NC0020664_Comments_20241104

�' CARO
O RECEIVED
z ..p.. a
NOV 0 4 2024
town of Spinda/e
%WO NCDEQ/DWR/NPDES
PO Box 186 • 125 Reveley Street • Spindale, NC 28160
Phone: [phone] • Fax: [phone]
November 1, 2024
NCDEQ/DWR
NPDES Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject:
Draft NPDES Permit Renewal
Permit NC0020664
Town of Spindale WWTP
Rutherford County
Grade IV Biological WPCS
SIC Code 4952
To Whom This May Concern,
On behalf of the Town of Spindale, NC, I write to confirm receipt of the Draft NPDES permit renewal
for the Town of Spindale WWTP, and I write to convey comments that the Town has respecting the
permit. We would like to thank Mr. Ori Tuvia for granting the Town additional time to submit these
comments.
• Cover letter,second bullet point,and Permit, Part I,A.(1.)(a.), effluent limitations for total
copper. The basis for the reduction in total copper limits in the permit(on a monthly average,
reduced from 45.7 ug/L to 41.8 ug/L and for the daily maximum, reduced from 53.4 ug/L to
47.7 ug/L) Based on the information of the second bullet point, stating the copper standards
are dependent on the stream and effluent hardness, we do not understand why new, lower
total copper limits were added. The second bullet point refers to stream and effluent
hardness, but in the past the hardness results have been quarterly, and total copper effluent
results have been monthly.Can you please explain how new total copper limits can be added
based upon results that were collected in different ranges of time? Also, can you please
explain why the total copper limit is decreasing in the Permit when the hardness average in
both effluent and upstream has increased?
• Cover letter,third and fourth bullet point,and Permit, Part I,A.(1.)(a.), effluent limitations
for total cyanide and chloride. It appears to the Town that the sole basis for creating these
new effluent limitations is the Town's quarterly monitoring for these parameters, and during

the current permit cycle,each parameter was out of range only once during the current permit
cycle. Can you please explain how one exceedance triggers application of a reasonable
potential analysis for these parameters? If our understanding is correct, we suggest that a
more measured approach on this issue to report each of these parameters out as monitor
and report only during the upcoming permit cycle. Finally, please note that proposed limits
are set out in ug/l when tests are run in mg/l.
• Permit, Part I,A.(1.)(a.),footnote 10. This footnote says that sampling for hardness should
be taken to coincide with metals. However, the Permit, Part I(A.)(1)(a.) chart says that
hardness sampling should be performed quarterly, and metals sampling (for copper and
cyanide)should be performed monthly. Can you please clarify this?
• Permit, Part I,A. (5.) Wastewater Management Plan-The Town objects to this proposed
requirement as unnecessary, duplicative and cost prohibitive.This proposed requirement to
evaluate the deficiencies and operational difficulties in the existing collection system or
treatment facility is unnecessary and duplicative as the Town is currently evaluating the
collection system through the previously awarded $400,000 AIA Grant through NCDEQ to
perform a pipe condition assessment and update to our Asset Management Plan.
Additionally, hiring an engineering firm to perform such an analysis would be cost prohibitive
and any resources spent evaluating the Wastewater Treatment Facility would be better spent
in rehabbing Clarifier No. 3,which is the main concern at the plant.To fund the rehabilitation
of Clarifier No.3,the Town applied for DWI funding in Fall'23,Spring'24, and Fall'24 rounds.
In addition to applying for State funding for this project, the Town has proactively increased
sewer rates across all customer classes to better fund capital; however, rate affordability is
becoming an issue given the recently adopted double digit rate increase and our citizens low
Median Household Income of approximately$38,000. In short, as it pertains to Clarifier No.
3 being out of service,we do not need to expend our extremely limited resources to identify a
problem that we already know exists but instead use those resources to their highest and
best use, which would be the actual rehabilitation of the clarifier, hopefully in conjunction
with funding from DWI.
To help resolve this matter,the Town would be willing to consider a Special Order of Consent
to complete the tasks contemplated by the Waste Management Plan if those tasks are still
necessary after the Town receives funding to rehabilitate Clarified No. 3 and after
improvements to Clarifier No. 3 are completed.
• In section A.6 states that we use method 1633,latest version until EPA approves their version
of PFAS testing. Is this correct?
• In section A. (6) would indirect dischargers be industries that contribute less than the
required flow of an SIU, but listed on EPA PFAS Strategic Roadmap as an SIU?
• A.(6) PFAS Monitoring Requirement and Pretreatment-The proposed requirements in
this section appear to be premature given that the current EPA Method 1633 has not been
published in the Federal Register as an approved test method. Additionally, these new
requirements could prove costly and/or burdensome on our SIU's, which the Town can ill
afford to lose from an economic standpoint. The Town would suggest that implementing

these measures be delayed until an approved test method has been published and only then
begin evaluating the effluent for PFAS.Additionally,the SIU's should not have to comply with
testing requirements until we have a clear history of test results at the plant that
demonstrates the need for additional PFAS testing, again, based on an approved/published
method for such testing.
Thank you for considering these comments.
Sincerely,
‘sh
G.Scott Webber
Town Manager
cc: Ori Tuvia, Environmental Engineer III
NPDES Permitting Unit