NC0023906_Comment for Renewal_20150714

WILSON
NORTH CAROLINA
July 8, 2015
CERTIFIED MAIL
RETURN RECEIPT REQUESTED RECEIVEDIDENRIDWR
Mr. Yang Song JUL 14 2015
NCDENR—Division of Water Resources
NPDES Unit Water Quality
1617 Mail Service Center Permitting Section
Raleigh,NC 27699-1617
Subject: Comments to Draft NPDES Permit Renewal (NC0023906)
Dear Mr. Song:
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 June 3,
2015. After a thorough review of the draft permit, we have identified several items that we ask
you to consider modifying. I have listed them by page number below.
Page 2: Add: "one(1)mechanical bar screen at influent pump station".
Add: "one(1) serpentine conveyor at influent pump station".
Please clarify that the "two (2) service entrances to provide redundant power
source of electric power" applies only to the influent pump station, not the entire
WWTP.
Change: "two (2)automatic bar screens"to "two (2)mechanical bar screens".
Change: "mechanical bar screens"to"manual bar screens".
Remove: "two (2)preaeration basins(out of service)"
(these basins were modified and are replaced by the "two (2)flow equalization
basins")
Change: "one(1)biological nutrient removal tank"to "one (1)biological
phosphorus removal tank"
CITY OF WILSON Page 1 of 4
INCORPORATED 1849
WATER RECLAMATION FACILITY I PO.BOX 10 I WILSON,NORTH CAROLINA 2 7894-001 0 I [phone] I [phone]
EQUAL OPPORTUNITY EMPLOYER AFFIRMATIVE ACTION EMPLOYER

Subject: Comments to Draft NPDES Permit Renewal(NC0023906) July 8,2015
Change: "seven(7)extended aeration basins"to"seven(7) aeration basins for
biological nutrient removal".
Change"polishing ponds"to"polishing ponds(out of service)".
The ponds still exist but are not part of our treatment process.
Add: "chlorine feed system"
Add: "dechlorination feed system"
Page 3: Request that Dissolved Oxygen measurement frequency at the Effluent be
changed from"Daily"to"Twice/Week".
Change"Fecal Coliform"for Upstream&Downstream to read"Fecal Coliform2"
Request that Total Residual Chlorine measurement frequency at the Effluent be
changed from"Daily"to"Twice/Week".
Please verify the TN Load Limit of"157,887" lb/year. Our previous permit listed
a value of"157,886"lb/year.
Request that Temperature measurement frequency at the Effluent be changed
from"Daily"to"Twice/Week".
Change"3/Week" for Temperature at Upstream&Downstream to read"Footnote
2".
Request that Conductivity measurement frequency at the Effluent be changed
from"Daily"to"Twice/Week".
Change"3/Week" for Conductivity at Upstream&Downstream to read"Footnote
2".
Request that monitoring for Total Copper be removed from the permit. We would
continue to monitor as part of the facility's Pretreatment Long Term Monitoring
Program.
Request that monitoring for Dichlorobromomethane be removed from the permit.
We would continue to monitor when the Effluent Pollutant Scan is performed as
required by the permit.
Request that pH measurement frequency at the Effluent be changed from"Daily"
to"Twice/Week".
Page 2 of 4

Subject: Comments to Draft NPDES Permit Renewal(NC0023906) July 8, 2015
Remove"Monitor and Report"from the following parameters: Conductivity,
Total Copper, Dichlorobromomethane,and Effluent Pollutant Scan. (This
statement is not needed).
Page 4: Footnote 2: We request that instream monitoring requirements be removed.
(Point sources in the Neuse Basin are <50%of their allowable load so we do not
feel this requirement is necessary.)
Footnote 6: This should be worded so that all effluent TRC values that are less
than 50 µg/L shall be reported on DMR as"<50" µg/L.
The statement"There shall be no discharge of floating solids or visible foam in
other than trace amounts"is not needed and should be removed.
Page 6: Please verify the TN Load Limit of"157,887"lb/year in table A. (4.)a.
Our previous permit listed a value of"157,886"lb/year.
Page 8: In the middle column,please underline and italicize"Acid-Extractable
compounds:"so that it is differentiated as a header and not an analyte, as"Base-
neutral compounds:"is done below it in the same column.
Request that the due dates for Effluent Pollutant Scan reports be changed from
"December 31St of each designated sampling year"to"December 31st of each
designated sampling year,or within 90 days of sampling,whichever is latest".
We typically perform Effluent Pollutant Scans in conjunction with our Toxicity
testing, especially multi-species. We are required to do this testing in various
seasons and one of those would be in November. The December 31St deadline
could present some difficulty when we sample in the last quarter of the year.
Page 10: Please remove"Regardless of the submission method,the first DMR is due on the
last day of the month following the issuance of the permit or in the case of a new
facility,on the last day of the month following the commencement of the
discharge". This statement is already provided in"Part II - Standard Conditions
for NPDES Permits, Section D—Monitoring and Records, Item 2—Reporting"
and is not needed.
Page 11: Please verify latitude coordinate of 35°41' 14"and longitude coordinate
(Map) of-77°53' 45"listed on the map. We provided updated latitude coordinate of 35°
40' 37"and longitude coordinate of-77°54' 51"in the permit renewal application.
Our coordinates were determined from a personal GPS unit positioned at the
discharge pipe.
Page 3 of 4

Subject: Comments to Draft NPDES Permit Renewal(NC0023906) July 8, 2015
Please contact me at(252) 3' - 91 or via email at [e-mail] if you have any
• - i a• .. : :: _- •• •r i you ne d any additional information in regards to this matter.
Sincerely, 40111111410
Jimmy ' •. _en
Water Rec t: a .tion Manager
Cc: Dathan Shows, Chief Operations Officer
Barry Parks,Director of Water Resources
Gabriel Dusablon,Cauley•Pridgen—City Attorney
Paul Calamita,AquaLaw/NCWQA
Debra Collins, Water Reclamation Chemist
Laura Pruitt, Water Reclamation Compliance Coordinator
Page 4 of 4