NC0064734_Staff Comments_20020913

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Bradfield Farms WWTP Expansion
Subject: Bradfield Farms WWTP Expansion
Date: Thu, 15 Aug 2002 18:36:30 -0400
From: Martin Lashua <[e-mail]>
Reply -To: lashua—[e-mail]
Organization: Carolina Water Service Inc.
To: "Wilson, Susan" <[e-mail]>
CC: "Stewart, Dale" <[e-mail]>
Dear Susan,
I hope you are doing well.
I did get your application return dated 5/29/02. Thank you for your
time in review of the application. We know your Unit is very busy and
short staffed.
We have been discussing how we should respond to your requests.
Needless to say, we are disappointed with your Division's and Unit's
position on this matter and your demand for extraneous information
clearly intended to favor - and with clear prejudice for - municipal
service.
Our goal is to provide utility service to an area that can not be served
by other means for the near future. There is demand now and we feel we
can meet that demand. Municipal service is not available nor will it be
for many years. We are at a loss to understand why flow going through a
single regional facility seems preferred to several other smaller, well
run facilities. It is an ecological fallacy that flow going through one
plant - with a single very heavy flow to a single point in the stream -
can possibly be better environmentally that several point sources over a
wider range of stream. Clearly, the receiving waters can absorb impact
from several different well dispersed areas rather than a single large
one.
I think our application and EAA has done a good job of presenting the
options. However, we feel we may have another means of obtaining the
same goal that will be a much better solution for all parties. After
careful review of the actual flows from the WWTP for the last two years
and of your rules, we feel we have sufficient data to request a flow
reduction in the system. This seems like a win win solution for both
DWQ and our company. By obtaining a flow reduction, we can gain more /
connections with the existing NPDES permit and will not need a flow
increase nor burden you with reams of data to try and prove our case.
Our engineer - Dale Stewart of Land Design Inc. - and I would very much
like to meet with you as soon as possible to discuss this option and to
make sure we are applying the rule correctly to meet your requirements
for the flow reduction. I hope you will agree the benefit of this
approach - it will alleviate a lot of headaches all around and makes it
very simple.
If you would have some time the week of August 26th, that should give us
enough time to adjust our schedules to come and meet with you. Let us
know if we could inconvenience you for a personal meeting.
Thanks in advance for your attention and consideration. As always, your
assistance is appreciated.
Martin Lashua
Bradfield Farms Water Co.
Carolina Water Service Inc. of NC
0
.0U9
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I oft Tii'rr UPP'vR- l0* �(LE? vzt id
8/15/02 9:01 PM

[Fwd: Bradfield Fauns W WTP Expansion]
i3TO (I : ab
Subject: [Fwd: Bradfield Farms WWTP Expansion]
Date: Fri, 23 Aug 2002 08:11:24 -0400 13T� ?jp
From: Kim Colson <[e-mail]>
To: Susan A Wilson <[e-mail]
CAA 2 '—,Jr ( ZIff
Susan - the 12th or 13th work best for me. KC
Subject: Re: Bradfield Farms W WTP Expansion
Date: Thu, 22 Aug 2002 17:18:26 -0400
From: Martin Lashua <[e-mail]>
Reply -To: lashua—[e-mail]
Organization: Carolina Water Service Inc.
To: Susan A Wilson <[e-mail]>
CC: "Colson, Kim" <[e-mail]>, "Stewart, Dale" <[e-mail]>
Dear Susan,
Dale Stewart and I could come up to visit with you and/or Kim on September 9th,
12th, 13th or 16th. Please advise if one of these dates works best and what
time_ Preferably late morning (circa 11:00 a.m.) or early afternoon (circa 1
p.m. to 2 p.m.) to allow us travel time from Charlotte.
Thanks again for your efforts.
Martin
Susan A Wilson wrote:
> Martin -
> Thanks for your note. You are correct in that it is getting more and more
> difficult for new or expanding facilities, of any type, to be permitted due
> to more stringent requirements at both the state and federal level, as well
> as greater scrutiny from interested parties.
> I'd be happy to sit down and discuss the flow issue with you.
> Unfortunately, I'll not be able to meet the week of the 26th. The earliest
> date for me will probably be the week of the 9th of September or later. I'm
> Copying Kim Colson (Non -discharge Permitting Unit) on this as his folks, I
> believe, usually do reviews for flow adjustments and I'd like for one of
> them to be able to attend the meeting (or you can meet with them separately,
> if you'd like, if they can meet sooner than I can). If you and Dale would
> throw out some dates that you will be available, I'll work on getting a
> meeting arranged (or feel free to solicit Kim yourself).
> Susan
> Martin Lashua wrote:
> > Dear Susan,
> > I hope you are doing well.
> > I did get your application return dated 5129102. Thank you for your
> > time in review of the application. We know your Unit is very busy and
> > short staffed.
> > We have been discussing how we should respond to your requests.
1 of 3 8/23/02 9:33 AM

[Fwd: Bradfield Farms WWTP Expansion]
> > Needless to say, we are disappointed with your Division's and Unit's
> > position on this matter and your demand for extraneous information
> > clearly intended to favor - and with clear prejudice for - municipal
> > service.
> > Our goal is to provide utility service to an area that can not be served
> > by other means for the near future. There is demand now and we feel we
> > can meet that demand. Municipal service is not available nor will it be
> > for many years. We are at a loss to understand why flow going through a
> > single regional facility seems preferred to several other smaller, well
> > run facilities. It is an ecological fallacy that flow going through one
> > plant - with a single very heavy flow to a single point in the stream -
> > can possibly be better environmentally that several point sources over a
> > wider range of stream. Clearly, the receiving waters can absorb impact
> > from several different well dispersed areas rather than a single large
>>one.
> > I think our application and EAA has done a good job of presenting the
> > options. However, we feel we may have another means of obtaining the
> > same goal that will be a much better solution for all parties. After
> > careful review of the actual flows from the WWTP for the last two years
> > and of your rules, we feel we have sufficient data to request a flow
> > reduction in the system. This seems like a win win solution for both
> > DWQ and our company. By obtaining a flow reduction, we can gain more
> > connections with the existing NPDES permit and will not need a flow
> > increase nor burden you with reams of data to try and prove our case.
> > Our engineer - Dale Stewart of Land Design Inc. - and I would very much
> > like to meet with you as soon as possible to discuss this option and to
> > make sure we are applying the rule correctly to meet your requirements
> > for the flow reduction. I hope you will agree the benefit of this
> > approach - it will alleviate a lot of headaches all around and makes it
> > very simple.
> > if you would have some time the week of August 26th, that should give us
> > enough time to adjust our schedules to come and meet with you. Let us
> > know if we could inconvenience you for a personal meeting.
> > Thanks in advance for your attention and consideration. As always, your
> > assistance is appreciated.
> > Martin Lashua
> > Bradfield Farms Water Co.
> > Carolina Water Service Inc. of NC
> > 704-525-7990 ext. 216
Division of Water Quality
DENR
2 of 3 8/23/02 9:33 AM

Re: Bradfield Farms WWTP Expansion
Subject: Re: Bradfield Farms WWTP Expansion
Date: Thu, 22 Aug 2002 17:18:26 -0400
From: Martin Lashua <[e-mail]>
Reply -To: lashua—[e-mail]
Organization: Carolina Water Service Inc.
To: Susan A Wilson <susan.a.wilson @ncmail.net>
CC: "Colson, Kim" <Kim.Col son @ncmail.net>, "Stewart, Dale" <[e-mail]>
Dear Susan,
Dale Stewart and I could come up to visit with you and/or Kim on September 9th,
12th, 13th or 16th. Please advise if one of these dates works best and what
time. Preferably late morning (circa 11:00 a.m.) or early afternoon (circa 1
p.m. to 2 p.m.) to allow us travel time from Charlotte.
Thanks again for your efforts.
Martin
Susan A Wilson wrote:
> Martin -
> Thanks for your note. You are correct in that it is getting more and more
> difficult for new or expanding facilities, of any type, to be permitted due
> to more stringent requirements at both the state and federal level, as well
> as greater scrutiny from interested parties.
> I'd be happy to sit down and discuss the flow issue with you.
> Unfortunately, I'll not be able to meet the week of the 26th. The earliest
> date for me will probably be the week of the 9th of September or later. I'm
> copying Kim Colson (Non -discharge Permitting Unit) on this as his folks, I
> believe, usually do reviews for flow adjustments and I'd like for one of
> them to be able to attend the meeting (or you can meet with them separately,
> if you'd like, if they can meet sooner than I can). If you and Dale would
> throw out some dates that you will be available, I'll work on getting a
> meeting arranged (or feel free to solicit Kim yourself).
> Susan
> Martin Lashua wrote:
> > Dear Susan,
> > I hope you are doing well.
> > I did get your application return dated 5129102. Thank you for your
> > time in review of the application. We know your Unit is very busy and
> > short staffed.
> > We have been discussing how we should respond to your requests.
> > Needless to say, we are disappointed with your Division's and Unit's
> > position on this matter and your demand for extraneous information
> > clearly intended to favor - and with clear prejudice for - municipal
> > service.
> > Our goal is to provide utility service to an area that can not be served
> > by other means for the near future. There is demand now and we feel we
> > can meet that demand. Municipal service is not available nor will it be
> > for many years. We are at a loss to understand why flow going through a
> > single regional facility seems preferred to several other smaller, well
1 of 2 8/23/02 9:15 AM

Re: Bradfield Farms WWTP Expansion ,
> > run facilities. It is an ecological fallacy that flow going through one
> > plant - with a single very heavy flow to a single point in the stream -
> > can possibly be better environmentally that several point sources over a
> > wider range of stream. Clearly, the receiving waters can absorb impact
> > from several different well dispersed areas rather than a single large
>>one.
> > I think our application and EAA has done a good job of presenting the
> > options. However, we feel we may have another means of obtaining the
> > same goal that will be a much better solution for all parties. After
> > careful review of the actual flows from the WWTP for the last two years
> > and of your rules, we feel we have sufficient data to request a flow
> > reduction in the system. This seems like a win win solution for both
> > DWQ and our company. By obtaining a flow reduction, we can gain more
> > connections with the existing NPDES permit and will not need a flow
> > increase nor burden you with reams of data to try and prove our case.
> > Our engineer - Dale Stewart of Land Design Inc. - and I would very much
> > like to meet with you as soon as possible to discuss this option and to
> > make sure we are applying the rule correctly to meet your requirements
> > for the flow reduction. I hope you will agree the benefit of this
> > approach - it will alleviate a lot of headaches all around and makes it
> > very simple.
> > If you would have some time the week of August 26th, that should give us
> > enough time to adjust our schedules to come and meet with you. Let us
> > know if we could inconvenience you for a personal meeting.
> > Thanks in advance for your attention and consideration. As always, your
> > assistance is appreciated.
> > Martin Lashua
> > Bradfield Farms Water Co.
> > Carolina Water Service Inc. of NC
> > 704-525-7990 ext. 216
2 of 2 8/23/02 9:15 AM

Re: Bradfield Farms
Subject: Re: Bradfield Farms
Date: Tue, 27 Aug 2002 17:08:12 -0400
From: Martin Lashua <[e-mail]>
Reply -To: lashua_cws @bellsouth.net
Organization: Carolina Water Service Inc.
To: Susan A Wilson <[e-mail]>
CC: Kim Colson <Kim.Colson @ ncmail. net>, [e-mail],
Dave Goodrich <Dave.Goodrich @ncmail.net>,
Valery Stephens <Valery.Stephens @ncmail.net>,
Christie Jackson <Christie.Jackson @ncmail.net>
Susan,
Dale and I confirm and will see you and Kim on Friday 9/13 at 11:00 a.m.
'thanks for your time!!
Susan A Wilson wrote:
> Martin & Dale -
> I've set up the meeting regarding Bradfield Farms for 11:00 am on
> Friday, September 13th. It will be in the 9th floor conference room of
> the Archdale building. Kim Colson plans to attend. (not sure Dave will
> be able to attend).
> If this date/time do not work for you - please go through Valery
> Stephens or Christie Jackson to reschedule. (both are cc'd on this).
> I'll be out of the office from 8127 through 915. Thanks.
1 of 1 9/5/02 9:15 AM

Bradfield Farms (NC0064734)
Subject: Bradfield Farms (NC0064734)
Date: Wed, 28 Aug 2002 15:23:25 -0400
From: Michelle Woolfolk <Michelle.Woolfolk@ ncmail.net>
Organization: NCDENR-Division of Water Quality
To: [e-mail]
Seems you have these files. Can you please check the permit for the limits on
fecal coliform. EPA has written a TMDL for the McKee Creek watershed and stated
that this permit has a 400 cfu/100mL limit that is being violated.
Thanks.
Michelle
MICHELLE WOOLFOLK
DWQ PLANNING BRANCH
NCDENR
1617 MAIL SERVICE CENTER
RALEIGH NC 27699-1617
PH:919/733-5083 x505 FX:919/715-2941
[e-mail]
1 of 1 9/5/02 9:41 AM

Bradfield Farms Water Company
Bradfield Farms WWTP
NPDES No. NC0064734
Peak Flow per Connection Study
July 2001 - June 2002
Date
Recorded
Flow
MGD
Approx.
Time
Hours
Peak Flow per
Connection
Gallons
Adjusted
2 Flow
FMGDw
Adjusted
24-Hour Peak
Flow per
Connection
Gallons
March 7, 2002
.2860
33.50
242
.2049
174
January 2, 2002
.2780
25.00
236
.2669
226
March 29, 2002
.2500
26.00
212
.2308
196
August 20, 2001
.2220
27.50
188
.1937
164
April 1, 2002
.2140
28.50
181
.1802
153
March 30, 2002
.2100
22.50
178
.2240
190
June 7, 2002
.2100
27.00
178
.1867
158
November 5, 2001
.2020
27.50
171
.1763
149
April 22, 2002
.2000
26.50
169
.1811
154
November 29, 2001
.1980
23.50
168
.2022
171
October 28, 2001
.1980
27.25
168
.1744
148
November 12, 2001
.1960
27.50
166
.1711
145
September 11, 2001
.1940
19.50
1 164
.2388
202
March 28, 2002
.1920
18.00
163
.2560
217
February 18, 2002
.1920
27.25
163
.1691
143
March 18, 2002
.1900
26.00
161
.1754
149
March 17, 2002
.1900
27.00
161
.1689
143
June 10, 2002
.1880
26.25
159
.1719
146
June 5, 2002
.1880
27.50
159
.1641
139
January 14, 2002
.1860
23.50
158
.1900
161
June 21, 2002
.1860
25.00
158
.1786
151
May 22, 2002
.1860
27.00
158
.1653
140
June 24, 2002
.1860
27.00
158
.1653
140
April 14, 2002
.1840
23.50
156
.1879
159
May 30, 2002
.1840
24.50
156
.1802
153
April 15, 2002
.1820
19.50
1 154
.2240
190
November 23, 2001
.1780
23.00
151
.1857
157
October 29, 2001
.1760
22.75
149
.1857
157
June 6, 2002
.1760
23.00
149
.1837
156
June 16, 2002
.1740
19.50
147
.2142
181
March 14, 2002
.1740
23.00
147
.1816
154
June 15, 2002
.1740
25.00
147
.1670
1 142
January 4, 2002
.1720
24.50
146
.1685
143
April 7, 2002
.1700
20.50
144
.1990
169
March 21, 2002
.1700
23.75
144
.1718
146
March 1, 2002
.1700
24.25
144
.1682
143
Average
165
161
t 1 ` %0.�Sbvs ��°r`

ENR-ENVIRONMENTAL MANAGEMENT COMMISSION TI SA: 02H.0200
Stadiums, Auditoriums, Theaters, Drive-ins 5
gal/seat or space
Stores, shopping centers and malls -- Note: if food service is included,
add 40 gal/seat 120
gal/1000 R2
Swimming Pools and Bathhouses 10
gal/person
(3) An adjusted daily sewage flow may be granted upon a showing that a sewage system is
adequate to meet actual daily water consumption from a facility included in
Subparagraph (1) or (2) of this Paragraph. Documented, representative data from that
facility or a comparable facility shall be submitted, consisting of at least 12 consecutive
monthly total water consumption readings and daily total water consumption readings for
at least 30 consecutive days of water use. The daily readings shall be taken during a
projected peak sewage flow month. The adjusted design daily sewage flow shall be
determined by taking the numerical average of the daily readings that fall within the
upper 10 percent of the daily readings when ranked in descending order.
(m) For Treatment and Disposal of Soil Containing Petroleum Products:
(1) Landfarming of Soils Containing Petroleum Products at Minimum Rates. Petroleum
contaminated soils shall be incorporated into the native soils of the receiver site
immediately upon application. Liming, fertilization, and aeration of the soils mixture
shall be optional, unless otherwise required by the Division. Subsequent application of
petroleum contaminated soils onto the same receiver site shall not occur for at least 18
months from the date of the most recent application of petroleum contaminated soils and
shall cause the receiver site to be reclassified as a "dedicated remediation site" unless the
permittee or applicant can demonstrate, through soil sampling and contaminant analytical
procedures approved by the Department, that the petroleum contaminant level in the
upper eight inches of the receiver site soils is below analytical detection levels;
(2) Landfarming of Soil Containing Petroleum Products at Conventional Rates.
Landfarming of soils containing petroleum product at an application thickness greater
than one inch shall require fertilization, liming, and aeration of the native soils and
petroleum contaminated soils mixture as approved by the Division. Application
thickness shall be based upon the nature of the receiver site soils, depth to the seasonal
high water table, the intended cover crop, and the source of contamination, in accordance
with procedures approved by the Division. Operation of the landfarming program shall
not result in contravention of classified groundwater or surface water quality standards.
Subsequent application of petroleum contaminated soils onto the same receiver site shall
not occur for at least 18 months from the date of the most recent application of petroleum
contaminated soils and shall cause the receiver site to be reclassified as a "dedicated
disposal site" unless the permittee or applicant can demonstrate, through soil sampling
and contaminant analytical procedures approved by the Department, that the petroleum
contaminant level in the upper eight inches of the receiver site soils is below analytical
detection levels;
(3) Containment and Treatment of Soil Containing Petroleum Products:
(A) A containment structure designed to bioremediate or volatilize soil containing
petroleum products shall be constructed of either a synthetic liner of at least 30
mils thickness or of a one foot thick liner of natural material, compacted to at
least 95 percent standard proctor dry density and with a permeability of less than
1 x 10 7 cm/sec.
(B) The bottom of the containment structure shall be at least three feet above the
seasonal high water table or bedrock.
(C) A leachate collection system must be installed in order to prevent runoff from
the petroleum contaminated soils within the containment structure, or steps
taken to avoid accumulation of stormwater within the containment structure.
(4) Disposal of Petroleum Contaminated Soils at Dedicated Sites. Subsequent applications
of petroleum contaminated soils at dedicated sites shall not recur until such time as it can
NORTH CAROLINA ADMINISTRATIVE CODE Effective April 1 2001 Page 39 of 44

EFFLUENT
NPDFe t NO- C 00 � Discharge No. 00 / Month 3 L(y�2 Year ,00 2
Facilityty Name
amName _Bgjl i,,e jd Figat,76 Class �'T County C� J311/2 cc 5
Operator in Responsible Charge (ORC) _ 51ei,c (f& %/ e�Ls Grade T Phone 70 `/ -S2 - `7 990
Certified Laboratories (1) /��i5� kmb tyc (2)
CHECK BOX IF ORC HAS CHANGED ❑ Person(s) Collecting Samples .5'fe.t-e
Mail ORIGINAL and ONE COPY to;
ATIN: CENTRALFnm_ .
DIV. OF WATER QUAuTY X '7
D13NR --,,
(SIGNATURE OF OPfiRATOR IN RESPONSIBLE CHARGE) DA
1617 MAIL SERvicE CENTER BYTms SIGNATURE, I CERTII'Y THAT Tms REPORT Is ACCURATE AND CGMPLETE TO
RALEIOH, NC 27699-1617 THEERST of MY KNOWLEDGE.
50050
00010
00400
50060
00310
00610
00530
31616
00300
00600
00665
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EFFUCENT
NPDES PERMIT NO. e DISCHARGE NO. 00 MONTH /VA.Z YEAR 200 2-
FACILITY NAME B.ys CLASS L COUNTY_ e ghoAerr5
OPERATOR IN RESPONSIBLE CHARGE (ORC)_$�i 2 OSL 7& j, GRADE -J—/ PHONE_ 5 - tj�0
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CHECK BOX IF ORC HAS CHANGED [] PERSON(S) COLLECTING SAMPLES _5y_,?.�� C,4� exs
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES
DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH NC 27699-1617
BY THIS SIGNATURE, I CERTIFY TIIAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
DWQ Form MR-1 (01100)

EFFLUENT
NPDES PERMIT NO. DISCHARGE NO. OP (( MONTH YEAR i�O04
FACILITY NAME N Aw.¢m s CLASS�l _CO TY C.tt�@`'4'Z
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ATTN: CENTRAL FILES x l .!/J Z� 5 DL
DIVISION OF WATER QUALITY rSICWTURE OF OPERNTOR IN RESPONSIBLE CHARGE) DATE
1617 MAIL SERVICE CENTER BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
RALEIGH NC 27699-1617 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
00400
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EFFLUENT
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ATTN: CENTRAL FILES
DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH NC 27699-1617
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
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1617 MAIL SERVICE CENTER
RALEIGH NC 27699-1617
EFFLUENT
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DWQ Form MR-1 (01/00)

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Facility Name ,BR q�(
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DENR
1617 MAIL, SERVICE CENTER
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EFFLUENT
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DWQ. Form Nilt-I (01/00)

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Facility Name . d&A
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DENR
1617 MAm SERVICE CENTER
RALWH, NC 27699-1617
EFFLUENT
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DWQ Form MR-1 (01/00)

NPDES Perrnit No. [ 00,
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DENR
1617 MAIL SER FME CENTER
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