NC0074268_Comments_20210607

TWOVE RS
11 T I l I I I f
We are TRU to our customers! RECEIVED .. ;
June 7, 2021 JUN 1,5 2021
NCDEQ/DWR NCDEQIDWRINPDES
NPDES Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Draft NPDES Permit Renewal
Permit NC0074268 Crowders Creek WWTP
Dear Mr. Coco:
Thank you for sending the draft of Crowders Creek WWTP's renewed NPDES permit which we received May
12, 2021. We have reviewed this draft permit and corresponding fact sheet, and appreciate the work in its
thorough preparation. In accordance with your request, the following comments are submitted for potential
modifications for the final permit:
• Allowing the testing of free cyanide in place of total cyanide has been proposed by NC DEQ as part of the
current triennial review. Two Rivers Utilities requests wording be added to specify that if testing for free
cyanide is approved, it would be an acceptable method for use in meeting the effluent cyanide permit limit
without requiring a permit modification.
• Two Rivers Utilities asks to verify that the cyanide sample for the effluent is intended to be a composite and
the hardness sample for the effluent is intended to be a grab.
• Please review the reference in Part I A.(1.) a. footnote 1. It appears that it should refer to Special Condition
A.(8.).
We appreciate DWR's work on this permit and have no other comments on the draft at this time. If I can be of
assistance, please feel free to contact me at 704-866-6726 or [e-mail].
Sincerely,
Stephanie Scheringer
Division Manager Wastewater Treatment
Two Rivers Utilities
CC: Charlie Graham -Treatment Plant Supervisor, Crowders WWTP
David Shellenbarger—Asst. WWTD Manager Compliance
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