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Home My WebLink AboutNC0021156_correspondence_20091103WDES DOCUWENT SCANNIN& COVER SHEET NPDES Permit: NC0021156 Mount Holly WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: November 3, 2009 This document is printed on reuse paper -ignore any content on the resrerse side North Carolina Beverly Eaves Perdue Governor Mr. Robert C. Whitt Mayor, City of Mount Holly P.O. Box 406 Mount Holly, NC 28120 Dear Mayor Whitt: NCDENR Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director November 3, 2009 Subject: Mount Holly WWTP NPDES PermitNCO021156 Nutrient Limits Gaston County Dee Freeman Secretary The Division of Water Quality (Division) appreciates your concerns expressed in your letter dated September 29, 2009 regarding future nutrient limitations in your NPDES permit. My September 1, 2009 letter to the Town was meant as a only forewarning to the permitees on the Catawba River arm of Lake Wylie that the Division plans to incorporate nutrient limits into the next permits as the Division prepares to issue permits in the rest Catawba basin next year. We understand that the City has been actively evaluating future wastewater treatment options with Charlotte Mecklenburg Utilities, as well as the possibility of expanding your own plant. There is a good likelihood that these evaluations will not be concluded when your NPDES permit is up for renewal in 2010. The Division also recognizes the difficult financial times currently impacting all municipalities. We can assure you that the Division staff will work closely with the City during the permit renewal. Nutrient limitations will not take effect immediately-, rather, the City will be provided a sufficient compliance schedule to accommodate the City's projected wastewater expansion timelines. If you have any questions, feel free to contact me at 919-807-6309. Sincerely, e PouM Supervisor, Point Source Branch Cc: Eric Davis, Mount Holly City Manager James Friday, Mount Holly Utility Director MRO SWPS Central Files NPDES File NCO021156 1617 Mail Service Center, Ralegh. North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One Phone: 919-807-6300 k FAX: 919-807.64921 Customer Service: 1-877-62M748 NorthCarolina Internet www.nnity eA rality.org c _ �►�aturl it An Equal Opportunity 1 Affirmative Action Employer � �/ L "J Celmcf FJ-P,. NC0-D Z►►S( �pUNl, r R�1 � CITY of MOUNT HOLLY �J "' t N.0 /o dP ra61VeIJJP�CJ/ �P�Mi * rPnPwa/ UTu nEs DEPARTMENT 400 last Ceutml Avenue • Post pfiice Box 406 • Mount Holly, NC 28120 • 704-822-2939 0704-822-2933 Fax • w .mtholly.us October 8, 2009 NCDENR / DWQ Attn: NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 RE; Permit NC 0021156 Nutrient Limits Dear DENR; The City of Mount Holly (the City) received your letter dated September 1, 2009 regarding nutrient limits added to the 2010 NPDES Permit. The City of Mount Holly at this time would like to request an extension of seven years before nutrient limits are imposed on the NPDES Permit. The City is currently in negotiations with Charlotte Mecklenburg Utilities to build a joint regional Wastewater Treatment Plant. We have also started the preliminary work to expand our Wastewater Treatment Plant. However, it would seem very unlikely that either path taken would be in place within the next seven years. If you require any further information place feel free to contact me at any time. S' ly, t- ames Friday Utility Director City of Mount Holly Cc: Eric Davis, City Manager RECEIVED OCT 1 2009 DENR - WATER QUALITY POINT SOURCE BRANCH dMouhr9 OCITY of MOUNT HOLLY From the Office of the MBE C E IVE D Mayor Robert Whitt September 290i, 2090T 1 2 2009 Mr. Jeff Poupart Supervisor, Point Source Branch Division of Water Quality DENR - WATER OUALITY POINT SOURCE BRANCH North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Dear Mr. Poupart: I am writing in response to your letter dated September 1 % 2009 concerning the City of Mount Holly's 2010 permit renewal, and the implementation of nutrient limits on the City of Mount Holly. Please accept this letter as the City of Mount Holly's official objection to these nutrient limit requirements. As you may know, our City Manager, Consulting Engineer, and Utility director have had numerous meetings with your staff concerning the status of our waste treatment plant over the last two years. They have raised the question many times about the possible nutrient limit requirements on the City of Mount Holly. Each time that the issue was raised, we received the same answer: "As long as the City of Mount Holly does not expand its waste treatment facility, then nutrient limits will not be imposed." Your letter directly contradicts this. Secondly, please understand that the City of Mount Holly supports environmental advocacy and protection. However the economic impact of this unfunded mandate will be extremely burdensome to our ratepayers. Preliminary estimates indicate that implementation of these nutrient limits would cost Mount Holly utility customers $30 million. This will be an incredible burden for our residents and corporate citizens to bear in these difficult financial times. Third, your letter indicates that the Division of Water Quality is evaluating the entire Catawba River Basin. However, after discussing the matter with your staff, this review is only pertaining to waste treatment plants tied to Lake Wylie; specifically, the City's of Belmont and Mount Holly. If the City of Mount Holly is going to be required to meet these new standards, then we would expect all waste contributors in the Catawba River Basin to comply as well. Finally, we recognize our inclusion in the Lake Wylie TMDL plan that was approved by the U.S. EPA in 1996. However, our belief is that the plan called for nutrient limit reductions upon expansion of existing facilities. Our current waste treatment facility is A operating at approximately 50% of its approved capacity. We understand that the nutrient limit loads for Nitrogen and Phosphorous are already stipulated for Mount Holly when we expand our existing facility. We do recognize our responsibility to meet these limits only when an expansion of the existing facility is undertaken, and ask that these requirements be delayed until an expansion is required. I appreciate your time in considering our objections. I look forward to your response. Robert C. Whitt Mayor, City of Mount Holly Cc: Governor Beverly Eaves Perdue Mr. Richard Boyce, Mayor of Belmont Mr. David Hoyle, N.C. State Senator Wil Neuman, N.C. House of Representatives Dee Freeman, DENR Secretary Beverly Eaves Perdue Governor Y 'Ir • 4 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director September 1, 2009 Mr. Eric Davis City Manager, Mount Holly P.O. Box 406 Mount Holly, NC 28120 Subject: Nutrient Limits/2010 Permit Renewal NPDES Permit NCO021156 City of Mount Holly WWTP Gaston County Dear Mr. Davis: Dee Freeman Secretary The Division of Water Quality (the Division) has been evaluating permitting requirements for the Catawba River Basin, which is the next basin up for NPDES permit renewals. The Division notes that the subject NPDES permit expires February 28, 2010, and that this permit still does not contain effluent nutrient limits (TN, TP) as prescribed by the Lake Wylie TMDL approved by the U.S. EPA in February 1996. The 1996 TMDL states that the nutrient allocations were "scheduled to be implemented over the next several years". Given the fact that this is the only TMDL that is still not fully implemented, the Division plans to incorporate nutrient limitations into your 2010 permit renewal in accordance with the approved TMDL. If you would like to discuss this pending permit requirement, please contact Tom Belnick at 919-807- 6390. Sincerely, Jeff Poupart Supervisor, Point Source Branch Cc: MR0 SWPS Modeling/TMDL Unit NPDES File Central Files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location. 512 N. Salisbury St. Raleigh, North Carolina 27604 One Phone: 919-807-6300 S FAX: 91M07-6492 i Customer Service: 1-877-623-6748 NOrthCarolina Internet: w►w+.ncwaterquality.org An 'cqua! Opportunily . Aff Naturallyrma6ve Action Emp"r