the wastewater tank. Unused dissolved oxygen in the
wastewater film is mixed with the contents of the mixed liquor which maintains a mixed
liquor dissolved oxygen concentration.
Shearing forces exerted on the biomass as it passes through the wastewater cause
excess biomass to slough from the media into the mixed liquor. This prevents clogging
of the media surfaces and maintains continual microorganism population of the media.
The mixing action of the rotating media keeps the sloughed solids in suspension until the
flow of treated wastewater carries them out of the RBC tank so that they can be separated
from the wastewater in the final clarifiers.
The RBC unit installed at the Brevard WWTP is the Aero-surf air -driven system
manufactured by Envirex. This RBC unit has a row of air diffusers mounted below the
rotating discs and air is supplied to the diffusers room air blowers. As the air is released
in the tank it is captured in air caps attached to the periphery of the media and this air
causes the shafts to rotate, adds dissolved oxygen to the wastewater and helps to strip the
biological solids from the rotating discs. The rotational speed of the shafts can be varied
by varying the amount of air supplied to the diffusers.
Final Clarifiers
Description
Two final clarifiers are provided at the Brevard WWTP as shown in Figure 3-14.
Each clarifier is 50' in diameter and operates at a 14' side -water depth. Effluent from the
RBC tank flows to the clarifier division box in a 24" line as shown in Figure 3-9. The
division box contains two adjustable weir gates that control the flow of wastewater to the

individual clarifiers. Wastewater enters the clarifiers by 24" influent lines which
discharge into the center well of the clarifiers.
Each clarifier is equipped with a rotating sludge scraper which scrapes the settled
sludge to a collection well located at the center of each clarifier. Each clarifier is also
equipped with a scum baffle, scum scraper and scum collection box in order to remove
and collect scum that rises to the surface of the clarifiers.
The sludge and scum rakes are driven by a V2 HP electric motor connected to a
worm gear reducer by means of a roller chain drive. The drive unit is provided with an
overload device that includes two limit switches adjusted so that a contact closure occurs
at 80°A, overload and another contact closes at maximum overload.
Liquid effluent leaves the clarifiers by discharging over an effluent weir and into
an effluent channel. The flow is transported to the Chlorine Contact Chamber in a 24"
line. Sludge that settles to the bottom of the clarifiers is raked to the sludge well by the
sludge collector and is lifted to a sludge box by a telescoping valve. The sludge is then
discharged to the Sludge Pumping Station and is pumped to the Sludge Holing Tank or to
the Belt Filter Press Building. The scum is discharged from the scum trough into the
sludge box and is discharged with the sludge to the Holding Tank.
Sludge Pumping Station
Description
The Sludge Pumping Station is a prefabricated pump station located adjacent to
the Final Clarifiers. A layout of the station is shown in Figure 3-17.
The Sludge Pump Station contains two vertical, close -couples, non -clog sewage
pumps with the following characteristics:
Capacity = 250 GPM
Head = 40'
Max Speed = 1150 RPM
Electrical = 460 volt, 3 phase, 60 Hertz
The pumps are located in a dry -well and take suction from the wet -well through
6" suction lines. Each pump is provided with a 6" plug valve on its suction side and a 4"
check valve and 4" plug valve on the discharge side. The pumps discharge into a 4"
force main that transfers the sludge to the Sludge holing Tank or to the Belt Filter Press
Building. The force main contains two 4" valves that control the direction of flow for the
sludge.
Controls for the pumps consist of a "Hand -Off -Auto" selector switch, indicating
lights and an elapsed time meter for each pump. Pump operation is controlled by an air
bubbler system that operates the pumps as a function of liquid level in the wet -well. The
bubbler system causes the pumps to operate as follows:

Wet -well Elevation
Wet -well Depth Functions
2099.5 6.5 High Level Alarm
2099 6.0 2nd Pump On
2098 5.0 1 st Pump On
2095 2.0 Pumps Off
A sump pump is installed in the dry -well to remove water that enters the well.
The pump has a capacity of 34 GPM at a TDH of 15' and is driven by a 1/3 HP motor.
Operation of the pump is controlled by an automatic float valve that starts and stops the
pump in response to rising and falling levels in the sump.
The dry -well also contains a refrigeration -type dehumidifier that is provided to
maintain a dry atmosphere within the station. The unit is provided with an automatic
humidistat control, and will operate the unit to maintain the desired conditions in the
station.
Chlorination
Descriation
Chlorination equipment at the Brevard Plant includes two wall -mounted, solution -
feed chlorinators designed for manual control of Sodium Hyperchlorite Feed System.
The capacity of each unit is between 25-500 pounds per day. Chlorine is supplied to the
chlorine feed pumps from two 1000-gallon containers mounted in the Chlorine Building.
Each container is connected to a chlorine feed pump.
The liquid chlorine is fed from the containers through the chlorine feed pumps.
The flow through the chlorine feed pumps can be manually controlled by knobs on the
units. Normally, only one chlorinator will be required to be in service at any given time
and the other unit shall be on standby.
Liquid chlorine is fed from the feed pumps to an injector, which receives a flow
of water to form a chlorine solution. The solution is fed from the injector to diffusers
mounted in the Chlorine Contact Chamber.
The Chlorine Contact Chamber consists of a baffled concrete tank that is 41' — 9"
long by 32' wide. Wastewater arrives at the Chlorine Contact Chamber in a 24" line and
enters the inlet compartment of the chamber. The inlet compartment is equipped with
two slide gates and the Chlorine Contact Chamber is divided into two sections as shown
in Figure 3-20. The chlorine diffusers are located in the inlet compartment to introduce
the chlorine solution to the wastewater. The contact chamber is provided with around -
the -end baffle walls that provide some degree of mixing and prevent short-circuiting of
flow through the chamber. Effluent leaves the chamber by discharging over weir walls
and into an effluent chamber. The flow leaves the chamber by passing over an additional
weir into a 24" effluent line that transports the effluent to the point of discharge in the
French Broad River. An ultrasonic device is mounted above the effluent chamber to
measure the water level over the weir. This device serves as an effluent flow -measuring
device for the plant.

Sludge Treatment
Description
Sludge is generated in the RBC unit at the Brevard WWTP and sill be collected in
the Final Clarifiers. This sludge is mostly liquid, but the relatively small fraction of
solids will contain a high percentage of volatile (organic) matter. Typical sludge, as
discharged from final clarifiers at an RBC plant, can be expected to have the following
general characteristics:
Solids Content 1% - 3.5%
Moisture Content 96.5% - 99%
% Volatile Solids 85%
Treatment and disposal of sludge is an important part of the wastewater treatment
process. Sludge treatment, prior to disposal, has two main objectives.
1) To reduce the concentration of organic matter in the sludge in order to
produce a biologically stable material.
2) To dewater the sludge (separate the solid and liquid fractions) so that less
volume of material remains for final disposal.
Sludge treatment facilities at the Brevard Treatment Plant include an aerated
sludge holding tank (aerobic digester), and belt filter presses. The sludge will not be
completely stable when discharged into the holding tank; however, aeration of sludge in
the tank will help to stabilise the organic fraction of the sludge solids. The tank also
serves as a holding tank for the sludge prior to dewatering. The Sludge Holding Tank
can also serve as a thickener to help concentrate the sludge solids prior to discharge of the
solids to the filter presser. Thickening will reduce the volume of sludge that must be
dewatered on the presses.
Sludge Wasting Practices
Description
Sludge from the final clarifiers can be wasted to either the Sludge Holding Tank
or to the Filter Press Building. Sludge is withdrawn from the final clarifiers in 8" lines as
shown in Figure 3-15. These 8" lines discharge into the wet -well of the sludge pumping
station and the pumps in the station discharge to either the Sludge Holding Tank or to the
Filter Press Building.
As discussed above, the arrangement of piping and pumps makes it possible to
waste sludge to either the Sludge Holding Tank or the Filter Press Building. If it is
necessary to discharge sludge and the operator does not wish to operate the filter presses,
he may discharge to the Sludge Holding Tank and store the sludge until he is ready to
operate the presses. If he wishes to bypass the holding tank and discharge directly to the
filter presses he may operate in that manner as well. The choice of which way to operate
may be dictated by a number of factors including the preference of the operator.

Sludge Holding Tank/Aerobic Digester
Description
The Sludge Holding Tank is 66' in inside diameter and operates with a side water
depth of 16 feet, thus the tank has a volume of 54,711 ft3 or 409,241 gallons. It is
equipped with a pipe grid system that contains air diffusers to distribute air throughout
the tank to aerate and mix the contents. Air is supplied by a 100 HP Blower mounted on
a pad adjacent to the tank.
Waste sludge is introduced to the tank through the 4" line from the sludge
pumping stating as discussed in Section 4.1 above. Sludge is withdrawn from the tank
through a 4" line that drains to the sludge feed pumps in the Filter Press building.
The tank is equipped with a supernatant withdrawal line and four drawoff pipes as
shown in Figure 4-2. The top drawoff line does not have a valve and serves as an
emergency overflow while the other three lines are equipped with valves to control
supernatant withdrawal. Supernatant drains from the Holding Tank into the Supernatant
Return Station and is pumped from the station to manhole #1 ahead of the Stationary
Screen. Operation of the Supernatant Return Pumps is discussed in Section 4.3 below.
Supernatant Return Pump Station
Description
The Supernatant Return Pump station consists of two submersible pumps located
in a 6' diameter precast manhole wet -well as shown in Figure 4-3. Each pump discharges
into a 4" force main which passes trough a valve pit. Each line is provided with a 4"
check valve and 4" force main on the downstream side of the valve pit and this 4" main
discharges into the influent manhole.
Each pump is a Flygy CP-3102 submersible pump with a 5 HP motor rated for
460 volt operation. The pumps each have a capacity of 300 GPM at 30' TDH. The
pumps are controlled by a "roto-float" float switch system that will start and stop the
pumps in response to changes in water level in the wet -well. Controls for the pumps are
mounted in a control module and consist of "H-O-A" selector switches for each pump,
and a Pump #1-Alternate-Pump #2 selector switch. Rum lights and elapsed time meters
for the pumps are also provided.
Sludge Feed Pumps
Description
Two sludge feed pumps are provided in the Filter Press Building as shown in
Figure 4-5. The pumps take suction from the Sludge Holding Tank and discharge
through 4" lines to the belt presses. Each pump is equipped with a 15HP variable speed
drive motor and each is capable of delivering from 50 to 215 GPM against 26 PSI.
Polymer solution from the polymer feed system (Section 4.7) is injected into the
discharge line at three points between the pumps and the belt presses.
The pump drive units are the mechanically adjustable v-belt type complete with
an adjustable speed transmission case and gear reducer. The speed adjustment is motor

operated and adjustable from a remote device and manual control is also provided. Each
pump is provided with a capacitance type flow detector for automatic shut down of the
pump to prevent the pump from running dry.
Piping is arranged so that either pump can serve either of the belt presses. This
arrangement provides flexibility in the use of equipment and allows the pumps to serve as
backups to each other.
Belt Filter Press
Description
The filter press is designed to dewater liquid sludge that has been polymer
conditioned and to provide a dewatered cake that can be readily disposed of. Sludge is
first conditioned "in -line" with polymer and pumped to a distribution box which is
mounted on the upper deck of the belt press frame. The resultant agglomerated solids
release large amounts of free water as they are distributed onto the gravity drainage
section of the press. This free water is removed by gravity through openings in the
polyester belt and through a non-metallic grating to a drain pan.
Baffling devices disperse sludge over the belt and open additional drainage
channels for removal of ponded water which has formed on the sludge surface.
Movement of the belt over the supporting non-metallic grate assists in the removal of
capillary water.
After sludge has been concentrated by means of gravity, the agglomerated solids
are gently distributed onto a lower belt. The upper and lower belts then come together to
form a moving wedge section. The sludge is sandwiched between the two belts. Gradual
increased pressure is applied as the sandwiched sludge passes through rolls of decreasing
diameter. The final rolls form a "S" shaped configuration which generate a shear force
and open additional drainage channels.
Dewatered sludge is discharged from the press for ultimate disposal. To
aid the removal of dewatered sludge, doctor blades are utilized for each belt. After the
cake has been discharged, the belts are washed with high pressure spray water.
The position of each belt is continuously and automatically monitored by
micro -torque sensing units ("live" hydraulic control valve) which are installed with guide
devices. The guide device rides the edge of the polyester cloth belt. The micro -torque
unit senses belt misalignment and automatically walks the belt back to the normal
operating position by means of a "live" hydraulic cylinder which is attached to a tracking
roller. The opposite end of the tracking rollers incorporates self -aligning pillow block
bearings which allows the tracking rollers to pivot in a horizontal plane. Belt tracking is
automatically operated by the hydraulic power pack. A limit switch is provided on each
side of each belt to detect extreme belt travel and initiate a shutdown signal and sound an
alarm.
Each lower deck belt is equipped with a hydraulic cylinder operated by the
hydraulic power pack to automatically insure proper present belt tension while
dewatering varying thickness of sludge. Belt tensioning is accomplished by increasing
the hydraulic pressure in the cylinders and is adjusted by valves at the hydraulic power
pack.
The upper deck belt tension is manually adjusted through screw type take-ups.

The hydraulic power pack is provided to operate the lower deck drive
components, tensioning and tracking mechanisms. Both pressure belts are drived by one
common drive unit. The drive motor is designed to provide belt speeds up to 30 feet per
minute. Both belts run at the same speed. A jog -reverse switch is provided to aid the
operator during maintenance, clean-up, ect.
The same power pack actuates the separate drive for the upper deck belt and its
tracking device. The belt speeds can be easily changed to optimize dewatering
performance by adjusting a valve at the power pack.
Extreme belt travel triggers a limit switch that shuts the system down when
operated in the automatic mode, and triggers an audio alarm when operated in either the
manual or automatic mode. A small cable is strung on each side of the press which can
be pulled in an emergency to shut down the entire system.
A schematic view of the belt filter press is shown in Figure 4-9.

SEPTAGE
PRETREATMENT
FACILITY
INFLUENT
CS MGD
STATIONARY
SCREENS
SCHEMATIC OF WASTEWATER FLOW
CITY OF BREVARD
WASTEWATER TREATMENT
SLUDGE TO
LANDFILL
ROTATING
BIOLOGICAL
CONTACTORS
(8)
SUPERNATANT RETURN LINE
6 DRY TONS
PER DAY
IVISION
BOX
BELT
FILTER
PRESS
SUPERNATANT
RETURN
PUMP
STATION
CLARIFIERS (2)
GPM
DG
SLUDGE
HOLDING
TANK
SLUDGE
PUMP
STATION
CHLORINE
CONTACT
CHAMBER
BACKWASH
PUMP STATION
TO FRENCH BROAD RIVER
25 NGD
WASTEWATER FLOW
SLUDGE
SUPERNATANT
DRY SLUDGE
FILTRATE
BACKWASH WATER

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City of Brevard
NPDES NC0060534
Location Map
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City of Brevard
NORTH CAROLINA
Utilities Department
Donald G. Byers
DIRECTOR
City of Brevard
Wastewater Treatment Facility
Sludge Management Plan
March 2000
The City of Brevard owns and operates a 2.5 million -gallon per day, Rotating
Biological Contractor Wastewater Treatment Facility. Sludge produced by the RBC's is
collected in 2-60' diameter clarifiers. Clarifier sludge is withdrawn and transferred to a
500,000-gallon aerobic digester. Digested sludges at approximately 2% solids are
pumped to a 1.5 meter Envirex belt filter press. Six dry tons per day are produced on an
average of five days per week. Solids content of this sludge range from 15 — 21 percent.
The sludge is loaded by belt conveyor onto dump trucks and transported approximately
fifteen miles along Highway 64 west to the Transylvania County Landfill. Transylvania
County operates a "lined" landfill and mixes wastewater sludge with the municipal solid
waste stream and add earth cover on a daily basis.
151 West Main Street 828-883-8461
Wilson Road Brevard, North Carolina 28712 Fax [phone]

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Donald G. Byers
151 West Main Street
Brevard, North Carolina 28712
AtT7A
�EHNR
April 25, 1996
Subject: NPDES Permit Modification
NPDES Permit No. NC0060534
City of Brevard WWTP
Transylvania County
Dear Mr. Byers:
On August 21, 1995, the Division of Environmental Management issued NPDES Permit No.
NC0060534 to the City of Brevard WWTP. A review of the permit file has indicated that an error was
inadvertently made in the permit. Accordingly, we are forwarding herewith a modification to the subject
permit to correct the error. This permit modification is to Part III, Section F. The modification changes
the text to accurately list the months in which toxicity testing is conducted.
Please find enclosed an amended page for Part III which should be inserted into your permit. The old
page should be discarded. All other terms and conditions contained in the original permit remain
unchanged and in full effect. These permit modifications are issued pursuant to the requirements of North
Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the
U. S. Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit modification
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, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is made,
this decision shall be final and binding.
If you have any questions concerning these permit modifications, please contact Charles Weaver at
telephone number [phone], extension 511.
Sincerely yours,
Preston Howard, Jr., P.E.
cc. Mr. Roosevelt Childress, EPA
Asheville Regional Office
Central Files
Permits and Engineering Unit
Aquatic Survey &: Toxicology Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

Part III
F) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 22% (defined as treatment two in the North Carolina procedure document). The permit
holder shall perform quarterly monitoring using this procedure to establish compliance with the permit
condition. The first test will be performed after thirty days from the effective date of this permit
during the months of January, April, July, and October. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code
TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Permit No. NC0060534
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate retesting (within 30 days of initial monitoring event). Failure to submit suitable test
results will constitute noncompliance with monitoring requirements.

DIVISION OF ENVIRONMENTAL MANAGEMENT
September 18, 1995
MEMORANDUM
TO: Dave Goodrich
rA
THROUGH: Matt Matthews ('
FROM: Kristie Robeson
SUBJECT: Permit Modification
Brevard WWTP
NPDES Permit No. NC0060534
Transylvania County
By cover letter dated August 21, 1995, the subject facility was issued NPDES
Permit No. NC0060534 with an effective date of October 1, 1995, and an expiration date
of August 31, 2000. Upon review of the permit, a discrepancy was noted in the required
testing months for toxicity. The M3 page of the permit specifies January, April, July, and
October as the testing months, and Part III, Condition F specifies January, April, July and
August as the testing months. This office recommends January, April, July, and October
as the required testing months in order to reflect a quarterly schedule.
I appreciate your assistance to undertake the necessary steps to modify the existing
permit and incorporate the recommendation cited above. Should you have any questions,
please feel free to contact me at 2136.
cc: Asheville Regional Office
Larry Ausley
Central Files