NC0040355_Additional Information Requested_19910402

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State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Govemor George T. Everett,Ph.D.
William W. Cobey, Jr., Secretary Director
April 2, 1991
Mr. George W. Jensen, P.E.
Jensen Engineering
P. O. Box 18149
Asheville, N.C. 28814
Subject: NPDES Permit No. NC0040355
Royal Oaks, Inc.
Haywood County
Dear Mr. Jensen:
The Division of Environmental Management is currently processing your NPDES Permit to
discharge treated wastewater into East Fork Pigeon River. Before we can proceed further with
your application, Royal Oaks, Inc., must submit an engineering wastewater disposal alternatives
analysis that justifies the most cost effective and environmentally sound treatment alternative has
been selected. The analysis must conform to the attached document, "Guidance for Evaluation of
Wastewater Disposal Alternatives." The preliminary engineering proposal submitted with the
application package does not contain all that is required by the guidance package. Your design
flow numbers must conform to the flow activity guidance contained in regulation 15 NCAC 2H
.0200 (copy attached).
The analysis must be submitted by April 30, 1991, or the division may return your project as
incomplete.
If you have questions please contact Mr. Max Hanes at 704-251-6208.
cc: Asheville Regional Office
Technical Support Branch
Pollution Prevention Pays
cerely,
ale Overcass ,
NPDES Permits Supervisor
RECEIVED
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] ��P o 1991
An Equal Opportunity Affirmative Action Employer TECHNICAL SUPPORT

EH;VR - EA'I'IRO.\'.11EVTAL ,11ANAGE:1MENT TI5.4: 02H .0200
Type of Establishments
Airports, also RR Stations, bus terminals.
(not including food service facilities)
Barber Shops
Bars, Cocktail Lounges (not including
food services)
Beauty Shops
Bowling Alleys
Businesses (other than those
listed in this table)
Camps
Construction or work camps
Summer camps
Camp grounds Without water
and sewer hookups
Travel trailer/recreational vehicle park
with water and sewer hookup
Churches (not including food service, day care
and camps)
Country Clubs — Resident Members
Nonresident Members
Day Care Facilities
Factories (exclusive of industrial
wastes) — per shift
Add for showers — per shift
Food Service Facilities Restaurants
(including fast food)
24—hour Restaurants
Single —Service (exclusive of fast food)
Food Stands
(1) Per 100 square feet of total floor
space
(2) Add per employee
Hospitals
Laundries (self—service)
Marinas
With bathhouse
Meat Markets
(1) Per 100 square feet of total floor
space
(2) Add per employee
Motels/Hotel
with cooking facilities in room
Nursing/Rest Homes — With laundry
Without laundry
Daily Flow
For Design
5 gal/passenger
50 gal/chair
20 gal/seat -
125 gal/booth or bowl
50 gal/lane
25 gal/employee
60 gal/person
60 gal/person
100 gal/campsite
120 gal/campsite
3 gal/seat
60 gal/person
20 gal/person
15 gal/person
25 gal/person
10 gal/person
40 gal/seat or
40 gal/ 15 ft2 of
dining area,
whichever
is greater
50 gal/seat
25 gal/seat
50 gal
25 gal
300 gal/bed
500 gal/machine
10 gal/boat slip
30 gal/boat slip
50 gal
25 gal
120 gal/room
175 gal/room
120 gal/bed
60 gal/bed
NORTH C. t ROLINA .4 D.I I LVI S TR.4 TI I E CODE 10122190 Page 19

EHNR - ENVIRONMENTAL MANAGEMENT TISA: 02N .0200
Offices — per shift
Residential Care Facilities
Resort
Restaurants
Schools
Day Schools
With cafeteria, gym, and showers
With cafeteria only
With neither cafeteria nor showers
Boarding
Service Stations
Stadiums, Auditoriums, Theaters, Drive—ins
Stores, shopping centers and malls — Note: if
food service is included, add 40 gal/seat
Swimming Pools and Bathhouses
25 gal/person
60 gal/person
200 gal/room
40 gal/seat or
40 gal/15 ft2 of
dining area_
(whichever
is greater)
15 gal/student
12 gal/student
10 gal/student
60 gal/person
250 gal/water closet
or urinal
5 gal/seat or space
120 gal/1000 ft2
10 gal/person"
(3) An adjusted daily sewage flow may be granted upon a showing that a sewage system is adequate
to meet actual daily water consumption from a facility included in Subparagraph (1) or (2) of
this Paragraph. Documented, representative data from that facility or a comparable facility shall
be submitted, consisting of at least 12 consecutive monthly total water consumption readings
and daily total water consumption readings for at least 30 consecutive days of water use. The
daily readings shall be taken during a projected peak sewage flow month. The adjusted design
daily sewage flow shall be determined by taking the numerical average of the daily readings that
fall within the upper 10 percent of the daily readings when ranked in descending order.
(m) Additional requirements:
(1) distance between water supply wells and waste facilities in accordance with Rule 2C .0107(a)
of this Chapter or, if a greater area may be impacted, a distance in accordance with the perimeter
of compliance described in Rule 2L .0103(h) of this Chapter;
(2) compliance with the groundwater standards specified in Subchapter 2L of this Chapter;
(3) where applicable compliance with rules on "coastal waste treatment disposal" found in Section
.0400 of this Subchapter; and
(4) For subsurface disposal systems, compliance with rules on subsurface disposal systems found
in Section .0300 of this Subchapter.
(n) Alternative Design Criteria may be approved by the Director. This approval will only be given
in cases where the applicant can demonstrate that the Alternative Design Criteria will provide the fol-
lowing:
(1) Equal or better treatment of the waste; and
(2) Equal or better protection of the waters of the state; and
(3) No increased potential for nuisance conditions.
Histozy Note: Statutory Authority G.S. 143-215.1; 143-215.3(a) (1);
Eff October 1, 1987;
Amended Eff. August 1, 1988.
.0220 CERTIFICATION OF COMPLETION
Prior to the operation of any sewer system, treatment works or disposal system permitted in accord-
ance with this Section, a certification must be received by the permitting agency from a professional
engineer certifying that the sewer system, treatment works or disposal system has been installed in ac-
cordance with the approved plans and specifications. For facilities with phased construction or where
there is a need to operate certain equipment under actual operating conditions prior to certification,
additional certification may be needed as follow-ups to the initial, pre -operation, certification.
.\'ORTII C.1RO1.LV.1 . 11.).111.\'ISTN.1 T11'E• CODE 10/22190 Page 74

GUIDANCE FOR EVALUATION OF WASTEWATER DISPOSAL ALTERNATIVES
Proposed Discharge
I. General Information
A. Provide the following:
facility name
- county
- facility address
report preparer's name
- report preparer's North Carolina P.E. certification
number
report preparer's mailing address and telephone number
B . Provide a detailed description of the proposed discharge facilities (you may include a diagram
indicating the plant components and processes)
C. Describe the project served by the WWTP (i.e. school, subdivision, number of students or
households, total waste contribution calculated according to 15 NCAC 2H . 0219 (1), etc.)
D. Indicate if it is a phased development and provide the estimated wasteflow per phase (indicate
current phase status for existing facilities)
II. Evaluation of Environmental Feasibility of Discharge Alternatives
A. Evaluate the environmental feasibility of all three of the following non -discharge alternatives.
1. Connection to Sewerage System (served by a municipalityor other entity holding a
valid NPDES or Non -Discharge Permit).
a. Existing Sewerage System: Indicate distance to an existing sewer line within a
five mile radius (radius extension should be considered if cost effective as it
relates to project size) If there are not available sewer lines in the vicinity, please
note this and proceed to entry 1(b) below.
(1) Provide description of sewer facilities necessary to connect to
receiving wastewater treatment plant.
(2) Provide preliminary indication of flow acceptance from municipal or
private WWTP under consideration for connection (documentation
should include NPDES permit number and county of the accepting
WWTP). If a municipal or private WWTP cannot accept the wastewater,
please explain.
(3) Indicate if third party agreements or easements would be necessary.
(4) Attach a topographic map or, if appropriate, a site drawing showing the
physical aspects of this alternative (i.e. proximity to sewer system, route
for sewer line, property difficulties, etc.)
(5) Proceed to Alternative II. A (2) - Subsurface Disposal Systems.
b. Planned Sewerage System: Determine if an area wide sewerage system within a
five mile radius is projected to be available within the next five years to receive
waste from the project under study. Determine availability date and flow
acceptance projection with appropriate regulatory authority. Identify your contact

Page 2
in the public utility or private management group that assisted you in this
determination. Should a sewer line be available for connection within the next
five years entry (1)(a) should be evaluated.
2. Subsurface Disposal System ( Installation of nitrification systems, low pressure pipe
systems and mound systems)
Note: Subsurface disposal systems (i.e., low pressure systems and nitrification systems) are
only permitted by DEM for the following types of facilities: city owned facilities, county
owned facilities, public utility facilities and industrial facilities with an industrial
wastewater component. Other categories of facilities (i.e., privately owned mobile home
parks, homeowner associations, nursing homes, industrial facilities with 100% domestic
waste, etc.) are permitted by local county health departments. Any facility in the latter
category must obtain a statement from the local County Health Department concerning
suitability/unsuitability of soils for subsurface systems.
a. Determine if permittee currently owns land that is available and suitable for a
ground absorption system.
(1) Provide a preliminary report from a soil scientist with a
loading rate recommendation based on soil type.
(2) Provide calculations to determine land size requirements based
on design and loading rate characteristics.
Note: Disposal systems require 100% reserve area.
(3) Indicate if all buffer zone requirements are met according to 15 NCAC 2H
.0219 (j). Provide a site plan indicating proposed layout of subsurface
system.
(4) If there is sufficient usable land, considering the existing
project development plan, what modifications to the plan (such as
reducing the number of units produced, the reduction of design flow,
etc...) would be necessary to allow for adequate usable land on the
site.
(5) If there is insufficient usable land on the project site, proceed to
entry 2 (b) below, if applicable. Otherwise, proceed to Alternative II A
(3) - Spray Irrigation Systems.
b. Determine if adjacent land could be acquired through purchase or
permanent easement. Provide documentation of availability. If adjacent
land could be acquired, evaluate according to entry 2 (a).
3. • Spray Irrigation System
a. Determine if permittee currently owns land that is available and suitable
for a spray irrigation system.
(1) Provide a preliminary report from a soil scientist with a loading rate
recommendation based on soil type.

Page 3
(2) Provide calculations to determine land size requirements based on design
and loading rate characteristics.
(3) Indicate if all buffer zone requirements are met according to 15 NCAC
2H .0219 (j). Provide a site plan indicating proposed layout of
spray irrigation system.
(4) If there is sufficient usable land, considering the existing
project development plan, what modifications to the plan (such as
reducing the number of units produced, the reduction of design flow,
etc...) would be necessary to allow for adequate usable land on the
site.
(5) If there is insufficient usable land on the project site. Refer to entry
3 (b) if applicable. Otherwise, proceed to Section II. B.
b. Determine if adjacent land could be acquired through purchase or
permanent easement. Provide documentation of availability. If adjacent
land could be acquired, evaluate according to entry 3(a) immediately above.
B. If one or more of the three non -discharge alternatives, II. A (1), (2) or (3) were found
to be environmentally feasible, select one and notify DEM that the alternative will be
undertaken in lieu of submitting the NPDES application. If a non -discharge
application is selected, the rest of this guidance is not required to be completed.
If one or more of the three non -discharge alternatives were found to be
environmentally feasible, but the permit applicant does not wish to select one because
he claims doing so would be unreasonably costly, cost estimates prepared according
to Section III of this Guidance must be submitted to DEM. Proceed to Section II.C.
If none of the three alternatives, II.A.(1),(2), or (3) were found to be
environmentally feasible, proceed to Section II.C.
C. Evaluate the environmental feasibility of the discharge to a flowing stream (defined as
a stream with 7Q10/30Q2>0 cfs flows).
NOTE: This section is not required to be completed unless the three
non -discharge alternatives evaluated in Section II.A. were found to be
environmentally infeasible, or if one or more of the alternatives were found to be
environmentally feasible but the permit applicant claims that selecting any of the
environmentally feasible alternatives would be unreasonably costly.
1. Indicate distance to nearest stream with positive flow meeting the above criteria
(attach topographic map indicating current existing/proposed discharge point and new
proposed location).
2. Provide documentation as to whether or not third parties agree to provide necessary
easements if applicable. Proceed to Section M.

Page 4
III. COST ESTIMATION AND COMPARISON
NOTE: Section III must be completed only if one or more of Alternatives (1), (2), and (3)
evaluated in Section II.A. or if the proposed discharge evaluated in Section II.C. were found to
be environmentally feasible and the permit applicant claims that selecting the least costly of the
feasible alternatives would be unreasonably costly.
A. Prepare cost estimates in accordance with the following guidelines for each of Alternatives 1,
2 and 3 that were found to be environmentally feasible in Section II. Be sure to convert all
costs to present value as described in Section III.E.
1. Connection to a Sewerage System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit.).
a. Provide detailed cost estimate of an installed sewer line interceptor and pump
station(s) if applicable (i.e. materials and labor)..
b. Determine the operating expenses of the sewer extension (i.e. materials, utilities,
maintenance and operator costs) for the design period.
c. Indicate cost of easements if applicable (include documentation of offer to provide
easement with dollar amount from appropriate party).
d. Indicate connection fees and/or surcharge required by the WWTP under
consideration.
Note: - If a periodic surcharge is required, please consider cost in analysis.
2. Subsurface Disposal System.(Installation of nitrification systems, low pressure pipe
systems and mound systems).
a. Provide a detailed cost estimate for the installed cost (i.e. materials and
labor) of treatment facilities.
b. Determine the opportunity cost of any land under current ownership to be utilized
under this alternative.
c. Provide the cost of any land to be purchased and/or cost of the permanent
easement (include letter of offer to sell or provide permanent easement with dollar
amount from appropriate party) to be utilized under this alternative.
d. Determine the operating expenses of the subsurface disposal system (i.e.
materials, utilities, maintenance and operator costs) for the design period.
3. Spray Irrigation System
a. Provide a detailed cost estimate for the installed cost (i.e. materials and labor) of
treatment facilities.
b. Determine the opportunity cost of the land or portion thereof under current
ownership utilized under this alternative.
c. Provide the cost of any land to be purchased and/or cost of the permanent

Page 5
easement (include letter of offer to sale or to provide permanent easement with
dollar amount from appropriate party).
d. Determine the operating expenses of the spray irrigation system (i.e. materials,
utilities, maintenance and operator costs) for the design period.
B . If discharge to a flowing stream was found to be environmentally feasible in Section II.C.,
prepare a cost estimate in accordance with the following guidelines. Be sure to convert all
costs to present value as described in Section III.E.
1. Provide detailed cost estimate of installed effluent line and pump station(s) if applicable
(i.e. materials and labor) to proposed discharge point.
2. Indicate cost of easements if applicable (include documentation of offer to provide
easement with dollar amount from appropriate party).
3. Determine the operating expenses of the WWTP (i.e. materials, utilities, maintenance
and operator costs) for design period.
D. Cost Comparison
Title 15 NCAC 2H.0105(c)(2) requires that the most environmentally sound wastewater
disposal alternatives be selected from the reasonably cost effective options. The three
non -discharge alternatives evaluated in Section II.A. are assumed to be roughly equivalent
alternatives where they are found to be environmentally feasible, and preferable to a
proposed discharge. Therefore, if a permit applicant has determined the environmental
feasibility of one or more of the non -discharge alternatives, but he claims the alternative(s),
compared to a proposed discharge, would be unreasonably costly, he must present
justification of the claim based on the appropriate cost comparisons as to why the difference
between the costs would be unreasonable.
E. Present Value of Costs
Costs incurred in different time periods must be converted to a common time period before
they can be accurately combined or compared. Performing this calculation is known as
"computing the present value," or "discounting" the costs. Present value is also sometimes
called "present discounted value" or "present worth".
The following standard formula for computing the present value must be used in all cost
estimates made under this evaluation guidance.
PV. Co + Ct
t (1+r)t
Where:
PV = Present value of costs.
Co = Costs incurred in the present year.
Ct = Costs incurred in time t.
t = Time period after the present year ( The present year is t = 0)

Page 6
n = Ending year of the life of the facility.
r = Discount rate. for these calculations, use the rate that is required to be used by all
Federal agencies in the formulation and evaluation of water and related land
resources plans. The rate is computed annually in accordance with Sec. 80 (a)
Public Law 93-251 [88 Stat. 34J and 18 CFR 70439, and published in the
Federal Register. The current rate (for Federal Fiscal year 1989-90) is 8 7/8%.
Therefore in the above formula for this year, r = .08875.
However, if the costs are the same in every time period from year one through year n (i.e.,
Ct = C, a constant for t = 1,2,..., n ), then the formula reduces to:
PV=
+ C
1- 1
(1+r)
1 1
((1+r))
n
J
In this case, the present value may also be looked up in a table containing -the present value of
annuities (an annuity is a constant amount payable in each year for a certain number of years).
Such tables are available from financial institutions.

State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUAL:TY SECTION
MEMORANDUM
TO:
THROUGH:
THROUGH:
March 28, 1991.
Susan A. Wilson
Technical Support Branc.:h
Roy M. Davis, Regional
Division of Environment ' . ia•' ,+,. n
Forrest R. Westa
Regional Water. Qu-,,,1'. upervisor
FROM: Max L. Haner
Environmental Chemist /
SUBJECT:
Ann B. Orr
Regional Manager
APR 0 2 1991
TECHNICAL SUPFW T BRANCH
Request for Additional Wastel.oad Allocation
Amendment to WLA #5928
Royal Oaks, Inc./Golf and Housing
NPDES Permit Number NC0040355
Haywood County, North Car.c: i.i.na
In regards to our earlier conversations on this subject, the presence
of existing discharges to the Pigeon River Drainage Basin (including
East Fork Pigeon River) appears to quali.f,, major streams in this basin
for a WSIII designation by 3MC under- Water Supply Rules adopted as
effective January, 1991, and pursuant to the Watershed Protection Act.
While we may support the Town of Canton's request for the highest
possible level of protection for thzs drainage basin (WSII), actual
designation by EMC of a water quality classification other than WSIII
appears to be dependent upon the management scheme that Haywood County
as the controlling body is willing to adopt. Since preparation of the
recently completed wasteioad (#5928-attnched), there are indications
from the County that it may support a. levc7l of management equal to that
required by WSIII designation instead of WSII. If that is the case,
public notice for Royal Oaks' NPDES permit (expansion from .025 MGD to
.100 MGD) should not assume that the WS T designation will be
forthcoming for the East Fork Pigeon River. Given that a public
meeting on issuance of this NPDES permit, a certainty, DEM must have
Interchange Building, 59 Woodfin Place, Asheville, N.C. 28801 • Telephone [phone]
An Equal Oppommiry Affirmative Action Employer

Page 2
March .28, 1991
flexibility in its final decision. For these reasons, I am requesting
that you amend the existing wasteload for Royal Oaks permit to also
show the treatment level required by a WSIII-Trout classification for
this receiving stream. Thanks very much. Please call me if you want to
discuss this matter in more detail.
enclosure
xc: Mack Wiggins
Carla Sanderson
Steve Zoufaly