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HomeMy WebLinkAboutDELETE STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT ANI) NATURAL RESOURCES DIVISION OF WATER RESOURCES APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC) L PERMIT RELATED INFORMATION: Sa. 1. Applicant (corporation, individual, or other): Jones Estates Pace LLC 2. Print or Type Owner's or Signing Official's Name and Title: RECEIVED Kellen Buss, Director of Site Infrastructure DEC 2 0 2022 3. Facility Name (as shown on Permit): Pace Mobile Home Park NCDEQIDWRJNPDES 4. Owner Phone: (419) 357-9091 (or) 5. Owner Email: Kbuss@rentstackhouse.com, copy to Mbrown cr,rentstackhouse.com 4. Application Date: December ?, 2022 5. NPDES Permit No. (if applicable): NC0064246 6. Name of the specific wastewater treatment facility (if different from 13. above): Pace Wastewater Treatment Plant IL PRE-APPLICATION MEETING: Prior to submitting this completed application form, applicants must meet with the appropriate regional office staff to discuss whether or not an SOC is appropriate for this situation. Please note the date this meeting occurred and who represented the permittee: Representative: Kellen Buss, Jason Freed Date: August 19, 2022. III. ADDITIONAL FLOW OR FLOW REALLOCATION: In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may request additional flow. Additional flow may be allowed under an SOC only in specific circumstances. These p circumstances may include eliminating discharges that are not compliant with an NPDES or Non-discharge permit. These circumstances do not include failure to perform proper maintenance of treatment systems, collection systems or disposal systems. When requesting additional flow, the facility must include its justification and supporting documentation. If the requested additional flow is non-domestic, the facility must be able to demonstrate the ability to effectively treat the waste and dispose of residuals. The applicant must provide a detailed analysis of the constituents in the proposed non-domestic wastewater. The total domestic additional flow requested: N/A gallons per day. The total non-domestic additional flow requested: N/A gallons per day. The total additional flow(sum of the above): N/A gallons per day. Please attach a detailed description or project listing of the proposed allocation for additional flow, with an explanation of how flow quantities were estimated. Further, any additional flow requested must be justified by a complete analysis, by the permittee, that additional flow will not adversely impact wastewater collection/treatment facilities or surface waters. IV. NECESSITY NARRATIVE: Please attach a narrative providing a detailed explanation of the circumstances regarding the necessity of the proposed SOC. Include the following issues: • Existing and/or unavoidable future violations(s) of permit conditions or limits(s), • The existing treatment process and any process modifications that have been made to date to ensure optimum performance of existing facilities, • Collection system rehabilitation work completed or scheduled (including dates), • Coordination with industrial users regarding their discharges or pretreatment facilities. Identify any non-compliant significant industrial users and measure(s) proposed or already taken to bring the pretreatment facilities back into compliance. If any industrial facilities are currently under consent agreements, please attach these agreements, • Date and outcome of last Industrial Waste Survey, • Whether or not the facility is acting as a regional facility receiving wastewater from other municipalities having independent pretreatment programs. V. CERTIFICATION: The applicant must submit a report prepared by an independent professional with expertise in wastewater treatment. This report must address the following: • An evaluation of existing treatment units, operational procedures and recommendations as to how the efficiencies of these facilities can be maximized. The person in charge of such evaluation must sign this document. • A certification that these facilities could not be operated in a manner that would achieve compliance with final permit limits. The person making such determination must sign this certification. • The effluent limits that the facility could be expected to meet if operated at their maximum efficiency during the term of the requested SOC (be sure to consider interim construction phases). • Any other actions taken to correct problems prior to requesting the SOC. 2 VI. PREDICTED COMPLIANCE SCHEDULE: The applicant must submit a detailed listing of activities along with time frames that are necessary to bring the facility into compliance. This schedule should include milestone dates for beginning construction, ending construction, and achieving final compliance at a minimum. In determining the milestone dates, the following should be considered: • Time for submitting plans, specifications and appropriate engineering reports to DWR for review and approval. • Occurrence of major construction activities that are likely to affect facility performance (units out of service, diversion of flows, etc.) to include a plan of action to minimize impacts to surface waters. • Infiltration/Inflow work, if necessary. • Industrial users achieving compliance with their pretreatment permits if applicable. • Toxicity Reduction Evaluations (TRE), if necessary. VII. FUNDING SOURCES IDENTIFICATION: The applicant must list the sources of funds utilized to complete the work needed to bring the facilityinto compliance. Possible funding p sources include but are not limited to loan commitments, bonds, letters of credit, block grants and cash reserves. The applicant must show that the funds are available, or can be secured in time to meet the schedule outlined as part of this application. If funding is not available at the beginning of the SOC process, the permittee must submit a copy of all funding applications to ensure that all efforts are being made to secure such funds. Note: A copy of the application should be sufficient to demonstrate timeliness unless regional office has reason to request all information associated with secur ing ring funding. THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION PACKAGE UNLESS ALL OF TIIE APPLICABLE ITEMS ARE INCLUDED WITH THE SUBMITTAL. Required Items: a. One original and two copies of the completed and appropriately executed application form, along with all required attachments. • If the SOC is for a City / Town, the person signing the SOC must be a ranking elected official or other duly authorized employee. • If the SOC is for a Corporation / Company / Industry / Other, the person signing the SOC must be a principal executive officer of at least the level of vice- president, or his duly authorized representative. • If the SOC is for a School District, the person signing the SOC must be the Superintendent of Schools or other duly authorized employee. 3 Note: Reference to signatory requirements in SOCs may be found in the North Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)]. b. The non-refundable Special Order by Consent (SOC) processing fee of$400.00. A check must be made payable to The Department of Environment and Natural Resources. c. An evaluation report prepared by an independent consultant with expertise in wastewater. (in triplicate) APPLICANT'S CERTIFICATION: (NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE) I, Kellen Buss, Director of Site Infrastructure, attest this application for a Special Order by Consent (SOC) has been reviewed by me and is accurate and complete to the best of my knowledge. I understand if all required parts of this application are not completed and if all required supporting information and attachments are not included, this application package may be returned as incomplete. (Please be advised that the return of this application does not prevent DWR from collecting all outstanding penalties upon request). Furthermore, I attest by my signature that I fully understand that an upfront penalty, which may satisfy as a full settlement of outstanding violations, may be imposed. {Note: Reference to upfront penalties in Special Orders by Consent may be found in the North Carolina Administrative Code [T15A NCAC 2H .1206(c)(3)] y Date `1 Dec ec 2_6 ZZ Signature of Signing Official ge. ttri ?- 70 cJ SS Printed Name of Signing Official THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS: NORTH CAROLINA DIVISION OF WATER RESOURCES POINT SOURCE BRANCII 1617 MAIL SERVICE CENTER RALEIGH, NORTH CAROLINA 27699-1617 IF THIS APPLICATION IS FOR A NON-DISCHARGE SYSTEM, THEN SEND TO: NORTH CAROLINA DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION 1636 MAIL SERVICE CENTER RALEIGH, NORTH CAROLINA 27699-1636 4 Response to Para. IV of the Pace Mobile Home Park SOC Application: Necessity Narrative. The current system serving Pace Mobile Home Park, while under repair, is in a severely deteriorated condition due to neglect under prior ownership. The Jones Estates Pace LL C LC has made significant improvements and investment in the system, as shown in the attached Hydrologic Report dated October 4, 2022 from John W. Harris, P.E. (the "Engineer Report"). Despite these improvements, the system continues to violate requirements for BOD5, and nitrogen/ammonia, as indicated on page 8 of the Engineer Report. Continued investment and improvements are scheduled as shown on Page 13 of the Engineer Report. Violation of BOD5, nitrogen/ammonia and possibly oxygen are likely to continue until such time as all scheduled improvements are completed, around May of 2023. Collection system improvements are not required and not planned. The system does not treat waste from industrial users. Response to Para V of the Pace Mobile Home Park SOC Application: Certification. Please see Engineer Report. Response to Para VI of the Pace Mobile Home Park SOC Application: Predicted Compliance Schedule. Please see Engineer Report. Response to Para VII of the Pace Mobile Home Park SOC Application: Funding Sources Identification. Detailed below are the remaining financial obligations connected with the completion of the sanitary system upgrade work at Pace Mobile Home Park. • Engineering Fees: $8,600 • Construction Labor: $44,500 • Materials (PVC, Electrical Wire, etc): $15,000 • Total: $68,100 Since acquiring Pace Mobile Home Park, Jones Estates Pace LLC has invested over $150,000 in improvements to the sanitary system to correct prior ownership negligence and significant deferred capital expenditure. In total, Jones Estates Pace LLC will have invested over $200,000 to bring the community's sanitary system into compliance once complete. 5 The remaining funds needed ($68,100) to complete the sanitary system upgrade work have been set aside and have been sourced from ongoing lot rent collection activities over the past year. They will not need to be sourced via financing, grant, loan or bond activities. The cash reserves are available now and ready to be deployed. 6 ENGI NEERING REPORT Ior PACE WWTP Johnston County 4 October 2022 0tttt!!!lpi4 rcc 5r 10742 . .••.: o rO C-ji) JOHN W. HARRIS, P.E. 5112 Bur Oak Circle CONSULTING ENGINEER, Inc. Raleigh,N.C. 27612 www.harriseng.net C-3017 (919)789-0744 21-October-2022 9:20 AM Page 1 of 17 TABLE OF CONTENTS Table of Contents PROJECT NARRATIVE 3 VICINITY MAP 4 EVALUATION OF EXISTING TREATMENT SYSTEM 6 OPERATIONAL PROCEEDURE 7 RECOMMENDATION OF EFFICIENCIES 8 OPERATION IMPROVEMENTS NEEDED 9 EFFLUENT LIMIT EXPECTATIONS 11 OTHER PROCESS IMPROVEMENTS 12 WORK TASKS AND TIME FRAME, W/PROBABLE ACHIEVEMENT DATES 13 ATTACTMENTS/PICTURES 14-17 21-October-2022 9:20 AM II Page 2 of 17 PROJECT NARRATIVE: The Pace WWTP is a small 15,000-gpd(0.015mgd) Wastewater treatment facility serving a mobile home park located at 15026 Buffalo Road, Clayton,NC. The treatment facility, as part of the MHP was recently purchased by the current owner and a revised Permit to the new owners was issued on February 23, 2021, See Attachement-1. This treatment facility is an older system, and it appears it has not been effectively maintained by the previous owners. The new owners have not owned this facility more than a couple of years and have been actively working to repair and improve the facilities and equipment. 21-October-2022 9:20 AM 11 Page 3 of 17 VICINITY MAP d II II iI l SITE--..... Ir. VICINITY MAP (NOT TO SCALE) AERIAL OF WWTP AREA EL+. ' Coen.t. •••DISCWMER••• IN�•i��n I�t ,, 01�cn Coup r�rurMy�liw�werl/M+w YMs�/o���pw�rN�. * ,- 4, i� d s ke ' -",-,,' A r'' \ --- -1 ', / , , -•-•,...„ 1 -Soso i''1•,:r,`-'t f'' r-'11 ' ' I[ ,7 , „, ,,,,,, r.aecL uma s►a0 ., •y` \ S t r 4'..44,,c, \ ' 1 .., .- ,,,,, .,- I , r"' r#' '1- ' 1 , -.-{14 7 ''A ii/A' V '''� --T, �, , .► .. a ;`J r r r ` 'm' , , , I �t �r� '9.` _ _.. v ,1 ,� 1 ,ems • ',. 1 ar, 1 '''. ' ' 'J, 4-',,,' ''.;`,1t ii..)",,rlitrjfil,', :ni, ' --1,„' ‘:i'dli'l'PN . . , ,k,,-:. E Ir y iili 5 ' — r .A . •. , 21-October-2022 9:20 AM ii Page 4 of 17 r CA y HI - 1 SITE--___y, - •`�� i O VICINITY MAP '_'Y. -s•� ..1..a '.....- ......:.nrHe..w .w Pva vP..wiue. .,., i •--t"` m /« YP•.RMttl••MOP* wm Jo*.. sw.*4*/AA/TH,a .e.nu n n..emose ' 1 ,wets nc,n +un.n:. ' / _ .' ' �•A ;. {/ ,[ ,, .I_L,._roas 3312022 I'' i/ ... .,- *as ','i t'./r ' ''//,� /, tY+q ,y�yi cow.um./ter surawecT.mom / fra A nRSSW*s�IC ucann.SG w.� f L k �..,„ \-,\•' OS ' rw,au.P..... � <ISOs n��: /. s 1 ..:+er rsa ST,OC/AS GAM nse..eP a.az vnar on+nln rory.'.� �"x'+w . R,P,,.SS -� ,`k,1, j ,ST,r,... mc..a E .. ,crwwa.r..o —.—....--- ‘,\,-.-- i -o- :. i $ / • r ., 1 • E . CD 1 . / o I /TO AN3XIP.- HER DATE REYI8WwE8) • J4H HT R WI �,, sAftQ AO�w SURVEYING �T,TE ROR M OCLINA TOPOGRAPHIC AND IhP, AS-BUILT SURVEY FOR ' �'/SEAT - ,' SOLUTI O\S IeI:R.E. 15056 BUFFALO ROAD .31(2 b DATE.I+ARewuan.TEa V,a.a,�sc�,•� precision Pcv:'9rec ly integrity a� PROJECT=EDSt i H k,, !1C@6g G14bI4 GOA AN? 01Q�1myAi O `CriG.IIW55,S5.EEITYVIb1.8 a' 1a 4C 44. JOHNSTON COUNTY F" 377PASTMOIZT ra»GSNILIERCrsx til I SHEET 1OFi ndn 919E5119021sax9wRtYvcc01eISURZVVGCH O ►r J EVALUATION OF EXISTING TREAMENT SYSTEM Representatives from Harris Engineers have inspected the site on numerous occasions in January, March, and July of 2022. We note that the system is a dual train activated sludge "package plant"process. These types of systems were common in the 1980's and early 1990's. Our experience with these"package" systems has indicated they can be very efficient for normal domestic sewage. The existing treatment facility is shown in the photos below. Train-A: in Operation Train-B: not in O eration : ; 1 •T'Sr- _ '''''?' ...-•.-f.--- -.3i=g-i-d "-----i-itmaims,.. la tifi PS '-- --`-' 1110f0,.. ,WNW „-- ,,- • yk---_. APir Ile ----, „_,....-------) --.' - ."' .a `. " �4))1hf' +'.► ems, T . 1 1-' a° ..•� ' -'a While the system is currently only operational on 1-train, The owners have taken steps and have refurbished the Train-2 tanks, installed new electrical panels, and purchased new equipment(blowers, pumps, etc.) This equipment is currently"on-site"and awaiting installation. Refurbished tanks; Train-2 New Electrical Control Panels '1 3 --.ice ; 1,It i5', •,I .{ w.` a__ t �, w y t � it;';,'-'':•V.,1,,,i�y . .4411 \ ,,,II ippiiii fry �yi{'i� l'' `- ' ' / _ 1, ! ll It'.J .;•Y.,F, ,;.` r.nt`x W dt'a' 0.`. -Y. .ice.'^., ^$•, $ h, ,mod J..;(¢. '} i[S .' {p' 7, . "'fit` ?u7.;7,•Ki r ' ,44:'7 ..' .te 21-October-2022 9:20 AM 11 Page 6 of 17 I OPERATIONAL PROCEEDURE The standard activated sludge process as diagramed below is primarily the same configuration as is existing in each of the 2-trains of the Pace WWTP. Settled Raw Sewage Sewage Aeration --i— F'''T ► Tank ► S.S.T Effluent Settle Slucte 4 Sludge Removed Activated Sludge You can see in the picture below, starting from the far left is the primary clarifier,the aeration chamber(2- middle sections) and the final clarifier. We have a facility that is sized appropriately and capable of efficient operation and treatment when all components are installed. 1111 1 , 3 .. ti - The Pace WWTP has a certified operator, Matthew Bailey,who is very experienced with this process and has been able to work effectively with the poor conditions of the plant. 21-October-2022 9:20 AM Page 7 of 17 RECOMMENDATION OF EFFICIENCIES The NCDEQ required effluent limits for this system are as shown below. DowSlip Envelope 10.AO8A30ee F0884COE 8C08-CCOA0a00FC4C Permit NC0064246 Part I. A.(I.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 0213.0400 et sock 021 0500 ct scq.1 During the period beginning on the effective date of this permit and lasting until expiration,the Permitter is authorized to discharge from outfall 001.Such discharges shall be limited and monitored'Is<the Permitter as specified below• EFFLUENT OMITS MONITORING REQUIREMENTS PARAMETER Monthly Daffy Unit of Measurement Sample Sample [.DMR Coda] Average Maximum Measure Frequency Type Loeaaart 1 0015 MOD Continuous Recorder I fluanl r Effluent Olaf Monthly Flow Month Reaxdor a Influent a k4Ghnonth1322201 Calculated Effluent a s,5-Day(20 Deg.C) 9 13.5 mgI. Weekly Grab Effluent C03101 dal Suspended Solids 30 45 C05301 mg'L Weedy Grab Effluent .is Nitrogen(as N) C06101 2 10 rrg4 Weekly Grab Effluent April t-October 31) .nia Nitrogen(as N) C06101 4 20 mot Weakly Grab Effluent November 1-Mardi 31) Fecal Coklam(geometric mean) 200 400 XI100m1 Weekly Grab Effluent 31616] Ord Residual Chlorine(TRC)t r r,r 17 frge tlay 2 X week Grab Ffnt empaaexe degrees C Weekly Grab EMuen1 (00010( s',:. :.Oxygen Defy average:5.0 00 1 VI. mg/1 Weekly Grab Effluent oral Phospfwnrt(as PI 1 mg4 Marbly Grab ENuent a0000N j t(asmg4 Monthly Grab Effluent Total Nitrogen LoaOt (01.06001 poundslmadh Monthly Calculated Effluent )0Y6001 pounds/year Arxetaly Calculated Effluent otal Kjeldahl Nitrogen(as N) 00625) roge MonthlyGrab Eritrea at.4.103(as mg4 Nattily Grab Effluent 006301 •H 6.0 and<9.0 standard ails Weekly Grab Effluent 004001 empealure degrees C Weekly Grab U 6 0 1060101 Orssdved Oxygen 1 mg4 WeeklyGrab U&D 00300 Page 3 of a We have tabulated test results from the 5 previous weeks to allow us to see how this system, in its current state, is doing. We can see from the table that the BODS is only slightly out of line and does from time to time have below required. The Total Suspended Solids (TSS)are well within the requirements, as are the fecal coliform. The only reported constituent that is above the required limits is ammonia nitrogen. We feel that this is correctable in the near future and well within the treatment abilities when the facility is repaired. PACE WWTP Required Limits 913017077 9176(2077 91817077 91617077 812617027 811817077 811017077 81817077 Parameter Month Iv Average Daily Max Units Flow 0.015 Effluent-BOD-5 9 13.5 10.5 5.5 8.1 9.4 40.1 9.1 23.9 9.0 Clarifier-BOD-S 6.8 TSS 20 45 9.3 5.6 5.1 9.3 15.2 16.3 10.1 8.0 Ammonia Nitrogen-5 2 10 3.9 0.4 7.2 13.5 13.0 9.2 4.6 13.7 Ammonia Nitrogen-4 4 20 Fecalceliform 200 400 51.21100 2420f100 4.11100 77.11100 21100 66.3)100 7.5(100 27.51100 Total Residual Chlorine 17 - Disolved Oxygen >1=5.0 Total Phosphorus 0.57 pH 6.0-9.0 21-October-2022 9:20 AM Page 8 of 17