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HomeMy WebLinkAboutNC0086053_Comments_20210706 PILOT . COMPANY RECEIVED 6/29/2021 JUL 0 6 2021 NCDEQ/DWR/NPDES NCDEQ, Division of Water Resources NPDES Unit 1617 Mail Service Center Raleigh, NC 27699 Re: Response to Public Notice of Intent to revoke NPDES Permit NC00086053, Deny renewal application, and or deny permit transfer request. The Pilot Travel Center was the original applicant for and permit holder of NPDES Permit NC00086053. Pilot worked closely with Junaluska Sanitary District ("JSD")to solve wastewater issues at Pilot Travel Center#393. We transferred the permit to JSD so that it could work on the possibility of having its own wastewater treatment plant. We support that effort, and would ask that DEQ, not revoke the permit, not deny the renewal of the permit, and allow the transfer of the permit to JSD. We wrote to Daniel Smith, the Director of the Division of Water Resources on April 29, 2021. We reiterate our concerns and our position as set forth in that letter. Sincerely, oey Cupp Director of Environmental Pilot Travel Centers LLC Pilot Company 5508 Lonas Drive Knoxville,TN 37909 1.800.562.6210 NCDEQ, Division of Water Resources NPDES Unit 1617 Mail Service Center Raleigh, NC 27699 6/29/2021 • Re: Response to Public Notice of Intent to revoke NPDES Permit NC00086053, Deny renewal application, and or deny permit transfer request. I am a long-time resident of Haywood County and the property owner of the Sam's Mart and Haywood Café located at Exit 24 off Interstate 40 at 3360 Crabtree Road. This property has been a long-time customer of the Junaluska Sanitary District ("JSD"). Sam's Mart and Haywood Café worked closely with JSD to solve wastewater issues and now provides wastewater services to my property. Sam's Mart is a gas station and convenience store. A part of the building is leased to Haywood Café, a small restaurant. Without access to sewer, operating a small business and restaurant in a rural area such as ours would be very difficult. We support JSD having a permit to operate its own wastewater treatment plant. We ask the DEQ not revoke the permit and allow transfer of the permit to JSD. Since ely, DannyMc Iro Y McElroy Inc. Waynesville, NC NCDEQ Division of Water Resources NPDES Unit 1617 Mail Service Center Raleigh, NC 27699 6/29/2021 Re: Response to Public Notice of Intent to revoke NPDES Permit NC00086053, Deny renewal application, and or deny permit transfer request. I am a long-time resident of Haywood County and a long-time customer of the Junaluska Sanitary District ("JSD"). My family owns the property on which the Pilot Travel Center#393 is located. My family donated an easement so the travel center could connect to JSD. I support JSD's efforts to build its own treatment plant. I ask that DEQ not revoke NPDES Permit NC00086053, and that the permit be transferred to JSD. Sincerely, 7�!O-.7 Ed Bryson 209 Crossing C Waynesville, NC Junaluska Sanitary District P.O. Box 35 `--. Lake Junaluska, NC 28745 520-43E-1178 828-452-1178 www.jsdwater.org RECEIVED JUL 062021 June 24, 2021 NCDEQ/DWR/NPDES NCDEQ, Division of Water Resources NPDES Unit 1617 Mail Service Center Raleigh, NC 27699 Please find our attached response to the Public Notice of intent to revoke NPDES Permit NC0086053, deny permittee's renewal application, and/or deny permit transfer request. We respectfully submit these comments and await your response. Sincerely, James H. Fra • Chairman of the Board Junaluska Sanitary District M N ` Jo h Nickol General Manager/Chief Financial Office Junaluska Sanitary District Junaluska Sanitary District EleT3 "1,a P.O. Box 35 Lake Junaluska, NC 28745 828-452-1178 www.jsdwater.org NCDEQ, Division of Water Resources RE �jEtVED NPDES Unit 1617 Mail Service Center JUL 0 6 2021 Raleigh, NC 27699 NCDEQIDWRJNPDES 6/22/2021 Re: Response to Public Notice of intent to revoke NPDES Permit NC0086053, Deny permittee's renewal application,and/or Deny permit transfer request. Junaluska Sanitary District(JSD,the District)and its members submit the following comments in response to the Public Notice of intent regarding NDPES Permit NC0086053: The Pilot Travel Center#393 ("Pilot") applied for a renewal of NPDES NC0086053 (the "NPDES Permit") permit on July 24, 2020. DWR approved this renewal on September 29, 2020. In September, 2019, Pilot connected to a new sewer line constructed by JSD.At that time, Pilot did cease operating its package treatment plant and began sending its wastewater to JSD's system. Pilot did not eliminate or terminate its NPDES Permit. Following the renewal of the NPDES Permit and throughout the construction of the JSD Sewer Capital Project to connect Pilot to the JSD system, Pilot was working directly with Brown Consultants on the close- out of their sewer plant. Furthermore, Pilot was working with JSD to take over the NPDES Permit once Pilot was connected to the JSD sewer system. In accordance with DEQ guidance and regulations,JSD and Pilot entered into an agreement to transfer the NPDES Permit to the District (see attached) in order for JSD to submit the Minor Name change application. JSD's intent, in obtaining the NPDES Permit, was and is to have the option or opportunity to pursue its own WWTP for the benefit of the district's customers/members. Some of the reasons for JSD's interest in operating its own treatment plant are set forth herein. JSD has been in a contract(interlocal agreement)with the Town of Waynesville since approximately 1986 to receive wastewater collected by the JSD system. Over the years, issue have arisen with the Town of Waynesville regarding impact fees(now SDF's)and available capacity.' JSD has attempted to partner with Waynesville and even offered to purchase Waynesville's treatment plant which is located in the center of our District as well as an offer to buy-in to their future upgrades. Both offers were rejected without any discussion. Under the current agreement,JSD is nothing more than an outside industrial customer. The current arrangement will prove to be very costly to our members as Waynesville's treatment costs increase to cover upgrades to its plant and collection system.JSD does not feel as though it should bear the burden of these upgrade costs that should have been addressed years ago. It has been reported in the local paper that sewer rates will increase by 50%in the coming years. 'As DEQ is aware,there are also ongoing issues with Waynesville's sewer system and treatment plant which will require expensive upgrades. It is difficult, at best,for JSD to plan (CIP)for District growth,services,cost, rehab, and budgets when the treatment provider does not communicate rates, allocations, or planning with JSD. The District, in partnership with Haywood County, did extend its sewer lines up to Riverbend School (North of 1-40 up to the Crabtree area corridor). JSD's partnership with the County was to provide public sewer to existing businesses and operations as well as allowing for growth along exit 24 on Interstate 40.The District is best positioned to serve this area, but its ability to do so will be limited without a viable partnership with the Town of Waynesville. Given the absence of this cooperation, the District's long-term goal to serve the community would be to have its own treatment plant operation. JSD has asked Waynesville to revise the interlocal agreement to no avail at this point. The District understands the town of Waynesville is in the middle of planning the future upgrade of its WWTP and does not want to renew the contract until the planning is complete. However, the District feels it should not have to suffer the consequences of Waynesville's prior neglect or future costs, and needs the opportunity to serve our members more efficiently and economically. The District has completed preliminary studies of having its own treatment plant that would only serve our members and customers. The debt service to accomplish this is far less than what the District would have to pay in annual sewer treatment rates to the town of Waynesville over the next ten (10)years.The savings, capacity control and costs to our members is why the District needs to have this opportunity. Furthermore, no additional flow discharge will be realized if JSD were to open its own treatment facility since the amount of flow the District generates would be reduced at the Waynesville plant. The District understands that the ownership name change is only the first step, and we would have to deal with permitting our own WWTP. JSD is prepared for this. At this time JSD is asking only that DEQ acknowledge the transfer of the permit and that the Permit not be revoked.