NC0062961_Permit Issuance_20171117

Water Resources
Environmental Quality
November 17, 2017
Ms. Judith Schwebke
RCS Properties, Inc.
4501 Tynecastle Highway
Banner Elk, NC 28604
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Subject: Issuance of NPDES Permit NCO062961
Tynecastle WWTP, WW-2
NC Highway 105, Banner Elk 28604
Avery County
Dear Ms. Schwebke:
The Division of Water Resources (the Division) hereby issues the attached NPDES permit for the subject
facility. 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 October 15, 2007, or as subsequently amended.
The Division understands that you have made no significant changes to your facility since the last permit
renewal. We have made the following updates to your previous permit:
1. The facility map has been updated.
2. Regulatory citations have been added.
3. Electronic reporting of discharge monitoring reports (eDMR) has been added in Section A. (2.).
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty
(30) days after receiving this letter. Your request must take the form of a written petition conforming to
Chapter 150B of North Carolina General Statutes, and you must file it with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is
made, this permit shall remain 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 Resources or any
other Federal, State, or Local governmental permits that may be required.
State of North Carolina I Environmental Quality
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707-9000

Ms. Schwebke
November 17, 2017
Page 2 of 2
If you have questions, or if we can be of further service, please contact Derek Denard at
[[e-mail]] or call [phone].
espec lly,
C
Linda Culpepper, Interim r
Division of Water Resources, NCDEQ
Enclosure: NPDES Permit NC0062961 (Issuance Final)
hc: Central Files
NPDES Program Files
ARO Files/ Attn: Landon Davidson
ec: Jadd Brewer, Water Quality Lab & Operations, Inc. [[e-mail]]
Samantha Wotell, Manager, RCS Properties, Inc. [[e-mail]]

NPDES Permit NCO062961
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
NPDES
In compliance with the provisions 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,
RCS Properties, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Tynecastle WWTP
NC Highway 105, Banner Elk 28604
Avery County
to receiving waters designated as the Watauga River in the Watauga 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, 2018.
This permit and authorization to discharge shall expire at midnight on September 30, 2022.
Signed this day November jf, 2� 17. ;
rz da Culpepper, Interim Dire-_._.
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 6

NPDES Permit NCO062961
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.
RCS Properties, Inc.
is hereby authorized to:
1. continue to operate an existing 0.030 MGD package wastewater treatment system with the
following components:
• surge tank
• anoxic tank
• dual (2) aeration basins
• dual (2) clarifiers
• aerated sludge holding tank
• ultraviolet disinfection
located in Banner Elk at the Shoppes of Tynecastle off NC Highway 105 in Avery County; and
2. discharge from said treatment works via Outfall 001, at the location specified on the attached map,
into the Watauga River [stream index 8-(1)], currently classified B; Trout, HQW waters located
within Subbasin 04-02-01 [HUC: 060101030301] of the Watauga River Basin.
Page 2 of 6

NPDES Permit NCO062961
PART I
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited, monitored and
reported' by the Permittee as specified below:
LIMITS
MONITORING REQUIREMENTS 1
EFFLUENT CHARACTERISTICS
Month' Y
Daily
Measurement
Sample
Sample
Parameter Code
Average
Maximum-
Frequency
Type
Location 2
Flow (MGD)
50050
0.030 MGD
Continuous
Recording
Influent Effluent
BOD, 5-day (20°C)
C0310
30.0 mg/L
45.0 mg/L
Weekly
Composite
Effluent
Total Suspended Solids (mg/L)
C0530
30.0 mg/L
45.0 mg/L
Weekly
Composite
Effluent
NH3 as N (mg/L)
(April 1— October 31
C0610
2.3 mg/L
11.5 mg/L
Weekly
Composite
Effluent
NH3 as N (mg/L)
ovemberl—March3 l
C0610
4.4 mg/L
22.0 mg/L
Weekly
Composite
Effluent
Fecal Coliform (#/100m1) 3
31616
200/100 ml
400/100 ml
Weekly
Grab
Effluent
(geometric mean
Temperature (°C)
00010
Monitor & Report
Daily
Grab
Effluent
Dissolved Oxygen (mg/1)
00300
Daily average > 5.0 mg/L
Weekly
Grab
Effluent
pH (su)
00400
Not < 6.0 nor > 9.0
Weekly
Grab
Effluent
Standard Units
Temperature (°C)
00010
Monitor & Report
Weekly
Grab
Upstream &
Downstream
Dissolved Oxygen (mg/1)
00300
Monitor & Report
Weekly
Grab
Upstream &
Downstream
Footnotes:
1. The Permittee shall begin submitting Discharge Monitoring Reports electronically using NC DVWR's eDMR
application system. See Condition A. (3.).
2. Upstream = 50 feet above discharge; Downstream = 200 feet below discharge.
3. Fecal Coliform shall be calculated using the geometric mean, according to the procedure detailed in Part 11.
Section A.
Conditions:
• There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 6

NPDES Permit NCO062961
A. (2.) TEMPORARY MEANS OF DISINFECTION [G.S. 143-215.1(a) & (b)]
In the event that the wastewater treatment plant's ultraviolet (UV) disinfection system should fail,
underperform, or otherwise be removed from effective service, the permittee or his agent should
immediately inform the Surface Water Protection Section staff of the Winston-Salem Regional Office
of this development and discuss temporary, alternate means for disinfection of the effluent.
If chlorine compounds are used as temporary means of disinfection, the total residual chlorine (TRC)
concentration of the effluent must be monitored on a daily basis while this method of disinfection is in
use and values must be reported on the discharge monitoring report. TRC in the effluent may not
exceed 28 µg/L; therefore, dechlorination methods may also be necessary to ensure protection of water
quality in the receiving stream.
The limit for total residual chlorine is only if chlorine is used for disinfection. The Division shall
consider all effluent TRC values reported below 50 µg/1 to be in compliance with the permit. However,
the Permittee shall continue to record and submit all values reported by a North Carolina certified
laboratory (including field certified), even if these values fall below 50 µg/1
Use of a disinfection system other than the permitted UV system during circumstances not deemed as
emergency and/or temporary (replacement of lamps, lamp cleaning or maintenance, etc.) will be
considered a violation of the terms of this permit.
A. (3.) ELECTRONIC REPORTING OF MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Reporting
Records Retention
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring
data and submit DMRs electronically using the internet.. Until such time that the state's eDMR application
is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be required
to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the
computer printed eDMR to the following address:
Page 4 of 6

NPDES Permit NC0062961
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access, then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to
Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
Pretreatment Program Annual Reports; and
Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver
from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial recipient
for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or
the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving
electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type
of electronic submission and for each state. Instructions on how to access and use the appropriate electronic
reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found
at: http://www2.epa.gov/compliance/final-national-pollutant-discharge-elimination-system-npdes-
electronic-reporting-rule.
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division.
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty (60) days prior to the date the facility would be required under this permit to begin
Page 5 of 6

NPDES Permit NC0062961
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and
shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by
the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an
approved reporting waiver request may submit monitoring data and reports on paper to the Division for the
period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
htip:Hdeg.ne.gov/about/divisions/Water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part U,
Section B. (I 1.)(a) or by a duly. authorized representative of that person as described in Part H, Section B.
(11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account
and login credentials to access the eDMR system. For more information on North Carolina's eDMR
system, registering for eDMR and obtaining an eDMR user account, please visit the following web page:
htip://deg.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system -shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"I certijy, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submittingfalse information, including the possibility offines and imprisonmentfor knowing violations."
5. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report. This
period may be extended by request of the Director at any time [40 CFR 122.41].
Page 6 of 6

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DEQ / DWR / NPDES
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit NCO062961
npral- Df-nnrd Cmmnlinnna k FYnPAitf-A Permittinu I Tnit / 919-907-6307 120ct2017
Facility Information
Applicant/Facility Name
RCS Properties, Inc.
Tynecastle WWTP
Applicant Address
4501 Tynecastle Highway, Banner Elk, NC 28604
Facility Address
NC Highway 105, Banner Elk 28604
Permitted Flow (MGD)
0.030
Type of Waste
100% Domestic < 1MGD
Facility Class
WW-2
County
Avery
Permit Status
Renewal
Regional Office
ARO
Stream Characteristics
Receiving Stream
WATAUGA RIVER
Stream Classification
B;Tr,HQW
Stream Segment
8-(l)
Drainage basin
Watauga
Summer 7Q 10 (cfs)
0.1
Subbasin
[IIUC)
04-02-01
060101030301
Winter 7Q10 (cfs)
0.1
Use Support
8-(1)a:
Supporting (Cat 2)
30Q2 (cfs)
0.17
303(d) Listed
Average Flow (cfs)
1 0.5
State Grid
C 11 SE
IWC (%)
31.74
1 USGS Topo Quad
Grandfather Mt, NC
FACILITY SUIV M"Y: This facility is an existing 0.030 MGD package wastewater treatment system
with the following components:
• surge tank
• anoxic tank
• dual (2) aeration basins
• dual (2) clarifiers
• aerated sludge holding tank
• ultraviolet disinfection.
RENEWAL SUMMARY: This permit reflects discharge at Outfall 001. DWR updated the following:
The Division understands that you have made no significant changes to your facility since the last permit
renewal. We have made the following updates to your previous permit:
1. The facility map has been updated,
2. Regulatory citations have been added.
3. Electronic reporting of discharge monitoring reports (eDMR) has been added in Section A. (2).
Fact Sheet
Renewal 2017 -- NPDES Permit NCO062961
Page l

DATA SUMMARY:
DMR Daily Parameter Values for Aug2012-Ju12017
Parameter
T Location
Data
ILimits
! Max
IMin I Average I Count
Monthly Avg jDaily Max
UoM
00010 - Temperature, Water Deg. Centigrade
Downstream
28
6
16.6
62
deg c
Effluent
29
0
14.3
1245
deg c
Upstream
28
6
16.6
62
deg c
-100300 - Oxygen, Dissolved (DO)
Downstream
7
6
6.6
62
mg/I
Effluent
7.6
5.2
6.6
267
Daily average > 5.0
mg/I
Upstream_
7.6
6
6.6
62
mg/I
- 00400 - pH
Effluent
9
6
_
268
Not < 6.0 nor > 9.0
su
- 31616 - Coliform, Fecal MF, MFC Broth, 44.5 C
Effluent
6000
1
260
200
400
#/100ml
- 50050 - Flow, in conduit or thru treatment plant
Effluent
0.16
0.0002
0.0119
1810
0.030
mgd
- C0310 - BOD, 5-Day (20 Deg. C) - Concentration
Effluent
36
2
6.4
260
30.0
45.0
mg/I
- CO530 - Solids, Total Suspended - Concentration
Effluent
44
5
9.6
260
30.0
45.0
mg/I
Month -
Location
Data
I
Limits
Parameter T
Max Min Average Count
3.81 0.2 0.41 22
3.38 0.2 0.54 20
5.3 0.2 1.14 22
1.75 0.2 0.32 22
0.73 0.2 0.28 21
Monthly jDaily jUoM
4.4 22.0 mg/I
4.4 22.0 mg/I
4.4 22.0 mg/I
2.3 11.5 mg/I
2.3 11.5 mg/I
2.3 11.5 mg/I
2.3 11.5 mg/I
2.3 11.5 mg/I
2.3 11.5 mg/I
2.3 11.5 mg/I
4.4 22.0 mg/I
4.4 22.0 m I
C0610 - Nitrogen, Ammonia Total (as N) - Concentration
- 1
Effluent
Effluent
-,2
-3
Effluent
-•4
Effluent_
-!5
Effluent
-16
Effluent
3.2 0.2 0.53 2_2
-i 7
Effluent4.31
0.2 0.64 22
- 8
Effluent
1.99 0.2 0.42 21
--9
Effluent_
0.88 0.2 0.25 21
- 10
Effluent
4.33 0.2 0.55 23
- 11
Effluent
8.91 0.2 0.72 21
- 12
Effluent
2 0.2 0.48 23
C0610 - Nitrogen, Ammonia Total (as N) - Concentration Total 8.91 0.2 0.53 260
COMPLIANCE HISTORY: Aug2012-Ju12017 See Attached Spreadsheet.
Fact Sheet
Renewal 2017 -- NPDES Permit NCO062961
Page 2

PERMIT . NC0062961
FACILITY . ,RCS Properties-Tynecaslle WWTP
.f�UNTY very
REGION Asheville
MONITOR MONITO OUTFALL LOCATION LOCATION PARAMETER
VIOLATION FREQUENCY UNITOF
LIMIT CALCULATED % OVER VIOLATION
VIOLATIO
VIOLATION LAST
REPORT R
NUMBER TYPE
DATE
MEASURE
VALUE
TYPE
N ACTION
COMMENT
UPDATED BY
MONTH REPORT
ID
YEAR
2
2013 001
Outfall
Effluent
Temperature,
02/09/2013 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
2
2013 001
Outfall
Effluent
Temperature,
02/16/2013 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
2
2013 001
Outfall
Effluent
Temperature,
02/23/2013 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
2
2016 001
Outfall
Effluent
Coliform, Fecal
02/11/2016 Weekly
#1100ml
400.0000 6000.0000
1400 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded
3
2013 001
Outfall
Effluent
Temperature,
03/02/2013 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
4
2016 001
Outfall
Effluent
Coliform, Fecal
04/05/2016 Weekly
#/100ml
400.0000 2800.0000
600 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded
5
2016 001
Outfall
Effluent
Coliform, Fecal
05/10/2016 Weekly
#/100ml
400.0000 1000.0000
150 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded
5
2015 001
Outfall
Effluent
Coliform, Fecal
05/19/2015 Weekly
#/100ml
400.0000 700.0000
75 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded
6
2015 001
Outfall
Effluent
pH
O6/29/2015 Weekly
su
6.0000 4.6000
23 Daily
Proceed to
janet.cantwell
Minimum Not NOV
Reached
6
2015 001
Outfall
Effluent
Coliform, Fecal
06/17/2015 Weekly
#/100ml
400.0000 1200.0000
200 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth; 44.5 C
Exceeded
7
2016 001
Outfall
Effluent
Coliform, Fecal
07/06/2016 Weekly
#/100ml
400.0000 1200.0000
200 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded
7
2013 001
Outfall
Effluent
Coliform, Fecal
07/3112013 Weekly
#/100ml
400.0000 2400.0000
500 Daily
Proceed to
janet.cantwell
MF, MFC'
Maximum
NOV
Broth, 44.5 C
Exceeded
8
2014 001
Outfall
Effluent
Temperature,
08/09/2014 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
8
2014 001
Outfall
Effluent
Temperature,
08/16/2014 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
8
2014 001
Outfall
Effluent
Temperature,
08/23/2014 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
8
2014 001
Outfall
Effluent
Temperature,
08/30/2014 5 X week
deg c
Frequency
Proceed to
janet.cantwell
Water Deg.
Violation
NOV
Centigrade
8
2013 001
Outfall
Effluent
Coliform, Fecal
08/06/2013 Weekly
#/100ml
400.0000 6000.0000
1400 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded
8
2012 001
Outfall
Effluent
pH
O8/04/2012 Weekly
su
Frequency
Proceed to
janet.cantwell
Violation
NOV
8
2012 001
Outfall
Effluent
Oxygen,
08/04/2012 Weekly
mgh
Frequency
Proceed to
janet.cantwell
Dissolved (DO)
Violation
NOV
11
2014 001
Outfall
Effluent
Colifonn, Fecal
11/04/2014 Weekly
#1100ml
400.0000 4400.0000
1000 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded
11
2012 001
Outfall
Effluent
Temperature,
11/03/2012 5 X week
deg c
Frequency
No Action,
Was done
janet.cantwell
Water Deg.
Violation
Facility
10131for wk
Centigrade
Reporting
end.11/3.
Error
JAC.4/5/13.
12
2014 001
Outfall
Effluent
Coliform, Fecal
12102/2014 Weekly
#/100ml
400.0000 1600.0000
300 Daily
Proceed to
janet.cantwell
MF, MFC
Maximum
NOV
Broth, 44.5 C
Exceeded

Denard, Derek
From: Wiggs, Linda
Sent: Tuesday, September 26, 2017 10:27 AM
To: Denard, Derek; Heim, Tim
Cc: Boss, Daniel J
Subject: Tynecastle NC0062961 renewal
Attachments: nc0062961 request.pdf
Comments on Tynecastle:
The attached request was submitted to Raleigh requesting this subject permit be
considered for tiers. Not sure why/if it was not in the Raleigh file and considered prior to
going to draft, regardless, Raleigh needs to review this permit for this request.
Environmental Senior Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 299 7043 fax
Email: linda.wiggs(c)-ncdenr.goy
I:
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
{ -%'Nothing Compares,.,`
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
3

Denard, Derek
From: Denard, Derek
Sent: Tuesday, September 26, 2017 12:33 PM
To: Wiggs, Linda; Heim, Tim
Cc: Boss, Daniel J
Subject: RE: Tynecastle NCO062961 renewal
Linda,
I didn't have this letter in the file. Somehow this got overlooked. By the way, they did not request this in the renewal
application. Looks like Jadd Brewer requested this for several permits around that time. I have a letter in the file for
three other permits in Watauga county that denies the same request. The letters indicate that composite sampling is
based on design flow. In other words, they would have to redesign the system to be less than 30,000 gpd for us to agree.
If Jadd Brewer comments on the draft for NC0062961, I will address this request in the final cover letter. Here is the rule
sited in these letters:
15A NCAC 026 .0505 (3) (B) and (3)(C).
3) Collection of Samples:
(A) Samples collected in receiving waters shall be grab samples.
(e) Samples of the influent and effluent of the water pollution control facility or other point source shall be composite
samples, except as provided in Rule .0505 (c)(3)(C) of this Section, or for facilities with design flows of 30,000 gallons per
day or less unless required by the Director. The Director may specify the methods of sample collection as to type of sample
and type of composite sampling required.
(C) The following influent and effluent tests shall be made on grab samples and shall not be made on composite samples:
(i) dissolved oxygen,
(ii) temperature,
(iii) settleable matter,
(iv) turbidity,
(v) pH,
(vi) residual chlorine,
(vii) coliform bacteria (fecal or total),
(viii) cyanide,
(ix) oil and grease,
(x) sulfides,
(xi) phenols,
(xii) volatile organics.
Thanks,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard cDncdenr.c7ov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Wiggs, Linda
Sent: Tuesday, September 26, 2017 10:27 AM
To: Denard, Derek <[e-mail]>; Heim, Tim <[e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: Tynecastle NC0062961 renewal
Comments on Tynecastle:
The attached request was submitted to Raleigh requesting this subject permit be
considered for tiers. Not sure why/if it was not in the Raleigh file and considered prior to
going to draft, regardless, Raleigh needs to review this permit for this request.
Environmental Senior Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 299 7043 fax
Email: linda.wiggs(cD-ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
— ' Nothing Compares,,,
Entail correspondence to and fif1om this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
5

Denard, Derek
From: Water Quality Labs <[e-mail]>
Sent: Tuesday, October 17, 2017 11:52 AM
To: [e-mail]; Denard, Derek
Cc: Davidson, Landon; Heim, Tim; Kinney, Maureen
Subject: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
Attachments: Tynecastle WWTP Avg Flow Data.docx
CAUTION. This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
We are in receipt of the draft permit for Tynecastle WWTP (NC0062961). We would like to request
that sampling for the aforementioned be changed to time -paced sampling as opposed to flow -
proportional sampling. While the plant's design is 0.030 MGD, the system has not experienced an
average flow at or above that from January 2015 to the present time. I have attached a document
detailing that data for your perusal.
Thank you for your time and consideration-, please feel free to contact me if I can be of further
assistance.
Sincerely,
Jadd Brewer
Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Monday, September 25, 2017, 1:09:08 PM EDT, Denard, Derek <[e-mail]> wrote:
Please find the attached copy of the draft permit NCO062961 for Tynecastle WWTP. A hard copy will be mailed to the
permittee shortly. Please provide your comments, if any, to me via email [[e-mail]] or write to my
attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. If you have questions concerning this
draft, please e-mail me or call my direct line [phone].
Sincerely,

Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard anncdenr.Qov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Denard, Derek
From: Davidson, Landon
Sent: Tuesday, October 17, 2017 1:44 PM
To: Denard, Derek
Cc: Heim, Tim; Kinney, Maureen
Subject: RE: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
Anyone understand what "time -paced" means? Constant time/variable volume, variable time/constant volume or
constant time/constant volume?
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson(a)ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Water Quality Labs[mailto:[e-mail]]
Sent: Tuesday, October 17, 2017 11:52 AM
To: [e-mail]; Denard, Derek <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Heim, Tim <[e-mail]>; Kinney, Maureen
<[e-mail]>
Subject: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
We are in receipt of the draft permit for Tynecastle WWTP (NC0062961). We would like to request
that sampling for the aforementioned be changed to time -paced sampling as opposed to flow -
proportional sampling. While the plant's design is 0.030 MGD, the system has not experienced an
average flow at or above that from January 2015 to the present time. I have attached a document
detailing that data for your perusal.
Thank you for your time and consideration; please feel free to contact me if I can be of further
assistance.
Sincerely,
Jadd Brewer

Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Monday, September 25, 2017, 1:09:08 PM EDT, Denard, Derek <derek.denard(aD_ncdenr.gov> wrote:
Please find the attached copy of the draft permit NCO062961 for Tynecastle WWTP. A hard copy will be mailed to the
permittee shortly. Please provide your comments, if any, to me via email [[e-mail]] or write to my
attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. If you have questions concerning this
draft, please e-mail me or call my direct line [phone].
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard(a)-ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
i
Email correspondence to and from th�s address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Denard, Derek
From: Heim, Tim
Sent: Tuesday, October 17, 2017 1:49 PM
To: Davidson, Landon; Denard, Derek
Cc: Kinney, Maureen
Subject: Re: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
I am confused by this request as well. I forwarded to Linda Wiggs to see if she has any thoughts.
From: Davidson, Landon
Sent: Tuesday, October 17, 2017 1:44:06 PM
To: Denard, Derek
Cc: Heim, Tim; Kinney, Maureen
Subject: RE: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
Anyone understand what "time -paced" means? Constant time/variable volume, variable time/constant volume or
constant time/constant volume?
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. David son(aD-ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and fi`om th s address is subject to the
North Carolina Puh!icf��^cords. -41VV a ul may be disclosed to third parties.
From: Water Quality Labs [mailto:[e-mail]]
Sent: Tuesday, October 17, 2017 11:52 AM
To: [e-mail]; Denard, Derek <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Heim, Tim <[e-mail]>; Kinney, Maureen
<[e-mail]>
Subject: [External] Re: Draft NPDES Permit NCO062961- Tynecastle WWTP, WW-2
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
We are in receipt of the draft permit for Tynecastle WWTP (NC0062961). We would like to request
that sampling for the aforementioned be changed to time -paced sampling as opposed to flow -
proportional sampling. While the plant's design is 0.030 MGD, the system has not experienced an
average flow at or above that from January 2015 to the present time. I have attached a document
detailing that data for your perusal.
11

Thank you for your time and consideration; please feel free to contact me if I can be of further
assistance.
Sincerely,
Jadd Brewer
Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Monday, September 25, 2017, 1:09:08 PM EDT, Denard, Derek <derek.denard(a)ncdenr.gov> wrote:
Please find the attached copy of the draft permit NCO062961 for Tynecastle WWTP. A hard copy will be mailed to the
permittee shortly. Please provide your comments, if any, to me via email [[e-mail]] or write to my
attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. If you have questions concerning this
draft, please e-mail me or call my direct line [phone].
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard(a-)ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
12

Denard, Derek
From: Denard, Derek
Sent: Tuesday, October 17, 2017 2:32 PM
To: Heim, Tim; Davidson, Landon
Subject: RE: [External] Re: Draft NPDES Permit NC0062961 - Tynecastle WWTP, WW-2
Landon & Tim,
I am confused as well. For the permit the choice is grab or composite. In 2B definitions (NPDES Standard Conditions as
well) composite sampling can be taken as continuous, constant time/variable volume, variable time/ constant volume,
or constant time/constant volume. I'm not sure how to address such an option or special condition in the permit.
Anyway, whatever he wants to do other than continuous sampling has to be approved separate from the permit. I
believe we have denied such requests for other permits with flow over 0.030 MGD. I may ask him to clearly which one is
this it he wants to do other than continuous.
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard(a)ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
14

1SA \CAC 02B .0503 DFFi\11 IONS r.
Unless lire cotuem otherwise reyt►ues. the tenus used herein shall be as defined in G.S. 143-213 and as follow+.-
i I i "Biological uwmtoru►g- slall mean the saimphag or tesuug of the biological integrity of staface akaters and
meastrremanuts of impact, including accunudauom of pollutants in tissue. toxicity nrorutonnc. and
claractenzation of uastream biological populations
i_►-Classified wafer pollution doutrol facility" means a ueau»eui %wits classified by the Water Pollution
Control %\meta Operator Cemfrcation C'onnmcsron pursuant to Cliapter5►oAofthe NorthCarolim Genital
Statutes as claws 1. class 11. class 111. or class R' fac ilit•. or arch other c las.+afrcations as the Water Pollution
C'onnrol System Opefator Cetrificatiou C'otnimssion tray hereafter adopt.
1 3) "C'omutercial thbornioiy.' rtrdarrs any labonuory which analyzes water wungales for a tilt.
i 4 i "Cbttrpostte sruriple" meaus: A sample gathered over a _4 hour period by counnuous-mimphn_ Ole conibnnu_
grab *pan;ale, to such a tanner as to result in a total sample ►+faith is representative of the wasre++•arer
dischme dminY the sample period. Tiffs satuple Wray be obtained by ine liods given beloy. lxmvevet. the
Duector stay designate the most appropriate methodf nuttuber and size of aliquots necessary and the Flat
mtenval ben+•een scab samples on a case -by -case base. Samples roily be collected tuanually or
atnotuatically.
to i C otac►tnornts - a smile. continuous Miliple collected over a 24 hrnu penal prop rtonal to tlne rate
of flow
t b i Cortstvtt little +•arable volunle -a seines of emb ,attiples collected at equal brae mien als ow i a
24 hotu period of discharge and combined pwixnponal to the rate of flow ttneamtred at the tune of
mtdividtah �.attrple collection. or
t c ► \'auaable Britt constant vohtune - a setiea of grab volanne i.Alecied over a 24 limit
period %sith the imie intervals tvr ween samples ittiouiuted by a I» eset mtutdlet of gallon. p a,'suig
the sarniAta_ point. Flow meauaenrent bemecu sample nncn•als shall be deter tnined by use of a
RON%- recorder and ti taltzer. and the pre-set gallon nrten al between sample collection fixred at no
greater rlaata 1 24 of Flit expected total daily flow at the rreatmrent sycteu►. or
id) C'on+tvu tuna corn+taut volunic - a series of grab uumples of ettual volume collected over a 24
hour period at a constant tune iitteival. 7 Iris urettral «ray be uu,ed in sitrsanntns ++here etllrretu 11on
rates a:ary less than 15 percent. The grab samples shall he taken at uatervalc ofurn erecter tluut 20
taaimues apart during any 24 hour period auud must bt of equal size anci of no less tlaata ICM)
milliliters. Use of tluis uaethod requires prior approval by die Director.
From: Heim, Tim
Sent: Tuesday, October 17, 2017 1:49 PM
To: Davidson, Landon <[e-mail]>; Denard, Derek <[e-mail]>
Cc: Kinney, Maureen <[e-mail]>
Subject: Re: [External] Re: Draft NPDES Permit NCO062961- Tynecastle WWTP, WW-2
I am confused by this request as well. I forwarded to Linda Wiggs to see if she has any thoughts.
From: Davidson, Landon
Sent: Tuesday, October 17, 2017 1:44:06 PM
To: Denard, Derek
Cc: Heim, Tim; Kinney, Maureen
Subject: RE: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
Anyone understand what "time -paced" means? Constant time/variable volume, variable time/constant volume or
constant time/constant volume?
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson(oncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email corresponderrca io and from this address is subject to the
15

North Carolina Public Records Law and may be disclosed to third parties.
From: Water Quality Labs [mailto:[e-mail]]
Sent: Tuesday, October 17, 2017 11:52 AM
To: [e-mail]; Denard, Derek <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Heim, Tim <[e-mail]>; Kinney, Maureen
<[e-mail]>
Subject: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
We are in receipt of the draft permit for Tynecastle WWTP (NC0062961). We would like to request
that sampling for the aforementioned be changed to time -paced sampling as opposed to flow -
proportional sampling. While the plant's design is 0.030 MGD, the system has not experienced an
average flow at or above that from January 2015 to the present time. I have attached a document
detailing that data for your perusal.
Thank you for your time and consideration; please feel free to contact me if I can be of further
assistance.
Sincerely,
Jadd Brewer
Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Monday, September 25, 2017, 1:09:08 PM EDT, Denard, Derek <derek.denardAncdenr.gov> wrote:
Please find the attached copy of the draft permit NCO062961 for Tynecastle WWTP. A hard copy will be mailed to the
permittee shortly. Please provide your comments, if any, to me via email [[e-mail]] or write to my
attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. If you have questions concerning this
draft, please e-mail me or call my direct line [phone].
Sincerely,
16

Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denardCaD-ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
17

Denard, Derek
From: Davidson, Landon
Sent: Tuesday, October 17, 2017 2:34 PM
To: Denard, Derek; Heim, Tim
Subject: RE: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
Agreed, yes 30K has been the bounds or rule guidance but we have several facilities way under that have composite
sampling requirement. Yes, that process is separate and I don't know exactly what he is asking for. By the way, there is
discussion in the regions with regards to how to evaluate these requests; right now, that is unresolved.
Thanks.
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson(a)ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Denard, Derek
Sent: Tuesday, October 17, 2017 2:32 PM
To: Heim, Tim <[e-mail]>; Davidson, Landon <[e-mail]>
Subject: RE: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
Landon & Tim,
I am confused as well. For the permit the choice is grab or composite. In 2B definitions (NPDES Standard Conditions as
well) composite sampling can be taken as continuous, constant time/variable volume, variable time/ constant volume,
or constant time/constant volume. I'm not sure how to address such an option or special condition in the permit.
Anyway, whatever he wants to do other than continuous sampling has to be approved separate from the permit. I
believe we have denied such requests for other permits with flow over 0.030 MGD. I may ask him to clearly which one is
this it he wants to do other than continuous.
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard(a)_ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
18

Email correspondence to and J Im th s address is subject to the
North Carolina Public Records L aw a d may be disclosed to third parties.
USA XCAC 02B A503 DEFINITION'S .+
Unless [lit COMM otltensise requu es. the tent+ toed herein shall be as defrured in G.S. 143-213 arid as folk%%-,.
III "Biological uwtutortn_" shall nman the ssutrphue or testing of the biological tmegnn ofsurL+cc «aterx auxl
measurements of unpxrs Including accuunulation, of pollutants nts tit nssue. toxicity ntsnttonug. and
characterization of utstrzaw biological populations.
411 -Classified water pollution control facility" means a neaurreut swcxks classified b}• the Water N-Mutton
Control System operator Cert►ficawn Countusxton pttrvttaru to C7napter 9OA oftlre Niorlll Carolina Getietal
Statutes as class 1. class 11. class M. or class lv. facditv. or %itch other classifications as the Water polltnion
Control System Operator Certification C'ounuissiou uray hereafter adopt
13) "Commercial hnboratoly" meam any laboratory wWch analyzes water sattlples for a fte.
(41 "Composite uuuple" ntcarts: a sample gathered Over a N liar penal by contin uott+sainpling or contbuung
grab samples m'kuch a manner as to result in a total sanyrle Which is rep1V1entat1we of the «nstetwater
discharge during the sample period. This sample may be obtained by methods given below. however. the
Director may desi€nate the two appropriate metltodi number and size of aliquots necessan• and the time
Interval between grab samples off a case -by -case basis. Samples uuny be collected nutuutally or
automatically,
i a ► CouhnnOUS • a %tingle, contuutous sannple collected over a 24 hour period proportional to the rate
of now
(b) Constant rtrpe,vanalIle %vlunte - a stints of ertb -tiatuples collected at equal time utren2ts over a
24 hour pl, of di Marge and combmat propottrortal to tlu rate of Ilo%v uttaswed at the time of
iucli�idtusl le c Ilection. or
tc) \variable titre+cousti3uir vohrtue - a set ie, oCgrab smttples of�ttal trltnite Mllecteci over a 24 hors
period i%ith the time urten•als between samples cleterrtnrted by a pr v et uaanbeu of gallons passing
tlne sampling point. 'Flory measurement between sample intervals shall be detentuned by ruse of a
ncAv recorder and totalizer. aril the preset gallon Interval between sample collection fixed sit no
greater than 1.24 of, the expected total daily flow at the ntatnMt syStettl. or
tdl Constant Tinto constant volunne - a series of Arab svtrples of eti nal volume collected over a 24
hour period at a constant tune inter -al. Tltis ntetlrocl tiny be toed m stnratrons ufiereet]lttetrt 11otw
rates vary less than 15 percent. The grab stnrples shall be taken at unter-aN of tin greater than 20
nutmtes apart during any 24 hour period and nntst be of equal size attd of no less than 100
milliliters. Use of this method requires prior approval by the Duectot.
From: Heim, Tim
Sent: Tuesday, October 17, 2017 1:49 PM
To: Davidson, Landon <[e-mail]>; Denard, Derek <[e-mail]>
Cc: Kinney, Maureen <[e-mail]>
Subject: Re: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
I am confused by this request as well. I forwarded to Linda Wiggs to see if she has any thoughts.
From: Davidson, Landon
Sent: Tuesday, October 17, 2017 1:44:06 PM
To: Denard, Derek
Cc: Heim, Tim; Kinney, Maureen
Subject: RE: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
Anyone understand what "time -paced" means? Constant time/variable volume, variable time/constant volume or
constant time/constant volume?
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
19

828 296 4680 office
828 230 4057 mobile
Landon. Davidson (a)ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Water quality Labs[mailto:[e-mail]]
Sent: Tuesday, October 17, 2017 11:52 AM
To: [e-mail]; Denard, Derek <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Heim, Tim <[e-mail]>; Kinney, Maureen
<[e-mail]>
Subject: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
We are in receipt of the draft permit for Tynecastle WWTP (NC0062961). We would like to request
that sampling for the aforementioned be changed to time -paced sampling as opposed to flow -
proportional sampling. While the plant's design is 0.030 MGD, the system has not experienced an
average flow at or above that from January 2015 to the present time. I have attached a document
detailing that data for your perusal.
Thank you for your time and consideration; please feel free to contact me if I can be of further
assistance.
Sincerely,
Jadd Brewer
Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Monday, September 25, 2017, 1:09:08 PM EDT, Denard, Derek <derek.denardCcDncdenr.gov> wrote:
Please find the attached copy of the draft permit NCO062961 for Tynecastle WWTP. A hard copy will be mailed to the
permittee shortly. Please provide your comments, if any, to me via email [[e-mail]] or write to my
attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. If you have questions concerning this
draft, please e-mail me or call my direct line [phone].
20

Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
dere k.denard(a-)_ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
I i
Email correspondence to and from th�s address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
21

Denard, Derek
From: Denard, Derek
Sent: Tuesday, October 17, 2017 2:55 PM
To: 'Water Quality Labs; [e-mail]
Cc: Davidson, Landon; Heim, Tim; Kinney, Maureen
Subject: RE: [External] Re: Draft NPDES Permit NC0062961 - Tynecastle WWTP, WW-2
Mr. Brewer,
Please clarify for us what method you are requesting for composite sampling. We are not sure what you meant by
"time -paced sampling". NPDES Permit Standard Conditions (page 1 & 2) (Version 11%09/2011.1) Part II Section A.
Definitions gives the following four (4) options for composite sampling:
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in
such a manner as to result in a total sample representative of the wastewater disc arge during the sample period. The
Director may designate the most appropriate method (specific number and size o aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour
period of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling point.
Flow measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and
the preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily
flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. Tl}e following restrictions also apply:
➢ Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
➢ Influent samples shall not be collected more than once per (hour. - i
➢ Permittees with wastewater treatment systems whose deie ion ti e < 24 hours shall collect
effluent grab samples at intervals of no greater than 20 minutes�apart2uring any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall
collect effluent grab samples at least every six hours; there inust be a minimum of four samples during
a 24-hour sampling period.
Any composite sampling method other than continuous would have to be approved ion a case -by -case basis by the
Division. The only option for the permit renewal is grab or composite. However, we may address you request separately
from the permit renewal at another time.
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
22

919 807 6307 office
derek.denard(cDncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Water Quality Labs [mailto:[e-mail]]
Sent: Tuesday, October 17, 2017 11:52 AM
To: [e-mail]; Denard, Derek <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Heim, Tim <[e-mail]>; Kinney, Maureen
<[e-mail]>
Subject: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
We are in receipt of the draft permit for Tynecastle WWTP (NC0062961). We would like to request
that sampling for the aforementioned be changed to time -paced sampling as opposed to flow -
proportional sampling. While the plant's design is 0.030 MGD, the system has not experienced an
average flow at or above that from January 2015 to the present time. I have attached a document
detailing that data for your perusal.
Thank you for your time and consideration; please feel free to contact me if I can be of further
assistance.
Sincerely,
Jadd Brewer
Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Monday, September 25, 2017, 1:09:08 PM EDT, Denard, Derek <derek.denard(cDncdenr.gov> wrote:
Please find the attached copy of the draft permit NCO062961 for Tynecastle WWTP. A hard copy will be mailed to the
permittee shortly. Please provide your comments, if any, to me via email [[e-mail]] or write to my
23

attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. If you have questions concerning this
draft, please e-mail me or call my direct line [phone].
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denardCa_ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
24

Denard, Derek
From: Water Quality Labs <[e-mail]>
Sent: Wednesday, October 18, 2017 9:35 AM
To: [e-mail]; Denard, Derek
Cc: Davidson, Landon; Heim, Tim; Kinney, Maureen
Subject: Re: RE: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
Of the options listed, we are requesting the fourth one.
Sincerely,
Jadd Brewer
Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Tuesday, October 17, 2017, 2:54:50 PM EDT, Denard, Derek <[e-mail]> wrote:
Mr. Brewer,
Please clarify for us what method you are requesting for composite sampling. We are not sure what you meant
by "time -paced sampling". NPDES Permit Standard Conditions (page 1 & 2) (Version 1110912011.1) Part II
Section A. Definitions gives the following four (4) options for composite sampling:
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100
mL in such a manner as to result in a total sample representative of the wastewater discharge during the
sample period. The Director may designate the most appropriate method (specific number and size of
aliquots necessary, the time interval between grab samples, etc.) on a case -by -case basis. Samples may be
collected manually or automatically. Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate
of flow.
25

(2) Constant time/variable volume: a series of grab samples colle ted;a equal time intervals over a
24 hour period of discharge and combined proportional to the rat of flo measured at the time of
individual sample collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24
hour period with the time intervals between samples determined by a preset number of gallons
passing the sampling point. Flow measurement between sample intervals shall be determined by
use of a flow recorder and totalizer, and the preset gallon interval between sample collection fixed at
no greater than 1/24 of the expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-
hour period at a constant time interval. Use of this method requires prior approval by the Director.
This method may only be used in situations where effluent flow rates vary less than 15 percent. The
following restrictions also apply:
➢ Influent and effluent grab samples shall be of equal size and of no less than 100
milliliters
➢ Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall
collect effluent grab samples at intervals of no greater tha 20 m minutes apart during any 24-
hour period. �'
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours
shall collect effluent grab samples at least every six hours; there must be a minimum of four
samples during a 24-hour sampling period.
Any composite sampling method other than continuous would have to be approved on a case -by -case basis by
the Division. The only option for the permit renewal is grab or composite. However, we may address you
request separately from the permit renewal at another time.
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
26

derek.denard(aD-ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Water Quality Labs [mailto:[e-mail]]
Sent: Tuesday, October 17, 2017 11:52 AM
To: [e-mail]; Denard, Derek <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Heim, Tim <[e-mail]>; Kinney,
Maureen <[e-mail]>
Subject: [External] Re: Draft NPDES Permit NCO062961 - Tynecastle WWTP, WW-2
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify
that the attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Mr. Denard,
We are in receipt of the draft permit for Tynecastle WWTP (NC0062961). We would like to request
that sampling for the aforementioned be changed to time -paced sampling as opposed to flow -
proportional sampling. While the plant's design is 0.030 MGD, the system has not experienced an
average flow at or above that from January 2015 to the present time. I have attached a document
detailing that data for your perusal.
27

Thank you for your time and consideration; please feel free to contact me if I can be of further
assistance.
Sincerely,
Jadd Brewer
Water Quality Lab & Operations, Inc.
PO BOX 1167/1522 Tynecastle Hwy.
Banner Elk, North Carolina 28604
Phone-[phone]
Fax- [phone]
On Monday, September 25, 2017, 1:09:08 PM EDT, Denard, Derek <derek.denard(cDncdenr.gov> wrote:
Please find the attached copy of the draft permit NCO062961 for Tynecastle WWTP. A hard copy will be mailed to the
permittee shortly. Please provide your comments, if any, to me via email [[e-mail]] or write to my
attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. If you have questions concerning this
draft, please e-mail me or call my direct line [phone].
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard(a)ncdenr.gov
F

0
Water Quality Lab & Operations, Inc.
P.O. Box 1167/ 1522 Tynecastle Highway
Banner Elk, NC 28604
Ph. 828-898-6277 Fax [phone]
August 24, 2016
Mr. Bob Sledge
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Tynecastle WWTP
Mr. Sledge:i
I am writing to request hat Tynecastle WWTP, NPDES Number NC0062961, have their
permit amended to refl ct that their samples are changed from flow proportional
sampling to grab sampling. Our request is based on flow data that reflects that the plant
has not exceeded 30,006 gallons in flow over the past three'(3) years. We intend to
request the same when their permit renews in 2017.
I appreciate your time and attention to this matter. Please feel free to contact me with atiy
questions or concerns.
Sincerely,
Jadd Brewer
Signatory for Tynecastle
Operations Mangier of Water Quality Labs
I
Cc: Linda Wiggs,. Ash Iville Regional Office
vision W�I R�"O
Dirces
SEP 6 2016
water otiafity Regional operations
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