NC0064734_Return_20020529

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
May 29. 2002
Mr. Martin Lashua, Regional Manager
Utilities, Inc.
5701 Westpark Drive, Suite 101
Charlotte, North Carolina 28217
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NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Return of NPDES Permit Application
Bradfield Farms WWTP Expansion Request
NPDES No. NCO064734
Return No. 2157
Mecklenburg County
Dear Mr. Lashua:
The application that you submitted for an NPDES permit received November 2, 2002 for the
discharge of wastewater from the Bradfield Farms Subdivision is lacking complete information and is
being returned to your consulting engineer. Although much information was provided with the
application, the initial review of the project indicates that the following information must be provided
before a permit can be developed (more specific comments are offered in Appendix A of this letter):
Flow Justification. Currently, Bradfield Farms is permitted for an ultimate flow of 0.7 MGD, with
treatment capacity at 0.46 MGD. The alternatives document indicates that approximately 0.583
MGD is allocated to current and future users. The average flow for the past 12 months has been
0.14 MGD (or 30% of the design flow of 0.46 MGD). More information is needed in order to justify
a permitted flow increase to 0.99 MGD. Specifically, the document should contain the contract (or
other binding document, which includes the number of units proposed) that demonstrates that
service will be provided to the subdivisions specified in the service area and that those subdivisions
commit to transfer their wasteflow to Bradfield Farms W WTP. Additionally, the document should
state if CWS will tie -on the Lamplighter Subdivision. Because there is possibility of connection to a
regional system within 5 to 10 years, the flow justification should be documented based on 5, 10,
15, and 20-year projections. The Division cannot expand flow based on speculation of commitment
for service.
2. Local Government Sign -Off. Any proposed subdivision must have local government sign -off to
ensure that proposed developments conform to any local zoning requirements.
3. Regional Wastewater Systems. The document should provide a letter from each regional system
(both CMU and WSACC) stating that service cannot/will not be provided to the proposed service
area. Documentation should also be provided as to when service may be available. The document
should state the distance to both regional system lines and the capacity (or lack of to
accommodate any proposed flow (if the distance is over 5 miles to any line, no cost estimate has to
be completed).
1617 MAIL SERVICE CENTER, RALDOH, NORTH CAROLINA 27699-1617 -TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

Mr. Martin Lashua .-
Page 2 of 4
4. Documentation of Non -discharge Options. The EAA states that there are some septic systems in
use within the area. The EAA should state and cost -out the feasibility of septic systems. The EAA
may account for loss of opportunity costs for the additional lot size that would be required with
septic systems. The document mentions a golf course development; feasibility of the golf course
for re -use of wastewater should be investigated.
5. Water Quality Model. Because of the outstanding issues to be resolved, the water quality model for
this discharge has not been performed. As you are aware, there are many discharges in this area
that must be accounted for within the framework of the model. Instream data for Lamplighter
Subdivision, as well as Bradfield Farms Subdivision, have been reviewed. During the past 2 years,
Lamplighter has recorded some upstream values below the dissolved oxygen (D.O.) standard of 5
mg/l. Instream D.O. values for Bradfield Farms Subdivision have not indicated values below the
standard during the past 2 years. The Division will be reviewing this data more closely in
development of the model, should the expansion prove necessary.
McKee Creek, in the Yadkin River Basin, is listed on the state's 303d list for impaired waters. The
cause of impairment is fecal colifonn, likely due to various sources. The EPA is developing a TMDL
for fecal coliform on McKee Creek. Because the NPDES permits require fecal coliform limits, the
development of the TMDL will likely not affect the point source requirements already in place.
Other uses may be affected, however.
You may contact Susan A. Wilson at (919) 733 - 5083, ext. 510 should you have further
questions regarding the project.
Sincerely,
Ad A. Goodrich, Supervisor
NPDES Unit
cc: Central Files
Mooresville Regional Office, Water Quality Section
Betsy Albright, Modeling/TMDL Unit
Dale Stewart, P.E. LandDesign Engineering
223 North Graham Street
Charlotte, NC 28202
NPDES file

. • Mr. Martin Lashua
Page 3 of 4
APPENDIX A
Comments, by Sections
Section II.
Provide the contract (portion of, or other signed documentation) with T.M. One, Inc. As part of this,
provide documentation that T.M. One will develop 600 units. Also, reconfirm the flow of 0.225 MGD -
should this be 0.216 MGD?
Provide any documentation of service agreements for the Larkhaven Golf Course.
Has service to Lamplighter Subdivision been considered? Please document that this has been
considered and if not connected, state why.
Section IV.
4.02. Reference should be made for Appendix D (instead of Q.
Has other land been platted for development (besides T.M. One and Larkhaven) within the Bradfield
Farms service area? . What is the scope of the adjacent land around Bradfield Farms and how is the
assumption made that this land will be developed? The speculation on flow in Appendix D is based on
all land in the drainage area being platted for subdivision development, please justify. You may wish
to include information on the build -out of the surrounding area during the previous 5 and 10 year
period.
Section V.
5.02. As stated in the letter, documentation must include letters from both CMU and WSACC as to
the availability of service and when service may be possible.
Please document the distance from the existing lines, including trunk lines.
5.03.02. For land application (or spray irrigation of wastewater) total land required and cost should be
included. As stated in the Division's EAA guidance, you may use county soils maps (for existing
facilities), using best case loading rates to estimate land requirements. This should be done for the
requested expansion phase and must include the 5 day stabilization/ 30 day storage requirement if no
treatment is provided, but in any case to include the minimum 30 day storage requirement. Possible
re -use of the treated wastewater onto the Larkhaven Golf Course should also be included.
A Special Use Permit may not be needed if most could be included in Mecklenburg County.
5.03.05. As stated in the letter, although septic systems may not be feasible, the cost should be
included in the document. Loss of opportunity cost can be accounted for within the cost analysis as
well (i.e., loss of revenue of the developer should lot sizes have to be increased to accommodate the
septic system area and required repair area) .
5.04. Modify this to reflect all alternatives.
Section VI.
6.01 B. As stated previously, potential areas for re -use of wastewater should also be documented.
Traditionally, cost estimates are based on the 20 year life of the project. However, since service to this
area may be provided within 5 to 10 years, please compare costs and document over 5 years, 10 years,
and 20 years.
2. - Document the source of the land cost/acre.
3. - Document the loading rate source (as stated previously, existing facilities may use county soils
maps with the best -case loading rates).

Mr. Martin Lashua
Page 4 of 4
Appendix B.
Is the Tory Homes section and the commercial area built? If not, please state when those areas will be
completed.
Appendix E.
Please reference costs for cost estimates used in both the capital costs and O&M costs.
Alternate C. Please document total land estimate for spray, as stated previously. Also document piping
costs. Please reference Site Maintenance costs.

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BRRDFIELD FRRMS WRTER CDMPRNY
RN BFFILIBTE OF
lUITUL17IIIES, ]INC.
Regional Office:
5781 Westpark Or„ Suite 101
PO Buk 248988
Charlotte, NC 28224
Telephone: [phone]
FRR: [phone]
Mr. David Goodrich, Supervisor
NPDES Unit
Division of Water Quality
NC DENR
1617 Mail Service Center
Raleigh, NC 27699-1617
October 17, 2001
Re: Bradfield Farms WWTP Expansion — Proposed
NPDES NCO064734
Dear Mr. Goodrich,
Please find enclosed three (3) copies of the Preliminary Engineering Report and an
Application to increase our permitted flow limit for the above referenced facility.
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As you know from our past meeting, correspondence and discussions, it is our desire to
expand this facility to accommodate development needs in the area near this plant. It is our
intent and request to expand our facility by increasing our current NPDES permit from
presently approved 0.7 MGD to proposed 0.99 MGD. We feel our report clearly reflects an
immediate need for service in our area with no other viable alternatives. While municipal
expansion will occur, it will not happen any time soon. We have contacted Charlotte -
Mecklenburg Utility Department (CMU) and the Water and Sewer Authority of Cabarrus
County (WSACC). Both municipalities have indicated intent to expand into this area, but no
commitments can be made and it is anticipated a 5-10 year delay before any actual activation
of such infrastructure can be expected. It is our position that we can act now to provide this
service and should not be restricted or hindered by proposed municipal expansion.
We believe the enclosed report to be thorough and comprehensive. However, if you need any
additional information, please do not hesitate to call me in our Charlotte Office at
704-525-7990 (Ext. 216).
We hope to expedite this process and would appreciate your prompt attention.
s always, your consideration is greatly appreciated.
incerel
Martin Lashua
Regional Manager
Enclosure
CC: Mr. Carl Daniel
Mr. Dale Stewart — Land Design
Mr. Steve Livitis — Kilpatrick, Stockton L.L.P.

LM
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 NC 0064734
(if known)
Please print or type
1. Mailing address of applicant/permittee:
Facility Name Bradfield Farms Wastewater Treatment Plant
Owner Name Bradfield Farms Water Company
Street Address 5701 Westpark Drive, Suite 101
City Charlotte
State North Carolina
ZIP Code 28217
Telephone Number ( 704) 525 - 7990
Fax Number (704) 525 - 8174
e-mail Address Lashua,[e-mail]
2. Location of facility producing discharge:
Name (If different from above)
Facility Contact Person Martin Lashua
Street Address or State Road 4250 John Bostar Road
City / Zip Code Harrisburg, NC
County Cabarrus
Telephone Number (704) 525 - 7990
3. Reason for application:
Expansion/Modification * xxxx Existing Unpermitted Discharge
Renewal New Facility
* Please provide a description of the expansion/modification:
Utility desires to increase the permit from currently permitted 0.7 MGD to proposed 0.99 MGD
4. Description of the existing treatment facilities (list all installed components with
capacities):
Influent pump station, bar screen and splitter box. Two (2) parallel 0.23 MGD extended
aeration WWTP's each with equalization basin, aeration basin, secondary clarifier, sludge
holding tank, chlorine contact tank, chlorination and traveling bridge filter. Each plant
Equipped with flow measurement device. One combined flow outfall.
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NPDES PERMIT 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 Number of Employees
Commercial Number of Employees
Residential xxxx Number of Existing Homes 1161
School Number of Students/Staff
Other
Describe the source(s) of wastewater (example: subdivision, mobile home park, etc.):
Subdivision
6. Number of separate wastewater discharge pipes (wastewater outfalls):
One
7. If the facility has multiple discharge outfalls, record the source(s) of wastewater for
each outfall:
Not applicable
8. Name of receiving stream(s) (Provide a map showing the exact location of each outfall):
McKee Creek
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.
Martin Lashua
Printed Name of Person Signing.
Signature of Applicant liate 5ignect
North Carolina General Statute 143-215.6(b)(2) 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 under Article 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.)
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