HomeMy WebLinkAboutNC0025453_Draft Permit_20190821 ROY COOPER
Governor .r
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
August 21, 2019
Adam Lindsay, Town Manager
Town of Clayton
111 East Second Street
Clayton,North Carolina, 27528
Subject: Draft NPDES Permit Renewal
Permit NC0025453
Little Creek WRF
Johnston County
Grade IV Biological WPCS
SIC Code 4952
Dear Mr. Lindsay:
Enclosed with this letter is a copy of the Draft NPDES permit renewal for your facility. Please
review this draft carefully to ensure thorough understanding of the requirements and conditions it
contains. There are several changes from the existing permit, including the following:
• The NC 2007-2014 Water Quality Standards (WQS) Triennial Review was approved by
the NC Environmental Management Committee (EMC) on November 13, 2014. The US
EPA subsequently approved the WQS revisions on April 6, 2016 with some exceptions.
The NC Division of Water Resources NPDES Permitting Unit is required to implement the
new dissolved metal standards in all permits public noticed after April 6, 2016. The new
standards for most metals include acute standards. Further, the freshwater standards for
several metals are expressed as the dissolved form of the metals, and seven metals have
hardness-dependent equations. As a result, the NPDES Permitting Unit will need site-
specific effluent hardness data and instream hardness data, upstream of the discharge, for
each facility monitoring these metals in order to calculate permit limitations. Effluent
hardness and instream hardness sampling, upstream of the discharge, have been added to
the permit at a monitoring frequency of quarterly [See A.(1.)]
• Some of the wording has changed in Special Condition A. (2.), Chronic Toxicity Permit
Limit, please review each paragraph carefully.
• Special Condition A. (3.) has been modified to include the specific three years in which
the Effluent Pollutant Scan shall be performed (2020, 2021, and 2022). In addition, at the
end of the Special Condition, 2nd species Toxicity Testing Requirements for municipal
permit renewals per Federal Regulations [40 CFR 122.21(j)(5)] have been added.
E North nmental Quality I rc
512 NorthCarolina SalisburyDepartment Street 1 of1617 MailEnviro Service Center I RaleighDivision.NorthofWater CarolinaResou 2769es9-1617
rbwokur+a+twak, /'' 919.707.9000
• Parameter codes have been added to the Effluent Limitations and Monitoring Requirements
[ See A. (1.)]
• Regulatory citations have been added to the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The requirement to continue reporting discharge
monitoring data electronically using the NC DWR's Electronic Discharge Monitoring
Report(eDMR) internet application has been added to your NPDES permit. [See A. (7.)]
• Bis(2-ethylhexyl)phthalate showed reasonable potential to violate WQS in a limited data
set and quarterly monitoring has been added.
• Mercury data did not indicate reasonable potential to violate WQS and quarterly
monitoring has been removed. Since the facility reported no quantifiable levels of
mercury in the effluent, the MMP requirement has been removed.
The NPDES standard conditions (Parts II, III, and IV)that are a part of the permit are not included
in this draft document (cover, map, and Part I). The conditions are the same as in your current
permit except that agency and division names have been updated. The latest version is available at
https://bit.ly/2BZ4xxx and can be viewed online or downloaded as a PDF file.
Concurrent with this notification the Division is publishing a notice in a a news er having
g
circulation in the general Johnston County area, soliciting public comments on this draft permit.
Please provide any written comments you may have to the following: NCDEQ/DWR, NPDES
Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 no later than 30 days
after receipt of this draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments
and take appropriate action prior to issuing a final permit. If you have questions concerning this
draft permit, please call me at (919) 707-3612 or by email at David.hill@ncdenr.gov.
Sincere
David Hill, Environmental Specialist II
NPDES Complex Permitting Unit
Hardcopy: NPDES Files
Ecopy: US EPA Region 4
DWR/Ecosystems Branch/Mark Vander Borgh
DWR/Aquatic Toxicology Branch/Hannah Headrick
DWR/Raleigh Regional Office/Water Quality
DWR/Operator Certification Program/Maureen Kinney
Town of Clayton/James Warren
Page 2 of 2
Permit NC0025453
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions 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, the
Town of Clayton
is hereby authorized to discharge wastewater from a facility located at the
Little Creek Water Reclamation Facility
1000 Durham Street Extension
Clayton
Johnson County
to receiving waters designated as the Neuse River in the Neuse River Basin in accordance with
effluent limitations, monitoring requirements, and other applicable conditions set forth in Parts I,
II, III and IV hereof
This permit shall become effective Month xx, 2019
This permit and authorization to discharge shall expire at midnight on March 31, 2023.
Signed this day Month xx, 2019
DRAFT
Linda Culpepper, Director
Division of Water Resources
By the Authority of the Environmental Management Commission
Permit NC0025453
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are
hereby revoked. As of this permit issuance, any previously issued permit bearing this number is
no longer effective. Therefore, the exclusive authority to operate and discharge from this facility
arises under the permit conditions, requirements, terms, and provisions included herein.
The Town of Clayton is hereby authorized to:
1. Continue to operate and maintain an existing 2.5 MGD wastewater treatment facility
consisting of the following components:
• mechanical screening and grit removal system,
• influent pump station
• 214,500 gallon anaerobic basin,
• 300,000 gallon anoxic tank,
• oxidation basin No. 2,
• 200,000 gallon anoxic tank
• oxidation basin No. 1,
• three(3) secondary clarifiers,
• two tertiary filters,
• ultraviolet disinfection with back-up chlorination/dechlorination,
• 90,000 gallon aerated digester/sludge stabilization tank,
• 360,000 gallon sludge holding tank,
• sludge loading station,
• sludge thickening building with rotary drum thickener
• non-potable water system using reclaimed treated wastewater
• reclaimed water pump station
This facility is located at the Little Creek Water Reclamation Facility, Durham Street
Extension, Clayton, Johnson County, and
2. Discharge from said treatment works at the location specified on the attached map via Outfall
001 into the Neuse River, classified WS-IV, NSW, CA waters in the Neuse River Basin.
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Permit NC0025453
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [2.5 MGD]
[15A NCAC 02B .0400 et seq., 15A NCACO2B .0500 et seq.] Grade IV
Biological Water Pollution Control System [15A NCAC 08G .0302]
During the period beginning on the effective date of the permit and lasting until expiration,the permittee
is authorized to discharge treated municipal and industrial wastewater from Outfall 001. Such discharges
shall be limited and monitored' by the permittee as specified below:
PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS
r
Monthly Weekly Daily Measurement Sample p Sample
PARAMETER CODE Average Average Maximum Frequency Type Location2
Flow 50050 2.5 MGD Continuous Recording I or E
BOD,5 day,20°C3 C0310
(April 1-October 31) 5.0 mg/L 7.5 mg/L 2/weeksComposite I and E
BOD,5 day,20°C3 C0310
(November 1-March 31) 10.0 mg/L 15.0 mg/L 2/weeksComposite I and E
Total Suspended Solids3 C0530 30.0 mg/L 45.0 mg/L 2/weeks Composite I and E
NH3 as N C0610
(Apr 1-Oct 31) 1.0 mg/L 3.0 mg/L 2/weeksComposite E
NH3 as N C0610 2.0 mg/L 6.0 mg/L 2/weeks Composite E
(Nov 1-Mar 31) _
Dissolved Oxygen 00300 Daily Average>_6.0 mg/L Daily Grab E
pH 00400 Between 6.0 and 9.0 Standard Units Daily Grab E
Temperature°C 00010 Monitor and Report Daily
Grab E
Fecal Coliform 31616 200/100 mL 400/100 mL 2/weeks Grab E
(geometric mean)
Total Residual Chlorine4 50060 28 µg/L Daily Grab E
TKN (mg/L) 00625 Monitor and Report Weekly Composite E
NO3-N+NO2-N (mg/L) 00630 Monitor and Report Weekly Composite E
Total Nitrogen5 (mg/L) C0600 Monitor and Report Weekly Calculated E
TN Load 9,1° QM600 Monitor and Report(lb/month) Monthly
QY600 22,832 lb/yr Annually Calculated E
Total Monthly Flow(MG) 82220 Monitor and Report Monthly Calculated E
Total Phosphorus(mg/L) C0665 2.0 mg/L(Quarterly Average) Weekly Composite E
Conductivity(µmhos/cm) 00094 Monitor and Report Daily Grab E
Bis(2-Ethylhexyl)Pthalate(µg/L) 39100 Monitor and Report Quarterly Composite E
e TGP3B Monitor and Report arterl Composite E
Chronic Toxicity y
Pollutant Scan7 NC01 Monitor and Report Footnote 7 Footnote 7 E
Hardness 11-Total as CaCO3(mg/L)00900 Monitor and Report Quarterly Composite E 1
Hardness 11-Total as CaCO3(mg/L)00900 Monitor and Report Quarterly Grab U
Dissolved Oxygen (mg/L) 00300 Monitor and Report Variable2 Grab U and D
Temperature°C 00010 Monitor and Report Variable2 Grab U and D
Conductivity(µmhos/cm) 00094 Monitor and Report Variable2 Grab U and D
Fecal Coliform(#/100mL) 31616 Monitor and Report Variable2 Grab U and D
(geometric mean)
Footnotes:
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. See Special Condition A.(7.).
Footnotes are continued on the next page.
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Permit NC0025453
Footnotes continued from A.(1.)Effluent Limitations and Monitoring Requirements.
2. Sample locations I-Influent, E-Effluent,U-Upstream=at NCSR 1700, D-Downstream=(1)NC HWY 42 and
(2)NCSR 1908. Upstream and downstream samples shall be grab samples collected 3/week during June,July,
August, and September and 1/week during the remainder of the year. Instream sampling requirements are
provisionally waived in light of the permittee's participation in the Lower Neuse River Basin Association.Should
participation in the association cease,all instream sampling requirements are immediately reinstated.
3. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the
respective influent value(85%removal).
4. The Division shall consider all effluent total residual chlorine values reported below 50 41 to be in compliance
with the permit. However,the permittee shall continue to record and submit all values reported by a North
Carolina certified laboratory(including field certified),even if these values fall below 50 41.
5. For a given wastewater sample,TN=TKN+NO3-N+NO2-N,where TN is Total Nitrogen,TKN is Total
Kjeldahl Nitrogen,and NO3-N and NO2-N are Nitrate and Nitrite Nitrogen,respectively.
6. Chronic Toxicity(Ceriodaphnia dubia)P/F at 2%with testing in March,June,September,and December.See
Special Condition A.(2.).
7. The permittee shall perform three effluent pollution scans during the term of this permit. See Special Condition
A.(3.).
8. Twice per week sampling must occur on any two non-consecutive days during the calendar week.
9. TN Load is the mass load of TN discharged by the permittee in a period of time. See Special Condition A.(4.).
10. Compliance with these limits shall be determined in accordance with Special Condition A. (5.),Annual Limits
for Total Nitrogen.
11. The permittee shall sample instream hardness upstream of the facility's discharge.The sample shall be
representative of the hardness in the stream.If the permittee is a member of the Monitoring Coalition Program,
sampling for instream hardness may be waived as long as the Monitoring Coalition agrees to sample hardness at
the nearest upstream location,at a minimum frequency of quarterly,and the permittee has obtained approval
from DWR-NPDES Permitting Unit that the upstream station being monitored by the coalition is representative
of the receiving stream for this discharge.The permittee is responsible for submitting instream hardness test
results with its DMRs as results are received from the coalition.If coalition membership is cancelled or the
Monitoring Coalition terminates instream hardness sampling at the approved station,the permittee will
immediately notify the Division and resume sampling for instream hardness,upstream of its discharge,as
required in Section A. (1.).Effluent hardness shall be performed in conjunction with testing for hardness
dependent metals(cadmium,copper,lead,nickel,silver,and zinc).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) [15A NCAC 02B.0200]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 2%.
The permit holder shall perform at a minimum,quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised December 2010,or
subsequent versions or"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised-December 2010)or subsequent versions.The tests will be performed during the months of
March,June, September,and December. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
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Permit NC0025453
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit,then multiple-concentration testing shall be performed at a minimum,in
each of the two following months as described in"North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure"(Revised-December 2010)or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form(MR-1) for the months in which tests were performed,using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,DWR Form AT-3
(original)is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water 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,accurate,include all supporting chemical/physical measurements and all
concentration/response data,and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
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
Water Sciences Section at the address cited above
Should the permittee fail to monitor during a month in which toxicity monitoring is required,monitoring
will be required during the following month.Assessment of toxicity compliance is based on the toxicity
testing quarter,which is the three month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources 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,minimum control organism reproduction,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.
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A. (3.) EFFLUENT POLLUTANT SCAN (Municipal POTWs) [G.S. 143-215.1(b)]
The permittee shall perform a total of three(3)Effluent Pollutant Scans for all parameters listed below.One
scan must be performed in each of the following years: 2020, 2021,and 2022. Analytical methods shall
be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether parameters
are present in concentrations greater than applicable standards and criteria. Samples should be collected
with one quarterly toxicity test each year, and must represent seasonal variation [i.e.,do not sample in the
same quarter every year]. Unless otherwise indicated,metals shall be analyzed as"total recoverable."
Ammonia(as N) Trans-1,2-dichloroethylene Bis(2-chloroethyl)ether
Chlorine(total residual,TRC) 1,1-dichloroethylene Bis(2-chloroisopropyl)ether
Dissolved oxygen 1,2-dichloropropane Bis(2-ethylhexyl)phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Phosphorus
sp ores Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate
Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1,1,1-tichloroethane 1,2-dichlorobenzene
Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid-extractable compounds: Diethyl phthalate
Mercury(EPA Method 1631 E) P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene
Acrolein Phenol Hexachloroethane
Acrylonitrile 2,4,6-trichlorophenol Indeno(I,2,3-cd)pyrene
Benzene Base-neutral compounds: Isophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1,1-dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane Bis(2-chloroethoxy)methane
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Permit NC0025453
Reporting. Test results shall be reported electronically via eDMR or on DWR Form—DMR-PPA-1 (or
on a form approved by the Director)by December 31st of each designated sampling year. The report shall
be submitted to the following address:
NC DEQ/DWR/Central Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that Municipal
facilities that are subject to the Effluent Pollutant Scan requirements listed above are also subject to
additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.21(j)(5). The US EPA
requires four(4)toxicity tests for a test organism other than the test species currently required in this permit.
The multiple species tests should be conducted either quarterly for a 12-month period prior to submittal of
the permit renewal application,or four tests performed at least annually in the four and one half year period
prior to the application. These tests shall be performed for acute or chronic toxicity,whichever is specified
in this permit. The multiple species toxicity test results shall be filed with the Aquatic Toxicology Branch
at the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Contact the Division's Aquatic Toxicology Branch at 919-743-8401 for guidance on conducting the
additional toxicity tests and reporting requirements. Results should also be summarized in Part E(Toxicity
Testing Data)of EPA Municipal Application Form 2A,when submitting the permit renewal application to
the NPDES Permitting Unit.
A. (4.) CALCULATION OF TOTAL NITROGEN LOADS [G.S. 143-215.1(b)]
a. The permittee shall calculate monthly and annual TN Loads as follows:
i. Monthly TN Load(lb/mo)=TN x TMF x 8.34
where:
TN = the average Total Nitrogen concentration(mg/L)of the composite
samples collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the month
(MG/mo)
8.34 = conversion factor, from(mg/L x MG)to pounds
ii. Annual TN Load(lb/yr)=Sum of the 12 Monthly TN Loads for the calendar year
b. The permittee shall report monthly Total Nitrogen results(mg/L and lb/mo)in the discharge
monitoring report for that month and shall report each year's annual results(lb/yr)in the December
report for that year.
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A. (5.)ANNUAL LIMITS FOR TOTAL NITROGEN [G.S. 143-215.1(b)]
a. Total Nitrogen(TN)allocations and TN Load limits for NPDES dischargers in the Neuse River
basin apply on a calendar year basis.
b. For any given calendar year,the permittee shall be in compliance with the annual TN Load limit in
this Permit if:
i. the permittee's annual TN discharge is less than or equal to its TN Load limit,or
ii. the permittee is a co-permittee member of a compliance association.
c. If the permittee is not a co-permittee member of a compliance association and the permittee's
cumulative annual TN discharge exceeds the effective TN Load limit in this permit at any point
during the calendar year,the permittee is in violation of its TN Load limit,and each day of a
continuing violation shall constitute a separate violation.
d. The TN Load limit in this Permit(if any)may be modified as the result of allowable changes in the
permittee's TN allocation.
i. Allowable changes include those resulting from purchase of TN allocation from the Wetlands
Restoration Fund;purchase, sale,trade, or lease of allocation between the permittee and other
dischargers; regionalization; and other transactions approved by the Division.
ii. The permittee may request a modification of the TN Load limit in this Permit to reflect
allowable changes in its TN allocation.Upon receipt of timely and proper application,the
Division will modify the permit as appropriate and in accordance with state and federal
program requirements.
iii. Changes in TN limits become effective on January 1 of the year following permit
modification.The Division must receive application no later than August 31 for changes
proposed for the following calendar year.
iv. Application shall be sent to:
NCDWR/NPDES Programs
Attn: Neuse River Basin Coordinator
1617 Mail Service Center
Raleigh,NC 27699-1617
e. If the permittee is a member and co-permittee of an approved compliance association,its TN
discharge during that year is governed by that association's group NPDES permit and the TN limits
therein.
i. The permittee shall be considered a Co-permittee Member for any given calendar year in
which it is identified as such in Appendix A of the association's group NPDES permit.
ii. Association roster(s)and members'TN allocations will be updated annually and in
accordance with state and federal program requirements.
iii. If the permittee intends to join or leave a compliance association,the Division must be
notified of the proposed action in accordance with the procedures defined in the association's
NPDES permit.
(A) Upon receipt of timely and proper notification,the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
(B) Membership changes in a compliance association become effective on January 1 of the
year following modification of the association's permit.
f. The TN monitoring and reporting requirements in this Permit remain in effect until expiration of
this Permit and are not affected by the permittee's membership in a compliance association.
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A. (6.) TOTAL NITROGEN ALLOCATIONS [G.S. 143-215.1(b)]
a. The following table lists the Total Nitrogen(TN)allocation(s)assigned to, acquired by, or transferred
to the permittee in accordance with the Neuse River nutrient management rule(T15A NCAC 02B .0234)
and the status of each as of permit issuance. For compliance purposes,this table does not supersede any
TN limit(s)established elsewhere in this permit or in the NPDES permit of a compliance association of
which the permittee is a Co-permittee Member.
ALLOCATION AMOUNT1
ALLOCATION SOURCE DATE STATUS
TYPE Estuary Discharge
(Ib/yr) (Ib/yr)
Base Assigned by Rule 12/7/97; 10,700 21,400 Active
(T15A NCAC 02B .0234) 4/1/03
Supplemental Purchased from 7/5/06 3,668 7,336 Reserve
South Granville WSA
(NC0026824)
Supplemental Purchased from 8/30/2007 1,645 3,290 Mixed
UNIFI-Kinston 716 1,432 Active
(NC0003760) 929 1,858 Reserve
TOTAL 16,013 32,026 Mixed
11,416 22,832 Active
4,597 9,194 Reserve
Footnote:
1. Transport Factor=50%
b. Any addition, deletion,or modification of the listed allocations(other than typographical errors)or any
change to Active status of any of the listed allocations shall be considered a major modification of this
permit and shall be subject to the public review process afforded such modifications under state and
federal rules.
A. (7.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21,
2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D.(2.) and Section E. (5.) (all
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The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report(eDMR)internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross-Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,signing,
and submitting one signed original and a copy of the computer printed eDMR to the following address:
NC DEQ/Division of Water Resources/Water Quality Permitting Section
A 1TENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617 •
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband access,
then a temporary waiver from the NPDES electronic reporting requirements may be granted and
discharge monitoring data may be submitted on paper DMR forms(MR 1, 1.1,2,3)or alternative forms
approved by the Director. Duplicate signed copies shall be submitted to the mailing address above.
See"How to Request a Waiver from Electronic Reporting"section below.
Regardless of the submission method,the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports,when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act(CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting"section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9),the permittee must identify the initial recipient at the time of
each electronic submission. The permittee should use the EPA's website resources to identify the initial
recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program)that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each
type of electronic submission and for each state. Instructions on how to access and use the appropriate
electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting
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Permit NC0025453
Rule is found at: https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-
pollutant-discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the"Reporting Requirements"section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver,a permittee must first submit an electronic reporting waiver request to the
Division. Requests for temporary electronic reporting waivers must be submitted in writing to the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver
shall not exceed 5 years and shall thereupon expire. At such time,monitoring data and reports shall be
submitted electronically to the Division unless the permittee re-applies for and is granted a new
temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not
transferrable. Only permittees with an approved reporting waiver request may submit monitoring data
and reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements 'Supplements Section B. (11.) (b)and Supersedes Section B.(11.)(dli
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a)or by a duly authorized representative of that person as described in Part II, Section
B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting
purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North Carolina's
eDMR system, registering for eDMR and obtaining an eDMR user account,please visit the following
web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted.Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am
aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations."
10 of 11
Permit NC0025453
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report.
This period may be extended by request of the Director at any time [40 CFR 122.41].
11 of 11
Permit No. NC0025453
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Little Creek WRF—NC0025453 Facility Location (not to scale)
Town of Clayton
Receiving Stream: Neuse River Stream Class: WS-IV,
Drainage Basin: Neuse River Basin NSW CA *T
Permitted Flow: 2.5 MGD Sub-Basin: 03-04-02 lv
State Grid/USGS Quad: E2SNW,Clayton HUC: 0320201
Latitude 35°39'50" Longitude 78°25'26"
Fact Sheet
NPDES Permit No. NC0025453
Permit Writer/Email Contact David Hill,david.hill@ncdenr.gov:
Date: August 21,2019
Division/Branch:NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
® Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification(Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers,EPA Form 2A or 2D requirements,Engineering Alternatives Analysis,Fee
• For Existing Dischargers(POTW),EPA Form 2A,3 effluent pollutant scans,4 2°d species WET
tests.
analytical requirements based
• For ExistingDischargers on-POTW ,EPA Form 2C with correctyt eq
g � )
on industry category.
Complete applicable sections below. If not applicable,enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name: Town of Clayton/Little Creek WRF
Applicant Address: PO Box 879,Clayton,North Carolina
Facility Address: 1000 Durham Street Extension,Clayton,NC
Permitted Flow: 2.5 MGD
Facility Type/Waste: MAJOR Municipal; 95%domestic,5%industrial
Facility Class: Class 4
Treatment Units: Mechanical bar screens&grit removal,influent pump station,
anaerobic basin,anoxic tanks,oxidation basins,clarifiers,tertiary
filters,UV disinfection with backup chlorination/dechlorination,aerated
sludge digester, sludge holding tank,sludge thickener,non-potable
reclaimed water system
Pretreatment Program(Y/N) Yes
County: Johnston
Region Raleigh
Page 1 of 11
Briefly describe the proposed permitting action and facility background: The Town of Clayton has
applied for NPDES permit renewal and submitted a renewal application dated September 29,2017.
This facility serves a population of 19,102 residents and operates a pretreatment program with two
pharmaceutical Categorical Industrial Users,Novo Nordisk and Grifols. Currently,Grifols
discharges to Johnston County's WWTP. Novo Nordisk's flow to Little Creek WWTP was 0.076
MGD. Clayton has agreements with Johnston County and Raleigh's Neuse River WWTP(once the
pump station is online)to divert up to 1.3 MGD and 1.0 MGD to those plants respectively. Clayton
also operates a reclaimed water system and land applies up to 237,840 GPD under permit
WQ0022224. I&I was reported at 438,000 GPD.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s): Outfall 001-Neuse River
Stream Segment: 27-41.3
Stream Classification: WS-IV; NSW, CA
Drainage Area(mi2): 1,150
Summer 7Q10 (cfs) 186 (regulated)
Winter 7Q10 (cfs): 186 (regulated)
30Q2 (cfs): 186 (regulated)
Average Flow(cfs): 186 (regulated)
IWC (%effluent): 1.6
303(d) listed/parameter: No
Subject to TMDL/parameter: Yes- Subject to Neuse nutrient rule 15A NCAC 02B .0234,
Statewide Mercury TMDL
Subbasin/HUC: 030402/03020201
USGS Topo Quad: E25NW/NW Clayton
3. Effluent Data Summary
Effluent data is summarized below for the period May 2014 through December 2018.
Table 1. Effluent Data Summary.
Parameter Units Average Max Min Permit
Limit
Flow MGD 1.55 5.82 0.46 2.5
5.0 MA
BOD summer mg/1 2.43 16.4 <2 7.5 WA
Page 2 of 11
10.0 MA
BOD winter mg/1 2.35 15 <2 15 WA
1.0 MA
NH3N summer mg/1 0.37 6.4 <0.04 3.0 WA
2.0 MA
NH3N winter mg/1 0.46 3.9 <0.04 6.0 WA
30.0 MA
TSS mg/1 2.8 28.4 2.1 45.0 WA
pH SU 7.5 8.8 6.6 6-9
Temperature °C 21.6 28.8 10.3
DO mg/1 7.8 10.3 5.6
TRC ug/L 18.7 20 <1 28 DM
TN mg/1 4.14 13.08 1.24
Kjeldahl Nitrogen mg/1 1.24 6.04 0.2
Nitrate+Nitrite mg/1 2.89 11.24 0.48
TN Monthly lb/mo 1627 3308 630
TN Yearly lb/yr 19903 20901 18472 22,832
TP mg/1 1.08 6.53 <0.04
TP Quarterly Average mg/1 1.08 1.65 0.40 2.0
Conductivity umhos 724.8 1703 7.4
200 MA
Fecal Coliform #/100 ml 23.3 2419 < 1 400 WA
MA-Monthly Average, WA-Weekly Average,DM-Daily Maximum
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1)to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2)to
verify model predictions for outfall diffuser; 3)to provide data for future TMDL; 4)based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee(in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The permit requires instream monitoring for DO,pH,temperature,conductivity,
and fecal coliform which is waived in lieu of the facility's participation in a monitoring coalition.
The nearest upstream station,J4130000, had only 3 samples taken from April 2014-December 2018.
Page 3 of 11
The next upstream station,J4050000,is over 8 miles upstream with Raleigh's Neuse River WWTP,
a 60 MGD facility,discharging below that station.Therefore,there are no upstream data with
which to determine site specific effects of this discharge on the receiving stream.
Is this facility a member of a Monitoring Coalition with waived instream monitoring(Y/N): Yes
Name of Monitoring Coalition: Lower Neuse Basin Association(LNBA).
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported one
BOD MA and WA violation each in April 2017,and three DO daily minimum violations in May
2017.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 19 of 19 quarterly chronic toxicity tests, as well as all 4 second
species chronic toxicity tests.
Summarize the results from the most recent compliance inspection: The last facility inspection
conducted in 2017 was compliant in all areas with a rating of"very reliable".
6. Water Quality-Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow(acute Aquatic Life); 7Q10 streamflow(chronic Aquatic
Life; non-carcinogen HH); 30Q2 streamflow(aesthetics); annual average flow(carcinogen, HH).
If applicable, describe any other dilution factors considered(e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA
The critical flow at this discharge point is a regulated flow based on the minimum release at Falls
Dam and subsequent water balance of downstream dischargers,intakes,and tributary 7Q10 runoff
flows.The regulated flow of 186 CFS will be used for all critical flows noted above.
Oxygen-Consuming Waste Limitations
Limitations for oxygen-consuming waste(e.g.,BOD)are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen(DO)water quality standard. Secondary TBEL limits
(e.g., BOD=30 mg/1 for Municipals)may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: Limitations for
BOD are based on advanced tertiary treatment limits validated by a QUAL2E model(1991)to be
protective of the instream DO standard.
Ammonia and Total Residual Chlorine Limitations
Page 4 of 11
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1(summer)and 1.8 mg/1(winter).Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non-Municipals.
Limitations for Total Residual Chlorine(TRC)are based on the NC water quality standard for protection
of aquatic life(17 ug/1)and capped at 28 ug/1(acute impacts). Due to analytical issues,all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: NA.
Reasonable Potential Analysis(RPA)for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards,a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44(d)(i). The NC
RPA procedure utilizes the following: 1)95%Confidence Level/95%Probability;2)assumption of zero
background; 3)use of Y2 detection limit for"less than"values;and 4)streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6,2016,NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards,dated June 10,2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between May 2014 and
December 2018. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria.Based on this analysis,the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality-based
effluent limit(WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: None.
• Monitoring Only. The following parameters will receive a monitor-only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria,
but the maximum predicted concentration was>50%of the allowable concentration:None.
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was<50%of the allowable
concentration: Arsenic,beryllium,cadmium,chlorides,chromium,copper,cyanide total
phenolic compounds,lead,molybdenum,nickel,selenium,silver,and zinc.
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s)will receive a water quality-based effluent limit(WQBEL)
with monitoring, since as part of a limited data set,two samples exceeded the allowable
discharge concentration:None.
o The following parameter(s)will receive a monitor-only requirement,since as part of a
limited data set,one sample exceeded the allowable discharge concentration:Bis(2-
ethylhexyl)phthalate
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet.Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Page 5 of 11
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity(WET)have been established in
accordance with Division guidance(per WET Memo, 8/2/1999). Per WET guidance,all NPDES permits
issued to Major facilities or any facility discharging"complex"wastewater(contains anything other than
domestic waste)will contain appropriate WET limits and monitoring requirements,with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits,using single concentration screening tests,with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Major POTW,and a chronic WET limit at 2%
effluent will continue at a quarterly frequency.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria(0.3 mg/kg)for human health protection.The TMDL established a
wasteload allocation for point sources of 37 kg/year(81 lb/year),and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources(-2%of total load),the TMDL emphasizes mercury minimization plans(MMPs)for point source
control. Municipal facilities>2 MGD and discharging quantifiable levels of mercury(>1 ng/l)will
receive an MMP requirement. Industrials are evaluated on a case-by-case basis,depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value(based on the NC WQS of 12 ng/l)and/or if any individual value exceeds a TBEL
value of 47 ng/l.
To comply with the MMP in the previous permit, Clayton created an MMP on September 3, 2014.
They identified 29 potential source contributors to their system and sent one-time compliance
notifications to all the dental facilities in that list informing them of the requirements of 40 CFR 441.
They also performed 9 sampling events in their collections system.
Table 2. Mercury Effluent Data Summary.
2014 2015 2016 2017 2018
#of Samples 3 4 4 4 3
Annual Average,ng/L 0.5 0.5 0.5 0.5 0.5
Maximum Value,ng/L 0.5 0.5 0.5 0.5 0.5
TBEL,ng/L 47
WQBEL,ng/L 588
Describe proposed permit actions based on mercury evaluation: Since no annual average mercury
concentration exceeded the WQBEL,and no individual mercury sample exceeded the TBEL,no
mercury limit is required. The facility is>2 MGD with no reported quantifiable levels of mercury
(> 1 ng/1),therefore a MMP will not be required.Mercury monitoring will remain as part of the
facility's pretreatment LTMP and priority pollutant scans.
Page 6 of 11
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit
Nitrogen
The Environmental Management Commission adopted Nutrient Management Strategy rules in
December 1997,classifying the entire Neuse River Basin as Nutrient Sensitive Waters. The point
source rule(T15A NCAC 2B.0234)sets Total Nitrogen(TN) discharge limits for all point source
dischargers larger than 0.5 MGD.
The rule also allows dischargers to form a group compliance association and work together to
reduce nitrogen; this option allows the association members added flexibility in controlling nitrogen
discharges.At the same time,the association is subject to a group NPDES permit ensuring that the
association and its individual members are accountable if they exceed the applicable nitrogen
limits.
Under the rule,there are three types of TN limit in the Neuse:
1. the individual limits in the dischargers' individual permits,
2. the aggregate limit in an association's group NPDES permit,and
3. the individual allocations/limits for each Association member,also in that association
permit.
A discharger may be subject to the first type of limit,or to the second and third,but never to all
three at the same time. The discharger is first subject to the TN limit(if any)in its individual
NPDES permit. If becomes a co-permittee to a compliance association's group NPDES permit,it is
then governed by the TN limits in that permit. If the association complies with its group TN limit in
a given year,all members are deemed to be in compliance with their individual allocations/limits in
the group permit.If the association exceeds its limit,the members then become subject to their
individual allocations/limits as well.
Regardless of which permit governs a TN discharge, allocations/limits will likely change over time
as the dischargers purchase,sell,trade,lease,or otherwise transfer nitrogen allocations.The
Division will modify the affected permits as necessary to ensure that the limits are kept up to date
and reflect any such transactions.
The Permittee is a member of the Neuse River Compliance Association at this time. So long as it
remains a co-permittee member,it is deemed to be in compliance with the TN limit in this permit,
and its TN discharge is governed instead by the Association's group NPDES permit,issued
December 12,2008.
The Town's TN active allocation is 22,832 lb/year at the discharge equivalent to 11,4161b/yr at the
estuary. The allocation includes the county's original allocation assigned by rules in addition to
supplemental allocations obtained through purchases. The Town has 9,194 lb/yr in reserve
allocation.
Table 3. TN Allocations.
Source Allocation(lb/yr)
Assigned by rule 21,400
Purchased from SGWASA 7,336
Page 7 of 11
Purchase from UNIFI-Kinston 3,290
Phosphorus
The City's 2.0 mg/L Total Phosphorus quarterly average limit is carried forward in this permit.
Other WOBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs:NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo:NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e)and 15A NCAC 2B.0226 for this permit renewal: NA
7. Technology-Based Effluent Limitations (TBELs)
Municipals(if not applicable,delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements(30 mg/1
BOD5/TSS for Monthly Average, and 45 mg/I for BOD5/TSS for Weekly Average). YES
If NO,provide a justification for alternative limitations(e.g., waste stabilization pond). NA
Are 85%removal requirements for BOD5/TSS included in the permit? YES
If NO,provide a justification (e.g., waste stabilization pond). NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non-discharge alternatives per 15A NCAC 2H.0105(c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis(EAA)and any water quality modeling results:NA
9. Antibacksliding Review:
Sections 402(o)(2)and 303(d)(4)of the CWA and federal regulations at 40 CFR 122.44(1)prohibit
backsliding of effluent limitations in NPDES permits.These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit,with some exceptions where limitations
Page 8 of 11
may be relaxed(e.g.,based on new information,increases in production may warrant less stringent TBEL
limits,or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit(YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance,Monitoring Frequency for Toxic Substances(7/15/2010 Memo); 3)NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance(10/22/2012 Memo); 4)Best
Professional Judgement(BPJ). Per US EPA(Interim Guidance, 1996),monitoring requirements are not
considered effluent limitations under Section 402(o)of the Clean Water Act,and therefore anti-
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring,refer to Section 4.
On April 30,2015,the facility was granted reductions in monitoring frequencies for BOD,
Ammonia-N,TSS,and fecal conform in accordance with the Division's Guidance Regarding the
Reduction of Monitoring Frequencies in NPDES Permits for Exceptionally Performing Facilities
(October 22,2012).These parameters were re-evaluated this cycle for compliance with the
requirements and are summarized in Table 4.
Table 4.Monitoring Frequency Reduction Values.
Parameter Mean 50%MA #>(200%WA)
BOD,mg/L 2.4 2.5 1 (15)
TSS,mg/L 2.8 15.0 0(90)
Ammonia-N,mg/L 0.41 0.5 1 (6)
Fecal Coliform 1.9* 100 2(800)
#/100mL
*Geometric Mean
The facility met the criteria for all four parameters and will receive twice per week monitoring
requirements for them.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21,2015. Effective
December 21,2016,NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs)electronically. Effective December 21,2020,NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting,consistent with Federal requirements.
12.Summary of Proposed Permitting Actions:
Table 5. Current Permit Conditions and Proposed Changes.
Page 9 of 11
Parameter Current Permit Proposed Change Basis for Condition/Change
Flow MA 2.5 MGD No change 15A NCAC 2B .0505
Total Monthly
BOD5 Summer: No change WQBEL.Based on protection of DO
MA 5 mg/1 standard. 15A NCAC 2B.0200
WA 7.5 mg/1
Winter:
MA 10 mg/1
WA 15 mg/1
NH3-N Summer: No change WQBEL.Based on protection of
MA 1 mg/1 State WQ criteria. 15A NCAC
WA 3 mg/1 2B.0200
Winter:
MA 2 mg/1
WA 6 mg/1
TSS MA 30 mg/1 No change TBEL. Secondary treatment
WA 45 mg/1 standards/40 CFR 133/ 15A NCAC
2B .0406
Fecal coliform MA 200/100m1 No change WQBEL. State WQ standard, 15A
WA 400/100m1 NCAC 2B .0200
DO >5 mg/1 Daily Average No change WQBEL. State WQ standard, 15A
NCAC 2B .0200
pH 6—9 SU No change WQBEL. State WQ standard, 15A
NCAC 2B .0200
TRC 28 ug/L DM No change WQBEL. State WQ standard, 15A
NCAC 2B .0200
Total Hardness No Monitoring Quarterly Monitoring For Hardness Dependent WQS. 15A
NCAC 02B
Effluent and upstream
Total Nitrogen Monitor Only Monitor Only For TN Load, 15A NCAC 2B.0234
TKN Monitor Only Monitor Only For TN Load, 15A NCAC 2B.0234
Nitrate+Nitrite Monitor Only Monitor Only For TN Load, 15A NCAC 2B.0234
TN Load 22,832 lb/yr No change WQBEL. State WQ standard, 15A
NCAC 2B .0234 Neuse River
Monthly reporting
nutrient strategy.TMDL
Page 10 of 11
Total Phosphorus 2.0 mg/L quarterly No change WQBEL. State WQ standard, 15A
average NCAC 2B .0234 Neuse River
nutrient strategy. TMDL
Conductivity Monitor only No change 15A NCAC 2B .0500
Temperature Monitor only No change 15A NCAC 2B .0500
Toxicity Test Chronic limit, 2% No change WQBEL. No toxics in toxic
effluent amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Effluent Pollutant Three per permit cycle No change 40 CFR 122
Scan
Total mercury Quarterly monitoring Remove monitoring WQBEL. Consistent with 2012
Statewide Mercury TMDL
Implementation.No reasonable
potential to violate WQS
S Q
Electronic No requirement Add Electronic In accordance with EPA Electronic
Reporting Reporting Special Reporting Rule 2015.
Condition
MGD—Million gallons per day, MA- Monthly Average,WA—Weekly Average,DM—Daily Max
13. Public Notice Schedule:
Permit to Public Notice: August 21,2019
Per 15A NCAC 2H .0109& .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed(Yes/No): --
If Yes, list changes and their basis below: --
15. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• Dissolved Metals Implementation/Freshwater or Saltwater
Page 11 of 11