NC0021407_Correspondence_19980901

NPDES DOCUHENT !;CANNING COVER !SHEET
NPDES Permit:
NC0021407
Highlands WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 1, 1998
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Mr. John H. Hankinson, Jr.
Regional Administrator
EPA Region IV
Atlanta Federal Center
61 Forsyth Street .
Atlanta, Georgia 30303
Subject: Highlands Wastewater Treatment Facility
EPA Response to US
Representative Charles Taylor
Dated September 1, 1998
Macon County
Dear Mr. Hankinson:
I have taken an opportunity to review a copy of the subject response to
Representative Taylor's inquiry concerning the status of Highland's NPDES
Permit renewal. I rea1i7e that this response was discussed in draft stage with
Division staff. I certainly appreciate EPA's efforts to coordinate this
correspondence, but I must take this opportunity to respond to certain aspects of
your September 1, 1998 letter.
Despite several efforts over the last few years to brief you and your staff
on all the water quality aspects of this NPDES permitting issue, EPA persists in
making statements about "perceived" impacts to water quality that cannot be
supported by scientific data. The Division has invested a significant amount of
resources to carefully monitor water quality in the Cullasaja River below the
Highlands discharge. That monitoring effort includes the Division's best
available methodology for assessing the ecological health of surface waters:
aquatic biological monitoring. In addition to chemical monitoring, the Division
has used benthic macroinvertebrate and fish population sampling to determine if
the presence of this discharge has resulted in any kind of ecological changes in the
River. As you know, Highlands constructed a new wastewater treatment facility
that went on line in December, 1994. Prior to the new plant's construction and
moving the discharge point below Lake Sequoyah Dam, the Division performed
"baseline" monitoring on. the River to establish "before" conditions, so future
sampling could determine any "shifts" in quality due to the discharge location.
After several months operation of the new plant, the Division followed earlier
sampling efforts with some "after" monitoring in 1996.
P.O. BOX 29535, RALEIGH, NORTH CAROLINA 27626-0535
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public concerns.:
John H. Hankinson,Jr.
Page Two
The results of that effort were compared to the earlier conclusions and.the overall.
assessment was that the movement of the discharge had no measurable impact on. the River_ As
the report stated,. "These data indicated that the relocation of the Town of Highlands WWTP's
discharge to the Cullasaja River below Lake Sequoyah has had no impact on the river's
macroinvertebrate community." Chemical sampling in the River before and after the discharge
location changed also has shown no changes in basic aquatic chemistry in the Cullasaja.. These
results have been provided to EPA and have been discussed on a number of occasions: You and
your -staff have acknowledged receiving these data..
In yourrecent letter -to Congressman Taylor, you state:: "However,.the perinit:does, not.:-
address nutrients, dissolved solids, and other pollutants which may have adverse impacts on the
River's ecological health. Finding an alternative disposal method could provide significant -
environmental benefits." While you do refer to the excellent compliance record of -the facility,.
you do not summarize the available ecological data on the River. Since this Agency's best
efforts to useill water quality assessment tools- available to itcannot detect any changes in River
quality dueto the new treatment facility,. I fail to see the valueof the referenced statement
While it is true that the permit doesn't limit the effluent characteristics you refer to,. thereis no
information available that would indicate a need. to deal with: these parameters. As you know, for
this type wastewater; neither EPA nor the States typically do not limit these parameters unless
there is an established water quality problem requiring limitations for these potential pollutants..
In addition to the biological data referenced for the Cullasaj a,. the chemical data available related
to your statement on the River show no_ water quality problems for nutrients or for dissolved
solids.. The before -and after (discharge location movement) sampling fornutrientsand
conductivity show no change in basic water chemistry. Therefore, the "significant environmental
benefits" associated with removing the discharge thatyou refer to cannot be' supported by our
database.
The North Carolina Division of W_ ater Quality understands very well the citizen concerns
voiced over Highlands' discharge to the Cullasaja River. We can appreciate the desire to have
the discharge out of the River, even on only a part-time land_ application basis. We certainly
support better dialog between the concerned parties, but dialog is two-way communication: They
perceived impacts of this -discharge oa the_ river have been devaluated and cannot be'supported by
the data. Realizing that it would be the desire of any recreational user of the River to have the -
discharge removed, we still cannot disregard the reality of the water quality data, thegoverning
federal and state regulations, ,legally valid regulatory decisions; and the- financial limitations of
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the -Town in~meeting their wastewater managementneedsWer agreedtorinclude (andthee_Town
was willing to accept) extensive and detailed alternative analysis language m the renewal permit
a ./tir `
should the Town -desire to request expansion. of .their wastewat•er system in' the future:. This -
condition, ifapplied to certain requested expansions (<.0.50 nagd increase. m design flow), is
more restrictive than our standard procedures and represents a .good_ faith: effort to respond to
•

John H. Hankinson, Jr.
Page Three
I believe that EPA's desire is to be a positive factor in this difficult and long running
debate. However, the implication of certain statements made in your September 1, 1998
correspondence to Rep. Taylor and referenced in this letter, reinforce the perception that there are
unknown and potentially dangerous impacts to the Cullasaja River which have not been
addressed by North Carolina's permit. Such an implication suggests that the North Carolina
Division of Water Quality has not drafted a permit that is adequate to protect water quality in the
Cullasaja River. In addition to being scientifically unsupportable, I am concerned that such
statements contribute to the continued failure of attaining meaningful dialog in this matter. The
Division remains ready to work with EPA to continue to provide scientifically supportable and
legally valid regulatory actions related to Highlands and to work toward better community
communication and understanding. This can only be accomplished by everyone involved being
committed to legal, fiscal and scientific realities. I would be happy to discuss this with you
further, if you so desire. Please don't hesitate to call me at [phone].
Sincerely,
A. Preston Howard, Jr., P.E.
cc: Mr. Bill Holman
Congressman Charles Taylor
Mr. Allan L. Trott, Mayor of Highlands
Ms. Coleen Sullins
Mr. Forrest Westall
Mr. Bill Anderson
Ms. Peg Jones, Save Our Rivers, Inc.