NC0024201_Comments_20180905

P.O.Box 308
P�pKE R9.o 1000 Jackson Street
o �d Roanoke Rapids,NC 27870
al OMB Roanoke Rapids Sanitary District [phone]
v Fax: [phone]
www.rrsd.org
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September 5,2018
RECEIVED/DENR/DWR
Ms. Teresa Rodriguez SER 0 7 2018
NC DENR,Division of Water Quality,NPDES Unit Water
1617 Mail Service Center Pesources
Permiuing Section
Raleigh,North Carolina,27699-1617
RE: Permittee Comments on Draft NPDES Permit Number NC0024201
Roanoke River Waste Treatment Plant(WWTP)
Dear Ms. Rodriguez,
The Roanoke Rapids Sanitary District(RRSD) received the draft National Pollutant Discharge
Elimination System(NPDES)permit for its referenced treatment unit on August 17, 2018. Per the cover
letter from the Division of Environmental Quality(DEQ)Division of Water Resources(DWR)NPDES
Unit,we have 30 days from receipt of the draft permit to submit comments to DWR. We respectfully
request that the following changes be made to our permit:
1. We noticed several inconsistencies in our Fact Sheet that require correction,as follows:
a. On page 1,the Fact Sheet incorrectly states that we have two significant
industrial users(SIUs)and one non-categorical user. We have one SIU and two
categorical industrial users(C1Us).
b. In Section 3 Table 1 and Section 12 Table 3,the Fact Sheet references a
dissolved oxygen(DO)limit of 5 mg/L. Our permit does not require a permit
limit for DO. We are required to monitor for DO.
c. In section 5 Compliance Summary the NOV's are not distinguished between
weekly and monthly.
d. On page 5 of 8 and page 8 of 8 in Section 12 Table 3,the proposed effluent
chronic toxicity requirement is specified at 90 percent effluent. Our toxicity
requirement is at 1.1 percent effluent.
2. A typo in our permit cover letter applicant address delayed its postal delivery.The correct
address is P.O.Box 308,Roanoke Rapids,NC,27870. The Fact Sheet correctly specifies
the applicant and facility addresses.
3. Since our NPDES renewal application was submitted in September 2016,we have
determined that our downstream sampling location is not a safe location for our staff at
low flows.We request that the sampling location be moved to 1090 Rockfish Lane in
Weldon,NC in lieu of the current Weldon sampling location at 419 River Road.Our
proposed sampling location remains downstream of our outfall and also the US 158/301
bridge crossing the Roanoke River.

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4. In Section A. (3)of the permit,DEQ has specified that the effluent priority pollutant
scans be conducted in 2019,2020,and 2021. Due to the uncertainty associated with the
timing of this next 5-year permit cycle,we have already conducted a pollutant scan in
2018.We request that DEQ modify the timing of the effluent pollutant scans to 2018,
2020, and 2021.
We very much appreciate the time and effort of the NPDES Unit to consider our requests for
modification of our Draft Permit and Fact Sheet. 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. Danieley Brow .E.
Chief Executive Officer
cc: Steven Ellis, ORC RRSD Wastewater Treatment Plant
Isabelle Wilcoxin,Laboratory Manager Wastewater Treatment Plant
Gregg Camp, Wastewater Treatment Plant
Mary Sadler,PE,Hazen and Sawyer