NC0025453_Comments_Draft_Permit_Mod_20200824

From: Guyer. Shawn
To: Templeton. Mike
Cc: Walter. Carmalin
Subject: NPDES RE: permit mod, Clayton, NCO025453
Date: Monday, August 24, 2020 4:49:54 PM
Attachments: 25453 draft nutr mod+map 20200717.pdf
25453 factsheet - draft permit 20200717.pdf
25453 cov Itr - draft permit 20200710.pdf
Mike,
I concur with the issuance of this permit provided the facility is operated and maintained properly,
the stated effluent limits are met prior to discharge, and the discharge does not contravene the
designated water quality standards.
Shawn F. Guyer, P.E.
Regional Engineering Supervisor
Raleigh Regional Office
Public Water Supply Section
Division of Water Resources
Department of Environmental Quality
919 791-4299 direct
919 791-4200 main
Shawn. GuyerQncdenr.gov
Physical: 3800 Barrett Drive,
Raleigh NC 27609
Mailing: 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: Templeton, Mike
Sent: Wednesday, July 22, 20201:17 PM
To: Guyer, Shawn <[e-mail]>
Subject: permit mod, Clayton, NC0025453
Attached for your review are the draft permit, fact sheet, and cover letter for modification of the
Town of Clayton permit, NC0025453. The facility discharges to the Neuse River, which is classified as
WS-IV NSW CA waters at the point of discharge. The permit is scheduled for public notice on or
about July 24th, and comments will be due by August 24th. Let me know if you have any questions or
need additional information.
— Mike T

Michael E. Templeton, P.E.
Wastewater Permitting Section
Division of Water Resources
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925V)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3603
mike.temoleton (@ncdenr.eoy
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on
staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties. r4

From: Barrett Jenkins
To: Templeton. Mike
Subject: [External] Clayton Permit Public Notice Draft
Date: Friday, July 24, 2020 1:46:03 PM
Attachments: Town of Clayton Draft Permit 7222020r.odf
Mike,
I just wanted to mention there's language in the draft permit on notice regarding the units and
longevity of the nutrient offset credits that might be confusing. The permit and fact sheet at times
suggest the credits might only be good for 30 years. We would like the credits to be considered
permanent, similar to allocation and not limited to 30 years of use. I wanted to make sure that was
the intent and check in to see if we needed to do anything to "convert" them.
Previously it had been discussed with other people at DWR that the credits are currently in the unit
of Ibs in the amount of 715,858.18 lbs. The new rule allows these annual or term credits to be
converted to permanent credits in the unit of Ibs/year by dividing by 30 and this would be
appropriate for Clayton's situation:
"15A NCAC 028.0703 (f)(8)
Nutrient offset credits that were approved prior to the adoption of this Rule may make application to
be reclassified. The Division shall approve the application associated with any nutrient offset project
to reclassify credits as permanent that meet the requirements for permanent credits at the time of
the application to be reclassified. Other nutrient offset credits that were approved prior to the
adoption of this Rule or that were conditionally approved pursuant to a mitigation banking
instrument or other agreement with DEQ prior to the adoption of this Rule, shall be considered term
credits and may be transferred between term and permanent ledgers at a ratio of 30 years of term
nutrient offset credit to one permanent nutrient offset credit."
Thanks,
Barrett Jenkins
Restoration Systems
512.230.0424

From: Merritt. Katie
To: Barrett Jenks
Cc: Templeton. Mike
Subject: RE: [External] Town of Clayton Draft Permit 7222020r (002).pdf
Date: Friday, July 24, 2020 2:12:01 PM
Hey,
So I remembered something. Applicant can buy the credits from RS-Flat Swamp, LLC in the units as
they are in the Statement Of Availability letter... but can be converted to permanent in the Permit by
DWR if necessary. Mike may have already made them permanent in the table for the Applicant, but
since they are purchased in Ids/yr over 30 years he had to state the credit in "real time" in the
factsheet.
I don't think there is an issue. Mike is on vacation until next week but he can shed some light on this
if necessary.
katie
From: Barrett Jenkins [mailto:[e-mail]]
Sent: Friday, July 24, 20201:16 PM
To: Merritt, Katie <[e-mail]>
Subject: [External] Town of Clayton Draft Permit 7222020r (002).pdf
FYI