NC0086070_staff comments_20191023

Weaver, Charles
From: Boss, Daniel J
Sent: Wednesday, October 23, 2019 2:27 PM
To: Weaver, Charles
Subject: RE: tiered permit for the Western Justice Academy
Thanks Charles,
That's a good point about the flow meter argument, it's a double edged sword.
Daniel Boss
Environmental Specialist- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
From: Weaver, Charles
Sent: Wednesday, October 23, 2019 2:25 PM
To: Boss, Daniel J <[e-mail]>
Subject: RE: tiered permit for the Western Justice Academy
Dan — have them request the tiered flow arrangement with their permit renewal application. We might be able to re-
insert the lower flow at renewal, but not before then.
Also, the "maybe the flow meter was wrong" argument goes both ways — what if they've been under -reporting flow for
all this time, due to a faulty meter? If McGill thinks the meter was malfunctioning, they'd better be sure it's working
before they ask for a lower flow tier.
CHW
From: Boss, Daniel J
Sent: Wednesday, October 23, 2019 11:19 AM
To: Weaver, Charles <[e-mail]>
Subject: tiered permit for the Western Justice Academy
Hi Charles,
Western Justice Academy, NC0086070 has a tiered permit that is triggered when the monthly flow average gets above
0.010 MGD. That did happen April -June of 2017, but those months are definitely outliers and there is some question as
to whether the flow meter may have malfunctioned.
Julia Byrd from McGill Associates called asking me if there was any way to get the facility back under the lower flow
limits, since it has been two years without any flows close to April -June of 2017. 1 know that the permit is clear that
once the monthly flow average exceeds 0.010MGD then the tighter limits are supposed to be in effect until the permit

expiration, but as I said the high flows in spring of 2017 seem to be outliers and Julia seemed to believe the flow meter
may have been malfunctioning.
Thanks for any input/advice you can give.
Daniel Boss
Environmental Specialist- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778