NC0089737_Fact Sheet_20181127

FACT SHEET FOR EXPEDITED PERMIT RENEWALS
This form must be completed by Permit Writers for all expedited permits which do not require
full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile
home parks, etc) that can be administratively renewed with minor changes, but can include
facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing,
instream monitoring, compliance concerns).
Basic Information for Expedited Permit Renewals
Permit Writer / Date
Brianna Young 11/27/18
Permit Number
NC0089737
Facility Name / Facility Class
Town of Franklin WTP / PC-1
Basin Name / Sub -basin number
Little Tennessee River / 04-04-01
Receiving Stream / HUC
Cartoo echa e Creek / 0601020201
Stream Classification / Stream Segment
B; Tr / Index: 2-19- 10.5
Does permit need Daily Maximum NH3
limits?
N/A
Does permit need TRC limits/language?
Yes
Does permit have toxicity testing? IWC (%)
if so
Yes; IWC = 1.92%
Does permit have Special Conditions?
Yes; see below
Does permit have instream monitoring?
No
Is the stream impaired on 303 d list)?
No
Any obvious compliance concerns?
N/A
Any permit mods since lastpermit?
N/A
New expiration date
12/31/2023
Comments on Draft Permit?
None
Proposed Facility and Discharge:
This is a new permit for an existing conventional WTP in the Town of Franklin in Macon
County. The source water for finished potable water is the Cartoogechaye Creek. The
design potable flowrate is 2.0 MGD and a potential maximum daily wastewater discharge
of 0.255 MGD. The facility will generate intermittent backflow with a discharge
occurring 7 days per week (WTP is typically operated 14 to 16 hours per day). The
discharge will consist of clear supernatant from the second alum lagoon. The filters will
be backwashed with finished potable water and the sedimentation basins will be cleaned
out with finished potable water.
Potable water treatment will consist of.
• Pre-treatment (Actiflo) ballasted settling unit of raw water
• Polyaluminum chlorosulfate (PAC) (cedarcleaer-757) added as a coagulant
• Two (2) sedimentation basins
• Filtration using mixed media filter
• Chlorine gas/sodium hypochlorite
• Caustic soda/sodium hydroxide (for pH adjustment)
• Zinc -orthophosphate prior to storage in clearwell
Page 1 of 5

Wastewater treatment generated from the pre-treatment unit (Actiflo), filter backwash,
periodic cleaning of sedimentation basins, and process instrument wastewater will consist
of:
• 136,700 gallon flow equalization tank
• Two (2) alum sludge lagoons functioning in series (combined volume of 1.8 MG)
• Discharge will be from second alum sludge lagoon
Discharge will consist of the following waste streams:
• Pretreatment unit (Actiflo)
• Filter backwash
• Periodic cleaning of the sedimentation basins
• Process instrument wastewater
Permitting Strategy:
This permit has been drafted following the 2009 WTP strategy for conventional WTPs
and the 2012 guidance update. Parameters included in permit are:
Flow
Conventional strategy
followed
Total Suspended Solids
Conventional strategy
followed
H
Conventional strategy
followed
Total Residual Chlorine
Conventional strategy
followed; Limit based on WLA
Turbidity
Conventional strategy
followed
Aluminum
Conventional strategy
followed
Total Copper
Conventional strategy
followed
Fluoride
Conventional strategy
followed
Total Zinc
Conventional strategy
followed
Ammonia Nitrogen
Conventional strategy
followed
Total Phosphorus
Conventional strategy
followed
Total Nitrogen
Conventional strategy
followed
Hardness
WTP guidance followed
WET Testing
Conventional strategy
and WLA
followed; IWC % based on RPA
Total Iron is not included in the permit as there is no longer a water quality standard for
iron.
Manganese is not included in the permit as there is no longer a water quality standard for
manganese.
Little Tennessee River Basinwide Water Quality Plan:
The 2012 Little Tennessee River Basinwide Water Quality Plan was reviewed.
Cartoogechaye Creek was not listed as having a TMDL. The plan contained the following
information:
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• DWQ sampled Cartoogechaye Creek for possible bacterial contamination in
September 2011, completing five samples within 30 days resulting in a geometric
mean of 273 colonies/100 ml which exceeds the standard. This creek qualifies to
be listed on the 303(d) list in 2014. The sampling site is located at the Town of
Franklin WTP, which is just upstream of the town limits and the more commercial
zone. Surveys in the watershed indicate that livestock farming without the use of
BMPs (e.g. cattle exclusion fencing), may be the main cause of elevated fecal
coliform levels. There may be some contribution from failing septic systems, but
surveys by the WaDE program indicated this was not a major problem. Action to
address this issue should include working with the local Soil and Water
Conservation District to provide cost -share funding for the implementation of
BMP's where livestock have access to the creek.
• Biological data collected by DWQ indicated the benthic community at site GB40
rated Good in 2009 and 2004, but was Excellent in 1999. The habitat was good,
indicating the decline is likely due to a change in water quality. Site GB41, in the
headwaters, rated Excellent in 2004 and the fish community at site GF6 rated
Good.
• The Little Tennessee Watershed Association (LTWA) completed the
Cartoogechaye Creek Municipal Watershed Assessment in 2008. They monitored
fish communities in the Cartoogechaye watershed at 14 locations. Their
monitoring results indicate a high incidence of the parasitic infection called
blackspot. Blackspot is often associated with organic enrichment, but can be
found in healthy streams. LTWA reports blackspot was in decline in 2006, but a
resurgence was seen in 2009. Further monitoring will determine if the trend will
continue.
• Table 1-1 lists waterbodies identified as needing additional protection and
potential restoration actions:
Stream Name
AU#
Class.
Stressor
Source
Status
Actions
Needed
Cartoogechaye
2-19-(1)
WS-111;Tr
nutrients,
development,
S
P,
Creek
2-19-(10.3)
WS-III;Tr,CA
fecal
agriculture
BMPs
2-19-(10.5)
B;Tr
coliform
bacteria
* S = supporting
*P = Protection
Special Conditions:
As this is a new WTP discharge, Section A. (3) has been added to require that, in
accordance with 40 CFR 122.2 1 (k)(5)(vi), no later than 2 years after the commencement
of discharge from the proposed facility, the applicant is required to complete and submit
items V and VI of NPDES application form 2C.
Page 3 of 5

Compliance History:
There is no compliance history to review as this is a new permit.
The Town of Franklin WTP ran toxicity tests on 3 grab samples collected from the first
lagoon in July 2018. Samples were taken from the first lagoon, rather than the second
lagoon where discharge will occur from, as the second lagoon was undergoing
maintenance at the time the samples were taken. The toxicity test used was Ceriodaphnia
Chronic Pass/Fail Test EPA-82 1 -R-02-013 using 90% dilution. The results were as
follows:
• Sample collected 7/10/18 — FAIL
• Sample collected 7/17/18 — PASS
• Sample collected 7/24/18 — PASS
Quarterly toxicity testing will be required per the 2009 WTP strategy for conventional
WTPs. The toxicity test will be a chronic monitor only test using Ceriodaphnia dubia
with an IWC of 1.92% based on the WLA and RPA.
RPA:
Monitoring data provided with the revised permit application were reviewed. Effluent
data from two labs was provided for 1 grab sample collected from the proposed discharge
location in the second sludge lagoon on June 21, 2018. A maximum discharge of 0.255
MGD was used to calculate limits.
• Arsenic — No RP, predicted max < 50% of allowable Cw; no monitoring required
as arsenic is not a parameter of concern per conventional WTP strategy
• Chlorides — No RP, predicted max < 50% of allowable Cw; no monitoring
required as chlorides are not a parameter of concern per conventional WTP
strategy
• Copper — No RP, predicted max > 50% of allowable Cw; monthly monitoring
applied as no data exists for the proposed WTP and copper is a parameter of
concern per conventional WTP strategy
• Lead — No RP, predicted max < 50% of allowable Cw; no monitoring required as
lead is not a parameter of concern per conventional WTP strategy
• Zinc — No RP, predicted max < 50% of allowable Cw; monthly monitoring
applied as no data exists for the proposed WTP and zinc is a parameter of concern
per conventional WTP strategy
Radiological data was provided for the proposed effluent for 1 sample collected on June
21, 2018 (results below). The 15A NCAC 02B .0219 standard states that water quality
standards applicable to class C waters [found in 15A NCAC 02B .0211 ] also apply to B
waters. The 15A NCAC 02B .0219(17) standard states the average annual activity level
for combined radium-226 and radium-228 shall not exceed five (5) pCi/l, average annual
gross alpha particle activity shall not shall not exceed fifteen (15) pC/l, and average
annual gross beta particle activity shall not exceed fifty (50) pCi/l. Based on the results
below, monitoring for radiological components is as follows:
Page 4 of 5

Parameter
Value
Modifier
Units
Monitor?
Reason
Gross Beta
4
<
pCi/1
No
Does not exceed
annual average
50 pCi/L
standard
Radium 226
1
<
pCi/1
N/A
N/A
Radium 228
1
<
pCi/1
N/A
N/A
Combined Radium
Not
Not
pCi/1
No
Radium 226 and
226/228
tested
tested
Radium 228
individually do
not exceed
annual average 5
pCi/L standard;
Permit will
contain Section
requiring
monitoring per
40 CFR
122.21 k 5 vi
pCi/1
No
Does not exceed
Gross Alpha 3 <
annual average
15 pCi/L
standard
NCG59 General Permit Eligibility:
• This is a new permit with no data to review at this time
• The facility must be under a general permit for at least 1 permit cycle before
being considered for the NCG59 permit
• Conclusion: This permit is not eligible for NCG59 at this time
Changes from draft to final:
• Year of effective date updated to reflect accurate date
• Facility grade added in A(1)
Comments received on draft permit:
• Byron Hamstead (US FWS; via phone 3/19/18)
o Stated he did not have any particular concerns about this project
• Tim Heim (ARO; via email 10/29/18)
o Looks fine from their end. No changes.
• Andrea Leslie (NCWRC; via email 11/16/18)
o Given what the project entails, do not have a lot of concerns at this point.
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