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HomeMy WebLinkAboutNC0080098_staff comments_20180510Weaver, Charles From: Davidson, Landon Sent: Thursday, May 10, 2018 11:56 AM To: Weaver, Charles Cc: Hennessy, John Subject: RE: review of limits for NCO080098 Great summary and analysis Charles. I'm really familiar with the facility and especially the ND permit. I concur with your conclusion and we will work the facility in that direction. Thanks again for taking the time to capture the history and how you arrived at the position. 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, 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: Weaver, Charles Sent: Thursday, May 10, 2018 11:50 AM To: Davidson, Landon Cc: Hennessy, John Subject: RE: review of limits for NCO080098 Landon - NCO080098 was originally permitted so that wastewater could be discharged when on -site disposal [irrigation] was unavailable. The WWTP was designed and built to meet reuse limits. I've attached the original wasteload allocations from the 1990s so you can see how the limits were developed. The facility was first issued a permit in 1992. From then until 2003, they received 2 civil penalties. However, there was storm damage from Hurricanes Frances & Ivan. McGill submitted a Preliminary Engineering Report in October 2004 that addressed the damage, as well as the cost of repairs to the reuse system. There's nothing further in our file about repairs. The facility changed owners five times after the storm damage [2005; twice in 2007; 2010; 2011]. The reuse permit was rescinded in 2010. Since 2004 the facility has operated in a manner that doesn't match its original design. Given the low flows, they shouldn't be discharging at all - the reuse system should be handling the wastewater. Since the reuse system was damaged, they have received 23 civil penalties. The loss of the reuse system is the source of their compliance woes. The constant switching of facility owners hasn't helped. Any request from the permittee to re-evaluate limits would require an updated EAA, and an explanation for why the reuse system was abandoned. Unless they have new streamflow data, or some other basis to change the limits, we can't relax them: Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(I) prohibit backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL limits, or WQBELs may be less stringent based on updated RPA or dilution). The permittee would spend their money most wisely by repairing and reactivating the reuse system. CHW -----Original Message ----- From: Davidson, Landon Sent: Wednesday, May 09, 2018 2:48 PM To: Weaver, Charles <charles.weaver@ncdenr.gov> Subject: RE: review of limits Thanks Charles, Linda will contact you direct about the Candler Travel facility. She has verified that the discharge is piped to a DOT culvert that runs under the highway to a UT to Georges Branch. She says there is another WWTP in the same area with similar location with different limits. Regarding Linville, I seriously doubt they will be built out anytime in the future or perhaps ever. Does this create options? Tiered limits based on flow increase? Thanks, I realize this is extra work but we are really trying to hard to reduce violations in the region, primarily through solid enforcement, inspections, ORC board referrals but also being fair enough to re-evaluate some WWTP limits. 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@ncdenr.gov 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. -----Original Message ----- From: Weaver, Charles Sent: Wednesday, May 09, 2018 8:22 AM To: Davidson, Landon <landon.davidson@ncdenr.gov> Subject: Re: review of limits NC0085952 (Candler Travel) discharges to a zero -flow tributary. Extending the outfall line to the mainstem of the French Broad would probably get them relaxed limits. NC0080098 (Linville Falls) is trickier. They discharge directly to the N Fork Catawba, but it's a trout stream. The tighter limits are probably to protect trout, and also because they have an expansion phase of 0.202 MGD. I'll have to review the file and see why the existing limits were set where they are. CHW Messages sent to or from this address are subject to the North Carolina Public Records Law. From: Davidson, Landon Sent: Tuesday, May 8, 2018 3:35:04 PM To: Weaver, Charles Subject: review of limits Charles - Linville Falls and Candler Travel Plaza are two facilities where staff are concerned that the limits may be too restrictive. Linville Falls has had a technical assistance review and found no recommendations. I've also have Dan Boss review the operation and he generally agreed that it could be difficult to meet the permit limits. With regard to Candler, Linda believes the discharge may actually be to a larger stream than the permit indicates. An thoughts on how to approach a potential re-eval. of these two facilities? 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@ncdenr.gov<maiIto: Landon. Davidson@ncdenr.gov> 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.