NC0071528_Staff Comments_20011019

N00 157.- 1
Division of Water Quality
Water Quality Section
Point Source Branch
October 19, 2001
MEMORANDUM
To:
Coleen Sullins
Through:
Dave Goodrich
Bill Reid
From:
Michael Myers
Subject:
Package Plant Dischargers to Class B waters of Lake Norman
Catawba River Basin
In October 2000, the Division issued an NPDES Permit to Mid -South Water systems for the Highway
150 WWTP. The Division issued a final permit that included increased monitoring for fecal coliform
and spill notification requirements (See Exhibit 1 and 2). In order to protect public health and address
public concern, the Division required increased fecal monitoring during the summer and required public
notification of spills. The conditions were implemented because of the B classification of the receiving
water and the high level of recreational use.
Since the issuance of the Highway 150 WWTP, the Division has received numerous requests from
concerned citizens asking that these same conditions apply to all discharges to Lake Norman where
treatment is performed using package plants (examples attached). In order to address these concerns, the
NPDES Unit and the Mooresville Regional Office evaluated the following alternatives:
1. No action;
2. Include daily fecal monitoring and spill notification requirements on package plant discharges
to class B waters of Lake Norman. The implementation strategy would place these
conditions in applicable NPDES permits that have not been issued and modify the remaining
permits upon renewal.
3. Same as option 2 except, the implementation strategy would place these conditions in
applicable NPDES permits that have not been issued and reopen the remaining permits and
modify accordingly.
4. Same as option 2 except, the implementation strategy would place these conditions in
applicable NPDES permits upon renewal.

Option 1 was deemed not appropriate, since upon renewal of the Highway 150 permit, the Division
anticipated these request and agreed that these conditions were appropriate for discharges to class B
waters in the Catawba River Basin.
Option 2 was considered and deemed inappropriate. All of the package plants with NPDES permits
discharging into Lake Norman have been issued with the exception of 2 — 3 permits. Therefore, it would
not be appropriate to require the remaining few discharges to adhere to these conditions, while the
facilities having already received their permits do not.
Option 3 was considered and deemed inappropriate. Prior to the issuance of the Highway 150 NPDES
permit many of the permits for discharges to Lake Norman had been issued. Limited time and resources
make reopening and modifying these permits impracticable.
Option 4 was considered to be the most appropriate. This option provides the Division with a consistent
permitting approach for package plant domestic discharges to class B waters of Lake Norman with
minimal strain on resources, while addressing public concern.
Analysis
Within the Catawba River Basin there are a total of 28 package plants with discharges to class B waters,
with more than 64% discharging to Lake Norman. Since there were so few package plant discharges to
class B waters outside of Lake Norman and public interests is centered around Lake Norman, the
effected area was limited to the class B waters of Lake Norman.
Reviewing existing dischargers as of July 2001, it is anticipated that this permitting policy will affect
approximately 18 NPDES permitted dischargers. This policy will have the greatest effect on Heater
Utilities, who owns approximately 40% of the effected facilities.
Economic Analysis
The economic affect of the spill notification requirement is difficult to assess. However, it is the
Division's experience that very few spills of untreated wastewater originate from small package plants.
Therefore, this special condition is expected to put a minimal strain on financial resources.
The daily fecal monitoring requirement will increase fecal monitoring from 1/week to 7/week per facility
during April through October. Over a one-year period, this will increase the number of samples from
approximately 30 to 214 and require an operator to visit the site daily. Assuming a cost of $25 per
sample for laboratory cost and $32 (4hours x $8.00) for operator, the total annual increase in cost for
fecal coliform monitoring is $6648 per facility per year [(64 days x $32/day) + ((214-30) x $25/sample)].

Recommendation
After evaluating the different options and affected dischargers, it is recommended that package plant
discharges to class B waters of Lake Norman in the Catawba River basin include daily fecal coliform
monitoring during the summer months (including weekends and holidays) and public notification
requirements (See Exhibits 1 and 2) in the event of a release of untreated wastewater reaching waters of
the State. It is additionally recommended, that implementation of these special conditions occur during
the 2004-2005 permitting cycle and the policy should be reevaluated periodically for modification or
deletion based on the number of spills occurring from such facilities.

A(4.) SPECIAL CONDITION — Spill Notification
(a) Contacting Public Health Directors
The facility must notify the and County Public Health Directors within 12
hours of first knowledge by the owner/operator of any discharge of untreated wastewater to waters of the State or a
discharge from the wastewater treatment plant that has not received adequate disinfection due to a malfunctioning
treatment unit.
The County Public Health Directors can be contacted using the following information:
Current Information for , '. and County Health Directors
County Health Director
Address line 1
Address line 2
Phone number
County Health Director
Address line 1
Address line 2
Phone number
(b) Public Notification
County Health Director
Address line 1
Address line 2
Phone number
County Health Director
Address line 1
Address line 2
Phone number
The facility must notify the public of untreated wastewater spills. Wastewater facility owners or operators
must issue a press release after a discharge to surface waters of 1,000 gallons within 48 hours of first knowledge of the
spill by the owner/operator. The press release must be issued to "all electronic and print news media outlets that
provide general coverage in the counties ( , and ) where the discharge occurred."
A copy of the press release must be maintained for one year by the owner/operator. This press release is required in
addition to the permit requirement of contacting the North Carolina Division of Water Quality (DWQ).
If a discharge of 15,000 gallons or more reaches surface water, a public notice is required in
addition to the press release. The public notice must be placed in a newspaper having general
circulation in the County in which the discharge occurred and the county immediately downstream. At
a minimum the notice should be published in the newspaper of general circulation in ,
, and Counties. If a discharge of 1,000,000 gallons of wastewater or more
reaches surface waters, the DWQ regional office must be contacted to determine in what additional
counties, if any, a public notice must be published. A copy of these public notices and proof of
publication must be sent to the DWQ to the attention of "Non Discharge Compliance Enforcement
Unit" at the letterhead address within 30 days of publication. The minimum content of the notice is
the location of the discharge, estimated volume, water body affected and steps taken to prevent future
discharges.
Note to Permit Writer. The counties inserted into this special condition should include the county where the
discharge occurs and the county immediately downstream (if the B classification extends into the downstream
county). For situations similar to the Lake Norman area where the county line divides the receiving water. The
counties listed should include the county where the discharge occurs, the adjacent county, and the two downstream
counties (if the B classification extends into the downstream county).

Exhibit 2. EFFLUENT LIMITATIONS AND MONITORING REOUIREMENTS
,Effluent Characteristics
Limits
Monitoring Reaui'rements:
Monthly
Average
vve kiy
Average
Daily
Maximum
Measurement_
Frequency
Sample
,Sample _
`Locat! n
Fecal Coliform
(geometric mean)
Summer'
200% 100 ml
400/100 ml
Daly3
Grab
E
Fecal Coliform
(geometric mean intern
200/ 100 ml
400/100 ml
Weekly
Grab
E
Footnotes:
1. Sample Location: E — Effluent, I — Influent
p p ' ugh October 31, while waiter is defined as Nooember 1 through 2.. M � i defined as the ,enod.fromA n1 thto
�asly xs defined as 7 .days,p.,erweek including Saturday, 5 day', and Holidays during the summer months a4d,-5 days per
week, during the winter months.