NC0087891_Staff Comments_20050516

NPDES/East Yancey W WTP rO_
Subject: NPDES/East Yancey WWTP
From: Tom Belnick <[e-mail]>
Date: Mon, 16 May 2005 17:45:00 -0400
To: [e-mail], [e-mail]
Hello folks- sorry for the delay in getting back to your final comments on this project, but I'm
still playing catch-up after vacation. Just an FYI for both- I contacted the Rural Center after I
got back and discussed how this permit played out. I requested that they ask applicants to contact
DWQ for speculative limits at the application stage, which we would then prepare and also copy the
natural resource agencies (USFWS, NCWRC). That way, we all know about the project at an earlier
stage (before the permit is drafted). Dennis Lassiter with the Rural Center did not think this would
be a problem, and he mentioned that the Rural Center has already allocated all their funds for
wastewater facilities, and is uncertain what the future funding will be (currently they are seeking
more money from the legislature). Anyways, it sounds like we shouldn't see any more Rural
Center -funded projects for awhile.
Sara- Unfortunately I did not have sufficient time to consider any of your additional recommendations
which I received via email on 4/21, since I committed to getting the final permit out the door before
I left for vacation on 4/22. Based on my conversation with the consultant after the 4/11 meeting,
there were no significant changes to the proposed project, so I proceeded to permit finalization.
Dave- I mentioned in the cover letter that the applicant agreed to incorporating effluent filters and
UV disinfection should funding become available. As with all NPDES permits, DWQ cannot dictate what
treatment they will use, as long as they meet the permit limits. Thus, I left it in the cover letter
as something they agreed to do pending available funding.
Let me know if you have additional suggestions to improve the process down the road. Thanks.
[e-mail]
N.C. DENR/DWQ/NPDES
919-733-5083,ext. 543
of 1 5/17/2005 9:04 AM

E Yancey W&S draft NPDES permit follow-up
Subject: E Yancey W&S draft NPDES permit follow-up
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J Y P P
From: [e-mail]
Date: Thu, 21 Apr 2005 09:33:46 -0400
To: Tom Belnick <[e-mail]>
CC: [e-mail], [e-mail], [e-mail], [e-mail]
Hi, Tom.
I appreciate your willingness to delay final permit issuance for the East
Yancey Water and Sewer District NPDES permit (NC0087602) pending the
outcome of our April llth meeting with the applicant's consultants (Forrest
Westall and Harry Buckner, McGill Associates). As we discussed over the
phone, one topic of discussion during that meeting was the feasibility of
alternative discharge locations for the facility (namely Little Crabtree
Creek or Ayles Creek). The applicant at one time considered Little
Crabtree Creek as a potential discharge site (and requested speculative
limits from DWQ to that end), and it appears that sufficient dilution
capacity is available. However, we heard at the meeting that the
anticipated cost to pipe the effluent to this receiving stream from the
currently planned facility site and the lack of access for needed
infrastructure make further consideration of this alternative impracticable
at this time.
We appreciate the receptiveness of DWQ and the applicant to consider
additional measures and permit conditions to maintain water quality at this
location given the presence of the Appalachian elktoe mussel in the South
Toe River. We understand from our dialog with you that additional permit
conditions have been added including instream monitoring requirements for
ammonia and total residual chlorine, a requirement for completion of a
mussel survey in the outfall location, and re -opener language for ammonia
limits (should a State or site -specific ammonia standard be adopted). We
are also encouraged by the applicant's efforts to seek funding for tertiary
treatment and ultraviolet disinfection at the facility. We support these
steps and offer the following comments and recommendations for additional
permit measures:
1. We recommend that instream ammonia and TRC monitoring be conducted
more frequently (e.g., twice a week) during periods of low flow or high
inflow (e.g., heavy rainfall events) to capture those times where a process
upset would be more likely to have an impact on water quality conditions.
2. We understand from our meeting with their consultants that the
applicant is willing to consider alternative outfall designs (e.g. bank
splash, diffuse flow) to allow for rapid effluent mixing instream. We
recommend that design strategies be coordinated with our Asheville staff as
they are familiar with the site topography and resources at risk in the
South Toe River. Given that mussel surveys will be conducted when the
outfall design / location needs are better understood, we would be happy to
coordinate with the applicant to meet onsite and conduct these surveys
under appropriate conditions (e.g., weather, flow, etc) to facilitate this
process.
3. We also recommend that whole effluent toxicity testing be required
(at least for a demonstration period) to assure that the permit conditions
are protective and effluent from the facility does not result in adverse
effects to receiving stream biota.
4. Provided that funding sources are secured to implement tertiary
treatment and UV disinfection at the facility, we recommend that more
stringent limits be considered based on tertiary treatment capabilities.
We appreciate DWQ's responsiveness to concerns that have been raised
regarding the draft permit, but we remain concerned with two aspects of the
approach taken to review the ammonia loading concerns. While these do not
need to be resolved for this facility (due to its small size), we will be
back in touch with you regarding:
of 2 4/21 /2005 11:07 AM

Yancey W&S draft NPDES permit follow-up
1. the potential for a 7Q10 design flow (rather than a historic low
flow) to be inadequately protective of sessile organisms that could occur
adjacent to an outfall where they would not get the benefit of the stream's
full dilution at low flow (particularly a concern for endangered sessile
organisms since loss of individuals is important); and,
2. while we were glad to see that the ammonia concentrations we
published were used in the analyses, it is important to note the caveat in
that paper that those recommendations "did not consider additional margins
of safety that could be recommended for protection of threatened or
endangered mussel species in instances where information is specifically
lacking. Because threatened or endangered mussels have not been tested for
sensitivity to ammonia, additional approaches may be required." (page 2574
in Augspurger et al. 2003).
It certainly seems like we can address these State-wide (rather than permit
by permit or plan by plan) based on the data that are available and DWQ's
previous development of ammonia permitting strategies (reference the
10/15/02 DWQ memorandum on Implementation Policy for Permits with Monthly
Average NH3-N Limits - while DWQ, industry and municipal government
interests were represented on the stakeholder group for that process, a
similar process could be used to address these two issues with an expanded
group of stakeholders).
Feel free to give me (856-4520 x. 30) or Tom (x. 21) a call if you have any
questions regarding the recommendations above. We will be flowing -up with
you regarding earlier coordination measures you discussed with Tom at the
February meeting in Raleigh; your ideas sound very practical and helpful.
Take care,
Sara
Sara E. Ward
U.S. Fish and Wildlife Service
Raleigh Ecological Services Field Office
P.O. Box 33726
Raleigh, NC 27636-3726
Phone: [phone] Ext. 30; Fax: [phone]
Email: Sara [e-mail]
2 of 2 4/21 /2005 11:07 AM

East Yancey WWTP Final Permit
NC VJ4
Subject: East Yancey W VTP Final Permit
From: "David McHenry" <[e-mail]>
Date: Mon, 2 May 2005 09:12:22 -0400
To: "Tom Belnick" <[e-mail]>
Tom,
Thanks for all your hard work on this project. I received the final permit last week. I do have one question.
When we met with McGill Associates, they indicated that the permit would have language saying that after
construction of the WWTP and phase 1 of the collection system, the next improvements would be filtration,
then UV disinfection, then next collection phases as the $ became available. The permit cover letter
mentions that they have agreed to UV and filtration if funding becomes available before plant construction.
Was what McGill told us considered by DWQ but determined unnecessary or not doable? Or, perhaps
there was some misinterpretation somewhere? I guess it's somewhat irrelevant now, nevertheless I'd
appreciate any clarification you might have on this.
Thanks
Dave McHenry
Mountain Region Coordinator
Habitat Conservation Program
NC Wildlife Resources Commission
828/452-0422 ext. 24
828/452-7772 Fax
1 of 1 5/4/2005 10:48 AM