NCG560043_Other Correspondence_20210615

DocuSign Envelope ID:92FDEC45-622B-4B78-9ECA-0F6A24F0D73F
ROY COOPER , .--.
Governor Or e
JOHN NICHOLSON
interim Secretary ilk
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
6/15/2021
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
7018 1830 0001 8037 1752
Dwayne Patterson, Director
NC Division of Parks and Recreation
1615 Mail Service Center
Raleigh,NC 27699-1615
Subject: White Lake Alum Application
Town of White Lake
NPDES General Permit NCG560043
Bladen County
Dear Director Patterson:
It has come to the attention of the North Carolina Division of Water Resources(hereafter the
Division)that the Town of White Lake(hereafter the Town) intends to perform additional alum
treatments to White Lake.
Previous correspondence between the Division, the Town,and other stakeholders is summarized
below(dates provided are letter dates):
• April 11,2018: The Division allowed the Town to use their existing NPDES General
Permit NCG560043 for a one-time alum treatment of White Lake with monitoring and
public notification processes. The letter also stated that any request for retreatment(with
alum or any other in-lake treatment)would require an individual NPDES permit, which
may not be approved.
• April 26,2018: The Division reiterated the allowance of the Town to use their existing
NPDES General Permit NCG560043 for a one-time alum treatment of White Lake with
updated monitoring and public notification process requirements.
• May 4,2018: The Town commenced alum application to White Lake.
• May 8, 2018: The Division stated dead fish had been reported after commencement of
alum treatment to the lake,with numbers exceeding 1,000 and across multiple size
classes and species. The Division stated alum application should stop immediately and
not resume until notification from the Division.
• May 10,2018: The Division indicted the observed fish mortality may not have been a
direct result of the alum treatment and allowed the Town to resume alum treatment, with
dosage rate below 9.8 mg/L.
• May 15,2018:North Carolina State University(NCSU) found there were no indicators of
the long-term presence of poor water quality in White Lake to cause the fish kill, and that
it was possible a large number of fish in the lake suffered acute toxicity.
• June 11,2018: The North Carolina Wildlife Resources Commission (NCWRC)estimated
114,770 fish died in White Lake between May 4-9, 2018, with fish kill replacement costs
1
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699 I617
N�fil H C,AfdJ1.INA
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DocuSign Envelope ID:92FDEC45-622B-4B7B-9ECA-0F6A24F0D73F
totaling $634,132. An NCWRC report dated June 7,2018 was attached to this letter
which provided additional information on the study performed by NCWRC.
• April 16,2019: The Division reiterated application of alum to White Lake was approved
as a one-time event in 2018 under NCG560043 and that any subsequent requests for alum
1 application (or any other in-lake treatment) would require the North Carolina Division of
Parks and Recreation(as owner of White Lake)to apply for an individual NPDES permit.
The Division also stated the significant fish kill and loss of biomass that occurred
concurrent with the alum application to White Lake in 2018, along with additional
information that became available after,gave the Division significant concerns that alum
application to White Lake would result in water quality standard violations.
It is the Division's determination that an application for,and issuance of, an NPDES individual
permit is required before any alum application to White Lake. This rational is based on the
unique chemistry of White Lake, the potential for toxicity that would result in water quality
standard violations,the potential for alum residuals and aluminum hydroxide in the lake
sediments, and the loss of fish biomass observed in 2018. Therefore, any in-water discharges of
substances would be a violation of NCGS §143-215.1 and would be subject to enforcement.
In accordance with 15A NCAC 02H .0127(i),the Director of the Division of Water Resources
maintains the determination that an NPDES individual permit is required for any additional
discharge to White Lake. As White Lake is owned by the North Carolina Division of Parks and
Recreation,any permit applications for any additional discharges to White Lake must be
acquired by Parks and Recreation.
Applications for individual permits can be found on the Division's website at:
https://deq.nc.gov/about/divisions/water-resources/water-quality-permitting/npdes-
wastewater/npdes-permitting-process. If you have questions concerning this,please contact John
Hennessy at 919-707-3615,or via e-mail [[e-mail]].
Sincerely,
EiDocuSigned
by:
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8328B44CE9EB4A1...
S. Daniel Smith, Director
Division of Water Resources
cc: NPDES Files(Laserfiche)
Trent Allen,Fayetteville Regional Office
Mark Brantley,Fayetteville Regional Office
Julie Grzyb,NC Division of Water Resources
Jeff Poupart,NC Division of Water Resources
Brianna Young,NC Division of Water Resources
Chris Johnson,NC Division of Water Resources
Eric Moms,NC Division of Water Resources
Rob Emens,NC Division of Water Resources
Mayor Goldston Womble,Jr.,Town of White Lake