NC0069761_correspondence_20040113

F W A TF Michael F.Easley,Governor
\Otu 9pG William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
> Division of Water Quality
Coleen H.Sullins,Deputy Director
Division of Water Quality
January 13, 2004
Mr. Richard A. DeMott
Watauga River Conservation Partners
784 Alpine Dr., Seven Devils
Banner Elk, NC 28657-7980
Subject: Response To Concerns Regarding NPDES Permit Renewals In The Watauga River Basin
Dear Mr. DeMott:
In letters dated July 15, 2002 and July 31, 2002,you stated concerns regarding wastewater
treatment facilities in the Watauga River Basin. The Division regrets the long period of time
between your letter and this response. The Division held issuance on five permits for which you
provided detailed comments. The following discussion focuses on those.
The Town of Beech Mountain(NC0022730 &NC0069761)
The Town of Beech Mountain operates two facilities, the Grassy Gap Wastewater Treatment Plant
(WWTP) and Pond Creek WWTP. As you point out,both have had problems in the past.
Presently, these plants are on moratorium,which means they cannot accept additional flow until
they demonstrate consistent compliance. Both plants are also under a Special Order by Consent
(SOC), which is an agreement between the Town and the Division of Water Quality to bring the
facilities into compliance. In exchange for relaxation of certain permit limits, improvements must
be made to the facilities within certain time frames. As you pointed out in your letter,plant
improvements can be very costly, but the town has made a commitment to spend the money
necessary to comply with their permits. In this case, the Town of Beech Mountain must be in
compliance with the final permit limits at both plants before the SOC expires in November 2005.
The Grassy Gap WWTP was assessed two civil penalties in 2002 and three in 2003. The Pond
Creek WWTP was assessed three civil penalties in 2002 and one in 2003. The Division of Water
Quality is working with the facilities to ensure compliance in the future, and the Town of Beech
Mountain is making improvements to the systems.
Hawksnest Utilities Inc. —Valley,Creek WWTP C0058891
The Valley Creek WWTP was assessed two civil penalties in 2003. The facility failed to monitor
some parameters as frequently as required in the permit. This issue has been addressed. The
permit holder is not under moratorium, nor under a Special Order by Consent. As you noted, this
permit has multiple limits for flow(and other parameters) contained within it. In order for this
facility to expand above the current treatment system, capable of discharging up to 10,000 gpd, the
permit holder must clearly justify the need for higher flows prior to expansion.

Seven Devils Wastewater Treatment Facility(NC0035149)
The Seven Devils Wastewater Treatment Facility has not been assessed civil penalties in 2002 or
2003. The regional office inspects facilities on a regular schedule, and any maintenance issues
should be addressed at that time, if they had not been addressed previously. The permit presents
limits for this facility to expand from 20,000 gpd to 70,000 gpd and, ultimately, to 120,000 gpd.
Similar to the Hawksnest Utilities permit, the Division has placed a requirement in the renewal to
make sure the owner first justifies the need for specific design flows prior to a request for flow
expansion.
Adams Apple Condominiums (NC0042358)
The Division has not developed any enforcement actions against this facility during the past two
years. Based on a review of self-monitoring information, the 20,000 gpd plant discharged between
2,000 and 5,000 gallons per day during 2003. The Division will continue to work with the owner
to assure consistent treatment for optimal performance. You mentioned in your letter: "there
appears to have been occurrences of discharges not fully reported to the DWQ". Any unpermitted
discharges must be reported to the Division. If you or your associates discover a suspicious
discharge, please contact the Asheville Regional Office at(828)-251-6208 and/or the managers at
Adams Apple Condominiums immediately.
The mission of the Division of Water Quality is to preserve, protect and enhance North Carolina's
water and groundwater resources through quality monitoring programs, efficient permitting,
responsible management, fair and effective enforcement and excellence in public service. The
Division has limited resources and can be assisted by citizen groups like the Watauga River
Conservation Partners taking an active role and interest in water quality issues. The Division
appreciates your continued interest and has included, for your reference and files, copies of the five
permits discussed in this letter. Please note that by listing your name on each permit cover letter,
facilities will be made aware that your organization is taking an interest in their specific facility.
Changes to the permits are noted in the cover letters. If you have any questions or comments,
please call me at(919)-733-5083, extension 517.
Respectfully,
4wa�, 14. 97V64�/X__
David A. Goodrich
NPDES Unit Supervisor
cc: Central Files
Permit Files
Winston-Salem Regional Office
Asheville Regional Office
Karen Rust