NC0089095_Wasteload Allocation_20120131

y. r
Berry, Ron
From: Berry, Ron
Sent: Tuesday, January 31, 2012 9:50 AM
To: Cranford, Chuck
Subject: RE: More comments on High Vista Falls
Chuck,
FYI
I did a quick check since Rosewood is currently not required to operate at tertiary BAT limits but is operating with
secondary treatment limits and does not need to meet BAT NH3-N limits. Not knowing what they may need expansion -
wise, Line Creek waste load model suggest the possibility of applying NH3-N limits still above the BAT limits (less than
current limits) for a Rosewood expansion double the existing permitted flow that would protect Line Creek. This could
all change if Line Creek became impaired. The NH3-N BAT monthly limits for minor domestic treatment facility are
summer = 2.0 mg/L, winter = 4.0 mg/L. As always any expansion request is subject to review for approval at the time of
the permit modification application.
Ron
Ron Berry [e-mail]
Engineer I
DWQ/Point Source/NPDES Complex Permitting Unit
NCDENR
Phone: [phone]
Fax: [phone]
Office: Archdale Building Room 925Y
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
From: Cranford, Chuck
Sent: Tuesday, January 31, 2012 8:16 AM
To: Berry, Ron
Subject: RE: More comments on High Vista Falls
Hi Ron —
Keith, Wanda and I met yesterday to compile comments we had on the earlier draft. Your email with the proposed
changes was timely.
According to Wanda and Keith, more experienced than I in WW treatment, the lower limits could be tough to meet. But,
they did not think impossible.
The probable expansion limitation to the Rosewood MHP could be an issue for that facility. The owner has more
property and is very likely to desire an expansion at some point. We plan on contacting him, so he can comment on the
permit.
Our comments are likely ready to be submitted. Will you update the permit and send it to us one more time before it
goes public or should we go with the information from the email yesterday and comment?
Thanks,

Chuck
Chuck Cranford
Supervisor, Surface Water Protection Section
Division of Water Quality
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
chuck.cranford@ ncdenr.gov
Email correspondence to and from this address is subject to
the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or
other regulation.
From: Berry, Ron
Sent: Monday, January 30, 2012 11:51 AM
To: Cranford, Chuck
Subject: More comments on High Vista Falls
Chuck,
Just emailed an update to everyone on the amended draft permit and explained that High Vista Falls was receiving a
fixed allocation with no possibility of expanding beyond the 0.045 MGD discharge into Line Creek. Also, the NPDES
permit limits are fixed based on the allocation and are more stringent than conjunctive. I did not made any changes to
the proposed TSS limits as the facility is already required to meet a monthly average limit of 5 mg/L and we will continue
to expected the facility to meet TSS limits as designed.
My only concern is the ability of High Vista Falls to comply with the NPDES limits. Based on the last three years of data
submitted under the non -discharge permit:
1) Flow monthly average = 0.026 MGD
2) BOD monthly average = 5.4 mg/L (42% of data above 5 mg/L)
3) TSS monthly average = 2.5 mg/L (4% of data above 5 mg/L)
4) NH3-N monthly average = 0.6 mg/L ( 15% of summer data above summer 2 mg/L, no winter data above winter
4.0 mg/L)
5) Fecal Coliform monthly average = 4.7 #/100 ml (there were some daily values in excess of 25 #/100 ml, not sure
of problem, facility using tablet chlorination)
We do not want to issue a final permit for parameters the facility is incapable of meeting. However, changing this facility
from a reclaim to a NPDES discharge may help. In any case this facility is designed as a tertiary treatment facility and my
understanding is that it should be capable of operating within the NPDES permit limits. Not sure how the past
operational problems relate to the reported data.
Let me know of your thoughts or the regions thoughts. My goal is to issue the draft permit this week for comment.
Thanks,
Ron
Ron Berry [e-mail]
Engineer I
DWQ/Point Source/NPDES Complex Permitting Unit
NCDENR

Phone: [phone]
Fax: [phone]
Office: Archdale Building Room 925Y
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
�� 6 fN U (,-� 4 1' � k Vi 5,)-7,- F,,,, 115- -,,- f - L, N
w>v��
S-�-A'n A C-r
3