NC0041696_Comments on Draft Permit_20171129

First of all, thank you for the time and effort the State has put into writing the draft permit for the Town of
Valdese.
While the Town is in agreement with most of the changes proposed for the new permit, there are a few
areas of contention and at least one perceived error in wording.
The seventh (761) bullet point on the draft proposal states, `added monthly and daily maximum effluent
limits for ammonia nitrogen for the permitted flow of 7.5 MGD as per NPDES Permitting Guidance to
implement ammonia chronic criteria. (See A. (2))'
The "daily" does not match up with the Effluent limitations and monitoring requirements page. Should
this read monthly and weekly average, not daily maximum?
Regardless of the language of the ammonia nitrogen requirements, the Town does not agree with the
increased monitoring of NH -3 on the 3.5 MGD permit, previous sampling does not support this increased
monitoring. The average discharge for NH -3 for each of the past 4 years has been <.50, with only 2
samples out of 205 being >= 2.0 mg/l. A total of 184 samples resulted in a zero (0) or less than detection.
The Town further opposes the increased monitoring and included limits on the 7.5 MGD permit based on
the past results. The Town feels the changes in NH -3 monitoring for the 3.5 and 7.5 MGD permit are
unwarranted. The Town requests that NH -3 remain the same as the current permit, monitor weekly on the
3.5 and 7.5 MGD or be removed altogether.
The Town request, as has been requested in the past, that the upstream and downstream monitoring
requirement be totally removed from the permit. The data, that is collected by the Town, from upstream
and downstream monitoring has no scientific value. The current permit allows for sampling once per
week during the summer months and once per month during the remaining months of the year. The Town
has seen no variability in the data over the years. Data collected has not been useful in modeling any
changes to the lake over the years. The Town feels that the upstream and downstream sampling is a gross
miss use of time and resources, both for the Town and anyone that reviews the data. And as such should
be removed from the permit requirements.
The Town would also like to go on record as opposing the usefulness of the Mercury Minimization Plan
(NHAP). The issue of mercury in the streams was not created by the wastewater plants, but the wastewater
plants are being made to bear a great deal of the cost and responsibility in an attempt to remove mercury
and clean up the waters of the state, when most mercury is a result of discharge of mercury into the
atmosphere. That being said, the Town will comply and have a MMP in place within 180 days permit
effective date.
Thank you,
Greg Padgett
Water Resources Director RECEIVED/KICOEO/M
828-879-2131
NOV 2 8 2017
waw. Juallty
Permitting Section