NC0088684_Fact Sheet_20200904

FACT SHEET FOR EXPEDITED PERMIT RENEWALS
This form must be completed by Permit Writers for all expedited permits which do not require
full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile
home parks, etc) that can be administratively renewed with minor changes, but can include
facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing,
instream monitoring, compliance concerns).
Basic Information for Expedited Permit Renewals
Permit Writer / Date
Brianna Young 9/4/2020
Permit Number
NCO088684
Facility Name / Facility Class
Daniel Stowe Botanical Garden WTP / PCNC
Basin Name / Sub -basin number
Catawba / 03-08-37
Receiving Stream / HUC
UT to Catawba River (Lake Wylie) /
03050101150
Stream Classification / Stream Segment
WS-V, B / 11- 123.5
Does permit need Daily Maximum NH3
limits?
N/A
Does permit need TRC limits/language?
N/A
Does permit have toxicity testing? IWC (%) if
so
Yes; IWC = 90%
Does permit have Special Conditions?
Yes — Discharge alternatives analysis
Does permit have instream monitoring?
No (discharge is to a dry ditch
Is the stream impaired on 303 d list)?
Yes — PCB fish tissue advisory
Any obvious compliance concerns?
Yes — failing toxicity
Any permit mods since lastpermit?
None
New expiration date
8/31/2025
Comments on Draft Permit?
Yes — See Section 7 below
Section 1. Facility Overview:
The Daniel Stowe Botanical Garden WTP operates a membrane (RO) WTP utilizing a
water softener, designed for a potable flowrate of 0.00056 MGD and a wastewater
discharge of 0.00029 MGD. The facility generates backflow with an intermittent
discharge 7 days a week for 4 hours. The maximum, monthly average discharge between
May 2017 and May 2020 was 0.00262 MGD.
Per the renewal application: The reverse osmosis system at the Garden's Orchid
Conservatory functions to purify the water supply for hand irrigation and a high pressure
fog system that maintains proper humidity in the greenhouse. Well water supplies the
purification system and wastewater is delivered to a nearby unnamed tributary of
Catawba Creek via underground storm drainage.
Sludge management plan: Monthly solids build up monitoring is provided by a
contractor, and the 5,000 gallon tank is pumped once a year in March or April to ensure
the lines remain cleared. Contents are disposed into the contractor's State approved
Kaiser Road site owned by Dennis Willis Septic Services in Cherryville, NC.

Section 2. Compliance History (April 2015 — April 2020):
• 3 NOVs for TSS daily max exceedances
• 1 NOV for late/missing DMR
• Failed 8 of the last 12 toxicity tests
303(d) listing:
11-(123.5]a CATAWBA RIVER (Lake Wylie below elevation 5701 North Carolina portion
From the upstream side of Paw Creek Arm of Lake Wvlle to North Carolina -South Carolina State Line
or Area 11 4,294 jUnits JJFW Acres IlPrevious ALI
Assessment Criteria Status Reasanfor Rating Parameter of Interest Category�
Exceeding Criteria Fish Consumption Advisory PCB Fish Tissue Advisory {Advisory, FC, NQ C
Section 3. RPA:
The maximum monthly average flow between May 2017 and May 2020 was 0.00262
MGD.
• Copper — RP; Monthly monitoring with limit applied
• Zinc — RP; Monthly monitoring with limit applied
Section 4. NCG59 General Permit Eligibility:
• They use membrane/RO treatment technology, therefore they are not eligible
• Conclusion: They are not eligible for the NCG59
Section 5. Changes from previous permit to draft:
• Updated eDMR footnote inA(1) and language in A(5)
• Updated outfall map
• Added facility grade in A(1)
• Updated language on the Supplement to Permit Cover Sheet
• Added components list on Supplement to Permit Cover Sheet based on flow
schematic submitted for renewal
• Flow monitoring increased to 2/Month in a(1) to match most frequently
monitored parameters per current WTP guidance
• Duration of discharge monitoring added in A(1) as instantaneous flow monitoring
is required
• pH and TDS monitoring increased to 2/month per 2012 WTP guidance
• Turbidity monitoring in A(1) increased to monthly per 2012 WTP guidance
• Limits added for copper and zinc and monitoring increased to monthly based on
RPA in A(1)
o Compliance schedule added as A(4) for new copper and zinc limits
• Hardness monitoring added in A(1) per current WTP guidance

• Removed former footnote #2 stating "Monitoring should be conducted in
conjunction with whole effluent toxicity testing" as this is no longer required per
2012 WTP guidance
• Updated tox language in A(2)
• Discharge alternatives analysis condition kept in permit as A(3) with a reduced
timeline as analysis not done as required per previous permit
Section 6. Changes from draft to final:
• None
Section 7. Comments received on draft permit:
• Jeff Wuilliez (via email through Elena Potter on 8/20/2020):
o Engineering services have been retained and a scope of work and
associated costs provided to get the RO system running properly,
efficiently, and with an effluent that is in compliance with State
guidelines. The RO was shut down shortly after receiving notice from the
state, and has remained shut down since. The permittee anticipates the RO
system will not start processing water until all necessary repairs have been
completed and the effluent TDS is within compliance.
o With regard to Item No. 6 in the letter, permittee asks that in consideration
of the steps taken that reporting will be allowed to continue as one per
month instead of the proposed two per month.
o DWR response: Flow, pH, and TDS were increased from monthly to
2/month in accordance with the Division's current water treatment plant
guidance. As such, the monitoring will remain at 2/month for these
parameters.

NPDES Implementation of Instream Dissolved Metals Standards — Freshwater
Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by
the NC Environmental Management Commission (EMC) on November 13, 2014. The
US EPA subsequently approved the WQS revisions on April 6, 2016, with some
exceptions. Therefore, metal limits in draft permits out to public notice after April 6,
2016 must be calculated to protect the new standards - as approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW,
µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW,
µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form.
Aquatic life standards for Mercury and selenium are still expressed as Total
Recoverable Metals due to bioaccumulative concerns (as are all human health
standards for all metals). It is still necessary to evaluate total recoverable aquatic
life and human health standards listed in 15A NCAC 213.0200 (e.g., arsenic at 10
µg/l for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for
aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise
under 15A NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/1
Cadmium,Acute
WER*{1.136672-[lnhardness](0.041838)] e^{0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters
WER* {1.136672-[ln hardness](0.041838)] e^{0.9151 [ln hardness]-3.6236}
Cadmium,Chronic
WER* {1.101672-[ln hardness](0.041838)] e^{0.7998[ln hardness]-4.4451 }
Chromium III, Acute
WER*0.316 e^{0.8190[lnhardness]+3.7256}
Chromium III, Chronic
WER*0.860 e^{0.8190[lnhardness]+0.6848}

Copper, Acute
WER*0.960 e^10.9422[ln hardness]-1.7001
Copper, Chronic
WER*0.960 e^10.8545[ln hardness]-1.7021
Lead, Acute
WER* 11.46203-[ln hardness](0.145712)) • e^11.273 [In hardness]-1.4601
Lead, Chronic
WER*11.46203-[ln hardness](0.145712)) • e^11.273[In hardness]-4.705}
Nickel, Acute
WER*0.998 • e^10.8460[ln hardness]+2.2551
Nickel, Chronic
WER*0.997 • e^10.8460[ln hardness]+0.05841
Silver, Acute
WER*0.85 • e^11.72[ln hardness]-6.591
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^10.8473[ln hardness]+0.8841
Zinc, Chronic
WER*0.986 e^10.8473[ln hardness]+0.8841
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards.
However, application of the dissolved and hardness -dependent standards requires
additional consideration in order to establish the numeric standard for each metal of
concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream
(upstream) hardness and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR
122.45(c). The discharge -specific standards must be converted to the equivalent total
values for use in the RPA calculations. We will generally rely on default translator values
developed for each metal (more on that below), but it is also possible to consider case -
specific translators developed in accordance with established methodology.
RPA Permitting Guidance/WQBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each
metal of concern, based on recent effluent data, and calculate the allowable effluent
concentrations, based on applicable standards and the critical low -flow values for the
receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or
acute), the discharge has reasonable potential to exceed the standard, which warrants a
permit limit in most cases. If monitoring for a particular pollutant indicates that the
pollutant is not present (i.e. consistently below detection level), then the Division may
remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit
Writer compiles the following information:

• Critical low flow of the receiving stream, 7Q 10 (the spreadsheet
automatically calculates the IQ 10 using the formula IQ 10 = 0.843
(s7Q 10, CfS) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of
concern and for each individual discharge, the Permit Writer must first determine
what effluent and instream (upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test
results for any hardness data and contacts the Permittee to see if any additional
data is available for instream hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial
evaluation using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)).
Minimum and maximum limits on the hardness value used for water quality
calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal
showing reasonable potential, the permit writer contacts the Permittee and
requests 5 site -specific effluent and upstream hardness samples over a period of
one week. The RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as
follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) x (s7Q 10, cfs *Avg. Upstream
Hardness, mjg/L)
(Permitted Flow, cfs + s7Q 10, cfs)
The Combined Hardness for acute is the same but the calculation uses the IQ 10
flow.
3. The permit writer converts the numeric standard for each metal of concern to a
total recoverable metal, using the EPA Default Partition Coefficients (DPCs) or
site -specific translators, if any have been developed using federally approved
methodology.

EPA default partition coefficients or the "Fraction Dissolved" converts the
value for dissolved metal at laboratory conditions to total recoverable metal
at in -stream ambient conditions. This factor is calculated using the linear
partition coefficients found in The Metals Translator: Guidance for
Calculating a Total Recoverable Permit Limit from a Dissolved Criterion
(EPA 823-B-96-007, June 1996) and the equation:
Cdiss = 1
Ctotal 1 + { [Kpo] [SS(l+a)] [10-6] }
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L
used, and
Kpo and a = constants that express the equilibrium relationship between
dissolved and adsorbed forms of metals. A list of constants used for each
hardness -dependent metal can also be found in the RPA program under a
4. The numeric standard for each metal of concern is divided by the default partition
coefficient (or site -specific translator) to obtain a Total Recoverable Metal at
ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist
(ie. silver), the dissolved numeric standard for each metal of concern is divided by
the EPA conversion factor to obtain a Total Recoverable Metal at ambient
conditions. This method presumes that the metal is dissolved to the same extent as
it was during EPA's criteria development for metals. For more information on
conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total
allowable concentration (permit limits) for each pollutant using the following
equation:
Ca = (s7Q 10 + Qw)(Cwgs) — (s7Q 10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3*
(µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q 10)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity
and human health through the consumption of water, fish, and shellfish from
noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background
concentrations
Flows other than s7Q 10 may be incorporated as applicable:
IQ 10 = used in the equation to protect aquatic life from acute toxicity

QA = used in the equation to protect human health through the
consumption of water, fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each
pollutant of concern. Data entered must have been taken within four and one-half
years prior to the date of the permit application (40 CFR 122.21). The RPA
spreadsheet estimates the 95th percentile upper concentration of each pollutant.
The Predicted Max concentrations are compared to the Total allowable
concentrations to determine if a permit limit is necessary. If the predicted max
exceeds the acute or chronic Total allowable concentrations, the discharge is
considered to show reasonable potential to violate the water quality standard, and
a permit limit (Total allowable concentration) is included in the permit in
accordance with the U.S. EPA Technical Support Document for Water Quality -
Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules
in accordance with the EPA Headquarters Memo dated May 10, 2007 from James
Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent
chromium and hexavalent chromium Water Quality Standards. As a cost savings
measure, total chromium data results may be used as a conservative surrogate in
cases where there are no analytical results based on chromium III or VI. In these
cases, the projected maximum concentration (95th %) for total chromium will be
compared against water quality standards for chromium III and chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the
discharge, are inserted into all permits with facilities monitoring for hardness -
dependent metals to ensure the accuracy of the permit limits and to build a more
robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this
permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness
Default value
(mg/L)
25
[Total as, CaCO3 or (Ca+Mg)]
Average Upstream Hardness
Default value
(mg/L)
25
[Total as, CaCO3 or (Ca+Mg)]
7Q 10 summer (cfs)
0
BIM S
1 Q 10 (cfs)
0
RPA
Permitted Flow (MGD)
0.00262
Max, monthly flow average
for previous 36 months

Young, Brianna A
From: Elena Potter <[e-mail]>
Sent: Tuesday, October 13, 2020 12:23 PM
To: Young, Brianna A; Jim Hoffman
Subject: RE: [External] RE: Issued NPDES Permit for Daniel Stowe Botanical Garden WTP
(NC0088684)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Document received, accessible, and have saved/printed.
Thank you,
Elena Potter
From: Young, Brianna A [mailto:[e-mail]]
Sent: Tuesday, October 13, 2020 11:24 AM
To: Elena Potter <[e-mail]>; Jim Hoffman <[e-mail]>
Subject: RE: [External] RE: Issued NPDES Permit for Daniel Stowe Botanical Garden WTP (NC0088684)
Elena,
Thank you for your response. Attached is the issued NPDES permit for the Daniel Stowe Botanical Garden WTP
(NC0088684). Please respond to this email confirming that you received the attached document, were able to open
and view the document, and have saved/printed a copy for your records.
Thank you,
Brianna Young, MS
Environmental Specialist II
Compliance and Expedited Permitting Unit
Division of Water Resources
NC Department of Environmental Quality
Office: 919-707-3619
Brian na.Young(a�ncdenr.gov
Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle
your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.

From: Elena Potter <[e-mail]>
Sent: Tuesday, October 13, 2020 11:20 AM
To: Young, Brianna A <[e-mail]>; Jim Hoffman <[e-mail]>
Subject: [External] RE: Issued NPDES Permit for Daniel Stowe Botanical Garden WTP (NC0088684)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hello Brianna,
Please accept this as verification that transmittal of documents electronically is acceptable.
Thank you,
Elena Potter
Elena Potter
Executive Assistant and HR Manager
6500 South New Hope Road I Belmont, NC 28012
Office: 704-829-1290
From: Young, Brianna A[mailto:[e-mail]]
Sent: Friday, October 09, 2020 7:49 AM
To: Jim Hoffman <[e-mail]>
Cc: Elena Potter <[e-mail]>
Subject: Issued NPDES Permit for Daniel Stowe Botanical Garden WTP (NC0088684)
Good morning,
In order to provide more convenience, control, and security to our permittees and assist them in processing their
transactions, the Division of Water Resources is currently transitioning towards electronic correspondence. This will
hopefully provide more efficient service to our permittees and other partners and will allow us to more effectively
process and track documents. We are writing to ask you for your approval of the transmittal of documents related
to your permitting and related activities with the Division in an electronic format. Documents will be emailed to the
appropriate contact person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an electronic manner is
acceptable to you. If you have any questions, please feel free to contact me.
Thank you,
Brianna Young, MS
Environmental Specialist II
Compliance and Expedited Permitting Unit
Division of Water Resources
NC Department of Environmental Quality
Office: 919-707-3619

Brian na.Young(a�ncdenr.gov
Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle
your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.

AFFIDAVIT OF INSERTION OF ADVERTISEMENT
The Gaston Gazette
Gastonia, N.C.
Gaston County
The Gaston Gazette does certify that the advertisement for:
PUBLIC NOTICE North Carolina Environmental Management Commi
1617 Mail Service
Measuring 8.44 inches appeared in The Gaston Gazette, a newsr
Gaston County, Gastonia, N.C., in issues)
07/23/2020
NOTICE
North Carolina Environmental
Management Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES
Wastewater Permit
the North Carolina Environmental Managemen
:ommission proposes to issue a NPDES wastewater,
iischarge permit to the person(s) listed below. Writ
an comments regarding the proposed permit will be
accepted until 30 days after the publish date of this
totice. The Director of the NC Division of Water Re
sources (DWR) may hold a public heanng shoulc
here be a significant degree of public interest.
'lease mail comments and/or information request'
o DWR at the above address. Interested persons
nay visit the DWR at 512 N. Salisbury Street, Ra.
nigh, NC to review information on file. Additional in-
>rnation on NPDES permits and this notice may be
)und on our website: http1/deo.nc.aov/about
twe Conservancy has requested renewal
'DES PermR NCO088684 for the Daniel Stowe
iical Garden WTP in Gaston County. This per
I discharge is reverse osmosis reject water to
lamed tnbulary to the Catawba River (Lake Wit
the Catawba River Basin. This discharge may
t future allocations in this portion of the river
2020
Name of Account NCDENR—Division of Water Resources — Gazette
Order Number 54605858
Ad Number 54747010
Sworn to, and subscribed before me this 23 rd day of July, 2020.
Print Name (Classified R resentative) Signature (Classifi epresentative)
, Stephanie B. Sisk, Notary Public
�i� My Commission Expires March 23, 2025
• NQ���� •y Z'
...........Jc`�

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
MEMORANDUM
To: Clinton Cook
NORTH CAROLINA
Environmental Quality
September 4, 2020
NC DEQ / DWR / Public Water Supply
Mooresville Regional Office
From: Brianna Young
Compliance and Expedited Permitting Unit
Subject: Review of Draft NPDES Permit NCO088684
Daniel Stowe Botanical Garden WTP
Gaston County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
October 3, 2020. If you have any questions on the draft permit, please contact me at 919-707-3619 or
via e-mail [[e-mail]].
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
RESPONSE: (Check one)
❑Concur with the issuance of this permit provided the facility is operated and maintained properly,
the stated effluent limits are met prior to discharge, and the discharge does not contravene the
designated water quality standards.
Fx_�Concurs with issuance of the above permit, pr-e.,idea the following eenditions are met:*
* I have no appreciable expertise in implementation of the Clean Water Act requirements
and have minimal understanding of the information provided. As a result, I have no basis
for opposing the permit.
F-1 Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signed:
a
Date: October 8, 2020
N(1HTH f:A�i(1!_INAD E Q�;
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919,707,9000

Young, Brianna A
From: Elena Potter <[e-mail]>
Sent: Monday, August 24, 2020 3:15 PM
To: Young, Brianna A
Subject: [External] Re: Draft NDPES permit for Daniel Stowe Botanical Garden WTP
(NC0088684)
Attachments: 08 20 2020 Ltr re Permit Draft_Signed.pdf; EQ-220S10 Daniel Stowe Botanical
Gardens.xls.pdf
OWNa
xternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to @ nc. g ov
Good afternoon Brianna,
Please see attached letter in response to your email dated August 18, 2020.
Thank you,
Elena Potter
Elena Potter
Executive Assistant and HR Manager
6500 South New Hope Road I Belmont, NC 28012
Office: 704-829-1290
From: Young, Brianna A <[e-mail]>
Sent: Wednesday, July 22, 2020 7:34 AM
To: Elena Potter <[e-mail]>
Subject: Draft NDPES permit for Daniel Stowe Botanical Garden WTP (NC0088684)
Good morning Elena,
Attached is a copy of the draft NPDES permit for the Daniel Stowe Botanical Garden WTP (NC0088684) which is now
out to public notice. A hard copy of this draft permit has been placed in the mail to you as well. Please provide any
comments by August 215t
Thank you,
Brianna Young
Environmental Specialist II
Compliance and Expedited Permitting Branch
Division of Water Resources
Department of Environmental Quality
Office: 919-707-3619

Brian na.Young(a�ncdenr.gov
Mailing address:
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.

August 20, 2020
Brianna Young
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
VIA: E-mail and USPS Mail
Re: Draft NPDES Permit NCO088684
Dear Ms. Young:
We are in receipt of your letter dated ,duly 22, 2020 regarding the draft permit referenced above. After careful
review, we would like the following taken into consideration prior to issuing a final permit.
Efforts have been actively underway to correct reporting concerns as follows:
d,
Hydro Services & Supplies, inc. (Hydro) engineer services were retained in July to devise a scope of work and
provide associated costs to get the reverse osmosis (RO) system running g property, efficiently, and with an effluent
that isin compliance with State guidelines.
On August, 19, 2020, we received a report and quote for replacement of RO control board, feedwater solenoid
valve, and low-pressure switch (see enclosed quote).
The RO was shut down shortly after receiving the aforementioned notice from the State, and has remained shut
doixm since. We anticipate the RO system will not start processing water until all necessary repairs have been
complet
ed k.1 Hydra, and the effluent TDS is within compliance.
With regard to Item No.. 6 in your letter, we ask that in consideration of the steps taken ghat reporting will be
allowed to continue as one per month instead of the proposed two per month.
Please let me know if you have further .questions regarding this matter. Thank you.
Sincerely,
i�iI Yr uillfVWz
Director a, f Hol
-ticulture and Facilities
Enclosure/ep: Quote No. 220S06-0
6500 South New Hope Road I Belmont, NC 128012
4

QUOTATION
Page: 1 / 1
Date: August 7, 2020
Quotation #220S06-0
yii�W��
Service and Supplies
To:
Attn: Jeffrey Wuilliez
Daniel Stowe Botanical Garden
6500 South New Hope Road
Belmont, NC 28012
704-829-1282
From:
Hydro Service & Supplies. Inc.
Tony Dimino
513 United Drive
Durham, NC 27713
919-544-3744
REFERENCE
TERMS
FREIGHT
DELIVERY
'Iw
NET 30
Prepaid
2 Weeks
EQUIPMENT
PART #
I QTY
I PRICE
I PER
EXTENSION
Hydro shall provide one (1) replacement RO Controller and
feed water solenoid valve for the existing Mario MRO-3600-
4-LP.
Replacement Parts
Valve Solenoid NC 3/4" Mario
68176
1
ea
Feedwater Low Pressure Switch, 10E-10
99971-1
1
ea
Circuit Board for S100 Controller
99971-2
1
ea
Labor
Installation Labor
04991
1
Is
Notes:
- Sales Tax is not included with this quotation.
- Freight is included.
- Installation and Start -Up labor is included.
SIGNATURE
FREIGHT
SUBTOTALTOTAL
$25.00
$ 2,061.00
$ 2,086.00

August 20, 2020
Brianna Young
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
VIA: E-mail and USPS Mail
Re: Draft NPDES Permit NCO088684
Dear Ms. Young:
RECEIVED
AUG 2 j 2020
NCL)'c-OTVVR/1VPDES
We are in receipt of your letter dated July 22, 2020 regarding the draft permit referenced above. After careful
review, we would like the following taken into consideration prior to issuing a final permit.
Efforts have been actively underway to correct reporting concerns as follows:
Hydra Services & Supplies, Inc. (Hydro) engineer services were retained in July to devise a scope of work and
provide associated costs to get the reverse osmosis (RO) system running properly, efficiently, and with an effluent
that is in compliance with State guidelines.
On August, 19, 2020, we received a report and quote for replacement of RO control board, feedwater solenoid
valve, and low-pressure switch (see enclosed quote).
The RO was shut down shortly after receiving the aforementioned notice from the State, and has remained shut
down since. We anticipate the RO system will not start processing water until all necessary repairs have been
completed by Hydro, and the effluent TDS is within compliance.
With regard to Item No. 6 in your letter, we ask that in consideration of the steps taken that reporting will be
allowed to continue as one per month instead of the proposed two per month.
Please let me know if you have further questions regarding this matter. Thank you.
Sincerely,
Jeff Wuilliez
Director of Horticulture and Facilities
Enclosurc/op: Quote No. 220S06-0
6500 South New Hope Road I Belmont, NC 128012

QUOTATION
To:
Attn: Jeffrey Wuilliez
Daniel Stowe Botanical Garden
6500 South New Hope Road
Belmont, NC 28012
704-829-1282
Page: 1 / 1
Date: August 7, 2020
Quotation #220S06-0
From:
Hydro Service & Supplies. Inc.
Tony Dimino
513 United Drive
Durham, NC 27713
919-544-3744
REFERENCE
TERMS
FREIGHT
DELIVERY
lw
NET 30
Prepaid
2 Weeks
EQUIPMENT
PART #
QTY
PRICE
PER
EXTENSION
Hydro shall provide one (1) replacement RO Controller and
feed water solenoid valve for the existing Mario MRO-3600-
4-LP.
Replacement Parts
Valve Solenoid NC 3/4" Mario
68176
1
ea
Feedwater Low Pressure Switch, 10E-10
99971-1
1
ea
Circuit Board for S100 Controller
99971-2
1
ea
Labor
Installation Labor
04991
1
Is
Notes:
- Sales Tax is not included with this quotation.
- Freight is included.
- Installation and Start -Up labor is included.
SIGNATURE
FREIGHT
SUBTOTAL
$25.00
$ 2,061.00
$ 2,086.00

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
Facility Name
WWTP/WTP Class
NPDES Permit
Outfal I
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
❑ CHECK IF HQW OR ORW WQS
Daniel Stowe Botanical Garden WTP
PCNC
NCO088684
001
0.003
UT to Catawba River (Lake Wylie)
030501011502
W S-V, B
❑� Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1 Q10s (cfs)
0.00
0.00
0.00
0.00
0.00
Effluent Hardness
----
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
25 mg/L (Avg)
---------------�����
25 mg/L (Avg)
25 m /L
--------_---------
25 m /L
Data Source(s)
I —I CHECK TO APPLY MODEL
Par01
Par02
Par03
Par04
Par05
Par06E
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name w4s Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
0.5899
FW
3.2396
ug/L
Chlorides
Aquatic Life
NC
230
FW
r
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
117.7325
FW
905.0818
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
Ng/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
Ng/L
Copper
Aquatic Life
NC
7.8806
FW
10.4720
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
2.9416
FW
75.4871
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
37.2313
FW
335.2087
Ng/L
Nickel
Water Supply
NC
25.0000
WS
N/A
Ng/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
0.2964
ug/L
Zinc
Aquatic Life
NC
126.7335
FW
125.7052
ug/L
NCO088684 RPA - Freshwater, input
9/4/2020

H1
Date Data
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
H2
Use"PASTE SPECIAL
Effluent Hardness Values" then "COPY• Upstream Hardness
. Maximum data
points = 58
Use"PASTE SPECIAL
Values" then "COPY'
. Maximum data
points = 58
BDL=1/2DL Results
Date
Data BDL=1/2DL Results
25 25 Std Dev. N/A
1
25 25 Std Dev. N/A
Mean
25.0000
2
Mean
25.0000
C.V.
0.0000
3
C.V.
0.0000
n
1
4
n
1
10th Per value
25.00 mg/L
5
10th Per value
25.00 mg/L
Average Value
25.00 mg/L
6
Average Value
25.00 mg/L
Max. Value
25.00 mg/L
7
Max. Value
25.00 mg/L
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
NCO088684 RPA - Freshwater, data
-2- 9/4/2020

REASONABLE POTENTIAL ANALYSIS
Par05
Chlorides
Use "PASTE SPECIAL -
Values" then "COPY".
Pall
Copper
Maximum data points =
58
Date Data
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
1
11/17/2015
20
20
Std Dev.
3.1411
1
11/17/2015
16
16
Std Dev.
2
12/15/2015
14
14
Mean
14.3
2
12/15/2015
25
25
Mean
3
1/12/2016
15
15
C.V. (default)
0.6000
3
1/12/2016
35
35
C.V.
4
2/10/2016
11
11
n
6
4
2/10/2016
38
38
n
5
3/8/2016
12
12
5
3/8/2016
34
34
6
4/19/2016
14
14
Mult Factor =
2.1
6
4/19/2016
44
44
Mult Factor =
7
Max. Value
20.0 mg/L
7
6/14/2016
26
26
Max. Value
8
Max. Pred Cw
42.8 mg/L
8
9/13/2016
32
32
Max. Pred Cw
9
9
12/13/2016
18
18
10
10
3/7/2017
32
32
11
11
6/13/2017
42
42
12
12
9/26/2017
34
34
13
13
12/19/2017 <
5
2.5
14
14
3/20/2018
24
24
15
15
6/19/2018
9
9
16
16
9/25/2018 <
5
2.5
17
17
12/11/2018
8.6
8.6
18
18
3/19/2019
8
8
19
19
6/18/2019
5
5
20
20
12/10/2019
11
11
21
21
3/10/2020
5
5
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
Use 'PASTE SF
Values" then "I
Maximum c
points = 5
21.5048
0.6474
21
1.37
44.00
60.28
NCO088684 RPA - Freshwater, data
-3- 9/4/2020

REASONABLE POTENTIAL ANALYSIS
ug/L
ug/L
Par21
Use 'PASTE SPECIAL
Zinc
Values" then "COPY"
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
11/17/2015
38
38
Std Dev.
94.1612
2
12/15/2015
41
41
Mean
82.6429
3
1/12/2016
51
51
C.V.
1.1394
4
2/10/2016
138
138
n
21
5
3/8/2016
60
60
6
4/19/2016
80
80
Mult Factor =
1.62
7
6/14/2016
39
39
Max. Value
393.0 ug/L
8
9/13/2016
45
45
Max. Pred Cw
636.7 ug/L
9
12/13/2016
35
35
10
3/7/2017
39
39
11
6/13/2017
< 5
2.5
12
9/26/2017
32
32
13
12/19/2017
17
17
14
3/20/2018
70
70
15
6/19/2018
14
14
16
9/25/2018
33
33
17
12/11/2018
393
393
18
3/19/2019
211
211
19
6/18/2019
246
246
20
12/10/2019
50
50
21
3/10/2020
101
101
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-4-
NCO088684 RPA - Freshwater, data
9/4/2020

Daniel Stowe Botanical Garden WTP
NCO088684 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD) =
0.0026
WWTPIWTP Class:
PCNC
1Q10S (cfs) =
0.00
IWC% @ 1Q10S =
100
7Q10S (cfs) =
0.00
IWC% @ 7Q10S =
100
7Q10W (cfs) =
0.00
IWC% @ 7Q10W =
100
30Q2 (cfs) =
0.00
IWC% @ 30Q2 =
100
Avg. Stream Flow, QA (cfs) =
0.00
IW%C @ QA =
100
Receiving Stream: UT to Catawba River (Lake Wylie) HUC 030501011502 Stream Class:
WS-V, B
Outfall 001
Qw = 0.00262 MGD
COMBINED HARDNESS (mg/L)
Acute = 25 mg/L
Chronic = 25 mg/L
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS WATER SUPPLY
Effluent Hard: 0 value > 100 mg/L
Effluent Hard Avg = 25 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
~
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
a
M
Applied
Chronic Acute
n # Det. Max Pred Cw Allowable Cw
d
StandAcute:
NO WQS
Chlorides
NC
230 FW
mg/L
6 6
42.8
Note: n < 9
C.V. (default)
Chronic: 230.0
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
No value > Allowable Cw
Monitoring required
Acute: 10.47
RP shown - apply Monthly Monitoring with Limit
Copper
NC
7.8806 FW 10.4720
ug/L
21 19
60.28
_ _ -----------------------------------------
Chronic: 7.88
RP shown - apply Monthly Monitoring with Limit
17 values > Allowable Cw
Acute: 125.7
RP shown - apply Monthly Monitoring with Limit
Zinc
NC
126.7335 FW 125.7052
ug/L
21 20
636.7
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 126.7
RP shown - apply Monthly Monitoring with Limit
4 values > Allowable Cw
NCO088684 RPA - Freshwater, rpa
Page 5 of 50 9/4/2020

MONITORING REPORT(MR) VIOLATIONS for:
Report Date:
04/23/2C Page
1 of 1
Permit: nc0088684
MRS Betweel 4 - 2015 and 4 - 2020
Region:
%
Violation Category:%
Program Category:
Facility Name: %
Param Nam(%
County:
%
Subbasin: %
Violation Action: %
Major Minor: %
PERMIT: NCO088684
FACILITY: Daniel Jonathan Stowe Conservancy - Daniel Stowe
COUNTY: Gaston
REGION: Mooresville
Botanical Garden WTP
Limit Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT OUTFALL
LOCATION PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
03-2017 001
Effluent Solids, Total Dissolved
03/07/17
Monthly
mg/I
500
1,050
110
Daily Maximum
Proceed to NOV
Exceeded
10-2017 001
Effluent Solids, Total Dissolved
10/30/17
Monthly
mg/I
500
864
72.8
Daily Maximum
Proceed to NOV
Exceeded
03-2018 001
Effluent Solids, Total Dissolved
03/20/18
Monthly
mg/I
500
578
15.6
Daily Maximum
Proceed to NOV
Exceeded
Reporting Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT OUTFALL
LOCATION PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
11 -2015
12/31/15
Late/Missing DMR
No Action, BPJ
08-2016
10/01/16
Late/Missing DMR
Proceed to NOV
09-2019
10/31/19
Late/Missing DMR
No Action, BPJ

DocuSign Envelope ID: 1313AOC9-E741-4413-83F1-801D77EC52AD
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL #:
RETURN RECEIPT REQUESTED
Ms. Elena Potter
Daniel Jonathan Stowe Conservancy
6500 S New Hope Road
Belmont, NC 28012
Dear Ms. Potter:
NORTH CAROLINA
Environmental Quality
5/27/2020
Subject: Notice of Violation NOV-2020-PC-0246
Failure to Submit Discharge Alternatives Evaluation
Daniel Stowe Botanical Garden WTP
NPDES permit NCO088684
Gaston County
Per the terms of your NPDES permit found in Part I, Condition A. (2), you were required to
submit a Discharge Alternatives Evaluation to the Division along with the submission of the next
permit renewal application due 6 months prior to permit expiration on August 31, 2020. Our
records indicate that as of the date of this letter, the Discharge Alternatives Evaluation has not
been received.
Failure to submit a Discharge Alternatives Evaluation to the Division is a violation of the terms
of your permit, subjecting you to a possible assessment of civil penalties. In order to reduce the
risk of receiving additional enforcement action, you must complete and submit a Discharge
Alternatives Evaluation.
Based upon the above facts, I conclude as a matter of law that the Daniel Jonathan Stowe
Conservancy violated or failed to act in accordance with the requirements of NPDES Permit
NCO088684 and G.S. 143-215.1(b). A civil penalty of not more than $25,000.00 per violation
may be assessed against a person who fails to file, submit, or make available any documents,
data, or reports required by G.S. 143-215. 1 (b). The State's enforcement costs in this matter may
be assessed pursuant to G.S. 143-215.3(a)(9) and G.S. 143-282.1(b)(8).
If you wish to provide additional information regarding the noted violations and prevent further
action, please respond in writing within ten (30) days of receipt of this notice.
Please ensure that the Discharge Alternatives Evaluation is sent in to the Division. A review of
your response will be considered and you will be notified of any civil penalties that may be
D Q713—�
3 North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CPAOLINR �
O.M, .^t M F.W. W uuA 919.707.9000

DocuSign Envelope ID: 1313AOC9-E741-4413-83F1-801D77EC52AD
Mr. Hudson
Page 2 of 2
assessed regarding these violations. If no response is received in this Office within the 30-day
period, a civil penalty may be assessed.
If you have any questions about this letter or discharge monitoring reports, please contact
Brianna Young at 919-707-3619 or via e-mail at [e-mail].
Sincerely,
DocuSigned by:
8328B44CE9EB4A1...
S. Daniel Smith, Director
Division of Water Resources, NCDEQ
cc: Central Files
NPDES Program Files
Mooresville Program Files

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Daniel Jonathan Stowe Conservancy
I Attn: Elena Potter
28012
PS Form 3800, April 2015 PSN 7530-02-000-9047
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Daniel Jonathan Stowe Conservancy
Attn: Elena Potter
6500 S New Hope Road
Belmont, NC 28012
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Daniel Jonathan Stowe Conservancy
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6500 S New Hope Road
Belmont, NC 28012
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Daniel Jonathan Stowe Conservancy
°'
Attn-, Elena Potter
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6500 S New Hope Road
-----------------
r`
Belmont, NC 28012
-----------------
PS Form April 2015r rrr•r•

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• Yau may purchase Certified Mail service with
signee to be at least 21 years of age (not
Frst-Class Mail®, First -Class Package Service®,
or Priority Mail® service.
available at retail).
- Adult signature restricted delivery service, which
■ Certified Mail service is notavailable for
requires the signee to be at least 21 years of age
and provides delivery to the addressee specified
intemabonai mail.
■ Insurance coverage is notavailable for purchase
by name, or to the addressee's authorized agent
with Certified Mail service. However, the purchase
(not available at retail).
of Certified Mail service does not change the
insurance coverage automatically included with
■ To ensure that your Certified Mail receipt is
accepted as legal proof of mailing, it should bear a
certain Priority Mail items.
■ For an additional fee, and with a proper
USPS postmark. if you would like a postmark on
this Certified Mail receipt, please present your
endorsement on the mailpiece, you may request
Certified Mail item at a Post office'" for
If you don't need a postmark on this
the following services:
. Return receipt service, which provides a record
postmarking.
Certified Mah receipt, detach the barcoded portion
of delivery (including the recipient's signature).
You can request a hardcopy return receipt or an
of this label, affix it to the mailpiece, apply
appropriate postage, and deposit the mailpiece.
electronic version. For a hardcopy return receipt,
complete PS Form 3811, Domestic Return
Receipt, attach PS Form 3811 to your mailpiece;
iMPOHTAfir save this receipt for your records.
pS.Form 3800, Apol 2015 (Reverse) PSN 7530-02-000-9047

Young, Brianna A
From: Elena Potter <[e-mail]>
Sent: Thursday, June 18, 2020 11:04 AM
To: Young, Brianna A
Subject: Re: [External] Re: Daniel Stowe Botanical Garden WTP (NC0088684)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
�[e-mail]
Good morning,
Just following up on this. Dennis Willis Septic Services is contracted to check our systems and report conditions monthly
to our facility. Once a year, they provide pumping services and dump contents into their State approved Kaiser Road site
owned by Dennis Willis Septic Services in Cherryville, NC. Also, regarding the flow data, I received a call from Ori Tuvia
from the Mooresville office and he explained we need to report the flow in millions per day not what the meter directly
shows. I am working with our reporting lab to correct the information in the system.
Please let me know if there is anything else we need to be aware of or provide.
Thank you,
Elena Potter
From: Young, Brianna A <[e-mail]>
Sent: Thursday, June 4, 2020 7:36:08 AM
To: Elena Potter <[e-mail]>
Subject: RE: [External] Re: Daniel Stowe Botanical Garden WTP (NC0088684)
Good morning Ms. Potter,
I received your email from May 29t". I apologize for not responding yet as I was waiting for guidance from other DWR
staff on one aspect. In regards to the solids management plan, a response via email is sufficient. It looks like
you provided a partial response, but a complete response should include how frequency the solids are
removed as well as where they are disposed of (ex: landfill, land applied, etc.). Please provide a complete
solids plan that addresses all aspects of sludge management. Thank you for the clarification on the flow
data. I am waiting to hear back from other DWR staff regarding this. Once I receive an answer, I will reach
back out to you.
Thank you,
Brianna Young

Environmental Specialist II
Compliance and Expedited Permitting Branch
Division of Water Resources
Department of Environmental Quality
Office: 919-707-3619
Brian na.Young(oncdenr.gov
Mailing address:
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Elena Potter <[e-mail]>
Sent: Wednesday, June 03, 2020 10:10 AM
To: Young, Brianna A <[e-mail]>
Subject: [External] Re: Daniel Stowe Botanical Garden WTP (NC0088684)
Importance: High
• kExternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
Hello Brianna,
I am in receipt of your letter dated May 27, 2020 regarding failure to submit discharge alternatives evaluation. I sent you
a follow up email on the 29", see below, and have not heard back if the information provided is satisfactory. Could you
please either give me a call at 704-829-1290 or email me and let me know?
Thank you,

Elena Potter
dsb .or
From: Elena Potter
Elena Potter
Executive Assistant
6500 South New Hope Road I Belmont, NC 28012
Office: 704-829-1290
ClLac�ebook�.com CI-LiLwitter.com ' )Jil nstagram.coml
Sent: Friday, May 29, 2020 4:35 PM
To: Young, Brianna A <[e-mail]>
Subject: Re: [External] Re: Daniel Stowe Botanical Garden WTP (NC0088684)
Hi Brianna,
We are finally starting to hold some limited business hours and so I apologize for not getting back to you
sooner in regards to this. For the solids report, do you need a separate report or am I able to just provide an
explanation in my reply email to your questions. Based on records, we have monthly solids build up
monitoring provided by Dennis Willis who also has our 5,000 gallon tank pumped once a year to ensure lines
remain cleared right before our usual busy season in March or April. Unfortunately, since we've been closed
for business, they have not been able to come to the site since March.
I reached out to our lab that does our sampling about the reported numbers, and it appears that at some
point they started providing us the total gallons number that the meter read. I think she said her name is

Gosha, with K&W, ran the daily rate and said there was not much difference from your referenced numbers
from October 2019 numbers to present.
This is what K&W sent over as explanation:
Month
October
November
December
January
February
March
Total Gallons
689199
697270
708898
713166
718123
718123
8071/33
11628/28
14268/31
4033/46
924/12
4834/37
Rai
1246
1415
1138
88
66
131
Rate
Please let me know if this clarifies the information you are seeking. If you would like to discuss further, please
give me a call Wednesday between the hours of 9 am and 2 pm. This is the only time I am physically at the
office, otherwise feel free to email me.
Thank you,
Elena Potter
From: Young, Brianna A <[e-mail]>
Sent: Tuesday, May 26, 2020 2:02 PM
To: Elena Potter <[e-mail]>
Cc: Jeff Wuilliez <[e-mail]>; Patrick Larkin <[e-mail]>
Subject: RE: [External] Re: Daniel Stowe Botanical Garden WTP (NC0088684)
Good afternoon Elena,
I hope you are doing well. I saw that the paperwork giving Mr. Wuilliez and yourself signature authority has been
submitted. Do you have an update on the remaining items requested? Per our database, the flow data is still as in my
previous email, and I have not seen or received the items required in Section 15 of the permit renewal application (flow
schematic and solids management plan).
Thank you,
4

Brianna
Brianna Young
Environmental Specialist II
Compliance and Expedited Permitting Branch
Division of Water Resources
Department of Environmental Quality
Office: 919-707-3619
Brian na.Young(�Ocdenr.gov
Mailing address:
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Elena Potter <[e-mail]>
Sent: Friday, April 24, 2020 10:36 AM
To: Young, Brianna A <[e-mail]>
Cc: Jeff Wuilliez <[e-mail]>; Patrick Larkin <[e-mail]>
Subject: [External] Re: Daniel Stowe Botanical Garden WTP (NC0088684)
• External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
��m(@nc.gov
Hi Brianna,
We were in the process of getting Jeff signatory authorization around the time that major changes were happening at
Daniel Stowe with closure of the Garden and stay-at-home orders issued. We will follow up on this and submit the
proper forms as soon as possible to finish authorizing Jeff as our Director of Horticulture.
Also, I had already submitted a request to the reporting administrator to remove Todd Beasley and Christine Cordy as
signors since they are not employed by the Garden anymore and haven't been for some time. I will follow up on this as
well.
Thank you for bringing this to our attention and we'll be in touch to address the other items in your email shortly.
Thanks,
Elena Potter
fdsbq.orql
Elena Potter
Executive Assistant
6500 South New Hope Road I Belmont, NC 28012
Office: 704-829-1290
Ufacebook.coml ©ftwitter.coml ' _) finstagram.coml
[dsbg.orgl [dsbg.orgl [dsbg.orgl [dsbg.orgl

From: Young, Brianna A <[e-mail]>
Sent: Friday, April 24, 2020, 10:11 AM
To: Elena Potter
Cc: Jeff Wuilliez
Subject: Daniel Stowe Botanical Garden WTP (NC0088684)
Good afternoon,
I am reviewing the permit renewal application for the Daniel Stowe Botanical Garden WTP (NC0088684), and had a few
comments.
The application was signed by someone not listed in our database. The permit application must be signed by
someone with permit signature authority. Please either resubmit the permit application with a signature from
Elena Potter, Todd Beasley, or Christine Cordy, or submit the proper paperwork to request Jeffrey Wuilliez be
given permit signature authority. The Delegation of Signature Authority Form can be found on our website at
https://deg.nc.gov/about/divisions/water-resources/water-quality-permitting/npdes-wastewater/npdgs-
compliance-and-0, under the "Reporting Forms" section.
2. The permit application was submitted without a solids handling plan or a flow schematic. Per Section 15 of the
permit renewal application, both of these items are required. Please review Section 15 of the permit application
for all information related to what is required.
The flow volume reported to the Division since November 2019 is not consistent in magnitude with previous
monitoring data. A summary of flow data from the Division's database is below. Please review all DMRs and
submit corrected DMRs is needed.
Date
Flow Volume
(MGD)
6/18/2019
0.000241
7/26/2019
0.000552
8/14/2019
0.00262
10/28/2019
0.000471
11/12/2019
697270
12/10/2019
708898
1/10/2020
713166
2/25/2020
717199
In order for review to continue on the permit renewal request, all of the above items must be addressed. Please let me
know if you have any questions.
Thank you,
Brianna Young
Environmental Specialist II
Compliance and Expedited Permitting Branch
Division of Water Resources
Department of Environmental Quality
Office: 919-707-3619
Brian na.Young(cDncdenr.gov

Mailing address:
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.

NPDES Permit NCO088684
Daniel Stowe Botanical Garden
Schematic of Flow
RAW WATER SUPPLY WATER SOFTENER
3.8 GPM =* 3.8 GPM
01
RO PRODUCT RO SYSTEM
2.5 GPM to SERVICE 3.8 GPM FEEDWATER
RO REJECT
1.3 GPM to STORM*
*RO Reject water flows through —50OLF of storm drain before introduction to surface water at outfall.

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Gary Wilson
Daniel Stowe Botanical Garden
6500 South New Hope Road
Belmont, NC 28012
Dear Mr. Wilson:
f }Y
NORTH CAROLINA
Ertlrleanmertmal Qggarrty
June 7, 2019
Subject: Compliance Evaluation Inspection
Daniel Stowe Botanical Garden WTP
NPDES Permit No. NCO088684
Gaston County
Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted
at the subject facility on May 22, 2019, by Ori Tuvia. Your cooperation during the site visit was
much appreciated.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Ori Tuvia at [phone], or at
[e-mail].
Sincerely,
DocuuSiigned by:
A14CC681 AF27425...
W. Corey Basinger
Regional Supervisor
Mooresville Regional Office
Division of Water Resources
Cc: NPDES Unit, MRO Files (Laserfiche)
Christine Cordy (E-copy)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704 663 1699

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 15 1 3 I NCo088684 111 12 I 19/05/22 I17 18 i d 19 i G i 201
21111111IIIIIIIIIIIIIIIIII1IIIIII IIIIIIIIIII f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
1.0 70 71 [„ I 72 l-1 L �, � 73 L_LJ74 751 1 1 1 1 LU80
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
12:40PM 19/05/22
16/05/01
Daniel Stowe Botanical Garden WTP
6500 S New Hope Rd
Exit Time/Date
Permit Expiration Date
Belmont NC 28012
01:45PM 19/05/22
20/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Gary Wilson///
Not Required/ORC/919-807-6353/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Chris Gardner,6500 S New Hope Rd Belmont NC 28012//704-825-4490/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
Ori A Tuvia �_r— MRO WQ//704-663-1699/ 6/7/2019
cc�
ERRQc;7A?r)P:n17AQR
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger Division of Water Quality//704-2,
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
e� 6/7/2019
AtaccsatAl=vazs... Page#

NPDES yr/mo/day Inspection Type
NCO088684 I11 12, 19/05/22 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

Permit: NCO088684 Owner - Facility: Daniel Stowe Botanical Garden WTP
Inspection Date: 05/22/2019 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
M
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: The subject permit expires on 8/31/2020.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
M
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported CM
Are DMRs complete: do they include all permit parameters?
0
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
0
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
0
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
0
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: Monthly DMRs and COCs were reviewed for January 2019 throuqh March 2019.
Records
reviewed were well organized and maintained. Facility staff was requested to record weekly
site visits as well as maintenance Dreformed
Laboratory
Yes No NA NE
Page# 3

Permit: NCO088684 Owner - Facility: Daniel Stowe Botanical Garden WTP
Inspection Date: 05/22/2019 Inspection Type: Compliance Evaluation
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: K & W Laboratories (certification #559) has been contracted to provide analytical support
and subcontracts the whole effluent toxicity testing to Meritech.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
❑
❑
representative)?
Comment: The permit reauires arab samples for all reauired Darameters. which are collected in the
manhole outside the orchid conservatory. All effluent samples and associated water quality
readings (PH) are collected by staff from the contracted analytical laboratory (K & W
Laboratories
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
❑
❑
Is flow meter calibrated annually?
❑
❑
❑
Is the flow meter operational?
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
❑
Comment:
Page# 4

Permit: NC0088684
Inspection Date: 05/22/2019
Owner - Facility: Daniel Stowe Botanical Garden WTP
Inspection Type: Compliance Evaluation
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
0
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
MEI
Comment: At the time of the inspection discharge at the outfall appeared clear with no foam.
Right of
way to the outfall should be maintained.
Page# 5

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Daniel Jonathan Stowe Conservancy
Attn: Jeffrey Wuilliez, Dir. of Horticulture
6500 S New Hope Rd
Belmont, NC 28012
Subject: Permit Renewal
Application No. NCO088684
Daniel Stowe Botanical Garden WTP
Gaston County
Dear Applicant:
NORTH CAROLINA
Environmental Quality
February 27, 2020
The Water Quality Permitting Section acknowledges the February 27, 2020 receipt of your permit renewal application and
supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting
branch. Per G.S. 150E-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deg.nc.ciov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
SIncerel
Wren
Administrative Assistant
Water Quality Permitting Section
ec: WQPS Laserfiche File w/application
N.-irth CsroBns Departrnsnt of Env:ianmertal YUEGt} Divs3zn of Water 6esouiws
-E i,°z,7resvJ!e IOffics I M East Center Ave nue,SutoSOX I IV, orEesvl!e, North Csroeina 28115

cr
Daniel Stowe Botanical Garden
February 24, 2020
Wren Thedford
NC DENR / DWR / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Permit Renewal Application
Permit No. NCO088684
Mr. Thedford:
A Garden for all Seasons!
RECEIVED
FEB 2 7 82@
NCDEQ/DWR/NPDES
Enclosed please find the completed and signed renewal application and supporting
documentation for the above referenced permit number. No changes have been made
since the previously submitted application in 2015.
The reverse osmosis system at the Garden's Orchid Conservatory functions to purify
the water supply for hand irrigation and a high pressure fog system that maintains
proper humidity in the greenhouse. Well water supplies the purification system and
wastewater is delivered to a nearby unnamed tributary of Catawba Creek via
underground storm drainage.
If you have any additional questions, please feel free to contact me at [phone] or
[e-mail].
Sincerely,
Wiere Wuilliez
Horticulture & Facilities Director
Enclosures/ep
Helianthur rrbweinitzii
Federally rndangered species protected at the Gard-
'*', Recycled Paper
6500 S. New Hope Rd.
Belmont, NC 28012
704.825.4490
704.829.1240 (fax)
www.DSBG.org

NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Mail the complete application to:
NCDEQ / DWR / NPDES
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number NC0088684
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Daniel Jonathan Stowe Conservancy
Daniel Stowe Botanical Garden
6500 South New Hope Road REGEWE D
Belmont FEB 2 7 2020
NC 28012 NCDEO/DMIRES
[phone]
[phone]
[e-mail]; [e-mail]
2. Location of facility producing discharge:
Check here if same as above
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name N/A
Mailing Address
City
State / Zip Code
Telephone Number ( )
Fax Number ( )
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
Pagel of 3 Version 6/2017

NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
5. Type of treatment plant:
❑ Conventional (Includes coagulation, flocculation, and sedimentation, usually followed by
filtration and disinfection)
❑ Ion Exchange (Sodium Cycle Cationic ion exchange)
❑ Green Sand Filter (No sodium recharge)
® Membrane Technology (RO, nanofiltration)
Check here if the treatment process also uses a water softener
6. Description of source water(s) (i.e. groundwater, surface water)
Well water
7. Describe the treatment process(es) for the raw water:
The raw water passes through a water softener and is then purified by a reverse osmosis system.
The purified water is used for irrigation and also supplies a high pressure misting system inside
a conservatory.
8. Describe the wastewater and the treatment process(es) for wastewater generated by the
facility:
The characteristics of the wastewater haven been documented in which the existing NPDES
discharge permit has been maintained in good standing. Ultimately delivered to a nearby creek
via underground storm drainage.
9. Number of separate discharge points: 1 Outfall Identification number(s) 001
10. Frequency of discharge: Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs: Seven Duration: 4 hours
11. Plant design potable flowrate 0.00056 MGD
Backwash or reject flow 0.00029 MGD
12. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
UT Catawba Creek
13. Please list all water treatment additives, including cleaning chemicals or disinfection
treatments, that have the potential to be discharged.
Alum / aluminum sulfate Yes No X
Page 2 of 3 Version 6/2017

NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Iron sulfate / ferrous sulfate Yes No X
Fluoride Yes No X
Ammonia nitrogen / Chloramines Yes No X
Zinc -orthophosphate or sweetwater CP1236 Yes No X
List any other additives below:
14. Is this facility located on Indian country? (check one)
Yes ❑ No
15. Additional Information:
Provide a schematic of flow through the facility, include flow volumes at all points in
the water treatment process. The plan should show the point[s] of addition for
chemicals and all discharges routed to an outfall [including stormwater].
Solids Handling Plan
16. NEW Applicants
Information needed in addition to items 1-15:
New applicants are strongly recommended to contact a permit coordinator with the
NCDENR Customer Service Center.
Was the Customer Service Center contacted? ❑ Yes ® No
Analyses of source water collected
Engineering Alternative Analysis
Discharges from Ion Exchange and Reverse Osmosis plants shall be evaluated using a
water quality model.
17. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Jeffrey Wuilliez Director of Horticulture
Printed name of Person Sienina Title
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in any application,
record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that
Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21
or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5
years, or both, for a similar offense.)
Page 3 of 3 Version 6/2017

Daniel Jonathan Stowe Conservancy
6500 South New Hope Road, Belmont 28102
R�ceivine Stream: UT to Catawba River (Lake Wylie) Stream Clacc: WS-IV, B
Stream Scoment: 11-023.5) Sn - a, i
Draina:e Basin: Catawba alh 03-08-07
Latitude: at 1 b 13" Lon itu 030501011502
State Grid/l' .0 (l� U: G 14NF / Belmont, NC aak: R 24.000 R"
_ 1:24.000
Facility
ocation
I Not to Scale
NPDES Pennit .4
Gaston County