NC0024244_Comments_20170322

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ALBEMARLE
NORTH CAROLINA
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Public Utilities Department
March 22, 2017
Ms. Jennifer Busam
NCDEQ— Division of Water Resources
Water Quality NPDES Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Draft NPDES Permit Renewal - Comments
City of Albemarle Long Creek WWTP
NPDES Permit NCO024244
Stanly County, NC
Dear Ms. Busam:
www.albemarlenc.gov
PO Box 190
144 North Second Street
Albemarle, NC 28002-0190
WAR 212 017
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The NCDEQ Water Quality Permitting Section recently issued the City of Albemarle a draft NPDES
Permit pertaining to the Long Creek WWTP (NPDES Permit No. NC0024244). There were"'a
number of changes in the conditions and allowable limits within the existing permit with the key
changes being the incorporation of the new dissolved metal standards. The purpose of this letter
is to provide comment with respect to the timeframes laid out for compliance within -the draft
permit. The City of Albemarle feels that it will be difficult to accomplish all the tasks needed to
comply with the new permit limits in the time allotted. These tasks will consist of, but not limited
to, identifying all sources of these metals entering the collection system, amend the "headworks
analysis" for each Significant Industrial User (SIU), and conduct a study to examine cost effective
methods to remove Total Silver, Total Copper, Total Cadmium, and Chromium VI. After the
completion of these tasks, new treatment systems will need to be designed, constructed, and
commissioned to achieve compliance.
The City of Albemarle will need to conduct a study of our wastewater collection system in order
to identify the major contributing sources of the targeted metals. This study phase could take as
much as two (2) years in order to locate all sources and understand how the usage patterns for
each SIU change during a year. Once acknowledged, new localized limits will need to be
established -and the existing pre-treatment agreement(s) will need to be revised. The evaluation
of treatment systems to, address the total metal removal needs as well as the design,
construction, and commissioning of the treatment systems will have similar timeframes. In
combination, these elements would normally consume the entire compliance timeframe
contained in the draft permit.

The addition of treatment units at the Long Creek WWTP for metal removal may not be feasible
and/or effective from both a treatment and cost perspective. It is likely that any new treatment
system(s) for metal removal will need to be at the source point at each SIU facility identified. This
will likely result in a hardship for the local industries in the form of capital expenditures and
additional operating overhead, which will be needed to meet the desired pre-treatment levels
and to achieve compliance with the NPDES Permit. One local industry who may be a suspect
contributor to the metal levels entering the facility is a major employer in Albemarle. It goes
without saying that any adverse economic impact on an industry results in an adverse economic
impact to the City. Funding assistance through the typical 'DEQ programs (i.e. SRF, etc.) are
focused on improvements to government owned treatment facilities and are generally not
available to industries for the addition of treatment systems.
Protecting water quality and the environment is an extremely important mandate of the City and
our staff. However, we must also recognize the potential economic impact on our industrial base
in executing that mandate. It is the intent of the City to approach compliance with the new permit
in a cooperative manner with our industries. As such, the City of Albemarle will need to work
with our industries to explore alternative funding options that are focused on assisting and
maintaining industries in North Carolina. The funding cycles associated with these alternative
processes have long time frames, some in the range of 24 to 36 months. The State of North
Carolina Department of Commerce and United States Economic Development Administration
(EDA) has several funding programs that focus on job retention and assist industries with making
needed improvements similar to what will be needed to ensure compliance with the new metal
limits contained in the NPDES Permit. A longer overall compliance timeframe within the NPDES
Permit will enable Albemarle and the industries to work cooperatively together and navigate the
extended funding processes to assist with the design and construction of such treatment
facilities.
Therefore, the City of Albemarle respectfully requests NCDEQ- DWR to consider an additional 24
month extension of the proposed timelines for compliance within the Draft NPDES Permit. It is
the goal of The City of Albemarle to be in compliance with all permit limits and conditions set
forth in the draft permit and the extension, if provided, will help the City and our industries
achieve this goal...

The City appreciates your consideration of our request and your assistance as we diligently work
to become compliant with the new NPDES permit requirements. If you have any questions
regarding the technical issues related to this request, please don't hesitate to contact me
(704.984.9608; [e-mail]) or Ben Clawson ([e-mail]) with
Municipal Engineering Services in Garner at 919-772-5393.
Respectfully
CITY OF BEIVIARLE
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Michael Leonas
Director - Public Utilities
CC: Michael Ferris, City Manager — City of Albemarle
Brandon Plyler, ORC - Long Creek Wastewater Treatment Facility - City of Albemarle
Mark Donham, Economic Development Director —City of Albemarle
Ben Clawson, Municipal Engineering Services Co. PA
Michael McAllister, Municipal Engineering Services Co. PA