NC0049867_Return_19990420

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State of North Carolina
Department of Environment
and Natural Resources 4
Division of Water Quality
James B. Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
April 2O, 1999
Mr. Harold J. Thabet
4072 Beaverbrook Drive
Clemmons, North Carolina 27012
Subject: NPDES Application Return
Return No. 2035
Bridle Path Farms WWTP
Rowan Counry
Dear Mr. Thabet:
The Division received your NPDES permit application and Preliminary Engineering Report for
the Bridle Path Farms development on June 18, 1998. We have determined that the proposed
discharge is not acceptable at this time and are, by this letter, returning your application. We are
also adding copies of this lerter to the permit files for Statesville and Cleveland, for reasons
explained below.
In reviewing your submittal. we found the application to be sufficiently complete and accurate.
The engineering report, including its analysis of discharge alternatives, was thorough, clearly
written, and well organized- The report concludes that direct discharge to Third Creek is the most
reasonable and environmentally sound alternative available for the project. We agreed with this
conclusion initially, based on our review.
We then evaluated the potential impact of the proposed discharge on the receiving stream. using
a computer model to predict dissolved oxygen levels downstream of the proposed discharge
point. We found that, under low -flow conditions in the stream and at the maximum allowable
flows from all facilities on the stream, dissolved oxygen levels would drop below North
Carolina's water quality standards. As a result, the added discharge from Bridle Path Farms is
not acceptable at this time.
The model further showed that the existing upstream discharges, primarily Statesville and to
some extent Cleveland, are likely the cause of the low oxygen levels we would predict under the
worst -case conditions evaluated. These two facilities are operating well below their design flows
at present and are not actually causing low oxygen levels. However, as they approach their
maximum flows, they may cause measurable impacts to water quality in Third Creek. The
Division will address those issues when plant upgrades or permit modifications prompt a re-
assessment of the discharges. In the meantime, we cannot permit new discharges on the stream
without compromising its quality and designated uses.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Internet: http://h2o.enr.state.nc.us;

Mr. Harold J. Thabet
Bridle Path Farms WWTP
Permit No. NCO086444
Return No. 2035
Page 2
The Division can reconsider your application as circumstances change. For instance, the Division
may elect to lower allowable discharge limits for existing dischargers, if we find these are
necessary to protect water quality. This may, in turn, create enough extra capacity that a few
small dischargers, such as Bridle Path Farms, could discharge without causing unacceptable
impacts. Copies of this letter will go to our Statesville, Cleveland, and Third Creek files, so that
we will be reminded to reconsider your proposal as circumstances change.
In the meantime, we encourage you to re-evaluate wastewater reuse and other non -discharge
options for the project. These may provide an acceptable wastewater alternative or an interim
solution until a surface water discharge becomes possible. If you have any questions about these
options, please call Mr. Kim Colson, Non -Discharge Unit Supervisor, at [phone],
extension 540.
If you have any questions or comments regarding the NPDES permit, please contact Mike
Templeton at [phone], extension 541.
Sincerely, .
David A. Goodrich, Supervisor
NPDES Unit
Enclosures: NPDES Permit Application, NC0086444
cc: Kim Colson, Non -Discharge Unit
Mooresville Regional Office, Water Quality
Central Files
NPDES Files: Returns
Statesville NC0020591
Cleveland NC0049867
Yadkin/ Third Creek/ WLAs