NC0024431_staff comments_20180712

Weaver, Charles
From: Davidson, Landon
Sent: Thursday, July 12, 2018 1:56 PM
To: Weaver, Charles
Subject: RE: Permit NCO024431 - composite sampling
Thank you for putting time into this response Charles.
G. Landon Davidson, P.G.
Regional Supervisor —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson(cDncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Weaver, Charles
Sent: Thursday, July 12, 2018 11:50 AM
To: Boss, Daniel J <[e-mail]>
Cc: Davidson, Landon <[e-mail]>
Subject: RE: Permit NCO024431 - composite sampling
Dan — I've reviewed our files, which go back to 1974. The first permit was issued in 1980.
BIMS shows that composite sampling has been required since 8/1/1985 for BOD, NH3 as N, and Total Suspended
Solids.
I've scanned all of the historical files we have from the period 1974-2000. They are available on the S: drive, specifically:
S:/SWP-Point Source->NPDES->Permit files->NC0024431
Regarding the historical files:
• Most documents discuss permit limits and monitoring frequencies. The sample types are not discussed.
• There are repeated concerns about phosphorus concentrations in Wolf Lake, though these concerns did not lead
to permit limits.
• Those ARO staff who commented on draft permit renewals didn't mention the composite sample requirement.
• The 1995 ARO staff report recommended that an alternatives analysis should be performed, given the available
land [at that time] that could potentially house a non -discharge system.
• The statement "Wastewater flow data may be obtained from water well meter readings." was added at the
ARO's request, again without any discussion of sample type.
I pulled all the violations in BIMS for NC0024431. The report is attached.
Four "Sample Type Violation" events were noted, three in November 2001 and one in April 2002. No other violations of
this type were noted in BIMS.

I reviewed the inspection notes in BIMS going back to 2000. All inspectors were very complimentary about the 0&M at
the facility and the quality of the effluent. None of the inspectors commented on sampling by / at the WWTP.
In conclusion:
➢ CONGRATULATIONS! You are without question the only person to actually read permit NC0024431 since
8/1/1985. No one else - at the facility or within NC DEM/DEHNR/DENR/DEQ— ever did. Thank you.
➢ The absence of sample -type violations puzzles me. If all the DMRs since April 2002 were marked "Compliant"
composite samples should have been collected. If no composites were collected, the DMRs should not be
marked "Compliant".
➢ If the facility can't collect composite samples (and you believe that they are inappropriate for this WWTP
anyway), the permittee should promptly submit a modification request to have the sample types changed to
Grab.
Proceed as you see fit.
CHW
From: Boss, Daniel J
Sent: Tuesday, July 10, 2018 5:22 PM
To: Weaver, Charles <[e-mail]>
Subject: Permit NC0024431
Hi Charles,
I did an inspection at the Kanuga Conference Center WWTP (NC0024431) in Hendersonville today. This is a WWI sand
filter facility. The permitted flow is 35,OOOgpd.
I was surprised to find that this facility is required to do composite sampling. They have always taken grab samples and
apparently no inspector has ever noticed the composite sampling requirement until today. It appears you may have
written this permit and so I was wondering if the composite flow has always been a requirement or if it was added at
some point. I could only find permits back to 2005 at our office and I believe the facility has been in operation since
1995.
I wanted to make sure that the continuous flow monitoring and composite sampling requirements were not errors,
because it may be tricky to do flow proportional sampling with this system since it is batch fed. The other reason that I
wondered if the composite sampling was an error is that the continuous flow requirement includes a footnote that says
"Wastewater flow data may be obtained from water well meter readings." I'm not sure why we would include that
footnote if we intended them to do flow -proportional composite sampling.
I will appreciate any insight you can give me in regards to this permit. Thanks,
Daniel Boss
Environmental Specialist- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Office Phone: [phone]
Email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778