NC0083275_More Informtion (Requested)_20200527

DocuSign Envelope ID: 61FBI 682-8C07-4342-897E-299260FC8243
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Janet Mason, City Manager
Town of Forest City
P.O. 728
Forest City, NC 28043
Dear Ms. Mason:
NORTH CAROLINA
Environmental Quality
5/27/2020
Subject: Request for Additional Information
Draft NPDES Permit NCO083275
Harris Plant WWTP
Rutherford County
During the mandatory 30-day public comment period, the Division received public comments.
Following the public comment period, the Division reviewed all pertinent comments on your draft
permit. One comment noted that no Authorization to Construct (ATC) permit has been applied for
since the previous permit was issued.
According to 15A NCAC 02H .0 13 8 (a), for ATC permits the following is required:
(a) Required. After an NPDES permit has been issued by the Division of Environmental
Management in accordance with this Section, construction of wastewater treatment
facilities or additions thereto shall not begin until final plans and specifications have been
submitted to and an Authorization to Construct has been issued to the permittee by the
Division of Environmental Management. If an Authorization to Construct has not been
applied for in accordance with the requirements of the NPDES permit during the term of
the permit, the permit will be considered void upon expiration and future actions will be
considered as a new application.
During the last renewal of this permit, DWR determined that the facility did not have adequate
treatment capabilities. The permit, issued on November 24, 2014, required approval of a new
Authorization to Construct and submittal of a signed engineering certificate before any discharge of
wastewater. Review of our records indicated that an ATC Permit has not been received since this
permit was last renewed. Without an ATC Permit, in accordance with 15A NCAC 02H .0 13 8(a),this
permit application will be processed as a new application.
The term "New" is defined according to 15A NCAC 02H .0103 (16) as follows:
(16) "New", with respect to implementing the NPDES permitting program, means:
(a) Proposed facilities that do not have a NPDES Permit nor have any facilities constructed.
(b) Facilities which physically exist, however are illegally constructed, i.e., no required
agency approvals.
(c) Facilities which have received an NPDES Permit and have received an Authorization to
Construct but have not begun significant construction of any wastewater treatment facilities
within the term of the current permit.
DNorth Carolina Department of Environmental Quality Division of Water Resources
E Q��
_ 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
Department of Emimnmental Wality /`� 919.707.9000

DocuSign Envelope ID: 61FBI 682-8C07-4342-897E-299260FC8243
Any increases in treatment plant hydraulic capacity, which has not received an
Authorization to Construct shall be considered new and new effluent limitations and other
requirements, if applicable, would be imposed for the entire facility.
In order to process this permit renewal application as a new permit application, the Division requires
an Engineering Alternatives Analysis (EAA). Given the many years passed since any alternatives to a
direct discharge have been evaluated for this facility, an updated EAA would be prudent. Economic
costs, best available technology, and availability of a connection to a POTW may have changed over
time.
The Division has reviewed your application and public comments for the draft permit. To enable us to
complete our review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 21-1.0105, please provide
additional or revised information to address the following comments:
Complete an Engineering Alternatives Analysis (EAA): The Division requires applicants to
fully document and exhaust all alternatives to surface water discharge [G.S. § 143-215.1(b)(a)
and 15A NCAC 2H .0105 (c)(2)]. The EAA should include boring logs and/or other
information indicating that a subsurface system is neither feasible nor practical as well as
written confirmation indicating that connection to a POTW is not an option. For the non -
discharge alternatives, please demonstrate whether or not the physical size of the site is
prohibitive, and whether or not the resulting loading rate is prohibitive based on site specific
soil conditions. For your reference, the "Engineering Alternatives Analysis (EAA) Guidance
Document" is enclosed. Please complete and return Attachment A. Local Governments Review
Form (page 8). The EAA should also include a present value of costs analysis as outlined in the
Division's EAA guidance. Each alternative should be thoroughly evaluated and each
conclusion should be substantiated by appropriate documents and itemized budgets
demonstrating that alternatives are cost prohibitive.
If no response is received within 60 calendar days [per 15A NCAC 2H.0107(b)], the project will be
deactivated and withdrawn from our review process. If you have any questions, please contact Emily
DelDuco at 919-707-9125 or email at emily.delducokncdenr.gov.
Sincerely,
E
DocuS��i/gned by:
k/
8328B44CE9EB4A1...
John E. Hennessy, Supervisor
Compliance & Expedited Permitting Unit
Division of Water Resources, NCDEQ
Enclosure: Engineering Alternatives Analysis (EAA) Guidance Document
ec: NPDES Program Files
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