HomeMy WebLinkAboutNC0001376_permit issuance_20100326NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
' March 26, 2010
Mr. John Lancaster
Riverplace, LLC
P. 0. Box 31568
Raleigh, NC 27622
Subject: Issuance of Renewal NPDES Permit
NPDES Permit NC0001376
Riverplace WWTP
Wake County
Class 11
Dear Mr. Lancaster:
A response was sent to you regarding your questions and comments on the subject draft permit,
and on your current activities and anticipated future plans. After further evaluation the Division has
approved issuing this renewal for the subject permit with an expiration date of February 28, 2013,
corresponding to the next scheduled Neuse River permits renewal date.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007
(or as subsequently amended).
Summary of Changes in Renewal Permit from Existing Permit
1) Effluent Permitted Flow Limit, BOD Limits, Total Suspended Solids (T55) Limits, Ammonia as
Nitrogen (NH3 N) Limits, and Total Phosphorus (TP) monitoring were changed. The influent is
considered a reduced intermittent domestic wastewater and stormwater source. Therefore:
- Permitted flow limit was reduced, reported flow must be total flow over a 24-hour day and no
reported flow means no flow event,
- NH3-N limits were removed, changed to monitoring only,
- BOD and TSS limits were changed to secondary treatment standards, and
- TP sampling frequency was reduced to monthly.
2) Effluent Fecal Coliform Limits with weekly monitoring were added. As a domestic treatment system
compliance with the Fecal Coliform secondary standard is required.
3) Effluent parameters COD, Total Chromium, Color, Total Copper, Phenols, Sulfides, and Total Zinc
were removed. These parameters are not applicable for this domestic discharge at this time.
Page 1 of 2
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-807-63001 FAX: 919-807-64951 Customer Service: 1-877-623-6748
Internet: http:/ / h2o.state.nc.us /
An Equal Opportunity 1Affrmative Action Employer
NorthCarolina
Naturattg
4) Effluent Chronic Toxicity Limit and monitoring was removed. This parameter is not applicable at thi's
time.
5) Effluent Total Nitrogen Limits (TNL) and Total Nitrogen Load Allocation Limits (TNLAL) were added.
The Neuse River Basin nutrient rules assigned a TNLAL to this discharge in 1997 and was deeded to
a third party in 1999 leaving this discharge with a "zero" TNLAL and a "zero" TNL tolerance. This
permit was revised to state the applicable TNL and TNLAL limits. Footnotes and special conditions
to clarify calculations, minimum reportable level, and the nutrient rule were added.
6) Effluent Nitrite/Nitrate Nitrogen and Total Kje/dahl Nitrogen reporting were added. These
parameters are measured to calculate the Total Nitrogen (TN) value. Footnotes were added to
define minimum detection and reporting requirements. . 11r
7) Effluent conditional Total Residual Chlorine (TRC) Limit .with 2/weekly monitoring and footnote
narrative was added. The applicable conditional TRC water quality standard (WQS) with narrative is
stated for compliance.
8) lnstream monitoring was removed. These data are not needed at this time.
9) A Special Condition A. (5.) was added. This condition established the reporting steps with
milestones to design, to implement equipment changes, and to eliminate the discharge before the
next renewal.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings
(6714 Mail Service Center, Raleigh, North Carolina 27699-6714). , Unless such demand is made, this
decision shall be final and bipding.
Please note. that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other federal or local
governmental permits that may be required.
If you have any questions concerning this permit, please contact Ron Berry at telephone number
(919) 807-6396.
Sincerely,
Ik p
Coleen H. Sullins
Attachments
Cc: Raleigh Regional Office/Surface Water Protection Section (email)
EPA Region IV/Marshall Hyatt (email)
Central Files
NPDES Unit
Page 2 of 2
NC0001376
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
► i
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended, the
Riverplace II, LLC
is hereby authorized to discharge wastewater from a facility located at the
Riverplace WWTP
9701 Capital Boulevard
North of Raleigh
Wake County
to receiving waters designated as Neuse River in the Neuse River Basin in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective May 1, 2010.
This permit and authorization to discharge shall expire at midnight on February 28, 2013.
Signed this day March 26, 2010.
-�f
Coleen H.-Sullins, Director f'
Division of Water Quality
By Authority of the Environmental Management Commission
NC0001376
SUPPLEMENT TO PERMIT COVER SHEET
All pre vious NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and pro visions included herein.
Riverplace II, LLC
is hereby authorized to:
Continue to operate an existing wastewater treatment facility permitted for 0.002 MGD
treated domestic wastewater discharge located north of Raleigh at 970 Capital Boulevard in
Wake County, and consisting of:
0 Bar screen
0 Influent flow meter
0 Main influent flow splitter box
0 Two (2) aeration pond A and B
0 One (1) retention pond
0 Secondary flow splitter box
0 One (1) active clarifier A
0 Two (2) inactive clarifiers B and C (requires stormwater dewatering)
0 One (1) inactive polishing pond (requires stormwater dewatering)
0 One (1) inactive alum pond (requires stormwater dewatering)
0 One (1) inactive sludge pond (requires stormwater dewatering)
0 Nine (9) drying beds (used for stormwater dewatering, recycle to retention pond)
0 One (1) dried sludge storage basin
0 Effluent meter
0 Effluent composite sampler
0 Dual submerged discharge line
Discharge from said treatment works, through Outfall 001, into the Neuse River, a Class C,
NSW water in the Neuse River Basin, at the location specified on the attached map.
Riverplace If
VA7 TP F ad I Y
NCO001316
USGS Quad: D24NE Wake Forest, NC
Outfall Facility
Latitude: 350 541 30" N 350 54' 47" N
Longitude: 780 33, 81, W 780 33' 13" W
Stream Class: C, NSW
Subbasin: 03-04-02 HUC:03020201
,Receiving Stream: Neuse River
%r,t , 0 i- -
NCO001376
Discharge
14
3
I
Facility
Location
Riverplace 11 WWTP NC0001376
Wake County
Permit NC0001376
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
Monthly
Daily
Measurement
Sample Sample
CHARACTERISTICS
Averse
Maximum
Frequency
Type Location
Flow
0.002 MGD
Continuous
Recording Effluent
Total Monthly Flow (TMF)
Monitor and Report, MG
Monthly
Calculated Effluent
Total Residual Chlorine (TRC) 2
28 µg/L
2/Week
Grab Effluent
BOD, 5-day, 209 C
30.0 mg/L
45.0 mg/L
Weekly
Composite Effluent
Total Suspended Solids (TSS)
30.0 mg/L
45.0 mg/L
Weekly
Composite Effluent
Fecal Coliform
(Geometric mean)
200/100 mL
400/100 mL
Weekly
Grab Effluent
pH
Not more than 9.0 S.U. nor
Weekly
Grab Effluent
less than 6.0 S.U.
Dissolved Oxygen, mg/L (DO)
Not less than 5.0 mg/L,
Weekly
Grab Effluent
daily avers e
Temperature, °C
Weekly
Grab Effluent
Total Phosphorus (TP)
2.0 mg/L
Monthly
1 Composite Effluent
Total Kjeldahl Nitrogen (TKN) 3
Monitor anfi Report, mg/L
Monthly
Composite Effluent
Nitrite/Nitrate Nitrogen
(NO -N + NO -N)
Monitor and Report, mg/L
Monthly
Composite Effluent
Total Nitrogen (TIN) '3
0.0 mg/L
0.0 mg/L
Monthly
Calculated Effluent
TN = (NO -N + NO -N) + TKN
TN Load'
"0" Ibs per month 4
Monthly
Calculated Effluent
"0" Ibs per year 4
Annually
Calculated Effluent
TN Load = TN x TMF x 8.34
Ammonia as Nitrogen, mg/L
Monthly
Composite Effluent
(NH -N)
Footnotes:
1. Total Nitrogen Load is the mass quantity of Total Nitrogen (TN) discharged in a given time period
and thus requires Total Monthly Flow (TMF). See A. (2.) for details.
2. Total Residual Chlorine compliance is required for chlorine or chlorine derivative used for
disinfection, or if chlorinated water is in the source water. The Division shall consider all effluent TRC
values reported below 50 ug/L to be in compliance with the permit. However, the Permittee shall
continue to record and submit all values reported by a North Carolina certified laboratory (including
field certified), even if these values fall below 50 ug/L.
3. All quantities must be measured and reported to a minimum detection level; Nitrite/Nitrate Nitrogen
to a minimum of 0.01 mg/L, Total Kjeldahl Nitrogen to a minimum of 0.1 mg/L.
4. This facility has no Total Nitrogen Load allocation and therefore has a "0" Ibs per month and "0" Ibs
per year allocation limits. See A. (3.) and A. (4.) for details. "0" Ibs means the calculated Ibs is less
than 0.002 Ibs per month and 0.002 Ibs per year.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Permit NCO001376
A. (2.) CALCULATION OF TOTAL NITROGEN LOADS
a. The Permittee shall calculate monthly and annual TN Loads as follows:
Monthly TN Load (pounds/month) = TN x TMF x 8.34
where:
TN = the average Total Nitrogen concentration (mg/L) of the composite samples
collected during the month
TMF =' the Total Monthly'Flow of wastewater discharged during the month '
(MG/month)
8.34 = conversion factor, from (mg/L x MG) to pounds
ii. Annual TN Load (pounds/year) = Sum of the 12 Monthly TN Loads for the calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/L and pounds/month) in the
discharge monitoring report for that month and shall report each year's annual results
(pounds/year) in the December report for that year.
A. (3.) ANNUAL LIMITS FOR TOTAL NITROGEN
a. Total Nitrogen (TN) allocations and TN Load limits for NPDES dischargers in the Neuse River
basin are annual limits and a're applied for the calendar year.
b. For any given calendar year, the Permittee shall be in compliance with the annual TN Load
limit in this Permit if:
i. the Permittee's annual TN Load is less than or equal to said limit, or
ii. the Permittee is a Co-Permittee Member of a compliance association.
C. The TN Load limit in this Permit (if any) may be modified as the result of allowable changes in
the Permittee's TN allocation.
i. Allowable changes include those resulting from purchase of TN allocation from the
Wetlands Restoration Fund; purchase, sale, trade, or lease of allocation between the
Permittee and other dischargers; regionalization; and other transactions approved
by the Division.
ii. The Permittee may request a modification of the TN Load limit in this Permit to
reflect allowable changes in its TN allocation. Upon receipt of timely and proper
application, the Division will modify the permit as appropriate and in accordance
with state and federal program requirements.
iii. Changes in TN limits become effective on January 1 of the year following permit
modification. The Division must receive application no later than August 31 for
changes proposed for the following calendar year.
iv. Application shall be sent to:
NCDWQ / NPDES Unit
Attn: Neuse River Basin Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
d. If the Permittee is a member and co-Permittee of an approved compliance association, its TN
discharge during that year is governed by that association's group NPDES permit and the TN
limits therein.
i. The Permittee shall be considered a Co-Permittee Member for any given calendar
year in which it is identified as such in Appendix A of the association's group NPDES
permit.
ii. Association roster(s) and members' TN allocations will be updated annually and in
accordance with state and federal program requirements.
Permit NC0001376
(Continued from A. (4.) ANNUAL LIMITS FOR TOTAL NITROGEN)
ii i. If the Permittee intends to join or leave a compliance association, the Division must
be notified of the proposed action in accordance with the procedures defined in the
association's NPDES permit.
(1) Upon receipt of timely and proper notification, the Division will modify the
permit as appropriate and in accordance with state and federal program
requirements. ,
(-2) Membership changes in .a compliance association become effective on
January 1 of the year.following modification of the association's permit.
e. The TN monitoring and reporting requirements in this Permit remain in effect until expiration
of this Permit and are not affected by the Permittee's membership in a compliance
association.
A. W) TOTAL NITROGEN ALLOCATIONS
a. The following table lists the Total Nitrogen (TN) allocation(s) assigned to, acquired by, or
transferred to the Permittee in accordance with the Neuse River nutrient management rule
(T15A NCAC 02B .0234) and 'the status, of each as of permit issuance. For, compliance
purposes, this table does not supercede any TN limit(s) established elsewhere in this permit or
in the NPDES permit of a compliance association of which the Permittee is a Co-Permittee
Member.
ALLOCATION
ALLOCATION AMOUNT (1)
TYPE
SOURCE
DATE
STATUS
Estuary (lb/yr)
Discharge (lb/yr)
Base
Assigned by Rule
(T15A NCAC 02B .0234)
12/7/97
28,223.5
56,447
Active
Decremental Deeded to LNRA/City of Raleigh (z) 8/4/99
28,223.5
56,447
Deducted
TOTAL
0
0
Active
rootnote:
(1) Transport Factor = 50%
(2) Prior to ownership change to Riverplace II, LLC in November 1999.
b. Any addition, deletion, or modification of the listed allocation(s) (other than to correct
typographical errors) or any change in status of any of the listed allocations shall be
considered a major modification of this permit and shall be subject to the public review
process afforded such modifications under state and federal rules.
Permit NC0001376
A. (5.) IMPLEMENATION PLAN FOR ELIMINATION OF DISCHARGE
A discharge elimination implementation plan must be submitted to the Regional Office and NPDES
Unit no later than September 30, 2011. This plan must contain but is not limited to:
1) A final engineered -design to divert the current domestic wastewater influent to an acceptable
disposal alternative including connection to the regional sewer or other approved non -discharge
disposal method. This must include:
a) obtaining any additional required permits, '
b) a flow schematic clearly defining the new connection and the disconnect point to the
existing treatment facility influent, and
c) a timetable with the disposal option operational no later than December 31, 2012,
2) A final engineered -design to terminate flow to NPDES permit NC0001376 outfall as previously
agreed including elimination of stormwater discharge. This must include:
a) the permanent disconnect and isolation of the existing treatment facility,
b) the clean up and/or approved disposal steps for all equipment related items as outlined
by the Raleigh Regional Office, pursuant to permit rescission,
c) a stormwater control plan to eliminate stormwater discharge, or other approved
stormwater alternative, #
`
d) a timetable with the completion of items in a) through c) no later than December 31,
2012,
e) a narrative on the future dewatering activities that will be required for any remaining
impoundments.
3) Date for submittal of NPDES permit NC0001376 application for rescission.
Submit a copy of the plan to:
Raleigh Regional Office
NCDWQ/Surface Water Protection
Judy Garrett
1628 Mail Service Center
Raleigh, NC 27699-1628
and
NCDWQ / NPDES Unit
NPDES File
File: NC0001367
1617 Mail Service Center
Raleigh, NC 27699-1617
If this special condition A. (5.) is not met, the Division may issue a notice of violation and take
enforcement action.
4 «
DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0001376
Revised: 3/22/10
Facility Information
Applicant/Facility
Name:
Riverplace II WWTP (former Burlington Industries 5.0 MGD
WWTP)
Applicant Address:
P.O. Box 31568; Raleigh, North Carolina 27622
Facility Address:
9701 Capital Boulevard; Raleigh, North Carolina
27857
Permitted Flow
Estimated by DWQ 0.002 MGD
Type of Waste:
Commercial domestic (private)
Facility/Permit Status:
Class II /Active; Renewal/Modification
County:
Wake County
Miscellaneous
Receiving Stream:
Neuse River
Stream Classification:
C, NSW
Subbasin:
03-04-02
Index No.
27-(22.5)
Drainage Area (mi2):
NA
303(d) Listed?
No
Summer 7Q10 (cfs)
NA
Regional Office:
Raleigh
Winter 7Q10 (cfs):
NA
State Grid / USGS
Quad:
D24NE
Wake Forest, NC
30Q2 (cfs)
NA
Permit Writer_:
Ron Berry
Average Flow (cfs):
NA
Date:
3/22/10
IWC M:
NA
Other:
Nutrient rulet
BACKGROUND
The original. renewal application had been submitted by Burlington Industries in 1998, a
major textile industrial waste treatment discharge with a permitted flow of 5.0 MGD. Prior to
expiration and renewal of the permit Riverplace, LLC purchased the Burlington Industries
facility which had closed in 1999. The Divisions requested an ownership change notification
and a modified renewal application from Riverplace, LLC.
Riverplace, LLC indicated a large portion of the physical property that the treatment works
occupied was to be reclaimed for future property development. The previous owner
Burlington had removed the sludge from the treatment system. One important change was
that the previous Burlington Industries NPDES permit TN Load allocation was sold making
this a "zero" TN Load point source prior to Riverplace, LLC purchase.
Riverplace, LLC renewal application included a narrative on the termination of wastewater
discharge to the Neuse River after 2003 and phase -out, reclaimation of the existing
treatment works property. Plans called for two of the six ponds to remain operational, one
being the polishing pond for stormwater control, neither to discharge to the Neuse River
after 2003.
Because of expected continuing domestic wastewater, now and in the future, from the
existing building Riverplace, LLC had stated that either a permanent connection to the
regional sewer line from the Town of Wake Forest or a non -discharge alternative will be
installed prior to the end of 2003. A closing statement was made that no development to the
property would occur until a firm commitment had been received regarding the provisions
for a sanitary sewer.
Initially, a renewal draft permit was developed and proposed in November 2002 using BPJ
with an estimated 2,000 GPD domestic wastewater influent but was not issued pending
connection to regional POTW."
In 2006 Judy Garrett, Raleigh Regional Office noted stormwater routinely flowing from the
alum pond being discharged and not being monitored. A plug was installed in the alum pond
overflow pipe. Any dewatering activity currently required from the alum. pond is conducted
by pumping the pond to the drying beds which automatically drain to a sump and are
NPDES NC''WO1 70
Patti i of 4
pumped back to.aeration pond#2. A follow up inquiry to Riverplace, LLC in 2007 resulted in a
phone narrative that a pumping station and regional sewer connection was being designed.
Attempts to further determine the status and timeline for meeting the April 2001 application
narratives has been unsuccessful. Currently, EnviroLink a contracted ORC service, is visiting
the site, operating dewatering functions, supervising batch discharges of wastewater to the
outfall, taking effluent and instream samples, and completing ®MR and logs. It was
determined that no toxicity samples had been taken because the discharge events had not
occurred in any of the specified months listed in the active oermit.
The current owner continues to operate under the existing pre-1999 5.0 MGD permit (1) has
not connected to the regional POTW (2) and has not terminated discharge. In addition the
permit current TN Load allocation is "zero" but was not amended.
CURRENT 5.0 MGD TREATMENT PLANT OPEARTION
Domestic wastewater enters through a bar screen to the influent flow flume with meter and
totalizer, continues to one of two aeration ponds, then to a large retention pond. Aerators
may or may not be in service. Once the water level is above the retention pond outlet pipe
the ORC will manually open a value to allow the wastewater to flow to Clarifier A. Once the
flow stops (liquid level below outlet pipe) the ORC closes the value to Clarifier A. Clarifier B
and C have been disconnected from the process.
The wastewater continues from Clarifier A and flows through an effluent flume with meter
and totalizer where a composite sample can be taken. The polishing pond, sludge pond,
alum pond, Clarifier B and C, and drying beds are dewatered as needed to the retention
pond. The effluent flows through a gravity main to a submerged dual discharge in the Neuse
River.
Various aerators and pumps are operated for preventative maintenance. The influent and
effluent meters calibrations are maintained. Instream samples and effluent samples are
taken for every discharge event (about twice a year). No addition chemicals treatments such
as a chemical disinfectant are added.
EFFLUENT DATA REVIEW
Since domestic influent was a small intermittent volume, the operation of this large volume
treatment facility was a batch process followed by long periods of no discharge. The data
below shows actual discharge dates, recorded flow volumes, and parameter measurements,
Date
Flow
BOD
Tss
pH
NH3-N
77V
TP
MGD
(Mg/0
(MCl/1)
Is.U.)
(Mg/I
Imo//1
(mg/I)
3/19/01
0.298
3.3
2.3
7.96
0.02
0.78
4.76
3/22/01
0.128
2.1
3.3
7.99
0.02
1.18
0.50
1/31/02
0.088
2.9
5.3
7.53
0.16
0.04
4/11/02
0.232
3.8
3.8
7.72
0.02
2.72
0.17
10/18/02
0.424
58.0
3.7
45.95
0.78
0.79
0.38
2/27/03
a382
6.7
6.3
7.88
0.43
0.24
2/23/04
a430
6.8
24.0
7.29
0.20
1.68
0.06
11/1/04
0.796
2.7
2.2
6.83
0.54
1.76
0.16
1/13/05
a733
1.0
1.2
7.94
0.60
1.48
0.12
8/30/05
0.167
1.0
1.8
7.98
0.02
1.19
0.09
1/5/06
0.349
1.0
1.3
6.53
0.02
0.88
0.02
7/6/06
0.421
11.0
11.0
7.11
0.07
2.97
0.28
11/22/06
a431
3.4
5.7
7.08
1.34
2.70
0.06
10/10/08
0.476
5.2
15.0
6.89
0.72
1.77
0.13
The values in bold italics would be considered out of compliance with the proposed modified
permit.
Fact slloo!
Pi e 2 c+ 4
COD, Total Chromium, Total Cooper, Total Zinc, Total Phenols, Sulfides .
Several required parameters on the prevailing permit were unique to the original industrial
effluent. Based on the sample data submitted on the DMR the data was consistent with a
system that has no industrial source or residue.
Chronic Toxicity and DO
No samples were taken since discharge events did not occur in months specified in permit.
No data was available for DO.
PERMITTING STRATEGY
The Division needs resolution by the owner Riverplace, LLC to meet the terms as stated in
their 2001 modified renewal application where by (1) the domestic wastewater is collected
and discharged to the regional POTW, (2) the discharge to the Neuse River is terminated,
and (3) this permit is rescinded. This renewal permit will be issued for 33 months from the
effective date to match the next Neuse River renewal cycle. This permit must reflect the
standards applicable to this discharge. Therefore, this permit must show compliance with
Neuse River Basin nutrient rules.
The other required parameters must be applied in accordance with a privately -owned
domestic wastewater treatment facility using BPJ. A determined maximum flow (see below)
from the existing sanitary facilities and stormwater sources of 2,000 gallon per day will be
applied as the permitted flow.
Determination of maximum discharge flow:
35 gallons per employee per day = 700 gpd (gpd = gallons per day)
Intermittent flow for visitors = 500 gpd
Estimates miscellaneous, stormwater = 300 gpd
25% contingency 500 gpd
Total: 2,000 gpd
Effluent Limitations and Monitoring -Requirements
Flow BOD. TSS DO H Total Residual Chlorine Fecal Coliform Total Phosphorus, Total
Nitrogen, Total Nitrogen Load
All of these limited parameters will be in the renewal permit. Since flow is intermittent the
total flow discharged in any physical day (24 hours) must be reported. A new 0.002 MGD
permitted flow limit will be applied. For TN and TN Load the compliance value is "zero" which
means anytime a discharge occurs and Total Nitrogen is detected the permittee is out of
compliance. The permittee will have to submit a monthly calculated TN Load value for each
month. If disinfection by chlorination or chlorine derivatives is required then the Total
Residual Chlorine limit must be met.
Discussed minimum detection limits BAT EPA Method with Reedy Creek Lab, Nitrite/Nitrate
Nitrogen is 0.01 mg/L and TKN is 0.1 mg/L. If you assume maximum permitted flow at
minimum detection limit then 0.002 MGD x (0.1 mg/L + 0.01 mg/L) x 8.34 = 0.0018 lbs. Add
footnote narrative to nitrogen parameters to define minimum requirements.
Effluent Monitoring Requirements
Ammonia as Nitrogen, Nitrite Nitrate Nitrogen, Total Kieldahl Nitrogen, Temperature
All of these parameters must be measured and reported. If not already in the active permit
then they will be added to this permit. Ammonia as Nitrogen Limits will be removed from this
permit. ,
COD Total Chromium Total Copper, Total Zinc Total Phenols Sulfides
Based on the data there was no evidence that these suspect industrial residuals were
present in significant amounts to warrant further monitoring. Therefore, these parameters
will be removed from this permit. If future analysis indicates these compounds are present at
levels that exceed the prevailing water quality standards then they will be re-evaluated.
�('0001376
llq��e 3 uf'4
Chronic Toxicity
Based on BPJ this parameter will be removed from this permit.
Implementation Plan
This new condition must be followed and will be added to this permit.
Instream Monitoring
Based on BPJ this requirement will be removed from this permit.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: December 30, 2009
Permit Scheduled to Issue: March 2010
Expiration Date: February 28, 2013
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit,
please conta t Ron B rry at (919) 807-6396 or email ron.berry@ncdenr.gov.
li
NAME: DATE:
REGIONAL OFFICE COMMENTS
NAME: DATE:
SUPERVISOR: DATE:
rjC. S'9,ext.
Beverly Eaves Perdue
Governor
Mr. John Lancaster
Riverplace, LLC
P. O. Box 31568
Raleigh, NC 27622
Dear Mr. Lancaster:
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
March 10, 2010
Subject: Response to Comments on
NPDES Permit NC0001376
Riverplace WWTP
Wake County
Class II
Dee Freeman
Secretary
Draft Permit
The Division has reviewed your February 9, 2010 letter and has the following comments and
information.
Item 1) One purpose of A.(5.) is to clarify all types of wastewater that must be addressed through
the NPDES regulatory process. Under current regulations this includes stormwater. In a large
majority of cases stormwater may have its own individual permit. You are correct that in the permit
narrative stormwater is specifically not included. Again, we wanted to make you aware that this
permit cannot be used as a stormwater discharge.
Item 2) You are correct, any discharge will violate the TNLAL since you have no allocation. For
details on acquisition, compliance, or mitigation for nutrient requirements as a discharger into the
Neuse River see 15A NCAC 028.0234 Neuse River Basin - Nutrient Sensitivity Waters Management
Strategy.- Wastewater Discharge Requirements.
In your letter you discussed future plans to operate a drinking water treatment facility and
potentially continue discharge from this site. Please be aware the Division intentions are to not allow any
modification to this NPDES permit, for you to connect to the regional domestic treatment facility with your
sanitary waste, for you to decommission the existing treatment system including the proper disposal of
any waste residuals, and to have this permit rescinded.
Any future discharge activities on this site that are not already part of the draft permit narrative
coverage are considered a new discharge, and require you to follow the requirements for applying for a
new discharge in this segment of the Neuse River. There is no guarantee a new discharge wil I be allowed.
In regards to A. (5.) the narrative and conditions it contains are only applicable to the draft permit.
Page 1 of 2
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-807-63001 FAX: 919.807-64951 Customer Service: 1-877-623-6748
Internet: http:11 h2o.state.nc.us I
An Equal Opportunity 1 Affirmative Action Employer
Nne
orthCarolina
Naturally
r
We have received no other comments from the public on your draft permit. Your renewal permit is
scheduled for issuance by the end of March 2010. If you have any additional questions concerning the
permit for your facility, please call Ron Berry at (919) 807-6396 or by email at ron.berryPncdenr.gov.
Sincerely,
. A,, r
Ron Berry
Eastern NPDES Program
Attachments
Cc: Raleigh Regional Office/Surface Water Protection Section (email/copy of February letter attached)
Central Files (copy of February letter attached) ,
NPDES Unit (copy of February letter attached)
0
r � r
Page 2 of 2
n
U
n
R R p CE LLC
P.O. Box 31568, Raleigh, NC 27622 • 4509 Creedmoor Rd., Suite 102 Raleigh, 27612 • (919) 838-8484 Fax (919) 838-8425
February 9, 2010
111A
Mr. Ron Berr
y ffd
North Carolina Division of Water Quality Eastern NPDES Permit Program FEB 1 1 Z010
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: NC0001376 Draft Permit
Dear Mr. Berry,
Thank you for the opportunity to review and comment on Draft Permit NC0001376. Riverplace
received the permit on January 6, 2010 anti hoc reviewed the sub; draft per"':t �:^A O`i0 m %i;e
following comments. Please feel free to contact us for additional information or clarification.
1. Stormwater requirement Special Condition A. (5) Implementation Plan for Elimination of
Discharge. The Supplement To Cover Page in Paragraph 1 authorizes Riverplace to discharge
only "treated domestic wastewater' under this permit. However, Condition A. (5.) makes two
references to elimination of stormwater. Riverplace does not understand the inclusion of
stormwater in this permit and requests clarification or removal from the requirement.
2. Effluent Total Nitrogen Limits (TNL) and Total Nitrogen Load Allocation Limits (TNLAL).
Riverplace requests clarification and discussion to the statement made in the cover letter.
regarding compliance violations. Riverplace is concerned about the potential for violations
resulting from this statement and issuance of this permit.
Riverplace fully acknowledges the previous discussions held regarding this permit and facility. Since
that time Riverplace and Franklin County have entered into a Memorandum of Understanding and is
actively planning the use of this site for the withdrawal and treatment of potable water for delivery to
Franklin County.
While the Water Treatment Plant design has not been initiated, there is a potential that there could
be a need to continue discharge from this site. Riverplace is aware and will comply with NC DENR
requirements and to that end has held several meetings with various agencies, including DWR,
PWS, SEPA, and DWQ as it continues to make plans for this important project. Riverplace will
continue to work closely with NC DENR officials in order to ensure that reaulatory requirements are
met. Riverplace is not asking for any modification to the existing permit at this time but mentions this
issue here as it potentially may affect the future of this permit and will be included in the
Implementation Plan required in Condition A.(5.).
Again thank you for the opportunity to provide comment to this permit. If you have any further
comments, please feel free to contact either me or Michael Myers with questions or concerns.
pne
John Lancaster
River Place, LLC.
Berry, Ron
From: Hyatt.Marshall@epamaii.epa.gov
Sent: Tuesday, January 05, 2010 11:03 AM
To: Berry, Ron
Subject: re NC0001376, Riverplace LLC
EPA has no comments on this draft permit.
7i t� 1 1:0.3 AM
, dr ''je nit.
1
AFFIDAVIT OF PUBLICATION
NORTH CAROLINA.
Wake County.) Ss.
Public Notice
North Carolina Environmental
Management CommissiorVNPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES'Wastewater Permit
The North Carolina Environmental Man-
agement Commission proposes to issue a
NPDES wastewater discharge permit to
the Person(s) listed below.
mau comments anaior mtormarion re-
quests to DWQ at the above address. Inter-
ested persons may visit the DWQ at 512 N.
Salisbury Street, Raleigh, NC to review
information on file. Additional information
on NPDES permits and this notice may be
found on our website: www.ncwoterquollfy
.o►g, or by ca I I ing (919) 807-6304.
Riverplace, LLC requested renewal of Per-
mit NC0001376 for Riverplace WWTP in
Wake County. This permitted discharge is
treated domestic wastewater and storm -
water to the Neuse River, Neuse River
Basin.
N&O: January 2, 2010
Before the undersigned, a Notary Public of Chatham
County North Carolina, duly commissioned and authorized to
administer oaths, affirmations, etc., personally appeared Debra
Peebles, who, being duly sworn or affirmed, according to law,
doth depose and say that she is Accounts Receivable Specialist
of The News and Observer a corporation organized and doing
business under the Laws of the State of North Carolina, and
publishing a newspaper known as The News and Observer, in
the City of Raleigh , Wake County and State aforesaid,
the said newspaper in which such notice, paper, document, or
legal advertisement was published was, at the time of each and
every such publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of the General
Statutes of North Carolina, and that as such she makes this
affidavit; that she is familiar with the books, files and business
of said corporation and by reference to the files of said
publication the attached advertisement for NCDENR/ DWQ/
POINT SOURCE was inserted in the aforesaid newspaper
on dates as follows: 01/02/10
Account Number: 80763040
The above is correctly copied from the books and files of the aforesaid Corporation and publication.
Debra Peebles, Accounts Receivable Specialist
Wake County, North Carolina
Sworn or affirmed to, and subscribed before me, this
04 day of JANUARY , 2010 AD by, Debra Peebles
In Testimony Whereof, I have hereunto set my hand
and affixed my official seal, the day and year aforesaid.
Janet Scroggs, Nota u is
My commission expires 14th day of March 2014.
RE NC0001376- Riverplace
NCDENR
Phone: (919) 807-6396
Fax: (919) 807-6495
Office: Archdale Building Room 925N
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records
Law and may be disclosed to third parties.
From: Vinzani, Gil
sent: Thursday, December 03, 2009 10:38 AM
To: Poupart, Jeff
Cc: Berry, Ron; Garrett, Judy; Templeton, Mike
Subject: FW: N00001376- Riverplace
Jeff:
As you know, we have been stymied on this one for quite a while. It had been
reassigned to Ron, who
was working with Judy at RRO.
Gil
Gil Vinzani, Engineer
Eastern NPDES Program
919-807-6395
E-mail correspondence to and from this address may be subject to the NC Public
Records
Act
From: Templeton, Mike
sent: Thursday, December 03, 2009 10:09 AM
To: Poupart, Jeff
Cc: Vinzani, Gil; Belnick, Tom
Subject: FW: N00001376- Riverplace
Jeff -
It would probably be more appropriate for you to handle this permit question from
Marshall. I have
only followed Riverplace from a distance since late 2002, when I gave Dave a draft
permit to review. It
ended up in Gil's lap and he may a better idea about the facility's status.
The issue is that Riverplace has zero TN allocation and, although it discharges
infrequently, any
discharge is an exceedance under the Neuse TMDL and rule. They facility should also
have a permit
limit of zero, but we've been sitting on the permit since 2003 and the plant is
still operating under the
old Burlington Industries limits, with no TN limit. The owner assured me in 2002
that they would be
connecting to Raleigh or wake Forest in 2003, but the last I heard was that they
still discharge once or
twice a year (large industrial wwTP, now treating small amounts of domestic waste
and whatever
stormwater the system collects).
The draft permit I gave Dave included a TN limit of zero, effective 1/1/03 per the
Neuse rule, but we
discussed giving them a brief compliance schedule to allow time to connect or come
up with the
allocation. The RRO has inspected the facility a few times over the years but, as
far as I know, we
Page 2
RE NC0001376- Riverplace
haven't gotten anywhere with the permit.
- Mike T
From: Belnick, Tom
sent: Wednesday, December 02, 2009 5:16 PM
To: Hyatt.Marshall@epamail.epa.gov
Cc: Templeton, Mike
subject: N00001376- Riverplace
Marshall- I'm in training on wed/Thur, but caught your phone message about
Riverplace. I don't know
much about it- the previous owner (Burlington Industries, textile facility)
transferred their TN
allocation to Raleigh in 1999. Then in the same year Riverplace bought the site,
but still has no TN
allocation. No manufacturing in over a decade. I've copied Mike Templeton, who
might be able to add
some more info as to why permit has been backlogged.
Tom Belnick
Supervisor, NPDES west Program
NC DENR/Division of water Quality
1617 Mail Service Center, Raleigh, Nc 27699-1617
(919) 807-6390; fax (919) 807-6495
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records
Law and may be disclosed to third parties.
Page 3
[Fwd: Re: Riverplace LLC]
Subject: [Fwd: Re: Riverplace LLC]
From: Gil Vinzani <Gi1.Vinzani@ncmail.net>
Date: Fri, 21 Nov 2008 07:59:19 -0500
To: ron Berry <Ron.Berry@ncmail.net>
Ron:
I'll speak with you this afternoon about this one
yesterday, that I would like you to pick up.
Thanks,
Gil
Subject: Re: Riverplace LLC
From: Mike Templeton <Mike.Templeton@ncmail.net>
Date: Fri, 18 Jan 2008 09:04:58 -0500
To: Gil Vinzani <Gil.Vinzani@ncmail.net>
CC: Matt Matthews <matt.matthews@ncmail.net>, Susan A
It's one of the two I mentioned
Wilson <Susan.A.Wilson@ncmail.net>
Gil - Did Mike say how they were going to deal with the nitrogen issue? I'll say it again: This facility
has no allocation and should have been subject to a TN limit of 0.0 lb/yr as of l/1/03. Five years later,
this still don't have a limit. I recommend issuing the permit with the TN limit and a short -as -possible
compliance schedule. By not forcing the issue, we are allowing a discharge in violation of the TMDL
and giving others the impression that there is an opportunity for continuing, even expanding, the
discharge. This one could bite us if we don't do something about it pretty soon. - Mike T
Gil Vinzam wrote:
As you know, Riverplace is the oldest permit on our backlog. We have heard throughout the years
continual excuses on why they can't tie on right away to the Raleigh Neuse Plant. I just spoke with
Mike Myers, who is working with Riverplace IV (John Lancaster) to determine what they are going
to do.
The latest plan is that Franklin Country would utilize the site for the discharge of domestic waste.
This would let them avoid having to get an inter basin transfer certificate, since they want to take
water out of the Neuse Basin for use within the Tar -Pam.
I indicated to Mike that we were disappointed that there was not going to be a tie-in, and that we had
been looking forward to getting rid of this one. He is going to work on an Engineering Alternatives
Analysis, and send us a letter next week that has more details.
Gil
Gil Vinzani <Gil.vinzam(r),ncmail.net>
Supervisor, Eastern NPDES Program
NC Division of Water Quality
12,11]leg .J G
90
of 2 12/12/2008 2:14 PM
Re. Riverplace LLC
Subject: Re: Riverplace LLC
From: Mike Templeton <Mike.Templeton@ncmail.net>
Date: Fri, 18 Jan 2008 09:04:58 -0500
To: Gil Vinzani <Gi1.Vinzani@ncmail.net>
CC: Matt Matthews <matt.matthews@ncmail.net>, Susan A Wilson <Susan.A.Wilson@ncmail.net>
Gil - Did Mike say how they were going to deal with the nitrogen issue? I'll say it again: This facility
has no allocation and should have been subject to a TN limit of 0.0 lb/yr as of 1/l/03. Five years later,
this still don't have a limit. I recommend issuing the permit with the TN limit and a short -as -possible
compliance schedule. By not forcing the issue, we are allowing a discharge in violation of the'TMDL
and giving others the impression that there is an opportunity for continuing, even expanding, the
discharge. This one could bite us if we don't do something about it pretty soon. - Mike T
Gil Vinzani wrote:
As you know, Riverplace is the oldest permit on our backlog. We have heard throughout the years
continual excuses on why they can't tie on right away to the Raleigh Neuse Plant. I just spoke with
Mike Myers, who is working with Riverplace IV (John Lancaster) to determine what they are going
to do.
The latest plan is that Franklin Country would utilize the site for the discharge of domestic waste.
This would let them avoid having to get an inter basin transfer certificate, since they want to take
water out of the Neuse Basin for use within the Tar -Pam.
I indicated to Mike that we were disappointed that there was not going to be a tie-in, and that we
had been looking forward to getting rid of this one. He is going to work on an Engineering
Alternatives Analysis, and send us a letter next week that has more details.
Gil
of 1 11/20/2008 9:53 AM
OCT 600 2Z
AT6 ��
461,F;A
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Fact Sheet - NPDES Permit
FACILITY INFORMATION
Facility Name:
Permit Flow (MGD):
Facility Class:
Facility Status:
Permit Status:
County:
Regional Office:
USGS Topo Quad:
PROPOSED ACTION
Riverplace WWTP
0.002
Grade 2 Biological
Existing
North Carolina
Wake
Raleigh
Riverplace II, LLC
Riverplace WWTP
NPDES No. NC0001376
RECEIVING STREAM
Receiving Streams: Neuse River
Subbasin:
Index No.:
Stream Class:
303(d) Listed:
Use Support:
Drainage Area (miz):
Summer 7Q10 (cfs)
Winter 7010 (cfs):
3002 (cfs):
Average Flow (cfs):
IWC (%):
030402
C-NSW
Y
PS
Riverplace II, LLC, has applied for renewal of NPDES Permit No. NC0001376 for the Riverplace WWTP
in Wake County, north of Raleigh. The facility was formerly operated as the Burlington Industries
Wake Plant, a textiles mill permitted to discharge 5.0 MGD of treated industrial Wastewater.
The facility's current NPDES permit was issued to Burlington Industries on January 25, 1995, and
expired January 31, 1999. Burlington Industries ceased operations of the mill in 1996. Riverplace
purchased the facility in 1999 and converted it to commercial use.
Prior to the sale, Burlington Industries made timely application for renewal of its NPDES permit.
Riverplace subsequently submitted a revised application and a change -of -ownership request. Because
the original application was submitted at least 180 days prior to permit expiration, the permit was
administratively extended and continues to govern discharges from the facility.
The Division finds Riverplace's application to be acceptable and has made a tentative determination to
reissue the facility's permit with significant modifications, including:
• new effluent limitations and monitoring requirements consistent with the nature and scale of
the new operation, and
• new effluent limitations and monitoring requirements for Total Nitrogen (TN) and Total
Phosphorus (TP), consistent with the Neuse River Basin Nutrient Sensitive Waters rules and the
approved TN TMDL.
FACT SHEET - NPDES PERMIT Riverplace I1, LLC
DRAFT NPDES No. NC0001376
PERMITTED FACILITY
r The permitted facility was, until 1999, a textile mill owned and operated by Burlington Industries. It
was permitted to discharge up to 5.0 MGD of treated process and other wastewaters and was classified
as a NPDES "major' facility.
Riverplace purchased the facility in 1999 and has converted the former mill for warehouse, retail, and
office use. All wastewaters generated in the facility are sanitary wastes from employees (approx. 20)
and customers. None of the tenants or wastewaters are industrial in nature. The Division has requested
that EPA Region 4 reclassify Riverplace as a NPDES "minor" facility.
The sanitary wastewaters are currently treated in the existing 5.0 MGD treatment facility, and discharge
is to the Neuse River at Outfall 001. Riverplace has indicated it intends to eliminate its discharge to the
river. According to its permit application:
"The wastewater treatment plant at the former Wake Mill facility consisted of five
f ponds. The applicant plans to phase down over the 2 years to leave only tow ponds
operations. The pond currently employed as a polishing pond will be among those
retained. The remaining two ponds will be kept permanently for the purpose of
managing stormwater, but will not discharge to the Neuse River after 2003. Permits for
stormwater management will be obtained as required. The phased -out ponds will [sic]
emptied, allowed to dry, mucked out, and closed. Material mucked out of the ponds
will [sic] characterized according to applicable solid waste regulations and disposed of
accordingly.
"Wastewater continues to be contributed to the ponds from the restrooms in the
warehouse facility. This flow will continue to 2003, contemporaneous with the phase -
down of the ponds. Applicant has received assurances from the Town of Wake Forest
that sanitary sewer service will be extended to the property by 2003. If, for whatever
reason, sewer is not available by 2003, applicant will temporarily install a nondischarge
alternative for wastewater treatment until permanent sanitary sewer becomes available.
No development will occur on the property prior to a firm commitment has been
received [sic] regarding the provision of sanitary sewer to the property."
At the present time, Riverplace has not begun construction to connect to the Wake Forest collection
system. It continues to operate the treatment facility (contract operations) and discharges only as
needed. However, as noted below, the facility has discharged fewer than ten days since the beginning
of 1999 and most of that is the result of rainfall onto the treatment ponds. (The facility actually
experienced a net loss of wastewater during the summer of 2002, due to the exceptionally dry
�* conditions.)
RECEIVING WATERS
In order to protect the designated uses of its surface waters, North Carolina has classified each of its
stream segments according to the established use(s) and has adopted water quality standards to
provide the necessary level of protection for each. Where more than one standard exists (such as for
multiple uses), the most stringent standard for a given parameter applies, in order to protect for all
designated uses.
The receiving waters for the facility is the Neuse River, designated as Class C Nutrient Sensitive Waters
(C-NSW). The designated uses of Class C waters are aquatic life propagation and maintenance of
biological integrity, wildlife, secondary recreation, and agriculture. No additional uses are associated
with the supplemental NSW classification.
Water quality standards for Class C waters are specified in T15A NCAC 2B .0211. General requirements
for NSW waters are defined in 2B .0223. In December 1997, the state adopted specific requirements to
-2-
FACT SHEET - NPDES PERMIT Riverplace II, LLC
DRAFT NPDES No. NC0001376
address the basin's NSW designation. The point source rule (2B .0234) establishes total nitrogen and
total phosphorus limits for many dischargers in the Neuse River Basin, including Burlington Industries.
The entire Neuse River Basin has been listed on the state's 303(d) list of impaired waters, due to nutrient
impacts from point,.nonpoint, and natural sources on the Neuse River estuary. In 1997 the state
adopted as rule a nutrient management strategy to restore water quality in the basin; and in 1999 and
2002, the US EPA approved Total Nitrogen TMDLs for the basin. The 2000 303(d) list again includes the
basin but notes that the TMDL has been approved and is being implemented.
CURRENT PERMIT AND FACILITY PERFORMANCE
Permit Overview
The current permit sets limits at Outfall 001 for the former textile mill, including flow, BOD, NH3-N,
TSS, COD, chromium, phenols, sulfides, total phosphorus, temperature, pH, and chronic toxicity.
In addition, monitoring is required for total nitrogen, copper (total), zinc (total), color, and dissolved
oxygen. Instream monitoring is required for pH, temperature, and D.O.
Compliance History
A review of effluent data indicates that Riverplace discharged on fewer than ten days from January
1999 through July 2002. The main reason for this is that the volume of wastewater treated is minor
_...--� compared to the capacity of the treatment plant. If not for rainfall directly onto the plant, the discharge
would be even less frequent.
Riverplace has monitored most of the parameters in the existing permit, including the industry -specific
parameters. It has consistently complied with the (industrial) permit limits for those. BOD values have
been less than 5 mg/L, and chromium and copper values have been less than detection levels. The
facility passed its last whole effluent toxicity test, conducted in March 1999.
PROPOSED EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
The Division has developed effluent limitations, monitoring requirements, and special conditions for
the proposed permit based on the following:
federal requirements for secondary treatment of municipal wastewater, 40 CFR Part 133;
and
North Carolina water quality standards, including the Neuse River Basin Nutrient
Management Strategy.
The current and proposed permit requirements are described below.
Effluent Limitations - Outfall 001
Flow Limitations
The current permit includes a monthly average flow limit of 5.0 MGD. Riverplace's permit application
did not specify a proposed flow rate for the new operation. At 35 gpd per employee, the wastewater .
flow for the 20 employees would be 700 gpd. Additional flow is expected from customer use of rest
rooms and from stormwater. The new permit includes a limit of 2,000 gpd, or 0.002 MGD, from all
sources.
-3-
FACT SHEET - NPDES PERMIT
DRAFT
II, LLC
NPDES No. NC0001376
Technology -Based Limitations for BOD, TSS, and pH
The proposed BOD and TSS limits for sanitary wastes are based on a level of treatment typically
required for similar wastes at publicly owned treatment works: 30 mg/L BOD and TSS, pH within the
range of 6-9 S.U.
Water Quality -Based Limitations
Nutrients. In 1997, the Environmental Management Commission adopted as rule the Neuse River Basin
Nutrient Sensitive Waters Management Strategy - Wastewater Discharge Requirements (T15A NCAC
2B .0234). The permit includes limits for Total Nitrogen (TN) and Total Phosphorus (TP) as prescribed
in the rules.
c)�t+
Under the rule, Burlington Industries received a TN allocation. However, prior to the sale of the facility
310 to Riverplace, Burlington Industries deeded its TN allocation to the City of Raleigh for the benefit of a
future group compliance association. This leaves the facility with no remaining allocation. Accordingly,
the permit specifies a TN limit of zero (0) pounds per year, effective January 1, 2003. In effect, the TN
j limit prohibits any discharge of wastewater as of January 1, 2003. Riverplace committed in its
j application to eliminating its discharge by 2003, and the permit limit holds the permittee to its
commitment.
The permit also includes a TP limit of 2.0 mg/L (quarterly average), effective with the permit.
Proposed Monitoring Requirements - Outfall 001
State rule 2H .0500 establishes minimum monitoring requirements for discharges to surface waters,
based on SIC of the discharging facility. The proposed monitoring frequencies are consistent with the
rule.
The permit requires continued monitoring for several parameters from the Burlington Industries permit
to determine whether they are still found in the treatment plant and are discharged along with the
present-day wastewater. The Division proposes quarterly monitoring for these parameters:
Chemical Oxygen Demand (COD)
Ammonia Nitrogen
Total Chromium
Total Copper
Total Zinc
Phenols
Sulfides
The permit includes a re -opener clause allowing the Division to add effluent limits for these parameters
or to increase or decrease the monitoring frequencies depending upon the results of the monitoring.
PROPOSED SPECIAL CONDITIONS
ac `
Total Nitrogen. The ermit 'nclVdess descril� how Total Nitrogen mass loads are to be
s ✓
calculated. ` anda`rd re -opener clauses `�'`" the Division (1) update special
conditions pertaining to the group compliance association when those conditions are developed (if
necessary) and (2) add other special conditions pertaining to nutrient control requirements if those
should be necessary as part of a basin -wide implementatio policy. sic . t�,,. a 'n.res
tt • �hV 2� Loo't�
�1V�'�T'S,.S.t "'4 �y�'"�� p�.yr � {1.ei'�iv. ��'1" °��vhvc:+��'�,.q 1lw �t'a+'►'1:=d'��, �y �/1f l� �
-4-
Permit Review Sheet
NCDEHR Riverplace II, LLC
NORTH GROUNA DEPARTMENT OF Riverplace WWTP
ENVIRONMENT IR AND NURAL RESOURCES
NPDES No. NC0001376
PERMIT REVIEW
Please review the attached draft permit package and provide comments and/or concurrence at least
one week before the close of the public comment period (below).
If you have any questions on this fact sheet, the draft permit, or other attachments, please contact at
(919) 733-5083, extension.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: November 6, 2002
End of Comment Period: December 6, 2002 (approx.)
Permit Scheduled for Issuance: December 20, 2002
NPDES Recommendation by:
Signature Date
REGIONAL OFFICE COMMENTS This space is used by the regional office personnel to identify specific
concerns in reference to issuance of the subject permit. Attach
additional sheets as needed.
Regional Recommendation b
Signature Date
REVIEWED AND ACCEPTED BY:
Regional Supervisor:
Signature
Date
NPDES Unit Supervisor:
Si nature
Date
PERMIT NUMBER: NC0001376 PERIOD ENDING MONTH: 12 - 2002
FACILITY NAME Riverplaco II, LLC - Rivcrplacc II LLC
CITY: Wake Forest COUNTY: Wake
TCP.,R
pass/fell
P/F STATRE "lpay
Chi Cerioaaphnia
1 - 02
2-02
3-02
4-02
5-02
6-02
7-02
8-02
9-02
10-02
11 - 02
12-02
REGION: Raleigh
PERMIT NUMBER: NC0001376
FACILITY NAME Riverplace It, LLC - Riverplave II LLC
CITY: Wake Forest COUNTY: Waite
OUTFALL. 001 EFFLUENT
PERIOD ENDING MONTH: 12 -2001
REGION: Raleigh
00010
o
Temperature,
Water Deg.
Centigrade
[00082
1
or,
ttrophato,
Sept at 7.6
00300
mg/l
DO, Oxygen,
Dissolved
0031000340
lbs/day
Son, 5-Day (20
Deg. C)
lba/day
COD, Oxygen
0-nd, Chem.
(High Level)
00400
u
pH
0053deg
lbs/dea y
Solids, Tots.
Suspended
1 -01
390
8.719.8
1,948.9
2-01
390
fi.7t9. c^
t,948.9
3 - 07
14,35
390
2.7
61719.
44
7.96 - 7.99
1,948.9
2.8
4-01
.90
6, 7i9.8
5-019
8.719.E
1,948.9
6.01
_+8
u, 7 1 $ 8
1,948.9
7 - 01
39C
8, 719.8
f,9d8.9
9-01
39;
8.�,9.8
11439
10 - 01
6.7:?'i ti
;.94E.P
11 -01
390
6, ]r9. it
l,948.9
12 - D1
39r1
6: 779.E
1.948.9
PERMIT NUMBER: NC0001376
FACILITY NAME River -place IL LLC - Riverplace II LLC
CITY: Wake Forest
PERIOD ENDING MONTH: 12 - 2001
COUNTY: Wake REGION: Raleigh
00610
00665
00745
'01034
01042
01092
32730
mg/i
m9/1
lbs/day
lbs/day
mq/1
mg/1
1ba/day
Nitrogen,
Phosphorus,
Sulfide, Total
Chromic@, Total
Capper, Total
Zinc, Total las
Phenolics,
Mmionla Total
Total (as PI
(as al
(as Crl
(as Cu)
set
Total
lee N)
Recoverable
1 - 01
4
17.9
8.9
8.9
2-01
4
IT9
E.9
8.9
3-01
-
17.9
8.9
8.9 '.
0
2.63
0
0
0
29
0
4 - 01
4
179
.5,
8.9
5-01
.t
3.
8.9
6 - 01
`?
7.9
r,.n,
8.9
7-01
4
1' g
8.9
E.9
8 .01
17.9
8.9
8.9
9 - 01
10-01
-
IT9
11-01
r79
8.°
d-
12-01
4
17.9
8.9
-
PERMIT NUMBER: NC0001376 PERIOD ENDING MONTH: 12 - 2000
FACILITY NAME Riverplace 11, LLC - Riverplace ❑ LLC
CITY: Wake Forest COUNTY: Wake
TGP3B
pass/tail
P/F STATRE 7Day
Chr Ceri,d.phni-
1 - 00
2.00
3-00
4-00
5-00
6-00
7-00
8-00
9-00
10-00
11 - 00
12-00
REGION: Raleigh
PERMIT NUMBER: NC0001376
FACILITY NAME Riverplace 11, LLC - Riverplace II LLC
CITY: Wake Forest COUNTY: Wake
OUTFALL. OOl EFFLUENT
PERIOD ENDING MONTH: 12 - 1999
REGION: Raleigh
0001.0
0D092
0030C
00310
"1"
10110
01131
deq C
inq/1
mq/1
Iba/day
lbs/day
L
1bs/day
Tempararere,
Color,
DO, Oxygen,
WD, 5-Day (20
COD, Oxygen
pH
Solids, Tota.
Water Deg.
Spaotrophoto,
Dissolved
Deg. C)
Demand, Chem.
Suspended
Centigrade
Wtr Smpl at 7.6
(High Level)
1-99
390
8, 719.a
t.948.9
2 - 99
:t90
8. 7 19. 8
1948.9
3 - 99
3x
6,719.8
1,948.9
9
3
69
7.4-7.7
5
4 - 99
s90
6.719.8
1,948.9
5 - 99
6.719.6
1,948.9
6 - 99
t90
6.7i9.6
1,948.9
7.99
390
6, 719.8
1,948.7
8.99
s9
5.719.8
9aa.9
9-99
6, 719.6
1.4489
10 - 99
,....
.719 a
11-99 9-+98
t, G4r, i
12 - 99
':'+`
7? d a
4.94ti.9
PERMIT NUMBER: NC0001376
FACILITY NAME Riverplace 11, LLC - Riverplace 11 LLC
CITY: Wake Forest COUNTY: Wake
PERIOD ENDING MONTH: 12 - 1999
REGION: Raleigh
00610
00665
00745
01031
01042
01092
32730
m9/1
mg/1
lbs/day
lba/day
mg/1
mg/1
lb./day
Nitrogen,
Phosphorus,
Sulfide, Total
Chromium, Total
Copper, Total
zinc, Total [as
Phenolics,
Amdonia Total
Total (es PI
Isa S)
(ae Cr)
Iss Cu)
Sn)
Total
(as NI
Recoverable
1-99
4
2-99
4
17.9
8.9
8,g
3-99
4
17.9
6.9
8.9
0
0
0
0.05
0.05
0.1
0.02
4-99
4
179
8.9
8.9
5 - 99
4
17.9
8.9
8.9
6 - 99
4
17.9
,..�
8.9
7-99
4
17.9
8 - 99
4
17.9
8.9
B.9
9-99,
10-99
a
17.t)
rv.9
39
11-99
179
8.9
89
12-99
17.9
a.9
a,q
PERMIT NUMBER: NC0001376 PERIOD ENDING MONTH: 12 - 1999
FACILITY NAME Rivelplace 11, LLC - Rivefplace II LLC
CITY: Wake Forest COUNTY: Wake REGION: Raleigh
rces��
pass/fail
P/F STATRE 10ay
Chr Ceriotlaphniz
2-99
3-99
1
4-99
5-99
6-99
7-99
8-99
9-99
10-99
11 - 99
12-99
Riverplace II, LLC - Riverplace WWTP
County Wake
NC0001376
Region Raleigh
Outfall001
Subbasin 03-04-02
Version 1.0
monm
uay
Year
t;omment Parameter
Sample
UoM
Value Modifie
Cell Type
3
3
1999
50050 - Flow
Recorder
mgd
.66
DLYVALUE
3
5
1999
50050 - Flow
Recorder
mgd
.14
DLYVALUE
2
10
2000
50050-Flow
Recorder
mgd
.057
DLYVALUE
8
1
2000
50050 - Flow
Recorder
mgd
.774
DLYVALUE
3
19
2001
50050 - Flow
Recorder
mgd
.298
DLYVALUE
3
22
2001
50050 - Flow
Recorder
mgd
.128
DLYVALUE
1
31
2002
50050-Flow
Estimate
mgd
.088
DLYVALUE
4
11
2002
50050 - Flow
Recorder
mgd
.232
DLYVALUE
3
3
1999
00310 - BOD5
Composit
Ibs/day
3.
DLYVALUE
2
10
2000
00310 - BOD5
Composit
mg/L
4.6
DLYVALUE
8
1
2000
00310-BOD5
Composit
mg/L
LESST
DLYVALUE
3
20
2001
00310 - BOD5
Composit
mg/L
3.3
DLYVALUE
3
23
2001
00310 - BOD5
Composit
mg/L
2.1
DLYVALUE
1
31
2002
00310 - BOD5
Composit
mg/L
2.9
DLYVALUE
4
11
2002
00310 - BOD5
Composit
mg/L
3.8
DLYVALUE
TELEPHONE RECORD
Date: 3/13/01
Time: 1200 N
❑ Return Mr./ Mrs. Craig Bromby
® Call to Address
❑ Call from
Telephone:-899-3032
FAX: - -
Subject: NPDES permit renewal
Overdue application
NOTES/ SUMMARY
Representing: Hunton & Williams
Project: Riverplace II
(On 1124101, I e-mailed Mr. Bromby to note that I had not yet received permit application and other material that Bill Trent had
agreed to submit by Jan 1 — see notes from our Dec 8 meeting. Mr. Bromby responded on 1125, indicating a different
understanding from our meeting and asking for a conference call or meeting to clear things up. Today's call was in response to
that message.)
Mr. Bromby responded differently from his 1/25 e-mail. He recalled that the application was due around Jan 1 and did
not question the other information I said was expected with the application. He said he had talked w/ Mr. Trent in late
Jan and expressed some confusion as to why we had not received anything yet. He apologized several times for the
delay.
Mr. Bromby then asked when we needed the application. I replied that it was already overdue; that any discharge
would be without a valid permit (last recorded discharge thru 1/31/01 was on Aug 1); that I'm prepared to begin work
on the permit — or other action, if needed — within the next couple of weeks. He indicated he will get back to Mr. Trent
and will make every effort to get the application and additional information in by the end of next week. Mr. Trent may
call me if there is any confusion about what is expected.
NEEDED FOLLOW-UP ACTION(S)
1. Submit NPDES application and summary of
wastewater management plans for the facility.
BY WHOM/WHEN
1. Trent/ Bromby, by Fri, Mar 23 d.
�I
Signed
Mike Templeton
NPDES Unit, DWQ, Raleigh
MEETING NOTES
Who: Bill Trent, Riverplace
Craig Bromby, Hunton Et Williams, re r senting Riverplace
Mike Templeton, DWQ / NPDES
What: Burlington Industries / Riverplace LLC permit transition
When: 7 Dec 2000, 1500 - 1645 hrs.
Where: Hunton Et Williams offices, downtown Raleigh
Why: To clear up questions about Riverplace's plans the Burlington Industries site and about the
status of the NPDES permit, and to discuss necessary actions by DWQ and Riverplace
Backeround and Riverplace's Plans for the Burlington Industries Site
Burlington Industries suspended manufacturing at its Wake textiles plant in November 1996. They had
been cutting back production for several years before that and had no process wastes for a while
before closing. Riverplace bought the property and plans to develop the plant site for retail and
warehouse space. One furniture store has begun business so far.
Since the mill ceased operation, the WWTP has received only sanitary wastes. At present, the only
water uses are for drinking water and toilets. Seventeen people are employed on the site now, and no
more than about 200 could be employed there by 2003. Riverplace does not intend for there to be any
sort of non -domestic wastewaters going to the WWTP, now or in the future.
The treatment plant is a lagoon system designed for 5 MGD of textile wastewater. The plant is in
operation, with EnviroLink as the contract operator, and discharges only occasionally, due to the
extremely low flows. Weather conditions (rainy or dry periods) have a considerable effect on the water
levels in the lagoons, much more that do the wastewater flows. The water in the lagoons is mostly
stormwater.
Riverplace will convert the existing textile plant for retail and warehouse space, and plans to manage
the rest of the property separately. The site was annexed by Wake Forest on September 14, 2000, and
is zoned for heavy industry. Riverplace has petitioned the City to re -zone the building to reflect the
intended use.
Riverplace intends to connect to Wake Forest's collection system before 2003 and then close the
WWTP, empty the lagoons, and restore the site (approx. 37 acres). They expect to sell some or all of
this property for others to develop. They have retained an environmental consultant to evaluate the
site and determine what is needed to carry out this plan.
The Wake Forest sanitary sewer is 4,000 ft. away. When a new development by others (now getting
underway) is completed, the connection will be 2,000 ft. away. Riverplace would prefer to wait for the
developer to install the first 2,000 ft. but is prepared to install the entire line if necessary to cease
discharge by 2003. Estimated cost is $40/ linear foot.
None of the waste in the lagoons is from Burlington Industries' operations. The lagoons were emptied
before the sale.
Questions and Issues
Q: What is the permit status?
A: Burlington's permit expired in January 1999. Because they submitted an application for
renewal in July 1998, their permit was administratively extended. DWQ delayed most permitting
activities in the basin while it revised the Nutrient Management Strategy rule and has yet to re -issue
the Burlington Industries permit. Burlington sold the facility in the meantime and submitted a
name/owner change request. To date, no one has submitted a modified application for the new owner
or any explanation of the new owner's plans for the site.
Q: Is the Riverplace operation considered to be new or existing?
A: For DWQ's purposes, including the Neuse NMS, we are considering the facility to be "existing."
The type and quantity of wastewater that Riverplace will generate were already covered under the
previous permit to Burlington.
Q: Does Riverplace have or need a nitrogen allocation for its operation?
A: Riverplace absolutely intends to get out of the wastewater business before 2003 so that it does
not have a direct discharge to surface and does not need an allocation. They were aware of the
implications of Burlington transferring its entire allocation to Raleigh and made an informed decision to
allow it. (Apparently, there is a story to be told about this, but the opportunity has not presented itself
yet.)
Q: Are there other ways to handle this transition, to speed and/or simplify the termination of
their discharge?
A: We discussed other options.
• One would be to scale down the treatment operation immediately. The WWTP capacity
vastly exceeds the current needs, and the unneeded lagoon area only serves to capture
more rainfall, which has to be monitored and discharged under the NPDES permit. They
could scale down by using only one or two lagoons and closing the others or by bringing in a
package treatment plant and closing all four lagoons.
Another would be to install a sump and holding tank, collect the sanitary wastewater, and
have a contract hauler transport it to the Wake Forest WWTP. In this case, they could
proceed to close all four lagoons, end their discharge, and terminate their permit. They
would incur costs for the tank and the hauling but would vastly reduce their operating costs
(including the contract operator). It is not clear whether the Division would/could approve
this approach, because 2H .0205 limits pump -and -haul arrangements to 6 months in most
cases.
Next Steps
We agreed on the following course of action for this permit:
Riverplace will submit a revised permit application (Short Form D) by January 1. In the
submittal, they will describe their plans for eliminating their surface discharge by 2003,
identify key actions, and provide an approximate timetable which will assume the WWTP
remains in service during that time.
2. At the same time, Riverplace will begin looking at options for closing the WWTP sooner and will
submit their initial findings along with the permit application.
3. 1 will took into the question about the pump -and -haul approach - would this be acceptable
under these circumstances?
Re: riverplace - npdes
r
• Subject: Re: riverplace - npdes
Date: Wed, 22 Nov 2000 08:49:36 -0500
From: Mike Templeton <mike.templeton @ ncmail.net>
To: "Bromby, Craig A." <CBromby@hunton.com>
CC: Dave Goodrich <Dave.Goodrich@ncmail.net>, Charles Weaver <Charles.Weaver@ncmail.net>
Sorry I didn't get back to you on Tuesday. Have an idea for a new bumper sticker, though - "Meetings Happen." I'm out of the
office today, Thursday, and Friday, and will give you a call on Monday, late a.m. or early p.m. For the meantime, here's a little
more on the Riverplace matter.
First is the NPDES application. The files I have include Burlington Industries' Jul '98 application for renewal and the Nov '99
request for a name change. Since Riverplace is not simply continuing the Burlington textile operation, we need a new
application describing the new operation, its wastewater characteristics, and so on. (Form C is on our web site at
http://h2o.enr.state.nc.us/NPDES/NPDESweb.htm(; I can get you a hard copy next week, if that works better for you.)
You mentioned that some of Burlington's old wastewater is still on site and needs to be disposed of. The application package
needs to tell how much water there is, what treatment it's received, what it's characteristics are (the permit parameters, at
least), and how it will be managed. It could present a problem if the wastewater is untreated, since Riverplace would need a
certified operator to run the treatment plant. Treated or untreated, the discharge still has to comply with the permit, of course.
The next issue is the nitrogen allocation. When Burlington deeded its allocation to the City of Raleigh, it left Riverplace with a
zero limit for nitrogen, effectively eliminating any possibility of discharge to the river.* There may be some understanding
among the three parties as to how this will be handled, but it hasn't been conveyed to the Division. The application package
should explain how Riverplace will acquire the nitrogen allocation it needs for its discharge or describe other plans it has to
meet the limit by 2003 (connection, etc.). We will need some sort of document which formally memorializes the arrangements.
* If all else fails, DWO could assign a portion of the Burlington allocation to Riverplace. We have not had reason
to object to the allocation transfer so far and have left it alone. But we are no more bound by this transfer
agreement than if Burlington had deeded its BOD allocation to another discharger. (We can always consider
such a request from the permittees and, if appropriate, modify both permits to reflect the change. We were not
aware of Burlington's intent in this instance until we received a signed copy of the Deed of Gift.)
That should give you a clearer idea of what is required for an acceptable application from Riverplace. Let's talk next week and
take care of any other questions we have.
Hope you have a Happy Thanksgiving.
- Mike T
"Bromby, Craig A." wrote:
This one seems to have slipped through the cracks. Burlington has donated
their N allocation from the operation of the former Wake Mill facility, as I
understand it. Of course, the facility is no longer being used as a textile
mill facility. It is now being used as a warehouse, and may be used for
commercial and light industrial (in keeping with the zoning). The
wastewater being generated is domestic in nature, but, as you would expect,
the flow is significantly reduced, well below 0.5 MGD. When the warehouse
facility is completely rented out, over the next permit cycle, I anticipate
a maximum of fewer than 1000 employees and visitors per day, which,
referring to 15A NCAC 18A .1949 for guidance, would generate a maximum daily
flow of 25 gallon per day per person per shift, or 1000 x 25 x 3 = 75,000
gpd or 0.075 MGD maximum flow. In fact, flow would probably not be this
high. Ultimately, Riverplace expects that the Town of Wake Forest will
extend sewer to the property and the WWTP will simply be phased out. One
issue to be aware of is that there was residual wastewater from the
Burlington operation that remained in the WWTP at the time of the sale, so
there may still be wastes associated with Burlington's operation that would
not be expected for just the warehouse use of the property. I am trying to
contact the consultants today to get further detail. Do you want to set a
time that I can come meet with you and lay out all the information I have?
-----Original Message-----
1 of 2 12/7/00 2:38 PM
Re: riverplace - npdes
From: Mike Templeton [mailto:mike.templeton@ncmail.net]
Sent: Thursday, November 16, 2000 9:29 AM
To: cbromby@hunton.com
Subject: riverplace - npdes
Hello, Craig -
It's been a while since we talked about the Riverplace case. I am still
waiting for your letter re plans for use of the existing WWTP and for
discharge, agreements concerning nitrogen allocation, etc. We have
considered the expired BI permit to be administratively extended,
assuming we had a complete and accurate application for the new permit.
Lacking the additional info, the application is incomplete - an awkward
position at best for Riverplace II. Please let me know when you will be
getting that in to us.
- Mike T
Mike Templeton
NCDENR / DWQ / NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
512 N. Salisbury St.
Raleigh, NC 27604
(mailing address)
(street address)
919-733-5083 x541
919-733-0719 (fax)
mailto:mike.templeton@ncmail.net
Mike Templeton
NCDENR / DWQ / NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
512 N. Salisbury St.
Raleigh, NC 27604
(mailing address)
(street address)
919-733-5083 x541
919-733-0719 (fax)
mailto:mike.templeton @ ncmail.net
2 of 2 12/7/00 2:38 PM
RE: riverplace - npdes
Subject: RE: riverplace - npdes
Date: Fri, 17 Nov 2000 09:24:04 -0500
From: "Bromby, Craig A." <CBromby@hunton.com>
To: 'Mike Templeton' <mike.templeton@ncmail.net>
This one seems to have slipped through the cracks. Burlington has donated
their N allocation from the operation of the former Wake Mill facility, as I
understand it. Of course, the facility is no longer being used as a textile
mill facility. It is now being used as a warehouse, and may be used for
commercial and light industrial (in keeping with the zoning). The
wastewater being generated is domestic in nature, but, as you would expect,
the flow is significantly reduced, well below 0.5 MGD. When the warehouse
facility is completely rented out, over the next permit cycle, I anticipate
a maximum of fewer than 1000 employees and visitors per day, which,
referring to 15A NCAC 18A .1949 for guidance, would generate a maximum daily
flow of 25 gallon per day per person per shift, or 1000 x 25 x 3 = 75,000
gpd or 0.075 MGD maximum flow. In fact, flow would probably not be this
high. Ultimately, Riverplace expects that the Town of Wake Forest will
extend sewer to the property and the WWTP will simply be phased out. One
issue to be aware of is that there was residual wastewater from the
Burlington operation that remained in the WWTP at the time of the sale, so
there may still be wastes associated with Burlington's operation that would
not be expected for just the warehouse use of the property. I am trying to
contact the consultants today to get further detail. Do you want to set a
time that I can come meet with you and lay out all the information I have?
-----Original Message -----
From: Mike Templeton[mailto:mike.templeton@ncmail.net]
Sent: Thursday, November 16, 2000 9:29 AM
To: cbromby@hunton.com
Subject: riverplace - npdes
Hello, Craig -
It's been a while since we talked about the Riverplace case. I am still
waiting for your letter re plans for use of the existing WWTP and for
discharge, agreements concerning nitrogen allocation, etc. We have
considered the expired BI permit to be administratively extended,
assuming we had a complete and accurate application for the new permit.
Lacking the additional info, the application is incomplete - an awkward
position at best for Riverplace II. Please let me know when you will be
getting that in to us.
- Mike T
Mike Templeton
NCDENR 1 DWO / NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617 (mailing address)
512 N. Salisbury St.
Raleigh, NC 27604 (street address)
919-733-5083 x541
919-733-0719 (fax)
mailto:mike.templeton@ncmail.net
1 of 1 12/7100 2:38 PM