NC0086070_Meeting Officer's Report_19971107

DIVISION OF WATER QUALITY
7 November 1997
MEMORANDUM
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TO: Preston Howard
Director
FROM: Roger Thorpe 4(
Water Quality Supervisor
Washington Regional Office
SUBJECT: Meeting Officer's Report & Recommendations
NPDES Permit Meeting N0086070
Henderson County Utilities
Western North Carolina Justice Academy
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In November 1996 an application for a NPDES permit was submitted by
Henderson County Utilities for a proposed discharge of 40,000 gpd of domestic
wastewater to Lewis Creek, a class C-Trout stream in the French Broad River Basin. The
proposed treatment plant would serve a soon to be constructed Western North Carolina
Justice Academy and the surrounding community. The Western North Carolina Justice
Academy is to be located at an old Edneyville school site and is proposing to train 150
students initially. In addition to the academy, the treatment plant would serve the sewer
needs of 28 residential and commercial customers.
The Permits and Engineering Unit reviewed the application package and
determined that the engineering alternatives analysis was incomplete and the package
was therefore returned. The package was resubmitted in February 1997 and at that time
the Division began its own investigation of disposal alternatives. During the evaluation
process, the applicant twice requested changes in the discharge point location in response
to local community concerns. Based on the Division's investigation it was determined
that only a plant of 30,000 gpd could be justified, but a stream discharge was determined
to be the most cost effective alternative.
Due to much public concern, a public meeting was noticed and as the appointed
meeting officer, I conducted the meeting on 25 September 1997. Four people made
comments. The county's consultant spoke on behalf of the county and explained the
process it had gone through and explained that a site for location of the treatment plant
had not been selected. This apparently has been a major concern of some people in the
community. One community resident spoke in favor of the project.. Two other
community residents spoke against the project. They were basically opposed to all
wastewater treatment plants and were afraid of malfunctions, noise and odors. No one
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spoke about a concern that the proposed receiving stream is used for irrigation of
farmland which is what I understood was a concern.
Just a couple of days before the public meeting was held, the county submitted a
'$ request to move the proposed discharge point about a 1000 feet upstream. Based on this
information, I decided to hold open the meeting record for two additional weeks to allow
additional written comments to be submitted. This was explained at the meeting and the
audience was encouraged to contact anyone they knew who might be affected by moving
the proposed point of discharge.
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Eight letters were received following the hearing; one supporting and seven
opposed. Of those opposed, two say that the creek is used for irrigation by other people,
but they don't mention by whom. One person says that he irrigates out of Clear Creek.
Lewis Creek is a tributary to Clear Creek at a point approximately 1.5 miles downstream
of the point of discharge. Clear Creek has a 7Q10 of 6.0 cfs. Therefore there is
significant dilution at this point. One person says that she does not currently irrigate out
of Lewis Creek but plans to irrigate fruits, vegetables and herbs in the future. Her
property is located at the confluence of Lewis and Clear Creeks. Again this is
approximately 1.5 miles downstream of the proposed discharge point. Other reasons
mentioned for opposing the discharge included fear of mechanical failure, effect on trout
populations and creek flooding.
Recommendations
The effluent limits proposed for this permit are BOD-5mg/1, NH3 as N-2mg/1,
TRC-28ug/1, D.O.-6mg/l, and Fecal Coliform-200/100 ml. These stringent effluent limits
would not normally be imposed where the receiving stream has a summer 7Q 10 of 1.2 cfs
as this one does. However, these more stringent limits are being proposed as an extra
safety precaution due to the possibility of the stream flow being lover due to crop
irrigation.
With the stringent effluent limits proposed and the amount of dilution available, I
would not anticipate any water quality standard violations, and the quality of the stream
should be adequate as an irrigation source. Therefore, I recommend that the permit be
issued.
cc: APfave Goodrich