NC0067326_Speculative Limits_20060125

Michael F. Easley
W AT �R4 Governor
G William G. Ross, Jr., Secretary
Cr North Carolina Department of Environment and Natural Resources
-I Alan W. Klimek, P.E., Director
G3 '� Division of Water Quality
January 25, 2006
Mr. Terry Bell
Chief Operations Officer
Macon County Schools
P.O. Box 1029
Franklin, North Carolina 28744
Subject: Speculative Effluent Limits
NCO067326 - Cullasaja Elementary School
NCO067318 - Nantahala Elementary School
Macon County
Dear Mr. Bell:
This letter is in response to the request for an increase in permitted wasteflow for the
two schools listed above. Before the Division can proceed, some additional information needs
to be provided by Macon County Schools. First, completed NPDES applications for each
school requesting the expansion flow from 2000 GPD to 3000 GPD should be sent to this
office and should include major modification fees at $215.00 per school. In addition, an
Engineering Alternatives Analysis (EAA) needs to be submitted that will evaluate any
alternatives to the expanruction should provide insight into the on process. A consultation with hinforma onr. Bob e that must be
weese of the
Department of Public Instruction P
provided in the EAA.
The Cullasaja Elementary School discharges to the Cullasaja River in the Little
Tennessee River Basin and has a stream classification of B -Trout. The Nantahala
Elementary School discharges to Partridge Creek, in the Little Temmessee River Basin and
has a stream classification of C Trout. Neither of these streams is listed on the North
Carolina 303(d) Impaired Waters List for 2004.
Based on available information, the tentative effluent limits for oxygen -
consuming constituents
s bothllasaja Elementary School at the flow of 0.003 MGD aredthe included on
he
ala
Elementary School d ischarge
attached effluent sheets.
The Division of Water Quality is requiring chlorine limits for all new or expanding
dischargers proposing the use of chlorine for disinfection. The process of
chlorination/dechlorination or an alternate form of disinfection, such as ultraviolet radiation,
should allow the facility to comply with this requirement.
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 DENR19)7
33-0719
Internet: h2o.enr.state.nc.us Customer Service Center: 1800 623 7748

Final NPDES effluent limitations will be determined when a permit application
is submitted to the Division. If there are any additional questions concerning this
matter, please feel free to contact Jackie Nowell of my staff at [phone] ext. 512.
Respectfully,
& � 4­ -'�
Susan A. Wilson, Supervisor
NPDES Western Program
cc: Asheville Regional Office/Surface Water Protection
Dr. Rodney Shotwell/Macon County Schools
Bob Deweese/ Department of Public Instruction
NPDES Permit Files/NC0067326; NC0067318

CULLASAJA ELEMENTARY SCHOOL — NCO067326
SPECULATwE EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon rerating to 0.003 MGD and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
cnerifled_beloW' -- - ----- - -
Footnotes:
1. .The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NANTAHALA ELEMENTARY SCHOOL — NC0067318
SPECULATIVE EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon rerating to 0.003 MGD and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
----specified-below!-
Flow 0.003 MGD
Weekly
Instantaneous
Influent or Effluent
BOD, 5-day (20°C) 30.0 mg/L
45.0 mg/L
Weekly
Grab.
Effluent
Total Suspended Solids 30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
NH3 as N
2/Month
Grab
Effluent
Temperature (°C)
Weekly
Grab
Effluent
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Macon County Schools
Subject: Macon County Schools
From: Forrest Westall <[e-mail]>
Date: Tue, 11 May 2004 12:58:17 -0400
To: Susan A Wilson <[e-mail]>
CC: Kevin Barnett <[e-mail]>
Susan,
I talked to Bob DeWeese with the State Superintendent's
office about Cullasaja and Nantahala Schools. They had
requested a flow increase with the last permit renewal, but
that request was denied. I reviewed the WWTP capacity at
both schools and the student population numbers. The State
flow figures with the current student population numbers
would put both schools over their current 2,000 gpd limit
(12 gpcd). Both plants have sand filters1 and the other
parameters on their effluent quality are excellent (they
have secondary limits). The school -'system asked for the
flow increases to protect them from potential enforcement.`(/"
Because per capita water usage is significantly lower than
the State guideline, -they are currently in compliance with
�'
the flow limit, but the levels are approaching the limit and
�fJ,00
are close to going over. Also, Cullasaja district is
growing and next year they could have populations that
result in a flow violation. 'I think that increasing the
flow limit at each plant is certainly supportable by the
student numbers and the capacity of the plants. Both plants
18
b�+
are 2000 gal capacity and would still provide adequate
`�
hours detention at 3000 gpd (this is what they requested •at
�
both plants). 'Chlorine contact time is OK at 3000 gpd and
even if clarifer overflow rates are a bit high, they have
sand filter capacity following the clarifer. If we wait
until they start having flow violations, we will be placing
the schools in the enforcement machine for no go good
reason. Assimulative capacity is good in both receiving
streams and other alternatives are not available (Cullasaja
is miles :from Franklin and Nantahala is away from
everything --it's in the middle of woods). The option of
increasing permit flow is the .most appropriate and is
supported by the facilities present. I've suggested to Bob
that he meet with you about these requests and better
explain the need. Keeping unnecessary flow expansions out
of permits is a good thing, but the Macon County schools
requests -make sense for their situation. I would be Happy
to discuss this with you, just let me know. Thanks for the
consideration. Forrest
Forrest Westall - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
1 of 2 5/ 11 /2004 2:27 PM

Macon County Schools
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Forrest Westall <[e-mail]>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
2 of 2 5/ 11 /2004 2:27 PM