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HomeMy WebLinkAboutNC0028746_Fact Sheet_20220911DENR/DWQ EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit: NCO028746 2021 Renewal This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Facility and Stream Information Applicant/ Facility Name: Aqua North Carolina, Inc. / Briarwood Subdivision WWTP Applicant Address: 202 Mackenan Court; Cary, NC 27511 Facility Address: Weatherford Drive; King, NC 27021 Facility Class Permit Status: Grade II Biological WPCS Renewal Permitted Flow (as built) US MGD Type of Waste 100% Domestic Receiving Stream UT Brushy Fork Creek Stream Class / ID C / 22-25-1 River Basin Roanoke Subbasin 03-02-01 HUC 030101030201 USGS Too Kin 7Q10 Sum Win cfs 0.08 30Q2 cfs Avg. Stream Flow cfs IWC %) sum/win 49 County Stokes Regional Office WSRO Basic Information for Expedited Permit Renewal Permit Writer / Date Bradley Bennett / June 23, 2022 Updated 9/11/22 Does permit need daily max NH3 limits? No - Has monitoring and tox limits Does permit need TRC limits/language? Yes - Already in permit Does permit have toxicity testing? Yes - Pass/Fail Does permit have Special Conditions? Yes - Chronic Tox Does permit have instream monitoring? Yes - Temp and DO Stream on 303 d List? For w arameter? No - Mercury statewide issue only Any compliance concerns? I No Enforcements and a few Violations Any modifications since lastpermit? None in app but inspection noted bar screen New expiration date: February 28, 2027 FACILITY OVERVIEW: This facility is 100% domestic waste and treats a subdivision serving a population of 323 people. The facility has a permitted and as built flow rate of 0.05 MGD. The treatment system includes the following wastewater treatment components: • Influent sedimentation chamber • Aeration basin • Clarification basin • Tablet chlorination • Contact chambers • Dechlorinator Bar Screen - This component has been added to the treatment system since the last permit and has been noted by the Regional Office in a 2019 inspection and subsequent NOV. There is no record of an ATC for adding this component. See discussion below under Inspections. The facility also holds collection system permit WQCSD0228. The last inspection under the collection system permit was August 8, 2019 and there were no violations. APPLICATION The application does not indicate any changes in the facility or treatment since the last renewal of the permit. The treatment system is operated by Aqua North Carolina, Inc. The annual average daily flow is indicated as 0.011 MGD over the last two years, so the facility is operating at well below its designed and permitted capacity. The application indicated a different outfall location than is on the previous permit and in BIMS. Based on map reviews this location appears to be more accurate for the location of the treatment facility. The current location in our records is northeast of this location. The draft permit has changed this location and it will be verified through the WSRO. See discussion under Inspection about bar screen that has been added to the facility. INSPECTION The most recent inspections occurred in 2019 - February 1st and a follow-up inspection on March 28th. The February 2019 inspection resulted in an NOV for a number of issues - floating solids in the clarifier; housekeeping issues; bar screen construction without an ATC (also previously noted in an October 30, 2017 NOV); inappropriate monitoring procedures; excessive solids in the contact chamber; discharge of solids. The subsequent follow-up inspection found that most issues were either corrected or being addressed. One issue not resolved was the bar screen construction without proper approval. The Winston-Salem Regional Office has verified that they did not receive any response on this issue. Division ATC staff (Min Xiao) were consulted on this issue and indicated they had been made aware of this previously and contacted the permittee. They will check into this issue and assess the need for an Engineering Certification for the work. ATC staff have been given information on this issue for their review (email attached). Since the bar screen component is in place and confirmed by the regional office staff it will be added to the draft permit. MONITORING DATA REVIEW: Parameter Units Min Max Avg Permit Limit Comments Flow (MGD) 0.00 0.039 0.01 0.05 MA Flow well below permit limit BOD (mg/L) Summer < 2 27.2 3.2 30 MA 45 DM No Exceedances TSS (mg/L) < 2.5 17.3 3.9 30 MA 45 DM No Exceedances Temp (C) - Effluent 7 29 18.4 - Temp (C) - Upstream -2 24 13.1 - Temp (C) - Downstream 0 25 18.4 - NHs-N (mg/L) < 0.2 6.25 0.91 - DO (mg/L) - Effluent 6.2 13.3 9 - DO (mg/L) - Upstream 6.9 17.5 10.5 - DO (mg/L) - Downstream 5.3 16.8 10.1 - Fecal Coliform (#/ml) < 1 275 6.9 200 MA 400 DM No Exceedances TRC (µg/L) 4 47 12.3 28 DM No values > compliance level of 50 Total Nitrogen (mg/L) 6.3 33.7 12.9 - Total Phosphorus (mg/L) 4.04 7.53 5.4 - pH (su) 1 6.3 1 8.7 1 N/A >-6 and <-9 No Exceedances MA -Monthly Average DM - Daily Max QA -Quarterly Average DA - Daily Average Summer - April through Oct Winter - Nov through March The data reviewed for the renewal is from July 2017 through April 2022. REVIEW OF PERMIT LIMITS: Flow - The facility is operating on average at around 20% of the flow allowed by the permit. None of the 58 monthly average values was above 0.018MGD. Briarwood Subdivision WWTP Fact Sheet NPDES Renewal 2022 - July 18, 2022 Page 2 BOD / TSS / Fecal - No limit violations occurred for any of these limited parameters over the permit cycle. TRC- The facility reported 48 values of TRC that were over the 28µg/L limit but none of these values exceeded the compliance threshold of 50. Ammonia (NH3 N - In July 2016 the NPDES program began implementation of revised ammonia criteria based on the potential for toxic impacts from ammonia [memo attached in the Fact Sheet]. Previously, some 100% domestic discharges were allowed to choose an effluent toxicity test instead of an ammonia limit. That option is no longer available. As those permits are received for renewal (or major modification), ammonia limits are being included in this permit in accordance with the 2016 memo. The effluent toxicity test will be removed, as it was only in those permits in lieu of an ammonia limit. The effluent toxicity test is being replaced with a more stringent standard (the ammonia effluent limits) so, removal of the toxicity requirement is consistent with NPDES permitting requirements. The Waste Load Allocation spreadsheet for this discharge calculated NH3-N limits of 1.8 mg/L for both winter and summer limits. However, Division policy has established that for small discharges (< 1 MGD) the best available treatment technology for these facilities leads to monthly average limits no lower than 2 mg/L - summer and 4 mg/L - winter. Limits in the permit will be set as follows: Monthly Avg Daily Max Frequency Type Location NH3-N - Summer 2 m /L 10 m /L Weekly Composite Effluent NH3-N - Winter 4 m /L 20 m /L Weekly Composite Effluent The data reviewed for this renewal would indicate that the facility can maintain these permit limits. During the previous permit cycle, evaluating the data with these limits results in only one monthly average violation over the permit cycle. COMPLIANCE: During the permit cycle this facility had two assessed NOVs, one for a failed chronic toxicity test in October 2018 and an NOV for violations noted in the 2019 inspection discussed above. There were no enforcement actions over the permit term and no assessed violations (NOD, NOV) for monitoring issues. There have been no enforcement actions since 2010. FILE HISTORY REVIEW SUMMARY • June 10, 1999 - Authorization to Construct (ATC) approved for steel weir plate and relocation of flow monitor. • March 2000 - ATC request for liquid chlorine process to replace tablet chlorination. • July 2000 - Add -info on March ATC request for liquid chlorine process to replace tablet chlorination. Division noted the proposal was not justified. • October 2000 - Document indicating no ATC necessary for removal of unused tertiary filter and holding tank. • 2002 Permit Renewal - this is the earliest permit in the file buts stem permitted prior to this time. Flow (MGD) BOD m L TSS m L DO m L Fecal per 100 mL pH Chronic Tox 0.05 30 45 30 45 >6 200 400 6 to 9 Pass fail The permit also included effluent monitoring for NH3-N, TRC, Temp, TN, and TP. Instream monitoring (U & D) was required for Temp, and DO. • 2004 - Name change to Aqua North Carolina, Inc. • 2007 Permit Renewal - added 28µg/L limit for TRC with an October 2008 compliance date. • 2012 Permit Renewal - No Changes • 2017 Permit Renewal - added eDMR language and rule citations. Briarwood Subdivision WWTP Fact Sheet NPDES Renewal 2022 — July 18, 2022 Page 3 PROPOSED PERMIT CHANGES: • Updated eDMR requirements to be consistent with final EPA rule. • Added regulatory citations throughout permit as needed. • Added Bar Screen to treatment components. • Added NH3-N effluent limits of 2/5 - summer and 4/20 winter. This change will also result in the removal of the Chronic Toxicity monitoring requirement and special condition. • Permit map information updated including location of outfall point. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: July 26, 2022 Permit Scheduled Effective Date: November 1, 2022 STATE CONTACT: If you have questions concerning the above or the attached documents, please contact Bradley Bennett at bradley.bennett@ncdenr.gov . SUPPLEMENT TO FACT SHEET The permittee, Aqua, submitted comments on the draft permit. Their request was for a two (2) year compliance schedule for the added Ammonia (NH3-N) limit. This request is to allow the permittee to adjust treatment plant operations and make modifications necessary to comply with the new limits. The Division is in agreement with this requested schedule of compliance and has added language in the permit as a footnote to the effluent page to set a schedule of compliance for the permit limits for NH3-N that will be in effect two years from the effective date of the permit. Monitoring for NH3-N will still be required beginning on the effective date of the permit. Briarwood Subdivision WWTP Fact Sheet NPDES Renewal 2022 — July 18, 2022 Page 4 NORTH CAROLINA STOKES COUNTY AFFIDAVIT OF PUBLICATION Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to administer oaths, personally appeared Sandra Hurley who being first duly sworn, deposes and says: that he (she) is Regional Publisher (Publisher or other officer or employee authorized to make affidavit) of ADAMS PUBLISHING GROUP, LLC, engaged in the publication of a newspaper known as THE STOKES NEWS, published, issued, and entered as periodicals class mail in the city of King in said County and State; that he (she) is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a true copy of which is attached hereto, was published in THE STOKES NEWS on the following dates: - -� and that the said newspaper in which such notice, paper, document or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning of Section 1-597 of the General Statutes of North Carolina. This �� day of , 2022 making Sworn to and subscribed fore me, this X da} of 2022 Notary Public My Commission expires: �Xgxe—' C 1 ��C� JENNAJOHNSON Notary Public - North Carolina Surry County My Comrrussioe Expires September 13, 2026 ! Public Notice North Carolina Environmental Management Commission/NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NP- DES Wastewater Permit NCO028746 Briarwood Subdi- vision WWTP The North Caro- lina Environmental Manage- ment Commission proposes to issue a NPDES wastewater discharge permit to the per©on(s) listed below. Written comments regaruir,9 the pro- posed permit will be accepted until 30 days after the publish date of this notice. The Direct- or of the NC Division of Water Resources (DWR) may hold a public hearing should there be a significant degree of public interest. Please mail com- ments and/or information re- quests to DWR at the above address. Interested persons may visit the DWR at 512 N. Salisbury Street, Raleigh, NC 27604 to review information on file. Additional information on NPDES permits and this no- tice may be found on our web - site: http://deq.nc.gov/about/di- v i s i o n s/wate r- res o u rc e s/wate r- reso u rces-perm its/wastewate r- branch/n pdes-wastewater/pub- lic-notices,or by calling (919) 707-3601. AQUA North Caro- lina, Inc [202 MacKenan Court; Cary, NC 275111 has reques- ted renewal of NPDES permit NCO028746 for the Briarwood Subdivision WWTP, located in Stokes County. This permitted facility discharges 100% do- mestic wastewater to a UT to Brushy Fork Creek, a class C; water in the Roanoke River Basin. Some of the paramet- ers in the permit are water quality limited. This discharge may affect future allocations in this segment of the Brushy Fork Creek. Publish: 7-28-22 70062952 109672 2x Bennett, Bradley From: Sent: Bennett, Bradley Tuesday, July 26, 2022 11:54 AM To: Pearce, Joseph R; Berger, Amanda A Cc: Lambeth, Robyn E; Ison, Laurie T; Simmons, Randy L Subject: RE: [EXTERNAL] Draft Permit for Briarwood WWTP - NC0028746 Thanks for the comments Joe. We will look at this issue when finalizing the permit. Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradlev.bennettC@ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Pearce, Joseph R <JRPearce@aquaamerica.com> Sent: Tuesday, July 26, 2022 11:48 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov>; Berger, Amanda A <AABerger@aquaamerica.com> Cc: Lambeth, Robyn E <RELambeth@aquaamerica.com>; Ison, Laurie T <LTlson@aquaamerica.com>; Simmons, Randy L <RLSimmons@aquaamerica.com> Subject: RE: [EXTERNAL] Draft Permit for Briarwood WWTP - NC0028746 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Bradley, With respect to the Ammonia Limit, please recognize this 50 year old wastewater treatment plant was built as a contact stabilization wastewater treatment plant and not an extended aeration wastewater plant. If one looks at the wastewater treatment plant data closely, one will note that it does not always fully nitrify. As such, we request a two year schedule of compliance to meet the ammonia limit, which will allow us time to make necessary improvements to modify the facility to fully nitrify. Joe u ,.Lv #rIP AL A Joseph Pearce PE CFM Director of Operations Aqua North Carolina, Inc. 202 MacKenan Court Cary, North Carolina 27511 0:919.653.6964 F:919.460.1788 w V #; From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Tuesday, July 26, 2022 8:57 AM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com> Subject: [EXTERNAL] Draft Permit for Briarwood WWTP - NCO028746 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Attached is the draft permit for Briarwood Subdivision WWTP — NC0028746. Of note in this draft is the addition of limits for Ammonia (NH3-N). As noted in the cover letter, this change is one that the Division is making due to procedure changes from a few years ago. Previously the Division would allow Toxicity testing in lieu of NH3-N limits for 100% domestic discharges. Essentially allowing the tox test (biology) to take the place of a chemical limit. EPA has responded to the Division on this issue and indicated that this is not an acceptable approach. With this change the permit is also proposing to remove the previously required toxicity testing. If you have any questions, please let me know. Please respond to this email to confirm that you received the draft permit and can download, open and print the file for your records. Thanks fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.ben nett(aMcdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws NH3/TRC WLA Calculations Facility: AQUA - Briarwood Subdivision WWTP Permit No. NC0028746 Prepared By: Bradley Bennett Enter Design Flow (MGD): 0.05 Enter s7Q10 (cfs): 0.081 Enter w7Q10 (cfs): <= Permitted Flow if Different from Design Total Residual Chlorine (TRC) Ammonia (Summer) Daily Maximum Limit (ug/1) Monthly Average Limit (mg NH3-N/1) Design Permitted Design Permitted s7Q10 (CFS) 0.081 s7Q10 (CFS) 0.081 DESIGN FLOW (MGD) 0.05 DESIGN FLOW (MGD) 0.05 DESIGN FLOW (CFS) 0.0775 s DESIGN FLOW (CFS) 0.0775 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22 IWC (%) 48.90 IWC (%) 48.90 Allowable Conc. (ug/1) 35 Allowable Conc. (mg/1) 1.8 < 1 MGD Policy Applies Design Permitted Fecal Coliform Monthly Average Limit: 200n00mi #VALUE! (If DF >331; Monitor) (If DF<331; Limit) Dilution Factor (DF) 2.05 € #VALUE! Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Design Permitted w7Q10 (CFS) 0 DESIGN FLOW (MGD) 0.05 DESIGN FLOW (CFS) 0.0775 STREAM STD (MG/L) 1.8 Upstream Bkgd (mg/1) 0.22 IWC (%) 100.00 Allowable Conc. (mg/1) 1.8 Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/l, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals) 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed • By Policy dischargers < 1 MGD get limits no lower than 2 & 4 due to BAT * From 2B .0404(c) - Winter Limits can be no less stringent than 2 times the summer limits Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) Bennett, Bradley From: Thomas, Zachary T Sent: Tuesday, July 19, 2022 9:21 AM To: Bennett, Bradley Cc: Moore, Cindy; Graznak, Jenny Subject: RE: Draft Permit Renewal for Briarwood Subdivision WWTP - NC0028746 Hi Bradley, All of this sounds good to ATB — please let us know if we can help with anything and I will keep an eye out for the final permit and update our database accordingly! Thank you, Zach Thomas Environmental Specialist II Aquatic Toxicology Branch, Compliance and Enforcement NCDEQ— Division of Water Resources — Water Sciences Section Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. 919.743.8439 Office 919.743.8517 Fax zachary.thomas@ncdenr.gov 1621 Mail Service Center Raleigh, NC 27699-1621 Submit ATForms electronically to: ATForms.ATB@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, July 18, 2022 4:50 PM To: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Graznak, Jenny <jenny.graznak@ncdenr.gov> Subject: RE: Draft Permit Renewal for Briarwood Subdivision WWTP - NC0028746 Zach, We have had some discussion in our group about the Ammonia/Tox questions for 100% domestic facilities. We are going to start changing these facilities to ammonia limits rather than the toxicity requirements. This is in keeping with Division guidance on ammonia criteria and is consistent with EPA's concern for our use of toxicity measurements in place of chemical parameter limits. For this permit we will propose to remove the tox requirement and add ammonia limits of: Monthly Avg Daily Max NH3-N - Summer 2 mg/L 10 mg/L NH3-N - Winter 4 mg/L 20 mg/L The 2 and 4 limits are a result of Division policy for small (< 1MGD) facilities to have limits no more stringent than these levels. Thanks for your help on this one and let me know if you want to discuss further. mm Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Sent: Wednesday, June 29, 2022 4:20 PM To: Bennett, Bradley <bradley.ben nett@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Graznak, Jenny <ienny.graznak@ncdenr.gov> Subject: Re: Draft Permit Renewal for Briarwood Subdivision WWTP - NC0028746 Hi Bradley, Yep - this looks more consistent with the language for limited permits! I checked against another limit permit we received recently and they appear to match. Let me know what you think about the option of them being 100% domestic and how switching them to a limit for ammonia may play out. ATB is trying to catch facilities at the permit renewal stage to see if they are a good fit for that option. Thank you, Zach Thomas Environmental Specialist II Aquatic Toxicology Branch, Compliance and Enforcement Officer NCDEQ— Division of Water Resources —Water Sciences Section Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. 919.743.8439 Office 919.743.8517 Fax zachary.thomas@ncdenr.gov 1621 Mail Service Center Raleigh, NC 27699-1621 Submit ATForms electronically to: ATForms.ATB@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, June 29, 2022 7:14 PM To: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Graznak, Jenny <]enny.graznak@ncdenr.gov> Subject: RE: Draft Permit Renewal for Briarwood Subdivision WWTP - NCO028746 Zach, Does this version look better? m Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Sent: Wednesday, June 29, 2022 3:57 PM To: Bennett, Bradley <bradley.ben nett@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Graznak, Jenny <ienny.graznak@ncdenr.gov> Subject: Re: Draft Permit Renewal for Briarwood Subdivision WWTP - NC0028746 Hi Bradley, Yes, it looks like the language for the 2017 permit was off from what it should say. It should have had another paragraph in there that stated what they are required to do when a test results in a "fail". I will be in the office and my schedule is pretty open tomorrow if you would like to set up a Teams call to chat about it - just let me know! Thank you, Zach Thomas Environmental Specialist II Aquatic Toxicology Branch, Compliance and Enforcement Officer NCDEQ— Division of Water Resources — Water Sciences Section Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. 919.743.8439 Office 919.743.8517 Fax zachary.thomas@ncdenr.gov 1621 Mail Service Center Raleigh, NC 27699-1621 Submit ATForms electronically to: ATForms.ATB@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, June 29, 2022 6:55 PM To: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Graznak, Jenny <ienny.graznak@ncdenr.gov> Subject: RE: Draft Permit Renewal for Briarwood Subdivision WWTP - NCO028746 Zach, I went back and looked at permits prior to 2017 and I think the issue is that the 2017 Special Condition Language was off. It also had Monitor and Report under effluent limits in the effluent table. I'll take that out as well. M Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettCa@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Bennett, Bradley Sent: Wednesday, June 29, 2022 3:48 PM To: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Graznak, Jenny <ienny.graznak@ncdenr.gov> Subject: RE: Draft Permit Renewal for Briarwood Subdivision WWTP - NCO028746 Zach, I have attached the previous permit for the Brairwood Subdivision (NC0028746) permit. Take a look, maybe we just had some language off before, but he Special Condition in the 2017 permit looks more similar to the Template for Pass/Fail Monitoring that we use today? Maybe we can talk at some point so I can make sure I have the right thing in the permit. Thanks for looking through this with me. I'm pretty slow when it comes to the tox stuff so I need your help! Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nettcDncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Sent: Wednesday, June 29, 2022 11:57 AM To: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Bennett, Bradley <bradley. bennett@ncdenr.gov> Cc: Graznak, Jenny <lenny.graznak@ncdenr.gov> Subject: Re: Draft Permit Renewal for Briarwood Subdivision WWTP - NC0028746 Please see attached for reference. Thank you, Zach Thomas Environmental Specialist II Aquatic Toxicology Branch, Compliance and Enforcement Officer NCDEQ— Division of Water Resources — Water Sciences Section Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. 919.743.8439 Office 919.743.8517 Fax zachary.thomas@ncdenr.gov 1621 Mail Service Center Raleigh, NC 27699-1621 Submit ATForms electronically to: ATForms.ATB@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Moore, Cindy <cindy.a.moore@ncdenr.gov> Sent: Wednesday, June 29, 2022 2:44 PM To: Thomas, Zachary T <zachary.thomas@ncdenr.gov>; Bennett, Bradley <bradley. ben nett@ncdenr.gov> Cc: Graznak, Jenny <menny.graznak@ncdenr.gov> Subject: RE: Draft Permit Renewal for Briarwood Subdivision WWTP - NC0028746 Just as an FYI. In 2014, the Town of Parkton asked for relief from the WET test siting that this facility was 100 domestic. Town of Parkton had several noncompliant issues, which included BOD ,etc. Permitting changed the WET test to monitoring only but kept the test in the permit siting those noncompliant issues. From: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Sent: Wednesday, June 29, 2022 11:29 AM To: Bennett, Bradley <bradley.ben nett@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov>; Graznak, Jenny <jenny.graznak@ncdenr.gov> Subject: Re: Draft Permit Renewal for Briarwood Subdivision WWTP - NC0028746 Hi Bradley, I have reviewed the draft permit and ATB has a few comments: ATB currently has this facility has a limit rather than monitoring only. Are we switching them to a monitoring only requirement? If not, the language will need to be update in the A2 section to reflect follow-up testing requirements. Also, this facility appears to be 100% domestic and may be eligible to request ammonia limits instead of performing toxicity testing if they choose. It does appear that they had a failure back in 2018, but have been passing consistently since then. I have attached a copy of the toxicity change memo above for reference. NPDES Test Date .i Ttype I Result LabNum Ccmpliani Nur N C0028746/001 411312022 Pass 27 C NC'0028746/0D1 111712022 Ceri?dPF Pass 27 C NC0023746/001 10/18/2021 Ceri fdPF Pass 27 C N C0023746/001 7/26/2021 C eri?d P F P= 27 C i N C00287461001 411912021 C er1. P a � � 27 C NC0023746/001 1/1812021 Ceri?dPF Pass 27 C NC00287461001 101512020 Ceri fdPF Pass 14 C NC0023746/001 71112020 Ceri?dPF Pass 14 C N C00287461001 41112024 C eri f d P F Pass 14 C NC0023746/001 11612020 Ceri?dPF Pass 14 C NC00287461001 101112019 Ceri fdPF Pass 14 C NC0023746/001 71112019 Ceri?dPF Pass 14 C NC00287461001 41112019 Ceri fdPF Pass 14 C Please let me know if you have any questions. Thank you, Zach Thomas Environmental Specialist II Aquatic Toxicology Branch, Compliance and Enforcement Officer NCDEQ— Division of Water Resources — Water Sciences Section Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. 919.743.8439 Office 919.743.8517 Fax zachary.thomas@ncdenr.gov 1621 Mail Service Center 8 Raleigh, NC 27699-1621 Submit ATForms electronically to: ATForms.ATB@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, June 29, 2022 11:59 AM To: Thomas, Zachary T <zachary.thomas@ncdenr.gov> Subject: Draft Permit Renewal for Briarwood Subdivision WWTP - NCO028746 Hey Zach, Here is the draft Briarwood Subdivision WWTP (NC0028746) permit renewal for your review. The renewal application is available in Laserfiche if you need that. This one should go to public notice the week of July 11'. If you have any comments, please pass them along before then if you can. Thanks fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Hennessy, John Sent: Thursday, July 7, 2022 3:30 PM To: Bennett, Bradley; Carpenter, Sydney; Richards, Emily; Corporon, Joe; Weaver, Charles; Chen, Siying; Phillips, Emily; Wiggins, Kent Subject: Ammonia v TTox Attachments: Ammonia Permitting Guidance 2016.pdf, EPA Triennial Review Response Letter 2016.pdf Recently, I have had several discussions about ammonia in 100% domestic facilities. In the past, we used to allow 100% domestic facilities to choose between an ammonia limit or a test. After the 2016, triennial review, EPA eliminated that option. The attached two documents speak to that. We must now assess ammonia limits. I think we can remove tox testing without triggering anti -backsliding. We will discuss all this in the next staff meeting. PAT MCCRORY Governor DONALD R. VAN DER VAART secremry Water Resources ENVIRONMENTAL QUALITY S. JAY ZIMMEi RMAN Director Memorandum To: NPDES Complex Unit From: Tom Belnick Date: July 20, 2016 Subject: NPDES Permitting Guidance NPDES Implementation of Ammonia Criteria- Update NC has still not adopted an ammonia standard, though it is on our WQS Triennial List for next round. NC did establish ammonia chronic criteria for use in NPDES permitting back in 1989/90, which was based on EPA's 1986 criteria development document that factored in pH/Temp across three regions of the State (see attached). This evaluation resulted in ammonia chronic criteria of 1.0 mg/l NH3-N (summer) and 1.8 mg/l NH3-N (winter) for use in permitting purposes. NC implements these chronic criteria as Monthly Averages limits utilizing instream dilution. In 2002, NC developed procedures for complimentary acute permit limits (discussed below). The current ammonia permitting procedures should be as follows: • The NH3/TRC Wasteload Allocation (WLA) spreadsheet automatically calculates appropriate ammonia Monthly Average limits for summer and winter. The spreadsheet assumes a background ammonia concentration of 0.22 mg/1. • For any permit (new/renewal), always run the NH3/TRC WLA spreadsheet to verify appropriate Monthly Average Ammonia Limits for protection of aquatic life. • If the allowable ammonia concentration is greater than 35 mg/l, no limit should be imposed. • If the allowable concentration is less than 35 mg/l, then the allowable limit is needed and the spreadsheet will automatically calculate it. • For Municipal facilities, the acute limit will be expressed as a Weekly Average, and is based on multiplying the Monthly Average limit by a factor of 3. • For non -Municipal facilities, the acute limit will be expressed as a Daily Maximum, and is based on multiplying the Monthly Average limit by a factor of 5. • If a new more stringent ammonia limit is required, discuss the need for a Compliance Schedule with senior staff and then with the Permitee. • There is no RPA procedure used for ammonia; it is implemented strictly based on WLA spreadsheet results (similar to TRC). State of North Carolina I Environmental Quality I Water Resources 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 919 707 9000 Page 12 • A sample NH3/TRC WLA is attached. In this example, the spreadsheet indicates that Monthly Average ammonia limits of 3.2 mg/1 and 12.7 mg/1 should be imposed for summer and winter, respectively, in order to protect for NC's chronic ammonia criteria. Some additional considerations: This guidance will need to be revisited after NC formally adopts an ammonia standard for both chronic and acute aquatic life protection. In the past, some ammonia limits were based strictly on protection of our DO standard rather than ammonia toxicity, and that is why the permit writer should always verify the correct ammonia limit with any permit renewal using the WLA spreadsheet. In the past, some practices allowed for maintaining a less stringent ammonia limit if the facility was consistently passing the WET test (i.e., biology trumps chemistry). This is no longer a valid approach and EPA would object. In April 2016 EPA expressly stated that NC cannot use biology to override chemical results. EPA also disallowed the use of Action Levels in permitting, in which toxicity test results (if passing) were used to override the need for permit limits for copper/zinc/silver/iron/chloride. AMMONIA CRTTERTA TABLES (NH3 as N) Based on EPA recommended 4-day maximum average concent.ration criteria (Mou'ntain'sand Trout Waters TEMPERATURE H 120C 230C . 6.8 1.8084 1.0028 Total Ammonia 7.5 1,.8084 1.0111 (mg/l NH3 as N) Pie•dmon:t Freshwaters r TEMPERATURE H 140C 2 60C 6.8 1.8084 1.1344 Total Ammonia 7.5 1.8084 1.1541 (mg/1 NH3 as N) Coastal Plain and Sandhills Freshwaters TEMPERATURE H 160C 280C 6.8 1.7920 0.9700 Total Ammonia 7.5 1.7920 0.9864 (mg/1•NH3 as N) S Ex NH3/TRC WLA Calculations Facility: Anywhere USA NC00 Prepared By: Tom Belnick Enter Design Flow (MGD): 0.03 Enter s7Q10 (cfs): 0.13 Enter w7Q10 (cfs): 0.32 Total Residual Chlorine (TRC) Ammonia (Summer) Daily Maximum Limit (ug/1) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 0.13 s7Q10 (CFS) 0.13 DESIGN FLOW (MGD) 0.03 DESIGN FLOW (MGD) 0.03 DESIGN FLOW (CFS) 0.0465 DESIGN FLOW (CFS) 0.0465 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22 IWC (%) 26.35 IWC (%) 26.35 Allowable Cone. (ug/1) 65 Allowable Cone. (mg/1) 3.2 Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 0.32 Monthly Average Limit: 200/100mi DESIGN FLOW (MGD) 0.03 (If DF >331; Monitor) DESIGN FLOW (CFS) 0.0465 (If DF<331; Limit) STREAM STD (MG/L) 1.8 Dilution Factor (DF) 3.80 Upstream Bkgd (mg/1) 0.22 IWC (%) 12.69 Allowable Cone. (mg/1) 12.7 Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) Bennett, Bradley From: Bennett, Bradley Sent: Friday, July 8, 2022 5:25 PM To: Carpenter, Sydney Subject: RE: Another Aqua Permit for Review - Briarwood Subdivision WWTP - NC0028746 Thanks Sydney. As I mentioned in the teams chat John and I did talk about the ammonia issues and I will add that in on this draft. No Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradlev.ben nettCaMcdenr.gov Email correspondence to and from this address may be subject to public records laws From: Carpenter, Sydney <sydney.carpenter@ncdenr.gov> Sent: Friday, July 8, 2022 4:31 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: Another Aqua Permit for Review - Briarwood Subdivision WWTP - NC0028746 Hi Bradley, I didn't find much during my review of the draft permit for Briarwood Subdivision! Everything looks good. -Facility might need ammonia limits (see John's recent email regarding Ammonia vs. TOX) -Map coordinates don't match the coordinates we have in BIMS, but they do match the ones submitted in the application, and I saw your requested the permittee to confirm that they are the correct coordinates. -Factsheet doesn't include a 'snapshot' of their TOX history, which I usually include for my facilities that have TOX monitoring. Not a major thing. That's it! Thanks! Sydney Carpenter (she/her) Environmental Specialist I Compliance and Expedited Permitting Unit Division of Water Resources N.C. Department of Environmental Quality Office: 919-707-3712 sydney.carp enterPncdenr.gov 1617 Mail Service Center Raleigh, INC 27699-1617 P=E Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, June 29, 2022 8:52 AM To: Carpenter, Sydney <sydney.carpenter@ncdenr.gov> Subject: Another Aqua Permit for Review - Briarwood Subdivision WWTP - NCO028746 Hey Sydney, Here is second Aqua North Carolina Inc permit renewal for review. This one is for Briarwood Subdivision WWTP (NC0028746) in Stokes County. It has been added to the OneDrive folder along with the Mikkola Downs draft for review and the direct link is below. M NCO028746 - Aqua - Briarwood Subdivision WWTP Thanks [37 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nettcDncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Bennett, Bradley Sent: Wednesday, June 29, 2022 8:57 AM To: Graznak, Jenny Subject: Draft Briarwood Subdivision Renewal - NCO028746 Attachments: NC0028746_Fact Sheet Binder_2022.pdf; NC0028746_Draft Permit and Cover Ltr_ 2022.pdf Hey Jenny, Here is the draft Briarwood Subdivision WWTP (NC0028746) permit renewal for your review. The renewal application is available in Laserfiche. This one should go to public notice the week of July 11t". If you have any comments, please pass them along before then if you can. Thanks m Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.ben nett&ncdenr.gov Email correspondence to and from this address may be subject to public records laws 1 Bennett, Bradley From: Sent: Kinney, Maureen Wednesday, June 29, 2022 9:06 AM To: Bennett, Bradley Subject: RE: Draft Permit Renewal for Briarwood Subdivision WWTP - NCO028746 Good Morning Bradley, The classification looks good, thank you! Mat we 4,v Kbn*iey NCDEQ/ DWR / PWS NC Wastewater Operator Certification Program 919-707-9038 Correspondence to and from this address is subject to the NC Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, June 29, 2022 9:01 AM To: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Subject: Draft Permit Renewal for Briarwood Subdivision WWTP - NCO028746 Hey Maureen, Here is the draft Briarwood Subdivision WWTP (NC0028746) permit renewal for your review. The renewal application is available in Laserfiche. This one should go to public notice the week of July 11t". If you have any comments, please pass them along before then if you can. Thanks m Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Bennett, Bradley Sent: Tuesday, June 28, 2022 12:59 PM To: Xiao, Min Cc: Graznak, Jenny Subject: ATC Question for Briarwood Subdivision WWTP - NCO028746 Attachments: NC0028746_NOV-2019-PC-0062_20190207.pdf, NCO028746_NPDES Inspection With All files available under Categories_20190201.pdf, NCO028746_NPDES Inspection With Categories_ appropriate year in Laserfiche 20190328.pdf, NC0028746_Issuance of Perm it_20170609.pdf Hi Min, Thanks for talking with me about this one and checking into it. As I mentioned, it looks like they installed a bar screen without any prior approval possibly as far back as 2017. 1 have attached the most recent permit along with Inspections from 2019 and an NOV from 2019 as well. The 2019 NOV mentions the ATC issue and also notes that this was mentioned in a 2017 NOV. I could not find the 2017 NOV in Laserfiche though. The ORC listed in BIMS is Morgan Lee Turner. There is no email address but phone is listed as (336) 996-2841 The contact on the Renewal Application is Amanda Berger - aaberger@aquaamerica. com phone 919) 653- 6965 Let me know if you need anything else or if you find something on this one. fi:3 Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.ben nett(o)ncdenr.gov Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Bennett, Bradley Sent: Tuesday, June 28, 2022 12:43 PM To: Graznak, Jenny Subject: RE: Aqua NC Inc - Briarwood Subdivision WWTP - NC0028746 Hey Jenny Just wanted to give you a heads up. I talked with our ATC expert (Min Xiao) about this, and she seemed to remember maybe getting involved with this issue a while back after some discussions with regional staff. At least she thinks it was this one. At that time, she had contacted them and asked for an ATC. She wants to get more info on this one and pursue it with them. You may hear from her sometime later this week bout it. I am going to sent her some info and I will copy you when I do. fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Graznak, Jenny <jenny.graznak@ncdenr.gov> Sent: Thursday, June 23, 2022 8:28 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: Aqua NC Inc - Brierwood Subdivision WWTP - NC0028746 Yes I think it should be an add info request if it's not listed as components. I don't know about forcing an ATC after all this time, and especially after this office didn't pursue it. Jenny Graznak Assistant Regional Supervisor Winston Salem Regional Office Division of Water Resources Department of Environmental Quality 450 West Hanes Mill Road, Suite 300 Winston Salem NC 27105 336-776-9695 office 336-403-7388 mobile jenny.graznak@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, June 22, 2022 4:06 PM To: Graznak, Jenny <menny.graznak@ncdenr.gov> Subject: RE: Aqua NC Inc - Brierwood Subdivision WWTP - NCO028746 Okay. Is there anything that you think we need to do with this on during the renewal process? The bar screen isn't in the last permit under treatment system components. Should I add it in on the renewal? Do you want me to mention this issue to them as an add info request? I guess I'm not sure what we would usually do in these situations? Do we make them get an after the fact ATC? I can check up here add see what I can find out or maybe you have dealt with this before. m Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@.ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Graznak, Jenny <jenny.graznak@ncdenr.eov> Sent: Wednesday, June 22, 2022 4:02 PM To: Bennett, Bradley <bradley.ben nett@ncdenr.eov> Subject: RE: Aqua NC Inc - Brierwood Subdivision WWTP - NCO028746 I have searched through our files and I do not think we ever got a response from them or followed through on enforcement. I see where Lon made a site visit in 2019 but then nothing happened after that, that I can tell. Jenny Graznak Assistant Regional Supervisor Winston Salem Regional Office Division of Water Resources Department of Environmental Quality 450 West Hanes Mill Road, Suite 300 Winston Salem NC 27105 336-776-9695 office 336-403-7388 mobile 6enny.graznak@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, June 22, 2022 10:43 AM To: Graznak, Jenny <lenny.graznak@ncdenr.gov> Subject: Aqua NC Inc - Brierwood Subdivision WWTP - NCO028746 Hey Jenny, I'm working on this renewal now and had some questions. There were a couple of inspections in 2019 that noted some compliance issues. Some look to have been handled but one in particular I didn't see any resolution on. They had put in a manual bar screen without an ATC. There was an NOV but no enforcement. I didn't see anything in LF that showed they had responded. Could you check and see if you guys ever got a response from them on this issue? Thanks MM Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennettC@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Weaver, Charles Sent: Wednesday, June 22, 2022 11:53 AM To: Bennett, Bradley Subject: RE: Question on Permit Renewal - Briarwood Subdiv (NC0028746 I've already corrected BIMS. CHW From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, June 22, 2022 11:52 AM To: Weaver, Charles <charles.weaver@ncdenr.gov> Subject: RE: Question on Permit Renewal - Briarwood Subdiv (NC0028746 Thanks Charles, That matches with what is showing on the Tox Results Info. I'll make that change in BIMS also. No Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradlev.ben nettCaMcdenr.gov Email correspondence to and from this address may be subject to public records laws From: Weaver, Charles <charles.weaver@ncdenr.gov> Sent: Wednesday, June 22, 2022 11:50 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: Question on Permit Renewal - Briarwood Subdiv (NC0028746 I don't know why there were no old WI -As in the file when I pulled it for scanning. I did find a flow study from 1994 on the S: drive. It indicates the summer 7Q10 should be 0.081 cfs. The study is attached. I'd use 0.081 cfs in your IWC calculation. I'll upload the flow study to Laserfiche, too. CHW From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, June 22, 2022 11:39 AM To: Weaver, Charles <charles.weaver@ncdenr.gov> Subject: Question on Permit Renewal - Briarwood Subdiv (NC0028746 Hey Charles, 1 This permit has Chronic Tox. and the testis set at 49% effluent concentration. I thought this was supposed to be the IWC. For this one BIMS indicates that all flow values (7Q10, 30Q2) are zero. So, should this one be 100% or is there some other reason it has always been 49%? 1 can't find any old WLA files for this permit to look at flow numbers. There was only one permit (2017) in the hard copy file and the scanned files I found on the shared drive only had permits, ATC and Correspondence. Any advice you could give on this would be appreciated. Thanks Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov Raleigh, NC 27699-1617 , ATC Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Bennett, Bradley Sent: Tuesday, May 31, 2022 11:26 AM To: Graznak, Jenny Subject: Aqua Renewals up for review next on my list Hey Jenny, Hope you are doing well. I just wanted to get in touch with you and let you know that the next permit renewals that I will be working on are a group of Aqua Facilities that are all in the W-SRO. The list is below. If you guys have any input on these as I'm getting started, please let me know. Forward these on to the right contacts in your region if others might have comments or concerns with these. Here is the list: Permit Owner Facility County NCO067091 Aqua North Carolina, Inc. Mikkola Downs Subdivision WWTP Forsyth NCO028746 Aqua North Carolina, Inc. Briarwood Subdivision WWTP Stokes NCO078115 Aqua North Carolina, Inc. Gre stone Subdivision WWTP Forsyth NCO083933 Aqua North Carolina, Inc. Salem Quarters WWTP Forsyth Thanks 1*-1V Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws