WQ0000731_Application_20220126

Anchor QEA of North Carolina, PLLC
231 Haywood Street
Asheville, North Carolina 28801
828.281.3350
Poorva Mokashi
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
, ANCHOR
QEA
January 26, 2022
Re: Lake Toxaway Country Club WWTP Permit No. WQ0000731; Condition 1.1 Alternative Design
Criteria Request
Dear Ms. Mokashi,
The North Carolina Department of Environmental Quality (NCDEQ) issued Permit WQ0000731 to the
Lake Toxaway Company for the Lake Toxaway Country Club (LTCC) WWTP (wastewater treatment
plant) Reclaimed Water Generation and Dedicated Utilization System' (dated August 6, 2021). Of the
12 conditions included, 11 are accepted without comment. Condition 1.1 requires a response. On
behalf of the Lake Toxaway Company, Anchor QEA of North Carolina, PLLC, is pleased to provide this
Alternative Design Criteria Request to comply with Condition 1.1.
Condition 1.1
The NCDEQ cover letter of Permit No. WQ0000731 issued August 6, 2021, included Condition 1.1 that
states:
This condition requires that the Permittee submit a permit modification prior to November 1,
2022. This modification shall address the fact that the existing 39,789-gallon five-day upset
pond is insufficiently sized for a 20,000 gallon per day (GPD) facility.
Furthermore, Section I —Schedules, states:
1. Prior to November 1, 2022, the Permittee shall submit a permit modification application to
address the requirements in 15A NCAC 02U .0402(d), which reads, "Effluent from the
treatment facility shall be discharged to a five-day side -stream detention unit if either the
turbidity exceeds 10 [Nephelometric Turbidity Units] NTUs or if the permitted pathogen
levels cannot be met. The facility shall have the ability to return the effluent in the five-
day side -stream detention unit back to the head of the treatment facility." Based upon the
facility's permitted flow of 20,000 [gallons per day] GPD, the five-day upset pond is
required to have a volume of 100,000 gallons; however, the existing five-day upset pond
has a volume of 39,789 gallons.
North Carolina Department of Quality, 2021. Letter to: Reginald D. Heinitsch, Jr., Lake Toxaway Co. Regarding: Permit
No. WQ0000731 Lake Toxaway Country Club, WWTP Reclaimed Water Generation and Dedicated Utilization System, Transylvania
County. August 6, 2021.
LTCC_Response to Permit WQ0000731 Conditionl.1_20220126.docx

January 26, 2022
Page 2
Alternative Design Criteria Request
Per the options listed in the Condition 1.1, Anchor QEA requests that NCDEQ accept this Alternative
Design Criteria request pursuant to 15A NCAC 02U .0105(n), which demonstrates that the existing
39,789-gallon five-day upset pond is adequately sized for the facility, and that the existing five-day
upset pond at the permitted flow rate of 20,000 GPD meets the three listed criteria per the following:
i. Provides equal or better treatment of the waste compared to current operations:
In 2016, improvements were made to the WWTP that included the addition of a
recording flow meter and a continuous monitoring and recording turbidity meter.
Improvements also included addition of pumps, valves, and piping that would
automatically reroute treated wastewater to be recirculated if it does not meet the
treatment standard for turbidity 10 NTUs. This feature prevents treated water that is
non -compliant for turbidity from being discharged to the irrigation pond by directing
it into the five-day upset pond to be recirculated through the treatment system. As
discussed below, this upset condition has not occurred since installation in 2016.
ii. Provides equal or better protection of the waters of the state compared to current
operations:
In 2019, the liners in both the five-day upset and irrigation ponds were replaced with
60-mil high -density polyethylene liner. The design and completed upgrades were
reviewed and approved by the North Carolina Division of Water Resources. These
infrastructure upgrades provide equal or better protection of the waters of the state
compared to conditions prior to 2019, and these protective conditions will be
unchanged by accepting the existing five-day upset pond volume and maintaining the
current permitted flow rate of 20,000 GPD.
Review of non -discharge monitoring report (NDMR) forms from January 2018 to
November 2021 identified the following:
o Per the permit, turbidity is the parameter that dictates the use of the five-day upset
pond with a 10 NTU permit limit and daily monitoring frequency. The maximum
monthly turbidity was 9.3 NTUs in February 2018, with only five occurrences when
the maximum monthly turbidity exceeded 5 NTUs (equivalent to 50% of the permit
limit; Figure 1). Per Figure 1 below, measurements of higher turbidity generally
occur when the average flow is less than 2,000 GPD. Although turbidity
exceedances have not occurred since the 2016 upgrades, if they did occur, they are
most likely to occur when average flow rates are well below 7,958 GPD, and hence,
the five-day upset pond is adequately sized.

January 26, 2022
Page 3
o A maximum monthly average flow of 9,459 GPD was recorded in July 2021, with 36
of the 44 months reviewed having flow rates under 7,958 GPD. With these flow
rates, there have been no upset conditions, and, per Figure 1, larger flow rates
typically result in lower turbidity readings.
Figure 1
Correlation of Turbidity Versus Flow Rates
10
1 9
8
472 6
5
4
2 3
E
E
!O
7
2
0
• •_
•
• •
0 2,000 4,000 6,000 8,000 10,000
Average Monthly Flow (GPD)
Notes:
Data shown is from NDMRs from January 2018 to November 2021.
iii. Provides no increased potential for nuisance conditions from noise, odor, or vermin:
Continuing to operate the WWTP under the current design (i.e., since 2016) will not
increase potential for nuisance conditions from noise, odor, or vermin compared to
current operations.
The WWTP permitted upgrades in 2016 and historical successful operation of the system
documented in NDMRs demonstrates that the existing 39,789-gallon five-day upset pond is
adequately sized for the facility and verifies that the existing five-day upset pond at the permitted
flow rate of 20,000 GPD meets the three listed criteria. We request that the Alternative Design
Criteria be granted to allow the continued operation of the five-day upset pond.
The Lake Toxaway Company and Anchor QEA appreciate your review of this matter. Please contact
me at 828-281-3350 or [e-mail] if you have any questions.
Sincerely,
Robert Cork, PE MEng
Managing Engineer
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cc: Scott McCall, Lake Toxaway
John Schoenbeck, Lake Toxaway
Digitally signed
by Robert Cork
p gz o Date: 2022.01.26
08:26:23-05'00'