NC0036196_Response to Draft Permit_20210422

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:*' 9.L. CITY OF NEWTON Waste Water Treatment Plant
W.@ >T 4 ire
.1 af'„�,y a= P.O.Box 550 • Newton,N.C.28658 • phone [phone] • fax [phone]
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c,?855,
NCDEQ/DWR
NPDES Permitting Branch\1617 Mail Service Center
Raleigh,NC 27699-1617 RECEIVED
APR 22Z021
Subject: draft NPDES Permit Renewal NCDEQIDWRINPDES
Permit NC0036196
Clark Creek WWTP
Catawba County
Grade IV Biological WPCS
SIC Code 4952
Dear Mr. Coco,
The City of Newton reviewed the draft permit. There are two changes that the City of Newton believes is
too excessive. Total aluminum limits with monthly monitoring and total copper limits with monthly
monitoring. We currently test for aluminum and copper quarterly when preforming toxicity test. Data in
the past four years for both aluminum and copper, shows the City of Newton has not came close to the
proposed daily or monthly maximum limits. (See Attached Graph)
City of Newton did have a copper limit in the past.It was removed by the State,because years of testing
proved that set limits were not exceeded, or even come close. Furthermore,there were no violations for
exceeding the copper limits,thus the State removed copper limits.
Extra testing for aluminum and copper will add cost,which otherwise could be redirected to operations.
The City request that the extra testing for aluminum and copper be omitted from the draft permit. The
City intends continuing testing for aluminum and copper during quarterly toxicity test. If we do see
changes, then we will notify the State and would not object to increasing the testing and having a limit
set.
Please call me if you have any questions.
Si 7)),,t)Y�4�fEric JWasteer Treatment Plant Superintendent
City of Newton
PO Box 550
Newton NC 28658
828-695-4328
[e-mail]

Month Zinc(mg/L) Copper(mg/L) Copper(ug/L) Aluminum (mg/L) Aluminum (ug/L)
March 0.047 0.006 6.00 0.019 19.00
June 0.035 0.010 10.00 <0.050 <50.00
O September 0.013 0.005 5.00 0.083 83.00
N
December 0.037 0.006 6.00 <0.050 <50.00
March 0.044 0.006 6.00 <0.050 <50.00
00 r-I June 0.042 0.007 7.00 0.087 87.00
O September 0.020 0.011 11.00 0.056 56.00
N
December 0.138 0.035 35.00 0.056 56.00
March 0.040 0.008 8.00 0.119 119.00
0I-I June 0.038 0.009 9.00 0.092 92.00
O September 0.024 0.009 9.00 0.073 73.00
N
December 0.022 0.006 6.00. 0.052 52.00
March 0.040 0.009 9.00 0.067 67.00
0 N June 0.018 0.014 14.00 0.006 6.00
0 September 0.012 0.008 8.00 0.057 57.00
N
March 0.030 0.005 5.00 0.058 58.00