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Home My WebLink AboutNC0075388_Fact Sheet_20210413DENR/DWQ EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit: NCO075388 2021 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: TRO Consultants, Inc. Pleasant Grove Home WWTP Applicant Address: P.O. Box 1051; Flat Rock, NC 28731 Facility Address: 189 Robinson Cove Rd; Candler, NC 28715 Facility Class Permit Status: Grade II Biological WPCS Renewal Permitted Flow (as built) 0.025 0.012 MGD Type of Waste 100% Domestic Receiving Stream Pole Creek Stream Class ID C 6-76-6 River Basin French Broad Subbasin 04-03-02 HUC 0601010SO502 USGS Too Asheville, NC EBSE 7Q10 Sum Win cfs 1.0 1.3 30Q2 cfs 1.8 Avg. Stream Flow cfs 3.8 IWC % 3.8% 1.9% County Buncombe I Regional Office ARO Basic Information for Expedited Permit Renewal Permit Writer / Date Bradley Bennett / January 26, 2021 Does permit need daily max NH3 limits? Limits in permit for Summer 21 MA 35 DM Does permit need TRC limits/language? Limit in permit 28µ L Does permit have toxicity testing? No - does have NH3-N limits Does permit have Special Conditions? One condition related to phased construction Does permit have instream monitoring? No Stream on 303 d List? For w/parameter? None other than statewide mercury listing Any compliance concerns? No enforcement actions; See compliance discussion below Any modifications since lastpermit? None noted in application. Facility not o eratin New expiration date: I October 31, 2025 FACILITY OVERVIEW: This facility is 100% domestic waste. The application notes that the facility serves an assisted living center with 99 residential spaces. The facility is permitted at 0.025 MGD and the current as -build design capacity of the treatment system is 0.012 MGD. The treatment system consists of the following wastewater treatment components: • Manual bar screen • Aeration basin with dual blowers • Rectangular Clarifier with skimmer and sludge return • Aerobic digestor • Tablet chlorinator with Chlorine contact chamber • Tablet Dechlorination • Lift station and force main to outfall The force main noted above is over 3,400 feet of pipe so the outfall is located a good distance from the facility and treatment system. The location map on the permit has been updated to indicate the location of the facility along with some other roads for location purposes. Regional Office staff have indicated that the force main and outfall location should be checked by the permittee prior to operating the treatment system again. Given the lack of use over the last few years and the distance of the pipe it is felt that some review of the piping and outfall is warrented. No modifications were noted or proposed in the current application. The application indicated no flow over the last three years and there was no data reported in the application. The cover letter with the application indicated that the system currently has no electricity to it and is inoperable. It notes that the permittee is willing to make all needed corrections to the facility to bring it back on line when needed. Additional Information: As part of the permit review it was found that the facility was overdue with their annual fee. The permittee was contacted about the fee and made aware that with recent rule changes we cannot reissue the permit if fees are owed. Additional information was also requested about the status of the facility and clarification on the treatment plant size. The permittee responded and has submitted the fee. Permittee also indicates that the facility is still vacant, but plans were underway for rehabilitation of the building. The facility will maintain its license capacity for up to 99 residents, but the rebuilding will convert some rooms to private and will have a net effect of reducing the occupants to 50 or 60 % which will also reduce the staff in a similar manner. So, the waste load generated should actually decrease. INSPECTION The most recent inspection (3/8/2016) noted that the site was in disrepair the facility was vacant and the treatment system was not operation. New owners (TRO) had recently purchased the facility. DWR staff had indicated to the onsite consultant that small package treatment plants of this type could have difficulty with the waste stream from the facility. The consultant assured that the facility had functioned previously under the same load situation. Regional office staff also pointed out, during this inspection, the need to address rust in the treatment facility and to repaint the facility. The appropriate steps to address this concern, checking for possible degraded areas, repairing and painting will be key items in assuring the long-term operation of the treatment system. There may be other items as well and appropriate professionals should review the treatment system repairs needed to assist this process. The needed repairs and maintenance should take place to assure the treatment system is properly operational before any wastewater flow from the facility is routed to the system. Asheville Regional Office staff should be contacted for an inspection prior to operation of the treatment facility. To address the issue of proper review of needed repairs a Special Condition has been added to the permit to require review by appropriate professionals to assess needed repairs. This requirement is also referenced in the Supplement to the Cover Page of the permit. COMPLIANCE: During the permit cycle this facility did not have any enforcement actions. The facility 2 NOVs for late/missing DMRs (2019 & 2020) and an NOD (2021) for the same. There were also 2 NOVs (2018 & 2019) for permit condition violations and no ORC designated along with an NOV in 2018 for overdue annual fees. In review of the application and other available information the permit writer found that the facility has failed to submit their most recent annual fee (due January 2021). The permittee has been contacted about the overdue fee and advised that with recent changes to our rules we cannot reissue the permit with fees owed to the Division. The facility has paid the annual fee and the permit can be reissued. Pleasant Cove Home WWTP Fact Sheet NPDES Renewal 2020 — January 26, 2021 Page 2 MONITORING DATA REVIEW: Parameter Units Avg. Low Permit Limit Comments Facility not operating - No Flow (MGD) 0.012 MA Discharge BOD (mg/L) 30MA 45DM TSS (mg/L) 30MA 45DM Temp (C) - Fecal (#/100ml) 200MA 40ODM pH (SU) 6 to 9 NH3-N (mg/L) Summer 21MA WLA spreadsheet shows no need for 35DM limits for 0.012 MGD but no data to verify so leave in the renewal NH3-N (mg/L) Winter TRC (µg/L) 28DM MA - Monthly Average DM - Daily Max Daily Average The data reviewed for the renewal is from June 2016 through November 2020. All data showed as having a waiver due to No Discharge indicated in the system. FILE HISTEORY REVIEW SUMMARY • Authorization to Construct issued July 25, 2989 to construct a 0.012 MGD treatment system with a discharge point into Pole Creek. • Waste Load Allocation (WLA) in 1993 set limits of 30 mg/L for BOD and TSS; 1000 col/100mL for fecal and 6 to 9 standard units for pH. Monitoring also required for total residual chlorine (TRC) and ammonia nitogen (NH3-N). These limit applied to both discharge levels - 0.012 and 0.025 MGD. • 1995 WLA added a TRC limit of 28 µg /L and a summer NH3-N limit of 21 mg/L applicable to the 0.025 flow level. BOD and TSS levels set at 30/45 and fecal 200 / 400 (monthly average / daily max) for both discharge levels. • 2001 Permit Renewal - no major changes in the permit. • 2005 Permit Renewal - added NH3-N limits of 21 and 35 mg/L and TRC limit of 28 mg/L (DM) to the 0.012MGD flow. The monitoring frequency for NH3-N changed to weekly. On the 0.025MGD limits a daily max of 35 was added to NH3-N and 28 µg/L for TRC. • 2010 Permit Renewal - updated the treatment system components based on regional office comments and corrected monitoring frequencies in the 0.025 MGD flow that should have been weekly. • 2016 Permit Renewal - no changes other than added electronic reporting and rule references. PROPOSED PERMIT CHANGES: • Updated eDMR requirements to be consistent with final EPA rule. • Added regulatory citations throughout permit as needed. • Added location of the facility on the discharge map. • Added Special Condition for completion of a technical study to review needed repairs to the treatment system. This condition is also referenced in the Supplement to the Cover page of the permit. Pleasant Cove Home WWTP Fact Sheet NPDES Renewal 2020 — January 26, 2021 Page 3 PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: February 26, 2021 Permit Scheduled Effective Date: May 1, 2021 STATE CONTACT: If you have questions concerning the above or the attached documents, please contact Bradley Bennett at (919) 707-3629. Pleasant Cove Home WWTP Fact Sheet NPDES Renewal 2020 — January 26, 2021 Page 4 E6 MS A°i]' SOSI 9L6 L-L620nLC P 4PG 06LX O�p�p n I Oul 9 W9A K to 206 s v4w- M9f6L b"WpNNCOD32388 b16s2�9ultCon�6 Hol 8 oI iu{eul lu pm6 9 41bDE2 M921s s ; . w NC 3l2aa-1815 W�vigil � 26WC6U U{64 w1,0j* AILO null 9U9a6 HOIg! (:91011U9 Eunnouw6u{91 W Will HOpcc 21916 Ot /AA!2COU2lU UOf9U\ bnpl!c AICKA LEFi), dd O' HENISAtlAE' I b'O' BOX S080 I V2HEAlrfE' NC Sam I (200) 900-4504 (SSG) 533-2830 I less) 323'20as Lvx VqA Cowwlzzlou szblLG2' H0191A bnPl!c alWIG 01 M2muzN' GvonuA 01 u 1 u o 2mow {o suq znpzcupsq ps{ols {ps S g i WsLc p' SOSJ �6a91 C16LK 2!ausq Iplz Suq of WsLcp' 5OS4 2GCf10U 4-201 OI Ip6 eGUSL91 2491n{62 of HOup C9LO Ns. Nollp Cslollus suq m92 9 dnsllpsq uGM2bsbsl mlMu fps wssulua O{ Lsdnuew lz suq dnsll.Umpme ok 2scpou 4-2al OlfpG eGMLsl 27s1ne2 of Ip6 7wG o{ sscp suq Gosh bnplImpou' 9 usmzb9beL wsepua 911 o{ Ips 29lq uopee' bsbel' gocnureu{ oL leas, sgAGLpzswGuf msz bnpl!2peq msz' s{ {ps follomlua gs{s(z) OS\sor Vuq 1psf IpG 2slq usmzb9bsl w mPlW mp!op !z spscpeq psLG fo' ms2 bnpl!2pGq !U 1ps y2p6AIIIG CpRsu-ywGz Ou 2mOW 2191GWGUI! Ip9f {ps UDfl G OL 0{p6L 1Ga91 9gAGq?GwGul' s lw6 CObT 01 21916 0{ Nogp CSLOI!us' {p9f VG\2ps 12 SMPOUSGq to wsl(G fp!2 sWgsAg suq GU{GLeq sz pL2{ c1922 ws8 !u Ips C!IT oly2psrylls' lu Bnucowps COMA suq uGwbsb6L KUOMU 921p6 V2p6AI116 (;1JlSaU-J!WG2' bnpllep6q' 122nGq' suq CIGLK of 1N6 V21JGAllle CI{Issu-1111168' Guasasq !u bnpllcsf!ou o{ 9 mpo' pe!ua plzl gnIN 2mow' g6boz6z suq agAa: Ipsf lG\zps 12 1ps fsasl 9n{poussq pA Ism {o squnul2lsl oslpz' bGWOUSIIX sbbGsLsq z9lg lGasl CIGLK' B6{oLG 1ps nugGLzlausq's WofsLT bnpllc' gnlA oowuA22l000q' dnsl!psq suq W091H cvKo ov Bnt4coWBE conmiA VLLID`dAll OE bf16EICVIIO 1 bvbl0k 1HE 112tl JoDVA NE1M0bK CIIINEI =11WE? 4/7/2021 Mail - Bennett, Bradley - Outlook [External] Re: Draft Permit for Pleasant Cove Home WWTP - NCO075388 Kenneth Hodges <kenhodges@morrisbb.net> Thu 2/2S/2021 4:SS 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. Good afternoon Mr. Bennett, This is to acknowledge receipt of the draft permit for WWTP - NC0075388, and to let you know that I was able to view and download the file for my records. Thank you so much for your time and attention to this matter. Best regards, Ken Hodges Pres., TRO Consultants, INC 423-772-0287 423-534-5461 On Feb 25, 2021, at 7:32 AM, Bennett, Bradley <bradley.bennetI2ncdenr.gov> wrote: Mr. Hodges, The draft permit for your wastewater NPDES discharge permit is completed and will be going to public notice later this week. I have attached a copy of the draft permit and cover letter here for your review. Please respond to this email to let me know that you received the draft permit and were able to view the file and download it for your records. 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 <NC0075388_Draft Permit and Cover Ltr_202100222.pdf> https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj 4/7/2021 Mail - Bennett, Bradley - Outlook RE: Pleasant Cove Home - Updated language in permit and cover letter Wiggs, Linda <linda.wiggs@ncdenr.gov> Tue 2/23/2021 4:53 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> That is fine. That sentence does need to be removed though in the final if that is ok. Thanks. V�AD�,.E--3 Environmental Senior SpecialistlDivision Water Resources North Carolina Department of EnNironmental Quality 828-296-4500 (Office) Linda. wiggs gcdear.gov !rai coffespolndencc to and lII Mills addfuss �q , .: r' t,-) the Noah Carc*w PUtAc Re cods Law and I be dsdcwd to thli'd parries From: Bennett, Bradley Sent: Tuesday, February 23, 20213:45 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Re: Pleasant Cove Home - Updated language in permit and cover letter Thanks Linda. I made the change on "additional" earlier. I'll have to make the change on the sentence after the notice since the draft already went to our folks to post and I can't easily make the adjustment right now. 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: Tuesday, February 23, 20213:24 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: Pleasant Cove Home - Updated language in permit and cover letter Hi Bradley, See attached for my edits. Just removed a sentence and fixed a word. Thanks, E .=il`�r�rw r.... .djll�ft �%17Ij� Environmental Senior SpecialistlDivision Ti ater Resovrces North Carolina Department of EnNironmetval Quality 828-296-4500 (Office) Linda.wiggs@ncdenr.gov https:Houtlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2El ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1 /2 4/7/2021 Mail - Bennett, Bradley - Outlook From: Bennett, Bradley Sent: Monday, February 22, 20217:53 AM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Pleasant Cove Home - Updated language in permit and cover letter Hey Linda, Just wanted to make you aware of the changes I made to this one to add in the special condition for a treatment system study. I have highlighted the parts of the letter and permit that changed. BB Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 INC 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:Houtlook.office365.com/mail/search/id/AAMkADg1YjdhZmlxLTMzMGYtNGU3Ni1 hNGU4LTY3M2E10DhmOGQxYgBGAAAAAACylgF`JgHeWQptj... 2/2 2/21 /2021 Mail - Bennett, Bradley - Outlook RE: [External] NPDES Wastewater Permit Renewal - NCO075388 Wiggs, Linda <linda.wiggs@ncdenr.gov> Mon 2/1/2021 10:50 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Yes, you and Mr. Hodges are on the right track. His response is sufficient now for my concerns. Thank you. , 1v Environmental Senior SpecialistlDivision Water Resources North Carolina Department of EnNironmental Quality 828-296-4500 (Office) Linda. wiggs gcdear.gov &rai coffespolndencc to and frcrn the Addfuss �q , .: r' P) the Noah Carc*w PUbic Recofds Law and rry be ckx*md to third parties From: Bennett, Bradley Sent: Sunday, January 31, 2021 1:06 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Fw: [External] NPDES Wastewater Permit Renewal - NCO075388 FYI, Mr. Hodges' response to my recent email. You can look down the email string and see the specific comments I sent to him recently. Hope I have been on the right track with this. BB Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 INC 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: Kenneth Hodges <kenhodges @morrisbb.net> Sent: Friday, January 29, 20214:48 PM To: Bennett, Bradley <bradley. ben nett@ ncden r.gov> Subject: Re: [External] NPDES Wastewater Permit Renewal - NCO075388 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, Sorry for the slow response but I've been out of town on business and away from my office since early Tuesday morning. Hopefully by now the annual fees have arrived at your office. Thank you for the clarification on item 2. Yes, I 100% agree with all of your comments and direction in your most recent email and was definitely planning on addressing any needed repairs and maintenance of the treatment plant prior to routing any wastewater flow from the remolded facility to the system. I have spoken to your Asheville Regional Office staff as well as my consultant about this several times previously and I think I have a pretty good understanding of what will need to take place prior to putting the system back into full-time service. And as you point out, this would naturally be the time to address these issues. My consultant has given me a pretty good breakdown of things that will need to take place and they will be very involved in the repairs and ensuring that everything is brought back to new condition prior to putting the system back online. They (or I) will keep your office informed of our progress and of course involve your Asheville Regional Office in any consultation and/or inspections and site approval as work progresses. https:Houtlook.office365.com/mail/search/id/AAQkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgAQANyQHkFKPeNPg8d5hZK... 1 /4 2/21 /2021 Mail - Bennett, Bradley - Outlook Thanks again for reaching out to me and for your thoughtful direction and input. Wishing you a wonderful and blessed weekend, Ken Hodges (423) 534-5461 On Jan 27, 2021, at 10:37 AM, Bennett, Bradley <bradley.bennett@ncdenr.gov> wrote: Mr. Hodges, Thank you for the response to my previous email. We appreciate the quick handling of the annual fee issues. I did want to get back in touch about the items in #2 related to rehabilitation of your facility. That information is very helpful for us, thanks for providing the update. In addition, however, we are concerned about the wastewater treatment system and the maintenance and repairs needed there. Your consultant has noted some needed repairs in the cover letter to make the system operational. Our regional office staff pointed out during an inspection in 2016 the need to address rust in the treatment facility and to repaint the facility. The appropriate steps to address this concern, checking for possible degraded areas, repairing and painting will be key items in assuring the long-term operation of the treatment system. There may be other items as well and we would suggest that you have appropriate professionals review the treatment system repairs needed to assist this process. The needed repairs and maintenance should take place to assure the treatment system is properly operational before any wastewater flow from your facility is routed to the system. Our Asheville Regional Office staff should be contacted for an inspection prior to operation of the treatment facility. We realize that this may be a while in the future before this would be needed. In the meantime, our Regional Office staff are available for an inspection now or in the future if you feel you need any additional input our technical assistance in the process. Thanks for your assistance in our review of your facility. 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: Kenneth Hodges <kenhodges@ morrisbb. net> Sent: Monday, January 25, 2021 10:17 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: Re: [External] NPDES Wastewater Permit Renewal - NCO075388 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, Thank you for the update on the permit renewal for the Pleasant Cove Home WWTP discharge permit. Please see below a response to your three inquiries. 1. The $860 annual permit fee is in the mail and should be arriving to your office within the next day or two (See attached copy of invoice and check #899). 1 know the mail is running unusually slow but if you do not receive it by the end of this week, please let me know. 2. As mentioned by my consultant, the facility is closed and undergoing significant rehabilitation. The license capacity for the facility will remain at 99 but we are converting many of the semi -private rooms to private rooms, and will be converting 2 semi -private resident rooms that currently house 4 residents and share 1 Jack -and -Jill bathroom into 1 two -room suites designed for 1 or no more than 2 residents. We will NOT be adding onto the footprint of the building so the net effect of the building rehab will be a facility with a maximum capacity of around 50 to no more than 60 residents. This of course will also result in a 50% staff reduction so the total net wastewater discharge of the building will probably be around 50% to 60% of previous usage. We have not yet started the actual renovations but are still finalizing plans, pulling permits, soliciting bids and securing the funding necessary to recapitalize the asset. 3. 1 completed the renewal application with the assistance of my consultant and I have a call into them to seek clarification on item 9. 1 probably entered the MGD plant description incorrectly. Hopefully I can clarify this by end of business Tuesday and shoot you have follow-up email with the correct information. Thanks again for your assistance with processing this renewal. Please let me know if you need any additional information at this time. Ken Hodges (423) 534-5461 https:Houtlook.office365.com/mail/search/id/AAQkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgAQANyQHkFKPeNPg8d5hZK... 2/4 2/21 /2021 Mail - Bennett, Bradley - Outlook On Jan 25, 2021, at 10:41 AM, Bennett, Bradley <bradley.ben nett ncdenr.gov> wrote: Mr. Hodges, As I noted in a previous email I am currently working on the permit renewal for the Pleasant Cove Home WWTP discharge permit. In my review I have a few issues that I need to address with you before we can move forward with the renewal. I have outlined these below. 1. You currently have an overdue annual fee for the permit. I have attached a copy of the invoice for the fee. If you have documentation that the fee was paid then please reply to this email with the documentation attached and we will update our system. If the fee has not been paid then please remit the fee as soon as possible. Failure to pay annual fees is a permit violation and could result in enforcement actions. Please also note that due to recent rule changes (15A NCAC 02H .0105) applications with annual fees dues are considered incomplete and we will not be able to process your renewal until the fee is paid. If there are contact changes that should be made (name, address, email or phone number) on the attached invoice, please let us know that. 2. In your renewal application your consultant noted in the cover letter that the facility is currently inoperable but will be running again once the permit is reissued and needed repairs can be made to the system. Could you please provide me with any updates on the current status of the system. 3. In your renewal application Item #9 - Description of the Treatment System - indicates that the system is a 0.01 MGD plant. The current permit and our records indicate the system is a 0.012 MGD plant. Could you review the submitted information and clarify this? if you have any questions please feel free to contact me. I am currently working out of the office, so contact through email is the best method. 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: Main Office <office .jjemi.net> Sent: Wednesday, January 20, 2021 11:44 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: ken hodges@morrisbb.net<kenhodges@morrisbb.net> Subject: [External] Re: NPDES Wastewater Permit Renewal - NCO075388 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Yes, please proceed. On Wed, Jan 20, 2021 at 10:59 AM Bennett, Bradley <bradley.bennett Dncdenr.gov> wrote: Mr. Hodges I am the permit writer for the renewal of your NPDES wastewater discharge permit for Pleasant Cove Home WWTP - NC0075388. I hope to have the draft permit ready for public notice soon. I think I have all the information that I need for the draft, but I will contact you if there is anything else we need. If you have any questions, please feel free to reach out to me. I am currently working out of the office, so email is the best way to touch base. In order to provide more convenience, control, and security to our permittees and assist them in processing their transactions, The Division of Water Resources is currently transitioning towards electronic correspondence. This will hopefully provide more efficient service to our permittees and other partners and will allow us to more effectively process and track documents. 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 https://outlook.office365.com/mail/search/id/AAQkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgAQANyQHkFKPeNPg8d5hZK... 3/4 2/21 /2021 Mail - Bennett, Bradley - Outlook will be emailed to the appropriate contact person(s) in your organization in a PDF format. If this is acceptable to you could you please respond to this email to let me know electronic submittal is okay. Thanks Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: brad ley. bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Thank you, James & James office@jjemi.net 828-697-0063 <NC0075388_Annual Fee Invoice.pdf> https://outlook.office365.com/mail/search/id/AAQkADg1 YjdhZmlxLTMzMGYtNGU3Ni1 hNGU4LTY3M2E1 ODhmOGQxYgAQANyQHkFKPeNPg8d5hZK... 4/4 NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY INVOICE Annual Permit Fee Overdue This annual fee is required by the North Carolina Administrative Code. It covers the administrative costs associated with your permit. It is required of any person holding a permit for any time during the annual fee period, regardless of the facili operating status. Failure to pay the fee by the due date will subject the permit to revocation. Operating without a valid permit is a violation and is subject to a $10,000 per day fine. If the permit is revoked and you later decide a permit is needed, you must reapply, with the understanding the permit request may be denied due to changes in environmental, regulatory, or modeling conditions. Invoice Number: 2020PRO11532 Permit Number: NCO075388 Buncombe County Pleasant Cove Home Kenneth R. Hodges Tro Consultants PO Box 1051 Flat Rock, NC 28731 Annual Fee Period: 2021-01-01 to 2021-12-31 Invoice Date: 12/03/2020 Due Date: 01/02/2021 Annual Fee: $860.00 Notes: 1. You may pay either by mail with check/money order OR by electronic payment (eCheck or Credit Card). 2. If payment is by check/money order, please remit payment to: NCDEQ - Division of Water Resources Attn: Animal/Discharge/Non-Discharge Billing 1617 Mail Service Center Raleigh, NC 27699-1617 3. If payment is electronic, please see https://deg.nc.gov/epayments/wq to pay electronically. Payments by eCheck will debit your checking account. Credit card transactions will incur a convenience fee. 4. Please include your Permit Number and Invoice Number on all correspondence. 5. A $25.00 processing fee will be charged for returned checks in accordance with North Carolina General Statute 25-3-512. 6. Non -Payment of this fee by the payment due date will initiate the permit revocation process. 7. Should you have any questions regarding this invoice, please contact the Annual Administering and Compliance Fee Coordinator at 919-707-3698. (Return This Portion With Check) ANNUAL PERMIT INVOICE Invoice Number: 2020PRO11532 Permit Number: NCO075388 Buncombe County Pleasant Cove Home Kenneth R. Hodges Tro Consultants PO Box 1051 Flat Rock, NC 28731 Overdue Annual Fee Period: 2021-01-01 to 2021-12-31 Invoice Date: 12/3/2020 Due Date: 1/2/2021 Annual Fee: $860.00 Check Number: 2/21 /2021 RE: Pleasant Cove Home Draft - NCO073588 Mail - Bennett, Bradley - Outlook Wiggs, Linda <linda.wiggs@ncdenr.gov> Wed 1/27/2021 11:44 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> 11 1 attachments (768 KB) 86053 Pilot Travel Issuance w sigs Nov2016.pdf: Here is the permit I was thinking of. I don't think Mr. Hodges will need a PE, but the metal corrosion evaluation needs to be done a professional in that line of work. Q Environmental Senior'-cialistlDivision Water Resources Nonh Carolina Depa=ent ofEnNironmental Quality 828-296-4500 (Office) - Linda.xv1ggsgncd=.g v r a+ r r r �. r r r ,� r* st .� • a •r r r- � rf rti r From: Bennett, Bradley Sent: Wednesday, January 27, 2021 11:34 AM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Pleasant Cove Home Draft - NCO073588 Linda, Here is the draft permit and fact sheet. I have adjusted the language in the cover letter a little. I also sent another email to Mr. Hodge. I'll let you know what I hear from him. I guess I didn't really ask him for stuff as much as I pointed out the things we discussed. Hopefully, he will acknowledge that. So, John cancelled our staff meeting while we were meeting so I didn't get to ask about the example permit language, but I am checking with some others in the group to see if they have suggestions. If we find something, we can add it in. I just wanted to go ahead and get you this to review. Take a look at the map where I added the facility location and make sure it looks correct. If you want to google it and look at the satellite, the address I found in the historical documents is 18 Horse Barn Road. 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/AAQkADglYjdhZmlxLTMzMGYtNGU3Ni1 hNGU4LTY3M2E1 ODhmOGQxYgAQANyQHkFKPeNPg8d5hZK... 1/1 2/21 /2021 Re: Pleasant Cove Home Draft - NCO073588 Mail - Bennett, Bradley - Outlook Bennett, Bradley <bradley.bennett@ncdenr.gov> Wed 1/27/2021 4:42 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Linda, I skimmed through the ARO Historical file again. Most of it is NOVs and Civil penalties. I did find some handwritten notes starting around pg 310 that looked to be about a complaint about a discharge that seemed to be traced back to this facility. BB Bradley Bennett Compliance and Expedited Permitting INC 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: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, January 27, 20214:16 PM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Re: Pleasant Cove Home Draft - NCO073588 I didn't see anything that showed that but it was 400 pages and I didn't look at all of it. BB Bradley Bennett Compliance and Expedited Permitting INC 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, January 27, 20213:25 PM To: Bennett, Bradley <bradley. ben nett@ ncden r.gov> Subject: RE: Pleasant Cove Home Draft - NCO073588 Hey, I just looked at the maps you suggested and I am curious about that force main. I did not realize it was that far away and I assume along a State Rd. I wonder if it shouldn't be checked. Or once they can get things working, but before its WW being discharged, to at least verify where that discharge pipe is located and that water is indeed coming out of it. Did you find anything in our files showing where the FM is laid. Afi 01ry Environmental Senior SpecialistlDivision Water Resources North Carolina Department of EnNironimental Quality 828-296-4500 (Office) Linda.irviggs@ncd=.gov ! From: Bennett, Bradley Sent: Wednesday, January 27, 2021 11:34 AM To: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Pleasant Cove Home Draft - NCO073588 https:Houtlook.office365.com/mail/search/id/AAQkADg1 YjdhZmlxLTMzMGYtNGU3Ni1 hNGU4LTY3M2E10DhmOGQxYgAQANyQHkFKPeNPg8d5hZK... 1 /2 2/21 /2021 Linda, Mail - Bennett, Bradley - Outlook Here is the draft permit and fact sheet. I have adjusted the language in the cover letter a little. I also sent another email to Mr. Hodge. I'll let you know what I hear from him. I guess I didn't really ask him for stuff as much as I pointed out the things we discussed. Hopefully, he will acknowledge that. So, John cancelled our staff meeting while we were meeting so I didn't get to ask about the example permit language, but I am checking with some others in the group to see if they have suggestions. If we find something, we can add it in. I just wanted to go ahead and get you this to review. Take a look at the map where I added the facility location and make sure it looks correct. If you want to google it and look at the satellite, the address I found in the historical documents is 18 Horse Barn Road. Thanks BB 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, INC 27699-1617 Email correspondence to and from this address may be subject to public records laws https://outlook.office365.com/mail/search/id/AAQkADg1YjdhZmlxLTMzMGYtNGU3Ni1 hN GU4LTY3M2E 1 ODhmOGQxYgAQANyQHkFKPeNPg8d5hZK... 2/2 NH3/TRC WLA Calculations Facility: Pleasant Cove Home WWTP PermitNo. NC0075388 Prepared By: Bradley Bennett Enter Design Flow (MGD): 0.012 0.025 <= Permitted Flow if Different from Design Enter s7Q10 (cfs): 1 Enter w7Q10 (cfs): 1.3 Total Residual Chlorine (TRC) Ammonia (Summer) Daily Maximum Limit (ug/1) Monthly Average Limit (mg NH3-N/1) Design Permitted Design Permitted s7Q10 (CFS) 1 1 s7Q10 (CFS) 1 1 DESIGN FLOW (MGD) 0.012 0.025 DESIGN FLOW (MGD) 0.012 0.025 DESIGN FLOW (CFS) 0.0186 0.03875 DESIGN FLOW (CFS) 0.0186 0.03875 STREAM STD (UG/L) 17.0 17 STREAM STD (MG/L) 1.0 1.0 Upstream Bkgd (ug/1) 0 0 Upstream Bkgd (mg/1) 0.22 0.22 IWC (%) 1.83 3.73 IWC (%) 1.83 3.73 Allowable Conc. (ug/1) 931 456 Allowable Conc. (mg/1) 42.9 21.1 Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Design Permitted Design Permitted Fecal Coliform w7Q10 (CFS) 1.3 1.3 Monthly Average Limit: 200i100mi 200/1oomi DESIGN FLOW (MGD) 0.012 0.025 (If DF >331; Monitor) DESIGN FLOW (CFS) 0.0186 0.03875 (If DF<331; Limit) STREAM STD (MG/L) 1.8 1.8 Dilution Factor (DF) 54.76 26.81 Upstream Bkgd (mg/1) 0.22 0.22 IWC (%) 1.41 2.89 Allowable Conc. (mg/1) 112.2 54.8 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)