NC0036641_Wasteload Allocation_20160406

Sledge, Bob
From: Davidson, Landon
Sent: Wednesday, April 06, 2016 7:34 AM
To: Sledge, Bob; Rodriguez, Teresa
Subject: RE: Fletcher Academy meeting
Thank you Bob and Teresa. This will be very helpful in moving forward. I'll keep you posted.
Landon
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Sledge, Bob
Sent: Wednesday, April 06, 2016 6:32 AM
To: Davidson, Landon <[e-mail]>; Rodriguez, Teresa <[e-mail]>
Cc: Heim, Tim <Tim.Heim @ncdenr.gov>
Subject: RE: Fletcher Academy meeting
Hi Landon,
Teresa was kind enough to run the Level B model again, based upon inputs that existed in the file. The results of this
new run of the model indicated that the discharge from the site at the current permit limits for BOD and NH3 should not
have a detrimental effect on the receiving stream in terms of removal of dissolved oxygen. Therefore, if the facility was
to put in a new WWTP at the same flow limits, the only changes that would need to be made to the permit would be to
lower the TSS limits from their current levels (90 & 135 mg/L) for lagoon discharges to the standard 30 & 45 mg/L
concentrations for monthly average and daily maximum.
They should be made aware that if they would desire to expand the plant and increase discharge capacity, they would
be subject to the permitting strategy for the Mud Creek watershed and would have limits of 10 mg/L for BOD, 2 mg/L for
NH3, and 6.0 mg/L for D.O. imposed. I'm still surprised that this is presented as an issue unless they were thinking we
were looking at very low potential limits. I can't imagine they'd consider installing a WWTP that wouldn't be designed to
consistently meet 10 mg/L BOD and 2 mg/L NH3; contemporary, well run package plants typically perform much better
than that. If they'd be installing a 0.1 MGD package plant, I'd expect it to be of such design as to discharge a very high
quality effluent, and not simply meeting permit limits.

If there is some concern that the discharge from the hospital is something more than just domestic flow, and that it may
be affecting the treatment performance in the existing system, it would probably affect any other plant they may
install. At some point (if it hasn't been done already), it may be beneficial for them to do some type of comprehensive
analysis of the flow from the hospital to let them and us know what they're dealing with.
Have a fine day up there!
Bob
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Davidson, Landon
Sent: Wednesday, March 30, 2016 7:59 AM
To: Sledge, Bob <[e-mail]>; Berry, Ron <[e-mail]>; Rodriguez, Teresa
<Teresa.Rodriguez@ ncdenr.gov>
Cc: Heim, Tim <[e-mail]>
Subject: RE: Fletcher Academy meeting
Thanks Bob, no rush here. Let's just discuss when you return. I'm in field all day today but in Thursday and Friday.
Landon
G. Landon Davidson, P.G.
Regional Supervisor —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson d)ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, KC. 28711
: Nothing Compares.-�.n.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Sledge, Bob
Sent: Wednesday, March 30, 2016 7:04 AM
To: Davidson, Landon <[e-mail]>; Berry, Ron <[e-mail]>; Rodriguez, Teresa
<Teresa.Rodriguez@ ncdenr.,gov>
Cc: Heim, Tim <[e-mail]>
Subject: Re: Fletcher Academy meeting
Good Morning,

I'm sorry I missed your note yesterday. We were visiting with my in-laws during the day and I didn't see the
message until late in the evening.
I'm not sure what we can do in a concrete fashion very quickly. As we noted last year, Tom Belnick's crew
would have to examine the record and work on the model to establish any new limits that would be imposed
with construction of a new WWTP. Just from recollection, I don't think they'd be looking at anything a well
run, contemporary package plant couldn't provide, but a closer look at the waste stream from the hospital
may lead us to include additional monitoring parameters.
I don't have access to any of the files here. I believe they're in my office (somewhere). I'm copying Teresa
Rodriguez and Ron Berry on this. Perhaps they can find the files and look at them and come up with some
ideas. Unfortunately, I'm going to be busy today beginning in just a few minutes trying to burn the debris that
fell in our ice storm. this will be my only chance this week to do it and do it safely. I'll get back in touch.
should be able to talk sometime tomorrow, because the forecast is for rain by midday.
hope all is well with you and yours. Talk to you soon.
From: Davidson, Landon
Sent: Tuesday, March 29, 2016 9:44 AM
To: Sledge, Bob
Cc: Heim, Tim
Subject: FW: Fletcher Academy meeting
Bob -
Sorry to pound your Inbox while you are out. We are in need of further refinement (i.e., assurance) in obtaining permit
limits for the Fletcher Academy. This will allow their engineers to further refine design and costs related to installation of
a new WWTP. Fletcher Academy will in the coming weeks submit a letter to County Comm. indicating the amount they
can afford to contribute toward running a County sewer line. Currently, Fletcher and the County appear to be about
$500K apart on making connection happen. That said, Fletcher Academy is wanting to look very hard at what their
permit limits would be for a new facility given the costs involved with connection (i.e., running line, connection fees,
etc.).
We would do a quick conference call no this provide further detail perhaps but to refine their costs, they are wanting
hard permit limit estimates. I really feel the connection to County sewer will ultimately workout but we have to be
prepared for Plan B.
Thanks Bob. Let me know when we all three can discuss. The challenging part is that this discharges to a 303(d) listed
stream and is a fairly large hospital attached to it.
Landon
G. Landon Davidson, P.G.
Regional Supervisor— Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson (cDncdenr.gov

2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Nothing Compares.. —
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Wednesday, November 18, 2015 8:56 AM
To: Heim, Tim <Tim. Heim@ ncdenr. ov>
Subject: RE: Fletcher Academy meeting
Yes, go ahead with a summary. At some point, they'll need to move forward with the information they have and perhaps
simply use alternative costs estimates based on potential additional treatment. Thanks.
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson(c)ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Kfc- .
�'Nothing Compares, --,-
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Heim, Tim
Sent: Wednesday, November 18, 2015 8:44 AM
To: Davidson, Landon <[e-mail]>
Subject: FW: Fletcher Academy meeting
FYI,
What do you think about me sending Fletcher's Engineer a summary of the below, and letting him decide if he wants to
do a budgetary estimate based on the conservative permits numbers now, or wait until he gets the revised model results
(he could also do a budgetary estimate based on both permit limit potentials now and see which one he ends up with).
That way he has as much lead time to get started as we can provide.
I also asked Sledge what kind of timeframe we are looking at for the revised model.
-T
4

Tim Heim, P.E.
Environmental Engineer —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Noth€rtg Compares »,..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Sledge, Bob
Sent: Wednesday, November 18, 2015 8:34 AM
To: Heim, Tim <[e-mail]>
Subject: RE: Fletcher Academy meeting
Hi Tim,
The big issue in looking at potential limits in this case will be with regard to TSS. Currently the permit includes old
categorical limits for lagoon systems (90 mg/L monthly average & 135 mg/L daily maximum). With a new system
installed, these would surely go down to 30 & 45 mg/L.
The rest of the matter isn't so clear. We have data from an old model developed when the facility once asked for
expanded flow that just looks odd. It is recommended that we rerun the model to get a better idea of what the BOD and
ammonia limits ought to be. It could be that the existing limits for each would still work. However, file data shows we
had implemented a permitting strategy at some point in the past for new and expanding discharges into Mud Creek and
its tributaries that capped BOD and ammonia limits at 10 &2 as monthly averages. This was in response to observed
problems in the watershed, perhaps exacerbated at the time by Hendersonville's discharge. Mud Creek is still 303d
listed. I haven't looked at Fletcher's data. I know they've had recent compliance problems and there's historical
reference to low DO in the receiving stream (Byers Creek). Even though I don't hear that they want expanded flow,
there's a chance those limits may come into play here.
We're going to rerun the model and see what it says. I don't know exactly when that will happen, but it shouldn't be as
difficult as some because we have existing inputs, and maybe can be done sooner rather than later. In the meantime, I
personally don't think it would be unreasonable under the circumstances to tell their consultant that they ought to
initially aim for the stricter limits. For contemporary package plants, those limits shouldn't be a problem to
meet. Additionally, I don't know if at some point we'd want to re -characterize the wastewater coming to the
WWTP. The facility serves a hospital; though the flow is said to be 100% domestic, I'd be curious about other stuff that
might get poured down drains, etc.
It's not much of an answer. Hopefully there'll be more to come. I don't want to give anyone artificial bad news, but I'd
also like to encourage them to pursue the connection as much as possible.
Thanks for your patience.

Bob
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Heim, Tim
Sent: Monday, November 16, 2015 2:52 PM
To: Sledge, Bob <[e-mail]>
Subject: FW: Fletcher Academy meeting
Bob,
I've been in and out of interviews all day, and am off tomorrow, but we wanted to get your input on the situation below
and the permit limits a package plant for Fletcher might need to consider in the design (for a budgetary estimate).
I can explain further if you want more context.
Hope all is well.
-Tim
Tim Heim, P.E.
Environmental Engineer —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
email: tim.heim(&ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
�.': 3othing Compares---.,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Will Buie f mailto:[e-mail]]
Sent: Tuesday, November 10, 2015 11:28 AM
To: Davidson, Landon <[e-mail]>
Cc: Heim, Tim <[e-mail]>; 'Gary Carlson' <[e-mail]>
Subject: RE: Fletcher Academy meeting
Landon and Tim,
Thank you for your time this morning. To quickly summarize our discussion:
-FAI's Board has authorized Gary Carlson to enter into negotiations with Henderson County about connecting to the Cane
Creek sewer system.
-Gary and I have met with the County (Marcus Jones) to discuss the connection and a contribution by FAI to the cost of
the sewer extension.

-This informal offer has been discussed with County staff.
-Based on the pending merger between Cane Creek and MSD, Marcus has presented the project to MSD. The County
wants to make sure MSD is aware of the project along with the fact that the County/District would have to borrow money
to fund a large portion of the sewer extension.
-MSD has requested water usage information from FAI, and that will be provided this week.
-Henderson County has indicated the next step in this process is for FAI to present a formal written request to connect to
the Cane Creek sewer system. With this request, FAI would provide their offer of a contribution to the cost of the sewer
extension. This contribution should ideally be based on the estimated cost for any other alternative for wastewater
treatment and disposal.
That leads to our request to you. As we discussed in our meeting in late August, we believe the construction of a package
treatment facility is likely the next best option for FAI. To provide a cost estimate for this option, we will need some
indication of the discharge limits that might be considered by DEQ. At this time, any information on discharge limits would
be used only for cost estimating purposes.
Once we have some idea of discharge limits, we will prepare a cost estimate for FAI. They will use this cost estimate to
prepare their formal offer of a contribution to the sewer line extension.
Feel free to contact me if you have any questions.
Thanks,
Will
William R. Buie, P.E.
WGLA Engineering, PLLC
214 N. King Street
Hendersonville, NC 28792
(828) 687 - 7177 ext. 302
wbuie(o-)wgla.com
From: Davidson, Landon [mailto:landon.davidson ncdenr. ov]
Sent: Friday, August 28, 2015 4:58 PM
To: Will Buie (wbuie(&wgla.com); dwackCafletcheracademy.com
Cc: Heim, Tim; Price, Bev
Subject: Fletcher Academy meeting
Thank you for providing us with additional information regarding options for the subject facility. I've attached a template
for a compliance agreement which is one potential tool with regard to covering the facility under an EPA recognized
agreement while we continue to evaluate options. As stated in the meeting, an SOC is premature at this phase simply
because we do not have an agreed up option to pursue. Please understand that the Division has not yet agreed to a
compliance agreement at this time but it is an option we are evaluating. Additional penalties and notices may be levied
based on continuing violations. A compliance agreement typically includes a penalty for non-compliance and usually
requires compliance or application for an SOC at the termination of the agreement. To formulate an agreement, we
would need to incorporate specific milestones into the document which may also be a challenge to draft at this phase
but perhaps in the coming month(s).
Tim is continuing to explore the other items on our list with regard to funding and potential limits if a new NPDES permit
or modification were sought. A very preliminary discussion suggests reductions to the following limits: BOD —10 and TSS
30/45. Please do not use these numbers for any evaluation or calculations at this time as these are very preliminary.
Please also understand that our preferred option is connection to municipal sewer. The Division will continue to support
your efforts moving toward that goal.
Sincerely,
Landon

G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.org
Need help with other DENR permits? http://portal.ncdenr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law
and may be disclosed to third parties.

IWC Calculations
Fletcher Academy
NC0036641
Prepared By: Bob Sledge, C&EP Unit
Enter Design Flow (MGD): 0.1
Enter s7Q10(cfs): 0.56
Enter w7Q10 (cfs): 0.9
Residual Chlorine
Ammonia (NH3 as N)
(summer)
7Q10 (CFS)
0.56
7Q10 (CFS)
DESIGN FLOW (MGD)
0.1
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
0.155
DESIGN FLOW (CFS)
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (t
0
UPS BACKGROUND LEVEL
IWC (%)
21.68
IWC (%)
Allowable Conc. (ug/1)
78
Allowable Conc. (mg/1)
Ammonia (NH3 as N)
(winter)
0.56
0.1
0.155
1.0
0.22
21.68
3.8
7Q10 (CFS) 0.9
Fecal Limit 200/100ml DESIGN FLOW (MGD) 0.1
(If DF >331; Monitor) DESIGN FLOW (CFS) 0.155
(If DF <331; Limit) STREAM STD (MG/L) 1.8
Dilution Factor (DF) 4.61 UPS BACKGROUND LEVEL 0.22
IWC (%) 14.69
Allowable Conc. (mg/1) 11.0
INPDES Servor/Current Versions/IWC
11 /18/2015

2014 AU Number: I AU Name:
AU Description:
French Broad River Basin
AU Length Area: j AU Units: I Classification:
6-96-10b Little Ivy Creek (River) 2.1 FW Miles WS-II;HQW
From State Route 1547 to Ivy Creek
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d) yr:
5 EC Fecal Coliform (GM 200/400 5 in 30, REC, FW) 2011 2014
6-96-10a Little Ivy Creek (River) 2.6 FW Miles WS-II;HQW
From California Creek to State Route 1547
RCategory: ACS: Parameter Of Interest:
5 EC Fecal Coliform (GM 200/400 5 in 30, REC, FW)
Collection Year: 303(d) yr:
2011 2014
6-54-(1)b
Mills River
1.8 FW Miles WS-II;Tr,HQW
From River Mile 1.03 to a point 0.5 mile upstream of N.C. Hwy. 191
IRCategory:
ACS: Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC pH (6 su, AL, FW)
2012
2012
6-55c1
Mud Creek
7.4 FW Miles C
From Little
Mud Creek to Clear Creek Byers Creek
IRCategory:
ACS: Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC Benthos Fair (Nar, AL, FW)
2000
2006
5
EC Fish Community Fair (Nar, AL, FW)
2002
2006
6-55c2 Mud Creek 3.6 FW Miles C
From Clear Creek to Byers Creek
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d) yr:
5 EC Fish Community Fair (Nar, AL, FW) 2002 2006
5 EC Benthos Fair (Nar, AL, FW) 2000 2006
6-55b Mud Creek 1.9 FW Miles C
From State Route 1125 to Little Mud Creek
RCategory:
ACS:
Parameter Of Interest:
Collection Year:
303(d) yr:
5
EC
Benthos Fair (Nar, AL, FW)
2007
1998
5
EC
Fish Community Poor (Nar, AL, FW)
2002
1998
6-84d
Newfound Creek
From State Route 1378 to Dix Creek
IRCategory: ACS: Parameter Of Interest:
5 EC Benthos Fair (Nar, AL, FW)
6-84b Newfound Creek
From State Route 1296 to SR 1297
4.4 FW Miles C
Collection Year: 303(d) yr:
2007 1998
1.3 FW Miles C
RCategory: ACS: Parameter Of Interest: Collection Year: 303(d) yr:
5 EC Benthos Fair (Nar, AL, FW) 2002 1998
Friday, February 21, 2014 draft 2014 NC 303(d) List -Category 5 assessments requiring TMDLs Page 31 of 148