WQ0035784_Additional Information Request_20210806

DocuSign Envelope ID: 9DE23C31-427E-4F89-9849-3F9547712867
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
August 6, 2021
CERTIFIED MAIL 7018 1130 0000 1612 5297
RETURN RECEIPT REQUESTED
Mr. Justin Pellegrino, Portfolio Manager
Cottages of Boone
4100 E. Mississippi Ave, Floor 15
Denver, CO 80246
Subject: Additional Information Request
Application for Temporary Pump & Haul Permit
The Cottages of Boone
Watauga County
The North Carolina Division of Water Resources has reviewed the application for a temporary
pump & haul permit received July 29, 2021. However, additional information was requested via
email on July 30, 2021, and there has been no response provided to date. This information is
required before the review may be completed. Please provide the information requested below
within 10 business days of receipt of this letter.
1. Item VI.1. of the application indicated "haul of treated effluent due to limited wet weather
application/storage of spray irrigation discharge" and "untreated water hauling during
cleaning of membranes". Please provide a response to the following:
a. The wastewater level that is being reported to the Division for the wet weather
storage tank has been lowered to a level that is compliant with the permit (i.e., the
most recent report indicated 14.5 feet of available storage in the wet weather storage
tank). In addition, weather and site conditions are conducive to wastewater
irrigation and increasing available storage at this time.
Please provide explanation how there is "limited wet weather application" and
"limited storage available" at the time of this application submittal.
b. For over one year there has been discussions between the Division and onsite
representatives concerning the membranes failing, requiring more and more
frequent cleanings, with the cleaning events being less and less effective. It has
become apparent that there are issues with these membranes which require
immediate attention and possibly replacement of failed membranes.
Please provide a plan of action for taking corrective actions along with an
estimated timeline for repair or replacement of membranes.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

DocuSign Envelope ID: 9DE23C31-427E-4F89-9849-3F9547712867
2. Item VI.2. & 3. of the application indicated the reason for the request as "running out of
wet weather storage" and that the temporary permit will be needed for "2 months". Please
provide a response to the following:
a. Again, the wastewater levels reported in the wet weather storage tank show a trend
of increased available storage with each month.
Please provide explanation how the facility is "running out of wet weather
storage" over the next two months as indicated in the application.
b. The application is requesting the permit be issued for a period of two months. At
this time there is sufficient wet weather storage and irrigation activities that are
being reported to the Division show a trend for increasing storage availability. Also,
at this time there is no timeframe provided to the Division related to
repair/replacement of membranes.
Please confirm that this application is intended for permit coverage for a
period of only two months.
Please submit the information requested above to the address on letterhead to my attention. Once
received, all additional information will be reviewed, and the permitting process can continue.
Please be aware, any omissions made in responding or failure to respond within the timeframe
provided may result in your application being returned as incomplete.
If you have any questions regarding this request, please do not hesitate to contact Patrick Mitchell
or me by phone or email at [e-mail] or [e-mail].
Thank you for your cooperation,
DocuSigned by:
L oti 'T. Stildu-
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Mr. Sean Devine — 2626 Glenwood Ave, Suite 550, Raleigh, NC 27608
Ms. Rose Hernandez-Chim (Electronic Copy)
Laserfiche Files
WSRO Electronic Files
Page 2 of 2

Mitchell, Patrick
From: Mitchell, Patrick
Sent: Friday, July 30, 2021 9:54 AM
To: 'Rose Hernandez'
Cc: Snider, Lon; Graznak, Jenny
Subject: RE: [External] The Cottages of Boone - Permit Application
Importance: High
Rose,
Thank you for providing the electronic copy of the pump & haul permitting application. We will be looking for the hard
copy to arrive in the mail. However, we need to request some additional information.
NC regulations allow for issuance of temporary pump & haul permits for use during emergency situations or due to
unavoidable delays in construction of a wastewater treatment system or connection to a public sewer collection system.
These same rules also indicate that pump & haul activities are not to alleviate a failing wastewater system; meaning that
repair solutions, upgrade plans or other permanent means of treatment and disposal shall be in place prior to permit
issuance. This is the fifth application for a temporary pump & haul permit that the Division has received since 2018 from
the Cottages of Boone facility. Due to the number and frequency of these permits, we must request additional
information before we can proceed with permitting.
1. Item VI.1. of the application indicated "haul of treated effluent due to limited wet weather application/storage
of spray irrigation discharge" and "untreated water hauling during cleaning of membranes". Please provide a
response to the following:
a. The wastewater level that is being reported to the Division for the wet weather storage tank has been
lowered to a level that is compliant with the permit (i.e., the most recent report indicated 12.5 feet of
available storage in the wet weather storage tank). In addition weather and site conditions are
conducive to wastewater irrigation and increasing available storage at this time.
Please provide explanation how there is "limited wet weather application" and "limited storage
available" at the time of this application submittal.
b. For over one year there has been discussions between the Division and onsite representatives
concerning the membranes failing, requiring more and more frequent cleanings, with the cleaning
events being less and less effective. It has become apparent that there are issues with these membranes
which require immediate attention and possibly replacement of failed membranes.
Please provide a plan of action for taking corrective actions along with an estimated timeline for
repair or replacement of membranes.
2. Item VI.2. & 3. of the application indicated the reason for the request as "running out of wet weather storage"
and that the temporary permit will be needed for "2 months". Please provide a response to the following:
a. Again, the wastewater levels reported in the wet weather storage tank show a trend of increased
available storage with each month.
Please provide explanation how the facility is "running out of wet weather storage" over the next two
months.
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b. The application is requesting the permit be issued for a period of two months. At this time there is
sufficient wet weather storage and irrigation activities that are being reported to the Division show a
trend for increasing storage availability.
Please confirm that this application is intended for permit coverage for a period of only two
months.
Please provide responses to the items requested above in a timely manner, as we cannot proceed with permitting until
we have received this information. Feel free to contact us if you have questions.
Thank you,
Patrick L. Mitchell, REHS, LSS
Environmental Program Consultant — Soil Scientist
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environmental Quality
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
tc
Nothing Compares.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Rose Hernandez <[e-mail]>
Sent: Tuesday, July 27, 2021 2:16 PM
To: Mitchell, Patrick <[e-mail]>
Subject: [External] The Cottages of Boone - Permit Application
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hello Patrick,
I sent over the pump and haul permit application to you by mail. It should be there any day. I have attached a
copy of what was sent over to you as we foresee still pump and hauling for untreated water. Let me know if you
have any questions.
Thank you,
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Rosalia Hernandez-Chim I Community Manager
615 Fallview Ln. I Boone, NC 28607
0.828.865.1800 I [e-mail]
www.thecottagesofboone.com
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