NC0060755_Permit Issuance_20030403

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Mr. Jim Highley
Carolina Water Service, Inc. of North Carolina
P.O. Box 240908
Charlotte, North Carolina 28224
Dear Mr. Highley:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
April 3, 2003
Subject: Issuance of NPDES Permit NCO060755
Saddlewood Subdivision WWTP
Gaston County
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as
subsequently amended).
We apologize for the delay in issuance of this final permit. The Division received no affidavit or
verbal confirmation of publication for the December 2002 Public Notice until yesterday. Final permits
cannot be issued without proof that the Public Notice was published.
This NPDES Unit received a comment letter from Mr. Martin Lashua of your company on January
21, 2003. The Division offers the following responses to Mr. Lashua's comments:
➢ The daily maximum ammonia limits are new in this permit, and were not present in the previous
permit. Previous permits for .this facility had only monthly average limits for ammonia nitrogen.
➢ The permittee name has been changed as requested.
➢ Instream monitoring for dissolved oxygen (DO) and temperature remains in the final permit; both
these parameters are necessary to evaluate DO saturation instream. Instream monitoring for fecal
coliform and conductivity has been deleted.
➢ Mr. Lashua objected to the word "substantial" in the text of Part III. D., saying it was "highly
subject to individual interpretation". The text in question derives from North Carolina General
Statute 143.215.1, which states "that an applicant satisfy the Department that the applicant ... Has
substantially complied with the effluent standards and limitations and waste management
treatment practices applicable to any activity in which the applicant has previously engaged, and
has been in substantial compliance with other federal and state laws, regulations and rules for
protection of the environment." [NCGS 143.215.1 (b) (4) and 143.215.1 (b) (4) b. 2]. While the
Division does not have the authority to change the wording in the statute, the text in Part III. D.
has been altered to match other permits issued to your company.
➢ This final permit includes no other changes from the draft permit sent to you in December 2002.
N. C. Division of Water Quality / NPDES Unit Phone: [phone], extension 511
1617 Mail Service Center, Raleigh, NC 27699-1617 Fax: [phone]
Internet: h2o.enr.state.nc.us e-mail: [e-mail]

If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings
(6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this
decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or
Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Charles Weaver at telephone
number [phone], extension 511.
Sincerely,
ORIGINAL SIGNED BY
SUSAN A. WILSON
Alan W. Klimek, P.E.
cc: Central Files
Mooresville Regional Office/Water Quality Section
NPDES Unit

Permit NCO060755
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water
Pollution Control Act, as amended,
Carolina Water Service, Inc. of North Carolina
is hereby authorized to discharge wastewater fzom a facility located at the
Saddlewood Subdivision WWTP
Off NCSR 2416 south of Gastonia
Gaston County
to receiving waters designated as an unnamed tributary to Crowders Creek in the Catawba River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II,
III and IV hereof.
This permit shall become effective May 1, 2003.
This permit and authorization to discharge shall expire at midnight on August 31, 2005.
Signed this day April 3, 2003.
ORIGINAL SIGNED BY
SUSAN A. WILSON
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NCO060755
SUPPLEMENT TO PERMIT COVER SHEET
Carolina Water Service, Inc. of North Carolina is hereby authorized to:
1. Continue to operate an existing 0.009 MGD wastewater treatment facility with the
following components:
♦ Bar screen
♦ Aeration basin
♦ Clarifier
♦ Aerated sludge holding tank
♦ Tablet chlorine disinfection with contact basin
The facility is located at the Saddlewood Subdivision WWTP off NCSR 2416 south of
Gastonia in Gaston County.
2. Discharge from said treatment works at the location specified on the attached map into
an unnamed tributary to Crowders Creek, a class C stream in the Catawba River Basin.

Latitude: 35'10'4T'
Longitude•. '81 ° 10'59"
Quad: Gaston South, NC/SC
Stream Class: C
Subbasin:30837
Receiving Stream: UT Crowders Creek
Facility'
NCO060755 --
Location
Carolina Water Service
Saddlewood WWTP
North SCALE 1:214000

Permit NCO060755
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, ,the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS_
LIMITS
,MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample Location'
Flow
0.009 MGD
Weekly
Instantaneous
Influent or Effluent
BOD, 5-day (20°C)
(April 1 — October 31
5.0 mg/L
7.5 mg/L
Weekly
Grab
Effluent
BOD, 5-day (20°C)
November 1— March 31
10.0 mg/L
15.0 mg/L
Weekly
Grab
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
NH3 as N
(April 1 — October 31
2.0 mg/L
10.0 mg/L
Weekly
Grab
Effluent
NH3 as N
November 1 — March 31
4.0 mg/L
20.0 mg/L
Weekly
Grab
Effluent
Fecal Coliform (geometric mean)
200 / 100 ml
400 / 100 ml
Weekly
Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
Temperature (°C)
Weekly
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
Effluent,
Upstream & Downstream
Total Residual Chlorine
17 Ng/L
2/Week
Grab
Effluent
pHs
Weekly
Grab
Effluent
Footnotes:
1. Upstream = at least 100 feet upstream from the outfall. Downstream = at least 300 feet downstream from the
outfall.
2. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
April 3, 2003
Mr. Jim Highley
Carolina Water Service, Inc. of North Carolina
P.O. Box 240908
Charlotte, North Carolina 28224
Subject: Issuance of NPDES Permit NCO060755
Saddlewood Subdivision WWTP
Gaston County
Dear Mr. Highley:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as
subsequently amended).
We apologize for the delay in issuance of this final permit. The Division received no affidavit or
verbal confirmation of publication for the December 2002 Public Notice until yesterday. Final permits
cannot be issued without proof that the Public Notice was published.
This NPDES Unit received a comment letter from Mr. Martin Lashua of your company on January
21, 2003. The Division offers the following responses to Mr. Lashua's comments:
➢ The daily maximum ammonia limits are new in this permit, and were not present in the previous
permit. Previous permits for this facility had only monthly average limits for ammonia nitrogen.
r ➢ The permittee name has been changed as requested.
fl`1"d
�r Instream temperature monitoring has been removed from the final permit, as requested. Instream
P monitoring for dissolved oxygen remains in the final permit.
j ➢ Mr. Lashua objected to the word "substantial" in the text of Part III. D., saying it was "highly
zT�
subject to individual interpretation". The text in question derives from North Carolina General
, 100 Statute 143.215.1, which states "that an applicant satisfy the Department that the applicant ... Has
��Vp,
�y5k • substantially complied with the effluent standards and limitations and waste management
L `0' ts� treatment practices applicable to any activity in which the applicant has previously engaged, and
° has been in substantial compliance with other federal and state laws, regulations and rules for
protection of the environment." [NCGS 143.215.1 (b) (4) and 143.215.1 (b) (4) b. 2]. A copy of
the statute text is enclosed for your records. While the Division does not have the authority to
change the wording in the statute, the text in Part III. D. has been altered to match other permits
issued to your company.
➢ This final permit includes no other changes from the draft permit sent to you in December 2000.
'�{F7NK qoa -roR. !ion A�DIL� t�S f4t5 IbiKr6Lf�3E 3)
N. C. Division of Water Quality / NPDES Unit Phone: [phone], extension 511
1617 Mail Service Center, Raleigh, NC 27699-1617 Fax: [phone]
Internet: h2o.enr.state.nc.us e-mail: [e-mail]

Permit NCO060755
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS . R . m
LIMITS
s•
MONITORING REQUIREMENTS `
-
Monthly
Averages.
Daily .
Maximum
Measurement
Frequency,
Sample Type
Sample Location' ,
Flow
0.009 MGD
Weekly
Instantaneous
Influent or Effluent
BOD, 5-day (20°C)
April 1 — October 31
5.0 mg/L
7.5 mg/L
Weekly
Grab
Effluent
BOD, 5-day (20°C)
November 1 — March 31)
10.0 mg/L
15.0 mg/L
Weekly
Grab
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
NH3 as N
(April 1 — October 31
2.0 mg/L
10.0 mg/L
Weekly
Grab
Effluent
NH3 as N
November 1 — March 31)
4.0 mg/L
20.0 mg/L
Weekly
Grab
Effluent
Fecal Coliform (geometric mean)
200 / 100 ml
400 / 100 ml
Weekly
Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
Dissolved Oxygen2
Weekly
Grab
'--Efflueffl,
Upstream & Downstream
Total Residual Chlorine
17/jg/L
2/Week
Grab
Effluent
pH3
Weekly
Grab
Effluent
Footnotes:
1. Upstream = at least 100 feet upstream from the outfall. Downstream = at least 300 feet downstream from the
outfall.
2. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

PUBLIC NOTICE
ak)
State of North Carolina
Environmental Management
1617Commission/NPDESiService
Unit FIDAVIT OF INSERTION OF ADVERTISEMENT
1617 Mail Service Center '
Raleigh, NC 27699-1617
The Gaston Gazette
Notification of Intent to Issue A
NPDES Wastewater Permit
On the basis of thorough staff
review and applications of NC
General Statute 143.21, Public
law 92-500 and other lawful Onia NC
standards and regulations, the f
North Carolina Environmental iston County
Management Commission pro-
poses to issue a National Pollu-
tant Discharge Elimination Sys-
tem (NPDES) wastewater dis-
charge permit to the person(s) lelissa Birchfield Legal Advertising Manager of the The Gaston Gazette, do certify
listed below effective days ie advertisement of PUBLIC NOTICE
from the publish date off this no-
tice. NOTIFICATION OF INTENT TO ISSUE A NPDES
Written comments regarding WASTEWATER PERMIT
the proposed permit will be ac-
cepted until 30 days after the
publish date of this notice. All
comments received prior to that
date are considered in the final
determinations regarding the
proposed permit. The Director of the NC Division of Water wring 8.53 Inches appeared in The Gaston Gazette, a newspaper published in
Quality may decide to hold a In County, Gastonia, NC, In issues
public meeting for the proposed
permit should the Division re-
ceive a significant degree of
public interest.
Copies of the draft permit and EMBER I5, 2002
other supporting information on
file used to determine condi-
tions present in the draft permit
are available upon request and
payment of the costs of repro-
duction. Mail comments and/or
requests for information to the
NC Division of Water Quality at
the above address or call Ms.
Valery Stephens at (919)
733-5083, extension 520.
Please include the NPDES per-
mit number NC0060755, in any n to and subscribed before me this
communications. Interested
persons may also visit the Divi-
sion of Water Quality at 512 N.
Salisbury Street, Raleigh, NC
27604-1148 between the hours
of 8:00 a.m. and 5:00 to review
information on file.
NPDES Permit Number NC
0060755, Carolina Water Serv-
ice, Inc. (Saddlewood WWTP),
P.O. Box 240908, Charlotte,
NC 28224 has applied for a
permit renewal for a facility lo-
cated in Gaston County
discharging treated wastewater
into an unnamed tributary to
Crowders Creek in the Cataw-
ba River Basin. Currently BOD,
ammonia nitrogen and total re-
sidual chlorine are water quality
limited. This discharge may af-
fect future allocations in this
portion of the receiving stream.
ommission expires
tK,m 1 ,111 i,
► /���
"issaBifield
Legal Advertising Manager
,2003
Notary Public
£ooz 9 - »dd
1 C-December 15, 2002

Re: affadavit forNCO060755
To: Charles Weaver <Charies.Weaver c�i ncmail.net>
Per Carla Potter the ad rare 12-15-02, she will send another affidavit.
Charles Weaver wrote:
> Valery, th11s Went to 1Vot1ce December lath but r st111 have no allciUa iL.
> Please check and let me knoy, if you ever received a verbal confirmation_
> Thanks,
> CHW
1 of 1 4/ 2/2005 9`.20 AM

♦ Pre Seminar Material
♦ Confirmation letter
♦ Location, date & time
♦ Hotel accommodation information
♦ Rescheduling information
♦ Re -confirmation letter
♦ Location, date & time
♦ Hotel accommodation information
♦ Rescheduling information
♦ Course Description
♦ Agenda
♦ Map of Area with Written Directions
♦ Seminar Presentation Material
♦ Binders
♦ Welcome Page
♦ Wearing name badges
♦ Info. about how messages can be left while attending seminar
♦ Cell phones off or on vibrate
♦ Pay phone location
♦ Restroom location
♦ Smoking policy
♦ How to I.D. DWQ staff members
♦ Preliminary Attendee list
♦ Course Description
♦ Agenda
♦ Slide Presentations & Handouts
♦ Speaker Information
♦ List of Restaurants in area (w/ map)
♦ Pie chart for explanation of fees collected
♦ Organizational charts and phone numbers
♦ Reference Documents (too large to present)
♦ Evaluation Form
♦ Notepads
♦ Pens/Pencils
♦ Snacks/Lunch
♦ Water for tables
♦ Message board
♦ Post -Seminar Material
♦ Certificate of Participation
♦ Thank -you Letter
♦ Final List of Attendees
♦ Instructions forgetting continuing education credit

CAROLINA WATER SERVICE, INC.
AN AFFILIATE Of
Ur[I ICI ITMCSOIIMC
Regional Office:
5701 Westpark Dr., Suite 101
P.O. Box 240908
Charlotte, NC 28224
Telephone: [phone]
FAX: [phone]
January 20, 2003
Mr. Charles H. Weaver
NPDES Unit
NC DENR — Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Saddlewood WWTP
NPDES NCO060755
Gaston County
Dear Mr. Weaver,
J AN 2 1 2003
We are in receipt of your December 11, 2002 letter, enclosures and draft permit for the above facility.
There are two issues to address — one is the draft permit and the other is the issue of the EAA
requirement.
Draft Permit
We offer the following:
1) You state that Daily Limits for Ammonia were added to the permits. This is not correct. Our existing
permit already has these same limits for this parameter. kIROAIG
2) Our official name is Carolina Water Service, Inc. of North Carolina. This was indicated on our
application and in the existing permit. Please correct. jJWF7
3) We would like to request that all instream monitoring be removed. This data collection seems l //
unnecessary. This is a request only and if you feel this data is important we will, of course, comply. /lee-,l r� -
4) In Section (III)(D), we have concerns over the use of the word " ... substantial ..." without clear tv, / j
definition. "Substantial" non-compliance is highly subject to individual interpretation. A cle /,, PO.
definition would eliminate confusion. f n -1P7
`� V, e 5�ec� o �5 �n /l/leeZ-fV / .
EAA
Our positions on this topic differ substantially.
1) An EAA was submitted but it did not meet the deadline of January 1, 2001. An EAA dated August
30, 2001 prepared by Land Design, Inc. was submitted to your office and then summarily rejected and
returned to us with a December 13, 2001 letter from Mr. Goodrich. Your Department felt that we
were using outdated information when in fact nothing significant had changed. This is a small facility
in a reasonably remote part of Gaston County with no development or growth.
2) Again, an EAA was submitted — albeit late — and Mr. Daniel's commitment was honored. However,
Mr. Daniel committed in good faith with the impression that the Division had authority to require the
EAA when in fact, by definition, this requirement did not apply to this facility.

Page 2
Mr. Charles H. Weaver
January 20, 2003
3) In our opinion, the Division has a flawed perspective in your continuing focus on facility discharge
elimination. The argument has been made that NPDES stands.for Discharge Elimination. It actually
stands for Pollution Discharge Elimination. Reduction in permit parameter limits and continued
enforcement, not the elimination of the discharge itself, can accomplish this. If there was a way to
truly eliminate the discharge flow (by spray irrigation, etc.) then your argument on report 92-04
would have merit. However, trying to force connection to the City of Gastonia simply moves the
flow from one point to another in the same basin. The Division is not eliminating anything other than
the point source. It seems environmentally unsound to require multiple small point source discharges
to combine into one large one. It would appear that the environment could more easily absorb
discharge impact in many dispersed and smaller quantity flows than one facility discharging huge
volumes of water into a single point in the stream. Why does the Division insist on connection to a
municipality? In this case the Division wants a facility with a very good compliance history to
connect to a large municipality with a poor track record. Why does the Division not ask the City (or
other municipalities) to seek other alternatives? The answer is because there are none. Why does a
municipality not contact us when they wish to expand in an area already served by our system? If
indeed a water quality report recommends the removal or elimination of discharges, this does not
mean to simply move the flow to another facility. The Division continues to focus on elimination of
privately owned facilities with the encouragement of "super -sizing" municipal ones - many of whom
have poor compliance history. The only real benefit of elimination of a discharge by connecting to
another is elimination of the number of facilities the Division has to monitor.
You reference an April 3, 2002 e-mail to our attorney, Mr. Steve Levitas. In that e-mail, you again
use an argument that doesn't apply. You state that, " ... we have used it in other permits for facilities
with chronic problems/operation deficiencies." In fact, the Saddlewood WWTP has a very good
compliance history.
We sincerely thank you for forwarding the Permit and moving this renewal forward. It is imperative that
the Division understands the need to consider cost effectiveness in these evaluations. As a regulated
utility, these costs are almost always included in rate base to the consuming public.
IfAve can ever be of assistance, please do not hesitate to contact me at 704-525-7990, Ext. 216.
Martin Lashua
Regional Manager
CC: Mr. Carl Daniel
Mr. Tony Konsul
Mr. David Roberts

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
December 11, 2002
Mr. Martin Lashua
Carolina Water Service, Inc.
P.O. Box 240908
Charlotte, North Carolina 28224
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Draft NPDES Permit
Permit NCO060755
Saddlewood Subdivision WWTP
Gaston County
Dear Mr. Lashua:
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefully
to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from your current permit:
➢ Daily Maximum limits for ammonia have beer' added to the Effluent Limitations and
Monitoring Requirements page (Part I. A (1)). See the attached ammonia policy memo for
details. .
➢ Instream monitoring for fecal coliform has been deleted.
➢ Conductivity monitoring has been deleted.
➢ Part III. E., the permit condition requiring the alternatives analysis, has been deleted.
The Division agrees with the findings from your investigation into alternatives to discharge. The
correspondence from the City of Gastonia is adequate documentation that connection to the Crowders
Creek WWTP is not feasible at this time.
In regard to your objections to the EAA requirement, we offer the following responses in order to clarify
this issue:
➢ The existing permit for Saddlewood (issued on July 7, 1997) required that an alternatives analysis be
submitted by January 1, 2001. This requirement is documented in the cover letter and in Part III. E.
of the permit (see attached copies). No EAA was submitted. Carolina Water Service (CWS)
therefore failed to comply with the permit.
➢ CWS agreed to the EAA requirement and the January 2001 deadline, per a conference call between
Mr. Carl Daniel, Mr. David Goodrich and Mr. Mack Wiggins. This is also documented in the permit
cover letter. By failing to submit an EAA, CWS failed to honor the commitment Mr. Daniels
made.
➢ The EAA requirement was prompted by the Water Quality Investigation of Lake Wylie (Report No.
92-04), which recommended removal of existing discharges tributary to the Crowders Creek
drainage basin. The preferred means of removal was by connection to the City of Gastona's
Crowders Creek WWTP. Your objections to the EAA requirement would be relevant if the EAA
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 511 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer Charles.Weaver@ ncmail.net

Draft Permit NCO060755
Page 2
t
had been required solely because the Saddlewood WWTP discharges to a zero -flow stream.
However, the EAA requirement was based upon watershed -specific concerns, in response to the
above -referenced study. This reasoning is stated in the cover letter and Part III. E. of the existing
permit. This reasoning -was also communicated to your attorney (Mr. Steve Levitas) in April 2002
(see attached e-mail copies).
➢ The EAA requirement from 1997 has now been satisfied, and the Division plans to reissue the
permit.
Submit any comments to me no later than thirty days following your receipt of the draft. Comments should
be sent to the address listed at the bottom of this page. If no adverse comments are received from the
public or from you, this permit will likely be issued in late January, with an effective date of March 1, 2003.
If you have any questions or comments concerning this draft permit, call me at [phone], extension
511.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Mooresville Regional Office / Water Quality Section
NPDES Unit

Permit NCO060755
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water
Pollution Control Act, as amended,
Carolina Water Service, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Saddlewood Subdivision WWTP
Off NCSR 2416 south of Gastonia
Gaston County
to receiving waters designated as an unnamed tributary to Crowders Creek in the Catawba River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II,
III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on August 31, 2005.
Signed this day
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NCO060755 I
SUPPLEMENT TO PERMIT COVER SHEET
Carolina Water Service, Inc., is hereby authorized to:
1. Continue to operate an existing 0.009 MGD wastewater treatment facility with the
following components:
♦ Bar screen
♦ Aeration basin
♦ Clarifier
♦ Aerated sludge holding tank
♦ Tablet chlorine disinfection with contact basin
The facility is located at the Saddlewood Subdivision WWTP off NCSR 2416 south of
Gastonia in Gaston County.
2. Discharge from said treatment works at the location specified on the attached map into
an unnamed tributary to Crowders Creek, a class C stream in the Catawba River Basin.

Facility LN" T"
Latitude: 35-10'42" NCO060755
TO,, "'N
Longitude: 81'10'59" Location V
Quad: Gaston South, NC/SC Carolina Water Service
Stream Class: C SaddLewood WWTP
Subbasin: 30837
Receiving Stream: LIT Crowders Creek NorthSCALESCALE 1:24000

Permit NCO060755
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
;AFFLUENT
h LIMITS
RIN MONITOG REQUIREMENTS
„.
CHARACTERISTICS ;
v s x •"
Monthly
Daily
N�easurement
Sample Type'
Sample I_ocatron�`
_ �..
��..Average_.. r,
Maximum.
Frequer�Ey
,
Flow
0.009 MGD
Weekly
Instantaneous
Influent or Effluent
BOD, 5-day (20°C)
5.0 mg/L
7.5 mg/L
Weekly
Grab
Effluent
(April 1— October 31
BOD, 5-day (20°C)
10.0 mg/L
15.0 mg/L
Weekly
Grab
Effluent
(November 1 — March 31)
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
NH3 as N
2.0 mg/L
10.0 mg/L
Weekly
Grab
Effluent
(April 1 —October 31)
NH3 as N
4.0 mg/L
20.0 mg/L
Weekly
Grab
Effluent
(November 1— March 31
Fecal Coliform (geometric mean)
200 / 100 ml
400 / 100 ml
Weekly
Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
Temperature (°C)
Weekly
Grab
Upstream & Downstream
Dissolved Oxygen2
Weekly
Grab
Effluent,
Upstream & Downstream
Total Residual Chlorine
17 Ng/L
2/Week
Grab
Effluent
pH3
Weekly
Grab
Effluent
Footnotes:
1. Upstream = at least 100 feet upstream from the outfall. Downstream = at least 300 feet downstream from the
outfall.
2. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
A&71 0
7A
AdMhE
[DEHNR
July 7, 1997
Mr. Carl Daniel, Vice President
Carolina Water Service, Inc. of North Carolina
P.O. Box 240704 ;
Charlotte, North Carolina 28224
Subject: NPDES Permit Issuance
Permit No. NCO060755
Saddlewood Subdivision
Gaston County
Dear Mr. Daniel:
In accordance with the application for a discharge permit received November 1. 1995, the Division is
forwarding herewith the subject NPDES permit. This permit is issued pursuant to the requirements of
North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina
and the US Environmental Protection Agency dated December 6, 1983.
Discharges tributary to the Crowders Creek drainage basin are targeted for removal by connection to
the Crowders Creek regional wastewater treatment plant. As you agreed in a telephone conversation with
David Goodrich and Mack Wiggins of my staff, the permittee shall submit a revised engineering alternative
analysis evaluating alternatives to discharge by January 1, 2001. Also as agreed in this discussion,
Carolina Water Service will have until April 1, 1998 to meet a Total Residual Chlorine limit of 17 ug/l.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be to the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is
made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part II, E.4. addresses the requirements to be
followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Mack Wiggins at telephone
number [phone], extension 542.
Sincerely,.
Original Signed By
David A. Goodrich
A. Preston Howard, Jr., P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
Mr. Roosevelt Childress, EPA
Permits and Engineering Unit
Facility Assessment Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Part III
Permit No. NC0060755
E. Water Quality evaluations of Lake Wylie have documented that the lake is threatened by
eutrophic conditions, particularly in the embayments and tributary arms (see Report No. 92-04,
Water Quality Investigation of Lake Wylie). Discharges tributary to the Crowders Creek drainage
basin are targeted for removal by connection to the Crowders Creek regional wastewater treatment
plant.
Additionally, the Saddlewood Subdivision wastewater treatment plant discharges into an unnamed
tributary to Crowders Creek, a stream with no flow under low flow conditions. Removal of
discharges from low flow, streams are recommended if a more environmentally sound alternative is
available at an economically reasonable cost ( in accordance with 15A NCAC 2B .0206).
Therefore, an alternative analysis should be completed and sent to the following address by
January 1, 2001:
NCDEHNTR/DWQ
NPDES Group
PO Box 29535
Raleigh, North Carolina 27626-0535

Division of Water Quality
Point Source Branch/NPDES Unit
October 15, 2002
MEMORANDUM
To: Coleen H. Sullins, Water Quality Section Chief
Through: Dave Goodrich, Supervisor, NPDES Unit
From: Susan A. Wilson, P.E_, Environmental Engineer, NPDES Unit
Subject: Implementation Policy for Permits with Monthly Average NH3-N Limits
Background. According to the Code of Federal Regulations. [40. CFR 122.45 (d)], continuous
discharges "shall unless --impracticable be- stated as: (1) Maximum` daily and average monthly
'`discharge limitations for all dischargers ther than publicly owned .treatment works; and (2)
Average weekly and average monthly discharge limitations for POTWs". To date, North
Carolina has instituted NH3-N limits based on monthly average limits only (with the exception
of industry specific Federal Guideline limits), as directed by the Water Quality Section Chief
via memo dated June 6,,1990 [Appendix A]. No adverse comments�were received from the EPA
regarding NH3-N until 2001. Durin the last quarter of 2001, the NPDES Unit began receiving
comments from EPA Region -IV objecting to permits that did not' have corresponding daily
maximum and weekly average limits for ammonia., The Division'of Water Quality (the Division)
and EPA reached an agreement on April 8, 2002 to issue permits with a reopener clause for
N143-N during. the interim period, until a policy could be established.
In order to formulate the NH3-N policy, a.workgroup of stakeholders was formed:
Matt Matthews, Supervisor, Aquatic Toxicology Unit
Mike Johnson, Environmental Manager, DuPont Company Fayetteville Works
Stanley Curtis, Superintendent of Wastewater Treatment, City'of Rocky Mount
Susan Wilson, Environmental Engineer, NPDES Unit
Dave Goodrich, Supervisor, NPDES Unit
The workgroup met on 3 occasions, and corresponded via e-mail or phone to resolve issues
concerning the policy.
Options Reviewed. The workgroup reviewed various options that could be used in developing
the daily maximum or weekly average NH3-N limit. Both an "effluent" technology -based limit
and a "water quality" standards -based limit were evaluated.
Water qualitU-based limit. For a water quality -based daily maximum or weekly average value,
the workgroup discussed using an NH3-N value based on nutrient concerns, a value based on
oxygen consuming waste (established through modeling), or a value based on toxicity.

i
A value based on nutrient concerns was because nutrient effects are typically based on long
term, rather than short term concerns. Additionally, nutrient issues were eliminated since
they are specifically addressed in the five nutrient sensitive river basins throughout the state.
The workgroup also discussed an NH3-N limit based on the effects of oxygen consuming
wastes. The NIPDES Unit currently uses a water quality model to predict the effects of BOD5
and NH3-N (through nitrogenous biochemical oxygen demand) on the receiving stream. 'These
models use stream flow conditions and design wastewater characteristics, to determine BOD5
and NH3-N .limits to protect the state standard for dissolved oxygen. In order to establish a
daily maximurn value or a weekly average NH3-N value, appropriate streamflow for modeling
would need to be established. Three water quality based models were run using average flow
to reflect daily or weekly conditions. Elevated values for NH3-N were inserted into randomly
selected site -specific models to determine the impact on dissolved oxygen. Although there
was some impact associated with increased NH3-N levels, none of the models .predicted
dissolved oxygen near the instantaneous minimum value of 4 mg/1 dissolved oxygen. Because
every model is site -specific, every condition could not be simulated, for. this study. However,
based on the 3 models randomly selected, this option was eliminated due to the lack of impact
that a daily or weekly average NH3 value has on the receiving. stream.
A toxicity -based approach to establish a daily maximum value or a weekly average value was
also considered by the workgroup. North Carolina has no chronic or acute standard for ---- ----
NH3-N . (although North Carolina. has implemented toxicity based NH3-N limits since 1990).
Research into 'acute criteria. indicated a range of values from 12 mg/1 to 15 mg/1 [See
Appendix A, Table, p.21. Of the water quality -based approaches, the- work groupr focused on
'this method.
Technoiogwbased` limit. For 'a' technology -based daily maximum or weekly average valise, the
workgroup discussed using an NH3-N valise based on :site specific best available technology, a
value based On,, design - specific capability, and a value based on . , analysis :of a sting
performance data.
A site specific best available technology limit was (dismissed due to the time constraints
involved iii-developing a site specific value and the need to develop a method which cpuld be
simple enough to be applied on a state-wide basis.
For a design specific NH3-N value, several design consultants were called to determine what
an appropriate daily maximum or weekly average value would be for a given monthly average.
In general, most respondents stated that their designs were specific to the facility and in the
majority of cases they designed the facility to meet the most stringent limit on a daily basis -
they did not design for "daily or weekly maximums". Essentially, the design engineers
designed the facility to comply with the monthly average NH3-N limit on a daily basis - with
the probability that in any wastewater treatment system - there may be excursions that could
be managed operationally. Therefore, the design specific weekly average or daily maximum
NH3-N value did not really exist in the context of this work and was dismissed by the
workgroup.
A performance based NH3-N value was also reviewed by the workgroup. The workgroup
decided to review weekly average/monthly average values for several existing, compliant
municipal facilities, as well as daily maximum/monthly average values for industrial and
minor non -municipal facilities. From this information, a ratio of weekly average or daily
maximum to monthly average NH3-N ratios could be reviewed. This determination for an

NH3-N value was deemed easy to apply state-wide, would not strain resources, and would
comply with the federal requirement.
Chosen Option. The workgroup had to decide between the water quality -based approach
(based on toxicity) and the technology -based approach (based on' actual performance). Water
quality based limits are established to protect known or predicted water quality impacts.
Since there have been no known or predicted acute stream impacts due to NH3-N, a water
quality based limit was eliminated by the group. Furthermore, the Division would need to
adopt a standard for any chosen water quality method. Therefore, the performance based
NH3-N value was chosen as the best alternative to comply with the Federal Guideline.
Data Evaluation. Once the method for choosing the NH3-N daily maximum/weekly average
limit was established, facility data were evaluated for 6 industrial facilities, 8 minor non -
municipal domestic facilities, and 8 municipal facilities. Effluent NH3-N data for the calendar
year 2001 were reviewed for these facilities. For the industrial and the minor non -municipal
facilities, the highest daily maximum values were evaluated and compared to monthly average
values for each m6n0—. For die municipal facilities, the highest weekly average value for the
month was' -evaluated and compared to each corresponding. monthly average. The total
number of data points was 99 for municipal facilities and 160 for combined industrial and
minor non -municipal facilities. These data sets represented variability associated with
seasonality.
For each facility category the ratios of daily maximum to monthly average or weekly average to .
• monthly average were listed and ranked., The .95th and 99th .percentiles were evaluated for each
category [See Appendix B).
For the municipal. facilities, :the 95th percentile ratio value was chosen as the multiplier.
Because. municipal facilities must comply -with a weekly average NH3-N, limit, instead of a daily
maximum, the 95th percentile value was deemed most -appropriate, as this percentile would
.account for the averaging allowed by a weekly requirement. That value was found to be.3:1.
Due to thesimilar ratios (both 95th and : 99th percentile -values) and similar permitting
requirements (monthly averages/daily maximums) between the industrial and minor non -
municipal facilities,- these categories were combined to be evaluated as one group. Both of
these groups must meet a daily maximum NH3-N value. The two highest ratios were deemed
outliers and omitted from the ranking. From the modified data set,_ the 99th percentile ratio
value was chosen as the multiplier for industrial and non -municipal facilities. Because these
facilities must meet a daily maximum NH3-N value the 99th percentile ratio value was deemed
most appropriate, as this percentile would take into account potential daily variability (as
:opposed to the averaging effects that a weekly average value entails). That value was found to
be 5:1.
Implementation. The workgroup also discussed the implications of implementing the daily
maximum and weekly average values into permits.
As part of North Carolina's agreement with EPA, the Division agreed to re -open those permits
issued after April 8, 2002 to include weekly average or daily maximum limits, if review of the
data demonstrate a reasonable potential to exceed the established value [See Appendix C).
The Division will commence with re -opening those permits by December 31, 2002, if

necessary. Approximately 31 permits with NH3-N monthly average values have been issued
since the April agreement.
With renewal or new permits that have monthly average NH3-N limits, the NPDES Unit will
implement daily maximum or weekly average limits for non -municipal and municipal facilities,
using the ratio established through the workgroup (5:1 for non -municipal facilities, 3:1 for
municipal facilities).
The workgroup also discussed placing a maximum value, or cap requirement, on daily
maximum and weekly average values. For example, some permits have monthly average NH3-
N limits that are 10 mg/1 or higher. If a multiplier of 3:1 or 5:1 were used to establish a
weekly average or daily maximum limit, the value would be 30 mg/l or 50 mg/l. Because
typical untreated wastewater NH3-N values range from 12 50 mg/1 [Metcalf & Eddy,
Wastewater Engineering, 3rd Ed., p. 1091, the workgroup agreed to place a cap of 35 mg/1
(slightly higher than the medium waste strength value of 25 mg/1) on the calculated daily
maximum or weekly average values. This also corresponds with the NPDES Unit's current
policy of placing a maximum cap on NH3-N toxicity calculated valucw ?t 35 mg/l. The NPDES
Unit will allow a facility, if the facility objects to the cap, to demonstrate that the facility's
influent values are greater than 35 mg/1 in order to raise the cap. This wnl'be inaraaed on a
case -by -case basis.
Conclusion. The workgroup, along with the NPDES Unit, chose a performance based
approach to develop limits for daily maximum and weekly average NH3-N limits. Based on
review of the performance data, a ratio (or multiplier) of 3:1 was chosen for municipal facilities
and 5:1 for non -municipal facilities. Following approval by the Water Quality Section Chief,
the NPDES Unit will begin immediate implementation of these limits in new and renewal
permits. This will allow the Division of Water Quality to comply with the Federal Regulations.
Please feel free to call me at [phone], ext. 510 if you have any questions or comments.
cc: Shannon Langley, PSC&EU
Water Quality Regional Office Supervisors
NPDES Unit staff
Tom Poe, Pretreatment Unit
Darlene Kucken, Basinwide Unit
Stakeholder Workgroup

CAROLINA WATER SERVICE, INC.
AN AFFILIATE Of
uu rlICIitrlICssoIInc
Regional Office:
5701 Westpark Dr., Suite 101
P.O. Box 240908
Charlotte, NC 28224
Telephone: [phone]
FAX: [phone]
November 22, 2002
Mr Ch es Weaver
NPDES Unit
NC DENR — DWQ
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Saddlewood WWTP
NPDES Permit #NC0060755
EAA Request/Response
Dear Mr. Goodrich,
As you know, your Division has required the submission of an Engineering Alternatives Analysis (EAA)
for the above facility. We have made numerous attempts to resolve this issue. I understand that Mr.
Bruce Haas of our company met with Mr. Dave Goodrich on October 10, 2002 to discuss this matter in
detail. Mr. Goodrich indicated that he would review the information presented by Mr. Haas at their
meeting, namely that the previous EAA Study submittal regarding Saddlewood clearly indicated that the
plant was meeting Permit limits and NO upgrades were necessary. This information would clearly justify
our position that continued operation of the WWTP is the most economical and cost effective approach.
While the attached information clearly substantiates Carolina Water Service's position, we must further
go on record to state that we believe the request for an EAA was wrongfully applied, and without
appropriate requirement. 15A NCAC 2H.0105(c)(2) is only required and mandated for "a new Permit or
expanding an existing NPDES Permit ..." of which this facility is neither. This is a very small facility
permitted for only 9,000 gallons per day and serves only 17 customers.
We understand that your Division wishes to eliminate as many discharges as possible, but any option
must be practical and cost effective. This facility is in substantial compliance and we have already
incurred a substantial expense to submit not one, but two EAA analysis. The fact that the Permit has not
yet been renewed is disturbing given the facts of the case.
While not required to do so by regulation, we have invested substantial effort to meet your seemingly
unjustified requests. As an additional effort, we recently contacted the City of Gastonia to discuss
additional options. They are the only large system anywhere even remotely close to the facility. There
are only two options available for connection to Gastonia. One would be the provision of bulk service,
and the other would be system purchase. As you will see from the November 19, 2002 letter (enclosed)
from Mr. Mike Bynum with the City of Gastonia, neither is an option. Even if connection to their system
was possible and cost effective, the City would neither purchase our existing system and customers, nor
allow bulk service.

Page 2
Mr. Charles Weaver
November 22, 2002
Carolina Water Service, Inc. of NC has gone to great lengths on this matter to try to comply with your
Division's request. Since the EAA requirement is not applicable to the facility by your own definition,
we feel that we have made all reasonable efforts to investigate our sole option with the City of Gastonia
and to satisfy any and all concerns.
Since we have additional flow capacity available at our Saddlewood facility, we hope you will insist that
the City of Gastonia contact us for service in the immediate area and that any EAA requirement be
applied to them with equal vigor.
We respectfully ask that you renew the Permit and bring this matter to a close.
If you wish to discuss this or have any questions, please do not hesitate to contact me at 704-525-7990,
Martin Lashua
Regional Manager
CC: Mr. Carl Daniel
Mr. Bruce Haas
Mr. David Goodrich — NPDES Unit
Mr. Ray Waugh — Land Design, Inc.
Mr. Tony Konsul
Mr. David Roberts

Clifu of k"U""r damn
P. O. BOX 1748
(?�ttstaxtirz, urt1l (�azalina 28Q�3-1748
DEPARTMENT OF
PUBLIC WORKS AND UTILITIES
November 19, 2002
Martin Lashua, Regional Manager
Carolina Water Service, Inc.
Post Office Box 240908
Charlotte, North Carolina 28224
Subject: Saddlewood Sewer Collection System
Dear Mr. Lashua:
Thank you for your inquiry concerning the availability -of City of Gastonia sewer •service
to the Carolina Water Service, Inc. sewer system in the Saddlewood Subdivision. The
City of Gastonia has an outfall line along' Brandon Creek approximately one -quarter of a
mile to the west of the subdivision. A sanitary sewer extension could be installed from
the outfall to serve the subdivision as shown on the attached drawing. The approximate
length of such extension would be 4020 feet to reach the site of the existing wastewater
treatment facility for the subdivision. Additional extensions would be required to serve
the properties in the subdivision.
A magnitude of cost estimate has been completed. The estimated cost of the required
sewer extension to reach the existing wastewater treatment facility for the subdivision is
$381,997. This estimate is based on the required pipe sizes to serve the basin. The
estimated cost for the required on -site improvements for the City of Gastonia to serve the
17 lots currently on the privately operated sewer system is $195,445. The total estimated
cost to serve the lots currently served by Carolina Water Service, Inc. is $577,442.
At this time, the City. of Gastonia would not consider the purchase of the existing sewer
system, and customer base from Carolina Water Service; Inc.
The City of Gastonia does not currently`have a policy for the, bulk sale of water and/or
sewer service to privately owned utility companies. The City has in the past provided
temporary utility service to privately operated utilities on a short term basis while City
lines were constructed to replace the privately operated systems. Following the

installation of City lines, the privately operated systems were taken out of service. The
City of Gastonia does not have a sewer line close enough to the Saddlewood Subdivision
to provide an immediate connection.
If a majority of the property owners in the Saddlewood Subdivision including all of the
property owners served by the Carolina Water Service, Inc. system were to petition the
City of Gastonia for sewer service, lines could be extended to serve the subdivision. Once
the lines were installed and the customers on the privately operated system were
connected to the city system, the private system could be abandoned. The City of
Gastonia has received several inquiries concerning sewer service in the Saddlewood
Subdivision and in the area along Robinson Road. However, there are no active petitions
for sewer service at this time. The City of Gastonia would consider sewer service in this
area upon receipt of a sufficient petition for sewer service from the residents in the area.
Proceeding with such a project would also be contingent upon available funding.
Personnel from the Public Works and Utilities Department are available to meet to
discuss this matter. Please contact me at 704-866-6043 to schedule a meeting or if you
have any questions or need additional information.
Sincerely,
Michael W. Bynum, EIT
Utilities/Customer Service
Attachments
PC: Flip Bombardier
Matt Jordan
Larry Cummings
Ed Cross
Felix Pruitt
File

Sewer To Serve Sadd lewood
N

PUBLIC WORKS & UTILITIES DEPARTMENT
CITY OF GASTONIA
BUDGETARY ESTIMATE
PROJECT: PROPOSED SEWER TO SERVE PROPERTY
IN SADDLEWOOD SUBDIVISION CURRENTLY
SERVED BY CAROLINA WATER SERVICE, INC
OFFSITE SEWER IMPROVEMENTS
15" SEWER LINE (1420 LF @ $70.00/1-F) $ 99,400.00
12" SEWER LINE (2600 LF @ $60.00/1-F) $156,000.00
OFFSITE R/W ACQUISITION (4020 LF x 30 FT x $.50/SF) $ 60,300.00
SUBTOTAL $ 315,700.00
10% CONTINGENCY ALLOWANCE $ 31,570.00
10% ENGINEERING ALLOWANCE $ 34,727.00.
TOTAL OFFSITE SEWER $ 381,997.00
ONSITE SEWER INPROVEMENTS
12" SEWER LINE (890 LF @ $60.00/LF) $ 53,400.00
8"SEWER LINE (1190 LF @ $55.00/LF) $ 65,450.00
SERVICE CONNECTIONS (17 @ $675.00) $ 11,475.00
OFFSITE R/W ACQUISITION (2080 LF x 30 FT x $.50/SF) $ 31,200.00
SUBTOTAL $161,525.00
10% CONTINGENCY ALLOWANCE $ 16,152.50
10% ENGINEERING ALLOWANCE $ 17,767.75
TOTAL ONSITE SEWER $195,445.25
TOTAL ESTIMATED COST $ 577,442.25
Note: Estimate for sewer assumes the sewer lines alignment will be
in an area of no pavement cuts.
Pavement cut(s) would add approximately $20 per linear foot.
SaddlewoodSSCWS112002 11/18/2002

xrw management plan
From: CILtries Weaver <Charles.Wcaver a ncfnail.net% 4/ 3/2002 9:31 AN
Subject: xvw rriarillgc n tPlan
To: Steve Uvitas <[e-mail]>
Steve, we had 15 Neuse permits at Public Hearing in 2000. The Neuse River Foundation objected to all of them, but
not for identical reasons. Some had poor compliance records, some had other alternatives available and others had
no alternatives or compliance problems but were generally in poor shape.
In response to the Hearings, we developed a modular permit condition called the Wastewater Management Plan.
Simply levying fines for compliance problems does not convince many permittees that their treatment systems are
inadequate. The EAA requirement alone cannot reveal a facility's deficiencies or the best course of action for the
permittee if he/she must continue discharging. The Plan requirement is a diagnostic tool, both for the Division and
the permittee.
Since the Plan was developed for the Neuse facilities, we have used it in other permits for facilities with chronic
compliance problems/operational deficiencies. A template Plan is attached. Depending upon the issues/problems at
a given facility, sections in this text may be deleted or expanded. This is the text a permit writer starts with when
developing the Plan requirement.
Kings Grant and College Park will not get Plan requirements, as there are no chronic compliance problems at those
facilities.
However, we still need CWS to tell us what possibility exists for connecting those facilities to a POTW.
Let me know if you have questions.
CHW'
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L_.lwy-rW optimize.doc I Type: WINWORD File (application/msword)
1 Encoding. base64
1 of 1 12/3/2002 11:00 AM

zero -flow triage and NCO060755
To: [e-mail]
Steve - here is an abbreviated section of the NPDES Guidance Manual that
addresses zero -flow streams and how the 2B.0206 rule has been
i.mp 1. ement ed .
Remember that in the case of Saddlewood the impetus for the alternatives
analysis (EAA) was not primarily the 2B.0206 rule but the management
strategy for Lake Wylie and Crowders Creek, which recommended removal of
discharges to Crowders Creek.
Note also that in 1997 CWS agreed to submit the EAA by the 1/1/2001
deadline. I've attached an electronic copy of the 1997 renewal cover
letter which documents the reasons for the EAA.
I'll send you the wastewater management plan text in a separate message.
CHW
Name: 60755iss_1997.DOC
r,60755iss 1997.DOC I Type: WINWORD File (application/msword)
l Encoding: base64
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zero flow tri=.doc Type: WINWORD File (application/tnsword)
Encoding: base64
1 of 1 12/3/2002 10:59 AM

OF WAT,�9 Michael F. Easley
Governor
William G. Ross, Jr., Secretary
r NCDENR
North Carolina Department of Environment and Natural Resources
L Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
December 13, 2001
Mr. Bruce Haas
Carolina Water Service, Inc.
P.O. Box 240908
Charlotte, North Carolina 28224
Subject: NPDES Permit NCO060755
Saddlewood WWTP
Gaston County
Return # 2130
Dear Mr. Haas:
The Division is returning the Engineering Alternatives Analysis (EAA) for the subject facility submitted
by Ray Waugh of LandDesign, Inc. After a review of the EAA by the NPDES staff, the Division has
determined that the EAA is inadequate.
The EAA's deficiencies include:
■ Outdated information. The EAA submitted appears to be a repackaged copy of the EAA
performed in 1991. No updated costs are included, nor are any updated alternative options
explored.
■ Incomplete cost analyses. The 1991 EAA was based on 10-year Present Value of Cost
Analyses. Current Division policy (as documented in the EAA Guidance Document
previously sent to you) requires 20-year Present Value of Cost Analyses.
■ No updated information on sewer availability. The 1991 EAA showed that the cost of
connection to the City of Gastonia's collection system was within 11% of the cost of
maintaining the WWTP. Gastonia's collection system has expanded considerably since
1'991. If sewer is available at a closer location than in 1991, this discharge may no longer be
justified.
It is the Division's mandate to assure the most environmentally sound wastewater disposal alternative is used at all
permitted facilities. In order to verify that the most environmentally sound method is in use at Saddlewood, a current and
complete EAA is required. A current and complete EAA is already eleven months overdue, based on condition sin your
existing permit (issued July 7, 1997). If you wish to renew this permit, please submit a current and complete EAA.
Another copy of the Division's EAA Guidance Document is enclosed with this letter.
If you have any questions about this matter, contact Charles Weaver at the telephone number or address
listed below.
Sincerely,
44,�bW ��
David A. Goodrich
NPDES Unit Supervisor
cc: Central Files
NPDES He
Mooresville Regional Office
LandDesign, Inc. / Ray Waugh
N. C. Division of Water Quality / NPDES Unit Phone: [phone], extension 511
1617 Mail Service Center, Raleigh, NC 27699-1617 Fax: [phone]
Internet: h2o.enr.state.nc.us e-mail: [e-mail]

OF W ATFR Michael F. Easley
Governor
\O� r ©D A William G. Ross, Jr., Secretary
�Dan) North Carolina Department of Environment and Natural Resources
01 Kerr T. Stevens, Director
Division of Water Quality
July 31, 2001
Mr. Jim Highley
Carolina Water Service, Inc.
P.O. Box 240908
Charlotte, North Carolina 28224
Subject: NPDES Permit NCO060755
Saddlewood WWTP
Gaston County
Dear Mr. Highley:
Part IIl. E. of the existing permit for this facility (issued July 7, 1997) required that an analysis of
alternatives to wastewater discharge be submitted to the Division by January 1, 2001. To date, no such
analysis has been received.
Enclosed with this letter is a copy of the Division's EAA Guidance Document. Complete and
submit the EAA by August 31, 2001. Submit the EAA to the addresses listed below:
Mr. Charles H. Weaver, Jr. Mr. Michael Parker
NC DENR / DWQ / NPDES Unit NC DENR Mooresville Regional Office
1617 Mail Service Center 919 North Main Street
Raleigh, NC 27699-1617 Mooresville, NC 28115
Failure to submit the EAA by August 31, 2001 will diminish the chances for renewal of the subject
permit. If you have documentation that the alternatives analysis was performed prior to January 1, 2001,
submit it along with updated cost data for the alternatives that were evaluated.
If you have any questions about this matter, contact me at the address or telephone number listed
below.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Mooresville Regional Office / Mike Parker
NPDES Unit
N. C. Division of Water Quality / NPDES Unit Phone: [phone], extension 511
1617 Mail Service Center, Raleigh, NC 27699-1617 Fax: [phone]
Internet: h2o. enr. state. nc. us e-mail: [e-mail]

(, D.eaN :V_'L
SOC PRIORITY PROJECT: NO
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: April 18, 2001
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Gaston
NPDES Permit No.: NCO060755
MRO No.: 01-28
PART I - GENERAL INFORMATION
Facility and Address: Saddlewood subdivision WWTP
Carolina Water Services, Inc.
PO Box 240908
Charlotte, NC 29224
2. Date of Investigation: April 18, 2001
3. Report Prepared By: B. Dee Browder, Environ. Engr. I
APR 2 5 2001
DE NR - WATER OUALITY i
POINT SOURCE BRANCH
4. Person Contacted and Telephone Number: Bruce Haas, [phone]
5. Directions to Site: From the jct. of Highway 321 and Robinson Road approximately 0.9
miles north of the NC/SC border, travel NE on Robinson Road approximately 1.40 miles
to the junction with Saddlewood Drive. Turn left onto Saddlewood Drive, then left onto
Stockwood Drive, and finally left onto fair Meadows Court. The plant entrance is at the
end of the cul-de-sac.
6. Discharge Point(s), List for all discharge Points: -
Latitude: 350 10' 42"
Longitude: 810 10' 59"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: G14NW Gaston South
7. Site size and expansion area consistent with application: Yes.
8. Topography (relationship to flood plain included): Plant is located on a small flat area
near a stream; surrounding land is moderately sloping. Plant does not appear to be in a
flood plain.

Page 2
9. Location of Nearest Dwelling: Approx. 600 feet from the WWTP site.
10. Receiving Stream or Affected Surface Waters: Unnamed tributary to.Crowders Creek
a. Classification: C
b. River Basin and Subbasin No.: Catawba 03-08-37
C. Describe receiving stream features and pertinent downstream uses: The receiving
stream has a very small defined channel with little flow. Downstream users are
unknown.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater: 0.009 MGD (Design Capacity)
b. What is the current permitted capacity: 0.009 MGD
C. Actual treatment capacity of.current facility (current design capacity): 0.009 MGD
d. Date(s) and construction activities allowed by previous ATCs issued in the
previous two years: N/A
e. Description of existing or substantially constructed WWT facilities: The existing
WWT facilities consist of a 9,000 gpd extended aeration package plant including
a bar screen, aeration basin, clarifier, aerated sludge holding tank, and tablet
chlorinator with contact chamber. The construction of the new chlorination unit,
dechlorination unit, fine bubble diffuser in the dechlorination tank, and all
associated piping and controls has been completed.
f. Description of proposed WWT facilities: N/A
g. Possible toxic impacts to, surface waters: There are no toxic impacts expected.
h. Pretreatment Program (POTWs only): Not Needed.
2. Residual handling and utilization/disposal scheme: Sludge is removed by Oaks Liquid
Waste and transported to a Charlotte Mecklenburg Utilities WWTP for disposal.
a. If residuals are being land applied specify DEM Permit No. N/A.
Residuals Contractor: N/A
Telephone No. ( )N/A
b. Residuals stabilization: PSRP PFRP
C. Landfill: N/A

3. Treatment Plant Classification: Class II (no change from previous rating).
Page 3
4. SIC Code(s): 4952 Wastewater Code(s): 05
5. MTU Code(s): 06007
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No
2. Special monitoring or limitations (including toxicity) requests: None at this time.
3. Important SOC/JOC or Compliance Schedule dates: N/A
Submission of plans and specifications
Begin Construction
Complete construction
4. Alternative Analysis Evaluation
a. Spray Irrigation: N/A
b. Connect to regional sewer system: Service is available in the area.
C. Subsurface: N/A
d. Other disposal options: None know at this time.
PART IV - EVALUATION AND RECOMMENDATIONS
Carolina Water Services Inc. requests the renewal of the NPDES permit for Saddlewood
Subdivision WWTP. It is recommended that the permit be renewed as requested.
7 �
r
Signature of Report Preparer Date
Water QualityRegional Supervisor Date
h:\dsr\dsr99\

CAROLINA WATER SERVICE, INC.
AN Aif ILIATE OF
UirI l�IlirI lCS,I IFOX.
Regional Office:
5701 Westpark Dr., Suite 101
P.O. Box 240908
Charlotte, NC 28224
Telephone: [phone]
FAX: [phone]
February 19, 2001 D E C E 9
Mr. Charles H. Weaver, Jr. FEB 2 2 W
NC DENR / Water Quality / NPDES Unit
01
1617 Mail Service Center
Raleigh, NC 27699-1617 DENR-WATER QUALITY
DINT SOURCE BF'ANCH
Re: Notice of Renewal Intent
Saddlewood WWTP
NPDES Permit NCO060755
Gaston County
Dear Mr. Weaver:
Carolina Water Service, Inc. of NC is hereby requesting renewal of the aforementioned
permit. No modifications have been made to the facility since the current permit was
issued.
Enclosed are one original and two copies of this letter, the application and the facility's
sludge management plan.
If you should need additional information regarding the permit renewal application or have
questions about the information I have provided, please contact me by calling 704-525-
7990.
Sin rel ,
Jim Highley
Sr. Regional Manager
c: Carl Daniel

NPDES PERMIT APPLICATION - SHORT FORM D
To be filed only by dischargers of 100% domestic wastewater (<1 MGD flow)
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
North Carolina NPDES Permit Number NC00
(if known)
Please print or type
1. Mailing address of applicant/permittee:
Facility Name -
Owner Name
Street Address
City
State
ZIP Code
Telephone Number
Fax Number
e-mail Address
2. Location of facility producing discharge:
Name (If different from above)
Facility Contact Person
Street Address or State Road
City / Zip Code
County
Telephone Number
3. Reason for application:
Expansion/Modification * Existing Unpermitted Discharge
Renewal �. New Facility
* Please provide a description of the expansion/modification:
4. Description of the existing treatment facilities (list all. installed components with
capacities):
Page 1 of 2 Version 1112000

NPDES PERNIIT APPLICATION - SHORT FORM D
To be filed only by dischargers of 100% domestic wastewater (<1 MGD flow)
5. Description of wastewater (check all that apply):
Type of Facility Generating Wastewater
Industrial
Commercial
Residential
School
Other
Number of Employees
Number of Employees
Number of Homes
Number of Students/Staff
Describe the source(s) of wastewater (example: subdivision, mobile home park, etc.):
6. Number of separate wastewater discharge pipes (wastewater outfalls):
7. If the facility has multiple discharge outfalls, record the source(s) of wastewater for each
outfall:
S. Name of receiving stream(s) (Provide a map showing the exact location of each outfall):
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Printed Name of
Title
North Carolina General Statute 143-215.68 (i) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of.the .
Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any,
recording or monitoring device or method required to be operated or maintained underAdlcle 21 or regulations of the Environmental
Management Commission. implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides -a punishment -by a fine of not more than $10,000 or
imprisonment not more than 5 years, or both for a similar offense.)
Page 2 of 2 Version 1112000

CAROLINA WATER SERVICE, INC.
j j II (AllCFFILI1AATT�I 01
U I I I I� I I� �I I� SO I li i i ice.. o
Regional Office:
5701 Westpark Dr., Suite 101
P.O. Box 240908
Charlotte, NC 28224 .
Telephone: [phone]
FAX: [phone]
February 19, 2001
Mr. Charles H. Weaver, Jr.
NC DENR/Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Saddlewood WWTP
NPDES Permit No. NCO060755
Sludge Management Plan
Dear Mr. Weaver:
Please be advised that sludge generated at the aforementioned facility is removed and
disposed of by:
Liquid Waste, Inc.
9300 Steele Creek Road
Charlotte, NC 28273
704-588-2392
If you should need additional information regarding our sludge management program,
please contact me by calling 704-525-7990.
Sinc rel ,
Jim Highley
Senior Regional Manager

I NPDES FACILITY AND PERMIT DATA 02/27/01 16:00:07
.UPDATE OPTION TRXID 5NU KEY NC0060755
PERSONAL DATA FACILITY APPLYING FOR PERMIT REGION
FACILITY NAME> CWS - SADDLEWOOD COUNTY> GASTON 03
ADDRESS: MAILING (REQUIRED) LOCATION (REQUIRED)
STREET: P.O. BOX 240908 STREET: END OF FAIR MEADOWS COURT
CITY: CHARLOTTE ST NC ZIP 28224 CITY: GASTONIA ST NC ZIP 28052
TELEPHONE [phone] DATE FEE PAID: 03/07/96 AMOUNT: 200.00
STATE CONTACT> WIGGINS PERSON IN CHARGE CARL DANIEL
1=PROPOSED,2=EXIST,3=CLOSED 2 1=MAJOR,2=MINOR 2 1=MUN,2=NON-MUN 2
LAT: 3510410 LONG: 08110550 N=NEW,M=MODIFICATION,R=REISSUE> R
DATE APP RCVD 03/08/96 WASTELOAD REQS 03/08/96
DATE STAFF REP REQS 03/08/96 WASTELOAD RCVD 06/04/96
DATE STAFF REP RCVD 04/01/96 SCH TO ISSUE 07/07/97
DATE TO P NOTICE 05/21/97 DATE DRAFT PREPARED 04/21/97
DATE OT AG COM REQS / / DATE DENIED
DATE OT AG COM RCVD / / DATE RETURNED
DATE TO EPA / / DATE ISSUED 07/07/97 ASSIGN/CHANGE PERMIT
DATE FROM EPA / / EXPIRATION DATE 09/30/01
FEE CODE ( 4 ) 1=(>10MGD),2=(>1MGD),3=(>0.1MGD),4=(<0.1MGD),5=SF,6=(GP25,64,79),
7=(GP49,73)8=(GP76)9=(GP13,34,30,52)0=(NOFEE) DIS/C 05 CONBILL ( )
COMMENTS: SUBMIT REVISED ALTERNATIVE ANALYSIS BY 12/31/97
MESSAGE: *** ENTER DATA FOR UPDATE ***