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NC0022098_Permit (Issuance)_20110624
NPDES DOCUHENT SCANNING COVER SHEET NC0022098 Cranbrook Village WWP NPDES Permit: Document Type: 4ermit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: June 24, 2011 Thi�a document its printed on reuse paper - ignore any content on the re-sreriale aide 4/147A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary June 24, 2011 Mr. Eric Fairman, Operations Manager Cranbrook Village Communities, LLC 821 West 11 Mile Road Royal Oak, MI 48067 Subject: Issuance of NPDES Permit NC0022098 Cranbrook Village Communities Mobile Home Park WWTP Guilford County Dear Mr. Fairman: Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). This final permit includes no significant changes from the draft permit sent to you on April 27, 2011. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required. if you have any questions concerning this permit, please contact Bob Sledge at telephone number (919) 807- 6398, or via e-mail at bob.sledge@ncdenr.gov. Coleen H. Sullins cc: Central Files Winston-Salem Regional Office/Surface Water Protection Section NPDES Unit 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbur}f St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807.6492 \ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity\Affirmative Action Employer NorthCarolina aturalli • Permit NC0022098 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT. TO DISCHARGE WASTEWATER UNDER TFIE NATIONAL POLLUTANT DISCHARGE ELIIVIINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Cranbrook Village Communities, LLC is hereby authorized to discharge wastewater from a facility located at the Cranbrook Village WWTP 4309 Liberty Road Guilford County to receiving waters designated as Little Alamance Creek in the Cape Fear River Basin in accordance with effluent limits, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective August 1, 2011. This permit and authorization to discharge shall expire at midnight on June 30, 2016. Signed this day June 24, 2011. Cen H. Sullins, Direc Division of Water Quality By Authority of the Environmental Management Commission • • • Permit NC0022098 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions; requirements, terms, and provisionsincluded herein. Cranbrook Village Communities, LLC is hereby authorized to: 1. Continue to operate an existing 0.01 MGD wastewater treatment facility with the following components: • Influent grinder pump station ♦ . Aerated digester / sludge holding tank (underground) • Bar screen • Aeration basin • Clarifier • Effluent chlorination with chlorine contact basin • Dechlorination This facility is located southeast of Vandalia, at 4309 Liberty Road, at the Cranbrook Village Communities WWTP in Guilford County. 2. Discharge from said treatment works at the location specified on the attached map into Little Alamance Creek, classified WS-IV NSW waters in the Cape Fear River Basin. Permit NC0022098 N j.. 7,90 u -,/ ,, . rC � •. "' `� t.� • . .S •�` w . 43 • )• `� d Y. • 44) 1 arge 0 ,� �I 1 1 "'00 f i I` � ' ` �'am' j .3 . v�l"\ ri �r �. •� 1 r'J 79� '\ ir�� �= Get' > r r ,, �� i f : • ii gf 4 eet11 1 1• 1a�i�/ 1.�" ! l..gem_fif ' aF `. ',.1 G � %1 moo . C- .• r am , • 1, —. ,,, --,A ti v, ! -); ,s. i L: . 'tL 1-1-"'�r�'' j 3,\ ( v •- 7 '7"'_\. .: `' .... ram. / I( (-') i /f/ii- n • )..,/--)..... . \ �� 5 i (. (6----_-,\N:._' .-- '„N, r,,,l(--. I (Lr/ :-�_{1.•II�� \1Z1! •. '. --- r r • )�/,IA- i if ,. ( l• iy' l- 7.,...._,,,i...... _,. _ fe ,_.) if . ! : . Latitude: 36000'10" NC0022098 Longitude:79045'08" Quad # C19SE (Greensboro, N.C.) Stream Class: WS-IV; NSW Cranbrook Village Communities, LLC Subbasin: 03-06-03 Facility 7 � •' �� Location 4 Cranbrook Village WWTP Receiving Stream: Little Alamance Creek (Guilford County) North NOT TO SCALE • Permit NC0022098 A. (1.) EFFLUENT LIMITS AND MONITORING REQUIREMENTS — FINAL During the period beginning on the effective date of this permit and lasting until expiration, the permittee is authorized to discharge treated wastewater from outfall 001. Such discharges shall be limited and monitored by the permittee as specified below: • • EFFLUENT CHARACTERISTICS Parameter Description - PCS Code .. EFFLUENT: LIMITS : ' MONITORING REQUIREMENTS Month A verage DailY Maximum Measurement Frequency. Sample Type .. - Samle P. , Location Flow, in conduit or thru treatment plant - 50050 0.01 MGD Weekly Instantaneous influent or Effluent BOD, 5-Day (20 Deg. C) - 00310 • 30.0 mglL 45.0 mg/L Weekly Grab Effluent Solids, Total Suspended - 00530 30.0 mg/L 45.0 mg/L Weekly Grab Effluent Nitrogen, Arnmonia Total (as N) - 00610 - Winter 24.0 mg/L 35.0 mg/L Weekly Grab Effluent Nitrogen, Ammonia Total (as N) - 00610 - Summer 3.8 mglL 19.0 mg/L Weekly ' Grab Effluent Coliform, Fecal MF, M-FC Broth,44.5C - 31616 (geom.mean) 200/100 ml 400/100 ml Weekly Grab Effluent pH1 - 00400 Weekly Grab Effluent Chlorine, Total Residual2 - 50060 28 pg/L 2 /week Grab Effluent Temperature, Water Deg. Centigrade - 00010 Daily (weekdays) Grab Effluent Phosphorus, Total (as P) - 00665 Quarterly Grab Effluent Nitrogen, Total (as N)3 - 00600 Quarterly Grab Effluent Nitrogen, Kjeldahl, Total (as N) - 00625 Quarterly Composite Effluent Nitrite plus Nitrate Total 1 DET. (as N) - 00630 Quarterly Composite Effluent Winter: November 1- March 31 Summer: April 1- October 31 Footnotes: 1. The pH shall not be less than 6.0 standard units (s.u.) nor greater than 9.0 s.u. 2. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µme• 3. TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and NO3-N and NO2-N are Nitrate and Nitrite Nitrogen, respectively There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC0022098 A. (2) PERMIT RE -OPENER: NUTRIENT MONITORING Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II sections B- 12 and B-13 of this permit, the Director may reopen this permit to require supplemental nutrient monitoring of the discharge. The purpose of the additional monitoring will be to support water quality modeling efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan developed jointly by the Division and affected stakeholders. In addition, the results of water quality modeling may require that limits for Total Nitrogen and Total Phosphorus be imposed in this permit upon renewal. ATA. NCDERI North Carolina Department of Environmentand Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee. Freeman • Governor Director Secretary • April 27, 2011 MEMORANDUM To: Lisa Edwards NC DENR / DEH / Assistant Regional Engineer Winston-Salem Regional Office From: Bob Sledge 6(1' Compliance & Expedited Permits Unit Subject:. Review of Draft NPDES Permit NC0022098 Cranbrook Village Communities WWTP Guilford County Please indicate below your agency's position or viewpoint on the draft permit and return this form by June 1, 2011.. If you have any questions on the draft permit, please contact.me at (919) 807-6398 or via e-mail at bob.sledge@ncdenr.gov. RESPONSE: (Check one) Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. riConcurs with issuance of the above permit,• provided the following conditions are met: riOpposes the issuance of the above permit, based on reasons stated below, or attached: • Signed Oe& 1817 Mall Service -Center, Raleigh, North Carolina 27699.1617 Location: 512 N. Salisbury St: Raleigh, North Carolina 27604 • Phone: 919.807-63001 FAX: 9194307.84921 Customer Service:1.8774323-6748 Internet w++w.ncwaten;uattty org" An Equal Opportunity 1 Atilrmaiive Aden Employer _3-9 Date: News & Record Name Published by News & Record, Inc. Greensboro, North Carolina AFFIDAVIT OF North Carolina, Guilford County Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to administer oaths, personally appeared the Publisher's Representative who being first duly sworn, deposed and says: 1. That he/she is the Publisher's Representative of the Greensboro News & Record, Inc. a corporation, engaged in the publication of newspapers known as 'News & Record", published, issued and entered as second class mail in the City of Greensboro in said County and State. 2. That he/she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a copy of which is attached hereto, was published in the News & Record on the dates listed below. 3. That the said newspaper (or newspapers) in which such notice, paper, document, or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning of Section 1-59; of the General Statutes of North Carolina. Publisher's Representative Sworn to and subscribed befo e, this k. Q A LOU(‘'L Notary Public Ad # Date Edition NCDENR DWQ NPDES 34220325 04/28/11 News & Record Class PO Ad Copy `.�`\\\ P4NE/ "0/. 6�. �oTAR J- My Comm. Exp. 6/15/2014 ��G PUBLIC 400 Cranbrook Vi Public NoticeNorth Carolina Environmenta Ad IDl34220325 Date 04/27/2011 Time 13:06 PM Pubk Notice North Carolina Environmental Management Corrrission'NPDB Unit 1617 Mail Service Center Ralegh NC 27699-1617 Notice of Intent to Issue a NPDI5 Wastewater Perrrit The North Carolina Environmental ManagerrEntCorrrrission proposes to issue a NPDES wastewater discharge permit to the person(s) listed below Written comments regarding the proposed permit wil be accepted until 30 days after the pubish date of this notice. The Director of the NC Division of Water Quality (WVQ) rruy hold a pubk hearing should there be a significant degree of pubk interest Please rrei comments andlor information requests to DWQ atthe above address Interested persons rruy vkk the D Q at 512 N. Salisbury Street Raleigh NCto review information on file Additional information on NPDB pemiis and this notice may be found on our website: http//portaLncden r orgfwebhngwp/p s/npdeskalendar, or by calling (919) 880077-6304 Cranbrook Village Corrmuniies, LLC requested renewal of perrrit NC0022098 for the Cranbroo_k Village WWIP in Guilford County, this discharge is treated domestic wasteweterto little Alarrance Creek in the Cape Fear River Basin. Ad shown is not actual print size • Sledge, Bob From: Basinger, Corey Sent: Wednesday, April 20, 2011 10:50 AM To: Sledge, Bob Subject: RE: NC0022098 Permit Renewal Draft looks ready to issue. Thanks. CB W. Corey Basinger Supervisor, Winston-Salem Regional Office Surface Water Protection Section Division of Water Quality Corev.Basinger@ncdenr.Rov NC DENR Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 (336) 771-5000 Fax (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Sledge, Bob Sent: Friday, April 15, 2011 12:57 PM To: Basinger, Corey Subject: NC0022098 Permit Renewal Hi Corey, I'm sure you're busy, so I hate to send anything your way, but right now I don't know who else to send this to. This is simply a draft of the permit we'd propose to send to Cranbrook Village Communities (formerly Cedar Village Communities) in Guilford County. It doesn't look much different in form than the current permit, but since I didn't hear of any obvious compliance concerns, I took out the 2006 condition for a wastewater management plan. If y'all think it's ok to push out the door, I'll send it to them in a few weeks during our next public notice period. Let me know if WSRO wants any changes made. Thank you. Y'all have a fine weekend. Bob Bob Sledge Environmental Specialist Compliance & Expedited Permits Unit NC Division of Water Quality bob.sledge@ncdenr.gov (919) 807-6398 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. 1 FACT SHEET FOR EXPEDITED PERMIT RENEWALS This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Basic Information for Expedited Permit Renewals Permit Writer/Date Bob Sledge 4/26/2011 Permit Number NC0022098 Facility Name Cranbrook Village Communities WWTP Basin Name/Sub-basin number Cape Fear/03-06-03 Receiving Stream Little Alamance Creek (6u.,ii.: J C..) Stream Classification in Permit WS-IV, NSW Does permit need Daily Max NH3 limits? No, existing Does permit need TRC limits/language? QL language added to footnotes Does permit have toxicity testing? No Does permit have Special Conditions? No — removed Waste Management Plan Does permit have instream monitoring? No Is the stream what parameter? impaired (on 303(d) list)? For No (a Little Alamance Creek in Alamance County is listed; this is a different stream) Any obvious compliance concerns? No Any permit mods since last permit? Added dechlorination Current expiration date 06/30/2011 New expiration date 06/30/2016 Comments received on Draft Permit? Approved for transmittal to permittee Most Commonly Used Expedited Language: • 303(d) language for Draft/Final Cover Letters: "Please note that the receiving stream is listed as an impaired waterbody on the North Carolina 303(d) Impaired Waters List. Addressing impaired waters is a high priority with the Division, and instream data will continue to be evaluated. If there is noncompliance with permitted effluent limits and stream impairment can be attributed to your facility, then mitigative measures may be required". • TRC language for Compliance Level for Cover Letters/Effluent Sheet Footnote: "The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L.." BIMS Compliance Download: Queries>Reports>Violations>Monitor Report Violations>Limit Violations for Past 3 Years Reminder: Permits that are not subject to expedited renewal include the following: 1) Major Facility (municipal/industrial); 2) Minor Municipals with pretreatment program; 3) Minor Industrials subject to Fed Effluent Guidelines (lb/day limits for BOD, TSS, etc); 4) Limits based on reasonable potential analysis (metals, GW remediation organics); 5) Permitted flow > 0.5 MGD (requires full Fact Sheet); 6) permits determined by Supervisor to be outside expedited process. Note: This sheet is located on NPDES Server/CurrentVersions/Expedited Fact Sheet May2010 CRANBROOK VILLAGE COMMUNITIES, L.L.C. 301 West Fourth Street, Suite ;440 Royal Oak, MI 48067 Phone: (248) 399-7722 + Fax: (248) 399-9975 E-Mail: eric@oakridgemgt.com December 15, 2010 Mrs. Dina Sprinkle North Carolina Department of Environment And Natural Resources Division of Water Quality Point Source Branch 1617 Mail Service Center Raleigh, North Carolina 27699-1617 RE: Renewal Notice NPDES Permit NC0022098 Owner: Cranbrook Village Communities, L.L.C. Facility Name: Cranbrook Village WWTP also known as Cedar Valley Guilford County CcO7f Please consider this letter our request to renew NPDES Perrnit NC0022098 for Cranbrook Village WWTP. Enclosed you will find all the necessary completed forms and copies per your instructions/check list. Please note that we have added a declorination tablet feeder (see November 8, 2007 "Authorization to Construct" letter attached) to this facility since the issuance of the last permit. Very truly yours, Eric Fairman Operations Manager /lsw Enclosures: Cover letter (original and 2 copies) Completed application and Map (original and 2 copies) Sludge Narrative (original and 2 copies) S:\AAPARXS\ACTIVE\Norlh Carolina\CV - Cranbrook Village\Permanent\Sewer \Permi\T-l-I 1 to 6-30-XXWPDES Renewal 12-14-10 cover lettcr.doc 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 INC0022098 ©CPY 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: Owner Name Facility Name Mailing Address City State / Zip Code Telephone Number Fax Number e-mail Address Cranbrook Village Communities, L.L.C. Cranbrook Village WWTP 301 W, Fourth Street, Suite 440 Royal Oak Michigan 248-399-7755 248-399-9975 lelal oakridgemgt.com 2. Location of facility producing discharge: Check here if same address as Street Address or State Road City State / Zip Code County above ❑ 4309 Liberty Road Greensboro NC 27406 Guilford 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 Paul Smith Mailing Address City State / Zip Code Telephone Number Fax Number 235 Richardson Road Reidsville NC 27320 336-932-9347 336-342-9784 1 of 3 Form-D 05/08 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 0 Number of Employees Residential ® Number of Homes School 0 Number of Students/Staff Other 0 Explain: 85 Describe the source(s) of wastewater (example: subdivision, mobile home park, shopping centers, restaurants, etc.) : Mobile Home Park Population served: 170 5. Type of collection system ® Separate (sanitary sewer only) ❑ Combined (storm sewer and sanitary sewer) 6. Outfall Information: Number of separate discharge points 1 Outfall Identification number(s) 001 Is the outfall equipped with a diffuser? ® Yes ❑ No 7. Name of receiving stream(s) (Provide a map showing the exact location of each outfall): Little Alamance Creek 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. Influent Grinder Pump Station, aerated digester/sludge holding, bar screen, aeration basin, clarifier, effluent chlorination, dechlor tablet feed; sludge is hauled by septic tank company Carolina Septic Tank 2 of 3 Form-D 05/08 NPDES APPLICATION - FORM D For privately owned treatment systems treating 100% domestic wastewaters <1.0 MGD 10. Flow Information: Treatment Plant Design flow 0.010 MGD Annual Average daily flow 0.009 MGD (for the previous 3 years) Maximum daily flow 0.010 MGD (for the previous 3 years) 11. Is this facility located on Indian country? DI Yes ®No 12. Effluent Data 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. Parameter Daily Maximum Monthly Average Units of Measurement Biochemical Oxygen Demand (BOD5) 35 20 MG/L Fecal Coliform 50 10 100/200 ml Total Suspended Solids 35 15 MG/L Temperature (Summer) 28 22 °C Temperature (Winter) 8 8 °C pH 7.5 7.2 SU 13. List all permits, construction approvals and/or applications: Type Hazardous Waste (RCRA) UIC (SDWA) NPDES PSD (CAA) Non -attainment program (CAA) Permit Number NC0022098 14. APPLICANT CERTIFICATION Type NESHAPS (CAA) Ocean Dumping (MPRSA) Dredge or fill (Section 404 or CWA) Other Permit Number 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. Eric Fairman Operations Manager Printed name of Person Signing Title 4: .7-2L---- 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 05/08 CRANBROOK VILLAGE COMMUNITIES, L.L.C. 301 West Fourth Street, Suite 440 Royal Oak, MI 48067 Phone: (248) 399-7722 • Fax: (248) 399-9975 E-Mail: eric@oakridgemgt.com December 15, 2010 Mrs. Dina Sprinkle North Carolina Department of Environment And Natural Resources Division of Water Quality Point Source Branch 1617 Mail Service Center Raleigh, North Carolina 27699-1617 RE: Renewal Notice NPDES Permit NC0022098 Cranbrook Village WWTP Guilford County Sludge Management The sludge management plan and policy for this plant is as follows: Solids are removed from the WWTP as necessary by a licensed contract hauler (Carolina Septic) and disposed of properly. Very truly yours, Eric Fairman Operations Manager ilsw S;\AAPARKS\ACTIVE\North Carolina\CV - Cranbrook Village\Permanent\Sewer\Permit\7-1-I 1 to 6-30-XX\NPDES Renewal 12-14-10 cover letter.doc