NC0090247_Fact Sheet (Final)_20240506

Fact Sheet
NPDES Permit No. NCO09O247
Permit Writer/Email Contact: Siying Chen, [e-mail]:
Date: May 6, 2024
Division/Branch: NC Division of Water Resources/NPDES Compliance & Expedited Permitting Unit
Permitting Action:
❑ Renewal
❑ Renewal with Expansion
❑x New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Henderson County / Clear Creek WWTP
Applicant Address:
1 Historic Courthouse Square, Ste 6, Hendersonville, NC 28792
Facility Address:
Near Fruitland Road, Hendersonville, NC 28792
(Outfall location: 35' 22' 32.1" N, 82' 24' 36.3" W)
Permitted Flow:
0.2 MGD
Facility Type/Waste:
Minor Municipal
Facility Class:
Grade II
Treatment Units:
Influent pump station
Bar screens
Flow equalization tank
Two (2) activated sludge trains
Two (2) secondary clarification tanks
Sludge holding tank
Chlorine contact basin
Tertiary disc filters
Pretreatment Program (Y/N)
N
County:
Henderson
Region
ARO
Page 1 of 10

Briefly describe the proposed permitting action and facility background:
Henderson County has applied for an NPDES permit for the proposed Clear Creek WWTP in April 2023.
The new sanitary sewer collection system will be composed of both gravity and pumped systems to serve
existing residential and commercial properties in the unincorporated community of Edneyville as well as
connecting three other nearby package plants (Western Justice Academy WWTP, Blacksmith Run
WWTP, and Camp Judaea WWTP) in Henderson County, NC. The new WWTP will be constructed on an
approximately 15-acre greenfield parcel (parcels to be further subdivided pending discussions with
property owner) at the confluence of Clear Creek and Laurel Branch. The WWTP site footprint will be
approximately 0.5 acres. The WWTP will be a "package" -type plant and have the capacity to treat 0.2
million gallons per day (MGD) maximum month flow (MMF). Originally, it is conceptually planned to
allow for future capacity expansions up to 0.5 MGD via installation of additional packaged treatment
units. The WWTP will include an influent pump station and screening, a flow equalization cell, two
conventional activated sludge treatment trains, two secondary clarifiers, a sludge holding tank, and
effluent disinfection via chlorine.
This project is partly funded by $12.7 Million ARPA grant funds, administered by the Division of Water
Infrastructure. According to the final ruling for Coronavirus State and Local Fiscal Recovery Funds
(SLFRF, which is defined by ARPA), all ARPA funds are exempt from NEPA. Since these APRA funds
are directed to be administered by the DEQ/Division of Water Infrastructure through the Wastewater
Reserve Fund as established under NC General Statute Chapter 195G, these funds are statutorily exempt
from SEPA per G.S. 113A-12(2)(h) and do not require preparation of an environmental document.
2. Receiving Waterbody Information
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 — Clear Creek
Stream Segment:
6-55-11-(5)
Stream Classification:
C
Drainage Area (mi2):
34.1
Summer 7Q 10 (cfs)
15.0
Winter 7Q 10 (cfs):
21.5
30Q2 (cfs):
28.3
Average Flow (cfs):
58
IWC (% effluent):
2.02% (summer); 1.42% (winter)
303(d) listed/parameter:
Yes — for Benthos
Subject to TMDL/parameter:
No
Basin/Sub-basin/HUC:
French Broad River Basin / 04-03-02 / 060101050302
USGS Topo Quad:
Fruitland
Clear Creek is listed by the Division as impaired for Benthos in the 2022 North Carolina 303 (d)
List.
Page 2 of 10

Clear Creek 6-55-11-[5Ja
13216 From Lewis Creek to Laurel Branch
PARAMETER
Benthos (Nar, AL, FW)
IRCATEGORY CRITERIASTATUS
1.8 FW Miles
REASON FOR RATING 303D YEAR
5=Fxceeding Criteria Fair, Poor or Severe Bioclassification 2010
Clear Creek = 6-55-11-15jh C 4.7 FW Miles
13374 From Laurel Branch to Mud Creek
PARAMETER IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW) 0 lxceeding Criteria lFair, Poor or Severe Bioclassification 2020
Past benthos samplings at Clear Creek indicated that the stream likely suffers from a
combination of agricultural nonpoint source runoff and point source dischargers. DWR's
Biological Assessment Branch also indicated that it is difficult to identify the specific cause of
the benthos impairment in Clear Creek due to the limited sampling data available, but the lack of
long-lived stoneflies was consistent with the pesticides impacts in the Mills River study.
3. Effluent Data Summary
New facility, no effluent data available.
4. Instream Data Summary
New facility, no instream data available, and no instream monitoring is required at this point.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): N
Name of Monitoring Coalition: N/A
5. Compliance Summary
New facility, no compliance history available.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): N/A
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): N/A
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
BOD5, TSS, 85% removal, pHLimits:
Draft Permit - Applied 40 CFR 133.102 US EPA secondary treatment standards for a domestic treatment
facility. Based on modeling results, the BOD limits will protect the instream DO standard.
Page 3 of 10

Final Permit after the Public Hearing— Adopted BOD5 limits from the Hendersonville WWTP permit
(NC0025534). After further review of permit history for the Hendersonville WWTP permit, it was found
that the current limits established in their permit were based on a QUAL2E model ran on Mud Creek and
Clear Creek. The limits for BOD5 were Water Quality -Based Effluent Limits, developed based on
protection of Dissolved Oxygen standards. In order to protect downstream water quality at both Clear
Creek and Mud Creek, Hendersonville's BOD5 limits were adopted in the Clear Creek WWTP permit.
The final limits are as follows:
Parameter
Parameter Code
Monthly Average
Weekly Average
Limits
Limits
BOD, 5-day, (20°C) 3 (mg/L)
(April 1 — October 31)
CO310
10.0 mg/L
15.0 mg/L
BOD, 5-day, (20°C) 3 (mg/L)
CO310
20.0 mg/L
30.0 mg/L
(November 1 — March 31)
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1(summer) and 1.8 mg/1(winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1(acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal:
NH3 Limits:
Draft Permit - In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution
considerations for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow
(chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow
(carcinogen, HH). Limitations for ammonia are based on protection of aquatic life utilizing an Ammonia
chronic criterion of 1.0 mg/L (summer) and 1.8 mg/L (winter). Additional information on how the
proposed facility would meet these requirements would be expected as part of the design review. This
would address instream ammonia aquatic life concerns at the new discharge for 0.5 MGD.
Final Permit after the Public Hearing — Adopted NH3 as N limits from the Hendersonville WWTP
permit (NC0025534). After further review of permit history for the Hendersonville WWTP permit, it was
found that the current limits established in their permit were based on a QUAL2E model ran on Mud
Creek and Clear Creek. The limits for Ammonia Nitrogen were Water Quality -Based Effluent Limits,
developed based on protection of Dissolved Oxygen standards. In order to protect downstream water
quality at both Clear Creek and Mud Creek, Hendersonville's NH3 as N limits were adopted in the Clear
Creek WWTP permit. The final limits are as follows:
Parameter
Parameter Code
Monthly Average
Weekly Average
Limits
Limits
Ammonia (NH3 as N) (mg/L)
C0610
2.0 mg/L
6.0 mg/L
(April 1— October 31)
Ammonia (NH3 as N) (mg/L)
CO610
4.0 mg/L
12.0 mg/L
(November 1 — March 31)
Page 4 of 10

TRC, Fecal Coliform Limits:
Applied 15A NCAC 02B .0211 water quality standards.
Reasonable Potential Analysis (RPA) for Toxicants
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of/z detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was not conducted since there's no effluent data available.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Minor POTW, a chronic WET pass/fail test on a
quarterly frequency is required in the permit.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit:
Semi-annual monitoring for TN and TP according to 15a NCAC 02b .0508.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: N/A
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: N/A
7. Technology -Based Effluent Limitations (TBELs)
Municipals if not applicable, delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/l
BODS/TSS for Monthly Average, and 45 mg/l for BODS/TSS for Weekly Average). YES
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). N/A
Are 85% removal requirements for BOD51TSS included in the permit? YES
If NO, provide a justification (e.g., waste stabilization pond). N/A
8. Antidegradation Review (New/Expanding Discharge)
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all
Page 5 of 10

cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results:
1. Determine if the proposed discharge will be allowed
Zero flow stream restrictions
USGS provided low flow characteristics for Clear Creek (summarized below), it is not subject to zero -
flow stream restrictions.
Low -Flow Discharge
7Q10
Range (cfs)
5.8-23.9
Average (cfs)
15
Median (cfs)
15.3
30QZ
13.3-44.3
28.3
26.3
W7Q10
8.5-44.3
21.5
19.4
702
10.6-40.9
25.9
24.2
Basinwide Water Quali , Plans
Clear Creek is part of the French Broad River Basin, according to the 2011 French Broad Basinwide
Water Quality Plan, portions of Clear Creek are listed as Impaired, with other portions listed as
Supporting, but it does not preclude the proposed discharge.
Impaired waters and TMDLs
In the 2022 North Carolina Integrated Report (303(d) list), Clear Creek was given an Assessment Criteria
status of "Exceeding Criteria" for benthos. Clear Creek is not subject to any total maximum daily load
(TMDL) restrictions other than the statewide Mercury TMDL.
Presence of Endangered Species
C1earWater Environmental Consultants is preparing the Environmental Assessment (EA) for both the
proposed WWTP location and the upstream proposed collection system conveyance improvements. U.S.
Fish and Wildlife Service provided a protected species list in the project area, which are summarized
below:
CommonName
eagle
Scientific Name
HeUaeetos leocacepholus
Federal Status
BGPA'
State Status
—
Bog turtle
Glyptemys muhlenbergii
Threatened (5/A) I
Threatened
Bunched arrowhead
Sogittaria fascicolato
Endangered
—
Gray bat
Myotis grisescens
Endangered
Endangered
Mountain heartleaf
Hexostylis con tracto
—
Endangered
Mountain sweet pitcherplant
Sarrocenia rubra ssp. Jonesd
Endangered
Endangered
Northern long-eared bat
Myotis septentrionolis
Endangered
Threatened
Small whorled pogonia
lsotrio medeoloides
Threatened
—
Swamp pink
Helonia bollato
Threatened
—
White irisette
Sisyrinchium dichotomum
Endangered
—
No designated critical habitat for any species has been found within the project area. Potentially suitable
habitat for bunched arrowhead was observed within the proposed project area, between tributaries along
Clear Creek. No suitable habitat for all other listed species was observed within the proposed project area.
Page 6 of 10

2. Provide reasonable projections for population and flow
Below is the projected population for Henderson County:
Edneyville is primarily a rural and agricultural community with scattered suburban developments.
Currently, most of the community is unsewered and relies on septic treatment systems for wastewater
handling and disposal. There is limited data on current wastewater flows within the entire sewer subbasin
that would contribute to the new WWTP. There are also three existing package WWTPs within the
service area and they will be abandoned after this new WWTP is established.
Based on the likely and possible contributors, the new Edneyville sewer collection system is anticipated
to collect up to 65,000 gpd upon initial activation, and the anticipated growth rate for this system is
expected to be approximately 2.54 percent (%) per year. Below is the Edneyville Sewer Collection
System Flow Projections and Peaking Factors:
3. Evaluate technologically feasible alternatives
The EAA explored different alternatives including connection to existing sewer systems and WWTPs,
land -based disposal application, wastewater reuse, and combination of different alternatives. Below is a
comparison summary of the different alternatives:
Page 7 of 10

Option
Hendersonville WWTP can accept flows; additional gravity sewer
Connection to WWTP
Y
needed to facilitate connection; higher cost than surface water
discharge.
Limited available land for purchase and at high cost. Large potential
Land -Based Disposal
YjN
agricultural user base, however, demand is not anticipated to be stable;
further coordination on nature of demands and quality requirements is
needed.
Wastewater Reuse
N
Not feasible because of cost, low customer base, and distance to
cuStOmers.
Surface Water discharge
Y
Preferred option; economically feasible.
Combination of land -based disposal and surface water discharge is
Combination
Y
feasible but would incur significant additional cost and include the
limitations noted above
4. Evaluate economic feasibility of alternatives
Below is the summary cost table for the different alternatives discussed:
Alternative A: Connections to Hendersonville WWTP
Alternative B, Option 1: County -owned land application
Alternative B, Option 2: Agrilcultural land application
Alternative C: Wastewater reuse
Alternative D: Direct discharge
In the EAA review, concerns were raised about the close cost estimates between direct discharge
(Alternative D) and connection to Hendersonville WWTP (Alternative A). The concern has been
addressed with CEPU management and ARO, and both have agreed to proceed with the direct discharge
option.
9. Antibacksliding Review
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): N/A
If YES, confirm that antibacksliding provisions are not violated: N/A
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
Page 8 of 10

considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
Semi-annual monitoring for TN and TP according to 15a NCAC 02b .0508.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2025, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
12. Summary of Proposed Permitting Actions (Draft)
Speculative limits were issued by DWR on August 5, 2022, which includes limits and monitoring
requirements for BOD5, ammonia nitrogen, DO, TSS, TRC, pH, fecal coliform TN, TP, and chronic
toxicity pass/fail test. Special conditions for annual instream assessment and notification of start-up were
also included.
13. Public Notice Schedule
Permit to Public Notice: 9/12/2023
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30-days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. Public Comments, Public Hearing, and Additional Information
Substantial public comments were received during the public comment period. After reviewing the public
comments received, the Director decided to hold a public hearing, and the public hearing was held on
February 5, 2024
Based on the public comments received during the two comment periods, it was determined that more
information is needed to make the appropriate permit decision. Consultation with the DWR's Biological
Assessment Branch found that although it would be difficult to identify the specific cause of the benthos
impairment in Clear Creek due to the limited sampling data available, the lack of long-lived stoneflies
was consistent with the pesticides impacts found in the Mills River study.
The speculative limits developed for Clear Creek WWTP were based on a Level B model and were
developed based on the review of receiving stream conditions in Clear Creek discharge only. Further
review of Hendersonville WWTP permit history reveals that the current limits established in the permit
are based on a QUAL2E model ran on Mud Creek and Clear Creek. The limits for BOD5 (BOD5 = 10.0
mg/L) and Ammonia Nitrogen (NH3 as N = 2.0 mg/L) were WQBEL developed based on protection of
DO standards. In order to ensure that the Clear Creek WWTP discharge would be protective of the
downstream water quality at both Clear Creek and Mud Creek, we requested the permittee to submit
additional information. The permittee was asked to either 1) perform a QUAL2K model for the proposed
discharge that also include downstream of the discharge point of Hendersonville WWTP, or 2) provide a
revised Present Value Cost Analysis in Engineering Alternative Analysis for the Direct Discharge option
to base effluent limits on BOD5 = 10.0 mg/L and NH3 as N = 2.0 mg/L. These limits were based on the
Page 9 of 10

effluent limits in the Hendersonville WWTP permit and would be protective of downstream water quality
at both Clear Creek and Mud Creek. The permittee decided to go with option 2 and provided an updated
PVCA, the result is summarized as follows:
Cost ($M)
Direct Discharge
Connection to Hendersonville WWTP
Capital
9.71
10.95
Recurring
0.13
0.14
Present Value
11.8
13.1
15. Summary of Proposed Permitting Actions (Final)
Based on the additional information received, more restrictive limits for BOD5 and Ammonia Nitrogen
are adopted to be in line with the effluent limits established in the Hendersonville WWTP permit. The
limits for BOD5 and Ammonia Nitrogen has been changed to the following:
Parameter
Parameter Code
Monthly Average
Weekly Average
Limits
Limits
BOD, 5-day, (20°C) 3 (mg/L)
(April 1 — October 31)
CO310
10.0 mg/L
15.0 mg/L
BOD, 5-day, (20°C) 3 (mg/L)
CO310
20.0 mg/L
30.0 mg/L
(November 1 — March 31)
Ammonia (NH3 as N) (mg/L)
CO610
2.0 mg/L
6.0 mg/L
(April 1 — October 31)
Ammonia (NH3 as N) (mg/L)
CO610
4.0 mg/L
12.0 mg/L
(November 1 — March 31)
After further review of the flow projection provided in the EAA, it is determined that only the 0.2 MGD
flow is justified, not the expansion up to 0.5 MGD. As a result, the 0.5 MGD flow phase has been
removed in the final permit, and so are any language and special conditions (Chronic Toxicity Pass/Fail
Monitoring) that were related to the 0.5 MGD flow phase. Only the 0.2 MGD flow is permitted in this
permit issuance.
In addition, Special Conditions have been updated in Section A.(4.) Notification of Start -Up to pursue
the connections of three other WWTPs: Western Justice Academy WWTP (NPDES Permit NC0086070),
Blacksmith Run WWTP (NPDES Permit NC0088056), and Camp Judaea WWTP (NPDES Permit
NC0033430).
16. NPDES Division Contact
If you have questions regarding any of the above information or on the attached permit, please contact
Siying Chen via email at [e-mail].
Page 10 of 10

LOCAL'1*0
PO Box 631697 Cincinnati, OH 45263-1697
StarNews I The Dispatch
Times -News
Public Notice
PROOF OF PUBLICATION
North Carolina Environmen-
tal Management Commis-
sion/NPDES Unit
1617 Mail Service Center
Wren Thedford
Raleigh, NC 27699-1617
Deq-Division Of Water Res
Notice of Intent to Issue a
1617 MAIL SERVICE CENTER
NPDES Wastewater Permit
NCO090247 Clear Creek
Raleigh NC 27699
WWTP The North Carolina
Environmental Management
Commission proposes to
issue a NPDES wastewater
STATE OF NORTH CAROLINA, COUNTY OF HENDERSON
discharge permit to the
person(s) listed below. Writ -
ten comments regarding the
The Hendersonville Times -News, a newspaper printed and
F
proposed permit will be
published in the city of Gastonia, and of general circulation in the
accepted until 30 days after
County of Henderson, State of North Carolina, and personal
the publish date of this
knowledge of the facts herein state and that the notice hereto
g
notice. The Director of the
NC Division of Water
annexed was Published in said newspapers in the issue dated:
Resources (DWR) may hold
a public hearing should there
09112/2023
be a significant degree of
public interest. Please mail
comments and/or informa-
and that the fees charged are legal.
tion requests to DWR at the
Sworn to and subscribed before on 09/12/2023
above address. Interested
persons may visit the DWR
at 512 N. Salisbury Street,
Raleigh, NC 27604 to review
the information on file. Addi-
tional information on NPDES
permits and this notice may
be found on our website:
https://deq.nc.gov/public-
notices-hearings,or by call-
ing [phone]. Henderson
County has applied for an
NPDES permit NCO090247 for
its Clear Creek WWTP
located near Fruitland Road
in Henderson County. This
permitted facility discharges
Legal Clerk
treated municipal waste-
water to Clear Creek in the
French Board River Basin.
Notary,State of I, Coff Brow
oun� ^CY y
Currently Total Residual
Chlorine, Dissolved Oxygen,
^
and Fecal Coliform are
water quality limited. This
My commision expires
discharge may affect future
allocations in this segment of
Publication Cost: $89.15
Cieur Creek.
9/12/23 9263597
Order No: 9263597 # of Copies:
Customer No: 512930 -1
PO #:
THIS IS NOT AN INVOICE!
Please do not use this,ionn for pa{i'ment remittance
D
ITLYNFELTYotary Publice Of Wisconsin
Page 1 of 1

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Henderson County
ATTN: Marcus Jones
1 Historic Courthouse Square, Ste 6
Hendersonville, NC 28792
Dear Mr. Jones:
\f QUhMNa j
NORTH CAROLINA
Environmental Quality
March 19, 2024
Subject: Request for Additional Information
Draft NPDES Permit NCO090247
Clear Creek WWTP
Henderson County
The Division has reviewed the public comments submitted for the subject draft NPDES permit
NCO090247 — Clear Creek WWTP. After looking closer at the modelling done on Mud Creek for
Hendersonville WWTP, we would like to request more information to ensure that the proposed discharge
would be protective of the downstream water quality. To enable us to complete our review in accordance
with N.C.G.S. 143-215.1 and 15A NCAC 2H.0105, please provide additional or revised information as
following:
1. Perform a QUAL2K model for the proposed discharge that also include downstream of the
discharge point of Hendersonville WWTP. The result should ensure that the proposed discharge
would be protective of both Clear Creek and Mud Creek downstream.
•'
2. Provide a revised Present Value Cost Analysis in Engineering Alternative Analysis for the Direct
Discharge option to base effluent limits on BOD5 = 10.0 mg/L and NH3 as N = 2.0 mg/L. These
limits are maintained at the same levels as the Hendersonville WWTP to ensure that it would be
protective of downstream water quality at Mud Creek as well.
Please submit the requested information within 30 calendar days of this letter to ensure the Division has
adequate time to review and reach a final decision on the draft permit. If you have any questions, please
contact me at 919-707-3619, or via e-mail at siyin .cg henkdeq.nc.gov.
Sincerely,
<;fJJ C6.",
Siying Chen
Environmental Specialist II
NPDES Compliance and Expedited Permitting Unit
ec: NPDES File [Laserfiche]
NC DEQ Division of Water Resources — Julie Gryzb
NC DEQ Division of Water Resources — Mike Montebello
NC DEQ Division of Water Resources — John Hennessy
CDM Smith — Anish Luthra [[e-mail]]
CDM Smith — Jonathan Lapsley [[e-mail]]
DEQ ,fJ North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA (J1(�.'�O'�.(�OQO
Department of Emlmnmenfal Duali�

Smith
April 151h, 2024
Mr. John Hennessy
North Carolina Department of Environmental Quality (NC DEQ)
Division of Water Resources
NPDES Permitting Program
512 N. Salisbury Street
Raleigh, NC 27604
Subject: Request for Additional Information
Draft NPDES Permit NC0090247
Clear Creek Wastewater Treatment Plant
Henderson County
Dear Mr. Hennessy:
This letter is being provided in response to the letter issued by the Division on March 19th, 2024 to
request additional information for the subject Draft NPDES Permit NC0090247 — Clear Creek
Wastewater Treatment Plant (WWTP). Henderson County has reviewed the request and elected to
provide a revised Present Value Cost Analysis from the Engineering Alternatives Analysis for the Direct
Discharge option to base effluent limits of BODS = 10.0 mg/L and NH3 as N = 2.0 mg/L. It should be
noted that the Clear Creek WWTP was already being designed for full nitrification as presented in the
subject permit's Engineering Alternatives Analysis due to the initially prescribed NH3 as N speculative
limit for the future flow conditions of 0.5 MGD. In order to meet the effluent limits noted in the above -
mentioned letter, the only unit process that would need to be added to the Clear Creek WWTP would be
tertiary filtration. No other unit process presented in the Engineering Alternatives Analysis would need
to be altered.
Attached to this letter is an updated Net Present Value Cost Analysis for the Connection to the City of
Hendersonville WWTP alternative and the Direct Surface Discharge alternative. Also attached, is the
capital cost buildup for both alternatives for reference. Below are the key assumptions that were made
in developing the updated Capital Costs and Net Present Value Cost Analyses. It should be noted that
the Capital Costs and Net Present Value Cost Analyses presented in the Engineering Alternatives Analysis
dated April 2023 were developed in 2022, for which reason the updated estimates are escalated over
two years in order to provide estimates in current 2024 dollars.
Connection to the City of Hendersonville WWTP Capital Cost Estimate Assumptions
1) All unit prices that were presented to the Division in the document titled EAA Capital Costs
Estimates (CDM Smith, 2022) in August 2023 were escalated 4% annually over two years.
Direct Surface Discharge Capital Cost Estimate Assumptions
1) Steel Tank Package WWTP item cost estimate was revised based on the updated cost proposals
provided by the package WWTP vendors in April 2024.
4600 Park Road Suite 240, Charlotte, NC 28209 1 tel: [phone]

Smith
Mr. Hennessy
April 151h, 2024
Page 2
2) Tertiary Disc Filter item cost estimate was developed based on cost proposals provided by disc
filter vendors in April 2024. Two disc filters units with associated backwashing pumping
equipment and instrumentation are being proposed to be operated in a duty/standby
configuration. Each disc filter unit is sized to treat the average day max month flow and
hydraulically pass the peak hourly flow.
3) Influent Pump Station item cost estimate that was presented to the Division in the document
titled EAA Capital Cost Estimates (CDM Smith, 2022) in August 2023 was escalated 4% annually
over two years.
4) Unit prices for Site Grading, Excavation and handling of spoils, Backfill, stone, compaction, and
Package Plant Concrete Slab that were presented to the Division in the document titled EAA
Capital Cost Estimates (CDM Smith, 2022) in August 2023 were escalated 4% annually over two
years. Quantities for these unit prices were increased to add the tertiary disc filter units.
Connection to the City of Hendersonville WWTP Net Present Value Cost Analysis Assumptions
1) Capital cost based on revised capital cost buildup for this alternative as described above. As
presented in the Engineering Alternatives Analysis, no capital cost assumed for infrastructure
improvements at the City of Hendersonville WWTP.
2) Recurring costs for 3rd Party O&M Contract and Maintenance and Repairs escalated two years at
4% annually. Recurring costs for Rate Surcharge remain unchanged.
3) Discount rate updated to 2.75% based on latest guidance from the Federal Register for discount
rates for water resource planning projects.
Direct Surface Water Discharge Net Present Value Cost Analysis Assumptions
1) Capital cost based on revised capital cost buildup for this alternative.
2) Recurring costs for 3rd Party O&M Contract and Chemicals and Utilities escalated two years at
4% annually. Recurring costs for Maintenance and Repair updated based on updated equipment
costs for the package WWTP and disc filter units.
3) Discount rate updated to 2.75% based on latest guidance from the Federal Register for discount
rates for water resource planning projects.
In conclusion, the updated Net Present Value Cost Analysis for the Connection to the City of
Hendersonville WWTP results in a 20-year lifecycle cost of $13.11M. The updated Net Present Value Cost
Analysis for the Direct Surface Water Discharge results in a 20-year lifecycle cost of $11.81M. Based on
these results, the recommendation of the Engineering Alternatives Analysis remains unchanged and
suggests that the Direct Surface Water Discharge alternative is the most financially viable option for
Henderson County.
4600 Park Road Suite 240, Charlotte, NC 28209 1 tel: [phone]

Smith
Mr. Hennessy
April 151h, 2024
Page 3
If you have any questions or require anything further, please do not hesitate to contact me at (704) 342-
4546 or at [e-mail].
Sincerely,
Jonat"I han Lapsley, P.E., P
Vice President
CDM Smith Inc.
cc: Marcus Jones, P.E., Henderson County
William Buie, P.E., WGLA Engineering, PLLC
Anish Luthra, P.E., PIMP, CDM Smith Inc.
Siying Chen, NC DEQ Division of Water Resources
Julie Gryzb, NC DEQ Division of Water Resources
Mike Montebello, NC DEQ Division of Water Resources
4600 Park Road Suite 240, Charlotte, NC 28209 1 tel: [phone]

EAA Capital Cost Buildup (Updated April 2024)
Connection to Hendersonville WWTP
Proposed Clear Creek WWTP
Item
Quantity Unit
Unit Price
Price
Item
Quantity Unit
Unit Price
Price
Clearing & Grubbing
10 ac
$
11,816
$
118,165
Steel Tank Package WWTP
1 LS
$
3,555,240
$
3,555,240
Erosion Control
1 LS
$
162,240
$
162,240
Tertiary Disc Filters
1 LS
$
777,775
$
777,775
24" Gravity Sewer
11000 LF
$
359
$
3,950,003
Influent Pump Station
1 LS
$
600,288
$
600,288
Dewatering
1 LS
$
270,400
$
270,400
Site Grading
331 cu yd
$
55.70
$
18,426
48" Steel Encasement Bored
80 LF
$
3,245
$
259,584
Excavation and handling of spoils
2924 cu yd
$
10.82
$
31,622
5' Diameter Manholes
40 Ea
$
8,653
$
346,112
Backfill, stone, compaction
1711 cu yd
$
118.98
$
203,612
Washed Stone Bedding
25000 TN
$
38
$
946,400
Package Plant Concrete Slab
428 cu yd
$
1,315.23
$
563,111
Sewer Services
1 LS
$
54,080
$
54,080
Incidental Stone
4000 TN
$
38
$
151,424
Stream Crossings
2 Ea
$
21,632
$
43,264
Seeding and Stabilization
10 ac
$
5,408
$
54,080
Equipment, Labor, Taxes Subtotal
$
6,355, 752
$
5,750,074
Mobilization (3%)
$
190,673
$
172,502
General Conditions (7.5%)
$
476,681
$
431,256
Bonds, Insurance, and Permitting (5%)
$
317,788
$
287,504
Contractor's OH&P (10%)
$
635,575
$
575,007
Project Subtotal
$
7,976,469
$
7,216,343
Contingency (15%)
$
1,196,470
$
1,082,451
Engineering (18%)
$
1,435,764
$
1,298,942
Permitting Costs
$
150,000
$
40,000
Easement Acquisition Cost
$
190,000
$
75,000
Total
$
10,948,800
$
9,712,800

Henderson County Wastewater Treatment Facility
Engineering Alternatives Analysis - Appendix C (April 2024 Update)
Connect to a Sewer Collection System
1. Capital Costs
A. Gravity Connection to City of Hendersonville Sewer
See CDM Smith Gravity Sewer for breakdown of capital costs.
Capital Cost:j $ 10,948,800.00
B. Upgrades to Hendersonville Wastewater Treatment Plant
No anticipated cost for any upgrades to the Hendersonville Wastewater Treatment Plant are expected. See Appendix B.
Capital Cost: 1 $ -
C. Total Capital Cost
Total Capital Cost: 1 $ 10,948,800.00
2. Recurring Costs
A. Operations and Maintenance Costs
O&M Costs have been calculated on a yearly basis for maintenance of the gravity pipeline.
Cost per Year
$ 33,746
$ 21,632
$ 80,000
$ 135,378
$ 135,378
3rd Party O&M Contract:
Chemicals and Utilities:
Maintenance and Repairs:
Rate Surcharge:
Subtotal:
Contingency:
Yearly O&M Cost:
B. Treatment Costs
The City of Hendersonville charges sewer customers based on meter size, customer type, and other various factors. Due to uncertainty
regarding individual account meters and type of customer, these costs are not evaluated herein. The County users would be required to pay
the "Outside City Limits" rates, which can be set up to 60% above the "Inside City Limits" rate.
C. Total Recurring Cost
Total Recurring Cost: 1 $ 135,400.00
3. Present Value Cost Analysis (PVCA):
-
L
J
Life of facility, n:
20.00
Discount rate, r:
2.750%
Capital Cost, Co:
$10,948,800
Recurring cost, C:
$135,400
P/A = ((1+r)^n - 1)/(r(1+r)^n)
15.23
PV = $10948800 + $135400*((1+2.250%)20 - 1)/(2.250%(1+2.250%)20)
PV = $10948800'15.23
= $13,100,000
4. Notes
1. Discount Rate - https://www.federalregister.gov/documents/2023/11/16/2023-25310/change-in-discount-rate-for-water-resources-planning

Henderson County Wastewater Treatment Facility
Engineering Alternatives Analysis - Appendix F (April 2024 Update)
Surface Water Discharge
1. Capital Costs
A. New Wastewater Treatment Facility
Plant Site and Equipment':
200,000 GPD WWTF: $ 8,695,766
Influent Pump Station: $ 1,016,971
Total Capital Cost: $ 9,712,800
2. Recurring Costs
A. Yearly Recurring Costs for Treatment Facility
3rd Party O&M Contract:
$ 50,619
Chemicals and Utilities:
$
25,958
Maintenance and Repairl
$
58,248
Rate Surcharge:
$
-
Subtotal:
$ 134,826
Contingency:
$
Total Recurring Cost: $ 134,900
3. Present Value Cost Analysis (PVCA):
Life of facility, n:
20.00
Discount rate 2, r:
2.750%
Capital Cost, Co:
$9,712,800
Recurring cost, C:
$134,900
P/A = ((1+r)An - 1)/(r(1+r)An)
15.23
PV = $9712800 + $134900`((1+2.250%)20 - 1)/(2.250%(1+2.250%)20)
PV = $9712800 + $134900*15.96
$11,800,000
4. Notes
1. Discount Rate https://www.federalregister.gov/documents/2023/11/16/2023-25310/change-in-discount-rate-for-water-resources-planning

From: Hennessy. ]oho
To: Grzvb. ]ulie; Montebello. Michael ]• Chen. Sivina
Subject: Fw: Discuss Clear Creek Impairment
Date: Wednesday, March 13, 2024 11:54:29 AM
Info for Mud Creek downstream of confluence with with Clear Creek. More of the same, including no stoneflies (Plecoptera).
From: Fleek, Eric <[e-mail]>
Sent: Wednesday, March 13, 2024 11:46 AM
To: Hennessy, John <john.hen [e-mail]>
Subject: RE: Discuss Clear Creek Impairment
We have two sites on Mud below the confluence with Clear: EB 309, EB 123.
Both sites are below the Hendersonville WWTP.
Specifically, EB309 is the closest to the WWTP, but EB 123 is also downstream (about 6.0 miles).
I am sure the Hendersonville (as well as the Mountain View WWTP) are not helping with the impaired conditions, not to mention Mud Creek runs right through Hendersonville
proper.
If you want something more than this, probably should go to 303d Guru and get up with Cam McNutt.
Benthic Communitv Table
Stream
MUD CR
MUD CR
MUD CR
MUD CR
MUD CR
MUD CR
MUD CR
MUD CR
MUD CR
Site Location
US 25
US 25
US 25
US 25
US 25
SR 1508 BE
HENDERSON
WWTP
SR 1508 BE
HENDERSON
WWTP
SR 1508 BE
HENDERSON
WWTP
SR 1508 BE
HENDERSON
WWTP
County
Henderson
Henderson
Henderson
Henderson
Henderson
Henderson
Henderson
Henderson
Henderson
Site ID
EB123
EB123
EB123
EB123
EB123
EB309
EB309
EB309
EB309
Collection date
9/9/1997
7/13/2000
8/15/2007
7/26/2012
8/28/2017
9/12/1985
7/7/1992
9/8/1997
7/12/2000
BAU sample number
7464
8178
10320
11420
12304
3679
5877
7459
8179
Sample method
Full Scale
Full Scale
Full Scale
Full Scale
Full Scale
Full Scale
EPT
Full Scale
Full Scale
Criteria
Summer/
Mountain
Summer/
Mountain
Summer/
Mountain
Summer/
Mountain
Summer/
Mountain
Summer/
Mountain
Summer/
Mountain
Summer/
Mountain
Summer/
Mountain
Richness
Ephemeroptera
7
3
6
9
5
2
4
4
8
Plcoptera
0
0
0
0
0
0
0
0
0
Trichoptera
5
7
10
12
4
1
3
4
4
Odonata
5
3
5
8
2
5
5
6
Megaloptera
2
2
0
1
0
0
2
2
Coleoptera
5
4
3
6
3
2
2
5
Chironomidae
16
21
24
7
13
10
16
14
non-Chironomidae Diptera
3
1 4
1 4
1 3
1 2
1 3
1
1 5
1 1
Oligochaeta
5
3
4
0
3
6
4
2
Molluscs
3
5
4
3
2
1
2
1
Othertaxa
3
5
7
6
2
1
3
3
Total taxa richness
54
57
67
55
36
31
47
46
Other biological metrics
Total EPT
12
10
16
21
9
3
7
8
12
Seasonal EPT
Corrected EPT
EPT abundance
54
50
80
114
51
5
36
32
65
EPT Biotic Index
5.71
5.77
5.01
4.69
5.57
7.24
6.51
5.78
5.61
NCBI
6.80
7.13
6.21
5.39
6.13
7.81
---
7.03
6.68
Seasonal Correction
Corrected NCBI
Bioclassifcation
Fair
Poor
Fair
Good -Fair
Fair
Poor
Poor
Poor
Fair
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From: Hennessy, John <[e-mail]>
Sent: Wednesday, March 13, 2024 11:08 AM
To: Fleek, Eric <[e-mail]>
Subject: Re: Discuss Clear Creek Impairment
What about on Mud Creek, below the confluence of Clear Creek & Mud Creek. That was the section Julie was asking about. Do you have any data on that strem reach
as to why it is on the 303d list?
From: Fleek, Eric <ericfleek(@c1ea.nc.gov>
Sent: Tuesday, March 12, 202410:31 AM
To: Hennessy, John <joh n. hen nessv(a]dea.nceov>
Subject: Re: Discuss Clear Creek Impairment

Ok, unfortunately our furthermost downstream location on Clear Creek is the previously mentioned site at SR 1513 ((Site ID: E1373).
Sorry I cannot be of more help.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Hennessy, John <joh n. hen nessv(@dea.nc.eov>
Sent: Monday, March 11, 2024 2:03 PM
To: Fleek, Eric <eric.fleek(@c1ea.nceov>
Subject: Re: Discuss Clear Creek Impairment
Thanks.
From: Fleek, Eric <eric.fleek(andea.nc.eov>
Sent: Monday, March 11, 20241:44 PM
To: Hennessy, John <john.hennessy(radea.ncTeov>
Subject: Re: Discuss Clear Creek Impairment
I will look into it.
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From: Hennessy, John <joh n. hen nessvPdea.nc.eov>
Sent: Monday, March 11, 202410:26 AM
To: Fleek, Eric <eric.fleek(@c1ea.nc.eov>
Subject: Re: Discuss Clear Creek Impairment
It is super critical, but (after talking to Julie), we don't think you need to do any additional instream work.
However, Julie has questions about the impairments downstream of the Hendersonville discharge in Hendersonville to Mud Creek (downstream of the clear cleek and
mud creek impairment). Do you have any data for that reach of stream? We are on a pretty short timeline and this is politically sensitive. If you could make it a
priority to look into that, I would greatly appreciate it.
From: Fleek, Eric <eric.fleek(adea.nceov>
Sent: Friday, March 1, 2024 11:50 AM
To: Hennessy, John <joh n. hen nessy(@dea.ncTeov>
Subject: Re: Discuss Clear Creek Impairment
If this is super critical I'd be willing to do a small, targeted study but (like the Mills) in order to nail down specific stressors (and their sources) that would require chemical sampling
assistance from the ARO.
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From: Hennessy, John <joh n. hen nessv(@dea.nc.eov>
Sent: Thursday, February 29, 2024 1:28 PM
To: Fleek, Eric <eric.fleek(ddeo.nceov>
Subject: Re: Discuss Clear Creek Impairment
Thanks Eric. I'll cancel our meeting. I really appreciate you help and hope all is going well.
Sent from my phone
On Feb 29, 2024, at 12:05 PM, Fleek, Eric <eric.fleekPdea.nc.gov> wrote:
In this instance, based just off the benthos data, and based off one discreet summer sample, I cannot say with precision what the specific cause of impairment is.
As is usually the case in a complicated catchment such as this, there are certainly multiple pollutants responsible.
That being said, the 2017 sample at SR 1513 did lack long-lived stonefly taxa and that is very consistent with the pesticide impacts we saw in the Mills study.
Speaking of that Mills River study, (which was multi -year, seasonal, and covered multiple sites) we did that in conjunction with the ARO and they did extensive
chemical sampling at all of our benthos sites and so we were able to specifically label a culprit (pesticides) in that case.
Since we do not have that intensive chemical data here, and there is no AMS site on Clear Creek that I can find, I can't just based on benthos make that call

unequivocally (although again, the lack of long-lived stoneflies certainly is highly suggestive of pesticides).
Cam McNutt may have access to other physical/chemical data that I do not so perhaps he can help you further.
For what it is worth, the ARO has asked us to resample that Clear Creek station (SR 1513) this summer.
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From: Hennessy, John <john.hen nessy(adea.ncTeov>
Sent: Thursday, February 29, 2024 11:27 AM
To: Fleek, Eric <eric.fleek(@cIeq.ncTeov>
Subject: Re: Discuss Clear Creek Impairment
It was good to a point. The question I have, and you may not know it, is the benthos impairment due to pesticides, sediment, or other discharges up stream.
I know your staff know the streams they survey and thought you might be privy to more information than was in the actual report.
John E. Hennessy
Regional Office Section Chief, Division of Water Resources
North Carolina Department of Environmental Quality Office: [phone]
iohn.hennessyladeo.ncTeov
<image001.png>
Email carrespandence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Fleek, Eric <eric.fleek(ddea.ncTeov>
Sent: Thursday, February 29, 2024 10:16 AM
To: Hennessy, John <john.hennessy(a)deq.nc.aov>
Subject: Re: Discuss Clear Creek Impairment
I assume my email summary on 2/23 didn't suffice?
If that's the case, I will attempt to call in on my cell.
However, I have nothing new to add over my previous email.
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From: Hennessy, John <john.hen nessyna dea.ncTeov>
Sent: Thursday, February 29, 2024 8:43 AM
To: Fleek, Eric <eric.fleek(@dea.ncTeov>; Chen, Siying <sjyine.chen0dea.ncTeov>
Subject: Discuss Clear Creek Impairment
When: Wednesday, March 6, 2024 1:00 PM-1:30 PM.
Where: Microsoft Teams Meeting
Eric, we need some help (if you have anything) with understanding the basis for the Clear Creek benthos impairment for an NPDES permit we are
dealing with.
Microsoft Teams meeting
Join on your computer, mobile app or room device
Click here to join the meetina
Meeting ID: 247 455 580 148
Passcode: gMgRCV
Download Teams I loin on the web
Join with a video conferencing device
ncQov(cam webex rum
Video Conference ID:118 691 317 2
Alternate VTC instructions
Or call in (audio only)
[phone]..737337620# United States, Raleigh
Phone Conference ID: 737 337 620#
Find a local number I Reset PIN

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From:
Hennessy, John
To:
Chen, Sivina
Subject:
Fw: Clear Creek
Date:
Monday, February 26, 2024 1:09:28 PM
Attachments:
Clear Creek.xlsx
Outlook-pez40u2 r. gno
John E. Hennessy
Regional Office Section Chief, Division of Water Resources
North Carolina Department of Environmental Quality Office: [phone]
[e-mail]
NORTH CARULINA
Department of EnvimnmeMal Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Fleek, Eric <[e-mail]>
Sent: Friday, February 23, 2024 2:12 PM
To: Hennessy, John <john.hen [e-mail]>
Subject: Clear Creek
Here are the details from the most recent sample at the basinsite:
NCDEQ-DWR :: Benthos Site Details (ncwater.org)
I've also attached all of our benthos data for Clear Creek above (from left to right, arranged
downstream to up).
Apologies if you've already seen this information..
One point of clarification from the write up: that 690 condo was measured near a pipe we found
during our collection and that pipe was associated with a package plant.
Here is what we sent to the ARO (Tim Fox) right after that sample and observation: "Hey Tim. Was
sampling Clear Creek, SR 1513 in Henderson, CO. Found a discharge pipe about 30' upstream of
bridge, on left bank (looking upstream). Specific conductance was 697. That seemed a bit high.
We found a small package plant as source. Managed by (1 think) something called James and
James Environmental. In any event, given that hot condo, thought y'all might want to know
about it".
From talking to Tim Fox, he says the ARO issued an NOV, but I have not heard anything more about it
than that (i.e., compliance status).
In addition to the small dischargers upstream, that catchment has tons of ag (apples and tomatoes)

and we have documented severe impacts associated with pesticide applications on tomato farms
(that specific study was on the Mills River, but it's a universal problem).
Hopefully, this answers your question, if not email me (NOTE: we are in the process of leaving this
BLDG, and as part of that process, I have no landline).
In other words, email is by far the best way to reach me.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may
be disclosed to third parties.
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.

North Carolina Department of Environmental Quality
Water Pollution Control System Operators Certification Commission
Roy Cooper W. Corey Basinger Elizabeth Biser
Governor Chairman Secretary
September 9, 2023
SENT VIA VIA EMAIL:
Mr. John Mitchell
County Manager
Henderson County
1 Historic Courthouse Square
Hendersonville, NC 28792
SUBJECT: CLASSIFICATION OF WATER POLLUTION CONTROL SYSTEM: WW-II
Clear Creek WWTP
Permit Number: NCO090247
Henderson County
Dear Mr. Mitchell,
In accordance with North Carolina General Statute § 90A-37, the Water Pollution Control System Operators
Certification Commission is required to classify all water pollution control systems.
Upon review of the subject draft permit, the Water Pollution Control System Operators Certification
Commission confirms that the subject facility is classified as follows:
Grade II Biological Water Pollution Control Treatment System (WW-II)
15A NCAC 08G .0302(b)
Please review the requirements set forth in 15A NCAC 8G .0202, and your permit.
If you have any questions concerning this classification or the designation of operators, please contact
me at 919-707-9038, or via email at [e-mail].
Sincerely,
Extension Education & Training Specialist
NC Operators Certification Program
ec: Natalie J. Berry, Cane Creek Water & Sewer District
Marcus Jones, Henderson County
Dan Boss, NC DEQ Asheville Regional Office, Water Quality Regional Operations
Chen Siying, NC DEQ NPDES Permitting
1618 Mail Service Center I Raleigh, North Carolina 27699-1618
919 707 9190 1 Fax [phone] http://deq.nc.gov/opcert

From:
Luthra, Anish
To:
Chen. Sivina
Cc:
Hennessy. John
Subject:
RE: [External] FW: Henderson County, DWI SRP-W-ARP-0085, Clear Creek Sewer System project
Date:
Thursday, July 27, 2023 7:48:45 AM
Attachments:
imaoe001.pna
imaae005.Dna
EAA Capital Cost Estimates.pdf
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.
Siying,
Please see responses to your questions below in red and attached capital cost estimate for the City of
Hendersonville Connection and Surface Water Discharge alternatives. Please let us know if you have any additional
questions.
Thanks,
Anish
From: Chen, Siying <[e-mail]>
Sent: Friday, July 21, 2023 12:11 PM
To: Luthra, Anish <[e-mail]>
Subject: RE: [External] FW: Henderson County, DWI SRP-W-ARP-0085, Clear Creek Sewer System project
Hi Anish,
The application was submitted to EAA review and we would like to request more information regarding the
connection to the Hendersonville WWTP alternative.
1. The cost estimated should only consider the cost of piping/pumps/resources necessary to connect to
the existing wastewater treatment plant, just want to double check with you and make sure the cost
evaluation provided is not considering other fees. For the purpose of the Engineering Alternatives
Analysis, it is assumed that a 24" gravity sewer line will convey flows to the location of the proposed
Clear Creek WWTP. The cost of this upstream gravity sewer is considered equal for all alternatives
within the Engineering Alternatives Analysis and is not considered in the cost estimate of any
alternative. For the alternative to connect to the Hendersonville WWTP, it is assumed that
approximately an additional 11,000 LF (-2 miles) of 24" gravity sewer will need to be installed from the
location of the proposed Clear Creek WWTP to a tie-in point on an existing 24" gravity interceptor that
currently conveys flows to the Hendersonville WWTP. Figure 3 in the Engineering Alternatives Analysis
shows the additional—11,000 LF of gravity sewer and tie-in point to the existing gravity interceptor. The
attached cost estimate breakdown only considers the cost associated with installation of the—11,000 LF
of new 24" gravity sewer. The City of Hendersonville noted that there would be no capital
improvements required to accept the Henderson County flows.
2. What's the distance between the proposed Clear Creek WWTP and the existing Hendersonville WWTP?
As noted above, Figure 3 shows the additional—11,000 LF of 24" gravity sewer that would need to be
installed from the location of the proposed Clear Creek WWTP to the tie-in point on the existing 24"
gravity interceptor that conveys flows to the City of Hendersonville WWTP. For reference only, the 'as
the crow flies' distance between the proposed Clear Creek WWTP location and the existing City of
Hendersonville WWTP is approximately 3.6 miles.
3. A breakdown for the cost analysis for connecting to Hendersonville WWTP and direct discharge would
be helpful, we would like to take a closer look and compare the budget for the two different options.

Please see attached cost capital cost buildup for the City of Hendersonville Connection and Proposed
Clear Creek WWTP alternatives. As described in further detail within Section 4 of the EAA, the capital
costs estimates are Class 4 cost estimates that are based on equipment and unit costs. Contractor and
other project multipliers are applied at the same percentages on both alternatives.
Thank you!
Siying (Sylvia) Chen (she/her/hers)
Environmental Specialist H, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
siying.chen(@deq.nc.gov
E
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: Luthra, Anish <luthraa(cDcdmsmith.com>
Sent: Friday, July 21, 2023 7:59 AM
To: Chen, Siying <ssiying.chen(@deq.nc.gov>
Subject: RE: [External] FW: Henderson County, DWI SRP-W-ARP-0085, Clear Creek Sewer System project
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 Siying,
Please see attached digital copy of the EAA. Due to file size, I will send a second email with the NPDES Permit
Application and associated figures.
Thanks,
Anish
From: Chen, Siying <siying.chen( deq.nc.gov>
Sent: Friday, July 21, 2023 6:48 AM
To: Luthra, Anish <luthraa(@cdmsmith.com>
Subject: RE: [External] FW: Henderson County, DWI SRP-W-ARP-0085, Clear Creek Sewer System project
Hi Anish,
I actually have a request for you, do you have a digital copy of the application, orjust the EAA report? I would like
to save a copy on our Laserfiche site, but I figure I should check with you first before I try to scan the whole binder,
in case you have a digital copy already.
Thanks!

Connection to Hendersonville WWTP
Proposed Clear Creek WWTP
Item
Quantity Unit
Unit Price
Price
Item
Quantity Unit
Unit Price
Price
Clearing & Grubbing
10 ac
$
10,925
$
109,250
Steel Tank Package WWTP
1 LS
$
3,502,164
$
3,502,164
Erosion Control
1 LS
$
150,000
$
150,000
Influent Pump Station
1 LS
$
555,000
$
555,000
24" Gravity Sewer
11000 LF
$
332
$
3,652,000
Site Grading
331 cu yd
$
51.50
$
17,036
Dewatering
1 LS
$
250,000
$
250,000
Excavation and handling of spoils
2379 cu yd
$
10.00
$
23,790
48" Steel Encasement Bored l
80 LF
$
3,000
$
240,000
Backfill, stone, compaction
1322 cu yd
$
110.00
$
145,383
5' Diameter Manholes
40 Ea
$
8,000
$
320,000
Package Plant Concrete Slab
344 cu yd
$
1,216.00
$
418,844
Washed Stone Bedding
25000 to
$
35
$
875,000
Sewer Services
1 LS
$
50,000
$
50,000
Incidental Stone
4000 TN
$
35
$
140,000
Stream Crossings
2 Ea
$
20,000
$
40,000
Seeding and Stabilization
10 ac
$
5,000
$
50,000
Equipment, Labor, Taxes Subtotal
$
5,876,250
$
4,662,217
Mobilization (3%)
$
176,288
$
139,867
General Conditions (7.5%)
$
440,719
$
349,666
Bonds, Insurance, and Permitting (5%)
$
293,813
$
233,111
Contractor's OH&P (10%)
$
587,625
$
466,222
Project Subtotal
$
7,374,694
$
5,851,082
Contingency (15%)
$
1,106,204
$
877,662
Engineering (18%)
$
1,327,445
$
1,053,195
Permitting Costs
$
150,000
$
25,000
Easement Acquisition Cost
$
190,000
$
75,000
Total
$
10,148,400
$
7,882,000

From: Pohlig, Ken <ken.pohligna deq.nc.gov>
Sent: Friday, May 26, 2023 3:55 PM
To: Eric Romaniszyn<eromaniszyn(d)enviroscienceinc.com>; Marcus Jones <mmones(@hendersoncountync.gov>;
Clement Riddle <clement(@cwenv.com>; Lapsley, Jonathan <LaosleyJS(@cdmsmith.com>; Luthra, Anish
<luthraa(@cdmsmith.com>
Cc: Davidson, Landon <landon.davidson(@deq.nc.gov>; Chen, Siying <siying.chen(@deq.nc.gov>; Hennessy, John
<iohn.hennessy(@deq.nc.gov>; Wainwright, David <david.wainwright(@deq.nc.gov>; Kluttz, Logan M
<Logan.Kluttz(@deq.nc.gov>; Desai, Trupti A <Trupti.Desai(@deq.nc.gov>; Evans, Tony V <tony.evans(@deq.nc.gov>;
Risgaard, Jon <ion.risgaardla deq.nc.gov>; Basinger, Corey <corey.basinger(a deq.nc.gov>
Subject: Henderson County, DWI SRP-W-ARP-0085, Clear Creek Sewer System project
IYou don't often get email from ken.pohlig aQdeq.nc.Qov. Learn why this is im op rtant
To: Marcus Jones, Henderson County
Eric Romaniszyn, Clement Riddle, ClearWater
Clement Riddle
Jonathan Lapsley, Anish Luthra, CDM Smith
cc: John Hennessy, Siying Chen, Division of Water Resources/NPDES Unit
David Wainwright, Division of Water Resources
Landon Davidson, Supervisor, Asheville Regional Office
This is a follow-up email to the Teams meeting we had this morning, where we discussed the Henderson County,
Clear Creek Sewer project.
This Henderson County project is partly funded by $12.7 Million ARPA grant funds, administered by the Division of
Water Infrastructure.
This project consists of a new WWTP in the Edneyville area of the County, and also a sewer collection system.
Recently, Henderson County submitted an NPDES Permit Application for this Edneyville area WWTP to the
DWR/NPDES Unit for review.
Regarding NEPA (National Environmental Policy Act): According to the final ruling for Coronavirus State and Local
Fiscal Recovery Funds (SLFRF, which is defined by ARPA), all ARPA funds are exempt from NEPA. See page 38 of
the attached document.
6.3. Does the National Environmental Policy Act (NEPAA apply to projects funded mith
SLFRF funds':
NEPA does not apply to Treasury's administration of the funds, including funds expended
under the revenue loss, public health and negative economic impacts, and water, sewer,
and broadband infrastructure eligible use categories. Projects supported with payments
from the funds may still be subject to NEPA review if they are also funded by other federal
financial assistance programs or have certain federal licensing or registration requirements.
Regarding SEPA (State Environmental Policy Act):
Regarding the $12.7 Million ARPA funds directed to this project by SL 2021-180, since these APRA funds are
directed to be administered by the DEQ/Division of Water Infrastructure through the Wastewater Reserve Fund as
established under NC General Statute Chapter 195G, these funds are statutorily exempt from SEPA per G.S.
113A-12(2)(h) and do not require preparation of an environmental document.
With regards to the rest of the funds to be used for this project, these funds may still be subject to the SEPA

requirements.
From this morning discussions between CDM Smith, Clear Water and the County, it appeared to be the case that
these activities would not trigger a SEPA review.
We and DWR encourage Henderson County to work with the appropriate funding agency (NC PRO office) to
determine whether these funds and/or construction activities still may trigger a SEPA review.
Let us know, and also DWR/NPDES Unit, regarding this final determination.
State Environmental Policy Act (SEPA) I NC DEQ
When Does SEPA Apply?
For any project that meets all three of the following criteria, an environmental document must he
prepared:
• An expenditure of S10 million in funds provided by the state of North Carolina foras! ngle project
or action or related group of projects or action
Or
land4sturbing activity of equal to or greater than 10 acres of public lands resulting in
substantial, permanent changes in the natural cover or topography of those (ands (or waters)
• An action by a state agency, and
• Has a potential detrimental environmental effect upon natural resources, public health and safety,
natural beauty, or historical or cultural elements, of the state's common inheritance.
Need help in determiningthe level of environmental impact or detrimental environmental effect? DEQ
has developed minimum criteria to identify those projects requiring an environmental document
{scroll to page 7).
Ken Pohlig, PE, Supervisor
Wastewater Projects Unit
Division of Water Infrastructure
Water Infrastructure I NC DEQ
Department of Environmental Quality
[phone] office
[phone] cellphone
ken. Dohlia aancdenr.aov
Mailing Address - 1633 Mail Service Center, Raleigh, North Carolina, 27699-1633
Street Address - 512 N. Salisbury St, Raleigh, North Carolina, 27604
-��---Nothing Compares --
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

DocuSign Envelope ID: 5B5AC59D-E985-4C6E-B372-635D77A1C450
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Marcus E. Jones, County Engineer
Henderson County Engineering
1 Historic Courthouse Square, Suite 6
Hendersonville, North Carolina 28792
Dear Mr. Jones:
NORTH CAROLINA
Environmental Quality
August 5, 2022
Subject: Speculative Effluent Limits
Edneyville/Clear Creek WWTP
NPDES Permit No. N/A
Henderson County
French Broad Basin
This letter provides speculative effluent limits for a new 0.2 MGD or 0.5 MGD WWTP in the
Edneyville/Clear Creek areas. The Division received the speculative limits request in a letter dated May 23,
2022, from Marcus A. Jones, PE., of Henderson County Engineering. Please recognize that speculative limits
may change based on future water quality initiatives, and it is recommended that the applicant review the
speculative limits with the Division's Municipal NPDES Unit when the NPDES permit application is
submitted.
Receiving Stream. Clear Creek is located within the French Broad River Basin. Clear Creek has a stream
classification of C, and waters with this classification have a best usage for aquatic life propagation and
maintenance of biological integrity, wildlife, secondary recreation and agriculture. The three potential WWTP
locations along Clear Creek have the following flows:
Site
DA
s7Q10
w7Q10
Average Flow
30Q2
Preferred Location #2
34.1 mil
15 cfs
21.5 cfs
58 cfs
28.3 cfs
Alternate Location #1
32.4 mil
14.3 cfs
20.4 cfs
55.1 cfs
26.9 cfs
Alternate Location #3
32.3 mil
14.2 cfs
20.3 cfs
54.9 cfs
26.7 cfs
This segment of Clear Creek is listed on the 2022 303(d) list as impaired for aquatic life based on `biological
integrity'. The sources of these impairments are undetermined, however non -point sources are typically a
significant contributing factor for biological impairment. Although the impairment does not preclude a new
discharge at this time, the Division would include the following condition in an issued NPDES permit:
"The Permittee shall submit a study plan to annually assess biological integrity in the receiving water via
benthic macroinvertebrate (benthos) sampling and analysis. The study plan shall include methodologies
consistent with DWR-approved assessment methodologies and propose an annual assessment schedule and
sampling location(s). Once approved, the studyplan shall be usedfor all subsequent assessments unless a study
plan modification is approved by the Division. Instream biological integrity assessments shall be conducted by
a laboratory or entity that is NC -certified for the procedure. "
Based upon a review of information available from the North Carolina Natural Heritage Program Online Map
Viewer, there are Federally Listed threatened or endangered species identified within a 5-mile radius of the
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CARCLINA
919.707.9000

DocuSign Envelope ID: 5B5AC59D-E985-4C6E-B372-635D77A1C450
proposed discharge location. If there are any identified threatened/endangered species, it is recommended that
the applicant discuss the proposed project with the US Fish and Wildlife Service to determine whether the
proposed discharge location might impact such species.
Speculative Effluent Limits. Based on Division review of receiving stream conditions and specific proposed
discharge locations, speculative limits for the proposed new 0.2MGD or 0.5 MGD WWTP are presented in
Tables 1-3. A complete evaluation of these limits and monitoring requirements for metals and other toxicants,
as well as potential instream monitoring requirements, will be addressed upon receipt of a complete NPDES
permit application.
Every applicant shall also submit documentation of any additional pollutants for which there are certified
methods with the permit application if their discharge is anticipated. These pollutants may be found in 40
CFR Part 136, if there are additional pollutants with certified methods to be reported, please submit the
Chemical Addendum to NPDES Application and, if applicable, list the selected certified analytical method
used.
Some features of the speculative limit development include the following:
NH3 Limits. In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution
considerations for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow
(chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow
(carcinogen, HH). Limitations for ammonia are based on protection of aquatic life utilizing an
Ammonia chronic criterion of 1.0 mg/1 (summer) and 1.8 mg/1 (winter). Additional information on
how the proposed facility would meet these requirements would be expected as part of the design
review. This would address instream ammonia aquatic life concerns at the new discharge for 0.5 MGD.
BOD5, TSS, 85% removal, pH Limits: Applied 40 CFR 133.102 US EPA secondary treatment
standards for a domestic treatment facility. Based on modeling results, the BOD limits will
protect the instream DO standard.
TRC, Fecal Coliform Limits: Applied 15A NCAC 02B .0211 water quality standards.
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly

DocuSign Envelope ID: 5B5AC59D-E985-4C6E-B372-635D77A1C450
TABLE 1. Speculative Limits for the proposed Edneyville/Clear Creek WWTP — Preferred Location
#2 (0.2 MGD and 0.5 MGD)
Effluent Limitations 0.2 MGD
Effluent Limitations 0.5 MGD
EFFLUENT
CHARACTERISTICS
Monthly
Weekly
Daily
Monthly
Weekly
Daily
Average
Average
Maximum
Average
Average
Maximum
Flow
0.2 MGD
0.5 MGD
BOD51
30.0 mg/L
1 45.0 mg/L
30.0 mg/L
45.0 mg/L
NH3 as N — Summer
Monitor & Report
16.1 mg/L
35.0 mg/L
NH3 as N - Winter
Monitor & Report
Monitor & Report
Dissolved Oxygen
(minimum)
Daily average > 5.0 mg/l
Daily average > 5.0 mg/l
TSS
30.0 mg/L
45.0 mg/L
30.0 mg/L
45.0 mg/L
TRC3
1 28.0 ug/L
1 28.0 ug/L
p H
Not less than 6.0 S.U. nor greater than
Not less than 6.0 S.U. nor greater than
9.0 S.U.
9.0 S.U.
Fecal coliform (geometric
200/100 mL
400/100 mL
200/100 mL
400/100 mL
7
mean)
Total Phosphorus
Monitor & Report
Monitor & Report
Total Nitrogen
Monitor & Report
Monitor & Report
Chronic Toxicity Pass/Fail
2 0%
4.9%
(Quarterly test)
Note:
1. The monthly average BOD5 and TSS concentration shall not exceed 15% of the respective
influent value (85% removal).
2. Summer: April 1 — October 31 Winter: November 1 — March 31
3. TRC is only applicable if chlorine or a chlorine derivative is used for disinfection.
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly

DocuSign Envelope ID: 5B5AC59D-E985-4C6E-B372-635D77A1C450
TABLE 2. Speculative Limits for the proposed Edneyville/Clear Creek WWTP — Alternate Location
#1 (0.2 MGD and 0.5 MGD)
Effluent Limitations 0.2 MGD
Effluent Limitations 0.5 MGD
EFFLUENT
CHARACTERISTICS
Monthly
Weekly
Daily
Monthly
Weekly
Daily
Average
Average
Maximum
Average
Average
Maximum
Flow
0.2 MGD
0.5 MGD
BOD51
30.0 mg/L
1 45.0 mg/L
30.0 mg/L
45.0 mg/L
NH3 as N — Summer
Monitor & Report
15.4 mg/L
3 5. 0 mg/L
NH3 as N - Winter
Monitor & Report
Monitor & Report
Dissolved Oxygen
(minimum)
Daily average > 5.0 mg/l
Daily average > 5.0 mg/l
TSS
30.0 mg/L
45.0 mg/L
30.0 mg/L
45.0 mg/L
TRC3
1 28.0 ug/L
1 28.0 ug/L
p H
Not less than 6.0 S.U. nor greater than
Not less than 6.0 S.U. nor greater than
9.0 S.U.
9.0 S.U.
Fecal coliform (geometric
200/100 mL
400/100 mL
200/100 mL
400/100 mL
mean
Total Phosphorus
Monitor & Report
Monitor & Report
Total Nitrogen
Monitor & Report
Monitor & Report
Chronic Toxicity Pass/Fail
2 1 %
5.1 %
(Quarterly test)
Note:
1. The monthly average BOD5 and TSS concentration shall not exceed 15% of the respective
influent value (85% removal).
2. Summer: April 1 — October 31 Winter: November 1 — March 31
3. TRC is only applicable if chlorine or a chlorine derivative is used for disinfection.
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly

DocuSign Envelope ID: 5B5AC59D-E985-4C6E-B372-635D77A1C450
TABLE 3. Speculative Limits for the proposed Edneyville/Clear Creek WWTP - Alternate Location
#3 (0.2 MGD and 0.5 MGD)
Effluent Limitations 0.2 MGD
Effluent Limitations 0.5 MGD
EFFLUENT
CHARACTERISTICS
Monthly
Weekly
Daily
Monthly
Weekly
Daily
Average
Average
Maximum
Average
Average
Maximum
Flow
0.2 MGD
0.5 MGD
BOD51
30.0 mg/L
45.0 mg/L
30.0 mg/L
45.0 mg/L
NH3 as N - Summer
Monitor & Report
15.3 mg/L
35.0 mg/L
NH3 as N - Winter2
Monitor & Report
Monitor & Report
Dissolved Oxygen
(minimum)
Daily average > 5.0 mg/1
Daily average > 5.0 mg/1
TSS
30.0 mg/L
45.0 mg/L
30.0 mg/L
45.0 mg/L
TRC3
1 28.0 ug/L
1 28.0 ug/L
p H
Not less than 6.0 S.U. nor greater than
Not less than 6.0 S.U. nor greater than
9.0 S.U.
9.0 S.U.
Fecal coliform (geometric
mean)
200/100 mL
400/100 mL
200/100 mL
400/100 mL
Total Phosphorus
Monitor & Report
Monitor & Report
Total Nitrogen
Monitor & Report
Monitor & Report
Chronic Toxicity Pass/Fail
2 1 %
5.2%
(Quarterly test)
Note:
1. The monthly average BOD5 and TSS concentration shall not exceed 15% of the respective influent
value (85% removal).
2. Summer: April 1 - October 31 Winter: November 1 - March 31
3. TRC is only applicable if chlorine or a chlorine derivative is used for disinfection.
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES permit
for a new or expanding discharge will be issued with these speculative limits for either 0.2 MGD or 0.5 MGD.
Final decisions can only be made after the Division receives and evaluates a formal permit application for the
expanded discharge.
In accordance with North Carolina Administrative Code 15A NCAC 2H.0105(c), the most environmentally
sound alternative should be selected from all reasonably cost-effective options. Therefore, as a component of
all NPDES permit applications for new and expanding flow includes a detailed engineering alternatives analysis
(EAA) that must be prepared. The EAA must justify the requested design flow and provide an analysis of
potential wastewater treatment alternatives. A copy of the Division guidance for preparing EAA documents is
attached.
In addition to the EAA, please review information available from the North Carolina Natural Heritage
Program Online Map Viewer. Please confirm if there are/are not any Federally Listed threatened or
endangered aquatic species identified within a 5-mile radius of the proposed discharge location. If there are
any identified threatened/endangered species, the applicant may consider reviewing the proposed project with
the US Fish and Wildlife Service to determine whether the proposed expanded discharge might impact such
species.
State Environmental Polices SEPA) EA/EIS Requirements. A SEPA EA/EIS document may be required
for projects that: 1) involve $10 Million or more of state funds; or 2) will significantly and permanently
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly

DocuSign Envelope ID: 5B5AC59D-E985-4C6E-B372-635D77A1C450
impact 10 or more acres of public lands. Please check with the DWR SEPA coordinator (David Wainwright,
919-707-9045) as to whether your project requires SEPA review. For projects that are subject to SEPA, the
EAA requirements discussed above will need to be folded into the SEPA document. If required, a FONSI
must be issued prior to issuance of the NPDES permit for the expansion.
We understand this project is moving forward rapidly; however we would expect that any request for NPDES
permitting action for the expansion be taken within a five-year period from the date of this letter, or the noted
speculative limits in Tables 1-3 would be subject to reassessment and review.
Should you have any questions about these speculative limits or NPDES permitting requirements, please feel
free to contact Kristin Litzenberger at [phone] / [e-mail] or Michael Montebello
at Michael.Montebello ci,ncdenr.gov.
Respectfully,
Do'c'fu,Si-gne'Id by, A A
C464531431644FE...
Michael Montebello
NPDES Program Branch Chief
Attachment: Link to EAA Guidance Document, Chemical Addendum Form, and NPDES application information:
https:Hdeg.nc. gov/about/divisions/water-resources/water-qualiiy_pemiitting/npdes-wastewater/npdes-permitting-process/npdes-
individual-permit-applications
ec: NPDES Files [Laserfiche]
Henderson County / Marcus E. Jones, County Engineer [[e-mail]]
CDM Smith / Anish Luthra [[e-mail]]
DWR / Julie Grzyb [e-mail]]; Michael J Montebello [[e-mail]]; Doug Dowden
[[e-mail]]; Derek Denard [[e-mail]]
ARO / Dan Boss [[e-mail]]
NC WRC / Maria Dunn [[e-mail]]
US Fish and Wildlife Service / Sarah McRae [sarah [e-mail]]
DWR/Basinwide Planning, Michelle Raquel [[e-mail]]
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly

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Fl Road Data; Natural Earth Data; U.S. Department of State Humanitarian Information Unit; and NOAA National Centers for Environmental Information, U.S. Coastal
ORelief Model. Data refreshed June, 2022.
N Legend Clear Creek WWTP
Proposed Gravity Sewer Henderson County, NC
Topographic Location Map 1 inch = 1,200 feet Figure 1
0 600 1,200 2,400
Feet CDM
Smith

CLEAR CREEK RD
CREEK R�
QO 24" GRAVITY
4P SEWER LINE
0
PROPOSED 12"
GRAVITY SEWER LINE
BLACKSMITH RUN \ /
WWTP/PROPOSED
PROPOSED PUMP STATION \ `
12" GRAVITY
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PROPOSED
V, 8" GRAVITY SEWER LINE
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S�ources:Esri, HERE, Garmin`Iriferrmap�incr'ernent P Corp., GEBCO, (USG- —,,FAO.) NPS,
NRCAN, GeoBasAe, IGN, Kadaster NL, Ordna `ce Survey, Esr)Japan, •M'ETI, Esri China -('Hong
p Kong), (c) Open StreetMap contributors, and=the GlS_User Community a
N Legend Figure 1 Henderson County, NC
Pr. Force Main Major Roads Parcel Map of Proposed Collection System Improvements
Pr. Gravity Sewer 0 Pr. Wastewater Treatment Plant CDM
Streams 0 Pr. Pump Station 0 2,300et
Smith
MILEYCO is\Mllev\ArcGIS\269598 2Z2510 ClearO \DATA\M F1.0 11 110- 11-30-l—A 1/31/2023

9
10,500 LF of Proposed
III Gravity Sewer
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Tie-in to Existing 24"
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H0
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N'
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NkKadasterNL—b6aanceSurvey, Esri_Japan, METI, Esri China (Hong Kong), (c)
ap-coo ntributors—and the G,.IS User.Community
N Legend Henderson County, NC
Existing Gravity Sewer Proposed Wastewater Treatment Plant Figure 3
Proposed Gravity Sewer C Parcel o izso CDM.
Streams ,
Feet Smith
MILEVCO C\Users\mllevco\OneDrive-CDM SmICF\Deskcoo\Clear Creek Sewer- We'— l.'- Academy\ III 12]251J Clear Creek EAA\Fleure l\Fleure 1.— e/1-22

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N Legend
WWTF Parcels
100-Year Floodplain
17) ® Floodway
Outfall Location
- - - - - - - - WWTP Footprint
(with Expansion)
�Y
Henderson County, NC
Figure 7
0 75 150 300
Feet CDM
1 inch = 300 feet Smith

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Figure No. 2
Clear Creek WWTP - Flow Diagram
FEB 2023

0—ET WEIR
BOX
4 BE
T BLET FEEDER
6-INCH
A
ow
O WIn
PUMPS
PLAN VIE'
ELEVATIOI` „
2._0"
L o
2'-0•
FLOW SPUTTER
BOX
z._°.
f
J 5'ML L LJ�I ill
FLOW CONTROL
BOX WITH BAR
SCREEN
DIMSFF
gIOP
DAS
cocR vuvE
mPPusm
I—E NR
gfFU5ER5
DIFFUSER DROP
CONCEPT PLAN FOR ENGINEERING 4'-0 }14'-0•—{
ALTERNATIVE ANALYSIS EMERGENCY BY—PASS BY 8" PIPES 4 HOUR RETENTION TIME PLUS 3 DISINFECTION I
VOLUME PROVIDED IN TANDEM DOUBLE CLARIFIER CLARIFIER V-
TYPE: DIMENSIONS 28' WIDE BY 24' LONG HOPPER STYLE CLARIFIERS CHLORINE CONTACT TANK CROSS-SECTION CROSS-SECTION
FIELD ERECT (TEAR DOWN): SLUDGE HOLDING WITH AERATION 27,450 GALLONS STORAGE PROVIDED 30 MINUTE CONTACT TIME AT
,4•-0' PER TRAIN AVERAGE DAILY FLOW, EXCEEDING
CONCEPT IS PROVIDE 100,000 GPD 58,000 GALLONS STORAGE WITH 30 TWO TRAINS PROVIDED VOLUME REQUIREMENT 15—MINUTE
TREATMENT TRAINS WITH 24—HOUR DAYS OF STORAGE CONTACT TIME AT PEAK FLOW
EXTENDED AERATION RETURN ACTIVATED SLUDGE / WASTE Vj�jj
Vj�
WITH DECANT SYSTEM ACTIVATED SLUDGE PIPING SYSTEM BY DIMENSIONS 28 FEET WIDE X 2 FEET 77B._5.
MINIMUM SCOPE PROVIDE 200,000 AIR-LIFT PUMPS LONG X 12'-4" TALL
7
AA=A GPD TREATMENT WITH ABILITY TO DIMENSIONS 28' X 22' LONG
EXPAND TO 500,000 GPD AS NEEDED INLET BAFFLE CONTROL ADDITIONAL FEATURES
24—HOUR HYDRAULIC RETENTION TIME CLARIFIER —SECTION
BY CONSTRUCTING 100,000 GPD EXTENDED AERATION CHAMBER WITH SURFACE LOADING RATE 255 GAL/SQ. ACCESS STAIR WITH LANDING HOT TYPICAL
TREATMENT TRAINS AERATION PROVIDED FT. AVERAGE DAILY FLOW DIPPED GALVANIZED
FLOW EQUALIZATION CHAMBER WITH 100,000 GALLONS PER TRAIN, TWO SURFACE LOADING RATE 447 GAL/SQ. COATING SYSTEM
AERATION PROVIDED TRAINS PROVIDED FT. AVERAGE DAILY FLOW
FOR A TOTAL OF 200,000 GALLONS SSPC—SP10 ALL INTERIOR SURFACES
SEWAGE CONTROL WITH AUTOMATIC OUTLET CONTROL SAW TOOTH WEIR SSPC—SP6 ALL EXTERIOR SURFACES
SCREENING, FLOW DISTRIBUTION AND DIMENSIONS PER TRAIN 14' WIDE BY PLATE
RECYCLE FLOW CONTROL TO AERATION 76'-6" LONG STRIPE COAT ON UNEVEN SURFACES.
CHAMBER DIMENSIONS PER TRAIN 14' WIDE X
CLARIFICATION 28' LONG X 16'-6" TALL TWO COAT SYSTEM TNEMEC N 8-12
63,000 GALLONS STORAGE FINAL DFT SOLID PIGMENTED COLORS
ONLY ON BOTH INTERIOR AND
EXTERIOR
Pro -Water
Systems, I nc
Process Equipment for Waste
Water Treatment
Pro -Water Model and Flow:
FH-200,000 GPD
Date:
October 17, 2022 1
Scale:
16" per foot
DRAWING:
Pro -Water Plant Serves:
HENDERSON CO
Pro -Water Plant Location:
EDNEYVILLE, NC
Pro -Water Representative:
GARRY HAGER
Dimensions:
A: AS SHOWN
B:
C:
D:
E:
H:
L:
M:
Q•
S:
Plant Length:
CONCEPT PLAN
FOR REVIEW ONLY
NOT FOR BIDDING OR
CONSTRUCTION
PAGE 1 OF 7 OVERALL

A 63 000 GALLON
FLOW EQUALIZATION
28 0"
14' - 0'
a
A
FLOW
EQUALIZATION
PUMPS
a
FLOW CONTROL
BOX DUALIZED
WITH RECYCLE
CT-200
SCREEN
24'-0"
58,000 GALLON
SLUDGE HOLDING
Pro -Water
Systems, I nc
Process Equipment for Waste
Water Treatment
a a
a a
Pro -Water Model and Flow:
FH-200,000 GPD
Date:
0
October 17, 2022
Scale:
4" per foot
WAS DRAWING:
Pro -Water Plant Serves:
HENDERSON CO
Pro -Water Plant Location:
o EDNEYVILLE, NC
___ ___ ___ _____ ________ Pro -Water Representative:
CARRY HAGER
Dimensions:
A: AS SHOWN
B:
0
C:
D:
E:
WAS H:
L:
M:
Q:
S:
Plant Length:
CONCEPT PLAN
FOR REVIEW ONLY
NOT FOR BIDDING OR
CONSTRUCTION
22'-0" --
PAGE 2 OF 7 PLAN 1

iz00000 GALLON
EXTENDED AERATION
a
WAS
WAS
RAS
RAS
RAS
4-INCH RAS
2-INCH SC
4-INCH RAS
11 2-INCH SC
Pro -Water
Systems, I nc
Process Equipment for Waste
Water Treatment
Pro -Water Model and Flow:
FH-200,000 GPD
Date:
TREATMENT TRAIN #2 October 17, 2022
Scale:
4" per foot
a a
a
2-INCH SC
4-INCH RAS
2-INCH SCMA
TREATMENT TRAIN #
a < a
76'-6"
DRAWING:
Pro -Water Plant Serves:
HENDERSON CO
Pro -Water Plant Location:
EDNEYVILLE, NC
Pro -Water Representative:
GARRY HAGER
Dimensions:
A: AS SHOWN
B:
C:
D:
E:
H:
L:
M:
Q:
S:
Plant Length:
CONCEPT PLAN
FOR REVIEW ONLY
NOT FOR BIDDING OR
CONSTRUCTION
152'-6"
PAGE 3 OF 7 PLAN 2

a
as
54 90 GALLON Pro -Water
C Kl F E R S Systems, I nc
6 —INCH process Equipment for Waste
OUTLET a PIPE
Water Treatment
a
Pro -Water Model and Flow:
BAFFLE FH-200,000 GPD
OUTLET WEIR Date:
B 0 X October 17, 2022
Scale:
4" per foot
DRAWING:
Pro -Water Plant Serves:
HENDERSON CO
Pro -Water Plant Location:
EDNEYVILLE, NC
---- ,- - - - - - ------ - - - -- - ---- - - --- FIPI TIN (I milli Pro -Water Representative:
-- --
CARRY HAGER
Dimensions:
A: AS SHOWN
B:
C:
BAFFLES D:
E:
0 0
a H:
L:
M:
4 TUBE Q:
TABLET FEEDER S:
O O Plant Length:
TROUGH 6—INCH CONCEPT PLAN
INSET
a a a FOR REVIEW ONLY
PIPE
NOT FOR BIDDING OR
CONSTRUCTION
289-099 29-099
PAGE 4 OF 7 PLAN 3

8-INCH 8-INCH WAS
14' — 0' Pro -Water
Systems, I nc
Process Equipment for Waste
Water Treatment
8—INCH
Pro -Water Model and Flow:
FH-200,000 GPD
I I I I I I I I I I I I
I I I I I I I I I I I I
I I I I I I I I I I I I
Date:
a a
October 17, 2022
:H: H: E :E[BE � I � H � �� � ��:
A FLOW CONTROL Scale:
BOX DUALIZED 4" per foot
WITH RECYCLE DRAWING:
FLOW 24 — 0 " 22 — 0 "
EQUALIZATION Pro -Water Plant Serves:
PUMPS HENDERSON CO
Pro -Water Plant Location:
I X VE V V EDNEYVILLE, NC
PLAN
BY-PASS Pro -Water Representative:
TURNDOWN
ELBOW GARRY HAGER
Dimensions:
;SCREEN A: AS SHOWN
B:
WASTE
C:
o�RFoww RECE ACL
------ --- D:
E:
-- 4„ H:
8" DRAIN --- EMERGENC
LINE c^e^� Y—PASS WA `_ L:
P AS
M:
Q:
3" DECA I', S:
ASSEMBL Plant Length:
CONCEPT PLAN
--- FOR REVIEW ONLY
NOT FOR BIDDING OR
__- CONSTRUCTION
a azi a a
E EEVAT 0 E V EW
PAGE 5 OF 7 ELEV 1

Z]
4" RAS /jo,
WAS
ASSEMBLY
W.L.
11 ■ 5i:
2" SCUM
LINE
TREATMENT TRAIN #1
a ° a
152'-6"
A
76'-6"
a
Pro -Water
Systems, I nc
-Process Equipment for Waste
Water Treatment
Pro -Water Model and Flow:
FH-200,000 GPD
-Date:
October 17, 2022
_Scale:
4" per foot
DRAWING:
Pro -Water Plant Serves:
HENDERSON CO
Pro -Water Plant Location:
EDNEYVILLE, NC
Pro -Water Representative:
GARRY HAGER
Dimensions:
A: AS SHOWN
B:
C:
D:
-E:
-H:
L:
M:
Q:
S:
Plant Length:
CONCEPT PLAN
FOR REVIEW ONLY
NOT FOR BIDDING OR
CONSTRUCTION
PAGE 6 OF 7 ELEV 2

a a
a
a
a
28'-09
a
Pro -Water
Systems, I nc
Process Equipment for Waste
4 TUBE Water Treatment
TABLET FEEDER
Pro -Water Model and Flow:
FH-200,000 GPD
TROUGH 1
45�6—INCH Date:
INLET October 17, 2022
PIPE
Scale:
4" per foot
DRAWING:
9 099
BAFFLE BAFFLE
/^\ 1 0 9 0 9 9
z
- z
zJ
z
o
9
N
10'-2"
12' — 4"
Pro -Water Plant Serves:
HENDERSON CO
Pro -Water Plant Location:
EDNEYVILLE, NC
Pro -Water Representative:
GARRY HAGER
Dimensions:
A: AS SHOWN
B:
C:
D:
E:
H:
L:
M:
Q:
S:
Plant Length:
CONCEPT PLAN
FOR REVIEW ONLY
NOT FOR BIDDING OR
CONSTRUCTION
PAGE 7 OF 7 ELEV 3

z
w
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Q� V)
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m
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130'-2"
14'-0" 60'-0" 9'-6" 41'-8"
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z_ o
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J 0
of
111,250 GALLON AERATION
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111,250 GALLON AERATION
0
rri
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52,352 GAL. 500 SF
MECHANICAL CLARIFIER
1000 GPD/SF AT PEAK
52,352 GAL. 500 SF
MECHANICAL CLARIFIER
1000 GPD/SF AT PEAK
ALKALINITY FEED SYSTEM
14 DAY BULK STORAGE
5'-0"
DUTY AND STANDBY PUMPS
ALUMINUM HANDRAILING
PRECAST POST TENSIONED CAP WALKWAY
PUMP SCHEDULE:
PRECAST POST TENSIONED WALL PANEL
TWO FLOW EQ SUBMERSIBLE RAIL
PUMPS,
CAST IN PLACE CONCRETE BASE
140 GPM ® 16' TDH,
1.0 HP
0)
I o
I
`0
TWO SLUDGE PUMPS,
SUBMERSIBLE
RAIL
1'-0" WALL THICKNESS
60 GPM @ 16' TDH,
0.5 HP.
j
BLOWER SCHEDULE:
'1
SECTION VIEW
PLANT BLOWERS
THREE URAI-56 & 20 HP. (TWO OPERATING, ONE STAND-BY)
322 CFM @ 8.5 PSI
FLOW EQ BLOWER
TWO URAI-56 & 20 HP. (ONE OPERATING AND ONE STAND-BY)
355 CFM @ 8 PSI
SLUDGE HOLDING BLOWERS
TWO URAI-45 & 10 HP. (ONE OPERATING AND ONE STAND-BY)
94 CFM © 8 PSI
o ro' _
Lu
Fzml -ia-Q
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cn = Q I o 0
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0 0 V)
o = Q
o 0 o
1 0.2 MGD WWTP- PRELIMINARY
CLEAR CREEK WASTEWATER TREATMENT PLANT
HENDERSON COUNTY, NORTH CAROLINA
DRAWN BY: ADM SCALE: NTS DRAWING NO.:
DATE: 10/18/22 1 REV: 1 1 /1 /22 XXXXX
MACK INDUSTRIES, INC.
201 COLUMBIA ROAD, VALLEY CITY, OHIO 44280 [phone]