NC0023281_Fact Sheet_20230628

FACT SHEET FOR EXPEDITED PERMIT RENEWALS
This form must be completed by Permit Writers for all expedited permits which do not require full Fact
Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc)
that can be administratively renewed with minor changes, but can include facilities with more complex
issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance
concerns).
Basic Information for Expedited Permit Renewals
Permit Writer / Date
Siying Chen 11/09/2022
Permit Number
NCO023281
Facility Name / Facility Class
Ta oco Lodge & Village WWTP / WW-2
Count / Regional Office
Graham / ARO
Basin Name / Sub -basin number
Little Tennessee / 04-04-02
Receiving Stream / HUC
Little Tennessee River (Cheoah Lake,
Calderwood Lake) / 060102040107
Stream Classification / Stream Segment
C-Trout / 2- 167
Does permit need Daily Maximum NH3 limits?
No
Does permit need TRC limits/language?
N/A
Does permit have toxicity testing? IWC % if so
No
Does permit have Special Conditions?
No
Does permit have instream monitoring?
No
Is the stream impaired on 303(d) list)?
No
Any obvious compliance concerns?
No
Changes in draft permit?
Added WWTP classification
Updated eDMR requirements
Updated parameter codes
Added monitoring for temperature, turbidity, and
dissolved oxygen
Updated outfall ma
New expiration date
10/31/2027
Comments on Draft Permit?
Ownership change
ARO commented on component list
SELC commented on temperature in trout waters
Most Commonly Used Expedited Language:
• 303(d) language for Draft/Final Cover Letters: "Please note that the receiving stream is listed
as an impaired waterbody on the North Carolina 303(d) Impaired Waters List. Addressing
impaired waters is a high priority with the Division, and instream data will continue to be
evaluated. If there is noncompliance with permitted effluent limits and stream impairment can
be attributed to your facility, then mitigative measures may be required".
• TRC language for Comuliance Level for Cover Letters/Effluent Sheet Footnote: "The
facility shall report all effluent TRC values reported by a NC certified laboratory including field
certified. However, effluent values below 50 µg/l will be treated as zero for compliance
purposes."
Fact Sheet for Permit Renewal
November 2022 -- NPDES Permit NCO023281 - Page 1

Section 1. Facility Overview:
This facility is a minor facility (flow < 1 MGD) discharging 100% domestic wastewater with a design
capacity of 0.02 MGD. This WWTP utilizes the following treatment components:
• Aeration
• Clarifier
• Sludge and skimmer returns
• Aerated sludge holding
• Continuous flow monitoring
Section 2. Compliance History (June 2018 — March 2022):
• No compliance issue during the last permit cycle.
Section 3. Chanp_es from previous permit to draft:
• Updated facility address on cover sheet and supplement to permit cover sheet.
• Added facility grade in A. (1).
• Updated eDMR footnote in A. (1) and language in A. (2).
• Updated parameter codes for BOD5 and Total Suspended Solids in A. (1).
• Added instream monitoring for temperature and effluent monitoring for turbidity and dissolved
oxygen in A. (1) to determine compliance with 15A NCAC 02B.0211.
• Updated outfall map.
• For WW-2 classification per 15A NCAC 02B .0400 et seq., 02B .0500 et seq., monitoring
required for fecal coliform, pH, and ammonia nitrogen, however monitoring is not being added
as permit file history indicates these parameters were not included on earlier permits due to
dilution.
Section 4. Comments received on draft permit:
Received comment from previous owner that they had submitted ownership change request back
in November 2022, but such request couldn't be located in our files. Processed the ownership
change during the comment period.
ARO staff Lauren Armeni performed site inspection on June 13, 2023, and noted some
discrepancies in the component list during her inspection:
o No sludge holding tank at the facility. There's a section at the end of the package plant
that isn't really used for anything (it's pumped out when they pump out the secondary
clarifier), and it connects to the secondary clarifier, so it's not an isolated area like a
sludge holding tank would be.
o Has a manual bar screen, which is missing in the component list
o Has two secondary clarifier tanks, but only one clarifier is listed in the permit
Fact Sheet for Permit Renewal
November 2022 -- NPDES Permit NCO023281 - Page 2

SELC submitted comment on behalf of MountainTrue, the North Carolina Chapter of Trout
Unlimited, North Carolina Wildlife Federation, Watauga Riverkeeper, and the Southern
Environmental Law Center on May 24, 2023, in regards of the temperature standard in trout
waters. SELC raised concerns about not having a temperature standard in the permit, even
though the permittee expects to discharge effluent warmer than the maximum in -stream
temperature allowed to protect the receiving streams' uses as trout waters. In response to this,
NPDES permitting unit management discussed and decided that 100% domestic discharges do
not qualify as a " heated liquid" as stated in the rule, and thus no trout water temperature
standards should be applied to this permit.
Section 5. Changes from draft to final:
• Updated ownership information on the cover sheet, supplement to permit cover sheet, and outfall
map.
• Updated component list on the supplement to permit cover sheet.
Fact Sheet for Permit Renewal
November 2022 -- NPDES Permit NCO023281 - Page 3

Clrl'IZE-- __ TIMES
Public Notice
State of North Carol ina/EnvironmentaI
Management Commission
1617 Mail Service Center,
Raleigh NC27699-1617
Notice of Intent to Issue a
NPDES wastewater permit.
The North Carolina Environmental Man-
a9ement Commission proposes to issue a
NPDES wastewater discharge permit to
the person(s) listed below. Tapoco Part-
ners, LLC [14981 Tapoco Road, Robbins-
ville, NC 287711 requested renewal of
permit NCO023281 for the Tapoco Locige
& Village WWTP in Graham County. T is
facility discharges to the Little Tennessee
River of the Little Tennessee River Basin.
Currently, no parameters are water quali-
ty limited. This discharge may affect fu-
ture allocations in this portion of the Little
Tennessee River. Western Valley Proper-
ties, LLC [505 Racking Cove Road, Sylva,
NC 287791 has requested renewal of per-
mit NCO032808 for Morningstar of
Jackson WWTP in Jackson County. This fa-
cility discharges to Blanton Branch in the
Little Tennessee River Basin. Currently, fe-
cal coliform and total residual chlorine are
water quality limited. This discharge may
affect future allocations in this portion of
Blanton Branch. Written comments re-
garding the proposed permit will be ac-
cepted until 30 days after the publish
date. The Director of the INC Division of
Water Resources may hold a public hear -
in should there be a significant degree
of public interest. Interested persons may
visit the DWR at 512 N. Salisbury Street,
Raleigh, NC, 27699. Please mail comments
and/or information requests to DWR at
the address listed above. Additional infor-
mation on NPDES permits and this notice
may be found on our website.
http://deq.nc.gov/about/d ivisions/water-
resources/water-resources-permits/
wastewater - branch/npdes-
wastewaterVpblic- notices, or by calling
[phone].
May 4, 2023
0005687534
VICKY FELTY
Notary Public
State of Wisconsin
PART OF THE USA TODAY NETWORK
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
NORTH CAROLINA
Before the undersigned.a Notary Public, duly commissioned, qualified and
authorized by law to administer oaths, personally appeared said legal clerk,
who. being first duly sworn, deposes and says: that he/she is the Legal
Clerk of The Asheville Citizen -Times, engaged in publication of a
newspaper known as The Asheville Citizen -Times, published, issued, and
entered as first class mail in the City of Asheville, in Buncombe County and
State of North Carolina; 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 here to, was published in The Asheville Citizen -Times on
the following date(s) 05/04/23. And that the said newspaper in which
said notice, paper, document or legal advertisement was published was, 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 Statutes of North Carolina.
Signed this 4th of May, 2023 ,
Leg 'al er
Sworn to and subscribed before the 4th of May, 2023
My Commission expires.
[phone] 1 [phone] FAX
14 O. HENRY AVE. I P.O. BOX 2090 1 ASHEVILLE, NC 28802 1 [phone]

NH3/TRC WLA Calculations
Facility: Tapoco Lodge & Village WWTP
PermitNo. NC0023281
Prepared By: Siying Chen
Enter Design Flow (MGD): 0.02
Enter s7Q10 (cfs): 82.3
Enter w7Q10 cfs : N/A
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
82.3
s7Q10 (CFS)
82.3
DESIGN FLOW (MGD)
0.02
DESIGN FLOW (MGD)
0.02
DESIGN FLOW (CFS)
0.031
DESIGN FLOW (CFS)
0.031
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
0.04
IWC (%)
0.04
Allowable Conc. (ug/1)
45149
Allowable Conc. (mg/1)
2071.8
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
N/A
Monthly Average Limit:
qot Required DESIGN FLOW (MGD)
0.02
(If DF >331; Monitor)
DESIGN FLOW (CFS)
0.031
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
2655.84 Upstream Bkgd (mg/1)
0.22
IWC (%)
#VALUE!
Allowable Conc. (mg/1)
#VALUE!
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

MONITORING REPORT(MR) VIOLATIONS for:
Permit: nc0023281 MRS Betweel 6 - 2018 and 3 - 2023 Region: %
Facility Name: % Param Nam(% County: %
Major Minor: %
Report Date: 04/05/22 Page 1 of 1
Violation Category:% Program Category:
Subbasin: % Violation Action: %
PERMIT: FACILITY: COUNTY: REGION:
MONITORING VIOLATION UNIT OF CALCULATED %
REPORT LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION

SOUTHERN 48 Patton Avenue, Suite 304 Telephone [phone]
ENVIRONMENTAL Asheville, NC 28801 Facsimile 828-258-2024
LAW
CENTER
May 24, 2022
Via Email
Richard Rogers
N.C. Dept. of Environmental Quality
Division of Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
Re: Application of the trout waters temperature standard in draft NPDES Permit
Nos. NC0020451, NC0023281, NC0032115, NC0061930, and NCO079561
Dear Mr. Rogers:
Please accept the following comments submitted on behalf of MountainTrue, North
Carolina Trout Unlimited State Council, North Carolina Wildlife Federation, Watauga
Riverkeeper, and the Southern Environmental Law Center related to the North Carolina
Department of Environmental Quality's ("DEQ") failure to apply the required trout waters
temperature standard in five recently noticed draft National Pollutant Discharge Elimination
System ("NPDES") permits: Draft Permit Nos. NCO020451 (West Jefferson WWTP),
NCO023281 (Tapoco Lodge & Village WWTP), NCO032115 (Town of Banner Elk WWTP),
NCO061930 (Mark Laurel WWTP), and NCO079561 (Town of Elk Park WWTP). All five
permits would authorize discharges into designated trout waters.' Proper application of the trout
waters temperature standard is critical to protecting trout populations in North Carolina.
Unfortunately, the draft permits leave the affected populations at risk by failing to ensure trout
streams remain sufficiently cool. We also point out several additional shortcomings in Draft
Permit No. NCO020451 (West Jefferson WWTP).
I. Trout require cold, clean water to survive.
Keeping water temperature in designated trout waters below certain thresholds is
critically important because North Carolina's three species of trout —brook trout, brown trout,
and rainbow trout —require cold, clean, oxygen -rich water to survive and thrive. Water
1 See NPDES Draft Permit Nos. NCO020451, West Jefferson WWTP (Feb. 22, 2023), at 2 (indicating discharge into
an unnamed tributary to Buffalo Creek" in the New River basin, classified as Class C trout water and North Fork
New River Outstanding Resource Water Area); NCO023281, Tapoco Lodge & Village WWTP (May 2, 2023), at 2
(indicating discharge into the Little Tennessee River, a Class C trout water in the Little Tennessee River basin);
NC0032115, Town of Banner Elk WWTP (March "xx" [sic] 2023), at 2 (indicating discharge into the Elk River, a
Class C trout water in the Watauga River basin); NC0061930, Mark Laurel WWTP (Apr. 5, 2023), at 2 (indicating
discharge into the East Fork Overflow Creek, a Class C trout water and an Outstanding Resource Water in the
Savannah River basin); and NC0079561, Town of Elk Park WWTP (Mar. 22, 2023), at 2 (indicating discharge into
the Little Elk Creek, a Class C trout water in the Watauga River basin).
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

temperature for these trout generally needs to be kept below 20 °C (68 OF).2 Unfortunately, past
and ongoing land management practices threaten trout habitats, including by increasing stream
temperatures. As we explained in our comments on North Carolina's draft 2022 Clean Water Act
Section 303(d) list, numerous trout streams routinely exceed safe water temperatures for trout.3
Climate change is exacerbating this problem. By 2060, western North Carolina is
predicted to see 10-20 more days each year with air temperatures above 35 °C (95 OF), increasing
the potential for water temperatures to rise above 2 1. 1 °C (70 °F)—levels that can be lethal to
trout.4 This combination of past habitat loss, ongoing poor land management practices, and
climate change poses an existential threat to many western North Carolina trout populations.
Declines in trout populations —driven by increasing stream temperatures or otherwise —
will hurt local economies. The total economic benefit of trout fishing in North Carolina is
estimated at $383.3 million annually, supporting nearly 3,600 jobs.5 If trout habitats are further
reduced, these economic benefits will be at risk. Overall, stream temperatures in North Carolina
are increasing, and this trajectory is predicted to continue under a changing climate. To protect
trout populations and the businesses that rely on them, North Carolina must take proactive steps
to ensure trout waters remain sufficiently cold.
II. North Carolina promulgated a temperature water quality standard to protect
trout.
Recognizing that trout require cold water, North Carolina exercised its authority under
the Clean Water Act to develop a temperature water quality standard designed to keep trout
streams cold. The Clean Water Act requires states to designate "uses" of waterbodies and
promulgate standards to protect those uses. See 33 U.S.C. § 1313; 40 C.F.R. § 131.10; N.C. Gen.
Stat. § 143-214.1. All waterbodies in North Carolina are subject to a temperature standard to
protect their associated designated use. 15A N.C. Admin. Code 2B.0211(18). Some North
Carolina waterbodies have been assigned a "trout waters" use. See 15A N.C. Admin. Code
213.0301(b)(3) (explaining trout waters classification); 40 C.F.R. § 131.10(c) ("States may adopt
sub -categories of a use and set the appropriate criteria to reflect varying needs of such sub-
categories of uses, for instance, to differentiate between cold water and warm water fisheries.").
The temperature standard —for both trout waters and non -trout waters —provides that water
temperature is:
2 Trout Species of North Carolina, Fly Fishing NC (accessed Dec. 16, 2022), https://www flyfishingnc.com/trout-
species-of-north-carolina.
s S. Envtl. L. Ctr., Comments on North Carolina's Draft 2022 § 303(d) List (Feb. 28, 2022).
a Emma Johnson, Climate Change Challenges Trout Industry in North Carolina, Carolina Public Press (Feb. 17,
2021), https:Hcarolinapublicpress.org/42527/climate-change-challenges-trout-industry-in-north-carolina/. See also
Kunkel, K.E., et al., North Carolina Climate Science Report (2020), available at
https://ncics. org/wpcontent/uploads/2020/ 10/NC_Climate_Science_Report_FullReport_Final_revised_September20
20.pdf.
5 N.C. Wildlife Res. Comm'n, Mountain Trout Fishing: Economic Impacts on and Contributions to North Carolina's
Economy (2015), available at https://www ncwildlife.org/Portals/0/Fishing/documents/Economic-Impacts-Trout-
Fishing.pdf.

not to exceed 2.8 degrees C (5.04 degrees F) above the natural water temperature,
and in no case to exceed 29 degrees C (84.2 degrees F) for mountain and upper
piedmont waters and 32 degrees C (89.6 degrees F) for lower piedmont and coastal
plain waters; the temperature for trout waters shall not be increased by more than
.5 degrees C (0.9 degrees F) due to the discharge of heated liquids, but in no case
to exceed 20 degrees C (68 degrees F).
15A N.C. Admin. Code 02B .0211(18).
The standard has two partsa delta limit and an absolute limit. In non -trout waters, the
delta limit prohibits an increase attributable to a discharger of more than 2.8 °C above the natural
water temperature. The absolute limit provides that temperature shall "in no case" exceed 29 °C
in mountain and upper piedmont waters and 32 °C in lower piedmont and coastal plain waters
regardless of the presence of permitted dischargers.
The trout waters standard follows this same structure: Stream temperature may not be
increased "by more than .5 degrees C ... due to the discharge of heated liquids" but "in no case"
shall stream temperature exceed 20 °C. This makes sense because keeping trout waters below
20 'C—regardless of the presence of permitted dischargers —is critical to sustaining healthy trout
populations.
North Carolina's temperature standard, including for trout waters, is implemented in part
through NPDES permits that regulate point source discharges by setting limits and monitoring
requirements for a variety of water quality characteristics. 33 U.S.C. § 1342(a). State agencies
with delegated authority to administer the NPDES program, such as DEQ, are responsible for
ensuring NPDES permits identify and apply the correct water quality limits for the waterbody
into which the permittee will be discharging effluent.
In issuing a recent NPDES permit for a discharge into a designated trout water without
the required temperature standards, DEQ explained it had concluded that "effluent from 100%
domestic WWTPs [is] not a `heated liquid' as reference[d] in the rule" and, presumably, that the
trout waters temperature standard therefore did not apply.6 This conclusion is unsupported by the
text and the purpose of the rule; it is also irrelevant to the absolute limit set by the standard.
Temperature in trout waters shall "in no case ... exceed 20 degrees C." 15A N.C. Admin. Code
2B.0211(18) (emphasis added). DEQ must include limitations in permits to ensure that
discharges do not cause or contribute to an exceedance of the 20°C standard, even if that
discharge is not a "heated liquid."
III. DEQ must ensure all five draft NPDES permits comply with the trout waters
temperature standard.
To comply with the Clean Water Act and state water quality standards, DEQ must ensure
all five draft NPDES permits facilitate compliance with the temperature limits necessary to
protect trout waters. The draft permits out for comment currently contain no language to prevent
exceedances of those standards, despite in two cases newly including in -stream monitoring
6 Fact Sheet for NPDES Permit No. NCO067318 (Jan. 13, 2023).
3

requirements for temperature.7 We applaud DEQ for taking notice of the importance of
monitoring water temperature for the protection of trout waters. But it must also include permit
limits to prevent violations of water quality standards, including the trout waters temperature
standard.
The draft permit for the West Jefferson WWTP (Draft Permit No. NCO020451)
exemplifies why permit limits are necessary. West Jefferson's application materials list an
estimated maximum effluent temperature of 23.5 °C, exceeding the 20-degree maximum set for
trout waters. s The application also incorrectly refers to the applicable temperature standard as
29 °C instead of the 20 °C limit required for trout waters.9 Further, the effluent is expected to
constitute 56 percent of the receiving stream's total flow.10 This indicates a substantial risk that
the discharge will violate both the delta and absolute temperature limits applicable to discharges
to trout waters.
This is particularly problematic because temperature is a "parameter of concern for
aquatic life" for this facility and DEQ has documented a "statistically significant difference" in
temperature between monitoring stations upstream and downstream of the discharge point." In
other words, it appears the discharge is increasing stream temperature. The receiving stream is
also listed as impaired on North Carolina's Section 303(d) list due to effects to "benthos" and the
"fish community."12 Taken together, DEQ is aware that this facility is causing impacts to stream
temperature in an impaired waterbody. Nevertheless, the draft permit includes no limit on this
facility's ability to affect stream temperature. The limited discussion of temperature in the draft
permit materials applies the wrong standard —the 29 °C standard applicable to mountain waters
generally instead of the 20 °C limit required for trout waters.
To be clear, DEQ has no authority to issue NPDES permits that do not ensure compliance
with water quality standards, including the trout waters temperature standard. See 33 U.S.C. §
1311(b)(1)(C) (requiring NPDES permits to include limitations "necessary to meet water quality
standards"); 40 C.F.R. § 122.44(d)(1). Where draft permits fail to ensure compliance —as is the
case with the West Jefferson WWTP draft permit —those permits must be revised.
Incorporating the trout waters temperature standard into permits is also important because
DEQ has failed to correctly apply this standard when preparing its Clean Water Act Section
303(d) list. Section 303(d) requires states to identify waterbodies that are not meeting water
quality standards, investigate the reasons for noncompliance, and develop a plan to remediate
those problems. For several years, DEQ has wrongly applied in the Section 303(d) context the
water quality temperature standard for mountain waters (29 °C) to designated trout waters
I Letter from Emily Richards, N.C. Dep't of Env't Qual., to Paul Isenhour, Water Qual. Labs & Operations, Inc.
(March "xx" [sic] 2023), at 1; Letter from Siying Chen, N.C. Dep't of Env't Qual., to Kevin Bailey, Tapoco
Partners, LLC (May 2, 2023), at 1.
a Fact Sheet for draft NPDES Permit No. NC 0020451, West Jefferson WWTP (Feb. 16, 2023), at 3.
9 Id. at 4, 5 ("Temperatures in both [instream monitoring] sites were below the standard of 29 °C for upper piedmont
and mountain waters.").
to Id. at 2.
" Id. at 5.
12 See generally North Carolina 2022 Integrated Report at 1035, available at
https:Hedocs.deq nc.gov/WaterResources/DocView.aspx?dbid=0&id=2361713&cr=1.
al

protected by the 20 °C standard.13 DEQ has committed that error with respect to at least one of
the receiving streams at issue here. Tapoco Lodge & Village WWTP (Draft Permit No.
NC0023281) discharges into Cheoah Lake, a designated trout water, but in the Section 303(d)
context DEQ assesses compliance with a temperature standard of 29 °C.14 The 2022 303(d)
Integrated Report does not disclose which standard DEQ applied to other receiving waters at
issue in the draft NPDES permits. But the combination of these two errors —failure to include
temperature standards in NPDES permits and failure to assess compliance with the correct
temperature standard in the Section 303(d) context —generally risks jeopardizing trout
populations.
In summary, before finalizing any of these five permits, DEQ must ensure they facilitate
compliance with the water quality temperature standard for trout waters. The most
straightforward and thorough approach is to include language DEQ has already properly applied
to other trout water discharge permits:
"The instream temperature shall not be increased by more than 0.5 degrees C (0.9
degrees F) due to the discharge of heated liquids, but in no case to exceed 20
degrees C (68 degrees F). If the stream temperature exceeds 20 degrees C due to
natural background conditions, the effluent cannot cause any increase in instream
water temperature."
This expression of the temperature standard, found in the most recent draft NPDES
permit for the Buffalo Meadows WWTP, NPDES Permit No. NCO030325 (and others), correctly
requires permittees to cause no further increase in temperature when stream temperature already
exceeds trout water standards. Apparently, the Tapoco Lodge & Village WWTP permit used to
include similar language —in each of the 1998, 2003, 2007, and 2012 permits —but it was
removed in 2018.15 To meet its obligations under the Clean Water Act, DEQ should add this
language back.
IV. DEQ must correct additional problems in Draft Permit No. NCO020451 (West
Jefferson WWTP)
In addition to the trout waters temperature standard issue discussed above, DEQ must
address several additional shortcomings in Draft Permit No. NCO020451 (West Jefferson
WWTP).
First, the total suspended solids limit in the draft permit runs afoul of the Clean Water
Act's anti -backsliding provision, which EPA has interpreted to require that "when a permit is
renewed or reissued, interim effluent limitations, standards or conditions must be at least as
stringent as the final effluent limitations, standards, or conditions in the previous permit." 40
C.F.R. § 122.44(l)(1). Here, the previous permit limited total suspended solids to 10 mg/L
" See supra note 3.
14 See supra note 12, at 538.
" Compare Fact Sheet for draft NPDES Permit No. NC0023281, Tapoco Lodge & Village WWTP (April 25, 2018),
at 2 with NPDES Permit No. NC0023281 (March 30, 1998), at 3 n.2; NPDES Permit No. NC0023281 (Jan. 27,
2003), at 4 n.1; NPDES Permit No. NC0023281 (Oct. 8, 2007), at 4 n.1; NPDES Permit No. NC0023281 (Aug. 22,
2012), at 4 n.1.
5

monthly average and 15 mg/L weekly average. 16 The draft permit attempts to increase those
limits to 30 mg/L and 45 mg/L, respectively. DEQ must impose the earlier total suspended solids
limit to remain in compliance with the Clean Water Act.
Second, the compliance schedule for copper in the draft permit also falls short of the
Clean Water Act's requirements. Regulations implementing the Clean Water Act require a
compliance schedule, for example, to impose "an enforceable sequence of interim requirements"
leading to compliance. 40 C.F.R. § 122.2. Compliance must be achieved "as soon as possible."
40 C.F.R. § 122.47(a), see also 40 C.F.R. § 123.25 (requiring permitting authorities to administer
delegated state programs in conformance with this and other specified regulatory provisions).
EPA's guidance to permit writers reinforces that schedules of compliance to meet state water
quality standards must meet certain minimum criteria.17 Echoing the regulatory requirements,
permit writers must "U]ustify and demonstrate that compliance with the final WQBEL is
required as soon as possible."
Here, the compliance schedule for copper appears to have been copied and pasted from
another permit —indeed, the compliance schedule repeatedly refers to achievement of zinc and
silver limits even though the schedule is purportedly about copper limits.18 There is no indication
that DEQ is attempting to achieve water quality limits "as soon as possible" as required under the
Clean Water Act. To the extent a compliance schedule is permissible here at all, DEQ has not
carried its burden to show how the proposed schedule meets Clean Water Act requirements.
Third, we understand that DEQ has also added a monitoring condition for PFAS to the
draft permit.19 If DEQ suspects that the West Jefferson facility discharges PFAS, it must demand
sampling information in the permit application process and evaluate whether technology -based
and water quality -based limits are necessary. See 40 C.F.R. §§ 125.3, 122.44(d)(1)(i); see also
Piney Run Pres. Assn v. Cty. Commis of Carroll Cty., Maryland, 268 F.3d. 255, 268 (4th Cir.
2001). The monitoring condition is also too lenient. As EPA made clear in guidance issued last
December, monitoring should "be conducted at least quarterly to ensure that there are adequate
data to assess the presence and concentration of PFAS in discharges."20 This requirement should
be applied to all wastewater plants, including those without industrial users.21 Moreover, EPA
has stressed that these requirements should be implemented immediately and that agencies need
not wait for Draft Method 1633 to be finalized.22
16 See NPDES Permit No. NCO020451, West Jefferson WWTP (Feb. 16, 2018), at 2.
17 See U.S. EPA, NPDES Writers Manual § 9.1.3, available at https://www.epa.gov/sites/production/files/2015-
09/documents/pwm 2010.pdf
18 See NPDES Draft Permit No. NCO020451, West Jefferson WWTP (Feb. 22, 2023), at 10.
19 See id. at 3; Fact Sheet for NPDES Draft Permit No. NCO020451, West Jefferson WWTP, at 9.
21 Memorandum from Radhika Fox, Assistant Administrator, U.S. Env't Prot. Agency, Addressing PFAS
Discharges in NPDES Permits and Through the Pretreatment Program and Monitoring Programs (Dec. 5, 2022), at 4
(emphasis added).
21 Id.
22 Id.
on

V. Conclusion
North Carolina has some of the best and most at -risk trout habitat in the eastern United
States. Ensuring viable trout populations persist in the future requires keeping trout streams clean
and cold. To that end, DEQ must forthrightly apply the trout waters temperature standard in the
final versions of NPDES Permit Nos. NCO020451, NCO023281, NC0032115, NC0061930, and
NC0079561.
Please notify Henry Gargan at [e-mail] or 828-258-2023 when DEQ issues
final versions of these NPDES permits. We remain available as always to discuss our concerns.
Sincerely,
Henry Gargan
Associate Attorney
Southern Environmental Law Center
hga^rgannselcnc.org
Patrick Hunter
Managing Attorney
Southern Environmental Law Center
Cc: Charles Weaver ([e-mail])
Gary Perlmutter ([e-mail])
Emily Richards ([e-mail])
Siying Chen ([e-mail])
7

Water Resources
ENVIRONMENTAL QUALITY
April 25, 2018
Robin Turner and Adrian Bailey
Tapoco Partners, LLC
14981 Tapoco Road
Robbinsville, NC, 28771
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Subject: NPDES PERMIT ISSUANCE
NPDES Permit NCO023281
Tapoco Lodge & Village WWTP
Class WW-2
Graham County
Dear Permittee:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached final 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 October 15,
2007 (or as subsequently amended).
The final permit includes the following significant changes from the existing permit:
➢ The facility classification has been changed to Class WW-2 per the letter dated January 23, 2018
from the NC Water Pollution Control System Operators Certification Commission.
➢ The footnote in Section A. (1) and language in Section A. (2) have been added concerning the
requirement for electronic submission of effluent data. Federal regulations require electronic
submittal of all discharge monitoring reports (DMRs).
➢ Regulatory citations have been added.
➢ Outfall map has been updated.
➢ The owner name has been updated based on paperwork submitted.
➢ Language on the Supplement to Permit Cover Sheet has been updated.
➢ The footnote for temperature in Section A. (1) has been removed as it is not required.
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 permit 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 any other Federal, State, or Local governmental permit that may be required.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, NC 27699-1617
919 807 6300 919-807-6389 FAX
https://deq.nc.govlaboutldivi sionslwater-resources/water-resources-permitslwastewater-branchlnpdes-wastewater-permits

Robin Turner and Adrian Bailey
NC0023281 Renewal
p. 2
If you have any questions or need additional information, please do not hesitate to contact Brianna
Young of my staff at [phone], or via e-mail [[e-mail]].
S' ly,
Linda Culpepper
Interim Director, Division of Water Resources
cc: NPDES Files
Central Files
Asheville Regional Office

Permit NCO023281
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES ))
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,
Tapoco Partners, LLC
is hereby authorized to discharge wastewater from a facility located at the
Tapoco Lodge & Village WWTP
U.S. Highway 129, North of Tapoco
Graham County
to receiving waters designated as the Little Tennessee River (Cheoah Lake, Calderwood Lake) in
subbasin 04-04-02 of the Little Tennessee 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 June 1, 2018.
This permit and authorization to discharge shall expire at midnight on October 31, 2022.
Signed this day April 25, 2018.
I]� C
a Culpepper
Interim Director, Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 6

Permit NC0023281
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions included herein.
Tapoco Partners, LLC
is hereby authorized to:
1. Continue to operate an existing 0.02 MGD wastewater treatment facility with the following
components:
♦ Aeration
♦ Clarifier
♦ Sludge and skimmer returns
♦ Aerated sludge holding
♦ Continuous flow monitoring
The facility is located at the Tapoco Lodge & Village WWTP off U.S. Highway 129, North of
Tapoco in Graham County.
2. Discharge from said treatment works at the location specified on the attached map into the Little
Tennessee River (Cheoah Lake, Calderwood Lake) [Stream Segment: 2-(167)], currently classified
C; Trout waters in subbasin 04-04-02 [HUC: 0601020404] in the Little Tennessee River Basin.
Page 2 of 6

Permit NCO023281
PART I.
A. (1) 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 and monitored'
by the Permittee as specified below:
EFFLUENT CHARACTERISTIC
Parameter Code
LIMITS
MONITORING REQUIREMENTS
Sample Location
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Flow 50050
0.02 MGD
Continuous
Recorder
Influent or Effluent
BOD, 5-day 20°C 00310
30.0 m /L
45.0 m /L
Weekly
Grab
Effluent
Total Suspended Solids 00530
30.0 m /L
45.0 m /L
Weekly
Grab
Effluent
Temperature °C 00010
Weekly
Grab
Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR
application system [see A. (2)].
There shall be no discharge of floating solids or visible foam in other than trace amounts. -
Page 3 of 6

Permit NCO023281
A. (2) ELECTRONIC REPORTING OF MONITORING REPORTS
[NCGS 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.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
1. Reportine Requirements [Supersedes Section D. 2. and Section E. 5. a
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:
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
Page 4 of 6

Permit NCO023281
0 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: https://www.federalre ister.p-ov/documents/2015/10/22/2015-24954/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 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:
http://deLl.nc. gpv/about/divisions/water-resources/edmr
4. SSi natory Requirements ISupplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part II, Section
B. (I 1.)(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:
Page 5 of 6

Permit NCO023281
http://d2g.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:
7 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am
aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations. "
5. Records Retention [Sul2plements 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 6of6

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Tapoco Partners, LLC N
Tapoco Lodge & Village WWTP
NPDES Permit NCO023281
Receiving Stream: Little Tennessee River Stream Class: C; Trout Facility Location
Stream Segment: 2-(167) Sub -Basin M 04-04-02 scale not shown
River Basin: Little Tennessee HUC: 0601020404 SCALE USGS Quad: Tapoco
County: Graham 1:24,0130 1 35.450001, -83.943610
0 M

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Tapoco Partners, LLC
Attn: Kevin Bailey, President
14981 Tapoco Rd
Robbinsville, NC 28771
Subject: Permit Renewal
Application No. NCO023281
Tapoco Lodge & Village WWTP
Graham County
Dear Applicant:
NORTH CAROLINA
Environmental Quality
April 25, 2022
The Water Quality Permitting Section acknowledges the April 22, 2022 receipt of your permit renewal application and
supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting
branch. Per G.S. 150B-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deg.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
Sincere)
Wren Thedford
Administrative Assistant
Water Quality Permitting Section
ec: WQPS Laserfiche File w/application
� � North Carolina Department of Environmental Quality I nnawDivision of Water R Carolina
2 es
Asheville Regional Office 12090 US. Highway 70 I Swannanoa, North Carolina 28T78
828296.4500

North Carolina
Department of Environmental Quality
Division of Water Resources
Print All Pages
Print Form Only
Modified Application Form 2A
Revised March 2021
Modified Application
Form 2A
Minor Sewage Facilities < 0.1 MGD
and No Pretreatment Program
NPDES Permitting Program
RECEIVED
APR 2 2 2022
NCDEQIDWRINPDES
Note: Complete this form if your facility is a MINOR new or existing publicly owned treatment works.

NPDES Permit Number
Facility Name
Modified Application Form 2A
NCO023281
Historic Tapoco Lodge
Modified March 2021
Form
NC Department of Environmental Quality - Application for NPDES Permit to Discharge Wastewater
MINOR SEWAGE FACILITIES (Before completing this form, please read the instructions. Failure to follow
NPDES
the instructions ma result in denial of the lication.)
•
• • • n A • k • •
Facility name
1.1
Historic Tapoco Lodge
Mailing address (street or P.O. box)
14981 Tapoco Rd
City or town
State
ZIP code
c
Robbinsville
NC
28771
1°
Contact name (first and last)
Title
Phone number
Email address
Kevin Bailey
President
8284982800
[e-mail]
c
Location address (street, route number, or other specific identifier) © Same as mailing address
m
U-
City or town
State
ZIP code
1.2
Is this application for a facility that has yet to commence discharge?
❑ Yes + See instructions on data submission 0 No
requirements for new dischargers.
1.3
Is applicant different from entity listed under Item 1.1 above?
❑r Yes ❑ No 4 SKIP to Item 1.4.
Applicant name
Tapoco Partners LLC
Applicant address (street or P.O. box)
g
14981 Tapoco Rd
City
State
ZIP
or town
code
Robbinsville
NC
28771
Contact name (first and last)
Title
Phone number
Email address
a
Kevin Bailey
President
8284982800
kevinQtapoco.com
a
a
1.4
Is the applicant the facility's owner, operator, or both? (Check only one response.)
❑ Owner ❑ Operator ❑✓ Both
1.5
To which entity should the NPDES permitting authority send correspondence? (Check only one response.)
❑ Facility ❑ Applicant ED Facility and applicant
(they are one and the same)
1.6
Indicate below any existing environmental permits. (Check all that apply and print or type the corresponding permit
number for each.
Existing Environmental Permits
a
❑ NPDES (discharges to surface
❑ RCRA (hazardous waste)
❑ UIC (underground injection
water)
control)
E
c
NCO023281
o
❑ PSD (air emissions)
❑ Nonattainment program (CAA)
❑ NESHAPs (CAA)
c
w
rn
N
❑ Ocean dumping (MPRSA)
❑ Dredge or fill (CWA Section
❑ Other (specify)
w
404)
Page 1

NPDES Permit Number
Facility Name
Modified Application Form 2A
NC0023281
Historic Tapoco Lodge
Modified March 2021
1.7
Provide the collections stem information
requested below for the treatment works.
Municipality
Population
Collection System Type
Ownership Status
Served
Served
(indicate percentage)
100 % separate sanitary sewer
17 Own ❑ Maintain
% combined storm and sanitary sewer
❑ Own ❑ Maintain
it y
❑ Unknown
❑ Own ❑ Maintain
c
% separate sanitary sewer
❑ Own ❑ Maintain
—
% combined storm and sanitary sewer
❑ Own ❑ Maintain
❑ Unknown
❑ Own ❑ Maintain
a
a
% separate sanitary sewer
❑ Own ❑ Maintain
% combined storm and sanitary sewer
❑ Own ❑ Maintain
❑ Unknown
❑ Own ❑ Maintain
a,
% separate sanitary sewer ❑ Own ❑ Maintain
% combined storm and sanitary sewer El Own ❑ Maintain
rn
c
❑ Unknown ❑ Own ❑ Maintain
Total
°i
Population
�
Served
Separate Sanitary Sewer System Combined Storm and
Sanitary Sewer
Total percentage of each type of
100 % %
sewer line in miles
z'
1.8
Is the treatment works located in Indian Country?
V
El Yes No
1.9
Does the facility discharge to a receiving water that flows through Indian Country?
12
❑ Yes No
1.10
Provide design and actual flow rates in the designated spaces.
Design Flow Rate
02 mgd
Annual Average Flow Rates Actual
Two Years Ago
Last Year
This Year
c
0051 mgd
0087 mgd
0057 mgd
_c
Maximum Daily Flow Rates Actual
Two Years Ago
Last Year
This Year
.033 mgd
.047 mgd
.0167 mgd
U)
1.11
Provide the total number of effluent discharge points to waters of the State of North Carolina by type.
c
Total Number of Effluent Discharge Points b Type
a c.
Constructed
F
Treated Effluent
Untreated Effluent
Combined SewerOverflows
Bypasses
Emergency
_
Overflows
0
1
Page 2

NPDES Permit Number Facility Name Modified Application Form 2A
NCO023281 Historic Tapoco Lodge Modified March 2021
Outfalls Other Than to Waters of the State of North Carolina
1.12
Does the POTW discharge wastewater to basins, ponds, or other surface impoundments that do not have outlets
for discharge to waters of the State of North Carolina?
❑ Yes ❑✓ No 4 SKIP to Item 1.14.
1.13
Provide the location of each surface impoundment and associated discharge information in the table below.
Surface Im oundment Location and Dischar a Data
Average Daily Volume
Continuous or Intermittent
Location
Discharged to Surface
(check one)
Impoundment
❑ Continuous
gpd
❑ Intermittent
ElContinuous
gpd
❑ Intermittent
gpd
❑ Continuous
❑ Intermittent
j 0
1.14
Is wastewater applied to land?
❑ Yes ❑ No 4 SKIP to Item 1.16.
c1.15
Provide the land application site and discharge data requested below.
H
Land Application Site and Discharge Data
o
Average Daily Volume
Continuous or
CD
Location
Size
A lied
pp
Intermittent
2'
check one
m
Nacres
d
gpd
❑ Continuous
o
❑ Intermittent
s
acres
9p d
❑ Continuous
0
❑ Intermittent
acres
d
gpd
El Continuous
❑ Intermittent
1.16
Is effluent transported to another facility for treatment prior to discharge?
42
o
El Yes 0 No 4 SKIP to Item 1.21.
i
1.17
Describe the means by which the effluent is transported (e.g., tank truck, pipe).
1.18
Is the effluent transported by a party other than the applicant?
❑ Yes ❑ No 4 SKIP to Item 1.20.
1.19
Provide information on the transporter below.
Transporter Data
Entity name
Mailing address (street or P.O. box)
City or town
State
ZIP code
Contact name (first and last)
Title
Phone number
Email address
Page 3

NPDES Permit Number Facility Name Modified Application Form 2A
NCO023281 Historic Tapoco Lodge I Modified March 2021
1.20
In the table below, indicate the name, address, contact information, NPDES number, and average daily flow rate of the
receiving facility.
Receivina F cilitv Data
Facility name
Mailing address (street or P.O. box)
City or town
State
ZIP code
0
U
Contact name (first and last)
Title
0
r
d
Phone number
Email address
c0
NPDES number of receiving facility (if any) ElNone
Average daily flow rate mgd
N
1.21
Is the wastewater disposed of in a manner other than those already mentioned in Items 1.14 through 1.21 that do
0
not have outlets to waters of the State of North Carolina (e.g., underground percolation, underground injection)?
Cn
s
❑ Yes ❑✓ No 4 SKIP to Item 1.23.
U
a
1.22
Provide information in the table below on these other disposal methods.
Information on Other Disposal Methods
o
Disposal
Location of
Size of
Annual Average
Continuous or Intermittent
Method
Disposal Site
Disposal Site
Daily Discharge
(check one)
Description
Volume
acres
gpd
❑ Continuous
❑ Intermittent
acres
gpd
ElContinuous
❑ Intermittent
acres
gpd
❑ Continuous
❑ Intermittent
1.23
Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(n)? (Check all that apply.
d w
Consult with your NPDES permitting authority to determine what information needs to be submitted and when.)
❑ Discharges into marine waters (CWA ❑ Water quality related effluent limitation (CWA Section
Cr
Cc
Section 301(h)) 302(b)(2))
✓❑ Not applicable
1.24
Are any operational or maintenance aspects (related to wastewater treatment and effluent quality) of the treatment works
the responsibility of a contractor?
❑ Yes ❑r No +SKIP to Section 2.
1.25
Provide location and contact information for each contractor in addition to a description of the contractor's operational
and maintenance responsibilities.
Contractor Information
Contractor 1
Contractor 2
Contractor 3
0
Contractor name
com an name
Mailing
_
address
street or P.O. box
`o
City, state, and ZIP
code
c
Contact name (first and
U
last
Phone number
Email address
Operational and
maintenance
responsibilities of
contractor
Page 4

NPDES Permit Number Facility Name Modified Application Form 2A
NCO023281 Historic Tapoco Lodge Modified March 2021
SECTIONDD• •• • 1
c Outfalls to Waters of the State of North Carolina
LL
2.1
Does the treatment works have a design flow greater than or equal to 0.1 mgd?
rn
c
❑ Yes ❑✓ No 4 SKIP to Section 3.
c
2.2
Provide the treatment works' current average daily volume of inflow
Average Daily Volume of Inflow and Infiltration
.2
and infiltration.
gpd
Indicate the steps the facility is taking to minimize inflow and infiltration.
c
m
0
0
c
e
s
2.3
Have you attached a topographic map to this application that contains all the required information? (See instructions for
A
specific requirements.)
IM C
0
0
❑ Yes ❑ No
E
2.4
Have you attached a process flow diagram or schematic to this application that contains all the required information?
c 2
(See instructions for specific requirements.)
c
❑ Yes ❑ No
2.5
Are improvements to the facility scheduled?
❑ Yes ❑ No 4 SKIP to Section 3.
Briefly list and describe the scheduled improvements.
0
1.
c
E
n.
2.
E
0 0
y
d
3.
d
5
4.
N
0
2.6
Provide scheduled or actual dates of completion for improvements.
Scheduled or Actual Dates of Completion for Improvements
E
0
Scheduled
Affected
Begin
End
Begin
Attainment of
>
o
a.
Improvement
Outfalls
(list outfall
Construction
Construction
Discharge
Operational
Level
E
(from above)
number)
(MM/DDNYYY)
(MM/DD/YYYY)
(MM/DD/YYYY)
MM/DD/YYYY
v
1.
v
d
L
in
2.
3.
4.
2.7
Have appropriate permits/dearances conceming other federal/state requirements been obtained? Briefly explain your
response.
❑ Yes ❑ No ❑ None required or applicable
Explanation:
Page 5

NPDES Permit Number Facility Name Modified Application Form 2A
NCO023281 Historic Tapoco Lodge Modified March 2021
SECTION•- • ON • r
3.1 Provide the following information for each outfall. (Attach additional sheets if you have more than three outfalls.)
Outfall Number 001
Outfall Number
Outfall Number
State
NC
H
County
Graham
0
w
City or town
Robbinsville
0
c
.Qc
Distance from shore
30 ft.
ft.
ft.
Depth below surface
4 ft.
ft.
ft.
0
Average daily flow rate
•0072 mgd
mgd
mgd
Latitude
° " N or
° " N or
° " N or
Longitude
" N or
° " N or
"
3.2
Do any of the outfalls described under Item 3.1 have seasonal or periodic discharges?
c
❑ Yes ✓❑ No 4 SKIP to Item 3.4
3.3
If so, provide the following information for each applicable outfall.
L
Outfall Number
Outfall Number
Outfall Number
0
v
Number of times per year
0
discharge occurs
I
Average duration of each
_
0
discharge (specify units
c
Average flow of each
mgd
mgd
mgd
0
discharge
M
in
Months in which discharge
occu rs
3.4
Are any of the outfalls listed under Item 3.1 equipped with a diffuser?
❑ Yes ❑ No 4 SKIP to Item 3.6.
3.5
Briefly describe the diffuser type at each applicable outfall.
CL
Outfall Number
Outfall Number
Outfall Number
d
N
3
C)
c
3.6
Does the treatment works discharge or plan to discharge wastewater to waters of the State of North Carolina from
12 ?
one or more discharge points?
3
❑� Yes ❑ No 4SKIP to Section 6.
Page 6

NPDES Permit Number
Facility Name
Modified Application Form 2A
NCO023281 7
Historic Tapoco Lodge
Modified March 2021
3.7
Provide the receiving water and related information if known for each outfall.
Outfall Number 001
Outfall Number
Outfall Number
Little Tennessee River
Receiving water name
Name of watershed, river,
c
or stream system
U.S. Soil Conservation
Service 14-digit watershed
o
code
°=
Name of state
Little Tennessee River Basin
o
management/river basin
U.S. Geological Survey
8-digit hydrologic
cataloging unit code
Critical low flow (acute)
cfs
cfs
cfs
Critical low flow (chronic)
cfs
cfs
cfs
Total hardness at critical
mg/L of
mg/L of
mg/L of
low flow
CaCO3
CaCO3
CaCO3
3.8
Provide the following information
describing the treatment pr vided for discharges from each outfall.
Outfall Number 001
Outfall Number
Outfall Number
Highest Level of
❑ Primary
❑ Primary
❑ Primary
Treatment (check all that
O Equivalent to
❑ Equivalent to
❑ Equivalent to
apply per outfall)
secondary
secondary
secondary
❑ Secondary
❑ Secondary
❑ Secondary
❑ Advanced
❑ Advanced
❑ Advanced
❑ Other (specify)
❑ Other (specify)
❑ Other (specify)
0
0
aDesign
Removal Rates by
°°°81SS 0°mg2mMl, °er""°'
Outfall
y
Of
BOD5 or CBOD5
%
%
%
d
E
TSS
%
%
%
F=
0 Not applicable
❑ Not applicable
❑ Not applicable
Phosphorus
%
%
°
0 Not applicable
❑ Not applicable
❑ Not applicable
Nitrogen
o
°
o
Other (specify)
0 Not applicable
❑ Not applicable
❑ Not applicable
Page 7

NPDES Permit Number
Facility Name
Modified Application Form 2A
NC0023281
Historic Tapoco Lodge
Modred March 2021
3.9
Describe the type of disinfection used for the effluent from each outfall in the table below. If disinfection varies by
season, describe below.
d
c
I c
C
L)
c
Outfall Number 001
--
Outfall Number
Outfall Number
n
Disinfection type
None
N
d
Seasons used
m
E
m
Dechlorination used?
❑r Not applicable
❑ Not applicable
❑ Not applicable
r
❑ Yes
❑ Yes
❑ Yes
❑ No
❑ No
❑ No
3.10
Have you completed monitoring for all Table A parameters and attached the results to the application package?
R1 Yes ❑ No
3.11
Have you conducted any WET tests during the 4.5 years prior to the date of the application on any of the facility's
discharges or on any receiving water near the discharge points?
❑ Yes ❑ No + SKIP to Item 3.13.
3.12
Indicate the number of acute and chronic WET tests conducted since the last permit reissuance of the facility's
discharges by outfall number or of the receiving water near the dischar e points.
Outfall Number
Outfall Number
Outfall Number
Acute
Chronic
Acute
Chronic
Acute
Chronic
,o
Number of tests of discharge
rn
5
water
Number of tests of receiving
water
I>=
w
3.14
Does the POTW use chlorine for disinfection, use chlorine elsewhere in the treatment process, or otherwise have
reasonable potential to discharge chlorine in its effluent?
❑ Yes 4 Complete Table B, including chlorine. 0 No 4 Complete Table B, omitting chlorine.
3.15
Have you completed monitoring for all applicable Table B pollutants and attached the results to this application
package?
❑ Yes ✓❑ No
Have you completed monitoring for all applicable Table D pollutants required by your NPDES permitting authority and
3.18
attached the results to this application package?
❑ Yes No additional sampling required by NPDES
permitting authority.
Page 8

NPDES Permit Number
Facility Name
Modified Application Form 2A
NCO023281
Historic Tapoco Lodge
Modified March 2021
3.19
Has the POTW conducted either (1) minimum of four quarterly WET tests for one year preceding this permit application
or (2) at least four annual WET tests in the past 4.5 years?
❑ Yes ❑ No + Complete tests and Table E and SKIP to
Item 3.26.
3.20
Have you previously submitted the results of the above tests to your NPDES permitting authority?
❑ Yes ❑ No 4 Provide results in Table E and SKIP to
Item 3.26.
3.21
Indicate the dates the data were submitted to our NPDES permitting authority and provide a summary of the results.
Date(s) Submitted
Summary of Results
MM/DDNYYY
m
c
c
0
M
3.22
Regardless of how you provided your WET testing data to the NPDES permitting authority, did any of the tests result in
o
toxicity?
c
❑ Yes ❑ No 4 SKIP to Item 3.26.
3.23
Describe the cause(s) of the toxicity:
d
LU
w
3.24
Has the treatment works conducted a toxicity reduction evaluation?
❑ Yes ❑ No SKIP to Item 3.26.
3.25
Provide details of any toxicity reduction evaluations conducted.
3.26
Have you completed Table E for all applicable outfalls and attached the results to the application package?
❑ Yes Not applicable because previously submitted
information to the NPDES permittinq authority.
Page 9

NPDES Permit Number
Facility Name Modified Application Form 2A
NCO023281
Historic Tapoco Lodge Modified March 2021
SECTION•
. .
6.1
In Column 1 below, mark the sections of Form 2A that you have completed and are submitting with your application. For
each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not
all applicants are required to provide attachments.
Column 1
Column 2
ID Section 1: Basic Application
w/ variance requestEl w/ additional attachments
Informationforfor All A licants
❑ Section 2: Additional
❑ w/ topographic map ❑ w/ process flow diagram
Information
❑ w/ additional attachments
r❑ w/ Table A ❑ w/ Table D
❑ Section 3: Information on
❑ w/ Table B ❑ w/ additional attachments
d
Effluent Discharges
E
❑ w/ Table C
d
is
u'
Section 4: Not Applicable
c
c
eo
Section 5: Not Applicable
d
o
Section 6: Checklist and
❑
❑ w/ attachments
Certification Statement
;
6.2
Certification Statement
d
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations.
Name (print or type first and last name)
Official title
Kevin Bailey
President
Signoture
Date signed
V
4/18/22
Page 10

NPDES Permit Number
Facility Name
Outfall Number
NCO023281
Historic Tapoco Lodge
001
Modified Application Form 2A
Modified March 2021
•• I
Maximum Daily Discharge
Average Daily Discharge
Pollutant
Analytical
Number of
ML or MDL
Value
Units
Value Units Method'
(include units)
Sample
Biochemical oxygen demand
34.6
mg/L
10.6
mg/L
o BOD5 or ❑ CBOD5
❑ MIL
(report one
❑ MDL
Fecal coliform
n/a
❑ MIL
❑ MDL
Design flow rate
.020
mgd
0072
mgd
pH (minimum)
n/a
pH (maximum)
n/a
Temperature (winter)
6
Celcius
Temperature (summer)
24
Celcius
Total suspended solids (TSS)
32.9
mg/L
12.6
mg/L
❑ ML
❑ MDL
1 Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
Page 11

EPA Identification Number I NPDES Permit Number Facility Name Outfall Number
NCO023281 I Historic Tapoco Lodge
Modified Application Form 2A
Modified March 2021
Maximum Daily Discharge Average Daily Discharge
Pollutant
Analytical
ML or MDL
Number of
Value
Units
Value
Units
Method'
(include units)
Sam les
Ammonia (as N)
❑ ML
❑ MDL
Chlorine
❑ ML
total residual, TRC s
❑ MDL
Dissolved oxygen
❑ ML
❑ MDL
Nitrate/nitrite
❑ ML
❑ MDL
Kjeldahl nitrogen
❑ ML
❑ MDL
Oil and grease
❑ ML
❑ MDL
Phosphorus
❑ ML
❑ MDL
Total dissolved solids
❑ ML
❑ MDL
' Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
2 Facilities that do not use chlorine for disinfection, do not use chlorine elsewhere in the treatment process, and have no reasonable potential to discharge chlorine in their effluent are not
required to report data for chlorine.
EPA Form 3510-2A (Revised 3-19) Page 12

EPA Identification Number NPDES Permit Number Facility Name Outfall Number
Modified Application Form 2A
NC0023281 Historic Tapoco Lodge
Modified March 2021
Maximum Daily Discharge Average Daily Discharge
Pollutant
iu!
Analytical ML or MDL
Number of
Value Units Value Units
Method' (include units)
Samples
-
Metals, Cyanide, and Total Phenols
Hardness (as CaCO3)
❑ ML
❑ MDL
Antimony, total recoverable
❑ ML
❑ MDL
Arsenic, total recoverable
❑ ML
❑ MDL
Beryllium, total recoverable
❑ ML
❑ MDL
Cadmium, total recoverable
❑ ML
❑ MDL
Chromium, total recoverable
❑ ML
❑ MDL
Copper, total recoverable
❑ ML
❑ MDL
Lead, total recoverable
❑ ML
❑ MDL
Mercury, total recoverable
❑ ML
❑ MDL
Nickel, total recoverable
❑ ML
❑ MDL
Selenium, total recoverable
❑ ML
❑ MDL
Silver, total recoverable
❑ ML
❑ MDL
Thallium, total recoverable
❑ ML
❑ MDL
Zinc, total recoverable
❑ ML
❑ MDL
Cyanide
❑ ML
❑ MDL
Total phenolic compounds
❑ ML
❑ MDL
Volatile Organic Compounds
Acrolein
❑ ML
❑ MDL
Acrylonitrile
❑ ML
❑ MDL
Benzene
❑ ML
❑ MDL
Bromoform
❑ ML
❑ MDL
EPA Form 3510-2A (Revised 3-19) Page 13

EPA Identification Number NPDES Permit Number Facility Name Outfall Number
Modified Application Form 2A
NCOO23281 Historic Tapoco Lodge
Modified March 2021
••Mw � ••
Maximum Daily Discharge Average Daily Discharge
Pollutant
Analytical ML or MDL
Number of
Value Units Value Units
Method' (include units)
Samples
Carbon tetrachloride
❑ ML
❑ MDL
Chlorobenzene
❑ ML
❑ MDL
Chlorodibromomethane
❑ ML
❑ MDL
Chloroethane
❑ ML
❑ MDL
2-chloroethylvinyl ether
❑ ML
❑ MDL
Chloroform
❑ ML
❑ MDL
Dichlorobromomethane
❑ ML
❑ MDL
1,1-dichloroethane
❑ ML
❑ MDL
1,2-dichloroethane
❑ ML
❑ MDL
trans-1,2-dichloroethylene
❑ ML
❑ MDL
1,1-dichloroethylene
❑ ML
❑ MDL
1,2-dichloropropane
❑ ML
❑ MDL
1,3-dichloropropylene
❑ ML
❑ MDL
Ethylbenzene
❑ ML
❑ MDL
Methyl bromide
❑ ML
❑ MDL
Methyl chloride
❑ ML
❑ MDL
Methylene chloride
❑ ML
❑ MDL
1,1,2,2-tetrachloroethane
❑ ML
❑ MDL
Tetra chIoroethylene
❑ ML
❑ MDL
Toluene
❑ ML
❑ MDL
1,1,1-trichloroethane
❑ ML
❑ MDL
1,1,2-trichloroethane
❑ ML
❑ MDL
EPA Form 3510-2A (Revised 3-19) Page 14

EPA Identification Number NPDES Permit Number Facility Name Outfall Number
Modified Application Form 2A
NCOO23281 Historic Tapoco Lodge
Modified March 2021
Maximum Daily Discharge Average Daily Discharge
Pollutant
Analytical ML or MDL
Number of
Value Units Value Units
Method' (include units)
Samples
Trichloroethylene
❑ ML
❑ MDL
Vinyl chloride
❑ ML
❑ MDL
Aci I -Extractable Compounds
p-chloro-m-cresol
❑ ML
❑ MDL
2-chlorophenol
❑ ML
❑ MDL
2,4-dichlorophenol
❑ ML
❑ MDL
2,4-dimethylphenol
❑ ML
_
❑ MDL
4,6-dinitro-o-cresol
❑ ML
❑ MDL
2,4-dinitrophenol
❑ ML
❑ MDL
2-nitrophenol
❑ ML
❑ MDL
4-nitrophenol
❑ ML
❑ MDL
Pentachlorophenol
❑ ML
❑ MDL
Phenol
❑ ML
❑ MDL
2,4,6 trichlorophenol
❑ ML
❑ MDL
Base -Neutral Compounds
Acenaphthene
❑ ML
❑ MDL
Acenaphthylene
❑ ML
❑ MDL
Anthracene
❑ ML
❑ MDL
Benzidine
❑ ML
❑ MDL
Benzo(a)anthraCene
❑ ML❑
MDL
Benzo(a)pyrene
❑ ML
❑ MDL
3,4-benzofluoranthene
❑ ML❑
MDL
EPA Form 3510-2A (Revised 3-19) Page 15

EPA Identification Number NPDES Permit Number Facility Name Outfall Number
Modified Application Form 2A
NCOO23281 Historic Tapoco Lodge
Modified March 2021
Maximum Daily Discharge Average Daily Discharge
Pollutant Number of
Value Units Value Units Samples
Analytical ML or MDL
Method' (include units)
Benzo(ghi)perylene
❑ ML
❑ MDL
Benzo(k)fluoranthene
❑ ML
❑ MDL
Bis (2-chloroethoxy) methane
❑ ML
❑ MDL
Bis (2-chloroethyl) ether
❑ ML
❑ MDL
Bis (2-chloroisopropyl) ether
❑ ML
❑ MDL
Bis (2 ethylhexyl) phthalate
❑ MIL
❑ MDL
4 bromophenyl phenyl ether
❑ ML
❑ MDL
Butyl benzyl phthalate
❑ ML
❑ MDL
2-chloronaphthalene
❑ ML
❑ MDL
4 chlorophenyl phenyl ether
❑ ML
❑ MDL
Chrysene
❑ ML
❑ MDL
di-n-butyl phthalate
❑ ML
❑ MDL
di-n-octyl phthalate
❑ ML
❑ MDL
Dibenzo(a,h)anthracene
❑ ML
❑ MDL
1,2 dichlorobenzene
❑ ML
❑ MDL
1,3-dichlorobenzene
❑ ML
❑ MDL
1,4-dichlorobenzene
❑ ML
❑ MDL
3,3-dichlorobenzidine
❑ ML
❑ MDL
Diethyl phthalate
❑ ML
❑ MDL
Dimethyl phthalate
El ML
❑ MDL
2,4-dinitrotoluene
❑ ML
❑ MDL
2,6 dinitrotoluene
El ML
❑ MDL
EPA Form 3510-2A (Revised 3-19) Page 16

EPA Identification Number NPDES Permit Number Facility Name Outfall Number
Modified Application Form 2A
NCO023281 Historic Tapoco Lodge
Modified March 2021
Maximum Daily Discharge Average Daily Discharge
Pollutant
Analytical ML or MDL
Number of
Value Units Value Units
Method' (include units)
Samples
1,2-diphenylhydrazine
❑ ML
❑ MDL
Fluoranthene
❑ ML
❑ MDL
Fluorene
❑ ML
❑ MDL
Hexachlorobenzene
❑ ML
❑ MDL
Hexachlorobutadiene
❑ ML
❑ MDL
Hexachlorocyclo-pentadiene
❑ ML
❑ MDL
Hexachloroethane
❑ ML
❑ MDL
indeno(1,2,3-cd)pyrene
❑ ML
❑ MDL
Isophorone
❑ ML
❑ MDL
Naphthalene
❑ ML
❑ MDL
Nitrobenzene
❑ ML
❑ MDL
N-nitrosodi-n-propylamine
❑ ML
❑ MDL
N-nitrosodimethylamine
❑ ML
❑ MDL
N-nitrosodiphenylamine
❑ ML
❑ MDL
Phenanthrene
❑ ML
❑ MDL
Pyrene
❑ ML
❑ MDL
1,2,4-trichlorobenzene
❑ ML
❑ MDL
1 Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR Chapter I, Subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2A (Revised 3-19) Page 17

NPDES Permit Number Facility Name Out -fall Number Modified Application Form 2A
NCO023281 Historic Tapoco Lodge 001 Modified March 2021
Maximum Dail Da Average Daily Discharge
Pollutant Analytical ML or MDL
Number
(list) Value Units Value Units Methods (include units)
s
Samples
❑� No additional sampling is required by NPDES permitting authority.
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
❑ ML
❑ MDL
I Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required
under 40 CFR chapter I, subchapter Nor 0. See instructions and 40 CFR 122.21(e)(3).
Page 18