NC0021253_WASTELOAD ALLOCATION_19940110

NPDES DOCUMENT SCANNIN& COVER SHEET
NPDES Permit: NC0021253
Havelock WWTP
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
.Engineering Alternatives Analysis
201 Facilities Plan
Instream Assessment (67B)
Speculative Limits
Permit
History
Document Date: January 10, 1994
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coateat oa the re'%rerse side

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NPDES WASTE LOAD ALLOCATION .r-.
PERMIT NO.:
NCO021253 I I Modeler Date Rec. #
City of Havelock Ci to to g3 b L
PERMITTEE NAME: -.
FACILITY NAME: Havelock Wastewater Treatment Plant
Facility Status: _ Existing Drainage Area(mi2y ..35.0 Average Streamflow(cfs): 46.0
Permit Status: Renewal s7010(cfs): Tidal p w7010 (cfs): Tidal 3002 (cfs): Tidal
Major Minor Toxicity Limits: 900/6 Chronic @ 1.5 mgd and 1.9 mgd
Pipe No.: 001 Instream Monitoring: refer"Special Instream Monitoring Requirements"
Design Capacity: 1.5 MGD attached to Fact Sheet
Monthly Average Monthly Average
Domestic (% of Flow): 100 % Summer Winter Summer Winter
Wasteflow(MGD): 1.50 1.50 1.90 1.90
Industrial (% of Flow): CBOD5(mgA): 5.0 •" 11.0 ••• 3.0 ••• 6.0 •"
NH,N(mgA): 2.0 3.0 0.5 1.0
Comments: DO(mgA): 6.0 6.0 6.0 6.0
TSS(mg/1): 30 "' 30 "' 30 "' 30 "'
Future permitted expansion is 1.9 MGD Fecal Col. (/100 ml): 200 200 200 200
pH (SU): o�' 6-9 6-90.0 6-9 6.9
Residual Chlorine (µgft yFre rng/I ' &:Qrng/I ' 17.0 17.0 "
Oil&Grease (mgA): nr nr nr nr
TP(mgA): 2.0 2.0 0.7 1.0
RECEIVING STREAM:East Prong Slocum Creek TN (mgA): monitor monitor 4.0 8.0
Class: C-Swamp NSW Limit effective until expansion, at which time a 17.0 µg/I limit will apply. Dechlorination
or an alternative method of disinfection is required
Sub-Basin: 03-04-10 •• Dechlorination or an alternative method of disinfection is required. Monitoring is not
required if an alternative method of disinfection is implemented
Reference USGS Quad: H 31 NW (please attach) ^' The monthly average effluent CBODS and Total Suspended Residue concentrations ! •1
County: Craven
shall not exceed 15%of the respective influent value(85% removal).
Regional Office:_ Washington Regional Office 41tax
Daily Max. -ffa-i�Max.
Previous Exp.Date: 5/31/93 Treatment Plant Class: Class IV Flow(mgd): 1_50 1.90
Cadmium (µgA): nr nr
Classification changes within three miles: Chromium (µg/l): monitor monitor
changes to SC Swamp NSW at Slocum Creek Copper(µg/1): monitor monitor
Nickel (µg/l): monitor monitor
Lead (µg/l): monitor monitor
Zinc (µg/1): monitor monitor
Aluminum (µgA): monitor monitor
Requested by: re Nizich Dale: 10/13/93 Conductivity (µmho/cm): monitor monitor
Mercury (µg/l): nr nr
Silver (µg/1): nr nr
Prepared by: I `�-' Date: t l a l g y
Reviewed by: (� Date: '1 I0L� I
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NPDES WASTE LOAD ALLOCATION
PERMIT'NO.:
NCO021253 Modeler Date Rec. #
PERMITTEE NAME: City of Havelock
0 ] 1 Li
FACILITYNAME:
Havelock Wastewater Treatment Plant Drainage Area(mil ) Avg. Streamflow (cfs):
Facility Status: Existing 7Q10 (cfs) Winter 7Q10 (cfs) 30Q2 (cfs)
Permit Status: Renewal Toxicity Limits: IWC % Acute/Chronic
Major Minor Instream Monitoring:
Pipe No.: 001 Parameters
Design Capacity: 1.9 MGD Upstream Location
Domestic (%of Flow): 100 % Downstream Location
Industrial(%of Flow):
Effluent Summer Winter
Comments: Characteristics
BOD5 (mg/1)
NH3-N (mg/1)
RECEIVING STREAM:East Prong Slocum Creek D.O. (mg/1)
Class: C-Swamp NSW TSS (mg/1)
Sub-Basin: 03-04-10 F. Col. (/100 in])
Reference USGS Quad: H 31 NW (please attach) pH (SU)
County: Craven
Regional Office: Washington Regional Office
Previous Exp. Date: 5/31/93 Treatment Plant Class: Class IV
Classification changes within three miles:
changes to SC-Swamp NSW at Slocum Creek
Requested by: Greg Nizich6'510 Date: 10/13/93
Prepared by: Date: Comments: P xt `I1 Z1
Reviewed by: Date:

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GKEX88/MP 10/11/93
COMPLIANCE EVALUATION ANALYSIS REPORT PAGE 1
PERMIT--NC0021253 PIPE--001 REPORT PERIOD: 9209-9308 LOC---E
FACILITY--HAVELOCK WWTP, CITY OF DESIGN FLOW-- 1.5000 CLASS--4
LOCATION--HAVELOCK REGION/COUNTY--07 CRAVEN
50050 00310 00530 00610 31616 50060 00300 TGP3B
MONTH Q/MGD BOD RES/TSS NH3-N FEC COLI CHLORINE DO CERI7DPF
LIMIT F 1.5000 F 5.00 F. 30.0 F 2.00 F 1000.0 NOL F 6.00
92/09 . 9901 2.12 1.1 .00 19.5 .347 7.83
LIMIT F 1.5000 F 5.00 F 30.0 F 2.00 F 1000.0 NOL F 6.00 NOL
92/10 . 9838 1. 63 .5 .00 28.3 .281 8.35 1
LIMIT F 1.5000 F 11.00 F 30.0 F 3.00 F 1000 .0 NOL F 6.00 NOL
92/11 1.0482 1. 62 .6 .00 23.5 .272 8 . 65
92/12 1.0337 1.84 .3 .00 13. 6 .319 9.10
93/01 1.3325 5.60 20.6 .11 77 .1 .321 9.17 2
93/02 1.3112 2.75 7.8 .04 25.0 .340 9.46
93/03 1.4613 3.00 7. 9 .03 25.0 .269 9.43
LIMIT F 1.5000 F 5.00 F 30.0 F 2.00 F 1000.0NOL F 6.00 NOL
93/04 1 .3665 9.70F, 6 .13 91.7 .342 8 . 99 1
93/05 1. 1180 2 .77 1.3 .03 60 .3 .340 8.39
93/06 1.0999 4.5 .00 121.7 .368 8.04
LIMIT F 1.5000 F 5.00 F 30.0 F 2.00 F 200.0 NOL NOL NOL
93/07 1.0690 1. 9 .00 155. 6 .276 7 . 64 1
93/08 . 9499 2.0 .02 36.0 .295 7. 64
AVERAGE 1 .1470 3.44 9.0 .03 56.4 .314 8.55 1
MAXIMUM 2.2530 150 .00 1200 .0 1. 60 17000.0 1.200 9.80 2
MINIMUM .8180 .70 LESSTHAN LESSTHAN 1.0 LESSTHAN 7.30 1
UNIT MGD MG/L MG/L MG/L #/100ML MG/L MG/L PASS/FAI
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CITY OF HAVELOCK
Post Office Drawer 368
Havelock, N.C. 28532 i. OCI 4 1993
'YG�RI RATEO
WAT%F? :emu
t N
September 28 , 1993 •4
N
Mr . Preston Howard , Director
Division of Environmental Management
North Carolina DEHNR
P .O . Box 29535
Raleigh , NC 27626-0535 OCT 1 1993
Subject : City of Havelock NPDES Permit Renewal WOFENVINMMENTALMGMHT.
DIRECTORS OFFICE
Dear Mr . Howard :
.Attached is the City of Havelock ' s application for NPDES
permit renewal . Our current permit expires March 31 , 1994 . It
is our understanding that under the Neuse Basinwide Water Quality
Management Plan , Havelock ' s NPDES permit will be issued for a
five ( 5 ) year period , as will all other permits in the sub-basin
ten ( 10) of the Neuse River .
The City of Havelock anticipates that its average daily
discharge under the present permit limits will exceed 1 . 5 MGD
rn
before March of 1999 . the date of expiration of the initial arn
permit under the basinwide approach . With this factor in mind , = 3;
the City of Havelock will simply ask that the discharge limit be
N:
increased from 1 . 5 to 1 . 9 MGD upon completion of Phase II of our
plant upgrade to be completed by June of 1996 , as it is permitted m:
under the current permit which expires March 31 , 1994 . z1
z_
Also , a pilot filter system for nitrogen removal is not _ cc
reducing nitrogen to levels expected and methanol feed is in- p z
creasing BOD . Therefore , we will need to negotiate or remove ~
limits for total nitrogen .
The City of Havelock appreciates the help and cooperation it
receives from the DEM . Should you have any questions , please
feel free to call me anytime .
Sinc ely ,
H . al Kennedy
City Manager
Enclosure
\HRK/ jd
Phone(919) 444-6401 Fax[phone]

EXISTING ANNUAL AVERAGE 1.1. MGD
EXISTING PERMITTED 1.5 MOD
BAR SCREEN/
GRIT CHAMBER
RAS
INFLUENT PUMP STATION
SPUTTER BOX
CONTACT
STABILIZATION UNITS
- SLUDGE
CONCENTRATOR
NITRIFICATION TANKS
INTERMEDIATE PUMP STATION
WAS - AEROBIC
FINAL CLARIFIER DIGESTERS
CHLORINE CONTACT BASIN
REAERATION BASIN
PARSHALL FLUME SCHEMATIC OF EXISTING
DISCHARGE #001 WAS'IEWATER FLOW
EAST PRONG OF SLOCUM CREEK HAVELOCK WWTP
HAVELOCK, NORTH CAROLINA
DISCHARGE #001
NOVEMBER, 1992
PAGE 1 OF 2

EXISTING ANNUAL AVERAGE 1.1 MGD
BAR SCREEN/ PROPOSED PERMIT 1.9 MGD
GRIT CHAMBER
RAS
INFLUENT
PUMP STATION
AERATION DISTRIBUTION
BOX # 1
1 ST. STAGE
AERATION
BASINS NO. 1 NO. 2
H
AERATION
DISTRIBUTION N
BOX #2 ¢
2 ND STAGE
AERATION W). 1 N0. 2 N0. 3
BASINS
FINAL CLARIFIER
FINAL CLARIFIER FINAL CLARIFIER INFLUENT PUMPcc
INFLUENT DISTRIBUTION STATION
PUMP STATION BOX FINAL CLARIFIERS
(SERIES FLOW WAS
OPTION) NO. 1
NO. 1 NO. 2 LIME,
STABILIZATION
WAS
FINAL CLARIFIERS
(PARALLEL FLOW -LIME
OPTION) STABILIZATION NO. 2
FILTERS,
ULTRAVIOLET
DISINFECTION FILTERS
REAERATION BASIN
PARSHALL FLUME
DISCHARGE #001
—yy
EAST PRONG OF SLOCUM CREEK SCHEMATIC OF PROPOSED
WASTEWATER FLOW
HAVELOCK WWTP
HAVELOCK,NORTH CAROLINA
DISCHARGE #001 NOVEMBER, 1992
PAGE 2OF2

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ROAD CLASSIFICATION
LANE,6 LANE
Heavy"duly— Light-duty—
Medium-duty A L4NE,6 LANE Unimproved dirt.......
OU. S. Route O State Route
QUADRANGLE LOCATION HAVELOCK, N. C.
Map photoinspected 1971 N3452.5—W7652.5/7.5
No major culture a drainage changes observed
1949
PHOTOINSPECTED 1971
AMS 5653 IV NW—SERIES V842
LOCATION MAP
FROM USGS MAP 1971
HAVELOCK WWTP
HAVELOCK, CRAVEN COUNTY.
NORTH CAROLINA
JUNE 1991
PAGE 1 OF 1

CITY OF HAVELOCK, NORTH CAROLINA
NPDES PERMIT APPLICATION
PROPOSED TREATMENT MODIFICATIONS
The City of Havelock requests approval to increase its present
permitted discharge of treated wastewater to the East Prong of Slocum
Creek. The proposed increase would be from 1 . 5 million gallons per
day (MGD) to 1 .9 MGD.
To provide the level of treatment required at the higher permitted
flow the City proposes to modify the existing activated sludge system
to increase the detention time from 11 hours at 1 .5 MGD to 14 hours at
1 .9 MGD. New air diffusers will be installed to improve oxygen
transfer and provide both greater treatment capacity and lower energy
costs . New final clarifiers and tertiary filters will also be added.
The chlorination system will be expanded and de-chlorination added, or
ultraviolet disinfection will be utilized. Chemical treatment
facilities will be added to insure that the more restrictive
phosphorus limits are met.
The expanded solids management system will consist of waste activated
sludge thickening, lime stabilization of the thickened solids,
expanded solids storage, and continued land application of the bio-
solids as a liquid.
The existing preliminary treatment system, screening and grit removal,
will remain since the capacity is adequate at 1 .9 MGD.

As indicated in the permit application forms, we propose that the limits for
the expanded WwTP be the following:
Flow 1.9 MGD
CBOD 3.0 mg/l / 6.0 mg/l (Summer/Winter)
NH3-N 0.5 mg/1 / 1.0 mg/i
Total Phosphorus 0.7 mg/l / 1.0 mg/l
Total Nitrogen No Limit
Total Suspended Solids 30 mg/1

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1
��CO.4POR a TED fl�9
CITY' OF HAVELOCK
WASTEWATER TREATP¢27P FACILITY
P.O. Drawer 368
Havelock, North Carolina 28532
NARRATIVE DESCRIPTION OF SLUDGE MANAGEMENT PLAN
The City of Havelock land applies both liquid and belt
thickened sludge to the John B . Hardee farm on Old Airport
Road, New Bern. The site is fenced, and locked gates provide
restricted entry. The City utilizes approximately 160 acres
of the permitted 200 acres at the site . The remainder
provides land for roads and buffer zones . The sludge is
currently applied to permanent pasture , but it has also been
utilized for corn and soybean crops raised as cattle feed.
The staff applies the sludge in a uniform manner and records
each load as it is applied. The landowner ( farmer) is
responsible for applying lime to the field before use . He
also provides soils analyses for our records .
The farm is sectioned into six smaller sites on which to
rotate application. A written running log is maintained for
each of the six fields . The log includes the amount of
sludge applied in dry pounds and in dry tons , the plant
available nitrogen and copper in pounds , and the permit
limits so that no field is subject to overloading . A copy of
these records is submitted quarterly to DEM' s Washington
Regional Office along with a map showing total pounds applied
to date for each field.
Sludge analyses are performed quarterly on the wastewater
treatment plant sludge for TKN, NI6 -N, NOa , NO_- , and Cu.
Semi-annual analyses for TKN, NO3-NOa , and Cu are performed
on filter backwash sludge from the water plant. These
records are maintained at the wastewater treatment facility
and are available upon request.

q
I
RECEIVED
WASH NGTON OFFICE
FACT SHEET FOR WASTELOAD ALLOCATION
NOV 1 6 t993
Request# 7621 �rybZZ
Facility Name: Havelock Waste Water Treatment Plant I o. E. M.
NPDES No.: NCO021253
Type of Waste: Domestic - 100%
Facility Status: Existing
Permit Status: Renewal
Receiving Stream: East Prong Slocum Creek
Stream Classification: C - Swamp NSW
Subbasin: 03-04-10
County: Craven Stream Characteristic:
Regional Office: Washington USGS # 02.0926.4675
Requestor: Nizich Date: • 1989
Date of Request: 10/1 3/9 3 Drainage Area(mi2): 35.0
Topo Quad: H 3 1 N W Summer 7Q10 (cfs): 0.0
Winter 7Q10 (cfs):
Average Flow (cfs): 46.0
30Q2 (cfs):
IWC (%):
Wasteload Allocation Summary ,n rn
(approach taken, correspondence with region, EPA, etc.) 'o
Permit re-issued with same limits. -
* Note: facility currently has 200/100 nil fecal coliform limit. rn�
r ,
Special Schedule Requirements and additional comments from Reviewers: z �'
-E
cCD
1
JV
Recommended by: n 1 i y� Date: ji 6t��
Farrel!Keough
Reviewed by
Instream Assessment: Date: 11151cl
Regional Supervisor: C Date: �� 3 ��
Permits&Engineering: Dater
DEC 0 8 1993
RETURN TO TECHNICAL SERVICES BY:

CONVENTIONAL PARAMETERS
Existing Limits:
Monthly Average Monthly Average
Summer Winter Summer Winter
Wasteflow(MGD): 1.50 1.5 1.90 Vi
CBOD5(mg/l): 5.0 *** 11.0 *** 3.0 *** 6.0 ***
NH3N (mg/i): 2.0 3.0 0.5 1.0
DO(mg/I): 6.0 6.0 6.0 6.0
TSS (mg/1): 30 *** 30 *** 30 *** 30 ***
Fecal Col. (1100 ml): 200 200 200 200
pH (SU): 6-9 6 -9 6-9 6 -9
Residual Chlorine(µo): 17.0 * 17.0 * 17.0 ** 17.0 **
✓Jyv Oil &Grease(mg/1): nr or nr or
TP (mg/1): 2.0 2.0 "6-1 -rut•D
TN(mg/1): monitor monitor 4.0 A;06$
* Effective upon expansion. Dechlorination or an alternative method of disinfection is required
** Dechlorination or an alternative method of disinfection is required. Monitoring is not required if an alternative
method of disinfection is implemented
kkk The monthly average effluent CBOW and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85910 removal).
Recommended Limits:
Monthly Average Monthly Average
Summer Winter wQ.EL Summer Winter wQ.EL
Wasteflow(MGD): 1.50 1.5 1.90 111
CBOD5 (mg/1): 5.0 *** 11.0 *** WQ 3.0 *** 6.0 *** WQ
N143N (mg/1): 2.0 3.0 WQ 0.5 1.0 WQ
DO(mg/I): 6.0 6.0 WQ DO 6.0 6.0 WQ O°
TSS (mg/1): 30 *** 30 *** 30 *** 30 ***
Fecal Col. (/100 ml): 200 200 200 200
pH (SU): 6 -9 6-9 6-9 6-9
Residual Chlorine(µg/I): (17.0 (17.0 WQ 17.0 ** 17.0 ** WQ
Oil &Grease(mg/I): nr nr nr fir
TP(mg/I): 2.0 2.0 WQ toti-1 W 1.0 WQ
WQ
TN (mg/I): monitor monitor 4.0 4a$
R0.ChlevitQ=0.Lom91l Ord l el`-p n5ion,4+Jw11L'5'1
* Effective upon expansion. Dechlorination or an alternative method of disinfection is required
** Dechlorination or an alternative method of disinfection is required. Monitoring is not required if an alternative
method of disinfection is implemented
*** The monthly average effluent CBODS and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
Limits Changes Due To: Parameter(s) Affected
Change in 7Q10 data
Change in stream classification
Relocation of discharge
Change in wasteflow,
Other(onsite toxicity study,interaction,etc.)
Insueam data
New regulations/standards/procedures
New facility information
(explanation of any modifications to past modeling analysis including new flows,rates,field data,interacting
discharges)
(See page 4 for miscellaneous and special conditions,if applicable)

TOXICS/METALS
Type of Toxicity Test: Chronic Toxicity (Ceriodaphnia) P/F
Existing Limit: 90%
Recommended Limit: 90%
Monitoring Schedule: January, April, July, and October
Existin Limits
imits
Daily Max. Daily Max.
Flow (mgd): 4-1301.5 4 t90-I.
Cadmium (µo):
Chromium (µo): monitor monitor
Copper(µg/1): monitor monitor
Nickel (µo): monitor monitor
Lead (µo): monitor monitor
Zinc (jig/1): monitor monitor
Aluminum (µo): monitor monitor
Conductivity (µmho/cm): monitor monitor
Mercury (µg/1):
Silver(µg/1):
Recommended Limits
Daily Max. wQmEL Daily Max. wQmEL
Flow (mgd): -9-.f5o, I.5 -0 5e• I. q
Cadmium (µg/1):
Chromium (µo): monitor monitor
Copper(µg/1): monitor monitor
Nickel (µo): monitor monitor
Lead (µo): monitor monitor
Zinc (gg/1): monitor monitor
Aluminum (µo): monitor monitor
Conductivity (µmho/cm): monitor monitor
Mercury (µg/l):
Silver (µg/l):
Limits Changes Due To: Parameter(s) Affected
Change in 7Q10 data
Change in stream classification
Relocation of discharge
Change in wasteflow
New pretreatment information
Failing toxicity test
Other(onsite toxicity study,interaction,etc.)
_x_ Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
OR
No parameters are water quality limited, but this discharge may affect future allocations.

INSTREAM MONITORING REQUIREMENTS
Upstream Location: refer attached
Downstream Location: refer attached
Parameters: refer attached
Special instream monitoring locations or monitoring frequencies:
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Adr,quacy of Existing Treatment
Has the facility demonstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes No
If no, which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate? Yes_ No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
Special Instructions or Conditions
Wasteload sent to EPA? (Major) _(Y or N)
(If yes, then attach schematic, toxics spreadsheet,copy of model,or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
Additional Information attached? (Y or N) If yes, explain with attachments.

Special Instream Monitoring Requirements NC0021253
Parameter Frequency Method / Sample Type Location
DO 3/week,Apr- Oct; 1 /week, Nov - Mar vertical - at 1 meter increments 1,2
2/month, Jun - Sep vertical - at 1 meter increments 3,4
Temperature 3/week, Apr- Oct; 1 /week, Nov - Mar vertical - at 1 meter increments 1,2
2/month, Jun - Sep vertical - at 1 meter increments 3,4
Conductivity 3/week,Apr- Oct; 1 /week, Nov - Mar vertical - at 1 meter increments 1,2
2/month, Jun - Sep vertical - at 1 meter increments 3,4
Salinity 3/week, Apr- Oct; I /week, Nov - Mar vertical - at I meter increments 1,2
2/month, Jun - Sep vertical - at 1 meter increments 3,4
Secchi Depth 2 /month,Jun - Sep 1,2,3,4
Total Phosphorus 2 /month,Jun - Sep depth integrated composite sample 1,2,3,4
Total Nitrogen 2/month, Jun - Sep depth integrated composite sample 1,2,3,4
NH3-N 2/month, Jun - Sep depth integrated composite sample 1,2,3,4
NO, 2/month, Jun - Sep depth integrated composite sample 1,2,3,4
Chlorophyll -a 2/month, Jun - Sep depth integrated composite sample 3,4
pH 2 /month, Jun - Sep depth integrated composite sample 3,4
Monitoring Locations:
1.) East Prong Slocum Creek at Highway 70
2.) East Prong Slocum Creek at Slocum Village Personnel Bridge
3.) Slocum Creek upstream of Cherry Point outfall, 2 miles below Havelock WWTP outfall
4.) Slocum Creek above Tucker Creek, 4 miles below Havelock WWTP outfall
* Note: depth-integrated samples should be composites taken within the photic zone [i.e., 2x's the Secchi depth]

Facility Name City of Havelock Waste Water Treatment Plant Permit n NCO021253 Pipe n 001
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The Notch Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 90 % (defined as treatment two in the North Carolina procedure document). The permit holder
shall perform quarterly monitoring using this procedure to establish compliance with the permit condition.
The first test will be performed after thirty days from the effective date of this permit during the months of
Jan., Apr., Jul., and Oct. Effluent sampling for this testing shall be performed at the NPDES permitted
final effluent discharge below all treatment processes.
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 TGP3B.
Additionally, DEM Form AT-1 (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 single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly
in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the receiving stream, this permit may be re-opened
and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will require
immediate retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will
constitute noncompliance with monitoring requirements.
J"'
7Q10 0.0 cfs
Permitted Flow 1.50 MGD Recommended
lWC 100 % Farrell Keough
Basin & Sub-basin 03-04-10
Receiving Stream East Prong Slocum Creek
County Craven Date Y Ahxr.acrL, laq�)
QCL P/F Version 9191

Facility Name City of Havelock Waste Water Treatment Plant Permit # NCO021253 Pipe #
001
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay Procedure -
Revised*September 1989)or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality is 90 %
(defined as treatment two in the North Carolina procedure document). The permit holder shall perform quarterly monitoring
using this procedure to establish compliance with the permit condition. The fuse test will be performed after thirty days
from the effective date of this permit during the months of Jan., Apr., Jul., and Oct. Effluent sampling for this
testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
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 TGP3B. Additionally, DEM Form AT-1
(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 single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing,this monthly test requirement will revert to quarterly
in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Environmental
Management indicate potential impacts to the receiving stream,this permit may be reopened 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. 'I
7Q10 0.0 cfs �-
Permitted Flow 1.90 MGD Recommended by: L -
IWC 100 % Farrell Keough
Basin & Sub-basin 03-04-10
Receiving Stream East Prong Slocum Creek
County Craven Date i Nok. r�<2 1555
I
QCL PIF Version 9191

Facility Name: Havelock Waste Water Treatment Plant
Permit Number: NC0021 253
Engineer: Nizich
Subbasin: 03-04-10
Recieving Stream: East Prong Slocum Creek
USGS quad #: H31 NW
Request Number: 7621
Date: 10/13/9 3
Expiration date: 5/31/93
Existing WLA checked: x
Staff Report:
Topo checked:
USGS Flows confirmed:
PIRF/APAMS: nr
IWC Spreadsheet: x
Stream Classification: x
Nutrient Sensitivity: x
Instream Data: nr
Brief of WLA Analysis
Reissuance with same limits; last WLA finalized February, 1993. Changes were requested by facility in letter dated May
13, 1993, (in WLA file) with a response from Preston Howard dated June 30,,1993, (letter attached to WLA request).
These changes are reflected in the attached permit pages. A Fact Sheet will be*sent out on this facility since it is a major
and so controversial. The last Fact Sheet sent to WaRO on this facility was not signed and a comments page was
attached requesting denial of an expansion by this facility. Tedder ended up signing the Fact Sheet, thus=iret}mventipp
the Region. ovr r
The stringent limits for this facility are currently based on the Slocum Creek configuration; it closes down at the far end
and thus acts like a lake. The USMC Cherry Point discharge used to be to this body of water also, even with these levels
of treatment by Havelock, Slocum Creek will still need time to rebound from previous waste levels pumped into it.
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SOC PRIORITY PROJECT: Yes No ✓
If Yes , SOC No . It
•r
t
To: Permits and Engineering Unit
Water Quality Section
g8g F
Attention: (Greg Nizich)
Date: No 1 , 1993 `Nov 31993
IF(N1Vi '
NPDES STAFF o REtPiORT AND RECOMMENDATION'
SUpppR7 BRANCH
Craven
'1
Permit No. NCO021253 (;
i
PART I - GENERAL INFORMATION
1. Facility and Address: Havelock Wastewater Treatment Plant
Post Office Box 368
Havelock, N.C. 28532
2 . Date of Investigation: October 28, 1993
3 . Report Prepared by: Lyn Hardison
4 . Person= Contacted and Telephone Number: Susan Rexrode
919/444-6421
5. Directions to Site: Located off Jackson Drive, approximately
0.4 miles North of Hwy 70 in Havelock.
6. Discharge Point(s) , List for all discharge points:
Latitude: 340 53 ' 20" Longitude: 760 54 ' 30"
Attach a USGS map extract and indicate treatment facility site
and discharge point on map.
U. S.G. S. Quad Name Havelock
7. Site size and expansion area consistent with application ?
XX Yes No If No, explain:
S . Topography (relationship to flood plain included) :
Flat, elevation of 10 feet
9 . Location of nearest dwelling: approximately 75 yds

10. Receiving stream or affected surface waters: East Prong of
Slocum Creek ,
a. Classification: "C" Swamp NSW
b. River Basin and Subbasin No. : Neuse: 030410
C. Describe receiving stream features and pertinent
downstream uses: Fishing, boating and drainage
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 1 . 9 MGD(Ultimate
Design Capacity) After expansion
b. What is the current permitted capacity of the Waste Water
Treatment 1 . 5 MGD facility?
C. Actual treatment capacity of the current facility
(current design 1. 5 MGD capacity) ?
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two
years: July 27 , 1993 A to C was granted to the City
to install a sludge stablization system in order to
comply with 503 regulations.
e. Please provide a description of existing or
substantially constructed wastewater treatment
facilities: The 1. 5 MGD facility consist of
preliminary treatment (bar screen and grit removal)
followed by a contact stabilization process including
aeration, clarification, reaeration, followed by
nitrification basins followed by a final clarifier for
sedimentation. Then the chlorine contact basin for
disinfection followed by reaeration.
f. Please provide a description of proposed wastewater
treatment facilities: Treatment will consist of
screening, grit removal, activated sludge for
carbonaceous and nutrient removal, final clarifier,
chemical for additional nutrient removal, tertiary
filter for solids and nitrogen removal, chlorine
disinfection, dechlorination or UV treatment and
reaeration. Excess solids will be thickened, lime
stabilized and land applied.
g. Possible toxic impacts to surface waters: Possibly
Chlorine
NPDES Permit Staff Report
Version 10/92
Page 2

h. Pretreatment Program (POTWs only) :
in development approved
should be required not needed XX_
2 . Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DEM
permit no.W00000702
Residuals Contractor: City of Havelock
Telephone No. Susan Rexrode 919/444-6421
b. Residuals stabilization: PSRP PFRP_
Other
C. Landfill:
d. Other disposal/utilization scheme (Specify) :
3 . Treatment plant classification (attach completed rating
sheet) : Class IV
4 . SIC Code(s) : 4952
Wastewater Code(s) of actual wastewater, not particular
facilities i. e. . , non-contact cooling water discharge from a
metal plating company would be 14 , not 56.
Primary 01 Secondary.
Main Treatment Unit Cod-_ 072 3
Main Treatment Unit Code: 112 3 after expansion
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only) ?
2 . Special monitoring or limitations (including toxicity)
requests:
3 . Important SOC, JOC or Compliance Schedule dates: (Please
indicate) NA
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
NPDES Permit Staff Report
Version 10/92
Page 3

4 . Alternative Analysis Evaluation: Has the facility evaluated
all of the non-discharge options available. Please provide
regional perspective for each option evaluated.
Spray Irrigation: NA
Connection to Regional Sewer System: NA
Subsurface: NA
Other disposal options:
5. Other Special Items:
PART IV - EVALUATION AND RECOMMENDATIONS
According to the self monitoring data between September 1992
through August 1993 , Havelock's WWTP has produced effluent that
complies with its NPDES permit. Presently, the facility averages
a chlorine residual of 0.42 mg/l, and fecal coliform of 44 . 7/100
ml (permit limit of 1000/100 ml) .
During the time of the investigation, the facility is undergoing
construction/installing the lime ste`.iization system. The City
proposes to have their final construction plan to expand the
treatment system by June 1, 1994 .
Signa ure of report preparer
Water Quality Regional Supervisor
Date
NPDES Permit Staff Report
Version 10/92
Page 4

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Facility Name: Havelock Waste Water Treatment Plant
NPDES No.: NC0021253
Type of Waste: 100% Domestic
Facility Status: Existing
Permit Status: 201 Review
Receiving Stream: East Prong Slocum Creek
Stream Classification: C-Swamp NSW
Subbasin: 03-04-10
County: Craven Stream Characteristic:
Regional Office: Washington USGS#
Requestor: Swihart Date:
Topo Quad: H 31 NW Drainage Area(mi2): 35.0
Summer 7010(cfs): Tidal
Winter 7010 (cfs):
Average Flow(cfs): 46.0
30Q2(cfs):
IWC(%):
1975: 201 review of possible discharge points and quantities. Format and documentation limits the amount of information
presented. What looks to be an WLA indicates a 0.5 mgd discharge w/limits given in both mass and concentration,
(concentration presented)30 BODS,20 TKN, 5 dissolved oxygen, 30 TSS,200 fecal coliform, 6-9 pH. A second
201 submission also indicates numerous possible discharge locations and various discharge quantities. A memo
form WLA has limits for a 2.0 mgd discharge to East Prong Slocum Creek of 5 BODS,2 TKN,5 dissolved oxygen,
10 TSS, 200 fecal coliform, 6-9 pH.
1981: modeling notes indicate stream standard of 4.0 mg/I dissolved oxygen was used for this WLA. For a discharge of
1.0 mgd the recommended limits were 11 BODS,3 NH3-N,6 dissolved oxygen, 30 TSS, 1,000 fecal colform, 6-8.5
PH. A second WLA form includes the same limits for 1.0 mgd, but also has recommended limits for 2.0 mgd of 5
BODS, 2 NH3-N, 6 dissolved oxygen, 30 TSS, 1,000 fecal coliform, 6 -8.5 pH;this second WLA was not signed by
appropriate personnel. Letter in file indicates that the modeling analysis used the wrong reaeration coefficient(k2)
and thus the previously recommended limits would apply.
1982: expansion requests were already taking place for this facility by October. Recommended limits and attachments to
the memo's past back and fourth about this is not in files. WLA recommendations for 1.25 mgd were 11 BODS,
2 NH3-N,6 dissolved oxygen, 30 TSS, 1,000 fecal coliform,6 -8.5 pH.
19a5: Zoufaly modeled expansion from 1.25 to 1.50 mgd w/recommended limits of 5/11 BODS, 2/3 NH3-N, 6 dissolved
oxygen, 30 TSS, 1,000 fecal coliform,6-8.5 pH, (summer/winter respectively)
1986: SOC w/relaxed limits. Review of previous models indicates that upstream DO's were assumed at 7.0 and 6.6 mg/l;
also a letter in the file to the Town from Meg Kerr,gives a quick explanation of the A's that occurred.
1988: reissued w/same limits. BODµ spreadsheet attached.
1991: requested expansion to 1.9 mgd was Denied. Notes in file indicate that City received a letter that an expansion was
not recommended, (i.e. solve I and I problems). Trevor Clements talked w/City in 1991,telling them that an
expansion would be denied.
1992: good correspondence package from October, 1987 through June 1992 about Intensive Survey findings and needs,
actions between USMC Cherry Point and Town of Havelock, etc. Notes from meeting w/Havelock: Tedder stated
the DEM consistent since 1987 that no assimilative capacity exists in Slocum Creek. When our staff was
questioned about the instream dissolved oxygen readings being consistently higher downstream,Jay Sauber
answered that the receiving waters act as a lake due to poor flushing,thus it is the accumulation of the pollutants of
concern that constitute the problem.
1993: Steve Tedder met w/Town and allowed an expansion up to 1.9 mgd w/limits of 3/6 CBODS, 0.5/1 NH3-N,6
dissolved oxygen, 30 TSS, 1,000 fecal oolrform, 6-8.5 pH., 0.7/1 T. phosphorus,4/8 T. nitrogen, (summer/
winter respectively),plus dechlorination, (1993 letter from Town has the requests for these Permit limits).
1994: E-mail message stating that nitrogen limits were established through negotiations between DEM and Town, (may
not protect receiving waters but BAT at present).

� y -FYI _ C .j . �:
WARD AND SMITH. P. A. `^
ATTORNEYS AT LAW 1,01 ()�! ( ✓
1001 COLLEGE COURT
POST OFFICE BOX 867
120 wEST FIRE TOWER ROAD NEW BERN, N.C. 28563-0867 SUITE 2400
POST OFFICE BOX 8088 TWO HANNOVER SQUARE
GREENVILLE, N.0 27835-8088 FAYETT EVILLE STREET ALL
T ELEPHONE [phone] POST OFFICE BOX 2091
FACSIMILE (9191 756-3689 TELEPHONE [phone] RAL POST
H, N.C. 29602-2091
FACSIMILE [phone] TELEPHONE [phone]
FOURTH FLOOR FACSIMILE [phone]
202 NORTH OFF THIRD STREET
POST OFFICE B28 2179
WILMI02-
2179
TELE HONE N.C. 762-5 00
TELEPHONE 910) 62- 5 03
FACSIMILE [phone]
March 14 , 1994
COPY
VIA TELECOPIER 'J
Mr. Steve W. Tedder
Water Quality Chief , NCDEM
Post Office Box 29535
Raleigh, North Carolina 27625-0535
RE : Draft NPDES Permit No. NCO021253 -- City of Havelock
Our File 72-0017 (CL)
Dear Mr. Tedder:
This letter comments on the Draft NPDES Permit issued by DEM to the
City on February 15 , 1994 . As you and I . discussed recently by
telephone, engineers at Black & Veatch have expressed concern about
the availability of a reliable, cost effective filter system that
can meet proposed 4/8 Total Nitrogen limits without upsetting the
ability of the POTW to meet all other permit limits , such as CBOD.
It appears that there is a filter system on the market which
functions more reliably than the one recently tested by the City;
unfortunately, the cost is several orders of magnitude higher.
In light of our recent discussions concerning the potential long
term expansion needs for the City' s POTW and in order to show a
long term commitment to water quality protection, the City has
decided to install the high cost filter system in a maximum effort
to meet the proposed 4/8 Total Nitrogen permit limits and provide
for maximum long term water quality protection. On behalf of the
City, I would like to take this opportunity to thank you for your
candor in discussing DEM' s concerns and to ask that you and your
staff work closely with the City and its engineers to facilitate an
effective implementation of the planned WWTP facility upgrades .
In light of the above, the City accepts the February 15, 1994 Draft
NPDES Permit as written . However, there is one correction needed

WARD AND SMITH, P. A.
Mr. Steve W. Tedder
March 14 , 1994
Page 2
regarding the metals monitoring frequency contained in the draft
permit and referenced in David Goodrich ' s February 2 , 1994 letter
(copy enclosed) . As you may recall , Item 6 of Preston Howard ' s
June 30 , 1993 permit transmittal letter to the City ( copy enclosed)
documents the agreement reached between the City and DEM that
monitoring for metals only be required on a monthly basis and,
further, that after collection of one year ' s data the City could
apply to DEM for a further reduction in monitoring frequency. It
therefore- is requested that the "2/month" monitoring frequency
requirement for metals as contained in the draft permit be
corrected to "monthly. "
Thank you again for your assistance in resolving these matters and,
with best personal regards , I remain
Yours truly,
I . Clark Wright, Jr.
ICWjr: icwjr
WSMAIN/97121
Enclosures
cc : L--MY. David Goodrich
,Mr. Ralph Kennedy
Mrs . Susan Rexrode
Mr. Joe Hardee
Mr. Max Frazier
Mr . J . Troy Smith, Jr .

State of North Carolina
Department of Environment,
Health and Natural Resources ® C
Division of Environmental Management
stir
James S. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
February 2, 1994
Mr. H. Ralph Kennedy
City of Havelock
P.O, Box 368
Havelock NC 28532
Subject: DraftPernit
NPDES Permit ONC0021253
City of Havelock WWTP
Craven County
Dear. Mr. Kennedy:
The following change has been made from your existing permit:
Monitoring frequency for toxics and metals has changed from monthly to 2/month. The
2/month frequency on the existing permit was incorrect..DEM policy requires all class N
facilities that monitor these types of parameters to do so on a twice per month basis.
If you have any questions regarding this matter please call Mr, Greg Nizich at 919-733-5083.
Sincerely,
David A. Goodric?, Isl..upervisor
NPDES Permits Group
GSN:gn
ce: Washington Regional Office
Permit File
P.O. Box 29535, Raleigh, North Carolina 27626.0535 Talophono 919-733.5083 FAX [phone]
An Equal Opportunity Afflrmativo Action Employer, 50%recycled/10%Post-consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary RE'.) FEE A. Preston Howard, Jr., P.E., Director
June 30, 1993
Mr.-H. Ralph Kennedy, City Manager
City of Havelock
P.O. Box 368
Havelock, NC 28532
Subject NPDES Permit#NC0021253
City of Havelock WWTF
Craven County
Dear Mn Kennedy:
In accordance with your application for discharge permit received on November 23, 1992, we are
forwarding herewith the subject State - NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the US Environmental Protection Agency dated December 6, 1983.
Reference is made to the letter of May 13, 1993, from Mr. L Clark Wright, Jr.regarding the draft
NPDES permit for the subject facility. The Division of Environmental Mangemaent(DEM) has
reviewed the comments in the letter. The items are addressed below:
Item 1: Part I, Sections A(3) and A(4) - The monthly average, summer/winter limits for
CBOD5 have been changed from 2.0/4.0 mg/1 to 3.0/6.0 mg/1 as requested The associated
weekly averages have been modified proportionately as well.
Item 2: Part I, Sections A(3) and A(4) - The monthly average, summer/winter limits for N'H3
as N have been changed from 0.2/0.4 mg/1 to 0.511.0 mg/1 as requested There is no weekly
average limit for this parameter.
Item 3: Part I, Sections A(3) and A(4) - The quarterly average, summer/winter limits for total
phosphorus have been changed from 0.2/0.4 mg/I to 0.7/1.0 ma/1 as requested. 'There is no
weekly average limit for this parameter- the quarterly average is based on weekly samples..
Item 4: Part I, Sections A(3) and A(4) - Permit limits now become effective on June 1, 1996,
and likewise, the limits in Sections A(1) and A(2) are in effect through May 31, 1996. In
accordance with this change, no increase in flow is permr ed prior to June 1, 1996, evep if
ed before that date
plant expansion is cor/nplea u /ems,- CK-!' �
Item 5: Part I, Sections A(1) and A(2), a limit for total residual chlorine of 0.6 mg/l has been
added as re�uested, and will be in effect until expansion or June 1, 1996, wh;�ver occur fj
-� first. . � „�_d` 6-/-�G T- lw - �� �� �. : c.
Item 6: Monthly monitoring for aluminum, chromium, copper, nickel, lead and zinc is
required until at least one year's worth of data has been collected. After that time, the City may
request that DEM review the data to see if inducing the monitoring frequency is justified-
P.O. Box 29535,Raleigh. North Carolina 27626.0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer - 500/recycled/ 10/post-consumer paper

Item 7: A reporting form for the instream monitoring parameters is available from the
Washington Regional Office. Monitoring in upstream locations less than 1 meter in depth is
not required. The term "depth integrated using composite sampler" has been modified. The
sample required is a depth integrated composite within the photic zone.
Item 8: The permit has been modified to require influent monitoring for CBOD5 and Total
Suspended Residue so that compliance with the 85% removal requirement can be determined_
The Division hopes the above comments and changes resolve your concerns.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicative hearing upon written request within thirty
(30)days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings,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 11, 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 Environmental Management 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 Mr. Greg Nizich at telephone
number 919/733-5083.
Sincerely,
A. Preston Howard, Jr., P.E.
Director
cc: Mr. Jim Patrick, EPA
Washington Regional Office
Compliance
Central Files
y i

WARD AND SMITH, P. A.
ATTORNEYS AT LAW
1001 COLLEGE COURT
POST OFFICE BOX 867 SUITE 2400
12C, WEST FIRE TOWER ROAD. NEW BERN, N.C. 28 56 3-08 67 TWO HANNOVER SQUARE
POST OFFICE BOX 8088 FAYETTEVILLE STREET MALL
GREENVILLE. N.C. 27835-8088 RALEIGH. N.C. 27601
TELEPHONE [phone] TELEPHONE [phone] TELEPHONE [phone]
FACSIMILE [phone] FACSIMILE 1919) 836-$507
FACSIMILE [phone]
FOURTH FLOOR
202 NORTH THIRD STREET -
POST OFFICE BOX 2179
WILMINGTON, N.C. 28 402-2179
TELEPHONE [phone]
FACSIMILE [phone] May 13 , 1993 ,
VIA FEDERAL EXPRESS / 40
Ms . Coleen H. Sullins GGA\�N �.
Water Quality Section
NPDES Permits Group `9 -
North Carolina Division of
Environmental Management U
512 North Salisbury Street
Archdale Building ? _
Post Office Box 27687
Raleigh, North Carolina 27611-7687
RE : Comments -- Draft NPDES Permit No . NC0021253 ;
City of Havelock, North Carolina
Our File 72-0017 (BX)
Dear Ms . Sullins :
+v -
This letter provides comments from the permittee, City of Havelock
( "the City" ) , in response to DEM' s March 31 , 1993 Notice o£ Intent
to Issue a State NPDES Permit. In summary, the City seeks minor
modifications to the draft permit concentration limits for three
effluent characteristics ( 5-day Carbonaceous Biological Oxygen
Demand ( "CBOD/511 ) , Ammonia as Nitrogen ( "NH3 as N" ) , and Total
Phosphorous ( 11TP" ) ] , interim relief on dechlorination requirements ,
and clarification of several other permit provisions . The City
requests that these comments be included in the Administrative
Record for this NPDES permit and that all requested changes be
incorporated into the final NPDES permit .
These comments and requested amendments are submitted in full
appreciation of , and are not inconsistent with, the goals and
objectives reflected in the draft permit . As you know, the City
has one of the State ' s best POTW operators and an enviable track
record of obtaining the lowest possible levels of pollutant
discharge given the physical limitations of its facility. The
City' s proposed upgrades , to be completed on or before June 1 ,
1996 , greatly will enhance its pollution control capabilities and,

WARD AND SMITH, P. A.
Ms . Coleen H. Sullins
May 13 , 1993
Page 2
at the same time, allow for a modest increase in system capacity.
The City is confident the net effect of its POTW upgrade program,
coupled with issuance of a final NPDES permit in accordance with
the comments herein, will be to provide an increased level of
pollution control and water quality protection for Slocum Creek and
adjacent Neuse River watershed areas .
The City asks that DEM recognize that even with the best POTW
operators and the expenditure of several million dollars for POTW
facility upgrades , it is uncertain that the very stringent CBOD/5 ,
NH3 as N and TP concentration limits contained in the draft permit
can be met consistently. Any failure by the City consistently to
meet the proposed limits for these effluent characteristics could
result in severe and unnecessary consequences . In addition to
possible assessment of administrative and civil penalties ,
potential liabilities could include criminal charges and exposure
to third party citizen suit claims brought under Section 505 (a) of
the federal Clean Water Act ( 33 U. S .C . S 1365 (a) ] . The City would
be remiss if it did not identify and object to proposed draft
permit limits that simply are not attainable on a consistent basis .
After extensive consultation with its POTW operators and engineers ,
the City proposes the following adjustments to the concentration
limits contained in Part I , Sections A( 3 ) and A( 4 ) of the Draft
Permit : /
✓For CBOD/5 : Change the monthly average summer/winter
concentration limits for the post-expansion period from
2 . 0/4 . 0 mg/l to 3 . 0/6 . 0 mg/l (weekly average limits also
to be modified proportionately] ;
b`� � • ✓For NH3 as N: Change the monthly average summer/winter
concentration limits for the post-expansion period from
0 . 2/0 . 4 mg/l to 0 . 5/1 . 0 mg/l (weekly average limits also
to be modified proportionately] ; and
3 • ✓For TP (effective 6/l/96 ) : Change the monthly average
summer/winter concentration limits for the post-expansion
period from 0 . 2/0 . 4 mg/1 to 0 . 7/1 . 0 mg/l [weekly average
limits also to be modified proportionately] .
The purpose of these minor adjustments is to set these permit
limits at the most stringent level the City consistently can meet .
The limits proposed herein are more stringent than the very low
limits originally proposed by the City in its NPDES permit renewal
application. They represent a "compromise" vis-a-vis the draft

WARD AND SMITH, P. A.
Ms . Coleen H . Sullins
May 13 , 1993
Page 3
permit limits proposed by DEM only in the sense that they recognize
the technical limits of wastewater treatment technology and the
inherent variability of testing for such low concentration levels .
The proposed modifications do not compromise, however the water
quality of Slocum Creek or the We--use River watershed .
Additional comments and proposed draft permit modifications include
the following :
�+ Part I , Sections A( 3 ) and A( 4 ) use the phrase "beginning
on EXPANSION ABOVE 1 . 5 MGD" as the trigger for imposition
�^ of many new permit limits . The City requests that the
4c;n (01.0 above phrase be replaced with "beginning on June 1 ,
f� f U"1l - 1996" . This date, already referenced in the ++ footnote,
provides a much clearer reference point for imposition of
the new, more restrictive permit limits and the City is
. � )1{,lc confident it will have completed its expansion/upgrade
i project by that date . Sections A( 1 ) and A( 2 ) of .Part I
similarly should be modified by replacing the phrase
y, ,i l 6�y ✓ ,V "lasting until EXPANSION ABOVE 1 . 5 MGD" with "lasting
until May 31 , 1996"
y, —• $ art I , Sections A( 1 ) and A( 2 ) require, for the effluent
c characteristic "Total Residual Chlorine" ( "TRC" ) , that
the City implement "dechlorination or an alternate method
of disinfection" as of the effective date of the final
1� permit . As stated in the City' s permit application, the
City plans to implement Ultraviolet ( "UV" ) disinfection
tC �1V as part of its expansion/upgrade project. Existing
b % ` monitoring data indicate the City could meet an interim
TRC limit of 0 . 6 mg/l pending installation of the new UV
disinfection equipment . The City requests the draft
permit be modified to impose an interim TRC limit of 0 . 6
mg/l effective upon permit issuance and terminating June
1 , 1996 or upon completion of the POTW expansion/upgrade
project, whichever comes first.
G r e� �'• O"CA Part, I , Sections A( 1-4 ) require monthly monitoring for
j /v0� l y 0A six metals (Aluminum, Chromium, Copper, Nickel , Lead,
�y� Zinc) . The City proposes a footnote be added to these
V- monitoring requirements stating that upon letter request
�y� to DEM by the City, the frequency of this monitoring will
I be reduced to a quarterly basis upon collection of one
�j � year of satisfactory monthly data .

L
WARD AND SMITH, P. A.
Ms . Coleen H. Sullins
May 13 , 1993
Page 4
7 • Part I , Section A( 5 ) contains extensive in-stream
monitoring requirements . The City requests clarification
as to the form on which to. report such monitoring
�L results , the feasibility of monitoring at 1 meter
intervals in the shallower upstream locations , and thea � l
meaning of the phrase "depth integrated using composite
sampler" . . In the future the City may seek a reduction in
the intensity and/or frequency of some such monitoring
requirements should the data produced confirm expected
improvements in water quality.
JPart I , Sections A( 1-4 ) contain a ** footnote imposing
the EPA-mandated 85% removal requirement as measured by
monthly averages of influent and effluent test results
for CBOD/5 and Total Suspended Residue ( "TSR":) . The
permit monitoring requirements for CBOD/5 and TSR,
however, only specify effluent testing. The City
requests clarification in the final permit as to whether
it is required to test and/or report influent values for
CBOD/5 and TSR in order to satisfy the 85% rule .
UIse, Pursuant to DEM' s basinwide permitting schedule, the
�S�Vsydraft permit expires March 31 , 1994 . However, the draft
permit terms anticipate events occurring subsequent to
that date ( i . e. , the June 1 , 1996 date for imposition of
stricter TN and TP limits ) . The City understands that
Cve the final permit limits issued by DEM will not be; further
tightened in any respect for the subsequent April 1994 -
April 1999 full basinwide permit term.
Based upon the reasons set forth above and information previously
provided, the City respectfully requests that all above-described
minor modifications be made to the draft NPDES Permit . With
implementation of all such changes , the City consents to issuance
of a final permit . Should any of the above-described changes be
unacceptable to DEM, the City requests that DEM staff contact Joe
Hardee of Black & Veatch [ ( 919 ) 859-7203 ] , City Manager Ralph
Kennedy [ ( 919 ) 444-6401 ] , or the undersigned [ ( 919 ) 633-1000 ] prior
to making any final permit decision .

WARD AND SMITH, P. A.
Ms . Coleen H. Sullins
May 13 , 1993
Page 5
Thank you for your attention to this matter.
Yours very truly
I . Clark Wrl4et, Jr.
ICW: icw
WSMAIN\63237
cc : Mr. Ralph Kennedy
Ms . Susan Rexrode
Mr. Joe Hardee
Mr . Max Frazier