NC0032778_Draft Permit_20180124

Water Resources
Environmental Quality
January 24, 2018
Mr. Stephen Lamar Nix, Director Public Works
Town of Highlands
P O. Box 460
Highlands, NC 28741-2063
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Subject: Draft NPDES Permit NCO032778
Highlands WTP (PC -1)
Macon County
Dear Mr. Nix:
In response to your request to renew the subject NPDES permit, the Division of Water Resources (DWR or
the Division) hereby transmits this draft for your review and comment. Please review this document to assure
your understanding of the permit lmuts and monitoring conditions, and to correct errors, if any.
The Division understands that you have made no significant changes to your facility since the last permit
renewal. We have made the following updates to your previous permit
1. The facility map has been updated. Please note that the Outfall coordinates have been adjusted to
35°4'14"N, 83°13'3"W (35.0706° N, -83.2175° W).
2. Regulatory citations have been added.
3. Electronic reporting of discharge monitoring reports (eDMR) has been added in Section A. (4.)
4. The maximum, monthly average discharge for this facility is 0.199 MGD. Additionally, a design
backwash flow of 0.086 MGD was indicated on the application. In accordance with WTP permitting
strategy for conventional technology, for monthly average flows greater than 0 050 MGD, the
following monitoring requirements have been implemented:
a. Flow measurement has been changed to continuous recording. The Town will have 18
months from the effective date of this permit to install a continuous flow meter. Until then
instantaneous measurements can be taken with the duration of discharge to be noted in log
books and a total daily discharge reported on the DMR.
b. Total Nitrogen and Total Phosphorus have been added
5. Total Manganese and Total Iron monitoring have been removed because the EPA approved removal
of NC aquatic life standard as part of 2007-2016 Triennial review. Therefore, there are no limits to
compare monitoring data for these parameters.
6. The following Total Copper and Total Zinc limits have been applied for this permit renewal:
Parameter Outfall • Monthly Average Daily Maximum Limit
Total Copper 001 56.37 gg/L 63.35 µg/L
Total Zinc 001 760.4 gg/L 760.4 µg/L
Please note that Practical Quantitation Limits (PQL's) for Total Copper and Total Zinc should be 2
µg/L and 10 µg/L, respectively. NPDES Permit Standard Conditions Part II, Section D. (4.) requires the
following:
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and all
State of North Carolina I Environmental Quality
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707-9000

Mr. Nix
January 24, 2018
Page 2 of 2
data generated must be reported down to the minimum detection or lower reporting level of the
procedure. If no approved methods are determined capable of achieving minimum detection and
reporting levels below permit discharge requirements, then the most sensitive (method with the
lowest possible detection and reporting level) approved method must be used.
7. A compliance schedule has been added for the Total Copper and Total Zinc limits in Section A (2.)
8. Effluent and upstream quarterly monitoring for Total Hardness has been added. Please see discussion
below for more information. Effluent hardness sampling should be performed in conjunction with
sampling for hardness dependent metals (Copper, Zinc) (Footnote 4). The Permittee shall sample
instream hardness, upstream of the facility's discharge. The sample shall be representative of the
hardness in the receiving stream (Footnote 5).
9. Concurrent sampling with quarterly WET testing is no longer required for toxicants.
The NC 2007-2014 Water Quality Standard (WQS) Tnenmal Review was approved by the NC
Environmental Management Committee (EMC) on November 13, 2014. The US EPA subsequently approved
the WQS revisions on April 6, 2016 with some exceptions The NC Division of Water Resources NPDES
Permitting Unit is required to implement the new dissolved metal standards in all permits public noticed after
April 6, 2016
The new standards for most metals include acute standards Furthermore, the freshwater standards for several
metals are expressed as the dissolved form of the metals, and seven metals have hardness -dependent
equations. As a result, the NPDES Pzrmitting Unit will need site-specific effluent hardness data and instream
hardness data, upstream of the discharge, for each facility monitoring these metals in order to calculate permit
limitations Effluent hardness and instream hardness sampling, upstream of the discharge, has been added to
this pen -nit at a monitoring frequency of quarterly. See Section A (1.) Effluent Limitations and Monitoring
Requirements.
Concurrent with this notification, the Division will solicit public comment on this draft by publishing a notice
in newspapers having circulation in the general Macon County area, as required by the NPDES Program.
Please provide your comments, if any, to me via email [[e-mail]] or write to my attention
care of DEQ / DWR / NPDES Program no later than February 23, 2018. Your written comments are
welcome but not mandatory.
Following the mandatory 30 -day public comment period, the Division will review all pertinent comments on
your permit draft, and take appropriate action prior to issuing your NPDES permit final. If you have questions
concerning this draft, please e-mail me or call my direct line [phone].
Sincerely,
Derek Denard, Environmental Specialist
Compliance & Expedited Permitting Unit
Division of Water Resources, NCDEQ
Enclosure- NPDES Permit NC0032778 (renewal DRAFT)
he NPDES Program Files
ec DWR/ARO, Landon Davidson [Landon Davidson@ncdenr gov], Tim Heim [Tim Heim@ncdenr gov]
Wastewater Operator Certificaticn Group / Maureen Kinney [Maureen Kinney@ncdenr gov]
Aquatic Toxicology Branch / Susan Meadows [susan meadows@ncdenr gov], Cindy Moore [curdy moore@ncdenr gov]
DWR/PWS/ARO, Bill Conner [bill conner@ncdenr gov]
Jim Mull, Town of Highlands Dim mull@highlandsnc org]

NPDES Permit NCO032778
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
NPDES
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
Town of Highlands
is hereby authorized to discharge wastewater from a facility located at the
Highlands Water Treatment Plant (WTP)
440 Hickory Hill Road, Highlands 28741
Macon County
to receiving waters designated as Big Creek in the Little Tennessee River Basin, in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111 and IV
hereof.
This permit shall become effective 52018.
This permit and authorization to discharge shall expire at midnight on
Signed this day 12018.
Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 8

NPDES Permit NCO032778
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Town of Highlands
is hereby authorized to:
1. continue to operate a conventional technology water treatment plant [coagulation, flocculation,
sedimentation, and filtration] with discharge of wastewaters from media filter backwash and
sedimentation basins with a design potable flowrate of 2.0 MGD and a maximum, monthly average
wastewater discharge of 0.199 MGD, with wastewater treatment consisting of,
• decant tank for dechlorination and settling
• decant clear well
chemical usage consisting of
o alum / aluminum sulfate [coagulation & flocculation]
o zinc -orthophosphate [corrosion inhibitor]
o caustic soda [pH adjustment]
o sodium hypochlorite [disinfection]
o polymer (Polyacrylamide — Clanfloc® N -3300P) [coagulation & flocculation]
o polymer (Polyacrylamide — Superfloc N-3000 [coagulation & flocculation]
located at the Town of Highlands WTP, 440 Hickory Hill Road, Highlands, Macon County.
2. discharge from said treatment works, via Outfall 001, at the location specified on the attached map
into Big Creek [stream index 2-21-5-1-(4)], currently classified WS-I1;Tr,HQW,CA waters within
Subbasm 04-04-01 [HUC: 060102020201 ] of the Little Tennessee River Basin.
Page 2 of 8

NPDES Permit NCO032778
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge filter backwash from outfall 001. Such discharges shall be limited,
monitored and reported' by the Permittee as specified below:
EFFLUENT
CHARACTERISTIC
[PARAMETER CODES]
LIMITS
MONITORING REQUIREMENTS'
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow (MGD) 2
50050
Contmuous2
Recording 2
Effluent
Total Suspended Solids (mg/1)
C0530
30 0 mg/L
45 0 mg/L
2/Month
Grab
Effluent
PH (su)
00400
Not<6.0or>90
standard units
2/Month
Grab
Effluent
Turbidity (NTU)
00070
Monitor & Report
2/Month
Grab
Effluent
Total Residual Chlorine (µg/1) 3
50060
28 µg/1, 2
2/Month
Grab
Effluent
Hardness - Total as
[CaCO3 or (Ca + Mg)] (mg/1) 4
00900
Monitor & Report
Quarterly
Grab
Effluent
Hardness - Total as
[CaCO3 or (Ca + Mg)] (mg/1) 5
00900
Monitor & Report
Quarterly
Grab
Upstream
Total Copper (µg/1) 416
01042
56.37 µg/16
63 35 µg/16
Monthly
Grab
Effluent
Total Zinc (µg/1) 4,6
01092
760.4 µg/16
760 4 µg/16
Monthly
Grab
Effluent
Total Aluminum (µg/1)
01105
Quarterly
Grab
Effluent
Total Nitrogen (mg/1) 7
C0600
Monitor & Report
Quarterly
Grab
Effluent
Total Phosphorous (mg/1)
C0665
Monitor & Report
Quarterly
Grab
Effluent
Whole Effluent Toxicity 8
TGP3B
Monitor & Report
Quarterly
Grab
Effluent
Footnotes:
1. The Permittee shall begin submitting Discharge Monitoring Reports electronically using NC DWR's eDMR
application system See Condition A (4.).
2. The Town will have until , 18 months from the effective date of this permit, to install a continuous
flow meter. Until then instantaneous measurements can be taken with the duration of discharge to be noted
in log books and a total daily discharge reported on the DMR.
3. The Division shall consider all effluent TRC values reported below 50 gg/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.
4. Effluent hardness sampling should be performed in conjunction with sampling for hardness dependent
metals (Copper, Zinc).
5. The Pernnttee shall sample mstream hardness, upstream of the facility's discharge The sample shall be
representative of the hardness in the receiving stream.
Page 3 of 8

NPDES Permit NCO032778
6. Compliance with this limit shall commence on , approximately 48 months form the
permit effective date See Compliance Schedule Condition A. (2.)
7 For a given wastewater sample, TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total
Kjeldahl Nitrogen, and NO3-N and NO 2-N are Nitrate and Nitrite Nitrogen, respectively.
8. Chronic Whole Effluent Toxicity (WET) testing (Ceriodaphnia dubia) 7 -day chronic pass/fail test,
monitoring only, at 7% in March, June, September and December. See condition A. (3.).
Cond,tions-
• All samples collected should be from a representative discharge event.
• There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (2.) SCHEDULE OF COMPLIANCE (OUTFALL 001) [G.S. 143-215.1(b)]
1. Within one year from the effective day of the permit the Permittee shall submit to the Division of Water
Resources a Corrective Action Plan summarizing the actions to be taken to achieve compliance with the
total copper and total zinc limits at Outfall 001 and a schedule of activities to implement the Plan.
2. Within two years from the effective date of the permit submit a report to the Division summarizing actions
taken in accordance with the Corrective Action Plan.
3 Within three years from the effective date of the permit submit a report to the Division summarizing actions
taken in accordance with the Corrective Action Plan.
4 Within four years from the effective date of the permit submit a report to the Division summarizing actions
taken in accordance with the Corrective Action Plan.
5. Achieve compliance with total copper and total zinc limits specified in Sections A (1) by
(four years from effective date of permit).
Upon approval of the Corrective Action Plan by the Division, the report and actions become an enforceable part
of this permit. Any modifications to the schedule shall be requested to the Division at least ninety (90) days
before the deadline. Modifications to the schedule in excess of four months will be subject to public notice
Page 4 of 8

NPDES Permit NCO032778
A. (3.) CHRONIC TOXICITY PASS/FAIL MONITORING ONLY (QUARTERLY)
[15A NCAC 02B .0500 et seq.]
The permittee shall conduct quarterly chronic toxicity tests using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent
versions.
The effluent concentration defined as treatment two in the procedure document is 7%. The testing shall be
performed as a Ceriodaphnia dubia 7 -day pass/fail test. The tests will be performed during the months of
March, June, September and December. These months signify the,first month of each three month toxicity
testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative
effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR -1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DWR Form AT -1 (original) is to be sent tothefollowing address -
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology4Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed
in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and yeported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from thefacility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area,of the form. The report shall be submitted to the Water Sciences Section at the
address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly
monitoring will begin immediately. Upon submission of a valid test, this monthly test requirement will revert to
quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified
to include alternate monitoring requirements or limits.
NOTE Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, mimmum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
Page 5 of 8

NPDES Permit NCO032778
A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federzl regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part R of this permit
(Standard Conditions for NPDES Permits) -
• Section B. (11.) Signatory Requirements
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Reporting
Records Retention
Monitoring Reports
i
1. Reporting Requirements (Supersedes Section D. (2:
The permittee shall report discharge monitoring data'electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during lie 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,6DMR to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files i
1617 Mail Service Center
Raleigh; North Carolina 27699-1617'
If a permittee is unable to use the eDMR system due to"a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access, then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to
Request a Waiver from Electronic Reporting" section below.
Regardless of the submission' method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
Pretreatment Program Annual Reports; and
Clean Water Act (CWA) Section 316(b) Annual Reports.
The periruttee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver
from Electronic Reporting" section below).
Page 6 of 8

NPDES Permit NC0032778
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial
recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA
or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving
electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type
of electronic submission and for each state. Instructions on how to access and use the appropriate
electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting
Rule is found at: htti)://www2.el)a.gov/compliance/final-nationalTollutant-discharge-elimination-system-
Lipdes-electromc-reporting-rule.
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division.
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty (60) days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and
shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by
the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an
approved reporting waiver request may submit monitoring data and reports on paper to the Division for the
period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
http://deq nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements 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.
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://deq nc gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
Page 7 of 8

NPDES Permit NCO032778
"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 submlttingfalse information, including the possibility offines and imprisonment for knowing
violations "
5. Records Retention [Supplements Section D. (6.)1
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 8 of 8

1 7
'w+�t �. _, �...---••y ter, �.r.-.� � -. l
} �
' /
fes. } lr•�
Outfall 001
# [flows south] 't
Big Creek
[flows southwest]
4-
64
� f!
Approximate
Facility Boundary A, —,
Hicky Hill Rd
Big Creek Arm of
Lake Sequoyah,
Cullasaja River
Town of Highlands WTP
NPDES Permit NCO032778
440 Hickory Hill Road, Highlands 28741
Receiving Stream: Big Creek Stream Class: WS-II;Tr,HQW,CA
Stream Segment: 2-21-5-1-(4) Sub -Basin #: 04-04-01
River Basin: Little Tennessee HUC: 060102020201
N
SCALE
1:10 000
10
"0 1
35.07060 N,-83.21750 W
NC Grid: G6SW
USGS •Highlands,
County: Macon