Summary of Congaree Riverkeeper’s Position on Alpine Utilities NPDES Permit
 
·         Congaree Riverkeeper supports DHEC’s identification of Alpine Utilities as a temporary treatment facility in the permit consistent with the Central Midlands 208 plan. This plan calls for the eventual elimination of all wastewater discharges into the Lower Saluda as a result of the construction of regional wastewater collection infrastructure. If DHEC has the authority to impose a timeline for the consolidation of wastewater discharges along the Lower Saluda, we request that they develop and enforce a timeline for all utilities discharging into this reach of river.
 
·         Congaree Riverkeeper supports DHEC’s requirement to increase the sampling frequency for Fecal Coliform from once a week to once every weekday. This will result in increased attention on this parameter; however, Alpine Utilities Discharge Monitoring Reports demonstrate that this facility has had repeated violations of other water quality parameters including ultimate oxygen demand, 5 day biological oxygen demand, pH, total suspended solids, ammonia-nitrogen, total recoverable cadmium, total recoverable lead, total residual chlorine, as well as both 7 day chronic effluent toxicity tests. Please see the Discharge Violations below for more details. Congaree Riverkeeper asks that the sampling frequency be increased to once every weekday not only for Fecal Coliform, but for all other parameters which they have violated in the last 5 years. 
 
 
·         Alpine Utilities previous permit limits for water quality parameters are based on a Monthly Averages as well as Daily Maximum limits. The new permit limits are based on Monthly Averages and now Weekly Averages. Congaree Riverkeeper asks that, for the parameters which have been violated within the last 5 years, DHEC require the permit limits to continue based on Monthly Averages as well as Daily Maximum limits.