McDowell Co. - Lake James Environmental Association

PHONE:
N..>_C...DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
ASHEVILLE, NORTH CAROLINA 28801
828/251-6208 FAX: [phone]
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FROM:
DATE:
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MESSAGE: If questions, please call 828/251-6208.
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G.M ` D c 'GVLG ` D
ATTORNEYS AT LAW ^
LAMAR GUDGER
Of Counsel
V.LA^ ,r'11 "'
CAROL L. GOINS
Honorable Everette Clark
Mayor, City of Marion
200 North Main Street
Marion, North Carolina 28752
Re: Lake James
Dear Mayor Clark:
ASHEVILLE, NORTH CAROLINA
TELEPHONE: [phone]
F;,,:S.MILE: [phone]
E-mail: [e-mail]
January 8, 2001
MAILING ADDRESS:
P.O. Box 336
ASHEVILLE, NC 28802
STREET ADDRESS:
ONE OAK PLAZA, SUITE 306
ASHEVILLE, NC 28801
My client, the Lake James Environmental Association (LJEA), wants to protect
the water quality of Lake James while promoting economic growth in McDowell
County. LJEA has asked me to investigate the potential impact of the Pleasant
Gardens Elementary School sewer line expansion and related development.
Enclosed is a report on- the fragility of the Lake James and 'Catawba River
ecosystem by Dr. Richard Maas. As you know, Professor Maas heads the
Environmental Studies Institute at the University of North Carolina at Asheville, and
has studied Lake James for many years.
Dr. Maas concludes that even minimal changes in effluent discharge could
destroy Lake James as a cold water fishery.
The Lake James Environmental Association has also been :informed that
McDowell County plans to locate a drinking water intake plant on Lake James near Big
Island. My client does not understand why a drinking water source is being
threatened by increased industrial and commercial waste water discharges.

We would like to meet with you to discuss the future of Lake James at our
earliest mutual convenience. Thank you for considering Dr. Maas's latest report.
Very truly yours,
V '
- - V. Lamar Gudger, III
VLG/ra -. -- -
cc: Mike Thompson, Chairman, McDowell County Commissioners
Larry Frost, North Carolina Department of Environment and Natural Resources
Brian Cole, State Supervisor, United States Fish & Wildlife Service
Enclosures

An Assessment of the Tt-ophic Status
and Quality of Lake James and the
Projected Impact of Increased Treated
Wastewater Discharges
Richard P. Maas, Ph.D.
Research Director, UNC Asheville
Environmental Quality Institute
November 8, 2000

I. INTRODUCTION AND BACKGROUND
The ENVR 321 - Limnology class from the Department of Environmental
Studies at UNC Asheville has conducted water quality field studies at Lake James
during September of most years since 1988 under the direction of Dr. Richard P .
Maas. These studies have been conducted almost exclusively on the Catawba River
portion of the lake and have focused on measuring and interpreting standard
limnological parameters including dissolved oxygen, temperature, pH, CO2, available
phosphorus, ammonia, turbidity, secchi transparency, faunal color scale, sediment
phosphorus concentrations, zooplankton identification from the entire depth profile
of the lake as appropriate.
The purpose of the present assessment is to integrate these annual lake study
results in terms of the possible effects on the ecosystem health of the lake from
proposed additional treated wastewater discharges from the Catawba WWT P
draining into the upper end of the Catawba portion of Lake James.
II. CURRENT TROPHIC STATUS OF LADE JAMES
Figure 1 on the next page shows the average temperature and dissolved oxygen
(DO) depth profile for Lake James in early September over the past decade. In some
years greater oxygen deficits have been observed and in some years there is less of an
oxygen deficit. No clear trend with time has yet been observed, probably because
annual summer weather variability is generally the most influential factor. As can be
seen from Table 1, oxygen concentrations drop drastically between 6 and 10 meters
depth corresponding to the beginning of the temperature thermocline at about 8
meters depth. The DO generally decreases to less than 2 parts -per -million (ppm)
between 9 and 12 meters and then begins to recover with greater depth. In most, but
not all, years the DO recovers to levels above 4 ppm between about 15 m and 24 m
depth. Near the bottom the DO decreases again, presumably due to the influence
of organic, oxygen -demanding sediment material.
Although the exact amount of dissolved oxygen necessary to insure fish survival
varies with species, generally 4 ppm is considered a critical minimum concentration
for long-term viability. Most species can survive somewhat lower concentrations for
periods up to several days. From Figure 1 it can be seen that typically the DO rises
somewhat above 4 ppm between 15 and 24 m during September of most years. This
is critical for the overall biological health and integrity of Lake James. Cool water fis h

species (e.g., trout, small -mouth bass, walleye) must be ably. Lo move to the deeper
colder waters of a lake during summer to avoid respiratory stress and disease.
Already, there is a section of the lake between about 9 and 13 meters where fish can
not survive because of low DO, and the only viable cool -water habitat is between 15
and 24 m.
The observed oxygen deficit (DO deficit = DO conc. at saturation - DO actual
observed) is caused primarily by organic matter being decomposed by aerobic bacteri a
which use up oxygen in this process and release CO2. It is not uncommon for WNC
reservoirs to show a large oxygen deficit across the thermocline (i.e., 8-15 m) in late
summer and autumn from bacterial decomposition of organic matter. This organic
matter tends to build up in the thermocline layer as a result of: 1) stream inputs to
the lake (stream water in summer is generally warmer and less dense than th e
hypolimnion (i.e., bottom) water and colder and more dense than the epilimnion
(i.e., surface) water; and thus this water and the organic materials it carries are spread
across the lake at the thermocline depths. 2) Algae and zooplankton which slowly
sink from the photosynthetic zone in the epilimnion to die and be bacterially
decomposed in the thermocline region. The amount of algae which grow in the
surface water and eventually sink to the thermocline to use up oxygen is ultimately
dependent on the amount of nutrients from treated wastewater discharges, shore line
development .activities, farmland, and other sources which reach the lake.
If the organic inputs are relatively low, and the lake is deep with a large
hypolimnion, most of this oxygen -utilizing decomposition will occur in th e
thermocline region, and the relatively small amount of remaining organic material
which sinks to the hypolimnion will have only a relatively minor impact on the DO
levels there. In the case of Lake James, it can be seen from Figure 1, that nearly all
of the oxygen in the thermocline is used up and that the additional decomposition
in the hypolimnion has almost pushed the DO levels there to levels which will
eliminate cool -water fish species from the lake ecosystem. It should be noted that th e
reoxygenating fall turnover generally does not occur in Lake James until late
November, and thus the thermocline and hypolimnion DO conditions probably
become even more critical later in September and in early October. (By late October,
surface water temperatures are cool enough for cool -water fish species to return to the
oxygenated epilimnion.)
2

III. ASSESSMENT OF THE IMPACTS OF INCREASED VOL UMES OF
TREATED WASTEWATER DISCHARGES
As noted above and illustrated by Figure 1, the current nutrient and organic
material loading to the Catawba side of Lake James has already pushed the lake close
to the boundary of maintaining a cool water fishery habitat and ecosystem. In most
other regards, the lake quality seems to be sufficiently high to support other intended
uses.
A. Dissolved Oxygen Effects
The proposal to add the Pleasant Gardens School to the load of the Catawba
Plant would add about 10,000 gal/day (gpd) to the current 80,000 gpd discharge
from the plant (i.e., a 12.5% increase). If other facilities, such as Crane Resistoflex,
Tom Johnson Camping Center, etc., are added on, the percentage of discharge
increase would be much larger, perhaps as much as doubling the current discharge.
The calculated effects described below will be assessed for three possible scenarios:
1) Pleasant Gardens School addition only, 2) additional line extension tie-ins totaling
80,000 gpd, and 3) an increase of treated waste discharge to a total of 250,000 gpd.
Any additional discharge from the Catawba plant could adversely affect Lake James
in two ways: 1) Extra oxygen -demanding organics would be added directly to the
thermocline area of the lake which is already very oxygen depleted during the
summer and early fall. Some of this material would sink and cause more oxygen
depletion in the already borderline cool -water fish habitat in the hypol imnion of the
lake. 2) The additional effluent would add substantial additional phosphorus to the
lake over the years which would produce more algal biomass and consequently more
oxygen demand on the thermocline and hypolimnion portions of the water column.
Some approximate calculations to semi -quantify the impacts are shown below:
1. Pleasant Gardens School only (12.5% increase)
a. 10,000 gpd at 30 mg/L BOD for the period of April 15 to October 15
each year spread over the 3,000-acre Catawba portion of the lake:
206 I<g of Oz demand = 20 in of water over 3,000 acres equals a loss
of dissolved oxygen of only about 0.001 mg/L, which is negligible by
itself.
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b. phosphorus loadings causing more algal growth and subsequent DO loss:
10,000gpd x2 mgP/Lx365 days = 27.6 Kg P/yr x 500 g of
biomass/gP = 13,760 Kg of biomass, which when decomposed
consumes 12,900 I<g of 02. This translates to a total oxygen deficit of
about 0.054 mg/L, of 02 over bottom 20 meters of the lake.
Thus, only a small, just barely noticeable, decrease in thermocline and
hypolimnion oxygen levels would be expected from just the addition of
the Pleasant Gardens School. By itself, this would only shift the DO
profile graph in Figure 1 slightly to the left.
2. Assessment assuming Pleasant Gardens School plus various industries and
subdivisions (i.e., a doubling of the current Catawba Plant discharge from
80,000 gpd to 160,000 gpd).
a. Direct thermocline organic input: 02 demand increase = 0.0096 mg/L
b. Increased algal production from increased phosphorus input: 0.054 x
6.4 = 0.35 mg/L of 02 demand increase
Thus, the total additional 02 deficit = 0.36 mg/L. This represents a greater
impact on thermocline and hypolimnion DO levels, but is still not large.
Subtracting 0.36 mg/L from all of the data points shown in Figure 1 reduces
the remaining area of cool -water fish habitat from about 9 meters width (15
m - 24 m) down to only between 5.5 and 6 meters width, a significant
decrease. The actual biological effect could be critical in certain worse -than -
normal DO depletion years.
3. Assessment assuming an increase of average daily treated waste discharge to a
total of 250,000 gpd.
a. Direct thermocline organic input: 250,000 gal/day at 30 mg/L BOD
spread over the period 4/15 to 10/15 each year spread over the Catawba
portion of the lake translates to a loss of dissolved oxygen of about 0.02
mg/L. This would probably actually be about twice as great in the upper
end of the Catawba side of the lake and above half as great in the lower
4

half.
b. P-loading causing more algal growth and subsequent DO loss in
thermocline and hypolimnion.
0.054 mg/L per 10,000 gpd x 170,000 gpd additional = 0.92 mg/L DO
Total = 0.92 + 0.02 = 0.94 mg/L
Again, it could reasonably be expected that, due to the relatively slow
flushing rate of Lake James, the effect would probably be about twice as
great in the upper portion of the lake and perhaps only about half as
great in the lower portion of the lake. The effects of this wastewater
addition on the hypolimnetic dissolved oxygen levels, and subsequently
on the cool -water fishery habitat are illustrated in Figure 2. As can be
seen from Figure 2, the addition of this much treated waste and its
associated phosphorus would almost certainly eliminate - the fragile
remaining cool -water fishery habitat from the Catawba portion of Lake
James. Bear in mind that Figures 1 and 2 illustrate mean September
observed DO concentrations for the period 1990-2000. Some
individual years exhibited lower DO concentrations in the thermocline
and hypolimnion, which would already have stressed this fishery
substantially.
The effects of all three scenarios described above calculated above would be
more severe if the plant malfunctioned frequently at these higher input loads
and discharged more than its permitted BOD of 30 mg/L, although this would
probably be approximately counterbalanced by the periods when the discharge
was less than 30 mg/L BOD. Also, the calculations shown above are very
sensitive to the phosphorus (P) concentration used. Two mg/L is common for
such treatment plants, but an average discharge of I mg/L would half the
calculated effect and a 3 mg/L average discharge would increase it to almost a
0.52 mg/L DO reduction at a 160,000 gpd discharge, which would
significantly degrade the cool -water fishery habitat, and under the 250,000
gpd discharge scenario, the estimated hypolimnetic DO reduction is over 1.4
mg/L, which would almost without question quickly eliminate the cool -water
fishery habitat.
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B. Other Effects
1. The added P from the extra treated waste discharge would cause some extra
algal growth in the lake, which would lower the visibility and aesthetic appeal
of the lake somewhat. The effect of just the Pleasant Gardens School would
probably not be noticeable, but a doubling of discharge from the addition of
other sources would almost certainly be noticeable, and the effect of a 250,000
gpd discharge would be substantially noticeable..
2. As noted above, the calculations above consider the entire Catawba side of the
lake as a whole. The calculated effects would probably be greater in the upper
portion of the lake and somewhat less in the lower portion.
VI. SUMAIM RYAND CONCL USIONS
Overall, the addition of the Pleasant Gardens School to the Catawb a
Treatment Plant would by itself have a very minimal and just barely measurable
effect on Lake James. The tying in of other facilities to this line extension would
have a more noticeable, but still relatively moderate, impact on the dissolved oxygen,
cool -water fishery, and aesthetic/water clarity dynamics of the lake. An increase in
treated waste discharge at 30 mg/L BOD and 2.0 mg/L, phosphorous to 250, 000 gpd
would almost certainly destroy the remaining cool -water fishery habitats, at least in
the Catawba portion of the lake.
With the extensive shoreline residential development currently underway on
the lake, overall water quality conditions can be expected to decrease somewhat with
time even if no additional wastewater discharges were permitted. Any impacts from
additional treated discharges will combine with the additional effects of new shoreline
development to cause overall effects greater than calculated above.
Overall, Lake James is a relatively clean, clear, ecologically healthy lake whose
water quality currently supports all intended ecosystem, fishery, recreational an d
aesthetic uses. The most critical water quality parameter is the amount of
summer/fall dissolved oxygen in the thermocline and hypolimnion of the lake which
determines the viability of the lake to support a cool -water fishery. These conditions
are already borderline for supporting a cool -water fishery. Thus, the combined effect s
of increasing shoreline residential and golf course development along with additional
treated waste discharge would probably combine to push the cool -water fishery
6

habitat out of existence in Lake James, converting it to a strictiv warm -water fishery
as seen in all the lower -elevation downstream lakes in the Catawba River system,
especially if treated discharges increased to 170,000 or 250,000 gpd. Clearly, if
preserving the cool -water fishery habitat is a priority, then any additional treated
waste discharges should be avoided if possible, and other upstream land use and land
protection control should be encouraged to lower phosphorus and BOD inputs.
If substantial increases in treated effluent volume from the Catawba plant were
to be permitted, the only way to avoid the above -described degradation of Lake Jame s
in terms of cool -water fishery habitat and water clarity would be to upgrade the
Catawba Plant. A lowering of its permitted BOD effluent limits would provide some
mitigation, but mainly the plant would need to have tertiary phosphorus removal
capabilities implemented. From the calculations above it would appear that an
effluent limit of about 0.7 mg/L total P would be needed if the plant discharge permit
was expanded to 0.25 MGD to protect the cool -water fishery and water clarity. '
7

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Tapoco-APGI - About Hydroelectric Project
Page 1 of 1
About
Hydroelectric
The Tapoco Project is a four -development hydroelectric project located in eastern
Tennessee and western North Carolina. The Tapoco Project is owned and
operated by APGI (the Tapoco division), a subsidiary of� j a�
Alcoa, and consists of four individual developments:
Santeetlah, Cheoah, Calderwood and Chilhowee. Three of
the dams, Cheoah, Calderwood and Chilhowee are located on the Little
Tennessee River between two Tennessee Valley Authority (TVA) hydroelectric
projects: Fontana (upstream) and Tellico (downstream). The fourth dam,
Santeetlah, is located on the Cheoah River, a tributary to the Little Tennessee
River.
About Tapoco-APGI I About Hydroelectric Project I Events I Relicensing News I Documents
http://www.tapoco-apgi. com/about-hydro/default. asp?locking=unlock
1 /4/2001

Larry Frost
C/o DENR
Asheville Regional Office
Division of Water Quality
59 Woodfin Place
Asheville, N.C. 28801
Re: 09/27/00 request for information
fli Larry,
New, Awd4 Cwx4aa .28761
www.main.nc.us/ljea=
00/
10/17/00
Thank you for your response to my last inquiry concerning the City of Marion's application for a new
discharge permit at their Corpening Creek WWTP.
While we had requested a complete copy of the new permit application, the documents you sent us
appear to be incomplete. Please check your files for a complete copy of this application. I have enclosed a copy of
the documents you sent for your reference.
As always, thank you for your help.
Cc: Gudger & Gudger, Forrest Westall
t
$e�rcGiedo die o� .L'rize �csHed �asc2 it'd i2.sEisy wuiti... _�`'?=. _—_ s.

I
CITY OF MA ION
P.O. Drawer 700
rip OFFICE OF THE
2
Marion, North Carolina 8752 CITY MANAGER
October 18, 1999
Mr. Charles H. Weaver, Jr.
NC DENR / Water Quality / NPDES_ Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Mr. Weaver:
Please find enclosed an executed original and two copies of the Renewal of
NPDES Permit NCO031879 for the Corpening Creek Waste Water Treatment
Plant.
If you need any further information, please feel free to give me a call at (828)
652-3551.
Thank you.
Sincerely,
J. Earl Daniels
City Manager
JED/dws
Cc: Nadine Blackwell
James Laux
Files
SENT CERTIFIED MAIL

NPDES PEE— IT APPLICATION - STANDAR FORM A
Municipal Facilities with permitted flows > 1 MGD or with pretreatment programs
State of North Carolina - Department of Environment and Natural Resources
Division of Water Quality - NPDES Unit
SECTION 1. APPLICATION AND FACILITY DESCRIPTION
Unless otherwise specified on this form all items are to be completed. If an item is not applicable indicate WN. .
North Carolina NPDES Permit Number NC00 31879 (if known)
1. Applicant and facility producing discharge
This applies to the person; agency, itrm, municipality, or any other entity that owns or is responsible for the permitted facility. This may or may not be the same
name'as the facility, or;activity,producing the discharge. Enter the name of the applicant as it is officially or legally referred to; do not use colloquial names as a
substitute for the official name.
Nameof applicant / permittee_
Mailing address:
Street address PO Box
City of Marion (Corpening Creek WWTP)
700
City. Marion County. McDowell
State North Carolina Zip Code 28752
Telephone Number (8 2 8 ) 6 5 2- 8 8 4 3
Fax Number (828 ) 652-1943
e-mail address
2. Mailing address of applicant's Authorized Agent / Representative:
Engineer/ Company name City of Marion
Street address PO Box 700
City Marion County__McDowell
State North Carolina Zip Code 28752
Telephone Number (828 ) 652-8843
Fax Number (828 ) 652-1943
e-mail address
3. Permitted Facility Location:
Give the physical location of the facility where discharge(s) presently occur(s) or will occur.
Street address Highway 226 South
City, ` Mar'i'.na'n 'Count y=_MrT)nwpll
State North Carolina Zip Code 28752
Telephone Number (8 2 8 ) 6 52 - 8 8 4 3
Fax Number (828 ) 65?-.l 9'43
e-mail address
4. Municipalities or Areas Served (see instructions
Enter the names of-ilie municipalities or areas served by this facility. For each municipality enter the best estimate of actual population served at the time of this
application.
Name of Community / Area Actual Population Served
'Marion'
Total Population Served -5000
t of 3

t IFDIrS PEk___1T APPLICATION - S'I'ANDAI. FORM A
Municipal Facilities with permitted flows > I MGD or with pretreatment programs
SECTION III. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL. SYSTEM
Submit a separate Section Ill, for each Significant Industrial User.
1. Significant Industrial User (SIU)
An SIU has (or could have) significant impact on the POTW receiving the wastewater or upon the quality of effluent from the receiving POTW.
Specifically, an SIU:
• has a flow of 50,000 gallons or more per average workday;
• has a flow greater than 5 percent of the total flow carried by the municipal system m receiving the waste, or
• has a toxic material in its discharge.
It may be necessary to alter these administrative criteria in certain cases, such as an instance where two or more contributing industries in
combination can produce an undesirable effect on either the municipal facility or the quality of its effluent.
Name of SIU Marion
Street address 700 Baldwin Avenue
City Marion County Mr -Dowel...
State North Carolina Zip Code 28792
Telephone Number (828 ) 652-3010
Fax Number ( )
e-mail address
Primary Product or Raw Material
Specify either the principal product or the principal raw material and the maximum quantity per day produced or consumed. Quantities are to be reported in the units
of measurement given in Table III for the particular SIC categories that are listed. Enter the letter -number code from the Code column in Table III for the units selected
under'Units ' Other SIC categories should use the units of measurement normally used by that industry.
Quantity
Units see SIC Table
Product H 1 Cloth, Synthetic
1,040,000
pounds
Raw Material
4. Flow
Indicate the volume of water discharged into the POTW and whether this discharge is intermittent or continuous
0 . 0 3 6 7MGD ❑ Intermittent ® Continuous
I certify that 1 am familiar with the information contained in this application and that to the best of my knowledge and belief such
information is true, complete, and accurate.
J. EARL DANIELS CITY MANAGER
Printed Name of Person Signing Title
or Authorized Agent
OCTOBER 18, 1999
Date Application Signed
North Carolina General Statue 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in any application, record, report, plan, or other
document files or required to be maintained under Article 21. or regulations of the Environmental Management Commission implementing that Article, or who falsities, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the EnvironmentalManagement Commission Implementing
that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (16 U.S.C. Section 1001 provides a punishment by
a mine or not more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.)
3of3

f'
i .
NPDRS PF y.UT APPLICATION - STANDA} • FORM A r
Municipal Facilities with permitted flows > 1 MGD or with pi _reatment programs
SECTION Ill. INDUSTRIAL WASTE CONTRIBUTION TO MUN➢C➢PAS, SYSTEM
Submit a separate Section Ill for each Significant Industrial User.
Significant Industrial User (SIU)
An SIU has (or could have) significant impact on the POTW receiving the wastewater or upon the quality of effluent from the receiving POTW.
Specifically, an SIU:
• has a flow of 50,000 gallons or more per average workday;
• has a flow greater than 5 percent of the total flow carried by the municipal system m receiving the waste, or
• has a toxic material in its discharge.
It may be necessary to alter these administrative criteria in certain cases, such as an instance where two or more contributing industries in
combination can produce an undesirable effect on either the municipal facility or the quality of its effluent.
Name of SIU Galey & Lord
Street address PO Box 250 (Highway 70 East)
City. Marion County. McDowell
State North Carolina Zip Code 28752
Telephone Number (828 )_652-1448 ext- 208
Fax Number ( )
e-mail address
3. Primary Product or Raw Material
Specify either the principal product or the principal raw material and the maximum quantity per day produced or consumed. Quantities an; to be reported in the units
of measurement given in Table Ill for the particular SIC categories that are listed. Enter the letter -number code from the Code column in Table III for the units selected
under'Un'tts.' Other SIC categories should use the units of measurement nomraliv used by that industry -
Quantity
Units see SIC Table
Product Corduroy, Flatgoods
24 million
pounds
Raw Material .
4. Flow
Indicate the volume of water discharged into the POTW and whether this discharge is intermittent or continuous
0.028 MGD Q Intermittent D Continuous
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such
information is true, complete, and accurate.
J. EARL DANIELS
Printed Name of Person Signing
or Auffionfied Agent
CITY MANAGER
Title
CTOBER 18, 1999
Date Application Signed
North Carolina General Statue 143-215.6 (b)(2) provides that: Any person who knowingly makes any lalse statement representation, or certification in any application, record, report, plan, or other
document riles or required to be maintained under Article 21 or regulations of the Environmental Management Commission Implementing that Article, or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing
that Article, shall be gully of a misdemeanor punishable by a tine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (16 U.S.C. Section 1001 provides a punishment by
a fine or not more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.)
3of3

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published by the Geological Survey
414
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n triC methods from aerial. Photographs SCALE
1962 MN
7 North American 'dalu GN 1000 0 1000 2000
m.X
orth Carolina coordinate system
,rse Mercator grid ticks.
27MILS, _2L3?:_ I
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DOTTED LINES REPRES I
Ite -selected fence and field lines where A) DATUM IS ME
10tographs. This information is unchecked UTM GRID AND 1962 MAGNETIC NORTH
rich only landmark buildings are shown DECLINATION AT CENTER OF SHEET /VW
THIS MAP COMPLIES WITH NATIOl
FOR SALE BY U.S. GEOLOGICAL S
A FOLDER DESCRIBING TOPOGRAPHIC MAP-,

-4 "1

CITY OF MARION
NPDES: NCO031879
SLUDGE MANAGEMENT PLAN
The City of Marion holds a Landfill Permit (Permit No. W00003698) issued by NCDENR.
The sludge is to dewatered by a vacuum filter and then sent to the land fill. During 1998,
187 dry tons of sludge was sent to the landfill.
The City of Marion also holds a Class A Distribution Permit ;(Permit No:. WQ0008681)
issued -by NCDENR'to pasteurize the sludge and distribute to the local residents to land
apply. During; 1998, 29 dry tons of sludge was produced and 32 dry.tons Was distributed
to the *local residents.

2a4e �asrtPil. Cssuvu3nowaW 4"ackdsosi, >' ow
AeGa, Aondi Ca4d"#M 28761
www.main.nc.us/ljea
Larry Frost
C/O DEh1R
Asheville Regional Office
Division of Water Quality
59 Woodfin Place
A h s ill" 'll TVC 28g01
let
Re: Corpening Creek WWTP permit
Hi L
COPY
Cg �.
09/27/00
arry,
As you are aware, the Corpening Creek WWTP permit expired last Spring. Officials
with DENR have assured me in the past that they expect to issue the permit soon.
Would you please provide us with a complete copy of the application for the new
permit?
As always, we appreciate your help.
Sincerel
K arris
/President, Lake James Environmental Association
/ Chair, Lake James State Park Advisory Committee
bed"" & 46 "J&W� a4 -014, Yam" afad it'd

ZaAze �G.owl Caarwaow rW 4"ocrdr;oot, .lost
/Ve,&, No2tt ea4olWa 2876f
www.main.nc.us/ljea
Larry Frost
C/o DENR
Asheville Regional Office
Division of Water Quality
59 Woodfan Place
Asheville, N.C. 28801
Re: 09/27/00 request for information
I-E Larry,
C •'
10/17/00
Thank you for your response to my last inquiry concerning the City of Marion's application for a new
discharge permit at their Corpening Creek WWTP.
While we had requested a complete copy of the new permit application, the documents you sent us
appear to be incomplete. Please check your files for a complete copy of this application. I have enclosed a copy of
the documents you sent for your reference.
As always, thank you for your help.
Cc: Gudger & Gudger, Forrest Westall
" l'e
`�e�ted to Ilse rveedvrc�fnsi a� 1'r%e a%rsr�a. assd it'd i2u�iu�.�✓uy u�ta�cd.... _~�__-- �1 ��� t�� i , _-- `-

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P.G. Baz *30
,Art DuttonWcDowell County Representative D
NC DENR
Asheville Regional Office �O�O
Division of Water Quality
59 Woodfin Place
Asheville, N.C. 28801 V
Re: Future increase of wastewater discharge, McDowell County
Dear Mron, 06/12/00
Thank you for responding to my inquiry of 01/14/00. Lake James Environmental is always interested in
point source discharges on the Catawba River above Lake James.
It has come to our attention that McDowell County and the City of Marion are considering a significant
increase in discharge at the Catawba River wastewater treatment facility near Garden Creek. This plant is
currently permitted to discharge at a rate of 250,000 gallons per day (GPD) and is now discharging an average of
about 80,000 GPD. The County/City plans would maximize daily output at this plant. In our annual inspection of
the plant last November LJEA reviewed records indicating recurring spikes in discharge at over 300,000 GPD.
The engineer in charge of the plant explained that these spikes in output occurred at any time it rained heavily
(this plant handles rainwater runoff for the entire "five -lane" commercial district). Therefore, if output were
maximized at 250,000 GPD, then during and after heavy rainfall this plant would »verflow raw sewage at a rate
of approximately 440,000 GPD directly into the Catawba River above Lake James! This overflow would be
completely uncontrollable. In November we asked the plant's engineer how the plant would fare if daily output
were upped to the maximum, and he stated that he would not advise running that high volume through that
particular plant.
Lake James Environmental Association agrees wholeheartedly that the Pleasant Gardens
community needs and deserves sewer service. We support the effort to provide the service to the
community. However, LJEA would assert that wastewater from this area should be collected and pumped just
one mile uphill, where it could be gravity fed through existing sewer lines to the Corpening Creek Wastewater
Treatment Plant. This plant is now operating at only 32% of a 3-million GPD capacity and can easily handle the
waste from Pleasant Gardens. Earl Daniels, Marion City Manager, suggests that the Corpening Creek plant is
being reserved for future commercial discharge and should not be used for this project. LJEA insists that the
proposed increase at the Catawba River plant (approximately 170,000 GPD) would have virtually NO impact on
the Corpaning Creek plant's ability to handle fixture commercial waste.
Any increase in discharge on the Catawba River would also have far-reaching consequences to the Lake
James watershed. Burke and McDowell Counties are currently looking to using Lake James as a source of clean
drinking water. One step in the process would be reclassifying Lake James from watershed designation WS-V to
WS-IV or WS-IIL Reclassification would have a very significant positive impact on the costs of building and
operating a water intake and treatment facility (Gary McGill, McGill and Associates). Allowing any mcrease m
point source discharge on the Catawba River would not only endanger any efforts to reclassify the watershed, but
would also lead to higher costs for construction and operation of the new water intake facility.
4 �
fsfiedeaatiasz o f —PaAs;dared. awd it'd Ar w&%t s uasAId..

You should be aware that there is a large effort underway to purchase land in Lake James watershed
areas from Duke Energy (Crescent Resources). These purchases would be by various Federal and State agencies,
and would be aimed at preserving the lakeshore and its treasure of resources, including clean water. The timing of
those acquisition efforts is in a critical phase. It is entirely possible that the acquiring agencies could be turned off
by what they could perceive as the unnecessary increase of point source pollution to the Lake James watershed at
a time when we are making the case that their help is needed to preserve the quality of that water.
Lake James Environmental Association would implore the North Carolina Division of
Environment and Natural Resources to look carefully at this situation and use its authority to convince
McDowell County to use its existing wastewater treatment capacity, and to not needlessly endanger the
Lake James watershed, especially when an e

_ Y
GKEX88/MP
07/05/2000
COMPLIANCE EVALUATION
ANALYSIS
REPORT
PAGE 1
.:-- PERMIT--NC0071200
PIPE--001
REPORT
PERIOD:
9901-9912
LOC
--- E
FACILITY--MARION
(CITY)-CATAWBA RVR
WWTP
DESIGN FLOW--
.2500
CLASS--2
LOCATION--MARION
REGION/COUNTY--01
MCDOWELL
50050
00310
00530
00610
31616
50060
00010
00400
MONTH
Q/MGD
BOD
RES/TSS NH3+NH4-
FEC COLI
CHLORINE
TEMP
PH
LIMIT F
.2500
F 30.00
F 30.0
NOL
F 200.0
NOL
NOL
9.0 6.0
99/01
.0730
1.30
6.5
.00
1.0
1.380
11.30
8.0-6.2
99/02
.0784
5.00
24.0
3.71
1.0
1.380
12.50
6.5-6.1
99/03
.0701
.00
7.4
2.50
1.6
1.590
11.70
7.2-6.2
99/04
.0729
4.80
6.8
1.20
1.0
1.150
17.80
7.0-6.3
99/05
.0710
1.00
9.0
1.10
1.0
1.490
20.20
6.8-6.2
99/06
.0658
1.80
7.8
.00
1.0
1.750
25.10
6.6-6.0
99/07
.0689
.00
15.5
.00
.0
1.630
26.90
6.5-6.1
99/08
.0709
2.80
10.6
.00
.0
.860
27.00
6.9-6.1
99/09
.0684
3.30
4.5
.00
.0
.980
24.40
6.9-6.1
99/10
.0659
10.00
4.8
.00
1.5
1.140
20.80
6.8-6.2
99/11
.0660
1.80
5.0
.00
3.3
.740
17.50
6.9-6.2
99/12
.0598
.60
10.2
.00
1.0
1.290
14.10
6.9-6.2
AVERAGE
.0692
2.70
9.3
.70
1..0
1.281
19.10
MAXIMUM
.0784
10.00
24.0
3.71
3.3
1.750
27.00
8.000
MINIMUM
.0598
.00
4.5
.00
.0
.740
11.30
6.000
UNIT
MGD
MG/L
MG/L
MG/L
#/100ML
MG/L
DEG.0
SU
2 $%
17
3/

GKEX88/MP 07/05/2000
COMPLIANCE EVALUATION ANALYSIS REPORT PAGE 2
PERMIT--NC0071200 PIPE--001 REPORT PERIOD: 9901-9912 LOC --- E
FACILITY--MARION (CITY)-CATAWBA RVR WWTP DESIGN FLOW-- .2500 CLASS--2
LOCATION--MARION REGION/COUNTY--01 MCDOWELL
00600 00665
MONTH TOTAL N PHOS-TOT
NOL NOL
99/01 4.200 7.2000
99/02
99/03
99/04 7.110 4.6000
99/05
99/07 12.300 4.8000
99/09
99/10 1.840 3.1000
99/11
99/12
AVERAGE
6.362
4.9250
MAXIMUM
12.300
7.2000
MINIMUM
1.840
3.1000
UNIT
MG/L
MG/L

GKEX88/MP
07/05/2000
COMPLIANCE EVALUATION
ANALYSIS REPORT
PAGE 1
PERMIT--NC0071200
PIPE--001
REPORT
PERIOD:
0001-0005
LOC
--- E
FACILITY--MARION
(CITY)-CATAWBA RVR
WWTP
DESIGN FLOW--
.2500
CLASS--2
LOCATION--MARION
REGION/COUNTY--01
MCDOWELL
50050
00310
00530
00610
31616
50060
00010
00400
MONTH
Q/MGD
DOD
RES/TSS NH3+NH4-
FEC COLI
CHLORINE
TEMP
PH
LIMIT F
.2500
F 30.00
F 30.0
NOL
F 200.0
NOL
NOL
9.0 6.0
00/01
.0566
2.60
6.2
.00
1.7
1.990
11.20
6.9,-6.3
00/02
.0707
6.00
11.7
.00
LESSTHAN
2.100
11.70
7.1-6.4
00/03
.0670
3.80
3.2
.00
LESSTHAN
1.760
15.10
7.1-6.5
00/04
.0705
4.80
4.8
.85
LESSTHAN
1.760
17.30
7.0-6.2
AVERAGE
.0662
4.30
6.4
.21
1.7
1.902
13.82
MAXIMUM
.0707
6.00
11.7
.85
1.7
2.100
17.30
7.100
MINIMUM
.0566
2.60
3.2
.00
LESSTHAN
1.760
11.20
6.200
UNIT
MGD
MG/L
MG/L
MG/L
4/100ML
MG/L
DEG.0
SU

GKEX88/MP 07/05/2000
COMPLIANCE EVALUATION ANALYSIS REPORT PAGE 2
PERMIT--NC0071200 PIPE--001 REPORT PERIOD: 0001-0005 LOC --- E
FACILITY--MARION (CITY)-CATAWBA RVR WWTP DESIGN FLOW-- .2500 CLASS--2
LOCATION--MARION REGION/COUNTY=01 MCDOWELL
00600 00665
MONTH TOTAL N PHOS-TOT
NOL NOL
00/01 5.120 .8300
00/02
00/03
00/04
7.240
1.7000
AVERAGE
6.180
1.2650
MAXIMUM
7.240
1.7000
MINIMUM
5.120
.8300
UNIT
MG/L
MG/L

.L'a4e �affza� � �4y o�, Sac
P.G. /3oz 430
Nam, NmA ea4dwa .2876>
Forest Westall
C/O DENR
Asheville Regional Office
Division of Water Quality
59 Woodfin Place
Asheville, N.C. 28801
Re: Catawba River Wastewater Treatment Plant, McDowell County
Dear Mr. Westall, 07/06/00
McDowell County and the City of Marion have applied to DENR for a permit to add an additional
hookup to the Catawba River Wastewater Treatment Plant here in McDowell County. This additional hookup
would add 170,000 gallons per day to this plant, maximizing that plant's permitted discharge at 250,000 GPD.
Lake James Environmental Association would ask for your personal attention to this matter as we are very
concerned that the county and city will proceed with their current plans, regardless of the consequences to the
Lake James watershed and without seriously exploring more favorable environmental and financial alternatives.
Just over two weeks ago DENR Secretary Bill Holman communicated to McDowell and Burke Counties,
and Senators Steve Metcalf and Charles Carter, that his temporary_ buffer_n,te�would not be implemented as
planned for the Catawba River P—;r _ — tewards in the mean time. "It is
important that local govi �ity while the EMC delays action"
is his direct quote; "DEN 'ze County officials to protect the
high water quality, excel;
Lake James Envi e57J tl.)unty tomorrow morning to
discuss the issue. We have (this week allowing the hookup to
the Catawba River Plant. j 'auch a permit. We are confident
that once all factors are co; r f ,�,� ,A 1 will be chosen.
GG -3
President
Cc: DENR Secretary Bill Holman
r �
t d.°
be&,,A?J A6 p2Pi ",a.� —flalae �aas"a d it'd hu ,,&49,

1'alw Yes Pt �4�, Sac
P.G. /3oz 430
Nam, Nwdk ewwk*za .2876'
Editor
McDowell News
P.O. Box 610
Marion, N.C. 28752
Re: Guest opinion/letter to the editor
Dear Editor, 06/09/00
McDowell County and the City of Marion are considering a significant increase in wastewater discharge
at the Catawba River wastewater treatment facility near Garden Creek. This plant is currently permitted to
discharge at a rate of 250,000 gallons per day (GPD) and is now discharging an average of about 80,000 GPD.
The County/City plans would maximize daily output at this plant. In our annual inspection of the plant last
November Lake James Environmental Association (LJEA) reviewed records indicating recurring spikes in
discharge at over 300,000 GPD. The engineer in charge of the plant explained that these spikes in output occurred
at any time it rained heavily (this plant handles rainwater runoff for the entire "five -lane" commercial district).
Therefore, if output were maximized at 250,000 GPD, then during and after heavy rainfall this plant would
overflow raw sewage at a rate opproximately 440 000 GPD directly into the Catawba River above Lake James
This overflow would be completely uncontrollable. In November we asked the plant's engineer how the plant
would fare if daily output were upped to the maximum, and he stated that he would not advise running that high
volume through that particular plant. The Garden Creek plant was never designed to handle rainwater runoff. This
rainwater is infiltrating the system somewhere along the five lane, and the City of Marion cannot fmd the source.
Lake James Environmental Association agrees wholeheartedly that the Pleasant Gardens
community needs and deserves sewer service. However, LJEA would assert that wastewater from this area
should be collected and pumped just one mile uphill, where it could be gravity fed through existing sewer lines to
the Corpening Creek Wastewater Treatment Plant. This plant is now operating at only 32% of a 3 million GPD
capacity and can easily handle the waste from Pleasant Gardens. Earl Daniels, Marion City Manager, suggests that
the Corpening Creek plant is being reserved for future commercial discharge and should not be used for this
project. LJEA insists that the proposed increase from the Pleasant Gardens Community (approximately 170,000
GPD) would have virtually NO impact on the Corpening Creek plant's ability to handle future commercial waste.
Any increase in discharge on the Catawba River would also have far-reaching consequences to the Lake
James watershed. Burke and McDowell Counties are currently looking to using Lake James as a source of clean
drinking water. One step in the process would be reclassifying Lake James from watershed designation WS-V to
WS-IV or WS-III. Reclassification would have a very significant positive impact on the costs of building and
operating a water intake and treatment facility (Ref: Gary McGill, McGill and Associates). Allowing any increase
in point source discharge on the Catawba River would not only endanger any efforts to reclassify the watershed,
but would also lead to higher costs for construction and operation of the new water intake facility.
Most citizens are aware that there is a large effort underway to purchase land in Lake James watershed
areas from Duke Energy (Crescent Resources). These purchases would be by various Federal and State agencies,
and would be aimed at preserving the lakeshore and its treasure of resources, including clean water. The timing of
.`hecQicutecQ #a tie rrheselirxetiaai a� 1'r�he �a�nns � it's .t�,�Gsitwuy ir.J....

—fla/6 �am" ��� �l�ez, Yow
A t7. /3ox 430
Ne&, Aadk (?wx wa .28761
those acquisition efforts is in a critical phase. It is entirely possible that the acquiring agencies could be turned off
by what they could perceive as an unnecessary increase of point source pollution to the Lake James watershed at a
time when we are making the case that their help is needed to preserve the quality of that water.
Lake James Environmental Association would implore the citizens of McDowell and Burke
Counties, the McDowell County Commissioners, the McDowell County Board of Education and the City of
Marion to look more carefully at this situation. We would call for a public hearing to allow for input from
the citizens who will be paying for the project, and who will be drinking the water drawn from Lake James
in the near future. We must not needlessly endanger the quality of the water in Lake James, especially
when easily implemented alternatives exist.
Sincerely,
Ken Harris
President
Lake James Environmental Association
`nedicu,�ed �a die �ix.ie�wa�iass a� 1'G.he �rmP,s � ii's �iriGrc#�✓uy u�a�vir,J....

1' ea&bW"Oft&V l 4ddGsrV 9w
AC9. Batz 430
NeGaa, AW4 Gar. wZWa 28761
Art Dutton/McDowell County Representative
NC DENR
Asheville Regional Office
Division of Water Quality
59 Woodfin Place
Asheville, N.C. 28801
Re: Future increase of wastewater discharge, McDowell County
Dear Mr. Dutton,
Thank you for responding to my inquiryof 01/14/00. Lake James
point source discharges on the Catawba River above Lake James.
It has come to our attention that McDowell County and the City of Marion are considering a significant
increase in discharge at the Catawba River wastewater treatment facility near Garden Creek. This plant is
currently permitted to discharge at a rate of 250,000 gallons per day (GPD) and is now discharging an average of
about 80,000 GPD. The County/City plans would maximize daily output at this plant. In our annual inspection of
Iglat last November LJEA reviewed records indicating recurring spikes in discharge at over 300,000 GPD.
in charge of the plant explained that these spikes in output occurred at any time it rained heavily
rainwater runoff for the entire "five -lane" commercial district). Therefore, if output were
QED, then during and after heavy rainfall this plant would overflow raw sewage at a rate
�� „) directly into the Catawba River above Lake .lames! This overflow would be
e ber we asked the plant's engineer how the plant would fare if daily output
that he would not advise running that high volume through that
�tion agrees wholeheartedly that the Pleasant Gardens
ce. We support the effort to provide the service to the
hat wastewater from this area should be collected and pumped just
.ed through existing sewer lines to the Corpening Creek Wastewater
ing at only 32% of a 3-million GPD capacity and can easily handle the
.els, Marion City Manager, suggests that the Corpening Creek plant is
lischarge and should not be used for this project. LJEA insists that the
ier plant (approximately 170,000 GPD) would have virtually NO impact on
,io handle future commercial waste.
e on the Catawba River would also have far-reaching consequences to the Lake
r� :;Dowell Counties are currently looking to using Lake James as a source of clean
drinkiu6, process would be reclassifying Lake James from watershed designation WS-V to
WS-IV or W .motion would have a very significant positive impact on the costs of building and
operating a water u►-,, Itreatment facility (Gary McGill, McGill and Associates). Allowing any increase in
point source discharge on the Catawba River would not only endanger any efforts to reclassify the watershed, but
would also lead to higher costs for construction and operation of the new water intake facility.
2edate� to the p4eee urn' s c 1'aiie;'am" and it'd �Adw&" urc�iie... _ � '�-
��

i
You should be aware that there is a large effort underway to purchase land in Lake James watershed
areas from Duke Energy (Crescent Resources). These purchases would be by various Federal and State agencies,
and would be aimed at preserving the Lakeshore and its treasure of resources, including clean water. The timing of
those acquisition efforts is in a critical phase. It is entirely possible that the acquiring agencies could be turned off
by what they could perceive as the unnecessary increase of point source pollution to the Lake James watershed at
a time when we are making the case that their help is needed to preserve the quality of that water.
Lake James Environmental Association would implore the North Carolina Division of
Environment and Natural Resources to look carefully at this situation and use its authority to convince
McDowell County to use its eidsting wastewater treatment capacity, and to not needlessly endanger the
Lake James watershed, especially when an e

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Ph. B z 430
Ne&, /U 414 ea4ak-aa 2876f
X
Art Dutton/McDowell County Representative
NC DENR �Q
Asheville Regional Office
Division of Water Quality v �
59 Woodfin Place
Asheville, N.C. 28801
Re: Future increase of wastewater discharge, McDowell County
Dear Mr. Dutton, 06/12/00
Thank you for responding to my inquiry of 01/14/00. Lake James Environmentafis always interested in
point source discharges on the Catawba River above Lake James.
It has come to our attention that McDowell County and the City of Marion are considering a significant
increase in discharge at the Catawba River wastewater treatment facility near Garden Creek. This plant is
currently permitted to discharge at a rate of 250,000 gallons per day (GPD) and is now discharging an average of
about 80,000 GPD. The County/City plans would maximize daily output at this plant. In our annual inspection of
the plant last November LJEA reviewed records indicating recurring spikes in discharge at over 300,000 GPD.
The engineer in charge of the plant explained that these spikes in output occurred at any time it rained heavily
(this plant handles rainwater runoff for the entire "five -lane" commercial district). Therefore, if output were
maximized at 250,000 GPD, then during and after heavy rainfall this plant would overflow raw sewage at a rate
of approximate.1y 440 000 GPD directly into the Catawba River above Lake James! This overflow would be
completely uncontrollable. In November we asked the plant's engineer how the plant would fare if daily output
were upped to the maximum, and he stated that he would not advise running that high volume through that
particular plant.
Lake James Environmental Association agrees wholeheartedly that the Pleasant Gardens
community needs and deserves sewer service. We support the effort to provide the service to the
community. However, LJEA would assert that wastewater from this area should be collected and pumped just
one mile uphill, where it could be gravity fed through existing sewer lines to the Corpening Creek Wastewater
Treatment Plant. This plant is now operating at only 32% of a 3-million GPD capacity and can easily handle the
waste from Pleasant Gardens. Earl Daniels, Marion City Manager, suggests that the Corpening Creek plant is
being reserved for future commercial discharge and should not be used for this project. LJEA insists that the
proposed increase at the Catawba River plant (approximately 170,000 GPD) would have virtually NO impact on
the Corpening Creek plant's ability to handle future commercial waste.
Any increase in discharge on the Catawba River would also have far-reaching consequences to the Lake
James watershed. Burke and McDowell Counties are currently looking to using Lake James as a source of clean
drinking water. One step in the process would be reclassifying Lake James from watershed designation WS-V to
WS-IV or WS-III. Reclassification would have a very significant positive impact on the costs of building and
operating a water intake and treatment facility (Gary McGill, McGill and Associates). Allowing any increase in
point source discharge on the Catawba River would not only endanger any efforts to reclassify the watershed, but
would also lead to higher costs for construction and operation of the new water intake facility.
.L'ahe wined. aad ` '

You should be aware that there is a large effort underway to purchase land in Lake James watershed
areas from Duke Energy (Crescent Resources). These purchases would be by various Federal and State agencies,
and would be aimed at preserving the lakeshore and its treasure of resources, including clean water. The timing of
those acquisition efforts is in a critical phase. It is entirely possible that the acquiring agencies could be turned off
by what they could perceive as the unnecessary increase of point source pollution to the Lake James watershed at
a time when we are making the case that their help is needed to preserve the quality of that water.
Lake James Environmental Association would implore the North Carolina Division of
Environment and Natural Resources to look carefully at this situation and use its authority to convince
McDowell County to use its existing wastewater treatment capacity, and to not needlessly endanger the
Lake James watershed, especially when an e;

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www.main.nc.us/ljea
Forest Westall
C/O DENR
Asheville Regional Office
Division of Water Quality
59 Woodfin Place
Asheville, N.C. 28801
Re: Lake James Algae Bloom, Spring 2000
IE Forest-
'Ile s
- d)s
08/31/00
Thank you for taking the time to attend our meeting with the City of Marion and
McDoweWs Utility Committee last month. I realize that in your position things can get
uncomfortable at times.
In that meeting I told you about an algae bloom on Lake James that occurred last spring.
It literally turned the lake the color of antifreeze from the Catawba River through 12 miles
down the lake. Anything placed into the water came out coated with a thick, bright green slime.
At 20 miles the color was not so intense, but was very noticeable. I told you also that the
incident happened just days before the bass spawn began- the first or second week in April
2000. Could you please check the discharge records for the Catawba River Wastewater
Treatment Plant for that period? This sticks in my mind particularly because this bloom
happened at exactly the same time that the Corpening Creek Wastewater Treatment Plant had a
major spill. Is there a possibility that some clerical mistake might have been made in identifying
one spill rather than two?
I am certainly no marine biologist, but it would seem to me that in order to create an
algae bloom as massive as the one we witnessed in April one would have to dump an extremely
large quantity of nutrient into the river. Are there naturally occurring factors that could create
this scenario?
Thank you for your help. Please respond as quickly as possible.
Sincerely,
Lake James Environmental Association
Chair, Lake James State Park P.A.C.
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4" � �� • '� it '� __�

Re: [Fwd: URGENT! From Lake James Enviro... al Association- Time is of the essence!]
Subject: Re: [Fwd: URGENT! From Lake James Environmental Association- Time is of the
essence!]
Date: Tue, 18 Jul 2000 12:17:54 -0400
From: Forrest Westall <[e-mail]>
Organization: NC DENR - Asheville Regional Office
To: Bill Holman <[e-mail]>
CC: Coleen Sullins <[e-mail]>, Kim Colson <[e-mail]>,
Larry Frost <[e-mail]>, Tommy Stevens <[e-mail]>
Bill,
I attended the local utilities meeting on Friday July 7 in Marion and this session was arranged for the Lake
James Association folks to get their issues out on the table. I think it was a pretty good session, but
concerns about growth in the Catawba drainage to the lake will continue. The basic issue to the LJEA is
keeping the waste discharge and nutrient load to the lake from going up. Their suggestion on servicing the
area north and west of Marion is to pump the waste to the Corpening Creek facility (it discharges below the
lake) located to the south of Marion. The Pleasant Gardens area proposed for service, needs service (a few
package plants already discharge to the lake and a school has a failing subsurface system) and overall the
project would be a water quality benefit (improve local WQ--impacts of existing "discharging" systems,
consolidate management of the wastewater under the City of Marion, allow us to consolidate discharges
and apply any future "nutrient controls" to point sources to one facility in this area --not anticipated at this
point --Lake James is by all agency criteria a "clean" lake, etc.). The cost to pump the waste over to
Corpening Creek (which still results in a projected nutrient increase to Lake Rodhiss and all the Catawba
"chain" lakes downstream) would increase the proposed project cost by over 40 % and is not really
economically feasible and would raise other environmental issues (such as why would we be allowing
McDowell Co. to move new point source nutrient loading downstream of James, a clean lake, to Rodhiss
and Hickory that are showing signs of problem eutrophication). I understand the concerns of the LJEA and
in principle think that the issues that they have brought up need to be considered. However, as I pointed
out at the meeting (two city council members, city manager, two county commissioners, county manager
and five members of the LJEA--one by phone, along with two DWQ staff members present) the associated
increased non -point nutrient loading from "development" of this part of the county, has a greater potential
of impacting the Lake than the point source increase from public sewer service (discharge to the Catawba
Plant, which is above the Lake). I strongly suggested to the County that they adopt some local ordnance
rules to limit non -point source impacts (it was an opportunity to press the need for buffers, which most
everyone there acknowledged were needed) from the "growth" expected from the presence of public sewer
service in this relatively "rural" area. I also suggested that the LJEA use its strength to support such a local
action. I also stated that this was an excellent opportunity for McDowell County to put its "money where
its mouth is" on providing good stewardship of its existing good water quality (since they always say that
because of their past actions they have kept the area water quality and the quality of Lake James
good --actually this has been due to development patterns rather than strong local action and a huge part of
the upper watershed being in forest and public lands --National Forest, but that's another story). By the
close of the meeting, I tried to make it clear that Marion has a permit and a facility allowed to discharge up
to 0.25 MGD (monthly average) of waste into the Catawba River above the Lake and that under our rules,
there is no way to prevent their increasing their flow as long as they stay in compliance (the plant is now at
a maximum monthly flow of 0.08 MGD and effluent quality is excellent, well below their limits --actually
about 20% of allowable BOD and TSS). With current performance, the plant has about 0.17 MGD of
capacity. The proposed project has only about 0.05 to 0.07 MGD maximum flow, so the project represents
no real issue for accommodation by the Catawba plant. I have suggested to the LJEA that they focus their
attention on this issue when a request is received for additional capacity at the Catawba Plant. An NPDES
expansion would require opportunity for a public hearing (and could under SEPA, as a special situation --it
1 of 3 7/18/2000 1:01 PM

Re: [Fwd: URGENT! From Lake James Enviro... al Association- Time is of the essence!]
would likely be below any thresholds established --be required to do an EA). In the meantime, the County
should move toward some local controls that would limit non -point source impacts from additional growth
(density and buffers). The County Manager offered to do a study of this issue and to determine if controls
of this type would be necessary. I think this is a positive development, but I think that the LJEA is still not
sure of its position on the proposed project. The County Commissioners, according to Chuck Abernathy,
County Manager, voted 3 to 2 on July 10 to move forward with the Pleasant Gardens project. At this point
and under our regulations, I think we have to approve this project. We have already issued an individual
permit for the school (with a failing, cannot be repared--been "fixed" several times --subsurface system,
only 0.01 MGD) to go to the Catawba plant, but they will use those funds to support the bigger project (to
serve the whole area) if that project goes forward. I expect a permit application for the bigger project
within a few weeks.
I apologize for the length of this e-mail, but the issues here are pretty complex. Let me know if you you
have additional questions.
Forrest
Bill Holman wrote:
Forrest: What are your thoughts on this discharge?
-------- Original Message ---------
Subject: URGENT! From Lake James Environmental Association- Time is of the essence!
Date: Thu, 6 Jul 2000 16:11:38 -0700
From: "Ken Harris" <[e-mail]>
To: 'Bill Holman" <[e-mail]>
Mr. Holman- Please take a minute to read the attachments. McDowell County is moving ahead with plans to unnecessarily
discharge wastewater into Lake James, and we need your attention now!Thank you, Ken Harris, LJEA President
Forrest Westall - Forrest. [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Forrest Westall <Forrest.Westallancmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
2 of 3 7/18/2000 1:01 PM

DEC 01 100 04.43PM MCDOWELL COUNTY
-rW _ 7
McDowell COu
60 .fast Court Street
Mafi0n, North Carulina 28752
Volpe: 828/882-7121
Fax_ 828l68_9-3484
FAX TRANSMISSION COMER SHEET"
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CONFIDENTiALAND PRMLEGED: The information in this facsimile is privileged end confidential
fnformalon intended for the sole use of the addressee. If the reader of this facsimile is not the intended
recipient, or the employee or agent responsible for derrvedrrg it to the intended recipient, you we hereby
notified that any d'rsserninailon, dlstri'bution of copying of this carr murricatorl Is -frfdy prohibited, If you
have received this transmission in error, please irnmed'tateiy notify the sender.

DEC 01 '00 04:44PM MCDOWELL COUNTY P.2
9 e
An Assessment o� f the Troop Zic Status
and Quality o� f Lake James and the
P rojeaed .Impact o, f Increased Treated
WasteNater Discharges
RichaYd P. Maas, Ph.D.
Research Director, UNC Asheville
Envi ronmenW Quality Institute
November 8, 2000

DEC 01 100 04:44PM MCDOWELL COUNTY P.3
I. INI.RODUCTIONAND BACKGROUND
The ENVR 321 - Limnology class from the Department of F.anvirorumental
Studies at UNC Asheville has conducted water quality field studies at Lake Jame s
during September of most years since I9s8 under the direction of Dr. Richard Ia.
Maas. These studies. have been conducted almost exclusively on the Catawba Diver
portion of the lake and have focused on measuring and interpreting standar d
Iimnological parameters including dissolved oxygen, temperature, pH, CQa, available
phosphorus, ammonia, turbidity, secchi transparency, faunal color scale, sediment
phosphorus concentrations, zooplankton identification from the entire depth profile
of the lake as appropriate.
The purpose of the present assessment is to integrate these annual lake study
results in terms of the possible effects on the ecosystem health of the lake from
proposed additional treated wastewater discharges from the Catawba 1VVVTri
draining into the upper end of the Catawba portion of Lake James.
H. CURRENT TROPI-HC STATUS OF LAKE JAMaES
Figure 1 on the next page shows the average temperature and dissolved oxygen
(DO) depth profile for Lake James its early September over the past decade. In some
years greater oxygen deficits have been observed and in some years there is Iess of an
oxygen deficit. No clear trend with time has yet been observed, probably because
annual summer weather variability is generally the most influential factor. As can b e
seen from 'Fable 1, oxygen concentrations drop drastically between 6 and 10 meters
depth corresponding to the beginning of the temperature thermocline at about 8
meters depth. The DO generally decreases to less than 2 parts -per -million (ppm)
between 9 and 12 meters and then begins to recover with greater depth.. In most, but
not all, years the DO recovers to Iev& above 4 ppm between. about 15 m and 24 zn
depth. Near the bottom the DO decreases again, presumably due to the influence
of organic, oxygen -demanding sediment material.
Although the exact amount of dissolved oxygen necessary to insure fish survival
varies with species, generally 4 ppm is considered a critical minimum concentration
for long-term viability. Most species can survive somewhat lower concentrations for
periods up to several days. From Figure .I it can be seen that typically the DO rises
somewhat above 4 ppm between 15 and 24 in during September of most years. TW9
is critical for the overall biological health and integrity of Lake James. Cool water fish

DEC 01 '00 04:44PN MCDOWELL COUNTY
P.4
species (e.g., trout, small -mouth bass, walleye) trust be, able to move to the deeper
colder waters of a lake during summer to avoid respiratory stress and disease.
.Already, there is a section of the lake between about 9 and 13 meters where fish can
not survive because of low DO, and the only viable cool -water habitat is between 15
and 24 rn.
The observed oxygen deficit (Do deficit = DO conc. at saturation - DO actual
observed) is caused primarily by organic mattes being decomposed by aerobic bacteri a
which use up oxygen in this process and release CO.. It is not uncommon for WNC
reservoirs to show alarge oxygen deficit across the thermodine (i.e., 5-15 gym) In late
summer and autumn from bacterial decomposition of organic matter, This organic
matter tends to build up in the thermocline layer as a result. of. 1) stream inputs to
the lake (stream water in summer is generally warmer and less dense than the
hypohmnion (i.e., bottom) water and colder and more dense than the epilimnion
(i.e., surface) water; and thus this water arkd the orgaxuc materials it carries are spread
across the lake at the thermocline depths. 2) Algae and zooplarikton which slowly
sink from the photosyndmtit zone in the epihmnion to die and be bacteriaBy
decomposed in the thermocline region. The amount of algae which grow in the
surface water and eventually sink to the thermocline to use up oxygen is ultimately
dependent on the amount of nutrients from treated wastewater discharges, shoreline
development .activities, farmland, and other sources which reach the lake.
If the organic inputs are relatively low, and the lake is deep with a Iarge
hypolimnion, most of this oxygen -utilizing decomposition will occur in the
therrnocline region, and the relatively small amount of remaining organic material
which sinks to the hypolimnion will have only a relatively minor impact on the DO
levels there. In the case of Lake James, it can be seen from Figure 1, that nearly all
of the oxygen in the thermocline is used up and that- the additional decomposition
in. the hypolimnion has almost pushed the DO levels there to levels which will
eliminate cool -water fish species from the lake ecosystem. It should be noted that the
reoxygenating fall turnover generally ' does not occur in Lake James until late
November, and thus the thermocline and hypolimnion DO conditions probably
become even more critical later in September and in early October. (By late October,
surface water temperatures are cool enough for cool -water fish species tolretum to the
oxygenated epilimnion. )

DEC 01 100 04.45PN NCDOWELL COUNTY
P.5
ASSESSMENT TT OF TR E IMPACTS D_' I11iCItEASED VOX; UMESOF
7RM7ED WA.STEWAM DISCHARGES
As noted above and illustrated by Figure 1, the current nutrient and organic
material loading to the Catawba side of Lake James has already pushed the lake clone
to the boundary of maintaining a cool water fishery habitat and ecosystem. In most
other regards, the lake quality seems to be sufficiently high to. support othex intende d
uses.
A. Dissoiived O ygm Effects
The proposal to add the Pleasant Gardens School to the load,of the Catawba
PIant would add about 10,000 gal/day (gpd) to the current 80,000 gpd discharge
from the plant (i.e., a 12.5% increase). If other facilities, such as Crane ResistoflM
Tom Johnson Camping Centex, etc., are added on, the percentage of discharge
increase would be much larger, perhaps as much as doubling the current discharge.
The calculated effects described below will be assessed for three possible scenarios;
1) Pleasant Gardens School addition only, 2) additional line extension tie-ins totaling
80,000 gpd, and 3) an increase .of treated waste discharge to a total of 250,000 gpd..
Any additional discharge from -the Catawba plant could adversely affect Lake James
in two ways: 1) Extra oxygen -demanding organics would be added directly to the
thennocline area of the .lake which is already very oxygen depleted during the
summer and early fall. Some of this material would sink and cause more oxygen
depletion in the already borderline cool -water fish habitat in the hypolimnion of the
lake. 2) The additional effluent would add substantial additional phosphorus to the
lake over the years which would produce more algal biomass and consequently more
oxygen demand on. the thermocline and hypohmnion portions of the water column,
Some approximate calculations to semi -quantify the impacts are shown below:
I. Pleasant Gardens School only (12.5% increase)
a. 10,000 gpd at 30 mgfL 130D for the period of April 1.5 to October 15
each year spread over the 3,000-acre Catawba portion of the lake:
206 Kg of 02 demand _ 20 rn of 'water over 3,000 acres equals a loss
of dissolved oxygen of only about 0.001 mg/L, which is, negligible by
itself.

DEC 01 '00 04.46PM MCDOWELL COUNTY P.6
b. phosphorus loadirtgs causing more algal growth and subsequent DO loss:
10,000 gpd x 2 mg P/L x 365 days = 27.6 Kg P%yr x 500 g of
biomass/gP = 13,760 Kg of biomass, which when decomposed
consumes 12,900 Zug of Oa, This translates to a. total oxygen deficit of
about 0,054 mg/L of Oa over bottom 20 meters of the lake.
Thus, only a small, just barely noticeable, decrease in thermocline and
hypolimrtion oxygen levels would be expected from just the addition of
the Pleasant Gardens School. By itself, this would only shift the DO
profile graph in Figure 1 slightly to the left,
2. Assessment assuming Pleasant Gardens School plus various 'indust ies and
subdivisions (i.e., a doubling of the torrent Catawba Plant discharge from
80,000 gpd to 160,000 gpd).
a. Direct therrnocline organic input: OZ demand increase = 0.0096 mg/L
b. Increased algal production from increased phosphorus input: 0.054 x
6.4 = 0.35 mg/L of OZ demand increase
Thus, the total additional Oa deficit = 0,36 mg/L. This represents a greater
impact on thermocline and hypolimnion DO levels, but is still not large . .
Subtracting 0.36 mg/L from all of the data points shown in Figure I reduces
the remaining area of cool -water fish habitat from about 9 meters width (15
m - 24 m) down to only between 5.5 and 6 meten width, a significant
decrease. The actual biological effect could be critical in certain worse -than -
normal DO depletion years.
3. Assessment assuming an increase of average daily treated waste discharge to a
total of 250,000 gpd.
a. Direct thermocline organic Input: 250,000 gal/day at 30 mg/L BOD
spread over the period 4/15 to 10/13 each year spread over the Catawba
portion of the lake translates to a loss of dissolved oxygen of about 0.02
mg/L. This would probably actually be about twice as great in the upper
end of the Catawba side of the lake and above half as great in, the lower
4

DEC 01 '00 04:46PM MCDOWELL COUNTY
P.7
IA�M
b. F-loading causing more algal growth and subsequent DO loss in
thermocline and hypolimnion.
0.054 mg/L per 10,000 gpd x 170,000 gpd additional = 0.92 mg/L DO
Total = 0.92 + 0.02 = 0.94 mg/L
Again, it could reasonably be expected that, due to the relatively slow
flushing rate of Lake James, the effect would probably be about twice as
great in the ripper portion of the lake and perhaps only about half as
great in the lower portion of the lake. The effects of this wastewater
addition an the hypoWiadtic dissolved oxygen levels, and subsequently
on the cool -water fishery habitat are illustrated in Figure 2. As can be
seen from Figure 2, the addition of this much treated waste and its
associated phosphorus would almost certainly eliminate- the fragile
remaining cool -water fishery .habitat from the Catawba portion of Lake
James. Bear in mind. that Figures 1 and 2 illustrate mean September
observed DO concentrations for the period 1990-2000. Some
individual years exhibited lower DO concentrations in the thermrtochne
and hypolimnion, which would already have stressed this fishery
substantially.
The effects of all three scenadus described above calculated above would be
more severe if the plant a-Wfunctioried frequently at these higher input loads
and discharged more than its permitted BOD of 30 rng/L, although this would
probably be approximately counterbalanced by the periods when the discharge
was less than 30 mg/L BOD. Also, the calculations shown above are very
sensitive to the phosphorus (F) concentration used. Two mgg%1_, is common fir
such treatment plants, but an average discharge of 1 mg/L would half the
calculated effect and a 3 mg/L average discharge would increase it to almost a
0.52 mg/L DO reduction at a 160,000 gpd discharge, which would
significantly degrade the cool -water fishery habitat, and under the 250,000
gpd discharge scenario, the estimated hypolimnetic DO reduction is over 1.4
mg/L, which would almost without question quicldy eliminate the cool -water
fishery habitat.

DEC 01 '00 04:47PM MCDOWELL COUNTY
P.e
E. Other Effects
1. The added P from the extra treated waste discharge would cause some e= a
algal growth in the lake, which would lower the visibility and aesthetic appeal
of the lake somewhat. The effect of just the pleasant Gardens School would
probably not be noticeable, but a doubling of discharge from the addition of
other sources would almost certainly be noticeable, and the effect of a 2,50,000
gpd discharge would be substantially noticeable..
2. As noted above, the calculations above consider the entire Catavt►ba side of the
lake as a whole. The calculated effects would probably be greater in the Tipper
portion of the lake and somewhat less in the lowest portion.
VI. SUMMEiRY''AND CONCLUMON,S
Overall, the addition of the Pleasant Gardens School to the Catawb a
Treatment plant would by itself have a very minimal and just barely measurabl e
effect on Lake James. The tying in of other facilities to this line extension would
have a more noticeable, but still relatively moderate, impact on the dissolved oxygen,
cool -water fishery, and aesthetic/water clarity dynamics of the lake. An increase in
treated waste discharge at 30 rng/L BOD and 2.0 mg/, phosphorous to 250, 000 gpd
would almost certainly destroy the remaining cool -water fishery habitats, at least in
the Catawba portion of the lake.
With the extensive shoreline residential development currently underway on
the lake, overall water quality conditions can be expected to decrease somewhat with
time even if no additional wastewater discharges were permitted. Any impacts from
additional treated discharges will combine VAth the additional effects of new shoreline
development to cause overall effects greater than calculated above.
Overall, Lake James is a relatively clean, clear, ecologically healthy lake whose
water quality currently supports all intended ecosystem, fishery, recreational art d
aesthetic uses. The most critical water quality parameter is the amount of
surnmerffall dissolved oxygen in the thermocline and hypolirnnion of the lake which
determines the viability of the lake to support a cool -water fishery. These conditions
are already borderline for supporting a cool -water fishery. Thus, the combined effect s
of increasing shoreline residential and golf course development along with additional
treated waste discharge would probably combine to push the cool -water fishery

DEC 01 100 04;47PM MCDOWELL COUNTY
P.9
habitat out of existence in Lake James, converting it to a strictly warm-wa#or fishety
as seers in all the lower -elevation downstream lakes in the Catawba River system,
especially if treated discharges increased to 170,000 or 250,000 gpd, Clearly, if
preserving the cool -water fishery habitat is a priority, then any additional treated
waste discharges should be avoided if possible, and other upstream, land use and land
protection control should be encouraged to lower phosphorus and BOD inputs.
If substantial increases in treated effluent volume from the Catawba plant were
to be permitted, the only way to avoid the above -described degradation of Lake Jame's
in terms of cool -water fishery habitat and water clarity would, be to upgrade the
Catawba Plant. A lowering of its permitted BOD effluent limits would provide some
mitigation, but mainly* the plant would. need to have tertiary phosphorus removal
capabilities implemented, From the calculations above it would appear that an
efflueit limit of about 0.7 mgfL total P would be needed if the plant discharge permit
was expanded to 0.2.5 ,E GD to protect the cool -water fishery and wager clarity.

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[Fwd: Response to Mass information on Lal<e James]
Subject: [Fwd: Response to Mass information on Lake James]
Date: Mon, 11 Dec 2000 15:19:51 -0500
From: Forrest Westall <[e-mail]>
Organization: NC DENR - Asheville Regional Office
To: Larry Frost <[e-mail]>
For your review. Share with McDowell Co. please. We can
discuss in 2001. Thanks. FRW
-------- Original Message --------
Subject: Response to Mass information on Lake James
Date: Mon, 11 Dec 2000 14:00:36 -0500
From: Jay Sauber <[e-mail]>
To: Forrest Westall <[e-mail]>,Larry Frost
<[e-mail]>, Rick mass <[e-mail]>,Michelle
Woolfolk <[e-mail]>,Debra Owen
<[e-mail]>,Bill Foris <[e-mail]>
CC: Jimmie Overton <[e-mail]>
Forrest per your request, we took a look at Rick's September
data and evaluation memo. I think Rick raises some good
questions that in the future we should be able to answer.
But for now, I think this is the food for thought kind of
stuff not a solid reason for delaying consolidating of
dischargers. This response represents a quick review from
me, Debra Owen and Michelle Woolfolk. I have copied Rick on
this Email in appreciation for his views and to give him the
courtesy of our thoughts as well. Lots of data and graphs
attached in ms excel. I hope that Rick will join those of
us who consider a good calibrated nutrient response model of
Lake James to be a high priority. Others may wish to
respond individually, especially if I have not captured
their thoughts correctly but please, as a courtesy, copy the
folks listed above so that we can all be on the same
discussion page. Thanks...
"An Assessment of the Trophic Status and.Quality of Lake
James and the Projected Impact of Increased Treated
Wastewater Discharges" by R.P. Mass, PhD (Nov 2000)
It clearly seems that this report was generated due to some
concern with protecting the reservoir as a cold water
fishery and concerns of increased eutrophication. This is a
concern noted by DWQ but also be aware that the reservoir is
not classified for trout. Although the tone of the report
1 of 6 12/13/2000 9:12 AM

[Fwd: Response to Mass information on Lake James]
is compelling, We find it difficult to agree with all of the
suppositions leading to the conclusions. Generally the
report suggests that increases of BOD and nutrient loading
from the waste flow of the Catawba WWTP would bring about
adverse changes_ to the reservoir. However, a cause:effect
relationship for levels of dissolved oxygen that have been
observed in the strata of this reservoir has not been
established within this report. In brief, the report
successfully raises some interesting questions but fails to
scientifically support any conclusions related to:
1. A cause and effect relationship for observed dissolved
oxygen data;
2. A reasonable assumption that a modest increase in the
wasteload of the lake will result in an adverse condition;
3. That the observed dissolved oxygen profile in September
is a result of the WWTP discharge.
4. That the observed dissolved oxygen profile in September
is representative of an undesirable anthropogenic pollution
effect.
The report is useful for discussing the possibilities and
potential explanations of the observed September dissolved
oxygen profile as a stimulus for extensive academic
discussion. However, the report is insufficient for a
management decision -making tool or even a strong management
inference. Lake James is not representative of a classic
lake situation. In a natural lake one could expect oxygen
dynamics to be predicted based simply on dissolved oxygen
solubility, temperature, pressure, and the amount of
oxidizable substances contributed from a single WWTP.
Rather, Lake James is a highly complex artificial hydropower
reservoir. And as such, the explanation of oxygen maxima
and minima in the metalimnion is anything but simple. In
natural lakes, metalimnion oxygen maxima and minima are
typically explained by photosynthetic activity and
accumulations of oxidizable materials creating a low level
of dissolved oxygen. However, in hydropower reservoirs
temperature and complex hydrology and morphology alone may
also explain this phenomenon.
>From Fundamentals of Limnology by Franz Ruttner second
German edition published 1952 page 79.
The influence of temperature can be considered as follows.
Let us assume that we could eliminate contact with the air
and the effect of carbon assimilation in a lake with normal
temperature stratification and with a uniform content of
oxygen and oxidizable substances at all depths. According
to van t'Hoff's law, the oxygen will be consumed appreciably
2 of 6 12/13/2000 9:12 AM

[Fwd: Response to Mass information on Lake James]
sooner in the upper warm strata than in the cold depts.
After a certain time oxygen would first be encountered in
the metalimnion and -corresponding to the drop in
temperature -would increase with depth. If carbon
assimilation is then permitted, production of oxygen will
take place from the top down, the rate decreasing with depth
as the light decreases, and will reach the null point in the
metalimnion under certain conditions. The curve for the
final distribution of oxygen, which results from the
summation of production and consumption, must then of
necessity show a more or less well expressed minimum in the
metalimnion. If the lower limit of photosynthesis
penetrates deeper, the oxygen minimum will gradually become
a maximum, as can easily be seen by constructing the
corresponding case (Ruttner, 1933).
In North Carolina hydrology appears to be the governing
physical characteristic of all of our reservoirs. The
hydrology of North Carolina's reservoirs is greatly
dependent on the physical and climatological characteristics
of the drainage areas that contribute loadings as well as
the operation of the controling dam structures. The complex
hydrology and the operational characteristics of the Lake
James hydropower operations have not been considered in this
report. North Carolina does have some cause:effect water
quality models for several reservoirs downstream of Lake
James and all of these models have shown, sometimes
overwhelmingly, that hydrology governs the response of the
lake to pollution, even in small areas of these reservoirs.
Hydrology needs to be considered in any cause:effect
analysis of the reservoir.
It is impossible to judge anything in this report without a
more clear presentation of the data that was collected.
Were the samples collected from 1988 through now (2000?)
collected on one day in September of each year? or were the
profiles based on an average of multiple profiles in
September? Were the samples collected shortly after a
rainfall/runoff event? Again, weather can affect the
short-term response of the reservoir in terms of oxygen and
algae. How many different locations in the Catawba River
arm of the reservoir were sampled? If multiple sites were
sampled, where were the samples collected within the
reservoir? The preceding summertime stratification profiles
could greatly support a more complete assessment that might
3 of 6 12/13/2000 9:12 AM

[Fwd: Response to Mass information on Lake James]
lead to adequate management scenarios. However, with the
presentation of these questions we are not questioning the
validity of the observed September data. In fact, we have
made similar observations at one lake station during the
summer months (CTB 015A-data attached). The point is that
this is a very complex system and more information and tools
are necessary to support a valid hypothesis on explanations
for the observed dissolved oxygen profiles.
The report alludes to the Marion Catawba River WWTP and the
impacts of increasing the waste load from this facility.
The plant is currently permitted at 0.25 MGD and has an
instream waste concentration of 0.060. The actual flow is
more like 0.067 MGD, well below the permitted flow. It is
difficult to construct any reasonable scenario that this
discharge is currently controlling the dissolved oxygen
response of the data observed in September as presented in
the report. Future loading scenarios as described in the
report do not alter the fact that the wasteload from the
WWTP will still be less than 10 of the instream
concentration. There was no presentation or analysis of
loading information from the river or from the WWTP within
the report, although these data are readily available
through early 2000.
It should be noted that there are multiple studies of Lake
James that have been undertaken in recent years. The
Western Piedmont Council of Governments developed a EUTROMOD
model of the reservoir. While the in -reservoir predictions
were not representative of actually observed data, the load
estimates for portions of the watershed were reasonable,
including the Catawba River portion of the watershed (the
Linville River estimates were more uncertain). Also, Duke
Energy conducted a multiple year study of the reservoir and
are currently developing a nutrient response model of the
reservoir based on that data. This study is not yet
complete so the cause:effect relationship of additional
oxygen -consuming waste or nutrients is uncertain. In short,
these studies are better examples of the types of studies
for the development of management tools to recommend permit
changes for WWTPs or land use changes/BMPs for the watershed
in general.
Attached are dissolved oxygen profiles taken during 1997 at
multiple locations within the reservoir during the summer
growing season. You will note that the metalimnetic minima
and maxima were observed during August 1997, particularly
note CTB015A. These observations were similar all three
4 of 6 12/13/2000 9:12 AM

[Fwd: Response to Mass information on Lalce James]
months. Also attached is a summary of lake monitoring
activities, a map and general information that you may find
useful. The Maas report does provide some helpful questions
that should be considered as future management tools are
developed for this reservoir. In addition the report does
reflect a valid concern for eutrophication of this system.
The Lake James system is highly complex and has a long
retention time with good water clarity. These types of
systems are very difficult to restore once excessive
nutrient loading has contributed to nuisance conditions.
Caution is advised on the future development and management
of the drainage areas leading to this sensitive reservoir.
But caution needs to be exercised in a pragmatic and
realistic manner. The collection of good science and the
development of good management tools and models should be a
priority for continuing the long-term maintenance of this
valuable resource.
Jay H. Sauber
NC Division of Water Quality
4401 Reedy Creek Road
Raleigh, N.C. 27607
Phone: [phone]
Fax: [phone]
Name: James june 1997.xls
[_ Type: Microsoft Excel Worksheet (application/vnd.ms-excel)
i__,tames june 1997.xls Encoding: base64
Download Status: Not downloaded with message
Name: James August 1997.xls
�_ James August 1997.xls Type: Microsoft Excel Worksheet (application/vnd.ms-excel)
-' Encoding: base64
Download Status: Not downloaded with message
5 of 6 12/13/2000 9:12 AM

[Fwd: Response to Mass information on Lake James]
Name: James july 1997.xls
-* Type: Microsoft Excel Worksheet (application/vnd.ms-excel)
rq
_games July 1997.x1s Encoding: base64
Download Status: Not downloaded with message
Name: LAKE JAMES 97.doc
[` SLAKE JAMES 97.doc Type: Winword File (application/msword)
=' Encoding: base64
Download Status: Not downloaded with message
6 of 6 12/13/2000 9:12 AM

10.0
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CTBO15C
8/11/97
6
26.5
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40
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CTBO15C
8/11/97
7
_
25.4
7.4
41
8.3
CTBO15C
8/11/97
8
23.2
6.9
47
6.9
CTBO15C
8/11/97
9
21.8
6.7
45
6.1
CTBO15C
8/11/97
10
21.0
6.4
45
5.4
CTBO15C
8/11/97
11
19.9
6.4
42
5.8
CTBO15C
8/11/97
12
19.4
6.3
42
5.7
CTBO15C
8/11/97
13
18.8
6.2
42
5.1
CTBO15C
8/11/97
14
18.4
6.2
44
4.3
CTBO15C
8/11/97
15
17.9
6.1
44
4.1
CTBO15C
8/11/97
20
16.7
6.1
47
2.9
CTBO15C
8/11/97
25
15.9
6.1
46
3.0
CTBO15C
8/11/97
30
14.9
6.0
44
3.1
CTBO15C
8/11/97
33.5
13.8
6.1
46
2.1
CTB023B
8/11/97
0.15
27.6
7.1
39
7.9
4.6
CTB023B
8/11/97
1
27.0
7.3
38
8.0
CTB023B
8/11/97
2
26.8
7.5
38
8.1
CTB023B
8/11/97
3
26.7
7.6
38
8.2
CTB023B
8/11/97
4
26.6
7.6
38
8.2
CTB023B
8/11/97
5
26.5
7.6
38
8.1
CTB023B
8/11/97
6
26.4
7.6
37
8.1
CTB023B
8/11/97
7
25.6
7.2
37
8.1
CTB023B
8/11/97
8
22.8
7.0
43
8.1
CTB023B
8/11/97
9
21.8
6.8
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7.7
CTB023B
8/11/97
10
20.9
6.7
40
7.2
CTB023B
8/11/97
11
19.9
6.5
40
6.6
CTB023B
8/11/97
12
19.2
6.4
39
6.2
CTB023B
8/11/97
13
18.7
6.3
39
5.8
CTB023B
8/11/97
14
18.3
6.2
39
5.6
CTB023B
8/11/97
15
17.9
6.2
39
5.3
CTB023B
8/11/97
20
1.6.7
6.1
40
4.9
CTB023B
8/11/97
25
15.9
6.0
38
4.2
CTB023B
8/11/97
29.4
15.1
6.0
40
1.9
CTB023A18/11/97
0.15
27.3
7.3
36
8.0
3.6
CTB023A18/11/97
1
27.0
7.5
36
8.1
CTB023A18/11/97
2
26.7
7.6
36
8.2
CTB023A18/11/97
3
26.6
7.6
36
8.2
CTB023A1-8/11/97
4
26.5
7.6
36
8.1
CTB023A18/11/97
5
26.5
7.5
36
8.1
CTB023A18/11/97
6
26.3
7.2
35
7.9
CTB023A18/11/97
7
25.1
6.8
35
6.6
CTB023A18/11/97
8
23.4
6.3
37
5.2
CTB023A18/11/97
9
22.1
6.1
37
4.7
CTB023A18/11/97
10
20.9
6.1
37
4.5
CTB023A18/11/97
11
20.1
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4.1
CTB023A18/11/97
12
19.4
5.9
39
2.8
CTB023A18/11/97
13
19.0
5.9
39
2.4
CTB023A18
11/97
13.4
18.9
5.8
39
2.0
Page 2

0
0
7
6
E
5
x
O
m 4
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CTBO13C
CTB013C - August 11,1997
Water Depth (meters)
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Page 1

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11
CTBO15A
CTB015A -August 11, 1997
Dissolved Oxygen
26.2 +Water Temperature
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5.0
Page 1

10.0
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CTB013B
CTB013B -August 11, 1997
Dissolved Oxygen
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1
Depth (meters)
I
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Page 1

M
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CTB015C
CTB015C -August 11, 1997
8.3 -t- Dissolved Oxygen
--� Water Temperature
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Page 1

AUGUST
LAKE JAMES
OCATION DATE
MMDDY'.�meters
Depth
Temp
deg C
pH
units
SpCond
uS cm
DO
mg/1
ISecchi _
eters
CTB015A
8/11/97
0.15
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47
7.7
3.5
CTB015A
8/11/97
1
26.8
7.0
47
7.7
CTB015A
8/11/97
2
26.6
7.0
48
7.7
CTB015A
8/11/97
3
26.5
7.0
47
7.7
CTB015A
8/11/97
4
26.5
7.0
47
7.7
CTB015A
8/11/97
5
26.5
7.0
48
7.6
CTB015A
8/11/97
6
26.2
6.7
50
6.5
CTB015A
8/11/97
7
24.4
6.4
58
3.9
CTB015A
8/11/97
8
22.0
6.1
55
1.7
CTB015A
8/11/97
9
19.3
6.1
51
1.1
CTB015A
8/11/97
10
15.3
6.1
48
1.6
CTB015A
8/11/97
11
13.0
6.1
46
2.6
CTB015A
8/11/97
12
11.7
6.1
46
3.5
CTB015A
8/11/97
13
10.7
6.2
47
3.8
CTB015A
8/11/97
14
10.1
6.1
46
4.0
CTB015A
8/11/97
15
9.7
6.1
47
4.2
CTB015A
8/11/97
20
8.7
6.2
48
4.2
CTB015A
8/11/97
25
8.4
6.1
48
3.3
CTB015A
8/11/97
27.1
8.2
6.1
50
1.9
CTB013C
8/11/97
0.15
26.8
8.0
55
8.3
2.0
CTB013C
8/11/97
1
26.6
8.1
55
8.4
CTB013C
8/11/97
2
26.3
8.1
54
8.4
CTB013C
8/11/97
3
26.2
7.9
54
8.1
CTB013C
8/11/97
4
26.1
7.9
55
8.2
CTB013C
8/11/97
5
26.1
7.9
55
8.0
CTB013C
8/11/97
6
25.6
7.3
59
7.3
CTB013C
8/11/97
7
24.1
7.0
73
6.1
CTB013C
8/11/97
8
23.2
6.7
74
4.8
CTB013C
8/11/97
9
19.2
6.3
57
1.0
CTB013C
8/11/97
10
15.9
6.2
57
0.8
CTB013C
8/11/97
11
13.6
6.2
56
0.7
CTB013C
8/11/97
12
11.9
6.2
57
0.6
CTB013C
8/11/97
13
11.1
6.2
55
0.5
CTB013C
8/11/97
14
10.4
6.2
55
0.5
CTB013C
8/11/97
15
10.0
6.2
59.
0.5
CTB013C
8/11/97
16.1
9.6
6.2
68
0.5
CTB013B
8/11/97
0.15
26.5
8.1
60 '
8.7
1.1
CTB013B
8/11/97
1
25.5
8.2
63
8.9
CTB013B
8/11/97
2
22.7
7.4
72
7.9
CTB015C
8/11/97
0.15
28.6
7.2
41
7.8
5.0
CTB015C
8/11/97
1
27.2
7.3
41
8.0
CTB015C
8/11/97
2
26.8
7.5
40
8.1
CTB015C
8/11/97
3
26.6
7.5
40
8.1
CTB015C
8/11/97
4
26.6
7.6
40
8.1
CTB015C
8/11/97
5
26.5
7.6
40
8.1
Page 1

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CTB013C - July 7, 1997
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CT13015A -July 11, 1997
27.2 .2 Dissolved Oxygen
8 8.7 +Water Temperature
25.2
7.7 2.9
21.7
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Depth (meters)
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2.0
0.0
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CTBO13B
CT13013B -July 11, 1997
3
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Dissolved Oxygen
—s— Water Temperature
2 3
Depth (meters)
Page 1
4
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26.0
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CTBO15C
CT13015C -July 11, 1997
1 2 3 4 5 6 7 8 9 10 11
Depth (meters)
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30.0
28.0
26.0
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Page 1

LA F-e3S
LOCATION
DATE I
Depth
Temp
I pH
SpCond
DO
Secchi
MMDDYY
meters
deg C
units
uS/cm
mg/I
meters
CTB015A
7/7/97
0.15
27.4
6.8
42.7
7.7
4.0
CTB015A
7/7/97
1
27.3
6.9
42.8
7.7
CTB015A
7/7/97
2
27.2
6.9
42.7
7.7
CTB015A
7/7/97
3
27.2
6.9
42.7
7.7
CTB015A
7/7/97
4
25.2
7.1
43.1
8.8
CTB015A
7/7/97
5
22.9
7.1
46.7
9.2
CTB015A
7/7/97
6
21.7
6.9
46.9
8.7
CTB015A
7/7/97
7
19.8
6.5
46.7
6.9
CTB015A
7/7/97
8
18.0
6.2
47.4
5.2
CTB015A
7/7/97
9
16.2
6.1
41.4
4.2
CTB015A
7/7/97
10
14.3
6.1
45.8
4.1
CTB015A
7/7/97
15
9.6
6.2
46.5
5.2
CTB015A
7/7/97
20
8.8
6.2
47.1
5.3
CTB015A
7/7/97
25
8.4
6.2
47.6
4.8
CTB015A
7/7/97
29.3
8.1
6.1
52.2
1.7
CTB013C
7/7197
0.15
27.5
7.2
48.1
8.0
2.6
CTB013C
7/7/97
1
27.4
7.2
48.4
8.0
CTB013C
7/7/97
2
27.3
7.2
49.5
8.1
CTB013C
717197
3
27.0
7.1
49.7
7.8
CTB013C
7l7/97
4
25.6
6.6
51.9
6.6
CTB013C
7/7/97
5
23.8
6.4
56.1
4.5
CTB013C
717197
6
21.9
6.3
60.8
4.0
CTB013C
717/97
7
19.6
6.2
56.5
3.3
CTB013C
7/7/97
8
17.8
6.1
54.3
2.7
CTB013C
717197
9
15.6
6.1
54.0
2.0
CTB013C
7l7/97
10
14.1
6.1
53.9
1.3
CTB013C
717197
15
9.6
6.1
57.9
0.3
CTB013C
7l7/97
15.3
9.6
6.1
59.3
0.3
CTB013B
7/7/97
0.15
26.6
7.2
52.7
8.4
1.0
CTB013B
7/7/97
1
25.9
7.1
1 52.8
8.4
CTB013B
7/7/97
2
25.3
7.1
53.3
8.0
CTB013B
7/7/97
2.6
22.9
6.6
55.4
6.0
CTB015C
7/7/97
0.15
27.0
6.7
40.2
7.7
4.8
CTB015C
7/7/97
1
27.0
6.8
40.2
7.7
CTB015C
7/7/97
2
27.0
6.8
40.0
7.7
CTB015C
7/7/97
3
27.0
6.8
40.1
7.7
CTB015C
7/7/97
4
26.7
6.8'
38.5
7.9
CTB015C
7/7/97
5
24.6
7.0
40.8
8.8
CTB015C
7/7/97
6
22.6
7.1
41.0
9.1
CTB015C
7/7/97
7
21.0
6.9
42.0
8.9
CTB015C
7/7/97
8
19.9
6.8
41.9
8.7
CTB015C
7/7/97
9
19.4
6.7
41.1
8.6
CTB015C
7/7/97
10
18.9
6.4
41.2
7.8
CTB015C
7/7/97
15
17.1
6.1
42.5
6.2
CTB015C
7/7/97
20
16.0
6.1
45.0
5.2
CTB015C
7/7/97
25
15.3
6.1
43.7
5.1
CTB015C
7/7/97
30
14.2
6.1
42.6
4.9
CTB015C
7/7/97
33.7
12.9
6.1
44.4
3.7
Page 1

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LAKE JAMES
COUNTY:
Burke BASIN:
SURFACE AREA: 2635 hectares (6510 acres)
CLASS:
Catawba
USGS TOPO: Glen Alpine, N.C.
WS-V WS-IV B LAKE TYPE:
1997 Data Summary
Reservoir
Sampling Date:
June 9,1997
July 7,1997
August 11,1997
NCTSI:
-5.0
-3.4
-3.2
Trophic State:
Oligotrophic
Oligotrophic
Oligotrophic
Mean Secchi Depth:
4.1 m
1.9 m
3.3 m
Mean TP:
0.01 mg/L
0.01 mg/L
0.02 mg/L
Mean TON:
0.16 mg/L
0.21 mg/L
0.18 mg/L
Mean CHLa:
2 µg/L
3 µg/L
4 µg/L
Surface Physical Data
Conductivity:
36-47 µmhos/cm
37-53 µmhos/cm
36-60 µmhos/cm
Dissolved Oxygen:
8.3-8.9 mg/L
7.7-8.4 mg/L
7.7-8.7 mg/L
Water Temperature:
18.4-18.9 °C
26.6-27.5 °C
26.5-28.6 °C
pH:
6.8-7.2 s.u.
6.7-7.2 s.u.
6.9-8.1 s.u.
Lake James , which is owned by Duke
Energy, was created by three dams which
impounded waters of the Catawba River and
the Linville River on the eastern edge of the
Appalachian Mountains.. Construction of the
dams began in 1916 and was completed in
1923. The Catawba River, the North Fork of
the Catawba River, and the Linville River are
its major tributaries. The lake has 150 miles of
shoreline, a maximum depth of 141 feet (43
meters) and a hydraulic retention time of 228
days. The most upstream of the
impoundments in the Catawba Chain Lakes
system, Lake James is hydrologically divided
into two units: the Catawba River section and
Linville River section. These units are
connected by a manmade canal located at the
Highway 126 bridge. The watershed is
primarily forested and is characterized by
rolling hills. The waters of Lake James are
used to generate electricity at the Bridgewater
Hydroelectric Plant and for recreational
purposes.
Lake James is owned by Duke Power
Company and is classified WS-IV, WS-V and
B. It has a mean hydraulic retention time of
228 days. The waters of Lake James are used
to generate electricity at the Bridgewater
Hydroelectric Plant and for recreational
purposes.
Lake James was most recently monitored in
June, July and August, 1997. Based on the
NCTSI scores, Lake James was found to be
oligotrophic on the days it was sampled
during the growing season of 1997. The
lowest Secchi depths and highest total

phosphorus values were generally found at
the sampling site in the upper Catawba River
arm of the Lake (CTB013B). The highest
chlorophyll a value (10 µg/L) was also found
at this sampling site in July and August.
Metals were below DWQ laboratory detection
levels except for zinc, (35 µg/L in July and 41
µg/L in August) and copper (2.9 µg/L in
July). These values were less than the
applicable state water quality standards for
each metal. Fecal coliform bacteria
concentrations ranged from less than 10 to 18
colonies per 100 ml. Based on NCTSI scores,
Lake James was found to oligotrophic on each
of the three days that it was sampled during
the growing season of 1997. Algal Growth
Potential Tests conducted for Lake James in
1997 indicated that the lake was phosphorus
limited at five of the six sites sampled. The
most upstream sampling site (CTB013B) was
found to be nitrogen limited (Appendix L).
The control Mean Standing Crop (MSC)
ranged from 1.31 mg/L (CTB015C) to 4.88
mg/L at the most upstream lake sampling site
(CTB013B).

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State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Division of Water Quality
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
.Attention: Ken Harris
Lake James- Environmental Association
Six South Logan Street
Marion, North Carolina 28752
Dear Mr. Harris,
January 2, 2001
Subject: Permit Number NCO031879
Marion — Corpening Creek
McDowell County
Regarding your letter of December 18, 2000, 1 want to assure you that we, at the
Asheville Regional Office, have tried to respond to all of your requests for information in an
accurate and factual manner. I assure you that there has been no effort towithhold,
misrepresent or cover up any of the events regarding the permitting process.
I want you to know that our files are open for your inspection and I am available to
arrange time for you and your organization, to view them.
Next, the Department's permitting unit in Raleigh will be glad to discuss the permitting
process with you and/or your organization, with regards to the Corpening Creek and Catawba
River Wastewater Treatment Plants. The unit can be reached at [phone], extension 517
— Dave Goodrich Supervisor. I have forwarded a copy of your request to them and they are
aware of your concerns.
Finally, I have spoken to Forrest Westall, Supervisor — Water Quality Section, Asheville
Regional Office, and he and I will be glad to make ourselves available to meet with you and your
organization to answer questions regarding this matter or other environmental concerns.
Please, contact me at 828/251-6208 and I will arrange a time and place.
Should you have any questions, please do not hesitate to call me.
Sincerely,
G
rry Frost
Environmental Technician

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Larry Frost - Larry.Frost(ancmail.net
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone] ext: 288
Fax: [phone]
Dear Larry,
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12/18/00
As you know, Lake James Environmental Association has made several requests in
the last few months for information regarding the City of Marion's permit renewal
process for the Catawba River and Corpening Creek WWTPs.
After reviewing your last a -mails and the other information we have received from
DENR Asheville in the last few months we would ask you for a full explanation, on your
letterhead, for the discrepancies therein.
It would appear from our point of view that information has been withheld and
misrepresented, and that there has been an effort to cover up the'events. Considering our
active involvement and vested interests in Marion's WWTPs, and the permanent affects
on our community, we are appalled at the possibility of such reprehensible conduct.
When you factor in your office's acute awareness of our requests for information- well,
let's just say that we are extremely upset.
We would like to give your office the first opportunity to respond and to dispel our
view. Please do so immediately and without delay, as time is of the essence in this matter.
Please send your response addressed to me at Six South Logan Street, Marion, N.C.,
28752.
Please include your new e-mail addresses; I have been trying to contact you by e-
mail for several days. Apparently your addresses have changed since last week.
Sincerely,
Lake James Environmental Association
keno harrisrealty.org
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Larry Frost - Larry.Frost(a,ncmail.net
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone] ext: 288
Fax: [phone]
Dear Larry,
12/18/00
As you know, Lake James Environmental Association has made several requests in
the last few months for information regarding the City of Marion's permit renewal
process for the Catawba River and Corpening Creek WWTPs.
After reviewing your last a -mails and the other information we have received from
DENR Asheville in the last few months we would ask you for a full explanation, on your
letterhead, for the discrepancies therein.
It would aunear from our point of view that information has been withheld and
misrepresented, and that there has been an effort to cover up the events. Considering our
active involvement and vested interests in Marion's WWTPs, and the permanent affects
on our community, we are appalled at the possibility of such reprehensible conduct.
When you factor in your office's acute awareness of our requests for information- well,
let's just say that we are extremely upset.
We would like to give your office the first opportunity to respond and to dispel our
view. Please do so immediately and without delay, as time is of the essence in this matter.
Please send Your response addressed to me at Six South Logan Street, Marion, N.C.,
28752.
Please include your new e-mail addresses; I have been trying to contact you by e-
mail for several days. Apparently your addresses have changed since last week.
Sincerely,
n arris
Lake James Environmental Association
kenAharrisrealty.org
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