NC0047562_Speculative Limits_20170424

N1Z
Water Resources
ENVIRONMENTAL. QUALITY
Johnathan Blanton, City Manager
City of Hamlet
201 West Main St.
PO Box 1229
Hamlet, North Carolina 28345
Dear Mr. Blanton:
/v9O f' �(
April 24, 2017
ROY COOPER
Goventor
MICHAEL S. REGAN
Secrermr
S. JAY ZIMMERMAN
Director
Subject: Speculative Effluent Limits
Hamlet WWTP
Permit No. NC0047562
Richmond County
Yadkin -Pee Dee River Basin
This letter provides speculative effluent limits for 2 million gallons per day (MGD) and 3 MGD
at the Hamlet WWTP. The Division received the speculative limits request in a letter dated
October 3, 2016 from Marcus Abernethy former City Manager. Please recognize that
speculative limits may change based on future water quality initiatives such as establishment of
nutrient criteria or nutrient management strategies. It is highly recommended that the applicant
verify the speculative limits with the Division's NPDES Unit prior to any engineering design
work.
Receiving Stream. Marks Creek is located within the Yadkin -Pee Dee River Basin. Marks
Creek has a stream classification of C, and waters with this classification have a best usage
for aquatic life propagation and maintenance of biological integrity, wildlife, secondary
recreation and agriculture. Marks Creek has a summer 7Q10 flow of 2.5 (cubic feet per
second) cfs, a winter 7Q10 flow of 6.4 cfs, and an annual average flow of 15 cfs.
Marks Creek is currently listed as an impaired waterbody on the 2016 North Carolina 303(d)
Impaired Waters List for biological integrity. There are no specific permitting strategies for
Marks Creek in the Yadkin -Pee Dee River Basinwide Water Quality Plan. Marks Creek
ultimately drains into the Pee Dee River in South Carolina.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are Federally Listed aquatic species of concern
identified within a 5-mile radius of the proposed discharge location. If there are any
identified threatened/endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge location might impact such species.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 707 9000

Speculative Effluent Limits. Based on Division review of receiving stream conditions and
water quality modeling results, speculative limits for the proposed expansion to 2 MGD and
3 MGD are presented in Tables 1 and 2, respectively. A complete evaluation of these limits
and monitoring requirements for metals and other toxicants, as well as potential instream
monitoring requirements, will be addressed upon receipt of a formal NPDES permit
application. Some features of the speculative limit development include the following:
• BOD/NH3 Limits. Given the low instream dissolved oxygen levels reported in
Marks Creek, and impairment for biological integrity, these speculative limits are
based on freezing current permitted BOD ultimate loading (i.e., facility will not be
allowed to discharge oxygen -consuming waste above what is currently permitted).
The resultant limits at expanded flows are considered technologically -feasible.
• Ammonia limits are based on the criteria of 1.0 mg/L for summer and 1.8 mg/L for
winter.
TABLE 1. Speculative Limits for City of Hamlet WWTP (Proposed Expansion to 2 MGD)
Effluent Characteristic
Effluent Limitations
Monthly
Average _
Weekly
Average
Daily
Maximum
Flow
2.0 MGD
BOD5
(April 1-October 31)
12.0 mg/L
18.0 mg/L
BOD5
(November 1-March 31)
15.0 mg/L
22.5 mg/L
NH3 as N
(April 1-October 31)
1.6 mg/L
4.8 mg/L
NH3 as N
(November 1-March 31)
5.1 mg/L
15.3 mg/L
Dissolved Oxygen
(minimum)
5.0 mg/ L
TSS
30 mg/L
45 mg/L
TRC
28 µg/I
Fecal coliform (geometric
mean)
200/100 ml
400/100 ml
Total Phosphorus
Total Nitrogen
Chronic Toxicity Pass/Fail
(Quarterly test)
55%

TABLE 2. Sveculative Limits for City of Hamlet WWT'P (Proposed Expansion to 3 MG
Effluent Characteristic
Effluent Limitations
Monthly
Average
Weekly
,Average
Daily
MaxiMum
Flow
3.0 MGD
BOD5
(Apri11-October 31)
8.0 mg/L
12.0 mg/L
BOD5
(November 1-March 31)
10.0 mg/L
15.0 mg/L
NH3 as N
(April 1-October 31)
1.4 mg/L
4.2 mg/L
NH3 as N
(November 1-March 31)
4.0 mg/L
12.0 mg/L
Dissolved Oxygen
(minimum)
z5.0 mg/L
TSS
30 mg/L
45 mg/L
TRC
26 µg/1
Fecal coliform (geometric
mean)
200/100 ml
400/100 ml
Total Phosphorus
Total Nitrogen
Chronic Toxicity Pass/Fail
(Quarterly test)
65%
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee
that an NPDES permit for a new or expanding discharge will be issued with these
speculative limits. Final decisions can only be made after the Division receives and
evaluates a formal permit application for the new/expanded discharge. In accordance with
North Carolina Administrative Code 15A NCAC 2H.0105(c), the most environmentally
sound alternative should be selected from all reasonably cost effective options. Therefore,
as a component of all NPDES permit applications for new or expanding flow, a detailed
engineering alternatives analysis (EAA) must be prepared. The EAA must justify requested
flows and provide an analysis of potential wastewater treatment alternatives. A copy of the
Division guidance for preparing EAA documents is attached.
State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document
may be required for projects that: 1) involve $10 Million or more of state funds; or 2) will
significantly and permanently impact 10 or more acres of public lands. Please check with
the DWR SEPA coordinator (David Wainwright, 919-807-6442) as to whether your project
requires SEPA review. For projects that are subject to SEPA, the EAA requirements
discussed above will need to be folded into the SEPA document. Additionally, if subject to
SEPA, the NPDES Unit will not accept an NPDES permit application for a new/expanding
discharge until the Division has approved the SEPA document and sent a Finding of No
Significant Impact (FONSI) to the State Clearinghouse for review and comment.

Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact David Hill at [phone] or Julie Grzyb at (919)
807-6390.
Respectfully,
.14:k d'•
e Grzyb
pervisor, NPDES Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
Central Files
NPDES Permit File
Electronic Copy:
NC WRC, Inland Fisheries, shannon.deaton@ncwildlife org
US Fish and Wildlife Service, [e-mail]
DWR/Water Quality Fayetteville Regional Office
DWR/Basinwide Planning, Ian McMillan
DWR/NPDES Server>Specs

NH3/TRC WLA Calculations
Facility:Hamlet WWTP
PermitNo. NC0047562
Prepared By: David Hill
Enter Design Flow (MGD): 2
Enter s7Q10 (cfs): 2.5
Enter w7Q10 (cfs): 6.4
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/l)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/l)
IWC (%)
Allowable Conc. (ug/l)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
2.5
2
3.1
17.0
0
55.36
31
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mgll)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
1.81 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/l)
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I
2.5
2
3.1
1.0
0.22
55.36
1.6
6.4
2
3.1
1.8
0.22
32.63
5.1
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

NH3/TRC WLA Calculations
Facility:Hamlet WWTP
PermitNo. NC0047562
Prepared By: David Hill
Enter Design Flow (MGD): 3
Enter s7Q10 (cfs): 2.5
Enter w7Q10 (cfs): 6.4
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/l)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/l)
IWC (%)
Allowable Conc. (ug/I)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
2.5
3
4.65
17.0
0
65.03
26
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/l)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
2001100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
1.54 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/l)
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I
2.5
3
4.65
1.0
0.22
65.03
1.4
6.4
3
4.65
1.8
0.22
42.08
4.0
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

-SPrcepe, NuAdel'
Belnick, Tom
From:
Sent:
To:
Subject:
Belnick, Tom
Wednesday, November 02, 2016 1:20 PM
Rodriguez, Teresa (Teresa. [e-mail])
FW: Hamlet Letter of Request for Speculative Limits
SPEC eyvs4-
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Tow* %F 141101
Will need to discuss with you. Not clear on prior position, since it appears we issued specs previously with Tess stringent
limits than 5/1.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmen
919-807-6390 office
[e-mail]
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
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Nothing Compares_ -.'--
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
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From: Marcus Abernethy [mailto:[e-mail]]
Sent: Wednesday, November 02, 2016 12:00 PM
To: Belnick, Tom <[e-mail]>
Subject: RE: Hamlet I etter of Request for Speculative Limits
Thank you again Tom,
I will be looking for your correspondence. I appreciate your help. Prior staff was told that the State would not permit the
City to discharge any more than 1MGD into Marks Creek because of its impairment. We are wondering if something was
mis-interpreted back then. This was around 12-15 years ago.
Does this mean that with proper upgrades, if the WWTP can treat discharge within these limits you basically listed
of
below, then we could discharge up to 3MGD intoMarks
obtain rhght f way easement for a pope to disecause prior thinking charge into the
staff years ago was that the City would have to build and
Pee Dee River, which is 9 miles away.
Thanks Tom,
Marcus
PAL Ltl-� I
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•
47
6 N., ,N1/1 11/411ewth ; ' 4 ,,,.
!(Maa'rcus Aber*i thyme, i
City of Hamlet, NC
City Hall: [phone]
Mobile: [phone]
Website: http://www.hamletnc.us/
Email: [e-mail]
*Pursuant to Chapter 132 of the North Carolina General Statutes, this email message and any attachments hereto, as
well as any electronic mail messages) that may be sent in response to it may be considered public record and as such
are subject to request and review.
From: Belnick, Tom [mailto:[e-mail]]
Sent: Monday, October 31, 2016 4:16 PM
To: Marcus Abernethy <[e-mail]>
Subject: RE: Hamlet Letter of Request for Speculative Limits
Marcus:
I received your phone message today, sorry for my late response. Most of my staff are currently working on Duke coal
ash permitting activities, including my lone water quality modeler that prepares speculative limits. However, we quickly
looked at your 2015 permit renewal and instream conditions, and we will likely be recommending BOD limits of 5 mg/I
and NH3 limits of 1 mg/I at expanded flows of 2 and 3 MGD, based on the low instream dissolved oxygen conditions and
impaired downstream waters. I will proceed forward with a formal speculative letter, but please let me know if you
have any immediate questions.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
tom. belnick(c�ncdenr.gov
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
%'Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Marcus Abernethy [mailto:[e-mail]]
Sent: Monday, October 03, 2016 8:29 AM
To: Belnick, Tom <[e-mail]>
Subject: RE: Hamlet Letter of Request for Speculative Limits
Tom,
I noticed a typo in my previous request. I put Town of Hamlet in the Subject line. I made the correction and attached the
updated copy.
Thanks,
Marcus Abernethy
City Manager
City of Hamlet, NC
City Hall: [phone]
Website: http://www.hamletnc.us/
Email: [e-mail]
*Pursuant to Chapter 132 of the North Carolina General Statutes, this email message and any attachments hereto, as
well as any electronic mail message(s) that may be sent in response to it may be considered public record and as such
are subject to request and review.
From: Marcus Abernethy [mailto:[e-mail]]
Sent: Wednesday, September 28, 2016 9:02 AM
To: '[e-mail]' <[e-mail]>
Subject: Hamlet Letter of Request for Speculative Limits
Tom,
I hope you are doing well. I wanted to write you to request speculative limits for our WWTP to expand to 2.0 or 3.0
MGD. Thank you for your time with this rewuest.
Thank you,
Marcus Abernethy
City Manager
City of Hamlet, NC
City Hall: [phone]
Website: http://www.hamletnc.us/
Email: [e-mail]
*Pursuant to Chapter 132 of the North Carolina General Statutes, this email message and any attachments hereto, as
well as any electronic mail message(s) that may be sent in response to it may be considered public record and as such
are subject to request and review.

Enrironmcnta!
Draft 2016 Category 5 Assessments EPA Submittal-303(d) List
Pee Dee River Subbasin Yadkin -Pee Dee River Basin
Marks Creek (Boyds Lake, City Lake From NC 177 to N.C.-S.C. State Line
13-45-(2)b
C 13.3 FW Miles
Assessment Criteria Status Reason for Rating
Parameter of Interest Category
Exceeding Criteria Fair Benthos (Nar, AL, FW) 5
Rocky River Subbasin
Back Creek From source to Rocky River
13-17-7
C 12.5 FW Miles
Assessment Criteria Status Reason for Rating
Parameter of Interest Category
Exceeding Criteria Fair Benthos (Nar, AL, FW) 5
Beaverdam Creek From source to Lanes Creek
13-17-40-11
WS-V 12.1 FW Miles
Assessment Criteria Status Reason for Rating
Parameter of Interest Category
Exceeding Criteria > 10% and >90 conf
Dissolved Oxygen (4 mg/I, AL, FW) 5
Big Bear Creek From source to Long Creek
13-17-31-5
C 19.9 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest Category
Exceeding Criteria Fair Fish Community (Nar, AL, FW) 5
Caldwell Creek From source to Freeman Drive
13-17-8-5a C 6.0 FW Miles
Assessment Criteria Status Reason for Rating
Parameter of Interest Category
Exceeding Criteria Fair Benthos (Nar, AL, FW) 5
Clarke Creek From source to Rocky River
13-17-4
C 5.5 FW Miles
Assessment Criteria Status Reason for Rating
Parameter of Interest Category
Exceeding Criteria
Poor Fish Community (Nar, AL, FW)
5
6/6/2016 Draft 2016 NC Category 5 Assessments- EPA Submittal Page 192 of 209

201 West Main Street
Post Office Box 1229
Hamlet, North Carolina 28345
Phone [phone]
Fax [phone]
www.hamletnc.us
Mr. Tom Belnick
NC DEQ/DWR
NPDES Permitting
1617 Mail Service Center
Raleigh, NC 27699-1617
October 3rd, 2016
RE: Request for Speculative NPDES Limits for the City of Hamlet
Mr. Belnick,
The City of Hamlet owns and operates a wastewater treatment plant (WWTP), NPDES
#NC0047562, which is permitted for 1.0 MGD. The City would like to request speculative limits
for increasing the permitted flow capacity at the WWTP to 2.0 and 3.0 MGD. The current
average daily flow is at 60% capacity. Obtaining speculative limits is critical in order to
effectively explore and evaluate all available options to address future wastewater capacity
issues within the City and County.
If there are questions regarding this request, please contact me by email at
[e-mail], or by telephone at [phone]. Our mailing address is listed
above. Thank you in advance for your time and attention in reviewing this letter.
Sincerely,
Marcus R. Abernethy
City Manager
City of Hamlet, NC

Belnick, Tom
From: Belnick, Tom
Sent: Monday, October 31, 2016 4:16 PM
To: 'Marcus Abernethy'
Subject: RE: Hamlet Letter of Request for Speculative Limits
Marcus:
I received your phone message today, sorry for my late response. Most of my staff are currently working on Duke coal
ash permitting activities, including my lone water quality modeler that prepares speculative limits. However, we quickly
looked at your 2015 permit renewal and instream conditions, and we will likely be recommending BOD limits of 5 mg/I
and NH3 limits of 1 mg/I at expanded flows of 2 and 3 MGD, based on the low instream dissolved oxygen conditions and
impaired downstream waters. I will proceed forward with a formal speculative letter, but please let me know if you
have any immediate questions.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
[e-mail]
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
Nothing Compares_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Marcus Abernethy [mailto:[e-mail]]
Sent: Monday, October 03, 2016 8:29 AM
To: Belnick, Tom <[e-mail]>
Subject: RE: Hamlet Letter of Request for Speculative Limits
Tom,
I noticed a typo in my previous request. I put Town of Hamlet in the Subject line. I made the correction and attached the
updated copy.
Thanks,
0 /ipaerio,- ce4 tf,/ eti f)40 6

Marcus Abernethy
City Manager
City of Hamlet, NC
City Hall: [phone]
Website: http://www.hamletnc.us/
Email: [e-mail]
*Pursuant to Chapter 132 of the North Carolina General Statutes, this email message and any attachments hereto, as
well as any electronic mail message(s) that may be sent in response to it may be considered public record and as such
are subject to request and review.
From: Marcus Abernethy [mailto:[e-mail]]
Sent: Wednesday, September 28, 2016 9:02 AM
To: '[e-mail]' <[e-mail]>
Subject: Hamlet Letter of Request for Speculative Limits
Tom,
hope you are doing well. I wanted to write you to request speculative limits for our WWTP to expand to 2.0 or 3.0
MGD. Thank you for your time with this rewuest.
Thank you,
Marcus Abernethy
City Manager
City of Hamlet, NC
City Hall: [phone]
Website: http://www.hamletnc.us/
Email: [e-mail]
*Pursuant to Chapter 132 of the North Carolina General Statutes, this email message and any attachments hereto, as
well as any electronic mail message(s) that may be sent in response to it may be considered public record and as such
are subject to request and review.