NC0065358_staff comments_19920806

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
Winston-Salem Regional Office
Water Quality Section
August 6, 1992
MEMORANDUM
TO: Colleen Sullins
Permits and Engineering
THROUGH: Steve Mauney
FROM: Mike Mickey
SUBJECT: Hidden Forest Estates MHP
Engineering Economic Analysis
Permit No. NC0065358
Randolph County
2
DEM recently reissued the above permit to Hidden Forest
Estates Mobile Home Park (HFMHP) with an effective date of
4-13-92. The permit (Part III.D) required HFMHP to submit an
engineering study evaluating alternatives to a surface water
discharge on or before 5-15-92. The study was necessary due to
the fact that the system discharges into a zero flow stream and
has caused water quality problems in pond located 1000 feet
downstream of the outfall.
The engineering report was submitted by Mr. Dennis Herzing,
Research and Analytical Laboratories on 7-20-92. The report
concluded that the least costly alternative would be "to upgrade
the existing treatment plant continue to discharge at the present
location". The upgrade (approximately $65,500) could include
effluent sand filters, dechlorination and a chemical feed system
for nutrient removal.
Unfortunately, the study did not adequately address possible
problems with the pond should they continue to discharge
upstream, except to mention that it "complicates this particular
project". It is WSRO's opinion that Stewart's pond would
continue to suffer adverse water quality impacts as long as the
0.027 MGD package plant discharges upstream. It is relevant to
note that recent fish kills and algae blooms have continued to
occur in the pond even when self monitoring data (1/92 - 6/92)
shows an average effluent BOD of 6.4 mg/1 and an average NH3-N of
1.1 mg/1. Obviously, the proposed 5 mg/1 BOD and 1 mg/1 summer
limits would provide little improvement.

Page #2
It is recommended that effluent pipe be relocated around the
pond to discharge below the dam in order to protect Mr. Stewart's
pond. HFMHP should be required to revise the engineering study
to address this option. Obviously, upgrading of the system would
still be necessary since the stream flow would most likely still
be zero.
In order to provide proper guidance to HFMHP concerning the
study, WSRO needs clarification on two issues from the Central
Office. The first is if DEM can legally require HFMHP to
relocate the discharge due to the pond, or do they have the
option to attempt to meet the proposed 5 mg/1 BOD and 1 mg/1
NH3-N limits at the existing location beginning March 1, 19931
The second is if HFMHP agrees to move the outfall below the pond,
can DEM allow a WWTP to relocate their discharge from one zero
flow location to another?
Any comments you could provide concerning these questions
would be appreciated.
cc:
Steve Tedder
Charles Lowe
Ruth Swanek
Central Files
WSRO

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North Carolina Department of Natural
Resources &Community Development

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27626-0535
James G. Martin, Governor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary
Director
April 13, 1992
Mr. Dewey W. Chapple, Jr., Partner
Hidden Forest Estates, A N.C. General Partnership
Post Office Box 15432
Winston-Salem, N.C. 27113
Subject: NPDES No. NC0065358
Hidden Forest Estates MHP
formerly issued to
Mr. Richard M. Scheid
Randolph County
Dear Mr. Chapple:
In accordance with your request received November 18, 1991, we are forwarding
herewith the subject permit now issued to Hidden Forest Estates, A N.C. General Partnership.
The only changes in this permit are in name and ownership as well as update the permit to current
DEM regulations. This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S.
Environmental Protection Agency dated December 6, 1983.
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 take notice 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.
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Page Two
Mr. Chapple
This permit does not affect the legal requirement to obtain other permits which may be
required by the Division of Environmental Management 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.
If you have any questions or comments concerning this permit, please contact Charles M.
Lowe at [phone].
Sincerely,
George T. Everett
'Director
cc: Central Files
Compliance
Mr. Jim Patrick, EPA
Technical Support Branch
Winston-Salem Regional Office
Mr. F. Roger Page, Jr.
Mr. Morris Crafton
Mr. Richard C. Scheid

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
November 7, 1990
MEMORANDUIVM
TO: NPDES Permit Holders
FROM: Steve Tedder
Water Quality section Chief
SUBJECT: NPDES Effluent Limitations
George T. Everett, Ph.D.
Director
The Division of Environmental Management has recently received a number of questions
about limitations in NPDES permits. Many permit holders do not understand how or why their
permit limitations can change. For your information, I have enclosed a brief explanation which
should help explain some of the factors affecting permit limitations. Also included are some
reasons why these limitations may change.
If you have any questions on this matter, please do not hesitate to contact Mr. Don Safrit
of the Permits staff or Mr. Trevor Clements of the Modeling staff at 919T733-5083.
Enclosure
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

9
FACTORS AFFECTING WASTE LOAD ALLOCATIONS
Over the past decade North Carolina has experienced rapid population growth and
industrial development. With this growth has come more jobs and better housing
opportunities. This prosperity has also brought an increasing demand on our
State water's as locations for wastewater discharges. These waters are a
resource with only limited capacity to accept wastewater. Additional discharges,
in many cases, result in a requirement for upgraded treatment by the existing
dischargers. This is an unfortunate side effect of our growth, but it is one that
. you must consider now, and throughout the life of your project.
Beginning on page three of your NPDES permit are the effluent limitations that
you are required to meet. These limitations were derived to protect the water
quality in your receiving stream under existing.conditions. The effluent limits
contained in your permit are usually effective throughout the term of the permit.
However, these limits can change during the term of the permit (usually five years)
if: (1) a crater quality concert: is documented in the receiving stream or, (2) the
federal guidelines change for facilities with limits based on effluent guidelines.
Effluent limits in the permit are also subject to change at the time of
reissuance of the NPDES Permit. This change can result from several factors, for
example: (1) more discharges in your immediate area, (2) an increase in total
permitted flow to your stream, (3) a change in the condition of your stream,
(4) an increase in our understanding of your receiving stream. If your limits
do change, you will be responsible for taking the action necessary to upgrade your
treatment facility to meet your nec.• effluent limits. As the Division becomes aware
of a change in the limitation of existing dischargers, we will provide you with as
much notice as is possible so that you can begin making plans to meet those new
limitations.