NC0024201_Permit Renewal Request_20160921

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September 21, 2016
Mr. Wren Thedford
NC DENR, Division of Water Quality, NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina, 27699-1617
RE: Renewal Request of NPDES Permit Number NC0024201
Roanoke River Waste Treatment Plant
Roanoke River Basin
Dear Mr. Thedford,
P.O. Box 308
1000 Jackson Street
Roanoke Rapids, NC 27870;
[phone]
Fax: [phone]
www.rrsd.ora
The Roanoke Rapids Sanitary District (RRSD) is permitted to discharge 8.34 million gallons per day
(mgd) of treated effluent to the Roanoke River under NPDES Permit No. NC0024201. The NPDES
permit is scheduled to expire on March 31, 2017. The enclosed application is for renewal of the current
permit. In accordance with the requirements of federal (40 CFR 122) and state (15A NCAC 2H.0105(3))
regulations, we are submitting three signed copies of the completed application package and associated
attachments and figures. The application package includes the following information:
1. NPDES Permit Application — EPA Form 2A
2. EPA: Form 2A Additional Information (Topographic Map, Process Flow Diagram and Process
Narrative)
3. Priority Pollutant Scan Analyses (three scans)
4. First Species Effluent Toxicity Tests
5. Second Species Toxicity Tests
6. Biosolids Management Description
7. Technical Memorandum in support of the Reduction of Monitoring Frequency for Exceptionally
Performing Facilities
8. Effluent and stream hardness data
9. Mercury Minimization Plan Summary
At the time of this application submittal, the required second species toxicity testing events have not yet ,
been completed. The June, July, and August tests have been completed and the results are included in our
application package. The remaining second species tests are currently scheduled to be completed in
September and October 2016. When the second species toxicity test results become available, they will
be forwarded to the Division of Water Resources (DWR) along with revisions to Part E of EPA Form 2A

to include these results. All of the second species toxicity tests will be submitted prior to the current
permit expiration date of'March 17, 2017.
In accordance with 15A NCAC 2B .0508(b)(1) and the October 2012 DWR Guidance Document for the
Reduction of Monitoring Frequency for Exceptionally Performing Facilities, the District respectfully
requests a continuation in reduction in frequency monitoring for carbonaceous biochemical oxygen
demand (CBOD5), ammonia, and fecal coliform. Effluent sampling results from the past three years
demonstrate that all state regulatory and guidance requirements have been met in support of this request.
A summary of the sampling data and analysis for the reduction of monitoring frequency is attached to this
application.
Additionally, RRSD respectfully requests that the following issues be addressed in this permit renewal:
• We request that Influent Equalization / Sludge Storage tanks be added to the treatment
components list in the supplement to the permit cover sheet as per request by DWR inspector
Autumn Romanski on 4/2/2015.
• We request that Footnote 1 remain in the permit unaltered.
We request that Footnote 2 — Monthly average effluent CBODs and TSS concentrations shall
not exceed 15% of the respective influent value (i.e., 85% removal is required) — be removed
from the permit. We believe that the additional percentage removal limitation is not
warranted as the facility continuously meets the monthly and weekly average permit limit.
If Footnote 2 is not removed, we request that the language be modified to make an exception
for low influent suspended solids and CBOD events. Our facility has difficulty meeting, this
percent removal requirement when influent suspended solids and CBOD concentrations are
extremely low. Thus, we request that Footnote 2 be modified, as follows: Monthly average
effluent CBODS and TSS concentrations shall not exceed 15% of the respective influent value
(i. e., 85% removal is required). This requirement shall be waived if influent TSS
concentrations are less than 150 mg/7 and/or influent CBOD is less than 100 mg/L.
• Reduce the total nitrogen and total phosphorous monitoring frequency from monthly
sampling to once per quarter. Our facility does not discharge into nutrient sensitive waters.
• Reduce the chronic toxicity sampling (Ceriodaphnia) from quarterly to annually. We have
been conducting chronic toxicity testing since April 1993. All of our toxicity tests have
passed, including the second species testing with Fathead Minnow.
A reasonable potential analysis was conducted using data from our Long Term Monitoring
Plan (LMTP) and Priority Pollutant Analysis (PPA) scans. Reasonable potential of the
effluent to violate the new instream dissolved metals standards was not found. The District
has been collecting effluent and receiving stream hardness data, which is included in this
application.
We request the following information as part of the draft permit preparation:
• A copy of the permit Fact Sheet.
• Documentation for any methodology, data, and assumptions used in any permit modification,
including Reasonable Potential Analyses, if applicable.
• A copy of any comments that are received from the public regarding this permit renewal, if
applicable.
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We very much appreciate the time and effort of the NPDES Unit to consider our requests for this permit
renewal. Please do not hesitate to call myself (252-537-9137) or Mary Sadler with Hazen and Sawyer
(919-755-8560) if you have any questions.
Sincerely,
Roanoke Rapids Sanitary District
R. D ieley Brow , P.E.
Chief Executive fficer
Attachments:
Letter from Contract Laboratory
WET Test Results
Hardness Data
Biosolids Program Description
RMF Technical Memo
MMP Summary
cc: Steven Ellis, ORC
Gregg Camp, RRSD Wastewater Treatment Plant
Jeff Poupart, DWQ, Point Source Branch Chief
Tom Belnick, DWQ, NPDES Unit Supervisor
Mary Sadler, PE, Hazen and Sawyer
File
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