NC0037737_Return_19990406

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
April 6, 1999
Mr. John G. Burton, Owner/Manager
Nantahala Village
9400 Highway 19 West
Bryson City, North Carolina 28713
Dear Mr. Burton,
Al Ale,
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
SUBJECT: Request for Flow Increase
Nantahala Village
NPDES No. NCO037737
RETURN No. 2040
Swain County
The Division received your request, dated February 8, 1999, for flow expansion at Nantahala Village
(NPDES No. NC0037737). In your letter you requested that the permitted flow for Nantahala Village be
increased from 7800 gallons per day to 19,440 gallons per day.
As indicated by letter December 1, 1997 from Mr. Paul White of the Division's Asheville Regional
Office to you, the current permit was renewed March 27, 1998 at the existing flow of 7800 gallons per
day. At that time you were instructed that you could "reapply for an expansion with a specific
justification for the requested flow based on the proposed facilities, along with an engineering economics
analysis of the alternatives to discharging"
Although the current treatment system may be hydraulically capable of accommodating an increased
flow rate, with any increase in permitted flow the facility may be subject to more stringent limits. A
modeling analysis would be needed with any increase in flow.
For the reasons cited above your request is being returned as incomplete. The following information
must be provided should you wish to continue the request for a permitted flow increase at Nantahala
Village:
• A completed application form [Short Form D], attached to this letter.
Further information on the units which have been added to the existing treatment system. Your
August 18, 1997 letter indicated that the local health department was evaluating the site to determine
if the "Upper Lodge" was viable for a septic tank/drainfield system. Please provide information on
this evaluation and if the Upper Lodge is connected to its own system or the existing discharge •
system. Also, reconfirm the number of rooms in the Main Lodge, number of seats in the restaurant,
existence of a laundry, etc.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

Mr. Bruton
Nantahala Village
Page 2
An evaluation of wastewater discharge alternatives as required by 15A NCAC 2H .0105 (c)(2). A
guidance document for preparation of Engineering Alternatives Analysis is attached to this letter.
• Application Fee. Changes in the fee schedule for NPDES permits went into effect on January 1,
1999. The new fee for a major modification of a minor individual permit is $215. Should you
continue to pursue the requested flow increase at Nantahala Village, this fee must be submitted with
the completed application.
If you have any questions or need additional information, please contact Susan Wilson at (919) 733 —
5083, ext. 510.
Sincerely,
.��jf"err T. Stevens
Cc: Central Files (/Jj
NPDES Files
Asheville Regional Office/ Kerry Becker

QUALITY
SERVICE
•
RESPECT
WV,#
4PAC"b C MOUNTAIN RESORT & MEETING CENTER
February 8, 1999
Mr. Dave Goodrich
Permits and Engineering Unit
Division of Water Quality
NC DENR
PO Box 29535
Raleigh, NC 27636-0535
Dear Mr. Goodrich,
�7
'T1 -
rn
co
N
N
Re: NPDES Permit # NCO037737
Swain County
I am writing to request an increase in the permitted flow of our waste water
treatment plant from the current limit of 7,800 gallons per day to 19,440 gallons per
day.
On August 17, 1997 I wrote Mr. Wiggins with a similar request (copy attached.)
On December 1, 1997, Paul White of the Asheville office responded, saying rules for
flow expansion require a specific justification of the need, and an analysis of
alternatives.
We operated the plant last year with one major flaw: our flow meter was faulty,
which we did not discover until late in the summer. Early in the year we were building
our new lodge, which opened at the end of May. In late August, 1998, Kerry Becker
made us aware of the heightened enforcement activity at the DENR, and we all
concluded then that the meter was not working accurately. We installed a dump counter
(our plant works from a dosing tank after the effluent passes through three or four
septic/holding tanks) on our dosing tank, and so now we believe we have accurate flow
records, starting in mid -September. Unfortunately, we do not know what the maximum
flows were or will be in the summer, but we are confident they were nothing like the
faulty numbers put out by the flow meter.
The plant, with its new recirculation system, has proven capable of handling the
maximum summer flows, whatever they are. I have done an analysis of flows relative
to business volume on the attached spreadsheet, which predicts summer flows within
permitted levels. However, even before the new system was built, it seems we had
occasional flows above the permitted maximum, and it seems nearly 100% capacity in
lodging and a busy restaurant lead to higher than mathematically -predicted flows. For
that reason, and since the plant has demonstrated its ability to handle peak summer
flows, I am requesting the premitted flows be increased to the maximum for a plant of
our size, which I understand to be 5 gallons per square foot. We have three 36' x 36'
sand beds, totalling 3,888 square feet, which multiplies out to 19,440 gallons per day.
9400 HIGHWAY 19 WEST • BRYSON CITY, NC 28713
828-488-2826 • 800-438-1507 • FAx [phone]
www.nvnc.com

Dave Goodrich, 2/8/99, page 2
We don't know exactly what the peak flows will be. At the same time, we do
not want to be fined again for exceeding our permit limits, since we now have a plant
capable of handling whatever flows we put through it in the summer. I am seeking your
help in modifying our permit to reflect these unique circumstances.
As for consideration of alternatives, it seems unreasonable and unnecessary to
go through a process of analysis of alternatives, when we already have in place a
working plant that is discharging compliant effluent into the stream. R
Thank you for your consideration. I look forward to hearing from you soon, as
the season is approaching.
Sincerely,
Tihn G. Burton
Owner/Manager
pc: Kerry Becker

August 18, 1997
Mr. Mack Wiggins
NC DEHNR
Division of Environmental Management
Water Quality Section
PO Box 29535
Raleigh, NC 27626-0535
Dear Mr. Wiggins,
This cover letter accompanies our application for an increase in the discharge amount allowed out
of our plant, Permit # 37737. We have recently enhanced the capabilities of the plant by adding, at an
expense of $60,000, an active recirculation system designed by McGill Associates and installed by
Mountain Shore Construction. The new system went on line in the spring of this year, and is operating
well.
As you know, we are rebuilding our Main Lodge, though with slightly smaller capacities than the
old Lodge it replaces: 11 lodge rooms versus 14, and 75 seats in the restaurant versus 100 in the old
building. The office space will accommodate approximately the same number of staff. The main addition
we are contemplating is for a guest laundry in the basement, housing three coin -op washers.
We are also building a new "Upper Lodge" approximately 100 yards up a small hill behind the
Main Lodge. It has 12 guest rooms each with private bath, and two public restrooms associated with a
meeting room of approximately 1000 square feet. The local health department officials are studying the
site to see if we can put the Upper Lodge on its own septic tank and drain field. We expect to open both
buildings in May or June of 1998.
I am applying for higher outflow limits for two reasons: with the old Lodge we often approached
our permitted limit of 7800 gallons per day, and even if we do not put the Upper Lodge on the system, we
may add other facilities in the future which would push the permit limits. I would like to increase the
permit to whatever is the maximum carrying capacity of the streams into which we are discharging now.
If there is not much increse in capacity possible, I wonder if extending the effluent pipe further toward the
Nantahala River would be economically feasible.
The other factor in this decision is the enhanced capability of the plant with the recent addition of
the active recirculation system. We now have a system which can easily handle increased flows, and so
we are confident we can responsibly discharge greater flows into the streams.
Thank you for your consideration. Please let me know what other data I need to supply to your
office, and how we may help expedite this process.
Sincerely,
John G. Burton
Owner/Manager
pc: Paul White

State of North Carolina
Department of Environment, IL j
Health and Natural ResourcesF4•
Asheville Regional Office 7�
Now,
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary [ E H N FZ
WATER QUALITY SECTION
December 1, 1997
Mr. John Burton
Nantahala Village
9400 Highway 19 West
Bryson City, NC 28713
If
Subject: Nantahala Village WWTP
NPDES Permit NCO037737
Swain County
Dear Mr. Burton:
Your letter which accompanied the application for renewal has been
forwarded to me for reply. As you know, the permit is being renewed at
the current flow rate. You should have received a draft copy for comment
no later than November 21, 1997. No expansion is included in this
renewal for the following reasons:
Requested flows: The reduction in flow from the proposed smaller main
lodge will be somewhat offset by the addition of a guest laundry. The
wastewater from the proposed additional upper lodge is under
consideration for disposal in a subsurface drain field. We would need to
know the outcome of the County Health Department's decision before
considering this flow.
General plans for expansion is not sufficient justification for flow
expansion. Rules for discharging require a specific justification of
need for expected flow volumes.
Rules also require that an analysis of alternatives to discharging
be done to assure that the most environmentally sound alternative for
wastewater disposal is selected from the cost effective options.
Therefore you should continue to pursue non -discharging options for any
additional flows.
Enhanced Treatment Capability: Improvements to treatment that were
completed and placed on line around April 1997 have improved effluent
quality, however,,the loss of the lodge in the winter of 1997 has
decreased flows. This may be partly responsible for improved effluent.
Since reported monthly average flows following the completion of
improvements are 3000 gpd or less, it is difficult to project how the
facility will perform with increased flows.
Interchange Building, �'w; An Voice 704-251-6208 FAX [phone]
59 Woodfin Place, �� Equal Opportunity Affirmative Action Employer
Asheville, North Carolina 28801 - . 50% recycled/10% post -consumer paper

John Burton
December 1, 1997
Page Two
There is no specific maximum carrying capacity of the streams; the
additional cost of treatment to meet increasingly strict effluent
limitations as the wastewater flow increases is a limiting factor.
Extending the effluent pipe to a larger stream would also be a
consideration to evaluate in the engineering economics'`analysis.
If no non -discharging option is available, you may re -apply for an
expansion with a specific justification for the requested flow based on
the proposed facilities, along with an engineering economics analysis of
the alternatives to discharging.
As a reminder, if any projected expansion involves sewer lines
serving more than one building, approval of sewer line construction plans
is required prior to construction.
If you have any questions, please call me at 704-251-6208.
Sincerely,
l `
l.�
Paul R. White, P. E.
Environmental Engineer
copy: Mack Wiggins

Nantahala Village WWTP Flow Analysis, as of 02/08/99
Monitoring Reports
Weekly readings I Average
Jan-98 1
Feb-98
Mar-98
Apr-98
May-98
Jun-98
700
3,000
1,300
1,100
2,100
_ 1,600
�900
600
500
1,000
1,300
1,600
_ 700
1,100
200
1,300
600
1,000
600
_
1,700
400
1,600
700
2,100
_
1,200
9,100_
7,400
8,600
8,500
12,00_0
Jul-98
_
14,800
11,700
11,300
20,200
14,500
Aug-98
31,000
199000
14,000
8,700
23,000
Sep-98
Oct-98
2,000
3,000
3,000
3,000
2,800
2,300
4,000
_
4,000
4,000
31500
Nov-98
1,700
2,700
1,700
2,100
21000
Dec-98
wwtp numbers.123
7 8 9
Dump Counter
End of Number Monthly
month of average
reading dumps flow
10
Busine
Gross
lodging
and food
revenue
Volu
a Comparison
Adjusted
for
Index
Predicted
seasonal
(Sept =
WWTP
prices
100)
volume
$209,000
209,000
155
--
$288000
288,000
213
$243,000
243,000
180
2,800
$135,000
1359000
100
20
48
3,560
$168,000
168,000
124
48
28
2,080
_ $77,000
1019000
75
631
151
1,110
$32,400
34,500
26
4,300
69000
5,000
2,800
2,100
700

February 8, 1999
Notes to accompany WWTP flow analysis
Columns 2-6, under "Monitoring Reports," show the reported data for our plant in 1998. January through August the data
came from the flow meter; September through December the data were read from the dump counter. The new lodge was opened May
22, 1998, which initiated the first heavy flows into the revamped plant, which itself had been put on line in May, 1997. Flows
pre -May 1998 were so marginal as to not raise a flag about whether the in -line flow meter installed with the plant was working
properly.
In early September, 1998, we installed a dump counter on the dosing tank. It recorded 48 dumps (of 2,300 gallons each) in
October, 28 in November, and 15 in December (column 8). These volumes (column 9) were correlated to a proxy of our business
volume, column, 11, adjusted for seasonal pricing in our lodging, to create an index of expected volume using September as the base =
100. This index predicts nearly perfectly the plant flow for November and December (comparing column 13 to column 9.) Applying
the index back to try to estimate summer flows yields expected flows of 4,300 gallons per day in June, 6,000 in July, and 5,000 in
August.
We know we had flows higher than these in previous summers, with the old lodge, so the index may not predict completely
accurately when we are super -busy in the restaurant. We will continue to monitor this closely as the spring and summer unfold.

� dl 99� • / SS l> 63
Z •�/.- Sa�u,;V
s, ju 01AAW-
6,67
C�Atm�cc `G/s/z