NC0088901_Permit issuance_20100625

Beverly Eaves Perdue
Governor
AMA`
NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Coleen H. Sullins
Director
June 25, 2010
Mr. Larry Miller
2024 Nix Creek Road, Suite A
Marion, North Carolina 28752
Subject:
Dear Mr. Miller:
Resources
Dee Freeman
Secretary
Issuance of NPDES Permit NCO088901
2041 US Hwy 70 East Apartment Complex
McDowell County
Division personnel have reviewed and approved your application for a new permit. 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 October 15, 2007 (or as subsequently amended).
This final permit includes no major changes from the draft sent to you on April 28, 2010.
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 Centex, Raleigh,
North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
The permittee shall comply with the setback requirements in 1.5A NCAC .02T .0506(b)
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity t Affirmative Action Employer
Nne
orthCarolina
N
atlli'qlIl�

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 Sergei Chernikov at
telephone number [phone].
Sin erely,
a��
oleen H. Sullins
cc: NPDES Files
Central Files
Asheville Regional Office -Surface Water Protection
CG&L (e-copy)
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: 91 M07-64921 Customer Service: 1-877-623-6748 NorthCarolina
Internet: www.ncwaterquality.org An Equal Opportunity \AffirmativeAction Employer �atK'/ra//`iff

Permit NCO088901
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,
Larry Miller
is hereby authorized to discharge wastewater from a facility located at the
2041 US Hwy 70 East Apartment Complex
2041 US Hwy 70 East
Marion
McDowell County
to receiving waters designated as Forsyth Creek in Catawba 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 August 1, 2010.
This permit and authorization to discharge shall expire at midnight on January 31, 2015.
Signed this day June 25, 2010.
I I&LV,
een H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

c
- , 0 Permit NCO088901
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.
Larry Miller is hereby authorized to:
1. After receiving an Authorization to Construct permit from the Division,
construct wastewater treatment facilities not to exceed 0.002 MGD design
flow.
2. After submitting an Engineer's Certification, operate 0.002 MGD package
plant located on Highway 70 East at 2041 US Hwy 70 East Apartment
Complex in McDowell County and discharge from said treatment works at
the location specified on the attached map into Forsyth Creek, a class C
water in the Catawba River Basin.

Latitude:
350 42' 0.96"
Longitude:
810 58' 42.63" NI
USGS Quad #:_
E l ONE
River Basin #:
03-08-30
Receiving Stream:
Forsyth Creek
Stream Class:
C
2041 US Hwy 70 East
Apartment Complex
McDowell County
NCO088901

Permit NCO088901
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
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 and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Location
Flow
0.002 MGD
Weekly
Instantaneous
Influent or
Effluent
BOD, 5-day (20°C)
30,0 mg/L
45.0 mg/L
2/1VIonth
Grab
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
2/Month
Grab
Effluent
NHs-N
Monthly
Grab
Effluent
Fecal Coliform (geometric
mean)
200/100 mL
400/100 mL
2/Month
Grab
Effluent
Total Residual Chlorine'
28 pg/L
2/Week
Grab
Effluent
Temperature (°C)
Weekly
Grab
Effluent
pH2
2/Month
Grab
Effluent
Footnotes:
1. Limit and monitoring applies only if chlorine is added for disinfection. The facility
shall report all effluent TRC values reported by a NC certified laboratory including
field certified. However, effluent values below 50 µg/L will be treated as zero for
compliance purposes.
2. 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

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO088901
Facility Information
Applicant/Facility Name:
2041 US Hwy 70 East Apartment Complex
Applicant Address:
2024 Nix Creek Road, Suite A, Marion, North Carolina 28752
Facility Address:
2041 US Hwy 70 East, Marion, North Carolina 28752
Permitted Flow:
0.002 MGD
Type of Waste:
100% Domestic.
Other Permit(s):
N/A
Facility / Permit Status:
Class I / New
County:
McDowell County
Miscellaneous
Receiving Stream:
Forsyth Creek
Regional Office:
Asheville
Stream Classification:
C
USGS Topo Quad:
EIONE
303(d) Listed?
No
Permit Writer:
Sergei Chernikov
Subbasin:
03-08-30
Date:
April 12, 2010
Drainage Area (mi):
0.69
•
Lat. 35' 42' 0.96" N Long. 81 ° 58' 42.63" W
Summer 7Q10 (cfs) :
0.19
Winter 7Q10 (cfs):
0.31
3OQ2 (cfs) :
0.43
Average Flow (cfs):
1
IWC (%):
1.9
BACKGROUND:
2041 US Hwy 70 East Apartment Complex WWTP is a proposed Class II, 100% domestic
wastewater treatment system that treats waste from an apartment complex that consists of 8 units
(2 bedroom each). The EAA for this facility has been approved on October 7, 2009. Effluent
limitations are based on the Level B model conducted on October 30, 2008.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: April 28, 2010 (est.)
Permit Scheduled to Issue: June 21, 2010 (est.)
NPDES CONTACT:
If you have questions regarding any of the above information or on the attached permit, please
contact Sergei Chernikov at [phone].
REGIONAL OFFICE COMMENTS:
Fact Sbeet
NPDES NCO088901 New
Pave ].

ASHEViT .T .F
CITIZEN TPHS
VOICE OF THE MOUNTAINS • CITIZENTIMES.com
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
PuLNic No"
SS.
E°ro melMal
NORTH CAROLINA
Mama � t iPDEcoom is-
1617 Mail Service
RaleighfNeCn 27699.1617
NoticeoflntaMtel
a NPDES Wastewater
Before the undersigned, a Notary Public of said County and
Permit ,
The
State, duly commissioned, qualified and authorized by law
North Carolina In Manage-
ment Commission ro-
poses.to issue a NPpDES
to administer oaths, personally appeared Elyse Giannetti,
permt t toethe p rson'�s1
listed below.
who, being first duly sworn, deposes and says: that she is
Written comments re-
the Legal Billing Clerk of The Asheville Citizen -Times,
get? - the proposed
permit will acer the
until 30 days
engaged in publication of a newspaper known as The
s after the
rippublish date
ce. The Dirof this no
ector of the
NC
Asheville Citizen -Times, published, issued, and entered as
Division of Water
mag
hold ality (DWQPublic
first class mail in the City of Asheville, in said County and
should therei�behaas�-
lic Interests Please muaiiI
State; that she is authorized to make this affidavit and
comments and/or st i
formation requests to
Dwat the atad- n-
Q
sworn statement; that the notice or other legal
,
dress. Interested per-
sons may visit the DI'WQ
at N. Salisbury
advertisement a true copy of which is attached hereto, was
.512
review InfofmationC on
>
published in The Asheville Citizen -Times on the
file. Additional informa-
NPDce permits
tion this
and this notice may be
following date: April 29t1' 2010. And that the said
found on our website:
jww.ncwaterq ual ity.or
7-o8r304 y calling (919)
,
newspaper in which said notice, paper, document or legal
Larry Miller requested
advertisement was published was,, at the time of each and
permit
NCO088901wfor p2041 U5
Complex East Ary�Dow 11
Yv
eve publication, a newspaper meetingall of the
+,
County; this
do.
requirements and qualifications of Section 1-597 of the
rdatev
chartge is treated do-
mes IC wastewater tol
Forsyth Creek, Catawba
River B05in.
General Statues of North Carolina and was a qualified
Apr29,2010 I newspaper within the meaning of Section 1-597 of the
77Z2 General Statues of North Carolina.
Signed this 29th day of April, 2010
of person making affidavit)
Sworn to and subscribed before me the 29th day of April,
2010.1
My Co*ission expires the 51n day of October, 2013,
[phone] 1 [phone] FAX
14 O. HENRY AVE. I P.O. BOX 2090 1 ASHEVILLE, NC 28802 1 [phone]
Cy GAN W
N`0_f ANY
PE.1BL'(',

TO: NPDES UNIT �`�
WATER QUALITY SECTION rat!
ATTENTION: Sergei Chernikov
DATE: March 31, 2010
NPDES STAFF REPORT AND RECOMMENDATI F
McDowell COUNTY
PERMIT NUMBER NC0088901
PART I - GENERAL INFORMATION
1. Facility and Address: Miller Apartment Complex
2041 US Hwy 70, Marion, North Carolina 28752-8749
Mailing: Mr. Larry Miller, GEM Constructors, Inc.
2024 Nix Creek Road, Suite A
Marion, NC 28752
2. Date of Investigation: March 24, 2010
3. Report Prepared By: Janet Cantwell/ ARO
APR 62010
4. Persons Contacted and Telephone Number: Mr. Larry Miller: Office # 828-659-1441/ Ext. 15
Cell # 828-442-6007
5. Directions to Site: From ARO: 1-40 E to Exit 81 toward Marion. Turn left onto Sugar Hill Road and
go 2.2 miles. Sugar Hill Road becomes W. Henderson St. Go 1.2 miles and turn left onto S. Main
St/ US 221. Go @ 500 ` and turn right onto E. Court St./ US Hwy 70 and go @ 2.1 miles. The
apartment complex is on the left past "The Attic."
C.1
7.
8.
9.
10
Discharge Point(s), List for all discharge points: N/A: Facility has not been built.
Latitude: degrees .... minutes .... seconds
Longitude:.... degrees .... minutes .... seconds
Attach a USGS map extract and indicate treatment facility site and discharge point on map.
U.S.G.S. Quad No.: E11 NW4 U.S.G.S. Quad Name ...............
Site size and expansion area consistent with application?
Yes X —No If No, explain:
Topography (relationship to flood plain included): It appears the sand filter will be located about
50 or so feet from Forsyth Creek.
Location of nearest dwelling: Onsite apartment building; home on property adjacent to E side.
Receiving stream or affected surface waters: Forsyth Creek
a. Classification: "C"
b. River Basin and Sub basin No.: CTB30 Stream Index: 11-25
C. Describe receiving stream features and pertinent downstream uses: secondary recreational
and wildlife propagation.
-1-

rill)
030030
,I jvj
IZF 0
Tg
`1'11/ � W,4,A) // Zif,
ZlWr�� 3L
0 y

Miller Apt. Complex
Residual Chlorine
Ammonia as NH3
(summer)
7Q10 (CFS)
0.15
7Q10 (CFS)
0.15
DESIGN FLOW (MGD)
0.0019
DESIGN FLOW (MGD)
0.0019
DESIGN FLOW (CFS)
0.002945
DESIGN FLOW (CFS)
0.00295
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
UPS BACKGROUND LEVEL (1
0
UPS BACKGROUND LEVEL
0.22
IWC (%)
1.93
IWC (%)
1.93
Allowable Concentration (ugJ
882.87
Allowable Concentration (m
40.73
Ammonia as NH3
(winter)
7Q10 (CFS)
0.3
Fecal Limit
2001100ml
DESIGN FLOW (MGD)
0.0019
Ratio of 50.9 :1
DESIGN FLOW (CFS)
0.00295
STREAM STD (MG/L)
1.8
UPS BACKGROUND LEVEL
0.22
IWC (%)
0.97
Allowable Concentration (m
162.75
NC0088901 10/28/2009

Facility: miller apartments
NPDES#: nc0088901
Receiving Stream: forsyth creek
Comment(s):
gage number not available
Low Flow Record Station Number:
Hydrologic Area Number: HA10
Drainage Area Low Flow Record Station:
Qave Low Flow Record Station:
s7Q10 Low Flow Record Station:
w7Q10 Low Flow Record Station:
30Q2 Low Flow Record Station:
must be < 400 sq. miles
Drainage Area New Site:
0.69 sq. miles
MAR New Site:
1.8
Qave per Report Equation:
1 cfs
s7Q10 per Report Equation:
0.19 cfs
w7Q10 per Report Equation:
0.31 cfs
30Q2 per Report Equation:
0.43 cfs
Continue
Drainage Area Ratio: #DIV/O!
[ new DA / Da at gage #DIV/O!
Weighted Ratio: #DIV/O!
Over -ride Inappropriate Site ( y ):
IIDrainage Area New Site: 0.69 miles squared
If MAR New Site: 1.8
Weighted Qave per Report Equation: #DIV/O!
Weighted s7Q10 per Report Equation: no input from above
Weighted w7Q10 per Report Equation: no input from above
Weighted 30Q2 per Report Equation: no input from above

Chernikov, Sergei
From: Cantwell, Janet
Sent: Tuesday, December 01, 2009 10:36 AM
To: Chernikov, Sergei
Cc: Cantwell, Janet; Edwards, Roger
Subject: Miller Apt. Complex: permit application NCO088901 McDowell Co.
Hi Sergei---Roger, Mike and I found quite a few discrepancies in the EAA package sent by Brooks Engineering
Associates (BEA) for the Miler Apartment Complex on US Hwy 70 East in McDowell County.
Listed below are some of the discrepancies:
1. Figure 1 Development Site Plan: under General Notes: mentions BUNCOMBE County (this is McDowell Co.
2. 6.0 Attachments: Attachment B- Denial letter from JACKSON County
3. Attachment A. Local Government Review Form: was sent to the City Manager but the green card was from the
County Manager's office. It shows they signed it, but BEA said it had not been received. WHAT?
4. On page 1: Introduction: BEA mentions "a letter from the regional branch of the DWQ was issued October 31, 2008
stating that discharge from the sewage system was increasing fecal coliform in the stream located on the property."
This letter was not included in the package.
5. BEA talks about a 2,500 gallon septic tank but on the maps it shows a 2,000 gallon tank.
It appears that Brooks Engineering Associates should review their package and correct their mistalyes. y n
Call if you have any questions---Thanks---Janet Aj� �� �,,�� bow(- (Sce�-------------------------------------------------------------------------------------------------------------------------------------
Janet [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 US Highway 70
Swannanoa, NC 28778-8211
Tel: [phone]
Fax: [phone]
Link to "Guidebook to Water Quality Management in North Carolina":
http//h2o.enr.state.nc.us/basinwide/documents/SupportDocument.pdf
Link to the NC Division of Water Quality:
http://www.ncwaterguality.org
Link to NPDES Programs & Compliance Info: (DMRs, Annual Report, Etc.):
http://h2o.enr.state.nc.us/NPDES/
Link to Technical Assistance & Compliance Unit, WW Operator Regs, Etc.:
http://h2o.enr.state.nc.us/tacu/index.html
Link to Collection Systems (PERCS Unit):
http://www.ncwaterq ualitv.oriz/i)eres/Collection%2OSvstems/CollectionSvstemsHome.htm I
Link to NC Surface Waters & Wetlands Standards ("Redbook"):
http_ah2o.enr.state.nc.us/admin/rules/codes statutes.htm
Link to NC Stream Classifications:
http://h2o.enr.state.nc.us./bims/reports/rei)ortsWB.html
Link to Water Supply Watershed Info:
httpJ/h2o.enr.state.nc.us/wswp/index.html
Link to booklet "Guidelines for Riparian Buffer Restoration:"
http://www.nceer).net/services/euidancedoc.htm
Link to Stormwater, General Permits, & Runoff Pollution:

Planning & Project Management Civil Engineering Surveying
l
Soil Science Services Environmental Engineering & Services
ENGINEERINGBROOKS
ASSOCIATES
1 17 Arlington Street I Asheville NC 28801 / www.hrooksea.com 1828-M-4700
December 17, 2009
NPDES-West
1617 Mail Service Center
Raleigh, NC 27606
Attention: Sergei Chernikov
Regarding: Miller Apartment Complex
Project No. 326409
Dear Mr. Chernikov:
DENR - WATER QUALITY
POINT SOURLE BRANCH
Brooks Engineering Associates, P.A. appreciates the review of the Miller Apartment Complex
sewer system plans and EAA package. This letter and accompanying submittals are to address
the comments from the regional staff per your email dated December 2, 2009.
Enclosed with this letter are two (2) copies of the revised Engineering Plans & EAA report.
The following is a line item response to comments per your email:
1. General Note now refers to McDowell County.
2. Attachment B now refers to McDowell County.
3. The Local Government Review Form was sent to both the City of Marion and McDowell
County as required per Instructions to the Applicant as found on the Local Government
Review Form. Per Bullet 3 under the Instructions to the Applicant; a copy of the certified
mail card (Domestic Return Receipt) shall be submitted as evidence to the Commission
that the local government failed to respond within 15 days. BEA has provided the
Domestic Return Receipt as evidence that the County did indeed receive the Local
Government Review Form and as of this date has still not responded. Please call me at
our office if any further clarification is needed regarding this matter.
4. A copy of the regional DWQ office letter dated October 31, 2008 has been provided with
this resubmittal.
5. The plan (map) has been revised to depict a 2500 gallon tank.
Please contact our office if you need any additional information or clarification regarding the
responses to your comments.
Sincerely,
Broo ist,S
oci tes, PA
Paul E. Sexto,

BROOKS Planning & Project Management Civil Engineering Surveying
Soil Science Services Environmental Engineering & Services
ENGINEERING A S S O C I A T E S 17 Arlington Street / Asheville NC 288011 www.brooksea.com % 828-2324700
October 1, 2009
N.C. Department of Environment and Natural Resources REUE VL-D
Division of Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Regarding: 2041 U.S. Highway 70 East Apartment Comp1DEN R ' WATER O UALITY
McDowell County, Marion, NC POINT SOURCE BRANCH
To Whom It May Concern:
A certified letter from North Carolina Department of Environmental and Natural
Resources (NCDENR), Division of Water Quality (DWQ), dated October 31, 2008 was
issued to Larry Miller. This letter states that the existing subsurface sand filter sewage
treatment system that was permitted by the McDowell County Health Department is not
providing adequate treatment of sewage. The letter also states that a permit to discharge
to waters of the state as required by North Carolina General Statute 143-215(a)(1) is not
held. Mr. Miller has contracted with our firm to bring the sewage discharge into
compliance with state rules.
The accompanying plans are for the repair of an existing surface discharge onsite
wastewater system that serves an 8 unit apartment complex. The design flow is 1920
gpd. Based on the Soils Report by Walker Ferguson LSS, the site is unusable for
wastewater application via surface drip, subsurface drip, or conventional system due to
spatial site limitations and unsatisfactory soil depth. This report can be found in
Attachment B. There is no public sewage disposal system located near the subject site.
The most practical resolution to bring the site in compliance with state regulations is to
provide improvements to the existing system.
The site is located within the limits of the City of Marion. The improvements to the
existing wastewater treatment system for the apartment complex consists of a 2500 gal
septic tank (STB-446) and 3000 gallon pump tank (PT-143) by Dellinger Precast, Inc. A
recirculating sand filter designed based on a 5 GPD/ft2 loading rate provides 400 ft2 of
surface area for treatment. A 4:1 recirculation ratio box by American Manufacturing is
used to rout % of the flow back to the pump tank via gravity flow where it is re -circulated
through the sand filter. Chlorination and de -chlorination apparatus by Bio- Dynamic are
used for disinfection. The tablet chlorinator and dechlorinator consists of a housing and
three tablet feed tubes. Slow dissolving Blue Crystal tablets dissolve at a rate
proportional to the flow providing disinfection. Bio-Max dechlorination tablets are used
for the removal of residual chlorine. A contact chamber provides approximately 37.5
minutes of detention time after the chlorination apparatus. Residual chlorine is then

removed after flowing through the dechorination tablet feeder device. A cascade aerator
provides aeration before the effluent discharges to the stream.
Final plans for the treatment system stamped "Preliminary Not released for
construction" have been included. The following items have been included as
Attachments in this application package:
A. Two signed copies of NPDES Application Form D
B. Letter from soil scientist of evaluation of subject site for suitable disposal
systems.
C. Specifications for all major treatment components.
D. Engineering Calculations.
This submittal was originally submitted and received by NCDENR- Water Quality Point
Source Branch on June 8, 2009. The submittal package was returned to our office in
request for additional information per letter dated June 17, 2009. As requested per that
letter the following items are include in this resubmittal:
Application Fee of $860.00 (Check# 1194 );
Completed Engineering Alternatives Analysis and Local Government Review Form.
We appreciate your timely review of this material. If there are any questions or issues
that can be resolved with an explanation, please feel free to contact me at (828) 232-
4700.
Sincerely,
Brooks Engineering Associates, PA
Paul E. Sexton, P.E.
Attachments: A. NPDES Application Form D
B. Soil Scientist Evaluation
C. Wastewater System Specifications & Calculations

Brooks Engineering Associates
Land Planning Civil Engineering Surveying Environmental Services Soil Science Services
April 22, 2009
Larry Miller
G.E.M. Constructors, Inc.
2024 Nix Creek Road, Suite A
Marion, North Carolina 28752
Attention: Mr. Miller
Regarding: Report of Findings Soils Evaluation
2041 U.S. Highway 70
McDowell County, NC
Dear Mr. Miller,
Walker B. Ferguson of Brooks Engineering Associates (BEA) conducted a soils investigation on
a 1.34 acre tract located at 2041 Highway 70 McDowell County, North Carolina. This
investigation was conducted at the request of Mr. Miller. The purpose of the soil study was to
determine if any land based wastewater options were available for an eight two-bedr000m unit
apartment complex. The apartment complex is currently being served by a sand filter and surface
water discharge system which is in failure.
Fieldwork was conducted using the following tools and methods. A 3-inch hand auger, a knife,
and a sharpshooter shovel were used to examine the soil. A Suunto clinometer was used to
measure soil slope.
Recommendations are based on, but not limited to, observations made and data collected on
topography, landscape position, parent material, underlying geology, and soil characteristics.
Soil characteristics include, but are not limited to, depth to a seasonal high water table (SHWT),
depth to a restrictive horizon, total soil depth, soil horizonation, soil structure, soil color, clay
mineralogy, bulk density, consistence, plasticity, stone content, and percent sand, silt, clay, and
mica. They follow the guidelines set forth in the North Carolina Laws and Rules for Sewage
Treatment and Disposal Systems, laws amended effective December 19, 2001, and rules
amended effective June 1, 2006. Grading which occurs subsequent to this fieldwork renders the
soil investigation in the graded area null and void.
17 Arlington St. Asheville, NC 28801 www.brooksea.com ph.828.232.4700 fx.828.232.1331

RESULTS AND DISCUSSION
+ BEA found Mr. Millers tract to be unsuitable for any surface or subsurface wastewater
disposal system. The site is unsuitable for a subsurface wastewater system due to a
shallow Seasonal High Water Table (SHWT) and insufficient area to support the 1920
gal/per/day (gpd) design flow. This tract does not meet setback requirements for surface
drip irrigation to be considered.
• BEA concludes that the only feasible alternative for the 1920 gpd is a pre-treated surface
water disposal system into the stream northwest of the apartment complex.
Thank you for the opportunity of presenting this information to you. If we can be of further
assistance, please feel free to call.
Sincerely,
Walker B. Ferguson
Licensed Soil Scientist
2

References:
North Carolina Department of Environment, Health, and Natural Resources, Division of
Environmental Health, On -Site Wastewater Section. 1998. Laws and Rules for Sewage
Treatment and Disposal Systems, section .1956(6). P.O. Box 27687, Raleigh, NC, 27611-
7687.
2. North Carolina Department of Environment, Health, and Natural Resources, Division of
Environmental Health, On -Site Wastewater Section. 1996. Procedures and Information
Required for Approval of Large Subsurface Wastewater Systems. P.O. Box 27687, Raleigh,
NC, 27611-7687.
3. North Carolina Department of Environment, Health, and Natural Resources, Division of
Environmental Management. 1996. Administrative Code Section: 1 SA NCAC 2H. 0200 —
Waste Not Discharged to Surface Waters. Environmental Management Commission,
Raleigh, NC

$v.13. 2009 4:04PM Brooks Engineering Assoc.
No. 18u / F. 2
NPI)ES APPLICATION - FORM D
For privately owned treatment systems treating 100516 domestic wastawaters <1.0 MGD
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPI)ES Unit
1617 Mail Service Center, Raleigh, NC 27699.1617
NPDRS Permit FLCOO
If you are completing this form in Computer use the ?AB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Naive Larry Miller
Facility Name 2041 U.S. Hwy 70 East Apartment Complex
Mailing Address 2024 Nix Creek Road, Suite A
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Marion
North Carolina / 28752
[phone]
[phone]
larryoogemconstructors.com
2. Location of facility producing discharge:
Cheek here if same address as above ❑
Street Address or State Road 2041 U.S. Htvy 70 East
City
State / Zip Code
County
Marion
North Carolina / 28752
McDowell
3. Operator Information:
Narne of the fim� public organization or other entity that operates the facility. (Note that this is not
referring to the Operator in Responsible Charge or ORQ
Name Larry Miller
Mailing Address 2024 Nix Creek Road, Suite A
City
State / Zip Code
Telephone Number
Fax Number
WVro :T1
NC / 28752
[phone]
[phone]
1013 Forni•D 1/06

May.13. 2009 4:04PM Brooks Engineering Assoc.
No.180) P. 3 .
NPDES APPLICATION - FORM D
For privately owned treatment systems treating 100% domestic wastewaters <1.0 MGD
4. Description of wastewater;
Facility Gonerating Wastewaterlbheek all that apply):
Industrial
❑
Number of Employees
Commercial
❑
Number of Employees
Residential
®
Number of Homes g
School
❑
Number of Students/Staff
Other
❑
Explain -
]Describe the source(s) of wastewater (example. subdivision, mobile home park, shopping centers,
restaurants, etc.);
Aparment complex - Consist of 8 two bedroorn knits
Population served: 16
5. Type of collection system
9 Separate (sanitary sewer only) ❑ Combined (storm sewer and sanitary sewer)
6. OutfaIl information;
Number of separate discharge points One
Outfall Identification number(s) 1
Is the out€all equipped with a diffusers? ® Yet; ❑ No
7. Name of receiving stream(s) (Pt'ouide tl trtrtp sF:owi:tg itte ex(xcf locaiton of each otttfall};
Forsyth Creek
S. Frequency of Dlseharge: Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs: Duration:
9. Describe the treatment system
List all installed Components, including capacity, provide de-Ayn removal for BOD, MS, nitrogen and
Phosphorus. If the space provided is not sufficient, attach the description of the treatment system in a
separate sheet of paper,
See attached summary of treatment eyatem,
200
Fotm-D f/0"o

May. 13. ZUU9 4,U4YM Brooks Engineering Assoc. No, 1807 p 4
NPDES APPLICATION - FORM D
Far privately owned treatment syatetns treating 100% domestic wastewaters <1,0 MQD
10. Flow Information;
Treatment Plant Design flow .Om9 MGD
Annual Average daily flow .cim MGD (for the previous 3 years)
Maximum daily flow ,_0019 MGD (for the previous 3 years)
11. Is this facility located on Indian country?
❑ Yc'•s ® No
12. Effluent Data
Provide data for the parameters listed. Fecal Colifotm, Temperahire andpH shalt be grab samples, for all otizer
parameters 24-hour composite sampling shall be used. Effluent testing data must be based on at least three samples
and must be rw more tfutn four and one half years aid.
Parameter Deily Monthly Unite of Number of
Maximum Avera a Measurement Samples
Biochemical Oxygen Demand
(bolas)
Fecal Coliform
Total Suspended Solids
Temperature (Summer)
Temperature (Winter)
pH
13, List all permits, construction approvals and/or applications;
Type Permit Number Type Permit Number
Hazardous waste (RCRA) N-)1� HAPS (CAA)
UIC (SDWA) Ocean Dumping (MP12SA)
NPDES Dredge or till (Section 404 or 0VA)
PSD (CAA) Special Order of Consent (;;QC)
Non -attainment program (CAA) Other
14, APPLICANT CERTIFICATION
I certify that I am familiar with the Information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Larry Miller Owner
Printed name of person Signing Title
Signatu t o Applicant bate U
North Oolffia General Statute 143-2I5.6 (b)(2) states: Any person who knowingly makes any false statement
rcpr y,.fttation, or certification itt any appheation, record, report, plan, or other document files or required to be
to untained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or
who falsifta, tampers %vith, or knowly renders ina.cmrate an recording or monitoring device or method rNuircd to be
operated or maintaintd under Article 21 or regulations of the Environmental Management Commission implementing
that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by impriaonnimt not to
exceed six months, or by both, (18 U.S.C. Section 1001 provides a punishment by a Fume of hot more than $25,000 of
imprisonment not more than 5 years, or both, for a similar offense.)
3 d a Form-) 1106

MILLER APARTMENT COMPLEX
U.S. HIGHWAY 70 EAST
McDOWELL COUNTY, NORTH CAROLINA
ENGINEERING ALTERNATIVES ANALYSIS
(EAA)
PREPARED FOR. RE C E02 i 'VE' D
LARRY MILLER
2024 NIX CREEK ROAD
SUITE A MARION, NC 28752DENR - WATER QUALITY
POINT SOURCE BRANCH
SUBMITTED TO:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY - NPDES UNIT
1 61 7 MAIL SERVICE CENTER
RALEIGH, NC 27699-161 7
PROJECT Na. 326409
04�>i�i
SEAL
032890
ORIGINAL: AUGUST 1 7, 2009
REVISED : DECEMBER 1 7, 2009

Table of Contents
1.0
Introduction.......................................................................................................1
1.1
Applicant Information...............................................................................1
1.2
Property Information................................................................................2
2.0
Initial
Discharge Determination........................................................................3
3.0
Technical
Evaluation of Alternatives...............................................................5
3.1
Connection to Existing Waste Treatment Plant........................................5
3.2
Individual or Group Septic Systems.........................................................5
3.3
Reuse Land Application & Reuse............................................................7
3.4
Direct Discharge to Surface Waters.........................................................
8
3.5
Combination of Alternatives.....................................................................
8
4.0
Economic
Evaluation of Alternatives.............................................................10
4.1
Connection to Existing Wastewater Treatment Plant..............................11
4.2
Individual or Group Septic Systems.......................................................12
4.3
Land Application....................................................................................13
4.4
Direct Discharge to Surface Waters.......................................................14
4.5
Combinations of Alternatives..................................................................14
5.0 Figures
1.
Development Site Plan
2.
General Site Location Map & Discharge Location Map
3.
Neighboring Discharge Facility Locations
6.0 Attachments
A.
Local Government Review Form
B.
County Environmental Health Denial Letter
C.
BEA Soil Scientist Report
D.
Drainfield & Irrigation Required Acreage Calculations
E.
Present Value Cost Analysis
F.
Engineer's Opinion of Cost for Infrastructure
G.
Proposed Treatment Technology Cut -sheet

1.0 Introduction
This Engineering Alternatives Analysis (EAA) is provided as part of the application for
a new NPDES permit for the Miller Apartment Complex in accordance with 15A NCAC
2H.0105. The purpose of this EAA is to determine the technical and economic
feasibility of wastewater disposal options available for the development.
As part of the 1972 Clean Water Act, discharge to surface waters is considered only as
a last resort. Brooks Engineering Associates has evaluated all of the alternatives and
has concluded that the surface discharge permit is the only viable option for the
applicant. The project consists of an existing 8 unit apartment complex located on a
1.34 acre parcel. The apartments have been utilizing an existing sand filter
discharging to Forsyth Creek that was originally permitted by the county health
department, so no NPDES permit has been issued for the facility. A letter from the
regional branch of the Division of Water Quality was issued October 31, 2008 stating
that discharge from the sewage system was increasing fecal coliform in the stream
located on the property. A copy of the letter is provided as Attachment A. The owner
has hired our firm to assist in bringing the discharge in compliance with state
regulations. Upon initiation of an investigation of the soil conditions by the McDowell
County Department of Public Health, it was determined that the soil was unsuitable for
a land disposal system because of unsuitable soil material and setback regulations.
9.1 Applicant Information
Pertinent information regarding the applicant and this application is as follows.
Property Owner:
NPDES Permit Applicant:
Larry Miller
2024 Nix Creek Road, Suite A
Marion, NC 28752
Larry Miller
2024 Nix Creek Road, Suite A
Marion, NC 28752
EAA Preparers Information: Brooks Engineering Associates, PA
17 Arlington Street
Asheville, NC 28801
[phone]
Contact: Paul E. Sexton, P.E.
Brooks Engineering Associates, P.A. Engineering Alternatives Analysis
BEA Project No. 326409 Miller Apartment Complex

1.2 Property Information
The subject property is located in McDowell County near the intersection of NCSR
1536 (Memorial Park Road) and U.S. Highway 70 E, in Marion, NC. The subject site
consists of one parcel (PIN # 1712-52-6802) which is 1.34 acres. The site is mostly
cleared with an existing two-story 8 unit apartment building and associated asphalt
parking lot. The site is bordered to the north by Memorial Park Road and bordered to
the south by U.S. Hwy 70 E. Forsyth Creek runs across the property from west to
east.
The existing building was built in the early 1970's and has been used as a residential
apartment complex.
The site water service is provided by a single existing well. The site layout is provided
as Figure 1. The Local Government Review Form is provided as Attachment A.
A general site location map has been included as Figure 2 depicting the discharge
location. The proposed wastewater receiving stream is Forsyth Creek. The design
flow for the project is calculated to be 1,920 gallons per day (gpd) based upon 8 units
each with 2 bedrooms at 120 gpd/bedroom in accordance with 15A NCAC 02T .0114
(since 15A NCAC 2H 0.219 has been repealed).
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
2

2.0 Initial Discharge Determination
Brooks Engineering Associates has performed an initial determination regarding the
potential of the receiving stream to accommodate the proposed developments' design
wastewater flow of 1,920 gpd. The discharge location longitude and latitude are
provided on Figure 2. The receiving stream, Forsyth Creek, was researched for
limiting classifications and the following determinations were made:
♦ Forsyth Creek has no zero -flow restrictions per 15A NCAC 2B.0206 (d)(2);
♦ Forsyth Creek is classified as a Class C stream (Stream Index No. 11-25);
♦ Forsyth Creek is not designated as an Impaired Water and has no designated
TMDLs;
♦ The portion of Forsyth Creek where this project is proposed has no known
presence of endangered species.
♦ Class C waters have no restrictions on watershed development or types of
discharges.
Forsyth Creek is part of the Catawba River Basin. A basin wide plan does exist for the
Catawba River Basin but Forsyth Creek is not identified in the plan.
To address potential deficiencies of the receiving stream regarding flow, BEA staff
conducted an investigation by confirming a positive 7Q10 "low stream flow" for Forsyth
Creek with the USGS. These activities are discussed below.
On June 29, 2009 BEA staff contacted Mr. Curtis Weaver, PE of the USGS in Raleigh,
North Carolina. Mr. Weaver is the principal engineer in charge of making stream flow
determinations for the Raleigh USGS office. The 7-day 10-year low flow (7Q10) is the
governing stream criteria for wastewater point source discharges for flow acceptance.
Mr. Weaver replied via e-mail that a drainage area of 0.69 sq. mi. was determined for
the point of interest on Forsyth Creek downstream from U.S. Highway 70 at Clinchfield
(station id 0213814220); there are three nearby partial -record sites and two
continuous -record gaging stations in McDowell County and western Burke County that
are in vicinity of the subject site for which low -flow discharge estimates are provided. In
Table 1 of the report United States Geological Survey Water -Supply Paper 2403, '
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
3

Low -Flow Characteristics of Streams in North Carolina' low -flow discharge estimates
are provided for these nearby sites. Expressing these estimates as low -flow yields
provides some indication of 7Q10 flow estimates ranging from about 0.23 to 0.45 cfs
(average about 0.31 cfs). The regional low -flow relations presented in above
referenced report for this hydrologic area (HA10) results in a 7Q10 low -flow estimate
with yield value of about 0.28 cfsm.
Applying the above stated low -flow yields to a drainage area of 0.69 sq. mi. results in
7Q10 flow estimates ranging from about 0.15 to 0.3 cfs (average about 0.2 cfs).
No USGS records of discharge are known to exist for at the discharge point on Forsyth
Creek. Where no or insufficient data is available for a low -flow analysis, a
determination of low -flow characteristics is based on assessment of low -flow yields
(expressed as flow per square mile drainage area, or cfsm) at nearby locations where
such statistics have previously been determined. The low -flow characteristics that
have been provided have been computed by correlating the runoff characteristics of a
nearby stream in vicinity of the request site.
Therefore, based upon the preliminary investigation, it appears there are no flow or
water quality restrictions on Forsyth Creek that would immediately prohibit discharge of
domestic wastewater with a standard level of treatment to surface waters.
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
4

3.0 Technical Evaluation of Alternatives
3.1 Connection to Existing Waste Treatment Plant
Figure 3 shows a map of the closest existing Wastewater Treatment Facility which is
the Marion Catawba River facility (NPDES Permit No. NC0071200). The facility is
currently being assumed by the City of Marion. The closest connection point is a
pump station located off of Seagle Road. The route to the pump station has
approximately 68 ft of elevation gain from average elevation of the subject site. The
nearest connection location to the pump station is calculated to be 0.87 mile from the
subject property. BEA estimates one pump station and force main construction for the
entire 0.87 miles along U.S. Hwy 70 E, secondary roads, and private property would
be required to connect to this system. This facility is permitted for 0.25 MGD and the
City of Marion has stated that allocation for discharge to this plant is obtainable. The
allocation fees for City of Marion are included in the economic evaluation.
The next closest wastewater treatment facility is the Corpening Creek WWTP
(NC0020214). The facility is located approximately 6.3 miles south of the subject site.
Pump stations and force mains would also be required if the sewer line were to follow
federal and state roadways to the facility. The Corpening Creek facility would be
extremely difficult to route a sewer connection line and is much further away than the
Catawba River facility. This facility is not considered further in this evaluation.
While the connection to the Catawba River WWTP collection system is possible and
permittable, the distance and route required to the facility is significant and must be
evaluated for the economic feasibility. This option will be analyzed in Section 4.1.
3.2 Individual or Group Septic Systems
The McDowell County Department of Environmental Health performed a Soils
Evaluation for the site. Upon investigating the 1.34 acre site, sufficient drainfield area
for the existing building was not found. The soils were deemed "unsuitable" and the
application was denied. A copy of the McDowell County report is provided as
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
5

Attachment B. Brooks Engineering Associates conducted a soils investigation to find
areas suitable for subsurface disposal or surface irrigation. The entire site was
determined to be unsuitable due to setback conditions and inconsistent soil properties
on site. The Brooks Engineering Associates soils report letter summarizing the findings
is provided in Attachment C. The setbacks from surface water, property lines, and
right-of-ways and poor soil conditions render the subject site unsuitable for surface
irrigation.
For a community system, the 1,920 god system would require 1.32 acres for primary
and repair conventional drainfield area and 0.59 acre for a community subsurface drip
system. These calculated areas are based upon assumed average soil loading rates
and do not include any required acreage for setbacks and any pretreatment system
placement land requirements, just disposal area. Calculations are provided in
Attachment D. It is estimated a 0.59 acre area would be necessary to site the drip
system with the governing setbacks and allow for conveyance piping. This amount of
acreage is not available at the site.
Individual and/or community septic systems (including subsurface drip) are determined
to not be feasible at the subject site for the following reasons.
o The project soil scientist report has not identified any area suitable according to
the NCAC 18A .1900 rules due to the nature of the existing soil material.
o The site plan depicts no area available for on -site disposal. There is
insufficient acreage available.
As neither the County nor BEA found any available space on the proposed site with
suitable or provisionally suitable soil conditions, all of the 0.59 acre needed for a
community septic (or subsurface drip) system would have to be acquired from adjacent
property owners. This option is evaluated in subsequent sections.
3.3 Land Application & Reuse
A full investigation of the feasibility of a land application system typically encompasses
the following evaluations:
1. Soils Evaluation (to determine saturated hydraulic conductivity rates);
2. Agronomist Evaluation (to determine nutrient balance);
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex

3. Hydrogeologic Evaluation (to determine water table and lateral flow); and
4. Water Balance Evaluation (to determine storage requirements).
The irrigation rate is derived from soil saturated hydraulic conductivity measurements
and a water balance based upon regional rain and evapotranspiration and storage
provided. Based upon other regional projects, an irrigation rate of 1 inch per week
(in/wk) is an assumed reasonable irrigation rate that will not necessitate restrictions
based upon hydrologic or nutrient loading. A surface drip system would require 0.50
acre of disposal area (excluding setbacks and piping) with the same 1.0 in/wk loading
rate. Calculations are provided in Attachment D. To obtain the required setbacks for
surface irrigation systems, a reuse quality effluent would have to be provided (NCAC
18A 2T .0900 regulations) as the wastewater irrigation rule setbacks (NCAC 18A 2T
.0500 regulations) can not be met with the existing site conditions to maintain required
distances from habitable structures, property lines and surface waters. If reuse quality
effluent can be provided, the only applicable setback would be 25 feet from the surface
waters. From a practical standpoint, BEA estimates that at a minimum 0.50 acres
would be required off site to get the disposal system installed with the 1.0 in/wk loading
rate.
A wastewater reuse irrigation system is determined to not be feasible at the subject
site for the following reasons.
o The project soil scientist report has not identified any area suitable for land
application due to the nature of the fill material.
o The existing site conditions and improvements allow no available property for
on -site disposal.
o Under the NCAC 18A 2T .0900 regulations a wet weather storage pond,
typically sized for 30 days of wet weather storage (57,600 gallons) must be
sited and an additional pond sized for five days of storage (9600 gallons) would
have to be provided to accommodate "upset" conditions. An additional 0.05
acre would be required for constructing these ponds.
Again, the basic land requirements result in this disposal option as being unfeasible for
the present conditions. At a minimum, an additional 0.55 acre would have to be
purchased for the disposal area and for the necessary storage ponds under the 15A
NCAC 18A 2T .0900 requirements.
Brooks Engineering Associates, P.A. Engineering Alternatives Analysis
BEA Project No. 326409 Miller Apartment Complex

Additional Land Purchase
The economic feasibility of purchasing additional land purchase option is evaluated in
Section 4.0. From a practical feasibility standpoint, the following purchase options
have been evaluated and pursued. Adjacent property owner on the southwest is
Northstar Properties Limited (2.2 acres, Deed Book 485, page 708) and to the
northeast is Todd J. & Lisa M. Schweiger (0.79 acre, Deed Book 829, page 575). The
southwestern adjacent property is a commercial warehouse facility that consumes
most of the property. The northeastern adjacent property consists of a residential
home. The adjoining property owners are shown on the attached "Site Layout" map
(Figure 1).
None of the adjacent parcels are for sale and given the use none are likely to be for
sale. Neighboring land owners were not contacted for possible land acquisition by Mr.
Larry Miller. However, a PVCA is provided in Section 4.0 assuming land was
available.
3.4 Direct Discharge to Surface Waters
As discussed in Section 2, discharge to surface waters is found to be a technically
viable option as the initial evaluation has revealed the following conditions.
• Forsyth Creek has no zero -flow restrictions per 15A NCAC 2B.0206 (d)(2).
♦ Forsyth Creek has a Class C stream classification.
♦ Forsyth Creek is not designated as impaired stream and has no
designated TMDLs.
♦ This section of Forsyth Creek has no presence of endangered species.
3.5 Combination of Alternatives
Neither the subsurface disposal or land application alternatives are viable for the
development due to unsuitable soil conditions. A combination of discharge and land
application or subsurface disposal could be effective if there were a neighboring
property for sale with suitable soil conditions, but this is not the case.
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
8

Therefore, the only feasible options for the development are to connect to the nearest
public collection system (with a connection point 0.87 miles from the subject site),
acquire neighboring property, and a surface discharge permit. Each of these options
are evaluated in Section 4.
Brooks Engineering Associates, P.A. Engineering Alternatives Analysis
BEA Project No. 326409 Miller Apartment Complex

4.0 Economic Evaluation of Alternatives
The Present Value of Costs Analysis (PVCA) for each disposal option is provided as
Attachment E. The economic evaluation of alternatives is for each of the wastewater
treatment options based upon the best available information. As the apartment
complex is existing, no development costs are provided. Essentially the wastewater
system would have to be financed by rent profits. Should the wastewater system
upgrade not be within a reasonable cost, the apartment complex would be abandoned,
resulting in loss of lower income housing for the community. The cost for construction
and operation is calculated for the project under the following scenarios:
1) extending sewer service to the nearest existing collection system (Marion Catawba
River facility);
2) a community subsurface drip system requiring additional land purchase;
3) a community wastewater irrigation system (surface drip) requiring additional land
purchase; and
4) an on -site recirculating sand filter system with a surface discharge permit.
Only Options 1 and 4 were determined to be feasible in Section 3.0 primarily due to
site limitations and soil constraints, so Options 2 and 3 are analyzed under the
incorrect assumption that the purchase of adjacent property is possible. Options 1 and
4 are analyzed without an additional land purchase as none is required. The
Engineers Opinion of Cost (EOC) for the development infrastructure is provided as
Attachment F. The infrastructure costs in the Engineer's Opinion of Cost are based
upon professional experience and data collected on previous regional projects. As all
of the infrastructure cost would be incurred in the initial year of the development, they
are all considered initial costs and therefore have no time value discounting and are
not included in the PVCA analysis.
The owner rents all 8 units in the apartment complex. The rental price for each unit is
$500 resulting in a gross annual income of $48,000. After all financing and expenses,
the owner profits approximately $12,000 annually. The upgrades to the VWVTP must
be able to be financed with the annual profits of the apartment complex, or else the
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
10

apartments will be abandoned, resulting in the loss of much needed affordable housing
for the area.
4.1 Connection to Existing Wastewater Treatment Plant
The nearest sewer connection is the Marion Catawba River facility (NC0087602)
currently operated by the City of Marion .The nearest connection point to this facility is
a pump station located off Seagle Road measured to be 0.87 of a mile from the subject
site.
The cost for the internal development sewer collection for the apartment complex is
not included in the PVCA for each disposal option, but it is included in the general
infrastructure costs for the development as the collection system would have to be
implemented with any of the wastewater options.
The references utilized for the cost basis are as follows:
♦ The price for sewer force main line is based upon professional experience
and data collected on previous regional projects. This data shows the
average cost for 8-inch sewer line installation is $38/foot installed. This
price includes materials and labor. It is assumed this would require one
pump station (as a result of the headloss in the 0.9 miles of piping) and
several road bores to cross the road. This price does not include any road
re -surfacing as it is assumed the line could be installed off of the edge of
pavement the entire length. This may or may not be true. Any road
repairs would add significant cost. The price per foot could increase to
over $100 per foot should road re -surfacing be required.
6 The price for pump stations is based upon professional experience where
BEA has engineered similar pump stations to NC state standards. The
$150,000 price includes a diesel backup power generator.
4 The costs of the impact fees were from City of Marion Public Works.
As the operation and maintenance of the WWTF, pump stations, and force main would
be performed by the City of Marion and are of no expense to Larry Miller, these costs
are not included in the PVCA. Sewage rates would be paid by tenants. However, the
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
11

cost of the force main and pump station installation would be assumed by Larry Miller.
The route for the sewer extension analyzed is that shown on Figure 3 with
approximately 0.87 miles (4,594 ft).
The results of the PVCA show that the project can not possibly support the 0.9 mile
sewer extension is required, which would render it not an economically viable option.
This lengthy sewer extension would put undo hardship on the applicant and render his
land investment worthless. The PVCA for this option is provided in Attachment E.
4.2 Individual or Group Septic Systems
Individual and community septic systems are discussed in Section 3.2. Individual
septic systems are determined to be not a technically feasible option. A community
septic system is an option only with the purchase of additional neighboring property.
While no neighboring properties are available, this option is evaluated for economic
feasibility. The purchase price of $107,610 is determined from latest tax appraisal
data. It is determined in Section 3.2 that a minimum of 0.59 acres of land is required
for disposal plus additional acreage for set -backs and constructability. Assuming
property could be purchased, the northeastern adjoining lot (0.79 acres) would provide
the 0.59 acre.
The cost references utilized for the PVCA are as follows:
♦ The price for the wastewater treatment system is based upon vendor
pricing for a recirculating media system capable of delivering tertiary
treated effluent and includes materials, installation labor, and engineering.
♦ The price for the land application drip system is based upon vendor pricing
and includes materials, labor and engineering.
♦ Operation and maintenance costs are based upon professional
experience, except for electrical costs which are based upon state
requirements and vendor recommendations.
The results of the PVCA analysis demonstrate the project can not support this option,
even if any of the identified adjacent parcels are for sale. This renders this option
neither technically nor financially feasible.
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
12

4.3 Reuse Land Application
Individual and group land application systems are determined to not be technically
feasible without additional land purchase. Section 3.3 identifies an additional minimum
of 0.50 acre would be required for disposal and setbacks. Assuming property could be
purchased, a portion of the adjoining northeastern lot would need to be purchased.
The on -site collection and pump system are again the same for any of the treatment
options and this cost is not included in the PVCA, but is considered in the return on
investment analysis. The general infrastructure costs for the collection system in the
development would have to be implemented with any of the wastewater options, with
the exception of individual septic systems, and the cost is the same with each option,
except where otherwise noted.
Treatment of the effluent is to be performed by a recirculating media system capable of
delivering tertiary treatment standards. The effluent is then distributed to a drip
irrigation system located on the northeastern adjoining lot. The drip system will have
to be dosed by an additional pump station and have a disc filtration and monitoring
system.
The cost references utilized for the PVCA are as follows:
• The price for the extended a small aerobic packed media filtration system
is based upon vendor pricing and includes materials, installation labor,
and engineering.
• The price for the land application drip system is based upon vendor pricing
and includes materials, labor and engineering.
• Operation and maintenance costs are based upon professional
experience, except for electrical costs which are based upon state
requirements and vendor recommendations.
The results show the project can not support this option. Also, as no additional
neighboring acreage is available, this disposal option is rendered not technically
feasible nor financially feasible.
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
13

4.4 Direct Discharge to Surface Waters
This alternative is identified as technically viable and is analyzed for economic
feasibility. The Present Value of Costs Analysis is provided as Attachment E.
The proposed treatment technology is a recirculating media filtration unit. The
proposed plant is an E=Z Treat TM system in which septic tank effluent is dosed
approximately 36 times a day over a high surface area synthetic media for aerobic
biodegradation. The technology is capable of attaining tertiary treatment limits. The
system has a dual treatment train to allow for duplicity in the system and provide
backup treatment in an emergency situation. The system will be equipped with tablet
disinfection. A brochure for this technology is provided as Attachment G.
The references utilized for the PVCA are as follows:
♦ The price for the EZ-Treat system is based upon vendor pricing and
includes, materials, labor, engineering, and backup power.
♦ Operation and maintenance costs are based upon professional
experience, except for electrical costs which are based upon vendor
recommendations. (Electrical costs for the E-Z Treat system are less than
that of an extended air system as there are no blowers).
The results of the PVCA demonstrate this disposal option to be economically viable
with a 42% Return on Investment.
4.5 Combinations of Alternatives
As all soil disposal options require the purchase of additional land, which is not
available, no combinations of alternatives are deemed technically or economically
feasible.
Brooks Engineering Associates, P.A.
BEA Project No. 326409
Engineering Alternatives Analysis
Miller Apartment Complex
14

DOPY r. 97A11111
D.B. am Pa. an
ZUM L HATE. RS UL
D.D. 237, PG. 40
\ 4,*
G
C, NOT LOCATED IN A
SPECIAL FLOOD HAZARD
9y �� `
AREA.
481/280
PHONE
PEDESTAL
FENCE CROSSES
\
\\
PROPERTY LINE
NORTHSTAR PROPERTIES LIMITED PARTNERSHIP
D.B. 485, PG. 708
LEGEND
©
EXISTING IRON RESAR
A
DOSTING IRON PIPE
16
ENISTTNG SOLD IRON PIN
0
UNMARKED POINT
®
N.C.G.S CONTROL MONUMENT
&
UTILITY POLE
FIRE HYDRANT
e
WATER VALVE
®
PVC CLEAN -OUT
®
SANITARY SEWER MANHOLE
CHAIN-DNK FENCE
I II
KEYNOTES:
2500 gallon Septic Tank, IEin=997.84 See detail on Sheet WW-2. z
0
2 Proposed 3000 gallon pump tank, See detail on Sheet WW-2. y
m
OControl Panel. See Sheet W W-2 for Details. 8
z
O Recirculating Sand Filter Bed located within 20' x 20' concrete block enclosure. c o
/ ( See Details on Sheet W W-4 $ z
/ O Proposed 4:1 Ratio Box by American Manufacturing.
W
IEin = 998.08; IEaut = 998.08 s
z
Bio-Dynamic Model LF 3000 Chlorine Tablet Feeder, IEin=997.58 .. �
American Manufacturing Chlorine Contact Chamber ( See Detail an Sheet W W-3) Z
/ y IEin=997.79; 1Eout=997.74
`o`�anuuuuunoi
2nd Car. O Blo-Dynamic Model LF 3000 De -Chlorination Tablet Feeder
481/280 Ov
O Cascade Aerator w/ riprap; Outlet IE = 998.98 ( See Detail on Sheet W W-3) = o
)d. SEE NOTE CONCERNING sEff u _ w_
THIS SUVER OF LAM 0 y Existing sewer system to be removed upon completion on new system.
a �+
y��v / rrrlln ilt,,,,�,��
/ r
DD.B.�P�6711 �
F7 z a
cA" as I �0 5 S�go219
ORES
4 N
HCOS MONUMENT "CRESTVIEW
s N - 3.788.93'
8 1 .F 2'SCH40PVC
'O FOR AIN E-
721.117.988.77'
TEIM: MAO NAIL NAD a3(2007) �0 0
EliY=1000.0 (ASSUMED)` Q�• ^b+
ASPHALT PARKING r P 3 US
` / \ NODRDI24 TIED CORNER
1 O G�' / \ \ E - 1,118,939.78' 9 6
1 �� ep�\ NAD 83(2oD7) SYSTEM NOTES & CALCULATIONS: 4) a
0
� 1. Existing septic system to be abandoned upon construction completion of new system. = w $ 2 s
2. Design Flow = 1920 d. 120 d per bedroom: 8 Two bedroom units; 120.2.8 = 192
/ ocaAL / 0�1 0.00 9 9P ( 9P P Ol CD S
C� �;D \ 3. Recirculating Sand Filter Square Footage = 1920 gpd ! 5 gpd/Ft"2 = 384 sq.ft. C
/�"- Jj ( See Sheet W W-2 for details.) W o
c� co M
m m I pp
N N U�
c I N m
GENERAL NOTES: m V 'C' Z 00 o
i. All work and materials must meet or exceed the standards set forth In the Laws and Rules of Sewage Treatment and c m ro C4 o
Disposal Systems by N.C. Department of Envlronmental Health and Natural Resources dated August 3, 1996 and _ _
January20, 1997. Q > g
1 �, �, 2. All electrical and plumbing work must meet or exceed N.C. Building Cade and be approved by the McDowell County m m x 3
D.B. 6a0, P0. 80 Department of Public Health before operating. < o 0
1 0 3. Any alterations to this system shall be approved by the Project Engineer and McDowell County Department of a I`
' PANE Environmental Health.
&PEDESTAL Qi' .•iv - �� \ 4. Annual sampling of the effluent from [he system is required. See'Technical Bulletin forGeneral Permit
ti°A' ery6 NCG550000" as provided as part of these plans for further details.
yLA� ��• / � z
/ \ •�
ENGINEERING NOTES: �
'\ TRASH DIN / / - 1. Maintain minimum 1/R' per foot slope on all gravity lines.
>iae1111T NEWA'!$rx BY UL 2. Maintain minimum 1 foot of cover over conveyance piping. 2 feet of cover typical. Z =
\ Da a97, PG. 120 3. All tanks shall have no more than 3 feet of cover, unless H-20 traffic rated tanks substituted. W g
4. All gravity conveyance piping to be 4"0 (min.) Schedule 40 PVC. 2: tl z
/ \ 5. Cleanouts required every 100' on gravity lines. 1-7
6. All tanks shall be sited a minimum of 5' from building foundations.
\ W Q
`�'•+ �/ \ Survey Note: Qg j
1. The boundary shown hereon is for Information only and should not be construed as an actual boundary survey.
2. Elevation Datum is assumed. r Q 0
D01311111T I!A'lRM g VDIL \ 3. This property is not located within a flood hazard area per FEMA FIRM Number 37021 C0352 C, dated May 6, 1998. LL1 a.
L& 872. PG. m
o �
fri O
Z
0
a
f
Z
SCALE 1"=30' SITE SURVEY PROVIDED BY:
0' 30' 60' 9C' O- LL1
R.L. GREENE SURVEYING AND MAPPING C CD Lotion Sbwt M2m=North Cvdiny 28732 Z � TWOO-e (( F
v M 3

Scale as shown.
Note: Extracted from Delorme TopoUSA digital geographic data.
SITE LOCATION MAP
FIGURE 2

Scale as shown.
Note: Extracted from Delorme TopoUSA digital geographic data.
EXISTING TREATMENT PLANT MAP
FIGURE 3

Attachment A. Local Government Review Form
General 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 (EMC) 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 lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a 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 statewide
significance and is in the best interest of the State.
Instructions to the Applicant: 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 certified mail, return receipt requested.
■ If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
■ As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the
15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government -IT F M a r 1 d i-)
(City/County)
Does the city/county hh jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [ ] 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 [ ] No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [ ]
No [ ]
Date�VQIISignature - ����A ' L11c7�Itr
( ity Manager/C Tanager) J
c
State of 14 0 RE CJel TW I_ i ).3 M , County of _ MFrJ_QQ3 F3L L
On this C� day of — 6F_D7i=m&eJ? , 2001, personally appeared before me, the said
name Ikoi3E !2 i 1LOW LD:_ to me known and known to me to be the person described in
and who executed the foregoing document 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 document are true.
My Commission expires r.r+� aA 13 .(Signature of Notary Public fl4 LD
Notary Public (Official Seal)
DEBRA W SHE"
r.sowy Pof k
Me DMO co"
my, 1113
Mirth CMS
EAA Guidance Document Version: June 23, 2005

1
The Local Government Review Form sent to the county has not been received as of
September 30, 2009. A copy of the Domestic Return Receipt has been attached below.
■ Complete items 1, 2, and 3. Also complete A.
item 4 if Restricted Delivery is desired. X
■ Print your name and address on the reverse
so that we can return the card to you. B.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
COOIi AikAr i, phi
AA+P- c o1J /,"Ic", �r'�SA
O Agent
Received b (P ' ted Name C. of
>s delivery address differen from item i? L Ye:
If YES, enter delivery address below: ❑ No
3. Service Type
❑ Certified Mail ❑ Express Mail
0 Registered ❑ Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery?(Extra Fee) p Yes
2. Article Number
(Transfer from service label) 7009 1680 0001 6087 9925
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540

Planning & Project Management / Civil Engineering % Surveying
BROOKS Soil Science Services i Environmental Engineering & Services
ENGINEERING ASSOCIATES 17Arlington Street / Asheville NC 28801 / www.brooksea.com / 828-232-4700
There have been several attempts to contact the McDowell County Health Department
regarding the denial of conventional sub -surface discharge systems. The Health
Department will not return any calls or provide correspondence regarding this project.
The Local Government Review Form was sent certified mail with a domestic return
receipt with a dated delivery of September 9, 2009. As of September 30, 2009 that form
has not been received by Brooks Engineering Associates, P.A. A copy of this receipt has
been provided in previous section of this submittal.

Brooks Engineering Associates
Land Planning Civil Engineering Surveying Environmental Services Soil Science Services
April 22, 2009
Larry Miller
G.E.M. Constructors, Inc.
2024 Nix Creek Road, Suite A
Marion, North Carolina 28752
Attention: Mr. Miller
Regarding: Report of Findings Soils Evaluation
2041 U.S. Highway 70
McDowell County, NC
Dear Mr. Miller,
Walker B. Ferguson of Brooks Engineering Associates (BEA) conducted a soils investigation on
a 1.34 acre tract located at 2041 Highway 70 McDowell County, North Carolina. This
investigation was conducted at the request of Mr. Miller. The purpose of the soil study was to
determine if any land based wastewater options were available for an eight two-bedr000m unit
apartment complex. The apartment complex is currently being served by a sand filter and surface
water discharge system which is in failure.
Fieldwork was conducted using the following tools and methods. A 3-inch hand auger, a knife,
and a sharpshooter shovel were used to examine the soil. A Suunto clinometer was used to
measure soil slope.
Recommendations are based on, but not limited to, observations made and data collected on
topography, landscape position, parent material, underlying geology, and soil characteristics.
Soil characteristics include, but are not limited to, depth to a seasonal high water table (SHWT),
depth to a restrictive horizon, total soil depth, soil horizonation, soil structure, soil color, clay
mineralogy, bulk density, consistence, plasticity, stone content, and percent sand, silt, clay, and
mica. They follow the guidelines set forth in the North Carolina Laws and Rules for Sewage
Treatment and Disposal Systems, laws amended effective December 19, 2001, and rules
amended effective June 1, 2006. Grading which occurs subsequent to this fieldwork renders the
soil investigation in the graded area null and void.
17 Arlington St. Asheville, NC 28801 www.brooksea.com ph.828.232.4.700 fx.828.232.1331

RESULTS AND DISCUSSION
• BEA found Mr. Millers tract to be unsuitable for any surface or subsurface wastewater
disposal system. The site is unsuitable for a subsurface wastewater system due to a
shallow Seasonal High Water Table (SHWT) and insufficient area to support the 1920
gal/per/day (gpd) design flow. This tract does not meet setback requirements for surface
drip irrigation to be considered.
• BEA concludes that the only feasible alternative for the 1920 gpd is a pre-treated surface
water disposal system into the stream northwest of the apartment complex.
Thank you for the opportunity of presenting this information to you. If we can be of further
assistance, please feel free to call.
Sincerely,
Walker B. Ferguson
Licensed Soil Scientist
2

References:
1. North Carolina Department of Environment, Health, and Natural Resources, Division of
Environmental Health, On -Site Wastewater Section. 1998. Laws and Rules for Sewage
Treatment and Disposal Systems, section .1956(6). P.O. Box 27687, Raleigh, NC, 27611-
7687.
2. North Carolina Department of Environment, Health, and Natural Resources, Division of
Environmental Health, On -Site Wastewater Section. 1996. Procedures and Information
Required for Approval of Large Subsurface Wastewater Systems. P.O. Box 27687, Raleigh,
NC, 27611-7687.
3. North Carolina Department of Environment, Health, and Natural Resources, Division of
Environmental Management. 1996. Administrative Code Section: 1 SA NCAC 2H. 0200 —
Waste Not Discharged to Surface Waters. Environmental Management Commission,
Raleigh, NC

r Brooks Engineering Associates
www.brooksea.com 17 Arlington St. Asheville, NC 28801 ph.828.232.4700 fx.828.232.1331
Land Planning Civil Engineering Surveying Environmental Services
Project Name V•S• NW 70 F- h wyon;:o GL&vftrx- Project Number 3-7-�`9 0 5
By ?F5 Date -Xoa l 2JO Sheet_ of
Subject 6cl 1�tKP405k[_.Oftaa CA44,3�-A-rto,,15
Go.NJErJT�®,�qc, �JE.i''i' oC.. St's"fEJ"1, l�Q V.a2.��E�j'S
0. 2, . & P D/5 F 1,.0 A 01 ^�6 RAT`
1192.0 GPD =- 0.2 PD/sr = 5 6oO SF
X 3 Fop. TiZi £�Gc-t. SPAc.I r- 6 r�Z a J goo 5 r
X ' Foy- ReP/t 1, lL AP -EA = 5i 1 6 ®a s F = 1. 32 Aci,E5
1�. S uE)5%3tifAcE- DRIP_. 61?srf m� KFL Q t 2F—Mf.�S
ASSunaf— 0. 15 CPof. SF 1-.aaot�(� "T-E_
1)-920 GPD -
0.15 b?,O f SF =
12/
eov
Sr_
X 7-
Fog- P, E.PA t 2 =
25/
b o©
SF = 0.55 ACt2E
�. S o RFA GC. DR i .P_ S°? STr M
ASS0t+\L I 11\1c-H/VJfFC C k6ACIOG P-ATt
GPo -; D, oe9 G PO f t �- = 21) 5�13 1= 2 = O. 50 /�CfL1

I Connection to Existing Sewer System Option - Marion Catawba River WWTF
Item Units No. Units Cost/Unit Cost
Construction
Installation of Gravity Sewer Line - Offsite
feet
0
$151.5
$0
Installation of Force main Line
feet
4593
$38
$174,534
Installation of Pump Stations
each
1
$150,000
$150,000
Underground Road boring
per crossing
2
$6,000
$12,000
subtotal
$336,534
Easements & Legal fees
Marion Tap Fee ($2,520/unit)
per
8
$2,520
$20,160
Engineering & Carry Costs
Engineering, Surveying & Permitting Fees
$45,000
Operation & Maintenance (Pump Stations)
Contract O&M (included above)
$0.00
Electricity & Parts (included above)
$0.00
PRESENT VALUE ANALYSIS FOR SEWER EXTENSION SCENARIO
Present Value (PV) = Co + T-n cm+r)`
where: Co = Initial Costs in present year
Ct = costs incurred in time t
t = time period after present year
n = ending year of facility life
r = current EPA discount rate
Year Expenditure
0 Original Land Acquisition & Development Costs
1 Cost of Sewer Extension
2 Finance Charges (Annualized)
3 Finance Charges (Annualized)
4 Finance Charges (Annualized)
5 Finance Charges (Annualized)
6 Finance Charges (Annualized)
7 Finance Charges (Annualized)
8 Finance Charges (Annualized)
9 Finance Charges (Annualized)
10 Finance Charges (Annualized)
1 Finance Charges (Annualized)
11 Finance Charges (Annualized)
12 Finance Charges (Annualized)
13 Finance Charges (Annualized)
14 Finance Charges (Annualized)
15 Finance Charges (Annualized)
16 Finance Charges (Annualized)
17 Finance Charges (Annualized)
18 Finance Charges (Annualized)
19 Finance Charges (Annualized)
20 Finance Charges (Annualized)
Return on Investment Analysis
20 year Cost PV
20 Year Income PV
Return on Investment
4.875%
Incremental
Total
Incremental
Total
Cash
Cost PV
Cost PV
Income PV
Income PV
$0
$0
$0
$12,000
$401,694
$383,022
$383,022
$11,442
$11,442
$22,897
$20,817
$403,839
$10,403
$21,845
$21,691
$18,805
$422,644
$9,019
$30,864
$20,486
$16,935
$439,579
$7,455
$38,319
$19,281
$15,198
$454,776
$5,876
$44,196
$18,076
$13,586
$468,362
$4,416
$48,612
$16,871
$12,090
$480,452
$3,165
$51,777
$15,666
$10,705
$491,157
$2,163
$53,940
$14,461
$9,422
$500,579
$1,409
$55,349
$13,256
$8,235
$508,815
$875
$56,224
$12,051
$11,491
$520,306
$835
$57,059
$22,897
$13,564
$533,869
$494
$57,553
$10,846
$6,126
$539,996
$279
$57,833
$9,641
$5,192
$545,188
$150
$57,983
$8,436
$4,332
$549,520
$77
$58,060
$7,230
$3,541
$553,061
$38
$58,098
$6,025
$2,813
$555,874
$18
$58,116
$4,820
$2,146
$558,020
$8
$58,124
$3,615
$1,535
$559,555
$3
$58,127
$2,410
$976
$560,531
$1
$58,129
$1,205
$465
$560,996
$1
$58,129
Present Value $560,996 $58,129
$560,995.92
$58,129.06
-865.09%
Brooks Engineering Associates, P.A. p. 1 of 4

II Community Subsurface Drip System
Item
Units
No. Units
Cost/Unit
Cost
Land Acquisition
Initial Purchase (NE Adjoining 0.79 Acre Parcel)
Lot
1
$107,610
$107,610
Subtotal
$107,610
Construction
1920 gpd WWTP
per
1920
$12
$23,040
Irrigation Controls & Pumping system
per
1,920
$8
$15,360
Transfer piping to irrigation fields
ft.
1,750
$12
$21,000
Irrigation line and heads
lin. ft.
16,875
$2.50
$42,188
Subtotal
$101,588
Annual Operation & Maintenance
Recommended operator checks
per visit
4
$150
$600
Laboratory
per visit
4
$200
$800
Pump outs
pervisit
1
$500
$500
Electrical
per month
12
$150
$1,800
Subtotal
$3,700
5 Year Capital Improvements
Pump & line repairs
Estimate
I
$2,500
$2,500
Salvage Value (20% of original cost)
$20,318
PRESENT VALUE ANALYSIS FOR LAND APPLICATION SCENARIO
Present Value (PV) = Co + Y-n Ctl(1+r)t
where: Co = Initial Costs in present year
Ci = costs incurred in time t
t = time period after present year
n = ending year of facility life
r = current EPA discount rate
4.875%
Incremental
Incremental
Year
Expenditure
Cash
Cost PV
Income PV
0
Original Land Acquisition & Development Costs
$107,610
$107,610
$12,000
1
System Construction
$101,588
$96,865
$11,442
2
O&M
$3,700
$3,364
$10,910
3
0&M
$3,700
$3,208
$10,403
4
O&M
$3,700
$3,059
$9,920
5
O&M
$3,700
$2,916
$9,458
6
O&M & Capital Improvements
$6,200
$4,660
$9,019
7
O&M
$3,700
$2,652
$8,600
8
O&M
$3,700
$2,528
$8,200
9
O&M
$3,700
$2,411
$7,819
10
O&M
$3,700
$2,299
$7,455
11
O&M & Capital Improvements
$6,200
$3,673
$7,109
12
O&M
$3,700
$2,090
$6,778
13
O&M
$3,700
$1,993
$6,463
14
O&M
$3,700
$1,900
$6,163
15
O&M
$3,700
$1,812
$5,876
16
O&M & Capital Improvements
$6,200
$2,895
$5,603
17
O&M
$3,700
$1,647
$5,343
18
0&M
$3,700
$1,571
$5,094
19
O&M
$3,700
$1,498
$4,858
20
O&M - Salvage Value
-$16,618
-$6,414
$4,632
Present Value Cost
$244,235
$163,144
Return on Investment Analysis
20 year Cost PV
$244,235.28
20 Year Income PV
$163,144.32
Return on
Investment
-49, 71 %
Brooks Engineering Associates, P.A. p. 2 of 4

III Reuse Land Application
Item
Units
No. Units
Cost/Unit
Cost
Land Acquisition
Initial Purchase (NE Adjoining 0.79 Acre Parcel)
Lot
1
$107,610
$107,610
Subtotal
$107,610
Construction
1920 gpd WWTP
per
1920
$12
$23,040
5-day lined upset pond
gal
9600
$0.25
$2,400
30-day Wet weather storage pond
gal
57600
$0.25
$14,400
Irrigation Controls & Pumping system
per
1,920
$8
$15,360
Transfer piping to irrigation fields
ft.
1,750
$12
$21,000
Irrigation line and heads
lin. ft.
16,875
$2.50
$42,188
Subtotal
$118,388
Annual Operation & Maintenance
Recommended operator checks
per visit
12
$35
$420
Laboratory
per visit
12
$200
$2,400
Pump outs
per visit
1
$500
$500
Electrical
per month
12
$150
$1,800
Subtotal
$5,120
5 Year Capital Improvements
Pump & line repairs
Estimate
1
$2,500
$2,500
Salvage Value (20% of original cost)
$23,678
PRESENT VALUE ANALYSIS FOR LAND APPLICATION SCENARIO
Present Value (PV) = Co + y- Ct/o+r)'
where: Co = Initial Costs in present year
Ct = costs incurred in time t
t = time period after present year
n = ending year of facility life
r = current EPA discount rate
4.875%
Incremental
Incremental
Year
Expenditure
Cash
Cost PV
Income PV
0
Original Land Acquisition & Development Costs
$107,610
$107,610
$12,000
1
System Construction
$118,388
$112,884
$11,442
2
O&M
$5,120
$4,655
$10,910
3
O&M
$5,120
$4,439
$10,403
4
O&M
$5,120
$4,232
$9,920
5
O&M
$5,120
$4,036
$9,458
6
0&M & Capital Improvements
$7,620
$5,727
$9,019
7
O&M
$5,120
$3,669
$8,600
8
O&M
$5,120
$3,499
$8,200
9
O&M
$5,120
$3,336
$7,819
10
O&M
$5,120
$3,181
$7,455
11
O&M & Capital Improvements
$7,620
$4,514
$7,109
12
O&M
$5,120
$2,892
$6,778
13
O&M
$5,120
$2,758
$6,463
14
O&M
$5,120
$2,629
$6,163
15
O&M
$5,120
$2,507
$5,876
16
O&M & Capital Improvements
$7,620
$3,558
$5,603
17
O&M
$5,120
$2,280
$5,343
18
O&M
$5,120
$2,174
$5,094
19
O&M
$5,120
$2,073
$4,858
20
O&M- Salvage Value
-$18,558
-$7,163
$4,632
Present Value Cost $275,489
Return on Investment Analysis
20 year Cost PV
20 Year Income PV
Return on Investment
$163,144
$275, 488.89
$163,144.32
-68.86%
Brooks Engineering Associates, P.A. p. 3 of 4

IV Surface Discharge WWTP
Item Units No. Units Cost/Unit Cost
Land Acquisition
Initial Purchase acres 0 $0 $0
Subtotal $0
Construction
1920 gpd WWTP per 1920 $18 $34,560
Subtotal $34,560
Annual Operation & Maintenance
Recommended operator checks
per visit
12
$35
$420
Laboratory
per visit
12
$200
$2,400
Pump outs
per visit
1
$500
$500
Electrical
per month
12
$150
$1,800
Subtotal
$5,120
5 Year Capital Improvements
Pump & line repairs
Estimate
1
$2,500
$2,500
Salvage Value (20% of original cost)
$6,912
PRESENT VALUE ANALYSIS FOR LAND APPLICATION SCENARIO
Present Value (PV) = Co + En Ct/(1+r)t
where: Co = Initial Costs in present year
Ct = costs incurred in time t
t = time period after present year
n = ending year of facility life
r = current EPA discount rate 4.875%
Year
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Expenditure
Original Land Acquisition & Development Costs
System Construction
O&M
O&M
O&M
O&M
O&M & Capital Improvements
0&M
O&M
O&M
O&M
O&M & Capital Improvements
O&M
O&M
0&M
O&M
O&M & Capital Improvements
O&M
O&M
O&M
O&M - Salvage Value
Return on Investment Analysis
20 year Cost PV
20 Year Income PV
Return on Investment
Incremental
Incremental
Cash
Cost PV
Income PV
$0
$0
$12,000
$34,560
$32,954
$11,442
$5,120
$4,655
$10,910
$5,120
$4,439
$10,403
$5,120
$4,232
$9,920
$5,120
$4,036
$9,458
$7,620
$5,727
$9,019
$5,120
$3,669
$8,600
$5,120
$3,499
$8,200
$5,120
$3,336
$7,819
$5,120
$3,181
$7,455
$7,620
$4,514
$7,109
$5,120
$2,892
$6,778
$5,120
$2,758
$6,463
$5,120
$2,629
$6,163
$5,120
$2,507
$5,876
$7,620
$3,558
$5,603
$5,120
$2,280
$5,343
$5,120
$2,174
$5,094
$5,120
$2,073
$4,858
-$1,792
-$692
$4,632
Present Value Cost $94,419 $163,144
$94,419.10
$163,144.32
42.13%
Brooks Engineering Associates, P.A. p. 4 of 4

Engineer's Opinion of Cost
BEA Project#
d
326409
---------------------------------
---------------------------------
Component
---------------------------------
---------------------------------
---------- ----
---------- ----
Unit
---------- ----
---------- ----
----------- - ---------------------------
----------- - ---------------------------
Unit Price
----------- - ---------------------------
----------- - ---------------------------
Cost
2000 Gallon Septic Tank
1 EA
$3,500.00
$3,500.00
3000 Gallon Pump Tank
1 EA
$4,500.00
$4,500.00
Pump System
1 EA
$2,800.00
$2,800.00
Sand Filter Enclosure
1 EA
$17,500.00
$17,500.00
Ratio Box
1 EA
$600.00
$600.00
Tablet Feeder
2 EA
$800.00
$1,600.00
Contact Chamber
1 EA
$1,000.00
$1,000.00
Cascade Aerator
1 EA
$1,500.00
$1,500.00
4" PVC Pipe
150 LF
$10.40
$1,560.00
Total Cost: $34,560.00
1