NC0085707_Permit Issuance_19960801

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
August 1, 1996
Mr. Richard L. Schauer
Chairman of the Board
Cape Hatteras Water Association
P.O. Box 578
Buxton, NC 27920
A
CD E H tom! 11
Subject: NPDES Permit Issuance
Permit No. NCO085707
Cape Hatteras WTP
Dare County
Dear Mr. Schauer:
In accordance with the application for a discharge permit received on March 21, 1996, the
Division of Water Quality (DWQ) is forwarding herewith the subject NPDES permit. This permit is
issued pursuant to the requirements of North Carolina General Statute 143-213.1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection Agency
dated December 6, 1983.
The Division received comments on the draft permit on July 22, 1996 with a cover letter by Mr.
Eric Weatherly of Hobbs, Upchurch & Associates, P.A. The comments pertained to three primary
areas: the location of the discharge outfall, the monitoring requirements, and the timing and scheduling
of events.
The Location of the Discharge:
To minimize any environmental impacts and public nuisance issues, the discharge is initially
being located a distance of 1000 feet off shore. This site was selected to increase the likelihood that
the effluent will mix adequately with ambient waters. This distance should be sufficient to minimize
shore effects, keep the discharge submerged and protect people engaging in shoreline activities from
safety concerns in regard to the effluent pipe headworks. As you may be aware, a request for an
Authorization to Construct (ATC) is required prior to the installation of any discharge pipe or
headworks in the Pamlico Sound.
The Division is willing to reconsider the exact location of the outfall pipe pending the
submission of information demonstrating that ambient water quality will be adequately protected at
any specific alternative site that is proposed. For example, a shorter discharge pipe may be
acceptable if sufficient justification is provided with a request for a modification. In an effort to
further investigate the site, the Division recommends that you arrange a visit to the proposed
discharge location. Such a visit will identify and clarify issues of location and environmental
conditions at the site.
Regular Monitoring Requirements,
The effluent sheet of the draft permit contained weekly monitoring requirements for several
metals at the effluent. The Division feels that such a requirement will identify and quantify actual
amounts of these constituents in the effluent and therefore, does not recommend quarterly testing of
each production well. The Division will consider reducing or eliminating monitoring requirements for
specific metals if their concentrations can be shown to pose no reasonable potential to violate water
quality standards. The results of twelve or more sampling events should be sufficient to provide the
required information to make such a determination.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Schauer
August 1, 1996
Page 2
By definition all waters classified SA are High Quality Waters (HQW). The N.C.
Administrative Code 15A:2B.0201 (d) stipulates that TSS discharges shall be limited to 20 mg/1 and
limits for specific chemicals shall be allocated at one-half the normal standard at design conditions for
all HQW waters. The N.C. Administrative Code 15A:2B.0212 (b) stipulates that any discharge shall
not cause the turbidity in the receiving stream to exceed 25 NTU. The number "2" pertains to the
footnote and is not a limit. This has been clarified on the effluent sheet.
Monitoring Plan Requirements
To determine the effects of dispersion at the outfall and document the nature of any impacts
on ambient salinity, monitoring is required (see Part III, Condition F). The dye study is required in lieu
of simulation modeling, as the available dispersion models are not applicable to the current situation.
A site specific dispersion model could, in theory, be constructed but is likely to be considerably more
expensive than a dye study. The information produced by the dye study should allow the estimation
of how much dilution is occurring at different distances from the discharge point and in what direction
the effluent plume is moving. In addition, this study will:
• determine the actual dilution and dilution required to protect water quality.
• help to determine whether the discharge location is adequate.
• help to determine whether or not a diffuser is necessary.
Once the monitoring plan has been submitted, a determination can be made as to what changes
of discharge type or location, if any, will be required to protect water quality standards. The results
of this analysis may require additional construction.
The purpose of the salinity, conductivity and depth measurements are to see how these
parameters vary over time. Some biota are very sensitive to changes in salinity. The Division hopes to
document the extent of change in salinity and conductivity prior to and after discharge. At a
minimum, these measurements should take place during the 12 months prior to discharge (only at the
point of discharge) and the 12 months after commencement of discharge (at the point of discharge and
at the additional 16 locations). These measurements may be collected at the site by meter and do not
require lab analysis.
The Division does not disagree with the approach of performing the dye study prior to
discharge, however, it is important to make an accurate estimate in the location of the outfall to ensure
circulation patterns will be the same for an active discharge.
Timing and Scheduling:
The expiration date will remain as March 31, 1998 to keep the permit consistent with the
basinwide permitting strategy. This expiration date will also allow the Division to make appropriate
changes in the permit based on sampling data collected up to that point.
Language has been included in the Acute Toxicity Monitoring (Part III, Condition E) that make
this requirement take effect after the facility has commenced discharging. The language pertaining to
the dye study in the Monitoring Plan (Part III, Condition F) has been modified to allow for this study
to be conducted prior to discharge or after discharging has commenced. The requirement that the dye
study be conducted after the facility has been discharging for a period of four months has been
dropped.
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

Mr. Schauer
August 1, 1996
Page 3
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless
such demand is made, this decision shall be final and binding.
Please take notice, this permit is not transferable. Part II, EA. addresses the requirements to be
followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land Resources,
Coastal Area Management Act or any other Federal or Local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Steven D. Pellei at telephone
number [phone], extension 516.
Sincerely,
0.restoin ward, Jr., P.E.
cc: Central Files
Washington Regional Office
Mr. Roosevelt Childress, EPA
Mr. Ronald S. Huff, P.E.
Hobbs, Upchurch & Associates, P.A.
290 S. W. Broad Street
P.O. Box 1737
Southern Pines, North Carolina 28388
Permits and Engineering Unit
Facility Assessment Unit
Aquatic Survey and Toxicology Unit

Permit No. N00085707
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, 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,
Cape Hatteras Water Association, Inc.
is hereby authorized to discharge wastewater from a facility located at
Cape Hatteras Water Association Water Treatment Plant
Water Plant Road
Buxton
Dare County
to receiving waters designated as the Pamlico Sound in the Pasquotank River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III, and IV hereof.
The permit shall become effective September 1, 1996
This permit and the authorization to discharge shall expire at midnight on March 31, 1998
Signed this day August 1, 1996
1
1 Av..'
- -
A --Preston ard, Jr., P.E., Director
ivision of Water Quality
By Authority of the Environmental Management Commission

I
SUPPLEMENT TO PERMIT COVER SHEET
Cape Hatteras Water Association, Inc.
is hereby authorized to:
Permit No. NC0085707
1. After receiving an Authorization to Construct, construct and operate a conveyance system
for reject water from a reverse osmosis plant located at Cape Hatteras Water Association,
Water Treatment Plant, Water Plant Road, Buxton, NC, Dare County, and
2. Discharge reject water from a reverse osmosis treatment plant at the location specified on the
attached map into Pamlico Sound which is Class SA waters in the Pasquotank River Basin.

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'M FEET P4A—, -.ERAS 5.9 rtr
N �d Geodetic Survey
-ological Survey
ROAD CLASSIFICATION
PRIMARY HIGHWAY UGNT-0UTY ROAD. HARD OR
HARD SURFACE IMPROVED SURFACE
SECONDARY MGKWAY
HARD SURFACE 0:200= UNIMPROVED ROAD
Latitude 35016' 00 Longitude 750 35' 08"
Map # F36SE Sub -basin 030155
Stream Class SA
Discharge Class 100% Industrial
Receiving Stream Pamlico Sound
Design 0 1.8 MQD Permit expires 3/31 /98
1446 1 447 "48
1 5
SCALE 1:24 000
CONTOUR INTERVAL 10 FEET
QUAD LOCATION Cape Hatteras Water Assoc.
NCO085707
Dare County
WTP

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Permit No. NCO085707
Upon operation of a Reverse Osmosis Water Treatment System and lasting until expiration, the Permittee is authorized to
discharge from outfall(s) serial number 001 - Reverse Osmosis Treatment Reject Discliarge. Such discharges shall be limited
and monitored by the Permittee as specified below:
Flow
Total Suspended Solids
Settleable Solids
Turbidity2
Arsenic
Beryllium
Cadmium
Chloride
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Salinity
Selenium
Silver_
� - ----- --- ---
Acute Toxicity3
Discharge Limitations
Monthly, Avg, Daily Max.
1.8 MGD
20.0 mg/l 35.0 mg/l
0.1 ml/I 0.2 ml/I
A -3
Monitoring
Measurement
ggaulrements
Sample
Frequency
Type
Sample
Locations
Continuous
Recording
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent2
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Weekly
Grab
Effluent
Quarterly
Composite
Effluent
Footnotes:
I Samples shall be collected at some point after exiting the RO unit and prior to discharge to the Pamlico Sound, unless otherwise noted.
2 The discharge shall not cause the turbidity of the sound water at the discharge point to exceed 25 NTU. If the turbidity exceeds these levels
as a result of natural background conditions, the discharge level cannot cause any increase in the turbidity in the receiving water.
3 Acute Toxicity I'/F Monitoring (Mysidopsis bahia) @ 80%. See Part 111, Special Condition E. Further studies will be required to determine
the cause of toxicity, if any.
The Pennittee shall perform a study at the proposed point of discharge as specified in Part III, Special Condition F.
The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units and shall be -monitored weekly at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Part III Permit No. NC0085707
E. ACUTE TOXICITY PASS/FAIL MONITORING(QRTRLY)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North
Carolina Procedure Document entitled "Pass /Fail Methodology For Determining Acute Toxicity In A
Single Effluent Concentration." The monitoring shall be performed as a Mysidopsis bahia 24 hour static
test, using effluent collected as a 24 hour composite. The effluent concentration defined as treatment
two in the North Carolina procedure document will be 80% . Effluent samples for self -monitoring
purposes must be obtained during representative effluent discharge below all treatment components and
prior to mixing with the receiving waters. Unless the facility has not commenced discharging, the first
test will be performed after thirty days from the effective date of this permit during the months of
January, April, July, and October.
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
TGE3E. Additionally, DWQ Form AT-2 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of Water Quality
4401 Reedy Creek Road
Raleigh, N.C. 27607
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 of the waste stream.
Shall 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 body of water, 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 retesting (within 30 days of initial monitoring event). Failure to submit suitable test
results will constitute noncompliance with monitoring requirements.

Part III
F. MONITORING PLAN
Permit No. NC0085707
Beginning with the issuance of the permit, salinity and conductivity shall be measured twice per month
at the proposed point of discharge. Once the plant begins discharging, salinity and conductivity shall be
measured twice per month at the point of discharge and at 16 locations surrounding the discharge point.
As shown on the attached diagram, this radial sampling design specifies monitoring locations at
distances of 10, 50 and 100 meters from the outfall. At each location, sampling shall be performed at
the surface �� �} arm a - y --- - 1T�� The depth of water shall be measured
at the point of discharge during each sampling event.
A dilution study shall be conducted to determine circulation patterns in the area of the discharge, to
predict the behavior of the effluent plume, and to determine the extent of actual dilution. This study
shall be conducted during a relatively calm period, when the effect of wind tides is minimal. The
dilution study shall involve injection of a fluorescent tracer (dye) and the measurement of depth of water
at the point of discharge. When the study is conducted, the dye shall be injected into the effluent of the
facility if the facility is operational, or if the facility is not yet operational , the dye shall be injected into
the receiving waters at the proposed point of discharge. The dye shall be injected at a constant rate for
at least 24 hours, longer if a more extended period is necessary to obtain steady state conditions., wd. ; if
During the initial 16 hours of the study, dye concentrations shall be measured every 4 hours at each 4111 c „�
sampling location designated on the attached diagram. These locations are identical to those at which }el
salinity and conductivity monitoring is conducted, with the addition of 8 sampling stations located 200
meters from the discharge site. Beginning 16 hours after dye injection is initiated, samples shall be!
collected every 2 hours until equilibrium conditions are reached. The permittee must demonstrate to the
satisfaction of the Division of Water Quality that steady state conditions were obtained during the
study. The results of the completed dye study shall be submitted to DWQ by Derembnc:4'r, }S7r, if the
discharge of the plant has commenced prior to that date.
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LOCATION OF SALINITY/CONDUCTIVITY MONITORING STATIONS:
10, 50 AND 100 METERS FROM POINT OF DISCHARGE
LOCATION OF DYE STUDY MONITORING STATIONS:
10, 50, 100 AND 200 METERS FROM POINT OF DISCHARGE

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Permit No. NCO085707
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
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,
Cape Hatteras Water Association, Inc.
is hereby authorized to discharge wastewater from a facility located at
Cape Hatteras Water Associatio 4ad
ter Treatment Plant
Water Plant
Buxton.14&- _,
Dare County
to receiving waters designated as the Pamlico Sound in the Pasquotank River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III, and IV hereof.
The permit shall become effective ¥¥¥¥¥, 1996
This permit and the authorization to discharge shall expire at midnight on/March 3 1998
Signed this day VY W¥, 1996
DRAFT
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

SUPPLEMENT TO PERMIT COVER SHEET
Cape Hatteras Water Association, Inc.
is hereby authorized to:
Permit No. NC0085707
1. After receiving an Authorizarion to Constuct, construct and operate a conveyance system for
,,-true water from a reverse osmosis plant located at Cape Hatteras Water Association, Water
L10
\ Treatment Plant, Water Plant Road, Buxton, NC, Dare Countyffwe '1 arkI$rof tli4s Fe�,
and
k q
1"4
2. Discharg�r�ev se osmosis treatment p trnext �roerles at the location
specified on the attached map into Pamlico Sound which is lass SA waters in the
Pasquotank River Basin. 7

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NCO085707
Upon operation of a Reverse Osmosis Water Treatment System and lasting until expiration, the Permittee is authorized to
discharge from outfall(s) serial number 001 - Reverse Osmosis Treatment / - Discharge. Such discharges shall be limited
and monitored by the Permittee as specified below:
Effluent Characteristics Discharge Limitations may( Monitoring Requirements
Measurement Sample Sample
Monthly. Avg, Daily Max. y3SFreguencv Type Location'
Flow 1.8 MGD Nix.4)( Continuous Recording Effluent
Total Suspended Solids 20.0 mg/I 3S/ -A-5�0 mg/I Weekly Grab Effluent
Settleable Solids 0.1 ml/I 0.2 ml/I Weekly Grab Effluent
Turbidity 2 2 Weekly Grab Effluent2
Arsenic Weekly Grab Effluent
Beryllium I Weekly Grab Effluent
Cadmium > 'or-i� (dlj" ' 4<6A7.5nIII71 � Weekly Grab Effluent
Zhro� mium / Weekly Grab Effluent
Copper Weekly Grab Effluent
Cyanide Weekly Grab Effluent
Lead Weekly Grab Effluent
Mercury Weekly Grab Effluent
Nickel Weekly Grab Effluent
Salinity Weekly Grab Effluent
Selenium Weekly Grab Effluent
Silver Weekly Grab Effluent
Zinc Weekly Grab Effluent
Acute Toxiclgv 4 Quarterly Composite Effluent
Footnotes:
Golly
i Samplgshall be t kt It at some point after exiting the RO unit and prior to discharge to the Pamlico Sound, unless otherwise noted.
2 e discharge shall not cause the turbidity of the sound water at the discharge point to exceed 25 NTU. If the turbidity exceeds these levels
ds r«ftlae-w natural background conditions, the discharge level cannot cause any increase in the turbidity in the receiving water.
After six months of data c ion in ' ttn a ' o etectio
f the e e art III, S cial Condition F.

Acute Toxicity P/F Monitoring (Mysidopsis bahia) @ 80%. See Part III, Special Condition E. Further studies will be required to determine
the cause of toxicity, if any.
The Permittee shall perform a study at the proposed point of discharge as specified in Part III, Special Condition G.
The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units and shall be monitored weekly at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

f �
Part III Permit No. NC0085707
E. ACUTE TOXICITY PASS/FAIL MONITORING(QRTRLY)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North
Carolina Procedure Document entitled 'Pass/Fail Methodology For Determining Acute Toxicity In A
Single Effluent Concentration." The monitoring shall be performed as a Mysidopsis bahia 24 hour static
test, using effluent collected as a 24 hour composite. The effluent concentration defined as treatment
two in the North Carolina procedure document will be 80% . Effluent samples for self -monitoring
purposes must be obtained during representative effluent discharge below all treatment componenets
and prior to mixing with the receiving waters. The first test will be performed after thirty days from the
effective date of this permit during the months of January, April, July, and October.
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
TGE3E. Additionally, DEM Form AT-2 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
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 of the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving body of water, 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 retesting(within 30 days of initial monitoring event). Failure to submit suitable test
results will constitute noncompliance with monitoring requirements.
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G. MONITORING PLAN
A study to investigate the environmental conditions prior to, and during discharge, shall be completed at
pp,, (( the proposed point of discharge. The study shall include at a minimum: a map locating shellfish bedsj�
G�,J� der 3the vicinit;. ofof theme and a submerged aquatic vegetation survey, '
sl�ellfistr, a dilution study and a study of salinity/chloride levels and water leve m e vicuuty of the
rs arge pipe. The study plan shall be developed in accordance with DEM guidance, finalized within
90 days of the permit issuance date and submitted to DEM for review and approval.
Specific details of the monitoring plan would be mutually agreed upon by DEM and the CHWA
following issuance of the permit but prior to the initiation of any construction. The monitoring plan for
the first permit period has three components:
(1) Monitoring of salinity, conductivity and water level;
(2) Baseline and post -discharge monitoring of submersed rooted vasculars (SRV) ;
(3) A dye study,
Salinity and conductivity at the site of the proposed outfall should be measured twice per month
beginning with the issuance of the permit. Once the plant begins discharging monitoring should occur as
follows. Salinity and conductivity should be measured twice per month at the point of discharge and at
a matrix of locations surrounding the discharge point. Sampling should be conducted at
�lecations within 100 meters of the outfall. At each location, sampling should be performed at the
surface and t approximately one meter increments of depth. The water level should be measured at the
point of dfs arge at the same time that salinity and conductivity are measured. WP4'� ha ✓iAdV
A baselines ey showing the location of SRV (formerly referred to a merged aquatic vegetation _ SItiJJ�
should be conducted prior to any construction activi m amlic ound:' The survey sly repeated
after the plant has been discharging for a period o east tw . If a survey delineating the current
location of aquatic vegetation at the site already exists and was conducted at an appropriate scale, the
results of such survey may be submitted in lieu of conducting the baseline survey, upon approval by
DEM. The post -discharge SRV survey must be conducted in either case.
Priorthe ' tiati of any co traction activi she sh ould a collet d and ue s plf
anzed fttthe olio g substance ante . Hg, Cd, ' Th a are t 6 meta or �e A has
renti set seree levels for /shellfish ssue. amnl shoal a tolled an prevazec
the Water ,Quality,Sectioq%s Stand ,OdOpe�ting P�bcedures Manual for
e. The shellfisl sfimpl'
should be limited to an area
within 100 meters of the outfall
distance. Sic .Y t Sluts.
Once the facility has been discharging for a period of at least 6 months, a, dye study should be
conducted to determine circulation patterns in the area of the discharge and the behavior of the effluent
plume. The design of the study should be approved by DEM. The dye study should be conducted
during a relatively calm period, when the effect of wind tides is minimal.
'h �Yoc..li r�z Ord �:.C..: .).. �, w,y e 1 � ,J ::.n �.: ��% %1 �•C��� �Q�
H. O L OLLUTANALYSIS •. , d;,:, _,,:. S„ p, ,,., p�;.
A m le pol tant alysis shal b ompleted .4ae
first3dasi addi ' nal o utant resen in the dis azrrenti eP d e conv tipl d n conve tional•pol tifle y ane esent ' the. s azee If anv fthese no utane a ove the et mit the shall be
added to thLligt of Oolluta) is being monitorna and will be trd fof weekl{/by grab
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dWhat 4rl1�7���

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Health
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Linda C. Sewall, Director
July 31, 1996
MEMORANDUM
IDEHNFR
TO: Mr. David Goodrich
NPDES Permits Group Leader
Discharge Permits Unit
Division of EnYironmental Management
FROM: Linda Sewall)DDirector
u,
Division of Environmental Health
SUBJECT: Draft National Pollutant Discharge
c�
Elimination System Permit
Cape Hatteras Water Association, Inc.
Cape Hatteras Water Association Water Treatment Plant
p- -
Water Plant Road
Buxton
"
Dare County
Permit No. NCO085707
Reference is made to the above mentioned Draft National Pollutant Discharge Elimination
System Permit. We have reviewed this permit application and determined that the proposed
discharge will not adversely affect any SA waters.
We concur with the issuance of this proposed permit provided the facility is operated and
maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not
contravene the designated water quality standards.
If we can be of further assistance, please contact us.
LS/RG B/pf
cc: Rick Durham
M. P. Bell
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street * Raleigh, North Carolina 27611
James B. Hunt. Jr., Governor
Facsimile Cover Sheet
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Fax: (itq) i Z6- s41 s
From: ST EVC—e,3 b • Ptt.t_6
Phone: [phone] —,SIG
Fax: [phone]
pages, including this cover sheet.
Comments:
Jonathan B. Howes, Secretary
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P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax: [phone]
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.kemorandum
Re:
Cape Hatteras RO Plant
Date:
July 5,1996
From:
Steve Pellei
To:
Dave Goodrich
This memo summarizes the letters received commenting on the Cape Hatteras RO Plant.
The proposed permit was Noticed on May 19,1996.
The public comment period closed on June 19, 1996.
Letter received March 8,1996, from L. Browning (resident of Frisco):
Mr. Browning expressed concerns over the effects of this discharge on the already declining
water quality of the sound. He raises several question on the method and location of the
discharge point, and the effects on the fish and bottom grasses.
Finally, Mr. Browning asks whether this permit will fly threw the system like the Rodanthe
RO plant due to the political clout of prominent parties.
Letter received June 14,1996, from D. E. Williams (commercial fisherman and property
owner in Buxton):
Mr. Williams objects to the discharge. He states the additional water will jeopardize the
harvest area while only helping those few "who will develop, sell and move". He feels this
breeding ground should be given more consideration and that the Environmental
Assessment is not convincing in its statement that "the discharge should have no negative
potential impact on plant or animal life in. the sound" and , "we know of no negative
potential impact to shellfish water." His discussions with experts indicate that there will be
an adverse impact on all shellfish. He suggests that the Rodanthe RO plant discharge site
should be studied carefully in order to determine the effects of such discharges prior to
issuance. The current discharge to Peter's Ditch has already caused problems with sludge
being flushed into the sound, further intensifying the wastewater discharge problem. Any
sludge produced should be kept on site to be monitored and controlled.
The following were received after the close of the public comment period:
Letter received June 21,1996, from E. J. Geiger (rental property owner):
Mr. Geiger expressed concerns over the additional development on the island that will
naturally follow due to the increased availability of potable water that this discharge will
allow. Specifically, he was concerned about the increased population, number of septic
systems and the evacuation problems in the event of a hurricane. These problems will
stress the already stressed resources of the island.
Letter received June 24,1996, from S.B. West (NC Fisheries Assoc.,* President):
The association represents commercial fishing families dependent upon the Pamlico Sound
for its productive nursery area and numerous fish species. The association is "concerned
that the increase in salinity and bioaccumulation of metals will have an impact on the
stability of the Pamlico estuary, negatively impacting finfish and shellfish as well as
submerged vegetation." The letter points out that the Environmental Assessment does not
contain complete information on the salinity tolerance s of some species and neglects to
include other species. Finally, the letter urges the EMC to use caution in its consideration of
this permit.

V ED
r Lou Browning
ti R. PO Box 275 MAR g 1906
C . Frisco, NC 27936
r Voice/Data 919.995.5743
Fax [phone]
To: Division of Enviro ent41lealth and Natural Resources
From: Lou Browning
Re: R.O. discharge permit for Dare Cou (Hatteras Island)
Date: February 27, 1996
Dear Environmental Specialist,
I understand that Dare County is trying to get a permit for an R.O. waste water
discharge into the Pamlico Sound. As I'm sure you're already aware, the Pamlico Sound
is a major marine estuary for the Atlantic seacoast. We coastal residents have watched 0)
our water quality decline for many years as the coastal areas continue to grow. Most
shellfishing grounds close to shore have been closed by Marine Fisheries due to high
fecal coliform counts. These closures have certainly been caused by septic runoff and CO
leaching from the many new and old dwellings built on the island.
To add a new source of potential contaminates to the sound, surely dictates that
environmental studies and much forethought be given this situation and its overall effects c
on the entire coast. The raw water that is going to be used for the R.O. plant is high in
chlorides and other naturally occurring substances. When these impurities are removed
from the potable water, they will be concentrated,. then partially diluted and dumped into
the sound.
Are any of these substances going to be at "toxic" levels? Will there be a single
point discharge or multiple heads? Will the discharge be close to shore, in a creek, off
shore, or on the west side of the shoals? If a pipe discharge system is run out into the
sound, what will the effects of the construction be on bottom grasses? What will the
long term effects be on the fish and plant life of the sound? Will the discharge water
quality be monitored for changes that are likely to occur as the deep wells chloride levels
inevitably increase?
These are questions I am curious about and think need to be answered. Will an
environmental impact study be required for this permit and if not, why? It surely will
have an environmental impact.
I understand that the permit for the Rodanthe R.O. plant flew through the system
because of political clout of prominent Dare County interested parties. Is this going to be
a similar situation?
Thank you for your time. Please keep me informed as -to the progress of this
permitting process.

Dennis E. Williams
50234 Indian Ridge
P. 0. Box 1028
Buxton, N.C. 27920
May 29, 1996
Mr. Dave Goodrich
NC Division of Environmental Management
Post Office Box 29232
Raleigh, North Carolina 27626-0535
Re: Cape Hatteras Water Association
Wastewater Discharge Plan
Dear Mr. Goodrich:
As a commercial fisherman with a NC State Shellfish Lease and a property
owner near the proposed discharge site, I object to this proposed
wastewater discharge plan for numerous reasons.
The environmental assessment prepared by consultants Hobbs, Upchurch, and
Associates, reports; "the discharge should have no significant impact on
plant or animal life in the sound," and, "we know of no negative
potential impact to shellfish waters." These are not convincing
statements considering the potential impact on marine life in the Pamlico
Sound.
Certainly the discharge of high concentrates of minerals, salt and other
contaminants into waters that serve as a breeding ground for marine life
for the entire area of eastern North Carolina should receive more
consideration than a presumption that this discharge should not adversely
impact on marine environment.
Experts whom I have discussed my concerns with have indicated that the
wastewater discharge will in fact have an adverse impact on all shell
fish. Local oystermen from Ocracoke who have experienced first hand the
results of wastewater discharge from a reverse-osmis plant confirm this
fact.
Although the Rodanthe plant has been in operation only a short time, the
discharge site should be studied carefully to determine the impact on
marine life before issuing permits in the Buxton area.
The current discharge site at Peter's Ditch shows a tremendous buildup of
sludge. Periodically some of this sludge gets flushed into the sound by
high tides and heavy rain fall. When this occurs a very distinct
degrading of water quality occurs in the sound.
rye
C G

Mr. Dave Goodrich
May 29, 1996
Page 2
The increased water production expected from the proposed reverse-osmis
plant will intensify the wastewater discharge problem regardless of the
discharge site. But sending it directly into an environmentally
sensitive area is in my opinion totally irresponsible.
Winter storms with strong N'West winds will push the contaminants toward
the shore, covering oyster beds, crabbing grounds and eventually the back
yards of waterfront property owners. KEEP THIS SLUDGE CONTAMINANT ASHORE
WHERE IT CAN BEST BE MONITORED AND CONTROLLED.
Please consider carefully the impact on resident commercial fishermen
who's livelihood depends on a clean and healthy harvest area. The
potential risk of harm far outweighs the need for additional water to
satisfy those few individuals who will develop, sell and move.
I will be convinced that this proposal should go forward only when I see
an environmental assessment that says; the discharge of wastewater into
the Pamlico Sound shall not adversely impact on marine life and the
pumping of water from the newly installed wells shall not adversely
impact residents who depend on shallow wells for their water.
thank you for considering my comments regarding this proposed project.
Sincerely,
IS E. WILLIAMS

06121 / 1996 07: 56 9199954131. H/0 AU}{-4CFA
Hatteras -Ocracoke Auxiliary
North Carolina Fisheries Association
P.O. Box 163
Buxton, N.C. 27920
June 20, 1996
NPDES Permits
Environmental Management Commission
P.O. Box 29535
Raleigh* N.C. 27626-0535
Via Fax: [phone]
RE: NPDES No. NCO085707
PAGE 01
Hatteras Islands commercial fishing families have a strong
interest in the health of the Pamlico Sound. Many of our
families set crab pots, pound nets, or gill nets, harvesting fish
and shellfish directly from the Pamlico Sound. In addition, our
families are highly dependent on the well-being of the'Pamlico
which is a large and productive nursery area for numerous species
of fish.
Our very direct dependence on the health of the Pamlico Sound
obviously leads to a concern over the discharge of 1.8 million
gallons per day of reject water into the Pamlico from a reverse
osmosis plant. We are concerned that the increase in salinity
and the bioaceumulation of metals will have an impact on the
stability of the Pamlico estuary, negatively impacting finfish
and shellfish as well as submerged vegetation.
The Environmental Assessment for Expansion of Cape.Hatteras
Water Association Treatment Capacity, prepared by Hobbs,
Upchurch, and Associates in March 1996, contains a chart listing
salinity tolerances for some species of finfish caught in the
Pamlico. The chart doesn't appear to be complete, however, and
lacks tolerances for some Species and neglects to include other
species, such as southern flounder, which are important to
fishermen in this area.
We also noticed that the Environmental Assessment contains no
information on the temperature of the proposed discharge and the
effects on associated water quality standards.
We urge the Environmental Management Commission to use caution
in consideration of this permit, considering the broad spectrum
of ecological changes that could upset the stability of this
important estuary. •
neerely,
Susan Ir West
President
919-995 -4131 (T/F)

June 14,1996
Mr. Dave Goodrich
North Carolina Division of
Environmental Management
Post Office Box 29232
Raleigh, NC 27626-0535
Re: Cape Hatteras Water Association's Request
for a Reverse -Osmosis Discharge Permit
Dear Mr. Goodrich:
I respectfully request that you consider the environmental impact the issuance of the above
referenced permit would have on the future of this barrier island. This island is, after -all,
not much more than a thin sandbar twenty miles offshore, a fragile thing to say the least.
Over the past several years a number of attempts have been made to provide the southern
half of this island with additional water so that development may continue. The island in
its own way has, time and again, said I can not supply more water.
If you are only charged with determining whether or not the discharge from a reverse -
osmosis plant will harm plant and aquatic life in the Pamlico Sound I suspect the permit
will be approved. However, if you were to consider the environmental implications the
additional water will have on the development of this island you may find dire
��r ca- cpwrgLPy �/nces.
The North Carolina Department of Transportation has already expanded the ferry landing
site at the south end of the island in anticipation of future increased north/south traffic
flow, adding 17 traffic lights in an area about the size of a football field. Prior to that the
entire island had only one, very questionable, traffic light. _
One need not be Nostradamus, to envision the environmental future of this island once
additional water becomes available. Construction will boom, more septic systems will mean
the possibility of more seepage into Pamlico Sound, and Route 12 the only north -south
road on the island will become increasingly stressed. This last consideration is probably the
most important. Picture the island once it becomes over -built and a hurricane evacuation
becomes necessary. This is a frightening scenario, which I hope will cause everyone to

consider not just the next step (the discharge permit) on this slippery environmental slope,
but the next step and the next step, etc.
I thank you for your time and consideration in this matter.
Sincerely,
t
Edward J, Geig , Rental Property Owner on the Island
305 Signey Lane
Somerdale, NJ 08083
1-609-346-4804
cc: To Editor, Island Breeze

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injection of a fluorescent tracer (dye) and the measurement of depth of water at the point of discharge. When
the study is conducted, the dye shall be injected into the effluent of the facility if the facility is operational, or if
the facility is not yet operational , the dye shall be injected into the receiving waters at the proposed point of
discharge. The dye shall be injected at a constant rate for at least 24 hours, longer if a more extended period is
necessary to obtain steady state conditions. During the initial 16.hours of the study, dye concentrations shall
be measured every 4 hours at each sampling location designated on the attached diagram. These locations are
identical to those at which salinity and conductivity monitoring is conducted, with the addition of 8 sampling
stations located 200 meters from the discharge site. Beginning 16 hours after dye injection is initiated,
samples shall be collected every 2 hours until equilibrium conditions are reached. The permittee must
demonstrate to the satisfaction of the Division of Water Quality that steady state conditions were obtained
during the study. The results of the completed dye study shall be submitted to DWQ by December 31, 1997,
if the discharge of the plant has commenced prior to that date.

injection of a fluorescent tracer (dye) and the measurement of depth of water at the point of discharge. When
the study is conducted, the dye shall be injected into the effluent of the facility if the facility is operational, or if
the facility is not yet operational , the dye shall be injected into the receiving waters at the proposed point of
discharge. The dye shall be injected at a constant rate for at least 24 hours, longer if a more extended period is
necessary to obtain steady state conditions. During the initial 16.hours of the study, dye concentrations shall
be measured every 4 hours at each sampling location designated on the attached diagram. These locations are
identical to those at which salinity and conductivity monitoring is conducted, with the addition of 8 sampling
stations located 200 meters from the discharge site. Beginning 16 hours after dye injection is initiated,
samples shall be collected every 2 hours until equilibrium conditions are reached. The permittee must
demonstrate to the satisfaction of the Division of Water Quality that steady state conditions were obtained
during the study. The results of the completed dye study shall be submitted to DWQ by December 31, 1997,
if the discharge of the plant has commenced prior to that date.

b,/
Memorandum t �
Re:
Cape Hatteras RO Plant
Date:
June 27,1996
From:
Steve Pellei
To:
Dave Goodrich
Eric Weatherly and Ron Huff of Hobbs Upchurch c
several questions / concerns about the draft permit i
Some of their questions were answered and some I
Their questions / concerns and my responses
Why are we requiring a discharge 1000 feet
analysis at the shore?
sP� I�', 1000 feet is arbitrary but not unreasonable '
��r�� discharge location. This preliminary dist cf
S�cLI� �qL� and keep the discharge submerged and dd4
people engaging in shoreline activities om s
s s T � ' headworks. Lastly, dispersion is likel to be
�A
What if the 1000 feet is not enough
DEM is looking at this as a two phase proo
need a study, hence our Monitoring Plan R
made as to what changes of discharge type
quality standards. After which additional
required before because dispersion pats
discharge, especially considering the size
Who is going to do the study?
t ST J w�I 6e use , _I
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T 'S S Sand �o(S'r", 6�T40
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(� v�c�/-'L us to Tie
r.V%y CON P Ic �'hrs , cc cS�
.1/�do/6/26/96 and 6/27/96 with
r the proposed Cape Hatteras RO Plant.
rill eed to get back to them. ,& l
is iFc
z be as follows:
re? Why can't we just start our
l
light Of the fact that we were not given an exact
sho d be sufficient to minimize shore effects,
m fr m shore. This distance should also protect
;afy concerns in regard to the effluent pipe
batter the greater the distance from shore.
�s. Since we don't know dispersion effects we
quirement. After which a determination can be
)r location will be required to protect water
)nstruct may be required. This study was not
could be very different without an active
this discharge. ` 4 A y o ,�,�,T� � 'r .3 &/ /s t,
ZP To YPrcvcl Jr4- C,1.
�r° FQc, The study is to be done by the Permittee. If ey want to just give us the sampling results,
crunching the numbers is the easy part per ji Bloise. Jim suggests that they can request to
r� Slei �,� have some DEM folks out there to ensure it is one in a way that will meet the information
�Tr1�y ,,needs of DEM.
T.rei- r , L-f
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Since there are no good computer models. What will the stud do for us? 6.�mod cis is
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The information produced by the monitoring should tell us how much dilution you are r l c ch Iy
getting at different distances from the discharge point and in what direction the plume is
moving.
Isn't the number of points and other requirements a bit much for the monitoring plan?
Maybe we need the Coast Guard out there for this.

The radial design and the number of locations was determined by Jim Blose ber.
These should be adequate to provide the information we need and should not prove too
burdensome considering the time and distances involved. The proposed site of discharge
may be shallow enough to wade in.
What if construction is incomplete or they are not discharging before Dec.1997 (the due
date of the study)? Ron said he'd be surprised if they were discharging by the end of 1997.
If that is the case we may reissue the permit for a period of only a year or so and require the
dye study to be submitted. After which a determination will be made as to the discharge
structure.
What happened to our two year grace period for Toxicity?
The toxicity requirement is for monitoring only right now and not a limit. You can still fail
your toxicity test and be compliant, however this might not be prudent.
Is the equilibrium dilution something we estimate prior to or after we conduct the study?
The equilibrium dilution is what we will be able to reasonable estimate from the results of a
dye study conducted during steady state conditions. To ensure steady state conditions are
met the study should be a minimum of 24 hours, conducted during calm weather, and
concentrations should stabilize out at various locations.
What are the effects of the comment letters?
i
Don't know yet. The Director hasn't determined whether a Public Hearing will be held or
1 not.
Just to throw it out, what if we diluted the discharge with sound water prior to discharge?
Don't know. OKAAr C-oltvz( S,,1jtI)A-.S � 6t�Itli� `%K E �1 wOvIQ
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Page 1
Note for Steve Pellei
From:
Dave Goodrich
Date:
Thu, Jun 27, 1996 12:50 PM
Subject:
RE: Cape Hatteras RO WTP
To:
Steve Pellei
This can be sent up for issuance. I would summarize the comments you received in your
permit development notes. As for the ATC, I would tell them we would like them to submit
an ATC request for the extension of the outfall. This is SOP. Finally, as for the Press, I
would tell Reuter that we are in the part of the process where we decide whether or not to
hold a public meeting. Should have word within the next week or two.
From: Steve Pellei on Wed, Jun 26, 1996 10:59 AM
Subject: Cape Hatteras RO WTP
To: Dave Goodrich
Status:
Don Reuter came by to check on the status of this permit. He received a call from the
Island Breeze inquiring about the status of this permit. The comment period closed on
6/19/96 and there have been only two letters received to date. Although we have received
several phone calls, most of these were requests for additional information (i.e. pertaining to
the location of the discharge, route of the pipe, etc.). I confirmed receipt of the draft package
and copies of the two comment letters, by Ron Huff (Hobbs Upchurch) on 6/24/96.
What happens next?
Call from the Region:
Al Hodges called this morning and strongly requests that we require an ATC for the
discharge pipe to minimize any environmental impacts. He feels a review by DEM, Marine
Fisheries, and Coastal Management of the construction plans and proposed location is
necessary. Lastly, although this pertains just to a conveyance system, his understanding is
that requiring an ATC is SOP for this type of discharge.
Do we, or are we going to require an ATC for this, or can language be added to require
coordination of the location and installation of any discharge piping to be through the regional
office?

DIVISION OF ENVIRONMENTAL MANAGEMENT
May 15, 1996
MEMORANDUM
TO: Coleen Sullins
Dave Goodrich
FROM: Jim Blose p O
THROUGH: Steve Bevington,P
Ruth Swanekq, 5
SUBJECT: Sampling Plan for Cape Hatteras Water Association (NC0085707)
At our meeting on May 9th we discussed the need for special sampling requirements for the discharge into
Pamlico Sound from the Cape Hatteras Water Association's (CHWA) proposed water treatment plant. We
concluded that, due to a combination of circumstances, water quality and ecological sampling requirements
were necessary to assure that any toxic impacts of the discharge could be identified and that appropriate
remedial actions could be specified if necessary. These circumstances include the classification of Pamlico
Sound as SA/HQW, the large volume of the discharge compared to other reverse osmosis facilities, the
continuing concerns raised by other agencies and the general public, and the limited information currently
available. It is also worth noting that the March 1996 Environmental Assessment acknowledged the need
for additional biological investigations (p. 22): "In order to gauge the effects of the discharge on aquatic
species, an aquatic survey will be conducted before the proposed discharge begins. The surveys cannot be
performed at this time because the season is not optimum for such studies. This survey will be repeated
after a specified period of time to determine what effects are being seen on aquatic species."
This memo summarizes the general nature of the recommended monitoring requirements. Specific details
of the monitoring plan would be mutually agreed upon by DEM and the CHWA following issuance of the
permit but prior to the initiation of any construction. The monitoring plan for the first permit period has
three components:
(1) Monitoring of salinity, conductivity and water level;
(2) Baseline and post -discharge monitoring of submersed rooted vasculars (SRV) and shellfish;
(3) A dye study.
Salinity and conductivity at the site of the proposed outfall should be measured twice per month beginning
with the issuance of the permit. Once the plant begins discharging monitoring should occur as follows.
Salinity and conductivity should be measured twice per month at the point of discharge and at a matrix of
locations surrounding the discharge point. Sampling should be conducted at no fewer than 12locations
within 100 meters of the outfall. At each location, sampling should be performed at the surface and at
approximately one meter increments of depth. The water level should be measured at the point of discharge
at the same time that salinity and conductivity are measured.
A baseline survey showing the location of SRV (formerly referred to as submerged aquatic vegetation)
should be conducted prior to any construction activity in Pamlico Sound. The survey should be repeated
after the plant has been discharging for a period of at least two years. If a survey delineating the current
location of aquatic vegetation at the site already exists and was conducted at an appropriate scale, the

results of such survey may be submitted in lieu of conducting the baseline survey, upon approval by DEM.
The post -discharge SRV survey must be conducted in either case.
Prior to the initiation of any concoction activity shellfish should be collected and tissue samples analyzed
for the following substances: Hg, Cd, Se. These are the metals for which the EPA has currently set
screening levels for fish/shellfish tissue. Samples should be collected and prepared following procedures
outlined in the Water Quality Section's Standard Operating Procedures Manual for Physical and Chemical
Monitoring. The shellfish sampling should be repeated after the plant has been discharging for at least two
years. The SRV surveys and shellfish sampling should be limited to an area within 100 meters of the
outfall, if a quantity of shellfish adequate for testing can be found within that distance.
Once the facility has been discharging for a period of at least 6 months, a dye study should be conducted to
determine circulation patterns in the area of the discharge and the behavior of the effluent plume. The
design of the study should be approved by DEM. The dye study should be conducted during a relatively
calm period, when the effect of wind tides is minimal.
The information collected will be used as follows.
Salinity and conductivity. The Division of Marine Fisheries has raised concerns regarding a potential
increase in local salinity, but how the discharge may affect salinity in the area of the discharge and the size
of any zone of impact are unknown. The sampling will enable us to address this issue as well as aid in
determining whether a diffuser is necessary. The proposed sampling frequency will provide a sufficient
number of observations for useful analysis, and should assure that a wide range of ambient conditions is
encountered.
SRV and shellfish. The Division of Marine Fisheries and some fisherman have raised concerns regarding
long-term toxic effects. WET testing may not address toxic impacts to plants, nor the potential human
health impacts associated with the accumulation of toxicants by shellfish. Measurement of the location of
rooted aquatic vegetation and the concentration of various toxicants in shellfish tissue is the most direct
way to assess these impacts. Trends in aquatic vegetation in the area of the discharge will be used to
assess whether changes in plant operations or additional limits are necessary. The shellfish analysis will be
used to determine if the tissue concentration exceeds EPA screening levels for those toxicants for which
such levels have been established (Hg, Cd, Se). Extension of the discharge pipe, the addition of a diffuser,
and/or limits for specific toxicants may be necessary to address any problems identified.
Dye study. Knowledge of circulation patterns and plume behavior is essential to the evaluation of any
apparent toxic effects on SRV or other estuarine resources, as well as to decisions regarding diffuser design
and location. Additionally, if metals limits are necessary, the results of this investigation will be used to
establish the IWC for setting appropriate limits. The Enviromnental Assessment (p. 18) states that
modeling will be used to determine the appropriate outfall location and diffuser configuration, but in fact
the available dilution/mixing zone models are not applicable to the present situation. Without a dye study,
developing a strategy to address any identified toxicity problems will be extremely difficult
cc: Steve Pellei

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TABLE 2
PROJECTED DISCHARGE
- _ - ---FROM REVERSE OSMOSIS PROCESS
(3 MGD Total Production)
D SCHARGE FLOW =1.8 MGD
Constituent
'Ca Ig S
Mg
Na
K
� Ba EPc 2,0 ,0(( VACJ- o ", H,o Qb T.
Sr
CO3
HCO3
SO4
CI
—F
✓ NO3
Total Alkalinity (CaCO3)
Total Hardness (CaCO3)
FF,,(Calcium Hardness (CaCO3)
Mg QCaCO3)
i 3)
— eolor
Silica (SiO2)
j Iron-
Cu
Mn
PO4
4 Zn
T Pb-
Turbidity (NTU)
-TDS
Sulfide
pH
+ �'I m. .S-Pet- _ (oa C.fos) 52i5
I .C, S0 i295
¢ 394
+ G C 0,
4
1,64 17
{-ems, Nk •4"Nf 55f 6
(+c,� Nu-dw�r
Concentration
tmQ/11
(,,j
526.00
13 if
1143.60
46maG
8529.00
301.00
3 �5
0.00
0.00
IT80
.60
512.00
1568.00
16363.30
1.56
0.42
384.00
5900.00
1704.00
4196.00
682.00
v.vG
39.4
.29
.03
0.24
0.528
0.34
0.00
0.46
29000.00
--133.5-60-
0.00
7.74

3 TwtWity(NTbL' 0.46 7
1,3 Zinc 0.34 6 86 (AL)
1 Toxic Pollutants Table III
2 Conventioanal and Nonconventional Pollutants Table IV
3 NC Action Level or WQ Standard for saltwaters
4 Not Likely to be present in Discharge
86 CCC
5 Not monitored b/c non -detect in Projected Discharge per Enivronmental/Assesment.
6 Suggest Monitoring and /or limit due to NC Wtr Std & AL
7 Not monitored. Not likely to be problematic based of preojected levels.
8 Likely to be present. GW suggests monitoring.

L ! 1
P.01
fift
wv+t ?Jultieras
P.O. Box 578 — Buxton, N.C. 27920
Telephoge 99MO61
14ay • 14 , 1996
Steve Pellei
Division of Environmental, Management
PerMitd • ire Engineering
P. O. Box 29535
Raleigh, North Carolina 27626--0535
Dear Mr. Pellei:
The Cape Hatteras Water Association Board of Directors has
authorized the firm of Hobbs, Upchurch & Associates, P.A. to sign
the NPDHS reverse osmosis permit on their behalf.
f
S' cerely,
Carr Schauer, President
Cape Hatteras Water Association

REF Constituent
2
Pdaninierm
1
teeny
1,3
Arsenic
2
1,3
Beryllium
2
-lk)ren
2
BFestide
_Ca
1,3
Cadmium
3
- Chloride
1,3
Chromium IV
C-Or
2
GgalavA-
2
-@oitn-
1,3
Copper
1,3
Cyanide
2
-Iron
2
PeeaI9441URFM
2
Fluoride
K
1,3
Lead
2
- Magnesium(CaCO3)
2
Mengwtese
1,3
Mercury
2
-
1,3
fdi I_
Nickel
2
a
2
M15MgC1 L, TUt. Org
2
tease
3
pH
-YOT
1,3
-Rwnels
2
Radieae§uty-
3
Salinity
1,3
Selenium
3
1,3
Silver
Sr
2
Sulfate
2
2
Su fitL-
3
Temperature
1
2
Tie-
2
zitgnawl,�
Tot. Alk (CaCO3)
Tot. Hardns(CaCO3)
Ca Hardns (CaCO3)
3
+eMF Err
TDS
3
Toxic Substances
2
-TP
2
TRG
Projected
Discharge
mg/l
526
16363
0
0.03
0.29
0.0
4196
0.24
0.0
0.42
7.74
0.528
39.4
17.8
1335
0.0
384
5900
1704
29000
Actions NC NC
Aqu Life Hum HIth
µg/l µg/l
a
a-
6
5
6
4-
4.
8
6
8
6
4-
4-
5
6
6
8
4
8
8
6
6
4-
5
6
7
4
4
6
7
4
4
6
6
4-
6
8
5
6
4
4-
4-
8
8
8
�* 4-
6
4
4
50
117
5.0
20
3 (AL)
1
14 (SA)
25 (N)
0.025
EPA Con
µg/l
frshwtr only concern 1
4300 OC
0.14 CC
2000 MCL W&OC
t CIC
9.3 CCC
50 CCC
2.9 CCC
1 CCC
8.5 CCC
.025 T CCC
8.3 8.3 CCC
10k MCL W&OC Nitrates
0.1 CCC
6.8-8.5
(N)
(N)
(N)
71 71 CCC
0.1 (AL) 2.3 CMC
(N)
(N)
(N)
6.3 CC
7.5 CCC

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Nay

COUNTY OF DARE
KILL DEVIL HILLS, NORTH CAROLINA 27948
BOB ORESKOVICH
DIRECTOR
WATER DEPARTMENT
Mr. David A. Goodrich
State of North Carolina DEHNR
Division of Environmental Management
P.O. Box 29535
Raleigh, NC 27626-0535
April 10, 1995
600 MUSTIAN ST.
PHONE [phone]
RE: Dare County NPDES Permit #0070157
v
Dear Mr. Goodrich,
We at the Dare County Water Department have received a copy of the NPDES Permit
Issuance #NC0070157.
We wish to express our gratitude for your understanding of our concerns surrounding
the initial proposed maximum limit for Mercury in our Reverse Osmosis concentrate discharge
water. We will monitor the Mercury concentration in this discharge in addition to all other
required monitoring at intervals you have prescribed. This additional testing will increase our
analyses costs for the discharge to over $400 per month, or $14,000 over the remaining life of
this permit.
We have no problem with this testing frequency and cost because this is something we
can accomplish. We have the capability to have this analyses performed.
Presently we do not have the capability of reducing or removing the Nickel
concentration in our discharge water.
Our request to raise the maximum limit of Nickel in our discharge from 8.3 parts per
billion (ppb) to 88 ppb was based on the following reasons:
1. We, just as the Hyde County R.O. Plant (Swan Quarter), do actually discharge
our concentrate water into a freshwater stream; a canal that carries stormwater
drainage away to an outfall to the ocean.
LAND OF BEGINNINGS
PRINTED ON RECYCLED PAPER

r
2. At 18 ppb we will exceed the requirement that Nickel concentrations be below
8.3 ppb.
3. We are unaware of any treatment in existence to remove Nickel from water
(excluding Reverse Osmosis, which will create another waste stream with an
even higher concentration of Nickel in it).
The requirement of DEM for us to investigate ways of reducing the amount of Nickel
which is discharged leads us to an immediate dead end. We are open to suggestions on how we
should proceed at this point.
As the permit stands today, we will have no problem meeting its requirements. If we
agree to all of the stipulations and do not come up with a way to reduce the 18 ppb of Nickel
to below 8.3 ppb by November 1996, at that time we will be in violation of the permit we agree
to today and could be faced with fines and much controversy.
We will contact our engineers and begin an effort to explore possible ways to reduce the
discharge Nickel levels.
We respectfully request that DEM revise the Permit requirement to reflect monitoring
only for Nickel until its expiration in March of 1998.
cc: Terry Wheeler, County Manager
Wm�,d,�t
Best regards,
Robert W. Oreskovich, Director
Dare County Water System
LAND OF BEGINNINGS
PRINTED ON RECYCLED PAPER

r ± F
Brooks NO
Kings Pt
L- K •
•a' oo d� G
N _ _
I; H �_> E
It 11
J
447 .448 (CAPE HATTERAS)
5A5L II NG _
Latitude: 35 016'00"
NC0085707
Facility
Ii• '
,,
Longitude: 7595'22"
Location
Quad # F36SE
Receiving Stream: Pamlico Sound
Clare County -Cape
Stream Class: SA
Subbasin: 30155
Hatteras Water System
y
//
no P th
SCALE 1 :24000