NC0020184_Draft Permit Renewal_20170215

February 15, 2017
Ms. Teresa Rodriguez
NPDES Complex Permitting Unit
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Draft NPDES Permit Renewal
Permit NC0020184
Long Creek WWTP
Gaston County
Class IV Facility
Dear Ms. Rodriguez:
Thank you for sending the draft of Long Creek WWTP's renewed NPDES permit which we received
February 2, 2017. We have reviewed this draft, and appreciate the thorough preparation and the
changes that were made in limits and monitoring frequencies following the data review. In
accordance with your request, we would like to submit the following comments for potential
modifications for the final permit:
• The address for the Long Creek WWTP should be listed as 3000 Old Spencer Mountain Road, Dallas
on pages 1 and 2. At the time of our permit renewal, we were unaware the section of road had
been renamed.
• A "coarse bar screen" is listed in the facility components on page 2 of the draft permit. No separate
coarse bar screen is in place at the Long Creek WWTP — all screening occurs on the mechanical bar
screens.
• A monthly TN Limit of 6 mg/L is listed through March 31St 2017. We ask that this be removed since
we do not believe there should be a winter concentration limit in effect during this period.
• "DWQ Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits for
Exceptionally Performing Facilities" states that facilities meeting the requirements may have
monitoring reduced to 2/week. The Long Creek WWTP met the requirements for TSS, ammonia and
fecal coliform, but monitoring was only reduced to 3/week. We respectfully ask that the minimum
requirement for this monitoring be reduced to 2/week.
• Standard Conditions were not included with the draft permit. We do not have any comments on
Standard Conditions if version 11/09/2011.1 is included.

We appreciate DWR's work on this permit and have no other comments on the draft at this time. If I
can be of any assistance please feel free to contact me at 704-866-6726 or email at
[e-mail].
Sincerely,
Stephanie Scheringer
Division Manager Wastewater Treatment
Two Rivers Utilities
CC: Doug Barker, ORC Long Creek WWTP
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