Loading...
HomeMy WebLinkAboutWQ0040510_Permit (Issuance)_20190423 coo SrATLF q, ROY COOPER Governor MICHAEL S.REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality April 24, 2019 David Cheek, City Manager City of Mebane 106 E.Washington Street Mebane, NC 27302 Subject: Permit No. WQ0040510 Modification City of Mebane Cambridge Park Sanitary Sewer Improvements Wastewater Collection System Extension Permit Alamance County Dear Mr. Cheek: In accordance with your application received April 18, 2019, we are forwarding herewith Permit No. WQ0040510 Modification dated April 23, 2019, to the City of Mebane (Permittee) for the construction and operation upon certification of the subject wastewater collection system extension. This permit shall be effective from the date of issuance until rescinded, shall void Permit No. WQ0040510 issued December 7, 2018, and shall be subject to the conditions and limitations as specified therein. This cover letter shall be considered a part of this permit and is therefore incorporated therein by reference. This modification to Permit No. WQ0040510 adjusts the originally permitted 3,510 linear feet of 10-inch gravity sewer to 860 linear feet of 16-inch and 2,300 linear feet of 12-inch gravity sewer. It also adjusts the original 6,200 linear feet of 8-inch forcemain to 6,430 linear feet of 10-inch forcemain. Please pay particular attention to the following conditions contained within this permit: Condition 11.1: This permit shall not be automatically transferable; a request must be made and approved. Condition IIA: Requires that the wastewater collection facilities be properly operated and maintained in accordance with 15A NCAC 02T.0403 or any individual system-wide collection system permit issued to the Permittee. Condition 11.7: Upon completion of construction and prior to operation of these permitted facilities,the completed Engineering Certification form with checklist attached to this permit shall be submitted with the required supporting documents to the address provided on the form. Permit modifications are required for any changes resulting in non-compliance with this permit, regulations, or the Minimum Design Criteria. [15A NCAC 02T.0116] N�T��R�ND-EQ> fYpa,hnmlM EnWrenme„bl pu. North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road,Suite 300 1 Winston-Salem,NC 27105 336-776-9800 City of Mebane Permit No.WQ0040510 Modification It shall be responsibility of the Permittee to ensure that the as-constructed project meets the appropriate design criteria and rules. Failure to comply may result in penalties in accordance with North Carolina General Statute §143-215.6A through §143-215.6C, construction of additional or replacement wastewater collection facilities, and/or referral of the North Carolina-licensed Professional Engineer to the licensing board. If any parts, requirements, or limitations contained in this permit are unacceptable,you have the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request must be in the form of a written petition, conforming to Chapter 150B of North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made,this permit shall be final and binding. If you need additional information concerning this matter, please contact Jenny Graznak at (336) 776- 9800 or via e-mail at Jenny.Graznak@ncdenr.gov. Sincerely, EDocuSigned by: L uti T SmAr 945B49E225C94EA... for Linda Culpepper Director, Division of Water Resources by Lon T. Snider,Assistant Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ cc: Mark Lacy, P.E.—LKC Engineering, PLLC (mark@ Ikcengineering.com) Tonya Mann—Utilities Director, City of Graham (tmann@cityofgraham.com) Winston-Salem Regional Office Files Water Resources Central Files PERCS (electronic copy) Page 2 of 8 �OuoNVL� NORTH CAROLINA Environmental Quality WASTEWATER COLLECTION SYSTEM EXTENSION PERMIT In accordance with the provisions of Article 21 of Chapter 143,General Statutes of North Carolina as amended, and other applicable Laws, Rules, and Regulations, permission is hereby granted to the City of Mebane Alamance County for the construction and operation of approximately 860 linear feet of 16-inch gravity sewer and 2,300 linear feet of 12-inch gravity sewer; a 500—gallon per minute pump station with duplex pumps, on-site audible and visual high water alarms, telemetry, and a permanent generator with automatic transfer switch; as well as approximately 6,430 linear feet of 10-inch force main as part of the Cambridge Park Sanitary Sewer Improvements project,and the discharge of"0"gallons per day of collected domestic wastewater into the City of Graham's existing sewerage system, pursuant to the application received April 18, 2018, and in conformity with 15A NCAC 2T; the Division's Gravity Sewer Minimum Design Criteria adopted February 12, 1996 as applicable; the Division's Minimum Design Criteria for the Fast-Track Permitting of Pump Stations and Force Mains adopted June 1, 2000 as applicable; and other supporting data subsequently filed and approved by the Department of Environmental Quality and considered a part of this permit. Permit Modification History: The initial permit, issued December 7, 2018, contained the following project description:for the construction and operation of approximately 3,510 linear feet of 10-inch gravity sewer; a 500—gallon per minute pump station with duplex pumps, on-site audible and visual high water alarms, telemetry, and a permanent generator with automatic transfer switch; as well as approximately 6,200 linear feet of 8-inch force main as part of the Cambridge Park Sanitary Sewer Improvements project,and the discharge of"0"gallons per day of collected domestic wastewater into the City of Grahams existing sewerage system, pursuant to the application received December 4, 2018. Flow for this project will be allocated in a modification to Permit No. WQ0040466, post certification of the subject project. This permit shall be effective from the date of issuance until rescinded and shall be subject to the specified conditions and limitations contained therein. EDocuS�igfned<by: LJti l c.JnJer -4'B49E225C94EA... for Linda Culpepper Director, Division of Water Resources By Authority of The Environmental Management Commission Permit Number: WQ0040510 Modification Permit Issued: April 24,2019 Page 3 of 8 SUPPLEMENT TO PERMIT COVER SHEET City of Mebane is hereby authorized to: Construct,and then operate upon certification the aforementioned wastewater collection extension. The sewage and wastewater collected by this system shall be treated in the City of Graham Wastewater Treatment Facility in accordance with Permit Number NC0021474. Permitting of this project does not constitute an acceptance of any part of the project that does not meet 15A NCAC 02T; the Division's Gravity Sewer Minimum Design Criteria adopted February 12, 1996 as applicable;and the Division's Minimum Design Criteria for the Fast-Track Permitting of Pump Stations and Force Mains adopted June 1, 2000 as applicable, unless specifically mentioned herein. Division approval is based on acceptance of the certification provided by a North Carolina-licensed Professional Engineer in the application. It shall be the Permittee's responsibility to ensure that the as-constructed project meets the appropriate design criteria and rules. Construction and operation is contingent upon compliance with the Standard Conditions and any Special Conditions identified below. I. SPECIAL CONDITIONS 1. This permit shall become voidable unless the agreement between the City of Mebane and the City of Graham for the collection and final treatment of wastewater is in full force and effect. [15A NCAC 02T.0304(g)] 2. No flow in excess of the quantity permitted herein, "0" GPD, shall be made tributary to the subject sewer system until an application for permit modification for an increase in flow has been submitted to and approved by the Division. [15A NCAC 02T.0304(b)] 3. Each pump station shall be clearly and conspicuously posted using a weatherproof sign with a pump station identifying name/number, 24-Hour Emergency telephone number, and name of the owner/operator of the sewer system/pump station and instructions to call the number in the event of alarm activation or other emergency. Simplex pump stations or vacuum sewer pits serving a single- family residence may have a placard or sticker on the control panel in lieu of a sign. [15A NCAC 02T .0305(h)(2)] II. STANDARD CONDITIONS 1. This permit shall not be transferable. In the event there is a desire for the wastewater collection facilities to change ownership, or there is a name change of the Permittee, a formal permit request shall be submitted to the Division accompanied by documentation from the parties involved, and other supporting materials as may be appropriate. The approval of this request shall be considered on its merits and may or may not be approved. [15A NCAC 02T.0116; G.S 143-215.1(d3)] 2. This permit shall become voidable unless the wastewater collection facilities are constructed in accordance with the conditions of this permit; 15A NCAC 02T; the Division's Gravity Sewer Minimum Design Criteria adopted February 12, 1996 as applicable; the Division's Minimum Design Criteria for Page 4 of 8 the Fast-Track Permitting of Pump Stations and Force Mains adopted June 1, 2000 as applicable; and other supporting materials unless specifically mentioned herein. [15A NCAC 02T.0110] 3. This permit shall be effective only with respect to the nature and volume of wastes described in the application and other supporting data. [15A NCAC 02T.0110] 4. The wastewater collection facilities shall be properly maintained and operated at all times. The Permittee shall maintain compliance with an individual system-wide collection system permit for the operation and maintenance of these facilities as required by 15A NCAC 02T .0403. If an individual permit is not required,the following performance criteria shall be met: a. The sewer system shall be effectively maintained and operated at all times to prevent discharge to land or surface waters, and to prevent any contravention of groundwater standards or surface water standards. b. A map of the sewer system shall be developed and shall be actively maintained. c. An operation and maintenance plan including pump station inspection frequency, preventative maintenance schedule, spare parts inventory and overflow response has been developed and implemented. d. Pump stations that are not connected to a telemetry system shall be inspected every day(i.e. 365 days per year). Pump stations that are connected to a telemetry system shall be inspected at least once per week. e. High-priority sewer lines shall be inspected at least once per every six-months and inspections are documented. f. A general observation of the entire sewer system shall be conducted at least once per year. g. Overflows and bypasses shall be reported to the appropriate Division regional office in accordance with 15A NCAC 2B .0506(a), and public notice shall be provided as required by North Carolina General Statute §143-215.1C. h. A Grease Control Program is in place as follows: 1. For public owned collection systems, the Grease Control Program shall include at least biannual distribution of educational materials for both commercial and residential users and the legal means to require grease interceptors at existing establishments. The plan shall also include legal means for inspections of the grease interceptors, enforcement for violators and the legal means to control grease entering the system from other public and private satellite sewer systems. 2. For privately owned collection systems, the Grease Control Program shall include at least bi- annual distribution of grease education materials to users of the collection system by the permittee or its representative. 3. Grease education materials shall be distributed more often than required in Parts (1) and (2) of this Subparagraph if necessary to prevent grease-related sanitary sewer overflows. i. Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility. j. Documentation shall be kept for Subparagraphs(a)through (i)of this Rule for a minimum of three years with exception of the map,which shall be maintained for the life of the system. Page 5 of 8 5. The Permittee shall report by telephone to a water resources staff member at the Winston-Salem Regional Office,telephone number (336) 776-9800, as soon as possible, but in no case more than 24 hours,following the occurrence or first knowledge of the occurrence of either of the following: a. Any process unit failure,due to known or unknown reasons,that renders the facility incapable of adequate wastewater transport, such as mechanical or electrical failures of pumps, line blockage or breakage, etc.; or b. Any SSO and/or spill over 1,000 gallons; or c. Any SSO and/or spill, regardless of volume,that reaches surface water Voice mail messages or faxed information is permissible, but this shall not be considered as the initial verbal report. Overflows and spills occurring outside normal business hours may also be reported to the Division of Emergency Management at telephone number (800) 858-0368 or (919) 733-3300. Persons reporting any of the above occurrences shall file a spill report by completing and submitting Part I of Form CS-SSO (or the most current Division approved form) within five days following first knowledge of the occurrence. This report must outline the actions taken or proposed to be taken to ensure that the problem does not recur. Part 11 of Form CS-SSO(orthe most current Division approved form) can also be completed to show that the SSO was beyond control. [G.S. 143-215.1C(a1)] 6. Construction of the gravity sewers, pump stations, and force mains shall be scheduled so as not to interrupt service by the existing utilities nor result in an overflow or bypass discharge of wastewater to the surface waters of the State. [15A NCAC 02T.0108(b)] 7. Upon completion of construction and prior to operation of these permitted facilities, the completed Engineering Certification form with checklist attached to this permit shall be submitted with the required supporting documents to the address provided on the form. A complete certification is one where the form is fully executed and the supporting documents are provided as applicable. Any wastewater flow made tributary to the wastewater collection system extension prior to completion of this Engineer's Certification shall be considered a violation of the permit and shall subject the Permittee to appropriate enforcement actions. A complete certification is one where the form is fully executed and the supporting documents are provided as applicable. Supporting documentation shall include the following: a. One copy of the project construction record drawings(plan & profile views of sewer lines&force mains) of the wastewater collection system extension. Final record drawings should be clear on the plans or on digital media (CD or DVD disk) and are defined as the design drawings that are marked up or annotated with after construction information and show required buffers, separation distances, material changes, etc. b. One copy of the supporting applicable design calculations including pipe and pump sizing,velocity, pump cycle times, and level control settings, pump station buoyancy, wet well storage, surge protection, detention time in the wet well, and force main, ability to flush low points in force mains with a pump cycle, and downstream sewer capacity analysis. If a portable power source or pump is dedicated to multiple stations, an evaluation of all the pump stations' storage capacities and the rotation schedule of the portable power source or pump, include travel timeframes, shall be provided. Page 6 of 8 c. Changes to the project that do not result in non-compliance with this permit, regulations, or the Minimum Design Criteria should be clearly identified on the record drawings, on the certification in the space provided, or in written summary form. Prior to Certification (Final or Partial): Permit modifications are required for any changes resulting in non-compliance with this permit (including but not limited to pipe length changes of 10% or greater, increased flow, pump station design capacity design increases of 5% or greater, and increases in the number/type of connections), regulations, or the Minimum Design Criteria. Requested modifications or variances to the Minimum Design Criteria will be reviewed on a case-by- case basis and each on its own merit. Please note that variances to the Minimum Design Criteria should be requested and approved during the permitting process prior to construction. After- construction requests are discouraged by the Division and may not be approved, thus requiring replacement or repair prior to certification &activation. [15A NCAC 02T.0116] 8. Gravity sewers installed greater than ten percent below the minimum required slope per the Division's Gravity Sewer Minimum Design Criteria shall not be acceptable and shall not be certified until corrected. If there is an unforeseen obstacle in the field where all viable solutions have been examined, a slope variance can be requested from the Division with firm supporting documentation. This shall be done through a permit modification with fee. Such variance requests will be evaluated on a case-by-case basis.Resolution of such request shall be evident prior to completing and submitting the construction certification. [ 15A NCAC 02T.0105(n)] 9. A copy of the individual permit and construction record drawings shall be maintained on file by the Permittee for the life of the wastewater collection facilities. [15A NCAC 02T.0116] 10. Failure to abide by the conditions and limitations contained in this permit; 15A NCAC 02T; the Division's Gravity Sewer Design Criteria adopted February 12, 1996 as applicable; the Division's Minimum Design Criteria for the Fast-Track Permitting of Pump Station and Force Mains adopted June 1, 2000 as applicable; and other supporting materials may subject the Permittee to an enforcement action by the Division, in accordance with North Carolina General Statutes§143-215.6A through§143- 215.6C, construction of additional or replacement wastewater collection facilities, and/or referral of the North Carolina-licensed Professional Engineer to the licensing board. [15A NCAC 02T.0108(b-c)] 11. In the event that the wastewater collection facilities fail to perform satisfactorily, including the creation of nuisance conditions,the Permittee shall take immediate corrective action, including those as may be required by this Division, such as the construction of additional or replacement facilities. [15A NCAC 02T.0110; 15A NCAC 02T.0108(b)] 12. The issuance of this permit shall not exempt the Permittee from complying with any and all statutes, rules, regulations,or ordinances that may be imposed by the Division any other Federal,State,or Local government agencies which have jurisdiction or obtaining other permits which maybe required by the Division or any other Federal, State, of Local government agencies. [G.S. 143-215.1(b)] Page 7 of 8 CERTIFICATION CHECKLIST To be completed by the certifying engineer prior to operation of the permitted sewers, per 15A NCAC 02T.0116. Certifying Engineer: Certification Review Date: Project Name: WQ00 Project County: 1) Has permittee information changed since the permit was issued (or last modified): change of mailing address, change of ownership,transfer from developer to HOA/POA, etc. ❑ Yes ❑ No • If yes, please provide either a change of ownership form or new contact information. Note that transfer of permits from the developer to the HOA/POA must occur with the first certification. 2) Have the as-built drawings have been signed,sealed,and dated by an N.C. PE? ❑ Yes ❑ No 3) Final Engineering certification? ❑ Yes ❑ No • If Partial Engineering certification, provide detailed narrative including what is being certified in the current phase,what was previously certified (if applicable),and what is left to be certified. 4) Adequate information related to sewer lines: ❑ Yes ❑ No ❑ N/A • Three feet minimum cover has been provided for all sewers unless ferrous pipe was installed. • Minimum diameters for gravity sewers are 8-inches for public lines and 6-inches for private lines. • Manholes have been installed: At the end of each line, at all changes in grade, size, or alignment, at all intersections, and at distances not greater than 425 feet; minimum diameter shall be 4 feet (48-inches). 5) Adequate information related to pump stations: ❑ Yes ❑ No ❑ N/A • Ensure power reliability option was selected per 15A NCAC 02T.0305(h). 6) Was project construction completed in accordance with all of the following: ❑ Yes ❑ No ❑ N/A • 15A NCAC 02T, Minimum Design Criteria (MDC)for the permitting of Gravity Sewers (latest version), and MDC for the Permitting of Pump Stations and Force Mains (latest version)? If not, a variance approval is required in accordance with 15A NCAC 02T.0105(b), prior to certification and operation. • Contact the Central Office to discuss the variance to determine a course of action. • Applicant must submit two copies of the variance request form, plans, specifications, calculations, and any other pertinent information to the Central Office (one hard copy, one digital copy). • The central office will review the variance request, and if approvable, specific language regarding the variance will be incorporated into the permit, either via a special condition or a supplementary letter. A copy of the reissued permit with variance language or the variance letter must be maintained with the original documents. 7) Does the project contains high priority lines(15A NCAC 02T .0402(2))? ❑ Yes ❑ No • If yes,ensure that the permit already contains the necessary condition related to high priority lines 15A NCAC 02T.0403 (a)(5). If the permit does not include this language,the Fast Track reviewer will reissue the permit with the appropriate language. 8) Are Permit modifications are required for any changes resulting in non-compliance with this permit(including but not limited to pipe length changes of 10%or greater,change in flow,pump station design capacity design change of 5%or greater,and/or change in the number/type of connections)? ❑ Yes ❑ No • If yes, a permit modification request must be submitted to the appropriate Regional Office, and a modified permit with revised certification must be issued prior to certification and operation. NC DWR—Water Quality Regional Operations Section 450 West Hanes Mill Road,Suite 300,Winston-Salem, NC 27105 Winston-Salem Regional Office Phone: (336)776-9800 FAX: (336) 776-9798 FAST TRACK SEWER ENGINEERING CERTIFICATION PERMITTEE: City of Mebane PERMIT#: WQ0040510 Modification PROJECT: CAMBRIDGE PARK SANITARY SEWER IMPROVEMENTS ISSUE DATE: April 24, 2019 This project shall not be considered complete nor allowed to operate in accordance with Condition 7 of this permit until the Division has received this Certification and all required supporting documentation. It should be submitted in a manner that documents the Division's receipt. Send the required documentation the Regional Supervisor, Water Quality Regional Operations Section at the address at the bottom. Any wastewater flow made tributary to the wastewater collection system extension prior to completion of this Certification shall be considered a violation of the permit and shall subject the Permittee to appropriate enforcement actions. The Permittee is responsible for tracking all partial certifications up until a final certification is received. A Final Certification shall be a complete set of record drawings and design calculations regardless of whether partials have been submitted. PERMITTEE'S CERTIFICATION I,the undersigned agent for the Permittee, hereby state that this project has been constructed pursuant to the applicable standards & requirements, the Professional Engineer below has provided applicable design/construction information to the Permittee, and the Permittee is prepared to operate & maintain the wastewater collection system permitted herein or portions thereof. Printed Name,Title Signature Date ENGINEERS CERTIFICATION I, as a duly registered Professional Engineer in the State of North Carolina, having been authorized to observe (❑ periodically, ❑ weekly, ❑ full time) the construction of the project name and location as referenced above for the above Permittee hereby state that,to the best of my abilities, due care and diligence was used in the observation of the following construction: of approximately 860 linear feet of 16-inch gravity sewer and 2,300 linear feet of 12-inch gravity sewer; a 500—gallon per minute pump station with duplex pumps, on-site audible and visual high water alarms, telemetry, and a permanent generator with automatic transfer switch; as well as approximately 6,430 linear feet of 10-inch force main as part of the Cambridge Park Sanitary Sewer Improvements project, and the discharge of"0" gallons per day of collected domestic wastewater into the City of Graham's existing sewerage system, pursuant to the application received April 18, 2019; such that the construction was observed to be built within substantial compliance of this permit; 15A NCAC 02T; the Division of Water Resources' (Division) Gravity Sewer Minimum Design Criteria adopted February 12, 1996 as applicable; the Division's Minimum Design Criteria for the Fast-Track Permitting of Pump Stations and Force Mains adopted June 1, 2000 as applicable; and other supporting materials. ................................................: North Carolina Professional Engineer's Seal w/signature & date: ❑ Final ❑ Partial (include description) Certification Comments/Qualifiers (attach if necessary): ...............................................: NC DWR—Water Quality Regional Operations Section 450 West Hanes Mill Road,Suite 300,Winston-Salem, NC 27105 Winston-Salem Regional Office Phone: (336)776-9800 FAX: (336)776-9798 Central Files: APS _ SWP 4/23/2019 Permit Number WQ0040510 Permit Tracking Slip Program Category Status Project Type Non-discharge Active Major modification Permit Type Version Permit Classification Gravity Sewer Extension,Pump Stations,&Pressure Sewer Extensions 1.10 Individual Primary Reviewer Permit Contact Affiliation jennifer.graznak Coastal SWRule Permitted Flow 0 Facility Facility Name Major/Minor Region Cambridge Park Sanitary Sewer Improvements Minor Winston-Salem Location Address County Alamance Facility Contact Affiliation Owner Owner Name Owner Type City of Mebane Government-Municipal Owner Affiliation David S.Cheek city mgr 106 E Washington St Dates/Events Mebane NC 27302 Scheduled Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration 12/7/2018 4/18/2019 4/23/2019 4/23/2019 Regulated Activities Requested/Received Events Subdivision Additional information requested Wastewater collection Additional information received Outfall Waterbody Name Streamindex Number Current Class Subbasin L C April 17, 2019 Ms. Sherri Knight, PE Endito 'en al Ouzilty g Received NCDEQ Winston-Salem Regional Office 450 West Hanes Mill Road, Suite 300 r', i'" e 5 t t i, Winston-Salem, NC 27105 1Ninston-Salem' Re: Permit Modification for WQ0040510 Regional Office Cambridge Park Off-Site Sewer Improvements City of Mebane,Alamance County Fast Track Sewer Extension Application LKC Project No.: Evans-18.01 I Ms. Knight, In regard to the above referenced project, please find the following items: 1. Two copies of the Fast Track Application Package 2. One application fee check for$480.00 3. Flow Tracking Forms 4. USGS and Area Maps 5. Current Permit issued 12/07/18 We are requesting a modification to the above referenced permit to adjust the sewer main diameter and total length. The proposed sewer mains needed to be realigned due to satisfy property owner.In addition, the City of Mebane requested that the size of the proposed mains be increased to allow capacity for potential future development.The pump capacity will remain the same, but the design head was reduced due to the larger forcemain: All tributary flow to the proposed system improvements will be permitted by a modification to Permit No.WQ0040466 as well as future permits for other projects. The modifications requested for the permit description are as follows: • Replace "3,510 linear feet of 10-inch gravity sewer" with "860 linear feet of 16-inch, and 2,300 linear feet of 12-inch gravity sewer" • Replace "6,200 linear feet of 8-inch forcemain"with "6,430linear feet of 10-inch forcemain" If you have any questions, please do not hesitate to contact me at (910) 420-1437 or by email at mark@lkcengineering.com. Sincerely, LKC Engineering, PLLC Mark Lacy, P.E. LKC Engineering,PLLC,140 Aqua Shed Court,Aberdeen,North Carolina 28315 PH:910/420-1437*FAX: 910/420-1438*License No.P-1095 II l; Graznak Jenny From: Mark Lacy <mark@lkcengineering.com> Sent Wednesday, April 24, 2019 9:42 AM To: Graznak, Jenny Subject: RE: [External] RE: Cambridge Park Sanitary Sewer Improvements Modification Attachments: Page 1 of 5.pdf I've attached the edited page showing the correct WWTP and I also corrected the size for the receiving sewer. Let me know if you need anything else. Thanks, Mark From: Graznak,Jenny<jenny.graznak@ncdenr.gov> Sent:Wednesday, April 24, 2019 8:25 AM To: Mark Lacy<m a rk@ Ikce ngi nee ri ng.co m> Subject: RE: [External] RE: Cambridge Park Sanitary Sewer Improvements Modification Can you please send an updated Page 1 of 5 to reflect that?Thank you. Jenny Graznak Environmental Specialist II Winston Salem Regional Office Division of Water Resources 336-776-9695 office 336-403-7388 mobile ienny.graznak@ncdenr.gov 450 W Hanes Mill Road Winston Salem NC 27105 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Subscribe to Collection System & Sewer Permitting Updates From: Mark Lacy<markCcDlkceneineerine.com> Sent:Tuesday,April 23, 2019 4:39 PM To: Graznak,Jenny<iennV eraznak ncdenr.eov> Subject: [External] RE: Cambridge Park Sanitary Sewer Improvements Modification Jenny, 1 The wastewater will be treated by the City of Graham as noted in the permit.The Mebane W WTP was listed in the FTA by mistake. I apologize for the confusion. Thanks, Mark Lacy, P.E. 140 Aqua Shed Court Aberdeen, NC 28315 Phone: 910-420-1437 Cell: 910-639-3811 i From:Graznak,Jenny<jenny.graznak@ncdenr.gov> Sent:Tuesday,April 23, 2019 4:20 PM To: Mark Lacy<mark@Ikceneineerine.com> Subject: Cambridge Park Sanitary Sewer Improvements Modification Hi Mark, Our office received the FTA for the modification of the Cambridge Park Sanitary Sewer Improvements project.The original permit stated that the flow would be going to City of Graham POTW, butthis application states City of Mebane POTW. Which is correct? f Thanks, Jenny Gramak Environmental Specialist II Winston Salem Regional Office Division of Water Resources 336-776-9695 office 336-403-7388 mobile ienny.2raznak@ncdenr.gov 450 W Hanes Mill Road Winston Salem NC 27105 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Subscribe to Collection System & Sewer Permitting Updates 2 i State of North Carolina Department of Environmental Quality Division of Water Resources 15A NCAC 02T.0300—FAST TRACK SEWER SYSTEM EXTENSION APPLICATION FT 04-6&SUPPORTING DOCUMENTATION bF Wader'tRo G W [: e:)m leted b DWR) Application Number: ( P Y All items must be completed or the application will be returned I. APPLICANT INFORMATION: 1. Applicant's name: City of Mebane(company,municipality,HOA,utility,etc.) 2. Applicant type: ❑Individual ❑Corporation ❑General Partnership ❑Privately-Owned Public Utility ❑Federal ❑State/County ®Municipal El ether 3. Signature authority's name:David Cheek per 15A NCAC 02T 0106(b) Title: City Manager 4. Applicant's mailing address: 106E Washington Street City:Mebane State:NC Zip:27302-_ 5. Applicant's contact information: Phone number: (919)563-5901 Email Address: dcheek@cityofinebane.com II. PROJECT INFORMATION: 1. Project name: Cambridge Park Sanitary Sewer Improvements 2. Application/Project status: ❑Proposed(New Permit) ®Existing Permit/Project If a modification,provide the existing permit number:W00040510 and issued date: 12/07/18 If new construction but part of a master plan,provide the existing permit number:W Q00_ 3. County where project is located:Alamance County 4. Approximate Coordinates(Decimal Degrees):Latitude: 36.0616670 Longitude:-79.3 8861 V 5. Parcel ID(if applicable): 160191 (or Parcel ID to closest downstream sewer) III. CONSULTANT INFORMATION: 1. Professional Engineer:Mark Lacy,P.E. License Number: 036286 Firm:LKC Engineering,PLLC Mailing address: 140 Aqua Shed Court City:Aberdeen State:NC Zip:28315-_ Phone number:.(910)420-1437 Email Address:mark@lkcengineering.com W. WASTEWATER TREATMENT FACILITY(WWTF)INFORMATION: 1. Facility Name: City of Graham W WTP/ Permit Number:NCO021211 Owner Name:City of Graham V. RECEIVING DOWNSTREAM SEWER INFORMATION(if different than WWTF): 1. Permit Number(s): WQ_ Downstream(Receiving) Sewer Size: 15 inch System Wide Collection System Permit Number(s)(if applicable):WQCS00081 Owner Name(s): City of Mebane Page 1 of 5 FORM:FTA 04-16 State of North Carolina Department of Environmental Quality DWR Division of Water Resources 15A NCAC 02T.0300—FAST TRACK SEWER SYSTEM EXTENSION APPLICATION Division of Water Resources FTA 04-16&SUPPORTING DOCUMENTATIONii Application Number. W ®(to he completed by DWR) All items must be completed or the application will be returned L APPLICANT INFORMATION: I 1. Applicant's name: City of Mebane(company,municipality,HOA,utility,etc.) 2. Applicant type: ❑ Individual Corporation ❑ General Partnership ❑Privately-Owned Public Utility El Federal. ❑ State/County ®Municipal ❑Other 3. Signature authority's name:David Cheek per 15A NCAC 02T'.0I06(b) Title:City Manager 4. Applicant's mailing address: 106 E. Washington Street Ervirof entalQuality City:Mebane State:NC Zip:27302-_ Received 5. Applicant's contact information: Phone number:(919)563-5901 Email Address:dcheek(acitvofinebane.com i IL PROJECT INFORMATION: - - - FR4Cionafl CC{71Ce 1. Project name:Cambridge Park Sanitary Sewer Improvements 2. Application/Project status: ❑Proposed(New Permit) ® Existing Permit/Project j If a modification,provide the existing permit number:W00040510 and issued date: 12/07/18 If new construction but part of a master plan,provide the existing permit number: W000_ 3, County where project is located:Alamance County 4. Approximate Coordinates(Decimal Degrees):Latitude: 36.061667' Longitude:-79.318611' 5. Parcel ID(if applicable): 160191 (or Parcel ID to closest downstream sewer) 111. CONSULTANT INFORMATION: 1. Professional Engineer: Mark Lacy,P.E. License Number:036286. Firm:LKC Eneineering,PLLC Mailing address: 140 ApuaShed Court City:Aberdeen State:NC Zip:28315-_ Phone number: (91.0)420-1437 Email Address:mark0ftcen ing_eering com IV. WASTEWATER TREATMENT FACILITY(WWTF)INFORMATION: 1. Facility Name:City of Mebane W WTP/ Permit Number:NCO021474 Owner Name:City of Mebane V. RECEIVING DOWNSTREAM SEWER INFORMATION(if different than WWTF): 1. Permit Number(s):WQ. Downstream(Receiving)Sewer Size: 10 inch System Wide Collection System Permit Numbers)(if applicable):WQCS00081 Owner Name(s):City of Mebane FORM: FTA 04-16 Page 1 of 5 i I VI. GENERAL REQUIREMENTS 1. If the Applicant is a Privately-Owned Public Utility,has a Certificate of Public Convenience and Necessity been attached? ❑Yes ❑No ®N/A 2. If the Applicant is a Developer of lots to be sold,has a Developer's Operational Agreement(FORM: DEVI been attached? El Yes ❑No ZN/A 3. If the Applicant is a Home/Property Owners'Association,has an Operational Agreement(FORM:HOA)been attached? i ❑Yes ❑No ®N/A 4. Origin of wastewater: (check all that apply): ® Residential Owned ❑Retail (stores,centers,malls) ❑Car Wash ❑ Residential Leased ❑ Retail with food preparation/service ❑ Hotel and/or Motels ❑:School/preschool/day care ❑ Medical/dental/veterinary facilities ❑ Swimming Pool/Clubhouse.. Food and drink facilities ❑ Church ❑ Swimming Pool/Filter Backwash ❑ Businesses/offices/factories ❑Nursing Home ❑Other(Explain in.Attachment) 5. Nature of wastewater: 10010/u Domestic/Commercial 0%Commercial' 0%Industrial(See 15A NCAC 02T.0103(20)) "Is there a Pretreatment Program in effect? ❑Yes ❑No 6. Hasa flow reduction been approved under 15A.NCAC 02T.01 14(f)? ❑Yes ❑No ➢ If yes,provide a coov of flow reduction approval letter 7. Summarize wastewater generated by project: Establishment Type(see 02T.0114(f)) Daily Design Flow a." No.of Units Flow gal/ GPD gal/ GPD gal/ GPD gal/ GPD gal/ GPD gal/ GPD Total 0 GPD a See 15A NCAC 02T.0114(b).(d).(e)(1) and (e)(2)for caveats to wastewater design flow rates(i.e.,minimum flow per dwelling;proposed unknown non-residential development uses;public access facilities located near high public use areas; and residential property located south or east of the Atlantic Intracoastal Waterway to be used as vacation rentals as defined in G.S.42A-4). b Per 15A NCAC 02T.0114(c),design flow rates for establishments not identified[in table 15A NCAC 02T.01 141 shall be determined using available flow data,water using fixtures,occupancy or operation patterns,and other measured data. 8. Wastewater generated by project:_GPD(per 15A NCAC 02T_0114) Do not include future flows or previously permitted allocations If permitted flow is zero, indicate why: �.Pump Station or Gravity Sewer where flow will be permitted in subsequent permits that connect to this line ❑ Flow has already been allocated in Permit Number:_ Rehabilitation or replacement of existing sewer with no new flow expected ❑Other(Explain): _ FORM: FTA 04-16 Page 2 of 5 VIL GRAVITY SEWER DESIGN CRITERIA(If Applicable)-02T.0305&MDC(Gravity Sewers): i 1. Summarize gravity sewer to be permitted: Size(inches) Length(feet) Material 16-inch 860I.f DIP 12-inch 2,300I.f PVC/DIP i ➢ Section II:& III of the MDC for Permitting of Gravity Sewers contains information related to design criteria ➢ Section III contains information related to minimum slopes for gravity sewer(s) Oversizing lines to meet minimum slope requirement is not allowed and a violation of the MDC VIII. PUMP STATION DESIGN CRITERIA(If Applicable)—02T.0305& MDC(Pump Stations/Force Mains): COMPLETE FOR EACH PUMP STATION INCLUDED IN THIS PROJECT I. Pump station number or name:Cambridge Park Pump Station 2.. Approximate Coordinates(Decimal'Degrees):Latitude:36.0413890 Longitude:-79.302500° i 3. Design flow of the pump station: 0.720 millions gallons per day(firm capacity) 4. Operational point(s)of the pump(s): 500 gallons per minute at 139 feet total dynamic head(TDH) 5. Summarize the force main to be permitted(for this Pump Station): I Size(inches) Length(feet) Material !I 10-inch 6,430 Lf. PVC C900/DIP I 6. Power reliability in accordance with 15A NCAC 02T.0305(h)(1): ® Standby power source or pump with automatic activation and telemetry- 15A NCAC 02T.0305(h)(1)(B).* Required for all pump stations with an average daily flow greater than or equal to 15,000 gallons per day ➢ Must be permanent to facility Or if the pump station has an average daily flow less than 15,000 gallons per day: ❑. Portable power source with manual activation;quick-connection receptacle and telemetry- 15A NCAC 02T .0305(h)(1)(C) or ❑ Portable pumping unit with plugged emergency pump connection and telemetry- 15A NCAC 02T.0305(h)(1)(C): ➢ It shall be demonstrated to the Division that the portable source is owned or contracted by the applicant(draft agreement) ! and is compatible with the station. ➢ If the portable power source or pump is dedicated to multiple pump stations,an evaluation of all the pump stations'storage capacities and the rotation schedule of the portable power source or pump, including travel timeframes,shall be provided in.the case of a multiple station power outage. FORM:FTA 04-16 Page 3 of 5 IX. SETBACKS&SEPARATIONS—(02B.0200& 15A NCACO2T.0305(f)): I. Does the project comply with all separations found in 15A NCAC 02T.0305(0&(e) ®Yes ❑No 15A NCAC 02T.0305(f)contains minimum separations that shall bep provided for sewers stems: Setback Parameter*. Separation Required Storm sewers and other utilities not listed below(vertical) 24 inches i Water mains vertical-water over sewer including in benched trenches 18 inches Water mains horizontal 10 feet Reclaimed water lines vertical-reclaimed over sewer :1.8 inches Reclaimed water lines horizontal-reclaimed over sewer 2 feet "Any private or public water supply source,including any wells,.WS-I waters of Class I.or Class II impounded reservoirs used as a source of drinking water 100 feet "Waters classified WS(except WS4 or WS-V),B,SA,ORW,HQW,or SB from normal high water or tide elevation and wetlands see item IX.2 50 feet "Any other stream, lake, impoundment,or ground water lowering and surface drainage ditches 10 feet Any building foundation 5 feet Any basement 10 feet Top slope of embankment or cuts of 2 feet or more vertical height 10 feet Drainage systems and interceptor drains 5 feet An swimmin Dols 10 feet Final earth grade vertical 36 inches ➢ 15A NCAC 02T.0305(a)contains alternatives where separations.in 02T.0305(f)cannot be achieved. ➢ "Stream classifications can be identified using the Division's NC Surface Water Classifications weboaee � ➢ If noncompliance with 02T.0305(f)or(g),see Section X of this application 2. Does the project comply with separation requirements for wetlands?(50 feet of separation) ®Yes ❑No ❑N/A ➢ See the Division's draft separation requirements for situations where separation cannot be meet ➢ No variance is required if the alternative design criteria specified is utilized in design and construction ➢ As built documents should reference the location of areas effected 3. Does the project comply with setbacks found in the river basin rules per 15A NCAC 02B..0200? ®Yes ❑No ❑N/A ➢ This would include Trout Buffered Streams per 15A NCAC 2B.0202 4. Does the project require coverage/authorization under a 404 Nationwide or ❑Yes ®No individual permits or 401 Water Quality Certifications? Information can be obtained from the 401.&Buffer Permitting.Branch I 5. Does project comply with 15A NCAC 02T.0 I 05(c)(6)(additional permits/certifications)? ®Yes ❑No Per 15A NCAC 02T.0105(c)(6), directly related environmental permits or certification applications are being prepared,have been applied for,or have beenobtained. Issuance of this permit is contingent on issuance of dependent permits.(erosion and sedimentation control plans,stormwater management plans,etc.). 6. Does this project include any sewer collection lines that are deemed"high-priority?" Per 15A NCAC 02T.0402,"high-priority sewer"means"any aerial sewer,sewer contacting surface waters,siphon,or sewer III positioned parallel to streambanks that is subject to erosion that undermines or deteriorates the sewer. ❑Yes ®No ❑N/A ➢ If yes,include an attachment with details for each line, including type(aerial line,size,material,and location). High priority lines shall be inspected by the permittee or its representative at least once every six-months and inspections documented per 15A NCAC 02T.0403(a)(5)or the permitee's individual System-Wide Collection permit. FORM: FTA 04-16 Page 4 of 5 �I k X. CERTIFICATIONS: I. Does the submitted system comply with 15A NCAC 02T,the Minimum Design Criteria for the Permitting of Pump Stations and Force Mains(latest version),and the Gravity Sewer Minimum Design Criteria(latest version).as applicable? ®Yes ❑No If No,complete and submit the Variance/Altemative Design Request application(VADC 10-14)and supporting documents for review. Aooroval of the request is required prior to submittal of the Fast Track Application andsu000rtine documents 2. Professional En gineer's Certification: H . l t, 144AR4 LACY attest that this application for (Professional Engineer's name from Application Item Ill.1.) has been reviewed by me and inaccurate,complete and consistent with the information supplied in the plans,specifications, engineering calculations,and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design .has been prepared in accordance with.the applicable regulations, Gravity Sewer Minimum Design Criteria for Gravity Sewers(latest version),and the Minimum Design Criteria for the Fast-Track Permitting of Pump Stations and Force Mains(latest version). Although other professionals may have developed certain'portions of this submittal package, inclusion of these materials under my signature and seal signifies that-I have reviewed this material and have judged it to be consistent with the proposed design. I NOTE - In accordance with General Statutes 143-215.6A and 143-215.6B, any person who knowingly makes any false statement, representation, or certification in any:application package shalt be guilty of a Class 2 misdemeanor, which may include a fine not to exceed$10,000,as well as civil penalties up to$25,000 per violation ICI �1l\Illl1l/J/ North Carolina Professional.Engineer's seal,signature,and date SEAL 36 86 � •� ';1'GIME r ��� itttl ram. 3. Applicant's Certification per 15A NCAC 02T.0106(b): y. 1'7- to( 1 Dl�nt a Cyq(:lviG attest that this application for III (Signature Authority's name&title from Application Item 1.3.) has been reviewed by me and is accurate and complete to the best of my knowledge. I.understand that if all required parts of this application are not completed and that if all required supporting documentation and attachments are not included, this application package is subject to being returned as incomplete. f understand that any discharge of wastewater from this non- discharge system to surface waters or the land will result in an immediate enforcement action that may include civil penalties, :injunctive relief,and/or criminal prosecution. I will make no claim against the Division of Water Resources should a condition of this permit be violated. I also understand that if all required parts of this application package are not completed and that if all required supporting information and attachments are not included, this application package will be returned to me as incomplete. NOTE — In accordance with General Statutes 143-215.6A and 143-215.6B,'any person who knowingly makes any false statement, representation, or certification in any application package shall be guilty lofa Class 2 misdemeanor, which may include a fine not to exceed$10,000 as well as civil penalties up to,$25,000 per violation. 6 Date: l b 41 Signature: — FORM: FTA 04-16 Page 5 of 5 State of North Carolina Department of Environmental Quality Division of Water Resources IN 141" Dlvislon of Water Resources Flow.Tracking for Sewer Extension Applications (FTSE 10-18) Entity Requesting Allocation: City of Graham -Mebane Allocation Project Name for which flow is being requested: Cambridge Park Phase IA More Oran one FTSE may be required for a single project if the owner of the WWTP is not responsible for all pump stations along the route of lire proposed waslewater flow. I. Complete this section only if you are the owner of the wastewater treatment plant. a. WWTP Facility Name: City of Graham WWTP b. WWTP Facility Permit#: NC O021211 All flows are in MGD c. WWTP facility's permitted flow 3.50 d. Estimated obligated flow not yet tributary to the WWTP .958786 j e. WWTP facility's actual avg. flow 1.60 f. Total flow for this specific request .015600 -Mebane Allocation g. Total actual and obligated flows to the facility 2.574386 h. Percent of permitted flow used 73.6% I1. Complete this section for each pump station you are responsible for along the route of this proposed wastewater flow. I List pump stations located between the project connection point and the WWTP: (A) (B) (C) (D)=(B+C) (E)=(A-D)I Design Obligated, Pump Pump Average Approx. Not Yet Total Current Station Station Firm Daily Flow** Current Tributary Flow Plus (Name or Permit Capacity,* (Firm/pf), Avg. Daily Daily Flow, Obligated Available Number) No. MOD MOD Flow,MOD MOD Flow Capacity*** Cherry Lane 2.5_ 1.0 .0125 .750 .7625 .2375 i - II *The Firm Capacity(design flow)of any pump station is defined as the maximum pumped flow that can be achieved with the largest pump taken out of service. **Design Average Daily Flow is the firm capacity of the pump station divided by a peaking factor (pf)not less than 2.5,per Section 2.02(A)(4)(c)of the Minimum Design Criteria. ***A Planning Assessment Addendum shall be attached for each pump station located between the project connection point and the WWTP where the Available Capacity is<0. Downstream Facility Name(Sewer): Cherry Lane Force Main Downstream Permit Number: WQ 0029492 Page 1 of 6 FTSE 10-18 City of Graham FTSE-Cherry Lane Lift Station W WTP-2018 Fiscal Year Flows GPD Cherry Lane 12,500 Total Flow 12,500 W WTP-Allocated Flows-Non-Tributary Project Name GPD City of Mebane-Allocation(Remaining) 747 500 NCCP - Hawfields Day Care(Mebane Allocation) 2,500 Total Allocated-Non Tributary Flows 760,000 Proposed Flows Project Name GPD Cambridge Park, Phase 1A Mebane Allocation 15,600 I Total Flows 762,500 i Situation GPD %of Capacity Peak Capacity of Station-Design 2,505,600 30.4% Average Daily Flow Capacity- Design 1,002,240 76.1% Future Capacity of Station (Additional Pum 5,011,200 15.2% ueDe ly Flow Capacity(Additional Pump)-Design 2,004,480 38.0% III II, City of Graham FTSE-W WTP W WTP-2017 Calendar Year Flows GPD W WTP 1,600,000 Total Flow 1,600,000 W WTP-Obligated Flows-Non-Tributary Project Name GPD Graham Obligated Flows Mebane NCCP Flows - Mebane Allocation 747,500 HawFields Day Care Mebane Allocation 2,500 Total Allocated-Non Tributary Flows 958,786 Proposed Flows Project Name GPD Cambridge Park, Phase 1A 15,600 Total Flows 2,574,386 Permitted Flows 3,500,000 Percentage of Permitted Flow 73.6% i i State of North Carolina Department of Environmental Quality Division of Water Resources i;v15F: E x ria:?= •g_.n;rce Flow Tracking for Sewer Extension Applications (FTSE 10-18) Entity Requesting Allocation: City of Mebane Project Name for which flow is being requested: Cambridge Park Phase IA More than one FTSE maybe required for a single project if the owner of the WWTP is not responsible for all pump stations along the route of the proposed wastewater flow. i I. Complete this section only if you are the owner of the wastewater treatment plant. a. WWTP Facility Name: Allocation to Graham WWTP b. WWTP Facility Permit#: NC 0021211 All flows are in MGD c. WWTP facility's permitted flow 0.750 d. Estimated obligated flow not yet tributary to the WWTP 0.00 e. WWTP facility's actual avg. flow 0.00 f. Total flow for this specific request .015600 g. Total actual and obligated flows to the facility .018100 h. Percent of permitted flow used 2.4% II. Complete this section for each pump station you are responsible for along the route of this proposed wastewater flow. List pump stations located between the project connection point and the WWTP: (A) (B) (C) (D)=(B+C) (E)=(A-D) Design Average Approx. Obligated, Total Pump Pump Daily Current Not Yet Current Flow Station Station Firm Flow** Avg. Daily Tributary Plus (Name or Permit Capacity, * (Firm/pf), Flow, Daily Flow, Obligated Available Number) No. MGD MGD MGD MGD Flow Capacity*** i Cambridge Park .500 .288 0.00 0.00 .00 .288 *The Firm Capacity(design flow)of any pump station is defined as the maximum pumped flow that can be achieved with the largest pump taken out of service. **Design Average Daily Flow is the firm capacity of the pump station divided by a peaking factor (pf)not less than 2.5,per Section 2.02(A)(4)(c)of the Minimum Design Criteria. ***A Planning Assessment Addendum shall be attached for each pump station located between the project connection point and the W WTP where the Available Capacity is<0. Downstream Facility Name(Sewer): Cambridge Park Onsite Outfall Downstream Permit Number: Not Permitted Yet Page 1 of 6 FTSE 10-18 III. Certification Statement: I David Cheek certify to the best of my knowledge that the addition of the volume of wastewater to be permitted in this project has been evaluated along the route to the receiving wastewater treatment facility and that the flow from this project is not anticipated to cause any capacity related sanitary sewer overflows or overburden any downstream pump station en route to the receiving treatment plant under normal circumstances, given the implementation of the planned improvements identified in the planning assessment where applicable. This analysis has been performed in accordance with local established policies and procedures using the best available data. This certification applies to those items listed above in Sections I and II plus all attached planning assessment addendums for which I am the responsible party. Signature of this form certifies that the receiving collection system or treatment works has adequate capacity to transport and treat the proposed new wastewater. Signing Official Signature Date 6M M.4=4A(56A Title of Signing Official i I I I Page 2 of 6 FTSE 10-18 CAMBRIDGE PARK USGS MAP N 6t?(} ; SANITARY SEWER IMPROVEMENTS PERMIT MODIFICATIONS WE Connection to j r CITY OF MEBANE, NC ` Existing Outfall S 1 t Proposed 16-inch Proposed 12-inch i% t A. Gravity Sewer Gravity Sewer a � f it Tta ■ _ µ 64 ■ . it .� ♦� f ■ �`r•• } dr ■ Dark ., ■ ■ w Il • 4� 11� - � � � ■ ; ' Proposed 10-inch w -�"� ■ Forcema, Legend Proposed Pump a! Proposed Pump Station Station Site Proposed Gravity 12-inch r ---_. + `• /�/ 18-inch a ,••«: Proposed Force Main 0 500 1,000 2,000 ,.,. s Feet