NC0020648_wasteload allocation_19920226

NPDES DOCYNENT 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 (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
February 26, 1992
This docume Mt is priated oa reuse paper - ignore May
ooateat on the reverse side

E3a 5�
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 No Sal' b S
is ury trees • Raleigh, North Carolina 27604
James G. Martin, Governor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
February 26, 1992
The Honorable Floyd G. Brothers
City of Washington
PO Box 1988
Washington, NC 27889
Subject: NPDES Permit Application
NPDES Permit No. NCO020648
City of Washington
Beaufort County
Dear Mayor Brothers: Twg -'Kivee.
In accordance with your request received February 19, 1992, the Division of
Environmental Management (DEM) is returning your NPDES Permit modification application. A
copy of your application has been submitted to our Central Files for future reference.
Should you desire to reactivate your permit modification request after completion of your
investigation of discharge into the Tar River, please advise the Division of Environmental
Management in writing and resubmit the complete application with the appropriate application
processing fees. Please note that construction or operation of additional wastewater discharge
facilities without a permit may be considered a violation of the Division of Environmental
Management regulation 15 NCAC 2H .0101 and the North Carolina General Statutes (GS
143-215.1).
If you have any questions, please contact Mr. Dale Overcash at [phone].
cc: Washington Regional Office
Mr. Trevor Clements
Mr. Jim Patrick, EPA
Central Files
Sincerely,
George T.
,,
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NPDES WASTE LOAD ALLOCATION
PERMrr NO.: NCO020648
pER1vIITTEE NAME: The City of Washington / Washington WWTP
Facility Status: Existing
Permit Status: Renewal
Major -1 Minor
Pipe No.: 001*
Design Capacity: 2.12 MGD
Domestic (% of Flow):
Industrial (% of Flow):
96.6 %
3.4** %
Comments:
* Resubmittal based on relocated outfall - see attached
** See attached Pretreatment Form
STREAM INDEX: 28-002.5)
RECEIVING STREAM: Tar River
Class: C-NSW
Sub -Basin: 03-03-07
Reference USGS Quad: E30SE, Washington (please attach)
County: Beaufort
Regional Office: Washington Regional Office
Previous Exp. Date: 9/30/90 Treatment Plant Class: IV
Classification changes within three miles:
Requested by: Jule Shanklin
Prepared by: CM U,
Reviewed by:
3o.t>u "is_
Date: 9/4/90
Date: 3 I9 0 1
Dace:
Modeler
JDateRec.
I#
CMS
9
S
qo
S83(o
Drainage Area (mil ) �)Cl $ 8 Avg. Streamflow (cfs):.30 q3
7Q10 (cfs) / �p 6 Winter 7Q10 (cfs) 2 7�5 30Q2 (cfs)
Toxicity Limits: IWC % Acut Chronic
Instream Monitoring:
Upstream �
Downstream *-
Effluent
Characteristics
l% o i . 'U C.
NJ. YIVLY-
BOD5 (mg/1)
10
;r ov AV 1
NH3-N (mg/1)
U r0 h
D.O. (mg/1)
Jr
2/ ' VkLmu
TSS (mg/1)
30
�SAu yyt&w 4vv
F. Col. (/100 ml)
�Q�A
�rG - V"Vtn-iuV
pH (SU)
i� I
G niCIQ yytg�
7"P (9✓0
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ev' ill1/
2ri
C�i-JQe✓ i
re uiY Cup
ei ion e
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,nel
Comments:
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4 ' 4 A1jC
1;,S
August 20, 1990
Mr. Roger Thorpe, Regional Water Quality Supervisor
NC Department of Environment, Health and E:by r
Natural Resources
Division of Environmental Management
P.O. Box 1507
Washington, NC 27889
Subject: Outfall Extension to Tar River
City of Washington WWTP Effluent
Dear Mr. Thorpe:
Enclosed are copies of drawings you requested showing the proposed
relocation of the effluent discharge to the Tar River.
Our intention is to relocate the effluent line from Kennedy Creek
to the Tar River within three years. We plan this relocation due to the
low 7 Q 10 flow of Kennedy Creek and the limits required for continuing
to discharge into the Creek.
If you need additional information, please let me know.
Sincerely,,,
4w-a v
Russell Waters
Director of Public Works
RW/tb
Enclosures
pc: Tom Howell.
Jerry Cutler
CITY OF WASHINGTON - P. O. BOX 1922 - WASHINGTON, N. C. 27885
(9193 948-1033

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NPDFS PRETREATMENT INFORMATION RWMT FORM i . S
FACIIITY NAME: W466lNO�Dti WWTP, (, ,&PDES NO. NC00 2 ¢
;REQUESTER: w GJ w�C (� , DATE: 3 / 13 /1 RFX ION: Dj 07
IJpiliOy MAnb]Yii. • S 7,IYC
This facility has no SIUs and should not have pretreatment language.
This, facility should and/or is developing a pretreatment program.
Please include the following conditions:
_ Program Development ;
Phase I due
Phase II due
_ Additional Conditions
(attached)
This) facility is currently implementing a pretreatment program.
Please include the following conditions:
IX Program Implementation.;
_ Additional Conditions
,
(attached)
SIGNIFICANT INDUSTRIAL USERS'
SIU FUX9 - TOTAL:
- COMPOSITION: TEXTILE:
METAL FINISHING:
OTHER:
0io�v, YM
CI
_ ea
a�
r.�
HEAIMORKS REVIEW
Pr
� PARAMETEEi
i-------
-DAMS
LOAD IN hLiS/DAY—�U
jALLOWBLE
DaMESTIC
PERMI'iTED
I JE
BFrSI9�
Cd
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p, -0 oaf
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Cr
Cu
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8 2
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Pb
Zn
CN
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PJ• lS
o.vo/D
Phenol
—
Other
a•-o3q
01000
q
RECEIVED: 3 //S/ RMEWED sY: �i /vy G �REITJRNED: 3 /�/
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-1-
FACT SHEET FOR WASTELOAD ALLOCATIONS
Facility Name
NPDES No.
Type of Waste
Facility Status
Permit Status
Receiving Stream
Stream Classification:
Subbasin
County
Regional Office
Requestor
Date of Request
Topo Quad
The City of Washington
NCO020648
96.6% Domestic / 3.4%
Existing
Renewal
Tar River
C-NSW
030307
Beaufort
Waro
Jule Shanklin
9/5/90
E30SE
Industrial
Request No.5836
lygsy rro,v OPP,
F�9 i p 9qq,
E y
Stream Characteristics:
USGS # Estimates Date 1989
Drainage Area: 2988 sq.mi.
Summer 7Q10: 120 cfs (tidal)
Winter 7Q10: 275 cfs
Average Flow: 3073 cfs
30Q2: cfs
Wasteload Allocation Summary
An analysis was performed per request for relocation of the discharge
from Kennedy Creek to the Tar River above HWY 17. A DO analysis
was not performed since Technical Support lacks the pertinent data (i.e.
dispersion, tidal information, etc.) needed to support a model for this
estuary system. The Tar/Pamlico River will have a basin management plan in
place in the near future (1995). The basin plan will include a model that
will take into account all upstream discharges. This will provide Techni-
cal Support with the necessary information to assign limits for protection
of the water quality standards instream. Water quality reports and current
ambient data for the Tar/Pamlico River reveal algal blooms and violations
of the State's WQ standard for DO in the section of the River where the
Town would like to relocate.
WASTELOAD SENT TO EPA?(Major) _Y_ (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 fits into basinwide plan)
��� //��
Recommended by: J.(/7.C,L� Date:
Reviewed by
Instream Assessment
Regional Supervisor
Permits & Engineering
RETURN TO TECHNICAL SERVICES BY: MAR 0 7 1991
Date:
414
Date: 3f4tq(
-

-2-
CONVENTIONAL PARAMETERS
- KENNEDY CREEK -
Existing Limits
(Until Nov. 1993)
Month Average
Summer/Winter
Wasteflow
(MGD):
2.12
BOD5
(mg/1):
15
NH3N
(mg/1):
4
DO
(mg/1):
5
TSS
(mg/1):
30
Fecal Coliform (/100
ml):
200
pH (SU):
6-9
T. Phosphorus
(mg/1):
monitor
T. Nitrogen
(mg/1):
monitor
Chlorine
(ug/1):
monitor
(After Nov., 1993)*
Monthly Average
Summer/Winter
2.12
5/10
1/1.8
6
30
200
6-9
2
4/8
17
*Note: These limits apply in three years if the discahrge is not
relocated.
- TAR RIVER -
Recommended Limits Monthly Average
Summer/Winter
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1):
TSS (mg/1):
Fecal Coliform (/100 ml):
pH (SU) :
Oil & Grease (mg/1):
TP (mg/1):
TN (mg/1):
Limits Changes Due TO:
Instream Data
Nutrient Sensitive Waters
2.12
10 3141Q1
x
5
30
200
6-9
NR
Monitor
Monitor
Parameter(s) Affected
BOD5, NH3N
Phosphorus, nitrogen
Other:
Changes due to new location of discharge into the Tar River.
(explanation of any modifications to past modeling analysis
including new flows, rates, field data, interacting discharges, etc.)
(See page 4 for Miscellaneous and special conditions if apply)

MIM
TOXICS
Toxicity Limit Monitoring Schedule
(KENNEDY CREEK)
Existing Limit: 99% Chronic/Ceriodaphnia/Quarterly-Feb,May,Aug,Nov
(TAR RIVER)
Recommended Limit:-�y-��� �,aug,Nov
2�r rt4hW M,60CW 2,{ hil No 5,5, /1bdah lu
Toxics or metals limits J/
Existing Limits
Daily Maximum
Cadmium
(ug/1):
2.0
Chromium
(ug/1):
50.0
Copper
(ug/1):
monitor
Nickel
(ug/1):
88.0
Lead
(ug/1):
25.0
Zinc
(ug/1):
monitor
Cyanide
(ug/1):
5.0
Silver
(ug/1):
monitor
Chlorine
(ug/1):
monitor
Recommended
Limits
Daily Maximum
Cadmium
(ug/1):
NR
Chromium
(ug/1):
monitor
Copper
(ug/1):
monitor
Nickel
(ug/1):
NR
Lead
(ug/1):
monitor
Zinc
(ug/1):
monitor
Cyanide
(ug/1):
monitor
Silver
(ug/1):
monitor
Chlorine
(ug/1):
28 (may be changed to monitoring if
region sees the need)
Limits Chances Due to:
Parameter(s) Affected
Change in 7Q10 data all toxics limits, except chlorine
& toxicity test
Relocation of discharge all toxics including chlorine
& toxicity test
Protection from chlorine toxicity Chlorine
Other:
Due to the relocation of the discharge to the Tar River and increased
mixing, the existing chemical -specific toxic limits were changed to moni-
toring only. The chlorine limit of 28 ug/1 is to protect against acute
toxicity within the mixing zone.

. -4-
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
INSTREAM MONITORING REOU_IREMENTS:
Upstream: Yes Location: at Grimesland Bridge
Downstream: Yes Location: At Pamlico Bridge - HWY 17
Instream monitoring parameters:
DO, Temperature, BODS, NH3N, Conductivity, pH, Salinity
SPECIAL INSTRUCTIONS OR CONDITIONS:
A diffuser is required and location of the pipe should be determined by the
regional office after review of physical channel characteristics and upon
consultation with appropriate State Agencies.
SCHEDULE REQUIREMENTS:
(for P&E of region to recommend time frame for implementing new limits)
ADDITIONAL !'REVIEWER" COMMENTS:
Additional Information attached? (yes or no) If yes, explain attachments.
Information attached that will be sent to EPA.

Facility NameK4,nVl Permit# /UCX0Q(D4A
ACUTE TOXICITY TESTING REQUIREMENT (QRTRL7)
Fathead Minnow 24 hr - No Significant Mortality
The permittee shall conduct acute toxicity tests on a qmALrgrjy basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Detemtining Acute
Toxicity In A Single Effluent Concentration". The monitoring shall be performed as a Fathead
Minnow (Pime hales vromelas) 24 hour static test, using effluent collected as a 24 hour
composite. The effluent concentratioh at which there may be at no time significant acute mortality
in any two consecutive toxicity tests is 90% (defined as treatment two in the North Carolina
procedure document). Effluent samples for self -monitoring purposes must be obtained during
representative effluent discharge below all waste treatment. The fast test will be ppe�rformed after
thirty days from issuance of this permit during the months of FPJOtMA i _r. [�/4 V
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DEM Form AT-2 (original) is to be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687 '
Raleigh, N.C. 27611
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 either these monitoring requirements 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.
7Q10 100 cfs
Permitted Flow �. a MGD
IWC% a. °7
Basin & Sub -Basin /13o3O'7
Receiving Stream! -Tdr RIVEr
County %jeAUYor
Recommended by:
i...// �� .. �.: � � Wi
**Acute Toxicity(Fathead Minnow 24hr) No Significant Mortality at 90%, b
See Part �3 , Condition _T .

DIVISION OF ENVIRONMENTAL MANAGEMENT
i
February 1, 1991
To: File
From: Carla Sanderson
Subject: Washington WWTP Relocation
NPDES Permit No NCO020648
1Beaufort County
1!
In July 19901 a wasteload allocation for the City of Washington WWTP's NPDES
permit renewal was completed by Technical Support. As part of the recommend-
ations for renewal, the facility was asked to remove the discharge from Kennedy
Creek or make renovations to the treatment plant to meet tertiary treatment lim-
its (limits of 5mg/1 BODS, 1mg/1 NH3N, and 6mg/l DO), including 99% toxicity
limit and WQ standards for all toxics involved in the discharge.
In response to the Draft permit, the City choose to hold a meeting with DEM to
discuss the newly recommended permit limits and an alternate location for dis-
charge. The City decided to investigate a relocation to the Tar River just
upstream of Kennedy Creek. Therefore this WLA request for modification of the
permit wassubmittedto Technical Support:
Attempts to model the discharge to the Tar River were made using the Georgia
estuary model framework. Since there are too many gaps in the input information
at this time to get an adequate simulation of the system, the model was not used
to produce11limits for the relocation.
�i
The Washington WWTP is currently achieving close to tertiary treatment. Since
the City plans to relocate without any major modification'to the treatment
plant, Technical Support will issue limits of 10 mg/1 BODS, 2 mg/1 NH3N, and 5
mg/i DO. At an average design wasteflow of 1.57 MGD the plant is currently
achieving the following limits:
(Yearly Average 12/89 through 11/90)
BOD51 (mg/1) NH3N (mg/1)
1.951 0.77
(Maximum'Monthly Average 12/89 through 11/90)
3.0 4.85
NH3N is above 2.0 mg/1 monthly average two times in this year. All other times
the monthly average is 1 mg/1 or below for NH3N.

Information gathered from the "Interim Review (June -November 1988) of Baseline
Water Quality Data From The Pamlico and Neuse River Estuaries", NC Dept. EH&NR,
DEM. Water,Quality Section, is as follows:
The Pamlico River has numerous fill kills associated with ulcerative mycosis
(UM) (a disease associated with deep lesions). Research has yet to determine
the actual cause of the disease yet some support the theory that environmental
stresses such as organic enrichment and low DO contribute to UM.
Most algal blooms in the lower Pamlico occur during winter or late summer.
Anoxia & hypoxia (which are common in estuarine systems) seem to be increasing
in the Pamlico. Reports of summer algal blooms on the Pamlico have increased in
recent years (probably due to increased monitoring associated with the Albemar-
le-Pamlico'study and increased interest by the local population)
Nitrogen samples taken in the Pamlico showed that the highest concentrations are
located in„the river near Washington.
BODS averages for all samples taken in the Pamlico were found to be the highest
at the Pamlico R. station near Washington (mean = 5.4 mg/1). Phytoplankton Den-
sity (up to 80000 units/ml) and Chlorophyll -a (up to 160 ug/1) were aslo sampled
in the Pamlico and found to be the highest at the Washington Station. These
results are most likely caused by the algal blooms occurring in Kennedy Creek
l
Pamlico River 0 Washington 02084472
Mean CHL_a = 84.0 ug/l
Mean Biovolume = 7949 mm3/mm3
Mean Density = 27346 units/ml
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01/29/91 ver 3.1 T O 4 S R E V I E W
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Facility: City of Washington
NPDES Permit No.: NCO020648
Status (E, P, or M) : M
Permitted Flow: 2.1 mqd
Actual Averaqe Flow: 1.5 mgd
Subbasin: 1030307
Receiving Stream: Tar River I--------- PRETREATMENT DATA ------------- I---- EFLLUENT DATA ----
Stream Classification: C-NSW I ACTUAL PERMITTED[
7Q10: 120.0 cfs 1 Ind. + Ind. + I FREQUENCY I
II IWC: 2.67 % I Domestic PERMITTED Domestic I OBSERVED of Chronicl
Stn'd / Bkq I Removal Domestic Act.Ind. Total Industrial Total I Eflluent Criteria I
Pollutant AL Cone. I Eff. Load Load Load Load Load I Cone. Violationsl
(ug/1) (ug/1) I it (#/d) (#/d) (#/d) (#/d) (#/d) I (ug/1) (#vio/#aam)I
--------- ------------------ I -------- -------- -------- -------- --------- -------- I -------- ---- ----- I
Cadmium S 2.0 1 9211 0.0 0.0 0.03 0.0 0.039 I I
Chromium S 50.0 I 76* 0.6 0.0 0.56 0.7 1.230 1 I I
Copper AL 7.0 I 82% 0.7 0.0 0.69 0.4 1.040 I I N
Nickel S 88.0 I 321k 0.2 0.0 0.24 0.2 0.410 I ( P
Lead S 25.0 I 81% 0.6 0.0 0.56 0.1 0.646 1 I U
Zinc AL 50.0 I 774 2.0 0.1 2.02 0.4 2.370 1 I T
Cyanide S 5.0 I 59% 0.5 0.0 0.46 0.2 0.640 1 I
Mercury S 0.012 I Olt I I S
Silver AL 0.06 I 94% 0.1 0.0 0.06 0.0 0.094 I I E
Selenium S 5.00 i 0% I ( C
Arsenic S 50.00 I 0lk I I T
Phenols S NA I Olt ( I I
NH3-N C ( 0P6 I I 0
T.R.Chlor.AL 17.0 I 0% I 3,000.0 ( N
I
I I I
(------*- ------ ALLOWABLE PRDCT'D PRDCT'D PRDCT'D--------- MONITOR/LIMIT --------- I--ADTN'L RECMMDTN'S-- I
I l! Effluent Effluent Effluent Instream I Recomm'd I
1 Cone. using using Cone. Based on Based on Based on I FREQUENCY INSTREAM I
I Allowable CHRONIC ACTUAL PERMIT using ACTUAL PERMITTED OBSERVED I Eff. Mon. Monitor. I
Pollutant I Load Criteria Influent Influent OBSERVED Influent Influent Effluent I based on Recomm'd 2 I
I (#/d) (ug/1) (ug/1) (ug/1) (ug/1) Loading Loading Data I OBSERVED (YES/NO)
--------- -- I-------------------------------------------------------------------I----------------- I
Cadmium S I 16.49 75.037 0.195 0.247 0.00 I I A
Chromium S kll 137.40 1875.928 10.721 23.397 0.00 Monitor I I N
Copper AL W I 25.65 262.630 9.888 14.837 0.00 Monitor Monitor ( I A
Nickel S ( 85.35 3301.634 13.070 22.098 0.00 I I L
Lead S 1 06.78 937.964 8.495 9.728 0.00 Monitor 1 I Y
Zinc AL I 143.37 1875.928 36.879 43.204 0.00 Monitor Monitor 1 I S
Cyanide S I 6.04 187.593 14.981 20.798 0.00 Monitor Limit - I I I
Mercury S I 0.01 0.450 0.000 0.000 0.00 I I S
Silver AL I 0.66 2.251 0.289 0.447 0.00 Monitor Monitor I
�I
Selenium S ( 3.30 187.593 0.000 0.000 0.00 I I R
Arsenic S I 32.98 1875.928 0.000 0.000 0.00 I I E
Phenols S ( 0.000 0.000 0.000 0.00 I I S
NH3-N C I 0.000 0.00 I I U
T.R.Chlor.AL I 637.816 79.96 Limit I NCAC YES I L
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RECEIVED
s
1992
State of North Carolina
Department of Environment, Health, and Natu, I Resources--` 'Y w4*w*
Division of Environmental Management '�
512 North Salisbury Street •Raleigh, North Carolina 27604
James G. Martin Gov r e nor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
January 21, 1992
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
The Honorable Floyd G. Brothers, Mayor
City of Washington
102 East Second Street
Washington, NC 27889
Dear Mayor Brothers:
Subject: NPDES Permit No. NCO020648
City of Washington WWTP
Beaufort County
Your application for a NPDES permit modification to discharge 2.5 MGD of treated
wastewater into Kennedy Creek from a wastewater treatment facility located in Washington was
received on July 15, 1991. Our Washington Regional Office has performed a site investigation,
and the Division has completed its review of the permit application.
Or u review has determined that the receiving stream designated b i g g y you has no natural
flow on at lea�t seven (7) consecutive days during a ten (10) year period and at least thirty (30)
consecutive days during a two (2) year period. We refer to this stream as having zero 7Q10 and
30Q2 flow. Title 15A of the North Carolina Administrative Code, 2B .0206 (d) (2), specifically
prohibits new'or expanded discharges under such flow conditions. The plant discharges into a
tidally influenced area where there is no freshwater influence. Instream dissolved oxygen levels
below the stream standard have been recorded, as well as algal blooms during the summers of
1987, 1988, and 1991. Elevated nutrient and chlorophyll a levels have also been recorded.
After, thirty (30) days from receipt of this letter, this Division will send your permit
application to ,public notice stating our intent to deny your application for a NPDES permit
modification unless:
1. You withdraw your request for an NPDES permit. The City should investigate
alternatives to discharging into Kennedy Creek such as the Tar River.
2. You state your intention to demonstrate that the zero flow estimate is in error, and
you can demonstrate that improvements in treatment can prevent further water
quality violations from occurring. Demonstrating that the flow estimate is ih error
can be attempted using the attached procedure for projecting flows at ungauged
sites, while addressing the water quality issues will require extensive field and
modeling studies which can be discussed further with staff should you decide to
pursue this alternative.
Pollution Prevention nays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

If you wish to withdraw your request for a NPDES permit modification, you may do so by
stating that desire in a letter to our office. Your letter mast be received by our office within thirty
(30) days of your receipt of this letter.
If you have any questions on this permit application, please contact Mr. Dale Overcash of my
staff at telephone number 9191733-5083.
George T.
cc: Washington Regional Office
Technical, Support Branch
Permits and Engineering Unit
Permit File

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NC0020648
PERNIITTEE NAME: The City of Washington
FACILITY NAME: Washington WWTP
Facility Status: Existing
Permit Status: Modification
Major Minor
Pipe No.: 001
Design Capacity:
2.5 MGD
Domestic (% of Flow):
Industrial (% of Flow):
Comments:
96.2 %
RECEIVING STREAM: Kennedy Creek
Class: C-NSW
Sub -Basin: 03-03-07
Reference USGS Quad: E 30 SE (please attach)
County: Beaufort
Regional Office: Washington Regional Office
Previous Exp. Date: 3/31/95 Treatment Plant Class: IV
Classification changes within three miles:
rLUI
Requested by: Rosanne Barona Date: 10/8/91
Prepared by: Date:
Reviewed by: e. Date: /a. 1U 5
AIA —
Modeler
Date Rec.T
#
spfi66
to a
4
t35
Drainage Arrea�mil) 1.6 Avg. Streamflow (cfs):
7Q10 (cfs) () Winter 7Q10 (cfs) O 30Q2 (cfs)
Toxicity Limits. IWC % Acute/Chronic
Instream Monitoring:
Parameters
Upstream
I e .romil
Downstream Location
Effluent
Characteristics
Summer
Winter
BOD5 (mg/1)
NH3-N (mg/1)
Y15/
Qv 7L
D.O. (mg/1)
CC Ui sd
TSS (mg/1)
a QJ
F. Col. (/100 ml)
(A
pH (SU)
w�
�Q
II
'H aO/6i 7i
M D
,'O- 6Y7
f
UO d 2
a c
re coed ;n
aw On
lot&u)
TCC.i'I�tACJ
Abw-, l5tu�
©u
�l d 6d
i trM
Comments:
fin 1 chi
Vl a. 7e Vle
vt

RECE
tVASH NG Oy OFFICE
FACT SHEET FOR WASTELOAD ALLOCATION
OR () 2 1991
Facility Name:
City of Washinton W WTP
Request # 6485
n' L k
NPDES No.:
NCO020648
Type of Waste:
96.2% Domestic & 3.8% Industrial
-'
Facility Status:
Existing
Permit Status:
Modification
Receiving Stream:
Kennedy Creek
Stream Classification:
C-NSW
Subbasin:
030307
County:
Beaufort
Stream Characteristic:
Regional Office:
WaRO
USGS #
Requestor:
Rosanne Bamna
Date:
Date of Request:
10/9/91
Drainage Area (mi2):
<1.0
Topo Quad:
E30SE
Summer 7Q10 (cfs):
0
Winter 7Q10 (cfs):
0
Average Flow (cfs):
30Q2 (cfs):
0
IWC (%):
100
Wasteload Allocation Summary LA d,
(approach taken, correspondence with region, EPA, etc. $
Request for expansion from 2.12 MGD to 2.5 MGD ' erred. Facility discharges into a
tidally influenced area where there is no freshwater influence (i.e. 7Q10=0 & 30Q2=0). _ s L.—IJ Q�
In addition to the zero flow procedure, this modification request -is Teme3based on recorded
instream D.O. levels below the standard upstream and downstream of the discharge; and algal
bloom reports during the summers of 1987, 1988, and 1991 which also include reports of elevated
nutrient and chlorophyl a levels.
Special Schedule Requirements and additional comments from Reviewers:
7
Recommended by:
Reviewed by
Instream Assessment:
t`* Regional Supervisor:
Permits & Engineerin
DEC 2 b 13
RETURN TO TECHNICAL SERVICES BY:
N)

CONVENTIONAL PARAMETERS
Existing Limits
Monthly Average
Monthly Average
Summer
Winter
Wasteflow (MGD):
2.12
2.12
2.12
BOD5 (mg/1):
15
5
10
NH3N (mg/1):
4
1
1.8
DO (mg/1):
5
6
6
TSS (mg/1):
30
30
30
Fecal Col. (/100 ml):
200
200
200
pH (SU):
6-9
6-9
6-9
Residual Chlorine (µg/1):
monitor
monitor
monitor
Oil & Grease (mg/1):
TP (mg4):
monitor
2.0
2.0
IN (mg/1):
monitor
4.0
8.0
TOXICS/METALS
Type of Toxicity Test: Chronic pass/fail
Existing Limit: at 99% effluent
Monitoring Schedule: quarterly
Existing Limits
Daily Max.
WQ or EL
Cadmium (ug/1):
2.0
WQ
Chromium (ug/1):
50.0
WQ
Copper (ug/1):
monitor
Nickel(ug4):
88.0
WQ
Lead (ug/1):
25.0
WQ
Zinc (ug/1):
monitor
Cyanide (ug/1):
5.0
WQ
Phenols (ug/1):
Mercury (ugft
Silver (upA):
monitor
WQ
WQ
WQ
_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.
e
No parameters are water quality limited, but this discharge may affect future allocations.

INSTREAM MONrFORING REQUIREMENTS
Upstream Location: above discharge on Kennedy Creek
Downstream Location: 1- below outfall at mouth of Kennedy Creek
2- on Pamlico River @ HWY 17
Parameters:
Special instream monitoring locations or monitoring frequencies:
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Facility is currenly required (through most recent permit issued) to submit an engineering report showriivJ nc
alternative to surface water discharge.
Wasteload sent to EPA? (Major) -td- (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? M (Y or N) If yes, explain with attachments.

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street - Raleigh, North Carolina 27604
James G. Martin; Governor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
November 4, 1991
Mr. John C. Hall
Kilpatrick & Cody
Suite 800
700 Thirteenth Street, NW
Washington, D.C. 20005
Subject: Local' nutrient limits application to City of Washington, NC
Dear Mr. Hall:,,
Enclosed please find information that you requested regarding documentation of eutrophication in
Kennedy Creek, the receiving waters for the City of Washington's wastewater discharge. The
materials enclosed relate to "Bloom Reports" collected by the Division. In recent years when algae
blooms have been reported to the Division by the general public, DEM has attempted to sample those
areas so that the magnitudes of problems can be tracked and trends within basins can be detected for
subsequent management action. Kennedy Creek is a waterbody where DEM's own biologists and
regional staff have witnessed localized blooms occurring periodically for several years. Thus, the
attached information -- although conclusive by itself -- is only a partial record of the problems
witnessed in Kennedy Creek.
With regard to your question as to whether the blooms in Kennedy Creek were extensions of
blooms also occurring in the Tar River below, DEM staff have said that during their visits to sample
the blooms the jeffected area was restricted to Kennedy Creek. Thus, as you will note in the reports,
sampling was restricted to Kennedy Creek.
Also, you seemed to indicate that the City of Washington appeared surprised by DEM's recent
permit action. As I mentioned to you, the Division had been discussing these issues with the City
for a considerable length of time. Our records indicate that we met with the City and their consultant
in July, 1990 and again in March, 1991. At both of these meetings, the issues surrounding
eutrophication in Kennedy Creek were discussed and the City was provided speculative limits
including nutrient requirements. It was also stated that since the receiving waters had no flow under
7Q10 or 30Q2 conditions, the City would not be allowed to expand their discharge in its current
location under Current NC regulations. Therefore, the Division recommended that the City relocate
its discharge to 1 address both existing and future problems associated with a discharge to Kennedy
Creek, and the NPDES permit conditions were established to reflect these recommendations (i.e. a
schedule for nutrient limits if outfall remained in Kennedy Creek; monitoring only if the discharge
was relocated to the Tar River pending the outcome of the NSW study).
Pollution Prevention Pays
P.O. Box 29535, Raleigh; North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

- page 2 -
As you know, the Tar -Pamlico Basin NSW strategy specifically states that localized
eutrophication conditions will be handled on a case -by -case basis and not necessarily fall under the
agreement applying to point source/non-point source nutrient trading. This exception was
purposefully placed in the strategy to address situations like Kennedy Creek where only specific
controls or elimination of point sources will address the localized problems.
I hope that this information is useful to you in advising the Tar Basin Association and the City of
Washington. Please let me know if I can be of further assistance to you in this matter.
Sincer y,
J. T evor Clements, Asst. Chief
at r Quality Section
Attachments
cc: Jim Mulligan
Malcom Green
I
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

October 31, 1991
MEMORANDUM
To: Trevor Clements
From: Betsy Johnson
Subject: Justification of local impacts in Kennedy Creek.
Localized impacts from nutrient loading have been documented in Kennedy
Creek. Nutrients are trapped in the creek due to winds, tides, and lack of upstream flow.
Though the City of Washington discharges less than 2 mg/I of phosphorus on average,
algal blooms proliferate.
Algal blooms have been sampled on three occassions, July 1987, September 1988
and July 1991. Bloom condi, ,ons, elevated nutrient and chlorophyll a levels were
recorded during each event. ach successive bloom an additional location was sampled.
In 1987, sampling was upstream of the outfall only. In 1988, samples were taken above
and below the outfall. In 1991, samples were taken at the outfall in addition to upstream
and downstream. Bloom conditions were present at all sites, with the highest biovolume
and density at the upstream site.
Samples have not been taken in the Tar -Pamlico River during a bloom in
Kennedy Creek. The Kennedy Creek blooms are confined to the creek and extend only
to the mouth.
Attachments

DIVISION OF ENVIRONMENTAL MANAGEMENT
October 16, 1991
MEMORANDUM
TO: Al Hodge, WARO
THROUGH: Trish MacPherson
FROM: I Karen Lynch k4
RE: Kennedy Creek Algal Blooms, Beaufort County
Kennedy Creek, a tributary to the Pamlico River, is tidally
influenced and rated as a 'no flow' creek. The city of Washington has
a wastewater treatment discharge into the creek and proposes to
increase its flow from 2.12 to 2.5 million gallons per day. Because
there is very little flushing in the creek and winds often push waters
upstream, phytoplankton populations are able to proliferate
throughout the creek utilizing available nutrients.
The following summarizes algal bloom samples collected from
Kennedy Creek. On July 24, 1991, green water and elevated
dissolved oxygen (D.O.) concentrations were found in the surface
waters of,� Kennedy Creek. The saturation values for Kennedy Creek
were over 200%. This high saturation rate is a- violation of the North
Carolina Administrative Code statute 15A.2B.0212(3)(D) which states
that 'total dissolved gasses should not be greater than 110% of
saturation.'
Nutrients, chlorophyll -a and phytoplankton were collected at
three sites i on Kennedy Creek because of a suspected algal bloom.
The map (;included illustrates the three stations with #1 above the
wastewater treatment plant, #2 at the wastewater treatment outfall
and #3 at the mouth of Kennedy Creek.
Algal" bloom conditions were present at all three sites with
elevated biovolume and density estimates listed on Table 1.
Typically,!,' phytoplankton numbers are considered elevated or at
bloom levels when biovolume is greater than 5,000 mm3/m3 or
density is higher than 10,000 units/ml. Algal densities from stations
1 and 2 were sixteen times the level set for algal blooms.
Phytoplankton communities were dominated at all three stations by
small cyanophytes or blue-green algae (Synechococcus species) and

diatoms (Cvclotella species 3). Station #1 also contained an
abundance of an xanthophyte or yellow -green algae, O l i s th o d i s c u s
carterae, which has been found in Kennedy Creek in prior blooms
This species has been associated with high chlorophyll -a levels.
Elevated chlorophyll -a concentrations approaching or greater
than the state standard of 40 ug/1 (Table 1) also signified bloom
conditions on July 24. Nutrient concentrations were elevated,
particularly at the uppermost two stations, even in the presence of
such high algal growth.
Water quality samples were collected the following day on July
25. Chlorophyll -a and nutrient concentrations, particularly levels of
total phosphorus were again high. Stations 1 and 3 exceeded the
state standard for chlorophyll -a with concentrations measuring 58
ug/1 at both stations. Due to time constraints, only algal sample #2
was quantitatively counted. This sample contained similar species
composition as the previous day along with an elevated
phytoplankton density estimate.
Similar algal blooms were reported from Kennedy Creek in 1987
and 1988 with corresponding chlorophyll -a values ranging from 64
to 200 u9/1. The phytoplankton, nutrient and chlorophyll -a data
from these blooms is presented in Table 1. Station A is roughly the
same as station #1 while Station B is equivalent to #3.
Algal bloom levels of phytoplankton are likely to continue, in the
presence �ilof such high nutrients unless nutrient concentrations are
decrease .
cc: Kevin Miller, WARO
Bexsy Johnson
Dianne Reid
Jimmie Overton
�i
i',

TABLE 1. PHYTOPLANKTON, NUTRIENT AND CHLOROPHYLL•a RESULTS FROM KENNEDY CREEK
BIOVOLUME
DENSITY
CHL-A
TOTAL
TOTAL
NITROGEN
PHOSPHO
STATION
DATE
mm3/m3
units/ml
u /I
m /I
m /I
------------------------------------------ — -------------------
-----------
KENNEDY-1
910724
26283
162808
64
1
0.34
KENNEDY-2
910724
1171
162808
37
1.06
0.4
KENNEDY-3
910724
3252
39829
34
0.6
0.16
KENNEDY-1
910725
NOT COUNTED
58
0.9
0.39
KENNEDY-2
910725
3553 66730
27
1.49
0.41
KENNEDY3
910725
NOT COUNTED
58
0.61
0.24
KENNEDY-A
880907
3868
12097
91
2.06
0.23
KENNEDY-B
880907
7377
23233
120
2.15
0.25
KENNEDY-A
880923
2529
22797
64
0.72
0.025
KENNEDY-B
880923
7203
37034
64
0.84
0.029
KENNEDY.A
870730
19548
289980
200
1.6
0.27
gENNEDY CREEK AT.GAL BLOOMS; DULY 1991
BEAUFORT COUNTY `
•� 3fi'
Xr
RE
jj
AHubbard(C� , WASHINGTON'S WWTP DISCHARGE.:•
�. pu
o DaYb["
71 1-1
T. 2
o DaYbeaconso Pile -'
0
Piling
JSlumps ° %z'Coas'(C)^....
`
..
Piling �•/ i
a r 4... L� . b
Mi.."k

KENNEDY CREEK, BEAUFORT CO.
Sampled by C. Tyndall, R. Bland 88091500
880923 1400
Water quality samples were collected from Kennedy Creek
because of elevated pH and dissolved oxygen readings. The water also
appeared greenish. On September 7th, northeast winds backed up
water in Kennedy Creek. These samples collected upstream (KC-1)
and downstream (KC-2) of the Waste Water Treatment Plant
contained "bloom" levels of phytoplankton. Olisthodiscus carterae, an
xanthophyte, often associated with high chlorophyll -a levels,
comprised over 66 percent of the biovolumes in these samples.
Corresponding chlorophyll -a levels of 91 and 120 99/1 (respectively)
further supported bloom conditions. The algae were responding to the
high levels of total nitrogen (2.06 mg/l & 2.15 mg/1) and total
phosphorus (0.23 mg/l & 0.25 mg/1) present in early September.
Samples collected near the end of the month contained high
densities of Cyclotella species 3, a small to medium sized centric
diatom, and cryptophytes.
High total phosphorus concentrations were still present on
September 23rd. Excessive chlorophyll -a concentrations of 64 µg/l
were recorded at both stations, indicating bloom.. conditions.
DOMINANT SPECIES BY BIOVOLUME
KC-1 SPECIES
880907
nI ISTHODISCUS C'ARTERAE
C'RYPTOMONAS EROSA REFLEXA
CRYPTOMONASOVATA
TOTAL BIOVOLUME = 3,868 mm3/m
DOMINANT SPECIES BY DENSITY
SPECIES
nI ISTHODISCUS CARTERAE
OCHROMONAS SPECIES 3
CHROOMONAS MNUfA
TOTAL DENSITY = 12,097 units/ml.
CLASS BIOV. % BIOV.
XAN
2,542
66
CRY
433
11
CRY
415
11
CLASS DENS. % DENSITY
XAN
4,717
39
CHIC
1,965
16
CRY
1,179
10
I■

DOMINANT SPECIES BY BIOVOLUME
KC-2 SPECIES CLASS BIOV. % BIOV.
880907
OLISTHODISCI JS CARTERAE XAN 6,214 84
TOTAL BIOVOLUME = 7,377 mm3/m3
DOMINANT SPECIES BY DENSITY
SPECIES
CLASS
DENS.
% DENSITY
OLISTHODISCUS CARTERAE
XAN
11,529
50
CHROOMONAS MDWA
CRY
2,533
11
OCHROMONAS SPECIES 3
CHR
2,533
11
CYCLOTELLA SPECIES 2
BAC
2,184
9
TOTAL DENSITY = 23,233 units/ml.
DOMINANT SPECIES BY BIOVOLUME
KC-1 SPECIES
CLASS
BIOV.
%BIOV.
880923
CYCLOTELLA SPECIES 3
BAC
1,123
44
CRYPTOMONAS ERO A
C'RY
323
13
CRYPTOMONAS EROSA REFLEXA
CRY
216
9
CHROOMONAS CAUDATA
CRY
208
8
TOTAL BIOVOLUME = 3,868 mm3/m3
DOMINANT SPECIES BY DENSITY
SPECIES
CLASS
DENS.
% DENSITY
CYCLOTELLA SPECIES 3
BAC
11,364
59
CYCLOTELLA SPECIES 2
fl
BAC
3,232
14
TOTAL DENSITY = 22,797 units/mi.
DOMINANT SPECIES BY BIOVOLUME
KC-2 SPECIES
CLASS
BIOV.
% BIOV.
880923
CRYPTOMONAS ERO A REFLEXA
CRY
2,595
36
CYCLOTELLA SPECIES 3
BAC
1,981
28
CRYPTOMONAS OVATA
CRY
664
9
TOTAL BIOVOLUME = 7,203 mm3/m3
w

DOMINANT SPECIES BY DENSITY
SPECIES
• � 1
P••v• y�l
TOTAL DENSITY = 37,034 units/ml.
CLASS DENS. % DENSITY
BAC 23,583 61
CRY 3,144 8
-87-

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10/22/91 ver 3.1
Facility:
NPDES Permit No.:
Status (E, P, or M):
Permitted Flow:
Actual Average Flow:
Subbasin:
Receiving Stream:
Stream Classification:
7010:
IWC:
Stn'd / Bkg
Pollutant AL Cone.
(ug/1) (ug/1)
Cadmium S
Chromium S
Copper AL
Nickel S
Lead S
Zinc Al
Cyanide S
Mercury S
Silver AL
Selenium S
Arsenic S
Phenols S
NH3-N C
T.R.Chlor.AL
Pollutant
Cadmium S
Chromium S
Copper AL
Nickel S
Lead S
Zinc AL
Cyanide S
Mercury S
Silver AL
Selenium S
Arsenic S
Phenols S
NH3-N C
T.R.Chlor.AL
2.0
50.0
7.0
88.0
25.0
50.0
5.0
0.012
0.06
5.00
50.00
NA
17.0
WASHINGTON WWTP
NCO020648
M
2.5 mgd
1.5 mgd
'030307
KENNEDY CREEK
C-NSW
0.0 of$
100.00 t
Removal Domestic
Eff. Load
4 (4/d)
924 0.0
764 0.6
82% 1.0
32% 0.2
81% 0.6
77% 2.0
59% 0.5
0%
94% 0.1
06
05
0%
06
0%
------------ ALLOWABLE PRDCT'D
Effluent Effluent
Cone. using
Allowable CHRONIC ACTUAL
Load Criteria Influent
(4/d) (ug/1) (ug/1)
0.32
2.000
0.190
2.68
50.000
11.110
0.50
7.000
14.674
1.66
88.000
12.921
1.69
25.000
8.319
2.79
50.000
37.480
0.16
5.000
14.759
0.00
0.012
0.000
0.01
0.060
0.283
0.06
5.000
0.000
0.64
50.000
0.000
0.000
0.000
0.000
17.000
T 0% I C S R E V I E W
I -------- PRETREATMENT DATA -------------- I ---- EFLLUENT DATA---- I
ACTUAL
PERMITTEDI
I
Ind. +
Ind. + I
FREQUENCY I
I
Domestic
PERMITTED
Domestic I
OBSERVED
of Chronicl
ACC.Ind.
Total
Industrial
Total I
Eflluent
Criteria I
Load
Load
Load
Load I
Cone.
Violations]
(i/d)
--------
(4/d)
--------
(4/d)
(4/d) I
(ug/1)
-------
(4vio/43am)]
0.0
0.03
---------
0.0
-------- I
0.051 1
--------- I
1
0.0
0.59
0.7
1.294 1
1 1
0.0
1.05
0.4
1.466 1
1 N
0.0
0.24
0.3
0.519 1
7.0
1 P
0.0
0.56
0.1
0.646 1
4.0
I U
0.1
2.09
0.4
2.358 1
46.0
I T
0.0
0.46
0.2
0.654 1
11
1
I
I S
0.0
0.06
0.0
0.104 1
I E
I C
IT
I
I
ID
I
I N
I
PRDCT'D
PRDCT'D
I
I
--------- MONITOR/LIMIT ---------
I
I
1--ADTN'L RECIMDTN'S--
Effluent
Instream
I Recomm'd
using
Cone.
Based on
Based on
Based on
I FREQUENCY INSTREAM I
PERMIT
using
ACTUAL
PERMITTED
OBSERVED
I EPf. Mon. Monitor. I
Influent
OBSERVED
Influent
Influent
Effluent
I based on Recomm'd 2 I
(ug/1)
(ug/1)
Loading
Loading
Data
---------I
I OBSERVED (YES/NO) I
------- -------- I
---- --
0.316
--------
0.00
--------
Monitor
--------
Limit
I I A
24.164
0.00
Limit
Limit
I I N
20.538
0.00
Monitor
Monitor
I I A
27.446
7.00
Limit
Limit
Monitor
I NCAC NO I L
9.551
4.00
Limit
Limit
Limit
I NCAC NO I Y
42.192
40.00
Monitor
Monitor
Monitor
I Monthly YES I S
20.874
0.00
Limit
Limit
I NCAC NO I I
0.000
0.00
I S
0.486
0.00
Monitor
Monitor
I I
0.000
0.00
] I R
0.000
0.00
I I E
0.000
0.00
I S
0.00
I 1 U
0.00
Limit
I I L
I I T
I S

Pamlico River at Washington
Sampled by D. Denton
Waterfront, Beaufort County
900718 1615
An algal sample was collected from the Pamlico River on the
waterfront in Washington in response to a citizen's complaint.
Greenish colored water was observed along with elevated surface DO
(12.0 mg/1) and pH (8.4) levels. The sample contained a blue-green
bloom of Merismol2edia tenuissima, a colonial plate -forming algae
that often tints the water a greenish color. The plates of cells were in
the process of disintegrating, and therefore were not quantitatively
countable. M. tenuissima is commonly found in the plankton of fresh
and brackish water.
The excessive chlorophyll -a concentration of 50 ug/l confirmed
algal bloom conditions on the Washington waterfront.
Pamlico River, Beaufort County
Sampled by K. Miller, L. Tison 900724 1125-1540
On July 24, five algal bloom samples were collected from Ragged
Point to downstream at Bayview, in response to a fish kill. Dead
menhaden, flounder, hog chokers, and spot were observed and were
most concentrated around Hawkins Landing on the northern shore of
the river.
Supersaturated surface DO measurements were found at most of
the five sampling sites. Salinity and DO data illustrated the presence
of a salt wedge at stations 4B and 7D with nearly anoxic conditions
and higher salinity concentrations on the river bottom.
All five samples contained elevated phytoplankton growth and
were considered to be algal blooms with the highest concentrations
at Bayview (10E) and Hawkins Landing (2A). Dinoflagellates such as
Peridinium trochoideum, Gymnodinium aurantium, Gyrodinium
uncatenum and small filamentous cyanophytes, Phormidium
angustissima dominated the samples.
Elevations in chlorophyll -a and total phosphorus concentrations
were found in all samples.

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