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NC0043257_Permit Issuance_20041025
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 YE; -J011...:;; r .1i" v,,.; . October 25, 2004 Mr. Matthew Raynor Nature Trail Associates 10006 Hammock Bend Rd. Chapel Hill, North Carolina 27517 Subject: Issuance of NPDES, Permit Permit No. NCO043257 Nature Trails MHP vVWTP Chatham County Dear Mr. Raynor: 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). The following modifications to the draft permit are included in the final permit: • The correct limits for Total Nitrogen and Total Phosphorus are 669 lb/yr and 243 lbs/yr, respectively. • The limits for daily maximum and weekly average for ammonia and daily maximum for Total Residual Chlorine are also applicable to the Effluent and Limitations Requirements for the existing flow of 0.04 MGD. The permit includes an 18 months compliance schedule for the total residual chlorine limit. This limit will not apply if a UV disinfection system is in operation at the end of the compliance schedule. If the proposed expansion, which includes a UV disinfection system, is underway but not completed at the end of the compliance schedule the permittee may request a modification to the permit to extend the compliance schedule. 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. North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-5083 Internet h2o.ennstate.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-0719 An Equal Opportunity/Affirmative Action Employer —50% Recycled/10% Post Consumer Paper one Np Caina rowon/ltf Customer Service 1-877-623-6748 Mr. Raynor Nature Trail MHP WWTP Page 2 If you have any questions concerning this permit, please contact Teresa Rodriguez at telephone number (919) 733-5083, extension 553. Sincerely, ORIGINAL SIGNED BY Mark McIntire Alan W. Klimek, P.E. cc: Central Files Raleigh Regional Office NPDES Unit Files 4f Permit NCO043257 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 provisions 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, the Nature Trails Associates is hereby authorized to discharge wastewater from a facility located at the Nature Trails Associates MHP WWTP off NCSR 1008 Chapel Hill Chatham County to receiving waters designated as Cub Creek in the Cape Fear 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 December 1, 2004. This permit and authorization to discharge shall expire at midnight on April 30, 2006. Signed this day October 25, 2004. ORIGINAL SIGNED BY Mark McIntire Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0043257 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to Qperate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Nature Trails Associates, is hereby authorized to: 1. Continue to operate an existing 0.04 MGD wastewater treatment facility with the following components: ♦ Influent pump station ♦ Equalization basin ♦ Flow splitter box ♦ Aeration basins ♦ Dual clarifiers ♦ Aerobic sludge digesters ♦ Tertiary sand filters ♦ Effluent chlorination ♦ Flow monitoring and located off NCSR 1008 at the Nature Trails Associates MHP WWTP in Chatham County; and 2. Upon receiving an Authorization to Construct from the Division, construct and operate facilities for a design capacity of 0.060 MGD, and 3. Discharge from said treatment works at the location specified on the attached map into Cub Creek, classified WS-IV NSW waters in the Cape Fear River Basin. • r I 1 . Ilya • t!+ I 1 I 1 1 _ I •I. I I Permit NC0043257 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of this permit and lasting until expansion above 0.04 MGD or 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 Frequent Sample Type Sample Locations Flow 0.04 MGD Continuous Recording Influent or Effluent BOD, 5-day (20°C) 17.0 mg/L 25.5 mg/L, Weekly Composite Effluent Total Suspended Residue 30.0 mg/L 45.0 mg/L Weekly Composite Effluent NH3 as N (April 1 - October 31) 2.0 mg/L 10.0 mg/L Weekly Composite Effluent NH3 as N (November 1-March 31) 5.0 mg/L 25.0 mg/L Weekly Composite Effluent Dissolved Oxygen2 Weekly Grab Effluent, Upstream & Downstream Fecal Coliform (geometric mean) 200 / 100 mL 400/100 mL Weekly Grab Effluent Total Residual Chlorine3 28 Ng/L 21Week Grab Effluent Temperature CC) Daily Grab Effluent Temperature CC) Weekly Grab Upstream & Downstream Total Nitrogen (NO2-N+NO3-N+TKN) Quartedy Composite Effluent Total Phosphorus Quarterly Composite Effluent pH4 Weekly Grab Effluent Footnotes: 1. Upstream - at least 50 feet upstream from the outfall. Downstream - at least 1.2 miles downstream from the outfall. 2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. 3. Effluent monitoring and limitation only apply if chlorine or a chlorine derivative is added to the waste stream during treatment. See Condition A.(5.) 4. 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. Permit NC0043257 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (0.06 MGD) Beginning upon expansion above 0.04 MGD and lasting until expiration, the Permittee is authorized to discharge treated wastewater 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 Locationi Flow 0.06 MGD Continuous Recording Influent or Effluent BOD, 5-day (20°C) 10.0 mg/L 15.0 mg/L Weekly Composite Effluent Total Suspended Residue 30.0 mg/L 45.0 mg/L Weekly Composite Effluent NH3 (April 1- October 31) 2.0 mg/L 10.0 mg/L Weekly Composite Effluent NH3 as N (November 1 - March 31) 5.0 mg/L 25.0 mg/L Weekly Composite Effluent Dissolved Oxygen2 Weekly Grab Effluent, Upstream & Downstream Fecal Coliform (geometric mean) 2001100 mL 400 / 100 mL Weekly Grab Effluent Total Residual Chlodne3 28 uglL 21Week Grab Effluent Temperature (°C) Daily Grab Effluent Temperature (°C) Weekly Grab Upstream & Downstream Total Nitmgen4 (NOrN+NO3-N+TKN) 669lbs/yr Month Composite Effluent Total Phosphorus4 243 Ibs/yr 21Month Composite Effluent pHs I Weekly Grab Effluent Footnotes: 1. Upstream - at least 50 feet upstream from the outfall. Downstream - at least 1.2 miles downstream from the outfall. 2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. 3. Effluent monitoring and limitation only apply if chlorine or a chlorine derivative is added to the waste stream during treatment. See Condition A.(5.) 4. See condition A. (3.) 5. 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. Permit NCO043257 A. (3.) CALCULATION OF TOTAL NITROGE AND TOTAL PHOSPHORUS LOADS a. The Permittee shall calculate monthly and annual TN and TP Loads as follows: L Monthly TN (or TP) Load (lb/mo) = TN (or TP) x TMF x 8.34 where: TN (or TP) = the average Total Nitrogen or Total ]phosphorus concentration (mg/ L) of the composite samples collected during the month TMF = the Total Monthly Flow of wastewater discharged during the month (MG/mo) 8.34 = conversion factor, from (mg/L x MG) to pounds H. Annual TN (or TP) Load (lb/yr) = Sum of the 12 Monthly TN (or TP) Loads for the calendar year b. The Permittee shall report monthly Total Nitrogen or Total Phosphorus results (mg/ L and lb/mo) in the discharge monitoring report for that month and shall report each year's annual results (lb/yr) in the December report for that year. A. (4.) ADDITIONAL NUTRIENT CONTROLS Upon formal approval of a nutrient management strategy, TMDL, or similar control measures affecting these receiving waters, the Division may re -open or, alternately, revoke and re -issue this permit to incorporate nutrient control requirements consistent with the approved measure(s). The Division shall notify the Permittee in writing of its intent to initiate any such action and shall allow for public comment and due process consistent with state and federal requirements. A. (5.) TOTAL RESIDUAL CHLORINE The limit for total residual chlorine sl disinfection system but no later than chlorination/ dechlorination is used, i ive upon com �u✓�e I, zoo6 Dn of the installation of a If a method different than not be applicable. State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Kerr T. Stevens, Director October 15, 2004 j&J7�1� � NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES MEMORANDUM To: Michael Douglas NC DENR / DEH / Regional Engineer Raleigh Regional Office % From: Teresa Rodriguez NPDES Unit Subject: Review of Draft NPDES Permit NC0043257 Nature Trails WWI P Chatham County Please indicate below your agency's position or viewpoint on the draft permit and return this form by November 3, 2004. If you have any questions on the draft permit, please contact me at the telephone number or e-mail address listed at the bottom of this page. RESPONSE: (Check one) Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. ❑ Concurs with issuance of the above permit, provided the following conditions are met: ❑ Opposes the issuance of the above pemtit, based on reasons stated below, or attached: c: P1 mt tj /2d \ d 1 \M'-o k� Date: V�1 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5063, extension 511 (fax) 919 733-0719 VISIT US ON THE INTERNET@http:/m2o.encstate.nc.usINPDES Charles.Weaver@ncmail.net ]The Chatham News I F_,fL i CHATHAM COUNTY AFFIDAVIT OF PUBLICATION Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified, and authorized by law to administer oaths, person- ally appeared Florence.Turner first duly sworn, deposes and says: that he (she) is Accounts Receivable Clerk (owner, partner, publisher, or other officer or employee authorized to make this affidavit) PUBLIC NOTICE STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION/NPDES UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 NOTIFICATION A NPDESWASTEWATER PERM PERMIT On the basis of thorough staff review and appplication of NC General. Statute 14,t 2i, Public law 92-500 and other awful standards and regulations, the North Carolina Environmental ,e.nt Cnmmission or000ses to national r system =ift to c6va 45 ( s notice. proposed permit will b days after the publish All comments receive are considered in the I regarding the prop( who being Director of the NC decide to hold a pub proposed permit s receive a significant interest. Coates of the draft of The Chatham News Publishing Co., Inc., engaged in the publication of a newspaper known as, The Chatham News, published, issued, and entered as second class mail in the Town of Siler City, in said County and State; that he (she) is authorized to make this affidavit and sworn statement; that the notice or legal advertisement, a true copy of which is attached hereto, was published in The Chatham News on the following dates: �)_G Lc n and that the said newspaper in which such notice, paper, document, or legal advertisement was published was, at the time of each and everysuch publication, a newspaper meeting all of tha requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a quali- fied newspaper within the meaning of Section 1-597 of the General Statues of North Carolina. This )-(I day of Sworn to and subscribed before me, this person making affidavit) a 6 Z;7- day of - V to at regarding the accepted until 30 ate of this notice. prior to that date hould the Division degree of public permit and other m on file used to present in the draft upon request and is of reproduction. d/or requests for Division of Water nrfdress or call Ms. 604-114it between the hours of 8:00 I and 5:00 pm to review information on 1. ature Trails MHP WW -P NPDES rm8 NC0043257, has aloplied for a rmit expansion from 0.04 MGD to 0.06 3D, discharging to Cub Creek in the rpeFear River Brim. SOD, ammonia, at nitrogen and total phosphorus are tier quality limited parameters. This ;charge could affect future dlscharppas the receiving stream. Au26,1tc Notary My Commission expires: // . e -7 - .-�2 a es PUBLIC NOTICE STATE OF NORTH CAROLINA 'ENVIRONMENTAL MANAGEMENT COMMISSION/ NPDES UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC 27699- 1617 NOTIFICATION OF INTENT ISSUE A NPDES WASTEWATER PERMIT On the basis of thor- ough staff review and application of NC General Statute 143.21, Public law 92- 500 and other lawful standards and regula- tions, the North Caro- lina Environmental Management. Com- mission proposes to issue a National Pol- lutant Discharge Elimination System (NPDES) wastewater discharge permit to the person(s) listed below effective 45 days from the publish date of this notice. Written comments regarding the pro- posed permit will be accepted until 30 days after the publish date of this notice, All comments received prior to that date are considered in the fi- nal determinations regarding the pro- posed permit. The Di- rector of the NC Divi- sion of Water Quality may decide to hold a public meeting for the proposed permit should the Division receive a significant degree of public inter- est. Copies of the draft permit and other sup- porting information on file used to deter- mine conditions pres- ent in the draft per- mit are available upon request and payment of the costs of reproduction. Mail comments and/or re- quests for informa- tion to the NC Divi- sion of Water Quality at the above address or call Ms. Carolyn Bryant at (919)733- 5083, extension 520. Please include the NPDES permit num- ber (attached) in any communication. In- terested persons may Affrdauit of Publication North Carolina Bill Homer III, Publisher of &4t 17s>tttfurb Atra[b, a newspaper published in Lee County in the state of North Carolina, being duly sworn, deposes and says: that the attached advertisement of notice, in the action entitled AUG 2 6 2004 was duly u��raid ne spaper once a week for 1 consecutive weeks, beginning with the.issue.datedthe; b day ofpfu!�—, to L1 and ending with the issue dated the 0?01day of , Bi orner III, Publisher Sworn -to and subscribed before mG; this -8 day of _ Notary My Commission expires: 1- 3 Ada_. s9 Received of IJ _f:)C AZ /�wGL / $ �j' the cost of the above publication. 1a , C� � C9 d� By: PtZ �3z Mo j Ny�y ,2by 'O n.oCC�'di O �n VJNe+t6>w �' x�., a� oC7UU m«r�ab Uri ytit=a�'"ow�.E Wo m m GV ooEEoo�ck ao ,�,$ym Ozv�gx oy,t''v U A d z3.:8ax� � ob�o 3�m oU�ma04C N DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NCO043257 Facility Information Applicant/Facility Name: Nature Trail Associates / Nature Trails MHP W WTP Applicant Address: 10006 Hammock Bend Rd., Chapel Hill, NC 27517 Facility Address: Same Permitted Flow (MGD): 0.04 (existing) 0.06 (proposed) Type of Waste: 100 % Domestic Facility Classification: II Permit Status: Expansion County: Chatham Miscellaneous Receiving Stream: Cub Creek Regional Office: RRO Stream Classification: WS-IV NSW State Grid / USGS Quad: D22SE 303(d) Listed? No Permit Writer: Teresa Rodriguez Basin/Subbasin: 030605/Cape Fear Date: 7/16/04 Drainage Area (mi2): 5.34 Lat. 350 51' 30" N Long. 790 01' 36" W Summer 7Q10 (cfs) 0.13 Winter 7Q10 (cfs): 0.3 30Q2 (cfs) 0.7 Average Flow (cfs): 5.6 IWC (%): 41.7 Summary: Nature Trails Associates submitted a permit expansion request and an Engineering Alternative Analysis on February 2004. The existing W WTP has a capacity of 0.04 MGD, they want to expand to 0.06 MGD to accommodate approximately 55 more mobile homes. The existing plant consist of a pump station, 10,000 gallon equalization tank, 60,000 gallons aeration basin, clarifier, 15,000 gallons aerobic sludge digester, tertiary sand filters, and effluent chlorination. The proposed facility will utilize some of the existing units and install new ones. The existing pump station will remain in use. Two of the existing 5,000 gallons aeration tanks are to be converted to equalization for a total capacity of 20,000 gallons. Two 30,000 gallons aerobic/anaerobic basins and two 5,000 gallons clarifiers will be added. New filters and a UV system will also be installed. Six of the existing 5,000 gallons aerobic tanks will be converted to sludge holding tanks. Engineering Alternative Analysis: The alternatives evaluated included connection to a treatment system, individual subsurface systems, drip irrigation, spray irrigation and reuse. The only treatment system in the vicinity is The Governors Club, which doesn't have capacity to accept additional wastewater. Individual subsurface systems and the reuse option are not feasible for the development. Two feasible options were direct discharge and land application. The cost of a direct discharge is $790,000 and for land application is $1,403,000. The most economically feasible alternative is the direct discharge. Permit limits development — 0.06 MGD Flow: BOD, Ammonia: A level B model was developed to determine BOD and ammonia limits. The flow data was estimated for the location of the discharge. Apparently when a waste load allocation was completed in 1988 the flow statistics that were used didn't correspond to the discharge location. The values used were for a location upstream of the discharge in Cub Creek. The drainage area and low flow values were recalculated and used in the level B model. The model data and results are attached. Based on the model's results summer monthly average limits for BOD of 10 mg/I and ammonia of 2 mg/I as will protect water quality in the receiving stream. Following Division's policy daily maximum limits for ammonia were implemented. The daily maximum limits are 10 mg/I for summer and 25 mg/I for winter. Fact Sheet NPDES NCO043257 Page I TSS & Fecal Coliform: These limits will remain as in existing permit. Total Residual Chlorine: A limit of 28 pg/I was included in the permit. The Division implemented a water quality standard for TRC in 2003. All dischargers will receive TRC limits upon renewal or expansions. Total Nitrogen & Total Phosphorus: The receiving stream is classified as Nutrient Sensitive Water (NSW) therefore is subject to House Bill 515. An annual average mass load of 657 Ibs/yr was calculated for Total Nitrogen using 5.5 mg/I and 0.04 MGD flow. An annual average mass load of 237 Ibs/yr was calculated for total phosphorus based on 2 mg/I and 0.04 MGD. DMR Review: DMRs were reviewed for the period of January 2001 to February 2004. The average flow was 0.0306 MGD, BOD averaged 6.4 mg/I, Total Nitrogen averaged 26 mg/I and Total Phosphorus 4.6 mgA. 303(d): Cub Creek is not listed in the 303(d) list. Cub Creek flows into Morgan Creek approximately 3 miles downstream of the discharge. Morgan Creek is listed as impaired due to chlorophyll a violations and biological integrity. The Division is developing a Nutrient Response Model for the lake to provide a basis for a Nutrient Management Strategy. The Division expects to complete the Nutrient Management Strategy by December 2004. The strategy could affect the nutrient limits in the permit. A nutrient reopener condition was included in the permit to re -open the permit if the Jordan Lake strategy calls for different nutrient conditions or limitations. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: Permit Scheduled to Issue: NPDES DIVISION CONTACT August 18, 2004 October 11, 2004 If you have questions regarding any of the above information or on the attached permit, please contact Teresa Rodriguez at (919) 733-5083 ext. 553. NAME: REGIONAL OFFICE COMMENTS IF'V// NAME: �O' DATE: qkq-J o SUPERVISOR: DATE:ie) Z-S 6 Fact Sheet NPDES NCO043257 0.,.. I Nature Trail NCO043257 4/30/2004 TR BIMs report DMR (quarterly sample) Calculated Average Month Year Flow (mgd) Tn (m I) TP (mgOl TN (lb/d) lb/mth Yearly Load 1 2001 .0241 15.19 1.17 5.4 166.4 2 2001 .0283 6.3 176.5 3 2001 .0249 5.5 171.9 4 2001 .0192 4.3 128.3 5 2001 .0394 8.8 272.0 6 2001 .0309 6.9 206.4 7 2001 .0265 5.9 182.9 8 2001 .0287 21 4.36 6.4 198.1 9 2001 .0261 23.1 3.27 5.8 174.4 10 2001 .033 22.3 3.39 7.3 227.8 11 2001 .037 8.2 247.2 12 2001 .037 8.2 255.4 2407.1 Ib/yr. 1 2002 .035 21.8 4.17 7.8 241.6 2 2002 .038 8.5 236.9 3 2002 .038 8.5 262.3 4 2002 .035 16.5 6.94 7.8 233.8 5 2002 .036 8.0 248.5 6 2002 .035 7.8 233.8 7 2002 .037 41.8 5.48 8.2 255.4 8 2002 .034 7.6 234.7 9 2002 .035 7.8 233.8 10 2002 .036 33.1 9.09 8.0 248.5 11 2002 .032 7.1 213.8 12 2002 .029 6.5 200.2 2843.4 Ib/ r 1 2003 .028 6.2 193.3 2 2003 .034 7.6 212.0 3 2003 .035 7.8 241.6 4 2003 .031 6.9 207.1 5 2003 .029 6.5 200.2 6 2003 .027 32.4 3.63 6.0 180.4 7 2003 .031 6.9 214.0 8 2003 .03 6.7 207.1 9 2003 .031 21.6 3.63 6.9 207.1 10 2003 .022 4.9 151.9 11 2003 .022 39.2 4.58 4.9 147.0 12 2003 .024 5.3 165.7 23�,2 Ib/ r 1 2004 .023 5.1 158.8 2 2004 .023 32.3 6 5.1 143.4 Ave 26.7 4.64 M .�3d�qd - err-,scd SUMMER 0 MODEL RESULTS Discharger : NATURE TRAILS MHP Receiving Stream : CUB CREEK ---------------------------------------------------------------------- The End D.O. is 6.50 mg/l. The End CBOD is 4.33 mg/l. The End NBOD ---------------------------------------------------------------------- is 2.21 mg/l. WLA WLA WLA DO Min CBOD NBOD DO Waste Flow (mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd) Segment 1 ------ 6.26 ---------------- 0.39 1 ---- ---- -- ---------- Reach 1 15.00 9.00 5.00 0.06000 SUMMER Seg # Reach # Seg Mi D.O. CBOD NBOD Flow 1 1 0.00 6.34 7.42 4.34 0.22 1 1 0.13 6.29 6.96 4.01 0.23 1 1 0.26 6.26 6.55 3.72 0.25 1 1 0.39 6.26 6.18 3.46 0.26 1 1 0.52 6.27 5.84 3.23 0.27 1 1 0.66 6.29 5.53 3.02 0.28 1 1 0.79 6.33 5.25 2.83 0.29 1 1 0.92 6.36 4.99 2.65 0.31 1 1 1.05 6.41 4.75 2.49 0.32 1 1 1.18 6.45 4.54 2.35 0.33 1 1 1.31 6.50 4.33 2.21 0.34 Seg # ( Reach # Seg Mi D.O. CBOD NBOD Flow *** MODEL SUMMARY DATA *** • Discharger : NATURE TRAILS MHP Subbasin 030606 Receiving Stream : CUB CREEK Stream Class: C Summer 7Q10 : 0.13 Winter 7Q10 : 0.37 Design Temperature: 26.0 LENGTH SLOPE VELOCITY DEPTH Kd Kd Ka Ka KN mile -------------------------------------------------------------------------------- ft/mi fps I ft design @200 design @200 I I I design Segment 1 1 1.31 8.19 0.100 1 0.43 1 0.33 1 0.25 1 1.68 1 1.47 0.48 Reach 1 T Flow CBOD NBOD D.O. cfs mg/l mg/l mg/l Segment 1 Reach 1 Waste 0.093 15.000 9.000 5.000 Headwaters 0.130 2.000 1.000 7.300 Tributary 0.000 2.000 1.000 7.300 * Runoff 0.091 2.000 1.000 7.300 * Runoff flow is in cfs/mile WINTER Q MODEL RESULTS Discharger : NATURE TRAILS MHP Receiving Stream : CUB CREEK ---------------------------------------------------------------------- The End D.O. is 8.95 mg/l. The End CBOD is 3.56 mg/l. The End NBOD ---------------------------------------------------------------------- is 3.82 mg/l. WLA WLA WLA DO Min CBOD NBOD DO Waste Flow (mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd) -- ---------- Segment 1 ------ 8.42 ---------------- 0.00 1 ---- ---- Reach 1 15.00 22.50 5.00 0.06000 WINTER Seg # Reach # Seg Mi D.O. CBOD NBOD Flow 1 1 0.00 8.42 4.61 5.32 0.46 1 1 0.13 8.49 4.48 5.13 0.47 1 1 0.26 8.56 4.36 4.96 0.49 1 1 0.39 8.62 4.24 4.79 0.50 1 1 0.52 8.67 4.13 4.63 0.51 1 1 0.66 8.73 4.02 4.48 0.52 1 1 0.79 8.78 3.92 4.33 0.53 1 1 0.92 8.83 3.82 4.20 0.55 1 1 1.05 8.87 3.73 4.07 0.56 1 1 1.18 8.91 3.64 3.94 0.57 1 1 1.31 8.95 3.56 3.82 0.58 Seg # Reach # Seg Mi D.O. CBOD ( NBOD Flow *** MODEL SUMMARY DATA *** Discharger : NATURE TRAILS MHP Subbasin : 030606 Receiving Stream : CUB CREEK Stream Class: C Summer 7Q10 : 0.13 Winter 7Q10 : 0.37 Design Temperature: 14.0 LENGTH SLOPE VELOCITY DEPTH Kd Kd Ka Ka KN mile ------------ ------------------------------------------------------------------- ft/mi fps I ft design @200 I design @200 I I design Segment 1 1 1.31 8.19 0.100 1 0.59 1 0.18 0.23 1.29 1 1.47 0.19 Reach 1 t Flow CBOD NBOD D.O. c f s mg/ l mg/ l mg/1 Segment 1 Reach 1 Waste 0.093 15.000 22.500 5.000 Headwaters 0.370 2.000 1.000 9.280 Tributary 0.000 2.000 1.000 9.280 * Runoff 0.091 2.000 , 1.000 9.280 * Runoff flow is in cfs/mile NgUEST NO; 8246 SITE NO; DATE; 1/ 4/88 GVUKCE; NRCD �-Sl3ON; NEW STREAMFLOW CONDITION: �� tl�All()N NUMBER; 0209752617 TYPE SlATION; 20 �/k � ''''/�� STATION NAME; COB C NR B0OTHE HILL, NC ~ LOCATION; 2"3 MI BL US 15-501 AND 1.6 MI N OF BOOTHE HILL, NC LATITUDE; 355101 LONGITUDE; 790350 ~ QUADRANGLE NUMEER; D22SE COUNTY CODE: 037 STAlE CODE; 37 DISTRICT CODE; 37 HYDROLOGIC UNIT CODE; 03030002 NKCD BASIN CODE; 030606 DRAINAGE AREA; 2"90 AVERAGE FLOW; 3.00 RANGE; 2,4 `cfs to 3^6 cfs 20 Percent [B] {7 � 7U1W MIN FLOW; (}^6'15 RANGE; 0.05 cfs to 0,1 cfs Percent [C] (SUMMER) 0 � 3002 MIN FLOW: 0°4 RANGE; 0"3 cfs to 0.5 cfs 35 Percent [B] � 8q 7010 MIN FLOW; 0"2 RANGE: 0"1 cfs to 0^3 cfs 35 Percent [B] (WINTER) r� 702 MIN FLOW; kANGE; cfs to cfs Percent [ ] ~~ NOTES' [A] Estimate is based on records collected at or near the site, and the range indicates approximate interval in which the actual value may lie [B] Estimate is based entirely on runoff observed at nearby streams and therefore no degree of r^eiiabiity is attached" [C] Because of the probable degree of inaccuracy of the estimate only a range is given. [D] Approximately. Streamflow Condition Codes [R] Regulated [N] Natural REMARKS; REQU2ST0R-~Z0UFALY Entered by; AEF Fee charged; 0^00 Fib GAIL.SiT NOZ 8246 NRU'D SITE NO-1r, A("TION' DATE • NEW 1./ 4/88 STREAMFL.OW ["ONOfTION' STATION NUMBER" 0209*752665 T Y PE STATION' 20 151q%j STATION Nf)M!---.'V' CUB C AB SIR 1008 NR FARRINVON,. NC LOCATION" It 0.8 MI AB S E3R 1008 AND 3.5 MI N OF" FARRIN6TON:, NC L.. A T I T U D E 335108 LONUELTUDE vv 7901,J3 QUADRAN[A-E NUMBERV* D22SE COUNTY wr 0T.,1 SI'A*1'1'--" CODEvv 37 DISTRICT Ir CODE ' 37 HYPROLOUIC LJN I T C 0 1) 2 L v 0303000" NRCD BASIN CODE'': 030606 DRAINA0E AREA: 5. 70 AVERAGE FLOW" 6.00 RANGETZ 5 c f s to 1 cfs 20 Percent [131 7LI10 MIN F*I..OWvf R A N 6% E 0.1 cfs to 0.2 cfs Percent EC3 (SUMMER) 3VIG12 MIN FLOW; 0.8 RANGE' 0.5 cfs to 1.1 cfs 35 Percent IV0 7 Q:10 MIN v FLOW ', 0.4 v RANGEv f 0.3 c S to 0.5 cf s 35 Percit--nt LBI ( W1 N TE R ) 7 V-12 M X N FL 0 W Z RANOJE cfs to cfs Percent E :1 L A J Estimate is bastz!d on re -cords collsucted at or near the site:, and the range indicates approximate inteurval in which the actual value may lie EB3 Estimate is based entirelL p on runoff observed at neprby streams and therefore no (.,Je;-eqr3.---e of reLiablity is attached. LC3 Because of the probabls.-! clegreir.t of. inaccurz:.cy of the, estimate only a range i--s qive-in. [DJ A p p r ox, i m a t r-.!'l y Streamflow Condition Godes L R-J R e, g u I a t e d E N J Natural REMARKS TV R E' (' I U E. S * 1* 0 R --- -- Z 0 U FA L Y f::n-t�:1r,ired bt. Al' F 0. 00 JJ; AN fil::GlUkST N0� 8246 SITE NO,0ACTION." GATE: 1,/ fi 6`0L11iCE wo NIR(aU NEW STIREAMFLOW C.OND I *r i ON - STATION NUMBER.' 8.097 28-00 TYPE STA!'ION+ ,:.W STATION NAME'V' CUB C AT MTH NIA I~ARRING*rON.. NC L.OG-ATIONs AT MTH AND 2.0 M.I. NE OF FARRINGTON, NC L.A'l':I:'C'tio : 354943 LON(3:l:Tt.3GI~: Y 79opj j7 QUADRANGLE NUMBER IN D22SE COUNTY COUC: Ot'*557 G'rATE CODE- 37 D:I:G'i'RIC:T CODE'. 37 I•IYDROL.()GIC UNIT CODE' Lr13030002 NRCD BASIN CODE*" �.'�.��Ei(!If»ti DRAINAi"E AREA V' 8.40 AVERA13E t- LOW a 9.00 RANGE_ 10 7 c f s to 1.1 cfs 20 h'erc erit 1. 8 J U10 MIN F1..0WT 0.2 RANGET 0.1 cfs to 0.3 cfs 3.J Percent 1BJ N ( SUMMER) 0 3002 MIN FI...CsW: 1.2 RANGE: 0.8 cfs to 1.6 cfs 35 Percent IBI 7Q1.G MIN FL-OW'G.6 RANGE'qp 0.4 cfs to 0.8 cfs 35 Percent CBI � (WINTER) �y 7Q2 MIN 1='l..OW; RANGE.: cfs to cfs Percent L 1 O 0 NOTES sw L A I Estimate is based on records collected at or near the s i to v and the range indicates approximate interval in which th* actual value (flay lie L B I Estimate is haled entirely on runoff observed at nearby streams <:.>•nd therefore no degree of rel i ab 1. i ty is attach: a. C C`.I Because of the., pr•obak+tw: degree of inaccuracy of the estimate only a range is given. ED] Approx i mate Iu. Stream f low Condition Code LRI Regulated EN::I Natural REMARKS s REE(:Il.1lw'STOR--•-ZOt.lF AL Y En•t t-t,rect bwv fit1:;:F* Fee r_•harged= 0.90 Lea site. 0a0975a(o/4 ss°s "or" -boo, = a a ray = WAJ 3.O J-s 0,075 e�5 a 1 V44-r _ 35°5/ �. oao475. r s i by-J 7900/ 53' at}=5.L- `Y1l•, . v'pr = (o . O c.` sy-q/0= O•/s ch s0Q 0 = o, Ch o� W = a, y c,�s \0., yc- F. /9 //,, a ys rq l� JvL' 2 - `r 501 j - 5 1 -7 y'i.c.lds QqIJ �', = L05 CDs%m` s'4gl0'* C, is � 7Q(0w c 30Qa L. ,9 = ./y C.�s/miZ z.S m, Run C4- s3giu= .��-•13=D.U38 r,31 PAY 1.3! r•3 � gJ L� b2 ., J 1/U(s9 cog 3s• `-l'4 a" iArs- 00'67„ bA= q 4 ck 0.Oq 30Qa = I, 2- wa4rv= o.C, j_ LA4l C ,Q,f ✓l afi,�-�z 'rcu-1 (Qow, = 5.34 min I.OSck mil s�W1o= s.3yK.0zCo = 0.13 C N 7g10 =s,-3v x 0' = 0. 3-7 30 C2 a ° 5 3Y x ,IV = 0, % CAS A�- sx- /ooK 6 ff = •7. 0 m, Z q =7.ox i.os = '1.55 c{s '79/ro = 7x o7 = o,V9 c� 7X ./Y = _0. 9K c s b2asE Farr i r -on b i Z -2— Si 7- -20 one t4ac4 C-6 �nao p/r5ar� C600 N3ob �/� / � a-)- LEVEL B MODEL INFORMATION File Name: nattrls nattrlw t F Wit s� z a iii£. �'.,:it2 »4.,.,.: M, ; .r N �i �o o�i r�{sue• £ �� #:,�a ' .:x:,. ,..i.-,+.,... .aY�n�'--�_y*5."�'..". tF.. .�...,. xa, Facility Name Nature Trails MHP To o Quad Farrington NPDES No. NCO043257 USGS sta. # Type of wastewater 100 % domestic Date of flow estimate 7/21 /2004 Facility status Expansion 0.04 to 0.06 MGD Drainage Area (mi) 5.34 Receiving stream Cub Creek Summer7Q10 cfs 0.13 Stream class WS-IV NSW Winter7Q10 cfs 0.37 Subbasin 30605 Average flow cfs 5.6 County Chatham 30Q2 cfs 0.7 Regional Office RRO IWC at discharge % 41.7 ..- -, NO ItE 3 ..,•,. Ss "'t -0046 Nq Igg ..ram 1 zw�3 � r , < ,.: zx Segment/Reach 1 Length of reach mi 1.31 Incremental length 0.131 Sloe 8.19 Waste characteristics Flow MGD) 0.06 CBODm/I) 15s 15w NBODm/l 9s 22.5w DO m /I 5 Runoff charactericstics s7Q10 cfs/mi 0.038 QA cfs/mi 1.33 CBOD m /I NBOD m /l DO m /I TR 7/21/04 CULPEPER ENGINEERING, P.C. P.O. BOX 733 LOCUST GROVE, VIRGINIA 22508 Phone: 540 423-9706 Fax: 540 423-1534 July 8, 2004 Teresa Rodriguez Department of Environment and Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Re: Permit No. NCO043257 Nature Trails WWTP Chatham County Dear Ms. Rodriguez, E R9 9 W [ N i J U L 15 2004 L__ OENR - WATER QUALITY POINT SOURCE BRANCH In response to your letter regarding the permit expansion request for NC0043257, Nature trails WWTP, the following information is provided. 1. Governor's Club was contacted verbally regarding capacity availability. The persons contacted were both the project engineer and the facility manager. Both individuals indicated that there was no capacity in their facility, which could be utilized by Nature Trails. There was no formal written correspondence to follow up the verbal "NO". They were contacted by Mr. Raynor when the original EAA was prepared and again after he received your May 4, 2004 letter. A written response from them has not been received. 2. The property owned by Nature Trails Associates includes approximately 63.83 acres (County record). Much of the land encompasses steep terrain and is occupied by the developed mobile home park. The existing discharge facility was installed to service the park due to the lack of available land for installation of drainfields. The land area that is not included in the home sites and roads is limited and is scattered. Much of this is to be additional home sites. There is some open area, which is part of the property that is adjacent to the treatment plant. The available area is not adequate for a land based treatment system. Please refer to the attached survey of the property. It is noted that the physical survey of the property indicates a total area of 66.10 acres. The remaining property that is not currently developed, which is owned by The Carlyle Group, is located partially in a floodplain. This parcel include 6. acres I have attached information from the Chatham County Site indicating the land parcels in the area. The area includes residential parcels and parcels owned by others. Other than the currently owned property which does not total the required acreage, it is not believed that offsite property can be acquired that will provide equate area and characteristics for a land based system. Please refer to he attached assessment sheets for various parcels (undeveloped) in the area. I have utilized an average per acre cost of four parcels to determine the cost associated with land acquisition. It is anticipated that should there be property that could be obtained, it would require obtaining approximately 20 acres to yield 16 acres under irrigation. Based on local soil conditions it is also assumed that a storage capacity of approximately 90 days would be required for a land -based option. There is limited area behind the existing treatment plant and the beginning of the park. The available area here currently serves as a buffer area between the residential area and the treatment plant. To the left of the plant is the entrance road to the MHP. The creek is immediately in front of the treatment plant and to the right of the plant there is area of land, but again much of this area is topographically low and limited. The area in the immediate vicinity is to be utilized for the additional treatment facilities. It is assumed for the land application option, that this area would be sufficient for the required treatment plant and storage. Storage is assumed to be two above grade tanks providing 90 ,days of storage capacity. As with the existing STP, all components will be required to be above grade to provide the necessary flood protection. 3. A cost estimate for the proposed discharge option was previously provided. I have provided an estimated cost for the non -discharge scenario, which would serve the additional 20,000 gpd of flow. The cost estimates are tabulated on the attached sheet. If you require any additional information, please do not hesitate to call. S;ea . Tolliver attachments Cost Estimate - Facility Upgrade Facility - 60,000 gallon Discharge New Influent Pump Station - To be handled as a separate contract Upgrade to existing influent pump station (as necessary) $10,000 Modification to provide additional equalization in existing basins $15,000 Secondary treatment facilities $285,000 Tertiary treatment $65,000 UV Disinfection $20,000 Sludge Management Modifications $80,000 Miscelaneous mechanical/electrical $50,000 Maintenance Building $70,000 Generator $50,000 Site Work $50,000 Subtotal $695,000 Contingency $70,000 Engineering/Stake-out/Control $25,000 Estimated Total Project Cost $790,000 Cost Estimate - Facility Upgrade Facility - 20,000 gpd Land Application New Influent Pump Station - To be handled as a separate contract Upgrade to existing influent pump station (as necessary) $10,000 Equalization Basin $15,000 Secondary treatment facilities $100,000 UV Disinfection $8,000 Storage (90 Days) $500,000 Effluent Pump Station to Application Sites $20,000 Irrigation Wet well and system controls and pumps $45,000 Irrigation Systems (3 zones) $36,000 Groundwater Monitoring $9,000 Maintenance Building $70,000 Miscelaneous Mechanical/electrical Land Acquisition - 16 acres required $50,QOQ C$250,000 Land Clearing0, Site Work - Plant $15,000 Site Work - application sites/fencing $30,000 Subtotal $1,178,000 Contingency $105,000 Engineering/Stake-out/Control $120,000 Estimated Total Project Cost $1,403,000 Chatham County NC Web Site Information regarding Nature Trails Associates and property owned by the Carlyle Group. Additional sheets detailing vacant parcels in the vicinity of the park. Page 1 of 1 Property Report - 119 NATURE TRAIL RD GO Property Details Name: NATURE TRAIL ASSOCIATES Address: 9073 NEMO ST Owner ID: 41521 citylstatemp: 11LOS ANGLES,CA,90069 Parcel ID: 20060 Address: 119 NATURE TRAIL RD PIN: 9786-97-4650.000 District: 107 Deed Date: 1989 Acreage: 63.83 Deed Book: 11547 Finished Area: 1344 Deetl Page: 0725 Effective Year Built: j 1982 Legal Description: 01-5 Zoning: Land Value: $1,286,235 Zoning Jurisdiction: COUNTY ZONING Improvements Value: 11$1,397,511 Total Value: 1$2,683,746 .../usi?fonnis=ptmap&MouseX=O&MouseY=O&zoomfac=&propnum=2&proptxt=20060&Ea06/07/2004 Page 1 of 1 Property Report - NATURE TRAIL RD TR2 si 2 TR-1 � TR1 TR-1 1 TR-2 B y 304 / 1 _._---. ...___._-----'--------- — ass Property Details Name: CARLYLE GROUP INC THE Address: 9073 NEMO ST Owner ID: 25770 CitylstatelZip: LOS ANGELES,CA,90069 Parcel ID: 60693 Address: NATURE TRAIL RD PIN: 9796-17-3414.000 District: 107 Deed Date: —� 1985 Acreage: 6.08 Deed Book: 1 489 Finished Area: 11704 Deed Page: 110238 Effective Year Built: 1950 Legal Description: 01-3C Zoning: Land Value: $92,460 11 Zoning Jurisdiction: JCOUMYZONING Improvements Value- JIS20,773 Total Value: 1$113,233 ..Iusi?formis=ptmap&MouseX=82&MouseY=300&zoomfac=l&propnum=2&proptxt=6069306l23/2004 Page I of I Property Report - OFF MT CARMEL CHURCH RD Property Details Name: MARTINDALE ALICE D CHEEK Address: 1077 A MT CARMEL CH RD Owner ID: 18237 CitylStawzip: CHAPEL HILL,NC,27514 Parcel ID: 20039 Address: II OFF MT CARMEL CHURCH RD PIN: 9796-18-1294000 District 11107 Deed Date: 1994 Acreage: 3.13 Deed Book: 636 Finished Area: 0 Deed Page 10748 Effective Year Built 0 Legal Description: 01-3D Zoning: Land Value: 11$17,606 lZoning Jurisdiction: COUNTY ZONING Improvements Value: 11s Total Value: 1$17,606 .../usi?formis=ptmap&MouseX=4] 0&MouseY=210&zoomfac=&propnum=2&nropbd=20039)6/22; 2tit;4 Page i of 2 Property Report - OFF MT CARMEL CHURCH RD - ----- 2 1341 13 14 1 na 6733 1794 67r � 12 i77 S; u 'p �? TR-1 rn in TR-2 TR-2 TR-1 „ Property Details Name; MARTINDALE ALICE D CHEEK Address: 1077 A MT CARMEL CH RD Owner ID: 18237 City/stateizip: CHAPEL HILL,NC,27514 Parcel ID: 72756 Address: OFF MT CARMEL CHURCH RD PIN 9796-18-0099000 District: 107 Deed Date: 1980 Acreage: 3.09 Deed Book: 436 Finished Area: 0 Deed Page: 0898 Effective Year Built 0 Legal Description: 01-3-12 Zoning: Land Value: 1$17,381 Zoning Jurisdiction: COUNTY ZONING Improvements Value: $ Toial Value: $17,381 /usi . fbrmis=ptmap&MouseX=O&MouseY�&zoom&c=&nropnurn=2&nroptxt=7275b&EaO6/22/2004 Re: Nature Trails Association CLP - Nature Trails Mobil... Subject: Re: Nature Trails Association CLP - Nature Trails Mobile Home Park From: Jack Roskoz <rjroskoz@nc.rr.com> Date: Sun, 16 May 2004 22:55:58 -0400 To: Teresa Rodriguez <teresa.rodriguez@ncmail.net> Dear Ms. Rodriquez, Thank you very much for the prompt and informative response to my inquiry. I have just one question, that being, where does the public notice appear? Would it be in the Raleigh News and Observer or the local Chapel Hill newspaper, and what is expected from the appearance of the public notice, if anything? Thanks again, I appreciate your patience explaining the procedures to someone unfamiliar with the process. Jack Roskoz On May 14, 2004, at 10:22 AM, Teresa Rodriguez wrote: Mr. Roskoz, The permit is not at a stage to determine if there will be a public hearing or not. This will be determined after the permit goes to public notice. The issue of noise from the plant can be addressed when the permittee requests the Authorization to Construct (AtC). The AtC is evaluated only after the permit expansion has been approved. I am looking at their request for expansion, if this expansion is approved I will make a reference to the noise complaints to and have the review engineer look at the potential noise effects form the proposed treatment system at the time of AtC review. Teresa Jack Roskoz wrote: Dear Ms. Rodriquez, In reference to the pending modification Nature Trails' waste water discharge permit, will there be a public hearing on the application? I and others have been very unhappy with the noise level originating at the current facility. Recent measures have been taken by the operator to mitigate the noise with a type of enclosure. It is hoped that the new installation (I have been told it will be a "package plant" but I am not entirely sure what that means) will be designed and constructed to further reduce the noise which is or can be very bothersome to neighbors of Nature Trails. 1 of 2 5/28/2004 10:44 AM Re: Nature Trails Association CLP - Nature Trails Mobil... In the past I have spoken with or contacted Tom Belnick of your office and Judy Garrett of the Raleigh regional office. Thank you in advance for your consideration. Jack H. Roskoz 60136 Davie Chapel Hill, NC 27517 919-967-8900 Teresa Rodriguez, P.E. Division of Water Quality NPDES Unit 919-733-5083 2 of 2 5/28/2004 10:44 AM O ZQ j May 4, 2004 Mr. Matthew Raynor 10006 Hammock Bend Rd. Chapel Hill, North Carolina 27517 Michael F. Easley, Governor State of North Carolina William G. Ross, Jr., Secretary Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality Subject: Permit No. NCOO43257 Engineering Alternative Analysis Nature Trails WWTP Chatham County Dear Mr. Raynor: The Division has completed a review of your permit expansion application submitted on February 4, 2004. The following information is required before we can proceed with the final evaluation and permit modification: 1. Your letter states that the Governor's Club was contacted and no capacity was offered. Provide documentation received from the Governor's Club stating so. 2. Your report also states that 16 acres of land would be required for a land based application system. No information was provided on the number of acres available for this type of system. Please provide a site map including property boundaries, the location of existing structures, proposed structures and available area for land application. If the available land is not sufficient evaluate the cost of adjacent land and provide an estimate of how much land would be needed. 3. A Present Worth Analysis shall be completed for the non -discharge and discharge options. Present the results of the cost per alternative in a table format. The unfeasible alternatives will be eliminated based on overall cost. The discharge from Nature Trails MHP is into the Jordan Lake watershed. Jordan Lake is designated as Nutrient Sensitive Waters. The Division is developing a Nutrient Response Model for the lake to provide a basis for a Nutrient Management Strategy. The Division expects to complete the Nutrient Management Strategy by December 2004. The strategy could affect the nutrient limits in your permit. Please provide the above information to the Division within 30 days of receipt of this letter. If you have any questions concerning the testing requirements, please call me at (919) 733-5083, extension 553. Sincerely, 1�� /2,� Teresa Rodriguez NPDES Unit Cc: NPDES Files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone (919) 733-5083 FAX (919) 733-0719 An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET @ www.enr.state.nc.us lz d�f2/�u� NATURE TRAILS M.H P.,L.L.C. 5604 PRESTON PLACE RALEIGH, NORTH CAROLINA 27604 January 29, 2004 David A. Goodrich NPDES Unit Supervisor North Carolina Division of Water Quality NPDES Unit 1617 Mail Service Center FEB I, 4 2001 Raleigh, North Carolina 27699-1617 Re: Nature Trails NW — NPDES No. NCO043257 Dear Mr. Goodrich, In response to the recent correspondence from Mr. Belnick and a follow up conversation with him regarding the permit modification request for an expansion of flow at the facility to GD from MMGD I have enclosed the following information. 1. I have enclosed three copies of the permit application. 2. I have enclosed three copies of the original EAA that was submitted to your office and which was subsequently returned. I have included three copies of the recently provided addendum which addressed the concerns associated with the original submittal. 3. I have provided the Local Government form. - 4. I have enclosed a check for $215. I had Ms. Tolliver speak with Mr. Belnick regarding the resubmission. It is understood that the original document provides the required assessments required regarding evaluation of alternatives to surface discharge. Although the original request in the EAA addressed a request for a flow of 0.80 MGD, the evaluation of alternatives remain valid. Specifically, the original EAA determined the following regarding disposal alternatives: 1. The closest POTW is the City of Durham which is more than 8 miles away and in another county. The Nature Trails is a private facility and does not have the advantage of eminent domain to secure the easements which would be required. In addition, the different jurisdictional location creates a problem for acceptance of flow. 2. The closest privately owned treatment facility, Govenors Club was contacted and no capacity was offered. 3. On -site, individual subsurface facilities are precluded due to steep terrain and the predominant soil characteristics. The existing plant was installed due to a lack of available soils for on -site management of wastewater. 4. A community subsurface system was determined to not be a viable alternative due to a lack of property available with soil characteristics that are acceptable. The open property owned on -site is a floodway that has Creedmoor soils which have limited capability for wastewater management. The same property was available when the existing facility was installed and was not considered a viable location for an installation.1 5. The area was evaluated to determine if an irrigation or drip facility could be installed. Based on the assessment, the area was not considered viable for a 1 system. The hydraulic evaluation determined that the site soils, Creedmoor, t, appear to have an available capacity of 17.05 in/yr. For the modified request, for �A01 the additional flow of 201000_gpd would require a minimum area active a lication of � 6 acres:'In addition, area would be required for the storage of generated flow during the periods of non -application, Additionally, reserve areas and buffers would be required. The area of open land owned is not adequate to manage the revised proposed expansion. The non -developed-------- ---� portion of the park is located at the entrance and is not large a ugh �o provide the required area. The undeveloped land is limited t es from due to the dense residential , r 6. Reuse was deleted consideration development and the steep topography. Additionally, there are no central 5 facilities like HVAC that might be appropriate for reuse. The development consists of individual mobile homes. 7. The alternative appears to be an expansion of the existing surface water discharge. Following Mr. Belnick's review of the original EAA, the flow increase was revised to a total flow for the facility of 60,000 gpd. In his letter, he indicated that it would be necessary to provide a revised discussion of the proposed facilities and a revised cost estimate. Due to the fact that the original submittal indicated the only viable alternative for the expansion is a surface water discharge (as detailed above) the cost associated with expanding the facilities to 60,000 gpd have been limited to the required treatment to comply with the anticipated discharge limits, specifically the TN of 3.67 mg/l for the 60,000 gpd flow. The addendum prepared by Rebecca Tolliver provides the requested cost estimate. Hopefully I have provided you with all of the information necessary to process the request. If you require any additional information, please do not hesitate to call. Sincerely, Matthew Raynor NATURE TRAILS FACILITY UPGRADE TO 60,000 GPD The Nature Trails Facility requests that the facility discharge be allowed to expand from the existing 40,000 gpd flow to a projected flow of 60,000 gpd. The request is a change from the previous request for an expansion to 80,000 gpd. It is understood that the discharge criteria for total nitrogen is based on a TN of 5.5 based on the prior flow of 40,000 gpd. The allowed loading for the proposed discharge of 60,000 gpd will thus be a TN of 3.67. It is also understood that the limit will be a mass based limit. " The facility desires to move ahead with the request. A treatment facility to meet these strict criteria will be designed and is to incorporate aero " aand anoxic treatment chambers to obtain the required treatment. Final filtration is also proposed prior to ultraviolet disinfection. The main treatment facilities are to be new units. Portions of the existing facilities are to be incorporated into the new plant. The facility influent pump station is to remain. A new remote station will be required for flows generated on portions of the property located at an elevation lower than the existing station. The new station will direct influent flow to the equalization facilities. It is anticipated that the existing surge tank will remain in operation. In addition, a portion of the existing plant will be converted to additional equalization. This expansion will afford the required surge capacity. Two of the existing basins will be converted to equalization; conversion of two of the existing basins will provide a total surge capacity of 20,000 gallons. The conversion will incorporate the installation of grinder pumps. The converted facilities will have pumps to match the existing. There will then be a total of four surge pumps each rated at 30 gpm The existing facility and the converted portion of the existing plant will both discharge to the new treatment plant. Aeration is provided in the existing surge basin and will remain in the basins to be converted to surge control. Dual new package type secondary treatment plants are to be installed. The facilities are to include anoxic and aerobic zones. Each train will treat 30,000 gpd. The initial tank in the flow scheme is to be an anoxic basin, followed by an aeration basin and a clarifier. There will be another anoxic basin and aerobic basin and clarifier. The plant will also have chemical addition for phosphorus removal. There are to be polishing filters prior to UV disinfection. A schematic has been provided indicating the proposed flow configuration. The remaining, six existing aeration basins in the existing facility will be converted to sludge management/holding facilities. In addition the existing sludge holding facilities are to be retained. The existing clarifiers will be evaluated and a determination made regarding their reuse. The expanded sludge holding will be beneficial for the scheduling of final sludge management. Based on the need to recycle flows to achieve the required level of treatment, the basins are to include adequate capacity to address the return flows. A brief description of the proposed facilities follows. Influent Pump Station — The existing station is to remain. An additional station may be required to address flows generated from a topographic location lower than the existing station. The pump station, when required, is to be handled as a separate item The existing pump station pumping capacity will be upgraded as necessary to meet demand. Both stations (existing and future) will pump to equalization. Equalization -- The existing 10,000 gallon equalization basin is to remain. Two of the 5,000 gallon basins in the existing plant are to be converted to equalization as well for a total capacity of 20,000 gallons. Each of the converted basins will be equipped with a 30 gpm grinder pump. The converted basins will be equipped with an influent bar screen and will be interconnected. Secondary treatment — Secondary treatment will include two plants each capable of treating 30 000 gpd. Each facility will be equipped with anoxic (with mixers) and aeration chambers. The proposed capacities for each facility are to be approximately 6,000 gallons initial anoxic zone, 15,000 gallon aerobic zone, 5,000 gallon clarification, 3,000 gallon anoxic zone, 3,000 gallon aerobic zone, 5,000 gallon clarifier. Filtration — Tertiary filters are to be provided. The filters are to be dual filters sized to treat the 60,000 gpd flow. The filters may be DynaSand filters. The DynaSand filter is a continuous backwash, upflow, deepbed, granular media filter. Tertiary denitrification is accomplished by establishing an organic substrate in the anoxic zone of the sand filter. A methanol addition may be required to establish the substrate and achieve nitrate reduction. Phosphorus removal - It is anticipated that there will be chemical addition (ferrous sulfate) to the treatment plant for the removal of phosphorus. Sludge dement — Waste sludge is to be managed in the existing sludge digestion/holding (15,000 gallons) facilities and six of the existing aeration basins (30,000 gallons) are to be converted to sludge management units. The expanded capacity for sludge management will afford flexibility required for the ongoing contract biosolids management operations. It is anticipated that a new equipment building will be provided to house mechanical equipment and provide space for control and lab equipment. The emergency generator will be associated with the equipment building as well. Costs have been estimated for the proposed facility upgrade and are presented below New Influent Pump Station — To be handled as a separate contract. Upgrade to existing pump station (as necessary) $10,000 Modification to provide additional equalization in existing basins $15,000 Secondary treatment facilities $2855000 Tertiary treatment $65,000 UV Disinfection $20,000 Sludge Management Modification $80,000 Miscellaneous mechanical/electrical $50,000 Maintenance building $703,000 Generator $503,000 Site work $501,000 Sub Total $695,000 Contingency $70,000 Engineering/Survey Stake-out/Control $25,000 Estimated Total project cost $790,000 Secondary Schematic Layout of Proposed Treatment Plant Upgrade Filter Filter Operations Building Ex. Existing EQ SHT SHT SHT EQ Q Reserve I SHT SHT I SHT Reserve New Facilities Highlighted Existing Facilities to be Retained & Reused Flow Meas Discharge mailbox:///C I /Documents%20and%20Settings/charles weaver/Appli... Subject: Re: Nature Trails Association - Chatham County From: Charles Weaver <charles.weaver@ncmail.net> Date: Wed, 21 Jan 2004 07:44:04 -0500 To: Jack Roskoz <rjroskoz@nc.rr.com> CC: Tom Belnick <Tom.Belnick@ncmail.net> Mr. Roskoz: The Carlyle Group [owners of Nature Trails MHP] submitted a request to expand the Nature Trails WWTP from 0.4 MGD to 0.8 MGD on March 10, 2003. That submission was poorly prepared and incomplete; additional information was requested on March 11, 2003. Sixty days passed, during which no additional information was submitted. The application was returned on May 19, 2003 [see attachment Return 2193.doc]. The Carlyle Group was notified that they could re -submit the application within 6 months [by late November 20031 and pay no additional fees IF they submitted all the necessary information. The Carlyle Group submitted another incomplete application on January 12, 2004 with no fee, seemingly oblivious to all they had been told during 2003. That application was returned on January 14, 2004 [see attachment Return2208.doc]. If you have additional questions about the 2003 submittal, contact Tom Belnick [tom.belnick@ncmail.net] in our Unit. I'd also recommend you contact Bob Mangum or Randy Jones at the NC DENR Raleigh Regional Office [919 571-4700]; Bob did a site inspection in 2002 and Randy may also be familiar with that facility. CHW 1 of 1 1 /21 /2004 7:44 AM imap://charles. weaver%40dwq.denr.ncmail.net@cros.ncmail.net:143/f... Subject: Nature Trails Association - Chatham County From: Jack Roskoz <rjroskoz@nc.rr.com> Date: Tue, 20 Jan 200415:30:49 -0500 To: charles.weaver@ncmail.net Dear Mr. Weaver, I am writing you because you are identified as having been the primary reviewer of the Association in Chatham County back in 2001. on the list of issued NPDESWWRRO permits permit issued (NC0043257) to Nature Trails I have been in contact with Nature Trails for the last year regarding the noise level coming from their waste treatment plant. They told me last February that they were planning a new "package plant", had applied to the State for approval, and expected to be under construction in 2 or 3 months. I said fine presumably the new package plant would have the offending motor/pump enclosed or in some other location as would solve the noise problem. Having seen no construction activity, I inquired of them back in August and again in November regarding the plant. They continue to say they were waiting for State approval and that was the cause of delay. I recently have been checking on what info might be available from NC Division of Water Quality and found two lists. The first listing issued permits (where I found your name and the permit number for Nature Trails) and the second listing of pending permits - which, I assume, would include Authorizations to Construct. I don't see anything relating to Nature Trail in either list which would indicate that an application for a new waster treatment plant has been made. Perhaps I have not found the correct source of information or perhaps it is not available on line. Before I go further with Nature Trails, I would ask if you, or someone to whom you could refer the question, could verify that an application for a new waste disposal plant has been made. And, if so, is there some particular problem with the permitting of same, i.e. have they provided sufficient information, etc. Thank you in advance for your attention to my request. Jack H. Roskoz 60136 Davie Chapel Hill, NC 27517 919-967-8900 1 of 1 1/21/2004 7:44 AM F'n ©DA Mr. Matthew Raynor The Carlyle Group 5604 Preston Place Raleigh, North Carolina 27604 Dear Mr. Raynor: Michael F. Easley Governor William G. Ross, Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality January 14, 2004 Subject Return of NPDES Application Nature Trails MHP NPDES No. NC0043257 Chatham County Return # 2208 The Division is returning your NPDES permit modification request to expand your permitted flow from 0.40 MGD to 0.60 MGD. This modification request was received on January 12, 2004. In the last return letter dated 5/19/03 (Return #2193), the Division indicated that the perrnit modification fee of $215 would be applied for any subsequent submissions received within six months. Since your submission was received outside this timeframe, you will need to include a new permit modification fee. In addition, as indicated in the last letter, the previous application was returned as incomplete. In order for us to accept another application and begin the review process, you will need to resubmit a complete application package, which includes three copies of the application and EAA. If you have any questions about submission requirements, please contact me at 919-733-5083, ext. 543. Sinc ely, om Belnick NPDES Unit cc: Rebecca Tolliver, Culpepper Engineering, POBox 733, Locust Grove, VA 22508 NPDES File Return Letter File N. C. Division of Water Quality I NPDES Unit Phone: (919) 733-5083, extension 511 Fax: (919) 733-0719 1617 Mail Service Center, Raleigh, NC 276WI617 DENR Customer Service Center..1 800 623-7748 Internet: h2o.enr.state.nc.us e-mail: charles.weaver@ncmail.net CULPEPER ENGINEERING, P.C. P.O. BOX 733 LOCUST GROVE, VIRGINIA 22508 PHONE: 540 423-9706 FAX: 540 423-1534 September 3, 2003 Mr. Charlie Horne, County Manager Chatham County P.O. Box 87 Pittsboro, NC 27312 Re: Nature Trails Mobile 'dome Park NPDES Permit Application Dear Mr. Horne, The Nature Trails Mobile Home Park has been in contact with the Division of Water Quality -- NPDES Unit regarding the expansion of the wastewater treatment facility at the Nature Trails MHP from a flow of 0.04 MGD to a capacity of 0.06 MGD. As part of the process, the facility is required to request the local government complete the attached Local Government Review Form. The form requests that the County which has jurisdiction complete and return the form to the applicant. Once you have reviewed the provided information and completed the form, please return it to the Nature Trails M.H.P., L.L.C. local representative, Matthew Raynor. His mailing address is: Matthew Raynor 5604 Preston Place Raleigh, NC 27604 If you have any questions regarding any of the attached information, please do not hesitate to contact me at 540 423-9706 or Mr. Raynor at 919 217-0036. Thank you for your assistance in this matter. Sincer Reb ca. S. Tolliver, P.E. Local Government ]review Requirements for the issuance of New Non -Municipal Domestic wastewater Discharge Permits General Statute Overview North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has received a written statement from each city and county government having jurisdiction over any part of the lands on which the proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide significance and is in the best interest of the State. instructions to the Applicant Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant shall request that nth. the aearbv cry and cOmM gnvernment complete this form. The applicant must: ♦ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and the county by certified mail, return receipt requested. ♦ If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to the NPDES Unit. ♦ As evidence to the Commission that the local govemment(s) failed to respond within 15 days, the applicant shall submit a copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the 15-day period. Instructions to the i..ocal overnment The nearby city and/or county government which may have or has jurisdiction over any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this form to the applicant within 15 da s of receipt. The form must be signed and notarized. Name of to go cal vernment C� �A�" e-191 V1 (City/County) Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be located? Yes No [ ] If no, please sign this form, have it notarized, and return it to the applicant Does the city/county have in effect a zoning or subdivision ordinance? Yes [1(] No [ ] If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes No [ Signature ((City Manage County Manager) of State o€� C.�rOli County n this dh —.day of 2, personally appeared before me, the said • to me known and known to me to be the person name_ e 1-�- A c� t Sb n - escribed in and who executed the foregoing document and he (or she) acknowledged that he (or sheCIM11tt d �� executed the same and being duly sworn by me, made oath that the statements in the foregoing are true. My Commission expires Jq b (p .(Signature of Notary Public) LX!yNo TA#j NPDES APPLICATION FOR PERMIT RENEWAL - SHORT FORM A For municipal discharges < 1 MGD without a pretreatment program (or similar publicly owned discharges <1MGD) N. C. Department of Environment and Natural Resources Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 http://h2o.enr.state.nc.us/NPDES/ NPDES Permit CO043257 Please print or type r 1. Contact Information: Facility Name Nature Trails MHP WWTP Owner Name Nature Trails MHP, LLC ATTN: Matthew Raynor Street Address 5604 Preston Place City Raleigh State / Zip Code North Carolina, 27604 Telephone Number ( 919 ) 217-0036 Fax Number ( 919 ) 217-4070 e-mail Address tarmatt@aol.com Operator Name John Dodson Street Address 5728 Chambers Court City Cedar Grove State / Zip Code North Carolina, 27231 County Orange Telephone Number ( 919 ) 245-0145 2. Location of facility, producing discharge: Check here if same as above Facility Name (If different from above) Nature Trails MHP W'WTP Street Address or State Road 326 Nature Trails Road City Chapel Hill State / Zip Code North Carolina, 27517 County Chatham 3. Design flow of facility 0.06 MGD. Average monthly flow 0.032 MGD Existing facility is permitted for 0.04 MGD (12 Month Average) 4. Population served: 1-199 200-499 500-999 1,000-4,999 5,000-9,999 10,000 or more S. Do you receive industrial waste? ❑ Yes a No If yes, enter approximate number of industrial dischargers into system NPDES APPLICATION FOR PERMIT RENEWAL - SNORT FORM A For municipal discharges <1 MGD without a pretreatment program (or similar publicly owned discharges <1MGD) 6. List all permits, construction approvals and/or applications: T r e Permit Number RCRA NA UIC NA NPDES NCO043257 PSD NA NESHAPS NA Type Permit Number Non -Attainment NA Ocean Dumping NA Dredge/Fill Permits NA Other NA 7. Name of receiving stream(s) (Provide u map showing the exact location of each outfall): Cub Creek S. Is this facility located on Native American lands? (check one) YES R NO a 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. 0 Printed name of Person Signing Signature of Applicant A_-1k 4,-LW Title Date North Carolina General Statute 143-215.6 (b)(2) states: 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 knowly 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 monthnsonment not morel than 5 years, or both, fop a similar punishment by a fine of not more than $10,000 or imp offense.) 12102 2of2 `0 0 3 10: -'-35 91921740-0 MATT RAYNOR PAGE 02 NCO0432S7 tu r c T ra i I s NI f -11 V*S-U,..; N'�N,�' k_ I Vy Fac'l- Location t h SCALE R NCDENR 1 Y I\It. Matthew Ravnor The Carlyle Group 5604 Preston Place Raleigh, North Carolina 27604 Dear Mc. Raynor: Michael F. Easley Governer William G. Ross, Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality May 19, 2003 Subject: Return of NPDES Application Nature Trails MHP Chatham Counts Return # 2193 The Division is returning your NPDES permit modification request to expand your pe—,tutted flow from 0.40 i IGD to 0.80 MGD. This modification request was received on March 10, 2003. The NPDES Unit subsequently requested additional information on March 11, 2003, but has not received this data. Due to the volume of permits curendv under review, the NPDES Unit is unable to store incomplete applications pending receipt of additional data. If you resubmit a completed application within sit months, your original application fee will be applied towards the resubmission (Note: please include a copy of this letter to support a resubmission without fee). The resubmission should address the following items: L Incomplete evaluation. Based on discussions with Culpeper Engineering. i_ appears that you now plan to request an expansion to 60,000 gpd, rather than 80,000 gpd. The EA -A cost estimates should be based on treating 60,000 gpd. Please note that based on House Bill 515 requirements, the total nitrogen mass Ln- t is frozen based on a TN concentration of 3.5 mg/1 and the permitted flow- as of 1997 (40,000 gpd). An increase to 60,000 gpd will effectively reduce the TN limit to 3.67 mg/1. However, please note that TN compliance will be based on a mass -based limit rather than a concentration -based limit. As previously discussed, you should include information on the nitrogen treatment capabiliry of the proposed package treatment system. There are no anticipated changes to the current ammonia-` limits of 2 mg/1 (summer) and 5 mg/ l (winter). 2. Local Government Review Form. The submittal lacked a completed Local Government Review Form. Enclosed please find a Local Government Revie•a- Form, as well as an Engineer_ng Alte_ :adves Guidance Document. If you have any questions about this project or permit application requirements, please contact Tom Belnick at (919, 733-5083,extension 543. Sincerely, David A. Good--ch NPDES Unit Supervisor cc: Raleigh Regional Office, Water Quafiry (Paul Clark) Rebecca Tolliver, Culpepper Engineering, POBox 733. Locust Grove, VA 22508 NPDES He dC 0043151 N. C. Division of Water Doaiity I NPDES Unit Phone: (919) 733-5053. exle— or. 511 Fax: (919) 733-0719 1617 Mail Service Center, Rale!ch. NC 27699-1 c17 DENR Customer Sernce Cer:e- 1 800 623-7748 Inlemet: h2o.enr.steterc.us e--ma!: ciades.wea,e-'�ncc.2..ra. CULPEPER ENGINEERING, P.C. P.O. BOX 733 LOCUST GROVE, VIRGINIA 22508 PHONE: 540 423-9706 FAX: 540 423-1534 May 2, 2003 Tom Belnick North Carolina Department of Environment and Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Re: Nature Trails Mobile Home Park Dear Mr. Belnick, £OOZ 5 - 1,V W �c This letter is to request that you temporarily place the previously submitted Engineering Alternatives Analysis regarding an expansion of the Nature Trails W WTF on hold. It is understood that this request should allow you to not respond to the request within the 180 day review period. Having spoken with you and Mr. Goodrich, it has been decided that the facility should limit their expansion request to 60,000 gpd. Prior to finalizing an amendment to reflect to flow modification, I would like to clarify the following items. Based on the requirements detailed in BB 515, it is understood that the total nitrogen loading permitted for an expanded facility is based on the statutory 5.5 mg/l total nitrogen concentration and the flow which was permitted at the time the NSW designation was made. Accordingly, it is understood that the total nitrogen loading which will be allowed for an expansion at this facility is limited to an annual loading resulting from an average concentration of 5.5 mg/1 @ 40,000 gpd or an average daily loading of 1.835#/day. Assuming the requested expansion to 60,000 gpd can be approved, the average daily total nitrogen allowed would be 3.67 mg/1 total nitrogen. It is understood that the loading is an annual average requirement. Prior to submitting an amendment to the EAA to reflect the reduced flow request, I would like to clarify proposed effluent limitations. Specifically, please clarify if the total nitrogen loading will be specific with regards to Ammonia-N concentration. The existing permit includes seasonal limits for Ammonia-N. Will these seasonal limits be continued at the expanded flow ? Specifically will the permit include a 1.3 mg/1 requirement for Ammonia-N during the period from April 1 through October 31 and a 3.3 mg/l limit specified during November 1 through March 31 or will the limits be expressed only as Total Nitrogen. It is assumed that the following limits would be required for a 60,000 gpd discharge: �l Parameter: Monthly Average: Flow 0.06 AGD _ BDD-5 11.33_mg/1_ TSS 20.0 mg/l Fecal Coliform 200/100 ml Total N 3.67 mg/1 Total P 1.33 mg/l I also was curious about the HB 515 notation that the total nitrogen limitation is described as an average, annual loading, criteria. I would like to understand the importance of this stipulation and be better able to clarify its meaning. If the permit is issued at 60,000 gpd and the new plant is constructed will the plant be in violation if a concentration limit is exceeded even if the loading is in compliance? As an example: if the facility is discharging at an average flow of 50, 000 gpd during a month and reports a total nitrogen result for the month of 3.88 mg/l is this a violation? The facility daily loading based on 60,000 gpd and 3.67 mg/1 is 1.84 #/day. Even though the concentration in the example is above the concentration of 3.67 mg/l the mass loading resulting from the sample presented is 1.62 #/day. Please clarify if this constitutes a violation or not. I was trying to be able to clarify this. I am proceeding with an EAA update which reduces the flow to 60,000 gpd and would appreciate the above clarifications so as to be able to provide you with a complete submittal. Again, please put the project review on hold until the update is finalized. It would be great if you could restart the 180 day review period once the update is presented. Since , Rebe S. Tolliver cc: Matt Raynor IWC Calculations Nature Trails MHP NCO043257 Prepared By: Tom Belnick, NPDES Unit Enter Design Flow (MGD): 0.06 Enter s7010(cfs): 0.075 Enter w7Q10 cfs): 0.2 Residual Chlorine Ammonia (NH3 as N) (summer) 7Q10 (CFS) 0.075 7Q10 (CFS) 0.075 DESIGN FLOW (MGD) 0.06 DESIGN FLOW (MGD) 0.06 DESIGN FLOW (CFS) 0.093 DESIGN FLOW (CFS) 0.093 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 UPS BACKGROUND LEVEL (1 0 UPS BACKGROUND LEVEL 0.22 IWC (%) 5 6 IWC (%) 55.36 Allowable Conc. (ug/1) 31 Allowable Conc. (mg/1) 1.6 Ammonia (NH3 as N) (winter) 7Q10 (CFS) 0.2 Fecal Limit 200/100ml DESIGN FLOW (MGD) 0.06 (If DF >331; Monitor) DESIGN FLOW (CFS) 0.093 (if DF <331; Limit) STREAM STD (MG/L) 1.8 Dilution Factor (DF) 1.81 UPS BACKGROUND LEVEL 0.22 IWC (%) 31.74 Allowable Conc. (mg/1) 5.2 INPDES Servor/Current Versions/IWC 5/19/03 ENGINEERING ALTERNATIVES EVALUATION NATURE TRAILS MOBILE HOME PARK December 2002 Everette L. Chambliss, Jr. t The Wooten Company 120 North Boylan Avenue Raleigh, North Carolina 27603 Phone: (919) 828-0551 Table of Contents GENERALINFORMATION.....................................................................................1 Project ProjectDescription................................................................................................ I ExistingFacility..................................................................................................... I DISPOSAL ALTERNATIVES................................................................................... 3 Connection to a Publicly Owned Treatment Connection to a Privately Owned Treatment Works .............................................. 3 Individual Subsurface Systems..............................................................................3 Community Subsurface Systems...........................................................................4 Drip or Spray Irrigation System............................................................................ 4 Reuse..................................................................................................................... 5 Surface Water Discharge Through the NPDES Program......................................6 Alternative Comparisons and Costs....................................................................... 9 SUMMARY..............................................................................................................10 FIGURES Figure 1 Flow Schematic Existing treatment Plant.................................................2 Figure 2 Flow Schematic Proposed Treatment Plant Expansion ............................8 GENERAL INFORMATION PROJECT IDENTIFICATION The project consists of expanding the wastewater treatment capacity of the Nature Trails Mobile Home Park wastewater treatment plant in Chatham County, North Carolina. This facility is located off of NCSR 1009 and discharges into Cub Creek in the Cape Fear River Basin. The treatment plant discharges under the terms of NPDES Permit Number NC0043257. There arc no office or telephone facilities at the wastewater treatment plant, but the management for the facility can be reached by calling Mr. Matthew Raynor at 919-217-0036. This report has been prepared by: Mr. Everette L. (Ford) Chambliss, Jr., PE The Wooten Company 120 North Boylan Avenue Raleigh, North Carolina 27603 Phone: (919) 828-0531 PROJECT DESCRIPTION The Nature Trails Mobile Home Park is not completely built out, and there exists within the confines of the Mobile Home Park numerous sites where additional trailers may locate. There also exists within Chatham County and the Triangle area as a whole a strong demand for affordable housing like that offered in the Nature Trails Mobile Home Park. Accordingly, management of the the Nature Trails Mobile Home Park wishes to continue to add units until its wastewater flow is 0.080 mgd. Increasing its discharge to 0.080 mgd will not exhaust its capacity to add housing units, but this level of development has been selected because it can be accommodated with a treatment system without any increase in the wasteload allocation now embodied in the Nature Trails Mobile Home Park NPDES Permit. EXISTING FACILITIES The Nature Trails Mobile Home Park existing wastewater treatment facilities will generally not be kept in service in their existing capacity. These facilities consist of an influent pump station, and an equalization tank/pump station (added in 1998), the original treatment system, and sludge holding tanks added recently. Figure 1 is a schematic flow Wastewater Treatment Plant Expansion Study flow diagram of this system. The original treatment plant consisted of a series of 10 precast concrete tanks configured to act as aeration basins and settling tanks, and additional similar tanks used for sludge digestion/holding. As actual flows approached design flows, reliable operation became progressively more difficult, and the equalization basin was added. This basin proved effective in allowing for better process control and better clarifier efficiencies, and the facility has been able to consistently meet effluent limits while operating essentially at design flow. Stabilized sludge is disposed of by contract sludge hauler. The sludge holding tanks were added to assure that inclement weather preventing disposal operations would not force the aeration basin to operate at excessively high sludge ages, and these tanks have also contributed to process stability. The original core system is, however, more than 20 years old, and is not readily amenable to upgrading or expansion. �ixar In+In M y Wastewater Treatment Plant Expansion Study FIGURE I FLOW SCHEMATIC, EXISTING TREATMENT PLANT DISPOSAL ALTERNATIVES CONNECTION TO A PUBLICLY OWNED TREATMENT WORKS Connection to a public owned treatment works would allow the discharge of the Nature Trails Mobile Home Park to be eliminLe egrettabl est ublicly owned treatment works is that of theDurh?62nection ore th 8 miles awa d ins another County. The distance alone m economically infeasible. Even if distance were not so great, there are other problems that would prevent the connection. As a private enterprise, Nature Trails Mobile Home Park has no means to secure the force main route to the Durham plant. While encroachment agreements with the NC DOT (North Carolina Department of Transportation) could probably be secured, NC -DOT attorneys have repeatedly advised that for private enterprises, easements from all property owners along the pipeline route may also be required. Nature Trails Mobile Home Park is, with no power of eminent domain, in no position to secure such easements. Even were the distance and easement obstacles to be overcome, it is doubtful the City if Durham would agree to yield any of its capacity to a private development in another County. CONNECTING TO A PRIVATELY OWNED TREATMENT WORKS There is a privately owned, treatment works located relatively close to the Nature Trails Mobile Home Park facility. This is the treatment system operated for the Governors Club. This facility was contacted informally about providing capacity to the Nature Trails Mobile Home Park. Not surprisingly, no capacity was offered, since the Owner's of the facility need all that treatment capacity they can secure to meet the needs of their own development. INDIVIDUAL SUBSURFACE SYSTEMS The development density, steep terrain, and predominate soil characteristics preclude use of individual on -site subsurface systems. The original surface discharge treatment system was installed because of the unsuitability of individual on -site systems for the predominate soils and development density of the mobile home park. Wastewater Treatment Plant Expansion Study COMMUNITY SUBSURFACE SYSTEM The Nature Trails Mobile Home Park does have an undeveloped, relatively flat area near its entrance that could potentially be employed for wastewater disposal. This area is in a broad floodway, and consists of Creedmoor type soils. Creedmoor soils are poorly drained clayey soils with only limited potential for use with on -site disposal. It is expected that if used for a subsurface treatment/disposal system, these soils could sustain no more than 0.1 gallons per day per square foot, and possibly as little as 0.05 gallons per day per square foot. Even using the higher value of 0.1 gallons per day per square foot would require a disposal/treatment area of 400,000 square feet (9.2 acres) if a the system were just built to handle the proposed 40,000 gallons per day of expansion, and 800,000 square feet if the system were built to handle the entire 80,000 gallons per day of design flow. There is simply not this much undeveloped land available. DRIP OR SPRAY IRRIGATION SYSTEM Irrigation systems, because these types of systems utilize the most biologically active and most easily reaerated top portion of the soil, offer potentially better treatment than sub- surface systems. In additional, since such systems are typically built with extended storage facilities for holding of wastewater during times when spraying is not feasible, these systems can still be considered for use on land where flooding occurs, as long as ^ n ) the flooding is infrequent and not extended in duration. Land area requirements for such l� systems, can, however, be extensive, depending on the type of soils available. Although p 071 SCS soils mapping has not yet been published for Chatham County, much of the workL� U rf for the County has been done, and individual soils maps are available for the Nature 0 Trails Mobile Home Park area. These maps show that the only non -developed area, a relatively flat, low area at the Park entrance, to be Creedmoor soils. A water balancee_l these types of soils was performed to estimate the type of loading the soils could sustain. This analysis is shown on the following page. An annual loading of only 17.0 in hes is shown as being possible with the Creedmoor soils. This loading rate equates to an acreage requirement, for a 40,000 gallon per day system, of 31.5 acres as shown below: 40,000 Ls- x 365 days Acreage = `a'' ym = 31.53 acres 27,156 acmewchioce x 17.05 re- — The acreage required for the full 80,000 gallons per day would be twice this amount, over Wastewater Treatment Plant Expansion Study 63 acres. There is insufficient land available for either a 40,000 gallon per day or a 80,000 gallons per day land application system. Water Balance - Creedmoor Soils Triangle Area Water Losses Water ADnlied Month Evapo- Drainage Total Trecip- Effluent Total Transpiration (inches) (inches) tation Applied (inches) Oct 2.1Y 2.81' 4.98 3.30 1.68- 4.98 Nov 1.50 2.81 4.31 3.62 0.69 4.31 Dec 0.93 2.81 3.74 4.45 0.00 4 47 Jan 0.93 2.81 3.74 4.10 0.00 4.10 Feb 1.68 2.81 4.49 4.44 0.05 TV Mar 2.79 2.81 5.60 4.68 0.92 5.60 Apr 3.60 2.81 6.41 3.60 2.81 6.41 May 4.65 2.81 7.46 4.54 2.92 7.46 Jun 5.10 2.81 7.91 5.37 2.54 7.91 Jul 4.96 2.81 7.77 5.90 1.87 7.77 Aug 4.34 2.81 7.15 5.91 1.24 7.15 Sep LO 281 §.Al 407 6.41 Total 36.25 33.72 69.97 53.99 17.05 71.04 Drainage Rate Calculation: Depth (inches) Water Loss % volume) Drainage Per Cycle Inches Top Horizon 8 inches 12.3% 0.984 inches Basic Considerations: (1) Irrigation Time 0.5 day (2) Drainage Time 7.0 day (3) Reaeratlon Time 31Q �y Total Hydraulic Cycle Time 10.5 day Drainage Rate, inch/month = 30 days/monthx 0.984 inch/cycle = 2.81 inch/month 10.5 days/cycle -- REUSE The Nature Trails Mobile Home Park is a relatively densely developed residential development in a hilly area. Where possible, existing vegetation (forest) has been left in place. The slope, soils, and dense development present minimal opportunities for landscape type irrigation as a reuse source. There are no centralized facilities that could use reuse water for HVAC (heating, ventilating, and air conditioning) purposes. The mobile homes themselves,, with their resident populations including a large number of infants and children, are not good candidates for installation of gray water systems (i.e. use of reuse water for toilet flushing, car washing, etc.). The adjacent development s part of the Govenors's Club, which already employs reuse water wherever practicle. Wastewater Treatment Plant Expansion Study 5 Therefore, reuse on -site and reuse off -site are not considered a viable alternatives to discharge. SURFACE WATER DISCHARGE THROUGH THE NPDES PROGRAM The Nature Trails Mobile Home Park currently operates a wastewater treatment plant discharging into Cub Creek. Cub Creek waters eventually discharges into B. Everett Jordan Lake. An official with the North Carolina Division of Water Quality was contacted regarding the feasibility of increasing the permitted discharge into Cub Creek. That official advise that an increase in permitted flow would be possible, but an increase in wasteload allocation would not be possible, and that any expanded plant should have nitrogen and phosphorous removal capability. The planned increase in wastewater from 0.040 mgd to 0.080 mgd would therefore result in concentration based limits for critical parameters that are half of the values contained within the existing permit. These limits, while stringent, are within the bounds of what is technically achievable. Existing and projected future limits are listed as follows: Flow BOD-5 TSS NH3-N (April 1 - October 31 NH3-N (November 1 - March 31) Fecal Coliform Total Nitrogen Total Phosphorous 0.040 mgd 0.080 mgd 17.0 mg/L 25.5 mg/L 8.5 mg/L 30.0 mg/L 45.0 mg/L 30.0 mg/L 2.0 mg/L - 1.0 mg/L 5.0 mg/L 2.5 mg/L 200/100m1 400/100 ml 200/100ml - - 5.5 mg/L 2.0 mg/L 12.7 mg/L 45.0 mg/L 400/100 ml Figure 2 is a schematic of the proposed wastewater treatment system. Each major component of the system is described as follows: Influent Pump Station: The existing influent pump station and basket screen will be kept in service. The influent pumps will be increased in capacity to 167 ppm units. Equalization/Anaerobic Reactor: The existing equalization basin will be kept in service but modified. Mixers will be provided, and the return activated sludge will be rerouted to flow through this tank, allowing the unit to serve as an anaerobic selector tank or- he biological phosphorus removal prop. -The normal operation of the system will be for the mam pumps to discharge into an elevated adjustable weir box. The weir will be adjusted so that in normal operation the discharge from the wier box to a new treatment Wastewater Treatment Plant Expansion Study 6 unit will be set to approximate the sum of the then current average daily influent flow flow and the return activated sludge flow. Wastewater pumped in excess of flow rate will be returned to the Equalization/Anaerobic Reactor tank. Float levels for pump control will be set so that 2 to 4 hours retention time (based on the then current approximate value of the average daily flow) will be achieved in the tank. If flow levels rise above the 4 hour retention time level, then a second pump will come on. This second pump will discharge directly into the elevated weir box discharge line so that none of the second pump discharge is routed back to the Equalization/Anaerobic Reactor tank. A total of 3 pumps will be provided, so that with one pump out of service, up to 222 M can be effectively discharged from the Equalization/Anaerobic Reactor tank. Anoxic Reactors.: -Dual anoxic reactors will be provided with a combined volume of approximately 13,300 gallons. These reactors will be compartments in a new painted steel treatment unit. The anoxic reactor compartments will have mixers, and in addition to the influent will receive mixed liquid recycled from the adjoining aerobic reactor compartments (aeration basins). Aeration Basins: The same new painted steel treatment unit that houses the anoxic reactors will contain dual aeration zones (aerobic reactors) with a combined volume of 75,000 gallons. These reactors will be -equipped with fine bubble diffusers for aeration and mixing. Pumps will also be provided in each basin to recycle up to 320,000 gallons per day of nitrified mixed liquor from the aeration basin to the anoxic reactor zones. Anoxic/Aeration Polishing Zones: The same new painted steel treatment unit will contain at the effluent end small anoxic and aerobic polishing reactor zones totaling 5000 gallons. The anoxic zone will have mixers, while the aerated zone will have fine bubble diffusers for aeration and mixing. Discharge from the final aeration zone will be combined and directed to a new final clarifier. Final Clarification: A new final clarifier will be provided. This unit be a center feed, peripheral withdrawal unit will have a diameter of 20 feet, and a side water depth of 14 feet. The unit will have a rotating rake system for bottom sludge withdrawal, and a rotating top arm for scum removal. A telescopic valve mounted in an exterior compartment will be used for sludge removal and wasting. Return sludge will be routed to the Equalization/ Anaerobic Reactor tank. Waste sludge and scum will be routed to the existing aerobic digesters. Tertiary Filters: Clarified effluent will be discharged to a package tertiary filter system. A two filter cell unit with integrated clear well and mudwell will be used. A minimum of 66 square feet of -filter surface will be provided. UV Disinfection: Filtered effluent will be directed to a new, package UV disinfection treatment unit. This unit will connect to the existing effluent discharge weir box. Sludge Digestion/Holding: The existing 15,000 gallons of sludge digestion and holding will remain in service. In addition, all of the existing aeration basin capacity will be available for sludge holding and digestion on an emergency basis. Contract sludge disposal will continue to be utilized. . Back-up Clarification: The existing two clarifier units will be kept available as back-up units should it ever be necessary to remove the new clarifier from service for maintenance. The existing clarifiers will not, however, be used under ordinary conditions. Back-up Phosphorous Removal: A tote type alum feed system (using sodium aluminate, so that pH adjustment will not be necessary) will be used as a backup for the biological Wastewater Treatment Plant Expansion Study phosphorous removal system. This will alleviate need for providing dual units for the Equalization/Anaerobic Reactor tank. FH3uNrT Fkow SC>*MATIC, PPoiWAFD i1LAiMENt VVNr CAVAMMW Wastewater Treatment Plant Expansion Study ALTERNATIVE COMPARISONS AND COST It is customary in an Engineering Cost Analysis to perform a cost-effective analysis of the alternatives. However, in the case of the Nature Trails Mobile Home Park (Nature Trails MHP) this is not possible, since only one of the alternatives is technically feasible. There are no other surface discharge plants to which Nature Trails MBF could connect. On -site treatment of any type is not possible due to the limited available land area, and poor quality of soils on that land area. Therefore, the only viable alternative is expansion and upgrading of the exiting surface discharge system. The projected cost for this ,.....4..«., :- 'Upgrade Influent Lift Station $20,000 Modify Existing Equalization Weir Box $7,000 Modify Existing Equalization Pumps $15,000 New Package Treatment Units* Equipment & Basic Installation $3301,000 Base Slabs $45,000 Package UV Disinfection Equipment $15,000 Equipment Installation $5,000 Back -Up Chemical Feed System $5,000 Piping and Site Work $7%560 Electrical $44,200 Standby Generator $50,000 Sub -Total $615,760 Contingency $61,576 Engineering $34,664 Total $712,000 * Painted steel tank with multiple anoxic <<nd aerobic zones, package tertiary filters Wastewater Treatment Plant Expansion Study SiJNIlVIARY Nature Trails Mobile Home Park (MHP) wishes to approximately double the number of additional housing units so that it can better serve the demand for affordable housing for low and moderate income people in the Triangle Area. In doing so the amount of wastewater that will be generated in the development will increase to 80,000 gallons per day. Alternatives were evaluated for handling this 40,000 increase in flows above present permitted capacity. No existing treatment systems are available to which this discharge could be directed. A privately owned system is nearby, but the entire capacity of this system is needed to met the needs of its owners. The City of Durham operates the nearest publicly owned treatment system, but connection for it is not viable for three reasons:(1) the distance(8 miles) involved; (2) the Nature Trails MHP management does not have the legal authority required to secure the necessary rights -of -way for the transportation lines that would be needed to convey its wastewater to the Durham facility, and; (3) the City of Durham is unlikely to give up any capacity to serve a private development located well outside of its jurisdiction, and in another County. Land application systems, both subsurface and surface, were evaluated, and it was found that the Nature Trails Mobile Home Park did not have available anywhere near the land area required for such systems. The nature of the development at Nature Trails Mobile Home Park is such that there are is no viable alternative available to it to reuse treated wastewater, leaving Nature Trails Mobile Home Park with only one alternative, expansion of its wastewater treatment system and discharge. An expansion alternative has been developed that will allow Nature Trails Mobile Home Park to expand the treatment plant with no increase in its wasteload allocation from the State, to virtually eliminate its dependence on the oldest portions of its treatment system, and to meet the nutrient limits expected to be imposed with any wastewater treatment system expansion. The projected cost of these improvements is $712,000. Wastewater Treatment Plant Expansion Study 10 SOC PRIORITY PROJECT: Yes: No: x If Yes, SOC No.: NPDES STAFF REPORT AND RECOMMENDATIONS FOR NATURE TRAILS MHP Date:2/26/02 To: Water Quality Section NPDES Permitting Unit Attention: Charles Weaver County: Chatham Permit No.: NCO043257 PART I - GENERAL INFORMATION 1. Facility and Address: Nature Trails MHP 101 Nature Trails Chapel Hill, NC 27514 2. 3. 4. 5. 9 7 Date of Site Visit: 2/21/02 Report Prepared by: Bob Mangum MAR 14 2002 U I Persons Contacted and Telephone Number: Mathew Raynor-919-217-0036 Directions to Site: US 15-501 South of Chapel Hill, left on SR 1008, facility is on the right app. 2.5 miles. Discharge Point(s), List for all discharge points: Latitude: 35' 51' 32" Longitude: 79 ° 01' 51" Attach a USGS map extract and indicate treatment facility site and discharge point on map. U.S.G.S. Quad No.: D22SE U.S.G.S. Quad Name: Farrington Site size and expansion area consistent with application? Yes: x No: If No, explain: Non -Discharge Staff Report Page 1 o_ 8. Topography (relationship to flood plain included): WWTP appears to be above flood plain, surrounding area is flat and low. 9. Location of nearest dwelling: app.1000 ft. 10. Receiving stream or affected surface waters: Cub Creek a. Classification: WS-IV NSW b. River Basin and Subbasin No.: 03 06 06 C. Describe receiving stream features and pertinent downstream uses: Jordan Lake is downstream PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of Wastewater to be permitted: 0.040 MGD b. What is the current permitted capacity of the Waste Water Treatment facility? .04 MGD C. Actual treatment capacity of the current facility (current design capacity)? .04 MGD d. Date(s) and construction activities allowed by previous Authorization to Construct issued in the previous two years:n/a e. Please provide a description of existing or substantially constructed wastewater treatment facilities: influent pump station -equalization basin - flow splitter box -aeration basins -dual clarifiers -aerobic sludge digesters - tertiary sand filters -effluent chlorination -flow monitoring f. Please provide a description of proposed wastewater treatment facilities: n/a g. Possible toxic impacts to surface waters: NH3 chlorinated effluent h. Pretreatment Program (POTWs only): in development: approved: should be required: not needed: n/a 2. Residuals handling and utilization/disposal scheme: a. If residuals are being land applied, please specify DEM permit no.: Residual Contractor: Granville Farms Telephone No.: Non -Discharge Staff Report Page 2 b. Residuals stabilization: PSRP:x PFRP: Other: C. Landfill: d. Other disposal/utilization scheme (Specify): 3. Treatment plant classification (attach completed rating sheet):Class II 4. SIC Code(s): 6515 Wastewater Code(s) of actual wastewater, not particular facilities i.e.., non -contact cooling water discharge from a metal plating company would be 14, not 56. Primary: 08 Main Treatment Unit Code: 051-3 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved. (municipals only)?n/a 2. Special monitoring or limitations (including toxicity) requests:none 3. Important SOC, JOC or Compliance Schedule dates: (Please indicate) Date Submission of Plans and Specifications Begin Construction Complete Construction 4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available? Please provide regional perspective for each option evaluated. Spray Irrigation:n/a Connection to Regional Sewer System:n/a Subsurface:n/a Other disposal options: none 5. Other Special Items: Non -Discharge Staff Report Page 3 c PART IV - EVALUATION AND RECOMMENDATIONS The Raleigh Regional Office has received the submittal package requesting renewal of the subject NPDES Permit. All submitted material has been reviewed by this office and a site visit has been also been performed. Therefore, this office has no objection to the renewal of this permit. Signature of report 2/��/62— Date Water Quality Regional Supervisor Date Non -Discharge Staff Report Page 4