WQ0013252_Additional Information Response_20220616

CHARLOTTE
W TER
June 15, 2022
Ms. Lauren Raup-Plummer
North Carolina Division of Water Resources (NCDWR)
512 North Salisbury Street
9th Floor - Archdale Building
Raleigh, NC, 27604
Re: Application No. WQ0013252
Mallard Creek WRF Reclaimed Water System
Draft Permit Comments
Ms. Raup-Plummer:
Thank you for sending the draft permit (Permit No. WQ0013252), which we received via
email on May 13th, 2022. Charlotte Water (CLTWater) has reviewed the document and is
providing the following comments for your consideration. We appreciate your time with
this matter and look forward to receiving your written responses.
1) II.14(a): Does footnote 1 refer to somewhere specific in this condition? Its
subscript could not be found.
2) III.15: CLTWater requests that qualifying language be used in this section that
states that this requirement only applies to those users under CLTWater's
permit since users will be accepting and utilizing reclaimed water under their
own respective permit(s).
3) IV.3: It is unclear whether the term "treatment facility" refers to the entire
Mallard Creek Water Reclamation Facility or to the reclaimed water system.
Since the wastewater treatment process at Mallard Creek WRF is not necessarily
indicative of the reclaimed water system, CLTWater requests that this section be
omitted from the final permit.
Charlotte Water 5100 Brookshire Blvd, Charlotte, NC 28216 charlottewater.oig
ti?Operatecl by the City of Charlotte

4) IV.6: Since DWR has been accepting electronic submissions for some time,
CLTWater requests that this condition be modified to allow for electronic
submission.
5) IV.7: Part II Section E. 12 of our NPDES permit (NC0030210) already calls for the
Annual Performance Report that is referenced here and required by NCGS 143-
215.1C. Since this is a reclaimed water generation system permit CLTWater
requests that this section be omitted from the final permit.
6) IV.9(c): CLTWater requests that this condition be omitted or modified to
maintain consistency with other similar permits. Power interruption testing on
alternate supply is not required by the Mallard Creek WRF NPDES permit nor its
air quality permit.
7) IV.10: CLTWater requests that this requirement be removed since reclaimed
water users will accept and utilize reclaimed water under their own respective
permits.
8) IV.11(d): This condition refers to IV.9.g, but it seems it should refer to IV.9.f.
9) V.2: CLTWater requests that "or their designee" be inserted after "The
Permittee" in the first sentence of this condition, reverting to the current permit
language and to allow CLTWater to seek outside assistance with these tasks if
necessary.
10)Attachment A: CLTWater has noted several discrepancies in the PPI 001 table.
Although the footnote says that "monitoring requirements have been aligned
with those requirements in Permit No. NC0030210," this isn't accurate. Our
NPDES permit contains seasonal cBOD monthly and weekly average limits, as
compared to the monthly average and daily maximum BOD limits in this draft.
All PCS code references need to align with our NPDES permit and be accurately
reflected in this table and associated footnotes. The Fecal Coliform PCS code
conflicts with our NPDES permit. The "Sample Type" for Total Residual Chlorine
should be "Grab".
11)Attachment B: CLTWater requests that UNCC be added to the list of offsite
conjunctive reclaimed water users conditional to their receipt of a conjunctive
use permit
Charlotte Water 5100 Brookshire Blvd, Charlotte, NC 28216 charlottewater.org
Operated by the City of Charlotte

Thank you for your consideration of these comments. Please contact Shannon Sypolt, our
Water Quality Program Administrator, at 704.634.6984 or [e-mail] with
any questions. Thank you for your assistance with this permit renewal.
Respectfully,
Joseph Lockler, Operations Chief
Cc: Shannon Sypolt (CLTWater), Billy Allen (CLTWater), Henry Eudy (CLTWater)
Charlotte Water 5100 Brookshire Blvd, Charlotte, NC 28216 charlottewater.org
Operated by the City of Charlotte