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HomeMy WebLinkAboutNC0067318_Permit Issuance_20060417 O�1N ATF Michael F.Easley,Governor `0 QG William G.Ross Jr.,Secretary rNorth Carolina Department of Environment and Natural Resources >_ Alan W.Klimek,P.E.Director Division of Water Quality April 17, 2006 Dr. Rodney Shotwell Macon County Schools P.O. Box 1029 Franklin, North Carolina 28744 Subject: NPDES Permit Issuance Permit No. NCO067318 Nantahala School WWI? Macon County Dear Dr. Shotwell: Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly,we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended). The permit authorizes Macon County Schools to discharge up to 0.002 MGD of treated wastewater and up to 0.003 MGD (upon rerating of the plant) from the Nantahala School WWTP to Partridge Creek, a class C-Trout water in the Little Tennessee River Basin. Upon receipt of an authorization to operate the facility can discharge up to 0.003 MGD. The permit includes discharge limitations/or monitoring for flow, biochemical oxygen demand (BOD), total suspended solids (TSS), ammonia and temperature. The following modification has been made in this final permit: ■ The addition of an effluent page for 0.003 MGD upon approval of re-rating from 0.002 MGD. 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, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits,which may be required by the Division of Water Quality, or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permits may be required. WCartrtMra a North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 Phone(919)733-7015 Customer Service Internet: www.ncwa=ualiLy.ora Location: 512 N.Salisbury St. Raleigh,NC 27604 Fax (919)733-2496 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer-50%Recycledl10%Post Consumer Paper Letter to Dr. Shotwell Page 2 If you have any questions or need additional information, please contact Ms. Jacquelyn Nowell at telephone number(919) 733-5083, extension 512. cerely,���. / /anW. Klimek, P.E. Attachments cc: Asheville Regional Office/Surface Water Protection Bob W. Deweese/Dept. of Public Instruction Permit File Central Files ' I t Permit NCO067318 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1,other lawful standards.and regulations promulgated and adopted by the North Carolina Environmental Management Commission,and the Federal Water Pollution Control Act,as amended,the Macon County Schools are hereby authorized to discharge wastewater from a facility located at the Nantahala School VUVUTP 212 Windingstairs Road, south of Fairview Macon County to receiving waters designated as Partridge Creek in the Little Tennessee River Basin in accordance with effluent limitations,monitoring requirements,and other conditions set forth in Parts I,II,III and IV hereof. This permit shall become effective June 1,2006. This permit and authorization to discharge shall expire at midnight on November 30,2007. Signed this day April 17,2006. . IVA W.Klimek,P.E.,Director ivision of Water Quality By Authority of the Environmental Management Commission Permit NCO067318 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. The Macon County Schools are hereby authorized to: 1. Continue to operate an existing 0.002 MGD extended-aeration wastewater treatment system with: ■ a primary clarifier tank ■ a holding tank ■ a recirculating sand filter, and ■ tablet chlorination/contact tank The facility is located at the Nantahala School WV'TP, south of Fairview off Windingstairs Road in Macon County. 2. Upon receiving an Authorization to Operate from the Division of Water Quality, treat up to 0.003 MGD of domestic wastewater, and 3. Discharge from said treatment works at the location specified on the attached map into Partridge Creek, a class C-Trout stream in the Little Tennessee River Basin. :• .� -'r'pm W°Rh Z+�XT �"�-�.-. '.iii�5::`;��j��aQ�� ;' ..' ,,r ;• �i;' y ,'• •) 107 ^ i( i r � /-> a �aP, `�1:=. �.•.-n 'tom.�� s"%R Wa Mom _ t... - - _ _ is ).� _ _ r•L J: t .��✓ �1.���� J 'f fJ{:� ���•`�'�it ii:,r _ \1 tit w •P,_v /~'•�rG'� i �^_. �_'� y'' — _ . - - �, �, -- - �- -" - "fir/ �_=:.- _- _; � - >__ ��•, •) i T. - V;�. . arga Poln z _ (JJ1\ :—� �l3+' ' 1 r• :. ..:4. __. '% c� o,;.J,r(♦ f�';;i �'.; sFunu—_ �� ,V� :,_-;= '. :. �/� �1` % '�-- 5 \\./•"7 �J`i��"\1-F� :I:J i• ' •.�:' A'� riOlma°.N. Iryg j •, EaoerALswrvrr,eesmx,viee o—ra+ �KYLEJ.9M/.` 3 37•30" Quad:Hewitt,N.C. NCO067318 Facility , Stream Class:C-Trout Location Subbasin:40403 NantahaLa School WWTP Latitude:35*15'10" Longitude:83°38'06" Receiving Stream:Partridge Creek North SCALE 1:21{000 1 t Permit NCO067318 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of this permit and lasting until rerating to 0.003 MGD,the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT LIMITS MONITORING REQUIREMENTS CHARACTERISTICS Monthly Daily Measurement Sample Type Sample Location Average Maximum frequency Flow 0.002 MGD Weekly Instantaneous Influent or Effluent BOD,5-day(200-C) 30.0 mg/L 45.0 mg/L Weekly Grab Effluent Total Suspended Solids 30.0 mg/L 45.0 mg/L Weekly Grab Effluent NHs as N 2/Month Grab Effluent Temperature(2C) Weekly Grab Effluent There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NCO067318 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning upon rerating to 0.003 MGD and lasting until expiration,the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Pemaittee as specified below: EFFLUENT LIMITS MONITORING REQUIREMENTS CHARACTERISTICS Monthly Daily Measurement Sample Type Sample Location Average Maximum Frequency Flow 0.003 MGD Weekly Instantaneous Influent or Effluent BOD,5-day(201C) 30.0 mg/L 45.0 mg/L Weekly Grab Effluent Total Suspended Solids 30.0 mg/L 45.0 mg/L Weekly Grab Effluent NHs as N 2/Month Grab Effluent Temperature(°C) Weekly Grab Effluent There shall be no discharge of floating solids or visible foam in other than trace amounts. 1 PUBLIC N( TICE NORTH CAROLINA d T 33 STATE OF Macon County NORTH CAR,OLINA • ivv�c� �ti.. � AFFIDAVITs,f P , GAME sw - OF PUBLICATION c slO� , f 'h1PDES UNIT 1617MAtL SERVICE •,TENTER Before the undersigned, a Notary Public of said County and State, RALEIGH NC 27699- duly commissioned,qualified, and authorized by law to administer oaths,personally appeared...................... NOTIFICATION OF s INTENT•TO.ISSUE A ; ......................................DOROTHY HA4LPIN.............................................. ,NPD9S WASTEWATER PERMIT• who is duly sworn,deposes and says: that she is On the basis of.thorough { } d lication , ............................Administrative Assistant....................................... ��revie , - S�f�,-�ter• F�p�•�� , ral� tote ofNC' 1 •i wa; (owner,partner,publisher,or other officer or employee authorized to make this affidavit) 143`: 1� Pul � vv2=500 and .other�lawful_, tan4lards of The Franklin Press,engaged in the publication of a newspaper known and xeula North S as TheFranklin Press published, issued and entered as second class t Carolinas' nvironmental x �, f .•r °,,,�T mail in the Town of Franklin,in said County and State that she is 1Vanagement t Commission.w,• authorized to make thisaffidavit and sworn statement;that the notice to-issue a National ,..proposes" - g copy, of which is attached hereto, pollutant =' Discharge or other legal advertisement a true limul►aon,; System was published in The Franklin Press on the following dates: I (NPDES)., wastewater ' s- : . •: March 2006 charge,: permit to.; the. erson(s)'listed'below effec- ........................ 7, tive 45 days rrom the.pu sh date:of this notice. and that the said newspaper in which such notice,paper,document,or f tteii comments•iggai'd' F� ! , �� r'• legal advertisement was published was, at the time of each and eve 4-�i he}-propose�ernut;will g P every •be: occe ted until :30 days such publication, a newspaper meeting all of the requirements and quali- ,rP to, after;the.publisla thi of s fications of Section 1-597 of the General Statutes of North Carolina notice. A11'� comments A and was a qualified newspaper within the meaning of Section 1-597 of received'-prior to at., are the General Statutes of North Carolina. r: onsidered t al:deter: c yin he fui , -_ ininations regarduig the pro-. This the 3rd d 2006 posed permit 'Ihe DiOct0r-0- •••••••••••••••• ay o April •,,,yam c.r: ;�.:,;.y,, .. the' -- vision ;of a ,dec de to:}hold.a ........................ . ... ...... ........ .... ............................................ ri �u ty, Y �? x public .etmg ti or he_pro ' Signature of rson m •ng affidavit 1 'posed p i, should the ,'Division receive a significant degree of public interest Copies of the draft:perinit j: Sworn to and subscribed before me...this...3rd and'other� uF_n rtin infor, ed r , :� d of........... l........ , 006. n� ao deter ay Apri .2con present r in the drafx permit are available u n request and.payment•of .. ....... ... ...................................................... po ...... the 1 cpsts of-Iseproducti6n Notary P blic ' Mail` . 'fco eiits � 'ann or fl. .� My commission expires:........... requests ,for,:informatio to . •• ..... .... ............` .......... ........ the NC. Di vi i 14 of,Water w u at� esabove address TAQ �,,�..Att ,� nt ..Sourceor:: ea11 e•. `'"ni:4V:at,-(4 91 733-5083, Macon County Schools P.O. Box 1029 Franklin, NC 28744 October 25, 2005 COT 3 1 2005 II Susan Wilson N.C.Division of Water Quality 1617 Mail Service Center Raleigh, N.C. 27699-1617 Dear Ms. Wilson: I have enclosed the correspondence dated August 17,2003 in regard to our request for NPDES permit modifications as you requested in our telephone conversation. Please review and let me know what can be done. Sincerely, Terry el Chief Operations Officer e-email terrv.bellLa)mcsk-12.org telephone 828-524-4414 ext.342 Phone(828)524-4414 FAX(828)369-7240 •(828)524-5938 an equal opportunity/g07rmati've action employer �1 �oF WnrF9O �O G North Carolina Department of : ry g Environment and Natural Resources > L./WLJ�-a Division of Water Quality (919) 733-5083 A-/?,O u r i �} ➢5- u P e- /I,L M (� Yam' LJ,4 T ��� of � (•txcYs !�' Nl Fpl�f� u.1� tlQ� lntG2o � n°"� �tr � Al- 570 wo�/� aeLk 7so awns°'` •PI4ANT OPERATION 919 807 354E 08/20 `03 17:35 N0.439 02/06 August 17, 2003 Mr. Kevin. Barnette N. C. Division of Water Quality 59 Woodfin Place Asheville, N. C. 28801 SUBJECT*:- bequest for NPDES Permit Modifications Increase in Monthly Average Flow Cullasaja Elementary School (NC0067326) Nantahala Elementary School (N00067318) Macon County Schools Dear Mr. Barnette: We are requesting flow increases at the subject Cullasaja and Nantahala Elementary Schoo13 from 0 .002 to 0 . 003 MGD. I have attached evaluations of each school' s wastewater treatment capabilities that were prepared by Mr.. Bob DeWeese,, Environmental Engineer, with NC D?I Plant Operation Section in Raleigh. These evaluations and our historical monthly monitoring data demonstrates that each of these facilities can meet the requested flow increases and still maintain a high quality effluent that will meet the other_ parametric requirements contained in the permits . If you have any questions or need additional information regarding this request, please contact Mr. DeWeese at (919a07-3546 or 807-3545 FAX. Thank you in advance for your considerations in this permit modification. Sincerely, Dr. Rodney Shotwell, Superintendent Cc: Mr. David Curtis Mr. Bob DeWeese i ?Lt�NT OPERATION 919 B07 3545 08120 '03 17:35 N0.439 03106 WASTEWATER TREATMENT CAPACITY EVALUATION CULI.ASAJA ELEMENTARY SCHOOL MACON COUNTY I8August2003 I. System Components A. Flow Equalization and duplex pumps (21000 Gal) B. Aero-Flow Package Unit, SO-200 (2, 000 GPD) C. Recirculating Sand Filter 580 SF D. Tablet Chlorination/Contact Tank (1,200 Gal) II. Treatment Capacity Usually a recirculating sand filter_ treatment system is preceded by an anaerobic system. (septic -tank) that reduces the organic loads by approximately fifty per cent. However_ the use of sand filters after an aerobic system, either as "polishing" or as a separate secondary treatment unit, is a preferred option, since aerobic conditions are maintained continuously throughout the sand filter. In addition organic loads are reduced by seventy-five to n nety-f i vA per cent in these systems . Since this is a complex treatment system involving dual secondary treatment units, 1 have chosen to evaluate the recirculating sand filter as the primary system and the flow equalization/package unit as preliminary treatment. A. Sand Filter_ 1 . Size: 22' 2" x 26' 2" = -580 SF (Sand replaced 2002) 2. Loading Rates (Tertiary Treatment) a. Hydraulic Loading 5-6 gpd/sf 580sf x 5gpd/sf = 2, 900gpd. 580sf. x 6gpd/sf = 3, 480gpd Permitted Flow = 3,000gpd b. Organic Loading -0.005 lbs/d/sf 590.sf x 0.005lbs/d/sf = 2. 9lbs/d./sf PLANT OPERATION 919 807 3545 08/20 '03 17:35 N0.439 04/06 z Assuming 50/50, BOD/TSR, mg/1 in effluent; worst case conditions, Lbs/day = 0.002MGD x 50mg/l x 8-. 34= 0. 83 THEREFORE, HYDRAULIC LOADING RATE CONTROLS. Since these loading rates are conservative and we have demonstrated the treatment capability of this facility over the years, a treatment capability of 3, 000gpd is sustainable. This loading rate would. be 5.2 GPD/SF and is very conservative considering the organic concentration is so low and that the preliminary treatment unit' s efficiency is maximized by flow equalization. B. Chlorine Contact 1. Size 11200 gal. 2 . Detention Time (avg. ) 1, 200gal/2,000gpd x 24hrs . = 14 . 4 hours . and 11200gal/31000gpd x 24hrs. = 9. 6 hours, OR 3 . Detention Time (de nami.c) 500 gallon dose over, a one hour period. 1, 200gal/500gph = 2 .4 hours, OK Therefore, the 0.5 hour contact time is satisfied. It is my professional opinion based on these calculations and the historical performance data of this treatment system that treating 3,000gpd is. sustainable at this site if it is operated and maintained properl . Prepared. by: Bob W. DeWeese August 20, 2003 PLANT OPERATION 919 807 3545 08/20 '03 17:36 N0.439 05/06 WASTEWATER TREATMENT CAPACITY EVALUATION NANTAHALA ELEMENTARY SCHOOL MACON COUNTY I8August2003 I. System Components A. Flow Equalization and duplex pumps (2, 000 Gal) B. Aero-Flow Package Unit, SO-200 (2400 GPD) .C. Recirculating Sand Filter. 625 SF II. Treatment Capacity Usually a recirculating sand filter treatment system is preceded by an anaerobic system (septic tank) that reduces the organic loads by approximately fifty per cent. However the use of sand filters after an aerobic system, either as "polishing" or as a. separate secondary treatment unit, is a preferred option, since aerobic conditions are maintained continuously throughout the sand filter. In addition orga.)ai.c loads are reduced by seventy-Live to ninety-five per cent- in these systems. Since this is a complex treatment system involving dual secondary treatment units, I have chosen to evaluate the recirculating sand filler as the primary system and the flow equalization/pack.-age unit as preliminary treatment. A. Sand. Filter 1. Size: 23' 8" x -26' 5" = -625 SF (Sand replaced 2002) 2. Loading Rates (Tertiary Treatment) a. Hydraulic Loading 5-6 gpd/sf 625sf_ x 5gpd/sf = 3, '25gpd Permitted Flow = 31 OOOgpd b. Organic Loading -0. 005 lbs/d/sf 625sf. x 0. 005lbs/d/sf = 3. 125 lbs/d .PLANT OPERATION 919 807 3545 08/20 '03 17:36 N0.439 06/06 Assuming 50/50,BOD/TSR, ma/1 in effluent; worst case conditions, Lbs/day = 0.002MGD x 50mg/). x 8. 34= 0.83 THEREFORE, HYDRAULIC LOADING RATE CONTROLS. Since these loading rates are conservative and we have demonstrated the treatment capability of this facility over the years, a. treatment capability of 3, 000gpd is sustainable. This loading rate would be 5. 2 GPD/SF and is very conservative considering the organic concentration is so low and that the preliminary treatment unit' s efficiency is maximized by flow equalization. P. Chlorine Contact 1. Size 1,200 ga.l. 2. Detention Time (avg. ) 1, 200gal/2, 000gpd x 24hrs. = 1.4 . 4 hours and 1, 200gal/3, 000gpd x 24hrs. = 9.6 hours, OK 3. Detention Time . (dynamic) 500 gallon dose over a one Dour period. 1, 200gal/500oph = 2 .4 hours, OK Therefore, the 0.5 hour contact time is satisfied. f It is my professional opinion based on these calculations and the historical performance data of this treatment system that treating 3f000gpd is sustainable at this site if it is operated and maintained properly. Prepared by: Bob W. DeWeese August 20, 2003 ENGINEERING AILTERNAT IVE S ANALYSIS (EAA) I. GENERAL INFORMATION A. Project Identification: Nantahala School WWTP Mr. David Curtis Macon County 145 River Road Franklin, NC 28734-8920 828-524-2744 FAX: 828-524-0294 Bob W DeWeese, Environmental Engineer N. C. DPI, Plant Operation Section 301 N. Wilmington Street Raleigh, N. C. 27601 (919) 807-3546; FAX 807-3545 B. Nantahala School operates under NPDES Permit No. NCO067318 issued by the Division of Water Quality. The proposed project would be for a wastewater system for 140 regular students and 60 Smart Start students, therefore: (140 students + 40 S. Start) x 12 GPC = 2, 400 GPD Note: The addition of flow conservation devices should reduce the daily flow by -200 (max. ) . 21400 GPD x 0. 80 = N1, 920 GPD C. Existing facilities: See attached "Wastewater Treatment Capacity Evaluation" of January 2006. D. Construction will not be phased. No construction is requested. Phased schedule is not applicable. II . EVALUATE DISPOSAL ALTERNATIVES A. Connecting to POTW by F/M: NA Connecting by Gravity Sewer is economically unfeasible. B. Connecting to private treatment works N/A C. Individual subsurface system N/A Local Health Department evaluations of soil conditions at the school and the local area demonstrate the soils to be unsuitable. D. Community Subsurface N/A E. Drip Irrigation (surface and subsurface) : 1 . Use existing treatment $ 000 .00 2 . Install Storage 150,000 Gal. 40.000.00 3. Purchase 3 acres minimum 36,000.00 4. Install UV Disinfection 13,500 .00 5. Install Duplex Pump Station 15,000.00 6. Install 3" PVC Force Main, 5000' 50,000.00 7 . Install pipe network/drip tube 32,000.00 8. Install Control Building/Controls 25,000.00 9. Landscaping, etc. 3,500.00 10. Electrical 3,000.00 11. Misc. Piping 1,500.00 Subtotal 219,500 .00 Engineering/contingencies 44,000.00 TOTAL $263,500.00 Operational Costs/year $ 11,500.00 F. Spray Irrigation N/A G. Reuse N/A H. Ex. Surface water discharge to Partridge Creek: Modifications are not necessary to increase treatment capacity to 0. 0030MGD at existing permitted effluent limitations. Annual operating costs -$15,625 III . CALCULATING PRESENT VALUE OF COSTS FOR EACH OPTION Assuming 8% interest and a life cycle of 20 years A. Land application with Drip/Spray: PW = Present cost + Annual Cost PW = -$263, 500 + (-11, 500) (9. 8181) _ - .$376,408 B. Ex. Discharge to Partridge Creek: (Secondary limitations) PW = 0 + (-15, 625) (9. 8181) _ - $153,407 Costs for construction were derived from the following: 1) RS MEANS 2) Costs of recent facilities 3) Best Professional Judgement 4) Wastewater Services of NC, INC. Costs for operation were derived from actual costs the Macon County Public Schools are paying for analytical services from their contract laboratory and in-house personnel for operations and maintenance. WASTEWATER TREATMENT CAPACITY EVALUATION NANTAHALA ELEMENTARY SCHOOL MACON COUNTY January 11, 2006 I . System Components A. Flow Equalization and duplex pumps (2, 000 Gal) B. Aero-Flow Package Unit, SO-200 (21000 GPD) C. Recirculating Sand Filter 625 SF II. Treatment Capacity Usually a recirculating sand filter treatment system is preceded by an anaerobic system (septic tank) that reduces the organic loads by approximately fifty per cent. However the use of sand filters after an aerobic system, either as "polishing" or as a separate secondary treatment unit, is a preferred option since aerobic conditions are maintained continuously throughout the sand filter. In addition organic loads are reduced by seventy-five to ninety-five per cent in these systems. Since this is a complex treatment system involving dual secondary treatment units, I have chosen to evaluate the recirculating sand filter as the primary system and the flow equalization/package unit as preliminary treatment. A. Sand Filter 1. Size: 23' 8" x 26' 5" = -625 SF (Sand replaced 2002) 2 . Loading Rates (Tertiary Treatment) a. Hydraulic Loading 5-6 GPD/SF 625sf x 5gpd/sf = 3, 125gpd Permitted Flow = 3,000 gpd b. Organic Loading -0 . 005 lbs. /D/SF 625sf x 0.0051bs/d/sf = 3. 125 lbs. /D Assuming 50/50, BOD/TSR, mg/l in effluent; worst case conditions, Lbs/day = 0. 002MGD x 50mg/1 x 8 . 34= 0. 83 THEREFORE, HYDRAULIC LOADING RATE CONTROLS. Since these loading rates are conservative and we have demonstrated the treatment capability of this facility over the years, a treatment capability of 3, 000gpd is sustainable. This loading rate would be 5. 2 GPD/SF and is very conservative considering the organic concentration is so low and that the preliminary treatment unit' s efficiency is maximized by flow equalization. B. Chlorine Contact 1. Size 1, 200 gal. 2 . Detention Time (avg. ) 1, 200ga1/2, 000gpd x 24hrs. = 14 . 4 hours and 1, 200ga1/3, 000gpd x 24hrs . = 9. 6 hours, OK 3 . Detention Time (dynamic) 500 gallon dose over a one hour period. 1, 200ga1/500gph = 2.4 hours, OK Therefore, the 0.5 hour contact time is satisfied. It is my professional opinion based on these calculations and the historical performance data of this treatment system that treating 3,000gpd is sustainable at this site if it is operated and maintained properly. Prepared by: Bob W. DeWees January 11, 2 06 Macon County Schools Subject: Macon County Schools From: Forrest Westall <Forrest.Westall@ncmail.net> Date: Tue, 11 May 2004 12:58:17 -0400 To: Susan A Wilson <Susan.A.Wilson@ncmail.net> CC: Kevin Barnett <Kevin.Barnett@ncmail.net> Susan, I talked to Bob DeWeese with the State Superintendent's office about Cullasaja and Nantahala Schools. They had requested a flow increase with the last permit renewal, but that request was denied. I reviewed the WWTP capacity at both schools and the student population numbers. The State flow figures with the current student population numbers would put both schools over their current 2,000 gpd limit (12 gpcd). Both plants have sand filters and the other parameters on their effluent quality are excellent (they have secondary limits). The school system asked for the flow increases to protect them from potential enforcement. Because per capita water usage is significantly lower than the State guideline, they are currently in compliance with the flow limit, but the levels are approaching the limit and are close to going over. Also, Cullasaja district is growing and next year they could have populations that result in a flow violation. I think that increasing the flow limit at each plant is certainly supportable by the student numbers and the capacity of the plants. Both plants are 2000 gal capacity and would still provide adequate 18 hours detention at 3000 gpd (this is what they requested at both plants). Chlorine contact time is OK at 3000 gpd and even if clarifer overflow rates are a bit high, they have sand filter capacity following the clarifer. If we wait until they start having flow violations, we will be placing the schools in the enforcement machine for no go good reason. Assimulative capacity is good in both receiving streams and other alternatives are not available (Cullasaja is miles from Franklin and Nantahala is away from everything--it's in the middle of woods). The option of increasing permit flow is the most appropriate and is supported by the facilities present. I've suggested to Bob that he meet with you about these requests and better explain the need. Keeping unnecessary flow expansions out of permits is a good thing, but the Macon County schools requests make sense for their situation. I would be happy to discuss this with you,just let me know. Thanks for the consideration. Forrest Forrest Westall - Forrest.Westall@ncmail.net North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Water Quality - Water Quality Section 2090 U.S. 70 Highway 1 of 2 5/18/2004 11:13 AM i i T 7h Ipp \ Ile- Con w 2�s� Oct o� C� ©o ZAt4 a 8"(.a ; L>,A z t D Scwoo v g&N g&f) Gl�alGcnl�- i 3 Abe✓i rio"j ,3Uu r'G/�no� &jb RaV�cw (Brsrc) �7 N'WA V6 �,o, oo� _�.___�_._ �_._..__.__.__..w .__.._._�.____.. r . / _ _�._ _..... �___ .... _.____�_._.v..___ �A Sum �.L 1 Tom.... STIN�....._..�..�.� 73__ ��'"--4---... _..,__.__._.___._..._ ���� ti �t � - �lil co�- ►- _.�._.�. � _. ._ � ��� _..�. l -- -�. . �