NC0024881_NOD2018PC0034_20180419

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
April 19, 2018
David Bracken, Interim Director of Public Works
City of Reidsville
230 West Morehead Street
Reidsville, NC 27320 RECEIVED/DENR/DWR
APR 24 2018
Subject: Comments on Response to Notice of Deficiency
NOD Tracking Number NOD-2018-PC-0034 Water Resources
Permitting Section
NPDES Permit NC0024881
Reidsville WWTP, Rockingham County
Dear Mr. Bracken:
Our office received a response from Mr. Ben Bani regarding the subject Notice of Deficiency on March
20, 2018. We appreciate the efforts made to maintain compliance with the NPDES permit.
Composite Sampling
Mr. Bani stated that he contracted with a third party to set up the flow proportional influent and
effluent samplers. Mr. Bani subsequently stated that the samplers had been set to conduct flow proportional
sampling as of March 29, 2018.This satisfies the Composite Sampling deficiency.The samplers should be
checked periodically to ensure that the appropriate volume is collected (at least 100 mL per aliquot), and
adjusted as necessary.
Power Failures
Mr. Bani provided a document from the Division to the City dated December 20, 1995 regarding the
upcoming construction of the Haw River Outfall. In the letter, one general comment stated:
"A standby generator for the proposed effluent pump station will not be required if it can be
demonstrated'that (1)the plant has experienced no serious power interruptions over the past 5 years
and that (2) in the event it becomes necessary to discharge plant effluent from the pump station to
Little Troublesome Creek during a power outage,there is sufficient existing generation capacity to
maintain aeration and disinfection."
Mr. Bani indicated that the City's belief was that this statement provided an exemption from the
Permit's power reliability requirement at the effluent pumps.
This statement resembles 15A NCAC 02H .0124(2)(c), which provides that power reliability measures
may include "a demonstration that the waters that would be impacted by a power failure are classified as C
waters,the applicant may be allowed to show a history of power reliability that would demonstrate that an
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alternative power source would not be needed or demonstrate other measures which provide comparable
assurances that surface waters will not be impacted during power outages."
Prior to construction of the Haw River Outfall, effluent was discharged to Little Troublesome Creek,
and this is the waterbody affected by power failure. In 1995, Little Troublesome Creek was Class C, NSW.
Reidsville found it necessary to relocate the outfall to the Haw River due to ongoing inability to meet the
toxicity requirements in Little Troublesome Creek. After the new outfall was completed, Little Troublesome
Creek was not maintained as a secondary discharge location. Its classification at the old outfall was
subsequently changed to Class WS-V, NSW in 2009 with the implementation of the Jordan Water Supply
Nutrient Management Strategy (see 15A NCAC 02B .0262(1)). Furthermore, any power failure would result in
a bypass of the effluent pumps and unpermitted discharge to Little Troublesome Creek. A file review revealed
that at least one such bypass occurred in July of 2017.
As Little Troublesome Creek is no longer Class C,the 02H .0124(2)(c) statement no longer applies.
Therefore, in order to gain compliance with Part II, Section C.7, Power Failures, some form of reliability
measure must be provided.
Our office suggests obtaining compliance with this condition via one of the following methods:
1. Install emergency generators for the effluent pumps. Submit a time frame for installation to this
office for review:Submission of a time frame would not necessarily prevent enforcement action
from being taken in case of a bypass due to power failure. Alternatively, you may submit a request
in writing to the NPDES Complex Permitting Unit to attempt to have a compliance schedule
introduced to the next permit renewal.
2. Establish Little Troublesome Creek as an emergency or secondary outfall. However, preliminary
analysis by Gary Perlmutter of the NPDES Complex Permitting Unit indicated that this option may
not be feasible due to the strict effluent limits that would be placed on the discharge. If you would
still like to pursue this option, a written request must be submitted to the NPDES Complex
Permitting Unit.
Please respond to this letter within 30 calendar days of receipt indicating your plan to attain compliance with
this requirement. Finally, please be reminded that any bypass is subject to the prohibition and notification
requirements of Part II, Section C.4, unless exempted by Part II, Section C.4(a).
If you have any other questions please do not hesitate to contact Paul DiMatteo of the Winston-Salem
Regional Office at [phone] or [e-mail].
Sincerel
,e(1
Sherri V. Knight, P.E., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
CC: WQS Winston-Salem Regional Office—Enforcement File
NPDES Compliance/Enforcement Unit—Enforcement File
Gary Perlmutter—NPDES Complex Permitting Unit
Central Files