NC0064416_Permit Issuance_19980803

NPDES DOCYNENT SCANNING COVER SHEET
NC0064416
Cullasaja Club WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Additional Information Received
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
August 3, 1998
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content on the reYerse side

-';'State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Daniel A. Almers
Cullasaja Club
1371 Cullasaja Club Drive
Highlands, North Carolina 28741
Dear Mr. Almers:
DENR
August 3,,1998
Subject: Issuance of NPDES Permit
Permit No. NC0064416
Cullasaja Joint Venture
Jackson County
This letter is to inform you that the Division has finalized its review and the comment period is
now closed for NPDES permit NC0064416. A final copy of the permit is attached to this letter for your
records.
Based on a review of the facility files and the information presented at the public meeting, held on
January 13, 1998, the Director has recommended issuing the permit without any requirements for
irrigation of the effluent. In addition to this recommendation, the director has requested that the facility
perform instream monitoring. The following additional monitoring requirements were included in the
final permit:
• Instream Monitoring Requirements:
The Permittee is required to perform monitoring upstream and downstream of the discharge
point for the following parameters:
- Dissolved Oxygen
- Fecal Coliform (geometric mean)
- Temperature
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, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such
demand is made, this decision shall be final and binding.
Please be advised that this permit is not transferable. Part II, E.4. addresses the requirements to
be followed in case of change in ownership or control of this discharge. In addition, this permit does not
affect the legal requirement to obtain other permits that may be required by the Division of Water
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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Issuance of NPDES Permit NC0064416
Cullasaja Joint Venture
Page 2 of 2
Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any
other Federal or Local governmental permit that may be required.
In closing, I would like to state that it is the Division's ultimate goal to provide quality service to
the public. Please take a moment to review the procedures you followed in applying for this permit
renewal in addition to the Division's response to your project needs. If we can improve our service to
you in any manner, please bring it to our attention. We appreciate your cooperation during the renewal
process and we look forward to working with you in the future.
If we can be of further assistance to you or if you would like to suggest any improvements we
can make to strengthen our customer service efforts, please do not hesitate to contact Jeff Myhra of my
staff at [phone], extension 597. We look forward to hearing from you.
Sir�cerely,
A. Preston Howard, Jr.,
cc: Central Files
Mr. Roosevelt Childress, EPA
Asheville Regional Office / Water Quality Section
Point Source Compliance Enforcement Unit
NPDES Unit / Permit file
Mr. Richard Melvin, Jones. Key, Melvin & Patton, P.A.
19 East Main Street
Franklin, NC 28734

Permit No. NC0064416
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,
Cullasaja Joint Venture
is hereby authorized to discharge wastewater from a facility located at the
Cullasaja Joint Venture
east of US Highway 64 & NC Highway 28 Intersection
northeast of Highlands
Jackson County
to receiving waters designated as Norton Mill Creek in the Savannah River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV
hereof.
The permit shall become effective September 1, 1998
This permit and the authorization to discharge shall expire at midnight on August 31, 2002
Signed this day August 3, 1998
A. Preston Howard, Jr., P.E.,.Qirect
Division of Water Quality
By Authority of the Environmental Management Commission

SUPPLEMENT TO PERMIT COVER SHEET
Cullasaja Joint Venture
is hereby authorized to:
Permit No. NC0064416
1. Continue to operate an existing 0.15 MGD wastewater treatment facility consisting of a dual
train activated sludge facility with tertiary filters, chlorine disinfection and a five day
detention effluent holding pond located at Cullasaja Joint Venture, east of US Highway 64
and NC Highway 28 intersection, northeast of Highlands, Jackson County (See Part III of
this permit), and
2. Discharge from said treatment works at the location specified on the attached map into
Norton Mill Creek which is classified Class C-TR with an additional management strategy to
protect downstream ORW waters in the Savannah River Basin.

ROAD CLASSIFICATION
PRIMARY HIGHWAY
HARD SURFACE
SECONDARY HIGHWAY
HARD SURFACE
LIGHT -DUTY ROAD. HARD OR
IMPROVED SURFACE
UNIMPROVED ROAD
Latitude 35°04'04"
Map # G6SW
Longitude 83°09'47"
Sub -basin 03-13-01
Stream Class C-TR
Discharge Class 05
Receiving Stream Norton Mill Creek
Design Qo.15 MGD Permit expires 08/31/02
0
SCALE 1:24 000
0
1 MILE
7000 FEET
771
•
1
0
1 KILOMETER
CONTOUR INTERVAL 40 FEET
Cullasaja Jont Venture
NC0064416
Jackson County

A.(1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0064416
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall
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
Location1
Flow
0.15 MGD
Continuous
Recording
I or E
BOD, 5 day, 20°C
30.0 mg/I
45.0 mg/i
3 / Week
Composite
E
Total Suspended Residue
30.0 mg/l
45.0 mg/l
3 / Week
Composite
E
NH3 as N (April 1 to October 31)
1.5 mg/I
3 / Week
Composite
E
NH3 as N (November 1 to March 31)
3.0 mg/i
3 ! Week
Composite
E
Dissolved Oxygen2
3 / Week
Grab
E
Dissolved Oxygen2
See Note 1
Grab
U, D
pH3
3 / Week
Grab
E
Fecal Coliform (Geometric Mean)
200 / 100 ml
400 / 100 ml
3 / Week
Grab
E
Fecal Coliform (Geometric Mean)
See Note 1
Grab
U, D
Total Residual Chlorine
27 pg/l
3 / Week
Grab
E
Temperature4
Daily
Grab
E
Temperature4
. See Note 1
Grab
U, D
Total Nitrogen (NO2 + NO3 + TKN)
Semi-annually
Composite
E
Total Phosphorus
Semi-annually
Composite
E
Notes:
1 Sample locations: E - Effluent, I - Influent. U - Upstream, D — Downstream approximately 20-40 feet (just before the steep drop-off).
Upstream and downstream samples shall be grab samples. Stream samples shall be collected three times per week during June, July, August,
and September and once per week during the remaining months of the year.
2 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg%l.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 0.5°C and in
no case cause the ambient water temperature to exceed 20°C.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
April 6, 1998
MEMQ$ANDQTM
TO: A. Preston Howard, Jr., Director
FROM: M. Steven Mauney, Meeting Officer N.,4
SUBJECT: Findings and Recommendations(s) in the Matter of
NPDES Permit NC0064416
Cullasaja Joint Venture
Jackson County
As directed by you, I have conducted a Public Meeting concerning whether to issue a NPDES
Permit to Cullasaja Joint Venture for the continued operation of the WWTP that serves Cullasaja
Club. This meeting was held at the Blue Ridge School in Cashiers on January 13, 1998, at 7:00 p.m.
Application Abstract
On January 28, 1997, Mr. Daniel Almers, General Manager of Cullasaja Club applied for
renewal of the NPDES Permit. The Permit initially issued in 1986 and renewed in June of 1993
authorized the continued discharge of 0.15 MGD to Norton Mill Creek which is classified C-Trout
with an additional management strategy to protect downstream ORW waters in the Savannah River
Basin. The permit also contained a condition in 1993 that stated, "A discharge from this facility shall
not be allowed except in cases when spray irrigation is not usable". The stream has a 7Q10 of 0.14
CFS and a 30Q2 of 0.35 CFS. Copy of a USGS topo map is located in Attachment I for your
convenience.
Meeting Summary DWO
1. In addition to the Water Quality Staff, there were 22 registered persons in attendance at the
meeting. Of these 22 persons, 4 expressed comments opposing issuance of the permit as
drafted. Senator Bob Carpenter of Franklin was also in attendance. The sign in sheet is at
Attachment II.
2. Mr. Jeff Myhra, with DWQ gave a brief presentation of our permitting procedures and
rationale forrenewing the NPDES Permit. See Item 3.F. for more comments by Mr. Myhra.
3. Issues raised:.
A. The common theme that was repeated by most speakers was their concern that the
permit condition that required irrigation of the effluent should be retained and the
amount of discharge should be reduced.

- 2-
B. Mr. Richard Melvin, Attorney from Highlands, N.C. indicated that based on the
permit condition that required irrigation in 1993, he thought that irrigation was still
being used until he saw the draft permit of 1997. He stated that the citizens have
relied on the good faith of our agency to require maximum irrigation of the
wastewater. His statement and another from Richard and Debbie Griffiths which he
presented at the hearing are given at Attachment III. Mr. Melvin also makes reference
to a transfer of water between watersheds which appears to be due to a
misunderstanding of the source of water at this site. Wells are the source of domestic
water at this site.
C. Mr. Ray Mortensen, V.P. Southeast Region (NC, SC, GA) Trout Unlimited expressed
concerns about protection of the river and requested the reduction of the effluent.
D. Ms. Peg Jones, President, Save Our Rivers, Inc. requested the facility look at spray
irrigation seriously and carefully. She feels that Disney which owns Cullasaja Joint
Venture should put the money into this project to stop all discharges. Ms Jones also
read a letter from William O. McLarney, Ph.D. which is in Attachment IV.
E. Buzz Williams, Executive Director, Chattooga River Watershed Coalition said that
the stream was impaired and that we should try something new, better and different
here. He argued that DWQ was, " hiding behind a bogus argument of high rainfall".
He suggested there was a violation of the Clean Water Act and his organization will
bring a lawsuit.
F In his presentation Mr. Myra stated that, "On March 14, 1997, the Permittee formally
requested a waiver of the requirement for disposing its wastewater effluent using
spray irrigation on the golf course. The following reasons were identified to justify
this request:
•
•
Rainfall in the area, over the past 40 years, has averaged 80 to 100 inches per
year which prevents use of the irrigation system on a regular basis;
The most significant use period for the spray irrigation system occurs during
the months of May and June when the evaporation rate is at its highest. In
addition, there is minimal usage during the months of July through October.
For the remainder of the year, November through April, the spray irrigation
system is completely closed down;
The maintenance of the facilities for the non -discharge option requires
additional expense that is not warranted in this case.
Based on information stated above and after a detailed review of the monthly
discharge monitoring report data, rainfall data for the Highlands area, compliance
inspection reports for the subject facility, and due to the fact that the facility has to

-3-
meet close limits specified in the discharge permit, the Division proposes to grant the
Permittee's request to delete the special condition requiring the Permittee to use
spray irrigation as the primary means for wastewater disposal. Consequently, the
spray irrigation permit was not renewed."
G. The Meeting Record was kept open until January 19,1998. Mr. Melvin submitted a
letter to the Winston-Salem office on February 9,1998 (letter dated February 2,1998)
with eight (8) letters attached from largely out of state residents some of which
mentioned ,"It has come to our attention that the Cullasaja Club is dumping raw
sewage into Norton Mill Creek". This is included at Attachment V.
Other Information
1. Observations made on the day of the meeting at the plant site revealed that the plant was
shielded from view and that the blowers were enclosed in a building to reduce noise. The
plant discharges to a 5 day holding basin and then to an outfall line that travels several
hundred feet across a fairway to the stream.
Mr. Almers noted there were 130 homes in the project currently, and that.the maximum
number of homesites are 350 (representing a current 37% buildout). All but 751ots have been
sold with the current price set at $140,000/lot.
2. Rainfall data from 1971 to mid-96 was reviewed with the driest year (1981) having 64.77
inches of rain and the wettest year being 1979 with 116.32 inches reported in only 11
months. The average for this 25 year period is 85.35 inches even with incomplete rainfall data
reported for several years. In fact, since 1989 there was only one year (`93 with 71.2 inches)
that has had less than 97 inches of rain. Precipitation data is summarized at attachment
VI.
3. While the NPDES permit was conditioned in 1993 to require irrigation there were several
things to resolve such as the potential need to modify the storage pond (requirement later
removed in June'96 by 15 NCAC 2H.0219,(k),(1),(B),(viii)), insuring compliance with
stringent turbidity and fecal coliform limits and verifying that buffers exist or providing
adequate buffers from all irrigation spray influence to streams or wells. While these were not
insurmountable obstacles it appears that they prevented Cullasaja Club from implementing
the irrigation system. Following the below average rainfall year of 1993 they have had 12 to
15 inches above average rainfall each year since then.
4. The discharge from this facility will dominate the stream at 7Q10 conditions with
150,000 GPD discharged and 90,500 GPD of stream flow. The ratio of effluent to
stream flow is 1.66, while the Instream Waste Concentration (IWC) is 0.624 {0.15 /

4
(0.15+0.0905)= 0.15/ 0.2405=0.624 } .
Findings
1. The basic issue involved in these matters is whether you, as Director of the Division of Water
Quality, should approve, deny or modify the NPDES permit in question. The decision making
criteria has been established in Title 15A NCAC Chapter 2, Subchapter H., Section .0112(b)
and N.C. General Statute 143-215.1 (b).
2. This application for permit appears to be proper, public notice of intent to issue and
subsequent notice of public meeting have been in keeping with regulatory requirements.
3. The receiving stream for this discharge is appropriately classified with applicable water quality
standards. The discharge limitations in the draft NPDES permit were determined using the
Division's approved waste load allocation methodology.
Discussion -
1. One hearing speaker suggested that the facility study their non -discharge options. As this
is an existing treatment plant that is largely in compliance with its NPDES Permit, and
discharging to a stream with a positive flow, there is no regulatory mandate for them to
pursue a non -discharge approach.
While the permit was conditioned in 1993 to require irrigation when useable, it was not
found to be a practicable matter to implement. Rainfall conditions and site limitations
including topography, buffer distances and the inability to irrigate from November
through April made spray irrigation of a high quality effluent seem impracticable.
2. According to 15A NCAC 2B .0225, (e), (2) no new discharges are allowed to Norton Mill
Creek or its tributaries nor any increases of pollutant loadings. This condition will certainly
provide some protection for the stream as only development of other projects with on -site
waste disposal will be occurring and they will certainly be low density type of projects.
3. The draft permit does not include any stream monitoring but with the limited stream
dillution as evidenced by the IWC of 0.624, it is an issue that must be considered.
The period of concern for this discharge is during the warm months such as April thru
October when the stream flows would be lower and the effluent limits are tighter.
Recommendation -
It is recommended that the permit be reissued without any requirements for irrigation of the
effluent but with stream monitoring conditions added for the summer months.
61)1
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n4-L3- 98 Scvre Pr) _ 06'04.

•
AFFIDAVIT OF PUBLICATION 1/1
CLIPPING OF LEGAL ADVERTISEMENT
ATTACHED HERE
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NORTH CAROLINA
JACKSON COUNTY
Before the undersigned, a Notary Public of
Macon County, North Carolina, duly commissioned,
qualified, and authorized by law to adrniui.stcroaths,
personally appeared
iurh<psee
who being first duly sworn, deposes and says: that he
(she)
is Cialk,111
(Owner, partner, publisher, or other of(i r or em-
ployee authorized to make this affidavit) of the Cash-
iers Crossroads Chronicle Newspaper, published,
issued, and entered as a second class mail in the Town
of Cashiers in said County and State; that he (she) is
authorized to make this affidavit and sworn state-
ment; that the notice or other legal advertisement, a
true -copy of which is attached hereto, was published
in The Cashiers rossroads Chronicle on the follow-
ing dates: / /0 l9• 7
and that the said newspaper in which such notice,
paper, document, or legal advertisement was pub-
lished was, at the time of each and 'every such publi-
cation,anewspaper meeting all the requirements and
qualification of Section ]-597 of the General Statutes
of North Carolina and was a qualified newspaper
Within the meaning of Section 1-597 of the General
Statutes of North Carolina.
This / / dayof
19
(Signature of person makin;'affidavit)
Sworn to anpfiubscribcd before me, this //
dayof , 19 677
Notary Public
My Commission Expires October28, 2001
My Commission expires:

NOTICE OF PUBLIC HEARING
TO BE BE HELD BY
THE NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT COMMISSION
SUBJECT: A public meeting
has been scheduled concerning
the issuance of State NPDES
Permit No. NC0064416 to the
Cullasaja Joint Venture, 1371
Cullasaja Club Drive, Highlands,
North Carolina 28741 for a facility
located at Cullasaja Joint Venture,
east of US Highway 64 & NC
Highway 28 Intersection, Jackson
County. The facility discharges
0.15 MGD of treated domestic
wastewater from one outfall into
Norton Mill Creek, a Class C-Trout
stream in the Savannah River
Basin, which has a 7Q10 flow of
0.14 cfs.
PURPOSE: The Cullasaja Joint
Venture has applied for a permit
renewal. On the basis of prelimi-
nary staff review and application of
Article 21 of Chapter 142 renerril
St-atuteg of North Carolina, and
other lawful standards and regula-
tions, the North Carolina Envir-
onmental Management Com-
mission proposes to issue a State-
NPDES permit subject to specific
pollutant limitations and special
conditions. The Director of the
Division of Water Quality pursuant
to NCGS 143-215 1(c) (3) and
Regulation 15 NCAC 2H .0100 has
determined that it is in the public
interest that a meeting be held to
receive all pertinent public
comment on whether to issue or
deny the renewal request.
MEETING PURPOSE: The
meeting will be conducted in the
following manner:
1. Explanation of the North
Carolina Environmental Manage-
ment Commission's Permit
. ;F,GU!:, by tho D'_'ision.. of 1..^./2ter
Quality.
2. Explanation of the action for
which the permit is required by the
applicant.
3_ Public Comment —
Comments, statements, data an,,
other information may be submitted
in writing prior to or during the
meeting or may be presented orally
at the meeting. Persons desiring to
speak will indicate this intent at the
time of registration at the meeting.
So that all persons desiring to
speak may do so, lengthy state-
ments may be limited at the discre-
tion of the meeting officer. Oral
presentations which exceed three
minutes must be accompanied by
three (3) written copies which will
be filed with the meeting clerk at
the time of registration.
4. Cross examination of per-
sons presenting testimony will not
be allowed; however, the meeting
officer may ask questions for clari-
fication.
5. The meeting record will be
closed at the conclusion of the
rneatin .
WREN: Tuesday, January 13th
at 7:00 p.m.
WHERE: Blue Ridge School
(meeting will take place in the
school cafeteria), 95 Bobcat Drive,
Cashiers, North Carolina.
INFORMATION: A copy of the
draft NPDES permit and a sketch
showing the location of the dis-
charge is available by writing or
calling:
Jeffrey T. Myhra, E.J.T.
NC DENR/DWQ/NPDES Group
P.O. Box 29535
Raleigh, North Carolina
27626-0535
Telephone Number: (919) 733-
.5083 extension 597. �,
The application and other in-
formation is on file at the Division
of Water Quality, 512 North
Salisbury Street, Room 925,
: :lu<.i---Rilikiirtg,,-Raieigh, Nortn
Carolina and at the Asheville
Regional Office, 59 Woodfin Place,
Asheville, North Carolina. They
may be inspected during normal
office hours. Copies of the infor-
mation on file are available upon
, request and payment of the costs
of reproduction. All such comments
and requests regarding this matter
should make reference to applica-
tion number NC0063321.
A. Preston Howard Jr., Director
Division of Water Quality
Date: 11-25-97
12/10, 1997, 1 x ch

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PAY LAST
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State of North Carolina
Department of Environment,
Health and Natural Resources
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
O C T 1© 1997
Mr. Richard Melvin
Jones, Key, Melvin & Patton, P.A.
Professional Building Suite 3
South Street
Highlands, North Carolina 28741
Dear Mr. Melvin:
Avir,de
�EHNR
y: AL> '"lJi
-y
Thank you for the recent letter and for sharing your concerns about a pending
renewal permit application for the Cullasaja Joint Venture's wastewater discharge permit.
By copy of this letter, I am referring your request for a public hearing on this issue
to Mr. Preston Howard, director of the North Carolina Division of Water Quality. Mr.
Howard will place your request in the public comment file for the Cullasaja Joint Venture
and will consider it when deciding whether to hold a public hearing.
Thank you again for sharing your concerns and opinions on this matter.
/0"-A9
Wayne McDevitt
cc: A. Preston Howard, Jr. (with attachments)
Roy Davis
William Anderson
OCT 1 7 1997
VVH I ER QUALITY
SECTION
PO. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
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RICHARD S. JONES. JR.
BOBBY I. KEY
RICHARD MELVIN
LAWRENCE M. PATTON. R.
GILBERT RUSSELL KEY II
CHESTER M. JONES
E. ELIZABETH LEFLER
FRED H. JONES
I. DAVID DILLON
RECEIVED
OFFICE OF THE SECRETARY
JONES, KEY, MELVIN & PATTON, P.A.t
ATTORNEYS AND COUNSELORS AT LAW
61 EAST MAIN STREET
FRANKLIN. N.C. 28734
TEL. [phone]
FAX [phone]
July 29, 1997
T E PROFESSIONAL BUILDING SU3 �I h0 MENT
P.O. BOX 609
HIGHLANDS. N.C. 2874
SOUTH STREET AA,,
HE' '
8-1906
TEL [phone]- �'��6-1920
`D MER A. JONES 1918-1963 i
PLEASE REPLY TO:
Highlands
Wayne McDevitt, Secretary
North Carolina Department of Environment, Health, and Natural Resources
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Norton Mill Creek Permit #NC0064416
Dear Sir,
This is to request a public hearing on the renewal of the above
permit. The original permit has been substantially modified without
notice to the public, our office, or affected property owners
The history of this permit is summarized in the attached letter
from the Asheville Regional Office of the Department dated April 29
(copy enclosed [Exhibit A] hereith for your reference).
The existing permit was issued after a public hearing and several
communications between the Department and the "Friends of Norton Mill
Creek" in 1986, resulting in an understanding that discharge would
be released into Norton Mill Creek only when the approved irrigation
system could not be operated (for example, in conditions of excess
rainfall or freezing weather). As a result of this understanding and
in reliance thereupon, no further actions were taken by the "Friends
of Norton Mill Creek" regarding the permit.
•
The substantial changes in operation without notice, in effect
amounting to a new permit, in spite of previous assurances by an agency
of the State raise genuine constitutional issues of due process. In
fact, the only notice came as a result of a routine comment on the
Savannah River Basin Plan, which was received on or about March 31
after the changes had already long previously been in effect.
Please also refer to our letter of January 9, 1986 (copy enclosed
[Exhibit B] hereith for your reference) in which we notified the Department
(V4) of a riparian rights issue, which it may become necessary to
pursue in addition to the procedural and administrative aspects of
this matter.

-2-
We also attach hereto a copy of the letter of the Jackson County
Commissioners and a clipping from the local newspaper showing substantial
public interest in this matter for your consideration, together with
petitions gathered at the recent Norton Family Reunion, in addition
to other petitions which may have been submitted to the department.
Yours truly,
Jones, Key, Melvin, & Patton, P.A.
Richard Melvin
cc: Zeb Alley, Esq.

('Exhibit A)•
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P,E., Director
Asheville Regional Office
ED-F. FNJF'
WATER QUALITY SECTION
April 29, 1997
C PY
Mr. Richard Melvin
Jones, Key, Melvin, & Patton, P.A.
Professional Building, Suite 3
South Street
Highlands, North Carolina 28741
Dear Mr. Melvin:
The following should bring you up to date on the wastewater
situation at Cullasaja Joint Venture. As you know, the permits are
to be renewed this year.
The decision to allow a discharge from the Cullasaja Joint
Venture wastewater treatment facility to Norton Mill Creek was
confirmed by the original permit (N00064416) issued in 1986. The
actual "decision" was made by the North Carolina General Statutes and
subsequent regulations of the Division. This permit did not mention
spray irrigation.
In July of 1988, the Division issued Permit Number 16529
thereby allowing spray irrigation of treated wastewater on the golf
course. In February 1989, this irrigation permit was modified to
require chemical monitoring of the wastewater. At this time, the
permit number was changed co WQ0000739. to March 1993, the Division
renewed this irrigation permit.
Because the wastewater reuse regulations had been promulgated
requiring considerable additional requirements, Cullasaja Joint
Venture objected to some of the conditions in the permit and to date,
this matter has not been settled.
None of the above permits required that the spray irrigation
facilities be used, and consequently no wastewater has been spray
irrigated to date.
In June of 1993, the discharge permit was renewed. As a special
condition (Part III E.) was added: "A discharge from this facility
Interchange Building, 59 Woodfin Place
Asheville, North Carolina 28801
Voice 704-251-6208
FAX [phone]
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Richard Melvin
April 29, 1997
Page Two
shall not be allowed except in cases when spray irrigation is not
usable." This condition was added because it promoted what appeared
on the surface to be environmentally the best method of wastewater
disposal. In actuality, the spray irrigation has not been "usable"
because of the non -discharge permit,requirements.
This brings us to the present. Last year, Cullasaja Joint
Venture requested that the spray irrigation requirement be removed
from the discharge permit for the following reasons:
1. The yearly average rainfall in Highlands for the
last forty odd years has been around 100 inches per
year. The maximum wastewater irrigation on the golf
course allowed by the permit is 1.75 inches per week,
total, and then only if no runoff could occur. The
result being that the amount of wastewater irrigation
allowed by the permit would be negligible.
2. The Cullasaja River drainage has become a water
supply source. Spray irrigation, because of the high
rainfall, could, in effect, become a discharge to the
Cullasaja.
it 3. Maintenance of the facilities for non -discharge
requires additional expense that is not warranted in
this case.
J
4. The discharge into Norton Mill Creek has not
caused any problems downstream. Mention of Norton
Mill Creek as "Use Threatened" because of
sedimentation in the basin plan has nothing to do
with the wastewater discharge. Both Cullasaja Club
and Highlands Falls have some development in this
drainage.
Please be assured that -the Division will continue to evaluate
this facility to determine if a more environmentally sound method
than discharge to the surface waters is possible. If you have
additional questions, please let me know. Forrest and/or I will be
happy to meet with you or your clients if you wish.
xc: Coleen Sullins
Darlene Kuchen
Sincerel
William E. Anderson
Environmental Specialist

July 27 , 1997
North Carolina Environmental Management Commission
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Norton Mill Creek Permit #NC0064416
Gentlemen:
This is to request a public hearing on the renewal of the above
permit. We understand that a permit and resolution was issued in 1992
satisfactory to the "Friends of Norton Mill Creek, but the conditions
of the permit were changed by the Department without notice to the
property owners or the community, and it appears that little or no
good faith effort has been made to comply with the original requirements,
but rather to avoid them.
The "Friends of Norton Mill Creek" hoped that this would become
a "test case" for good water management practices. One of the issues
is diversion from a different watershed and the natural flow of water.
Additional comments:
Yours truly,
ec-ftThref- r--7-
�C? a9Ls7.
/3,
/2./--- 45 Atk 6,J7
t2e- r2/t

July Z7 , 1997
North Carolina Environmental Management Commission
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Norton Mill Creek Permit #NC0064416
Gentlemen:
This is to request a public hearing on the renewal of the above
permit. We understand that a permit and resolution was issued in 1992
satisfactory to the "Friends of Norton Mill Creek, but the conditions
of the permit were changed by the Department without notice to the
property owners or the community, and it appears that little or no
good faith effort has been made to comply with the original requirements,
but rather to avoid them.
The "Friends of Norton Mill Creek" hoped that this would become
a "test case" for good water management practices. One of the issues
is diversion from a different watershed and the natural flow of water.
Additional comments:
M.“ Dom{ ion
7)CcLO
aas
Yours truly,
Address:
if2)-- Address:
Alt ..z'7717
,7v/vc&e„geo -.,a,c,0(11
7kJ al ig
„,,,4 fe aw5k/
s)v-)

July z/ , 1997
North Carolina Environmental Management Commission
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Norton Mill Creek Permit #NC0064416
Gentlemen:
This is to request a.public hearing on the renewal of the above
permit. We understand that a permit and resolution was issued in 1992
satisfactory to the "Friends of Norton Mill Creek, but the conditions
of the permit were changed by the Department without notice to the
property owners or the community, and it appears that little or no
good faith effort has been made to comply with the original requirements,
but rather to avoid them.
The "Friends of Norton Mill Creek" hoped that this would become
a "test case" for good water management practices. One of the issues
is diversion from a different watershed and the natural flow of water.
Additional comments:
7eae;_/.5F4

July 21 , 1997
North Carolina Environmental Management Commission
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Norton Mill Creek Permit #NC0064416
Gentlemen:
This is to request a public hearing on the renewal of the above
permit. We understand that a permit and resolution was issued in 1992
satisfactory to the "Friends of Norton Mill Creek, but the conditions
of the permit were changed by the Department without notice to the
property owners or the community, and it appears that little or no
good faith effort has been made to comply with the original requirements,
but rather to avoid them.
The "Friends of Norton Mill Creek" hoped that this would become
a "test case" for good water management practices. One of the issues
is diversion from a different watershed and the natural flow of water.
Additional comments:
Yours truly,
Address:
6Ps &vier' Zetc-impp
Address: 2 6 .712
% 0 &/
F.�Y- 3 3

• (Exhibit a)
19 EAST MAIN STREET
P.O. BOX 108
FRANKLIN. N.C. 28734
TEL [phone]
RICHARD S. JONES. JR.
BOBBY J. KEY
RICHARD MELVIN
LAWRENCE M. PATTON. JR.
JOSEPH D. JOHNSON
RUSSEU. R. BOWLING
CHESTER M. JONES
GILBERT RUSSELL KEY t1
JONES, KEY, MELVIN & PATTON, P.A.
ATTORNEYS AND COUNSELORS AT LAW
January 9, 1986
Mr. Arthur Mouberry, P.E.
North Carolina Division of Environmental Management
P.O. Box 27687
Raleigh, North Carolina 27611
Re: NPDES-NC0064416
SOUTH FOURTH STREET
P.O. BOX 609
HIGHLANDS. N.C. 25741
TEL 704-52S-3762
PLEASE REPLY TO:
GEO. A. JONES 1070-1903
Q LYLE JONES 1906.1920
GIUMER A. JONES 1918.1963
RICHARD S. JONES 192:4972
Dear Mr. Mouberry,
In the above matter, we renew our request of December 11, 1985
addressed to your office for an extension of time in which to submit
comments, for a public hearing, and for reconsideration by your
department of the application on the following grounds:
1) Application not properly advertised for public notice in
Jackson Ibunty. .
2) Policy reasons set forth in attached letter to U.S. Forest Service.
3) Adverse impact and pollution on private lands of our clients
located on and near Norton Mill Creek, including alteration and increase of
natural stream flow and preemption of development potential on downstream
lands if proposed discharge limits stream capacity.
Other reasons may be assigned upon final review of the file.
We further request that the file in NC-0059161 be reviewed for the
above reasons and particularly with reference to whether proper notice
was published in Jackson County in that application.
Please keep our office fully advised of all actions taken in this
file.
Yours truly,
JONES, KEY, MELVIN, & PATTON
Richard Mblvin

COMMISSIONERS OF JACKSON COUNTY
Sylva, North Carolina 28779
WAYNE HOOPER
COMMISSIONER OF FINANCE
ROBERT BLANTON
VERONICA NICHOLAS
PART•TIME COMMISSIONERS
Ph: [phone]
Mr. Richard Phillips
North Carolina Department of Natural
Resources and Community Development
Asheville, North Carolina 28802.
Dear Mr. Phillips:
DARLENE FOX
COUNTY ACCOUNTANT
W. PAUL HOLT, JR.
COUNTY ATTORNEY
""- July 8, 1986
� •
t ..
LPN IISIAE\11t.E
At our Regular Meeting of the Jackson County Board of Commissioners on
Monday, July 7, 1986, a group of residents from the Whiteside Cove Community
J
of Jackson County came to express their concern over the permit to discharge
150,000 gallons per day into Norton Mill Creek.
I learned at that meeting that approximately 600 acres of land would be
developed. Practically all of the development is on the northwest side of the
Eastern Continental -Divide. The sewage would be collected and pumped across
the Divide, treated and discharged into Norton Mill Creek, a tributary of the
Chattooga River which becomes the Savannah and is the state line between Soutt
Carolina and Georgia. The development is on the headwaters of the Cullasaja
River, which is one of the streams that forms the Tennessee River and empties
into the Ohio River at Paducah, Kentucky. The 55 million gallons annually may
not make a great difference in Hartwell or Clark Hill Reservoirs or the loss
of that amount may not be noticed in the lake level at Fontana and other TVA
projects but it is a significant change in a very delicate balance of nature
in the area where the development will occur. Additional development could
result in extension of collection lines and with the pump station capacity
increased one stream could dry up and the other could double in size.
I am aware or the•NRCD policy of not diverting water from one tributary to
another and this appears to be in direct conflict to that policy. Therefore
the Commissioners of Jackson County respectfully request that you consult
with the Environmental Management Division and request that a hold or delay
be placed on Permit #NC0064416 until a study can be made to determine the
impact this will have on the balance of nature as it relates to streams in
that area.
Sincerely,
Wayne Hooper, Chairman
Jackson County Commissioners
cc: 1r. Aurthur Mouberry, Raleigh, North Carolina
Ms. Betty Gene Alley, Highlands, North Carolina

PUBLIC NOTICE.
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
POST OFFICE BOX 29535.
RALEIGH, NORTH CAROLINA 27626-0535
NOTIFICATION OF INTENT TO ISSUE A STATE NPDES PERMIT
On the basis of thorough staff review and application of Article 21 of Chapter 143, General Statutes of
North Carolina, Public Law 92-500 and other lawful standards and regulations, the North Carolina
Environmental Management Commission proposes to issue a permit to discharge to the persons listed
below effective 8/18/97 and subject to special conditions.
Persons wishing to comment upon or object to the proposed determinations are invited to submit same in
writing to the above address no later than 8/1/97 . All comments received prior to that date will be
considered in the formulation of final determinations regarding the proposed permit. A public meeting may
be held where the Director of the Division of Environmental Management finds a significant degree of
public interest in a proposed permit.
•
A copy of the draft permit is available by writing or calling the Division of Environmental Management,.
P.O. Box 29535, Raleigh, North Carolina 27626-0535, [phone].
The application and other information may be inspected at these locations during normal office hours.
Copies of the information on file are available upon request and payment of the costs of reproduction.
All such comments or requests regarding a proposed permit should make reference to the NPDES permit
number listed below.
Date
JUN 2 5 1991 tbk4r1.4 4.
A. Preston Howard Jr., P.E., Director
L17Y'✓Division of Environmental Management •
Public notice of intent to issue a State NPDES permit to the following:
1. NPDES No. NC0037711. VZTOP Homeowners Association, Inc., P. O. Box 1709, Highlands, N.
C. 28741 has applied for a permit renewal for a facility located at VZTOP Homeowners Association, Inc.,
on NCSR 1616, southwest of Highlands, Macon County. The facility discharges 0.028 MGD of treated
domestic wastewater from one outfall into Brooks Creek, a Class B-Trout stream in the Savannah River
Basin which has a 7Q10 flow of 0.60 cfs. For some parameters, the available load capacity of the
immediate receiving water will be consumed. This may affect future water quality based effluent .
limitations for additional dischargers within this portion of the watershed.
2 NPDES No. NC0061123. The Mountain, Post Office Box 1299, Highlands, NC 28741 has applied
for a permit renewal for a facility located at Highlands Camp and Conference Center, 841 NC Highway
106, southwest of Highlands, Macon County. The facility discharges 0.006 MGD of treated domestic
wastewater from one outfall into Abes Creek, a Class C-Trout ORW stream in the Savannah River Basin
which has a 7Q10 flow of 0 cfs and a 30Q2 flow of 0.09 cfs. Dissolved oxygen is water quality limited.
For some parameters, the available load capacity of the immediate receiving waters will be utilized, and
more stringent water quality based effluent limitations may be established for dischargers downstream.

3. NPDES No. NC0061930. Mark Laurel Homeowner's Association, PO Box 375, Highlands, NC
28741 has applied for a permit renewal for a facility located at Mountain Laurel Subdivision, off NC
Highway 106, west of Highlands, Macon County. The facility discharges 0.042 MGD of treated
domestic wastewater from one outfall into East Fork Overflow Creek, a Class C-Trout ORW stream in the
Savannah River Basin which has a 7Q10 flow of 0.1 cfs. For some parameters, the available load
capacity of the immediate receiving water will be consumed. This mayaffect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
4. NPDES No. NC0064416. Cullasaja Joint Venture, PO Box 1432, Highlands, NC 2874] has applied
for a permit renewal for a facility located at Cullasaja Joint Venture, east of the intersection of US
Highway 64 & NC Highway 28, northeast of Highlands, Jackson County. The facility discharges 0.150
MGD of treated domestic wastewater from one outfall into Norton Mill Creek, a Class C-Trout stream in
the Savannah River Basin which has a 7Q10 flow of 0.14 cfs. For some parameters, the available load
capacity of the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.

5
BUNCOMBE COUNTY p
pss.
NORTH CAROLINA p
PUBLIC NOTICE
STATE OF
_NORTH CAROLINA
ENVIRONMENTAL -
MANAGEMENT
COMMISSION
Post -Office Box 29535
Raleigh, NC27626-0535
NOTIFICATION OF
INTENT TO ISSUE A
STATE NPDES PERMiT.
On the basis of 'thorough
staff• review and applica-
tion of Article 21 of Chap-
ter 143, General Statutes of
North Carolina, Public
Law 92-500 and other law-
ful standards and regula-
tions,- the• North Carolina.
Environmental Manage-•
ment Commission propos-
es to issue a permit to dis-
chargeto:the persons list-
ed. below effective 8/18797
and subject to special con-
ditions_
Persons wishing to com-
ment upon or object to the
proposed determinations
are Invited to submit same
in writing to the above ad-
dress no later than 8/1/97.
All comments received
prior to that date will be
considered in the formula-
tion of final determination
regarding the proposed
permit. A public meeting
may be held where the Di-
rector of the Division of
Environmental Manage-
ment finds a significant de-
gree of public interest in a.
Proposed permit. A copy of the draft permit
is available by writing or
calling the Division of En-,;
viranmentet Management,
P.O. Box 29535, Raleigh,'
North Carolina 27626-0535,
[phone].
The application and other.
information may oe in-
spected et these locations
'during normal• office
hours. Copies of the infer
;matron on file 'are avail-
able upon request and Pay-
ment of the costs of repro-
duction. All such • com-
ments or. requests regard-
ing a proposed permit
shoule make reference` to
the NPDES. permit num-
ber listed below..,
Date June 25, 1997
David A_ Goodrich
A. Preston Howard; Jr.
P.E. Director --
Division of
. Environmental Mgmt
Public notice of •intentto
issue a State NPDES per-
mit to the following:
1. NPDES-No. NC00.3771I`
VZTOP Homeowners. As-
sociation,. Inc:, P.O.' Box.
1709, Highlands, N.C.28741,
hos applied for a permit.
renewal fora facility locot�:
ed at VZTOP Homeowners
Association,. Inc.. on NCSR.
1616, southwest of High;'
lands, Macon County. The
facility discharges 0.028
`MGD of treated domestic -
,wastewater from one out -
fall into Brooks Creek,- a-
Class B-Trout stream..in
the Savannah River Basin:
which has a 7Q10 flow of
0.60 cis. For some parame-
ters, the available load ca-
pacity of the immediately
receiving water wilt -be'
consumed. This may affect
future water quality based;.
- effluent limitations for ad-'
AFFIDAVIT OF PUBLICATION
_Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified
and authorized by law to administer oaths,
personally appeared Katrina Petrey
Who, being first duly sworn, deposes and says:
that he (she) is LEGAL BILLING CLERK
of ASHEVILLE CITIZEN TIMES COMPANY,
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 he (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
dates: July 1, 1997.
and that the said newspaper in which said
notice, paper, document or legal advertisement
was published was, at the time of each and
every publication, a newspaper meeting all of
the requirements and qualifications of Section
1-597 of the General Statutes of North Carolina
and was a qualified newspaper within the
meaning of Section 1-597 of the General
Statutes of North Carolina.
This —o Jul
(Signet re of person making affidavit)
Sworn to and subscribed before me
The ! rd o f J 1 7
Luce
(Notary Public)
My Commission expires: October 24, 2001

Sworn to and subscribed before me
ing o proposed permit
shoule make reference 10
trm NPDES permit num-
ber listed below.
Date June 25, 1997
David A. Goodrich
A. Preston Howard, Jr.
P.E. Director
Division of
Environment • I Mgmt
Public tice o •intent to
issue a to DES per-
mit to the N ing:
1. NPDES �t\NC0037711.
VZTOP Ho - ners •As-
soclation,•Jfc., O. Box
1709, High • ds, .-:28741
has appli + • for a permit
renewal fa a facility locat-
ed at VZT• P Homeowners
Assoclation,-Inc., on NCSR
1616, southwest of High-
lands, Macon County. The
facility discharges 0.028
MGD of treated domestic
wastewater -from one out -
fall into Brooks Creek, a
Class B-Trout stream in
the Savannah River Basin
which has a 7Q10 flow of
0.60 cfs. For some parame-
ters, the available Toad ca.
Pacify of the immediately
receiving water will be
consumed. This may affect
future water quality based
effluent limitations for ad-
ditional dischargers within
this portion of the water-
shed.
2. NPDES No. NC0061123.
The Mountains, Post Of-
fice Box 1299, Highlands,
NC 28741 has applied for a
Permit renewal for 0 facili-
ty located at High -lends
Camp and Conference Cen-
ter, 841 NC Highway 106,
southwest of Highlands,
Macon County. The facility
discharges 0.006 MGD of
treated domestic wastewa-
ter from one outfall into
Abes Creek, a Class C—
Trout ORW stream in the
Savannah 'River. Basin
which has a 7Q10 flow of 0
cfs and a 30Q2 flow of 0.09
cfs. Dissolved oxygen is
water quality lid. For
some parameters, the
available load capacity of
the immediate receiving
waters will be utilized, and
more stringent water qual-
ity based effluent limita-
tions may be established
for dischargers down-
stream.
3. NPDES No. NC0061930.
Mork Laurel Homeown-
er's Association, PO Box
375, Highlands, NC 28741
has applied for a permit
renewal fora facility locat-
ed at Mountain Laurel
Subdivision, off NC High -
Way 106, west of High- ' •
lands, Macon County. The
facility discharges 0.042
MGD of treated domestic
wastewater from one out -
fall into East Fork Over-
flow Creek, a Class C--
Trout ORW stream In the
Savannah River Basin
Which has a 7Q10 flow of
0.1 cfs. For some parame-
ters, the available load co•
pacify of the immediate re-
ceiving water will be con-
sumed. This may affect fu-
ture water quality based
effluent limitations for ad-
ditional discharges within
this portion of the water-
shed.
4. NPDES No. NC0064416.
Cullasaia Joint Venture,
PO Box 1432, Highlands,
NC 28741 has applied for a
permit renewal fora facili-
ty located at Cullasaia
ntie sectionrofUS High
• way 64 & NC Highway 28,
northeast of Highlands,
Jackson County. The facil-
ity discharges 0.150 MGD
of treated domestic waste-
water from one outfall into
Norton Mill Creek, a Class
C-Trout stream in the So-
vannah River Basin which
has a 7Q10 flow of 0.14 cfs.
For some parameters, the
available load capacity of
the immediate receiving
water will be consumed.
This may affect future wo•
ter quality based effluent •
limitations for additional
dischargers within this
portion of the watershed.
July 1, 1997
(7122)
The �rd of July
_OLP
(Notary Public)
My Commission expires: October 24, 2001

A
•
PUBLIC NOTICE ' ;
STATE OF NORTH CAROLINA
ENVIRONMENTAL
MAN
AGEMENT. ••
COMMISS•
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 27626.0535
'NOTIFICATION OF INTENTTO ISSUE A
STATE NPDES PERMIT
On the basis of thorough staff review and
.application of Article 21 of Chapter 143)
• General Statutes. of North Carolina, Public :
Law 92-500 and Other lawful standards and
regulations, the :North Carolina Environ-
mental Management Commission proposes
to issue a permit to discharge to the per-
sons listed below effective 8/18,97 and sub-
ject to special conditions.
Persons wishing to comment upon or
object to the proposed determinations are
Invited to submit same in writing to the
above address no later than 8/1/97. All com-
ments received prior to that date will be
considered In the formulation of final deter-
nhinations regarding the proposed permit. A
public meeting may be held where the
Director of the Division of Environmental
• Management finds a significant degree of
public Interest In a proposed permit. •
A copy of the draft permits available by
writing or calling the Division of.Environ-
mental Management, P.O. Box 29535,
Raleigh, North , Carolina 27626-0535, (919)
733-7015. • . - . • . ;
•
The application and other 'information
may be inspected at these locations during
normal office hours. Copies of the informa-
tion on file are available upon request and
payment of the costs of reproduction.
All such Cp pernts mit should make reference
a proposedpe
to the NPDES permit number•ilsted betow.
_'Date June 25,1997 •-. • ••.
•
A. Preston Howard jr., P.E. DtrectOr
• • for Division of Environmental
Management '
'Public notice of intent to Issue a State
NPDES permit to the following:
- 1. NPDES No. NC0064416. Cullasaja Joint
Venture, PO Box 1432, Highlands, NC 28741 •
has applied for a permit renewal for a facili-
ty located at Cullasaja Joint Venture, east of
the intersection of US Highway 64 & NC
Highway ' 28, northeast of Highlands, ,
Jackson County. The facility discharges
0.150 MOD of treated domestic wastewater ,
from one outfall Into Norton Mill Creek, a
Class C-Trout stream in the Savannah River
Basin which has a 7010 flow of 0.14 cfs. For !
sonic parameters, the available load capac-
ity of the immediate receiving water will be
consumed. This may affect future water
quality based effluent limitations for addi-
tional dischargers within this portion of the
watershed. 13
NORTH CAROLINA
JACKSON COUNTY.
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified, and
authorized by law to administer oaths, personally
appeared
Qa zit"-
, who being
first duly sworn, deposes and says that he (she) is
(wit
(Owner, partner, publisher, or other officer or
employee authorized to make this affidavit)
of THE SYLVA HERALD, engaged in the publication
or a newspaper known as THE SYLVA HERALD,
published, issued, and entered as second class mail in
the City of Sylva, and said County and State; that he
(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 SYLVA HERALD on the following dates:
0141/
3 r 9 97
and that the said newspaper in which such notice,
paper, document, or legal advertisement was published
was, at the time of each and every publication, a
newspaper meeting all of the requirements and
qualifications of Section 1-597 of the General Statutes
of North Carolina and was a qualified newspaper
within the meaning of Section 1-597 of the General
Statues of North Carolina.
This L day of
,197
C�LL ,dt�.y
(Signature of person making affi , i Y
Sworn to a s subs bed before e, this
day of
19Z1
Notary ' c
My Commission expires:
l

0"
y '
THE SYLVA HERALD PUBLISHING CO.INC.
Post Office Box 307
SYLVA, NC 28779-0307
INVOICE # 3568 PAGE 1 of 1
DEHNR♦ WATER QUALITY DIV.
Att: Frances Cotten (DWQ )
P.O. Box 29535
RALEIGH NC 27626-0535
AUGUST 08, 1997
DATE QUANTITY TYPE DESCRIPTION CHARGE TAX AMOUNT
07/03/97 64.00 LINE 64-L-\13/NPDES PERMIT $49.92 $0.00 $49.92
Total Sales Tax: $0.00
Total Charge - : $49.92
THIS INVOICE IS FOR YOUR RECORDS
THE AMOUNT AT THE RIGHT IS INCLUDED IN YOUR REGULAR STATEMENT:----( $49.92
Cl''`EnNfr"t-
AUG 1.11997
Wilu BUDGE; •JrylvF
r111-
D:3_ AUG2 1 �199Z__.�_
TERMS: PAYABLE ON RECEIPT
Balance unpaid by the 25th of this month will be included in next month's bill.
Call us at [phone] if there is a problem with this statement.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B, Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Asheville Regional Office
DEHNR
WATER QUALITY SECTION
April 29, 1997
Mr. Richard Melvin
Jones, Key, Melvin, & Patton, P.A.
Professional Building, Suite 3
South Street
Highlands, North Carolina 28741
Dear Mr. Melvin:
The following should bring you up to date on the wastewater
situation at Cullasaja Joint Venture. As you know, the permits are
to be renewed this year.
The decision to allow a discharge from the Cullasaja Joint
Venture wastewater treatment facility to Norton Mill Creek was
confirmed by the original permit (NC0064416) issued in 1986. The
actual "decision" was made by the North Carolina General Statutes and
subsequent regulations of the Division. This permit did not mention
spray irrigation.
In July of 1988, the Division issued Permit Number 16529
thereby allowing spray irrigation of treated wastewater on the golf
course. In February 1989, this irrigation permit was modified to
require chemical monitoring of the wastewater. At this time, the
permit number was changed to WQ0000739. In March 1993, the Division
renewed this irrigation permit.
Because the wastewater reuse regulations had been promulgated
requiring considerable additional requirements, Cullasaja Joint
Venture objected to some of the conditions in the permit and to date,
this matter has not been settled.
None of the above permits required that the spray irrigation
facilities be used, and consequently no wastewater has been spray
irrigated to date.
In June of 1993, the discharge permit was renewed. As a special
condition (Part III E.) was added: "A discharge from this facility
Interchange Building, 59 Woodfin Place
Asheville, North Carolina 28801
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NOC
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J
Richard Melvin
April 29, 1997
Page Two
shall not be allowed except in cases when spray irrigation is not
usable." This condition was added because it promoted what appeared
on the surface to be environmentally the best method of wastewater
disposal. In actuality, the spray irrigation has not been "usable"
because of the non -discharge permit requirements.
This brings us to the present. Last year, Cullasaja Joint
Venture requested that the spray irrigation requirement be removed
from the discharge permit for the following reasons:
1. The yearly average rainfall in Highlands for the
last forty odd years has been around 100 inches per
year. The maximum wastewater irrigation on the golf
course allowed by the permit is 1.75 inches per week,
total, and then only if no runoff could occur. The
result being that the amount of wastewater irrigation
allowed by the permit would be negligible.
2. The Cullasaja River drainage has become a water
supply source. Spray irrigation, because of the high
rainfall, could, in effect, become a discharge to the
Cullasaja.
3. Maintenance of the facilities for non -discharge
requires additional expense that is not warranted in
this case.
4. The discharge into Norton Mill Creek has not
caused any problems downstream. Mention of Norton
Mill Creek as "Use Threatened" because of
sedimentation in the basin plan has nothing to do
with the wastewater discharge. Both Cullasaja Club
and Highlands Falls have some development in this
drainage.
Please be assured that the Division will continue to evaluate
this facility to determine if a more environmentally sound method
than discharge to the surface waters is possible. If you have
additional questions, please let me know. Forrest and/or I will be
happy to meet with you or your clients if you wish.
xc: Coleen Sullins
Darlene Kuchen
Sincerel
WilliamE. Anderson
Environmental Specialist

.03/04/1997 15:41 7042516452
PAGE 02
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Wafer Quality
Jaynes B, Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr.. P.E. Director
Asheville Regional Office
• WATER QUALITY SECTION
March 4, 1997
MEMORANDUM
TO: Jeff Myhra
THROUGH: Forrest R_ Westall
Coleen Sullins
FROM: William E. ,Anderson
AIP.WA
F1NIF
SUBJECT: NPDES Permit NC0064416 Renewal
Cullasaja Joint Venture
Jackson. County
ff
41AA'ilc')
4,64, 1"),,,Z)
�1 ffw' ci.b du ")
We are in the process of rescinding the spray irrigation
permit (NC0064416) for Cullasaja Joint Venture. If (when)
the spray irrigation permit is rescinded, it will be
appropriate to remove the language in the discharge permit
requiring spray irrigation. Please hold the NPDES Permit
renewal until we are sure of the spray irrigation permit
outcome.
If you have questions, please let me know.
Interchange Building, 54 Woodfln Place
Asheville, North Carolina 28801
Voice 704-251-6208
FAX [phone]
An Equal Opportunity/Affirrnative Action Employer
50% recycles/ 10% post -consumer paper
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NC0064416
Facility: Cullasaja Joint Venture
Discharge to: Norton Mill Creek
Stream class and index #: C - 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 0.6 :1
Ammonia as NH3
(summer)
0.14 7010 (CFS) 0.14
0.15 DESIGN FLOW (MGD) 0.15
0.2325 DESIGN FLOW (CFS) 0.2325
17.0 STREAM STD (MG/L) 1.0
0 UPS BACKGROUND LEVEL (MG/L) 0.22
62.42 IWC (%) 62.42
27.24 Allowable Concentration (mg/I) 1.47
minimum = 2
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/l)
0.18
0.15
0.2325
1.8
0.22
56.36
3.02
minimum = 4

• Staff Review and Evaluation
NPDES Wastewater Permit
FACILITY INFORMATION
Facility Cullasaja Joint Venture
NPDES No. NC0064416
Design Flow (MGD) 0.15 MGD
Facility Class III
0 m011.4kJ
STREAM CHARACTERISTICS
Stream Name Norton Mill Creek
Stream Class C-TR+
Sub -basin 03-13-01
Drainage Area (mi2) 0.49
S7Q10 (cfs) 0.14
W7Q10 (cfs) 0.18
30Q2 (cfs) 0.35
IWC (%)
1.''-• ��#?�O.
:.......?'azameters AffeCtOd
Basis for cyan e(s) .:.:� :>
Permit Cover Sheet
Added Part 1V reference
Not part of previous permit
Effluent Limitations Page
Combined winter and summer
limits into one effluent page
To make permit easier to read
Part III
Deleted Special Condition E.
Spray Irrigation system was
found to be insufficient. See
discussion below.
Effluent Limitations Page
Changed temperature
monitoring from 3 / Week to
Daily
As per 2B.0500 Rules
Effluent Limitations Page
Changed TRC monitoring from
Daily to 3 / Week
As per 2B.0500 Rules
Compliance Schedule: n/a
Special Condition(s): n/a
Permits & Engineering Comments:
The permit was drafted with existing limits but the method of discharge specified in existing permit
has been changed. A memo prepared by Bill Anderson, of ARO, was received on March 4, 1997 in
reference to changing the mode of discharge for the subject facility. The memo stated that procedures
had begun to rescind the spray irrigation permit. The memo went on to say that once this procedure took
place, the special condition in the existing permit requiring the facility to use spray irrigation would be
deleted.
A supplementary memo, prepared by Bill Anderson, was received on March 27,1997 confirming that the
special condition in the existing permit requiring the facility to use spray irrigation should be deleted.
A letter was attached to this memo from the facility explaining why spray irrigation is no longer
feasible at the subject facility. The following explanation was included in the cover letter "Due to the
high rain fall of approximately eighty to one hundred inches annually, our irrigation system is never
operated on a regular basis. Our most significant use occurs during the months of May and June, when the
evaporation rate is at its highest. Additionally, there is minimal usage during the months of July
through October. For the remainder of the year, being November through April, the system is
completely closed down. Our full operating procedure provides for a daily use of 200,000 gallons of
effluent. On average, we are only at full operating procedure 30 to 45 times annually." Based on this
information and upon a detailed review, the special condition requiring the use of spray irrigation was
deleted thus allowing the permittee to discharge directly into Norton Mill Creek.

,Staff Review and Evaluation
NPDES Wastewater Permit
Page2of2
Norton Mill Creek is included in the ORW management plan for the Chattooga River, but has a
Poor -Fair index of biotic integrity (NCIBI) based on a fish community assessment. In addition,
the stream received a benthic classification of Good -Fair. j [orton Mill Creek is currently rated
Partially Supporting based on monitoring data from 1990-1994. The probable causes of
impairment are sedimentation and nutrients.
Norton Mill Creek may be given high priority for NPS Team action. These efforts should allow
the causes and sources of impairment to be identified and corrected.
It is recommended that the permit be renewed as drafted.
Prepared by:
69 Regional Office Evaluation and Recommendations: Y

4•r
A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1 - October 3.1) Permit No. NC0064416
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 belimited and monitored by the permittee as specified below:
Effluent Characteristic. Discharge Limitations
Monthly Avq
Flow 0.150 MGD
BOD, 5 day, 20°C 30.0 m g / I
Total Suspended Residue 30.0 m g / I
NH3asN 1.5 mg/I
Dissolved Oxygen**
Fecal Coliform (geometric mean) 200.0 /100 mi
Total Residual Chlorine
Temperature "•
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Weekly Avq. Daily Max
45.0 mg/I
45.0 mg/I
400.0 /100
27.0 ug/I
Monitoring
Measurement
Frequency
Continuous
3/Week
3/Week
3/Week
3/Week
ml 3/Week
" ,Daily' 3/47r4
• Wee �`.`1 /
Semi-annually/
Semi-annually
Requirements
SamDIQ "Same,
Type Locatlq
Recording ( I or E
Composite - E
C site�1 E
Cite t E
Grab E
Grab E
Grab E
Grab E
Composite``�� E
Co siterfr E
*Sample locations: E - Effluent, I - Influent
**The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/1.
***The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 0.5°C and
in no case cause the ambient water temperature to exceed 20°C.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 3/weekly at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. ( ). EFFLUENTLIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NC0064416
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 Characteristic Discharge Limitation!
Monthly Avg
Flow 0.150 Neo
BOD, 5 day, 20°C 30.0 m g / I
Total Suspended Residue 30.0 m g / I
NH3asN 3.0 mg/1
Dissolved Oxygen ••
Fecal Coliform (geometric mean) 200.0 /100 ml
Total Residual Chlorine
Temperature •••
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Weekly Avg.
Monitoring
Measurement
Daily Max Frequency
Continuous
45.0 mg/I 3/Week
45.0 rng/I 3/Week
3/Week
3/Week
400.0 /100 ml 3/Week
27.0 ug/I Daily 3/l,/
3/Week NrV/Y.
Semi-annually
Semi-annually
/ 9
Requirements
Sampl@ .*Sampl
Type Locatlo
Recording y�
Composife
Compesiie/,
Cornpt5site�„, ,
Grab
Grab
Grab
Grab
Co p osit
Compgsit
I or E
E
E
E
E
E
E
E
E
*Sample locations: E - Effluent, I - Influent
**The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/I.
***The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 0.5°C and
in no case cause the ambient water temperature to exceed 20°C.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 3/weekly at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
.,