NC0051322_Permit Issuance_20051114

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Mr. Jim Highley
Carolina Water Service, Inc.
P.O. Box 240908
Charlotte, North Carolina 28224
Dear Mr. Highley:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
November 14, 2005
Subject: NPDES Permit Issuance
Permit No. NCO051322
Ashley Hills WWTP
Wake County
Alan W. Klimek, P.E., Director
Division of Water Quality
Division personnel have reviewed and approved your application for expansion of the subject
treatment system. Accordingly, we are forwarding the attached NPDES discharge permit. 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 May 9, 1994 (or as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless
such demand is made, this decision shall be 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 Quality or
permits required by the Division of Land Resources, the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Teresa Rodriguez at telephone
number [phone], extension 553.
Sincerely,
4r , Alan W. Klimek, P.E.
Cc: NPDES Files
Raleigh Regional Office
Constuction Grants and Loans Section
John F. Phillips - Diehl & Phillips, P.A.
219 E. Chatham Street
Cary, North Carolina 27511
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper
NorthCarolina
Customer Service
1-877-623-6748

Permit NCO051233
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision 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,
Carolina Water Service, Inc. of NC
is hereby authorized to discharge wastewater from a facility located at the
Ashley Hills WWTP
NCSR 2233 south of Knightdale
Wake County
to receiving waters designated as the Poplar Creek in the Neuse 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 effective December 1, 2005.
This permit and authorization to discharge shall expire at midnight on March 31, 2008.
Signed this day November 14, 2005.
/1 - te � I
Alan W. Klimek, P.E., Di ector
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0051233
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.
Carolina Water Service, Inc. of NC is hereby authorized to:
1. Continue to operate an existing 0.25 MGD wastewater treatment system with the
following components:
➢ Bar screen
➢ Splitter Box
➢ Surge Tank
➢ Diffused aeration basin
➢ Clarifier
➢ Sludge Holding Tank
➢ Chlorination
➢ Flow Measurement
➢ Post Aeration Tank
The facility is located south of Knightdale at the Ashley Hills Subdivision on NCSR
2233 in Wake County.
2. After receiving an Authorization to Construct from the Division, construct and
operate a 0.495 MGD wastewater treatment system.
3. Discharge from said treatment works at the location specified on the attached map
into Poplar Creek, classified C-NSW waters in the Neuse River Basin.

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CWS - Ashley Hills WWTP
Facility Location
State Grid/Quad: D25SW/Knightdale Latitude: 35' 45' 23" N not to scale
Longitude: 78' 28' 07" W
Receiving Stream: Poplar Creek Drainage Basin: Neuse River NPDES Permit No. NCO051322
Stream Class: C - NSW Sub -Basin: 03-04-02 c rth
I V 1 / Wake County

Permit NCO051233
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(0.25 MGD)
During the period beginning on the effective date of this permit and lasting until expansion
above 0.25 MGD or expiration, the Permittee is authorized to discharge- from outfall 001. Such
discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
Monthly
Daily
Measurement
Sample Type
Sample Location'
CHARACTERISTICS
Average
Maximum
Frequency
Flow
0.25 MGD
Continuous
Recording
Influent or Effluent
Total Monthly Flow
Monitor & Report
Monthly
Calculated
Influent or Effluent
BOD, 5-day (20°C)
5.0 mglL
7.5 mg/L
3/Week
Composite
Effluent
(April 1- October 31)
BOD, 5-day (20°C)
10.0 mg/L
15.0 mg/L
3Meek
Composite
Effluent
(November 1- March 31)
Total Suspended Residue
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent
NH3 as N
2.4 mglL
12.0 mglL
3/Week
Composite
Effluent
(April 1 - October 31)
NH3 as N
8.7 mg/L
35.0 mg/L
3Meek
Composite
Effluent
(November 1 - March 31)
Dissolved Oxygen2
3Meek
Grab
Effluent, Upstream &
Downstream
Fecal Coliform
200 / 100 ml
400 / 100 ml
3Meek
Grab
Effluent
(geometric mean)
Total Residual Chlorine
28 Ng/L
3/Week
Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
Temperature (°C)
3Meek
Grab
Upstream & Downstream
TKN
Monitor & Report (mg/L)
Weekly
Composite
Effluent
NO2-N + NO3-N
Monitor & Report (mg/L)
Weekly
Composite
Effluent
TN3
Monitor & Report (mg/L)
Monthly
Composite
Effluent
Monitor & Report (lb/month)
Monthly
Calculated
Effluent
TN Load4
Monitor & Report (lb/year)
Annually
Calculated
Effluent
Total Phosphorus5
2.0 mg/L
Monthly
Composite
Effluent
pHs
I
Weekly
Grab
Effluent
Footnotes:
1. Upstream - at least 200 feet upstream from the outfall. Downstream - at NCSR 2049.
2. The Daily Average dissolved oxygen effluent concentration shall not be lass than 5 mg/L.
3. For a given wastewater sample, TN = TKN + NO2-N + NO3-N, where TN is Total Nitrogen and TKN is Total
Kjeldahl Nitrogen.
4. TN Load is the mass load of Total Nitrogen discharged in a given period of time [see condition A. (3)]. The
annual TN Load limit shall become effective with the calendar year beginning on January 1, 2003.
Compliance with this limit shall be determined in accordance with condition A. (4).
5. The quarterly average for total phosphorus shall be the average of composite samples collected during each
calendar quarter (January -March, April -June, July -September, October -December).
6. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO051233
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(0.495 MGD)
During the period beginning upon expansion above 0.25 MGD and lasting until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
Monthly
Daily
Measurement Sample Type Sample Location'
CHARACTERISTICS
Average
Maximum
Frequency
Flow
0.495 MGD
Weekly Instantaneous Influent or Effluent
Total Monthly Flow
Monitor & Report
Monthly Calculated Influent or Effluent
BOD, 5-day (20°C)
5.0 mg/L
7.5 mg/L
3/Week Composite Effluent
(April 1— October 31)
BOD, 5-day (20°C)
10.0 mg/L
15.0 mg/L
3/Week Composite Effluent
(November 1— March 31)
Total Suspended Residue
30.0 mg/L
45.0 mg/L
3/Week Composite Effluent
NH3 as N
1.7 mg1L
8.5 mg/L
3/Week Composite Effluent
(April 1— October 31)
NH3 as N
5.3 mg/L
26 mg/L
3/Week Composite Effluent
(November 1 — March 31)
Dissolved Oxygen2
3/Week Grab Effluent, Upstream &
Downstream
Fecal Coliform
200 / 100 ml
400 / 100 ml
3/Week Grab Effluent
(geometric mean)
Total Residual Chlorine
28 Ng/L
3/Week Grab Effluent
Temperature (°C)
Daily Grab Effluent
Temperature (°C)
3/Week Grab Upstream & Downstream
TKN
Monitor & Report (mg/L)
Weekly Composite Effluent
NOrN + NO3-N I
Monitor & Report (mg/L)
Weekly Composite Effluent
TN3
Monitor & Report (mg/L)
2/Month Composite Effluent
TN Load4
Monitor & Report (lb/month)
Monthly Calculated Effluent
5,055lb/year (annual load)
Annually Calculated Effluent
Total Phosphorus5
1.0 mg/L (quarterly average)
Weekly Composite Effluent
PH6
I I
3/Week Grab Effluent
Footnotes:
1. Upstream - at least 200 feet upstream from the outfall. Downstream - at NCSR 2049.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
3. For a given wastewater sample, TN = TKN + NO2-N + NO3-N, where TN is Total Nitrogen and TKN is Total
Kjeldahl Nitrogen.
4. TN Load is the mass load of Total Nitrogen discharged in a given period of time [see condition A. (3)]. The
annual TN Load limit shall become effective with the calendar year beginning on January 1, 2003.
Compliance with this limit shall be determined in accordance with condition A. (4)..
5. The quarterly average for total phosphorus shall be the average of composite samples collected during each
calendar quarter (January -March, April -June, July -September, October -December).
6. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO051233
A. (3) CALCULATION OF TOTAL NITROGEN LOADS
a. The Permittee shall calculate monthly and annual TN Loads as follows:
L Monthly TN Load (pounds/month) = TN x TMF x 8.34
Where:
TN = average TN concentration (mg/L) of the composite samples collected during the month
TMF = Total Monthly Flow of wastewater discharged during the month (MG/month)
8.34 = conversion factor, from (mg/L x MG) to pounds
H. Annual TN Load (pounds/year) = Sum of the 12 Monthly TN Loads for the
calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/L and pounds/month) in
the discharge monitoring report for that month and shall report each year's annual
results (pounds/year) in the December report for that year.
A. (4) ANNUAL LIMITS FOR TOTAL NITROGEN
(a) TN limits for NPDES dischargers in the Neuse River basin are as prescribed in the
basin's Nutrient Management Strategy rule for wastewater treatment facilities, T15A
NCAC 213 .0234.
(b) The Permittee's TN discharge is governed by this Permit unless the Permittee is a
member and co-permittee of an approved compliance association, in which case its TN
discharge is governed by the association's group NPDES permit and the limits therein.
(c) TN limits for NPDES dischargers in the Neuse River basin are annual, calendar -year
limits. All such limits in effect on January 1 of a given year remain in effect for the
entire calendar year. Changes in TN limits become effective on January 1 of the year
following permit modification and remain in effect for the full year. Similarly, changes in
membership in a compliance association become effective on January 1 of the year
following the change and remain in effect for the full year.
(d) For any given calendar year, the Permittee shall be in compliance with the annual TN
Load limit in this Permit if:
(1) the Permittee's annual TN Load is less than or equal to said limit, or
(2) the Permittee is a Member of a compliance association and a Co-Permittee to the
association's group NPDES permit.
(e) The Permittee's effective TN limit (if any) may change due to changes in its TN allocation
or membership changes in a compliance association.
(1) The Permittee may notify the Division and request a modification of this Permit to
incorporate allowable changes in its TN Load limit. Allowable changes include those
resulting from purchase of TN allocation from the Wetlands Restoration Fund;
purchase, sale, trade, or lease of allocation between the Permittee and other
dischargers; regionalization; and other transactions approved by the Division.
(2) If the Permittee intends to join or leave a compliance association, the Division must
be notified of the proposed change.
(3) Upon receipt of timely and proper notification, the Division will modify the affected
permit(s) as necessary to incorporate the allowable changes in TN limits or to reflect
the change in membership.
a. The Division must receive notification no later than August 31 for changes
proposed for the following calendar year.
b. Notification shall be sent to:
NCDWQ / NPDES Unit
Attn: Neuse River Basin Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
(fJ For the purpose of permit compliance, an association's Co-Permittee Members in a
calendar year (and the Permittee's membership status) shall be as defined in its group
NPDES permit. The roster and the members' TN allocations will be updated annually
and in accordance with state and federal program requirements.
(g) The TN monitoring and reporting requirements in this Permit remain in effect until
expiration of this Permit and are not affected by the Permittee's membership in a
compliance association.

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] — Fax [phone]
November 9, 2005
Ms. Teresa Rodriguez
Environmental Engineer
Point Source Section, DWQ
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Requested Supplemental Information
EAA for Ashley Hills WWTP, NPDES Permit NCO051322
Carolina Water Service, CWS
Dear Ms. Rodriguez:
WILLIAM C. DIEHL, P.E.
JOHN F. PIULIPS, P.E.
ALAN R. KEnTL P.E.
In response for your request for additional information for the above referenced EAA, I am
submitting a copy of my letter to Knightdale (dated October 25, 2005), and a copy of the
response letter from Mr. Chris Scott of the Town of Knightdale (dated November 9, 2005).
The EAA did not include a detailed evaluation of the alternative to connect to the
Knightdale wastewater system because the Town's wastewater system masterplan indicated
they would not serve the Ashley Hills area until 20+ years from now. The Town had also
indicated, at the time of the EAA preparation, that they would possibly be a capacity
problem if they accepted the flow. That question has since been resolved since the merger
of Raleigh and Knightdale's utilities systems.
The attached response indicates that the Town of Knightdale will not accept the flow from
Ashley Hills at this time. Therefore, based on this confirmation of the Town's position, we
request the EAA be accepted as complete, and that the Division issue the expanded NPDES
permit.
Thank you for your assistance in this matter,
Cc: Mr. Richard Stockett
Mr. Jim Highley
Yours very truly,
Diehl & Phillips, P.A.
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John F. Phillips, P.E.
In ,
NOV 1 0 2005
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TOWN OF KNIGHTDALE
PLANNING DEPARTMENT
950 Steeple Square Court • Knightdale, NC 27545
Office [phone] r Fax [phone]
chns.scwlw ci.kmVhldale.nc.uS
November 9, 2005
John F. Philips, P.E.
Diehl & Phillips, P.A.
219 East Chatham Street
Cary, North Carolina 27511
Mr. Philips:
Pursuant to your letter dated October 25, 2005, the Town is not in a position to accept 250,000
gpd of untreated wastewater from the Ashley Hills Wastewater Treatment Plant at this time. At
this time, no public service is located near the subdivision, and the Town would not accept a
force main connection to our Mingo Creek Trunk Line. Ashley Hills is located within the
Town's Urban Services Area, and will eventually be able to connect to public sewer services
once they are extended to this area and the appropriate connection fees are paid.
Should you require additional information, please let me know.
Sincerely,
t�FCA47)�—
ChristopherO. Scott, AICP
Planner II — Current Planning

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] — Fax [phone]
October 25, 2005
Mr. Chris Scott, Planner II
Town of Knightdale
950 Steeple Square Court
Knightdale, NC 27545
Re: Wastewater Service for Ashley Hills and Adjacent Areas
Dear Mr. Scott:
WILLIAM C. DIEHL, P.E.
JOHN F. PHILLIPS, P.E.
ALAN R. KEITIL P.E.
Last fall you and I briefly discussed the existing wastewater treatment plant that serves
Ashley Hills and some of the adjacent neighborhoods. This facility is owned and operated
by Carolina Water Service (CWS), and is permitted to discharge into Poplar Branch. As a
part of the discharge permit expansion process, CWS is required to examine the feasibility
of all possible alternatives to discharging treated wastewater into the stream. These
alternatives typically include land applying the treated wastewater using a spray irrigation
system, disposing of the treated wastewater via subsurface systems, or pumping the
untreated wastewater to the nearest municipal treatment system.
I contacted you last fall to explore whether a pumped connection from the plant to
Knightdale's collection system was a concept that might be considered, or whether the
location of the subdivisions served would conflict with the Town's growth plans, utility
expansion plans, etc. We discussed that a previously prepared study for the Town indicated
municipal wastewater service was not planned for this area until 2027, and we also
discussed whether the Town had the 250,000 gallons per day capacity that would be
required.
My conclusion from our previous conversation was that the Town did not have plans to
serve the Ashley Hills area until 2027, and that the Town would not look favorably on a
request to accept 250,000 gallons of wastewater pumped from that area. The report I
submitted to the Division of Water Quality stated that the alternative of pumping 250,000
gpd to Knightdale did not appear feasible.
DWQ has now asked me to provide additional information regarding this alternative. To
clarify this matter, I need you or whomever you believe to be the appropriate person within
the Town staff, to respond to the following questions:

Mr. Chris Scott
October 25, 2005
Page 2
Would the Town of Knightdale be willing to accept, at this time, 250,000
gpd of untreated wastewater from the Ashley Hills Wastewater Treatment
Plant? If the answer is no, I would request a brief letter simply stating that
response.
If the answer is the Town would accept this flow at this time, I need to know
what charges would be assessed, and where the forcemain should discharge
into the Town's collection system. The pumping rate would be
approximately 438 gallons per minute, so the capacity of the receiving line
would have to be verified. We would then use this information to estimate
the costs for this alternative, and compare that costs to the cost of the other
alternatives.
I want to emphasize that this is only a request for information needed for us to respond to
DWQ's questions. We are not making a formal request for capacity on behalf of CWS.
Please contact me if you have any questions in this matter. Again, I appreciate your
assistance in this matter.
Yours very truly,
Diehl & Phillips, F.A.
John F Phillips, P.E.

Neuse Basin Nutrient Strategy: As per nutrient strategy for the Neuse River a total nitrogen
allocation is assigned to this facility. The total nitrogen allocation for Ashley Hills is 5,055 lb/yr. The
permit will include a TN limit of 5,055 Ib/yr and a total phosphorus limit of 1 mg/L.
Proposed changes:
Proposed limits for 0.495 MGD:
o BOD5 summer limits of 5.0 mg/L monthly aver, 7.5 mg/L daily max and winter limits of
10.0 mg/L monthly aver, 15.0 mg/L daily max. Limits are based on Level B modeling of
the receiving stream.
o TSS limits of 30 mg/L monthly aver and 45 mg/L daily max. Limits are secondary
standard limits.
o Total nitrogen limit of 5,055 lb/yr. This limit corresponds to the Total Nitrogen allocation
for Ashley Hills according to the Neuse River Rules.
o Total Phosphorus limit of 1 mg/L (quarterly Average) according to the Neuse River Rules.
• The effluent page for the flow of 0.125 MGD was eliminated from the permit. The capacity of the
existing plant is 0.25 MGD.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
NPDES DIVISION CONTACT
September 14, 2005
November 7, 2005
If you have questions regarding any of the above information or on the attached permit, please
contact Teresa Rodriguez at [phone] ext. 553.
NAME: DATE:
REGIONAL OFFICE COMMENTS
RRO has examined the draft permit and the EAA originally submitted. Our primary concern
is the lack of a present worth analysis for alternative 1, connection to a POTW. The
comments for this alternative on Sheet A-1 state that "a 245,000 gpd allocation would
exceed the Town's currently available capacity." While this might have been true at the time
of preparation of the EAA, and might even be true today, the Town of Knightdale purchases
allocation from the City of Raleigh. If they do not have sufficient allocation, the EAA needs
to include the cost of purchase of additional allocation.
We might also consider that the new 64 bypass, located a few thousand feet from the
treatment plant, will undoubtedly bring with it an expansion of water and wastewater
services beyond that ever proposed in the Town's master plan.
NAME: Barry Herzberg _ DATE: October 4, 2005
SUPERVISOR:
DATE:
Fact Sheet
NPDES NCO051322
Page 2

AFFIDAVIT OF PUBLICATION
NORTH CAROLINA.
Wake County.) Ss.
PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION/
'NPDES UNIT
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617 -
NOTIFICATION'OF INTENT TO ISSUE
A NPDES WASTEWATER PERMIT
On the basis of thorough staff review and application of NC
General Statute 143.21. Public law 92-500 and other lawful
standards and regulations, the North Carolina Environ-
mental Management Commission proposes to issue a
National Pollutant Discharge Elimination System
(NPDES) wastewater discharge permit to the Persons)
listed below effective 45 days from the publish -date of this
notice.
Written comments regarding the proposed permit will be
accepted unti 130 days after the publish date of this notice.
AI I comments received prior to that date are considered in
the final determinations regarding the Proposed Permit.
The Director of the NC Division of Water quality may
decide to hold a public meeting for the proposed permit
should the Division receive a significant degree of public
interest. ' _ - _
Written comments regarding the proposed Permit will be
accepted until 30 days after the publish -date of this notice.
Al I comments received prior to that date are considered in
the final determinations regarding the proposed permit.
The Director of the NC Division of Water Duality may
decide to hold a public meeting for the proposed permit
should the Division receive a significant degree of public
interest.
Copies of the draft permit and other supporting Informa-
tion on file used to determine conditions present in the
draft permit are available upon request and payment of
the costs of reproduction. Mail comments and/or requests
for information to the NC Division of Water Quality at the
above address or call the Point Source Branch at (919)
73-5083, extension 520. Please include the NPDES permit
number (attached) in any communication. Interested
Persons may also visit the Division of Water Quality at 512
N. Salisbury Street, Raleigh, NC'27604-1148 between the
hours of 8:00 a.m. and 5:00 p.m. to review information on
file.
NPDES Permit Nbmber-NC0051322, Carolina Water Ser-
vice, Inc., of North Carolina, Inc. (Ashley Hills Subdivi-
sion) has applied for a permit expansion to 0.495 MGD fora
facility located in Wake County discharging treated waste-
water into Poplar Creek in the Neuse River Basin.
Currently; ammonia, fecal col(form and total residual
chlorine are water quality limited. This discharge may
affect future allocations in this Portion of the receiving
stream.
N&O: September 19, 2005 ,
Before the undersigned, a Notary Public of Chatham
County North Carolina, duly commissioned and authorized to
administer oaths, affirmations, etc., personally appeared Debra
Peebles, who, being duly sworn or affirmed, according to law,
doth depose and say that she is Billing Manager -Legal
Advertising of The News and Observer a corporation
organized and doing business under the Laws of the State of
North Carolina, and publishing a newspaper known as The
News and Observer, in the City of Raleigh , Wake
County and State aforesaid, the said newspaper in which such
notice, paper, document, or legal advertisement was published
was, at the time of each and every such publication, a
newspaper meeting all of the requirements and qualifications
of Section 1-597 of the General Statutes of North Carolina and
was a qualified newspaper within the meaning of Section 1-
597 of the General Statutes of North Carolina, and that as such
she makes this affidavit; that she is familiar with the books,
files and business of said corporation and by reference to the
files of said publication the attached advertisement for NC
DIVISION OF WATER QUALITY was inserted in the
aforesaid newspaper on dates as follows: 09/19/05
Account Number: 73350831
The above is correctly copied from the books and files of the aforesaid Corporation and publication.
/'_� /Al 1'�141 '0
I SO
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µotoh,
15
4 14 boo
Ucu,�'-fie — —
Billing Manager -Legal Advertising
Sworn or affirmed to, and subscribed before me, this
20 day of SEPTEMBER , 2005 AD
In Testimony Whereof, I have hereunto set my hand
and affixed my official seal, the day and year aforesaid.
_
................... C............_.,,..............
Notary Public
My commission expires le of March 2009.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO051322
Facility Information
Applicant/Facility Name:
Carolina Water Service / Ashley Hills WWTP
Applicant Address'
P.O. Box 240908, Charlotte, NC 28224
Facility Address:
NCSR 2233 South of Knightdale, North Carolina
Permitted Flow (MGD):
0.25
Type of Waste:
Domestic/Subdivison
Facility Classification:
II
Permit Status: `
Expansion to 0.495 MGD
County:
Wake
Miscellaneous
Receiving Stream:
Poplar Creek
Regional Officer
Raleigh
Stream Classification:
C NSW
State Grid / USGS Quad:
Knightdale / D25SW
W3(d) Listed?
No
Permit Writer:
Teresa Rodriguez
Basin/Subbasin:
030402
Date:
9/2/05
Drainage Area (mi2):
5.5
Lat. 350 45' 23" N Long. 780 28' 07" W
Summer 7Q10 (cfs)..
0.7
Winter 7Q10 (cfs):
1.7
30Q2 (cfs)
6
Average Flow (cfs):
2
IWG (%):
35
Summary: Carolina Water Service submitted a request for an expansion of the Ashley Hills
WWTP from 0.25 MGD to 0.495 MGD. The Ashley Hills WWTP serves several subdivisions in
Knightdale. The expansion is to accommodate 635 new homes. The engineering alternatives
analysis evaluated connection to an existing treatment system, subsurface system, spray irrigation,
drip irrigation and expansion of the treatment system. Connection to the Knightdale WWTP is not
possible because there is no capacity available and the plans to extend service to the area delay
the connection until 2027. Land application alternatives and expansion of the existing treatment
system were considered feasible alternatives. The most economic and environmentally feasible
alternative is the expansion of the existing system.
The existing treatment system consists of: bar screen, 75,000 gal flow equalization basin, 250,000
gal aeration basin, three clarifiers, three tertiary filters, UV disinfection, and sludge holding tank.
The proposed expansion will include a denitrification filter to meet the total nitrogen limits. To meet
the total phosphorus limit the current method of precipitation by chemical addition will be continued.
A level B model was used to evaluate the effects of the increased discharge to Poplar Creek. The
results of the model indicate that summer limits of 5 mg/L for BOD, 1.7 mg/L ammonia and 5 mg/L
dissolved oxygen will protect the receiving stream.
Basin Plan: Poplar Creek is classified as supporting in the Neuse River Basin Plan and is not listed
as impaired in the 303(d) list.
Fact Sheet
NPDES NCO051322
Page 1

Neuse Basin Nutrient Strategy: As per nutrient strategy for the Neuse River a total nitrogen
allocation is assigned to this facility. The total nitrogen allocation for Ashley Hills is 5,055 lb/yr. The
permit will include a TN limit of 5,055 Ib/yr and a total phosphorus limit of 1 mg/L.
Proposed changes:
Proposed limits for 0.495 MGD:
o BOD5 summer limits of 5.0 mg/L monthly aver, 7.5 mg/L daily max and winter limits of
10.0 mg/L monthly aver, 15.0 mg/L daily max. Limits are based on Level B modeling of
the receiving stream.
o TSS limits of 30 mg/L monthly aver and 45 mg/L daily max. Limits are secondary
standard limits.
o Total nitrogen limit of 5,055 lb/yr. This limit corresponds to the Total Nitrogen allocation
for Ashley Hills according to the Neuse River Rules.
o Total Phosphorus limit of 1 mg/L (quarterly Average) according to the Neuse River Rules.
The effluent page for the flow of 0.125 MGD was eliminated from the permit. The capacity of the
existing plant is 0.25 MGD.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
NPDES DIVISION CONTACT
September 14, 2005
November 7, 2005
If you have questions regarding any of the above information or on the attached permit, please
contact Teresa Rodriguez at [phone] ext. 553.
NAME: �L DATE:
REGIONAL OFFICE COMMENTS
NAME:
TE:
SUPERVISOR: DATE:
Fact Sheet
NPDES NCO051322
Page 2

LEVEL B MODEL INFORMATION
Faci14ty information
Fk)w information
Facility Name
Ashley Hills
Topo Quad
Knightdale
NPDES No.
NCO051322
USGS sta. #
2087080
Type of wastewater
Domestic
Date of flow estimate
Facility status
Ex ansion to 0.495
Drainage Area (mi)
5.4
Receiving stream I
Poplar Creek
Summer7Q10 (cfs)
0.7
Stream class
C-NSW
Winter7Q10 (cfs)
1.7
Subbasin
030402
Average flow (cfs)
2
County
Wake
30Q2 (cfs)
6
Regional Office
RRO I
IWC at discharge (%)
52
Segment/Reach
S1 R1
IS1 R2
Length of reach (mi)
0.5
2.7
Incremental length
0.05
0.27
I Waste. characteristics
WWTP name
Cottonwood
Ashley Hills
Flow MGD)
0.0575
0.495
BOD
10
5
Multiplication factor
1.5
1.5
CBOD (mg/1)
15
7.5
NH3N
4
1.7
Multiplication factor
4.5
4.5
NBOD(mg/1)
18
7.65
DO (mg/1)
6
5
Runoff charactericstics
s7Q10 (cfs/mi)
0.7
0.179
QA cfs/mi
5
1.43
CBOD(mg/1)
NBOD (mg/1)
DO (mg/1)
Tributary characteristics
Trib name
s7Q10 cfs/mi)
QA (cfs/mi)
CBOD (mg/1)
NBOD (mg/I
DOm/l
Slope ft/mi
361
15
File Name: ASH1

DR=
3,!(© ml z
"IglO =
0.'35 Cis
w'1 Q10
0, atc
oZ.a�7yc�rvv -
DAV
sAQ lO =
(),l
jOQ z jr
Z. D
Q.w -
ca tf,
NC OO toy -1O (o.
�.ofbnwood u�� ��
NN3
H.sh1,1 HO-5 �r?' —
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00 a Q:D$ hni Z
s7q to
al Q to
30Cp Z-_ .5 cis
Q ai t en s
(�Ia J, I

( LnOR- -
izi-a.cl, f
s q Ru 0.g _ p,� of
•S
I.lo'f
—:179
.,79
9 — /, L p.y3
0—�s

SUMMER
ASH1
MODEL RESULTS
Discharger
:
ASHLEY HILLS WWTP
Receiving Stream :
POPLAR CREEK
----------------------------------------------------------------------
The End D.O.
is 7.50
mg/l.
The End CBOD
is 3.38
mg/l.
The End NBOD
----------------------------------------------------------------------
is 2.72
mg/l.
WLA
WLA
WLA
DO Min
CBOD
NBOD
DO
Waste Flow
(mg/1)
------
Milepoint Reach #
----------------
(mg/1)
----
(mg/1)
(mg/1)
(mgd)
Segment 1
6.26
0.50 2
----
--
----------
Reach 1
15.00
18.00
6.00
0.05750
Reach 2
7.50
7.65
5.00
0.49500

SUMMER
Seg #
Reach #
Seg Mi I
D.O.
CBOD
NBOD
Flow
1
1
0.00
6.93
4.64
4.45
0.44
1
1
0.05
7.05
4.40
4.12
0.47
1
1
0.10
7.15
4.19
3.83
0.51
1
1
0.15
7.22
4.01
3.58
0.54
1
1
0.20
7.28
3.85
3.36
0.58
1
1
0.25
7.33
3.71
3.17
0.61
1
1
0.30
7.38
3.58
3.00
0.65
1
1
0.35
7.41
3.47
2.84
0.68
1
1
0.40
7.44
3.36
2.70
0.72
1
1
0.45
7.47
3.27
2.57
0.75
1
1
0.50
7.49
3.18
2.46
0.79
1
2
0.50
6.26
5.31
5.02
1.56
1
2
0.77
6.69
5.05
4.70
1.60
1
2
1.04
6.95
4.81
4.40
1.65
1
2
1.31
7.12
4.59
4.13
1.70
1
2
1.58
7.23
4.38
3.88
1.75
1
2
1.85
7.31
4.18
3.65
1.80
1
2
2.12
7.36
4.00
3.43
1.85
1
2
2.39
7.40
3.83
3.23
1.89
1
2
2.66
7.44
3.67
3.05
1.94
1
2
2.93
7.47
3.52
2.88
1.99
1
2
3.20
7.50
3.38
2.72
2.04
Seg #
Reach #
Seg Mi
D.O.
CBOD I
NBOD
Flow

*** MODEL SUMMARY DATA ***
Discharger : ASHLEY HILLS WWTP
Receiving Stream : POPLAR CREEK
Summer 7Q10 : 0.35
Design Temperature: 27.0
Subbasin : 030402
Stream Class: C NSW
Winter 7Q10 : 0.88
SLOPEI
VELOCITY
DEPTH
Kd
Kd
Ka
Ka
KNI
--------------------------------------------------------------------------------
ILENGTHI
mile
ft/mi
fps
I ft
I design I
@20°
Idesigni
@20°
I design
Segment 1
0.50
36.00
0.141
0.54
0.45
0.33
10.64
9.13
0.86
Reach 1
--------------------------------------------------------------------------------
Segment 1
I 2.70I
15.00I
0.205 10.77
10.38
10.28
16.43 I
5.521
0.51 I
Reach 2
Flow
cfsI
mg/l
I mg/l I
mg/1
Segment 1
Reach 1
Waste
0.089
15.000
18.000
6.000
Headwaters
0.350
2.000
1.000
7.170
Tributary
0.000
2.000
1.000
7.170
* Runoff
0.700
2.000
1.000
7.170
Segment 1
Reach 2
Waste
0.767
7.500
7.650
5.000
Tributary
0.000
1
2.000
1.000
7.170
* Runoff
0.179
2.000
1.000
7.170
* Runoff flow is in cfs/mile

AIIWastConc-NH3 TRC.XLS
Allowable Waste Concentration
Facility Ashley Hills
NPDES Number NCO051322
SUMMER
WINTER
Ammonia as NH3
Ammonia as NH3
7Q10(cfs) 0.7
7Q10(cfs)
1.7
Design Flow (MGD) 0.495
Design Flow (MGD)
0.495
Design Flow (cfs) 0.76725
Design Flow (cfs)
0.76725
Stream Std (mg/1) 1.0
Stream Std (mg/1)
1.8
ups Bckgmd Lvl (mg4 0.22
ups Bckgrnd Lvl (mg
0.22
IWC % 52.292
IWC %
31.097
Allow Conc. (mg/1) 1.71
Allow. Cone. (mg/1)
5.30
Resdual. Chlorine
7Q10(cfs) 0.7
Design Flow (MGD) 0.495
Design Flow (cfs) 0.76725
Stream Std (ug/1) 17.0
ups Bckgrnd Lvl (ug/I 0.0
IWC (%) 52.292
Allow Conc. u /l) 32.51
Page 1

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] — Fax [phone]
Mr. Mark McIntire
Environmental Engineer
Point Source Section, DWQ
1617 Mail Service Center
Raleigh, NC 27699-1617
WILLIAM C. DIEHL, P.E.
JOHN F. MMLIPS, P.E.
ALAN R. KErM P.E.
� �}+xn--�.,.•-:�•��B,pig.t;r-;rip-?r^&FtF'II�Cq•RO[:Ui'�t�.:.�J�i'(1a�0i:'k.MV}Mwy�}•
w•,
July 15, 2005
JUL 2 1 2005
e' i iy
DERR - 'NATER QUALM
POINT SOURCE BRANCH
Re: Resubmittal of Engineering Alternatives Analysis (EAA) to Expand Flow
Ashley Hills WWT-P, NPDES Permit NCO051322
Carolina Water Service, CWS
Dear Mr. McIntire:
In accordance with Mr. Klimek's letter of April 1, 2005, the above referenced EAA has
been revised and is resubmitted herewith. I sent a letter to Mr. Joe Corporon of your section
on June 2, 2005 with follow-up questions regarding Mr. Klimek's letter, however, I have
not received a response to my questions to date. One of the questions was whether or not
the Division intended to issue TN limits to all Neuse basin dischargers with permitted
flows of less than 0.50 MGD during the next round of permit renewals. I asked this
question because of an email sent by Mr. Charles Weaver of the Division in December,
2003 regarding the Ashley Hills expansion, which stated in part "It is likely that the next
TMDL for the Neuse will require TN limits for all discharges, including small WWTPs...".
My purpose in asking Mr. Corporon for clarification was if TN limits are going to be issued
for the existing 0.25 MGD facility, the EAA should only examine the costs associated with
the nitrogen removal from the expanded flow 0.245 MGD. If TN limits are not going to be
issued to small dischargers during the next permit renewal, then the capital costs of the
nitrogen removal facilities for the entire 0.495 MGD should be included in the EAA, as the
plant expansion would trigger the TN reduction requirements rather than the permit
renewal.
Since I did not receive any response, I have assumed the worst case and included the cost
of the nitrogen removal equipment for the total plant flow (0.495 MGD) in the revised
EAA. As suggested in Mr. Klimek's letter, the contract operations cost have been increased
in anticipation of the more stringent TN and TP limits.
Mr. Klimek's letter was signed by you, on his behalf. I'm not sure who composed the
letter, but I do want to note for the file that there was a statement in that letter that I do not
believe should have been included. After discussing the need to revise the life cycle costs

Mr. Mark McIntire
July 15, 2005
Page 2
to include the advanced treatment costs and costs of any nitrogen allocation purchases, the
letter states "We suspect that the results may alter the discharge alternative priority." This
statement gives the impression that DWQ has formed an opinion regarding the revised
EAA without having yet reviewed the document and supporting information.
The revised EAA indicates the relative rankings of the Present Worths of the alternatives
have not been altered by the nutrient removal considerations, although the differences in
the present worth value of the discharge alternative and the other present worth values have
been changed.
Enclosed are three copies of the revised EAA and the original letter from CWS requesting
the expansion. The other documents originally submitted with the EAA (application and
permit modification check) were not included with the one copy of the EAA that was
returned, so I am assuming the Division still has these documents in its project file. Please
advise if you require duplicate copies of anything previously submitted.
Yours very truly,
Diehl & Phillips, P.A.
�IiL � a�,
John F. Phillips, P.E.
Cc: Mr. Richard Stockett
Mr. Jim Highley

CAROLINA WATER SERVICE, INC.
AN AFFILIATE OF
U� rl IL I h rl IC:so 11Fnl ❑
Regional Office:
5701 Westpark Dr., Suite 101
P.O. Box 240908
Charlotte, NC 28224
Telephone: [phone]
FAX: [phone]
October 28, 2004
Mr. David Goodrich
Supervisor, NPDES Unit
NCDE1,Tg /D ?AJn
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Engineering Alternatives Analysis for
NPDES Permit No. NCO051322
Ashley Hills WWTP
Wake County
Dear Mr. Goodrich:
Please find enclosed four copies of the referenced Engineering Alternatives Analysis, submitted
in support of a capacity expansion of the aforementioned NPDES permit. Carolina Water
Service, Inc. of NC hereby requests the average daily flow limitation of the referenced permit be
increased from 0.25 MGD to 0.495 MGD, to enable us to provide wastewater service to the areas
detailed in the EAA.
John Phillips, P.E., of Diehl & Phillips, P.A, prepared the EAA. Please direct any technical
review comments your staff may have to Mr. Phillips. If you require any further information to
process this permit modification request, please let me know. We will forward the required
permit modification fee after I`i W— has determined its concurrence witii the conclusions of the
EAA, or at the time of their request.
i el ,
im Highley
Sr. Regional Manager
C: Carl Daniel
John Phillips
Kerry Walton

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] — Fax [phone]
June 2, 2005
Mr. Joe Corporon
NPDES Unit, DWQ
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Return No. 2222
EAA for Expansion of NPDES Permit NCO051322
Ashley Hills WWTP, Wake County
Dear Mr. Corporon:
WILLIAM C_ DIEHL, P.E.
JOHN F. PHILLIPS, P.E.
ALAN R. KEI M P.E.
t� E
J U N 7 2005
DENR - WATER QUALITY
POINT SOURCE BRANCH
In response to Mr. Klimek's letter returning the referenced EAA, I would appreciate the
Division providing the following clarifications and/or information:
The letter states the Ashley Hills WWTP was allocated 5,055 lbs/yr (TN). Was this
allocation from the 138,000 pounds/year of TN that was divided among the dischargers
with less than 0.50 MGD permitted flow, as referenced in 15A NCAC 2B.0234(5)(a)(i)? If
so, what was the collective flow of the permits that was used in the allocation calculation?
When was this allocation made, and was Carolina Water notified of this allocation process?
Is the Division going to include TN limitations in existing permits with flows less than 0.50
MGD during the next permit renewal cycle?
I would appreciate your responses at your earliest convenience. With your responses we
should be able to revise the EAA as requested, and resubmit it to you for review.
Yours very truly,
Diehl & Phillips, P.A.
)t �-0
John F. Phillips, P.E.
PAL

Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek P.E., Director
Division of Water Quality
April 1, 2005
John Phillips, P.E.
Diehl and Phillips, P.A.
219 East Chatham Street
Cary, North Carolina 27551
Subject: Return No. 2222 -- Evaluation of Engineering
Alternatives Analysis (EAA) to Expand
Discharge Flow, NPDES Permit NCO051322
Carolina Water Service (CWS)
Ashley Hills WWTP
Wake County
Dear Mr. Phillips:
The Division of Water Quality (the Division) has reviewed your EAA and application to expand flow
authorized by the permittee, Carolina Water Service. The Division hereby returns your documents to
you and requests additional information.
Our reason for return is that your submittal does not address nutrient management requirements in the
Neuse River Basin. The Division has regularly required Total Nitrogen (TN) permit limits for flows at
0.500 MGD and above. While CWS proposes to expand the Ashley Hills WWTP to 0.495 MGD, the
Division sees no significant difference in these two flows with regard to nutrient management.
The CWS Ashley Hills plant has been allocated 5,055 lbs/yr (TN) at the discharge point, equivalent to
3.3 mg/L TN at 0.5 MGD. By rule [see 2B .0234(8)], the Permittee may acquire additional allocation as
needed, not to exceed the mass equivalent of 3.5 mg/L, or the facility's original allocation - whichever is
greater. The rule also requires the WWTP to comply with a monthly average Total Phosphorus (TP)
limit of 1.0 mg/L upon expansion.
Please note that the EAA must reflect that the facility will be subject to TN and TP limits upon
expansion. These limits will require CWS to upgrade the plant to provide advanced treatment. The
Division anticipates that this will require a serious commitment from CWS - both in terms of capital/
O&M costs and diligent operations - to consistently meet these limits.
AMA
NCDENR
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

Carolina Water Service (CWS)
Ashley Hills WWTP
Return of EAA and Request to Expand flow
NCO051322
Page 2
Finally, CWS must consider revised treatment -system capital and O&M costs related to advanced
treatment and further evaluate these added costs in the EAA lifecycle cost analysis. If CWS intends to
purchase additional allocation, it must also include these costs in the EAA. We suspect that the results
may alter the discharge alternative priority. Please consider the above and resubmit.
If you have questions concerning this review of your EAA, please contact [e-mail] or
call [phone], extension 597.
Respect y,
Ian W. Klimek, P.E.
Enclosure: EAA for NPDES Permit NCO051322
cc: Raleigh Regional Office, Water Quality Section
NPDES Unit
Carolina Water Service (CWS)
5701 Westpark Dr., Suite 101, P.O. Box 240908
Charlotte, North Carolina, 28224

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9

CWS holds permit NC0051322
March 11, 2005
Joe (and everybody at today's group review) -
Here is the feedback you asked for regarding the CWS - Ashley Hill proposal and the
Neuse rules. Let me know if you have any questions or if I overlooked any you already
asked.
Here's the situation, as I understand it:
• CWS holds permit NC0051322, with phased limits for 0.125 and 0.250 MGD.
The existing 0.250 MGD WWTP discharges treated wastewater in the Neuse
River basin.
• To accommodate upcoming development, they propose to expand the existing
plant to 0.495 MGD capacity. They have submitted an EAA w/ flow justification
for DWQ approval and, on approval, will request a permit mod for the expansion.
You asked specifically about how the nutrient management rule for wastewater
dischargers, 2B .0234, applies in this case. Under the rule,
All affected facilities are assigned a total nitrogen (TN) allocation. The Ashley
Hill WWTP has an allocation of 5,055 lb/yr at its discharge point.
Dischargers with permitted flows of 0.5 MGD or greater ("large" dischargers) are
subject to TN limits equal to their discharge allocations. This CWS plant is a
"small" plant and has no TN limit. As a small discharger downstream of Falls
Dam, it is not subject to total phosphorus (TP) limits under the rule (though I
think the permit includes a 2.0 mg//L limit at 0.250 MGD).
Expanding facilities are subject to certain requirements (see .0234(8)). Among
these, they must:
o evaluate all practical alternatives to surface water discharge (i.e., conduct
an EAA)
o make every reasonable effort to minimize increases in their TN discharge
o acquire additional allocation, if needed; the final allocation cannot exceed
(1) the mass equivalent of 3.5 mg/L or (2) the facility's original allocation,
whichever is greater
o meet a TP limit of 1.0 mg/L (mo. avg.)
The main question seems to be whether the Ashley Hills plant should get a TN limit upon
expansion. I believe our answer is "yes" regardless of the expanded flow. The rule clearly
requires limits for plants that were permitted for 0.5 MGD or more in 1995, but it doesn't
specify that a "small" but growing plant should get a limit when it crosses this threshold.
The section on expanding facilities (.0234(8)) can be read to require a limit upon
expansion, but it isn't specific either. We have taken the position any plant expanding to
0.5 MGD or more will get TN and TP limits. And, although we haven't had to make a call

on it yet, I believe we would apply nutrient limits to any plant that has to add
denitrification to meet its allocation under .0234(8).
CWS proposes a new design flow of 0.495 MGD, presumably to stay under the 0.5 MGD
threshold. The difference between the two is trivial, and - if I've stated our position well
enough - the plant should receive a TN limit regardless of what design flow is selected.
(Even if I'm off the mark, it doesn't make much sense for CWS to pick some lesser design
flow. The existing plant is 0.25 MGD and it would be much more reasonable for them to
simply double its capacity to 0.5, given that their flow estimate is in this ballpark
already.)
So CWS can expect to get a TN limit of 5,0551b/yr if they expand the Ashley Hill plant.
This is equivalent on average to about 3.3 mg/L TN at 0.5 MGD. The plant will also get a
TP limit of 1.0 mg/L.
These limits will require them to upgrade to advanced treatment. They can do it, but it
will take a serious commitment from CWS - both in terms of capital/ O&M costs and
diligent operations - to consistently meet these limits. As the group suggested today,
CWS needs to include these added costs in the EAA's life -cycle cost analysis, and the
results could end up pointing to a different discharge alternative. Could be interesting -
keep me posted.
- Mike T

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] — Fax [phone]
November 12, 2004
NPDES Unit
N.C. Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Request for Permit Expansion
NPDES Permit NCO051322 - Ashley Hills WWTP (Wake County)
Dear Sir or Madam:
WILLIAM C. DIEHL, P.E.
JOHN F. PHILLIPS, P.E.
ALAN R. KETTH, P.E.
On behalf of Carolina Water Service, Inc. of NC, Diehl & Phillips, P.A. hereby submits for
your review and comment the following:
• Three copies of an Engineering Alternatives Analysis (EAA)
• Three copies of the NPDES Application Form— Short Form D (requesting expansion)
• Application fee check no. 8477, in the amount of $215 (major modification, minor
NPDES permit)
• Letter from Permittee requesting expansion of their permit, based on the EAA
conclusions
A Local Government Review Form is not included as this request is for an expansion rather
than a new permit.
The enclosed EAA demonstrates that the expansion of the existing NPDES permit flow
limits, from .250 MGD to .495 MGD, is the only reasonably cost effective option of the
environmentally sound alternatives. This conclusion was reached after a thorough
evaluation of all non -discharge alternatives currently in common use, possible connections
to other privately and publicly owned treatment works, and possible re -use applications.
If the NPDES Unit has any questions or comments after reviewing this EAA, or if
additional information or copies are required, please contact me.
Yours very truly,
Diehl & Phillips, P.A.
John F. Phillips, P.E.
Cc: Mr. Tim Highley, CWS
Mr. Richard Stockett

mailbox:///Cl/Documents%20and%20Settinocharles_weaver/Applic...
Subject: expansion at Ashley Hills WWTP [NC0051322] and flow reduction at Kings Grant WWTP
[NC0062219]
From: Charles Weaver <charles.weaver@a ncmail.net>
Date: Tue, 09 Dec 2003 12:26:58 -0500
To: [e-mail]
CC: Mike Templeton <[e-mail]>, Dave Goodrich <Dave.Goodrich@a ncmail.net>
Kerry, I discussed your proposal with Mike and Dave. Based on their comments, I'm summarizing our
position on the proposal.
1. Any reduction in flow at Kings Grant does not "buy" Carolina Water Service (CWS) additional flow at
Ashley Hills; however, it is better for the environment and CWS in the long run. It is likely that the next
TMDL for the Neuse will require TN limits for all discharges, including small WWTPs like Kings Grant.
Lowering the flow now will save $$$ later by making compliance with future TN limits easier. Also, as
we discussed, the Kings Grant WWTP discharges to a zero -flow stream. The Division favors eliminating
all such discharges.
2. Carolina Water Service could request an expansion at Ashley Hills. The stream is not zero -flow and
does not appear on the most recent 303 (d) list. However, the most critical element of any expansion
request will be the EAA, specifically the flow justification. Therein lies the largest obstacle to any further
expansion at Ashley Hills.
Ashley Hill's current permit has a flow limit of 0.125 MGD, with an expansion phase of 0.25 MGD.
John Phillips submitted a partial completion notice for the expansion to 0.25 MGD in October 2003, but
the final notice has not yet been received. The average flows over the past 4 years, under a flow limit of
0.125 MGD [monthly average], do not justify any further expansion:
2000 highest monthly average reported: 0.108 MGD [December 20001
2001 highest monthly average reported: 0.097 MGD Qanuary 20011
2002 highest monthly average reported: 0.086 MGD [December 20021
2003 highest monthly average reported: 0.095 MGD [October 2003; November & december data not yet
logged]
In our previous discussions you said that developers were asking to connect potential new homes to the
Ashley Hills WWTP. A flow justification for any expansion beyond 0.25 MGD must document how the
remaining capacity at 0.25 MGD would be consumed and exceeded, either by further contruction
inside Ashley Hills, external connections, or both. Documentation from the developers [including
number of homes proposed and construction schedules] would be required, as well as documentation
from any local POTWs that might serve the new homes being proposed.
In short, CWS can ask to reduce flow at Kings Grant. Based on the environmental advantages, the
Division will probably say yes.
CWS can also ask to expand flow at Ashley Hill. Based on the lack of flow justification, the Division will
probably say no. However, if CWS can justify the flow expansion, feel free to submit an application, fee
and EAA.
If you have additional questions, simply reply to this message.
CHW
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