NC0051969_Other Correspondence_20190610

Castle Creek9llemory Care
4724 Castle ?fayne mad
Castle Yfayne, 9VC 28429
Division of Water Resources June 10, 2019
NPDES Compliance & expedited Permit Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Joe Corporon
Dear Mr. Corporon,
We are requesting a revised compliance schedule for Castle Creek Memory Care NPDES permit
number NC0051969 to allow additional time to study and make changes to the wastewater
system.
The permit renewal finalized on April 7, 2017 outlined new limits on chloride and copper that
went into effect May 1, 2019. Since receiving the new limits, the facility has been working
steadily to gain compliance.
Report and recommendation from our Operator Kevin Woodard:
"Castle Creek's water is well water; the ion exchange softening system was looked at first in an
attempt to reduce chloride levels received by the WWTP. By optimizing catalytic iron filtration
ahead of the softener, salt containing regeneration cycles we reduced in frequency from nightly to
every third night. This has been effective in reducing chloride levels but has not achieved the
230mg/L level required. The next step may be to redesign the well's water treatment plumbing
that would direct all softener backwash to a holding tank to be hauled offsite. This will take time
to gain approval and complete the changes.
The facility plumbing system is copper, and some leaching is unavoidable. After optimizing the
iron removal ahead of the softener, the facility has had the option of allowing a portion of the
flow to bypass the softener. Targeting a concentration of approximately 50mg/L hardness with
the goal of reducing the corrosion potential and levels of copper reaching the WWPT, has been
tried for a number of months. This so far has not been effective. The next step may be
implementing some form of chemical addition for corrosion control. This will require study,
planning, and approval prior to pilot study for effectiveness."
Castle Creek Memory Care is funded primary by Medicaid, and these changes will burden us
with considerable financial strain. We are formally requesting additional time to allow us to fully
study our options and achieve compliance as economically as possible.
a Dagenhart
Facilities Director
828-851-9981
[e-mail]
(Phone. [phone] E'ax (910) 910-675-8621