NC0045292_Comments_20240305

CITY OF
G R A H A 1\/1
NORTH CARO LINA,�t RECEIVED
2323
MAR 0 5 2024
February 29, 2024
NCDEQ/DWR/NPDES
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Sydney Deuterman, Environmental Specialist II
NPDES Compliance and Expedited Permitting
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: Comments for Draft NPDES Permit NC0045292
Graham-Mebane WTP-Grade I Physical Chemical WPCS-Alamance County
Dear Ms. Deuterman,
Our staff would like to provide the following comments on the Draft NPDES Permit NC0045292 received
January 31, 2024:
• On Page 2,we would request the following correction under the "Chemical Usage consists of"
section: Ammonium Sulfate/chloramines. It is listed in the draft permit as Ammonia
nitrogen/chloramines. We use ammonium sulfate for the formation of chloramines.
• We would request that the Whole Effluent Toxicity testing remain as a monitor and report
requirement as in the current permit. Our facility has been conducting the WET testing since
2011 on a quarterly basis per our NPDES Permit NC0045292. We have conducted 52 WET tests
from 2011—2023, passing 51 of these tests with only one failure in 13 years. The failure of the
WET test in June, 2023 was due to failure of our dechlorination chemical (sodium bisulfite)feed
system. The issue was immediately addressed, repaired and returned to normal operating
conditions. Our facility was back in compliance with the next quarterly WET test.
Thank you for your consideration of the above comments. If you have any further questions,
please contact me at 336-570-6721, or via email at [e-mail].
Sincerely,
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Tonya Mann
Utilities Director
City of Graham