NC0023906_Comments_20201002

WILSON
NORTH CAROLINA
October 2,2020
RE„LIVED
OCT 0 7 2020
CERTIFIED MAIL
RETURN RECEIPT REQUESTED NCDEQ/D I
Q RNP
DES
Mr.Nick Coco
NCDEQ—Division of Water Resources
NPDES Complex Permitting Unit
1617 Mail Service Center
Raleigh,NC 27699-1617
Subject: Comments to Draft NPDES Permit Renewal(NC0023906)
Dear Mr. Coco:
The City of Wilson thanks you for your efforts in renewing our NPDES permit and appreciates the
opportunity to comment on the draft permit you provided to us with your letter dated August 25,2020.
We received the information by U.S. Mail on September 4,2020. Overall,we are very pleased with the
permit as drafted. However,after a thorough review of the draft permit,we have identified a few items
that we ask you to consider modifying. I have listed them by page number below.
Page 1: Request that the permit become effective on the 1 St day of the month. This helps prevent
any discrepancies in the monitoring requirements that may not match between the current
active permit and the new one becoming effective.
Page 1: Request that the expiration date of the permit be a full five years from the effective date
of the permit.
Page 2: Request the Monthly Average limit for flow be changed from 14.0 MGD to 14 MGD.
Page 2: Request that the monitoring frequency for Dissolved Oxygen,Total Residual Chlorine,
Temperature,pH,and Conductivity be changed from"Daily"to"2/week". We recognize
that monitoring requirements for these parameters are established in 15A NCAC 02B
.0508,but also within that same section,per 15A NCAC 02B .0508(b)(1),such
requirements may be waived or modified to the extent that the Director determines to be
appropriate. They City of Wilson has an excellent compliance history with each of these
parameters and daily monitoring should not be required.
Page 2: Request the Daily Average limit for Dissolved Oxygen be changed from>_7.0 mg/L to
>6.0 mg/L. In the Fact Sheet generated for this permit renewal,the following
information was stated:
CITY OF WILSON Page 1 of 4
INCORPORATED 1849
WATER RECLAMATION DIVISION I PO BOX 10 I WILSON NORTH CAROLINA 27894 0010 I [phone] I [phone]
EQUAL OPPORTUNITY EMPLOYER I AFFIRMATIVE ACTION EMPLOYER

Subject: Comments to Draft NPDES Permit Renewal(NC0023906) October 2, 2020
In August 1979, an intensive survey of Contentnea Creek was conducted that
recommended a dissolved oxygen limit of no less than 7.0 mg/L.
This elevated limit of>7.0 mg/L is determined from a study that was performed over 41
years ago. It is surely not representative of the current flow conditions of Contentnea
Creek. For instance, in September 1999,during Hurricane Floyd,the newly upgraded
Buckhorn Reservoir was immediately filled to overflowing during this single event.
Since September 1999,the minimum release from Buckhorn Reservoir has continuously
been at least 7.6 cfs with the exception of a very brief period during the drought of 2007-
2008 (please reference enclosed letters from NC-DEHNR dated 6/4/1991 &Army Corp
of Engineers dated 2/21/1997). Based on this information,the City of Wilson feels that a
modification of the Daily Average limit for Dissolved Oxygen to>_6.0 mg/L is justified.
Page 4: In Footnote#2,we request that"U—Upstream at Old Black Creek Road"be changed to
"U—Upstream at Commerce Road". Commerce Road is a side road off of Old Black
Creek Road and is actually closer to our upstream monitoring point. The upstream
sampling location would still be the same,only the descriptive name would change.
Additionally,there is a bridge located on Old Black Creek Road that crosses Contentnea
Creek. That bridge location is downstream of our discharge point. Many years ago,the
City of Wilson did downstream monitoring at the bridge on Old Black Creek Road. We
are requesting this change to hopefully prevent any confusion.
Page 4: We request the removal of Footnote 3 that states:
The monthly average effluent BOD5 and TSS concentrations shall not exceed
15%of the respective influent value(85%removal).
The monthly average limits established in the permit for BOD5 and TSS make this
requirement unnecessary because we would meet it all the time as long as we are meeting
the numerical monthly average limits. Further,the City of Wilson has an excellent
compliance history with each of these parameters and we have no reasonable potential to
exceed the requirement specified in Footnote 3.
Page 4: We request that in Footnote 11,the 90%dilution value be considered for recalculation
based on a new 7Q10 value that will be addressed in a later comment.
Page 7: For Item A.(5.), in the first paragraph,we request that the 90%dilution value be
considered for recalculation based on a new 7Q10 value that will be addressed in a later
comment.
Page 9: For Item A.(6.)d.,please confirm that the address for report submittal of"1621 Mail
Service Center"is correct. In our current active permit and also in Item A.(5.)of this
permit,the address is listed as"1623 Mail Service Center".
Page 10: We request that the following text be removed:
Until such time that the state's eDMR application is compliant with EPA's
Cross Media Electronic Reporting Regulation (CROMERR),Permittees will be
required to submit all discharge monitoring data to the state electronically
using eDMR and will be required to complete the eDMR submission by
printing,signing,and submitting one signed original and a copy of the
computer printed eDMR to the following address:
Page 2 of 4

Subject: Comments to Draft NPDES Permit Renewal(NC0023906) October 2, 2020
NC DEQ/Division of Water Resources/Water Quality Permitting Section
ATTENTION:Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
This issue has been resolved and we are no longer required to complete the eDMR
submission by printing,signing, and submitting one signed original and a copy of the
computer printed eDMR.
In addition to the comments provided above for NPDES NC0023906 draft permit,we ask that you also
consider the following comments with regards to the Fact Sheet for NPDES Permit No.NC0023906:
Page 2: In Table 2,"Receiving Waterbody Information",the City of Wilson requests that the
Summer 7Q10 value of 1.3 cfs be reconsidered and modified. While it is not specifically
stated in this Fact Sheet,in the Fact Sheet generated August 2015 for the prior permit
renewal,it was stated:
The flow in Contentnea Creek is regulated by release from the upstream
Wiggins Mill Reservoir. The minimum release is 1.3 cfs and DWR has used
this value as a 7Q10 flow.
The first concern is that the value of 1.3 cfs is incorrect. The absolute minimum required
release is actually 1.4 cfs (please reference enclosed letters from NC-DEHNR dated
6/4/1991 &Army Corp of Engineers dated 2/21/1997). Further,the minimum release of
1.4 cfs would only occur during the most extreme of drought conditions. Wiggins Mill
Reservoir receives a portion of its flow via a regulated release to Contentnea Creek from
Buckhorn Reservoir which is located approximately ten miles upstream. In addition to
the regulated release from Buckhorn Reservoir,the Wiggins Mill Reservoir also receives
flow from all the tributaries to Contentnea Creek that are located between the Buckhorn
and Wiggins Mill Reservoirs. In September 1999,during Hurricane Floyd,the recently
upgraded Buckhorn Reservoir was filled to overflowing. Since September 1999,the
minimum release from Buckhorn Reservoir has continuously been at least 7.6 cfs with
the exception of a very brief period during the drought of 2007-2008. North Carolina
experienced the worst documented drought on record during 2007-2008. These records
from NOAA date back more than 125 years to 1895. (Please see enclosed chart titled
"North Carolina Palmer Drought Severity Index(PDSI)"from NOAA National Centers
for Environmental information, Climate at a Glance:Statewide Time Series). This would
have to be acknowledged as the ultimate worst case scenario to impact stream flow and
even a 7Q10 value determined from this time frame would actually be a 7Q125 value
(lowest continuous 7 day flow in 125 years). During the last 10 years,the City of Wilson
has maintained a minimum release from Buckhorn Reservoir of at least 7.6 cfs. Utilizing
the value of 7.6 cfs would still be a very conservative 7Q10 to represent minimal flow
within Contentnea Creek for the most recent 10 years. Due to the other tributary flow
received by Contentnea Creek above and below the Wiggins Mill Reservoir,the City of
Wilson is extremely confident that the actual 7Q10 over the past 10 years is significantly
greater than the continuous release of 7.6 cfs provided from Buckhorn Reservoir. Based
upon the information provided,the City of Wilson requests the 7Q10 be increased from
1.3 cfs to at least 7.6 cfs until additional stream flow studies can be completed in the
future that would indicate an even higher 7Q10 value is appropriate. Please also utilize
Page 3 of 4

Subject: Comments to Draft NPDES Permit Renewal(NC0023906) October 2, 2020
the new 7Q10 value to recalculate any limits issued in this permit that would be impacted
by the increase of the 7Q10 value.
This City of Wilson greatly appreciates your consideration of these comments and looks forward to
receiving your response. Please contact me at(252)399-2491 or via email at [e-mail] if
you have an .uestions or co • or if you need any additional information in regards to this matter.
Sincerely, •
Jimmy ' 'dgen
Water Rec m tion Manager
Cc: :arry Parks,Director of Water Resources
Paul Calamita,AquaLaw/NCWQA
Nicholas Eatmon, Operations &Maintenance Supervisor
Laura Pruitt, Water Reclamation Compliance Coordinator
Andrew Mlot, Water Reclamation Chemist
Enclosures: Letter from NC-DEHNR dated 6/4/1991
Letter from Army Corp of Engineers dated 2/21/1997
Chart titled"North Carolina Palmer Drought Severity Index(PDSI)"
Page 4 of 4

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a7' J
$!'! JUG 12 15 c
1
State of North Carolina f
Department of Environment, Health, and Natural Resources
Division of Water Resources
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor John N. Morris
William W. Cobey, Jr., Secretary Director
June 4 , 1991
Mr. Robert A. Berndt, P.E.
Hazen and Sawyer, P.C.
4011 Westchase Blvd. , Suite 500
Raleigh, North Carolina 27607
Dear Mr. Berndt:
We have reviewed your plans for the operation of the
proposed Buckhorn Reservoir expansion to provide additional water
supply storage for the City of Wilson. One of the primary
concerns of this Division is the operation of the proposed
project and its effects on d:.:wnstream flows and the related uses
of these flows.
We have no objections to the project if its operating
criteria are similar to those described in your May 22 , 1990
letter to me. Project operations should include the following
conditions:
1 . Stage one: An instantaneous minimum flow of
7 . 6.cfs (4 .9 MGD) is released from the dam as
long as reservoir storage is greater than
70 percent of full capacity.
2 . State two: An instantaneous minimum flow of .
5.3 cfs (3 .4 MGD) is released from, the dam when
reservoir storage is less than or equal to
70 percent of full capacity.
3 . State three: An instantaneous minimum flow of
1 .4 cfs (0 .9 MGD) , the estimated 7Q10 , is released
from the reservoir when reservoir storage is at or
below 50 percent of full capacity.
4 . The minimum flows released from Buckhorn Reservoir
will be passed through Wiggins Mill Reservoir such
that the instantaneous minimum release from Wiggins
Mill will be the same or greater than the release
from Buckhorn Reservoir.
C-17
P.O. Box 27687, Raleigh, North Carolina 27611.7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

5 . The locations of the staff gages and their ratings
or gage heights corresponding to the minimum
release values should be provided to the Division
of Water Resources. The gages should be calibrated
at least every two years with calibration details
provided to this Division.
The Environmental Assessment (EA) should include the
actual elevations of the 70 and 50 percent full reservoir
capacity "trigger points. " Provisions for monitoring the minimum
flow and reservoir level with staff gages should also be
described in the EA. Staff gages should be placed immediately
downstream of Buckhorn and Wiggins Mill Reservoirs and reservoir
levels recorded for Buckhorn. The document should include the
City of Wilson' s water conservation plan. This plan should
describe the wat-:r conservation measures the City will implement
at each s: age of the operating plan as defined above.
Please contact me if you have any questions or need
additional information.
Sincerely,
.- egr/Iikey\LC:
Steven E. Reed
Environmental Supervisor
SER/va
cc: John Wray, DWR
Woody Yonts, DWR
William P. Bartlett, City of Wilson
Don Cordell, Hazen & Sawyer
C-18

/4-r DEPARTMENT OF THE ARMY '
a, WILMINGTON DISTRICT, CORPS OF ENGINEERS
ICI iy
to, m P.O.BOX 1890
WILMINGTON,NORTH CAROLINA 28402-1890
1,„ v`
-bms February 21, 1997
IN REPLY REFER TO
Regulatory Branch
Action ID. 199401973
Mr. Charles W. Pittman
Deputy City Manager
Post Office Box 10
Wilson, North Carolina 27894
Dear Mr. Pittman:
In accordance with your written request of March 1, 1994, and the ensuing
administrative record, enclosed is a permit to place dredged or fill material
into Contentnea Creek approximately 600 feet downstream of the existing Buckhorn
dam in order to expand the Buckhorn Reservoir from 740 acres to 2303 acres.
If any change in the authorized work is required because of unforeseen or
altered conditions or for any other reason, the plans revised to show the change
must be sent promptly to this office. Such action is necessary, as revised plans
must be reviewed and the permit modified.
Carefully read your permit. The general and special conditions are
important. Your failure to comply with these conditions could result in a
violation of Federal law. Certain significant general conditions require that:
a. You must complete construction before December 31, 2002.
b. You must notify this office in advance as to when you intend to commence
and complete work.
c. You must allow representatives from this office to make periodic visits
to your worksite as deemed necessary to assure compliance with permit plans and
conditions.
The enclosed Notice of Authorization, ENG Form 4336, must be conspicuously
displayed at your worksite.
SinQeTel y,reARZ).0.1"3--41C- 7-1- 1-1
Terry It. Y4ungbluth
Colopel, U,S. Amy
Diotrict $05ineer
Enclosures

-7
-4-
a. Damages to the permitted project or uses of it because of other
permitted or unpermitted activities or from natural causes.
b. Damages to the permitted project or uses of it because of current or
future Federal activities initiated for the public.
c. Damages to other permitted or unpermitted activities or structures
caused by the authorized activity.
d. Design and construction deficiencies associated with the permitted
work.
e. Damage claims associated with any future modification, suspension, or
revocation of this permit.
10. Minimum flow discharges from the dam will be in accordance with the
requirements of the North Carolina Division of Water Resources' letter dated
June 4, 1991, to Mr. Robert Berndt (see Draft EIS, Appendix C, page C-17) .

https://www.ncdc.noaa.gov/cag/statewide/time-series/31/pdsi/all/1/1895-
2020?base prd=true&begbaseyear=1901&endbaseyear=2000&filter=true&filterType=binomial
..... .
North Carolina Palmer Drought Severity Index (PDSI)
— Binomial Filter
.-,,on- r 6.0C
P DS t 5 6,6 1
1 1
4.00-» -4.00
i
' 2.00- I `2.00
'ill iii i J 1111 i ,
, ,
1901-2000 Mean: 0.00
o.oc o.oc
-2.00-- -.-,0C
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-6.00 r r r -6.00
Jan 1895 Sep 1911 May1928 !an 1945 Sec 1961 May 1978 Jan 1995 Jan 2008 Aug 2020
• NOAA National Centers for Environmental information, Climate at a Glance: Statewide Time Series, published September 2020,
retrieved on October 1, 2020 from https://www.ncdc.noaa.gov/cag/