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HomeMy WebLinkAboutNC0075680_Fact Sheet_20210222DENR/DWQ EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit: NCO075680 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: She -Can Company Rosewood Mobile Home park WWTP Applicant Address: P.O. Box 2805; Asheville, NC 28805 Facility Address: 2554 Brevard Road; Arden, NC 28704 Facility Class Permit Status: Grade II Biological WPCS Renewal Permitted Flow (as built) 0.03 MGD 0.02 Type of Waste 100% Domestic Receiving Stream Line Creek Stream Class ID C 6-59 River Basin French Broad Subbasin 04-03-02 HUC 0601010SO704 USGS Too Sk land, NC FBNE 7Q10 Sum Win cfs 0.27 0.35 30Q2 cfs 0.57 Avg. Stream Flow (cfs) 1.1 IWC (%) 14.7% based on permitted flow 10.3% based on as -built flow County I Buncombe I Regional Office I ARO Basic Information for Expedited Permit Renewal Permit Writer / Date Bradley Bennett / November 30, 2020 Does permit need daily max NH3 limits? Limits in permit; See discussion below for Winter limit change. 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? No Stream on 303 d List? For w arameter? None other than statewide mercury listing Anv compliance concerns? See compliance discussion below Any modifications since last permit? None noted in application, but ATC for new treatment unit issued after application received New expiration date: October 31, 2025 FACILITY OVERVIEW: This facility is 100% domestic waste. The application notes that the residential subdivision currently has 50 homes served. The design capacity of the treatment system as built is 0.02 MGD and consists of the following wastewater treatment components: • Bar screen • Aeration tank • Sludge holding tank • Chlorine contact chamber • Dechlorination • Aerobic digester Treatment System Upgrade The permit includes a phased effluent limits page with a provision for expansion to 0.03 MGD. On August 22, 2019 the Division approved an Authorization to Construct for the Rosewood facility to modify the treatment plant. The modifications will increase the capacity of the plant to 0.03 MGD to reach the permitted flow. During the permit development process the permittee indicted that the facility modifications have been built and they are currently awaiting a few final inspections before beginning to operate the modified system. They anticipate that this will occur and the system will be operating by the end of the year. Once the permittee begins operating the upgraded system the permit will no longer need the phased effluent limits and the permit will operate at the 0.03MGD level. With the permit drafted and noticed with the phased effluent levels, the permittee will be advised in the accompanying cover letter that with completion and operation of the upgraded treatment system the final permit will reflect just the effluent level of 0.03MGD. The upgraded treatment system will consist of the following components: • Bar Screen • Equalization Basin (accepting flow from two influent lines) • Flow Control Box (will split flow to two separate treatment systems) • 2/3 of Flow to Existing Aeration Basin and Existing Clarifier • 1/3 Flow to New Aeration Basin and New Clarifier • New Chlorination / Dechlorination Tank • New Outfall Location (approx. 15 feet upstream of current discharge, still to Line Creek) ** Update After Public Notice: ** The treatment system upgrade has been completed. Asheville Regional Office staff conducted an inspection of the new system on February 19, 2021 and confirms that the system is in place in accordance with their A to C. With this change, the final permit has been adjusted to remove the tiered flow limits. The final permit only contains the effluent flow limits for the 0.03 MGD flow. Application Information No modifications were noted or proposed in the current application but as noted above, the permittee is currently upgrading the treatment system (Upgrade is complete). Inspection Information Most recent inspection (12/18/2018) noted that the facility should perform maintenance trimming to assure access to the effluent pipe. The report also indicated the permittee was considering changes to the flow measurement devices. Regional office staff recommended that in these reviews an overall review of other system components should be conducted by the engineer as well. COMPLIANCE: This facility has not had an enforcement action since 2002. During the permit cycle the facility did have two NOVs issued for fecal coliform exceedances, one in May 2017 and one in October 2018. Rosewood MHP WWTP Fact Sheet NPDES Renewal 2020 —Nov 30, 2020 (Feb 22, 2021 update) Page 2 MONITORING DATA REVIEW: Parameter Units Avg. Low Permit Limit Comments Flow (MGD) 0.01 0.01 0.01 0.02MA 263 of 264 values reported as 0.01 BOD (mg/L) 4.96 41 <2 30MA No exceedances 45DM TSS (mg/L) 6.54 26 <2.5 30MA No exceedances 45DM Temp (C) 16.34 26 6 - Values in line with seasonal variation Fecal (#/100ml) 12.58 921 <1 200MA 921 is the only value above 200 40ODM pH (SU) N/A 7 6 6.4 6 to 9 No values out of range 7.8MA No MA values > 7.8 (7.7max) & NH3-N (mg/L) - Summer 0.76 12 <0.10 35DM only 2 MA values >5.5 for 0.03 Flow 20MA No MA values > 20 (8.1 max) & NH3-N (mg/L) - Winter 1.88 14 <0.10 35DM None > 11.0 for 0.03 Flow TRC (µg/L) 22.08 33 <20 28DM 21 values over 28 but none > 50 MA - Monthly Average DM - Daily Max Daily Average The data reviewed for the renewal is from November 2015 through August 2020. NH3-N MONITORING: Current Requirement: 2/ Month monitoring in Current Permit at 0.02MGD flow and Weekly for 0.03MGD flow. Permit has winter monthly average limits that are more than 2 times the summer limit. 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. This will apply to the limits for both effluent pages (0.02 and 0.03). The draft permit includes proposed changes to the winter limits. These changes will reduce the winter monthly average limit from 20mg/L to 15.6 mg/L on the 0.02MGD effluent page and from 14mg/L to 11.0 mg/L on the 0.03MGD page. The daily max limits will remain unchanged at 35 mg/L for the 0.02MGD flow and 27.5mg/L for the 0.03MGD flow. A review of the monitoring data over the permit cycle indicates that the highest winter NH3- N value was 14 mg/L, so, no daily values exceeded the daily winter limits. There were no instances over the last permit cycle (25 monthly values) where monthly averages would have exceeded the proposed monthly average limit limits of 15.6mg/L and 11.0 mg/L. The highest monthly average value in these records is 8.1 mg/L. Based on the DMR data review from the last permit cycle it appears that these changes to the winter NH3-N values will not impact facility compliance. FILE HISTORY REVIEW SUMMARY Waste Load Allocation(WLA) in 1988 for 0.03MGD flow established limits for BOD, TSS, Fecal and pH. An Authorization To Construct (ATC) was issued in 1989 for a 0.02MGD treatment facility. Waste Load Allocation in 1993 was done for the permitted flow of 0.03MGD and for the as -built flow of 0.02MGD. Ammonia limits (NH3-N) were added in this review. Waters at the time were classified WS- IV and backup power was required for the 0.03MGD flow. This requirement has remained in the permit. This WLA notes that the drainage area in the earlier WLA was incorrect (1.1 acres rather than 0.69). The drainage area change causes minor changes in the 7Q10 and other flow numbers but is noted as not having Rosewood MHP WWTP Fact Sheet NPDES Renewal 2020 -Nov 30, 2020 (Feb 22, 2021 update) Page 3 a significant impact on the limit numbers. It still looks like the old numbers were used in all the calculations and the old numbers are the ones shown in the BIMS flow data today. A review was done (Nov. 2020) of the discharge location using USGS StreamStats and it allears that the original drainage area is more accurate (0.69 acres). So, it is probably okay that we have continued to use the original WLA flows and numbers. • 1995 Permit - limits added for NH3-N and monitoring added for Total Residual Chlorine (TRC). For 0.03MGD flow TRC limited. • Two permit modifications were issued in 1996. In July a modification was issued to reduce the monitoring frequency for BOD, TSS and Fecal to 2/Month. In October a modification was issued to reduce NH3-N monitoring to 2/Month. • 2001 Permit Renewal - Stream classification updated to reflect reclassification to Class C. The permit was transferred to the current owner (She -Can Company) in July 2001. • 2005 Permit Renewal - Daily Max limit added for NH3-N and limit added for TRC under the 0.02MGD flow. • In 2006 an ATC was issued for installation of a dechlorination system to meet the new limits. • 2010 Permit Renewal - No Changes • 2015 Permit Renewal - no major changes other than regulatory citations, etc. • In August 2019 an ATC was issued for the construction of upgraded treatment components to move the system to its permitted flow of 0.03MGD. Specifics of this addition have been discussed previously in this Fact Sheet The permitfile also contains two emails, one from 2012 and one from 2020 that discuss the potential impacts of another discharge permit upstream on Line Creek (High Vista - NC0089095). These emails establish that expansion of the Rosewood facility in the future would most likely result in a requirement to reduce ammonia limits for the facility. The 2012 Fact sheet addendum for the High Vista permit notes that the Rosewood permit has established discharge limits and will not be subject to limits revisions. The treatment system modification that is currently under way for this facility is in keeping with previously established permit limitations and is not subject to any limits modifications at this time. Any further expansion of this flow, however, will most likely result in a necessary modification of permit limits to protect the receiving stream. PROPOSED PERMIT CHANGES: • Requires for eDMR were not included in the 2015 permit so this renewal has added in the most recent eDMR requirements to be consistent with final EPA rules. • Added regulatory citations throughout permit as needed. • Updated NH3-N effluent limits to set winter limits at values that are no less stringent than 2 times the summer values to be consistent with Division rules. • Discharge outfall latitude/longitude updated for new location. • Facility Location latitude/longitude updated (location of 2554 Brevard Road address). • Update: 0.02MGD flow level removed with completion of upgraded treatment system (0.03MGD) PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: December 15, 2020 Permit Scheduled Effective Date: March 1, 2021 STATE CONTACT: If you have questions concerning the above or the attached documents, please contact Bradley Bennett at bradley.bennettOncdenr.gov or (919) 707-3629. Rosewood MHP WWTP Fact Sheet NPDES Renewal 2020 — Nov 30, 2020 (Feb 22, 2021 update) Page 4 CITIZEN TRIES PART OFTHE USA TODAY NETWORK AFFIDAVIT OF PUBLICATION BUNCOMBE COUNTY Public Notice NORTH CAROLINA North ^Carolina Environmental Manage - 617 Notice f INC ntent Notice of Interrt to Issue a NPDE5 Waste- Issue Before the undersigned,a Notary Public, duly commissioned, qualified and water Permit N00062634 Wedggefield Acres Mobile Home Park and NCW75680 authorized by law to administer oaths, personally appeared said legal clerk, Rosewood Mobile Home Park WWTP who, being first dui p y y 9 y sworn, deposes and says: that he/she is the Legal The North Carolina Environmental Man- agemeDES Comission proposes to issue a Clerk of The Asheville Citizen -Times, engaged in publication of a DES wasge permit to newspaper aP er known as The Asheville Citizen -Times, published, issued, and the person(s) listed below. Written com- bents regarding the proposed permit will he accee30 days entered as first class mail in the City of Asheville, in Buncombe County and State of North Carolina; that ptd u ntil after the publish he/she is authorized to make this affidavit and date of this notice, The Director of the NC Division of Water Resources (DWR) may sworn statement; that the notice or other legal advertisement, a true copy of hold a public hearing should there be a significant degree of public interest which is attached here to, was published in The Asheville Citizen -Times on Please mail comments and/or information the following date(s) 12/19120. And that the said news a er in which pap requests to DWR at the above address. In- persons may visit the DWR at 5to said notice, paper, document or legal advertisement was published was, at N. Salisbury N. Salisbury Street, Raleigh, NC 27604 to the time of each and eve publication, a newspaper meetin all of the every P9 review information on file. Additional in- formation on NPDE5 permits and this no- requirements and qualifications of Section 1-597 of the General Statues of tice may be found on our website: httpJ/d North Carolina and was a qualified newspaper within the meaning of eq.nc.gov/about/divisions/water- resources/water- resou -rces- Section 1-597 of the General Statutes of North Carolina. perm its/wastewater-bran ch/npdes- wastewater/public-notices,or_ by calling i34'for its WW10 in Buncombe Signed this 20th of December, 2020 This permitted facility discharges domestic wastewater to an un- tributary to Pond Branch in the _ :road. River Basin. Ammonia nitro A colliiform, and total residual are water quality limited. This dis- J42AIele nay affect future allocations in Legal Clerk me a -4 o,...a n-..-.w 1L_ — 9 moone Sworn to and subscribed before the 20th of December, 2020 County treated in the ROD* I p� �ragen, hlorine �barge ns por- Notary Public of State of Wiscon in, County of 4.wn - CIq Z My Commission expires. (828) 232-5830 1 (828) 253-5092 FAX 14 O. HENRYAVE. I P.O. BOX 2090 I ASHEVILLE, NC 28802 1 (800) 800-4204 VICKY FELTY Notary Public State of Wisconsin 2/22/2021 Mail - Bennett, Bradley - Outlook RE: Rosewood MHP - NCO075680 Heim, Tim <Tim.Heim@ncdenr.gov> Mon 2/22/2021 7:06 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov>; Wiggs, Linda <linda.wiggs@ncdenr.gov> We did it Friday afternoon. Everything is good to go. I'll write up the inspection today. Let me know if you need anything specific. I have pictures and notes. From: Bennett, Bradley Sent: Monday, February 22, 2021 6:50 AM To: Heim, Tim <Tim.Heim@ncdenr.gov>; Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Rosewood MHP - NCO075680 Hey Guys, Hope you are both doing okay. I just wanted to check in on the inspection for Rosewood. I know it was scheduled for last Thursday (2/18) but wasn't sure if the weather impacted that. Anyway, wanted to check in and see the status on this and if we can get the permit ready to issue. Thanks for your help! KI- Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws https://outlook.office365.com/mail/inbox/id/AAMkADgl YjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2El ODhmOGQxYgBGAAAAAACylgPJgHeWQptjf... 1 /1 12/9/2020 RE: Monitoring Questions / NCO075680 Mail - Bennett, Bradley - Outlook Wiggs, Linda <linda.wiggs@ncdenr.gov> Mon 12/7/2020 10:35 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> HI Bradley, We can leave Rosewood at instantaneous. I believe they may be getting a flow recording device, but just in case let's leave it as is under instantaneous. Thanks. Environmental Senior Spec iadist"DivisioJn Water Resources Noah Carolina Department ofEnvui onmental Quality 828-296-4500 (Office) Lida.wiggs%=I-- .goy &na# cwesporxt7 me 10 and km the addres.�, k,3 :>Ut4tx t to 1w, kWh Greew i bcou i-kcorris Law wd may be drscbsed to thrd parties From: Bennett, Bradley Sent: Monday, December 7, 2020 7:35 AM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Re: Monitoring Questions / NCO075680 Linda, So, for Rosewood looks like sample type can remain as grab since they are at, but not over .003MGD. For the flow, let me know what you think. If you guys feel they should move to continuous monitoring, then we can do that. Otherwise, we will leave it at instantaneous. Thanks BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Weaver, Charles <charles.weaver anncdenr.gov> Sent: Friday, December 4, 2020 1:28 PM To: Bennett, Bradley <bradley. ben netta@ncdenr.gov> Cc: Hennessy, John <john.hennessncdenr.gov>; Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: RE: Monitoring Questions / NCO075680 Flow: Leave 0.02 as Instantaneous. If the ARO thinks that the facility would benefit from installing a recording flow meter, add Continuous monitoring to the 0.03 flow phase. Sampling: Until they exceed 0.03 MGD, they can collect grab samples. That's what the rule requires. CHW From: Bennett, Bradley <bradley. ben nett@ ncdenr.gov> Sent: Friday, December 4, 2020 10:38 AM To: Weaver, Charles <charles.weaver@ncdenr.gov> Subject: Re: Monitoring Questions https:Houtlook.office365.com/mail/search/id/AAMkADg1 YjdhZmlxLTMzMGYtNG U3Ni 1 hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2 12/9/2020 It's Rosewood MHP - NCO075680 Mail - Bennett, Bradley - Outlook Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Weaver, Charles <charles.weaver@ncdenr.gov> Sent: Friday, December 4, 2020 10:02 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: Monitoring Questions What's the permit number? From: Bennett, Bradley <bradley.bennet @ncdenr.gov> Sent: Friday, December 4, 2020 9:29 AM To: Weaver, Charles <charles.weaver@ncdenr.gov> Subject: Monitoring Questions Hey Charles, Had a couple of quick questions for you. I have a renewal that currently has phased flows in the permit (0.02MGD and 0.03MGD). The current permit has the flow measurement for both of these set at instantaneous. I have a document (21B .0505 Monitoring Requirements Summary) that indicates Q> or = 0.01MGD requires continuous monitoring, but I didn't see that in the rule when I looked, maybe I missed it. If I need to change this it would be nice to have a reference to where that is required. 213 .0505 seems to just require continuous monitoring for all [ (b)(1)(A)) with the ability to allow other monitoring under (b)(1)(C). This permit has always had instantaneous for both (at least dating back to 1993 which is the oldest permit I have). Maybe we had approved Instantaneous some time before and i just don't have any documentation of it? Second question is for the same renewal. The region also asked if the 0.03MGD limits should require composite monitoring instead of grab. The same document I noted above says that Q> or = 0.03MGD - Composite. However, when I look at the rule it says Q< or = 0.03MGD = Grab (see language below). Does the summary need to be changed? 26 .0505 (c)(3)(B) (B) Samples of the influent and effluent of the water pollution control facility or other point source shall be composite samples, except as provided in Part (C) of this Subparagraph. Samples for facilities with design flows of 30,000 gallons per day or less shall be grab samples unless the Director determines that, due to such factors as the variability of the discharge or its potential for impacts on the receiving stream, composite samples are necessary to characterize the discharge. The Director may specify the type of sample and type of composite sampling required, in order to obtain representative samples. Thanks for any guidance you can give on these! BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws https://outlook.office365.com/mail/search/id/AAMkADg1YjdhZmlxLTMzMGYtNGU3Ni1 hN GU4LTY3M2 E 1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/2 12/9/2020 Mail - Bennett, Bradley - Outlook RE: Rosewood MHP Draft Permit - NCO075680 Wiggs, Linda <linda.wiggs@ncdenr.gov> Wed 12/2/2020 11:48 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Let me know if they do have to go to continuous and composite. Thanks D,.E Lz--Ilda ofxwy�,6 S Environmental Senior SpecialistlDivision Water Resources North Carolina Department of Enx-iromnental Quality 828-296-4500 (Office) L1nda. w1ggs (??,ncdenr.gov &T& cwesponllw Ce to and iiom Uls BCdIeS Ls sutoLx;t tithe Wh C : ` r a FUbk(. PAcofds Law and rnW be dsob%d to lt*d paftirss From: Bennett, Bradley Sent: Wednesday, December 2, 2020 11:34 AM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Re: Rosewood MHP Draft Permit - NCO075680 Thanks for the comments and 'catches" Linda. I'll look at these and make changes. BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Wiggs, Linda <linda.wiggs@ncdenr.gov> Sent: Wednesday, December 2, 2020 10:57 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: Rosewood MHP Draft Permit - NCO075680 Cover letter says Dear Mr. Bet instead of Best. Not really liking the third sentence since there has been significant changes to their treatment system but since you have the last bullet in there about the AtC then no matter. In the third bullet (NH) you have "and have" in there twice. I am not sure about the standby power question. I do know we'd want them to have it regardless and the AtC and plans state they will have it. The plans however show it under #28 and says to refer to specifications but I do not see those specifications. https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E10DhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2 12/9/2020 Mail - Bennett, Bradley - Outlook Z-OQE Environmental Senior SpecialistlDivision Water Resources North Carolina Department of$nNironmental Quality 829-296-4500 (Office) Linda.wiggsgncdenr.goA- • o�•r • r r • r . . r . r s r f • ' r ..Ili • rti • r' / ti�►!ram`• r / •� 1. From: Bennett, Bradley Sent: Wednesday, December 2, 2020 10:19 AM To: Wiggs, Linda <linda.wiggs@ cdenr.gov> Subject: Rosewood MHP Draft Permit- NCO075680 Hey Linda, Here is the draft permit for Rosewood MHP for your review. There are a couple of things that are a little strange with it. I have tried to explain in the cover letter and in the Fact Sheet. Let me know if this all makes sense. So the issues are: • They are in the process of their upgrade to reach their permit limit of 0.03MGD. The system is not yet operational so I have written the draft for notice to still include the phase effluent pages as before. However, I noted in the cover letter that the upgraded system will probably be in place before the renewal permit is effective (most likely March) so at that time the final permit will be written without the phased flow and just have the 0.0311VIGD effluent page. • The second issue is related to the assimilative capacity of Line Creek since High Vista is upstream. I have explained in the fact sheet that they already had this approval and so they get the limits that have been in the permit (with the exception of the reduced winter NH3-N limit to meet the rule). In the cover letter I have made them aware that it is possible that no further expansion will be allowed or may come with reduction in effluent limits. Take a look at all of this and let me know what you think. Thanks BB Bradley Bennett Compliance and Expedited Permitting INC Division of Water Resources 1617 Mail Service Center Raleigh, INC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/2 1 /6/2021 Mail - Bennett, Bradley - Outlook Re: Rosewood MHP WWTP Draft Permit Renewal Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Wed 12/2/2020 2:33 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Hi Bradley, Thanks for the heads up ... no changes to the classification for that change. Maureen M a cwee+l/ K bY� NC DEQ - Division of Water Resources Wastewater Operator Certification 919-707-9038 From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, December 2, 2020 10:29 AM To: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Subject: Rosewood MHP WWTP Draft Permit Renewal Maureen, Here is the second permit renewal draft that I mentioned. This one is a little different so I wanted to point something out to you and see if it leads to any changes for you guys. This permit has phased effluent flows but they are currently in the process of upgrading their treatment system. Most Likely the new system will be in place before the final permit is issued and we will write the permit just for the upgraded flow of 0.03MGD. I wanted to check with you and see of the upgrade from 0.02 to 0.03MGD will change any of your classifications for this treatment system or their operator needs. Thanks for your input on this. RE Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov 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 1 /6/2021 Mail - Bennett, Bradley - Outlook RE: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Troy Shriver <tshriver@brooksea.com> Fri 12/4/2020 2:36 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov>; mbrooks@brooksea.com <mbrooks@brooksea.com> CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Mr. Bennett, Here is the new location of the outfall at Rosewood MHP Lat: 35.432857 Lon: 82.569572 Or Lat: 35°25'58.28" Lon: 82°34'10.45" Troy Shriver, PLS Office: 828-232-4700 Cell: 828-273-0578 From: Bennett, Bradley [mailto:bradley.bennett@ncdenr.gov] Sent: Tuesday, November 24, 2020 10:36 AM To: mbrooks@brooksea.com Cc: 'Troy Shriver' <tshriver@brooksea.com> Subject: Re: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Thanks! Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: mbrooks@brooksea.com <mbrooks@brooksea.com> Sent: Tuesday, November 24, 2020 10:27 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: 'Troy Shriver' <tshriver@brooksea.com> Subject: RE: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam nc.gov https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E10DhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/5 1 /6/2021 Mail - Bennett, Bradley - Outlook It was only moved about 15' from the original discharge point. To be accurate our surveyors are going to shoot an as - built and we can send specific lat/long at that point? Mark C. Brooks, P.E. Brooks Engineering Associates, P.A. 17 Arlington Street Asheville, NC 28801 (828)232-4700 From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, November 23, 2020 4:23 PM To: mbrooks@brooksea.com Cc: 'nathan best' <nathan citizensfuel.com> Subject: Re: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Mr. Brooks, Thanks for the plans and sorry to have to ask to have them resubmitted. I was wondering if you might have Lat/Long for the new outfall point? If it is in the information and I missed it I'm sorry. W. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: mbrooks@brooksea.com <mbrooks@brooksea.com> Sent: Monday, November 23, 2020 3:45 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: 'nathan best' <nathan citizensfuel.com> Subject: FW: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam nc.gov Mr. Bennett — Attached are the plans of the proposed expansion. It is just about complete and we should be closing this out in the coming weeks. Mark C. Brooks, P.E. Brooks Engineering Associates, P.A. 17 Arlington Street https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/5 1 /6/2021 Asheville, NC 28801 (828)232-4700 Mail - Bennett, Bradley - Outlook From: Nathan Best <nathan citizensfuel.com> Sent: Monday, November 23, 2020 3:02 PM To: Mark Brooks <mbrooks@brooksea.com> Subject: Fwd: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Mark, See below. Do you have what he needs? (<►K Sent from my iPhone Begin forwarded message: From: "Bennett, Bradley" <bradley. ben nett@ncdenr.gov> Date: November 23, 2020 at 2:30:54 PM EST To: Nathan Best <nathan citizensfuel.com> Subject: Re: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Hi Nathan, I had another question for you. Since it looks like the new system will be in place before the permit is finalized I wanted to see if you could provide me with an update of the treatment system description for the permit. If you had a plan sheet that showed the overall components that you could email that would help. Since we are working from home right now I unfortunately don't have access electronically to any plans or drawings that were part of the Authorization to Construct from 2019. Thanks m Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Nathan Best <nathan@citizensfuel.com> Sent: Monday, November 16, 2020 4:07 PM https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 3/5 1 /6/2021 Mail - Bennett, Bradley - Outlook [External] RE: Draft Permit - Rosewood MHP WWTP - NCO075680 Nathan Best <nathan@citizensfuel.com> Mon 1/4/2021 1:51 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Bradley, I received your email. I will let you know when I have a chance to review the attachment. Thank you, Nathan From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, January 4, 2021 11:27 AM To: Nathan Best <nathan@citizensfuel.com> Subject: Draft Permit - Rosewood MHP WWTP - NCO075680 Mr. Best, I wanted to forward the attached letter and draft permit for the Rosewood MHP WWTP NPDES permit renewal. This permit went to public notice in mid -December. I am sorry that I did not forward you the draft permit for review at that time. I was out of the office and I neglected to take care of this like I should have. the public comment period will run through mid -January. If you have any comments or want to discuss any issues, please let me know. If there are any updates on the operation of the new treatment system please let me know the status. Could you also please respond to this email to le t me know that you received the attached draft and were able to download and review the file? Thanks Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov 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 12/1/2020 Mail - Bennett, Bradley - Outlook RE: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Wiggs, Linda <linda.wiggs@ncdenr.gov> Tue 11/24/2020 9:55 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> No further comments on Rosewood. Plans look good. Those limits are acceptable. ,:�5fD -1 1W-1ftF-S Q . • . �...•-. 1 Environmental Senior SpecialistlDivision Water Resources North Carolina Department of Environmental Quality 828-296-4500 (Office) Linda.wiggs@,ncdenr.gov From: Bennett, Bradley Sent: Tuesday, November 24, 2020 9:46 AM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Re: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Linda, Sorry i forgot about this, but their winter number will drop a little to be in compliance with the 2B .0404 rule of not exceeding summer numbers by more than 2X. However, based on the data from the last permit cycle it looks like they can meet those numbers. Here is what the changes would look like: For 0.03 MGD Parameter Current Limits New Limits Monthly Avg Daily Max Monthly Avg Daily Max NH3-N - Summer 5.5 mg/L 27.5 mg/L 5.5 mg/L 27.5 mg/L NH3-N — Winter 14.0 mg/L 35 mg/L 11.0 mg/L 35 mg/L So the only change would be the winter monthly average dropping to 11. They did not report any single winter value over 8.1 in the last cycle so it seems they would be okay. BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennttt@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Wiggs, Linda <linda.wiggs@ncdenr.gov> Sent: Tuesday, November 24, 2020 9:11 AM To: Bennett, Bradley <bradley.ben nett@ncdenr.gov> Subject: RE: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 If there is no change then go with it. This new WWTP cannot meet lower limits, that is why I asked. Please don't ask John, I am sorry I brought it up. It seems every time I ask a question about my permits, I end up getting my permittees in a bad place. ,�D -1 Ift-IftF-S Q rotl p • .ter..•-■ . ... f "inch C111YU Environmental Senior SpecialistlDivision Water Resources North Carolina Department of Environmental Quality 828-296-4500 (Office) Linda.wiggs@,ncdenr.gov From: Bennett, Bradley Sent: Monday, November 23, 2020 4:54 PM To: Wiggs, Linda <linda.wiggsPncdenr.gov> Subject: Re: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 https:Houtlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/4 12/1 /2020 Mail - Bennett, Bradley - Outlook I don't think they will since they previously had a phased permit that allowed them to go up to the 30,000 GPD that they will have once the new stuff goes online. The permit already had more stringent limits for the expanded flow so those will kick in. I'll check, but I don't think we need to change the limits since they already had this in the permit. I know this one is a little strange with High Vista and another discharge upstream so I'll make sure. What are you thoughts on this. You think I'm on the right track? BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Wiggs, Linda <linda.wiggs@ncdenr.gov> Sent: Monday, November 23, 2020 4:25 PM To: Bennett, Bradley <bradley bennett(cDncdenr.gov> Subject: RE: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Thanks Bradley. Is this permit draft going to have any changes in effluent limits? Especially NH3? ear��eD E 1 4•/ 1���• 1 i! il. :� From: Bennett, Bradley Sent: Monday, November 23, 2020 3:53 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Fw: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Hey Linda, Got the plans for Rosewood. See attached BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett ncd nr.gov Email correspondence to and from this address may be subject to public records laws From: mbrooks@brooksea.com <mbrooks(abrooksea.com> Sent: Monday, November 23, 2020 3:45 PM To: Bennett, Bradley <bradley.bennett@ncdenr.ggv> Cc:'nathan best' <nathan citizensfuel.com> Subject: FW: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 z c a Np Environmental Senior Spec ialist,Diwision Mat( North Carolina Department of Environmental 1 828-296-4500 (Office) Linda.uiggsc ncdenr_gov CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam nc.gov Mr. Bennett — Attached are the plans of the proposed expansion. It is just about complete and we should be closing this out in the coming weeks. Mark C. Brooks, P.E. Brooks Engineering Associates, P.A. 17 Arlington Street Asheville, INC 28801 (828)232-4700 https:Houtlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/4 12/1 /2020 Mail - Bennett, Bradley - Outlook Re: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Bennett, Bradley <bradley.bennett@ncdenr.gov> Mon 11/23/2020 4:54 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> I don't think they will since they previously had a phased permit that allowed them to go up to the 30,000 GPD that they will have once the new stuff goes online. The permit already had more stringent limits for the expanded flow so those will kick in. I'll check, but I don't think we need to change the limits since they already had this in the permit. I know this one is a little strange with High Vista and another discharge upstream so I'll make sure. What are you thoughts on this. You think I'm on the right track? BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919)707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Wiggs, Linda <linda.wiggs@ncdenr.gov> Sent: Monday, November 23, 2020 4:25 PM To: Bennett, Bradley <brad ley. ben nett@ ncd en r.gov> Subject: RE: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Thanks Bradley. Is this permit draft going to have any changes in effluent limits? Especially NH3? DEQ� tlid�i Uf YY6 Environmental Senior Specialist'Division ff arter Resources North Carolina Department of Envi rorumental Quality 828-296-4500 (Office) L inda. wiggs �cdear. got• From: Bennett, Bradley Sent: Monday, November 23, 2020 3:53 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Fw: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Hey Linda, Got the plans for Rosewood. See attached. BB Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919)707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: mbrooks@brooksea.com <mbrooks@brooksea.com> Sent: Monday, November 23, 2020 3:45 PM To: Bennett, Bradley <brad ley. ben nett@ ncd en r.gov> Cc:'nathan best' <nathan citizensfuel.com> Subject: FW: [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E10DhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/3 1 /6/2021 Mail - Bennett, Bradley - Outlook [External] RE: Permit Renewal - Rosewood MHP WWTP - NCO075680 Nathan Best <nathan@citizensfuel.com> Mon 11/16/2020 4:10 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> 1 1 attachments (33 KB) Delegation of Signature Authority.pdf, CAUTION External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam nc.gov Mr. Bennett, Please see my responses below in RED. THANKS, NATHAN From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Friday, November 13, 2020 9:46 AM To: Nathan Best <nathan@citizensfuel.com> Subject: Permit Renewal - Rosewood MHP WWTP - NCO075680 Mr. Best, I am currently reviewing the permit renewal request for the Rosewood Mobil Home Park. In reviewing the application and other information I have a few questions that I wanted to pass along to you. These are outlined below. • First, you have signed the application for the permit renewal. Applications must be signed by the appropriate Responsible Official for your facility. In our records Scott Shealy is listed as the Owner/Responsible Official. You can be delegated signature authority to sign applications and other permit documents, but our records do not include a Delegation of Signature Authority to you. We will either need to have Mr. Shealy sign the application or receive a delegation for you to sign. I have attached a template memo for the delegation if this is what you choose to do. You can have this signed and scan and email it back to me. SEE ATTACHED SIGNED FORM. • Second, I just wanted to get an update from you on any recent upgrades with the treatment system. I know that you received and Authorization to Construct in August 2019 for changes to the system. Are any of these upgrades in process at this point? THE NEW TREATMENT PLANT HAS BEEN INSTALLED AND THEY ARE GETTING FINAL INPSECTIONS SOON BEFORE WE START IT UP. SHOULD BE BEFORE THE END OF THE YEAR. • Last I wanted to let you know that The Division of Water Resources is currently transitioning towards electronic correspondence in order to provide more convenience, control, and security to our permittees and assist them in processing their transactions. This will hopefully provide more efficient service to our permittees and other partners and will allow us to more effectively process and track documents. With this, we would like to ask you for your approval of the transmittal of documents related to your permitting and related activities with the Division in an electronic format. Documents will be emailed to the appropriate contact person(s) in your organization in a PDF format. YOU HAVE MY PERMISSION. I CAN BE LISTESD AS THE CONTACT AND THIS EMAIL ADDRESS IS FINE TO USE. https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2ElODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2 1/6/2021 Mail - Bennett, Bradley - Outlook Please respond to me through email with verification that transmittal of your documents in an electronic manner is acceptable to you. ACCEPTABALE. If you have any questions, please feel free to contact me. At this time contact through email is best since most of our staff are working out of the office. If we need to set up a time for a phone call we can do that through email. Thanks for your help on this. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov 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 hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/2 November 13, 2020 Wastewater Branch Water Quality Permitting Section Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Delegation of Signature Authority ROSEWOOD MOBILE HOME PARK NPDES Permit Number NCO075680 To Whom It May Concern: By notice of this letter, I hereby delegate signatory authority to each of the following individuals for all permit applications, discharge monitoring reports, and other information relating to the operations at the subject facility as required by all applicable federal, state, and local environmental agencies specifically with the requirements for signatory authority as specified in 15A NCAC 2B.0506. Individual # 1 Name Nathan Best Title Property Manager Mailing Address Box 2805g Asheville, Nc 28802 Physical Address: (it di#e,eno 2 Clingman Ave Asheville, Nc 28801 Email Address nathan@citizensfuel.com Office Phone: 828 - 210 - 5181 Mobile Phone- 828 - 273 - 5888 Individual #2 (if applicable) Grady Moffitt Maintenance Supervisor Po Box 2805 Asheville, Nc 28802 2 Clingman Ave Asheville, Nc 28801 grady @citizensfuel.com 828-210-5185 If you have any questions regarding this letter, please feel free to contact me at Enter Email or Phone Number. Si erely, A Authorized Signing O icial's Name: Scott Shealy Authorized Signing Official's Title: Member/Manager Mailing Address: PO Box 2805 Asheville, NC 28802 Email Address: Scott@Citizensfuel.Com 828-210-5161 828-280-4163 cc: a Regional Office, Water Quality Permitting Section RC6EWCK)0 MOBILE HOME PARK OEMM FLOW = 30,0W GRID Am FLAW = 2" opm PEAK FL9W - 52A GPM PEAK]HG FAl7CR = 2.5 MT11+0 INFLUENT SLUYX HOLDM TANKS ERAS W E30SIING AER4TTON DAMN C ARIF1ER RROPWE0 SL6UGE FOLDING iAhK FLOW } FLOW 2:x-- PROP05EP mumqb NuwlpsE6 i+pmub E?0 RASN FLOW OONTROL AERVIDN GLARIFIER BCX BASIN PPoOPMEO CHLORMT[OW OE-0HLOR TAM WASTEWATER PROCESS SCHEMATIC FLAW DIAGRAM _ NEW OLUALL NH3/TRC WLA Calculations at 0.02 MGD Facility: Rosewood MHP WWTP PermitNo. NCO075680 Prepared By: Bradley Bennett Enter Design Flow (MGD): 0.02 Enter s7Q10 (cfs): 0.27 Enter w7Q10 cfs : 0.35 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/1) 1993 WLA indicated drainage areas wrong and noted different stream flows. Doesn't appear they have ever been used though. WLA notes they would not impact results significantly. Results shown in second column in italics. Review of DA shows 1988 WLA probably correct Summer 7Q10 0.26 Winter 7Q10 0.41 Ammonia (Summer) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 0.27 0.26 s7Q10 (CFS) 0.27 0.26 DESIGN FLOW (MGD) 0.02 0.02 DESIGN FLOW (MGD) 0.02 0.02 DESIGN FLOW (CFS) 0.031 0.031 DESIGN FLOW (CFS) 0.031 0.031 STREAM STD (UG/L) 17.0 17 STREAM STD (MG/L) 1.0 1 Upstream Bkgd (ug/1) 0 0 Upstream Bkgd (mg/1) 0.22 0.22 IWC (%) 10.30 10.65 IWC (%) 10.30 10.65 Allowable Conc. (ug/1) 165 160 Allowable Conc. (mg/1) 7.8 7.5 Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 0.35 0.41 Monthly Average Limit: 200/100ml 200 DESIGN FLOW (MGD) 0.02 0.02 (If DF >331; Monitor) DESIGN FLOW (CFS) 0.031 0.031 (If DF<331; Limit) STREAM STD (MG/L) 1.8 1.8 Dilution Factor (DF) 9.71 9.39 Upstream Bkgd (mg/1) 0.22 0.22 IWC (%) 8.14 7.03 Allowable Conc. (mg/1) 19.6 22.7 Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals) 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NH3/TRC WLA Calculations at 0.03 MGD Facility: Rosewood MHP WWTP PermitNo. NCO075680 Prepared By: Bradley Bennett Enter Design Flow (MGD): 0.03 Enter s7Q10 (cfs): 0.27 Enter w7Q10 cfs : 0.35 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/1) 1993 WLA indicated drainage areas wrong and noted different stream flows. Doesn't appear they have ever been used though. WLA notes they would not impact results significantly. Results shown in second column in italics. Review of DA shows 1988 WLA probably correct Summer 7Q10 0.26 Winter 7Q10 0.41 Ammonia (Summer) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 0.27 0.26 s7Q10 (CFS) 0.27 0.26 DESIGN FLOW (MGD) 0.03 0.03 DESIGN FLOW (MGD) 0.03 0.03 DESIGN FLOW (CFS) 0.0465 0.0465 DESIGN FLOW (CFS) 0.0465 0.0465 STREAM STD (UG/L) 17.0 17 STREAM STD (MG/L) 1.0 1 Upstream Bkgd (ug/1) 0 0 Upstream Bkgd (mg/1) 0.22 0.22 IWC (%) 14.69 15.17 IWC (%) 14.69 15.17 Allowable Conc. (ug/1) 116 112 Allowable Conc. (mg/1) 5.5 5.4 Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 0.35 0.41 Monthly Average Limit: 200/100ml 200 DESIGN FLOW (MGD) 0.03 0.03 (If DF >331; Monitor) DESIGN FLOW (CFS) 0.0465 0.0465 (If DF<331; Limit) STREAM STD (MG/L) 1.8 1.8 Dilution Factor (DF) 6.81 6.59 Upstream Bkgd (mg/1) 0.22 0.22 IWC (%) 11.73 10.19 Allowable Conc. (mg/1) 13.7 15.7 Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals) 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)