NCG510551_Application_20191206

WithersRavenel Letter of Transmittal
DATE 12/3/19 JOB NO. 02171214.41
115 MacKenan Drive ATTENTION Derek Denard
Cary, NC 27511
t: 919.469.3340 l f: 919.467.6008 RE: NPDES Permit
Blue Ridge Hospital Discharge Permit
TO: NCDEQ/DWR/Water Quality Permitting Section 125 Hospital Drive
1617 Mail Service Center Spruce Pine,Mitchell County,North Carolina
Raleigh,NC 27699-1617 UST Incident#: 3659
WE ARE SENDING YOU ❑ Attached ❑ Under Separate Cover via
THE FOLLOWING ITEMS ❑ Shop Drawings ❑ Prints 0 Plans ❑ Samples 0 Specifications
❑ Copy of Letter ❑ Change Order ❑ Diskette ❑ Other
COPIES DATE NO. DESCRIPTION
2 12-3-19 1 Blue Ridge Hospital Discharge Permit Application
RECEIVED
DEC 062019
NCDEQIDWRINPDES
THESE ARE TRANSMITTED as checked below:
O For approval 0 Approved as submitted ❑ Resubmit copies for approval
❑ For your use 0 Approved as noted ❑ Submit copies for distribution
❑As requested 0 Returned for corrections ❑ Return corrected prints
II For review and comment ❑ Other
❑ FOR BIDS DUE ❑ PRINTS RETURNED AFTER LOAN TO US
REMARKS:
COPY TO: Scott Ryals, NCDEQ UST Section SIGNED: G. Matthew James
If enclosures are not as noted,kindly notify us at once.

%0 WithersRavenel
1 Our People.Your Success.
December 3,2019
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 RECEIVED
Attention: Mr. Derek Denard DEC 0 6 2019
Re: Blue Ridge Hospital Discharge Permit NCDEQIDV�R�NPC�S
125 Hospital Drive
Spruce Pine, Mitchell County, North Carolina
NCDEQ UST Incident No.3659
WR Project No.02171214.41
Dear Mr. Denard:
WithersRavenel, Inc. (WR) is submitting the attached application for coverage under general permit
NCG510000 (see Attachment I). An existing groundwater remediation system (previously covered
under permit NCG510002 and rescinded)is currently in operation at the subject property to remove
petroleum free product and petroleum-impacted groundwater stemming from a leak from an
underground storage tank(UST)system.
WR is currently under contract with the North Carolina Department of Environmental Quality
(NCDEQ) Division of Waste Management UST Section to perform the operations and maintenance
of the groundwater remediation system.This permit application is being submitted on behalf of the
responsible party, Blue Ridge Hospital,at the request of the NCDEQ UST Section.
On April 19, 2018,via electronic mail, Mr.Jeff Dulaney, representative of Blue Ridge Hospital, Inc.,
authorized submittal of the permit application on behalf of Blue Ridge Hospital, Inc. The
documentation of authorization is included in Attachment II.
Description of the Treatment System
As will be summarized in greater detail in the attached specification package,the current groundwater
treatment system removes petroleum free product and petroleum-impacted groundwater that is
present just west of the hospital structure. The continued operation of the system is imperative to
remediate the contaminated groundwater and, more importantly, to reduce the potential for
petroleum-impacted groundwater to discharge aboveground at the toe of the slope adjacent to
Highway 19E. This occurrence would lead to surface migration of petroleum contaminants via
stormwater management features - meaning the contaminants would be directly discharged to
nearby surface water bodies,such as Beaver Creek and the North Toe River.
115 MacKenan Drive I Cary,NC 27511
1 t:919.469.3340 I f:919.467.6008 I www.withersravenel.com I License No.C-0832
Asheville I Cary I Greensboro I Pittsboro I Raleigh I Wilmington
1

410
WithersRavenel
it People Your SacC s
Engineering Alternatives Analysis (EAA)
The following alternatives were evaluated in preparation of this application:
Alternative A: Connection to Existing Wastewater Treatment System:
A letter from William Hunneke,Head Trust Fund Branch,is provided which documents the attempted
communications between NCDEQ - UST Section and the Town of Spruce Pine.
Alternative B: Land Application
WR evaluated the feasibility of land application via subsurface systems, drip irrigation, and spray
irrigation methods.
The Blue Ridge Hospital property is approximately 17 acres in size and is almost entirely developed
with infrastructure associated with the hospital operation. Therefore, there is no available
undeveloped land on-site which can be used for land application.
Adjacent and nearby properties within 2,500 were evaluated for potential location of off-site land
application. A Property Alternatives Evaluation Exhibit map was prepared to determine potential
areas for disposal. A copy of this exhibit and a USGS map is included in Attachment IV.
Subsurface Disposal
Regarding the subsurface disposal option,the groundwater contaminant plume is located west of the
hospital structure on a local topographic high. The contaminant plume migrates with the natural
groundwater flow direction, which is to the north-northwest towards Buffalo Creek. The hydraulic
gradient is relatively steep due the significant elevation difference between the subject property and
Highway 19E.Discharging the effluent to the subsurface could create a localized groundwater mound
that would accelerate the migration of the contaminant plume towards Highway 19E and Buffalo
Creek. This evaluation included offsite properties, and therefore, subsurface disposal was not
deemed feasible.
Spray Irrigation
Offsite disposal was evaluated within an approximate 2,500 ft radius of the site. If the system
averages a production of 14,400 gallons per day; at approximately 27,000 gallons per acre inch, a
spray system would apply approximately 0.5 inches per day over a one-acre area. This total would
result in an approximate application load of 180 inches over a one-acre disposal area over a 12-month
period. To maintain an approximate loading rate of 45 inches annually,the waste disposal area would
need to be in excess of four acres, not including drainage easements accessing the area and
required compliance boundaries.
Using this general information, WR compiled an aerial exhibit in an attempt to identify potential
disposal areas greater than four acres within 2,500 ft(approximately 0.5 mile)of the facility.
The only areas identified for potential use in the area are currently owned by private residents and/or
timbering enterprises. One parcel, identified as 8.7 acres owned by Timberjack, LLC has a recorded
Page 2 of 5

40 WithersRavenel
Ow Geople four S,icce=s.
land value of $60,900. A second parcel, identified as 9.64 acres owned by private residents has a
recorded land value of$77,100. These figured do not include the value of timber harvested on the
property.
Using this information,it is assumed that the cost of acquiring nearby property which could facilitate
the disposal would be approximately$7,000 per acre. It can be assumed this price rises considerably
due to the value of timber harvesting.
Although there has been no soils or hydrogeologic evaluation done for this area,the general soil types
in the area(excluding Urban Land)are defined as CaE:Cashiers sandy loam,30 to 50 percent slopes,
stony. It is assumed for purposes of this evaluation that soils with stony components on slopes
averaging 30 to 50 percent are unsuitable for irrigation application. Based on this information, the
alternative of Spray Irrigation was deemed infeasible.
A copy of the Mitchell County Soil Survey report for the subject area is included in Attachment V.
Drip Irrigation
Utilizing the same information presented above regarding spray irrigation(cost/acre for offsite usage,
non-compatible soils, and topographic slopes in the area), the drip irrigation alternative was also
deemed infeasible.
Alternative C. Wastewater Reuse.
The wastewater reuse alternative was deemed infeasible for many of the same reasons provided in
Alternative B (see above). In addition, the added costs of permitting and compliance for the reuse
system,including monitoring,reporting,and ORC requirements.
Alternative D. Discharge to Surface Waters
The discharge to surface waters alternative was deemed most feasible for this remediation system.
Alternative E. Combination of Alternatives
Due to the fact that discharging to an existing WWTP (Town of Spruce Pines), land application, and
reuse options were deemed infeasible,there is no practical alternative available to use in combination
with the discharge to surface waters option.
Results of the EAA
A Present Value Cost Analysis was performed for the discharge alternative only, as other options
were deemed infeasible for this remediation system.
Page 3 of 5

CO0 WithersRavenel
Our People Your Suaess.
The Present Value Cost Analysis variables are as follows:
Capital Costs:
Land Acquisition Cost=$0(although it should be noted the system does occupy capital space on the
hospital property).
Equipment Costs: $179,000(estimated using current costs of replacement of the existing system).
Range is from$179,000 to$209,000.
Labor Costs: $0,assumed within the original installation.
Installation Costs: $0,assumed within the equipment costs for this system estimate.
Design Costs:$0,assumed within the original installation.
Recurring Costs:
Operation & Maintenance: $80,000 annually. Estimate includes O&M, utilities, laboratory costs,
compliance&reporting,electricity(incurred by hospital).
PVCA Calculation:
PVCA=$179,000+($80,000$/yr x 10 yr)= $179,000+$800,000=$979,000 estimated PVCA.
It should be noted that the PVCA for the discharge option is a value cost that would be needed for each
alternative, since the remediation system generates and treats the recovered groundwater prior to
disposal. Therefore, it can be assumed that the evaluated alternatives for disposal would include the
estimated PVCA,as well as additional costs for influent fees(Alternative A),land acquisition,design,and
permitting(land application, reuse, a combination of alternatives), and would be additional costs above
the PVCA.
Page 4 of 5

1• WithersRavenel
Uw P,oplr YOUI SJCCe<,_
Specifications
The attached Groundwater Remediation System Specifications (Attachment VI) prepared by
S&ME provides details explaining the discharge pathway, design plans for the treatment system,
specifications of the treatment system components, influent analytical data, and a site
map showing the location of the system and associated recovery wells.
Please contact us at your earliest convenience if there are questions regarding the information
contained in this report. We can be reached by phone at (919) 469-3340 or email at
[e-mail] and [e-mail].
Sincerely,
WithersRavenel
G. Matthew James, PG R.S.(Butch) Lawter,Jr., PE
Senior Geologist Director of Environmental Services
Attachments: Attachment I: Application for Coverage Under General Permit NCG510000
Attachment II: Blue Ridge Hospital, Inc.Authorization Email
Attachment III: Letter from Town Manager
Attachment IV: Land Application Exhibit
Attachment V: Mitchell County Soil Survey Report
Attachment VI: Groundwater Remediation System Specifications
Page 5 of 5

ATTACHMENT I
Application for Coverage Under General Permit NCG510000

Division of Water Resources FOR AGENCY USE ONLY
A:17
National/1i
Pollutant Elimination S stem NPDES Discharge Y Date Received
NCDENR Application for Coverage Under General Permit Year Month Day
q i9, 0LID
N C G 510000 Certificate of Coverage
Authorization to Construct groundwater remediation projects designed N C G ; I j Gj
to treat petroleum-contaminated groundwater. Check# Amount
y l , c0,61::)
Assigned To:
NOTICE OF INTENT
[Required by 15A NCAC 02H .0127(d)]; [term definition see 15A NCAC 02H .0103(19)]
(Please print or type)
1) Mailing address of owner/operator(address to which all permit correspondence will be mailed):
RECEIVED
Company Name Blue Ridge Regional Hospital,Inc.
DEC 0 6 2019
Company Contact Jeff Dulaney
Street Address 125 Hosptial Drive NCDEQIDWRINPDES
City Spruce Pine State NC ZIP 28777-3035
Telephone# [phone] Fax
Cell/Mobile# [phone] Email [e-mail]
2) Location of facility producing discharge:
Facility Name Blue Ridge Regional Hospital
Facility Contact Jeff Dulaney
Street Address 125 Hospital Drive
City Spruce Pine State NC ZIP 28777-3035
County Mitchell
Telephone [phone] Fax
3) Physical location information:
Please provide a narrative description of how to get to the facility(use street names,state road numbers,and distance and
direction from a roadway intersection).
From I-240 west, take exit 4A for U.S, 19 N/U.S. 23 N/U.S. 70 W/Interstate 26 toward
Weaverville/Woodfin(0.2 miles), continue onto 1-26 W/US-19 N/US-23 N/US-70 W (18 miles),
take exit 9 for US 19 N/US 23A N toward Burnsville/Spruce Pine(0.3 miles), turn right onto US-
19 N/US-23 ALT(10.7 miles),continue onto US-19E N(19.7 miles),turn right onto Altapass Hwy
(0.2 miles),turn left onto Hospital Drive
(A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with
this application.)
Page 1 of 5 Revised 9/1/13

NCG510000 New Application
4) This NPDES permit application applies to which of the following:
® New[term definition see I5A NCAC 02H .0103(1611 or Proposed
Does the facility have an approved CAP?
❑ Yes -Date approved: Click here to enter a date.
® No—Please contact the Regional Office Groundwater Section to determine the status of CAP approval
and/or authorization to proceed if immediate remediation is recommended.
Regional Office contact person: Scott Ryals,PE
Site Ranking(A-E): Unknown GW incident#: 3659
❑ Modification
Please describe the modification:
❑ Renewal
Please specify existing permit number and original issue date: Click here to enter a date.
5) Does this facility have any other NPDES permits[term definition see 15A NCAC 02H.0103(15)]?
❑ Yes-List the permit numbers for all current NPDES permits for this facility:
® No
6) Description of discharge: [Required by 15A NCAC 02H.0105(c)(1)]
a) Is the discharge directly to the receiving water? ❑Yes ❑No- If no,submit a site map with the pathway to t
potential receiving waters clearly marked.
b) Number of discharge points(ditches,pipes,etc.that convey wastewater from the property): l
c) Volume of discharge per each discharge point(in GPD): <28,800
7) Discharge frequency: [Required by 15A NCAC 02H .0105(c)(1)]
a) The discharge is: ❑ Continuous
❑ Intermittent-Describe when the discharge will occur:
b) What is the source(s)of contamination(i.e.gasoline,diesel,solvents,etc.)?: Heating Oil
General permits may be obtained for gasoline and/or heavy fuel contamination. An individual permit application must
be submitted for sites contaminated with other constituents such as solvents and pesticides.
c) Is free product present?
►mil Yes-Product storage tank and an oil/water separator are required. Free product is defined as any
measurable accumulation of 1/8"or more in a well or floating on surface water.
❑ No
Page 2 of 5 Revised 9/1/13

NCG510000 New Application
8) Treatment system components: [Required by 15A NCAC 02H .0105(c)(3)]
Please note: Final design specifications for the actual system that will be installed must be included in this section.
Do not submit this application if only bid specifications are known.
Check all of the following that apply:
® Oil/Water Separator ® Air Stripper ® Carbon Adsorption ® Filters
❑ Other:
a) If an Oil/Water separator is present,please provide the following information:
i) Rated flow capacity of the unit(in GPM): 34 gpm (a 20 microns to 77 gym(a,30 microns
ii) Volume of unit(gal): 56-gallon sludge collection chamber
iii) Detention time(min): Unknown
iv) Free product disposal method: Gravity to AST
b) If an air stripper is present,please provide the following information:
i) Rated flow capacity of the unit(in GPM): 1 to 125
ii) Air provided for stripping(in CFM): 900
iii) Air to Water ratio: 135:1
iv) Number of trays(if applicable): 3
(Removal efficiencies for all chemicals of concern should be included in this submittal. Efficiencies should
be expressed as a percentage,i.e.98%or 0.98)
c) If carbon adsorption is present,please provide the following information:
i) Rated flow capacity of the unit(s)(in GPM): 75
ii) Number of carbon units and arrangement if number exceeds one(i.e.,in parallel or in series): 2 series
iii) Pounds of carbon in each unit: 1000
iv) Specify carbon breakthrough time: Unknown
(The method used to calculate breakthrough time must included in the submittal.)
d) If filters are used,please provide the following information:
i) Rated flow capacity of each unit(s)(in GPM): Up to 220 gum
ii) Arrangement of particulate filters within the system: ❑ Parallel ® Series
e) Solids disposal method:
f) If other components to be included,please specify: See description of process
9) Receiving waters: [Required by 15A NCAC 02H .0105(c)(1)]
a) What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility wastewater
discharges into? If the wastewater discharge is to a separate storm sewer system(4S),name the operator of the 4S
(e.g.City of Raleigh). Beaver Creek(Stream Indes 7-2-41-(2)1
b) Stream Classification(i.e.WS-IV,C,SA,etc): C Tr
10)Alternatives to direct discharge:
[Evaluation required by G.S. 143-215.1(b)(5)(a)and 15A NCAC 02H .0105(c)(2)1
Address the feasibility of implementing each of the following non-discharge alternatives:
a) Connection to a Municipal or Regional Sewer Collection System
b) Subsurface disposal(including nitrification field,infiltration gallery,injection wells,etc.)
c) Spray irrigation
Page 3 of 5 Revised 9/1/13

NCG510000 New Application
The alternatives to discharge analysis 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. It should also include a present value of costs analysis as outlined in the Division's "Engineering Alternatives
Analysis(EAA)Guidance Document".
Additional Application Requirements:
For new or proposed discharges,the following information must be included in triplicate with this application or it will be
returned as incomplete;per 15A NCAC 02H .0105(cl.
a) 7.5 minute series USGS topographic map(or a photocopied portion thereof)with discharge location clearly indicated.
b) A site map clearly tracing the pathway of the discharged water from the site to its discharge point,if the discharge is
not directly to a stream.
c) If the discharge will cross or empty into any easements, right-of-ways, or other public/private property, i.e. DOT,
utilities, ditches, etc., before entering the permitted discharge stream, proof that approval was received from the
appropriate landowners and/or agencies must be provided prior to issuance of the permit.
d) If this application is being submitted by a consulting engineer(or engineering firm),include documentation from the
applicant showing that the engineer (or firm) submitting the application has been designated an authorized
representative of the applicant;per 15A NCAC 02H .0138(b)(1).
e) Final plans for the treatment system(if application is for a new or modified permit). The plans must be signed and
sealed by a North Carolina registered Professional Engineer and stamped-"Final Design-Not released for
construction;"per 15A NCAC 02H .0139.
f) Final specifications for all major treatment components (if application is for a new or modified permit). The
specifications must be signed and sealed by a North Carolina registered Professional Engineer and shall include a
narrative description of the treatment system to be constructed,per 15A NCAC 02H .0139.
g) Site map identifying the location of the monitoring wells,the recovery wells,and the treatment system unit.
h) Analytical monitoring data which sufficiently characterizes the type and concentration of contaminants on site. This
includes a listing of any chemicals found with the maximum observed concentrations reported. The data provided
must be no older than one year prior to the date of this application. At a minimum,the following parameters must
be reported: Benzene,Toluene,Ethylbenzene,Xylene,Lead,Phenol,MTBE,and 1,2-Dichlorethane.
Page 4 of 5 Revised 9/1/13

NCG510000 New Application
CERTIFICATION
I certify that I am familiar with the information contained in this application and that to the best of my knowledge
and belief such information is true,complete,and accurate.
Printed Name of Person Signing: R.S.(Butch)Lawter,Jr.,PE
Title: WithersRavenel,Inc.,Director of Environmental Services
(Please review 15A NCAC 02H .0106(e)for authorized signing officials)
December 3, 2019
(Signature of Applicant) (Date Signed)
North Carolina General Statute 6 143-215.6B provides that:
Any person who knowingly makes any false statement representation,or certification in any application,record,report,
plan,or other document filed or required to be maintained under this Article or a rule implementing this Article;or who
knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article;or
who falsifies,tampers with,or knowingly renders inaccurate any recording or monitoring device or method required to be
operated or maintained under this Article or rules of the Commission implementing this Article,shall be guilty of a Class
2 misdemeanor which may include a fine not to exceed ten thousand dollars($10,000). 18 U.S.C.Section 1001 provides
a punishment by a fine or imprisonment not more than 5 years,or both,for a similar offense.
♦ ♦ ♦ ♦ ♦
This application must be accompanied by a check or money order for$100.00 [per G.S.§143-215.3(a)(lb)l
made payable to:
NCDENR
♦ ♦ ♦ ♦ ♦
Mail this application and one copy of the entire package(with check)to:
NC DENR/DWR/Water Quality Permitting Section
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Attn: Charles Weaver
Final Checklist
This application will be returned as incomplete,as allowed by 15A NCAC 02H.0107(b),unless all of the
following items have been included:
[dJ Complete application with all supporting documents(plus one copy of entire package)
[�Check or money order for$100.00,payable to NCDENR
El 3 copies of county map or USGS quad sheet with location of facility clearly marked on map
g 3 sets of plans and specifications signed and sealed by a North Carolina P.E.(if new or modified permit)
Thorough responses to items 1-11 on this application
2 Alternatives analysis including present value of costs for all alternatives
Note: The submission of this document does not guarantee the issuance of an NPDES permit.
Page 5 of 5 Revised 9/1/13

ATTACHMENT II
Blue Ridge Hospital, Inc. Authorization Email

•
Archived:Thursday,April 26,2018 2:01:34 PM
From:Jeff Dulaney
Sent:Thursday,April 19,2018 5:19:43 PM
To: Bradley S. Keyse
Cc: David Louis;Michael Mace
Subject:RE:Blue Ridge Hospital Permit
Importance: Normal
Yes please submit permit application. I am unaware of other NPDES permits associated with this facility. Thanks
From:Bradley S.Keyse[mailto:[e-mail]]
Sent:Thursday,April 19,2018 1:36 PM
To: Jeff Dulaney <[e-mail]>
Cc:David Loftis<[e-mail]>
Subject:[EXTERNAL]Blue Ridge Hospital Permit
Jeff,
Will you confirm that the Blue Ridge Hospital,Inc.authorizes S&ME to submit the NPDES permit application for the groundwater remediation system at 125 Hospital
Drive in Spruce Pine,NC on behalf of Blue Ridge Hospital, Inc.?
Also do you know of any other NPDES permits associated with the hospital?
Thank you,
Bradley S. Keyse, E.I.
Environmental Staff Professional
IMP S&ME
Ionia & 44 Buck Shoals Road,Suite C-3
mom Arden,NC 28704 map
0:828.483.3013
I " M: 828.329.3367
maw wwwsmeinc.com
linkedln I Twitter I Facebook
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ATTACHMENT Ill
Letter from William Hunneke

STATE°N.
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL SCOTT
Director
November 26, 2019
Memorandum
To: Mr. Derek Denard
From: William Hunneke, Head Trust Fund Branch UJY
Through: Z. Vance Jackson, Jr., Chief, UST Section
Subject: Blue Ridge Hospital, Spruce Pine NC, NOP S ermit
After the UST Section was informed that the previous NPDES permit had been
mistakenly deactivated due to an error of the former Asheville Regional Office
supervisor, the UST Section undertook to re-establish the permit. The Division of
Water Resources, DWR, indicated that a new permit application was needed.
During the new application, the DWR inquired about alternatives to the NPDES
permit. For the past year, the UST Section has been trying to work with the hospital
and the Town of Spruce Pine to determine if the discharge waters from the
remedial system could be discharged to the Town of Spruce Pine's publicly owned
treatment facility. At this time, no progress or even response has been made or
received.
The DWR has indicated that they can no longer continue to allow the remedial
system to continue to operate without a permit. The UST Section has been
working closely with the hospital and their attorney and has been unable to receive
any correspondence on this issue form the town or their POTW operator. As a
result, the UST Section would like the DWR to accept this letter as a denial from
the Town of Spruce Pine for the alternative discharge to the POTW so that the
NPDES permit can be issued.
Cr)'13:.E
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1646 Mail Service Center I Raleigh.North Carolina 27699-1646
919.707.8200

ATTACHMENT IV
Land Application Exhibit

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SPRUCE PINE,MITCHELL COUNTY,NC
111111 Engineers I Planners 1 Surveyors APPROVED BY DATE: PROJECT NO.
11S ICary NC2751th 919469.5340I1cenu# -OA,2I GENERAL LOCATION MAP M1 3/29/19 02171214.41
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