WQ0003017_Final Permit_19901221

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State of North Carolina:
Department of Environment, Health and Natural Rep
Division of Environmental Management P ,
512 North Salisbury Street • Raleigh, North CarolinaA�i`6.11
James G. Martin, Govemor
William W. Cobey, Jr., Secretary
Mr. Jon B. Sanborn, Administrative Assistant
Health Trust, Incorporated
Post Office Box 139
Supply, North Carolina 28462
Dear Mr. Sanborn:
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December 21, 1990 p EjGJ�,� NCLIj��#
Subject: Permit No. WQ0003017
Health Trust, Incorporated
The Brunswick Hospital
Wastewater Treatment and
Subsurface Disposal System
Brunswick County
This is in response to a letter received October 30, 1990, from Houston and Associates,
P.A. concerning various comments and amendment requests for the subject permit. When the
letter was received by the Pen -nits and Engineering Unit, it was reviewed and copies of the subject
letter were sent to the Wilmington Regional Office and the Groundwater Section for review and
comment. Based on the review and comments of the Wilmington Regional Office, the
Groundwater Section and the Permits and Engineering Unit, some changes in the current subject
permit should be made at this time. However, other requested changes to the subject permit cannot
be made. The following is an item by item response.
Item 1 Condition 1.5. In reference to the word "damages". This is a standard statement
which refers to contravention of water quality or groundwater standards.
Contravention could result in appropriate enforcement action being taken.
Failure to respond to water quality or groundwater violations may result in the
issuance of a penalty assessment under authority of G.S. 143-215.6.
Item 2 Condition I.9. "Green Area" is required for systems in the Coastal Area. Since
the site is drained by Doe Creek which is classified C SW HQW, the Coastal
Regulation does not apply. Designation of a "Repair Area" is required for new
or expanded systems. It is felt that when a new disposal system is installed to
repair a failing system, additional "Repair Area" should not be required. The
existing permit condition has been amended.
Item 3 Condition 1.11. The buffer zones stated in the permit should apply only to the
installation of the repair fields. The existing permit condition has been amended.
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Item 4 Condition I1-8.The treatment plant is connected to the hospital's emergency
power supply generator. This is a sophisticated system with an approved
monitoring system. This should satisfy the requirements of the Division.
Itcm 5 Condition IV.1. Monitoring wells are necessary to assure compliance with 2L
regulations. All waste treatment, storage, and disposal facilities must maintain
and operate a groundwater monitoring system as required by 15A NCAC 2H
.0219 (g).
The monitoring well immediately south of the field to be abandoned, shall be
abandoned according to 15A NCAC 2C ( Well Construction Standards). The
locations of the five (5) new monitoring wells is clearly shown on the map that
was attached to the subject permit. The permit clearly defines the Compliance
Boundary (POC) and the Review Boundary (POR) at the proposed repair fields.
The wells adjacent to existing fields No. 2 and No. 3 shall be moved to the POR
if it cannot be shown that the wells are already at that location or at the POC. The
exact location and construction details for these wells must be approved by the
Wilmington Regional Office.
Item 5 Condition IV.2. The total coliform requirement of 1/100 ml is the Class GA
Standard as set forth in 15A NCAC 2L_ It is not recommended that the standard
level be changed. The "(250.0)" to the right of Water Level" has been deleted
from the existing Permit.
The Division hopes that this response adequately addresses your concerns. Please
review the attached permit and if it is unacceptable to Holly Farms, Inc., you should proceed to file
a formal petition to the Office of Administrative Hearing as directed by the enclosed permit.
If you have any questions on this matter, please call Ms. Carolyn McCaskill or Mr
Seymour at 919/ 733-5083.
(in rely,
George T. Eve ett
cc: Wilmington Regional Office
Groundwater Section
John