NC0057533_Public Hearing Officer's Report_20200206

ROY COOPER
Governor
MICHAEL S. REGAN
Secretaij,
S. DANIEL SMITH
Director
NORTH CAROLINA
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6 February 2020
MEMORANDUM
L
To: S. Daniel Smith, Director
Division of Water Resources ..°
From: W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Subject: Hearing Officer's Report and Recommendations
Northwest Water Treatment Facility
NPDES Permit No. NCO057533
Brunswick County
I served as the Hearing Officer for a public hearing held on December 5, 2019, at 6:00 pm at the
Brunswick County Government Complex in Bolivia, North Carolina. The purpose of the public
hearing was to allow the public to comment on the draft NPDES wastewater permit modification
for the Northwest Water Treatment Plant, NPDES Permit Number NC0057533.
In addition to listening to oral comments at the public hearing, I have reviewed all written
comments received during the public comment period which ended on December 5, 2019. In
preparation of this report, I have considered all of the public comments, the public record, and the
site visit conducted at the subject facility.
The report has been prepared using the following outline:
I. Introduction
II. Facility Background
III. Public Record & Comments with Responses
IV. Recommendations
V. Attachments
Page 1 of 81

HEARING OFFICER REPORT
for
Major Modification of NPDES Permit NCO057533
Northwest Water Treatment Plant
Brunswick County, NC
This report is presented to the Director of the North Carolina Division of the Water Resources
INTRODUCTION
On November 4, 2019, a notice of Public Hearing was published requesting public comment on
the Draft NPDES Permit major modification for the Northwest Water Treatment Plant located in
the Cape Fear River Basin. This facility is located at 3954 Clearwell Drive NE, Leland, NC in
Brunswick County. The public hearing was held in response to significant public interest in the
modification of this facility's NPDES Permit (NC0057533).
The public hearing was held in Bolivia, NC at the Brunswick County Government Complex on
December 5, 2019. Approximately fourteen (14) individuals attended the public hearing, not
inclusive of Department staff. Seven (7) people provided oral comments during the public hearing
relativeto the permit modification being considered. These oral comments were mainly focused
on the requirements of the NPDES permit or on the general issues for per- and polyfluoroalkyl
substances (PFAS). The public comment period on the proposed permit modification was open
until December 5, 2019. W. Corey Basinger, Regional Supervisor in the Mooresville Regional
Office with the Division of Water Resources, served as the Hearing Officer.
This Hearing Officer Report summarizes the major issu
process, as well as the Hearing Officer recommendations
Director of the Division of Water Resources (DWR)
recommendations.
FACILITY BACKGROUND
es raised through the public hearing
for the NPDES permit renewal. The
will take final action on these
The Northwest Water Treatment Plant is an existing WTP utilizing conventional treatment
technology with a potable design rate of 24 MGD. Brunswick County has requested a modification
of the permit that will expand treatment capacity as well as include Reverse Osmosis (RO)
treatment of drinking water and add a second outfall to discharge the RO concentrate. The design
potable flowrate of the whole WTP will be 45 MGD (at build -out) with an expected wastewater
filter backwash discharge from the conventional treatment into Hood Creek of 3.9 MGD (at build -
out) and an expected RO wastewater discharge of 0.7 MGD (minimum) to 5.0 MGD (maximum
designed) into the Cape Fear River. The facility will generate discharge of the reject water
concentrate from the RO treatment process continuously. The source water will be surface water
drawn from the Cape Fear River.
The facility discharges to subbasin 03-06-17 in the Cape Fear River Basin. The facility operates
two outfalls; Outfall 001 discharges to Hood Creek and Outfall 002 will discharge to the Cape
Page 2 of 81

Fear River. The receiving waterbody for Outfall 001 (Hood Creek) is classified as Class C;
Swamp. The receiving waterbody for Outfall 002 (Cape Fear River) is classified as Class C;
Swamp, PNA. The facility is located in the southeastern coastal area of the state.
PUBLIC RECORD
The Division conducted a public hearing in Bolivia, NC on December 5, 2019. Approximately
fourteen (14) individuals attended the public hearing and .seven (7) attendees provided oral
comments. Attendees and speakers included representatives from Brunswick County, Brunswick
County Public Utilities, an Engineering Consultant for Brunswick County, and a private citizen
who indicated association with an environmental interest group (Clean Cape Fear). The Division
received sixteen (16) written comments.
1. Oral Comments from Cris HarrelsouLBErmunswick County Health Director:
Mr. Harrelson's comment was to state his support, as Brunswick County Health Director, for the
issuance of the modified permit as written.
Response 1: No response necessary.
2. Oral Comments from Reed Barton PE with CDM Smith:
• Mr. Barton's comment was to state his support for the issuance of the modified permit as written. Mr.
Barton is a Professional Engineer who contributed to the CDM Smith team that designed the proposed
reverse osmosis system. Mr. Barton mentioned in his supporting comments that this type system offers
the best possible reduction on PFAS from source water to produce a high quality drinking water.
Response 2: No response necessary
3. Oral Comments from Donald Dixon. De Director for Wastewater O erations
Brunswick Count • Public Utilities:
• Mr. Dixon's comment was to state his support for the issuance of the modified permit as written. Mr.
Dixon is the Deputy Director for Wastewater Operations for Brunswick County. Mr. Dixon mentioned
that he is a life-long resident of the area and fully supports providing the cleanest and safest drinking
water to all citizens.
Response 3: No response necessary
4. Oral Comments from Emily Donovan Citizen:
Ms. Donovan's comments were in support of approval of this permit modification. Ms. Donovan
mentioned that she was a local resident who has significant concern for the current quality of the
drinking water and being over exposed to PFAS. She also mentioned that she was associated with the
environmental group Clean Cape Fear. Ms. Donovan stated that these PFAS and other emerging
contaminants should be controlled at the source with more stringent regulation on those that
create/produce/discharge them. Ms. Donovan recommended an increase from twice per year
Page 3 of 81

monitoring for PFAS to twice per month monitoring.
Response 4: It is recommended that PFAS monitoring frequency be changed from twice per year to
quarterly upon commencement of discharge from Outfall 002. This recommendation is based on current
Division policy (see Appendix D)
5. Oral Comments from Bob Tweedy, PE with Brunswick County Public Utilities:
Mr. Tweedy's comment was to state his support for the issuance of the modified permit as written. Mr.
Tweedy is employed by Brunswick County Public Utilities and is the manager for the expansion
project. He is also a resident and water customer.
Response 5: No response necessary
6. Oral Comments from Glenn Walker Water Resources Manner, Brunswick Coun
Utilities:
• Mr. Walker's comment was to state his support for the issuance of the modified permit as written. Mr.
Dixon is the Water Resources Manager for Brunswick County. He mentioned that he is a life-long
resident of the area and is in full support of providing the cleanest and safest drinking water to all
citizens.
Response 6: No response necessary
7. Oral Comments from John Nichols Public Utilities Director Brunswick Coun
• Mr. Nichols' comment was to state his support for the issuance of the modified permit as written. Mr.
Nichols is the Public Utilities Director for Brunswick County.
Response 7: No response necessary
8. Written Comment from Robert "Bob" Tweedy, PE Brunswick Counly Public Utilities
Senior Utilities Manner — CIP/Infrastructure
• Mr. Tweedy's written comment was in support of the issuance of the permit modification. Mr. Tweedy
is the Senior Utilities Manager for the expansion project of the Northwest Water Treatment Plant and
the addition of advanced treatment.
Response 8: No response necessary
9. Written comments from Rhonda Olson. Citizen:
• Ms. Olson's comments were in support of approval of this permit modification and reflected a handout
provided to attendees by Brunswick County employees at the public hearing.
Response 9: No response necessary
Page 4 of 81

10. Written Comment from David M. Stanley, III, Executive Director, Brunswick County Health
and Human Services
• Mr. Stanley's written comment was in support of the issuance of the permit modification. Mr. Stanley
is the Executive Director of Brunswick County Health and Human Services. He stated his "full
support" in favor of issuance of the permit modification to ensure "the health, safety, and welfare of
all those who live and visit Brunswick County."
Response 10: No response necessary
11. Written Comment from Andrew Haines, Environmental Praram Supervisor II, Division of
Marine Fisheries — Shellfish Sanitation and Recreational Water Qualily Section
• Mr. Haines' email offered no comments on the draft permit.
Response 11: No response necessary
12. Written Comment from Hannah Headrick, Division of Water Resources - Aquatic
Toxicolo ,r- Branch
• Outfall 001 — Why is Chronic WET testing changing from monitoring only to Pass/Fail testing on
October 01, 2021?
• Outfall 002 — Page 7 of 19, item 6 — Should this be labeled as "Chronic WET testing (Ceriodaphina
dubia) Pass/Fail limit test at 33.3%"?
Response 12: The permittee is being switched from the monitor only to the pass/fail test due to a history
of failed toxicity tests. A compliance schedule is included in the draft permit that will allow the facility one
(1) year after the start-up of the new RO treatment system to address toxicity issues in the Hood Creek
discharge. The permit will be updated in Special Condition A. (1) to reflect the limit test rather than the
pass/fail limit so that the toxicity footnotes in Special Conditions A. (1) and A. (2) match the heading of
the toxicity conditions.
13. Written Comment from Frank Williams, Chairman - Brunswick County, Board of
Commissioners
• Chairman Williams' written comments were in support of issuance of the permit modification.
Chairman Williams mentioned in his comments the critical need for safe, clean drinking water to the
citizens. He also mentioned that "the NPDES permit modification will not increase the amount of
PFAs compounds in the environment because the Northwest WTP is not a generator of PFAS
compounds.".
Response 13: No response necessary
Page 5 of 81

14. Written Comment from James F. Merritt Ph.D. Director Emeritus Center for Marine
Science, UNCW
• Dr. Merritt's written comments were in support of issuance of the permit modification. Dr. Merritt
mentioned in his comments that the proposed modifications to the Northwest WTP appear to be the
best alternative to removing the PFAS compounds from the drinking water. He also stated that he was
hopeful that "the source of these chemicals will be prevented from entering the river by the chemical
companies at some point."
Response 14: No response necessary
15. Written Comment from Paul Biagiotti, citizen
• Mr. Biagiotti's written comment was in support of issuance of the permit modification. Mr. Biagiotti
mentioned in his comment that the proposed modifications were "extremely important" to "ensuring
the health, safety, and welfare of all those who live and visit Brunswick County."
Response 15: No response necessary
16. Written Comment from Randall Woodruff County Manner, Brunswick Counly
• Mr. Woodruff s written comments were in support of issuance of the permit modification. Mr.
Woodruff mentioned in his comments that this project is "crucial to the future growth of the County as
the Utilities Department strives to serve all residents with healthy drinking water...".
Response 16: No response necessary
17. Written Comment from Steven T. Stone Dei)uty County Manager, Brunswick Counly
Mr. Stone's written comments were in support of issuance of the permit modification. Mr. Stone
mentioned in his comments that the proposed modifications to the Northwest WTP appear to be the
best alternative to removing the known PFAS compounds from the drinking water as well as others
that may not be known at this time. He is also a nearby resident and water customer.
Response 17: No response necessary
18. Written Comment from Rob Johnson. Fire Chief. Sunset Harbor Zion Hill Volunteer Fire
Department
• Mr. Johnson's written comment was in support of issuance of the permit modification. Mr. Johnson
mentioned in his comments that the proposed modifications are in the "best interest for all to remove
pollutants from the water...". He also mentioned that emphasis should be placed on removing these
type compounds at the source.
Response 18: No response necessary
Page 6 of 81

19. Written Comment from Dow,las Todd, Chief, Tri-Beach Fire Department
• Mr. Todd's written comment was in support of issuance of the permit modification.
Response 19: No response necessary
20. Written Comment from Mark Vander Borgh Environmental Biologist, Division of Water
Resources — Water Sciences Section/Ecos) stem Branch
The Lower Cape Fear River Program (LCFRP) has four water quality monitoring stations in the same
stretch of the Cape Fear River as the proposed location of the WTP discharge. The LCFRP visits these
stations twice monthly from May to September and monthly from October through April as agreed
upon in the DWR LCFRP MOA. I believe the monitoring frequency in the WTP permit should align
with the LCFRP monitoring frequency.
The LCFRP and the WTP have been in negotiation to have the LCFRP conduct the WTP monitoring
while conducting their routine water quality monitoring. Although the modest instream monitoring
requirements of DO, pH, conductivity, and temperature are easily measured, the logistics of getting to
the discharge location is problematic. The measurements must be taken from a boat, as there is no
bank -side access to the designated upstream and downstream monitoring locations. The time it takes
to calibrate the meter, get the boat in the water, navigate to the discharge point and return to the lab for
post -calibration testing will take 4-5 hours. In addition, all boat runs require two staff as specified in
DWR safety protocols. Therefore, an additional half-day's work for two staff would be required to
meet the proposed permit year-round twice monthly requirement. My concern is that the additional
trips to the WTP to collect those few measurements will be cost prohibitive and/or too time consuming
for the LCFRP to perform. Therefore, a secondary contractor or WTP staff would collect those
measurements, which would not be in concert with the water quality monitoring currently being
performed.
The LCFRP would be conducting their water quality monitoring at the WTP on the same day, with the
same frequency, as it monitors the other stations on the river. This would provide a comprehensive
evaluation of the WTP discharge effects on the river. Measurements of DO, pH, conductivity and
temperature at other locations in the river can be compared to measured conditions around the WTP
discharge. Environmental conditions farther downstream than the WTP discharge can also be
evaluated.
The current LCFRP monitoring coupled with the measurements at the additional locations would
provide the data needed to evaluate the effects of reverse osmosis technology on the river as it removes
emerging compounds from drinking water distribution lines. I do not believe the additional twice a
month sampling for those seven months is needed to provide the data for this evaluation.
I would also add, the requirement for the collection of the instream samples at the same time as the
effluent samples represents other logistic concerns. I do agree all efforts should be made to do so, but
there should be some variance that allows this to occur between field and facility staff's schedules and
work duties. I suggest the requirement be changed from the same time to the same day.
Response 20: The Division has determined the permittee will be required to perform monitoring at the
frequency required in the permit for two years. After 2 years, the permittee may request a reduction in
monitoring for instream parameters, after which the Division will review all data received and determine
if a reduction in monitoring frequency may be granted.
Page 7 of 81

21. Written Comment from Beth Eckert, Chairman, Lower Cave Fear River Research Proeram
The LCFRP currently collects data based on the DWQ determined sampling plan to provide
comprehensive data for the entire lower basin. These data can and are being used to understand the
processes taking place in the river as more stress is placed on the river by increasing use. There would
be a great benefit to having the Brunswick County NW WTP join the LCFRP. The LCFRP has agreed
to conduct the collection of DO, pH, Cond and Temp at the two locations designated in the draft permit;
however, the requirement of twice a month collection during the winter months from October to April
would be difficult to accomplish. The program only conducts twice a month sampling from May to
September as part of their MOA with DWR. If this sampling frequency requirement could be amended
to be consistent with the current plan in the MOA and facilitate their participation in our program it
would be appreciated.
Additionally, footnote 5 on page 7 of their draft permit discusses the waiving of sampling requirements
for hardness if the utility joins the LCFRP. The footnote on other LCFRP member permits waives all
ambient monitoring and does not limit it to hardness. I believe their draft language should be amended
to include waiving the required ambient monitoring as long as membership is maintained.
Response 21: The Division has determined the permittee will be required to perform monitoring at the
frequency required in the permit for two years. After 2 years, the permittee may request a reduction in
monitoring for instream parameters, after which the Division will review all data received and determine
if a reduction in monitoring frequency may be granted.
22-41. Written Comment from F. Paul Calamita III, AquaLaw, on behalf of Brunswick County
• From Page 1, the permit will expire on March 31, 2023, only 3 years from the approximate date of
issuance of the modification. We ask that the Department consider a permit effective period of 5 years.
This will save DEQ and the County staff time by avoiding another permit action in just three years.
Response 22: The expiration date of the permit is based on the permitting schedule used by the Division,
which is done by river basin. Therefore, the expiration date of the permit will remain as is.
• Supplement to Permit Cover Sheet -- Page 2 and 3, Items 2 and 4: Brunswick County requests Items 2
and 4 be removed from the permit. As a minimum, the language of these items should also reference
Item 1, indicating there will be on -going discharge to Outfall 001 and that the notification to the cited
regulatory agencies should be prior to the expanded facilities being brought online.
Response 23: Language will be added to specify notification should be given within 60 days prior to
commencement of expanded discharge from Outfall 001.
Outfall 001 comments:
• Clarify the Authorized Waste Streams: The introduction paragraph on Page 5 only lists filter backwash
as a waste stream that is authorized to be discharged from Outfall 001. This sentence should be revised
to state: "is authorized to discharge wastewaters from media filter backwash and sedimentation basins
through Outfall 001." As revised, this authorization will be consistent with the description of the
authorized waste streams in the Supplement to Permit Cover Sheet.
Page 8 of 81

Response 24: The permit language will be updated to reflect discharge from both media filter backwash
and sedimentation basins.
Revise Copper Sampling Frequency to Quarterly Instead of Monthly: We request that the proposed
copper monitoring be revised from monthly to quarterly for two reasons. First, quarterly sampling will
yield either 12 (if the permit expiration data remains the same) or 20 results (if the permit expiration
date is changed to five years) for consideration to assess reasonable potential during the next permit
renewal. Second, quarterly monitoring will correspond to the quarterly hardness monitoring that is also
required. If the copper monitoring remains at monthly, it will force us to also monitor hardness monthly
(which is clearly unnecessary). If DEQ insists on monthly monitoring for copper, it should be limited
to the next three years and then cease.
Response 25: Monthly monitoring for copper was based on an analysis of discharge data provided to the
Division, which showed a reasonable potential to exceed surface water quality standards. Per the Division's
policy, monthly monitoring was implemented based on this potential, and shall remain in the permit. The
monitoring frequency for hardness will be unaffected by the monthly copper monitoring. Monitoring
requirements for copper will be reevaluated at the next permit renewal.
Revise Effective Date of Chronic Toxicity Limit: Footnote 6 to Table A(1) states the chronic WET test
will become a permit limit on October 1, 2021. Brunswick County requests this be modified so that
toxicity test will change from a monitor only test to a Pass/Fail Limited test 1 year after the discharge
from Outfall 002 commences. Preliminary scheduling indicated discharge from the RO treatment
through Outfall 002 was expected to begin October 1, 2021; however, the project schedule will be
revised. The current startup for Outfall 002 is anticipated in 2022. The delay is due to delays in issuance
of this NPDES permit as Brunswick County is unable to receive LGC approved funding until all the
major permits are finalized. This delay is expected to impact the authorization of the construction
contract. Brunswick requests that the date for change from a monitor only limit to an enforceable permit
limit be conditioned on the startup of Outfall 002 plus one year. The Supplement to the Permit Cover
Sheet requires notification of changes to DEQ prior to use of new facilities capacity; the notification
date in Item 3 — 60 days prior to the start of discharge from Outfall 002 — could be used.
Response 26: The toxicity footnote in Special Condition A. (1) will be updated to reflect the change in
toxicity testing will occur one (1) year after commencement of discharge from Outfall 002 begins.
Outfall 002 comments:
• Clarify Filter Backwash: On page 6, Section A. (2) "EFFLUENT LIMITATIONS AND
MONITORING REQUIREMENTS - OUTFALL 002" please change "filter backwash" to "reject
concentrate wastewater from reverse osmosis units" to match references in the Supplement to Permit
Cover Sheet.
Response 27: This error will be corrected.
• Page 6 Salinity and Conductivity Monitoring Requirements: While the monitoring requirements in the
draft permit match those found in Table 2.1, Monitoring Requirements for Membrane WTPs (from the
DEQ document Changes to Water Treatment Plant Strategy (October 2009)), the membrane facilities
at the Brunswick County Northwest WTP fundamentally differ from those at traditional membrane
Page 9 of 81

plants. The Northwest WTP's influent is freshwater from the Cape Feat River, and the discharge is to
freshwater. As has been demonstrated in the pilot plant data there is very little accumulation of salts in
the concentrate (maximum measured conductivity was 1551 µS/cm2); ions at this concentration are so
low conductivity cannot be converted to salinity. Therefore, Brunswick requests that the salinity and
conductivity in -stream monitoring requirements be deleted from the permit. Brunswick requests the
removal of all upstream and downstream sampling from the permit due to:
o Tidal influence at this point in the river.
o Relevance for such data where it has been demonstrated that the effluent has very low salinity
and conductivity.
o Even if Brunswick owned a boat capable of navigating the river, the nearest boat landings are
14 miles downriver and 18 miles upriver. This would put an undo -burden on staff to perform
this type of sampling. Moreover, additional staff would need to be hired and trained adding to
the burden for this unnecessary sampling.
o Accordingly, the County requests that in -stream monitoring requirements be waived as long
as Brunswick County remains a member of the Lower Cape Fear River Program. This waiver
has been provided to other NPDES permits in the lower Cape Fear River basin.
Response 28: Upstream and downstream monitoring requirements will remain in the permit, and removal
may be evaluated at the next permit renewal based upon monitoring data. The Division has determined the
permittee will be required to perform monitoring at the frequency required in the permit for two years.
After 2 years, the permittee may request a reduction in monitoring for instream parameters, after which the
Division will review all data received and determine if a reduction in monitoring frequency may be granted.
• Page 6 TRC limit: We ask that the TRC limit be reevaluated based upon the revised dilution requested
below.
Response 29: Per the Division memo dated June 19, 2003 (Total Residual Chlorine Policy for NPDES
Permits), a maximum TRC limit of 28 µg/L is allowed in NPDES permits to protect against acute impacts.
The TRC limit in the draft permit is the maximum allowed by the Division and was based on the approved
dilution zone.
• Page 6 Fluoride Limit: When the new RO facility goes online, the location of the fluoride addition to
finished water will be downstream of the RO facility feedwater. There will be no fluoride addition at
the Northwest WTP that can reach the concentrate. Brunswick requests that the permit limit and
monitoring requirements for total fluoride be removed from the permit.
Response 30: The limit and monitoring requirements for fluoride are based on pilot study data submitted
with the permit modification request, which showed the potential for fluoride to be discharged. As such,
the limit and monitoring specified will remain.
Page 6 perchlorate limit: Brunswick does not utilize bleach solutions and there is no reasonable
potential to form perchlorate in the process. This is especially the case when the updated dilution value
proposed below is applied.
Response 31: The limit and monitoring requirements for perchlorate are based on pilot study data submitted
with the permit modification request, which showed the potential for perchlorate to be discharged and
exceed water quality standards. As such, the limit and monitoring specified in the draft permit will remain.
Page 10 of 81

• Total Copper and Zinc Monitoring in the Effluent: We ask that the Department remove the Total
Copper and Zinc sampling requirements as no copper plumbing or zinc is being used to construct the
Reverse Osmosis facility. If the Department insists on copper and zinc monitoring, the permit should
allow the Department to terminate such monitoring at the County's request after two years.
Response 32: As Outfall 002 is a proposed new discharge, monitoring shall be required per Division policy.
Monitoring requirements will be reevaluated at the time of permit renewal based upon submitted
monitoring data.
Hardness Upstream Sampling Location: Brunswick requests that sampling for hardness in the
"upstream" water be allowed to be taken from the raw feed water for the plant. This location is a
representative of the "upstream" sampling location because the hardness in the Cape Fear River is
reasonably constant between Lock and Dam No. 1 (withdrawal location) and proposed Outfall 002.
Matt McIver of the UNC W Center for Marine Science has recently begun collecting data on hardness
in the river and provided via personal communication that recent hardness values at the power plant
and just downstream at the Pender County discharge are virtually the same.
Response 33: The location specified in the draft permit for upstream hardness monitoring will remain as
the location of the raw water intake at Lock and Dam No. 1 is several miles upstream from the proposed
discharge location for Outfall 002, with one major NPDES permitted discharger between the two locations.
The footnote added to Special Condition A. (1) waives instream monitoring reporting requirements as long
as Brunswick County remains a member of a monitoring coalition.
Correct Representative Sampling Requirement - Bottom of Page 7: Change from "typical" to
"representative" in the following sentence as the regulatory requirement is that monitoring data be
representative of the effluent being sampled: All samples must be collected from a typical discharge
event.
Response 34: The conditions under Sections A. (1) and A. (2) have been updated to be consistent with that
used in other NPDES permits.
10:1 Mixing/Dilution: The CDM Concept Design and Dilution Modeling (revised Feb, 2019) analyzed
the mixing mechanics, the regulatory requirements and other relevant factors. CDM concluded that a
discharger -specific dilution ratio of 47:1 for the anticipated diffuser installation is in accordance with
the applicable regulatory requirements and guidance, although the 47:1 ratio itself was chosen based
on some of the projected worst case effluent data, and not as a limit on the extent of the actual
anticipated dilution (which is expected to be even greater). The DWR Fact Sheet references the CDM
document.
o In addressing the potential discharge of dichloroacetic acid (DCA) at new outfall 002 the Fact
Sheet cites the highest CDM-projected effluent DCA concentration and concludes that a
"Target Dilution" needed to meet the relevant standard is 3:1. The Fact Sheet then specifically
applies the 3:1 Target Dilution. The Fact Sheet then, addressing a number of other pollutant
parameters, refers to the 3:1 dilution (and the 7Q10 critical low flow) and concludes that no
monitoring is required except for perchlorate (for which a numeric limit is proposed along with
monthly monitoring).
o The Fact Sheet goes on to address potential carcinogens, referring to 10:1 dilution and the
annual average instream flow statistic. Monitoring is proposed for some but not all of those
parameters, concluding for some that no monitoring is needed based on DWR's WTP strategy.
Page 11 of 81

o Brunswick County requests that DWR utilize a discharger -specific overall instream dilution
factor of at least 10:1 for this permit cycle, for the following reasons. First, as noted above, the
upgraded WTP facilities are not yet constructed, there is no discharge, and the CDM
projections of potential effluent pollutant concentrations are estimates based on pilot plant
concentrations and projected feed water/permeate ratios. Therefore, there is uncertainty in the
effluent characteristic projections which warrant allowing more of the available dilution to be
applied. Also, it is clear that for most or all of the parameters considered, the trace chemical
constituents involved are simply a pass -through concentration of constituents derived from the
WTP intake water from the stream. Further, there is no issue of process generation of pollutants
or discharge of traditional process wastewaters. In fact, this is a classic case for which a proper
mixing analysis is most appropriate, as the real concern is the localized concentrations. Note
that the WTP Strategy specifically requires (section 2.1) that new RO dischargers must perform
dilution modeling. We presume this is in part because of the factors we note here, and we
believe that using more of the demonstrated available mixing/dilution is particularly
appropriate and necessary here.
o DWR's mixing zone policy supports the specification of dilution or mixing zone parameters,
particularly in cases in which an effluent diffuser is proposed. Mixing Zones in North Carolina
at p. 2 (DWR July 23, 1999). Note also that there may be pollutant parameters for which the
application of a 3:1 dilution (out of the 47:1 available) may indicate reasonable potential,
though again related to the pass -through point noted. This is where the CDM recommendations
are most helpful. Because of the uncertainty in the effluent parameter projections, and because
of the nature of the pollutant parameters themselves, we request that DWR use a dilution factor
of at least 10:1 for this permit cycle. That would of course assume the installation and operation
of the diffuser as projected in the CDM report. A 10:1 dilution ratio still provides an extremely
high level of conservatism, and correspondingly high confidence in water quality protection.
We also ask that the draft numeric limits for total chloride, total fluoride and perchlorate be
reconsidered in light of the dilution, and either deleted in favor of routine monitoring or
amended in light of dilution.
o Finally, the mixing zone does not accommodate the effects of concentrating contaminants
present in the raw water supply using the RO membranes. Brunswick County is expected to
operate the membranes at permeate recovery rates ranging from 85% to 92%, with a target
recovery of 90%. At this level of efficiency, an in -stream dilution of 10:1 will be required to
achieve background levels of contaminants present in the raw water supply. Examples of
compounds fitting this description include fluoride and unregulated chemicals such as many
of the PFAS compounds present in Brunswick County's raw water. Brunswick County requests
a mixing zone achieving at least a 10:1 target dilution for maintaining compliance with existing
regulatory requirements and reserves the right to request some of the additional available
dilution in future permit renewals should that be necessary to address future water quality
standards for other chemicals (again, most likely present in the County's raw water supply).
Response 35: The mixing zone approved by the Division was based on information provided during the
permit modification request. The Division -approved dilution of 3:1 will remain in the permit. As such,
limits for total chloride, total fluoride, and perchlorate will remain as specified in the draft permit as the
limits were based on the allowed dilution and reasonable potential analysis. A reevaluation of all permit
limits will be conducted at the next permit renewal.
• Section A(6) Instream Sampling Locations: The locations proposed for sampling instream water
quality are problematic. First, the permit is unclear where the preferred sampling stations are located
Page 12 of 81

as only their longitudinal and vertical locations (relative to the main flow of the river) are described.
The lateral distance into the river for sampling is not described.
o If the intent of monitoring is to sample upstream conditions and then recently discharged
effluent at the edge of the mixing zone, these locations will be difficult to determine in the field
because the proposed discharge at Outfall 002 has been designed to jet the discharge toward
the middle of the river, and its trajectory will bend slightly based on the river's current, which
depends on the tidal stage and the river's flow rate. And even if the location can be determined,
it will be hard to maneuver the boat to that location and then hold the boat on station during
the several minutes it will take to lower the multiparameter probe, equilibrate it at the target
vertical sampling depth, and collect the sample readings; personal conversation with Matt
McIver whose organization will conduct the sampling indicates that dropping an anchor will
not be possible at all sampling dates due to currents or at all if the locations are close to the
shore where the anchor would have a great risk of being caught on snags. Further, given the
close proximity of the upstream and downstream sampling locations (20 longitudinal feet),
Brunswick County is concerned about the ability to obtain representative upstream and
downstream samples given the dynamic nature of the plume, potential for boat drift while "on
a sampling station," tidal nature of the location, and the multiparameter probe being swept in
the down -current direction from vertical.
o While the County understands that this sampling is grounded in the requirements of the WTP
permitting strategy, it is important to note that the Outfall 002 concentrate will not contain
temperature, pH, salinity or conductivity, dissolved oxygen or oxygen demanding substances,
to be significantly different from the river. The report Concept Outfall Design and Dilution
Modeling for the Northwest Water Treatment Plant's Concentrate Discharge provides data on
pH, TDS, and BOD for reference.
o Accordingly, the County requests that in -stream monitoring requirements be waived as long
as Brunswick County remains a member of the Lower Cape Fear River Program. This waiver
has been provided to other NPDES permits in the lower Cape Fear River basin.
Response 36: Upstream and downstream monitoring requirements will remain in the permit, and removal
may be evaluated at the next permit renewal based upon monitoring data. The Division will agree to a
waiver of instream monitoring reporting requirements as long as Brunswick County remains a member of
a monitoring coalition. It is the Division's understanding that the Lower Cape Fear River Monitoring
Program intends to perform all instream monitoring at the locations specified in the draft permit.
Additional comments:
• Section A. (3): The copper compliance schedule requires achieving compliance with the limit by April
1, 2022, which is approximately 2 years and 5 months from the date the draft permit was issued.
Therefore, provision #3 of Section A. (3), which requires reporting 3 years from the effective date of
the permit is not needed and should be removed from the permit.
Response 37: The third year was included as the compliance deadline and was over 2 years away. Thus, by
including the third year, allowed Brunswick County time to further report to the Division the actions being
taken. This correction will be made.
• Section A. (7) Reporting Requirements after Commencement of Discharge: This section requires
Brunswick County to complete a requirement 2 years after commencement of discharge for Outfall
001. Outfall 001 is currently in service. Please remove this requirement from the permit.
Page 13 of 81

Response 38: This requirement will remain as the facility is expanding and this additional monitoring will
be required after expansion has completed. The permit condition will be updated to reflect this.
Section A. (8) Reporting Requirements for Emerging Contaminants: The Northwest WTP is not a
generator of the PFAS compounds required for monitoring in this section of the draft permit. PFAS
compounds are present in the WTP's source water. With the proposed addition of membrane
technology, Brunswick will be providing its customers with the most protective advanced treatment
measure for human health. The current treatment process allows PFAS to be delivered to customers
and is then returned to the Cape Fear River Basin, Lockwood Folly River Basin, Shallotte River Basin,
Waccamaw River Basin, and Greater Lumber River Basin through irrigation, septic, and W WTP
discharges. The return of the concentrate to the river is not a net addition of pollutants to the
environment (or an increase in mass of PFAS compounds) over the concentrations that were present in
the raw water. It is requested that the permit language acknowledge that the discharge does not result
in a net increase into the environment and is therefore not a pollutant addition. Moreover, it is requested
that all PFAS monitoring be eliminated from the permit since 1) the Northwest WTP is not a producer
of PFAS, 2) PFAS concentrations within the river are known through raw water testing and DEQ
sampling, and 3) pilot testing confirms that essentially all PFAS in the raw water are removed by the
LPRO process.
Response 39: As indicated by monitoring data submitted with the permit modification request, PFAS
compounds are present in the wastewater discharged to the Cape Fear River. As the wastewater discharge
from the facility contains these compounds, monitoring will be required.
• Section A. (9) Disposal of Spent Membrane Cleaning Solutions: The last sentence of this section should
be clarified to add the words in all capital letters that ".....and discharge of the solution WITH
DETERGENTS to surface waters is not authorized under this permit."
Response 40: This clarification is stated earlier in the sentence as "When use of detergents is used with
membrane cleaning solutions..." therefore no changes are required.
• Page 16, item 1. Remove inapplicable reporting requirements: The draft permit requires the permittee
to submit reports on (1) sewer overflows and bypass events, (2) pretreatment program reports and C WA
section 316(b) reports. These reports are not relevant to a water treatment plant and should be removed
from the permit.
Response 41: All language in Section A. (13) will remain as it is standard language used in all NPDES
permits. The permittee shall follow all applicable requirements.
42-47. Written Comment from Geoff Gisler and Jean Zhuang, Southern Environmental Law Center
S( ELO
• Prior to detailing specific concerns with the draft permit, SELC states the following on page 1 of the
written comments: "Brunswick's new water treatment facility is a significant step forward in providing
safer drinking water to its customers by removing PFAS from it intake water. We support that process
and these comments are not intended to delay or prevent the construction of the facility. Providing
clean drinking water to Brunswick County's customers is of paramount importance."
Page 14 of 81

Response 42: No response necessary.
• Brunswick County has not adequately disclosed PFAS in its NPDES permit application.
Response 43: Brunswick County did submit PFAS data to DWR via email on November 16, 2018.
• DEQ has failed to evaluate limits for PFAS in Brunswick County's draft NPDES permit.
Response 44: No state or federal water quality standards currently exist for PFAS and therefore no effluent
limitations can be calculated at this time.
• The proposed monitoring requirements are inadequate. In the draft permit, DEQ requires Brunswick
County to sample its discharge for PFAS twice per year. Sampling twice per year simply cannot
account for the know variability in these pollutants. DEQ has recently required facilities to sample
monthly for PFAS and 1,4 dioxane, and should require at least monthly monitoring here.
Response 45: It is recommended that monitoring for PFAS should be increased to quarterly (from twice
per year) upon commencement of discharge from Outfall 002. This is consistent with current Division
policy (see Appendix D)
• PFAS are harmful to human health and the environment.
Response 46: DEQ and other state agencies continue to evaluate the human health and environmental
effects of PFAS.
• PFAS contamination is unnecessary. DEQ must use its authority to aggressively control PFAS
discharges upstream of Brunswick County's facility so as to prevent the pollution from appearing in
the facility's waste stream.
Response 47: DEQ is working diligently and expeditiously within its delegated authority to control PFAS
related issues in NC. DEQ is also working collaboratively with other state agencies and the EPA to address
PFAS related contamination.
HEARING OFFICER RECOMMENDATIONS
Based on review of the public record and written/oral comments received during the public
hearing process, I recommend to the Division Director that the NPDES permit for the Northwest
Water Treatment Plant (NC0057533) be revised and issued as follows:
1) Recommend modifying the effluent limitations page [Part I, Section A. (2)] and emerging
compounds reporting requirements [Part I, Section A. (8)] to reflect monitoring frequency
change for PFAS from twice per year to quarterly upon commencement of discharge from
Page 15 of 81

Outfall 002. This recommendation is consistent with current Division policy (see
Appendix D).
2) Modify the effluent limitations page [Part I, Section A. (1), Footnote 6] as follows: "6.
Chronic WET testing (Ceriodaphnia dubia) monitoring only at 90% in February, May,
August, and November [See Section A. (10)]. Beginning one (1) year after the
commencement of discharge from Outfall 002, with notification to the Aquatic Toxicity
Branch, Chronic WET testing (Ceriodaphnia dubia) Pass/Fail limit at 90% in February,
May, August and November [See Section A. (11)]."
3) Modify the effluent limitations page [Part I, Section A. (2), Footnote 6) as follows: "6.
Chronic WET testing (Ceriodaphnia dubia) Pass/Fail limit test at 33.3% in February, May,
August, and November. See Section A. (12)".
4) Upstream and downstream monitoring requirements should remain in the permit as
drafted. However, it is recommended that the reduction of upstream and downstream
monitoring may be evaluated at the next permit renewal based upon monitoring data. It is
recommended that the permittee be required to perform monitoring at the frequency
required in the permit for two (2) years. After two (2) years, it is recommended that the
permittee be allowed to request a reduction in monitoring for instream parameters, after
which the Division should review all data received and determine if a reduction in
monitoring frequency may be granted.
5) In the Supplement to Permit Cover Sheet, Items #2, #4, and #5 should have language added
to specify that notification should be given within 60 days prior to commencement of
expanded discharge from Outfall 001 since there will be on -going discharge from Outfalls
001 and 002 during expansion phases.
6) On permit page 5 of 19, [Part I, Section A. (1)], the language should be modified to reflect
"...discharge is from both media filter backwash and sedimentation basins through Outfall
001."
7) Monthly monitoring for copper was based on an analysis of discharge data provided to the
Division, which showed a reasonable potential to exceed surface water quality standards.
Per the Division's policy, monthly monitoring was implemented based on this potential,
and is recommended to remain in the permit. The monitoring frequency for hardness will
be unaffected by the monthly copper monitoring. It is also recommended that monitoring
requirements for copper will be reevaluated at the next permit renewal.
8) On page 6, Section A. (2) "EFFLUENT LIMITATIONS AND MONITORING
REQUIREMENTS - OUTFALL 002", it is recommended to change "filter backwash" to
"reject concentrate wastewater from reverse osmosis units" to match references in the
Supplement to Permit Cover Sheet.
9) In Part I, Section A. (1) and Section A. (2), recommend changing the word "typical" to
"representative" at the bottom of both sections to be consistent with the language used in
other NPDES permits.
Page 16 of 81

10) It is stated in Section A. (3) that the copper compliance schedule requires achieving
compliance with the limit by April 1, 2022, which is approximately 2 years and 2 months
from the date of this report recommendation. Therefore, provision # 3 of Section A. (3),
which requires reporting 3 years from the effective date of the permit, is not necessary and
is recommended to be removed from the permit.
11) Recommend modifying the reporting requirement in Section A. (7) to clarify the two (2)
year reporting requirement will remain as the facility is expanding and this additional
monitoring will be required after expansion has completed.
W. Corey Ba nger, Hearin,' Officer
Regional Supervisor, NC DEQ-DWR-MRO
APPENDICES
4; w Z0zo
Date
A. Draft Permit and Fact Sheet
B. Presentation from the Public Hearing
C. Hearing Registration Sheets
D. DWR Memo "Monitoring Frequency for Toxic Substances", dated 15 July 2010
Page 17 of 81

Appendix A
Page 18 of 81

n
NORTH CAROLINA
EhWrwL"mta1Qwftry
Mr. John Nichols
Brunswick County
PO Box 249
Bolivia, NC 28422-0249
Dear Mr. Nichols:
ROY COOPER
!;a•rmw
MICHAEL S. REGAN
&Nmn
LINDA CULPEPPER
twww
October 31, 2019
Subject: Draft NPDES Permit NCO057533
Northwest WTP
Grade I Physical Chemical WPCS
Brunswick County
The Division has reviewed your request to modify the subject permit. Please review this draft carefully
to ensure your thorough understanding of the information- conditions, and requirements it contains.
The draft permit includes the folloming significant changes firm the existing permit:
1. Outfall map has beery -updated.
2. Receiving stream for outfall 001 has been corrected to state it is an unnamed tributary to Hood
Creek on the Permit Cover Sheet and Supplement to Permit Cover Sheet per information
provided by the permittee's representative.
3. Language on the Supplement to Permit Cover Sheet has been updated for Outfall 001 and new
Language has been added to reflect the proposed expansion and addition of the proposed
Outfall 002.
4. The facility grade has been added in Section A. (1).
5. Turbidity monitoring has been reduced to 2/Month for outfall 001 in Section A. (1) per the
current water treatment plant guidance.
6. Limit for total residual chlorine has been updated for outfall 001 in Section A. (1) based on the.
waste load allocation at full expansion.
7. Limits for copper have been updated for outfall 001 in Section A. (1) per the reasonable potential
analysis-
S. Limits have been removed for fluoride for outfall 001 in Section A. (1) as the reasonable
potential analysis indicates here is no longer a potential to exceed water quality standards, and
the compliance schedule in the renumbered Section A. (3) has been updated to remove fluoride.
9. Limits have been removed for aluminum and monitoring reduced to quarterly for outfall 00 i in
Section A. (1) per the current water treatment plant guidance.
10. Monitoring for zinc has been removed for outfall 001 in Section A. (1) per the reasonable
potential analysis and as the permittee indicated in the last permit renewal application that zinc
orthophosphate or sweetwater CP1236 does not have the potential to be discharged.
11. A limited toxicity test with a compliance schedule has been added in Section A- (1) and language
as Section A. (11) for outfall 001 to address ongoing toxicity issues.
North Caroline Department of Environmental Quality I Division of Water. Resources
1817 Frail Service Center' R"4h, North Carolina 27899.1817
M-707-9000
Page 19 of 81

12. Sections A. (2) and A (12) have been added to reflect monitoring requirements for the proposed
outfall 002, consisting of a reverse osmosis concentrate waste stream into the Cape. Fear River.
13. Compliance schedule in renumbered Section A. (3) has been updated to reflect the current items
remaining until the compliance deadline for outfall 001.
14. Section A. (6) has been added to define instream monitoring requirements for the proposed
outfall 002.
15. Section A. (7) has been added for monitoring that will be required for outfalls 001 and 002 after
discharge commences from the proposed outfall 002.
16. Section A. (8) has been added for required monitoring for WAS compounds at outfall 002.
17. Section A. (9) has been added to address the disposal of the spent membrane cleaning solution
from the reverse osmosis treatment.
18. Language has been updated in renumbered Section A. (13) regarding electronic submission of
effluent data. Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs)-
Attachment A to this letter contains a list of labs that have been pre -approved as capable of analyzing
WAS by LCMSMS Compliant with Table B-15 of QSM 5.1 or Latest Version or with an acceptable
variation. Please be aware that criteria are being developed for PFAS compounds and are likely to be
lower than the current drinking water health advisory level. The PFAS drinking water health advisory of
70 ng/L is the target concentration for the sum of sample results for PFOA and PFOS. Results for WAS
that do not currently require action may trigger reduction activities in the future.
The NC 200 -201-0 dilater Quality Standard (WQS) Triennial Review was approved by the NC
En ironmenW (Management Committee (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions our April 6, 2016 with some exceptions. The NC Division of Water
Resources NPDES Pemutting Unit is required to implement the new dissolved metal standards in all
Dues public noticed after April 6, 2016.
The new stands & for most metals include acute standards. Further, the freshwater standards for several
metals are eWess ed as the dissolved form of the metals, and seven metals have hardness -dependent
equations. As a result, the NPDES permitting Unit will need site -specific effluent hardness data and
instrean: bxdn.es s data, upstream of the discharge, for each facility monitoring these metals in order to
calculate p emit :=dtations. Effluent hardness and instream hardness sampling, upstream of the
discharge, leas bem added to this permit at a monitoring frequency of quarterly. See Section A.(L)
Effluent L: I;.tiom and Monitoring Requirements.
With this notifecatioz., the Division will solicit public comment on this draft permit by publishing a
notice in newspapers having circulation in the general Brunswick County area, per EPA requirements.
Please pi-mide your comments, tf atty, to the no liven scan 30 days after receising this draft
pet ttsit.
Following, the 30-day public com aftar period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft, please
contact me at 919-707-3619, or via e-mail [Brianna.Young cl�ncdeur gnv].
Page 20 of 81

cc:
NPDES Files
Wilmington Regional office
Wastewater Operator Certification Group
WSS/Agoatic Toxicology Breach
WSSIEcosystems Branch
Division of Marine Fisheries
NC Wildlife Resources Co ---=---- scion
U.S. Fish and Wildlife Service
U.S. EPA WERA Program
Kelly Boone, CDM Smith
Tonathan Treach-W, CDM Smith
Sincerely,
stianna Young
Compliance and Expedited Permitting Unit
Page 21 of 81

A tnJament A
Labs as lrvi•Od by NO)EQ-'DAM t'0j• the 1'FAS Waiter- ater Influent S-Clwau ag sm1pon :,
(Note: M%st labs on dais List ice also listed on t1w DeVa kmit of Defense accxeWed list as oved fm
PFAS testing mug LCl1 S?vlS with Lsotf4x Diltation, feud by vWting
hm7. wtivn,.denix_osd.miltcdgiv/accreditation,accreditedlabsI noon seared ing by cr .iod `'PFAS'try
LCMSKS Cowliatst vAttt Table 13-19 of 01TV15.1 or Latest Veision".)
ALS EXA60)P]dt AMW — 9e150
MAzxam Analydes 1dernatio=1 Corp
1317 S. ITNAvenue
6740 C=poWl10 Road
Kelso, Wa*iiWou 98626
Jhfisstssauga, i' W;Ado L5N 2L8
(340) ..577-72.12
0*5) 817-5700 httu:. fmaxxam.ca
htm yrnwa4globa:com
APPL, Inc.
Microbac Laboratories, hre. - Ohio Valley Division
909 N. Temperance Arenue
158 Stulite Dri►•e
Clods, CA 93611
Marietta, OH 45750
[phone] hft t�-aenlinc_mm�
[phone]
h:Owww.minobae.com±'oarlaborato=n; s�marieih-ohiol
Alpha Analytical
SGS AXYS Analytical Senices Ltd
8 Walkup Drive
2045 Mills Road W.
Westborough, MA 01581
Sidney BC, Canada V8L 5X2
[phone] hriv:lfwww.auab.orz!
[phone]
hm www1XV-j"h2CaIcom,.
Battelle
*SGS North America, Inc. - Orlando
141 Longwater Drive, Suite 202
4405 Vineland Road, Suite CIS
Norwell, MA 02061
Orlando, FL 32811
[phone] httv:l.fwww.battelle.orzl
[phone]
hthr•Ifwww.szs.comt
*EndWpy Analytical
Shealy Emironmental Senices
2714 Exchange Drive
106 Vantage Point Drive
r-,`— -4- gton, NC 29405 (910)
West Columbia, SC 29172
212-5858 httvs:fAtnthalvv.com!
[phone]
h :Nvwwsheah b.com
Euro6ns Lancaster Laboratories En%uonmenta12425
TestAmerica - Sacramento
New Holland Pike
880 Ri%wside Parkway
Lancaster, PA 17601 (717)
West Sacramento,, CA 95605
656-2300
(9I6) 373-5600
h ww.laacasterlabs.comf
h www testame c com
GEL Laboratories, LLC
Vista Analytical Laboratory
2040 Savage Road
1104 Wind6eld Way
Charleston, SC 29407
El Dorado Hills, CA 95762
[phone]
[phone]
hm,. waw ecl.cam1
hft.LLW --aaalrmcal.rom
Gulf Coast Analytical Laboratories,
Inc. 7979 Innovation Park Drive
Daton &huge., LA 70320
[phone] btr®:C %-ww. cc;j.socar.d
' denotes labs a1)jY(ovrd by NCDFQ•-I)'WR to rtw dw DoD cwVliant mobod ieg"em4fficereditation
scat is aladlar axe a rxoved to ruin a 'araiiataon of t1w: I oD rtletliod.
Lalxxr dorit% that t eheve R" arou tllt! I oD crmpliartt awthod acri ratety and sbcitald be .ioclud d on this
list shall contact 1brisryaa Feftubmigb via 1lllAt'IS:' at 919-707-3625 or by email at
claisf}xzitattr.uiaaVj'@Rct a1:r.gov.
Page 22 of 81

Pmir i `'Cr)o5755:
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NA71ONAL POLLUTANT DISCHARGE ELEVMATION SYSTEM
_ (NPDES3
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Brunswick County
is k by A ioiiwd to di x*-mge wastetiwAtex from a f-miaity lor:atcd at ow
Northwest Water Treatment Plant (WTP) (Hood. Creek Vi7P)
59;4, ClearweM Ilr. NT.
Lflan d
ETUE MICk• C OURu -
to receiving waters designated as an tmta fed tnbutan, to Hood C'ree- within the Cape Fear River Basin
in accordance witheffluent cent limitations, momtomg :eq uremenis, and other conditions set Ponh in Farts
1,11, III, and IV hereof
The permit shall become effective on
This permit and the authorization to discharge shall expire at midnight an March 31, 2023.
Signed this day
Linda Culpepper
Director, Division of Water Resources
By .Aidority of the 1:' viroruaxwezt t nuxat erumt crytturrisuou
Page 1 of 14
Page 23 of 81

Permit N00057533
SUPPLEMENT TO PERNUT CONTR SHEET
All previous NPDES Permits issued to this facility, whether for operation or discbx a are hereby
revoked, and as of this issuance, any Previously issued permit beanng this number a no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises tinder the permit
conditions, requirements, terms, and provisions described hereLr. .
Brunswick County
is hereby authorized to:
Continue to operate a conventional water treatment plant with discharge of vvastevv 2lers at
Outfall 001 from media filter backwash and sedimentation basins, No reverse osmosis
coo-ai ate may be discharged from Oatfall 001. This water iTeab3ent plant cuireaily has a
design potable flowrate of24 MGD and a *na =111 u, monthly' aVeragt vv asteaVater discharge of
approximately 1.49 MGD. This facility fs located at the Northwesi W"M (Hood Creel: NC'7F),
3954 Clearwell Dr. NE in Leland in Brmswick County, �Vate-r and vvaste;vater treatmenf consist:
of:
• Influent disinfection [chlorination?
Tivo (2) 12 \MGD tip -flow clarifiers [dAiafecte-d ravv vvater]
Tv:o (2) bangs of four (4) filters each Mtexj
One. (1) 4 4IGD c:ear wel,
One (1) 2 NIGD surge lagoon
One (I) 0.120'MGD sludge thickenaer
• Dechlorination
• Cah=cal usage consists of-
o
Chlorine dioxide
o
50'1. sodium hv,dromde
o
Polyalt, mioum chloride
O
So(EftBYL silica Lt113ride
o
Bleach-tfiW w1utieas
o
Cationic poYy'Mef sohztiona
o
Calcium thiopbosphate
o
Powered actisated carbon
o
Orthophosphate
2. Upon completionof expansim of potable capacity tip to 36 11GD, and 60 days prior to
commencement ofdischarge from Outfall 001 from media falter backwash and sedimentation
basins, the Wilmington Regional Office staff'and Central Office staff must be contacted. No
reverse osmosis concentrate maybe discharged from Ourfall MI.
3. Upon completion of expansion ofpotable capacity up to 36 MGD; and 60 days prior t:
comment of discharge fromOvtfall 002 of reject concentrate vraste,,v ater from rn-erw
osmosis routs, the Wilmington Regiorsal Oiict staff" and C'eutral Office stab muse be coutacteA
Page 2 of 19
Page 24 of 81

Permit NCO057533
4. Upon completion of expansion of potable capacity up to 45 MGD, and 60 days prior to
commencement of discharge from Outfall 001 from media filter backwash and sedimentation
basins, the Wilmington Regional Office staff and Central Office staff must be contacted. No
reverse osmosis concentrate may be discharged from Outran 001.
5- Upon completion of expansion of potable opacity up to 45 MGD, and 60 days prior to
commencement of discharge from Outfall 002 of reject concentrate wastewater from reverse
osmosis units, the Wdnungtoa Regional Office staff and Central Office staff must be contacted
6. This water treatment plant, upon a.q)aasion at full build -out will have a design potable flownte
of 45 MGD and an estimated R-as tewatker discharge of 3.9 MGD from Outfall 001 from media
filter backwash and sedimentati on basins and a maximum design wastewater discharge of 5
MGD from Outfall 002 of reject concentrate wastewater from reverse osmosis units. No reverse
osmosis concentrate may be discharged from Outfall 001. This facility will be located at the
Northwest WTP (Hood Creek i['TP), 3954 Clearwell Dr. NE w Leland in Bninswnek County.
Water and wastewater treatment will consist of:
• Two (2) 24 MGD rapid mix basins
• Four (4) high rate clanfi er basins
• Sixteen (16) dual media (sand and anthracite) granular media filters
• Two (2) clearwells
• One (1) 4 MGD backwash equalization and decant basin
A Two (2) 80-ft diameter sludge thickeners
o Dechlormation
• Eight (8) 5.15 MGD reverse osmosis Ad&
• Surface water discharge (©v= 001)
• Submerged streambank discharge (Outfall 002)
• Conventional treatment chemical usage consists of
o Chlorine dioxide
o Chlorine
o Powdered activat ed carbon (PAC)
o Polyahiminum chloride (PA3Q
o Caustic soda
c Coagulant aidpoiymec
o Sodium fluorosilicate
o Orthophosphate
o Chlommmes (chlorine plus ammonia)
o Calcium thiosulfate
Reverse osmosis treatment chemical usage consists of
o Sodium bisulfite
o Antiscaiant
o Carbon dioxide
o Emulsified lime
Alkaline or acid solution (for membrane cleaning) - Spent membrane cleaning
solutions shall be treated and mixed with the membrane reject concentrate for
discharge from Outfall 002 or treated and disposed off -site.
]Page 3 of 19
Page 25 of 81

Pemut NC"0057',;
7. Discharge from said treatment works at the location specified on the attached neap to Oiufall 001
into an unnamed tributary to Hood Creek [Stream Segment: 18-66], a waterbody c-�- mi) ,
classified C; Sw within subbasin 03-06-17 [HUC: 0303000504] of the Cape fear Rt ver B a in.
13. Discharge from said treatment works at the location specified on the attached map t o Outfall 002
in the Cape Fear River [Stream Segment: 13463)), a waterbody currently classified C; Sw, PNA
within subbasin 03-W17 [HUC: 0303000504] of the Cape Fear River Basin.
Page 26 of 81

Permit NC0057533
PARS' L
A. (1) EFFLUENT LEM11TATIONS AND MONITORING REQUIREAM-4TS - OUTFALL 001
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Grade I Physical Chemical WPCS [15A NCAC 08G .0302]
Inning the peniod beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge filter backwash firm Outfali 001. Such discharges stall be limited,
monitored and repotted' by the Permittee as specified below:
UnUEW CHARACTERISTICS
Paraw"Co*
LRAITS
1 ONWOMMO
REQltRENEITS
Monthly
Averaw
Daily
maxima"
ttk urement
Fr
Sample
Type
Sample
Location
Flow (MGD) - 500b0
Continuous
Recording
E*jent
Total Suspended Sows C0530
30 mqR
45 m94
Weekly
Grab
Muent
pH OWW
Not < 6.0 s u. nor> 9.0 s.u.
Weekly
Grab
Etlhrerrl
Total Residual ChlotM 2 5WW
17 YgA
Weekly
Grab
EfMmd
Twbp2yy(NTU) 00070
2A41arrrit
Grab
Efbjerrt
Total Alum = (NgA) 01105
Quarterly
Grab
Efkwd
Total Copper 3 01042
8.12 NA
10.74 pgA
Morrtltiy
Grab
Ettkretrt
Total FMwride (WA 00951
Mon"
Grab
EtNrent
Total Nitrogen (TN) (mgiq (WO O
Morrlor 8 Report
Quay"
Grab
Effluent
Total Phosphorus (TP) (MA Cm
Mwft & Report
Quarterly
Grab
E1lrtent
Hardness - ToUl as
CaCO3 or Ca + + 00900
Monitor & Report
Quarterly
Grab
Etit and
Hardness - Toth as 0M
CaG03 or Ca + s
MwAx 8 R
Y
Grab
UPMM
Chromic WET Testing 6 TGP3B
See Footnote 6
Quarterly
Grab
EfRW
Footnotes:
1. The pem►itmee shall submit discharge monitoring reports electronically usmg the NC DWR's eDM R application
system [see Section A. (13)].
2. The Division shall consider all etHuent TRC values reported below 50 µg4. to be in compliance with the permit
However, the Permittee shall rontimte to record and submit all values reported by a North Carolina certified test
laboratory (including field certified), even if these values fall below 50 µg1L.
3. Compliance with this limit shall ca®ence on April 1. 2022. See Compliance Schedule in Section A. (3).
4 Effluent hardness sampling should be performed in conjunction with sampling for hardness dependent metals
(c)-
5. The Permittee shall sample iastream hardness, upstream of the facility's discharge. The sample shall be
representative of the hardness in the receiving stream.
6. Until September 30, 2021, Chronic WET teatiag (Cariodaphnia dubia) monitoring only at 90b6 in Febmars,
hfay, August and Nownber (See Section A- (10)). Beginning October 1, 2021, Chronic WET feasting
(Csrioda *Kd dubia) PanTail limit at 90% in February, May, August and Norember [See Section A. (11)].
All samples must be collected from a te-pieal discharge extent,
The Permittee shall discharge no Boating solids or foam.
Page 5 of 19
Page 27 of 81

Permit NC0057533
A (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - OUTFALL 002
[15A NCAC 02B .0400 et seq., 02B .0500 et seq-1
Upon completion of reverse osmosis treatment units, and lasting until permit esrpirafton, the. Petmittee is
authorized to discbarge filter backwash From OuW 002. Such discharges shall be limited, monitored
anti reported' by the Permittee as specified beer
EFFLUENT CHARACTEMSTICS LOM MONTORING RECAWWRTS
AParametarCode montbly Daily Wasurernent Sample SxWe
AveraW lV u mun EMEM 10 Location'
Flow (MW) 50050 C faro uous Recording Effluent
Dissolved Oxygen(mgrL) 00Ci00 21l %0 grab Effluent
U&D
SAy 00) 00W 2Nonth Grab Effluent
U&D
Condudivity(pmhosbn) 00460 2Mordh Grab Effluent
U&D
PH 00t00 Not t 6.0 s u. nor > 9.0 s.u. we" Grab Effluent
PH (s.u.)
00400
21MOO
Grab
U & D
Total Residual Chlorine'
500B0
284
W"
Grab
Effluent
Total Dissoved Solids (rrm/L)
7WO
2A kw*
Grab
Eflkwd
TuubkRy(NTU)
00070
2AAor*
Grab
Effluent
Total Arsenic (}rglL)
01002
JAM"
Grab
ESuent
Total Cnbdde
00940
345 null
lady
Grab
Efkwd
Total Copper (pg1L)
01042
fly
Grab
Effluent
Total Fluoride
00951
2,700 hall.
sty
Grab
Effluent
Total Zinc (WLL)
01092
W*Vy
Grab
Effluent
Ammonia NtroW (mg&)
C0610
MO("
Grab
Efluent
Perdiorate
61209
4.2 pg&
f4trxrlhly
Grab
Effluent
Total Lead
01051
Qui-rrtc"
Grab
Effluent
Dk *x'm add
51W5
Quarterly
Grab
Efiluexrt
TOW Nihsw am (PUYL)
COW
Qua'"
Grab
Effluent
T,*A F'ixx„ptmm (Tp) (no)
C0665
(uJw y
Grab
Effluent
HaOXISS - ] `" as 009W
#Monitor S Report
Qu it' Grab
I Effluent
(XX)., t)rG--r ¢ •
Haftms - Tout W $ o0900
iatWW g Report
Qua" Garb
1.1 xn
CaCO3 or fCa +
Chromic WET Testing • TGP3B
Pass 1 Fat
QUarlorty Grab
Effluent
PFAS Compounds I
See Footnote 7
Semi*wual Grab
Effluent
Page 6 of 19
Page 28 of 81

PwiLit NCO057533
rC' mtwxtes:
1. 12: ;}MMraiti shill wit r1i sc 1aar aaaaaait<; xlxartt esxasti•� ilky asaa}; tdre : i7W7? 's glrilt
; � vys*= (sue ,%,* as A, (1:3)�.
2.. U = 74nhevm I) == Downstmarraa. ;See Sedum A. (6) fix aras4rram rwmsitmiLi ; nxg nmwts.
3. YC)aa Diuixiusa # WUWdff at11 a £lncaat Fes(: tntlttes tejxxted •below :3S) d try. to be W caawlyd MY&T With dw
pmmt. However, x, OW PeivattekV slum a 3tmue to aeuenact saa'ta wt all VAN s agsxr ,d by a WW1'lt C rolmn
ceddedl test labotAory (int:.iucliaag ald c tfie d), even ifs vatkm fill below 50 pyjL..
4. Effluent lurrdaami =qAwg sbxtiid twe jlredb and ict o0u)ua"m with test ate, for hardmins )eUArat VX481s
(tea, ).
5. Mw F'eaanittw, ;draft -ars de; htstttaa lm daess, up stmzn of the fsidlity's dim. The supple ilaritd be
aepe-atative arf dw b arahke- s in the: weiwiug xtitrauaa. l(f tdm F'txtuWw is a imenber of 'M(K taatW
Coahbou laxsaW&M, sa+cttpkUB for irMueam baokml way be waived .as kw% M the 1VLMLiUMMg roalitum agrM
to sauadate hVdWM at for newest **tam location, at at wauntu m fiepency of gwulmty, and the F'eaaa uce
has itbt xaxta d aFrpxarval from DWR MvDFS F'axniftW, YFatrt ** dw upstmmustatim'beg,, nimntmed by t1w
CAA i•t as is sreptemwL*ve of the xe ccisanta#1 str€ u Ax dais Aw1mge.11w F icawnee is w_%xx sable far
s4Sdauaaitti ag aasd ra iwdaasm tstst xa:swts VAth its lxmmt a wal l:k-At aat PWJDW. xMxtlrtioaa
mmtber:4ktga is camm( tl or We Ctxd tuw tatu nuakn imbra m hwdnom sanakaliaag * the np ryo ed stkatitw, the
aaaa Tlee will nmuedt-Aeky axatify the Division m u:l rrstrcrae suaaW&W, Mira iatt�kr at 1�talaa�xs, tg)st re u of its
u'disrl uga.
6. Clmxu,- WL- I' tcstiaag (urinWayJaua dabaia) limit test at 33.3% an )Ftbruary, Ma), August and NoA tuber.
Sec Section A. (12).
See Section A. (8) Ex=nito mg; requirements.
. 2 sample s roust be collecod from a q-;LW discharge evear.
Thf Peimiim,� shall discharge no floating solids or foam,
Par " c r l a
Page 29 of 81

Permit NC0057533
A. (3) SCHEDULE OF COMPLIANCE - OUTFALL 001
[GS. 143 215.1(b)]
1. Within one year from the effective day of the permit flee Permtttee shall submit to the Division of
Water Resources a Corrective Action Plan summarizing the actions to be taken to achieve
compliance with the Total Capper limits at Outfall 001 and a schedule of activities to implement the
Plan.
2 . Within two years from the effective date of the permit submit a report to the Division srnnmarizing
actions talon in accordance with the Corrective Action Flag.
3. Within three years from the effective date of the pffn)A SuSmit a report to the Division summarizing
actions taken in accordance with the Corrective Action P12n.
5. Achieve compliance with Total Copper limits specified in Section A. (1) by Aid 1. 2022•
Upon approval of the Corrective Action Plan by the Division, the report and actions become an
enforceable part ofthis permit. Any modifications to The schedule shall be requested to the Division at
least ninety (90) days before the deadline. Modifications to the schedule in excess of four months will be
subject to public notice.
The Corrective Action Plan and reports shall include the owner's name, NPDES permit number and
Permittee contact person, and shall be submitted to:
(1 J 1t CDEQ I Division of Water Resources
N-PDES Compliance and Expedited Permitting
1617 Mail Service Crater
Raleigh, NC 27699-1617
(2) NCDEQ / Division of Water Resources
Wilmington Regional Office
127 Cardinal Drive Ext.
Wilmington, NC 28405
A. (4 PERMIT RE -OPENER. WHOLE EFFLUENT TOXIC'ITi'
(G.S. 143-215.1(b)]
Whole Effluent Toxicity monitoring results indicating aquatic toxicity may result in the Division of
Water Resources re -opening this permit, or requesting by letter that further action be taken. Additional
metals tc ling„ a toxicity identification evaluation, a toxicity reduction evaluation, and/or an assessment
of dischar ce t reatment alternatives maybe requested.
A. (� PERMIT RE -OPENER: TMDL I-AMEMENTATIO:,
(G.S. 143-215.1(b)]
The Division may, upon written notification to the Pemritke, reopen this permit in order to incorporate
or modify effluent limits, monitoring and reporting requirenems, and Wier permit conditions when it
deems such a ctiaa is necessary to implement TMDL(s) approved by the USEPA.
A. (6) iNSTREAM SAMPLE LOCATIONS
The Permittne shall collect grab samples at the designated locations and frequency during a comtimrolrs
discharge event after a minimum of i .hour of continuous discharge has occurred. Effort should be made
Page a of 19
Page 30 of 81

Prinjit N(AW-1533
to sxillrxt Idle Ungle ;sawr-al ket below the 'WrWX watex kwl of at ft xwd n Water dejXfi of tk river
:at tw Prrixit at Which 1w s'agik: is tied Vi a. Ewe .effixi aboald be mack, to aVhr-ate
location ad &gatte each tkw' i"Ixrma SWVICS we tAm. To 1wevide a peat d roxxkpZi%M the rcaliwed
effluent tab sa )k: shoeuld'tr; c oUctel at dxe -.wr tbrw.
In acx:ordaze; ti+n & 15A MAC 2B .0:503(cX 4), strem sacrxd)li, nasty be diwontion rA When floury
e IWAti(rtas sxr Wimw wren diee canditim cmdd rrstdt ira diary tv d di of We pe rik*s) c&hldeK%wg Aw
sax*tm. In :sttc:h am, on ere h day that muphng is dWMdkU&4 itt s_jiistiFie agora for dw
diwA*fi wi .4 all be; VwAtA iu the rraixuitcnirif; a art fcxr +.tw arurrath ixa +ariti(:la fir. e„Nrrmt €x:cwre d.
TU-% pwvLsiora.Aso aljilies to iufrttjq xxt d2hialt :t- azmplirif,.
11) :fed 10 feet
l7pstxe.: — t7 1D _ IAaese astA e
-------------------------- ----------- -------- -----------•------ X --------------
NO SCALE DISCHARGE LINE
"X" Marks the sample location ~— u 12 it from riser surface
H 6 ft from riverbank
Location Description:
U = upstream 10 feet, perpendicular to diffuser, approximately 12 feet from river surface and 6 feet from
riverbank
D = downstream 10 fret, pegnndicubw to diffuser, approxi= f ch, 1.2 feet from river surface and 6 feet
from riverbank.
A. M REPORTING REQiJIRMMNTS AFTER COMJEKC'E'ii7£NT OF DISCHARGE
In accordance with 40 CFR 122.2l(kX5Xvi), no later than 2 years aftet the coauneneeme nt of discharge
from the proposed facilitythrough outfai1001 and outfail 002. tl- applicant is teq�=ed to complete and
submit items V and VI of 1QDES application Foam 2C for outfal3 001 aad eu=002 , Flme note that
all data generated must be reported to the approved detection level of 10 :firer reporting level of the
procedure. Practical Quantitation Limit levels can be found on the DWR website at:
tt :/1 .nc. ov/about/diiisionslwat-rmourceshnte r re mrces-data/wate r-sciexroes-homt~
yaee nficmbioloQwinorrranics-braach/metbods-oals-ea. Two copies of items V and VI of NPDES
application Form 2C shall be submitted to:
:Page 9 of 19
Page 31 of 81

Permit NCO05753.3
Attention: North Carolina Division of dater Resources
Wastewater Branch J NPDl rS
1617 Mail Service Center
Raleigh, North Carolina 27699-162.1
In addition, no later than 2 yestrs after the commencement of discharge frama the proposed facility
through outfall 002, monitoring shall be performed and reported for all parameters listed in Attachment I
of this permit for outfall 002,. See Attachment I for wquired monitoring.
A. (8) REPORTING REQUHMIENTS FOR EMERGING COMPOUNDS - OUTFALL, 002
Monitoring for emerging compounds will be required for Outfali 002 at a semi-annual fiequency
Samples collected should be representative of the typical wastewater discharged from the facility"
Sufficiently sensitive test methods shall be used. All data shall be reported in the units of ng/L" The
PFAS by LCMSMS Compliant with Table B-15 of Q7SM 5.1 or Latest Version or with an acceptable
variation method should be used. Grab samples are required to avoid cross -contamination and ensure
Consistency.
EFFLUENT CHARACTERISTICS
Parmneter Code
LUUHS
Montl►lc Average I Daily Maximum
Pedhiorotetradecaaoic acid PFfeA
51631
Monitor & Repon
Pe fluorotridecanoic acid FTriA
51630
Monitor & Rrport
is acid FDDA
51629
Monitor & Report
Perfluorormdecanoic acid FUnA
51628
Monitor 8t Repml
Pertluorodecanoic acid FDA
51627
Monitor &
Perfluoronoaaaoic acid A
51626
Monitor & Report
Perfluarooctanoic acid FC?A
51521
Monitor 8t Report
F*flU0f011W2n0iC acid aDkA
5162.5
Monitor & Repon
Perfluorohexanoic acid
51624
Monitor & Report
Perfluoro tanoic acid FPeA
51623
Monitor &
Perfluorobutanoic acid
51522
Monitor , Re
Pesfluorodecanesulfonic acid S
Monitor &
c acid
Monitor & Reporl
Peril acid FOS)
Monitor & Repoit
Perlluorol tznesulfonicacid S
Monitor& Report
Perfluorohexanesrrlfonic acid
Monitor dt Repoli
Periluora ntanesulfonicacid S
Monitor& Report
Prafluorobutanesulfonic acid (PFBS)
Monitor dt Repon
PerIIuorooctaaesulfonamide OSA)
51525
Monitor & Reporn
2-QN4thy do)
acetic acid .-EtFOSAA
51643
Monitor & Report
2-(N-methylpelfl►► cr do)
acetic acid i' McFOSAA
51644
Monitor & Report
2,3,3,3-Tetrafluoro2 (1,1,2,2,3,3,3-
heptafluompropoxy}propanoic acid)
(HFPO-DA I PFPrOPrA 1
Monitor & Report
nge is of 1J
Page 32 of 81

Permit NC0057533
Ptdhwfo-2 meftxyam-tic acid(PFM
OAA
Monitor d Report
6:2 Fhu rotelamer suMmic acid 6:2 FTS
Monitor & Report
Nafion Bygoduct 2
Monitor & Report
Perfluor 35.7.9-tetraoxadecanoic acid
Monitor & Revon
Prr#iuor 3,5,7-trioxaoctauoic acid
Monitor dt REpon
Perfluo 3,5�lioxahexanoic acid
Monitor 8t Rrport
A. (9) DISPOSAL OF SPENT' MEMBRANE CLEANING SOLUTIONS
Spent membrane cleaning solutions shall be treated and mixed with the membrane reject concentrate at a
We ,which ICU not affect the aquatic toxicity of the effluent in the receiving waters. When use of
detergea;s is used with the membrane cleaning solutions, spent membrane cleaning solutions shall be
treated and off -site, and discharge of the solutions to surface waters is not .authorized under this
peolit.
A. (10) CHRONIC TOMCITY PASS/FAIL MONITORING (QUARTERLY)
OUTFALL 001
[15A NCAC 02B .0500 et seq]
The permittee shall conduct quartea chronic toxicity tests using test procedures outlined in the -North
Carolina Cwiodaphmia Chronic Effluent Bioassay Procedure," (Revised December 2010, or subsequent
versions).
The effluent concentration defined as treatment two in the procedure document is 90 %. The testing
shall be performed as a Ceriodaphnia dubia 7-day pass/fail test. The tests will beperfomied during the
months of February, May, August and Nor ember. These months signify the first month of each
three-month toxicity testing quarter assigned to the facility. Effluent sampling for this testing rust be
obtained during representative effluent discharge and shall be performed at the NPDES permitted final
effluent discharge below all btatment processes.
All toxicity testing results required as gars of this permit condition will be entered on the Effluent
)discharge Moniton g Foan (DHt 1) for the mom h in which it was performed, using the parameter code
TGn3B, Additonallt•, D R Fora AT-1 (original) is to be sent to the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
ar, results can be -seat to the email, ATFomns.ATBQncdenr.gov.
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Page 11 of 19
Page 33 of 81

Permit NC0057533
Test data shall be complete and accurate and include all supporting chemieal/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permitte a will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month4w of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Water acimmces; Section at the address cited above
Shoald the Mmittee fail to monitor during a month in which toxicity monitoring is required then
monUy moaitoriag will begin immediately. Upon submission of a valid best, this monthly test
requiremev wdl rn-en to quarterly in the months specified above.
ShoWd au%' test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include altemate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an ins -slid test and wdl require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
A (11) CHRONIC TOIhTM Y PERBffT LEWIT (QUARTERLY)
OUTFACE 001
[15A NCAC 02B .0200 et seq.]
The etilrent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to CMadaphufa duff at an effluent concentration of 90 %.
The permit holder shall perform at a mininnun, quarterly monitoring using test procedures outlined in
the "North Carolina CaHodaphnla Chronic Effluent Bioassay Procedure," (Revised December 2010, or
subsequent versions) or "North Carolina Phase H Chroruic Whole Effluent Toxicity Test Procedure"
(Revised December 2010, or subsequent versions). The tests will be performed during the months of
February, May, August, and Noremnber. These month signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent disclarg+e
below all treat processes.
If the tesrt pr. oc ednr+e perfcar wd ,As the fin# test of a ny sterol le quarter a*-5a lts in ,a ffai lw-e or C' -
below tke lmr xWt 11 nilt, then uo igt4ol"eactutra#iou testing shall the lreuformkl at µ+ nAra a , iu
VAc1u of ftibe MO f,990WI g rrrOn#lms .as it r>iloecl in "Weirth Car'd)Uaa Please H (.t 4-mu a Aftole
Et9fllucmt ywrkity Test lorocedm*" {l!UnivA-ilecember 2014), a s��aim s�sreaut cer�ouas).
All tow"cil y te.-stirug results roTtived z part of ttmis lowait cxmdifion wAl be c0exed .(w Or Efatkmt
T3isi k►a r i[ fwittxri; T, F rare (AIR -I) for the mozute; iu which fts is wm perfoutied, wwg ft a pa mini
Page 12 of 19
Page 34 of 81

Permit NCO057533
code TGP3B for the pass/fail results and TBP3B for the Chronic Value. Additionally DWR Foms AT-
3 (original) is to be sent to the following address:
North Carolina Division of Water Resources
Water Sciences SectionlAquiatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Or, results uz be se::: 'o tk email, ATFo3msATBOnodenr..
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentrationhesponse data, and be certified by laboratory supervisor and ORC or approved designate
signature- Total residual chlorin of the affluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of Sow from the facility during a month in which toxicity monitoring is
required, the permitter will Mete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the mouth/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Water Sciences Section at the address cited above.
Should the permittee fail to monitor daring a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three-month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third monde.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimumu control organism reproduction, and appropriate enmronmentai controls,
shall constitute an inmmlid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
A. (12) CHRONIC TOXICITY PERi1BT LMH (QUARTERLY)
OUTFALL 002
[15A NCAC 02B .0200 et seq.]
The a:flku�uit :disslit+rge sti,aYl ,ut ntc) tirrxr: ershibit sikrszxcrm$ilr: itilii�tliti� •nf rn-odacstura sr- itic~.axut
rurm uhty to CModayiirinM ,Avbia rat timt of 33.3 %.
The 1rxaxut b:>11�x slmalli lrradtTrau at a mraiatirtux+xa, xrua arutem 1 r M0t1it0rarug ru. tit [Ii1)Cmum txrtlirsa tl i u
the `NMth'(',ainlirma CV70 (1PJJMa t;'&Mlic Efflux rt Bjeassay P ux turv," (I3r~visseci D",n cr 2010, or
Page 13 of 19
Page 35 of 81

Pavia t 000575:3:3
sulgttaxrt vua ns) aa- "1e7rAb t arolfcA 1'h se.11 Chronic' ok a;f nod To icity Test Proatd"e"
(Ravi l)eocraibea• 2ill0, ur sub"u t •vea siaaaas). The tests wWl '� party during the months of
February, Dfay, August, and Not ember. Th+se iumths mgaakfy tte font wyndi ofiewh dmx- aalmob
taxt(ity tmt g alaartei auWxwd to the fatdlity. F, ,ueurt saw1mg for t tis testing ai7tlait'be obtained dtn Mg
repro dative a fflW at dischm•ge a ad sfiAtt be lister at the ioif►I9FS jymmitted finA tffimd dkisil-ar :
belw all treab=tt puoa:es.ms.
If the test pr'oa•edlur a performed as the fnr:st test of as y sin a grrar•ter results ha a fail uiv or d(;1 V
taeknr the permit >fimit, tlaen mu lt+.�ale-,ennctiattradon te:sti" sl ;ffl lie pedsarnied at a ndwimum, in
eaclr aafthe two folla)wing maaraths as idewribed iva Waamth Cava rwat Pha se llll Cbronie:Whole
Ffuuent To3ddty Teat Frt edutre" (Etrsisaed DeserartM. 2410, or Subsequent verse ons).
.ill tmu ity testing aestaltts required .is W of tlds pewit condition twill be catered aara than Effluent
Mw1rge Matuaitoriaig 1'"/ncsal (MR 1) fir the raaaaiW iri ellaurh VMts W:r,(' : perfoaMtl, UMMg MW IMCAWdff
codt 'lGP3B for the;pasr,/faid rmdtc wd'173B fox the (;tutmw ' :ikie..Paa'tt4Awyeally, DWR Form AT-
3 (aiginal) k to bar z rm ut to the t'olla wiM, ads:
Month Carolina Division of Water Resources
Water Sciences Sechon/Aquatic Toxicology Branch
1621 A+1ail Service Center
Raleigh, NC 27699-1621
Or, results can be sent to tine email;, FormsATB(ftcdenr,¢ov.
Completed Aquatic Toxicity Test Forties shall tx filed with theWater Sciences Section no later than 30
mays after the end of the reporting period for Much dke report is made
Test data shall be complete, accurate, include all supporting cheaucal physical meamirements and all
comeentratioa'response data, auad bt c&tifled by labonfar sup�Msor and ORC of apr. a; edd decimate
signartire. 'Loyal residual clilotir,.e of that c,'LMUAnt toxicity sarple must be measured and rep*rted if
chlorine is employer) for disin&ctionofthewaste szean-.
Should theft be no discharge of flow from the faciLry during a =sith in which toxicity monitoring is
nonce) ed, the pen nittee will complete the iaforaaation located at the top of the aquatic toxicity (AT) test
form indicating the facility name, pein.tt number, pipe number, amity, and the monthlyear of the report
with the natation Of` -NO F'lott' ' in the c omnnesit area of the farm.. Ile report shall be submitted) to the
V'ates SCitnces Section at the addMS cited above.
Shoald the permute- fail to monitor duriagg a month in which toxicity monitoring is required, monitoring
will be required during the follo ixg month. Assesssmentoftoxicitycompliance isbasedontle toxicity
test ng quarter; which is the three-month time iz enwal that begins on the first day of tie month in which
toxici?N• iestizq is required by this permit and continues until the final day ofthe Baird month
Should any test data front this monitoring requireruew or tests prrfonned by the North Carolina Division
orv'ater Resources indicate poleatial 'impacts to th,- receiviag stream, ihispermitmaybere and
modified to inchi k alternate monitoring requirements or limits.
Page 14 of 19
Page 36 of 81

Permit NC0057533
NOTE: Failure to achieve test conditions as specified in the cited document, such as mimmum control
MganisM survival, minimum control organism reproduction, and appropriate envimnm ental controls,
shall constitute an insalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
A. (13) ELECTRONIC REPORTING - DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This special condition supplements or supersedes the following sections 'within part H of this
permit (Standard Condition forNPDES Permits):
• Section B.(11) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5-) Monitoring Reports
1. Rep2ffMg ftuirements (Super sedeps SKdon D. (2) and Section E L51 ta31
The pernbitie^e shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge'Slomtoring Report (eDMR) interact application.
Momtm q results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR The eDMR system allows permitted facilities to enter
monitoring ,data and submit DMRs electronically using the intem et The eDMR system maybe
accessed at: htbs://dea.nc.gov/about/divisionsEarater resourocsfedmr.
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an am where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (luIIt 1,1.1, 2, 3) of
alternative foams approved by the Director. Duplicate signed copies shall be submitted to the
following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
See `Tiow to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility, on the last day of the month following the
commenceinent of discharge.
POP 15 of 19
Page 37 of 81

Permit NC O057533
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• Sewer Oveilow/Bypass Event ,
• Pretreatment Program Annual „ and
• Clean Water Act (CWA) Section 316(b) Amnual Reports..
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122A1(lx9), the permittee must identify the initial recipient at the time
of each electronic submission. The permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)).
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information an EPA's NPDES
Electronic Reporting Rule is found at: htlpsJ/www.federalre' ov/documents/2015/10/22/2015-
24954/national-nolhrtant-&scharrre-elimination-system-wdes-electronic-neoorti Z-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements„ section above_
3. Hon, to Reg nest a Wainer from Electronic Rep oruinQ
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a rAmuttee must first submit an electronic reporting waiver request to
the Division. Requests for teruporW electronic reporting waivers must be submitted in writing to
the Division for written app mml at least sixty (60) days prior to the date the facility would be
required under this permit to begin submitting monitoring data and reports. The duration of a
temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data
and reports shall be submitted alectionic ally to the Division unless the permittee re -applies for and is
granted a new temporary electr oink reporting waiver by the Division. Approved electronic reporting
waivers are not transfeerablc. Only permittees with an approved reporting waiver request may
submit monitoring data and feports on paper to the Division for the period that the approved
departing waiver request is effective.
Information on eDMR and tife application for a temporary electronic reporting waiver are, found on
the following web page
http://deg_nc.govlabou t/divisions/water-resrnucesledmr
Page 16 of 19
Page 38 of 81

Permit NC0057533
4. -Siguawy R&jvk*&mjt% 113mipplewents S"-om B. J11.) M mud B. au
AD cl)MM; admWffed to tbe PM -wit isg*fig mAhmity AmE be,sigued by a pemm ad lxd in Part H,
lieu B. (I I.)(a) or by a duty wtbmherA xrpwiatta vr of dut t pet wnw da-ailvd -LU PM1 11,
.%.*on B. (I 1.)(b). A data, and xwt a Imsition, xww be iWegWA 6gautorym0writy for tD'MR
,(qxxting pwPOSM, -
Furl eDIM StftuLSIADW, ft1VISM Mping =4 -W1w1iU* tine DMR naW iftAin an eDMR me(
wwwd mid logiu cardtntiati towxess tbL eDMR.sr4 twi. Fof vx= WbTmdom an Ntrth
Cmoliw's tDA'v.% iysteaa, wipstwing for eDWR and itbijimg 2a rDNR ttw awamd, 1&wx visit
die follomag, wth page:
http://deQ.nc.00v/about/divisions
Certification_ Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STAMERIM OF CERTIRCAT10N
WULBEACCEPTED:
7 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of thepenon or
persons who manage the sy
stem, or those persons dhwfly responsible for gathering the Information,
the Information submitted Is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are st"cantpenalties for submitting false Information, including the
possibility ofj7n#s and imprisonment for Avowing violations. "
5. Records Retention (Supplements Section D. 6.
The permittee shall retain records of 211 Discharge Monitoring Report, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41).
Pap 17 of 19
Page 39 of 81

Permit NCO057533
ATTACSMFM I — OUTFALL 002
No later than 2 years after the commencement ofdischargre from the proposed facility through outfall
002, monitoring for the following parameters shall be performed and reported. All laboratory data sleets
will be submitted to the Division. Testing shall be performed at the same time as parameters required by
NPDES application Form 2C. All samples shall be grab samples and must be collected from a typical
discharge event.
Pale 18 of 19
Page 40 of 81

Permit NC 0057533
Total HAAS
Monitor & Report
Total Organic C. ban OC
Monitor & Report
TricWaroacetic acid
Monitor & RepoTt
Try 1.34chlaro-2 1 hate
Monitor & Rrpori
Tri 2tarbo cthvl)plhospbine hvdrochloride
Monitor & Report
Page 19 of 19
Page 41 of 81

Northwest WTP
NPOES Permit NCOOS7533
Receiving Stream: 001: Hood Creek County: Brunswick
002: Cape Fear River Stream Class: 001: C; Sw
Stream Segment: 001:18-66 002: C; Sw, PNA
002: 18-(63) Sub -Basin p: 034)6-17
River Basin: Cape Fear HUC:0303000504
N
A
SCALE
1:30,000
i OWk
11lL*
Facility Localmn
scot not AM"
�A
Existing Outfall OD
Page 42 of 81

FACT SHEET FOR PER -NUT REXEII LS
Basic Information for Permit Renewals
Permit Writer / Date
Brianna Yaame 10/30/19
Permit Number
NCO057533
Facility Name /Facilm Class
Northwest WTPI PC -I
Basin Name f Sub4min number
Outfall 001: Cape Fear / 03-06-17
Outfall 002: Cape Fear / 03-06-17
Receiving Stream i ii X
Outfa11001: Hood Creel 10303000504
Ouu1f ffl 002: Cape Fear River / 0303000504
Stream Clasdficat:on;"Stream Segment
Outfall 001: C; Sw / Indm- 18-66
OutFall 002: Q Sw. PNA I Index: 1 63
Does permit need Daily 3v wdnmm M%
N/A
Limits?
Does pei=i need 7RC limitsllanguagO
Outfall 001: Already present
OWM 002: Added
Does permit have toxicity testing? 1WC ('/o) if
Outfall 001: Yes; IWC = 90%
so
Oatfa11002, Yes; IWC - 33.3% (based on
dilution model
Does thane Conditions?
Yes see Section 11 below
Does permit have instream monitoring?
Outfa11001: Yes - hardness
Outfall 002: Yes — DO, salinity, conductivity,
H hardness
Is the stream impaired (on 303(d) list)?
Outfall 001: No
Outfall 002: No
An,. obvious cc fiance concerns?
Yes see Section 4 below
Any pemut mods since last pamit?
Yes; proposed expansion for entire facility
and new outfall for ne a RO treatment units
New expiration date
3/31/2023
Comments on Draft Permit?
Section 1. Existing Facility and Discharte (Outfall 001):
The Northwest (Hood Creek) WTP currently utilizes conventional treatment technology,
with a potable design of 24 MGD. Outfall 001 has a compliance schedule for total copper
znd total fluoride, and permit reopens conditions are present for WET testing and TMDL
implemeatation.
Potable water and wastewater treatment currently consists of:
• Influent disinfection [chlorination]
• Two (2)12 MGD up -flow clarifiers [disinfected raw water]
• Two (2) banks of fair (4) filters each [sandfanthracite/gravvel filter]
• One (1) 4 MGD clear well
• One (1) 2 MGD surge lagoon
• One (1) 0.180 MGD sludge thickener
• Dechlorination
• Chemical usage consists of:
Page 1 of 22
Page 43 of 81

a Chlorine dioxide
0 501/6 sodium hydroxide
o Polyaluminum chloride
o Sodium silica fluoride
o Bleach -type solutions
Cationic polymer solutions
Calcium thiophosphate
Powered activated carbon
Orthophosphate
Section 2. Proposed FacilitV and Discharge i Ontfalls 001 and 0021.
The permittee has requested a modification of the permit for an existing conventional
WTP located in Leland in Brunswick County that wishes to expand treatment capacity as
well as mchrde RO treatment of drinking water and add a second outfall to discharge the
RO concentrate. The design potable flowrate of the whole WfP will be 45 MGD (at
build -out) and with an expected wastewater filter backwash discharge from the
conventional treatment into Hood Creek of 3.9 MGD (at build -out) and an expected RO
wastewater discharge of 03 MGD (minimum) to 5.0 MGD (maximum designed) into the
Cape Fear River. The facility will gm.erate discharge continuously of the reject water
concentrate from the RO treatment p. oeess. The source water will be surface water drawn
from the Cape Fear River. Discharge from the RO treatment through Outfall 002 is
expected to begin October 1, 2020.
Potable water and wastewater treatment at 45 MGD build -nut will consist of.
• Two (2) 24 MGD rapid min, basins
• Four (4) high rate clarifier basins
o Clarifiers modified for air scour and pumped backwash to provide solids
and particulate removal
• Sixteen (16) dual media (sand and anthracite) granular media filters
o Filters modified for air scour and pumped backwash to provide solids and
particulate removal
• Two (2) clearwells
• One (1) 4 MGD backwash equalization and decant basin
• Two (2) 80-ft diameter sludge thickeners
• Dechlorination
• Eight (8) 5.15 MGD reverse osmosis skids
• Surface water discharge (Outfall 001)
• Submerged streambank discharge (Outfall 002)
• Conventional treatment chemical usage will consist of
_Chlorine dioxide (p"xidant and primary disinfectant)
Chlorine (pre -oxidant)
Powdered activated carbon (PAC) for taste and odor control
Polyaluminum chloride (PAX) as a coagulant
Caustic soda for pH adjustment
Coagulant aid polymer
Page 2 of 22
Page 44 of 81

Sodium &wosilicate for fluoridation
Orthophosphate for corrosion inhibition
Chloramiues (chlorine plus ammonia) for distribution system residual
Calcium thiosulfate
Reverse osmosis treatment chemical usage will consist of:
Sodium bisulfite
o Antiscalant
o Carbon dioxide
o Emulsified lime
o Alkalinee or acid solution (for membrane cleaning) - Spent cleaning
solution will be neutralized ahead of disposal, and typically disposal will
include blending the neutralized solution with concentrate and
discharging. Occasionally, detergents may be used as part of the cleaning.
When they are used, the neutralized solution may be hauled separately to
the Northeast W WTP.
No treatment of the waste stream is planned. Discharge will be via a diffuser into the
Cape Fear River.
Section 3. Cam- Fear Basinnide Water Ou alin• Plan:
The 2005 Cape Fear River Basinwide Water Quality Plan was reviewed. The Cape Fear
River at the proposed discharge location [Stream Segment: 18-(63)b] is not subject to a
TMDL according to the DWR Modeling and Assessment Branch website, but the basin
plan states the Division is developing a TMDL to address the low DO. The basin plan
indicates the Cape Fear River at AU number 18-(63)b (from Bryant Mill Creek to
Toomers Creek; the proposed discharge location is in this segment of the stream) is not
rated for aquatic life with dissolved oxygen < 4 mg/L in 8.8% of samples collected at site
BA589, 13.8% of samples collected at site BA639, and l i % of samples collected at site
BA640. The plan states the classification of C, Sw indicates natural swamp
characteristic,.
More recent Cape Fear Basin planning data was reviewed as well. The 2018 Integrated
Review (IR) Summary Sheets AMSC Coalition with agency contains summary
information from ambient monitoring system stations from 2012 through 2016 as part of
a Basinwide Assessment Report. Three stations that fall into the stream segment 18-(63)b
(where the proposed discharge location is) were reviewed. During this time, 6.1% of
samples did not meet the evaluation level for DO of c 4 mg/L for monitoring station
B84650000 (formerly BA589), 8.2% did not for monitoring station B9020000 (formerly
BA639), and 9.8-1. did not for monitoring station B9030000 (formerly B640).
Per DWR staff there are currently no nutrient concerns for this part of the Cape Fear
River Basin concerning WTPs. Quarterly monitoring for Total Nitrogen and Total
Phosphors: has bm izchuded for outfall 002 per the 2009 membrane WTP strategy.
Downstream of proposed outfall 002. there are impairments for dissolved oxygen and pH.
These impairnnneW is are approximately 12-13 riverine miles downstream froau the
Page 3 of 22
Page 45 of 81

proposed discharge location and occur in a different surface water classification and
stream segments (class SC waters in stream segments 18-71 of the Cape Fear River and
18-77 of the Brunswick Rivet).
Section 4. Conwhance Elistory (October 2014 to October 2019):
Outfall 001
The compliance history of the existing outfall 001 is included below.
* Failed 8 of the last 12 toxicity tests (failed 3 of the last 4)
A 1 NOV for aluminum daily maximum exceedance
• 3 NOVs for TRC dad%• maximum exceedances
To address ongoing toxicity issues at {3utfah 001, the told itv test ;r-ill cbacge f om a
monitor only test to a Pass/Fail Limited tea: 1 vex fief discha: €e. from outall M2 is set
to commence, with a compliance schedule in the intenm
Outfall 002
There is no compliance history to review for the new proposed discharge Outfa11002.
As part of the gemtit application process for WTPs, applicants must complete toxicity
testing and demonstrate that the effluent will pass the appropriate toxicity tests at the
dilMon that is expected at the proposed receiving stream.
Brunswick County ran toxicit}` tests on a series of samples collected under different pilot
testing scenarios (85% efficiency and 92% efficiency; chlorine dioxide or free chlorine as
preoxidant) for the proposed OittM 002 to the Cape Fear River. Tests were performed
using EPA test method EPA-812-M2-013 except for two 48-hour acute tests, which
were perforated using EPA ter method EPA-812-R-02-012. All tests used CeHodaphnia
dubia. The approved Instream Waste Concentration (1WC) based on the dilution model is
33.3%.
Of the 14 toxicity tests conducted for which results were submitted, 2 tests passed at the
approved IWC of 33.3% (the remaining 12 tests either did not pass at IWC = 33.3% or
the results were inconclusive). The samples collected on 7111/2018 and 1/14/2019 had
chronic values > 9011a and therefore con<idmd passing. The sample collected on
7/1112018 was a grab sample that was collected when no preoxidant was in use and the
pilot plant was operating at 85% efficiency. The sample collected on 1/14/2019 was a 24-
hour composite sample that was collected when chlorine was used as a preoxidant and the
pilot plant was operating at 92% efficiency. All tests that used chlorine dioxide as a
preoxidant did not pass at the approved MIC of 33.3%.
Bawd on thr..-w xnstrlts, it is the Division's ftcoowy-m&-itiou that chlorine dioxide wt lie
eves( in the tie atxt t process as Toxicity tit restdts wdiralted the eftltwnt would not pass
tomctty tests `w brit chknine. dioxide is in uses T.he toxicity o fits ,aced associated resales .are
provided in a revised ps^raasit af4) ication itreived by dw Division w March 12, 2019.
Page 4 of 22
Page 46 of 81

Quarterly toxicity testing will be required for Outfall 002 per the 2009 '%rIP strategy for
mecibrane'WlPs. The toxicity test will be a chronic Pass/Fad limited test using
Ceriodaphnia dubia with an IWC of 33.3% based on the dilution model.
Section 5. NEPATONSI Determination for Outfall 002:
The proposed expansion and new outfall construction were subject to review by
governmental agencies under the National Environmental Policy Act (NEPA) as the EPA
WIHA program is the hiding source. In a letter dated May 21, 2019, EPA issued a
determination of no effect for nineteen species and may affect but is not likely to
adversely affect five. species. EPA requested USFWS and NMF to concur. In a letter with
a stamp date of June 19, 2019, the National Oceanic and Atmospheric Administration
(NOAA) National Marine Fisheries Service (NMFS) determined that the proposed
project will not likely adversely affect the NMFS Endangered Species Act (ESA) listed
Species anddlor designated critical habitat.
Section. 0. AnrtdK adattion Reiti?n ' E.A.-k Summa
Outfa.l 001
Per NC Anadegradation Policy (15A NCAC 02B .0201), each applicant for an NPDES
permit expansion must document an effort to consider non -discharge alternatives
pursuant to 15A NCAC 02H _0105(c)(2). DWR staff requested an Engineering
Alternatives Analysis (EAA) be completed for Outfall 001 as the facility is expandlug
and 3.9 MGD is the expected wastewater volume at the full 45 MGD build -out.
Conner fin to an existing W WTP: Brunswick County stated that discharging the waste
st mai from the facility to an existing sewer is not feasible as no municipal WViTTPs
ss ithm z 10-mi.le radius provide sewer service in the area, and the Northeast Brunswick
1�7% `F that could expand does not have the land available to do so.
Land z-olacation: Brunswick County states the required acreage, capital costs, and
o,px are r-g costs to implement a slow rate treatment of the treated process waste renders
:has alternative infeasible, and the soils present are not suitable for wastewater disposal
via ac.;- rare treatment or rapid infiltration.
IVP stnvmer reuse: Brunswick County stated there is a lack of industrial, residential or
cexW.annefcial wastewater reuse customers in the area and the required acreage and capital
and operating costs to implement a wastewater reuse irrigation system with the treated
process -waste renders this alternative infeasible.
IMrcct disc:h-wo to -,surface a svaf : BrsaAstvrrk co arty stated the rtnfrastxWture fix Surface
wattsr di cliarge is ckurently in place with W) piling xruA ficatiaus rrx*a°tl'tx°twerxs the
facility 4 the osrtftll location. and the cxvxmt isnfa.m uctom is sr�it:ir rst to �clischarge else
prulx).w,d incoas,e iu flows.
Page 5 of»
Page 47 of 81

Cost evatuation: Brwmwick Cotinty trahiated Aw ecM=r feasiNlity of several
altewtives. Comm6W toan existing VLrWrP -was based on =ual sewer use ftesalone
,,
(1yresent value costanalysis [PVCA] of $15.3 iniffitni over 20 yrws)—and with additi(md
cVit.d costs potentially m5cessmy tv infi-Astrumire to discharge to umby WWI?s. this
alternative tag as detemwd to be cost prolubitive. Lzid ;Mhc2tion and wastewater reuse.
were " con -sidereal feasible as 650,670;tcrei wotdd be, mItii;red ($26 million to $2ti.8
xrWhou for Laud Inueba-se alow) plus capital costs aad O&M costs (I'V(',A of $ 55.6
million to $56.7 naioa over 20 years), making, this alteixtative cost piobibifive.
INScliArge to surface waters at the existing otittall location into Hood Crt&- is estimated
to have no c:4pitzl costs as infi2structure is ajaady in place (FVCA of $12,625,658 over
20 year:;), dmming discharge to staface waters as the only feasible option.
Outfit 002.
Per'14C Antidegridation Policy (I M NC.AC 02B .020 1), each kppjicant fhr an NPDES
pen nit eqmsion wikst doaamtt im effort to considel Han-dischafge altematives
pun- ttant to 15A it CAC 02H .0 105 (c X2). This altenuitiws evaluation was subjWfted as
part of the EAA fair the pemit rnodill(ratim.. IYWR staff mviewed both the flow
imfification is well as the alternatives analysis. DWR staff concw- with the pfqircted
flow ikv& based on a 40-yea plan. Bnaiswick County serves the Towns of Bald Head,
Caswell Beach.. Holden Beach, Leland, Navassa, Oak Island, Ocean Isle Beach, Shallotte,
and Southport, as well as Bnmswick Regional (H2GO), Little River Water Company
(emergency use only), Northwest, 15 industrial customers, and individual retail
customers in imiracorporated towns. The County experienced an average 3% annual
growth fate over the past seven years, with a near doubling of daily demand occurring
between winter and peak summer conditions.
Brunswick County completed an Engineering Alternatives Analysis (EAA) as part of
their pnmt application/modification request. Several alternatives were evaluated,
including connecting to an existing wastewater treatment plant (WWTP), land
application, wastewater reuse, and direct discharge to surface waters. These alternatives
are discussed below.
Connecting to an existing WWT?: Bnmmck County evaluated connecting to an existing
VAM, but stated this was not a feasible option as none of the municipal WWTPs within
a 10-mile radius provide sewer service in the area of the WTP nor do they have the
permitted capacity to accept the volume of the proposed waste streara. In additional
information provided, the County also stated the nature of the waste stream would not be
desirable for acceptance at VAVI?s. Letters from these WWTPs denying acceptance of
the waste stream were provided to DWR_
Land agghfication: Brunswick County states that available Lind is being used for
residential devTlopments and that the WTP site is limited to 200 acres, and that
c.*-ulatiow based on low rate wastewater laudq4)hcatiou indicate an)raxiAlately 1,200
actes woald be xrqtaiird to apply 5 MGD. Sails Vx':eSCYAt at diesite arenot SUiAIC fie
f
wastew-ater dii1x)sal via slow rate frealumut or jayid irffiltration- Tlw ('01Wy states that
dw, requirett ac-mage. capital, and operating costs, to ioVituix.4ut a slow rate trentimmt
xuakes this IQ MeAsible altkTuative.,
Page 6 of 22
Page 48 of 81

Wastewater reuse: Brunswick County states they operate over 25 miles of reclaimed
water force mains that supply reclaimed water for irrigation to i 1 golf courses and 1,040
acres of tree and turf farms. However, they state this option is not feasible as there is a
lack of industrial, residential, or commercial wastewater reuse customers in the area
adjacent to the facility, and the infrastructure required to convey reclaimed water to
customers is not currently in place.
Direct discharge to surface waters: Brunswick County evaluated the proposed discharge
location into the Cape Fear River. The County believes sufficient dilution will be
available at the proposed discharge location to handle the waste stream and is the
recommended discharge option. The County states alternate locations were considered
but the length of the pipeline was considerably longer for each option
Additional alternatives evaluated: Brunswick County stated that there was no possible
combination of disposal alternatives. The County stated they reviewed options for all
waste streams generated by the WTP and will continue to Wlore options in the future.
Brunswick County also evaluated deep well injection and determined this was prohibited
by NCGS 143-214.2(b), therefore not a viable alternative for the RO concentrate.
Cost evaluation: Brunswick County evaluated the economic feasibility of several
alternatives. Connecting to an existing W WTP was not considered feasible based on
annual sewer use fees alone (521.7 million over 20 years). With additional capital costs
potentially necessary for infrastructure to discharge to nearby W WTPs, this alternative
was determined to be cost prohibitive. Land application and wastewater reuse were not
considered feasible as 1,200 acres would be required for reuse irrigation ($50 million for
and purchase alone) pus capital costs and O&M costs. In addition, there is a lack of
;s aste;� ater reuse customers in the adjacent area and there is no infrastructure currently in
place to convey reclaimed water to customers. Therefore, discharge to surface waters was
deemed the only feasible option. Discharge to surface water at the proposed outfall
. ocarion in the Cape Fear River is estimated to have a present value cost analysis (PVCA)
of S 121625,658.
Section 7. Summan- of Dilution Model Submitted for Outfall 002:
Per the dilution memo approval from DWR staff dated 8/12/2019:
CDM Smith has submitted a CORMIX model on behalf of Brunswick County to evaluate
wastewater dilution for a proposed reverse osmosis WTP discharging to the Cape Fear
River (classified: C, Swamp, PNA) approximately three miles below the confluence with
Hood Creel;. The WTP will have a requested maximum 5.0 MGD RO concentrate
discharge
31w +C ORMIX rnobel uvas 5ulm fitted 'Using the system's Uwstz-,ady A aabieatt C. Mrats
f meft(w due to tidal mflaew.m our the C.W. Fear fi:iver at this location. Flow values wr=
dbtaiar from I7SGS; gage 02105769 at Lock and Dam #1. field awl labaratmy saaupalr
were taken to s;ttegorae the ambient canditim s and calibrate the nxAd parantern". A
tWhyuht tic st uveyr shoWed ttat: Inert ac a of %uid watvm in the nw. r lxrtta>;an and •tvns used
Page 7 of ..
Page 49 of 81

in determining discharge port depth. Multiple model runs were pe:famsed to characterize
discharge characteristics at various river flows and tidal effects. A Sack -bill single port
diffuser was chosen to optimize discharge dilution over seasonal lu Fh and low flows
The pollutants of concern are dichloroacetic acid with an estimated coacen.tration of 35
µg/L. Target dilution needed to meet the dichloroacetic acid limit and establish a mixing
zone is 3:1. The CORMIX model results show that the standard is :vet a little snore than
meters downstream within the near -field. The Division approves the fo Ucwiag
specifications:
Target Dilution - 3:1
IWC% - 33.36%
Diffuser - single port duck -bill difiu_cr, approximately 12 feet deep and . feet from the
bank, oriented perpendicular to flow.
Regulatory Mixing Zone -10 feet radiss around the diffuser
Total dichloroacetic acid limit - 37.5 µg/L
Additional mixing zone considerations - Dilution of up to 10:1 would result in a mixing
zone f 20 feet longitud=llu from It outfall and 30 feet laterally.
No acute regulatorg misnng zone i= authorized by thbt model and evaluation
Section 8. RPA for Conventional Ti eatmeaC iCutf ll oo1- Dever Creek);
Maximum monthly average discharge between September 2016 and August 2019 was
approximately l .487 MGD. Parameter data reviewed between February 2015 and August
2019. Outvzll W1 euchargei; to a stream with a 7Q10s of0.07 cfs.
• Copges - U shown; monthly monitoring applied with limits
• Fluoride - m RP shown, but predicted max > 50•/• of allow -able Cw; quarterly
monito:in a maintained
Zinc -no RP shown, predicted max < 500/o of allowable Cw; monitoring will be
removed as facility indicated zinc orthophosphate does not have the potential to
be discharged (per the previous renewal application)
• Ahmsiauru - ro RP A is nec essay}' per the 2012 V Tic guidance; monitoring
maintained at quxlesly as aiim: has ibe potential to be discharged (per the
previous renewal application)
Section 9. RFA for RO Trearmc it (OutfiU (102 - Cape Fear River):
Monitoring data provided with the permit application was reviewed. Pilot study effluent
data was provided for 1 sample collected on October 16, 2018. Additional data was
provided for samples collected on February 26, 2018, March 26. 2018, and May 24, 2013
at 85% efficiency and 92% efficiency.
Page 8 of 22
Page 50 of 81

A na-dinuin dLw!amgr of 5.0 241GD,was used to cMculate linjits, as this is the niaximuin
&qiped discLarge. A dilationof 3:1 (IWC = 33.30%) was wisM bxsed on the ij4xoved
diluthm uxxtel_ As ftw disckugr is to PN.A w-Attys, tW HQW rq)hou was Selec-ted.
* Axsenic —No RP rprrActed nixt 501/a of allowible Cw; umtKy ixwniitoring
2pplied -xs no data rxists Ibr the proposed outW and arioji<- is a piruUtter of
rancerti pa mnxilumAr WTP antegy
* CUoAdes -- RP for billited & tlwt (n --,'g samples); no daw es fists for the proposed
Dutf3l! UW d11011de A a p2rameter of con m-u pa• mmilraw WTP stvatrgy;
woirtWy monAmmg with lumts applied
* CopW­No RP, predicted max W/o of allowa0k Cw; nionddywoni for ing
,
applied as no data exists for the piqlw%od outfall and cojYper is i parmwei of
cawein pry meuxbmw WTP strategy
* F11%oride — RP for jia3iw 4-Atilset saWles); no data inim for the IwoIxned
oudall mW f luoride is a pix2mettT of conotiv per inwitnuar WTP strategy;
jawo"y wmitmixig wAlitnits Whed
* Lod — RP for linifted dataset (a< 8 %upples) but uone of ttie ecru -detects Im
gmater thau CNV; uo data exist--,, for tile proposed OL"; quarterly
nu tutoring apphed
* Molybdenum — No RP, predicted max < 50% of allowable Cw; monitoring not
required as not a parameter of concern per membrane WTP strategy
* Zinc — No RP, predicted max < 50*/o of allowable Cw, monthly monitoring
applied as no data exists for the proposed outfall and zinc is a parameter of
concert per membrane WTP strategy
Ammonia and Total Residual Chlorine Limitations:
Limitations fo: mi=ia are based on protection of aquatic life utilizing an ammonia
chronic cr ttrion of 1.0 mg/l (summer) and 1.8 mg/l (winter). Acute ammonia limits are
derived from chronic criteria., utilizing a multiplication factor of 3 for Municipals and of
5 for Non -Municipals.
The updated outfall design and dilution modeling (letter date of February 14, 2019) for
outfall 002 showed the following ammonia nitrogen concentrations measured during the
pilot study:
• April 2018 (85% efficiency): < 0.2 mg/L
• April 2018 (92/o efficiency): < 0.4 mg/L
• October 2018 (85% efficiency): < 0.2 mgIL
• October 2018 (92% efficiency): < 0.4 mg/L
• January 2019 (92% efficiency): < 0.2 mg/L
Ammonia nitrogen concentrations allowed according to the attached NH3/rRC waste
load allocation (VILLA) for the proposed discharge of 5 MGD with 7Q 10 of 15.5 cfs (3:1
dilution) are. 2.6 mg/L for summer and 5.0 mg/L for winter.
Per 15A NCAC 02B .0224, oxygen consuming wastes in high quality waters must meet
surface water quality standards of 2 mg/L for ammonia nitrogen and 6 m&I for dissolved
oxygen. Brunswick County did not provide monitoring data for dissolved oxygen but
Page 9 of 22
Page 51 of 81

concluded that ammonia levels did not demonstrate an oxygen consuming waste and
therefore would not impact dissolved oxygen levels in the river.
Limitations for Total Residual chlorine (TRC) are based on the NC water quality
standard for protection of aquatic life (17 µgiL) and capped at 28 µg/L (acute impacts).
Due to analytical issues, all TRC values reported below 50 µgtL are considered
compliant with their permit limit. Proposal TRC limits for outfall 002 are based on
standard operating procedure?action level for TRC (see attached NH31TRC WLA).
Additional parameters:
Brunswick County performed additional testing while performing their pilot study, which
DWR compared to available NC 02B standards, EPA National Recommended Water
Quality Criteria (NRWQC), and North Carolina in -stream target values for surface
waters. The samples were taken on February 26, 2018, March 26, 2018, and May 24,
2018. The pilot study was run at 85% efficiency and 92% efficiency (the efficiency at
which Brunswick County intends to run the proposed RO facility).
Parameters for which standards were available for review through an RPA are below. A
maximum discharge of 5.0 MGD was used, as this is the maximum designed discharge.
A dilution of 3:1(IWC — 33.30%) or 10:1 JWC =10%) was used. As the discharge is to
PNA waters, the HQW option was selected.
No cancer endpoint (3:1 dilution applied as 7010 required for calculations):
• 1,2,4-Trichlorobenzene — RP for limited dataset (n < 8 samples), all data points
were non detect, PQL < 1 µg/L; No monitoring required at this time as a
sufficiently sensitive test was utilized
No comer endpoint; used EPA NRWQC for fish consumption
• 2,4-D —No RP, predicted max < 50/a of allowable Cw; monitoring not required
as not a parameter of concern per membrane WTP strategy
No cancer endpoint; used NC in -stream target values for surface waters
for aquatic life and secondary recreation
• Atrazine — No RP, predicted max < 50/o of allowable Cw; monitoring not
required as not a parameter of concern per membrane WTP strategy
o No cancer endpoint; used NC in -stream target values for surface waters
for fish consumptions (human health)
a Alpha-Hexachlorocyclohexane — RP for limited dataset (n < 8 samples), all data
points were non detect, no PQL per the DWR inorganic Chemistry Branch; No
monitoring required at this time
o No cancer endpoint; used EPA NRWQC for fish consuunption
• Brrnmonuthane - RP for linsited dataset (n < 8 samples), all data points were non
detect PQL < 2 µg/L; No monitoring required at this time as a sufficiently
sensitive test was utilized
o No cancer endpoint; used NC in -stream target values for surface waters
for aquatic life and secondary recreation for methyl bromide as
bromomethane was listed as a synonym
p Chloroform - No RP, predicted .max < 50°!0 of allowable C w; monitoring not
required as not a parameter of concer per membrane WTP strategy
No cancer endpoint; used EPA NR`VQC for fish consumption
Page 10 of 22
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• Clilmpywifbs - 1!P for limited d atoset (u 8 .swuples), .all dat t 1w rots wne Burn
detect, no PQL 1x. the DWR Inorgmne C h muistxy Bx inch; No umnoring
required at tt& tiruc
o No cater nk(poiut; used EPA NRIVQC for aquatic. life
• Pexclrloratr; -• RI' for limited dabset (n 8 sa%*i); lion ldy moo iitoaiiug -%rith
limit :.4rplxti
C) No eanacert exadpoirat; used NC a t-streaaxa target valur`x tsar since waters
fair M. I caxr5 3tiom (hunwa hea(th)
• CoiUt -RP fUr limited datset (a tilt sa Wles), all data buts vme non detect,
I'QL 50 pglL; No amitoxing rtnkiiwl at tlii'; tkW ,as a Sufficiently sensitive test
avers wiiized
o No cancer eL*xrirat; ustA NC in -stream target value-s for rsaarface waters
for aquatic fife and stet xiOry rr;ctewtux
• Cobalt --No RP, predicted mrm -,. Sty% ofallowable Cw: Al data Tints were taoxn
detect, PQI, < .50 lam,; No as mutoriq xequirM at tus time as a sufficiently
,wmative test was unitized
o No C ant cx ,rsack w nt; irved NC:' in --stream target va ut , for slxrface watm
for fish c:o>usauuption (hunm a health)
Cancer endpoint (10.1 dilution applied as Q== [annual flow average] reauined for
calculations):
• Arsenic (human health) - No RP, predicted max �: 50'/0 of allowable Cw, all data
points were non detect; monthly monitoring applied as no data exists for the
proposed outfall and arsenic is a parameter of concern per membrane WTP
strategy
a 1,"oxane -No RP, predicted max < 501/6 of allowable Cw; monitoring not
required as not a parameter of contemn per membrane WTP strategy
o Cancer endpoint; used NC in -stream target values for surface waters for
fish consumption (human health)
• Dichloroacetic acid - No RP, predicted max 2: 501/6 of allowable Cw; Quarterly
monitoring applied
o Cancer endpoint; used NC in -stream target values for surface waters for
fish consumption (human health)
• Bromoform - No RP, predicted max < 50•/. of allowable Cw; monitoring not
required as not a parameter of concern per membrane WTP strategy
c BPaYed on a cancer slope; used EPA NRWQC for fish consumption
Acfyloahrile -No RP, predicted max < 501/o of allowable Cw; monitoring not
rewired as not a parameter of concern per membrane WTP strategy
o Cancer endpoint; used EPA NRWQC for fish consumption
e 1,2,3-Trichloropropane - RP for limited dataset (n < 8 samples), all data points
were non detect, PQL < 1 µglL; No monitoring required at this time as a
sufficiently- sensitive test was utilized
o Car. -es endpoint; used NC in -stream target values for surface waters for
fish con gumption (human health)
• 1,2-Dibrnmo-3-chloropropane (DBCP) - No RP, predicted max >- 50'/o of
allowable Cw, all data points were non detect, PQL < 2 µg1L; No monitoring
required at this time as a sufficiently sensitive test was utilized
Page 11 of 22
Page 53 of 81

Catac a rxcllxsirxt: nseal NC iax stux��cce►1 �;e`t ua1n tsn srtrfac:e LVi1te'. fair
f Sh c;crr s tptiOn (ltuoa A hCAlth)
• N-Nitrosodixidbyhwii_ve, (1VI)NiA) -No RP, predicted nan 50 of a.0irwable.
Cw; monitoring not required .as, not a paraw.ttr of c:onc ou per n embr%w WTP
P
xtrategy
c) Caner eitdpoitrt; used EPA NR' (X, for fish evasuaul4im
• Tetracb1ofoerhylt ne - No IMP, predicted rxaa s <'. 50,1% of allowable C.w; %uonitohUg
no requirod as not a ltsarnraaetef of cone -an per membrane WTP t-&-ategy
o +�,;anc:ex llxrint; used 0`�.I3 WQ:i f�fish ctrausurmlatitna
• Bmgl chloride - No R-P, pivActe d mAx 50"/* of 20owable Cw; xaao0o6 g not
red( 61W aSnot a pd�lr ..Mete of cmce+aa;pex meatbrane WT? strategy
o Cancer gm4miaxt; iwed NC in -stream target valxtes for :sttrfac:e waters fhj-
fish (lxanaa,W laralth)
• Carbon tetrarhloride - No RP, predicted arnx < 50% of a lov able Cw; motutox*
not re tlxuced as atot a parameter of c oncem per xxrrtabrane W rP Strategy
c) Career smdpoiaxt: tcsed EPA NRWQC, for -AQ, coitsrn°aixption
• ElexachImoe.01 e. - RP for li cited dAtaset (n 8 sawales), ail data points were
ncna detect, PQI, <,10 µg/L; No monitoring rexltaiwd at 'this time as a auici dy
sensitive test was utilized
o Cancer endpoint; used EPA NRWQC for fish consumption
Radiological data was provided from the pilot study for the Northwest WTP proposed
RO concentrate for 1 sample collected on October 16, 2018 (results below). 15A NCAC
02B .0211 states the average annual activity level for combined R2dium-226 and
Radium-228 shall not exceed five (5) pCi/L and the average annual gross beta particle
activity shall not exceed fifty (50) pCi/L. Based on the results using annual stream flow
average (Qa; 10:1 dilution), monitoring for radiological components is as follows:
Parameter (,zr Z 1ue
i
,Gross Beta
I Uri 11%nito_r? � Reason
L �-G
31.6 (pilot study value) I
Maximum predicted pCL4 Yes
per RPA (at 10:1
dilution) - 195 92
Radium 226 - -�< 1
Radium 22$ � 1
< 2 (pilot study
Combined Maximum pr
etii
- Maximum predicted
concentration >_ 50•/a of
allowable Cw of 250 i
pCi/L per RPA; See
Attachment I of the
permit for monitoring
rewire nents
N/A
-4N/AA
Maximum predicted
concentration < 50% of
allowable Cw of 25
pCi/L per RPA
Um-egulated Compounds:
Brunswick County also performed additional testing for unnegulated emerging
compounds while performing the pilot study. The samples were taken on February 26,
Page 12 of 22
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2018, March 26, 2013, and May 24, 2013. There are no NC 02B standards, EPA National
Recommended Water Quality Criteria (NRWQC), or North Carolina in -stream, target
values for surface waters with which to compare the data.. However, as these are
pollutants of concern, monitoring for the follon iug compounds will be required for
outfall 002 at a semi-aamaial fluency:
• Perfluorotetridecauoic acid (PFTeA)
• Pezf noiridecanoic acid (PFTriA)
• PernuoredodecanOic acid A)
• Fertiuorotinde aoic acid (PFUnA)
• Per fuorotc.ancic acid (PS-DA)
• Perfluoronoaaaoic acid (PFNA)
• Perfluorooctaacic acid ,PFOA)
• Perfluoroheptanoic. acid �'PFHpA)'
• Perfluorchtxanoic avid (PFHxk
Perfluoropffitaneic acid (PFek
• Pe Euorobutanoic acid (PFBA,
• Perfluorodecanesulfonic acid (PFDS)
• Peffluorononanesulfonic acid (PENS)
• Ferfluorooctanesulfonic acid (PFOS)
• Pertuoroh�tptaaesulfonic acid pS)
Per#luorohwaaesulfonic acid (PFHxS)
• Perfluoropentanesulfonic acid )
• Perfluorobutawsu.1fonic acid S)
• Per&wooctanesulfouamide (PFOSA)
• 2-(N-ethylperfluorooctane do) acetic add (N-EtFOSAA)
• 2-(N-methylperfluorooctanesullonamido) acetic acid (N-McFOSAA)
• 2,3,3,3-Tetrafluoro 2(1,1,2,2,3,3,3-heptafluoropropoxy)-propanoic add) (HM-
DA / PFPrOPrA / GenX)
• Periiuoro-2-methoxyacetic acid (PFMOAA)
• 6:2 Fluorotelom r sulfonic add (6:2 FTS)
• Nafion Byproduct 2
Fesfluoro(3,5,7,9-tetr•aoxadecanoic) acid
• Pesfluoro(3,5,7-tricaoaL--ta.caic) add
• Per#hwro(3,5-dioxzh oic) acid
Additionally, pollutants for wbict pr'.lot stud• reivlts of unregulated compounds for
Outfall 002 were submitted will have mquired mnitonng (see Section 11 below), The
samples were taken on February 26, 2018, March 26, 2018, and May 24, 2018. The pilot
study was run at 85% efficiency and 9rl efficiency (tire efficiency at which Brunswick
County intends to run the proposed RO facility). Theseparameters can be found in the
following locations of the permit modification request:
Initial application submission received in letter dated November 9, 2018
Additional information received in letter dated February 15, 2019
Additional information received in letter dated March 8, 2019
Page 13 of 22
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• Additional information received on May 2, 2019
Section 10. Permi Strat -
The existing Outfall 001 to Hood Creek has been updated following the. 2009 WTP
strategy for membrane WTPs, the 2012 guidance update, and RPA_
The new proposed Outfall
002 to the Cape Fear River has been drafted following the
2009 WTP strategy for membrane WTPs and the 2012 guidance update. Total Iron is not
included for Outfall 002 as there is no longer a NC water quality standard. Parameters
included in the permit are below.
Flow
Membrane WTP strategy followed
_
Dissolved Oxygen
Membrane WTP strategy followed
Membrane WTP strate y followed
Conductivity
Membrane WI? strategy followed
pH
Membrane WTPfollowed
__ LL
Total Residual Chlorine
1(Mem6rane WTP strategy followed
Total Dissolved Solids
Membrane U`TP strate�follovved
Turbidity
_
Membrane WTP strategy followed
Total Arsenic
Membiine WTP sl ategy followed
Total Chloride
Membrane WTP strategy followed; See RPA (Section 9
of factsheet)
Total Copper
Membrane WTP strategy followed
Total Fluoride
Membrane WTP strategy followed; See RPA (Section 9
Yy_
offactsheet)
Total Zinc
Membrane WTP strategy followed
Ammonia Nitrogen
Membrane; WTP strategy followed
Perchlorate
See RPA (Section 9 of factsheet)
Total Lead
See RPALSection 9 of factsheet)
taros Beta
_
See RPA (Section 9 of factsheet)
Dichloroacetic acid
See RPA fSeMA 9 of factsLee
Total Nitrogen
Membrane WTP strategy_ followed
Total Phosphonn
Membrane WTP strafe qy "bowed
Total Hardness
WTP guidance followed
WET Testing
Membrane WTP strategy followed, IWC %based on
CORMIX model (see Section 7 of factskeet�
PEAS Compounds
�f See RPA (Section 9 of factsheet) and Special Conditions
(Section I 1 of factsheet)
Additional Parameters
See Special Conditions (Section 11 of factsheet) and
Attachment I of permit
Page lit of 22
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Section 11. Smcial Conditions:
Special Condition A. (6) has been added to the permit to define required instream
monitoring locations based on the approved dilution model -
Special Condition A (7) has been added to the permit to require that, in accordance with
40 CFR 122.21(kX5xvi), no later than 2 years after the commencement of discharge
from the proposed facility through outfalls 001 and 002, the applicant is required to
complete and submit items V and VI of NPDES application form 2C.
Special Condition A. (7) also requires that monitoring be performed for outfall 002 for all
parameters listed in Attachment I. This additional monitoring represents parameters that
are to in the NPDES application form 2C, but monitoring data was submitted from the
pilot study and the parameters have NC 02B water quality standards; EPA National
Recommended Water Quality Criteria (NRWQC), or North Carolina w-&eam target
values for surface waters with which to compare the data. Attachment I also includes
required monitoring of parameters that have no standards but monitoring results
submitted were above the level of detection as they are potential pollutants of concern if
NC or EPA standards are set. Monitoring will not be required for additional parameters
that monitoring data was submitted for (such as medications and food products) that are
known to be in raw water systems as the Division can require monitoring in the fixture.
Monitoring will also not be required for parameters that do not have NC or EPA
standards and submitted results were below the level of detection. See attachment to this
factsheet for a list of parameters.
Sptml C=dilion A. (8) has been added to the permit to address monitoring for emerging
PFAS compoinds.
Sptci2i Cor,,14 iota A. (9) has been added to the permit to address disposal of spent
membraze cleaning soluions in line with treatment stated in the permit application.
So- Oon 12. Changes from current pejult to draft-.
• Updated outfall map
• Updated language on the Supplement to Permit Cover Sheet for outfall 001 to
reflect current language used
• Receiving stream for outfaii 001 corrected to an unnamed tributary to Hood Creek
on cover sheet and Supplement to Permit Cover Sheet per comments from CDM
Smith (permittee's represeiitative)
•, Added language on the Supplement to Permit Cover Sheet to reflect the proposed
expansion and outfall 002
• Facility grade added in A (1)
• Turbidity monitoring red; 4 ed to 2'month in A(1) for outfall 001 per the 2012
WTP guidance
TRC limit updated in A(1) for outfall 001 based on WLA (full build -out
wastewater flow of 3.9 MGD used)
• Limits updated for copper in A(1) for outfall 001 per the RPA
Page 15 of 22
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• Limits removed for fluoride in A(1) for outfall 001 per the RPA
Compliance schedule in renumbered A(3) updated to reflect removal of
fluoride limits for outfall 001
• Limits removed for alummum and mo=tormg reduced to gg,=crly m A(l) for
outfall 001 per the 2012 WIP guidance
• Monitoring for zinc removed in A(l) for oula1001 per RPA
o Previous permit application indicated that zinc orthophosphate did not
have the potential to be discharrge6
• Added limited tonicity test with compliance schedule for outfall 001 in A(1) and
associated language as A(l 1 j to a ddiress ongoing toxicity issues
o Compliance date chosen as 1 year after discharge from outfall 002 is
scheduled to commence
• Added A(2) as effuent montoring for the proposed RO discharge outfail 002 into
the Cape Fear Rives and assmated toxicity language as A(12)
• Compliance schedule updated in A(3) to reflect current time to compliance
deadline
• Added A(6) for instream. nwnitoring location requiremeats for ou�fall 00-
Added A(7) to requi a additioml monitoring at outfalls 00l and 002 attef
discharge ccmmences• at owfall 002
o Cor.di^ion cza i- removed ftin¢ new ranr;t al
• Added A(&) to rents. a additional morutormg at outfall 002 for PFAS compounds
• Added A(9) to address dispos ;l of spent membrane cleaning solution
• Updated eDNa language in reatint'wed A(13)
Swiou 12�, Chanter from draft oo final.
Section.14. Comments received on draft permit-.
Page 58 of 81

Section 15. NPDES Implementation of In_meam Dissolved Metals Standards -
Freshwater Standards:
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by
the NC Environmental Management Commission (EMC) on November 13, 2014. The U:5
EPA subsequently approved the WQS revisions on April 6, 2016, with some exceptions.
Therefore, metal limits in draft permits out to public notice after April 6, 2016 must be
calculated to protect the new standards - as approved.
Table 1. NC Dissolved illetals Rater Quality StandardslAnuatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW,
ugll
(Dissolved)
Acute SW. itg/l
(Dissolved)
Chronic SW,
gWI
(Dissolved)
Arsenic
340
150
69
136
Beryllium
65
6.5
—
Cadmium
Calculation
Calculation
40
8.8
Chromium M
Calculation
Calculation
Chromium vl
16
11
1100
50
COPPff
Calculation
Calculation
4.8
1 3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation i
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Cakvlation I
Calculation 190
81
Table 1 Notes:
1. FW Freshwater, SW- Saltwater
2. Cakubtion= Hardness dependent standard
3. Only the aquatic life standards listed above aree expressed in dissolved form
Aquatic life standards for Mercury and selenium are still expressed as Total
Recoverable Metals due to bioaccumulative concerns (as are all human health
standards for all metals). It is still necessary to evaluate total recoverable aquatic
life and human health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at 10
µgll for human health protection; cyanide at 5 µg/L and fueride at 1.8 mg/L for
aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise. under ISA
NCAC 02B .0211 Subparagraph (1 lXd)
Mew NC Dissohred Standard pgi
Cadmium, Acute WER-(1.136672-[ln hardness](0.041838)) • e-(0.9151 [in hardam]-
3.1485)
Cadmium Acute Trout WER'{1.136672-finh rdness](0.041&M) -e(0915l[Gnhudness]-
wateas 13.6236)
Page 17 of 22
Page 59 of 81

Qdm;um� Chronic
VAR*(1.1016724!n hmdaess](0.041838)) - e-(0.7998[!n hudness]-
4.4451)
Chromium III, Acute
WER-0.316 e^{0.8190[br hardnew]+3.7256)
Chromium III, Chronic
W M-0.860 a^(0.8190[ln hudorss]+0.6848)
Copper, Amue
WER-0.960 - e(O.9422[ln hardness]-1.700)
Copps, Chronic
WER''0.960 • a-(0.8545[ln lumdoem]-1.702)
Lead, Acute
WER*(1.46203-[ln budaess](0.145712)) e(l173[In hudnew]-
1_a60}
Lead, Chronic
WER" (1.46203-[ln hardoew)(0.445712)) ejl-273[ln hardnew]-
4.705)
Ncbei, Acute
WER•0.998 eA(0.8460[Lt hardness]+2.255}
Mdkel, Chronic
WER-0.997 eA(0.8460[in hudnew]+0.0584)
Silver, Acute
WER`0.85 • a^{ 1.72[Li hardness]-6.59)
Silver, Chronic
Not applicable
Zinc, Acute
WER-0978 e^{0.8473[ln hardoew]+0.884]
Zinc, Chronic
WER*0.986 eA(0.8473[1n hzdaess]f0.884}
General information oa the Reasonable Potential Asahys k iRPAi
The RPA process itself did not chime as the result of the nett metals standards.
However, application of the dissolved and hardness -fit standards requires
additional consideration in order to establish the numeric standard for each metal of
concern of each indiAdml daschzre.
The hardness -based standards regtii a some knowledge of the effuent and instream
(upstream) hardness and so must be calculatedcase-by-case- faz each discharge.
Metals limo musi be c%4r.essed as 'total recoverable' metals in accordance with 40 CFR
122.45(c). The ciKbzge-specific standards must be converted to the equivalent total
values for use in the RPA calculations. We will generally rely on default translator values
developed for each metal (more on that below), but it is also possible to consider case -
specific translators developed in accordance with established methodology
Section 16. RPA Permitting. Guidan_ce/tii'OBELs for Hardness-fte indent Metals —
Freshaater:
The RPA is designed to predict the maximum likely effluent concentrations for each
metal of concern, based on recent effluent data, and calculate the allowable effluent
concentrations, based on applicable standards and the critical low -Sow values for the
receiving stream.
Page 18 of 22
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ff the maximum p xedicted value is greater than the maximum allowed value (chronic or
acute), the discharge has reasonable potential to exceed the standard which warrants a
pe: vu i timil in most cases. if monitoring for a particular pollutant indicates that the
pollutant is wt parent (i_e. consistently below detection level), then the Division may
remove the u:onit oring requirement in the reissued permit.
To perform a RPA on the Freshwater hardness t metals the Permit
Voter compiles the following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet
automatically calculates the 1Q10 using the formula iQiO = 0.843
(s7Q10, cfs) a.M
• Effluent hardness and upstream hardness, site -specific data is preferred
Permitted flow
• Receiving stream classification
In order to establish the numeric standard for each hardness -dependent metal of
concern and for each individual discharge, the Permit Writer must fast determine
,a,hat eMuent and instream (upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test
results for any hardness data and contacts the Permittee to see if any additional
darn is available for instream hardness values, upstream of the discharge.
I1 no tardness data is available, the permit writer may choose to do an initial
evaluation using a default ha: chess of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum
and a=ximuin limits on the Ludness value used for water quality calculations are
25 cog L and 4 00 mg/L, resxtlively.
If the use of a default hardaes s value results in a hardness -dependent metal
showing reasonable potential,, the perout writer contacts the Pernnittee and
requests 5 site -specific effluent and upstream hardness samples over a period of
one week. The RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as
follows:
C:orr'jirred Hardness (chronic)
= Teztutted Flow. Os *Avg Ettlueit Hw4xss mg/L) x (s7010 cfs 'ALg Upstream Hardness mg(L)
(Pemutted now, cfs + s7Q10, ch)
The Combined Hardness for acute is the saute but the calculation uses the 1Q10
BM
The permit writer converts the numeric standard for each metal of concern to a
total recoverable metal using the EPA Default Partition Coefficients (DPCs) or
site -specific translators, if any have been developed using federally approved
methodology
Page 19 of 22
Page 61 of 81

EPA default partition coefficients or the `Fraction Dissolved' converts the
value for dissolved metal at laboratory conditions to total recoverable metal
at in -stream ambient conditions. This factor is calculated using the linear
partition coef cients found in The Metals Translator. Guidance for
Calculating a Total Recoverable PwmltLimit from a Dissolved Oitedon
(EPA 823-&96-007, June 1996) and the equation:
Cau = I _
CVW I - ( [Keel [SSO"'21 [1041 }
Where:
ss - in -stream suspended solids concentration [mg/11, minimum of 10 mg/L
used, tad
Kpo and a — constants that express nix equilibrium relationship between
diSSeXed rind adsorbed forms of metals A list of constants used for each
hardness-deodent metal can also be found in the RPA program under a
The numeric standard for each rietal of concern is divided by the default partition
coefficient (or site -specific tr=12tar) to obtain a Total Recoverable Metal at
ambient conditions.
In some cases, where an EPA default partition coefficient t =lator does not exist
(ie. silver), the dissolved numeric standard for each metal of concem is divided by
the EPA conversion factor to obtain a Total Recoverable Metal at ambier
conditions. This method presumes that the metal is dissolved to the same exlent as
it was during EPA's criteria development for metals For more information on
conversion factors see the June, 1996 EPA Translator Guidance. Dc-,ummt.
The RPA spreadsheet reset a mass ba:ance equation to detenzine the total
allowable conceatratica pe^siit lira its; fo: each polhitax u:iag the following
equation:
Ca = Is7Q10 + QQ (Cwgs) — (s7Q10`. (Gb)
Qw
Where: Ca = allowable effluent concentra"io>a (pg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (pg/L or mg,I)
Cb = background concentration.: w s:.ame zero for all toxicants except R i;'
W/L or nIg/L)
Qw=permitted effluent flow (cfs_ .malch s7Q10)
s7Q10 = summer low flow used to protect aquatic lifee from chronic toxicity
and human bealtb through the consumption of water, fish and
shellfish from n carcinogens (cfs)
" Discussions are on -going wi tb EPA on how best to address background
concentrations
Flows other than s7QIC may be =orNrated as appticab
Page 20 -f 22
Page 62 of 81

1Q10 = used in the equation to protect aquatic life from acute toxicity
QA = used in the equation to protect human health through the
consumption of water, fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
The permit writer enters the most recent 2-3 years of effluent data for each
Pollutant of concern. Data entered must have been taken within four and one-half
years prior to the date of the permit application (40 CFR 122.21). The RPA
spreadsheet estimates the 95th percentile upper concentration of each pollutant..
The Predicted Max concentrations are compared to the Total allowable
concentrations to deteimine if a permit limit is necessary.. If the predicted max
exceeds the acute or chronic Total allowable concentrations, the discharge is
considered to show reasonable potential to violate the water quality standard, and
a permit snit (Total allowable concentration) is inchmded in the permit in
accordant a "'ittt the U.S. EPA Technical Support Document for Water Quality -
Based Tonics Control published in 1991.
hen aopriate, permit writers develop facility specific compliance schedules
m accordance with the EPA Headquarters Memo dated May 10, 2007 from James
L <aalon to .klvds Strauss ca 40 CFR 122A7 Compliance Schedule R quireme ats.
S. Ilae To:aa Ctro-m um NCWQS was removed and replaced with trivalent
chromium and ltxavalmt chromium Water Quality Standards. As a cost savings
measure, total cluomium data results may be used as a conservative surrogate in
cases where there are no analytical results based on chromium III or VI. In these
cases, the projected maximum concentration (95th %) for total chromium will be
compared against %vater qualit^^ standards for chromium III and chromium VI.
e Efllum' tardnrss sampling and instream hardness sampling, upstream of the
di schage, are s nserted in°o all permits with facilities monitoring for hardness-
depeadent metals to ensure ".ne accuracy of the permit limits and to build a more
roast hardness dataset.
16. hardness and flow values used ism tole Reasonable Potential Analysis for Outfall
001 for this Permit inchaded:
Parameter I
Value
Comments Mata Source
Average Effluent Hardness
25 mg/L
DMRs from Apri12018 to
(mg/L)
August 2019
Total as_ CaCO3 or(CR±Mgjj
Average Upstream Hardness
28 mg/L
DMRs from May 2018 to
(mg/L)
August 2019
Total as, C2CO3 or (Ca-NIg)
7 l0 sum=er (cfs)
0.07 cfs
Valise pulled from BalS
1Q10 (cfs)
0.06 cfs
Value pulled from RPA
Permitted Mow (MGD)
1d/A
WTP's do not have permitted
flow included in 'ts
Page 21 of 22
Page 63 of 81

11. Hardness and flow values used in the Reasonable Potential Analysis for Outfall
002 for this permit included:
Parameter
value
Comments(Data Source
Average Effluent Hardness
221.2 mglL
Pilot study conducted at 85%
OWIL)
efficiency and 92% efficiency,
[Total as. CaCO3 or (Ca+Mg))
Value is average of data
provided for both efficiencies
combined
Average Upstream Hardness
25
Upstream data not provided as
(mg/L)
part of pilot study; Standard
Total as, CaCO3 or (Ca+M
minimum used
7Q10 summer (cfs)
15.5 cfs
7Q10 for noncarcinogenic
parameters
69.75 cfs
7Q10 for carcinogenic
parameters
Based on dilution model
submitted with .ilication
1Q10 (cfs)
12.82 cfs
1Q10 for noncarcinogenic
parameters
57.08 ct's
1Q10 for carcinogenic
parameters
Based on dilution model
submitted with application
Permitted Flow (MGD)
NIA
WTP's do not have permitted
flow included in ptunits
Page 22 of 21
Page 64 of 81

Appendix B
Page 65 of 81

I
Clean Water Act and a -'DES Ovenriew �
• Clean 1Natc r Act of 1972
• Sectkr M3 - Classifications and Standards
• Sectio- 4122 - National Pollutant Discharge Elimination System (NPDES)
• CoNTess asslq�ied the responsibility of implementation to the EPA
• MNionai Polktant Discharge Elimination System (NPDES) program delegated to North
Carolina in 197 •,
• l*Ah Caroa w statues and rules used to administer the program
- Pk Oversigh,
Audits
Approve standards
Approve major permits
DepartwmrgfEnYimm"rnral Qualiot
2
Page 66 of 81

3
Ffater• Quality Standards
• Established by states twig EPA approval)
• Water quality roust conform to designated use
Antidegradation Policy
Tyoca' a 3:
Puot-c *-ater suppkes
• Protoct human heahh
Propagation of fish and wildlife
Recreational
Agacultural
Department of Ertrnnnnrantvl Quaii�►,
Ozo Needs an NPDES Permit'
M=
• Direct discharge to surface waters (any process wastewater or collected stomnxater)
Indirect dischargetPretreabnent
• Deemed permitted activities
DepartmentofEnrrronmental Qualiq
4
Goan i**A ww.•..owftdw
Page 67 of 81

.iVPDES Permitting Process
• CortVete AWlicatiort_
Pen -nit application
• Engineering Alternatives Analysis (EAA)
Mixing zone model (if dilution is requesters)
Munnoring data
• Oral1 Pemtit
• Public Notice - 30 day comment period
• Public Hearing
• Final Permit recision - Must be mw wlt
• If approved, permit gill have up to a , ye
D#partmont gfFaniromnanral Qualm
.1
90 da`, _ Of PLOGC 1)ea-m^
d lratitdf,
Permit Conditions (Individual Permits)
• Components fist and receiving stream characteristics
• Effluent Limitations wd Monitoring Requirements
• Special Conditions
• Standard Conditions (Boilerplate)
DvpaslmantofEm•mamncntal Quality•
M.
D- E
Page 68 of 81

7
8
Northwest R 7P — Proposed Expansion
. and Upgrades
• Currently a 24 mililon gallon per day (MGD) potable design WrP utilizing convention
treatment technology
Wastewater discharges to an unnamed tributary MT) to Nord Creek
• Proposing expansion of potable water treatment capacity over 2 buiki-out phases
• 24 MGD 4 3e MGD
38 MGD 4 45 MGD
• Reverse osmosis (RO) treatment technology will be added with expanded oonventional
treatment capacity
• Conventional waste stream will discharge to UT to Hood Creek
- Discharge wil be up to 3.9 MUD at full plant build -out
• RO waste stream will discharge to the Cape Fear River
Discharge will be up to 5 MGD at full plant build -out
• Dilution granted based on mixing zone model �L
DeparmmiofEnviromnental Quality
Conventional Treatment
I Ferrratd Fiow
h
i
Ir
or a,
■
_ .
Wash wra
Page 69 of 81

Reverse Osmosis Treatment
• Osmosis:
• Passage of a liquid from a weak solution
to a more concentrated soluton across a
semipermeable membrane
• Membrane allows the passage of water
(solvent) but not dissolved solids
(solutes)
' Reverse osmosis is forcing tie osmosis
reaCtw to move backwards by app(ylrtg
pressure
Dvparftr mrofEnviromitental quatirt,
9
10
OSXI SIS
ProduvrN Glier►_ y
1AXNWIM
Need% crieryp
Page 70 of 81

►- Blue Banks Loop Fd NE
-
z
Proposed Outhkil002
tc,pe� i�er�
Id
f
f
� Mt. Misery Road NE
cxislm� Dutfan
FIX
[UT to Hood_[,:(eevt,&,
41
-� Faaity Location
3FIn
11:10

Components List 9
cment and Pro;med water am wastewaw Tros"em
!IdDmftdrsirabection
Two (2) 12 MGD Lq>-Ioet daffms Two (2) 24 MGD rapid mix bat-ns
E E; sandla -i-n dt eigravel eats
MGD c$tv *t
0 (�)1 MGDsurge lagoor
One (1) CASD IVG- sudp to-c*ener
Detokcrexm
Surface Wem dish.(Outfal! 001)
I
Chvnica; 6isag4
—2
13
Four (4) high rate clarMer basis
Sixteen (18) duaT nx*ft (sand and anOrazie) granular media Fka
Two (2) deamels
One(1)4 MGO bac-Lwash oquiijT.- ji o* a!,,c decant tmir:
Two (2) 80-ft diamew slidget-'okeners
Dechkwkwation
Eigh! (8) 5.15 MGD osmosis skd s
Surface wiser dkdw,-4 ; W !,,
Submerged sbewr&m* d&harge (0". CC!)
Cheaical usage
Outfall 001 to b7 to Hood Creek
so= coromm
ftwm" "Wrt
TOW, Sus Wdm Swft
C= 30"V 45 ff4i %W"
elm EAkWd
PH
001M w < &0 sac atOt> 9.0 r.U. we"
Grab WWR
1w Resm" 000mle =
50000 17p" Weepy
Grab Emuert
TWMM(NM
00070 2A4WM
Grab EMUNt
TOUA%Wftn (po)
01105 QuarbuT
Grab Elnuem
7wcopper3
01042 8.12W I0.74VO ww"
Grab EMmM
7btal FkWMe W)
00051 mm4w
Grab Emuent
TOW NWW(TN)O"
cww Mw1ara Rvm Qfarterrit
GM EMLOW
TMIMMOMM(Mew)
cows KW 'Dr I room GUN"
Grab Merit
HaMness -IbW as
09M m w twa Repcxt OUN"
Grab Emkielt
IcaCO2 or (ca + &V)) MIWL)
Maydness-Tmas
or fm+ &Vl MG&)
90 T�&RePat Quar
Graff Ups"m
LCftmft vffr 7w" a
Ti" Sm Fo"Ie 6 Qm*q
Qfmm
14
Page 72 of 81

-
urdrrwHinacrMi TCA��_---_
care
6ww
caransaa
rrra" &WUUW
Dr9oMaeeJ Oaypen t�wOIL)
tr070D
Z�ot
am is WAM*
uaD
sawitmi
oared
attar,
Crab Ewa
UAD
aa,rrrloatM)
dam
2UMM
arch Errant
VAD
ON
OMW
pDls6aaAtDOragasa lj-W
OM Mart
Oufaft00?
ONCLIO
ooaao
2%ftlm
Grab VAD
to Cape
ONReM"Chtarlm-
e0000
a•lW View*
aft Mot
Fear
TOO cusoaaotlaMm MOW
70M
awbM
Grab ee>ms
OM
Do=
MbM
crab eVirort
7"ArvefttpaLt
araea
care*
crab BMW*
TaNcaalar
oaeso
atsmyL MM"
drab Eta
TOWCOPM4U )
0tn4:
Mary
am emw*
TaWFluorl4e
=91
27WpgOL Narry
Grab enuer,t
Turf am 40V
01 MB
fi 7
am eauisk
AnanoiUNWOM(rrWU
COOID
Mary
Grab ENW9
pwchbraie
9120
4.2poL Mary
Grab emu&*
Toti Low
owl
Owl"
Grab EWM*
OMOrDK@k &M
Sim
Coro"
Grab etow t
Tow Mitt (TM M OU
aoaoo
Orrrlcb
am EtOrrrrt
Tdo Awipbraa (M tom)
C06e6
Gur
ww (rib eSurrt
NWrrem-T MSS cries-A"Aprota°
Dow
Mlarttoridepart Cw ftw
Grab MWA
lYrOUSS-Taw asPvooyCrMe-M4II(arDL)k
cc=
MlorAwargow arrr"
arch V
CawW&WETTeSWO►
7GP39
Pan/FaB Ouirwv
Grab ERk&7rt
PFAB CDmp zgk
Set FOobrab 7 Seft*ArA
M Crab eAMai!
is
,Special Conditions for Nortlnvest i3'TP
• Compliance Schedule for Outtall 001 (UT to Hood Creek) for total copper
• Permit Reopener for Whole Effluent Toxiaty
• Permit ReopQnc for I iMDt_ implementation
" rnstream Sampling Locations
• Rt,jy ung Requirements after Commencenwi sf Dtsc�-iarp.
DepmnntnlejEn►#vmrrarrtal Qr1a1t`tt'
16
Page 73 of 81

Special Conditions for Northwest W7P
-1.
• Reporting Requirements for Emerging Compounds for Outfall 002 (Cape Fear River)
. Disposal of Spent Membrane Cleaning Solution
• Chronic Toxicity Testing for Outfall 001 and Ovifall 002
'Electronic Reporting of Discharge Monitoring Reports
Drpwm*ntqfEmyf7cmx#nraI Qualzo
17
Standard Conditions (Boilerplate)
- Standard Conditions for all permits
EPA approved
M 5 V\�tkm
,�Yufinititions
• General conditions
• Operation and maintenance
• Monitoring and records
• Reporting requirements
DeparnmentofEm•unmrxental Qualm
18
�s.wrr.>aw ar.r+noa,.rp'lwaa-M a_.w»'.
Y4,r� N.rnar.. a.ir+..s ._•r. .ear. .
y�y�i�+- ar-MwYiMY..n •-r.Kw .ra_ .r .r..
Page 74 of 81

Anticipated Permit timeline
• Pul)lic Hearing -December 5. 2019
• Public Comment Feriod Closes Dc—m-�uer 5, 2019
• Hearing Officer's Report
- Final Permit Decision - No later than March 4.20 0
Public Water Supply - Stilt in review
Depoment of Em i7omnenral Qualio,
19
Contact Infomation
• John Hennessy - Supervisor. Compliance & Expedited Permitting Branch
• Email. John.HennessyQncdenngov
• Phone- 910-707-3815
DEQ
• Brianna Young - Environmental Specialist 11, Compliance & Expedited Permitting Branch
• [e-mail]
Phone- 919-707-3819
DepartwarofEnviromnenral Quathy
20
Page 75 of 81

Appendix C
Page 76 of 81

Page 77 of 81

NON -SPEAKER SIGN IN SHEET
BRUNSWICKCOUNT rNoRTtt r W rp-NPDLS PFRmrrXC0W533
PunBttutvSwlcK C4vrr�" Gov�lN� Co4itr tC HEARIN'€:
Bit'NgMCKCOUNrvCOMMUMONMC"AMwm%B tvtn,NC
DEct-An RS, 2019 CrffMDAV)
— — ►e+--r
NAME t1[1,mw.NTsr
WHOM DO Y(Pli It f:t'RFSF-N-i'?
3.CD
4.
n
7.
9.
10.
ti�13.� -

PUBLIC ]HARING NON-SpEAIKER SIGN ilY SHEET
-- CO Yl t WHO T)o you RYA
I .�rthrl,Wl C f� CL)La '9"j
—

'9
Appendix D
Page 80 of 81

ATA
rCDE�IR
font Caroarta Department of E:nvironn-eil and Natural Resources
Division or Walef Qualm,,
Be very r4ief: H Sullins Dee
Direr ui Secretary
Memorandum
To: NPDES Permit Writers
Thru: Jefl'Poupart
From: Torn Relniclr
Date: July 15, 201
Re: Aionitoring, Free uenev for Toxic Substances
The following guidance will provide for more consistent determinations of monitoring frequency for NPDES
permitting. The monitoring frequencies listed below arc consistent with several Region 4 States. and will
provide sufficient data to perform reasonable potential analysis (RPA) at permit renewal. This guidance
pertains to toxic substances (e.g., metals, cyanide, carcinogens) that have corresponding water quality
standardso'criteria that provide for RPA evaluation. This guidance is not applicable for T.RC or NH3, which are
toxicants but arc not subject to RPA analysis and already have monitoring frequencies defined in 15A NCAC
2B.050t1(Surface Water Monitoring). Permit writers should continue to use all available toxicant data (I.TMP,
PPA, DMRs) to conduct RPA evaluation.
Effective immediately, this guidance for monitoring frequency should he follmved for permit development.
However. there will undoubtedly be the need for some case -by -case decisions (e.g.. toxicants with TMUL.
reduced monitoring for New Permits following data collcction(RPA evaluation). Permit writers should discuss
such exceptions with the NPDES Unit Supervisors. Monitoring frequcncy can also be increased for non-
compliance.
RPA Condition Permit Monitoring Frequency
LRPA Exists
, Monitor Monthly and add Permit Limit
-.RPA Exists but Action Levels I Cu. Zn, Ag ,Fc, Cl►
' Monitor Quarterly in conjunction with Tox `test
3a.RPA Exists but Dataset Limited (n< 8 samples)
Monitor Quarterly
3b. RPA exists, dataset limited. but 2 values a
t Monitor Monthly and add Permit Limit
allowable Cw
4 No RPA (Predicted Max > 5tr% of Allowable}
Monitor Quarterly (or defer to Pretreat LTMPf
S.No RPA (_Predicted 4iax { 5(r/. Allowable
No Monitoring
6a.No Data (New* Permit, New Waste Stream)
Monitor Monthly for Toxic Pollutants of Concert
bh. New Greemand or Conventional IWTP
Monitor Quarterly for Toxic Pollutants of Concert
11 11ai sews* l.et 6' RIM
?rn §t3 H C: Rt ,q W'M" Ca
x. 914 1 r 4
1f �n
(Inc
ortti('arofina
Page 81 of 81