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Home My WebLink AboutNC0089737_Request for Additional Information_20180112Water Resources ENVIRONMENTAL QUALITY January 12, 2018 CERTIFIED MAIL 7015 0640 0007 9833 5622 RETURN RECEIPT REQUESTED Ms. Summer Woodard Town of Franklin PO Box 1479 Franklin, NC 28744-1479 Dear Ms. Woodard: ROY COOPER Govei not MICHAEL S REGAN Secs elmy LINDA CULPEPPER Liles un Dnecloi Subject: Request for Additional Information NPDES Renewal Application Town of Franklin WTP NPDES permit NCO089737 Macon County The Division has reviewed your application, received on November 14, 2017, for a new NPDES permit NC0089737. To enable us to complete our review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 2H .0 105, we need additional or revised information regarding your discharge: 1. Please provide a more detailed solids handling plan. Per Item #15 of Short Form C — WTP, a solids handling plan is required with every application. Information provided with the current application is incomplete. 2. The schematic provided with the application should show the proposed sampling point, the outfall, and the flow of the discharge through the property all the way to the discharge point. The information currently provided does not include the proposed sampling point. 3. Per Item #16 of the application, all new applicants are required to provide analyses of the source water collected. This information was not submitted with the application. All results for all samples tested should be submitted to the Division for review. 4. Please provide five (5) days of Total Hardness (CaCO3 or [Ca + Mg]) data for the water treatment plant effluent and upstream from Outfall 001 to Cartoogechaye Creek. The NC 2007-2014 Water Quality Standard (WQS) Triennial 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. State of North Carolina I Environmental Quality I Water Resources 1617 Mail service Center I Raleigh, North Carolina 27699-1617 919 807 6300 Ms. Summer Woodard January 12, 2018 The new standards for most metals include acute standards. Further, 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 Permitting 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. Additionally, more information is required of the Engineering Alternatives Analysis (EAA). The EAA submitted to the Division is incomplete. 5. Step 1 of the EAA, whether the discharge is allowed, is not evaluated. In order to determine if the facility is subject to zero flow restrictions, additional information is needed. If possible, please provide a 7Q10, 30Q2, and Qaverage at the location of Outfall 001, located at Latitude: 35° 09' 44" N, Longitude: 83° 26' 13" W (per the application), by contacting the following staff member with the US Geological Survey: J. Curtis Weaver, Hydrologist, PE USGS North Carolina Water Science Center 3916 Sunset Ridge Road Raleigh, NC 27607 Phone: (919) 571-4043 // Fax: (919) 571-4041 E-mail address -- jcweaver(a,usgs.gov Internet address -- http://nc.water.usgs.gov/ 6. Step 1 of the EAA requires that the receiving stream classification, Basinwide water quality plan, and 303(d) listing for impairment be evaluated. This information is not included in the submitted EAA. 7. Step 1 of the EAA requires that endangered species be evaluated. This information is not included in the submitted EAA. 8. Step 2 of the EAA requires that projections for population be evaluated. This information is not included in the submitted EAA. 9. Step 2 of the EAA requires that protections for flow be evaluated. More information concerning this is needed. Please see Step 2 of the EAA for all information required. 10. Step 3 of the EAA requires alternatives be evaluated. The alternatives required by the EAA to be evaluated are connecting to an existing WWTP (Alternative A), land application (Alternative B), reuse (Alternative C), and direct discharge (Alternative D). More information is needed to evaluate Alternative A. Alternatives B and C were not evaluated. More information is needed to evaluate Alternative D. Please see Step 3 of the EAA for all required information. 11. Step 4 requires that a cost estimate be provided for all alternatives. This information is not included in the submitted EAA. 12. Attachment A of the EAA requires the local government approval form be submitted with the application. This information is not included in the submitted EAA. Ms. Summer Woodard January 12, 2018 If no response is received within 60 calendar days [per 15A NCAC 2H.0107(b)], the application will be returned. If you have any questions, please contact Brianna Young of my staff at 919-807- 6333 or via email at brianna.young@ncdenr.gov. racer y, John Hennessy, Supervisor Compliance and Expedited Permitting Unit cc- NPDES Permit Files Central Files DWR/ARO/WQROPS ec. Keith Webb, McGill Engineers [Keith Webb@Mcgillengmeers com]