NC0005274_More Information (Received)_20190402

REC-€IVEWD NR/DWR
Lowell Investments I, LLC
5320 Old Pineville Road, Charlotte,NC 28217 APR 2 2019
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Permit�iri9 Section
April 2, 2019
Via Certified Mail
Michael E. Templeton, Environmental Engineer
North Carolina Department of Environmental Quality
Division of Water Resources
512 North Salisbury Street
1617 Mail Service Center
Raleigh,NC 27669-1617
Re: 90-Day Notice—Incomplete Application—Request for Extension
NPDES Permit NC0005274
Lowell Investments WWTP
Gaston County
Dear Mr. Templeton:
We received your letter dated January 28, 2019 notifying us that the Division intends to
effectively terminate our permit if specified actions are not satisfactorily completed by May 3,
2019. We are actively working on plans to comply with these requirements.
Recent sludge sample analysis by NCDEQ Division of Waste Management(DWM) indicates the
presence of volatile components that may restrict disposal options for the sludge. DWM has
indicated that they plan to utilize existing remediation funds to contract sludge removal, and is
currently assessing scope and schedule while bidding the sludge removal work.
We are prepared to consolidate all remaining water into the largest tank for sampling prior to
final release via the approved outfall location. To prevent further accumulation of storm water in
the open-top tanks, a water removal coordinated with the sludge removal would be the most
efficient plan. Estimates from contractors that we spoke with previously have indicated a time-
frame of 2-4 weeks to remove the wastewater(including analytical requirements) and 4-6 weeks
to haul the sludge to an approved off-site disposal location. Because of the expected timeline for
wastewater removal, we are formally requesting a 60-day extension in order to coordinate the
wastewater removal with the sludge removal.
Once DWM has contracted sludge removal specifics and schedule, we can proceed with
completion of all items required in your 90-Day Notice. We are requesting a response to the
extension request by April 8, 2019 in case we need to maintain the wastewater removal schedule
under the permit required by the 90-Day notice.

90-Day Notice—Incomplete Application—Request for Extension page 2 of 2
NPDES Permit NC0005274
March 27, 2019
Please contact me if you have any questions concerning this response.
Sincerely,
Houston Roberts
Partner, Lowell Investments I, LLC
Cc: Harry Zinn
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