HomeMy WebLinkAboutNC0064246_SOC (Application)_20221228 (2)STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION: Saaw4
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 OU 2 0 2022
3. Facility Name (as shown on Permit): Pace Mobile Home Park WDEUDWRINPDES
4. Owner Phone: (419) 357-9091 (or)
5. Owner Email: Kbuss@rentstackhouse.com, copy to Mbrown a,rentstackhouse com
4. Application Date: December Q, 2022
5. NPDES Permit No. (if applicable): NCO064246 Laserfiehe
6. Name of the specific wastewater treatment facility (if dii fereni from 13. above):
Pace Wastewater Treatment Plant
II. 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
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:
The total non -domestic additional flow requested:
The total additional flow (sum of the above):
._N/A gallons per day.
_N/A gallons per day.
_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
facility into compliance. Possible funding 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 securing funding.
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE 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
elected official or other duly authorized employee.
If the SOC is for a Corporation / Company / Industry
the SOC must be a principal executive officer of
president, or his duly authorized representative.
the SOC must be a ranking
/ Other, the person signing
at least the level of vice -
If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2I-I .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 ofthis 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)L1
Signature of Signing Official
Printed Name of Signing Official
ql IJ.2c ZD'LZ
TIIE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT
TO TIIE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
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
RALEIGI-I, NORTH CAROLINA 27699-1636
0
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 LLC 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.
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.
ENGINEERING REPORT
For
PACE WWT P
Johnston County
4 October 2022
-A CAP
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JOHN W. HARRIS, P.E. 5112 Bur Oak Circle
CONSULTING ENGINEER, Inc. Raleigh, N.C. 27612
www.harriseng.net C-3017 (919) 789-0744
2 1 -October-2022 9:20 AM Page 1 of 17
TABLE OF CONTENTS
Table of Contents
PROJECT NARRATIVE 3
VICINITY MAP d
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 1 J-17
2 1 -October-2022 9:20 AM 11 Page 2 of 17
PROJECT NARRATIVE:
The Pace W WTP 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.
2 1 -October-2022 9:20 AM 11 Page 3 of 17
VICINITY MAP
AERIAL OF WWTP AREA
VICINITY MAP
(NOT TO SCALE)
21-October-2022 9:20 AM 11 Page 4 of 17
SITE SURVEY OF THE PLANT
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2 1 -October-2022 9:20 AM 1I Page 5 of 17
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
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.
21-October-2022 9:20 AM 11 Page 6 of 17
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 W WTP.
Raw settled
Sewage
Sewage Aeration
P.s.T Tank
t tieated&lxlge
FSdttIe
Effluent
d
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.
The Pace W WTP 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.
2 1 -October-2022 9:20 AM 11 Page 7 of 17
RECOMMENDATION OF EFFICIENCIES
The NCDEQ required effluent limits for this system are as shown below.
Oxuilpn PaMbm In:AttAICM fee6.ClEdLOB CM9ee]iiUC
Pe-t NCIMJ246
Pail I.
A.(1.) EFFLUF.NT LIMITATIONS AND MONITORING REQUIREMENTS
115A NCAC 02B.0100 a nn, , O2Ba500 ct x4.1
Deno, the paned beginning on the e6eaive date of this permit and lasting nndl cz nothirm. the Pemsioeo is
authorized to didnga fbm out(WI MI. Sock dixbs es shall be limited and monitored' 65 the Permince so,
mou8od below:
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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 BOD5 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 W WIP
Reduired❑miss 9130120229198190Y9 SMLZ 2 916= 81 69 12079 8118/9099 811012029 8161?n9➢
h muter
Monthly A
Dai�Mas
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Flow
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9
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Ammonia Nivogert-it
4
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Fecal odfvm
200
400
510100
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4.11100
77.11100
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60.31100
7.51100
27.51100
Taal Resi&AChbMe
17
Oiaolved Oxygen >1. 5.0
Total Phosphorus
0.57
pH 6.0-9.0
2 1 -October-2022 9:20 AM 11 Page 8 of 17
OPERATION IMPROVEMENTS NEEDED
There are many improvements that have begun and many others that are in progress at this time. The following outline
will provide a synopsis of what has been completed and what we are planning to do,
February 2021 Train #2 was drained. it was removed and welded back together around the deteriorating areas. The
welding work was $8,231.94.
May 2021 Identified additional areas of concern that needed to be upgraded. Purchased; (2) Blowers, (2) Motors, Control
Panel, Flowmeter, totaling $35,100.00.
May 2021 Purchased EPA compliant testing equipment for site. Hach DR1900, HQ4200. Totaling 8,076.24
June 2021 Hired Breedlove Electric to install the control panel and electrical components. Contract cost $49,780.00.
November 2021 DEQ Meeting, SOC Pre -Application Meeting.
January 2022 Hired John Harris, P.E. Consulting Engineer, INC. (Harris Engineering)
August 2022 DEQ Meeting
July-2022 Harris Engineering prepared a "Step -I" plan to allow for the diversion of flow (from Train-1 to Train-2) and to
provide for the proper placement of the new pumps and blowers. See plan below.
New Electrical
equipment + .:
21-October-2022 9:20 AM 11 Page 9 of 17
This will require that a new Bar Screen and Splitter Box be constructed and placed between the 2-Train units.
21-October-2022 9:20 AM 1I Page 10 of 17
EFFLUENT LIMIT EXPECTATIONS
The current system is not capable of consistently meeting the required discharge effluent limits. This is
unavoidable until the repairs (in progress) are completed. We do note that even in the plants severely
deteriorated condition. it is close to the required limits and some periodically are met but not consistently. These
current violations are unavoidable due to the severely deteriorated condition of the plant and will continue
during the SOC.
However, it is my professional opinion that when the W WTP is fully repaired and operating with both trains,
we see no reason for concern and expect that this system will be able to both meet and exceed the current
effluent limits.
21-October-2022 9:20 AM 11 Page 11 of 17
OTHER PROCESS IMPROVEMENTS
We see no reason for additional process improvements. We are in a repair condition with this system.
2 1 -October-2022 9:20 AM J� Page 12 of 17
WORK TASKS AND TIME FRAME W/ PROBABLE ACHIEVEMENT DATES
February 2021 Train #2 was drained. it was removed and welded back together around the deteriorating areas. The
welding work was $8,231.94.
May 2021 Identified additional areas of concern that needed to be upgraded. Purchased; (2) Blowers, (2) Motors, Control
Panel, Flowmeter, totaling $35,100.00.
May 2021 Purchased EPA compliant testing equipment for site. Hach DR1900, HQ4200. Totaling 8,076.24
June 2021 Hired Breedlove Electric to install the control panel and electrical components. Contract cost $49,780.00.
November 2021 DEQ Meeting, SOC Pre -Application Meeting.
January 2022 Hired John Harris, P.E. Consulting Engineer, INC. (Harris Engineering)
August 2022 DEQ Meeting
July-2022 Harris Engineering prepared a "Step-V plan to allow for the diversion of flow (from Train-] to Train-2) and to
provide for the proper placement of the new pumps and blowers. See plan below.
October/November 2022; Begin Phase-1 improvements construction
January 2023; Install new equipment and initiate switchover from Train-1 to Train-2
March 2023; Remove old equipment and Train-1 tanks to be refurbished and or replace as needed
May 2023; Re -install the Train-1 side and begin dual train operation.
We need to point out that we are aware of the slow pace of the process. The growing economic climate, while good, has
made it difficult to locate available skilled contractors to perform the required tasks. We are making every effort to
complete this work as quickly and as efficiently as possible.
21-October-2022 9:20 AM 11 Page 13 of 17
ATTACHMENTS
ATTACHMENT-1
WY COOPER
I,-
MICR.
MICHAEL S. REGAN
S. DANIEL SMITH
aoani uaounn
Mrnm
(n�beniwM1/Qudlll
February 23. 2021
Mr. Jonathan Gindes
Jones Psuta Pace, LLC
P.O. Box 14466
Durham, NC 277M
Subject: Tr foofosrnership/pmmitmMifmatinn
NPDES Permit NCU0M246
Pace Mobile Horne Park
Gmde n WPCS
Johnston County
Dear Mr. Gin ke:
The Division received and approved your mailers to change the ownership fo the subject permit in
rebmary 2020. However, due 10 the shutdown of our oillea during the COVID pnMemic. me Division neglected
o xnd The
Division
re-iheaving (n,64246. remelavnmuc surdstoshow ywuorth CarvimtntMnew
owneq. The 15.1 and
Memorandum
ofAgrementrstween Northuant to the
U-Craliromental
Statute 143-216,1 rem the Memorandum 7 or U subsebetween North Carolina and erns U.S. Environmental
Protection Agency dated Octobr I5. 2W] lure u subsequeMY amended).
If soy parr, meawnmrnt beyuancies or sampling requirements contained in this modification ere
unacceptable In you, you have the right to an adjudicator, hearing upon written request within rains, (70) days
following receipt nfthis lettm, This request nun he in the Irmo of. written pmition, umfmmi, m (Ympler
1 S0H ofth. North Carolina G..1 Statuses, and filed with the Office of Adminislmtive Hearings (6714 Mail
Senix Canter, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be fwi
Red binding.
This permit iamn uansRMle except ale" resuce to the Division. The Division mS)r require mothfmation
or revrcetion sell neissuame of the Permit. This pemtil dean am.lrect the lead requinmems to ok.i. other
permits which may he required by any other redered, Same, or Local governmental regulation. Ifyue have any
questions ommeming this matter, pleew camract Charles H. Waver via.mail �chvkv.wwver utnrArnr Ravi.
ce: WOES fi1e(Ixwrfiche)
^•,� ��"• am mrwev
SSmeerak,
L
t S. Daniel
Director
Smith
2 1 -October-2022 9:20 AM lI Page 14 of 17
tier~ fnabP ID: ADM)DB6f00B eCeE2[Ce{CMDBO6Rat
Permit NCn0W2a6
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE. W ASTEW A'rER UNDER ME
In compliaam with the provision of North Carolina General Saute I43-215. 1, other lawful sbnlanls and
regulations promulgated and s lopmd by the North Carolina Envimnmemal Management Commission, and the
Fdeml Water Pollution Coined Am, as amended.
Jones Estates Pace LLC
is bomb, authorieed to discharge wastewater from a facility located at the
Pace Mobile Home Park W WTP
15026 Buffalo Road
Clayton
Johnston County
to receiving waters designated . an uaoamed tributary (Bl) m Buffalo Crock in subbazin 03-04-06 ofthe N.
River Basin in accordance with effluent lineinfions, monitoring requirements, and other conditions set froth in
Pun I. 11. 111, aM rV hereof.
'Iles permit model canam is eff.u. Aped 1. 2020,
This worst and authorisation to discharge shall ce so, at midnight oa Apol.10, 2023.
Signed Otis dal. 3/20/2020 =84AI,
by:
,
/nr S. Daniel Smith, rN etor
Dimetim, Division of Water Resources
By Amh miry ofthe Emiranmattal Management Commission
Page 1 ors
21-October-2022 9:20 AM 11 Page 15 of 17
WCuxgn lentWov in a WAsM Ftlae•1WE4icN ccMaioil K
Nook NM9429.
SUPPLEMENTTO PERMIT COVER SIIEET
All pn wmx NPDP-YPcrmitNrsxed to thle ynclit(e. whether br aii naion ordlsuhnrge• am, hrmby r ,okvrl Aa of
this InrmiNsrxumx, xnppreviarnly issvrrllxrmit heuring thlr numfmr /s rat hmger e//acnve. 7herq/hm, nc,
eschnvr m✓horirvm nµ rxte and ✓ileharga•fmmthis. hicunsererina Mlrermlrcmxlisimrs. rcrp✓rcmenss
terms, am! pnmsions Imlmk✓herem.
Jones Estates Pace LLC is hereby authorized to:
Cantinsn+ in operate an calsmrg 0,015 MOB wnslewaler tmani sysrem thm includes the fbllmring
Wmpmrcirm.
• Cominuous flow mcmrsyncm
• Maned bar scrum
• Uqudirmlon tank
• Dxd neratioo ehnmbcn
• Dud darifcrs
• Aorated sludge bolding look
• Dail air blowxrs
• Dud tablet chlorinator
• Table(do<hlodnator
• Audible visual alamrs
• Electrical hook-up for ponable generator
• PortaNegencramr(kcpr off -site)
This Class W W-2 facility is IocnkM at Ile, P. Mnhdo Hanna Park W WTP (IM26 Buffalo Road) in
Johnson. Count.
2. Discharge from said treatment works via Outfdl 001 at Ilia location specified on the attached trap into an
unwmed Inbutary to Buffalo Crock (Saeam Indes 27-57-16{]D, a waterbody cuirena5 classified C-NSW
waters in suW i. 03- 1-06 (IIUC 0302020115) of it. Nouse River Basin.
Page 2 of s
21-October-2022 9:20 AM 11 Page 16 of 17
ATTACHMENT-2: PHOTOS:
Bar Screen
Farm Duty Motor
Im (P
I j wre
nnjj�1.L1�.;F x.
��� '. r.Y 1iJ1 �WG W.I.
MJI urn Sut.uMYr
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Nr.e N�Mra ur rrru
.
'r�.ri46aYnnry' ...
tigw;d-nirrr.t..
•... ...
Train-2 New Electrical Controls Train -I
Primary Clarifier
Equipment Shed
21-October-2022 9:20 AM 11 Page 17 of 17