NC0020648_Speculative Limits_19930611

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit:
NC0020648
Washington WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
201 Facilities Plan
Instream Assessment (6713)
Environmental Assessment (EA)
Permit
History
Document Date:
June 11, 1993
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�2ern
a State of North Carolina
Department of Environment,
Health'' and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
June 11, 1993
Mr. Edward Burchins, City Manager
City of Washington
Post Office Box 1988
Washington, North Carolina 27889
LI.9WA
r***.J F1
Subject: NPDES Permit No. NCO020648
City of Washington Wastewater
Treatment Facility
Effluent Reuse
Beaufort County
Dear Mr. Burchins:
A review of the proposal to reuse the effluent from the City's wastewater treatment facility
in the National Spinning manufacturing process has been completed. Based on the
following assumptions, the Water Quality Section Staff has developed effluent limitations
and monitoring requirements for both facilities. The assumptions are as follows:
- The total volume from the Washington wastewater treatment plant (WWTP) will be
discharged to the Tar River through the National Spinning outfall and diffuser and the
outfaU to Kennedy Creek eliminated. Limits have been established for the existing flow
2.12 MGD and 2.5 MGD.
- The National Spinning effluent line and diffuser are adequately sized to handle the
additional volume of flow from the city's WWTP, 5.25 MGD. The 5.25 MGD is
based on the assumption that there will be days when National Spinning will not use
the ci'ty's effluent and therefore, the line will have to handle the entire volume of both
wastewater plants. To fully assess the proposed reuse and to draft a finalpermit,
information on the discharge line and diffuser is required.
Separate draft effluent limitations have been established for both the Washington and the
National Spinning facilities. These limitations will apply to the individual waste streams
prior to the combination of the effluents. The instream monitoring requirements, one
upstream at Grimesland Bridge and one downstream at the Highway 17 Bridge, will be
combined. The following limits are proposed for the Washington WWTP discharge to the
Tar River.
Flow
2.12/2.5 MGD
BIOD5 15mg/1
Total Suspended Solids 30 mg/1
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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Washington Reuse
June 11, 1993
Page Two
Ammonia 4 mg/l
Fecal 200 ml/1
pH 6-9
Acute Toxicity (Fathead Minnow) Quarterly P/F @ 90%
@ 2.5 MGD a chlorine limit of 28 µg/1 shall apply
-Effleunt 'Monitoring Requirements: Total Nitrogen, Total Phosphorous, chlorine,
cadmium) chromium, nickel, lead, cyanide, copper, zinc, silver and conductivity
-Upstream Monitoring (Grimesland): temperature, dissolved oxygen, conductivity, BOD5,
ammonia; chromium and salinity (The instrealn monitoring requirements shall be
coordinated to coincide with the National Spinning monitoring of the downstream site).
Since Washington is a member of the Tar Pamlico Basin Association, nutrient limits will
not be included in the NPDES permit at this time. As you know, a final decision on
whether nutrient limits will be applied at a future date is dependent on the success of the
NSW strategy for the Tar Pamilico Basin and the outcome of the Phase I studies under the
multi -party agreement. Since the results of those studies are unknown at this time, DEM
recommends that Washington begin planning for the potential for nutrient limits.
;I
As you are aware, the Division is currently expecting to receive the Hydroqual Estuary
model late this year that is being developed for the Tar Pamlico Basin Association. This
model will enable us to more accurately assess the water quality of the Tar River.
Please note that this information is preliminary only. Upon receipt of an application and
information on the effluent line and diffuser sizing, the permit limits shall be finalized. If
you need any additional information, please call Coleen Sullins or Ruth Swanek at
919n33-5083.
Sincerely,
Steve W. Tedder
Water Quality Section Chief

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AUG 2 3-1992 1
State of North Carolina TECHNICAL SUPPORT BRANCH,
Department of Environment, Health and Natural Resources
Division of Environmental Management I
512 North Salisbury Street a Raleigh, North Carolina 27611 ; II
James G. Martin, Governor i A. Preston Howard, Jr., P.E.
William W. Cobey, Jr., Secretary Acting Director
August 24, 1992
Mr. Edward Burchins, City Manager
City of Washington
Post Office Box 1988
Washington, North Carolina 27889
Subject: NPDES Permit No. NCO020648
City of Washington Wastewater Treatment Facility
Effluent Reuse
Beaufort County
Dear Mr. Burohins,
The Division is in receipt of your letter dated August 4, 1992, concerning the reuse of effluent from the City's wastewater
treatment facility. We are encouraged by the City's effort to find a more environmentally acceptable method of wastewater
management Although the effluent will be ultimately discharged into the surface waters, the Division currently thinks that
the further reuse of the wastewater by National Spinning and subsequent discharge into the Tar River is a definite
improvement over the continued discharge into Kennedy Creek.
Staff of the Water Quality Section has reviewed your letter and are in general agreement that this proposal is a win/win
scenario for all involved There are several areas that need to be evaluated further concerning the management and control of
effluent quality for National Spinning's reuse and actual permitting of the proposal. However, we are comfortable in stating
that this option appears to be a viable alternative and we will work with the city to achieve this goal.
One issue we would like evaluated is the option to divert all treated wastewater to National Spinning for their potential reuse.
We are aware that supply of effluent from the city could exceed demand by National Spinning, however, we would encourage
this total diversion due to National Spinning's existing ability to discharge to the Tar River. We are uncertain of the capacity
of National Spinning's effluent outfall but we feel this alternative should be strongly considered. Additionally, this may
allow the consideration of expansion of the Washington Wastewater Treatment Facility and less stringent effluent limits since
the discharge would be into the Tar River, rather than Kennedy Creek which is experiencing dissolved oxygen violations and
eutrophication from the input of nutrients from the current wastewater discharge.
Upon your review of these issues, we would like to schedule a meeting with the city and the company to discuss these
matters in greater detail. Please contact either Mr. Roger Thorpe, Water Quality Regional Supervisor of the Washington
Regional Office at [phone] or Mr, Donald Safrit, P.E., Supervisor of the Permits and Engineering Unit in the Raleigh
Central Office at [phone] at your earliest convenience to arrange an appropriate time for a meeting.
cc: Permits & Engineering Unit
%0iftical Support Branch
Washington Regional Office
National Spinning Company, Inc.
Buster Humphreys
Bill Reynolds
Asheville Fayeueville momer ille
704/251-6208 919/486-1541 704/663-1699
SinnccSincerely,%��
(44J(✓-li-G-'y"
Steve Tedder, Chief
Regional Office,
Raleigh Waghington
9191571-4700 919/946-6491
P.Lhuion Pnvenfion Pap
Wilmington Winston-Salem
9191395-3900 919/896-7007
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity AfSrmadw Action Employer

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August 4, 1992
North Carolina Department of Environment,
Health, and Natural Resources
Division of Environmental Management
P.O. Box 29535
Raleigh, NC 27626-0535
Subject: Effluent Reuse
NPDES NCO020648
Attention: Mr. Preston Howard
Gentlemen:
1992
UIV. OF E"'l ONYENTA,
DI ?ECTOR'g OFFICEGMNT.
q�
GM•
AUu ? 0 iy92
WATER QUALITY
SECTION
For the last two years, the City of Washington has been
evaluating alternatives to comply with current and future NPDES
Permit discharge requirements and provide expanded wastewater
service in the community. We have been told by the Division of
Environmental Management (DEM) that no additional flow will be
permitted for discharge to Kennedy Creek. We have received a
permit requiring us to comply with very stringent nutrient
limitations by the end of 1994 if the discharge continues to
Kennedy Creek.
Although the Wastewater Treatment Plant (WWTP) effluent is
currently in compliance with these stringent limitations, we have
determined that additional facilities are necessary to provide
consistent compliance with the total nitrogen limitation at
higher flows. We have projected our total flow at 2.5 million
gallons per day (mgd) by the end of the decade, exceeding our
permitted flow by 0.38 mgd. our current discharge averages 1.7
mgd, and this is expected to increase soon when we begin
receiving flow from the Town of Chocowinity.
The City evaluated the option to relocate the discharge to
Tar River to obtain additional permitted flow. The estimated
cost to relocate the discharge is more than one million dollars,
and the outfall must be constructed across sensitive areas, with
the possibility of public opposition. We believe that, although
"buying" nutrients in accordance with the Tar -Pamlico Nutrient
Sensitive Waters Implementation Strategy is an option, the
facilities necessary for compliance with stringent nutrient
limitations will eventually be mandated.
P. O. BOX 1988 —
WASHINGTON, N. C. 2788E
CITY OF WASHINGTON
[phone]

Page 2
Mr. Howard
August 4, 1992
We have developed an effluent reuse alternative in
cooperation with National Spinning Inc. (a major Textile
Manufacturing Company located in Washington) that will more
effectively achieve the objective of protecting the environment.
Over the last several months, officials of the City and National
Spinning have been discussing the potential for National Spinning
Inc. to use approximately eighty percent of the WWTP effluent
after 1994 when the plant upgrade is completed. Based on these
meetings and limited testing, effluent reuse is technically and
economically feasible, and the City plans to proceed with design
of facilities to make it a reality. We believe that this is a
superior alternative for protecting water quality than relocating
the discharge to Tar River and "buying" nutrients. This project
has the potential for protecting not only surface water quality
but also groundwater resources in that it significantly reduces
groundwater withdrawals for treatment and use as industrial
process water.
We realize that there are a number of issues that must be
addressed by the regulatory agencies. One of these is the fact
that, although the discharge to Kennedy Creek should be
significantly less than the monthly average permitted flow of
2.12 mgd, the discharge may exceed the permitted flow during
months of routine industry shutdowns. We need language in the
NPDES Permit to allow these temporary excursions of the flow
limit. Again, we intend to comply with the remaining constituent
limits at all times.
We would like to meet with you and other officials as
appropriate to discuss this project and determine what specific
concerns must be addressed during design. We plan to submit
plans and specifications and request authorization to construct
these facilities in early 1993. Please contact us if you have
questions regarding this letter.
Sincere
Ed Burchins
City Manager
EB/tb
pc: Dr. Ronald Levine, State Health Director
Mr. Rick Rowe, Division Director
Mr. Mike Bell, Regional Engineer
Mr. Jim Mulligan, DEM

Page 3
Mr. Howard
August 4, 1992
pc: Mr. David McNaught, PTRF
Mr. Doug Rader, EDF
Mr. Buster Humphreys, National Spinning
Mr. Bill Reynolds, National Spinning
Mr. Donald Safrit, DEM
Mr. Perry Nelson, DEM

�" �d mel Ssshins
Ak
n
P
C/ C��L Rul avii�u
lli6
July 27, 1992
Mr. Buster Humphreys
National Spinnng
Plymouth Street
Washington, NC 27889
6,
JUL 281992
OIV. OF IREC °ORS offICE ENTAL NT
M.
r R'yew, �'s• ; KID
,, " =3
WATER QUALITY
SECTION JUL 3 01992
Dear Mr. Humphreys: WAJER
This letter summarizes the discussions among the participants
at July 16, 1992 meeting. The City of Washington wants to sell
wastewater treatment plant (WWTP) effluent to National Spinning
for use in your manufacturing processes. Based on previous
discussions and limited testing by your personnel, it appears to
be technically feasible to use the upgraded WWTP effluent as yourr
raw water source.
The City will soon begin design of tertiary filter
facilities to upgrade the WWTP. These filters are necessary to
meet our discharge limits, and are also required to provide the
quality of raw water (essentially free of suspended solids)
needed by National Spinning. In addition, pumping facilities
will be required to get the effluent to existing storage
facilities and then in National Spinning's raw water piping. The
cost opinion for these additional facilities (including site
piping) has been included in a previous memorandum. The
estimated cost to National Spinning would be $0.22/1,000 gallons
(based on 2 mgd) to $0.27/1,000 gallons (based on 1.5 mgd). The
scheduled date of completing construction of the upgrade is
December 1994.
We believe that this is an excellent opportunity for both
the City and National Spinning. It clearly indicates our concern
for protecting surface water and groundwater resources. It makes
use of facilities that would otherwise be abandoned. This and
other efforts denote a cooperative working relationship between
the City and National Spinning.
We look forward to working with you on this project. Please,
contact me if you have any questions regarding this letter.
Very truly yours, _
CIT�OSHUGTON
n
0
Edward B rchins
CITY OF WASHINGTON — P. O. BOX 1588 — WASHINGTON, N. C. 2788E
0�
(6'15] 646-1033