NC0087602_Return_20020416

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit:
NC0087602
Whittier WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
i
.Return
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
April 16, 2002
This document is pririted on reuse paper - ignore a rty
coiiterit on the resrerse side

4
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
April 16, 2002
Mr. George Rogers
P.O. Box 368
Whittier, North Carolina 27511
Subject: Engineering Alternative Analysis Return
Whittier Sanitary District
NPDES Permit NC0087602
Dear Mr. Rogers:
The Engineering Alternatives Analysis submitted for the proposed Whittier Sanitary District Wastewater
Treatment Plant is being returned by the Division because it lacks required components. The following is
a list of information and questions that were raised during the EAA review:
• The Engineering Alternatives Analysis report states that the two existing treatment systems permitted
under NC0000264 and NC0074250 will be eliminated with the construction of one centralized
WWTP. Documentation is needed from the owners of these wastewater treatment systems
confirming the intention to connect to the proposed WWTP and close the existing systems.
• All new facilities are required to provide a soil analysis, characterization and loading
recommendations developed by a licensed soil scientist. The soil was not identified and the
assumption of the application rate of 0.05 GPD/SF was not explained.
• The projected population growth for 2023 was based on a 3% growth rate. The actual growth rate
based on the Census is 1.1 %. Why is the 3.3 % an appropriate growth rate and the how are the
expected flows projections attainable?
• The EAA report mentions that several septic systems are failing or have the possibility of failing in
the future. It also mentions that funds from the North Carolina Rural Economic Development have
been obtained for a project, but there is no information or description of the project. Is this project
providing funds to repair the septic systems?
• The report should contain a scaled map showing the necessary improvements and new facilities
required for the connection to the Town of Bryson City. Has the Whittier Sanitary District
approached the Town of Bryson City regarding regionalization and expected user fees? Provide
documentation from the Town of Bryson City agreeing to the possibility or the denial of this
alternative.
• A description and diagram of the proposed treatment system including disinfection were not included.
• On the cost estimate for the drip and spray irrigation systems a description is needed of the
components under drip and spray irrigation systems and the itemized cost.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Whittier Sanitary District
Permit No. NC0087602
Page 2
If you wish to resubmit the application this additional information must be included in the
application package. If you have any questions, please call me at [phone], extension 595.
Sincerely,
7/7,;(,, P4d/L--.
David A. Goodrich
NPDES Unit Supervisor
cc: NPDES Unit.
Central Files
Asheville Regional Office
Randal Hintz, P.E. — McGill Associates
P.O. Box 2259
Asheville, NC 28802

wA rF Michael F. Easley, Governor
William G. Ross Jr., Secretary
r _ ` y North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
September 19, 2001
George Rogers, Chairman
Whittier Sanitary District
P.O. Box 850
Bryson City, North Carolina 28713
Subject: Speculative Limits Request
Whittier Sanitary District
Jackson County
Dear Mr. Rogers:
This letter is in response to your request for speculative effluent limits for a proposed discharge
to the Tuckasegee River at the location of the existing discharge for the Jackson County Industrial
Wastewater Treatment Facility. The Whittier Sanitary District is proposing to eliminate the waste
treatment plants under permits NC0000264 and NCO074250 and build a new treatment plant with a
capacity of 0.250 MGD. The permitted capacity for each existing plant is 0.005 MGD. A flow
justification for the 0.250 MGD shall be submitted with the Engineering Alternatives Analysis (EAA)
when applying for the permit (guidance is attached).
The speculative limits were developed based on our understanding of the proposal in addition to
our understanding of present environmental conditions at the proposed discharge location. The Division
of Water Quality (Division) can not guarantee that an NPDES permit will be issued at the proposed
location. Final decisions can only be made after the Division receives and evaluates a formal permit
application for the proposed discharge and after the public has an opportunity to comment on the project.
Speculative Effluent Limits
The low flow data used for the development of the limits was the following:
Average flow
940 cfs
Summer 7Q 10 '-
212.9 cfs
Winter 7Q1O
254.7 cfs
Annual 30Q2
380.8 cfs
Based on the available information, tentative limits for the proposed discharge to the Tuckasegee
River near Whittier at a flow of 0.25 MGD are attached.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET CO www.enr.state.nc.us

The explanation for the effluent monitoring requirements follows:
BOD5 and Total Suspended Solids (TSS) and Fecal Coliform - The BOD5 and TSS limits are
standard for secondary treatment of municipal wastewater.
Fecal Coliform, pH - The limits for fecal coliform bacteria and pH represent water quality
standards for Class B waters (T15A NCAC 2B .0219).
Total Residual Chlorine (TRC) — A limit is required for all new treatment plants using chlorine
for effluent disinfection.
NHS as N, Total Nitrogen and Total Phosphorus - Monitoring for these parameters is required to
evaluate and protect water quality in the receiving stream.
Please be advised that the limits and monitoring frequencies on the attached pages were based on
the information presented in the speculative limits request. In addition, it was assumed that the proposed
WWTP will be a Class II facility. This assumption was used to develop an estimate of the monitoring
frequencies that would be required for each parameter. A complete evaluation of these limits and
monitoring frequencies in addition to monitoring requirements for metals and other toxicants will be
addressed upon receipt of a formal NPDES permit application.
By copy of this letter the Division is communicating to the US Fish and Wildlife Service and the
North Carolina Wildlife Resources Commission the intent of Whittier Sanitary District to expand the
discharge to the Tuckasegee River.
Should you have any questions or if you need any additional information, please feel free to
contact Teresa Rodriguez [phone], extension 595.
Enclosure
cc: Central Files
Asheville Regional Office
NPDES Unit
USFWS, Tom Augspurger
NCWRC, Owen Anderson
Sincerely,
David A Goodrich
NPDES Unit Supervisor
— P.O. Box 33726
Raleigh, North Carolina 27636-3726
— 20830 Great Smokey Mountains Expressway
Waynesville, North Carolina 28786

A. (1) SPECULATIVE LIMITATIONS AND MONITORING REQUIREMENTS
The following table presents speculative limits and associated monitoring requirements for the proposed
WWTP for Whittier Sanitary District. Preparation of these limits does not guarantee that the Division
will issue a NPDES permit. In addition, it does not guarantee that these limits will remain unchanged if a
permit is issued to Whittier Sanitary District. A complete evaluation of these limits and monitoring
frequencies in addition to monitoring requirements for metals and other toxicants will be addressed upon
receipt of a formal NPDES permit application.
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by
the Permittee as specified below:
EFFLUENT
CHARACTERISTICS _
_ ;
_LIMITS
= MONITORING
_
REQUIREMENTS
Monthly
_ _ _A1 er"age -
Weekly :
Average :
=' Daily
_Maximum :.._Frequency...
.Saneple
_ Type.
Sample
.Location' _
-_Measurement
_
Flow
0.250 MGD
Continuous
Recording
I or E
BOD, 5-day, 20°C 2
30.0 mg/1
45.0 mg/1
Weekly
Composite
.\"`,0\ .'-
Total Suspended Residue2
p
30.0 mg/1
45.0 mg/1
Weekly
Composite
r , `'
,..., • 4 ,, < `.,
pH3
Weekly
i rice r"'.,`,�'
,.� -,s \\
Fecal Coliform (geometric
mean)
200/100 ml
400/100 ml
Weekly
Grab \\ `\
f.- _ \
\\, \,\`, W+ `,�\
, \ \ \ \ ,
Total Residual Chlorine4
28 1
µg /
Monthl. ••--� \
..� Y:
• ` 't ab `\ `\
, f
E
` \� \\-= E
,
NH3 as N
<\` \
?r/MQkitlx \ ��\��
\
ih o ite`l
, 4� p 1
E
Total Nitrogen (NO2+NO3+TKN)
_ \\
\` \ \2./yew,'\
(pfliposite
E
Total Phosphorus
c"\" ,
> ,----• r \% ‘, ;\\\ 4Jyear \;,,.=
S11 posite
E
Notes:
\•
\ t\\ \ \\
1 • Sample locations E - Effluent, I ; f ue l;, U - Upstre�an ;,D" — Downstream. Instream monitoring
requirements to be detern*ed, uOn appiicatjb i.receipt:
2. The monthly average effl\uebt B905\ancl\XbtaI Suspended Residue concentrations shall not exceed 85% of
the respective influent,value,(0% removal required).
3. The pH-sk al1,n' t be,:le s--tti�- 6 0 standard units nor greater than 9.0 standard units.
4. Monitori'ngyequirement applies only if chlorine is used for disinfection.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Whittier Sanitary District
Speculative Limits Notes
NPDES permit num: NC0000264 and NC0074250
Owner: Mr. George Rogers
Whittier Sanitary District
P.O. Box 850
Bryson City
Jackson County
Requested by: McGill & Asscoiates
P.O. Box 2259
Asheville, NC 28802
Summary: The Whittier Sanitary District requested speculative limits for a proposed discharge. This new
WWTP would replace the two wastewater treatment systems permitted under NC0000264 and NC0074250.
Actual flow: 0.005 MGD each (total combined flow is 0.010 MGD)
Proposed Flow: 0.250 MGD
Stream Information:
River Basin:
Little Tennessee
Average flow:
940 cfs .
Stream:
Tuckasegge River
Summer 7Q10:
212.9 cfs
Sub -basin:
04-04-02
Winter 7Q10:
254.7 cfs
Classification:
B
Annual 30Q2:
380.8 cfs
Basin Plan: The Tuckasegee River in Jackson County is rated as excellent for taxa richness values and
bioclassifications.
Proposed limits: Limits are effluent limited. A Level B model was developed, secondary limits will
protect for summer and winter conditions.
Parameter
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
0.25 MGD
BODS
30 mg/1
45mg/1
TSS
30 mg/1
45mg/1
pH
6-9
TRC
28 Ag/I
Fecal Coliform
200 /100 ml
400/100 ml
NH3 as N
Monitor only
Total Phosphorus
Total Nitrogen
Regional Office correspondence: ARO recommends coliform limits. The ARO performed an inspection on
March 2001 at the Jackson County Development Corp. facility (NC0000264). The inspection report
indicates operational and compliance problems.

SUMMER
Discharger : WITTIER
Receiving Stream : TUSCKEEGEE
MODEL RESULTS
The End D.O. is 7.13 mg/l.
The End CBOD is 2.06 mg/l.
The End NBOD is 1.14 mg/1.
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd)
Segment 1 7.04 0.00 1
Reach 1 45.00 90.00 0.00 0.25000

*** MODEL SUMMARY DATA ***
Discharger
Receiving Stream .
Summer 7Q10
Design Temperature:
WITTIER
TUSCKEEGEE
212.9
28.0
LENGTH SLOPE VELOCITY
mile ft/mi fps
Subbasin
Stream Class: B
Winter 7Q10 : 254.0
DEPTH Kd Kd Ka Ka KN
ft design @20° design @20° design
Segment 1
Reach 1
0.40
6.40
1.103
3.64
0.37
0.25
7.39
6.21
0.56
Flow
cfs
Segment 1 Reach 1
Waste
Headwaters
Tributary
* Runoff
0.388
219.000
0.000
0.000
CBOD NBOD D.O.
mg/1 mg/1 mg/1
45.000 90.000 0.000
2.000 1.000 7.050
2.000 1.000 7.050
2.000 1.000 7.050
* Runoff flow is in cfs/mile

I Seg # I Reach # ( Seg Mi I D.O. CBOD I NBOD I Flow I
1 1 0.00 7.04 2.08 1.16 219.39
1 1 0.04 7.05 2.07 1.16 219.39
1 1 0.08 7.06 2.07 1.15 219.39
1 1 0.12 7.07 2.07 1.15 219.39
1 1 0.16 7.08 2.07 1.15 219.39
1 1 0.20 7.09 2.07 1.15 219.39
1 1 0.24 7.09 2.07 1.15 219.39
1 1 0.28 7.10 2.06 1.15 219.39
1 1 0.32 7.11 2.06 1.15 219.39
1 1 0.36 7.12 2.06 1.14 219.39
1 1 0.40 7.13 2.06 1.14 219.39
Seg # I Reach # I Seg Mi 1 D.O. I CBOD I NBOD I Flow I

IWC Calculations
Owner Whittier Sanitary District
Facility Proposed WWTP
Prepared By: Teresa Rodriguez, NPDES Unit
Enter Design Flow (MGD):
Enter s7Q10(cfs):
Enter w7Q10 (cfs):
0.25
212.9
254.7
Residual Chlorine
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (1
IWC (%)
Allowable Conc. (ug/I)
Fecal Limit
(If DF >331; Monitor)
(If DF <331; Limit)
Dilution Factor (DF)
NPDES Servor/Current Versions/IWC
212.9
0.25
0.3875
17.0
0
0.18
9357
Ammonia (NH3 as N)
(summer)
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL
IWC (%)
Allowable Conc. (mg/I)
Ammonia (NH3 as N)
(winter)
7Q10 (CFS)
Not Required DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
550.42 UPS BACKGROUND LEVEL
IWC (%)
Allowable Conc. (mg/I)
212.9
0.25
0.3875
1.0
0.22
0.18
429.5
254.7
0.25
0.3875
1.8
0.22
0.15
1040.3
11/14/01

LEVEL B MODEL INFORMATION
Facility Information
Facility Name
Whittier Sanitary District
NPDES No.
Type of wastewater
Domestic/Industrial
Facility status
New
Receiving stream
Tuckasegee (Little Tennessee River basin)
Stream classification
B
Subbasin
40402
County
Jackson
Regional Office
Asheville
Topo Quad
F5NE (Whittier)
Flow Informaiton
USGS #
351060200
Date of flow estimate
Drainage Area (m12)
376
Summer7Q10 (cfs)
212.9
Winter7Q10 (cfs)
254.7
Average flow (cfs)
940
30Q2 (cfs)
380.8
!WC at discharge (%)
0.18
Cummulative IWC (%)
Model Input Information
Reach
1
Length of reach (mi)
0.4
Incremental length
0.04
Waste characteristics
Flow (MGD)
0.25
CBOD (mg/0
60
NBOD (mg/I)
90
DO (mg/0
Runoff charactericstics
s7Q10 (cfs/mi)
0
QA (cfs/mi)
0
CBOD (mg/!)
NBOD (mg/I)
DO (mg/l)
Tributary characteristics
s7Q 10 (cfs/mi)
QA (cfs/mi)
CBOD (mg/I)
NBOD (mg/I)
DO (mg/I)
Slope (ft/mi)
6.4
File name: Whittier

LEVEL B MODEL INFORMATION
/).
Facility Information v
Facility Name ,
Whittier Sanitary District
NPDES No.
Type of wastewater
Domestic/Industrial
Facility status
New
Receiving stream
Tuckasegee (Little Tennessee River basin)
Stream classification
B — 7 1�
Subbasin0402----""
County
Jackson
Regional Office
Asheville
Topo Quad
F5NE (Whittier)
Flow Informaiton
USGS #
351060200
Date of flow estimate
Drainage Area (mil)
376
Summer7Q 10 (cfs)
212.9
Winter7Q10 (cfs)
254.7
Average flow (cfs)
940
30Q2 (cfs)
380.8
IWC at discharge (%)
0.18
Cummulative 1WC (%)
Model Input Information
Reach
1
Length of reach (mi)
0.4
Incremental length
0.04
Waste characteristics
Flow (MGD)
0.25
CBOD (mg/I)
60
NBOD (mg/I)
90
DO (mg/I)
; 6,
Runoff charactericstics
�--�
s7Q 10 (cfs/mi)
0
QA (cfs/mi)
0
CBOD (mg/1)
NBOD (mg/I)
DO (mg/I)
Tributary characteristics
s7Q 10 (cfs/mi)
-
QA (cfs/mi)
CBOD (mg/1)
NBOD (mg/I)
DO (mg/!)
Slope (ft/mi)
6.4
File name: Whittier

Discharger
Receiving Stream :
Summer 7Q10
Design Temperature:
*** MODEL SUMMARY DATA ***
WITTIER
TUSCKEEGEE
212.9
28.0
frcfX6Qc1C1OCLat3
Subbasin :
Stream Class: B-T!)
Winter 7Q10 : 254.0
LENGTH SLOPE VELOCITY DEPTH Kd Kd Ka Ka KN
mile ft/mi fps ft design @20° design @20° design
Segment 1
Reach 1
0.40
6.40
1.103
3.64
0.37
0.25
7.39
6.21
0.56
Flow
cfs
Segment 1 Reach 1
Waste
Headwaters
Tributary
* Runoff
0.388
219.000
0.000
0.000
CBOD NBOD D.O.
mg/1 mg/1 mg/1
45.000 90.000 0.000
2.000 1.000 7.050
2.000 1.000 7.050
2.000 1.000 7.050
* Runoff flow is in cfs/mile

SUMMER
Discharger : WITTIER
Receiving Stream : TUSCKEEGEE
MODEL RESULTS
The End D.O. is 7.13 mg/1.
The End CBOD is 2.06 mg/l.
The End NBOD is 1.14 mg/l.
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd)
Segment 1 7.04 0.00 1
Reach 1 45.00 90.00 0.00 0.25000

SUMMER
Seg # I Reach # I Seg Mi I D.O. I CBOD I NBOD
1 1 0.00 7.04 2.08 1.16
1 1 0.04 7.05 2.07 1.16
1 1 0.08 7.06 2.07 1.15
1 1 0.12 7.07 2.07 1.15
1 1 0.16 7.08 2.07 1.15
1 1 0.20 7.09 2.07 1.15
1 1 0.24 7.09 2.07 1.15
1 1 0.28 7.10 2.06 1.15
1 1 0.32 7.11 2.06 1.15
1 1 0.36 7.12 2.06 1.14
1 1 0.40 7.13 2.06 1.14
Seg # I Reach # I Seg Mi I D.O. I CBOD I NBOD
Flow I
219.39
219.39
219.39
219.39
219.39
219.39
219.39
219.39
219.39
219.39
219.39
Flow I

�O
r`CR f(/COQ i� (04 Michael F. Easley, Govemor
Q William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
"' Division of Water Quality
September 27, 2001
Mr. Michael Bolt, Chair
Water Quality Monitoring
Watershed Association of the Tuckasegee River
PO Box 320
Whittier, NC 28789
Dear Mr. Bolt: •
I am writing in response to your correspondence dated May 23, 2001, addressed to Mr. Forrest Westall, and
copied to me regarding the proposed wastewater treatment plant on the Tuckasegee River. I have discussed its
contents with Teresa Rodriguez of the Division of Water Quality (DWQ) Central Office NPDES Unit and
Kevin Barnett of the DWQ Asheville Regional Office. Ms. Rodriguez informed me that speculative permit
limits have been requested for a proposed discharge to the Tuckasegee River at the location of the existing
discharge for the Jackson County Industrial Wastewater Treatment Facility. The Whittier Sanitary District is
proposing to eliminate the waste treatment plants under permits NC0000264 and NC0074250 (0.005 MGD
each) and build a new treatment plant with a capacity of 0.250 MGD.
The request from the Watershed Association for the Tuckasegee River for reclassification of this portion of the
Tuckasegee River from Class C to Class B Tr has been received (along with a similar request from the
Tuckaseigee Chapter of Trout Unlimited) and is currently being processed by DWQ. Your concerns have been
discussed with both Ms. Rodriguez and Mr. Barnett and both are aware of the intent to pursue reclassification.
A copy of your correspondence and the request for reclassification have been placed in the NPDES permit file
for this proposed project and will be considered when an application for this proposed facility is reviewed by
DWQ. Thank you for your concern about water quality in the Tuckasegee River watershed.
Sincerely,
Callie L. Dobson
Little Tennessee River Basin Planner
CC: Forest Westall, DWQ ARO
David Goodrich, DWQ NPDES
Boyd Devane, DWQ Planning
•
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Customer Service
1 800 623-7748

Watershed Association of the Tuckasegee River
May 23, 2001
Mr. Forrest Westall Michael Bolt
N.C. DWQ Regional Supervisor P.O. Box 320
59 Woodfin Place Whittier
Asheville, N.C. 28801 N.C. 28789
Dear Mr. Westall,
Yesterday evening I attended a public meeting in
Whittier, N.C., regarding the proposed construction of a
.25 mgd wastewater treatment plant there on the
Tuckasegee River.
The contract engineers, McGill and Associates
outlined their plans for the project and stated that they
had applied to NCDWQ's David Goodrich for
speculative NPDES permit limits. Their design for the
plant will include disinfection by chlorination.
This section of the river has greatly improved in
water quality and has been identified as habitat for the
endangered Appalachian Elktoe Mussel. The Watershed
Association of the Tuckasegee River has been in
discussion with Callie Dobson, N.C. DWQ Little
Tennessee River Basin Planner about having it
reclassified from class 'C' to class `B' Trout waters.
We would prefer that the proposed plant use ultra
violet disinfection and we would like to see low limits set
for NPDES permit parameters such as BOD, TSS, NH3,
TRC etc., combined with quarterly toxicity testing which
would be appropriate for a class `B' trout receiving
stream.

I would be most grateful for your attention to this
matter prior to the issuance of speculative NPDES permit
limits.
Sincerely, 8..4_
Michael Bolt
Chair, Water Quality
Monitoring, WATR
Enclosures
cc: Callie Dobson, NCDWQ
Kevin Barnett, NCDWQ
David Wheeler, President WATR
Robert Ferguson, Secretary WATR
Mark Cantrell, USFWS

Ms.Callie Dobson
Basin Planner
N.C. Dept. of the Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, N.C. 27899
Dear Ms. Dobson,
The Tuckaseigee Chapter of Trout Unlimited would like to request a reclassification of the
Tuckaseigee River from a Class C Water to a Class B Trout Water.
Thank you for your consideration. If you have any questions, or if we can help with this
process in any way, please let me know. My phone number is [phone] and my e-mail
address is jcmkdeweese@aoLcain.
Sincerely,
Jerry DeWeese
President, Tuckaseigee Chapter
Trout Unlimited

W A T Michael F. Easley, Governor
Q William G. Ross Jr., Secretary
0 7 North Carolina Department of Environment and Natural Resources
r
—I Gregory J. Thorpe, Ph.D.
0 Acting Director
Division of Water Quality
George Rogers, Chairman
Whittier Sanitary District
P.O. Box 850
Bryson City, North Carolina 28713
September 19, 2001
Subject: Speculative Limits Request
Whittier Sanitary District
Jackson County
Dear Mr. Rogers:
This letter is in response to your request for speculative effluent limits for a proposed discharge
to the Tuckasegee River at the location of the existing discharge for the Jackson County Industrial
Wastewater Treatment Facility. The Whittier Sanitary District is proposing to eliminate the waste
treatment plants under permits NC0000264 and NC0074250 and build a new treatment plant with a
capacity of 0.250 MGD. The permitted capacity for each existing plant is 0.005 MGD. A flow
justification for the 0.250 MGD shall be submitted with the Engineering Alternatives Analysis (EAA)
when applying for the permit (guidance is attached).
The speculative limits were developed based on our understanding of the proposal in addition to
our understanding of present environmental conditions at the proposed discharge location. The Division
of Water Quality (Division) can not guarantee that an NPDES permit will be issued at the proposed
location. Final decisions can only be made after the Division receives and evaluates a formal permit
application for the proposed discharge and after the public has an opportunity to comment on the project.
Speculative Effluent Limits
The low flow data used for the development of the limits was the following:
Average flow
940 cfs
Summer 7Q10
212.9 cfs
Winter 7Q10
254.7 cfs
Annual 30Q2
380.8 cfs
Based on the available information, tentative limits for the proposed discharge to the Tuckasegee
River near Whittier at a flow of 0.25 MGD are attached.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET @ www.enr.state.nc.us

The explanation for the effluent monitoring requirements follows:
BOD5 and Total Suspended Solids (TSS) and Fecal Coliform - The BOD5 and TSS limits are
standard for secondary treatment of municipal wastewater.
Fecal Coliform, pH - The limits for fecal coliform bacteria and pH represent water quality
standards for Class B waters (T15A NCAC 2B .0219).
Total Residual Chlorine (TRC) — A limit is required for all new treatment plants using chlorine
for effluent disinfection.
NH3 as N, Total Nitrogen and Total Phosphorus - Monitoring for these parameters is required to
evaluate and protect water quality in the receiving stream.
Please be advised that the limits and monitoring frequencies on the attached pages were based on
the information presented in the speculative limits request. In addition, it was assumed that the proposed
WWTP will be a Class II facility. This assumption was used to develop an estimate of the monitoring
frequencies that would be required for each parameter. A complete evaluation of these limits and
monitoring frequencies in addition to monitoring requirements for metals and other toxicants will be
addressed upon receipt of a formal NPDES permit application.
By copy of this letter the Division is communicating to the US Fish and Wildlife Service and the
North Carolina Wildlife Resources Commission the intent of Whittier Sanitary District to expand the
discharge to the Tuckasegee River.
Should you have any questions or if you need any additional information, please feel free to
contact Teresa Rodriguez [phone], extension 595.
Enclosure
cc: Central Files
Asheville Regional Office
NPDES Unit
USFWS, Tom Augspurger
NCWRC, Owen Anderson —
Sincerely,
-'6, /lbw
i David A Goodrich
NPDES Unit Supervisor
— P.O. Box 33726
Raleigh, North Carolina 27636-3726
20830 Great Smokey Mountains Expressway
Waynesville, North Carolina 28786

A. (1) SPECULATIVE LIMITATIONS AND MONITORING REQUIREMENTS
The following table presents speculative limits and associated monitoring requirements for the proposed
WWTP for Whittier Sanitary District. Preparation of these limits does not guarantee that the Division
will issue a NPDES permit. In addition, it does not guarantee that these limits will remain unchanged if a
permit is issued to Whittier Sanitary District. A complete evaluation of these limits and monitoring
frequencies in addition to monitoring requirements for metals and other toxicants will be addressed upon
receipt of a formal NPDES permit application.
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by
the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
0.250 MGD
Continuous
Recording
I or E
BOD, 5-day, 20°C 2
30.0 mg/1
45.0 mg/1
Weekly
Composite
-,-',E,1.
Total Suspended Residue2
30.0 mg/1
45.0 mg/1
Weekly
Composite
, ...4;1. �. ' ,
pHs
Weekly
Ckrab %' .� •
,
• E` . ', ',,
Fecal Coliform (geometric
mean)
200/100 mi
400/100 ml
Weekly
Grab• • ',
• ••\",
'. E •s `, '\ •
Total Residual Chlorine4
28
µg/1
Monthly ^.` ,
, •,• •:Grab ', •s
,, '•
s.' E
NH3 as N
•; .',
2/MQnth '\
•., Composite `
E
Total Nitrogen (NO2+NO3+TKN)
‘•
'- ,2/year. '•` •
Composite
E
Total Phosphorus
,
, - ,
�, .; �2/year '
`Composite
E
Notes:
1. Sample locations E - Effluent, I Influent, I —Upstream,:D — Downstream. Instream monitoring
requirements to be determined upon •application receipt.
2. The monthly average effluent BOD5•and Total Suspended Residue concentrations shall not exceed 85% of
the respective influentvalue (85a10 removal required).
3. The pH shall not be less -than 6.0 standard units nor greater than 9.0 standard units.
4. Monitoring requirement applies only if chlorine is used for disinfection.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

a
Whittier Sanitary District
Speculative Limits Notes
NPDES permit num: NC0000264 and NC0074250
Owner: Mr. George Rogers
Whittier Sanitary District
P.O. Box 850
Bryson City
Jackson County
Requested by: McGill & Asscoiates
P.O. Box 2259
Asheville, NC 28802
Summary: The Whittier Sanitary District requested speculative limits for a proposed discharge. This new
WWTP would replace the two wastewater treatment systems permitted under NC0000264 and NC0074250.
Actual flow: 0.005 MGD each (total combined flow is 0.010 MGD)
Proposed Flow: 0.250 MGD
Stream Information:
River Basin:
Little Tennessee
Average flow:
940 cfs
Stream:
Tuckasegge River
Summer 7Q10:
212.9 cfs
Sub -basin:
04-04-02
Winter 7Q10:
254.7 cfs
Classification:
B
Annual 30Q2:
380.8 cfs
Basin Plan: The Tuckasegee River in Jackson County is rated as excellent for taxa richness values and
bioclassifications.
Proposed limits: Limits are effluent limited. A Level B model was developed, secondary limits will
protect for summer and winter conditions.
Parameter
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
0.25 MGD
BOD5
30 mg/1
45mg/1
TSS
30 mg/1
45mg/1
pH
6-9
TRC
28 µg/1
Fecal Coliform
200 /100 ml
400/100 ml
NH3 as N
Monitor only
Total Phosphorus
Total Nitrogen
Regional Office correspondence: ARO recommends coliform limits. The ARO performed an inspection on
March 2001 at the Jackson County Development Corp. facility (NC0000264). The inspection report
indicates operational and compliance problems.
Whittier Spec Limits Notes 08/21/01
Page 1 of 1
Teresa Rodriguez

LEVEL B MODEL INFORMATION
Facility Information
Facility Name
Whittier Sanitary District
NPDES No.
Type of wastewater
Domestic/Industrial
Facility status
New
Receiving stream
Tuckasegee (Little Tennessee River basin)
Stream classification
B
Subbasin
40402
County
Jackson
Regional Office
Asheville
Topo Quad
F5NE (Whittier)
Flow Informaiton
USGS #
351060200
Date of flow estimate
Drainage Area (mil)
376
Summer7Q10.(cfs)
212.9
Winter7Q10 (cfs)
254.7
Average flow (cfs)
940
30Q2 (cfs)
380.8
!WC at discharge (%)
_ __
0.18
Cummulative IWC (%)
Model Input Information
Reach
1
Length of reach (mi)
0.4
Incremental length
0.04
Waste characteristics
Flow (MGD)
0.25
CBOD (mg/I)
60
NBOD (mg/I)
90
DO (mg/I)
Runoff charactericstics
s7Q 10 (cfs/mi)
0
QA (cfs/mi)
0
CBOD (mg/l)
NBOD (mg/I)
DO (mg/I)
Tributary characteristics
s7Q10 (cfs/mi)
QA (cfs/mi)
CBOD (mg/I)
NBOD (mg/I)
DO (mg/I)
Slope (ft/mi)
6.4
File name: Whittier

SUMMER
Discharger : WITTIER
Receiving Stream : TUSCKEEGEE
MODEL RESULTS
The End D.O. is 7.13 mg/1.
The End CBOD is 2.06 mg/l.
The End NBOD is 1.14 mg/1.
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd)
Segment 1 7.04 0.00 1
Reach 1 45.00 90.00 0.00 0.25000

SUMMER
Seg # I Reach # I Seg Mi I D.O. I CBOD I NBOD I Flow I
1 1 0.00 7.04 2.08 1.16 219.39
1 1 0.04 7.05 2.07 1.16 219.39
1 1 0.08 7.06 2.07 1.15 219.39
1 1 0.12 7.07 2.07 1.15 219.39
1 1 0.16 7.08 2.07 1.15 219.39
1 1 0.20 7.09 2.07 1.15 219.39
1 1 0.24 7.09 2.07 1.15 219.39
1 1 0.28 7.10 2.06 1.15 219.39
1 1 0.32 7.11 2.06 1.15 219.39
1 1 0.36 7.12 2.06 1.14 219.39
1 1 0.40 7.13 2.06 1.14 219.39
I Seg # I Reach # I Seg Mi I D.O. I CBOD I NBOD I Flow

*** MODEL SUMMARY DATA ***
Discharger : WITTIER Subbasin .•
Receiving Stream : TUSCKEEGEE Stream Class: .,8
Summer 7Q10 : 212.9 Winter 7Q10 : 254.0
Design Temperature: 28.0
LENGTH SLOPE VELOCITY DEPTH Kd Kd Ka Ka KN
mile ft/mi fps ft design @20° design @20° design
Segment 1
Reach 1
0.40
6.40
1.103
3.64
0.37
0.25
7.39
6.21
0.56
Flow
cfs
Segment 1 Reach 1
Waste
Headwaters
Tributary
* Runoff
0.388
219.000
0.000
0.000
CBOD NBOD D.O.
mg/1 mg/1 mg/1
45.000 90.000 0.000
2.000 1.000 7.050
2.000 1.000 7.050
2.000 1.000 7.050
* Runoff flow is in cfs/mile

Zc�1u G�c �c c5on C/ c, ;? &t,c t - /P%'ory o so d ,2 5 At/ G(i.s chter
2GccRaour
Cv-katter
4,60),
Au„,
T
Yiscikar, S -
0-fr
/ -.�' t— c2.
-- - cry, --f_.
z
�Rur' 2 iO
`gyj s1 q to = 5. q 2 as
(5)(\ w 7Q 10= 1 cf s
3a9a • !Llolcf7
(0s3 s roc, ! 000)
Dis dwelt
'DA 37(0, rni 2
q = 910els
37Q ro = .2/Q. 9 cis
w?(Pro 3 a5i.7 c<s
30R a - 3 f(D . F -�: ---

Facility:
NPDES#:
Receiving Stream:
Comment(s):
Low Flow Record Station Number:
Hydrologic Area Number:
Drainage Area Low Flow Record Station:
Qave Low Flow Record Station:
s7Q10 Low Flow Record Station:
w7Q10 Low Flow Record Station:
30Q2 Low Flow Record Station:
Drainage Area New Site:
MAR New Site:
Qave per Report Equation:
s7Q10 per Report Equation:
w7Q10 per Report Equation:
30Q2 per Report Equation:
tuckagee river
gage number not available
03.5110.5000
HA10
347
763.40 cfs
198.00 cfs
236.00 cfs
353.00 cfs
must be < 400 sq. miles
376
2.5
Drainage Area Ratio:
[ new DA / Da at gage
Weighted Ratio:
Over -ride Inappropriate Site (y ):
940 cfs
156.02 cfs
221.21 cfs
323.36 cfs
Continue
1.08 : 1
Continue
0.97 : 1
Drainage Area New Site:
MAR New Site:
Weighted Qave per Report Equation:
Weighted s7Q10 per Report Equation:
Weighted w7Q10 per Report Equation:
Weighted 30Q2 per Report Equation:
II
376
2.5
940 cfs
212.92 cfs
254.76 cfs
380.85 cfs

Facility:
NPDES#:
Receiving Stream: tuckagee river
Comment(s):
gage number not available
Low Flow Record Station Number.
Hydrologic Area Number
Drainage Area Low Flow Record Station:
Qave Low Flow Record Station:
s7Q1 0 Low Flow Record Station:
w7Q10 Low Flow Record Station:
3002 Low Flow Record Station:
Drainage Area New Site:
MAR New Site:
Qave per Report Equation:
s7Q10 per Report Equation:
w7Q10 per Report Equation:
30Q2 per Report Equation:
03.5110.5000
HA10
347
763.40 cfs
198.00 cfs
236.00 cfs
353.00 cfs
must be < 400 sq. miles
400
2.5
1000 cfs
166.09 cfs
235.18 cfs
344.00 cfs
Continue
Drainage Area Ratio: 1.15 : 1
[ new DA / Da at gage Continue
Weighted Ratio: 0.95 :1
Over -ride Inappropriate Site (y ):
Drainage Area New Site: 400
MAR New Site: 2.5
Weighted Qave per Report Equation: 1000 cfs
Weighted s7Q10 per Report Equation: 225.08 cfs
Weighted w7Q10 per Report Equation: 270.17 cfs
Weighted 30Q2 per Report Equation: 403.71 cfs

C� eo n Lei C
Facility:
NPDES#:
Receiving Stream:
Comment(s):
Low Flow Record Station Number:
Hydrologic Area Number:
Drainage Area Low Flow Record Station:
Qave Low Flow Record Station:
s7Q10 Low Flow Record Station:
w7Q10 Low Flow Record Station:
30Q2 Low Flow Record Station:
Drainage Area New Site:
MAR New Site:
Qave per Report Equation:
s7Q10 per Report Equation:
w7Q10 per Report Equation:
30Q2 per Report Equation:
Wittier Sanitary District
Spec
Tuckaseegee
gage number not available
03.5106.1000
HA10
13.50 miles squared
33.80 cfs
must be < 400 sq. miles
13.50 sq. miles
2.5 cfs/miles squared
Drainage Area Ratio:
[ new DA/ Da at gage
Weighted Ratio:
Over -ride Inappropriate Site (y ):
34 cfs
5.42 cfs
8.21 cfs
11.61 cfs
Continue
1.00:1
Continue
1.00:1
Drainage Area New Site:
MAR New Site:
Weighted Qave per Report Equation:
Weighted s7Q10 per Report Equation:
Weighted w7Q10 per Report Equation:
Weighted 30Q2 per Report Equation:
u
13.50 miles squared
2.5 cfs/miles squared
34 cfs
no input from above
no input from above
no input from above

IWC Calculations
Owner Whittier Sanitary District
Facility Proposed WWTP
Prepared By: Teresa Rodriguez, NPDES Unit
[nter Design Flow (MGD):
Enter s7Q10(cfs):
Enter w7Q10 (cfs):
0.25
212.9
254.7
Residual Chlorine
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (l
IWC (%)
Allowable Conc. (ug/l)
Fecal Limit
(If DF >331; Monitor)
(If DF <331; Limit)
Dilution Factor (DF)
NPDES Servor/Current Versions/IWC
212.9
0.25
0.3875
17.0
0
0.18
9357
Ammonia (NH3 as N)
(summer)
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL
IWC (%)
Allowable Conc. (mg/I)
Ammonia (NH3 as N)
(winter)
7Q10 (CFS)
Not Required DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
550.42 UPS BACKGROUND LEVEL
IWC (%)
Allowable Conc. (mg/I)
212.9
0.25
0.3875
1.0
0.22
0.18
429.5
254.7
0.25
0.3875
1.8
0.22
0.15
1040.3
6/21/01

NC DENR - DIVISON OF WATER QUALITY 2B . 0300
.0303 LITTLE TENNESSEE RIVER BASIN
Classification
Name of Stream Description Class Date Index No.
Unnamed Tributary to From source to Sylva Water WS-I HQW 08/03/92 2 79-39-11-2.5-(1)
Fisher Creek Supply Intake
Unnamed Tributary to From Sylva Water Supply C Tr 07/01/73 2 79-39-11-2.5-(2)
Fisher Creek Intake to Fisher Creek
Dills Creek From source to Fisher Creek C 08/03/92 2 79-39-11-3
Unnamed Tributary to From source to Sylva Water WS-I HQW 08/03/92 2-79-39-11-3-1-(1)
Dills Creek Supply Intake
Unnamed Tributary to From Sylva Water Supply C 08/03/92 2-79-39-11-3-1-(2)
Dills Creek Intake to Dills Creek
Monteith Branch From source to Scott Creek C 07/01/61 2 79-39-12
Kitchin Branch From source to Scott Creek C 07/01/61 2-79-39-13
Allens Branch From source to Scott Creek C 09/01/74 2-79-39-14
Cope Creek From source to Scott Creek C Tr 07/01/73 2-79-39-15
Dills Branch From source to Scott Creek C 09/01/74 2-79-39-16
Mack Town Branch From source to Tuckasegee C 07/01/61 2-79-40
River
Tuckasegee River From Mack Town Branch to 3 09/01/96 2-79 (40.5)
Cochran Branch
Long Branch From source to Tuckasegee C 07/01/61 2-79-41
River
Mince Branch From source to Long Branch C 07/01/61 2-79-41-1
Dicks Creek From source to Tuckasegee C Tr 07/01/61 2-79-42
River
West Fork Dicks From source to Dicks Creek C 07/01/61 2-79-42-1
Creek
Ned Branch From source to West Fork C 07/01/61 2-79-42-1-1
Dicks Creek
Big Branch From source to West Fork C 07/01/61 2-79-42-1-2
Dicks Creek
Buckeye Branch From source to West Fork C 07/01/61 2-79-42-1-3
Dicks Creek
East Fork Dicks From source to Dicks Creek C 07/01/61 2-79-42-2
Creek
Schoolhouse Branch From source to Dicks Creek C Tr 07/01/61 2-79-42-3
Laurel Branch From source to Tuckasegee C 07/01/61 2-79-43
River
Barkers Creek From source to Tuckasegee C Tr 07/01/61 2-79-44
River
West Fork Barkers From source to Barkers Creek C 07/01/61 2-79-44-1
Creek
Middle Fork Barkers From source to Barkers Creek C 07/01/61 2-79-44-2
Creek
East Fork Barkers From source to Barkers Creek C 07/01/61 2-79-44-3
Creek
27

WHITTIER SANITARY DISTRICT
PO BOX 850
BRYSON CITY, NC 28713
July 3, 2001
Mr. David Goodrich
North Carolina Department of Environment,
Health and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Mr. Goodrich:
CD
Cr)
J
CL
RE: Whittier Sanitary District
Request for Speculative Effluent Limitations
On behalf of the Whittier Sanitary District, this letter is to inform you that the District has
authorized McGill Associates, P.A. of Asheville, North Carolina to request speculative
effluent limitations for a discharge to the Tuckaseigee River. Further, as the design for
this facility is completed, we intend to submit an application package for an NPDES
discharge to construct this facility. Your review, assistance and cooperation in these
efforts on this very important project are greatly appreciated. If you have any questions,
please do not hesitate to call me.
Sincerely,
WHITTIER SANITARY DISTRICT
George Rogers, Chairman
cc: Steve Eller, Southwestern Commission
Randy Hintz, McGill Associates

7:0-zot — 4,4 ApXoLat,Siti
Mc G
1 SSOCI A TES
March 8, 2001
Mr. David Goodrich)
North Carolina Department of Environment,
Health and Natural Resources
Division of Water Quality
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Dear Mr. Goodrich:
rn
m
cn
A-4
Al
f7 rn
m �
CO O
:O
D Cr—
"r
)
RE: Whittier Sanitary District
Request for Speculative Effluent Limitations
CD
On the behalf of the Wittier Sanitary District, we are requesting speculative effluent
limitations for a discharge to the Tuckaseegee River. As indicated on the enclosed portion of
the Whittier USGS Quadrangle map, we are considering the elimination of the existing
wastewater treatment facility serving the Jackson County Industrial Park (currently permitted
for 5,000 GPD under NPDES permit # NC0000264) and constructing a new facility within the
industrial park that would have a capacity of 250,000 GPD. The influent wastewater is
expected to be typical municipal wastewater. This project would also eliminate an additional
existing wastewater treatment facility in the area serving Gateway Chevron and Gateway
Factory Housing (also currently permitted for 5,000 GPD under NPDES permit # NC0074250)
We appreciate your prompt assistance with this very important issue. If you have any
questions, please do not hesitate to call me.
Sincerely,
McGILL ASSOCIATES, P.A.
RANDALL D. HINT , .E.
Project Engineer
Enclosure
Engineering • Planning • Finance
McGill Associates. P.A. • Y.U. liox 259, :Ishrrille. NC 2NS02 • 5 Broad Street. Aahrrillr, NC 2Rh01
828-252-0575 • FAX S2S-252-25IS

3923
..Cove .II
630 000
FEET 30
h'
' u
•