NC0021156_Permit Renewal Correspondence_20161122

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HOLLY
Coaarding Col im itIv & Nam -
Mr. Michael E. Templeton, PE
Environmental Engineer
NC Division of Water Resources
Archdale building, 9th Floor
512 N. Salisbury Street
Raleigh, North Carolina 27604
Re: City of Mount Holly NPDES Permit NCO021156
Dear Mr. Templeton:
November 22, 2016
RECE(VEDINCDE 1DIN
DEC 0 7 2016
Water Quality
PGrm.iffiirig 'Cection
Thank you very much for hosting the combined meeting of the minds from Mount Holly, Belmont and
Charlotte Water. We realize your time is valuable with the transition of projects from Tom to you.
I am positive this transition will be difficult and complex knowing the experience and specific knowledge
that Tom Belnick, Supervisor; NPDES Complex Permitting Unit brings to the discussion. You are now
fully aware of our expressed concern about our permit. It is good to know from our perspective that your
sincere efforts to process our permit renewal will become your next priority.
It is important to summarize this complex issue into a brief distinct time line:
1. August 1, 2014 The City of Mount Holly submitted the permit renewal application
2. August 2, 2014 Acknowledgement of Permit Renewal letter from NCDENR. This
enclosed letter is over 180 -days from the expiration date of our permit.
3. February 28, 2015 Permit and authorization to discharge expiration date
4. October 30, 2015 Conference call with all four parties to discuss the status of the
agreements between the parties (NCDEQ, CW, MH, & Belmont)
5. November 15, 2016 Meeting held in your offices to discuss permits associated with
Charlotte Water, Belmont and Mount Holly —application for a permit
renewal has not been acted upon by NCDEQ
6. April 1, 2017 Date the TN Load limit becomes effective in the Mount Holly
Permit NCO021156
As we expressed in the meeting, we are and will be non-compliant with the TN load limit of 64,200
lbs/summer if effective today and on April 1, 2017.
P.O. Box 406 Mount Holly, North Carolina 28120

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It was beneficial to have Charlotte Water attend the meeting so they could outline their Long Creek
WWTP schedule. As they stated, a 2019 or 2020 operational schedule was entirely conceivable.
Combining this time estimate with your work load and prediction to start addressing the permits with
Clariant's TN allocations will most assuredly be in progress on April 1, 2017. This delay would put
Mount Holly in non-compliance on the very day the TN becomes effective April 1, 2017 ---4 months
from NOW!
In my opinion, there are three alternatives in which this matter can be handled.
1. NCDEQ does nothing and continues to evaluate the entire regionalization plan developed
by Charlotte Water. This decision would be predicated upon knowing the following:
a. Mount Holly would be non-compliant but the river would be under its
TMDL allotment for TN because Clariant is not discharging to the river.
b. Mount Holly is not protected in this scenario from 3`d party action as you
stated in the meeting.
2. NCDEQ works with Charlotte Water, Belmont and Mount Holly to structure an agreement
between all parties distributing the Clariant TN allocation. At the present time only Mount
Holly is non-compliant and will be officially non-compliant on April 1, 2017. With all due
respect to the legal profession, these agreements will be scrutinized to the ninth degree and all
three governing bodies will have to pass a resolution ratifying their agreement — no small task.
If this issue was left in our technical hands, we could get it done. Leave it in legal hands with
political oversight — not so much!
a. Mount Holly would be non-compliant but the river would be under its
TMDL allotment for TN because Clariant is not discharging to the river.
b. Mount Holly is not protected in this scenario from 3`d party action as you
you stated in the meeting.
C. Mount Holly would be in compliance with our 300 lbs/day plus the 223 lbs/day
TN allocation on April 1, 2017 IF the agreements could be ratified by this date.
3. NCDEQ renews our permit application and extends the effective date of the TN load
limit to April 1, 2020.
By extending the effective date in the Mount Holly permit, the agreements, allocation of
Clariant's TN and the construction of the Long Creek WWTP would closely coincide.
a. Mount Holly would be in compliance with the renewed permit and the TN
discharged to the river would be under the TMDL allotment for TN because
Clariant is not discharging to the river.
b. Mount Holly would be protected in this scenario from 3`d parties.
P.O. Box 406 Mount Holly, North Carolina 28120

C. This extension of the TN effective date would be consistent with the construction
of the Charlotte Water's Long Creek WWTP and the exchange and allocation of
Clariant's TN allocation would become clear and much easier to administer.
I do know what is in the best interest of the City and we prefer to be operating our W WTP with a VALID
permit.
I also know that the coal ash issue, NCDEQ staffing and the transition of key staff will make
Alternative's 1 and 2 extremely difficult to achieve.
I may be over simplifying the tasks involved but Mount Holly's current permit modification dated
January 16, 2015 could be modified and issued by changing a date on Page 1 of 10 and making the same
date change on Page 4 of 10 to April 1, 2020.
Extending the Total TN Permit Limit to April 1, 2020 would not adversely affect the receiving waters
designated as the Catawba River because Clariant is not adding TN to the river.
Also, with the support of Danny Jackson, City Manager and the City Council, the Utilities Department
has been and will continue to investigate possible reuse projects that will further reduce our discharge to
the Catawba River.
Thank you again for your time and your continued efforts on our behalf. I truly hope that you will
seriously consider Alternative 3 as a viable option that will protect all entities.
I would be glad to meet you at your offices if you should have any questions or wish to further discuss
this matter. Please let me know.
Enclosure
CC: Tom Belnick, NCDEQ
Danny Jackson, Mount Holly City Manager
Miles Braswell, Mount Holly Assistant City Manager
Ray Clemmer, Deputy Director, Utilities Department
Original Mailed and Copy emailed
Best Regards,
Da�d E. Johns n, PE
Uti ties Directo / City Engineer
P.O. Box 406 Mount Holly, North Carolina 28120

AMP,
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
August 04, 2014
Attn: Danny Jackson, City Manager
Mount Holly WWTP
PO .Box 406
Mount Holly, NC 28120
Subject: Acknowledgement of Permit Renewal
Permit NCO021156
Gaston County
Dear Mr. Jackson:
The NPDES Unit received your permit renewal application on August 01, 2014. A member of the
NPDES Unit will review your application. They will contact you if additional information is required to
complete your permit renewal. You should expect to receive a draft permit approximately 30-45 days
before your existing permit expires.
if you have any additional questions concerning renewal of the subject permit, please contact4�en4
1
Sincerely,
W revs, Tk eWfo-rot,
Wren Thedford
Wastewater Branch
cc: Central Files
Mooresville Regional Office
NPDES Unit
1617 Mad Service Center, Raleigh, Nonh Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] Fax: [phone]JCuslomer SeNice. 1-877.623-6748
internet:: gnaw.nnwater,orq
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