NC0089737_Comments_20180905

E. McGill
ASSOCIATES
September 5, 2018 SEP 11 2018
Water Rgsources
Ms. Brianna Young
Permitting Section
Environmental Senior Specialist
Department of Environmental Quality
Division of Water Resources
Compliance and Expedited Permitting Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
RE: Water Treatment Plant Upgrade
Town of Franklin
NPDES Application Permit#NC0089737
Macon County
Dear Ms.Young:
I have received your email dated August 20, 2018 for the NPDES permit application for
the Town of Franklin Water Treatment Plant, NPDES Permit NC0089737. I am providing and
enclosing the following additional information as requested per your email. Your question is
shown first and then the response:
1. The submitted EAA states peak wastewater flow will be 255,000 GPD,but it is unclear
how this number was determined or if this is representative of the existing plant design
potable flowrate of 2.0 MGD. Please verify the maximum potential volume for each
individual waste stream(not averages), the maximum potential discharge into
Cartoogechaye Creek through the outfall, and the plant design potable flowrate the
discharge volumes are based on.
RESPONSE
The water treatment plant design flow is 2.0 MGD (million gallons per day)
Peak maximum daily wastewater from the Actiflo process = 72,000 gpd(gallons/day)
50 gpm @ 24-hour operation = 72,000 gpd)
Peak filter backwash
Backwash 1 filter per day at peak flow of 41,000 gpd/filter backwash
55 Road Street P.O. Box 2259ph: 828 252 0575
Asheville,North Carolina 28801 Asheville,North Carolina 28802 1: 828.252.2518 www.mcgillengineers.com

Sedimentation basins will require cleaning once every 6 months once the Actiflo process
is in place. Assuming recycle system installed for sedimentation basin cleaning then
water wasted per basin cleaning = 142,000 gpd.
Maximum probably daily wastewater production =
Actiflo @ 72,000 gpd
Filter backwash @ 41,000 gpd
Sedimentation basin cleaning @ 142,000 gpd
Total = 255,000 gpd
All wastewater from the water treatment plant operation first flows to the 136,700-
gallon capacity backwash flow equalization tank, then flows into the first lagoon
which has a capacity of 545,000 gallons, then into second lagoon which has a
capacity of 366,000 gallons. Discharge from the wastewater treatment system and
lagoons to Cartoogechaye Creek is from the second lagoon.
The maximum discharge to Cartoogechaye Creek from the wastewater treatment
system would be 255,000 gpd to allow the operators to lower the water level in the
second lagoon prior to cleaning the sedimentation basin and backwashing a filter.
2. The additional information request dated June 8th included that an analysis of the
wastewater be performed for Beta Particles and Radium 226 &228. I did not see this
information provided with the other water analyses. Was this analysis completed?
RESPONSE
A copy of the Radiological analysis for the lagoon effluent grab sample for Gross
Alpha, Radon, Uranium, Combined Radium, Radium 226, Radium 228 and Gross
Beta are attached.
3. The toxicity results indicate that the first test resulted in a failure, and the two subsequent
tests resulted in passes. Were the samples for all 3 tests taken in the same location, in the
same manner, with the same processes running at the WTP? We would like to verify that
all 3 samples were representative of the potential discharge.
RESPONSE
All three grab samples were taken from the first sludge lagoon at the same location.
The second and third sampling event took place a minimum of 24 hours following
filter backwash and the wastewater had time to settle in the sludge lagoons. For the
second grab sample taken on July 19 the temperature of the grab sample was 22.5°C
and the pH was 7.19. For the third grab sample taken on July 24 the temperature of

the grab sample was 21.6°C and the pH was 6.97. However, the first grab sample
was taken shortly after a filter backwash event and the wastewater did not have time
to adequately settle as will be the normal operation. For the first grab sample taken
on July 10 the temperature of the grab sample was 23.1 °C and the pH was 8.48.
I believe the time of the sampling shortly following a filter backwash event had a
negative impact on the Ceriodaphnia Chronic Effluent Toxicity testing. Given time for
the wastewater to settle in the lagoons prior to discharge as was the case in the
second two sampling events is more representative of the normal operation of the
facility.
4. Step 3 of the EAA requires that land application alternatives be considered. The updated
EAA provided in April 2018 addressed spray irrigation, however, subsurface and drip
irrigation systems were not addressed as required in the EAA. Documentation of these
alternatives is needed.
RESPONSE
Attached for your reference is the report and evaluation of the alternatives for drip
irrigation and subsurface disposal prepared by Dr. A.R. Rubin and S.J. Fredrick for
the project. Neither alternative is feasible due to the lack of property near the Franklin
Water Treatment Plant for the location of either alternative.
If there are any questions, please give me a call at 828-252-0575 or email at
[e-mail].
Sincerely,
McGI L ASSSO�OCIATES, P.A.
i A J C
KEITH WEBB, P.E.
Vice President- Principal
Attachments
CC; Summer Woodard—Franklin
Nathanael Moore—Franklin w/attachment
Rob Hartsell—Franklin
J.Meliski-McGill Associates w/attachment
15.00359/Franklin WTP/NPDES/by5sept18-npdes response

Radiological Analysis
Franklin Water Treatment Plant Alum Sludge Lagoon
Grab Sample

,•t
:r Florida Radiochemistry Services, Inc.
5456 Hofner Ave.,Suite 201 Orlando,FL 32812
- Phone [phone] Fax' (407-382-7744
Radiological Analysis -
Note.6.14,Intormation must be supplied for compliance credit
WATER SYSTEM OD#: _______-l__-___ County:
Name of Water System: �,(an t& (;r 1 w 1 l'nn
Sample Type: ❑Single Sample-Entry Point ❑Composite Sample-Entry Point
lSp cial/Non-compliance
Facility ID No _-- CollectionData
Date Time CoMcted 6r
Sample Point (MMJDDIY Y) lspediy I M or tM)
Sirsa oe 1...QV
Dg(rJ1 Lid 4/ :so rol i4,4
5Mail Results tollre'nrrna'lae)cstSolutions,Inc,
PO I),rn 7565
Acheville,rNC2/3802 2"Qtx _J_J__ M
Telephone# e ) 3stmu`"i --1--1-- -- - -M
Fax# f 350"13 toe _ 4..(It' _J_J—_ M__ _
Responsible Person's email I _ I i
LABORATORY ID#: 12 7 0 9 ❑SAMPLE UNSATISFACTORY ❑ RESAMPLE REQUIRED
Required ALAI Detected
Contain Method Repotting Limit (i.e.<R.R.L.) Quantified Counting Allowable
••
Contaminant Code (R.R.L) (X) •- Results* Error Limit
4002 - Gross Alpha— 435 's pCi/L lir � 15 pCi/L
. pCi/L _047_
4004 Radon ' 100 pCi/L ❑ N/A
pCi/L
4006 — Uranium 456 0 67 pCi/L C] 20.1 pCi/L
pCi/L __• ** _
4010 Combined Radium N/A N/A N/A 5 pCi/L
pCi/L ___
' (4020 ) Radium 226 446 1 pCi/L jir D z 3 pCi/L
• pCi/L __• _
4030 ) Radium 228 452 1 pCi/L D 2 pCi/L
pCi/L __'_
x4100 Gross Beta 435 4 pCi/L g J,2 50 pCi/L
*Note: If result exceeds allowable limit,the laboratory must fax analytical results to the State within 48 hours.
**Note: Not applicable if using ICP-MS
Date: lime:
Analyses Begun: 0 422_,a ii j_t_ o 6 : © ,_, Am
(MM/DD/YY) (Specify AM or PM)
Analyses Completed: o 22 o Le 1 L: o j, f M
(MM/DD/YY) (Specify AM or PM)
Laboratory Log#: l Sp( (7)--° ( Certified by: Mike Naumann/,��
1 Comments: •
-
Laboratory should mall results to-
Public Water Supply Section,Attn:Data Entry,1634 Mail Service Center,Raleigh,NC 27699-1634
Fax: [phone]
/
Rev.01/09/08

o - CHA,IN-OF-CUSTODY / Analytical Request
,,,,, - 01
Client Name:
r------):._..--1 Address:
ETS1 WC-
�, Environmental Testing Solutions,Inc. Report to:
PO Box 7565,Asheville,NC 28802 Phone: , Fax:
Phone: [phone],-9 + Fax: [phone] PO Number:
Project Name: f viiyi,!)Itti/ % IA 11- Re.ueSted Anal ses
Project Number: i pH Checked Upon Receipt
I CI,<0.2 mg/I Upon Receipt
Preservatives (
co C4
Sample Identification U a , � a _,
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Sample.Condition Upon Receipt IRelitigtii hed By- — Company Date I-
Time I Accepted by 'Company I Date ( Time
Temperature(°C) /JJS �A�1./e R/YI, /J O/ 61 le •
Received on Ice: Y / N P ` j e ,� v� K�V Rau, tJ�i�I.ti - , IVO--
Sealed
3 f��
Sealed Cooler: Y / N L�7
Samples Intact: Y / N
Additional Comments: Sampler Name,and Signature Date
Printer vi f Balmier.
Signature of Sampler:

A. R. Rubin Report
Alternative Analysis
Subsurface and Drip Irrigation

Site and Soil Report
Town of Franklin Water Plant
Franklin, NC
By
A. R. Rubin and S. J. Frederick
Introduction:
The Town of Franklin, NC is planning an expansion of the water plant.The plant
expansion is intended to increase the capacity of the water supply from the current
2 MGD to between 3 and 4 MGD.Water needs will increase to approximately 4 MGD
by 2060 (Engineering Alternatives Analysis, McGill and Associates, October 2017).
The water treatment system proposed includes an Actiflo Water Treatment system
and this system will generate between 40 and 55 GPM wastewater flow. The plant
will operate approximately 16 hours per day and the anticipated wastewater flow at
the planned capacity is estimated as 75,000 gallons per day.
The engineering alternatives assessment submitted previously included an
assessment of a surface wastewater irrigation alternative,but did not include an
assessment of a subsurface wastewater dispersal system (October 2017). The
NCDEQ DWR letter 8 June 2018 (item 4) requested an assessment of subsurface
dispersal options for the wastewater generated in the process. Two possible sub-
surface options are available. These are a low-pressure pipe system or a sub-surface
drip dispersal system.
The soil resources in the area have been mapped through NRCS. The soil resources
typically contain clay subsoil and this will limit the liquid loading (LTAR) to a soil
based system. This is discussed in the section that follows, but the clays will restrict
liquid loads to approximately 0.1 gallons per square foot per day.A conventional or
gravity based dosing system is not possible since NC Rule requires positive or
pressure dosing for any system requiring over 750 linear feet of soil absorption field
as discussed below. Consequently the sub-surface dispersal options include
pressure dosed standard trench (3 feet in width), a Low Pressure Pipe (LPP) system
or a drip dispersal system.
Design Procedures:
The proposed water plant is located in the Franklin County Industrial Park. The
water plant site is located on a peninsular shaped landscape bounded to the east by
Cartoogechaye Creek and to the west by Potts Creek. The plant location limits the
potential land areas available for a subsurface system unless a creek crossing is
planned.The creek crossing eliminated land areas requiring the crossing and land

areas over 2500 to 3000 feet from the water plant were eliminated because of slope
(Soil Map Attached)
The soils map generated through the USDA NRCS Web Soil Survey program suggests
the soil resources in the area best suited to host a subsurface wastewater system
include the following soil resources: Statler clay loam, (StB), Dillsboro sandy clay
loam (DsB) (), Evard-Cowee complex (EvD), Hayesville clay loam (HaD) and
Udornths (Ud).With exception of the Udornths,typical descriptions for these are
attached. Udornths are soil materials that have been dramatically altered by
activities of man and are not suitable for wastewater application. These soils are
typically listed as group III soils in the NC Rules for subsurface wastewater systems
and the rules define acceptable long term acceptance rates (LTAR) for this soil
resource group as between 0.2 and 0.4 gallons per square foot per day. For large
flows (those greater than 3000 GPD) the more conservative liquid loading rates are
recommended in the fine textured soils of group III and IV.
Each of these soils contain a clay enriched sub-surface horizon. The clay enriched
sub-soil optimizes the potential for treatment, but limits liquid loading. Based on the
NCDHHS EHS rules,the textural class and associated permeability of the sub-surface
horizon will limit the liquid loading utilizing a sub-surface system to between 0.2
gallons per square foot per day for the required pressure dosed wastewater system..
The land area required to accommodate the estimated 75,000 GPD wastewater flow
is calculated as:
75000 GPD/0.2 Gallons/sq. ft./day= 375,000 Sq. ft. or approximately 8.6 Ac.
Examination of the web-soil survey map attached depicts a tract of undeveloped
land approximately 1000 feet from the water plant.This tract contains
approximately 4.1 acres and this undeveloped tract can not assimilate the liquid
waste generated at the treatment plant. This limitation indicates additional tracts
will be required and design, installation, operation, and management issues increase
the complexity of any sub-surface wastewater system.
In addition,the NCDHHS EHS Rules require a back-up or repair area of equal
treatment capacity. This regulatory requirement will, at minimum, double the land
area necessary to assimilate this water plant wastewater. The land area required for
a sub-surface wastewater treatment system is very significant and that land area
does not appear available with in 0.5 miles of the water plant.
The two general categories of wastewater distribution require extensive trenching
to accommodate the wastewater distribution network. The trench lengths are
determined differently for the distribution options. The length of distribution pipe
required in a traditional trench system is calculated total area required for
assimilation divided by trench width (typically 3 feet). The trench length for a LPP
or a drip system is calculated as area divided by line spacing. In an LPP system
typical spacing is 5 feet while that in a drip system is typically 2 feet.

Linear footage of trench or distribution network is calculated for the various
distribution options as:
Traditional system: 375000 square feet/3 feet= 125,000 linear feet of trench with 3
feet width
LPP: 375000 square feet/5 feet= 75,000 linear feet of traditional LPP line at 5 ft O.C.
Drip: 375,000 square feet/2 feet= 187,500 linear feet of drip line at 2 feet O.C.
The land area required to accommodate a traditional or conventional style
drainfield would necessitate a land area of almost 9 acres and when a system is
actually developed on land that area would increase to approximately 12 acres for
the primary flow.The LPP system too would require almost 9 acres,but the actual
lay-out will waste less space and the actual land mass required is typically 20% over
design or approximately 11 acres. The drip dispersal system is most effective at
utilization of available land and this option would require approximately 10 acres.
Again,those acreage values are for the primary system only and rule requires a
reserve or repair area of equal capacity.
Recommendations and Conclusion:
Based on review of the wastewater flow projected and the review of the site and soil
resources identified within 0.5 miles of the water plant no subsurface wastewater
system is appropriate for use in managing this wastewater stream. The biggest
imitation is the availability of a landmass sufficiently large to accommodate the
primary wastewater flow and the repair area required.
The sites with steep slope designated as "D" are typically too steep for use with
subsurface dispersal systems. The land areas designated EvD and HaD are steeply
sloping and typically not suited to receive industrial wastewater.
The sites designated "B" are gently sloping and these are capable of receiving
wastewater. The land areas designated StB and DsB are suited as receivers,but the
area available containing these soil resources is less than the approximately 20
acres required to host a primary wastewater system and a repair area.As stated
above,the land area closest to the plant and containing a soil suitable to host a sub-
surface wastewater system contains only 4.1 acres and this is clearly unsuited to
serve as a receiver for the volume of wastewater5 proposed for generation at the
plant.
In addition to these site restrictions, NCDHHS EHS Rules do require extensive site
assessment for wastewater systems designated to handle industrial wastewater.A
detailed mounding analysis is often required pretreatment may be required to

assure the shallow groundwater receiving the wastewater is not adversely impacted
and the adjacent surface water its not impacted.
Based on review of the information available through the USDA NRCS Web Soil
Survey,the wastewater analysis provided, and the land use map for the area there
does not appear to be a site suited to accommodate the approximately 75,000 GPD
wastewater flow predicted from the Franklin Water plant. Utilization of a
subsurface wastewater system would not comply with requirements in the sub-
surface wastewater rules for North Carolina as 15 A NCAC 18E.
Attachments:
Web-Soil Survey
Soil descriptions of predominant soils in area

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Map Unit Descriptiot) .:ia } a a
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Printable Version
Area of Interest(AOI) o 'ap Report—Map Unit Description
Macon County, North Carolina ;iionj Add to Shopping Cart
- r . l''',:',.:•77:::',':'7 7' 9,7 , CF,';=`, DsB—Dillsboro loam,2 to 8 percent slopes . , . - . ..
Map Unit Setting
Search 0
National map unit symbol: 19z6
Map Unit Legend Elevation: 1,200 to 2,000 feet S ®rzi V)
Mean annual precipitation:45 to 70 inches
Mean annual air temperature:46 to 57 degrees F
Frost-free period: 116 to 170 days
Macon County, North Carolina(NC113) Farmland classification:All areas are prime farmland ^5' '
Macon County, North Carolina (NC113) Map Unit Composition
Map Dillsboro and similar soils:85 percent
Unit Map Unit Name Acres Perces
Symbol in AOI of AO Estimates are based on observations,descriptions,and transects of the
mapunit.
BkC2 Braddock clay 30.8 9.E Description of Dillsboro
loam, 8 to 15 Setting
percent slopes, Landform: Fans,stream terraces
eroded Landform position(two-dimensional): Summit
Landform position(three-dimensional):Tread
DsB Dillsboro loam, 2 39.2 12.1 Down-slope shape: Linear
to 8 percent Across-slope shape: Convex
Slopes Parent material:Old alluvium and/or old colluvium derived from
igneous and metamorphic rock
DsC Dillsboro loam, 8 2.4 O. Typical profile " •,
to 15 percent Ap-0 to 10 inches: loam
slopes Bt1 -10 to 15 inches:clay `
8t2-15 to 43 inches:sandy clay loam
EvC Evard-Cowee 11.1 3.4 28C-43 to 87 inches:cobbly sandy clay loam
complex, 8 to 15
Properties and qualities
percent slopes
Slope:2 to 8 percent
EvD Evard-Cowee 46.9 14.4 Depth to restrictive feature: More than 80 inches
complex, 15 to 30 Natural drainage class:Well drained
Runoff class: Medium
percent slopes Capacity of the most limiting layer to transmit water(Ksat):
EvE Evard Cowee 9.6 3.0 Moderately high to high(0.57 to 1.98 in/hr)
Depth to water table: More than 80 inches
complex, 30 to 50 Frequency of flooding: None
percent slopes Frequency of ponding:None
Available water storage in profile: Moderate(about 7.4 inches)
HaC2 Hayesville clay 2.0 0.E
loam, 8 to 15 Interpretive groups
narrPnt clnnPc Land capability classification(irrigated): None specified
Land capability classification(nonirrigated): 2e
FOIA I Accessibility Statement Hydrologic Soil Group: B Vhite House
Hydric soil rating: No
Description—Map Unit Description
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Area of Interest(AOI) 1 Soil Map r Report— Map Unit Description 0
Macon County, North Carolina art)
EvC—Evard-Cowee complex,8 to 15 percent slopes
Map Unit Setting
Search
National map unit symbol: 19z!
Map Unit Legend Elevation: 1,820 to 2,640 feet Ji
Mean annual precipitation: 50 to 58 inches
Mean annual air temperature: 46 to 57 degrees F
Frost-free period: 124 to 176 days
Macon County, North Carolina (NC113) Farmland classification: Farmland of statewide importance
Macon County, North Carolina (NC113) Map Unit Composition
Map Evard, stony, and similar soils: 55 percent
Unit Map Unit Name Acres Percei Cowee, stony, and similar soils: 35 percent
Symbol in AOI of AO Minor components: 10 percent
BkC2 Braddock clay 30.8 9.5 Estimates are based on observations, descriptions, and transects of the
loam, 8 to 15 mapunit.
percent slopes, Description of Evard,Stony
eroded Setting
Landform: Ridges
DsB Dillsboro loam, 2 39.2 12.1 Landform position (two-dimensional): Summit, shoulder
to 8 percent Landform position (three-dimensional): Interfluve
slopes Down-slope shape: Linear
Across-slope shape: Convex
DSC Dillsboro loam, 8 2.4 O."; Parent material: Residuum weathered from hornblende gneiss and/or
to 15 percent amphibolite
slopes Typical profile
A - 0 to 5 inches: gravelly loam
EvC Evard-Cowee 11.1 3.4 Bt- 5 to 29 inches: sandy clay loam
complex, 8 to 15 BC-29 to 37 inches: sandy loam
percent slopes C-37 to 80 inches: sandy loam
EvD Evard-Cowee 46.9 14.4 Properties and qualities
complex, 15 to 30 Slope: 8 to 15 percent
Percent of area covered with surface fragments: 0.1 percent
percent slopes Depth to restrictive feature: More than 80 inches
EvE Evard-Cowee 9.6 3.0 Natural drainage class: Well drained
Runoff class: Medium
complex, 30 to 50 Capacity of the most limiting layer to transmit water(Ksat):
percent slopes Moderately high to high (0.57 to 1.98 in/hr)
Depth to water table: More than 80 inches
HaC2 Hayesville clay 2.0 0.€ Frequency of flooding: None
loam, 8 to 15 Frequency of ponding: None
nPrrPnt cinnac Available water storage in profile: Moderate (about 8.2 inches)
Interpretive groups
FOIA I Accessibility Statement I Privacy P e
Land capability classification (irrigated): None specified
Land capability classification (nonirrigated): 3e
Hydrologic Soil Group: B
Hydric soil rating: No
Description of Cowee,Stony
Setting
Landform: Ridges
Landform position (two-dimensional): Summit, shoulder
Landform position (three-dimensional): Interfluve
Down-slope shape: Linear
Across-slope shape: Convex
Parent material: Residuum weathered from hornblende gneiss and/or
amphibolite
Typical profile
A - 0 to 5 inches: gravelly loam
Bt- 5 to 27 inches: gravelly sandy clay loam
Cr-27 to 80 inches: bedrock
Properties and qualities
Slope: 8 to 15 percent
Percent of area covered with surface fragments: 0.1 percent
Depth to restrictive feature: 20 to 40 inches to paralithic bedrock
Natural drainage class: Well drained

Runoff class: Low
Capacity of the most limiting layer to transmit water(Ksat): Very low
to high (0.00 to 1.98 in/hr)
Depth to water table: More than 80 inches
Frequency of flooding: None
Frequency of ponding: None
Available water storage in profile: Low (about 3.9 inches)
Interpretive groups
Land capability classification (irrigated): None specified
Land capability classification (nonirrigated): 3s
Hydrologic Soil Group: C
Hydric soil rating: No
Minor Components
Hayesville,moderately eroded
Percent of map unit: 5 percent
Landform: Ridges
Landform position(two-dimensional): Summit
Landform position(three-dimensional): Interfluve
Down-slope shape: Linear
Across-slope shape: Convex
Hydric soil rating: No
Fannin
Percent of map unit: 3 percent
Landform: Ridges
Landform position (two-dimensional): Summit, shoulder
Landform position(three-dimensional): Interfluve
Down-slope shape: Linear
Across-slope shape: Convex
Hydric soil rating: No
Lauada
Percent of map unit: 2 percent
Landform: Ridges
Landform position (two-dimensional): Summit, shoulder
Landform position (three-dimensional): Interfluve
Down-slope shape: Linear
Across-slope shape: Convex
Hydric soil rating: No
Description — Map Unit Description

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Macon County, North Carolina (NC113) .0 1.4
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Macon County, North Carolina (NC113) a --" " ,5
Map Acres Percent ���' ff. %�
„,"0"..„,- --
Symbol UMap Unit Name in AOI of AOI �.`~
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BkC2 Braddock clay 30.8 9.5% 40.
loam, 8 to 15
kV
percent slopes, " Itt:
eroded �'� J
- . .4,,
t r-,
DsB Dillsboro loam, 2 39.2 12.1% WC Dki*
to 8 percent
slopes
DsC Dillsboro loam, 8 2.4 0.7% h4 R'f
to 15 percent
F.
slopes ra=====kin �i
EvC Evard-Cowee 11.1 3.4%
complex, 8 to 15
percent slopes
EvD Evard-Cowee 46.9 14.4% l
complex, 15 to 30
percent slopes
EvE Evard-Cowee 9.6 3.0%
complex, 30 to 50
percent slopes
HaC2 Hayesville clay 2.0 0.6%
loam, 8 to 15
narrant clnnac
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