NC0064246_Permit Issuance_20081020

/LFWA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
OCT 2 0 2008
Joel M. Pace
Pace Mobile Home Park
13290 Buffalo Road
Clayton, North Carolina 27527
William G. Ross, Jr., Secretary
Coleen H. Sullins, Director
Subject: Issuance of NPDES Permit NCO064246
Pace Mobile Home Park WWTP
Johnston County
Dear Mr. Pace:
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 October 15, 2007 (or
as subsequently amended).
A public hearing on the renewal of the NPDES permit for Pace Mobile Home Park
and four other dischargers was held on June 19, 2008. Because compliance with
permit limits has been poor at times in the past, Pace MHP must optimize treatment
system performance. The Division may require a facilities assessment and/or
engineering alternatives analysis if the discharge does not meet permit limits more
consistently. If it is determined to be necessary, the assessment would:
■ Describe deficiencies and operational difficulties in the existing collection
system and treatment facility that affect performance or permit compliance;
■ Identify potential improvements to improve performance/compliance;
■ Estimate the cost of implementing those improvements; and
■ Provide a schedule for implementation.
The alternatives analysis would evaluate, in particular, the feasibility of connecting
to one of the publicly owned wastewater utilities in the area.
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
512 N. Salisbury St., Raleigh, North Carolina 27604
Phone: [phone] / FAX: [phone] / Internet: www.ncwaterqualit .gM
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
O1e
NofthCarohna
Na&ijilibl

Pace Mobile Home Park — NCO064246
Page 2
The final permit includes the following modification from the draft version:
■ For compliance purposes, all Total Residual Chlorine values below 50 µg/L
will be treated as zero. However, you are still required to report all data
reported by a North Carolina certified laboratory including field certified.
Please see the attached TRC letter for more detail. The TRC compliance level
is noted in the footnotes within Permit Condition A. (1.).
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.
If you have any questions concerning this permit, please contact Vanessa Manuel at
telephone number [phone].
Attachments
Cc: DWQ/SWP Central Files
DWQ/SWP Raleigh Regional Office
NPDES Files

Permit Number: NCO064246
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,
Joel M. Pace
is hereby authorized to discharge wastewater from a facility located at the
Pace Mobile Home Park WWTP
15026 Buffalo Road, Clayton (north of Archers Lodge)
Johnston County
to receiving waters designated as unnamed tributary to Buffaloe Creek in the Neuse River
Basin in accordance with effluent limits, monitoring requirements, and other conditions set
forth in Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2008.
This permit and authorization to discharge shall expire at midnight on April 30, 2013.
Signed this day . OCT 2 0 2008
Cdeen H. Sullins, Pilvctor
Division of Water vuality
By Authority of the Environmental Management Commission

Permit Number: NCO064246
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and provisions included herein.
Joel M. Pace
is hereby authorized to:
1. Continue operation of an existing 0.015 MGD wastewater treatment system,
consisting of the treatment units:
• Continuous flow meter system
• Manual bar screen
• Equalization tank
• Dual aeration chambers
• Dual clarifiers
• Aerated sludge holding tank
• Dual air blowers
• Dual tablet chlorinator
• Dual tablet de -chlorinator
• Audible visual alarms
• Electrical hook-up for portable generator
• Portable generator (kept off -site)
This facility is located at the Pace Mobile Home Park WWTP, 15026 Buffalo
Road in Clayton, north of Archers Lodge in Johnston County.
2. Discharge treated domestic wastewater from said treatment works at the
location specified on the attached map through outfall 001 into an unnamed
tributary to Buffaloe Creek, currently classified C Nutrient Sensitive Waters in
the Neuse River Basin.

Pace Mobile Home Park Facility
Latitude: 35°42'3e' Sub -Basin: os-ua-oe Location AOW
L.oneitude: 79°22'5V
Ouad fl: E 25 NW - Clayton
Stream Class: C-NSW Joel M. Pace
Receiving Stream: Unnamed Tributary to Buffaloe Creek A �O Y'f� Pace Mobile Home Park
Permitted Flow: 0.015 MGD N V r ( NCO064245

Permit Number: NC0064246
A. (1.) EFFLUENT LIMITS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on December 1, 2008 and lasting until April 30, 2013, the permittee is authorized
to discharge treated wastewater from outfall 001. Such discharges shall be limited and monitored by the
permittee as specified below:
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Recorder
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Total Monthly Flow
MG
Monthly
Recorder or
Calculated
Influent or Effluent
BOD, 5-Da 20 De . C - 00310
9
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Weekly
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Solids, Total Suspended - 00530
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Nitrogen, Ammonia Total as N - 00610 - Winter
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400
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Grab
Effluent
hlodne, Total Res1dual2 - 50060
17
/L
2 X week
Grab
Effluent
Temperature, Water Deg. Centigrade - 00010
deg. C
Weekly
Grab
Effluent
0, Oxygen, Dissolved3 - 00300
m
Weekly
Grab
Effluent
Phosphorus, Total as P - 00665
m /L
Monthly
Grab
Effluent
Nitrogen, Total4 (as N) - 00600
m
Monthly
Grab
Effluent
Total Nitrogen Loads - 00600
Ibs/month
Monthly
Calculated
Effluent
Ibs/ ear
Annually
Calculated
Effluent
Nitrogen, lqeldahl, Total as N - 00625
m
Monthly
Grab
Effluent .
Nitrite plus Nitrate Total 1 DET. as N - 00630
m /L
Monthly
Grab
Effluent
PHg - 00400
s.u.
Weekly
Grab
Effluent
Temperature, Water Deg. Centigrade - 00010
deg. C
Weekly
Grab
Upstream &
Downstream
DO, en, Dissolved - 00300
m 1L
Weekl
Grab
Upstream &
Downstream
Winter. November 1- March 31
Summer. April 1- October 31
Footnotes:
1. Upstream: at least 100 feet from the outfall; Downstream: at least 300 feet from the outfall.
2. The facility shall report all effluent TRC values reported by a North Carolina certified laboratory including
field certified. However, effluent values below 50 µg/L will be treated as zero for compliance purposes.
3. The daily average Dissolved Oxygen effluent concentration shall not be less than 5.0 mg/L.
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 and NO2-N are Nitrate and Nitrite Nitrogen, respectively.
5. TN Load is the mass quantity of Total Nitrogen "discharged in a given period of time [see condition A. (2)].
6. The pH shall not be less than 6.0 standard units (s.u.) nor greater than 9.0 s.u.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit Number: NCO064246
A. (2.) CALCULATION OF TOTAL NITROGEN (TN) LOADS
a. The permittee shall calculate monthly and annual TN Loads as follows:
L Monthly TN Load (lbs/month) = TN x TMF x 8.34
Where:
TN = average TN concentration (mg/L) of the composite samples collected during the month
TMF = Total Monthly Flow of wastewater discharged during the month (MG/month)
8.34 = conversion factor, from (mg/L x MG) to pounds
ii. Annual TN Load (lbs/year) = Sum of the 12 Monthly TN Loads for the
calendar year
b. The permittee shall report monthly Total Nitrogen results (mg/ L and lbs/ month) in the discharge
monitoring report for that month and shall report each year's annual results abs/year) in the
December report for that year.
A. (3.) TOTAL NITROGEN ALLOCATIONS
a. The following table lists the Total Nitrogen (TN) allocation(s) assigned to, acquired by, or
transferred to the permittee in accordance with the Neuse River nutrient management rule (T 15A
NCAC 02B .0234) and the status of each as of permit issuance. For compliance purposes, this
table does not supercede any TN limit(s) established elsewhere in this permit or in the NPDES
permit of a compliance association of which the permittee is a co-permittee member.
ALLOCATION AMOUNT hl::
ALLOCATION
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4/1/03
Footnote:
1. Transport Factor = 50%
b. Any addition, deletion, • or modification of the listed allocation(s) (other than to correct
typographical errors) or any change in status of any of the listed allocations shall be considered a
major modification of this permit and shall be subject to the public review process afforded such
modifications under state and federal rules.

Permit Number: NCO064246
A. (4.) OUTFALL SIGNAGE
The permittee shall maintain permanent signage identifying outfall 001 as a wastewater discharge
point. Unless otherwise approved in writing by the Director, the signage shall conform to the
following specifications:
a. It shall be located in reasonable proximity to the outfall.
b. It shall be clearly visible to persons on the adjoining property and in or near the surrounding
waters and, toward that end, shall:
• be two-sided
• be located at least 3 feet above ground level
• at least two feet by two feet (2 ft x 2 ft) in size
• consist of black letters on a white field; the word "notice" to be at least 3 inches tall and the
remaining words to be at least 2 '/4 inches tall
c. The signage shall contain, at a minimum, the following information:
NOTICE
THIS IS A WASTEWATER DISCHARGE POINT
PACE MOBILE HOME PARK
WASTEWATER TREATMENT PLANT
NPDES PERMIT NCO064246
< local contact number for the facility >
NORTH CAROLINA
DIVISION OF WATER QUALITY
RALEIGH REGIONAL OFFICE
919-791-4200

North Carolina Division of Water Quality
September 29, 2008
Memorandum
To: Coleen Sullins
From: Bradley Bennett
Stormwater Permitting Unit
Subject: Neuse Wastewater Permit Renewals
Hearing Officer's Report and Recommendations
On June 20, 2008 1 served as Hearing Officer for a public hearing on the reissuance of five wastewater discharge
permits in the Neuse River Basin. The public hearing was requested by the Neuse River Keepers on behalf of the Neuse
River Foundation (NRF) and focused on permits that the NRF had concerns for in terms of compliance and enforcement.
The five permits considered are outlined in the table below.
South Granville Water and Sewer Authority (SGWASA) WWTP - NCO026824: This facility discharges
5.5 MGD of treated domestic and industrial wastewater into Knapp of Reeds Creek.
Town of Stantonsburg WWTP - NCO057606: The facility is permitted to discharge 375,000 gallons per
day of treated domestic wastewater to Contenlnea Creek,
Pope Industrial Park WWTP - NCO060526: Facility serves a medium sized industrial park and treats
100% domestic effluent. Permitted to discharge at 0.008MGD to Swift Creek Lake Wheeler).
Indian Creek Overlook WWTP - NCO060771: Facility is permitted to discharge 64,000 gallons per day of
treated domestic wastewater to Swift Creek Wake County).
Pace Mobile Home Park WWTP - NCO064246: Facility is permitted to discharge up to 150,000 gallons
per day of treated domestic wastewater into a tributary to Buffalo Creek.
The hearing was held in Raleigh and around thirty people attended, not counting Division staff. Ten people spoke at the
hearing and provided comments on the various permit renewals being considered. The public comments period on the
proposed permits was open until June 30, 2008. Twenty individuals/groups provided written comments on the proposed
permits. The major issues from the public comments are summarized below.
SUMMARY OF PUBLIC COMMENTS RECEIVED
South Granville Water and Sewer Authority:
• A number of commenters noted the facility discharges to impaired waters that are classified as NSW and that the
discharge is upstream of Falls Lake which is a drinking water supply source. Comments noted concerns that
protection was not afforded to immediately downstream waters (Falls Lake) through the permit's nutrient
requirements that are based on protecting the estuary at the lower part of the basin.
• The facility's compliance history was also noted as a concern although comments did note improvement since the
facility was taken over by SGWASA.
• Specific concerns were noted by commenters about the facility's pretreatment program, wastewater lab and
industrial users and some commenters noted this as the main area of concern for the facility. Comments
expressed the opinion that the requirements for the program were not adequate and that additional monitoring
parameters should be added (specifically zinc, copper, cadmium, antimony and nitrogen) and that monitoring
should be more frequent. Comments requested that no additional industrial users be added until the pretreatment
program was in full compliance.

• A number of comments were received concerning the possibility of an added discharge to the plant from a
proposed facility — the National Bio and Agro-Defense Facility. The major issues here were the constituents that
may be discharged to the SGWASA plant from this facility and SGWASA's ability to handle these pollutants.
There was also general concern about the facility's impact in the area.
• Comments requested that an Engineering Alternatives Analysis be completed by the facility to look at
environmentally sound alternatives to discharge including reuse alternatives.
• Comments were also raised about Environmental Justice implications with the facility.
Town of Stantonsbura Wastewater Treatment Plant:
• One commenter addressed this facility and noted long term difficulties with compliance and made a request that
an Alternatives Analysis be completed to evaluate other alternatives to discharge.
Pope Industrial Park Wastewater Treatment Plant:
• Comments were received concerning the continued non-compliance for this facility and the lack of response to
correct these problems by the facility or to move toward connection with the City of Raleigh's wastewater system.
• Comments noted the facility's discharge to Swift Creek, which is an impaired water and also questioned the
facility's impact on the Dwarf Wedge Muscle located in the watershed.
• Comments requested that the permit require an assessment to determine the sources causing BOD and
Ammonia limits to be exceeded. Also requested an Industrial Waste Survey be conducted to assess materials
getting to the facility.
• Comments requested that the permit require connection of the facility to the City of Raleigh's wastewater system
by a specific deadline.
• The owner of the facility provided comments indicating an anticipated hook up to the City when sewer line was
available to the facility. He also noted the cost for hook-up and a desire for time to achieve this. Owner also
noted that it had been challenging to maintain qualified operators for the facility and encouraged the state to work
to train more operators.
Indian Creek Overlook Wastewater Treatment Plant:
• Comments on this facility indicated that the facility was working with the City of Raleigh to connect to their sanitary
sewer system. These comments requested a reopener in the permit to assure the connection occurred.
• Comments noted the facility's discharge into Swift Creek which is listed as an impaired water.
Comments also highlighted compliance issues at the facility and questioned the unknown reasons for the
noncompliance.
Pace Mobile Home Park Wastewater Treatment Plant:
• Comments noted that the facility drained to waters that were in trouble and impaired (Buffalo Creek) and asked
for added requirements for the facility.
• It was acknowledged in comments that the facility has had substantial improvements but was still not considered
to be enough.
• Commenters requested a feasibility study be conducted to look at the possibility of connection to Johnston
County's sanitary sewer.
Page 2

History/Background:
Wastewater permits in the Neuse River Basin have had a history of close review and consideration as the Division has
worked to address nutrient management issues. Over time a series of strategies have been put in place to address
issues in the basin and to be responsive to various programs — Nutrient Sensitive Waters Designation, TMDL
development, impaired waters issues, etc. Various organizations have been a part of this process and have provided
valuable input. As an example, over time the Neuse River Foundation (NRF) has continued to work with the Division in
the permit renewal process to target discharges of concern for additional consideration in the permit renewal process.
During this cycle of permit renewals the five permits outlined here were targeted for closer public review working with the
Foundation. As mentioned previously, these facilities were targeted based on NRF's concerns for compliance with their
permits and abilities to protect water quality.
My review of these facilities has considered the public comments received both at the public hearing and those submitted
in writing during the comment period. I have also gathered information from the permit writers, from regional office and
other compliance staff familiar with the facilities and from staff familiar with various strategies related to these facilities and
permits. All the facilities have experienced various levels of non-compliance with the current permits over the most recent
permit term. It is also apparent that non-compliance for the facilities is not always the result of the same issues. In some
cases it appears that facilities can achieve compliance with consistent operation and maintenance of the facility. In other
cases it appears that some changes should be made at the facilities and potentially in the permits to assure that the
discharges come into, and remain in compliance. It is also apparent that some unique situations exist for these facilities
that should not be ignored in the process.
Specific Recommendations
Below is a discussion of my recommendations for each of the five permits. I recommend renewal of all of the permits. As
noted below, I have made specific recommendations for modifications to most of the permits before reissuance.
South Granville Water and Sewer Authoritv
It's apparent that this facility continues to have challenges in meeting the conditions of its permit. The new permittee
(SGWASA) has taken steps to address facility operation and work toward improvements to the facility. These steps,
however, have not yet resulted in established improvements or timelines for those improvements to move the facility into
consistent compliance. The permit needs to set a process to more clearly establish this end result.
From comments from the public and discussions with DWQ staff I believe the concern about this facility's discharge above
the Falls Lake Water Supply is valid, especially with regard to nutrients. Establishing different permit conditions to
address this concern seems to be a reasonable request. However, my discussions with staff lead me to believe that this
isn't as simple a solution as it seems. The facility is currently a part of the Neuse River Compliance Association, and
already subject to established nutrient loading and compliance procedures. It does appear possible that more stringent
limits can be established for the facility, but this would require a modeling effort to establish the appropriate basis for those
limits. That modeling effort is under way as part of the ongoing Falls Lake Study.
I understand and appreciate the concerns for protecting the uses downstream of this discharge but the process of
establishing specific permit limits/conditions for this facility seems to be better handled in the Falls Lake Study process.
It's apparent that the end results of this study will likely lead to this facility receiving more stringent limits and being
required to modify their treatment process to achieve these changes. With this in mind, it is appropriate for the facility to
be required now to evaluate and move forward on reasonable efforts to improve the capabilities of their treatment system.
Improvements implemented should be considered in a positive sense for the facility when conditions are set under the
results of the Falls Lake Study/TMDL. Commenters noted their agreement that improvements should be credited in this
process.
In addressing the issues discussed above my recommendation is that the permitting staff develop appropriate language in
the final permit to require that the facility undertake Wastewater Management Planning activities as highlighted below.
Page 3

Optimization Plan. Within 12 months of the reissuance of this permit the facility should be required to submit the
results of an optimization planning effort designed to identify specific measures, key tasks and schedule for
implementation of recommendations to optimize performance of the treatment system. This review should spell
out the potential capabilities of the plant and the strategies to move toward meeting these capabilities.
Facilities Analysis and Reuse Evaluation. Within 18 months of the reissuance of this permit the facility should be
required to submit a facility assessment to describe deficiencies and operational difficulties in the treatment plant
that affect performance and compliance and identify potential improvements. This should include a technical
evaluation of reuse and reclamation alternatives for some or all of their plant discharge. This should recognize
that ongoing studies in the Falls Lake Watershed will impact plant evaluations in the future and this effort should
start with focus on straight forward efforts that would be effective and achievable in the short term. The process
should work to evaluate plant operation, implement effective changes and consider all viable levels of reuse that
are reasonable. This recognizes that even if all the discharge can not be handled through reuse alternatives, any
portion that can be removed is an advantage in downstream protection.
The information required in these evaluations will be submitted to the Division and once accepted would become
enforceable components of the permit including schedules for implementation.
The facility's pretreatment program continues to have compliance issues, including their most recent inspection in August.
These issues need to be resolved in order for the facility to move toward consistent compliance. There were requests for
more stringent requirements in this area, but my discussions with Division staff indicates that permit changes are not
needed, rather, it is more an issue of the appropriate compliance efforts to get the facility inline with the current permit
conditions. My recommendation is that Division efforts be focused in this area to assure that proper steps and timelines
are established to assure that the facility's pretreatment program attains full compliance. This may include available
compliance/enforcement measures as the Division sees necessary and regular reporting by the facility on efforts and
results in this program area. The Division should consider the possibility of establishing set compliance points in this
process that may trigger enforcement measures if unmet.
Comments were also received on a proposed National Bio and Agro-Defense Facility that could potentially be developed
in the area and seek to connect to the SGWASA system. Questions centered around the plant's ability to treat the waste
streams potentially associated with this type of facility. While the concerns are reasonable, it seems that they are not
appropriate for consideration in this permit renewal process. The facility may not actually come to the area and if it does
there will obviously be other environmental reviews that would better assess the potential wastewater issues at that time
when more is know about the facility. No recommendations are included here on this facilities potential impact other than
to note that future detailed reviews should be undertaken if such a facility should plan to connect to this plant to assure
that conditions are appropriate for the connection.
Stantonsburg WWTP
One commentor noted ongoing compliance issues with this facility. Discussions with Division staff verify that some
regular issues do exist for this facility. Some of the main issues appear to be solids management at the facility, potential
problems with the current final sampling location, and potential inflow and infiltration at some points in their system. In
response to these issues I recommend that permitting staff work with the regional office to address some areas of concern
in the permit. These include modifications to the facility's disinfection component (add chlorine contact chamber and
dechlorination), adjustments to target a more appropriate final sampling point and modifications to monitoring
requirements (increased frequency and added parameters) to better identify problems within the system.
With these changes in the permit, more information will be available to help the Division and the facility to determine
necessary strategies for the plant to move toward more consistent compliance. The permit transmittal letter should alert
the facility to the potential for additional adjustments based on the results of these changes. Continued compliance issues
will require the development of a solids management plan to better address solids issues and the development of a facility
assessment to address deficiencies and operational difficulties in the treatment system and the existing collection system.
Page 4

Pope Industrial Park
Comments on this facility focused on non-compliance with permit conditions and with the possibilities for the facility to
connect to the City of Raleigh's sewer system. This facility is a small treatment plant on a very low flow stream with
conditions that appear to make the system challenging to operate. Ultimately the most effective alternative does appear
to be connection to a system more able to consistently handle the waste stream. The owner has indicated his desire to
move toward connection in this permit term and the Division should encourage this effort in a reasonable timeframe.
From discussions with Division Staff it appears that major issues with this facility are 1) periodic situations where a tenant
disposes of material that the plant is not designed to treat (paint, etc.) and 2) consistently having experienced operators
for the facility.
The permit includes a requirement for an Industrial Waste Survey to assess the types and sources of wastewater entering
the plant. This directly addresses a comment received on this action. In addition, I recommend that the final permit
require a Communications Plan that establishes a regular process of informing the customers of the system how their
discharges to the system impact the system's performance and alerting them to the types of wastewaters they are allowed
to send to the system. Communication should be required on a quarterly basis to assure that tenants remain attentive to
the need to avoid inappropriate disposal into the system. Documentation of these efforts must be made available the
Division as part of regular record review.
Indian Creek Overlook
Comments on this facility noted unresolved compliance issues and the facility discharge to impaired waters. It was also
noted that efforts are in process for the facility to connect to the City of Raleigh. Based on responses from the facility and
the City it does appear that this is likely within the next couple of years. In discussions with staff it appears that this facility
is not overloaded and should be able to meet its limits with proper operation. BOD and ammonia were noted by staff as
areas the facility should potentially revisit. In addition, staff have mentioned the potential benefits of adding UV at the
facility.
The facility does appear headed to connection and they should keep Division staff updated on the process and timeline. If
connection is not to occur, the facility should consider the addition of UV disinfection and also evaluate appropriate
engineering analysis to revisit treatment alternatives to reduce BOD and Ammonia. I recommend that the transmittal of
this renewed permit include specific discussion of these items and noting that they will be required for the system and
schedules will be set for these items if the facility has not established a schedule for connecting to the City of Raleigh
within 18 months of the renewal of this permit.
Pace Mobile Home Park
Some concerns were raised about this facility, but it was noted that the facility has shown improvement. Discussions with
Division staff indicate that the plant is well maintained and may have periodic seasonal challenges. The facility has shown
more consistent compliance. Alternatives for this discharge do not appear to be as available as for other facilities,
including the possibility of connection. Based on improvements shown and limited reasonable alternatives, I do not
recommend any additional changes beyond those in the draft permit. I do recommend that the transmittal of the permit
should notify the facility that failure to meet permit limits may lead to the facility being required to conduct an alternatives
analysis of viable wastewater disposal alternatives.
Page 5

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Permit Number: NCO064246
A. (4.) OUTFALL SIGNAGE
Not later than 120 days after the effective date of this permit (February 1, 2005), the Permittee shall
install and thereafter maintain permanent signage identifying Outfall 001 as a wastewater discharge
point. Unless otherwise approved in writing by the Director, the signage shall conform to the
following specifications:
a. It shall be located in reasonable proximity to the outfall.
b. It shall be clearly visible to persons on the adjoining property and in or near the surrounding
waters and, toward that end, shall:
• be two-sided
• be located at least 3 feet above ground level
• at least two feet by two feet (2 ft x 2 ft) in size
• consist of black letters on a white field: the word "notice" to be at least 3 inches tall and the
remaining words to be at least 2 V4 inches tall
c. The signage shall contain, at a minimum, the following information:
NOTICE
THIS IS A WASTEWATER DISCHARGE POINT
PACE MOBILE HOME PARK
WASTEWATER TREATMENT PLANT
NPDES PERMIT NCO064246
< local contact number for the facility >
NORTH CAROLINA
DIVISION OF WATER QUALITY
RALEIGH REGIONAL OFFICE
919-571-4700

AFFIDAVIT OF PUBLICATION
NORTH CAROLINA.
Johnston County.) Ss.
A NPDES
On the basisof thorough staff revieward application of NC
General Statute 343.215.1 and 15A NCAC 02H.0109 and
other lawful standards and regulations, the North Caroli-
na Environm.rml Management Commission Proposes to
Issue a National Pollutant Discharge Elimination System
(NPOES) wastewater discharge Permit to the Person(e)
listed below effective 6 days from the Publish date of this
notice.
be
Copies of the draft Permit and other supporting Informa-
tion on file used to determine conditions present in the
4raft Permit are available upon request and payment of
the costs of reproduction. Mail comments and/or reauest5
for information to the NC Division of Water Quality at the
above address or call Dina Sprinkle (919)73 5(l exten-
sion 363 at the Paint Source Branch.. Please include the
NPDES Permit number (below) In any communication.
Interested persons may also visit the Division of Water
Quality of 512 N. Salisbury Street. Raleigh, NC 276D4-I148
between the hours of 8:00 am and 5:00 Pm to review the
Information on file.
Kintler Morgan Swihemt TemnI.1% I i C has appl led far
a mreyAl W NPDES permit (N000811278) for disrhnrge of
treuled sfomN.ater m an unnamed iriMary of Mill
Creek, located within the Neese River Basin. Totol
susperckd ashes is walarpualHy limited. This disdprge
moon, affect future wasteload anaoollora to this Portion of
the receiving stream
NPDES Permit Number NCODM246, Paw Mobile Hare
Park, has applied for ronewal of Its Permit discharging
treated domestic wastewater to an unnamed tributary to
Buffalo Creek In the Neuse River Basin. Currently BODS,
NH N, Dissawal Onygau and Total Residual Chlorine,
are water quality limited. This discharge may affect
future allowHaas in this portion of the rewlvlm stream
April 30, M
Before the undersigned, a Notary Public of Chatham
County North Carolina, duly commissioned and authorized to
administer oaths, affirmations, etc., personally appeared Debra
Peebles, who, being duly swom or affirmed, according to law,
doth depose and say that she is Billing Manager -Legal
Advertising of The Herald a corporation organized and
doing business under the Laws of the State of North Carolina,
and publishing a newspaper known as The Herald , in
the City of Smithfield , Johnston County and State aforesaid,
the said newspaper in which such notice, paper, document, or
legal advertisement was published was, at the time of each and
every such publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of the General
Statutes of North Carolina, and that as such she makes this
affidavit; that she is familiar with the books, files and business
of said corporation and by reference to the files of said
publication the attached advertisement for NC DMSION OF
WATER QUALITY was inserted in the aforesaid newspaper
on dates as follows: 04/30/08
Account Number: 73350833
The above is correctly copied from the books and files of the aforesaid Corpo tion and publication.
Debra Peebles, Billing Manager -Legal Advertising
Wake County, North Carolina
Swom or affirmed to, and subscribed before me, this
01 day of MAY 1 2008 AD ,by Debra Peebles.
In Testimony Whereof, I have hereunto set my hand
and affixed my official seal, the
yp day and year aforesaid.
Z VW
anet Scroggs, Notary Public
My commission expires 140' of March 2009.

WATF9
Michael F. Easley, Governor
11 �1�^\OG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
� � --�
Coleen H. Sullins, Director
Division of Water Quality
January 17, 2008
To: Vanessa Manuel
Through: Barry Herzberg
From: Mitch Hayes
Subject: Pace Mobile Park WWTP
Permit #NC0064246
Joel M. Pace - owner
Johnston County
Vanessa,
Some items noted for the permit renewal:
1 vw --
1 JAN �Ii
z s zoos � L II
DENR-WATER OU4lITY
POINT�UR_-E BRANCH I
1) A tablet chlorinator was added to the WWTP in 2005. Please use the following description for
the WWTP: manual bar screen, equalization basin, dual aeration chambers, dual clarifiers,
aerated sludge holding tank, dual air blowers, dual tablet chlorinator, dual tablet dechlorinator, a
continuous effluent Stevens flow meter, audible visual alarms, electrical quick connect for hook-
up to a portable generator. Portable generator is kept off -site at owner's home.
2) The location of the discharge outfall on permit and application is not correct. Please see the
attached web link for the Topozone map indicating the correct location. Coordinates for the
discharge outfall are 35 42' 36" 78 22' 54". htto://www.t000zone.com/mao.aso?lat=35.71014&Ion=-
78.38181 &datum=nad27&u=6&laver=DRG&size=l&s=25
3) For the review period August 01, 2004 through October 31, 2007, there have been 7
enforcement cases against Pace Mobile Park. Six cases were for exceeding monthly NH4-N
limit. There are currently no operational or compliance problems. Last enforcement case was
May 2007.
The Raleigh
Regional Office has no objection in reissuing permit NCO064246 with corrections as noted.
�
0- /4
Signature of Report arer Pre DatZ�G�
9 p P
Signature of Regional Supervisor Date
Cc: RRO SWP files
Ni�l�e rr,,<relOtl 8
Natmallb
North Carolina Division of Water Quality 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone]
httemet: www.ncwaterqualitv.ore Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
Customer Service
1-877-623-6748

PACE MOBILE HOME PARK
Joel M. Pace
13290 Buffalo Road
Clayton, NC 27527
919-553-5701
October 24, 2007
NC DENR
Division of Water Quality
Point Source Branch
Mrs. Frances Candelaria
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mrs. Candelaria,
L j`
OCT 2 5 2 —
DENR - VIATu� UUNLII
MINT Cnmlr npnJru
I'm writing in response to my NPDES permit expiring on April 30, 2008. 1 am
requesting a renewal for permit NPDES NC 0064246 wastewater treatment system
located at the Pace Mobile Home Park WWTP off NCSR1003 north of Archer Lodge
in Johnston County.
Sincerely,
J ?1M. ace

NPDES APPLICATION - FORM D
For privately owned treatment systems treating 100% domestic wastewaters <1.0 MGD
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699
NPDES Permit OCOO91(4
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City --
State / Zip Code
Please print or type.
ac e-
01Ql +nll. eSc '205-21
Telephone Number (q(q ) F553 -5-76
Fax Number RW 5r)3 - gi(OR-1
e-mail Address
2. Location of facility producing discharge:
Check here if same address as above ❑
Street Address or State Road
city
State / Zip Code
County
�' 10.uknni
'OCT 2 5 2007
DENR
POINT 5
3. Operator Information:
Name of the firm, public organization or other entity that operates the facility. (Note that this is not
referring to the Operator in Responsible Charge or ORQ
Name
Mailing Address
City
State / Zip Code
Telephone Number ( )
Fax Number ( )
1 of 3 Form-D 4/05

NPDES APPLICATION - FORM D
For privately owned treatment systems treating 100% domestic wastewaters <1.0 MGD
4. Description of wastewater:
Facility Generating Wastewater(check all that apply):
Industrial
❑
Number of Employees
Commercial
❑
Number of Employees
Residential.
[�]
Number of Homes A
School
❑
Number of Students/Staff
Other
❑
Explain:
Describe the source(s) of wastewater (example: subdivision, mobile home park, shopping centers,
restaurants, etc.):
Population served: 1- )35-
5. Type of collection system
Lk-Se-parate (sanitary sewer only) ❑ Combined (storm sewer and sanitary sewer)
6. Outfall Information:
Number of separate discharge points
Outfall Identification number(s) 00
Is the outfall equipped with a diffuser? ❑ Yes 1940
7. Name of receiving stream(s) (Provide a map showing the exact location of each outfall).
Unlknej tr,'bojgq fo 1301191 tC✓eeK ;414>: i4/e01-in.t '✓°i' �s,%7
8. Frequency of Discharge: &? Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs: Duration: _
9. Describe the treatment system
List all installed components, including capacities, provide design removal for BOD, TSS, nitrogen and
phosphorus. If the space provided is not sufficient, attach the description of the treatment system in a
separate sheet of paper.
- (O, O/ �/1'l d D
0U4/cG2/'4-/io11 G/IamberS
- 004 C %41"-F e rrs
- of 3 /ion S y sfc iiJ
2 of 3 Form-D 4/05
—14 le dethlbr 51s,em

NPDES APPLICATION - FORM D
For privately owned treatment systems treating 100% domestic wastewaters <1.0 MGD
10. Flow Information:
Treatment Plant Design flow 60/3MG11)
Annual Average daily flow DQ2M MGD (for the previous 3 years)
Maximum daily flow 0. c� ?a MGD (for the previous 3 years)
11. Is this facility located on Indian country?
❑ Yes 21Qo
12. Effluent Data
Provide data. for the parameters listed. Fecal Coliform, Temperature and pH shall be grab samples, for all other
parameters 24-hour composite sampling shall be used. If more than one analysis is reported, report daily maximum
and monthly average. If only one analysis is reported, report as daily maximum.
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BODS)
13..E
9� ©
�-
Fecal Coliform
yc.)O/ /o 0
Total Suspended Solids
j�`
. 0
Temperature (Summer)
Temperature (Winter)
pH 0 ct4k 1.0
Sf4vi4let,,d U,1 i �s
13. List all permits, construction approvals and/or applications:
Type Permit Number Type
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA) Ocean Dumping (MPRSA)
NPDES /UG 006 y,� 1-% 1�p Dredge or fill (Section 404 or CWA)
PSD (CAA) Other
Non -attainment program (CAA)
14. APPLICANT CERTIFICATION
Permit Number
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.
del 141. /'ace- oc44e '
Printed name of Person Signing Title
0
of Applicant
l d - C� -c3
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 $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a
punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.)
3 of 3 Form-0 4/05

PACE MOBILE HOME PARK
Joel M. Pace
13290 Buffalo Road
Clayton, NC 27527
919-553-5701
October 24, 2007
SLUDGE MANAGEMENT PLAN
For the sludge management plan at Pace Mobile Home Park WWTP permit number NC
006424. The sludge generated during the wastewater treatment is removed by Davis
Septic Tank Cleaning from Pine Level, NC License # 22181 and taken to the Smithfield
WWT P.
el M. Pace

information request
Subject: information request
From: Mitch Hayes <[e-mail]>
Date: Mon, 02 Jul 2007 17:12:18 -0400
To: [e-mail]
�6AS,r 3kS' to
"�, /�A5
7 G.
Vanessa,
I am responding to your request for information on the following facilities: Stantonsburg W WTP, Pace
Mobile Home Park WWTP, Kenly Regional WWTP, and Jerry G. Williams & Sons, Inc., Wet Deck
Storage Site, Princeton WWTP.
Slantonsburg W WTP NCO057606 - the facility continues to have flow and fecal problems during
heavy rainfall. The high fecal colifonn counts are due to a backup of flow from Contentnea Creek in the
flow sampling area during rain events. The high flow violations are from the neighboring Town of
Saratoga who sends their wastewater to Stantonsburg for treatment and is constantly surcharging the
Town of Stantonsburg collection system during heavy rainfall. CG&L and the RRO are waiting for a
response from the Town how they will address the flow and fecal issues and to the technical review
comments from CG&L PER Project No. E-SRL-T-05-0068.
A/Pace Mobile Home Park W WTP NCO064246 - the facility currently has BOD and ammonia violations
V for the month of April 2007. Fecal violations were recorded for 9/14/2006 and 01/25/2007 however,
these were caused by laboratory error and dirty sample bottles supplied by the laboratory. The facility
appears to have trouble maintaining adequate amount of nitrofying bacteria during cold temperatures.
This is what the ORC has stated during past CEI's when asked about past frequent ammonia violations.
�enly Regional WWTP - fecal violations were recorded for January, April, May, and November 2006.
The Town Manager stated that the investigating the causes of the fecal violations. Filter sand in the
traveling bridge filters was replaced. The facility has not had a fecal violation since the sand was
They are currently compliant with their permit.
VAerry G. Williams & Sons, Inc., Wet Deck Storage Site NCO085936 - "The process wastewater"
consists of water runoff from the wet decking operation. Screens to catch bark in the runoff on the
concrete pad have helped in reducing settleable solids. The discharge point was changed in 2006. The
new discharge point is more representative of the discharge of the wet decking operation, as it does not
receive flow from other stormwater drainage. The other two discharge points from the concrete pad are
covered under stormwater permit NCG210290. The facility has been compliant since December 2006.
Ar
inceton WWTP NCO026662 - Past flow violations have been caused by heavy rains due to tropical
storms. The plant has been recently experiencing fecal violations during times of extreme low inflow;
when school is out for the summer. There is no industry in Princeton. The ORC has stated that the fecal
"problems" did not occur until after the WWTP was upgraded to include two -fifteen -foot diameter
secondary clarifier's. Don Register has made a technical assistant visit 06/25/2007 to help solve the
frequent violations. Don has made several recommendations on plant operation, but has yet to take effect
until he has permission from the Town of Princeton and Envirolink; the company who operates the
WWTP.
If you have any questions about the above information, just let me know.
Mitch Hayes
1 of 2 7/3/2007 6:43 AM

information request
-------- Original Message --------
Subject: Neuse Permits Review
Date: Tue, 19 Jun 2007 15:20:15 -0400
From: Vanessa Manuel <Vanessa.Manuelpncmail.net>
To: Chuck Wakild <Chuck.Wakildpncmail.net>
Chuck,
To prepare for an upcoming meeting with the Neuse River Basin Association, we are gathering
information on those permits in the Neuse River Basin that have received civil penalty assessments in
the last 5 years (see attached spreadsheet). Please have your staff provide any information you have on
the status of these facilities, especially if the region is working with the facility to bring it back into
compliance. Also note if any SOCs are being discussed or under negotiation. Any information you can
provide on the facility's history and/or severity of the problem would be most useful for this meeting.
Please provide this information to me by next Wednesday, June 27th. Please contact me if any delays
are suspected. Thanks.
Vanessa
P.S.-
The worksheet named "Summary" gives a summary listing of the permits with compliance issues.
The worksheet titled "Violations" lists the enforcement cases and parameters violated for each facility
found on the Summary sheet.
If any questions, please contact me.
Mitch Hayes <mitch.hayesna,ncmail.net>
Environmental Specialist
Environment & Natural Resources
NC Division of Water Quality
2 of 2 7/3/2007 6:43 AM

FACT SHEET FOR EXPEDITED PERMIT RENEWALS
Rude Tnfnrmatinn in dptprmine notential for expedited aermit renewal
Reviewer/Date
Permit Number
Facility Name
e- k
Basin Name/Sub-basin number
030qou
Receiving Stream
Stream Classification in Pennit
Does permit need NH3 limits?
Does permit need TRC limits?
Does permit need Enteroccoci limit?
Does permit have toxicity testing?
Nfn
Does permit have Special Conditions?
Does permit have instream monitoring?
es o e-
Is the stream impaired (on 303(d) list)?
--
Any obvious compliance concerns?
Any permit mods since last unit?
Existing expiration date
8'
New ex iration date
New ermit effective date
TURe, alinvinnnc Vnmmante
This is a SIMPLE EXPEDITED ermit renewal (administrative
YES_ P
renewal with no changes, or only minor changes such as TRC, NH3,
nametownership changes).
YES_ This is a MORE COMPLEX EXPEDITED permit renewal (includes
Special Conditions (such as EAA, Wastewater Management Plan),
Conventional WTP, 303(d) listed, toxicity testing, instream monitoring,
compliance concerns, phased limits). Basin Coordinator to make case -by -
case decision.
YES_ This permit CANNOT BE EXPEDITED for one of the following reasons:
• Major Facility (municipal/industrW)
• Minor Municipals with pretreatment program
• Minor Industrials subject to Fed Effluent Guidelines (lb/day limits for BOD, TSS, etc)
• Limits based on reasonable potential analysis (metals, GW remediation organics)
• Permitted flow > 0.5 MGD (requires full Fact Sheet)
• Permits determined by Basin Coordinator to be outside expedited process
TR Version 9/7/2007