NC0026441_Comments_20181121 (2)

Gary D Simpson
82 Cynthia Lane
Pittsboro, NC 27312
November 21, 2018
Mr. Michael Templeton RECEIVED/DENR/DWR
NC DEQ Water Quality Permitting Section NOV 2018
1617 Mail Service Center
Raleigh, NC 27699-1617 Water Resources
Permitting Section .
Dear Mr. Templeton,
Below please find my comments on the Siler City WWTP NPDES Permit Modification
No. NC0026441.
I'm asking that the permit modification require Montaire Farms to undertake proper
measures to ensure that Siler City wastewater discharges will not raise total nitrogen
levels beyond the current average of 1.8 mg/I in the Rocky River below Loves Creek.
In 2007-2008 total nitrogen levels in the Rocky River below Loves Creek averaged 12.6
mg/I when both the Pilgrims Pride and Townsends chicken processing plants were in
operation. Current permit provisions for Montaire Farms mean that total nitrogen levels
below Loves Creek could exceed the elevated 2007/8 level by as much as 60%. Such
elevated nitrogen levels will cause extreme algal blooms that must be avoided.
The modified permit should include the following provisions.
(1) To avoid violating the Clean Water Act provisions concerning new discharges
into impaired waters, the permit must state that nitrogen pollution will be
disallowed in Loves Creek and the Rocky River below US Hwy 64 until a
TMDL is completed for both areas.
(2) N.C. Water Quality Standards guarantee protection of downstream uses of
the river including wading, boating and fishing. The current modified permit
does not protect the Rocky River because of the elevated levels of nitrogen
that are allowed.
(3) Before the modified permit is issued, a public hearing on the permit
modifications should be scheduled.
Sincerely,
Gary D. Simpson
Qa vy D. so-w