NC0028827_Fact Sheet_20231018

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
FACT SHEET
EXPEDITED - PERMIT RENEWAL
NCO028827 — Class 2
Basic Information for Expedited Permit Renewals
Permit Writer/Date
Andrew Friedman -Herrin / NPDES / October 6th 2023
Permit Number - Class
NCO028827 — Class 2
Flow
0.020 MGD
Owner
Snug Harbor Management, LLC
Facility Name
Snug Harbor on Nelson Bay
Type of Waste
100 % domestic
Basin Name/Sub-basin number
White Oak River Basin / 03-05-04
Receiving Stream
Salters Creek [segment 21-35-7-10-2
Stream Classification in Permit
SC
Does permit need Daily Max NH3 limits?
No
Does permit need TRC limits/language?
Has limit — added footnote
Does permit have toxicity testing?
Yes, and have had failures.
Does permit have Special Conditions?
Yes — Compliance Schedule for new Copper Requirements
Does permit have instream monitoring?
No
Is the stream impaired on 303(d) list)?
No
Any obvious compliance concerns?
Inspection in 2/2019 revealed extensive disrepair. Some repairs
and upgrades implemented by 7/2019 as noted in the Violation
Settlement, but specifics of what was upgraded is not
documented. Facility has been closed since 12/2019. Unclear if
more repairs needed to reopen the plant/fully address the
previously needed repairs. Upgrades will likely need to be made
to address new copper limits over a 5 year compliance schedule.
Any permit MODS since lastpen-nit?
Facility is currently not operating.
Requests for Renewal
Received Jan 27, 2022
New expiration date
July 31, 2028
Changes to Current Permit?
Copper Effluent Limits were added after an RPA determined a
reasonable potential for harm due to the levels of Copper being
discharged. 5 year Compliance Schedule Added
Data Review —
Reviewed BIMS data from 2015 through present. Violations for several parameters, especially in 2019.
They have been monitoring for copper and WET since 2007. 1 used the copper data from 2015-2019 to perform
an RPA and determined that copper should have an effluent limit and added a 5 year compliance schedule.

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Saltwater RPA 95% Probablity/95% Confidence
MAXIMUM DATA POINTS = 58
NA REQUIRED DATA ENTRY
Table 1. Project Information Table 2. Parameters of Concern
Facility Name
❑ CHECK IF HQW OR ORW WQS
Snug Harbor on Nelson Bay
WWTP/WTP Class
Class II
NPDES Permit
NCO028827
Outfall
001
Flow, Qw (MGD)
0.020
Receiving Stream
Salters Creek
Stream Class
SC
7Q10s (cfs)
Tidal, IWC = 100%
7Q10w (cfs)
Tidal, IWC = 100%
30Q2 (cfs)
Tidal, IWC = 100%
QA (cfs)
Tidal, IWC = 100%
1Q10s (cfs)
Tidal, IWC = 100%
Data Source(s)
Saltwater streams are tidal resulting in all IWC % = 100%.
If an approved model is conducted then a chronic dilution
factor is determined and can be applied to a discharge to
calculate its IWC % . If a stream is classified as a SA or
ORW then its is also classified as a HQW. The appropriate
IWC % must be defined to properly calculate WQS-based
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Name w4s Type Chronic Modifier Acute PQL Units
Arsenic
Aquatic Life
C
36
SW
69
ug/L
Arsenic
Human Health
C
10
HH
ug/L
Cadmium
Aquatic Life
NC
8.9
SW
40.2
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
10
ug/L
Chromium VI
Aquatic Life
NC
50.4
SW
1107.8
ug/L
Chromium, Total
Aquatic Life
NC
N/A
SW
N/A
ug/L
Copper
Aquatic Life
NC
3.7
SW
5.8
ug/L
Cyanide
Aquatic Life
NC
1
SW
1
10
ug/L
Lead
Aquatic Life
NC
8.5
SW
220.8
ug/L
Mercury
Aquatic Life
NC
25
SW
0.5
ng/L
Molybdenum
Human Health
NC
2.0
HH
mg/L
Nickel
Aquatic Life
NC
8.3
SW
74.7
ug/L
Selenium
Aquatic Life
NC
71
SW
ug/L
Silver
Aquatic Life
NC
0.1
SW
2.2
ug/L
Zinc
Aquatic Life
NC
85.6
SW
95.1
ug/L
NOTE: The aquatic life chronic and acute WQS for several metals are calculated based on EPA convers
see "Diss. SW stds. As TM" for more details and summary of calculated WQS..
9595 Final Saltwater RPA 2017,input
6/26/2023

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
REASONABLE POTENTIAL ANALYSIS - DATA
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Chromium, Total
Values" then "COPY"
. Maximum data
points = 58
Date Data BDL=1/2DL Results
Sid Dev.
NO DATA
Mean
NO DATA
C.V.
NO DATA
n
0
Mult Factor =
N/A
Max. Value
N/A ug/L
Max. Pred Cw
N/A ug/L
Date
1 1/8/2015
2 4/7/2015
3 7/9/2015
4 10/15/2015
5 1/7/2016
6 1/17/2017
7 4/4/2017
8 7/25/2017
9 10/3/2017
10 1/9/2018
11 1/3/2019
12 4/1/2019
13 10/1/2019
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Copper
Data
BDL=1/2DL
Results
687
687
Sid Dev.
1
1
Mean
53
53
C.V.
111
111
n
225
225
237
237
Mult Factor =
164
164
Max. Value
210
210
Max. Pred Cw
194
194
268
268
112
112
63
63
114
114
Values" then "COPY"
. Maximum data
points = 58
169.8688
187.6154
0.9054
13
1.8900
687.00 ug/L
1298.43 ug/L
9595 Final Saltwater RPA 2017,data
Date}

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Snug Harbor on Nelson Bay
NCO028827 Saltwater RPA 95% Probablity/95% Confidence
MAXIMUM DATA POINTS = 58
Qw (MGD) =
0.02
WWTP/WTP Class: Class II
1Q10S (cfs) =
Tidal, IWC = 100%
IWC% @ 1Q10S =
100
7Q10S (cfs) =
Tidal, IWC = 100%
TWC% @ 7Q10S =
100
7Q10W (cfs) =
Tidal, IWC = 100%
IWC% @ 7Q10W =
100
30Q2 (cfs) =
Tidal, IWC = 100%
TWC% @ 30Q2 =
100
Avg. Stream Flow, QA (cfs) =
Tidal, IWC = 100%
IWC% @ QA =
100
Receiving Stream: Salters Creek
Stream Class:
SC
Outfall 001
Qw = 0.02 MGD
PARAMETER
NC STANDARDS OR EPA CRITERIA
N
REASONABLE POTENTIAL RESULTS
TYPE
a
z
RECOMMENDED ACTION
Applied
Chronic Acute
n # Det. Max Pred Cw Allowable Cw
Standard
Acute (SW): 69.0
Arsenic
C
36 SW(7Q10s) 69
ug/L
0 0
N/A
Chronic (SW): 36.0
Arsenic
C
10 HH(Qavg)
ug/L
Chronic (HH): 10.0
Acute: 40.20
Cadmium
NC
8.9 SW(7Q10s) 40.2
ug/L
0 0
N/A
Chronic:----- 8.90 --
---------------------------
Acute: NO WQS
Total Phenolic Compounds
NC
300 A(30Q2)
10.0
ug/L
0 0
N/A
-----300.0--
---------------------------
Chronic:
Acute: 1,107.8
Chromium VI
NC
50.4 SW(7Q10s) 1107.8
ug/L
0 0
N/A
Chronic:----- 50.4 --
---------------------------
Chromium, Total
NC
ug/L
0 0
N/A
Acute: 5.80
Copper
NC
3.7 SW(7Q10s) 5.8
ug/L
13 13
1,298.43
Chronic: 3.70
RPA for non -AL - apply Monthly Monitoring
12 values > Allowable Cw
with Limit
Acute: 1.0
Cyanide
NC
1 SW(7Q10s) 1
10.0
ug/L
0 0
N/A
--
---------------------------
Chronic:----- 1-0
Acute: 220.80
Lead
NC
8.5 SW(7Q10s) 220.8
ug/L
0 0
N/A
Chronic:----- 8.50 --
---------------------------
Acute: NO WQS
Mercury
NC
25 SW(7Q10s)
0.5
ng/L
0 0
N/A
--
---------------------------
Chronic:-----25.0
Acute: NO WQS
Molybdenum
NC
2 HH(7Q10s)
mg/L
0 0
N/A
9595 Final Saltwater RPA 2017,rpa
Page 1 of 2 6/26/2023

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Snug Harbor on Nelson Bay
NCO028827
Saltwater RPA 95% Probablity/95% Confidence
Outfall 001
Qw = 0.02 MGD
Chronic: 2.0
---------------------------
Acute: 74.70
Nickel
NC
8.3 SW(7Q10s) 74.7
ug/L
0 0
N/A
Chronic:----- 8.30 --
---------------------------
Acute: NO WQS
Selenium
NC
71 SW(7Q10s)
ug/L
0 0
N/A
Chronic:----- 71.0 --
---------------------------
Acute: 2.20
Silver
NC
0.1 SW(7Q10s) 2.2
ug/L
0 0
N/A
Chronic:----- 0.10 --
---------------------------
Acute: 95.1
Zinc
NC
85.6 SW(7Q10s) 95.1
ug/L
0 0
N/A
Chronic:----- 85.6 --
---------------------------
Acute:
0 0
N/A
Chronic:----------
---------------------------
Acute:
0 0
N/A
Chronic:----------
---------------------------
Acute:
0 0
N/A
Chronic:----------
---------------------------
Acute:
0 0
N/A
Chronic:----------
---------------------------
Acute:
0 0
N/A
Chronic:----------
---------------------------
Acute:
0 0
N/A
Chronic:----------
---------------------------
Acute:
0 0
N/A
Chronic:----------
---------------------------
9595 Final Saltwater RPA 2017,rpa
Page 2 of 2 6/26/2023

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Wnole LTTluent I oxlclty I esting ana JelT Ivlonitoring Jummary
Skyco WTP NCO035670/001 County: Dare
Mysd24PF Begin: 10/1/2018 Mysid Acu 24hr PF M NonComp:
J F M A M
2019 Pass - - Pass -
2020 Pass - - Pass -
2021 Pass - - Pass -
2022 Pass - - Pass -
2023 Pass - - Pass -
Smith Creek WWTP
NCO030759/001
County:
Wake
Ceri7dPF
Begin:
4/1/2019
chr lim: 6.5% @ 3.0
NonComp:
Single
J
F M
A
M
2019
-
Pass(s) -
-
Pass
2020
-
Pass -
-
Pass
2021
-
Pass -
-
Pass
2022
-
Pass -
-
Pass
2023
-
Pass -
-
Pass
Smithfield Packing Co.,
Tarheel
Div.
NCO078344/001
County:
Bladen
Ceri7dPF
Begin:
2/1/2018
chr lim: 0.58%
NonComp:
Single
J
F M
A
M
2019
Pass
- -
Pass
-
2020
Pass
- -
Pass
-
2021
Pass
- -
Pass
-
2022
Pass
- -
Pass
-
2023
Pass
- -
Pass
-
Smithfield WTP, Town of
NCO083348
County:
Johnston
Ceri7dPF
Begin:
8/1/2013
Chr Monit: 90%
NonComp:
J
F M
A
M
2019
Fail
- -
Fail
-
2020
Fail
- -
Fail
-
2021
Fail
- -
Fail
-
2022
Fail
- -
Pass
-
2023
Pass
- -
Pass
-
Snug Harbor on Nelson
Bay WWTP
NCO028827/001
County:
Carteret
Mysd24PF
Begin:
2/1/2013
Acu Lim: 90% (plant
NonComp:
J
F M
A
M
2019
�mn
Pass
u
- -
Pass
u
-
Region: WARO
Basin:
PAS51
Jan Apr Jul Oct
7Q10: Tidal
PF: 0.192 IWC: NA
Freq: Q
J
J
A
S
O
-
Pass
-
-
Pass
Pass
-
Pass
-
-
Pass
-
Pass
-
-
Pass
Pass
Region: RRO
Basin:
NEU02
Feb May Aug Nov
7Q10: 67
PF: 3.5
IWC: 5.3
Freq: Q
J
J
A
S
O
Pass
-
Pass
Pass
-
-
NULL
Pass
-
-
Pass
-
Region: FRO
Basin:
CPF16
Jan Apr Jul Oct
7Q10: 795
PF: 3.0
IWC: 0.58
Freq: Q
J
J
A
S
O
-
Pass
-
-
Pass
-
Pass
-
-
Pass
-
Pass
-
-
Pass
-
Pass
-
-
Pass
Pass
Region: RRO
7Q10:
J
Region: WIRO
7Q10:
J
Basin: NEU02 Jan Apr Jul Oct
PF: 0.3 IWC: Freq: Q
J A S O
Fail - - Fail
Fail - - Fail
Fail - - Fail
Fail - - Fail
Basin: WOK04 Jan Apr Jul Oct
PF: IWC: Freq: Q
J A S O
NR Pass
H H
SOC JOC:
N
SOC JOC:
N
Pass >21.2(P)
Pass
Pass
Pass
SOC JOC:
N
SOC JOC:
N
SOC JOC:
N
0
1o7
0
INJ
0
Legend: P= Fathead minnow (Pimohales Dromelas). H=No Flow (facilitv is active), s = Solit test between Certified Labs Page 97 of 115

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit Enforcement History by Permit
Permit: NC0028827 Facility: Snug Harbor on Nelson Bay WWTP Owner:
Region: Wilmington County: Carteret
Penalty Remission Enforcement EMC Collection
Assessment Penalty Enforcement Request Conference Hearing Memo Sent
Case Approved Amount Costs Damages Received Held Held To AGO
Snug Harbor Management LLC
Total Paid Balance Due
Has
Payment
Plan
Case
Closed
LR-1990-0276
05/21/90
$150.00
$0.00
$0.00
$150.00
$0.00
No
06/25/90
LR-1990-0395
11/21/90
$300.00
$0.00
$0.00
01/18/91
02/06/91
$300.00
$0.00
No
03/01/91
LR-1990-0408
12/26/90
$600.00
$0.00
$0.00
$600.00
$0.00
No
03/01/91
LR-1991-0013
01/22/91
$1,200.00
$0.00
$0.00
02/20/91
04/03/91
$1,200.00
$0.00
No
06/11/91
LV-2002-0335
08/21/02
$250.00
$40.55
$290.55
$0.00
No
09/09/02
LV-2003-0071
02/07/03
$250.00
$40.55
02/27/03
04/02/03
$290.55
$0.00
No
05/20/03
LV-2004-0167
06/09/04
$100.00
$54.83
$154.82
$0.00
No
07/02/04
LV-2008-0387
10/20/08
$200.00
$40.43
11/10/08
01/26/09
$240.43
$0.00
No
12/17/09
LV-2009-0124
04/17/09
$900.00
$43.05
$0.00
05/05/09
08/06/09
$543.05
$0.00
No
08/21/09
LV-2009-0160
05/15/09
$900.00
$43.05
$0.00
05/28/09
08/06/09
$493.05
$0.00
No
08/21/09
MV-2016-0016
12/09/16
$115.00
$117.25
$0.00
$232.25
$0.00
No
01/18/17
LV-2017-0201
07/07/17
$450.00
$117.25
$0.00
$251.23
$0.00
No
10/09/19
MV-2018-0012
06/19/18
$375.00
$137.75
$0.00
$249.58
$0.00
No
10/09/19
MV-2018-0017
10/26/18
$760.00
$137.75
$0.00
$364.39
$0.00
No
10/09/19
MV-2018-0018
10/26/18
$920.00
$137.75
$0.00
$412.10
$0.00
No
10/09/19
LM-2019-0007
01/08/19
$785.00
$137.75
$0.00
02/18/19
$371.84
$0.00
No
10/09/19
MV-2019-0003
01/08/19
$1,280.00
$137.75
$0.00
02/18/19
$519.46
$0.00
No
10/09/19
MV-2019-0004
01/08/19
$1,520.00
$137.75
$0.00
02/18/19
$591.03
$0.00
No
10/09/19
MV-2019-0005
01/08/19
$955.00
$137.75
$0.00
02/18/19
$422.54
$0.00
No
10/09/19

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Case
Penalty
Assessment
Approved
Penalty
Amount
Enforcement
Costs
Remission Enforcement
Request Conference
Damages Received Held
EMC Collection
Hearing Memo Sent
Held To AGO
Total Paid
Balance Due
Has
Payment
Plan
Case
Closed
MV-2019-0006
01/08/19
$1,080.00
$137.75
$0.00 02/18/19
$500.89
$0.00
No
10/09/19
MV-2019-0007
01/08/19
$760.00
$137.75
$0.00 02/18/19
$364.39
$0.00
No
10/23/19
LR-2019-0001
01/22/19
$500.00
$100.00
$249.10
$0.00
No
10/09/19
LR-2019-0002
01/22/19
$500.00
$100.00
02/21/19
$249.10
$0.00
No
10/09/19
LR-2019-0003
01/22/19
$500.00
$100.00
02/19/19
$249.10
$0.00
No
10/09/19
Total Cases:
Total Penalties:
24
$15,350.00
$2,036.71
$17,386.71
Total Penalties after
$9,289.45
$0.00
$9,289.45

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit
Facility
Date Parameter UoM Value
Cell Type
Location
NCO028827
Snug Harbor on Nelson Bay WWTP
1/8/2015 01042 - Copper, Total ug/I
687
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
4/7/2015 01042 - Copper, Total ug/I
1
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
7/9/2015 01042 - Copper, Total ug/I
53
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
10/15/2015 01042 - Copper, Total ug/I
111
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
1/7/2016 01042 - Copper, Total ug/I
225
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
1/17/2017 01042 - Copper, Total ug/I
237
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
4/4/2017 01042 - Copper, Total ug/I
164
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
7/25/2017 01042 - Copper, Total ug/I
210
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
10/3/2017 01042 - Copper, Total ug/I
194
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
1/9/2018 01042 - Copper, Total ug/I
268
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
1/3/2019 01042 - Copper, Total ug/I
112
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
4/1/2019 01042 - Copper, Total ug/I
63
DLYVALUE
Effluent
NCO028827
Snug Harbor on Nelson Bay WWTP
10/1/2019 01042 - Copper, Total ug/I
114
DLYVALUE
Effluent

DocuSign Envelope ID: 5681 FF06-Dl534F75-MAB-07AB26ED7411
NC0028827
Snug Harbor on Nelson Bay WWTP Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
Flow, in conduit or thru
treatment plant
NC0028827
Snug Harbor on Nelson Bay WWTP
Flow, in conduit or thru
treatment plant
NC0028827
Snug Harbor on Nelson Bay WWTP
Flow, in conduit or thru
treatment plant
NC0028827
Snug Harbor on Nelson Bay WWTP
Flow, in conduit or thru
treatment plant
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
Temperature, Water Deg.
Centigrade
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
Temperature, Water Deg.
Centigrade
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
Oxygen, Dissolved (DO)
NC0028827
Snug Harbor on Nelson Bay WWTP
Temperature, Water Deg.
Centigrade
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
pH
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
)ATE FREQUENCY UNIT OF MEASURE
LIMIT CALCULATED VALUE % OVER VIOLATION TYPE VIOLATION ACTION
12/05/2015 Weekly
mg/I
Frequency Violation Proceed to NOV
12/12/2015 Weekly
su
Frequency Violation Proceed to NOV
12/12/2015 Weekly
mgll
Frequency Violation Proceed to NOV
12/19/2015 Weekly
su
Frequency Violation Proceed to NOV
12/19/2015 Weekly
mgll
Frequency Violation Proceed to NOV
12/26/2015 Weekly
mgll
Frequency Violation Proceed to NOV
04/30/2016 Weekly
mgd
0.0200 0.0200
0 Monthly Average Exceede No Action, BIMS Calculation Error
05/31/2016 Weekly
mgd
0.0200 0.0220
9 Monthly Average Exceede Proceed to NOD
06/30/2016 Weekly
mgd
0.0200 0.0210
3 Monthly Average Exceede No Action, BPJ
07/31/2016 Weekly
mgd
0.0200 0.0230
14 Monthly Average Exceede Proceed to NOV
08/06/2016 Weekly
mg/I
Frequency Violation Proceed to Enforcement Case
12/03/2016 Weekly
mg/I
Frequency Violation Proceed to NOV
12/10/2016 Weekly
mg/I
Frequency Violation Proceed to NOV
12/17/2016 Weekly
mg/I
Frequency Violation Proceed to NOV
12/24/2016 Weekly
deg c
Frequency Violation Proceed to NOV
12/24/2016 Weekly
mgll
Frequency Violation Proceed to NOV
12/31/2016 Weekly
deg c
Frequency Violation Proceed to NOV
12/31/2016 Weekly
mg/I
Frequency Violation Proceed to NOV
01/19/2017 Weekly
mg/I
45.0000 84.0000
87 Daily Maximum Exceeded Proceed to Enforcement Case
01/20/2017 Weekly
su
6.8000 6.7000
1 Daily Minimum Not Reach No Action, BPJ
01/26/2017 Weekly
mg/I
45.0000 1680.0000
3633 Daily Maximum Exceeded Proceed to Enforcement Case
01/26/2017 Weekly
su
8.5000 8.6000
1 Daily Maximum Exceeded No Action, BPJ
01/31/2017 Weekly
mg/I
30.0000 32.3300
8 Monthly Average Exceede Proceed to Enforcement Case
01/31/2017 Weekly
mg/I
30.0000 431.3800
1338 Monthly Average Exceede Proceed to Enforcement Case
08/31/2017 Weekly
cful100ml
35.0000 39.9800
14 Monthly Geometric Mean I Proceed to NOV
11/06/2017 Weekly
su
8.5000 8.8000
4 Daily Maximum Exceeded No Action, BPJ
11/09/2017 Weekly
su
8.5000 9.0100
6 Daily Maximum Exceeded No Action, BPJ
11/13/2017 Weekly
su
8.5000 9.0100
6 Daily Maximum Exceeded No Action, BPJ
11/14/2017 Weekly
su
8.5000 8.9900
6 Daily Maximum Exceeded No Action, BPJ
11/15/2017 Weekly
su
8.5000 9.0900
7 Daily Maximum Exceeded No Action, BPJ
11/16/2017 Weekly
su
8.5000 8.5800
1 Daily Maximum Exceeded No Action, BPJ
11/20/2017 Weekly
su
8.5000 8.9300
5 Daily Maximum Exceeded No Action, BPJ
11/21/2017 Weekly
su
8.5000 9.1900
8 Daily Maximum Exceeded No Action, BPJ
12/05/2017 Weekly
su
8.5000 8.8700
4 Daily Maximum Exceeded No Action, BPJ
12/07/2017 Weekly
su
8.5000 8.6900
2 Daily Maximum Exceeded No Action, BPJ
12/12/2017 Weekly
su
8.5000 9.0600
7 Daily Maximum Exceeded No Action, BPJ
12/19/2017 Weekly
su
8.5000 9.1000
7 Daily Maximum Exceeded No Action, BPJ
12/21/2017 Weekly
su
8.5000 8.7000
2 Daily Maximum Exceeded No Action, BPJ
12/31/2017 Weekly
cful100ml
35.0000 39.5900
13 Monthly Geometric Mean I Proceed to NOV
01/31/2018 Weekly
su
8.5000 8.6000
1 Daily Maximum Exceeded No Action, BPJ
02/17/2018 Weekly
su
Frequency Violation Proceed to Enforcement Case
02/24/2018 Weekly
su
Frequency Violation Proceed to Enforcement Case
02/24/2018 Weekly
mgll
Frequency Violation Proceed to Enforcement Case
02/24/2018 Weekly
deg c
Frequency Violation Proceed to Enforcement Case
02/28/2018 Weekly
cful100ml
35.0000 82.4600
136 Monthly Geometric Mean I No Action, BPJ
03/10/2018 Weekly
cful100ml
Frequency Violation Proceed to Enforcement Case
03/17/2018 Weekly
cful100ml
Frequency Violation Proceed to Enforcement Case
03/22/2018 Weekly
su
6.8000 6.5000
4 Daily Minimum Not Reach No Action, BPJ
03/24/2018 Weekly
cful100ml
Frequency Violation Proceed to Enforcement Case
03/31/2018 Weekly
cful100ml
Frequency Violation Proceed to Enforcement Case
04/07/2018 Weekly
cfu/100ml
Frequency Violation Proceed to Enforcement Case
04/14/2018 Weekly
cfu/100ml
Frequency Violation Proceed to Enforcement Case
04/21/2018 Weekly
mg/I
Frequency Violation Proceed to Enforcement Case
04/21/2018 Weekly
mg/1
Frequency Violation Proceed to Enforcement Case
04/21/2018 Weekly
cfu/100ml
Frequency Violation Proceed to Enforcement Case

DocuSign Envelope ID: 5681 FF06-Dl534F75-MAB-07AB26ED7411
2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
04/28/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
05/01/2018
Late/Missing DMR
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
05/05/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
05/12/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
05/12/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
05/12/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
05/12/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
05/19/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
05/19/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
05/19/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
05/19/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
05/26/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
05/31/2018
Late/Missing DMR
No Action, BPJ
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
06/02/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
06/02/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
06/02/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
06/02/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
06/09/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
06/16/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
06/23/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
06/23/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
06/23/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
06/23/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
06/30/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
07/01/2018
Late/Missing DMR
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
07/07/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
07/07/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
07/07/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
07/14/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
07/21/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
07/28/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
07/31/2018
Late/Missing DMR
No Action, BPJ
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
08/04/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
08/11/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
08/18/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
08/23/2018 Weekly
mg/I
45.0000 54.0000
20 Daily Maximum Exceeded
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
08/25/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
08/29/2018 Weekly
mg/I
45.0000 118.0000
162 Daily Maximum Exceeded
No Action, BPJ
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
08/31/2018
Late/Missing DMR
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Flow, in conduit or thru
08/31/2018 Weekly
mgd
0.0200 0.0920
358 Monthly Average Exceede No Action, Facility Reporting Error
treatment plant
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
08/31/2018 Weekly
mg/I
30.0000 44.4400
48 Monthly Average Exceede No Action, BPJ
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
09/01/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
09/01/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
09/01/2018 Weekly
cfu/100m1
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
09/01/2018 Weekly
mg/I
Frequency Violation
Proceed to Enforcement Case
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Enterococci
09/08/2018 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
NC0028827
Snug Harbor on Nelson Bay WWTP
Temperature, Water Deg.
09/22/2018 Weekly
deg c
Frequency Violation
No Action, BPJ
Centigrade

DocuSign Envelope ID: 5681 FF06-Dl534F75-MAB-07AB26ED7411
2018 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
10/01/2018
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
10/06/2018 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
10/13/2018 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
10/16/2018
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
10/20/2018 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
10/27/2018 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
10/31/2018
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
11/03/2018 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
11/03/2018 Weekly
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
11/03/2018 Weekly
Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
11/03/2018 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
11/10/2018 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
11/10/2018 Weekly
(as N) - Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
11/10/2018 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
11/10/2018 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
11/17/2018 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
11/17/2018 Weekly
(as N) - Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
11/17/2018 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
11/17/2018 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
11/24/2018 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
11/24/2018 Weekly
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
11/24/2018 Weekly
Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
11/24/2018 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
12/01/2018 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
12/01/2018 Weekly
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
12/01/2018 Weekly
Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
12/27/2018 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
01/17/2019 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
01/26/2019 Weekly
(as N) - Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
01/26/2019 Weekly
Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
01/26/2019 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
01/26/2019 Weekly
Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
01/31/2019
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
02/01/2019 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
BOD, 5-Day (20 Deg. C) -
02/02/2019 Weekly
Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
Enterococci
02/02/2019 Weekly
NC0028827
Snug Harbor on Nelson Bay WWTP
Solids, Total Suspended -
02/02/2019 Weekly
Concentration
NC0028827
Snug Harbor on Nelson Bay WWTP
Nitrogen, Ammonia Total
02/02/2019 Weekly
(as N) - Concentration
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
02/19/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
02/27/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
02/28/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
03/01/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
03/02/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
03/03/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
03/04/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
03/05/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
03/06/2019 Weekly
NC0028827
Snuq Harbor on Nelson Bay WWTP
pH
03/08/2019 Weekly
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
Late/Missing DMR
Proceed to Enforcement Case
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
Aquatic toxicity permit limit Proceed to NOV
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
cfu/100ml
Frequency Violation
Proceed to Enforcement Case
Late/Missing DMR
No Action, BPJ
mg/I
Frequency Violation
Proceed to NOV
mg/I
Frequency Violation
Proceed to NOV
mg/I
cfu/100ml
mg/I
mg/I
cfu/100ml
mg/I
mg/I
mg/I
cfu/100ml
mg/I
mg/I
mg/I
mg/I
cfu/100ml
mg/I
mg/I
mg/I
cfu/100ml 276.0000 2420.0000
mg/I 45.0000 70.0000
mg/I
mg/I
cfu/100ml
mg/I
su
8.5000
8.7000
mg/I
cfu/100ml
mg/I
mg/I
su
8.5000
8.6000
su
8.5000
8.9800
su
8.5000
8.6500
su
8.5000
8.7600
su
8.5000
8.8400
su
8.5000
8.7800
su
8.5000
8.7600
su
8.5000
8.8400
su
8.5000
8.8500
su
8.5000
8.8600
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
Proceed to NOV
Frequency Violation
No Action, Facility Reporting Error
Frequency Violation
No Action, Facility Reporting Error
Frequency Violation
No Action, Facility Reporting Error
777 Daily Maximum Exceeded
Proceed to NOV
56 Daily Maximum Exceeded
Proceed to NOV
Frequency Violation Proceed to NOV
Frequency Violation Proceed to NOV
Frequency Violation Proceed to NOV
Frequency Violation Proceed to NOV
Late/Missing DMR No Action, BPJ
2 Daily Maximum Exceeded No Action, BPJ
Frequency Violation No Action, Facility Reporting Error
Frequency Violation No Action, Facility Reportinq Error
Frequency Violation No Action, Facility Reporting Error
Frequency Violation No Action, Facility Reporting Error
1 Daily Maximum Exceeded No Action, BPJ
6 Daily Maximum Exceeded No Action, BPJ
2 Daily Maximum Exceeded No Action, BPJ
3 Daily Maximum Exceeded No Action, BPJ
4 Daily Maximum Exceeded No Action, BPJ
3 Daily Maximum Exceeded No Action, BPJ
3 Daily Maximum Exceeded No Action, BPJ
4 Daily Maximum Exceeded No Action, BPJ
4 Daily Maximum Exceeded No Action, BPJ
4 Daily Maximum Exceeded No Action, BPJ

DocuSign Envelope ID: 5681 FF06-D153-4F75-A4AB-07AB26ED7411
2019 Weekly
su
8.5000
8.9200
5 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/10/2019 Weekly
su
8.5000
9.0400
6 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/11/2019 Weekly
su
8.5000
8.8600
4 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/12/2019 Weekly
su
8.5000
8.7400
3 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/13/2019 Weekly
su
8.5000
8.6400
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/14/2019 Weekly
su
8.5000
8.9200
5 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/15/2019 Weekly
su
8.5000
8.6800
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/19/2019 Weekly
su
8.5000
8.5400
0 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/20/2019 Weekly
su
8.5000
8.7200
3 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/22/2019 Weekly
su
8.5000
8.8400
4 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/23/2019 Weekly
su
8.5000
8.6200
1 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/24/2019 Weekly
su
8.5000
8.6000
1 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/25/2019 Weekly
su
8.5000
8.8900
5 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/27/2019 Weekly
su
8.5000
8.6900
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/30/2019 Weekly
su
8.5000
8.6900
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
03/31/2019 Weekly
su
8.5000
8.7200
3 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/01/2019 Weekly
su
8.5000
8.8100
4 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/02/2019 Weekly
su
8.5000
8.6800
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/06/2019 Weekly
su
8.5000
8.8400
4 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/13/2019 Weekly
su
8.5000
8.5400
0 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/17/2019 Weekly
su
8.5000
8.8600
4 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/18/2019 Weekly
su
8.5000
9.0100
6 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/20/2019 Weekly
su
8.5000
8.8200
4 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/22/2019 Weekly
su
8.5000
8.9300
5 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/23/2019 Weekly
su
8.5000
8.9800
6 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/26/2019 Weekly
su
8.5000
8.5900
1 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/27/2019 Weekly
su
8.5000
8.6200
1 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/28/2019 Weekly
su
8.5000
8.6400
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
04/29/2019 Weekly
su
8.5000
8.6900
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
07/03/2019 Weekly
su
8.5000
8.6400
2 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
07/04/2019 Weekly
su
8.5000
8.5200
0 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
09/20/2019 Weekly
su
8.5000
8.5200
0 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
11/12/2019 Weekly
su
8.5000
8.5100
0 Daily Maximum Exceeded No Action, BPJ
NCO028827
Snuq Harbor on Nelson Bay WWTP
pH
12/04/2019 Weekly
su
8.5000
8.5500
1 Daily Maximum Exceeded No Action, BPJ

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 15 I 3 I NCO028827 111 12 I 19/02/27 I17 18 L R J 19 L G j 201
21111111 11111111111 1111111 1111111 11111111111 r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
671
70 I, I 71 I p I 72 I n, I 73 I —LI J74 751 I I I I I I I80
I —I �J I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
12:15PM 19/02/27
17/08/01
Snug Harbor on Nelson Bay WWTP
272 US Hwy 70
Exit Time/Date
Permit Expiration Date
Sealevel NC 28577
04:30PM 19/02/27
22/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
F Patrick AusbandH252-225-4411 /2522251670
John EstepH252-225-4411 ext 223/
Mary Althouse//252-225-4411 /
Patricia DavisH252-723-7528 /
Patricia Taylor Davis/ORC/252-466-6787/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
John Estep,PO Box 150 Sealevel NC 285770150/Engineering Director/252-225-4411/
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance 0 Self -Monitoring Program
Sludge Handling Disposal 0 Facility Site Review
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dean Hunkele Docu� WIRO WQ//910-796-7215/
E3/18/2019
E1 D9294C4D3746E...
Page#

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Doc'u"siigned by: Date
rMorella Sanchez -King WIROWQ//910-796-7218/ 1b f ��3/ 019
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit: NCO028827
Inspection Date: 02/27/2019
NPDES yr/mo/day
31 NCO028827 1" 121 19/02/27 1
17
Owner - Facility: Snug Harbor on Nelson Bay WWTP
Inspection Type: Reconnaissance
Inspection Type
18 1 RI
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The visit was to determine the facility's current status and if the items/conditions noted in 2-2017 had
been addressed as no correspondence & evidence to that effect had been submitted to DWR's
regional office. It was also to meet with new & current staff while discussing the effluent data reporting
issues that occurred for most of 2018.
A long discussion and Q&A session began the visit as all of the facility staff are new within the past few
months to a year. The management and ownership (represented by Pat Ausband) need to do a better
job in overseeing the operational staff and ensuring funds are available for repairs and bills are paid in a
timely manner. Review of preliminarily revised reports & data showed the facility had monitored some
items and simply failed to report them or did so incorrectly. The last few months of 2018, it was a
matter of failing to pay the lab for their service and thus they withheld the data.
The off -site pump station (referred to as influent PS in this report) is considered part of a deemed
permitted or approved collection system per 15A NCAC 2T .0403, but certain things must be done in
accordance with the regulation. With staff being on -site daily, then complete & documented weekly
testing versus daily is okay since no telemetry is installed; telemetry monitoring of the station and plant
EQ is recommended. There are some electrical issues noted from 2017 that still need to be
addressed and the excessive solids were observed again (not sure if ever cleaned). Installation of
pump run clocks is recommended with at least weekly logging of the times to determine if a float has
gone bad, the alternating circuit has failed, or if a pump is showing signs of an issue.
Facility needs better accounting of flow and the volume of sources to the treatment plant along with
tracking rainfall and its affect on total flow. Our Public Water Supply Section staff indicated lack of a
meter or accurate readings for the water system recently. This is also important in order to determine
if half the treatment system can be taken off-line or not and if not then what size rental tankage would
be needed to control flow while each side is taken down independently for cleaning and repair.
The permit continues to list a Flow Equalization Basin as installed/active equipment, but it has not been
used as such going back to at least 3-2011 when it was noted during an inspection. Given that the
facility can receive normal domestic flow, laundry flow, cafeteria flow, and water system backwash,
then reinitializing the use of the EQ Basin is highly recommended to make the influent more
homogeneous and allow the flow to be sent through the plant at a consistent flow rate and split evenly
between the treatment trains if necessary to operate both. However, to do so will require the flow
splitter box to be repaired or replaced and the EQ Basin plumbed from the old sludge holding tank back
into it.
Observation of redworms in the filters means they are at least in the clarifiers meaning the sludge is
very old and not being properly wasted. The old sludge holding tank could be the source if not well
mixed and volume not replaced regularily. Please provide a MLSS report for each aeration basin and
the sludge holding tank and send us records regarding the last two sludge hauling events.
The exterior railings and tank walkway grating has been replaced making it much safer to get around
the plant without fear of safety; these were first noted as needing to be addressed in 3-2009. Additional
work is needed on internal railings& access stairs plus most metal electrical panels need to be
replaced along with areas of conduit around the plant which were noted in 2017. These are safety
issues for both inspectors and staff and can lead to a complaint by our staff to the NC Dept of Labor
which would inspect your entire complex.
Page#

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit: NCO028827 Owner - Facility: Snug Harbor on Nelson Bay WWTP
Inspection Date: 02/27/2019 Inspection Type: Reconnaissance
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Is the facility as described in the permit?
❑
0
❑
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: No EQ Basin in use and hasn't been since before 3-2011. The facilitv did indicate it was
part of their operational system in their 2017 renewal application which was apparently
inaccurate.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ 0 ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Exterior safety railings have been replaced, but stairs accessing plant and filters have vet to
be replaced. A viewing and access platform has been built for the filters. New
fiberglass/resin grating has been installed over tankage where needed. None of the
electrical panels/boxes have been repaired or replaced, but most if not all need complete
replacement as well as replacement of damaged conduit & fittings around the plant.
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Yes No NA NE
■ ❑ ❑ ❑
❑ ■ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑ ■
❑ ❑ ❑ ■
❑ ❑ ■ ❑
❑ ❑ ❑ ■
Comment: This is the off -site DumD station. Need to determine what tvDe of Dumps are installed to
determine if the bar screen or basket is necessary in the wetwell as not required for grinders
with functional cutting blades. The wetwell was full of excessive solids/grease/rags that
could interfere with float/pump operation. In addition, the solids were so bad that excessive
"dung" flies were present in the station which is not acceptable from a vector control aspect.
The control panel is old with the conduit housing the lines from the wetwell into the panel not
sealed per current code which is an explosion hazard and the conduit entering the side of
the panel is not connected allowing moisture inside. The solids and electrical issues were
noted during the 2-23-2017 inspection which the facility indicated in writing would be
corrected. It is recommended that pump run times and/or advanced telemetry like a Mission
system be installed.
Page# 4

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit: NCO028827 Owner - Facility:
Inspection Date: 02/27/2019 Inspection Type:
Snug Harbor on Nelson Bay WWTP
Reconnaissance
Equalization Basins
Yes No NA NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Is the basin free of excessive grease?
❑
❑
❑
Are all pumps present?
❑
❑
❑
Are all pumps operable?
❑
❑
❑
Are float controls operable?
❑
❑
❑
Are audible and visual alarms operable?
❑
❑
❑
# Is basin size/volume adequate?
❑
❑
❑
Comment: The EQ basin is no longer functionina as one and is operatina operatina strictly as an
influent pump station as was noted during the 3-2011 inspection vet the last permit issuance
indicates its existence & use as EQ. The force main trottled back by a valve (which will
shorten the pumps life) was replumbed from the concrete splittler box due to its structural
failure to the original sludge holding tank whereby it flows by gravity into at least one
treatment train in some manner. Given the nature of varying wastestreams and their
duration from the complex having an EQ basin is highly recommended, thus the flow splitter
box should be repaired or replaced with a return to EQ in place and flow routed back to it.
During the 3-2011 it was noted that the MLSS was not even between the aeration basins.
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
❑ ❑
❑
Are surface aerators and mixers operational?
❑ ❑
0
❑
Are the diffusers operational?
0 ❑
❑
❑
Is the foam the proper color for the treatment process?
❑ ❑
0
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑
❑
❑
Is the DO level acceptable?
❑ ❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑ ❑
❑
Comment: The only blower present was shut down to facilitate communication. Prior to that it
appeared that mixing was adequate, but activated sludge looked on the dark side; no MLSS
records were available nor was a decent settleometer vessel; use of a portable TSS meter
to measure MLSS on -site or periodic MLSS samples to the lab is recommended. A
replacement blower for the one missing has been supposedly ordered. If the remaining
blower fails, then the plant's biology will die.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑
❑
0
❑
Page# 5

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit: NCO028827 Owner - Facility:
Inspection Date: 02/27/2019 Inspection Type:
Snug Harbor on Nelson Bay WWTP
Reconnaissance
Secondary Clarifier
Yes No NA NE
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
❑
❑
0
❑
Is the return rate acceptable (low turbulence)?
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
❑
❑
❑
Comment: Observed through the grating
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
❑
❑
❑
Is the site free of excessive foaming in the tank?
0
❑
❑
❑
# Is the odor acceptable?
0
❑
❑
❑
# Is tankage available for properly waste sludge?
0
❑
❑
❑
Comment:
Filtration (High Rate Tertiary)
Yes No NA NE
Type of operation:
Down flow
Is the filter media present?
0 ❑
❑
❑
Is the filter surface free of clogging?
0 ❑
❑
❑
Is the filter free of growth?
0 ❑
❑
❑
Is the air scour operational?
❑ ❑
❑
Is the scouring acceptable?
❑ ❑
❑
Is the clear well free of excessive solids and filter media?
❑ ❑
❑
Page# 6

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit: NC0028827
Inspection Date: 02/27/2019
Filtration (High Rate Tertiary)
Owner - Facility: Snug Harbor on Nelson Bay WWTP
Inspection Type: Reconnaissance
Yes No NA NE
Comment: Filters are dosed by pumps. Red worms observed on media surface which indicates a ver
old sludge; no idea when sludge last hauled. The inspection 2 ergo mentioned media
was being lost to the mudwell. It is very likely the filters have been augmented from the
original design based on appearance of the dosing frame & overflow trough. The media
level appeared to be way too high in relation to the overflow trough for scoured solids (less
than a foot) and apparent depth of the filters, thus no doubt getting media carry-over. Given
this facility's limits especially for TSS, the need for filters shouldn't exist if flows are accurate
& if facility is operated properly. Filters do provide a safety factor for effluent quality, thus if to
remain in use then they should be returned to orginal design specifications or augmented to
function better.
Disinfection -Liquid
Yes No NA NE
Is there adequate reserve supply of disinfectant?
❑
❑
❑
(Sodium Hypochlorite) Is pump feed system operational?
❑
❑
❑
Is bulk storage tank containment area adequate? (free of leaks/open drains)
0
❑
❑
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
Comment: There was discussion about reDlacina the liauid with tablets to match the dechlorination
method. Based on this facility's plug flow from an off -site pump station and especially with
the EQ basin functioning as a pump station too, then tablet chlorination would be a better fit
in function & likely cost. Effluent very clear but tank very dark; perhaps cleaning and painting_
would allow observation inside the unbaffled tank. Tank should not be aerated to mix as it
drives off chlorine, should be mixed with submerged pump or motorized mixer.
De -chlorination
Yes No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑ ❑
0
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
0 ❑
❑
❑
Comment:
Are the tablets the proper size and type? ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use?
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? 0 ❑ ❑ ❑
Page# 7

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Permit: NCO028827 Owner - Facility:
Inspection Date: 02/27/2019 Inspection Type:
Snug Harbor on Nelson Bay WWTP
Reconnaissance
Flow Measurement - Effluent
Yes No NA NE
Is flow meter calibrated annually?
❑ 0
❑
❑
Is the flow meter operational?
❑ ❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑ ❑
❑
Comment: Last known calibration was in 11-2016. Apparently the vender was not paid for his last
service thus hasn't come since. The facility should not be generating the volume it has
reported at times based on the number of patients and new CIRC that operates a similar
facility nearby agreed. Not keeping meters calibrated and lack of a meter on the water
system backwash makes it hard to know the volume and source plus rainfall isn't tracked to
check for its impact thru the sewer system. Based on this facility's approved flow limit over
1 OK, then a flow meter with charting should be required vet permit doesn't indicate
continuous flow measurement. Since one is available then it should be used and a
datalogger to store the data for charting at any time interval. There was a discussion about
relocating meter to effluent pump station, but would require the hole in the low baffle wall to
be plugged and this is where samples should be collected anyway.
Pump Station - Effluent Yes No NA NE
Is the pump wet well free of bypass lines or structures?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
❑
❑
❑
0
Are float controls operable?
❑
❑
❑
M
Is SCADA telemetry available and operational?
❑
❑
0
❑
Is audible and visual alarm available and operational?
❑
❑
❑
Comment: The station has two submersible pumps whose housings were observed to be completely
out of the water, thus will shorten the life of the pumps and can lead to overheating
& tripping_
of breakers or pump failure. Floats should be adjusted accordingly to keep pumps
properly
submerged.
Page# 8

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
N0RTH CAROLINA
Environmentai' Quality
July 30, 2019
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
CERTIFIED MAIL 7018 1830 0001 8037 0076 - RETURN RECEIPT REQUESTED
Mr. Tom Gatewood, Management President
Snug Harbor Management LLC
PO Box 150
Sealevel, NC 28577-0150
Subject: Settlement Agreement for NPDES Permit NCO028827
Dear Mr. Gatewood,
Please find attached a copy of the signed Settlement Agreement for NPDES Permit NCO028827
for the following enforcement cases: LR-2019-0003, LR-2019-0002, LR-2019-0001, MV-2019-
0003, MV-2019-0004, MV-2019-0005, LM-2019-0007, MV-2019-0006, MV-2019-0007, MV-
2018-0018, MV-2018-0017, MV-2018-0012, LV-2017-0201.
If you have any questions, please contact Dean Hunkele at 910-796-7380 or via email
[dean.hunkele@ncdenr. gov] .
Since ly,
Linda Culpepper
Director
Division of Water Resources
cc: NPDES files
WilmingtonRegional Office
D_EQ��
North Carolina Department of Environmental Quality I Division of Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707-9100

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
NPDES Permit NCO028827
Settlement Agreement
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF CARTERET
IN THE MATTER OF
NORTH CAROLINA ) SETTLEMENT AGREEMENT
NPDES PERMIT NCO028827
HELD BY SNUG HARBOR MANAGEMENT LLC)
Pursuant to provisions of North Carolina General Statute § 143-215.3(a)(6), this Settlement
Agreement is entered into by Snug Harbor Management LLC and the North Carolina
Environmental Management Commission, an agency of the State of North Carolina created by
N.C. General Statute § 143B-282, and hereinafter referred to as the Commission:
1. Snug Harbor Management LLC and the Commission hereby agree to the following findings:
(a.) Snug Harbor Management LLC holds North Carolina NPDES permit NCO028827 for
operation of the Snug Harbor on Nelson Bay wastewater treatment plant (WWTP) and
for making an outlet therefrom for the discharge of treated wastewater to Salters Creek,
currently Class SC waters of this State in the White Oak River Basin.
(b.) Effluent limits included as terms of NPDES permit NCO028227 have been established
as those concentrations of pollutants that may be discharged into the receiving stream
without causing applicable water quality standards to be contravened.
(c.) Snug Harbor Management LLC has been noncompliant with the effluent limits and
reporting requirements contained in NPDES permit NCO028227 in the manner and to
the extent described in paragraph (d.) and Attachment A to this Agreement. Reported
violations of effluent limits and monitoring requirements have persisted from July 2017
through January 2019.
(d.) Snug Harbor Management LLC has been assessed penalties totaling $12,179.75 for
effluent limit and reporting violations that occurred from July 2017 through January
2019. Of that total, nothing has yet been remitted (reduced/removed), leaving an
outstanding assessed civil penalties balance of $12,179.75, as summarized in the table
below.
Page 1 of 3

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
NPDES Permit NCO028827
Settlement Agreement
DATE
CASE NUMBER
CIVIL
ENFORCEMENT
TOTAL
PENALTY
COST
AMOUNT
AMOUNT
I 1/22/2019
LR-2019-0003
$500.00
$100.00
$600.00
1/22/2019
LR-2019-0002
$500.00
$100.00
,}
$600.06
1/22/2019
LR-2019-0001
$500.00
$100.00
_ - $600.00
_
1/8/2019
_
MV-2019-0003
_
$1,280.00
_ _
$137.75
—
$1,417.75
1_
MV-2019-0004�
v__$1,520.00
- -_-. $137.75
`$1,657.75
---1/8/2019
1/8/2019
MV-2019-0005
$955.00
$137.75
-
$1,092.75
—1/8/2019
LM-2019-0007 ---
--- $785.00 ___
_'_$137.75 -
$922.75
1/8/2019
MV-2019-0006
$1,217.75
$137.75
$1,355.50
10/26/2018
MV-2018-0018
$920.00
$137.75
$1,057.75
6/19/2018
MV-2018-0012
$375.00
�$137.75
$512.75
/7rv2017
7p�_
LV-2017-02010
$450.00
$117.25
T
Total Penalties
$5 67.25
$12,179.75
(e.) Following an on -site inspection by regional staff from the Wilmington Regional Office
in February 2019 and actions taken by the facility prior to and continuing afterwards in
addition to a review of revised monthly monitoring reports submitted by the facility, the
Division's regional office is recommending a significant reduction in the civil penalty
balance while retaining all enforcement costs.
2. In order to facilitate resolution of the matters of outstanding civil penalties and unassessed
violations documented in paragraph 1. (d.) above, the Commission and Snug Harbor
Management LLC agree to settle the above described penalties and violations for the total
amount of $4,794.75. Payment shall be made by check made payable to the North Carolina
Department of Environmental Quality within 15 days of the execution of this Agreement,
and sent to the following address:
Attn: John Hennessy, Supervisor
Compliance & Expedited Permitting Branch
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Full payment of the settlement amount shall constitute complete satisfaction of all
outstanding civil penalties assessed prior to the execution of this Agreement and resolve
all unaddressed violations occurring prior to the execution of this Agreement.
3. Nothing in this Agreement relieves Snug Harbor Management LLC of its duty to abide by
the terms of NPDES permit NC0028827. Noncompliance with the terms of the NPDES may
subject Snug Harbor Management LLC to the assessment of additional civil penalties during
the time this Agreement is in effect.
Page 2 of 3

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
NPDES Permit NCO028827
Settlement Agreement
4. Requests, actions and or reports required by the terms of paragraph 2 above shall be deemed
overdue if they are not made, completed or submitted by the dates specified. The burden for
providing sufficient documentation of the satisfaction of the terms of this Agreement is held
entirely by Snug Harbor Management LLC.
5. Because this is an Agreement between the Commission and Snug Harbor Management LLC,
neither party will file a petition for a contested case or for judicial review concerning its
terms.
For the Snug Harbor Management LLC:
Date
Tom Gatewood
Management President
For the North Carolina Environmental Management Commission:
Linda Culpepper
Director
North Carolina Division of Water Resources
for the Chair of the Commission
Date
Page 3 of 3

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Context rrom zuut rermii Issuance
violations resulted in three (3) enforcement penalties and three (3) notices of violation.
Please see the attached NPDES Permit Violation Summary for details.
9) Treatment plant classification: Type: Biological Activated Sludge
Class: Il
B1MS has the appropriate classification designated, therefore no rating sheet is provided.
SIC Code(s): 4952
PART IV - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
(municipals only) involved?
N/A
2. Special monitoring or limitations (includingtoxici ) requests:
N/A
3. Important SOC. JOC or Compliance Schedule dates:
N/A
4. Alternative Analysis Evaluation:
N/A
5. Other Special Items:
N/A
PART V - EVALUATION AND RECOMMENDATIONS
It is strongly recommended that a special condition be placed in the permit requiring the facility to
hire a North Carolina licensed professional engineer to conduct a structural integrity evaluation as
well as a diagnostic investigation to ensure that all components of the facility area in good working
condition considering the age of the system and the compliance history. The facility has some
significant leaks in the basin side walls between the tertiary filter and mudwell.
This facility has had problems with high copper in the sludge. It has posed a problem with Lewis
Farm's ability to land apply the sludge. Lewis Farms has continued to haul their sludge (although
they no longer have Snug Harbor on their permit) but has relied upon mixing the sludge with another
facility's sludge in order to dilute the copper concentration. The Surface Water Protection Section
has notified the Aquifer Protection Section regarding this situation (see attached letter dated March
1, 2007). The facility investigated every possible source of copper including medicines, copper
plumbing and cleaning agents. Influent sampling for copper was conducted in an attempt to identify
the source. Influent results proved negative for copper. It is theorized that the concrete used for
casting the aeration, clarifier and sludge holding basins may contain copper and zinc. The slow
deterioration of the tank walls may be releasing copper and zinc into the treatment system. Since
copper concentrations are high in the sludge, it may be possible that copper concentrations above the
water quality standard action levels may be present in the effluent, potentially posing toxicity issues
for aquatic life. It may be prudent to include monitoring for either copper or include whole effluent
toxicity monitoring.
The draft permit has been received by the Wilmington Regional Office. The draft included total
residual chlorine limitations and Enterococci Bacteria monitoring with limits.

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
AFFIDAVIT OF PUBLICATION
CARTERET COUNTY, NORTH CAROLINA
PUBLIC NOTICE
NCDEQ-DWR
North Carolina
1617 Mail Service Center
Environmental Management
Commission/NPDES Unit
RALEIGH NC 27699
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
Before the undersigned, a notary public of said County and State,
NCO028827 Snug Harbor on
duly commissioned, qualified, and authorized by law to administer
Nelson Bay WWTP The North
oaths, personally appeared:
Carolina Environmental
Mona McFerran
Management Commission
first duly sworn, deposes and says that he (she) is:
proposes to issue a NPDES
wastewater discharge permit to
(Owner, partner, publisher or other officer or employee
the person(s) listed below.
authorized to make this affidavit)
Written comments regarding
Clerk of THE CARTERET PUBLISHING CO., INC., engaged in
the proposed permit will be
the publication of a newspaper known as CARTERET COUNTY
accepted until 30 days after the
publish date of this notice. The
NEWS -TIMES, published, issued, and entered as second class
Director of the NC Division of
mail in the Town of Morehead City, in Carteret County, North
Water Resources (DWR) may
Carolina; that he (she) is authorized to make this affidavit and
hold a public hearing should
sworn statement; that the notice or other legal advertisement, a true
there be a significant degree of
public interest. Please mail
co of which is attached here -to, was published the following
PY P g
comments and/or information
publication and dates:
requests to DWR at the above
Carteret County News -Times: 7/30/2023
address. Interested persons
and that said newspaper in which such notice, paper, document, or
may visit the DWR at 512 N.
legal advertisement was published was, at the time of each and ev-
Salisbury Street, Raleigh, NC
27604 to review the information
ery such publication, a new paper meeting all of the requirements
on file. Additional information
and qualifications of Section 1-597 of the General Statutes of
on NPDES permits and this
North Carolina and was a qualified newspaper within the meaning
notice may be found on our
of section 1-597 of the General Statutes of No Carolina.
w e b s i t e
https://deq.nc.gov/public-notice
Date: 7/31/2023
s-hearings,or by calling (919)
707-3601, Snug Harbor
Management, LLC (PO Box
150, Sea Level, NC) has
applied for rewalthe of permit
(Sign u f rtg affidavit)
NCO028827 for Snug
Harbor on Nelson Bay WWTP.
Sworn and subscribed to before me on:
This permitted facility
7/31/2023
discharges treated domestic
wastewater and drinking water
41111 er��►rr,
treatment filter backwash
�
wastewater into Salters Creek
•..•a..... • �,
in the White Oak River Basin.
Notary Public �` ::�C
'
Currently, Enterococci bacteria,
= p
0 OT,q':
dissolved oxygen, acute
My commission expires: = D �'P� Cn =
toxicity, total residual chlorine,
and copper new requirement)
August 24, 2024 = -4 :cam c/C
' '• G�.
are water quality -limited. This
•'
'�'���, :`'4 202A •: ��j ��.��
Name NCDEQ-DWR '
discharge may affect future
allocations in this portion of the
Order Number 12330 COUN 1
receiving stream.
Order Date 7/25/2023 �•.. ,`��o`
Jy30
Number Issues 1
First Issue 7/30/2023
Last Issue 7/30/2023
Order Price $68.16
Publications Carteret County News -Times

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Friedman -Herring, Andrew
From: John Estep <[e-mail]>
Sent: Friday, June 16, 2023 4:33 PM
To: Friedman -Herring, Andrew
Subject: [External] Re: NPDES Permit NCO028827
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Andrew,
There have been no changes and electronic documents are acceptable
Sincerely
John Estep
Sent from my iPhone
On Jun 16, 2023, at 3:29 PM, Friedman -Herring, Andrew <[e-mail]> wrote:
Dear Mr. John Estep,
I just wanted to touch base with you on the renewal of your NPDES wastewater permit for the Snug
Harbor on Nelson Bay WWTP. I am the permit writer assigned to this renewal. I apologize for the time it
has taken for us to get to this renewal request. We have had a number of issues that have led to a
backlog of renewals for our staff.
I wanted to reach out for a couple of reasons. First, since it has been a while since your application came
in, I wanted to see if there had been any changes or if there was any additional information you wanted
to pass along for our renewal review. I also wanted to pass along information regarding electronic
submittal of permit documents — please see the information below on this issue. Lastly, I have attached
a report showing the contact information that we currently have in our database for your permit. Please
review this information and let me know if the contacts are correct or if any changes, updates or
additions need to be made.
Electronic Transmission of Documents
In order to provide more convenience, control, and security to our permittees and assist them in
processing their transactions, The Division of Water Resources is currently transitioning towards
electronic correspondence. This will hopefully provide more efficient service to our permittees and
other partners and will allow us to more effectively process and track documents. We are writing to ask
you for your approval of the transmittal of documents related to your permitting and related activities
with the Division in an electronic format. Documents will be emailed to the appropriate contact
person(s) in your organization in a PDF format.

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Please respond to me through email with verification that transmittal of your documents in an
electronic manner is acceptable to you.
If you have any questions, please feel free to contact me at this email address. Thanks.
Best,
Andrew Friedman -Herring (he/him)
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
[e-mail]
<image001.png>
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third
parties by an authorized state official.
<Snug Harbor Contacts.xls>

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Friedman -Herring, Andrew
From: Weaver, Charles
Sent: Tuesday, June 27, 2023 11:58 AM
To: Friedman -Herring, Andrew
Subject: RE: Permit NC0028827 Peer Review
Make the expiration date 7/31/2028. Since we are imposing Copper limits, we need to make this a full 5-year renewal.
Update the wording in footnote 2 of Section A. (1) to read "The permittee shall continue to monitor total copper with no
effluent limit until these limits take effect. See Section A. (3) for a compliance schedule regarding Total Copper over the
next five years."
Fact Sheet
Delete the paragraph labeled Notes. It repeats what you've already written in the table above.
The portion of a staff report that was included in the fact sheet has this text from the WiRO:
"It is strongly recommended that a special condition be placed in the permit requiring the facility to hire a North
Carolina licensed professional engineer to conduct a structural integrity evaluation as well as a diagnostic investigation
to ensure that all components of the facility area in good working condition considering the age of the system and the
compliance history. The facility has some significant leaks in the basin side walls between the tertiary filter and
mudwell."
I recommend sending the draft to the WiRO for comments and asking them if they want the evaluation done prior to
any future discharge. A special condition can be added to the permit requiring a facility evaluation prior to restart, etc.
Do this before you send the draft to Notice.
Charles H. Weaver
Environmental Specialist II
Division of Water Resources
919-707-3616
charles.weaver(a)deg.nc.gov
(mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617
DEQ�
Email Correspan&d ice to and from this address is mb" to the Nodh
Caroft;,? R+d c Records Law and may be GrsoWed to third parties,
From: Friedman -Herring, Andrew <[e-mail]>
Sent: Tuesday, June 27, 2023 11:05 AM
To: Weaver, Charles <[e-mail]>
Subject: Permit NC0028827 Peer Review
Hi Charles,

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
I have finished my first permit renewal and wanted to send it to you for peer review. Sydney helped me out a great deal,
as this permit is pretty complicated with a lot going on. It should be explained in the fact sheet, but I can also answer
questions. Let me know if I missed anything. Thanks!
Here's the link to the folder of documents: 7 Peer Review
Best,
Andrew Friedman -Herring (he/him)
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
[e-mail]
iFrrraff co"spondence to and Ircm this address is subject to the Wrth
aroMa Public Recwds taw andr maybe disclosed to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Friedman -Herring, Andrew
From: Friedman -Herring, Andrew
Sent: Wednesday, July 12, 2023 9:15 AM
To: Kegley, Geoff
Cc: King, Morella s; Tharrington, Tom; Perez, Helen I
Subject: RE: Draft Permit for NC0028827 and Questions
Geoff,
Thank you for reviewing the permit. It looks like the next public comment date is 7/25, 1 will make sure that this permit is
included. Let me know if something else comes up before then.
Best,
Andrew Friedman -Herring (he/him)
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
(919)-707-9125
[e-mail]
Oonrim"i 01 FnY5cm rhui u idy
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Kegley, Geoff <[e-mail]>
Sent: Tuesday, July 11, 2023 3:25 PM
To: Friedman -Herring, Andrew <[e-mail]>
Cc: King, Morella s <[e-mail]>; Tharrington, Tom <[e-mail]>; Perez, Helen
I <[e-mail]>
Subject: RE: Draft Permit for NC0028827 and Questions
Andrew,
I have reviewed the draft permit and discussed the facility with other staff and at this time we do not have any
comments.
Thanks for the opportunity to review.
Thanks,
Geoff
Geoff Kegley
Environmental Program Consultant, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
[e-mail]

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
*Please note, my email address has changed. Please update your addressbook to reflect my new address.
D_ E
NORTH CAROLINA cl;
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Friedman -Herring, Andrew <[e-mail]>
Sent: Friday, July 7, 2023 2:25 PM
To: Kegley, Geoff <[e-mail]>
Cc: King, Morella s <[e-mail]>
Subject: RE: Draft Permit for NCO028827 and Questions
I was hoping to get this permit wrapped up by mid/late next week, so if you could get comments by Wednesday or
Thursday that would be great. Getting more eyes on this would be appreciated as well, this is the first permit I've
actually drafted and it seems like a complicated one, haha.
Best,
Andrew Friedman -Herring (he/him)
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
(919)-707-9125
[e-mail]
E
Q
PapeflmMn PI Enri�onAllMal OVal.ly
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Kegley, Geoff <[e-mail]>
Sent: Friday, July 7, 2023 2:12 PM
To: Friedman -Herring, Andrew <[e-mail]>
Cc: King, Morella s <[e-mail]>
Subject: RE: Draft Permit for NCO028827 and Questions
Got it, thanks Andrew. Do have a deadline you need comments? There are some others in the office that know more of
the history of this facility, and I'd like to ask them also.
Geoff Kegley
Environmental Program Consultant, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
[e-mail]
*Please note, my email address has changed. Please update your addressbook to reflect my new address.
D_ E
NORTH CAROLINA 7..� Q
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Friedman -Herring, Andrew <[e-mail]>
Sent: Friday, July 7, 2023 2:00 PM
To: Kegley, Geoff <[e-mail]>
Cc: King, Morella s <[e-mail]>
Subject: RE: Draft Permit for NCO028827 and Questions
Hi Geoff,
Sorry about that. I've attached them as documents, let me know if this works. Thanks.
Best,
Andrew Friedman -Herring (he/him)
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
(919)-707-9125
[e-mail]
PlPefMMI[PI EtW�9nFl1lMil �Vel
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Kegley, Geoff <[e-mail]>
Sent: Friday, July 7, 2023 1:46 PM
To: Friedman -Herring, Andrew <[e-mail]>
Cc: King, Morella s <[e-mail]>
Subject: RE: Draft Permit for NCO028827 and Questions
Hi Andrew,
The link you have provided for the draft permit does not work; can you send it another way?
Thanks,
Geoff

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Geoff Kegley
Environmental Program Consultant, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
[e-mail]
*Please note, my email address has changed. Please update your addressbook to reflect my new address.
D 0
,: �: � ��� E-
NORTH CAROLINA -
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: King, Morella s <[e-mail]>
Sent: Wednesday, July 5, 2023 10:02 AM
To: Kegley, Geoff <[e-mail]>
Subject: FW: Draft Permit for NCO028827 and Questions
Hi Geoff!
Hope you had a great vacation time Q
Please look at this draft permit (link included below) and let Andrew know if any concerns.
Thank you,
Morella
Morella Sanchez King
Regional Supervisor
DEQ Division of Water Resources, Water Quality Section
127 Cardinal Drive Extension, Wilmington, NC 28405
910 796 7218 1 morel [e-mail] I TEAMS (preferred)
From: King, Morella s
Sent: Wednesday, July 5, 2023 9:52 AM
To: Friedman -Herring, Andrew<[e-mail]>
Subject: RE: Draft Permit for NCO028827 and Questions
Hi Andrew,
Honestly, I have not checked it. Thank you for the reminder.
I had a happy 4t"; 1 hope you too!

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
Morella
Morella Sanchez King
Regional Supervisor
DEQ Division of Water Resources, Water Quality Section
127 Cardinal Drive Extension, Wilmington, NC 28405
910 796 7218 1 [e-mail] I TEAMS (preferred)
From: Friedman -Herring, Andrew <[e-mail]>
Sent: Wednesday, July 5, 2023 9:50 AM
To: King, Morella s <[e-mail]>
Subject: RE: Draft Permit for NCO028827 and Questions
Hi Morella,
Have you had a chance to look at this draft permit for Snug Harbor? I was going to send it out to the rest of the
reviewers and for public notice on Monday if everything looks good to you. Thanks so much, and hope you had a good
4th
Best,
Andrew Friedman -Herring (he/him)
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
(919)-707-9125
[e-mail]
0!p![MM11 PI Enri�PnFlleMal OVal.ly
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Friedman -Herring, Andrew
Sent: Tuesday, June 27, 2023 5:00 PM
To: King, Morella s <[e-mail]>
Subject: Draft Permit for NCO028827 and Questions
Hello Morella,
I have been drafting the permit renewal for Snug Harbor (NC0028827) and wanted to send you the draft files and get
your thoughts before sending it out for comment. This facility had a large number of violations in 2018 and 2019, and
failed an inspection on 02/27/2019. Some repairs (the extent is not specified) were made to the facility, and they
entered a settlement on 07/31/2019 and paid their fines. Then, in December 2019 the facility closed and is currently not
operating. In 2007 it was noticed that large amounts of copper were being discharged, and monitoring conditions added
because of that. I performed an RPA with the data and as a result added effluent limits and a compliance schedule.
Should we also require a structural evaluation before allowing discharge again to make sure that all of the concerns
raised in 2019 have been addressed? Thanks so much.

DocuSign Envelope ID: 5681FF06-D153-4F75-A4AB-07AB26ED7411
The folder with the documents is here:
C:\Users\afriedman-herring\OneDrive - State of North Carolina\Documents\Application
Documents\NC0028827\NC0028827 Renewal Documents
Best,
Andrew Friedman -Herring (he/him)
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
[e-mail]
WpegnlalN Y1 EIYYIrun111611U1 uuTi.ry
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.