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NC0063614_Fact Sheet_20230613DENR/DWR EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit: NCO063614 2023 Renewal This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303 (d) listed water, toxicity testing, instream monitoring, compliance concerns). Facility and Stream Information Applicant/Facility Name: Aqua North Carolina, Inc. Wildwood Green WWTP Applicant Address: 202 Mackenan Court; Cary, NC 27511 Facility Address: Gleneagles Drive; Raleigh, NC 27614 Facility Class/Permit Status: Grade II Biological WPCS / Renewal Permitted Flow (as built 0.1 MGD Type of Waste 100% Domestic Receiving Stream UT Lower Barton Cr Stream Class / ID WS-IV; NSW / 27-16- 1 River Basin Neuse Subbasin 03-04-01 HUC 030202010602 USGS Too Ba leaf D24NW 7Q10 Sum Win cfs 0.06 0.13 30Q2 cfs 0.19 Avg. Stream Flow cfs 0.72 IWC % sum/win 72 54 County Wake Regional Office RRO Basic Information for Expedited Permit Renewal Permit Writer / Date Bradley Bennett / March 6, 2023 Does permit need daily max NH3 limits? No - Has monitoring and tox limits Does permit need TRC limits/language? Yes - Already in permit as backup to UV Does permit have toxicity testing? Yes - Pass Fail Does permit have Special Conditions? Yes - Combined Nutrient Limits; Nutrient Calculation & Reporting; Annual Nutrient Limits; Nutrient Allocations; Temporary Disinfection and Chronic Tox Does permit have instream monitoring? Yes - Temp and DO Stream on 303 d List? For w arameter? No - Mercury statewide issue only Any compliance concerns? No Enforcements and a few Violations under previous permit Any modifications since last permit? Changes to achieve nitrogen removal to comply with 2018 permit limits. New expiration date: January 31, 2028 FACILITY OVERVIEW: This facility is 100% domestic waste and treats a subdivision serving a population of 1,892 people. The facility has a permitted and as built flow rate of 0.1 MGD. The treatment system includes the following wastewater treatment components: • Bar screen • Aeration basins with mixers and DO probes • Clarifier with blower • Chemical phosphorus removal • Tertiary filters • Flow meter • Ultraviolet disinfectant • Effluent pumps • Back-up power generator APPLICATION The application does not indicate any changes in the facility or treatment since the last renewal of the permit. The treatment system is operated by Aqua North Carolina, Inc. The annual average daily flow is indicated as 0.04 MGD over the last two years, so the facility is operating at well below its designed and permitted capacity. The application indicates upcoming improvements with metal rehab scheduled for January 2025. The application indicates discharge is to Upper Barton Creek, but the location of the facility on the map and previous information in the permit file confirm that the discharge location to Lower Barton Creek is accurate. The application also notes the facility location as on Gleneagle Drive but the BIMS database notes a location on Baileywick Road. Permittee response on this issue is that the Baileywick address doesn't exist and it appears Gleneagles wasn't extended as is should have been. The entrance to the WWTP is off of Baileywick but old permits have said location is Gleneagles and it appears the applicant wants to maintain this location. As part of the application request Aqua asked that the Division remove Whole Effluent Toxicity (WET) requirements from the permit. Their request is based on the facility no longer using chlorine for disinfection and having passed all toxicity tests during the permit cycle. INSPECTION The most recent inspections occurred on December 27, 2018 and was conducted by Wake County Environmental Services. The inspection noted that the facility was being upgraded to begin nitrification and was operating well. One note in the inspection report indicated that the exact location of the outfall needed to be marked. The inspection report noted modifications in the aeration basins to create anoxic conditions for denitrifications (new mixers, DO probes and blower). Reviewing other file information shows that in response to the 2018 permit changes that included nitrogen limits, the facility initiated a pilot process to promote nitrogen removal. This pilot process became final with a 2019 ATC for the finalization of the mixers, blower and DO probe noted in the inspection report. MONITORING DATA REVIEW: Parameter Units Min Max Avg Permit Limit Comments Flow MGD 0.003 0.153 0.036 0.1 MA BOD m L Summer < 2 4.50 1.28 11 MA 16.5 DM BOD m L Winter < 2 11.00 1.45 22 MA 33 DM TSS m L < 2.5 14.00 1.77 30 MA 45 DM Temp (C) - Effluent 10.30 65.7 19.36 One large value (>26K) removed from data set Temp C - Upstream 0.00 30.10 17.27 Temp C - Downstream 0.00 29.30 16.48 NH3-N m L Summer < 0.045 2.40 0.13 9 MA 35 DM NH3-N m L Winter < 0.0098 5.80 0.29 18 MA 35 DM DO m L - Effluent 5.25 23.20 8.24 5 DA DO m L - Upstream 0.00 14.30 7.92 DO m L - Downstream 5.25 23.20 8.24 - Fecal Coliform # ml < 1 2420.00 10.15 200 MA 400 DM 24K value is only high value in data TRC (µg/L) 24DM No use of Chlorine Total Nitrogen m L 1.27 124.53 15.38 - TN Monthly lbs month 19.17 1 707.14 144.06 See discussion below TN Annual (lbs/year) Data Reported Inaccurately. See below Total Phosphorus m L < 0.025 6.30 0.66 TP Monthly lbs month 0.00 28.92 6.45 See discussion below TP Annual lbs ear Data Reported Inaccurately. See below H su 6.59 8.85 N/A >-6 and <-9 MA -Monthly Average DM - Daily Max QA -Quarterly Average DA - Daily Average Summer - April through Oct Winter - Nov through March The data reviewed for the renewal is from March 2018 through January 2023. Wildwood Green WWTP Fact Sheet NPDES Renewal 2023 - March 28, 2023 Page 2 REVIEW OF PERMIT LIMITS: Flow - The facility is operating on average at around 40% of the flow allowed by the permit. None of the 59 monthly average values was above 0.056MGD. BOD / TSS / Fecal - The only limit violation this cycle was one exceedance for fecal coliform. This value was well above any other value for fecal reported during the permit cycle. Ammonia (NH3-N) and ToxicU - This permit has had both ammonia and toxicity limits since the 1991 WLA. The 1991 WLA had looked at setting NH3-N limits at 1.3 and 3.1 mg/L, but the permittee instead asked for the existing limits of 9 and 18 mg/L with the addition of WET requirements. These requirements have remained in the permit. Over time the permittees (prior to Aqua) had asked for removal of the toxicity requirements in the permit. During those reviews it was determined that the facility had toxicity test failures and those failures were not during times when other parameters like ammonia showed any issues to potentially cause the failures. So, the WET testing was maintained in the permit. With this application Aqua has requested review of the WET requirements in this permit for removal. Over the last permit cycle the facility did not have any failed WET test results. The Aquatic Toxicology Branch has been contacted about the removal of WET testing and feels that for this facility, as a 100% domestic discharger, the WET requirements can be removed from the permit. The Regional Office was also asked for input. This draft proposes removal of the WET requirements. Along with this change the permit will include more stringent Ammonia limits consistent with the WLA spreadsheet analysis, implementation of revised ammonia criteria and the Division's policy for small WWTP of this type. The Waste Load Allocation spreadsheet for this discharge calculated NH3-N limits of 1.8 mg/L for summer and 3.1 mg/L for winter. However, Division policy has established that for small discharges (< 1 MGD) the best available treatment technology for these facilities leads to monthly average limits no lower than 2 mg/L -summer and 4 mg/L - winter. Limits in the permit will be set as follows: Monthly Avg Daily Max Frequency Type Location NH3-N - Summer 2 m L 10 m L Weekly Composite Effluent NH3-N - Winter 4 m L 20 m L Weekly Composite Effluent The data reviewed for this renewal would indicate that the facility can meet these permit limits. During the previous permit cycle, evaluating the data with these limits resulted in no violations over the permit cycle. The permittee was informed of the removal of WET requirements and adjustment of the NH3-N limits in an email on March 14, 2023. After hearing about the NH3-N limits the permittee responded that they would like to rescind their request for WET removal. Division staff responded that with the new ammonia criteria and input from EPA on the use of action level standards in the place of chemical limits we could no longer allow WET requirements in leu of more stringent NH3-N limits. Nutrients This permit was renewed in 2018 with nutrient limits - concentration, monthly and annual load limits. The facility worked to add treatment processes to address nutrient reduction and requested a modification to the permit that was issued in 2019. The 2019 modification set up a bubble permit that works with Aqua's Hawthorne WWTP (NC0049662) to establish nutrient allocations and load limits that are set as combined mass load limitations for the two plants. In the year prior to the modification the permittee had multiple violation and enforcement actions for TN and TP concentration violations. These concentration limits were removed as part of the 2019 permit modification. The permittee has been reporting some of the nutrient data inaccurately in the eDMR system. The permitee has reported the nitrogen and phosphorus annual loads, QY600 and QY655, on a monthly basis. Each month the value is reported identical to the monthly value (QM600 and QM655). They should be reporting the QM values monthly and then reporting the total annual load (QY values) in the December DMR only. The permittee is also Wildwood Green WWTP Fact Sheet NPDES Renewal 2023 — March 28, 2023 Page 3 required to report the total combined annual load number for nitrogen and phosphorous as part of the December DMR for the Hawthorne (NC49662) facility as part of a separately established permit outfall in the Hawthorne permit. The permittee reported this data correctly in 2019 and 2020 but did not report the data at all in 2021 and 2022. The permittee also had one DMR (July 2022) that reported TN and TP numbers that were very high and subsequently modified the DMR in January 2023. However, the January 2023 correction was added to the eDMR system but never submitted appropriately in the system. So, the incorrect data is still the data found in the BIMS system. Permit staff accounted for these corrections in the review of permit data. The permittee was made aware of these issues in an email as part of this renewal review and is working to correct these. COMPLIANCE: The facility had one NOV for a daily max fecal violation in 2020 and also an NOV for missing a WET test in 2022. The WET test was completed in a subsequent month. In 2018 (as noted above) the facility had a number of TN and TP concentration violations and enforcements, but the concentration limits were removed from the permit in the 2019 permit modification. FILE HISTORY REVIEW SUMMARY • Permit was originally issued in 1986 • March 26, 1985 WLA - Class C Water Design flow = 0.065 MGD s7010 =0.04 cfs w7010 = 0.12 cfs BODS m L NH3-N m L DO m L TSS m L Fecal m L pH std units Total P m L 16 11 5 30 1,000 6-9 1 July 15, 1986 WLA - This WLA indicates that the 1985 WLA was done for the wrong location. This one is done for two flows, 0.065 MGD and 0.10 MGD with s7Q10 = 0.04 cfs and w7Q10 = 0.3 cfs. Stream class is C- NSW: Flow MGD BODS m L NH3-N m L DO m L TSS m L Fecal m L pH std units Total P m L (s 0.065 23 5 30 1,000 6-9 1 20(s) s) 0.10 22 5 30 1,000 6-9 1 18(s) July 15, 1986 Authorization to Construct (ATC) for construction of 0.065 MGD wastewater treatment plant with surge tank, bar screen, two aeration tanks, two clarifiers, sludge holding tank, tertiary filter with foot filter cells, post aeration tank, etc. May 28, 1987 ATC for 0.10 MGD wastewater treatment plant with surge tank, bar screen, two clarifiers, aerobic digester, duel cell tertiary filter, chlorinator and chlorine contact tank, etc. January 14,1991 WLA - Stream class changes to WS-IV; NSW. Design flow is 0.10 MGD only with 7Q10s = 0.06 cfs and 7Q10w = 0.13 cfs. Fecal changed to 200. Season BOD5 m L NH3-N m L DO m L TSS m L Fecal m L pH std units Total P m L Summer 11 9 5 30 200 6-9 2 Winter 22 18 5 30 200 6-9 2 Also requires TRC monitoring. This WLA had proposed lower NH3-N limits (1.3/3.1) or to maintain the existing 9/18 limits with WET testing. Permittee chose WET test alternative. October 19, 1992 WLA - Stream class is WS-IV; NSW. Design flow is 0.10 MGD with 7Q10s = 0.06 cfs and 7Q10w = 0.13 cfs. Includes Chronic Tox requirement as well as NH3-N limits of 9 and 18 like 1991 WLA. The documents mention that TP may have been dropped in the past in favor of Tox. The document mentions the facility having a Wake County permit of some type in the past as well. Wildwood Green WWTP Fact Sheet NPDES Renewal 2023 — March 28, 2023 Page 4 • 2000 Permit Renewal - This renewal added daily max limits to the monthly averages as noted below. Winter NH3-NH reduced from 20 to 18 mg/L, BOD5 NH3-N DO TSS Fecal pH Total P TRC Season m /L m /L m /L m /L m /L std u. m /L µ /L Summer 11 / 16.5 9 5 30 / 45 200 / 400 6-9 2 24 MA/DM Winter 22 / 33 18 5 1 30 / 45 1 200 / 400 6-9 2 24 Heater Utilities requested removal of the WET requirements and instead strengthen NH3-N limits. DWQ reviewed and found that there had been toxicity failures at times when neither TRC or NH3-N data showed any potential issues. Due to this, DWQ denied the request to remove WET and recommended that the permittee look for and address the source of toxicity and then, with one full year of compliance with the Tox requirements they could request removal again. With Tox remaining, NH3-N limits remained at 9/8 rather than being reduced to 2/4. • September 15, 2000 ATC for installation of a UV disinfection system • June 21, 2001 Engineer's Certification for completion of the UV disinfection system • 2003 Permit Renewal - Heater again requested removal of the WET requirement. DWQ review again showed that there had been toxicity failures and at the time of the failures NH3-N levels did not show a problem. WET requirements were maintained in the permit without decreased NH3-N limits. Added daily max limits for NH3-N to meet EPA requirements. Limits set at 35mg/L for both summer and winter (5:1 ratio with 35 as the Division cap). Notes the NSW rules and that the facility will be subject to nitrogen limits in the next permit cycle. Fact Sheet seemed to be leaning to removing WET testing but then the facility had a failed test in Aug 2003. Monitoring for TKN and NO2-N+NO3-N required to be reported separate in DMR. Influent monitoring for BOD and TSS deleted in a permit correction letter. • 2008 Permit Renewal - At this time Aqua has become the permittee. There is no indication in the file that Aqua requested any review of the WET requirement. The staff report for this renewal noted that there had been periodic toxicity issues not related to NH3-N. Major changes in this permit are the addition of nitrogen requirements in keeping with the NSW rules. This included special conditions for Nitrogen calculations, Annual Limits and Load Allocation. Special condition also added on temporary disinfection. The permit included a condition for a Wastewater Management Plan including a mechanical evaluation of the facility. The Fact Sheet had a lot of discussion about the facility moving to Class III and associated monitoring changes but ultimately the facility stayed Class II. • 2013 Permit Renewal - No discussions about removal of WET. Permit adds in the parameter codes and also updated the TRC footnote language about compliance threshold. • 2018 Permit Renewal - Permit renewal added monthly average TN limit of 8mg/L and an annual average limit of 5.5mg/L. TP monthly average was lowered to 1.0 mg/L and a TP annual average limit of 0.5mg/L was added. This permit also added rule citations and language for electronic submittal of DMRs. There was no discussion about WET requirements. • February 2018 Modification - This modification was issued in response to the permittee's request for a time extension to meet TN and TP limits. The average annual limits for TN and TP were set as taking effect January 1, 2019. The quarterly average limit for TP was set to expire December 31, 2018. • March 2019 Permit Modification - This modification was issued in response to the permittee's request for a modification that allowed for mass load combined (bubble) permit limits for this permit and their nearby Hawthorne WWTP (NC0049662). The permit changed the effluent limits page to monitoring only for TN and TP and established Special Conditions pages to outline Combined Limitations for the Wildwood Green and Hawthorne WWTPs. The permit also established changes in special conditions to set TN and TP Allocations. No discussion about WET requirements. • August 28, 2019 - ATC for finalization of pilot upgrades to the treatment system for increased nitrogen removal. Upgrades consist of the addition of four mixers to the aeration basins, connection of a dedicated blower for the clarifier and installation of DO probes in the aeration basins. • September 5, 2019 Memo to File on Transfer of Unavailable TN Allocations. This memo summarizes a meeting between Aqua staff and DWR staff on September 3, 2019 to discuss transferring TN allocations from Hawthorne and Wildwood Green WWTPs to Aqua's Neuse Colony facility. The Neuse rules don't provide for existing facilities to increase their limits and expects them to take steps to meet their assigned limits. Aqua could transfer TN allocation to Neuse Colony but it could only be used when the facility Wildwood Green WWTP Fact Sheet NPDES Renewal 2023 — March 28, 2023 Page 5 expands beyond 0.75 MGD as currently permitted. It did not appear likely that Aqua would benefit from a transfer. PROPOSED PERMIT CHANGES: • Updated eDMR requirements to be consistent with final EPA rule. • Added or updated regulatory citations throughout permit as needed. • Removed WET from the permit and added in more stringent NH3-N limits of 2/10 summer and 4/20 winter. • Permit map information updated. • Added Special Condition for Nutrient Re -opener. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: April 4, 2023 Permit Scheduled Effective Date: July 1, 2023 STATE CONTACT: If you have questions concerning the above or the attached documents, please contact Bradley Bennett at bradley.bennettOncdenr.gov. . Wildwood Green WWTP Fact Sheet NPDES Renewal 2023 — March 28, 2023 Page 6 ipt> News & Observer Publication Name: News & Observer Publication URL: Publication City and State: Raleigh, NC Publication County: Wake Notice Popular Keyword Category: Notice Keywords: NC0049662 Notice Authentication Number: 202305010822360971244 2510867466 Notice URL: Back Notice Publish Date: Thursday, April 27, 2023 Notice Content Public Notice State of North Carolina/Environmental Management Commission 1617 Mail Service Center, Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES wastewater permit. The North Carolina Environmental Management Commission proposes to issue a NPDES wastewater discharge permit to the person(s) listed below. AQUA North Carolina, Inc [202 MacKenan Court; Cary, NC 27511] has requested renewal of NPDES permit NC0063614 for the Wildwood Green WWTP, located in Wake County. This permitted facility discharges 100% domestic wastewater to a UT to Lower Barton Creek, a class WS-IV; NSW water in the Neuse River Basin. Some of the parameters in the permit are water quality limited. This discharge may affect future allocations in this segment of Lower Barton Creek. AQUA North Carolina, Inc [202 MacKenan Court; Cary, NC 27511] has requested renewal of NPDES permit NC0049662 for the Hawthorne WWTP, located in Wake County. This permitted facility discharges 100% domestic wastewater to Upper Barton Creek, a class WS-IV; NSW water in the Neuse River Basin. Some of the parameters in the permit are water quality limited. This discharge may affect future allocations in this segment of Upper Barton Creek. The Town of Robersonville has applied for renewal of NPDES permit NC0026042 for its Robersonville WWTP in Martin County. This permitted facility discharges treated wastewater to Flat Swamp in the Tar Pamlico River Basin. Written comments regarding the proposed permit will be accepted until 30 days after the publish date. The Director of the NC Division of Water Resources may hold a public hearing should there be a significant degree of public interest. Interested persons may visit the DWR at 512 N. Salisbury Street, Raleigh, NC, 27699. Please mail comments and/or information requests to DWR at the address listed above. Additional information on NPDES permits and this notice may be found on our website: http://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/npdes- wastewater/public-notices, or by calling (919) 707-3601. W00000000 Publication Dates Back Bennett, Bradley From: Sent: Bennett, Bradley Tuesday, May 9, 2023 2:09 PM To: Berger, Amanda A Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) Thanks for the comments, Amanda. I'll look at these when we are finalizing the permits. Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@ncdenr.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, May 9, 2023 1:55 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Hey Bradley — The only comments received were: 1. Chemical for phosphorus removal is sodium aluminate not ferric sulfate. a. Can we just say chemical phosphorus vs specifying the chemical? Also Hawthorne has a flow EQ basin and influent basin listed. Are they not the same? Thanks, Amanda AQUA Amanda Berger Director, Environmental Compliance Aqua North Carolina 202 Mackenan Court; Cary, NC 27511 0() From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Tuesday, April 18, 2023 3:30 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Thanks Amanda From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, April 18, 2023 3:19 PM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: RE: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Hi Bradley - I was out of the office that week, and I was under the impression someone else responded. Yes, we have received the drafts and are under review by operations staff. I will let you know if we have any comments or concerns. Wildwood Green —Yes, it has backup chlorination. It is rarely used but it's available. Thank you, and apologies on the delayed response. Best regards, Amanda AQUA Amanda Berger Director, Environmental Compliance Aqua North Carolina 202 Mackenan Court; Cary, NC 27511 4) From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Thursday, April 6, 2023 7:52 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: [EXTERNAL] Draft Permits - Hawthorne WWTP (NC0049662) and Wildwood Green (NC0063614) CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Attached are the draft permit renewals for these two WWTPs. These permits are going to public notice as drafted. Please review and let me know if you have any questions or comments. On the Wildwood Green WWTP could you verify whether or not there is backup disinfection (Chlorine). There has been some language in the permit to include TRC limits if chlorine is used and discuss temporary disinfection. Backup disinfection was not mentioned in the application though. If this is not the case then we can remove that reference. Please respond to this email to let me know that you received the two permit files and were able to read, download and print the files for your records. fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director MEMORANDUM NORTH CAROLINA Environmental Quality April 4, 2023 To: Shawn Guyer and Catherine Hadidon NC DEQ / DWR / Public Water Supply Raleigh Regional Office From: Bradley Bennett BB Compliance and Expedited Permitting Unit Subject: Review of Draft NPDES Permit NCO063614 Wildwood Green Subdivision WWTP Wake County Please indicate below your agency's position or viewpoint on the draft permit and return this form by May 4, 2023. If you have any questions on the draft permit, please contact me via e-mail [bradley.bennett@ncdenr.gov]. RESPONSE: (Check one) Concur with the issuance of this permit provided the facility is operated and maintained Fv_1 properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. F-1 Concurs with issuance of the above permit, provided the following conditions are met: F-1 Opposes the issuance of the above permit, based on reasons stated below, or attached: Signed Date: 04/19/2023 D "I� North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 NOfiTH CAROL.INA - Ueon�mtd,imnmnulousi� /'� 919.707.9000 Bennett, Bradley From: Guyer, Shawn Sent: Wednesday, April 19, 2023 5:09 PM To: Bennett, Bradley Cc: Hadidon, Catherine E Subject: RE: Draft Permits for Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Attachments: 2023-04-19 NCO049662_PWS Memo-2023 -signed.pdf, 2023-04-19 NCO063614_PWS Memo-2023 -signed.pdf Thanks Bradley. See attached. Shawn Shawn F. Guyer, P.E. Deputy Section Chief - Technical Services Branch Head Division of Water Resources, Public Water Supply Section North Carolina Department of Environmental Quality Office: (919) 791-4299 1 Mobile: (919) 605-6016 Shawn.Guyer@ncdenr.gov DE " 7'� ` IQ 10� NORTH CAROLINA - Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, April 10, 2023 2:07 PM To: Hadidon, Catherine E <catherine.hadidon@ncdenr.gov> Cc: Guyer, Shawn <shawn.guyer@ncdenr.gov> Subject: Draft Permits for Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Hey Catherine, Here area couple of draft NPDES Permit renewals for your review and comment. Let me know if you have any questions. I have included the Fact Sheets. Shawn -congratulations on the new job. I just saw the email. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben netto-)ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Kinney, Maureen Sent: Tuesday, April 11, 2023 8:42 AM To: Bennett, Bradley Subject: RE: Needs Reclassification: Drafts - Wildwood Green (NC0063614) and Hawthorne (NC0049662) No, sorry Bradley. That was my goof. Thanks for checking back. Ma A.re *v K U' q V eY NC DEQ - Division of Water Resources Wastewater Operator Certification 919-707-9038 From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Tuesday, April 11, 2023 8:39 AM To: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Cc: Weaver, Charles <charles.weaver@ncdenr.gov>; Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Subject: RE: Needs Reclassification: Drafts - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Maureen, There was discussion about the classification in the permit files for each of these. There is a brief discussion of this in my Fact Sheets. For Hawthorne there was a January 2000 letter in the file from DWQ that classified the system as Class II. For Wildwood Green there was discussion about the proper classification in the 2008 permit renewal. Ultimately it was given Class II status instead of Class III. I can't remember if there was a letter in the file on this one or not. I'm in the office today and did not bring the files for these but I'll check back through about that and get back to you. Is there anything that has happened recently that would change these to Class II? Thanks M9. From: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Sent: Tuesday, April 11, 2023 8:26 AM To: Bennett, Bradley <bradley.ben nett@ncdenr.gov> Cc: Weaver, Charles <charles.weaver@ncdenr.gov>; Manuel, Vanessa <vanessa.manuel@ncdenr.gov>; Cory.Larsen@ncdenr.gov Subject: Needs Reclassification: Drafts - Wildwood Green (NC0063614) and Hawthorne (NC0049662) These both appear to be WW-II in BIMS but should be WW-III. Cory/Vanessa - does RRO concur? If so, I'll draft letters to the permittee. Thanks all, Maureen Ma,&we aw K 6nvtey NC DEQ - Division of Water Resources Wastewater Operator Certification 919-707-9038 From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Monday, April 10, 2023 7:27 AM To: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Subject: Drafts for Review - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Hey Maureen, Here are two draft permit for your review. Both are Aqua facilities. Let me know if you have any comments. Thanks Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Bennett, Bradley Sent: Monday, April 10, 2023 7:36 AM To: Zhang, Cheng Cc: Manuel, Vanessa Subject: Permits to Notice - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Attachments: NC0063614_Draft Permit and Cover Ltr_2023.pdf; NC0063614_Fact Sheet Binder_ 2023.pdf; NC0049662_Fact Sheet Binder_2023.pdf, NC0049662_Draft Permit and Cover Ltr_2023.pdf Hey Cheng, Just wanted to pass along that these two permits have gone to notice. I know you had indicated some comments on the components list. I had responded to your last email to try and get clarification on those changes since it looked like you hadn't attached the file where you made the changes. Even though that didn't get in the drafts we can make appropriate changes in the final permits. Thanks for your help with these. fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Pearce, Joseph R <JRPearce@aquaamerica.com> Sent: Wednesday, March 15, 2023 12:58 PM To: Bennett, Bradley; Berger, Amanda A Cc: Lambeth, Robyn E; Krueger, Robert D Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Bradley, Thanks for the info. I was concerned that the ultra low ammonia tox limits may become a matter of conflict. Joe Joseph Pearce PE CFM Chief of Operations and Engineering Aqua North Carolina, Inc. 202 MacKenan Court Cary, North Carolina 27511 0:919.653.6964 F:919.460.1788 From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, March 15, 2023 12:31 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com>; Pearce, Joseph R <JRPearce@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Thanks for the updated info and looking into the DMR issues. On the Ammonia/WET testing issue I guess I should have mentioned a few other pieces. We had another renewal (Briarwood I think) that noted the Division is implementing updated Ammonia criteria that is based on EPA input that we can no longer use action levels to replace chemical limit requirements. In the past we had allowed people to pick adding toxicity over more stringent ammonia limits. We can no longer do this in our permits and have to use the more stringent chemical limit requirements. So, I think we will have to implement the required ammonia limits. Looking at the data from the previous permit cycle and using the proposed limits (2/10 — summer and 4/20 -winter) it looks like your facility would not have had any limit violations. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, March 14, 2023 5:29 PM To: Bennett, Bradley <bradley.ben nett@ncdenr.eov> Cc: Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com>; Pearce, Joseph R <JRPearce@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Hi Bradley, The DMR's are generated by our compliance software. For programming purposes, it lists the annual loads monthly. I have advised the operator to remove that column moving forward. The monthly loads for each facility is correct. Please ignore the annual loading calculations for each facility. Operations will be revising the December DMRs to include the annual loading requirements for Wildwood Green. Hawthorne appears correct on my end, but I have also asked they verify prior to your review of that facility. With respect to the WET requirement, given the information regarding the ammonia limit, Aqua is requesting rescission of the request to remove the WET testing requirement. Thanks, Amanda From: Pearce, Joseph R <JRPearce@aquaamerica.com> Sent: Tuesday, March 14, 2023 3:53 PM To: Berger, Amanda A <AABerger@aquaamerica.com>; Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs Good Afternoon Bradley, Staff are reviewing the DMR issue. I trust they will have it figured out in a day or so, and then will file amended DMRs. Joe 'A'4 'RIP ###r t ka* Joseph Pearce PE CFM Chief of Operations and Engineering Aqua North Carolina, Inc. 202 MacKenan Court Cary, North Carolina 27511 0:919.653.6964 F:919.460.1788 000 From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Tuesday, March 14, 2023 3:44 PM To: Bennett, Bradley <bradley.ben nett@ncdenr.eov> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Krueger, Robert D <RDKrueger@aquaamerica.com> Subject: RE: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs Hi Bradley, Doing well. Hope you are! Answering the first 2 questions. I will need to work with operations to review the others. The address listed on the application is the address listed on prior permits. See below. a. When I searched for 1899 Baileywick, the address is not either listed or it is not the WWTP. Looking at old aerials, it appears that Gleneagles Drive should have been extended and utilized as the entrance to the WWTP; however, it is not. Entrance is off of Baileywick at intersection with Old Creedmore Rd. I cannot locate a street address for either Baileywick or Gleneagles. Upper Barton — Mistype from Hawthorne. Yes, its Lower Barton. AQUA North Carolina, Inc. i erebyauthorized to discharge wastewater from a facility located at the Wild ood Green Subdivision WWTP Gleneagles Drive Northwest of Raleigh Wake County receiving waters designated as an unnamed tributary to Lower Barton Creek in the Meuse River Basin Thanks, Amanda From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Tuesday, March 14, 2023 11:30 AM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Pearce, Joseph R <JRPearce@aquaamerica.com>; Lambeth, Robyn E <RELambeth@aquaamerica.com>; Ison, Laurie T <LTlson@aquaamerica.com> Subject: [EXTERNAL] Permit Renewals for Wildwood Green (NC0063614) and Hawthorne (NC0049662) WWTPs CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Hope you are doing well! I just wanted to touch base on the Wildwood Green and Hawthorne permit renewals. I am currently working on the permit renewal reviews for each of these facilities. Since they are connected with the nutrient loading requirements I want to complete and notice them at the same time. I have gone through the Wildwood Green renewal and started on Hawthorne. I had a couple of issues to run by you guys based on where I'm at currently. I may have additional issues as I work through the Hawthorne renewal but wanted to go ahead and send these along. • On the Wildwood Green application, you indicate the facility address as Gleneagles Drive but in our system, it shows as 1899 Baileywick Road. Could you verify the location for us. If it is Gleneagles is there an address number as well? • The Wildwood Green application indicates the discharge is to Upper Barton Creek, but it appears that our records from before are accurate in showing discharge to UT to Lower Barton Creek. • Wildwood Green submitted a DMR correction for your July 2022 data submittal. The correction was entered in eDMR in January 2023. The data was certified in the eDMR system but was never submitted. The data needs to be Submitted in eDMR before the correction can be processed and the data updated. • For both Wildwood Green and Hawthorne, it appears that your monitoring data for nutrient loads is being reported inaccurately. Your permits require submittal of monthly loads for TN and TP (QM600 & QM655) as well as an annual load for each (QY600 & QY655). Your DMRs show that you are reporting the QY values each month and reporting the same values as the monthly (QM) values. You should be reporting the QM values monthly and the QY values only in the December monitoring report for each year showing the total annual load. • For the Hawthorne permit you are also required to report combined annual nutrient loading for the Wildwood Green and Hawthorne facilities using a separate outfall. Looking at the data it appears that you may not have submitted this annual load for 2021 or 2022. Please check this and make the corrections if needed. • For Wildwood Green you had requested review of WET testing requirements for potential removal from the permit. It does appear that we will be able to grant this request and remove WET requirements. Please note that with this change we will also update the ammonia limits in your permit. This will result in lower limits for this parameter. • 1 have attached Contact Information downloads from our system for each of the facilities. Please review this information and let us know of contact corrections that should be made and any contacts that should be removed, etc. • You might also hear from Raleigh Regional Office staff on the monitoring issues noted above. As with previous permits over the last few years, I will plan to submit drafts and the final permit do you electronically unless you request hard copies. Thanks for your attention to these requests. I'll be back in touch if there are other issues as I continue my review. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Zhang, Cheng Sent: Tuesday, March 14, 2023 9:49 AM To: Bennett, Bradley; Manuel, Vanessa Cc: Goss, Stephanie Subject: RE: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Yes, please let them know they need to complete the submission, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhang(dncdenr.gov 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Tuesday, March 14, 2023 9:46 AM To: Zhang, Cheng <cheng.zhang@ncdenr.gov>; Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Cc: Goss, Stephanie <stephanie.goss@ncdenr.gov> Subject: RE: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Cheng, On the July DMR for Wildwood Green, I think they did enter a corrected DMR in January 2023, but it never actually got submitted in the eDMR system. They certified it so you can see it in eDMR but because they never submitted it the data never made it into the system and got pushed to BIMS. I can talk with them about that issue if you want. [37 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.ben nettat ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: Zhang, Cheng <cheng.zhang@ncdenr.eov> Sent: Tuesday, March 14, 2023 9:40 AM To: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Cc: Goss, Stephanie <stephanie.goss@ncdenr.gov>; Bennett, Bradley <bradley. bennett@ncdenr.gov> Subject: RE: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Bradley is correct, Aqua needs to report monthly TN (QM600) TP (QM665) loads each facility's DMR, and only report the combined annual TN (QY600) and TP (QY665) on Hawthorne's December DMR (Permit Conditions Part I A(3). C.), and they have been doing that (I think they reported the combined loads on Hawthorne's December DMRs) , I checked their 2022 data, the final numbers were not correct according to my calculation though, still well less that the annual TN and TP limits. I will ask Aqua to amend Wildwood Green's July 2022 DMR (QM600 and QM665 were way off because total monthly flow was calculated wrong) and check their annual load numbers, and also let them they only need to report annual loads on Hawthorne's December DMR. Please let me know if you have any questions, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhang(a�ncdenr.gov 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Sent: Monday, March 13, 2023 3:35 PM To: Zhang, Cheng <cheng.zhang@ncdenr.gov> Cc: Goss, Stephanie <stephanie.goss@ncdenr.gov>; Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: FW: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Cheng, Please see Bradley's email below and assist him with his questions. Thanks, Vanessa E. Manuel Assistant Regional Supervisor Division of Water Resources — Raleigh Regional Office Department of Environmental Quality 919 791-4232 Office; 919 817-1256 Mobile vanessa.manuel(cD-ncdenr.gov Physical: 3800 Barrett Drive, Raleigh, NC 27609 Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628 K-- - Z- -�.`�Nlothing Compares , Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Goss, Stephanie <stephanie.goss@ncdenr.gov> Sent: Monday, March 13, 2023 3:13 PM To: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Subject: FW: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Vanessa, Can you please assist Mr. Bennett with his questions or concerns. Thanks and hope you had a nice weekend. Stephanie Z. Goss 401 & Buffer Permitting Supervisor Division of Water Resources 512 N. Salisbury Street Raleigh, NC 27620 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Wednesday, March 8, 2023 9:37 AM To: Goss, Stephanie <stephanie.goss@ncdenr.gov> Subject: Questions on Aqua Facilities - Wildwood Green (NC0063614) and Hawthorne (NC0049662) Hey Stephanie, I am currently reviewing the permit renewals for these two facilities. They have bubble permits that tie the two together with TN and TP loads. I noticed that you recently inspected the Hawthorne facility so I thought I'd reach out about a couple of issues monitoring wise on these two. I'm not sure if you are familiar with the Wildwood Green facility or not but thought I'd check. On their monitoring I just wanted to verify that what I think I'm seeing is correct. Sometimes I miss some things on the reported data and you guys help to straighten me out! So before I comment to Aqua I want to run this by someone in the regional office. For both of these facilities they are reporting annual load numbers for TN and TP (QY600 and QY665) on a monthly basis. Most months they are reporting the same number in the QY data as the monthly TN and TP (QM6OO and QM665) load values. I think they should only be reporting the QY values in December? Looks like in December they often are reporting a different QY value that seems to reflect an annual number. Also, for the Hawthorne plant it looks like they haven't submitted their Combined Total TN and TP annual values for 2021 or 2022. These are supposed to be submitted under a different outfall number (CO1). Maybe I'm mossing something on these? Thanks for any input on these. Let me know if you have any other comments about these two renewals. MM Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennettC@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Bennett, Bradley From: Moore, Cindy Sent: Tuesday, February 28, 2023 5:43 AM To: Bennett, Bradley; Manuel, Vanessa; Nicholson, Molly Subject: Re: Permit Renewal for Wildwood Green WWTP - NCOO63614 This is consistent with our tox strategy. With this being a domestic facility and having a consistent record of passing their tox then the tox can be removed. We do have one domestic facility that still has a tox in the permit but it is monitoring only. Town of Parkton has not consistently passed their tox. I would be in agreement to remove the tox requirement for Wildwood Green. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, February 27, 2023 4:06 PM To: Manuel, Vanessa <vanessa.manuel@ncdenr.gov>; Nicholson, Molly <molly.nicholson@ncdenr.gov> Cc: Moore, Cindy <cindy.a.moore@ncdenr.gov> Subject: Permit Renewal for Wildwood Green WWTP - NCOO63614 Hey Guys, I am working on the permit renewal for this permit and had a question about Tox for this one. Aqua has asked if they can have tox removed from the permit. For these domestic dischargers we have been looking at removing tox where it was included in the past in leu of ammonia limits. This is in keeping with EPA's call on these types of limits and our need to use the chemical requirements (2016 Memo). For this one in particular they had asked a number of years ago to remove tox and go with increased ammonia limits, but in previous reviews we had found that they were failing tox and there was no correlation with high ammonia numbers. Looking at the most recent data it looks like it has been quite a while since they failed a tox test. We are considering removing tox and giving them lower ammonia. How do you guys feel about that change. Relevant page from most recent tox results is included. Vanessa, If you guys have any other comments on this one please let me know about those as well. This is a bubble permit with Hawthorne WWTP (NCOO49662) so I may pick that one up also and try and review these two together. So let me know if you have any input on Hawthorne as well. Thanks No Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3692 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws Whole Effluent Toxicity Testing and Self Monitoring Summary WestPointStevens-Wagram WWTP NC0005762/001 County: Scotland Ceri7dPF Begin: 11/1/2014 chr lim: 9% @ 7MGD NonComp: Single J F M A M 2019 H H 2020 H H Whiteville-Whitemarsh WWTP NCO021920/001 County: Columbus Ceri7dPF Begin: 2/1/2021 chr lim: 50% NonComp: Single J F M A M 2019 Pass>100(P) - - Pass>100(P) - 2020 Pass - - Pass - 2021 Pass - - Pass >100(P) - 2022 Pass - - Pass >100(P) - Wildwood Green NCO063614/001 County: Wake Ceri7dPF Begin: 3/1/2018 chr lim: 72% NonComp: Single J F M A M 2019 - Pass - - Pass 2020 - Pass - - Pass 2021 - Pass - - Pass 2022 - Pass - - NR Wilkesboro Cub Creek WWTP NCO021717/001 County: Wilkes Ceri7dPF Begin: 2/1/2016 chr lim: 3.7%; if PF 6. NonComp: Single J F M A M 2019 - - >14.8(P) Pass - - 2020 - - Pass - - 2021 - - Pass >14.8(P) - - 2022 - - Pass - - Williamston WWTP NCO020044/001 County: Martin Ceri7dPF Begin: 2/1/2019 chr lim: 2.0 MGD @ 0 NonComp: Single J F M A M 2019 - - Pass - - 2020 - - Pass - - 2021 - - Pass >1.08(P) - - 2022 - - Pass - - Wilson -Hominy Crk WRF-Contentnea NCO023906/001 County: Wilson Ceri7dPF Begin: 3/1/2021 chr lim: 90% NonComp: Single J F M A M 2019 - Pass - - >100(P) Pass 2020 - Pass - - Pass 2021 - Pass - - Pass 2022 - >100 (P) Pass - - Pass Region: FRO Basin: LUM51 Feb May Aug Nov SOC JOC: 7Q30: 117 PF: 7.0 IWC: 9.0 Freq: Q J J A S O N H H Region: WIRO Basin: LUM58 Jan Apr Jul Oct 7Q10: 4.7 PF: 3.0 IWC: 50 Freq: Q J J A S O - Pass - - Pass - Pass - - Pass - Pass - - Pass - Pass - - Pass Region: RRO Basin: NEU01 Feb May Aug Nov 7Q30: 0.06 PF: 0.1 IWC: 72 Freq: Q J J A S O Pass - Pass Pass - Pass Pass - - Region: WSRO Basin: YAD01 Mar Jun Sep Dec 7Q30: 196 PF: 4.9 IWC: 3.72 Freq: Q l l A S O Pass - - Pass - Pass - - Pass - Pass >14.8(P) - - Pass >14.8(P) - Pass - - Pass - Region: WARO Basin: ROA09 Mar Jun Sep Dec 7Q10: 1170 PF: 2.4 IWC: 0.26 Freq: Q J J A S O Pass - - Pass - Pass - - >1.08(P) Pass - >1.08 (P) Pass - - Pass - Pass - - Pass - Region: RRO Basin: NEU07 Feb May Aug Nov 7Q30: 0.5 PF: 14.0 IWC: 97.37 Freq: Q J J A S O Pass - Pass Pass Pass SOC JOC: N SOC JOC: N Pass Pass Pass Pass SOC_JOC: N SOC JOC: N SOC JOC: N Pass Pass >100 (P) Pass >100 (P) Pass C C G D Pass Pass Pass >14.8 (P) Pass D Pass 0.76 (P) Pass Pass Pass IG Leizend: P= Fathead minnow (Pim)hales oromelas). H=No Flow (facilitv is active), s = Split test between Certified Labs Page 96 of 98 NH3/TRC WLA Calculations Facility: Aqua -Wildwood Green WWTP Permit No. NCO063614 Prepared By: Bradley Bennett Enter Design Flow (MGD): 0.1 Enter s7Q10 (cfs): 0.06 Enter w7Q10 (cfs): 0.13 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/1) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (UG/L) Upstream Bkgd (ug/1) IWC (%) Allowable Conc. (ug/1) Fecal Coliform Monthly Average Limit: (If DF >331; Monitor) (If DF<331; Limit) Dilution Factor (DF) <= Permitted Flow if Different from Design Ammonia (Summer) Monthly Average Limit (mg NH3-N/1) Design Permitted Design Permitted 0.06 s7Q10 (CFS) 0.06 0.1 DESIGN FLOW (MGD) 0.1 0.155 DESIGN FLOW (CFS) 0.155 17.0 STREAM STD (MG/L) 1.0 0 Upstream Bkgd (mg/1) 0.22 72.09 IWC (%) 72.09 24 Allowable Conc. (mg/1) 1.3 < 1 MGD Policy Applies Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Design Permitted Design Permitted w7Q10 (CFS) 0.13 200/100mi DESIGN FLOW (MGD) 0.1 DESIGN FLOW (CFS) 0.155 STREAM STD (MG/L) 1.8 1.39 Upstream Bkgd (mg/1) 0.22 IWC (%) 54.39 Allowable Conc. (mg/1) 3.1 Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/l, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals) 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed * By Policy dischargers < 1 MGD get limits no lower than 2 & 4 due to BAT * From 2B .0404(c) - Winter Limits can be no less stringent than 2 times the summer limits Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) Bennett, Bradley From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Wednesday, August 17, 2022 12:58 PM To: Bennett, Bradley Cc: Hennessy, John Subject: RE: [External] Salem Quarter and Briarwood CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Thank you Bradley. From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Wednesday, August 17, 2022 11:25 AM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Hennessy, John <john.hennessy@ncdenr.gov> Subject: RE: [External] Salem Quarter and Briarwood CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Amanda, Just wanted to touch base with you on this issue with Wildwood Green. Looks like this one is in-house for renewal (just came in). We will review this issue as part of the permit renewal. :: Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Email: bradley.ben nett(o)ncdenr.gov Email correspondence to and from this address may be subject to public records laws From: Hennessy, John <iohn.hennessy@ncdenr.gov> Sent: Thursday, August 11, 2022 3:37 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Cc: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Subject: Re: [External] Salem Quarter and Briarwood Given that it is 100 domestic, it may not need Tox. I reviewed the last fact sheet. It was mute on the subject. Given that this is an old permit, I have copied the oldest person I know (Bradley) on this email to see if he can review the file further back to see when that was added and what the rationale was at the time. By the way, I will pay for the old joke. We will get back to soon. John E. Hennessy Environmental Supervisor II Compliance and Expedited Permitting Unit NC DEQ/ Division of Water Resources aohn.hennessy@ncdenr.gov 919-707-3615 (office) Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Monday, July 25, 2022 12:47 PM To: Hennessy, John <iohn.hennessy@ncdenr.gov> Subject: RE: [External] Salem Quarter and Briarwood CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. NC0063614 From: Hennessy, John <iohn.hennessy@ncdenr.gov> Sent: Monday, July 25, 2022 12:45 PM To: Berger, Amanda A <AABerger@aquaamerica.com> Subject: Re: [External] Salem Quarter and Briarwood CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. What is the permit number? John E. Hennessy Environmental Supervisor II Compliance and Expedited Permitting Unit NC DEQ/ Division of Water Resources 9ohn.hennessy@ncdenr.gov 919-707-3615 (office) Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Monday, July 25, 2022 9:27 AM To: Hennessy, John <iohn.hennessy@ncdenr.gov> Subject: RE: [External] Salem Quarter and Briarwood CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. John — Reviewing the Wildwood Green permit application, and question for you... Why does Wildwood have Chronic Tox requirements? Is it basin specific? Appreciate any information you can provide. Thanks, Amanda 3 From: Hennessy, John <john.hennessy@ncdenr.gov> Sent: Friday, July 22, 2022 10:10 AM To: Berger, Amanda A <AABerger@aquaamerica.com> Subject: Re: [External] Salem Quarter and Briarwood CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Thank for the update Amanda. John E. Hennessy Environmental Supervisor II Compliance and Expedited Permitting Unit NC DEQ/ Division of Water Resources aohn.hennessy@ncdenr.gov 919-707-3615 (office) Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records law and may be disclosed to third parties. From: Berger, Amanda A <AABerger@aquaamerica.com> Sent: Thursday, July 21, 2022 11:22 AM To: Hennessy, John <john.hennessy@ncdenr.gov> Subject: [External] Salem Quarter and Briarwood CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Hi John — 4 Following up regarding Salem Quarter and Briarwood. I forwarded the details of our conversation to operations and engineering. I did locate where we started a project in 2019 to address the bar screen at Briarwood, but somehow it did not get awarded. We have a compliance management tracking system that was brought online in 2020, and both projects have been assigned and will be tracked to ensure this does not occur again. Engineering is reaching out to contracted engineer firms for design, and I should have additional information in a couple of weeks. With respect to auditing other locations, we already have a permit review process in our Central and Eastern regions have requested the Western Region's assistance in developing a similar model. The Kernersville office has a new supervisor, and he and I have scheduled time to visit each of his facilities to begin the process. I will be in touch with additional information as its available. Thank you, Amanda Berger Director, Environmental Compliance Aqua North Carolina 202 Mackenan Court; Cary, NC 27511 0:919.653.6965 M:910.773.0406 0()