NC0089532_Application Review Comments_20150508

RECEIVED/DENR/DWR
MAY 1 2 2015 Water & Sewer
Authority
Water quality ICTINNTUCKASEIGEE
SERVING JACKSON COUNTY
Permitting Section 1246 West Main Street
Sylva, NC 28779
May 8th, 2015
NCDENR
Division of Water Resources
NPDES Complex Permitting Unit
Attn: Teresa Rodriguez
1617 Mail Service Center
Raleigh, NC 27699-1601
Ref: Draft NPDES Permit
Permit NC0089532
Jackson County- Class 2 Facility
Applicant Review Comments
Dear Ms. Rodriguez:
This letter is being written in response to the above referenced documents provided by
your office in a package dated April 8th, 2015. This package was received in this office on
April 13th.2015 and our review began at that time. It is our understanding that the review
period commenced upon receipt and runs for 30 days, thus ending on May 12th, 2015.
This letter is provided as a consolidated set of comments after review of your transmittal
by our staff and our consulting engineer. The following remarks, questions and comments
are provided for your consideration in this matter.
1. The application package was submitted as a 0.495 mgd discharge with no phasing
due to the complexity of the Engineering Alternatives Analysis and the application.
While this 0.495 mgd is the ultimate build out for the proposed discharge, we
request the permit to be drafted in final form to provide for three phases of
construction to occur with provisions in the permit for discharges to begin after
construction is complete for 0.125 mgd and 0.250 mgd of capacity, in addition to
the 0.495 mgd already in the permit as full capacity.
2. The Latitude and Longitude for the discharge point as included in the Draft Permit
Map are incorrect. The Latitude and Longitude originally provided by TWSA in the
permit application package has been reviewed by our consulting engineer and
found to be correct as originally provided. We request that the original Latitude: 35
deg 07 min 46 sec N, and Longitude 83 deg 04 min 00 sec be reflected in the final
permit package.

3. We are unsure of the reasoning for inclusion of mercury monitoring in this draft
permit. It is our understanding that NCDENR will be adding mercury monitoring
requirements to municipal discharges that have the potential for elevated mercury
levels. The service area in Cashiers has no current industrial users. The likelihood
of any such a user ever connecting to the system is extremely low given the cost
of land and tight land use restrictions for the community. In addition, there are no
known airborne sources of mercury (i.e. coal fired boilers (power, heat or
combined) plants) within close proximity. We request that this requirement not be
included, or if it remains that the basis for such inclusion be provided for
clarification.
4. We request clarification of the monthly/weekly limit for Ammonia forperiod of April
1- Oct 31. The Draft permit includes information on winter, but not summer limits
for this parameter. In addition the stated winter limits are more restrictive than
those we must comply with in the summer at our existing VW TP in Cashiers
discharging into the HQW waters of the Chattooga River. We are concerned about
our ability to meet these limits in a cost effective manner in the cold weather during
low flows in this seasonal community. Please clarify the basis of the winter limits
and also what limits will be in place for the summer months.
5. The frequency of monitoring for Total Nitrogen and Phosphorous is listed as
monthly in the Draft Permit. Our existing WWTP in Cashiers discharging into the
HQW waters of the Chattooga River has a permit requiring monitoring of these
parameters on a semiannual basis. Please clarify the basis for this more restrictive
monitoring requirement.
6. Our staff has expressed concerns over the BOD limits in the permit due to
turnaround time on testing of samples. Please clarify the basis for these limits as
provided in the Draft Permit.
7. Our staff has also expressed concern over the limits for TSS in the Draft Permit.
Please clarify the basis for these limits as provided in the Draft Permit.
8. We request that NCDENR provide for TWSA's review and records all of the
supporting information developed or referenced to develop the draft permit. This
would include, but not be limited to;
a. fact sheets or other reviewed materials,
b. Regional Office staff reports,
c. Modelling work completed to check the limits meet water quality standards,
d. Comments from other NCDENR/DWR units,
e. Internal communications,
f. Any internal communications, written (electronic or hard copy) notes or
correspondence.

We appreciate the work accomplished by your office and the ongoing support of the
Asheville Regional Staff in this matter. We continue to be committed to meeting our
obligations to be a good steward of the water resources of Jackson County. At the same
time we also have a responsibility to our current and future customers to make sure we
keep our capital, operating and maintenance costs in control. It is our intent that our
interaction in this matter reflect both of these responsibilities in a balanced approach.
In view of that goal, we respectfully request that you address these comments as provided
and will be glad to discuss these questions at your convenience if that would be of
assistance. You may contact me at my office at 828.586.5189, extension 203, or by email
at dharbaugh©twsanc.us.
Sincerely,
Daniel E. Harbaugh
Executive Director
Tuckaseigee Water and Sewer Authority
CC: Project File
McGill Associates, PA