NC0086053_Owner (Name Change)_20201027

I .
/% f Junaluska Sanitary District
isilP.O. Box 35
Lake Junaluska, NC 28745
828-452-1178
www.jsdwater.org
October 23, 2020
NCDEQ/DWR/NPDES RECEIVED
OCT 2 7 2020
Re: Permit Name/Ownership Change Form
NPDES NC0086053 NCDEQ/DWRINPDES
Dear Sirs,
I am writing on behalf of the District regarding our attached application and submittal for the Discharge
Permit Name/Ownership change from Pilot Truck Stop to Junaluska Sanitary District (JSD). We are
currently wrapping up a Capital Improvement Project that was funded through Golden Leaf, Haywood
County and SRF to install new sewer lines for Riverbend Elementary, Pilot Truck Stop and Sam's Mart
convenience center.All three entities were on failing septic systems with the Pilot and Sam's Mart both
incurring NOV's from DEQ. This was a joint project to aid these operations and connect them to a new
public sewer system.
With that, over a year ago our Engineer communicated with the Regional and State office to make
inquiries about the ability and process of JSD acquiring Pilot's discharge permit (transferring it to our
name). Through those conversations, we learned this was achievable and were informed on the proper
course of action to do so. With that understanding, the District set in motion with Pilot to take over the
name of this permit.
Just recently, in follow up discussions with the Regional and State office regarding our submittal and
application,we have been informed by the regulators that this permit will be denied. Furthermore,it was
stated it would be denied even before reviewing this application.
On behalf of JSD, lam hoping our submittal and application is fairly reviewed and considered as we have
followed all the appropriate submittal processes, and believe that we meet all criteria for this application
to be approved
Sincerely,
ItA-
Jos Nickol
GM/Finance Officer
Junaluska Sanitary District
CC:Junaluska Sanitary District Board Members
P7CEIVED/NCDEQIDWR
OCT 272020
Non-Discharge
Permitting Unit

.13.•
BROWN CONSULTANTS FA
October 16,2020.
Technical Memorandum
•
To: NCDEQ/DWR/NPDES
1617 Mail Service Center
Raleigh,NC.27699-1617
From: Jeffrey T. Brown,PE
•
Co
Josh.Nickel
District Manager and CFO
•
•
Re: Permit Name/Ownership Change Form
NPDES.NC0,08•605 •
Dear Sirs:
Please find WS Letter as a Request for Approval of the Ownership for the•NDPES Permit
NC00..8,603..The current pentittee is the Pilot Travel Center 3 .3.The Junaltiska.Sanitary
District(ISD)is applying for the Name Change/Ownership of the Permit. Please find
attached the following items:
1. Permit Name/Ownership Change•Forin
2. Legal Documentation.ofthe transfer of Ownership.
Based upon my conversation with the NPDES Unit and NCDEQ Staff,the Process, as we
were instructed to change the Ownership of.a Permit is as follows:
1. Complete a Legal Tronsfer(documentation)of the Ownership
.2. Complete the Permit Name/Ownership forni(NCDEQ)
3. Once these documents are completed.submit to NPDES in Raleigh
Once the OwnerShip is enlarged,NPDES will review the Permit/Permit Limits,etc.for
the new owner prior to releasing use of the Permit.
30 Ben Lippen School Road,Suite 202,Asheville,NC 28806>828.350.7683[office]>NC License No.:C-3214>www.brownpa.net

r
In the Example given to us,the name change/transfer would occur THEN if the new
owner desires to amend the Permit,that would require completing and review by staff of
the EAA.
Based upon this criterion,we are submitting to the NPDES unit items 1,and 2 above
(attached)for initial Approval and Transfer of Ownership of the Permit.
Upon Approval of the Ownership Change,the JSD will Complete and Submit the EAA
for Approval.
Additional and Information is attached just a quick understanding/overview of the 1
location of the discharge. Included are the five items identified in Step I of the EAA..
This is for your information and use only at this time. Certainly once the Name Change is
Approved we will submit the Full EAA as required.
If you have any questions or need any further information,please do not hesitate to
contact me this office

PAT MCCRORY
4 . .. . ..
DONALD R. VAN DER VAART
S. JAY 2IMMEIb MAN
Water Resources
squimetwoo vAt 4tiAi Mr
PERMIT NAME/OWNERSHIP CHANGE FORM
I. CURRENT PERMIT INFORMATION:
Permit Number: NCOO 8 /6 /0 /,S/ 3 or NCGS / / / /
1. Facility Name: I )11.01 l e- 4 EL. C Ef4T€L. 3g3 3
It. NEW OWNER/NAME INFORMATION:
1. This request for a name change is a result of:
Xa. Change in ownership of property/company
b. Name change only
c. Other(please explain):
2. New owner's name(name to be put on permit):
T i tarIPI.OSKA tDil'kriti-PO '", 1 ) kle ICI i
3. New owner's or signing official's name and title: ,.S'o►i 14 le-gm( .
(Person legally responsible for permit)
t•aeaft. AhiPltvcv i APO OK' r.
.,t22 g,ne) _
4- Mailing address: PO �0!' 76 Citylajee 1 J RI P•uJ SILty
State: Mc. Zip Code: 2,9?L I Phone:(5Z6) +�
E-mail address: j pi 1 A K a _ , S e><1a)('t!y . o r c�
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY TFIE DIVISION UNLESS ALL OF THE
APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS: r
i
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a property deed, articles of
incorporation, or sales agreement)
[see reverse side of this page for signature requirements]
Stale of-North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh,NC 27699-1617
919 807 6300 919-807-6389 FAX
httpsJ/deq.rx.gov/about/d i visionshvater:resou teedwa lei-Peso ones-Perm i t s/waslevrater-hmelAp d es-waste water-permits

NPDES Name&ownership Change
Page 2 of 2
Applicant's Certification:
, attest that this application for a
name/ownership Ehange has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature•/,%
� Date' l0/ 20
•THE COMPL TECH APPLICATIOftl:3 ACKAGE, INCLUDING ALL SUPPORTING
INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DEC)/DWR I NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 7/2016

This instrument prepared by
Sales Agreement
THIS SALES AGREEMENT made and entered into by JUNALUSKA SANITARY DISTRICT, a body politic and
corporate, [herein "the District"] and Pilot Travel Centers , LLC ,5508 Lonas Dr, Knoxville, TN 37909 [herein
"Grantor"].[The District and Grantor may also variously be collectively referred to herein as"the Parties".]
The Sole purpose of this Sales Agreement is to provide an agreement of the Transfer of Ownership of the NPDES
Permit No NC0086053.
WHEREAS, the District is a sanitary district established pursuant to N.C,G.S. Section 130A-47 et seq.,which desires to
take over Ownership of the NPDES Permit No 0086053.
WHEREAS, Grantor is the owner of the NPDES Permit No. NC0086053.
WHEREAS, the Parties desire to define the relative rights of the Parties in respect to the matters addressed herein.
NOW THEREFORE, in consideration of the mutual covenants, conditions and promises herein contained, and
other good and valuable consideration,the receipt of which is hereby acknowledged,
IT IS HEREBY AGREED as follows:
1) GRANTOR CONVEYANCES.Grantor hereby grants and conveys to the District the following:
The transfer of Ownership of the NPDES Permit No. NC0086053, not to include any physical assets, such as
piping, buildings, tanks, pumps,wwwtp appurtnaces.
2) THE DISTRICT.
The District hereby , in exchange for the NCPDES Permit No NC 0086053, conveys to the Grantor a
commercial pump station, backup generator, and connection the District Sewage System.
REMAINDER OF PAGE INTENTIONALLY LEFT BLANK

IN WITNESS WHEREOF on the day and year indicated in the respective notarization, Grantor has caused this
instrument to be duly executed in its name for the purposes herein stated by its duly authorized representatives
as Grantor's official act.
Pilot Travel Center, LLC
ByL`- ./i / Z.- -----
0(9 r L_;.. 'P — b:Ee (, / .4.,ra 4-44/
Name and Offi6l
[COMPANY SEAL]
State of /G.UIne-1Y'e.
County of kiNio,
I, . 1 !^r' L- BIwlce_ [Type or Print Name], a Notary Public for the County of
Kr'c> , State of le'11,v",`�c _ ,hereby certify that on this day:
• The foregoing instrument was produced to me in Knox County, / r_r-1+1 '5S �. .
• Before me, SO \I C .), Dirrs_or- /04 of Pilot Travel Center
personally appeared ISefore m4 and acknowledged the execution of the foregoing instrument by authority duly
given and as the act of the corporation, the foregoing instrument was signed in its name by him/her its
Dir r -CPAA. and sealed with its corporate seal.
• -Met{ C, -" p is known to me and known to me to be the person described in the foregoing
instrument.
This the )t,} day ofkleIN—2020.
i Ai ,�.,.--., , tII ILL jLc My Commission Expires— Io�-)O" [Affi IQ cyp2 /'/.
Signature 6j Notary :2-;•• . -/. r.
fi. StiPEE •%V-
1`+ l� 2 Typed or Printed Name of Notary rr�: NNESSEE
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TENo-rP '
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IN WITNESS VI/HEREOF on the day and year indicated in the respective notarizations,the parties have caused
this instrument to be duly executed in their respective names for the purposes herein stated or by their duly
authorized representatives as their individual official act.
JUNALUSK,A SANITARY DISTRICT
--` R j
By: �"� a v r" [Official Sea!]
Josh`kid --(;)
< ,General Manager [
North Carolina-Haywood County
&a'io .t
I. lima r&-i4,8,F2 G a Notary Public for-I}aywvod County, North Carolina, certify that Josh Nickol, General
Manager of JUNALUSK4 SANITARY DISTRICT, a body politic established pursuant to N.C.G.S. Section 130A-47 et
seq., personally appeared before me this day and acknowledged the execution of the foregoing instrument by the
authority given him as the General Manager on behalf of JUNALUSKA SANITARY DISTRICT.
Ti
WITNESS my hand and official stamp or seal,this the /7 day of aro 6 4 2020.
CA My Commission Expires— ®3//gi//99001, [Affix Notary Seal]
1 LaFeinberer g- Not y Publi-
a`a ' P.F Et�NBE9c.
I NOTARY • �1.�
PUBLIC
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Engineering Alternatives Analysis (EAA) Guidance Document
North Carolina Division of Water Resources
NOTE: The N.C.Division of Water Resources (DWR)will not accept an NPDES application for a new or
expanding wastewater treatment plant discharge unless all the requited application requirements are
submitted. A complete NPDES application will include the following items:
NPDES Application Form(in triplicate)
Application Fee
Engineering Alternatives Analysis (in triplicate)
Local Government Review Form(non-municipals only)
Failure to submit all of the required information will result in return of the incomplete package. If you have
any questions about these requirements, contact the NPDES Unit staff Contact names,application forms,
applicable fees,and guidance documents are available on the NPDES website at:
https://deq.nc.gov/about/divisionstwater-resources/water-resources-permits/was tewa ter-branch/np des-
wastewater-permits. Completed applications should be mailed to: NCDENR/DWR/NPDES Complex
Permitting Unit,1617 Mail Service Center,Raleigh,NC 27699-1617.
Background
The NPDES permit program was enacted in 1972 as part of the Clean Water Act. The original goal of the program
was to eliminate all point source discharges to surface waters by 1985. Although this goal was not achieved, the
NPDES program continues to strive toward it In that light, an Engineering Alternatives Analysis (EAA) is
required with any NPDES application for a new or expanding wastewater treatment plant discharge, in
accordance with 15A NCAC 2H.0105(c)(2). In order for an NPDES application to be approved, the EAA must
provide complete justification for a direct discharge to surface water alternative,and demonstrate that direct discharge
is the most environmentally sound alternative selected from all reasonably cost-effective options [per 15A NCAC
2H.0105(c)(2)].
The purpose of this EAA Guidance Document is to provide guidance to the regulated community for the evaluation of
wastewater disposal alternatives. The impetus behind this comprehensive guidance was based on the following 1) a
majority of new NPDES applications were being returned as incomplete due to inadequate EAA submissions;and 2) a
few recent court cases resulted in unfavorable rulings for the NPDES discharger due in part to inadequate EAAs.
DWR most frequently returns EAAs as incomplete due to inadequate flow justification, inadequate alternatives
evaluations,and/or lack of documentation/references used to design and cost alternatives.
Please note that this guidance document is designed primarily for domestic wastewater discharges. For other proposed
discharges such as water treatment plant discharges from ion exchange and reverse osmosis units, some alternative
disposal options may not be technologically feasible. Within this guidance document,we have attempted to point out
where such technological limitations may exist. You are urged to review NPDES permitting guidance documents on
the NPDES website,which discuss some of the limited disposal options for some discharges.
Please note that if a proposed municipal expansion is subject to SEPA Environmental Assessment
(EA)/Environmental Impact Statement (EIS) requirements, the EAA requirements should be incorporated into the
SEPA document In addition,the NPDES Unit cannot accept an application for a new/expanding NPDES discharge
until departmental review of the SEPA document is complete and a Finding of No Significant Impact(FONSI) has
been submitted to the State Clearinghouse for circulation.
EAA Guidance Document Revision:October 2019
Page 1 of 8

•
The following step-by-step outline should be used for the preparation of all EAA submissions. If an FAA submission
lacks any of these basic elements,the NPDES application will be returned as incomplete.
STEP 1. Determine if the proposed discharge will be allowed
Before beginning any engineering evaluation of alternatives, you must first determine if the proposed wastewater
discharge will be allowed. Otherwise, time and money may be spent needlessly for an EAA preparation that will
ultimately be rejected on the basis of existing water quality restrictions. There are several potential restrictions to a
wastewater discharge to surface waters,including
• Zero flow stream restrictions [15A NCAC 2B.0206(d)(2)] apply to oxygen-consuming waste in zero-flow
streams. In order to determine streamflow at the proposed discharge location, contact the U.S.
Geological Survey at 919-571-4000.
• Receiving stream classification restrictions [e.g., ORW,WS,SA,NSW,and HQ class waters have various
discharge restrictions or require stricter treatment standards]. Stream classifications are available on the
the DWR Classification and Standards/Rule Review Branch website:
(http://portal.ncdenr.org/web/wq/ps/csu), while wastewater discharge restrictions for various stream
classifications are presented in state regulations [15A NCAC 2B.0200].
• Basinwide Water Quality Plans. These basin-specific plans list NPDES permitting strategies that may
limit wastewater discharges to particular streams within the basin due to lack of stream assimilative
capacity, etc. Basin plans are available on the DWR website, or you may contact the DWR Basinwide
Planning Branch(http://portatncdenr.org/web/wq/ps/bpu)..
• Impaired waters and TMDLs. Certain waterbodies listed as impaired on the 303(d)list and/or subject to
impending TMDLs may have wastewater discharge restrictions. The list of 303(d) impaired waters is
located on the DWR website, or you may contact the DWR Modeling and Assessment Branch
(http://portal.ncdenr.org/web/wq/ps/mtu).
• Presence of Endangered Species. If endangered species are present in the proposed discharge location,
there may be wastewater discharge restrictions. Endangered species information may be included in the
Basinwide Water Quality Plan, or you may contact the U.S. Fish and Wildlife Service (919-856-4520),
N.C. Wildlife Resources Commission (919-733-3633), or the N.C. Natural Heritage Program (919-733-
7701).
Municipal applicants.
As a public service, the NPDES Unit will evaluate whether a proposed municipal discharge is considered allowable.
The municipality needs to initiate this review by submitting a letter request for Speculative Effluent Limits to the
NPDES Unit. You must obtain streamflow estimates for the proposed discharge location to ensure that the receiving
stream is not subject to zero flow restrictions. Low flow data (specifically, drainage area, summer and winter 7Q10,
average flow and 30Q2 flow statistics) can be obtained for a nominal fee from the U.S. Geological Survey in Raleigh at
919-571-4000. The low flow data must be submitted with the speculative limits request letter. If the proposed
discharge appears to be allowable, the NPDES Unit will prepare speculative effluent limits for a maximum of 2 flows
and 2 discharge locations using water quality models. The municipality can then use the speculative limits to prepare
preliminary engineering design and cost estimates for the direct discharge alternative within the EAA. In limited
instances where complex water quality models are necessary to develop speculative limits and determine potential water
quality impacts,some municipalities have undertaken the modeling effort(with DWR review)in order to expedite this
portion of the NPDES permit review process.
Non-municipal applicants.
Due to staff constraints, the NPDES Unit cannot prepare speculative limits for non-municipal applicants. Thus,it is I`
your responsibility to make your own determination as to whether the proposed discharge might be allowed by the
Division,by evaluating the water quality factors listed above. It is highly recommended that you discuss the proposed
discharge with the applicable DWR Regional Office and/or NPDES Unit staff,who may be able to provide input on
EAA Guidance Document Revision:October 2019
Page2of8

the likelihood of a new/expanding discharge. As a first step,you must obtain streamflow estimates for the proposed
discharge location to ensure that the receiving stream is not subject to zero flow restrictions. Low flow data
(specifically, drainage area,the summer and winter 7Q10, average flow and 30Q2 flow statistics) can be obtained for a
nominal fee from the U.S. Geological Survey in Raleigh at 919-571-4000. The low flow data must be submitted with
the EAA,and will be used by the permit writer to develop permit limits. You must also verify that the proposed action
(i.e., construction of a wastewater treatment plant and its appurtenances) is consistent with local zoning and/or
subdivision ordinances. You will need to request the local government(s) to complete a Local Government Review
Form(Attachment A),and include the signed and notarized form with your NPDES application package.
All applicants.
If you conclude that the proposed discharge will pass the "allowable discharge" criteria, then begin the EAA
preparation by summarizing the following general information about the proposed project
■ Provide a description of the proposed project. If the project will be constructed in phases, provide a
schedule for constructing each additional phase,and provide the projected flow per phase(see STEP 2).
■ Applicant name,mailing address,phone number,contact person
■ Facility name,address,county,phone number,.contact person
• EAA preparer's name,mailing address,phone number,contact person
STEP 2. Provide reasonable projections for population and flow
Residential Population Projections.
Facilities requesting an NPDES discharge permit for new or expanding domestic wastewater discharges must
document the population to be served within the service area over a 20-year planning period. The NC State
Demographics unit provides population data for each county and municipality and can be accessed on the Internet at
http://www.demog.state.nc.us. If 20-year population projections for specific areas are not available, a linear
extrapolation of population trends from the past decade should be used. Any deviation from a linear projection
method must be dearly justified. If population projections include future annexations,include a proposed annexation
schedule as well as any annexation requirements that must be met.
Municipal Flow Projections.
Justification of flow as well as a demonstration of need shall be provided. Mere speculation is not sufficient. Flow
projections should represent average anticipated flows, since permit flow limits are based on monthly averages.
Peaking factors used to design various components of the wastewater collection system (e.g., collector sewers,
interceptor sewers, pumping stations) should not be used in the justification of the average anticipated flow. For
municipal wastewater dischargers,flow must be justified using the Clean Water Loan Program(CWLP) Guidance for
Preaparing Engineering Reports available on the Internet at http://portal.ncdenr.org/web/wi/cleanwater/er.
Exceptions to these flow criteria may be approved on a case-by-case basis provided adequate justification is supplied.
• Current Flow- Provide current flows including residential, commercial,industrial, and infiltration/inflow
(I/I) based on actual flow data or water billing records. Current residential flow and current commercial
flow may be based on water billing records minus a 10% consumptive loss. Current industrial flow may
be based on dual metering to deterinirie:consumptive losses.
• Future Residential Flow- Provide 20-year residential flows based on projected residential growth.
Multiply the projected growth in residential population by 70 gallons per clay per capita.
• Future Commercial Flow- Provide 20-year commercial flows based on projected residential growth.
Multiply the projected growth in residential population by 15 gallons per day per capita.
• Future Industrial Flow- Provide flow for future documented industrial flow. A nominal allowance for
future unplanned industrial expansions may be considered by the Division,provided the basis is dearly },
justified and current land-use plans and local zoning allow for such industrial growth.
EAA Guidance Document Revision:October 2019
Page 3 of 8
•

V
Non-Municipal Flow Projections.
Flow may be justified in accordance with 15A NCAC 2H .0219(1) for various activities (e.g., new subdivisions,new
schools, various commercial activities). For other proposed discharges (e.g., groundwater remediation, water
treatment plant filter backwash, industrial facilities), the flow projections will be based on engineering design
considerations and/or production projections rather than population projections.
STEP 3. Evaluate technologically feasible alternatives
Since a goal of the Clean Water Act is to minimize or eliminate point source discharges to surface waters, any
proposal for a new or expanding wastewater discharge must include evaluation of wastewater disposal alternatives in
addition to direct discharge. Particularly for dischargers of domestic wastewater,this evaluation should investigate the
feasibility,of the following wastewater disposal alternatives:
■ Connection to an existing wastewater treatment plant(public or private)
■ Land application alternatives, such as individual/community onsite subsurface systems, drip irrigation,
spray irrigation
• Wastewater reuse
• Surface water discharge through the NPDES program
• Combinations of the above
In order for the applicant to eliminate a wastewater-disposal alternative, you must either show that the alternative is
technologically infeasible, or that it would be cost prohibitive to implement relative to a direct discharge alternative.
Please note that for some alternatives,it might be easier to prove an alternative is not viable based on high cost rather
• than technological feasibility. For example, for a large municipal expansion that would require several hundred acres
for a land application alternative,it might be easier to simply assume that the required acreage could be purchased and
calculate the present value costs (including current market land costs) for this option, rather than evaluating whether
land application is technologically infeasible due to lack of available land and/or poor soil conditions. For those
alternatives identified as technologically feasible, you must develop and compare costs, based on a preliminary level
design effort(see STEP 4).
The Division recognizes that wastewater disposal alternatives may be limited for some non-domestic wastewater
scenarios,and a full alternatives evaluation may not be warranted. If there is some question as to whether an alternative
may be eliminated, contact the NPDES Unit staff. Some scenarios that might not require a full alternatives evaluation
include:
• Water Treatment Plant Discharges. Discharges from water treatment plants (WTPs) that utilize a
membrane technology (e.g., reverse osmosis, nanofiltration) or ion exchange system tend to generate
highly concentrated wastestreams. These wastestreams are not amenable to land application and do not
have to be evaluated for this alternative. However,since these wastestreams can also have a toxic impact
on a receiving freshwater system,proposed new discharges from these WTPs to freshwaters will not be
considered for an NPDES permit unless you can demonstrate that the environmental impacts would be
minimal based on dilution modeling. You should investigate whether the wastewater can be piped to a
stream with sufficient dilution, or whether a local WWII' might accommodate this discharge. Please
note that discharges from WTPs that utilize greensand filtration or conventional technology produce a
wastestream that is not saline, therefore no disposal alternatives can be automatically ruled out as
infeasible for these other WTPs. Refer to the NPDES website for permitting strategies for: reverse
osmosis,ion exchange,greensand filtration,and conventional WTPs.
• Groundwater Remediation System Discharges. You will need to evaluate whether WWII' connection,
land application,infiltration galleries,in-situ groundwater remediation wells, or dosed-loop groundwater
remediation wells are viable disposal alternatives. While land application might be a feasible alternative in
rural areas,it would not be a feasible alternative in downtown Charlotte,where there is no land available
EAA Guidance Document Revision:October 2019
Page 4 of 8

r
for wastewater application. In this instance,you may simply state that land application is infeasible based
on land constraints within the city. You will also need to evaluate connection to an existing WWTP (in
accordance with Alternative A),since there are some municipalities that have accepted this wastestream
in the past. If the municipality will not accept the wastestream, the connection alternative is also
considered technologically infeasible. Please note that in-situ and closed-loop groundwater remediation
wells are permittable well types and further guidance is available through the Aquifer Protection Section.
Aside from these exceptions,you should proceed with the alternatives evaluation in accordance with the following
requirements. If you have any questions about these requirements,contact the NPDES Unit staff.
Alternative A. Connection to an Existing Wastewater'Treatment System.
You must evaluate the feasibility of connecting to an existing wastewater treatment system served by a municipality or
other entity holding a valid NPDES or Non-Discharge Permit All connection options should include an evaluation of
a gravity line and/or force main with pump station(s).
1. Existing Sewerage System:
(a) Identify whether there are existing sewer lines within a five-mile radius, or consider a greater radius if
cost effective for the project size.
(b) Provide a preliminary indication of flow acceptance from existing municipal or private WWTPs
under consideration for connection. If a municipal or private WWTP cannot accept the wastewater,
include a letter documenting such and consider this alternative technologically infeasible.
(c) If an existing sewerage system will accept the wastewater, evaluate the piping/pumps/resources
necessary to connect to the existing wastewater treatment plant. Attach a topographic map or a site
drawing showing the physical route of this alternative. Conduct a Present Value Cost Analysis per
SllP4.
2. Planned Sewerage System:Determine if a regional sewerage system within a five mile radius is projected
to be available within the next five years to receive waste from the project site. If applicable, determine
availability date and flow acceptance projection from appropriate authority.
Alternative B. Land Application.
Land application disposal alternatives include individual/community onsite subsurface systems, drip irrigation, and
Y irriga
tion.
ti
1. Provide an estimate of the best case hydraulic loading rate based on County Soil Surveys or from a soil
evaluation performed by a soil scientist.Include calculations showing the hydraulic loading rate and
the total area of land needed for the land disposal system,including buffers.
2. Assess the availability of land. If insufficient land is available onsite, assume that the necessary land can
be purchased and estimate the land purchase cost based on local real estate prices. Alternatively,provide
documentation to demonstrate that insufficient land is available for sale in the project area (include letters
from adjacent property owners indicating no interest in selling property).
3_ Provide a description of the wastewater treatment system and the non-discharge application system.
Include a site plan showing the proposed layout, the application area, any existing structures,proposed
structures,and other uses within the site.
4. Explain the proposed reuse plan if reclaimed water will be used by a third party.
5. Conduct a Present Value Cost Analysis per STEP 4. For the reclaimed water system include the potential
revenue generated by selling the water.
6. Provide all calculations,documentation and maps as necessary to support assumptions and conclusions.
7. Note:The design of land application systems must meet the treatment and design requirements specified
in 15A NCAC 2T.05 or 15A NCAC 18A.1900.
8. Note: Proposed discharges from groundwater remediation systems must evaluate the potential for an
infiltration gallery treatment alternative.
Alternative C. Wastewater Reuse.
You must evaluate reusing all or a portion of the wastewater generated. Some municipalities arc currently reusing
wastewater within the confines of their WWTP property for irrigation, toilet flushing, backwashing, etc., while other
municipalities have established progressive reuse programs for residential irrigation. Reuse applications might include
EAA Guidance Document Revision:October 2019
Page 5 of 8

golf course irrigation, crop irrigation (e.g., hardwood or pine plantation, grasses), athletic field irrigation, landscape
uses, and commercial/industrial uses. Some of these reuse applications will be evaluated under Alternative B,Land
Application. The design of reclaimed water systems must meet the treatment and design requirements specified in
15A NCAC 2U.
Alternative D. Direct Discharge to Surface Waters.
1. No new or expanding(additional) discharge of oxygen-consuming waste will be allowed to surface waters
of North Carolina if both the summer 7Q10 and 30Q2 streamflows are estimated to be zero, in
accordance with 15A NCAC 2B.0206(d). Private applicants must contact the USGS in Raleigh at 919-
571-4000 and obtain (generally for a nominal fee), the receiving streamflow data (s7Q10, 30Q2, annual
average streamflow) at the proposed discharge location. This information must be induded in the EAA,
and will be used to develop permit limits.
2. All direct discharge systems of oxygen-consuming wastes should be evaluated both with tertiary filtration
[BOD5=5 NH3-N=1 m 1 and without,andregime.
mg/1, g/] assuming a weekly sampling
3. Provide a description of the proposed wastewater treatment facilities, including a schematic diagram of
the major components and a site plan of the treatment facility with outfall line(s).
4. Provide documentation of the availability of required land and/or easement agreements.
5. Conduct a Present Value Cost Analysis per STEP 4.
6. Note:All direct discharge treatment systems must comply with Reliability Requirements specified in 15A
NCAC 2H.0124.
Alternative E. Combination of Alternatives,
You should evaluate the possibility of a combination of wastewater alternatives that would minimise or eliminate a•
direct discharge alternative. For example, consider whether the facility can operate a land application system during
the dry season when streamflows are at their lowest and provide less dilution, and operate an NPDES discharge
system during the wet season when soils may not be as amenable to land application and the receiving stream
provides its greatest dilution.
STEP 4. Evaluate economic feasibility of alternatives
To provide valid cost comparisons among all technologically feasible wastewater alternatives identified.in STEP 3,a 20-
year Present Value of Costs Analysis (PVCA) must be performed. A preliminary design level effort is considered
appropriate for comparing feasible options. and their associated costs. For the PVCA cost comparison, all future
expenditures are converted to a present value cost at the beginning of the 20-year planning period: A discount rate is
used in the analysis and represents the time value of money(the ability of money to earn interest). Present value is also
referred to as "present discounted value" or"present worth".
The. PVCA should include all monetary costs associated with construction, startup and annual operation and
maintenance of a facility. All unit cost information must be provided, and costs must be referenced. Costs can be
referenced in paragraph format by summarizing the sources utilized (e.g., vendor quotes, realtor land quotes, past
bids, Means Construction Index, etc). Venderr quotes received for treatment units or other components, as well as
realtor land quotes,shall be included as well. For each treatment alternative identified as technologically feasible,costs
should include,but not be limited to,the following:
Capital Costs.
• Land acquisition costs
■ Equipment costs
■ Labor costs
• Installation costs
• Design costs
EAA Guidance Document Revision:October 2010
Page 6of8

Recurring Costs
• Operation and maintenance costs (with replacement costs)
• Laboratory costs assuming a weekly monitoring regime for discharge systems and a monthly regime for
non-discharge systems
• Operator and support staff costs
• Residual disposal costs
• Connection fees and subsequent user fees
• Permit and compliance fees
• Utility costs (power,water,etc.)
Lost Opportunity Costs
PVCA Calculation Method.
The following standard formula for computing the present value must be used in all cost estimates made under this
evaluation:
PV=c +E C,
(l+r)'
Where:
PV =Present value of costs.
Co =Costs incurred in the present year.
Ct =Costs incurred in time t.
t =Time period after the present year(The present year is t=0)
n =Ending year of the life of the facility.
r = Current EPA discount rate. EPA adjusts this rate annually on October 1, and it can be accessed from
the Internet at http:/www.nccgl.net/fap/cwsrf/201gui.htmt
If recurring costs are the same in years 1 through 20,then Ct=C and the formula reduces to:
n
PV= C +C (1 +r) —ll
r(1+ r)n
As an example,assuming capital costs.(Co)of $2 million,annual recurring costs(C)of$40,000,and a discount rate(r)
of 5.625%,the 20-year(n=20)present value of costs would equal:
PV= capital costs+ recurring costs X [(1+0.05625)2U—1] / [0.05625(1+0.05625)29
PV= $2,000,000 + $40,000 X [1.98/0.168]
PV= $2,000,000 + $471,428
PV= $2,471,428
PVCA Sumrnary Table.
"l'he EAA must include a Summary Cost Table,which summarizes present worth costs developed for all technologically
feasible wastewater alternatives. The summary should include a breakdown of capital costs and recurring costs. In
some situations,the Division may require the applicant to refine cost estimates for some alternatives,or possibly collect
actual soil data to better characterize the land application alternative. Ultimately, the final determination on cost
effectiveness is made by the Division with consideration of monetary costs as.well as potential environmental impacts.
EAA Guidance Document Revision:October 2019
Page 7of8

Attachment A. Local Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6)allows input from local governments in the issuance
of NPDES Permits for non-municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non-municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and(if such an ordinance is in effect)whether the proposed facility is consistent with
the ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submittingan application for a NPDES Permit fora proposed facility,the applicant
PP � PPP P ty�
shall request that both the nearby city and county_government complete this form. The applicant must:
• Submit a copy of the permit application(with a written request for this form to be completed)to the clerk of the city and
the county by certified mail,return.receipt requested.
• If either(ot bOth)local government(s) fail(s) to mail the completed form,as evidenced by the postmark on the certified
mail catd(s),within 15 days after receiving and signing for the certified mail,the applicant may submit the application to
the NPDES Unit
• As evidence to the Commission that the local government®failed to respond within 15 days,the applicant shall submit a
copy of the certified marl card along with a notarized letter stating that the local governments) failed to respond within
the 15-day period.
Instructions to the Local Government The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government
(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes[ ] No[ ] If no,please sign this form,have it notarized,and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes[ ] No[ ]
If there is a zoning or subdivision ordinance in effect,is the plan for the proposed facility consistent with the ordinance? Yes[ ]
No [ ]
Date Signature
(City Manager/County Manager)
State of ,County of
On this day of , ,personally appeared before me,the said
name to me known and known to me to be the person described in
and who executed the foregoing document and.he(or she)acknowledged thathe(or she)executed the same and being duly sworn
by me,made oath that the statements in the foregoing document are true.
My Commission expires . (Signature of Notary Public)
Notary Public(Official Seal)
EAA Guidance Document Revision:October 2019
Page 8of8

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6/3/2019 2018 NC Category 5 Assessments"303(c1)List"Approved by EPA May 22,2015 Page 62 of 252

Chapter 2
Pigeon River = �
;
Part of Hydrologic Unit Code 06010106
Subbasin Overview
WATERSHED AT A GLANCE
This approximately 535 square mile subbasin is the equivalent to the COUNTIES
old DWQ subbasin number 04-03-05. The Pigeon River flows from Haywood
southern Haywood County to the northwest where it empties into
the French Broad River near Newport,Tennessee. The Pigeon River MUNICIPALITIES
watershed includes portions of the Great Smoky Mountains National Canton, Clyde,Maggie Valley,
Park,Pisgah National Forest,Pisgah Game Lands,and the Shining Waynesville
Rock Wilderness Area. Major tributaries to the Pigeon River in-
clude: Cattalochee Creek,East Fork Pigeon River,Jonathans Creek, POPULATION
Richland Creek, and West Fork Pigeon River. 1990:
44,414 or 83 per mil 2000:
The West Fork Pigeon River and upper Pigeon River make up one of 51,212 or 96 per mi2
the few remaining areas that still support populations of the federally
endangered Appalachian Elktoe. This mussel species,once found 2001 LAND COVER
throughout the mountains of western North Carolina requires clean, Developed: 7.7
well-oxygenated water that flows at a moderate to fast pace. They
also require stable,relatively silt-free,gravelly or rocky stream bot- Forest: 80.8
toms(USFWS,2008). % Agriculture:
10.0 %
Population and Land Cover Other:
Most of the population in the subbasin is concentrated around 1.5 %
Waynesville and Canton. The subbasin has been experiencing only
moderate growth with an increase of about 7.4 percent between EPA LEVEL IV ECOREGIONS
2000 and 2009. However,Maggie Valley is an exception because its Southern Crystaline Ridges and
population has increased by over 100 percent since 2000. Mountains
Southern Metasedimentary Moun-
Permits tains
NPDES Wastewater Discharge High Mountains
There are 15 NPDES individual wastewater discharge permits in this Broad Basins
subbasin with a total permitted flow of 37.13 MGD.Three of those
dischargers are permitted to discharge one million gallons a day or
more of treated wastewater. They are the Canton Mill(29.9 MGD),Waynesville WWTP(6 MGD), and Mag-
gie Valley WWTP(1 MGD). Figure 2-1 shows the location of all individual NPDES wastewater permits in this
subbasin. For a complete list of all individual NPDES wastewater permits in the basin,see Appendix V.
1

FIGURE 2-1: PIGEON RIVER SUBBASIN(06010106)
Pigeon River 06010406
Ess00000
F
,, 0, Rl I �Qt. � _. MADISON :.,,..-c, 11Pir
Goa or
outs
ieV- r.
.. 7- /) ./‘ , es
,._ V., = 4 �'�` ove Creek
tc4 ❑ L, :231
'c--\-- ,,
o r �' ` BUNCOMBE
.„ irirki cv ,k-,-
Ci
SWAIN ♦ r•.tree CI. e 6
,,,
CP �z4owpffzt S ��
a !
;1 L-
4 MA •
1 r a1 c ``
„ _���__� ` }00 1'1 ♦a` _ Canton r
,-- '' a Clyde ' �._,
_c ��, ' . 'gieY•Iley /'`�m26O<".:ff.2 ,,J: =K .
.( Kt, s 1 0 l `
�. rx4a o ,n
PlouCre \ o o Q.. .3 r
,� `-35�f W svullett o
I Aas
CDSubbasinBouudai}° kU `,, , tFork,0
County Boundaries 1 C �' :e� / .,
Municipalities ''Q c _
NPDES R'W Dischargers '' _ I� .� ' ��_r .
•
Major mzr3` y Cott C ek ' G
A Minor • f/ - 'c e
Monitoring Sites ` �d U
.o
6 Ambient o
t+? Fish Community
JACKSON 1...-- °o 're
t', Benthos r.P
Use Support Rating )t
P-N.-, Supporting
TRANSYLVANIA
'�Impaired
'-\ i Not Rated N
0 2 4 8 12 16
^ ._> No Data ��� Miles
2

While compliance at WWTP has improved,many collection systems continue to report frequent sanitary sewer
overflows(SSO). A state statute requires that wastewater collection system owners report all SSO incidents.
The main causes of SSOs are broken or clogged sewer lines,equipment failures, and inadequate treatment ca-
pacity. The following are ways to prevent SSOs from occurring:
• Sewer system cleaning and maintenance;
• Reducing infiltration and inflow through system rehabilitation and repairing broken or leaking service lines;
• Enlarging or upgrading sewer,pump station,or sewage treatment plant capacity and/or reliability; and
• Construction wet weather storage and treatment facilities to treat excess flows.
There are 11 permitted trout farms in the basin. This number excludes farms not meeting permit coverage
requirements related to annual fish production and feed usage. (See NPDES General PermitNCG530000 for
more information.) Macroinvertebrate and chemical sampling data collected in streams utilized by certain
farms indicate negative impacts to water quality. Additional data need to be collected and analyzed. In an ef-
fort to support the industry in the region and improve and protect water quality,a collaborative approach has
been undertaken,enlists trout farmers,NC Department of Agriculture and Consumer Services,NC Cooperative
Extension and DWQ. The outcomes should be a better understanding of farm operations,best management
practices,water resource protection,and regulatory needs. The NCG530000 permit will be renewed in July
2012. Any necessary permit modifications to fully protect surface waters utilized by trout farm operations will
be considered and discussed by the DWQ and stakeholders during the renewal period.
During this process,DWQ should encourage trout farms to contact their local extension service and/or research
institutions to use management measures such as those recommended/developed by DWQ in Collaborative As-
sessment for Watershed and Streams(CAWS)Project(funded by an EPA 104(b)(3)grant):
• Use hand feeding as much as possible to reduce the amount of food that enters the raceways and stream;
• Use high quality feed,which results in less manure production;
• Clean raceways regularly and land apply the manure as fertilizer;and
• Consider reducing the amount of fish being raised if the assimilative capacity has been exceeded.
Stormwater
The Stormwater Permitting Unit of the Wetlands and Stormwater Branch is responsible for the develop-
ment,planning,and implementation of statewide stormwater control policies, strategies,and rules designed to
protect the surface waters of North Carolina from impacts of stormwater pollutants and run-off volumes. The
Unit handles permitting for industrial,municipal,and post-construction(for development projects)stormwater
programs,as well as provides technical assistance to the regulated community,engineers,industry,citizens,and
local governments. For a list of stormwater permits in the basin refer to Appendix V.
Animal Operations
DWQ and the Division of Soil and Water Conservation work in all areas of the state to ensure that animal opera-
tions are not having a negative impact on water quality. The local soil and water conservation districts,NRCS,
RC&Ds,and other funding agencies should continue to work with farmers to install livestock exclusion from
streambanks and to install alternate water supplies for livestock watering:
Ambient Water Quality
Samples were collected at five AMS sites. Three sampling locations in the subbasin exceeded the screening
criteria for fecal coliform bacteria. Richland Creek was the only waterbody that exceeded the screening criteria
and is currently Impaired for recreation due to bacteria levels.
3 •
L

Biological Health
Twenty-one benthic macroinvertebrate samples were taken in the Pigeon River subbasin from January 2004
through December 2008 at 20 different locations. Figure 2-2 shows the current site rating for all benthic macro-
invertebrate sampling sites in which at least one sample was taken during the assessment period and figure 2-3
illustrates how those site ratings changed. Fish communities were sampled 5 times at 5 different locations in the
Pigeon River subbasin from January 2004 through December 2008.
One fish kill was reported in the Pigeon River watershed between January 2004 and December 2008.
FIGURE 2-2: CURRENT BENTHOS SITE RAT- FIGURE 2-3: CHANGE IN BENTHOS RATINGS
E4 Excellent
Good LI Improved
Good-Fair ■Declined
d ' . Fair III No Change
■Poor El Initial Rating
10% 6
O Not Rated
Lake Sampling
Lake Junaluska [AU#5-16-(11.5)d] was the only lake in the Pigeon River subbasin to be sampled by DWQ.
The lake was monitored between April and September 2007. The lake was again found to have pH levels great-
er than the state standard of 9.0 s.u. and has been on the 303(d) list of Impaired waters since 2006. The high pH
may be the result of eutrophication of the lake,which can produce algal blooms. When these algal blooms die
off at night,it decreases the oxygen in the water and can lead to fish kills.
Local Water Quality
The North Carolina portion of the Pigeon River subbasin contains three 10-digit hydrologic units. Table 2-1
lists these watersheds with a summary of their sizes and the number of locations that were sampled between
January 2004 and December 2008.
TABLE 2-1: 10-DIGIT HYDROLOGIC UNrr OR WATERSHEDS IN THE PIGEON RIVER SUBBASIN
10-DIGIT HUC NAME SQUARE BENTHIC FISH COM. AMBIENT
MILES SITES SITES SITES
0601010601 Headwaters Pigeon River 168.0 7 0 2
0601010602 Richland Creek-Pigeon River 181.7 8 4 2
0601010603 Cataloochee Creek-Pigeon River 186.1 3 1 2
0601010604 Pigeon River* *0.0 0 0 1
*Hydrologic Unit is entirely in Tennessee.
4

Headwaters Pigeon River Watershed(0601010601)
Over half of this watershed is within the Pisgah National Forest and another approxi-
c.
�v21 mutely six percent is managed by the Wildlife Resource Commission as part of the
Cold Mountain Game Land. This watershed contains the Town of Clyde and most of
f:1 r Canton. There are three minor and one major NPDES individual wastewater discharge
permits in this watershed,with permitted flows totaling 29.95 MGD.
{ Blue Ridge Paper Product,Inc.,operates a kraft pulp and paper mill in Canton that has
),..,—` been in operation since 1908. This facility has a permitted discharge of 29.9 MGD.
Historically,this discharger was a major polluter,but over time has greatly improved
performance. The current permit,issued on May 26,2010, contains variances for both color and temperature.
The limits for both temperature and color were tightened. The permit also requires future reduction to the color
limit,as well as increased monitoring for turbidity,hardness,and dioxins. Although this permit is being chal-
lenged in court by Cocke County,Tennessee and several environmental groups,it should be noted that the mill's
improvements have led to the successful reintroduction of various native fish species to Pigeon River below the
mill.
Beaverdam Creek-Pigeon River Subwatershed(060101060105)
Pigeon River[AU#5-(7)b]is Impaired for biological integrity due to a Fair bioclassification rating at benthic
macroinvertebrate sampling site EB257. This site has been sampled 13 times since 1984 and all have been
either Poor or Fair,except for one sampling in 1997 that rated Good-Fair.
In September 2007,a.fish kill of approximately 8,000 fish occurred on the Pigeon River below Canton. The
fish kill event was attributed to low flow,low DO,and high water temperatures brought on by ongoing drought
:conditions. Investigators observed numerous live fish during the investigation.
Richland Creek-Pigeon River Watershed(0601010602)
This watershed contains the Towns of Waynesville and Maggie Valley. There are six
� � minor and two major NPDES individual wastewater discharge permits in this water-
L. ter,, shed,with permitted flow totaling 7.08 MGD.
1 Staff from the DWQ Asheville Regional Office(ARO)and the ESS have partnered
with the Wildlife Resource Commission,the University of Tennessee-Knoxville,and
others to reintroduce several species of native fish to the upper reaches of Richland
Creek. Thousands of rock bass,warpaint shiners,river chubs,tuckasegee and greenfin
darters and mottled sculpins were released in April and September 2010 to waters up-
stream of the Lake Junaluska dam. This effort is being conducted to improve the fish population diversity and
remove the stream from its Impaired status for fish community.
Upper Richland Creek Subwatershed(060101060201)
The Harrison Construction rock quarry,south of Waynesville,was issued a notice of violation in July 2010 for
improperly controlling sediment in stormwater runoff coming from the site and entering Allen Creek[AU#
5-16-7-(8.5)]. The inspection that took place by DWQ was initiated by complaints from local citizens.
The DWQ Aquifer Protection Section staff in the ARO have partnered with the United States Geological Survey
(USGS),N.C.Division of Environmental Health's Waste Discharge Elimination Program,and Haywood Wa-
terways Association to conduct a septic-well survey to determine the potential impacts of on-site septic leachate
on private drinking well water.The study is being conducted in the Hyatt Creek and Richland Creek watersheds
in Haywood County as part of ongoing watershed restoration efforts in this area. For more information visit the
Richland Creek Watershed Use Restoration website.
5

The Southwestern North Carolina Resource Conservation and Development Council has been awarded three
319 Nonpoint Source Pollution Control Grants since 2005. The first project focused on the creation of a wa-
tershed plan for Hyatt Creek,repairing failing septic systems, and installation of agricultural best management
practices. The second grant expanded this project to include Richland Creek watershed,from its headwaters to
the confluence of Richland Creek and Raccoon Creek. This project is expected to be completed in December
2012. The third grant was awarded for a site specific project to purchase and demolish a hog and a dairy farm,
purchase an easement,and restore 2,830 of Oxner Creek,which is a tributary of Hyatt Creek. This project is
expected to be completed in March 2011.
Hyatt Creek[AU#5-16-6a and 5-16-6b]is no longer impaired for biological integrity due to a Good-Fair rating
at benthic macroinvertebrate sampling site EB236. An Unnamed Tributary to Hyatt Creek[AU#5-16-6uti]
was sampled for benthic macroinvertebrates in August of 2009 using small stream sampling and received a rat-
ing of Good.
Richland Creek[AU#5-16-(1)a] is Impaired for recreation due to levels of fecal coliform bacteria samples that
exceeded water quality standards.
Lower Richland Creek Subwatershed(060101060202)
Raccoon Creek[AU#5-16-14] is Impaired for biological integrity due to a Poor rating at fish community
sampling site EF42. Land use in the Raccoon Creek watershed is a mix of urban and agricultural. Site EF42
is downstream of the Town of Waynesville and the North Carolina Department of Agriculture and Consumer
Services Mountain Research Station. Ratcliffe Cove Branch a tributary of Raccoon Creek that enters just above
EF42 and has insufficient to nonexistent buffers.
•
Richland Creek[AU#5-16-(11.5)a and 5-16-(11.5)b]is Impaired for recreation due to levels of fecal coliform
bacteria samples that exceeded water quality standards. As part of the ARO Watershed Initiative,staff are
conducting an ongoing project to identify and remove fecal sources in the Richland Creek watershed upstream
of Lake Junaluska through thorough sampling and characterization of the watershed,stream walking to visu-
ally identify sources,and remediation/repair of these sources. Sources have been found to be primarily leaking
sewer infrastructure in the.Town of Waynesville,failing septic systems,and livestock with access to the creek.
Agriculture and failing septic system issues have been addressed through cooperation with the Haywood Water-
ways Association,the Haywood Soil and Water Conservation District,and DENR's WaDE Program. Through
this project,measurable improvement has been documented in Shelton Branch[AU#5-16-13], a tributary to
Richland Creek. Shelton Branch is entirely in the jurisdiction of the Town of Waynesville and served by the
Town's sanitary sewer collection system. Leaks in the collection system were identified and repaired resulting
in the measured reduction in fecal coliform levels.
Lake Junaluska is a small reservoir located in the mountains of southwestern North Carolina.The lake is pri-
vately owned by the Methodist Church and was built by the Lake Junaluska Assembly as a meeting ground for
southern Methodists.DWQ monitored this reservoir from April-September 2007.
Due to drought conditions during the spring and summer of 2007,nonpoint source runoff into Lake Junaluska.
was reduced. Subsequently,turbidity values were lower than those previously observed by DWQ and Secchi
depths were slightly greater. Nonpoint source runoff was reduced during drought,but agricultural,residential
and commercial development upstream of Lake Junaluska resulted in increasing sediment entering the lake
from Richland Creek and Factory Branch. In addition,stormwater monitoring has indicated that the Raccoon
Creek and Ratclliffe Cove watersheds are sediment sources into Lake Junaluska(HWA,2002).
In the past,the solution to this problem has been to lower the level of the lake and dredge out the accumulated
sediment. In 2004,as a condition of the NCDENR permit to dredge Lake Junaluska,a three-quarter acre wet-
6

land was created on the lake's northwest shore to improve the lake's water quality, enhance fish and wildlife
habitat and increase citizen awareness of water quality protection by providing an educational element to the
lake.A 12 foot wide littoral shelf was also constructed and planted with native plants and grasses by the DWQ
Intensive Survey Unit.This structure also serves to improve fish and wildlife habitat while controlling runoff
into the lake(Don Hendershot,May 7,2003).
Haywood Waterways Association(HWA)is currently developing potential alternative solutions to dredging
Lake Junaluska. They are developing a long term project focused on making substantial and permanent reduc-
tions in sediment discharged from the Raccoon Creek and Ratcliffe Cove watersheds. In addition,HWA is
proposing a certification process for developers that incorporate recommendations of suitability analysis in their
design,change some existing practices,and follow best management practices development will be certified as
conservation based development.
Lake productivity increased during this monitoring period,as suggested by pH values and percent DO concen-
trations. Lake-wide mean pH values exceeded state water quality standard of 9.0 s.u.on June 12 and July 17,
2007. Chlorophyll a values,an indicator of increased algae growth in the lake,were elevated on July 17 and
August 14,2007. Analysis of algae samples collected from Lake Junaluska indicated the presence of an algal
bloom(based on cell densities)in July. This bloom was dominated by the diatom Achnanthidium sp. This
algae is usually found attached to aquatic plant stems and leaves and is found in the water column only when
it has been sheared away from the surfaces of these plants. Other algae found in water samples included green
algae,cryptomonads,and chrysophytes,all of which are considered to be beneficial as the base of the aquatic
food web.
Upper and Lower Jonathans Creek Subwatersheds(060101060203 and 060101060204)
Jonathans Creek[AU#5-26-(7)]is currently Not Rated because ambient sampling system site E6300000
exceeded the fecal coliform screening criteria of 43 colonies/L in 23.5 percent of the samples taken and had
a geometric mean of 218 colonies/L. To rate this stream for fecal coliform bacteria,five samples in a 30-day
period are required. Dairy farms near the sampling site may be contributors to the bacteria levels in the creek.
Jonathans Creek is no longer impaired for Turbidity,but is still considered as borderline with 9.8 percent of the
samples exceeding the standard.
Crabtree Creek-Pigeon River Subwatershed(060101060205)
Pigeon River(Waterville Lake) [AU#5-(7)c]is currently Impaired for biological integrity due to a Fair ben-
thic macroinvertebrate sample rating at site EB255 in 2006. This same site also rated Fair in 1994. This site is
immediately downstream of the Town of Waynesville WWTP discharge and is approximately 8.5 miles down-
stream
of the Canton's Mill discharge.
-�- Cataloochee Creek-Pigeon River Watershed(0601010603)
Almost 52 percent of this watershed is part of the Great Smoky National Park and is
under the management of the National Park Service(NPS). Approximately another 23
percent is part of the Pisgah National Forest and is under the management of the United
States Forest Service(USFS). The only NPDES individual wastewater discharge
\l I' permit in this watershed belongs to the State and is for the Haywood County Rest Area.
\,___/"This permit has a maximum permitted flow of 0.026 MGD. All waterbodies in the
watershed that have been assessed are Supporting for all designated uses.
Walters Lake-Pigeon River Subwatershed(060101060303)
A total of four fish community sites in the Fines Creek watershed were sampled for the presence of trout for
purposes of determining whether or not it qualifies for reclassification to Trout(Tr)waters. All sites were found
to be supporting a wild or naturalized and stocked trout population on a year-round basis (BAU Memorandum
7 i.

F-20060906).
A contractor working for the EEP completed stream restoration on approximately 3,900 linear feet of Morgan
Creek and three of its tributaries,as well as 9.8 acres of riparian buffers and 1.1 acres of wetlands in the Morgan
Creek watershed in 2009. The project is now in the monitoring phase which will determine if the project was
successful.
Recommendations
Pathogens remain a water quality concern throughout the Richland Creek-Pigeon River watershed. Continuation
of work by the HWA and.the North Carolina Wastewater Discharge Elimination program to find and repair
straight pipes and failing septic systems is needed. In addition, Richland Creek would benefit from an inflow/
infiltration study of the Waynesville wastewater collection system and the subsequent repair of any damaged lines
and equipment found during such a study.
Buffers are needed along Raccoon Creek and Ratcliffe Cove Branch.The Department ofAgriculture and Consumer
Services Mountain Research Station along Raccoon Creek and a few small tributaries are in need of buffers to
protect water quality and could serve as a demonstration area for agricultural best management practices in the
mountain region.
8

FIGURE 2-4: HEADWATER PIGEON RIVER WATERSHED WITH 2010 USE SUPPORT
�Headwaters',;Pigeon River
.--))
0601010.601 BUNCOMBE
_ --''`'-) ;' O Watershed Boundary
� /
A. ` _.' County Boundaries
db ' :'..c
° {\ Municipalities
r" Conservation Land f'7 z.
A ( Primary Roads
tee. . �,
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�_� Monitoring Sites
/ //� sg0000 �v� _
( _*NI. __ ® Ambient -
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v ^o, ( `—`._i Supporting
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an �, y
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ong TRANSYLVANIA
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9

FIGURE 2-5: RICHLAND CREEK WATERSHED WITH 2010 USE SUPPORT
Rich land Creek - ,W4DIsI
Pigeon River f�
06010 0602 11 'BUNCOMBE
CD
40
tes el Bta��e� HAYWOOD ����,/— )/I/
Elk
41 Pigeo? e _'_�
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Coye ekc r f � <Ccc� .
- > f E6300000 C Lip
>ti _ f <<'rabt e'e
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SWAIN Hemphil me vs o�YB j`9 Lon �nch�
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41..
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19 C7 Waynesville.��,�;,ir F4 o ow
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Plott Creek. � aGt� . �EF5 A �
4 CD- 0 �.
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�e Fe?A o�)235244�reeii « !p �>)z7s Q Watershed Boundary
�r s.1 _ County Boundaries
EF65;►. '`EF46 0/� :�-` Ji
Municipalities
JACKSON A EB361 ti _0,o
8r Conservation Land
•� J_ EF33'
df Primary Roads
1 kyi6c -- EF49 °has,:
EF38 , ® CAFO-Cattle
al ----'aGc : Deep Gd Wastewater Discharge
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Impaired
EB236 i
l '`\,,. Not Rated
EF27 EF4 \_ 0 1 2 4: 6
5 '-�. No Data
, t
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10

Cataloochee Creek - Pigeon '
River
0601010603 w
aCC..-
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TENNESSEE o \, \I f.
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WatershedBoundan' "a kie ri , " TuIN-,c.ic',, i
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Municipalities oL x r U; _Ai..., `Jf j, des CCc Cove Creek J o
kCi• o E6450Qb11ry',EB320 �o m
6.
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Use Support Rating :r f""' ee
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'�� Not Rated ,kI �,
'N No Data 0 2 4 6 \ 8 N
A
% Miles

Endangered Species, Threatened Species, and
Candidate Species,
Haywood County, North Carolina
liar
Updated: 07-17-2020
Critical Habitat Designations:
Spruce-fir moss spider -Microhexura montivaga -
Federal Register Reference: July6, 2001, Federal Register, 66:35547-35566.
Appalachian elktoe -Alasmidonta raveneliana - The main stem of the West Fork
Pigeon River (French Broad River system), from the confluence of the Little East
Fork Pigeon River, downstream to the confluence of the East Fork Pigeon River, and
the main stem of the Pigeon River, from the confluence of the West Fork Pigeon
River and the East Fork Pigeon River, downstream to the N.C.Highway 215 Bridge
crossing, south of Canton, North Carolina. Within these areas, the primary
constituent elements include: (i) Permanent, flowing, cool, clean water;
(ii)Geomorphically stable stream channels and banks; (iii)Pool, riffle, and run
sequences within the channel; (iv)Stable sand, gravel, cobble, boulder, and bedrock
substrates with no more than low amounts of fine sediment; (v)Moderate to high
stream gradient; (vi)Periodic natural flooding; and (vii)Fish hosts, with adequate
living, foraging, and spawning areas for them.

Federal Register Reference: September 27, 2002, Federal Register, 67:61016-
61040.
Common Name Scientific name Federal Record Status
Status
Vertebrate:
Bald eagle Haliaeetus leucocephalus BGPA Current
Carolina northern flying Glaucomys sabrinus E Current
squirrel coloratus
Eastern small-footed bat Myotis leibii ARS Current
Gray bat Myotis grisescens E Current
Hellbender Cryptobranchus ARS Current
alleganiensis
Indiana bat Myotis sodalis E Current
Northern septentrionalis-eared bat Myotis tentrionalis T Current
g Y
Invertebrate:
Appalachian elktoe Alasmidonta raveneliana .E Current
Rusty-patched bumble bee Bombus affinis E Historical
Spruce-fir moss spider Microhexura montivaga E Probable/potential
Vascular Plant:
Small whorled pogonia Isotria medeoloides T Current
Spreading avens Geum radiatum E Current
Nonvascular Plant:
a liverwort Plagiochila sharpii ARS Historical
Lichen:
Rock gnome lichen Gymnoderma lineare E Current
Definitions of Federal Status Codes:
E = endangered. A taxon "in danger of extinction throughout all or a significant
portion of its range."
T = threatened. A taxon "likely to become endangered within the foreseeable future
throughout all or a significant portion of its range."
C = candidate. A taxon under consideration for official listing for which there is
sufficient information to support listing. (Formerly "Cl" candidate species.)
BGPA =Bald and Golden Eagle Protection Act. See below.
ARS = At Risk Species. Species that are Petitioned, Candidates or Proposed for
Listing under the Endangered Species Act. Consultation under Section 7(a)(2) of the

ESA is not required for Candidate or Proposed species; although a Conference, as
described under Section 7(a)(4) of the ESA is recommended for actions affecting
species proposed for listing.
T(S/A) = threatened due to similarity of appearance. A taxon that is threatened due to
similarity of appearance with another listed species and is listed for its protection.
Taxa listed as T(S/A) are not biologically endangered or threatened and are not
subject to Section 7 consultation. See below.
EXP = experimental population. A taxon listed as experimental (either essential or
nonessential). Experimental, nonessential populations of endangered species (e.g.,
red wolf) are treated as threatened species on public land, for consultation purposes,
and as species proposed for listing on private land.
P =proposed. Taxa proposed for official listing as endangered or threatened will be
noted as "PE" or "PT", respectively.
Bald and Golden Eagle Protection Act (BGPA
In the July 9, 2007 Federal Register( 72:37346-37372), the bald eagle was declared
recovered, and removed (de-listed) from the Federal List of Threatened and
Endangered wildlife. This delisting took effect August 8,2007. After delisting, the
Bald and Golden Eagle Protection Act (Eagle Act) (16 U.S.C. 668-668d) becomes
the primary law protecting bald eagles. The Eagle Act prohibits take of bald and
golden eagles and provides a statutory definition of"take" that includes "disturb".
The USFWS has developed National Bald Eagle Management Guidelines to provide
guidance to land managers, landowners, and others as to how to avoid disturbing bald
eagles. For mor information, visit http://www.fws.gov/migratorybirds/baldeagle.htm
Threatened due to similarity of appearance(T(S/A))_
In the November 4, 1997 Federal Register(55822-55825), the northern population of
the bog turtle (from New York south to Maryland) was listed as T (threatened), and
the southern population (from Virginia south to Georgia) was listed as T(S/A)
(threatened due to similarity of appearance). The T(S/A) designation bans the
collection and interstate and international commercial trade of bog turtles from the
southern population. The T(S/A) designation has no effect on land management
activities by private landowners in North Carolina, part of the southern population of
the species. In addition to its official status as T(S/A), the U.S. Fish and Wildlife
Service considers the southern population of the bog turtle as a Federal species of
concern due to habitat loss.
Defmitions of Record Status: 1.
Current - Based on NC Natural Heritage Program information, this. taxon is

considered to be extant in the county.
Historical - Based on NC Natural Heritage Program information, this taxon is
considered to be historical in the county, meaning that all recorded occurrences are
either extirpated, have not been found in recent surveys, or have not been surveyed
recently enough to be confident they are still present.
Obscure - the date and/or location of observation is uncertain.
Incidental/migrant - the species was observed outside of its normal range or habitat.
Probable/potential - the species is considered likely to occur in this county based on
the proximity of known records (in adjacent counties), the presence of potentially
suitable habitat, or both.
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