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HomeMy WebLinkAboutNC0089541_Permit Issuance_20150908Pat McCrory Governor NCDENR North Carolina Department of Environment and Natural Resources September 8, 2015 Mr. Michael Lancaster, Operations Manager Ashton Lewis Lumber Company 96 Lewis Mill Road Gatesville, North Carolina 27938 Dear Mr. Lancaster: Donald R. van der Vaart Secretary Subject: Issuance of NPDES Permit Permit No. NCO089541 Ashton Lewis Lumber Company Gates County Facility Class PCNC Division personnel have reviewed and approved your application 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 Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). No changes were made to the draft permit sent to you on May 20, 2015. The final permit authorizes the Ashton ' Lewis Lumber Company to discharge wastewater from wet deck log storage site to an unnamed tributary to the Bennetts Creek, a class C; NSW water in the Chowan River Basin. The Permittee provided comments about the on -site ORC. After conferring with NC Operators Certification Program and Washington Regional Office, the facility classification was changed to physical chemical not classified (PCNC) and the facility is not required to have an ORC or a back-up. As identified previously, the new permit contains the following significant limitations, monitoring and reporting requirements: • The requirement to begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your NPDES permit. [See Special Condition A.(4.)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://portal.ncdenr.or. web/wq/admin/bog/ipu/edmr. For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the following web site: httu://www2.eDa.gov/compliance/proposed-npdes-electronic-reporting-rule. • Through discussion with your design engineer Mr. Sean Coury, the Division has decided to permit two outfalls (Outfall 001 and Outfall 002) that discharge wastewater from wet deck process (including stormwater) and boiler blowdown, respectively. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Phone: 919-707-86001 Internet: www.ncdenr.gov An Equal opportunity 1 Affirmative Action Employer — Made in part by recycled paper • Outfall 001 has numeric and/or narrative limitations on pH, total suspended solids (TSS), debris, floating solids/visible foam with weekly monitoring of flow, pH, oil and grease, and quarterly monitoring of total nitrogen and total phosphorus. • Outfall 002 has numeric and/or narrative limitations on pH, floating solids/foam with quarterly monitoring of flow, temperature, pH, and chemical oxygen demand (COD). Note the upstream and downstream monitoring requirement of temperature is not necessary if the discharge is to a receiving stream that does not contain any flowing water at the time of discharge. • The Permittee shall obtain approval from the Division's Aquatic Toxicology Branch prior to the use of any biocide (not previously approved by the Division) in the effluent discharged under this permit. Approval for use of any biocide not previously approved should be requested at least 90 days in advance of any planned usage. Please complete Biocide Form 101 Worksheet at the following link: littp://portal.ncdenr.org/web/wq/swp/ps/nodes/forms. 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 Resources or any other Federal, State, or Local government permits that may be required. If you have questions concerning this permit, please contact Yang Song by e-mail (yang.song@ncdenr.gov) or phone at (919) 807-6479. Sincerely, Jay Zimmerman, P.G. Director, Division of Water Resources Enclosure: NPDES Permit NC0089541 cc: NPDES Unit Central Files Washington Regional Office / Water Quality Program e-copy: Susan Meadows, Aquatic Toxicity Branch Steve Reid, Wastewater Operator Certification & Training Sean Coury, P.E., Consulting Engineer, Coury Science & Engineering, PLLC Permit NCO089541 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Ashton Lewis Lumber Company is hereby authorized to discharge wastewater from a facility located at the Wet Deck Log Storage site 96 Lewis Mill Road Gatesville, NC Gates County to receiving waters designated as an unnamed tributary to the Bennetts Creek in the Chowan River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, and III hereof. The permit shall become effective ............................... October 1, 2015. This permit and the authorization to discharge shall expire at midnight on September 30, 2020. Signed this day .............................................. September 8, 2015. . Jay Zimmerman, P.G. r Director, Division of Water Resources By Authority of the Environmental Management Commission Page 1. of 6 r Permit NCO089541 SUPPLEMENT TO PERMIT COVER SHEET Ashton Lewis Lumber Company is hereby authorized to: 1. Discharge wet -decking wastewater runoff and stormwater at Outfall 001, and boiler blowdown wastewater at Outfall 002. Both outfalls are located at the wet deck log storage site. This facility is located in Gatesville, NC at 96 Lewis Mill Road in Gates County; and 2. Discharge at the locations specified on the attached map into an unnamed tributary to the Bennetts Creek, classified C; NSW waters in the Chowan River Basin. Page 2of6 Permit NCO089541 Part I A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — Outfall 001 [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] a. During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge wet -decking wastewater and stormwater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITATIONS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow 2 {MGD) Weekly Instantaneous Effluent Total Suspended Solids 3 30 mg/L 45 mg/L Weekly Grab Effluent s PH Not less than 6.0 S.U. nor greaterWeekly than 9.0 S.U. Grab Effluent Oil and Grease 3(mg/L) Weekly Grab Effluent Total Nitrogen (TN) 3'4 (mg/L) Monitor & Report Quarterly Grab Effluent Total Phosphorus (TP) 3 (mg/L) Monitor & Report Quarterly Grab Effluent Footnotes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A.(4.). 2. If no discharge during the month, report "No Discharge" on Monthly eDMRs. 3. Based on the episodic discharge condition, it is recommended that sampling for parameters shall coincide with flow measurement. 4. For a given wastewater sample, TN = TKN + (NO3-N + NO2-N), where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and (NO3-N + NO2-N) are Nitrate and Nitrite Nitrogen, respectively. b. There shall be no debris discharged from the facility. c. There shall be no discharge of floating solids or visible foam in other than trace amounts. d. There shall be no discharge of process wastewater pollutants associated with sawmill operations. Page 3 of 6 Permit NCO089541 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — Outfall 002 [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] a. During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge boiler blowdown wastewater from Gutfall 002. Such discharges shall be limited and monitored) by the Permittee as specified below: EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Daily Measurement Sample Sample Location CHAR.A.CTERISTICS Averse Maximum Frequency Type Flow MGD) Quarterly Estimate Effluent Temperature 2(°C) Quarterly Grab Effluent U stream & Downstream pH Not less than 6.0 S.U. nor Quarterly Grab Effluent eater than 9.0 S.U. Chemical Oxygen Demand (COD) (mg/L) Quarterly Grab Effluent Footnotes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A.(4.). 2. Effluent temperature will be regulated so that the temperature of the receiving stream does not increase more than: 2.8°C above the natural water temperature. The Permittee shall demonstrate compliance with the effluent temperature limitations by monitoring the temperature of the receiving stream upstream and downstream of the discharge outfall. The Division should be consulted in selecting representative upstream/downstream sampling locations. Upstream and downstream monitoring is not necessary if the discharge is to a receivinLy stream that does not contain any flowing water at the time of discharge. b. All boiler blowdown water sample locations shall provide representative samples of the discharge and require sampling prior to discharge commingling with any other waters or substances, such as stormwater or surface water to enable characterization of a pollutant of concern. c. There shall be no discharge of floating solids or visible foam in other than trace amount. Page 4 of 6 Permit NCO089541 A. (3.) BIOCIDE CONDITION [G.S. 143-2152143-215.1(b)] a. There shall be no chromium, zinc or copper added to the treatment system except as pre -approved additives to biocidal compounds. b. The Permittee shall obtain approval from the Division's Aquatic Toxicology Branch prior to the use of any biocide (not previously approved by the Division) in the effluent discharged under this permit. Approval for use of any biocide not previously approved should be requested at least 90 days in advance of any planned usage. c. Contact the Aquatic Toxicology Branch for detailed instructions on requesting approval of biocides: NC DENR / DWR / Aquatic Toxicology Branch 1623 Mail Service Center Raleigh, North Carolina27699-1623 A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS [G. S. 143-215.1(b)] Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will be adopted and is beginning implementation in late 2013. NOTE: This special condition supplements or supersedes the following sections within Part H of this permit (Standard Conditions for NPDES Permits): Section B. (11.) Signatory Requirements Section D. (2.) Reporting Section D. (6.) Records Retention Section E. (5.) Monitoring Reports 1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)l Beginning no later than 270 days from the effective date of this permit, the permittee shall begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with .EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / DWR / Information Processing Unit ATTENTION: Central Files / eDMR 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring Page 5 of 6 Permit NC008954 f data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary waiver by the Division. Information on eDMR and application for a temporary waiver from the NPDES electronic reporting requirements is found on the following web page: http://portal.ncdenr.org/web/wg/admin/bodi u/p edmr Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. 2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)l All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part H, Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part H, Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://portal.ncdenr.or web/wg/admin/boglipu/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: V certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who- manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " 3. Records Retention [Supplements Section D. (6.)l The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Page 6 of 6 IS ( a a 1 • �xpaq a• • 1 1 (j Yam\ atesville f, 37 f1 37 lk _47_ -1M "�- ✓s .... .ra. ��• R-'A — -`- KF — 4 NO U - Outfall 001&002 r• -_• = �. �.-.. . Lz --+... Lumber �. +• -' T air ..p zy. — � 1. — .�. .�_ ¢ �. Y � '� _ b � •1.' ' •w ,i•' i. .y,.. Sir N- -si^ __ ••► V ;A -rs- db- -' Latitude: 36"23'46" Sub -Basin: 03-01-01 cility FFa Longitude: 76046'02" 8-Dugut HUC: 03010203 cation Stream Class: C, NSW Ashton Lewis Lumber Company Deck Storage Site Receiving Stream: UT of Bennetts Creek, Chowan River Basin North NC0089541 COMMUNICATIONS NORTH CAROLINA LLC The Daily Reflector- The Daily Advance - The Rocky Mount Telegram Bartle Ledger- Chowan Herald - Duplin Times - Farmville Enterprise - Perquimans Weekly - Standard Laconic Tarboro Weekly -Times Leader - W lliamston Enterprise PO Box 1967, Greenville NC 27835 Date: July 15, 2015 - LEGALAD PROOF - Thank you for advertising with us! This is the proof of your ad scheduled to run on the dates indicated below. If changes are needed, please contact Brian Gray by phone at (252) 335-8078 or email at bgray@dailyadvance.com. CUSTOMER INFORMATION Account #: 100553 Company Name: NC DENR/DWQ/PT. SOURCE BRANCH Address: Wren Thedford 1617 MAIL SERVICE CENTER RALEIGH NC 27699-1617 Telephone: (919) 807-6304 Email: wren.thedford@ncdenr.gov AD INFORMATION Ad ID: Run Dates: 07/19/15 to 07/19/15 # of Inserts: # of Lines: 36 Ad Class: 42 Total Cost: Ordered By: Description: Publications Daily Advance DaiyAdvance.com $124.00 Public Notice Start Date 07/19/15 07/19/15 Account Rep: Brian Gray Phone #: (252) 335-8078 Email: bgray@dailyadvance.com End Date # of Insertions 07/19/15 07/19/15 Ad Proof Public Notice North Carolina Environmental Manage- ment Commission/NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDE5 Wastewater Permit The North Carolina Environmental Management Commission proposes to issue a NPDES wastewater discharge permit to the person(s) listed below. Written comments regarding the pro- posed Dermit will be accented until 30 (cent degree of public interest Please mail comments and/or information re- quests to DWR atthe above address.ln- terested persons may visit the DWR at 512 N. Salisbury Street, Raleigh, NC to review information on file. Additional ps/npdesrWlendar, or by calling (919) 807-6304. Ashton Lewis Lumber Company re- quested a new permit NCO089541 for its Wet Deck Log Storage Site in Gates Counry; this permitted discharge is treated industrial wastewater to Un- named Tributary of Bennetts Creek, Chowan River Basin. 7/19 y.s hJ3 q/i/-?'oIS i o l 7- T-a C, -t 5: h a f NC DENR/DWR/NPDES Permitting Unit FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES PERMIT NC0089541 Facility Information Applicant/Facility Name: Ashton Lewis Lumber Company Applicant Address: 96 Lewis Mill Road, Gatesville, NC 27938 Facility Address: 96 Lewis Mill Road, Galesville, NC 27938 Permitted Flow Not applicable Type of Waste: Domestic (0%) / Industrial 100% Pretreatment Program Not Applicable Facility Class/Permit Status: Class PCNC / New Permit County: Gates County Miscellaneous Receiving Stream: UT of Bennetts Creek Regional Office: Washington Stream Classification: C; NSW 8-digit 14UC: 03010203 303(d) Listed? No Permit Writer: Yang Son Subbasin/ Stream Index: 03-01-Ol/ 25-17 Date: July 6, 2015 Drainage Area (mi): Lat. 36023' 46" N Long. 76° 46' 02" W Summer 7Q10 (cfs): Winter 7Q 10 (cfs): Average Flow (cfs): IWC (%): 100%/Tidal Effect PERMIT ACTION: This is an NPDES permit application for NEW DISCHARGE from a wet decking operation and boiler blowdown. BACKGROUND: Ashton Lewis Lumber Company (Ashton Lewis) operates a southern yellow pine sawmill in Gatesville, NC. Ashton Lewis is planning to discharge wastewater from a wet decking operation and boiler blowdown. The proposed discharge will be comprised of the following waste streams: • Wet Deck process wastewater - 576,000 GPD • Stormwater— 1,000 GPD • Boiler Blowdown - 1,700 GPD The Permittee proposed to operate the wet decking mainly during dry seasons. However the boiler blowdown is produced continuously with addition of chemicals. The Division proposed two outfalls for wastewater would be applicable for this situation, which is accepted by the facility. Outfall 001 will discharge wastewater from wet deck process and stormwater runoff. Outfall 002 will discharge boiler blowdown. Both outfalls discharge to an unnamed tributary to the Bennetts Creek, a class C; NSW water in the Chowan River Basin. Ashton Lewis has its stormwater discharges under general NPDES stotmwater permit NO. NCG210185. This facility's wet decking operation SIC is 2411 and federal guideline 40 CFR 429 Subpart I applies. TREATMENT PROCESS: For outfall 001, wastewater is captured from the wet decking operation where stacked logs are sprayed with water pumped from nearby surface water. The wet decking wastewater passes through a bark screen into an on -site detention pond that flows to an unnamed tributary of the Bennetts Creek through an Fact Sheet Page I overflow pipeline. The screen and drainage area are cleaned routinely to remove any wood byproducts such as bark to prevent build up. For outfall 002, the non -process industrial boiler blowdown is discharged directly to the same unnamed tributary. RECEIVING STREAM: • The receiving stream is an unnamed tributary of Bennetts Creek, which is classified C; NSW. • Bennetts Creek is not an impaired stream on the 2014 final 303(d) list. • USGS indicates records from 1977 shows one point, upstream of proposed discharge point, has the estimated 7Q 10 as 0.2cfs with tidal influence. COMPLIANCE REVIEW: • This is a proposed NEW discharge. No compliance record. PERMIT DEVELOPMENT (for NEW discharge): • SEPA/FONSI Determination The proposed discharge is not subject to SEPA review. • Endangered Species Review It was reported that U.S. Fish and Wildlife Service concurred that the proposed discharge would not likely adversely affect any federally -listed endangered or threatened species, their formally designated critical habitats, or species currently proposed for listing under the Act at the Gates County locations. • Local Government Review Gates County Planning Department has completed its review of the application and a completed local government review form was send to the Division with the application. Gates County indicated that the plan for proposed facility is consistent with the local ordinance. • DWR Regional Office Review The DWR Washington Region staff conducted an on -site visit on April 29, 2015. No issues were found during this inspection. • Federal Effluent Guideline Review Wet decking is regulated by 40 CFR429 Subpart I which requires no debris discharged, and the pH between 6.0 and 9.0 S.U. • Impaired Waters Review (303(d) List) The receiving stream is not on the 2014 final 303(d) list. • Antidegradation Review Per NC Antidegradation Policy (15A NCAC 213.0201), each applicant for a new/expanding NPDES permit must document an effort to consider non -discharge alternatives pursuant to 15A NCAC 2H.0105(c)(2). The Engineering Alternatives Analysis (EAA) document was submitted as part of the NPDES application package. DWR staff reviewed the EAA and concurred with the engineering alternatives analysis conclusion that a direct discharge to surface water was the most environmentally sound alternative from the reasonably cost-effective options (per 15A NCAC 2H.0105). The 20-year present cost analysis for each alternative is listed below: o Land Application - $1,660,673.00 o Wastewater Reuse - $589,790.00 o Surface Water Direct Discharge - $2 f 3,942.00 o Combination (Surface Water Discharge/Land Application) - $589,790.00 • Proposed Limits/Monitoring Outfall 001 o Flow: Weekly monitoring o TSS: Weekly monitoring with limitations of monthly average 30 mg/L and daily maximum 45 mg/L Fact Sheet Page 2 o pH: Weekly monitoring with limitations of not less than 6.0 S.U. nor greater than 9.0 S.U. o Oil and Grease: Weekly monitoring o Nutrients (TN and TP): There are no nutrient limits proposed in this permit since the proposed discharge is not considered a nutrient source. However, quarterly nutrient monitoring will be required in accordance with 15A NCAC 2B.0508 Outfall 002 o Flow: Quarterly monitoring o Temperature: Quarterly monitoring o pH: Quarterly monitoring with limitations of not less than 6.0 S.U. nor greater than 9.0 S.U. o Chemical Oxygen Demand (COD): Quarterly monitoring SUMMARY OF PROPOSED PERMIT CONDITIONS: The Tables below summarizes proposed permit conditions for two proposed NEW discharges: Outfall 001 EFFLUENT CHARACTERISTICS LIMITATIONS RATIONALE FOR LIMITATIONS Monthly Average Daily Maximum Flow (GPD) 15A NCAC 213.0500 Total Suspended Solids 30 mg/L 45 mg/L 15A NCAC 213.0500; BPJ H Not less than 6.0 S.U. nor greater than 9.0 S.U. 40 CFR429; 15A NCAC 213.0211 Oil and Grease (mg/L) I BPJ Total Nitrogen (TN) (mg/L) Monitor & Report 15A NCAC 213.0508 Total Phosphorus (TP) (mg/L) Monitor & Report 15A NCAC 213.0508 Outfal1002 EFFLUENT LIMITATIONS RATIONALE FOR LIMITATIONS CHARACTERISTICS Monthly Average Daily Maximum Flow (GPD) NCG500000 Consistence Temperature (°C) 15A NCAC 2B.0211; NCG500000 Consistence H Not less than 6.0 S.U. nor greater than 9.0 S.U. 15A NCAC 213.0211 Chemical Oxygen Demand NCG500000 Consistence (COD) (mg/L) PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice Permit Scheduled to Issue: NPDES DIVISION CONTACT: July 22, 2015 (estimate) September 7, 2015 (estimate) If you have questions regarding any of the above information or on the attached permit, please contact Yang Song at (919) 807-6479 or by email at yang.song@ncdenr.gov. ncdenr.gov. NAME: I � DATE: COMMENTS: No comments were received from the WaRO — Water Quality Program. The Permittee provided comments about the on -site ORC. After conferring with NC Operators Certification Program and Washington Regional Office, the facility classification was changed to physical chemical not classified (PCNC) and the facility is not required to have an ORC or a back-up. Fact Sheet Page 3 SOC PRIORITY PROJECT: No To: DWR - Water Quality Programs NPDES Complex Permitting Unit Attention: Tom Belnick / Yang Song Date: May 4, 2015 NPDES STAFF REPORT AND RECOMMENDATIONS County: Gates NPDES Permit No.: NCO089541 PART I - GENERAL INFORMATION RECEIVEDIDENR/DWR 1. Facility and address: Ashton Lewis Lumber Company MAY 8 2015 96 Lewis Mill Road Water Quay: Gatesville, NC 27938 pemdftsedw 2. Date of investigation: April 29, 2015 (inspection attached) 3. Report prepared by: Scott Vinson, Environmental Engineer 4. Person contacted and telephone number: Mr. Michael Lancaster (252) 357-0050 5. Directions to site: The facility is located west of Gatesville off NC Hwy 137 at 96 Lewis Mill Road, in Gates County, North Carolina. 6. Discharge point(s), list for all discharge points: Outfall 001 Latitude: 360 23' 45.4" N Longitude: 760 45' 55.6" W 7. Receiving stream or affected surface waters: Canal to Bennetts Creek (Merchants Mill Pond) a. Classification and Stream Index No.: C; NSW, 25-17 b. River Basin and Subbasin No.: Chowan, 03-01-01 C. Describe receiving stream features and pertinent downstream uses: The receiving stream is classified and used for secondary recreation, fishing, wildlife, fish consumption, aquatic life including propagation, survival and maintenance of biological integrity, and agriculture. Secondary recreation includes wading, boating, and other uses involving human body contact. RECEIVED/DENR/DWR Page Two MAY 8 Z015 Water Quality Permitting Section PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS a. Volume of wastewater: Discharge will be daily and can be continuous at times during operation of the wet deck. b. What is the current permitted capacity: n/a C. Actual treatment capacity of current facility (current design capacity): n/a d. Description of existing or substantially constructed W WT facilities: n/a e. Description of proposed WWT facilities: bar screenand settling pond f. Possible toxic impacts to surface waters: Ashton Lewis poses no apparent toxic impacts to surface waters. PART III - OTHER PERTINENT INFORMATION Special monitoring or limitations (including toxicity) requests: none 2. Compliance: The facility has not started their wet deck spray operation yet this year and therefore is currently compliant. However, it is understood from my site visit that they are in need of spraying their wet deck typically around Memorial Day each year. The proposed bar screen and settling pond seem to be in order for a typical wet deck operation and the region has no further questions from the applicant. PART IV - EVALUATION AND RECOMMENDATIONS Ashton Lewis Lumber Company has requested coverage under an NPDES discharge permit and the Washington Regional Office recommends issuing the permit once proper notice has been given and a draft permit has been issued and reviewed by all parties. SZy&- Scott Vinson �' Signature of Report Preparer Date - 2) h: 71CM s & Robert Tankard WQROS Assistant Regional Supervisor Date 10000 •:QBIL White 1220 �♦ —' - R -� + o \ 3000 IL Its o � '� -w- 3 g' � a 2500 1 1113 1l11 — . 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Light -duty road, hard or 1 hard surface ...... ---•- improved staface .. �"�i �t +�+ > ES Secondary highway, 5000 so 7000 em 9DOO 10000 hard surface....... Unimproved road.. Er Interstate Route 0 U. S. Route O State Rode 3VAL 2 METERS )UR INTERVAL 1 METER N ]NTOURS ARE APPROXIMATE .RTICAL DATUM OF 1929 GATESV1LLEe N. C. I TO THE NEAREST 0.1 METER QUADRANGLE LOCATION NE/4 WINTON 15' QUADRANGLE TO THE NEAREST 0.5 METER 36076 D7 TF 024 1ETERS—DATUM IS MEAN LOW WATER CONTOURS AND ELEVATIONS TWO DATUMS 1S VARIABLE IN METERS 19$1 MAL MAP ACCURACY STANDARDS PHOTOINSPECTED 1990 ;EOLOGICAL SURVEY DMA 5656 IV NE --SERIES V842 NCCT08gsv) - &'Co3eg Wei NEW 3�2o�S National Pollutant Discharge `Elimination System Individual Permit Application Ashton Lewis Lumber Company Gatesville, Gates County, North Carolina March 2015 Prepared for: I�gON <F �GMeEa� Ashton Lewis Lumber Company 96 Lewis Mill Road Gatesville, North Carolina 27938 Prepared by: Wolff • Coury Science & Engineering, PLLC 471 Royal Tern Drive Hampstead, North Carolina 28443 March 12, 2015 RECEIVED/DENR/DWR MAk 16 2015 NC DENR / DWR / NPDES Unit 1617 Mail Service Center Water Quality Raleigh, NC 27699-1617 Permitting Section RE: NPDES Permit Application and Engineering Alternative Analysis Ashton Lewis Lumber Company Gates County Attached are the original and two copies of the completed Form C-MI and Engineering Alternative Analysis for Ashton Lewis Lumber Company. The application is for a proposed wet decking operation for the Ashton Lewis facility located in Gates County, NC. If you should have any questions concerning this renewal application or need additional information, please contact Sean Coury at 910-685-3662 or email, sean.courv@couryse.com. Thank you. Certification: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or person who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, trite, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility offtnes and imprisonment for knowing violations. " Sincerely, ; I �� A vv-� Michael Lancaster Operations Manager Ashton Lewis NPDES Permit Application March 2015 Ashton Lewis Lumber Company (Ashton Lewis) operates a southern yellow pine sawmill in Gatesville, Gates County, North Carolina. Ashton Lewis falls under the standard industrial classification (SIC) code of 2421 for Sawmills and Planing Mills, General. The facility is proposing to permit wastewater discharges from a wet deck operation and boiler blowdown. PERMIT REQUEST AND PERMIT FEES The purpose of this application is for a new individual National Pollutant Discharge Elimination System (NPDES) Permit. The facility's stormwater discharges are currently covered under general NPDES stormwater permit No. NCG210185. The plant does not have a sludge management plan because wastewater is not treated onsite. This application is intended to satisfy all requirements of 15A NCAC 2H .0105. In accordance with the North Carolina (NC) Division of Water Resource (DWR) fee schedule, the fees associated with new permit applications for Minor Individual NPDES permits is $860, which is being submitted with this application. Included in this package is one original and two copies of the application as required. Ashton Lewis is not required to obtain an Authorization to Construct (ATC) following issuance of the NPDES permit by the NC DWR. Session Law 2011-394, which became effective July 1, 2011, no longer requires ATC permits for wastewater generated from manufacturing facilities. FACILITY INFORMATION ink� The physical and mailing address for Aston Lewis is as follows: P.O. Box 5 96 Lewis Mill Road Gatesville, North Carolina 27938 1M* To facilitate review of this application, please contact the following individuals identified below. Preoarer's Contact Information: Sean Coury, PE (NC) Partner Coury Science & Engineering, PLLC (910)319-0017 sean.coury@couryse.com DOCUMENT ORGANIZATION Facilitv's Contact Information: Michael Lancaster Operations Manager Ashton Lewis Lumber Company (252)357-0050 mlancaster@ashton-lewis.com This permit application is divided into five sections and various appendices. Tables are included throughout the document and are referenced in the table of contents. The seven sections and four appendices are as follows: Section 1 Introduction Section 2 Site Information Section 3 Effluent Description and Treatment Section 4 Engineering Alternatives Analysis Section 5 Application Form Refer to the table of contents for a detailed listing of tables and figures. Page 4 of 24 /"W. Ashton Lewis NPDES Permit Application March 2015 This section provides information on the site location, surrounding terrain, and description of industrial activities. SITE LOCATION Ashton Lewis is situated on approximately 75 acres in Gatesville, Gates County, North Carolina. The approximate coordinates are 36023'53.69" N, 76°46'02.50" W. The facility stormwater and wastewater will feed into an easterly flowing canal that eventually discharges into the portion of Bennetts Creek located south of the NC Hwy 37 / NC Hwy 137 intersection in Gatesville, Gates County, North Carolina. Bennetts Creek is a class C; NSW stream located in the Chowan River Basin. Bennetts Creek is not on the 303(d) (Impaired Waters) list for any pollutants. DESCRIPTION OF MANUFACTURING PROCESS Ashton Lewis operates a state-of-the-art sawmill which produces flooring, paneling, siding, window blanks, and a variety of other wood products based on customer specifications and requests. Ashton Lewis receives high quality southern yellow pine logs. The logs are separated based on intended use or product and maintained in the concrete storage area until ready for production. Ashton Lewis will utilize wet spray to maintain adequate moisture content in the lumber. The wet spray (or wet decking) operation reduces end checking, log staining, and decay, which in turn allows for a higher quality product. AO%k The logs are mechanically debarked and transferred to either one of the two sawing lines. A scanning carriage and single band mill breaks down larger logs while a unique and versatile end -dogging machine processes smaller logs through twin bandsaws. Further reduction occurs downstream as lines merge to a twin horizontal resaw and then are edged with either of two multiple saw scanning optimized edgers. All sawn lumber Is optimized for end trimming and sorted for drying by thickness, length, width, and grade in a computerized 26 bay drop bin sorter. All lumber is mechanically stacked and dried in one of seven computer controlled low temperature steam dry kilns. All steam for this segment of the operation is produced by a gasification type wood waste boiler plant. The boiler plant consists of two wood -fired boilers with a rated heat input capacity of 19.1 and 28.7 million Btu per hour capacity, respectively. Lumber is cooled in covered areas and routed to a very versatile finish mill. Two high-speed pattern planers finish most domestic sales lumber and a German 8 head Weinig Moulder produces architectural profiles. Simultaneously, rough kiln dried lumber can be graded on a parallel system. All lumber is graded in air-conditioned, constant lighted room and passes to a computerized separator and package maker. Any excess trimmings or off -grade lumber, chipped in a chipping machine, bark, and sawdust are used as fuel in the wood waste boiler plant. SITE MAP A site map depicting the facility and surrounding areas is located in Appendix 1. The log storage area where the wet deck operation will take place has been outlined in red and the proposed location of the settling basin is outlined in blue. The facility outfall location has been denoted with a red star on the site map. GOON A topographic map that shows the terrain of the site and surrounding areas is included in Appendix 2. Page 5 of 24 l Ashton Lewis NPDES Permit Application March 2015 This section describes the effluent that will be generated from the wet decking operation and boiler blowdown. The section also details the proposed method of wastewater treatment and disposal and engineering design analysis. DESCRIPTION OF DISCHARGED WASTEWATER AND TREATMENT Ashton Lewis is proposing to permit discharge from a wet decking operation, which will be used to spray water onto the log storage piles especially during warmer, dryer months. Surface water will be pumped from a canal that drains to Bennetts Creek and then sprayed onto logs stockpiled on the wet deck via spray nozzles. Ashton Lewis is proposing to install concrete curbing around the perimeter of the concrete log storage pad which will be sloped in a manner that will ensure water will flow into a detention/settling pond prior to discharge back into the canal via Outfall 001, indicated on the site map in Appendix 1. Since the water will operate as a single use or single pass system (i.e., water is not reused or continuously recycled), the quality of the water returned to the canal is similar in quality to that originally withdrawn. Use of a single pass system will help reduce the discharge of pollutants and ensure a low biochemical oxygen demand (BOD) in the effluent stream. The wet decking operation will consist of four sprinkler heads, each with an approximate flow rate of 100 gallons per minute (gpm). The calculated maximum flow rate is 0.576 million gallons per day (MGD), assuming 100 gpm from each of four sprinkler heads for 1,440 minutes per day. No chemicals will be added for the wet decking operation, and once -through water will be pulled from a nearby canal. A water flow line diagram is included in A„kl Appendix 3. Ashton Lewis is also proposing to permit non -process industrial wastewater discharge from boiler blowdown. Boiler blowdown is water that is purged from the boiler to avoid building up impurities within the boiler. The discharge from the boiler blowdown at Ashton Lewis is estimated to be 1,700 gallons/day and will be comingled with the overflow from the settling pond. Chemicals are added to boiler feed water daily in order to prevent corrosion, scaling, and deposition in the boiler. The following chemicals are expected to be present in the boiler blowdown water, prior to comingling with the pond overflow water: Product Name Chemical Components Usage SEL Loxy 600 Sodium sulfate (>95%) Cobalt sulfate (<3%) 1 cup per day SEL Lamine 340 Diethylethanola mine (30-50%) 1 gallon per day SEL Lamine 316H Diethylethanola mine (10-30%) 1 gallon per day SELplus 730M I Sodium hydroxide (<0.5%) 1 gallon per day ESTIMATED EFFLUENT DATA US EPA effluent limitations guidelines for Timber Products Processing (40 CFR 429), Subpart I, Wet Storage Subcategory, states that there shall be no debris discharged from the wet decking operation and provides ranges for effluent pH. As required by these federal effluent limitations guidelines, there will be no debris present in the effluent and the pH will remain within the range of 6.0 to 9.0. To ensure that no debris will be present in the PON discharge, all runoff associated with the wet decking operation will be routed to a settling pond prior to discharge. Page 6 of 24 /1 Ashton Lewis NPDES Permit Application March 2015 In accordance with the 2007 Chowan River Basinwide Water Quality Plan, all waters in the Chowan River Basin, including Bennetts Creek, are classified as NSW (Nutrient Sensitive Waters) which requires wastewater dischargers to set permitted nitrogen and phosphorus limits of 3 mg/I and 1 mg/I, respectively. Based on the characteristics of the proposed wastewater stream and the design of the proposed wet settling basin, effluent nitrogen and phosphorus quantities are expected to be well within these specified limits. The system has been designed to minimize BOD and chemical oxygen demand (COD). The water withdrawal/discharge system is designed to be a single pass system to prevent concentrations of BOD and COD from increasing. Additionally, incoming water will pass through a filter to minimize the amount of bark that is introduced to the settling basin. The proposed settling basin will include a forebay to provide an additional pretreatment step and reduce solids in the permanent pool. ENGINEERING DESIGN OF SETTLING POND The runoff from the proposed wet decking operation will be diverted to a wet detention pond prior to discharge to surface waters. The pond has been designed in accordance with USDA Soil Conservation Services Practice Standard Code No. 378 and the North Carolina Department of Environment and Natural Resources (NCDENR) Practice Standards and Specifications for Sediment Basins. Appendix 4 includes a drawing of the proposed settling pond and supporting calculations. The proposed pond is designed with a 2.5:1 length to width ratio, which Is greater than the recommended minimum of 2:1. The proposed volume of the pond is 43,052 cubic feet and results in a hydraulic residence time of 13.4 hours at maximum flows. Additionally, the proposed pond has been designed with a forebay to enhance solids removal and reduce the cost of pond cleanouts. The proposed forebay lom� is 20% of the pond size. The permanent pool and the forebay pool are 4 feet deep with 1 foot of sediment storage. ^� In accordance with ISA NCAC 2H .0105, an Engineering Alternatives Analysis (EAA) is required for any new wastewater discharge. This section contains the components of the engineering alternatives analysis including determination if the proposed discharge will be allowed, flow projections, evaluation of technically feasible alternatives, and evaluation of economically feasible alternatives. ALLOWABLE PROPOSED DISCHARGE Prior to evaluating alternatives, Ashton Lewis made the determination that the proposed wastewater discharge would be allowed. The following sections detail the evaluation that was conducted in order to confirm that the proposed wastewater would be an allowable discharge. The restrictions that could be imposed on a proposed wastewater discharge to surface waters include zero flow stream restrictions, receiving stream classifications, NPDES permitting strategies listed in the Basinwide Water Quality Plans, impaired water and Total Maximum Daily Load (TMDL) classifications, and the presence of endangered species. STREAM FLOW RESTRICTIONS Specific stream restrictions are listed in 15A NCAC 2B .0206(d)(2) for oxygen -consuming wastewater in zero -flow streams. In efforts to determine the 7Q10 flow at the proposed discharge location into Bennetts Creek, Mr. Curtis Weaver, with United States Geological Services (USGS), was contacted. Mr. Weaver indicated that the low -flow files at the USGS South Atlantic Water Science Center in Raleigh, NC did not indicate any determinations for the specified point of interest. There were, however, records from 1977 for a point in Bennetts Creek, upstream of the Page 7 of 24 /0*% Ashton Lewis NPDES Permit Application March 2015 proposed discharge point that Indicated a 7Q10 of 0.2 cubic feet of water per second. A copy of the correspondence with the USGS is included in Appendix 5. RECEIVING STREAM CLASSIFICATION RESTRICTIONS The stream classification for Bennetts Creek is C (Class C), which does not impose stricter treatment standards than federal standards. All waters in the Chowan River Basin, including Bennetts Creek, are classified as NSW (Nutrient Sensitive Waters) which requires wastewater dischargers to set permitted nitrogen and phosphorus limits of 3 mg/I and 1 mg/I, respectively. Based on the characteristics of the proposed wastewater stream, effluent nitrogen and phosphorus quantities should be well within these specified limits. Bennetts Creek is not listed as impaired on the 303(d) list and is not subject to any impending TMDLs according to the NC DWR's website. Bennetts Creek is located In the Chowan River Basin. The 2007 Chowan River Basinwide Water Quality Plan was reviewed and no additional standards or restrictions were required for Bennetts Creek. ENDANGERED SPECIES If endangered species are suspected to be present in the proposed discharge location, then additional restrictions may be implemented for wastewater discharges in that area. To determine if any endangered species might be present in the area of discharge to Bennetts Creek, an evaluation request was submitted to Mr. Pete Benjamin, US Fish and Wildlife Services— Raleigh Field Office. According to US Fish and Wildlife Service's response, the proposed discharge would not likely adversely affect any ram, federally -listed endangered or threatened species, their formally designated critical habitat, or species currently proposed for listing under the Act at the Gates County location. Therefore, the requirements for section 7(a)(2) of the Endangered Species Act of 1973 were satisfied for this project. The US Fish and Wildlife Services was, however, concerned about potential impacts on aquatic species, since they are highly susceptible to sedimentation. Since Ashton Lewis proposes to install a pond to provide for settling of solids prior to discharge, the proposed discharge is not expected to adversely impact aquatic species. The correspondence with US Fish and Wildlife Services is included in Appendix 6. ZONING Ashton Lewis is currently operating a sawmill at the Lewis Mill Road site (Parcel No. 0101346) which is zoned as'A- 1' for agricultural uses. Following discussions with Ms. Jennifer Baptiste, Gates County Planning Department, it was confirmed that wood products manufacturing is allowed for parcels zoned for agricultural use; however, a special use permit is required for new wood products operations. Since the facility is existing, the property has been grandfathered from the requirements to obtain a special use permit. Therefore, in accordance with our discussions with Gates County Planning Department, the site and proposed discharge is consistent with local zoning ordinances. Gates County Planning Department has completed its review of the application and a completed Local Government Review Form is included in Appendix 7. FLOW PROJECTIONS Page 8 of 24 Ashton Lewis NPDES Permit Application March 2015 The population projections are not applicable to industrial facilities, but instead apply to domestic wastewater production for evaluation of an increase or decrease in population. The projected wastewater flows for Ashton Lewis are only dependent on the manufacturing operation, and would not be affected by changes in population. As previously discussed in this application, the projected wastewater flow is expected to be approximately 578,000 gallons per day. Of that 576,000 gallons is proposed to be discharged from the wet decking operation (settling pond) and 1,700 gallons from boiler blowdown. TECHNOLOGICALLY FEASIBLE ALTERNATIVES The section includes the evaluation of other technologically feasible alternatives for wastewater discharge. As listed in the NC Division of Water Resource's Engineering Alternatives Analysis (EAA) Guidance Document, the determination includes the evaluation of the technological feasibility of the following: 1. Connecting to an existing wastewater treatment plant 2. Land application through spray irrigation 3. Reuse of wastewater 4. Surface water discharge through NPDES permitting 5. Combination of any of the alternatives CONNECTION TO EXISTING WASTEWATER TREATMENT PLANT The only wastewater treatment facility located in Gates County operates under a NC DWQ's non -discharge permit /�. (Permit No. WQ0000267). The permit, which is currently undergoing renewal, is issued to Gates County Correctional Facilities and accepts wastewater from the county correctional facility, Gatesville Middle and High Schools, and the Division of Transportation. The facility is permitted with a 25,000 gallon per day capacity as a spray irrigation and disposal facility. After speaking with Mr. Timothy Hedgepeth, Water Plant Supervisor, it was confirmed that the wastewater treatment facility is a very small operation and could not accept wastewater of the magnitude proposed by Ashton Lewis. Therefore, it has been determined that connection to an existing wastewater treatment plant is technologically infeasible for the Ashton Lewis location. r LAND APPLICATION Soil types in the vicinity of the proposed wet decking operation were reviewed to evaluate the potential for disposing of the wastewater via land application (or spray irrigation). The only remaining land, not occupied by the plant footprint, located on the Ashton Lewis property is forestland; therefore, the only option for spray irrigation would be the purchase of additional farmland nearby the facility. The neighboring farmland consists of primarily the following soil types: NaA (Nawney loam), AaB (alaga sand), PaA (Pactolus Sand), and IcA (Icaria fine sandy loam). According to the soils report obtained from USDA, these soil types are classified as 'very limited' for disposal of wastewater by Irrigation, meaning that the soils have at least one feature that make them unfavorable for disposal of wastewater by irrigation. As described in the USDA soils report, 'very limited' classifications typically means that "the limitations cannot be overcome without major soil reclamation, special design, or expensive installation procedures." The poor performance can be attributed to soil characterizations such as depth to saturated zone, filtering capacity, and high acidity. Appendix 8 includes a map from the USDA Custom Soil Resource Report which depicts the various soil types and classification for wastewater disposal by irrigation. Page 9 of 24 ^N Ashton Lewis NPDES Permit Application March 2015 NCDENR non -discharge rules (15A NCAC 02T Sections 0.0100-0.1600) and the coastal waste Treatment Disposal rules (15A NCAC 02H Section 0.0400) describe the limitations for land applications. The Ashton Lewis facility (Gates County) is located in a designated coastal area (15A NCAC 02H Section 0.0403(3)). Due to the speculative nature of this exercise, specific property tracts have not been identified yet for this alternative; therefore, the necessary testing has not been performed. Based on the USDA soils report, there is a combination of well -drained soil types (AaB) and poorly drained soil types (NaA and PaA). For cost estimation purposes, it is assumed that the highest application rate for low -rate application can be met in the soils located in the property adjacent to the facility. If the infiltration rate is lower, then the costs to accomplish infiltration would be much higher. The low -rate infiltration cutoff for designated coastal areas is 0.156 gallons per day per square foot (gpd/ftz) (15A NCAC 02T 0.0702(1)). Therefore, the application of 0.578 MGD would require at least 3,703,205 ftZ of property (85 acres). Assuming the adjacent property to the Ashton Lewis facility is suitable for land application and available for sale, approximately 1.8 miles of piping would be required to transfer and apply the water over 85 acres. WASTEWATER REUSE Reuse of water from wet decking operations is commonly utilized; however it does pose several disadvantages. When wastewater from wet decking operations is continuously recirculated the level of BOD in the wastewater continues to increase and debris from the operation begins clogging pumping and sprinkler heads. Additionally, large storage basins will be required to ensure that water is not discharged during heavy rain events. According to �^ the National Oceanic and Atmospheric Association (NOAA) Atlas 14, Volume 2, Version 3 for the Edenton, NC station, 24-hr 25-yr precipitation estimates for the Ashton Lewis facility are approximately 7.2 inches (Appendix 9). Therefore, a storage basin capable of holding 0.578 million gallons of water in addition to the regulatory required 2 foot freeboard requirement and additional freeboard requirement to prevent a discharge during high intensity rain events will be required. In addition to a large storage basin, some form of land application will be required so that discharge does not occur during extended wet periods. For this exercise, it is assumed that the water equivalent of approximately V of freeboard will be required to be land applied. It is estimated that an 8-foot deep storage basin with a surface area of 15,453 square feet will be required. Therefore, approximately 115,500 gallons of water will be required to decrease the storage basin by 1'. SURFACE WATER DISCHARGE THROUGH NPDES PROGRAM The Ashton Lewis facility is in close proximity to Bennetts Creek, which drains into the Chowan River. Wastewater associated with the Ashton Lewis operation will include canal water that is sprinkled on logs, stormwater, and boiler blowdown. Wastewater will pass through a filtration step and a settling pond prior to discharge. Feasibility studies for discharge into Bennetts Creek have been discussed in prior sections. The surface water discharge option will require a settling pond and minimal piping to transfer the water from the settling pond to an unnamed tributary that drains into Bennetts Creek. COMBINATION OF ALTERNATIVES A combination of wastewater reuse with land application was already considered as an option in the wastewater reuse section. Wastewater reuse with surface waster discharge is technologically feasible; however, it is not 10",° recommended for wet decking applications. As previously discussed, the BOD will increase when water is Page 10 of 24 AOM, /'\ Ashton Lewis NPDES Permit Application March 2015 continuously recirculated. BOO effluent limitations would most likely be exceeded; therefore, a combination of wastewater reuse and surface water discharge will not be considered. Discharge to surface waters is the least complicated option and will require the least amount of construction to implement. Combination of land application with surface water discharge will be much more costly than utilizing the surface water discharge option alone. The combination of land application with surface water discharge will be comparable to the wastewater reuse option; therefore, the cost will be assumed to be equal to the wastewater reuse option. ECONOMIC FEASIBILITY OF ALTERNATIVES This section addresses the economic feasibility of each of the technologically feasible engineering alternatives. Those alternatives that were considered technologically feasible and evaluated in this section are land application, wastewater reuse, and surface water discharge through the NPDES program. Each cost analysis includes the capital cost, recurring cost, and lost opportunity costs. The cost estimates are determined assuming 20 years of operation. The cost analyses are explained in detail below for each technologically feasible alternative. LAND APPLICATION Appendix 10-1 includes cost estimate details for land application. It is estimated that the purchase of 105 acres would be necessary for disposal of wastewater via land application based on infiltration rates and setback requirements. Land costs were estimated based on the USDA 2014 land values summary for farmland in North Carolina. Land Application costs include the cost of a settling pond, a pump station, 1.8 miles of piping, and an irrigation system capable of supplying water to 87 acres of land. The cost could be substantially more if adjacent land is not available or if existing soils need significant work to make them suitable for land application. The total present value cost analysis for land application was found to be $1,660,673. WASTEWATER REUSE Appendix 10-2 includes cost estimation details for wastewater reuse. A combination of wastewater reuse and land application was considered to provide options during extended periods of increased precipitation. An application rate of 100 gpm is assumed and that the application will be split over three eight hour days, resulting in an application rate of 38,300 gallons per day. Using the same assumptions as the land application alternative, the wastewater reuse alternative will require approximately six acres of property and an additional three acres of property for setbacks. In addition to the land purchase, costs for the wastewater reuse option include 1.0 miles of piping, a settling basin, a pump station, irrigation systems, and ancillary equipment. The total present value cost analysis for wastewater resuse was found to be $589,790. SURFACE WATER DISCHARGE THROUGH NPDES PROGRAM Appendix 10-3 includes cost estimation details for surface water discharge through the NPDES program. Discharge through the NPDES program will require a settling basin to remove the potential for discharge of solids. The estimated cost for construction of the pond was determined from the equation found in Table 2 of An Evaluation of Cost and Benefits of Structural Stormwater Best Management Practices. The aforementioned reference lists construction of wet ponds as C=13,909x°'611, where x = drainage area and C = construction cost in current United Page 11 of 24 Ashton Lewis NPDES Permit Application March 2015 States dollars. A drainage area of 2.2 acres was used to calculate the construction cost. The total present value cost analysis for discharge through the NPDES program was found to be $213,942. COMBINATION OF SURFACE WATER DISCHARGE AND LAND APPLICATION The same land application rate that was used for wastewater resuse was assumed for this scenario. Addtitonally, a similar sized pond would be required as the wastewater resuse option. Therefore, capital and operation costs would be similar to the wastewater reuse option. The total present value cost analysis for combination of surface water discharge and land application was found to be $589,790, RESULTS OF ECONOMIC FEASIBILITY ALTERNATIVES A summary the costs of each alternative considered are displayed in the table below. Alternative Total Cost (assumes 20 years of operation) Land Application $1,660,673 Wastewater Reuse $589,790 Surface Water Discharge (NPDES) $213,942 Surface Water Discharge/Land Application' $589,790 —Assumed to be same cost as wastewater reuse. Assumed same land application requirements as wastewater reuse. The alternative with the least economic impact is surface water discharge into Bennetts Creek. The discharge alternative is less than half the cost of the next closest alternative (wastewater reuse). The most expensive option is land application. REPORT CERTIFICATION This report was prepared by Coury Science and Engineering, PLLC. Coury Science and Engineering is licensed to practice engineering in the state of North Carolina (P-1120). I, Sean Coury, a North Carolina Professional Engineer for Coury Science and Engineering certify that the information contained in this report is correct and accurate to the best of my knowledge. Sean T Coury, PE (North Carolina PE Number 037855) OL SEAL ol"B 5 12 Proposed Wet Deck Site Map Ashton Lewis Facility Gatesville, North Carolina Al 0 Coordinate System: WGS 1984 Web Mercator Auxiliary Sphere Projection: Mercator Auxiliary Sphere Datum: WGS 1984 False Easling: 0.0000 False Northing: 0.0000 Central Meridian: 0.0000 Standard Parallel 1: 0.0000 Auxiliary Sphere Type: 0.0000 Units: Meter Outfall 001 Latitude: 76' 45' 55.564" N Longitude:360 23' 45.436" N N 0 0.050A 0.2 0.3 0.4 0.5 wE Miles \Y/ s General Location and Topographic Map Ashton Lewis Facility Gatesville, North Carolina i3. 8m H,gh tit Bennetts Creek Stream Class C; NSW Sources: Esn, Del-orme. NAVTEO, TomTom, Intennap, increment P Corp., GEBCO, USGS, FAO, NIPS, NRCAN, GeoBase, IGN, Kadaster NIL, Ordnance Survey, Esn Japan, METI, Esri China (Hong Kong), swisstopo, and the GIS User Community, Source: Esri, DigitalGlobe, GeoEye, i-cubed. USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swsstopo, and the GIS User Community Coordinate System: WGS 1984 Web Mercator Auxiliary Sphere Projection: Mercator Auxiliary Sphere Datum: WGS 1984 False Easting: 0.0000 False Northing: 0.0000 Central Meridian: 0.0000 Standard Parallel 1: 0.0000 Auxiliary Sphere Type: 0.0000 Units: Meter .^N Peak Discharge Calculations Method:NCDENR Stormwater Best Management Practices (BMP) Manual, Chapter 3-Runoff Coefficient 1. C = (Runoff) Coefficient =0.95 (all areas paved with asphalt) 2. A = (Runoff) Area = 2.2 Acres 3. 1 = Intensity, Rainfall (NOAA Atlas 14, Volume 2, Version 3 for the Edenton, NC station) 2-yr, 24hr. storm: 3.79 inches/hour 10yr, 24hr storm: 5.83 inches/hour 4. Calculate Peak Discharge Rate , Q from stormwater runoff Q = C*I*A (equation 1) Q2yr,24hr = 10.4 cubic feet per second (cfs) Q101124hr = 12.2 cfs Add runoff from wet decking operation — 400 gpm * 0.134 W/gallon * 0.016 min/sec = 0.9 cfs Q24r,24hr = 10.4 = 0.9 cfs =11.3 cfs Q10rr,24hr = 12.2 cfs + 0.9 cfs = 13.1 cfs Pond Calculations Reference: Fifield, Jerald S. 2004. Designing For Effective Sediment Control on Construction Sites. Forester Press, Santa Barbara, CA. and Hydraulic Residence Time Method 1. Peak flows of the 10-year, 24 hour storm Q10yr,24hr- a. Peak flow (see above) : Qioyr„24hr = 13.1 cfs 2. Determine minimum basin volume: a. Minimum containment volume must be >3,600 cubic feet per acre V = 3600 ft3/acre x 2.2 acres = 7,920 ft3. �1 3. Determine minimum surface area: a. Minimum surface area = 435 ft2 per every cfs. Minimum Surface Area = 435 ft2 x 13.1 cfs = 5,698 ft2 4. Determine pond dimensions and compare to minimum design requirements a. Minimum Length to Width ratio is 2:1 b. Proposed depth is 4' for the permanent pool and 1 'for sediment storage c. The proposed dimensions of the pond are 65' by 165' Surface area=10,725 ft2 Volume = 42,900 ft3 5. Determine Hydraulic Residence Time (HRT) a. HRT = Volume / Qavg %vg = 400 gpm* 60 minutes/hour * 24 hours/day * 0.134 ft3/gallon = 77,000 ft3/day HRT = 42,900 ft3 / 77,000 ft3/day * 24 hours/day =13.4 hours 6. Determine Pipe Diameter for Pond Discharge (NCDENR Stormwater Manual Section 3.5.2) a. Q = Co * A * (2 * g * Ho)(1/2) Co = Coefficient of discharge = 0.6 default value (unitless) A = Cross Section of Area of Flow at entrance (solve equation to calculate) (ft) g = Acceleration gravity = 32.2 ft/sec2 Ho = driving head = 1 ft Q pond discharge = 5 cfs Solve for A to get: A =1.2 ft2 A=nr2 r = 0.6' or d=14..... use 18" diameter pipe 7. Vegetation a. Trees and woody shrubs shall not be planted on the dam structure; b. Wet ponds should incorporate a minimum of three diverse species of shallow water emergent and shallow land herbaceous vegetation on the vegetated shelf; A minimum of 50 plants per 200 sf of shelf area shall be planted; c. Turf grass shall be provided on the tops of berms and on the exterior slopes of containment berms; and d. Weeping love grass shall not be used on the vegetated side slopes because it does not provide long- term slope stabilization. Inlet from' existing ditch Forebay Outlet Oriifice 18 inch dia. pipe 10 Corrugated metal to Outfall 001 2 m 2:1 side slope CROSS SECTION 4.5:1 SCALE vegitated side slope Freeboard j slope I slop I slope � 1ft I slope I slope I slope I I I Permanent Forebay I I Pool 4 t 1 I I Sediment Storo e Sediment Storage 1ft Wit 3ft 3ft aft POND AND WATER FLOW Wednesday, March 11, 2015 at 10:46:47 AM Eastern Daylight Time Subject: FW: Initial USGS response concerning... Re: Low Flow Estimates in Gates County Date: Tuesday, December 2, 2014 at 4:21:31 PM Eastern Standard Time From: Christy Richardson To: sean.coury@couryse.com FYI. Christy Richardson Senr En ineering Project Manager (910)733-0908 chiisty.a-icltar(Ison (wcou ryse.com www.courysc.com An Economically Disadvantaged Women -Owned Small Business From: Weaver, John [mailto:jcweaver@usgs.gov] Sent: Tuesday, December 02, 2014 4:12 PM To: Christy Richardson Cc: John Weaver Subject: Initial USGS response concerning... Re: Low Flow Estimates in Gates County Ms. Richardson, In response to your inquiry about the low -flow characteristics for Bennetts Creek downstream of NC Highway 37 at Gatesville in Gates County, the following information is provided: A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh unit) does not indicate any previous determination of low -flow characteristics for the specific point of interest identified via the Iattlong coordinates provided in your email dated December 01, 2014. The low -flow files do indicate a previous estimate immediately upstream from your point of interest that was completed in April 1977 for Bennetts Creek at NC 37 at Galesville (station id 0205359250, drainage area 95 sgmi). The 7Q10 estimated for the site in 1977 was 0.2 cfs, based on transfer of flow characteristics from a USGS partial - record station on nearby Cole Creek near Gatesville. However, a note saying "possible tidal effects" was also written near the estimates. No USGS discharge records are known to exist for the point of interest. Please also note that available historical streamflow records are very limited for the area in vicinity of your point of interest. In the absence of site -speck discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square mile drainage area, of cfsm) at one or more nearby site(s) where such estimates have previously been determined. For streams in Gates County, the most recently published low -flow information is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, 'Low -flow characteristics of streams in North Carolina" em1 (Giese and Mason, 1993). An online version of the report is available through http://pti¢s.0 sWgpv w—s 24 rep-g t.p f. The report provides the low -flow characteristics (based on data through 1988) via regional relations and at -site values for rural sites with drainage basins between 1 and 400 sgmi and not Page 1 of 3 considered or known to be affected by regulation and/or diversions Please note the low -flow characteristics in the above -referenced low -flow report are based on data ending during the late 1980's and do not reflect the occurrence of recent droughts, which have resulted in decreased low -flow statistics at some USGS streamgaging stations. Inspection of the topographical map suggests the stream location could potentially be affected by tidal influences. The elevation at the point of interest is 1 meter or less (3.3 feet or less). In USGS Water -Supply Paper 2221 (Giese and others, 1985), tidal influences up the Chowan River were indicated as far inland beyond the Virginia border (plate 1), which suggests that your point of interest may be affected by tidal influences. Please note the USGS SAWSC Raleigh unit currently refrains from providing low -flow estimates for streams known or suspected of being tidally affected. There are currently no techniques that allow for quantifying the effects of tides on low flows. Concerns that tides may possibly reduce low -flow discharges (that is, relative to low -flow estimates for the same stream not tidally -affected) lead us to speculate that any such estimates for these streams may be too high. Hope this information is helpful in some manner. Thank you. Curtis Weaver J. Curtis Weaver, Hydrologist, PE Email. icweaver@usas.gov USGS South Atlantic Water Science Center Online: htta:[/nc.water.usas.00v1 North Carolina - South Carolina - Georgia 3916 Sunset Ridge Road Raleigh, NC 27607 Phone: (919) 571-4043 // Fax: (919) 571-4041 On Mon, Dec 1, 2014 at 2:06 PM, Christy Richardson <christy richardson�couryse.com> wrote: Curtis, As we discussed earlier today, I am looking to obtain a low -flow estimate (specifically 7Q10) for Bennetts Creek, located near Gatesville, Gates County, NC. I have attached a map of the approximate location on Bennetts Creek, which is just below the 37/137 intersection. The lat/long coordinates for the location is as follows: 36.396040,-76.752377. If you have any questions or need anything else, please let me know. Thanks so much for your help! Christy Richardson Senior En ineeri® Project Manager MMUM (910)733-0908 christy.richardson@couryse.com www.cour sy e.com e0, An Economically Disadvantaged Women -Owned Small Business Page 2 of 3 eN Attachment A. Local Government Review Form General Statute Overview: North Carolina General Statute 143-215.1 tcjt6; allows input frstm local go%cmments 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 Jomestic wastewater discharge facility until it has received a written statement from each tiny and county govcmmcnt having jurisdiction over any pan of the lands on which the proposed facility and its appurtenances am to be ktcawd. 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 effcetl 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 si0fieance and is in the best interest of the State. Instructions to the Applicant Prior to submitting an application for a NPDRS Prima for a proposed facility, the applicant shag request that both the nearby city and county govcmmcm complete this to=. The applicant must: • Submit a copy of the permit application (with a written request for this to= to be completed) to the clerk of the tiny and the count- by certified mail, return mccipt requested. • If either (or loth) local government(s) fail(s) to mail the completed fort, as evidenced by the postmark on the certified mail eard(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to the \PDES Unit. • As evidence to the Comminion that the local govcmmcm(s) failed to respond within 15 days, the applicant shall submit a copy of the certified mail card along with a nomrized letter stating that the local govcmmcnt(s; failed to respond within the 15-dad period. Inswctions to the Local Government: The m arbt tiny and/or county government which may have or has jurisdiction over any pan of the land on which the pmposcd facility or its appurtenances are to be located is required to complete and return this form to the applicant within 15 days of receipt. The form must be signed anti notarized. Namc of local govemmem �(//.h (4vdl/ _ (Ciro/County) Does the eift4cougA. have jurisdiction over any pan of the land on which the pmpus. d facility and its appurtenances arc to he located? Yes (t,4 No ( I If no, please sign this forth, have it notarized, and rcmm it to the applicant. Doc: the cirr/coumv have in effect a zoning or subdivision odinancce Ycs \o If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance% Yes No Dare / 0/5— Sign ^• ____ n¢' Scam of ! Cou/ntr of O,ri( On this -r. dad of N1 t-Pl I personally apprarrvl before me, the sail name ,Tt"f)l h 4� , to me knuwm and known to my to Its the (arson described in and who escorted the foregoing doxumcnt and he (or she) acknowledged that he (or she) csceuted the same arid -bring duh swum by mc, made math that the smtcmcnm in the foregoing document arc may. My Commission espins1 j // - .i(/Y .(Signature of Notary Public) -/ A y P!iub' ^ it EAA Guidance Document Revision: Apn7 2014 C t� Ouw: �,� Page 8 of 8 S �a# %- M N W 2 19'N Custom Soil Resource Report Map —Disposal of Wastewater by Irrigation s a 300000 W9 MI" 3413W 3416D0 N19W 3 Map Smie: 1:13,900'rfp WmAl3rdsmpe(11"c8.505iee1. MeRrs N 0 200_ 400 800 1200 ,.- _ iFeet 0 500 1000 2000 3000 Map ppJetm: Web Mamb r Qm omrdiat : WG$34 Edge bs: UTM Zme 18N WGSB4 25 36°2PUN S F �i 36° 331A N 3122W N2500 3428W M3100 3 m Custom Soil Resource Report MAP LEGEND MAP INFORMATION Area of Interest 1A01) Background The soil surveys that comprise your AOI were mapped at 1:24,000. 0 Area or Interest (AOq . Aerial Photography _ Warning: Soil Map may not be valid at this scale. Soils Soil Rating Polygons F__J Very limited Enlargement of maps beyond the scale of mapping can cause misunderstanding of the detail of mapping and accuracy of soil line Somewhat limited placement. The maps do not show the small areas of contrasting Q Not limited soils that could have been shown at a more detailed scale. Q Not rated or not available Please rely on the bar scale on each map sheet for map Soil Rating Lines measurements. ..� Very limited «r Somewhat limited Source of Map: Natural Resources Conservation Service Web Soil Survey URL: http:/ANebsoilsuNey.nres.usda.gov ,y Not limited Coordinate System: Web Mercator (EPSG:3857) • . Not rated or not available Maps from the Web Soil Survey are based on the Web Mercator Soil Rating Points projection, which preserves direction and shape but distorts 0 Very limited distance and area. A projection that preserves area, such as the Albers equal-area conic projection, should be used if more accurate p Somewhat limited calculations of distance or area are required. Not limited p Not rated or not available This product is generated from the USDA-NRCS certified data as of the version date(s) listed below. Water Features Streams and Canals Soil Survey Area: Gates County, North Carolina Transportation Survey Area Data: Version 10, Sep 13, 2014 ti Rails Soil map units are labeled (as space allows) for map scales 1:50,000 N Interstate Highways or larger. .� US Routes Dates) aerial images were photographed: Feb 15, 2011—Apr 4, Major Roads 2011 Local Roads The orthophoto or other base map on which the soil lines were compiled and digitized probably differs from the background imagery displayed on these maps. As a result, some minor shifting l J ^ Apendix 10-1 Land Application Alternative Land Cost Cost per acre $4,510 according to USDA Farm Real Estate Value by State Estimated Acres Needed 87 acres 100' buffer 18 acres Total Acres Required 105 acres Cost $473,550 Fees and closing costs $14,206.50 assume 3% Total Land Purchase Cost $487,757 Piping/Pumping Cost # Units Cost/unit Total Cost 12" Pipe 18" 1000 ft $40.00 $40,000 10" Pipe 500 ft $30.00 $15,000 Pipe 500 ft $20.00 $10,000 6" Pipe 500 ft $15.00 $7,500 4" Pipe 4500 ft $12.00 $54,000 Irrigation System 2 ea $55,000 $110,000 Pumps 1 ea $300,000 $300,000 Electrical controls 1 ea $90,000.00 $90,000 Engineering 10% of cost ea $0.10 $62,650 Total Piping/Pumping Cost $689,150 Pond FConstruction cost $24,000 from Table 2 - NC State Structural Stormwater Best Management Practices ',18" pipe) $6,000.00 Cost $30,000 Total Land and Capital Cost of Land Application $1,206,907 Land Application Alternative - Operation and Maintenance Costs Pump Station 585,000 gpd 450 gpm Friction Loss 1 ft per 100 ft 70 feet Delivery Pressure 60 psi 139 feet Elevation Head 8 ft 8 feet Total 217 feet Total Dynamic Head Pump Efficiency 70°Y HP Required 33 Horsepower (HP) KW Required 25 Kilowat (KW) lower Cost $0.06 $/kw-hr Duke Energy lumping Rate 0.908428732 kw-hr/1000 gal lumping Cost $0.05 $/1000 gal lump Cost/day $31.89 $/day lump Cost/yr $11,638.33 $/yr )&M Pond 600 $/yr from Table 2 - NC State Structural Stormwater Best Management Practices )perator 10400 $/yr $40/hr - 5 hrs/week Inalytical Costs 2500 $/yr lermit Fees 1260 $/yr ;ytem Maintenance $6,891.S0 $/yr Assume 1% of piping capital Cost Cost of Property Taxes $3,121.64 $/yr Gates County Tax rate $0.64/$100 valuation Total O&M Cost $36,411.48 $/yr Present value Cost Analysis PV Present Value Costs Co Costs incurred in present yr $1,206,907 C Costs incurred yearly $36,411.48 n ending life of facilty = 20 20 r current EPA discount rate 0.05 Appendix 10-2 Wastewater Reuse Alternative Land Cost Cost per acre $4,510 according to USDA Farm Real Estate Value by State Estimated Acres Needed 6 acres 100' buffer 3 acres Total Acres Required 9 acres Cost $40,590 Fees and closing costs $1,217.70 assume 3% Total Land Purchase Cost $41,808 Piping/Pumping Cost # Units Cost/unit Total Cost 12" Pipe 1000 ft $40.00 $40,000 10" Pipe 500 ft $30.00 $15,000 8" Pipe 500 ft $20.00 $10,000 6" Pipe 500 ft $15.00 $7,500 4" Pipe 500 ft $12.00 $6,000 Irrigation System 1 ea $6,000 $6,000 Pumps 1 ea $100,000 $100,000 Electrical controls 1 ea $20,000.00 $20,000 Engineering 10% of cost ea $0.10 $20,450 Total Piping/Pumping Cost $224,950 Pond FConstruction cost $100,000 from Table 2 - NC State Structural Stormwater Best Management Practices , 18" pipe) $6,000.00 Total Pond Cost $106,000 Total Land and Capital Cost of land Application $372,758 Wastewater Reuste Operation and Maintenance Costs Pump Station 38,333 gpd 100 gpm Friction Loss 1 ft per 100 ft 30 feet Delivery Pressure 60 psi 139 feet Elevation Head 8 ft 8 feet Total 177 feet TDH Pump Efficiency 70% HP Required 6 HP KW Required 4 KW Power Cost Pumping Rate Pumping Cost Pump Cost/day Pump Cost/yr O&M Pond Operator Analytical Costs Permit Fees Svtem Maintenance of Property Taxes $0.06 $/kw-hr Duke Energy 0.164661429 kw-hr/1000 gal $0.01 $/1000 gal $0.38 $/day $138.23 $/yr 600 $/yr from Table 2 - NC State Structural Stormwater Best Management Practices 10400 $/yr $40/hr - 5 hrs/week 2500 $/yr 1260 $/yr $2,249.50 $/yr Assume 1% of piping capital Cost $267.57 $/yr Gates County Tax rate $0.64/$100 valuation Total O&M Cost $17,415.30 $/yr Present Value Cost Analysis PV Present Value Costs Co Costs incurred in present yr $372,758 C Costs incurred yearly $17,415.30 n ending life of facilty = 20 20 r current EPA discount rate 0.05 PV $589,790.86 a t Appendix 10-3 NPDES Discharge Alternative Pond Construction cost $24,000 from Table 2 - NC State Structural Stormwater Best Management Practices Piping (100', 18" pipe) $6,000.00 Total Pond Cost $30,000 Total Capital Cost of NPDES Discharge $30,000 Operation and Maintenance Costs F nd 600 $/yr from Table 2 - NC State Structural Stormwater Best Management Practices 10400 $/yr $40/hr - 5 hrs/week l Costs 2500 $/yr es 1260 $/yr Total O&M Cost $14,760.00 $/yr FPresentalue Cost Analysis Present Value Costs o Costs incurred in present yr C Costs incurred yearly n ending life of facilty = 20 r current EPA discount rate 1 $30,000 $14,760.00 20 0.05