WQ0032352_Regional Office Physical File Scan Up To 9/13/2022

December 31, 2007
Alex D. Baker President
AIG Baker Cashiers, LLC .
1701 Lee Branch Lane
Birmingham, Alabama 35242
} Michael F. Easley, Governor
\ r William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Subject: Permit No. WQ0032352
Millstone Inn and Condominium
Development
Wastewater Surface Irrigation
Jackson County
Dear Mr. Baker:
In accordance with your permit application received on November 14, 2007, and subsequent
additional information received on December 12, 2007, we . are forwarding herewith Permit No.
WQ0032352, dated December 31,, 2007, to AIG Baker Cashiers, LLC for the construction and operation
of the subject wastewater treatment and surface irrigation, facilities.
This permit shall be effective .from the date of issuance until November 30, 2012, and shall be
subject to the conditions and limitations .as specified therein. Please pay .particular attention to the
monitoring requirements in this permit. Failure to establish an adequate system for collecting and
maintaining the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. 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, NC 27699-6714. Unless such demands are made this permit shall be final and binding.
One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this matter, please contact ,Lori Montgomery- Veal at, [phone] or
[e-mail].
Sincerely,
"'Z ('oleen H. Sullins
cc: Jackson County Health Department
As i v-ffle-Regional-Office; Agii E ProteHion-Secfi`on
Mark C. Brooks, P.E. — Brooks Engineering Associates
Technical Assistance and Certification Unit
APS Central Files
LAU Files
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: www.ncwaterquali .org Location: 2728 Capital Boulevard Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper.
NorthCarohna
�atura!!J -
Telephone : [phone]
Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
SURFACE 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
AIG Baker Cashiers, LLC
Jackson County
FOR THE
construction and operation of a 16,400 gallon per day (GPD) surface irrigation treatment and disposal
facility consisting of
two (2) 22,000-gallon septic tanks connected in series; one (1) 25,000-gallon fitrate recirculation tank
with an audible/visual high water alarm; four (4) 57 -gallon per minute (GPM) filter dosing pumps; eight
(8) Advantex textile media bio-filter units; two (2) flow splitter basins for routing effluent back to the
septic tank and recirculation tank; two (2) ultraviolet disinfection modules connected in series with two
(2) lamps each; one (1) 6,000-gallon dosing tank with dual 39 GPM irrigation pumps; one (1) 1,600-
gallon grease trap to serve the Inn restaurant; one (1) 295,200-gallon wet weather storage tank with
eighteen (18) days of effective storage; a carbon feed system for enhanced denitrification; 16,708 linear
feet (1.£) of drip tubing serving six (6) irrigation zones totaling 2.11 acres; one (1) 1,200-gallon irrigation
system flush return pump tank with dual 20 GPM return pumps and audible/visual high water alarms; a
rainfall sensor to prevent irrigation during precipitation. events; and a 80 kW natural gas -powered backup
generator;
to serve seven (7) bedrooms and a fifty (50) seat full service restaurant at Millstone Inn, and 113
bedrooms at Millstone Condominium Development, with no discharge of wastes to the surface waters,
pursuant to the application received November 14, 2007, and subsequent additional information received
by the Division of Water Quality (Division), and in conformity with the project plan, specifications, and
other supporting data subsequently filed and approved by the Department of Environment and Natural
Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until November 30, 2012, and shall be
subject to the following specified conditions and limitations:
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I.
SCHEDULES [please revv"�, __'rie entire pennit_for reporting, monitoring' ,Id other on -going activities]
Upon completion of construction and prior to operation of this permitted facility, a certification (si
attached form) must be received from a professional engineer certifying that the permitted facility h
been installed in accordance with this pennit, the approved plans and specifications, and oth__
supporting materials including the location of all monitoring wells as applicable. If this project is to
be completed in phases and partially certified, you shall retain the responsibility to track further
construction approved under the same permit, and shall provide a final certificate of completion once
the entire project has been completed. Mail the Certification to the Aquifer Protection Section,
Division of Water Quality, 1636 Mail Service Center, Raleigh, NC 27699-1636.
2. The Asheville Regional Office, telephone number [phone], shall be notified at least forty-
eight (48) hours in advance (excluding weekends and holidays) of operation of the installed facilities
so that an in -place inspection can be made. Such notification to the regional supervisor shall be made
during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding
State Holidays.
3. Monitoring wells MW-1, MW-2, MW-3, MW-4, MW-5 and I MW-6 shall be approved by the
Asheville Regional Office, telephone number [phone] prior to installation and installed prior
to beginning waste disposal operations. The regional office shall be notified at least forty-eight (48)
hours prior to (excluding weekends and holidays) the construction of any monitoring well. Such
notification to the regional Aquifer Protection supervisor shall be made during the normal office
hours from 8:00 a.m. until 5:00 p.m. on -Monday through Friday, excluding State Holidays. The
well(s) shall be constructed such that the water level in the well is never above or below the screened
(open) portion of the well at any time during the year and in accordance with 15A NCAC 02C .0108.
The general location and name for each well is marked on Figure 2 — Monitoring Locations. See also
well construction form submittal requirements in Section IV. of this permit.
4. Within sixty (60) days of completion of all monitoring well(s), the permittee shall submit two original
copies of a scaled site mdp (scale no greater than 1"=100'); however, special provisions may be
granted upon prior approval for large properties. The map(s) must include the following information:
a. The location and identity of each monitoring well.
b. The location of major components of the waste disposal system.
c. The location of property boundaries within 500 feet of the disposal area(s).
d. The latitude and longitude of the established horizontal control monument.
e. Theelevation of the top of the well casing (which shall be known as the "measuring point")
relative to a common datum.
f. The depth of water below the measuring point at the time the measuring point is established.
g. The location of review and compliance boundaries.
h. The date the map is prepared and/or revised.
Control monuments shall be installed in such a manner and made of such materials that the
monument will not be destroyed due to activities that may take place on the property. The maps and
any supporting documentation shall be sent to the N.C. Division of Water Quality, Aquifer Protection
Section, 1636 Mail Service Center, Raleigh, N.C. 27699-1636. The permittee is responsible for the
geographic accuracy of a?ay map submitted, however produced.
No later than six (6) months prior to the expiration of this permit, the Permittee shall request renewal
of this permit on official Division form(s). Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will extend the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note that Rule
15A NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
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i
Permit No. WQ0032352
December 31, 2007
ENGINEER'S CERTIFICATION
Partial Final
as a duly registered Professional Engineer in the State
of North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of
the project,
Project Name Location and County
for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of this permit, the approved plans and specifications, and.other supporting
materials.
Signature Registration No.
Date
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Permit issued this the 3Ist dr if December, 2007 °a
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
oleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0032352 "
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JF2. The Permittee or his de,__._-,e shall inspect the wastewater treatmenI,,, l disposal facilities to prevent
malfunctions and deterioration; operator errors and discharges which may cause or lead to the release
of wastes to the environment, a threat to human health, or a nuisance. The Pennittee shall keep an
inspection log or summary including at least the date and time of inspection, observations made, and
any maintenance, repairs, or corrective actions taken by the Pennittee. This log of inspections shall
be maintained by the Permittee for a period of five years from the date of the inspection and shall be
made available upon request to the Division or other permitting authority.
3. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or
facility at any reasonable time for the purpose of determining compliance with this permit; may
inspect or copy any records that must be maintained. under the terms and conditions of this permit,
and may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
Failure to abide by the conditions and limitations contained in this permit may subject the Permittee
to an enforcement action by the Division in accordance with North Carolina General Statute 143-
215.6A to 143-215.6C.
2. This permit shall become voidable unless the facilities are constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3.. This permit is effective only with respect to the nature and volume of wastes described in the
application and other supporting data. No variances to applicable rules governing the construction
and. / or operation of the permitted facilities are granted unless specifically requested and. granted in
this permit.
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 government agencies (local, state,
and federal) that have jurisdiction. 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 the Division's General Permit NCG010000, and any requirements pertaining to
wetlands under 15A NCAC 02B .0200 and 02H .0500.
5. In the event there is a desire for the facilities to change ownership, or there is a name change of the
Permittee, a formal permit request must be submitted to the Division on official Division form(s),
documentation from the parties involved, -and other supporting materials as may be appropriate. The
approval of this request will be considered on its merits and may or may not be approved. The
Permittee of record shall remain fully responsible for compliance until a permit is issued to the new
owner.
The Permittee shall retain a set of approved plans and specifications for the life of the facilities
permitted herein.
7. The Pe='ttee shall maintain this permit until all permitted facilities herein are properly closed or
pennitted under another permit issued by the appropriate permitting authority.
8. The Permittee must pay the annual fee within thirty (30) days after being billed by the Division.
Failure to pay the fee accordingly may cause the Division to initiate action to revoke this permit
pursuant to 15A NCAC 02T .0105(e).
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Three (3) copies of all n,, oring data [as specified in Conditions I`, and IV. 4.] on Form NDMR
for each PPI and three (3) copies of all operation and disposal records Las specified in Conditions IV.
5 and IV. 6.] on Form NDAR-1 for every field 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 Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina27699-1617
10. An annual representative soils analysis (Standard Soil Fertility Analysis) shall be conducted on each
irrigation field and the results maintained on file by the Permittee for a minimum of five years. The
Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the following
parameters:
Acidity
Manganese
Potassium
Calcium
Percent Humic Matter
Sodium
Copper
pH
Zinc
Magnesium
Base Saturation (by calculation)
Phosphorus
Cation Exchange Capacity
Exchangeable Sodium Percentage
11. Noncompliance Notification:
The Permittee shall report by telephone to the Asheville Regional Office, telephone number (828)
296-4500, 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. Any occurrence at the wastewater treatment facility which results in the treatment of significant
amounts of wastes which are abnormal in quantity or characteristic, such as the dumping of the
contents of a sludge digester; the known passage of a slug of hazardous substance through the
facility; or any other unusual circumstances including ponding in the irrigation field or runoff
from the irrigation fields.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators,
compressors, etc.
c. Any failure of disposal system resulting in a by-pass directly to receiving waters.
d. Any time that self -monitoring information indicates that the facility has gone out of compliance
with its permit limitations including, but not limited to, freeboard measurements, effluent
limitations, exceedances of groundwater standards, or overloading of any field.
For any emergency that requires immediate reporting (e.g., discharges to surface waters, imminent
failure of a storage structure, etc.) outside normal business hours must be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or (919) 733-
3300. Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following first knowledge of the occurrence. This report must outline the actions
taken or proposed to be taken to ensure that the problem does not recur.
V. INSPECTIONS
1. Adequate inspection and maintenance shall be provided by the Permittee to ensure proper operation
of the subject facilities.
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3. .Flow through the treatn:. � facility shall be continuously monitorer,__. id daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device consistent with
approved engineering and scientific practices to ensure the accuracy and reliability of flow
measurement. Flow measurement devices selected shall be capable of measuring flows with a
maximum deviation of less than 10 percent from true flow, accurately calibrated at a minimum of
once per year, and maintained to ensure that the accuracy of the measurements is consistent with the
accepted capability of that type of device. The Permittee shall keep records of flow measurement
device calibration on file for a period of at least three years. At a minimum, data to be included in
this documentation shall be:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
4. The wastewater treatment facility effluent and the surface water monitoring locations shall be
monitored by the Permittee at the frequency(ies) and location(s) for the parameter(s) specified in
Attachment A. Surface water monitoring locations are specified on Figure 2 — Monitoring locations.
5. The Permittee tracking the amount of wastewater disposed shall maintain" adequate records. These
records shall include, but are not necessarily limited to, the following information:
a. Date of irrigation,
b. Volume of wastewater irrigated,
c. Field irrigated,
d. Length of time field is irrigated,
e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings for each field,
f. Continuous monthly and year-to-date loadings for anynon-hydraulic parameter specifically
limited in Attachment B for each field,
g. Weather conditions, and
h. Maintenance of cover crops.
6. Monitor wells MW-1 through MW-6 shall be sampled after construction and within 3 months prior to
initiating waste disposal operations. Monitor wells shall be sampled thereafter at the frequencies and
for the parameters specified in Attachment C. All mapping, well construction forms, well
abandonment forms. and monitorinLy data shall refer to the hermit number and the well nomenclature
as provided in Attachment C and Figure 2 — Monitoring Locations.
7. For the initial sampling of the well as specified_ elsewhere in the permit, the permittee shall submit a
copy of the GW-1 Form (Well Construction Record) that lists this permit number and the appropriate
monitoring well identification number with the Compliance Monitoring Form (GW-59) for that well.
Initial Compliance Monitoring Forms that do not include copies of the GW-1 form are incomplete
and may be returned to the permittee without being processed.
8. Two (2) copies. of the results of the sampling and analysis must be received on Form GW-59
(Groundwater Quality Monitoring: Compliance Report Form), along with attached copies of
laboratory analyses, by the Division of Water Quality, Information Processing Unit, 1617 Mail
Service Center, Raleigh, North Carolina 27699-1617 on or before the last working day of the month
following the sampling month. Form GW-59 shall include the number of this permit and the
appropriate well identification number. One Form _GW-59a certification form shall be provided for
each set of sampling results submitted.
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2. Upon classification of' wastewater treatment and irrigation f. ;ties by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), the Permittee shall designate and
employ a certified operator to be in responsible charge (ORC) and one or. more certified operator(s) to
be back-up ORC(s) of the facilities in accordance with 15A NCAC 08G .0200. The ORC shall visit
the facilities in accordance with 15A NCAC 08G .0200 or as specified in this permit and shall comply
with all other conditions specified in these rules.
3. A suitable year round vegetative cover shall be maintained such that crop health is optimized, allows
for even distribution of effluent, and allows inspection of the irrigation system.
4. Adequate measures shall betaken: to prevent wastewater ponding or runoff from the irrigation field.
Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff.
6. All waste application equipment must be tested and calibrated at least once per year. Records of the
calibration must be maintained for five years.
7. No type of wastewater other than that from -Millstone Inn and Condominium Development shall be
irrigated onto the irrigation area.
8. An automatically activated standby power source shall be on site and operational at all times capable
of powering all essential treatment units. If a generator is employed as an alternate power supply, it
shall be tested weekly by interrupting the primary power source.
9. No traffic or equipment shall be allowed on the disposal area except while installation occurs or while
normal maintenance is being performed.
10. Public access to the land application sites shall be controlled. Such controls may include posting of
signs around the irrigation area(s) to warn the public about the disposal of treated wastewater.
11. The residuals generated from these treatment facilities must be disposed / utilized in accordance with
15A NCAC 02T .1100. The Permittee shall maintain a residual management plan pursuant to 15A
NCAC 02T .0508.
12. Diversion or bypassing of the untreated wastewater from the treatment facilities is prohibited.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (including groundwater, surface water, soil or plant tissue analyses) deemed
necessary by the Division to ensure surface and ground water protection will be established and an
acceptable sampling reporting schedule shall be followed.
2. All laboratory analyses for effluent, ground waters, or surface waters shall be made by a laboratory
certified by the Division for the required parameter(s) under 15A NCAC 02H .0800.
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The facilities permitted herein must be constructed according to the following setbacks:
a. The setbacks for Irrigation sites shall be as follows (all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership:
ii. 'Any habitable residence or place of public assembly owned by the permittee:
iii. Any private or public water supply source:
iv. Surface waters:
v. Groundwater lowering ditches:
vi. Surface water diversions:
vii. Any well with exception of monitoring wells:
viii.Any property line (per 15A NCAC 02T .0506(c)):
ix. Top of slope of embankments or cuts of two feet or more in vertical height:
x. Any water line from a disposal system:
xi: Subsurface groundwater lowering drainage systems:
xii. Any swimming pool:
xiii.Public right of way:
xiv. Nitrification field: -
xv. Any building foundation or basement:
b. The setbacks for Treatment and storage units shall be as follows (all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership:
ii. Any private or public water. supply source:
iii.. Surface waters:
iv. Any well with exception of monitoring wells:
v. Any property line:
100
15
100
100
100 .
25
100
0
15
10
100
100
50
-20
15
100
100
50
100
50
9. The Operational Agreement (Attached) between the Permittee and the Environmental Management
Commission is incorporated herein by reference and shall be a condition of this permit.
Noncompliance with the terms of the Operational Agreement shall subject the Permittee to all
sanctions provided by North Carolina General Statutes § 143-215.6A to § 143-215.6C for violation of
or failure to act in accordance with the terms and conditions of this permit.
10. The disposal system shall be connected to a rain or moisture sensor that shall indicate when
wastewater application is not appropriate in accordance with Condition III. 4. and M. 5. of this
permit.
III. OPERATION AND MAINTENANCE REQUIREMENTS
i. 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 pursuant to 15A NCAC 02T .0507 including operational functions, maintenance
schedules, safety measures, and a spill response plan.
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II. PERFORMANCE STAN)r j --bS
The surface irrigation facilities shall be effectively maintained and operated at all times so that there
is no discharge to the surface waters, nor any contravention of groundwater or surface water
standards. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance .conditions or failure of the irrigation area to adequately assimilate the wastewater, the
Permittee shall take immediate corrective actions including those actions that may be required by the
Division, such as the construction of additional or replacement wastewater treatment and disposal
facilities.
2. The issuance of this pen -nit shall not relieve the Permittee of the responsibility for damages to ground
or surface waters resulting from the operation of this facility.
All wells that are 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 state and local laws and regulations pertaining to well construction.
4. Effluent limitations shall not exceed those specified in Attachment A. Surface water monitoring
locations shall be sampled for the parameters and at the frequencies listed in Attachment A.
5. Application rate(s), whether hydraulic, nutrient, or other pollutant shall not exceed those specified in
Attachment B.
The Compliance Boundary and Review Boundary for the disposal system are specified by 15A
NCAC 02T .0506(c). The Compliance and Review boundaries shall be 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. An exceedance of groundwater .standards at or
beyond the compliance boundary is subject to remediation action according to 15A NCAC 02L
.0106(d)(2) as well as enforcement actions in accordance with North Carolina General Statute 143-
215.6A through 143-215.6C.
7. The Permittee shall apply for a permit modification prior to any sale or transfer of property that
affects a compliance boundary to establish a new compliance boundary.
8. In accordance with 15A NCAC 02L .0107(d), no wells, other than monitoring wells, shall be
constructed within the compliance boundary except as provided by 15A NCAC 02L .0107(g).
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ATTACHMENT A - LIMITATIONS AND MONITORING REQUIREMENTS
Millstone Inn and Condominium Development
PPI 001= WWTF Effluent
Permit Number: WQ0032352 Version: 1.1
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Parameter Description - PCS Code
Monthly Average'
Weeltiy Average
Daily Maximum`
Measurement
Frequency
Sample
Type
Flow — in conduit or thru treatment plant - 50050
16,400
GPD
Continuous
Recorder
BOD, 5-Day (20 Deg. C) - 00310
10
mg/1
15
mg/l
2 X month
Grab
Solids, Total Suspended - 00530
5
mg/l
10
mg/l
2 X month
Grab
Nitrogen, Ammonia Total (as N) - 00610
4
mg/l
6
mg/l
2 X month
Grab
Nitrogen, Nitrate Total (as N) - 00620
10
mg/1
2 X month
Grab
Coliform, Fecal MF, M-FC Broth, 44.5 C — 31616 (geo. mean)
14b
#/100 nil
25.
#/100 nil
2 X month
Grab
Solids, Total Dissolved — 180 Deg. C - 70300
500
mg/1
3 X year'
Grab
Chloride (as Cl) - 00940
250
mg/1
3 X year'
Grab
Nitrogen, Total (as N) - 00600
15
mg/l
2 X month
Grab
Phosphorus, Total (as P) - 00665
4
mg/1
2 X month
Grab
Turbidity, HCH Turbidimeter - 00076
10
ntu
Continuous
Continuous
pHd - 00400
6.5-8.5
S.U.
Daily - weekdays
Grab
'Monthly averages for all but fecal coliform shall be the arithmetic mean of all samples collected during the reporting period.
'Monthly average for fecal coliform shall be the geometric mean of all samples collected during the reporting period.
'Daily maximum shall be the maximum value of all samples collected during the reporting period.
dThe effluent pH shall not be less than 6.5 standard units nor greater than 8.5 standard units.
'3 X year sampling shall be conducted in the same months as the groundwater monitoring well sampling (March, July, and November).
WQ0032352 Version 1.0 Attachment A
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ATTACHMENT A - LIMITATIONS AND MONITORING REQUIREMENTS
Millstone Inn and Condominium Development
Permit Number: WQ0032352 Version: 1.0
SW-1— Surface Water Monitoring Point 1` (Spring Head) and SW-2 — Surface Water Monitoring Point 2` (Silver Slip Falls Lake)
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Parameter Description - PCS Code
Monthly Averages
Weekly Average
Daily Maximum`
Measurement
Frequency
Sample
Type
Nitrogen, Total (as N) - 00600
3 X yea?
Grab
Phosphorus, Total (as P) - 00665
3 X yea?
Grab
Monthly averages shall be the arithmetic mean of all samples collected during the reporting period.
b3 X year sampling shall be conducted in the same months as the groundwater monitoring well sampling (March, July, and November).
°Surface`water monitoring points are shown in Figure 2 — Monitoring Locations.
WQ0032352 Version 1.0
Attachment A
Pa

ATTACHMENT B - APPROVED LAND APPLICATION SITES AND LIMITATIONS
Millstone Inn and Condominium Development
Permit Number: WQ0032352 Version:j.
UTILIZATION AREA INFORMATION
APPLICATION LIMITATIONS
Field/
Basin
Owner
County
Latitude
Longitude
Net
Acreage
Dominant
Soil Series
Parameter
Rate
(m/hr)
Pearly
Max
in/ r
1
AIG Baker Cashiers, LLC
Jackson
35006'24"
83006'60"
0.34
Pigeonroost
01284 - Application Surface Irrigation
0.30
104
2
AIG Baker Cashiers, LLC
Jackson
35006'24"
83006'59"
0.30
Pigeonroost
01284 - Application Surface Irrigation
0.30
104
3
AIG Baker Cashiers, LLC
Jackson
35006'23"
83006'59"
0.36
Pigeonroost _
01284 - Application Surface Irrigation
0.30
104
4
AIG Baker Cashiers, LLC
Jackson
35006'25"
83006'59"
0.35
Pigeonroost
01284 - Application Surface Irrigation
0.30
104
5
AIG Baker Cashiers, LLC
Jackson
35'06'27"
83'06'59"
0.40
Pigeonroost
01284 - Application Surface Irrigation.
0.30
104
6
AIG Baker Cashiers, LLC
Jackson
3P06'28"
83606'59"
0.36
Pigeonroost
01284 - Application Surface Irrigation
0.30
104
Total
2.11
WQ0032352 Version I..O Attachment B Page 1 of 2

THIS PAGE BLANK
WQ0032352 Version 1.0 Attachment B

ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS
Millstone Inn and Condominium Development
Monitoring wells': MW-1, MW-2, MW-3, MW-4, MW-5, MW-6
Permit Number: WQ0032352 . Version: 1.1
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
Parameter Description _ Parameter Code
Daily Maximum
Frequency Measurement
Sample Type
Footnotes
Water level, distance from measuring point - 82546
3 X Year
Calculated
a, b, c
pH - 00400
6.5 s.u.
8.5 s.u.
3 X Year
Grab
a, b
Coliform, Fecal MF, M-FC Broth, 44.5C - 31616
3 X Year
Grab
a
Solids, Total Dissolved — 180 Deg C - 70300
500 mg/l
3 X Year
Grab
a
Carbon, Tot Organic (TOC) - 00680
3 X Year
Grab
a, f
Chloride (as Cl) - 00940
250 mg/1
3 X Year
Grab
a
Nitrogen, Ammonia Total (as N) - 00610
3 X Year
Grab
a
Nitrogen, Nitrate Total (as N)`- 00620
10 mg/l
3 X Year
Grab
a
Phosphorus, Total (as P) - 00665
3 X Year
Grab
a
Volatile Compunds, (GC/MS) - 78732
Anually
Grab
a, d, e
a. 3 X year monitoring shall be conducted in March, July & November; Annual monitoring shall be conducted every November.
b. 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 be made after purging and prior to sampling for the remaining parameters.
C. 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. -
d. Volatile Organic Compounds (VOC) - In November only, analyze by one of the following methods:
1. Standard Method 6230D, PQL-at 0.5 µg/L or less.
2. Standard Method 621 OD, PQL at 0.5 µg/L or less
3. EPA Method 8021, Low Concentration, PQL at 0.5 µg/L or less
4. EPA Method 8260, Low Concentration, PQL at 0.5 µg/L or less
5. Another method with prior approval by the Aquifer Protection Section Chief
Any method used must meet the following qualifications:
a. A laboratory must be DWQ 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.
c. The method used must provide a PQL of 0.5 µg/L or less that must be supported by laboratory proficiency studies as required by the DWQ Laboratory Certification Unit. Any constituents
detected above the MDL but below the PQL of 0.5 µg/L must be qualified (estimated) and reported.
e. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Asheville Regional Office Aquifer Protection Supervisor, telephone
number [phone], must be contacted immediately for further instructions regarding any additional follow-up analyses required. I -
WQ0032352 Version 1.0 Attachment C Page 1 of 2

f. If TOC concentrations greater than 10 mg/I are 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/1, 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.
g. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 2 — Monitoring Locations and this attachment.
WQ0032352 Version 1.0 Attachment C

ATE OF NORTH CAROLINA+�
COUNTY OF T,4C1_5an! Permit No. GJQ 00 3 2 35 Z
OPERATIONAL AGREEMENT
This AGREEMENT made pursuant to G.S..143-215.1 (dl) and entered into.this 13th day of
November , by and between the North Carolina Environmental Management Commission, an
agency'of the State of North Carolina, hereinafter known as the COMMISSION; and AIG Baker Cashiers,
LLC , a corporation general partnership registered/licensed to do business in' the State of North
Carolina, hereinafter known as the DEVELOPER.
VnTNESSETH: -
1. The DEVELOPER is the owner of the certain lands lying in Jackson County, upon
which it is erecting and will erect dwelling units and other improvements, said development to be known
as Millstone Inn and Condominiums (hereinafter the Development).
2. The DEVELOPER desires, to construct a wastewater collection system with pumps,. wastewater treatment
works, and/or disposal facilities (hereinafter Disposal System) to provide sanitary sewage disposal.to serve
the Development on said.lands.
3. The DEVELOPER has applied to the .COMMISSION for the issuance of a permit pursuaiit to G.S. 143-
215.1, to construct, maintain, and operate the Disposal System.
4. The DEVELOPER has created or shall create unit ownership in said dwellings `units, other improvements
and lands through filing of a Declaration of Unit Ownership (hereinafter Declaration), pursuant to Chapter
- 47C of the North Carolina General Statutes.
5. The DEVELOPER has caused to be formed or will cause to be -formed at the time of filing of the
Declaration, the Millstone Homeowners Association (hereinafter
Association), a non-profit corporation organized and existing under and by the virtue of the laws of the
State of North Carolina; for"the purpose, among others, of handling the property, affairs and business of
the Development; of operating, maintaining, re -constructing and repairing the common elements of the.
lands and improvements subject to unit ownership, including. the Disposal System; and of collecting dues .
and assessments to provide funds for such operation, maintenance, re -construction and repair.
6. The COMMISSION desires to assure that the Disposal System of the Development is properly
constructed, maintained and operated in accordance with law and permit provisions in order to protect the
quality of the waters of the State and the public interest therein.
NOW, .THEREFORE, in consideration of the promises and the benefits to be derived by each of the parties
hereto, the.COMMISSION and DEVELOPER do hereby mutually agree as follows:
1. The DEVELOPER shall construct,the Disposal System in accordance with the permit and plans and
specifications hereafter issued and approved by the COMMISSION, and shall thereafter properly operate
and maintain such systems and facilities in accordance with applicable permit provisions and law.
2. The DEVELOPER -shall not transfer ownership and/or control of the Disposal System to the Association
until construction has been completed in accordance with the permit and approved plans, and the staff of
the Division of Water. Quality has inspected and approved of the facilities. In order, to change the name of
the permit holder, the DEVELOPER must request that permit be reissued to the Association. The
request must include a copy of the Association Bylaws and Declaration. -
3. The DEVELOPER shall not transfer, convey, assign or otherwise relinquish or release its responsibility
for the operation and maintenance of its Disposal System until, a permit has been reissued to the
DEVELOPER's successor,
Paoa 1 of 7

4. The DEVELOPER shall p :.:cde in the Declaration and Association Lyaaws that the Disposal System and '
appurtenances thereto are part of the common elements and shall thereafter be properly maintained and
• operated in conformity with law and the provisions of the permit for construction, operation, repair, and
maintenance of the system and facilities. The Declaration and Bylaws shall identify the entire wastewater
treatment, collection and disposal system as a common element, which will receive the highest priority for
expenditures by the Association except for Federal, State, and local taxes and insurance.
5. The DEVELOPER shall provide in the Declaration and Association Bylaws that the Disposal System will
be maintained out of the common expenses. In order to assure that there shall be funds readily available to
repair, maintain or construct the Disposal System, beyond the routine operation and maintenance
expenses, the Declaration and Association Bylaws shall provide that a fund be created out of the common
expenses. Such fund shall be separate from the routine maintenance funds allocated for the facility and
shall be part of the yearly budget.
6. In the event the common expense allocation and separate fund are not adequate for the construction,
repair, and maintenance of the Disposal. System, the Declaration -and Association Bylaws shall provide for
special assessments to cover such necessary costs. There shall be no limit on the amount of such
assessments, and the Declaration and Bylaws,shall provide that such special assessments can be made as
necessary at anytime. .
7. If a wastewater collection system and wastewater treatment and/or disposal facility provided by any city,
town, village, county, water and sewer authorities, or other unit of government shall hereinafter become
available to serve the Development, the DEVELOPER shall take such action as is necessary to cause the
existing and future wastewater of the Development to be accepted and discharged into said governmental
system, and shall convey or transfer as much of the Disposal'System and such necessary easements as the
governmental unit may require as condition of accepting the Development's wastewater.
8. Recognizing that it would be contrary to the public interest and to the public health, safety and welfare for
the Association to enter into voluntary dissolution without having made adequate provision for the
continued proper maintenance, repair and operation of its Disposal System, the DEVELOPER shall
provide in the Association Bylaws that the Association shall not enter into voluntary dissolution without
first having transferred its said system and facilities to some person, corporation or other entity acceptable
to and approved by the COMMISSION by the issuance of a permit.
9. The agreements set forth in numbered paragraphs 1, 2, 3, 4, 5., 6, 7, and 8 above shall be conditions of any
permit issued by the COMMISSION to the DEVELOPER for the construction, maintenance, repair and
operation of the Disposal System.
10. A copy of this agreement shall be filed at the Register of Deeds in the County(ies) where the Declaration is
filed and in the offices of the Secretary of State of North Carolina with the Articles of Incorporation of the
Association.
IN WITNESS WHEREOF, this agreement was executed in duplicate originals by the duly authorized
representative of the parties hereto on the day and year written as indicated by each of the parties named below:
FOR THE ENVIRONMENTAL
MANAGEMENT COMMISSION
Coleen H. Sullins, Director
Division of Water Quality
(Date)
Ao(r9, AS L• .G
N e EVEL P bhvx-r- SlAw?ktat- c(.10TO Paoftft
E MEMREQ
B O�,
(Signature)
. R�--Sye P. bAYx--PZ ;' I VF-nrr
Print Name and Title
11��3�e�i
(Date)
VnMa. nMU nr, m

1 t Lr U (L 1_ L. - 1" L V t y I I lJ I- I s v v Lr
1 1 1 2 1 3 1 4 ' 5 1 6 1 7 1 8 1 9 1 10 I 11 1 12 1 13 I tl 1 15 1 16 1 I
R
©1
IRRIGATION CALCULATIONS
1. DESIGN FLOW CALCULATIONS:
EXISTING INN (7 BED/ 50 SEAT RESTAURANT) = 2,840 GPD,
1 BEDROOM RENTALS (6 EACH) - 720 GPD.
LOWER TOWNHOMES (14 EACH/ 2.5 BED)' = 4,200 GPD.
UPPER CONDO UNITS (24 EACH/ 2.5 BED)' a 7,200 GPD
COTTAGE UNITS (4 EACH/ 3 RED) = 1,440 GPO.
TOTAL 16,400 GPD.
-ASSUME EVEN SPLIT OF 2 BEDROOM AND 3 BEDROOM CONDOS AND TOWN HOMES.
2. DESIGN BASED ON IRRIGATION RATE OF 2.00INCHES PER WEEK (0.1785 GPD/FT3).
SATURATED HYDRAULIC CONDUCTIVITY AND OTHER SOIL DATA FROM KENDALL SL ASSOCIATES.
3. IRRIGATION AREA NEEDED - 16,400 GPD/0.17ES - 91,876 Fr- (2.109 ACRES). THE IRRIGATION AREA IS DIVIDED
.. INTO 6 ZONES WITH A TOTAL WETTED AREA OF 91,876 FT2 (2.109 ACRES). _
NOTES:
1. ALL SETBACKS AND CONSTRUCTION METHODS AS SPECIFIED IN 15A NCAC 02T ,0500 AND .0900 APPLY AND
SUPERCEDE ANY DRAWING DEPICTIONS HEREIN. RECLAIMED WATER EFFLUENT STANDARDS (SSA NCAC 02T .0906)
ACHIEVED TO LTTILTZE THE 2T .0900 SETBACK FOR PROPERTY LINES.
2. ALL IRRIGATION LINES TO BE INSTALLED ON CONTOUR AT GROUND SURFACE 4 FT O.C.
3. ALL IRRIGATION LINE LOCATIONS SHALL BE SURVEY STAKED PRIOR TO CONSTRUCTION,
4. CAUTION SIGNS ARE TO BE POSTED EVERY 100' AROUND THE DISPOSAL AREA. SEE SHEET E•S FOR
SIGNAGE DETAILS. _
Rene Prassura and
Flow
'
1
Number
boo ComDlned i MM)mum
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Fresaure Nigh
of . Total Latnn)
I
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KEYNOTES:
F
1
2" PVC FORCEMAINS SLEEVED IN 1 B" DIP. APPROXIMATELY 40 L.F.' SEE
O(2)
DETAIL 3 SHEET E-9,
VALVE BOX (TYP.) WITH AIR RELEASE VALVE INSTALLED AT HIGH POINT IN
OZ
BOTH THE SUPPLY AND RETURN FORCE MAIN. SEE DETAIL 8 SHEET E-11.
E
OVALVE
BOX (TYP.) WITH SOLENOID TO OPEN WHEN FLUSHING ZONES 4, 5,
AND 6.
GAL. PUMP TANK FOR RETURNING FLUSH FROM ZONES 4, 5, AND 6.
0
®1,20D
SEE DETAIL 4 SHEET-E-9. LE. = 3434.0'.
O2"
SUPPLY FORCE MAIN. SEE DETAIL 3 SHEET E-8 FOR TRENCHING DETAILS.
2" FLUSH RETURN FORCE MAIN. SEE DETAIL 3 SHEET E-8 FOR TRENCHING
0
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DEVELOPMENT NOTES:
MILLSTONE INN AND CONDOMINIUM DEVELOPMENT IS A DETACHED CONDOMINIUM STYLE DEVELOPMENT WHICH
REQUIRES NO SUBDIVISION OF LAND, ONLY INDIVIDUAL BUILDINGS ARE BEING SOLD. ALLWASTEWATER
TREATMENT AND DISPOSAL COMPONENTS ARE LOCATED ON PROPERTY OWNED CURRENTLY BY AIG BAKER
CASHIERS, U.C. ALL W WTP COMPONENTS ARE LOCATED ON COMMON ELEMENT AREAS (AS OPPOSED TO LIMITED
USE AREAS). THE WASTEWATER TREATMENT AND THE IRRIGATION DISPOSAL SYSTEM WILL BE OWNED BY AIG
BAKER CASHIERS, LUC., WHICH WILL CONTRACT THE SYSTEM OPERATION WITH A LICENSED OPERATOR.
1. DESIGN FLOW CALCULATIONS:
S)(IST1NG INN (7 BED/ 50 SEAT RESTAURANT) = 2,840 GPD.
1 BEDROOM RENTALS (6 EACH) = 720 GPD.
LOWER TOWNHOMES (14 EACH/ 2.5 BED)' - 4,200 GPD.
UPPER CONDO UNITS (24 EACH/ 2.5 BED)- - 7,200 GPD
COTTAGE UNITS (4 EACH! 3 BED) = 1440 GPD
TOTAL 16,400 GPD.
'ASSUME EVEN SPLIT OF 2 BEDROOM AND 3 BEDROOM CONDOS AND TOWN HOMES.
2. DESIGN BASED ON IRRIGATION RATE OF 2.00 INCHES PER WEEK (0,1785 GPD/FT2).
SATURATED HYDRAULIC CONDUCTIVITY AND OTHER SOIL DATA FROM KENDALL 8, ASSOCIATES.
3. IRRIGATION AREA NEEDED - 16,400 GPD/0.1785 - 91,876 FTi (2.109 ACRES). THE IRRIGATION AREA IS DIVIDED
INTO 6 ZONES WITH A TOTAL WETTED AREA OF 91,876 FT2 (2.109 ACRES).
KEYNOTES:
0 PER 1SA NCAC 02L 0108 AND 15A NCAC 02T .0506 (C) THE REVIEW BOUNDARY
HAS BEEN ESTABLISHED AS THE IRRIGATION AREA BOUNDARY.
OPER 15A NCAC 02L 0107 AND 15A NCAC 02T.0506 (C) THE COMPLIANCE
BOUNDARY HAS BEEN ESTABLISHED AS THE IRRIGATION AREA BOUNDARY.
OTREATMENT AND DOSING FACILITY.
® 18 - DAY WET WEATHER STORAGE TANK.
OPROPOSED COMMUNITY WATER SUPPLY WELL UNDER CONSTRUCTIbN.
LOCATION HAS BEEN SURVEYED.
© EXISTING COMMUNITY WATER SUPPLY WELL. .
OEXISTING STREAM. .
® EXISTING LAKE.
OPROPOSED 1,600 GAL GREASE TRAP TO RECEIVE ALL WASTES ASSOCIATED
g WITH FOOD SERVICE. GRAYWATER ONLY. SEE DETAIL 6 SHEET E-9.
CAPACITY DETERMINED IN ACCORDANCE WITH 15A NCAC 18A .19S5(k):
LC- DxGLxSTxHR/2xLF=5Dx25x2.5x122xO.8=1,500gal
WHERE LC = GREASE TRAP LIQUID CAPACITY (GALLONS)
D = NUMBER OF SEATS IN DINING AREA
GL - GALLONS OF WASTEWATER PER MEAL
ST = STORAGE CAPACITY FACTOR (2.5)
HR = NUMBER OF HOURS OPEN
UP = LOADING FACTOR
THE SETBACKS UTILIZED IN THIS DESIGN ARE THOSE FOR A WASTEWATER DRIP
IRRIGATION SYSTEM LOCATED IN 15A NCAC 02T .0506. THE SYSTEM IS DESIGNED
TO MEET RECLAIMED WASTEWATER EFFLUENT STANDARDS THEREFORE THE
SYSTEM UTILIZES THE PROPERTY LINE SETBACK IN ISA NCAC 025 .0912.
SPECIFICALLY, THE SETBACKS UTILIZED ARE AS FOLLOWS:
IRRIGATION AREAS
ANY HABITABLE RESIDENCE UNDER SEPARATE OWNERSHIP
100 FT
SURFACE WATERS
100 FT
ANY COMMUNITY WATER SUPPLY WE
100 FT
PROPERTY LINE
NO SETBACK
TOP OF CUT BANK
15 PT
PUBLIC RIGHT OF WAY
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ANY HABITABLE RESIDENCE UNDER SEPARATE OWNERSHIP
100 FT '
ANY WATER SUPPLY SOURCE
100 FT
SURFACE WATERS
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ANY COMMUNITY WATER SUPPLY WE
. 100 FT
ANY PROPERTY LINE
50 FT
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• ANGER BORING
1 TEST PR
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LINE LEGEND:
PROPERTYLINE.
—•
REVIEW BOUNDARY
"- —"
COMPLIANCE BOUNDARY
DISPOSAL AREA BOUNDARY
..
- SURFACE WATER
SOIL MAP UNIT BOUNDARY
L,Ei
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Permit: WO0032352
SOC:
County: Jackson
Region: Asheville
Contact Person: Alex D Baker
Directions to Facility:
System Classifications: SI,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 12/31/07 Expiration: 11/30/16 Owner: Aig Baker Cashiers LLC
Effective: Expiration: Facility: Millstone Inn and Condominium Development
119 Lodge Ln
Title:
Inspection Date: 12/30/2016 Entry Time: 09:OOAM
Primary Inspector: Beverly Price VV
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Cashiers NC 28717
Phone: [phone]
Certification: Phone:
Exit Time: 09:30AM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 12/30/2016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
There was no site visit for this inspection.
The permit expired 11/30/2016.
The facility was never constructed.
Last known contact: Amy McMullen 205-972-9669 w/AIG Baker. Last attempt to contact was on 12/30/2016; left
message; message not returned.
Page: 2

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 12/30/2016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Page: 3

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_ k:�orporations Division
Page 1 of 1
Click Here To:
North Carolina
Elaine F. Marshall DEPARTMENT OF THE
Secretary SECRETARY aF STATE
PO Box 29822 Raleigh, NC 27626-0622 (919}807 2000 Account
Login
Register
View Document Filings File an Annual Report Amend a Previous Annual Report
Print a Pre -Populated Annual Report form
Corporate Names
Legal: ►AIG-"Baker_Cashiers,`.L:L_C,; UJQ0o
feu Q loPme^f�
Limited Liability Company Information
Sosid:
0892314
Status:
Revoked-'.,
/Annual Report Status:
Not Applicable
Citizenship:
Foreign
Date Formed:
1/12/2007
Fiscal Month:
December
State of Incorporation:
DE
Registered Agent:
CT Corporation System
Corporate Addresses
Reg Office:
150 Fayetteville St., Box 1011
Raleigh, NC 27601
Reg Mailing:
150 Fayetteville St., Box 1011
Raleigh, NC 27601
Mailing:
700 Montgomery Highway Suite 186
Birmingham, AL 35216
Principal Office:
700 Montgomery Highway Suite 186
Birmingham, AL 35216
Company Officials
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20
Member: AIG Baker Shopping Center Properties LLC
700 Montgomery Highway Suite 186
Birmingham AL 35216
http://www.sosnc.gov/Search/profcorp/8129342 1 /4/2017

f_brporations Division
Page 1 of 1
North Carolina
Elaine F. Marshall DEPARTMENTOF THE
Secretary SECRETARY aF `IATE
PO Box 29622 Raleigh, NO 27626-0622 [phone]
Click Here To:
View Document Filings File an Annual Report Amend a Previous Annual Report
Print a Pre -Populated Annual Report form
Corporate Names
Legal: MILLSTONE INN, INC.
Business Corporation Information
Account
Login
Register
Sosld:
0345720
Status:
Withdrawn
Annual Report Status:
Not Applicable
Citizenship:
Foreign
Date Formed:
6/1/1994
Fiscal Month:
December
State of Incorporation:
GA
Registered Agent:
Secretary of State
Corporate Addresses
Reg Office: 2 South Salisbury Street
Raleigh, NC 27601
Reg Mailing: 2 South Salisbury Street
Raleigh, NC 27601
Mailing: PO Box 949
Cashiers, NC 28717
Principal Office: PO Box 949
Cashiers, NC 28717-0949
Officers
Stock
http://www.sosne.gov/Search/profcorp/5017329 1/4/2017

Compliance Inspection Report
Permit: WQ0032352 Effective: 12/31/07 Expiration: 11/30/16 owner: Aig Baker Cashiers LLC
SOC: Effective: Expiration: Facility: Millstone Inn and Condominium Development
County: Jackson 119 Lodge Ln
Region: Asheville
Cashiers NC 28717
Contact Person: Alex D Baker Title: Phone: [phone]
Directions to Facility:
System Classifications: SI,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/29/2014 Entry Time: 03:30PM
Primary Inspector: Beverly Price
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Exit Time: 03:45PM
Phone: [phone]
Inspection Type: Reconnaissance
Page: 1

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 09/29/2014 Inspection Type : Reconnaissance Reason for Visit: Routine
Inspection Summary:
Placed numerous calls to the last contact for Alex Baker: Amy McMullen [phone] Calls have not been returned.
Status unknown other than the facility has not been constructed.
Page: 2

Permit: WQ0032352
SOC:
County: Jackson
Region: Asheville
Compliance Inspection Report
Effective: 12/31/07 Expiration: 11/30/16 Owner: Aig Baker Cashiers LLC
Effective: Expiration: Facility: Millstone Inn and Condominium Development
119 Lodge Ln
Contact Person: Alex D Baker
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
SI,
Inspection Date: 09/30/2013
Primary Inspector: Beverly Price
Secondary Inspector(s):
Title:
Alex D Baker
Entry Time: 02:00 PM
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Cashiers NC 28717
Phone: [phone]
Certification:
Exit Time: 02:15 PM
Phone:
Phone: [phone]
Phone: [phone]
Inspection Type: Reconnaissance
Page: 1

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 09/30/2013 Inspection Type: Reconnaissance Reason for Visit: Routine
Inspection Summary:
spoke with Blackwater Resources on 9/30/13
Alex Baker is still a part owner in Millstone. They are still deciding what to do; not actively trying to sell right now.
Page: 2

Pat McCrory
Governor
r
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Thomas A. Reeder
Acting Director
June 28, 2013
CERTIFIED MAIL # 70121640 0000 9792 4176
RETURN RECIEPT REQUESTED
Mr. Alex D. Baker
Aig Baker Cashiers, LLC
700 Montgomery Hwy, Suite 186
Vestavia, AL 35216
Subject: Notice of Deficiencies NOD-2013-PC-0257
Millstone Inn &Condominium Development
Permit Number WQ0032352
Wastewater Irrigation Permit
Jackson County
Dear Mr. Baker:
John E. Skvarla, III
Secretary
As of this date, our records indicate that the above -referenced permit, which was issued on December 31,
2007 and expires on November 30, 2016, has overdue fees. It is a condition of your permit to pay the
annual administering and compliance fee within thirty (30) days of being billed by the Division of Water
Quality (Division).
Failure to pay the fee accordingly may result in the Division initiating enforcement actions, to include the
assessment of civil penalties. Civil penalty assessments may be issued of not more that twenty-five
thousand ($25,000) dollars against any "person" who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit under authority of G.S. 143-215.6A.
Therefore, it is imperative that you submit the appropriate fee as requested within thirty (30) days of the
receipt of this notice. According to our records, the following invoice(s) are outstanding:
Invoice Number
Invoice Date
Due Date
Outstanding Fee
2012PRO11368
November 6, 2012
December 6, 2012
$1,310.00
2011PRO10365
November 2, 2011
December 2, 2011
$1,310.00
2009PRO12792
December 8, 2009
January7, 2010
$1,310.00
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX,: 919-807-64801FAX: [phone]
Internet: wwwmwaterguality.orq
Igo -thCarohna
An Equal Opportunity, Affirmative Action Employer

Mr. Alex D. Baker
June 28, 2013
Page 2 of 2
Please remit payment made payable to the North Carolina Department of Environment and Natural
Resources in the amount of $3,930.00. Please mail this payment to:
Division of Water Quality
Budget Office
Attn: Fran McPherson
1617 Mail Service Center
Raleigh, NC 27699-1617
For questions regarding any overdue annual fees, please contact Fran McPherson with the Division's
Budget Office at [phone]. If you have any other questions, please contact Ed Hardee by phone at
[phone] or by email at [e-mail].
cc: A79heville Regional Office — APS
APS Central Files - Permit No. WQ0032352
Fran McPherson — DWQ Budget Office
Sincerely,
Jon Risguard, Supervisor
Land Application Unit
U01ldal0jd aavtn y
a0410 IBU0I6E)U BIIInBySV
WE a- IIIr
9AI 3H

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Charles Wakild, P. E.
Director
January 8, 2013
Mr. Mike Glenn
Silver Slip Homeowner's Association, Inc.
P.O. Box 1308
Cashiers, N.C. 28717
Mr. Glenn:
Dee Freeman
Secretary
Re: Request to Rescind Wastewater Surface Irrigation
System for Millstone Inn and Condominium Development
Permit No.: WQ0032352
Jackson County, NC
Your letter dated November 13, 2012 to Mr. Bill Cary, General Counsel for the
Department of Environment and Natural Resources (NCDENR), has been referred to us for
response. In the letter, you refer to a February 23, 2011 letter in which you requested the
Division of Water Quality (Division) to revoke the subject permit, issued to the Millstone Inn
and Condominium Development, which is owned by AIG Baker Cashiers, LLC. Your letter of
February 2011 summarized the results of a Settlement Agreement and Mutual Release
(Agreement) signed between Silver Slip Falls Development and AIG Baker. The Agreement
indicates that AIG Baker acknowledges that the lots owned by AIG Baker within the
subdivision, including those referenced in the subject permit, are subject to applicable
subdivision protective covenants.
In a previous letter (August 2008), you indicated that your concern was the permitted
wastewater drip irrigation system owned by AIG Baker was to be installed on property approved
for residential, single-family use only as stipulated by subdivision covenant. In a September 3,
2008 response letter, Mr. Dan Oakley, NCDENR General Counsel, concluded that the subject
permit allows the construction and operation of the system, however, it does not conifer upon any
person the right to develop or construct on the property where a property interest may otherwise
prohibit it. The permittee (i.e., AIG Baker) is required to comply with all other applicable statue
or rule (refer to Section VIA of the subject permit).
Your letter of November 13, 2012 requests that the subject permit be revoked since AIG
Bakers is offering the Millstone and Condominium Development for sale and any new owner
would encounter similar constraints if installing the permitted system. With the Agreement and
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterguality.org
One NhCarolina
An Equal Opportunity 1 Affirmative Action Employer

Mr. Mike Glenn
c
Silver Slip Homeowner's Association, Inc.
December 3, 2012
Page 2 of 2
applicable protective covenants, it appears that adequate measures are in place to allow the Silver
Slip Falls HOA to exercise their right to restrict improvements on all lots subject to covenants as
they deem necessary.
Currently the Division is not in a position to revoke the subject permit unless specifically
requested by the permittee and retains the position stated in the September 3, 2008 letter, that our
practice in these situations is to notify parties that the issued permit does not confer any right to
develop or construct on any property where a property interest may prohibit it. The subject
permit allows construction and operation of the wastewater system, but requires the permit
holder to comply with all other applicable statutes or rules.
I hope this letter offers further clarification of the Division's position concerning the
existing permit. If you have any questions please contact Mr. Landon Davidson at (828) 296-
4500.
Sincerely,
Charles Wakild, P. E.
cc: Jon Risgaard
Landon Davidson
Bill Cary

�6 wwn,�
SILVER SLIP FALLS HOMEOWNERS' ASSOCIATION, INC.
P.O. BOX 1308 (r�'�'✓1;�bN
CASHIERS, NORTH CAROLINA 28717 0
Writer's email: melennQghmslaw.com
November 13, 2012
Mr. Bill Cary
NC-DENR
Office of General Counsel
217 West Jones Street
Raleigh, North Carolina 27603
��,;;�•.> >,;
goy 1
.. ���-�
RE: Waste Water Surface Irrigation System
Permit Number: WQ0032352
Permit Holder: Millstone Inn and Condominium Development
Owner: AIG Baker Cashiers, LLC
Dear Mr., , .
..... � Cary:; ..
On February 23, 20111 I wrote to Mary Penny Thompson who, at that time, was in
the -Office of General Counsel. I enclose a copy of that letter.
In that letter, I requested that the Division of Water Quality be instructed to revoke
the waste water surface irrigation system permit number WQ0032352 which had
been issued to Millstone Inn and Condominium Development which was owned
by AIG Baker Cashiers, LLC.
In that letter I described the background leading to my request. Recently I found
that the permit -in question has been extended and now expires on November 30,
2016. I spoke with 2 people in your Asheville, North Carolina office of the
Division of Water Quality and learned that this permit; like all other permits, was
extended automatically and without application or permission of the holder of the
permit.
My reason for requesting that the permit be cancelled is that AIG Baker Cashiers,
LLC is offering the Millstone and Condominium Development for sale. I want to
make sure that any purchaser understands that the permit in place, number

Mr. Bill Cary
November 13, 2012
Page 2
WQ0032352, cannot be used. If any one should purchase the property planning to
use the permit, another suit will be filed to stop the waste water service irrigation
system. I again.request that the Division of Water Quality revoke the permit as
soon as possible. I enclose copies of all the documents which were included in my
February 23, 2011.letter. If you need further information concerning this matter, I
will be happy to provide it.
I shall appreciate your looking into this matter and responding to my request.
Yours very truly,
Michael D. Glenn
MDG/sbl
Enc.
CC; Ms. Mary Penny Thompson
NC-DENR
Chief Deputy Secretary
-"Ms. Coleen H. Sullins, Director
Division of Water Quality
Mr. Ed Pearson
Mr. Al Berry
Mr. Doug Tuttle

Permit: WO0032352
SOC:
County: Jackson
Region: Asheville
Compliance Inspection Report
Effective: 12/31/07 Expiration: 11/30/16 Owner: Aig Baker Cashiers LLC
Effective: Expiration: Facility: Millstone Inn and Condominium Development
119 Lodge Ln
Contact Person: Alex D Baker
Directions to Facility:
System Classifications: SI,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Cashiers NC 28717
Title: Phone: [phone]
Certification: Phone:
Inspection Date: 09/20/2012 Entry Time: 11:30 AM
Primary Inspector: Beverly Price
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Surface Irrigation
Facility Status: 0 Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions
(See attachment summary)
Exit Time: 12:00 PM
Phone: [phone]
Inspection Type: Reconnaissance
Page: 1

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 09/20/2012 Inspection Type: Reconnaissance Reason for Visit: Routine
Inspection Summary:
per Mark Brooks (project engineer) - nothing has changed with this facility since inquiry last year.
The Inn has shut down - driveway gated with no tresspassing sign.
Page: 2

Price, Bev
From: Mark Brooks [[e-mail]]
Sent: Thursday, September 13, 2012 3:39 PM
To: Price, Bev
Subject: RE: Permit update
Nope. Not ing-new-with-these.
W a is goi o g at Deereborne Cottages? They may be shut down due to the property being in recievership, but that
system should not be allowed to operate. I certified one or two zones based on additional. site work being done (filling in
pits, blanking over a ditch, fixing leaks). I was told the work was done but truth is it never was. Not sure if this is on your
radar screen.
Mark C. Brooks, P.E.
Brooks Engineering Associates, P.A.
[phone]
BROOKS
ENOINEERIN® ASSOCIATES
From: Price, Bev [mailto:[e-mail]]
Sent: Thursday, September 13, 2012 11:31 AM
To: Mark Brooks
Subject: Permit update
Hi Mark,
I'm doing my yearly permit status update. Anything new on these? At least the list is getting smaller?
Mli'IIste,Mf ma►Cfi/�_R@@3235R2 Gurfacealrrigatigni)-
The Cliffs WQ0033455 (Surface Irrigation)
Thanks,
Bev
Bev Price - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: 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.

f�
Compliance Inspection Report
Permit: WQ0032352 Effective: 12/31/07 Expiration: 11/30/16 Owner: Aig Baker Cashiers LLC
SOC: Effective: Expiration: Facility: Millstone Inn and Condominium Development
County: Jackson 119 Lodge Ln
Region: Asheville
Cashiers NC 28717
Contact Person: Alex D Baker Title: Phone: [phone]
Directions to Facility:
System Classifications: Si,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/20/2012 Entry Time: 11:30 AM
Primary Inspector: Beverly Price
Secondary Inspector(s):
Reason for Inspection: Routine .
Permit Inspection Type: Surface Irrigation
Facility Status: ❑ Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions
Exit Time: 12:00 PM
Phone: [phone]
Inspection Type: Reconnaissance
(See attachment summary)
f Y, � 1 l s I---f~�. t „ n - a.� e. ac moss' V� b
Page: 1

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 09/20/2012 Inspection Type: Reconnaissance Reason for Visit: Routine
Inspection Summary:
Page: 2

Compliance Inspection Report
Permit: WQ0032352 Effective: 12/31/07 Expiration: 11/30/16 Owner: Aig Baker Cashiers LLC
SOC: Effective: Expiration: Facility: Millstone Inn and Condominium Development
County: Jackson 119 Lodge Ln
Region: Asheville
Contact Person: Alex D Baker
Directions to Facility:
System Classifications: SI,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 09/12/2011
Primary Inspector: Beverly Price
Secondary Inspector(s):
Title:
Mark C Brooks
Entry Time: 10:00 AM
Reason for Inspection: Routine
Permit Inspection Type: Surface Irrigation
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Cashiers NC 28717
Phone: [phone]
Certification: Phone:
Phone: [phone]
Exit Time: 10:30 AM
Phone: [phone]
Inspection Type: Reconnaissance
Page: 1

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 09/12/2011 Inspection Type: Reconnaissance Reason for Visit: Routine
Inspection Summary:
per phone conversation with Sharon Diorio(AIG 205-969-1000) on 9/12/11,the facility has not been constructed. The
project is on the "side -burner" per company attorney Amy McMullen (205-972-9669). Ms. McMullen should be the future
contact.
Page: 2

Price, Bev
From: Mark Brooks [[e-mail]]
Sent: Thursday, May 12, 2011 5:38 PM
To: Price, Bev
Subject: RE: Facility Status
Bev — See my comments below in red.
FYI Bear Lake just got the permit modification to remove Zone L. I anticipate a final/final in a month or so.
Mark C. Brooks, P.E.
Brooks Engineering Associates, P.A.
[phone]
BROOKS
ENCINEERIN© ASSOCIATES
A 1,,_k BoLker A05- 969 - r000
From: Price, Bev [mailto:[e-mail] 4 15u-e_ PA2
Sent: Thursday, May 12, 2011 1:25 PM
To: Mark Brooks
Subject: Facility Status
Hi Mark,
I was wondering if you could give me a facility status update for the following:
Cold Mountain WQ0029962. This site was re -permitted with individual and cluster septic systems. The permit needs to
be closed out. I doubt Mr. Graves will pay any re -permitting fees.
WflistiggE il,nnrandc2&a W • -r&311 have not heard anything from these folks. Last I heard the adjacent property
owners were suing because some of the proposed drip field is in a subdivision with a lot of covenants. I think the Inn
may be operating but on the existing septic system.
Camp Highlander WQ0032714. The DWQ permit needs to be closed out. They permitted and installed a drip system
through DEH to avoid the wet weather pond. I thought this was done as they were told to do this in the DEH permitting.
The Cliffs at High Carolina WQ0033455. Plans just still kinda' on hold. Not really sure if/when any construction will start.
As always, thanks for your help,
Bev
Bev Price - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: 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.

Permit: WQ0032352
SOC:
County: Jackson
Region: Asheville
Compliance Inspection Report
Effective: 12/31/07 Expiration: 11/30/15 Owner: Aig Baker Cashiers LLC
Effective: Expiration: Facility: Millstone Inn and Condominium Development
119 Lodge Ln
Contact Person: Alex D Baker
Directions to Facility:
System Classifications: SI,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 02/09/2010
Primary Inspector: Beverly Price
Secondary Inspector(s):
Title:
Mark C Brooks
Entry Time: 03:00 PM
Reason for Inspection: Routine
Permit Inspection Type: Surface Irrigation
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions
(See attachment summary)
Cashiers NC 28717
Phone: [phone]
Certification:
Exit Time: 03:15 PM
Phone:
Phone: [phone]
Phone: [phone]
Inspection Type: Reconnaissance
Page: 1

Permit: WQ0032352 Owner - Facility: Aig Baker Cashiers LLC
Inspection Date: 02/09/2010 Inspection Type: Reconnaissance Reason for Visit: Routine
Inspection Summary:
This project is on hold until further notice per Mark Brooks (phone conversation 2/9/10).
Page: 2

Re: Thompson letter
, a
Subject: Re:'Thompson letter
From: Landon Davidson <[e-mail]>
Date: Fri, 15 Aug 2008 17:49:18 -0400
To: Mike Glenn <[e-mail]>
CC: bev <[e-mail]>, Brett Laverty <[e-mail]>
Mr. Glenn -
Thank you for sending me a copy of your letter stating your concern. I understand
your concerns and would likely have similar concerns as a landowner myself. The
requirements placed upon the permit applicant in regard to demonstrating land
ownership can be found in 15A NCAC 02T .0504(f) and states:
/(f) Property Ownership Documentation shall be provided to the Division by the
applicant consisting of:
(1) legal documentation of ownership (i.e., contract, deed or article of
incorporation);
(2) written notarized intent to purchase agreement signed by both parties,
accompanied by a plat or survey
map; or
(3) written notarized lease agreement signed by both parties, specifically indicating
the intended use of the
property, as well as a plat/
The complete rule for this type of system can be found at this link:
http://h2o.enr.state.nc.us/admin/rules/documents/2Tbook OOO.pdf
I realize this does not specifically address your concern or petition but I wished to
respond to your submittal. In the following week, I will likely discuss the site with
our staff and Ms. Thompson perhaps to determine a path to address your concerns. We
will likely need to meet with you and other concerned citizens in the area. Please
feel free to call me direct at 828.296.4680 if you have any questions or concerns in
the interim. Do you happen to have a copy of the HOA covenants you can forward to me?
I could not access them on the Jackson Co. -registry page.
Landon
Mike Glenn wrote:
Mr. Davidson,
Here is my letter to Mary Penny Thompson. If you need further information, I can
be reached by email or, next week, at 864-226-1885. Thanks for speaking with me
this afternoon.
Mike Glenn
G. Landon Davidson, P.G.
NCDENR - Division of Water Quality
Aquifer Protection Section
Regional APS Supervisor - Asheville Regional Office
1 of 2 3/17/2009 7:46 AM

Re: Thompson letter
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
web page: http://h2o.enr.state.nc.us/agw.html
Landon Davidson <[e-mail]>
NC DENR - Asheville Regional Office
Division of Water Quality -Aquifer Protection Section
2 of 2 3/17/2009 7:46 AM

Re: Express permitted sites
Subject: Re: Express permitted sites
From: Landon Davidson <[e-mail]>
Date: Fri, 15 Aug 2008 17:40:23 -0400
To: Lori Veal <[e-mail]>
CC: Kim Colson <[e-mail]>, bev <[e-mail]>, Nathaniel Thornburg
<[e-mail]>, [e-mail], Brett Laverty
<[e-mail]>
I spoke with Mike Glenn today as well as
reporter earlier this week regarding the
Mary Penny T. as well. He is suggesting
having a drip system next to their house
he said a septic and drainfield but I ge
then I would think the HOA would have tc
aware of this if they were aware of rest
well about the reduced property line off
with setbacks as well ... usually there az
.0504(f)...'..I can't find a copy of the
listed as Silver Slip Falls subdiv. I'm
likely meet with him in the near future.
Landon
Lori Veal wrote:
Buzz Williams two days ago and even a
site. I know Mr. Glenn has sent a letter to
they will likely take legal action to avoid
. I did ask what type of system they have and
t his point ..... if it is against convenants,
take action. Milestone should have made us
rictions through the HOA. Makes me wonder as
set we granted if there are HOA restrictions
e. Sounds as if we have fulfilled
convenants online but the AEG sites are
writing Mr. Glenn and email now and will
Rich and I worked on this project last year. I spoke to a concerned gentleman
this week (Mike Glenn) who lives next to the Inn. The Permittee owns two separate
parcels adjacent to the Inn, which they plan to use for the new WWTP and drip
irrigation areas. The Permittee provided ownership documentation for these
parcels during the application process, and the design is in compliance with all
required setbacks. However, Mr.. Glenn claims that the parcels in question are
part of a single-family residential subdivision which has HOA restrictions against
this type of use. We were not presented with that information during the review
process. Regardless, it seems to me that it would be up to the HOA to enforce
this restriction if it does exist. Thoughts?
G. Landon Davidson, P.G.
NCDENR - Division of Water Quality
Aquifer Protection Section
Regional APS Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
web page: http://h2o.enr.state.nc.us/agw.html
Landon Davidson <Landon.Davidsonpnemail.net>
NC DENR - Asheville Regional Office
Division of Water Quality -Aquifer Protection Section
1 of 1 3/17/2009 7:46 AM

t
SILVER SLIP FALLS HOMEOWNERS' ASSOCIATION, INC.
P.O. BOX 1308
CASHIERS, NORTH CAROLINA 28717
August 12, 2008
VIA FACSIMILE AND U. S. MAIL
919-715-3060 -
Ms. Mary Penny Thompson
NC - DENR
Office of General Counsel
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
RE: Waste Water Surface Irrigation System
Permit Number: WQ0032352
Permit Holder: Millstone Inn and Condominium Development
Owner: AIG Baker Cashiers, LLC
Dear Ms. Thompson:
I serve on the Board of Directors of Silver Slip Falls, a residential community in
Cashiers, North Carolina. AIG Baker Cashiers, LLC is the owner of. approximately
5.2 acres which includes a Bed and Breakfast Inn and two (2) other structures
located adjacent to residential lots within Silver Slip Falls development.
The above mentioned -permit was issued on.December 31, 2007. This permit
provides for the installation of a waste water surface irrigation system to service a
new development on the property owned by AIG Baker Cashiers, LLC. The permit
provides that the entire system including tanks and irrigation zones will be located
on single-family residential lots within Silver Slip Falls. Specifically AIG Baker
owns lots 7, 14, 16, and 17 in Unit 4 of the Silver Slip Falls development. The
Declaration of Protective Covenants for Silver Slip Falls is recorded in Deed Book
488 at page 49 of the Jackson County Registry. The Covenants provide that the
lots owned by AIG Baker are single-family residential lots and prohibit any
disturbance of the lots for any purpose other than for single-family residences.

Ms. Mary Penny Thompson
August 12, 2008
Paae 2
Many residents of Silver Slip Falls development are concerned about the permit
which allows for a septic system to be installed in our single-family residential
subdivision. This purpose clearly violates our Covenants.
In addition, the permit issued to AIG Baker provides that AIG Baker -will form a
Homeowner's Association which will ultimately be responsible for the operation
of the septic system. The permit also provides that the septic system will be
designated as a part of the common area of the new Homeowner's Association.
Upon reviewing the entire situation, it is my belief that this permit should never
have been issued to allow for a sewage treatment system in our subdivision and
which would allow single-family residential lots in our subdivision to become a
common area for another Homeowner's Association.
I shall appreciate your advising me at your earliest convenience whether we can
expect any help from the Division of Water Quality in revoking this permit.
Thank you in advance for your consideration of this request.
Yours very truly,
SILVER SLIP FALLS HOMEOWNER'S ASSOCIATION
Michael D. Glenn
Board Member
MDG/sbl
CC: Ms. Coleen H. Sullins, Director
Division of Water Quality

Permit: WQ0032352
SOC:
County: Jackson
Region: Asheville
}
Compliance Inspection Report
Effective: 12/31/07 Expiration: 11/30/12 Owner: Aig Baker Cashiers LLC
Effective: Expiration: Facility: Millstone Inn and Condominium Development
119 Lodge Ln
Contact Person: Alex D Baker
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 06/16/2008
Primary Inspector: Beverly Price
Secondary Inspector(s):
Title:
Mark C Brooks
Entry Time: 10:00 AM
Reason for Inspection: Routine
Permit Inspection Type: Surface Irrigation
Facility Status: Q Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions
(See attachment summary)
Cashiers NC 28717
Phone: [phone]
Certification:
Exit Time: 10:30 AM
Phone:
Phone: [phone]
Phone: [phone]
Inspection Type: Reconnaissance
Page: 1

Permit: WQ0032352
Inspection Date: 06/16/2008
Owner - Facility: Aig Baker Cashiers LLC
Inspection Type: Reconnaissance
Reason for Visit: Routine
Inspection Summary:
There was no site visit to the facility. According to facility representative/engineer Mark Brooks.(Brooks & Medlock
Engineering), construction has not started on the facility. The permittee is considering moving the location of the WWTP
which would require a permit modification. The WWTP is 6-12 months away from start-up.
Type Yes No NA NE
Activated Sludge Spray, LR n
Single Family Spray, LR
Lagoon Spray, LR n
Infiltration System n
Reuse (Quality) n
Activated Sludge Spray, HR n
Activated Sludge Drip, LR n
Recycle/Reuse
Single Family Drip
n
n
Page: 2

-:5 72-
Ys I/--
1. Coo,
.5
(5,; -9
7'

WAT�gPG _
r
o �
January 17, 2008
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr Alex D Baker
AIG Baker Cashiers LLC
1701 Lee Branch Lane
Birmingham Al 35242
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Paul E. Rawls, Chairman
Water Pollution Control System Operators Certification Commission
Subject: Classification of Water Pollution Control System
Facility: Millstone Inn and Condominium Development
Permit #: WQ0032352
County: Jackson
Dear Mr. Baker:
JAN 22 2008
Rogional Office
c<uitr Protection
In accordance with North Carolina General Statute 90A-37, the. Water Pollution Control System
Operators Certification Commission is required `to olassify water pollution control systems. The
Commission hereby classifies the subject facility as a Surface Irrigation System effective today. In
accordance with 15A NCAC 8G .0201 and your permit, you must designate one Operator in Responsible
Charge (ORC) and one or more back-up operators who possess active Surface (Spray) Irrigation System
Operator certifications.
You are required to complete and return the enclosed designation form to this office by June 30, 2008.
The form must be signed by the ORC, the backup ORC(s), and you or your designee. You may designate
yourself and/or employees to be the ORC and back-up operator(s), or you may engage a contract
operations firm to perform these services. All operators designated as ORC or back-up operators must
possess active Surface (Spray) Irrigation System Operator certificates.
If construction of your system is incomplete or has not yet begun, you must notify this office, in writing,
of an anticipated startup date and your plans for obtaining and designating the required certified operators.
Please note that failure to designate a properly certified ORC and backup operator 60 days prior to the
introduction of waste into the system is a violation of Rule 15A NCAC 8G .0201(3)(a).
A Surface (Spray) Irrigation System Operators Training School is being offered May 5 — 8, 2008, at the
McKimmon Center in Raleigh. The next training school will be offered in May 2009. School registration
information and a list of contract operators are enclosed.
Ne Carolina
oNaturally
Technical Assistance & Certification Unit Internet: http://h2o.enr.state.nc.us/tacu
1618 Mail Service Center, Raleigh, NC 27699-1618 Telephone [phone] Fax [phone]
An Equal Opportunity Action Employer 50% recycled/10% post -consumer paper

Alex D.Baker
WQ0032352
Page Two
If you have questions concerning this requirement, please contact Beth Buffington at [phone],
extension 313, or [e-mail].
Sincerely,
4
J )rnr-yvRimmer, Supervisor
Technical Assistance and Certification Unit
Enclosures
cc Asheville -Reg iio lal`_-Ze, DWQ Agtzifer-Protectiori Section---
DWQ APS Central Files ~�
DWQ LAU Files
DWQ TACU Facility Files

RECEIVED
JAN 0 4 2000
...............................................................................
/lcquifer Protection EJ
DIVISION OF WATER QUALITY . .
RALEIGH REGIONAL OFFICE
January 3, 2008
MEMORANDUM
TO: Landon Davidson
Regional Supervisor
Aquifer Protection, Asheville Regional Office
FROM: Rich Hayes
Soil Scientist
Aquifer Protection Section, Raleigh Regional Office
SUBJECT: Permit No. WQ0032352
Millstone Inn and Condominium Development
Wastewater Surface Irrigation
Jackson County
I am sending a package of information received during the express permitting process for permit
number WQ0032352 for your files. You will be receiving the permit from the. Central Office in a separate
mailing. Please do not hesitate to contact me if you need any additional information about this project.

Re.: Millstone Figure 1
Subject: Re: Millstone Figure 1
From: Lori Veal <[e-mail]>
Date: Fri, 28 Dec 2007 09:27:48 -0500
To: Bev Price <[e-mail]>
FYI ... revised Figure 2 with adjusted SW-2 location.
Lori
Bev Price wrote:
great, thanks Lori.
Bev
Lori Veal wrote:
Got your change.
the guidance!
Lori
I'll adjust that location on the permit draft. Thanks for
Bev Price wrote:
i got it, thanks. we'll 1 pick a new spot and send to you.
Bev
Lori Veal wrote:
ITry this one...
Bev Price - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Bev Price - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Lori M. Veal - Environmental Engineer II
NC Division of Water Quality
Aquifer Protection Section Land Application Unit
phone: [phone]
fax: [phone]
Q 'g p Content -Type: application/pdf
W 0032352 Fig 2.df
1 of 2 12/28/2007 10:29 AM

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Re: [Fwd: Re: Millstone Lodge - Cashiers NC]
Subject: Re: [Fwd: Re: Millstone Lodge - Cashiers NC]
From: Brett Laverty <[e-mail]>
Date: Tue, 18 Dec 2007 09:59:20 -0500
To: Bev Price <[e-mail]>, Landon Davidson <[e-mail]>.
Bev and Landon,
I just received a call from Rich concerning the Millstone express permit. In addition to the four proposed
monitoring wells, he is requiring two additional bedrock wells and two surface water sites - one at Silver
Slip Falls Lake and one at the spring house. Millstone will be required to contact us prior to well
installation so we can put our two cents in. Baseline samples are required immediately after well
construction and 3 months prior to irrigation. Millstone is also required to notify us 48 hours in advance
of the first irrigation event. In addition, the water supply well has been flagged and should be outside the
100' setback limits. Rich will be sending out the permit for review. Contact Lori Veal if you see any
changes that need to be made.
Brett
Bev Price wrote:
Rich,
If permitted to apply above agronomic rates, how will this be reflected in the permit; just curious
from an inspection standpoint?
You should have all of our comments/concerns at this point. If you need anything more, let me
know.
Thanks
Bev
Bev Price - [e-mail]
North Carolina Dept. of Environment
Asheville Regional Office
Division of Water Quality - Aquifer
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
and Natural Resources
Protection Section
Subject:
Re: Millstone Lodge - Cashiers NC
From: Brett Laverty <[e-mail]>
Date: Mon, 17 Dec 2007 16:19:32 -0500
To: Landon Davidson <Landon.Davidson(a,nemail.net>, Bev Price <Bev.Price(u ncmail.net>.
To: Landon Davidson <Landon.DavidsonPncmail.net>, Bev Price <Bev.Price@,ncmail.net>
1 of 3 12/18/2007 10:09 AM

Re: �Fwd: Re: Millstone Lodge - Cashiers NC]
Bev,
Landon and I discussed the monitoring requirements for Millstone. There ate no issues with the four
proposed shallow monitoring wells located downstream of the spray fields. Our recommendation is
for an additional two monitoring wells to be located mid -point between the shallow monitoring
wells. These additional monitoring wells will be constructed below the saprolite and screened within
competent bedrock. My only other concern is Silver Slip Falls Lake, which is located down gradient
of the east spray field. I recommend an additional surface monitoring site to assess the quality of the
lake.
Brett Laverty
Landon Davidson wrote:
Rich -
My staff will likely have addtl. comments later today but here are mine:
Off the top of my head questions regarding Millstone (I'm out at a meeting the rest of the day)
1. Do they have adequate storage for periods of frozen ground and
rain events (given that this is Cashiers 80+ inches a year in rain)?
2. The doubling of nitrogen uptake from 50 to 100 seems ok from what
little literature I've been able to find (106 to 3001bs/acre/year
for trees at least fives years old)....however, I did read something
(in process design manual) about calculating application rates to
supply plant N requirements are more complicated than for ag.
crops..... something to do with nitrogen transformations such as
denitrification, uptake by understory, soil immobilization for
enhancement of forest soil organic-N (ON) pools .... I know little
about N uptake for ag. crops and absolutely nothing, in regard to
uptake in forest cover....hopefully, someone out there does.
3. Without looking at the map, are there any surface water bodies
that could receive phosphorus impacted groundwater? I guess there
has been some issues out there with eutrophication of surface
water bodies.
We should note that the monitoring wells may include wells that are capable of monitoring the
transition zone (between regolith and competent rock) given the setting. Also need to make sure
that PWS has appropriate monitoring in place if this is part of a community system (which the
well may only be for the lodge itself).
Thanks
Brett Laverty - [e-mail]
North Carolina Dept. of Environment and Natural Resources
2 of 3 12/18/2007 10:09 AM

Nitrogen - Plant Nutrient Issues for Sustainable Land Application
Page 1 of 5
Bi U logy-Qnline.org
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15
NITROGEN
Potentially Available Nitrogen and Nitrogen Mineralization
The USEPA 40 CFR Part 503 regulations require that sewage
sludge land applications not exceed the agronomic rate for a
given crop. The agronomic rate provides the amount of N
required by the crop and minimizes the amount of N available
for leaching below the root zone to ground water supplies.
Similarly, the Code 590 guidelines state that animal manures
can be applied on a N basis provided the risk of P loss is low. A
generalized approach for determining PAN is illustrated in the
following equation:
Soil Fertilizer 1
Compare Soil fertilizer and P-A.N = k. (No') = tf of INNH,I--N} I -i- (NN1 0a—N) [1]
other Fertilizers where PAN is potentially available N concentration, km is the
www.smarter.com/Fertilizers fraction of organic N that mineralizes in the first growing
season, No is the organic N content of the residual, of is the
fraction of NH4 N that does not volatilize, NNH a—N is the
ammonium N content, and NN03 —N is the nitrate N content.
Regulations requiring that residuals be applied based on PAN
content create an expectation that land application will not
cause problems with crop N deficiencies in crops or excessive
nitrate leaching. Accurately calculating the agronomic rate is
complicated due to the difficulty in estimating PMN, which can
vary considerably among biosolids sources and soil types (Ajwa
and Tabatabai. 1994; Gilmour et al.. 1996).
Researchers have attempted to calculate PMN using laboratory
methods, field studies, decay series, and computer models.
Field studies by Cogger et al. (1999) found apparent biosolids N
recovery of 28 to 40% for forage grasses and 11 to 44% for
dryland winter wheat. Results indicated a greater availability of
biosolids N in the second year of application than predicted
from commonly used biosolids decay series (USEPA. 1983).
Carryover N mineralized from biosolids applied to forage
grasses can be significant; cumulative apparent N recovery
increased by an average of 9% in the year following biosolids
application (Sullivan et al.. 1997). In a similar field study,
Plant Nutrient Issues
for Sustainable Land
Application
• Abstract
• Introduction
• Federal standards and
legislation
• Nitrogen
• Greenhouse gas emissions
• Phosphorus: Relative
Availability of Phosphorus...
• Summary and research needs
• References
• Figures
• Tables
Print this Agriculture Article
http://www.biology-online.org/articles/plant nutrient issues_sustainable/nitrogen.html 1 12/14/2007

Nitrogen - Plant Nutrient Issues for Sustainable Land Application Page 2 of 5
Barbarick et al. (1996) reported net N mineralization from 25 to
57% for five to six applications of 6.7 Mg biosolids ha-1 on
dryland winter wheat. More recent research from Barbarick and
Ippolito (2000) found that 1 Mg of biosolids was equal to
approximately 8 kg N fertilizer, whereas estimates calculated
using the USEPA (1983) approach for the same material were
only 6 to 7 kg N fertilizer equivalent per 1 Mg biosolids. They
also estimated first -year mineralization rates that ranged from
25 to 32%.
Computer models and constant decay series -have also been
used to predict the amount of available N in municipal waste
products. Gilmour and Skinner (1999) estimated PAN from six
biosolids using decay -series modeling. This included average
biosolids decomposition kinetic data from laboratory
incubations, average field site weather data, and biosolids
analytical data. Potentially available N released from biosolids
during the field study was linearly related to the biosolids C to N
ratio, organic N, or total N. Biosolids C to N ratio was the best
predictor of biosolids PAN in the field, followed by organic N
and total N. Slopes from the relationships of PAN to organic N
and total N suggested that about 45 and 40% of the biosolids N
was made plant available during the growing season,
respectively.
Gilmour and Skinner (1999) used two approaches to calculate
annual estimates of PAN from biosolids. For each approach,
the computer model Decomposition employed analytical data
for organic C, organic N, and inorganic N. One method used
actual decomposition kinetics and weather data, and the other
method used mean biosolids kinetics and mean weather data to
estimate biosolids decomposition (Gilmour et al.. 1996). Both
methods produced similar estimates of PAN for the same
biosolids source, but variability among biosolids was great.
Mean estimates for PAN during the first year for Methods 1 and
2 were almost identical at 32.4 and 32.0 kg N Mg-1 biosolids,
respectively. Overall, similar PAN predictions were obtained
with decay series using the computer model with average or
actual decomposition kinetics and weather data. This approach
was verified with field studies located across a wide range of
climatic conditions. Gilmour et al. (2003) reported that observed
and predicted PAN were strongly correlated (r2 = 0.72), with the
slope and intercept not significantly different than unity and
zero, respectively ( g_ 1) . The application of this approach to
other by-products has yet to be demonstrated.
Accurate estimates of PMN are also needed for animal waste
products. Land application of livestock manure can lead to
surface and ground water contamination if rates exceed crop
needs and reduce crop yields if rates limit N availability.
Nitrogen mineralization in manure is influenced by a host of
factors, both product -specific and environmental. Variability in N
mineralization is due partly to soil type and field environmental
conditions; however, the composition of the manure can
significantly influence the rate and amount of organic N
mineralization (Van Kessel et al.. 2000). Net N mineralization in
an incubation study ranged from —29.2 to 54.9% for several
different dairy manure samples (Van Kessel and Reeves.
2002). While manure sample analysis found compositional
differences in the samples, there was no strong correlation
between various composition parameters and organic N
mineralization (Van Kessel and Reeves. 2002). Van Kessel and
Reeves (2002) identified no relationship between near -infrared
http://www.biology-online.org/articles/plant nutrient issues_sustainable/nitrogen.html 12/14/2007

Nitrogen - Plant Nutrient Issues for Sustainable Land Application _ Page 3 of 5
spectral characteristics and N mineralization, but Qafoku et al.
2001 found a strong correlation (r2 = 0.82) between PMN and
predicted N in poultry litter using near -infrared reflectance
spectroscopy (Fig. 2) .
Haney..et_ a�2001 evaluated the relationships between the
flush of CO2 during 1 d after rewetting of dried soil and potential
soil N mineralization in the laboratory and forage N uptake in
the field following dairy cattle manure application. The flush of
CO2, or mineralized C, during 1 d was highly correlated with
potential N mineralized in soil after a 24-d incubation and forage
N uptake in the field. There was poor correlation between
residual inorganic soil N and N mineralized during the same
incubation. The C mineralized in 1 d after soil rewetting
represents a rapid and reliable laboratory test to estimate
potentially mineralizable N in manure -amended soils.
Ammonia Volatilization
The potential for NH3 volatilization from many land -applied by-
products, particularly poultry litter and anaerobically digested
and alkaline biosolids, poses environmental and agronomic
dilemmas. Concentrated animal feeding operations and
wastewater treatment facilities can also be significant sources
of NH3 emissions. Animal agriculture contributes approximately
50% of the total U.S. anthropogenic ammonia emissions (van
Aardenne et al.. 2001). Such N loss reduces the agronomic
fertilizer value of the by-products and contributes to
environmental problems such as acid deposition,
eutrophication, reductions in biodiversity, and human and
animal health concerns. In addition, NH3 exacerbates odor
problems and reacts with other atmospheric constituents to
produce haze. Conversely, NH3 volatilization could be viewed
as advantageous by allowing greater residual application rates
through reductions in the concentration of total N.
Quantification of NH3 emissions from various sources including
CAFOs, wastewater treatment facilities, and land application of
by-products is critical because of increased interest in the
environmental effects of atmospheric NH3 and the lack of
research on this topic. Unfortunately, the methodologies for
measuring of NH3 emissions in the field limit our capabilities to
predict N loss. Laboratory measurements are more useful for
determining relative differences in NH3 volatilization potential
than absolute field balances. Methods to accurately quantify
NH3 losses in the field have not yet been developed.
Chemical amendments can reduce NH3 loss from poultry
manure. Moore et al. (1995) tested several Al, Fe, and Ca
amendments for reducing N loss from poultry litter via
volatilization. Calcium hydroxide did not significantly affect NH3
loss in litter. Ammonia volatilization was reduced by 11 and
58% with high and low concentrations of FeSO4.7H2O,
respectively, and by 24 to nearly 100% with alum + CaCO3 or
alum alone. The higher alum rate resulted in a twofold increase
of the N concentration in the litter, which increased the value of
the material as an N fertilizer. Moore et al. (2000) also
demonstrated that poultry health and production could be
increased by alum reduction of NH3 emissions (Table 1).
http://www.biology-online.org/articles/plant nutrient issues_s-ustainable/nitrogen.html 12/14/2007

Nitrogen - Plant Nutrient Issues for Sustainable Land Application Page 4 of 5
Methods of application of by-product influence NH3 losses as
well. Hansen et al. (2003) compared NH3 losses from six
injection techniques with surface broadcast of liquid cattle
manure and found subsurface placement reduced NH3 losses
20 to 75%.
Composting, a commonly employed'organicwaste processing
method, can increase NH3 volatilization from manure depending
primarily on the C to N ratio. Organic and inorganic
amendments can also affect NH3 volatilization during the
composting process. Kithome et al. (1999)evaluated the
addition of adsorbents and chemical amendments to reduce
NH3 emission during the composting of poultry manure.
Adsorbents, such as zeolites, clay, and coir (fibrous material
that makes up the thick mesocarp of the coconut fruit), are
employed to bind NH3 and NH+4. Inorganic chemicals, such as
CaC12, CaSO4, MgC12, MgSO4, and Al2(SO46 will inhibit the
production of NH3. Ammonia loss from the unamended manure
ranged from 14 to 29% of total N during the first 3 d and
increased to 47 to 62% after 25 d. Manure amended with 38%
zeolite and 33% coir reduced NH3 losses by 44 and 48%,
respectively. The decreased volatilization resulted in greater
extractable N in amended composts, thereby increasing the N
fertilizer value. Alum also reduced NH3 volatilization, and
increased the total N concentration in the resulting compost
material.
Nitrate Leaching
Soil NO-3 accumulation and leaching to ground water are
increased on land that routinely receives animal wastes. Nitrate
from the Mississippi River basin has been implicated as one of
the primary causes for the hypoxic zone in the Gulf of Mexico
(USGS. 2000) (Fig. 3) .'Efficient N management is vital for
reducing N loss through both surface and subsurface transport.
Recent interest in hypoxia, and in N-based land application
systems has generated interest in improving N fertilizer
recommendation models to minimize nitrate losses from the
landscape.
Andraski et al. (2000) evaluated four cropping -manure
management system effects on soil water NO-3 concentrations
and leaching below the root zone in corn. Early -season soil
profile NO3 N contents varied among systems. Soil profile
NO3 N contents increased by 80 to 210 kg N ha-1 from April to
June in systems that had received past manure applications.
The continuous corn system,' with no manure history, had an
increase of only 20 kg N ha 1. Management systems with a
manure history had the greatest soil water NO3 N
concentrations. Total NO3 N leaching amounts were greaterfor
management systems with a history of manure application than
for cropping systems with no manure history, and the
economically optimum N rate was lower for sites with a history
of manure application's (Table 2).
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Chapter J
The Role of Nitrogen in Residuals Management
C. L. HENRY
College of Forest Resources, Box 352100, University of Washington, Seattle, WA 98195-2100
Abstract —Nitrogen applied as a component of residuals has a very dynamic nature. Prediction of its fate is the basis
of most application rate calculations, and approaches to application rate calculations vary considerably depending
upon the type of residual used. There are three general categories of N-containing residuals that require either
different approaches, or markedly different assumptions: solid and semi -solid, low C:N ratio residuals; solid and
semi -solid, high C:N ratio residuals; and liquid residuals. All three types rely on the basic transformations and losses
of the N cycle, but the contrast in the magnitude of these interactions requires intimate knowledge of the character-
istics of the amendment used. Similarly, research results indicate that stand conditions greatly affect the assimilative
capacity of N added from residuals applications and play a major role in any calculation of application rates.
Nitrogen (N) has traditionally been considered one of
the most important soil elements, as the lack of it most
commonly limits plant productivity. Nitrogen in many
forest systems is inadequate for maximum productivity,
as soils high in productivity often have been converted
to other (such as agricultural) uses. Because soils are
often deficient in N, plants usually respond to N fertili-
zation, and forests have increasingly been fertilized to
enhance productivity (Heilman 1981). Since the amount
of N in many residuals is relatively high, their attractive-
ness for use as soil amendments has increased over the
years.
Application rates of residuals for forest sites can be
based on a number of criteria, such as hydraulic load-
ing, organic loading, or metals loading, but in most cases
N limits rates, or at least much consideration must be
given to N loadings (McKim 1978, U.S. EPA 1981, 1995,
Polglase and Tunningley 1996). Typically, they are
matched to plant N requirements, but also may include
some immobilization in the soil. However, nitrogen ap:
plied as a component of residuals has a very dynamic
nature, and sites change in the availability and cycling
of N from repeated fertilizations of N.
N dynamics of forest systems are complicated in that
there are two components to plant requirements -the trees
and the understoryboth of which are perennial, there is
no annual harvest (removal of N from the site), and
there is a great degree of recycling of nutrients in decay-
ing vegetation, litterfall, twigs, and branches. Addition-
ally, as a stand progresses through different growth stages,
the environmental conditions change near the soil. All
of these factors affect the cycling of N in forest ecosys-
tems and impact the application rates of residuals.
It is well documented that excess N which exceeds the
assimilative capacity of soil will result in nitrate leach-
ing (Brockway and Urie 1983, Henry 1991, Hornbeck et
al. 1979, Sidle and Kardos 1979, Zasoski et al. 1984);
thus, it is important to understand the mechanics of the
calculations made in determining application rates.
Three categories of residuals are discussed here: solid
and semi -solid, low C:N ratio residuals, such as biosolids,
secondary pulp and paper sludges, and N-rich composts;
solid and semi -solid, high C:N ratio residuals, such as
primary pulp and paper sludges, wood wastes, and low-
N composts; and liquid residuals, such as effluent from
municipal or industrial wastewater treatment systems.
Although all three types of residuals rely on the basic
transformations and losses of the N cycle as shown in
Figure 1, the contrast in the magnitude of these interac-
tions requires intimate knowledge of the characteristics
of the amendment used.
atmospheric deposition
fertilization
NZ fixation NH3
L C
oxidation
nitrification
o`
(NH4
NHq+
NO3 `tfi .:v`
Figure 1. The nitrogen cycle: inputs, changes in the form of
nitrogen, and losses from the soils.
54 Henry

0
BASIC TRANSFORMATIONS AND LOSSES
The N from residuals changes form readily, some of
which are subject to losses to the atmosphere or ground-
water. The major transformations and losses are discussed
below.
Mineralization
Varying amounts of the N in residuals are available to
plants as ammonium (NH41 or nitrate (NOO; the rest is
present as organic N (ON) in microbial cell tissue and
other organic compounds. Mineralization of N (release
of NH4* as organic residues decomposes) depends on
the nature of the N compounds. Nitrogen mineraliza-
tion for the first year ranges from essentially none for a
high C:N material, to 10-40% of the organic N in
biosolids, to nearly 100% of some liquid wastes. Miner-
alization is often not complete in the first year, continu-
ing during the next few years at progressively slower
rates. Some of the N is retained in stable organic matter
(like humus), which continues to mineralize, but only
very slowly. As much as half of the organic N in some
biosolids may remain stable for decades.
Immobilization
High C:N materials may even immobilize mineral N
into ON (Henry 1991), or N released from residuals
may be taken up by soil microbes and converted back to
organic forms. Immobilization generally occurs in nutri-
ent poor soils, in soils with a lot of low-N, carbon -rich
matter (such as woody material or straw), or when or-
ganic amendments are added (such as sawdust or low-N
compost). C:N is often used as an indication of whether
mineralization or immobilization will occur. When the
surface soil layers or amendments have a C:N greater
than 30:1, immobilization is highly likely. Conversely,
when C:N is below 20:1, N mineralization is likely.
Ammonia Volatilization
The potential for losses of ammonia to the air de-
pends on several soil and atmospheric conditions: pH,
the temperature and wind speed, and whether the re-
siduals are incorporated either by mechanical action or
with movement of water. Most volatilization happens
within the first few days of application. In some forest
environments little volatilization may occur owing to
low pH of the forest floor, low wind speed in forest
stands, and less radiation reaching the forest floor. Con-
versely, dry, hot, open stands enhance volatilization.
Volatilization can range from negligible with wastewa-
ter in closed stands to nearly 100% for dewatered
biosolids applied in an and climate.
Plant Uptake
Trees and understory utilize the available N from
biosolids to increase growth. The N requirements for
different forest systems vary widely, from older stands
that require minimal N to rapidly growing hybrid pop-
lar stands that require >400 kg-N/ha/yr.
Nitrification
Microbes will oxidize available NH4' to NO3" Nitrifi-
cation rates are highest when soils are warm and moist
and pH is neither strongly acidic nor alkaline. In moist
climates (where rainfall exceeds evapotranspiration) NO3
leaching can occur; in and climates, this excess of NO3
will accumulate in the soil.
Denitrification
If the soil becomes depleted of Oz, some microbes
can use the O in NO3' as an alternative. Conditions
encouraging denitrification include: having NO3' avail-
able, soil or microsite saturation, soil temperature, and
having easily decomposable organic matter available.
Denitrification from biosolids application is usually low
(<25%) but can be dramatic with wastewater applica-
tions (over half of the N applied).
Litterfall and Special Conditions
Litterfall adds a complexity to N cycling. Presently, we
do not have a good database on the contribution litterfall
makes to the variety of forest systems, especially after
biosolids applications. We have seen longer needle re-
tention for several years following an application but
assume eventually more litterfall will occur.
Repeated applications may either build up organic
matter in forest ecosystems from increased litterfall or
mineralize existing forest floor and reduce the total N
pool in forest systems (such as found for wastewater ap-
plications) .
Other special conditions, such as thinning and prun-
ing, occasionally affect the N dynamics in managed for-
est systems. These activities resemble litterfall, except at
a far greater level, that temporarily increases the cycling
of N from the decomposing foliage.
APPROACHES FOR DETERMINING
NITROGEN APPLICATION RATES
The two basic approaches for determining biosolids
application rates based on N are shown in Figure 2.
The N Balance Approach
The objective of the N balance approach is to match
available mineral nitrogen to plant needs after additions
Role of Nitrogen in Residuals Management 55

ff
Basic Approaches to Making
Application Rate Calculations
Based on Nitrogen
N fertilization I soil amendment
The Nitrogen
Balance Approach Target C:N & OM
• annual balance •add organic matter
• storage •balanced C:N ratio
Figure 2. Approaches to determining nitrogen application
rates.
(mineralization) and losses (volatilization and denitrifi-
cation) take place. This is matched with the demand of
the plant/soil system (plant uptake and soil immobiliza-
tion) and is most common for N-rich materials and waste-
water. Conceptually, this is a stepwise procedure.
• Estimate the plant -soil requirements; what N the
plant needs minus what the soil supplies or plus
what the soil needs (immobilizes).
• Estimate the plant available N from biosolids (the
pool of N the plant has access to, accounting for the
losses and transformations).
The C:N and Organic Matter Approach
In contrast, the C:N and organic matter approach is
focused more on soil amendment properties of residu-
als, increasing the organic matter of the soil but in such
a way that there is not too much mineral N for the
plant -soil system to assimilate. Excess nitrogen added
from one amendment can be immobilized by C-rich
material (such as sawdust), or C-rich material will need
N added from another source. Whereas this approach
can be used in a number of situations, it is a relatively
new concept and requires much more fine-tuning in the
field to verify application rates.
SUMMARY AND LIMITATIONS
Many assumptions are necessary to determine appli-
cation rates of residuals in forest systems based on tree
and understory N requirements. Not all the N dynamics
of forest systems are well known because of nutrients
recycling in decaying litterfall and potential soil immo-
bilization. Also, application rates are greatly influenced
by stand dynamics and year of application.
Numerous areas lack comprehensive data and experi-
ence in a variety of situations that concern the compo-
nents of N dynamics. However, applications can be made
with confidence as long as estimates are initially conser-
vative, followed by a monitoring program to fine-tune
application rates.
New projects in different forest stands will continue to
improve the predictive capability of our N balance ap-
proach. Especially helpful will be a broad range of sites
with different tree species, climates, and soil conditions,
as most of our information now comes from the Dou-
glas -fir forests of western Washington.
REFERENCES
Brockway, D. C., and D. H. Urie. 1983. Determining sludge
fertilization rates for forests from nitrate-N in leachate and
groundwater. J. Environ. Qual. 12(4):487492.
Heilman, P. E. 1981. Minerals, chemical properties and fer—
tility tility of forest soils. p. 121-136. In P. E. Heilman et al.
(eds) Forest soils of the Douglas -fir region. Washington
State Cooperative Extension Service, Pullman. -
Henry, C. 1991. Nitrogen dynamics of pulp and paper sludge
to forest soils. Water Sci. Technol. 24(3/4):417-425.
Hornbeck, J. W., M. T. Koterba, and R. S. Pierce. 1979.
Sludge application to a northern hardwood forest in New
Hampshire: potential for dual benefits? In W. E. Sopper
and S. N. Kerr (eds.) Utilization of municipal sewage ef-
fluents and sludge on forest and disturbed land. Pennsyl-
vania State Univ. Press, University Park.
McKim, H. L. (ed.) 1978. State of knowledge in land treat-
ment of wastewater. Proc. Int. Symp. CRREL, Hanover,
NH.
Polglase, P. J., and W. M. Tunningley (eds.) 1996. Land ap-
plication of wastes in Australia and New Zealand: Re-
search and practice. Proc. 14th Land Treatment Collec-
tive Meeting. CSIRO Forestry and Forest Products,
Canberra.
Sidle, R. C., and L. T. Kardos. 1979. Nitrate leaching in a
sludge -treated forest soil. Soil Sci. Soc. Am. J. 43:278-282.
U.S. Environmental Protection Agency. 1981. Process design
manual for land treatment of municipal wastewater.
EPA625/ 1-81-013.
---. 1995. Process design manual for land application of
sewage sludge and domestic septage. EPA625/R-95/001.
Zasoski, R. J., R. L: Edmonds, C. S. Bledsoe, C. L. Henry, D.
J. Vogt, K. A. Vogt, and D. W. Cole. 1984. Municipal
sewage sludge use in forests of the Pacific Northwest,
U.S.A.: Environmental concerns. Waste Manage. Res.
2:227-246.
56 Henry

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31

Chapter 10 Nitrogen
The two nutrients of concern are nitrogen and phosphorous. Both of these are fertilizers
and either can be the limiting nutrient for plant growth in receiving streams. The term
'straight fertilizer' is used for any material that supplies only one of the three principal
macronutrients: nitrogen, phosphorus or potassium. Mixed fertilizers are those that
contain two or all three of the principal macronutrients. Both may be liquids, but usually
they are solids in granular form.. The manufacturer labels every container to show the
grade of the fertilizer. This is expressed by three numbers, which are the percentages of
the three major nutrients. Thus, a 4 -16 -18 fertilizer contains 4 percent nitrogen (N), 16
percent phosphoric oxide (P2O5), and 18 percent potassium oxide (K2O).1 Nitrogen will
generally stimulate the growth of foliage; phosphate assists root growth, energy storage
and flower formation while potassium contributes to cell wall strength. Roses seem to
prefer 18-24-16 (NPK) while other plants thrive on different amounts.
Adequate supplies of these nutrients (NPK) lead to rapid growth and reproduction of
algae, the eutrophication stage for the water system. The explosion in growth rate for
the algae is called a "bloom". Algae are plants and during times of sunlight add oxygen
to the water as a byproduct of photosynthesis, during the dark hours they absorb
oxygen. When the bloom reaches maximum growth, the algae begin to die.
Decomposition of the algae by bacteria also contributes to the oxygen depletion in the
water.
Nitrogen in wastewater is most commonly present in the form of bound organic nitrogen.
Biological treatment is required to convert the organic nitrogen; first to ammonia, next to
nitrite, then nitrate. Ammonia is produced under anaerobic conditions while the nitrate is
the product of aerobic digestion. If nitrate is produced, the nitrogen reduction has come
to a dead-end. Currently, it is not economically feasible to further reduce nitrate levels in
water. Ammonia can be, however; several methods are available: air -stripping, ion -
exchange and breakpoint chlorination.
The compounds of nitrogen are of interest to the wastewater treatment plant operator
because of the importance of nitrogen in the life processes of all plants and animals.
The chemistry of nitrogen is complex because of the several forms that nitrogen can
assume. Ammonia, organic, nitrate, and nitrite are the most important nitrogen forms in
wastewater treatment. Kjeldahl nitrogen is organic plus ammonia nitrogen.
Molecular nitrogen that is present in the air is of (almost) no concern as related to
nitrates: the only way molecular nitrogen can become nitrite and nitrate is through
fixation of the molecular nitrogen by bacteria such as rhizobium. These bugs are usually
associated with root system of plants such as legumes, but they may be present in a
lagoon environment. If so, input of nitrogen into a lagoon provides bacteria with an
essential nutrient which eventually is converted into a biomass, which after decay
contributes ammonia, nitrite and nitrate. While aerating a lagoon with air (^-79%
Nitrogen), the nitrogen combines very little (like in air, although the nitrogen dissolves in
the splashing along with the oxygen) with anything unless helped by bugs. Without
bugs (rhizobium, or some plants with nitrogen fixing nodules which most of the time are
bacterial colonies) atmospheric nitrogen (N2) does not get into the cycle. The only other
effect of air's nitrogen that is important in biological treatment is what happens in
aeration with air in deep tanks: oxygen is the most consumed molecule while nitrogen,
dissolved above saturation at normal pressure, upon release in the effluent the nitrogen

bubbles out and sludge is difficult to settle since in effect we have dissolved nitrogen
flotation. In such cases degasification (denitrogenation) is needed to help settling. This
aspect is often not considered by deep tank designers.
The Nitrogen Cycle
Whereas carbon, hydrogen, and oxygen are actively cycled by microorganisms, plants,
and animals, the biogeochemical cycling -of nitrogen is largely dependent on the
metabolic activities of microorganisms alone. Aside from the chemical fixation of
molecular nitrogen by human beings to form nitrogen fertilizers, the ability to fix
atmospheric nitrogen (the conversion of N2 to.ammonia or organic nitrogen) that can be
assimilated into biomass is restricted, almost exclusively, to a limited number of bacterial
species. Most microorganisms and all 'plants and animals are unable to use
atmospheric nitrogen directly and depend on the availability of fixed forms of nitrogen for
incorporation into their cellular biomass. Other than one exceptional case where a green
algae has been shown to fix atmospheric nitrogen, this process is carried out strictly by
bacteria. The productivity of many ecosystems is limited by the supply of fixed forms of
nitrogen. Ammonia is the first detectable product of nitrogen fixation. It is assimilated
into amino acids and subsequently synthesized into proteins and nucleic acids.
Proteins, amino acids, and inorganic ammonium ions are used as a source of nitrogen
by many organisms that are unable to assimilate atmospheric nitrogen directly.
It is estimated that microorganisms convert approximately 200 million metric tons of
nitrogen to fixed forms of nitrogen per year compared to about 30 million metric tons
produced by industrial production of nitrogen fertilizers. The fixation of atmospheric
nitrogen depends on the nitrogenase enzyme system. Nitrogenase is very sensitive to
oxygen and nitrogen fixation and, therefore, nitrogen fixation often is restricted to
habitats with appropriately low levels of free oxygen; the nitrogenase enzyme is
protected in some systems by leghaemoglobin, which supplies oxygen to the organisms
for respiration without denaturing the nitrogenase. ATP, adenosine triphosphate, is
required to drive the reactions catalyzed by the nitrogenase enzyme system... The
fixation of atmospheric nitrogen requires a high energy input (approximately 30 ATP/N2
fixed) and in terrestrial ecosystems is largely dependent on the availability of relatively
high concentrations of organic matter for use in generating ATP.
Nitrogen fixation in soil
In terrestrial habitats, the microbial fixation of atmospheric nitrogen is carried out by free-
living bacteria and by bacteria living in symbiotic association with plants. Symbiotic
nitrogen fixation by rhizobium is most important in agricultural fields, where this
bacterium lives in association with various crop plants. In forests, other symbiotic
nitrogen -fixing bacteria, including actinomycetes, live in association with various trees
and make significant contributions to the nitrogen needed to support the growth of
forests.. When growing in association with plants or animals, symbiotic nitrogen -fixing
bacteria, such as rhizobium species, generally exhibit rates of nitrogen fixation that are
two to three orders of magnitude higher than are accomplished by free-living nitrogen -
fixing soil bacteria. Rhizobium species associated with alfalfa, for example, can account
for an input of 250 kg of nitrogen fixed per hectare per year, as compared to 2.5 kg of
nitrogen fixed per hectare per year for free-living nitrogen -fixing Azotobacter species.

Ammonia may be oxidized to nitrite then to nitrate in varying degrees depending on
temperature, time and available oxygen. Nitrate is seldom found in raw wastewater or
primary effluent, but the secondary effluent- will have . some because of the biological
treatment -process..
To illustrate the concept of nutrient cycles. a simplified version of the nitrogen cycle will
be used as an example. A wastewater treatment plant discharges nitrogen in the form of
nitrate in the plant effluent to the; receiving waters. Algae take up the nitrate and
produce;. more algae. The algae are eaten h by fish which convert the nitrogen to amino
acids, urea and organic residues. If the fish die and sink to the bottom, these nitrogen
compounds can be converted to ammonium. In the presence of dissolved oxygen and
special bacteria, the ammonium is converted to nitrite then to nitrate, and finally the
algae can take up the nitrate and start the cycle all over again.
"Nitrogenous material can enter the aquatic environment from either natural or human -
caused sources. The proper delineation of these sources an often be clouded, since the
apparent quantities from natural sources can include nitrogen generated from human
activity. For example, while nitrogen fixation by lightning may be expected in rainfall, the
combustion of fossil fuels or the application of liquid ammonia agricultural fertilizers,
which subsequently releases to the air through volatilization can increase rainfall
concentration of Nitrogen substantially. The pervasiveness of human impact on the
environment limits the certainty with which naturally occurring Nitrogen and pollution
source Nitrogen can be differentiated quantitatively. Measurement of naturally occurring
baseline Nitrogen levels are best made in more remote, underdeveloped and pristine
areas; yet interpretation of these data -should still be considered uncertain to some
degree." 9
Nitrogen exists in many forms in the environment'. The movement and transformation of
these nitrogen compounds through the biosphere is characterized by the nitrogen cycle.
The atmosphere serves as a reservoir of nitrogen in the form of nitrogen gas. Although
virtually inexhaustible ( the atmosphere is 79 percent nitrogen), the nitrogen must be
combined with hydrogen or oxygen before it can be assimilated by higher plants, the
plants, in turn are consumed by animals. Fixation of nitrogen means the incorporation of
inert, gaseous nitrogen into chemical compounds such that it can be used by plants and
animals. Ammonification is the change from organic nitrogen to the ammonium form.
Synthesis, or assimilation, is a biochemical mechanism that uses ammonium or nitrate
compounds to form plant protein.. Nitrification is the biological oxidation of ammonium.
This is done in two steps, first to the nitrite form [NO2], then to the nitrate form [NO3].
Nitrification is a biological process accomplished primarily by two types of
microorganisms: Nitrosomonas and Nitrobacter, autotrophs. The proper conditions must
exist for Nitrosmomonas to be able to separate the nitrogen from the hydrogen in the
ammonium molecule and replace the hydrogen with oxygen molecules. Sufficient
oxygen and the appropriate temperature and microbiological food must be present to
accomplish this process. Nitrobacter also rely 'on oxygen to complete the stabilization of
the nitrite molecule into the more stable nitrate substance.
Denitrification is the biological reduction of nitrate to nitrogen gas. It can proceed
through several steps in the biochemical pathway, ' with the ultimate production of
nitrogen gas. A fairly broad range of heterotrophic bacteria are involved in this process.
The nitrogen cycle is complex and follows many paths.

The compounds of nitrogen are of interest to thewastewater treatment plant operator
because of the importance of nitrogen in the life processes of all plants and animals.
The chemistry of nitrogen is complex because of the several forms thatnitrogen can
assume. Ammonia, organic, nitrate, and nitrite are the most important nitrogen forms in
wastewater treatment: The term Kjeldahl (KELL-doll) nitrogen refers to organic plus
ammonia nitrogen. In wastewater, the definitions of TKN and TN are: TKN = organic
nitrogen + ammonia. TN (Total Nitrogen),= TKN + nitrate + nitrite = organic nitrogen +
ammonia + nitrate + nitrite. Therefore, the difference is the oxidized forms of nitrogen,
nitrate and nitrite. Depending on the treatment process, organic loading, and, other
considerations, one needs to decide which is important to test. If oxidized forms of
nitrogen affect the removal of ammonia, then those concentrations are important. In
secondary treatment process, nitrate and nitrite are usually tested, at least in summer
months. TKN is important because organic loading (from organic nitrogen) represents
oxygen demand.
Total Kjeldahl nitrogen (TKN) is a parameter that is frequently used. as an indicator of
industrial pollution and sewage (Boler 1992). This .parameter includes nitrogen. from
ammonia, amino acids, polypeptides, and proteins (Boler 1992). The concerns of
excessive TKN levels are largely the same as for excessive total nitrogen levels, though
the pressures are generally more from point sources such as sewage treatment plants
and industrial point sources.
Total nitrogen is the combined measurement of various forms of nitrogen in water
including nitrate, nitrite, ammonia, and organic nitrogen. Such nitrogenous compounds
along with other nutrients, serve as an important nutrient base for primary productivity.
When the concentration of these nutrients consistently exceeds natural levels, however,
a nutrient imbalance is produced. This imbalance can lead to undesirable changes in
the biological community and can- drive an aquatic system into an accelerated rate of
eutrophication. Typically, the eutrophication process leads to a change in the structure
.of the algal community, including severe algal blooms for extended periods of time. In
turn, the decomposition of these large algal blooms usually leads_ to a depletion in
dissolved oxygen concentrations (Friedemann and Hand 1989).
Chapter 11
Wastewater is relatively rich in phosphorous compounds, that is, domestic wastewater;
industrial wastewater may not have any. Phosphorus is essential to the growth of
organisms. The discharge of wastewater containing phosphorus may stimulate
nuisance algal growths. Phosphorus bans or limitations in synthetic detergents or
changes in detergent formulas by the manufacturers have served to reduce the
overloading.
Prior to 1940 phosphorous in wastewater was not a big problem., Normal domestic
wastewater only contained around 1 -to 5 mg/L phosphorous, generally in the form of
organic phosphorous or orthophosphate. However with the advent of more scientifically
designed detergents for washing clothes and dishes, the amount of phosphorous in
wastewater climbed rapidly. Phosphorous compounds are added to these formulations
as "builders" to sequester hard water producing metal ions like calcium and magnesium,
and improve the cleaning ability of the detergent by stabilizing the dirt particles in

solution. Most of these added 'phosphorous compounds are condensed or
polyphosphates.
Chemical -physical removal of phosphorous -from wastewater. is possible only when the
phosphorous is in the orthophosphate form. Although the organic and. condensed
phosphates can be easily converted into orthophosphate by treating them with strong,
hot oxidizing acid conditions, this is not .practical on a multi -million gallon per day scale.
Fortunately, most biological treatment processes perform the conversion of the organic
and condensed phosphates to orthophosphate.
Most orthophosphate salts are not soluble in water and phosphorous reduction is
achieved by forming an insoluble salt. The most common methods are to form the
insoluble calcium, aluminum or iron phosphates and let the salt,particles get caught in a
floc and settle to produce a sludge.
Dissolution of lime (CaO, calcium oxide) in water produces calcium ions and hydroxyl
ions. The hydroxyl ions serve to raise the pH to around 11 .SU. The calcium ions
connect with the orthophosphate ions already in solution to form calcium
hydroxyphosphate (hydroxyapatite). At pH 11 SU or higher, hydroxyapatite is not
soluble and forms a sludge on the bottom- of the settling tank. along with any calcium
carbonate formed by the reaction of calcium ions with carbonate (alkalinity) ions. After
the orthophosphate is removed, the water is acidified by carbon dioxide to lower the pH
to a value more suitable for discharge to receiving waters. The first stage carbonation
can be halted at pH 9.3 SU to allow all the 'remaining calcium carbonate to precipitate.
However, as this is, a very finely divided solid, polymer can be added to .increase the
particle size and speed the settling. -The second stage of carbonation reduces the pH to
the final' desired value of 7 to 8 SU.
Aluminum hydroxyphosphate is formed from alum treatment of the orthophosphate
containing wastewater. Alum (AISO4, aluminum sulfate) reacts with alkalinity to form the
floc of aluminum hydroxide. The aluminum ions combine with the orthophosphate and
alkalinity to form the solid aluminum hydroxyphosphate. The pH for successful
phosphate removal by alum treatment lies in a very narrow range around 6 SU and two
molecules of alum are required for every one of phosphate removed. At pH below 5 or
above 7 SU, the removal of phosphate is either incomplete or a fine solid forms which
has poor settling qualities.
Orthophosphate removal as iron hydroxyphosphate is achieved from ferric chloride or
ferric sulfate treatment. The iron ions in the solution' combine with alkalinity and
phosphate to form the insoluble ferric hydroxyphosphate and the floc ferric hydroxide
which helps in the precipitation. The ideal pH for this to occur is around 6 SU. Most of -
the sludge from this removal is moved into an anaerobic digester where reduction of
ferric iron to ferrous iron occurs. This does not affect the phosphorous removal as
ferrous phosphate (vivianite), also insoluble.
A problem with phosphate which is not really applicable as preferred method of
phosphate removal occurs in supernatant, recycle/removal lines from anaerobic
digesters. Magnesium ions, ammonium ions and phosphate ions can all exist in solution
if the pH is low, around 6 SU or so. However in the recycle pipelines, the pump suction
can release carbon dioxide from the supernatant, especially at pipe elbows. When the
carbon dioxide is removed, the pH goes up to around 10 SU and magnesium ammonium

phosphate (struvite) deposits in the pipe and on screens. Severe cases can result in
plugged pipes and major maintenance headaches.
Phosphorus, in addition to nitrogen, is a nutrient which can result in eutrophication of
receiving streams and lakes. The NPDES parameter is total phosphorous which means
that all forms of phosphorus, of which there are many, must be converted to
orthophosphate prior to analysis.

f
��L�Alkbli'�P,LANNIN
{ LL �—
i JAN 04 2000
ille Regional ®dice
Aciuifer Protection
AGINEERING
.BER
r 1VII FN rI NF F R I Nr SIIR V F V INr FN V I R r N M FN TAI SERVICES
Letter of Transmittal
To:
Lori Veal
NCDENR
Division of Water Quality
Land Application Unit
2728 Capital Blvd.
Raleigh, NC 27604
(919) 7156048
Project Name:
Millstone Inn and Condo Development
WQ003252
Project No:
242207
From:
Mark Brooks, P.E.
Brooks Engineering Associates, PA
17 Arlington Street
Asheville, NC 28801
[phone]
Date:
11/28/07
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
(Courier 52-01-00)
919/791-4200
DEC 2007
1 � ,
GFFICF .
❑ Mail ❑ Deliver U` Overnight* Other
9 *must use street address & include phone number
Document Description:
Date:
Use:
Fee Check for $1,409
12/11/07
permit
Revised Application WWIS 12-06
12/11/07
review
Response Letter 3 copies)
12/11/07
review
11x17 copies of Engineering Plans 2)
12/11/07
review
24x36 Engineering Plans 3)
12/11/07
1 review
Revised Specifications & Calculations 3)
12/11/07
review
Revised O&M Manual 3)
12/11/07
review
Comments:
17 ARLINGTON STREET ASHEVILLE, NO 28801 P: 828.232.4700 F: 828.232.1331 WWW.BROOKSEA.GOM

�F W A %FR
O� QG
_ [
p
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
C
November 28, 2007 E
JAN 04 20GG
ALEX D. BAKER - PRESIDENT
nPtianlfficQ
AIG BAKER CASHIERS, LLC
,�shev'sllc
AtlJfnr E'�n
1701 LEE BRANCH LANE
BIRMINGHAM, ALABAMA 35242
Subject: Application No. WQ0032352
Additional Information Request
Millstone Inn and Condominium
Development
Wastewater Treatment and Surface
Irrigation System
Jackson County
Dear Mr. Baker:
The Central and Regional Aquifer Protection Section's Express Reviewers have completed their review
of the subject permit application package. Additional information is required before we may continue our
review. Please address the following items no later than the close of business on December 12, 2007.
Please be aware that you are responsible for meeting all requirements set forth. in North Carolina rules and
regulations. Any oversights that occurred in the review of the subject application package are still the
responsibility of the applicant. In addition, any omissions made in responding to the above items may
result in future requests for -additional information.
Please reference the subject application number when providing the requested information. Three (3)
copies of all revised and/or additional documentation should be signed, sealed, dated, and submitted to
the address below. One (1) copy of all revised and/or additional documentation should be signed, sealed,
dated, and submitted to Rich Hayes in the Raleigh Regional Office. Please note that failure to provide
this additional information on or before the above requested date may result in your application being
returned as incomplete.
If you have any questions regarding this request, please do not hesitate to contact me at [phone].
Thank you for your cooperation.
Sincerely,
on M. Veal
Environmental Engineer II
cc: Rich Hayes — Raleigh Regional Office, Aquifer. Protection Section
Seth Hammer, P.E. — AIG Baker Cashiers, LLC
Mark C. Brooks, P.E. — Brooks Engineering Associates
Bob Kendall — Kendall & Associates, Inc.
Lynn Mann — Brooks Engineering Associates No"e Carolina
Permit Application File WQ0032352 �tdrrl!!!f
North Carolina Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: www.ncwaterquality.org 2728 Capital Boulevard Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

Mr. Alex D. Baker
November 28, 2007
Page 2 of 7
Application:
1. Upon submittal of the additional information prior to the close of business on Wednesday, December
12th, please submit a check made payable to the Department of Environment and Natural Resources
in the amount of $1,409. Failure to provide this check by 5:00 pm on December 12`h shall result in
the immediate return of the application package. Failure to provide all requested additional
information items shall result in an automatic additional information request.
2. Application Item II.2. lists the incorrect fee ($1,310). The appropriate Express Review fee that was
previously submitted is $5,635. Please correct.
3. Application Item 11.5. states that the Erosion & Sedimentation Control Plan is pending. Please
provide the date when the E&SC Plan was submitted. In addition, provide the anticipated date for
submittal of the associated collection system permit application.
4. Application Item III.3. shows a total flow determination of 16,400 gallons per day (GPD). During the
submittal meeting, the applicant inquired about reducing the flow allocation for the restaurant, since it
is expected to serve only one meal a day to community residents only. Based on 15A NCAC 02T
.0114, flow from a "single service restaurant" is assumed to be 20 GPD per seat. If the Applicant
wishes to utilize this classification, then submit a letter of certification specifying that the restaurant
will be restricted to serving one meal a day to on -site residents only, and revise all application
material and supporting documentation accordingly.
5. Revise Application Item IV.4. to provide the 100-year flood elevation in the project area. This
information must be provided even if the wastewater treatment plant and disposal fields are not
located within the flood plain.
6. Revise Application Item V.2.i. to provide information regarding the backup generator.
7. The Specification page numbers given for the location of wastewater treatment plant equipment in
Application Item V.2.c., V.21, and V.2.i. appear to be incorrect. Please revise to provide the correct
page,numbers.
8. Complete Application Item VII.5. by providing the average depth to the seasonal high water table
within the irrigation fields, consistent with the Soil Scientist's Evaluation.
9. Amend Application Items VII.7 and VH.11. to include information on the proposed irrigation area
only.
10. Revise Application Item VII.9. by providing the latitude/longitude coordinates for all six (6) irrigation
zones.
11. Complete Application Item VII.11. by providing the required agronomic information:
• Proposed mineralization and volatilization rates. (MR is typically assumed to be 20% for
aerobic/activated sludge type systems, and VR is typically assumed to be 20-30 % for drip
irrigation systems).
• Irrigation area based on the nitrogen balance.
• Irrigation area based on the phosphorus balance.
• -Indicate whether the site is hydraulically limited or nutrient limited.
Please ensure that this information is consistent with that provided in the Agronomic Evaluation.

Mr. Alex D. Baker,
November 28, 2007
Page 3 of 7
Agronomic Evaluation:
1. The Agronomic Evaluation provided uses effluent nitrogen concentrations that are not consistent with
the values provided in Application Item III.5. Per Application Instruction.L and 15A NCAC 02T
.0504(i), provide an Agronomic Evaluation that includes recommendations concerning cover crops and
their ability to accept the proposed application rates of liquid and nutrients. Plant Available Nitrogen
(PAN) expected in the effluent should be calculated using the following method:
PAN = [(MR) x (TKN — NH3 )] + [(1- VR) x (NH3 )] + [NO, + NO,
Where:
PAN - Plant Available Nitrogen
MR = Mineralization Rate (typically assumed to be 20% for aerobic/activated sludge
type systems)
VR = Volatilization Rate (typically assumed to be 20-30 % for drip irrigation systems)
TKN = Total Kjeldhal Nitrogen (value from WWTP effluent calculation)
NH3 = Ammonia Nitrogen (value from WWTP effluent calculation)
NO3 = Nitrate Nitrogen (value from WWTP effluent calculation)
NOZ = Nitrite Nitrogen (value from WWTP effluent calculation)
• Use the calculated value to determine the amount of PAN loading in pounds per year
based on the proposed. irrigation rates.
• Calculate the phosphorus loading using the expected effluent phosphorous
concentration.
• Specify the cover crop for the site and determine the applicable PAN and phosphorus
uptake values. Divide the loading values by the appropriate uptake values to
determine the required acreage.
• Use this information to show whether the site is nutrient limited or hydraulically
limited (Application Item VII.11.), and make any resulting revisions to the
application package.
• Please ensure that the values used for nitrogen and phosphorus calculations are
consistent with the WWTP design effluent values given in the Engineering
Calculations and Application Item HI.5.

Mr. Alex D. Baker
November 28, 2007
Page 4 of 7 _
Agronomic Evaluation (continued)
2. 15A NCAC 02T .0505(c) requires that all wastes be applied at agronomic rates, unless predictive
calculations are provided to document that State groundwater standards will be protected. Predictive
calculations shall comply with the method outlined in Appendix B of the Division's "Groundwater
Modeling Policy", effective May 31, 2007.
• Section 3.0 — Agronomic Analysis, contained in the Soil Evaluation assumes that 100% of the
PAN uptake rate for the cover crop may be subtracted from the total PAN loading. However, the
above referenced policy allows for 50% removal of the Realistic Yield Expectation. Please revise
accordingly.
Section 3.0 — Agronomic Analysis, contained in the Soil Evaluation assumes that dilution by
ambient groundwater will reduce the leachate concentration by half. However, this is not
consistent with the Hydrogeologic Evaluation, which states that ambient groundwater is not
present. Furthermore, the above -referenced policy does not assume dilution of the calculated
leached concentration.
Please re-evaluate the predictive calculations utilizing the method and assumptions outlined in Appendix
B of the Division's Groundwater Modeling Policy (http://h2o.enr.state.ne.us/lau/policies.html), and
ensure that all values used in the predictive calculations are consistent with what is provided in
Application Items HI.5. and IV.2., the Agronomic Evaluation, and the Engineering Calculations.
Soil Evaluation:
1. Per 15A NCAC 02T .0504(b)(2)`, the Soils Evaluation shall contain recommendations for the annual
hydraulic loading rate (inches/year) for all irrigation fields. Please provide. Please note that the
annual loading value(s) given in Application Item VII.7. shall be consistent with the Soil Scientist's
recommendation.
2. Please provide a copy of all Ksac data worksheets.
Detailed Plans:
➢ General Plans
1. Application Item IV.3. states that restricted access will be achieved by placing a fence around the
wastewater treatment plant and signs around the disposal fields. Provide a detail of the fence and the
signage to be used, in accordance with 15A NCAC 02T .0505(q).
2. Per 15A NCAC 02T .0506(b), a 50-foot setback is required between treatment/storage units and
surface waters. Irrigation supply and return lines are considered part of the treatment/storage system.
While the design meets this requirement, please amend Sheets E-1, E-12 and E-13 to clearly specify
this 50-foot setback between the return lines and the delineated spring head.
➢ Sheet E-1
1. It appears that a small part of the irrigation area on Lot 14 maybe within the required 100-ft buffer to
the lake and the required 50-foot buffer to private right of ways. Please address, and revise if
necessary.
2. Provide labels for the irrigation zones shown on Sheet E-1.

Mr. Alex D. Baker
November 28, 2007 �.!
Page 5 of 7 '-
Detailed Plans (continued):
3. Amend Sheet E-1 to clearly label the required 50-foot setback between wastewater treatment/storage
units and property lines.
➢ - Sheet E-2
1. Per Application Instruction N, the hydraulic profile shall extend from the treatment plant headworks
to the highest disposal point. Please revise the hydraulic profile to include the highest disposal point.
➢ Sheet E-12
1. Plan Sheet E-12 shows irrigation supply/retum lines crossing the subdivision road. Will this road be
classified as a "public right of way"? If so, then the proposed design would require an easement from
the North Carolina Department of Transportation. If this is the case, please provide documentation of
the NCDOT easement agreement in order for the Division to move forward with the project review.
If, however; the road is to be privately owned and maintained, then an easement will be required for
crossing all property lines associated with the road. This easement(s) must be recorded in the
associated deed(s) since the permit and associated property will -likely be transferred to a
Homeowner's Association (HOA) in the future. Please`"submit documentation of this 'easement(s).
Site Map:
1. The site map (provided on Sheet E-1) does not show all of the required information within 500 feet of
wastewater treatment and disposal areas. Per 15A NCAC 2T .0504(d), provide a site map that has
been signed and sealed by a licensed NC Professional Engineer that includes all of the following
items at a minimum:
• A scaled map of the site, with topographic contour intervals not exceeding 1.0 feet or 25 percent of
total site relief and showing all facility -related structures and fences within the treatment, storage
and utilization sites.
�K Soil mapping units (i.e., soil series) shown on all irrigation areas.
• The location of all wells (including usage and construction details if available), streams
(ephemeral, intermittent, and perennial), springs, lakes, ponds, . and other surface drainage
features within 500 feet of all waste treatment, storage, and irrigation area(s). Note this includes
sites located offproperty.
• Delineation of the review and compliance boundaries.
• All setbacks as required by 15A NCAC 2T .0506(a) and .0506(b).
• . Site property boundaries (including, all easements within the property) within 500 feet of all waste
treatment, storage, and disposal site(s). Note this includes off site property.
• All habitable residences or places of public assembly within 500 feet of all waste treatment,
storage, and disposal site(s). Note this includes proposed residences.

Mr. Alex D. Baker
November 28, 2007
Page 6 of 7
Engineering Calculations:
No calculations were provided to verify the design effluent concentrations provided in Application
Items 111.5. (Page 7) and IV.2. (Page 9) will be met. Per 15A NCAC 02T .0504(c)(3) and Application
Instruction Q, engineering calculations must include hydraulic and pollutant loading calculations for
each treatment unit. Therefore, please provide the required engineering calculations to verify the
design effluent concentrations for all the parameters listed in Item 111.5. This information is critical
since reduced setbacks to property lines have been requested under 15A NCAC 02T .0506(c), which
requires the WWTP to achieve reclaimed water effluent standards under 15A NCAC 02T .0906.
2. Section 1.0 of the Specifications document states that the Advantex® system is expected to achieve
enhanced nitrification and nutrient removal by utilizing a loading rate that is lower than the
manufacturer's recommendations, and returning 10% of the filtrate to the second septic tank. Provide
verification in the form of predictive calculations or certification from the manufacturer that these
methods will provide sufficient nutrient removal to meet the design effluent concentrations provided
in Application Items III.5. (Page 7) and IV.2. (Page 9). In addition, provide any third party
verification that may be available. .
3. Application Item I1I.5. shows a total phosphorus (TP) reduction from 12 mg/1 to 2 mg/l. However, no
phosphorus removal process is discussed. Revise the engineering calculations to address phosphorus
removal and verify that the design effluent TP concentration is feasible.
4. Provide sludge production calculations to verify that at least 30-days of residuals holding capacity
. will be provided, in accordance with 15A NCAC 02T .0505(o).
5. Division policy does not allow soil overburden to be used in buoyancy calculations. However, the
minimum weight of water (below pump off float) may be used. In addition, a safety factor of 1.2 is
generally required. Please revise the buoyancy calculations accordingly for the below -ground tanks
and revise the anti -floatation design if necessary.
6. Please provide manufacturer's information ( i.e., cut -sheets) for the proposed flow -meter and the drip
irrigation system equipment.

Mr. Alex D. Baker
November 28, 2007
Page 7 of 7
Residuals Management Plan:
1. Application Item IV.7. states that thirty (30) days of residuals storage is provided. However, the
Residuals Management Plan that is included in the Operation and Maintenance Manual does not
contain all of the required information. Per 15A NCAC 02T .0508, a Residuals Management Plan
shall be provided that addresses how these residuals will be handled and disposed. The Plan shall
include at a minimum the items listed in Application Instruction T:
• A detailed explanation describing how the residuals that are generated by the wastewater treatment
system will be stored, treated, and disposed.
• An evaluation of the residuals storage requirements for the treatment facility based upon the
maximum anticipated residuals production rate and ability to remove residuals.
• A permit for residuals utilization or a written commitment to the Permittee of a Department
approved residuals disposal/utilization program accepting the residuals which demonstrates that
the approved program has adequate capacity -to accept the residuals, or that an application for
approval has been submitted.
• Please note that if an on -site restaurant is contributing waste to the system, an oil/grease disposal
plan will be necessary, and operation and maintenance of all grease traps will be the responsibility
of the Permittee. The Engineering Plans and Specifications shall detail any grease traps. Please
revise the application material as necessary.
General:
1. 15A NCAC 02T .0505(i) requires flow equalization of at least 25% of the facility's permitted
hydraulic capacity for all seasonal or resort facilities and all other facilities with fluctuations in
influent flow which may adversely affect the performance of the system. Since no dedicated flow
equalization is provided in the proposed design, please provide a statement from the engineer to detail
how the proposed design will comply with this rule.
2. During the site visit there was a discussion about the location of the treatment plant with regards to a
planned water supply well. Please confirm that the current plans accurately depict the location of the
treatment plant. If any change to its location is planned, then revise all applicable plan sheets. In
addition, please revise the location of the water supply well if necessary.
3. During the site visit a temporary access road was observed near the proposed site of the treatment
plant and water supply well. If some. or all of this road will be permanently used in the future to
provide access to the treatment plant, then please revise all applicable plans as necessary so that this
road is accurately located.
4. Please note that due to the proposed irrigation loading above agronomic rates, the permit will require
a monitoring well network to ensure that the proposed system remains in compliance with
groundwater (15A NCAC 02L) standards. Water quality monitoring will also be required in the
spring located in the southern portion of Lot 7.
5. Per Application Instruction N., please submit the required two (2) sets of 11 X.17 inch plans.

W 0032352 - MILLSTONE INN AND CONDOMINIUM
EXPRESS REVIEW
DEVELOPMENT? -� .� � �� OCT,
SUBMITTAL MEETING — WEDNESDAY, NOVEMBER 14TH @ 11:00 AM.
SITE VISIT — MONDAY NOVEMBER 19TH ' �' ° 93 Y -61.3 N
REVIEW MEETING WEDNESDAY, NOVEMBER 28 1:00 PM
ADDITIONAL INFORMATION # 1 DUE - WEDNESDAY, DECEMBER 12TH BY 5 : 00
ADDITIONAL INFORMATION MEETING (1). — WEDNESDAY, DECEMBER 19TH @ 3:00 PM TENTATIVE)
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AFFILIATION
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RICH HAYES
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