WQ0002520_More Information (Received)_20220218

The Oistoric Mown of Bath
P O Drawer 60, 103 S King Street
Bath, North Carolina 27808
(p) 252-923-0212 69 252-923-0313
February 16, 2022
Lauren Raup-Plummer, Engineer III
NCDEQ 1 Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: Application No. WQ0002520
Town of Bath WWTP
Permit No. WQ0002520 —permit draft for 2022
Wastewater Irrigation System
Beaufort County
Dear Lauren:
In response to your recent letter dated January 21, 2022 and a follow-up to the above -referenced
application, enclosed is comment, additional information, and requests regarding the draft permit
provided the Town of Bath.
As stated in your recent letter the draft permit provided to the applicant is considerably different
than the existing permit. The draft -letter covering the drat permit lists eight (8) Old Conditions
removed since the Iast permit issuance dated May 1, 2017, plus ten (10) {new} Conditions that
are new since the last permit issuance dated May 1, 2017. The enclosure addresses each of the
eighteen listed conditions.
Six (6) of the removed Old Conditions and five (5) of the {new} Conditions are related to
abandon of the high -rate infiltration basin (HRIB) and no longer having that HRIB in the Permit.
Those eleven (11) changes to the Permit are considered okay, or say agreed -upon changes. Two
(2) other Old Conditions (1. 1, VI.2) are considered okay, or say agreed -upon changes. Three (3)
other {new} Conditions (III.16, IV.9.b, VI.3) are considered no -comment changes.
However, the Town is making request(s) in regard to two (2) of the Inew) Conditions (II.6,
1II.14) plus (new)Attachment A. One statement in the draft -letter regarding Condition 11.6
mentions "the installed rain/moisture sensor"; there is no "installed rain/moisture sensor" to "be
connected to the irrigation system". Irrigation operation is totally manual and the Town of Bath
requests Condition II.6 not be added to the Permit.
Another statement in the draft -letter speaks to Condition III.14 that "requires gauges be installed
to monitor waste levels in the 1,560,000 gallon and 2,850,000 gallon lagoons." A gauge for the

Lauren-Raup Plummer, Engineer III
NCDEQ \ Division of Water Resources
February 16, 2022
Page 2 of 2
1,560,000 gallon facultative/5-day upset lagoon and a gauge the 2,850,000 gallon lined
facultative/storage lagoon are in -place and the Town of Bath requests Condition III.14 not be
added to the Permit.
In regard to Attachment A — PPI 002 WWTP Effluent to the Wastewater Irrigation System, the
Town is requesting monitoring requirements and effluent limits follow appropriate 15A NCAC
02T.0505 DESIGN CRITERIA that covers less than or equal for BOD5 (30 mg/l), Total Suspended
Solids (30 mg/l), Ammonia (15 mg/l), Fecal Coliform (200 1100 ml), and does not have a
requirement or limit for Turbidity.
Under the Old Permit, Old Attachment A PPI 001 followed 5A NCAC 02T.0705 DESIGN
CRITERIA covering effluent to high -rate infiltration basins. We believe Old Attachment A — PPI
002 WWTP Effluent to the Wastewater Irrigation System was made the same as Old Attachment
A — PPI 001 given their common sampling at the same point location in he wastewater facility.
With the abandon and removal of the high -rate infiltration basin plus removal of PPI 001 from
the Permit, it would be most appropriate to have PPI 002 WWTP Effluent to the Wastewater
Irrigation System follow 15A NCAC 02T.0505 DESIGN CRITERIA.
Please call if you have any questions.
Sincerely,
ZX
.E. Bubs Carson
Town Manager
cc: Gale Smith, PE. — Rivers & Associates
Greg Churchill, P.E. — Rivers & Associates
C:lUsers\Owner\AppData\Local\Microsoft\Windows\lNetCache\Content.OutlooklYNW6'I'WXY\ncdeq It2022 02-16
WQ0002520f.doc

Town of Bath WWTP
Permit No. WQ0002520
Wastewater Irrigation System
Beaufort County
Permit conditions removed since the last permit issuance dated May 1, 2017
1. 01. okay: removed / requirement has been met with installation of gauge in
1, 560, 000 gallon five-day upset pond
11.06. okay: removed / no HRIB
11.07. okay: removed / no HRIB
III. 16. okay: removed / no HRIB
IV. 06. okay: removed / no HRIB
IV. 08. okay: removed / no HRIB The NDAR-2 reporting form requirements have been
removed from Condition IV. 08.
IV. 14.f okay: removed / no HRIB
VL 02. okay: removed/ rule change permits are no longer voidable
New hermit conditions added since the last Dermit issuance dated Mav 1.2017
1.01. okay: Within one (1) year of the effective date of this permit, the Permittee must
breach the infiltration dike wall surrounding IB-1 at ground level. The permittee shall
notify the Washington Regional Office, telephone number [phone], at least
two business days in advance of breaching the infiltration dike so that a representative
for the Division can be present. [15 A NCAC 02T .0108(b)(1)(13)]
1.02. okay: Within 60 days of the effective date of this permit, Monitoring wells MW-10
and MW-11 shall be temporarily abandoned by securing the wellheads to prevent
access. Each monitoring well shall have a lockable cap, and compatible watertight
cap or seal shall be placed onto each monitoring well riser pipe. [15 A NCAC 02T
.0108(c)(7, 02T .0108(b)(1)(B)]
11.06. The Permittee shall connect the irrigation system to a rain or moisture sensor
designed to prevent irrigation during precipitation events or wet conditions. [15A
NCAC 02T .0505(X)]
In regard to direction in the draft -permit from NCDEQ, "connect the irrigation
system to a rain or moisture sensor designed to prevent irrigation during
precipitation events or wet conditions". Statement in letter covering the draft -
permit says, "Condition II.6 — This condition requires that the installed
rain/moisture sensor be connected to the irrigation system." Neither a
rain/moisture sensor, nor automatic controls with timers and other devices are
currently installed at the wastewater treatment facility. Operation and control
of irrigation is a manual on -and -off operation; irrigation can only occur when
the operator manually initiates action by energizing the irrigation pumps. The

operator only irrigates in the presence of dry conditions and does not irrigate
during precipitation events or in the presence of wet conditions.
With all things under consideration, the Town of Bath requests Condition II.6
not be added to the Permit.
III. 14. Gauges to monitor waste levels in the 1,560,000 gallon facultative/5-day upset lagoon
and 2,850,000 gallon lined facultative/storage lagoon shall be provided. These
gauges shall have readily visible permanent markings, at inch or tenth -of -foot
increments, indicating the following elevations: maximum liquid level at the top of
the temporary liquid storage volume; minimum liquid level at the bottom of the
temporary liquid storage volume; and the lowest point on top of the dam. [15A
NCAC 02T .0507(g)]
A gauge for the 1,560,000 gallon facultative/5-day upset lagoon and the
2,850,000 gallon lined facultative/storage lagoon are in -place.
The Town of Bath requests Condition I11.14 not be added to the Permit.
III. 16. Monitoring equipment shall be tested and calibrated annually.
no comment
IV. 09.b Include the date of irrigation equipment calibration in the maintenance log.
no comment
VI. 03. Unless specifically requested and approved in this permit, there are no variances to
administrative codes or general statutes governing the construction or operation of the
facilities permitted herein. [15A NCAC 02T .0105(c)(6)]
no comment
Attachment A — okay for PPI 001: Monitoring requirements for the WWTP effluent to
the high -rate infiltration basin, PPI 001, have been removed.
not -okay for PPI 002: With the high -rate infiltration basin being
removed from the Permit and effluent disposal only by the wastewater
spray irrigation field; the Town of Bath requests that monitoring
requirements {and Effluent Limits) for WWTP Effluent to the
Wastewater Irrigation System, PPI 002, follow appropriate 15A
NCAC 02T.0505 DESIGN CRITERIA that covers BOD5, Total Suspended
Solids, Ammonia, Fecal Coliform, and does not have a requirement or limit
for Turbidity.
Attachment B — okay: The high -rate infiltration basin, I13-1, has been removed.
Attachment C — okay: Monitoring wells MW-10 and MW-I I have been removed.
END