NC0077992_Toxicity Testing_20170524

May 24, 2017
Mr. Derek Denard
N.C. Division of Water Quality
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Dear Mr. Denard:
RECEIVEDINCDEQIDWR
JUN 01:2017
water Quality eion
Permitting
We have reviewed the proposed changes to NPDES permit number NC0077992 and
would like to make additional comments. We hope to modify the proposed changes by
providing you with information that we believe support our opposition to some of the
changes.
Permit #NC0077992
Item # 1 Comments are for permit # NC0077992
Toxicity Testing
We know we cannot pass this test
So once again, we will use this opportunity to express our opposition to these tests.
Because we were required to do this test in the past on ceriodaphnia at 90%
concentrations. We feel that we will end up failing once again. What the R/O membranes
separate are primarily mineral salts and organics. The conductivity of our concentrate is
too high to support the life cycle of ceriodaphnia. We have made the required test
quarterly in the past years and have yet to pass a test at this plant. I am sure that should
we be forced to change over to this toxicity test for the next 4 years, without some sort of
changes, the result will be the same as they were in past permits. We hope that we
can keep our toxicity test the same as our last permit.
Item 42 Turbidity/PH
For turbidity and PH we have always been under the limit and understand that the WTP
Permitting Strategy is saying go to 2 times monthly. We have years of info showing that
we are not close to the limit and ask to stay like we are on current permit.

Item #3 Ammonia Nitrogen
For Ammonia Nitrogen we also understand what the WTP Permitting Strategy is saying
but once again we have years of data that shows it stays the same and ask to keep it the
same as our last permit.
WTP Permitting Strategy should be a guideline for new RO Water Tretment Plants but
with 25 years of test and data there should be ways to look at this data and reduce the
amount of test that are taken.We want to do our part but, someone needs to weigh the
cost of continuous test producing the same result for years against the expense.
These test you proposed to add or change may have relevance for a new facility where
there is no data, but we have been testing at this plant for 25 years.
Respectfully,
J
Clint Berry, Manager