WQCS00383_Recommendations_20180628

People WorkingTOWN OF NAVASSA Town Council
334 MAIN STREET Eulis A.Willis,Mayor
NAVASSA,NC 28451 Milton Burns
Phone: [phone] Athelston Bethel
Fax:[phone] Minnie Brown
For People www.townofnavassa.org Antonio Burgess
Jerry Merrick
ATTN: Deborah Gore, PERCS Supervisor Charlena Alston,Town Clerk
North Carolina Division of Water Quality
Pretreatment, Emergency Response and Collection Systems Unit
1617 Mail Service Center
Raleigh, NC 27699-1617 RECEIVED/DENR/DWR
Re: Permit No. WQS00383 JUNater 2esou8 2018
WRrces
Dear Sir/Madam: Permitting Section
Thank you for your correspondence dated May 31, 2018. The Town of Navassa has been
primarily engaged in selecting a new collection system operator prior to the expiration of our
Contract with Brunswick County. Envirolink will work with us to help us through the permitting
process.
With respect to the permit directive issued by your department, we respectfully reject
the amount of flow the permit required.The Town of Navassa does not use 200,000 gallons per
day in our collection system. That number is above and beyond our current permitting needs
and is factually incorrect number. We respectfully request a delay in filing our Permit until that
number can be tested and quantified.
This number has been part of an issue on how the Town has been overlooked by
Brunswick County. Our collection system includes portions collection lines that serve the H2go
Sanitary district and that Sanitary district flow has been attributed to the Town's daily totals. In
addition, there was a one-time spill that was 95% H2go flow that was being collected in
Navassa's system and was attributed to Navassa and drove upward our yearly flow numbers as
well as our future projected capacity usage. We reported both issues to Brunswick County, our
former collection system maintenance partner,to no avail. This is why the Town decided to
obtain our own Collection System Operator instead of retaining our agreement with Brunswick
County.
We ask for an extension of time until the North Brunswick waste water treatment
partners (NBWWTPP) complete the construction of a "bypass system" (currently WIP)that will
remove the H2go flow from Navassa's collection system and we can accurately gauge, and in
fact count, our true daily flow.
We acknowledge that the current Permit is less than desirable, and we are committed
to obtaining our own permit as soon as possible. Please respond to us immediately, so that we
can engage our contractor to pursue the permit application.Thank you in advance for your
considerations
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Mayor Eulis A Willis