NC0061425_Denial_20160330

Water Resources
ENVIRONMENTAL QUALITY
March 30, 2016
Jadd Brewer, Operations Manager/Signatory
Water Quality Lab & Operations, Inc.
PO Box 1167 / Tynecastle Hwy
Banner Elk, North Carolina 28604
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Subject: Concerning Your Request
to Modify Three NPDES Permits
Watauga County
Dear Mr. Brewer:
Director
The Division of Water Resources (the Division) hereby acknowledges your February 29, 2016 request to
modify the following NPDES permits:
1. NCO030473 - Mill Ridge Development WWTP
2. NCO061425 - Willow Valley WWTP
3. NCO032212 - Yonahlossee WWTP
We understand that you would prefer a "Grab" sampling instead of "Composite" sampling protocol. You
base your request on "...flow data that reflects that the plant has not exceeded 30, 000 gpd inflow over the
past three (3) years." However, upon review of the BIMS/DMR database, we find flow rates exceeding
0.030 MGD reported for each of the above facilities. The most contrary example, Mill Ridge WWTP,
reported maximum rates of 0.072 MGD (2014), 0.095 (2015) and 0.064 MGD (2016). Considering a flow
limit of 0.052 MGD, these are permit violations, likely unassessed.
Please understand that North Carolina Rule bases Composite sampling on design flow; these are
mandatory for all systems designed at 0.030 MGD or greater. The Rule lists grab only samples as
parameter -specific exceptions to those requiring composites [see T15A. 02B.0500 (3) (B) and (3) (C)]. Our
review of the above NPDES permits shows that parameters are correctly identified in each as "Grab," i.e.,
we find no errors as issued.
In light of the above -identified conditions and records, the Division must deny your request. If you have
questions concerning this ruling, please email Joe R. Corporon, L.G. [e-mail]] or call
his direct line [919-807-6394].
espe fully,
ZX S. Jay Zimmerman, L.G.
hc: NPDES Program Files
DWR/WSRO/SWPS, Sherri Knight, Supervisor
Central Files
ec: WSRO/SWPS, Sherri Knight, Supervisor
WSRO/SWPS George Smith
State of North Carolina I Environmental Quality I Water Resources
1611 Mail service Center I Raleigh, North Carolina 27699-1611
919 707 9000