NC0060224_Correspondence_20050111

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® North Carolina Wildlife Resources Commi sion
Richard B. Hamilton Executive
MEMORANDUM
TO: Carolyn Bryant,NPDES Unit
Division of Water Quality JAN 1 2 2005
FROM: Ron Linville,Regional Coordinator
Habitat Conservation Program / DENR - WATER QUALITY
POINT SOURCE BRANCH
DATE: January 11,2005 ..-.
SUBJECT: Proposed Permit Renewal for Jonas Ridge Nursing Home, NPDES Permit No.
NCO060224,Burke County
Biologists with the North Carolina Wildlife Resources Commission have reviewed the subject application
for impacts to fish and wildlife. Our comments are provided in accordance with provisions of the Fish
and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d),North Carolina General
Statutes(G.S. 113-131 et seq.), and the North Carolina Administrative Code 15A NCAC 10I.0102.
Jonas Ridge Nursing Home has submitted a request for a permit renewal for its WWTP to discharge
treated wastewater into an unnamed tributary of Camp Creek. Excessive amounts of chlorine are deadly
to aquatic species and minimal amounts of chlorine can be harmful to juvenile aquatic species. Camp
Creek is wild trout waters that are near the Blue Ridge Parkway.
We appreciate the efforts of the Division of Water Quality to improve water quality. The implementation
of effluent limit reductions and monitoring requirements to renewal permits and disallowing new or
expanding wastewater discharges should go along way in protecting this important resource. Biologists
are concerned about chlorinated effluents. Chlorine is acutely toxic to aquatic organisms and forms
secondary compounds that are also detrimental to aquatic life. De-chlorination chemicals are also very
suspect. Additionally, freshwater mussels are among the most sensitive aquatic organisms tested for
impacts from ammonia, and ammonia may be a significant limiting factor for unionids (Augspurger et al.
2003). Recent research by Augspurger et al. (2003) found that ammonia concentrations which may be
protective of freshwater mussels range from 0.3 to I.0 mg/L total ammonia as N at pH 8.
We recommend that the following conditions be incorporated into the permit to reduce impacts to fish and
wildlife resources and in particular to juvenile fish and rare species.
1. If practicable, any existing chlorine and de-chlorination systems should be replaced by ultraviolet
light or ozone systems. Utilization of these techniques would provide an additional benefit of
Mailing Address: Division of Inland Fisheries - 1721 Mail Service Center - Raleigh,NC 27699-1721
Telephone: [phone] - Fax: [phone]

r Jonas Ridge Nursing Home 2 January 11,2005
removing a hazardous material from the workplace. Emergency use of chlorine should not be
allowed. �4a s /7
2. We recommend a reevaluation of any ammonia limits based on the research discussed above and
readjusting the limits. Please contact Tom Augspurger with the U.S.Fish and Wildlife Service at
[phone] for additional information. [4,;t S ;2,lq /0 If3-/0 V-5
3. Stand-by power is recommended if not already provided
4. If a Publicly Owned Treatment Works (POTW) and sewer collection system becomes available,
connection should occur to the POTW without undue delay.
Thank you for the opportunity to provide input during the planning stages for this project. If we can be of
further assistance,please contact our office at(336) 769-9453.
Citation:
Augspurger, T., A. E. Keller, M. C. Black,W. G. Cope, and F. J. Dwyer (2003)Water quality guidance
for protection of freshwater mussels (Unionidae) from ammonia exposure.
Environmental Toxicology and Chemistry 22:2569-2575.
Cc: Tom Augspurger,USFWS Raleigh,USFWS Raleigh
E-mail: Mark Cantrell, USFWS Asheville
Sarah McRae,NHP