Roxboro Comments on NCG110000

RDrxBORO
City of Roxboro
Ms. Brittany Cook
Mr. Isiah Reed
Stormwater Program
Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Re: General Permit NCG110000 NPDES Permit to Discharge Stormwater
Dear Ms. Cook and Mr. Reed:
The City of Roxboro NC would like to offer the following comments to the North Carolina Department of
Environmental Quality Division of Energy, Mineral and Land Resources(DEMLR's) proposed reissuance
of the General Permit to Discharge Stormwater from Treatment Works under the National Pollutant
Discharge Elimination System for Treatment Works, Permit NCG110000 draft.
The City of Roxboro acknowledges and fully supports the NCG110000 draft permit comments Paul
Calamita (General Counsel)and his staff at Aqualaw have made on behalf of each affected North
Carolina Water Quality Association Member. We also agree completely with Mr. Calamita's comment
concerning the disappointment that there was no outreach that we are aware of to the local permittees
concerning a significantly revised draft permit and comment period.
Additionally,we request that consideration be given to the following;
The City of Roxboro has committed to and is currently undergoing a 23 million dollar upgrade to its
Wastewater Treatment Plant due to lower NH3 NPDES permit limits. The process of completing the
project, bringing the various parts and pieces on line along with the SOP,JSA/JHA analysis development,
staff training, etc. that will be required while maintaining NPDES permit compliance has stretched our
current WWTP staff of 9 to its limits. Additionally, our WWTP staff is working with the NCDEQ NPDES
permit writer on renewal of it NPDES permit that expired on 5/31/2022. The safety of our WWTP staff,
the successful completion of our WWTP upgrade, NPDES permit compliance and NPDES permit
renewal/implementation along with all the different components that go into each must be our priority
at this time.
Because of this,we request a "phased in approach option" be added to any new requirements/language
included in the final NCG110000 stormwater permit. We recognize the definition of"General Permit"
but feel current circumstances at individual municipalities should dictate the pace of implementation
105 S.LAMAR STREET•PO BOX 128•ROXBORO,NORTH CAROLINA 27573•[phone]•FAX[phone]
www.cityofroxboro.com

whenever significant changes to any permit are proposed. One way this could be achieved is by
including permit language that allows municipalities the ability to petition the Director for an addendum
to the General Permit that would accommodate this phased in approach. This addendum would provide
municipalities the necessary time needed to;
1. Review the final permit and identify what parts can be handled in house and what parts would
require outside source development/review and funding.
2. Allocation of funds via annual budget for outside source required plan development/review,the
necessary changes at outfall locations to allow for SAFE sampling,additional staffing, additional
testing and the additional access points required in the site perimeter fencing to accommodate
sampling.
3. Implement the permit required various plans, staff training and construction where necessary
for safe sampling access at each affected outfall and any proposed changes to the perimeter
fencing.
4. Account for the competition in a limited workforce as a result of generational retirements and
COVID related backlog on in-person training opportunities; Municipalities are facing increasing
difficulty in finding certified labor and phasing can allow time to locate the needed staff.
Five of the seven outfalls located at the City of Roxboro Wastewater Treatment Facility were
constructed prior to and have been in place since the original WWTP was started up in 1965. Visual
inspection of these outfalls clearly indicates that"safe access for sampling"was not a consideration
when these outfalls were designed and installed. The visual inspection/documentation required in the
current permit of these outfalls has been accomplished semiannually in the spring and fall when there
was little to no vegetation to contend with but even then,access to the areas would not be considered
completely safe.
Additionally,we would like to request the ability to provide comments in response to staff comments
addressing our concerns. Once the final permit is available we request ample time to review and provide
additional comments for your consideration. We would also request an opportunity and guidance for
submitting a petition to the Director concerning a realistic timetable for compliance.
We respectfully ask that you consider the comments that have been submitted by Mr. Paul Calamita on
behalf of all the affected North Carolina Water Quality Association Members concerning the proposed
Draft General Stormwater Permit NCG110000,our comments here as they relate to the City of Roxboro
WWTP and the comments received from any other municipalities concerning the significant revisions
included in the draft permit.
Sincerely,
�1( 4 -
Allen Brooks Lockhart
City Manager
City of Roxboro