NC0051322_Draft Permit_20171115

Water Resources
ENVIRONMENTAL QUALITY
November 15, 2017
Mr. Bryce Mendenhall, Vice President of Operations
Carolina Water Service, Inc. of North Carolina
P.O Box 240908
Charlotte, NC 28224-0908
Dear Permittee:
ROY COOPER
Gova na
MICHAEL S REGAN
Sea elary
S. JAY ZIMMERMAN
Direcloi
Subject: Draft NPDES Permit NCO051322
Ashley Hills WWTP
Wake County
Class WW -2
The Division has reviewed your request to renew the subject permit. Please review this draft
carefully to ensure your thorough understanding of the information, conditions, and
requirements it contains.
The draft permit includes the following significant changes from the existing permit:
➢ Section A. (7.) has been added to require electronic submission of effluent data.
Federal regulations require electronic submittal of all discharge monitoring
reports (DMRs).
➢ Regulatory citations have been added to the permit.
➢ Removed Post aeration tank and Flow measurement from treatment system equipment
list. Updated to two sludge tanks, not three, and update to 42,000 and 28,000 gallons
instead of 35, 42, 8s 45,000 gallons. Changed Tertiary sand filter to Tertiary
membrane filtration.
➢ Aquatic Toxicology testing language has been updated.
➢ An updated outfall map has been included.
With this notification, the Division will solicit public comment on this draft permit by
publishing a notice in newspapers having circulation in the general Wake County area, per
EPA requirements. Please provide your comments, if any, to me no later than 30 days
after receiving this draft permit.
Following the 30 -day public comment period, the Division will review all pertinent comments
and take appropriate action prior to issuing a final permit. If you have any questions
concerning this permit, please contact Emily Phillips at [phone].
Sincere ,
f 3
Emily Phillips
Compliance and Expedited Permitting Unit
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, NC 27699-1617
919 807 6300 919-807-6389 FAX
https•//deq nc gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/npdes-wastewater-permits

Permit NCO051322
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control
Act, as amended,
Carolina Water Service, Inc. of NC
is hereby authorized to discharge wastewater from a facility located at the
Ashley Hills WWTP
320 Woods Run, Knightdale
Wake County
to receiving waters designated as Poplar Creek in the Neuse River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III and IV hereof.
This permit shall become effective.
This permit and authorization to discharge shall expire at midnight on February 28,
2022.
Signed this day.
DRAFT
S. Jay Zimmerman, P.G.
Director, Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 12

Permit NCO051322
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Carolina Water Service, Inc. of NC is hereby authorized to:
1. Continue to operate an existing 0.250 MGD wastewater treatment system that includes
the following components:
➢ Influent pump station
➢ Bar Screen
➢ Splitter Box
➢ Surge Tank
➢ Diffused aeration basins - 125,000/75,000/50,000 gallon
➢ 3 - Clarifiers - 29,000/10,000/13,200 gallon
➢ Tertiary membrane filtration
➢ 2- Sludge Holding Tanks - 42,000/28,000 gallon
➢ UV Disinfection
The facility is located south of Knightdale at the Ashley Hills Subdivision (320 Woods
Run) in Wake County.
2. After receiving an Authorization to Construct from the Division, construct and operate a
0.495 MGD wastewater treatment system.
3. Discharge from said treatment works at the location specified on the attached map into
Poplar Creek, currently classified C -NSW waters in sub -basin 03-04-02 of the Neuse
River Basin.
Page 2 of 12

Permit NCO051322
Part I.
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS —
(0.25 MGD)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until
expansion above 0.25 MGD or expiration, the Permittee is authorized to discharge from
outfall 001. Such discharges shall be limited and monitored6 by the Permittee as specified
below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Daily
Measurement
Sample
Sample
Parameter Code
Average
Maximum
Frequency
Type
Location'
Total Monthly Flow
Monitor & Report
Monthly
Calculated
Influent or Effluent
82220
BOD, 5 -day (20°C) — Summer*
5 0 mg/L
7.5 mg/L
3/Week
Composite
Effluent
C0310
BOD, 5 -day (20°C) — Winter"
10 0 mg/L
15 0 mg/L
3Meek
Composite
Effluent
C0310
Flow
0 25 MGD
Continuous
Recording
Influent or Effluent
50050
Total Suspended Solids
30 0 mg/L
45 0 mg/L
3Meek
Composite
Effluent
C0530
NH3 as N — Summer*
2 4 mg/L
12.0 mg/L
3Meek
Composite
Effluent
C0610
NH3 as N — Winter*
g 7 mg/L
35 0 mg/L
3Meek
Composite
Effluent
C0610
Dissolved Oxygen
Daily Average > 5 0 mg/L
3/Week
Grab
Effluent
00300
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
3Meek
Grab
Effluent
31616
Total Residual Chlorine2
28 Ng/L
3/Week
Grab
Effluent
50060
Temperature (°C)
Daily
Grab
Effluent
00010
TKN
Monitor & Report (mg/L)
Weekly
Composite
Effluent
00625
NO2-N + NO3-N
Monitor & Report (mg/L)
Weekly
Composite
Effluent
00630
TN 3
Monitor & Report (mg/L)
2/Month
Composite
Effluent
C0600
TN Load 4 QM600
Monitor & Report (Ib/month)
Monthly
Calculated
Effluent
QY600
Monitor & Report (Ib/year)
Annually
Calculated
Effluent
Total Phosphorus 5
Monitor & Report (mg/L)
2/Month
Composite
Effluent
C0665
pH
Not < 6.0 nor > 9 0
00400
Standard Units
Meekly
Grab
Effluent
Dissolved Oxygen
Daily Average > 5 0 mg/L
3Meek
Grab
Upstream &
00300
1
1 Downstream
Temperature (°C)
3/Week
Grab
Upstream &
00010
Downstream
Page 3 of 12

Permit NCO051322
*Summer. Apnl 1 - October 31; *Winter. November 1 - March 31
Footnotes:
1. Upstream - at least 200 feet upstream from the outfall. Downstream - at NCSR 2049.
2. The TRC limit and monitoring requirements apply only if chlorine is used for disinfection The
Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the
permit. However, the Permittee shall continue to record and submit all values reported by a North
Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L.
3. For a given wastewater sample, TN = TKN + NO2-N + NO3-N, where TN is Total Nitrogen and TKN is
Total Kjeldahl Nitrogen.
4. TN Load is the mass load of Total Nitrogen discharged in a given period of time [see condition
A. (4)]. Compliance with this limit shall be determined in accordance with condition A. (5) and
A. (6).
5. The quarterly average for total phosphorus shall be the average of composite samples collected
during each calendar quarter (January -March, April -June, July -September, October -December).
6. The Permittee shall submit discharge monitoring reports electronically using the Division's eDMR
system [see A. (7.)]
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN
TRACE AMOUNTS.
Page 4 of 12

Permit NCO051322
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS —
(0.495 MGD)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning upon expansion above 0.25 MGD and lasting until
expiration, the Permittee is authorized to discharge from outfall 001. Such discharges
shall be limited and monitored6 by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly Daily
Measurement
Sample Type
Sample
Parameter Code
Average Maximum
Frequency
Location'
Flow
50050
0 495 MGD
Weekly
Instantaneous
Influent or Effluent
Total Monthly Flow
Monitor & Report
Monthly
Calculated
Influent or Effluent
82220
BOD, 5 -day (20°C) — Summer*
5 0 mg/L
7.5 mg/L
3Meek
Composite
Effluent
C0310
BOD, 5 -day (20°C) — Winter*
10.0 mg/L
15 0 mg/L
3Meek
Composite
Effluent
C0310
Total Suspended Solids
30 0 mg/L
45 0 mg/L
3/Week
Composite
Effluent
C0530
NH3 as N — Summer*
1.7 mg/L
8.5 mg/L
3/Week
Composite
Effluent
C0610
NH3 as N — Winter*
5 3 mg/L
26 mg/L
3Meek
Composite
Effluent
C0610
Dissolved Oxygen
Daily Average > 5 0 mg/L
3/Week
Grab
Effluent
00300
—
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
3Meek
Grab
Effluent
31616
Total Residual Chlorine
28 pg/L
3Meek
Grab
Effluent
50060
Temperature (°C)
Daily
Grab
Effluent
00010
TKN
Monitor & Report (mg/L)
Weekly
Composite
Effluent
00625
NO2-N + NO3-N
Monitor & Report (mg/L)
Weekly
Composite
Effluent _
00630
TN4
Monitor & Report (mg/L)
2/Month
Composite
Effluent
C0600
TN Load 4 QM600
Monitor & Report (Ib/month)
Monthly
Calculated
Effluent
QY600
5,055 Ib/year (annual load)
Annually
Calculated
Effluent
Total Phosphorus6
1.0 mg/L (Monthly Average)
Weekly
Composite
Effluent
C0665
pH
Not < 6 0 nor > 9.0
3/Week
Grab
Effluent
00400
Standard Units
Dissolved Oxygen
3/Week
Grab
Upstream &
00300
Downstream
Temperature (°C)
3Meek
Grab
Upstream &
00010
1
1 Downstream
*Summer Apnl 1 — October 31; *Winter. November 1 — March 31
Page 5 of 12

Permit NCO051322
Footnotes:
1. Upstream - at least 200 feet upstream from the outfall. Downstream - at NCSR 2049.
2. The TRC limit and monitoring requirements apply only if chlorine is used for disinfection. The
Division shall consider all effluent TRC values reported below 50 µg/ L to be in compliance with the
permit. However, the Permittee shall continue to record and submit all values reported by a North
Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L.
3. For a given wastewater sample, TN = TKN + NO2-N + NO3-N, where TN is Total Nitrogen and TKN is
Total Kjeldahl Nitrogen.
4. TN Load is the mass load of Total Nitrogen discharged in a given period of time [see condition
A. (4)]. Compliance with this limit shall be determined in accordance with condition A. (5) and
A. (6). Upon expansion the annual load limit will go into effect after January 1 of the following
year.
5. The quarterly average for total phosphorus shall be the average of composite samples collected
during each calendar quarter (January -March, April -June, July -September, October -December).
6. The Permittee shall submit discharge monitoring reports electronically using the Division's eDMR
system [see A. (7.)].
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IlV OTHER THAN
TRACE AMOUNTS.
A. (3.) REOPENER CLAUSE:
[G. S 143-215.1(b)]
The Division may reopen this permit to increase monitoring, add additional parameters of
concern, and/or implement additional limits should effluent data or surface water data
indicate potential impacts, or should further information on radiological components become
available.
A. (4.) CALCULATION OF TOTAL NITROGEN LOADS
[G.S 143-215.1(b)]
a. The Permittee shall calculate monthly and annual TN Loads as follows:
i. Monthly Total Nitrogen (TN) Load (pounds/month) = TN x TMF x 8.34
Where:
TN = average TN concentration (mg/L) of the composite samples collected
during the month
TMF = Total Monthly Flow of wastewater discharged during the month
(MG/month)
8.34 = conversion factor, from (mg/L x MG) to pounds
ii. Annual TN Load (pounds/year) = Sum of the 12 Monthly TN Loads for
the calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/L and
pounds/month) in the discharge monitoring report for that month and shall
Page,6 of 12

Permit NC0051322
report each year's annual results (pounds/year) in the December report for that
year.
A. (5.) ANNUAL LIMITS FOR TOTAL NITROGEN
[G.S 143-215.1(b)]
a. Total Nitrogen (TN) allocations and TN Load limits for NPDES dischargers in the
Neuse River basin are annual limits and are applied for the calendar year.
b. For any given calendar year, the Permittee shall be in compliance with the annual
TN Load limit in this Permit if:
i. the Permittee's annual TN Load is less than or equal to said limit, or
ii. the Permittee is a Co -Permittee Member of a compliance association.
c. The TN Load limit in this Permit (if any) may be modified as the result of allowable
changes in the Permittee's TN allocation.
i. Allowable changes include those resulting from purchase of TN allocation from
the Wetlands Restoration Fund; purchase, sale, trade, or lease of allocation
between the Permittee and other dischargers; regionalization; and other
transactions approved by the Division.
ii. The Permittee may request a modification of the TN Load limit in this Permit to
reflect allowable changes in its TN allocation. Upon receipt of timely and proper
application, the Division will modify the permit as appropriate and in
accordance with state and federal program requirements.
iii. Changes in TN limits become effective on January 1 of the year following permit
modification. The Division must receive application no later than August 31 for
changes proposed for the following calendar year.
iv. Application shall be sent to:
NCDEQ/DWQ/NPDES
Attn: Neuse River Basin Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
d. If the Permittee is a member and co -permittee of an approved compliance
association, its TN discharge during that year is governed by that association's
group NPDES permit and the TN limits therein.
i. The Permittee shall be considered a Co -Permittee Member for any given
calendar year in which it is identified as such in Appendix A of the
association's group NPDES permit.
ii. Association roster(s) and members' TN allocations will be updated annually and
in accordance with state and federal program requirements.
iii. If the Permittee intends to join or leave a compliance association, the Division
must be notified of the proposed action in accordance with the procedures
defined in the association's NPDES permit.
Page 7 of 12

Permit NCO051322
(1) Upon receipt of timely and proper notification, the Division will modify the
permit as appropriate and in accordance with state and federal program
requirements.
(2) Membership changes in a compliance association become effective on
January 1 of the year following modification of the association's permit.
e. The TN monitoring and reporting requirements in this Permit remain in effect until
expiration of this Permit and are not affected by the Permittee's membership in a
compliance association.
A. (6.) TOTAL NITROGEN ALLOCATIONS
[G.S 143-215.1(b)]
a. The following table lists the Total Nitrogen (TN) allocation(s) assigned to, acquired
by, or transferred to the Permittee in accordance with the Neuse River nutrient
management rule (T15A NCAC 02B .0234) and the status of each as of permit
issuance. For compliance purposes, this table does not supersede any TN limit(s)
established elsewhere in this permit or in the NPDES permit of a compliance
association of which the Permittee is a Co -Permittee Member.
Footnote:
(1) Transport Factor = 50%
i. Any addition, deletion, or modification of the listed allocation(s) (other than to correct
typographical errors) or any change to Active status of any of the listed allocations shall be
considered a major modification of this permit and shall be subject to the public review
process afforded such modifications under state and federal rules.
A. (7.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[NCGS 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and program reports. The final NPDES Electronic Reporting Rule was adopted and became
effective on December 21, 2015.
Page 8 of 12
ALLOCATION AMOUNT (1)
ALLOCATION
SOURCE
DATE
STATUS
TYPE
Estuary (Ib/yr)
Discharge
(Ib/yr)
Base
Assigned by Rule
12/7/97,
2,528
5,055
Active
(T1 5A NCAC 02B .0234)
4/1/03
TOTAL
2,528
5,055
Active
Footnote:
(1) Transport Factor = 50%
i. Any addition, deletion, or modification of the listed allocation(s) (other than to correct
typographical errors) or any change to Active status of any of the listed allocations shall be
considered a major modification of this permit and shall be subject to the public review
process afforded such modifications under state and federal rules.
A. (7.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[NCGS 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and program reports. The final NPDES Electronic Reporting Rule was adopted and became
effective on December 21, 2015.
Page 8 of 12

Permit NCO051322
NOTE: This special condition supplements or supersedes the following sections within Part
II of this permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (all
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each
month and submitted electronically using eDMR. The eDMR system allows permitted
facilities to enter monitoring data and submit DMRs electronically using the internet.
Until such time that the state's eDMR application is compliant with EPA's Cross -Media
Electronic Reporting Regulation (CROMERR), permittees will be required to submit all
discharge monitoring data to the state electronically using eDMR and will be required to
complete the eDMR submission by printing, signing, and submitting one signed original
and a copy of the computer printed eDMR to the following address:
NC DENR / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due
to the facility being physically located in an area where less than 10 percent of the
households have broadband access, then a temporary waiver from the NPDES electronic
reporting requirements may be granted and discharge monitoring data may be submitted
on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director.
Duplicate signed copies shall be submitted to the mailing address above. See "How to
Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the
month following the commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following
compliance monitonng data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
Pretreatment Program Annual Reports; and
Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to
Request a Waiver from Electronic Reporting" section below).
Page 9 of 12

Permit NCO051322
2. Electronic Submissions
In accordance with 40 CFR 122.41(l)(9), the permittee must identify the initial recipient
at the time of each electronic submission. The permittee should use the EPA's website
resources to identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means
the entity (EPA or the state authorized by EPA to implement the NPDES program) that is
the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting
tool for each type of electronic submission and for each state. Instructions on how to access
and use the appropriate electronic reporting tool will be available as well. Information on
EPA's NPDES Electronic Reporting Rule is found at:
https: / /www.federalregister.gov/ documents /2015 / 10 /22 /2015-24954 /national-pollutant-
discharge-elimination-system-np des-electronic-reportmg-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements"
section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To
obtain an electronic reporting waiver, a permittee must first submit an electronic
reporting waiver request to the Division. Requests for temporary electronic reporting
waivers must be submitted in writing to the Division for written approval at least sixty
(60) days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not
exceed 5 years and shall thereupon expire. At such time, monitoring data and reports
shall be submitted electronically to the Division unless the permittee re -applies for and is
granted a new temporary electronic reporting waiver by the Division. Approved electronic
reporting waivers are not transferrable. Only permittees with an approved reporting
waiver request may submit monitoring data and reports on paper to the Division for the
period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are
found on the following web page:
http: / / deg.nc. gov /about/ divisions /water -resources / edmr
4. Signatory Requirements jSupplements Section B. (11.) (b) and Supersedes Section B.
(11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person
described in Part II, Section B. (11.) (a) or by a duly authorized representative of that
person as described in Part II, Section B. (11.)(b). A person, and not a position, must be
delegated signatory authority for eDMR reporting purposes.
Page 10 of 12

Permit NC0051322
For eDMR submissions, the person signing and submitting the DMR must obtain an
eDMR user account and login credentials to access the eDMR system. For more
information on North Carolina's eDMR system, registering for eDMR and obtaining an
eDMR user account, please visit the following web page:
http://deg.nc.gov/about/­divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system
shall make the following certification [40 CFR 122.221. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and
imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years
from the date of the report. This period may be extended by request of the Director at
any time [40 CFR 122.41].
Page 11 of 12

FACT SHEET
EXPEDITED - PERMIT RENEWAL
NCO051322 — Class 2
Basic Information for Expedited Permit Renewals
Permit Writer/Date
Emily Phillips / NPDES / October 27, 2017
Permit Number - Class
NCO051322 — Class 2
Flow
0.250 MGD [2980 people]
Owner
Carolina Water Service, Inc. of NC
Facility Name
Ashley Hills WWTP
Type of Waste
100 % domestic
Basin Name/Sub-basin number
Neuse River Basin / 03-04-02
Receiving Stream
Poplar Creek [segment 27-35]
Stream Classification in Permit
C; NSW
Does permit need Daily Max NH3 limits?
No
Does permit need TRC limits/language?
No
Does permit have toxicity testing?
No
Does permit have Special Conditions?
No
Does permit have instream monitoring?
Yes, DO & Temperature
Is the stream impaired (on 303(d) list)?
No
Any obvious compliance concerns?
No
Any permit MODS since last permit?
No
Requests for Renewal
Received July 19, 2017
New expiration date
February 28, 2022
Changes to current permit?
Updated map, added eDMR language, & added regulatory
citations
Data Review -- Reviewed BIMS data from 2012 through present. A couple of enforcements for limit violations
and numerous violations for daily maximums of BOD and Fecal Coliform, which all proceeded to NOVs.