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HomeMy WebLinkAboutNC0025712_Permit (Issuance)_20001009NPDES DOCUMENT SCANNING COVER SHEET NPDES Permit: NC0025712 Hookerton WWTP Document Type: , 'Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Report Speculative Limits Instream Assessment (67b) Environmental Assessment (EA) Permit History Document Date: October 9, 2000 This documerit is printed on reuse paper - ignore any content on the re' rerse side State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secretary Kerr T. Stevens, P.E., Director October 9, 2000 Mr. James Spivey, Utility Director Town of Hookerton P.O. Box 296 Hookerton, North Carolina 28538-0296 e�� NCDENR Subject: NPDES Permit Issuance Permit No. NC0025712 Hookerton WWTP Greene County Dear Mr. Spivey: Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended.) Please accept our apology for the extreme delay in the reissuance of the permit. All of the Neuse River permits expired in 1998 or 1999. As the permits from the upper portion of the basin were being readied for issuance in 1998, three issues emerged and delayed final action on the permits. First, the NRF submitted a request to the Division to hold public hearings on all 168 of the NPDES permits in the basin. Next, staff discovered a mistake in the NSW rules governing the nitrogen reductions from point sources necessary to protect water quality. Finally, the Division was in the process of working with the EPA to develop a total maximum daily load for total nitrogen. These three factors held up final action on the permits until temporary rules were adopted in February 2000. Public hearings on the renewal of the NPDES permit for the Hookerton WWTP and fourteen other discl?argers were held on May lu and 4th of this year. After a thorough review of all submitted comments and recommendations, the following modifications have been made to the final permit: • Quarterly monitoring for TN and TP has been modified to 2/month. • Repair of the existing floating aerator must be accomplished within 90 days. The extension of the outfall directly into Contentnea Creek within one year is also a requirement of this permit. (Please see Special Conditions A (3) and A (4)). This facility's discharge is located in the Neuse River Basin, in which all streams have been designated as nutrient sensitive waters (NSW) as a result of algal bloom problems in the estuary. The North 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083/FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper Carolina Environmental Management Commission recently adopted rules establishing the Neuse River Basin Nutrient Sensitive Waters Management Strategy for the reduction of phosphorus and nitrogen inputs. The point source rule (15A NCAC 2B .0234) is intended to reduce total nitrogen (TN) discharges by 30% by 2003. It specifies that individually permitted wastewater discharges to the Neuse River Basin with permitted flows less than 0.5 MGD in 1995 shall be allocated a collective annual mass Toad of 155,400 pounds/year of total nitrogen. This is equivalent to an allocation in the range of 5 - 10 mg/1 TN for each small discharger. Although no total nitrogen limits appear in the permit at this time, Hookerton may be subject to nitrogen limits in the next permitting cycle. All facilities with permitted flow greater than or equal to 0.5 MGD are receiving a TN limit in this permit cycle. The Division recommends that Hookerton evaluate the cost of installation for nutrient removal facilities in the event that a nutrient limit is imposed. It is also recommended that alternative discharge options be evaluated such as such as spray irrigation, subsurface systems, wastewater reuse, or connection to a larger regional system. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable. Part II, E.4. addresses the requirements to be followed in case of change in ownership or control of this discharge. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permits may be required. If you have any questions or need additional information, please contact Ms. Jacquelyn Nowell at telephone number (919) 733-5083, extension 512. Sincerely, ORIGINAL SIGNED BY KERR T. STEVENS Kerr T. Stevens cc: Central Files Washington Regional Office / Water Quality Section Mayor Kim S. Purser, Hookerton Sam Johnson, Town Commissioner Ken Garris, Town Commissioner Morris Luckett, Town Commissioner Clarence Edgar O'Briant, Town Commissioner Neuse River Foundation ;NPDES Unit, Permit File r Point Source Compliance/Enforcement Unit Training and Certification Unit Permit No. NC0025712 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision 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, Town of Hookerton is hereby authorized to discharge wastewater from a facility located at Town of Hookerton Wastewater Treatment Plant Highway 123 North of Hookerton Greene County to receiving waters designated as Contentnea Creek in the.Neuse River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective November 1, 2000 This permit and authorization to discharge shall expire at midnight on May 31, 2003 Signed this day October 9, 2000 ORIGINAL SIGNED BY KERR T. STEVENS Kerr T. Stevens, Director Division of Water Quality By Authority of the Environmental Management Commission Permit No. NC0025712 SUPPLEMENT TO PERMIT COVER SHEET Town of Hookerton is hereby authorized to: 1. Continue to operate an existing 0.060 MGD treatment plant consisting of an influent bar screen, a three cell lagoon with adjustable effluent baffles, and a small aerator in the third cell located at Town of Hookerton Wastewater Treatment Plant, Highway 123, north of Hookerton, Greene County and, Discharge from said treatment works at the location specified on the attached map into the Contentnea Creek, which is classified C-Swamp NSW waters in the Neuse River Basin. Facility Information Latitude: Longitude: Quad #: Stzeam Class: Receiving Steam: Permitted Flow: 35°25' 42" 77°35'35" F28NE C-Sw NSW Contentnea Czeek 0.060 MGD Sub -Basin: 03-04-07 Town of Hookezton W WTP NC0O25712 Greene County A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NC0025712 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location1 Flow 0.06 MGD Continuous Recording I or E BOD5 2 30.0 mg/I 45.0 mg/I 2/Month Grab E, I Total Suspended Solids 2 90.0 mg/I 135.0 mg/I 2/Month Grab E, I NH3-N • Monthly Grab E Dissolved Oxygen Weekly Grab E Dissolved Oxygen (April 1 — May 31) Weekly Grab U,D Dissolved Oxygen (June 1 — September 30) 3/Week Grab _ U,D Fecal Coliform (geometric mean) 200/100 ml 400/100 mi 2/Month Grab E pH 3 Weekly Grab E Total Residual Chlorine 2/Week Grab E Conductivity Weekly Grab E Conductivity (April 1 — May 31) Weekly Grab U,D Conductivity (June 1 — September 30) 3/Week Grab U,D Temperature Weekly Grab E Temperature (April 1 — May 31) Weekly Grab U,D Temperature (June 1 — September 30) 3/Week Grab U,D Total Nitrogen (NO2-N + NO3-N + TKN) 4 No Effluent Limit (mg/I) No Effluent Limit (Ib/mo) No Effluent Limit (lb/yr) 2/Month Monthly Annually Grab Calculated Calculated E E E Total Phosphorus 2/Month Grab E Notes: Sample Locations: E - Effluent, I — Influent, U — Upstream at Highway 13/258, D — Downstream at Highway 123 2 The monthly average effluent BOD5 concentration shall not exceed 35% of the respective influent value (65% removal). 3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 4 See Special Condition A (2), Total Nitrogen Monitoring. There shall be no discharge of floating solids or visible foam in other than trace amounts. • Permit NC0025712 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A (2). TOTAL NITROGEN MONITORING The Permittee shall calculate the annual mass loading of total nitrogen as the sum of monthly loadings, according to the following equations: (1) Monthly Mass Loading (Ib/mo) = TN x Q x 8.34 where: TN = the average total nitrogen concentration (mg/L) of the composite samples collected during the month 0 = the total wastewater flow discharged during the month (MG/mo) 8.34 = conversion factor, from (mg/L x MG) to pounds (2) Annual Mass Loading (Ib/yr) = Z (Monthly Mass Loadings) for the calendar year The Permittee shall report the total nitrogen concentration for each sample and the monthly mass loading in the appropriate self -monitoring report and the annual mass loading of total nitrogen in the December self -monitoring report for the year. A (3). AERATOR REPAIR Not later than 90 days after the effective date of this permit, the Permittee shall return the existing floating aerator to operating condition and put the aerator back into service. A (4). OUTFALL EXTENSION Not later than one (1) year after the effective date of this permit, the Permittee shall: a) Submit an approvable design and request for an Authorization to Construct to extend its existing outfall to the mainstem of Contentnea Creek, and b) Upon issuance of the Authorization to Construct, construct and activate the approved extension. DIVISION OF WATER QUALITY September 20, 2000 MEMORANDUM TO: Kerr T. Stevens FROM: Boyd DeVane SUBJECT: Report and Recommendations: Neuse River Discharge Permit Hearings I. INTRODUCTION As you requested, I served as Hearing Officer for two hearings held on May 1" and May 4th in Raleigh and New Bern, respectively. The hearings were held as a result of requests from the Neuse River Foundation (NRF). The hearings focused on 15 of the 168 individually permitted NPDES wastewater facilities in the Neuse River Basin and provided opportunity for public comment on those facilities and their draft permits. The facilities were as follows, in approximate upstream -to - downstream order: • City of Durham • Heater Utilities — Hawthorne Subdivision • Ira D. Lee — Deerchase Subdivision • Whitewood Properties — Neuse Crossing Subdivision • Riverview Mobile Home Park • Uniprop, Inc. — Mill Run Mobile Home Park • Town of Benson • Pope Industrial Park • Town of Hookerton • Town of LaGrange • West Craven Middle School • Town of Vanceboro • Town of Bridgeton • Town of Trenton • Carolina Pines Utility Co. — Carolina Pines Subdivision In the course of preparing for and conducting these hearings, I received numerous public comments, visited each of the treatment plants, reviewed discharger monitoring reports and other Division records, and discussed these matters with Division staff. This memorandum presents my findings and recommendations to you on this matter. It is worth noting that, although these were some of the first combined hearings the Division has conducted on this scale, we can expect to hold more like them in the future. Because we organize our permits on a basin -wide approach, it is reasonable for public hearings to assume a basin -wide scope as well. In fact, the NPDES Unit is already looking at using a similar approach with the Catawba River basin permit renewals, which are now underway. 1 • II. HISTORY/BACKGROUND As you are aware, the Neuse River basin has experienced tremendous growth and development pressures during the last 20 years or so. During this same period, nutrient enrichment problems have been documented in the upper basin (upstream of the Falls of the Neuse Reservoir) and the estuary (downstream of Streets Ferry). This basin was one of the first basins in North Carolina to receive the supplemental classification of nutrient -sensitive waters (NSW). Dissolved oxygen levels in the river are also of concern and are closely monitored. A field -calibrated QUAL2E model was developed in the early 1990's to establish a reliable tool for predicting impacts of oxygen -consuming waste inputs to the river system. All of the Neuse River permits expired in 1998 or 1999. As the permits from the upper portion of the basin were being readied for issuance in 1998, three issues emerged and delayed final action on the permits. First, the NRF submitted a request to the Division to hold public hearings on all 168 of the NPDES permits in the basin. Next, staff discovered a mistake in the NSW rules governing the nitrogen reductions from point sources necessary to protect water quality. Finally, the Division was in the process of working with the EPA to develop a total maximum daily load for total nitrogen. These three factors held up final action on the permits until temporary rules were adopted in February 2000. III. HEARING PROCESS AND SITE VISITS Initially, the NRF requested that public hearings be held for all 168 of the NPDES wastewater permits within the basin. The primary concern at this point was related to excessive nutrient loading and the lack of an acceptable TMDL for total nitrogen. As TMDL development, review, and refinement was being undertaken, the NRF agreed to re -focus the objectives of public hearings. The Division and NRF worked closely to target 15 facilities that had specific issues related to planning, operation, and/or compliance. The NRF, the permit holders, and the Division then worked together to co-ordinate meeting locations, processes, and comments. We agreed that two hearings would be held — in Raleigh and New Bern — within the same week. The hearings were advertised once each in the Raleigh News and Observer, the Durham Morning Herald, the Kinston Daily Free Press, and the New Bern Sun - Journal at least 30 days prior to the hearing dates. Prior to the hearings, regional office staff, NPDES Unit members, and I visited all of the 15 treatment plant sites. Kent Penny from Wake County Health Department joined us for those facilities in Wake County. Of course, a plant operator represented permit holders at each of the 15 sites, and in some cases local elected officials joined us as well. In addition to these site visits, a number of staff members and I surveyed the lower Neuse River estuary near New Bern by boat with the help of the Neuse River Rapid Response Team on May 4t. The May 1 S` hearing was held in the Ground Floor Hearings Room of the Archdale Building and was attended by approximately 60 members of the public plus Division staff. The May 4'1' meeting was held in the Craven County Courthouse in New Bern and was attended by approximately 100 members of the public plus Division staff. IV. PERMIT -RELATED FINDINGS AND RECOMMENDATIONS POSITIVE PARTICIPATION OF STAKEHOLDERS First, I would like to commend the Neuse River Foundation for its well -organized and extensively researched effort to bring their concerns about the condition of these and other discharges in the 2 Neuse Basin to our attention. They focused on significant problems with the facilities and pointed out areas of our program which need improvement. My recommendations in this report include several of their proposals. I also want to commend those dischargers who have made conscientious efforts to maintain and improve the performance of their wastewater systems and who enlightened us of the challenges they face in doing so. PERMIT -RELATED FINDINGS For the purposes of this report, I have divided the findings and recommendations into two groups: those pertaining to specific permit issues and those dealing with other, usually programmatic issues. Public comments from the hearings were, of course, the main source of permit -related issues. Division staff identified additional issues as the result of the pre -hearing site visits and their discussions with regional staff, plant operators and management, and local elected officials. Comments and concerns are summarized below. Public Health Threats The Neuse River Foundation identified potential public health threats from several facilities' outfall pipes. In one case (West Craven Middle School, see below), a boat ramp was installed several dozen yards upstream of an existing outfall, and the area immediately surrounding the discharge pipe has become a popular swimming area, complete with rope swing. In another (Riverview Mobile Home Park), the collection system within the community has overflowed in tenants' yards, exposing the children who play there to raw sewage. Permit Non -Compliance Poor permit compliance was the primary concern voiced by the NRF about most of these permits. The Foundation based its revised hearing request largely on compliance records in the basin; specifically, the list of assessments issued within the last five years. Fortunately, only a few facilities in the basin had major compliance problems in this permit cycle, but most of the facilities selected for hearing received more than one enforcement action during the same period. Deficient Facility Management and Operation The NRF was critical of operators at certain facilities where they felt management and operation were deficient. In addition to noting the poor compliance records at these facilities, the NRF pointed out instances where poor biosolids management resulted in loss of solids directly to streams; in some cases, our pre -hearing site visits (and past compliance inspections) directly supported those observations. It was clear from our site visits that some local governments allow their collection and treatment facilities to be operated and maintained at a sub -standard level. On the positive side, we saw some facilities that were well operated and well maintained. They deserve our commendations for their commitment. Several permittees that had compliance problems in the last permit cycle have already hired new contract operators or taken other concrete measures to correct the problems at their facilities. 3 Inadequate Facility Planning & Regionalization Division staff noted during the site visits that over half of the 15 facilities in these hearings need to conduct some sort of facility planning to re-evaluate discharge alternatives, prepare for future growth, renovate existing collection or treatment facilities, improve treatment plant operations, or meet other specific needs. The Division usually relies on dischargers to periodically re -assess their wastewater management needs and disposal alternatives on their own initiative. Many of the subject facilities have not done so. Improper Wastewater Contribution by Tenants At three facilities receiving wastes from multiple units (two mobile home parks and an industrial park), wastewater contributions by tenants have caused considerable disruption of waste treatment processes. The main causes are oil and grease (residential sources) and potentially toxic chemicals (commercial sources). The overflow conditions mentioned earlier for one mobile home park were caused by excess grease in the sewer lines. PERMIT -RELATED RECOMMENDATIONS Discharge Identification Signs Commentors at the public hearing in New Bern noted the opportunity for the public to get into direct body contact with treated wastewater at several discharging facilities. Staff learned that, at several sites, people swim, boat, or fish in close proximity to an unmarked discharge. I recommend that "Discharge Identification" signs be required at those facilities where there is a reasonable likelihood that human contact could occur. The signs will notify visitors of each discharge location and advise them to avoid contact or consumption. The signs will also list telephone numbers so that citizens can easily contact the discharger or the Division if they see evidence of improper treatment. The Division staff can provide a template (see draft template, attached) or a low-cost sign suitable for outdoor use. I further recommend that we evaluate the effectiveness of the signs during a trial period; and, if they prove effective in promoting environmental safety and awareness, that we consider applying this requirement in future permits renewals statewide. Facility Rehabilitation and Optimization The staff and I believe there is considerable opportunity to improve the operation and maintenance at some of the wastewater treatment plants we reviewed, which would lead to improved plant performance and better water quality in the receiving streams. Although in the past the Division has worked with facilities to perform assessments of their operations and their facility needs, it has become apparent that a more focused approach is needed. I recommend adding special conditions to most of these 15 permits requiring the permittees to perform optimization and rehabilitation studies of their wastewater treatment and collection systems, to be completed within set timeframes. I further recommend that for certain facilities the permit issuance letter reflect our disappointment with the seemingly low priority placed on wastewater treatment issues and copy the appropriate elected officials to encourage higher prioritization of these needs. 4 Discharge Alternatives Analyses The DWQ staff realizes that special conditions in the permits should be strengthened and better enforced. The staff is aware that many facilities failed to provide information as outlined in the previous permits and have accordingly strengthened the wording in the permits and included specific dates for compliance. It is my opinion as hearings officer and the opinion of other Division staff that several of the 15 facilities (and many others in the Neuse Basin) should be required to connect with larger neighboring facilities as soon as reasonably possible. I recommend we pursue elimination of these discharges more aggressively by including language in several of the permits requiring specific steps that will lead to increased regionalization of facilities. Communications Strategies Where tenants have caused problems with treatment plant operations, the staff and I believe it is reasonable to require the permittees to undertake an educational program to minimize those problems. Several utilities in the area have already developed similar materials for their own use, and these may serve as a model for the Neuse dischargers. It may also be useful to apply this educational mandate in similar situations elsewhere around the state. I recommend adding special conditions to certain permits requiring the permittees to develop and implement appropriate educational programs. Facility -Specific Actions The attached sheets summarize my findings and recommendations for each of the 15 permits considered at these public hearings. Most of the recommendations involve adding special conditions to the permits to address the significant concerns mentioned above. V. ADDITIONAL FINDINGS AND RECOMMENDATIONS This section presents my findings and recommendations for other issues, not specifically related to any one permit or group of permits, which arose during the site visits, hearings, and related discussions. These are generally broader issues regarding how the Division administers the water quality programs statewide. As a result, I believe we should consider implementing several of these recommendations in all 17 basins of the state, not only in the Neuse River basin. ADDITIONAL FINDINGS Need for Improved Compliance Monitoring The Neuse River Foundation pointed out that some dischargers did not complete certain requirements in the current permits, such as looking at alternative discharge options, and that the Division did not take enforcement action for these failures. Division staff note that the compliance tracking system only monitors compliance with monthly average effluent limits, so that many permit requirements, including narrative conditions and some types of effluent limits, are not automatically tracked. Limited Priorities for Wastewater Needs of Small Municipalities A recent review of our records shows that most enforcement actions by the Division have been issued to small municipal wastewater treatment systems. These small municipal dischargers are, 5 in turn, the least able to fund the necessary improvements to their wastewater systems and operations in order to achieve compliance. However, the state's funding priorities do not seem to adequately reflect the greater needs of the smaller dischargers. Regionalization and the Sovereignty of Small Municipalities One issue raised by the Neuse River Foundation was the desirability of eliminating some discharging facilities. The Division strongly agrees that larger facilities are usually more capable of consistently meeting higher levels of treatment with fewer operational aberrations and supports the regionalization of wastewater systems wherever feasible. At the same time, we recognize that incentives for the smaller municipalities are limited. They are often reluctant to connect to other systems, regardless of the potential cost savings. They fear that, in surrendering control of their wastewater systems to a neighboring utility, they are also surrendering their sovereignty and their ability to control their own destiny. The current legaL and policy framework may not adequately protect the interest of the smaller local governments in these situations. ADDITIONAL RECOMMENDATIONS Improved Compliance Monitoring Because of the limitations of the computerized compliance monitoring system, most of the new nutrient requirements being implemented in the Neuse River basin and most of the permit Special Conditions I recommend in this report will have to be tracked `manually,' each month, one permit at a time. And, because of the magnitude of the water quality issues in the basin and the high profile of these permits in particular, it is essential that we do a better job of following up on the permit requirements and ensuring compliance. I recommend that you reinforce that compliance monitoring and enforcement is a high priority for the Division and that you direct the Washington and Raleigh Regional Offices to carefully track and review these dischargers' compliance with all requirements in their permits, particularly the new Special Conditions. I also support continued development of BIMS, or some other suitable compliance tracking system, to improve data management and compliance monitoring in the permitting program. Higher Priorities for Small Municipal Systems I recommend that the Division consider how we can improve our support for small municipalities' waste management efforts. One way may be to modify our ranking system in order to better target the available funding to meet the greatest needs. Another may be to target our technical assistance efforts to these dischargers. Support for Operation and Maintenance Improvements In keeping with the above, I recommend that you direct the Technical Assistance and Certification Unit to assist and monitor the municipal dischargers' efforts in optimizing their facilities and operations. This would help ensure that the dischargers meet the special requirements I am recommending for their permits. I also recommend that you direct the TA&C Unit to identify other ways it can better ensure that contract operators are fully qualified to operate and are operating the treatment plants under their control within acceptable bounds. 6 Regionalization and Sovereignty of Small Municipalities I recommend that the Division consider rule changes that would strengthen mandates for local governments using state funding to evaluate regionalization possibilities. The new rules should also ensure that the sovereignty of any municipalities connecting to a regional system is protected. VI. ATTACHMENTS A. Original and Revised Requests for Public Hearing B. Announcement of Public Hearings C. Pictures from Pre -Hearing Site Visits D. Handouts from Public Hearings - E. Written Comments Received - F. Summary and Recommendations Sheets • City of Durham • Heater Utilities — Hawthorne Subdivision • Ira D. Lee — Deerchase Subdivision • Whitewood Properties — Neuse Crossing Subdivision • Riverview Mobile Home Park • Uniprop, Inc. — Mill Run Mobile Home Park • Town of Benson • Pope Industrial Park • Town of Hookerton • Town of LaGrange • West Craven Middle School • Town of Vanceboro • Town of Bridgeton • Town of Trenton • Carolina Pines Utility Co. — Carolina Pines Subdivision 7 Summary and Recommendations Neuse River Basin Public Hearings May 4, 2000 Town of Hookerton Hookerton WWTP NC0025712 Facility Description The Town of Hookerton owns and operates a lagoon wastewater treatment plant. The wastewater is 100% domestic in nature. Treatment consists of a three -cell lagoon with a small aerator in the third cell. Discharge is to Contentnea Creek, a Class C Sw NSW water. A segment of the creek upstream of Hookerton is on the 303(d) list for D.O. violations and sediment problems. Permit Summary The facility is permitted to discharge 0.060 MGD to Contentnea Creek. Existing limits are 30 mg/L BOD, 90 mg/L TSS, and 200/100 mL fecals, with quarterly monitoring of TN and TP. The Town is currently under SOC, with relaxed limits for BOD and TSS. It has applied for grants for both connection to the Snow Hill WWTP and installation of an innovative duckweed treatment system. The draft permit increases TN and TP monitoring to 2/month; no other changes. Comments Grace Evans, NRF: • Long history of permit violations, largely ignored until recent years. Despite this record, DWQ increased flow from 0.020 to 0.060 MGD with 1994 SOC. • DWQ failure to get treatment facilities out of the floodplains contributed to the poor water quality in Contentnea Creek after Hurricane Floyd. • Unfortunately, DWQ did not actively support plans for connection of Hookerton system to Snow Hill. • NRF supports innovative ideas but is concerned about the proposed duckweed alternative. Long-term performance is uncertain; especially concerned that Town is seeking industrial users but that duckweed system has problems treating industrial wastes. Vendor would assume ownership of the WWTP. Concerns are heightened because vendor claims the company is listed on NASDAQ, but NRF hasn't been able to verify • Hookerton lacks the resources to meet its long-term waste management needs. • NRF recommends: — Thorough check of Bionet claims (technical and other) before approving the duckweed project — If claims are supported, verify that Town has legally binding long-term contract to ensure WQ protection and financial protection for the Town in case the system does not perform as claimed. DWQ Response and Discussion • Many treatment facilities in the Neuse River Basin were impacted by the floods that followed Hurricane Floyd. The standard that is generally accepted across the country is that facilities should be located and designed to withstand the 100-year flood. The recent flood waters were extraordinarily high, approaching the 500-year flood level. While these events may be reason to review the siting criteria, the flooding of the treatment facilities does more to illustrate the severity of the flooding than to question the validity of the criteria. • DWQ has worked with the Hookerton to find a more effective and reliable approach to wastewater treatment and has promoted and supported its connection to the Snow Hill regional treatment system. While the Division still prefers this regional solution, we are open to considering the innovative 1of2 a duckweed system and will review the system design when the Town submits the system design for approval. • Hookerton's financial resources are indeed limited. The Town is pursuing the duckweed system in part due to its ability to secure funding through the CWMTF. Unfortunately, the grant and loan monies under the Division's control are not adequate to meet all of the priority needs in the State. • During the pre -hearing site visit, staff noted that the surface aerator in the Town's final lagoon was still inoperative after being damaged in the recent floods. Repairs are overdue and should be completed immediately. • The treatment plant discharges to a short channel adjacent to Contentnea Creek. The channel is not considered an 'effluent channel' under state policy, meaning that the discharge is required to meet WQ standards in that channel. Since this is not likely to be feasible, the Town should extend its outfall line to the Creek. Recommended Action(s) The NPDES Unit recommends the following (to be inserted as a Special Condition in the permit (listed below): • repair of the existing lagoon aerator. • a design and request for an Authorization to Construct an outfall extension to the Creek. A. (_.) AERATOR REPAIR Not later than 90 days after the effective date of this permit, the Permittee shall return the existing floating aerator to operating condition and put the aerator back into service. A. (_.) OUTFALL EXTENSION Not later than one (1) year after the effective date of this permit, the Permittee shall: a) Submit an approvable design and request for an Authorization to Construct to extend its existing outfall to the mainstem of Contentnea Creek, and b) Upon issuance of the Authorization to Construct, construct and activate the approved extension. 2 of 2 DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0025712 Facility Information Applicant/Facility Name: Town of Hookerton WWTP Applicant Address: P.O. Box 296 Hookerton, NC 28538 Facility Address: Highway 123 north of Hookerton, NC Permitted Flow 0.060 MGD Type of Waste: 100% Domestic Facility/Permit Status: Renewal Facility Classification I County: Greene Miscellaneous Receiving Stream: Contentnea Creek Regional Office: Washington Stream Classification: C Sw NSW USGS Topo Quad: F28NE 303(d) Listed?: Yes Permit Writer: Jackie Nowell Subbasin: 03-04-07 Date: April 3, 2000 Drainage Area (mi2): 733 AlliillirP Summer 7Q 10 (cfs) 31 Winter 7Q10 (cfs): Average Flow (cfs): IWC (%): Primary SIC Code: 4952 SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION The Town of Hookerton WWTP has requested renewal of existing permit. Facility is a 0.060 MGD plant that discharges into the Contentnea Creek. The receiving stream is classified C Swamp NSW. There are segments of Contentnea Creek above the Hookerton WWTP that are listed on the DWQ draft 2000 303d list. The segment is from the dam at Wilson Water Supply to NC 58, Wilson County. The problem parameters are DO and sediment. Existing limits are BOD5= 30 mg/1, NH3 monitoring, TSS =90 mg/1, Fecal = 200/ 100m1, quarterly monitoring of TN and TP. Hookerton is currently under Special Order by Consent (SOC) for the parameters of BOD5 and TSS. The SOC was requested in Feb. 1997, the Town paid an upfront penalty of $3000 and the Order was signed March 31, 1999. The Town is to achieve compliance with all final permit effluent limitations on or before May 1, 2001. The SOC expires August 1, 2001. Correspondence in Sept. 1999 - Hookerton is requesting a grant from the Clean Water Management Trust Fund for the innovative technology of using duckweed as a treatment process. "The Town was included in a grant application to the Office of State Construction that would have provided funds to construct a lift station and force main from the facility to a new regional treatment system in the Town of Snow Hill. This grant application was denied. Thus, there are no other alternative currently being considered that would bring Hookerton into compliance." — correspondence to Roger Thorpe, WaRO from W. Patrick Rushing, PE, Civil Group Leader, The East Group 4/6/2000 - Telecon with Ray Carlton of Clean Water Management Trust Fund (CWMTF). The Trustees have tentatively agreed on the grant for Hookerton. They have negotiated an agreement with Hookerton and have sent it to them. The Town is in the process of reviewing it and the Town Council has said they would sign the agreement. When CWMTF receives it back, it will be signed. This facility's discharge is located in the Neuse River Basin, in which all streams have been designated as nutrient sensitive waters (NSW) as a result of algal bloom problems in the estuary. The North Carolina Environmental Management Commission recently adopted rules establishing the Neuse River Basin Nutrient Sensitive Waters Management Strategy for the reduction of phosphorus and nitrogen inputs. The point source rule (15A NCAC 2B .0234) is 1-lookerion WWTP Pact Sheet NPDES Renewal Pn:, tF• intended to reduce total nitrogen (TN) discharges by 30% by 2003. It specifies that individually permitted wastewater discharges to the Neuse River Basin with permitted flows less than 0.5 MGD in 1995 shall be allocated a collective annual mass load of 155,400 pounds/year of total nitrogen. This is equivalent to an allocation in the range of 5 - 10 mg/1 TN for each small discharger. Although no total nitrogen limits appear in the permit at this time, Hookerton may be subject to nitrogen limits in the next permitting cycle. All facilities with permitted flow greater than or equal to 0.5 MGD are receiving a TN limit in this permit cycle. The Division recommends that Hookerton evaluate the cost of installation for nutrient removal facilities in the event that a nutrient limit is imposed. It is also recommended that alternative discharge options be evaluated such as such as spray irrigation, subsurface systems, wastewater reuse, or connection to a larger regional system. TOXICITY TESTING: Current Requirement: None — 100 % domestic wastewater COMPLIANCE SUMMARY: In 1999, Hookerton WWTP had one permit exceedance with flow at 0.3773 MGD in January 1999. The averages between February 1999 and January 2000 were Qw = 0.023 MGD, BODS =24.17 mg/1, TSS = 52 mg/1, NH3 = 0.94 mg/1, TN = 8.5 mg/1, TP = 1.46 mg/1. There were consistent violations of the pH limit (nine (9) exceedances). The ranges were from 6.5 - 10.3 SU. In 1998, Qw averaged 0.0521 MGD, BOD= 24.27 mg/1, TSS = 57.3 mg/1, NH3 = 0.91 mg/1, TN = 3.98 mg/1, TP = 1.43 mg/1. One fecal coliform violation in Sept. 1998 In 1997, Qw averaged 0.0284 MGD, BOD= 30.5 mg/1, TSS = 95.7 mg/1), NH3 = 0.21 mg/1, TP = 1.73 mg/I. In 1996, Qw averaged 0.0309 MGD (one exceedance), BOD= 26.08 mg/1 (four exceedances), TSS = 46.9 mg/1, NH3 = 1.14 mg/1, TN = 2.93 mg/1, TP = 1.10 mg/1. In 1995, Qw averaged 0.0241 MGD (one exceedance), BOD= 20.29 mg/1, TSS = 28.8 mg/1, NH3 = 1.35 mg/1, TN = 2.61 mg/1, TP = 2.38 mg/1. INSTREAM MONITORING: April - October 1999 - Note that Hurricane Floyd did tremendous damage in September by flooding the lagoons. This probably contributed to the poor water quality in Contentnea Creek in the month to follow. DO values from July 1999 to October 1999 averaged <5 mg/1 both upstream and downstream of the facility. April - October 1998 - DO values from July 1998 to September 1998 averaged <4.6 mg/1 both upstream and downstream of the facility. The DO values in other months are satisfactory. April - October 1997 - Overall DO from this period was good however in September and October, upstream and downstream values averaged approximately 4.5 mg/1. The other months ranged from 5.3 -7.8 mg/1 upstream and 5.4 - 7.7 downstream. Upstream and downstream fecal conform values were <200/ 100m1 except for downstream in Sept. 1997. Recommend continued instream monitoring for temperature, dissolved oxygen and conductivity. Inclusion of conductivity monitoring recommended by TMDL/Modeling Unit to be used in future modeling for Contentnea Creek. Upstream at Highway 13/258, Downstream at Highway 123 PROPOSED CHANGES: The following modifications have been made to the permit: • Quarterly monitoring for TN and TP will be modified to 2/month. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: Permit Scheduled to Issue: I-iookerton WWTP Fact. Sheet NPDES Renewal Pa cif, 9 Permit Notes NC0025712 Page 4 Alternatives are: A) Spray irrigation alternative uses Hookerton's lagoons with pump stations sending to the storage lagoon (21MG) at the spray irrigation site (250 acres). Snow Hill proposes to build an 18-MG lagoon and pump to the storage lagoon for disposal. Twenty- year worth of alternative is $6.7 M. B) Expansion of WWTP with the oxidation ditch consists of building a new plant at the Snow Hill WWTP. Hookerton would pump its wastewater to Snow Hill for treatment and disposal. After the new plant is constructed, the old plant would be modified for sludge treatment and storage. The expansion capacity is for 0.700 MGD. Twenty-year worth of this alternative is $4.2 M. WARO indicates that the expansion plan is the most cost effective and would meet the prospective needs of the Towns of Snow Hill and Hookerton. Snow Hill plant would go from 0.500 MGD to 0.700 MGD and would have to reapply for permit at the higher wasteflow. 8/4/1997 — NOV for BOD, TSS 7/7/1997 — NOV for BOD, TSS 6/16/1997 - NOV for BOD 6/3/1997 - Draft SOC for Hookerton. BOD5 at 45 mg/1 is the only parameter included. No upfront penalty is being requested by DWQ. 5/16/1997 - NOV for BOD 5/9/1997 — Instream Assessment for SOC request. Recommended that lowest possible achievable BOD5 limits are given in the SOC. The swampy, slow moving, low flow stream cannot be evaluated with a steady state one-dimensional model. The traditional modeling tools currently available cannot replicate Contentnea Creek and more sophisticated modeling approaches need to be researched. 4/17/1997 — SOC request for fast track penalty work sheet, which would include a calculated upfront penalty, based on violations for 4 BOD exceedances from 31-36 mg/l. 3/27/1997 — Request for In -stream assessment for 67(b) analysis for BOD5 and TSS 2/26/1997 — Application for a Special Order by Consent from the Town of Hookerton 2/17/1997 - NOV for BOD Instream Data April — October 1999 — Note that Hurricane Floyd did tremendous damage in September by flooding the lagoons. This probably contributed to the poor water quality in Contentnea Creek in the month to follow. DO values from July 1999 to October 1999 averaged <5 mg/1 both upstream and downstream of the facility. April — October 1998 - DO values from July 1998 to September 1998 averaged <4.6 mg/1 both upstream and downstream of the facility. The DO values in other months are satisfactory. Permit Notes NC0025712 Page 5 April — October 1997 — Overall DO from this period was good however in September and October, upstream and downstream values averaged approximately 4.5 mg/1. The other months ranged from 5.3 —7.8 mg/1 upstream and 5.4 — 7.7 downstream. Upstream and downstream fecal coliform values were <200/100m1 except for downstream in Sept. 1997. Recommend continued instream monitoring for temperature, dissolved oxygen and conductivity. Inclusion of conductivity monitoring recommended by TMDIlModeling Unit. Upstream at Highway 13/258, Downstream at Highway 123 The following language will be placed in Hookerton's draft cover letter: This facility's discharge is located in the Neuse River Basin, in which all streams have been designated as nutrient sensitive waters (NSW) as a result of algal bloom problems in the estuary. The North Carolina Environmental Management Commission recently adopted rules establishing the Neuse River Basin Nutrient Sensitive Waters Management Strategy for the reduction of phosphorus and nitrogen inputs. The point source rule (15A NCAC 2B .0234) is intended to reduce total nitrogen (TN) discharges by 30% by 2003. It specifies that individually permitted wastewater discharges to the Neuse River Basin with permitted flows less than 0.5 MGD in 1995 shall be allocated a collective annual mass load of 155,400 pounds/year of total nitrogen. This is equivalent to an allocation in the range of 5 — 10 mg/1 TN for each small discharger. Although no total nitrogen limits appear in the permit at this time, Hookerton may be subject to nitrogen limits in the next permitting cycle. All facilities with permitted flow greater than or equal to 0.5 MGD are receiving a TN limit in this permit cycle. The Division recommends that Hookerton evaluate the cost of installation for nutrient removal facilities in the event that a nutrient limit is imposed. It is also recommended that alternative discharge options be evaluated such as such as spray irrigation, subsurface systems, wastewater reuse, or connection to a larger regional system. Recommend renewal of existing NPDES limits with some changes. There will be some modification to the permit based on the Neuse Management strategy. • Quarterly monitoring for TN and TP will be modified to 2/month. Permit Notes NC0025712 Background The Town of Hookerton WWTP has requested renewal of existing permit. Facility is a 0.060 MGD plant that discharges into the Contentnea Creek. The receiving stream is classified C Swamp NSW. There are segments of Contentnea Creek above the Hookerton WWTP that are listed on the DWQ draft 2000 303d list. The segment is from the dam at Wilson Water Supply to NC 58, Wilson County. The problem parameters are DO and sediment. Existing limits are BOD5= 30 mg/l, NH3 monitoring, TSS =90 mg/1, Fecal = 200/100m1, quarterly monitoring of TN and TP. Hookerton is currently under Special Order by Consent (SOC) for the parameters of BOD5 and TSS. The SOC was requested in Feb. 1997, the Town paid an upfront penalty of $3000 and the Order was signed March 31, 1999. The Town is to achieve compliance with all final permit effluent limitations on or before May 1, 2001. The SOC expires August 1, 2001. Correspondence in Sept. 1999 - Hookerton is requesting a grant from the Clean Water Management Trust Fund for the innovative technology of using duckweed as a treatment process. "The Town was included in a grant application to the Office of State Construction that would have provided funds to construct a lift station and force main from the facility to a new regional treatment system in the Town of Snow Hill. This grant application was denied. Thus, there are no other alternative currently being considered that would bring Hookerton into compliance." — correspondence to Roger Thorpe, WaRO from W. Patrick Rushing, PE, Civil Group Leader, The East Group 4/6/2000 - Telecon with Ray Carlton of Clean Water Management Trust Fund (CWMTF). The Trustees have tentatively agreed on the grant for Hookerton. They have negotiated an agreement with Hookerton and have sent it to them. The Town is in the process of reviewing it and the Town Council has said they would sign the agreement. When CWMTF receives it back, it will be signed. The grant will be for $790,000. There are five milestones in the grant and are as follows: 1. Complete engineering and design 5/20/2000 2. DENR reviewed completed 10/21/2000 3. Award the Construction Grant within 60 days (after review completion) 4. Construction done in 180 days 5. Startup in 45 days Review of Compliance Data In 1999, Hookerton WWTP had one permit exceedance with flow at 0.3773 MGD in January 1999. The averages between February 1999 and January 2000 were Qw = 0.023 MGD, BOD5 =24.17 mg/1, TSS = 52 mg/1, NH3 = 0.94 mg/1, TN = 8.5 mg/1, TP = 1.46 mg/1. There were consistent violations of the pH limit (nine (9) exceedances). The ranges were from 6.5 — 10.3 SU. In 1998, Qw averaged 0.0521 MGD, BOD= 24.27 mg/1, TSS = 57.3 mg/1, NH3 = 0.91 mg/1, TN = 3.98 mg/1, TP = 1.43 mg/1. One fecal coliform violation in Sept. 1998 Permit Notes NC0025712 Page 2 In 1997, Qw averaged 0.0284 MGD, BOD= 30.5 mg/1, TSS = 95.7 mg/1), NH3 = 0.21 mg/1, TP =1.73 mg/1. In 1996, Qw averaged 0.0309 MGD (one exceedance), BOD= 26.08 mg/1 (four exceedances), TSS = 46.9 mg/1, NH3 = 1.14 mg/1, TN = 2.93 mg/1, TP = 1.10 mg/1. In 1995, Qw averaged 0.0241 MGD (one exceedance), BOD= 20.29 mg/1, TSS = 28.8 mg/1, NH3 = 1.35 mg/1, TN = 2.61 mg/1, TP = 2.38 mg/1. Correspondence File 8/18/99 — June 1999 DMR was not received. 6/11/99 — NOV - Review of the March 1999 self -monitoring report showed violations for BOD5 and pH. 4/4/99 — Sent copy of signed SOC to Town of Hookerton, signed by Stevens on 3/31/99 2/2/99 — received upfront penalty payment of $3000 from Hookerton 2/16/99 — Letter to Town from WaRO about their consideration of permitting a duckweed treatment process. Information needed includes plans and specs for all proposed units, data showing that the proposed facilities can meet permit limits, proposal for handling duckweed and a disposal method if no market for sale, and an alternatives analysis. 1/8/99 — SOC for review and signature by the Town. 11/2/98 — NOV for illegal discharge, sewer line break that was severed due to erosion of the foundation and dumping fill material onto the line. Line temporarily repaired but lost 45,000 gallons of wastewater into Contentnea Creek. Civil penalty may be assessed. Town must show plan of action to permanently repair the line. 10/20/98 — Technical assistance visit to identify operational and design problems contributing to facility's compliance. • Three lagoon system in series. Lagoons 1 & 2 are the proper green color, no problems noted. Lagoon three darker green and more solid material visible caused by increase in alga growth in lagoon three. • Better aeration in lagoon three may prevent more alga growth. • Information on a product approved to control algae. • Chlorine had been used in the past to control algae but concerns about toxicity, ended its use. Technical Assistance/WaRO will review a plan for chlorination/dechlorination of the final lagoon to help Hookerton. 10/1/98 — Draft SOC for Town of Hookerton from WaRO to Point Source Compliance Unit 9/24/98 - Notice of non-compliance during compliance evaluation inspection. • All three lagoons were full of blue-green algae • Aerator in the third lagoon seemed to be making a difference in controlling algae growth • Bank erosion between the 2' and 3rd lagoon because of high flows last winter • Effluent flow meter not in place. New meter installed on the influent should be moved back to the effluent ASAP. Permit Notes NC0025712 Page 3 • Lack of daily effluent flow monitoring • Lack of pH monitoring Plant Inspection Ratings (9/15/98) 1) Flow Measurement - Unsatisfactory 2) Self Monitoring Program — Unsatisfactory 3) Effluent/Receiving Water - Marginal Overall Rating of the Facility - Marginal 9/18/98 — Staff Report, recommended removal of chlorine monitoring since there was no chlorination at the WWTP. Requested that aerator in the third lagoon be added to the description of the plant. 9/11/98 — Letter from NPDES addressing Hookerton's proposal to connect to the Maury Sanitary District. Town had questions about the potential for nitrogen limits for Maury after the consolidation and Hookerton's mass loading being allocated to Maury. 2/23/98 — NOV for TSS, 91 mg/1 reported, 90 mg/1 limit 1/15/98 - Compliance Evaluation Inspection • Screening collected at the head of the plant are buried on site • Existing aerator in the third lagoon in no in use. Not served its function of reducing the algae floc in the lagoon. • The third lagoon is overtaken with algae • Effluent flow meter has been inoperative since August • Effluent is full of blue-green algae, discharge is a greenish hue • Effluent is consistently out of compliance, after a review of the DMRs • Plant grounds are generally well maintained. Plant Inspection Ratings (1/9/98) 1) Flow Measurement - Unsatisfactory 2) Self Monitoring Program — Unsatisfactory 3) Effluent/Receiving Water - Unsatisfactory Overall Rating of the Facility - Marginal 12/2/1997 — NOV for TSS 8/25/1997 — NOV for BOD, TSS 8/20/1997 — 201 Facilities Plan for Towns of Snow Hill and Hookerton. Reviews several alternatives. Snow Hill has a dual unit 0.250-MGD contact stabilization facility with effluent chlorination. Hookerton has a three -stage lagoon system. Towns looking at upgrading their facilities by having a regional system. Re: Status of CWMTF Grant for Hookerton Subject: Re: Status of CWMTF Grant for Hookerton Date: Fri, 07 Apr 2000 13:03:42 -0400 From: Coleen Sullins <Coleen.Sullins@ncmail.net> To: Jackie Nowell <jackie.nowell@ncmail.net> CC: Bill Reid <Bill.Reid@ncmail.net>, Dave Goodrich <Dave.Goodrich@ncmail.net> Interesting schedule. Typically these projects would come to WQ if there is no SRF or bond money. Is there SRF or bond funding? Has Bobby agreed to review, do you know? How about touching base with him. Thanks Coleen Jackie Nowell wrote: Coleen, I talked with Ray Carlton of the CWMTF this afternoon and he asked me to relay this information to you. The Trustees have tentatively agreed on the grant for Hookerton and the innovative technology using duckweed as a treatment process. They have negotiated an agreement with Hookerton and have forwarded it to them. The Town is in the process of reviewing it and the Town Council has said they would sign the agreement. Mr. Carlton anticipates getting it back very soon. Upon receipt by CWMTF, it will be signed. The grant will be for $790, 000. There are five milestones in the grant and are as follows: 1. Complete engineering and design 2. DENR review (by Construction Grants) 10/21/2000 3. Award the construction grant within 60 4. Construction done in 180 days 5. Startup in 45 days 5/20/2000 completed days (after review completion) I of I 4/7/00 4:16 PM SEAST AJC1lO57/ 1- . E;,,-„,, , :. , , : • E-ir,j'I' .':I,,,, :4 :, P,1ye' iIttr)'. September 3, 1999 Mr. Roger K. Thorpe Division of Water Quality North Carolina Department of Environment and Natural Resources 943 Washington Square Mall ?g7,1)0 NC 27889.$i,�'`.,�'"'.. t:„40- SEP Re: Town of Hookerton Wastewater Treatment Facility Modification Preliminary Design Plans Greene County Dear Mr. Thorpe: 1 4 1999 Enclosed please find two copies of preliminary design plans for the Town of Hookerton Wastewater Treatment Facility Modification as well as two copies of Major Process Calculations. The intent of this submittal is to receive a favorable review of the innovative technologies utilized in this process such that the Town's grant application to the Clean Water Management Trust Fund (CWMT) may be considered. The Town is not requesting a detailed review of these plans at this time. If this project is approved and funded by the Clean Water Management Trust, final construction plans, specifications, detailed calculations, a preliminary engineering report, and permit application will be submitted to the Division for approval. We are including herein a synopsis of the proposed treatment process along with a sampling of published research papers that document the utilization of duckweed as a successful wastewater treatment vehicle. Please note that this process is the essence of the proposed modification. The Town requests that the Division provide a favorable review of these technologies at this time. Final plans detailing typical treatment facility components should not be required by the Division to make this determination. Existing Facility The Town of Hookerton currently utilizes a lagoon system that exceeds permitted standards for biochemical oxygen demand (BOD) and total suspended solids (TSS) during summer months. These limits are 30 mg/I and 90 mg/I, respectively. There are currently no limits on nitrogen and phosphorus. The Town was included in a grant application to the Office of State Construction that would have provided funds to construct a lift station and force main from the facility to a new regional treatment system in the Town of Snow Hill. This grant application was denied. Thus, there are no other alternatives currently being considered that would bring the Hookerton facility into compliance. Proposed Improvements The Town proposes to pump effluent from the first lagoon of the existing treatment system into header that will feed thirteen concrete nutrient -removal basins. Nutrient removal will be accomplished through a continuous process of growing and harvesting aquatic plants from the botanical family Lemnaceae, commonly known as duckweed. The concrete basins will be covered with a standard greenhouse structure that will allow sunlight to penetrate but prohibit wind from reaching the water surface. Research indicates that approximately 10 to 14 days of retention is required to reach complete treatment. The system as designed allows for 18.2 days of retention at a flow rate of 40,000 gallons per day. The duckweed is harvested every two days, or as conditions warrant. The harvested duckweed is pumped to a collection tank as indicated on the enclosed drawings. Supernatant is returned to the influent header. The harvested duckweed is periodically removed from the collection tank as needed. The duckweed, which is essentially protein, has any number of beneficial uses. The duckweed has essentially converted the available >t nutrients into cell mass. Unlike algae, the nutrients will not be re-released into the water column. Thus, the duckweed poses no threat to the environment regardless of its ultimate use. After the wastewater stream passes through the nutrient removal basins that contain the duckweed, it will be routed through a sand filter to remove any remaining suspended particulate matter. The TSS concentration entering the sand filter will be less than 30 mg/I; the TSS concentration exiting the sand filter will be less than 8 mg/I. Note that the current discharge permit for TSS is 90 mg/I. Ultraviolet disinfection is the final unit operation proposed in the Town's Wastewater Treatment Modification project. Dual in -line systems will be used such that either may be out of service at any time without losing service. There is not a disinfection system currently in use at the Hookerton facility. Effluent from the disinfection system will flow into a recirculation/effluent pump station. This pump station will serve several purposes. First, the pump station will allow operators to dilute influent of any strength to optimal levels. Second, the pump station will provide cooling water to the greenhouse systems to maintain optimal crop viability. Third, the pump station will discharge treated effluent of the highest quality. This discharge will be directed into the second anaerobic lagoon at the Hookerton facility. Thus, no existing treatment process currently in use will be bypassed. A discharge line from the effluent pump station to Contentnea Creek will be installed during this modification. Please note that this line will be closed and will not be utilized without the express written consent of the Division. The Town of Hookerton intends to demonstrate that effluent from the nutrient removal system is treated to a much higher standard than effluent from the existing system. Further, the Town will demonstrate that discharge back into the second and third lagoons actually degrades water quality. At that time, the Town will apply for a modification to its NPDES Permit that would allow direct discharge into Contentnea Creek. Again, a formal Construction Permit Application package will be submitted contingent upon receipt of a grant from the North Carolina Clean Water Management Trust Fund. A prerequisite for CWMTF funding is support from the Division of Water Quality for the proposed treatment facility modification. The Town, in its quest to ultimately adhere to the most stringent discharge limits imposed in the State of North Carolina, enthusiastically solicits and welcomes this support. Sincerely, The East Group W. Patrick Rushing, PE Civil Group Leader Enclosures cc: Mr. Bill Holman, NCDENR Mr. Dewey Botts, NCDENR Mr. Tommie Stevens, NCDENR Mr. Rolf Blizzard Ms. Treva Matthews, Town of Hookerton Ms. Sarah Head, Town of Hookerton Mr. Steve Bevington, NC Clean Water Management Trust Fund Mr. Paul Skillicorn To: Permits and Engineering Unit Water Quality Section Attn: Charles Weaver Date: September 18, 1998 SOC Priority Project: Yes No X If "Yes", SOC No. NPDES STAFF REPORT AND RECOMMENDATION Greene County Permit No. NC0025712 PART I - GENERAL INFORMATION c; c cn ..O :_il t:5110 , LAG 1. Facility and Address: Town of Hookerton WWTP 13r P.O. Box 296 nz. Hookerton, NC 28538 cJ_1 Physical address; S.R. 123 N Hookerton, NC 28538 2. Date of Investigation: Site Visit -September 15, 1998 3. Report Prepared by: Brad Shaver .00:4-/rivfiN 4. Persons Contacted and Telephone Number: Cecil Taylor (ORC) �+ (252) 747-3816 5. Directions to Site: The facility is located approximately 0.5 miles north of Town off of Highway 123. The facility is down a dirt road on the left side of the highway. 6. Discharge Point(s); List for all discharge points: Latitude: 35025'42" N Longitude: 77035'35" W Attach USGS map extract and indicate treatment facility site and discharge point on map. USGS Quad No. USGS Quad Name: Hookerton 7. Site size and expansion area consistent with application? Yes X No If "No", explain: 8. Topography (relationship to flood pain included): Lagoons are situated out of the 100'year flood plain. 9. Location of nearest dwelling: The nearest dwelling is 0.5 miles on the other side of Contentnea Creek. 10. Receiving stream or affected surface waters: Contentnea Creek a. Classification: Class C-Swamp, NSW b. River Basin and Sub -basin No. 03-04-07 c. Describe receiving stream features and pertinent downstream uses: Recreational fishing and fish propagation. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of Wastewater to be Permitted: 0.06 MGD b. Current Permitted Capacity: 0.06 MGD c. Actual Treatment Capacity: 0.06 MGD d. Date(s) and construction allowed by Authorizations to Construct issued past two years: N/A e. Description of existing or substantially constructed wastewater treatment facilities: The existing treatment works consists of an influent bar screen and three lagoons with adjustable effluent baffles, and there is a small aerator in the third cell. f. Description of proposed wastewater treatment facilities: Hookerton is seeking an SOC and ultimately wants to pump their waste to a regional treatment facility. It is Hookerton's desire to remove themselves from the wastewater business. g• Possible toxic impacts to surface waters: N/A h. Pretreatment Program (POTWs only): In development Should be required Approved Not needed X 2. Residuals Handling and Utilization Disposal Scheme: N/A a. If residuals are being land applied, specify DEM permit number: Residuals Contractor: Telephone Number: b. Residuals Stabilization: PSRP PFRP Other c. Landfill: d. Other disposal/utilization scheme (specify): The lagoon system consumes the sludge, it is not pumped out of the lagoons. 3. Treatment Plant Classification (attach completed rating sheet)7 I 4. SIC Code(s): 4952 Wastewater Code(s): 01 Main Treatment Unit Code: 300 4 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? No 2. Special monitoring or limitations (including toxicity) requests: N/A 3. Important SOC, JOC, or Compliance Schedule dates (indicate): N?A Activity Date Submission of Plans and Specifications Begin Construction Complete Construction 4. Alternatives Analysis Evaluation: Has the facility evaluated all of the non -discharge options available? Provide Regional perspective for each option evaluated. Spray Irrigation: area not available Connection to Regional Sewer System: Facility acts as regional system. Subsurface Disposal: Not practical based on flow. Other Disposal Options: None 5. Other Special Items: None PART IV - EVALUATION AND RECOMMENDATIONS Hookerton's current permit requires the Town to take residual chlorine samples 2/week. Hookerton does not have the capabilities or equipment to chlorinate their effluent. Since there is no chlorination at the wastewater treatment facility the residual chlorine monitoring should be eliminated from the new permit. Please add the aerator, which is facility section, to the new permit. highlighted in the existing treatment It is recommended that the permit be in the third cell. reissued with the addition of the aerator Signature of report preparer �c sir Wa er Quality Re tonal Supervisor Date 'Tatra of Roolltrion . (O. Sox 296 rlaukrrtnit, . I. 28538 Input 747-3816 September 17, 1998 UD CO rn -10 Mr. Charles H. Weaver, Jr. NPDES Unit N `- %' NCDENR C» y, rn r: P.O. Box 29535 7.ccrEED Raleigh, N.C. 27626-0535 O .t' c.n 0— cn S Subject: Dear Mr. Weaver: NPEDES Permit Renewal Application Sludge Management Permit NC0025712 Hookerton WWTP Greene County This letter is in response to your letter dated August 27, 1998 requesting a description of the sludge management practices at the Hookerton WWTP. The Hookerton WWTP is a 3 cell lagoon system in which all sludge is contained within and does not need any sludge management. If any additional information is needed, please feel free to call me. Cecil E. Taylor, Utility Director • State of North Carolina Department of Environment and Natural Resources Division of Water Quality James Bi Hunt, -Jr., Governor Wayne McDevitt; Secretary A. Preston Howard, Jr. P.E., Director Ms. Treva Matthews, Mayor Town of Hookerton P.O. Box 296 Hookerton, North Carolina 28538• N:;DENR September 11, 1998 Subject: NPDES Permit Modification Permit No. NC0025712 Town of Hookerton WWTP Greene County Dear Mayor Matthews: Please accept my apology for the delay in responding to your questions regarding the proposal to connect your existing wastewater treatment plant to the facility owned and operated by Maury Sanitary District (NPDES Permit No. NC0061492). The Division believes that the consolidation of these two plants will be beneficial to the environment and is ready to assist you in this endeavor to the extent possible. Specifically, you asked two questions regarding the changes in the permit conditions for Maury's wastewater treatment plant: • Will any expansion at Maury's facility result in a limit for nitrogen? • ; Can the mass loading allocated to Hookerton be transferred to Maury's permit upon consolidation of the two plants? Based on a review of 15A NCAC 2B .0234 (Neuse River Basin — Nutrient Sensitive Waters Management Strategy: Wastewater Discharge Requirements), facilities which hold permits prior...to.December 31, 1995 are considered existing wastewater discharge : Th' flowsrefore, a lunit would not immediately be placed in Maury Sanitary District's NPDES permit upon combination of these two wastewater treatment systems, ` provided '-`that; Maury'?pernutted flow remains less than 0.5' milliongallons per day (MGD). However,:, it should be noted that all discharges in the Neuse River basin which are permitted at flows less than 0.5 MGD have been allocated an aggregate annual total nitrogen load of 280,000 pounds. If the collective loading from these facilities approaches or exceeds this amount during the next permit term, then limits for total nitrogen will likely be placed in NPDES permits in 2003. Therefore, it is recommended that Maury Sanitary District examine the potential for operating their existing plant for optimal removal of nitrogen and phosphorus. This would be an especially important consideration for any future system design changes. Although neither plant has limits for total nitrogen at present, combining the plants would have the effect of increasing Maury's future allocation by Hookerton's "share" of the allowable load if limits are given in NPDES permits for all facilities less than 0.5 MGD. P.O. Box 29535, Raleigh, North Carolina 27626-0535 An Equal Opportunity Affirmative Action Employer Telephone 919-733-5083 FAX 919-733-0719 50% recycled/ 10% post -consumer paper In all likelihood, the distribution of the aggregate allocation for these smaller facilities would be similar to the allocations given to the larger facilities in the Neuse River basin. That is, each discharge may be required to meet the same concentration limits for total nitrogen based on permitted flow. (It should be noted, however, that it is unlikely that concentration limits as low as those given to the larger discharges would be required of the smaller facilities.) As a result of the uncertainty regarding the potential for limits in future permits, I realize that this is a complicated situation and would be happy to meet with you and representatives of the Maury Sanitary District if you would like. Given the tight time frames associated with your potential funding, I will make every effort to schedule such a meeting as soon as you request one. Since I will not be in the office the week of September 14`h, you may direct your inquiries to Mr. Mike Templeton at (919)-733-5083, extension 541. I will return on September 21, 1998 and can be reached at the same phone number, extension 517. Respectfully,ul9/776,(14--" .ds David A. Goodrich NPDES Unit Supervisor cc: Central Files Washington Regional Office, Water Quality NPDES Unit, Permit Files (Hookerton and Maury Sanitary District) Coleen Sullins Preston Howard Mike Templeton Jill Hickey Ruth Swanek