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HomeMy WebLinkAboutNC0088684_correspondence_20230621Weaver, Charles From: Sledge, Bob Sent: Wednesday, June 21, 2023 12:52 PM To: Scott Bradley Cc: Weaver, Charles; Bell, Wes Subject: RE: [External] reverse osmosis system Hi Scott, Thank you for your patience and for reaching back out to me by email and by phone. I spoke with staff in the Mooresville Regional Office this morning about the situation you've described to me. Here are some points for you to consider as you make your decisions about the future use of the RO system and the NPDES permit. The decision to use or not use the RO system and/or the NPDES permit is entirely up to the DSBG staff. If you are not going to use the RO system, and as a result, create no wastewater, you can request a monitoring and reporting suspension for the permit. This assumes a long term situation where the system is not able to create a wastewater discharge. During the time period the suspension is in effect, operator visitation would also not be required. However, DSBG would be responsible for payment of the annual fees associated with the permit and would be required to apply for renewal of the permit in accordance with its terms. If you see this as a more permanent situation, you could request rescission of the permit (i.e., giving up the permit or having it done away with). To request rescission, you would need to demonstrate that the discharge has been eliminated. You had mentioned DSBG may not wish to remove the RO system itself, in case future managers may wish to use it again. In that case, cutting the pipe from the wastewater reservoir to the outfall piping would adequately demonstrate the discharge had been eliminated. As we discussed, the issuance of a NPDES permit for this type of discharge has been something of an oddity and has created a unique set of headaches over the years. If the permit is rescinded and in the future you might desire permit coverage for a similar discharge, that circumstance would be treated as a brand new application and there is no guarantee that a permit would be issued for such a potential discharge. In either event, please let us know what your specific intentions in this matter are. I'd request that you reply to me and those copied on this email with your plans. If you wish to pursue a monitoring suspension, please provide us a description of how the potential for a discharge has been removed and how this will be a long term circumstance at the facility. If you wish to pursue permit rescission, please make an explicit request for rescission and describe how the discharge is being or has been permanently eliminated. Please provide photographs of the means used to eliminate the discharge. This should provide us with enough information to act upon the rescission request. Our staff would follow up with a site visit a later date to confirm the status. If my colleagues have any corrections to offer or other pertinent information to add, please feel free to join the discussion. Thanks again. Please feel free to call or reply if you have any questions. Have a great day. e Bob Sledge Environmental Specialist 11 Division of Water Resources — Water Quality Permitting Section North Carolina Department of Environmental Quality DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9tn Employee email addresses may look different, but email performance will not be impacted. 919-707-3602 bob.sledge(d_)deg.nc.gov (note new email address) 512 N. Salisbury Street 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Scott Bradley <bradley@dsbg.org> Sent: Tuesday, June 13, 2023 9:30 AM To: Sledge, Bob <bob.sledge@deq.nc.gov> Subject: RE: [External] reverse osmosis system 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. Bob This is Scott Bradley with Daniel Stowe botanical garden in Belmont we have not received anything from the Mooresville Regional Office regarding the removal of the reverse osmosis system can we go ahead and remove it. Scott Bradley Facilities Manager, Daniel Stowe Botanical Garden 704.829.1254 ® www.dsbg.org 0 bradleyC�Osbg.org ® 6500 South New Hooe Road. Belmont NC 28012 rf in From: Sledge, Bob <bob.sledge@ncdenr.gov> Sent: Wednesday, April 19, 2023 5:54 AM To: Scott Bradley <bradley@dsbg.org> Subject: RE: [External] reverse osmosis system Hi Scott, Thanks for getting in touch with me and sharing this news. As you move forward with removal of the RO system, I'd recommend keeping our Mooresville Regional Office (MRO) staff advised of developments. When the system has been removed and the wastewater discharge has ceased, you'll want to request that the NPDES permit be rescinded. MRO may wish to send one of its staff to the site to verify the situation before the permit is rescinded. At the present time, MRO (and all of the Division of Water Resources) is experiencing issues with depleted staffing levels. The person that last inspected your facility has taken another position in our organization; I'm not exactly sure who might be your best contact in that office. I'll forward your note to the acting supervisor and one of our senior staff members in the water quality programs within that office and ask them to reach out to you with additional guidance. If they should not contact you within the timeframe you need to get things done on your end, please feel free to contact me and I'll help coordinate things here. I hope you have developed a more worry -free way of keeping the plants and flowers looking so good. Best wishes to you in all your endeavors. :.. Bob Sledge Environmental Specialist II Division of Water Resources — Water Quality Permitting Section North Carolina Department of Environmental Quality 919-707-3602 bob.sledge(a ncdenr.gov 512 N. Salisbury Street 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Scott Bradley <bradley@dsbg.org> Sent: Tuesday, April 18, 2023 4:01 PM To: Sledge, Bob <bob.sledge@ncdenr.gov> Subject: [External] reverse osmosis system 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. Bob This is Scott Bradley with Daniel Stowe botanical garden in Belmont we have decided to remover the reverse osmosis system from the orchid conservatory with that been said do we need to let anyone know from the NC Division of Water Resources what we want to do. thanks Scott Bradley Facilities Manager, Daniel Stowe Botanical Garden ❑ 704.829.1254 ❑ www.dsbg.org ❑ bradley(@c1sbg.org ❑ 6500 South New Hope Road, Belmont NC 28012 ❑ ❑ ❑ Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official.