NC0047279_Engineering Alternatives Analysis_20050428

Pc00 yYz7f
/1 Au►x,�
Tingen Environmental Company
217 Clyde Pearce Road
Zebulon, NC 27597
919-404-2143
April 28, 2005
NCDENR-DWQ
NPDES Unit
1617 Mail Service Center
Raleigh NC 27699-1617
Subject: Engineering Alternatives Analysis
Heritage Meadows WWTP
Dear NPDES Unit:
(MAY 3 2005
WT WATER -" x
'DINT SOURCE BRANCH i
Please find enclosed a response to the Division's request for an EAA, due April 30,
2005.
If you should have any questions, please contact me or Charles Bradshaw.
Sincerely,
Mary Amanda Tingen
ORC
cc: file
Charles Bradshaw
Shannon Langley, RRO
I
MAY 2 2005
DEHR - WAIER DiDLITY
POINT SOWiCE BRANCH

Response to Request for
Engineeering Alternatives Analysis
Heritage Meadows WWTP, NCO047279
Background
The Engineering Alternatives Analysis was originally requested by the Division some
years ago and was inadvertently left out of the permit renewal. The EAA was again
requested in the October 13, 2004 NPDES Permit Issuance cover letter. It is
understood this request is in response to non-compliance issues from the previous
permit period (1999-2004). For the past two and one half years these non-compliance
issues have been addressed and resolved, exclusive of minor violations. In addition, all
fines and debts for previous violations owed by C & J Bradshaw, LLC, have been paid.
This summary will show that there is no alternative for wastewater disposal.
Facility: Long Term Care Facility (Renovated Private School)
Housing for owner and staff
Capacity: 88 persons, including surrounding dwellings
Land: 6.5 acres, including wellhouse, 4 mobile homes and the
WWTP. Land on the north side of the property is owned
by Thomas Currin and by Robert Shoffler on the southeast
side. Highway 96 occupies the western -most border. The
properties are not available for purchase.
Proximity of Munipalities: The closest municipal sewerage system is the City of
Oxford, approximately 8 miles from the facility. Of course
a lift station/force main would be installed to carry the
wastewater to the municipality. The cost to construct these
would be enormous.
Possibility of Spray irrigation/Subsurface System:
There is not sufficient property to meet the distance
requirements with regards to dwellings and water supply.
Summary
It is apparent there is no alternative to operation of the current Wastewater Treatment
facilities at Heritage Meadows Long Term Care Facility. Please note that the plant is
capable of being operated sufficiently to meet all NPDES permit limits. In addition,
improvements to the WWTP's structure and operations are ongoing.

21 North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
u uIi:►1 lu
TO: Karen Rust, NPDES Unit
Division of Water Quality
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 25 August 2009
SUBJECT: Permit Renewal for C&J Bradshaw LLC, Heritage Meadows W WTP, Granville County,
NPDES Permit No. NC0047279
Biologists with the North Carolina Wildlife Resources Commission have reviewed the subject
document. Our comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d), North
Carolina General Statutes (G.S. 113-131 et seq.), and North Carolina Administrative Code 15A NCAC
10I.0102.
C&J Bradshaw LLC has applied for a renewal of its NPDES permit to discharge treated
wastewater into an unnamed tributary to North Fork Tar River in the Tar -Pamlico River basin. There are
records for the federal and state endangered dwarf wedgemussel (Alasmidonta heterodon), the federal
species of concern and state significantly rare pinewoods shiner (Lythrurus matutinus), and the state
threatened creeper (Strophitus undulatus) in North Fork Tar River. The public notice indicates total
residual chlorine, ammonia -nitrogen and HOD are water quality limited.
Freshwater mussels are among the most sensitive aquatic organisms tested for impacts from
ammonia, and ammonia may be a significant limiting factor for unionids (Augspurger et al., 2003).
Augspurger et al. (2003) found that ammonia concentrations which may be protective of freshwater
mussels range from 0.3 to 1.0 mg/L total ammonia as N at pH 8.
We are concerned about impacts to dwarf wedgemussel and other listed species in North Fork Tar
River. Therefore, we offer the following recommendations to reduce impacts to aquatic resources.
1. If the W WTP uses chlorine systems for disinfection, these should be replaced by ultraviolet light
or ozone systems. Chlorine is acutely toxic to aquatic organisms and can form secondary
compounds that are detrimental to aquatic life. Valenti (2006) concluded the impact of long term
exposure to low doses of chlorine may impact juvenile mussels and reduce the chance of them
being recruited to the reproducing population.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
25 August 2009
Heritage Meadows WWTP
NPDES Permit No. NCO047279
2. If current ammonia limits exceed those listed above, we recommend a re-evaluation of the
ammonia limits based on the research discussed above and readjusting the limits. Please contact
Tom Augspurger with the U.S. Fish and Wildlife Service at [phone] for additional
information.
3. If not already in place, we suggest the installation of a stand-by power system.
Thank you for the opportunity to comment on this permit renewal. If we can be of further
assistance, please contact our office at [phone].
Literature cited
Augspurger, T., A. E. Keller, M. C. Black, W. G. Cope, and F. J. Dwyer. 2003. Derivation of water
quality guidance for protection of freshwater mussels (Unionidae) from ammonia exposure.
Environmental Toxicology and Chemistry 22(11):2569-2575.
Valenti, T.W., D.S. Cherry, R.J. Currie, R.J. Neves, J.W. Jones, R. Mair, and C.M. Kane. 2006. Chlorine
toxicity to early life stages of freshwater mussels (Bivalvia: Unionidae). Environmental
Toxicology and Chemistry, 25(9):2512-2518.
ec: Rob Nichols, WRC