WQ0035784_PC-2021-0028_20210716

J�
Parker Poe
Fern A. Paterson
Partner
t: 704.335.9891
f: 704.335.4456
[e-mail]
July 16, 2021
Via Certified Mail
Nathaniel Thornburg
NC DEQ / DWR / ND Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Atlanta, GA
Charleston, SC
Charlotte, NC
Columbia, SC
Greenville, SC
Raleigh, NC
Spartanburg, SC
Washington, DC
Re: Remission Request (Case No.: PC-2021-0028)
Wallace Loft, LLC; The Cottages of Boone - Wastewater Irrigation System
Permit No. WQ0035784; Watauga County
Dear Mr. Thornburg:
By way of this letter, we respectfully seek a reduction in the proposed civil penalty of
$22,621.33 in the above -referenced case on behalf of our client, Wallace Loft, LLC ("Wallace
Loft"), which owns and operates The Cottages of Boone ("The Cottages"). Specifically, Wallace
Lofts requests a reduction in the civil penalty on the grounds that: (1) Wallace Lofts has taken
additional actions, beyond the actions described in the Wallace Loft's response to the Notice of
Violation dated April 8, 2021 (the "Response") to correct the violation and prevent future
occurrences, as described further below; and (2) the release of treated wastewater was
inadvertent. Various supporting materials are attached to this written remission request, including
the Justification for Remission Request Form and Waiver of Right to an Administrative Hearing
and Stipulation of Facts, which are provided in Attachment A. We genuinely appreciate your
consideration of this written request and the information attached, and request an appropriate
reduction in the civil penalty assessed in this matter.
Wallace Loft Took Prompt Action to Correct the Violation and Prevent Future Occurrences.
In its Response dated April 8, 2021, which is attached hereto as Attachment B, Wallace
Lofts indicated that it would continue to review and evaluate options to address the limited wet
weather storage capacity at The Cottages, whether through permitting or other alternatives
identified through further analysis. As promised, Wallace Lofts identified and is in the process of
implementing additional response actions, including: (1) implementing water efficiency measures
at The Cottages with the goal of reducing water usage by greater than 40%; and (2) re -submittal
of an application for a Conjunctive Use permit under the National Pollutant Discharge Elimination
System ("NPDES") program requesting authorization to discharge up to 35,000 gallons per day
(0.035 MGD) to Laurel Fork only when necessary to prevent bypass of existing wet weather
storage during periods of extended inclement weather. Additional information is provided below:
PPAB 6432838v1
Parker Poe Adams & Bernstein LLP 620 South Tryon Street Suite 800 Charlotte, NC 28202
t 704.372.9000 f 704.334.4706 www.parkerpoe.com

July 16, 2021
Page 2
Water Efficiency Measures. Wallace Lofts engaged Navitas Equity Solutions
("Navitas") to evaluate available water efficiency upgrades at The Cottages with a
goal of reducing water usage, and associated demands on the wastewater
treatment plant, wet weather storage, and irrigation fields. Navitas identified the
following available water efficiency measures, as further described in the proposal
provided in Attachment Cl.-
Water Efficiency Measure
Associated Cost
Replace existing toilets with high -efficiency, 0.8
$295,020
gallon/flush toilets
Install high -efficiency, 0.5 gallon/minute aerators in
$14,751
existing bathroom sinks
Install high -efficiency, 1.25 gallon/minute aerators in
$24,585
existing showerheads
Install high -efficiency, 1.0 gallon/minute aerators in
$5,775
existing kitchen sinks
Install in -unit water meters to quickly and efficiently identify
$86,625
and repair potential leaks in residential units
Total Cost:
$426,756
Navitas estimates the proposed water efficiency measures will cumulatively
reduce water usage at The Cottages by greater than 40%. Wallace Lofts will
implement the water reduction measures in the third calendar quarter with a goal
of completing implementation by September 30, 2021.
Re -Submittal of Wallace Loft's Application for a Conjunctive Use NPDES
Permit. Between December 2020 through February 2021 (i.e., the period prior to
and during the WWTP bypass), the actual total volume of overflow of wet weather
storage at the wastewater treatment plant exceeded 3 million gallons, including
greater than 1 million gallons that were pumped and hauled to the Town of Boone's
municipal wastewater treatment facility. In coordination with Odom Engineering,
Wallace Lofts analyzed the wet weather storage needs during this period assuming
a 40% reduction in water usage, consistent with the water efficiency reduction
goals listed above.' Assuming a 40% reduction in water usage is achieved, the
total overage is significantly reduced to just over 1.1 million gallons. In other short,
even with the implementation of water efficiency measures, Wallace Lofts
anticipates that The Cottages could potentially experience future wet weather
storage capacity shortages during extended periods of cold, wet weather in the
winter months. To address the remaining overage, Wallace Lofts worked with
Odom Engineering to update and re -submit an Engineering Alternatives Analysis
("EEA") on July 12, 2021, and reapply for the NPDES Conjunctive Use Permit.
NCDEQ returned the Wallace Loft's original application for a NPDES Conjunctive
Use on January 19, 2021 due to deficiencies it identified in the Engineering
Alternatives Analysis ("EAX). The Wallace Lofts and Odom Engineering updated
the EAA per feedback from NCDEQ including, without limitation the evaluation and
' See Appendices B and C of the revised Engineering Alternatives Analysis ("EAA") submitted to NCDEQ
on July 12, 2021, and attached to this request as Attachment D.
PPAB 64328380

July 16, 2021
Page 3
implementation of the water efficiency measures described above. The updated
EAA is provided as Attachment D. In addition to including the water efficiency
measures described above, the following alternatives were evaluated, as detailed
in the attached EAA: (1) added storage capacity/deemed infeasible due to
topographical constraints; (2) increased irrigation rates and/or expanding irrigation
areas/deemed ineffective due to the same inclement weather issues leading to the
January -February 2021 event'; (3) tying to the Town's public utilities/deemed
infeasible due to political constraints; and (4) covering the existing wet storage
tank/deemed ineffective.
As described in the updated EAA, Wallace Lofts only seeks authorization to
discharge treated wastewater to Laurel Fork when necessary to avoid an overflow
of the existing wet weather storage, during periods of extended inclement weather.
Further, Wallace Lofts only seeks a maximum discharge rate during these
applicable period of 35,000 gallons/day (0.035 MGD). Except during these periods
of limited discharge to Laurel Fork, The Cottages would continue to land -apply
treated wastewater to the irrigation fields pursuant Permit No. WQ0035784.
The Release of Treated Wastewater Was Inadvertent and Wallace Loft Took Substantial
Actions to Prevent the Occurrence
In its April 8, 2021 response, Wallace Loft included a discussion of the circumstances of
the bypass and numerous actions that it took prior to and during the bypass to show that the
bypass was inadvertent and not reasonably preventable. Rather that rehash that discussion here,
we have attached the Response as Attachment B, and incorporate the discussion by reference.
A brief summary of the key discussions in the Response are also identified below:
Weather & Inability to Irrigate. Inclement weather leading up to and during the
event, allowing only minimal irrigation, for a 3-month period, as follows:
o December 2020. Minimum temperatures in December, were consistently
below freezing, only increasing above 32 OF on December 12 (37 OF),
December 13 (38 OF), and December 22 (33 OF).
o January 2021. In the days leading up to the beginning of the bypass on
January 10, it rained 7 out of 10 days. Minimum temperatures remained
freezing from January 4 through January 26. Cumulative precipitation in
January totaled more than 18 inches of rain or snow, and there was snow
cover at The Cottages for 16 out of the 31 days of the month.
o February 2021. Minimum temperatures only chimed above freezing on two
days (February 14 at 35 OF and February 26 at 33 OF). Between February
1 and February 22, when the bypass ended, there were 13 days of rain or
snow, and 8 days of snow cover at The Cottages.
2 In support of the updated EAA, the Wallace Loft also engaged a soil scientist to evaluate whether
existing irrigation rates may be increased and/or irrigation areas may be expanded. That report is
currently pending. However, the existing irrigation rates and area are more than sufficient to support the
WWTP outside the periods of extended inclement weather in the winter months, and Wallace Loft and
Odom Engineering determined that increasing irrigation rates and/or areas would not resolve the overage
issues during these periods. In hopes of obtaining the requested NPDES Conjunctive Use Permit prior to
winter, the EAA was submitted the soil survey pending, and be updated with the results of the soil survey
upon receipt.
PPAB 64328380

July 16, 2021
Page 4
Pump/Haul Operation & Iced -Over Roads. Between January 4 and March 23,
Wallace Loft pumped and hauled a total of 1,068,600 gallons of wastewater to the
Town of Boone's wastewater treatment facility, costing a total of $155,400, and
would have pumped and hauled more but for iced roads. Haul trucks were not
able to access The Cottages at all between January 10 (when the bypass began)
and January 18. Wallace Loft attempted to keep road clear by acquiring a mini
excavator, placing fresh gravel, and contracting a snowplow vendor, but weather
and road conditions continued to hamper and slow Wallace Loft's pump and haul
efforts throughout the event.
Increased Water Usage Due to the Covid-19 Pandemic. Water usage at The
Cottages nearly doubled after onset of the Covid-19 pandemic in March 2020 and
associated work-at-home/stay-at-home orders. Daily water usage averaged
approximately 36,000 GPD in March 2020, and climbed to approximately 78,000
GPD in February 2021. The Cottages hit a maximum daily usage of 112,600 GPD
on February 18. The irrigation fields are able to meet the increased wastewater
production rates during warmer months, but The Cottages was not able to keep up
with the increased rates and avoid the bypass during the extended period of
inclement weather between December 2020 and February 2021.
Efforts to Obtain a NPDES Conjunctive Use Permit. Wallace Loft engaged
Odom Engineering ("Odom") in October 2019 to assist with the wet weather
storage issues at The Cottages. Odom confirmed that operational challenges at
the WWTP tracked the weather, and Odom and Wallace Loft determined to apply
to NCDEQ for a NPDES Conjunctive Use permit that would allow The Cottages to
directly discharge treated wastewater to Laurel Fork, a small stream on property
adjacent to the existing WWTP. Wallace Loft applied for and was issued approved
speculative effluent limits for a 0.1 MGD NPDES Conjunctive Use permit on
January 10, 2020. Wallace Loft also applied for and received a zoning consistency
determination for the requested NPDES Conjunctive Use permit from Watauga
County on April 27, 2020. However, NCDEQ returned Wallace Loft's application
for a NPDES Conjunctive Use permit on January 19, 2021 after raising concerns
regarding the original EAA. As discussed in detail above, Wallace Loft submitted
a revised EAA addressing NCDEQ's concerns on July 12, 2021, along with an
updated NPDES application form and fee, to continue pursuing the requested
NPDES Conjunctive Use Permit.
In sum, Wallace Loft requests a reduction in the assessed civil penalty on the grounds
that it is implementing response actions to prevent any future occurrences of the wet weather
storage overflow and treated wastewater discharge that occurred in January -February 2021,
including implementation water reduction measures at a cost of greater than $400,000, and
revision and resubmittal of the EAA in support of is request for a NPDES Conjunctive Use Permit.
Wallace Loft has also described the circumstances of the event, showing that the bypass was
entirely inadvertent and not the result of any wanton or willful conduct.
PPAB 64328380

July 16, 2021
Page 5
We appreciate your appreciate your consideration of the justification for the remission
request provided in this letter and its attachments. If you have any questions regarding this letter,
please do not hesitate to contact me at fern paterson(a)parkerpoe.com or [phone] or David
Odom at davidodom(a-)odomengineering.com or [phone].
Sincerely,
Fern A. Paterson
Attachments:
Attachment A: Justification for Remission Request Form & Waiver of Right to and
Administrative Hearing and Stipulation of Facts
Attachment B: Wallace Lofts' Response to NOV, dated April 8, 2021
Attachment C: Navitas Equity Solutions — Utilities Optimization & Capital Construction
Plan, June 2021
Attachment D: Transmittal Letter for Application for NPDES Conjunctive Use Permit,
dated July 12, 2021
cc (electronic only):
Lon Snider, NCDEQ (Ion.snider(a ncdenr.gov)
Patrick Mitchell, NCDEQ (Patrick.mitchell(a-ncdenr.gov)
Sean Dwyer(sean.devine(a�cardinalgroup.com)
Justin Pellegrino (Justin.pellegrino(a-)_cardinalgroup.com)
Chris Gamic (Christopher.garnic(a-mapletree.com.sq)
Christopher Galante (cgalante(@mapletree.us)
Rose Hernandez (rose.hernandez(aDthecottagesofboone.com)
David Odom(davidodom(a)odomengineerinq.com)
PPAB 64328380

DocuSign Envelope ID: F8E2A3BB-FEC5-4140-8082-7569518DFB14
JUSTIFICATION FOR REMISSION REOUEST
Case Number: PC-2021-0020 County: Watauga
Assessed Party: Wallace Loft LLC
Permit No.: WO0035784 Amount assessed: $22,621.33
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation o�
Facts " form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in determining
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. By law [NCGS 133-215.6A(f)] remission of
a civil penalty may be granted when one or more of the following five factors applies. Please
check each factor that you believe applies to your case and provide a detailed explanation,
including copies of supporting documents, as to why the factor applies (attach additional pages
as needed).
(a) one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) were
wrongfully Pplied to the detriment of the petitioner (the assessment factors are
included in the attached penalty matrix and/or listed in the civil penalty
assessment document);
X (b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent
future occurrences);
X (c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you
from performing the activities necessary to achieve compliance).
EXPLANATION:
See attached transmittal letter for detail explanation.

DocuSign Envelope ID: F8E2A3BB-FEC5-4140-8082-7569518DFB14
STATE OF NORTH CAROLINA NORTH CAROLINA DEPARTMENT
OF ENVIRONMENTAL QUALITY
COUNTY OF WATAUGA
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
WALLACE LOFT LLC 1
PERMIT NO. WQ0035784 ) FILE NO. PC-2021-0020
Having been assessed civil penalties totaling $22,621.33 for violation(s) as set forth in
the assessment document of the Division of Water Resources dated, June 10, 2021 , the
undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an
administrative hearing in the above -stated matter and does stipulate that the facts are as alleged
in the assessment document. The undersigned further understands that all evidence presented in
support of remission of this civil penalty must be submitted to the Director of the Division of
Water Resources within thirty (30) days of receipt of the notice of assessment. No new evidence
in support of a remission request will be allowed after thirty (30) days from the receipt of the
notice of assessment.
This the 16 day of July , 2021.
s aan vw� v'
Signature
ADDRESS
Sean A. Dwver
Vice President, Student Living, USA
Mapletree US Management LLC
5 Bryant Park, Suite 2700
New York, NY 10018, USA
TELEPHONE
[phone]

Parker Poe
Fern A. Paterson
Partner
t: 704.335.9891
f: 704.335.4456
[e-mail]
April 8, 2021
Via E-mail [lon.snider(cD_ncdenr.gov]
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
NCDEQ — WSRO
450 W. Hanes Mill Rd., Suite 300
Winston-Salem, North Carolina 27105
Atlanta, GA
Charleston, SC
Charlotte, NC
Columbia, SC
Greenville, SC
Raleigh, NC
Spartanburg, SC
Washington, DC
Re: Response to Notice of Violation & Intent to Enforce (NOV-2021-PC-0187)
Wallace Loft, LLC; The Cottages of Boone - Wastewater Irrigation System
Permit No. WQ0035784; Watauga County
Dear Lon:
We appreciate this opportunity to respond to the above -referenced Notice of Violation
("NOV") on behalf of our client, Wallace Loft, LLC ("Wallace Loft"), which owns and operates The
Cottages of Boone ("The Cottages").
As you know, The Cottages holds a permit (Permit No. WQ0035784) to operate a non -
discharge wastewater irrigation system. The Permit authorizes the operation of a 108,530 gallon
per day (GPD) wastewater treatment and irrigation facility (the "WWTP"). The WWTP uses a drip
irrigation system consisting of approximately 14.39 acres of irrigation area with a mixed hardwood
and pine forest cover crop, and serves 894 bedrooms, as well as a pool, fitness center, and The
Cottage's administrative and clubhouse employees. As previously reported to NCDEQ, a bypass
of the WWTP occurred between January 10, 2021 and February 22, 2021. In this letter, we
provide additional information regarding the weather and conditions leading up to and during the
previously reported bypass, on -going storage capacity challenges with the WWTP during the wet
and cold winter months, efforts to obtain a National Pollutant Discharge Elimination System
("NPDES") Conjunctive Use permit allowing the direct discharge to Laurel Fork to resolve storage
capacity issues, and the status of The Cottages continuing efforts to obtain a NPDES Conjunctive
Use permit. We respectfully request NCDEQ's consideration of the circumstances of the bypass,
as well The Cottage's continuing good faith efforts to resolve the WWTP operating challenges
described further herein, and hope that the NOV can be resolved without the need for
enforcement.
PPAB 6221610v2.docx
Parker Poe Adams & Bernstein LLP 620 South Tryon Street Suite 800 Charlotte, NC 28202
t 704.372.9000 f 704.334.4706 www.parkerpoe.com

April 8, 2021
Page 2
Circumstances Surrounding the Incident
Tables providing daily details of the WWTP operation for December 2020 through
February 2021, including inflow and irrigation rates, temperatures, and precipitation rates, are
provided in Attachment A. As shown in the tables, minimum temperatures throughout
December were consistently below freezing, only increasing above 32 OF on December 12 (37
OF), December 13 (38 OF), and December 22 (33 OF). In addition, snow cover at the Cottages
from a 3" snow event on December 25 lasted for four days. In January, and the days leading up
to the beginning of the bypass on January 10, it rained 7 out of 10 days, and minimum
temperatures were below 32 OF from January 4 through January 26. In addition to freezing
temperatures and cumulative precipitation totaling more than 18 inches of rain or snow in January,
there was snow cover at the Cottages for 16 out of the 31 days of the month. Inclement weather
continued into February, with only two days with minimum temperatures climbing above the
freezing point (February 14 at 35 OF and February 26 at 33 OF). Between February 1 and February
22, when the bypass ended, there were 13 days of rain or snow, and 8 days of snow cover at The
Cottages.
In an effort to avoid a bypass, Wallace Loft arranged for pumping and hauling of excess
treated effluent on or around January 4. Between January 4 and March 23, a total of 1,068,600
gallons of wastewater was pumped and hauled from the WWTP to the Town of Boone's
wastewater treatment facility (the "Town"), with an associated total cost of $155,400 incurred by
Wallace Loft. However, worsening weather conditions on January 10 prevented haul trucks from
accessing The Cottages, which is located 3,400' above mean sea level. The bypass of treated
wastewater began on January 10. Photographs of the iced -over roads are provided below:
&-. ft. -
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April 8, 2021
Page 3
Pump and haul operations restarted when roads were sufficiently clear on January 18.
The Cottages acquired a mini excavator, placed fresh gravel on the roads, and contracted a
snowplow vendor to attempt to keep access to the wet weather storage tanks open for trucks.
Throughout the event and after, The Cottages pumped and hauled wastewater to the Town to
minimize the total bypass to the extent that it was able. Despite best efforts, The Cottages was
only able to land apply wastewater from the WWTP at the irrigation fields on one day in January
(January 3), and was not able to land apply wastewater again until February 24.
In addition to the challenges presented by inclement weather, The Cottages have
experienced significant increases in water usage and wastewater inflow rates in association with
the Coronavirus pandemic and associated stay-at-home and work -at-home orders. Governor
Roy Cooper issued Executive Order 121 on March 27, 2020, ordering people in the state of North
Carolina to stay at home for thirty days. The Order took effect on March 30, 2020. During the
month of March 2020, before the stay-at-home order took effect, the average daily water usage
at The Cottages was 36,381 gallons/day. By comparison, in February 2021, as residents continue
to abide by subsequent stay-at-home and work -at-home orders, average water usage has
increased to an average of 78,006 gallons/day, with a maximum daily usage of 112,600
gallons/day on February 18, 2021. In short, as residents continue to stay at home, cook at home,
and recreate at home in response to the on -going coronavirus pandemic, The Cottages has
experienced an approximate doubling of water usage. The wastewater system has been able
to meet the increased water usage and wastewater production rates during warmer months
without issue. However, with inclement weather preventing irrigation of treated wastewater and
iced -over access roads preventing the Cottages from pumping and hauling wastewater to the
Town, the WWTP was not able to keep up with the increased wastewater production and avoid
the bypass.
Additional information regarding the storage capacity at the WWTP, and the feasibility of
adding storage capacity, is discussed further below in relation to the efforts to permit a solution to
the WWTP issues during the cold and wet winter months.
Efforts to Obtain a NPDES Coniunctive Use Permit for the WWTP.
The WWTP began operating in 2013. In the first several years of operation, The Cottages
found that properly treating and disposing of effluent during the wet winter months, frequently with
freezing temperatures, presented greater -than -expected challenges. Wallace Loft engaged
Odom Engineering ("Odom") in October 2019 to assist with the challenges experienced at the
WWTP. Odom's analysis confirmed that operational challenges at the WWTP tracked the
weather, with the system running out of storage capacity during high precipitation and freezing
weather periods in and around January through March, as shown in Figure 1 below.
PPAB 622161M.docx

April 8, 2021
Page 4
Figure 1. Comparison of Weather Trends and Remaining WWTP Storage Capacity
Generally, daily inflow to the WWTP varies from 20,000-50,000 GPD. As described further
above, daily averages during the 2020-2021 Coronavirus pandemic have approximately doubled
as residents remain home in accordance with Gov. Cooper's various stay-at-home and work -at-
home orders. Daily irrigation rates vary more widely, from nothing (on days when weather
precludes drip irrigation of wastewater to the irrigation fields), to well above 100,000 GPD.
Importantly, on good weather days, The Cottages can, and frequently does, apply treated effluent
to the irrigation fields at rates at and above 100,000 GPD.
Wet weather storage at WWTP includes a 1,560,000-gallon bolted steel tank that provides
a 14-day capacity for wet weather storage at the maximum design capacity, and a 548,439 million
gallon 5-day upset tank for emergency conditions, which also may be used for additional wet
weather storage. Although The Cottages narrowly managed to avoid exceeding the storage
capacity of the WWTP during the winter months of the first few years of operation, The Cottages
has repeatedly needed to obtain authorizations to haul and dispose of excess effluent to the Town
to prevent system overflow and bypass. Attachment B to this letter provides daily details of
inflow to the WWTP and irrigation rates by field during March 2020, a sample month that saw
significant and frequent precipitation and freezing temperatures. The Table in the attachment
shows that, on good irrigation days, the WWTP is achieving irrigation rates at or above 100,000
GPD. Despite best efforts demonstrated by irrigation flow rates shown in the March 2020
summary, the WWTP did run out of storage capacity in March 2020, and was required to pump
and haul wastewater to Town of Boone's WWTP to avoid a bypass. In 2020, the Cottages
pumped and hauled 569,500 gallons of wastewater to the Town at a cost of $73,500. In 2021,
between January 4 and March 23, The Cottages pumped and hauled a total of 1,068,600 gallons
of wastewater to the Town at a cost of $155,400, and The Cottages would have pumped and
hauled even more wastewater if weather and roads had allowed.
PPAB 622161M.docx

April 8, 2021
Page 5
Odom also evaluated the cost and feasibility of increasing the existing wet weather storage
capacity of the WWTP by adding a 2,000,000-gallon capacity, bolted steel storage tank (86'
diameter by 24' height). Due to the mountainous terrain at The Cottages, installing the additional
storage tank would require blasting to remove rock and grading, as well as the construction of a
retaining wall around the tank. Overall, Odom estimates the construction cost for the new tank
would total more than $1.9 million (or up to $2.2 million with a 25% construction and engineering
contingency). Aerial photographs showing the proposed plans and an estimated cost schedule
prepared by Odom are provided in Attachment C. Further, it is uncertain whether a 2,000,000-
gallon capacity tank would provide adequate storage for a non -discharge WWTP given the
extended periods of precipitation and frozen temperatures experienced at The Cottages during
recent winters.
Connecting The Cottages' WWTP to the Town of Boone's municipal system was also
deemed to be technically infeasible due to, among other things, the prerequisite annexation and
zoning requirements under the Town's existing ordinances.
Odom and Wallace Loft therefore determined to apply to NCDEQ for a NPDES
Conjunctive Use permit that would allow The Cottages to directly discharge treated wastewater
to Laurel Fork, a small stream on property adjacent to the existing WWTP. Note that the purpose
of the permit was only to allow the Cottages to directly discharge to Laurel Fork during periods of
inclement weather when land application of treated wastewater through the drip irrigation system
is not available and wet weather storage capacity is exhausted. In pursuit of the NPDES
Conjunctive Use permit, Wallace Loft applied for and was issued approved speculative effluent
limits for a 0.1 MGD NPDES Conjunctive Use permit on January 10, 2020. Odom also applied
for and received a zoning consistency determination for the requested NPDES Conjunctive Use
permit from Watauga County on April 27, 2020. The Cottages submitted its application for the
NPDES Conjunctive Use permit, including an Engineering Alternatives Analysis ("EAX) prepared
by Odom, on May 20, 2020.
In the fall and winter of 2020, NCDEQ raised questions and requested additional
information regarding the EAA, and ultimately returned the application for a NPDES Conjunctive
Use permit to Wallace Loft in a letter dated January 19, 2021. In follow-up correspondence from
Nathaniel Thornburg, Branch Chief of NCDEQ's Non -Discharge Branch, NCDEQ indicated that
the following specific analyses should be conducted to further evaluate to potential non -discharge
option prior to submitting a revised application for the NPDES Conjunctive Use permit: (1)
reducing the amount of generated inflow to the WWTP; (2) increasing storage capacity of the
WWTP; (3) increasing the irrigation area of the WWTP; and (4) increasing the loading rate to the
existing irrigation areas. Odom and The Cottages are gathering information to provide responses
to these four items. In particular, a soil scientist has been engaged to evaluate the existing
irrigation fields and whether there is any potential to increase land application rates at the existing
irrigation fields or expand the irrigation areas. The soil scientist's report and findings should be
complete by mid -May.
Importantly, Odom and The Cottages believe that the existing WWTP provides more than
sufficient irrigation area for the permitted design capacity of the WWTP, provided weather allows
for the land application of treated wastewater. The limiting factor and root cause of the WWTP
overflows has been, and continues to be, the lack of sufficient storage capacity during periods of
frequent or sustained precipitation and/or freezing weather in the winter months. As discussed
above, the estimated cost to install an additional 2,000,000-gallon capacity storage tank is
between $2 million and $2.2 million.
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April 8, 2021
Page 6
Further, Odom and The Cottages continue to believe that permitting the direct discharge
of treated wastewater to Laurel Creek during the limited periods of inclement weather when the
WWTP's wet weather storage capacity is exceeded is the appropriate path forward. Indeed, had
The Cottage's efforts to obtain the NPDES Conjunctive Use permit in 2020 been successful, the
WWTP would have been authorized to lawfully discharge wastewater in accordance with the
standards and requirements established in the permit, and avoid the bypass that is the subject of
this NOV. Pending the results of the soil scientist's report and further analysis on available
storage capacity options, Odom and The Cottages anticipate submitting the updated information
and analyses to NCDEQ. Odom and The Cottages are hoping to submit an updated and revised
application for a NPDES Conjunctive Use permit that addresses NCDEQ's questions in concerns
in or around June 2021. Further Odom and The Cottages are committed to working with NCDEQ
to obtain a NPDES Conjunctive Use permit to allow for the lawful discharge of wastewater during
periods when the WWTP's wet weather storage capacity is exceeded as a result of inclement
weather.
With proper operation of the WWTP and the improved weather, The Cottages does not
anticipate any further shortage of storage capacity until winter weather returns. In the meantime,
the Cottages and Odom will make every effort resolve the issue, whether through permitting or
other alternatives identified through further analysis. We genuinely appreciate your consideration
of the information provided in this letter, and we look forward to working with you. If you have any
questions regarding this letter, please do not hesitate to contact me at
fern paterson(a)parkerpoe.com or [phone] or David Odom at
davidodom(a)odomengineering.com or [phone].
Sincerely,
r
Fern A. Paterson
Attachment
cc: Patrick Mitchell, NCDEQ (Patrick.mitchell(a-)-ncdenr.gov)
Sean Devine(sean.devine(@cardinalgroup.com)
Justin Pellegrino (iustin.pellegrino _cardinalgroup.com)
Rose Hernandez (rose.hernandez(a�thecottagesofboone.com)
Wayne Farquharson(wayne.farguharson(@mapletree.com.sg)
David Odom(davidodom(a�odomengineering.com)
PPAB 622161M.docx

Cottages of Boone
Daily Detail - December 2020
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26')
5-day (26')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
41
5
6
Total
1,562,000 Gal
548,000 Gal
2020
12
1
T
46
23
0.04
0.10
T
61,273
6.0
22.0
2020
12
2
W
24
20
0.10
1.00
1.0
62,307
6.0
22.0
2020
12
3
Th
42
15
0.00
0.00
1.0
56,608
6.0
22.0
2020
12
4
F
56
15
0.00
0.00
0.0
25,103
6.0
22.0
2020
12
5
Sa
49
32
1.20
0.00
0.0
64,997
2020
12
6
Su
35
30
0.00
0.00
0.0
64,997
8,000
8,000
8,000
8,000
-
32,000
2020
12
7
M
49
32
T
T
T
64,997
-
-
-
-
8,000
950
8,950
6.0
22.0
2020
12
8
T
37
21
T
T
0.0
61,738
6.0
22.0
2020
12
9
W
31
24
0.00
0.00
0.0
60,215
6.0
22.0
2020
12
10
Th
44
27
0.00
0.00
0.0
56,789
6.0
22.0
2020
12
11
F
59
26
0.00
0.00
0.0
24,735
16,000
15,518
8,242
9,162
15,214
12,532
76,668
6.0
22.0
2020
12
12
Sa
57
25
0.01
0.001
0.0
58,429
17,469
26,620
25,883
28,000
27,150
27,626
152,748
2020
12
13
Su
56
37
0.64
0.00
0.0
58,429
17,469
26,620
25,883
28,000
27,150
27,626
152,748
2020
12
14
M
60
38
0.07
0.00
0.0
58,429
-
-
-
-
-
6.0
22.0
2020
12
15
T
44
22
0.18
0.00
0.0
58,657
6.0
22.0
2020
12
16
W
39
21
1.05
0.00
T
57,072
2020
12
17
Th
36
26
T
T
0.0
57,078
6.0
22.0
2020
12
18
F
35
23
0.00
0.00
0.0
56,959
6.0
22.0
2020
12
19
Sa
35
17
0.00
0.00
0.0
49,454
2020
12
20
Su
38
16
0.05
0.00
0.0
49,454
2020
12
21
M
50
30
0.00
0.00
0.0
49,454
8,000
8,000
8,000
9,870
8,236
8,000
50,106
6.0
22.0
2020
12
22
T
48
33
0.00
0.00
0.0
45,277
-
-
6.0
22.0
2020
12
23
W
43
21
0.04
0.00
0.0
46,218
-
-
-
-
6.0
22.0
2020
12
24
Th
45
22
2.04
0.00
0.0
36,580
2020
12
25
F
48
12
0.03
2.50
3.01
36,580
2020
12
26
Sa
14
8
0.00
T
3.0
36,580
2020
12
27
Su
33
8
0.00
0.00
3.0
36,580
2020
121
281
M
1 43
15
0.00
0.00
1.0
36,580
6.0
22.0
2020
12
29
T
41
25
0.00
0.00
0.0
33,907
6.0
22.0
2020
121
30
W
51
24
0.00
0.00
0.0
54,225
6.0
22.0
2020
12
31
TH
51
24
0.00
0.00
0.0
60,889
6.0
22.0
Month Ttl. 1,580,590 66,938 84,758 76,008 83,032 85,750 76,734 473,220
Avg. Daily 50,987 15,265

Cottages of Boone
Daily Detail - January 2021
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26)
5-day (26)
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
41
5
6
Total
1,562,OOOGal
548,000Gal
2021
1
1
F
60
39
0.06
0.00
0.0
57,872
2021
1
2
Sa
48
34
0.84
0.00
0.0
57,872
2021
1
3
Su
59
39
0.00
0.00
0.0
57,872
5,338
8,000
7,972
3,669
9,234
8,000
42,213
2021
1
4
M
42
30
T
T
T
57,872
-
-
-
-
-
-
-
1.5
4.5
2021
1
5
T
42
30
T
0.00
0.0
57,682
-
-
-
-
-
-
-
1.5
4.5
2021
1
6
W
38
26
0.04
0.00
0.0
57,131
-
-
-
-
-
-
-
1.3
4.5
2021
1
7
Th
34
23
0.00
0.00
0.0
35,815
-
-
-
-
-
-
-
0.7
4.5
2021
1
8
F
37
21
0.25
4.00
4.0
55,838
-
-
-
-
-
-
-
2021
1
9
Sa
33
25
0.15
2.00
6.0
55,838
2021
1
10
Su
29
12
0.00
0.00
5.0
55,838
2021
1
11
M
41
11
0.00
0.00
4.0
52,196
-
-
-
-
-
-
-
0.0
0.2
2021
1
12
T
34
24
0.12
1.00
4.0
50,617
-
-
-
-
-
-
-
0.0
0.2
2021
1
13
W
37
17
0.00
0.00
3.0
55,212
-
-
-
-
-
-
-
0.0
0.2
2021
1
14
Th
51
16
0.00
0.00
2.0
48,622
0.0
0.2
2021
1
15
F
51
22
0.00
0.00
1.0
67,673
0.0
0.2
2021
1
16
Sa
38
23
T
T
T
67,673
2021
1
17
Su
30
25
0.02
1.00
1.0
67,673
-
-
-
-
-
-
-
2021
1
18
M
36
26
0.12
2.50
3.0
67,673
-
-
-
-
-
-
-
0.0
0.2
2021
1
19
T
31
26
T
0.00
T
52,839
0.0
0.2
2021
1
20
W
42
26
0.00
0.00
T
64,205
0.0
0.2
2021
1
21
Th
39
26
T
1.00
0.0
25,979
0.0
0.2
2021
1
22
F
37
32
T
0.00
0.0
67,469
0.0
0.2
2021
1
23
Sa
44
26
0.00
0.00
0.0
66,843
2021
1
24
Su
39
18
0.00
0.00
0.0
66,843
2021
1
25
M
44
23
T
Tj
0.0
66,843
-
-
-
-
-
-
-
0.0
0.2
2021
1
26
T
49
38
0.55
0.55
0.0
66,674
0.0
0.2
2021
1
27
W
60
37
0.00
0.00
0.0
65,828
-
-
-
-
-
-
-
0.0
0.2
2021
11
28
Th
56
23
0.18
0.18
T
36,351
-
-
-
-
-
-
-
0.0
0.2
2021
1
29
F
27
14
T
T
T
63,851
-
-
-
-
-
-
-
0.0
0.2
2021
11
30
Sa
31
14
0.00
0.00
0.0
69,026
2021
11
31
Su
36
14
0.40
4.00
169,026
Month Ttl. 1,808,746 5,338 8,000 7,972 3,669 9,234 8,000 42,213
Avg. Daily 58,347 1,362

Cottages of Boone
Daily Detail - February 2021
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26')
5-day (26')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
41
5
6
Total
1,562,000 Gal
548,000 Gal
2021
2
1
M
37
19
0.18
0.00
2.0
69,026
0.0
0.2
2021
2
2
T
32
17
0.05
1.00
1.0
71,422
0.0
0.2
2021
2
3
W
23
17
T
T
T
71,422
0.0
0.2
2021
2
4
Th
30
17
0.00
0.00
0.0
74,325
0.0
0.2
2021
2
5
F
44
17
0.03
0.00
0.0
53,012
0.0
0.2
2021
2
6
Sa
44
28
0.00
0.00
0.0
65,828
2021
2
7
Su
41
16
0.23
2.50
3.0
65,828
2021
2
8
M
37
15
0.00
0.00
1.0
65,828
0.0
0.2
2021
2
9
T
43
30
0.00
0.00
1.0
69,042
0.0
0.2
2021
2
10
W
49
29
0.00
0.00
0.0
20,069
0.0
0.2
2021
2
11
Th
51
28
0.00
0.00
0.0
72,336
0.0
0.2
2021
2
12
F
49
27
0.25
0.00
0.0
68,322
0.0
0.2
2021
2
13
Sa
32
32
0.69
0.00
T
67,048
2021
2
14
Su
1 39
35
0.45
0.00
0.0
67,048
2021
2
15
M
42
22
0.18
0.00
0.0
67,048
0.0
0.2
2021
2
16
T
37
31
0.45
0.00
0.0
67,589
0.0
0.2
2021
2
17
W
36
17
T
0.00
0.0
32,212
0.0
0.2
2021
2
18
Th
36
18
0.26
0.00
T
94,634
0.0
0.2
2021
2
19
F
36
31
0.64
0.00
0.0
45,246
0.0
0.2
2021
2
20
Sa
36
17
0.00
0.00
0.0
65,947
2021
2
21
Su
32
15
0.00
0.00
0.0
65,947
2021
2
22
M
39
15
0.00
0.00
T
65,947
0.0
0.2
2021
2
23
T
46
32
0.29
0.00
0.0
65,193
0.0
0.2
2021
2
24
W
53
31
0.00
0.00
0.0
32,520
14,856
16,000
16,000
16,000
16,000
10,542
89,398
0.2
0.2
2021
2
25
Th
64
29
0.00
0.00
0.0
71,007
23,616
24,000
18,196
16,000
16,000
21,436
119,248
1.1
0.2
2021
2
26
F
5
33
0.00
0.00
0.0
63,263
16,000
8,470
13,726
16,000
16,000
16,000
86,196
1.5
0.2
20211
021
2
27
Sa
41
31
0.841
0.001
0.0
67,118
20,000
20,000
20,000
20,000
24,000
18,000
122,000
20211
21
28
Su
601
311
1 0.001
0.001
0.0
67,118
20,000
20,046
20,046
21,216
24,000
18,372
123,680
Month Ttl. 1,771,345 94,472 88,516 87,968 89,216 96,000 84,350 540,522
Avg. Daily 63,262 17,436

Cottages of Boone
Daily Detail - March 2020
Date
Weather Observations
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26')
5-day (26')
Year
Month
Day
Max.
Min.
(in)
(in)
11
2
3
4
5
6
Total
1,562,000 Gal
548,000 Gal
2020
3
1
Su
32
20
0.00
0.00
53,608
-
-
3.0
4.5
2020
3
2
M
54
27
0.00
0.00
40,131
25,000
20,000
10,000
10,000
-
65,000
2.7
4.5
2020
3
3
T
49
31
T
0.00
51,294
20,000
20,000
10,000
10,000
60,000
2.5
4.5
2020
3
4
W
58
39
0.72
0.00
56,591
20,000
20,000
10,000
10,000
60,000
2020
3
S
Th
56
38
0.00
0.00
S6,S91
27,130
20,010
1,162
-
100,000
148,302
4.5
4.5
2020
3
6
F
50
29
T
0.00
53,665
2,754
10,000
10,000
10,000
9,978
42,732
5.0
4.5
2020
3
7
Sa
38
25
0.11
T
21,920
10,000
10,000
10,000
10,000
7,324
47,324
2020
3
8
Su
42
20
0.00
0.00
21,920
9,018
6,396
4,100
4,970
-
24,484
2020
3
9
M
56
19
0.00
0.00
21,920
29,614
27,152
10,000
10,012
25,920
102,698
5.0
4.5
2020
3
10
T
59
24
T
0.00
30,101
30,000
22,162
11,814
10,000
30,000
103,976
6.6
4.S
2020
3
11
W
60
4S
0.18
0.00
50,363
27,912
32,514
10,000
10,000
30,000
110,426
8.0
6.S
2020
3
12
Th
64
3S
0.00
0.00
56,100
17,746
18,604
10,000
15,830
30,000
92,180
9.0
7.5
2020
3
13
F
63
34
0.28
0.00
28,562
-
-
-
-
-
-
10.5
7.5
2020
3
14
Sa
61
46
0.00
0.00
28,531
28,637
30,568
30,000
89,205
2020
3
15
Su
SS
44
T
0.00
28,531
28,637
30,568
30,000
89,205
2020
3
16
M
53
35
0.03
0.00
28,531
-
-
-
-
11.5
7.5
2020
3
17
T
43
35
0.03
0.00
31,786
10,000
6,084
10,000
26,084
11.0
7.5
2020
3
18
W
56
41
0.08
0.00
30,410
-
-
-
-
-
-
11.0
7.5
2020
3
19
Th
55
41
0.03
0.00
31,498
16,014
18,308
1,186
10,000
20,000
65,508
10.5
7.5
2020
3
20
F
68
50
0.04
0.00
31,284
26,175
22,645
9,703
10,000
30,000
98,523
11.0
7.S
2020
3
21
Sa
68
53
0.13
0.00
33,513
26,175
22,645
9,703
-
30,000
88,523
2020
3
22
Su
60
3S
0.00
0.00
33,513
26,175
22,645
9,703
30,000
88,523
2020
3
23
M
47
38
0.23
0.00
33,513
-
-
13.0
7.5
2020
3
24
T
57
38
0.43
0.00
30,809
12.5
7.5
2020
3
25
W
51
42
1.12
0.00
30,065
12.0
7.5
2020
3
26
Th
57
39
0.12
0.00
31,261
-
-
-
-
-
-
11.5
7.5
2020
3
27
F
62
41
0.00
0.00
29,664
13,586
25,016
10,000
18,166
20,000
86,768
12.5
7.5
2020
3
28
Sa
78
41
0.00
0.00
30,243
29,951
18,088
924
10,000
30,000
88,963
2020
3
29
Su
81
49
0.00
0.00
30,243
29,951
18,088
-
-
30,000
78,039
20201
31
301
M
81
48
0.00
0.00
30,243
29,951
18,088
30,000
78,039
14.8
7.5
20201
31
31
T
611
461
1 0.00
0.00
27,351
-
-
10,000
3,754
-
13,754
14.8
7.5
Month Ttl. 1,093,755 484,426 439,581 148,295 152,732
Avg. Daily 35,282
523,222 1,748,256
56,395

rizi
� Odom
Engineering
PLLC
COTTAGES AT BOONE
TWO MILLION GALLON TANK COST ESTIMATE
APRIL 2021
Item Description Quantity Unit Unit Price Cost
1
Grading
15000
CY
$15.00
$225,000.00
2
Rock
100
CY
$100.00
$10,000.00
3
Retaining Wall
8,750
SF
$25.00
$218,750.00
4
Piping
1
LS
$35,000.00
$35,000.00
5
Tank Installation
1
LS
$1,500,000.00
$1,500,000.00
CONSTRUCTION SUBTOTAL
$1,988,750.00
5
Construction Contingencies/Engineering (25%)
$198,875.00
CONSTRUCTION TOTAL
$2,187,625.00
TOTAL PROJECT ESTIMATE
$2,200,000.00

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PARCEL ID: 2900317651000 7
MAY, ELIZABETH WHITE "/'�f/_ i'>/�/jj/j/ %''- - - _ - '� \•'G 1� �4�
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Odom
Engineering
PLLC
169 Oak Street, Forest City, N.C. 28043
ph: 828.247.4495 fax: [phone]
NC Firm#: P-0880
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JOB NAME: COTTAGES OF BOONE
LOCATION: BOONE, NC
DESCRIPTION: OVERALL SITE 2MG WASTEWATER TANK
BEST CHOICE for NEW LOCATION
SCALE: 1" = 100' IDRAWN BY: BSR
DATE: 08/29/12 CHECKED BY: DWO
PROJECT MGR: PED
PROJECT NUMBER ISHEET
19162 1 1 OF 20
U111W 7.11a

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VANNOY, JAMES L. VANNOY,
PEGGY SUE
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APPROVED:
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Odom
Engineering
PLLC
169 Oak Street, Forest City, N.C. 28043
ph: 828.247.4495 fax: [phone]
NC Firm#: P-0880
NOT
FOR
CONSTRUCTION
JOB NAME: COTTAGES OF BOONE
LOCATION: BOONE, NC
DESCRIPTION: PROPOSED RETAINING WALL for
NEW 2 MG WASTEWATER TANK
SCALE: 1" = 60'
DRAWN BY: BSR
DATE: 08/29/12 1 CHECKED BY: DWO
PROJECT MGR: PIED
PROJECT NUMBER ISHEET
19162 1 2 OF 20
U111W 7.11a

a\�C ity SoY,
z �A�
Empowering Energy Efficiency
EFFICIENCY &EMISSIONS REPORT
Utilities Optimization & Capital Construction Plan
Prepared for Mapletree Investments I Cottages at Boone (Toilet Replacement)
June 2021

aSEquity SONG
Empowering Energy Efficiency
Your facility is likely to consume more than 9.1 million gallons of water during the next 12 months, or a 46% overage. This report provides
recommended efficiency upgrades that if installed will help decrease this overage while creating a quantifiable environmental impact. If
implemented, the Program herein will:
• Meaningfully reduce the blended annual utilities expense at your asset and ensure ongoing expense savings
• Increase the capped value of your facility upon refinance or disposition
• Generate an attractive unlevered ROI on invested capital
EMISSIONS TOTAL
T-12 Consumption (Gallons) 19,809,450
Protected F-12 Consumption (Gallons) 10,681,573
Projected Usage Savings (Yr 1) 9,127,877
%of Historical 46%
CAPITAL REQUIREMENT
Efficiency Program Retrofit Hard/Soft Costs $426,756
Projected Rebates
Net Capital Requirement After Rebates $426,756
2

aSEquity SONG
Empowering Energy Efficiency
Investing for Expense Savings
Below are the recommended efficiency upgrades we've identified alongside projected expense reductions for each:
EMISSIONSEFFICIENCY & AD
The Cottages Boone
ECM Gross Cost
UTILITY CONSUMPTION
SAVINGS (GALLONS) Rebates
Net Cost
ELECTRICAL
WATER/SEWER
High Efficiency Toilets - 0.8 GPF
$295,020
3,466,654 $0
$295,020
High Efficiency Bathroom Sink Aerator - 0.5 GPM
$14,751
2,113,008 $0
$14,751
High Efficiency Showerhead - 1.25 GPM
$24,585
1,683,803 $0
$24,585
High Efficiency Kitchen Sink Aerators - 1.0 GPM
$5,775
864,412 $0
$5,775
In -Unit Water Meters
1 $86,625
1 1,000,000 $0
1 $86,625
!TOTAL: WATER/SEWER
EF6,756
$0
$426,756
TOTAL PROJECT COSTS
$426,756
9,127,877 $0
$426,756

Investing for Environmental Impact I Water
Implementation of an Efficiency Program will help to decrease your ongoing Water consumption in the following ways:
WATER/SEWER USAGE
2,500,000
$2,500,000
2,000,000
$2,000,000
c
0
1,500,000
$1,500,000
1,000,000
$1,000,000
0
500,000
$500,000
Of����������� 11 $0
f i f f f i f f i f f i�
0 0 0 0 0 0 0 0 0 0 -I _4
N N N N N N N N N N N N
a a 5 o z o
�T-12 TOTAL GALLONS F-12 TOTAL GALLONS
T-12 TOTAL $ F-12 TOTAL $
aSEquity SONG
Empowering Energy Efficiency
WATER SAVINGS OF: 9,127,877 Gallons
63.4 13.8
Average Olympic
residential homes OR swimming
for one year 100111�' pools
156.7
Average
residential
lawns
(irrigation)
536,934
O
OR O O O O Average
OO O O personal
OO O 0 showers
Expense
Consumption (Gallons)
Annual Water Savings
Previous 12 Months
$19,809,450
19,809,450
30 Olympic Pools
Next 12 Months
$10,681,573
10,681,573
16.2 Olympic Pools
Decrease of T-12
46%
46%
TOTAL EFFICIENCY
S9.127.877
9.127.877
Savings of 13.8 Olvmoic Pools
An

aC 'quity 8 Y,
Empowering Energy Efficiency
Our Service Lines
SERVICE
DESCRIPTION
Utilities &
We provide initial utilities audits and expert analysis surrounding the feasibility and benefit of upgrading the utilities infrastructure of
Efficiency
commercial real estate facilities you own or manage today. As your Utilities Partner, we also provide the same initial analysis for new
Consulting
acquisitions you may be considering.
Site Audit /
Utilizing degreed and licensed energy managers, professional engineers, and energy consultants, we identify and audit the design,
Efficiency Plan
operation, and maintenance parameters of your Facility to identify efficiency opportunities as well as to create a baseline to benchmark
Design
current utilities consumption. The result of this effort is our Efficiency & Emissions Report alongside a fixed -price utilities upgrade and
project management agreement.
Materials
Sourcing our deep network of trusted suppliers, we procure all of the materials required to achieve the efficiency upgrades outlined in this
Procurement /
report and then act as your project manager overseeing their installation onsite. To do so, we use our vetted list of national, regional, and
Project
local vendors and utilize our experience as former institutional real estate owners/operators to ensure minimal disruption to ongoing
Management
operations and tenant satisfaction.
Rebate &
Upon Project completion, we provide you with all applicable manufacturer warranties on the purchased materials and serve as your Rebate
Warranty
processor, identifying as many available rebates as we can and then tracking their application and award.
Processing
Measurement
Finally, we provide ongoing measurement and verification "M&V" to track the reduced utilities consumption as well as the ongoing utilities
& Verification
Cost Avoidance at the asset level to accurately illustrate progress and to provide full accountability of both the environmental and financial
Services
impact of the efficiency investment. These M&V services provide you with data and sustainability metrics to share with your team and
other outside parties.

aSEquity SONG
Empowering Energy Efficiency
Execution Timeline
The table below illustrates the projected execution timeline beginning upon mutual execution of the contract to Efficiency Program closeout.
PROJECT PHASE
WEEK 1 WEEK 2 WEEK 3 WEEK 4 WEEK 5 WEEK 6 WEEK 7 WEEK 8 WEEK 9 WEEK 10
CONTRACT EXECUTION
Project Awarded / Mutual Contract Execution
PRECONSTRUCTION
Materials Deposit Due (50%of Project Cost)
Kickoff Call
Materials Procurement
Installation Scheduling
EXECUTION
Mobilization & Start -Up
Project Installation
Substanital Project Completion I Quality Control
2nd Deposit Due (40% of Project Cost)
Final Project Completion I Punch
PROJECT CLOSEOUT
Rebate Processing
Warranty Processing
Final Invoicing (10% of Project Cost)
* Timeline above may change to due materials ordering and size of project

Process & Next Steps
1: Site Tour & FINAL Utilities Audit
We've toured your facility and conducted a utilities audit, the findings
included herein. The Efficiency & Emissions Report includes:
• Detailed utilities audit of your facility and step-by-step blueprint
to expense savings
• A fixed -price contract for our auditing & engineering consulting,
materials and labor, we construction management services, rebate
and warranty processing, and Measurement & Verification of
savings upon completion
2: Financing & Installation of Improvements
You fund the infrastructure improvements and we procure the
materials, manages the vendors, and serves as project manager over
the install. If you choose to move forward, we will execute a project
management agreement outlining the terms and conditions of our
utilities consulting, materials procurement, and construction
management services. Project Management Agreement payment
schedule:
PROJECT
$213,378 50% upon contract execution
$170,702 40% upon substantial project completion
$42,676 10% upon full project completion
3: The Contract between Navitas / Owner
Upon project completion, we processes identified rebates and provides
monthly measurement & verification services illustrating the utilities
consumption and cost savings for 12 months.
7
aSEquity SONG
Empowering Energy Efficiency

aC 'quity 8 Y,
Empowering Energy Efficiency
Efficiency Program Technologies
Below is a list of the Efficiency Program upgrades we recommend for your asset.
Water I Water fixtures, in the context of this report, include low -flow fixtures, water line apparatus, and smart irrigation systems.
Technologies I Shower Heads and Aerators
• Niagara High Efficiency Shower Heads are durable, have classic aesthetics, and offer a TamperProof option
• The Bathroom and kitchen aerators
• The 0.5 needle spray bathroom aerator has great pressure to efficiently wash hands
• The 1.5 Dual Spray kitchen has the force to clean dishes
Toilets
• STEALTH fixtures by Niagara can use as little as 0.625 gallons/flush - >50% improvement on the current toilets.
• Vacuum assisted technology that has a MaP premium rating of 800 which is a comparable force to a 1.6 GPF toilet; or a toilet that
uses 2x more water.
• Low flow toilets, the ones that are referred to often, are usually flapper toilets or pressure assisted which creates the following:
1) Pressure Assisted loud and dangerous. Not ideal for residential application because of their supersonic jet -like noise
2) Flapper Toilets are costly, leaky and running. Flapper Toilet Slow gravity fed that lacks force
3) Niagara has a Lifetime Warranty on Ceramic, 10-year on internals with little to no maintenance costs

aC quity8Y,
Empowering Energy Efficiency
Identified Rebate & Manufacturer Warranty Detail
IDENTIFIED REBATES
n/a
MANUFACTURER WARRANTIES
$ AMOUNT
DESCRIPTION & PROJECTED TIMELINE
DESCRIPTION & PROJECTED TIMELINE
High Efficiency Bathroom Sink Aerator - 0.5 GPM 1-year Product Warranty
High Efficiency Showerhead - 1.25 GPM 10-year Product Warranty
High Efficiency Kitchen Sink Aerators - 1 GPM 1-year Product Warranty
Zennergy Flow Management Device 15-year Product Warranty

Odom
Engineeftpuc
July 12, 2021
Mr. John Hennessy
Division of Water Resources
Water Quality Permitting Section - NPDES
Archdale Building — 9th Floor
512 North Salisbury Street
Raleigh, NC 27604
Dear Mr. Hennessy
169 Oak Street • Forest City, NC 28043
office 828.247.4495 • fax [phone]
Re: Application/EAA / LG Document Transmittal
For Conjunctive Use Permit Application
Resubmission
On behalf, Cottages of Boone WWTP
Permit No.: WQ0035784
Watauga County, NC
Please find enclosed a revised conjunctive use permit application for The Cottages of Boone WWTP. As you know,
NCDEQ returned the original application for the conjunctive use permit due to the Division of Water Resources'
identification of deficiencies in the Engineering Alternatives Analysis (EAA). This revised submission addresses
previous comments and concerns of the Division.
In addition to an expanded EAA, we have revised the previously submitted application Form D with updated
information, please advise if the department will require the newer Modified Application Form 2-A for this re-
application. Please note that we are recommending implementation of water efficiency measures with a goal of
reducing water usage by greater than 40%, in addition to continued irrigation to the maximum extent possible, and
a maximum permitted discharge of 0.035 MGD, for use only when necessary to prevent bypass of existing storage
during periods of extended inclement weather.
Enclosed please find:
• Three (3) bound sealed and signed copies of the Engineering Alternatives Analysis and Local Government
Review Forms submitted on behalf of Cottages of Boone WWTP;
• NPDES Application Form D; and
• Application Fee ($860.00).
A speculative effluent limits letter was issued for this project on January 10, 2020.
Thank you for your department's assistance with this important project, and for your department's review and
comment of the enclosed documents. Please direct any questions regarding the enclosed application to me or Pete
Dickerson at 828-247-4495 voice, or email [e-mail] and [e-mail] .
Sincerely,
a a t--
David Odom, P.E.

ENGINEERING ALTERNATIVES ANALVQS
for
Conjunctive Use Permit Application
at
Cottages of Boone WWTP
Permit No. WQ0035784
Watauga County, North Carolina
Watauga River Basin
nR TTE
0 F B 0 0 :CAI F,'
Revised July 09, 2021
May 12, 2020
t`
Prepared by:
Odom Engineering, PLLC
Odom
Engineeringr�.�.c
169 Oak Street •Forest City, NC 28043
office 828.247.4495 •fax [phone]

Table of Contents
1. Executive Summary..................................................................................................................... 1
2. Applicant Information................................................................................................................. 2
3. Existing Conditions...................................................................................................................... 2
4. Flow Projections.......................................................................................................................... 4
5. Alternatives Analysis................................................................................................................... 5
5.1 Do Nothing Alternative......................................................................................................... 5
5.2 Conjunctive Use: Irrigate + Discharge to Laurel Fork (Preferred Alternative) ...................... 6
5.3 Connection to Municipal System.......................................................................................... 9
5.4 Increase Wet -Weather Storage Capacity............................................................................. 9
5.5 Reduce Generated Flow...................................................................................................... 10
5.6 Cover Tanks to Reduce Precipitation Inflow....................................................................... 11
5.7 Increase Irrigation Area or Irrigation Rate.......................................................................... 11
6. Alternatives Summary............................................................................................................... 12
7. Local Government Review........................................................................................................ 13
8. Conclusions and Recommendations......................................................................................... 13
Appendices.................................................................................................................................... 14
Appendix A — The Cottages NOV Response, dated April 8, 2021
Appendix B — Daily Detail and Storage Analysis — Winter 2020-2021
Appendix C — Daily Detail and Storage Analysis with 40% inflow reduction — Winter 2020-2021
Appendix D — Additional Storage Tank Evaluation
Appendix E — Navitas Equity Solutions Efficiency & Emission Report, June 2021
Appendix F — Present Worth Evaluation of Alternatives
NPDES Permit No. WQ0035784, The Cottages of Boone WWTP
Speculative Effluent Limits - Laurel Fork, Watauga River Basin
Chronic Toxicity Test Results — The Cottages of Boone WWTP
Local Government Review Form -Watauga County, NC
Local Government Review Form —Town of Boone

1. Executive Summary
The Cottages of Boone ("The Cottages") WWTP seeks a conjunctive use discharge permit to allow
discharge of treated effluent to Laurel Fork, a stream near the WWTP, to supplement irrigation and on
site storage capacity of the existing permitted system. This request seeks authorization to permit the
Cottages of Boone WWTP to continue disposal of effluent through irrigation to the maximum extent
practical and permissible, and to discharge treated effluent to Laurel Fork only when necessary to
prevent overflow and bypass of existing storage, including during periods of extended inclement
weather when irrigation fields are not available.
Although the system exceeds design capacity requirements for irrigation area and storage capacity for
the residents served, in recent years extended periods of inclement weather (precipitation and
temperature) has resulted in periods where production exceeds storage and application capacity. During
these periods, the WWTP is forced to haul and dispose treated effluent into the Town of Boone WWTP
treatment system, at great expense, and with high risk of overflow of the system.
This Engineering Alternative Analysis (EAA) compares various alternatives for providing additional
treated effluent disposal capacity to reduce or eliminate the need for over the road hauling and
disposal.
The Cottages proposes to implement two of the identified alternatives, as follows:
Implement water efficiency upgrades, including replacing existing toilets and shower heads,
installing aerators in bathroom and kitchen sinks, and installing in -unit water meters to monitor
for, identify, and correct leaks. The goal of the proposed water efficiency upgrades, described
further herein, is to reduce water usage at The Cottages by greater than 40%. The Cottages will
begin implementing the water efficiency upgrades as soon as practicable and plans to complete
the upgrades by the end of the third calendar quarter (i.e., September 30, 2021). As discussed
further herein, the proposed water use reduction relieves the demand for treated wastewater
storage capacity, but would not eliminate overflows during extended periods of inclement
weather, as demonstrated based on actual data from January through February 2021.
2. Apply for and obtain a Conjunctive Use NPDES Permit authorizing the limited discharge of
treated wastewater from the WWTP to the nearby Laurel Fork when needed to prevent
overflow of the treated wastewater storage tank, particularly during periods of extended
inclement weather during winter months that prevents irrigation to the existing fields. This
alternative will require obtaining an approximately 150-foot easement across an adjoining
parcel and the installation of a gravity -flow discharge line. The Cottages proposes to begin
implementing the proposed alternative upon receipt of all required permits, including the
requested Conjunctive Use NPDES Permit.
11

2. Applicant Information
The Cottages of Boone WWTP is located at 615 Fallview Lane, Boone, NC 28607, in Watauga
County, North Carolina. The WWTP and irrigation system is operated under Permit No.
WQ0035784.
The Cottages of Boone WWTP is owned and operated by Wallace Loft, LLC, 2711 Centerville
Road, Suite 400, Wilmington, Delaware 19808. Phone [phone], email
[e-mail].
This EAA has been prepared by David Odom, P.E., Odom Engineering, PLLC, located at 169 Oak
Street, Forest City, NC, 28043. Phone [phone], email
[e-mail].
3. Existing Conditions
The Cottages of Boone is a residential apartment complex located just outside of the town
limits of Boone, in Watauga County, North Carolina. Wallace Loft, LLC, owner of the Cottages of
Boone, owns and operates a wastewater treatment plant serving the complex's 894 bedrooms,
five administrative/clubhouse employees, a fitness center, and a pool at The Cottages of Boone,
under NC DEQ-DWQ Permit No. WQ0035784. This permit is for continued operation of a
108,530 GPD domestic wastewater treatment and irrigation facility, as described in the
attached permit. Average three-year flow for the WWTP is 44,000 GPD. Please see figure 1
below, USGS Quadrangle showing the WWTP and proposed discharge location.
Water usage rates prior to the onset of the COVID-19 pandemic and associated stay-at-home
and work -at home orders, water usage at The Cottages averaged around 36,000 GPD. The
water usage approximately increased to about 57,000 GPD during the COVID-19 pandemic with
days reaching and exceeding doubled to around 70,000 GPD. Water usage has not dropped off
significantly since, and The Cottages believes that water usage could continue to be elevated
indefinitely due to societal changes associated with the pandemic.
2

Vip
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13
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Figure 1 — WWTP and Proposed Discharge Location

Currently, disposal of effluent is via drip irrigation system, consisting of approximately 14.39 acres of
drip irrigation area with a mixed hardwood and pine forest cover crop. The treatment system complies
with 15A NCAC 02T .0506(c). This high level of treatment allows irrigation setbacks from property lines
to be reduced to zero feet. The existing system exceeds design capacity for disposal of permitted flow
as detailed in the attached permit. A 1,562,000-gallon bolted steel tank provides 14-day capacity for
wet weather storage.
Irrigation is not appropriate during inclement weather or when the ground is in a condition that will
cause ponding or runoff (i.e., fully saturated or frozen soil surface).
As noted, extended periods of freezing temperatures and high precipitation have at times limited
irrigation to the extent that production of treated effluent exceeds storage capacity. A permit to haul
and dispose treated effluent has been obtained; and during these periods outside contractors must be
employed to haul and dispose treated effluent at the Town of Boone WWTP. This situation was
especially dire during the most recent winter season, December 2020 through February 2021.
Continuous severe weather, in combination with significantly increased wastewater inflow rates in
association with the Coronavirus pandemic and associated stay-at-home and work -at-home orders.
Water usage at The Cottages during this period was almost double that of the comparable previous year
period. Between January 4 and March 23, a total of 1,068,600 gallons of wastewater was pumped and
hauled from the WWTP to the Town of Boone's wastewater treatment facility (the "Town"), with an
associated total cost of $155,400 incurred by Wallace Loft. However, worsening weather conditions on
January 10 prevented haul trucks from accessing The Cottages, which is located 3,400' above mean sea
level. A bypass of treated wastewater began on January 10, 2021 and continued until February 22.
Additional information related to this bypass is provided in The Cottage's response to the NCDEQ's NOV
related to this incident, dated April 8, 2021, and attached here as Appendix A.
4. Flow Projections
The Cottages of Boone WWTP serves only this facility and buildout for the complex is complete. Average
flows for the previous past three years were 44,000 GPD, but, as noted previously, wastewater inflows
were significantly increased in association with the Coronavirus pandemic. Average daily inflow for the
December 2020 through February 2021 study period increased to 57,000 GPD. A reduction toward
previous use levels would be expected as we exit the pandemic, but there will likely be a lasting increase
in wastewater inflows due to societal changes associated with the pandemic. Additionally, The Cottages
has contracted a specialist to design and fast -track implement a water conservation program with a
stated goal of greater than 40% reduction of water use. This conservation program is presented (and
recommended) as one of the suggested alternatives herein, and The Cottages proposes to begin
implementing the proposed water efficiency measures as soon as practicable, and complete
implementation by the end of 3Q21. However, as discussed further below, the water efficiency
measures do not eliminate the need for the requested conjunctive use permit. In view of these
unknowns regarding flow projections, the conservative approach is to use the winter 2020-2021 study
period flows, and the current 3-year average daily flows where applicable.
r1

5. Alternatives Analysis
Alternatives considered include the following:
1. Do nothing. Continue to pump and haul when irrigation and storage capacity is exceeded.
2. Conjunctive use permit (preferred). Irrigate when conditions permit, discharge to Laurel Fork
only as necessary to prevent overcapacity condition.
3. Connect to municipal system for disposal of untreated effluent.
4. Increase on -site storage.
5. Reduce generated wastewater.
6. Cover tanks to eliminate precipitation inputs.
7. Increase irrigation area and or increase loading rate on existing irrigation areas.
Each alternative is evaluated to determine the following:
• Whether it is technically feasible,
• Whether it is expected to provide a practical alternative to direct discharge, and
• Whether it would be cost prohibitive to implement relative to a direct discharge alternative.
Assumptions: For comparison purposes this study will analyze overall cost of handling wastewater
inflow from The Cottages of Boone, including collection, treatment, through to final disposal of effluent.
Relatively equal treatment process costs exist in all considered alternatives except for the Municipal
Connection, where costs associated with onsite treatment reduced to maintenance of the lift station.
For present worth valuation of alternatives, a 20-year facility lifespan is assumed with a 2.5% current
EPA discount rate. Winter 2020-2021 study period flows and weather conditions are used in the
comparative analyses.
The alternatives considered are each discussed individually below.
5.1 Do Nothing Alternative
Under this alternative, The Cottages of Boone WWTP will continue to pump and haul when
irrigation and storage capacity are exceeded. Wet weather storage at the WWTP includes a
1,560,000-gallon bolted steel tank that provides a 14-day capacity for wet weather storage at
the maximum design capacity, and a 548,439 million gallon 5-day upset tank for emergency
conditions, which also may be used for additional wet weather storage.
Wet weather storage capacity has proven to be sufficient for the spring, summer, and fall
seasons, when irrigation is not limited by freezing conditions or saturated soils from
precipitation.
Annual costs for the do nothing alternative (continued pump and haul) can be estimated based
on the daily operational and weather records for the facility for the most recent winter season.
Based on these records, under the severe climate and high inflow conditions described below,
estimates show that it may be necessary to pump and haul up to 3.1 million gallons per year
under worse -case conditions (or 1.1 million gallons per year assuming a 40% reduction in water
5

usage), as were experienced during the 2020-2021 winter season. Based on this estimated
overage, pump and haul costs for a successful pump and haul season, with all bypasses
prevented, could reach an annual cost of $436,271.
Additionally, under this option, there is a higher likelihood for unintentional overflow and
release of effluent, being dependent on manual observations of storage freeboard, dependence
on availability of outside contractors for pumping, hauling, and disposal of effluent, and safe
road conditions for hauler access.
For purposes of alternative comparison, the present worth estimate for this alternative is based
on actual expenditure of $155,400, plus an assumed annual budget of $10,000 for potential
fines for bypasses.
During the winter 2020-2021 season, due to weather conditions limiting irrigation, storage
requirements for treated effluent exceeded available storage. In an effort to avoid a bypass,
Wallace Loft, owner of The Cottages, arranged for pumping and hauling of excess treated
effluent to the Town of Boone WWTP. Between January 4, 2021, and March 23, a total of
1,068,600 gallons of treated wastewater was pumped and hauled from the WWTP to the Town
of Boone's wastewater treatment facility (the "Town"), with an associated total cost of $155,400
incurred by Wallace Loft. Tables providing daily details of the WWTP operation for December
2020 through February 2021, including inflow and irrigation rates, temperatures, and
precipitation rates, are provided in Appendix B. As shown in the tables, minimum temperatures
throughout December were consistently below freezing, only increasing above 32 °F on
December 12 (37 °F), December 13 (38 °F), and December 22 (33 °F). In addition, snow cover at
the Cottages from a 3" snow event on December 25 lasted for four days. In January it rained 7
out of 10 days, and minimum temperatures were below 32 °F from January 4 through January
26. In addition to freezing temperatures and cumulative precipitation totaling more than 18
inches of rain or snow in January, there was snow cover at The Cottages for 16 out of the 31
days of the month. Inclement weather continued into February, with only two days with
minimum temperatures climbing above the freezing point (February 14 at 35 °F and February 26
at 33 °F). Between February 1 and February 22 there were 13 days of rain or snow, and 8 days
of snow cover at The Cottages.
Estimated present worth for the do-nothing alternative is $7,566,979. This alternative may be
also considered infeasible, due to the high likelihood of unintentional bypass of treated effluent.
5.2 Conjunctive Use: Irrigate + Discharge to Laurel Fork (Preferred Alternative)
Under this approach, The Cottages of Boone WWTP will make application for NPDES conjunctive
use permit with intent to continue irrigation as conditions permit, and discharge excess treated
effluent to Laurel Creek. To explore this alternative, a potential discharge point in the nearby
receiving stream was identified. A review of stream conditions at the proposed discharge
1.1

location was initiated with USGS and NCDEQ. The Speculative Effluent Limits produced by
NCDEQ suggest that a discharge of up to 0.1 MGD (the approximate permitted capacity of the
WWTP) would be ecologically sound and technically feasible. Please see attached Speculative
Effluent Limits letter dated January 10, 2020. As noted herein, The Cottages is only requesting
authorization for the limited discharge of treated wastewater to Laurel Fork when necessary to
prevent overflow and bypass of existing storage, particularly during extended periods of
inclement weather during the winter months. The Cottages estimates daily flows during such
periods to be approximately 0.035 MGD.
Additional preparatory research included performance of a non -report Chronic Toxicity Test,
with passing results. Test results are also attached herewith.
Please see attached map, Figure 2, showing proposed discharge location. The discharge point
may be reached by gravity flow and is approximately 580 lineal feet from the proposed
connection the WWTP. An easement approximately 150 feet in length will be required into an
adjoining parcel. Acquisition cost for this easement is estimated not to exceed $10,000.
A cost estimate for construction the proposed discharge line is shown below:
COST ESTIMATE
COTTAGES OF BOONE - DISCHARGE LINE
30-Jun-21
DESCRIPTION CITY UNIT UNIT PRICE TOTAL
1
Mobilization
1
LS
$5,000.00
$5,000.00
2
Clearing
0.07
AC
$5,000.00
$350.00
3
Connectto Existing Plant
1
LS
$5,000.00
$5,000.00
4
6-Inch Gate Valves
2
EA
$750.00
$1,500.00
5
New Manholes
3
EA
$5,000.00
$15,000.00
6
6" SDR 21 PVC Gravity Sewer
580
LF
$60.00
$34,800.00
7
Silt Fence
600
LF
$3.00
$1,800.00
8
Eronet S75 Erosion Control Blanket
200
LF
$3.00
$600.00
9
Outfall Screen Device
1
EA
$1,200.00
$1,200.00
10
Trench Rock
5
CY
$100.00
$500.00
11
Seeding
0.07
AC
$4,000.00
$280.00
12
Gravel Road Repair
1440
SF
$5.00
$7,200.00
13
$0.00
CONSTRUCTION SUBTOTAL
$73,230.00
Contingency(10•�)
$7,323.00
CONSTRUCTION TOTAL
$80,553.00
Engineering Services
$12,000.00
TOTAL PROJECT ESTIMATE $92,553.00
This alternative has an estimated initial cost of $102,533 including easement acquisition and
construction of the discharge. The are no additional annual costs over the normal annual
operating costs associated with this alternative. This is a feasible alternative with a total present
worth calculated at $5,091,065.
7

15�
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4
Al,
APPROXIMATE
PROPOSED DISCHARGE LOCATION
X
LAUREL FORK
LATTITUDE 36-19913
LONGITUDE —81.70090
E: 1203148.07D
N; 902231.,871
PROPOSED 20 FOOT WIDE UTILITY EASEMENT
1-r! FT LENGTH
3,00E} SQUARE FEET TOTAL
W.+o, -WE� L
PEM Y E
07A!ES OF B(; E '-T
TT -0 PERMIT
IT 1._ V. EORMIT Pl�
0-
Odom
Kngineering at
COTTAGES OF BOONE WWTP
1W('E 13, 2021)
IjLLC
169 02k Street, F"cor Cky, N.C. IM3
ph: BZB.247A4" lax: RM247.4490
NC Firruo! MW
PROPOSED NPDES
DISCHARGE LOCATION
FIGURE 2 - PROPOSED DISCHARGE LOCATION
M-1

5.3 Connection to Municipal System
The Cottages is located outside of the city limits of the City of Boone and at an altitude above
3,400 feet above mean sea level. Based on conversations with the Town Manager and the Public
Works Director for the Town of Boone, and in review of the Town's ordinances, it would be very
difficult to obtain approval for a sewer connection. Among other reasons, the Town's ordinance
would require annexation & zoning, and connection to the Town's water (which is also not
permitted for areas above MSL 3,400' which were not in town limits prior to March 8, 2007.)
Water connection also requires metering of individual housing units and installation of booster
pumps, water storage and telemetry. In addition, the ordinance requires a system development
fee of $7.99per gallon which, for the 108,000 GPD WWTP, would require an initial upfront
payment of $862,920 before implementing the change. For the purpose of this alternative
analysis, we assume that a variance could be obtained allowing connection for delivery of the
untreated wastewater flow, using a pump station, force main and a single meter for flow
measurement.
We would estimate capital costs for this approach at $80,000 for the pump station, $250,000 for
5,000 LF of force main with one highway bore, $40,000 in easement acquisition, for a total
$370,000 construction cost. Additionally, we estimate that the system development fee would
be $867,380 for the 108,530 GPD design flow. Estimated annual cost from the Town of Boone at
the out-of-town treatment rate would be $237,814 for an assumed 50,000 GPD average flow.
Connection to the municipal system, if allowed, would remove the need for onsite wastewater
treatment, and require only maintenance of a small pump station, at an estimated savings of
approximately $750,000 annually.
The total estimated present worth for this alternative, if a variance allowing the connection
were to be approved by the Town of Boone is estimated to be $5,729,023.
In addition to cost, a connection to the Town is not considered practically feasible at this time
due to annexation requirements and political resistance to annexation which is outside of the
control of The Cottages. Even if politically available, annexation of The Cottages would likely
take at least a year to effectuate. For these reasons, connecting to the municipal system is not a
feasible alternative at this time.
5.4 Increase Wet -Weather Storage Capacity
The fourth alternative evaluated the cost and feasibility of increasing the existing wet weather
storage capacity of the WWTP by adding a 2,000,000-gallon capacity, bolted steel storage tank
(86' diameter by 24' height). Due to the mountainous terrain at The Cottages, installing the
additional storage tank would require blasting to remove rock and grading, and the installation
Oj

of a retaining wall around the tank. Overall, the construction cost for the new tank is estimated
to total more than $1.9 million (or up to $2.2 million with a 25% construction and engineering
contingency). Details of siting and construction of this proposed tank are provided in Appendix
D. It is uncertain whether a 2,000,000-gallon capacity tank would provide adequate storage for a
non -discharge WWTP given the extended periods of precipitation and frozen temperatures
experienced at The Cottages during recent winters.
Initial capital cost for this approach is estimated at $2,200,000, assuming that the tank can be
installed without additional land acquisition. Annual and intermittent costs for this alternative
include pump and valve operation and maintenance, and paint touch-up at 15-year intervals,
approximately $1,500 annually.
The total present worth calculated for this alternative, assuming construction with no additional
land acquisition is calculated at $7,211,916, with no certainty that the additional storage would
be adequate.
5.5 Reduce Generated Flow
Reduction of generated wastewater flow is achieved through reduction of water use. The
Cottages of Boone has contracted a specialist to design a water conservation program with a
stated goal of 40% reduction of water use. Although this program is presented as an alternative
to NPDES discharge, the Cottages intends to initiate a water conservation program even if the
anticipated wastewater reduction is not sufficient to eliminate the need for a discharge permit.
Specifics of the proposed reduction program as recommended by the specialist follow:
"We intend on replacing the shower heads and replacing the toilets as well as reducing
the flow of the faucets. Currently the toilets are 1.6 GPF units. The replacements will be
0.8 GPF units. The kitchen sinks are 2.2 GPM faucets. We intend on adding flow
restrictors that will reduce the flow to 1.0 GPM. Similarly, the bathroom faucets are
currently 1.5 GPM. They will have restrictors installed reducing the flow to 0.5 GPM.
Lastly the current 2.5 GPM shower heads will be replaced with 1.25 GPM heads. The
vendor feels that we should see at least a 40% reduction in water use (and subsequent
wastewater.) ... Additionally, we are requesting to install water sub -meters throughout
the property. These meters can then be used to identify apartment that are wasting
water to help with the conservation efforts.
Capital cost for the proposed reduction program is estimated to be $426,756.
An analysis of anticipated winter storage capacity, using the 2020-2021 Winter historical
records, adjusted for a 40% inflow reduction is provided in Appendix B. This estimate suggests
that with the reduced flow, in weather conditions similar to the historic data, overage would still
be experienced, but that the cumulative winter overage, and associated pump and haul costs
would be reduced by approximately 63%. Estimated annual pump and haul would be $41,958
with a $2,700 reserve for potential bypass fines.
10

The total present worth calculated for this alternative is $6,111,469. Note that this alternative
would not be expected to eliminate the storage deficiency and need for discharge or continued
pumping and hauling.
5.6 Cover Tanks to Reduce Precipitation Inflow
Open top diameters for the currently installed storage tanks are approximately 100 feet for the
14-day tank and 60 feet for the 5-day upset tank. Each tank is approximately 26 feet in height.
Covers for tanks of this height are normally constructed during initial tank construction,
assembled at low elevation and jacked up as side tank sections are added. It would be extremely
difficult and expensive to add covers to these existing tanks due to lack of a sufficiently sized
adjacent flat assembly and craning area and difficulty meeting OSHA requirements for work at
26' height. Estimated cost for the covers, if technically possible to construct would be $250,000
for the large tank, and $100,000 for the 5-day upset tank.
Regardless of cover expense, estimated annual precipitation inflow (60" to 65" in Boone) to the
tanks would not be expected to greatly exceed estimated annual evaporation from the open
tanks (40" to 45"). The precipitation inflow with evaporation is insignificant, and the
construction of covers is not feasible. Present worth for this alternative is $5,338,532, with no
expected significant improvement on storage capacity.
5.7 Increase Irrigation Area or Irrigation Rate
Wallace Loft and The Cottages have engaged the services of a soil survey specialist to investigate
and review the site and soils. The intent of this study is to identify any potentially useful
additional areas for irrigation or reclaimed water reuse, and to determine whether application
rates in existing fields can be increased. Although this study has been contracted, it has not been
completed and data is not yet available for inclusion in this application. We have elected to
submit this application and intend to provide the soil study results as a later addendum as time
is of the essence in selecting, permitting, and constructing a feasible solution for the capacity
problem prior to the next winter season.
Identification of additional application areas, or irrigation rate improvements would be expected
to provide for increased available storage at the beginning of the winter season but based on
the weather records from the 2020-2021 Winter season, in similar weather conditions, and
adjusted for 40% water conservation, overages would still expected due to the number of
consecutive days when irrigation could not be used due to temperature or precipitation.
Although it is expected that a discharge or pump and haul would still be necessary, any
improvement in application rate would be helpful in reducing the overage volume, and The
Cottages may implement additional irrigation fields or irrigation rates if supported by the
pending soils report.
11

6. Alternatives Summary
A table summarizing the results of the individual alternatives analyses is presented below, Figure 3. Of
the options considered technically feasible, only the preferred option, conjunctive use, provides a
guaranteed solution to the system storage capacity issues, even with the implementation of the water
efficiency measures.
The do-nothing alternative does not solve capacity issues and has a high estimated present worth cost,
this is not an acceptable alternative.
Connection to municipal system, if feasible, would solve capacity issues with lowest present worth
lifetime cost, but as discussed previously, is not considered politically feasible at this time.
Increasing onsite storage by (2 million gallons) is not technically feasible due to high initial cost and
provides no guaranteed solution to capacity issues. It is estimated that this would not have provided
sufficient additional storage for the 2020-2021 Winter weather and inflow conditions.
A program intended to result in a 40% reduction of water use and generated wastewater is technically
feasible and will be implemented in 3Q21, however this reduction is not expected to be sufficient to
solve capacity issues.
Covering tanks to eliminate precipitation inputs is not technically feasible nor would it significantly
impact system capacity. In other words, precipitation into the tanks has a minimal impact on storage.
As noted, we are awaiting results of a site soil survey, to determine if irrigation areas and/or irrigation
rates can be increased. Due to siting and topography, it is unlikely that significant additional application
areas will be identified, but if it is determined that application rates can be increased, this could be
helpful in ensuring lower tank levels at the beginning of the severe weather season. Lower initial tank
levels could reduce but would not be expected to eliminate system storage issues during extended
periods when irrigation cannot take place.
Alternative
Alternative Specific
Capital Cost ($)
Recurring
Costs ($)
Present Worth of
Alternative ($)*
Technically
Feasible
Solves
Capacity Issues
Alternative
Specific Annual
Costs
Alternative
Specific
Intermittant
Costs
Annual
Collection and
Treatment
System
Operation
1
Do Nothing
-
155,400
10,000
320,000
7,566,979
Yes
No
2
Conjunctive Use (Irrigate+Discharge)
102,533
-
320,000
5,091,065
Yes
Yes
3
Connectto Municipal System
1,237,380
238,126
50,000
5,729,023
No
Yes
4
Increase On -Site Storage
2,200,000
1,500
320,000
7,211,916
No
No Guarantee
5
Reduce Generated Wastewater
426,756
41,958
2,700
320,000
6,111,469
Yes
No
6
Cover Tanks to Eliminate Precip Inputs
3S0,000
320,000
5,338,532
No
No
7
Increase Irrigation Areas/Rates *
-
waiting Info
No Guarantee
FIGURE 3 — Summary of Alternatives Analysis
IN

7. Local Government Review
Local Government Review Forms have been sent to the Town Manager of Boone, NC, and to
the Watauga County Manager. Responses to the form requests have been included in the
attached appendix.
8. Conclusions and Recommendations
The existing WWTP provides more than sufficient irrigation area for the permitted design
capacity of the WWTP, provided weather allows for the land application of treated wastewater.
The limiting factor and root cause of the WWTP overflows has been, and continues to be, the
lack of sufficient storage capacity during periods of frequent or sustained precipitation and/or
freezing weather in the winter months.
Based on USGS 7Q10 flows, and NCDEQ Speculative Discharge Limits, discharge into Laurel Fork
at up to the permitted flow for Cottage of Boone WWTP, 0.10 MGD would be ecologically
sound and meeting Speculative Effluent Limits would be technologically feasible. A recently
performed passing test for Chronic Toxicity is further indication that discharge of this treated
effluent would be ecologically sound.
It is our recommendation that The Cottages of Boone WWTP implement the water efficiency
measures in 3Q21, and also proceed with NPDES application for conjunctive use to allow
continued irrigation of treated effluent, and supplemented by discharge into Laurel Fork, only
when necessary to prevent bypass of existing storage.
We recommend requesting a permitted discharge flow of 0.035 MGD. This recommendation is
based on the highest monthly average daily flow experienced during the past severe weather
period (58,347 GPD, January 2021), with a 40% reduction applied for the proposed water
consumption reduction program. It is estimated that discharges would approach this flow
amount only under the most severe weather conditions.
With proper operation of the WWTP and improved weather, The Cottages does not anticipate
any further shortage of storage capacity until winter weather returns. We recommend that
every effort be made to complete permitting and construction of the proposed discharge
system prior to the return of winter weather.
13

Appendices
Appendix A — The Cottages NOV Response, dated April 8, 2021
Appendix B — Daily Detail and Storage Analysis — Winter 2020-2021
Appendix C — Daily Detail and Storage Analysis with 40% inflow reduction — Winter 2020-2021
Appendix D — Additional Storage Tank Evaluation
Appendix E — Navitas Equity Solutions Efficiency & Emission Report, June 2021
Appendix F — Present Worth Evaluation of Alternatives
NPDES Permit No. WQ0035784, The Cottages of Boone WWTP
Speculative Effluent Limits - Laurel Fork, Watauga River Basin
Chronic Toxicity Test Results — The Cottages of Boone WWTP
Local Government Review Form -Watauga County, NC
Local Government Review Form —Town of Boone
14

Parker Poe
Fern A. Paterson
Partner
t: 704.335.9891
f: 704.335.4456
[e-mail]
April 8, 2021
Via E-mail [lon.snider(cD_ncdenr.gov]
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
NCDEQ — WSRO
450 W. Hanes Mill Rd., Suite 300
Winston-Salem, North Carolina 27105
Atlanta, GA
Charleston, SC
Charlotte, NC
Columbia, SC
Greenville, SC
Raleigh, NC
Spartanburg, SC
Washington, DC
Re: Response to Notice of Violation & Intent to Enforce (NOV-2021-PC-0187)
Wallace Loft, LLC; The Cottages of Boone - Wastewater Irrigation System
Permit No. WQ0035784; Watauga County
Dear Lon:
We appreciate this opportunity to respond to the above -referenced Notice of Violation
("NOV") on behalf of our client, Wallace Loft, LLC ("Wallace Loft"), which owns and operates The
Cottages of Boone ("The Cottages").
As you know, The Cottages holds a permit (Permit No. WQ0035784) to operate a non -
discharge wastewater irrigation system. The Permit authorizes the operation of a 108,530 gallon
per day (GPD) wastewater treatment and irrigation facility (the "WWTP"). The WWTP uses a drip
irrigation system consisting of approximately 14.39 acres of irrigation area with a mixed hardwood
and pine forest cover crop, and serves 894 bedrooms, as well as a pool, fitness center, and The
Cottage's administrative and clubhouse employees. As previously reported to NCDEQ, a bypass
of the WWTP occurred between January 10, 2021 and February 22, 2021. In this letter, we
provide additional information regarding the weather and conditions leading up to and during the
previously reported bypass, on -going storage capacity challenges with the WWTP during the wet
and cold winter months, efforts to obtain a National Pollutant Discharge Elimination System
("NPDES") Conjunctive Use permit allowing the direct discharge to Laurel Fork to resolve storage
capacity issues, and the status of The Cottages continuing efforts to obtain a NPDES Conjunctive
Use permit. We respectfully request NCDEQ's consideration of the circumstances of the bypass,
as well The Cottage's continuing good faith efforts to resolve the WWTP operating challenges
described further herein, and hope that the NOV can be resolved without the need for
enforcement.
PPAB 6221610v2.docx
Parker Poe Adams & Bernstein LLP 620 South Tryon Street Suite 800 Charlotte, NC 28202
t 704.372.9000 f 704.334.4706 www.parkerpoe.com

April 8, 2021
Page 2
Circumstances Surrounding the Incident
Tables providing daily details of the WWTP operation for December 2020 through
February 2021, including inflow and irrigation rates, temperatures, and precipitation rates, are
provided in Attachment A. As shown in the tables, minimum temperatures throughout
December were consistently below freezing, only increasing above 32 OF on December 12 (37
OF), December 13 (38 OF), and December 22 (33 OF). In addition, snow cover at the Cottages
from a 3" snow event on December 25 lasted for four days. In January, and the days leading up
to the beginning of the bypass on January 10, it rained 7 out of 10 days, and minimum
temperatures were below 32 OF from January 4 through January 26. In addition to freezing
temperatures and cumulative precipitation totaling more than 18 inches of rain or snow in January,
there was snow cover at the Cottages for 16 out of the 31 days of the month. Inclement weather
continued into February, with only two days with minimum temperatures climbing above the
freezing point (February 14 at 35 OF and February 26 at 33 OF). Between February 1 and February
22, when the bypass ended, there were 13 days of rain or snow, and 8 days of snow cover at The
Cottages.
In an effort to avoid a bypass, Wallace Loft arranged for pumping and hauling of excess
treated effluent on or around January 4. Between January 4 and March 23, a total of 1,068,600
gallons of wastewater was pumped and hauled from the WWTP to the Town of Boone's
wastewater treatment facility (the "Town"), with an associated total cost of $155,400 incurred by
Wallace Loft. However, worsening weather conditions on January 10 prevented haul trucks from
accessing The Cottages, which is located 3,400' above mean sea level. The bypass of treated
wastewater began on January 10. Photographs of the iced -over roads are provided below:
&-. ft. -
PPAB 622161M.docx

April 8, 2021
Page 3
Pump and haul operations restarted when roads were sufficiently clear on January 18.
The Cottages acquired a mini excavator, placed fresh gravel on the roads, and contracted a
snowplow vendor to attempt to keep access to the wet weather storage tanks open for trucks.
Throughout the event and after, The Cottages pumped and hauled wastewater to the Town to
minimize the total bypass to the extent that it was able. Despite best efforts, The Cottages was
only able to land apply wastewater from the WWTP at the irrigation fields on one day in January
(January 3), and was not able to land apply wastewater again until February 24.
In addition to the challenges presented by inclement weather, The Cottages have
experienced significant increases in water usage and wastewater inflow rates in association with
the Coronavirus pandemic and associated stay-at-home and work -at-home orders. Governor
Roy Cooper issued Executive Order 121 on March 27, 2020, ordering people in the state of North
Carolina to stay at home for thirty days. The Order took effect on March 30, 2020. During the
month of March 2020, before the stay-at-home order took effect, the average daily water usage
at The Cottages was 36,381 gallons/day. By comparison, in February 2021, as residents continue
to abide by subsequent stay-at-home and work -at-home orders, average water usage has
increased to an average of 78,006 gallons/day, with a maximum daily usage of 112,600
gallons/day on February 18, 2021. In short, as residents continue to stay at home, cook at home,
and recreate at home in response to the on -going coronavirus pandemic, The Cottages has
experienced an approximate doubling of water usage. The wastewater system has been able
to meet the increased water usage and wastewater production rates during warmer months
without issue. However, with inclement weather preventing irrigation of treated wastewater and
iced -over access roads preventing the Cottages from pumping and hauling wastewater to the
Town, the WWTP was not able to keep up with the increased wastewater production and avoid
the bypass.
Additional information regarding the storage capacity at the WWTP, and the feasibility of
adding storage capacity, is discussed further below in relation to the efforts to permit a solution to
the WWTP issues during the cold and wet winter months.
Efforts to Obtain a NPDES Coniunctive Use Permit for the WWTP.
The WWTP began operating in 2013. In the first several years of operation, The Cottages
found that properly treating and disposing of effluent during the wet winter months, frequently with
freezing temperatures, presented greater -than -expected challenges. Wallace Loft engaged
Odom Engineering ("Odom") in October 2019 to assist with the challenges experienced at the
WWTP. Odom's analysis confirmed that operational challenges at the WWTP tracked the
weather, with the system running out of storage capacity during high precipitation and freezing
weather periods in and around January through March, as shown in Figure 1 below.
PPAB 622161M.docx

April 8, 2021
Page 4
Figure 1. Comparison of Weather Trends and Remaining WWTP Storage Capacity
Generally, daily inflow to the WWTP varies from 20,000-50,000 GPD. As described further
above, daily averages during the 2020-2021 Coronavirus pandemic have approximately doubled
as residents remain home in accordance with Gov. Cooper's various stay-at-home and work -at-
home orders. Daily irrigation rates vary more widely, from nothing (on days when weather
precludes drip irrigation of wastewater to the irrigation fields), to well above 100,000 GPD.
Importantly, on good weather days, The Cottages can, and frequently does, apply treated effluent
to the irrigation fields at rates at and above 100,000 GPD.
Wet weather storage at WWTP includes a 1,560,000-gallon bolted steel tank that provides
a 14-day capacity for wet weather storage at the maximum design capacity, and a 548,439 million
gallon 5-day upset tank for emergency conditions, which also may be used for additional wet
weather storage. Although The Cottages narrowly managed to avoid exceeding the storage
capacity of the WWTP during the winter months of the first few years of operation, The Cottages
has repeatedly needed to obtain authorizations to haul and dispose of excess effluent to the Town
to prevent system overflow and bypass. Attachment B to this letter provides daily details of
inflow to the WWTP and irrigation rates by field during March 2020, a sample month that saw
significant and frequent precipitation and freezing temperatures. The Table in the attachment
shows that, on good irrigation days, the WWTP is achieving irrigation rates at or above 100,000
GPD. Despite best efforts demonstrated by irrigation flow rates shown in the March 2020
summary, the WWTP did run out of storage capacity in March 2020, and was required to pump
and haul wastewater to Town of Boone's WWTP to avoid a bypass. In 2020, the Cottages
pumped and hauled 569,500 gallons of wastewater to the Town at a cost of $73,500. In 2021,
between January 4 and March 23, The Cottages pumped and hauled a total of 1,068,600 gallons
of wastewater to the Town at a cost of $155,400, and The Cottages would have pumped and
hauled even more wastewater if weather and roads had allowed.
PPAB 622161M.docx

April 8, 2021
Page 5
Odom also evaluated the cost and feasibility of increasing the existing wet weather storage
capacity of the WWTP by adding a 2,000,000-gallon capacity, bolted steel storage tank (86'
diameter by 24' height). Due to the mountainous terrain at The Cottages, installing the additional
storage tank would require blasting to remove rock and grading, as well as the construction of a
retaining wall around the tank. Overall, Odom estimates the construction cost for the new tank
would total more than $1.9 million (or up to $2.2 million with a 25% construction and engineering
contingency). Aerial photographs showing the proposed plans and an estimated cost schedule
prepared by Odom are provided in Attachment C. Further, it is uncertain whether a 2,000,000-
gallon capacity tank would provide adequate storage for a non -discharge WWTP given the
extended periods of precipitation and frozen temperatures experienced at The Cottages during
recent winters.
Connecting The Cottages' WWTP to the Town of Boone's municipal system was also
deemed to be technically infeasible due to, among other things, the prerequisite annexation and
zoning requirements under the Town's existing ordinances.
Odom and Wallace Loft therefore determined to apply to NCDEQ for a NPDES
Conjunctive Use permit that would allow The Cottages to directly discharge treated wastewater
to Laurel Fork, a small stream on property adjacent to the existing WWTP. Note that the purpose
of the permit was only to allow the Cottages to directly discharge to Laurel Fork during periods of
inclement weather when land application of treated wastewater through the drip irrigation system
is not available and wet weather storage capacity is exhausted. In pursuit of the NPDES
Conjunctive Use permit, Wallace Loft applied for and was issued approved speculative effluent
limits for a 0.1 MGD NPDES Conjunctive Use permit on January 10, 2020. Odom also applied
for and received a zoning consistency determination for the requested NPDES Conjunctive Use
permit from Watauga County on April 27, 2020. The Cottages submitted its application for the
NPDES Conjunctive Use permit, including an Engineering Alternatives Analysis ("EAX) prepared
by Odom, on May 20, 2020.
In the fall and winter of 2020, NCDEQ raised questions and requested additional
information regarding the EAA, and ultimately returned the application for a NPDES Conjunctive
Use permit to Wallace Loft in a letter dated January 19, 2021. In follow-up correspondence from
Nathaniel Thornburg, Branch Chief of NCDEQ's Non -Discharge Branch, NCDEQ indicated that
the following specific analyses should be conducted to further evaluate to potential non -discharge
option prior to submitting a revised application for the NPDES Conjunctive Use permit: (1)
reducing the amount of generated inflow to the WWTP; (2) increasing storage capacity of the
WWTP; (3) increasing the irrigation area of the WWTP; and (4) increasing the loading rate to the
existing irrigation areas. Odom and The Cottages are gathering information to provide responses
to these four items. In particular, a soil scientist has been engaged to evaluate the existing
irrigation fields and whether there is any potential to increase land application rates at the existing
irrigation fields or expand the irrigation areas. The soil scientist's report and findings should be
complete by mid -May.
Importantly, Odom and The Cottages believe that the existing WWTP provides more than
sufficient irrigation area for the permitted design capacity of the WWTP, provided weather allows
for the land application of treated wastewater. The limiting factor and root cause of the WWTP
overflows has been, and continues to be, the lack of sufficient storage capacity during periods of
frequent or sustained precipitation and/or freezing weather in the winter months. As discussed
above, the estimated cost to install an additional 2,000,000-gallon capacity storage tank is
between $2 million and $2.2 million.
PPAB 622161M.docx

April 8, 2021
Page 6
Further, Odom and The Cottages continue to believe that permitting the direct discharge
of treated wastewater to Laurel Creek during the limited periods of inclement weather when the
WWTP's wet weather storage capacity is exceeded is the appropriate path forward. Indeed, had
The Cottage's efforts to obtain the NPDES Conjunctive Use permit in 2020 been successful, the
WWTP would have been authorized to lawfully discharge wastewater in accordance with the
standards and requirements established in the permit, and avoid the bypass that is the subject of
this NOV. Pending the results of the soil scientist's report and further analysis on available
storage capacity options, Odom and The Cottages anticipate submitting the updated information
and analyses to NCDEQ. Odom and The Cottages are hoping to submit an updated and revised
application for a NPDES Conjunctive Use permit that addresses NCDEQ's questions in concerns
in or around June 2021. Further Odom and The Cottages are committed to working with NCDEQ
to obtain a NPDES Conjunctive Use permit to allow for the lawful discharge of wastewater during
periods when the WWTP's wet weather storage capacity is exceeded as a result of inclement
weather.
With proper operation of the WWTP and the improved weather, The Cottages does not
anticipate any further shortage of storage capacity until winter weather returns. In the meantime,
the Cottages and Odom will make every effort resolve the issue, whether through permitting or
other alternatives identified through further analysis. We genuinely appreciate your consideration
of the information provided in this letter, and we look forward to working with you. If you have any
questions regarding this letter, please do not hesitate to contact me at
fern paterson(a)parkerpoe.com or [phone] or David Odom at
davidodom(a)odomengineering.com or [phone].
Sincerely,
r
Fern A. Paterson
Attachment
cc: Patrick Mitchell, NCDEQ (Patrick.mitchell(a-)-ncdenr.gov)
Sean Devine(sean.devine(@cardinalgroup.com)
Justin Pellegrino (iustin.pellegrino _cardinalgroup.com)
Rose Hernandez (rose.hernandez(a�thecottagesofboone.com)
Wayne Farquharson(wayne.farguharson(@mapletree.com.sg)
David Odom(davidodom(a�odomengineering.com)
PPAB 622161M.docx

Cottages of Boone
Daily Detail - December 2020
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26')
5-day (26')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
41
5
6
Total
1,562,000 Gal
548,000 Gal
2020
12
1
T
46
23
0.04
0.10
T
61,273
6.0
22.0
2020
12
2
W
24
20
0.10
1.00
1.0
62,307
6.0
22.0
2020
12
3
Th
42
15
0.00
0.00
1.0
56,608
6.0
22.0
2020
12
4
F
56
15
0.00
0.00
0.0
25,103
6.0
22.0
2020
12
5
Sa
49
32
1.20
0.00
0.0
64,997
2020
12
6
Su
35
30
0.00
0.00
0.0
64,997
8,000
8,000
8,000
8,000
-
32,000
2020
12
7
M
49
32
T
T
T
64,997
-
-
-
-
8,000
950
8,950
6.0
22.0
2020
12
8
T
37
21
T
T
0.0
61,738
6.0
22.0
2020
12
9
W
31
24
0.00
0.00
0.0
60,215
6.0
22.0
2020
12
10
Th
44
27
0.00
0.00
0.0
56,789
6.0
22.0
2020
12
11
F
59
26
0.00
0.00
0.0
24,735
16,000
15,518
8,242
9,162
15,214
12,532
76,668
6.0
22.0
2020
12
12
Sa
57
25
0.01
0.001
0.0
58,429
17,469
26,620
25,883
28,000
27,150
27,626
152,748
2020
12
13
Su
56
37
0.64
0.00
0.0
58,429
17,469
26,620
25,883
28,000
27,150
27,626
152,748
2020
12
14
M
60
38
0.07
0.00
0.0
58,429
-
-
-
-
-
6.0
22.0
2020
12
15
T
44
22
0.18
0.00
0.0
58,657
6.0
22.0
2020
12
16
W
39
21
1.05
0.00
T
57,072
2020
12
17
Th
36
26
T
T
0.0
57,078
6.0
22.0
2020
12
18
F
35
23
0.00
0.00
0.0
56,959
6.0
22.0
2020
12
19
Sa
35
17
0.00
0.00
0.0
49,454
2020
12
20
Su
38
16
0.05
0.00
0.0
49,454
2020
12
21
M
50
30
0.00
0.00
0.0
49,454
8,000
8,000
8,000
9,870
8,236
8,000
50,106
6.0
22.0
2020
12
22
T
48
33
0.00
0.00
0.0
45,277
-
-
6.0
22.0
2020
12
23
W
43
21
0.04
0.00
0.0
46,218
-
-
-
-
6.0
22.0
2020
12
24
Th
45
22
2.04
0.00
0.0
36,580
2020
12
25
F
48
12
0.03
2.50
3.01
36,580
2020
12
26
Sa
14
8
0.00
T
3.0
36,580
2020
12
27
Su
33
8
0.00
0.00
3.0
36,580
2020
121
281
M
1 43
15
0.00
0.00
1.0
36,580
6.0
22.0
2020
12
29
T
41
25
0.00
0.00
0.0
33,907
6.0
22.0
2020
121
30
W
51
24
0.00
0.00
0.0
54,225
6.0
22.0
2020
12
31
TH
51
24
0.00
0.00
0.0
60,889
6.0
22.0
Month Ttl. 1,580,590 66,938 84,758 76,008 83,032 85,750 76,734 473,220
Avg. Daily 50,987 15,265

Cottages of Boone
Daily Detail - January 2021
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26)
5-day (26)
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
41
5
6
Total
1,562,OOOGal
548,000Gal
2021
1
1
F
60
39
0.06
0.00
0.0
57,872
2021
1
2
Sa
48
34
0.84
0.00
0.0
57,872
2021
1
3
Su
59
39
0.00
0.00
0.0
57,872
5,338
8,000
7,972
3,669
9,234
8,000
42,213
2021
1
4
M
42
30
T
T
T
57,872
-
-
-
-
-
-
-
1.5
4.5
2021
1
5
T
42
30
T
0.00
0.0
57,682
-
-
-
-
-
-
-
1.5
4.5
2021
1
6
W
38
26
0.04
0.00
0.0
57,131
-
-
-
-
-
-
-
1.3
4.5
2021
1
7
Th
34
23
0.00
0.00
0.0
35,815
-
-
-
-
-
-
-
0.7
4.5
2021
1
8
F
37
21
0.25
4.00
4.0
55,838
-
-
-
-
-
-
-
2021
1
9
Sa
33
25
0.15
2.00
6.0
55,838
2021
1
10
Su
29
12
0.00
0.00
5.0
55,838
2021
1
11
M
41
11
0.00
0.00
4.0
52,196
-
-
-
-
-
-
-
0.0
0.2
2021
1
12
T
34
24
0.12
1.00
4.0
50,617
-
-
-
-
-
-
-
0.0
0.2
2021
1
13
W
37
17
0.00
0.00
3.0
55,212
-
-
-
-
-
-
-
0.0
0.2
2021
1
14
Th
51
16
0.00
0.00
2.0
48,622
0.0
0.2
2021
1
15
F
51
22
0.00
0.00
1.0
67,673
0.0
0.2
2021
1
16
Sa
38
23
T
T
T
67,673
2021
1
17
Su
30
25
0.02
1.00
1.0
67,673
-
-
-
-
-
-
-
2021
1
18
M
36
26
0.12
2.50
3.0
67,673
-
-
-
-
-
-
-
0.0
0.2
2021
1
19
T
31
26
T
0.00
T
52,839
0.0
0.2
2021
1
20
W
42
26
0.00
0.00
T
64,205
0.0
0.2
2021
1
21
Th
39
26
T
1.00
0.0
25,979
0.0
0.2
2021
1
22
F
37
32
T
0.00
0.0
67,469
0.0
0.2
2021
1
23
Sa
44
26
0.00
0.00
0.0
66,843
2021
1
24
Su
39
18
0.00
0.00
0.0
66,843
2021
1
25
M
44
23
T
Tj
0.0
66,843
-
-
-
-
-
-
-
0.0
0.2
2021
1
26
T
49
38
0.55
0.55
0.0
66,674
0.0
0.2
2021
1
27
W
60
37
0.00
0.00
0.0
65,828
-
-
-
-
-
-
-
0.0
0.2
2021
11
28
Th
56
23
0.18
0.18
T
36,351
-
-
-
-
-
-
-
0.0
0.2
2021
1
29
F
27
14
T
T
T
63,851
-
-
-
-
-
-
-
0.0
0.2
2021
11
30
Sa
31
14
0.00
0.00
0.0
69,026
2021
11
31
Su
36
14
0.40
4.00
169,026
Month Ttl. 1,808,746 5,338 8,000 7,972 3,669 9,234 8,000 42,213
Avg. Daily 58,347 1,362

Cottages of Boone
Daily Detail - February 2021
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26')
5-day (26')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
41
5
6
Total
1,562,000 Gal
548,000 Gal
2021
2
1
M
37
19
0.18
0.00
2.0
69,026
0.0
0.2
2021
2
2
T
32
17
0.05
1.00
1.0
71,422
0.0
0.2
2021
2
3
W
23
17
T
T
T
71,422
0.0
0.2
2021
2
4
Th
30
17
0.00
0.00
0.0
74,325
0.0
0.2
2021
2
5
F
44
17
0.03
0.00
0.0
53,012
0.0
0.2
2021
2
6
Sa
44
28
0.00
0.00
0.0
65,828
2021
2
7
Su
41
16
0.23
2.50
3.0
65,828
2021
2
8
M
37
15
0.00
0.00
1.0
65,828
0.0
0.2
2021
2
9
T
43
30
0.00
0.00
1.0
69,042
0.0
0.2
2021
2
10
W
49
29
0.00
0.00
0.0
20,069
0.0
0.2
2021
2
11
Th
51
28
0.00
0.00
0.0
72,336
0.0
0.2
2021
2
12
F
49
27
0.25
0.00
0.0
68,322
0.0
0.2
2021
2
13
Sa
32
32
0.69
0.00
T
67,048
2021
2
14
Su
1 39
35
0.45
0.00
0.0
67,048
2021
2
15
M
42
22
0.18
0.00
0.0
67,048
0.0
0.2
2021
2
16
T
37
31
0.45
0.00
0.0
67,589
0.0
0.2
2021
2
17
W
36
17
T
0.00
0.0
32,212
0.0
0.2
2021
2
18
Th
36
18
0.26
0.00
T
94,634
0.0
0.2
2021
2
19
F
36
31
0.64
0.00
0.0
45,246
0.0
0.2
2021
2
20
Sa
36
17
0.00
0.00
0.0
65,947
2021
2
21
Su
32
15
0.00
0.00
0.0
65,947
2021
2
22
M
39
15
0.00
0.00
T
65,947
0.0
0.2
2021
2
23
T
46
32
0.29
0.00
0.0
65,193
0.0
0.2
2021
2
24
W
53
31
0.00
0.00
0.0
32,520
14,856
16,000
16,000
16,000
16,000
10,542
89,398
0.2
0.2
2021
2
25
Th
64
29
0.00
0.00
0.0
71,007
23,616
24,000
18,196
16,000
16,000
21,436
119,248
1.1
0.2
2021
2
26
F
5
33
0.00
0.00
0.0
63,263
16,000
8,470
13,726
16,000
16,000
16,000
86,196
1.5
0.2
20211
021
2
27
Sa
41
31
0.841
0.001
0.0
67,118
20,000
20,000
20,000
20,000
24,000
18,000
122,000
20211
21
28
Su
601
311
1 0.001
0.001
0.0
67,118
20,000
20,046
20,046
21,216
24,000
18,372
123,680
Month Ttl. 1,771,345 94,472 88,516 87,968 89,216 96,000 84,350 540,522
Avg. Daily 63,262 17,436

Cottages of Boone
Daily Detail - March 2020
Date
Weather Observations
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (26')
5-day (26')
Year
Month
Day
Max.
Min.
(in)
(in)
11
2
3
4
5
6
Total
1,562,000 Gal
548,000 Gal
2020
3
1
Su
32
20
0.00
0.00
53,608
-
-
3.0
4.5
2020
3
2
M
54
27
0.00
0.00
40,131
25,000
20,000
10,000
10,000
-
65,000
2.7
4.5
2020
3
3
T
49
31
T
0.00
51,294
20,000
20,000
10,000
10,000
60,000
2.5
4.5
2020
3
4
W
58
39
0.72
0.00
56,591
20,000
20,000
10,000
10,000
60,000
2020
3
S
Th
56
38
0.00
0.00
S6,S91
27,130
20,010
1,162
-
100,000
148,302
4.5
4.5
2020
3
6
F
50
29
T
0.00
53,665
2,754
10,000
10,000
10,000
9,978
42,732
5.0
4.5
2020
3
7
Sa
38
25
0.11
T
21,920
10,000
10,000
10,000
10,000
7,324
47,324
2020
3
8
Su
42
20
0.00
0.00
21,920
9,018
6,396
4,100
4,970
-
24,484
2020
3
9
M
56
19
0.00
0.00
21,920
29,614
27,152
10,000
10,012
25,920
102,698
5.0
4.5
2020
3
10
T
59
24
T
0.00
30,101
30,000
22,162
11,814
10,000
30,000
103,976
6.6
4.S
2020
3
11
W
60
4S
0.18
0.00
50,363
27,912
32,514
10,000
10,000
30,000
110,426
8.0
6.S
2020
3
12
Th
64
3S
0.00
0.00
56,100
17,746
18,604
10,000
15,830
30,000
92,180
9.0
7.5
2020
3
13
F
63
34
0.28
0.00
28,562
-
-
-
-
-
-
10.5
7.5
2020
3
14
Sa
61
46
0.00
0.00
28,531
28,637
30,568
30,000
89,205
2020
3
15
Su
SS
44
T
0.00
28,531
28,637
30,568
30,000
89,205
2020
3
16
M
53
35
0.03
0.00
28,531
-
-
-
-
11.5
7.5
2020
3
17
T
43
35
0.03
0.00
31,786
10,000
6,084
10,000
26,084
11.0
7.5
2020
3
18
W
56
41
0.08
0.00
30,410
-
-
-
-
-
-
11.0
7.5
2020
3
19
Th
55
41
0.03
0.00
31,498
16,014
18,308
1,186
10,000
20,000
65,508
10.5
7.5
2020
3
20
F
68
50
0.04
0.00
31,284
26,175
22,645
9,703
10,000
30,000
98,523
11.0
7.S
2020
3
21
Sa
68
53
0.13
0.00
33,513
26,175
22,645
9,703
-
30,000
88,523
2020
3
22
Su
60
3S
0.00
0.00
33,513
26,175
22,645
9,703
30,000
88,523
2020
3
23
M
47
38
0.23
0.00
33,513
-
-
13.0
7.5
2020
3
24
T
57
38
0.43
0.00
30,809
12.5
7.5
2020
3
25
W
51
42
1.12
0.00
30,065
12.0
7.5
2020
3
26
Th
57
39
0.12
0.00
31,261
-
-
-
-
-
-
11.5
7.5
2020
3
27
F
62
41
0.00
0.00
29,664
13,586
25,016
10,000
18,166
20,000
86,768
12.5
7.5
2020
3
28
Sa
78
41
0.00
0.00
30,243
29,951
18,088
924
10,000
30,000
88,963
2020
3
29
Su
81
49
0.00
0.00
30,243
29,951
18,088
-
-
30,000
78,039
20201
31
301
M
81
48
0.00
0.00
30,243
29,951
18,088
30,000
78,039
14.8
7.5
20201
31
31
T
611
461
1 0.00
0.00
27,351
-
-
10,000
3,754
-
13,754
14.8
7.5
Month Ttl. 1,093,755 484,426 439,581 148,295 152,732
Avg. Daily 35,282
523,222 1,748,256
56,395

rizi
� Odom
Engineering
PLLC
COTTAGES AT BOONE
TWO MILLION GALLON TANK COST ESTIMATE
APRIL 2021
Item Description Quantity Unit Unit Price Cost
1
Grading
15000
CY
$15.00
$225,000.00
2
Rock
100
CY
$100.00
$10,000.00
3
Retaining Wall
8,750
SF
$25.00
$218,750.00
4
Piping
1
LS
$35,000.00
$35,000.00
5
Tank Installation
1
LS
$1,500,000.00
$1,500,000.00
CONSTRUCTION SUBTOTAL
$1,988,750.00
5
Construction Contingencies/Engineering (25%)
$198,875.00
CONSTRUCTION TOTAL
$2,187,625.00
TOTAL PROJECT ESTIMATE
$2,200,000.00

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PARCEL ID: 2900317651000 7
MAY, ELIZABETH WHITE "/'�f/_ i'>/�/jj/j/ %''- - - _ - '� \•'G 1� �4�
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Engineering
PLLC
169 Oak Street, Forest City, N.C. 28043
ph: 828.247.4495 fax: [phone]
NC Firm#: P-0880
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JOB NAME: COTTAGES OF BOONE
LOCATION: BOONE, NC
DESCRIPTION: OVERALL SITE 2MG WASTEWATER TANK
BEST CHOICE for NEW LOCATION
SCALE: 1" = 100' IDRAWN BY: BSR
DATE: 08/29/12 CHECKED BY: DWO
PROJECT MGR: PED
PROJECT NUMBER ISHEET
19162 1 1 OF 20
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VANNOY, JAMES L. VANNOY,
PEGGY SUE
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APPROVED:
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Odom
Engineering
PLLC
169 Oak Street, Forest City, N.C. 28043
ph: 828.247.4495 fax: [phone]
NC Firm#: P-0880
NOT
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JOB NAME: COTTAGES OF BOONE
LOCATION: BOONE, NC
DESCRIPTION: PROPOSED RETAINING WALL for
NEW 2 MG WASTEWATER TANK
SCALE: 1" = 60'
DRAWN BY: BSR
DATE: 08/29/12 1 CHECKED BY: DWO
PROJECT MGR: PIED
PROJECT NUMBER ISHEET
19162 1 2 OF 20
U111W 7.11a

Appendix B - Daily Detail and Storage Analysis -Winter 2020-2021
Cottages of Boone
Daily Detail - December 2020
Overage Projections
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (22')
5-day (22')
Year
Month
Day
Max.
Min.
(in)
(in)
11
2
3
4
5
6
Total
1,562,000 Gal
548,000 Gal
2020
12
1
T
46
23
0.04
0.10
T
61,273
-
-
-
-
-
6.0
22.0
2020
12
2
W
24
20
0.10
1.00
1.0
62,307
-
-
-
-
-
-
-
6.0
22.0
2020
12
3
Th
42
15
0.00
0.00
1.0
56,608
-
-
-
-
-
-
-
6.0
22.0
2020
12
4
F
56
15
0.00
0.00
0.0
25,103
-
-
-
-
-
-
-
6.0
22.0
2020
12
5
Sa
49
32
1.20
0.00
0.0
64,997
-
-
-
-
-
-
-
2020
12
6
Su
35
30
0.00
0.00
0.0
64,997
8,000
8,000
8,000
8,000
-
-
32,000
2020
12
7
M
49
32
T
T
T
64,997
-
-
-
-
8,000
950
8,950
6.0
22.0
2020
12
8
T
37
21
T
T
0.0
61,738
-
-
-
-
-
-
-
6.0
22.0
2020
12
9
W
31
24
0.00
0.00
0.0
60,215
-
-
-
-
-
-
-
6.0
22.0
2020
12
10
Th
44
27
0.00
0.00
0.0
56,789
-
-
-
-
-
-
-
6.0
22.0
2020
12
11
F
59
26
0.00
0.00
0.0
24,735
16,000
15,518
8,242
9,162
15,214
12,532
76,668
6.0
22.0
2020
12
12
Sa
57
25
0.01
0.00
0.0
58,429
17,469
26,620
25,883
28,000
27,150
27,626
152,748
2020
12
13
Su
56
37
0.64
0.00
0.0
58,429
17,469
26,620
25,883
28,000
1 27,150
27,626
152,748
2020
12
14
M
60
38
0.07
0.00
0.0
58,429
-
-
-
-
-
-
-
6.0
22.0
2020
12
15
T
44
22
0.18
0.00
0.0
58,657
-
-
-
-
-
-
-
6.0
22.0
2020
12
16
W
39
21
1.05
0.00
T
57,072
-
-
-
-
-
-
-
2020
12
17
Th
36
26
T
T
0.0
57,078
-
-
-
-
-
-
-
6.0
22.0
2020
12
18
F
35
23
0.00
0.00
0.0
56,959
-
-
-
-
-
-
-
6.0
22.0
2020
12
19
Sa
35
17
0.00
0.00
0.0
49,454
-
-
-
-
-
-
-
2020
12
20
Su
38
16
0.05
0.00
0.0
49,454
-
-
-
-
-
-
-
2020
12
21
M
50
30
0.00
0.00
0.0
49,454
8,000
8,000
8,000
9,870
8,236
8,000
50,106
6.0
22.0
2020
12
22
T
48
33
0.00
0.00
0.0
45,277
-
-
-
-
-
-
-
6.0
22.0
2020
12
23
W
43
21
0.04
0.00
0.0
46,218
-
-
-
-
-
-
-
6.0
22.0
2020
12
24
Th
45
22
2.04
0.00
0.0
36,580
-
-
-
-
-
-
-
2020
12
25
F
48
12
0.03
2.50
3.0
36,580
-
-
-
-
-
-
-
2020
12
26
Sa
14
8
0.00
T
3.0
36,580
-
-
-
-
-
-
-
2020
12
27
Su
33
8
0.00
0.00
3.0
36,580
-
-
-
-
-
-
-
2020
12
28
M
43
15
0.00
0.00
1.0
36,580
-
-
-
-
-
-
-
6.0
22.0
2020
12
29
T
41
251
1 0.00
0.00
0.0
33,907
-
-
-
-
-
-
-
6.0
22.0
2020
12
30
W
51
24
0.00
0.00
0.0
54,225
-
-
-
-
-
-
-
6.0
22.0
2020
121
31
TH
51
24
0.00
0.00
0.01
9
1
-
-
-
-
-
-
6.0
22.0
Month Ttl. 1,580,590 66,938 84,758 76,008 83,032 85,750 76,734 473,220
Avg. Daily 50,987 15,265
Water Use (Gals) 1,987,600
Cumulative Volume Estimated Stored Volume
Inflow Outflow Overflow
Gals (Max.2,110,000¢all orPumo
61,273
-
911,273
- 911,273
62,307
973,580
973,580
56,608
-
1,030,188
- 1,030,188
25,103
-
1,055,291
- 1,055,291
64,997
-
1,120,288
- 1,120,288
64,997
32,000
1,153,285
1,153,285
64,997
8,950
1,209,332
- 1,209,332
61,738
-
1,271,070
- 1,271,070
60,215
-
1,331,285
- 1,331,285
56,789
1,388,074
1,388,074
24,735
76,668
1,336,141
- 1,336,141
58,429
152,748
1,241,822
- 1,241,822
58,429
152,748
1,147,503
- 1,147,503
58,429
-
1,205,932
- 1,205,932
58,657
-
1,264,589
- 1,264,589
57,072
-
1,321,661
- 1,321,661
57,078
-
1,378,739
- 1,378,739
56,959
1,435,698
1,435,698
49,454
-
1,485,152
- 1,485,152
49,454
-
1,534,606
- 1,534,606
49,454
50,106
1,533,954
- 1,533,954
45,277
-
1,579,231
- 1,579,231
46,218
-
1,625,449
- 1,625,449
36,580
-
1,662,029
- 1,662,029
36,580
-
1,698,609
- 1,698,609
36,580
1,735,189
1,735,189
36,580
-
1,771,769
- 1,771,769
36,580
1,808,349
1,808,349
33,907
-
1,842,256
- 1,842,256
54,225
1,896,481
1,896,481
60,889
-
1,957,370
- 1,957,370
Total Month Est Over:
-
Total Cumulative Est Over
-
** Assumed beginning of month stored volume 850,000 Gal

Appendix B - Daily Detail and Storage Analysis -Winter 2020-2021
Cottages of Boone
Daily Detail -January 2021
Overage Projections
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (22')
5-day (22')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
4
5
61
Total
1,562,000Gal
548,000Gal
2021
1
1
F
60
39
0.06
0.00
0.0
57,872
-
-
-
-
-
-
-
2021
1
2
Sa
48
34
0.84
0.00
0.0
57,872
-
-
-
-
-
-
-
2021
1
3
Su
59
39
0.00
0.00
0.0
57,872
5,338
8,000
7,972
3,669
9,234
8,000
42,213
2021
1
4
M
42
30
T
T
T
57,872
-
-
-
-
-
-
-
1.5
4.5
2021
1
5
T
42
30
T
0.00
0.0
57,682
-
-
-
-
-
-
-
1.5
4.5
2021
1
6
W
38
26
0.04
0.00
0.0
57,131
-
-
-
-
-
-
-
1.3
4.5
2021
1
7
Th
34
23
0.00
0.00
0.0
35,815
-
-
-
-
-
-
-
0.7
4.5
2021
1
8
F
37
21
0.25
4.00
4.0
55,838
-
-
-
-
-
-
-
2021
1
9
Sa
33
25
0.15
2.00
6.0
55,838
-
-
-
-
-
-
-
2021
1
10
Su
29
12
0.00
0.00
5.0
55,838
-
-
-
-
-
-
-
2021
1
11
M
41
11
0.00
0.00
4.0
52,196
-
-
-
-
-
-
-
0.0
0.2
2021
1
12
T
34
24
0.12
1.00
4.0
50,617
-
-
-
-
-
-
-
0.0
0.2
2021
1
13
W
37
17
0.00
0.00
3.0
55,212
-
-
-
-
-
-
-
0.0
0.2
2021
1
14
Th
51
16
0.00
0.00
2.0
48,622
-
-
-
-
-
-
-
0.0
0.2
2021
1
15
F
51
22
0.00
0.00
1.0
67,673
-
-
-
-
-
-
-
0.0
0.2
2021
1
16
Sa
38
23
T
T
T
67,673
-
-
-
-
-
-
-
2021
1
17
Su
30
25
0.02
1.00
1.0
67,673
-
-
-
-
-
-
-
2021
1
18
M
36
26
0.12
2.50
3.0
67,673
-
-
-
-
-
-
-
0.0
0.2
2021
1
19
T
31
26
T
0.00
T
52,839
-
-
-
-
-
-
-
0.0
0.2
2021
1
20
W
42
26
0.00
0.00
T
64,205
-
-
-
-
-
-
-
0.0
0.2
2021
1
21
Th
39
26
T
1.00
0.0
25,979
-
-
-
-
-
-
-
0.0
0.2
2021
1
22
F
37
32
T
0.00
0.0
67,469
-
-
-
-
-
-
-
0.0
0.2
2021
1
23
Sa
44
26
0.00
0.00
0.0
66,843
-
-
-
-
-
-
-
2021
1
24
Su
39
18
0.00
0.00
0.0
66,843
-
-
-
-
-
-
-
2021
1
25
M
44
23
T
T
0.0
66,843
-
-
-
-
-
-
-
0.0
0.2
2021
1
26
T
49
38
0.55
0.55
0.0
66,674
-
-
-
-
-
-
-
0.0
0.2
2021
1
27
W
601
371
1 0.00
0.00
0.0
65,828
-
-
-
-
-
-
-
0.0
0.2
2021
1
28
Th
56
23
0.18
0.18
T
36,351
-
-
-
-
-
-
-
0.0
0.2
2021
1
29
F
27
14
T
T
T
63,851
-
-
-
-
-
-
-
0.0
0.2
2021
1
30
Sa
31
14
0.00
0.00
0.0
69,026
-
-
-
-
-
-
-
2021
1
31
Su
36
14J
0.40
4.00
69,026
-
-
-
-
-
-
-
Month Ttl. 1,808,746 5,338 8,000 7,972 3,669 9,234 8,000 42,213
Avg. Daily 58,347 1,362
Water Use (Gals) 2,302,267
Inflow
Gals
Cumulative Volume
Outflow
(Max. 2,110,000 gal)
Estimated
Overflow
or Pump
Stored Volume
1,957,370
57,872
- 2,015,242
-
2,015,242
57,872
- 2,073,114
-
2,073,114
57,872
42,213 2,088,773
-
2,088,773
57,872
- 2,146,645
36,645
2,110,000
57,682
- 2,167,682
57,682
2,110,000
57,131
- 2,167,131
57,131
2,110,000
35,815
- 2,145,815
35,815
2,110,000
55,838
- 2,165,838
55,838
2,110,000
55,838
- 2,165,838
55,838
2,110,000
55,838
- F 2,165,838
55,838
2,110,000
52,196
- 2,162,196
52,196
2,110,000
50,617
- 2,160,617
50,617
2,110,000
55,212
- 2,165,212
55,212
2,110,000
48,622
- 2,158,622
48,622
2,110,000
67,673
- 2,177,673
67,673
2,110,000
67,673
- 2,177,673
67,673
2,110,000
67,673
- 2,177,673
67,673
2,110,000
67,673
- 2,177,673
67,673
2,110,000
52,839
- 2,162,839
52,839
2,110,000
64,205
- 2,174,205
64,205
2,110,000
25,979
- 2,135,979
25,979
2,110,000
67,469
- 2,177,469
67,469
2,110,000
66,843
- 2,176,843
66,843
2,110,000
66,843
- 2,176,843
66,843
2,110,000
66,843
- 2,176,843
66,843
2,110,000
66,674
- 2,176,674
66,674
2,110,000
65,828
- 2,175,828
65,828
2,110,000
36,351
- 2,146,351
36,351
2,110,000
63,851
- 2,173,851
63,851
2,110,000
69,026
- 2,179,026
69,026
2,110,000
69,026
- 2,179,026
69,026
2,110,000
Total Month Est Over: 1,613,903
Total Cumulative Est Over 1,613,903

Appendix B - Daily Detail and Storage Analysis -Winter 2020-2021
Cottages of Boone
Daily Detail - February 2021
Overage Projections
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (22')
5-day (22')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
4
5
61
Total
1,562,000Gal
548,000Gal
2021
2
1
M
37
19
0.18
0.00
2.0
69,026
-
-
-
-
-
-
0.0
0.2
2021
2
2
T
32
17
0.05
1.00
1.0
71,422
-
-
-
-
-
-
0.0
0.2
2021
2
3
W
23
17
T
T
T
71,422
-
-
-
-
-
-
0.0
0.2
2021
2
4
Th
30
17
0.00
0.00
0.0
74,325
-
-
-
-
-
-
0.0
0.2
2021
2
5
F
44
17
0.03
0.00
0.0
53,012
-
-
-
-
-
-
0.0
0.2
2021
2
6
Sa
44
28
0.00
0.00
0.0
65,828
-
-
-
-
-
-
2021
2
7
Su
41
16
0.23
2.50
3.0
65,828
-
-
-
-
-
-
2021
2
8
M
37
15
0.00
0.00
1.0
65,828
-
-
-
-
-
-
0.0
0.2
2021
2
9
T
43
30
0.00
0.00
1.0
69,042
-
-
-
-
-
-
0.0
0.2
2021
2
10
W
49
29
0.00
0.00
0.0
20,069
-
-
-
-
-
-
0.0
0.2
2021
2
11
Th
51
28
0.00
0.00
0.0
72,336
-
-
-
-
-
-
0.0
0.2
2021
2
12
F
49
27
0.25
0.00
0.0
68,322
-
-
-
-
-
-
0.0
0.2
2021
2
13
Sa
32
32
0.69
0.00
T
67,048
-
-
-
-
-
-
2021
2
14
Su
39
35
0.45
0.00
0.0
67,048
-
-
-
-
-
-
2021
2
15
M
42
22
0.18
0.00
0.0
67,048
-
-
-
-
-
-
0.0
0.2
2021
2
16
T
37
31
0.45
0.00
0.0
67,589
-
-
-
-
-
-
0.0
0.2
2021
2
17
W
36
17
T
0.00
0.0
32,212
-
-
-
-
-
-
0.0
0.2
2021
2
18
Th
36
18
0.26
0.00
T
94,634
-
-
-
-
-
-
0.0
0.2
2021
2
19
F
36
31
0.64
0.00
0.0
45,246
-
-
-
-
-
-
0.0
0.2
2021
2
20
Sa
36
17
0.00
0.00
0.0
65,947
-
-
-
-
-
-
2021
2
21
Su
32
15
0.00
0.00
0.0
65,947
-
-
-
-
-
-
2021
2
22
M
39
15
0.00
0.00
T
65,947
-
-
-
-
-
-
0.0
0.2
2021
2
23
T
46
32
0.29
0.00
0.0
65,193
-
-
-
-
-
-
0.0
0.2
2021
2
24
W
53
31
0.00
0.00
0.0
32,520
14,856
16,000
16,000
16,000
16,000
10,542
89,398
0.2
0.2
2021
2
25
Th
64
29
0.00
0.00
0.0
71,007
23,616
24,000
18,196
16,000
16,000
21,436
119,248
1.1
0.2
2021
2
26
F
5
33
0.001
0.001
0.0
63,263
16,000
8,470
13,726
16,000
16,000
16,000
86,196
1.5
0.2
2021
2
27
Sa
41
31
0.84
0.00
0.0
67,118
20,000
20,000
20,000
20,000
24,000
18,000
122,000
2021
2
28
Su
60
31
0.00
0.00
0.0
67,118
20,000
20,046
20,046
21,216
24,000
18,372
123,680
Month Ttl. 1,771,345
Avg. Daily 63,262
Water Use (Gals) 2,184,168
94,472 88,516 87,968 89,216 96,000 84,350 540,522
17,436
Inflow
Gals
Outflow
Cumulative Volume
(Max. 2,110,000 gal)
Estimated
Overflow
or Pump
Stored Volume
2,110,000
69,026
-
2,179,026
69,026
2,110,000
71,422
-
2,181,422
71,422
2,110,000
71,422
-
2,181,422
71,422
2,110,000
74,325
-
2,184,325
74,325
2,110,000
53,012
-
2,163,012
53,012
2,110,000
65,828
-
2,175,828
65,828
2,110,000
65,828
-
2,175,828
65,828
2,110,000
65,828
-
2,175,828
65,828
2,110,000
69,042
-
2,179,042
69,042
2,110,000
20,069
-
2,130,069
20,069
2,110,000
72,336
-
2,182,336
72,336
2,110,000
68,322
-
2,178,322
68,322
2,110,000
67,048
-
2,177,048
67,048
2,110,000
67,048
-
2,177,048
67,048
2,110,000
67,048
-
2,177,048
67,048
2,110,000
67,589
-
2,177,589
67,589
2,110,000
32,212
-
2,142,212
32,212
2,110,000
94,634
-
2,204,634
94,634
2,110,000
45,246
-
2,155,246
45,246
2,110,000
65,947
-
2,175,947
65,947
2,110,000
65,947
-
2,175,947
65,947
2,110,000
65,947
-
2,175,947
65,947
2,110,000
65,193
-
2,175,193
65,193
2,110,000
32,520
89,398
2,053,122
-
2,053,122
71,007
119,248
2,004,881
-
2,004,881
63,263
86,196
1,981,948
-
1,981,948
67,118
122,000
1,927,066
-
1,927,066
67,118
123,680
1,870,504
-
1,870,504
Total Month Est Over: 1,470,319
Total Cumulative Est Over 3,084,222

Appendix c - Daily Detail and Storage Analysis - with 40% Inflow reduction - Winter 2020-2021
Cottages of Boone
Daily Detail - December 2020
Overage Projections with 40% Water Use Reduction
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (22')
5-day (22')
Year
Month
Day
Max.
Min.
(in)
(in)
11
2
3
4
5
6
Total
1,562,000 Gal
548,000 Gal
2020
12
1
T
46
23
0.04
0.10
T
61,273
-
-
-
-
-
6.0
22.0
2020
12
2
W
24
20
0.10
1.00
1.0
62,307
-
-
-
-
-
-
-
6.0
22.0
2020
12
3
Th
42
15
0.00
0.00
1.0
56,608
-
-
-
-
-
-
-
6.0
22.0
2020
12
4
F
56
15
0.00
0.00
0.0
25,103
-
-
-
-
-
-
-
6.0
22.0
2020
12
5
Sa
49
32
1.20
0.00
0.0
64,997
-
-
-
-
-
-
-
2020
12
6
Su
35
30
0.00
0.00
0.0
64,997
8,000
8,000
8,000
8,000
-
-
32,000
2020
12
7
M
49
32
T
T
T
64,997
-
-
-
-
8,000
950
1 8,950
6.0
22.0
2020
12
8
T
37
21
T
T
0.0
61,738
-
-
-
-
-
-
-
6.0
22.0
2020
12
9
W
31
24
0.00
0.00
0.0
60,215
-
-
-
-
-
-
-
6.0
22.0
2020
12
10
Th
44
27
0.00
0.00
0.0
56,789
-
-
-
-
-
-
-
6.0
22.0
2020
12
11
F
59
26
0.00
0.00
0.0
24,735
16,000
15,518
8,242
9,162
15,214
12,532
76,668
6.0
22.0
2020
12
12
Sa
57
25
0.01
0.00
0.0
58,429
17,469
26,620
25,883
28,000
27,150
27,626
152,748
2020
12
13
Su
56
37
0.64
0.00
0.0
58,429
17,469
26,620
25,883
28,000
27,150
27,626
152,748
2020
12
14
M
60
38
0.07
0.00
0.0
58,429
-
-
-
-
-
-
-
6.0
22.0
2020
12
15
T
44
22
0.18
0.00
0.0
58,657
-
-
-
-
-
-
-
6.0
22.0
2020
12
16
W
39
21
1.05
0.00
T
57,072
-
-
-
-
-
-
-
2020
12
17
Th
36
26
T
T
0.0
57,078
-
-
-
-
-
-
-
6.0
22.0
2020
12
18
F
35
23
0.00
0.00
0.0
56,959
-
-
-
-
-
-
-
6.0
22.0
2020
12
19
Sa
35
17
0.00
0.00
0.0
49,454
-
-
-
-
-
-
-
2020
12
20
Su
38
16
0.05
0.00
0.0
49,454
-
-
-
-
-
-
-
2020
12
21
M
50
30
0.00
0.00
0.0
49,454
8,000
8,000
8,000
9,870
8,236
1 8,000
50,106
6.0
22.0
2020
12
22
T
48
33
0.00
0.00
0.0
45,277
-
-
-
-
-
-
-
6.0
22.0
2020
12
23
W
43
21
0.04
0.00
0.0
46,218
-
-
-
-
-
-
-
6.0
22.0
2020
12
24
Th
45
22
2.04
0.00
0.0
36,580
-
-
-
-
-
-
-
2020
12
25
F
48
12
0.03
2.50
3.0
36,580
-
-
-
-
-
-
-
2020
12
26
Sa
14
8
0.00
T
3.0
36,580
-
-
-
-
-
-
-
2020
12
27
Su
33
8
0.00
0.00
3.0
36,580
-
-
-
-
-
-
-
2020
12
28
M
43
15
0.00
0.00
1.0
36,580
-
-
-
-
-
-
-
6.0
22.0
2020
12
29
T
41
25
0.00
0.00
0.0
33,907
-
-
-
-
-
-
-
6.0
22.0
2020
12
30
W
51
24
0.00
0.00
0.0
54,225
-
-
-
-
-
-
-
6.0
22.0
2020
121
31
TH
51
24
0.00
0.00
0.0
60,889
-
-
-
-
-
-
-
6.01
22.0
Month Ttl. 1,580,590 66,938 84,758 76,008 83,032 85,750 76,734 473,220
Avg. Daily 50,987 15,265
Reduced Inflow
(60% of actual) Gals
Outflow
Cumulative Volume
(Max. 2,110,000 gal)
Estimated Stored Volume
Overflow
or Pump
850,000
36,764
-
886,764
- 886,764
37,384
-
924,148
- 924,148
33,965
-
958,113
- 958,113
15,062
-
973,175
- 973,175
38,998
-
1,012,173
- 1,012,173
38,998
32,000
1,019,171
1,019,171
38,998
8,950
1,049,219
- 1,049,219
37,043
-
1,086,262
1,086,262
36,129
-
1,122,391
- 1,122,391
34,073
-
1,156,464
- 1,156,464
14,841
76,668
1,094,637
- 1,094,637
35,057
152,748
976,947
- 976,947
35,057
152,748
859,256
- 859,256
35,057
-
894,314
894,314
35,194
-
929,508
- 929,508
34,243
963,751
963,751
34,247
-
997,998
- 997,998
34,175
-
1,032,173
- 1,032,173
29,672
-
1,061,846
- 1,061,846
29,672
-
1,091,518
- 1,091,518
29,672
50,106
1,071,084
- 1,071,084
27,166
-
1,098,251
- 1,098,251
27,731
-
1,125,981
- 1,125,981
21,948
-
1,147,929
- 1,147,929
21,948
-
1,169,877
- 1,169,877
21,948
-
1,191,825
- 1,191,825
21,948
-
1,213,773
- 1,213,773
21,948
-
1,235,721
- 1,235,721
20,344
-
1,256,066
- 1,256,066
32,535
1,288,601
1,288,601
36,533
-
1,325,134
- 1,325,134
Total Month Est Over: -
Total Cumulative Est Over -
** Assumed beginning of month stored volume 850,000 Gal

Appendix C - Daily Detail and Storage Analysis - with 40% Inflow reduction - Winter 2020-2021
Cottages of Boone
Daily Detail -January 2021
Overage Projections with 40% Water Use Reduction
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (22')
5-day (22')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
4
5
61
Total
1,562,000Gal
548,000Gal
2021
1
1
F
60
39
0.06
0.00
0.0
57,872
-
-
-
-
-
-
-
2021
1
2
Sa
48
34
0.84
0.00
0.0
57,872
-
-
-
-
-
-
-
2021
1
3
Su
59
39
0.00
0.00
0.0
57,872
5,338
8,000
7,972
3,669
9,234
8,000
42,213
2021
1
4
M
42
30
T
T
T
57,872
-
-
-
-
-
-
-
1.5
4.5
2021
1
5
T
42
30
T
0.00
0.0
57,682
-
-
-
-
-
-
-
1.5
4.5
2021
1
6
W
38
26
0.04
0.00
0.0
57,131
-
-
-
-
-
-
-
1.3
4.5
2021
1
7
Th
34
23
0.00
0.00
0.0
35,815
-
-
-
-
-
-
-
0.7
4.5
2021
1
8
F
37
21
0.25
4.00
4.0
55,838
-
-
-
-
-
-
-
2021
1
9
Sa
33
25
0.15
2.00
6.0
55,838
-
-
-
-
-
-
-
2021
1
10
Su
29
12
0.00
0.00
5.0
55,838
-
-
-
-
-
-
-
2021
1
11
M
41
11
0.00
0.00
4.0
52,196
-
-
-
-
-
-
-
0.0
0.2
2021
1
12
T
34
24
0.12
1.00
4.0
50,617
-
-
-
-
-
-
-
0.0
0.2
2021
1
13
W
37
17
0.00
0.00
3.0
55,212
-
-
-
-
-
-
-
0.0
0.2
2021
1
14
Th
51
16
0.00
0.00
2.0
48,622
-
-
-
-
-
-
-
0.0
0.2
2021
1
15
F
51
22
0.00
0.00
1.0
67,673
-
-
-
-
-
-
-
0.0
0.2
2021
1
16
Sa
38
23
T
T
T
67,673
-
-
-
-
-
-
-
2021
1
17
Su
30
25
0.02
1.00
1.0
67,673
-
-
-
-
-
-
-
2021
1
18
M
36
26
0.12
2.50
3.0
67,673
-
-
-
-
-
-
-
0.0
0.2
2021
1
19
T
31
26
T
0.00
T
52,839
-
-
-
-
-
-
-
0.0
0.2
2021
1
20
W
42
26
0.00
0.00
T
64,205
-
-
-
-
-
-
-
0.0
0.2
2021
1
21
Th
39
26
T
1.00
0.0
25,979
-
-
-
-
-
-
-
0.0
0.2
2021
1
22
F
37
32
T
0.00
0.0
67,469
-
-
-
-
-
-
-
0.0
0.2
2021
1
23
Sa
44
26
0.00
0.00
0.0
66,843
-
-
-
-
-
-
-
2021
1
24
Su
39
18
0.00
0.00
0.0
66,843
-
-
-
-
-
-
-
2021
1
25
M
44
23
T
T
0.0
66,843
-
-
-
-
-
-
-
0.0
0.2
2021
1
26
T
49
38
0.55
0.55
0.0
66,674
-
-
-
-
-
-
-
0.0
0.2
2021
1
27
W
601
371
1 0.00
0.00
0.0
65,828
-
-
-
-
-
-
-
0.0
0.2
2021
1
28
Th
56
23
0.18
0.18
T
36,351
-
-
-
-
-
-
-
0.0
0.2
2021
1
29
F
27
14
T
T
T
63,851
-
-
-
-
-
-
-
0.0
0.2
2021
1
30
Sa
31
14
0.00
0.00
0.0
69,026
-
-
-
-
-
-
-
2021
1
31
Su
36
14J
0.40
4.00
69,026
-
-
-
-
-
-
-
Month Ttl. 1,808,746 5,338 8,000 7,972 3,669 9,234 8,000 42,213
Avg. Daily 58,347 1,362
Reduced Inflow
actual) Gals
Cumulative Volumer'Over
Outflow
(Max. 2,110,000 gal)or
stimated
low(60%of
Pump
Stored Volume
1,325,134
34,723
- 1,359,857
-
1,359,857
34,723
- 1,394,580
-
1,394,580
34,723
42,213 1,387,091
-
1,387,091
34,723
- 1,421,814
-
1,421,814
34,609
- 1,456,423
-
1,456,423
34,279
- 1,490,702
-
1,490,702
21,489
- 1,512,191
-
1,512,191
33,503
- 1,545,693
-
1,545,693
33,503
- 1,579,196
-
1,579,196
33,503
- 1,612,699
-
1,612,699
31,318
- 1,644,017
-
1,644,017
30,370
- 1,674,387
-
1,674,387
33,127
- 1,707,514
-
1,707,514
29,173
- 1,736,687
-
1,736,687
40,604
- 1,777,291
-
1,777,291
40,604
- 1,817,895
-
1,817,895
40,604
- 1,858,499
-
1,858,499
40,604
- 1,899,102
-
1,899,102
31,703
- 1,930,806
-
1,930,806
38,523
- 1,969,329
-
1,969,329
15,587
- 1,984,916
-
1,984,916
40,481
- 2,025,398
-
2,025,398
40,106
- 2,065,503
-
2,065,503
40,106
- 2,105,609
-
2,105,609
40,106
- 2,145,715
35,715
2,110,000
40,004
- 2,150,004
40,004
2,110,000
39,497
- 2,149,497
39,497
2,110,000
21,811
- 2,131,811
21,811
2,110,000
38,311
- 2,148,311
38,311
2,110,000
41,416
- 2,151,416
41,416
2,110,000
41,416
- 2,151,416
41,416
2,110,000
Total Month Est Over: 258,169
Total Cumulative Est Over 258,169

Appendix C - Daily Detail and Storage Analysis - with 40% Inflow reduction - Winter 2020-2021
Cottages of Boone
Daily Detail - February 2021
Overage Projections with 40% Water Use Reduction
Date
Weather Observations
Snow/Ice/
Hail on
Ground
Inflow (Gallons)
Irrigation By Field (Gallons)
Tank Freeboard (Ft)
Temp (F)
Rain
Snow
Main (22')
5-day (22')
Year
Month
Day
Max.
Min.
(in)
(in)
1
2
3
4
5
6
Total
1,562,000 Gal
548,000 Gal
2021
2
1
M
37
19
0.18
0.00
2.0
69,026
-
-
-
-
-
-
0.0
0.2
2021
2
2
T
32
17
0.05
1.00
1.0
71,422
-
-
-
-
-
-
0.0
0.2
2021
2
3
W
23
17
T
T
T
71,422
-
-
-
-
-
-
0.0
0.2
2021
2
4
Th
1 30
17
0.00
0.001
0.0
74,325
-
-
-
-
-
-
0.0
0.2
2021
2
5
F
44
17
0.03
0.00
0.0
53,012
-
-
-
-
-
-
0.0
0.2
2021
2
6
Sa
44
28
0.00
0.00
0.0
65,828
-
-
-
-
-
-
2021
2
7
Su
41
16
0.23
2.50
3.0
65,828
-
-
-
-
-
-
2021
2
8
M
37
15
0.00
0.00
1.0
65,828
-
-
-
-
-
-
0.0
0.2
2021
2
9
T
43
30
0.00
0.00
1.0
69,042
-
-
-
-
-
-
0.0
0.2
2021
2
10
W
49
29
0.00
0.00
0.0
20,069
-
-
-
-
-
-
0.0
0.2
2021
2
11
Th
51
28
0.00
0.00
0.0
72,336
-
-
-
-
-
-
0.0
0.2
2021
2
12
F
49
27
0.25
0.00
0.0
68,322
-
-
-
-
-
-
0.0
0.2
2021
2
13
Sa
32
32
0.69
0.00
T
67,048
-
-
-
-
-
-
2021
2
14
Su
39
35
0.45
0.00
0.0
67,048
-
-
-
-
-
-
2021
2
15
M
42
22
0.18
0.00
0.0
67,048
-
-
-
-
-
-
0.0
0.2
2021
2
16
T
37
31
0.45
0.00
0.0
67,589
-
-
-
-
-
-
0.0
0.2
2021
2
17
W
36
17
T
0.00
0.0
32,212
-
-
-
-
-
-
0.0
0.2
2021
2
18
Th
36
18
0.26
0.00
T
94,634
-
-
-
-
-
-
0.0
0.2
2021
2
19
F
36
31
0.64
0.00
0.0
45,246
-
-
-
-
-
-
0.0
0.2
2021
2
20
Sa
36
17
0.00
0.00
0.0
65,947
-
-
-
-
-
-
2021
2
21
Su
32
15
0.00
0.00
0.0
65,947
-
-
-
-
-
-
2021
2
22
M
39
15
0.00
0.00
T
65,947
-
-
-
-
-
-
0.0
0.2
2021
2
23
T
46
32
0.29
0.00
0.0
65,193
-
-
-
-
-
-
0.0
0.2
2021
2
24
W
53
31
0.00
0.00
0.01
32,520
14,856
16,000
16,000
16,000
16,000
10,542
89,398
0.2
0.2
2021
2
25
Th
64
29
0.001
0.00
0.0
71,007
23,616
24,000
18,196
16,000
16,000
21,436
119,248
1.1
0.2
2021
2
26
F
1 5
33
0.001
0.001
0.01
63,263
16,000
8,470
13,726
16,000
16,000
16,000
86,196
1.5
0.2
2021
2
27
Sa
41
31
0.84
0.00
0.0
67,118
20,000
20,000
20,000
20,000
24,000
18,000
122,000
2021
2
28
Su
60
31
0.00
0.00
0.0
67,118
20,000
20,046
20,046
21,216
24,000
18,372
123,680
Month Ttl. 1,771,345 94,472 88,516 87,969 89,216 96,000 84,350 540,522
Avg. Daily 63,262 17,436
Reduced Inflow
(60% of actual) Gals
Outflow
Cumulative Volume
(Max. 2,110,000 gal)
Estimated Stored Volume
Overflow
or Pump
2,110,000
41,416
-
2,151,416
41,416
2,110,000
42,853
-
2,152,853
42,853
2,110,000
42,853
-
2,152,853
42,853
2,110,000
44,595
-
2,154,595
44,595
2,110,000
31,807
-
2,141,807
31,807
2,110,000
39,497
-
2,149,497
39,497
2,110,000
39,497
-
2,149,497
39,497
2,110,000
39,497
-
2,149,497
39,497
2,110,000
41,425
-
2,151,425
41,425
2,110,000
12,041
-
2,122,041
12,041
2,110,000
43,402
-
2,153,402
43,402
2,110,000
40,993
-
2,150,993
40,993
2,110,000
40,229
-
2,150,229
40,229
2,110,000
40,229
-
2,150,229
40,229
2,110,000
40,229
-
2,150,229
40,229
2,110,000
40,553
-
2,150,553
40,553
2,110,000
19,327
-
2,129,327
19,327
2,110,000
56,780
-
2,166,790
56,780
2,110,000
27,148
-
2,137,148
27,148
2,110,000
39,568
2,149,568
39,568
2,110,000
39,568
-
2,149,568
39,568
2,110,000
39,568
2,149,568
39,568
2,110,000
39,116
-
2,149,116
39,116
2,110,000
19,512
89,398
2,040,114
-
2,040,114
42,604
119,248
1,963,470
-
1,963,470
37,958
86,196
1,915,232
-
1,915,232
40,271
122,000
1,833,503
-
1,833,503
40,271
123,680
1,750,094
-
1,750,094
Total Month Est Over: 882,191
Total Cumulative Est Over 1,140,360
3084222
1,943,862
0.63026008

rizi
� Odom
Engineering
PLLC
COTTAGES AT BOONE
TWO MILLION GALLON TANK COST ESTIMATE
APRIL 2021
Item Description Quantity Unit Unit Price Cost
1
Grading
15000
CY
$15.00
$225,000.00
2
Rock
100
CY
$100.00
$10,000.00
3
Retaining Wall
8,750
SF
$25.00
$218,750.00
4
Piping
1
LS
$35,000.00
$35,000.00
5
Tank Installation
1
LS
$1,500,000.00
$1,500,000.00
CONSTRUCTION SUBTOTAL
$1,988,750.00
5
Construction Contingencies/Engineering (25%)
$198,875.00
CONSTRUCTION TOTAL
$2,187,625.00
TOTAL PROJECT ESTIMATE
$2,200,000.00

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DESIGN -NOT RELEASED FOR
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PARCEL ID: 2900317651000 7
MAY, ELIZABETH WHITE "/'�f/_ i'>/�/jj/j/ %''- - - _ - '� \•'G 1� �4�
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Odom
Engineering
PLLC
169 Oak Street, Forest City, N.C. 28043
ph: 828.247.4495 fax: [phone]
NC Firm#: P-0880
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FOR
CONSTRUCTION
JOB NAME: COTTAGES OF BOONE
LOCATION: BOONE, NC
DESCRIPTION: OVERALL SITE 2MG WASTEWATER TANK
BEST CHOICE for NEW LOCATION
SCALE: 1" = 100' IDRAWN BY: BSR
DATE: 08/29/12 CHECKED BY: DWO
PROJECT MGR: PED
PROJECT NUMBER ISHEET
19162 1 1 OF 20
U111W 7.11a

E: 1203148.070
3410 � ��\\ �� L\ ?\ \ 1A \ \ ��11 ��]1
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PARCEL ID: 2900326210000 '
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PROPOSED 20 FOOT WIDE UTILITY EASEMENT
150 FT LENGTH � ,I-i• ' - ,.\ � .� \\�����,
3,000 SQUARE FEET TOTAL ��
PARCEL ID: 2900320149000 ` , � '\ •\ �,,;�.�.\ � �� �,
VANNOY, JAMES L. VANNOY,
PEGGY SUE
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COTTAGES OF BOONE WWTPzz
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• PERMIT No 035784
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MAY, ELIZABETH WHITE /
THIS PLANTS A PRELIMINARY
DESIGN -NOT RELEASED FOR
CONSTRUCTION unEss
INITIALLED/DATED AS APPROVED
APPROVED:
0
Odom
Engineering
PLLC
169 Oak Street, Forest City, N.C. 28043
ph: 828.247.4495 fax: [phone]
NC Firm#: P-0880
NOT
FOR
CONSTRUCTION
JOB NAME: COTTAGES OF BOONE
LOCATION: BOONE, NC
DESCRIPTION: PROPOSED RETAINING WALL for
NEW 2 MG WASTEWATER TANK
SCALE: 1" = 60'
DRAWN BY: BSR
DATE: 08/29/12 1 CHECKED BY: DWO
PROJECT MGR: PIED
PROJECT NUMBER ISHEET
19162 1 2 OF 20
U111W 7.11a

a\�C ity SoY,
z �A�
Empowering Energy Efficiency
EFFICIENCY &EMISSIONS REPORT
Utilities Optimization & Capital Construction Plan
Prepared for Mapletree Investments I Cottages at Boone (Toilet Replacement)
June 2021

aSEquity SONG
Empowering Energy Efficiency
Your facility is likely to consume more than 9.1 million gallons of water during the next 12 months, or a 46% overage. This report provides
recommended efficiency upgrades that if installed will help decrease this overage while creating a quantifiable environmental impact. If
implemented, the Program herein will:
• Meaningfully reduce the blended annual utilities expense at your asset and ensure ongoing expense savings
• Increase the capped value of your facility upon refinance or disposition
• Generate an attractive unlevered ROI on invested capital
EMISSIONS TOTAL
T-12 Consumption (Gallons) 19,809,450
Protected F-12 Consumption (Gallons) 10,681,573
Projected Usage Savings (Yr 1) 9,127,877
%of Historical 46%
CAPITAL REQUIREMENT
Efficiency Program Retrofit Hard/Soft Costs $426,756
Projected Rebates
Net Capital Requirement After Rebates $426,756
2

aSEquity SONG
Empowering Energy Efficiency
Investing for Expense Savings
Below are the recommended efficiency upgrades we've identified alongside projected expense reductions for each:
EMISSIONSEFFICIENCY & AD
The Cottages Boone
ECM Gross Cost
UTILITY CONSUMPTION
SAVINGS (GALLONS) Rebates
Net Cost
ELECTRICAL
WATER/SEWER
High Efficiency Toilets - 0.8 GPF
$295,020
3,466,654 $0
$295,020
High Efficiency Bathroom Sink Aerator - 0.5 GPM
$14,751
2,113,008 $0
$14,751
High Efficiency Showerhead - 1.25 GPM
$24,585
1,683,803 $0
$24,585
High Efficiency Kitchen Sink Aerators - 1.0 GPM
$5,775
864,412 $0
$5,775
In -Unit Water Meters
1 $86,625
1 1,000,000 $0
1 $86,625
!TOTAL: WATER/SEWER
EF6,756
$0
$426,756
TOTAL PROJECT COSTS
$426,756
9,127,877 $0
$426,756

Investing for Environmental Impact I Water
Implementation of an Efficiency Program will help to decrease your ongoing Water consumption in the following ways:
WATER/SEWER USAGE
2,500,000
$2,500,000
2,000,000
$2,000,000
c
0
1,500,000
$1,500,000
1,000,000
$1,000,000
0
500,000
$500,000
Of����������� 11 $0
f i f f f i f f i f f i�
0 0 0 0 0 0 0 0 0 0 -I _4
N N N N N N N N N N N N
a a 5 o z o
�T-12 TOTAL GALLONS F-12 TOTAL GALLONS
T-12 TOTAL $ F-12 TOTAL $
aSEquity SONG
Empowering Energy Efficiency
WATER SAVINGS OF: 9,127,877 Gallons
63.4 13.8
Average Olympic
residential homes OR swimming
for one year 100111�' pools
156.7
Average
residential
lawns
(irrigation)
536,934
O
OR O O O O Average
OO O O personal
OO O 0 showers
Expense
Consumption (Gallons)
Annual Water Savings
Previous 12 Months
$19,809,450
19,809,450
30 Olympic Pools
Next 12 Months
$10,681,573
10,681,573
16.2 Olympic Pools
Decrease of T-12
46%
46%
TOTAL EFFICIENCY
S9.127.877
9.127.877
Savings of 13.8 Olvmoic Pools
An

aC 'quity 8 Y,
Empowering Energy Efficiency
Our Service Lines
SERVICE
DESCRIPTION
Utilities &
We provide initial utilities audits and expert analysis surrounding the feasibility and benefit of upgrading the utilities infrastructure of
Efficiency
commercial real estate facilities you own or manage today. As your Utilities Partner, we also provide the same initial analysis for new
Consulting
acquisitions you may be considering.
Site Audit /
Utilizing degreed and licensed energy managers, professional engineers, and energy consultants, we identify and audit the design,
Efficiency Plan
operation, and maintenance parameters of your Facility to identify efficiency opportunities as well as to create a baseline to benchmark
Design
current utilities consumption. The result of this effort is our Efficiency & Emissions Report alongside a fixed -price utilities upgrade and
project management agreement.
Materials
Sourcing our deep network of trusted suppliers, we procure all of the materials required to achieve the efficiency upgrades outlined in this
Procurement /
report and then act as your project manager overseeing their installation onsite. To do so, we use our vetted list of national, regional, and
Project
local vendors and utilize our experience as former institutional real estate owners/operators to ensure minimal disruption to ongoing
Management
operations and tenant satisfaction.
Rebate &
Upon Project completion, we provide you with all applicable manufacturer warranties on the purchased materials and serve as your Rebate
Warranty
processor, identifying as many available rebates as we can and then tracking their application and award.
Processing
Measurement
Finally, we provide ongoing measurement and verification "M&V" to track the reduced utilities consumption as well as the ongoing utilities
& Verification
Cost Avoidance at the asset level to accurately illustrate progress and to provide full accountability of both the environmental and financial
Services
impact of the efficiency investment. These M&V services provide you with data and sustainability metrics to share with your team and
other outside parties.

aSEquity SONG
Empowering Energy Efficiency
Execution Timeline
The table below illustrates the projected execution timeline beginning upon mutual execution of the contract to Efficiency Program closeout.
PROJECT PHASE
WEEK 1 WEEK 2 WEEK 3 WEEK 4 WEEK 5 WEEK 6 WEEK 7 WEEK 8 WEEK 9 WEEK 10
CONTRACT EXECUTION
Project Awarded / Mutual Contract Execution
PRECONSTRUCTION
Materials Deposit Due (50%of Project Cost)
Kickoff Call
Materials Procurement
Installation Scheduling
EXECUTION
Mobilization & Start -Up
Project Installation
Substanital Project Completion I Quality Control
2nd Deposit Due (40% of Project Cost)
Final Project Completion I Punch
PROJECT CLOSEOUT
Rebate Processing
Warranty Processing
Final Invoicing (10% of Project Cost)
* Timeline above may change to due materials ordering and size of project

Process & Next Steps
1: Site Tour & FINAL Utilities Audit
We've toured your facility and conducted a utilities audit, the findings
included herein. The Efficiency & Emissions Report includes:
• Detailed utilities audit of your facility and step-by-step blueprint
to expense savings
• A fixed -price contract for our auditing & engineering consulting,
materials and labor, we construction management services, rebate
and warranty processing, and Measurement & Verification of
savings upon completion
2: Financing & Installation of Improvements
You fund the infrastructure improvements and we procure the
materials, manages the vendors, and serves as project manager over
the install. If you choose to move forward, we will execute a project
management agreement outlining the terms and conditions of our
utilities consulting, materials procurement, and construction
management services. Project Management Agreement payment
schedule:
PROJECT
$213,378 50% upon contract execution
$170,702 40% upon substantial project completion
$42,676 10% upon full project completion
3: The Contract between Navitas / Owner
Upon project completion, we processes identified rebates and provides
monthly measurement & verification services illustrating the utilities
consumption and cost savings for 12 months.
7
aSEquity SONG
Empowering Energy Efficiency

aC 'quity 8 Y,
Empowering Energy Efficiency
Efficiency Program Technologies
Below is a list of the Efficiency Program upgrades we recommend for your asset.
Water I Water fixtures, in the context of this report, include low -flow fixtures, water line apparatus, and smart irrigation systems.
Technologies I Shower Heads and Aerators
• Niagara High Efficiency Shower Heads are durable, have classic aesthetics, and offer a TamperProof option
• The Bathroom and kitchen aerators
• The 0.5 needle spray bathroom aerator has great pressure to efficiently wash hands
• The 1.5 Dual Spray kitchen has the force to clean dishes
Toilets
• STEALTH fixtures by Niagara can use as little as 0.625 gallons/flush - >50% improvement on the current toilets.
• Vacuum assisted technology that has a MaP premium rating of 800 which is a comparable force to a 1.6 GPF toilet; or a toilet that
uses 2x more water.
• Low flow toilets, the ones that are referred to often, are usually flapper toilets or pressure assisted which creates the following:
1) Pressure Assisted loud and dangerous. Not ideal for residential application because of their supersonic jet -like noise
2) Flapper Toilets are costly, leaky and running. Flapper Toilet Slow gravity fed that lacks force
3) Niagara has a Lifetime Warranty on Ceramic, 10-year on internals with little to no maintenance costs

aC quity8Y,
Empowering Energy Efficiency
Identified Rebate & Manufacturer Warranty Detail
IDENTIFIED REBATES
n/a
MANUFACTURER WARRANTIES
$ AMOUNT
DESCRIPTION & PROJECTED TIMELINE
DESCRIPTION & PROJECTED TIMELINE
High Efficiency Bathroom Sink Aerator - 0.5 GPM 1-year Product Warranty
High Efficiency Showerhead - 1.25 GPM 10-year Product Warranty
High Efficiency Kitchen Sink Aerators - 1 GPM 1-year Product Warranty
Zennergy Flow Management Device 15-year Product Warranty

Appendix F - Present Worth Calculations for Alternative Comparison
MCA Calculation Method.
The following standard formula for computing the present value must be used in all cost estimates made under this
—1-tion:
PV= o+� C`
Where:
PV = Present value of costs.
Co = Costs incurred in the present year.
Ct - Costs incurred in time t.
t - Time period after the present year (The present year is t = 0)
n = Ending year of the life of the facility.
r - Current EPA discount rate. EPA adjusts this rate annually on October 1, and it can be accessed from
the Internet at http:/w .nccgl.net/fap/cwsrf/201gui.huffl.
If recurring costs are the same in years 1 through 20, then Ct-C and the formula reduces to:
�(1+r)"—I]
PV= o+ r(l+r)" J
20
2.5%
Alternative
Alternative Specific
Capital Cost ($)
Recurring Costs ($)
Present Worth of
Alternative ($)*
Alternative
Specific Annual
Costs
Alternative
Specific
Intermittant
Costs
Annual Collection
and Treatment
System
Operation
1
Do Nothing
155,400
10,000
1 320,000
7,566,979
2
Conjunctive Use (Irrigate+Discharge)
102,533
-
320,000
5,091,065
3
Connect to Municipal System
1,237,380
238,126
50,000
5,729,023
4
Increase On -Site Storage
2,200,000
1,500
320,000
7,211,916
5
Reduce Generated Wastewater
426,756
41,958
2,700
320,000
6,111,469
6
Cover Tanks to Eliminate Precip Inputs
1 350,000
320,000
5,338,532
71
Increase Irrigation Areas/Rates *
I
i
i
I
-
* Awating Data from Soils Engineering Consultant
** 20-Yr Facility Life, 2.5% EPA Discount Rate

Water Resources
ENVIRONMENTAL QUALITY
October 25, 2017
SEAN DEVINE
WALLACE LOFT, LLC
2711 CENTERVILLE ROAD, SUITE 400
WmmiNGTON, DELAWARE 19808
Dear Mr. Devine:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Permit No. W00035784
The Cottages of Boone W WTP
Wastewater Irrigation System
Watauga County
In accordance with your permit change of ownership request received July 28, 2017, we are
forwarding herewith Permit No. W00035784 dated October 25, 2017, to Wallace Loft, LLC for the
continued operation of the subject wastewater treatment and irrigation facilities.
Please note that the Permittee has been changed from CCC-Boone, LLC to Wallace Loft, LLC.
This permit shall be effective from the date of issuance until April 30, 2022, shall void Permit No.
W00035784 issued April 12, 2017, and shall be subject to the conditions and limitations as specified
therein. Please pay attention to the monitoring requirements listed in Attachments A, B and C for they may
differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall 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 at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Alice M. Wessner at (919)
807-6425 or alice.wessnerkncdenr.gov.
Sincerely,
S. Jay Zimmerman, P.G., Director
0Division of Water Resources
cc: Watauga County Health Department (Electronic Copy)
-^"Nothing Compares!,,
State of North Carolina I Environmental Quality I Water Resources I Water Quality Permitting I Non -Discharge Permitting
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-807-6332

Mr. Sean Devine
October 25, 2017
Page 2 of 2
Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
Wallace Loft, LLC
Watauga County
FOR THE
continued operation of a 108,530 gallon per day (GPD) wastewater treatment and irrigation facility
consisting of:
a rotary brush screen and a 500 gallon filtrate collection tank served by two 0.5 horsepower (hp) centrifugal
screening transfer pumps; a 54,496 gallon bolted steel equalization basin with a coarse bubble diffuser
system served by a 96 cubic feet per minute (CFM), 40 hp, positive displacement blower and two 4 hp
submersible transfer pumps; dual 12,000 gallon anoxic bioreactor tanks served by two 3 hp centrifugal
recycled activated sludge (RAS) / mix pumps; dual 12,000 gallon aerated bioreactor tanks with a coarse
bubble diffuser system served by a 96 CFM, 40 hp, positive displacement blower; a 12,000 gallon post -
anoxic bioreactor tank; dual ultra -filtration (UF) membrane filter racks served by three 5 hp centrifugal
circulation pumps, two 2 hp centrifugal membrane flush pumps, two 0.5 hp centrifugal membrane permeate
pumps, and two 3 hp centrifugal permeate backwash pumps (all as part of Dynatec Membrane Biological
Reactor treatment system); dual 130 gallon per minute (GPM) Severn Trent ultraviolet (UV) disinfection
systems; a Hach turbidimeter and a 190 GPM effluent flow meter; an automatic -activation propane -fueled
alternate power supply; a 548,000 gallon bolted steel 5-day upset tank; a 36,166 gallon bolted steel aerobic
digestion sludge holding tank with coarse bubble diffuser and 2-inch, 100 GPM sludge flow meter; a 12,059
gallon HDPE irrigation dosing tank served by two 15 hp centrifugal dosing pumps; a 1,562,000 gallon
bolted steel 14-day wet weather storage tank; a precipitation sensor; three 1,763 gallon precast return flush
tanks served by two 48 GPM vertical turbine flush return pumps; approximately 14.39 acres of drip
irrigation area with a mixed hardwood and pine forest cover crop with sufficient disposal capacity in zones
1-6 as detailed in Attachment B; and all associated piping, valves, controls and appurtenances
to serve 894 bedrooms, five administrative/clubhouse employees, a fitness center, and a pool at The
Cottages of Boone, with no discharge of wastes to surface waters, pursuant to the application received July
28, 2017, and in conformity with the project plans, specifications, and other supporting data subsequently
filed and approved by the Department of Environmental Quality and considered a part of this permit.
This permit shall be effective from date of issuance until April 30, 2022, shall void Permit No. WQ0035784
issued April 12, 2017, and shall be subject to the following specified conditions and limitations:
W00035784 Version 2.1 Shell Version 151201 Page 1 of

I.
1. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0I05(d) requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T .0105(d), 02T .0106, 02T .0109, 02T .0115(c)]
H. PERFORMANCE STANDARDS
1. The subject non -discharge facilities shall be effectively maintained and operated at all times so there is
no discharge to surface waters, nor any contravention of groundwater or surface water standards. In
the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due
to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the
effluent, the Permittee shall take immediate corrective actions including Division required actions, such
as the construction of additional or replacement wastewater treatment or irrigation facilities. [G. S. 143-
215.1, 143-213.3(a)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [ 15A NCAC 02B .0200, 02L .0100]
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1), 02T .0505(b)]
5. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0505(c), 02T .0505(n)]
6. The irrigation system shall be connected to a rain or moisture sensor, which shall indicate when effluent
application is not appropriate in accordance with Conditions IIIA. and HI.S. of this permit. [15A NCAC
02T .0108(b)(1)]
7. The compliance and review boundaries are established at the irrigation area boundaries. Any
exceedance of standards at the compliance or review boundary shall require action in accordance with
15A NCAC 02L .0106. [15A NCAC 02L .0106, 02T .0506(c)]
8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary. [15A NCAC 02L .0107(c)]
9. In accordance with 15A NCAC 02L .0107(d), no wells, excluding Division approved monitoring wells,
shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g). [15A NCAC 02L .0107]
W00035784 Version 2.1 Shell Version 151201 Page 2 of 9

10. Except as provided for in 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the
Watauga County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
11. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for irrigation sites permitted under 15A NCAC 02T .0500 shall be as follows (all
distances in feet):
i. Any habitable residence or place of public assembly under separate ownership:
100
ii. Any habitable residence or place of public assembly owned by the Permittee:
15
iii. Any private or public water supply source:
100
iv. Surface waters:
100
v. Groundwater lowering ditches:
100
vi. Surface water diversions:
25
vii. Any well with exception of monitoring wells:
100
viii. Any property line:
01
ix. Top of slope of embankments or cuts of two feet or more in vertical height:
15
x. Any water line from a disposal system:
10
xi. Subsurface groundwater lowering drainage systems:
100
xii. Any swimming pool:
100
xiii. Public right of way:
50
xiv. Nitrification field:
20
xv. Any building foundation or basement:
15
Setbacks to property lines have been reduced to 0 feet because the facility is complying with
15A NCAC 02T .0506(c).
[15A NCAC 02T .0506(a), 02T .0506(c)]
b. The setbacks for storage and treatment units permitted under 15A NCAC 02T .0500 shall be as
follows (all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership:
ii. Any private or public water supply source:
iii. Surface waters:
iv. Any well with exception of monitoring wells:
v. Any property line:
[15A NCAC 02T .0506(b)]
100
100
50
100
50
W00035784 Version 21 Shell Version 151201 Page 3 of 9

M. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater resulting
from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan,
which at a minimum shall include operational functions, maintenance schedules, safety measures and
a spill response plan. [15A NCAC 02T .0507]
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or more
certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules. [15A NCAC 02T .0117]
3. A suitable year round vegetative cover shall be maintained at all times, such that crop health is
optimized, allows for even distribution of effluent and allows inspection of the irrigation system. [15A
NCAC 02T .0108(b)(1)]
4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed
in Attachment B. [15A NCAC 02T .0108(b)(1)]
5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff. [15A NCAC 02T .0108(b)(1)]
6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration records
shall be maintained at the facility for a period of no less than five years, and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
7. Only effluent from The Cottages of Boone W WTP shall be irrigated on the sites listed in Attachment
B. [G.S.143-215.1]
8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment
installation or while maintenance is being performed. [15A NCAC 02T .0108(b)(1)]
9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. [15A NCAC
02T .0505(q)]
10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0508. [ 15A NCAC 02T .0508, 02T .1100]
11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited. [15A NCAC 02T .05050)]
12. Freeboard in the 1,562,000 gallon wet weather storage tank and the 548,000 gallon 5-day upset tank
shall not be less than two feet at anytime. [15A NCAC 02T .0505(d)]
13. Gauges to monitor waste levels in both the 1,562,000 gallon wet weather storage tank and the 548,000
gallon 5-day upset tank shall be provided. These gauges shall have readily visible permanent markings,
at inch or tenth of a foot increments, indicating the following elevations: maximum liquid level at the
top of the temporary liquid storage volume; minimum liquid level at the bottom of the temporary liquid
storage volume; and the lowest point on top of the dam. [15A NCAC 02T .0108(b)(1)]
W00035784 Version 2.1 Shell Version 151201 Page 4 of 9

14. All effluent shall be routed to the five day upset tank should the limit for fecal coliform (e.g., daily
maximum concentration of 25 colonies per 100 mL) or turbidity (e.g., instantaneous maximum of 10
NTU) be exceeded, until the problems associated with the wastewater treatment plant have been
corrected. The wastewater in the five day upset tank shall be pumped back to the treatment plant
headworks for re -treatment or treated in the five day upset tank prior to infiltration. [15A NCAC 02T
.0108(b)(1)]
15. The turbidimeter shall be tested and calibrated at a minimum of once per year. Calibration records
shall be maintained at the facility for a period of no less than five years, and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water analyses)
necessary to ensure groundwater and surface water protection shall be established, and an acceptable
sampling reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device to ensure the accuracy
and reliability of flow measurement consistent with accepted engineering and scientific practices.
Selected flow measurement devices shall be capable of measuring flows with a maximum deviation of
less than ten percent from true flow; accurately calibrated at a minimum of once per year; and
maintained to ensure the accuracy of measurements is consistent with the selected device's accepted
capability. The Permittee shall maintain records of flow measurement device calibration on file for a
period of at least five years. At a minimum, documentation shall include:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
[ 15A NCAC 02T .0105(k)]
4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A. [15A NCAC 02T .0108(c)]
The Permittee shall maintain adequate records tracking the amount of effluent irrigated. At a minimum,
these records shall include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings;
f Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions; and
h. Maintenance of cover crops.
[15A NCAC 02T .0108(c)]
WQ0035784 Version 2.1 Shell Version 151201 Page 5 of 9

6. Freeboard (i.e., waste level to the lowest embankment elevation) in the 1,562,000 gallon wet weather
storage tank and the 548,000 gallon 5-day upset tank shall be measured to the nearest inch or tenth of
a foot, and recorded weekly. Weekly freeboard records shall be maintained at the facility for a period
of no less than five years, and shall be made available to the Division upon request. [15A NCAC 02T
.0108(c)]
Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.) on Form NDAR-i for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month, monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(1)]
8. A record shall be maintained of all residuals removed from this facility. This record shall be maintained
at the facility for a period of no less than five years, and shall be made available to the Division upon
request. At a minimum, this record shall include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15ANCAC 02T .0108(b)(1)]
9. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a
period of no less than five years, and shall be made available to the Division upon request. At a
minimum, this log shall include:
a. Date of calibration of flow measurement device;
b. Date of calibration of turbidimeter;
c. Visual observations of the plant and plant site; and
d. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections
and cleanings, etc.).
[I5A NCAC 02T .0108(b)(1)]
10. Monitoring wells shall be sampled at the frequencies and for the parameters specified in Attachment
C. All mapping, well construction forms, well abandonment forms and monitoring data shall refer to
the permit number and the well nomenclature as provided in Attachment C and Figure 2 [15A NCAC
02T .0105(m)]
W00035784 Version 2.1 Shell Version 151201 Page 6 of 9

11. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[ 15A NCAC 02T .0105(m)]
12. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for a period
of no less than five years, and shall be made available to the Division upon request. At a minimum, the
Standard Soil Fertility Analysis shall include the following parameters:
Acidity
Exchangeable Sodium Percentage
Phosphorus
Base Saturation (by calculation)
Magnesium
Potassium
Calcium
Manganese
Sodium
Cation Exchange Capacity
Percent Humic Matter
Zinc
Copper
pH
[15A NCAC 02T .0108(c)]
13. Noncompliance Notification:
The Permittee shall report by telephone to the Winston-Salem Regional Office, telephone number (336)
776-9800, as soon as possible, but in no case more than 24 hours, or on the next working day following
the occurrence or fast knowledge of the occurrence of any of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure the problem does not recur. [15A NCAC 02T .0105(1), 02T .0108(b)(1)]
WO0035784 Version 2.1 Shell Version 151201 Page 7 of 9

V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and irrigation facilities. [15A NCAC 02T .0108(b)]
2. The Permittee or their designee shall inspect the wastewater treatment and irrigation facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment, a threat to human health or a public nuisance. The Permittee shall
maintain an inspection log that includes, at a minimum, the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this
inspection log for a period of five years from the date of the inspection, and this log shall be made
available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and irrigation facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions ofthis permit,
and may collect groundwater, surface water or leachate samples. [G.S. 143-21.5.3(a)(2)]
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with the
conditions of this permit, the Division approved plans and specifications, and other supporting
documentation. [ 15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T .0105(n).
[G.S. 143-21.5.1]
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under General Permit NCGO10000; any requirements pertaining to wetlands under 15A NCAC 02B
.0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the
General Statutes. [15ANCAC 02T .0105(c)(6)]
In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner. [15A NCAC
02T .0104]
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0108(b)(1)]
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority. [15A NCAC 02T
.01050)]
WQ0035784 Version 2.1 Shell Version 151201 Page 8 of 9

8. This permit is subject to revocation or unilateral modification upon 60 days' notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. [ 15A NCAC 02T .0110)
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). [15A
NCAC 02T .0120]
10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 25' day of October 2017
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Jay Zimmerman, P.G., Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number W00035784
W00035784 Version 2.1 Shell Version 151201 Page 9 of 9

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ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Sean Devine
Manager
Wallace Loft, LLC
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Dear Mr. Devine:
NORTH CAROLINA
Environmental Quality
January 10, 2020
Subject: Speculative Effluent Limits
The Cottages of Boone WWTP
Permit No. WQ0035784
Watauga County
Watauga River Basin
This letter provides speculative effluent limits for a 0.1 MGD conjunctive use permit at The Cottages of
Boone W WTP. The Division received the speculative limits request in an email dated November 14, 2019
from Pete Dickerson of Odom Engineering PLLC. Please recognize that speculative limits may change
based on future water quality initiatives, and it is highly recommended that the applicant verify the
speculative limits with the Division's NPDES Unit prior to any engineering design work.
Receivine Stream. Laurel Fork is located within the Watauga River Basin. Laurel Fork has a stream
classification of C;Trom, and waters with this classification have a best usage for aquatic life propagation
and maintenance of biological integrity, wildlife, secondary recreation, agriculture, and trout propagation
and survival. Laurel Fork has a summer 7Q10 flow of 0.44 cfs, a winter 7Q10 flow of 0.64 efs, a 30Q2
flow of 1.39 cfs, and an annual average flow of 3.2 cfs.
Based upon a review of information available from the North Carolina Natural Heritage Program Online
Map Viewer, there are not any Federally Listed threatened or endangered aquatic species identified within
a 5-mile radius of the proposed discharge location. If there are any identified threatened/endangered
species, it is recommended that the applicant discuss the proposed project with the US Fish and Wildlife
Service to determine whether the proposed discharge location might impact such species.
Speculative Effluent Limits. Based on Division review of receiving stream conditions and water quality
modeling results, speculative limits for the proposed conjunctive use discharge of 0.1 MGD are presented
in Table 1. A complete evaluation of these limits and monitoring requirements for metals and other
toxicants, as well as potential instream monitoring requirements, will be addressed upon receipt of a formal
NPDES permit application. Some features of the speculative limit development include the following:
• BODE, BOD limits are assigned to be protective of instream dissolved oxygen (DO)
and are consistent with the facility's non -discharge permit limits. NH3-N limits are assigned to
protect for instream ammonia toxicity and instream DO. The resultant limits are considered
technologically -feasible.
-D_E QJ� 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
wrnwxx.0
'^"'"' FnY0�0i•'�� 919.707.9000

• TSS: TSS limits are consistent with the facility's non -discharge permit limit, NPDES
implementation, treatment plant design, and are considered technically feasible.
TABLE 1. Speculative Limits for The Cottages of Boone W WTP
Effluent Characteristic
Effluent Limitations
Monthly
Average
Weekly
Average
Daily Maximum
Flow
0.1 MGD
BODS
10.0 m
15.0 m L
NH3 as N
3.2 mg/L
16.0 m
Dissolved Oxygen
6.0 m Daily Minimum Average
TSS
5.0 m
7.5 m
TRC
28
Fecal coliform (geometric
mean)
200/100 mL
400/100 mL
Chronic Toxicity, Pass/Fail
(Quarterly test
26%
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES
permit for a new or expanding discharge will be issued with these speculative limits. Final decisions can
only be made after the Division receives and evaluates a formal permit application for the new/expanded
discharge. In accordance with North Carolina Administrative Code 15A NCAC 214.0105(c), the most
environmentally sound alternative should be selected from all reasonably cost effective options. Therefore,
as a component of all NPDES permit applications for new or expanding flow, a detailed engineering
alternatives analysis (EAA) must be prepared. The EAA must justify requested flows and provide an
analysis of potential wastewater treatment alternatives. A copy of the Division guidance for preparing EAA
documents is attached.
Should you have any questions about these speculative limits or NPDES permitting requirements, please
feel free to contact David Hill at [phone].
Respectfully,
J li�
upervisor, t�NNPDES Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
NPDES Permit File
Electronic Copy:
NC Wildlife Resources Commission, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, [e-mail]
DWR/Water Quality Regional Operations/Winston-Salem
DWR/Non-Discharge Branch
DWR/Basinwide Planning, Ian McMillan
DWR/NPDES Server>Specs
Pete Dickerson, [e-mail]
Page 2 of 2

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 02/12/20
Facility: COTTAGES AT BOONE NPDES#: NCWQ003578Ripe#: 001 County: WATAUGA
Laboratory Performing Test: R & A LABORATORIES, INC. _.
Comments: Final Effluent A
X
Signa e o ra 1n Response e C arge Water Tech Project
X 78214-01
9'. to e a oratory Supervisor * PASSED: 2.81% Reduction
Work Order: 78093-01 Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Environmental Management
N.C. Dept. of EHNR
1621 Mail Service Ctr
Raleigh, North Carolina 27699-1621
NnrYh Ca rnlina f'ari nAnnhnin
Chronic Pass/Fail Reproduction Toxicity Test
'.ONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 1123124125123124125124122124122125124
Adult (L)ive (D)ead IIL IL IL IL IL IL IL IL IL IL IL IL
affluent %: 26%
'REATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 1122123122124125123124123122125121123
Adult (L)ive (D)ead IIL IL IL IL IL IL IL IL IL. IL IL IL
Chronic Test Results
Calculated t = 1.418
Tabular t = 2.508
% Reduction = 2.81
% Mortality
Avg.Reprod.
0.00
23.75
Control
Control
0.00
23.08
Treatment 2
Treatment 2
Control CV
4.443% PASS FAIL
% control orgs X
producing 3rd
brood 100 Check One
1st sample 1st sample 2nd sample Complete This For Either Test
PH Test Start Date: 02/05/20
Control 7.37 7.45 7.35 7.43 7.34 7.42 Collection (Start) Date
Sample 1: Type/Duration
Sample 2: 02/05/20
Treatment 2 7.28 7.36 7.40 7.46 7.39 7.47 Sample Type/Duration 2nd
1st P/F
s s s r
Comp. Durak
t e t e t e S S
a n a n a n Sample 1X 24.3 A A
r d r d r d M M
t t t Sample 2X 24.3 P P
1st sample 1st sample 2nd sample
D.O. ardness(mg ;;;'°° °"
Control 8.6 8.4 8.6 8.3 8.6 8.4 °°°°° °'°°"""
Spec. Cond.(pmh537 617
Treatment 2 8.6 8,4 8.6 8.3 8.6 8.4
Chlorine(mg/1) ,,,,,,, 0.01 0.01
LC50/Acute Toxicity Test Sample temp. at receipt(°C) ;;3.3 3.1
(Mortality expressed as %, combining replicates)
Note: Please
Concentration Complete This
Section Also
Mortality
start/end start/end
ation- G'HighO�
obit
her High
Conc.
PH D.O.
50 = %
Method of Determin
% Con i ence Limits
[9:5
Moving Average Pr
% -- %
Spearman Karber = Ot
Organism Tested: Ceriodaphnia dubia Duration(hrs):
Copied from DEM form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.32)

RESEARCH & ANAIyTiCAI
LABORATORIES, INC.
Analytical/Pracess Consultations
BIOASSAY CHAIN OF CUSTODY RECORD
Spec � 41
11
Client: r^i 2 e r c�7 %fir County: pipn�l� )y/e #: r( N//PDES #: C )()p�( Y
Collector (Print}: E^ // Contact Person.9( _ Ofr^�j" _
Collector (SignaYureC�'�a *�- Address:
Phone Number:
Lab #
(RAL only)
Sample
P
Description
(see note)
Sample Collection
Sample Type
No. of
containers
sent
Temp
Upon
Arrival
(°iv)
Analysis
Require
(acute;;
bioassay)
=rl
Date/
Time
Started
Date/
Time
Ended
Temp
(°C)
End
Com p
Grab
for Sample Description please use Effluent, Influent, Upstream, Post Cl., Etc.
Relinquished by: (Signature)
Recyua by: to.
Date/Time
elinquis e ( '' nature)
R a' d b ature,,
Date/Time
Met of S
nh
Logged in by: Moved to bioassay dept. by:
Initials_„_
Initials Dated ?' &D Time 'teaAl
Note: Original sent with shipment
Copy retained by collector
P.O. Box 473 • 108 Short Street • Kernersville, North Carolina 27284 • 336-996-2841 • Fax [phone]
www,randalabs.com

RESEARCh & ANALyTiCAI
LABORATORIES, INC.
AnalyticaUProcess Consultations
BIOASSAY CHAIN OF CUSTODY RECORD
Client: Cis L C�Z _ES z�3 �� County: Pipe #: NPDES #:___ d C 3S f
Collector (Print):
Collector (Signature:
Con[act Person.
Address:
Phone
Lab #
(RAL only)
`1
Sample
Description
(see note`)
Sample Collection
Sample Type
No. of
containers
sent
Te
on
Arrival
(°C}
�.3
Analysis
Required
!acute, chronic
bioassay!
Date/
Time
Started
y.I(
15-/6
Date/
Time
Ended
Y ;U
mks
Temp
(°C)
End
p 7
Comp.
Grab
for Sample Description please use Effluent, Influent, Upstream, Post CIZ, Etc.
Relinquished by: (Signature) I Received by: (Signature)
° ti
Relinquished by: (Signature) Receive -may: (Signature)
Method(af-)Sh�pment:�� f Logged in by:
yy �C 5—Initials _
Note: Original sent with shipment
Copy retained by collector
Date/Time
/(:Z0
Date/Time
Moved to bioassay dept. by:
InitialZQ1"" Date z-tr ZLO T;-- Z;
't 12;z)--3
P.O. Box 473 • 106 Short Street • Kernersville. North Carolina 27284 • 336-996-2841 > Fax [phone]
www.randalabs.com

L Odom
Engineering PLLc
March 13, 2020
Ms. Nicole Harmon
Town Clerk, Town of Boone
567 West King Street
Boone, NC 28607
Dear Ms. Harmon:
169 Oak Street • Forest City, NC 28043
office 828.247.4495 • fax [phone]
** Via Certified Mail — Return Receipt Requested **
Re: Local Government Review Form
On behalf, Cottages of Boone WWTP
NPDES Conjunctive Use Application
Boone, Watauga County, NC
The Cottages of Boone WWTP is a private wastewater treatment plant serving The Cottages of Boone, at 615
Fallview lane, Boone, NC, under Permit No. WQ0035784. This permit provides for drip irrigation disposal of treated
effluent. The Cottages of Boone WWTP is making application through NCDEQ Complex Permitting Unit for NPDES
Conjunctive Use, which will permit continued irrigation, to be supplemented by discharge of treated effluent to
Laurel Fork, a stream in the Watauga River Basin. NCDEQ has reviewed the proposed discharge and receiving
stream and issued Speculative Effluent Limits (attached) for technologically feasible, environmentally sound
discharge at the proposed discharge location.
As required by North Carolina General Statute [ 143-215.1(c) (6) ], prior to submitting the application for a NPDES
Permit, the applicant shall request that both the nearby city and county government complete the attached Local
Government Review Form. The purpose of the form is to determine if the nearby city or county has a zoning or
subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent
with the ordinance. The nearby city or county must respond within 15 days of receipt of this request. The attached
maps show location of the WWTP and proposed discharge location. We would be pleased to answer any questions
you may have concerning the attached form or the proposed permit.
Please Return the completed, signed and notarized form to:
Odom Engineering. PLLC
169 Oak Street
Forest City, NC 28043
Thank you for your assistance in completing the application requirements for this important project.
Sincerely,
061---
David Odom, P.E.
Attachments:
Local Government Review Form
USGS & 8 %" by 11" Site Maps
NPDES Speculative Effluent Limits Letter

Local Government Review Requirements
for the Issuance of New Non -Municipal Domestic Wastewater Discharge Permits
General Statute Overview
North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance of NPDES Permits for non -
municipal domestic wastewater treatment facilities. Specifically, the Environmental Management Commission (EMC) may not act
on an application for a new non -municipal domestic wastewater discharge facility until it has received a written statement from
each city and county government having jurisdiction over any part of the lands on which the proposed facility and its
appurtenances are to be located. The written statement shall document whether the city or county has a zoning or subdivision
ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the ordinance. The
EMC shall not approve a permit application for any facility which a city or county has determined to be inconsistent with zoning
or subdivision ordinances unless the approval of such application is determined to have statewide significance and is in the best
interest of the State.
Instructions to the Applicant
Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant shall request that both the
nearby city and county government complete this form.
The applicant must:
♦ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the
city and the county by certified snail, return receipt requested.
♦ If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the
certified mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the
application to the NPDES Unit.
♦ As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall
submit a copy of the certified mail card along with a notarized letter stating that the local government(s) failed to
respond within the 15-day period.
Instructions to the Local Government
The nearby city and/or county government which may have or has jurisdiction over any part of the land on which the
proposed facility or its appurtenances are to be located is required to complete and return this form to the applicant
within 15 days of receipt. The form must be signed and notarized.
Name of local government
(City/County)
Does the city/county have jurisdiclXon over any part of the land on which the proposed facility and its appurtenances
are to be located? Yes [ ] No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ] No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the
ordinance? Yes [ ] No [ ]
Date �— 2� 2J Signature a Li—IJ
(City anager/County Manager)
State of Moon 1 cayolina , County of 1AJ01—a UQC4
On this 22.nd day of Y'I , 2W personally appeared before me, the said
name,�kJA,J Wu d iTff to me known and known to me to be the person
described in and who executed the foregoing document and he (or she) acknowledged that he (or she)
executed the same and being duly sworn by me, made oath that ent
are true. D Nicole Harmon
My Commission expires 2'8' Zl .(Signature of Nota Pub
of u lic Officia Seal)
tMy Commission Expires bruary 0 , 2021

March 13, 2020
Ms. Anita Fogle
Watauga County Clerk
814 West King Street, Suite 205
Boone, NC 28607
Dear Ms. Fogle:
169 Oal< Street o Forest City, NC 28043
office 828. 247.4495 - fax [phone]
** Via Certified Mail — Return Receipt Requested **
Re: Local Government Review Form
On behalf, Cottages of Boone WWTP
NPDES Conjunctive Use Application
Boone, Watauga County, NC
The Cottages of Boone WWTP is a private wastewater treatment plant serving The Cottages of Boone, at 615
Fallview lane, Boone, NC, under Permit No. WQ0035784. This permit provides for drip irrigation disposal of treated
effluent. The Cottages of Boone WWTP is making application through NCDEQ Complex Permitting Unit for NPDES
Conjunctive Use, which will permit continued irrigation, to be supplemented by discharge of treated effluent to
Laurel Fork, a stream in the Watauga River Basin. NCDEQ has reviewed the proposed discharge and receiving
stream and issued Speculative Effluent Limits (attached) for technologically feasible, environmentally sound
discharge at the proposed discharge location.
As required by North Carolina General Statute [ 143-215.1(c) (6) ], prior to submitting the application for a NPDES
Permit, the applicant shall request that both the nearby city and county government complete the attached Local
Government Review Form. The purpose of the form is to determine if the nearby city or county has a zoning or
subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent
with the ordinance. The nearby city or county must respond within 15 days of receipt of this request. The attached
maps show location of the WWTP and proposed discharge location. We would be pleased to answer any questions
you may have concerning the attached form or the proposed permit.
Please Return the completed, signed and notarized form to:
Odom Engineering. PLLC
169 Oak Street
Forest City, NC 28043
Thank you for your assistance in completing the application requirements for this important project.
Sincerely,
a a t--
David Odom, P.E.
Attachments:
Local Government Review Form
USGS & 8 %" by 11" Site Maps
NPDES Speculative Effluent Limits Letter

Local Government Review Requirements
for the Issuance of New Non -Municipal Domestic Wastewater Discharge Permits
General Statute Overview
North Carolina General Statute 143-215.1 (c)(G) allows input from local governments in the issuance of NPDES Permits for non -
municipal domestic wastewater treatment facilities. Specifically, the Environmental Management Commission (EMC) may not act
on an application for a new non -municipal domestic wastewater discharge facility until it has received a written statement from
each city and county government having jurisdiction over any part of the lands on which the proposed facility and its
appurtenances are to be located. The written statement shall document whether the city or county has a zoning or subdivision
ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the ordinance. The
EMC shall not approve a permit application for any facility which a city or county has determined to be inconsistent with zoning
or subdivision ordinances unless the approval of such application is determined to have statewide significance and is in the best
interest of the State.
Instructions to the Applicant
Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant shall request that both the
nearby city and county government complete this form.
The applicant must:
♦ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the
city and the county by certified mail, return receipt requested.
♦ If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the
certified mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the
application to the NPDES Unit.
♦ As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall
submit a copy of the certified mail card along with a notarized letter stating that the local government(s) failed to
respond within the 15-day period.
Instructions to the Local Government
The nearby city and/or county government which may have or has jurisdiction over any part of the land on which the
proposed facility or its appurtenances are to be located is required to complete and return this form to the applicant
within 15 days of receipt. The form must be signed and notarized.
Name of local government
-� (Cityounty) '
ave jurisdiction over any part of the land on w6c-trroposed facility and its appurtenances
Does the cityEcoiu�n:
are to be located? Yes rt-A No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the ci /county)have in effect a zoning or subdivision ordinance? Yes V'q No [ ]
e
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the
ordinance? YesIK] No [ ]
Date
ger/County
State of 1�1� , County of l�DC-1d rot 1Qp
On this day of 4 ,[� personally appeared before me, the said
name CStf�a FL r nnal 1 to me known and known to me to be the person
described in and who executed the foregoing document and he (or she) acknowledged that he (or she)
executed the same and being duly sworn by me, made oath that the statements in the foregoing document
are true.
My Commission expires)-pQ* .(Signature of Notary Public)
Wntash C TA_AEge"
My Commission Expires
March 31, 2024