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HomeMy WebLinkAboutNC0049662_Fact Sheet_20230613DENR/DWR EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit: NC0049662 2023 Renewal This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303 (d) listed water, toxicity testing, instream monitoring, compliance concerns). Facility and Stream Information Applicant/Facility Name: Aqua North Carolina, Inc. Hawthorne WWTP Applicant Address: 202 Mackenan Court; Cary, NC 27511 Facility Address: Warwickshire Way; Raleigh, NC 27614 Facility Class/Permit Status: Grade II Biological WPCS / Renewal Permitted Flow (as built 0.25 MGD Type of Waste 100% Domestic Receiving Stream Upper Barton Cr Stream Class / ID WS-IV; NSW / 27-15- 1 River Basin Neuse Subbasin 03-04-01 HUC 030202010602 USGS Too Ba leaf D24NW 7Q10 Sum Win cfs 0.07 0.21 30Q2 cfs Avg. Stream Flow cfs 1.1 IWC % sum/win 85 65 County Wake Regional Office RRO Basic Information for Expedited Permit Renewal Permit Writer / Date Bradley Bennett / March 29, 2023; Updated 6/13/23 Does permit need daily max NH3 limits? No - Has monitoring and limits Does permit need TRC limits/language? Yes - Already in permit as backup to UV Does permit have toxicity testing? No Does permit have Special Conditions? Yes - Combined Nutrient Limits; Nutrient Calculation & Reporting; Annual Nutrient Limits; Nutrient Allocations; Temporary Disinfection and Neuse Re -opener Does permit have instream monitoring? Yes - Temp and DO Stream on 303 d List? For w arameter? Yes - Benthos and Mercury statewide issue Any compliance concerns? No Enforcements and a few Violations Any modifications since lastpermit? None since 2019 Modification New expiration date: January 31, 2028 FACILITY OVERVIEW: This facility is 100% domestic waste and treats subdivisions serving a population of 2,065 people. The facility has a permitted and as built flow rate of 0.25 MGD. The treatment system includes the following wastewater treatment components: • Mechanical Bar Screen • Influent pump station • Influent equalization basin • Splitter Box • Dual 0.089 MGD extended aeration treatment plants (with anoxic and oxic zones) • Dual 0.036 MGD extended aeration treatment plants (with anoxic and oxic zones) • Chemical phosphorus removal via a chemical feed system • Effluent equalization tank • Ultraviolet disinfection • Backup chlorine disinfection • Post aeration • 4 sludge holding tanks • Standby power • Flow meter Updates based on comments: The components list was updated based on input from Raleigh Regional Office staff and permittee to note descriptions in parenthesis and change reference to Flow Equalization Basin to Splitter Box to avoid confusion with the Influent Equalization. The item for chemical phosphorous removal was made more generic by removing reference to the specific chemical used. The region also questioned the backup chlorine disinfection but the permittee confirmed it was still in place. APPLICATION The application does not indicate any changes in the facility or treatment since the last modification of the permit in 2019. There was one change since the 2018 renewal - ATC for installation of a new auger type bar screen. The treatment system is operated by Aqua North Carolina, Inc. The annual average daily flow is indicated as 0.13 MGD over the last two years, so the facility is operating at well below its designed and permitted capacity. The application indicates upcoming improvements with generator replacement scheduled for January 2023 and coating repair scheduled for January 2025. As noted under the components above the system has two dual treatment trains, chemical treatment for phosphorous removal and UV disinfection. INSPECTION The most recent inspections occurred on February 28, 2023. The inspection did not note any issues of concern with the facility. Only the dual 0.089MGD trains were working at the time of the inspection. The sludge tanks for these trains were full but those for the dual 0.036 treatment trains were empty. Clarifiers were operating with six feet of freeboard. MONITORING DATA REVIEW: Parameter Units Min Max Avg Permit Limit Comments Flow MGD 0.007 0.28 0.13 0.25 MA BOD m L Summer 1.00 11.00 1.24 16 MA 124 DM BOD m L Winter 1.00 13.00 1.5 30 MA 45 DM TSS m L 1.25 13.00 1.90 30 MA 45 DM Temp C - Effluent 2.70 29.40 19.55 Temp C - Upstream 0.00 28.10 16.83 Temp C - Downstream 3.20 29.50 16.57 NH3-N m L Summer 0.005 4.50 0.13 2 MA 10 DM NH3-N m L Winter 0.005 5.70 0.38 4 MA 20 DM DO m L - Effluent 6.06 10.60 8.69 5 DA DO m L - Upstream 0.00 14.00 8.88 DO m L - Downstream 3.90 16.90 9.10 - Fecal Coliform # ml 0.50 2420.00 24.43 200 MA 400 DM TRC L 22 DM No use of Chlorine Total Nitrogen m L 0.10 55.00 7.14 - TN Monthly lbs month 82.00 1100.43 234.16 See discussion below TN Annual lbs ear Data Reported Inaccurately. See below Total Phosphorus m L 0.01 6.90 0.73 TP Monthly lbs month 3.17 129.43 27.46 See discussion below TP Annual lbs ear Data Reported Inaccurately. See below H su 6.81 8.98 N/A >-6 and <-9 MA -Monthly Average DM - Daily Max QA -Quarterly Average DA - Daily Average Summer - April through Oct Winter - Nov through March The data reviewed for the renewal is from March 2018 through January 2023. REVIEW OF PERMIT LIMITS: Flow - The facility is operating on average at around 50% of the flow allowed by the permit. None of the 59 monthly average values was above 0.164MGD. Hawthorne WWTP Fact Sheet NPDES Renewal 2023 - March 29, 2023; Updated June 13, 2023 Page 2 BOD / TSS / Fecal - The only limit violations this cycle were three daily max values for fecal. Ammonia (NH3-N) and Toxicity - The Waste Load Allocation spreadsheet for this discharge calculated NH3-N limits of 1.1 mg/L for summer and 2.7 mg/L for winter. However, Division policy has established that for small discharges (< 1 MGD) the best available treatment technology for these facilities leads to monthly average limits no lower than 2 mg/L -summer and 4 mg/L - winter. Limits in the permit remain as before. Nutrients The permittee asked for a permit modification in 2019 that set up a bubble permit that works with Aqua's Wildwood Green WWTP (NC0063614) to establish nutrient allocations and load limits that are set as combined mass load limitations for the two plants. In the year prior to the modification the permittee had concentration limits for TN and TP. These concentration limits were removed as part of the 2019 permit modification. The permittee has been reporting some of the nutrient data inaccurately in the eDMR system. The permitee has reported the nitrogen and phosphorus annual loads, QY600 and QY655, on a monthly basis. Each month the value is reported identical to the monthly value (QM600 and QM655). They should be reporting the QM values monthly and then reporting the total annual load (QY values) in the December DMR only. The permittee is also required to report the total combined annual load number for nitrogen and phosphorous for the two WWTPs as part of the December DMR for the Hawthorne (NC49662) facility. These combined TN and TP annual loads are to be reported as part of a separately established permit outfall (C01) for the Hawthorne permit. The permittee reported this data correctly in 2019 and 2020 but did not report the data correctly in 2021 and 2022. In these years the combined loading number appear to have been reported as the December QY numbers in the regular 001 Hawthorne outfall. The permittee has been made aware of these data entry inaccuracies and is working to correct these. COMPLIANCE: The last enforcement action for this facility was for a 2018 Fecal daily max exceedance. The facility had five NOVs since the permit modification in March 2019. Three of the incidents were for monitoring frequency violations and non -reporting. There were also two NOVs for Fecal daily max violations. FILE HISTORY REVIEW SUMMARY • Permit was originally issued in November 1981 • Authorization to Construct (ATC) - August 23, 1985. This ATC was for construction of a 0.10 MGD wastewater treatment facility consisting of additions to the existing 0.05 MGD plant: a 50,000 gallon capacity aerated tank for flow equalization and emergency wastewater storage; a splitter box; a second 0.05 MGD extended aeration plant with a 50,000 gallon capacity aeration tank and blowers, a 7,500 gallon capacity sludge holding tank, 8,333 gallon capacity clarifier, a 1,100 gallon capacity chlorine contact tank with tablet type chlorinator; a recording effluent flow meter and totalizer; equipment for chemical removal of phosphorous by the "Odophos" process; and all other necessary piping, valves, fittings, and appurtenances. • July 23, 1986 -Waste Load Allocation (WLA) -Class C; NSW Waters Design flow = 0.25 MGD s7Q10 =0.07 cfs w7Q10 = 0.21 cfs; Avg cfs = 1.1 Season BOD5 m L NH3-N m L DO m L TSS m L Fecal m L pH std units Summer 18 11 5 30 1,000 6-9 Winter 30 - 5 30 1,000 6-9 March 5, 1991 WLA - This one is done for two flows, 0.10 MGD and 0.25 MGD with 7Q10 numbers the same as previous. Stream class is C-NSW: Hawthorne WWTP Fact Sheet NPDES Renewal 2023 — March 29, 2023; Updated June 13, 2023 Page 3 Flow BOD5 NH3-N DO TSS Fecal pH Total P TRC MGD m /L m /L m /L m /L m /L std units m /L µ /L (w . 0.10 5 30 200 6-9 2 - 30 w) 3 18(s 1.1(s) . 0.25 w) 5 30 200 6-9 2 20.1 Also monitoring U,D for DO, Temp, Fecal and Conductivity. Permittee given choice of new NH3-N limits or existing limits with WET requirements. • January 19,1993 WLA - Stream classification - WS-IV; NSW. Requirements all the same as 1991 WLA. Ammonia numbers reported as high on DMRs. Not apparent if WET over more stringent the NH3-N limits accepted. Discussion about whether the facility was Class -III vs Class -II which would increase monitoring frequency. • May 25, 1994 - ATC for construction of 0.178 MGD expansion of treatment system to reach a total capacity of 0.25MGD. System spit four ways with 0.072 MGD spilt evenly to two existing dual package plants and 0.178 spilt equally to proposed dual package plants. System to include existing and new structures to provide equalization basin, flow control basin with weirs to split flows, aeration basins, clarifiers, sludge holding tanks, UV disinfection and chlorine contact tanks (backup), etc. • January 23, 2000 - DWR letter reclassifying the system as Class II. • October 9, 2000 - Permit Renewal. The permit is issued for an as -built flow of 0.161MGD and also contains apermitted flow of up to 0.25MGD with ATC, etc. Flow BOD5 NH3-N DO TSS Fecal pH Total P TRC MGD (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (std units) (mg/L) (µg/L) MA DM MA DA MA DM MA DM quarter avg DM 0.161 16.2/24.3(s) 2 (s) 5 30/45 200/400 6-9 2 22 30 45 w 4 w 0.25 1 2 5 30/45 200/400 6-9 2 20 / (w) 4 ( ) Permit also required TN monitoring and reporting monthly concentration, monthly load and annual load. Conductivity monitoring was removed from the permit. The permit included a Special Condition requiring development of a Wastewater Management Plan that looked at future flows and alternatives. There was also a special condition for the calculation of monthly and annual TN mass loads. In the cover letter for the permit the Division outlined new nutrient requirements based on the newly issued NSW rules. The facility was advised to begin looking at treatment options for nitrogen reduction. This permit, along with others in the Neuse Basin, was taken to public hearing. • June 25, 2001 - Permit modification to reduce instream monitoring from 3/week to weekly in response to the permittee's request. This modification is consistent with Class II facility requirements. • November 12, 2003 - Permit Renewal. This renewal added daily maximum limits for NH3-N of 10mg/L summer and 20mg/L winter. The permit included addition of a special condition addressing Annual Limits for TN and modified the previous condition on development of a Wastewater Management plan to obtain information not previously submitted. • November 25, 2003 - Engineer's Certification for Phase 3 of 3 completion for 1994 ATC. • December 2, 2003 - Heater Utility response completing requirements for Wastewater Management Plan information. • June 9, 2004 - Approval of requested flow reduction for future sewer line extensions to 285 GPD per three bedroom home and 95 GPD for each bedroom above 3. Minimum for all single and 2 bedroom homes of 190 GPD. • September 20, 2004 - Retraction of Sewer Line Moratorium. Division had not accounted for the permittee's completion of expansion of the treatment system. • February 18, 2008 - Permit Renewal - Renewal to current owner - Aqua NC. The permit included updates to the treatment system components to show the completion of the two dual treatment systems totaling 0.25MGD flow. Effluent table requirements consistent with the 0.25MGD table from the previous permit. Permit included special conditions for: the calculation of total nitrogen loads; total nitrogen load allocations and temporary means of disinfection. Staff report recommended a permit requirement for steel structures of the treatment plant to be reviewed by a structural engineer and a plan prepared to address any issues Havy thorne WWTP Fact Sheet NPDFS Renewal 2023 — March 29, 2023: Updated June 13, 2023 within 12 months and also recommended addition of weekly upstream/downstream fecal monitoring. These requirements were not included in the permit. • October 14, 2013 - Permit Renewal. This permit updated nutrient requirements to add TN and TP monthly average (8mg/L and 1mg/L) and annual average (5.5mg/L and 0.5mg/L) limits to become effective January 1, 2016. At that time the existing TP quarterly average limit expired. The permit also added special conditions for annual limits for total nitrogen and updated other nutrient special conditions. Permit also updated the facility location to off Warwickshire Way in response to regional office comments. • February 12, 2016 - ATC for construction/reconfiguration of treatment system to provide multiple anoxic zones within the various treatment trains in the system. • January 25, 2018 - Permit Renewal. This renewal maintained existing requirements with some adjustments to the effluent table. Added rule citations and language for electronic submittal of DMRs. • April 20, 2018 - ATC for replacement of existing manual bar screen with auger type mechanical bar screen and bypass manual bar screen. • September 21, 2018 - Engineer's Certification for 2018 ATC. • March 22, 2019 - Permit Modification - This modification was issued in response to the permittee's request for a modification that allowed for mass load combined (bubble) permit limits for this permit and their Wildwood Green WWTP (NC0063614). The permit changed the effluent limits page to monitoring only for TN and TP and established Special Conditions pages to outline Combined Limitations for the Wildwood Green and Hawthorne WWTPs. The permit also established changes in special conditions to set TN and TP Allocations. • September 5, 2019 Memo to File on Transfer of Unavailable TN Allocations. This memo summarizes a meeting between Aqua staff and DWR staff September 3, 2019 to discuss transferring TN allocations from Hawthorne and Wildwood Green WWTPs to Aqua's Neuse Colony facility. The Neuse rules don't provide for existing facilities to increase their limits and expects them to take steps to meet their assigned limits. Aqua could transfer TN allocation to Neuse Colony but it could only be used when the facility expands beyond 0.75 MGD as currently permitted. It did not appear likely that Aqua would benefit from a transfer. PROPOSED PERMIT CHANGES: • Updated eDMR requirements to be consistent with final EPA rule. • Added or updated regulatory citations throughout permit as needed. • After the public notice, treatment system components were adjusted based on permittee and regional office comments (see discussion of changes above). • Permit map information updated. • Added Special Condition for Nutrient Re -opener. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: April 4, 2023 Permit Scheduled Effective Date: July 1, 2023 STATE CONTACT: If you have questions concerning the above or the attached documents, please contact Bradley Bennett at bradley.bennett@ncdenr.gov. . Hawthorne WWTP Fact Sheet NPDES Renewal 2023 — March 29, 2023; Updated June 13, 2023 Page 5 ipt> News & Observer Publication Name: News & Observer Publication URL: Publication City and State: Raleigh, NC Publication County: Wake Notice Popular Keyword Category: Notice Keywords: NC0049662 Notice Authentication Number: 202305010822360971244 2510867466 Notice URL: Back Notice Publish Date: Thursday, April 27, 2023 Notice Content Public Notice State of North Carolina/Environmental Management Commission 1617 Mail Service Center, Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES wastewater permit. The North Carolina Environmental Management Commission proposes to issue a NPDES wastewater discharge permit to the person(s) listed below. AQUA North Carolina, Inc [202 MacKenan Court; Cary, NC 27511] has requested renewal of NPDES permit NC0063614 for the Wildwood Green WWTP, located in Wake County. This permitted facility discharges 100% domestic wastewater to a UT to Lower Barton Creek, a class WS-IV; NSW water in the Neuse River Basin. Some of the parameters in the permit are water quality limited. This discharge may affect future allocations in this segment of Lower Barton Creek. AQUA North Carolina, Inc [202 MacKenan Court; Cary, NC 27511] has requested renewal of NPDES permit NC0049662 for the Hawthorne WWTP, located in Wake County. This permitted facility discharges 100% domestic wastewater to Upper Barton Creek, a class WS-IV; NSW water in the Neuse River Basin. Some of the parameters in the permit are water quality limited. This discharge may affect future allocations in this segment of Upper Barton Creek. The Town of Robersonville has applied for renewal of NPDES permit NC0026042 for its Robersonville WWTP in Martin County. This permitted facility discharges treated wastewater to Flat Swamp in the Tar Pamlico River Basin. Written comments regarding the proposed permit will be accepted until 30 days after the publish date. The Director of the NC Division of Water Resources may hold a public hearing should there be a significant degree of public interest. Interested persons may visit the DWR at 512 N. Salisbury Street, Raleigh, NC, 27699. Please mail comments and/or information requests to DWR at the address listed above. Additional information on NPDES permits and this notice may be found on our website: http://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/npdes- wastewater/public-notices, or by calling (919) 707-3601. W00000000 Publication Dates Back Bennett, Bradley From: Sent: Bennett, Bradley Tuesday, May 9, 2023 2:09 PM To: Berger, Amanda A Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) Thanks for the comments, Amanda. I'll look at these when we are finalizing the permits. Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, May 9, 2023 1:55 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Hey Bradley — The only comments received were: 1. Chemical for phosphorus removal is sodium aluminate not ferric sulfate. a. Can we just say chemical phosphorus vs specifying the chemical? Also Hawthorne has a flow EQ basin and influent basin listed. Are they not the same? Thanks, Amanda AQUA Amanda Berger Director, Environmental Compliance Aqua North Carolina 202 Mackenan Court; Cary, NC 27511 000 From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Tuesday, April 18, 2023 3:30 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Thanks Amanda From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, April 18, 2023 3:19 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Hi Bradley - I was out of the office that week, and I was under the impression someone else responded. Yes, we have received the drafts and are under review by operations staff. I will let you know if we have any comments or concerns. Wildwood Green —Yes, it has backup chlorination. It is rarely used but it's available. Thank you, and apologies on the delayed response. Best regards, Amanda AQUA Amanda Berger Director, Environmental Compliance Aqua North Carolina 202 Mackenan Court; Cary, NC 27511 4) From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Thursday, April 6, 2023 7:52 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Attached are the draft permit renewals for these two WWTPs. These permits are going to public notice as drafted. Please review and let me know if you have any questions or comments. On the Wildwood Green WWTP could you verify whether or not there is backup disinfection (Chlorine). There has been some language in the permit to include TRC limits if chlorine is used and discuss temporary disinfection. Backup disinfection was not mentioned in the application though. If this is not the case then we can remove that reference. Please respond to this email to let me know that you received the two permit files and were able to read, download and print the files for your records. fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director MEMORANDUM NORTH CAROLINA Environmental Quality April 4, 2023 To: Shawn Guyer and Catherine Hadidon NC DEQ / DWR / Public Water Supply Raleigh Regional Office From: Bradley Bennett BB Compliance and Expedited Permitting Unit Subject: Review of Draft NPDES Permit NCO049662 Hawthorne WWTP Wake County Please indicate below your agency's position or viewpoint on the draft permit and return this form by May 4, 2023. If you have any questions on the draft permit, please contact me via e-mail [bradley.bennett@ncdenr.gov]. RESPONSE: (Check one) Concur with the issuance of this permit provided the facility is operated and maintained Fv_1 properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. F-1 Concurs with issuance of the above permit, provided the following conditions are met: 1-1 Opposes the issuance of the above permit, based on reasons stated below, or attached: Signed Date: 04/19/2023 D EQ �� 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 NOfiTH CAROL.INA � oop—WdEn..a t.lousi� /'� 919.707.9000 Bennett, Bradley From: Kinney, Maureen Sent: Tuesday, April 11, 2023 8:42 AM To: Bennett, Bradley Subject: RE: Needs Reclassification: Drafts - Wildwood Green (NC0063614) and Hawthorne (NC0049662) No, sorry Bradley. That was my goof. Thanks for checking back. Ma A.re *v K U' q V eY NC DEQ - Division of Water Resources Wastewater Operator Certification 919-707-9038 From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Tuesday, April 11, 2023 8:39 AM To: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Cc: Weaver, Charles <charles.weaver@ncdenr.gov>; Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Subject: RE: Needs Reclassification: Drafts - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Maureen, There was discussion about the classification in the permit files for each of these. There is a brief discussion of this in my Fact Sheets. For Hawthorne there was a January 2000 letter in the file from DWQ that classified the system as Class II. For Wildwood Green there was discussion about the proper classification in the 2008 permit renewal. Ultimately it was given Class II status instead of Class III. I can't remember if there was a letter in the file on this one or not. I'm in the office today and did not bring the files for these but I'll check back through about that and get back to you. Is there anything that has happened recently that would change these to Class II? Thanks M9. From: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Sent: Tuesday, April 11, 2023 8:26 AM To: Bennett, Bradley <bradley.ben nett@ncdenr.gov> Cc: Weaver, Charles <charles.weaver@ncdenr.gov>; Manuel, Vanessa <vanessa.manuel@ncdenr.gov>; Cory.Larsen@ncdenr.gov Subject: Needs Reclassification: Drafts - Wildwood Green (NC0063614) and Hawthorne (NC0049662) These both appear to be WW-II in BIMS but should be WW-III. Cory/Vanessa - does RRO concur? If so, I'll draft letters to the permittee. Thanks all, Maureen Ma,&we aw K 6nvtey NC DEQ - Division of Water Resources Wastewater Operator Certification 919-707-9038 From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Monday, April 10, 2023 7:27 AM To: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Subject: Drafts for Review - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Hey Maureen, Here are two draft permit for your review. Both are Aqua facilities. Let me know if you have any comments. Thanks Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Bennett, Bradley Sent: Monday, April 10, 2023 7:36 AM To: Zhang, Cheng Cc: Manuel, Vanessa Subject: Permits to Notice - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Attachments: NC0063614_Draft Permit and Cover Ltr_2023.pdf; NC0063614_Fact Sheet Binder_ 2023.pdf; NC0049662_Fact Sheet Binder_2023.pdf, NC0049662_Draft Permit and Cover Ltr_2023.pdf Hey Cheng, Just wanted to pass along that these two permits have gone to notice. I know you had indicated some comments on the components list. I had responded to your last email to try and get clarification on those changes since it looked like you hadn't attached the file where you made the changes. Even though that didn't get in the drafts we can make appropriate changes in the final permits. Thanks for your help with these. fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Zhang, Cheng Sent: Wednesday, March 29, 2023 11:58 AM To: Bennett, Bradley Cc: Manuel, Vanessa Subject: RE: Aqua Draft Permits - Hawthorne (NC0049662) and Wildwood Green (NC63614) Attachments: Hawthorne WWTP NC0049662.pdf Bradley, I made minor edits to the treatment components (see highlighted text): influent flow equalization basin is actually the splitter box; original aeration basins at all treatment trains were modified with anoxic and oxic zones in 2016 and 2017, which enabled the facility to remove nutrients biologically. The facility does not have backup chlorine disinfection, might need to remove the item. Please let me know if you have any questions, thanks. Do you know who is the permit writer for Knightdale Estates MHP WWTP (NC0040266)? I inspected the facility yesterday and was told there is a draft permit but I am unable to find it on Laserfiche or S: drive, there are a few minor changes need to be made for the treatment components. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax chena.zhan. (a-ncdenr.eov 1628 Mail Service Center Raleigh, NC 27699-1628 .., D Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, March 29, 2023 10:30 AM To: Zhang, Cheng <cheng.zhang@ncdenr.gov> Cc: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Subject: Aqua Draft Permits - Hawthorne (NC0049662) and Wildwood Green (NC63614) Hey Cheng, I have the draft permits ready for these tow Aqua facilities. The draft permits and fact sheets are attached. The applications are available in Laserfiche. Please take a look and let me know if you have any comments/concerns. I hope to get these out for public notice next week. :: Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett(o)ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Draft Permit NC0049662 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge, are hereby revoked. The exclusive authority to operate this facility arises under this permit. The authority to operate the facility under previously issued permits bearing this number is no longer effective. The conditions, requirements, terms and provisions of this permit authorizing discharge under the NPDES govern discharges from this facility. AQUA North Carolina, Inc. is hereby authorized to: 1. Continue to operate an existing 0.250 MGD wastewater treatment system with the following components: • Mechanical Bar Screen • Influent pump station • Influent equalization basin • Flow equalization basin (splitter box) • Dual 0.089 MGD extended aeration treatment plants (with anoxic and oxic zones) • Dual 0.036 MGD extended aeration treatment plants (with anoxic and oxic zones) • Chemical phosphorus removal via a ferric sulphate feed system • Effluent equalization tank • Ultraviolet disinfection • Backup chlorine disinfection • Post aeration • 4 sludge holding tanks • Standby power • Flow meter - Aqua confirmed facility does still have backup chlorine disinfection This facility is located north of Leesville at the Hawthorne WWTP off Warwickshire Way in Wake County. 2. Discharge from said treatment works at the location specified on the attached map into Upper Barton Creek, waters currently classified WS-IV; NSW [Stream Segment: 27-15-(1)] in sub -basin 03-04-01 [HUC: 030202010602] of the Neuse River Basin. Page 2 of 13 NH3/TRC WLA Calculations Facility: Aqua -Hawthorne WWTP Permit No. NCO049662 Prepared By: Bradley Bennett Enter Design Flow (MGD): 0.25 <= Permitted Flow if Different from Design Enter s7Q10 (cfs): 0.07 Enter w7Q10 (cfs): 0.21 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/1) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (UG/L) Upstream Bkgd (ug/1) IWC (%) Allowable Conc. (ug/1) Fecal Coliform Monthly Average Limit: (If DF >331; Monitor) (If DF<331; Limit) Dilution Factor (DF) Ammonia (Summer) Monthly Average Limit (mg NH3-N/1) Design Permitted Design Permitted 0.07 s7Q10 (CFS) 0.07 0.25 DESIGN FLOW (MGD) 0.25 0.3875 DESIGN FLOW (CFS) 0.3875 17.0 STREAM STD (MG/L) 1.0 0 Upstream Bkgd (mg/1) 0.22 84.70 IWC (%) 84.70 20 Allowable Conc. (mg/1) 1.1 < 1 MGD Policy Applies Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Design Permitted Design Permitted w7Q10 (CFS) 0.21 200/100mi DESIGN FLOW (MGD) 0.25 DESIGN FLOW (CFS) 0.3875 STREAM STD (MG/L) 1.8 1.18 Upstream Bkgd (mg/1) 0.22 IWC (%) 64.85 Allowable Conc. (mg/1) 2.7 Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/l, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals) 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed * By Policy dischargers < 1 MGD get limits no lower than 2 & 4 due to BAT * From 2B .0404(c) - Winter Limits can be no less stringent than 2 times the summer limits Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) Bennett, Bradley From: Pearce, Joseph R <JRPearce@aquaamerica.com> Sent: Wednesday, March 15, 2023 12:58 PM To: Bennett, Bradley; Berger, Amanda A Cc: Lambeth, Robyn E; Krueger, Robert D Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Bradley, Thanks for the info. I was concerned that the ultra low ammonia tox limits may become a matter of conflict. Joe Joseph Pearce PE CFM Chief of Operations and Engineering Aqua North Carolina, Inc. 202 MacKenan Court Cary, North Carolina 27511 0:919.653.6964 F:919.460.1788 From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, March 15, 2023 12:31 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com>; Pearce, Joseph R <JRPearce@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Thanks for the updated info and looking into the DMR issues. On the Ammonia/WET testing issue I guess I should have mentioned a few other pieces. We had another renewal (Briarwood I think) that noted the Division is implementing updated Ammonia criteria that is based on EPA input that we can no longer use action levels to replace chemical limit requirements. In the past we had allowed people to pick adding toxicity over more stringent ammonia limits. We can no longer do this in our permits and have to use the more stringent chemical limit requirements. So, I think we will have to implement the required ammonia limits. Looking at the data from the previous permit cycle and using the proposed limits (2/10 — summer and 4/20 -winter) it looks like your facility would not have had any limit violations. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, March 14, 2023 5:29 PM To: Bennett, Bradley <bradley.ben nett@ncdenr.eov> Cc: Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com>; Pearce, Joseph R <JRPearce@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Hi Bradley, The DMR's are generated by our compliance software. For programming purposes, it lists the annual loads monthly. I have advised the operator to remove that column moving forward. The monthly loads for each facility is correct. Please ignore the annual loading calculations for each facility. Operations will be revising the December DMRs to include the annual loading requirements for Wildwood Green. Hawthorne appears correct on my end, but I have also asked they verify prior to your review of that facility. With respect to the WET requirement, given the information regarding the ammonia limit, Aqua is requesting rescission of the request to remove the WET testing requirement. Thanks, Amanda From: Pearce, Joseph R <JRPearce@aquaamerica.com> Sent: Tuesday, March 14, 2023 3:53 PM To: Berger, Amanda A <AABerger@aquaamerica.com>; Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs Good Afternoon Bradley, Staff are reviewing the DMR issue. I trust they will have it figured out in a day or so, and then will file amended DMRs. Joe 'A'4 'RIP ###r t ka* Joseph Pearce PE CFM Chief of Operations and Engineering Aqua North Carolina, Inc. 202 MacKenan Court Cary, North Carolina 27511 0:919.653.6964 F:919.460.1788 000 From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, March 14, 2023 3:44 PM To: Bennett, Bradley <bradley.ben nett@ncdenr.eov> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs Hi Bradley, Doing well. Hope you are! Answering the first 2 questions. I will need to work with operations to review the others. The address listed on the application is the address listed on prior permits. See below. a. When I searched for 1899 Baileywick, the address is not either listed or it is not the WWTP. Looking at old aerials, it appears that Gleneagles Drive should have been extended and utilized as the entrance to the WWTP; however, it is not. Entrance is off of Baileywick at intersection with Old Creedmore Rd. I cannot locate a street address for either Baileywick or Gleneagles. Upper Barton — Mistype from Hawthorne. Yes, its Lower Barton. AQUA North Carolina, Inc. i erebyauthorized to discharge wastewater from a facility located at the Wild ood Green Subdivision WWTP Gleneagles Drive Northwest of Raleigh Wake County receiving waters designated as an unnamed tributary to Lower Barton Creek in the Meuse River Basin Thanks, Amanda From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Tuesday, March 14, 2023 11:30 AM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Ison, Laurie T <LTlson@aquaamerica.com> Subject: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Hope you are doing well! I just wanted to touch base on the Wildwood Green and Hawthorne permit renewals. I am currently working on the permit renewal reviews for each of these facilities. Since they are connected with the nutrient loading requirements I want to complete and notice them at the same time. I have gone through the Wildwood Green renewal and started on Hawthorne. I had a couple of issues to run by you guys based on where I'm at currently. I may have additional issues as I work through the Hawthorne renewal but wanted to go ahead and send these along. • On the Wildwood Green application, you indicate the facility address as Gleneagles Drive but in our system, it shows as 1899 Baileywick Road. Could you verify the location for us. If it is Gleneagles is there an address number as well? • The Wildwood Green application indicates the discharge is to Upper Barton Creek, but it appears that our records from before are accurate in showing discharge to UT to Lower Barton Creek. • Wildwood Green submitted a DMR correction for your July 2022 data submittal. The correction was entered in eDMR in January 2023. The data was certified in the eDMR system but was never submitted. The data needs to be Submitted in eDMR before the correction can be processed and the data updated. • For both Wildwood Green and Hawthorne, it appears that your monitoring data for nutrient loads is being reported inaccurately. Your permits require submittal of monthly loads for TN and TP (QM600 & QM655) as well as an annual load for each (QY600 & QY655). Your DMRs show that you are reporting the QY values each month and reporting the same values as the monthly (QM) values. You should be reporting the QM values monthly and the QY values only in the December monitoring report for each year showing the total annual load. • For the Hawthorne permit you are also required to report combined annual nutrient loading for the Wildwood Green and Hawthorne facilities using a separate outfall. Looking at the data it appears that you may not have submitted this annual load for 2021 or 2022. Please check this and make the corrections if needed. • For Wildwood Green you had requested review of WET testing requirements for potential removal from the permit. It does appear that we will be able to grant this request and remove WET requirements. Please note that with this change we will also update the ammonia limits in your permit. This will result in lower limits for this parameter. • 1 have attached Contact Information downloads from our system for each of the facilities. Please review this information and let us know of contact corrections that should be made and any contacts that should be removed, etc. • You might also hear from Raleigh Regional Office staff on the monitoring issues noted above. As with previous permits over the last few years, I will plan to submit drafts and the final permit do you electronically unless you request hard copies. Thanks for your attention to these requests. I'll be back in touch if there are other issues as I continue my review. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Zhang, Cheng Sent: Tuesday, March 14, 2023 9:49 AM To: Bennett, Bradley; Manuel, Vanessa Cc: Goss, Stephanie Subject: RE: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Yes, please let them know they need to complete the submission, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhang(dncdenr.gov 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Tuesday, March 14, 2023 9:46 AM To: Zhang, Cheng <cheng.zhang@ncdenr.gov>; Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Cc: Goss, Stephanie <stephanie.goss@ncdenr.gov> Subject: RE: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Cheng, On the July DMR for Wildwood Green, I think they did enter a corrected DMR in January 2023, but it never actually got submitted in the eDMR system. They certified it so you can see it in eDMR but because they never submitted it the data never made it into the system and got pushed to BIMS. I can talk with them about that issue if you want. [37 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nettat ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Zhang, Cheng <cheng.zhang@ncdenr.eov> Sent: Tuesday, March 14, 2023 9:40 AM To: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Cc: Goss, Stephanie <stephanie.goss@ncdenr.gov>; Bennett, Bradley <bradley. bennett@ncdenr.gov> Subject: RE: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Bradley is correct, Aqua needs to report monthly TN (QM600) TP (QM665) loads each facility's DMR, and only report the combined annual TN (QY600) and TP (QY665) on Hawthorne's December DMR (Permit Conditions Part I A(3). C.), and they have been doing that (I think they reported the combined loads on Hawthorne's December DMRs) , I checked their 2022 data, the final numbers were not correct according to my calculation though, still well less that the annual TN and TP limits. I will ask Aqua to amend Wildwood Green's July 2022 DMR (QM600 and QM665 were way off because total monthly flow was calculated wrong) and check their annual load numbers, and also let them they only need to report annual loads on Hawthorne's December DMR. Please let me know if you have any questions, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhang(a�ncdenr.gov 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Sent: Monday, March 13, 2023 3:35 PM To: Zhang, Cheng <cheng.zhang@ncdenr.gov> Cc: Goss, Stephanie <stephanie.goss@ncdenr.gov>; Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: FW: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Cheng, Please see Bradley's email below and assist him with his questions. Thanks, Vanessa E. Manuel Assistant Regional Supervisor Division of Water Resources — Raleigh Regional Office Department of Environmental Quality 919 791-4232 Office; 919 817-1256 Mobile vanessa.manuel(cD-ncdenr.gov Physical: 3800 Barrett Drive, Raleigh, NC 27609 Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628 K-- - Z- -�.`�Nlothing Compares , Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Goss, Stephanie <stephanie.goss@ncdenr.gov> Sent: Monday, March 13, 2023 3:13 PM To: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Subject: FW: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Vanessa, Can you please assist Mr. Bennett with his questions or concerns. Thanks and hope you had a nice weekend. Stephanie Z. Goss 401 & Buffer Permitting Supervisor Division of Water Resources 512 N. Salisbury Street Raleigh, NC 27620 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, March 8, 2023 9:37 AM To: Goss, Stephanie <stephanie.goss@ncdenr.gov> Subject: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Hey Stephanie, I am currently reviewing the permit renewals for these two facilities. They have bubble permits that tie the two together with TN and TP loads. I noticed that you recently inspected the Hawthorne facility so I thought I'd reach out about a couple of issues monitoring wise on these two. I'm not sure if you are familiar with the Wildwood Green facility or not but thought I'd check. On their monitoring I just wanted to verify that what I think I'm seeing is correct. Sometimes I miss some things on the reported data and you guys help to straighten me out! So before I comment to Aqua I want to run this by someone in the regional office. For both of these facilities they are reporting annual load numbers for TN and TP (QY600 and QY665) on a monthly basis. Most months they are reporting the same number in the QY data as the monthly TN and TP (QM6OO and QM665) load values. I think they should only be reporting the QY values in December? Looks like in December they often are reporting a different QY value that seems to reflect an annual number. Also, for the Hawthorne plant it looks like they haven't submitted their Combined Total TN and TP annual values for 2021 or 2022. These are supposed to be submitted under a different outfall number (CO1). Maybe I'm mossing something on these? Thanks for any input on these. Let me know if you have any other comments about these two renewals. MM Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws