NC0074772_Comments on Draft Permit_20180228

February 28, 2018
Division of Water Resources
Water Quality Permitting Section — NPDES
Attention: Joe Corporon
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Comments on Draft Permit Modification
Aqua North Carolina, Inc.
Diamondhead Subdivision WWTP (WW -2)
NPDES No. NCO074772
Iredell County
Dear Mr. Corporon,
RECEIVED/DENR/DWR
MAR ®'S 2018
Water Resources
Permitting Section
Aqua North Carolina, Inc. (ANC) has reviewed the draft NPDES Permit NC00074772
modification received by our office February 9, 2018, and has summarized our comments below.
Section A. (1.) Effluent Limitations and Monitoring Requirements
Footnote 8 — We are requesting a period of forty-eight months from the effective date of the
revised permit to achieve compliance with the limits imposed by the Changes to the Water
Treatment Plant Strategy outlined within this section. Those specific parameters include:
• Total Copper
• Total Fluoride
• Total Chloride
• Total Zinc
• Alpha emitters (excluding radon and uranium)
• Beta emitters (excluding potassium 40 and other naturally occurring radionuclides)
• Tritium
• Strontium
• Uranium
We believe that the data collection efforts, studies, evaluations, design, permitting, and
modifications could require up to forty-eight months to complete to ensure that we can be in
compliance consistently with all of the parameters newly added to the permit.

Section A. (1) Footnote 5
We are requesting a period of four years to achieve compliance with limits specified in Section
A. (1.) that pertains to the compliance limits imposed by the Water Treatment Plant Strategy.
Parameters include with this footnote include Total Chloride, Total Fluoride, Total Copper, and
Total Zinc. Data collection efforts, studies, evaluations, design, and permitting modifications
could require 48 months to complete.
Section A. (1) Footnote 7
We are requesting a period of four years to achieve compliance with limits specified in Section
A. (1.) that pertain the compliance limits imposed by the Water Treatment Plant Strategy.
Parameters include with this footnote include Alpha Emitters, Beta emitters, Tritium, Strontium,
and Uranium. Data collection efforts, studies, evaluations, design, and permitting modifications
could require an additional 48 months to complete.
Section A. (1) Footnote 10
The existing footnote, as currently drafted, reads as is if this is a permit limit. Requesting that the
footnote be revised to state "Monitor Only" in accordance with the guidance provided by the in
the Changes to Water Treatment Plant Strategy document dated October 14, 2009.
Section A. (2.) Chronic Toxicity Permit Limit
Requesting that "Monitor Only" be included in the header for Section A. (2). in accordance with
the guidance provided by the in the Changes to Water Treatment Plant Strategy document dated
October 14, 2009.
We appreciate your consideration of our comments for this permit revision. If you need any
additional information or assistance, please feel free to contact me at 704 489-9404 extension
57234.
Sincerely,
Laurie Ison
Area Manager
4163 Sinclair Street, Denver, NC, 28037 • 704.489 9404 • AquaArnenca corn