NC0064416_Staff Comments_20220510

From:Weaver, Charles
To:"[e-mail]"
Cc:Boss, Daniel J; Gurney, Anna
Subject:NC0064416 concerns
Date:Tuesday, May 10, 2022 12:18:56 PM
Mr. Pendergrast:
You sent some concerns to Daniel Boss in the Asheville Regional Office (ARO) regarding the subject
permit. I’ll be working on the permit renewal later this year. I’ve been with the NPDES program
since 1996.

Responses to your comments are listed below.
a. The WWTP renewal permit application references Norton Mill Creek as where the WWTP
discharge goes but says nothing about it being a protected High Quality Water or it being an
important headwaters tributary to the Outstanding Resource Water of the Chattooga National
Wild and Scenic River. All such discharges need to be strictly limited to avoid any impairment
of their pristine water quality.
Norton Mill Creek is NOT classified as a High Quality Water. Its classification is C-Trout *,
with the * representing the management strategy for protection of downstream ORW
waters. The management strategy is codified at 15A NCAC 02B.0225, with the Chattooga
River discussed in paragraph (d) (2). That paragraph requires upstream discharges to comply
with paragraph (c) (1), which states: “Freshwater: Water quality conditions shall be maintained to
protect the outstanding resource values of waters classified ORW. Management strategies to protect
resource values shall be developed on a site-specific basis during the proceedings to classify waters as
ORW in accordance with Rule .0101 of the Subchapter. No new discharges or expansions of existing
discharges shall be permitted, and stormwater controls for all new development activities requiring an
Erosion and Sedimentation Control Plan in accordance with rules established by the NC Sedimentation
Control Commission shall comply with the stormwater provisions set forth in 15A NCAC 02H .1000,
including the specific stormwater management requirements for freshwater ORW areas set forth in 15A
NCAC 02H .1019 and .1021.”. The permittee is not requesting an expansion as part of the
permit renewal. The facility was first permitted in March 1986, >9 years before the ORW
rules took effect. The ORW strategy does not require any changes to the current permit.

b. The application reflects Primary treatment only, not any form of secondary treatment to
remove phosphorus or nitrogen, or other nutrients that could impair water quality.
Incorrect. The WWTP is a class WW-2 biological plant with dual-train activated sludge
treatment and tertiary filters. It exceeds the minimum requirements for secondary
treatment facilities.
c. The monitoring does not include sampling for phosphorus or nitrogen.
Incorrect. Total Nitrogen (TN) and Total Phosphorus (TP) are monitored semi-annually in the
current permit. That monitoring will remain in the permit renewal.

d. No permit limit exists for phosphorus or nitrogen.
TN and TP limits are not required as the Savannah River Basin has no Total Maximum Daily
Load (TMDL) approved by EPA. The receiving stream is also not classified as a Nutrient-
Sensitive Water (NSW). The permit does have limits for ammonia nitrogen.

e. The average monthly flow in July 2021 was approximately 31,000 gallons per day. Average
monthly flows typically increase in the summer months when more people are occupying
houses in the Cullasaja Club development.
The permit allows for a monthly average flow of 150,000 gallons per day. For Calendar year
2021, the WWTP averaged 17,800 gallons per day, or 11.9% of its permitted capacity. The
Division has no existing concerns about flow volume for this facility.

f. Neighbors in Whiteside Cove have noticed a substantial increase in aquatic vegetative growth
in Norton Mill Creek over the past years, with that vegetative growth appearing in the
summer months and then declining in non-summer months.
Vegetative growth is more likely during the warmer months and less so during the winter.

You also said:
“Taking these considerations into account, it appears that Norton Mill Creek is experiencing impaired
water quality with excess aquatic vegetative growth resulting from discharge of excessive/untreated
nutrients from the Cullasaja Club development’s WWTP. With this in mind, I suggest that in
considering the WWTP renewal application NCDEQ should place nutrient monitoring and discharge
limits in any permit renewal and require appropriate monitoring and treatment to meet those
limits.”

Please note:
The Division currently has no streams classified as Impaired waters in the Savannah River Basin.
The existing permit has limits for ammonia nitrogen and monitoring for TN and TP.
The facility has had one enforcement case for limit violations in the past 20 years.
The facility is using roughly 12% of its permitted capacity, accounting for ca. 17% of the Instream
Waste Capacity for Norton Mill Creek.

The Division doesn’t plan any changes to the permit at this time.
If new evidence of a nutrient problem is acquired, either through instream data collection by the
Division or others, changes will be made as necessary.

Thanks for your concern, and for taking the time to comment on this issue. I have copied the ARO
on this message, and they can add any comments about the facility they deem relevant. ARO
personnel perform the site inspections for NC0064416.

Charles H. Weaver
Environmental Specialist
N.C. DEQ / Division of Water Resources

919-707-3616
[e-mail]

(mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617

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