NC0043532_LTR_20201124

STANLY COUNTY
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November 24, 2020
Mr. Corey Basinger
NCDEQ — Mooresville Regional Office
610 East Center Avenue Suite 301
Mooresville, NC 29202
RE: Amendment Request for West Stanly WWTP Special Order of Consent WQ S19-003
Dear Mr. Basinger:
By way of this letter, I would hereby request the following amendments be made to the Special Order of
Consent for the West Stanly Waste Water Treatment Facility SOC S19-003.
1. The construction contract has been executed with Haren Construction Company out of Etowah,
Tennessee and construction is underway. As part of the value engineering process it was agreed to
extend the construction contract from 12 months or 360 days to 15 months or 450 days. This
arrangement had verbal approval from the Mooresville Office and the contract and financing by NCDEQ-
DWI was approved. We would request an amendment to the SOC to document NCDEQ approval of the
time extension as noted.
2. It is our understanding in speaking with other utilities that are currently negotiating or have
executed an SOC agreement with NCDEQ that the discharged limits for BOD and Ammonia
concentrations were relaxed. As part of our negotiations we did request relaxed limits for the same
constituents but were informed that the assimilative capacity of the Rocky River, the primary discharge
stream was uncertain or reaching its limits. Because construction process may hinder our ability to stay
within the permitted limits for BOD and Ammonia, we would request consideration of the relaxed limits be
revisited with the following request:
BOD 5 Day April 1 — October 31 be increased from 9.0 mg/I to 18 mg/I and Weekly Average be
increased from 13.5 mg/I to 27 mg/I
BOD 5 Day November 1 — March 31 be increased from 18 mg/1 to 27 mg/I and Weekly Average
be increased from 27 mg/I to 54 mg/I.
NH3 as N April 1 — October 31 be increased from 3.0 mg/I to 6 mg/I and Weekly Average be
increased from 9.0 mg/1 to 18 mg/I.
NH3 as N November 1 — March 31 be increased from 6.0 mg/I to 12 mg/I and Weekly Average
be increased from 18 mg/I to 368 mg/I.
3. The Stanly County WWTP has a secondary permitted discharge into Long Creek, which is not
used except in the event of excessive flows. We would request that in calculating the discharge limits
Utilities Department, 1000 N. First Street, Suite 12, Albemarle, NC28001
Y/ 704.986.3686 www.stanlycountyncgov F/ 704.986,3711

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when this event occur that the daily sample not be considered a weekly or monthly event in the eDMR
reporting and subject to a violation for both discharge points..
Stanly County greatly appreciates your considerations of these amendments. It is our understanding the
State Office of NCDEQ is considering completing a comprehensive model analysis of the Rocky River to
determine its assimilative capacity at multiple points as it enters the Yadkin PeeDee. We would very
much advocate for this being done so as to provide more definitive guidance for all impacted utilities.
If you have any questions or concerns, please do not hesitate to contact me
Sincerely,
Duane Wingo
Stanly County Utilities Director
Cc: Tommy Gibbons — Stanly County
James W. Holland, PE — McKim and Creed
Utilities Department, 1000 N. First Street, Suite 12, Albemarle, NC28001
P/ 704.986.3686 www.stanlycountync..gov F% 704.986.3711