NC0025712_Draft Permit Comments_20150331

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RECEIVEDIDENRIDWR
March 27, 2015 MAR 31 2015
Water Quality
Permitting Section
NC Division of Water Resources
WQ Permitting Section/NPDES
ATTN: John Hennessy
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NPDES Draft Permit - Comments
Town of Hookerton
NPDES Permit#NC0025712
Greene County
Dear Mr. Hennessy:
The Town of Hookerton received a draft NPDES permit dated February 11, 2015 for review and
comment. The Town would like to request the following changes to the permit:
A. The old permit contained page A.2 Effluent Limitations and Monitoring Requirements
that contained limits and monitoring that would be effective upon the completion of a
Duckweed Treatment System. As was stated in the permit renewal application, this
system was constructed but failed prior to being operational. The duckweed system will
not ever be used and we request that section A.2 Effluent Limitations and Monitoring
Requirements of the draft permit be removed.
B. Section A.5 Annual Limits for Total Nitrogen and section A.6 Total Nitrogen Allocations
were added to the permit. These two sections imply that a permit limit for Total Nitrogen
is established. Part A. of section A.5 states that TN limits and allocation apply on a
calendar year basis and part B states that the Permittee is in compliance if the annual
discharge is less that the allocation. Although section A.2 Effluent Limitations and
P.O. Box 296 • Hookerton, NC 28538
[phone] • FAX[phone] • [e-mail]
www.hookertonnc.com
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Monitoring Requirements only includes the requirement for monitoring and reporting of
TN, we think that sections A. 5 & 6 can be interpreted as setting the annual discharge
limit for TN at 1,213 pounts. It is our understanding of the Neuse River Nutrient
Management rules that facilities with permitted flows of<0.5 mgd are not subject to TN
limits. We request that these sections be removed from the permit, as in earlier permits,
or that the language be modified to make clear that the TN allocation assigned is not in
fact an enforceable limit.
If you have any questions or comments, please contact April Baker, Town Clerk, at 252/747-
3816.
Sincerely, P
Robert Taylor, Mayor
Town of Hookerton
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