NC0086924_Response to NOV-2018-LV-0823_20181219

/ Tyrrell County Board of Commissioners lklczi'
Post Office Box 449 1�14
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Columbia,
Teleph Telephone [phone] //���FNq���
Nathan T. Everett, Chairman David L. Clegg;yCo tnage aKe((Attorney
Carl L. Willis, Vice Chairman Penny Rhoc ( rkktto the Board
Nina B. Griswell
Lawrence S. Swain �`
Jordan R. Davis{=.tr
December 19, 2018
Mr. Robert Tankard
NC DEQ Division of Water Resources
943 Washington Square Mall
Washington, NC 27889
Re: Tyrrell County, NC
NPDES Permit No. NCO086924
NOV-2018-LV-0823
Dear Mr. Tankard:
Regarding the above -reference discharge permit, we received Notice of
Violation NOV-2018-LV-0823 for exceeding the Daily Maximum and Monthly
Average limit values for the month of August 2018. Please accept this letter as our
response to the NOV, requesting that you waive any civil penalty for the reasons
described below.
The limits for copper in this NPDES permit were added as part of the renewal
in September of 2017 without prior notice to Tyrrell County. Having never
experienced issues with copper in the past, Tyrrell County currently does not know
the cause of the elevated copper level nor do we have a reliable plan to reduce risk
of future non-compliance. At the direction of your staff, wd plan to request a
modification to the discharge permit allowing delaying the copper implementation
for four years, such that we can work with an engineering firm to evaluate the
problem(s) and devise a solution. We will copy you on all correspondence with the
NPDES Unit in the near future.

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As I am sure you understand, Tyrrell County does not have t e res to
implement significant treatment changes without proper planning.pyl�kely ar'ir
means applying for funding to implement the recommended solution'�9rn,<'
We will work closely with your staff as we evaluate the problem, welcoii%g
your experience and expertise on the subject. We sincerely appreciate your
consideration not waive any civil penalty associated with this NOV.
Sincerely
L.
David L. Clegg