NC0025381_staff comments_20000830

Re: Question about the Broad
Subject: Re: Question about the Broad
Date: Wed, 30 Aug 2000 15,33:56 -0400
From: Tom Belnick <[e-mail]>
To: Deanna Doohaluk <[e-mail]>
Deanna- A couple of thoughts here.
• I checked the old Wasteload Allocation in the NPDES permit file (NC0025381). The IWC was
calculated at 19% based on a s7Q10 flow of 6.6 cfs. File notes indicate the s7Q10 value was
provided by USGS based on drainage area calculations (i.e., not based on any type of minimim
release).
• This facility has a permit requirement for continuous flow recording. If you check the monthly
discharge monitoring reports in our Central files, you could see whether the facility has been
discharging on a regular basis (as opposed to the citizen claim that they are holding back effluent
discharge for several days).
• They have weekly effluent fecal coliform limit. I don't see how holding back flows would help,
since they must meet this effluent limit prior to any stream dilution. It would really only help them if
they were required to collect instream fecal coliform samples, and wanted to dilute those numbers.
But the permit does not require them to collect instream samples.
• The NPDES Unit would be concerned if the dam release was withheld and streamflow fell below the
s7Q10 value, since the effluent permit limits for ammonia and BOD5 are based on this s7Q10 value
as a minimum flow. Old file notes reported that although this is non jurisdictional, the Division of
Water Resources could ask Dam Safety to put a requirement for minimum now in the Dam Safety
permit. Not sure if this was done.
• You mentioned Roger- have you discussed with Roger Edwards of the Asheville Regional office?
It looks like this county is under him.
• I'm still not sure who the NPDES basin coordinator is here. However, since this permit was issued
in 11/98 and won't expire until 8/31/03, probably no one will be taking a hard look at it until we get
close to renewal time.
• Let me know if you have further questions.
Deanna Doohaluk wrote:
Tom:
Here is the email to follow-up what I spoke to you about after the NPDES
training session regarding the Lake Lure Dam and Lake Lure WWTP. Please
pass this along to who on your staff is handling the Broad River Basin.
Last week a citizen called to report a potential problem with the Lake
Lure Dam located on the Broad River in Rutherford County. Currently,
there is no minimum flow requirement for the dam other than to meet a
flow of 6.6 cfs (the 7Q10) at the Lake Lure WWTP downstream. He reports
that the Dam operator and the Lake Lure WWTP operator are one in the
same and the WWTP and the WWTP is having trouble with fecal coliforms (6
recent violations). According to the citizen in order to help alleviate
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Re: Question about the Broad
the pressures of future violations, the dam and the WWTP are holding
back their releases for several days and releasing them together at
night. The releases are causing strong nasty odors in the River.
I have been speaking to Fred Tarver about conducting a minimum flow
study for the dam but a multitude of obstacles have been found. The
main obstacle is that the Dam is non jurisdictional and in order to a
minimum flow to be set, DWQ needs to show the need for such a measure.
I am working with the regional office on gathering this information. I
wanted, however, to check with you at NPDES for some insight and
information. What is the IWC for the WWTP? Is it based on a river
flow of 6.6 cfs? Has the facility requested any upgrades or expansions?
Is there any other information we should be aware of is pursuing a
minimum flow study and its potential affects on the WWTP? Any
information you can provide me with would be very helpful.
Thank you for your time and I look forward to speaking to you soon,
Deanna Doohaluk
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
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