NC0089991_Application_20210714

ROY COOPER -- '
Governor :11 Ii
JOHNNICHOLSON �, Mnn„• ,
Interim Secretary
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
July 14, 2021
Wallace Loft, LLC.
Attn: Sean A. Dwyer, Director
2711 Centerville Rd
Ste 400
Subject: Permit Application
Application No. NC0089991
The Cottages of Boone WWTP
Watauga County
Dear Applicant:
The Water Quality Permitting Section acknowledges receipt of your application for a new NPDES WW permit, including
supporting documentation and your check number 9517 in the amount of$860.00 as payment of the application fee.
These items were received in our offices on July 13, 2021. Your application will be assigned to a permit writer within the
Section's NPDES WW permitting branch. The permit writer will contact you if additional information is required to
complete evaluation of your application. Your timely and direct response to any such request will help to expedite the
review process. Please note that acceptance of the application does not guarantee a NPDES permit will be issued for the
proposed activity. A permit will only be issued following a complete review of the application, concluding the proposed
discharge is allowableper applicable statutes and rules.
9
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deq.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
Sincerely„
Xvo RIF•
Wren The. ord
Administrative Assistant
Water Quality Permitting Section
cc: David Odom-Odom Engineering, PLLC
ec: WQPS Laserfiche File w/application
D_E Q North Carolina Department of Environmental Quality I Division of Water Resources
Wilmington Regional Office 127 Cardinal Drive Extension K'llmington.North Carolina 28405
910.796.7215

Pr4474.7
Odom
169 Oak Street • Forest City,NC 28043
Engineering PLLC office 828.247.4495 • fax [phone]
July 12, 2021
Mr.John Hennessy
Division of Water Resources
Water Quality Permitting Section -NPDES
Archdale Building—9tn Floor
512 North Salisbury Street
Raleigh, NC 27604
Re: Application/EAA/LG Document Transmittal
For Conjunctive Use Permit Application
Resubmission
On behalf, Cottages of Boone WWTP
Permit No.:ihlEit993574:01—•
Watauga County, NC Jco�`�q �)
Dear Mr. Hennessy
Please find enclosed a revised conjunctive use permit application for The Cottages of Boone WWTP.As you know,
NCDEQ returned the original application for the conjunctive use permit due to the Division of Water Resources'
identification of deficiencies in the Engineering Alternatives Analysis(EAA).This revised submission addresses
previous comments and concerns of the Division.
In addition to an expanded EAA,we have revised the previously submitted application Form D with updated
information, please advise if the department will require the newer Modified Application Form 2-A for this re-
application. Please note that we are recommending implementation of water efficiency measures with a goal of
reducing water usage by greater than 40%,in addition to continued irrigation to the maximum extent possible,and
a maximum permitted discharge of 0.035 MGD,for use only when necessary to prevent bypass of existing storage
during periods of extended inclement weather.
Enclosed please find:
• Three(3)bound sealed and signed copies of the Engineering Alternatives Analysis and Local Government
Review Forms submitted on behalf of Cottages of Boone WWTP;
• NPDES Application Form D;and
• Application Fee($860.00).
A speculative effluent limits letter was issued for this project on January 10,2020.
Thank you for your department's assistance with this important project,and for your department's review and
comment of the enclosed documents. Please direct any questions regarding the enclosed application to me or Pete
Dickerson at 828-247-4495 voice,or email [e-mail] and [e-mail]
Sincerely,
David Odom, P.E.

i
NPDES APPLICATION - FORM D
For privately-owned treatment systems treating 100% domestic wastewaters <1.0 MGD
Mail the complete application to:
N. C. DENR / Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit NCOO (3`Icick
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise,please print or type.
1. Contact Information:
Ownrr Name Wallace Loft, LLC.
Facility Name The Cottages of Boone WWTP
Mailing Address 2711 Centerville Road, Suite 400
City Wilmington
State / Zip Code Delaware, 19808
Telephone Number [phone]
Fax Number [phone]
e-mail Address [e-mail]
2. Location of facility producing discharge:
Check here if same address as above ❑
Street Address or State Road 615 Fallview Lane
City Boone
State / Zip Code NC, 28607
County Watauga
3. Operator Information:
Name of the firm, public organization or other entity that operates the facility. (Note that this is not
referring to the Operator in Responsible Charge or ORC)
Name Wallace Loft, LLC,
Mailing Address 2711 Centerville Road, Suite 400
City Wilmington
State / Zip Code Delaware, 19808
Telephone Number [phone]
Fax Number [phone]
e-mail Address info(wthecottagesofboone.com
1 of 3 Form-D 11/12

1
NPDES APPLICATION - FORM D
For privately-owned treatment systems treating 100% domestic wastewaters <1.0 MGD
4. Description of wastewater:
Facility Generating Wastewater(check all that apply):
Industrial ❑ Number of Employees
Commercial ❑ Number of Employees
Residential ❑ Number of Homes
School ❑ Number of Students/Staff
Other Explain: Apartment Complex 894 Br
Describe the source(s) of wastewater (example: subdivision, mobile home park, shopping centers,
restaurants, etc.):
Apartment complex serving 894 bedrooms, five administrative/clubhouse employees, a fitness center
and a pool.
Number of persons served: QQ
d. Type of collection system
►:� Separate (sanitary sewer only) ❑ Combined (storm sewer and sanitary sewer)
6. Outfall Information:
Number of separate discharge points 1 (Proposed]
Outfall Identification number(s) 01
Is the outfall equipped with a diffuser? Yes (Proposed) ❑ No
7. Name of receiving stream(s) (NEW applicants:Provide a map showing the exact location of each
outfall):
Laurel Fork (Watauga River Basin) - See Attached Map showing proposed outfall location
8. Frequency of Discharge: ® Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs; Duration:
9. Describe the treatment system
List all installed components, including capacities,provide design removal for BOD, TSS, nitrogen and
phosphorus. If the space provided is not sufficient, attach the description of the treatment system in a
separate sheet of paper.
See attached WWTP Permit
2 of 3 Form-D 11/12

I
NPDES APPLICATION - FORM D
For privately-owned treatment systems treating 100% domestic wastewaters <1.0 MGD
10. Flow Information:
Treatment Plant Design flow 9.1085 MOD
Annual Average daily flow 0.044 MGD (for the previous 3 years)
Maximum daily flow 0.094 MGD (for the previous 3 years)
11. Is this facility located on Indian country?
Q Yes ® No
12. Effluent Data
1YEW APPLICANTS:Provide data for the parameters listed. Fecal Coliform, Temperature and pH shall be grab
samples,for all other parameters 24-hour composite sampling shall be used. If more than one analysis is reported,
report daily maximum and monthly average. If only one analysis is reported, report as daily maximum.
RENEWAL APPLICANTS: Provide the highest single reading (Daily Maximum)and Monthly Average
over the past 36 months for parameters currently in your permit, Mark other parameters "N/A".
Parameter Daily Monthly Units of
Maximum Average Measurement
Biochemical Oxygen Demand (BORN) 31.1 2.9 Mg/L
Fecal Coliform <1 <1 #/100 ml
Total Suspended Solids <2.5 <2.5 Mg/L
Temperature (Summer) N/A N/A N/A
Temperature (Winter) N/A N/A N/A
pH 8.79 7.1 su
13. List all permits, construction approvals and/or applications:
Type Permit Number Type Permit Number
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA) Ocean Dumping(MPRSA)
NPDES Dredge or fill (Section 404 or CWA)
PSD (CAA) Other
Non-attainment program (CAA)
14. APPLICANT CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Sean A. Dwyer Director. Wallace Loft, LLC.
Printed name of Person Signing Title
Digitally signed by Sean
A.Dwyer 08 July, 2021
Date:2021.07.08 15:49:38
Signature of Applicant Date
North Carolina General Statute 143-215.6 (b)(2) states: Any person who knowingly makes any false statement representation, or certification in any
application,record, report,plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management
Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article,shall be
guilty of a misdemeanor punishable by a fine not to exceed$25,000,or by imprisonment not to exceed six months.or by both. (18 U.S.C.Section 1001
provides a punishment by a fine of not more than$25,000 or imprisonment not more than 5 years,or both,for a similar offense.)
3 of 3 Form-D 11/12

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PROPOSED DISCHARGE LOCATION
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1111111 Odom P COTTAGES OF BOONE WWTP MARCH 13, 2020
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gineering PROPOSED NPDES
169 Oak Street,Forest City,N.C.28043 DISCHARGE LOCATION
ph:828.247.4495 fax:[phone] SC 1"=100�
NC Firm#:P-0880

ENGINEERING ALTERNATIVES ANALYSIS
for
Conjunctive Use Permit Application
at
Cottages of Boone WWTP
Permit No. WQ0035784
Watauga County, North Carolina
Watauga River TkeCOTTAGES
OF BOONE
Revised July 09, 2021
May 12, 2020
f
Prepared by:
Odom Engineering, PLLC ssss %
rib Odom
169 Oak Street • Forest City,NC 28043
Engineering PLLC office 828.247.4495 • fax [phone]

Table of Contents
1. Executive Summary 1
2. Applicant Information 2
3. Existing Conditions 2
4. Flow Projections 4
5. Alternatives Analysis 5
5.1 Do Nothing Alternative 5
5.2 Conjunctive Use: Irrigate + Discharge to Laurel Fork(Preferred Alternative) 6
5.3 Connection to Municipal System 9
5.4 Increase Wet-Weather Storage Capacity 9
5.5 Reduce Generated Flow 10
5.6 Cover Tanks to Reduce Precipitation Inflow 11
5.7 Increase Irrigation Area or Irrigation Rate 11
6. Alternatives Summary 12
7. Local Government Review . 13
8. Conclusions and Recommendations .. 13
Appendices 14
Appendix A—The Cottages NOV Response, dated April 8, 2021
Appendix B— Daily Detail and Storage Analysis—Winter 2020-2021
Appendix C— Daily Detail and Storage Analysis with 40% inflow reduction —Winter 2020-2021
Appendix D—Additional Storage Tank Evaluation
Appendix E—Navitas Equity Solutions Efficiency & Emission Report,June 2021
Appendix F—Present Worth Evaluation of Alternatives
NPDES Permit No.WQ0035784,The Cottages of Boone WWTP
Speculative Effluent Limits- Laurel Fork, Watauga River Basin
Chronic Toxicity Test Results—The Cottages of Boone WWTP
Local Government Review Form -Watauga County, NC
Local Government Review Form—Town of Boone

1. Executive Summary
The Cottages of Boone ("The Cottages") WWTP seeks a conjunctive use discharge permit to allow
discharge of treated effluent to Laurel Fork, a stream near the WWTP,to supplement irrigation and on-
site storage capacity of the existing permitted system. This request seeks authorization to permit the
Cottages of Boone WWTP to continue disposal of effluent through irrigation to the maximum extent
practical and permissible, and to discharge treated effluent to Laurel Fork only when necessary to
prevent overflow and bypass of existing storage, including during periods of extended inclement
weather when irrigation fields are not available.
Although the system exceeds design capacity requirements for irrigation area and storage capacity for
the residents served, in recent years extended periods of inclement weather(precipitation and
temperature) has resulted in periods where production exceeds storage and application capacity. During
these periods,the WWTP is forced to haul and dispose treated effluent into the Town of Boone WWTP
treatment system, at great expense, and with high risk of overflow of the system.
This Engineering Alternative Analysis (EAA) compares various alternatives for providing additional
treated effluent disposal capacity to reduce or eliminate the need for over the road hauling and
disposal.
The Cottages proposes to implement two of the identified alternatives, as follows:
1. Implement water efficiency upgrades, including replacing existing toilets and shower heads,
installing aerators in bathroom and kitchen sinks, and installing in-unit water meters to monitor
for, identify, and correct leaks. The goal of the proposed water efficiency upgrades, described
further herein, is to reduce water usage at The Cottages by greater than 40%. The Cottages will
begin implementing the water efficiency upgrades as soon as practicable and plans to complete
the upgrades by the end of the third calendar quarter(i.e., September 30, 2021). As discussed
further herein,the proposed water use reduction relieves the demand for treated wastewater
storage capacity, but would not eliminate overflows during extended periods of inclement
weather, as demonstrated based on actual data from January through February 2021.
2. Apply for and obtain a Conjunctive Use NPDES Permit authorizing the limited discharge of
treated wastewater from the WWTP to the nearby Laurel Fork when needed to prevent
overflow of the treated wastewater storage tank, particularly during periods of extended
inclement weather during winter months that prevents irrigation to the existing fields. This
alternative will require obtaining an approximately 150-foot easement across an adjoining
parcel and the installation of a gravity-flow discharge line. The Cottages proposes to begin
implementing the proposed alternative upon receipt of all required permits, including the
requested Conjunctive Use NPDES Permit.
1

2. Applicant Information
The Cottages of Boone WWTP is located at 615 Fallview Lane, Boone, NC 28607, in Watauga
County, North Carolina. The WWTP and irrigation system is operated under Permit No.
WQ0035784.
The Cottages of Boone WWTP is owned and operated by Wallace Loft, LLC, 2711 Centerville
Road, Suite 400, Wilmington, Delaware 19808. Phone [phone], email
[e-mail].
This EAA has been prepared by David Odom, P.E., Odom Engineering, PLLC, located at 169 Oak
Street, Forest City, NC, 28043. Phone [phone], email
[e-mail].
3. Existing Conditions
The Cottages of Boone is a residential apartment complex located just outside of the town
limits of Boone, in Watauga County, North Carolina. Wallace Loft, LLC, owner of the Cottages of
Boone, owns and operates a wastewater treatment plant serving the complex's 894 bedrooms,
five administrative/clubhouse employees, a fitness center, and a pool at The Cottages of Boone,
under NC DEQ-DWQ Permit No. WQ0035784. This permit is for continued operation of a
108,530 GPD domestic wastewater treatment and irrigation facility, as described in the
attached permit. Average three-year flow for the WWTP is 44,000 GPD. Please see figure 1
below, USGS Quadrangle showing the WWTP and proposed discharge location.
Water usage rates prior to the onset of the COVID-19 pandemic and associated stay-at-home
and work-at home orders, water usage at The Cottages averaged around 36,000 GPD. The
water usage approximately increased to about 57,000 GPD during the COVID-19 pandemic with
days reaching and exceeding doubled to around 70,000 GPD. Water usage has not dropped off
significantly since, and The Cottages believes that water usage could continue to be elevated
indefinitely due to societal changes associated with the pandemic.

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3

Currently, disposal of effluent is via drip irrigation system, consisting of approximately 14.39 acres of
drip irrigation area with a mixed hardwood and pine forest cover crop. The treatment system complies
with 15A NCAC 02T .0506(c). This high level of treatment allows irrigation setbacks from property lines
to be reduced to zero feet. The existing system exceeds design capacity for disposal of permitted flow
as detailed in the attached permit. A 1,562,000-gallon bolted steel tank provides 14-day capacity for
wet weather storage.
Irrigation is not appropriate during inclement weather or when the ground is in a condition that will
cause ponding or runoff(i.e., fully saturated or frozen soil surface).
As noted, extended periods of freezing temperatures and high precipitation have at times limited
irrigation to the extent that production of treated effluent exceeds storage capacity. A permit to haul
and dispose treated effluent has been obtained; and during these periods outside contractors must be
employed to haul and dispose treated effluent at the Town of Boone WWTP.This situation was
especially dire during the most recent winter season, December 2020 through February 2021,
Continuous severe weather, in combination with significantly increased wastewater inflow rates in
association with the Coronavirus pandemic and associated stay-at-home and work-at-home orders.
Water usage at The Cottages during this period was almost double that of the comparable previous year
period. Between January 4 and March 23, a total of 1,068,600 gallons of wastewater was pumped and
hauled from the WWTP to the Town of Boone's wastewater treatment facility(the "Town"), with an
associated total cost of$155,400 incurred by Wallace Loft. However, worsening weather conditions on
January 10 prevented haul trucks from accessing The Cottages,which is located 3,400' above mean sea
level. A bypass of treated wastewater began on January 10, 2021 and continued until February 22.
Additional information related to this bypass is provided in The Cottage's response to the NCDEQ's NOV
related to this incident, dated April 8, 2021, and attached here as Appendix A.
4. Flow Projections
The Cottages of Boone WWTP serves only this facility and buildout for the complex is complete. Average
flows for the previous past three years were 44,000 GPD, but, as noted previously, wastewater inflows
were significantly increased in association with the Coronavirus pandemic. Average daily inflow for the
December 2020 through February 2021 study period increased to 57,000 GPD. A reduction toward
previous use levels would be expected as we exit the pandemic, but there will likely be a lasting increase
in wastewater inflows due to societal changes associated with the pandemic. Additionally,The Cottages
has contracted a specialist to design and fast-track implement a water conservation program with a
stated goal of greater than 40% reduction of water use. This conservation program is presented (and
recommended) as one of the suggested alternatives herein, and The Cottages proposes to begin
implementing the proposed water efficiency measures as soon as practicable, and complete
implementation by the end of 3Q21. However, as discussed further below,the water efficiency
measures do not eliminate the need for the requested conjunctive use permit. In view of these
unknowns regarding flow projections,the conservative approach is to use the winter 2020-2021 study
period flows, and the current 3-year average daily flows where applicable.
4

5. Alternatives Analysis
Alternatives considered include the following:
g
1. Do nothing. Continue to pump and haul when irrigation and storage capacity is exceeded.
2. Conjunctive use permit (preferred). Irrigate when conditions permit, discharge to Laurel Fork
only as necessary to prevent overcapacity condition.
3. Connect to municipal system for disposal of untreated effluent.
4. Increase on-site storage.
5. Reduce generated wastewater.
6. Cover tanks to eliminate precipitation inputs.
7. Increase irrigation area and or increase loading rate on existing irrigation areas.
Each alternative is evaluated to determine the following:
• Whether it is technically feasible,
• Whether it is expected to provide a practical alternative to direct discharge, and
• Whether it would be cost prohibitive to implement relative to a direct discharge alternative.
Assumptions: For comparison purposes this study will analyze overall cost of handling wastewater
inflow from The Cottages of Boone, including collection, treatment,through to final disposal of effluent.
Relatively equal treatment process costs exist in all considered alternatives except for the Municipal
Connection,where costs associated with onsite treatment reduced to maintenance of the lift station.
For present worth valuation of alternatives, a 20-year facility lifespan is assumed with a 2.5% current
EPA discount rate. Winter 2020-2021 study period flows and weather conditions are used in the
comparative analyses.
The alternatives considered are each discussed individually below.
5.1 Do Nothing Alternative
Under this alternative,The Cottages of Boone WWTP will continue to pump and haul when
irrigation and storage capacity are exceeded. Wet weather storage at the WWTP includes a
1,560,000-gallon bolted steel tank that provides a 14-day capacity for wet weather storage at
the maximum design capacity, and a 548,439 million gallon 5-day upset tank for emergency
conditions, which also may be used for additional wet weather storage.
Wet weather storage capacity has proven to be sufficient for the spring, summer, and fall
seasons, when irrigation is not limited by freezing conditions or saturated soils from
precipitation.
Annual costs for the do nothing alternative (continued pump and haul) can be estimated based
on the daily operational and weather records for the facility for the most recent winter season.
Based on these records, under the severe climate and high inflow conditions described below,
estimates show that it may be necessary to pump and haul up to 3.1 million gallons per year
under worse-case conditions (or 1.1 million gallons per year assuming a 40% reduction in water
5

usage), as were experienced during the 2020-2021 winter season. Based on this estimated
overage, pump and haul costs for a successful pump and haul season, with all bypasses
prevented, could reach an annual cost of$436,271.
Additionally, under this option, there is a higher likelihood for unintentional overflow and
release of effluent, being dependent on manual observations of storage freeboard, dependence
on availability of outside contractors for pumping, hauling, and disposal of effluent, and safe
road conditions for hauler access.
For purposes of alternative comparison,the present worth estimate for this alternative is based
on actual expenditure of$155,400, plus an assumed annual budget of$10,000 for potential
fines for bypasses.
During the winter 2020-2021 season, due to weather conditions limiting irrigation, storage
requirements for treated effluent exceeded available storage. In an effort to avoid a bypass,
Wallace Loft, owner of The Cottages, arranged for pumping and hauling of excess treated
effluent to the Town of Boone WWTP. Between January 4, 2021, and March 23, a total of
1,068,600 gallons of treated wastewater was pumped and hauled from the WWTP to the Town
of Boone's wastewater treatment facility (the "Town"), with an associated total cost of$155,400
incurred by Wallace Loft. Tables providing daily details of the WWTP operation for December
2020 through February 2021, including inflow and irrigation rates, temperatures, and
precipitation rates, are provided in Appendix B. As shown in the tables, minimum temperatures
throughout December were consistently below freezing, only increasing above 32 °F on
December 12 (37 °F), December 13 (38 °F), and December 22 (33 °F). In addition, snow cover at
the Cottages from a 3 snow event on December 25 lasted for four days. In January it rained 7
out of 10 days, and minimum temperatures were below 32 °F from January 4 through January
26. In addition to freezing temperatures and cumulative precipitation totaling more than 18
inches of rain or snow in January, there was snow cover at The Cottages for 16 out of the 31
days of the month. Inclement weather continued into February, with only two days with
minimum temperatures climbing above the freezing point (February 14 at 35 °F and February 26
at 33 °F). Between February 1 and February 22 there were 13 days of rain or snow, and 8 days
of snow cover at The Cottages.
Estimated present worth for the do-nothing alternative is$7,566,979.This alternative may be
also considered infeasible, due to the high likelihood of unintentional bypass of treated effluent.
5.2 Conjunctive Use: Irrigate + Discharge to Laurel Fork (Preferred Alternative)
Under this approach,The Cottages of Boone WWTP will make application for NPDES conjunctive
use permit with intent to continue irrigation as conditions permit, and discharge excess treated
effluent to Laurel Creek. To explore this alternative, a potential discharge point in the nearby
receiving stream was identified. A review of stream conditions at the proposed discharge
6

location was initiated with USGS and NCDEQ. The Speculative Effluent Limits produced by
NCDEQ suggest that a discharge of up to 0.1 MGD (the approximate permitted capacity of the
WWTP) would be ecologically sound and technically feasible. Please see attached Speculative
Effluent Limits letter dated January 10, 2020. As noted herein, The Cottages is only requesting
authorization for the limited discharge of treated wastewater to Laurel Fork when necessary to
prevent overflow and bypass of existing storage, particularly during extended periods of
inclement weather during the winter months. The Cottages estimates daily flows during such
periods to be approximately 0.035 MGD.
Additional preparatory research included performance of a non-report Chronic Toxicity Test,
with passing results.Test results are also attached herewith.
Please see attached map, Figure 2, showing proposed discharge location.The discharge point
may be reached by gravity flow and is approximately 580 lineal feet from the proposed
connection the WWTP. An easement approximately 150 feet in length will be required into an
adjoining parcel. Acquisition cost for this easement is estimated not to exceed $10,000.
A cost estimate for construction the proposed discharge line is shown below:
COST ESTIMATE
COTTAGES OF BOONE-DISCHARGE LINE
30-Jun-21
DESCRIPTION CSTY UNIT UNIT PRICE TOTAL
I Mobilisation 1 LS $5,000.00 $5,000.00
2 Clearing 0.0/ AC .5,000.00 $350.00
Connect to Existin&Plant 1 LS $5,000.00 5.5,000.00
6-In€h Gate Valves 2 EA $750.00 $1,500.00
� New Manhole§ 3 EA ._ S5.000.00 $15,000.00
6_6"5(1821 PVC Gravity SaWer 580 LF $60.00 $34800.00
7 Silt Pence 600 LF_.. 53.00 $1,800.00
8 Eronet 575 Erosion Control Blanket .-- Z00 LF 53.00 $600.00
9 Outfall Screen Device 1 EA 51,200.00 $1,200.00
10 Trench Rock 5 CY $100.00 $500.00.
11 Seeding 0.07 AC $4,000.00 $280.00
12 Gravel Road Repair 1440 SF $5.00 $7,200.00
13 $0.00
CONSTRUCTION SUBTOTAL $73,230.00
Contingency(10%) $7,323.00
CONSTRUCTION TOTAL $80,553.00
Engineering Services $12,000,00
TOTAL PROJECT ESTIMATE 592.553.0d
This alternative has an estimated initial cost of$102,533 including easement acquisition and
construction of the discharge.The are no additional annual costs over the normal annual
operating costs associated with this alternative.This is a feasible alternative with a total present
worth calculated at$5,091,065.
7

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Sib: 144
APPROXIMA ! .-,. ' `t ''r
ROPOSED DISCHARGE LOCATION
LAUREL FORK t+..
E LATTITUDE 36.19913 1 ), `r., i �,,
LONGITUDE -81.70090 1
E: 1203148.07D `
N: 902231.871 T ,
'
PROPOSED 20 FOOT WIDE UTILITY EASEMENT --. I 4 , ; ,
150 FT LENGTH
3,000 SQUARE FEET TOTAL
a
r mt
4 COTTAGES OF BOONE wWTP _ . fili:"
x PERMIT No. WQ0035784
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Engineering COTTAGES OF BOONE WANT: MARCH 13, 2020
1LLC PROPOSED NPDES
169 Oak Strt et.Forest City.N.C.2113 DISCHARGE LOCATION . -lpa
‘h:R18.2::.1 4l6•195 fax:[phone]
FIGURE 2-PROPOSED DISCHARGE LOCATION
8

5.3 Connection to Municipal System
The Cottages is located outside of the city limits of the City of Boone and at an altitude above
3,400 feet above mean sea level. Based on conversations with the Town Manager and the Public
Works Director for the Town of Boone, and in review of the Town's ordinances, it would be very
difficult to obtain approval for a sewer connection. Among other reasons,the Town's ordinance
would require annexation & zoning, and connection to the Town's water(which is also not
permitted for areas above MSL 3,400' which were not in town limits prior to March 8, 2007.)
Water connection also requires metering of individual housing units and installation of booster
pumps, water storage and telemetry. In addition,the ordinance requires a system development
fee of$7.99per gallon which, for the 108,000 GPD WWTP, would require an initial upfront
payment of$862,920 before implementing the change. For the purpose of this alternative
analysis, we assume that a variance could be obtained allowing connection for delivery of the
untreated wastewater flow, using a pump station, force main and a single meter for flow
measurement.
We would estimate capital costs for this approach at $80,000 for the pump station, $250,000 for
5,000 LF of force main with one highway bore, $40,000 in easement acquisition,for a total
$370,000 construction cost. Additionally, we estimate that the system development fee would
be $867,380 for the 108,530 GPD design flow. Estimated annual cost from the Town of Boone at
the out-of-town treatment rate would be $237,814 for an assumed 50,000 GPD average flow.
Connection to the municipal system, if allowed, would remove the need for onsite wastewater
treatment, and require only maintenance of a small pump station, at an estimated savings of
approximately$750,000 annually.
The total estimated present worth for this alternative, if a variance allowing the connection
were to be approved by the Town of Boone is estimated to be $5,729,023.
In addition to cost, a connection to the Town is not considered practically feasible at this time
due to annexation requirements and political resistance to annexation which is outside of the
control of The Cottages. Even if politically available, annexation of The Cottages would likely
take at least a year to effectuate. For these reasons, connecting to the municipal system is not a
feasible alternative at this time.
5.4 Increase Wet-Weather Storage Capacity
The fourth alternative evaluated the cost and feasibility of increasing the existing wet weather
storage capacity of the WWTP by adding a 2,000,000-gallon capacity, bolted steel storage tank
(86' diameter by 24' height). Due to the mountainous terrain at The Cottages, installing the
additional storage tank would require blasting to remove rock and grading, and the installation
9

of a retaining wall around the tank. Overall, the construction cost for the new tank is estimated
to total more than $1.9 million (or up to $2.2 million with a 25% construction and engineering
contingency). Details of siting and construction of this proposed tank are provided in Appendix
D. It is uncertain whether a 2,000,000-gallon capacity tank would provide adequate storage for a
non-discharge WWTP given the extended periods of precipitation and frozen temperatures
experienced at The Cottages during recent winters.
Initial capital cost for this approach is estimated at$2,200,000, assuming that the tank can be
installed without additional land acquisition. Annual and intermittent costs for this alternative
include pump and valve operation and maintenance, and paint touch-up at 15-year intervals,
approximately$1,500 annually.
The total present worth calculated for this alternative, assuming construction with no additional
land acquisition is calculated at $7,211,916,with no certainty that the additional storage would
be adequate.
5.5 Reduce Generated Flow
Reduction of generated wastewater flow is achieved through reduction of water use.The
Cottages of Boone has contracted a specialist to design a water conservation program with a
stated goal of 40% reduction of water use. Although this program is presented as an alternative
to NPDES discharge,the Cottages intends to initiate a water conservation program even if the
anticipated wastewater reduction is not sufficient to eliminate the need for a discharge permit.
Specifics of the proposed reduction program as recommended by the specialist follow:
"We intend on replacing the shower heads and replacing the toilets as well as reducing
the flow of the faucets. Currently the toilets are 1.6 GPF units.The replacements will be
0.8 GPF units.The kitchen sinks are 2.2 GPM faucets. We intend on adding flow
restrictors that will reduce the flow to 1.0 GPM. Similarly, the bathroom faucets are
currently 1.5 GPM. They will have restrictors installed reducing the flow to 0.5 GPM.
Lastly the current 2.5 GPM shower heads will be replaced with 1.25 GPM heads.The
vendor feels that we should see at least a 40% reduction in water use (and subsequent
wastewater.) ... Additionally, we are requesting to install water sub-meters throughout
the property.These meters can then be used to identify apartment that are wasting
water to help with the conservation efforts.
Capital cost for the proposed reduction program is estimated to be$426,756.
An analysis of anticipated winter storage capacity, using the 2020-2021 Winter historical
records,adjusted for a 40% inflow reduction is provided in Appendix B.This estimate suggests
that with the reduced flow, in weather conditions similar to the historic data, overage would still
be experienced, but that the cumulative winter overage, and associated pump and haul costs
would be reduced by approximately 63%. Estimated annual pump and haul would be $41,958
with a $2,700 reserve for potential bypass fines.
10

The total present worth calculated for this alternative is $6,111,469. Note that this alternative
would not be expected to eliminate the storage deficiency and need for discharge or continued
pumping and hauling.
5.6 Cover Tanks to Reduce Precipitation Inflow
Open top diameters for the currently installed storage tanks are approximately 100 feet for the
14-day tank and 60 feet for the 5-day upset tank. Each tank is approximately 26 feet in height.
Covers for tanks of this height are normally constructed during initial tank construction,
assembled at low elevation and jacked up as side tank sections are added. It would be extremely
difficult and expensive to add covers to these existing tanks due to lack of a sufficiently sized
adjacent flat assembly and craning area and difficulty meeting OSHA requirements for work at
26' height. Estimated cost for the covers, if technically possible to construct would be $250,000
for the large tank, and $100,000 for the 5-day upset tank.
Regardless of cover expense, estimated annual precipitation inflow (60" to 65" in Boone)to the
tanks would not be expected to greatly exceed estimated annual evaporation from the open
tanks (40" to 45").The precipitation inflow with evaporation is insignificant, and the
construction of covers is not feasible. Present worth for this alternative is $5,338,532, with no
expected significant improvement on storage capacity.
5.7 Increase Irrigation Area or Irrigation Rate
Wallace Loft and The Cottages have engaged the services of a soil survey specialist to investigate
and review the site and soils.The intent of this study is to identify any potentially useful
additional areas for irrigation or reclaimed water reuse, and to determine whether application
rates in existing fields can be increased. Although this study has been contracted, it has not been
completed and data is not yet available for inclusion in this application. We have elected to
submit this application and intend to provide the soil study results as a later addendum as time
is of the essence in selecting, permitting, and constructing a feasible solution for the capacity
problem prior to the next winter season.
Identification of additional application areas, or irrigation rate improvements would be expected
to provide for increased available storage at the beginning of the winter season but based on
the weather records from the 2020-2021 Winter season, in similar weather conditions, and
adjusted for 40%water conservation, overages would still expected due to the number of
consecutive days when irrigation could not be used due to temperature or precipitation.
Although it is expected that a discharge or pump and haul would still be necessary, any
improvement in application rate would be helpful in reducing the overage volume, and The
Cottages may implement additional irrigation fields or irrigation rates if supported by the
pending soils report.
11

6. Alternatives Summary
A table summarizing the results of the individual alternatives analyses is presented below, Figure 3. Of
the options considered technically feasible, only the preferred option, conjunctive use, provides a
guaranteed solution to the system storage capacity issues, even with the implementation of the water
efficiency measures.
The do-nothing alternative does not solve capacity issues and has a high estimated present worth cost,
this is not an acceptable alternative.
Connection to municipal system, if feasible, would solve capacity issues with lowest present worth
lifetime cost, but as discussed previously, is not considered politically feasible at this time.
Increasing onsite storage by(2 million gallons) is not technically feasible due to high initial cost and
provides no guaranteed solution to capacity issues. It is estimated that this would not have provided
sufficient additional storage for the 2020-2021 Winter weather and inflow conditions.
A program intended to result in a 40% reduction of water use and generated wastewater is technically
feasible and will be implemented in 3Q21, however this reduction is not expected to be sufficient to
solve capacity issues.
Covering tanks to eliminate precipitation inputs is not technically feasible nor would it significantly
impact system capacity. In other words, precipitation into the tanks has a minimal impact on storage.
As noted, we are awaiting results of a site soil survey,to determine if irrigation areas and/or irrigation
rates can be increased. Due to siting and topography, it is unlikely that significant additional application
areas will be identified, but if it is determined that application rates can be increased,this could be
helpful in ensuring lower tank levels at the beginning of the severe weather season. Lower initial tank
levels could reduce but would not be expected to eliminate system storage issues during extended
periods when irrigation cannot take place.
Recurrmg Costs,..__ ....._
Annual
Alternative Collection and
Alternative Specific Treatment
Alternative Specific Specific Annual Intermittant System Present Worth of Technically Solves
Alternative Capital Cost(5) Costs Costs Operation Alternative($)` Feasible Capacity Issues
1 Do Nothirip 155,400 10,000 320,000 7,566,979 Yes No
2 Conjunctive Use(Irnprate+Discharge) 102,533 320,000 5,091 065 Yes Yes
3 Connect to Municipal System 1,237,380 238,126 50,000 5,729,023 No Yes
4 Iri€r@ase On-Site Storage 2,200,000 1,500 320,000 7,211,916 No No Guarantee
5 Reduce Generated Wastewater 426,756 41,958 3,700 320,000 6,111,469 Yes No
6 Cover Tanks to Eliminate Precp Inputs 350,000 320,000 5,338,532 No No
7 Increase Irrigation Areas/Rates* - waiting Info No Guarantee
FIGURE 3—Summary of Alternatives Analysis
12

7. Local Government Review
Local Government Review Forms have been sent to the Town Manager of Boone, NC, and to
the Watauga County Manager. Responses to the form requests have been included in the
attached appendix.
8. Conclusions and Recommendations
The existing WWTP provides more than sufficient irrigation area for the permitted design
capacity of the WWTP, provided weather allows for the land application of treated wastewater.
The limiting factor and root cause of the WWTP overflows has been, and continues to be, the
lack of sufficient storage capacity during periods of frequent or sustained precipitation and/or
freezing weather in the winter months.
Based on USGS 7Q10 flows, and NCDEQ Speculative Discharge Limits, discharge into Laurel Fork
at up to the permitted flow for Cottage of Boone WWTP, 0.10 MGD would be ecologically
sound and meeting Speculative Effluent Limits would be technologically feasible. A recently
performed passing test for Chronic Toxicity is further indication that discharge of this treated
effluent would be ecologically sound.
It is our recommendation that The Cottages of Boone WWTP implement the water efficiency
measures in 3Q21, and also proceed with NPDES application for conjunctive use to allow
continued irrigation of treated effluent, and supplemented by discharge into Laurel Fork, only
when necessary to prevent bypass of existing storage.
We recommend requesting a permitted discharge flow of 0.035 MGD. This recommendation is
based on the highest monthly average daily flow experienced during the past severe weather
period (58,347 GPD,January 2021), with a 40% reduction applied for the proposed water
consumption reduction program. It is estimated that discharges would approach this flow
amount only under the most severe weather conditions.
With proper operation of the WWTP and improved weather, The Cottages does not anticipate
any further shortage of storage capacity until winter weather returns. We recommend that
every effort be made to complete permitting and construction of the proposed discharge
system prior to the return of winter weather.
13

Appendices
Appendix A—The Cottages NOV Response, dated April 8, 2021
Appendix B— Daily Detail and Storage Analysis—Winter 2020-2021
Appendix C— Daily Detail and Storage Analysis with 40% inflow reduction —Winter 2020-2021
Appendix D—Additional Storage Tank Evaluation
Appendix E — Navitas Equity Solutions Efficiency & Emission Report, June 2021
Appendix F— Present Worth Evaluation of Alternatives
NPDES Permit No. WQ0035784, The Cottages of Boone WWTP
Speculative Effluent Limits - Laurel Fork, Watauga River Basin
Chronic Toxicity Test Results—The Cottages of Boone WWTP
Local Government Review Form -Watauga County, NC
Local Government Review Form—Town of Boone
14

d?
Parker Poe
Fern A. Paterson Atlanta.GA
Partner Charleston.SC
t:704.335.9891 Charlotte,NC
f:704.335.4456 Columbia,SC
[e-mail] Greenville,SC
Raleigh,NC
Spartanburg,SC
Washington,DC
April 8, 2021
Via E-mail [Ion.snider(@.ncdenr.gov]
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
NCDEQ —WSRO
450 W. Hanes Mill Rd., Suite 300
Winston-Salem, North Carolina 27105
Re: Response to Notice of Violation & Intent to Enforce (NOV-2021-PC-0187)
Wallace Loft, LLC; The Cottages of Boone -Wastewater Irrigation System
Permit No. WQ0035784; Watauga County
Dear Lon:
We appreciate this opportunity to respond to the above-referenced Notice of Violation
("NOV") on behalf of our client, Wallace Loft, LLC ("Wallace Loft"), which owns and operates The
Cottages of Boone ("The Cottages").
As you know, The Cottages holds a permit (Permit No. WQ0035784) to operate a non-
discharge wastewater irrigation system. The Permit authorizes the operation of a 108,530 gallon
per day (GPD)wastewater treatment and irrigation facility (the "WWTP"). The WWTP uses a drip
irrigation system consisting of approximately 14.39 acres of irrigation area with a mixed hardwood
and pine forest cover crop, and serves 894 bedrooms, as well as a pool, fitness center, and The
Cottage's administrative and clubhouse employees. As previously reported to NCDEQ, a bypass
of the WWTP occurred between January 10, 2021 and February 22, 2021. In this letter, we
provide additional information regarding the weather and conditions leading up to and during the
previously reported bypass, on-going storage capacity challenges with the WWTP during the wet
and cold winter months, efforts to obtain a National Pollutant Discharge Elimination System
("NPDES") Conjunctive Use permit allowing the direct discharge to Laurel Fork to resolve storage
obtain NPDESConjunctive
capacity issues, and the status of The Cottages continuingefforts to a
pg1
Y
Use permit. We respectfully request NCDEQ's consideration of the circumstances of the bypass,
as well The Cottage's continuing good faith efforts to resolve the WWTP operating challenges
described further herein, and hope that the NOV can be resolved without the need for
enforcement.
PPAB 6221610v2.docx
Parker Poe Adams&Bernstein r[P 620 South Tryon Street Suite 800 Charlotte.NC 28202
t 704.372.9000 f 704.334.4706 www.parkerpoe.corn

April 8, 2021
Page 2
Circumstances Surroundina the Incident
Tables providing daily details of the WWTP operation for December 2020 through
February 2021, Including inflow and irrigation rates, temperatures, and precipitation rates, are
provided in Attachment A. As shown in the tables, minimum temperatures throughout
December were consistently below freezing, only increasing above 32 °F on December 12 (37
°F), December 13 (38 °F), and December 22 (33 °F). In addition, snow cover at the Cottages
from a 3" snow event on December 25 lasted for four days. In January, and the days leading up
to the beginning of the bypass on January 10, it rained 7 out of 10 days, and minimum
temperatures were below 32 °F from January 4 through January 26. In addition to freezing
temperatures and cumulative precipitation totaling more than 18 inches of rain or snow In January,
there was snow cover at the Cottages for 16 out of the 31 days of the month. Inclement weather
continued into February, with only two days with minimum temperatures climbing above the
freezing point(February 14 at 35°F and February 26 at 33°F). Between February 1 and February
22, when the bypass ended, there were 13 days of rain or snow, and 8 days of snow cover at The
Cottages.
In an effort to avoid a bypass, Wallace Loft arranged for pumping and hauling of excess
treated effluent on or around January 4. Between January 4 and March 23, a total of 1,068,600
gallons of wastewater was pumped and hauled from the WWTP to the Town of Boone's
wastewater treatment facility (the "Town"), with an associated total cost of $155,400 incurred by
Wallace Loft. However, worsening weather conditions on January 10 prevented haul trucks from
accessing The Cottages, which is located 3,400' above mean sea level. The bypass of treated
wastewater began on January 10. Photographs of the iced-over roads are provided below:
el!'" 4.,
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PPAB 6221610v2.docx

April 8, 2021
Page 3
Pump and haul operations restarted when roads were sufficiently clear on January 18.
The Cottages acquired a mini excavator, placed fresh gravel on the roads, and contracted a
snowplow vendor to attempt to keep access to the wet weather storage tanks open for trucks.
Throughout the event and after, The Cottages pumped and hauled wastewater to the Town to
minimize the total bypass to the extent that it was able. Despite best efforts, The Cottages was
only able to land apply wastewater from the WWTP at the irrigation fields on one day in January
(January 3), and was not able to land apply wastewater again until February 24.
In addition to the challenges presented by inclement weather, The Cottages have
experienced significant increases in water usage and wastewater inflow rates in association with
the Coronavirus pandemic and associated stay-at-home and work-at-home orders. Governor
Roy Cooper issued Executive Order 121 on March 27, 2020, ordering people in the state of North
Carolina to stay at home for thirty days. The Order took effect on March 30, 2020. During the
month of March 2020, before the stay-at-home order took effect, the average daily water usage
at The Cottages was 36,381 gallons/day. By comparison, in February 2021, as residents continue
to abide by subsequent stay-at-home and work-at-home orders, average water usage has
increased to an average of 78,006 gallons/day, with a maximum daily usage of 112,600
gallons/day on February 18, 2021. In short, as residents continue to stay at home, cook at home,
and recreate at home in response to the on-going coronavirus pandemic, The Cottages has
experienced an approximate doubling of water usage. The wastewater system has been able
to meet the increased water usage and wastewater production rates during warmer months
without issue. However, with inclement weather preventing irrigation of treated wastewater and
iced-over access roads preventing the Cottages from pumping and hauling wastewater to the
Town, the WWTP was not able to keep up with the increased wastewater production and avoid
the bypass.
Additional information regarding the storage capacity at the WWTP, and the feasibility of
addingstorage capacity, is discussed further below in relation to the efforts to permit a solution to
9
the WWTP issues during the cold and wet winter months.
Efforts to Obtain a NPDES Conjunctive Use Permit for the WWTP.
The WWTP began operating in 2013. In the first several years of operation, The Cottages
found that properly treating and disposing of effluent during the wet winter months, frequently with
freezing temperatures, presented greater-than-expected challenges. Wallace Loft engaged
Odom Engineering ("Odom") in October 2019 to assist with the challenges experienced at the
WWTP. Odom's analysis confirmed that operational challenges at the WWTP tracked the
weather, with the system running out of storage capacity during high precipitation and freezing
weather periods in and around January through March, as shown in Figure 1 below.
PPAB 6221610v2.docx

April 8, 2021
Page 4
Figure 1. Comparison of Weather Trends and Remaining WWTP Storage Capacity
November 2017 throu•h March 2020 .
Clear Irrigation Days vs Storage Remaining at End of Month
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Generally, daily inflow to the WWTP varies from 20,000-50,000 GPD. As described further
above, daily averages during the 2020-2021 Coronavirus pandemic have approximately doubled
as residents remain home in accordance with Gov. Cooper's various stay-at-home and work-at-
home orders. Daily irrigation rates vary more widely, from nothing (on days when weather
precludes drip irrigation of wastewater to the irrigation fields), to well above 100,000 GPD.
Importantly, on good weather days, The Cottages can, and frequently does, apply treated effluent
to the irrigation fields at rates at and above 100,000 GPD.
Wet weather storage at WWTP includes a 1,560,000-gallon bolted steel tank that provides
a 14-day capacity for wet weather storage at the maximum design capacity, and a 548,439 million
gallon 5-day upset tank for emergency conditions, which also may be used for additional wet
weather storage. Although The Cottages narrowly managed to avoid exceeding the storage
capacity of the WWTP during the winter months of the first few years of operation, The Cottages
has repeatedly needed to obtain authorizations to haul and dispose of excess effluent to the Town
to prevent system overflow and bypass. Attachment B to this letter provides daily details of
inflow to the WWTP and irrigation rates by field during March 2020, a sample month that saw
significant and frequent precipitation and freezing temperatures. The Table in the attachment
shows that, on good irrigation days, the WWTP is achieving irrigation rates at or above 100,000
GPD. Despite best efforts demonstrated by irrigation flow rates shown in the March 2020
summary, the WWTP did run out of storage capacity in March 2020, and was required to pump
and haul wastewater to Town of Boone's WWTP to avoid a bypass. In 2020, the Cottages
pumped and hauled 569,500 gallons of wastewater to the Town at a cost of $73,500. In 2021,
between January 4 and March 23, The Cottages pumped and hauled a total of 1,068,600 gallons
of wastewater to the Town at a cost of $155,400, and The Cottages would have pumped and
hauled even more wastewater if weather and roads had allowed.
PPAB 6221610v2 docx

April 8, 2021
Page 5
Odom also evaluated the cost and feasibility of increasing the existing wet weather storage
capacity of the WWTP by adding a 2,000,000-gallon capacity, bolted steel storage tank (86'
diameter by 24' height). Due to the mountainous terrain at The Cottages, installing the additional
storage tank would require blasting to remove rock and grading, as well as the construction of a
retaining wall around the tank. Overall, Odom estimates the construction cost for the new tank
would total more than $1.9 million (or up to $2.2 million with a 25% construction and engineering
contingency). Aerial photographs showing the proposed plans and an estimated cost schedule
prepared by Odom are provided in Attachment C. Further, it is uncertain whether a 2,000,000-
gallon capacity tank would provide adequate storage for a non-discharge WWTP given the
extended periods of precipitation and frozen temperatures experienced at The Cottages during
recent winters.
Connecting The Cottages' WWTP to the Town of Boone's municipal system was also
deemed to be technically infeasible due to, among other things, the prerequisite annexation and
zoning requirements under the Town's existing ordinances.
Odom and Wallace Loft therefore determined to apply to NCDEQ for a NPDES
Conjunctive Use permit that would allow The Cottages to directly discharge treated wastewater
to Laurel Fork, a small stream on property adjacent to the existing WWTP. Note that the purpose
of the permit was gag to allow the Cottages to directly discharge to Laurel Fork during periods of
inclement weather when land application of treated wastewater through the drip irrigation system
Is not available and wet weather storage capacity is exhausted. In pursuit of the NPDES
Conjunctive Use permit, Wallace Loft applied for and was issued approved speculative effluent
limits for a 0.1 MGD NPDES Conjunctive Use permit on January 10, 2020. Odom also applied
for and received a zoning consistency determination for the requested NPDES Conjunctive Use
permit from Watauga County on April 27, 2020. The Cottages submitted its application for the
NPDES Conjunctive Use permit, including an Engineering Alternatives Analysis ("EAA") prepared
by Odom, on May 20, 2020.
In the fall and winter of 2020, NCDEQ raised questions and requested additional
information regarding the EAA, and ultimately returned the application for a NPDES Conjunctive
Use permit to Wallace Loft in a letter dated January 19, 2021. In follow-up correspondence from
Nathaniel Thornburg, Branch Chief of NCDEQ's Non-Discharge Branch, NCDEQ indicated that
the following specific analyses should be conducted to further evaluate to potential non-discharge
option prior to submitting a revised application for the NPDES Conjunctive Use permit: (1)
reducing the amount of generated inflow to the WWTP; (2) increasing storage capacity of the
WWTP; (3) increasing the irrigation area of the WWTP; and (4) increasing the loading rate to the
existing irrigation areas. Odom and The Cottages are gathering information to provide responses
to these four items. In particular, a soil scientist has been engaged to evaluate the existing
irrigation fields and whether there is any potential to increase land application rates at the existing
irrigation fields or expand the irrigation areas. The soil scientist's report and findings should be
complete by mid-May.
Importantly. Odom and The Cottages believe that the existina WWTP provides more than
sufficient irrigation area for the permitted desian capacity of the WWTP, provided weather allows
for the land application of treated wastewater. The limiting factor and root cause of the WWTP
overflows has been, and continues to be, the lack of sufficient storage capacity during periods of
frequent or sustained precipitation and/or freezing weather in the winter months. As discussed
above, the estimated cost to install an additional 2,000,000-gallon capacity storage tank is
between $2 million and $2.2 million.
PPAB 6221610v2.docx

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Cottages of Boone
Daily Detail-December 2020
Weather Observations Snow/Ice/ Tank Freeboard(Ft)
Date Temp(F) Rain Snow Hail on Irrigation By Field(Gallons) Main(26') 5-day(26')
-
Year Month Day Max. Min. (in) (in) Ground Inflow(Gallons) 1 2 3 4 5 6 Total 1,562,000 Gal 548,000 Gal
2020 12 1 T 46 23 0.04 OLIO T 61,273 - - - - - 6.0 22.0
2020 12 2 W 24 20 0.10 100 1.0 62,307 - - - - - - - 6.0 22.0
2020 12 3 Th 42 15 0.00 0.00 10 56,608 - - - - - - - 6.0 22.0
2020 12 4 F 56 15 0.00 0.00 0.0 25,103 - - - - - - - 6.0 22.0
2020 12 5 Sa 49 32 120 0.00 0.0 64,997 - - - - - - -
2020 12 6 Su 35 30 0.00 0.00 0.0 64,997 8,000 8,000 8,000 8,000 - - 32,000
2020 12 7 M 49 32 T T T 64,997 - - - - 8,000_ 950 8,950 6.0 22.0
2020 12 8 T 37 21 T T 0.0 61,738 - - - - - - - 6.0 22.0
2020 12 9 W 31 24 0.00 0.00 0.0 60,215 - - - - - - - 6.0 22.0
2020 12 10 Th 44 27 0.00 0.00 0.0 56,789 - - - - - - - 6.0 22.0
2020 12 11 F 59 26 0.00 0.00 0.0 24,735 16,000 15,518 8,242 9,162 15,214 12,532 76,668 6.0 _ 22.0
2020 12 12 Sa 57 25 0.01 0.00 0.0 58,429 17,469 26,620 25,883 28,000 27,150 27,626 152,748
2020 12 13 Su 56 37 0.64 0.00 0.0 58,429 17,469 26,620 25,883 28,000 27,150 27,626 152,748
2020 12 14 M 60 38 0.07 0.00 0.0 58,429 - - - - - - - 6.0 22.0
2020 12 15 T 44 22 0-18 0.00 0.0 58,657 - - - - - - - 6.0 22.0
2020 12 16 W 39 21 LOS 0.00 T 57,072 - - - - - - -
2020 12 17 Th 36 26 T T 0.0 57,078 - - - - - - - 6.0 22.0
2020 12 18 F 35 23 0.00 0.00 0.0 56,959 - - - - - - - 6.0 22.0
2020 12 19 Sa 35 17 0.00 0.00 0.0 49,454 - - - - - - -
2020 12 20 Su 38 16 0115 0.00 0.0 49,454 - - - - - - - _
2020 12 21 M 50 30 0.00 0.00 0.0 49,454 8,000 8,000 8,000 9,870 8,236 8,000 50,106 6.0 22.0
2020 12 22 T 48 33 0.00 0.00 0.0 45,277 - - - - - - - 6.0 22.0
2020 12 23 W 43 21 006 0.00 0.0 46,218 - - - - - - - 6.0 22.0
2020 12 24 Th 45 22 1.04 0.00 0.0 36,580 - - - - - - -
2020 12 25 F 48 12 003 230 311 36,580 - - - - - - -
2020 12 26 Sa 14 8 0.00 T 30 36,580 - - - - - - -
2020 12 27 Su 33 8 0.00 0.00 3.0 36,580 - - - - - - -
2020 12 28 M 43 15 0.00 0.00 ]A 36,580 - - - - - - - 6.0 22.0
2020 12 29 T 41 25 0.00 0.00 0.0 33,907 - - - - - - - 6.0 22.0
2020 12 30 W 51 24 0.00 0.00 0.0 54,225 6.0 22.0
2020 12 31 TH 51 24 0.00 0.00 0.0 60,889 - - - - - - - 6.0 22.0
Month Ttl. 1,580,590 66,938 84,758 76,008 83,032 85,750 76,734 473,220
Avg.Daily 50,987 15,265

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Engineering
PLLC
COTTAGES AT BOONE
TWO MILLION GALLON TANK COST ESTIMATE
APRIL 2021
Item Description Quantity Unit Unit Price Cost
1 Grading 15000 CY $15.00 $225,000.00
2 Rock 100 CY $100.00 $10,000.00
3 Retaining Wall 8,750 SF $25.00 $218,750.00
4 Piping 1 LS $35,000.00 $35,000.00
5 Tank Installation 1 LS $1,500,000.00 $1,500,000.00
CONSTRUCTION SUBTOTAL $1,988,750.00
5 Construction Contingencies/Engineering(25%) $198,875.00
CONSTRUCTION TOTAL $2,187,625.00
TOTAL PROJECT ESTIMATE $2,200,000.00

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L)ESIG,V NOT RELEASED FOR # I O d O M NOT LOCATION: BOONE. NC DATE.l aEE
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CONSTRUCTION \LEss [ Engineering FOR PROJECCWM PED
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1PPROb'ED: / 169 Oak street,Forest City,N.C.28043 DESCRIPTICet PROPOSED ROARING WAIL for
INI9iKs DATE ph:828.247A495 fax [phone]
NC Fkm4 TIER 2 MG WASTEWATER TANK 19162 2 OF 2 A
:4495

Appendix B-Daily Detail and Storage Analysis-Winter 2020-2021
Cottages of Boone
Daily Detail.-December 2020
Overage Projections
f Cumulative Volume Estimated Stored Volume
Weather Observations Snow/Ice/ Tank Freeboard(Ft) 1 Inflow Outflow Overflow
Date Temp(F) Rain Snow Hail on Irrigation By Field(Gallons) Main(22') 5-cloy(22') I Gals (Max.2,110,000 gal) or Pump
Wear Month Day Max. Mar. (in) (in) Ground Inflow(Gallons) 1 2 3 4 SI 6 Total 1,562,000 Gal 543,000 Gal 1 850,000
•
2020 12 1 T 46 23 0334 0.1D 4 61,273 - - - - - 6.0 22.0- 61,273 • 911,273 • 911,273
2020 12 2 W 24 In 0.10 100 12) 62,307 - - - - - - 6.0 220 62,307 - 973.580 - 973,580
2020 12 3 Th 42 15 0.00 0.00 Lb 56,608 - - - - - - 6.0' 22.0' 56,608 - 1,030,188 - 1,030,188
2020 12 4 F 56 15 0,00 0.00 0.0 25,103 1 - - - - - 6.0 22.0 25,103 - 1,055,291 - 1,055.291
2020 12 5 Sa 49 32 L20 0.00 0.0 64,997' - - - - - - ) 64,997 - 1,120,288 1,120,288
2020 6,Su 35 30 0.00 0,00 0.0 64,997 8,000 8,000' 8,000 8,000 - - 32,000 64,997 32,000 1,153,285 - 1,153,285
2020 7 M 49 32 T 4 T 64,997 - - - - - $® 950 8,950 6.0 22,0 64,997 8,950 1,209,332 • 1,209.332
2020. 8 P 37 21 T T 0.0 61738 - - - - - - - 6.0. 22.0'I 61,738 - 1,271,070 - 1,271,070
2020. • 941Al 31 24 0.00 0,00 0.0 60,215 - - - - - - - 6,0 22.01 60,215 - 1,331,285 - 1.331,285
2020 - 10 Th 44 27 0.00 000 0,0 56,789 - - . - - - 6,0 22 01 56,789 - 1,388,074 1,388,074
2020 .- 11T 59 ffi 0.00 0.00 0.0 24,735 16,000 15,518 8.24T 3,,183 353114 1532 Win 6.0 22.0 24,735 76,668 1,336.141 - 1,336,141
2020 12 12 Sa 57 25 0.01 0.00 0.0 58,429 17,469. 26,620 25,.883 PAM v„astm 257,622 952,70 E 58,429 152,748 1,241,822 • 1,241,822
2020 12 13 Su 56 37 0.64 0.00 0,0 58,429 17,469 26,620 25,883 XV= 7:4390 27,826 15 MS ' 58,429 152,748 0,147,503 - 1.147,503
2020 12 14 M 60 38 0:07 0.00 0.0 58,429 - - - - - - - 6.0' 22.0( 58.429 1,205,932 - 1,205,932
2020 12' 15 T 44 22 0.18 0.00 0.0 58,657 - - - - - - - 6.0' 22.01 58,657 - 1,264,589 - 1,264,589
2020 12 16 W 39 21 1105 000 T 57,072 - . - - - - - 57,072 - 1,321,661 - 1,321 661
2020 12 17 Th 36 26 T 4 0.0 57,078 - - - - - - - 20 22.011' I 57,079 - 1,378,739 - 1,378.739
2020 12 18 F 35 23 0.00 0.00 0,0 56,959 - - - - - - - 6,0' 22.0 56,959 - 1,435,698 - 1,435,698
2020 12 19 Sa 35 17 0.00 0.00 0.0 49,454 - - - - - - - ) 49,454 - 1,485,152 - 1,485,152
2020 12 20 Su 38 16 0.88 0.00 0.0 49454 - - - - - - - 44,454 - 1,534,606 - 1,534,606
2020 12 21 M 50 30 0.00 0.00 0.0 49,454 1 8,000 83000- 8,000 9,870 8,236. 806201 50)288 6.0 22.0) 49,454 50,106 1,533,954 - 1,533,954
2020. 12 22 T 48 33 0.00 0.00 0.0 45277 - - - - - - - 6.0' 22.01 45,277 - 1.579,231 - 1,579,231
2020, 112 23 W 43 21 004 0.00 0.0 46,218 - - - - - - - 6.0. 22.0 46,218 - 1,625,439 7,625,449
2020, 12 24 Th 45 22 2706 0.00 0.0 36,580 - - - - - - - 36,580 - 1,662.029 - 1,662,029
2020 12 25.F 48 12 023 2.50 30 36,580 - - - - - - - 36,580 - 1,698.609 - 1,698,609
2020 12 26 Sa 14 a 0.00 4 30 36,580 - - - - - - - 36,580 - 1,735,189 - 1,735189
2020 12 27 Su 33 8 0.00 0.00 310 36,580 - - - - - - - 36,580 - 1,771,769 • 1,771,769
2020 12 28.M 43 15 0.00. 0.00 110 36,580 - - - - - - - 6.0 22.0. 36,580 - 1,808,349 • 1,808,349
2020' 12 29 T 41 25 0.00 0.00 0.0 33,907 - - - , - - - - 6.0 22.0 33,907 - 1,842,256 - 1,842,256
2020 12 30 W 51 24 0.00 0.00 0.0 54,225 - - - - - - - 6.0 22.0 54,225 1,396,481 1,896,481
2020 12 31 TH 51 24 0.00 0.00 0.0 60,889 - - - - - - - 60 22.0 60,889 - 1,957,370 - 1,957,370
Month Ttl. 1,580,590 66,938 84,758 76,008 83,032 85,750 76,734 47.3,220' 1 Total Month Est Over: I -
Aug.Daily 50,987 15,265 Total Cumulative Lot Over -
Water Use(Gals) 1,987,600 ff.(Assumed''begteeing of month stored volume 850,000 Gal

Append106-Daily Detail and Storage Analysis-Winter 2020-2021
Cottages of Boone
Daily Detail-January 2021
Overage Projections.
• Cumulative Volume Estimated Stored Volume
Weather Observations Snow/Ice/ Tank.Freeboard(Ft) ] Irr'.ow Outflow Overflow
Date i Temp(F) Rain Snow Hail on Irrigator By Field(Gallons) Maio(221' 5-day(22'1 Gals (,Maw 2,110,000 gal) or Pump
Year Month Day ' Max. Min. In) (in) Ground Inflow(Gallons) 1 2 3 4 5 6 Total 1,562,000-Gal 548,000 Gm 1,957.370
2021 1 1 F 60 39 0136 0.00 00 57,872 - - - - I 57,872 2,015,242 2,015,242
2021 1 2 Sa. 48 34 8148 0.00) 0.0 57,872 - - - - l 57,872 2.073,114 2.073.114
2021 I 3 Su 59 39 0.00 0.001 0.0 57,872 9338 BNB 7,972'. 8668 9,234' 8,000 'Li 1_3. 57,872 42 213 2088773 2,088.773
2021 1 4M - 42 30 T T T 57,872 - - - - 1.5 4.5 57,372 2146645 36,645 2,110000
•
2021 1 5 T 42 3D T 0.001 0.0 57,682 - - - - 1.5 45 57,682 2,169682 57,682 2,110,000
2021 1 6 W 38 26 004 0.001 0.0 57,131 - - - - - 1.3 1 6 57,131 - 2,167,131 57,131 2,110,000
2021 1 7 Th 34 23 0.00 0.001 0.0 35,815 - - - - - 0.7 1 3 35,815 2,145,81'S 35,815 2,110,000'..
2021( 1 8 F 37 21 035 100 40 55,838 - - - - 55,838 2,165,636 55,338 2110,000
2021 1 9 Sa 33 25 0_Il5 2.10 632 55,838 - - - - - 55,838 23166,836 55,838 2,110,000
2021 1 10 Su 29 12 0.00 0.00 50 55,838 - - - - - 55,838 2,165,838 55,838 2,110,000
2021 1 11`uI 41 11 0.00 0.00 40 52,196 - - - - - 0.0' 0.2 52196 2,162,156 52,196 2,110,000
2021 1 12 T ' 34 21 0.12 1.D0 40 50.,617 - - - - - 0.0' 0.2 50.617 2,160617 50,617 2,110,000
2021 1 13 W 37 17 000 0-001 30 55,212 - - - - - 0-0 0:2 55212 2,195,212 55,212 2,110,000
2021 1 14 Th 51 16 0-00 0-001 20i 48,622 - - - - - 0.0 OS ' 48,622 2,158622 48,622 2,110 000
2021 1 1'.5 F 51 22 0.00 0.00 10 67,673 - - - - - 0.0 0.2 67,673 - 2,177,673 67,673 2,110,000
2021 1 16 Sa 36 23 T T T 67,673 - - - - 67,673 - 2,177,673 67,673 2,110,000
2021 1 17 Su 30 25 O02 1D0 00 67,673 - _ - - - 67,673 2,177,673 67,673 2110,000
2021 1 18.M 1 36 26 0.12 2.50 30 67,673 - - - - 0.0 0.2 67,673 2,177,673 67,673 2,110,000.
2021 1 150 31 26 7 0 001 T 52,839 - - - 0.0 0,2 52,839 2,162,839 52,839 2,110,000
2021 1 20.W 42 26 0.00 0.00 T 64,205 - - - - 0.0 0.2' 64„205 2,174,05 64,205 2,110,0002021 1 21 Th 39, 26 T 1,013 0.0` 25,979 - • - - 0.0 0.2 25,979 2,135,979 25,979 2,110,000
2021 1 22 F 37 32 T 0.00 0.0 67,469 - . - 0.0 0.2 67469 2,177,469 67,469 2,110,000
2021 1 23 Sa 44 26 0.00 0.00 0.0 66,843 11 66,843 2,176,343 66,843 2,110,000
2021 1 24 Su 39 18 0.00 0.00 0.0 66,843 I - - - - 65,843 2,176,643 66,843 2,110,000
2021 1 25,M 44 23 T T 0.0 66,843 - - - - - 0.0 0.1 66,843 2,176,843 66,843 2.110,000
2021 1 24 T 49 38 055 0-55 0.0 66,674 - - - - - 0 0 0.2 66.674 2176,674 66,674 2,110,000
2021 1 27 W 60 37 0.00 0.00 0,0 65,828 - - - - 0.0 0.2' 65,829 2,.175,828 65,828 2,110,000
2021 1 28.Th 56 23 0-18 0.18 T 36,351 - - - - 0.0 0.2 36.351 2,116,351 36,351 2,110,000
2021 1 29 F 27 14 T T T 63,851 - - - - 0.0 0.2 63,851 2,173,551 63,851 2,110,000
2021/ 1 30 Sa 31 14 0.00 0,00 0.0 69,026 - - - - - - - 69,026 - Z179,026 69,026 2110,000
2021 1 31 Su 36. 14 080 400 69,026 - - - - - - - 69,026 2,179,028 69,026 2,110000
Month Ttl. 1,808,746 9,333 8,000 7,972 3,669 9,234 8,000 42,213 Total Month Est Over. 1,613 903
Avg,Daily 58,347 1,362 Total Cumulative Est Over 1,613 903
Water Use(Gals) 2,302,267

Appendiw.B-Daily Detail and Storage Analysis Winter 2020-2021
Cottages of Boone
Daily Detail February 2021
Overage Projections
Cumulative Volume Estimated Stored Volume
Weather Observations 15 w/Ice/f Tank Freeboard(Ft) Ih813w Outflow Overflow
Date Temp(T) R.'' _ Hail on 'rogation By Feld(Gallons) Ma (22') 5 day(22') I 946 1Mar.2,110,000 gal) or Pump
Year!Month 0a9 Max- Min. ' Ground Inflow(Gallons) 1 2 3 4 5 6 Total 1,562 000 Gal 548,000 Gal , 2,110,000
2021. 2 1 M 37 19 '9.18 200 65,,026 - - - - - 0.0 0.2 69026 2,179026 69,026 2,110,000
2021. 2'' 2 T 32 17 005 3D 71,422 - - - - - 0.0 0.2 71,422 2,181,422 71422 2,110,000
Z0211 2 3OF 23 17 T - T 71,402 - - - - - - 0.0 02 71,422 2,19IlA22 71,422 2,110,000
2021 2 4 88, 30 17 0.00 ;I 0..0 74,325 - - - - - - 0.0 021v1 74,325 2,184,325 74,325 2,110,000
2021 2 5 r 44 17 0.0 53,012 - i 0.0 0.2 53,012 2,163,012 53,012 2,110,000
2021 2 -- 44 28 0.00 0.0 65,826 , - - - 65,828 2,175,828 65,828 2,110,000
2021 21 7,fs 41 16 023 - .. 310 65,828 - - . - 65828 2,175,828 65,828 2,110000
2021 2 BYVI 37 15 0.00 9.00. ILO 65,828 - - - - 0.0 0.2 65,823 2,175,828 65,828 2,110,000
2021 2 9T 43 30 0.00 0.00, 1.0 69,042 - - - 0.0 02, 69,042 2,179042 69,042 2,110,000
2021 2 10 3 44 29 0.00 0.00 0,8 20,069 - - . 0.0 0.2; 20,069 2,130,069 20,069 2,110,000
2021 2 51 28 0.00 0 001 0.0 72,336 - - - - - 0..0. 0.2 72,336 2:182,336 72,336 2,110,000
2021 2 12'0 49 27 025 0.001 0.0 68,322' - - - - - 0,0' 0,21 68,322 2,178,322 68,322 2,110,000
2021 2 13 5a 32 32 169 0.00, T 67',048. - - - - 67,043 2,177,048 67,048 2,110,000
2021 2 14 53 39 35 '245 0.00' 0.0 67,048' - - - - 67,043 2,177,048 67,048 2,110,000
2021 2 15 M 42 22 0.18 0.00'. 0.0 67,049 I ' n - - - 0.0 0,2 67,048 2,177/048 67,049 2,110,000
2021 2 16 T 37 31 0.45 0 001 00 67,589 - - - - - 0.0 0.2 67,589 - 2,177,509 67,589 2110.000
2021 2 17 0'' 36 17 T 0.00 1 0.0 32,212 - - - - - 0.0 0.2 32,212 - 2,142,212 32,212 2,110,000
2021 2 111111, 36 18 0.26 0.00, T 94,634 - 1 - - - - 0.0 0.2 94,634 - 2,204,634 94,634 2.110000
2021 2 19 T 36. 311 1 64 0 001 0.0 45,246 - 1 - - - - 0.0 0,2 45,246 2,155,246 45,246 2,110 000
2021 2 20 Sa 36 17 0.00 0 001 0.0 65.,947 ) - - - I} 65,947 - 2,175,947 65,947 2,110,000'
2021 2i 21 Su 32 15 0.00 0.001 0.0 65,947 1 - - - - j 65,947 - 2,174,947 65,947 2,110,000
2021 21 22 M 39 15 0.00: 0.00 T 65,947 t - - 0.0 0.2 65,947 - 2,175,947 65947 2,110,000 1
2021 2 23 T 46 32 029 0.001 0.0 65,193 - - - - 0.0. 0.2 65,193 - 2115,193 65,193 2,110,000
2021, 21 24 W 53 31 0.00 0.001 0.0 32,520 14,856; 16,000 16,001 L6,000 16,000 10,542 89,398 0.2 0.2 32,520 89,399 2,053,122 2,053,122
2021. 2 2510. 64 29 0.00 0.001 0.0 71,007 23,616; 24,000 131116 16,000 16,000 21,436 119,248 1.1 02' 71,007 119,248 2.004,881 - 2,004,881
2021 2 26 6 5 33, 0.00 0.001 0.0 63,263 16,000 I 8,470 03,726 16,000 16,000 16,000' 86,196' 1.5 0.2 63,263 86,196 1,981948 - 1,981948
2021 2' 27 5a 41 31 014 0.001 0.0 67,118 20,000 I 20,000 20,000 20,000 24,000 18,000 122,000 i 67,118 122,000 1,927066 - 1,927,06u
2021 2 2186 60 31 0.00 0.001 0.0 67,116 20,000 20,046' 20046, 21,216 24,000 18,372 123680 t , 67,118 123680 1,870,504 1,870,504:
Month Ttl. 1,771,345 94,472 88,516 87,968 89,216 96000 84,350 540522 Total Monet Est Over: I 1,470,319
Avg.Daily 63,262 17,436 ' Total Cumulative Est Over 3,084,222
Water Use(Gals) 7,184,163.

Appendix c-Daily Detail and Storage Analyse-with 40%Inflow reduction-Winter 2020-2021
Cottages of Boone
Daily Detail-December 2020
Overage Projections with 40%Water Use Reduction
Cumulative Volume Estimated Stored Volume
Weather Observations Snow/Ice/ Tank Freeboard(Ft) Reduced Inflow Outflow Overflow
i!!!! Date Temp(F) Rare Snow Hail on Irrigation By Field.(Gallons)', Main(22') 5-day(22') d (60%of actual)Gals (Max,2,110„000gal) or Pump
Year. Month Day Max. Min. (in).. (in) Ground. Inflow(Gallons) 1 2 3, 4 5, 6 Total' 1,562,000 Gal 548,000 Gal 850,000
2020 12 1 T 46 23 0.04 0.10 T 61,273 - - - - - 6.0 22' 36,764 • 886,764 - 886,764
2020 12 2 VV 24 25 510 100 Ile 62,307 - - - - - - - 6.0 229 37384 - 924,148 - 924,148
2020. 12 3 Th 42 15 0.00 0.00' LA 56,608 - - - - - - - 6.0 22o, 33,965 - 958,113 - 958,113
2020 12 4 F 56 15 0.00 0,00. 0.0 25,103 - - - - - - 60 220 15,062 • 973,175 - 973,175
2020' 12 5,Sa. 49 32 120 0,00 0.0 64,997 - - - - - - . 38,998 • 1,012,173 - 1,012,173
2020. 12 6 5u 35 3D 0.00 0.00'' 3.0 64,997 8,000 8,000 8,000 8,000 - - 32,000 38,998 32,000 1,019.171 - 1,019,171
2020 12 7'M 49 32 T T T 64,997 - - - - 8,0000 950 8,950 6.0 718 38,998 8950 1,049,219 - 1,049,219
2020 12 8 T 37 21 T T 0.0 61,738' - - . . - - - 6.0.' 22.0' 37,043 - 1.086,262 - 1,086,262
2020. 12 990' 31 24 0.00 0.20 0.0 60,215 - - - - - - • 6.01 22.01 36,129 - 1,122,391 - 1,122,391
2020 12. 130195 44 27 0.00 0.00 0.0. 56,789 - - - - - - - 6.0 22.0 34,073 - 1,156,464 - 1,156,464
2020 L2 00 IF 59 26 0.00 0.00 0.0 24,735 16,000 2592 5242' 9,162 15,214 12,532 76,668 6.0 22.0 14,841 76,668 1,094,637 - 1,094,637
2020 12 1.7 8w 57 25 501 0.00 0.0 58,429' 17,469 238920 25583 28,000 27,150. 27,626 152,744 35,057 152748 976,947 - 976,947
2020 12 1.36i6 56 37 0,64 0.00 0.0 58,429 177,69 26,629 2,5.,853 28,020 27,150 27,626 152,740 35,057 152,748 859.256 - 859,256
2422 22 144921 60 38 8.07 0.00 0.0. 58429 - - - - - - - , 6.0 220 35.057 - 894,314 - 894,314
12 1S 2D20 IT 44 22 0.16 0.00 0.0 55652 - - - 6.0 IPal 35,194 929508 929,508
2020 12 I6 h8L' 39 21 116 0.00 T Y11172 - - - - - - - 34,243 • 963,751 - 963.751
2020 12, 17!TM 36. 26 T T 0.0 52,,028 - - - - - - - 6.0 22.0) 34,247 997,998 - 997,998
2020 S F� 35 23 0.00 0.00 0.0 56,959 - - - - - - - 6.0 22_0 34,175 - 1,032,173 - 1,032,173
2020 3'0a 35 17 0.00 0.00 0.0. 49,454 - - - - - - - 29,672 - 1,061,846 - 1,061,846
2020 - 2104 38 16 m26 0.00' 0.0 49,454 - - • - - - - 29,672 - 1,091518 - 1,091,518
2020' 12 21'M 50 30 0.00 0.00 0.0 49,454 8 8,000 3,000 3570' 8,236 8,000 59,,0.06 6.0 29,672 50106 1,071 084 - 1,071.084
2020 -2 22 T 43 33. 0.00 0.00 0.0 45,277 - - - - - - 6.0. _'0 27,166 - 1,098,251 - 1,098,251
2020 .2 23 W 43 21 0.04 0.00 0.0 46,218 - - - - - - - 6.0 2201 27,731 - 1,125,981 1.125,981
2020 24 Th 1 45 22 254 0.00 0.0 36,591 - . - - - . . 21,948 1.147,929 - 1,147,929
2020 -_ 25.F 1 48 1P 0.93 2.50 3D 36,580 - - - . - - - 21,948 - 1,169877 - 1,169,877
2020 12 269a, 14 8 000 T 310 36,580 - - - - �1 - - ' 21,948 - 1.191,825 - 1,191,825
MO 12 27,Su: 33a 8 0.00 0.00 3.10 36,580 - - - - - - - 21,948 - 1,213,773 - 1,213,773
2020 12 28'.le 43 15 0.00 0.00 110 36,580 - - . - - - - ...., 21,948 - 1,235,721 - 1,235,721
2020 12 201 41 26 0.00 0.00 0.0 33,907 - - - . - - - .,.. 22.0. 1 20,344 - 1,256,066 - 1,256,066
2020 12 30036 51 24 0.00 0.00 0.0 54,225 - - - - - - - 22'.0' 32,535 - 1,288,601 - 1,288,601
2020 12 31 LW 51 24 0.00 0.00 0.0 60,889 - - - - - - - 6.0' 22-0 , 36,533 - 1,325,134 - 1,325,134
Month Ttl. 1,580,590 66,938 84,758 76,008 83,032 85,750 76,734 473,220 Total Month Est Over.
Avg.Daily 50,987 15,265 ( Total Cumulative Est Over -
"Assumed beginning of month stored volume 850,000 Gal

Appendix C Daily Detail and Storage Analysis-with 40%Inflow reduction-Winter 2020.2021
Cottages of Boone
lady Detail January 2021
Overage Projections with 40%Water Use Reduction
Cumulative Volume Estimated Stored Volume
Weather Observations. Snow/Ice/ Tank Freeboard(Ft) Reduced.Inflow Outflow Overflow
Date Temp(F) Rain Snow, Hal on Irrigation By Field(Gallons) Maul(22'):- 5-day(22') (60%of actual)Gals (Max.2,110.000 gal) or Pump
year' Month Day Max. Min. (in) ( ) Ground Inflow(Gallons), 11 2 3 4 5 6 Total 1,562,000 Gal 546000 Gai 1,325,134
2021) 1 60 39 0116 0.00' 0.0 57,872 - ) _ - - - - 34,725 - 1.359857 1,359857
2021 1 2 Se 48 34 084 0.00 0.0 57,872 - - - - - - - 34523 - 1,394,58U 1,394,580
( 2021 1 3 Su 59 39 0.00 0.00 0.0 57,872 5,338 8,000 7,972 3,669 9,234 8,000 42,213'' 34,723 42,213 1387,091 1,387 091
2021 1 4J4 42 30 T T T 57,872 1.5 4.5 34,723 1,421,814 1,421,814
2021 1 5 T 42 30 T 0.00 00 57,682 - - - . - - - - 1.5 -1 I. , 34,609 1,456,423 1,456,423
2021 1 6 YW 38 26 0.04 0.00 0.0 57,131 - - - Lit 4.'- 34.279 1,490,702 - 1,490,702
2021 1 719 34 23 0.00 0.00 0.0 35,815 0.7 I S 21.489 1,512,191 1512,191
2021 1 B�F 37 21 025 480 4111 55,838. - - - - - 33503 1,545,693 - 1,545,693
2021 1 9 Sa 33 25 0-15 283 648 55,838 - - - - - 33,503 1,579,196 - 1,579,196
( 2021'.. 1 10 Su 29 12 000 0.00 SJ3 55,838. - - - . - - - 33,503 1,612,699 - 1,612,699
20211 1 11 M 4I 11 0.00 0.00 44) 52,196 - - - - 00 0.2I 31,318 1.644,017 1,644,017
2021. 1 12 T 34 24 032 1100 40 50,617 - - - - . - MU02 30.370 1.674387 1,674,397
2021 1 13 W 37 17 0.00 0.00 30 55,212 - - . - - . - - 010 02 33,127 1,707,514 1,707,514
2021 1 14 Th 5I 16 0.00 0.00 20 48,622 - - - - - - - 010 012 29.173 1,736,687 1,736,687
2021 1 15 F 51 22 0.00 0.00 10 67,673 - - - - - - - MD02 .10,604 1,777,291 1,777,291
2021 1 16 Sa. 38 23 T T T 67,673. - - - - - - 40,604 1,817895 1,817895
2021 1 17 Su 30 25 002 100 1.0 67,673 - - - - • - 40604 1,858,499 1,858,499
2021 1 18.M 36 26 0.12 250 318 67,673 - - - - - - - 00. 012 40,604 1.899,102 1,899,102
2021 1 19 T 26 T 0.00 T 52,839 - - - - - - 0.0 0,2 31,703 1.930,806 1,930,806
31
2021 1 20.W 42 26 0.00 0.00 T 64,205 - - - - - - 110 02 38,523 - 1 969,329 1,969,329
2021 1 21 Th 39 26 T 1133 0.0 25,979 - - - - - - - 00 02 15,587 - 1,984,916 1,984,916
2021, 1 22 F 37 32 T 0.00 0.0 67,469 - - - - - - - 0.0 0,2 40,481 - 2025,398 2,025,398
2021 1 23.54. 44 26 0,00 0.00 0.0. 66,843 - - - - - - - , 40,106 2,065,503 2,065,503
2021: 1 24 Su 39 18 0.00 0,00 0.0. 66,843 - - - - - 40.106 2,105,609 2,105,609
2021 1 25 M 44 23 T T 0.0' 66,843 - - - - - 0,0+ 02 40,106 2,145,715 35,715 2,110000
2021 1 26 T 49 38 055 035 0.0. 66,674 - - - - - - 0'10' 0.2 40,004 2,150,001 40.004 2,110,000
2021 1 27 W 60 37 0.00 0.00 0.0 65,828 0.0 02 39,497 2,149,457 39,497 2,110,000
2021 1 28+Th 56 23 0.18 0-18 T 36,351 0.0. 012 21,811 2,131,811 21,811 2,110,000
2021 1 29 F 27 14 T T T 63,851 0:0 0.2' 33,31: 2,148311 38,311 2.110000
2021 1 30'Sa 31 14 0.00. 0.00 0.0 69,026 - - - - - 0..1111 - 2,151,416 41.416 2.110,000
2021 1 31 Su 36 14 0.40 4310 69,026 - - - - - -t'.I,,"i - 2,151416 41116 2.110,000
Month Ttl 1,808,746 5,338 8,000 7,972 3,669 9,234 8,000 42,213 Total Month Est Cue, 258,169
Aug.Daily 58,347 1,362 Total Cumulative Est Over ' 258,169

Appendix C-Daily Detail and Storage Analysis-with 40%Inflow reductor-Winter 2020-2021
Cottages of Boone
Daily Detail•February 2021
Overage Projections with 40%Water Use Reduction
Cumulative Volume Estimated Stored Volume
Weather Observations Snow/Ice/ Tank Freeboard(Ft) Reduced Inflow Outflow Overflow
Date Temp(F) Rain Snow Hail on Irrigation By Field(Gallons) Main(22') 5-day(22') ( (60%of actual)Gals (Max.2,110,000 gal) or Pump
-
Year Month Day Man, Min- (in) (in) Ground Inflow(Gallons) 1 2 3 4 5 6 Total, 1,562,000 Gal', 548,000 Gal. j 2,110,000
2021 2 1 M 37 19 8.18 0.00 OD 69,026 - - - - - - 0.0 0.2.; 41,416 - 24155416 41416 2,110,000
2021 2 2 T 32 17 5285 '1JDB 119 71,422 - - - - - - 0.0 0.2) 42,853 2,.152,253 42.853 2,110,000
2021 2 3 W 23 17 T T T 71,422 - - - - - - 0.0 0,21 42,953 - 2,152953 42,853 2,110,000
•
2021 2 4 Th 30 17 0.00 0.00 OCT 74,325 - - - - - - 0.0 0.2, 44,595 2,154,5595 44,595 2,110,000
2021' 2 5,F 44 17 52330.00. 0.0. 53,012 - - - - - - 0.0 0,21 31,807 - 2,141$37 31,807 2,110,000
2021. 2 6r54 44 28 0.00 0.00 0.0 65,828 - - - - - - 39,497 - 2,149,97 39,497 2,110,000
2021 2 7 Su 41 16 0.23 259 3® 65,828 - - - - - - 39,497 - 2.149,497 39,497 2,110,000
2021, 2 8 M 37 15 0.00 0.00 10 65,828 - - - - - - 0',0 0,2 39,497 - 2,14,3,497 39,497 2,110,000
2021 2 9 T 43 30 0.00. O'.00h 1.0 69,042 - - - - . 0.0 0.2, ' 41425 - 2,159.,415 41,425 2.110,000
2021 2 10 W 49 29 000: 0.00 0.0 20,069 - - - - - - 00 0.2; h1 12,041 - 2422,341 12,041 2,110,000
2021 2 1I Thh 51 23 0.011 0.00 0.0 72,336. - - - - - - 90 0.2', :� 43402 - P,153,4ffi 43,402 2,110,000
2021 2 12 F 49 27 ®,25 0.00 0,0 68,322 - - - - , - - 0.0 0.2 I 40,993 - 2,25D,993 40,993 2,110000
f 2021 2 13 Sa 32 32 091 0.00 IF 67,048 - - - - - - . 40,229 - 2.150219 40,229 2,110,000
2021 2 14 Su 39 35 0A5 0.00 0.0 67,048 - - - - - - 40,229 2,150229 40,229 2,110.000
2021, 2 15 51 42 22 838 0.00 0.0 67,048 - - - - - - 00 0.2 40,229 - 2,158,229 40,229 2,110,000
2021, 2 16 T 37 31 0.45 0.00 0.0 67,589 - - - - - - 00 0.2':. 40,553 2,5150,553 40,553 2,110,000
2021 2 17 W 36 17 T 0.00 0.0' 32,212 - - . - - - 0.0 02i 19,327 2129,327 19,327 2,110,000
2021 2 18 Th 36 18 026 0.00 T 94,634 - - - - - - 0.0 0.21 56,780 - 2,166,780 56,780 2,110,000
2021 2 19 F 36 31 9,64 0.00 0.0' 45,246 - - - - - - 0.0 0.21 27.148 2,137,168 27,148 2,110,000
2021 2 20 Sa 36 17 0.00 0.00 0.0. 65,947 - - - - - - 39,568 - 2,149,568 39,568 2,110,000
2021 2 2154 32 15 0.00 0,00 00 65,947 - - - - - - ) 39,568 - 2,149,588 39,568 2,110,000
2021 2 22 M 39 15 0.00 0,00 T 65,947 - - - - - - 00 0211 39,568 - 2,149,568 39,568 2.110,000
2021 2 23 T 46 32 029 0.00 0.0 65i193. - - - - - - 0.0 0.2' 39,116 2,149,126 39,116 2,110,000
2021 2 24W 53 31 0.00 0.00 00 32,520 14,856 16,000 16,000 16,000 16,000 10,542 89,398' 0.2 0.2 19,512 39,398 2,040.114 - 2,040,114
2021 2 25.Th 64 29 000 0.00 00 71,007 23,616 24,000' 18,196 16,000 16,000 21,436 119,248. 11 0.2 42,604 119,243 1,963 470 - 1,963,470
2021 2 26 F 5 33 0.00 0,00 00 63,263 16,000 8,470 13,726 16,000 16,000 16,000 86,196 1.5 0,2 37,958 36.196 1915,232 - 1,915,232
Z021� 2 275a 41 33 0184 0.00 02 67,118 20,000' 20,000 20,000 20,000 24,000 16,000 122,000 40,271 122,000 1,833.503 - 1,833,503
2021. 2 28 Su 60 31 0.00 0.00 0.0 67,118 20,000 20,046 20,046 21,216 24,000 18,372 123,680 I 40,271 123,680 1,750,094 - 1,750,094
Month Ttl. 1,771,345 94,472 88,516 87,968 89,216 96,000 84,350 540,522 Total Month Est Doer: 882,191
Aug.Daily 63,262 17,436 Total Cumulative Est Oyer 1,140,360
3084222
1,943,962
0.63026008

DOdom
i Engineering
PLLC
COTTAGES AT BOONE
TWO MILLION GALLON TANK COST ESTIMATE
APRIL 2021
Item Description Quantity Unit Unit Price Cost
1 Grading 15000 CY $15.00 $225,000.00
2 Rock 100 CY $100.00 $10,000.00
3 Retaining Wall 8,750 SF $25.00 $218,750.00
4 Piping 1 LS $35,000.00 $35,000.00
5 Tank Installation 1 LS $1,500,000.00 $1,500,000.00
CONSTRUCTION SUBTOTAL $1,988,750.00
5 Construction Contingencies/Engineering(25%) $198,875.00
CONSTRUCTION TOTAL $2,187,625.00
TOTAL PROJECT ESTIMATE $2,200,000.00

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EFFICIENCY & EMISSIONS REPORT
Utilities Optimization & Capital Construction Plan
Prepared.*Mapletree Investments 1 Cottages at Boone (Toilet Replacement)
June 2021
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Your facility is likely to consume more than 9.1 million gallons of water during the next 12 months, or a 46% overage. This report provides
recommended efficiency upgrades that if installed will help decrease this overage while creating a quantifiable environmental impact. If
implemented, the Program herein will:
• Meaningfully reduce the blended annual utilities expense at your asset and ensure ongoing expense savings
• Increase the capped value of your facility upon refinance or disposition
• Generate an attractive unlevered ROI on invested capital
EFFICIENCY&EMISSIONS PROJECT SUMMARY
The Cottages at Boone
EMISSIONS TOTAL
T-12 Consumption (Gallons) 19,809,450
Projected F-12 Consumption (Gallons) 10,681,573
Projected Usage Savings(Yr 1) 9,127,877
%of Historical 46%
CAPITAL REQUIREMENT
Efficiency Program Retrofit Hard/Soft Costs $426,756
Projected Rebates
Net Capital Requirement After Rebates $426,756

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FIMIng Energy Efk*My
Investing for Expense Savings
Below are the recommended efficiency upgrades we've identified alongside projected expense reductions for each:
EFFICIENCY&EMISSIONS UPGRADE PLAN
The Cottages at Boone
UTILITY CONSUMPTION
ECM Gross Cost SAVINGS(GALLONS) Rebates Net Cost
ELECTRICAL
WATER/SEWER
High Efficiency Toilets-0.8 GPF $295,020 3,466,654 $0 $295,020
High Efficiency Bathroom Sink Aerator-0.5 GPM $14,751 2,113,008 $0 $14,751
High Efficiency Showerhead-1.25 GPM $24,585 1,683,803 $0 $24,585
High Efficiency Kitchen Sink Aerators-1.0 GPM $5,775 864,412 $0 $5,775
In-Unit Water Meters $86,625 1,000,000 $0 $86,625
TOTAL:WATER/SEWER $426,756 9,127,877 $0 $426,756
'TOTAL PROJECT COSTS $426,756 9,127,877 $0 i $426,756

1(14'
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Investing for Environmental Impact I Water
Implementation of an Efficiency Program will help to decrease your ongoing Water consumption in the following ways:
WATER/SEWER USAGE WATER SAVINGS OF: 9,127,877 Gallons
2,500,000 $2,500,000 63.4 13.8
Average Olympic
c OR
2,000,000 $2,000,000 ' esidential homes swimming
0 for one year i pools
2 1,500,000 51,500,000 Ir � r
c 1,000,000 ' $1,000,000
t7 500,0000 i l
' I 1 Ssoo0,000
156.7 A536,934
0 0 0 0 0 0 0 0 0 0 .—I ,—r Average
N N N N N N NI IN N N N INOR
a Q Z a a residential 6660
Average
awns 6 O O O personal
T-12 TOTAL GALLONS F-12 TOTAL 4+.iiONS (irrigation) O O O showers
T-12 TOTAL$ -F-12 TOTAL$
WATER CONSUMPTION&EFFICIENCY IMPACT
Expense Consumption (Gallons) Annual Water Savings
Previous 12 Months $19,809,450 19,809,450 30 Olympic Pools
Next 12 Months $10,681,573 10,681,573 16.2 Olympic Pools
Decrease of T-12 46% 46%
TOTAL EFFICIENCY $9,127,877 9,127,877 Savings of 13.8 Olympic Pools
4

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Our Service Lines
SERVICE DESCRIPTION
Utilities& We provide initial utilities audits and expert analysis surrounding the feasibility and benefit of upgrading the utilities infrastructure of
Efficiency commercial real estate facilities you own or manage today. As your Utilities Partner, we also provide the same initial analysis for new
Consulting acquisitions you may be considering.
Site Audit/ Utilizing degreed and licensed energy managers, professional engineers, and energy consultants, we identify and audit the design,
Efficiency Plan operation, and maintenance parameters of your Facility to identify efficiency opportunities as well as to create a baseline to benchmark
Design current utilities consumption. The result of this effort is our Efficiency & Emissions Report alongside a fixed-price utilities upgrade and
project management agreement.
Materials Sourcing our deep network of trusted suppliers,we procure all of the materials required to achieve the efficiency upgrades outlined in this
Procurement/ ' report and then act as your project manager overseeing their installation onsite.To do so,we use our vetted list of national, regional,and
Project local vendors and utilize our experience as former institutional real estate owners/operators to ensure minimal disruption to ongoing
Management operations and tenant satisfaction.
Rebate& Upon Project completion,we provide you with all applicable manufacturer warranties on the purchased materials and serve as your Rebate
Warranty processor, identifying as many available rebates as we can and then tracking their application and award.
Processing
Measurement Finally,we provide ongoing measurement and verification"M&V"to track the reduced utilities consumption as well as the ongoing utilities
&Verification Cost Avoidance at the asset level to accurately illustrate progress and to provide full accountability of both the environmental and financial
Services impact of the efficiency investment. These M&V services provide you with data and sustainability metrics to share with your team and
other outside parties.
5

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Execution Timeline
The table below illustrates the projected execution timeline beginning upon mutual execution of the contract to Efficiency Program closeout.
PROJECT PHASE I WEEK 1 WEEK 2 WEEK 3 WEEK 4 WEEK 5 WEEK 6 WEEK 7 j WEEK 8 WEEK 9 ;WEEK 10
CONTRACT EXECUTION
1 Project Awarded/Mutual Contract Execution . '
PRECONSTRUCTION •
Materials Deposit Due(50%of Project Cost)
Kickoff Call
Materials Procurement
Installation Scheduling
EXECUTION
Mobilization&Start-Up
Project Installation
Substanital Project Completion I Quality Control
2nd Deposit Due(40%of Project Cost) •
j Final Project Completion Punch
PROJECT CLOSEOUT
Rebate Processing
Warranty Processing
Final Invoicing(10%of Project Cost)
*Timeline above may change to due materials ordering and size of project
6

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ra
Empammuy Eneryy EMancy
Process & Next Steps
1: Site Tour& FINAL Utilities Audit
We've toured your facility and conducted a utilities audit, the findings
included herein. The Efficiency& Emissions Report includes:
• Detailed utilities audit of your facility and step-by-step blueprint
to expense savings
• A fixed-price contract for our auditing & engineering consulting,
materials and labor,we construction management services, rebate
and warranty processing, and Measurement & Verification of
savings upon completion
2: Financing& Installation of Improvements
You fund the infrastructure improvements and we procure the
materials, manages the vendors, and serves as project manager over
the install. If you choose to move forward,we will execute a project
management agreement outlining the terms and conditions of our
utilities consulting, materials procurement, and construction
management services. Project Management Agreement payment
schedule:
PROJECT FUNDING SCHEDULE
$213,378 50% upon contract execution
$170,702 40% upon substantial project completion
$42,676 10% upon full project completion
3: The Contract between Navitas/Owner
Upon project completion, we processes identified rebates and provides
monthly measurement & verification services illustrating the utilities
consumption and cost savings for 12 months.
7

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•
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Emposenng Fee•e Mew.,
Efficiency Program Technologies
Below is a list of the Efficiency Program upgrades we recommend for your asset.
SCOPE DESCRIPTION
Water Water fixtures, in the context of this report, include low-flow fixtures,water line apparatus, and smart irrigation systems.
Technologies Shower Heads and Aerators
• Niagara High Efficiency Shower Heads are durable, have classic aesthetics,and offer a TamperProof option
•The Bathroom and kitchen aerators
•The 0.5 needle spray bathroom aerator has great pressure to efficiently wash hands
• The 1.5 Dual Spray kitchen has the force to clean dishes
Toilets
• STEALTH fixtures by Niagara can use as little as 0.625 gallons/flush->50%improvement on the current toilets.
• Vacuum assisted technology that has a MaP premium rating of 800 which is a comparable force to a 1.6 GPF toilet;or a toilet that
uses 2x more water.
• Low flow toilets,the ones that are referred to often,are usually flapper toilets or pressure assisted which creates the following:
1) Pressure Assisted loud and dangerous. Not ideal for residential application because of their supersonic jet-like noise
2) Flapper Toilets are costly, leaky and running. Flapper Toilet Slow gravity fed that lacks force
3) Niagara has a Lifetime Warranty on Ceramic, 10-year on internals with little to no maintenance costs
8

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fmewaM1g NegE Money
identified Rebate & Manufacturer Warranty Detail
IDENTIFIED REBATES&MANUFACTURER WARRANTIES
The Cottages at Boone
IDENTIFIED REBATES $ AMOUNT DESCRIPTION & PROJECTED TIMELINE
n/a n/a n/a
MANUFACTURER WARRANTIES DESCRIPTION& PROJECTED TIMELINE
High Efficiency Bathroom Sink Aerator-0.5 GPM 1-year Product Warranty
High Efficiency Showerhead- 1.25 GPM = = ;lfl year Product Warranty
High Efficiency Kitchen Sink Aerators- 1 GPM =;1-year Product Warranty
Zennergy Flow Management Device ;__:___ 15-year Product Warranty
9

Appendix F=Present Worth Calculations for Alternative Comparison
j!ycACalculation Method t 20
Thefollowing standard formula for eomputittg the pseseut wattle max be used us ap cost estjntates made owlet this
evaluation r 2.5%
PV.C:, C
�rhete:
By =Present value of costs-
Co =Costs nu-tweed its the peewit gear.
CI =Coos mended at time t
I =Time period epee rho present year(he present rear is I=o)
P =Fndigg yme of dia l.of the tacilitr.
r —Clereut CPA discotmt rate PP♦attests this rete ansutapp eq October 1,anti a can he accessed rtom
the Witham ai hnp./areaacce-uet/fap/oratf/2016tLLhirra.
If"mewls costs cue the same iq yetis I duotsOs 29.dawn Ct=C end the feaamh redness to:
6
Recurring Costs($
Alternative Annual Collection
Alternative Specific and Treatment
Alternative Specific Specific Annual Intermittent System Present Worth of
Alternative Capital Cost(5) Costs Costs Operation Alternative($)*
1 Do Nothing 155,400 10,000 320,000 7,566,979
2 Conjunctive Use(Irrigate+Discharge) 102,533 - 320,000 5,091,0€5
3 Connect to Municipal System 1,237,380 238,126 50,000 5,729,023
4 Increase On-Site Storage 2,200,000 1,500 320,000 7,211,916
5 Reduce Generated Wastewater 426,756 41,958 2,700 320,000 6,111,469
6 Cover Tanks to Eliminate Precip Inputs 350,000 320,000 5,338,532
7 Increase Irrigation Areas/Rates' -
Awating Data from Solis Engineering Consultant
"20=Yr Facility Life,2.5%EPA Discount Rate

ROY COOPER
Governor
N
'
MICHAEL S. REGAN
Secretary
Water Resources S.JAY ZIMMERMAN
ENVIRONMENTAL OUALITV
Director
October 25, 2017
SEAN DEVINE
WALLACE LOFT,LLC
2711 CENTERVILLE ROAD,SUITE 400
WILMINGTON,DELAWARE 19808
Subject: Permit No. WQ0035784
The Cottages of Boone WWTP
Wastewater Irrigation System
Watauga County
Dear Mr. Devine:
In accordance with your permit change of ownership request received July 28, 2017, we are
forwarding herewith Permit No. WQ0035784 dated October 25, 2017, to Wallace Loft, LLC for the
continued operation of the subject wastewater treatment and irrigation facilities.
Please note that the Permittee has been changed from CCC-Boone, LLC to Wallace Loft, LLC.
This permit shall be effective from the date of issuance until April 30,2022, shall void Permit No.
WQ0035784 issued April 12, 2017, and shall be subject to the conditions and limitations as specified
therein. Please pay attention to the monitoring requirements listed in Attachments A,B and C for they may
differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition,conforming to Chapter 150E of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center,Raleigh,NC 27699-6714. Unless such demands are made,this permit shall be final and binding.
If you need additional information concerning this permit,please contact Alice M.Wessner at(919)
807-6425 or [e-mail].
Sincerely,
�S. Jay Zimmerman, P.G., Director
Division of Water Resources
cc: Watauga County Health Department(Electronic Copy)
'Nothing Compares -
State of North Carolina I Environmental Quality I Water Resources I Water Quality Permitting I Non-Discharge Permitting
1617 Mail Service Center I Raleigh,North Carolina 27699-1617
919-807-6332

Mr. Sean Devine
October 25,2017
Page 2 of 2
Winston-Salem Regional Office,Water Quality Regional Operations Section(Electronic Copy)
Digital Permit Archive(Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143,General Statutes of North Carolina as
amended,and other applicable Laws,Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
Wallace Loft, LLC
Watauga County
FOR THE
continued operation of a 108,530 gallon per day (GPD) wastewater treatment and irrigation facility
consisting of:
a rotary brush screen and a 500 gallon filtrate collection tank served by two 0.5 horsepower(hp)centrifugal
screening transfer pumps; a 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; a 12,000 gallon post-
anoxic 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; a Hach turbidimeter and a 190 GPM effluent flow meter;an automatic-activation propane-fueled
alternate power supply;a 548,000 gallon bolted steel 5-day upset tank;a 36,166 gallon bolted steel aerobic
digestion sludge holding tank with coarse bubble diffuser and 2-inch, 100 GPM sludge flow meter;a 12,059
gallon HDPE irrigation dosing tank served by two 15 hp centrifugal dosing pumps; a 1,562,000 gallon
bolted steel 14-day wet weather storage tank;a precipitation sensor;three 1,763 gallon precast return flush
tanks served by two 48 GPM vertical turbine flush return pumps; approximately 14.39 acres of drip
irrigation area with a mixed hardwood and pine forest cover crop with sufficient disposal capacity in zones
1-6 as detailed in Attachment B;and all associated piping,valves,controls and appurtenances
to serve 894 bedrooms, five administrative/clubhouse employees, a fitness center, and a pool at The
Cottages of Boone,with no discharge of wastes to surface waters,pursuant to the application received July
28, 2017, and in conformity with the project plans, specifications, and other supporting data subsequently
filed and approved by the Department of Environmental Quality and considered a part of this permit.
This permit shall be effective from date of issuance until April 30,2022,shall void Permit No.WQ0035784
issued April 12,2017,and shall be subject to the following specified conditions and limitations:
WQ0035784 Version 2.1 Shell Version 151201 Page 1 of 9

SCHEDULES
1. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted,will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T.0105(d)requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T.0105(d), 02T.0106, 02T .0109, 02T.0115(c)]
IL PERFORMANCE STANDARDS
1. The subject non-discharge facilities shall be effectively maintained and operated at all times so there is
no discharge to surface waters, nor any contravention of groundwater or surface water standards. In
the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due
to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the
effluent,the Permittee shall take immediate corrective actions including Division required actions,such
as the construction of additional or replacement wastewater treatment or irrigation facilities. [G.S. 143-
215.1, 143-213.3(a)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02B .0200, 02L .0100]
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108(Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1),02T.0505(b)]
5. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0505(c),02T.0505(n)]
6. The irrigation system shall be connected to a rain or moisture sensor,which shall indicate when effluent
application is not appropriate in accordance with Conditions I1I.4.and III.5.of this permit. [15A NCAC
02T .0108(b)(1)]
7. The compliance and review boundaries are established at the irrigation area boundaries. Any
exceedance of standards at the compliance or review boundary shall require action in accordance with
15A NCAC 02L .0106. [15A NCAC 02L .0106, 02T.0506(c)]
8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary. [15A NCAC 02L .0107(c)]
9. In accordance with 15A NCAC 02L.0107(d),no wells,excluding Division approved monitoring wells,
shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g). [15A NCAC 02L .0107]
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10. Except as provided for in 15A NCAC 02L .0107(g),the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the
Watauga County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary;and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
11. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for irrigation sites permitted under 15A NCAC 02T .0500 shall be as follows (all
distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Any habitable residence or place of public assembly owned by the Permittee: 15
iii. Any private or public water supply source: 100
iv. Surface waters: 100
v. Groundwater lowering ditches: 100
vi. Surface water diversions: 25
vii. Any well with exception of monitoring wells: 100
viii.Any property line: 0
ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15
x. Any water line from a disposal system: 10
xi. Subsurface groundwater lowering drainage systems: 100
xii. Any swimming pool: 100
xiii.Public right of way: 50
xiv.Nitrification field: 20
xv. Any building foundation or basement: 15
' Setbacks to property lines have been reduced to 0 feet because the facility is complying with
15A NCAC 02T .0506(c).
[15A NCAC 02T.0506(a),02T.0506(c)]
b. The setbacks for storage and treatment units permitted under 15A NCAC 02T .0500 shall be as
follows(all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Any private or public water supply source: 100
iii. Surface waters: 50
iv. Any well with exception of monitoring wells: 100
v. Any property line: 50
[15A NCAC 02T.0506(b)]
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III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non-discharge system to prevent the discharge of any wastewater resulting
from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan,
which at a minimum shall include operational functions, maintenance schedules, safety measures and
a spill response plan. [15A NCAC 02T.0507]
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non-discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge(ORC)and one or more
certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules. [15A NCAC 02T .01 17]
3. A suitable year round vegetative cover shall be maintained at all times, such that crop health is
optimized,allows for even distribution of effluent and allows inspection of the irrigation system. [15A
NCAC 02T .0108(b)(1)]
4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed
in Attachment B. [15A NCAC 02T .0108(b)(1)]
5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff. [15A NCAC 02T .0108(b)(1)]
6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration records
shall be maintained at the facility for a period of no less than five years,and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
7. Only effluent from The Cottages of Boone WWTP shall be irrigated on the sites listed in Attachment
B. [G.S. 143-215.1]
8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment
installation or while maintenance is being performed. [15A NCAC 02T .0108(b)(1)]
9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. [15A NCAC
02T .0505(q)]
10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0508. [15A NCAC 02T.0508,02T .1100]
11. Diversion orb bypassing of untreated orpartiallytreated wastewater yp g ste ater from the treatment facilitiesis
prohibited. [15A NCAC 02T .0505(j)]
12. Freeboard in the 1,562,000 gallon wet weather storage tank and the 548,000 gallon 5-day upset tank
shall not be less than two feet at any time. [15A NCAC 02T .0505(d)]
13. Gauges to monitor waste levels in both the 1,562,000 gallon wet weather storage tank and the 548,000
gallon 5-day upset tank shall be provided. These gauges shall have readily visible permanent markings,
at inch or tenth of a foot increments, indicating the following elevations: maximum liquid level at the
top of the temporary liquid storage volume;minimum liquid level at the bottom of the temporary liquid
storage volume; and the lowest point on top of the dam. [15A NCAC 02T .0108(b)(1)]
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14. All effluent shall be routed to the five day upset tank should the limit for fecal coliform (e.g., daily
maximum concentration of 25 colonies per 100 mL) or turbidity (e.g., instantaneous maximum of 10
NTU) be exceeded, until the problems associated with the wastewater treatment plant have been
corrected. The wastewater in the five day upset tank shall be pumped back to the treatment plant
headworks for re-treatment or treated in the five day upset tank prior to infiltration. [15A NCAC 02T
.0108(b)(1)]
15. The turbidimeter shall be tested and calibrated at a minimum of once per year. Calibration records
shall be maintained at the facility for a period of no less than five years,and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
IV. MONITORING AND REPORTING REQUIREMENTS
I. Any Division required monitoring(including groundwater,plant tissue,soil and surface water analyses)
necessary to ensure groundwater and surface water protection shall be established, and an acceptable
sampling reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device to ensure the accuracy
and reliability of flow measurement consistent with accepted engineering and scientific practices.
Selected flow measurement devices shall be capable of measuring flows with a maximum deviation of
less than ten percent from true flow; accurately calibrated at a minimum of once per year; and
maintained to ensure the accuracy of measurements is consistent with the selected device's accepted
capability. The Permittee shall maintain records of flow measurement device calibration on file for a
period of at least five years. At a minimum, documentation shall include:
a. Date of flow measurement device calibration,
b. Name of person performing calibration,and
c. Percent from true flow.
[15A NCAC 02T .0105(k)]
4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A. [15A NCAC 02T .0108(c)]
5. The Permittee shall maintain adequate records trackingthe amount of effluent irrigated. At a minimum,
g
these records shall include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly, and year-to-date hydraulic(inches/acre) loadings;
f. Continuous monthly and year-to-date loadings for any non-hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions; and
h. Maintenance of cover crops.
[15A NCAC 02T .0108(c)]
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6. Freeboard(i.e., waste level to the lowest embankment elevation) in the 1,562,000 gallon wet weather
storage tank and the 548,000 gallon 5-day upset tank shall be measured to the nearest inch or tenth of
a foot, and recorded weekly. Weekly freeboard records shall be maintained at the facility for a period
of no less than five years, and shall be made available to the Division upon request. [15A NCAC 02T
.0108(c)]
7. Three copies of all monitoring data(as specified in Conditions IV.3. and IV.4.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.)on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month,monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[1 SA NCAC 02T.0105(1)]
8. A record shall be maintained of all residuals removed from this facility. This record shall be maintained
at the facility for a period of no less than five years,and shall be made available to the Division upon
request. At a minimum,this record shall include:
a. Name of the residuals hauler;
b. Non-Discharge permit number authorizing the residuals disposal,or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T.0108(b)(1)]
9. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a
period of no less than five years, and shall be made available to the Division upon request. At a
minimum,this log shall include:
a. Date of calibration of flow measurement device;
b. Date of calibration of turbidimeter;
c. Visual observations of the plant and plant site;and
d. Record of preventative maintenance(e.g.,changing of equipment,adjustments,testing,inspections
and cleanings,etc.).
[15A NCAC 02T .0108(b)(1)]
10. Monitoring wells shall be sampled at the frequencies and for the parameters specified in Attachment
C. All mapping, well construction forms, well abandonment forms and monitoring data shall refer to
the permit number and the well nomenclature as provided in Attachment C and Figure 2. [15A NCAC
02T.0105(m)]
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11. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form(GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T.0105(m)]
12. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for a period
of no less than five years,and shall be made available to the Division upon request. At a minimum,the
Standard Soil Fertility Analysis shall include the following parameters:
Acidity Exchangeable Sodium Percentage Phosphorus
Base Saturation(by calculation) Magnesium Potassium
Calcium Manganese Sodium
Cation Exchange Capacity Percent Humic Matter Zinc
Copper pH
[15A NCAC 02T .0108(c)]
13. Noncompliance Notification:
The Pennittee shall report by telephone to the Winston-Salem Regional Office,telephone number(336)
776-9800,as soon as possible,but in no case more than 24 hours,or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting(e.g., discharges to surface waters, imminent failure of
a storage structure,etc.)outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number(800)662-7956,[phone],or(919)733-3300. Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
be taken to ensure the problem does not recur. [15A NCAC 02T .0105(1),02T .0108(bx1)]
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V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and irrigation facilities. [15A NCAC 02T .0108(b)]
2. The Permittee or their designee shall inspect the wastewater treatment and irrigation facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment,a threat to human health or a public nuisance. The Permittee shall
maintain an inspection log that includes, at a minimum, the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this
inspection log for a period of five years from the date of the inspection, and this log shall be made
available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and irrigation facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions of this permit,
and may collect groundwater, surface water or leachate samples. [G.S. 143-21.5.3(a)(2)]
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with the
conditions of this permit, the Division approved plans and specifications, and other supporting
documentation. [15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted,unless specifically requested and approved in this permit pursuant to 15A NCAC 02T.0105(n).
[G.S. 143-21.5.1]
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g.,local,state,and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under General Permit NCG010000; any requirements pertaining to wetlands under 15A NCAC 02B
.0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the
General Statutes. [15A NCAC 02T .0105(c)(6)]
5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner. [15A NCAC
02T.0104]
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0108(b)(1)]
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority. [15A NCAC 02T
.0105(j)]
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8. This permit is subject to revocation or unilateral modification upon 60 days' notice from the Division
Director,in whole or part for the requirements listed in 15A NCAC 02T.0110. [15A NCAC 02T.0110]
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T.0120(b). [15A
NCAC 02T .0120]
10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 25th day of October 2017
NORTH CAROLINA ENVIRONMENTAL.MANAGEMENT COMMISSION
7S.Jay Zimmerman,P G.,Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0035784
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ATTACHMENT A—LIMITATIONS AND MONITORING REQUIREMENTS Permit Number: WQ0035784 Version: 2.1
PPI 001 WWTP Effluent(For flow averaging less than 100,000 GPD)
EFFLUENT CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS
PCS Parameter Description Units of Monthly Monthly Daily Minimum Daily Maximum Measurement Sample
Code Measure Average Geometric Mean Frequency Type
00310 BOD,5-Day(20°C) mg/L 10 15 Monthly Composite
00940 Chloride(as Cl) mg/L 3 x Year' Composite
31616 Coliform,Fecal MF,M-FC Broth.44.5°C #/100 m1, !4 25 Monthly Grab
50050 Flow,in Conduit or thru Treatment Plant GPD 100,000 Continuous Recorder
00610 Nitrogen,Ammonia Total(as N) mg/L 4 6 Monthly Composite
00625 Nitrogen,Kjeldahl,Total(as N) mg/L Monthly Composite
4
00620 Nitrogen,Nitrate Total(as N) mg/L 10 Monthly Composite
00600 Nitrogen,Total(as N) mg/L Monthly Composite
,
00400 pH su 5 x Week Grab
00665 Phosphorus,Total(as P) mg/L Monthly Composite
70300 Solids,Total Dissolved—180°C mg/L 3 x Year Composite
00530 Solids,Total Suspended mg/L 5 10 Monthly Composite
00076 Turbidity,I ICH Turbidimeter NTU 10 Continuous Recorder
1. 3 x Year sampling shall be conducted in March,July and November.
WQ0035784 Version 2.1 Attachment A Page 1 of 2

ATTACHMENT A—LIMITATIONS AND MONITORING REQUIREMENTS Permit Number: WQ0035784 Version: 2.1
PPI 002-WWTP Effluent(For flow averaging greater than 100,000 GPD)
EFFLUENT CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS
T
PCS Units of Monthly Monthly Measurement Sample
Code Parameter Description Measure Average Geometric Mean Daily Minimum Daily' Maximum Frequency Type
00310 BOD,5-Day(20°C) mg/L 10 15 2 x Month Composite
00940 Chloride(as CI) mg/L 3 x Year' Composite
31616 Coliform,Fecal MF,M-FC Broth.44.5°C #/100 m1. 14 25 2 x Month Grab
50050 Flow,in Conduit or thru Treatment Plant GPD 108,530 Continuous Recorder
00610 Nitrogen,Ammonia Total(as N) mg/L 4 6 2 x Month Composite
00625 Nitrogen,Kjeldahl,Total(as N) mg/L 2 x Month Composite
00620 Nitrogen,Nitrate Total(as N) mg/L 10 2 x Month Composite
y _
00600 Nitrogen,Total(as N) mg/L 2 x Month Composite
I
00400 pH su ; 5 x Week Grab
00665 Phosphorus,Total(as P) mg/L _ ___ _ — I 2 x Month Composite
70300 Solids,Total Dissolved— 180°C mg/L 3 x Year I Composite
00530 Solids,Total Suspended mg/L 5 10 2 x Month Composite
00076 Turbidity,HCH Turbidimeter NTH 10 Continuous Recorder
1 3 x Year sampling shall be conducted in March,July and November.
WQ0035784 Version 2.1 Attachment A Page 2 of 2

ATTACHMENT B-APPROVED LAND APPLICATION SITES AND LIMITATIONS Permit Number: WQ0035784 Version: 2.1
Wallace Loft,LLC-The Cottages of Boone WWTP
IRRIGATION AREA INFORMATION APPLICATION LIMITATIONS
Field Owner Dominant Hourly Yearly
County Latitude Longitude Net Acreage Soil Series Parameter Rate Max Units
I Wallace Loft,LLC Watauga 36.202779° • -81.705226° 2.80 Pigeonroost/"Tate 01284-Non-Discharge Application Rate 0.15 101.4 inches
2 Wallace Loft,LLC Watauga 36.202203° -81.704549° 2.70 Pigeonroost 01284-Non-Discharge Application Rate 0.15 101.4 inches
3 Wallace Loft,LLC Watauga 36.202258° -81.703531° ' 1.86 Pigeonroost 01284-Non-Discharge Application Rate 0.15 101.4 inches
4 Wallace Loft,LLC 1 Watauga I 36.201789° -81.702476° 2.72 Pigeonroost 01284-Non-Discharge Application Rate 0.15 101.4 inches
5 Wallace Loft,LLC Watauga i 36.199994° -81.698554° 1.72 Pigeonroost 01284-Non-Discharge Application Rate 0.15 101.4 inches
6 Wallace Loft,LLC Watauga 36.199283° -81.699303° 2.59 Pigeonroost 01284-Non-Discharge Application Rate 0.15 101.4 inches
Totals i 14.39
WQ0035784 Version 2.1 Attachment B Page 1 of 1

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ATTACHMENT C—GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQ0035784 Version: 2.1
Monitoring wells: MW-1,MW-2,and MW-3
GROUNDWATER CHARACTERISTICS 1 GROUNDWATER STANDARDS MONITORING REQUIREMENTS
PCS Code Parameter Description 1 Daily Maximum Frequency Measurement Sample Type Footnotes
00680 Carbon,Tot Organic(TOC) I mg/L 3 x Year Grab 1,6
00940 Chloride(as CI) 250 mg/L 3 x Year Grab 1
31616 Coliform,Fecal MF,M-FC Broth,44.5°C 4/100 mL 3 x Year Grab 1
00610 Nitrogen,Ammonia Total(as N) 1.5 mg/L 3 x Year Grab 1
00620 Nitrogen,Nitrate Total(as N) 10 mg/L 3 x Year i Grab 1
i
' 00400 pH 6.5-8.5 su 3 x Year i Grab 1,2
. j
00665 Phosphorus,Total(as P) mg/L 3 x Year Grab I
70300 Solids,Total Dissolved- 180°C 500 mg/L 3 x Year Grab 1
GWVOC Volatile Compounds(GC/MS) Present:Yes/No Annually Grab 1,4,5
82546 Water Level,Distance from measuring point 1 feet 3 x Year Calculated I,2,3
L 3 x Year monitoring shall be conducted in March,July&November,Annual monitoring shall be conducted every November.
2. The measurement of water levels shall be made prior to purging the wells_The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall he made after purging and prior to sampling for the remaining parameters.
3. The measuring points(top of well casing)of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points(top of
casing)of all monitoring wells shall be surveyed relative to a common datum.
4. Volatile Organic Compounds(VOC)-In November only,analyze by one of the following methods:
a. Standard Method 6230D,PQI,at 0.5 µg/I,or less
h. Standard Method 6210D,PQL at 0.5 µg/1,or less
c. EPA Method 8021,Low Concentration,PQI,at 0.5 µg/L or less
d. EI'A Method 8260,Low Concentration,PQI.at 0.5}tg/1,or less
e. Another method with prior approval by the Water Quality Permitting Section Chief
Any method used must meet the following qualifications:
a. A laboratory must be DWR certified to run any method used.
b. The method used must,at a minimum,include all the constituents listed in Table VIII of Standard Method 6230D.
e. The method used must provide a PQI,of 0.5 µg/L or less that must be supported by laboratory proficiency studies as required by DWR. Any constituents detected above the MDL but below
the PQL of 0.5 µg/L must be qualified(estimated)and reported.
5. If any volatile organic compounds(VOC)are detected as a result of monitoring as provided in Attachment C,then the Winston-Salem Regional Office supervisor,telephone number(336)776-
9800,must be contacted immediately for further instructions regarding any additional follow-up analyses required.
6. If TOC concentrations greater than 10 mg/L arc detected in any downgradient monitoring well,additional sampling and analysis must be conducted to identify the individual constituents comprising
this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring TOC
concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
7. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 2 and this attachment.
WQ0035784 Version 2.1 Attachment C Page I of 1

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ROY COOPER i .4:.
Governor
MICHAEL S.REGAN " ,,,_�
Secretary ,..t :::,,,:"`
LINDA CULPEPPER NORTH CAROLINA
Dire(for Environmental Quality
January 10,2020
Sean Devine
Manager
Wallace Loft, LLC
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Subject: Speculative Effluent Limits
The Cottages of Boone WWTP
Permit No. WQ0035784
Watauga County
Watauga River Basin
Dear Mr. Devine:
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 7Q 10 flow of 0.44 cfs, a winter 7Q 10 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 are 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.
Q�'' North Carolina Department of Environmental Quality i Division of Water Resources
Djfff' 512 North Salisbury Street i 1617 Mail Service Center I Raleigh.North Carolina 27699 1617
°'°""""°'r."^..Wu°srn\ e.' 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 Weekly Daily Maximum
Average Average
Flow 0.1 MGD
BODs 10.0 mg/L 15.0 mg/L
NH3 as N 3.2 mg/L 16.0 mg/L
Dissolved Oxygen 6.0 mg/L Daily Minimum Average
TSS 5.0 mg/L 7.5 mg/L
TRC 28 µg/L
Fecal coliform(geometric 200/100 mL 400/100 mL
mean)
Chronic Toxicity, Pass/Fail 26%
(Quarterly test)
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(919)707-3612.
Respectfully,
44441.fa47#--
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

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 02/12/20
Facility: COTTAGES AT BOONE NPDEB#: NCWQ003578sipe#: 001 County: WATAUGA
Laboratory Performing Test: R & A LABORATORIES, INC.
Comments: Final Effluent A
X
Sgna / o�r -ra in Responsible Charge Water Tech Project
X 78214-01
Si u e .f - , •ratory Supervisor * PASSED: 2.e1* Reduction
Work Order: 78093-01 Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Environmental Management
N.C. Dept. of EHNR
1621 Mail Service Ctr
Raleigh, North Carolina 27699-1621
North Carolina Ceriodaphnia
Chronic Pass/Fail Reproduction Toxicity Test Chronic Test Results
Calculated t . 1.418
Tabular t - 2.508
CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 % Reduction • 2.81
% Mortality Avg.Reprod.
# Young Produced 23 24 25 23 24 25 24 22 24 22 25 24
0.00 23.75
Control Control
Adult (L)ive (D)ead L L L L L L L L L L L L
0.00 23.08
Treatment 2 Treatment 2
Effluent I: 26t ..
TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV
4.443% PASS FAIL
# Young Produced 22 23 22 24 25 23 24 23 22 25 21 23 % control orgs © IN
producing 3rd
- brooduc Check One
Adult (L)ive (D)ead L L L L L L L L L L L L 100%
L
1st sample 1st sample 2nd sample Complete This For Either Test
pH Test Start Date: 02/05/20
Control 7.37 7.45 7.35 7.43 7.34 7.42 Collection (Start) Date
- Sample 1: 02/03/20 Sample 2: 02/05/20
Treatment 2 7.28 7.36 7.40 7.48 7.39 7.47 Sample Type/Duration 2nd
lst P/F
s s s Grab Comp. Duration D
t e t e t e I S S
a n a n a n Sample 1 X 24.3 hrs L A A
° r d r d r d U M M
t t t Sample 2 X 24.3 hrs T P P
1st sample lst sample 2nd sample
D.O. - Hardness(mg/1) 97 :i
Control 8.6 8.4 8.6 8.3 8.6 8.4 -
Spec. Cond. (pmhos) 398 537 617
Treatment 2 8.6 8.4 8.6 8.3 8.6 8.4 _
Chlorine(mg/1) '•: 0.01 0.01
LC50/Acute Toxicity Test Sample temp. at receipt(°C) 3.3 3.1
(Mortality expressed as %, combining replicates) I
% t I I I I I t 1 1 Concentration Complete This
-
Section Also
4 1 1 1 I I 1; 1 1 % Mortality Note: Please
start/end start/end
LC50 • I Method of Determination Control
95% Confidence Limits Moving Average Probit .
t -- - ISpearman Karber Other High
Conc.
pH D.O.
`Organism Tested: Ceriodaphnia dubia Duration(hrs) :
Copied from DEM form AT-1 (3/87) rev. 11/95 (DUBTA ver. 4.32)

I 1 . Spec,"4 1
RESEARCI-I & ANAlyTicAl d
I LAbORATORiES,INC.
I
Analytioel/Pracess Consultations
IBIOASSAY CHAIN OF CUSTODY RECORD
ICliant:rC 6 e'r c ' Persei4 County: Pipe #: NPDES #;G ,( f
Collector (Print):, 11,4 M/rrrld Concact Perao;,, O F& 1 011.
I
Collector (Signature. ". 7r/J't; - Address:
Phone Number:
Sample Collection
r i Date/ Date! TempTemp Analysis
• Sample Sample Type No. of Upon Rs uire
1 Lab # Description Time Time 1°C) containers Arrival (saute rc one
(PAL only) (sea note*) Started Ended End Comp, Grab sent (°C) bioa
I JO5'1010 •( w ela
0 t''') 6 . ,
1
I
i !
I
" for Sample Description please use Effluent, Influent, Upstream, Post C12, Etc.
IRelinquished by: (Signature) Rece by: to, ) Date/Time
/ '4'. d '
I
-elinquis . .• - - R lr•Id b ._ eture). Date/Time
IM of 3t• A Logged In by:
L
/ � Ina!als_��9, Moved to bioassay dept,by:
Initials /ice DateR.`"1'to Time $;tea^
Note: Original sent with shipment
Copy retained by collector
IP Q. Sax 473. 100 Short Street• Kornarsvllle, North Carolina 27284.338.896-2841 •Fox 338•926.0325
www,randniebe.corn
I

RES
EARC�i & ANALYTICAL 50.0e..t.f./
, is LABORATORIES,INC.
. ' Analytical/Process Consultations
I
•
I BIOASSAY CHAIN OF CUSTODY RECORD
Client: IZf et" 3, County: Pipe #: NPDES 0; (2A Utill
ICollector (Print): Contact POsart,
ICollector (Signature; Address;
Phone Number;
ISample Collection 4/air
Sample Date) Date/ TempTemp Analysis
ITimeLab # Descriptionp IaC Sample Type Na. of Upon Required
Tim° containers Arrival (acute, chronic
Lab
only) (see note') Started Ended End Comp. Grab sent (°C) bioassay)
;1/3/A0 d/4'/:w
c13 Ala (� .c iz 7
' _
I
" for Sample Description please use Effluent, Influent, Upstream, Post Cis, Etc,
I
Relinquished by: (Signature) Received by: (Signature) Date/Time
I
0/ile ik/144v) n2Pth(> oqw ---• -r-7-1,, ,..,.:...,,--- gm,4. /(#.a o
I Relinquished by: (Signature) Receiv -tsy; (Signature) Date/TimeI
., ...---r-plid„.0„.....„.........,
Methodpf�hLprtt®nt:,/'' r/‘ Logged In b : -'---�
`�� ��-- ,-z a Initials Moved to bioassay dept.by:
3 (} Inliialg9 Date " ''t° Time
I Note: Original sent with shipment ��;
Copy retained by collector
I Pfj.Sox 473• 106 Short Street•Kornarevilie,North Carolina 272 4•338^888,2H41 •Fax 338-888nQ32E3
www,randelaba,Qom
I

Odom
169 Oak Street • Forest City,NC 28043
Engineering PLLC office 828.247.4495 • fax [phone]
March 13, 2020 ** Via Certified Mail—Return Receipt Requested **
I
Ms. Nicole Harmon
Town Clerk,Town of Boone
567 West King Street
Boone, NC 28607
Re: Local Government Review Form
On behalf, Cottages of Boone WWTP
NPDES Conjunctive Use Application
Boone,Watauga County, NC
Dear Ms. Harmon:
The Cottages of Boone WWTP is a private wastewater treatment plant serving The Cottages of Boone, at 615
Fallview lane, Boone, NC,under Permit No.WQ0035784.This permit provides for drip Irrigation disposal of treated
effluent.The Cottages of Boone WWTP is making application through NCDEQ Complex Permitting Unit for NPDES
Conjunctive Use,which will permit continued irrigation,to be supplemented by discharge of treated effluent to
Laurel Fork,a stream In the Watauga River Basin. NCDEQ has reviewed the proposed discharge and receiving
stream and Issued Speculative Effluent Limits(attached)for technologically feasible,environmentally sound
discharge at the proposed discharge location.
As required by North Carolina General Statute[143-215.1(c)(6)),prior to submitting the application for a NPDES
Permit,the applicant shall request that both the nearby city and county government complete the attached Local
Government Review Form.The purpose of the form is to determine if the nearby city or county has a zoning or
subdivision ordinance in effect and(if such an ordinance is in effect)whether the proposed facility is consistent
with the ordinance.The nearby city or county must respond within 15 days of receipt of this request.The attached
maps show location of the WWTP and proposed discharge location. We would be pleased to answer any questions
you may have concerning the attached form or the proposed permit.
Please Return the completed,signed and notarized form to:
Odom Engineering. PLLC
169 Oak Street
Forest City, NC 28043
Thank you for your assistance in completing the application requirements for this important project.
Sincerely,
la
David Odom, P.E.
Attachments:
Local Government Review Form
USGS&8%z" by 11"Site Maps
NPDES Speculative Effluent Limits Letter

Local Government Review Requirements
for the Issuance of New Non-Municipal Domestic Wastewater Discharge Permits
General Statute Overview
North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance of NPDES Permits for non-
municipal domestic wastewater treatment facilities. Specifically,the Environmental Management Commission(EMC)may not act
on an application for a new non-municipal domestic wastewater discharge facility until it has received a written statement from
each city and county government having jurisdiction over any part of the lands on which the proposed facility and its
appurtenances are to be located. The written statement shall document whether the city or county has a zoning or subdivision
ordinance in effect and(if such an ordinance is in effect)whether the proposed facility is consistent with the ordinance. The
EMC shall not approve a permit application for any facility which a city or county has determined to be inconsistent with zoning
or subdivision ordinances unless the approval of such application is determined to have statewide significance and is in the best
interest of the State.
Instructions to the Applicant
Prior to submitting an application for a NPDES Permit for a proposed facility,the applicant shall request that both the
nearby city and county government complete this form.
The applicant must:
• Submit a copy of the permit application(with a written request for this form to be completed)to the clerk of the
city and the county by certified mail,return receipt requested.
• If either(or both)local government(s)fail(s)to mail the completed form,as evidenced by the postmark on the
certified mail card(s),within 15 days after receiving and signing for the certified mail,the applicant may submit the
application to the NPDES Unit.
• As evidence to the Commission that the local government(s)failed to respond within 15 days,the applicant shall
submit a copy of the certified mail card along with a notarized letter stating that the local government(s)failed to
respond within the 15-day period.
Instructions to the Local Government
The nearby city and/or county government which may have or has jurisdiction over any part of the land on which the
proposed facility or its appurtenances are to be located is required to complete and return this form to the applicant
within 15 days of receipt. The form must be signed and notarized.
Name of local government ' '� "" '`
(City/County)
Does the city/county have jurisdicion over any part of the land on which the proposed facility and its appurtenances
are to be located? Yes [ ] No [WI If no,please sign this form,have it notarized,and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ] No [ ]
If there is a zoning or subdivision ordinance in effect,is the plan for the proposed facility consistent with the
ordinance? Yes [ J No [ J n
Date 1-ila?- 2� �' Signature_
(City anager/County Manager)
State of Moriti Cal/Olivia ,County of UA1a1Z1 uq a
On this 22•nd day of r1 l ,2O personally appeared before me,the said
name John A,V a d t nt to me known and known to me to be the person
described in and who executed the foregoing document and he (or she) acknowledged that he (or she)
executed the same and being duly sworn by me,made oath that . • • • • -• .. • ent
are true. D Nicole Harmon
TA
My Commission expires 2.8.Zl .(Signature of Nota s, Pub
mars u lic(Officia Seal)
My Commission Expires February 08,2021

c0
x OCOifli 1'..
169 Oak Street • Forest City,NC 28043
• office 828.247.4495 • fax [phone]
.tngineering PLLC
March 13, 2020 **Via Certified Mail—Return Receipt Requested **
Ms.Anita Fogle
Watauga County Clerk
814 West King Street, Suite 205
Boone, NC 28607
Re: Local Government Review Form
On behalf, Cottages of Boone WWTP
NPDES Conjunctive Use Application
Boone,Watauga County, NC
Dear Ms.Fogle:
The Cottages of Boone WWTP is a private wastewater treatment plant serving The Cottages of Boone,at 615
Fallview lane, Boone,NC, under Permit No.WQ0035784.This permit provides for drip irrigation disposal of treated
effluent.The Cottages of Boone WWTP is making application through NCDEQ Complex Permitting Unit for NPDES
Conjunctive Use,which will permit continued irrigation,to be supplemented by discharge of treated effluent to
Laurel Fork,a stream In the Watauga River Basin. NCDEQ has reviewed the proposed discharge and receiving
stream and issued Speculative Effluent Limits(attached)for technologically feasible,environmentally sound
discharge at the proposed discharge location.
As required by North Carolina General Statute [143-215.1(c)(6)],prior to submitting the application for a NPDES
Permit,the applicant shall request that both the nearby city and county government complete the attached Local
Government Review Form.The purpose of the form is to determine if the nearby city or county has a zoning or
subdivision ordinance in effect and(if such an ordinance is In effect)whether the proposed facility is consistent
with the ordinance.The nearby city or county must respond within 15 days of receipt of this request.The attached
maps show location of the WWTP and proposed discharge location. We would be pleased to answer any questions
you may have concerning the attached form or the proposed permit.
Please Return the completed,signed and notarized form to:
Odom Engineering. PLLC
169 Oak Street
Forest City, NC 28043
Thank you for your assistance in completing the application requirements for this important project.
Sincerely,
David Odom, P.E.
Attachments:
Local Government Review Form
USGS&8%" by 11"Site Maps
NPDES Speculative Effluent Limits Letter

I
I Local Government Review Requirements
for the Issuance of New Non-Municipal Domestic Wastewater Discharge Permits
General.Statute OveQjew
I North Carolina General Statute 143-215.1 (c)(6)allows input from local governments in the issuance of NPDES Permits for non-
municipal domestic wastewater treatment facilities. Specifically,the Environmental Management Commission(EMC)may not act
on an application for a new non-municipal domestic wastewater discharge facility until it has received a written statement from
each city and county government having jurisdiction over any part of the lands on which the proposed facility and its
I
appurtenances are to be located. The written statement shall document whether the city or county has a zoning or subdivision
ordinance in effect and(if such an ordinance is in effect)whether the proposed facility is consistent with the ordinance. The
EMC shall not approve a permit application for any facility which a city or county has determined to be inconsistent with zoning
I or subdivision ordinances unless the approval of such application is determined to have statewide significance and is in the best
interest of the State.
Instructions to the Applicant
I Prior to submitting an application for a NPDES Permit for a proposed facility,the applicant shall request that both the
nearby city and county government complete this form.
The applicant must:
I . Submit a copy of the permit application(with a written request for this form to be completed)to the clerk of the I
city and the county by certified mail,return receipt requested.
e If either(or both)local government(s)fail(s)to mail the completed form,as evidenced by the postmark on the
certified mail card(s),within 15 days after receiving and signing for the certified mail,the applicant may submit the
I application to the NPDES Unit,
♦ As evidence to the Commission that the local government(s)failed to respond within 15 days,the applicant shall
submit a copy of the certified mail card along with a notarized letter stating that the local government(s)failed to
respond within the 15-day period.
IInstructions to the Local Government
The nearby city and/or county government which may have or has jurisdiction over any part of the land on which the
I proposed facility or its appurtenances are to be located is required to complete and return this form to the applicant
within 15 days of recei t. The form must be signed and notarized.
I Name of local government /t a��U.6r7
-.\ r ' (City ff ounty).
Does the citycoun ave over anypart of the land on whiro proposed facilityand its appurtenances
� � jurisdiction 1' P pp
Iare to be located? Yes X No [ ] If no,please sign this form,have it notarized,and return it to the applicant.
Does the cit(county/have in effect a zoning or subdivision ordinance? Yes �(t] No I ]
IIf there is a zoning or subdivision Qrdinance in effect,is the plan for the proposed facility consistent with the
ordinance? Yes {�( No [ ]
II Date7 - a-C)v� 7! Signatur I' v
giwatia=rger/County MiTriTRr--}(7;•4'r,4.).`,
IState of 1" C. , County of L,Dry-{ra_tR(a,
On this a rl '1 day of A9.rt ,1.i personally appeared before me,the said
Iname 3p_SC' 'l. F(-tcYY1an to me known and known to me to be the person
described in and who executed the foregoing document and he (or she) acknowledged that he(or she)
I executed the same and being duly sworn by me,made oath that the statements in the foregoing document
are true.
My Commission expires.3-.31-) i--!- ,(Signature of Notary Public) P *d'T CI,,,a5o.. reTi1 771'►a 1
t ` =
,�� 'she-county i
f`to. ,/ My Commission Expires
• , ,
- March 31,2024