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HomeMy WebLinkAboutNC0088684_Permit Issuance_20160415Water Resources ENVIRONMENTAL QUALITY PAT MCCRORY Gnremar DONALD R. VAN DER VAART Secretary S. JAY ZIMMERMAN Director April 15, 2016 Mr. Peter Grimaldi, Director of Horticulture Daniel Jonathan Stowe Conservancy 6500 South New Hope Road Belmont, NC 28012 Subject: Issuance of NPDES Permit NCO088684 Daniel Stowe Botanical Garden WTP 6500 South New Hope Road, Belmont 28012 Gaston County Dear Mr. Grimaldi: The Division of Water Resources (the Division) hereby issues the attached NPDES permit for the subject facility. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007, or as subsequently amended. We have made the following updates to your previous permit: • added parameter codes to Section A. (1.) • updated facility description has been modified to better reflect the operational circumstances of the facility, including the typical frequency and duration of discharge • pursuant to a review of data reported during the current permit cycle, including performance of a reasonable potential analysis upon applicable parameters (Chloride, Copper and Zinc), monitoring frequency has been reduced from monthly to quarterly for the following parameters: Total Dissolved Solids, Turbidity, Total Copper, Total Zinc, Total Nitrogen and Total Phosphorous • monitoring for pH has been reduced from 2/month to monthly • monitoring for Total Chlorides has been removed from the permit • added Discharge Alternatives Evaluation as described in Section A. (2.). Whole Effluent Toxicity test results submitted during the past three years have demonstrated that the Water Treatment Plant's effluent is showing potential for causing aquatic toxicity in the receiving stream. As a result, the Daniel Jonathan Stowe Conservancy shall perform a Discharge Alternatives Evaluation as described in Section A. (2.) of this permit. This evaluation is being requested to determine whether there are any economical and technologically feasible alternatives available to the Daniel Jonathan Stowe Conservancy to comply with all NC Water Quality Standards. The permittee will be given approximately one permit cycle to evaluate and document possible treatment/discharge alternatives to eliminate aquatic toxicity. The evaluation shall be submitted with the permittee's next permit renewal application and will be carefully reviewed by the Division and the results will be used in the State of North Carolina I Environmental Quality I Water Resources 1617 Mail service Center I Raleigh. North Carolina 27699-1617 919 807 6300 Mr. Grimaldi April 15, 2016 Page 2 of 3 development of a compliance schedule or possible variance request for the Daniel Jonathan Stowe Conservancy. _ We have made the following updates since the draft permit: • updated stream inform an unnamed tributary to Catawba River (Lake Wylie) [Stream Segment l l-(123.5)] classified WS-V, B waters (the previous permit and BIMS database indicated that the stream was Catawba Creek [Stream Segment 11-130] classified C waters which was incorrect) • updated the facility map • the coordinates for the Outfall 001 were adjusted to the following: Latitude: 35' 10' 13" Longitude: -81" 0311811 • updated footnote 1 in Section A. (1.): Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. See Special Condition A. (4). • updated Special Condition A. (4.) for electronic reporting of monitoring reports • removed Salinity monitoring because this parameter is intended for RO water treatment systems that typically are found near the coast in which there is a narrative water quality standard for saltwater • added a 500 mg/L limit with monthly monitoring for Total Dissolved Solids because Catawba River (Lake Wylie) is classified as WS-V, B waters. Starting December 21, 2016, federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. The requirement to begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) intemet application has been added to your. final NPDES permit. [See Special Condition A. (4.)] For information on eDMR, registering for eDMR and 6btaining an eDMR user account, please visit the following web page: http://deg.nc.gov/about/divis'ions/Water-resources/edmr. For more information on EPA's final NPDES Electronic Reporting Rule, please visit the following ,web site: http://www2.epa.gov/compliance/final-national-pollutant-discharge-elimination-system-nndes- electronic-reportin -rule. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty (30) days after receiving this letter. Your request must take the form of a written Mr. Grimaldi April 15, 2016 Page 2 of 3 petition conforming to Chapter 150B of North Carolina General Statutes, and you must file it with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall remain final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Resources or any other Federal, State, or Local governmental permits that may be required. If you have questions, or if we can be of further service, please contact Derek Denard at [derek.denard@ncdenr.gov] or call (919) 807-6307. esp tfully,�� S. Jay Zimmerman, P.G. for Division of Water Resources, NCDEQ Enclosure: NPDES Permit NCO088684 (Issuance Final) hc: Central Files NPDES Program Files MRO Files/ Attn: Corey Basinger ec: Peter Grimaldi [grimaldi@dsbg.org] Christine Cordy [cordy@dsbg.org] NPDES Permit NCO088684 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM .DES In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the Daniel Jonathan Stowe Conservancy is hereby authorized to discharge wastewater from a facility located at the Daniel Stowe Botanical Garden WTP 6500 South New Hope Road, Belmont 28012 Gaston County to receiving waters designated as an unnamed tributary to Catawba River (Lake Wylie) in the Catawba River Basin, in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11, III and IV hereof. This permit shall become effective May 1, 2016. This permit and. authorization to discharge shall expire at midnight on August 31, 2020. Signed this day April 15, 2016. Spy Zimmerman, P.G., Dira Division of Water Resourc By Authority of the Environmental Management Commission Page 1 of 8 NPDES Permit NCO088684 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requiiements, terms, and provisions included herein. Daniel Jonathan Stowe Conservancy is hereby authorized to: 1. continue to operate a reverse osmosis (RO) - membrane technology water treatment system with discharge of wastewaters consisting of RO Concentrate and Softener Regeneration with a design potable flowrate of 0.0038 MGD of high purity water and a wastewater discharge of 0.003552 MGD, serving to fill a 750 gallon tank twice a week; actual volume is much less than design; located at the Daniel Stowe Botanical Garden, 6500 South New Hope Road, Belmont, NC, Gaston County. 2. discharge from said treatment works via Outfall 001 at a location specified on the attached map, into an unnamed tributary to Catawba River (Lake Wylie) [Stream Segment 11-(123.5)], currently a Class WS-V, B waterbody within Subbasin 03-08-37 WC: 030501011502] of the Catawba River Basin. Page 2 of 8 NPDES Permit NCO088684 PART I A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the Permit effective date'and lasting until expiration, the Permittee is authorized to discharge backwash wastewater from reverse osmosis (RO) water treatment system and similar wastewaters from outfall 001. Such discharges shall be limited, monitored and reported" by the Permittee as specified below: s...=:.�f..+.) a.i".:.—ti�:Y-_+i-..._e.,,....�si=,L. EF�FLENT;C�iARACTERISTICS_ x r Pa�amel`er Code, ••, .�-. :,' _ LIMITS M nflil - - �p r� . t - 3t gverage. �, Maximum , + � .,.;.L r....A... �p,,.,.e:.-. MD)VITORIN. REQI�REMENTS� - Measurementa Sample Fr`e u nc mpleType q Location: Flow (MGD) 50050 Monitor & Report Monthly Instantaneous Effluent Conductivity (Nmhos/cm) 00094 Monitor & Report Monthly Grab Effluent pH (su) 00400 6.0 & <_ 9.0 standard units Monthly Grab Effluent Total Dissolved Solids (mg/L) 70295 500 mg/L Monthly Grab Effluent Turbidity (NTU) 00070 Monitor & Report Quarterly Grab Effluent Total Copper (Ng/L) 01042 Monitor & Report Quarterly2 Grab Effluent Total Zinc (Ng/L) 01092 Monitor & Report Quarterly2 Grab Effluent Total Nitrogen (mg/L) C0600 Monitor & Report Quarterly2 Grab Effluent Total Phosphorus (mg/L) C0665 Monitor & Report Quarterly2 Grab Effluent Whole Effluent Toxicity Monitoring3 TGP313 Monitor & Report Quarterly Grab Effluent Footnotes: 1. Starting on December 21, 2016, begin submitting Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (4.). 2. Monitoring should be conducted in conjunction. with whole effluent toxicity testing. 3. Whole Effluent Toxicity (Ceriodaphnia dubia) at 90%; March, June, September and December; refer to Special Condition A. (3.). Conditions: • All samples must be collected from a typical discharge event. • There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 3 of 8 NPDES Permit NCO088684 A. (2.) DISCHARGE ALTERNATIVES EVALUATION [15A NCAC 02H .0105] The Permiee shall assess potential alternatives to eliminate Whole Effluent Toxicity (WET) test failures. This evaluation shall assess the feasibility of all the following alternatives. 1. Connect discharge to a WWTP: Determine whether the wastewater can be discharged to a wastewater treatment plant. Approval or disapproval from the plant operator should be acquired. 2.Obtain a Non -discharge permit: Eliminate the. surface water discharge by obtaining a non -discharge permit for spray irrigation, infiltration, or subsurface disposal (on -site drainfield, infiltration gallery, injection wells). 3. Install Wastewater Treatment: Install improved wastewater treatment to enable the facility effluent to consistently pass the WET test. If this is not technically feasible or cost prohibitive, please explain and provide estimated costs. 4. Use Alternative Water Treatment Source: Obtain drinking water from another source (nearest County, City, or Town or other wells) so the discharge or toxicity problem is eliminated. 5. Use Alternative Water Treatment Method: Install alternative and/or innovative water treatment methods or operational improvements that do not produce toxic wastewaters. For example, install a recycle iron/manganese filtration system with no discharge or combine discharge with WWTP or cooling water effluents. 6. Discharge to a Larger waterhody/Perform a dilution model: Relocate the facility's discharge to as larger receiving waterbody to eliminate or reduce toxic impacts to the receiving waterbody given the increased dilution. If applicable, perform a dilution model to receive allowance for stream dilution in WET test. 7. Combination of Alternatives: Employ any combination of the alternatives listed above that would result in eliminating or decreasing toxicity until a more feasible solution becomes available. The evaluation shall include a present value of costs analysis for all technologically feasible options as outlined in the Division's "Engineering Alternatives Analysis Guidance Document." This Document can be found at: http://portal.ncdenr.or web/wq/swp/ps/npdes/permits. This evaluation is being requested to determine whether there are any economical and technologically feasible alternatives available to the Permiee to address aquatic toxicity in the plant effluent. Based upon the evaluation, please identify viable alternatives and present an implementation schedule and project timeline for the preferred alternative. The Permiee shall submit the Discharge Alternatives Evaluation to the Division along with the submission of their next permit renewal application (due 6 months prior to permit expiration on August 31, 2020) to: NC DENR / Division of Water Resources / Water Quality Permitting NPDES, Wastewater Branch 1617 Mail Service Center, Raleigh, NC 27699-1617 Page 4 of 8 NPDES Permit NCO088684 A. (3.) CHRONIC TOXICITY PASS/FAIL MONITORING ONLY (QUARTERLY) [15A NCAC 02B .0500 et seq.] The permittee shall conduct quarterl chronic toxicity tests using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions. The -effluent concentration defined as treatment two in the procedure document is 90 %. The testing shall be performed as a Ceriodaphnia dubia 7-day pass/fail test. The tests will be performed during the months of March, June, September and December. These months signify the first month of each three month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B. Additionally, DWR Form AT-1 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1623 Mail Service Center Raleigh, North Carolina 27699-1623 Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted io the Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately. Upon submission of a valid test, this monthly test requirement will revert to quarterly in the months specified above. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Page 5 of 8 NPDES Permit N00088684 A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS [G. S. 143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports and specify that, if a state does not establish a system to receive such submittals, then permittees must submit monitoring data and reports electronically to the Environmental Protection Agency (EPA). The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This special condition supplements or supersedes the following sections within Part H of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting • Section D. (6.). Records Retention • Section E. (5.) Monitoring Reports 1. Reporting Requirements (Supersedes Section D. (2.) and Section E. (5.) (a)1 Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting" section below. Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring data and reports, when applicable: Page 6 of 8 NPDES Permit N00088684 Sewer ,OverflowBypass Event Reports; Pretreatment Program Annual Reports; and Clean Water Act (CWA) Section 316(b) Annual Reports. The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). 2. Electronic Submissions In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each electronic submission. The permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. information on EPA's NPDES Electronic Reporting Rule is'found at: bZ://www2.epa. ov/compliance/final-national-pollutant- discharae-elimination-system-npdes-electronic-reporting-rule. Electronic submissions must start by the dates listed in the "Reporting Requirements" section above. - 3. How to Request a Waiver from Electronic Reporting The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: http://deq.nc-2ov/about/divisions/water-resources/edmr Page 7 of 8 NPDES Permit NCO088684 4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part U, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part H, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: hU:Hdeg.nc.gov/about/divisions/water-resources/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are .significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " 5. Records Retention [Supplements Section D. (6.)] The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Page 8 of 8 South New Hope Rd kJP0 pproximate ��. \ t .;, ��_- ��°•. G—J (` Facility Boundary V1 [flows southwest] UT to Catawba River (Lake Wylie) [flaws southwest] _� sa � � l / n , 27 \ �e 77 LAKE i' „ Daniel Jonathan Stowe Conservancy Facility 6500 South New Hope Road, Belmont 28102 LOCatlon Not to Scale Receiving Stream: UT to Catawba River (Lake Wylie) Stream Class: WS-IV, B. Stream Segment: ll-(123.5) Sub -Basin: 03-0847 Drainage Basin: Catawba Ruc: 030501011502 NPDES Permit NCO088684 Latitude: 350 10'13" Longitude: 81003' 18" North State GridRJSGS Ouad: G14NE/Belmont, NC Stair. 1:24,000 Gaston County DEQ/DWR/NPDES EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit NCO088684 Derek Denard, Compliance & Expedited Permitting Unit / 919-807-6307 14Apr2016 Facility Information Applicant/Facility Name Daniel Johnathan Stowe Conservancy Daniel Stowe Botanical Garden WTP Applicant Address 6500 South New Hope Rd, Belmont, NC 28012 Facility Address 6500 South New Hope Rd, Belmont, NC 28012 Permitted Flow (MGD) Not limited Type of Waste Water Plants and Water Conditioning Discharge — Reverse Osmosis (RO) Concentrate and Softener Regeneration — Membrane Technology WTP System Facility Class Not Classified County Gaston Permit Status Renewal Regional Office MRO Stream Characteristics Receiving Stream UT to Catawba River (Lake Wylie) Stream Classification WS-IV, B Stream Segment [11-(123.5)] Drainage basin Catawba Summer 7Q10 (cfs) --- Subbasin [HUC] 03-08-37 [030501011502] Winter 7Q 10 (cfs) --- Use Support Impaired (Cat 5) for PCB &Hg Fish Tissue 30Q2(cfs) 303(d)Listed Average Flow (cfs) State Grid F14SW 1WC (%) 100% USGS Topo Quad Gastonia North, NC Facility Summary This facility is a reverse osmosis (RO) - membrane technology water treatment system with discharge of wastewaters consisting of RO Concentrate and Softener Regeneration with a design potable flowrate of 0.0038 MGD of high purity water and a wastewater discharge of 0.003552 MGD, serving to fill a 750 gallon tank twice a week; actual volume is much less than design; Monthly average FLOW (MGD) — 36 months March2013-Feb2016: [Ave 0.00140 MGD; Maximum, Monthly average flow = 0.00426 MGD] Toxici —This permit requires Whole Effluent Toxicity (Ceriodaphnia dubia) at 90%; March, June, September and December; refer to Special Condition A. (3.) [TGP3B]. See information on Toxicity monitoring and the addition of a Discharge Alternatives Evaluation as described in Section A. (2.) in the Renewal Summary Section below. Twelve (12) out of twelve (12) [100% failure rate] toxicity tests failed for the review period March2013-F62016. Fact Sheet Renewal 2016 -- NPDES Permit NCO088684 Page 1 Data review DMRs were reviewed for the period of Sep2011-Feb2016 (4 %2 years). DMR data is summarized in Table I below: Table I Parameter Average I Max Min UOM 00070 - Turbidity 0.51 6.40 0.02 NTU 00094 - Conductivity 409 827 147 umhos/cm 00400 - pH 7.8 8.6 6.7 su 00940 - Chloride (as Cl) 11.9 30.0 3.6 mg/L 01042 - Copper, Total (as Cu) 83 157 16 µg/L 01092 - Zinc, Total (as Zn) 517 1242 38 µg/L 50050 - Flow, in conduit or thru treatment plant 1082.5 4739.3 1.2 GPD 70295 - Solids, Total Dissolved 307 618 96 mg/L C0600 - Nitrogen, Total (as N) - Concentration 1.56 4.30 0.05 mg/L C0665 - Phosphorus, Total (as P) - Concentration 0.20 0.57 0.06 mg/L Renewal Summary — This permit reflects discharge at Outfall 001. DWR updated the following: • added parameter codes to Section A. (L) • updated the facility map • updated stream inform an unnamed tributary to Catawba River (Lake Wylie) [Stream Segment 1I- (123.5)] classified WS-V, B waters (the previous permit and BIMS database indicated that the stream was Catawba Creek [Stream Segment 11-130] classified C waters which was incorrect) • updated facility description has been modified to better reflect the operational circumstances of the facility, including the typical frequency and duration of discharge • pursuant to a review of data reported during the current permit cycle, including performance of a reasonable potential analysis upon applicable parameters (Chloride, Copper and Zinc), monitoring frequency has been reduced from monthly to quarterly for the following parameters: Total Dissolved Solids, Turbidity, Total Copper, Total Zinc, Total Nitrogen and Total Phosphorous • monitoring for pH has been reduced from 2/month to monthly • monitoring for Total Chlorides has been removed from the permit • added Discharge Alternatives Evaluation as described in Section A. (2.). Whole Effluent Toxicity test results submitted during the past three years have demonstrated that the Water Treatment Plant's effluent is showing potential for causing aquatic toxicity in the receiving stream. As a result, the Daniel Jonathan Stowe Conservancy shall perform a Discharge Alternatives Evaluation as described in Section A. (2.) of this permit. This evaluation is being requested to determine whether there are any economical and technologically feasible alternatives available to the Daniel Jonathan Stowe Conservancy to comply with all NC Water Quality Standards. The permittee will be given approximately one permit cycle to evaluate and document possible treatment/discharge alternatives to eliminate aquatic toxicity. The evaluation shall be submitted with the permittee's next permit renewal application and will be carefully reviewed by the Division and the results will be used in the development of a compliance schedule or possible variance request for the Daniel Jonathan Stowe Conservancy. We have made the following updates since the draft permit: Fact Sheet Renewal 2016 -- NPDES NCO088684 Page 2 • updated stream inform an unnamed tributary to Catawba River (Lake Wylie) [Stream Segment 1I- (123.5)] classified WS-V, B waters (the previous permit and BIMS database indicated that the stream was Catawba Creek [Stream Segment 11-130) classified C waters which was incorrect) • updated the facility map • the coordinates for the Outfall 001 were adjusted to the following: Latitude: 35' 10' 13" Longitude: -81' 03' 18" • updated footnote 1 in Section A. (I.): Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. See Special Condition A. (4.). • updated Special Condition A. (4.) for electronic reporting of monitoring reports • removed Salinity monitoring because this parameter is intended for RO water treatment systems that typically are found near the coast in which there is a narrative water quality standard for saltwater • added a 500 mg/L limit with monthly monitoring for Total Dissolved Solids because Catawba River (Lake Wylie) is classified as WS-V, B waters. Stream — Discharge from Daniel Stowe Botanical Garden WTP for outfall 001 is into an unnamed tributary to Catawba River (Lake Wylie) [Stream Segment 11-(123.5)] classified WS-V, B waters (see Figure 1.). The previous permit and BIMS database indicated that the stream was Catawba Creek [Stream Segment 11-130] classified C waters which was incorrect (see Figure 2.). However, GIS mapping indicates that the discharge is into an unnamed tributary that drains to segment 11-(123.5) just below segment 11-130 [see attached GIS map]. The segment H-(123.5)a is listed as "Impaired (Cat 5)" for PCB & Hg in fish tissue in the 2014 Integrated Report 305(b). Outfall Location: Outfall location was adjusted to Latitude: 35° 10' 13" Longitude: -81° 03' 18". The previous coordinates Latitude: 35' 10' 13" Longitude: -81 ° 03' 16" use were not on property owned by Daniel Johnathan Stowe Conservancy. The outfall location was shifted two seconds to the west placing the outfall long both the stream segment and blue line indicated on USGS Topo Quad Belmont, NC. Previous permit maps indicated the wrong USGS Topo Quad as Gastonia North, NC. RPA — A Reasonable Potential Analysis (RPA) was conducted on Turbidity, TDS, Chloride, Copper and Zinc effluent parameters data because Discharge Monitoring Reports (DMRs) reported concentration above method -detection levels (MDLs) for the past three (3) years (Sep2011-17e62016), unless otherwise noted. [See attached RPA summary] • Chloride did not have reasonable potential to violate state WQS of 230.0 µg/L. The predicted maximum was less than 50% of the chronic allowable concentration (Cw). Therefore, monitoring will no longer be required for Chloride. Fact Sheet Renewal 2016 -- NPDES NC0088684 Page 3 -- NC Surface Water Classifications �yKe, N� ( �l?4y�OFOf � ,.a Y` _ U a .It' Ye� , i �= �n r� 7 r s{ NC Surface Water Classifications as�v2om r.. m�m,a�,.,,,im NC Clesslflcatlans WBbslto ,_ 6r_ N Figure 3. The outfall location was shifted two seconds to the west placing the outfall long both the stream segment and blue line indicated on USGS Topo Quad Belmont, NC. [Image not to scale] Figure 4. Reasonable Potential Analysis (RPA) Fact Sheet Renewal 2016 -- NPDES NCO088684 Page 5 Daniel Stowe Botanical Garden WTP 2014 Freshwater RPA - 95% Probability/95% Confidence NCO088684 MAXIMUM DATA POINTS = 58 Qw (MGD) = 0.004 IQIOS(cfs)= 0.00 7Q10S(cfs)= 0.00 7QIOW(cfs)= 0.00 30Q2 (cfs) = 0.00 Avg. Stream Flow, QA (cfs) = 0.00 Receiving Stream: Catawba River (Lake Wylie) WWTP/WTP Class: Not Rated IWC ® IQIOS = 100.00% IWC Q7QIOS= 100.00% IWCQ7QIOW= 100.00% IWC Q 30Q2= 100.00% IWC®QA= 100.00% Stream Class: WS-V, B Outfall 001 Qw = 0.004256 MGD PARAMETER STANDARDS & CRITERIA (2) w REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE (1) J a F NC WQS / Applied '/m FAV / Max Pred it # Det. Allowable Cw Chronic Standard Acute Cw Acute: NO WQS ChIorldes(AL) NC 230 FW mg/L 52 52E60. _ _ ____ ___ ChfOnic: 230 _ _ _ _ No RP, Pretlicletl Max<50%of Allowable Cw-No No value> Allowable Cw Monitoring required Acute: 7.3 Copper (AL) NC 7 FW 7.3 ug/L 53 53_ ____ Chronic: 7.0 _ _ _ _ _ _ _ _ _ RP for AL(Cu,Zn,Ag,Fe,CO-apply Quarterly 53 value s > Allowable Cw Monitoring in conjunction with TOX Test Acute: 67.0 Zinc (AL) NC 50 FW 67 ug/L 53 53 1,279.3 _ _ _ _____ ____ Chronic: 50.0 _ _ _ _ _ _ _ _ _ RPfor AL(CgZn,Ag,Fe,CI) apply Quarterly 51 values > Allowable Cw Monitoring in conjunction with TOX Test Acute: NO WQS Turbidity NC _.- FW NTU 39 38 8.4 _ Chr_ onic: 25.0 No RP, Predicted Max 150%of Allowable Cw- No value> Allowable Cw Monitoring Only Acute: NO WQS Total Dissolved Solids NC Soo WS mg/L 53 53 624.2 _ _ _ _ __ Chronic: 500.0 _-_ _ _ _ _ _ _ _ _ _ RP for non -AL- apply Monthly Monitoring with Limit I values > Allowable C w NCO088684 RPA 2015.x1sm, rps Page 1 of 1 4/14/2016 REASONABLE POTENTIAL ANALYSIS 5 Use"PASTE SPECIAL- Values" nren "Copp' . Chlorides (AL) 9 Copper (AL) Use"PASTE aPECIAI.Values" then"COPY". Maximum data points = 58 Maximum data points=So Date Data BDL=1/20L Results Date Data BDL=112DL Results 1 10/14/2011 11 11 Std Des. 4A888 1 10/14/2011 97.7 97.7 Sid Des. 35,3224 2 11/16/2011 8.9 8.9 Mean 11.9 2 11/16/2011 148 148 Mean 82.6340 3 12/13/2011 18 18 C.V. 0.3785 3 12/13/2011 103 103 C.V. 0.4275 4 1/11/2012 3.6 3.6 n 52 4 1/11/2012 76.4 76.4 in 53 5 2/14/2012 8.9 8.9 5 2/14/2012 133 133 6 3/13/2012 11 11 Mull Factor = 1.0 6 3/13/2012 70.4 70.4 Mull Factor = 1.02 7 4/10/2012 6.9 8.9 Max. Value 30.0 ini 7 4/10/2012 127 127 Max. Value 157.0 ug/L 8 5/11/2012 10 10 Max. Fred Cw 30.6 mg/L 8 5/11/2012 138 138 Max. Pred Cw 160.1 ug/L 9 6/12/2012 10 10 9 6/12/2012 105 105 10 7/17/2012 11 11 10 7/1712012 103 103 11 8/10/2012 11 11 11 8/10/2012 88 88 12 9/11/2012 11 11 12 9/11/2012 90.5 90.5 13 10/16/2012 5.3 5.3 13 10/16/2012 19 19 14 11/15/2012 11 11 14 11/15/2012 94.1 94.1 15 12/11/2012 8.9 8.9 15 12/11/2012 107 107 16 1/812013 11 11 16 1/8/2013 102 102 17 2/5/2013 11 11 17 2/5/2013 101 101 18 3/12/2013 5.3 5.3 18 3/12/2013 98.6 98.6 19 4/9/2013 12 12 19 419/2013 91.1 91.1 20 5/10/2013 9.8 9.8 20 5/10/2013 104 104 21 6/4/2013 5.3 5.3 21 6/4/2013 83.7 83.7 22 719/2013 11 11 22 7/9/2013 86.8 86.8 23 8/6/2013 8.9 8.9 23 8/6/2013 79.8 79.8 24 9/10/2013 12 12 24 9/10/2013 88.2 88.2 25 1018/2013 8.9 8.9 25 10/8/2013 73.5 73.5 26 11/5/2013 8.5 8.5 26 11/5/2013 90.8 90.8 27 1213/2013 11 11 27 12/3/2013 110 110 28 1/14/2014 14 14 28 1/14/2014 128 126 29 2/18/2014 11 11 29 2/18/2014 147 147 30 3118/2014 10 10 30 3/18/2014 157 157 31 4/15/2014 8.9 8.9 31 4/15/2014 116 116 32 5/19/2014 8.9 8.9 32 5/19/2014 102 102 33 6/10/2014 9.8 9.8 33 611012014 105 105 34 7/15/2014 8.9 8.9 34 7/15/2014 96 96 35 8/14/2014 19 19 35 8/14/2014 77 77 36 9/30/2014 12 12 36 9/30/2014 43 43 37 10/16/2014 12 12 37 10/16/2014 47 47 38 11/11/2014 13 13 38 11/11/2014 32 32 39 12/16/2014 14 14 39 12/16/2014 63 63 40 1/27/2015 12 12 40 1/27/2015 64 64 41 2/19/2015 12 12 41 2/19/2015 95 95 42 3/17/2015 12 12 42 3/17/2015 84 84 43 4/14/2016 12 12 43 4/14/2016 45 45 44 5/18/2015 14 14 44 5/18/2015 38 38 45 W312015 14 14 45 6/23/2015 52 52 46 7/16/2015 20 20 46 7/16/2015 36 36 47 8/18/2015 30 30 47 8/18/2015 40 40 48 9/15/2015 20 20 48 9/15/2015 60 60 49 10/30/2015 20 20 49 10/30/2015 29 29 50 11/17/2015 20 20 50 11/17/2015 16 16 51 1/12/2016 15 15 51 12/15/2015 25 25 52 2/10/2016 11 11 52 1/12/2016 35 35 53 53 2/10/2016 38 38 54 54 55 55 56 56 57 57 58 58 NCO088684 RPA 2015.xlsm, data - 1 - 4/14/2016 REASONABLE POTENTIAL ANALYSIS 18 Zinc (AL) Use "PASTE SPECIAL Values" then "COPY" 19 Turbidity. Use"PASTE SPECIAL Values" then "COPY" . Maximum data points = 58 Maximum data points = 58 Date Data BOL=112DL Results Date Data BDL=112DL Results 1 10/14/2011 960 960 Std Dev. 304.9553 1 10/16/2012 0.28 0.28 Std Dev. 1.2405 2 11/16/2011 987 987 Mean 517.4245 2 11115/2012 0.35 0.35 Mean 0.5041 3 12/13/2011 826 826 C.V. 0.5894 3 12/1112012 0.15 0.15 C.V. 2.4609 4 1/11/2012 147 147 IT 53 4 1/8/2013 0.00 0.06 n 39 5 2/14/2012 834 834 5 2/5/2013 0.16 0.16 6 3/13/2012 594 594 Mult Factor = 1.03 6 3/12/2013 0.33 0.33 Mult Factor = 1.32 7 4/10/2012 788 788 Max. Value 1242.0 ug/L 7 4/9/2013 0.07 0.07 Max. Value 6.4 NTU 8 5/11/2012 837 837 Max. Pred Cw 1279.3 ug/L 8 5/10/2013 0.15 0.15 Max. Pred Cw 8.4 NTU 9 6/12/2012 749 749 9 6/4/2013 0.08 0.08 10 7117/2012 702 702 10 7/9/2013 0.05 0.05 11 8/1012012 607 607 11 8/6/2013 0.06 0.06 12 9/11/2012 641 641 12 9/10/2013 4.1 4.1 13 10/16/2012 78.5 78.5 13 10/8/2013 0.05 0.05 14 11/15/2012 718 718 14 11/5/2013 0.06 0.06 15 12/11/2012 677 677 15 12/3/2013 2.5 2.5 16 1/8/2013 682 682 16 1/14/2014 0.17 0.17 17 2/5/2013 674 674 17 2/18/2014 0.47 0.47 18 3/12/2013 632 632 18 3/18/2014 0.07 0.07 19 4/9/2013 645 645 19 4/15/2014 0.02 0.02 20 6/10/2013 739 739 20 5/19/2014 0.09 0.09 21 6/4/2013 600 600 - 21 6/10/2014 0.05 0.05 22 7/9/2013 621 621 22 7115/2014 0.14 0.14 23 8/6/2013 484 484 23 8114/2014 0.49 0.49 24 9/10/2013 639 639 24 9130/2014 0.02 0.02 25 10/8/2013 554 554 25 10/16/2014 0.14 0.14 26 11/5/2013 604 604 26 11/11/2014 0.03 0.03 27 12/3/2013 710 710 27 12/16/2014 0.1 0.1 28 1/14/2014 649 649 28 1/27/2015 0.33 0.33 29 2/18/2014 740 740 29 2/19/2015 0.05 0.05 30 3/18/2014 653 653 30 3/17/2016 0.12 0.12 31 4/15/2014 592 592 31 4/14/2015 0.04 0.04 32 5/19/2014 501 501 32 33 6/10/2014 519 519 33 34 7/15/2014 441 441 34 7/16/2015 0.1 0.1 35 8/14/2014 98 98 35 8/18/2015 0.1 0.05 36 9/30/2014 135 135 36 9/15/2015 6.4 6.4 37 10/16/2014 104 104 37 10/30/2015 1.78 1.78 38 11/11/2014 98 98 38 11/17/2015 0.24 0.24 39 12/16/2014 345 345 39 12/15/2015 0.13 0.13 40 1/27/2015 389 389 40 1/12/2016 0.03 0.03 41 2/19/2015 983 983 41 2/10/2016 0.15 0.15 42 3/17/2015 1242 1242 42 43 4/14/2015 273 273 43 44 5/18/2015 84 84 44 45 6/23/2015 183 183 45 46 7116/2015 933 933 46 47 8/18/2015 105 105 47 48 9/15/2015 289 289 48 49 10/30/2015 70 70 49 50 11/17/2015 38 38 50 51 12/15/2015 41 41 51 52 1/12/2016 51 51 52 53 2/10/2016 138 138 53 54 54 55 55 56 56 57 57 58 58 NCO088684 RPA 2015.xism. data -2- 4/14/2016 REASONABLE POTENTIAL ANALYSIS 20 Total Dissolved Solids Use "PASTE SPECIAL Values"then"COPY" . Maximum data Wall is Date Data BDL=1/2DL Results 1 10/14/2011 263 283 Std Dev. 77.2564 2 11/16/2011 300 300 Mean 306.7358 3 12/13/2011 307 307 C.V. 0.2519 4 1/11/2012 135 135 n 53 5 2/14/2012 288 288 6 3/13/2012 286 286 Mult Factor = 1.01 7 4/10/2012 274 274 Max Value 6180 mg/L 8 5/11/2012 288 288 Max. Fred Cw 624.2 mglL 9 6/12/2012 279 279 10 7/17/2012 288 288 11 8/10/2012 286 286 12 9/11/2012 312 312 13 10116/2012 96 96 14 11/15/2012 279 279 15 12/11/2012 260 260 16 1/8/2013 320 320 17 2/5/2013 290 290 18 3/12/2013 112 112 19 4/9/2013 276 276 20 6/10/2013 270 270 21 6/4/2013 318 318 22 7/912013 291 291 23 8/6/2013 286 286 24 9/10/2013 319 319 25 10/8/2013 301 301 26 11/5/2013 285 285 27 1213/2013 309 309 28 1114/2014 228 228 29 2/18/2014 276 276 30 3/18/2014 346 346 31 4/15/2014 288 288 32 5/19/2014 278 278 33 6/10/2014 300 300 34 7/15/2014 279 279 35 8/1412014 618 618 36 9/30/2014 332 332 37 10/16/2014 301 301 38 11/11/2014 364 364 39 12116/2014 343 343 40 1/27/2015 366 366 41 2/19/2015 304 304 42 3/17/2016 390 390 43 4/14/2015 347 347 44 5/18/2015 360 360 45 6/23/2015 399 399 46 7/16/2015 423 423 47 8/18/2015 379 379 48 9/15/2015 319 319 49 10130/2015 369 369 50 11/17/2015 224 224 51 12/15/2016 419 419 52 1/12/2016 393 393 53 2/10/2016 274 274 54 55 56 57 58 NC0088684 RPA 2015.xlsm, data - 3 - 4/14/2016 2014 Freshwater RPA - 95% Probability/95% Confidence MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY Table 1. Project Information ❑CHECK IF HQW OR ORW WQS Facility Name W WTP/WTP Class NPDES Permit Outfall Flow, Qw, (MGD) Receiving Stream Stream Class 7Q10s (cfs) 7Q10w lots) 30Q2 (cfs) CIA (cfs) 1Q10s (cfs) Data Source(s) ❑CHECK TO APPLY MODEL Daniel Stowe Botanical Garden WTP Not Rated NCO088684 001 0.004 Catawba River (Lake Wylie) WS-V, B 0.00 0.00 0.00 0.00 0.00 BIMS Sep201 1 -Feb2016 Follow directions for dataf: j'In some cases a comment menu list the availa6le choices or a dropdown menu will provide a list you may select from. Error message occur if data entry does not meet input criteria. Par01 Par02 Par03 Par04 3 Paris Par06 Par07 Fares Par09 Par10 Parl1 Par12 Par13 Pi Paris Par16 Par17 Pails Par19 Par20 Par21 Par22 Table 2. Parameters of Concern Name Type Chronic Modifier Acute PQL a Units Copper (AL) NCO088684 RPA 2015.xlsm, input 4/14/2016 File Edit Wew Bookmarks Insert Selection Geoprocessing Customize Windows Help Drawing -LOCI • - A . 01 Anal - 14 B I U A - of - -0 - • � � Georeferencing• Labeling 6 •ti '{1 , ;j '.i1 -x Iart F.. - 1 L-�I10®� ; Editor - 1 -�v �8Od r ±._ 1:1.0co - f !❑r.7QQ(EL Q?" 0 rR�w able Of Contents x D ❑ LRS_Arcs — Interstate — US Highway -- Blue Ridge Parkway - - NC Highway — State Road, Other, Ramp D ® LRSAres Interstate US Highway Blue Ridge Parkway NC Highway State Road, Other, Ramp 0 0 hydro24k arc — <all other values> D ❑ Subbasin+r_hydro24k_arc E E7 ® Area_gm Comment QNC0021857 If; ❑ hydro24kpoly ; m ❑ Imagery_Orthoimagery_Late Ill NC Surface WaterClassificat p ❑ 12Digrt HUC Subwatersheds * ❑ LRS Arcs p ❑ County Boundaries p 0 County Parcels B ❑ Avery D ❑ TRANSYLVANIA 171 B ❑ Henderson p ❑ Buncombe p ❑ Madison O ❑ Wake B ❑ MECKLENBURG B 0 = 0 e ❑ BEAUFORT B ❑ BLADEN rl m s � �J/ rent 0 1 c n •• :�' �] 11 NCOo88884 L9 R� n ® o :6 J STOWE 0 18"W °10'3" 8103'16" S Nev; hov- %d, j 2,8m 222 m \y nit f.154 __ r Daniel Strwe Botanical q Garden t q, s� l V01011, 010 IS n f;y O..•]lt r. d m 12-Digit HUC (Subwatershed) 12-Digit Name: Catawba Creek 12-Digit Code: 030501011502 10-Digit Name: Lake Wylie -Catawba River 10-Digit Code: 0305010115 8-Digit Code: 03050101 River Basin: Catawba 12-Digit Area (ac): 20,678.00 Zoom to City of Chat �1 J �M ti J x ilRUR�� i. HERE, DeLorme, INCREMENT R It J - — «ar ' `'IRS' -'� � �-` � , •�' \ 1 _ I. 0-4 S _ Surface Water Classification t 1 � 5y �t Stream Index: 11-(123.5) I Stream Name: CATAWBA RIVER (Lake Wylie below elevation t '_ 570) North Carolina portion p Description: From the upstream 1 side of Paw Creek Arm I ., of Lake Wylie to North Carolina-South;,•lJ Carolina State Line Classification: WS-V,B Classification August 2, 1992 Date: �. River Basin: Catawba U - � `. - :{0 L'IF C.1!uLitia—'' — _ �.. 'v•"^ ,uh�« a..,•� «t,:� nn...,, ,...., � �" . I• �77 = Zoom to r• Surface Water Classification OUu 0111111UCA. 11'1JV ? . Stream Name: Catawba Creek r Description: From source to Lake Wylie, Catawba River Classification: C ''"'` Classification Date: October 31, 1985 River Basin: Catawba What does this More info Class. Mean? c ` - Zoom to 1 E 1. Daniel Slawe N Bolanic-3l 2 m ' = O = -.,'.*of Charlotte, State of North Carolina DOT Esri HERE DeLorme IN /77 Permit Reviewer Notes - Derek Denard Permit Number: vo Pp G�' Applicant/Facility Name: �� Dom; fob 4 4. �-e ohs« v Permit Status: Regional Office: Latitude: 7� 1v�717 Longitude: PI. Facility Class: �C/�G County: s�o Outfall: 1 Flow: Applica t ASldress: �� X) vo Facility Address: Type of Waste: c V �, r Stream Notes Receiving Stream: �_ rill -/ V C wt 4, 1r Ile V )e,1, r Stream Segment: Stream Classification: Drainage Basin: L Summer 7Q10 (cfs): Subbasin: G J O 7 Winter 7Q10 (cfs): O HUC Code: 30Q2 (cfs): c� to Grid: J ti� Average Flow (cfs): O USGS Top u IWC C t7b/ L b 1 , 303 d): �e1Wl �Cni"r Use* 4— /J 4 li3si Notes 111e, � c �y r�Clc PUBLIC NOTICE North Carolina Environmental Management Commission/ NPDES Unit 1617 Mail Service Center Raleigh, NC 27699.1617 Notice of Intent to Issue a NPDES Wastewater Permit AFFIDAVIT OF INSERTION OF ADVERTISMENT The Gaston Gazette Gastonia, N.C. Gaston County The Gaston Gazette does certify that the advertisement for: The North Carolina Envi- PUBLIC NOTICE North Carolina Environmental Management Commission/ NPDES Unit ronmental Management Commission ro oses to 1617 Mail Service I:6, V/ e- __ wa er disc forge pane o — --- the person(s) listed below. Written comments regard - In g the proposed permit will be accepted until 30 Measuring 9.63 inches appeared in The Gaston Gazette, a newspaper published in days after the puNish date Gaston County, Gastonia, N.C., in issue(s): of this The Director of the Division of Water C Division rc Resources (DWR) may hold a public hearing should there be a signer- cant degree of public inter- 02/09/2016. est. Please mall comments and/or information re- quests to DWR at the above amInterested persons ay visit the DWR mayvisit at 512 Salisbury Street, Raleigh,, NC to review in- on file. AdditionalES formatinform information on information of NPDES permits and this notice mayy be found on our we site: h1limt/portal .a by calling (919) 807-6304. The Daniel Jonathan Stowe Conservancy re- 80ew Pof NPDES sted renewal ermt Name of Account: NCDENR/DWQ/NPDES NCO088WDaniel o for the StoweBGarden Order Number: 54571919 this permiGaston ci discharrge is Ad Number: 54681030 reverse osmosis reject water to an unnamed trib- utary to Catawba Greek in the Catawba River Basin. Sworn to, and subscribed before me this 18 th day of March, 2016. Solvay USA Inc. requested renewal of permit NCO084638 for Gastonia ` County Nis permitted \�Ipllllllllllll/I//ll 0�� . r ^ n. )iivv dis- c harge is ireatetl GWR / IRA� wastewater to an UT. of Crowders Creek, in the Ca- tawba River Basin. d ?n I OljaRY Textron, Inc., 3800 Little Mtn. Rd, Gastonia, applied =r- � E e� / 4 C p' to renew NPDES permit NCO084622 discharging treated wastewater toaUT - Lisa yble, Notary Public to Crowders Creek, Ca- tawba River Basin, Gaston 'rllllll1111�1�j1 pllh��\`\` County. - IC -February 9, 2016. My Commission Expires April 25, 2017 Text GS571919 to 56654 Denard, Derek Pe;- ov?f flee C49'-�7,�e a /5 From: Peter Grimaldi <grimaldi@dsbg.org> Sent: Tuesday, March 15, 2016 9:33 AM To: Denard, Derek Cc: Christine Cordy, Basinger, Corey; Tuvia, Ori A; Bell, Wes Subject: Re: Changes to Draft permit NCO088684 Daniel Stowe Botanical Garden WTP Good morning Derek. The Garden does not have any comments on the updates to our draft NPDES permit, thank you. Please advise on when the new permit will be issued and monitoring parameters can change. Thanks again and we look forward to hearing from you. Peter Grimaldi Director of Horticulture, Facilities and Grounds 704.813.9106 Sent from my iPhone On Feb 29, 2016, at 11:58 AM, Denard, Derek <derek.denard@ncdenr.gov> wrote: Please find the following updates to permit N00088684 for Daniel Stowe Botanical Garden WTP as drafted on October 21, 2015.: • updated stream inform an unnamed tributary to Catawba River (Lake Wylie) [Stream Segment 11- (123.5)] classified WS-V, B waters (the previous permit and BIMS database indicated that the stream was Catawba Creek [Stream Segment 11-130] classified C waters which was incorrect) • updated the facility map • the coordinates for the Outfall 001 were adjusted to the following: Latitude: 35° 10' 13" Longitude: -81° 03' 18" • updated footnote 1 in Section A. (1.): Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. See Special Condition A. (4.). • updated Special Condition A. (4.) for electronic reporting of monitoring reports. If you have any comments, please provide them to me via email [derek.denard@ncdenr.sov] or write to my attention care of DEQ/ DWR/ NPDES Program no later than March 27, 2016. Sincerely, Derek Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard(o)ncden r.aov N. C. Division of Water Resources WQ Permitting Section — Wastewater Branch 1617 Mail Service Center Raleigh, NC 27699-1617 <irnage002.png> Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. <NC0088684 Permit Cover Final 2016.pdf> <NC0088684 Permit & Eff 2016.pdf> <NC00888684 map.pdf> <NC0088684 Fact Sheet 2016.pdf> Denard, Derek From: Denard, Derek Sent: Monday, February 29, 2016 12:17 PM To: Meadows, Susan; Moore, Cindy; Kinney, Maureen Subject: FW: Changes to Draft permit NC0088684 Daniel Stowe Botanical Garden WTP Attachments: NC0088684 Permit Cover Final 2016.pdf; NC0088684 Permit & Eff 2016.pdf; NC00888684 map.pdf; NC0088684 Fact Sheet 2016.pdf FYI From: Denard, Derek Sent: Monday, February 29, 2016 11:58 AM To: 'grimaldi@dsbg.org'<grimaldi@dsbg.org>;'cordy@dsbg.org' <cordy@dsbg.org> Cc: Basinger, Corey <corey.basinger@ncdenr.gov>; Tuvia, Ori A <ori.tuvia@ncdenr.gov>; Bell, Wes <wes. bel I @ ncdenr.gov> Subject: Changes to Draft permit NC0088684 Daniel Stowe Botanical Garden WTP Please find the following updates to permit NC0088684 for Daniel Stowe Botanical Garden WTP as drafted on October 21, 2015.: • updated stream inform an unnamed tributary to Catawba River (Lake Wylie) [Stream Segment 11-(123.5)] classified WS-V, B waters (the previous permit and BIMS database indicated that the stream was Catawba Creek [Stream Segment 11-130] classified C waters which was incorrect) • updated the facility map • the coordinates for the Outfall 001 were adjusted to the following: Latitude: 35° 10' 13" Longitude: -81° 03' 18" • updated footnote 1 in Section A. (1.): Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. See Special Condition A. (4.). • updated Special Condition A. (4.) for electronic reporting of monitoring reports. If you have any comments, please provide them to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ / DWR / NPDES Program no later than March 27, 2026. Sincerely, Derek Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard aC)ncdenr.00v N. C. Division of Water Resources WQ Permitting Section — Wastewater Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Denard, Derek From: Christine Cordy <cordy@dsbg.org> Sent: Tuesday, February 02, 2016 12:55 PM To: Denard, Derek; Rodman, Diane Cc: wioleta@kwlaboratories.com; Kara Newport; Chris Gardner; Peter Grimaldi Subject: RE: DSBG Effluent Report - Nov 2015 Follow Up Flag: Follow Up Due By: Tuesday, February 02, 2016 1:25 PM Flag Status: Flagged Derek, Thank you for your response. You are correct, we have been submitting email copies to Diane since October 2014 with no issues. We will take your submission guidance and I will send the November and December 2015 originals via certified mail to the mail service center address and continue to do so until the EPA CORMER signature is available. We thank you in advance for working on a retraction for November 2015. Regarding the NPDES permit NC0088684, I have been in contact with Kevin Bowden, Environmental Senior Specialist- N.C. Division of Water Resources. We have cut check number 3269 in the amount of $860.00 and will be remitting payment to DCDEQ at the 1617 Mail Service Center, Raleigh address today. Thank you for your assistance in these matters. Best Regards, Christine Cordy Executive Assistant cordy@DSBG.ors D 704-829-1290 Website I Facebook I Twitter I Pinterest I Private Events Daniel Stowe Botanical Garden 6500 South New Hope Road I Belmont, NC 280121704-825-4490 Experience Art & Orchids daily from January 22 through March 121 From: Denard, Derek [mailto:derek.denard@ncdenr.gov] Sent: Tuesday, February 02, 2016 11:38 AM To: Rodman, Diane <diane.rodman@ncdenr.gov>; Christine Cordy <cordy@dsbg.org> Cc: wioleta@kwlaboratories.com; Kara Newport <newport@dsbg.org>; Chris Gardner <gardner@dsbg.org>; Peter Grimaldi <grimaldi@dsbg.org> Subject: Re: DSBG Effluent Report - Nov 2015 Christine, From what I understood from the e-mail conversation is that you have been submitting DMRs by eDMR and have been e- mailing copies to Diane. We still require original "wet" signature hard copies to be sent to central files (the mail service center address) until the EPA approves North Carolina's application for the CROMER compliant electronic signature. I do not believe that e-mailing your hard copy to anyone with the Division meets the legal signature requirement because it is a copy of an original. I don't believe sending DMRs to one person is the best way to insure that the DMR is being receiving since one person can not always be available. Suppose that person is on leave for an extend period of time. Please send hard copies as the permit standard conditions, DMR form instructions and eDMR guidance requires to the Mail Service Center address so that multiple staff can insure that it is processed and entered into our database. I do realize there is potential for the mail to be lost or the DMR to be misfiled. Until the EPA CORMER signature is available, the only way to insure that we have received a DMR is by certified mail. I will work on a retraction for the NOV. If you have not done so, but please file a original signed copy for the record. Another matter I would like to address is that we have not received payment for last years annual fee (invoice 2015PR0I1817). The permit renewal for NPDES permit NC0088684 can not be processed until we receive this payment. If you have record that you sent payment or have recently sent it, please let me know and I can follow-up. Sincerely, Derek Denard Environmental Specialist N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek. dena rd O. ncden r. aov 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Rodman, Diane Sent: Monday, February 1, 2016 2:39 PM To: Christine Cordy; Denard, Derek Cc: wioleta@kwlaboratories.com; Kara Newport; Chris Gardner; Peter Grimaldi Subject: RE: DSBG Effluent Report - Nov 2015 Christine, We realize you understand the timeline and have been very prompt. Derek, please verify if can continue accept the email copies only. I believe, and Christine, correct me if my comments are not factual, one of the reports did not arrive in a timely manner one time, probably just wasn't received in Central Files, and Ms. Cordy began to send the reports by email to ensure we have received them and was sending the hard copies too. This became confusing at Central files, especially since we receive many of the facilities' reports the same day. We did inform Ms. Cordy we would accept the email copies and it wouldn't be necessary to send the hard copies. May we continue to follow this procedure? Diane From: Christine Cordy [mailto:cordy@dsbg.org] Sent: Monday, February 01, 2016 2:30 PM To: Rodman, Diane <diane.rodman@ncdenr.gov> Cc: wioleta@kwlaboratories.com; Kara Newport <newport@dsbg.org>; Chris Gardner <gardner@dsbg.org>; Peter Grimaldi <grimaldi@dsbg.org>; Denard, Derek <derek.denard@ncdenr.gov> Subject: RE: DSBG Effluent Report - Nov 2015 Hi Diane, Thanks for your help. Please confirm we understand the timeline for submitting reports (the monthly report needs to be submitted no later than the last calendar day following the reporting period) and also confirm we no longer need to send in hard copies. Thanks again, Christine Cordy Executive Assistant cordv@DSBG.org D 704-829-1290 Website I Facebook I Twitter I Pinteres I Private Events Daniel Stowe Botanical Garden 6500 South New Hope Road I Belmont, NC 28012 1 704-825-4490 Experience Art & Orchids daily from January 22 through March 121 From: Rodman, Diane [mailto:diane.rodman@ncdenr.gov] Sent: Monday, February 01, 2016 2:23 PM To: Christine Cordy <cordv@dsbg.org> Cc: wioleta@kwiaboratories.com; Kara Newport <newport@dsbg.org>; Chris Gardner <gardner@dsbg.org>; Peter Grimaldi <grimaldi@dsbg.org>; Denard, Derek <derek.denard@ncdenr.gov> Subject: RE: DSBG Effluent Report - Nov 2015 Dear Ms. Cordy, I apologize. You did send this by email and I was also waiting for the hard copy you usually send. I am not sure what happened in this situation. I will back date November's eDMR to the original date it was emailed. Diane Diane Rodman Office Assistant Division of Water Resources North Carolina Department of Environmental Quality 919 807 6306 office diane. rodman(a)ncdenr.gov 512 N Salisbury Street 1617 Mail Service Center Raleigh, NC 27699-1617 W. !"Nothing 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: Christine Cordy [mailto:cordv@dsbg.org] Sent: Monday, February 01, 2016 2:16 PM To: Rodman, Diane <diane.rodman@ncdenr.gov> Cc: wioleta@kwlaboratories.com; Kara Newport <newoort@dsba.org>; Peter Grimaldi <grimaldi@dsbg.org>; Chris Gardner <gardner@dsbg.org>; Denard, Derek <derek.denard@ncdenr.gov> Subject: FW: DSBG Effluent Report - Nov 2015 Hi Diane, We received a certified letter (attached) today from NC Water Resources stating we did not submit our Nov 2015 report in a timely manner. As you can see from the emails below, we received the Nov report from K&W on Wed 12/23/15 at 5:36pm, we submitted that Report to you on Thurs 12/24/15 at 11:29am, and we received your'thank you' on 12/28/15 at 7:56am. It's our understanding the monthly report needs to be submitted no later than the last calendar day following the reporting period, and therefore we did submit November's report within the required timeframe. It is also our understanding since we are submitting these reports on line, it is not a requirement to mail hard copies. If we have the time line wrong or if we need to still submit hard copies, please advise. We take this letter very seriously and are unsure of where the breakdown was on this particular reporting submission as we met the state's requirement. If you could shed some light on this, we would appreciate it. Please note Reports from Nov and Dec 2015 are attached; Dec was submitted to you 1/13/16. Thanks in advance for your help in this matter. Best Regards, Christine Cordy Executive Assistant cordv@DSBG.ore D 704-829-1290 Website I Facebook I Twitter I Pinterest I Private Events Daniel Stowe Botanical Garden 6500 South New Hope Road I Belmont, NC 28012 1 704-825-4490 Experience Art & Orchids daily from January 22 through March 121 From: Rodman, Diane [mailto:diane.rodman@ncdenr.¢ovl Sent: Monday, December 28, 2015 7:56 AM To: Christine Cordy <cordv@dsbg.ors> Subject: RE: DSBG Effluent Report - Nov 2015 Thank you, Dlane From: Christine Cordy [mailto:cordv@dsbg.org Sent: Thursday, December 24, 2015 11:29 AM To: Rodman, Diane <diane.rodman@ncdenr.eov> Subject: DSBG Effluent Report - Nov 2015 Diane, Attached please find DSBG's Effluent Report for Nov 2015. Happy Holidays!! Best Regards, Christine Cordy Executive Assistant cordv@DSBG.ore D 704-829-1290 Website I Facebook I Twitter I Pinterest (Private Events Daniel Stowe Botanical Garden 6500 South New Hope Road I Belmont, NC 280121704-825-4490 Experience Holidays at the Garden from November 20 through January 31 -----Original Message ----- From: wioleta@kwlaboratories.com[mailto:wioleta@kwlaboratories.coml Sent: Wednesday, December 23, 2015 5:36 PM To: Peter Grimaldi <grimaldi@dsbe.ore>; Christine Cordy <cordv@dsba.ore> Cc: Chris Gardner <gardner@dsba.ore> Subject: K&W Laboratories _Nov DMR and Reports Thank you very much. Merry Christmas! Kindly, PAT MCCRORY Governor DONALD R. VAN DER VAART Water Resources ENVIRONMENTAL QUALITY Secretary S. JAY ZIMMERMAN Director February 29, 2016 MEMORANDUM To: Keri B. Cantrell, PhD, PE Engineer (DWR/PWSS) Mooresville Regional Office From: Derek C. Denard DWR / NPDES Program 919-807-6307; Fax 919-807-6495; derek.denard@ncdenr.gov Subject: Review of Discharge to Surface Waters Designated Water Supply (WS) • unnamed tributary to Catawba River (Lake Wylie) [11-(123.5)], WS-IV, B, Catawba River Basin; • renewal of Individual NPDES Permit for Reverse Osmosis Membrane Technology WTP for: NPDES NCO088684 Daniel Johnathan Stowe Conservancy/Daniel Stowe Botanical Garden WTP located at 6500 South New Hope Rd, Belmont, NC 28012 Gaston County Please provide your comments by March 27, 2016 [email OK] RESPONSE: X_ I have reviewed the draft permit and determined that the proposed discharge is not located sufficiently close to any existing or known proposed public water supply intake (_miles) so as to create an adverse effect on water quality. The DWR concurs with the issuance of this permit provided the Permittee properly operates and maintains the facility; the Permittee meets the stated effluent limits prior to discharge; and the discharge does not contravene the designated water quality standards. I concur with issuance of the above permit provided the following conditions are met: I oppose the issuance of the above permit based on reasons stated below, or attached: Signed: /�¢ a. _ _ _ Date: 2/29/2016 cc: file 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Phone: 919-807-63001 Internet: www.ncwaterquality.org An Equal Opportunity 1 Affumative Action Employer — Made in part by recycled paper X, ` NPDES PERMIT APPLICATION - SHORT FORM C - WTP For discharges associated with water treatment plants Mail the complete application to: N. C. Department of Environment and Natural Resources Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1627 NPDES Permit Number INCO088684 I If you are completing this form in computer use the TAB key or the up — down arrows to move from one field to the next. To check the boxes, click your mouse. on top of the box. Otherwise, please print or type. 1. Contact Information: Owner Name Facility Name Mailing Address City State / Zip Code Telephone Number Fax Number e-mail Address Daniel Jonathan Stowe Conservancy WR Daniel Stowe Botanical Garden 6500 South New Hope Road Belmont Water Qua . r, .Ong S n' NC 28012 (704) 829-1282 (704) 829-1240 animaldi(aldsbg oxy 2. Location of facility producing discharge: Check here if same as above ED Street Address or State Road City 1 State / Zip Code County 3. Operator Information: Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the Operator in Responsible Charge or ORQ Name N/A Mailing Address City State / Zip Code Telephone Number ( ) Fax Number ( ) 4. Ownership Status: Federal ❑ State ❑ Private Public ❑ Pagel of 3 Version 5/2012 NPDES PERMIT APPLICATION - SHORT FORM C - WTP For discharges associated with water treatment plants S. Type of treatment plant: ❑ Conventional (Includes coagulation, flocculation, and sedimentation, usually followed by filtration and disinfection) ❑ Ion Exchange (Sodium Cycle Cationic ion exchange) ❑ Green Sand Filter (No sodium recharge) to Membrane Technology (RO, nanofiltration) Check here if the treatment process also uses a water softener 6. Description of source water(s) (i.e. groundwater, surface water) Well water 7. Describe the treatment process(es) for the raw water. The raw water passes through a water softener and is then purified by a reverse osmosis system. The purified water is used for irrigation and also supplies a high pressure misting system inside a conservatory. S. Describe the wastewater and the treatment process(es) for wastewater generated by the facility: The characteristics of the wastewater have been well -documented over the ten years in which the existing NPDES discharge permit has been maintained in good standing. The wastewater is ultimately delivered to a nearby creek via underground storm drainage. 9. Number of separate discharge points: 1 Outfall Identification number(s) 001. 10. Frequency of discharge: Continuous ❑ Intermittent If intermittent: Days per week discharge occurs: seven Duration: 4 hours 11. Plant design potable flowrate 0.00056 MGD Backwash or reject now 0.00029 MGD 12. Name of receiving stream(s) (Provide a map showing the exact location of each outfaA including latitude and longitudet UT Catawba Creek 13. Please list all water treatment additives, including cleaning chemicals or disinfection treatments, that have the potential to be discharged. Alum / aluminum sulfate Yes No X Page 2 of 3 Version 5/2012 ' NPDES PERMIT APPLICATION - SHORT FORM C - WTP For discharges associated with water treatment plants Iron sulfate / ferrous sulfate Yes No X Fluoride Yes No X Ammonia nitrogen / Chloramines Yes No X Zinc -orthophosphate or sweetwater CP1236 Yes No X List any other additives below: 14. Is this facility located on Indian country? (check one) Yes ❑ No 15. Additional Information: D Provide a schematic of flow through the facility, include flow volumes at all points in the water treatment process. The plan should show the points] of addition for chemicals and all discharges routed to an outfall [including stormwater]. D Solids Handling Plan 16. NEW Applicants Information needed in addition to items 1-15: New applicants are highly encouraged to contact a permit coordinator with the NCDENR Customer Service Center. Was the Customer Service Center contacted? ❑ Yes ® No Analyses of source water collected Engineering Alternative Analysis Discharges from Ion Exchange and Reverse Osmosis plants shall be evaluated using a water quality model. 17. Applicant Certification I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. Clk- ' w'h►NSC.._ e of Person Signing Title An ' t Date North8na Gen tote 143-215.6 (bX2) provlees that Any person who knowingly makes any fade slatern ent representatiat, or certification in any application, record, re an, or other document files or required to be malnt fined under Article 21 or regulations of the Environmental Management Commission Implementing that Ardde, or who falsities. tampers with, or knowingly renders Inawmte any recording or monibodq devlee or method required th be operated or mraktained wxferArtlCte 21 or regulations of the Envirommerttal Management Commission Implementing that Article, shall be guilty of a misdemeanor punishable by a One not to exceed $25,000, or by Imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a One of not more than $25,000 or Imprisonment not more than 5 years, or both, for a sUnDar offense.) Page 3 of 3 Version 5/2012 NPDES Permit NCO088684 Daniel Stowe Botanical Garden Schematic of Flow RAW WATER SUPPLY 3.8 GPM WATER SOFTENER 3.8 GPM 1'6 RO PRODUCT RO SYSTEM J 2.5 GPM to SERVICE 3.8 GPM FEEDWATER s 0 1 � RO REJECT 1.3 GPM to STORM* *RO Reject water flows through —500LF of storm drain before introduction to surface water at outfall. February 25, 2015 From: Peter Grimaldi Director of Horticulture Daniel Stowe Botanical Garden 6500 South New Hope Road Belmont, NC 28012 To: N.C. Department of Environmental and Natural Resources Division of Water Quality / NPDES Unit 1617 Mail Service Center Raleigh, NC 27699,1617 To whom it may concern: Please accept the Garden's application to renew NPDES Permit No. NC0088684 via Short Form C — WTP, attached hereto along with the necessary supporting documentation. The reverse osmosis system at the Garden's Orchid Conservatory functions to purify the water supply for hand irrigation and a high pressure fog system that maintains proper humidity in the greenhouse. Well water supplies the purification system and wastewater is delivered to a nearby unnamed tributary of Catawba Creek via underground storm drainage. The Garden requests that two additional factors be considered in the permit review process including the recent establishment of a significantly reduced flowrate as well as the Garden's proposal to reduce monitoring frequencies while viable engineering alternatives are explored. A new flowmeter was installed, calibrated and commissioned on May 16, 2014 with the approval of NCDENR. The new flowmeter is installed directly off the RO system, whereas the original flowmeter was installed further downstream in the storm drain at a point after other storm water is introduced into the system. The average daily flow over the past eight months is 0.00029 MOD, whereas the existing permit acknowledges 0.003552 MGD. The original flowmeter and historical flow data associated with the permit in question capture an inflated flow volume that included water sources other than the RO reject water. The reduced actual flow has motivated the Garden to explore engineering alternatives, most especially the merits of a non -discharge permit to deliver wastewater to the ground surface via irrigation. . Engineering alternatives are desirable because the monitoring requirements established by the existing NPDES permit present a financial burden to the Garden, which hereby proposes that measurement frequencies across almost all parameters be considered for reduction. The Garden is bound to environmental stewardship by its very mission and remains committed to maintaining its NPDES permit in good standing, but wishes to identify cost -saving opportunities while engineering alternatives are explored. The historical data has remained mostly static and wastewater characteristics present a reasonably low potential to fluctuate and exceed environmental limitations. Reduced measurement frequencies will make permit compliance more manageable for the Garden without undermining the assurance that no environmental threat is created by the operation of the RO system. Please consider the aforementioned scenarios along with our permit application and notify the Garden if any additional information is required. Director of Horticulture 2