Gastonia 2 Rivers Utilities NCG11 Comments

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May 15, 2023
Stormwater Program
Division of Energy, Mineral, and Land Resources
Attn: Brittany Cook
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: Public Comment on General Permit No. NCG110000
Dear Ms. Cook:
The City of Gastonia's Two Rivers Utilities appreciates the opportunity to comment on the
draft revision to General Permit No. NCG110000. Two Rivers Utilities understands the
importance of stormwater monitoring and fully support the efforts of the North Carolina
Department of Environmental Quality to protect water quality. However, it has some
significant concerns with the current draft and its impact on our wastewater treatment plants.
The draft permit requires quarterly analytical sampling of each stormwater outfall. These
outfalls are already required to be qualitatively monitored semiannually and all catch basins
are also inspected during dry weather to detect any process or chemical leaks. It seems
unlikely the analytical sampling would provide any additional environmental benefit. Two
Rivers Utilities' three wastewater treatment plants have a combined total of 22 outfalls, many
of which are positioned in difficult-to-reach locations along the creek banks. In addition to the
cost of these analyses, which is estimated at more than $4,000 annually for the utility, some
of the specific timing requirements make the sampling much more difficult.
The requirement that sampling be performed within 30 minutes of discharge from the first
measurable rain event is impractical. During a rain event with high flows entering the
treatment plants, it is difficult for plant operators to be available for operating the wastewater
treatment plant while collecting stormwater outfall samples. Additionally, collecting a
discharge from some of the outfalls will be unsafe, particularly during a rain event, due to the
locations of the outfalls.
The draft permit requires samples be collected whenever a rain event occurs during the
"facility's normal operating hours". Clarification is needed as to whether the "facility's normal
operating hours" means 24-hours a day for wastewater treatment plants staffed around the
clock. If so, that time requirement would often mandate that staff be out along the creek banks
in the middle of the night during a rain event, which adds another layer of difficulty and
significant safety risk.

The draft permit requires collection of fecal coliform sampling for each outfall, which is also
affected by these timing requirements. Even though Two Rivers Utilities has an internal
laboratory equipped to analyze fecal coliform, being required to collect unscheduled samples
at night or on weekends will make it difficult to analyze fecal samples within the 6-hour
regulatory hold time. It will also increase operating expenses for overtime to have laboratory
staff report in after hours to analyze samples.
Furthermore, many of Two Rivers Utilities' outfalls rarely have any discharge. Per the draft
permit, staff would need to keep returning to these difficult stormwater outfall locations every
time it rains and document that there was no flow coming from the stormwater outfall.
Additionally, the benchmark values listed in the draft permit are very low, especially for fecal
coliform, and there is not adequate justification given for the levels. Some of Two Rivers
Utilities' plants have significant populations of Canada geese, which are a protected species,
who by themselves will likely add more than the benchmark 1000 colonies/100ml of fecal
coliform into the stormwater. Exceeding the benchmark triggers a time-consuming chain of
events even though the exceedance likely would not have been caused by plant activities.
Two Rivers Utilities also has concerns about the requirement in the Tier Three Response
Chart that the facility obtain approval of its corrective action plan from the North Carolina.
Department of Environmental Quality within three months. The North Carolina Department of
Environmental Quality has previously often been slow to issue approvals, and a delayed
response would cause the utility to be out of compliance with this permit requirement through
no fault of its own.
Lastly, several of the other new documentation requirements in the draft permit, such as
annually updating the list of solvents present during the past 3 years and 24-hour notification
of any visible sediment disposition in the stream, are burdensome to the utilities without
appearing to add environmental benefit.
Two Rivers Utilities appreciates the opportunity to provide feedback on the draft revision to
the general stormwater permit for wastewater treatment plants. We believe strongly that the
current general stormwater permit requirements for twice annual qualitative monitoring and
twice annual dry inspection outfall monitoring already offer the environmental benefit of
ensuring stormwater discharges from wastewater treatment plants do not negatively impact
the environment. We hope that our concerns are taken into consideration and that the final
permit revision will be reasonable and feasible to implement. If you have any questions or
require further information, please do not hesitate to contact us. I can be reached at 704-
866-6726 or [e-mail].
Sincerely,
Stephanie Scheringer
Division Manager
City of Gastonia Two Rivers Utilities