NC0030210_Response to Notice_20220822

CHARLOTTE
W6T E R
August 18, 2022
NCDEQ-DWR RECEIVED
Compliance & Expedited Permitting Unit
1617 Mail Service Center AUG 2 2 2022
Raleigh NC, 27699-1617
NCDEOIDWRJNPDES
Dear Mr. Hennessy:
This letter is in response to the certified letter( 7018 1830 0001 8036 9216) dated 7/25/2022 regarding the
subject of "Pending Imposition of Sewer Line Moratorium" for NPDES Permit NC0030210. As you may not
be aware, Charlotte Water(CLTWATER) was aware of the requirements set forth in 15A NCAC 02T .0118 and
has previously taken the steps toward meeting the intent of this rule.
CLTWATER began preparing for the expansion of the Mallard Creek Water Reclamation Facility (WRF) in
2016 and both planning, design, permitting and construction of the initial expansion to 13.1 MGD is nearly
complete. Also, design plans have been submitted to NCDEQ for the expansion of the Mallard Creek WRF to
16.0 MGD and we are awaiting the ATC for this project. A more detailed history of our efforts to expand our
capacity can be found in the table below.
2016-06-08 CLTWater authorized Brown and Caldwell to study the Mallard and Back Creek sewer basins.
2018-02-02 In person meeting with NCDEQ to discuss CLTWater's intent to expand the Mallard Creek WRF was held. (Julie Grzyb,David Hill,Teresa
Rodriguez,Mike Templeton attended for NCDEQ)
2018-09-26 Request for speculative limits for the phased Mallard Creek WRF expansion from 12.0 MGD to 13.1,14.9,and 16.0 MGD.
2019-02-22 Speculative limits for the phased Mallard Creek WRF expansion issued by NCDEQ.
2019-06-11 ATC application submitted to NCDEQ forthe Rehabilitation and UV Improvements(RUVI)project.This project must be completed to expand
Mallard Creek to 13.1 MGD.
2019-09-04 Draft NPDES permit issued by NCDEQ listing effluent limits for expanded flows(tiers)and matching the speculative limits.
2019-12-17 Final NPDES permit issued by NCDEQ listing effluent limits for expanded flows(tiers)and matching the speculative limits.
2019-07-26 ATC for the Rehabilitation and UV Improvements(RUVI)issued from NCDEQ.Construction Manager at Risk(CMAR):Crowder.Value:$31.2
million
2020-10-05 ATC application submitted to NCDEQ forthe Mallard Phase 1A(Train 3 and Aeration System)project.This project must be completed to expand
Mallard Creek to 13.1 MGD.
2020-12-17 ATC forthe Mallard Phase 1A issued from NCDEQ(ATC No.030210A02 and 030210A03).Contractor:Crowder.Value:$5.7 million
2021-04-22 PC/Leeper selected as CMAR for the expansion of Mallard Creek to 16 MGD
2022-05-11 Final design documents and ATC application to expand to 16 MGD submitted to NCDEQ.CMAR:PC/Leeper.Value:$98.7 million
2022-05-11 ATC application submitted to NCDEQ forthe Mallard Phase 1 project.This project must be completed to expand Mallard Creek to 16.0 MGD.
2022-05-12 Meeting with NCDEQ to discuss CLTWater's ATC application forthe expansion to 16 MGD.
2022-07-13 NCDEQ comments on submitted 16 MGD expansion ATC received.
2022-07-22 CLTWater response to comments on 16 MGD expansion ATC submitted to NCDEQ plans reviewer
Charlotte Water 5100 Brookshire Blvd.,Charlotte,NC 28216 charlottewater.org
(Q)) Operated by the City of Charlotte

CHARLOTTE
W6TER
CLTWATER is currently awaiting approval of our ATC application for the expansion of the Mallard Creek
WRF to 16.0 MGD currently under review with NCDEQ. The latest comments by CLTWATER were returned
to the reviewer(Ms. Min Xiao) on July 22, 2022. CLTWATER assumes that permitting is imminent but any
assistance you can provide us to move this project forward would be appreciated. It is anticipated that
construction will begin immediately once the ATC is issued.
Based upon the above summary of permits and expansions, CLTWATER is far ahead of schedule in
meeting the requirements outlined in 15A NCAC 02T.0118. We frankly do not understand the need for
NCDEQ to issue CLTWATER a letter indicating "Pending Imposition of Sewer Line Moratorium"for our
Mallard WRF when our current average daily flows are below the 80% threshold and that NCDEQ has
known about our planning efforts and issued both speculative permit limits and ATC on a phased
expansion project. If we have misunderstood the intent of this notice, please let us know.
Should you require additional information, please contact Joseph Lockler,who manages our
Environmental Management Division at 704.634.3665 or via email at [e-mail].
Sincerely,
'J.
Angela D. harles, Director
Charlotte Water
CC: Richard Rogers, NCDEQ Director
Julie Grzyb, NCDEQ Deputy Director
Corey Basinger, NCDEQ-MRO Supervisor
Andrew Pitner, NCDEQ-MRO
Joseph Lockler, Charlotte Water
Charlotte Water 5100 Brookshire Blvd.,Charlotte,NC 28216 charlottewater.org
(Q)) Operated by the City of Charlotte