NC0070394_fact_20230905

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
FACT SHEET
EXPEDITED - PERMIT RENEWAL
Basic Information for Expedited Permit Renewals
Permit Writer/Date
Charles Weaver — 9/5/2023
Permit Number - Class
NC0070394 — Class WW-2
Owner
Willowbrook Run Property Owners Association, Inc.
Facility Name
Willowbrook Park WWTP
Type of Waste
100 % domestic
Basin Name/Sub-basin number
Little Tennessee / 04-04-01
Receiving Stream
Coweeta Creek [segment 2-10
Stream Classification in Permit
B-Trout
Does permit need Daily Max NH3 limits?
N/A due to massive dilution.
Does permit need TRC limits/language?
Already resent
Does permit have toxicity testing?
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?
One enforcement case and one NOV during the last permit cycle.
Any permit MODS since lastpermit?
No
New expiration date
July 31, 2028
Changes to current permit?
➢ Corrected owner name
➢ Corrected facility name
➢ Added monitoring for turbidity to determine compliance
with 15A NCAC 02B.0211 (21)
➢ Added instream temperature monitoring to determine
compliance with 15A NCAC 02B.0211 (18)
➢ Added monitoring for dissolved oxygen to determine
compliance with 15A NCAC 0213.0211 (6)
➢ Updated eDMR language
Changes to final permit?
➢ None. SELC sent standard letter demanding temperature
limit instream. NPDES management has decided that
effluent from 100% domestic WWTPs is not a "heated
liquid" as mentioned in the rule, and that instream
monitoring is sufficient.

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Invoice / Affidavit
The Franklin Press
Post Office Box 350
Franklin, NC 28744
STATE OF NORTH CAROLINA
COUNTY OF MACON
PUBLIC NOTICE
North Carolina Environmental
AFFIDAVIT OF PUBLICATION Personally appeared before the undersigned, Rachel Management
Hoskins, who having been duly sworn on oath that she is the Regional Publisher Commission/NPDES Unit I
of The Franklin Press, and the following legal advertisement was published in 1617 Mail Service Center
617
The Franklin Press newspaper, and entered as second class mail in the Town of Raleigh, Intent
nt to 1Iss
Notice of Intent to Issue a
Franklin in said county and state; and that she is authorized to make this NPDES Wastewater Permit
affidavit and sworn statement; that the notice or other legal advertisement, a NC0070394 Willowbrook Part
g WW iP The North Carolina
true copy of which is attached hereto, was published in The Franklin Press Environmental Management
Commission proposes to issue a
newspaper on the following dates: NPDES wastewater discharge
permit to the person(s) listed
below. Written comments
WILLOWBROOK PARK regarding the proposed permit
PUBLIC NOTICE will be accepted until 30 days
after the publish date of this
07/19/2023 notice. The Director of the NC
Division of Water Resources
(DWR) may hold a public hearing
And that the said newspaper in which such notice, paper, document or legal should there be a significant
advertisement was published, was at the time of each and every such degree of public interest. Please
mail comments and/or
publication, a newspaper meeting all the requirements and qualifications of information requests to DWR at
Section I-597 of the General Statues of North Carolina and was a qualified the above address. Interested
persons may visit the DWR at
newspaper within the meaning of the Section I-597 of the General Statues of 512 N. Salisbury Street, Raleigh,
NC to review information on file.
North Carolina. Additional information on NPDES
permits and this notice may be
found on our website:
C�k `,,ttt i t n�Uii hftp://deq.nc.gov/about/divisions/
^ 1water-resources/water-resources-
(�' �J �0 ```i
�p,%NE A4 permits/wastewater-
N �i� branch/npdes-wastewater/public-
fie,•'••••••• •'• FLL notices, or by calling (919) 707-
NQ%G 3601. The Willowbrook Run POA
Signature of person making affidavit _ Ry ; C has requested renewal of permit
%.* m _ NCO070394 for the Willowbrook
A Park WWTP ( 17 McClure Mill
2i '. IC
Rd, Franklin) in Macon County.
• • �. This permitted facility discharges
��� �O,y ••. •••• .• ��� treated domestic wastewater to
Little
"",e 00VNTy„NG��O°� Currently fecae col formt and total
residual chlorine are water quality
Sworn to and subscribed before me this 19th day of July, 2023 limited. This discharge may
affect future allocations in this
portion of Coweeta Creek.
41 - 07/19/2023 #770361
Notary Public
My Commission Expires:
Filed with: NCDEQ-DWR
Address: WATER QUALITY SECTION 1617 MAIL SERVICE CENTER RALEIGH NC 27699-1617
Total Amount Due: $72.41

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
SOUTHERN
ENVIRONMENTAL
NVRONMENTAL
LAW
CENTER
Via Email
Charles Weaver and Siying Chen
N.C. Dept. of Environmental Quality
Division of Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
48 Patton Avenue, Suite 304
Asheville, NC 28801
August 17, 2022
Telephone [phone]
Facsimile 828-258-2024
Re: Application of the trout waters temperature standard in draft NPDES Permit
Nos. NC0078697, NC0070394, NC0084441, and NC0023086.
Dear Mr. Weaver and Ms. Chen:
Please accept the following comments submitted on behalf of MountainTrue, North
Carolina Trout Unlimited State Council, North Carolina Wildlife Federation, 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 four recently noticed
draft National Pollutant Discharge Elimination System ("NPDES") permits: Draft Permit Nos.
NCO078697 (Six Oaks Complex WWTP), NCO070394 (Willowbrook Park WWTP),
NCO084441 (Smoky Mountain Country Club WWTP), and NCO023086 (Fontana Dam WWTP).
These permits would all authorize discharges into designated trout waters.' Proper application of
the trout waters temperature standard is critical to protecting trout populations in North Carolina.
Unfortunately, all four draft permits leave the affected populations at risk by failing to ensure
trout streams remain sufficiently cool.
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
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
1 See NPDES Draft Permit Nos. NCO078697 (Six Oaks Complex WWTP) (July 25, 2023), at 2 (noting discharge
into Green River, a Class B trout water and HQW in the Broad River Basin); NCO070394 (Willowbrook Park
WWTP) (July 11, 2023), at 2 (noting discharge into Coweeta Creek, a Class B trout water in the Little Tennessee
River Basin); NCO084441 (Smoky Mountain Country Club WWTP) (July 11, 2023) (noting discharge into Conleys
Creek, a Class C trout water in the Little Tennessee River Basin); and NCO023086 (Fontana Dam WWTP) (Aug. 8,
2023), at 2 (noting discharge into the Little Tennessee River, a Class C trout water)-
2 Trout Species of North Carolina, Fly Fishing NC (accessed Dec. 16, 2022), https://www flyfishingnc.com/trout-
species-of-north-carolina.
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

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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 placing additional thermal pressure on
water temperatures. By 2060, western North Carolina is predicted to see 10-20 more days each
year with air temperatures above 35 °C (95 °F), increasing the potential for water temperatures to
rise above 21.1 °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.
IL 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
2B.030 I (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 watersprovides that water
temperature is:
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
s S. Envtl. L. Ctr., Comments on North Carolina's Draft 2022 § 303(d) List (Feb. 28, 2022).
4 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.

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.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 parts —a 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 four 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 four 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 three cases (Willowbrook Park, Fontana Dam, and Six
Oaks) newly including in -stream monitoring requirements for temperature. We applaud DEQ
for taking notice of the importance of monitoring water temperature for the protection of trout
6 Fact Sheet for NPDES Permit No. NC0067318 (Jan. 13, 2023).
7 The third draft permit (for Smoky Mountain Country Club WWTP) continues to include temperature monitoring
standards imposed in prior permitting cycles.

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waters. That said, Willowbrook Park's draft permit (and prior permit) require daily monitoring of
effluent temperature,$ while Fontana Dam's, Six Oaks", and Smoky Mountain Country Club's
draft permits only require weekly effluent temperature monitoring.10 All four permits should
require daily effluent monitoring for temperature. But most importantly, the final documents
must include permit limits to prevent violations of water quality standards, including the trout
waters temperature standard.
The draft permit for the Smoky Mountain Country Club WWTP exemplifies why permit
limits for temperature are necessary. Smoky Mountain's application materials indicate an
estimated summer maximum effluent temperature of 27 °C, far exceeding the 20-degree
maximum set for trout waters." In fact, the discharge's average summer effluent temperature is
22.3 °C.12 These concerns are magnified by the draft permit's inclusion of provisional
authorization to double the facility's design flow of 60,000 gallons per day to 120,000 gallons
per day. 13 Similarly, Willowbrook Park's permit materials indicate an average summer
temperature of 19.9 °C and a maximum summer temperature of 25 °C.14 There is therefore a
substantial risk that both dischargers will violate both the delta and absolute temperature limits
applicable to discharges to 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, 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
protected by the 20 °C standard.15 The 2022 303(d) Integrated Report does not disclose which
8 See Draft NPDES Permit No. NCO070394 (July 11, 2023), at 3 (requiring "daily" monitoring frequency for
effluent testing and weekly monitoring of temperature upstream and downstream of the discharge).
9 Six Oak's permit application should be denied outright. This facility has not been constructed despite receiving an
Authorization to Construct in 1995. The permit application does not include information sufficient for DEQ to
comply with requirements under 15A N.C. Admin. Code 2H.0107, and whatever information was provided in 1995
is now stale. The applicant can apply for a new NPDES permit when they are prepared to move forward with their
project.
10 Draft NPDES Permit No. NCO084441, at 3; Draft NPDES Permit No. NC078697, at 3 (setting "weekly"
frequency for both effluent and in -stream temperature monitoring)
11 Renewal Application for NPDES Permit No. NCO084441 (Smoky Park Country Club WWTP) (Mar. 21, 2023), at
13.
12 Id.
" See Draft NPDES Permit No. NC0084441, at 2 (authorizing the permittee to "construct the necessary components
to expand total treatment capacity to 0.12 MGD" pending a construction permit from the agency).
14 Renewal Application for NPDES Permit No. NCO070394 (Willowbrook Park WWTP) (Mar. 20, 2023), at 13.
15 See supra note 3.
al

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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 four 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.
IV. 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. NC0078697, NC0070394, NC0084441, and NC0020386.
Please notify Henry Gargan at hgargannselcnc.org 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
hgargangselcnc.org
Patrick Hunter
Managing Attorney
Southern Environmental Law Center
5

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
Weaver, Charles
From: Xiao, Min
Sent: Tuesday, August 1, 2023 11:30 AM
To: Weaver, Charles
Subject: FW: [External] Willowbrook Run POA WWTP Issues
Attachments: Ridgetop Logo Final (1)jpg
Hi Charles,
You may recall the inquiry from Willowbrook Park WWTP (NC0070394) for a potential chlorine contact tank
replacement. They finally have determined that they won't pursue the project because it appears the existing concrete
tank is still functional after some repairments.
During the discussion, it was noted that the plant is permitted for 24,600 gpd but the actual average flow is only 1,200
gpd, and they have no plans to add new users in the future. In this case, during a permit renewal, will a plant downgrade
be considered to reflect the actual flow? By reducing the permitted flow, one benefit may be giving allocation to other
future dischargers or existing users who need expansions. Noticed this issue and just would like to let you know, trying
to see if this had come up previously as well.
Thanks,
Min
From: David Huskins <[e-mail]>
Sent: Tuesday, July 25, 2023 10:31 AM
To: Xiao, Min <[e-mail]>
Cc: Armeni, Lauren E <[e-mail]>; Boss, Daniel J <[e-mail]>; Matt Dees
<[e-mail]>; Environmentalinc <environmental [e-mail]>; Max Hopper <[e-mail]>
Subject: Re: [External] Willowbrook Run POA WWTP Issues
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning, Min.
See below:
• according to our certified operator, it is less than 1200 gpd influent, which is pumped from one
lift station
• there are no plan to add users in the future; the current footprint of users and available
property does not permit it
• all treatment units, including the contact/declbori nation tanks are sized to accommodate the
25K gpd capacity of the plant
• we have not experienced any operational dysfunctions due to sparse influent
On another note, on further investigation and counsel of our certified operator, we have determined
that the current concrete chlorination/dechlorination tanks we were proposing to replace are, in fact,
stable and have a longer -term life than we had anticipated. We think taking some maintenance and
repair measures for the respective tanks will remediate any issues we presently are concerned about:

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
• drain and clean both tanks
• patch to spec any spalling surfaces and concrete cracks
• apply to specification epoxy coatings to the interior of the tanks once cleaned and patched
• cover the tanks with a roof to help keep out leaves and airborne debris, as well as sun
We will work with our certified operator to make sure these repairs are in compliance with DEQ
standards. In short, we would not be proposing to change out the existing tanks for new concrete
tanks, or for an alternative solution. They will remain.
Thanks to all for working with us on this. We are working diligently to address the various issues.
Regards.
From: "Min Xiao" <Min.Xiaoadea.nc.aov>
To: "David Huskins" <davidCa-).ridgetopassociates.com>, "Lauren E Armeni"
<lauren.armeni(a)-deg.nc.gov>
Cc: "Daniel J Boss" <daniel.boss(a)deg.nc.gov>, "Matt Dees" <matt(a)-sefga.com>, "Environmentalinc"
<environmental inc(a)_aol.com>, "Max Hopper" <maxhhopper(O-)_gmail.com>
Sent: Monday, July 24, 2023 1:32:28 PM
Subject: RE: [External] Willowbrook Run POA WWTP Issues
David,
Thank you for the information, as that helps me understand the issues better. I will need to talk with the Expedited and
Compliance Unit as they handle permits for minor facilities.
I do have a few questions regarding the facility and hope that you could provide more information. What's the current
average daily flow for the facility? Is the facility anticipated to receive more flows in the near future? Are all the existing
treatment units sized based on the permitted 25k gpd? Any operational/compliance issues the facility currently has
because of the low influent received by the plant?
Thanks,
Min Xiao, PE
Environmental Engineer III
NPDES Industrial Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919-707-3644
min.xiao(a�decl.nc.clov (New Email Address)
512 North Salisbury St.
1617 Mail Service Center, Raleigh, NC, 27699-1617
From: David Huskins <[e-mail]>
Sent: Monday, July 24, 2023 1:00 PM
To: Xiao, Min <[e-mail]>; Armeni, Lauren E <[e-mail]>
Cc: Boss, Daniel J <daniel.boss@deg. nc.gov>; Matt Dees <[e-mail]>; Environmentalinc
<[e-mail]>; Max Hopper <[e-mail]>
Subject: [External] Willowbrook Run POA WWTP Issues

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi, DEQ Team!
Thank you so much for working with us at Willowbrook Run to address the many years of lack of
maintenance to the WWTP and lack of diligence in addressing the over the years continuing issues.
We are finally aggressively addressing those issues!
Thanks for patience.
On that note, we do feel we need to replace the concrete chlorination/dechlorination tanks; they
continue to leak for 35 years of spalling and deterioration. The bandaids continue, but we anticipate
this will be a continuing issue that we will be constantly addressing more fregquently going forward.
Obviously, technology has changed over 35 years. We anticipate their may be more suitable options
than replacing with concrete tanks. We are investigating.
The main question is, the current chlorination tanks (2) tanks are 1,000 gpd each. The plant is
permitted at 24,600 gpd, which is exponentially many times greater than what the POA will ever need.
The plant was side for a 72-unit complex, but only serves 16 users, who do not create any substantial
effluent. So, with replacement of the aforementioned tanks, if replacing with concrete, or an
acceptable alternative, would the replacement vessels require 1,000 gallons each? Certainly,
downsizing those tanks would be less expensive and, perhaps, make the system more efficient????
We need counsel on this, realizing that we will have our operator and DEQ at the table as we survey
the options and knowing that whatever we can do will need DEQ approval.
Regards and I will look to hear from you.
David P. Huskins, CEO
Ridgetop Management, Inc. d/b/a Ridgetop Associates
Post Office Box 182
Linville Falls, North Carolina 28647-0182
Mobile: [phone]
LAUID P. HUSKINS
BETTY R. HUSKINS
Piwffop
ASSOCIATES
"Instead of letting things happen to us, let's make things happen for us!"
Boyd Morris (deceased), President Emeritus, N.C. Restaurant Association
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
Weaver, Charles
From:
Armeni, Lauren E
Sent:
Tuesday, July 11, 2023 2:01 PM
To:
Weaver, Charles
Cc:
Armeni, Lauren E
Subject:
RE: DRAFT permit renewal for NCO070394
Hi Charles,
On the draft cover letter it says that the facility name was corrected, but I looked at the permit issued in 2018 and the
facility name was also "Willowbrook Park WWTP", which is also what they put in the permit renewal app.
For the permit components list, manual bar screen should be added and I would put secondary clarifier. Thanks!
Lauren Armeni
Environmental Specialist 11—Asheville Regional Office
Water Quality Regional Operations
Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
[e-mail]
DE Q:>
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Weaver, Charles <[e-mail]>
Sent: Monday, July 3, 2023 2:18 PM
To: Kinney, Maureen <Maureen.Kin [e-mail]>; Armeni, Lauren E <[e-mail]>
Subject: DRAFT permit renewal for NCO070394
This one will go to Notice on the 11th. Send me any comments as time permits.
Charles H. Weaver
Environmental Specialist II
Division of Water Resources
919-707-3616
charles.weaver(a deg.nc.gov
(mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617

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

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
NPDES Permit Number Facility Name
Modified Application Form 2A
�-1 J f Modified March 2021
Form NC Department of Environmental Quality v ity - Application for NPDES Permit to Discharge Wastewater
NPDES MINOR SEWAGE FACILITIES (Before completing this forth please read the instructions. Failure to follow,
the ershuc6pr� result in denial of the ication.
1.1 Facility name
address
City or town
or P.O. box)
:1'y"
1,.� ri '
Contact name (first and last) Title
tv
State ZIP code
S�
Phone number I Email address
Location address (street, route number, or other specific identif r u -f:2t
'� - ( (Yl ; 1 ( J ) ❑Same as mailing address
City or town State
Prr
ZIP code
1.2 Is this application for a facility that has yet to commence discharge?
❑ Yes 4 See instructions on data submission No
requirements for new dischargers.
1,3 Is applicant different from entity listed under Item 1.1 above?
❑ Yes
No 4 SKIP to Item 1.4.
Applicant name
Applicant address (street or P.O. box)
City or town State
ZIP code
Contact name (first and last) Title Phone number Email address
1.4 1 Its the applicant the facility's owner, operator, or both? (Check only one response.)
tl�J Owner ❑ Operator
❑ Both
1.5 To which entity should the NPDES permitting authority send correspondence? (Check only one response.)
❑ Facility ❑ Applicant Faciliy 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 EnvironmignW Permits
NPDES (discharges to surface RCRA (hazardous waste) ❑ UIC (underground injection
wat r)
t control)
PSD (air emissions) Nonattainment program (CAA) NESHAPs (CAA)
❑ Ocean dumping (MPRSA)
Dredge or fill (CWA Section
404)
❑ Other (specify)
Page 1
e

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
I I brwl( -
NPDES Permit Number
Facility Name
WTV
1.7 Provide the collection s stem information re uested below for the treatment works.
Cailectlon System Type
1i11i I,It``!M1
ri-�
<� N .R
prii Vq
i UGC`
indicate e
% separate sanitary sewer
% combined storm and
Own
T
sanitary sewer
❑
Own
❑
Unknown
❑
Own
% separate sanitary sewer
❑
Own
❑
% combined storm and sanitary sewer
❑
Own
Unknown
❑
Own
separate sanitary sewer
❑
Own
combined storm and sanitary sewer
❑
Own
❑
Unknown
❑
Own
% separate sanitary sewer
❑Own
% combined storm and sanitary sewer
❑
Own
❑
Unknown
❑
Own
Separate Sanitary Sewer Sys
Total percentage of each type of
sewer line in miles i v� 070
1.8 Is the treatment works located in Indian Country? 1
❑ Yes �No
1.9 Does the facility discharge to a receiving water that flows through Indian Country?
❑ Yes �No
1.10 Provide design and actual flow rates in the designated spaces.
Modified Application Form 2A
WOW March 2021
Status �, -
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
❑ Maintain
0�3iy U0 mgd
mgd 0 • vu t 1 mgd mgd
ats
mgd mgd r'1 �� I mgd
1.11 Provide -he total number of effluent discharge points to waters of the State of North Carolina by e.
tow, of Eftiuer�t Poinfs b 'Type
v.
.. Effluent Untreated Effluent Combined SewCotter `
Overflows Bypasses ��Y
i x terflovrs.
Page 2
0�3iy U0 mgd
mgd 0 • vu t 1 mgd mgd
ats
mgd mgd r'1 �� I mgd
1.11 Provide -he total number of effluent discharge points to waters of the State of North Carolina by e.
tow, of Eftiuer�t Poinfs b 'Type
v.
.. Effluent Untreated Effluent Combined SewCotter `
Overflows Bypasses ��Y
i x terflovrs.
Page 2
Page 2

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
NPDES Permit Number Facility Name Modified Application Form 2A
C Modified March 2021
mai nn 1 Nv I
¢-" 1.12 Does the POTW discharge wastewater to basins, ponds, or other surface impoundments that do not have outlets u
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 `able below.
r surface Im dment Locadort and D" Data
Average Daily Volume
Location
Discharged to Surface Continuous or intermittetd
I undment (check one)
gpd ❑ Continuous
❑ Intermittent
❑ Continuous
gpd ❑ Intermittent
❑ Continuous
gpd ❑ Intermittent
1.14 Is wastewater applied to land?
x
} V ❑ Yes No 4 SKIP to Item 1.16.
1.15 Provide the land a lication site and discharcle data r1eeluested below.
Land Site and Dischme Data
Locatkm size Average Daily volume Continuous or
Appried
check one
acres gpd ❑ Continuous
❑ Intermittent
acres gpd ❑ Continuous
❑ Intermittent
acres gpd ❑ Continuous
1.16 Is effluent transported to another facility for treatment prior to discharge? C Intermittent
❑ Yes R�" No 4 SKIP to Item 1.21.
1.17 Describe the means by which the effluent is transported (e.g., tank truck, i
P Pe)
1.18 Is the effluent transported by a party other than the applicant?
r ❑ Yes ❑ No + SKIP to Item 1.20.
Provide information on the trans orer below.
YEntity 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

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
IVrUES Permit Number LFa=ame
Modified Application Form 2A
NCOD 4 Mod fed March 2021
120 In the table below, indicate the name, address, contact information, NPDES umber, and average daily flow rate of the
s1 receiving facility.
;3- r Receivin Q8#a
Facility name
Mailing address (street or P.O. box)
City
y or town
State ZIP code
u
0
Contact name (first and last) Title
r
Phone number
i Email address
NPDES number of receiving facility (if any) ❑ None
Average daily flow rate mgd
1.21 Is the wastewater disposed of in a manner other than those already mentioned in Items 1.14 through 1.21 that do
not have outlets to waters of the State of North Carolina (e.g., underground percolation, underground injection)?
❑ Yes [� No 4 SKIP to Item 1.23.
1.22 Provide information in the table below on these other dis osal methodsmedoft
x,.
Location of Size of Annual Average
Qivasal 6b Disposal Site DMY Discharge Carttinuous or Irilm"dord 4
Volume (check one)
acres gpd ❑ Continuous
❑ Intermittent
acres ❑ Continuous
�M
gpd ❑ Intermittent
acres gpd ❑ Continuous
1.23 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.2113
2❑2.21 Int?rmittec
k all th
Corsult with your NPDES permitting authority to determine what information needs to be submitted and when.)at
nwhen.)at apply,
❑ Discharges into marine waters (CWA Water quality related effluent limitation (CWA Section
Section 301(h)) ❑ 302(b)(2))
y 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?
Ltd Yes
❑ No 4SKIP 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 res ponsibilities,
Cor►tractorinformauon
Contractor name C ractor2 G pr3
com an name
Mailing address t
street or P.O. box 1 y�"1
City, state, and ZIP
r code t 4
Contact name (first and
last
Phone number 17
�.- Email address
Operational and U�
maintenance C�rcecL 5
responsibilities of I
Page 4

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
Modified Application Forth 2A
Modified Marti 2021
2.1 1 Does the treatment works have a design flow greater than or equal to 0.1 mgd?
❑ Yes [� No + SKIP to Section 3.
2.2 Provide the treatment works' current average daily volume of inflow " " `%
and infiltration.
Indicate the steps the facility is taking to minimize inflow and infiltration. gPd
2.3 1 Have you attached a topographic map to this application that contains all the required information? (See instructions for
specific requirements.)
❑ Yes ❑ No
2.4 Have you attached a process flow diagram or schematic to this application that contains all the required information?
(See instructions for specific requirements.)
❑ Yes ❑ No
2.5 Are improvements to the facility scheduled?
❑ Yes ❑ No + SKIP to Section 3.
Briefly list and describe the scheduled improvements.
1.
2.
3.
4.
2.6 Provide scheduled or actua
SchWuiled
Improvement 0u
above)(list
nu;
1.
2.
3.
4.
2.7 Have appropriate permits/cle,
response.
❑ Yes
Explanation:
Of completion for
Begin
Construction
(1vf WDDJ'YYYY)
menu.
Co iedon for kn overnents
End n A# aittmbtit Of
Construction Disdwo O
(I ffi+UDD1YYYY) (Mkd/DO fYyyy)Level
s concerning other federalstate requirements been obtained? Briefly explain your
❑ No ❑ None required or applicable
Page 5

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
lL'�thnoit-
NPDES Permit Number Facility Name
—� r 1 I Modified Application Form 2A
't 1 ��1 y �'� t j ,� j Modified March 2021
3.1 Provide the following information for each outfall. (Attach additional sheets if you have more than three outfalls )
Outfall Number C CI Outfall Number Ouft Number
State
County
�^
City or town
Fran IL �tYl
Distance from shore
=
ft.
Depth below surface
ft. ft.
ft. ft. ft.
Average daily flow rate
mgd mgd
Latitude
35 o o mgd
Longitude
22
o
3.2 Do any of the outfails described under em 3.1 have seasonal or periodic discharges. ?
ElYes
m No 4 SKIP to Item 3.4.
3.3 If so, provide the following information for each applicable outfall,
t all plumber Oufti Nuimber
Number of times per year,
.
dischar e occurs
Average duration of each
dischar e s --; ,,nits
Average flow of each
dischar e
Months in which discharge
mgd mgd mgd
occurs
3.4 Are any of the outfalls listed under Item 3.1 equipped with a diffuser?
❑ Yes
V No 4 SKIP to Item 3.6.
3.5 Bner1 describe the diffuser t
eat each applicable cutfall.
lamer Outfatl Number NU,
3.6 Does the treatment works discharge or plan to discharge wastewater to waters of the State of North Carolina from
one or more discharge points?
❑ Yes ❑ No -SKIP to Section 6.
Page 6

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
IIJ
NPDES Permit Number Facility Name
\� yvTP
Modified Application Forth 2A
Modified March 2021
3.7 Provi a the receivin water and related information if known for each outfall.
Outtail Number
Outfall Number
n'{w
Receiving water nameQeirA
C'
Name of watershed, river,
4H e
or stream system
k
U.S. Soil Conservation
t
Service 14-digit watershed
c
code
Name of state
Lt
management/river basin
�CY`31
U.S. Geological Survey
8-digit
hydrologic
catalo in unit code
Critical low flow (acute)
cfs
cfs
cfs
Critical low flow (chronic)
cfs
cfs
cfs
Total hardness at critical
low flow
m /L of
mg/L of
mg/L of
3,8 CaCO3
Provide
CaCO3 CaCO3 the followtn mformation describin the treatment rovided for dischar es from each outfall
y
yNumber
Qutfall Number
OutW,Number
Highest Level of
Treatment (check all that
Primary
ClEquiv Equivalent to
❑
❑ Primary
zi
apply per outfall)
secondary
Equivalent to
seconds
❑ Equivalent to
❑ Secondary
❑ Seconds
Secondary
secondary
❑ Secondary
❑ Advanced
❑ Other (specify)
❑ Advanced
❑ Other (specify)
❑ Advanced
❑ Other (specify)
Design Removal Rates by
Outfall
BOD5 or CBOD5
%
%
TSS
{"h
Phosphorus
❑ Not applicable
❑ Not applicable
PP
❑ Not applicable
¢x
%
%
%
Nitrogen
❑ Not applicable
❑ Not applicable
❑ Not applicable
�.
Other (specify)
%
❑ Not applicable
%
O Not a licable
PP
%
El Not applicable
%
Page 7

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
VVi I inw hrLoL
NPDES Permit Number Facility Na�:MMjfied
—1 Application Form 2A
ACNIL ',, 'MOOiedMarch2021
3.9 Describe the type of disinfection used for the effluent from each outfalV li thelow. If disinfection v
season, describe below. ones by
OutW Number 1 kumbv
Disinfection type
� C 1t-I..YYl
Seasons used
`I Dechlorination used? RCLr ruin
❑ Not applicable ❑ Not applicable ❑ Not applicable
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?
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 /
LAY No 4 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
dischar es b outfall number or of the receivin water near the discharge points.
2 Outfall Number Ouft NumberWN`Number
Acute Chronic Acute Chronic
Acute Chx'oEtic '
Number of tests of discnarge
water
Number of tests of receiving
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?
tHaveYes -� Complete Table B, including chlorine.3.15ou completed monitoring for all applicable Table B pollutants d att c ed theNo 4 leesIts to te Table Bis app6ation, omitting orine.
e?
❑ 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?
1 ❑ Yes �/ No additional sampling required by NPOES
Page 8

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
i l I u/0 brcx.�
NPDES Permit Number Facility Name Modified Application Forth 2A
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 4 Complete tests and Table E and SKIP to
0 Have you previously submitted the results of the above tests to Item 3.26. 3.2your NPDES permitting g a
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 ermittin authorityand provide a summa of the results.
Summaty of Results
3.22 Regardless of how you provided your WET testing data to the NPDES permitting authority, did any of the tests result in
toxicity?
❑ Yes ❑ No 4 SKIP to Item 3.26,
3.23 Describe the cause(s) of the toxicity:
3.24 Has the treatment works conducted a toxicity reduction evaluation?
❑ Yes ❑ No 4 SKIP to Item 3.26,
3.25 Provide details of any toxicity reduction evaluations conducted.
3.26 1 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 oermittino authnrit
Page 9

DocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
NPDES Permit Number F it y Name Modified Appi caton Form 2A
©'� f Modified March 2021
j'�
SECTION• 1
41, 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 re uireclo provide attachments.
.. cdom2
Section 1: Basic Application
El w/ variance request(s) ❑ w;' additional attachments
Information for All Applicants
Section 2: Additional
❑ wl topographic map Eljv/process flew diagram
Information
❑3U additional attachments
wit Table A ❑ w/ Table D
Section 3: Information on
❑ w/ Table B ❑ wl additional attachments
Effluent Discharges
❑ wl Table C
m
Section 4: Not Applicable
c
t
Section 5 Not Applicable
i
U
j v
Section 6. Checklist and
wl attachments
Certification Statement
'fx .
B.2
Certification Statement
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 property 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. f am aware that there are significant penalties for submitting false information, including the possibiidy of fine
and imprisonment for knowing violations.
Name (print or type first and last name)
Official title
Max Hopper
chair Brd of Directors
Signature
Date signed
[--- .„ti.
fir (tem.r
3/15/2023
Page `0

IDocuSign Envelope ID: 010699BB-D8F6-47B1-948C-A920ABADF3B4
�'V I L u1 br
Permit Number Facility Name
Biemical oxygen demand
OD5 or ❑ CBOD5
rePqrt one
+
I L
Fecal coliform
lLZ mL
Ct
Design flow rate
`OU
M
PH (minimum)
SU
PH (maximum)
S Ll.
Temperature (winter)
I
O C
Temperature (summer)
5
Total suspended solids (TSS)
I
L
Sampling shall be conducted according to sufficiently sensitive tW procedures (i.e., methods) approve�c
required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
fial Number
Mod lied Application Form 2A
Modified March 2021
rf15?1❑Mj,
ate, t OADL
OMIL
UODIL
❑���
n1f7 ( t�IDL
0 CFR 136 for the analysis of pollutants or pollutant parameters or
Page 11