NC0021407_Correspondence_20000313

NPDES DOCIMENT SCANNING 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:
March 13, 2000
This document is printed on reuse paper - ignore any
content on the reverse side

ern
NCDENR
.LAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
KERR T. STEVENS
DIRECTOR
NORTH CAROLINA DEPARTMENT OF /lor .
ENVIRONMENT AND NATURAL RESOURCES a
March 13, 2000
The Honorable Allen L. "Buck" Trott
Town of Highlands
PO Box 460
Highlands, NC 28741
DIVISION OF WATER QUALITY
Dear Mayor Trott:
This letter responds to concerns expressed by the Town of Highlands regarding the proposed designation
of a 7.5-mile segment of the Cullasaja River, below Lake Sequoyah, as a State Natural and Scenic River.
It is understood that the Town is concerned that the proposed designation might limit future expansion of
the Town's wastewater treatment plant or place tighter requirements on the level of wastewater treatment.
I have reviewed this matter with the Director of the Division of Parks and Recreation. Based on this
review, I would like to affirm that the proposed designation of the river as Natural and Scenic would not
undermine our willingness and desire to work with the Town on meeting its future wastewater needs. The
Department's support for the river's designation and our commitment to work with town on its future
wastewater needs are not mutually exclusive. Regardless of the river's designation under the Natural and
Scenic River Program, the state will work with the Town of Highlands to protect the Cullasaja River
while seeking to accommodate future growth opportunities for the Town. Enclosed is a March 11, 1999
letter to you from the Division of Water Quality that outlines requirements agreed to by the Town, State
and EPA for future wastewater treatment plant expansions.
In looking at the practical aspects of a State Natural and Scenic River designation upon discharges, it is
worth pointing out that no additional water quality regulations arc imposed as a result of such a
designation. The enabling legislation speaks to water quality only in that it requires as a minimum that
Class C water quality be maintained. It is also worth noting that there are many permitted industrial and
domestic discharges in, and upstream of, other designated Natural and Scenic Rivers. These include a
26.5-mile segment of the New River below Boone (18 discharges), a 115-mile segment of the Lumber
River (30 discharges), and segments of the Linville (7 discharges) and Horsepasture Rivers (7 discharges).
Expansions have been approved for several of these discharges on, or above. the designated segments that
have protected the rivers while meeting the needs of the dischargers.
In closing, I think it is fair to say that there are few other rivers in the state more deserving of the title of
Natural and Scenic than the Cullasaja River below Lake Sequoyah. The State of North Carolina and the
Town of Highlands share a vested interest in protecting this invaluable natural resource, and this interest
would be well -served by designating a portion the Cullasaja River below Lake Sequoyah as a State
Natural and Scenic River. It is my hope that this letter provides you with assurance that the proposed
designation of the river as Natural and Scenic will not undermine this Department's commitment to work
with the Town in meeting its future wastewater needs, and that you would join us in supporting the
Natural and Scenic designation of the river.
Sincerely,
5
Kerr T. Stevens
Attachment: March 11, 1999 letter outlining requirements for future expansion
cc: Senator Robert C. Carpenter
Senator Dan Robinson
Representative James C. Carpenter
Richard Betz
Bill Holman
Phillip McKnelly
Forrest Westall
w f t e M O n 1.
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1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617
website: h2o.enr.state.nc.us PHONE [phone] S FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary •
A. Preston Howard, Jr., P.E., Director
Mayor Buck Trott
Town of Highlands
P.O. Box 563
Highlands, North Carolina 28741
March 11, 1999
DENR
Subject: NPDES Permit Modification
Permit No. NC0021407
Highlands WWTP
Macon County
Dear Mayor Trott:
Enclosed is a special condition that is to be added to the Highlands WWTP discharge
permit that was issued on March 3, 1999. This condition outlines requirements of the wastewater
management alternatives analysis that must be followed prior to the Town's request for an
increase in design flow. These requirements were agreed upon during a meeting between the
Town, State and EPA on February 9, 1998 and were outlined in a March 16, 1998 letter from the
Division to the EPA.
Please find enclosed the section of the permit referenced in the preceding paragraph and
add this new section to the permit. All other terms and conditions contained in the original
permit remain unchanged and in full effect. These permit modifications are issued pursuant to
the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency.
We apologize if this modification has caused any inconvenience. If you have any
questions, please contact Paul Clark at [phone], ext. 580.
Sincerely,
cc: Central Files
Asheville Regional Office, Water Quality Section
Roosevelt Childress, EPA
Mike McGhee, EPA
Point Source Compliance/Enforcement Unit
Ernie Seneca
Bill Holman
Peg Jones
Tommy Stevens
\____
A. Preston Howard, Jr., P.E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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Permit No. NC0021407
• . . 1
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITION
A(3). WASTEWATER MANAGEMENT ALTERNATIVES ANALYSIS REQUIREMENTS
Prior to the Town's request for an increase in design flow (permit modification or reissuance), the Ton
must submit a description of the proposed expansion to the Division of Water Quality for evaluation under the
State Environmental Policy Act (SEPA). If the proposed project requires preparation of an environmental
document under the provisions of SEPA (NCAC TO1 25.0108 and T15A: O 1 C .0500), the document must include,
in addition to meeting all the provisions of SEPA, a thorough consideration of wastewater management options
available to the Town. Should the State determine that the development of a document under SEPA woult
required, as a part of the documentation necessary to apply for a flow increase under Division rules (NCAC T t be
02H .0100), the Town must submit an evaluation of wastewater management alternatives. Thus, whether or not a
SEPA document is required, the Town shall submit an analysis of wastewater management options. When a
preparing this analysis, the permittee should consult Guidance for the Evaluation of Wastewater Disposal
Alternatives (prepared by the NPDES Unit and attached to this letter). Some of the requirements contained
within
the Guidance document are mentioned below for purposes of clarification and emphasis and include the following:
owYng:
- Justification and demonstration of the need for the proposed flow increase must be provided. Flow reduction
(i.e., inflow/infiltration analyses) and water conservation measures must be investigated. The anal sis should
include flow reduction projections. Y
- No Action Option
- Accommodation of expected growth in wastewater management needs by private, on -site treatment disposal
systems. p
- Land application of the additional wastewater flow (greater than the current treatment plant desi n on u
(Forest Service) or private land (purchased, leased or use of property obtained by agreement). g) P blic
- Expansion of the existing treatment system along with the construction of a land application s stem for
or
a portion of the treated wastewater during all or a portion of the application year (requiring discharge and land
application permits). This alternative should consider the use of public and private property. g
- Expansion of the existing treatment system with the development of a treated wastewater reuse ro
utilizing public -and/or private property. P gram
- Expansion of the existing treatment system with discharge of the wastewater to the Cullasa'a River e
discharge point). J (xisting
In developing these alternatives and any others required as part of SEPA compliance applicable
if a must include the following considerations: ( PP ), the Town
- The practical, legal, administrative, and technical aspects of securing: (1) permission to use US For
Service property for application of wastewater and (2) cooperation of private land owners in allowingest
the
application or reuse of treated wastewater on land managed for recreational purposes, i.e. if courses.
s.
- The development of realistic cost projections (using Present Value of Costs Analysis) for each alternative
considered. Y )
- The impact of agency action to require higher levels of treatment on any expansion of the existing g discharge