NC0074306_Fact Sheet_20181205

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 12/5/18
Permit Number
NCO074306
Facility Name / Facility Class
Forest City WTP / PC-1
Basin Name / Sub -basin number
Broad / 03-08-02
Receiving Stream / HUC
UT to Second Broad River / 0305010504
Stream Classification / Stream Segment
WS-V / Index: 9-41-(12.7) - Index wrong in
BIMS, associated with location north of the
actual discharge point
Does permit need Daily Maximum NH3
limits?
N/A
Does permit need TRC limits/language?
Already resent
Does permit have toxicity testing? IWC (%) if
so
Yes; IWC = 90%
Does permit have Special Conditions?
No
Does permit have instream monitoring?
No
Is the stream impaired on 303 d list)?
No
Any obvious compliance concerns?
No
Any permit mods since lastpermit?
No
New expiration date
7/31/2023
Comments on Draft Permit?
Yes; see below
Facility Overview:
The Forest City WTP operates a conventional WTP designed for a potable flowrate of 8
MGD and a design wastewater discharge of 0.056 MGD. The facility generates
backwash, but did not discharge during the previous permit cycle as the decant water
from the basins is pumped back to the head of the facility. Permittee confirmed that the
maximum potential wastewater discharge is 0.056 MGD in response to an additional
information request.
Compliance History:
• No NOVs between May 2013 and October 2018
• No tox test results available since January 2014

RPA:
There has been no discharge in the previous permit cycle, therefore there is no data
available to run an RPA.
NCG59 General Permit Eligibility:
• They do not have enough data to run an RPA or tox tests to confirm eligibility
• Conclusion: They are not eligible for the NCG59
Changes from previous permit to draft:
• Added eDMR footnote in A(1) and language as A(3)
• Updated outfall map
• Added regulatory citations
• Language updated on the Supplement to Permit Cover Sheet per 2012 WTP
guidance
• Components list added on the Supplement to Permit Cover Sheet per renewal
application
• Added units of measure in A(1)
• Facility grade added in A(1)
• Monitoring for turbidity reduced in A(1) to monthly per 2012 WTP guidance
• Monitoring for iron removed as permittee indicated iron sulfate/ferrous sulfate
does not have the potential to be discharged and there is no longer a water quality
standard
• Monitoring for total nitrogen and total phosphorus has been added back into the
permit as the facility has the potential to discharge up to 0.056 MGD, which
requires monitoring per the 2009 WTP strategy — no reason given for why
removed in previous renewal
• Added quarterly total hardness monitoring and associated footnotes in A(1) per
current WTP guidance
• Added "Monitor & Report" for tox testing in A(1) per 2012 WTP guidance
• Updated flow footnote in A(1) per 2012 WTP guidance
• Removed footnote #3 in A(1) stating "Monitoring should be performed in
conjunction with toxicity testing" as no longer required
• Updated toxicity footnote in A(1)
• Updated tox language in A(2)
Changes from draft to final:
• Upstream hardness footnote modified to indicate sampling should occur only if
flow is available (per ARO's comments; see below)
• New A(3) added to address monitoring if discharge should occur (per ARO's
comments below)

Comments received on draft permit:
• Mikal Wilmer (ARO; via email 11/6/18)
o The facility currently has a reporting waiver and would have to clear a
path and set up sampling again if they were to discharge. If we could put a
requirement to notify our office and Raleigh if/when they ever intend to or
need to discharge to the UT that would be great.
■ DWR response: If they have a reporting waiver, they are required
to notify the Division once discharge resumes (as it should be
stated in the waiver). However, to make this clear to them, a
separate condition will be added to the permit stating this. The
proposed condition language is below. Please let me know your
thoughts.
• According to the Division's records, the facility currently
has a reporting waiver for submitting Discharge Monitoring
Reports (DMRs) as wastewater is currently recycled back
to the head of the facility and is not actively discharged. If
or when a discharge to the receiving stream stated in this
permit is ever intended or needed, notification to the
Asheville Regional Office and the Central Office is
required.
o During my inspection earlier this year, the ORC and Superintendent
indicated the UT the facility would discharge to has little to no flow. I was
unable to verify stream flow due to the banks being overgrown; however,
if there isn't consistent flow, sampling upstream hardness would be
difficult (I guess they would use the minimum of 25 mg/L?).
■ DWR response: The upstream hardness footnote has been
modified to indicate sampling only needs to be done if flow is
available.
o One additional comment, Footnote 5, the last sentence appears to be cut
off or incomplete.
■ DWR response: There are 6 footnotes total. The last part of
footnote 5 is on a separate page with footnote 6. Footnote 5
appeared complete when I reviewed it.