NC0089532_More Information (Received)_20210301

Tuckaseigee Water & Sewer Authority
Serving Jackson County
1246 West Main Street
Sylva, NC 28779 RECEIVED
Phone: [phone] • Fax: [phone]
NDDEQ/DWR/NP, Qj202f DES
February 25, 2021
Mr. John Hennessy, Supervisor
NPDES Compliance and Expedited Permitting Unit
Division of Water Resources
North Carolina Department of Environmental Quality
512 North Salisbury Street (9th Floor Archdale Building)
Raleigh, North Carolina 27604
RE: Response to Request for Additional Information
TWSA WWTP #6 (NPDES Permit NC0089532)
Tuckaseigee Water and Sewer Authority
Jackson County, North Carolina
Dear Mr. Hennessy,
Tuckaseigee Water and Sewer Authority (TWSA) is now in possession of your Request for
Additional Information regarding the renewal of NPDES Permit NC0089532 for WWTP #6 near
Cashiers in Jackson County. This letter, dated June 16, 2020 on the copy we were able to obtain,
was addressed to Dan Harbaugh, who left the role of Executive Director of TWSA in October of
2019. His duties were assumed by Interim Executive Director Dan Schaeffer, who was in turn
replaced by myself, Daniel Manring, in March of 2020.
We have searched our files and cannot find the June 16, 2020 letter or any record that the
Authority received this correspondence. No one at TWSA was aware that a Request for Additional
Information had been made until February 18, 2021, when our consultant, McGill Associates,
accessed NCDEQ's Laserfiche Document Center and saw that a new document, placed in the
center's database December 9, 2020, was available for viewing and download. Prior to this
discovery, the latest correspondence with NCDEQ regarding this application was a letter from
Wren Thredford dated April 15, 2020 stating that "Per G.S. 150B-3 your current permit does not
expire until a permit decision on the application is made." We considered this statement to
constitute an extension of the term of the NPDES permit pending processing of the renewal
application.
Mr. Thredford's notification and affirmation that the permit was still in effect was key to the timing
of our submittal of the Authorization to Construct application. We were unaware of your June 16,
2020 communication requesting that the Authorization to Construct application be submitted
before the original expiration date of the NPDES permit, July 31, 2020. We submitted the
application under the assumption that the term had been extended while the renewal application
was being processed. Authorization to Construct No. 089532A01 for WWTP#6 was approved on
January 7, 2021.

Mr. John Hennessy
February 25, 2021
Page 2 of 2
Given the operational difficulties experienced by both NCDEQ and TWSA due to the ongoing
pandemic and its impacts on mail delivery and other communications at both of our organizations
as well as TWSA's recent leadership transition, we ask for the Division's understanding and
request that our NPDES renewal application be considered active and under review pending our
response to your Request for Additional Information, which you will receive within 60 calendar
days of today's date.
TWSA expended considerable resources and undertook an exhaustive evaluation of alternatives
and a comprehensive public outreach process in securing the Horsepasture discharge permit.
Considering the miscommunication that has obviously occurred, it would be an unfair burden on
the Authority to have to undertake a "new" application process for our Horsepasture discharge. It
should also be considered that this project has been under development for over 15 years. The
Horsepasture VVWTP is essential to the Cashiers area and its citizens. Potential customers for
this facility were identified over 10 years ago and we are receiving a significant number of requests
already for services this facility will provide.
Of additional importance is the fact that TWSA has secured funding for this project and a delay in
our ability to proceed could endanger that funding. We seek the Division's help in addressing this
important concern.
We would welcome the opportunity to discuss this situation and cooperatively seek a reasonable
solution to this issue. Please contact me to schedule a meeting to discuss this permit.
Sincerely,
Tuckaseigee Water and Sewer Authority
Daniel Manring
Executive Director
Ec: John Hennessy, iohn.hennessv ncdenr.gov
Kyle Seaman, PE, kyle.seaman(c�mcgillassociates.com
Forrest Westall, PE, forrest.westalk mcgillassociates.corn
Tanya Tallent, thaMtwsanc.us