NC0088331_Permit Issuance_20070702

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�0F WATFRpG
c r
7 y
Mr. Timothy A. Buck
County Manager
P.O. Box 158
Bayboro, North Carolina 28515
July 2, 2007
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
Subject: NPDES PERMIT ISSUANCE
Permit Number NCO088331
Kershaw WTP
Pamlico County
Dear Mr. Buck:
Division personnel have reviewed and approved your application for issuance of the subject
permit. Accordingly, we are forwarding the attached final NPDES discharge permit. This permit is
issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection
Agency dated May 9, 1994 (or as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-
6714). Unless such demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, Coastal Area Management Act, or any other
Federal or Local governmental permits which may be required.
If you have any questions or need additional information, please do not hesitate to contact
Jim McKay of my staff at [phone], extension 595.
Sincerely,
/ /
Coleen H. Sullins
cc: Central Files
NPDES Unit Files
Washington Regional Office — Surface Water Protection
Aquatic Toxicology Unit
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE 919-733-SOB3/FAX [phone]
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

Permit NCO088331
STATE OF NORTH - CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215:1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Pamlico County
is hereby authorized to discharge wastewater from a facility located at the
Kershaw WTP
4116 Kershaw Road
Arapahoe, NC
Pamlico County
to receiving waters designated as UT to Tarkiln Creek in the Neuse River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III and IV hereof.
This permit shall become effective August 1, 2007
This permit and authorization to discharge shall expire at midnight on June 30, 2009.
Signed this day July 2, 2007.
4r < Coleen H. Sullins Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NCO088331
SUPPLEMENT TO PERMIT COVER SHEET
Pamlico County is hereby authorized to:
1. Continue to operate a drinking water treatment plant with a discharge of filter
backwash and softener backwash wastewater.
2. Discharge from said treatment works located at 4116 Kershaw Road at the
Kershaw WTP in Pamlico County, at the location specified on the attached
map into an UT to Tarklin Creek, classified SC, NSW waters in the Neuse
River Basin.

Kershaw WTP - NC0088331 Facility
Location`
USGS Quad Name: G-31 SE Arapahoe Lat.: 35° 01' 53.4" =N
u
Receiving Stream: UT to Tarkiln Creek Long.: 76°46'10.2"
Stream Class: SC/ NSW
Subbasin: Neuse — 03-04-10 North Pamlico County

Permit NC0088331
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge filter backwash and softener backwash from outfall 001. Such discharges shall be
limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Quarterly
Average
Monthly
Average
Daily
Maximum
Measurement
Frequenc
Sample
T pe
Sample Location
Flow
Weekly
Estimate
Effluent
Temperature
1/Month
Grab
Effluent
Salinity
Worth
Grab
Effluent
Conductivitv
Worth
Grab
Effluent
PHI
21Month
Grab
Effluent
Dissolved Oxygen2
2lMonth
Grab
Effluent
Total Dissolved Solids
1/Month
Grab
Effluent
Total Suspended Solids
30.0 m /L
45.0 m A.
21Month
Grab
Effluent
Total Residual Chlorine3
13 ug/ L
21Month
Grab
Effluent
Total Copper
1/Month
Com osite4
Effluent
Total Chloride
11Month
ComposIte4
Effluent
Total Iron
II/Month
Composite4
Effluent
Total Manganese
I/Month
Cam osite4
Effluent
Total Lead
I/Month
Com osite4
Effluent
Total Zinc
11Month
Com osite4
Effluent
Ammonia Nitrogen
11Month
Com osite4
Effluent
TKN
11Month
Com osite4
Effluent
NO3-N + NO2-N (mg/ L)
1/Month
Composite4
Effluent
TN5 m L
II/Month
Corn site4
Effluent
Total Phosphorus
2.0 mg/ L
21Month
Composite4
Effluent
Whole Effluent To)dcity6
Quarterly
Com osite4
Effluent
Footnotes:
1. The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units.
2. Dissolved Oxygen shall not be less than 5.0 mg/L.
3. The Total Residual Chlorine limit shall become effective on February 1, 2009. Monitoring and reporting
shall begin on the effective date of the permit.
4. The requirement for composite samples will begin on February 1, 2009. Grab samples shall suffice
until that date.
5. TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and NO3-N +
NO2-N are Nitrate and Nitrite Nitrogen, respectively.
6. Acute 24-hour Pass/ Fail (Fathead Minnow OR Mysid Shrimp OR Silverside Minnow, Permittee's choice)
at 90%; February, May, August and November, refer to Special Condition A (2).
All samples collected should be from a representative discharge event.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO088331
A. (2.)ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The permittee shall conduct acute toxicity tests on a guarterlu basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity
In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The monitoring
shall be performed as a Fathead Minnow (Pimephales promelas), or Mysid Shrimp (Mysidopsis Bahia),
or Silverside Minnow (Menidia Beryllina) (Permittee's choice) 24 hour static test. Once a test
organism has been selected, all subsequent tests must use the same test organism. The effluent
concentration at which there may be at no time significant acute mortality is 90% (defined as
treatment two in the procedure document). Effluent samples for self -monitoring purposes must be
obtained during representative effluent discharge below all waste treatment. The tests will be
performed during the months of February, May, August and November.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DWQ Form AT-2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Environmental Sciences Section at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon passing,
this monthly test requirement will revert to quarterly in the months specified above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may
be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

FACTSHEET
Permit Number
NC0088331
Facility Name
Kershaw WTP
Basin Name/Sub-basin number
Neuse/ 03-04-10
Receiving Stream
UT to Tarkiln Creek
Stream Classification in Permit
SC - NSW
Does permit need NH3 limits?
No
Does permit need TRC limits?
Yes, 13 u L
Does permit have toxicity testing?
WET
Does permit have Special Conditions?
No
Does permit have instream monitoring?
No
Is the stream impaired (on 303(d) list)?
No
Any obvious compliance concerns?
No
Any permit mods since lastpermit?
N/ A
Existing expiration date
New Permit
New expiration date
June 30, 2009
New permit effective date
August 1, 2007 (Estimate)
Permit Writer/ Date
Jim McKay/ 3/19/2007
Miscellaneous Comments
The Kershaw WTP is one of four existing drinking water treatment plants with no
NPDES discharge permit in Pamlico County. They will all be issued NPDES permits for
the filter backwash and softener backwash waste water.
Mike Templeton and Coleen Sullins have decided that the four Pamlico Co. WTPs are
considered to be non -nutrient dischargers, and do not require an allocation at this time.
A Total Residual Chlorine limit of 13 ug/ L is in the permit because the discharge is to
salt water. An 18 month compliance schedule is provided to allow time to procure and
install dechlorination equipment. Monitoring and reporting is required from the permit
effective date.
An 18 month compliance schedule is provided to allow time for the plant to procure and
install a composite sampler. Grab samples will be taken in the interim.
Effluent Limits and Monitoring Requirements were taken from the Permitting Strategy
for Reverse Osmosis and Ion Exchange WTPs and from the Neuse River Basin TN
strategy. Since no TN limits are required, calculation of TN Load is not included.

i
PUBLIC NOTICE' '
STATE OF NORTH CAROLINA STATE,OF,NORTH CAROLINA
COUNTY OF PAMLICO ENVIRONMENTAL•,MANAGEMENT
AFFIDA VIT OF PUBLI'CA TION coMMISSIONMPoes `UNIT.
1617 MAIL SERVICE CENTER
RALEIGH, NC227689.1617
Before the undersigned, a erson duly comm 'rr�,,
p y NOTIFICATION OF.INTENT
qualified and authorized by law to administer oath To ISSIUEIA NP)9 :. '
appeared to Karen P. Winfrey, who after being fir WASTEWATER PERMIT
deposes and says she is the Business Manager of ' On the -basis of thorough staff review The Town of Oriental has applied fo
and appilcatlon•of NC General Statute a- new NPDES 'permitNO 008W,
PAMLICO NEWS, a newspaper published, issue,143.21,;Public.law,92-500 ar,d'ather ` for the. Oriental WTp• In,.pamlj«
entered as second class mail in the Town of Omer lawful standards and:regulationsr the County. This facility discharges fflt cc
North Carolina � Environmental .Man= backwash and ion exchange regen-
t eration water to Whittaker Creek in
said county and state, and that notice Or other leg age* meRt Commission propose§''to
advertisement, a true copy of which is attached h Josue a National Pollutant Disdharge the Neese giver Basin. TSS is water
Elimination System (NPDES) Wast qua limited• This discharge may
was published in THE PAMLICO NEWS on the ewater dlscharge permlt to the er affect future`alloeatlons In this portion
P ... of the Basin.
j sori(s)`listed below effective 45 days The, Pamtioo Coen
r1 from the public date:of' noticeuth County. (Highway .36s
v §Written Comments regarding the pro- Soy ' Grantsboro, North Carollna) .
posed permit will becCepted urtti , has .applied fora new NPDES per.
! 30 days: after,"the .pubiisn`clate of mit NC0088323 for ,the :,Grantsbaro
And that sal newspaper in which such notice, I this, notice. 'Ali comments received . VqP In. Pamilco'County. This permit
prior to that date are considered In , ted facility discharges- treated avast=
document or legal advertisement was published ' the final deterMinatlons regaiding''the ewater to the Unnamed'.Tributary
time of each and every publication, a newspaper proposed permit:-TheDlrector of,the ' to Beard Creek` In'the Neese- River
NO 'Division of Basin Current total residual chlo-
VVajer ^Qu ` may IY
all of the requirements and qualifications Of Cha decide to hold a pulsl c mee ng-far rival .. 4 °t ! phosphorous a water_;
Section 597 of the General Statutes of North Cai the.proposed permit should _the�bM_ q : v t 96 ." Thls:-;discharge may
was a qualified newspaper within the meaning c s!on receive a sip iflcant dey �rea ~f,aff
"Fq'IO`ans Inuits. portlor,
I th.0401euse� River Bas n�
public Interest. l
1, Section 597 Of the General Statutes of North - e County , j601N 3rd
Copies of the draft permit and other; , $tree}, B ro` hlorth Carotin y ids
applFe ;-f a lnew== NODES ('IFiji N
supporting Information on file used` NO .0088
3g0
This day Of 200 to determine conditions resent in for;.the`.Millpgnft:�NTP
y p . In Pamilco .County,:;This perrifted the draft ,permit -are -available .upon facility oisc arges treated ==4te=`', request and payment of the costs
"of . `ter, in the Unnamed Tributary to North
taA, T 1�• reproduction : 'Mail comments and/or` prong '.of , Bay River' in the Neese
reques#s' fo'r;inforritat1d"" to� the NC' j River Basin. Currently .total residual
Division of, Water Quality at the above- j chlorines and total phosphorous are
B SINESS MANAGER address orwcail_Ms. France&Cande-,� water quality limited. This discharge
lady "at (919) 733-l3083, extension „may .affect future allocations In this
520' at `the Poini'iSource Branch ' portion of the Neuse River Basin.
Sworn to and subscribed before me this pease ,Include .ttie:-NPDES perm!:: The Pamlico
Number (attached) Ia any communi y . - 'County (286 NO 307,-
s , . ar andemere; North Carolina) has:-.
canon interested 'persons may also _ applied for 'a riew. NODES permit NC
day of 2( visit the Dlvtslori -of Water Quality�n"
Q08835g for the,Vamdemere' WTP'
at 512 N. Salisbury Street,'Ralellgh Pamlico �,Co�i ,;
NO 27604-1148 between the hours MY sTh!s�pe '*d:'
of 8.00 a.m. and 5:00p.m. to review '. to j ' discharges red asfe�w a:
information on file. :.. T. .
NOTARY/PUBLIC
cu Y` residui c orme;'any
My COmf�2lSSlO1Z ,u st 4,�/008
total phosphorous are �ivater`guality
.11mite&.:This ;dls6harge: may,, affect
, ..�
: futuresiloatiarfs In this potion of the
Neese r
River Basin.
•
'•• it
t� '•
. tTlie rpani1-tco County"(4i16 Kershaw
Road,;Arapah' Morfh Carolina) has
�,; <t
Seal +, . 1— �' s
applied,ior a new;1Vl?DES permit NO
0088331•` for�'the; 1Ce h_aw "WTP' In
�.
Pam�iCo County. Thfs'permitted` facil-
!ty , discharges treated wastewater
i
.........
.�W
�to the Urznamed,�T0butarY to Tarklln
'Cree"""I n the Neuse -River- Basin.
ACidre4* 'tctal'resldual Chlorine,' and
total-_phosphorousare water quality
limited.: -This rdischarge may affect
future -allocations In this portion ofthe
*Duse'River Basin. •

Draft NPDES Permits
Subject: Draft NPDES Permits
From: Shannon Jenkins <shannon [e-mail]>
Date: Fri, 11 May 2007 14:36:23 -0400
To: Teresa Rodriguez <[e-mail]>, James McKay <[e-mail]>,
Frances Candelaria <[e-mail]>
I received a package of various draft NPDES permits. Please let this email confirm
that we have no comment on the draft permits for:
-Tyrell County Prison WTP NCO088251
-Jacksonville Nano -filtration N00088455
-Grantsboro WTP NCO088323
-Millpond WTP NCO088340
-Kershaw WTP NCO088331
-Vandemere WTP NCO088358
-Pine Knoll Shores WTP NCO082520
-West Carteret Water WTP NCO077143
thanks
Shannon Jenkins
Shellfish Sanitation & Recreational Water Quality
Division of Environmental Health
Shannon Jenkins <shannon.jenkins cpncmail.net>
NC Dept. Environment & Natural Resources
Shellfish Sanitatation & Recreational Water Quality
1 of 1 5/11/2007 2:42 PM

Pamlico wtp discharges
Subject: Pamlico wtp discharges
From: Al Hodge <[e-mail]>
Date: Fri, 04 May 2007 14:14:33 -0400
To: [e-mail]
hi jim:
bases on the application & eaa review and our conversations i recommend that we
issue the npdes permits for
* grantsboro
* kershaw
* millpond
* vandemere
Al Hodge
Division of Water Quality
Surface Water Protection
Washington Regional Office
Regional Office 252-946-6481
Direct 252-948-3844
fax- 252-946-9215
1 of 1 5/4/2007 2:34 PM

xe: unpenmtteu w 1 rs m the neuse- panuico county
Subject: Re: unpermitted WTPs in the neuse- pamlico county
From: Mike Templeton <[e-mail]>
Date: Thu, 15 Mar 2007 16:54:19 -0400
To: [e-mail]
CC: Gil Vinzani <[e-mail]>, Agyeman Adupoku <[e-mail]>,
James McKay <[e-mail]>, Susan Wilson <[e-mail]>, Matt
Matthews <[e-mail]>
Al -
Matt and I met with Coleen last week to look at some of the emerging issues with nitrogen in the Neuse.
We concluded that we should not require Pamlico County to buy allocation for the four WTP discharges.
The main reason is that we assumed WTP backwashes are not nitrogen -bearing discharges when we set
up the allocations; so it seems reasonable to continue to keep them outside the allocation framework
until (1) we come upon some extreme exception that challenges our assumption or (2) until we re -vamp
the TMDL/ allocations and decide to include the WTPs. Any thoughts? If you are okay with it, we'll put
theat issue aside and move ahead with the plants' permits.
You know, it could be that some good deeds (in this case, 'fessing up about the permits) go unpunished
after all.
- Mike T
------- Original Message--------
Subject:Re: unpermitted WTPs in the neuse- pamlico county
Date:Fri, 02 Mar 2007 13:07:19 -0500
From:Mike Templeton <Mike.Templeton(@,ncmail.net>
To:AI Hodge <[e-mail]>
CC:Teresa Rodriguez<teresa.rodriguez(o),,ncmail.net>, Gil Vinzani <Gil.Vinzani@)ncmail.net>,
Agyeman Adupoku <Agyeman.Adupoku @,ncmail.net>
References:<45E3247A.1080105(@,ncmail.net>
Al -
It only makes sense to look at the b/w data - I thought that's what we had all along. Even better if they
can do both raw water and the b/w. The TN results might not be very different, but let's find out.
FYI, I'm supposed to sit down with Coleen after next week's EMC meeting and get this and another
Neuse/ nitrogen issue ironed out. I'll let you know how it goes.
- Mike T
Al Hodge wrote:
1 of 2 3/16/2007 6:58 M

1\fir. LLlltivl illl LLNLL 1i A J ill "V6, 11\rMJM` IJ"AAL1lVV VVLLLILy
hi
spoke with fred hill with the drinking water section regarding the issue of nutrients. i believe that
the data we have looked at to evaluate nutrients has been raw water sources. fred suggests we look at
finished water used for backwash. because, free chlorine is required in the drinking water and with
free chlorine nutrients like nh3 will likely be volatilized. of course we still have the issue of tox; but
thats easier that nutrients.
2 of 2 3/16/2007 6:58 AN

Board of Commissioners
Ann Holton, Chairman
At Large
Paul Delamar Vice Chairman
At Large
Roy Brinson
Township #1
Christine Mele
Township #2
Jimmy Spain,
Township # 3
Carl 011ison
Township #4
J. Douglas Brinson
Township # 5
February 19, 2007
COUNTY OF PAMLICO
POST OFFICE BOX 776
BAYBORO, NORTH CAROLINA 28515
[phone] / 745-5195
FAX [phone]
Ms. Susan A. Wilson, P. E.
Supervisor, NPDES Program
N. C. Division of Water Quality
NPDES East Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
County Manager
Timothy A. Buck
Clerk to the Board
Kathy P. Cayton
County Attorney
Jimmie B. Hicks, Jr.
jr;�:
I�
t � �
FEB 2 i 2007
Re: NPDES Permit Applications
Grantsboro, Kershaw, Millpond, and Vandemere Water Treatment Plants
Pamlico County, North Carolina
Dear Ms. Wilson:
We recently received your letter dated January 17,'2007*requesting additional information
for the Engineering Alternatives Analysis for the referenced NPDES permit applications.
We have reconsidered the disposal alternatives for the Pamlico. County Water Treatment
Plants and we .continue to believe that there are very limited alternatives.
In the NPDES Permit Application under Section V — Engineering Alternatives Evaluation,
Section IV included an evaluation of alternatives. Three alternatives to a surface water
discharge were evaluated: discharge to a wastewater treatment plant, land application,
and wastewater reuse. The local wastewater plant, owned by the Bay River Metropolitan
Sewer District (BRMSD), does not have the capacity to accept the flows from the Pamlico
County Water Plants. This was confirmed by Jim Krauss of BRMSD. The Guidance
Document for preparation of Engineering Alternatives Analyses indicates that
wastestreams from ion exchange systems are not amenable to land application because
of the concentrated waste streams and therefore do not need to be evaluated for land
application. Similarly, wastewater reuse was not considered a feasible alternative.

Therefore, of the alternatives for the discharge of backwash water from the Pamlico
Water Treatment Plants, the surface water discharge remains the most viable option. .
We concur that for the surface water discharge, the total residual chlorine in the
discharges must be reduced. Improvements that we anticipate for the surface discharge
alternative include dechlorination facilities for each plant's waste stream. We request,
however, that the requirement for total nitrogen reduction be re-evaluated. In your letter
of January 17, 2007, the requirements listed from the "Neuse River Basin -Nutrient
Sensitive Waters Managements Strategy" are for new facilities proposing to discharge
wastewater. The Pamlico Water Treatment Plants are existing, and the surface* water
discharges pre -date the Neuse River Basin —Nutrient Sensitive Waters Management
Strategy. Therefore, we request that your agency review the NPDES permit applications
for these plants as existing discharges.
Given the significance of the total nitrogen concentrations in the waste stream, and the
associated permitting challenges associated with this parameter, Pamlico County is
currently conducting additional testing on the raw, finished and backwash flows at each of
the four plants. Waste stream water quality data for the Vandemere Plant is attached. It
was not included with earlier data, as the plant has been off-line and not available for
sampling. It reveals much lower total nitrogen concentrations at that facility. As soon as
the additional testing is completed, we will provide the additional data to you for your
consideration. Although the plants are not designed to add or remove nitrogen, the
testing should help identify the source of the nitrogen concentrations so that there is a
higher level of understanding regarding the presence of the nitrogen, and whether there
are opportunities to eliminate this from the waste stream. The samples at each plant will
be tested for the following: Ammonia -Nitrogen, Nitrate- and Nitrite -Nitrogen, Total
Kjeldahl Nitrogen, Total Nitrogen and Total Phosphorus.
In summary, given the limited available alternatives and the findings from our initial
alternatives screening process, there are no new 'apparent alternatives that could be
identified prior to the requested response date of February 28, - 2007. Additionally, we
request that the discharges be considered existing *in the context of Jhe Neuse River
Basin — Nutrient Sensitive Water Management Strategy.
If you have additional questions regarding the permit applications, please do not hesitate
to contact us.
K

Sincerely,
r
Timoth uck
County Manager
cc: H. Thomas Tant P.E.
Al Hodge, DWQ
3

Z-e: Existing, unpermitted WTPs on Neuse - fyi
Subject: Re: Existing, unpermitted WTPs on Neuse - fyi
From: Mike Templeton <[e-mail]>
Date: Thu, 18 Jan 2007 16:11:37 -0500 (EST)
To: <[e-mail]>, Matt Matthews <[e-mail]>, Al Hodge
<[e-mail]>
CC: James McKay <[e-mail]>, "[e-mail]"
<[e-mail]>, Gil Vinzani <[e-mail]>
I tend to agree with the "existing but unpermitted" call, but it has major implications for the nutrient
strategy, as Susan said, and we need to work through them with a certain amount of care. My main
concern is that, if we don't involve the NRF, Riverkeepers, existing facilities, NRCA, or others, one or
more of them will challenge the decision and the permits and we'll end up in a political mess. Our
approach needs to be consistent with how we're handling the Lee Steam Plant issue, too, or we can
expect to hear from Progress Energy about it.
The dilemma is that the Neuse rule includes definitions of "new" and "existing" dischargers that clearly
place these WTPs in the "new" category because they've never had a permit. All four were discharging
during the baseline period for the strategy and TMDL (1991-95), so we can argue that they were part of
the baseline load from point sources and that much load is "existing." If any of the nitrogen discharges
are any greater now than in 1995, the increase would be "new" and require allocation. That's similar to
we are taking with the Lee Steam Plant.
This approach makes sense to me, but the rule still says they're "new." We can either put the issue on the
table and work it out with the stakeholders, or we can see if anyone challenges it and then work it out. If
we take the latter path, we should say up front that we have a dilemma on our hands, are suggesting one
solution, and are inviting comments, suggestions for other approaches, etc. Then the permits can't be.
misinterpreted as some sort of conspiracy to "sneak one by" anybody.
----Original Message ----
From: [e-mail]
Date: 2007/01/17 4:50 PM
To: &quot;Matt Matthews&quot;, &quot;Al Hodge&quot;
Cc: &quot;James McKay&quot;, &quot;[e-mail]&quot;, &quot;Gil
Vinzani&quot;, &quot;Mike Templeton&quot;
Subj : Existing, unpermitted WTPs on Neuse - fyi .

te: Existing, unpermitted WTPs on Neuse - fyi
Matt and Al:
Just wanted to give you guys a heads -up. I'm signing a letter to Pamlico
Coun re. four existing, unpermitted water treatment plant
discharges in the lower Neuse basin. We're asking for additional
information re. the EAA (although these are I/O exchange facilities
that have been in place for quite some time - non-disch. alternatives
may not be feasible at ail). What Jim, Agyeman, Mike, Gil, and I
discussed was whether to consider these 'new' discharges or
'existing' discharges. There are quite extensive consequences if we
consider these 'new' (esp. since there seems to be some nutrients
resulting from these).
At this time (and we'll likely discuss this more after they've
submitted a more complete alternatives analysis) - since we are dealing
with existing water supplies - I'm making the most practical decision
right now and telling them the NPDES program will move forward on these
proposed projects as 'existing, unpermitted'. However -we've already
gotten comments on these (from Jim Krauss at Bay River) re. the
potential nutrient issue, etc. Also - there is potential for public
hearing with these.
If anyone has any other ideas - let us know (besides consider them
'new' discharges and have them pay millions of dollars to EEP).

HAZEN AND SAWYER
Environmental Engineers & Scientists
December 22, 2006
Mr. Jim McKay
Mr. Agyeman Adu-Poku
N. C. Division of Water Quality
NPDES East Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Hazen and Sawyer, P.C,
4011 WestChase Blvd.
Suite 500
Raleigh, NC 27607
[phone]
[phone] (Fax)
Re: NPDES Permit Applications
Grantsboro, Kershaw, Millpond, and Vandemere
Water Treatment Plants
Pamlico County, North Carolina
Dear Mr. McKay and Mr. Adu-Poku:
This letter is in response to your September 29, 2006, request for additional
information for the Engineering Alternatives Analyses for the referenced NPDES
permit applications.
• We contacted Mr. Jim Krauss of the Bay River Metropolitan Sewer
District, and his attached e-mail correspondence confirms that the
District is currently unable to accept the wastewater flows from the
Pamlico County Water Treatment Plants. (Attach is a clean copy of Mr.
Krauss e-mails.)
• Pamlico County has conducted the requested testing on the wastewater
flow from three of the four facilities (The Vandemere Plant was not in
operation at the time of testing.), and results are attached. The
wastewater from the Millpond and Kershaw Plants passed the toxicity
testing, while wastewater from the Grantsboro Plant failed. The
Vandemere Plant is scheduled to return to operation by the end of
December. Wastewater from Vandemere will be tested as for the other
facilities, and Grantsboro toxicity testing will be rerun at that time.
We contacted Mr. Curtis Weaver of the USGS North Carolina Water
Science Center about the possibility of relocating some of the
discharges downstream of the current zero -flow discharge locations in
an effort to obtain less stringent limits. Mr. Weaver responded that
USGS has insufficient data to indicate where the stream flow becomes
non -zero; therefore, it is apparent with additional and extensive
evaluation that an alternate location would allow less stringent limits.
His e-mail correspondence is attached.
New York, NY - Philadelphia, PA - Detroit, MI - Raleigh, NC - Charlotte, NC - Greensboro, NC - Atlanta, GA - Fairfax, VA - Baltimore, MU - Cincinnati, OH - Hollywood, FL - Boca Raton, FL - Tampa, FL - Miami, FL

HAZENAND SAM
Mr. Jim McKay
Mr. Agyeman Adu-Poku
December 22, 2006
Page 2
If you have additional questions regarding the permit applications, please do not
hesitate to contact us.
Very truly yours,
HAZEN AND SAWYER, P.C.
e---L. / T ---
H. Thomas Tant, P.E.
Senior Associate
HTT:bpr
Enclosures
Cc: Mr. Timothy A. Buck
Mr. Thomas Beasley
Ms. Alana Loughlin
Mr. David Laliberte
McKay 12.22.06 Itr.

From: jkrauss [mailto:[e-mail]]
Sent: Wednesday, November 15, 2006 12:06 PM
To: Laliberte, David M.
Subject: Pamlico NPDES backwash
Good Morning David,
I am sorry that it has taken longer than normal for me to reply back to you. In any event I
offer the following response to the request for handling the wastewater for Pamlico's
water plants.
First I must comment on the total amount of water that is wasted per day from the sum of
the facilities. Approximatly 550,000 gallons per day appears to be an ecessive amount of
backwash water and is more than the total permitted capacity of all the existing treatment
facilities in Pamlico currently.
As the only municipal wastewater provider in Pamlico County we are charged with
protecting the waters in and around the District from additional pollution loadings and
take this responsibility very seriously.
With this said the District cannot currently accept these flows and in the case of
the Kershaw plant the District does not have a line anywhere close to the facility.
The District realizes the need for this backwash water to be treated prior to disposal.
However, I believe that the District would oppose NPDES permits to discharge this
wastewater directly into any water body in the Neuse River Basin given the fact that the
District has invested millions of dollars to remove discharges inside our jurisdiction.
The District would endeavor to work with your firm and Pamlico County to reach a
satisfactory and environmentally sound solution to solve your disposal needs.
Please contact me with any comments or questions that you may have.
Sincerely;
James R. Krauss
Executive Director
Bay River MSD

From: jkrauss [mailto:[e-mail]]
Sent: Thursday, November 16, 2006 11:52 AM
To: Laliberte, David M.
Subject: discharges
David,
In my email yesterday I said that the District would most likely oppose the issuance of
any NPDES permit in our jurisdiction. Whereas I believe this to be true I should have
added that the District would be willing to help the county operate and or manage some
type of wastewater plant design to handle this backwash water. I do believe that some
type of land application or closed system for disposal would be the District's first option
for this disposal. I wanted to make sure that you know that the District is truly willing to
help within our own scope of operations.
Jim Krauss

r d6v A Ut
Loughlin, Alana B.
From:
John C Weaver [e-mail]]
Sent:
Tuesday, October 10, 2006 2:11 PM
To:
Loughlin, Alana B.
Cc:
Laliberte, David M.; John C Weaver
Subject: RE: Low -flow characteristics for selected locations in Pamlico County
Ms. Loughlin,
You've inquired about a possible downstream location on* Beard Creek where the 7Q10 flow may be higher, but the very limited
data that USGS has for Pamlico County streams makes it difficult to assess even a 7Q10 low -flow yield range (expressed as flow
per square mile drainage area, or cfsm) that could produce a higher -flow estimate.
A re -assessment today of the low -flow files (previous requests) and available USGS discharge records only shows a zero -flow
7Q10 yield for those nearby -sites where 7Q10 estimates have previously been determined. So mathematically speaking, the
results when estimating 7Q10 discharges will be limited to zero flow despite having a larger drainage area. So this situation
becomes one where any further estimates really need to be based on some additional streamflow data. ;
For the three sites at Kershaw WTP (Tarkiln Creek), Millpond WTP (North Prong of Bay River), and Vandemere WTP (Smith
Creek), attempting to move further downstream does raise the possibility of tidal influences which precludes us from attempting to
estimate a 7Q10 discharge.
I regret that USGS does not presently have the information to fully address your questions. Please call me with any further
questions.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Telephone: [phone] // Fax: [phone]
E-mail address —[e-mail]
Internet address -- http://nc.water.usgs.gov/
"Loughlin, Alana B." <[e-mail]>
10104/200610:45 AM
To .'John C Weaver" <[e-mail]>
CC I'Laliberte, David M." <dlaliberte@hazen and sawyer. com>
Subject RE: Low -flow characteristics for selected locations in Pamlico County
10/17/2006

rdgu L ul :
Mr. Weaver,
I appreciate all the information you provided a few months ago to help with our discharge permit applications for the four water
treatment plants in Pamlico County. A couple of weeks ago we submitted the applications to the NC Division of Water Quality's
NPDES Unit, and they have requested some additional information that I'm hoping you can help me find.
The NPDES Unit has suggested that if we are able to pipe some of the discharges downstream of the current zero -flow discharge
locations, some limits might be less stringent. I'd like to find out if information is available to determine where non -zero flow starts
in these streams.
For the Grantsboro WTP, could you please help me identify the closest (to the plant) point in Beard Creek downstream of the
current discharge location where the discharge estimate is greater than zero?
For the Kershaw WTP (Tarkiln Creek), Millpond WTP (North Prong of Bay River), and Vandemere WTP (Smith Creek), can I
assume that it will not be possible for us to determine a higher -flow location to use as a discharge point because of the presence
of tidal effects?
Please let me know if it would be helpful for me to resend the topo maps to you.
Thank you so much for your help.
Alana Loughlin
Hazen and Sawyer, P.C.
4011 WestChase Boulevard, Suite 500
Raleigh, North Carolina 27607
919-833-7152
919-833-1828 (fax)
[e-mail]
From: John C Weaver [mailto:[e-mail]]
Sent: Monday, July 17, 2006 11:46 AM
To: Loughlin, Alana B.
Cc: John C Weaver
Subject: Low -flow characteristics for selected locations in Pamlico County
Ms. Loughlin,
In response to your inquiry about the flow characteristics for four selected locations in Pamlico County, the following information is
provided about possible 7Q10 discharges:
A check of the USGS discharge records reveal very limited discharge records and very few previous determinations of 7Q10
discharges for locations on the streams you identified in your fax transmittal. Determining the low -flow characteristics for streams
in Pamlico County and other areas of the lower coastal plain region in North Carolina is very difficult without sufficient site -specific
discharge records to permit a low -flow analysis. Where previous low -flow determinations were noted in the files for locations near
your points of interest, the 7Q10 estimates were zero flow in most all cases, as is very common in the lower coastal plain streams.
Only two sites in western Pamlico County within the Upper Broad Creek basin have sufficient discharge records to permit low -flow
analyses. The 7Q10 for both these locations are estimated -to be zero flow. Drainage areas for these sites (station id's 02092590,
10/ 17/2006

1 agc J u1
02092620) are 21 and 3 sgmi, respectively.
Please also be aware that the USGS does not currently provide low -flow characteristics for streams recognized or suspected as
being affected by tidal influences. The techniques used by the USGS for completing low -flow analyses do not include a means of
quantifying the effects of tides on low -flow conditions. Possible tidal influences were identified in three of the four locations
identified in you fax transmittal.
Specific responses to each stream are listed below separately:
(1) Beard Creek - The location indicated on your fax map is very near a topographical ridge in the headwaters of Beard Creek.
Examination of the contour lines on the topo map suggests a very small drainage area (less than 1 sgmi), thus the 7Q10
discharge is estimated to be zero flow.
(2) Tarkiln Creek or Granny Gut - Examination of the topo map suggests that tidal effects may reach the locations on these
streams near the Kershaw WTP, which precludes any estimates of the 7Q10 discharge. No previous estimates exist in our files
here at the USGS office.
(3) Millpond drainage ditch (into North Prong of Bay River) - Examination of the topo map suggests that tidal effects may reach the
locations on the drainage ditch near the Millpond WTP, which precludes any estimates of the 7Q10 discharge. No previous
estimates exist in our files here at the USGS office for the drainage ditch.
(4) Smith Creek, Vandemere Creek, or Log Pond Creek - Examination of the WTP's location on the topo map indicates the facility
is located on a ridge between drainage ditches that appear to connect to the three streams in question. Because the drainage
area at a point near the WTP would be very small, the 7Q10 discharge would thus be estimated to be zero flow. Any potential
location of the discharge point further downstream onto these streams suggests the presence of tides, which precludes any further
estimates of the 7Q10 discharge.
Hope the above information is helpful and provides a sense of direction in your efforts.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Telephone: [phone] // Fax: [phone]
E-mail address -- [e-mail]
Internet address -- http://nc.water.usgs.gov/
10/17/2006

Environmental T
PO Box 7565
Asheville, NC 28802
Solutions, Inc.
Phone: [phone]
Fax: [phone]
E-mail;- JimSu nner@aol-com
Eflluent Toxicity Report Form - Acute Pass/Fail Date: November 17, 2006
Facility: Enviro Chemist
NPDTS ff: NC- Pflot Plant. Pipe#: 001 County: Pamilco
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LaboratoryPerforming Test: Envirormnental Testing Solutions. Inc. C:omtneats: .
Signature of Operator- in Responsible Charge: Project: 2971
Signature of Laboratory Supervisor: Smtple: 061108.35
14Iat1 Original To: Nort11 Carolina Deparhncnt ofEnvirotmtettt and Natural Resources
DWQ/Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1 f21
North Carolina Acute Pass/Fall Tonicity Test
Collection Dute: 11-07-06
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0.462
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This data package rortlains the trxslrity test results surnmariZed on this form -and includes a Cover Page,
A7=2 Form, Lrrbotrrior . Bencleslieets, Chain-o-CuslodyFonns and, Quality Control Charts.
D jornj AT 2 (8191)

From: jkrauss [maiito:[e-mail]]
Sent: Wednesday, November 15, 2006 12:06 PM
To: Laliberte, David M.
Subject: Pamlico NPDES backwash
Good Morning David,
I am sorry that it has taken longer than normal for me to reply back to you. In any event I
offer the following response to the request for handling the wastewater for Pamlico's
water plants.
First I must comment on the total amount of water that is wasted per day from the sum of
the facilities. Approximatiy 550,000 gallons per day appears to be an ecessive amount of
backwash water and is more than the total permitted capacity of all the existing treatment
facilities in Pamlico currently.
As the only municipal wastewater provider in Pamlico County we are charged with
protecting the waters in and around the District from additional pollution loadings and
take this responsibility very seriously.
With this said the District cannot currently accept these flows and in the case of
the Kershaw plant the District does not have a line anywhere close to the facility.
The District realizes the need for this backwash water to be treated prior to disposal.
However, I believe that the District would oppose NPDES permits to discharge this
wastewater directly into any water body in the Neuse River Basin given the fact that the
District has invested millions of dollars to remove discharges inside our jurisdiction.
The District would endeavor to work with your firm and Pamlico County to reach a
satisfactory and environmentally sound solution to solve your disposal needs.
Please contact me with any comments or questions that you may have.
Sincerely;
James R. Krauss
Executive Director
Bay River MSD

oFWAr��
• �0 p�
1
Mr. Timothy A. Buck
P.O. Box 158
Bayboro, North Carolina 28515
Dear Mr. Buck:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
January 17, 2007
Subject: NPDES Permit Applications
Grantsboro, Kershaw, Millpond, & Vandemere
Water Treatment Plants
Pamlico County, North Carolina
We recently received some of the additional information requested for the Engineering Alternatives
Analysis (EAA) for the referenced NPDES permit applications.
We have reviewed the data for Grantsboro, Kershaw and Millpond Water Treatment plants, and have
found that all three plants have elevated total nitrogen concentrations. Pursuant to 15A NCAC 213.0234 "Neuse
River Basin -Nutrient Sensitive Waters Management Strategy";
(a) All new facilities proposing to discharge wastewater shall evaluate all practical alternatives to
surface water discharge.
(b) New facilities submitting an application shall make every reasonable effort to obtain estuary
allocation for the proposed wastewater discharge from existing dischargers. If estuary
allocation cannot be obtained from the existing facilities, new facilities may purchase a portion
of the nonpoint source load allocation for a period of 30 years at a rate of 200 percent of the
cost as set in 15A NCAC 213.0240 to implement practices designed to offset the loading
created by the new facility. Payment for each 30-year portion of the nonpoint source load
allocation shall be made prior to the ensuing permit issuance.
Because these are existing, unpermitted discharges of non -domestic wastewater, the NPDES Program
may proceed forward with the proposed projects (depending on the outcome of the EAAs). However, based on
the above rule requirements, we foresee that the proposed NPDES permits may generate significant public
comment. We have already received adverse comments from Bay River Metropolitan Sewer District regarding
the proposed permits. We encourage you to explore other alternatives to surface water discharge. Please give us
detailed justifications for all alternatives you consider, including ways to reduce the Total Nitrogen (TN) and Total
Residual Chlorine (TRC) in the discharges, if the analyses still show that NPDES discharge permits are the only
feasible alternate. Please submit your findings to me no later than February 28, 2007.
If you have any questions or comments concerning this letter, you may contact me at the telephone
number [phone] ext 510 or Agyeman Adu-Poku at extension 508.
Sincerely, 00,
o/OoSe8sran A. Wilson, P.E.
Supervisor, NPDES Program
cc: NPDES Files
Washington Regional Office/Surface Water Protection
Hazen and Sawyer/H. Thomas Tant P.E.
4011 WestChase Blvd., Suite 500
Raleigh, NC 27607
N'01 Cara na
r� 'It
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwatCMualily.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/100/6 Post Consumer Paper

OFWA7-F�
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September 29, 2006
Mr. H. Thomas Tant, PE
Hazen And Sawyer, P.C.
4011 WestChase Blvd.
Suite 500
Raleigh, NC 27607
Dear Mr. Tant:
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject: NPDES Permit Applications
Grantsboro, Kershaw, Millpond and
Vandemere Water Treatment Plants
Pamlico County
The NPDES permit applications for these four water treatment plants have been assigned for review as follows: Mr.
Agyeman Adu-Poku - Millpond and Vandemere, and Jim McKay — Grantsboro and Kershaw. Mr. Adu-Poku can be reached
at [phone], ext. 508. His email address is agyeman.adupoku(a),ncmail.net. I can be reached at [phone], ext. 595.
My email address is James.McKay&cmail.net.
We have begun the review process for these four permits, and have found that we need some information that 'is not
included in the Engineering Alternatives Analysis.
• We need a letter from -an officer ofthe DayR7vet-Metropolitair SePwer District stating~that theycannot, accept,
the waste water from these four water treatment plants.
• We need at least one data point from each water treatment plant for each of the parameters on the attached
table. There should be one Whole Effluent Toxicity test run for each plant.
• Would it be possible to pipe some of the discharges to the stream instead of discharging to a zero flow
stream? This might make some limits less stringent.
If we require any more information during the course of our review, we will contact you.
Sincerely,
Jim McKay
NPDES East Unit
cc: Agyeman Adu-Poku
NPDES Files
Washington Regional Office/ Surface Water Protection
N. C. Division of Water Quality / NPDES Unit Phone: [phone] ext. 595 email: [e-mail]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center:1800 623-7748

HAZEN AND SAWYER
Environmental Engineers & Scientists
September 14, 2006
Mr. Al Hodge
Surface Water Protection Supervisor
NCDENR — Division of Water Quality
943 Washington Square Mall
Washington, North Carolina 27889
Re: Pamlico County
NPDES Permit Application
H&S Job No. 31077
Dear Mr. Hodge:
Hazen and Sawyer, P.C.
4011 WestChase Blvd.
Suite 500
Raleigh, NC 27607
[phone]
[phone] (Fax)
Enclosed for your review and consideration are three copies of the National Pollutant
Discharge Elimination System (NPDES) permit applications for Pamlico County's
Grantsboro, Kershaw, Millpond and Vandemere Water Treatment Plants. The
required application fee of $2,860.00 has been enclosed with the permit applications.
In addition to the permit applications, Engineering Alternatives Analysis has been
prepared for each of the water treatment plant sites.
If you have any questions for us regarding the permit application, please do not
hesitate to call me.
Very truly yours,
HAZEN AND SAWYER, P.C.
H. Thomas Tant, P.E.
Senior Associate
HTT:bpr
Enclosure
cc: Mr. Timothy A. Buck
Mr. Thomas Beasley
Ms. Alana Loughlin
Mr. David Laliberte
Hodge 09 14 06 Ur
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