NC0021717_More Information (Received)_20220714

W"KFSe0 TOWN OF WILKESBORO
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Wilkesboro,North Carolina 28697
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RECEIVED
July 8th, 2022 JUL 14 2022
Michael Montebello NCDEQIDWRINPDES
NPDES Program Branch Chief
Division of Water Resources
North Carolina Department of Environmental Quality
512 North Salisbury Street
Raleigh, NC 27604
Mr. Montebello,
Thank you for your emails dated July 1 and 5, 2022, regarding the NPDES permit application for
the Cub Creek WWTP (NC0021717). Based on our understanding from your emails, the permit
application has not been reviewed, and will be assigned to Nick Coco, who has an employment
start date of July 19, 2022.
The permit modification documents for the upgrade and expansion of the Cub Creek WWTP
(WWTP) were submitted electronically on January 24, 2022. As a follow-up to this email
submittal, printed copies of the documents were sent to your office, and on February 16, 2022,
lab results for landfill leachate sampling were submitted. In addition, HDR has followed up via
email on April 1, 2022, without getting a response to inquiries regarding the status of the permit
application. From your recent email, we understand that a review of the permit application will
not begin until after July 19, 2022. We hope the application review can be prioritized to enable
issuance of a draft permit as soon as possible.
As you may remember, the WWTP has experienced operational challenges over the past
several years, and there is a need to address capacity limitations as well. The Town of
Wilkesboro (Town) is very committed to addressing both permit compliance and plant capacity.
In recent years, the Town has taken proactive steps in planning for the upgrade and expansion
of the WWTP, which will provide adequate treatment capacity for both industrial and residential
wastewater flows. Steps taken are summarized below.
• Spring 2020 — Engaged HDR Engineering, Inc. of the Carolinas (HDR) to conduct an
initial data review and to assist with a formal request for speculative permit limits.
• September 2020 — Retained HDR to prepare a Preliminary Engineering Report to
evaluate alternatives to upgrade and expand the WWTP.
• February to May 2021 —Visited multiple wastewater treatment facilities to review viable
treatment technologies.
• June 2021 — Based upon the findings of the Preliminary Engineering Report, the Town
selected the AquaNereda process for upgrading the WWTP.
• Summer 2021 —Advertised a Request for Qualifications to invite the submittal of a
Statement of Qualifications ("SOQ") from firms interested in providing construction
manager at risk ("CMAR") services. The Town received and reviewed SOQs and
conducted interviews of short-listed firms.
MIKE INSCORE KENNETH D.NOLAND JAMES K.BYRD NELLIE ARCHIBALD RUSSELL F.FERREE
Mayor Town Manager Town Clerk JIMMY HAYES Mayor Pro Tern
[e-mail] ANDREW"ANDY"SOOTS
Council Members

• Fall 2021 — Selected a CMAR for the proposed project.
• January 2022- Following an evaluation of SOQs from interested consulting firms, the
Town entered a contract with HDR to design and prepare construction documents for the
upgrade and expansion of the WWTP.
Further, the Town has had the following meetings with NC DEQ regarding the proposed project.
These meetings are listed below:
• May 21, 2020 — Initial Permitting Meeting (virtual).
• July 23, 2021 — Meeting with NC DEQ to provide an overview of the AquaNereda
process (virtual).
• August 12, 2021 — Meeting with NC DEQ to discuss the proposed project, permitting and
project funding (in person meeting in Raleigh).
• September 13, 2021 — Meeting with NC DEQ to discuss modifications to the Industrial
User Permit for Tyson Foods (virtual).
• September 15, 2021 — Meeting with NC DEQ to discuss the Environmental Assessment
in support of the proposed project (virtual).
• September 15, 2021 — Meeting with NC DEQ to discuss the Sewer Extension
Moratorium (virtual).
Given the normal steps and time required in the NPDES permitting process, the reduced
staffing levels at NC DEQ, and the unexpected delay in beginning the review, we are very
concerned about potential impacts to our overall project schedule. Such timing will have the
following implications to this project.
1. Plant Operation & Compliance — The proposed upgrade and expansion will improve
reliability and resilience of the WWTP, increase WWTP capacity and improve the water
quality of treated effluent to meet the new permit limits. Any project delays will prolong
the current operation and compliance challenges at the WWTP.
2. Project Schedule - A delay in the issuance of a Final NPDES permit will affect the
Town's ability to obtain an Authorization to Construct (ATC) permit. The ATC application
requires the submittal of Part 1 of the Final NPDES permit. Although the full ramifications
to the project schedule are not known at this time, the construction start date could be
delayed until mid-2023.
3. Financial Impacts — Presently, HDR is providing the design and development of
construction documents for the proposed WWTP improvements. Additionally, the Town
is under contract with Ulliman Schutte Construction (CMAR) to provide preconstruction
services for this project, which generally include design and constructability reviews,
cost estimating, value engineering, development of a procurement plan, and the
development of a GMP.
The budget for both engineering and CMAR preconstruction services was included in the
State Revolving Fund (SRF) loan budget administered by the Division of Water
Infrastructure. Delays in the NPDES permitting process will delay the permits needed for
construction and access to the SRF funds. In the current inflationary environment,
particularly with infrastructure projects, delays may lead substantial costs increases. As
such, the Town may find it necessary to scale back the pace of design development.
Additionally, this unexpected delay may eliminate the possibility of an early works
package with the CMAR. An early works package would have included improvements to

the existing sludge dewatering facilities, which would benefit current operations at the
VWVfP. An early works package would also have an added benefit of accelerating the
overall project schedule.
The Town is a rural community that needs this project to move forward as it is essential to
industrial expansion and commercial development. Our area has a higher poverty rate and
lower median household income than state averages which places greater emphasis on
economic development. Again, we ask that the application review be prioritized to enable
issuance of a draft permit as soon as possible. Please let us know if there is any information we
can provide to assist in the review of this NPDES permit application.
Thank you,
))\k
Ken Noland
Town Manager