NC0032719_Email (NPDES Comments)_20190813

Strickland, Bev
From: May, David
Sent: Tuesday, August 13, 2019 4:27 PM
To: Bullock, Robert; Sipe, Randy; Vinson, Scott
Cc: Tankard, Robert
Subject: FW: [External] DRAFT NPDES Comment Letter
Attachments: Draft Letter_Chowan County NPDES Comments.docx
FYI
David May
Regional Supervisor —Water Quality Regional Operations Section
Department of Environmental Quality — Division of Water Resources
252-948-3939 office
david.maya-ncdenr.gov
943 Washington Square Mall
Washington, NC 27889
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Greg Churchill <[e-mail]>
Sent: Tuesday, August 13, 2019 3:59 PM
To: May, David <[e-mail]>; Tankard, Robert <[e-mail]>
Subject: [External] DRAFT NPDES Comment Letter
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
David and Robert -
I have sent the attached letter to Chowan County for their review.
Should you have any further suggestions, please let us know.
Thanks-

Greg Churchill, P.E.
President
Rivers & Associates, Inc.
107 E. Second Street
Greenville, N.C. 27858
P: [phone]
F: [phone]
C: [phone]
Please visit our website:
http://www.riversandassociates.com

DRAFT
Ms. Brianna Young
Compliance and Expedited Permitting Unit
NCDEQ Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699
SUBJECT: Draft NPDES Permit NC0032719
Valhalla WTP
Grade I Physical Chemical WPCS
Chowan County
Dear Ms. Young:
We have reviewed the draft NPDES Permit forwarded July 24, 2019, and have the following
comments/requests for your consideration:
Supplement to Permit Cover Sheet
1. The two (2) circular waste holding basins are proposed to replace the existing sand quarry.
2. We concur with the NCDEQ Washington Regional Office recommendation to revise the
existing discharge from an unnamed tributary of Pollock Swamp (Pasquotank River Basin)
to an unnamed tributary of Bennett's Millpond (Chowan River Basin).
Part I, A. (1) — Effluent Limitations and Monitoring Requirements
3. We request the monthly average limit of 230 mg/L for Total Chloride be eliminated in
favor of monitoring only. The existing discharge condition is temporary as the County is
working diligently under voluntary Special Order by Consent (SOC) to (1) remove the
discharge to the existing onsite sand quarry, (2) improve treatment of the filter backwash
and softener regeneration waste stream within proposed waste settling tanks, and (3)
discharge the treated effluent into more suitable receiving waters. The existing discharge
permit does not contain a limit for Total Chloride, rather monitoring only is required. If
the 230 mg/L Total Chloride limit is imposed within the limit sheet for the existing
discharge, the County will be in routine violation. Please consider maintaining the Total
Chloride monitoring only requirement while the County works to improve the effluent
treatment and discharge.
4. We request that Footnote 5 be eliminated from the permit. Footnote 5 ties the Total
Chloride limit and monitoring requirements to a Compliance Schedule included in Part I,
A. (6). As noted above the County is working to make improvements to the Valhalla WTP
within the schedule dictated by the voluntary SOC. In the event that circumstances justify
an adjustment to the schedule, this can be addressed through the Washington Regional
Office and/or the Environmental Management Commission as appropriate. Including a
compliance date within the NPDES permit requires additional effort, time and cost on the
part of the County to amend if a justifiable reason to do so exists. We do not see a benefit
in including the compliance date, and view it as a potential unnecessary hardship. Please
consider removing Footnote 5 and the associated Compliance Schedule of Part I, A. (6)
from the permit.

5. Please revise the footnote associated with Hardness to refer to Footnote 6 in lieu of
Footnote 5.
6. Please revise the footnote associated with Whole Effluent Toxicity to Footnote 7 in lieu of
Footnote 6.
Part I, A. (5) — Instream Sample Locations
7. Our CORMIX Consultant and Engineer have previously requested that the mixing zone
extend 25 meters from the effluent diffuser. The draft NPDES Permit indicates a distance
of 11 meters. We request that the in -stream sampling locations be extended from I I meters
to at least 12 meters to exceed the predicted CORMIX near -field mixing zone of 11.61
meters. This area is miniscule relative to the channel width and certainly would allow for
the free passage of organisms around the mixing zone.
Part I, A. (6) — Schedule of Compliance (Outfall 001)
8. We request that the Schedule of Compliance be eliminated as discussed in Comment 2 in
Part I, A. (1) above.
Receiving Stream Map
9. Revise to reflect current discharge location as described in Comment 1 above.
Your assistance in facilitating these requested modifications is greatly appreciated. Should you
have any questions, please feel free to call.
Sincerely,
Kevin Howard
Chowan County Manager
cc: David Tawes, Chowan County Water Department Director
Gregory J. Churchill, P.E., Rivers & Associates, Inc.
Emma H. Shipley, P.G., Groundwater Management Associates, Inc.
James K. Holley, P.G., Groundwater Management Associates, Inc.
David May, NCDEQ WARO Supervisor
Robert Tankard, NCDEQ WARO Assistant Regional Supervisor