NC0006548_Comments_20190730

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LI T V pay (City of iTM't
tivalet o ; All-AmmicaCltr
• kip Office of the City Manager
IR97
August 2,2019
DENR DWR RECEIVED/NCDEQ/DWR
Compliance &Expedited Permitting Unit
1617 Mail Service Center AUG 0 6 2019
Raleigh,North Carolina 27699-1617
Water Quality
Permitting Section
To Whom it May Concern:
My name is Jonathan Blanton and I am the City Manager in Hamlet, North Carolina. I am writing
today in regards to the July 19, 2019 correspondence to the-City of Hamlet ("the City") imposing a
sewer line moratorium and requesting a demonstration of.future wastewater treatment capacities for
NPDES Permit NC0047562.
During calendar year 2018,the City's wastewater treatment facility averaged a flow of 0.8043 MGD.
This average flow exceeded the 80% threshold as is mandated by Rule 15A NCAC 02T.00118 from
the Environmental Management Commission. The primary reason for this infraction is due to above
average rainfall during Hurricane Florence in September 2018. Prior to this natural disaster,the City
was maintaining flow averages well-below the 80%threshold and subsequently have maintained flow
averages below the required threshold. For example, during calendar year 2017, the City's average
flow was 0.619 and in calendar year 2016,the City's average flow was 0.590.
Contingent on no future natural disasters as the one experienced last fall,the City affirms that we have
made the necessary repairs to ensure future compliance. However,please note that the Cityconcluded
a Wastewater Treatment Plant Operations Evaluation in April of 2019 to evaluate the need for future
expansion. A copy of this engineering report from The Wooten Company is available upon request.
In conclusion,the City has not willingly engaged in the allowance of significant additional allowances
to our wastewater treatment plant to account for the 0.185 change in flow from calendar year 2017 to
calendar year 2018. This infraction was a result of Hurricane Florence and the City is confident that
necessary repairs have been made in the aftermath of the aforementioned natural disaster which will
allow the City to remain in compliance with your agency's regulations in the future. Please do not
hesitate to reach out to me directly should any further action or informati e n eded.
Th yo n est regards,
cc: Fayetteville Regional Office
ona an D.Blanton
City Manager
WWTP PUBLIC WORKS WATER BILLING SENIOR CENTER POUCE DEPT. FIRE DEPT. WTP
582-8074 582.7987 582.7963 582--7985 582.2551 582.2441 582-1117
P.O.BOX 1229•HAMLET.NORTH CAROUNA 28345•[phone]

64904
WAYWAYNI' E FA
July 30, 2019
Via email to ([e-mail]) and US Mail
Mr.Joe R. Corporon, P. G.
North Carolina Department of Environmental Quality
Division of Water Resources
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Comments on Draft NPDES Permit
Permit
548
Wayne Farms 06 Dobson Fresh Plant WWTP
t2ECE11l�p/NCOEQ/DWR
802 East Atkins Street
Dobson, NC AUG 0 6 20i9
Surry County
�/aterQuali
'efmitting Sect on
Dear Mr. Corporon,
Thank you for the opportunity to review and comment on the draft NPDES permit for our
Dobson Fresh Plant. Your June 12, 2019 letter identified changes in the permit renewal
which include the addition of a numeric turbidity limit and turbidity monitoring
requirements. We were surprised with this new permit condition since there have not
been known turbidity issues associated with the effluent.
The Fact Sheet states the receiving stream, Fisher River, is listed on the 303(d) list for
turbidity but does not state any basis for adding turbidity monitoring to the monitoring
requirements in the draft permit. It is well known that stream turbidity is often associated
with construction and land disturbing activities as well as agricultural activities. I
reviewed most of the Stormwater General Permits issued by the Division of Water
Resources and did not identify any stormwater permits with a numeric limit for turbidity.
The Stormwater General Permits cover activities which would have a tendency to have
impacts on stream turbidity and include Construction Activities (NCG010000),Treatment
Works (NCG110000), Stone, Clay, Glass, & Concrete Products (NCG070000), Landfills
(NGC120000). The Stormwater General Permit for Mining (NCG020000) requires semi-
annual sampling for turbidity but contains no numeric limit.
Wayne Farms LLC—Corporate Headquarters
4110 Continental Dr. •Oakwood,Georgia 30566• 1.800.392.0844•www.waynefarms.com

Comments re Draft NPDES Permit No. NC0006548 July 30,2019
Wayne Farms LLC—Dobson, NC Fresh Plant Pg.2
Typically, the effluent is well below the 50 NTU and therefore not likely to contribute to
a violation of the stream standards. Wayne Farms also objects the requirements in
Footnote 3 Turbidity which under certain circumstances goes well beyond the 50 NTU
permit limit. As written, if the instream turbidity falls below 50 NTU at the point of
effluent discharge, the WWTP effluent could be limited under the permit to less than 50
NTU. Additionally, the permit contains no objective data that establishes the instream
background turbidity. Wayne Farms also object to the requirements to sample upstream
and downstream since the sampling locations are not stated in the permit. Wayne Farms
believes there is no basis for a numeric limit for turbidity and requiring additional
monitoring for turbidity and requests the turbidity limit and monitoring requirements be
deleted from the permit when it is finalized.
We appreciate your assistance with the renewal of the NPDES permit and look forward to
working with you toward an appropriate resolution of these issues. I request a call with
you to discuss our comments, potential alternatives to the draft turbidity conditions and
identification of appropriate sampling locations.
Please contact me at(770) 297-3465 or via email at [e-mail] so
we can discuss these matters further.
Sincerely, mi
l9L(
J nathan Green, P.E.
Corporate Environmental Engineering
and Compliance Manager
cc: Jeremy Kilburn—Wayne Farms Corporate (via email)
Jeremy Bowlin—Wayne Farms Dobson, NC (via email)