NC0028975_staff comments_20211102

Weaver, Charles
From: Willmer, Mikal
Sent: Tuesday, November 2, 2021 7:18 AM
To: Weaver, Charles
Cc: Boss, Daniel J; Davidson, Landon
Subject: RE: Permit Question
Hey Charles,
Sorry I should have clarified in my previous email (but may not change much for compliance), the solids originating in
the clarifier are being reported as discharging out the outfall, no bypass of treatment or overflow of the treatment units.
Thanks again Charles. We'll discuss further to decide the best course of action, if any is needed currently.
Mikal Willmer (she/her)
Environmental Specialist II — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4686 office
828 989 7675 mobile
828-299-7043 fax
mikal.wilImertncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are
on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
From: Weaver, Charles <[e-mail]>
Sent: Monday, November 1, 2021 2:30 PM
To: Willmer, Mikal <[e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: RE: Permit Question
If you don't consider it a Bypass, the next reporting requirement is a Part II. E. 7 (Other Noncompliance).
1

You could also classify it as "Interference" of a "Pass Through" (Part IV. A.).
That's the best I can offer. If the overflow is not reaching surface waters, and not causing any violations, there's not
much of a hook for a compliance action, apart from inadequate O&M.
CHW
From: Willmer, Mikal <[e-mail]>
Sent: Monday, November 1, 2021 10:55 AM
To: Weaver, Charles <[e-mail]>
Cc: Boss, Daniel J <[e-mail]>
Subject: Permit Question
Good Morning Charles,
We had a question regarding how to classify this non-compliance reporting by a permittee. This is Saluda (NC0028975)
. During significant rain events, due to the I&I within the collection system, they will report a loss of solids at the WWTP
because the facility becomes hydraulically overloaded. Our question is, which permit condition is this in violation of
specifically since we do not have effluent data to show an exceedance of TSS and no documented stream impact? The
facility reports it as an upset and we do not really consider it an upset or a bypass.
Thanks,
Mikal Willmer (she/her)
Environmental Specialist II — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4686 office
828 989 7675 mobile
828-299-7043 fax
[e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are
on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
2