NC0074268_Draft Permit Renewal_20170221

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Ms. Teresa Rodriguez
NPDES Complex Permitting Unit
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Draft NPDES Permit Renewal
Permit NC©074268
Crowders Creek WWTP
Gaston County
Class IV Facility
Dear Ms. Rodriguez:
RECEIVEDINCDEgDWR
�Eq 21 2017
Permitting Se2on
Thank you for sending the draft of Crowders Creek WWTP's renewed NPDES permit which we received
February 2, 2017. We have reviewed this draft, and appreciate the thorough preparation and the
changes that were made in limits and monitoring frequencies following the data review. In
accordance with your request, we would like to submit the following comments for potential
modifications for the final permit:
• The address for the Crowders Creek WWTP should be listed as 5642 South York Road, Gastonia on
pages 1 and 2.
• A monthly TN Limit of 6 mg/L is listed through March 311t 2017. We ask that this be removed since
we do not believe there should be a winter concentration limit in effect during this period.
• "DWQ Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits for
Exceptionally Performing Facilities" states that facilities meeting the requirements may have
monitoring reduced to 2/week. The Crowders Creek WWTP met the requirements for BOD, TSS,
ammonia and fecal coliform, but monitoring was only reduced to 3/week. We respectfully ask that
the minimum requirement for this monitoring be reduced to 2/week.
• Section A.(4.)(c.) makes an incorrect reference to Special Condition A.(2) and talks of combining
nutrient limits with Long Creek WWTP, which is not applicable for Crowders WWTP. We believe this
section should be deleted.
• The map shows the discharge for Crowders Creek WWTP at an incorrect location. Please see the
attached map with the location of the discharge marked.

• Standard Conditions were not included with the draft permit. We do not have any comments on
Standard Conditions if version 11/09/2011.1 is included.
We appreciate DWR's work on this permit and have no other comments on the draft at this time. If I
can be of any assistance please feel free to contact me at 704-866-6726 or email at
[e-mail].
Sincerely,
f
Stephanie Scheringer
Division Manager Wastewater Treatment
Two Rivers Utilities
Attachment: Facility Location Map
CC: Kevin Graves, ORC Crowders WWTP
CERTIFIED MAIL: 7014 0150 0002 0276 0852

Permit NC0074268
Crowders Creek WWTP — NCO074268
Receiving Stream: Crowders Creek Stream Class: C
Drainage Basin: Catawba River Basin Sub -Basin: 03-08-37
HUC: 03040105
State Grid: F16SE USGS Quad: Concord SE, N.C.
Page 12 of 12
Facility Location (not to scale)
IN AOMW
Latitude 35° 30' 10" Longitude 81° 11' 48"