NC0069841_Speculative Limits Request_20240307

Black&Veatch International Company
BLACK&VEATCH 10925 David Taylor Drive,Suite 280,Charlotte,NC 28262
P+1 704-510-8421 E [e-mail]
March 7, 2024
Mr. Michael Montebello
Supervisor - NPDES, Pretreatment and Collection Systems
Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Request for Speculative NPDES Limits for Union County
Crooked Water Reclamation Facility
Dear Mr. Montebello:
We appreciate the willingness of NC Division of Water Resources and Environmental Quality
staff(NC DEQ) to meet with us on January 11, 2024,to discuss Union County Water's Request
for Speculative Limits for the new Crooked Creek Water Reclamation Facility at Site B. We have
been pursuing an evaluation of alternatives to the Site B location for a discharge into Crooked
Creek on behalf of Union County Water and wanted to verify the direction received from NC DEQ
prior to providing guidance to Union County Water as follows:
• A new wastewater discharge permit will not be able to be permitted at locations along
Crooked Creek where flow and effluent limits cause downstream dissolved oxygen
concentrations to fall below the 5.0 mg/I dissolved oxygen standard (15A NCAC 02B
.0211).
• Union County Water needs to re-evaluate discharge locations and identify a final location
that will meet the above requirements in order for NC DEQ to provide a final response to
the Request For Speculative Limits at Site B. Water Quality modeling results should be
submitted which demonstrated compliance with the dissolved oxygen standard based
on the discharge location.
In our preliminary analyses we have confirmed potential discharge locations between Highway
601 and the original Site A would support effluent limits that would maintain a minimum
dissolved oxygen concentration above the 5.0 mg/I standard. Speculative limits were
previously issued for Site A on July 12, 2021. Please verify those limits are still in effect should
Union County Water decide to finalize a discharge at Site A. We are working with Union County
Water to finalize a revised request based on the above direction and will contact DEQ to discuss
the preferred approach for modifying the most recent Site B Request for Speculative Limits prior
to submitting.
Your assistance is greatly appreciated. If you have any questions or need additional information,
please do not hesitate to either call [phone] or email me at [e-mail].
BUILDING A WORLD OF DIFFERENCE"

March 7,2024 1 Page 2
Kindest Regards,
lz/4 � . 6�1- -
Kent A. Lackey
Senior Vice president
Enclosure
CC: Union County Water
Aubrey Lofton, Planning & Resource Management Director,
[e-mail]
Hyong Yi -Water Administrator, [e-mail]
John Shutak- Engineering Division Manager,
[e-mail]
Josh Brooks- Operations Director, [e-mail]
Christopher Clark-Water&Wastewater Director,
[e-mail]
Jonathan Jordan -WRF Superintendent,
[e-mail]
Union County
Brian Matthews - County Manager, [e-mail]
Black&Veatch
Mike Osborne, [e-mail]
Chris deBarbadillo, [e-mail]
Tetratech
Trevor Clements,[e-mail]
Hillary Yonce, [e-mail]
Tedderfarm Consulting
Steve Tedder,[e-mail]
DWR
Derek Denard, [e-mail]
Pam Behm, [e-mail]
Adugna Kebede, [e-mail]
Bongghi Hong, [e-mail]
Doug Dowden, [e-mail]

4/18/24, 10:15 AM Mail-Denard, Derek-Outlook
[External] FW: DWR Letter Draft
Lackey, Kent A. <[e-mail]>
Fri 3/8/2024 8:24 AM
To:Montebello, Michael J <[e-mail]>
Cc:Lofton,Aubrey <[e-mail]>;[e-mail] <[e-mail]>;
Shutak,John <[e-mail]>;Christopher Clark <[e-mail]>;Jonathan Jordan
<Jonathan.Jordan@unioncou ntync.gov>;Matthews, Brian <[e-mail]>;Osborne,James M. (Mike)
<[e-mail]>;deBarbadillo, Chris <[e-mail]>;Massey, Kyle <[e-mail]>;Clements,Trevor
<[e-mail]>;Yonce, Hillary <[e-mail]>;Steve Tedder
([e-mail]) <tedderfarmconsulting@gmaiLcom>;Denard, Derek <[e-mail]>;Behm,
Pamela <[e-mail]>;Kebede,Adugna <[e-mail]>;Hong, Bongghi
<[e-mail]>;Dowden, Doug <[e-mail]>
1 1 attachments(202 KB)
WQ-N PDES_03.08.2024.pdf,
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Mr. Montebello,
I want to thank you for the participation in our meeting in January. It was helpful to receive actionable input for
Union County Water. Please see a letter, attached, requesting confirmation of the direction we heard in the
meeting which Union County plans to proceed based upon. If you have questions please feel free to reach out to
me at(704) 258-8666.
Thank you.
Kent A.Lackey,P.E.
Senior Vice President
Government&Water Utilities—East Region Managing Director
*Licensed in VA,NC,GA,FL
Black&Veatch
D+1 704-510-8421 (EST)
M+1 704-258-8666
E [e-mail]
Building a World of Difference.®
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