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HomeMy WebLinkAboutNC0070408_More Information Received_20180215ENGINEERING ALTERNATIVE ANALYSIS REPORT CLEVON WOODS ASSOCIATES, LLC NPDES NCO070408 WATAUGA COUNTY, NORTH CAROLINA �'SE V 93 %•.; TR r cK 7(5 18 Prepared By: J. Patrick Warren, PE Warren Consulting & Design, PLLC 850 9th Ave NW Hickory, NC 28601 January, 2018 TABLE OF CONTENTS I. GENERAL INFORMATION II. ALTERNATIVES ANALYSIS M. PRESENT VALUE ANALYSIS IV. CONCLUSIONS AND RECOMMENDATIONS V. APPENDIX Figure 1 Area Map Exhibit 1 CWA Deeds Exhibit 2 Draft NPDES Permit Exhibit 3 Additional Information Request Exhibit 4 Local Government Review Form Exhibit 5 WWTP Site Plan Exhibit 6 CWA Master Plan Exhibit 7 Speedway Plat Exhibit 8 Vestpocket Plat Exhibit 9 Draft NPDES Discharge Limits Exhibit 10 Town of Boone Connection Exhibit 11 Watauga County Soils Map r- I. GENERAL INFORMATION A. INTRODUCTION Clevon Woods Associates, LLC (CWA) is a private North Carolina limited liability company based out of Boone, NC that currently owns 18 acres of highly desirable commercial and residential development property fronting on NC Highway 105 (a main artery leading from Boone to Linville and beyond), located north the intersection of NC Hwy 105 and Aldridge Rd (SR 1594) and a 0.576 acre tract adjacent to Aldridge Rd on the south side of NC Hwy 105 in the Foscoe Community, Watauga County, NC. The 18 acre tract is for a proposed mix use development and the 0.576 acre tract is to be used for a wastewater plant (WWTP) installation with outfall line to the Watauga River. The Watauga River is classified as a Class B High Quality Watershed Trout Waters at the discharge point. A NPDES Discharge Permit NCO070408 was originally issued through the North Carolina Department of Environmental Quality (NC DEQ) for a capacity of 35,000 gpd for the Art Plaza WWTP in 1987. A location map of the property and surrounding properties is shown in the Appendix as Figure l . The deeds for the 18 acre and 0.576 acre tracts are attached in the Appendix as Exhibit 1. The NPDES permit has been re -issued for the property every 5 years since 1987. A draft permit was issued on 9/20/17 by NC DEQ and is attached in the Appendix as Exhibit 2. A Request for Additional Information letter was issued by NC DEQ on 12/14/17 and is attached in the Appendix as Exhibit 3. In response to the letter, this Engineering Alternative Analysis (EAA) has been prepared. A Conditional Use Permit (CUP) was issued for the construction of a WWTP on the CWA 0.576 acre tract by the Watauga County Board of Adjustment on 9/25/17. A copy of the Local Government Review Form is attached in the Appendix as Exhibit 4. B. PROPOSED WWTP A previously permitted used 35,000 gpd WWTP (NC AC 0063789) was purchased for the project in 2016 and is being stored on the 0.576 acre tract. The plant is an extended aeration package plant with tertiary filters. The Authorization to Construct (ATC) application and plans will be submitted to NC DEQ by February 10, 2018 and will be installed after approval. The plant is scheduled to go online in late spring or early summer of 2018. The WWTP Site Plan Sheet C3 is attached in the Appendix as Exhibit 5. C. NEED FOR PROJECT The CWA property is proposed to be a mix of commercial and residential uses that will generate a high volume of wastewater. The anticipated uses and wastewater flows are shown in Section D. A copy of the CWA Master Plan boundary is attached in the Appendix as Exhibit 6. In 1986, CWA constructed and leased a gas service and convenience store on a 1.245 acre tract adjoining the CWA Development Tract. The 1.245 acre tract is situated at the corner of NC Hwy 105 and NCSR 1151, known as Seven Devils Road). In 2008, CWA sold the property to Amicus Investments, LLC, a subsidiary of WilcoHess. Amicus has since sold it to Speedway, LLC, the present owner and operator of the gas service and convenience store. The septic system r. providing waste disposal for the convenience store failed in 2015 and the property has since been operating under a temporary pump & haul permit for waste disposal. There is not sufficient usable land for septic field repair or construction of an alternate drain field. Speedway has indicated its need and commitment to the proposed WWTP project by contributing $125,000.00 toward its construction, and has placed $125,000 in escrow with a Boone attorney. A gravity sewerline is designed to tie the Speedway property into the WWTP when completed and operational. The existing wastewater flow is shown in Section D. A copy of the Wilco Hess (now Speedway) boundary survey is attached in the Appendix as Exhibit 7. Vestpocket Investments, LLC (VI) has an existing 40 seat restaurant across from the WWTP site on Aldridge Rd. Their septic field has also failed and there is not enough usable land for repair. The restaurant will tie into the plant after it comes online. The existing wastewater flow is shown in Section D. A copy of the VI boundary survey is attached in the Appendix as Exhibit 8. D. WASTEWATER FLOW PROJECTIONS Based on the proposed projects in the vicinity of the WWTP, a total wastewater flow of 35,000 gallons per day (GPD) is ultimately projected for these properties. A breakdown of the total flow is described below. All wastewater flows have been calculated according to the NC DEQ Administrative Code Section 15A NCAC 2H .0219. Proposed Flows 1. 60 residential connections X 3 bedrooms X 120 GPD per bedroom = 21,600 GPD 2. One (1) 15,000 square foot shopping center X 120 GPD/1,000 ft2 = 1,800 GPD 3. One (1) 40 seat restaurant X 40 GPD/seat = 1,600 GPD Existipg Flows 1. One (1) convenience store with four (4) water closets X 250 GPD/water closet = 1,000 gpd 2. One (1) 40 seat restaurant X 40 GPD/seat = 1,600 GPD Total Proposed and Existing Flow = 27,600 GPD Total w/ 1.25 Peak Factor = 27,600 GPD X 1.25 = 34,500 GPD According to the USGS, the 7Q 10 for the Watauga River at the proposed discharge point is approximately 2.0 cfs or 1.2 MGD. The proposed increase in wastewater flow will not exceed 50% of the 7Q10. E. NPDES PERMIT LIMITS The draft NPDES permit limits are attached in the Appendix as Exhibit 9. II. EVALUATION OF DISPOSAL ALTERNATIVES A. DESCRIPTION OF ALTERNATIVES This section of the report will evaluate several alternatives for the disposal of the treated wastewater. The following alternatives will be evaluated: A. Connection to a publicly owned treatment works (POTW) B. Drip or spray irrigation of treated effluent on land in area C. Wastewater Reuse D. Discharge to the Watauga River E. Disposal Combination B. ALTERNATIVES ANALYSIS A. Alternative A - Connection to the Town of Boone WWTP The Town of Boone WWTP is the closest municipal system, with an existing gravity sewerline 8 miles east of the CWA property. The proposed sewage transmission system would consist of two (2) sewage pump station(s) and 42,000 L.F. of 4-inch force main along N.C. Highway 105. The Town of Boone WWTP has a capacity of 5.0 MGD and currently receives an average daily flow of approximately 2.4 MGD. The estimated total project cost for Alternative A is $2,075,000.00. A detailed cost estimate is included at the end of this section. Additionally, Watauga County presently has a Water and Sewer Committee that has been studying the feasibility of water and sewer treatment facilities in select areas of the County over the past 15 years. According to Mr. Joe Furman, Watauga County Planning Director, there are no current or future plans to fund any regional water and/or sewer facilities in the Foscoe area. A plan of the connection to the Town of Boone is attached in the Appendix as Exhibit 10. B. Alternative B - Drip or Spray Irritation of Effluent Alternative B includes the construction of the WWTP, but instead of discharging to the Watuaga River, the treated effluent is applied to land in the area by either drip or spray irrigation. It should be noted that land application requires that the effluent be treated to tertiary limits. A review of the Watauga County soils map and characteristics of soils in the area reveal that the CWA tract has 2 distinct soil types. The lower area adjacent to NC Hwy 105 is a Cullasaja with 8% to 15% slope and the upper areas are Chestnut-Edneyville with 15% to 30% & 30% to 50% slope range. In conversations with Mr. Steve Price, RSS, with these types of soils in the area, a best case loading rate for the treated effluent is 0.045 gpd/SF. Utilizing this loading rate, 18 acres of effective area would be required for 35,000 gpd, not including setbacks. According to State regulations, a drip irrigation system requires 50 foot setbacks, and spray irrigation systems require 150 foot setbacks from property lines. Therefore, a drip irrigation system will be less costly than a spray irrigation system, and the remainder of this discussion will be pertaining to a drip irrigation system. A copy of the Watauga County Soils Map is attached in the Appendix as Exhibit 11. r-- r-- Utilizing the 50-feet setback requirement, a drip irrigation site would need to have a total area of approximately 20 acres for 35,000 gpd. The total amount of acreage will vary depending on the shape of the tract of land. The State regulations require a minimum of 30 day storage pond to hold the effluent during wet or freezing weather. An effluent pump station and force main will be needed to transmit the effluent to a drip irrigation site. The County soils map shows some suitable soil in the general area of the C WA tract, but portions of the land are developed and the amount of usable land is insufficient. For the purposes of this report, it will be assumed that land approximately 1 mile north or east of the WWTP would be utilized as the drip irrigation site. The holding pond and effluent pump station would be located at the drip irrigation site with an effluent pump station at the WWTP. If this alternative is pursued further, site restrictions and practical land availability must be investigated in greater detail. It is highly unlikely whether 20 acres of usable land could be obtained in this area for a drip irrigation system. The total estimated cost for Alternative No. 4 is $2,698,000.00. A detailed project cost estimate and a schematic of the proposed improvements are provided at the end of this section. As noted earlier, since spray irrigation land and facilities would be greater in cost than drip irrigation facilities, the spray irrigation alternative has been dismissed. A subsurface disposal alternative was not considered based on the above soils information, available land, and cost of consideration. C. Alternative C — Wastewater Reuse This alternative involves all or a portion of the wastewater generated at the WWTP to minimize or eliminate the need for surface water discharge. Potential reuse options include drip or spray irrigation, industrial process cooling water, the use of reclaimed water for toilet flushing, etc. Drip/ spray irrigation systems were discussed in this report as Alternative B and eliminated as a possibility. At this time, there are no known industries that are planning to locate a facility near the WWTP that could reuse the wastewater effluent as either a process or cooling water. Using reclaimed water for toilet flushing at the facilities would still involve the construction of a treatment plant. The option of plumbing all of the existing and proposed connections is not an economically feasible alternative. Therefore, the option of reusing wastewater from the WWTP will not be discussed further. D. Alternative D - Discharee to the Watauea River Alternative D consists of constructing a dual train 35,000 WWTP. The proposed WWTP will include flow equalization basin, aeration basins, clarifier units, tertiary filters, blowers, internal piping, ultraviolet disinfection, and control panels. Sludge will be treated in a digester included with the package plant to provide a Class B bio-solids. Sludge disposal will be contracted with f - r the Town of Boone WWTP. There is adequate land on -site for the construction of the proposed facility. The estimated project cost in 2018 dollars is $656,250.00. A detailed project cost estimate and a proposed plant schematic are provided at the end of this section. The plant design will be based on the discharge limits in the draft NPDES Permit which is included in the Appendix. E. Alternative No. 6 - Disposal Combination r` This alternative would involve combining different waste disposal methods. As stated in Alternative B, the proposed 35,000 gpd would be treated by a drip irrigation system. This alternative is not economically feasible, based on the cost of construction for any type of irrigation or subsurface disposal system. Alternative A Connection to Town of Boone Estimate of Probable Cost 4. Sewage Pump Station — 2 g $200,000 5. 42,000 lft of 4" Forcemain _ _ Construction Cost Subtotal $400,000 1260 000 $1,660,000 10% Construction Contingency 166,000 Engineering 1669000 Construction Administration 83 000 Total Pro'ect Cost $2,0759000 Operation & Maintenance Cost Estimate Item Estimated Annual Cost Operation & Maintenance $12,000 LaboratorySludge Disposal - Electricity 5000 Miscellaneous Total 1 $18,000 Present Value 20 year present value at 7% $29075,000 + $189000 (P/A=10.594) = $24659692 r r- r- Alternative B Drip Field Construction Estimate of Probable Cost 1. 2. 35,000 GPD Package Plant, Installed 1.05 million gal Holding Pond $3509000 500,000 3. 4. Effluent Pump Station 5,2801ft of 4" Forcemain 150,000 1589400 8009000 5. Drip Irr' ation System 6. Land Acquisition 200,000 Construction Cost Subtotal $291589400 10% Construction Contingency 2159840 Engineering 2159840 Construction Administration Total Project Cost 107,920 $296989000 Operation & Maintenance Cost Estimate Item I Estimated Annual Cost WWTP & Drip Filed Operation & Maintenance (Contract) La Miscellaneous Total Present Value 20 year present value at 7% $2,6989000 + $579000 (P/A=10.594) = $3,3019858 $36,000 $57,000 Alternative D WWTP Construction Estimate of Probable Cost 1. 359000 GPD Package Plant, Installed 2. Foundation & Sitework $3509000 100,000 3. EmergencyEmeEgeney Generator & Electrical 75,000 Construction Cost Subtotal $5259000 10% Construction Contingency 529500 Engineering 52,500 Construction Administration 26,250 $656,250 Total Project Cost Operation & Maintenance Cost Estimate Item Estimated Annual Cost WWTP Operation & Maintenance Contract $24,000 2,000 Laboratory Sludge Disposal 2,000 Electricity 10,000 Miscellaneous 2,000 $40,000 Total Present Value 20 year present value at 7% $6259250.00 + $409000 (P/A=10.594) = $190499010 III. PRESENT VALUE ANALYSIS A. Alternative A - Connection to the Town of Boone WWTP The operation and maintenance costs associated with transmitting the flow to the Town of Boone WWTP for the 35,000 gpd are estimated to be $18,000.00 per year. Utilizing a 7% discount for 20 years, the present value of this alternative is $2,265,692.00. A detailed estimate of the O&M costs is included at the end of this section. B. Alternative B - Drip or Spray Irrigation of Effluent The operation and maintenance costs associated with the drip irrigation system alternative are estimated to be $57,000.00 per year for the 35,000 gpd flow. Utilizing a 7% discount rate for 20 years, the present value of is estimated to be $3,301,858.00. A detailed estimate of the O&M costs is included at the end of this section. C. Alternative D - Discharge to the Watauga River The operation and maintenance costs associated with the 35,000 gpd WWTP is $40,000.00 per year. Therefore, the present value utilizing a discount rate of 7% for a 20-year time period is $1,049,010.00. A detailed estimate of the O&M costs are provided at the end of this section. The table below summarizes the present values of the treatment and disposal alternatives. Alternative Description Present Value A Connect to Town of Boone $2,265,692.00 B Drip Irrigation $3,301,858.00 D Construct WWTP $1,049,010.00 r, V. CONCLUSIONS AND RECOMMENDATIONS Based on the detailed alternatives and present value analysis for treatment and disposal of the 35,000 gpd of wastewater for the CWA tract and existing flows, it is recommended that the WWTP be constructed with a discharge into the Watauga River. To date, funds in excess of $200,000.00 have been expended on the land, permitting, planning, engineering, surveying, environmental studies, legal agreements, and the used WWTP components for the 35,000 gpd WWTP construction and another $125,000.00 is being held in escrow (Speedway's contribution). Without an adequate method of wastewater disposal, the CWA tract, existing uses and surrounding properties cannot be developed to their full extent into residential and commercial properties, resulting in a significant loss of economic growth and jobs in the community. To allow for this growth, it is in the best interest of the community and CWA to provide a method of wastewater disposal with the proposed WWTP. APPENDIX 4k c WA l g,kc..-rAk-,-r FILED Joiinn Townsend Register.of Deeds, Watauga CO.NC Rrordin F% S29.00 NC Real state TX: $.OD �,Il�glui�ij�1111111ia NON -WARRANTY DEED Excise Tax: NONE STATE OF NORTH CAROLINA COUNTY OF WATAUGA This Non -Warranty Deed is made this 1 lth day of April, 2008, by and between CLEVON WOODS ASSOCIATES (hereinafter called "Grantor") and CLEVON WOODS ASSOCIATES, LLC, a North Carolina limited liability company (hereinafter called "Grantees") whose address is: P.O. Box 32 Boone, NC 28607 Ax INFORMATION RECOfgD D WITNESSETH: Tax " WHEREAS, Clevon Woods Associates, LLC is a limited liability company, organized and existing under the laws of the State of North Carolina, pursuant to Articles of Organization Including Articles of Conversion, filed with the North Carolina Secretary of State on April 3, 2008, a copy of which is attached hereto for reference; and WHEREAS, by virtue of filing the aforesaid and attached Articles, the property hereinafter described in Exhibit "A," formerly owned by Clevon Woods Associates, a North Carolina general partnership, was, ipso facto, transferred by operation of law to Clevon Woods Associates, LLC; and WHEREAS, the purpose of this Non -Warranty deed is to place on record a document evidencing the transfer of the property described in Exhibit "A" to Clevon Woods Associates, LLC, a North Carolina limited liability company. /Pmared by; Clement Law Office 756 West King Street a Boone a NC 28607 828/264-6411 Return to Grantee at address shown above. 1101411111101111111VN�i IAI{ NOW, THEREFORE, in consideration of the premises, and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Grantor given, granted, bargained, sold and conveyed and by these presents does give, grant, bargain, sell, convey and confirm unto Grantee, its successors and assigns, in fee simple, those certain parcels or tracts of land, together with improvements thereon, situated in the Town of Seven Devils, Watauga Township, Watauga County, North Carolina, and more particularly described in Exhibit "A" attached hereto and incorporated herein by reference. The foregoing description was prepared from information contained in the deeds recorded in Record Book 57, Page 514, Record Book 57, Page 517, and Record Book 81, Page 331, Watauga County, North Carolina, Public Registry, TO HAVE AND TO HOLD the aforesaid parcels or tracts of land and all privileges and appurtenances thereunto belonging, or in any wise appertaining, unto Grantee, its successors and assigns in fee simple forever. Grantor makes no warranty, express or implied, as to title to the property hereinabove described. IN WITNESS WHEREOF, Grantor has caused this instrument to be signed and sealed, the day and year first above written. CLEV WOOD LATES By: (Seal) Charles E. Clement, General P STATE OF NORTH CAROLINA COUNTY OF WATAUGA I certify that CHARLES E. CLEMENT personally appeared before me this day and acknowledged to me that he voluntarily signed the foregoing document for the purpose stated therein and in the capacity indicated. WITNESS My hand and official seal this 11th day of April, 2008. gnature Above and 'P�Vis or Typed Name Above 2 u,lu6uidMio�iixumBRNI� Exhibit "A" Legal Description The following tracts being located in Watauga Township, Watauga County, North Carolina and being more particularly described as follows: Tract No.1• A 7.751 acre tract located on the North side of an abandoned road, formerly known as the Old Foscoe Road, approximately 75 feet Northeast of the intersection of said road with N.C. Highway 105; being bounded by Stewart Aldridge, formerly Crevasse (1.4798 acre tract) and Mae Fox, and being more particularly described as follows: BEGINNING on an iron found in the center line of an abandoned road, formerly known as the Old Foscoe Road, corner to Stewart Aldridge, said iron being located North 80 degrees 29 minutes West, 155.80 feet from N. C. Geodetic Monument "Propst" found in the southern margin of N. C. Highway 105; thence from the BEGINNING and with the centerline of the said old road the following courses and distances; South 78 degrees 33 minutes West, 120.57 feet; South 72 degrees 07 minutes West, 98.01 feet; North 67 degrees 22 minutes West,111.00 feet; South 56 degrees 56 minutes West,129.00 feet; and South 42 degrees 31 minutes West,151.00 feet to a hub set in the center of said old road; thence leaving the center of said old road North 83 degrees 24 minutes West, 21.65 feet to an iron set in the fence, corner to Mae Fox; thence with the line of Mae Fox North 63 degrees 01 minutes West, 156.82 feet to an iron set at a 16 inch locust tree; thence North 46 degrees 58 minutes West,140.79 feet to an iron set in the fence at a locust snag; thence North 11 degrees 43 minutes East; 288.14 feet to an iron set at a 20 inch White Oak; thence North 00 degrees 46 minutes West, 131.81 feet to an iron set in a farm road; thence North 19 degrees 35 minutes East, 92.12 feet to a tack in an Ash tree at fence corner; thence North 32 degrees 48 minutes East, 63.76 feet to a tack in a 14 inch oak tree at fence corner; thence North 26 degrees 41 minutes East, 49.31 feet to a tack in fence post; thence North 34 degrees 49 minutes East, 93.85 feet to an iron set in the fence, corner to Mae Fox, Stewart Aldridge, and herein described; thence with the Aldridge line South 43 degrees 09 minutes East, 101.18 feet to an iron found; thence South 41 degrees 27 minutes East, 220.48 feet to an iron set in the fence; thence South 42 degrees 15 minutes East, 462.75 feet to an iron set; thence South 41 degrees 33 minutes East, 95.26 feet to the BEGINNING and containing 7.751 acres according to survey shown on Plat No. 73036 prepared February 18, 1982, by David K. Stern, RLS No. L-1301. Tract No. 2• A 1.4798 acre tract located on the South side of an abandoned road, formerly known as the Old Foscoe Road, and being bounded by Stewart Aldridge, formerly Crevasse (7..751 acre tract), Mae Fox and N. C. Highway 105 and being more particularly described as follows: BEGINNING on an iron stake in the right-of-way of N.C. Highway 105 and in the center of an abandoned road, formerly known as the Old Foscoe Road, and runs thence with r� r-. 1I1 O���I1�1�Q©�'I36890�II�II II I �I II���I ���I �II BR 6R1365 489 416 the center of said old road North 42 degrees 31 minutes East, 151 feet to an iron stake; r thence North 56 degrees 56 minutes East, 129.00 feet to an iron stake; thence South 67 degrees 22 minutes East,111.00 feet to an iron stake; thence North 72 degrees 07 minutes East, 98.01 feet to an iron stake; thence North 78 degrees 33 minutes East, 120.57 feet to an iron stake in the center of said old road in the Aldridge line; thence leaving said old road South 40 degrees 18 minutes East, 99.79 feet to a point in the center of N. C. Highway 105, thence with the center of said highway the following courses and distances: South 63 degrees 55 minutes West, 164.00 feet; South 74 degrees 28 minutes T West, 144.03 feet; and South 74 degrees 48 minutes West, 285.00 feet; thence leaving said highway North 15 degrees 12 minutes West, 50.00 feet to the BEGINNING and containing 1.4798 acres all according to survey by James A. Dugger, RLS, December 14, 1968, shown on Plat No. 73036 prepared February 18, 1982, by David K. Stern, RLS No. L-1301. Tract No. 3: BEGINNING on an iron found in the fence corner, a corner to Charles Clement and runs _. thence with Clement line South 42 degrees 31 minutes East, 140.63 feet to an iron found at a 20 inch locust in the fence; thence South 58 degrees 33 feet East, 157.67 feet to an iron found in the fence corner; thence South 58 degrees 33 minutes East, 87.54 feet to a stake in the center of N. C. Highway 105; thence with the center of N.C. Highway 105 the following courses and distances: South 76 degrees 56 minutes West, 88.74 feet; South 73 degrees 34 minutes West, 114.29 feet; South 67 degrees 44 minutes West, 72.22 feet; South 66 degrees 42 minutes West, 98.04 feet; thence leaving said N. C. Highway 105, a new line North 38 degrees 47 minutes West, 283.17 feet to a point; thence North 60 degrees 13 minutes East, 260.48 feet to the BEGINNING, containing 2.016 acres as shown by a plat dated March 12, 1979, prepared by Burkett surveyors, Inc., Walter H. Burkett, RLS No. L-1209. Tract No. 4• BEGINNING on a stake in N. C. Highway 105 and being the southwest corner of the 2.016 acres now owned by Charles Clement and Charles A. Von Stein, Inc., and runs thence with the west boundary line of said property North 38 degrees 47 West, 283.17 feet to the northwest corner of the said property and in the line of Carpenter and Sample, Inc.; thence with said line South 31 degrees 55 minutes West, 252.70 feet to a stake in the Seven Devils Road; thence with Seven Devils Road South 54 degrees 31 minutes East, 183.81 feet to a stake at intersection of Seven Devils Road and N. C. Highway 105; thence with said N.C. Highway 105 North 58 degrees 5 minutes East 190.02 feet to the BEGINNING, containing 1.145 acres as shown by a plat of survey dated March 12,1979, prepared by Burkett Surveyors. c"Monta9 I SOSID: 1036499 Date Filed: 413/200812:12:00 PM Elaine F. Marshall 1111111111111111��11111111j1111111111111111111111111 North c C200809301 29 eisrate BR1365 490 6/6 State of North Carolina Department of the Secretary of State ARTICLES OF ORGANIZATION INCLUDING ARTICLES OF CONVERSION Pursuant to §§ 57C 2 21, 57C-9A-01 and 57C-9A-03 of the General Statutes of North CaroIirhs, the undersigned converting business entity does hereby submit these Articles of Organization Including Articles of CAnversian for the purpose of forming a limited Liability company. I. The name of the limited liability company is: CLEVON WOODS ASSOCIATES, LLC. The limited liability company is being formed pursuant to a conversion of another business entity. 2. The name of the converting busineas entity is CLEVON WOODS ASSOCIATES, a North Carolina General Partnership, and the don and internal affairs of the converting business, entity are governed by e laws of the state or cotmtry of North Carolina, USA. plan lan of oonversoat has been approved by the converting business entity as requited by law. 3, The converting business entity is a parbweWp as defined in G.S. 59-36, whether or not formed under the laws of North Carolina, 4. If the limited liability company is to dissolve byy a c date, the latest date on which the limited liability company is to dlesolve:(o date for dissolution is speciM, them shad be no limit on ilia duration of the limited lklb lily wnspany.) 5. The name and address of each person executing these articles of organization is as follows: (,State whether each person is executing these articles of organization in the capadty of a rnember, organizer or both). Charles B. Clemens: General Partner 756 West Ift street MEMBER P. o. Box 32 ORGANIZER Boone, Watauga County, North Carolina 6. The street address and county of the initial registered office of the limited liability company is: 756 west King Street Booths, Watauga County, North Carolina 28607 The mailing address, if dgJerent from the sheet address, of the initial registerW office is: F. O. Box 32 Boone, NC 28607 f100M9001C9 p� II'�IhPIIIG 8. The name of the initial registered agent is: Charles E. Clement 9. Principal office information: The limited liability company has a principal office. The street address and county of the principal office of the limited liability company is; 756 West Kin gg Street Boone, NC28607 Watauga County The snailing address, if dif tt from the street address, of the principal office of the UinitedTliiaability company is: P. O. Box 32 Boone, NC 28607 10. Check one of the following. Imembsr••managed UC: all members by vifte of their status as members shall be managers of this limited liability company. 11. Any other provisions which the limited liability company elects to include are attached, 12. These articles will be effective upon filing. This is the 2nd day of April, 2008. 2 ON W ASSOCIATES Charles E. Clement, General Partner MEMBER ORGANIZER E�� t�t(>(T C C WA O.5 to'1 ok c 1 Cam" FILED Rmv J Shook Restsler of Deeds, Nataupa Co. NC Fee Ret: S26 00 9k 1960 Pg 373 (4) Reoorded: 02/15/2016 at :2.26.07 PM Doe No 666244 Kind DEED NON -WARRANTY DEED Excise Tax: $0 STATE OF NORTH CAROLINA COUNTY OF WATAUGA This Non -Warranty Deed made this r3' day of February, 2018, by and between BBR ENTERPRISES, LLC, a North Carolina limited liability company (hereinafter called "Grantor") whose address is: P.O. Box 193 Boone, NC 28607 and CLEVON WOODS ASSOCIATES, LLC, a North Carolina limited liability company (hereinafter called "Grantee") whose address is: P.O. Box 32 Boone, NC 28607 WITNESSETH. Grantor hereby gives, grants, bargains, sells, conveys and confirms unto Grantee, Its successors and assigns, all right, title and infierest, if any, which they may have in and to that certain lot or parcel of land situated In Watauga Township, Watauga County, North Carolina, and more particularly described in Exhibit "A" attached hereto and incorporated herein by reference. ftpered by: Clement Law Office • 756 West King Street • Boone • MC 28607. 828t164.6411 Return io Orantee at address shown above. BK 1960 PG 374 DOC# 666244 ak 1960 Pg 374 Doe No: 666244 Kind DEED The foregoing description was prepared from information contained in the deed recorded in Book of Records 1911, Page 893, Watauga County, North Carolina, Public Registry. TO HAVE AND TO HOLD the aforesaid parcel or tract of land and all privileges and appurtenances thereunto belonging, or in any wise appertaining, unto Grantee, its successors and assigns forever. Grantor makes no warranty, express or implied, as to title to the title to the property hereinabove described. Pursuant to N.C.G.S. 105-317.2, Grantor represents that the property conveyed herein is not its primary residence. IN WITNESS WHEREOF, Grantor has executed this Non -Warranty Deed, the day and year hereinafter set forth. STATE OF NORTH CAROLINA COUNTY OF WcL+ -0S0'- I certify that I prause Lit k s personally appeared before me this day and acknowledged to me that they voluntarily signed the foregoing document for the purpose stated therein and in the capacity indicated. WITNESS my hand and official seas this 190_ day of February, 2018. q• 4 NoyPublic Signature Above ,t11Ki180i i My Commission Expires: 2Q,.�:,-• •..� a0 AR (Affix Notarial Seal)•.. P(J BL�G. �r1(11i i C11%t��. BK 1960 PG 375 DOC# 666244 ak 1960 Pg 375 Doc No: 666244 Wid DEED �1!$1 �,i�l� • .. . BEING all that Certain 0.5M ame pmml GAWl•of lend .lout W:on:Wp•east atde of - Aldridge Road (N,.C.S.R. 1184),• mW'.bft'a*mdi6 of 0ce 9:I;aaa .: 1tss, Or4a comare d to Lea R Propot ad •wilt, Mer)► 8, •Prop t •ii�r � deet� det�1 Mar 23, 1967, adrem in Dead Doi* 102,, 4&:31Ce 't i ,'N, Moil Rmistry, endUft morm.partiaulady daubed as,fo110ws: BF.d1NNINt3 at an existing iron pipe set . in the, oa A iigaiq* 4f Aldridge' Road (N.C.S.R. 1194). being the• southwest coma Of -'a 1.0 f 1 • s6 m-tiiw oixnrd� * Yestpocltd la o men% LLC (Wmd Bock 1715, Page 30�,'wa#mu0 :10MW Z;,e )'.A 1l = from BEGINNING end with the aaa«n;ri.oA r1d�=,Road.NQztb'6'2-deea 10 minutes 30 seoands West 41'.88' IM td' a P . iemt': jdpo;6 9'� c m►hag with the mamfii oir Aldrldgm Road 14ort1Y46 d ',Si nti ' 0as bb s' Werst 83.13 that to an'a�dstlag :ison.pips'sat .19�ft •ems tg�r�t�a'bX'•"saidi .: TH ICS leavin$•Aldridge Road' with=a new Nne tlw. d'P(ga'ieettt *'*'A egrets SO' minutes 00 socoads Fast 200.00• fed- to m cplc+Atatad e�i„ TH +1C,l width' ai r pew'. line fivough dw Pmgst.lead South to' a imp of intcraeatioa b vuoetera lttto i Veatpp oet iietti „LLC'1:41 i -am trm 4 THENCE with the western of tAg: Vet' LLC 1.01 i acre treat South 44 degrees 59 minutes�;t1) �ieotida. WEs2OO.foattd `:plpp,.the POINT AND PLACE OF. 8B0R*ift and 6';� 0SX, 4xesos sho RJmd.rruna" described p�r:jyjep:OISt$?,. ,asifit ;"Boe'pafCfl P,or Ved po&d lnv. r LLC:.br D1lught�y l �i. �► Y+, No. 415S, a copy of bichils:eue" TooEmER WITH a ImDot wide `saaFec easgrae�t;.tlro tdrtitte;of "vrlttdi is described as follows: •BEGINNINO.at a=13ap�ii Itia''0.3T6 tiara°tn descrlbed�esorinabove, said begintt� P�, 17..QFS,troatii oirtlue•weat�t°Upe of_ . the rmrnetniag Peon •propeuty. also i1<a;essterr► it rgin bt Atdr d R ct fid.C.S.R. 1.184)]i 'THW- O Rom thO 0 ad. ,conijUwq*'With' 0te•ciiAQ, to of sad 10- foot wlde•eaaemarst North 42 degrees, t 3=rr ittntes 0 aeoQu&-Walt 147:9t1,f e?:: mid, then condnuing North 36 iT�gir.aa:4'.tttittti titot+'V4�aa�t 104;11� ;: ro the ierioaif�i�s of the said-eassamt, as shown ead°more p�tllciiter�lX.des bed oa 1 P #UI'S)06=C, obtitled "Centerlhtm of a:10' Sawa.Fhwnmm,`' by,Dau try [aumil'Suc�bKlrtg,;cRa=8:17a�ighby, PiS No. 41 S5, m partial copr•'of which is'.'mtiio�ed•tor illuatrativri pn�oi�. ' . M� BK 1960 PG 376 DOC# 666244 ak 1980 Pg 376 Doc No: 666244 Kind DEED 1. aatauga county ad va[or�nE;teacea.• : • '• . 2. Bi6t away for Nc KiglMiY IOS GW'AMridP(N-C►S-R.1.184). 3. 91t1boaea 1 a eocardsd,Book oi'Raoada 6� 01 Psgs'57e; Hook 4AWprds 347 at Page 365; Book of F0.0 rdi' i MAO P,,a. & 416; Book at`lteci * 1312 at Pap 556, Watauga 6muitt�'Ragt by.: . 4. BU=M t to Blue -Ridge• morda! in -Rook 4Records 1682 at-Pegg.613. W.atfwga 'Reglaby. S. The PmWty is to be wmd only cgni ofian, and oparnticn of a w*mnvgw t.- de dtlte�r:Stnftw tneatmgnt • ilinatioo. induding�ithouEliri�f�tsp�: •• ... r� �j tkt &T- '2' w Water Resources Environmental Quality September 20, 2017 Mr. Charles E. Clement, Manager Clevon Woods Associates, LLC 756 West King Street Boone, NC 28607 ROY COOPER Governor MICHAEL S. REGAN Secretary S. JAY ZMMIERMAN Director Subject: Draft NPDES Permit NCO070408 Clevon Woods — Art Plaza WWTP, PCNC NC Highway 105, Seven Devils 28604 Watauga County Dear Mr. Clement: In response to your request to renew the subject NPDES permit, the Division of Water Resources (DWR or the Division) hereby transmits this draft for your review and comment. Please review this document to assure your understanding of the permit limits and monitoring conditions, and to correct errors, if any. The Division understands that you have made no significant changes to your facility since the last permit renewal. We have made the following updates to your previous permit: 1. The facility map has been updated 2. Regulatory citations have been added. 3. Parameter codes have been updated in Section A. (L). 4. Electronic reporting of discharge monitoring reports (eDMR) has been added in Section A. (2.). Concurrent with this notification, the Division will solicit public comment on this draft by publishing a notice in newspapers having circulation in the general Watauga County area, as required by the NPDES Program. Please provide your comments, if any, to me via email (derek.denard@ncdeur.gov] or write to my attention care of DEQ / DWR / NPDES Program no later than October 20, 2017. Your written comments are welcome but not mandatory. Following the mandatory 30-day public comment period, the Division will review all pertinent comments on your permit draft, and take appropriate action prior to issuing your NPDES permit final. If you have questions concerning this draft, please e-mail me or call my direct line (919) 807-6307. Sincerely, Derek Denard, Environmental Specialist Compliance & Expedited Permitting Unit Division of Water Resources, NCDEQ Enclosure: NPDES Permit NCO070408 (renewal DRAFT) be: NPDES Program Files cc: DWR/WSRO, George Smith [george,smith@ncdenr.gov] Wastewater Operator Certification Group / Maureen Kinney [Maurem.Kinney@ncdenr.gov] Charles E. Clement, Manager, Clevon Woods Associates, LLC [cclementQa clementawoffice.com] State of North Carolina I Eavimmmental Quality 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 919-707-9000 NPDES Permit NCO070408 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERAUT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE EL-M4iNATION SYSTEM NPDES " In compliance with the provisions of North Carolina Geneial Statuic-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina) ti ronmental Management Commission, and the Federal Water Pollution Control Actramended, Clevon Woods Associates, LLC is hereby authorized to discharge',igastevgater from a proposed facility, the Y- Clevon Woods' r- *A' Plaza- WWTP NC Highway 1051 Seven Devils 28604 Wataugatounty to receiving waters designated as the Watauga River in the Watauga River Basin in accordance with effluent limitations; monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become •ective __ 2017. This permit and authorization to discharge shall expire at midnight on September 30, 2022. Signed this day , 2017. S. Jay Zimmerman, P.G., Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 6 NPDES Permit NCO070408 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, requirements, terms, and provisions included herein. Clevon Woods Associate. LLC is hereby authorized to: 1. after receiving an Authorization to Construct (AtQ permit from theion, construct and operate a 0.035 MGD wastewater treatment facility; located at the Art Plaza WWTP, offN�i.105, Seven Devils in Watauga County; and 2. discharge from. said treatment works via Qutfall 091, at the location specified on the attached map, into the Wiiaxffl F4ver [stream index 8-(1)1, currently classified B; Trout, HQW waters within Subbasth-04-02-01 [HUC:.060101030301] of the Watauga River Basin. Page 2 of 6 NPDES Permit NCO070408 PART I A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning upon completion of the construction of WWTP and lasting until expiration, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited, monitored and reported' by the Permittee as specified below: .&rri.urA r LIMITS MONITORING REQUIREMENTS' CHARACTERISTIC Monthly Daily Measurement Sample Sample [PARAMETER CODES] Average Maximum Frequency Type Locations Flow (MGD) 50050 0.035 MGD "Continuous Recorder I or E BOD, 5-day (20°C) (mg/L) C0310 5.0 mg/L 7.5 mg/L `' 1ekly Composite E Total Suspended Solids (TSS) (mg/L) C0530 10.0 mg/L 15.0 mg/L Web Composite E NH3 as N (mg/L) C0610 2.0 mg/L 10.0 mg/L Weekly Composite E Dissolved Oxygen (DO) (mg4) 00306- Daily average > 6.0 mg/L Weekly Grab E Dissolved Oxygen (DO) (mg/1) 00300 Monitor & Report Weekly Grab U & D Fecal Coliform (#/100m1) 3 31616 2001100 ml 11.00 ml Weekly Grab E (geometric mean Total Residual Chlorine 50060 µg/i 2/Week Grab E (TRC) ) `28 Temperature ('C) 00010 Monitor & Report Daily Grab E Temperature ("G} 00010 Monitors Deport Weekly Grab U & D pH (su) 00400 Not < 6.0 nor> 9.0 Weekly Grab E Standard Units Footnotes: 1. The Permittee shall begin submitting Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Condition,A. (2.). 2. I = Influent; E = Effluent, U = Ups4wm: at least 100 feet upstream from the outfall. D = Downstream: at least 100 feet downstream -font the outfall. 3. Fecal Coliform shall be calculated using the geometric mean, according to the procedure detailed in Part 11. Section A. 4. Total Residual Chlorine limit and monitoring is required only if chlorine is utilized in the treatment process. The Division shall consider all effluent TRC values reported below 50 ug/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 ug/L. Conditions: • There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 3 of 6 NPDES Permit NCO070408 A. (2.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. 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 APDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting ; . • Section D. (6.) Records Retentionti-' • Section E. (5.) Monitoring Reports d- ' 1, Reporting-ReauiremMo (Supersedes (5.1 lull The permittee shall report discharge monitoring data electronically using kC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. -' Monitoring results obtained during the previous month(s) shall be summarized fc i month and submitted electronically using eDMR. The eDMR systm allows permitted facilities to enter m (firing data and submit DMRs electronically using the tptaid, Until such time that the state's eDMR application is compliant with EPA's Cross Media Ele6tn6nle. Reporting Regulation (CROMERR), permteus• 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 printit#,-siV314 i�ld submitting one signed original and a copy of the computer printed eDMR to the following address: NC DEQ / Division of Water Resources / Water Quality Permitting $eetion ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Crina 27699-1617 If a peon itt6e is unable to :,us+e the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area ha .ere 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: • Sewer Overflow/Bypass Event Reports; • Pretreatment Program Annual Reports; and • Clean Water Act (CWA) Section 316(b) Annual Reports. Page 4 of 6 NPDES Permit NC0070408 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(l)(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: h jj,__Www2.epa.govtcomp�liancc/f-r�at.io; �aollutant-disghgr nlfon-system-nodes-ele=::_ reporting? -rule. Electronic submissions must start by the dates listed in the `Reporting Requirements" section above. 3. How to Request a Waiver fragg Eleetronic Re 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 an eDMR and the application for a temporary electronic reporting waiver are found on the following web page: !ft-ttfr:l/det .ne.goy/about/division siwater-resau ; 4. Slenason Reauirements 1Supokments Seebion B. (11.) M and Supersedes Section B. (11) Ml All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part 11, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part Il, 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: �c.Liov/about/divisions/wa er resesiedmr Page 5 of 6 Fl- NPDES Permit NC0070408 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 submitdngfalse information, including the possibility of fines and imprisonment for knowing violations." 5. Records Retention 1SuQalemends Section D. (6.11 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 6 of 6 Fffff 4(0 I Iry $PW r ! Vlw&iN 0- M, j t,�'oK(4c 1;1—r S � M Water Resources Environmental Quality D -C 2 1 2617 --------------- December 14, 2017 CERTIFIED MAIL 7015 1520 0000 7838 4627 RETURN RECEIPT REQUESTED Mr. Charles E. Clement, Manager Clevon Woods Associates, LLC 756 West King Street Boone, NC 28607 ROY COOPER Goveniat- MICHAEL S. REGAN Secretary LINDA CULPEPPER hiterim Director Subject: Request for Additional Information Draft NPDES Permit NCO070408 Clevon Woods — Art Plaza WWTP (WW-2) NC Highway 105, Seven Devils 28604 Watauga County Dear Mr. Clement: During the mandatory 30-day public comment period, the Division received ten (10) public comments. Following the public comment period, the Division reviewed all pertinent comments on your draft permit. A comment received from the Southern Environmental Law Center noted that no Authorization to Construct (ATC) permit has been applied for since the previous permit was issued. In According to 15A NCAC 02H .0138 (a), for ATC permits the following is required: (a) Required. After an NPDES permit has been issued by the Division of Environmental Management in accordance with this Section, construction of wastewater treatment facilities or additions thereto shall not begin until final plans and specifications have been submitted to and an Authorization to Construct has been issued to the permittee by the Division of Environmental Management. If an Authorization to Construct has not been applied for in accordance with the requirements of the NPDES permit during the term of the permit, the permit will be considered void upon expiration and future actions will be considered as a new application. Review of our records indicated that an ATC Perri t has not been received since this permit was originally issued on November 12, 1987. Without an ATC Permit, this permit application will be processed as a new application. The term "New" is defined according to 15A NCAC 02H .0103 (16) as follows: (16) "New", with respect to implementing the NPDES permitting program, means: (a) Proposed facilities that do not have a NPDES Permit nor have any facilities constructed. (b) Facilities which physically exist, however are illegally constructed, i.e., no required agency approvals. (c) Facilities which have received an NPDES Permit and have received an Authorization to Construct but have not begun significant construction of any wastewater treatment facilities within the term of the current permit. slate orNorth Carolina I Environmental Quality 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 919-707-9000 Mr. Clement December 14, 2017 Page 2 of 2 Any increases in treatment plant hydraulic capacity, which has not received an Authorization to Construct shall be considered new and new effluent limitations and other requirements, if applicable, would be imposed for the entire facility. In order to process this permit renewal application as a new permit application, the Division requires an Engineering Alternatives Analysis (EAA). One related public comment suggested that an alternative to direct discharge, such as a subsurface, be evaluated. Given that 30 years has passed since any alternatives to a direct - discharge have been evaluated for this purposed facility, an updated EAA would be prudent. Economic costs, best available technology, and availability of a connection to a POTW may have changed over time. The Division has reviewed your application and public comments for the draft permit. To enable us to complete our review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 2H .0105, please provide additional or revised information to address the following comments: 1. Complete an Lngineedq& Alternatives Analysis (EAA). The Division requires applicants to fully document and exhaust all alternatives to surface water discharge [G.S. § 143-215.1(b)(a) and 15A NCAC 214.0105 (c)(2)]. The EAA should include boring logs and/or other information indicating that a subsurface system -is neither feasible nor practical as well as written confirmation indicating that connection to a POTW is not an option. For the non -discharge alternatives, please demonstrate whether or not the physical size of the site is prohibitive, and whether or not the resulting loading rate is prohibitive based on site specific soil conditions. For your reference, the "Engineering Alternatives Analysis (EAA) Guidance Document" is enclosed. Please complete and return Attachment A. Local Governments Review Form (page 8). The EAA should also include a present value of costs analysis as outlined in the Division's EAA guidance. Each alternative should be thoroughly evaluated and each conclusion should be substantiated by appropriate documents and itemized budgets demonstrating that alternatives are cost prohibitive. If no response is received within 60 calendar days [per 15A NCAC 2H.0107(b)], the project will be deactivated and withdrawn from our review process and the documents recycled. If you have any questions, please contact Derek Denard at 919-807-807-6307 or email at derek.denardCcr�.ncdenr.gay. `Si rely, John E. Hennessy, Supern Compliance &Expedited Permitting Unit Division of Water Resources, NCDEQ Enclosure: Engineering Alternatives Analysis (EAA) Guidance Document he: NPDES Program Files ec: DWR/WSRO, George Smith (george.smitli@ncdenr.gov] Charles E. Clement, Manager, Clevon Woods Associates, LLC [cclement@ctementlawoffice.com] 1 Attachment A. Local Government Review Form Genera? Statute overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance of NPDES permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management Commission (8MC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has received a written statement from each city and county government having jurisdiction over any part of the Iands on which the proposed facility and its appurtenances are to be located. The written statement shall documentwhether the city or county has a Zoning or subdivision ordinance in effect and (tfsuch an ordinance is in effect) whether the proposed facility is consistent with the ordinance. The EMC shall not approve it permit application for any facility which a city or county has determined to be inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have stateside significance and is in the bat interest of die State. Innt,uerieaa to the Atmlicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant shall request that both the nearby city and county government complete this form The applicant must: • Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and the county by terrified mail, return receipt requested. e If either (or both) local govu=ent(s) fai(s) to unail the completed form, as evidenced by the postmark on the certified mail card(s), within 15 days afrer receiving and signing for the certified mail, the applicant may submit the application to the NPDFS Uric. As evidence to the Commission that the local governments) failed to respond within 15 daps, die applicant shall submit a copy of the ce-rdfied mail card along with n notarized letter stating that the local governments) failed w respond within the 15-day period. Ins ructinrta 1Q the Local Government: The nearby city and/or county government which may have or has jurisdiction over any part of the Load on which the proposed facility or its appurtenances are to be located is required to complete and return this form to the nppGcant within 15 days of receipt. The form ttatist be signets and notarized. Nae of localgovernmrncW matauga County (City/Count) Does the city/county have jurisdiction over any pact of tine land on which the proposed facility and its appurtenances are to be located? fifes [IQ No ( ] If no, please sign this form, have it notarized, and return it to the applicant. Does the city/county have in effect a zoning or subdivision ordinance? Yes CA] No [ ) if there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [X) No[ ] Date February 13, 201 B Signature f '�l'Ld!$ (city ?Mianager/Coo Manages) crate of North aroli. n Countyof Wataucra On this 1 3t7h day of February --, 2 11 Epennnally appeared before me, the said merle to me known and known to me to be the person described in and who executed the foregoing doc:u t and he (or she) acknowledged that he (or she) executed the same and being duly sworn by me, made oath that the statements in the foregoing documenr are true. My Commission expires [ ao-A l .(Signature of Norary Pubb'c},�. ! NOTA;? L % EAA Guidanne Document Recision: April 2014 Page 8 of 8 O'nld 'Noma V SNmnSNO3 N31MVM VNI M VJJ Hi" '1LLNf= VOW-LVM Oil 'OOSSV SaOOM NOA313 NOA a� S3111'713W J,PMlVMU O39OdOHd ewa �aanies NV'Id 31AS � c,-> 3sn 1VNOI awo z V co r a «. r � g Z 4/ I! GIs- 9% k W W f! 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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning upon completion of the construction of WWTP and lasting until expiration, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited, monitored and reported' by the Permittee as specified below: EFFLUENT LIMITS MONITORING REQUIREWNTSI CHARACTERISTIC Monthly Daily Measurement Sample Sample [PARAMETER CODES] Average Nbudmum Frequency Type Locationz Flow (MGD) S0050 0.035 MGD ' +' ° • Continuous ♦r ` Recorder I or E BOD, 5-day (20°C) (mg/L) C0310 5.0 mg/L 7.5 mg/L y { ` t evy Composite E Total Suspended Solids (TSS) (mg/L) C0530 10.0 mg/L 15.0 mg(L We % Composite E N113 as N (mg/L) C0610 2.0 mg/L 10.0 mg/L Weekly Composite E Dissolved Oxygen (DO) (mg/1) 0030� I��aily average > 6.0 mg/L Weekly Grab E Dissolved Oxygen (DO) (mg/1) 00300 .' hgpnitor & Report Weekly Grab U & D Fecal Coliform (#/100m1) 3 31616 20011:00 ml -40011-00 ml Weekly Grab E (geometric mean), Total Residual Chlorine4 50060 ! µg/L 2/Week Grab E TRC) f28 Temperature (°C) 00010 Monitor & Report Daily Grab E Temperature (°C<) 00010 Monitor & ort Weekly Grab U & D PH (su) 00400 Not < 6.0 nor > 9.0 Standard Units Weekly Grab E Footnotes: 1. The Permittee shall begin submitting Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Condition.,A. (2.). 2. I = Influent; E = Effluegt, U = Upstream: at least 100 feet upstream from the outfall. D = Downstream: at least 100 feet downstream iroM the outfalll. 3. Fecal Coliform shall be calculated using the geometric mean, according to the procedure detailed in Part 11. Section A. 4. Total Residual Chlorine limit and monitoring is required only if chlorine is utilized in the treatment process. The Division shall consider all effluent TRC values reported below 50 ug/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 ug/L. Conditions: • There shall be no discharge of floating solids or visible foam in other than trace amounts. 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