NC0021407_Permit Issuance_20041014

NPDES DOCUMENT !MCANNIN` 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)
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
October 14, 2004
This document is printed on reuse paper - ignore any
content on the re-szerse side

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
AMENDMENT TO FACT SHEET, 10/14/2004
NPDES No. NC0021407, Town of Highlands WWTP
Facility Information
Applicant/Facility Name:
Town of Highlands/ Highlands WWTP
Applicant Address:
P.O. Box 460, Highlands, NC 28741
Facility Address:
1184 Arnold Road, Highlands, NC 28741
Permitted Flow
0.5 MGD (current)
1.5 MGD (requested expansion of flow)
Type of Waste:
100% Municipal - domestic type wastewater
Facility/Permit Status:
Major modification - modification to include additional flow
County:
Macon
Miscellaneous
Receiving Stream:
Cullasaja River
Regional Office:
ARO
Stream Classification:
B - Tr
Quad
G6SW, Highlands,/('
303(d) Listed?:
No
Permit Writer:
S. Wilson/�i��1/
Subbasin:
040401 (Little
Tennessee)
Date:
October 14, 2004
Drainage Area (mi2):
14.4
Lk
'i
.=- .._
Summer 7Q10 (cfs)
7.2
(7.45 winter)
30Q2 (cfs):
14
Average Flow (cfs):
50
IWC (%):
9.7 %
(at 0.5 MGD)
24%
(at 1.5 MGD)
Primary SIC Code:
4592
SUMMARY
The fact sheet and permit reflect the modification for the increased flow to 1.5 MGD. The
following statements are added as an amendment to the fact sheet dated August 9, 2004:
The expanded plant will serve as a regional treatment facility for the area. The Division has
determined that the proposed expansion is necessary to accommodate social and economic growth
in the area and that it wilt not result in contravention of surface water quality standards or loss of
designated uses in the receiving stream.
All other statements in the fact sheet remain unchanged.
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Susan Wilson at [phone] ext. 510.
Highlands NC0021407
NPDES Modification
Page 1

Michael F. Easley, Govemor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
October 13, 2004
Mr. Richard Betz, Town Administrator
Town of Highlands
P.O. Box 563
Highlands, North Carolina 28741
Subject: NPDES Permit Issuance
Highlands WWTP
Permit No. NC0021407
Macon County
Dear Mr. Betz:
Attached to this letter is the final NPDES permit for the Town of Highlands wastewater
treatment plant, NPDES Permit No. NC0021407 (which includes the expansion request to 1.5
MGD). This permit is issued pursuant to the requirements of North Carolina General Statute
143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency dated May 9, 1994.
There have been no changes to this permit from the draft permit dated August 18, 2004.
If any parts, measurement frequencies, or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request
within thirty (30) days following receipt of this letter. This request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed
with the office of Administrative Hearings, Mail Service Center 6714, Raleigh, North Carolina
27699-6714. Unless such a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division of
Water Quality. The Division of Water Quality may require modification or revocation and
reissuance of the permit.
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or
any other federal or local governmental permit.
If you have any questions regarding the NPDES permit, please contact Susan Wilson at
(919) 733 - 5083, extension 510.
Of?i''SIGNED BY
Tom Belnick
Alan W. Klimek, P.E.
cc: Asheville Regional Office/Surface Water Protection
NPDES Unit
Construction, Grants, and Loans Section/ Daniel Blaisdell, P.E.
Central Files
Mr. Roosevelt Childress, EPA Region IV
Brian L. Tipp, P.E.
WK Dickson & Co., Inc.
616 Colonnade Drive
Charlotte, NC 28205
North Carolina Division of Water Quality
1617 Mad Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

Permit NC0021407
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
Town of Highlands
is hereby authorized to discharge wastewater from a facility located at the
Highlands WWTP
Below Lake Sequoyah Dam west of Highlands
Macon County
to receiving waters designated as the Cullasaja River in the Little Tennessee River
Basin in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective November 1, 2004.
This permit and authorization to discharge shall expire at midnight on October 31, 2007.
Signed this day October 13, 2004.
ORIGINAL SIGNED BY
Tom Belnick
Alan W. Klimek P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0021407
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this
permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive
authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and
provisions included herein.
The Town of Highlands is hereby authorized to:
1. Continue to operate a 0.50 MGD dual -path wastewater treatment plant that includes
the following components:
> Influent screen
> Dual 0.25 MGD sequencing batch reactor tanks, each with 7.5 HP floating mixers,
gravity decanters and 2.0 HP sludge wasting pumps
> 30.0 HP blowers with coarse bubble diffusers and motorized inlet valves
> Sludge digesting system
> 69,000-gallon post -equalization basin
> Chlorine injection tank
> Dual 15, 700-gallon chlorine contact basins
> Dechlorination tank
> Ultrasonic flow meter
> Post aeration step weir
> 355 GPM dual -pump lift station
This facility is located west of Highlands at the Highlands WWTP below Lake Sequoyah
Dam in Macon County.
2. After receiving an Authorization to Construct permit from the Division, construct
wastewater treatment facilities not to exceed 1.5 MGD design flow.
3. Discharge wastewater from said treatment works at the location specified on the
attached map into the Ci.1lasaja~River, classified Class B-Trout waters in the Little
Tennessee River Basin.

State Grid/Quad: Highlands, N.C.
G6SW
Receiving Stream: Cullasaja River
Stream Class: B-Trout
Latitude:
Longitude:
Drainage Basin:
Sub -Basin:
2004
35° 04' 03" N
83°13'31"W
Little Tennessee
04-04-01
NPDES Permit NC0021407
Highlands WWTP

Permit NC0021407
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[0.50 MGD]
During the period beginning on November 1, 2004 and lasting until expansion above 0.50 MGD flow or
expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited
and monitored by the Permittee as specified below:
;EFFLUENT
_ G ;LIMI S .
;"' �... r F LLB' t x' :a , i
L.. .�:it.... ...s.a ` - ...x '`L �•
'
, MO11 TORINC RE' VIREVIENf S
/� � q
, C E. al S i
..._7., r
z
3
i
f' Mont yWeek
`a 4 e gs
_3
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. `aily
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aJimu��
Measremmaent
E 'I e
Yyque�
s
..amsaa �t.Yr
_rr
, �s.a!}:cr'.: szy'--7--
'on
ample zcatY ; x.{`
��ao.—Y�= I
Flow
0.50 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20° C 2
30.0 mg/L
45.0 mg/L
Weekly
Composite
Influent and Effluent
Total Suspended Solids2
30.0 mg/L
45.0 mglL
.
Weekly
Composite
Influent and Effluent
NH3 as N
(April 1- October 31)
8.3 mg/L
24.9 mglL
Weekly
Composite
Effluent
NH3 as N
(November 1- March 31)
20.0 mg/L
35.0 mg/L
Weekly
Composite
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
28 pglL
2/week
Grab
Effluent
Temperature
Weekly
Grab
Effluent
Upstream & Downstream
Dissolved 0xygen3
Weekly
Grab
Effluent
Upstream & Downstream
pH4
Weekly
Grab
Effluent
Toluene
3.7 jig/
Weekly
Grab
Effluent
Total Copper
Weekly
Composite
Effluent
Total Silver
Weekly
Composite
Effluent
Total Nitrogen
(NO2+ NO3 + TKN)
Semi-annually
Composite
Effluent
Total Phosphorus
Semi-annually
Composite
Effluent
Pollutant Scan5
Annually
Footnote 5
Effluent
Notes:
1. Upstream - upstream of the outfall, but below the dam. Downstream - downstream at the nearest
accessible site below the outfall.
2. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15
of the respective influent value (85 % removal).
3. The dissolved oxygen concentration shall not be less than 5.0 mg/L.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. See Condition A.(4.) regarding the annual pollutant scan requirement.
There shah be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0021407
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[1.50 MGD]
During the period beginning upon expansion above 0.50 MGD flow and lasting until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
;? EFFLUENT
C ` , sERISTICS'
3
LIMITS r
' ', _.. t
;MGNIT�ORINGREQUIREMENTS
t . E.,. , ....
' Mciii, y
! "Averages
Weekly
Average l
aDaily
Maximumm
Measurement
Frequency
tSample 1
. fT p e,
Sample Locai�ton 1
Flow
1.50 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20° C 2
30.0 mg/L
45.0 mg/L
Weekly
Composite
Influent and Effluent
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
Weekly
Composite
Influent and Effluent
NH3 as N
(April 1- October 31)
3.4 mg/L
10.2 mg/L
Weekly
Composite
Effluent
NH3 as N
(November 1- March 31)
6.9 mg/L
20.7 mg/L
Weekly
Composite
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Weekly
Grab
Effluent
Upstream & Downstream
Total Residual Chlorine
28 pg/L
2/week
Grab
Effluent
Temperature
Weekly
Grab
Effluent
Upstream & Downstream
Dissolved 0xygen3
Weekly
Grab
Effluent
Upstream & Downstream
pH4
Weekly
Grab
Effluent
Toluene
1.5 pg/L
Weekly
Grab
Effluent
Total Copper
Weekly
Composite
Effluent
Total Silver
Weekly
Composite
Effluent
Total Nitrogen
(NO2+ NO3 + TKN)
Semi-annually
Composite
Effluent
Total Phosphorus
Semi-annually
Composite
Effluent
Pollutant Scan5
Annually
Footnote 5
Effluent
Chronic Toxicity Testing6
Quarterly
Composite
Effluent
Notes:
1. Upstream - upstream of the outfall, but below the dam. Downstream - downstream at the nearest
accessible site below the outfall.
2. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15
% of the respective influent value (85 % removal) .
3. The dissolved oxygen concentration shall not be less than 5.0 mg/L.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. See Condition A. (4) regarding the annual pollutant scan requirement.
6. Chronic Toxicity (Ceriodaphnia dubia) P/F at 24%: March, June, September, and December [see
Special Condition A.(3)1.
There shall be no discharge o, f floating solids or visible, foam in other than trace amounts.

Permit NC0021407
A. (3) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or
significant mortality to Ceriodaphnia dubia at an effluent concentration of 24% (at 1.5 MGD).
The permit holder shall perform at a minimum, quarterlU monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February
1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the
months of March, June, September and December. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each
of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity
Test Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean
of the highest concentration having no detectable impairment of reproduction or survival and the
lowest concentration that does have a detectable impairment of reproduction or survival. The definition
of "detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ
Form AT-3 (original) is to be sent to the following address:
Attention:North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements
and all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the aquatic
toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the
month/year of the report with the notation of "No Flow" in the comment area of the form. The report
shall be submitted to the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may
be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.

Permit NC0021407
A. (4) EFFLUENT POLLUTANT SCAN
The Permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the attached table. The
analytical methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to
determine whether parameters are present in concentrations greater than applicable standards and
criteria. Samples shall represent seasonal variations. Unless otherwise indicated, metals shall be
analyzed as "total recoverable."
Ammonia (as N) Trans-1,2-dichloroethylene Bis (2-chloroethyl) ether
Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether
Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Phosphorus Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate
Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid -extractable compounds: Diethyl phthalate
Mercury P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro•o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile omanic compounds: Pentachlorophenol Hexachlorocyclo•pentadiene
Acrolein Phenol Hexachloroethane
Acrylonitrile 2,4,6-trichlorophenol lndeno(1,2,3-cd)pyrene
Benzene Base -neutral compounds: lsophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethyivinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-tichlorobenzene
1,1-dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane Bis (2-chloroethoxy) methane
Test results shall be reported to the Division in DWQ Form- A MR-PPA1 or in a form approved by
the Director within 90 days of sampling. The report shall be submitted to the following address:
Division of Water Quality, Water Quality Section, Central Files, 1617 Mail Service Center,
Raleigh, North Carolina 27699-1617.

•S' rFs
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
gi 1/ YW REGION 4
o Q ATLANTA FEDERAL CENTER
Z�"41.61 FORSYTH STREET
�il' 4 PROl-G�`O� ATLANTA, GEORGIA 30303-8960 _.,.—�� •,—-•;= � „. ,,, ,may•.r0 .—
SEP 0 2 2004'
Ms. Susan Wilson
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
j SEP 7 2004
1
DENR - WATER court
POINT SOURCE BRANCH
SUBJ: Draft NPDES Permit
Town of Highlands WWTP - NPDES No. NC0021407
Dear Ms. Wilson:
In accordance with the EPA/NCDENR MOA, we have completed review of the draft permit
referenced above and have no comments. We request that we be afforded an additional review
opportunity only if significant changes are made to the permit prior to issuance, or if significant
comments objecting to the draft permit are received. Otherwise, please send us one copy of the final
permit when issued.
If you have any questions, please call me at [phone].
Sincerely,
Marshall Hyatt, Environmental Scientist
Permits, Grants, and Technical Assistance Branch
Water Management Division
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

PUBLIC NOTICE
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(attached), In any Corr►
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a. • 5) tong:lam iifttfe.o re
▪ Whiittf'rDistrict (P.O.
Box 34$.. W ilttier, - NC
28789) _ applied . for-.- a
neiN permit NC90374o2 for
its Tf in Jackson
County. Tht-permlttedfa-
cifily will dcfiare the
Tuckaseegee• River, in the
Lif tie Tennessee River
rretlyi re•
sI, I ` c for ne is wafer
duality -limited. This
charge may
all • a ,. In npo . l e
Rite ,..
The= Town of.,Highlands,
P,C) gc (Hi' ands,-
NC 28741 IiEappt fbr a
modifiatlti6ft t`ifeNRDES.
tst waiter it.: :The
exi tnd the
,T rpermitto15
- veiti` 'continued
dii cha •t- niu.
rtictOdit into
the +cut i• River, a
Clams- B water in
the LittleTen Tennessee River
Basin; Armriattia, residual
chlorine, and -toluene are
water quality limited. This
discharge mayaffect fu-
turedischargees in this por-
tion of the river basin.
Aug 20, 2004
(01.
•
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
SS.
NORTH CAROLINA
Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified and
authorized by law to administer oaths, personally
appeared Janis Pierce, who, being first duly sworn,
deposes and says: that she is the Legal Billing
Clerk of The Asheville Citizen -Times, engaged in
publication of a newspaper known as The Asheville
Citizen -Times, published, issued, and entered as
second class mail in the City of Asheville, in said
County and State; that she is authorized to make
this affidavit and sworn statement; that the notice or
other legal advertisement, a true copy of which is
attached hereto, was published in The Asheville
Citizen -Times on the following date: August 20,
2004.
And that the said newspaper in which said notice,
paper, document or legal advertisement were
published were, at the time of each and every
publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of
the General Statues of North Carolina and was a
qualified newspaper within the meaning of Section
1-597 of the General Statues of Nara i Carolina.
Signed this 23rd day of August; 2
(Signature of j rson making affidavit)
Sworn to and subscribed befor
August, 2004
(Notary Pu ic)
My Co mission expires the 3rd day o
2008. ;$IL
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JOTARY��'m
PUBLIC Ci
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Town of Highlands WWTP
Subject: Town of Highlands WWTP
From: "Brian Tripp" <[e-mail]>
Date: Mon, 9 Aug 2004 15:02:04 -0400
To: <susan.a.wilson©ncmail.net>
Susan,
I have taken over as project manager for the aforementioned project at W. K. Dickson. We
received word from Forrest last week that he has reviewed all the documents concerning
the aforementioned project and that he called you to recommend that the Town be
authorized to "notice" the project. At this time, I just wanted to clarify the sequence of
steps with you include:
1-Public Notice - It is my understanding that you will do this, correct? Also, please clarify
when we can submit plans/specs (i.e. it was my understanding that we could do this once
the project was placed on public notice - is this correct?)
2-30 day comment period
3-NCDENR has 45 days to act upon close of comment period ( Based on comments
received the Director can issue permit, deny permit, conduct a public hearing, etc.)
4- Assuming no further public hearings are required we can receive a permit and be good
to go once the approval of plans and specs is received.
Thank you for your assistance with the this project. If I can be of any assistance or answer
any questions or concerns, please don't hesitate to contact me at [phone].
Brian L. Tripp, P.E.
W.K. Dickson & Co., Inc.
Community Infrastructure Consultants
616 Colonnade Drive
Charlotte, NC 28205
Phone - [phone]
Fax - [phone]
Email - [e-mail]
www.wkdickson.com
1 of 1 8/9/2004 3:24 PM

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0021407, Town of Highlands WWTP
Facility Information
Applicant/Facility Name:
Town of Highlands/ Highlands WWTP
Applicant Address:
P.O. Box 460, Highlands, NC 28741
Facility Address:
1184 Arnold Road, Highlands, NC 28741
Permitted Flow
0.5 MGD (current)
1.5 MGD (requested expansion of flow)
Type of Waste:
100% Municipal - domestic type wastewater
Facility/Permit Status:
Major modification - modification to include additional flow
County:
Macon
Miscellaneous
Receiving Stream:
Cullasaja River
Regional Office:
ARO
Stream Classification:
B - Tr
Quad
G6SW, Highlands
�w'
303(d) Listed?:
No
Permit Writer:
S. Wilson
Subbasin:
040401 (Little
Tennessee)
Date:
August 9, 2004
Drainage Area (mi2):
14.4
._A _.
•
Summer 7Q10 (cfs)
7.2
(7.45 winter)
30Q2 (cfs):
14
Average Flow (cfs):
50
IWC (%):
9.7 %
(at 0.5 MGD)
24%
(at 1.5 MGD)
Primary SIC Code:
4592
SUMMARY
The Town of Highlands serves a permanent population of approximately 1800 people with a
much higher seasonal (summer) population. The proposed expansion reflects population/flow
projections to the year 2025. The Town has no significant industrial users and does not
have/need a pretreatment program. Speculative limits were submitted to the town via letter
dated August 14, 2002. Highlands completed an Environmental Assessment (EA) and received
a Finding of No Significant Impact on November 18, 2003.
Highlands submitted a complete application for expansion May 6, 2004 (prior to this - the
project had been returned due to a lack of information to fulfill the application requirements).
The EA contained a Preliminary Engineering Report outlining alternatives to discharge.
Discharge was found to be the most feasible option for the additional 1.0 MGD of wastewater
flow. With all alternatives, the additional treatment would be added. The Division of Water
Quality determined that the incremental impact of the increased wastewater flow would not
result in contravention of applicable water quality standards or Loss of the river's designated
uses, so that expansion of the existing treatment plant and continued discharge to the
Cullasaja River is the most feasible alternative.
This fact sheet and permit reflect the modification for the increased flow to 1.5 MGD. This
modification will put Highlands into 'major' permit status (over 1 MGD).
Highlands NC002 1407
NPDES Modification
Page t

TOXICITY TESTING:
Current Requirement: Toxicity testing is not currently required (at 0.5 MGD - the facility is
not classified as a major).
Proposed Requirement: Chronic P/F at 24%, January, April, July, October.
At 1.5 MGD, the facility will be classified as a "major" facility and subject to toxicity testing, per
Division of Water Quality guidance.
COMPLIANCE SUMMARY: BASED ON THE PREVIOUS 2 YEARS
There are no outstanding and/or chronic compliance problems related to the NPDES permit.
The facility did have some issues with toluene (after the renewal permit was issued in 2003);
this appears to have been corrected now.
(Review of 2 years of data, via BIMs pull, does not reveal any obvious compliance problems).
INSTREAM MONITORING:
The Town of Highlands is required to monitor fecal coliform, temperature, and dissolved oxygen
upstream and downstream of the outfall. Instream monitoring from 2002 - 2004 was reviewed.
There appeared to be no significant difference between upstream and downstream data and all
instream DO values were well above 6 mg/1. There were approximately 2 instances of fecal
coliform values above 400#/100 ml (upstream and downstream); likely this was in response to
a rain event (no violations of effluent fecal coliform were noted during those times).
PROPOSED CHANGES:
Speculative limits were presented to the Town of Highlands via letter dated August 24, 2002.
An EPA approved water quality model was used to derive the effluents limits necessary to
protect water quality downstream of the discharge. Based on this water quality model and the
low flow of the receiving stream (along with the higher design wasteflow), limits will be slightly
more stringent than the existing limits.
The ammonia limits will be slightly lower than the previous limits (due to the increased
wasteflow). A chronic toxicity testing requirement will be added.
An annual pollutant scan has been required to comply with the new EPA municipal application
stipulations.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: August 18, 2004 (est.)
Permit Scheduled to Issue: October 11, 2004 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Susan Wilson at [phone] ext. 510.
REGIONAL OFFICE COMMENT:
NAME: DATE:
Highlands NC0021407
NPDES Modification
Page 2

Facility: Highlands WWTP
Discharge to: Cullasaja River, 6 Tr
Residual Chlorine
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (UG/L)
IWC (%)
Allowable Conc. (ug/I)
Fecal Limit
Ratio of 3.1 :1
DA = 14.4 mi2
7Q10s = 7.2 cfs
7Q10w = 7.45 cfs
30Q2 = 14 cfs
Ammonia as NH3
(summer)
7.2 7Q10 (CFS)
1.5 DESIGN FLOW (MGD)
2.325 DESIGN FLOW (CFS)
17.0 STREAM STD (MG/L)
0 UPS BACKGROUND LEVEL (MG/L)
24.41 IWC (%)
69.65 Allowable Concentration (mg/I)
Ammonia as NH3
(winter)
7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Concentration (mg/I)
For Minor domestic -type facilities:
Minimum of 2 mg/I (summer) NH3-N; 4 mg/1 (winter) NH3-N
Chlorine:
Residual chlorine must be capped at 28 ug/I to protect for acute toxicity effects
7.2
1.5
2.325
1.0
0.22
24.41
3.42
7.45
1.5
2.325
1.8
0.22
23.79
6.86

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
OUTFALL: 001
EFFLUENT
COUNTY: Macon
PERIOD ENDING MONTH: 4 - 2004
REGION: Asheville
DMR 12 Month Calculated
PAGE 1 OF 2 •
00010
deg c
Temperature,
Water Deg.
Centigrade
00300
mg/1
DO, Oxygen,
Dissolved
00310
mg/1
BOD, 5-Day (20
Deg. C)
00340
mg/1
COD, Oxygen
Demand, Chem.
(High Level)
00400
su
pH
00500
mg/1
Solids, Total
00530
mg/1
Solids, Total
Suspended
00545
ml/1
Solids,
Settleable
5 - 03
30
30
16.05
6.275
12.9
6.7 - 6.9
13.6
6 - 03
'�'
30
18.525
7
7.3
6.9 - 7.1
6.225
7-03
30
36
20.48
6.28
5.5
6.7 - 7
4.8
8 - 03
30
30
21.05
5.675
7.125
6.8 - 7.1
5.025
9 - 03
30
30
19.04
6.18
4.98
6.9 - 7.1
7.16
10 - 03
30
30
15.775
6.75
5.675
6.8 - 7
10.475
11 - 03
30
30
13.875
6.65
10.675
6.6 - 6.8
12.05
12 - 03
30
30
7.44
7.42
6.6
6.8 - 7
16.78
1 - 04
30
30
6.525
7.375
7.55
6.8 - 7
5.6
2 - 04
30
30
5.4
7.5
9.4
6.9 - 7
12.35
3 - 04
30
30
9.02
7.14
6.54
6.9 - 7.1
8.26
4-04
30
3C
12.4
7.1
8.2
6.9 - 7
5.05

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
COUNTY: Macon
PERIOD ENDING MONTH: 4 - 2004
REGION: Asheville
DMR 12 Month Calculated
PAGE 2 OF 2
00600
mg/1
Nitrogen,
Total (as N)
00610
mg/1
Nitrogen,
Ammonia Total
(as N)
00665
mg/1
Phosphorus,
Total (as P)
31616
#/100m1
Coliform,
Fecal MF, M-FC
Broth,44.5C
31616
mpn/100m1
Coliform,
Fecal MF, M-FC
Broth,44.5C
50050
mgd
Flow, in conduit
or thru
treatment plant
50060
mg/1
Chlorine,
Total Residual
50060
ug/1
Chlorine,
Total Residual
5-03
8.3
0.5
0.1
1
0.209097
0
6 - 03
8. a3
0.5
0.1
1
0.206267
0
7-03
8.3
0.5
5.38
1.677916
0.235903
0
8-03
8.5
0.5
4.6
1
0.210258
0
9-03
8.'
0.5
1.52
1.462901
0.207
0
10-03
8.3
0.5
1.78
0.45
1.78
1
0.176548
0
11 -03
20
0.5
0.525
1
0.188033
0
12-03
20
0.5
0.32
1
0.160677
0
1 -04
20
0.5
0.2
1
0.13471
0
2-04
20
0.5
0.225
2.279507
0.153207
0
3-04
20
0.5
0.58
1
0.125419
0
4-04
8.3
0.5
2.3
0.65
1
1
0.141933
0

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
OUTFALL: 001
EFFLUENT
COUNTY: Macon
PERIOD ENDING MONTH: 4 - 2003
REGION: Asheville
DMR 12 Month Calculated
PAGE 1 OF 2 •
00010
deg c
Temperature,
Water Deg.
Centigrade
00300
mg/1
DO, Oxygen,
Dissolved
00310
mg/1
BOD, 5-Day (20
Deg. C)
00340
mg/1
COD, Oxygen
Demand, Chem.
(High Level)
00400
su
pH
00500
mg/1
Solids, Total
00530
mg/1
Solids, Total
Suspended
00545
ml/1
Solids,
Settleable
5 - 02
30
30
16.275
5.725
9.3
6.8 - 7
4.325
6 - 02
30
30
20.1
5.375
7.075
6.7 - 6.9
4.85
7 - 02
30
30
21.74
5.26
6.88
6.7 - 6.9
3.64
8 - 02
30
30
22.225
5.15
6.2
6.8 - 6.9
0.7
9 - 02
30
30
20.75
5.25
7.3
6.7 - 6.9
4.375
10 - 02
30
30
17.86
6.54
8.62
6.7 - 7
1.8
11 - 02
30
30
12.125
6.575
8.45
6.7 - 7
10.475
12 - 02
30
•
7.82
7.18
6.04
6.8 - 7
3.6
1 - 03
30
30
4.475
7.925
6.125 .
6.8 - 7.1
2.15
2 - 03
30
30
5.725
7.35
8.2
6.8 - 7
13.25
3 - 03
30
30
9.7
6.75
9.55
6.7 - 6.9
2.45
4 - 03
30
30
12.42
6.68
12.52
6.9 - 7.1
3.62

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
COUNTY: Macon
PERIOD ENDING MONTH: 4 - 2003
REGION: Asheville
DMR 12 Month Calculated
PAGE 2 OF 2
00600
mg/1
Nitrogen,
Total (as N)
00610
mg/1
Nitrogen,
Ammonia Total
(as N)
00665
mg/1
Phosphorus,
p
Total (as P)
31616
#/100m1
Coliform,
Fecal MF, M-FC
Broth,44.5C
31616
mpn/100m1
Coliform,
Fecal MF, M-FC
Broth,44.5C
50050
mgd
Flow, in conduit
or thru
treatment plant
50060
mg/1
Chlorine,
Total Residual
50060
ug/1
Chlorine,
Total Residual
5 - 02
0.5
0.5
0.25
1
0.161323
0
6 - 02
8.5
0.5
0.425
1
0.155233
0
7 - 02
8.5
0.5
0.86
0.82
0.63
1
0.179452
0
8 - 02
8.5
0.5
0.2
1
0.161968
0
9-02
8.3
0.5
0.325
1
0.199567
0
10-02
"5
0.04
1
0.192323
0
11 - 02
20
0.5
2.39
0.05
2.84
1
0.178133
0
12 - 02
20
0.5
0.46
1
0.167161
0
1 -03
20
0.5
4.45
1
0.141613
0
2-03
20
0.5
0.725
1
0.144357
0
3-03
20
0.5
0.175
1
0.14871
0
4 - 03
8.3
0.5
2.84
0.22
1.78
1
0.1721
0

Re: comments on NC002 1407, Town of Highla...
Subject: Re: comments on NC0021407, Town of Highlands WWTP
From: Susan Wilson <[e-mail]>
Date: Thu, 02 Sep 2004 10:49:58 -0400
To: [e-mail]
CC: [e-mail], [e-mail]
Marshall -
1. I'll revise the language and include as a fact sheet amendment.
2. As with many WQ standards - the effluent limits are not necessarily reflective of the
instream water quality standard, but they are protective of the instream WQS. In this case
- our EPA -approved Level B water quality model indicated that with the BOD5/NH3-N
effluent limits, along with an effluent DO limit of 5 mg/1, the instream standard D.O. of 6
mg/1 for trout waters was protected.
3. Highlands recently renewed their permit (issued 2/2003). Since the analytical data
provided for the renewal was less than 4 years old - I thought that data was sufficient for
this modification. Most of the data (except some of the second species tests) was prior to
Sept. 2003, when the new Hg testing method took effect. Also, prior to this modification -
they were not a major, had no existing Hg limit or monitoring requirement, and had no
pretreatment program - so were not on our initial list for the new method.
4. I'll definitely keep you guys informed of the comments we receive and if we need to go to
public hearing. I'm going to hold off on the fact sheet amendment in case we get significant
public comments - so far, I have received none.
Susan
[e-mail] wrote:
1. The fact sheet indicates that this facility is expanding and cites
completion of an EA by the Town and of receiving a FNSI from NC. The
fact sheet goes on to say that the proposed expansion is the most
feasible alternative and will not cause a loss of designated use nor
contravention of applicable WQS. 40 CFR Part 131.12(a)(2) requires
that for this (or any) expansion, the State must fmd that allowing
lowering water quality is necessary to accommodate important economic or
social development in the area in which the waters are located. There
is no such finding cited in the fact sheet. If the State can make this
finding, the fact sheet needs to express it.
2. If the DO criterion for trout waters is 6.0 mg/1, why is the DO
minimum in this permit 5.0 mg/1?
3. The permit application indicates that the facility used Method
245.1, rather than Method 1631, for Hg. Because NC has required use of
Method 1631 since September 2003, the permit should require at least
quarterly sampling for Hg using Method 1631 during the first year after
the permit modification is issued. The permit may include a reopener
to include Hg limits if the monitoring data so indicate.
5F-1
hudi ia„I ,r"1
1 of 2 9/2/2004 10:53 AM

Re: comments on NC0021407, Town of Highla...
4. Need to remind you that if any public comments are received that
object to this permit, the NPDES MOA requires that you send us a
proposed final permit for review, as well as a summary of comments
received and your response to them.
2 of 2 9/2/2004 10:53 AM

AUG-10-2004 12:50 FROM:WAT 8282964663
TO:919197330719 P:1'5
DICKSONPikWK
aP
community infrastructure consultants
July 20, 2004
Mr. Forrest Westall
NCDENR, Asheville Regional Office
Water Quality Section
2090 US Hwy.70
Swannaoa, North Carolina 28778
Re: NPDES Permit Application
Cullasaja River Wastewater Treatment Plant Expansion
Highlands, North Carolina
WKD # 20412.11.CL -I
Dear Mr. Westall:
We offer the following response to the review comments by Susan A. Wilson, PE regarding
Wastewater Management Analysis Requirements. For your convenience we are also including copies
of the Preliminary Engineering Report and the SEPA Environmental Assessment, a copy of Susan
Wilson's comments. We would like to schedule a meeting at your earliest convenience to discuss our
response and any concerns you may have.
Sincerely,
G. Tim Lowder, PE
vice President
Enclosures
cc: Mr. Richard Betz — Highlands
(,16 0o1onn,1dee Drive
Charlotte, NC 1112115
Ti.'I. 704.3.;4.5340
tot 704 :114 0078
www.wkdic k!,on.com
Post-Ir Fax Note 7671
oaro
Paa q►
TaJ ,
co./onot.
Phenol,
Fax It
From,„41-w
Co
Fax
UHighlands/2041211/l/Westall•A VI. R,sq,ona1072004
Nurlh (.around - South Carolina Geo'gla • Florida

AUG-10-2004 12:50 FROM:WAT 8282964663 TO:919197330719 P:2'5
Reply to comments from Susan A. Wilson, PE regarding Wastewater Management
Analysis Requirements.
Justification and demonstration of the need for the proposed flow increase must be
provided. Flow reduction. (i.e. inflow/infiltration analyses) and water conservation must
be investigated. The analysis should include flow reduction projects.
Environmental Assessment Section 2.2 Pages 2-3.
Preliminary Engineering Report Section 3 pages 3-11.
No Action Option
The growth in the arca surrounding the Town of Highlands continues, without the
cxpansion of the Cul.lasaja River Wastewater treatment Plant, private systems will
continue to be permitted, and existing systems that have currently experienced
problems wi.1.l. have to find alternative repair. options. The expansion of the usc of
private waste disposal systems will offer less control and provide unreliable long
tern sewer given the recent history of onsitc waste disposal systems in thc area,
see Environmental Assessment, Appendix E, letter Kenneth Ring, Macon County
Health Director, April. 16, 2003.
Accommodation of expected growth in wastewater management needs by private, on -site
treatment disposal system.
Environmental Assessment, Appendix E
Land application of the additional wastewater flow (greater than the current treatment
plant design) on public (Forest Service) or private land (purchased, leased or usc of
property obtained by agreement).
Preliminary Engineering Report Section 4 Option 2 pages 14-15
Expansion of the existing treatment system along with the construction of a land
application system for all. or a portion of thc treated wastewater during all or a portion of
the application year (requiring discharge and land application permits). This alternative
should consider thc use of public and private property.
Preliminary En.gi,rieerin.g Report Scction 4 Option 2 Pages 14-15

AUG-10-2004 12:51 FROM:WAT 8282964663
TO:919197330719 P:3/5
Expansion of the existing treatment system with the development of a treated wastewater
reuse program utilizing public and/or private property.
Preliminary Engineering Report Section 4 Option 4 Pages 17-18
Expansion of the existing treatment system. with discharge of the wastewatcr to the
Cullasaja River (existing discharge point).
Preliminary Engineering Report Section 4 Option 1 Pages 1 i -13
In development these alternatives and any others required as part of SEPA compliance (if
applicable), the Town must include the following considerations:
The practical, legal, administrative, and technical aspects of securing: (1) permission to
thc use US Forest Service property for application of wastewater and (2) cooperation of
private land owncrs in allowing the application or reuse of treated wastewater on land
managed for recreational purposes, i.e., golf courses.
Preliminary Engineering Report Section 4 Option 2 Page 14
Section 4 Option 4 Pages 17-18
The development of realistic cost projections (using Present Value of Costs Analysis) for
each. alternative considered.
Preliminary Engineering Report Appendix A, B, C, & D.
The impact of agency action to require higher levels of treatment on any expansion of the
existing discharge volume.
The requirement for highcr levels of treatment has not bccn evaluated; basis of
design and the preliminary cost estimate are based on the spcculativc limits
received by NCDENR August 14, 2002. Sec Preliminary Engineering Report
Appendix G. The Town of Highlands has been. very proactive in insuring the
water quality of the Culasaja River. The current treatment process and the basis of
design for the expansion will meet all of NCDENR's speculative limits. The
Town. of Highlands has elected to add Tertiary Filters to the treatment process that
will provide a wastewater, discharge well below the speculative limits presented
by NCDENR. Preliminary design and cost estimates have included Tertiary
Filters and UV Disinfection Facilities. Hi.gh.lan.ds prcfcrs not to see the limits
lowered, as additional. changes in thc treatment process may .not allow thcm to
meet their already expanded approved budget for thc project.

AUG-10-2004 12:51 FROM:WAT 8282964663
TO:919197330719 P:4/5
(it' "' ' C,Q MIcnact I-. ta;,tCy
�fl, 06 Governor
• 7 William G. Ross, Jr., Secretary
? North Carolina Department of Environment and Natural Resources
Y
Water Quality Section/ NPDES Unit
FAX: [phone]
5/13/04
Alan W. Klimek. P E., Director
Divieion of water ()utility
FAX TO: Mike Osborne, P.E.
WK Dickson
FAX NUMBER: 704 334 0078
Re.: Highlands expansion N 0021 ' •
4
FROM: Susan A. Wilson, P_E.
PHONE: [phone], ext. 510
NO. OF PAGES INCLUDING THIS SHEET: 2
Mike,
Here's a copy of the stipulations regarding axpanslon. This was done as a permit modification March 11, 1999 as
a result of a meeting between the Town, DWO, and EPA. I'm hopeful that most of these items were covered
within the EA (and subsequent EAA). I'd suggest, since you have not yet met with Forrest Westail and/or Kevin
Barnett, that you schedule a meeting with them to discuss the project and discuss these items (since Forrest was
at the original meeting). After you've had that discussion — we'll require that you (or the Town) go over each item
and reference where each of these were addressed in the EAA and/or EA.
The application looks complete and 11 has been accepted. A copy of the application will be submitted to EPA with
the draft permit. Give me a ring if you have questions,
Susan
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AUG-10-2004 12:51 FROM:WAT 8282964663
niir NO. N1..UU21'fU/
TO:919197330719 P:5'5
00
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITION
A(3). WASTEWATER MANAGEMENT ALTERNATIVES ANALYSIS REQUIREMENT S ..
Prior to the Town's request for an increase in design flow (permit modification or reissuance), the Town
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 T1SA: 01 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 would not be
reqqu��ired, as a part of the documentation necessary to apply for a flow increase under Division rules (NCAC T1 SA
02k1.0100), the Town must submit an evaluation of wastewater management alternatives, Thus, whether or not a
S FPA document is required, the Town shall submit an analysis of wastewater management options. When
preparing this analysis, the pennittee 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:
- 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.investigatcd. The analysis should
include flow reduction projections.
- No Action Option
- Accommodation of expected growth in wastewater management needs bye private, on -site treatment disposal
systems.
- Land application of the additional wastewater flow (greater than the current treatment plant design) on public
(Forest Service) or private land (purchased, leased or use of property obtained by agreement).
- Expansion of the existing treatment system along with the construction of a land application system for all or
a portion of the treated wastewater dung 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.
• Expansion of the existing treatment system with the development of a treated wastewater reuse program
utilizing public and/or private property.
Expansion of the existing treatment system with discharge of the wastewater to the Cullasaja River (existing
discharge point).
In developing these alternatives and any others required as part of SEPA compliance (if applicable), the Town
must include the following considerations:
- The practical, legal, administrative, and technical aspects of securing: (1) permission to use US Forest
Service property for application of wastewater and (2) cooperation of private land owners in allowing the
application or reuse of treated wastewater on land managed for recreational purposes, i.e., golf courses.
- The development of realistic cost projections (using Present Value of Costs Analysis) for each alternative
considered,
- The impact of agency action to require higher levels of treatment on any expansion oldie existing discharge
volume.
CO 'd Z6 :0 t 000Z 6 I n f 61LOF,EL616:xeJ ]3HflOs LN I Od OiQ

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Water Quality Section/ NPDES Unit
FAX: [phone]
7/9/04
FAX TO: Tim Lowder
Re.: Highlands
FAX NUMBER: 704 334 0078
FROM: Susan A. Wilson, P.E.i4k,
PHONE: [phone], ext. 510
NO. OF PAGES INCLUDING THIS SHEET:
Tim,
Here's what I had previously faxed to Mike O. Also — as I was telling you on the phone, I've reviewed the
previous speculative limits and am satisfied with those (meaning I don't anticipate any changes to those). I've got
the structure for the permit completed (along with the fact sheet we have to do for the permit). Once you guys get
those items in A(3) referenced and have the discussion with the region — when I get back from vacation I should
be able to submit the permit for public notice (first or 2nd week in August).
Susan

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Water Quality Section/ NPDES Unit
FAX: [phone]
5/13/04
FAX TO: Mike Osborne, P.E.
WK Dickson
Re.: Highlands expansion N 00214
FAX NUMBER: 704 334 0078
FROM: Susan A. Wilson, P.E.
PHONE: [phone], ext. 510
NO. OF PAGES INCLUDING THIS SHEET: 2
Mike,
Here's a copy of the stipulations regarding expansion. This was done as a permit modification March 11, 1999 as
a result of a meeting between the Town, DWQ, and EPA. I'm hopeful that most of these items were covered
within the EA (and subsequent EAA). I'd suggest, since you have not yet met with Forrest Westall and/or Kevin
Barnett, that you schedule a meeting with them to discuss the project and discuss these items (since Forrest was
at the original meeting). After you've had that discussion - we'll require that you (or the Town) go over each item
and reference where each of these were addressed in the EAA and/or EA.
The application looks complete and it has been accepted. A copy of the application will be submitted to EPA with
the draft permit. Give me a ring if you have questions.
Susan
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'Pen i t No. NC0021407
e
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 Town
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: O1 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 would not be
required, as a part of the documentation necessary to apply for a flow increase under Division rules (NCAC T15A
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
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:
- 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 analysis should
include flow reduction projections.
- No Action Option
- Accommodation of expected growth in wastewater management needs by private, on -site treatment disposal
systems.
- Land application of the additional wastewater flow (greater than the current treatment plant design) on public
(Forest Service) or private land (purchased, leased or use of property obtained by agreement).
- Expansion of the existing treatment system along with the construction of a land application system for all 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.
- Expansion of the existing treatment system with the development of a treated wastewater reuse program
utilizing public and/or private property.
- Expansion of the existing treatment system with discharge of the wastewater to the Cullasaja River (existing
discharge point).
In developing these alternatives and any others required as part of SEPA compliance (if applicable), the Town
must include the following considerations:
- The practical, legal, administrative, and technical aspects of securing: (1) permission to use US Forest
Service property for application of wastewater and (2) cooperation of private land owners in allowing the
application or reuse of treated wastewater on land managed for recreational purposes, i.e., golf courses.
- The development of realistic cost projections (using Present Value of Costs Analysis) for each alternative
considered.
- The impact of agency action to require higher levels of treatment on any expansion of the existing discharge
volume.

Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
May 6, 2004
Mr. Richard Betz, Town Administrator
P.O. Box 460
Highlands, North Carolina 28741
Subject: NPDES Permit Application
Town of Highlands Expansion Request
NPDES No. NC0021407
Macon County
Dear Mr. Betz:
The Division of Water Quality received the Town of Highlands application for a major
modification of the Town's NPDES permit (NC0021407) on April 26, 2004. An initial review of the
project indicates that the information for the application is complete and those items previously
lacking have been provided. The Division also received the Town's two checks for a total of fee of
$860 for the modification. Please accept this letter as acknowledgement of the completed
application.
The Division cannot accept the plans and specifications that were submitted with the
completed application. As has been discussed with your consultant in the past, plans and
specifications cannot be submitted until after the draft permit has been publicly noticed. The
plans and specifications are being returned to you. Please contact me prior to resubmitting them
in the future. As stated in the previous correspondence, the Town should also be aware that to
enter into a contract for construction would be in violation of North Carolina General Statute 143-
215.1 (a)(8) and potentially subject to a civil penalty of $25,000 per day per violation.
Also, as expressed to Mr. Osborne, your consultant with W.K. Dickson, it would be wise if
the Town would speak with representatives of the Division's Asheville Regional Office regarding the
project. Forrest Westall and/or Kevin Barnett should be contacted (Mr. Westall has had a long
history with the Town of Highlands) to discuss the project. They may be contacted at their new
office in Swannanoa, (828) 296 - 4500.
You and/or your consultant may contact me at [phone], ext. 510 should you have
further questions regarding the project.
Sincerely,
Susan A. Wilson, P.E.
NPDES Unit
cc: Asheville Regional Office, Water Quality Section
NPDES file
Michael Osborne, P.E.
WK Dickson
616 Colonnade Drive
Charlotte, NC 28205
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

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Re: Highlands
•
Subject: Re: Highlands
From: Susan Wilson <[e-mail]>
Date: Fri, 16 Jan 2004 10:48:23 -0500
To: Michael Osborne <[e-mail]>
CC: "Richard Betz (E-mail)" <[e-mail]>, Forrest Westall
<[e-mail]>, Kevin Barnett <[e-mail]>
Mike,
Our EPA contact is out today - so I can't give you an answer, but he's pretty responsive and
will likely give me a call back on Tuesday. I'll call you and send an e-mail as soon as I hear
back from him.
From the state's perspective - we're fine with the tests that have been conducted. However,
EPA has been very particular about the application form, so I want to make sure I have our
contact's buy -off before I tell you anything. I made the assumption that Highlands already
conducted chronic tests (then realized that they do not right now because they are under 1
MGD). I'll speak with our contact and explain the situation to them and see what he says.
I'd rather go ahead and get his input now rather than have EPA delay the process after the
draft is sent to public notice. The other thing is - they've been very particular about the
timing of the tests - the tests are supposed to represent seasonal variation. I do not know
if he'll have issues with the timing of the tests that were conducted (a couple of them do not
have even a 30 day separation). Unfortunately, all our municipalities applying for renewals
and/or expansions have been subject to this new application requirement and it's fairly
confusing right now.
Also, as we discussed on the phone, it would be wise for you guys to touch base with the
Asheville Regional Office (Forrest Westall and Kevin Barnett). Kevin and I have spoken
about Highlands during the Environmental Assessment process, but it would be wise to
speak with Forrest as he knows much of the history with Highlands (more than Kevin and
me). Their no. is 828-251-6208.
After you have a complete application - go ahead and send the original and one copy
directly to me, and one copy to the Asheville Regional Office, Water Quality, 59 Woodfm
Place, Asheville, NC 28801.
Thanks much.
Michael Osborne wrote:
Susan,
As I was looking through the toxicity testing information, I remembered that testing on a
second species was performed. The testing was as follows:
Three tests on species Ceriodaphnia and one test on Pimephales Promelas.
Do we still need 3 more tests on Pimephales?
Thanks for the help!
Mike
****************************************
J. Michael Osborne, PE
1 of 2 1/16/2004 10:48 AM

Re: Highlands
1 '
Project Manager
W. K. Dickson - Charlotte Office
[phone]
Original Message
From: Susan Wilson[mailto:[e-mail]
Sent: Friday, January 09, 2004 1:40 PM
To: Michael Osborne
Subject: Highlands
Mike,
Prior to the holiday's, I was drafting a letter to return the project (I was advised to do this
as we're not inclined to keep projects in-house if much additional information is
needed). It took me some time to figure out if the application was complete (due to the
piece -meal fashion it was submitted). I think I might have even searched the previous
renewal information to figure out if there was anything else. I think there are something
like four different piece -meal documents for the application. This is not acceptable. You
guys needed to put all that information together into one complete document (for ease of
my review, for EPA's review, and for the general public) and update it where appropriate.
The application is essentially the same one that was used for the renewal.
The other thing is, EPA allowed us to accept one alternate species test with renewals
prior to Jan. 2003 (because it was a new requirement at the time). With this expansion
request - that will not be acceptable (because the new application form has been out
there since 2001) . Highlands needs to conduct 3 more alternate species tests (the one
that was conducted previously is still acceptable, but we need 3 more). EPA has become
very rigorous about the required tests in the application - they are making us to hold up
some permits because of it. I think it would be OK if Highlands does the alternate
species tests without much separation time (but they can't do 3 tests all in the same
week).
The fee - and I didn't realize this was the case until after you submitted it - it is $860
because this is a major permit modification. I apologize for not catching this before.
An unprotected copy of the letter is attached. You'll be getting a hardcopy soon. Let me
know if you have questions.
2 of 2 1/16/2004 10:48 AM

W
.o
1,9
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
January 9, 2004
Mr. Richard Betz, Town Administrator
P.O. Box 460
Highlands, North Carolina 28741
Subject: Return of NPDES Permit Application
Town of Highlands Expansion Request
NPDES No. NC0021407
Return No. 2207
Macon County
Dear Mr. Betz:
The Division of Water Quality received the Town of Highlands application for a major
modification of the Town's NPDES permit (NC0021407) on November 19, 2003, as submitted by
your consultants, WK Dickson & Company, Incorporated. The application is lacking complete
information and is being returned to your consulting engineer. The initial review of the project
indicates that the information listed below must be provided before a permit can be developed for
the project. Many of the items stipulated are necessary due to EPA's new municipal application
form. The expansion of the facility will require review by EPA Region IV (as with all of North
Carolina's major NPDES permits), so this information must be completed.
Please provide the following items:
1. EPA Permit Application 2A Requirements. The EPA Application has been submitted in
various parts (and seems to be the exact application as was submitted for the renewal);
although some items will remain the same, other items should be updated where
applicable. Please have your consultant, if you choose, update the 2A application
(especially Part A.12., Part B.6.), compile it in one document, and obtain an updated
signature from the Mayor (or you may, as the Town Administrator, sign the application).
Also, reference on the permit application that the current design flow is 0.5 MGD and the
Town requests an expansion to 1.5 MGD (Part A.6). The dates the tests were conducted for
Part D should be stipulated on the application (three tests were conducted, which should
satisfy the EPA requirement, but the dates should be provided).
2. Part E of the EPA application form must be completed. This requires the Town of
Highlands to conduct, at a minimum, four whole effluent toxicity tests with an alternate
species (Pimephales promelas, as opposed to Ceriodaphnia dubia). With the previous
renewal, one test was acceptable at that time. With the expansion request, three
additional tests must be conducted (the test conducted August 2002 can be included as
part of the required four tests).
3. Because this is a major modification, the fee is $860. This is based on a statutory change,
which became effective January 1999 [ref. North Carolina General Statute 143-215.3D).
Highlands' check for $400 is being returned to you. You may add an additional $460 or
submit a new check for $860. DWQ apologizes for the confusion.
The Town should also be aware that to enter into a contract for construction would be in violation
of North Carolina General Statute 143-215.1 (a)(8) and potentially subject to a civil penalty of
$25,000 per day per violation.
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

Mr. Betz
Page 2
Copies of the various pertinent documents are being returned to your consultant (and one
copy will be retained in the NPDES Unit). When resubmitting the application, forward one copy to
me and one copy to:
Kevin Barnett, Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
You and/or your consultant may contact me at [phone], ext. 510 should you have further
questions regarding the project.
Sincerely,
san A. Wilson, P.E.
NPDES Unit
cc: Asheville Regional Office, Water Quality Section
NPDES file
Michael Osborne, P.E. (w/ documents)
WK Dickson
616 Colonnade Drive
Charlotte, NC 28205

\N A TF
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
November 19, 2003
Mr. Richard Betz, Town Administrator
Town of Highlands
PO Box 460
Highlands, NC 28741
Subject: Environmental Assessment; Highlands Wastewater Treatment Plant Expansion
Dear Mr. Betz:
The NC Environmental Policy Act review for the subject project is complete. No comments were
received during the course of the State Clearinghouse review (see attached letter from the
Clearinghouse).
Permit applications covering activities associated with this project may now proceed. The
applications should be consistent with the Finding of No Significant Impact issued by the
Division of Water Quality on October 6, 2003 (attached).
If there is anything else I can assist you with, please give me a call at 919.733.5083 ext. 555.
Sincerely,
t•
,'Alex'M ks, AICP
Environmental Specialist
Attachments
cc: Dave Goodrich
John Dorney
Forrest Westall
Gerald Pottern, RJGA
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone]
7aor
ro
Customer Service
1-877-623-6748

c
North Carolina
Department of Administration
Michael F. Easley, Governor Gwynn T. Swinson, Secretary
November 18, 2003
Mr. Alex Marks
DENR, Div of Water Quality
1617 MSC
Raleigh, NC 27616-3175
Dear Mr. Marks:
Re: SCH File # 04-E-4300-0093; Environmental Assessment/Finding of No Significant Impact;
Expansion and upgrade of the Town of Highlands WWTP to 1.50 MGD and installation of
67,000 if of new lines to connect existing subdivisons.
The above referenced environmental impact information has been reviewed through the State
Clearinghouse under the provisions of the North Carolina Environmental Policy Act.
No comments were made by any state/local agencies in the course of this review. Therefore, no further
environmental review action on your part is required for the compliance with the Act.
Best regards.
rely,
s. Chrys B .::gett
Environmen • Policy Act Coordinator
cc: Region A
Mailhtg Address: Telephone: [phone] Location Address:
1301 Mail Service Center Fax [phone] West Jones Street
Raleigh, NC 27699-1301 State Courier #51-01-00 Raleigh, North Carolina
e-mail [e-mail]
An Equal Opportunity/Affirmative Action Employer

i
O
FINDING OF NO SIGNIFICANT IMPACT
ENVIRONMENTAL ASSESSEMENT FOR THE TOWN OF HIGHLANDS
WASTEWATER TREATMENT PLANT EXPANSION
October 6, 2003
Project Applicant: Town of Highlands
Project Number: DWQ # 13128
Responsible Agency: NC Department of Environment and Natural Resources (DENR)
Division of Water Quality, Water Quality Section (Division)
Pursuant to the requirements of the North Carolina Environmental Policy Act (N.C.G.S. § 113A-
1, et seq.), an environmental assessment (EA) has been prepared for the expansion and upgrade
of the existing Town of Highlands Wastewater Treatment Plant (WWTP). The proposed project
would expand the plant's existing permitted capacity of 0.50 million gallons per day (MGD) to
1.50 MGD. The project also includes installation of 67,000 linear feet of new sanitary sewer
lines to connect several existing and partially developed subdivisions. The project's service area
totals 5,100 acres, 4,000 of which are within the present town limits. The additional 1,100 acres
are within five peripheral areas under study for annexation by Highlands.
The goal of the expansion project is to protect the Lake Sequoyah watershed by connecting as
much existing development as possible to the Highlands sewer system, eliminating septic
systems and package treatment plants to the extent practicable. The proposed expansion is sized
to accommodate full build -out of currently platted lots in proposed wastewater service area and
not have excess capacity to accommodate new subdivisions. The treatment plant will continue to
discharge effluent into the Cullasaja River below the Lake Sequoyah dam.
Several alternatives to the proposed project were analyzed for the EA. The town investigated
connecting to nearby treatment plants of other jurisdictions, spray irrigation of effluent, and
taking no action. The new facility will be constructed at least one foot above 100-year flood level
by extending tanks and related equipment above grade and by filling in the vicinity of the
treatment plant.
The Cullasaja River and its headwater tributaries in sub -basin 04-04-01 of the Little Tennessee
River basin drain the majority of the WWTP's service area. Headwater tributaries of the
Chatooga River in sub -basin 03-13-01 of the Savannah River basin drain the southernmost and
easternmost portions of the Highlands service area.
Direct water quality impacts during project construction will be negligible. No streams occur in
the proposed WWTP construction area, and no modification at the effluent discharge on the
Cullusaja River will be necessary. New sewerlines crossing streams along roadsides will be
installed in accordance with US Army Corps and DWQ permits conditions. The contractor will

v.
follow an approved Erosion and Sedimentation Control Plan meeting all requirements of both
DENR and the Town of Highland's ordinances.
No protected species are likely to occur in the proposed WWTP construction area which is
previously cleared land, nor in the Cullasaja River between Sequoyah Lake Dam and Dry Falls.
No direct impact to these species from WWTP construction is likely.
The WWTP improvements will allow future expansion of the town's wastewater collection
system to unsewered areas, and subsequent retirement of older septic systems and package
treatment systems that lack advanced treatment technology. The proposed expansion has not
been sized to accommodate excess capacity for new subdivisions; however, secondary and
cumulative impacts to the environment associated with new development may result from the
WWTP's increase in capacity. Mitigation for such impacts will partially be provided through the
town's enforcement of its water supply watershed regulations, and zoning and subdivision
ordinances as well as other measures described within the EA. Additionally, the town shall
continue to enforce its policy of not providing water and sewer service to an area unless that area
is annexed into the town and subject to all applicable Highlands ordinances and policies.
Furthermore, the Town of Highlands has committed to the attached and herein incorporated
resolution of its Town Council adopted on September 17, 2003 containing the following
additional mitigation measures:
1. The Town of Highlands agrees to continue to enforce its land use ordinances, including its watershed
protection rules, soil erosion ordinance, subdivision ordinance, and ordinance regulating the draining of
impoundments, in order to protect and improve water quality both within its jurisdiction and downstream in
the Cullasaja River and Little Tennessee watershed basin.
2. The Board of Commissioners agrees to ask its Planning Board to study the feasibility of identifying
significant intermittent streams within the Cullasaja River Watershed in order to expand its Watershed
Protection rules to include buffer protection for such streams.
3. The Board of Commissioners agrees to ask its Planning Board to study the feasibility of expanding its
Watershed Protection rules to streams in the Chattooga River Watershed.
4. The Town of Highlands agrees to keep the North Carolina Wildlife Resources Commission informed
concerning the mitigative measures contained herein.
The Division of Water Quality has concluded that the proposed project will not result in
significant impacts to the environment. This decision is based upon information provided in the
EA and review by governmental agencies. This EA and Finding of No Significant Impact
(FONSI) are prerequisites for the issuance of a NPDES Discharge Permit and 401 Water Quality
Certification by the Division of Water Quality. An environmental impact statement will not be
prepared for this project. This FONSI completes the environmental review record, which is
available for inspection at the State Clearinghouse.
North Carolina Division of Water Quality
October 6, 2003

follow an approved Erosion and Sedimentation Control Plan meeting all requirements of both
DENR and the Town of Highland's ordinances.
No protected species are likely to occur in the proposed WWTP construction area which is
previously cleared land, nor in the Cullasaja River between Sequoyah Lake Dam and Dry Falls.
No direct impact to these species from WWTP construction is likely.
The WWTP improvements will allow future expansion of the town's wastewater collection
system to unsewered areas, and subsequent retirement of older septic systems and package
treatment systems that lack advanced treatment technology. The proposed expansion has not
been sized to accommodate excess capacity for new subdivisions; however, secondary and
cumulative impacts to the environment associated with new development may result from the
WWTP's increase in capacity. Mitigation for such impacts will partially be provided through the
town's enforcement of its water supply watershed regulations, and zoning and subdivision
ordinances as well as other measures described within the EA. Additionally, the town shall
continue to enforce its policy of not providing water and sewer service to an area unless that area
is annexed into the town and subject to all applicable Highlands ordinances and policies.
Furthermore, the Town of Highlands has committed to the attached and herein incorporated
resolution of its Town Council adopted on September 17, 2003 containing the following
additional mitigation measures:
I . The Town of Highlands agrees to continue to enforce its land use ordinances, including its watershed
protection rules, soil erosion ordinance, subdivision ordinance, and ordinance regulating the draining of
impoundments, in order to protect and improve water quality both within its jurisdiction and downstream in
the Cullasaja River and Little Tennessee watershed basin.
2. The Board of Commissioners agrees to ask its Planning Board to study the feasibility of identifying
significant intermittent streams within the Cullasaja River Watershed in order to expand its Watershed
Protection rules to include buffer protection for such streams.
3. The Board of Commissioners agrees to ask its Planning Board to study the feasibility of expanding its
Watershed Protection rules to streams in the Chattooga River Watershed.
4. The Town of Highlands agrees to keep the North Carolina Wildlife Resources Commission informed
concerning the mitigative measures contained herein.
The Division of Water Quality has concluded that the proposed project will not result in
significant impacts to the environment. This decision is based upon information provided in the
EA and review by governmental agencies. This EA and Finding of No Significant Impact
(FONSI) are prerequisites for the issuance of a NPDES Discharge Permit and 401 Water Quality
Certification by the Division of Water Quality. An environmental impact statement will not be
prepared for this project. This FONSI completes the environmental review record, which is
available for inspection at the State Clearinghouse.
North Carolina Division of Water Quality
October 6, 2003

i,
RESOLUTION OF THE
TOWN OF HIGHLANDS
AGREEING TO CERTAIN MITIGATIVE MEASURES
IN CONNECTION WITH THE FINDING OF NO SIGNIFICANT IMPACT
FOR THE TOWN OF HIGHLANDS WASTEWATER TREATMENT PLANT PROJECT
INCREASING THE PLANT'S CAPACITY FROM 0.5 MILLION GALLONS PER DAY
TO 1.5 MILLION GALLONS PER DAY
WHEREAS, the Board of Commissioners of the Town of Highlands has submitted this
Resolution as part of the Environmental Assessment and Finding of No Significant
Impact (FONSI) for the Highlands wastewater treatment plant (WWTP) expansion
project; and
WHEREAS, the Board of Commissioners of the Town of Highlands understands the
need for effective planning and management of growth within the Town in order to
protect and sustain valuable natural resources; and
WHEREAS, an active collaboration between Town leadership and the DENR is
important in order for the Town to demonstrate its willingness to reduce,
minimize, and mitigate unintentional impacts associated with large public
projects of this nature;
NOW THEREFORE BE IT RESOLVED BY THE BOARD OF COMMISSIONERS OF THE TOWN OF
HIGHLANDS THAT:
1. The Town of Highlands agrees to continue to enforce its land use
ordinances, including its Watershed Protection Rules, Soil Erosion
Ordinance, Subdivision Ordinance, and Ordinance Regulating the Draining of
Impoundments, in order to protect and improve Water Quality both within its
jurisdiction and downstream in the Cullasaja River and Little Tennessee
Watershed Basin.
2. The Board of Commissioners agrees to ask its Planning Board to study the
feasibility of identifying significant intermittent streams within the Cullasaja
River Watershed in order to expand its Watershed Protection rules to include
buffer protection for such streams.
3. The Board of Commissioners agrees to ask its Planning Board to study the
feasibility of expanding its Watershed Protection rules to streams in the
Chattooga River Watershed.
4. The Town of Highlands agrees to keep the North Carolina Wildlife Resources
Commission informed concerning the mitigative measures contained herein.
This resolution is adopted this 17th day of September, 2003.
(TOWN' SEAL)
ATTEST.
Richard Betz, Tt i Clerk
The Town .of 1Hi.ghlands
Allen L. Trott, Mayor

Re: application for expansion
•
Subject: Re: application for expansion
Date: Thu, 06 Nov 2003 16:37:25 -0500
From: [e-mail]
To: Susan A Wilson <[e-mail]>
Susan,
The Form 2A requires effluent testing for the priority pollutants in the
Supplemental Application Information, Part D. The application
instructions require, at a minimum, three pollutant scans with seasonal
variation. It also requires Whole Effluent Toxicity (WET) data
monitored at a specific frequency. These requirements came into effect
in August of 1999. EPA worked out a schedule with NCDWQ for expiring
permits and what will be required for priority pollutant analyses and
2nd species WET tests. This information is included in an e-mail
correspondence between Mike Myers and Marshall Hyatt dated July 11,
2002. Since the permittee should have technically submitted the three
effluent data sets for their application dated 5/02 and most likely did
not (as was the norm) and since they are almost one year into their
permit cycle, they should have or should be near completing one effluent
testing since it is a standard condition in most of the NC municipal
permits.
The application for expansion should not be considered complete until
they have three complete pollutant scans (seasonal variation may not be
an option for the timeframe).
Please call me or e-mail me if you would like to discuss this further.
Thanks,
Madolyn
1 of 1 11/6/03 4:42 PM

DIVISION OF WATER QUALITY
September 28, 2003
To: Alex Marks
Local Government Assistance Unit
From: Susan A. Wilson, Environmental Enginee
NPDES Unit
Subject: Town of Highlands WWTP, Environmental Assessment
NPDES No. NC0021407
Macon County
I have reviewed portions of the Environmental Assessment (EA) for the proposed
increase in wastewater capacity for the Town of Highlands. The proposed project
includes the expansion of the wastewater treatment plant from 0.5 MGD to 1.5 MGD to
meet future growth needs around the Highlands area. The NPDES Unit submitted
additional comments regarding the EA on March 25, 2003.
The consulting firm stated that the Preliminary Engineering Report (PER) addressed
many of the concerns brought forward in the March memo from the NPDES Unit. The
NPDES Unit received the PER on May 21, 2003. The PER outlined the flow justification
(derived in three different ways) and several alternatives. The NPDES Unit submitted
an additional information request to the consultant (WK Dickson) on July 2, 2003
requesting clarification and further information on land -based disposal and cost
estimations. Information regarding this request was received on August 22 and
September 19, 2003.
The NPDES Unit believes that the Town of Highlands has now adequately addressed the
Engineering Alternatives Analysis. Expansion of the wastewater treatment system and
discharge to surface waters is deemed the most environmentally sound alternative from
the reasonably cost effective options. The discharge is not predicted to result in
contravention of applicable water quality standards or loss of the river's designated
uses.
The NPDES Unit has no further comments on the Highlands EA.
cc: Central Files
NPDES Files
ARO/ Water Quality Section

SEP-10-2003 12:34PM FROMIK DICKSON & CO, INC
7043340078
T-538 P.001
F693
FACSIMILE
/WK
DICKSON
Engrnrdr . Planners . 5urveyur7
Lundscup:Arhixcts
616 Colonnade Drive
Charlotte, North Carolina 28205 704.334-5348
SLtSc 1 %1ikc i
1e)c Mafk,
TO:
SO6, at) t,(s.eel
AFFII IATION:
rJcD?W(Z. fJPOES t4eitt
NCOE4-
RSA
DATE: 9-
FAX NO:
jOB NO.: 2o`1l L.l I .cc
RE:
MESSAGE:
14
9/5/733--C ll9
/1/7`s-5-6.37
cazg /CZC' -2s-N-
FROM: iiK, a bo7r+.E1
W.K. Dickson & Co., Inc.
Telephone: [phone]
FAX [phone]
Number of pages including cover sheet:

SFP-19-2003 12:34PMJ FROM-VK DICKSON & CO, INC 7043340078 T-538 P.002 F-693
S&ME
Serivolrer 19, 700:1
W.K. Dickson & Co., Inc.
616 ColonadT)r,
Charlotte, North Carolina 28205
Attn: Mr. Mike Osborne; PB.
Reference:
meaLLAms WWrP SOIL SCIENTIST EVALUATION
Town of Highlands, North Carolina
WKTl ti9.041710_ 0 ,
.De& Mr. Osburrst:
S&.1vlh', Inc. (S&MP.) has reviewed thy; info miation frovidedlny W.K. Dickson regarding the Town
of I•Iighlands Wastewater Treatment Plant Expansion and perforated additional literature review.
Based upon any profcssiotnal exp iience as a N.C. Licensed Soil Seicutist, a review of pioject-
spccihc cluutuncnts a11d the County Soil Survey, tlic typical range of splay irrigation rates for western
North. Carolina soils range from 0.5 to 1.75 inches per week By using an assumed rate of 1.5 inches
per' week? the required wetted acreage neezled for a spray field is approximately 172 acres, This total
doe§Jipt include properly, surface water, or ether required buffer acreage. The presence of
i-.dn4yville (coarse-loarny, mired, active, mcsic Typic Dystrudepts ), Plott (tine -loamy, isotic,
music flurnii DysLrudcpts), and Cullasaja (loainiy-akcletaI, isotic, mesic !filmic Dystrudepts)
series soils in the area would potentially necessitate the need for additional land due to these
soils tendency for having springs, scggs and surficiil Ix-, uternps the require buffering.
Sincerely,
S&ME, Inc.
Mathew J{ O'Brien, I..S,S.
TTdtrrnzl R cr.ource Deparhnent Tvirin i r
5&MV, Inc.
3718 Old 8olilesravne ROc,ri
Cxr:Fn;horo, hlorlh Corollna 2741 Q
•
ez,zit4 Ct
13?�} 234.7180
i3361 25E.5953 ic,:<
1800i G49-2985

�► WK
111 DICKSON
Engineers • Planners • Surveyors
Landscape Architects
August 20, 2003
Ms. Susan Wilson, PE
NCDENR - NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Town of Highlands
WWTP Expansion Environmental Assessment
vVKD #20412.10.CL
Dear Ms. Wilson:
AUG 2 2 2003
As requested by your letter (Attached) of July 2, 2003, we have further reviewed
land disposal alternatives and cost estimations for the referenced project. Provided
below is additional information per your request.
1. Land Based Disposal: A third soil scientist, independent of the two identified
in the PER, was consulted regarding soil loading rates. For the Highlands area, it
was confirmed that an application rate of 1.5 inches per week is suitable for best
case loading rates. This application rate is on the upper end of the range specified
(from 0.5 inches per week to 1.75 inches per week) in the previously submitted
Preliminary Engineering Report (PER). Since the Highlands WWTP already exists,
best -case loading rates for the documented soil types may be used per your letter.
Calculations for the amount of land area needed for spray or drip irrigation are
shown as follows:
A. Figure Gallons/Acre-Inch: 43,560 SF/Acre x 7.481 Gallons/CF x 1 FT/12 Inches
= 27,156 Gallons/Acre-Inch
B. Figure Acre-Inches/Week: 1 MGD x 7 Days/Week / 27,156 Gallons/Acre-Inch
= 258 Acre-Inches/Week
C. Figure Area: 257.8 Acre-Inches/Week/ 1.5 Inches/Week = 172 Acres
It should be noted that the required buffers are not included in the 172 acres.
Highlands does not currently own or have access to 172 acres of land. Therefore,
land purchase options were investigated. Attached is a letter received from a local
Real Estate Agent, which identifies an expected land cost of $50,000 per acre. For
172 acres, the total cost will exceed $8.5 million. The Agent also notes the distance
L\pro \Highlands\Swilson082003
616 Colonnade Drive
Charlotte, North Carolina 28205
704.334.5348
Fax [phone]
www.wkdickson.com
Other Offices:
Asheville, NC
Atlanta, GA
Boca Raton, FL
Columbia, SC
Hickory, NC
Raleigh, NC
Wilmington, NC

Ms. Susan Wilson, PE
August 20, 2003
Page 2
that the wastewater would have to be pumped, the difficult terrain and the
difficulties in accessing the land. Construction costs of a 7-mile, 12-inch force main
alone ($40 per foot, not including rock excavation, a pumping station or other
appurtenances) are $1.5 million. It should also be noted that the average annual
precipitation in Highlands is approximately 84-inches, which is considered the
highest in North Carolina. In comparison, the average annual precipitation in
Charlotte is 42-inches and in Raleigh is 45-inches. Since spray or drip irrigation of
treatment plant effluent cannot be achieved during and immediately after rain and/or
snow events, stream discharging must be used in unison as already stated in the
submitted PER. Finally, as previously indicated in the PER, the Highlands area Tacks
suitable soils and terrain for spray and drip irrigation wastewater treatment and
disposal methods.
In summary, the spray and drip irrigation wastewater treatment and disposal
methods are likely to exceed $10 million dollars in capital costs. Compared to the
capital costs of expanding the Cullasaja WWTP, approximately $5 million, the land -
based disposal option is cost prohibitive. Also, these methods do not make good
engineering sense given the high precipitation amounts, the difficult terrain and the
lack of suitable soils.
2. Cost Estimations: Our cost estimations are based on previous projects and best
professional judgement. We are comfortable with our estimations.
Please feel free to call me if you have any questions.
Sincerely,
W.K. Dickson & Co., Inc.
ged,fale
Michael Osborne, PE
Project Manager
Enclosure
cc: Mr. Richard Betz — Town of Highlands
Mr. Alex Marks — NCDENR
Mr. Gerald Pottern — Robert J. Goldstein & Associates
L\proj\H ighlands\Swi Ison082003

8-20-203 1:59PM FRO.1
P. 2
August 20, 2003
Mayor Buck Trott
Town of Highlands
Highlands, NC 28741
Dear Mayor Trott:
JOHN CLEAVELAND REALTY
Thank you for your inquiry regarding the acquisition of land in the Highlands Township. I havc Looked at
all the available tracts of land whether or not they are on the market. My research shows that within a 3
mile radius of the Town of Highlands there arc no parcels of land which would provide a 170 acre area
with a gentle terrain. As you know the high percentage of US Forest Service land in the immediate area
makes it difficult to find any large parcels and even if it were available you could expect to pay S50,000
per acre or more.
The only alternative I could find was a parcel of land with 120 acres of pasture and an 85 acre piece
adjoining it. The combined price to acquire this property would be S8,500,000.000, but it is seven miles
from the center of Town. The logistics of gaining right of ways and access to this parcel would make it a
very difficult option, but it is the only parcel that would seem to meet your guidelines.
Please let me know if you would like additional information on this tract or if I can assist you in any other
way. I am sorry I couldn't find any options that would provide any better alternatives.
Sincerely,
'_vfark Meadows

State of North Carolina
Department of Environ]
and Natural Resources
Division of Water Quality
Michael F. Easley, Governo
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
&tECEJVED
JUL 072003
--- ----j
W.K. DICKSON CO. !
I
Mr. Mike Osborne, P.E.
W.K. Dickson & Co., Inc.
616 Colonnade Dr.
Charlotte, North Carolina 28205
Dear Mr. Osborne:
July 2, 2003
Subject:
CDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Additional Information Request
Highlands WWTP Environmental
Assessment (19 February 2003)
PER (Revised 16 May 2003)
NPDES No. NC0021407
Macon County
The Division of Water Quality has reviewed the Town of Highlands Preliminary Engineering
Report (PER), Revised May 16, 2003. This document was referenced in the Town's Environmental
Assessment (EA) for the expansion of the plant to 1.5 MGD. Although many questions were clarified
with the PER, further questions must be addressed prior to agreeing with submittal of comments for a
Finding of No Significant Impact (FONSI).
1. Land -Based Disposal (spray or drip irrigation). Please follow the guidelines specified in the NPDES
Unit's Engineering Alternatives Analysis (EAA) Guidance document, attached, for determining soils
loading rates. For existing facilities, best -case loading rates for the documented soil types may be
used. Calculations should be shown to document the amount of land needed for spray or drip
irrigation. Land costs should be documented (this may be acquired from a Real Estate agent).
For spray irrigation, please document 1 MGD wastewater with storage (this assumes no increase in
a discharge permit from the existing 0.5 MGD permitted flow).
For drip irrigation - the same may be assumed. Land requirements will be somewhat less based
on the smaller buffer requirement.
Spray and drip irrigation do not have to meet the same treatment requirements as a discharging
system (they usually employ only stabilization and storage along with disinfection, therefore,
expansion of the wastewater treatment plant will likely not be necessary with these options).
For re -use of wastewater, stringent treatment is required and the wastewater treatment plant
would have to be expanded to comply with re -use rules.
2. Cost Estimations. The cost estimations for the various alternatives are well documented.
However, in instances where costs are estimated based on best professional judgement or previous
projects - please be certain that these can be fully substantiated, if necessary.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1 61 7 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 1 0% POST -CONSUMER PAPER
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

Mr. Osborne
Page2of2
Should you have further questions regarding the items above, please contact Susan A. Wilson,
P.E. at (919) 733 - 5083, ext. 510.
Sincerely,
'
'Susan A. Wilson, P.E.
NPDES Unit
cc: Central Files
Alex Marks, Local Government Assistance Unit, Planning Branch
Asheville Regional Office, Water Quality Section
Mr. Gerald Pottern
Robert J. Goldstein and Associates. Inc.
8480 Garvey Dr.
Raleigh, NC 27616
Mr. Richard Betz, Town Administrator
Town of Highlands
P.O. Box 460
Highlands, North Carolina 28741
NPDES file

Ali,-21-2003 09:23AM FROM-ViK DICKSON & CO, INC
7043340078
T-348 P.001 061
FACSIMILE
616 Colonnade Drive
Ci oicKso
£nQin[cri • Planners • 5urveyarz
Low:y.417eAnhitrtts
Charlotte, North Carolina 28205 704-334-5348
TO: c1'o tj11 sg r-,
AFFILIATION: 1.1 C.Oe
DATE: -2J -0 3
FAX NO:
JOB NO.: a! ,1!•CC,
RE:
MESSAGE:
FROM: Mtls_e O born_
W.K. Dickson & Co., Inc.
Telephone: [phone]
FAX [phone]
Number of pages including cover sheet:
( %)

AUG-21-2003 09:23AM FROM-WK DICKSON & CO, INC 7043340078 T-348 P.002
061
�I► W K
NW DICKSON
,rpulCrrc• Plwrrt2rS • Nr•'rynrt
andsram:,tr..hir, Ts
August 2D, 2003
Ms, Susan Wilson, PE
NCDENR - NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Town of Highlands
WWTP Expansion Environmental Assessment
WKD #20412.10.CL
Dear Ms. Wilson:
As requested by your letter (Attached) of July 2, 2003, we have further reviewed
land disposal alternatives and cost estimations for the referenced project. Provided
below is additional information per your request.
1. Land Based Disposal: A third soil scientist, independent of the two identified
in the PER, was consulted regarding soil loading rates. For the Highlands area, it
was confirmed that an application rate of 1.5 inches per week is suitable for best
case loading rates. This application rate is on the upper end of the range specified
(from 0.5 inches per week to 1.75 inches per week) in the previously submitted
Preliminary Engineering Report (PER). Since the Highlands WWTP already exists,
best -case loading rates for the documented soil types may be used per your letter.
Calculations for the amount of land area needed for spray or drip irrigation are
shown as follows:
A. Figure Gallons/Acre-Inch: 43,560 SF/Acre x 7.481 Gallons/CF x 1 F7/12 Inches
= 27,156 Gallons/Acre-Inch
B. Figure Acre-Inches/Week: 1 MGD x 7 Days/Week / 27,156 Gallons/Acre-Inch
= 258 Acre-Inches/Week
C. Figure Area: 257.8 Acre-Inches/Week / 1.5 Inches/Week = 172 Acres
It should be noted that the required buffers are not included in the 172 acres.
Highlands does not currently own or have access to 172 acres of land. Therefore,
land purchase options were investigated. Attached is a letter received from a local
Real Estate Agent, which identifies an expected land cost of $50,000 per acre_ For
172 acres, the total cost will exceed $8.5 million. The Agent also notes the distance
L1pn.)j\Hlghland5\Swilson082003
616 C'.I, r,VL,CIe I,)r it e.
C'li.,rhtm-.'North caralin.e 'Y 2r)5
704. ; 4.;;4,z,
1'.le 7114..t 3x.(4)71i
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Ali:Irin 1, GA
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1 i!righ, NC
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AUG-21-2003 09:23AM FROM-i9K DICKSON & CO, INC 7043340078 T-348 P.003 F-061
Ms. Susan Wilson, PE
August 20, 2003
Page 2
that the wastewater would have to be pumped, the difficult terrain and the
difficulties in accessing the land. Construction costs of a 7-mile, 12-inch force main
alone ($40 per foot, not including rock excavation, a pumping station or other
appurtenances) are $1.5 million_ It should also be noted that the average annual
precipitation in Highlands is approximately 84-inches, which is considered the
highest in North Carolina. In comparison, the average annual precipitation in
Charlotte is 42-inches and in Raleigh is 45-inches. Since spray or drip irrigation of
treatment plant effluent cannot be achieved during and immediately after rain and/or
snow events, stream discharging must be used in unison as already stated in the
submitted PER. Finally, as previously indicated in the:PER, the Highlands area lacks
suitable soils and terrain for spray and drip irrigation wastewater treatment and
disposal methods.
In siimmary, the spray and drip irrigation wastewater treatment and disposal
methods are likely to exceed $10 million dollars in capital costs. Compared to the
capital costs of expanding the Cullasaja WWTP, approximately $5 million, the land -
based disposal option is cost prohibitive. Also, these methods do not make good
engineering sense given the high precipitation arnounts, the difficult terrain and the
lack of suitable soils.
2. Cost Estimations: Our cost estimations are based on previous projects and best
professional judgement. We are comfortable with our estimations.
Please feel free to call me if you have any questions.
Sincerely,
W.K. Dickson & Co., Inc.
tWaLt0,4_._
Michael Osborne, PE
Project Manager
Enclosure
27914 R
�''ry�Ar�L QS g-z, —03
cc: Mr. Richard Betz - Town of Highlands
Mr. Alex Marks - NCDENR
Mr. Gerald Pottern - Robert J. Goldstein & Associates
L`pro1H igh lands\Swi kon0i32003
P

AUG-21-2003 00:24AM FROM-4IK DICKSON & CO, INC
7043340078
T-348 P.0O4 F-061
•
•+ l
•
:�%,►PP r
r4►F /
August 20, 2003
Mayor Brick Trot
Tom of Highlands
Highlands, NC 28741
Dear Mayor Trott:
JOHN CLEAVELAND REALTY
Thank you for your inquiry regarding the acquisition of land in the Highlands Township. I have looked at
all the avaiJabia tracts of land whether or nut they are on the market. My research shows that within a 3
mile radius of the Town of I-Ughlands there are no parcels of land which would provide a 170 acre area
with a gentle terrain, AS you iCllow the high percentage of US Forest Service land in the immediate area
makes it difficult to find any large parcels and even: if it were available you could expect to pay S50,000
per acre or more.
The only alternative I could find was a parcel of land with 120 acres of pasture and an 85 acre pi.oc
adjoining it. The combined price to acquire This property would be S8,500.000.000, bits it is men miles
From the center of Town. The logistics of gaining tight of ways and access to this parcel would make it a
very difficult option, but it is the only parcel that would Scent to meet your guidelines.
Plea let me know if you would lik additional information on this tract or if I can assist you in any ether
way. I am sorry I couldn't find any options that would provide any }otter alternatives.
SincIy,
• -v ark Meadows

AUG-21-2003 00:24AM FROM-WK DICKSON & CO, INC 7043340078 T-348 P.005 F-
81
State of North Carolina
Department of Environ
and Natural Resources
Division of Water Quality
[Michael F. Easley, Governo
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
aittECEIVED
JUL 07 2003 I
�
W.K. DICKSON CO. I
July 2, 2003
Mr. Mike Osborne, P.E.
W_It Dickson & Co.. Inc.
616 Colonnade Dr_
C: irlone, North Carolina a 28205
Subject:
Dear Mr. Osborne:
ATA
CDENR
NORM CAROLINA DEPARTMENT OF
ENVIRONMENT ANT? NATURAL RESOL.IRcES
Additional Information Request ti
Highlands WWTP Environmental �.
Assessment (19 February 2003)
PER (Revised 16 May 2003)
NPDES No. NC0021.407
Macon County
The Division of Water Quality has reviewed the Town of Highlands Preliminary Engineering
Report (PER). Revised May 16. 2003. This document was referenced in the Town's Environmental
Assessment (EA) for the expansion of the plant to 1.5 MGD, Although many questions were clarified
with the PER, further questions must be addressed prior to agreeing with submittal of comments for a
Finding of No Significant Impact (FQNSI).
1. Land -Based Disposal (spray or drip irrigation). Please follow the guidelines specified in the NPDES
Unit's Engineering Alternatives Analysis (EAA) Guidance document, attached, for determining soils
loading rates. For existing facilities, best -case loading rates for the documented soil types may be
used_ Calculations should be shown to document the amount of land needed for spray or drip
irrigation. Land costs should be documented (this may be acquireci from a Real Estate agent).
For spray irrigation, please document 1 MGD wastewater with storage (this assur, no increase in
a discharge permit from the existing 0.5 MGD permitted flow).
For drip irrigation — the same may be assumed. Land requirements will be somewhat less based
on the smaller buffer requirement.
Spray and drip irri :ltinn do not have to meet the same treatment requirements as a discharging
system (they usually employ only stabilization and storage along with disinfection. therefore.
expansion of the wastewater treatment plant will likely not he necessary with these options).
For re -use of wastewater, stringent treatment is required and the wastewater treatment plant
would have to be expanded to comply with re -use rules.
2. Cost Estimations. The cost estimations for the various alternatives are well documented.
However. in instances where costs are estimated based on best professional judgement or previous
projects — please be certain that these can be fully substantiated, 11' necessary.
1617 MAIL SER\'ICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPhONE[phone]]FAX [phone]
AN. EOu4L OrrORT,JNITr Arrip.M.TiVC ACTION EMPLOYCR - S0 V. Recyc,.co, 1 0 , POST-CONsUMCR Nos
VI;tT u5 ON MC w6a AT http• J f h2o,enr.state.nc,u5/ NPDES

AUG-21-2003 09:25AM FROM-WK DICKSON & CO, INC
Mr, Osbomc
Paae 2 of 2
7043340078 T-348 P.006 F-061
Should you have further questions regarding the items above. please contact Susan A. Wilson,
P.E. at (919) 733 - S083, ext. 510.
Sincerely.
"'Susan A Wilson. P.E.
NPDES Unit
cc: Central Filev
Alex Marks, Local Government Assistance Unit, Planning Branch
Asheville Regional Office, Water Quality Section
Mr. Gerald Pottcrn
Robert J. Goldstein and Associates. Inc.
8480 Garvey Dr.
Raleigh, NC 2761.6
Mr. Richard Betz, Town Administrator
Town of Highlands
P.O. Box 460
Highlands, North Carolina 28741
NPDES file