NC0081621_Comments_20240408

WSACC WATER&SEWER AUTHORITY
OF CABARRUS COUNTY
Administrative Offices
232 Davidson Hwy,Concord, NC
28027
704.786.1783 • 704.795.1564 Fax
Ny)
Rocky River Regional WWTP
6400 Breezy Lane,Concord, NC
ISO 14001:2015• NC Star Public Sector• OHSAS 18001007 28025
704.788.4164 • 704.786.1967 Fax
RECEIVED
April 4, 2024
APR 082024
CERTIFIED MAIL
RETURN RECEIPT REQUESTED NCDEQ/DWR/NPDES
Mr. Saad Masood
NPDES Municipal Permitting Unit
NCDEQ/Division of Water Resources/Water Quality Permitting
1617 Mail Services Center
Raleigh,NC 27699-1617
SUBJECT: DRAFT—NPDES PERMIT NC0081621
MUDDY CREEK WASTEWATER TREATMENT PLANT
Dear Mr. Masood:
This letter is to provide comments of the Water and Sewer Authority of Cabarrus County
(WSACC) on the draft NPDES draft permit for the Muddy Creek Wastewater Treatment Plant
(MCWWTP).
Draft Permit page 1 "
• We request extension of the expiration date to five years from the issuance date.
Draft Permit page 2
• We request that the facility components be updated to the following:
➢ Pump Station
➢ Mechanical bar screen and backup manual bar screen
➢ Equalization Basin
➢ Two treatment trains, each containing:
o Influent splitter box
o Two aeration basins
➢ Two clarifiers
➢ Tertiary filters
➢ Ultra-violet disinfection

➢ Cascade aeration
➢ Aerated sludge holding tanks
➢ Stand-by power
Draft Permit page 3
• We request that daily effluent temperature monitoring be reduced(for 0.3 MGD and 1.0
MGD). The fact sheet states "However, it was concluded that no statistically significant
difference exists between upstream and downstream temperature, implying that an
effluent impact is not likely observed."
• We request a reduction in the effluent monitoring frequency for conductivity at 0.3
MGD. 15A NCAC 02B .0508 requires weekly monitoring for a Grade II facility
discharging to water quality limited waters.
Draft Permit page 10
• Under"FACILITY CLOSURE REQUIREMENTS"at this time do not know that Outfall
001 will no longer be in use once Outfall 002 is constructed. We request that the
language be changed to recognize that Outfall 001 may remain active after Outfall 002 is
constructed.
Fact Sheet page a e 1
• Treatment Units need to be updated to reflect the components list on page 2 of the draft
permit.
Fact Sheet page 2
• We do not have a sufficient level of detail about future expansions to definitively say that
the next expansion will abandon the existing equipment/tanks and outfall entirely. The
next expansion may use much of the existing equipment/tankage. We request changes
here to consider the potential range of possibilities for the expansion design/construction.
NH3/TRC WLA Calculations sheet
• With the updated instream data for Rocky River we request that the NH3 limits be
reconsidered for both the 0.3 MGD and the 1.0 MGD page.
Monitoring Report Violations page
• The NOV for flow exceedance issued 1/31/2019 was retracted by Corey Basinger in a
letter received by WSACC dated 4/18/2019. We request that the page be updated
accordingly.
Water Compliance Inspection Report page
• The name of the Responsible Official needs to be updated to Harry M. Wilson.

Thank you for your consideration of this matter. If you should have any questions or need
additional information,please contact Matthew Isenhour, Operator in Responsible Charge (ORC)
at(704) 888-4888 or [e-mail], or myself at(704) 788-4164 x111 or
[e-mail].
Sincerely,
Mark Fowler
Facilities Director
ecc: Matthew Isenhour
James Sims
Cayce Atkinson
Thomas Hahn
Michael Wilson
File