HomeMy WebLinkAboutNC0074900_Permit Issuance_19961209State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
December 9,1996
Mr. Kim Colson
Mid -South Water Systems
P.O. Box 127
Shen -ills Ford, North Carolina 28673
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�EHNF1
Subject: NPDES Permit Issuance
Permit No. NCO074900
Knotts Landing WWTP
Iredell County
Dear Mr. Colson:
In accordance with the application for a discharge permit received on May 7, 1996, the Division is
forwarding herewith the subject NPDES 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 US
Environmental Protection Agency dated December 6,1983.
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, Post Office Drawer
27447, Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision shall be final and
binding.
Please take notice this permit is not transferable. Part 11, E.4. addresses the requirements to be followed
in case of change in ownership or control of this discharge.
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, 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 Susan Robson at telephone number (919)
733-5083, extension 551.
Sincerely,
Original Signed By
David A. Goodrich
A. Preston Howard, Jr., P.E.
cc Central Files
Mooresville Regional Office
Mr. Roosevelt Childress, EPA
Permits and Engineering Unit
Facility Assessment Unit
P.O. Box 29535, Raleigh, North Carolina 27626.0535 Telephone (919) 733.5083 FAX (919) 733.0719
An Equal Opportunity Affirmative Action Employer 50% recycled / 10 % post -consumer paper
Permit No. N00074900
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
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,
Mid South Water Systems, Inc.
is hereby authorized to discharge wastewater from a facility located at
Knotts Landing Development
NCSR 1197 (Oak Tree Road)
west of Mooresville
Iredell County
to receiving waters designated as the Catawba River (Lake Norman) in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III and IV hereof.
The permit shall become effective January 1, 1997
This permit and the authorization to discharge shall expire at midnight on June 30, 2000
Signed this day December 9, 1996
Original Signed By
Qavid A- GnMrirh
A. Preston Howard, Jr., P.E., Director
Division of Water Quality .
By Authority of the Environmental Management Commission
Permit No. NC0074900
SUPPLEMENT TO PERMIT COVER SHEET
Mid South Water Systems, Inc.
is hereby authorized to:
1. After receiving an Authorization to Construct from the Division of Water Quality for each phase
of expansion, construct and operate a wastewater treatment facility with an ultimate capacity of
0.30 MGD located at Knotts Landing Development, SR 1197 (Oak Tree Road), west of
Mooresville, Iredell County (See Part III of this Permit), and
2. Discharge from said treatment works at the location specified on the attached map into the
Catawba River (Lake Norman) which is classified Class WS-IV B CA waters in the Catawba
River Basin.
a;, a
a -
�
I N'
ROAD CLASSIFICATION
PRIMARY HIGHWAY LIGHT.DLrry ROAD. HARD OR
HARDSURFACE IMPROVED SURFACE
SECONDARY HIGHWAY
HARD SURFACE =011110= UNIMPROVED ROAD =_—
Latitude 35036'17"
Longitude 80056:35"
Map # E15SW
Sub -basin 03-08-32
Stream Class
WS-IV, B CA
Discharge Class
05
Receiving Stream
Lake Norman
Design Q 0.3 MGD Permit expires 6/30/2000
QTb
11
J
SCALE 1:24 000
0 1 MILE
0 7000 FEET
1 0 1 KILOMETER
CONTOUR INTERVAL 40 FEET
QUAD LOCATION Mid South Water Systems, Inc.
NCO074900
Iredell County
Knotts Landing Subdivision
A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NCO074900
During the period beginning upon the effective date of the permit and lasting until EXPANSION ABOVE 0.100 MGD or expiration, the
Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as
specified below:
Effluent Characteristics
Flow
BOD, 5-Day, 200C
Total Suspended Residue
NH3 as N
Dissolved Oxygen**
Fecal Coliform (geometric mean)
Total Residual Chlorine
Oil and Grease
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Discharge
Limitations
Monitoring Requirements
Measurement
Sample
Sample
Monthly. Avg. Weekly AVQ.
Daily Max.
Frequency
Typed
Location*
0.100
MGD
Continuous
Recording
I or E
15.0
mg/l
22.5 mg/I
Weekly
Composite
E
30.0
mg/I
45.0 mg/I
Weekly
Composite
E
4.0
mg/l
Weekly
Composite
E
Weekly
Grab
E
200
/100 ml
400 /100 ml
Weekly
Grab
E
28.0 µg/l
2/week
Grab
E
30.0
mg/l
60.0 mg/l
Weekly
Grab
E
Weekly
Grab
E
Quarterly
Composite
E
Quarterly
Composite
E
* Sample locations: E - Effluent, I - Influent.
** The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored weekly at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NCO074900
During the period beginning upon EXPANSION ABOVE 0.100 MGD and lasting until expiration, the Permittee is authorized to
discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow
BOD, 5-Day, 200C
Total Suspended Residue
NH3 as N
Dissolved Oxygen**
Fecal Coliform (geometric mean)
Total Residual Chlorine
Oil and Grease
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Discharge Limitations
Monthly, Avg. Weekly Avg. Daily Max.
0.300 MGD
15.0 mg/I 22.5 mg/l
30.0 mg/I 45.0 mg/I
4.0 mg/I
200 /100 ml 400 /100 ml
28.0 µg/I
30.0 mg/I 60.0 mg/I
Monitorinq Requirements
Measurement
Sample
Sam I—e
Frequency
TYRO
Location*
Continuous
Recording
I or E
Weekly
Composite
E
Weekly
Composite
E
Weekly
Composite
E
Weekly
Grab
E
Weekly
Grab
E
2/week
Grab
E
Weekly
Grab
E
Weekly
Grab
E
Quarterly
Composite
E
Quarterly
Composite
E
* Sample locations: E - Effluent, I - Influent.
** The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored weekly at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Health
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Linda C. Sewall, Director
A4
E5 FEE HNFR
October. 23, 1996
MEMORANDUM TO: David Goodrich
NPDES Permits Group Leader
Discharge Permits Unit
Division of Environmental Management
FROM: Linda C. Sewall, Director
Division of Environmental Health
SUBJECT: Draft National Pollutant Discharge
Elimination System Permit
Knotts Landing Development
NCSR 1197
Permit No. NCO074900
-Gatrawba County
Sr ecWl
Reference is made to the above mentioned Draft National
Pollutant Discharge Elimination System Permit. We have reviewed
this permit application and determined that the proposed discharge
will not be sufficiently close to any existing or known proposed
public water supply intake so as to create an adverse effect on
water quality.
We concur with the issuance of this permit provided the
facility is operated and maintained properly, the stated effluent
limits are met prior to discharge and the discharge does not
contravene the designated water quality standards.
If we can be of further assistance, please contact us.
LCS/EDH/pl
P.O. Box 27687, N
SAFAX 919-715-3242
Raleigh, North Carolina 27611-7687 An Equal Opportunity/Affirmative Action Employer
Voice 919-733-2870 50% recycled/ 100% post -consumer paper
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PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
POST OFFICE. BOX 29535
RALEIGH, NORTH CAROLINA 27626-0535
NOTIFICATION OF INTENT TO ISSUE A STATE NPDES PERMIT
On the basis of thorough staff review and application of Article 21 of Chapter 143, General Statutes of
North Carolina, Public Law 92-500 and other lawful standards and regulations, the North Carolina
Environmental Management Commission proposes to issue a permit to discharge to the persons listed
below effective 12/9/96 and subject to special conditions.
Persons wishing to comment upon or object to the proposed determinations are invited to submit same in
writing to the above address no later than 11/22/96. All comments received prior to that date will be
considered in the formulation of final determinations regarding the proposed permit. A public meeting may
be held where the Director of the Division of Environmental Management finds a significant degree of
public interest in a proposed permit.
A copy of the draft permit is available by writing or calling the Division of Environmental Management,
P.O. Box 29535, Raleigh, North Carolina 27626-0535, (919) 733-7015.
The application and other information may be inspected at these locations during normal office hours.
Copies of the information on file are available upon request and payment of the costs of reproduction.
All such comments or requests regarding a proposed permit should make reference to the NPDES permit
number listed below.
4
Dam
OCT 1 8 1996
A. Preston Howard Jr., P.E., Director
Division of Environmental Management
Public notice of intent to issue a State NPDES permit to the following:
1. NPDES No. NC0074900. Mid South Water Systems, Inc., PO Box 127, Sherrills Ford, NC 28673
has applied for a permit modification for a facility located at the Knotts Landing Development, SR 1197
(Oak Tree Road), Ireoell County. The permit currently allows the discharge of 0.041 MGD of treated
domestic wastewat& from one outfall into McCrary Creek (Lake Norman ), Class WS-N, B CA waters in
the Catawba River Basin. The permit modification allows for a flow increase to 0.300 MGD and location
of the discharge point in the Catawba River (Lake Norman) Class WS-IV, B CA waters in the Catawba
River Basin. BOD, ammonia, dissolved oxygen, and total residual chlorine are water quality limited. For
some parameters, the available load capacity of the immediate receiving waters will be consumed This
may affect fu water quality based effluent limitations for additional dischargers within this portion of
her)AGe� 'I;r GOfram+ GvuniI
P
NEcb Pv6. t0onCC Fok
196DCLL, COONTY
10-23_9L Pa�11r �{'laR
PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
POST OFFICE BOX 29535
RAIEIGH, N.C. 27626-0535
NOTIFICATION OF INTENT
TO ISSUE A STATE NPDES PERMIT
On the basis of thorough staff review
and application of Article 21 of Chapter
143. General Statutes of Noah
Carolina, Public Law 92-500 and other
I avd.l s19.d.rds and .egvlmions, the
Noah Carolina Environmental Manage-
ment Cammission proposes to issue o
Permit la discharge 10 the persons listed
below effective 1112SM6 and subject to
special conditions.
Persons wishing to comment upon or
object to the proposes determinations
are invited to submit some in wriling ro
the above address no later than
1118,96. All comments received prior to
that dole will be considered in the for
mulelip" of final determinations regard-
in,Jhe proposed Portal. A public aI
Ing may be held where the Director of
the Division of Environmental Manage-
ment finds a significant degree of public
interest in a proposed permit.
A copy of the draft permit is available
by writing or calling the Division of En-
vm.moomcl Manogem.nb P.O. Box
29535, Raleigh. Noah Carolina
27626.0535,(919)733-7015.
The application and .,her information
may, be inspected at these locations
daring normal office hours. Copies of
1pn ha immani a file or. available
^on raq ea and ppymenl of the casts
of reproduction, All such co ems or,
requests regarding a proposed permit
should make reference to the NPDES
permit number listed below.
Dote: October 2, 1996.
A. Preston Howard Jr., P.E., Director
Division of Environmental Management
Public nasice of intent to Issue a State
NPDES permit to she following:
1. NPDES No. NCINJ74900. Mid South
Water Systems. Inc., PO an. 127,
Sfierrills Ford, NC 28673 has applied
forts permit renewal for a facility to.
rated a1 the Knolls Landing Develop-
mmal, SR 11097 (Oak Tree Rood), Ca-
lawba County. The facility is cu erT
permitted to discharge 0.041 MOD of
anmed domestic wastewater From ane
omfoll into McCrary Crank hake
Normanl, a Class WS-IV, B CA sueom in
the Cmawbo River Basin. This permit
modiiicafon allows for a flow inaeasa
m 0.30 MGD with the discharge point in
the Cmowba River (Lake Normanl.
Ammonia. BOD5, d,solved oxygen and
total residual chlorine are water quality
limited. For some parameters the ova
able load rapacity of the immedmle to -
canting water will be consumed This
may aH., future water quality based
effluent limitations for additional
dischargers within this portion of the
wmanhed.
PUBLISH: OCTOBER 9, 1906,
GtJ
16152
NORTH CAROLINA
CATAWBA COUNTY
being first duly sworn, says: That he or
she is of the
Recorda
Hickory Daily , newspaper pub-
lished at Hickory, North Carolina; that in
the issues of the said newspaper for the
following days, to wit:
0,.. 9..9s...........
there appeared 9 %` spaced
lines of advertising as per attached named
advertiser:
The Hickory Daily Record is a qualified news -
Paper within the meaning of section I-597 of the
General Statutes of N. C. t
AM ant
Sworn to and subscribed before me,
this Fourteenth day of
October 19 96
Notary Public
My Commission Expires
December 0.9, 19 9,9,
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i. Figure 1 IV
General Location Map-Knotts Landing1,\� / I I
.11 USGS Quad Map "Lake Norman North' oa< li / `
1 inch = 2000 feet824
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" ' .��1 n (j I '. `. •' � i I �-\ `1 �dsn " � `.. -.. . �t 1, h5y \ llr I \\ 0
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Lot '
29
Thomas S. Tilson
i
Lot I
28
6
65 ;24 eX
315 Bg
Fovnd
Lot
27
Lot
3.51 Acres
26
(Area by C°°rdlnele melAed)
;7
b
1
Found
i' P/Pe
1
589 S!'00"E 294.96' Found
1 • Pie
Ctf
Q
ti
Martha L. Shelton
970/9"
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APPIE'
N: 679.237.412
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L
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and Rescue As
815/8
576 0
Rebor
Found
Figure 2
WWTP Site
Scale Location Map-Knotts Landing
Found
Ng9 �01io et l • Pia
State of North Carolina
Department of Environment,
Health and Natural Resources A14
. 0
Division of Water Quality r
1
James B. Hunt, Jr., Governor k �t
Jonathan B. Howes, Secretary p E H N F4
A. Preston Howard, Jr., P.E., Director
Mr. Gerald Horton
Triangle Environmental, Inc.
P.O. Box 41087
Raleigh, North Carolina 27629
August 12, 1996
Subject: Permit Modification - Add. Info.
NPDES Permit NCO074900
Mid South Water Systems, Inc.
Knotts Landing
Iredell County
Dear Mr. Horton:
Having reviewed your letter of July 30, 1996 I have determined that additional documentation of non -
discharge alternatives is necessary. Although non -discharge alternatives were examined to some
degree in 1994, that level of evaluation is not sufficient to move forward with this permit modification.
Furthermore, the treatment plant site and proposed development location have changed making
information from previous evaluations irrelevant without additional documentation.
While you are correct in stating that a valid permit exists, the 0.041 MGD flow is still considered
"new" as defined in 15A NCAC 2H .0103(14), therefore the requirements in 15A NCAC 2H
.0105(c)(2) to examine disposal alternatives for the entire flow must be satisfied. Although future
service areas may not currently be known, non -discharge alternatives for the 0.30 MGD flow must be
evaluated prior to permit modification.
At a minimum, a comparison of costs for discharge and non -discharge alternatives must be submitted.
The analysis performed in 1994 was especially deficient in this area. When determining appropriate
land application rates, in lieu of a new soils analysis, substitute documentation shall be provided
justifying soil characteristics (i.e., average values from soil tests on residential systems nearby or a
conservative figure provided by the County). Land costs should be appropriate for the area being
evaluated. The Division is aware that land costs are significant surrounding Lake Norman.
The requested information should be provided no later than September 16,1996, or the application
package will be returned as incomplete. If you have any questions regarding this application, please
contact me at 919-733-5083, ext. 541.
Sincerely,
7A_Q� til-
Greg Nizich, Environmental Engineer
NPDES Permits Group
cc: Mooresville Regional Office, Water Quality Section
Mr. Kim Colson, Mid South Water Systems, Inc., P.O. Box 127, Sherrills Ford, NC 28673
Permit File
P.O. Box 29535, Raleigh, North Carolina 27626-0535 . Telephone 919-733-5083 FAX 919-733-0719
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper
Suite 6l l The First Union Building
200 First Avenue, N.W.
III Hickory, North Carolina 28601 111E
Samuel H. Long THE
ONG
Certified Mediator Please Reply To:
P. O. Drawer 1310
L
LAW
AttorneyCounsellor At Law Hickory, North Carolina 28603-I310
FIRM
Telephone: 704/322-4033
Fax: 704/322,7110
July 26, 1996
Mr. Greg Nizich
for David A. Goodrich, Supervisor
NPDES Permits Group
Post Office Box 29536
u,
Raleigh, North Carolina 27626-0535
'J
RE: Permit Modification - Additional Information
Request
NPDES Permit NCO074900
Knotts Landing
Iredell County
NOTE: PLEASE TREAT THIS LETTER AS CONTAINING
ry �
PRIVILEGED BUSINESS PROPRIETARY INFORMATION
Dear Mr. Nizich:
I represent Mid South Water Systems, the permit holder in the
above matter. Kim Colson of Mid South has asked me to respond to
that portion of your letter of June 19, 1996 requesting information
as to why it is not feasible to consolidate discharges for this
permit with discharges under permit number NCO074535 pursuant to
which Mid South's Pier 16 WWTP discharges treated effluent into
Lake Norman.
There are several reasons why this is not a viable option.
1. The short answer to that question is that control and use
of the "Pier 1611 permit as well as control of the Pier 16 waste
water treatment plant (an 18,500 g/p/d plant) is involved in an
adversary proceeding in Federal Bankruptcy Court, Western District
of North Carolina. That litigation has been pending since 1993
and, unfortunately, is not close to being resolved. That lawsuit
involves multiple claims by two of the three parties (one of which
is bankrupt) which originally funded construction of the WWTP over
who controls the capacity of the WWTP and, thus, use of the
underlying discharge permit.
2. As to the Pier 16 plant itself, it is
plant, the current design capacity of which is
although there is actual capacity still unused.
located at the edge of the parking lot which
restaurants and the
There is literally
existing WWTP and
plant does not make
for Mid South or th
e
other commercial facilities at
no room for any significant e
even if there were room, the
expansion a viable business alt
businesses at,Pier 16 Marina.
an 18,500 g/p/d
fully allocated
The plant is
serves two (2)
Pier 16 marina.
xpansion of the
location of the
ernative either
Mr. Greg Nizich
for David A. Goodrich, Supervisor
July 26, 1996
Page 2
3. Two of the existing customers of the Pier 16 WWTP
(proposed both of the off -site customers) will be shifted to the
new facility when it goes on-line. At that point the only
customers of the Pier 16 WWTP will be the commercial business at
the Pier 16 Marina.
4. Moreover, the effluent line from the Pier 16 WWTP to Lake
Norman is located under the Pier 16 Marina parking lot and beside
two (2) of the Pier 16 commercial businesses. While acceptable
for the existing small Pier 16 WWTP which serves largely the Pier
16 Marina and its tenant, such a location for the effluent
discharge line for a large WWTP which would have to be located off
the Pier 16 site is not ideal either for Mid South or the Pier 16
tenants who face major disruption of their operations if major
repairs or maintenance ever has to be done on the line.
5. Because of information which has become public locally,
particularly within the developer community, regarding the disputes
and litigation over the Pier 16 WWTP and discharge permit, local
real estate developers are reluctant to rely upon obtaining service
from that facility. Moreover, it is clear that given the demand
for service which Mid South believes to exist for the proposed new
WWTP, there is no way that the demand could be met under the Pier
16 permit with -its 40,000 g/p/d maximum.
6. The North Carolina Utilities Commission franchise which
has been issued for the Pier 16 WWTP includes the Big Daddy's
restaurant complex and the Catawba Queen location as the only
franchised service areas other than the Pier 16 Marina itself . Mid
South will seek to transfer those "of f-site"customers and thus
service areas from the Pier franchise. The new franchise area will
extend from the Catawba Queen (now Queens Landing) complex area
east on both sides of N.C. Highway 150 past the Big Daddy's complex
at least to property owned by BV Belk and Associates which is
scheduled for residential development at an early date.
Accordingly, it is considered unlikely that the Pier 16 WWTP will
experience any significant increase in usage in the foreseeable
future. If anything, the likelihood is that discharge pursuant to
that permit will diminish.
P
Mr. Greg Nizich
for David A. Goodrich, Supervisor
July 26, 1996
Page 3 '
For all the above reasons, attempting at this time to
consolidate the Pier 16 facility and permit with the subject permit
is (1) not a viable legal alternative given the pending litigation
and (2) not a practical alternative given the location of the
existing facilities.
I trust that this adequately responds to your question. If I
can provide further information please do not hesitate to contact
me.
Thank you for your attention to this matter.
SHL/ j lw
Si
S�
cc: Mr. Carroll Weber
Mr. Kim Colson
Mid South Water Systems, Inc.
r
TiNwc,�
ENI/IRONMEMAL
INC.
P.O Box 41087
Raleigh, NC 27629
919-876-5115
800-849-5115
FAX 919-790-8273
September 13, 1996
Mr. David A. Goodrich, Supervisor
� W
NPDES Permits Group s CP 16 S6
North Carolina Division of Environmental Management
Post Office Box 29535 Copy �� G
Raleigh, North Carolina 27626-0535
Reference: Response to DEM Review Letter of August 12, 1996
NPDES Permit Application for
Mid South Water Systems, Inc.; Knotts Landing
Triangle Project No. 628-0119
Dear Mr. Goodrich:
Mid South Water Systems, Inc. is a utility company regulated by the North Carolina
Utility Commission. As such a utility, Mid South's principle business is serving
residents and developers needing water and/or sewer services. Mid South is familiar with
operations of discharging wastewater treatment plants in that they have five certified
operators and own/operate 17 permitted discharging wastewater treatment systems.
On behalf of Mid South Water Systems, Inc., Triangle Environmental, Inc. (Triangle) is
responding to comments received from you dated August 12, 1996. We understand the
issues raised by that letter to be:
1. The soils evaluation performed in 1994 is not sufficient in light of the increase in
flow sought to be permitted.
2. The flow is considered "new" and thus examination of disposal alternatives must
be satisfied and non -discharge alternatives must be considered for the 0.30 MGD
flow before the permit will be modified.
3. Costs for discharge and non -discharge alternatives must be considered utilizing
appropriate land costs, construction costs, and land irrigation rates.
Triangle has considered reasonable scenarios for three non -discharge and discharge
options and prepared cost estimates for each. To provide data to evaluate costs for the
alternatives, we obtained the soils report for Iredell County, spoke to the sanitarian,
gathered information from contractors and suppliers on wastewater treatment plants
(WWTPs), and sought listings from agents for land for sale in the area. In addition, we
reviewed a report prepared in May 1995 for a tract of land to support a wastewater land
MIDSOMASECONDASP
Mr. Dave Goodrich, Supervisor
NPDES Permits Group, DEM
September 13, 1996
Page 2
application system. That report, which we refer you to in the DEM files, was in support
of Morrison Cove Phase 1 in Iredell County, which your office permitted. According to
that report and the Iredell County soils report our site and the Morrison site have nearly
identical soils and soil conditions; that is, Cecil sandy loams and topography. The
Morrison project is located only one mile southeast of the Knotts Landing project.
The Cecil soils common to both sites are good absorptive soils for use with septic tanks
as well as for land application of wastewater. The report stated that the Cecil soils had
adequate capacity for a drip system application of 0.98 inches per week providing a
minimum wet weather storage of 30 days.
The three scenarios of wastewater treatment and disposal systems considered for costing
are as follows:
1. Constructing a drip land application (non -discharging) system, applying 300,000
gallons per day (GPD). The system, based upon data from the two soils reports,
would require:
• pump station near the apartments and a force main to the treatment site
• standby power
• a modified package secondary treatment plant
• approximately 77 acres of good land for drip irrigation
• a pumping station on site to the line/field
• a storage lagoon for 30 days wet weather detention of approximately seven
acres
• approximately 310,000 lineal feet of dripper line/field
• several ground water monitoring wells
2. Providing individual septic tanks for the proposed apartments, for each existing
restaurant, and for all future growth to reach a total waste generation rate
approximately equal to the 300,000 GPD applied for. Minimum lot size in the
area for residences requiring septic tanks is 20,000 square feet.. For community
systems such as for an apartment complex or restaurants, large subsurface
disposal systems would be required.
3. Discharging to a package wastewater treatment plant at the quarry site near NC
150 consisting of the following major components:
• pump station near the apartments and force main to the treatment site
• equalization basin
• dual aeration basins
• dual clarifiers
MOSOUTMECOND.RSP
Mr. Dave Goodrich, Supervisor
NPDES Permits Group, DEM
' September 13, 1996
Page 3
• dual filters
• aerobic digester
• disinfection and dechlorination
• standby power
• pump station and effluent force main to Lake Norman
The apartments for which the developers requested sewer service are to be located nearby
and partly on old overburden from an abandoned quarry. The property surrounding the
proposed apartment site is already developed or is unsuitable. Unsuitable areas adjacent
to the proposed treatment plant site include the old quarry pit. That area has been
significantly disturbed in the past due to the quarry operations. We reiterate that staff
from the Mooresville Regional DEM Office visited the site and can confirm these
conditions. Also DEM should consider that the property along NC 150 is presently
undeveloped due to lack of sewer availability demonstrating that there is demand for the
service, which also justifies Mid South's desire to seek 300,000 GPD capacity.
From the three scenarios presented above it can be seen in the attached calculations and
spreadsheet estimates that the three alternatives have estimated costs as follows:
1. Drip land application
$ 29,077,000
2. Individual septic tanks $ 12528,000
3. Package wastewater treatment plant $ 954,000
The attached figure indicates the location of the systems and the areas of service. Land
costs are one of the principle factors in the area which is clearly demonstrated by the
spreadsheets. A contingency was allowed under each scenario that is somewhat
proportional to the unknowns. The land application system is perhaps the riskiest as the
most assumptions were made. Particularly the assumption on availability of contiguous
reasonably close suitable lands may be invalid.
For the Septic Tank Option the following points are made:
1. There are other costs associated with the Septic Tanks Option that are difficult to
quantify, such as lost revenues for acreage lost to development as well as there
would be losses in usable land because certain lots or a percentage of the lands
would not be usable for septic tanks.
MIDSOUMSECONDASP
Mr. Dave Goodrich, Supervisor
NPDES Permits Group, DEM
September 13, 1996
Page 4
2. Each of the several development options (demands) such as apartments,
commercial, restaurants (existing, proposed, and speculative), and single-family
residences may not be able to rely on a septic tank or Low Pressure Pipe (LPP)
system as the solution due to the unavailability of lands.
Triangle has estimated the costs for each of the three alternatives but wishes to make or
reiterate the following points:
Evaluating costs for septic tanks, land application systems or any other systems,
regardless of the results, will not direct developers or utility operators to make
decisions based on such results. That is to say if the WWTP option makes good
sense to these parties and is permittable, then the projects will proceed.
2. Rescinding an option (denying an NPDES permit) could and likely will kill the
prospect for the environs being serviced by a sewer utility company.
Triangle, as a technical consultant, feels it would be preferable from a water
quality standpoint to have a regulated and competent utility company operate one
or two wastewater treatment systems, than to have numerous individual systems
operating that would have to be managed and maintained by numerous owners.
4. Land application is clearly an alternative that is not economically viable to Mid
South. It is difficult to imagine that any entity would embark upon such a
solution where the economics are so disadvantageous.
On behalf of Mid South, we respectfully request issuance of Public Notice and
proceeding to the next step in issuance of an NPDES Permit for the 0.30 MGD capacity
sought. If you have any questions please do not hesitate in contacting us at 876-5115.
Sincerely,
TRIANGLE ENVIRONMENTAL, INC.
Gerald W. Horton, P.E.
Senior Project Manager
/ra
Enclosure
xc: Mr. Greg Nizich
MIDSOUnMECONDASP
Drip Irrigation System
Cost Estimate
Item Unit Cost
Pump station to Drip system
job
Standby Power for Pump station
job
Force main to Drip system *1
7,000
LF
6.00 /LF
Land for Drip system, storage pond & infrastructure
86.0
Ac
10,000 /Ac *2
4n site pump station
job
Drip system lines *3
310,000
LF
0.30 /LF
Ground water monitoring wells
4
ea
2,200 /ea
WWTP consisting of dual extended air basins, clarifiers, and filters,
300000
g
per gal
1.90
disinfection
,al
capacity
Contingency 25 %
Total for Drip Irrigation System
',1 Assumed site is 7000 ft away tract 13, tax map # 2P. This
assumption in no way infers that this tract is suitable or available,
only that is a tract of suitable size & potentially of suitable soils.
*2 Lots of 20,000 sq ft range up to $12,000 and more. Commercial
land is selling for over $60,000 per acre. Tbus a figure of $10,000
per acre of raw land is reasonable or conservative.
*3 Using 4000 LF per acre similar to the Morrison report.
Estimated Cost
$502000
19,000
42,000
860,000
18,000
93,000
9,000
570,000
416,000
$ 2,077,000
WWTP Costs
Item
Unit Cost
Estimated Cost
Pump station to WWTP
job
$50 000
Standby Power for Pump station
job
19,000
Force main to proposed discharge point in Lake Norman
8,000 LF 6.00
/LF
48,000
Land for Wastewater treatment plant *1
4.0 Ac 0
/Ac
0 '
On site pump station to discharge force main
job
18,000
WWTP consisting of eq. basin, dual extended air basins, clarifiers, and filters,
300,000 gal 2.20
er pgal
660,000
an aerobic digestor, disinfection & dechlorination, and post aeration
capacity
Contingency 20 %
159,000
Total for WWTP with Discharge
$ 954,000
* 1. Note that land is available for implementation of the WWTP with discharge alternative.
Septic Tank Costs
Item
Pump stations to Absorption fields
Residential 1000 gal ST & Field &
land
3000 gal ST & Field
land, assume 3000 sq. ft. ( .07 ac.) for
each 3000 gpd system
30,000 gal Tank, Dosing systems, distribution
lines and pump station
land, assume i.o ac. [or each :JU,000
gpd system, plus equal replacement
Contingency 25 %
Unit Cost Estimated Cost
4
ea. 21,000
/ea.
$84,000
110
ea. 2,200
/ea.
242,000
25
ea. 18,000
/ea.
450,000
1.8
ac. 15,000
/ac
26,300
4
ea. 60,000
/ea.
240,000
12.0 ac. 15,000 /ac 180,000
305,575
Total for Septic Tanks $195289000
Irrigation Acreage Sizing
Knotts Landing WWT Mid South Utilities
Land Use Assumed calculation Acreage
Conditions Needed
at 1 inch per acre
1. Drip Irrigation field needed
per week * 0.3 =.3 MGD X 1 Ac-wk 7 days X / .02715 MG per acres 77.3
MGD
fluctuating depth of
2. - Wet weather detention pond
4 to 8 feet for 30 days X 0.3 MGD / 1.3 MG per acre = 6.9 - -
storage,
gravel, 16 ft width, _
3. Access roadway and facilities
allow 1 acre 1.0
500 lineal feet
Assume land yield
4. Additional land needed for loss
(usable acreage) is
due to poor soils, wetlands, buffers
= 77.3 + 13.8 + 1.0) / 0.75 a 86
75 /o of sum of
etc.
items 1,2, & 3
* 1 inch onto one acre
= 27,150 gallons
'.. >
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POSSIBLE LAND',.
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SPECTULATIV
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PROPOSED
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,9
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SCALEi'1 -2000'
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11/12/96 09:13 '0919 790 8273 TRIANGLE ENV.INC
Q 001
AIANGLE
ENVIRONMENTAL
Triangle Environmental,Inc.INC.
Boa 41087 2725 MBlbrodk Rd.
R,sleighw NC 27629 Raleigh] NC 27604
Fax Craver Sheet Number of ices indaWmg *over sheeh
DATE: November 12, 1996
TO:
FROM:
David A. Goodrich SUpv.
Gerald W., Horton
Triangle Environmental Inc.
9 : 733-5
PAX: 733-0719
9 919 87"115
FAX: 919 730-0273
REFERENCE: Draft NPDSS Permit
It is our understanding that DEHSNR intends to issue Permit NC 007490o to Mid S25outh Water Systems, Inc. on November ,
1996_
We have reviewed the draft permit and make the following comments. Please acknowledge that you received our comments.
1, The cover of the Permit errantly indicates that Knotts
Landing is in Catawba County. Ttils should read Iredeli
County.
2. We question why the permit will be issued to expire �----
June 30, 2000 instead of being issued for 5 years ?
Xr .AA n-f t-L� G �c1 VL--
S;1 pMWECT 1 mIpSOM 1 DEM-1 . FAX
fax transmittal is rivilcgcd and cmfidentK and is
Conti ntiali 0&16 The infol=tion contained m t6is F
intended fort addr+s only. Any disclvanc of this inf6rMAtion in any way or %ing of any action robing on
this khrmndOn is strictly probibited. If you have received this fax in crrM Please notify the pmm SeadinB the
icatien accordingly.
The requested information should be provided no later than July 31,1996, or the application package
will be returned as incomplete. If returned, the application can be resubmitted when the additional
information is obtained.
I am, by copy of this letter, requesting that the Mooresville Regional Office Supervisor prepare a staff
report and recommendations regarding this discharge. If you have any questions regarding this
application, please contact Mr. Greg Nizich at 919-733-5083, ext. 541.
Sincerely,
,�t avid'A. G'Iodrich, Supervisor
NPDES Permits Group
enclosure
cc: Mooresville Regional Office, Water Quality Section
Mr. Gerald Horton, Triangle Environmental, Inc., P.O. Box 41087, Raleigh, NC 27629
Permit File
Jl�.,� 23-96 TUE 1 3 : 43 MID SOUTH
• a. '
P03
PAGE 0?
Ty� TELEPMONE
oWn oYooreoille(704) 663.3800
~•••' Pos'r Orr= Box 978
NORTH C g A G L 1 !Y A MOORfSV%LC. NORTH CAROWNA 26113
July 1210 1996
Mid South Water Systems, Inc.
P.C. Box 127
Sher & Ford, North Carolina 28673
Attn: Mr. Kh Colson, P.E.
Re: Sewer Availability
NC 1 50 west Are$
DQ,Ar W. Colson:
V.In response to your letter dated July 2, 1996 concerWng sewer availabilityin the NC i 50
'Ust area, it is my opinion that the 'town of MooresviU h" no immediate or nu-
09vido sewer service to the area ind}cated on your ma►'' .Obvious term plans to
�'equest that would be mutually beaeflcia} to the T P �Y� if the Town received a
up t� tbo Town Board to decide if that service is owed the interested party, then it would be
W now have any plans to serve NC 150 something they wanted to pursue. But we do
future.
West with sewer service iuny time in the h ncdiate
Should you have any questions, do not hesitate to contact me at 704/662-8472.
Sincerely,
H. Carson Fisher, RE,
Town Engineer
cc: Mr. Rick McLean, Town Manager
Mt. Yoe DeBruhl, P.E., Willis Engineers
Mr. Glenn ShuIer, Utilities Director
JLA- -' 23-96 TUE 1 S : 43 MID SOUTH
t•
P . 04
IREDELL COUNTY
DEPARTMENT OF PLANNING & ENFORCEMENT
PO BOX 788 227 SOUTH CENTER ST.
STATESVflXE, NC 28687
LYNN S. NIBLOCK, DIRECTOR
PHONE: 704-878-3113
FAX: 704-878-3171
8,1996
Mr. Kim H. Colson, P.E.
Mid South Water Systems Inc.
PO ,Box 127
Sherrills Eord, NC 28673
Up: Response to your letter dated 7-2-96 to Mr. Joel Mashburn, County Manager
t cerning the availability if a sewer along Hwy.150 West.
Dear Mr. Colson:
fam writing you.at Mr. Mashburns request in response to your letter. Iredell County does
nut'bave any sewer system in any part of the County, including the area in question on
Hwy.11.50 W from the Doolie Community to the Catawba River Bridge. Prior to our office
1�SUing a building permit we must have verification that there is either an approved sewer
system or that the lot is suitable for a septic tank system. I hope this addresses your
question. Please let me know if I can be of additional assistance.
Sincerely;
Iayan S., Niblock
bisector of Planning & Enforcement
ci:: Mr. Joel Mashburn
Rr�)103
r )'
J
MAY 7 1996 P.O. Bar41087
TRIANGLE Raleigh, NC27629
919-876-5/15
NVIRONMENTAL DIV OF ENVIRONMENTAL MGT 800-849-51I5
INC. DIRECTOR'S OFFICE FAX919-790-8273
May 3, 1996
Mr. Preston Howard, PE, Director
ATTENTIONTermits Unit
Division of Environmental Management
PO Box 29535
Raleigh, NC 27626-0535
Reference: NPDES Permit Application for
Mid South Water Systems, Inc., Knotts Landing
Triangle Environmental, Inc. Project No. 628-0119
Dear Mr. Howard:
�D
On behalf of Mid South Water Systems, Inc., we are seeking NPDES Permit for discharge of
treated wastewater from the proposed location of a proposed wastewater treatment plant in t
Iredell County on Lake Norman. j
Enclosed please find included herewith the following:
1. NPDES Permit Short Form D Application, one original.
2. Check No. 24140 in the amount of $400.00 for permit application fee
3. Required report entitled "engineering proposal" in triplicate with information required
per 15A NCAC 2H.0100, Sect..0105 (c),
4. A general location map, three copies,
5. A Scale location map showing site, three copies.
An NPDES permit application had been previously submitted with number NC 0074900
issued on June 30, 1995. The present application will be for a facility in lieu of that facility.
The differences will be:
1. Seeking 0.3 MGD ultimate capacity instead of 0.041 MGD (Permitted) and
2. Proposed locations of: a) the discharge point and b) the wastewater treatment plant.
Should you have any questions please contact me at 876-5115.
Sincerely,
TRIANGLE ENVIRONMENTAL, INC.
Gerald W. Horton, PE
Senior Project Manager
s
N
rn
Engineering (Report) Proposal
Application for NPDES Permit
Mid South Water Systems, Inc.,
for
Knotts Landing, Iredell County, NC
by
Triangle Environmental, Inc.
April 1996
Mid South Water Systems, Inc.
Knotts Landing, 'Iredell County, NC
The North Carolina water pollution laws governing discharge of wastewaters requires that a
discharger or one proposing a discharge obtain a National Pollutant Discharge Elimination
System (NPDES) Permit in accordance with requirements contained in North Carolina
regulation 15A NCAC 211.0100. That regulation which governs discharges of
wastewater to surface waters.
That regulation stipulates that anyone proposing a discharge submit an "Engineering
Proposal" in accordance with section .0105 (c). This report addresses those requirements
which are:
1. Description of wastewater,
2. Summary of wastewater treatment options,
3. Narrative description of the proposed treatment works,
4. General location map and
5. Scale location map of wastewater treatment plant site.
Section 15A NCAC 2H.0100, Sect..0105 (c)-W - Description of origin, type and flow of
waste which is proposed to be discharged.
The origin of wastewaters to the Phase 1 proposed wastewater treatment plant will be from:
existing and proposed restaurants in the area, single family residentiaLi4nits at Knotts
Landing subdivision, and approximately 100 proposed apartmentk,N he Phase 1 flow is
estimated to be Urn MGD. The wastewater type will be domestic/sanitary wastewater
typical of that expected from the types of users described, that is, residential and restaurants.
Development pressure is high in this area and thus a Phase 2 is anticipated and applied for.
The ultimate capacity sought under this permit application is for a flow of 0.3 MGD.
Section 15A NCAC 2H.0100, Sect..0105 (c) 2 - Summary of waste treatment and
disposal options.
Reports were prepared addressing alternatives for wastewater disposal when application was
made in 1994 for an NPDES permit. That permit was subsequently issued. None of the
issues affecting alternatives or needs when the NPDES permit application was sought in
1994 have changed since the preparation of those reports. The reader is referred to those
reports:
1. Letter engineering proposal prepared by B.K. Barringer & Assocs. P.A., dated June
6, 1994. Briefly, that report addressed use of septic tanks, drip irrigation systems,
municipal utility availability and cited each as impractical for economic or
inadequacy reasons.
Incidentally, letters from the Town of Mooresville and from Iredell County
governments stipulated that neither has plans to sewer the area.
2. Letter report on soil evaluation prepared by registered soil scientist Dennis J.
Osborne, Ph.D. Date of report was May 20, 1994.
The primary finding of the soils evaluation was that the use of septic tanks would be
prohibitive because of the adverse effect on density of development as well as the
inadequacy of soils in portions of the development area, that is, the soils ability to
support the proper performance of septic tank systems.
Section 15A NCAC 2H.0100, Sect. .0105 (c) (4- Narrative description of the proposed
treatment works.
The limits issued under permit NC0074900 suggest that secondary treatment with effluent
disinfection via chlorination/dechlorination will be necessary.
Initially, for the first 0.10 MGD of capacity proposed for Phase One the following treatment
units and operations are proposed:
Flow equalization, influent screening, parallel 50,000 gpd extended aeration units,
tertiary filters, chlorination/dechlorination facilities, discharge pipe into the main
channel and standby power generation
Section 15A NCAC 2H.0100, Sect..0105 (c) (4 -- General location map.
Location map is attached, Figure 1, showing proposed plant and discharge point.
Section 15A NCAC 2H.0100, Sect. .0105 (c) 5)--- Scale location plan.
Property plat is attached, Figure 2, showing general area where plant will be located.
Section 15A NCAC 2H.0100, Sect..0105 (c) ) -- Statement to demonstrate financial
qualification and substantial previous compliance.
Mid South Water Systems, Inc. is a utility in North Carolina regulated by the State Utility
Commission. The company has been in business since 1978. Mid South has over 8,000
water customers and over 1,500 sewer customers. Mid South is presently operating in three
states, the other two being South Carolina and Virginia. =
ANGLE
.AMRONMENTAL
INC.
July 30, 1996
Mr. David A. Goodrich, Supervisor
NPDES Permits Group
North Carolina Division of Environmental Management
Post Office Box 29535
Raleigh, North Carolina 27626-0535
ATTENTION: Mr. Greg Nizich
Reference: Response to DEM Review
NPDES Permit Application for
Mid South Water Systems, Inc., Knotts Landing
Triangle Project No. 628-0119
Dear Mr. Goodrich:
P.O. Box 41087
Raleigh, NC 27629
919-876-5115
800-849-5115
FAX 919-790-8273
Q-c'd 3-30-I(,
On behalf of Mid South Water Systems, Inc., we are responding to comments received
from you dated June 19,1996.
Our response tracks the comments (repeated herein in italics) of your letter. Each of your
comments is followed by our response.
The following information is needed prior to finalization of this request:
Further evaluation of non -discharge alternadves. Since this request is for a
wastewater flow of 0.30111GD, the evaluation conducted for 0. 041 MGD (permitted
in 1995) is not sufficient. The following points need to be addressed:
RESPONSE
We maintain that all efforts, correspondence, and facts are as valid now when
applying for a 0.30 MGD NPDES Permit as they were when we applied for a 0.041
MGD permit. Non -discharge alternatives were not viable then nor now. Land costs
and development pressures do not afford us the luxury of obtaining land
economically. Further, devoting vast expanses of land to either irrigation or to
septic tanks with lot sizes starting at 40,000 square feet minimum is a very poor
utilization of land and contra to the .principle of highest and best usage (of land).
MMSOUnfMDES-FASP
� c
Mr. Dave Goodrich, Supervisor ,
NPDES Permits Group, DEM
July 3 0, 1996
Page 2
1. Feasibility of consolidating discharges with the Permittee's Pier 16 wastewater
treatment plant (NC 0074535) should be considered since the relocated discharge
point is in close proximity to the Pier 16 outfall location. The required expansion
of the Pier 16 plant should be evaluated under this scenario.
RESPONSE
You will be receiving (have received) a response from Mid South's attorney, Mr.
Sam Long, regarding legal proceedings and matters on consolidating customers.
2. The June 6, 19941etter from B.K Barringer & Associates to Mr. Dave Goodrich
dismissed community -type non -discharge disposal alternatives without sufficient
documentation. This is not acceptable for this expansion. Each option must be
evaluated for soil characteristics, with an economic analysis provided for all
feasible options. Adjacent land (i.e. not under current ownership by the Permittee)
must also be considered when evaluating non -discharge disposal options.
Guidance is enclosed delineating the extent of soils analysis required. Also, the
original evaluation was for a 100-lot subdivision it is not clear from the
information provided if that property has been developed at this time andlor if other
sites are under consideration for sewer service by the proposed facility at this time.
RESPONSE
We should not be required to re-evaluate the existing flow in the permit. We have a
valid permit though we have not built that plant. The existing restaurants have no
alternative since they are currently on Mid South's Pier 16 sewer system, and there
are no provisions for non discharge alternatives for them.
The proposed apartments we have been requested to serve will be located on old
overburden from an abandoned quarry. The property surrounding the proposed
apartment site is already developed or is unsuitable. Unsuitable areas adjacent to
the site include the old quarry pit and the area for the proposed WWTP. That area.
has been significantly disturbed in the past due to the quarry operations. Staff from
the Mooresville Regional DEM Office have visited the site and can confirm these
conditions. Mid South does not believe work by a soil scientist is necessary to
confirm the un-usability of the sites in this case for application of subsurface or non
discharge systems.
Alternatives above 0.100 MGD treatment capacity can not be provided at this time.
The property along NC 150 is presently undeveloped due to lack of sewer
availability. '
MOSOUTHWPDES-F.RSP
r� Mr. Dave Goodrich, Supervisor
NPDES Permits Group, DEM '
July 30,1996 T
Page 3
It appears that the needs analysis is ecbnomics driven. It is emphatically clear that
non -discharge alternatives are not viable. We can conclude this without spending
$10,000 to $15,000 in soils evaluations on an answer we already know. Surely the
State is not requiring us to expend such moneys when the alternatives are not viable
or even workable. Obtaining additional lands for non -discharge alternatives is not
feasible because: 1) we are a private utility company and obtaining lands would
require condemnation proceedings; 2) such proceedings would be costly; 3) it is not
in keeping with good land use principles seeking the highest and best usage of
lands; and 4) it is likely we would not prevail in legal proceedings in seeking such
lands. Also, the option of installing septic tanks is not viable as was demonstrated
and discussed in the report of June 1994. Specifically, several lots would not
sustain such systems and densities required for such development would not be
feasible. Please note we are a utility company, not a developer, so it is not our
decision how to develop lands, nor is it within our control.
3. Up-to-date letters from both Iredell County and the Town of Mooresville must be
provided indicating the present status of available sewer in this vicinity.
RESPONSE
Attached please find up-to-date letters from Iredell County and the Town of
Mooresville. As one can see, neither has intents of servicing the areas that we are
proposing to service with the new WWTP to be located on the south side of NC 150
as indicated by our earlier submittal.
Should you have any questions please contact me at 876-5115.
Sincerely,
T NGLE ENVIRONMENTAL, INS..
Gerald W. Horton, PE
Senior Project Manager
Ira
Enclosures: Letters from Iredell County and Town of Mooresville
MIDSOUTHWPDES-FASP