NC0074268_Comments to Drarft Permit_20211020

TW-(NrT I L I T I E S
We are TR U to our customers!
October 8, 2021
NCDEQ/DWR RECEIVED
NPDES Permitting Branch
1617 Mail Service Center OCT 2 0 2021
Raleigh, NC 27699-1617
NCDEQ/DWRINPDES
Attn: Ms. Diana Yitbarek
Re: Draft NPDES Permit Renewals
Permit NC0074268 Long Creek WWTP
Permit NC0006033 Eagle Road WWTP
Dear Ms.Yitbarek:
Thank you for sending the drafts of Long Creek and Eagle Road WWTPs' renewed NPDES permits which were
received September 13, 2021. The City of Gastonia has reviewed these draft permits and corresponding fact
sheets, and appreciates the work in their thorough preparation. In accordance with your request,the City of
Gastonia submits the following comments for potential modifications for the final permits:
Long Creek WWTP—NPDES#NC0020184
• The draft permit lists a monthly effluent limit for TP of 1.0 mg/L. The fact sheet states that this limit had
been in effect and is continuing; however, in the current permit the total phosphorus concentration limit
ended on 12/31/2017 (when the mass load limit took effect) and only monitoring and reporting is
currently required regarding the total phosphorus concentration.The removal of this limit is also
documented in section 6.7 of the permit's Fact Sheet and is consistent with the manner in which the
allocations are described as being expressed in this section of the Fact Sheet. The City of Gastonia
strongly requests that this monthly average limit be removed and that the phosphorus allocation
continues to be expressed solely as a mass load limit.
• The facility components listed in item 1 on page 2 of the draft permit do not fully reflect the components
at Long Creek WWTP.
o The influent pump station is listed twice.
o Long Creek WWTP has two mechanical bar screens.
o Two aeration basins is not fully representative of four trains of anaerobic, anoxic and oxic basins
that are part of these structures. The current version of the permit lists these as"dual basins for
biological nutrient removal."
o Long Creek WWTP does not have two tertiary filters. There is one tertiary filter that includes 8
cells.
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o A solids contact reactor exists but is not an operable part of the treatment system.
o Long Creek WWTP has an intermediate lift station and a waste activated sludge system that are
not included in this list.
• Section I A(8) 1. of this draft permit requires that "Until such time as the state's eDMR application is
compliant with EPA's Cross-Media Electronic Reporting Regulation (CROMERR), permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be
required to complete the eDMR submission by printing, signing, and submitting one signed original and a
copy of the computer printed eDMR ..." The City of Gastonia has previously been informed that signed
copies of the eDMR are no longer required to be submitted and asks that this section be removed if it is
not applicable.
• Section 1 of the Fact Sheet for this permit details an issue with plastics and fiberglass contamination.
There was a fiberglass contamination issue at Long Creek WWTP, but the plastics issue resulting from
Syncot Plastics occurred at Eagle Road WWTP. Due to these separate issues, biosolids at both wastewater
plants were pressed and landfilled.
• In Section 12 of the Fact Sheet for this permit under the parameter for Total Phosphorus, a MA of 1
mg/L is listed for"Current Permit Limits and Monitoring Frequency" but that limit was removed
12/31/2017. Monitor and Report should be listed in that section for Total Phosphorus.
Eagle Road WWTP—NPDES#NC0020184
• The draft permit lists a monthly effluent limit for TP of 1.0 mg/L. The fact sheet states that this limit had
been in effect and is continuing; however, in the current permit the total phosphorus concentration limit
ended on 12/31/2017 (when the mass load limit took effect) and only monitoring and reporting is
currently required regarding the total phosphorus concentration.The removal of this limit is also
documented in section 6.7 of the permit's Fact Sheet and is consistent with the manner in which the
allocations are described as being expressed in this section of the Fact Sheet. The City of Gastonia
strongly requests that this monthly average limit be removed and that the phosphorus allocation
continues to be expressed solely as a mass load limit.
• Conductivity analysis was added at a daily monitoring frequency for the effluent and at a variable
frequency for the instream samples. The rationale for this change is not addressed in the Fact Sheet and
the City of Gastonia requests that the conductivity monitoring requirement for the effluent and instream
sampling be removed.
• The facility components listed in item 1 on page 2 of the draft permit do not correctly list the size of
components at Eagle Road WWTP. The correct sizes are:
o Aeration basin: 6.3 MG
o Clarifiers: 690,000 gallons each
o Chlorine contact basin: 94,000 gallons
• Section I A(8) 1.of this draft permit requires that"Until such time as the state's eDMR application is
compliant with EPA's Cross-Media Electronic Reporting Regulation (CROMERR), permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be
required to complete the eDMR submission by printing, signing, and submitting one signed original and a
copy of the computer printed eDMR ..." The City of Gastonia has previously been informed that signed
copies of the eDMR are no longer required to be submitted, and asks that this section be removed if it is
no longer applicable.
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• Section 1 of the Fact sheet for this permit states that none of the industrial customers in TRU's service
area discharge to Eagle Road. While there are no industrial customers in the portion of Gastonia/TRU's
collection system that discharge to Eagle Road WWTP,there is one non-significant industrial customer,
Syncot Plastics, in the portion of the City of Belmont's collection system that discharges to Eagle Road
WWTP.
• Section 12 of the fact sheet for Eagle Road WWTP lists information that is inconsistent with the draft and
current permits for the following parameters:
o Conductivity: Monitor and Report is listed under"Current Permit Limits and Monitoring
Frequency" for instream samples at a variable frequency, but the current permit does not have an
instream conductivity monitoring requirement.
o Total Nitrogen (TN): Under"Proposed Change" a MA limit of 6 mg/L is listed along with comments
in "Basis for Condition/Change". This is inconsistent with the current and draft permits. The City
of Gastonia asks that"No Changes" be listed for Total Nitrogen.
o In Section 12 of the Fact Sheet for this permit under the parameter for Total Phosphorus, a MA
of 1 mg/L is listed for"Current Permit Limits and Monitoring Frequency" but that limit was
removed 12/31/2017. Monitor and Report should be listed in that section for Total
Phosphorus.
We appreciate DWR's work on these permits and have no other comments on the drafts 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
City of Gastonia
CC: Doug Barker—Treatment Plant Supervisor, Eagle Road WWTP
Mourice Brothers-Treatment Plant Supervisor, Long Creek WWTP
David Shellenbarger—Assistant WWTD Manager Compliance
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