NC0005312_staff comments_20221020

Weaver, Charles
From: Chernikov, Sergei
Sent: Thursday, October 20, 2022 4:17 PM
To: Weaver, Charles
Subject: Fwd: [External] RE: NC0005312 Duvaltex / Elkin Mill (US), Inc. Recommended Next Steps
Attachments: IMG_0207.JPG; IMG_0205.JPG; IMG_0206.JPG
Charles,
Should they officially request to be placed on the inactive status? Please see below.
Thank you!
Sergei
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From: Graznak, Jenny <[e-mail]>
Sent: Thursday, October 20, 2022 4:01 PM
To: Greg Kanellis <[e-mail]>; Dowden, Doug <[e-mail]>; Peter J. Paine, PMP
<[e-mail]>
Cc: Chernikov, Sergei <[e-mail]>; Snider, Lon <[e-mail]>
Subject: RE: [External] RE: NC0005312 Duvaltex / Elkin Mill (US), Inc. Recommended Next Steps
Good afternoon,
Please see the attached photos of the effluent basin from the Duvaltex site visit this morning to assess the dewatering
efforts. We estimate that there are approximately 7 feet of available freeboard currently in the effluent basin. The
operator estimated that 1.6 million gallons was removed from the system. As of today's site visit, WSRO concurs that
Duvaltex could be placed on inactive status at this point, since there is no chance of discharge anytime soon.
Sergei, can you weigh in on what the next steps should be?
Thank you,
Jenny Graznak
Assistant Regional Supervisor, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] I Cell: [phone]
[e-mail]
aE
NOH I H OAHOLINA
Department of Environmental Quality
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Carolina Public Records Law and may be disclosed to third parties.
i

From: Greg Kanellis <[e-mail]>
Sent: Wednesday, October 19, 2022 11:09 AM
To: Dowden, Doug <[e-mail]>; Peter J. Paine, PMP <[e-mail]>
Cc: Chernikov, Sergei <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<[e-mail]>
Subject: [External] RE: NC0005312 Duvaltex / Elkin Mill (US), Inc. Recommended Next Steps
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Doug,
Sorry for the delayed response. As discussed during our call and with Jenny and Lon onsite, Duvaltex wishes to pursue a
"freeze" of the permit. In preparation for requesting DEQ approval for placing the permit in an inactive status, Duvaltex
recently dewatered the WWTP structures to the extent practical through its permit -approved outfall to idle the
WWTP. See attached photographs. Duvaltex requests a return visit by Jenny and/or Lon to confirm the WWTP
dewatering and grant a "freeze" of the permit. Please let us know if you have any questions. We look forward to
coordinating the site visit.
Thanks,
Greg Kanellis, PE, Project Manager
Hart & Hickman, PC
3921 Sunset Ridge Rd, Ste 301 • Raleigh, NC 27607
Direct: 919-723-2512 • Mobile: [phone]
www.harthickman.com 031
From: Dowden, Doug <[e-mail]>
Sent: Friday, September 23, 2022 8:36 AM
To: Peter J. Paine, PMP <[e-mail]>; Greg Kanellis <[e-mail]>
Cc: Chernikov, Sergei <[e-mail]>; Snider, Lon <[e-mail]>; Graznak, Jenny
<[e-mail]>
Subject: NC0005312 Duvaltex / Elkin Mill (US), Inc. Recommended Next Steps
Good Morning Greg and Peter,
As follow-up to our recent meeting internally we have discussed next steps. Collectively, we believe
the best potential to achieve a reduction in monitoring requirements and a change from an ORC 4 to
a 2 would be a Major Permit Modification. Major modifications under CWA section 122.62 are
routinely applied to address:
1. alterations justifying new or different conditions
2. new information
3. new regulations (with consent of the permittee)
4. modifying a compliance schedule for good cause
5. addressing a variance request
6. inserting a §307(a) toxic effluent standard
7. requirements of a reopener condition
8. incorporating or removing net limits
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9. requiring a POTW to develop a pretreatment program
10. failure to notify a state whose waters might be affected by the discharge
11. addressing discharges of non -limited pollutants
12. establishing a notification level
13. modify compliance schedule for POTW construction using EPA grant funding (no
longer applicable)
14. requiring implementation of minimum control measure(s) for a small MS4
15. correcting technical mistakes or mistaken interpretations of law
16. modifying effluent limits when unsuccessful BPJ treatment was installed
17. incorporation of CAFO nutrient management plan not a cause
18. incorporating, revising, or adding a sewage sludge land application plan
Based upon the information supplied to date I believe numbers 1 and 2 above apply to the current
situation at your facility. Thus, the recommendation is to proceed with a Major Permit Modification.
Please note that information and data supplied will determine the results of the application.
If you should have any questions and/or concerns please feel free to reach out to me at your earliest
convenience.
Sincerely,
Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925Q)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3605
[e-mail]
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect
the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing
changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
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