NC0036684_Fact Sheet_20210103

DENR/DWQ
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO036684
2020 Renewal
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns).
Facility and Stream Information
Applicant/Facility Name:
Carolina Waters Services, Inc. of NC Bent Creek WWTP
Applicant Address:
P.O. Box 240908; Charlotte, NC 28224
Facility Address:
5 Donnybrook Ct; Asheville, NC 28806
Facility Class Permit Status:
Grade II Biological WPCS Renewal
Permitted Flow
0.1 MGD
Type of Waste
100% Domestic
Receiving Stream
Wesley Creek
Stream Class ID
B 6-67-10
River Basin
French Broad
Subbasin
04-03-02
HUC
0601010SO705
USGS Too
Asheville, NC EBSE
7Q10 Sum Win cfs
0.4 0.5
30Q2 cfs
0.7
Avg. Stream Flow cfs
1.2
IWC % S W
27.93% 23.66%
County
Buncombe
I Regional Office
ARO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / November 2, 2020
Does permit need daily max NH3 limits?
Already included in existing permit - see below
Does permit need TRC limits/language?
Limits in permit
Does permit have toxicity testing?
No - does have NH3-N limits
Does permit have Special Conditions?
No
Does permit have instream monitoring?
Yes - U D for DO and Temp
Stream on 303 d List? For w/parameter?
No
Any compliance concerns?
See compliance discussion below
Any modifications since last permit?
None noted in application
New expiration date:
I October 31, 2025
FACILITY OVERVIEW:
This facility is 100% domestic waste. The application notes that the residential subdivision (Saddle Creek) has
306 homes and estimates 765 people. The design capacity of the treatment system is 0.1 MGD and consists of
the following wastewater treatment components:
• Dual extended aeration basins
• Final clarifiers with sludge return
• Tablet chlorination with tablet dechlorination
• Post -aeration
• Sudge digester
No modifications were noted or proposed in the current application. The 2020 application noted the location
of the facility as 3 Donnybrook Cr but the applicant verified that the address should be 5 Donnybrook.
Most recent inspection (10/18/2019) noted a few issues with concrete decay at the WWTP. Staff in the
Asheville Regional Office (ARO) have indicated that the permittee has plans within the next few years to look at
replacement of the WWTP. ARO staff indicate that the facility is operated well.

COMPLIANCE:
During the permit cycle this facility had two enforcement actions (2017 and 2018) for limits violations - Fecal
and TSS in one and DO and NH3-N in the second. These enforcement actions resulted in total assessments of
$685.30 ($450 in penalties). The facility has had eight (8) NOVs and one (1) NOD during the permit cycle. It
should be noted that only two of these violations have occurred since July 2018. So, the last two and one-half
years have shown the facility in regular compliance.
MONITORING DATA REVIEW:
arameter Units
High
Low
Permit Limit
Comments
Flow (MGD)
___&vg.&
0.033
0.119
0.012
0.1 MA
BOD (mg/L)
5.97
49
2
30MA
1 exceedance in 244 data points
45DM
TSS (mg/L)
5.63
75
0
30MA
3 exceedances in 245 data points
45DM
Temp (C) - Upstream
13.14
24
1
Temp (C) - Effluent
18.10
26
1.6
-
Values in line with seasonal variation
Temp (C) - Downstream
13.74
24
1
Fecal (#/100ml)
18.25
1,140
0
200MA
No exceedances
40ODM
pH (SU)
N/A
7.67
5.6
6 to 9
Only one value out of range
NH3-N (mg/L) summer
0.62
3.2
0
3MA
15DM
See discussion below - proposed
change of winter limits to 6 and 30.
NH3-N (mg/L) winter
1.83
27.30
0
6.9MA
No daily values would have exceeded
34.5DM
the new limit of 30 but 3 monthly avg
out of 23 would have exceeded.
TRC (µg/L)
17.13
48
0
28DM
29 values >28 but none >50 threshold
DO (mg/L) - Upstream
9.49
13.30
5.6
12 Effluent values less than 5, but no
DO (mg/L) - Effluent
7.25
10.50
3.0
>= 5
downstream levels below 5. 104 value
DO (mg/L) - Downstream
9.67
104.00?
5.6
is questionable value.
TN (mg/L)
9.12
18.50
0.90
TP (mg/L)
4.39
5.20
3.30
MA - Monthly Average DM - Daily Max
The data reviewed for the renewal is from January 2016 through August 2020.
FILE HISTEORY REVIEW SUMMARY
The 2005 permit added TRC limit and also added NH3-N limit. With addition of NH3-N Toxicity
monitoring was removed from the permit.
The 2010 permit had no major changes
The 2015 permit had minor clarifications and updates in the permit language. Two technical
corrections were made after the initial issuance. So any review to look for the final permit for this cycle
should assure that all updates in the file are found.
Bent Creek WWTP Fact Sheet
NPDES Renewal 2020 - Nov 2, 2020
Page 2

NH3-N MONITORING:
Current Requirement: Weekly monitoring in Current Permit. Permit has summer limits of
3 and 15mg/L (Monthly Average and Daily Max) and winter limits
of 6.9 and 34.5mg/L (MA and DM).
Recent review by Division staff has noted that 15A NCAC 2B .0404(c) requires that winter waste load
allocations for oxygen consuming waste be no less stringent than 2 times the summer waste load limit.
To meet this rule requirement winter monthly average limits for NH3-N are being adjusted in the
permit.
The draft permit includes proposed changes to the winter limits. These changes will reduce the
monthly average limit to 6 mg/L and the daily max will be reduced to 30 mg/L. A review of the
monitoring data over the permit cycle indicates that the highest winter NH3-N value was 27.3 mg/L,
which occurred one time. So, no daily values exceeded the daily winter limits. There were three (3)
instances over the last permit cycle where monthly averages would have exceeded the proposed 6
mg/L monthly average limit. Three (3) monthly averages out of 23 total months evaluated. The
proposed change was discussed with the permittee along with the results of the data review. The
permittee felt that the change would not cause any significant issues.
PROPOSED PERMIT CHANGES:
• Updated eDMR requirements to be consistent with final EPA rule.
• Added regulatory citations throughout permit as needed.
• Updated NH3-N effluent limits to set winter limits at 6mg/L (Monthly Average) and 30 mg/L
(Daily Max).
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: November 10, 2020
Permit Scheduled Effective Date: February 1, 2021
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett
at [phone].
Bent Creek WWTP Fact Sheet
NPDES Renewal 2020 — Nov 2, 2020
Page 3

CITIZEN=TIMES
November 14, 2020
0004464730
ap V pljoyo .z'
..... ....... C
PART OF THE USA TODAY NETWORK
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
NORTH CAROLINA
Before the undersigned,a Notary Public, duly commissioned, qualified and
authorized by law to administer oaths, personally appeared said legal clerk,
who, being first duly swam, deposes and says: that he/she is the Legal
Clerk of The Asheville Citizen -Times, engaged in publication of a
newspaper known as The Asheville Citizen -Times, published, issued, and
entered as first class mail in the City of Asheville, in Buncombe County and
Slate of North Carolina; that he/she is authorized to make this affidavit and
sworn statement; that the notice or other legal advertisement, a true copy of
which is attached here to, was published in The Asheville Citizen -Times on
the following date(s) 11/14120. And that the said newspaper in which said
notice, paper, document or legal advertisement was published was, at the
time of each and every publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of the General Statues of
North Carolina and was a qualified newspaper within the meaning of
Section 1-597 of the General Statutes of North Carolina.
AASigned this 16th of November, 2020 ,
Legal Clerk
Sworn to and su scribed before the 16th of November, 2020
Notary Public o Sfate of N4sconsin, County of wn
My Commission expires.
[phone] I [phone] FAX
14 O. HENRY AVE. I P.O. BOX 2090 ( ASHEVILLE, NC 28802 1 [phone]

11 /10/2020
Mail - Bennett, Bradley - Outlook
[External] RE: Draft Permit for Bent Creek WWTP Renewal - NCO036684
Tony Konsul <[e-mail]>
Tue 11/10/2020 7:57 AM
To: Bennett, Bradley <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Received, thank you.
From: Bennett, Bradley <brad ley. bennett@ ncdenr.gov>
Sent: Tuesday, November 10, 2020 7:49 AM
To: Tony Konsul <Tony.Konsul@caroli nawaterservicenc.com>
Subject: Draft Permit for Bent Creek WWTP Renewal - NCO036684
CAUTION: This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and verify that the content is safe.
Hey Tony,
Attached you will find a cover letter and the draft permit for the Bent Creek WWTP (Nc0036684). This draft
will go to public notice later this week. Please take a look and let me know if you have any comments or
questions.
Please respond to this email to let me know that you received the permit document and are able to read it
and download it for your records.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
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11/2/2020 Mail - Bennett, Bradley - Outlook
RE: [External] RE: Permit Renewal Issues
Tony Konsul <[e-mail]>
Mon 11/2/2020 8:41 AM
To: Bennett, Bradley <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to [e-mail]
I think we would be okay with the limit changes for the NH3-N and really do not see any problems with what you
have listed below.
Thank you
From: Bennett, Bradley <bradley. [e-mail]>
Sent: Monday, November 2, 2020 8:34 AM
To: Tony Konsul <[e-mail]>
Subject: Re: [External] RE: Permit Renewal Issues
CAUTION: This email originated from outside of the organization. Do not click links or open
attachments unless you recognize the sender and verify that the content is safe.
Thanks for the response Tony and for sending the memo. I'll get these permits updated in our system
and forward this on to make sure it is reflected in others as needed. Sorry for any confusion on this. Let
me know your comments on the possible limits change.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: brad ley. ben [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Tony Konsul <[e-mail]>
Sent: Monday, November 2, 2020 8:31 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: [External] RE: Permit Renewal Issues
CAUTION- External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]
Mr. Bennett,
I have been completing the renewal packages for our wastewater permits since 2008, see the attached letter. I will
need to speak with my staff in regards to the NH3-N and will be back in touch with you on that matter.
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2ElODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/3

11 /2/2020
Mail - Bennett, Bradley - Outlook
Thanks,
From: Bennett, Bradley <[e-mail]>
Sent: Monday, November 2, 2020 8:05 AM
To: Tony Konsul <[e-mail]>
Subject: Permit Renewal Issues
CAUTION: This email originated from outside of the organization. Do not click links or open
attachments unless you recognize the sender and verify that the content is safe.
Hi Tony,
I just wanted to get with you about a couple of issues as I am working on two of your permit renewals.
One is a general issue that applies to both of the renewals I have but that may apply to others as well.
The second is specific to Bent Creek.
• Responsible Official Issue - For each of the permits I am working on - Queens Harbor and Bent
Creek - you sent in and signed the application. However, you are not listed in our permitting
database as having delegated authority for these facilities. JB Mendenhall is listed as the Owner
and Don Denton as Co -Owner for each. You are in our system as a contact person but I don't see
any record of you having delegated signature authority for these facilities. I have attached a
template form for you to be granted this authority if you should have that. Otherwise we should
get application forms signed by either the Owner or Co -Owner.
• Bent Creek Limit modification for Ammonia (NH3-N) - Our rules (2H .0404) require that in setting
limits for oxygen consuming waste we assure that winter limits are no less stringent than 2 times
the summer limits. This would apply to other oxygen consuming parameters and not just
ammonia. We have become aware that in a number of permits we did not follow this
requirement. Bent Creek is one of those permit and has winter limits that are set at a level more
than two times the summer limits. We are looking at this issue in the draft permit. Making this
adjustment would lead to the winter limits decreasing as follows: Monthly Average would drop
from 6.9 to 6.0 mg/L and your Daily Max would drop from 34.5 to 30.0 mg/L. Looking at the data
from the previous cycle for the winter months it looks like none of your daily values exceeded the
proposed 30mg/L. However, there would have been three months where your monthly average
would have exceeded 6.Omg/L. I just wanted to get your feedback on this proposed change.
I am currently working remotely so email is the best way to contact me. If we need to talk we can set up
a day/time for a call through email.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: brad ley. ben [e-mail]
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11 /2/2020
Raleigh, NC 27699-1617
Mail - Bennett, Bradley - Outlook
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cut7ilitie=s, Inc",
June 3, 2008
Ms. Coleen Sullins, Director
NC DENR - Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Permitting Signature Authority
Dear Ms. Sullins,
Regional Office: P.O. Box 240908
Charlotte, North Carolina 28224
Telephone: [phone]
Fax: [phone]
As an appropriate signing official of Utilities, Inc. for the below operating subsidiaries in North Carolina as
designated by 15A NCAC 2H .0206, I hereby delegate authority to sign and certify all permit applications,
reports or other permit related documents to the staff listed below, for the following permit types (sewer, spray,
land application) and/or permit numbers.
NC Operating Subsidiaries:
• Carolina Water Service, Inc. of NC
• CWS Systems, Inc.
• Transylvania Utilities, Inc.
• Carolina Trace Utilities, Inc.
• Elk River Utilities, Inc.
• North Topsail Utilities, Inc.
• Carolina Pines Utilities, Inc.
• Bradfield Farms Water Company
• Nero Utility Service, Inc.
• River Pointe Utility Corp.
• Belvedere Utility Company
• Queens Harbor Utility, Inc.
Staff Authorized:
• Martin Lashua, NC Regional Director
• Tony Konsul, NC Regional Manager
• Danny Lassiter, NC Regional Manager
• Martin Scanlon, NC Project Manager
If you have any questions, please contact me at the following:
Permittee/Applicant name (please print): Carl Daniel
Title: Vice President Email: cddanieWuiwater.com
Complete mailing address: P.O. Box 240908
City
Charlotte State
NC Zip
28224-0908
Telephone number: ( 704 ) 525-7990 Facsimile number: ( 704 ) 525-8174
Signature
6/3/08
Date

11/2/2020 Mail - Bennett, Bradley - Outlook
RE: Permit Renewals - Bent Creek and Waterford Place
Wiggs, Linda <[e-mail]>
Tue 10/27/2020 12:09 PM
To: Bennett, Bradley <brad ley.bennett@ ncdenr.gov>
HI Bradley,
CWS (Bent Crk) does not need any special condition in their permit. You can send me the draft once you get it completed, but I do not need anything
added for that facility. Now I'll say that and then the public notice ...... nevermind I don't want to jinx us. Really that plant is operated very well and rarely
has violations.
As far as the decay, it is not terrible and not to a point of causing violations, however, it needed to be addressed in the inspection. Regardless, CWS has
that facility slated for a new plant in their CIP in 2022-23.
DIE
J14(a `ill ��
Environmental Senior SpecialistlDivision Water Resources
North Carolina Department of Eni-ironmental Quality
828-296-4500 (Office)
Linda.w1ggs�Cdenr. gov
# :tip# • # ! ! # ti ! ! �41 • ! # # 1 / + / �'� # !� !
/' !RIlr�'/ ► ! p
From: Bennett, Bradley
Sent: Monday, October 26, 2020 2:14 PM
To: Boss, Daniel J <[e-mail]>; Wiggs, Linda <[e-mail]>
Subject: Permit Renewals - Bent Creek and Waterford Place
Hey Guys,
Just wanted to touch base. I am starting to work on the draft permits for two more ARO permit renewals (listed below). The applications
should be in Laserfiche. Could you let me know if there are any comments you have about either of these as I am review them?
• NCO036684 - Bent Creek WWTP (Carolina Water Service, Inc.) - The October 2019 inspection noted ongoing concern with concrete
decay and indicated the ORC said they were considering a new WWTP? They didn't indicate anything in the application so I guess
they haven't looked at that any more. Just wanted to see if you were aware of anything else on this or have any concerns.
• NCO055905 - Waterford Place WWTP (Waterford Place POA) - Last inspection noted need to address potential clogging of distribution
lines. Just an FYI - in Laserfiche it looked like there were multiple copies of the inspection report and one file had multiple copies of
the report in the file?
Let me know if there are any things you want to discuss or you want me to consider in the drafts on these.
Thanks
BB
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
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11/2/2020 Mail - Bennett, Bradley - Outlook
[External] RE: Bent Creek WWTP - NCO036684
Tony Konsul <[e-mail]>
Mon 10/26/2020 4:32 PM
To: Bennett, Bradley <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to [e-mail]
It should be 5 Donnybrook Court.
From: Bennett, Bradley <[e-mail]>
Sent: Monday, October 26, 2020 4:26 PM
To: Tony Konsul <[e-mail]>
Subject: Bent Creek WWTP - NCO036684
CAUTION: This email originated from outside of the organization. Do not click links or open
attachments unless you recognize the sender and verify that the content is safe.
Tony,
I am working on the draft for the renewal of the Bent Creek WWTP permit. One thing I noticed is that
the application in 2015 indicated the facility address as 5 Donnybrook Ct and the permit was issued that
way. The application you just sent indicates 3 Donnybrook Ct. Could you verify which it should be?
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E10DhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/1