HomeMy WebLinkAboutNC0073318_Fact Sheet_20230703DENR/DWR
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO073318
2023 Renewal
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303 (d) listed water, toxicity testing, instream monitoring, compliance concerns).
Facility and Stream Information
Applicant/Facility Name:
Clarke Utilities, Inc. Whippoorwill Valley WWTP
Applicant Address:
223 Hwy 70 East; Suite 115; Garner, NC 27529
Facility Address:
5634 Chimney Swift Drive; Wake Forest, NC
Facility Class Permit Status:
Grade II Biological
WPCS / Renewal
Permitted Flow [as built]
0.2 [0.05] MGD
Type of Waste
100% Domestic
Receiving Stream
Smith Creek
Stream Class / ID
C; NSW / 27-23-(2)
River Basin
Neuse
Subbasin
03-04-02
HUC
030202010702
USGS Too
Wake Forest D24NE
7Q10 Sum Win cfs
0.15 1.3
30Q2 cfs
2.2
Avg. Stream Flow cfs
24
IWC % s/w [as -built]
68 19; 34 6
County
Wake
Regional Office
RRO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / April 11, 2023
Does permit need daily max NH3 limits?
Yes - Already in permit
Does permit need TRC limits/language?
Yes - Already in permit
Does permit have toxicity testing?
No
Does permit have Special Conditions?
Yes -Calculation & Reporting of TN; TN
Allocations; and Neuse Re -opener
Does permit have instream monitoring?
Yes - Temp and DO
Stream on 303 d List? For w arameter?
Only state-wide mercury
Any compliance concerns?
See discussion below
Any modifications since lastpermit?
None noted in the application
New expiration date:
January 31, 2028
FACILITY OVERVIEW:
This facility is 100% domestic waste and treats a subdivision serving 156 residential connections and a
population of 378 people. The facility has a permitted flow of 0.2 MGD and as built flow rate of 0.05 MGD. The
treatment system includes the following wastewater treatment components:
• Influent pump station
• Influent bar screen
• Surge basin
• Aeration basin
• Sludge holding chamber
• Dual clarifiers
• Chemical phosphorus removal and pH adjustment
• Tablet chlorination
• Tertiary filter
• Tablet de -chlorination with post -aeration
APPLICATION
The application does not indicate any changes in the facility or treatment since the last modification of the
permit in 2018. The treatment system is operated by Clarke Utilities, Inc. The annual average daily flow is
indicated as 0.029 MGD over the last two years, so the facility is operating at well below its designed and
permitted capacity.
INSPECTION
The most recent inspections occurred on February 2, 2023. Recent DMR violations were discussed and the
report noted that the sludge holding tank was full, but was being pumped within the next week. The inspection
did not note any issues of concern with the facility.
MONITORING DATA REVIEW:
Parameter Units
Min
Max
Avg
Permit Limit
Comments
Flow (MGD)
0.00
0.29
0.03
0.05 MA
Total Monthly Flow MG
0.7
1.0
0.9
BOD m L Summer
1.0
7.7
1.5
5 MA 7.5 DM
One Violation
BOD m L Winter
1.0
28.0
2.7
10 MA 15 DM
Two violations, one enforcement
TSS m L
1.3
18.0
2.1
30 MA 45 DM
Temp C - Upstream
3.2
31.7
17.5
Temp C - Effluent
10.1
27.6
19.1
Temp C - Downstream
3.2
29.0
17.5
NH3-N m L Summer
0.0
12.2
0.8
2 MA 10 DM
Three violations; one enforcement
NH3-N m L Winter
0.0
13.3
1.3
4 MA 20 DM
Two violations, one enforcement
DO m L - Upstream
1.9
12.1
6.5
DO m L - Effluent
5.2
15.3
7.8
5 DA
DO m L - Downstream
2.2
12.2
6.8
-
Fecal Coliform # ml
0.5
9700.0
51.2
200 MA 400 DM
Two violation and one enforcement
TRC L
0.5
47.0
17.2
28 DM
No values above 50 enforcement value
Total Nitrogen m L
0.8
14.7
3.7
-
TN Monthly lbs month
1.5
98.8
26.4
TN Annual lbs ear
229.7
1 441.1
325.9
Total Phosphorus m L
0.1
11.3
1.4
2 QA
Two violations, one enforcement
H su
6.9
8.1
N/A
>-6 and <-9
MA -Monthly Average DM - Daily Max QA -Quarterly Average DA - Daily Average Summer - April through Oct Winter - Nov through March
The data reviewed for the renewal is from February 2018 through January 2023.
REVIEW OF PERMIT LIMITS:
Flow - The facility is operating on average at around 58% of the as -built flow allowed by the permit. None of
the 60 monthly average values was above 0.034 MGD. These data assessments included removing one outlier
value of 344 MGD reported in December 2022. This value was four orders of magnitude higher than other
reported values and was obviously inaccurate.
BOD / Fecal- There were five violations of BOD and Fecal limits with two of these resulting in enforcement
actions.
TSS- The were no violations for TSS in this permit cycle.
Ammonia (NH3-N)- There were four violations of NH3-N limits. Two of these violations led to enforcement
actions. The Waste Load Allocation spreadsheet included in this Fact Sheet shows allowable NH3-N limits that
Whippoorwill Valley WWTP Fact Sheet
NPDES Renewal 2023 -April 11, 2023
Page 2
are a bit higher than those included as limits in the permit. The 2 & 4 mg/L limits in the permit are a result of
previous modelling efforts that assessed overall impacts to the surface waters and will, therefore, remain in the
permit.
Nutrients
Total Nitrogen load numbers over the permit cycle included a maximum annual load of slightly over 440 lbs.
This annual load is well below that discharge allocation load of 4044 lbs. Total Phosphorous numbers did
include two quarterly values that exceeded the 2 mg/L limit. These values resulted in one NOV and one
enforcement action. The permit effluent tables previously included an eDMR code of 00600 for the TN loading
numbers. These codes have been corrected to QM600 for monthly load and QY600 for annual load.
COMPLIANCE:
This facility had twelve (12) violations during the permit term. Five of these violations lead to enforcement
actions with penalty assessments. The enforcement actions totaled $1,783.66 with $1,501.50 in penalties and
the remainder in enforcement costs. The permittee has failed to pay the last three of these actions with pending
amounts of $1,001.50 in penalties and $202.16 in enforcement costs still owed ($1203.66 total).
FILE HISTORY REVIEW SUMMARY
• Permit was originally issued in August 1988
• June 3, 1988 -Waste Load Allocation (WLA) -Class C; NSW Waters Design flow = 0.2 MGD s7Q10 =0.15
cfs w7Q10 = 1.3 cfs; 30Q2 = 2.2 cfs Avg cfs = 24
Season
BOD5
m L
NH3-N
m L
DO
m L
TSS
m L
Fecal
m L
pH
std units
Summer
5
2
5
30
1,000
6-9
Winter
10
4
5
30
1,000
6-9
The document discussed a recommendation that this facility tie on to the Wake Forest WWTP, but the
owner provided information that he had already talked with the Town about another WWTP (Deer Chase)
in close proximity and the Town was not open to the connection.
September 11, 1990 - Authorization to Construct (ATC) for a 50,000 GPD extended aeration treatment plant
with Bar screen, equalization tank, aeration tank, phosphorous reduction chemical feed system, dual
clarifiers, sludge holding tank, flow recorder, tablet chlorinator with contact chamber, tertiary filtration
units, post -aeration, rip -rap aerator, pipes, pumping, etc.
February 25,1993 WLA - This WLA is done for two flows, 0.05 MGD and 0.2 MGD with 7Q10 numbers the
same as previous. Stream class is C-NSW:
Flow
BODS
NH3-N
DO
TSS
Fecal
pH
Total P
TRC
MGD
m L
m L
m L
m L
m L
std units
m L
µ L
(w)
0.10
5
30
200
6-9
2
Monitor
10(w
4
(w)
0.2
5
30
200
6-9
2
25
10(w
4
Also instream monitoring U,D for DO, Temp, Fecal and Conductivity.
• April 5, 2000 - Permit Renewal. The permit is issued for an as -built flow of 0.05MGD and also contains a
ermitted flow of up to 0.20 MGD with ATC, etc. Facility designated a Class III treatments stem.
Flow
BOD5
NH3-N
DO
TSS
Fecal
pH
Total P
TRC
MGD
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(std units)
(mg/L)
(µg/L)
MA DM
MA
DA
MA DM
MA DM
quarter avg
DM
0.05
(w)
6
30/45
200/400
6-9
2
Monitor
0/ 15(s)
4
0.20
5/7.5(s)
2 (s)
5
30/45
200/400
6-9
2
25
10 15 w
4 w
Whippoorwill Valley WWTP Fact Sheet
NPDES Renewal 2023 — April 11, 2023
Page 3
Permit also required TN monitoring and reporting (2/month) for concentration plus monthly load and
annual load reporting. Instream conductivity and fecal monitoring was removed from the permit. The
permit included a special condition for the calculation of monthly and annual TN mass loads. In the cover
letter for the permit the Division outlined new nutrient requirements based on the newly issued NSW rules.
The facility was advised to begin looking at treatment options for nitrogen reduction. The permit's TP
requirements maintained the 2 mg/L quarterly limit but changed monitoring from quarterly to monthly
with the quarterly average being the average of samples collected during the calendar quarters (January -
March, etc.). This permit, along with others in the Neuse Basin, was held for a period of time while nutrient
issues were addressed in the basin.
• June 19, 2000 - Permit modification to reduce instream monitoring from 3/week to weekly for BOD, TSS,
NH3-N, pH, TRC, DO and fecal in response to correspondence from the Technical Assistance and Certification
Unit indicating the facility should be classified as a Class II treatment system.
• June 25, 2001 - Permit modification to adjust instream monitoring to weekly based on the facility's
designation as a Class II system.
• October 3, 2003 - Permit Renewal. This renewal added daily maximum limits for NH3-N of 10mg/L summer
and 20mg/L winter and modified the TRC limit for the 0.05 MGD flow to 28 µg/L. The permit included
addition of a special condition addressing Annual Limits for TN. The downstream monitoring location was
changed in response to the permittee's request to SR 2044 (Ligon Mill Road).
• January 30, 2004 - Permit modification to make monitoring frequencies for TN and TN components
consistent at 2/month.
• April 13, 2004 - Permit Name/Owner Change from Ira D. Lee and Associates to Clarke Utilities, Inc.
• April 14, 2008 - Permit Renewal - This renewal added a special condition for Total Nitrogen Allocations as
assigned by rule 15A NCAC 2B .0234. The permit also includes updates to the treatment system
components in the Supplement to Permit Cover Sheet.
• July 12, 2013 - Permit Renewal - This renewal does not include the previously added Special Condition on
Annual Limits for Total Nitrogen. The condition was removed because the permit does not include TN mass
limits. TP monitoring frequency was changed to 2/month to be consistent with other nutrient monitoring
requirements. TN was already set at 2/month. The cover letter for this permit noted Smith Creek being
listed as impaired with general language for impaired waters.
• January 6, 2018 - Permit Renewal - This renewal added the electronic submission language and added
regulatory citations.
• January 24, 2019 - Division letter to permittee to note that the January 2018 cover letter for the permit
inaccurately noted that TP had been changed to monitoring only. This was not the case; the permit
maintained the 2.0 mg/L limit and the cover letter was just in error.
PROPOSED PERMIT CHANGES:
• Updated eDMR requirements to be consistent with final EPA rule.
• Added or updated regulatory citations throughout permit as needed.
• Language in paragraph 2 of the Supplement to Permit Cover Page has been adjusted to outline
requirements prior to operating at the 0.20 MGD level.
• eDMR codes for BOD, TSS, NH3-N, TN and TP updated to replace initial 0 with C. Added code for Total
flow - 82220.
• eDMR codes for TN load have been corrected to note QM600 for monthly and QY600 for annual load.
• Footnotes in the effluent tables have been updated with current language where needed.
• In section A.(2), the effluent table for the 0.20 MGD flow, the footnotes were adjusted to correct incorrect
references.
• Permit map information updated.
• Added Special Condition for Nutrient Re -opener in section A.(5.).
Whippoorwill Valley WWTP Fact Sheet
NPDES Renewal 2023 — April 11, 2023
Page 4
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: May 2, 2023
Permit Scheduled Effective Date: August 1, 2023
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett at
bradley.bennettC@ncdenr.gov.
Whippoorwill Valley WWTP Fact Sheet
NPDES Renewal 2023 —April 11, 2023
Page 5
AFFIDAVIT OF PUBLICATION
Account #
Order Number
Identification
Order PO
Amount
Cols
Depth
19489
422814
Print Legal Ad-IPL01234100 - IPLO123410
$549.90
1
51 L
Attention: Wren Thedford STATE OF NORTH CAROLINA
DEPARTMENT OF WATER RESOURCES - RALEIGH COUNTY OF WAKE, COUNTY OF DURHAM
1617 MAIL SERVICE CENTER Before the undersigned, a Notary Public of Dallas
RALEIGH, NC 276991617 County, Texas, duly commissioned and authorized to
administer oaths, affirmations, etc., personally
meagen.benton@ncdenr.gov
appeared Tara Pennington, who being duly sworn or
affirmed, according to law, cloth depose and say that he
Public Notice
or she is Accounts Receivable Specialist of the News &
North Carolina Environmental Man-
Observer Publishing Company, a corporation organized
agement Commission/NPDES Unit
and doingbusiness under the Laws of the State of North
1617 M
1617 Mail Service Center
Raleigh, NC 27699-1617
Carolina, and publishing a newspaper known as The
Notice of Intent Issue a NPDES
News & Observer, Wake and State aforesaid, the said
Wastewater Permit it NC0063746 Deer
Chase WWTP, and NCO073318 Whip-
newspaper in which such notice, paper, document, or
poorwill Valley WWTP The North Caro-
legal advertisement was published was, at the time of
lina Environmental Management Com-
mission proposes to issue a NPDES
each and every such publication, a newspaper meeting
wastewater discharge permit to the
qualifications of Section 1d l all of the requirements an
q q
person(s) listed below. Written com-
ments regarding the proposed permit
597 of the General Statutes of North Carolina and was a
will be accepted until 30 days after
qualified newspaper within the meaning of Section 1-597
qg
the publish date of this notice. The ;
Director of the NC Division of Water
of the General Statutes of North Carolina, and that as
Resources (DWR) may hold a public
such he or she makes this affidavit; and is familiar with
hearing should there be a significant
degree of public interest. Please mail
the books, files and business of said corporation and by
comments and/or information re-
;
reference to the files of said publication the attached
quests to DWR at the above address.
Interested persons may visit the DWR
advertisement for DEPARTMENT OF WATER RESOURCES -
at 512 N. Salisbury Street, Raleigh, NC
RALEIGH was inserted in the aforesaid newspaper on
27604 to review the information on
file. Additional information on NPDES
dates as follows:
permits and this notice may be found
on our website: https://deq.nc.gov/
1 insertion(s) on:
public-notices-hearings,or by calling
published
(919) 707-3601. Clarke Utilities, Inc ;
05/19/23
[223 Hwy 70 East; Suite 115; Garner,
NC 27529] has requested renewal
of NPDES permit NCO063746 for the
Deer Chase WWTP, located in Wake
County. This permitted facility dis-
charges 100% domestic wastewater
to Toms Creek, a class C; NSW water
in the Neuse River Basin. Some of the
parameters in the permit are water
F
quality limited. This discharge may
r
affect future allocations in this seg-
ment of Toms Creek. Clarke Utilities,
Lr
Inc [223 Hwy 70 East; Suite 115; Gar-
ner, NC 27529] has requested renewal
I certify or declare) under penalty of perjury that the
of NPDES permit NCO073318 for the
Whippoorwill Valley WWTP, located in
foregoing is true and correct.
Wake County. This permitted facility
discharges 100% domestic wastewa-
ter to Smith Creek, a class C; NSW
water in the Neuse River Basin. Some
of the parameters in the permit are
water quality limited. This discharge
{Wr
may affect future allocations in this
segment of Smith Creek,
Notary Public in and for the state of Texas, residing in
Dallas County
IPL0123410
May 19 2023
'�"' '• STEPHANIE HATCHER
= - x• ;.
:x: •= My Notary I # 1335YA06
�; e:
E)Orss 4anuary 14, 2026
Extra charge for lost or duplicate affidavits.
Legal document please do not destroy!
Bennett, Bradley
From: Thedford, Wren
Sent: Wednesday, May 17, 2023 6:55 PM
To: Bennett, Bradley; Demery, Cynthia
Cc: Hennessy, John
Subject: Re: Two Permits for Public Notice This Week - Deer Chase (NC0063746) and
Whippoorwill Valley (NC0073318)
Correction, the ad will run on 5/19/23.
From: Thedford, Wren <wren.thedford@deq.nc.gov>
Sent: Wednesday, May 17, 2023 6:37 PM
To: Bennett, Bradley <bradley.bennett@deq.nc.gov>; Demery, Cynthia <cynthia.demery@deq.nc.gov>
Cc: Hennessy, John <john.hennessy@deq.nc.gov>
Subject: Re: Two Permits for Public Notice This Week - Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
Hi Bradley,
I had Cynthia pull the information that was already in Access. The notice will run on 5/18/23 in the N&O.
From: Bennett, Bradley <bradley.bennett@deq.nc.gov>
Sent: Wednesday, May 17, 2023 5:41 PM
To: Thedford, Wren <wren.thedford@deq.nc.gov>; Demery, Cynthia <cynthia.demery@deq.nc.gov>
Cc: Hennessy, John <john.hennessy@deq.nc.gov>
Subject: RE: Two Permits for Public Notice This Week - Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
Wren,
I think I updated all the notice language in the Access database but just in case, here is the language for each of these
usually just use the same language for the paper and website when I put it in access.
Thanks
m
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3629
NC Division of Water Resources
1617 Mail Service Center Email: bradley.bennett@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023.
Employee email addresses may look different, but email performance will not be impacted.
From: Thedford, Wren <wren.thedford@deq.nc.gov>
Sent: Wednesday, May 17, 2023 8:22 AM
To: Bennett, Bradley <bradley. bennett@ncdenr.gov>; Demery, Cynthia <cynthia.demery@deq.nc.gov>
Cc: Hennessy, John <john.hennessy@deq.nc.gov>
Subject: Re: Two Permits for Public Notice This Week - Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
Bradley- Thank you for providing those draft links. Please email the website language. These two permits
would be great for training purposes. We will follow up with you once we've received confirmation from the
newspapers.
Cynthia- Please add these to the list we worked on yesterday. If at all possible, follow the steps from
yesterday's training and contact me via Teams should you have questions.
From: Bennett, Bradley <bradley. ben nett@ncdenr.gov>
Sent: Wednesday, May 17, 2023 8:01 AM
To: Thedford, Wren <wren.thedford@deq.nc.gov>; Demery, Cynthia <cynthia.demery@deg.nc.gov>
Cc: Hennessy, John <iohn.hennessy@deg.nc.gov>
Subject: RE: Two Permits for Public Notice This Week - Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
Wren, Cynthia,
Is it too late to get these public noticed this week? Looks like they didn't go with the notices on May 2"d. Two permits
are Clarke Utilities permit renewal for Deer Chase WWTP (NC0063746) and Whippoorwill Valley WWTP
(NC0073318). The notice language has been updated in Access. I emailed the drafts to Joel Clarke already for his review
last week.
The draft permits are in Laserfiche and the external Laserfiche links are below.
Deer Chase WWTP - NCO063746:
URL: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2773426
Whippoorwill Valley WWTP — NCO073318:
URL: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2773396
m
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3629
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett(o)ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 91h 2023.
Employee email addresses may look different, but email performance will not be impacted.
From: Hennessy, John <john.hen nessy@deg.nc.gov>
Sent: Tuesday, May 16, 2023 5:33 PM
To: Thedford, Wren <wren.thedford@deg.nc.gov>; Demery, Cynthia <cynthia.demerv@deg.nc.eov>; Bennett, Bradley
<bradley. ben nett@ncdenr.gov>
Subject: Fw: Two Permits for Public Notice This Week - Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
I may not have done these. My last notices (other than the 2 for Sergei I did on May 4th) was April 28th.
I think these need to be processed.
John E. Hennessy
Environmental Supervisor 11, Division of Water Resources
North Carolina Department of Environmental Quality Office: (919) 707-3615
6ohn.hennessy@ncdenr.gov
z-4e NOH I H CAHQ INS D
Department of Environmental quality
Email correspondence to and from this address is subjea
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <bradley. ben nett@ncdenr.gov>
Sent: Monday, May 1, 2023 8:45 AM
To: Hennessy, John <iohn.hennessy@ncdenr.gov>; Demery, Cynthia <cynthia.demery@ncdenr.gov>
Subject: Two Permits for Public Notice This Week - Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
John, Cynthia:
Here are two Clarke Utilities permit renewals for this week's public notice. Notice language has been updated in
Access. I will email Joel Clarke the draft permits for his review. The draft permits are in Laserfiche and the external
Laserfiche links are below.
Deer Chase WWTP - NCO063746:
URL: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2773426
Whippoorwill Valley WWTP — NCO073318:
URL: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2773396
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3629
NC Division of Water Resources
1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
Bennett, Bradley
From: JOEL CLARKE <joel@clarkeutilities.com>
Sent: Monday, May 8, 2023 2:45 PM
To: Bennett, Bradley
Subject: [External] Re: Draft Permits for Whippoorwill Valley (NC0073318) and Deer Chase
(NC0063746)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
From: Bennett, Bradley <bradley.bennett@ncdenr.gov>
Sent: Thursday, May 4, 2023 4:26 PM
To: JOEL CLARKE <joel@clarkeutilities.com>
Subject: Draft Permits for Whippoorwill Valley (NC0073318) and Deer Chase (NC0063746)
Mr. Clarke,
I have attached the draft permits for the two Clarke Utilities WWTPs noted in the subject line above. These draft
permits will be going to public notice within the next week. Please take a look at the cover letters and permits for each
and let me know if you have any questions or comments.
Please respond to this email to verify that you received the draft permits and that you were able to download, open
and print the files for your records.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3629
NC Division of Water Resources
1617 Mail Service Center Email: bradley.bennett@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023.
Employee email addresses may look different, but email performance will not be impacted.
Bennett, Bradley
From: Bennett, Bradley
Sent: Thursday, May 4, 2023 4:44 PM
To: Kinney, Maureen
Subject: Two Draft Permits for Clarke Utilities
Attachments: NC0073318_Draft Permit and Cover Ltr_2023.pdf; NC0063746_Draft Permit and Cover
Ltr_2023.pdf, NC0063746_Fact Sheet Binder_2023.pdf; NC0073318_Fact Sheet Binder_
2023.pdf
Hey Maureen,
Here are two draft permits for your review. They are both Clarke Utilities facilities — NCO073318 — Whippoorwill Valley
WWTP and NCO062746 — Deer Chase WWTP. Let me know if you have any questions/comments on these. They have
been forwarded on for public notice hopefully within the next week or so.
Thanks
L3.3
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3629
NC Division of Water Resources
1617 Mail Service Center Email: bradley.bennett@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 91h 2023.
Employee email addresses may look different, but email performance will not be impacted.
Bennett, Bradley
From: Carpenter, Sydney
Sent: Tuesday, April 18, 2023 2:49 PM
To: Bennett, Bradley
Subject: RE: Draft Permit for Review - Whippoorwill Valley WWTP - NC0073318
Hey Bradley,
Sorry for getting this back to you on public notice day. I only found two minor errors. It looks great otherwise! Excellent
job. Q
-Incorrect sub -basin number in Permit (Supplement to Cover Sheet) and Factsheet (Facility/Stream Info box)
-In your Factsheet (File History Review), for the note dated Jan 24, 2019, 1 think it's supposed to say "TP" instead of "TN"
for the 2.0 mg/L limit.
Hope you have a great week!
Sydney Carpenter (she/her)
Environmental Specialist I
Compliance and Expedited Permitting Branch
Division of Water Resources
NC Department of Environmental Quality
Office: (919) 707-3712
sydney. carpenter(a)ncdenr.gov
1617 Mail Service Center
Raleigh, NC 27699-1617
AwE
Urpanmenc DiEnvinxwUm d 4— IR
Opw
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <bradley.bennett@ncdenr.gov>
Sent: Tuesday, April 11, 2023 12:22 PM
To: Carpenter, Sydney <sydney.carpenter@ncdenr.gov>
Subject: Draft Permit for Review - Whippoorwill Valley WWTP - NCO073318
Hey Sydney,
I have a draft ready for your review. I also have another Clarke Utilities permit that I'm working on and will send you
way shortly. Here is the link:
M NC0073318- Clarke Utilities - Whippoorwill Vallev WWTP
Thanks
m
Bradley Bennett
Compliance and Expedited Permitting
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: (919) 707-3629
email: bradley.bennett@ncdenr.gov
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
Bennett, Bradley
From: Hayes, Mitch
Sent: Tuesday, April 11, 2023 2:51 PM
To: Bennett, Bradley
Cc: Manuel, Vanessa
Subject: RE: Draft Permit for Whippoorwill Valley WWTP (NC0073318)
Bradley,
I have reviewed the fact sheet binder and draft permit. I saw no errors. They are well written and to detail. Great work
on both of them.
Mitch
Mitch Hayes
Environmental Specialist 1
3800 Barrett Drive
Mail Service Center 1628
Raleigh, NC 27609-1628
919.791.4261
Raleigh Regional Office
Regional Operations Section
NCDEQ — Division of Water Resources
DE
cl
;
NORTH CAROLINA -
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <bradley.bennett@ncdenr.gov>
Sent: Tuesday, April 11, 2023 12:24 PM
To: Hayes, Mitch <mitch. hayes@ncdenr.gov>
Cc: Manuel, Vanessa <vanessa.manuel@ncdenr.gov>
Subject: RE: Draft Permit for Whippoorwill Valley WWTP (NC0073318)
Sorry, it always helps when you actually attach the files. The application is available in Laserfiche.
Try this one
From: Bennett, Bradley
Sent: Tuesday, April 11, 2023 12:09 PM
To: Hayes, Mitch <mitch. hayes@ncdenr.gov>
Cc: Manuel, Vanessa <vanessa.manuel@ncdenr.gov>
Subject: Draft Permit for Whippoorwill Valley WWTP (NC0073318)
Hey Mitch,
Here is the draft permit for Whippoorwill Valley WWTP — NCOO73318. Take a look and let me know if you have any
comments/questions. I'd like to send this one on to public notice if you are okay with it.
MM
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3692
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
Bennett, Bradley
From: Hayes, Mitch
Sent: Tuesday, April 11, 2023 9:48 AM
To: Bennett, Bradley
Cc: Manuel, Vanessa
Subject: RE: Permit Renewals for Clarke Utilities permits - Whippoorwill Valley (NC0073318) and
Dear Chase (NC0063746)
Joel Clarke, ORC, is operating the plant very well with no issues that I saw. I do not see any concerns in eliminating WET
from the permit.
Mitch
Mitch Hayes
Environmental Specialist 1
3800 Barrett Drive
Mail Service Center 1628
Raleigh, NC 27609-1628
919.791.4261
Raleigh Regional Office
Regional Operations Section
NCDEQ — Division of Water Resources
D- E-
�
NORTH CAROLINA C1110)
Department of Environmental quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <bradley.bennett@ncdenr.gov>
Sent: Tuesday, April 11, 2023 9:32 AM
To: Hayes, Mitch <mitch. hayes@ncdenr.gov>
Cc: Manuel, Vanessa <vanessa.manuel@ncdenr.gov>
Subject: Permit Renewals for Clarke Utilities permits - Whippoorwill Valley (NC0073318) and Dear Chase (NC0063746)
Hey Mitch,
Hope you are doing well. I am working on permit renewals for these two Clarke Utilities facilities and noticed that you
had done the most recent inspections earlier this year. I just wanted to get in touch and see if you had any comments
about the renewals that you wanted to pass along. I have a draft for Whippoorwill Valley in the works now and have
done a little work on Deer Chase. I hope to send these to you for review soon and then on to notice. One thing I
wanted your input on for Deer Chase is their WET requirements. It looks like they have been consistently passing these
and recently the Aquatic Tox staff have indicated that we should remove WET requirements for these 100% domestic
discharges if there are no noted problems. Do you have any concerns about potentially eliminating WET requirements
for Deer Chase?
Thanks for tour help.
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3692
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett(o)ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
NH3/TRC WLA Calculations
Facility: Clarke Utilities - Whippoorwill Valley WWTP
Permit No. NCO073318
Prepared By: Bradley Bennett
Enter Design Flow (MGD): 0.05 0.200 <=
Permitted Flow if Different from Design
Enter s7Q10 (cfs): 0.15 0.15
Enter w7Q10 (cfs): 1.3 1.3
Total Residual Chlorine (TRC)
Ammonia (Summer)
Daily Maximum Limit (ug/1)
Monthly Average Limit (mg NH3-N/1)
Design Permitted
Design
Permitted
s7Q10 (CFS) 0.15 0.15
s7Q10 (CFS)
0.15
0.15
DESIGN FLOW (MGD) 0.05 0.2
DESIGN FLOW (MGD)
0.05
0.2
DESIGN FLOW (CFS) 0.0775 0.31
DESIGN FLOW (CFS)
0.0775
0.31
STREAM STD (UG/L) 17.0 17
STREAM STD (MG/L)
1.0
1.0
Upstream Bkgd (ug/1) 0 0
Upstream Bkgd (mg/1)
0.22
0.22
IWC (%) 34.07 67.39
IWC (%)
34.07
67.39
Allowable Conc. (ug/1) 50 25
Allowable Conc. (mg/1)
2.5
1.4
*Max 28
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Design Permitted
Design
Permitted
Fecal Coliform
w7Q10 (CFS)
1.3
1.3
Monthly Average Limit: 200i100mi 200i100mi
DESIGN FLOW (MGD)
0.05
0.2
(If DF >331; Monitor)
DESIGN FLOW (CFS)
0.0775
0.31
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
1.8
Dilution Factor (DF) 2.94 1.48
Upstream Bkgd (mg/1)
0.22
0.22
IWC (%)
5.63
19.25
Allowable Conc. (mg/1)
28.3
8.4
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
* By Policy dischargers < 1 MGD get limits no lower than 2 & 4 due to BAT
* From 2B .0404(c) - Winter Limits can be no less stringent than
2 times the summer limits
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)
Bennett, Bradley
From: Joel Clarke <clarkej@bellsouth.net>
Sent: Thursday, January 26, 2023 7:41 AM
To: Bennett, Bradley
Subject: Re: [External] Re: Permit Renewal Applications Overdue for Deer Chase (NC0063746)
and Whippoorwill Valley (NC0073318) WWTPs
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
No problem.
Joel Clarke
Clarke Utilities, Inc.
223 Hwy 70 East
East Pointe -Suite 115
Garner, NC 27529
Phone: 919-662-0457
www.clarkeutilities.com
joel@clarkeutilities.com
clarkej@bellsouth.net
On Wednesday, January 25, 2023 at 09:36:12 AM EST, Bennett, Bradley <bradley. ben nett@ncdenr.gov> wrote:
Joel,
Cassidy just forwarded the electronic copies of the two applications to us. However, you still need to forward signed hard
copies to our office. According to federal rules we still need to get the hard copies with your original signature. Please
send these to:
Wren Thedford
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
1
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3692
NC Division of Water Resources
1617 Mail Service Center Email: bradley.bennett@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Joel Clarke <clarkej@bellsouth.net>
Sent: Tuesday, January 24, 2023 4:34 PM
To: Bennett, Bradley <bradley. ben nett@ncdenr.gov>
Subject: [External] Re: Permit Renewal Applications Overdue for Deer Chase (NC0063746) and Whippoorwill Valley
(NC0073318) WWTPs
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
The permit renewal applications were sent to Cassidy Kurtz on Dec. 30, 2022.
Let me know if you cant find them.
Thanks
Joel
Joel Clarke
Frarke Utilities, Inc.
223 Hwy 70 East
East Pointe -Suite 115
Garner, NC 27529
Phone: 919-662-0457
www.clarkeutilities.com
0oel(a-clarkeutilities.com
clarkej(aD-bellsouth.net
On Tuesday, January 24, 2023 at 09:30:15 AM EST, Bennett, Bradley <bradley. bennett(a�ncdenr.gov> wrote:
Mr. Clarke,
After our call yesterday I checked with other staff in the central office and our Raleigh Regional Office and was not able to
track down permit renewal submittals for either of these permits. You mentioned talking with someone I think about
getting your submittal routed to the right person. Do you remember who you talked with?
At this point it would be helpful if you could forward copies of the applications if you have copies you could send.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: (919) 707-3692
NC Division of Water Resources
1617 Mail Service Center Email: brad ley. bennett(@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Monday, January 23, 2023 10:46 AM
To: clarkei(obellsouth.net
Subject: Permit Renewal Applications Overdue for Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
WWTPs
Mr. Clarke,
The NPDES discharge permits for the two WWTPs mentioned in the Subject line above expire on January 31, 2023. At
this point our records do not show receipt of permit renewal applications for either of these facilities. Renewal
applications are due 180 days before expiration of the current permit. This deadline is established in Federal and State
requirements [33 USC 1251, 40 CFR 122.21 (b), and 15 NCAC 21-1.0105 (e)] and in the conditions of your exiting permit
[Part 11 Section B. Paragraphs 9. and 10.] Discharge of wastewater without a valid permit is a violation of Federal and
State requirements.
If no renewal application is received, the Division is required to make the permit Inactive. If no response is received by
1/31/2023, the Division may take action to make the permits Inactive.
The renewal application form (Modified EPA Form 2A) can be found here:
https://deq. nc.gov/water-quality/aquifer-protection/afo/permits/2021-npdes-modified-epa-form-2a/download
Information on the permitting and renewal process can be found at:
https://deq. nc.gov/about/divisions/water-resources/water-quality-permitting/npdes-wastewater/npdes-permitting-
process/npdes-individual-permit-applications
Please complete and submit the form to:
Ms. Wren Thedford
NC DEQ / DWR / NPDES
1617 Mail Service Center
Raleigh NC 27699-1617
Only the completed original form is required — no extra copies need be submitted.
Thanks for your attention to this matter.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center Email: brad ley. bennett(@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws