HomeMy WebLinkAboutWQ0035784_Additional Information Request_20230206ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
SEAN DWYER — DIRECTOR
WALLACE LOFT LLC
5 BRYANT PARK — 28TH FLOOR
NEw YORK, NEw YORK 10018
Dear Mr. Dwyer:
NORTH CAROLINA
Environmental Quality
February 6, 2023
Subject: Application No. WQ0035784
Additional Information Request
The Cottages of Boone WWTP
Wastewater Irrigation System
Watauga County
Division of Water Resources' Central and Regional staff has reviewed the application package
received November 22, 2022. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on March 8,
2023.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through M, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with an
electronic response submitted to my attention at: https:Hedocs.deg.nc.gov/Forms/NonDischarge-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at (919) 707-3660 or
Lauren.Plummer(ancdenr.gov. Thank you for your cooperation.
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n,Mn Mummer, Engineer III
Division of Water Resources
Enclosure
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Mark Brooks, PE — Brooks Engineering Associates, P.A. (Electronic Copy)
Laserfiche File (Electronic Copy)
E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROHNA -
oePemmencatE.W —rdalQuari /� 919.707.9000
Mr. Sean Dwyer
February 6, 2023
Page 2 of 4
A. Cover/Response Letter:
1. The response letter dated August 22, 2022 indicates that the installation of the 90% pipe will reduce
the tank volume to 49,274 gallons (Item H.1). However, Section V. Item I I.a of Form WWIS 06-
16 and the provided engineering calculations lists the flow equalization tank volume as 40,786
gallons. Please address this discrepancy and revise the application, if necessary, to reflect the
equalization tank's volume upon installation of the 90% pipe.
B. Application Fee:
1. Not applicable.
C. Application (Form: WWIS-R 02-21):
Mr. Sean Dwyer is listed as the Signature Authority in Section I, Item 3. Our office recently
received a request on January 18, 2023, that Mr. Dwyer be removed from communications and
replaced with (Mr./Ms.) Wen De Tam. Please confirm that (Mr./Ms.) Wen De Tam is to replace
Sean Dwyer as the Owner/Director of Wallace Loft LLC and Signature Authority for this permit,
and please verify that Mr. Dwyer is no longer affiliated with Wallace Loft LLC so that we may
update our database.
Section V. Item 1 lists Mr. Eric Youngs as the Operator in Responsible Charge (ORC). A review
of our database shows that Mr. Youngs classification status is currently "invalid". Please have Mr.
Youngs contact the Operator Certification group (URL: https:Hdeg.nc.gov/about/divisions/water-
resources/operator-certification/wastewater-operator/staff-ww) to determine the necessary steps
required to return to "active" status. Pursuant to 15A NCAC 08G .0200, the Permittee shall
designate and employ a certified ORC and one or more back-up ORCs. The ORC and back-up
ORC must be in good standing with the Water Pollution Control System Operators Certification
Commission (WPCSOCC).
The response regarding Attachment J — Civil Penalties and Outstanding Violations was answered
as 'No". A Notice of Deficiency was issued January 9, 2023, that outlined deficiencies observed
during the December 2022 inspection. On January 18, 2023, a Notice of Violation was issued
related to compliance monitoring. Please provide an update regarding Wallace Loft LLC's
response to these Notices.
D. Application (Form: WWIS 06-16):
Section IV. Item 7 lists 859 bedrooms contributing to a daily design flow of 105,000 GPD. The
existing permit's facility description lists "894 bedrooms, five administrative/clubhouse
employees, a fitness center, and a pool" contributing to the Cottages of Boone WWTP for a total
daily design flow of 108,530 GPD. Please confirm that the current facility description is accurate,
and if the current facility description is in error, then please update the daily design flow
contributions in Section IV. Item 7 in accordance with 15A NCAC 02T .0114.
2. Section IV. Items 8 and 9 were unanswered. Please revise the application to include responses to
these questions.
Section V. Item 1 I.a. See Comment A. 1.
Mr. Sean Dwyer
February 6, 2023
Page 3 of 4
4. Section V. Item 1 I.c states that two Ultradynamic UV banks were installed with 4 bulbs per bank
and a maximum disinfection capacity of 150 GPM. The existing permit lists dual 130 GPM Severn
Trent UV disinfection systems. Were the Severn Trent units replaced?
5. The response to Section VIIL Item 4, is still answered "no" regarding intent to comply with 15A
NCAC 02T .0506(c) for reduced irrigation setbacks. Based on the provided response letter this
should have been changed to "yes". Please revise the application.
E. Property Ownership Documentation:
1. No comments.
F. Engineering Plans:
1. No comments.
G. Specifications:
The specifications for the proposed 90% outlet pipe do not appear to have been included within the
signed and sealed "Engineer's Evaluation of Valve Installation Including Specifications &
Calculations" letter. Specifications describing materials to be used, methods of construction
(including required procedures for cutting into the tank sidewall), and means for ensuring quality
and integrity of the finished product, including leakage testing are to be provided in accordance
with 15A NCAC 02T .0504(c)(2).
H. Engineering Calculations:
1. No comments.
I. Site Map:
1. Both applications indicated that a Site Map meeting the requirements of 15A NCAC 02T .0504(d)
was to be provided. This map was not included in the submitted documents. Please provide the
updated site map as required.
J. Power Reliability Plan:
1. No comments.
Mr. Sean Dwyer
February 6, 2023
Page 4 of 4
K. Operation & Maintenance Plan:
1. The Engineering Plans and Specifications documents referenced in the response letter are separate
from the Operation & Maintenance (O&M) Plan. The provided O&M Plan is dated August 2013
and does not appear to be updated to include operation of the knife valve and proposed 90% outlet
pipe. A revised O&M Plan meeting the requirements of 15A NCAC 02T .0507 is required. This
document shall include, at a minimum, a description o£
a. Operation of the wastewater treatment, storage, and irrigation systems insufficient detail
to show what operations are necessary for the system to function and by whom the
functions are to be conducted.
b. Anticipated maintenance of the wastewater treatment, storage, and irrigation systems.
c. Safety measures, including restriction of access to the site and equipment.
d. Spill prevention provisions such as response to upsets and bypasses, including how to
control, contain, and remediate.
e. Contact information for plant personnel, emergency responders, and regulatory agencies.
L. Residuals Management Plan:
1. No comments.
M. Additional Documentation:
➢ Existing Permit:
1. No comments.
➢ Engineer's Certification:
1. Our understanding is the knife valve is currently installed and operational. Please provide an
Engineer's Certification for the knife valve using the enclosed form to certify its continued use.