NC0089931_Fact Sheet with Info for Final App Return_20210114

DENR/DWQ
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO089931
2020 New Permit Application
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:
Wallace Loft, LLC The Cottage of Boone WWTP
Applicant Address:
2771 Centerville Road, Suite 400; Wilmington, DE 19808
Facility Address:
615 Fallview Lane, Boone, NC 28607
Facility Class/Permit Status:
Not Rated / New Application
Permitted Flow (as built)
0.108 MGD requested
Type of Waste
100% Domestic
Receiving Stream
Laurel Fork
Stream Class ID
C; Tr 8-10
River Basin
Watauga
Subbasin
04-03-02
HUC
060101030303
USGS Too
Boone, NC
7Q10 Sum Win cfs
0.44 0.64
30Q2 cfs
1.39
Avg. Stream Flow cfs
3.2
IWC %
26
County
Watauga
Regional Office
WSRO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / January 12, 2021
Does permit need daily max NH3 limits?
Seespeculative limits letter
Does permit need TRC limits/language?
Seespeculative limits letter
Does permit have toxicity testing?
Seespeculative limits letter
Does permit have Special Conditions?
If issued would require conjunctive use language
in this permit and in the non -discharge permit —
WQ0035784
Does permit have instream monitoring?
No
Stream on 303 d List? For w/parameter?
None other than statewide mercury listing
Any compliance concerns?
See compliance discussion below associated with
non -discharge permit
Any modifications since last permit?
New permit application
New expiration date:
L N/A
FACILITY OVERVIEW:
This facility is 100% domestic waste. The application notes that the system serves an apartment complex with
894 bedroom, five administrative/clubhouse employees, a fitness center and a pool. The design capacity of the
non -discharge irrigation treatment system as built is 0.108 MGD and consists of the following wastewater
treatment components:
• rotary brush screen and a 500 gallon filtrate collection tank served by two 0. 5 horsepower( hp)
centrifugal screening transfer pumps
• 54, 496 gallon bolted steel equalization basin with a coarse bubble diffuser system served by a 96 cubic
feet per minute ( CFM), 40 hp, positive displacement blower and two 4 hp submersible transfer pumps
• dual 12, 000 gallon anoxic bioreactor tanks served by two 3 hp centrifugal recycled activated sludge
RAS)/ mix pumps
• dual 12, 000 gallon aerated bioreactor tanks with a coarse bubble diffuser system served by a 96 CFM,
40 hp, positive displacement blower

• 12, 000 gallon postanoxic bioreactor tank; dual ultra -filtration ( UF) membrane filter racks served by
three 5 hp centrifugal circulation pumps, two 2 hp centrifugal membrane flush pumps, two 0.5 hp
centrifugal membrane permeate pumps, and two 3 hp centrifugal permeate backwash pumps ( all as
part of Dynatec Membrane Biological Reactor treatment system)
• dual 130 gallon per minute ( GPM) Severn Trent ultraviolet( UV) disinfection systems
• Hach turbidimeter and a 190 GPM effluent flow meter
• automatic- activation propane- fueled alternate power supply
• 548, 000 gallon bolted steel 5- day upset tank
• 36, 166 gallon bolted steel aerobic digestion sludge holding tank with coarse bubble diffuser and 2-
inch, 100 GPM sludge flow meter
• 12, 059 gallon HDPE irrigation dosing tank served by two 15 hp centrifugal dosing pumps
• 1, 562, 000 gallon bolted steel 14- day wet weather storage tank
• precipitation sensor
• three 1, 763 gallon precast return flush tanks served by two 48 GPM vertical turbine flush return pumps
• approx.. 14.39 acres of drip irrigation area with a mixed hardwood and pine forest cover crop with
sufficient disposal capacity in zones 1- 6 and all associated piping, valves, controls and appurtenances
Annlication Information and Review
The system is permitted under non -discharge permit WQ0037784. While the system is permitted at up to
108,530 MGD it has operated at a reported average flow of 36,000 GPD. This is one third of the design capacity
of the non -discharge permit. The permittee provided an Engineering Alternatives Analysis (EAA) that
evaluated 4 alternatives. An evaluation of the EAA was conducted and is included as part of this Fact Sheet.
This evaluation concluded that the EAA had not adequately established the need for the discharge because it
did not attempt to evaluate the operation and maintenance needs to allow the existing system to function as
designed as a non -discharge system.
Information included in the EAA claimed that the need for a discharge was due to weather conditions - rainfall
and snow and ice that had made the system unusable in winter months. The document outlined the permittee's
expenditures in 2019 and 2020 for pump and haul permits to handle overage for their system. However, the
EAA provided no soils or other technical information to show that the conditions were weather related issues.
The EAA did not address maintenance issues (see info below) that had led to unrepaired issues on one-third of
the available irrigation zones for months at a time. Permitting staff consulted with regional office staff and staff
in the non -discharge program and the consensus is that this permittee has a viable non -discharge permit and
with proper operation and maintenance of the system does not need a discharge permit. In accordance with
the statutes and rules a discharge permit is not allowable for this permittee.
Inspection Information
On July 10, 2020 the Winston-Salem Regional Office conducted an inspection of the facility and it's non -
discharge irrigation system. This inspection found multiple ongoing violations at the facility including
operation and maintenance concerns that has resulted in two of the six irrigation zones not being used at all for
months at the time (seven for one zone and fourteen for a second). A full third of the irrigation area for the
system has not been utilized for months at a time without repair.
COMPLIANCE:
This July 2020 inspection noted above resulted in a Notice of Violation (NOV) to the permittee under their non -
discharge permit. In addition, over the last three years the permittee has had four additional NOV's for permit
condition violations and one NOD for a permit limit violations. In 2019 the facility received an enforcement
action for permit condition violations and paid a penalty in the amount of $3,000. The facility also had two
reported By -Passes in 2020 and the regional office has just been made aware of a by-pass in January 2021.
The Cottages of Boone WWTP Fact Sheet
NPDES Renewal 2020 — January 12, 2021
Page 2

ACTIONS IN RESPONSE TO THE APPLICATION
After review of the EAA and other information permitting staff documented the review and met with
lead engineering staff in the NPDES Permitting Program (Dr. Sergei Chernikov) to review the findings
on August 28, 2020. Dr. Chernikov agreed with the review and conclusions that the EAA did not
appropriately consider the need to repair the non -discharge system and come into compliance with the
provisions of the existing permit. The EAA did not establish the necessity of the discharge and is not
acceptable.
September 22, 2020 - DWR staff held a conference call with the permittee's representatives and
consultants. Meeting notes are attached as part of this Fact Sheet. In this call DWR staff explain that our
statutes and rules require that requests for new discharges provide information to justify that discharge
is the best alternative. After review of the information provided, the Division explained that this
information had not been provided and the permittee currently had a non -discharge alternative that
provided appropriate design capacity to handle the generated flow without a discharge if the system
was operated and maintained properly.
October 01, 2020 - DWR staff met to discuss the conference call and next steps. There was agreement
that the permittee has not shown that their non -discharge system can not handle the generated flow.
The non -discharge permit has been in place since 2012 and there were no major issues until the
permitted started to have issues with ongoing maintenance. First pump and haul permit wasn't
requested until 2019 so the system operated for years without a need. What has changed? If
Information provided does not answer this issue. If there are issues that exist then they would also
need to work to modify their non -discharge permit. WSRO will continue to work with the permittee to
assure that the issues from the most recent NOV. The permittee has a non -discharge system approved
and design to handle flow well beyond their existing levels with the system maintained and operated
properly. Send letter stating our decisions as outlined in the September call and give them 60 days to
provide any additional information.
October 14, 2020 - The Division sent an Additional Information Request letter to the permittee
(emailed and verified received). Letter outlines our previous discussions and that a discharge permit
has not been justified. Notice give for 60 day response. Letter is included as part of this fact sheet.
December 10, 2020 - The permittee set up a conference call for discussion. Permittee and their
consultants met with central and regional office staff. The permittee sent a discussion document that is
included as part of this fact sheet. This document essentially just asked for a smaller discharge flow and
provided none of the information requested previously to justify the need for any discharge. Discussion
at the meeting was along the same lines as DWR staff reinforced the requirement that the permittee
provide information to show that the current system was not able to handle the flow. At the meeting it
was determined that the consultants would be in touch with Winston-Salem Regional Office staff
(Patrick Mitchell) and Non -Discharge staff (Nathaniel Thornburg) to determine the information they
needed to evaluate and provide for any further review.
December 14, 2020 - DWR staff conference call. Information from NDAR reports - Floating 12 month
application rates for the different zones show that Zone #4 and #5 have been well below the other
zones. For 2019-2020 these two zones were only used at around 35% of the level that the other zones
were used. DWR will wait for contact from staff with the Cottage of Boone. If there has been no
response by January 14, 2021 the application package will be returned as incomplete.
January 14, 2021- With no contact on this issue from the Cottage of Boone a letter is being sent
electronically to close our review of the application. Copy of letter included in fact sheet.
FINAL ACTION
• Application returned as incomplete
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett
at bradley.bennettOncdenr.gov or [phone].
The Cottages of Boone WWTP Fact Sheet
NPDES Renewal 2020 — January 12, 2021
Page 3

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Rose Hernandez (electronic submittal)
The Cottages of Boone
Wallace Loft, LLC
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Dear Ms. Hernandez:
NORTH CAROLINA
Environmental Quality
Subject: Return of Application
NPDES Permit Application - NCO089931
The Cottages of Boone WWTP
Watauga County
On December 10, 2020 Division staff had a conference call with you and your consultants
associated with your application for a discharge permit (received May 5, 2020). This conference
call was in response to our previous letter of October 14, 2020. The October letter, along with
previous discussions, outlined our determination that you have a viable non -discharge permit and
the discharge permit request could not be processed by our Division. This letter requested any
additional information that you may want to provide be submitted within 60 days in accordance
with 15A NCAC 2H .0107(b).
After our December conference call we understood that you would be in touch with Division
staff in the Winston-Salem Regional Office and the Non -Discharge permitting program to further
discuss issues and provide additional information based on those discussions. At this point,
however, our staff has not been contacted to discuss these issues and no further information has
been received. As such, your application does not contain adequate information to support the
issuance of a discharge permit. Specifically, an acceptable engineering alternatives analysis in
accordance with 15A NCAC 2H .0105(c) has not been received. The Division is therefore
returning your application as incomplete and no further review will be conducted.
D EQ
�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NOfiTH CAROL.INA �
oop—WdEn..a t.lousi� /'� 919.707.9000

Rose Hernandez
The Cottages of Boone Return
Page 2
If you have any questions or need additional information you should contact staff in the
Winston-Salem Regional Office or in our Non -Discharge Permitting Program.
Sincerely,
John Hennessey, Supervisor
Compliance and Expedited Permitting
cc: NPDES Files
Winston-Salem Regional Office / Water Quality — electronic
Nathaniel Thornburg / Non -Discharge Program — electronic

From Patrick Mitchell - WSRO
Cottages of Boone Talking Points
• They have been close to full on the wet weather storage a few times in past winters and they
have received two pump & haul permits since the system was first put into use in mid-2013.
• 1 do not doubt that they have run into storage issues during some extended weather events
times.
• At full design flow there is 14 days wet weather storage available.
• At 60,000 GPD flow there is approximately 25 days of wet weather storage available.
These numbers are assuming the storage structures were completely empty on day one —
which is not the standard for operating facilities. It is very rare to see a completely empty
storage structure at an operating facility during routine compliance inspections.
• They have been utilizing their 5-day upset storage structure for additional wet weather
storage. This increases the total storage to a total of 19 days at full design flow and 29 days
at 60,000 GPD.
• If average daily flows were 36,000 GPD as they indicated in the agenda for our most recent
call with them; that is 42 days wet weather storage, plus 14 days upset storge — for a total
storage capacity of 57 days (again, assuming the tanks were completely empty at day one).
During that call one of them indicated that they have data showing extended unsuitable
irrigation conditions, but I don't recall what timeframe was mentioned.
They have had chronic issues during the times when pump & haul was required with
maintaining their irrigation fields. They have a total of six irrigation fields. Field #5 was down for
a total of 14 months (not totally contiguous) in years 2018 and 2019, and Field #4 was down for
a total of 7 months (not totally contiguous) in that same timeframe. That means potentially up
to 1/3 or 4.44 acres of irrigation area was not available for use during some points.
- While it may be true that they were able to continue to dose during suitable weather and
site conditions, there is the potential for individual irrigation fields that were out of
operation to be suitable for irrigation at times when other fields were not (due to fields
having western aspect, some southern aspect, etc.; the differences in vegetation,
differences in soils, differences in slopes, etc. for each field).
If they had all fields operational for most of the time, it would be an easier sale that it is
weather and site conditions alone causing the shortage in storage. However, even with
100% of the fields available, there likely would be times when weather and conditions for
each individual field would be consistently unsuitable (e.g. frozen or wet conditions would
likely be the same overall but there could potentially be a day or two that some zones may
thaw and/or dry out faster than the others allowing irrigation).
Thus, not having all irrigation fields does potentially impact disposal at times and is an
agitating factor in having insufficient storage capacity. If daily influent flows were higher
close to maximum design flow, there would definitely be issues with storage or hydraulic
overloading of the other fields while some fields were out of operation.

From Patrick Mitchell - WSRO
I say all this to say...
1. If they provided a report on the data for the past four years or more for:
• weather data (temp. for highs and lows, precipitation amounts and types, other)
• wet weather storage structure & upset storage structure freeboard measurements,
• irrigation loading data to each field (including a note of zones or fields that were unavailable
for loading)
• average daily influent flows for each month (include note on peak flow volumes and extent)
and this data supports the claim for storage not being sufficient for this particular site,
2. and if they clearly demonstrate that adding additional storage structures is not reasonably
feasible,
3. and if they have taken actions to conserve and reduce influent flows to address storage issues,
4. and their request for an NPDES discharge permit was for a minimal amount. Just enough to
overcome anticipated wet -frozen winter weather conditions and to maintain maximum wet
weather storage coming into the winter months. Maybe something like a figure derived from
the maximum period demonstrated where irrigation is prohibited and calculate that average
daily flow spread throughout the year for the maximum daily discharge volume..
...then I could support an NPDES permit being issued for this facility.
However, asking for 100% daily conjunctive design flow for an existing ND system that clearly is not
failing and can handle flows the overwhelming majority of the time is not acceptable, IMO. Add in the
agitating factor of not properly maintaining the irrigation fields and not providing sufficient data to
support the request and it's a vote for returning their application as incomplete from me.

1 /14/2021
Mail - Bennett, Bradley - Outlook
Re: [External] Invitation: Additional Information - The Cottages of Boone - NCO089931 @ Thu
Dec 10, 2020 3:30pm - 4:30pm (EST) ([e-mail])
Rose Hernandez <[e-mail]>
Thu 12/10/2020 12:47 PM
To: Bennett, Bradley <[e-mail]>
Cc: Snider, Lon <[e-mail]>
1 attachments (74 KB)
Questions for DENR -Cottages of Boone WWTP (1).pdf;
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hey Bradley,
I wanted to send you over the agenda that our engineers have prepared for the call.
Talk to you soon.
Best,
On Tue, Dec 8, 2020 at 11:14 AM Rose Hernandez <rose.hernaInd [e-mail]> wrote:
Hey Bradley,
I just sent the invite over to you all!
Thank you,
On Mon, Dec 7, 2020 at 4:41 PM Bennett, Bradley <[e-mail]> wrote:
Rose,
Could you add the following to the invite? I'm not sure that I can forward this and it will work. I'm not
sure they will all be able to attend. Hopefully the meeting in Google Meet will work for us. I can try to
schedule a state dial in number also in case it doesn't work.
Please add:
John Hennessy [e-mail]
Nathaniel Thornburg [e-mail]
Jenny Graznak [e-mail]
Patrick Mitchell [e-mail]
Lon Snider [e-mail]
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
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1/14/2021 Mail - Bennett, Bradley - Outlook
From: rose. [e-mail] <[e-mail]>
Sent: Monday, December 7, 2020 3:43 PM
To: [e-mail] <derek.johnson cardinalgroup.com>; [e-mail]
<justin.pellegrino cardinalgroup.com>; Bennett, Bradley <[e-mail]>; [e-mail]
<[e-mail]>; pete@odomengineen g.com <pete odomengineen g.com>;
[e-mail] <davidodom@odomengineen g.com>
Subject: [External] Invitation: Additional Information - The Cottages of Boone - NCO089931 @ Thu Dec 10, 2020
3:30pm - 4:30pm (EST) ([e-mail])
When: Thursday, December 10, 2020 3:30 PM-4:30 PM.
Where:
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You have been invited to the following event.
Additional Information - The Cottages of Boone - NCO089931
When Thu Dec 10, 2020 3:30pm — 4:30pm Eastern Time - New York more details »
Joining info Join with Google Meet
meet.google.com/tmb-txum-tca
Join by phone
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Rosalia Hernandez-Chim I Community Manager
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1/14/2021 Mail - Bennett, Bradley - Outlook
615 Fallview Ln. I Boone, NC 28607
o.828.865.1800 1 [e-mail]
www.thecottagesofboone.com
Rosalia Hernandez-Chim I Community Manager
615 Fallview Ln. Boone, NC 28607
o.828.865.1800 [e-mail]
www.thecottagesofboone.com
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Cottages of Boone WWTP — Conjunctive use modification request
Background —
Cottages of Boone WWTP ((WQ0035784), permit is 108,000 gpd, average flow is approximately 36,000
gpd. Serves Cottages of Boone Student apartment complex composed of 894 bedrooms, fitness center,
pool and five employee office.
Treatment is membrane system with drip irrigation discharge. 1.6 million gal. open top stainless -steel
storage with 600,000-gallon backup. Effluent quality limits for the plant have been set at a high -quality
level to permit irrigation at close setbacks on the 14.39 permitted acres.
Issues are: constrained on the drip discharge by weather impacts - precipitation and freezing weather
conditions. During the past several winters, limitations on irrigation due to inclement weather resulted
in production of treated effluent exceeding holding capacity, requiring hauling of treated effluent to an
alternate (Boone) treatment plant, at great expense.
Odom Engineering was contracted to assist with an application of conjunctive use discharge to Laurel
Fork, a stream near the WWTP, to supplement irrigation and on -site storage capacity for treated
effluent.
In November of 2019, following contact and advice from Julie Grzyb, NPDES, a Low Flow request was
submitted to USGS. Ms. Grzyb received the low -flow report from USGS in Mid -November & noted that
the flows looks good & that her department had high backlog but would review the request.
A speculative effluent letter was received from NPDES January 10, 2020 (0.1 MGD).
NPDES Conjunctive Uses application, fee, EAA and LG sent to NPDES May 19, 2020.
EAA considered 4 alternatives:
1. Do nothing continue to pump and haul as necessary — Highest annual and PW costs.
2. Conjunctive use — Continue to Irrigate, discharge to Laurel Fork when necessary — Lowest annual
& PW Cost
3. Connect to Municipal System — High Capital and annual cost, not permitted by current
regulations (outside of City), no individual water metering at facility.
4. Increase wet weather Storage by 1 million Gals — High capital cost, still no guarantee of
sufficient capacity with weather impacts, no readily available site for tank on property. Site prep
would require extensive cut and retaining walls.
Questions:
1. Will the department consider approval of a minimal discharge flow, just enough to overcome
the necessity for hauling and disposal during extended periods of inclement weather?
If the department will consider this, we would like to see how they would like to proceed — is the
previous application still open & may we amend it?

3. We would like to see how we might resolve any questions the department may have regarding
operation and maintenance of the irrigation system and the impacts on irrigation due to
weather. The WWTP system irrigation volumes can be directly correlated to historic weather
data.
4. We would also like to ensure that the department is considering the high level of treatment
provided by the membrane system.

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Rose Hernandez (electronic submittal)
The Cottages of Boone
Wallace Loft, LLC
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Dear Ms. Hernandez:
NORTH CAROLINA
Environmental Quality
October 14, 2020
Subject: Additional Information Request
NPDES Permit Application - NCO089931
The Cottages of Boone WWTP
Watauga County
Thanks to you and others involved with this facility for taking the time to talk with us on
September 22nd about our concerns with your discharge permit application. During our call we
shared with you our findings from review of your NPDES permit application, Environmental
Alternatives Analysis (EAA) and recent compliance issues with your existing Non -discharge
system permit (WQ0035784). Our assessment from the information available is that the majority
of the issues with your treatment system are related to ongoing operation and maintenance issues
rather than weather related issues.
Your irrigation system has been designed and approved to function as a non -discharging system
at flow levels (over 108,000 GPD) well above the average and maximum flows that the system is
receiving. The system has functioned within these non -discharge parameters up until the last
year or so when multiple zones in the system have been unavailable for irrigation use for
extended periods of time. These zones being out of service have meant that upwards of one-
third of your irrigation area has been underutilized on an ongoing basis for the handling of
the wastewater you are producing.
The Cottages of Boone has a viable non -discharge alternative with your existing irrigation
system. As such, the Division cannot move forward with the issuance of a discharge permit for
your facility. If you have additional information that you would like to submit for the Division's
review on your discharge permit request, the Division would be happy to review any additional
information. In accordance with 15A NCAC 211.0107(b) please provide any additional
information to our office within 60 days of your receipt of this letter.
D EQ
�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center Raleigh, North Carolina 27699-1617
NOfiTH CAROL.INA �
oop—WdEn..a t.lousi� /'� 919.707.9000

Rose Hernandez
The Cottages at Boone
Page 2
You should also work with the Winston-Salem Regional Office to address issues noted in your
recent NOV and bring your non -discharge system into ongoing compliance. Any questions
related to those compliance issues should be addressed to Patrick Mitchell in the Winston-Salem
Office.
If you have any questions or need additional information, please do not hesitate to contact me.
At this time I am working out of the office so the best way to contact me is through email at
bradley.bennettgncdenr.gov. If needed, we can set up a time for a conference call through email.
Sincerely,
Docu Signed by:
EMF1774EA9435...
Bradley Bennett
Compliance and Expedited Permitting
cc: NPDES Files
Winston-Salem Regional Office / Water Quality — electronic
Nathaniel Thornburg / Non -Discharge Program — electronic
Steve Furst — Wallace Loft, LLC - electronic

EAA Evaluation —The Cottages of Boone
NCO089931 / WQ0035784
Background:
This EAA is associated with a new NPDES application for this facility. They currently have a WW Non -
Discharge Irrigation System permit. The Irrigation system is designed and permitted for 108,530 GPD
but the system operates at an average of 36,000 GPD. The system includes a 1,562,000 gallon storage
tank for wet weather storage. The system is built -out and no additional flow is anticipated.
The EAA indicates that in spite of the system over design they still have an overage of wastewater and
have recently had Pump and Haul permits to handle the excess. The EAA claims that the overage is due
to weather conditions, mainly in the wet periods of the winter with freezing temperatures, etc. EAA
claims 14 days of wet weather storage.
EAA reviewed 4 alternatives 1) Do Nothing and continue with pump and haul; 2) Conjunctive use permit
— maintain irrigation system permit and obtain NPDES permit for overage; 3) Connect to Sewer; and 4)
Increase onsite storage. Costs for each are shown below in a table from the EAA.
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Evaluation of Submittal:
Review of recent facility inspection and NOV and discussions with WSRO staff show that the facility has
had recent operational issues. The facility has six irrigation zones and 2 of these have not been
operational for 7 months and 14 months. The facility has not made needed repairs in a timely manner
recently. While weather may have some impact it does not address the larger issue of operation.
The EAA does not address the operational issues at all and does not address if the existing treatment
system can handle all the flow of operating at full capacity. There is no indication in the EAA that there
are soils issues or other functional issues impacting the system. No effort is made to assess the costs of
bringing the system up to permit requirements.
The numbers in the EAA are most likely in line with the discussed alternatives, but they are not the main
issue. The EAA does not seem complete since it does not address the larger issue of the system
operation and maintenance keeping it from functioning as a complete non -discharge system. WSRO
staff and Non -discharge staff feel that the system can function to handle the full load. The EAA claims a
wet storage capacity of 14 days but that is for the full permitted 108,000 gallon flow. At their average
flow of 36,000 GPD they would have over 43 days of storage. This storage plus operation and
maintenance to get all six irrigation zones working should be sufficient to allow irrigation in a manner to
have most, if not all of the storage capacity available for the wet season.
One additional concern is that their speculative limits and application request flow at up to 100,000
GPD. Given their compliance with the existing system it seems their intent may be to back entirely into
a discharge situation.

12/8/2020 Mail - Bennett, Bradley - Outlook
RE: Calculation Help for Cottages of Boone
Thornburg, Nathaniel <[e-mail]>
Wed 9/23/2020 3:00 PM
To: Bennett, Bradley <[e-mail]>
Cc: Mitchell, Patrick <[e-mail]>
Bradley,
You are correct on your math for Zone 5. At half capacity, that one zone could handle over twice the p&h overage.
Nathaniel D. Thornburg
Branch Chief
Non -Discharge Branch
Department of Environmental Quality
919 707 3653 office
[e-mail]
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <brad ley. bennett@ ncdenr.gov>
Sent: Wednesday, September 23, 2020 11:36 AM
To: Thornburg, Nathaniel<[e-mail]>
Cc: Mitchell, Patrick <Patrick.Mitchel [e-mail]>
Subject: Calculation Help for Cottages of Boone
Hey Nathaniel,
Just wanted to touch base with you and make sure I'm not too far off base on something. I was just looking at
the Irrigation Permit limits for this one. I'm sure that I am over simplifying things but I wanted to look at an
estimate of wastewater flow that the one zone they had down for 14 months could be expected to handle in a
year. It is Zone 5 and it is 1.72 acres. The permit says they have a yearly maximum application rate of 101.4
inches. I'm not sure if it is reasonable to expect that they would hit this max or not so I just assumed 50% or
51 inches.
51 inches applied over the 1.72 acre zone is 87.72 ac-inches
27,154 gallons in an acre -inch so, equals - 2,381,948.88 gallons
In their EAA they estimate 1,000,000 gallons annually to pump and haul so that is their "overage."
So even at half the yearly spray capacity this zone would be able to handle more than 2 times their claimed
overage.
They have a wet weather storage tank with 1,562,000 gallons capacity.
If they managed things appropriately it seems they would have more than enough storage.
Please drag me back to reality if this is off base (wouldn't surprise me if it is, been a long time since I was an
engineer).
Thanks
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12/8/2020
(&V
Mail - Bennett, Bradley - Outlook
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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12/8/2020
Mail - Bennett, Bradley - Outlook
RE: 9:00 Teams Meeting Cancelled - Cottages of Boone
Mitchell, Patrick <[e-mail]>
Wed 9/23/2020 8:58 AM
To: Bennett, Bradley <[e-mail]>; Graznak, Jenny <[e-mail]>; Snider, Lon
<[e-mail]>; Thornburg, Nathaniel<[e-mail]>; Hennessy, John <[e-mail]>
I wanted to throw a few thoughts out from the phone call yesterday (before I forget).
I wanted to expand on Bob Barr's clarification and also what one of the other representatives said related to the
irrigation zones not being maintained having nothing to do with impacts on storage issues. There are a total of 16
subzones out there as they indicated. These subzones make up the six irrigation zones that the system doses. This
system was designed and installed to operate by dosing 6 zones and cannot dose individual subzones
independently of each other.
Bob is correct, the system automatically rotates through each of the six irrigation zones (from zone #1 through
zone #6) as it completes a dose to each individual zone. What he is leaving out is that each day for each zone
that is skipped over is an opportunity for an additional volume of wastewater disposal missed. A simplistic way
of viewing this (not the correct math) is to assume each of the six irrigation zones is equal in size and the soils all
have the same hydraulic loading rate.. when one of those zones is down it would equal 18,000 GPD that is not
dosed. If two zones are down (as their records indicate at times), that's 36,000 GPD of disposal that is skipped
over by the system. Again, I would have to dig into the original application package for the Engineers
calculations for the exact volumes, but this gives some idea on the potential impacts of not maintaining all the
irrigation zones so the system can dose at 100%.
One of the representatives for the Cottages indicated that they have had to pump & haul every year. However, we
have only issued two pump & haul permits since this facility was placed into operation. It just so happens that
those two pump & haul permits were issued during two extremely wet years while they also failed to maintain
the irrigation zones. Would having all the irrigation zones up and running of made all the difference, who knows.
It certainly would have helped the situation and would have made for a stronger case for them if they had issues
while operating at 100% design.
I understand that freezing temperatures and extreme weather have impacts on this system at times. I have
reviewed their weather records and NDAR reporting forms during inspections, and their data at times suggests
there have been occasions with extended periods where irrigation could not occur. Nathaniel hit the nail on the
head with one of the major issues being lack of storage. Storage was a concern during the initial permitting for
this facility, but the design Engineer made a strong argument for his design meeting the minimum criteria in
regulations and it was permitted.
I still think their negligence to maintain all the irrigation zones has exacerbated this issue. However, with daily
flows that range 40 — 60% of the design capacity, one would think they could still limp by with 50 — 75% or
greater of the irrigation zones operating at any given time. Maybe that is what Bob Barr was referring to when
he said they are still irrigating and shouldn't have storage issues? To me this means that if they do not (or
cannot) address the additional storage needs for those occasions when extreme weather impacts irrigation
operations, they will continue to have occasions where they will have to pump & haul to prevent illegal
discharge to surface waters.
4. Lastly, if they had requested a smaller daily flow for the NPDES discharge permit, it would be more believable that
it is intended for a backup to the irrigation system. If they were able to discharge wastewater at 20,000 GPD to
30,000 GPD every day that it rained, snowed or temperatures were below freezing throughout the year, and they
maintained as much available storage as possible in their storage structures... wouldn't that be enough to prevent
pump & haul events? Seems like that may have been a more realistic request than for the full design flow.
Patrick L. Mitchell, REHS, LSS
Soil Scientist
Water Quality Regional Operations Section
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12/8/2020
Mail - Bennett, Bradley - Outlook
Division of Water Resources
NC Department of Environmental Quality
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
= ' Nothtng Compares v-
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, September 23, 2020 8:01 AM
To: Graznak, Jenny <[e-mail]>; Snider, Lon <[e-mail]>; Mitchell, Patrick
<Patrick.Mitchel [e-mail]>; Thornburg, Nathaniel <[e-mail]>
Subject: 9:00 Teams Meeting Cancelled - Cottages of Boone
Hey Guys,
Just making sure you got the calendar message that we had to cancel this meeting today.
Looking at schedules it looks like we might be into late next week before everyone is available again, but
maybe we can meet if we can find a spot where most are available.
0
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
Email correspondence to and from this address may be subject to public records laws
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The Cottages of Boone — NC0089931 New Application
Conference Call with Permittee Reps
September 22, 2020
Attendees: Lon Snyder, Jenny Grasnak, Patrick Mitchell — DWR WSRO
John Hennessey, Nathaniel Thornburg, Bradley Bennett — DWR CO
Rose Hernandez, Steve Perst(sp), Derick Johnson, Bob Barr, Dave Odom
• BB — introduced our staff and asked them to do the same. Rose introduced their direct staff but no mention
of the consultants online, I had to mention them.
• Steve asked Rose to give intro
Steve — Noted the permit request in house to discharge some flow. Indicated the reason for the request was
weather conditions, slope, etc. In winter they have inordinate costs due to pump and haul needs due to
water that can't be irrigated due to requirements. Net effect is 10's of 100's of thousands of dollars spent on
P&H. Wet, cold, freezing conditions, also more students recently since all are staying in their apartments due
to Covid. Need additional water taken away through discharge permit. Want efficiency for environment and
for them. Hopes to partner with DWR to provide more information to support a different solution. Current
approach unsustainable.
BB — outlined DWR concerns. According to our statutes and rules new permits and expansions have to
provide information to justify the need for a discharge permit as the best alternative. Division has reviewed
the permit application and EAA. Also looked at recent inspection report and NOV along with existing
irrigation system permit. The current WQ permit is designed for over 108,000 GPD and should be able to
handle that with no discharge. Currently the system averages (info in application) around 36,000 GPD so only
1/3 of the design capacity. Inspection and NOV indicate operation and maintenance issues that are ongoing
and have led to multiple zones being unavailable for extended periods. The EAA did not address the issue of
bringing the current irrigation system into compliance to handle the wastewater load, just assumed that
weather was the only factor. With the design of the system, the loads produced, etc. it appears that the
system should be able to handle the flow with the non -discharge system. The Division doesn't feel that there
is sufficient information justifying the discharge permit and would have a hard time supporting the permit
issuance.
• Lon — realize the P&H is expensive but also know that some zones are in disrepair and are not being utilized.
• Patrick — When all areas are not available or disposal this creates issues with storage in the system. Noted
that timely repair of the system was important and that all zones need to be maintained.
• Bob —The system has 16 subzones within the six major zones. Go zone to zone. When one is down for
repairs it maybe hard to get to in the winter. Irrigate zone to zone so when one is down they just move onto
the next one and don't miss irrigating. Recently have been filling storage as they now have 65-70K per day.
Had all zones running but now another one is down. May fix it and then another goes down again. Winter
have issues because the side of the mountain doesn't get sun, etc. Currently have 11 ft of storage available.
• Steve — So even with zones going down they are still irrigating, etc. Still think that they will have issues. Want
to agree that zones aren't an issue. Feels they are in for an expensive winter, spent over 100K last year under
normal conditions. Issue isn't irrigation zones, it is a base line issue of too much flow.
• Lon — noted that their inspections showed at least one zone down for over a year. Patrick noted zone 5 down
for 14 months over a 24 month span and that this is not a common thing for systems of this type. Understand
weather can be an issue, but system is designed the conditions and should be able to handle.
• Rose — Understand the red flags we see, but this year they tried not to pump and haul but had 24 days below
freezing and ended up with 733,000 gallon to pump and haul.
• Steve — indicated they needed to do a little math to assess where they are at but doesn't think one zone being
down addresses. Thinks the math is trivial given the amount of water being used and doesn't think zones are
the gating value.
• Jenny — noted the application request had the same flow rate as the existing irrigation system. Seems like a
lot of flow with a current system already in place. Concern that this isn't really a backup request, why not
request less?

• Response (?) — need to have somewhere to go when they can't irrigate. Intention is as a backup.
• Nathaniel — Irrigation disposal system capable of handling 108,000 GPD but having trouble with smaller flows?
• Permittee (?) indicated they were seeing flows now of 60-70,000 GPD now.
• Nathaniel — From non -discharge perspective sounds like storage may be an issue, have they looked at
storage? Also have they considered low flow fixtures?
• Steve — Additional storage was considered and costly (buy land etc.). Will consider low flow but feel that the
cost and other concerns may not be realistic.
• BB — asked about the 60-70K numbers and if they had just started. Steve indicated that flows were cyclical in
nature, etc. (seemed that there were examples over the last year but data doesn't show that)
• John — Sounds like a number of things could be done to make this system functional. Difficult to see how they
can justify a discharge permit. Noted federal and state requirements to try and eliminate discharges and that
the law is clear. All discussions with staff indicated to him that it would be hard to justify for this facility.
• Steve — Seems that all other alternatives are out of line financially. Doesn't seem realistic that they would
have to buy land to put in another storage tank. Not prudent. Are there any considerations for financial
issues, can they approach with additional data?
• John — We do look at cost in the process and will consider. The system already has an approved non -
discharge system that went through the process. Seems that O&M is a major issue. Understand the Covid
issues but these are not long term concerns.
• Derick — Noted that it would be hard to find additional land and reemphasized the weather issues. Noted that
in Jan and Feb 2020 there were 24 and 20 days below freezing and could have upwards of 60 days that they
could not irrigate.
• John — Willing to look at other information with an open mind. Concern that weather has always been the
same with the system yet it functioned before but doesn't handle the flow now?
• Steve — Appreciates issues relayed and will send additional information. Change in leadership has made these
issues more of a concern to them. Again noted he didn't feel that the issues were related to O&M and that
expenses were unnecessary from their perspective.
• BB — Checked in to make sure all aware of where we are, also noted again that the design at 108K and O&M
should not be discounted in their review.
• Steve — Noted that 108K is related to being able to irrigate. Will send additional information.
Page 2

Compliance Inspection Report
Permit: WQ0035784 Effective: 10/25/17 Expiration: 04/30/22 Owner: Wallace Loft LLC
SOC: Effective: Expiration: Facility: The Cottages of Boone WWTP
County: Watauga 1002 Fallview Ln
Region: Winston-Salem
Boone NC 28607
Contact Person: Sean Devine Title: Manager Phone: [phone]
Directions to Facility:
Take 140 BUS W/US-158 W/US-421 N from N Lierty Street. Follow 421 N to E King Street in Boone. Take US 221 S and NC 105 S to
Boone Circle
System Classifications: SI, WW2,
Primary ORC: Danny D Holman Certification: 1003141 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/16/2002 Entry Time 10:OOAM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Justin L Henderson
Reason for Inspection: Follow-up
Permit Inspection Type: Wastewater Irrigation
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Exit Time: 12:30PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 4

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 10/16/2002 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
On October 16, 2020, WSRO staff conducted an announced follow-up inspection of the subject facility. This inspection
focused on a review of the violations, deficiencies and items of concern noted in the recent NOV letter dated 7/28/2020 and
was not conducted as a comprehensive compliance evaluation inspection. Accompanying staff on the follow-up inspection
was Mr. Dale Holman (ORC), Mr. Bob Barr (Backup ORC), and Mr. David Smith (Maintenance). The majority of the
non -compliant issues noted in the NOV were found to be properly addressed at the time of inspection. Below is a summary
of notes from each item noted in the subject NOV.
VIOLATION ITEMS
1. Two valves leaking on the Membrane Bioreactor ('AV-1017A' and 'AV-1017B'):
BOTH VALVES WERE FOUND TO BE REPAIRED WITH NO LEAKS AT TIME OF INSPECTION.
2. Valve leaking on the outlet pipe of the EQ tank:
VALVE APPEARED TO HAVE BEEN REPAIRED, BUT VERY MINOR DRIP WAS OBSERVED TO BE DRIPPING INTO
THE GRAVEL AT TIME OF INSPECTION. IT WAS UNCLEAR IF THIS WAS RESULTING FROM LEAKAGE OR
CONDENSATION. REQUESTED REPRESENTATIVES MONITOR THE DRIP AND MAKE NECESSARY REPAIRS.
*FOLLOW-UP NEEDED.
3. 100% of Irrigation zones not operational with access to utilize all six zones:
THE COMPUTER DOSING SYSTEM INDICATED THATALL SIX IRRIGATION ZONES WERE OPERATIONALAT THE TIME
OF INSPECTION. IT WAS INDICATED THAT A CONTRACT REPAIR COMPANY HAD RECENTLY VISITED THE SYSTEM
AND MADE NECESSARY REPAIRS TO ALLOW DOSE TO ALL SIX ZONES. IT SHOULD BE NOTED THAT WHILE
OPERATIONAL, ZONE #3 WAS LISTED WITH A HIGH FLOW WARNING MEANING MINOR HOLES OR LEAKS ARE
PRESENT IN THE IRRIGATION ZONE. THIS ZONE NEEDS TO BE INSPECTED AND REPAIRED WHERE NECESSARY
TO MAINTAIN AS OPERATIONAL. IRRIGATION SYSTEM NOT REVIEWED IN OPERATION DUE TO RAINFALL AT TIME
OF INSPECTION. *FOLLOW-UP REVIEW IN OPERATION IS NEEDED.
THIS ITEM REMAINS A CONCERN DUE TO THE PROVIDED WRITTEN RESPONSE TO NOV (i.e. "We do not have the
personnel on hand to make these repairs..."). *FOLLOW-UP NEEDED.
DEFICIENCIES
A. Recirculating pump (Return Activated Sludge Pump) next to Bioreactor T-7400B not operational at the time of the
inspection:
A NEW PUMP WAS FOUND TO BE INSTALLED AND OPREATIONALAT TIME OF INSPECTION.
B. Sulzer pump 'B' (nearest the back of the WWTP building) out of operation:
A NEW PUMP WAS FOUND TO BE INSTALLED AND OPREATIONALAT TIME OF INSPECTION. IT SHOULD BE NOTED
THAT ONE OF THE OTHER SULZER PUMPS (ONE CLOSEST TO WWTP BLDG DOOR) WAS BEING REPLACED AT
TIME OF INSPECTION.
C. The alarm test feature serving the highwater alarm on the irrigation dose tank not working:
A NEW ALARM HAS BEEN INSTALLED. TEST FEATURE DID NOT FUNCTION BUT THE FLOATS WERE TESTED AND
FOUND TO OPERATE PROPERLY.
D. Soil sampling results were not available for review at the time of the inspection:
RESULTS RECEIVED VIA EMAIL FOLLOWING INSPECTION. IT WAS INDICATED THAT RESULTS WILL BE AVAILABLE
ONSITE DURING FUTURE INSPECTIONS.
E. The soil sampling results for year 2020 did not report results for the following required parameters: Base Saturation,
Percent Humic Matter, and Acidity:
SOILS ARE BEING SAMPLE AGAIN FOR 2020 TO OBTAIN COMPLETE RESULTS.
Page 2 of 4

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 10/16/2002 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Exchangeable Sodium Percentages (ESP) reported in the 2020 results are inconsistent:
AGAIN, SOILS ARE BEING SAMPLED AGAIN FOR 2020, THIS WILL BE USED TO EVALUATE ESP. DISCUSSED
PROPER SAMPLING TECHNIQUE AND DEPTH DURING INSPECTION, ALSO REFERRED TO NCDA SOIL SAMPLING
GUIDANCE DOCUMENT ON THEIR WEBSITE.
F. Onsite representative indicated that "very minor" leaks were present on the wet weather storage tank and the upset
storage tank when the tanks were nearly full of effluent:
NO LEAKS OBSERVED AT TIME OF INSPECTION. REQUESTED TO CONTINUE MONITORING AND REPAIR AS
NEEDED.
G. Stormwater runoff and erosion above the two storage tanks has not been properly addressed:
THIS HAD NOT BEEN PROPERLY ADDRESSED AT TIME OF INSPECTION.
OTHER NOTES:
• Freeboard at time of inspection — Wet weather storage tank: 10.5 ft. available storage (i.e. 17' reading on gauge), and 22.5
ft. available storage (i.e. 6' reading on gauge).
• Reviewed public access restrictions behind the residences. No evidence of walk paths accessing the wastewater irrigation
areas. Recommended adding signs in two areas neat small grinder pump lift stations #9 - #13. These two areas are
relatively flat with open woodline for easy access.
• Reminded drip calibration is due by 4/30/2022. Discussed two methods for doing calibration and the required
documentation from the calibration.
• Reminded that the Winston-Salem office would like to conduct a split sample event for the November 2020 sample event.
• At time of inspection WWTP effluent parameters reported as: DO= 3.6, pH= 6.0, Turbidity= 0.10.
Page 3 of 4

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 10/16/2002 Inspection Type: Compliance Evaluation
Reason for Visit: Follow-up
Type
Yes No NA NE
Recycle/Reuse
❑
Lagoon Spray, LR
❑
Activated Sludge Spray, LR
❑
Activated Sludge Spray, HR
❑
Single Family Spray, LR
❑
Infiltration System
❑
Reuse (Quality)
❑
Single Family Drip
❑
Activated Sludge Drip, LR
Page 4 of 4

DocuSign Envelope ID: 4E14519F-3229-409E-8604-138C6EF80E04
T ��wi4
G }-
ROY COOPER
Governor
f
`•�
MICHAEL S. REGAN
{%�°,,•
Secretary
S. DANIEL SMITH
NORTH CAROLINA
Director
Environmental Quality
October 19, 2020
Mr. Sean Devine
Wallace Loft, LLC — The Cottages of Boone
4100 E. Mississippi Ave., Floor 15
Denver, CO 80246
Subject: Follow -Up Compliance Inspection
The Cottages of Boone — Wastewater Irrigation System
Permit No. WQ0035784
Watauga County
Dear Mr. Devine:
On October 16, 2020, the Division of Water Resources Winston-Salem Regional Office (Division)
conducted an announced follow-up inspection of the subject wastewater irrigation system. The
primary purpose for this inspection was to follow-up on items listed in the Notice of Violation
letter (NOV) dated July 28, 2020. The items listed below from the subject NOV appear to have
been properly addressed. However, some items warrant continued action.
1. Minor leaks on two of the valves serving the Membrane Bioreactors. Both valves were
found to have been repaired. No leaks were observed from the subject valves at the time of
the inspection.
2. All six irritation zones not being maintained and consistently operational. All six
irrigation zones were found to be operational at the time of the inspection. Reportedly a
contract repair company recently made repairs necessary. It should be noted that irrigation
zone #3 did have a high flow warning present at the time of inspection but was reported as
operational. Please inspect zone #3 and make repairs necessary to maintain operations.
This item remains a concern for the Division and requires continued follow-up. The
written response dated August 7, 2020, provided to the Division indicated that "We do not
have the personnel on hand to make these repairs..."
3. Minor leak from valve on the outlet pipe of the Equalization Tank. Evidence of repair
work to the valve was observed. However, a very minor drip persists. Please monitor this
valve and make repairs necessary to prevent bypasses from occurring.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

DocuSign Envelope ID: 4E14519F-3229-409E-8604-138C6EF80E04
A. Recirculating pump (Return Activated Sludge Pump) out of operation. A new
replacement pump was found to be installed and operational.
B. Sulzer Pump `B' out of operation. A new replacement pump was found to be installed
and operational. One of the other Sulzer pumps was being replaced at the time of
inspection.
C. Alarm test feature serving the highwater alarm on the irrigation dose tank did not
function. A new alarm was found to be installed. The alarm floats are operating properly,
but the test feature did not operate properly.
D. Soil sampling results for the year 2020 did not report all required parameters. It was
indicated that soils will be sampled again in 2020 in effort to sample for all parameters.
E. Minor leaks on the wet weather storage tank and the upset storage tank when the
tanks are nearly full. No leaks were observed at the time of the inspection. Please make
necessary repairs to the storage tanks to prevent potential bypasses from occurring.
F. Stormwater runoff and erosion upslope of the two storage tanks. This condition
continues to persist and has not been properly addressed. Please take the actions necessary
to properly address the erosion and runoff issues upslope of the storage tanks.
The Division would like to thank you for the corrective actions that have taken place and for the
proposed actions to address the items described above. Please be advised that repeat non-
compliance items may result in enforcement actions, including civil penalties.
Please refer to the enclosed compliance inspection report for additional observations and
comments. If you have any questions regarding this letter, please contact Patrick Mitchell or me
at the letterhead address or phone number, or by email at patrick.mitchell(c�r�,ncdenr.gov or
Ion. snidergncdenr. gov.
Sincerely,
DocuSigned by: I
L23D2MCURB7456ti .uV...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
enc: Compliance Inspection Report
cc: Brittany Winter, Portfolio Manager (Electronic: brittany.winter&cardinalgroup.com)
Rose Hernandez (Electronic: rose. hernandezkthecottapesofboone.com)
David Smith (Electronic: david.smith(kthecottagesofboone.com)
Dale Holman, ORC (Electronic: daleholmangrocketmail.com)
Bob Barr, Backup ORC (Electronic: rbarr(krpbsystems.com)
Watauga County Environmental Health (Electronic)
DWR Laserfiche File WQ0035784, WSRO Electronic Files
Page 2 of 2

Compliance Inspection Report
Permit: WQ0035784 Effective: 10/25/17 Expiration: 04/30/22 Owner: Wallace Loft LLC
SOC: Effective: Expiration: Facility: The Cottages of Boone WWTP
County: Watauga 1002 Fallview Ln
Region: Winston-Salem
Boone NC 28607
Contact Person: Sean Devine Title: Manager Phone: [phone]
Directions to Facility:
Take 140 BUS W/US-158 W/US-421 N from N Lierty Street. Follow 421 N to E King Street in Boone. Take US 221 S and NC 105 S to
Boone Circle
System Classifications: SI, WW2,
Primary ORC: Danny D Holman Certification: 1003141 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 07/17/2020 Entry Time 09:30AM Exit Time: 01:OOPM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Caitlin Caudle
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions
Treatment Flow Measurement -Water Treatment Treatment Barscreen
Use Records
Treatment Filters Record Keeping Treatment Activated Sludge
Treatment Sludge Storage/Treatment End Use -Irrigation Treatment Disinfection
Treatment Flow Measurement Treatment Return pumps Storage
Standby Power Wells
(See attachment summary)
Page 1 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On July 17, 2020, WSRO staff conducted an announced inspection of the subject facility. It should be noted that the
originally scheduled inspection date (7/10/2020) was postponed the day before inspection after being scheduled over one
week in advance. Mr. Dale Holman (ORC) accompanied staff on the inspection. An in -office review of self -monitoring reports
for the period of January 2018 through April 2020 was also conducted as part of this inspection. The inspection found the
subject facility to be noncompliant with the permit. Violations, deficiencies, concerns and other items noted during the
inspection are listed below.
VIOLATIONS
1. Two valves serving the Membrane Bioreactor were found to have minor leaks present. One at `AV-1017A' and one at
`AV-101713'. It should be noted that one of the same valves was found to be leaking during the last inspection. Wastewater
leaking from the valves enters drains that reportedly distribute wastewater back to the head of the WWTP.
2. A minor leak from a valve on the outlet pipe of the EQ tank was observed. The wastewater is leaking onto the graveled
area outside the WWTP building and infiltrating into the ground. Thus, causing a minor bypass to occur for the system.
3. Review of self -monitoring and reporting data shows that irrigation zones have not been repaired in a timely manner. Two of
the six zones (i.e. Zones #4 and #5) were not utilized for extended periods during the subject review period and two others
(i.e. Zones #3 & #6) were not utilized for up to a one month period each, with limited monthly irrigation being reported
intermittently on most zones for the review period.
Zone #4 was reported with no irrigation for a total of 7 months and Zone #5 was reported with no irrigation for total of 14
months for years 2018 and 2019. Zone #5 has been reported with two months of limited irrigation and one month with no
irrigation through April 2020. Issues with zones being out of operation for extended periods was also noted during the
previous inspection.
Failure to repair the zones and have access to irrigate all six zones most likely contributed to freeboard issues that the
facility reported for the subject review period. Notices were issued previously to address the freeboard violations noted durinc
the review period.
DEFICIENCIES
A. One of the recirculating pumps (Return Activated Sludge Pump) next to Bioreactor T-7400B was not operational at the
time of the inspection. It should be noted that a new replacement pump was found to be present and is to be installed
ASAP.
B. One of the Sulzer pumps (`Sulzer Pump B') nearest the back of the WWTP building was out of operation at the time of
the inspection due to a major leak. It was indicated that this pump will be repaired ASAP.
C. The alarm test feature serving the highwater alarm on the irrigation dose tank located inside the WWTP building did not
work at the time of inspection. Needs to be repaired and ensure alarm floats work properly. *FOLLOW-UP TO TEST
FLOATS AND TO ENSURE THE TEST FEATURE IS REPAIRED.
D. The soil sampling results for year 2020 did not report results for the following required parameters: Base Saturation,
Percent Humic Matter, and Acidity. Request the missing parameters be provided if possible.
Exchangeable Sodium Percentages reported in the 2020 results are inconsistent compared to 2017, 2018 and 2019 results.
Furthermore, the results reported for the parameters in 2020 soils analyses were in unit of lbs./acre. To evaluate these
results, the values have to be converted into index values or into mg/L. Request that soil sampling results be reported as an
index value or in mg/L in the future.
Page 2 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
E. Onsite representative indicated that "very minor" leaks were present on the wet weather storage tank and the upset
storage tank when the tanks were nearly full of effluent. No leaks were observed at the time of the inspection. However, at
the time of inspection there was only approx. 6 and 6.5 ft. of effluent present in each tank. Reportedly repairs will be
scheduled soon.
F. Stormwater runoff and erosion above the two storage tanks has not been properly addressed. Evidence of stormwater and
saturation/ponding around the foundations of both aboveground tanks was observed. The erosion and the saturation could
cause issues with foundation integrity of one or both storage tanks if not properly addressed.
OTHER NOTES or REMINDERS
• The irrigation zones could not be tested during the inspection. The dosing tank was nearly empty. The ORC indicated that
the system had just dosed. Irrigation zones #5 and/or #6 were requested to be dosed, but there was not enough effluent
present in the dose tank. Effluent was refilling the tank at the time (i.e. near end of the inspection). *FOLLOW-UP IS
NECESSARY TO ENSURE ALL IRRIGATION ZONES ARE FULLY OPERATIONAL.
• Drip system calibration has not been completed yet. Reminded representative that calibration is due by April 30, 2022.
• Soil sampling results were not available for review at the time of the inspection. Results were received via email
immediately following the inspection. Reminded representative that soils results should be maintained and available for
review during future inspections.
• The soil sampling results for years 2018, 2019 & 2020 received following the inspection were reviewed. The Exchangeable
Sodium Percentage was reported as elevated (as high as 13.0 for zone #6) for some zones in the subject review period.
Remind ORC to take care when sampling soils to (be sure to use proper sampling technique, sampling depth, etc.) to
ensure a representative sample is collected for analyses. Soils should be resampled to verify if levels are elevated. Additiona
effluent parameters sampling may be necessary to evaluate the Sodium Adsorption Ratio in the effluent Elevated sodium in
soils can impact infiltration rates of soils and cause runoff and potential discharges to surface waters.
• Exchangeable Sodium Percentages reported in the 2020 results are inconsistent compared to 2017, 2018 and 2019
results. Check soil sampling procedures to ensure representative results are obtained.
• There is some question as to public access restrictions and measures in place. Remind Permittee that public access to
the irrigation system is to be restricted.
• Irrigation Pumps A & B were tested for only a brief period due to lack of effluent in the dosing tank, and both appear to be
operational.
• Reportedly a drip system repair contractor made repairs to the system just prior to the date of the inspection. Multiple
solenoids were replaced on the drip zones and one 2-inch supply line pipe was repaired that feeds irrigation Zone #5.
• Activated sludge QA/QC testing at time of inspection: TSS = 89 — 92 ppm, pH = 6.89, & DO = 0.33.
• Requested notification prior to November 2020 sampling events to allow opportunity for split sample events on effluent and
groundwater sampling.
• The brush screen had excessive debris present at the time of inspection. ORC indicated it is cleaned daily and will be
cleaned following the inspection.
*FOLLOW-UP INSPECTION REQUIRED.
Page 3 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Single Family Drip
❑
Recycle/Reuse
❑
Single Family Spray, LR
❑
Activated Sludge Spray, HR
❑
Infiltration System
❑
Activated Sludge Spray, LR
❑
Lagoon Spray, LR
❑
Activated Sludge Drip, LR
Reuse (Quality)
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ ❑ ❑
Do all treatment units appear to be operational? (if no, note below.) ❑ 0 ❑ ❑
Comment: See summary.
Treatment Flow Measurement -Influent
Yes No NA NE
Is flowmeter calibrated annually? ❑ ❑ ❑
Is flowmeter operating properly? ❑ ❑ ❑
Does flowmeter monitor continuously? ❑ ❑ ❑
Does flowmeter record flow? ❑ ❑ ❑
Does flowmeter appear to monitor accurately? ❑ ❑ 0 ❑
Comment: No influent meter, effluent meter located after disinfection, prior to storage tanks.
Treatment Flow Measurement -Water Use Records Yes No NA NE
Is water use metered? ❑ ❑ ❑
Are the daily average values properly calculated? ❑ ❑ 0 ❑
Comment:
Treatment Flow Measurement -Effluent
Yes No NA NE
Is flowmeter calibrated annually?
❑ ❑ ❑
Is flowmeter operating properly?
❑ ❑ ❑
Does flowmeter monitor continuously?
❑ ❑ ❑
Does flowmeter record flow?
❑
❑ ❑
Does flowmeter appear to monitor accurately?
❑ ❑ ❑
Comment: See summa
Standby Power Yes No NA NE
Is automatically activated standby power available? 0 ❑ ❑ ❑
Page 4 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is generator tested weekly by interrupting primary power source? 0 ❑ ❑ ❑
Is generator operable? 0 ❑ ❑ ❑
Does generator have adequate fuel? 0 ❑ ❑ ❑
Comment: Tested, runs.
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? ❑ 0 ❑ ❑
Is disposal of screenings in compliance? 0 ❑ ❑ ❑
Are the bars spaced properly? ❑ ❑ ❑
Is the unit in good condition? 0 ❑ ❑ ❑
Comment: Excessive debris present, see summary.
Treatment Activated Sludge
Yes No NA NE
Is the aeration mechanism operable?
0
❑ ❑ ❑
Is the aeration basin thoroughly mixed?
0
❑ ❑ ❑
Is the aeration equipment easily accessed?
0
❑ ❑ ❑
Is Dissolved Oxygen adequate?
0
❑ ❑ ❑
Are Settleometer results acceptable?
❑
❑ ❑
Is activated sludge an acceptable color?
0
❑ ❑ ❑
Comment: See summa
Treatment Return pumps Yes No NA NE
Are they in place? 0 ❑ ❑ ❑
Are they operational? ❑ 0 ❑ ❑
Comment: See summary.
Treatment Filters
Yes No NA NE
Is the filter media present?
❑ ❑ ❑
Is the filter media the correct size and type?
❑ ❑ ❑
Is the air scour operational?
❑ ❑ ❑
Is the scouring acceptable?
❑ ❑ ❑
Is the clear well free of excessive solids?
❑
❑ ❑
Is the mud well free of excessive solids and filter media?
❑
❑ ❑
Does backwashing frequency appear adequate?
❑ ❑ ❑
Comment: See summa
Treatment Sludge Storage/Treatment Yes No NA NE
Is the aeration operational? ❑ ❑ ❑
Is the aeration pattern even? ❑ ❑ ❑
If required, are Sanitary "Ts" present in tankage? ❑ ❑ ❑
Page 5 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Comment:
Treatment Disinfection
Yes No NA NE
Is the system working?
0
❑ ❑ ❑
Do the fecal coliform results indicate proper disinfection?
0
❑ ❑ ❑
Is there adequate detention time (>=30 minutes)?
❑
❑0 ❑
Is the system properly maintained?
❑ ❑ ❑
If gas, does the cylinder storage appear safe?
❑
❑ ❑
Is the fan in the chlorine feed room and storage area operable?
❑
❑ ❑
Is the chlorinator accessible?
❑
❑ ❑
If tablets, are tablets present?
❑
❑ ❑
Are the tablets the proper size and type?
❑
❑ ❑
Is contact chamber free of sludge, solids, and growth?
❑
❑ ❑
If UV, are extra UV bulbs available?
❑ ❑ ❑
If UV, is the UV intensity adequate?
❑ ❑ ❑
# Is it a dual feed system?
❑ ❑ ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
❑
❑ ❑
If yes, then is there a Risk Management Plan on site?
❑
❑ ❑
If yes, then what is the EPA twelve digit ID Number? (1000-
If yes, then when was the RMP last updated?
Comment: See summary.
Record Keeping
Yes No NA NE
Is a copy of current permit available?
❑ ❑ ❑
Are monitoring reports present: NDMR?
❑ ❑ ❑
NDAR?
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑ ❑ ❑
Are application rates adhered to?
❑ ❑ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑ ❑ ❑
Are all samples analyzed for all required parameters?
❑ ❑ ❑
Are there any 2L GW quality violations?
❑
❑ ❑
Is GW-59A certification form completed for facility?
❑ ❑ ❑
Is effluent sampled for same parameters as GW?
❑ ❑ ❑
Do effluent concentrations exceed GW standards?
❑ ❑ ❑
Are annual soil reports available?
❑
❑ ❑
# Are PAN records required?
❑
❑ ❑
# Did last soil report indicate a need for lime?
0
❑ ❑ ❑
Page 6 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
If so, has it been applied?
❑
0 ❑ ❑
Are operational logs present?
0
❑ ❑ ❑
Are lab sheets available for review?
0
❑ ❑ ❑
Do lab sheets support data reported on NDMR?
0
❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
0
❑ ❑ ❑
Are Operational and Maintenance records present?
0
❑ ❑ ❑
Were Operational and Maintenance records complete?
0
❑ ❑ ❑
Has permittee been free of public complaints in last 12 months?
0
❑ ❑ ❑
Is a copy of the SOC readily available?
❑
❑ 0 ❑
No treatment units bypassed since last inspection?
❑
0 ❑ ❑
Comment: See summa
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
0
❑ ❑ ❑
Is the cover crop type specified in permit?
❑ ❑ ❑
Is the crop cover acceptable?
❑ ❑ ❑
Is the site condition adequate?
❑ ❑ ❑
Is the site free of runoff / ponding?
❑ ❑ ❑
Is the acreage specified in the permit being utilized?
❑
❑ ❑
Is the application equipment present?
❑ ❑ ❑
Is the application equipment operational?
❑
❑ ❑
Is the disposal field free of limiting slopes?
❑ ❑ ❑
Is access restricted and/or signs posted during active site use?
❑ ❑ ❑
Are any supply wells within the CB?
❑
❑ ❑
Are any supply wells within 250' of the CB?
❑ ❑ ❑
How close is the closest water supply well?
❑
❑ ❑
Is municipal water available in the area?
❑
❑ ❑
# Info only: Does the permit call for monitoring wells?
❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB?
❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
❑ ❑ ❑
Are monitoring wells damaged?
❑
❑ ❑
Comment: See summa
5-DAY UPSET TANK
Storage Yes No NA NE
Storage Type? Aboveground
storage tank
Storage amount? 500000
Page 7 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Gallons
# At what point is side -stream wastewater returned to treatment?
Is there a Spill Control Plan?
0
❑ ❑ ❑
Aerated or Mixed?
If aeration is present, is it adequate?
❑
❑ 0 ❑
If present, are diffusers cleaned regularly?
❑
❑ 0 ❑
Is influent structure acceptable?
0
❑ ❑ ❑
Are banks/berms free of seepage and erosion?
❑
0 ❑ ❑
Are banks/berms free of excessive vegetation?
0
❑ ❑ ❑
Is pond lined?
❑
❑ 0 ❑
Liner Type
Is liner acceptable?
❑
❑ 0 ❑
Are baffles/curtains acceptable?
❑
❑ 0 ❑
Does the pond have a freeboard marker?
0
❑ ❑ ❑
Required freeboard?
2.0
Feet
Actual freeboard?
21
Feet
Is there suitable grassed vegetation?
❑
0 ❑ ❑
Is the vegetation maintained?
❑
0 ❑ ❑
Is the area free of excessive weeds and/or woody species?
0
❑ ❑ ❑
Is the area free from signs of overflow?
0
❑ ❑ ❑
Is color acceptable?
❑
❑ ❑
Are floating mats acceptable?
❑
❑ ❑
No excessive buildup of solids?
❑
❑ ❑
Are aerators/mixers acceptable?
❑
❑ 0 ❑
Is effluent structure acceptable?
0
❑ ❑ ❑
If present, is pond cover acceptable?
❑
❑ 0 ❑
Comment: See summa
WET WEATHER STORAC
Storage
Yes No NA NE
Storage Type?
Aboveground
storage tank
Storage amount?
1000000
Gallons
# At what point is side -stream wastewater returned to treatment?
Is there a Spill Control Plan? 0 ❑ ❑ ❑
Page 8 of 9

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 07/17/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Aerated or Mixed?
If aeration is present, is it adequate?
If present, are diffusers cleaned regularly?
Is influent structure acceptable?
Are banks/berms free of seepage and erosion?
Are banks/berms free of excessive vegetation?
Is pond lined?
Liner Type
Is liner acceptable?
Are baffles/curtains acceptable?
Does the pond have a freeboard marker?
Required freeboard?
Actual freeboard?
Is there suitable grassed vegetation?
Is the vegetation maintained?
Is the area free of excessive weeds and/or woody species?
Is the area free from signs of overflow?
Is color acceptable?
Are floating mats acceptable?
No excessive buildup of solids?
Are aerators/mixers acceptable?
Is effluent structure acceptable?
If present, is pond cover acceptable?
Comment: See summary. Enclosed tanks.
❑❑■❑
❑❑■❑
■❑❑❑
2.0
Feet
21
Feet
❑■❑❑
❑■❑❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑❑❑■
❑❑❑■
❑❑❑■
❑❑■❑
❑ ❑ ❑
Page 9 of 9

ROY COOPER
Governor
MICHAEL S. REGAN
Serrerarl
LINDA CULPEPPER
nrre,tor
Sean Devine
Manager
Wallace Loft, LLC
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Dear Mr. Devine:
NORTH CAROL INA
Environmental Quality
January 10, 2020
Subject: Speculative Effluent Limits
The Cottages of Boone WWTP
Permit No. WQ0035784
Watauga County
Watauga River Basin
This letter provides speculative effluent limits for a 0.1 MGD conjunctive use permit at The Cottages of
Boone WWTP, The Division received the speculative limits request in an email dated November 14, 2019
from Pete Dickerson of Odom Engineering PLLC. Please recognize that speculative limits may change
based on future water quality initiatives, and it is highly recommended that the applicant verify the
speculative limits with the Division's NPDES Unit prior to any engineering design work.
Receiving Stream. Laurel Fork is located within the Watauga River Basin. Laurel Fork has a stream
classification of C;Trout, and waters with this classification have a best usage for aquatic life propagation
and maintenance of biological integrity, wildlife, secondary recreation, agriculture, and trout propagation
and survival. Laurel Fork has a summer 7Q10 flow of 0.44 cfs, a winter 7QI0 flow of 0.64 cfs, a 30Q2
flow of 1.39 cfs, and an annual average flow of 3.2 cfs.
Based upon a review of information available from the North Carolina Natural Heritage Program Online
Map Viewer, there are not any Federally Listed threatened or endangered aquatic species identified within
a 5-mile radius of the proposed discharge location. If there arc any identified threatened/endangered
species, it is recommended that the applicant discuss the proposed project with the US Fish and Wildlife
Service to determine whether the proposed discharge location might impact such species.
Speculative Effluent Limits. Based on Division review of receiving stream conditions and water quality
modeling results, speculative limits for the proposed conjunctive use discharge of 0.1 MGD are presented
in Table 1. A complete evaluation of these limits and monitoring requirements for metals and other
toxicants, as well as potential instream monitoring requirements, will be addressed upon receipt of a formal
NPDES permit application. Some features of the speculative limit development include the following:
• BOD/NH3 Limits. BOD limits are assigned to be protective of instream dissolved oxygen (DO)
and are consistent with the facility's non -discharge permit limits. NH3-N limits are assigned to
protect for instream ammonia toxicity and instream DO. The resultant limits are considered
technologically -feasible.
9w!\Q�,�North Carolina Department of Environmental Quality 1 Division of Water Resources
'512 North Salisbury Street 1617 Mail Service Center I Raleigh. North Carolina 27699 1617
/' 919 7079000

• TSS: TSS limits are consistent with the facility's non -discharge permit limit, NPDES
implementation, treatment plant design, and are considered technically feasible.
TABLE 1. Speculative Limits for The Cottages of Boone WWTP
Effluent Characteristic
Effluent Limitations
Monthly
Average
Weekly
Average
Daily Maximum
Flow
0.1 MGD
BOD5
10.0 m L
15.0 m L
NH3 asN
3.2rn L
16.0m L
Dissolved Oxygen
6.0 m
L Dailv Minimum Average
TSS
5.0 m L
7.5 m L
TRC
28 L
Fecal coliform (geometric
mean
200/100 mL
400/100 mL
Chronic Toxicity, Pass/Fail
(Quarterly test
26%
Engineering, Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES
permit for a new or expanding discharge will be issued with these speculative limits. Final decisions can
only be made after the Division receives and evaluates a formal permit application for the new/expanded
discharge. In accordance with North Carolina Administrative Code 15A NCAC 2H.0105(c), the most
environmentally sound alternative should be selected from all reasonably cost effective options. Therefore,
as a component of all NPDES permit applications for new or expanding flow, a detailed engineering
alternatives analysis (EAA) must be prepared. The EAA must justify requested flows and provide an
analysis of potential wastewater treatment alternatives. A copy of the Division guidance for preparing EAA
documents is attached.
Should you have any questions about these speculative limits or NPDES permitting requirements, please
feel free to contact David Hill at [phone].
Respectfully,
J lie Grzyb
upervisor, NPDES Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
NPDES Permit File
Electronic Copy:
NC Wildlife Resources Commission, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, [e-mail]
DWR/Water Quality Regional Operations/Winston-Salem
DWR/Non-Discharge Branch
DWR/Basinwide Planning, Ian McMillan
DWR/NPDES Server>Specs
Pete Dickerson, [e-mail]
Page 2 of 2