NC0037508_NPDES Permit Draft_20100901

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 1, 2010
Mr. Dennis Brobst
Moore County Public Works Director
P.O. Box 1927
Carthage, North Carolina 28327-1927
Subject: Draft of Renewal and Modification to
NPDES Permit NC0037508
Moore County Water Pollution Control
Plant Expansion
Moore County
Dear Mr. Brobst:
Pursuant to your recent request, enclosed is a copy of the draft NPDES permit renewal
and modification for your facility. I encourage you to review the draft carefully to ensure
thorough understanding of the information, conditions, and requirements it contains.
This permit modification has the following differences from your current permit:
➢ The Supplement to the Permit Cover Sheet has been revised to include the
equipment and processes used for wastewater treatment.
➢ The TRC footnote has been changed on A.(1) - 6.7 MGD. Because there are
interferences sometimes in measuring low levels of TRC in wastewater, The Division
accepts any analysis reported by a certified laboratory of less than 50 ug/ L to be in
compliance with the permit limit.
➢ The mercury limits on A.(1) have been changed to 24.1 ng/ L as a monthly average
and a daily maximum in keeping with EPA requirements.
➢ A new Special Condition A.(2) and A.(5) for 10.0 MGD were created and added to the
permit based on the speculative limits letter dated January 12, 1999 and reaffirmed
on October, 2006. Monitoring frequencies for a Grade IV classified facility are used.
A new mercury limit of 20.1 ng/ L at 10.0 MGD discharge, 7Q1OS flow of 15.2 cfs,
and a background mercury concentration of 3.72 ng/ L was set as a monthly
average and a daily max in accordance with EPA requirements. The background
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity Affirmative Action Employer
0ne
NorthCarolina
Naturally

mercury data is from 2005, and is 5 years old. During the coming permit cycle, the
facility shall have a minimum of 12 upstream samples analyzed using Low Level
Method 1631E and submit the results with the next permit renewal application.
Concurrent with this notification, the Division is sending the draft to EPA Region 4 in
Atlanta and in-house agencies for review, and to newspapers having general circulation in the
Moore County area. Please provide any comments you may have regarding this draft to DENR
- DWQ, NPDES Unit no later than 30 days after receiving this draft permit.
Following the 30-day comment period, the Division will review all pertinent comments
and take appropriate action prior to issuing a final permit. If you have questions or comments
concerning the draft permit for your facility, please call me at [phone], or you may e-
mail me at [e-mail].
If no adverse comments are received, this permit will likely be issued in October, with
an effective date of December 1, 2010.
Sincerely,
Jim McKay
Complex NPDES Permitting
cc: Fayetteville Regional Office/ Attn: Belinda Henson - via. email with fact sheet
NPDES File
Technical Assistance & Certification Unit Attn: Mr. Steve Reid - via. email with fact sheet
Aquatic Toxicology Attn: Susan Meadows - via. email with fact sheet
Dana Foley - via. email with fact sheet and RPA
EPA Region IV. Attachment: Application, Fact Sheet and RPA
Hobbs, Upchurch & Associates, P.A./ 8262 Market Street, Suite 201/ Wilmington, NC 28411/ Attn:
Mr. Barry King, P.E.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity \ Affirmative Action Employer
North Carolina
Natural!,

NPDES Permit No. NC0037508
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY,
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Moore County
is hereby authorized to discharge treated wastewater from an outfall located at the
Moore County Water Pollution Control Plant
1094 Addor Road
Moore County
to receiving waters designated as Aberdeen Creek located within the Lumber River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective .
This permit and authorization to discharge shall expire at midnight on July 31, 2014.
Signed this day .
DRAFT
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

NPDES Permit No. NC0037508
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this
issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate
and discharge from this facility arises under the permit conditions, requirements, terms, and provisions described herein.
Moore County
is hereby authorized:
1. to continue discharging 6.7 MGD of domestic and industrial wastewater from the existing
wastewater treatment facility consisting of activated sludge wastewater treatment facilities. The
treatment system utilizes:
• pre -aeration
• grit removal
• primary clarification
• first -stage activated sludge
• intermediate clarification
• second -stage aeration
• final clarification
• anaerobic sludge digestion
• sludge drying beds
• post -aeration
• and, two back up generators
located at the Moore County Water Pollution Control Plant, 1094 Addor Road, Moore County,
and
2. After receiving an Authorization to Construct from the Division, to construct, and after submitting
an Engineer's Certification, to operate a 10.0 MGD Water Pollution Control Plant having a third
processing train similar to the two existing treatment units and with tertiary filtration added.
3. To discharge from said treatment facility through Outfall 001 at a specified location (see attached
map) into Aberdeen Creek, a waterbody classified as C waters within the Lumber River Basin.

NPDES Permit No. NC0037508
Moore County WWTP
and Dischlu. ge Line
(proximate Location)
• Outfall 001
(flows south)
Downstream M onitoring Point
(at ITCSR 1225)
Aloore County WAVTP
Receivint St:mane kb eitieenCieek DraistageBasin. : Lund er Rive
Latitude: 3504' 03"11 Lesatitude: 79.28'08"W
W.-Basin: 03-07- 'SO Permitted f bw: 6,7 1.1G1)
State Grid / USCS Ctuad: G 215W1Pilvab lufg 14.C. Stream Claes: C
IsTPDES Permit NC0037508
Moore County

NPDES Permit No. NC0037508
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, or expansion above 6.7
MGD, the Permittee is authorized to discharge treated wastewater through Outfall 001. Such discharges shall be
limited and monitored by the Permittee as specified below:
PARAMETERS _.
Flow (MGD)
BOD, 5 day, 20°C
(April 1 — October 31) 2
EFFLUENT LIMITS''
MONITORING REQUIREMENTS
Monthly '
Average ' 4
6.7
22.0 mg/L
33.0 mg/L
Daily
Maximum
Measureme
nt
Frequency
Continuous
Daily
Sample
e
Recording
Composite
Sample
Location1
I or E
I, E
BOD, 5 day, 20°C
(Nov. 1 — March 31) 2
30.0 mg/L
45.0 mg/L
Daily
Composite
I, E
Total Suspended Solids
(TSS) 2
30.0 mg/L
45.0 mg/L
Daily
Composite
I, E
NH3 as N
(April 1 — October 31)
2.1 mg/L
6.3 mg/L
Daily
Composite
NH3 as N
(Nov. 1 — March 31)
6.2 mg/L
18.6 mg/L
Daily
Composite
Fecal Coliform
(geometric mean)
200 / 100 m1
400 / 100 m1
Daily
Grab
Total Residual Chlorine
(TRC) 3
28 µg/L
Daily
Grab
Dissolved Oxygen
Daily average > 5.0 mg/L
Daily
Grab
Temperature (°C)
Daily
Grab
Conductivity
Daily
Grab
pH
> 6.0 and < 9.0 standard units
Daily
Grab
Total Phosphorus
Monthly
Composite
Total Nitrogen (NO2-
N + NO3-N + TKN)
Monthly
Composite
Total Copper
2/Monthly
Composite
Total Zinc
2/Monthly
Composite
Total Silver
2/Monthly
Composite
Total Mercury 4
24.1 ng/L 4
24.1 ng/L 4
Weekly
Grab
Chronic Toxicity 5
Quarterly
Composite
Temperature, °C
Variable 6
Grab
U, D
Dissolved Oxygen
Variable 6
Grab
U, D

NPDES Permit No. NC0037508
Table Footnotes:
1. Sample Locations: E — Effluent; I — Influent; U — approximately 100 feet Upstream of the
outfall; D — Downstream at NCSR 1225.
2. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not
exceed 15 % of the respective influent value (i.e., 85% removal is required).
3. Total Residual Chlorine (TRC) shall be monitored only if chlorine is used to disinfect. The Division
shall consider all effluent TRC values reported below 50 ug/1 to be in compliance with the permit. However, the
Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory
(including field certified), even if these values fall below 50 ug/1.
4. Mercury [see Special Condition A. (3.)]. To facilitate the Lumber River's Phase II TMDL
process for mercury, the Permittee shall report mercury using clean -sample collection
criteria/test methods established by EPA Method 1631.
5. Chronic Toxicity (Ceriodaphnia) at 41 %; quarterly during March, June, September,
December; See Special Condition A. (4.)
6. Variable: instream samples shall be collected upstream and downstream 3/week during the
summer months of June, July, August, and September; samples shall be collected weekly
during the rest of the year.
Units:
mg/L = milligrams per liter
ng/L = nanograms per liter
NH3 as N = ammonia as nitrogen
BOD = biochemical oxygen demand
µg/L = micrograms per liter
lbs/Day = pounds per day
ml = milliliter
This permit is subject to additional annual sampling
[See Special Condition A. (6.)].
Effluent shall contain no floating solids or foam visible in other than trace amounts.

NPDES Permit No. NC0037508
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on submittal of an Engineer's Certificate and lasting until expiration, the Permittee is
authorized to discharge treated wastewater through Outfall 001. Such discharges shall be limited and monitored by
the Permittee as specified below:
PARAMETERS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Locationl-
Flow (MGD)
10.0
Continuous
Recording
I or E
BOD, 5 day, 20°C
(April 1 — October 31) 2
5.0 mg/L
7.5 mg/L
Daily
Composite
I, E
BOD, 5 day, 20°C
(Nov. 1 — March 31) 2
10.0 mg/L
15.0 mg/L
Daily
Composite
I, E
Total Suspended Solids
(TSS) 2
30.0 mg/L
45.0 mg/L I
Daily
Composite
I, E
NH3 as N
(April 1 — October 31)
1.0 mg/L
3.0 mg/L
Daily
Composite
E
NH3 as N
(Nov. 1 — March 31)
2.0 mg/L
6.0 mg/L
Daily
Composite
E
Fecal Coliform
(geometric mean)
200 / 100 ml
400 / 100 ml
Daily
Grab
E
Total Residual Chlorine
(TRC) 3
28 µg/L
Daily
Grab
E
Dissolved Oxygen
Daily average > 6.0 mg/L
Daily
Grab
E
Temperature (°C)
Daily
Grab
E
Conductivity
Daily
Grab
E
pH
> 6.0 and < 9.0 standard units
Daily
Grab
E
Total Phosphorus
Monthly
Composite
E
Total Nitrogen (NO2-
N+NO3-N+TKN)
Monthly
Composite
E
Total Copper
2/Month
Composite
E
Total Zinc
2/Month
Composite
E
Total Silver
2/Month
Composite
E
Total Mercury 4
20.1 ng/L 4
20.1 ng/L 4
Weekly
Grab
E
Chronic Toxicity 5
Quarterly
Composite
E
Temperature, °C
Variable 6
Grab
U, D
Dissolved Oxygen
Variable 6
Grab
U, D

Permit NC0037508
Table Footnotes:
1. Sample Locations: E — Effluent; I — Influent; U — approximately 100 feet
Upstream of the outfall; D —Downstream at NCSR 1225.
2. The monthly average effluent BOD5 and Total Suspended Solids
concentrations shall not exceed 15 % of the respective influent value (i.e., 85%
removal is required).
3. Total Residual Chlorine (TRC) shall be monitored only if chlorine is used to disinfect.
The Division shall consider all effluent TRC values reported below 50 ug/1 to be in compliance
with the permit. However, the Permittee shall continue to record and submit all values reported by
a North Carolina certified laboratory (including field certified), even if these values fall below 50
ug/1.
4. Mercury [see Special Condition A. (3.)]. Permittee shall report mercury using
clean -sample collection criteria/test methods established by EPA Method
1631E.
5. Chronic Toxicity (Ceriodaphnia) at 50 %; quarterly during March, June,
September, December; See Special Condition A. (5.)
6. Variable: instream samples shall be collected upstream and downstream
3/week during the summer months of June, July, August, and September;
samples shall be collected weekly during the rest of the year.
Units:
mg/L = milligrams per liter
ng/L = nanograms per liter
NH3 as N = ammonia as nitrogen
BOD = biochemical oxygen demand
µg/L = micrograms per liter
lbs/Day = pounds per day
ml = milliliter
This permit is subject to additional annual sampling
[See Special Condition A. (6.)].
Effluent shall contain no floating solids or foam visible in other than trace
amounts.

Permit NC0037508
A (3). MERCURY REOPENER.
The Division may re -open this permit to require mercury load limitations,
mercury minimization plans, source water characterization, or other measures
following completion of the Phase 2 Mercury TMDLs for the Lumber and
Waccamaw River watersheds.
A. (4.)CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 41 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of, March,
June, September, and December. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
If the test procedure, performed as the first test of any single quarter, results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months, as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of
the highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3
(original) is to be sent to the following address:
Attention:
Environmental Sciences Section
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after the end of the reporting period for which the report is made. Test data shall be
complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test

Permit NC0037508
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment areaof the form. The report shall be submitted to the
Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Should any test data from this monitoring
requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts
to the receiving stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document (such as minimum
control organism survival, minimum control organism reproduction, and/or appropriate
environmental controls) shall constitute an invalid test and will require immediate follow-up testing,
to be completed no later than the last day of the month following the month of initial monitoring.
A. (5.)CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 50 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of, March,
June, September, and December. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
If the test procedure, performed as the first test of any single quarter, results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months, as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of
the highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3
(original) is to be sent to the following address:
Attention:
Environmental Sciences Section
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621

Permit NC0037508
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after the end of the reporting period for which the report is made. Test data shall be
complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Should any test data from this monitoring
requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts
to the receiving stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document (such as minimum control
organism survival, minimum control organism reproduction, and/or appropriate environmental controls)
shall constitute an invalid test and will require immediate follow-up testing, to be completed no later than
the last day of the month following the month of initial monitoring.

Permit NC0037508
A. (6.) SPECIAL CONDITION -- EFFLUENT POLLUTANT SCAN
The permittee shall perform Effluent Pollutant Scans (in accordance with 40 CFR.Part 136). for all parameters
listed in the attached table. The Permittee shall sample approximately annually except to provide seasonal'
variation to include a minimum of four (4) scans. Unless otherwise indicated, metals shall be analyzed as "total
recoverable."
Ammonia (as N)
Trans-1,2-dichloroethylene
Bis (2-chloroethyl) ether
Chlorine, total residual (TRC)
1,1-dichloroethylene
Bis (2-chloroisopropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite
1,3-dichloropropylene
4-bromophenyl phenyl ether
Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Phosphorus
Methyl chloride
4-chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
Antimony
1,1,2,2-tetrachloroethane
Tetrachloroethylene
Di-n-butyl phthalate
Di-n-octyl phthalate
Arsenic
Toluene
Dibenzo(a,h)anthracene
Beryllium
1,1,1-trichloroethane
1,2-dichlorobenzene
Cadmium
1, I ,2-trichloroethane
1,3-dichlorobenzene
Chromium
Trichloroethylene
1,4-dichlorobenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid -extractable Compounds
Diethyl phthalate
Mercury
P-chloro-m-cresol
Dimethyl phthalate
Nickel
2-chlorophenol
2,4-dinitrotoluene
Selenium
2,4-dichlorophenol
2,6-dinitrotoluene
Silver
2,4-dimethylphenol
1,2-diphenylhydrazine
Thallium
4,6-dinitro-o-cresol
Fluoranthene
Zinc
2,4-dinitrophenol
Fluorene
Cyanide
2-nitrophenol
Hexachlorobenzene
Total phenolic compounds
4-nitrophenol
Hexachlorobutadiene
Volatile Organic, Compounds.,
Pentachlorophenol
Hexachlorocyclo-pentadiene
Acrolein
Phenol
Hexachloroethane
Acrylonitrile
2,4,6-trichlorophenol
Indeno(1,2,3-cd)pyrene
Benzene
Base -neutral Compounds
Isophorone
Bromoform
Acenaphthene
Naphthalene
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chlorobenzene
Anthracene
N-nitrosodi-n-propylamine
Chlorodibromomethane
Benzidine
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3,4 benzofluoranthene
Pyrene
Dichlorobromomethane
Benzo(ghi)perylene
1,2,4-trichlorobenzene
1,1 -dichloroethane
Benzo(k)fluoranthene
1,2-dichloroethane
Bis (2-chloroethoxy) methane

Permit NC0037508
The Permittee shall report test results within 90 days of sample collection to the Division in DWQ Form- DMR-
PPA1 or in a form approved by the Director. The report shall be submitted to the following address:
NC DENR / DWQ / Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit NC0037508
INTRODUCTION
Moore County Water Pollution Control Plant (WPCP), herein called Moore County or the permittee,
requires a National Pollutant Discharge Elimination System (NPDES) permit to dispose treated
wastewater to the surface waters of the state. The permittee's 5-year NPDES permit expired July 31,
2009 and they have requested renewal and for a modification to increase permitted flow to 10.0 MGD
from the currently permitted 6.7 MGD from the Division of Water Quality (the Division). Moore
County has received Speculative Effluent Limits from The Division on October 30, 2006. An
Engineering Analysis was submitted to Construction Grants and Loans, a FNSI was issued on
October 28, 2009. This Fact Sheet summarizes background information and rationale used by the
Division's NPDES Unit to determine permit limits and monitoring conditions.
FACILITY RECORDS REVIEW
Facility Description. The Moore County WPCP (Table 1) is a 6.7 MGD publicly owned treatment
works (POTW) utilizing a Grade IV activated sludge wastewater treatment facility to treat domestic
and industrial wastewater. The Moore County treatment system utilizes pre -aeration, grit removal,
primary clarification, first -stage activated sludge, intermediate clarification, second -stage aeration,
final clarification, anaerobic sludge digestion, sludge drying beds, and post -aeration.
Table 1.
The Moore County WPCP
Facility Information
Applicant/Facility Name:
The Moore County WPCP
Applicant Address:
1094 Addor Road
Facility Address:
Aberdeen , North Carolina 28315
Permitted Flow (MGD):
6.7 expanding to 10.0
Type of Waste:
Domestic and Industrial (3 SIUs)
Related Permit (s):
Land Application WQ0018081 (Anson County)
Facility Grade / Permit Status:
Grade IV, Major / Renewal / Expansion
Drainage Basin:
Lumber River Basin
County:
Moore County
Miscellaneous
Receiving Stream:
Lumber River
Regional Office:
Fayetteville
Stream Classification:
C
State Grid /
USGS Topo Quad
G 21 SW /
Pinebluff, NC
303(d) Listed?
No
Permit Writer:
Jim McKay
Subbasin:
03-07-50
Date:
8/12/2010
Drainage Area (sq. mi.)
36.3
Summer 7Q10 (cfs)
15.2
r f
Lat. 35° 04' 03" Long. 79° 28' 10"
Winter 7Q10 (cfs)
28.7
30Q2 (cfs) . "
Average Flow (cfs)
47.2
IWC (%)
41 % @ 6.7 MGD, 50% @ 10
MGD
DRAFT Fact Sheet
Renewal/ Expansion-- NPDES Permit NC0037508
Page 1

Correspondence
Staff Report. Fayetteville Regional Office (FRO) conducted an annual facility inspection and Dale
Lopez prepared a Staff Report dated March 9, 2009. The FRO staff found the facility in good
condition and in compliance with the peinut recommending that the NPDES Unit renew the permit in
accordance with the basin plan.
Division Records and Permittee's Renewal Application. The current permit expired on July 31,
2009, and the Division received a timely request to renew the permit from the permittee (Standard
Form 2A) on January 29, 2009.
Permittee's Expansion Request. The Permittee submitted a request for expansion and upgrade of
the existing plant on May 21, 2010, along with the required EAA. The plan is to repair, replace and
upgrade the existing 6.7 MGD facility as needed, and construct an identical third train to provide 10.0
MGD capacity. A 10.0 MGD tertiary treatment system will be added after the secondary treatment in
order to improve the quality of treated wastewater.
COMPLIANCE REVIEW
Waste Load Allocation (WLA). The Division prepared the last WLA for the receiving stream in
June 1994 and developed effluent limits and monitoring requirements considering an in -stream waste
concentration (IWC) of 41 % at 6.7 MGD. The Division views these limits and monitoring
requirements appropriate for renewal except as outlined below (see Permitting Approach Summary).
Verifying Existing Stream Conditions. This facility discharges to Aberdeen Creek [Stream Index
No. 14- 2-11-(6)], a Class C waterbody within the Lumber River Basin. Aberdeen Creek is not listed
as "impaired" [not 303(d) listed], However, Aberdeen Creek discharges to Downing Creek, one of 11
waters within the Lumber River Basin with fish advisories for mercury.
Concerning Mercury. Beginning in September 2003, the Division required Moore County to
monitor Quarterly for mercury using new EPA method 1631 with no mercury limit. When the permit
was renewed in 2005, a mercury limit of 12 ng/ L was added on the assumption that there was no
dilution allowable. The plant sampled twice a month for 6 months at the upstream sample location,
using Method 1631. The highest instream sample was 3.72 ng/ L, so the County applied to the
Division for a relaxed mercury limit based on 7Q10 dilution and 3.72 ng/ L background. In 2006 the
permit was modified based on the new background data, and a mercury limit of 24.1 ng/ L was given
as a Weekly Average. For this renewal, the mercury limit has been kept at 24.1 ng/ L, but as a
monthly average and a daily maximum in keeping with EPA requirements. For the expansion to 10
MGD, the mercury limit was calculated again using 10 MGD discharge, 7Q10 dilution, and 3.72 ng/
L background. The new mercury limit is 20.1 ng/ L, given as a Monthly Average and a Daily
Maximum.
A "re -opener" clause has been retained on the permit to emphasize the need to reevaluate should
compliance questions arise.
DMR Instream and Effluent Data Review. The Division reviewed 24 months of DMRs (January
2008 through December 2009) noting monthly -average flows averaging approximately 4.5 MGD or
about 67% of its permitted capacity. DMRs appear regular, thorough, and complete
DRAFT Fact Sheet
Renewal/ Expansion -- NPDES NC0037508
Page 2

Effluent Total Residual Chlorine (TRC). The TRC footnote has been updated to the new practice of
accepting any reading of less than 50 ug/ L as been compliant with the permit.
Whole Effluent Toxicity (WET) Testing. The Division reviewed Moore County quarterly Whole
Effluent Toxicity records from January 2006 through June 2010 (26 quarterly tests). The Permittee
passed all, quarterly toxicity tests during this time period, except June 2006, December 2006 and
September 2009. Retests the next month all passed.
Notices of Violation (NOVs) and Penalty Assessment. Division records for this facility show no
permit limit violations during the time period January 2001 through September 2010.
Toxicant Chronic and Acute Impact — Pollutants of Concern (POCs). To establish POCs, the
Division reviewed the permit application, discharge monitoring reports (Jan. 2008 through Dec. 2009),
pretreatment data, and the Basin Plan. The Division then used the standard Reasonable Potential Analysis
(RPA) to calculate a maximum predicted concentration for each POC'. Each maximum was then compared
to the POC's freshwater Chronic Standard (Table 2) and also to its Final Acute Value ('/2 FAV) for
freshwater (Table 3).
If by the above method, a POC showed reasonable potential to exceed its 'A FAV, the Division included_a
permit limit as a Daily Maximum to protect the receiving stream against acute toxic affects. 1Q10 flow
was used to calculate dilution. Similarly, if the maximum exceeded the chronic standard, a Weekly and
Monthly Average limit was added to the permit. Findings and draft. permit changes are summarized
below (see Renewal Summary, Table 4).
Table 2.
Moore County WPCP Chronic RPA Findings and Renewal Action
Parameter
Samples
(n)'
Hits
(n)
Maximum ;
Predicted
Allowable
Concentration :
' RP*
y/n
„ Comments`/
Renewal Action
Copper',
58
58
334.6 µg/L
14 µg/L
Yes
Action Level Standard — no
toxicity problem, therefore no
limit; keep monitoring 2/Month
Mercury '"
>"a
123
123
29.61 ng/L
20.1 ng/L
Yes
Upstream data shows 3.27 ng/ L
instream. Limit recalculated for
10.0 MGD flow is 20.1 mg/ L
added as a monthly average and
daily maximum. Keep weekly
monitoring.
Silver:
48
_0
2.5 µg/L
.12 µg/L
Yes
Action Level Standard — no
toxicity problem, therefore no limit;- keep monitoring 2/Month
Zinc A`
48
48
116.1 µg/L
99 µg/L
Yes
Action Level Standard — no
toxicity problem, therefore no
limit; keep monitoring 2/Month
*RP = "Reasonable Potential' to exceed instream Water Quality Standard.
DRAFT Fact Sheet .
Renewal/ Expansion -- NPDES NC0037508
Page 3

Table 3.
Moore County WPCP Acute RPA Findings and Renewal Action
Parameter
,, '
Samples
(n) .`
Hits
(n)
. Maximum,>,
Predicted
Allowable ' `,
3 Concentration
. RP*
y/n
4; :. Comments /
°RenewalsActionr
tCopper
58
58
334.6 µg/L
13 µg/L
Yes
Action Level Standard — no
toxicity problem, therefore no
limit; Keep monitoring
2/Month
Mercury '
123
123
29.61 µg/L
—
—
No acute limit; Standard based
on bio-accumulation
(See Table 2).
Silver
;;n
48
0
2.5 µg/L
2 µg/L
Yes
Action Level Standard — no
toxicity problem, therefore no
limit; Keep monitoring
2/Month
Zinc''
`
" °�
48
48
116.1 µg/L
121 µg/L
No
Action Level Standard — no
toxicity problem, therefore no
limit; Keep monitoring
2/Month
*RP = "Reasonable Potential" to exceed instream Water Quality Standard
Pretreatment Compliance. This NPDES permit requires the Permittee to implement a Long
Term Management Plan (LTMP) or pretreatment program, as specified by federal regulations 40 CFR 403
and Title 15A NCAC 2H.0900 of state regulations. The Permittee's LTMP has been approved by the
Division and potential influent parameters were considered during the Reasonable Potential Analysis.
Moore County WWTP currently services domestic wastes from several surrounding communities and 3
Significant Industrial Users (SIU). All 3 are metal finishers. A fourth metal finisher was withdrawn in late
2009. They are permitted at 0.08 MGD, but are currently producing 0.059 MGD of wastewater, or about
0.88% of Moore County's permitted discharge.
Revising Ammonia (NH3 as N) Limits. Ammonia Limits have been adjusted for toxicity considering
IWC of 50%. The previous permit's Monthly Average (Summer) limit has been adjusted to 1.0 mg/L, and a
limit of 2.0 mg/L Monthly Average (Winter) has been added to the permit. Per statewide policy, the
Division has added ammonia Weekly Average limits to this permit. Because Moore County is a major
municipal, Weekly Average limits are calculated as "Monthly Average values times three." This
corresponds to a new Weekly Averages of 3.0mg/L (summer), and 6.0 mg/L (Winter).
Although new ammonia limits are notably more stringent, the Division reviewed the permittee's NH3 data
and anticipates no compliance problems with new permit limits. Data for the years 2008 and 2009 indicate
ammonia levels consistently reported below detection at 0.5 mg/L.
DRAFT Fact Sheet
Renewal/ Expansion -- NPDES NC0037508
Page 4

RENEWAL SUMMARY
Effluent Monitoring
Table 4.
Permit Renewal -- Recommended Changes/Additions:
Parameter
RP*
Comments / Renewal Action
Ammonia
(NH3 as N)
—
Revised Limits: adjusted Summer Monthly Ave. to 1.0 mg/L; Added Summer Weekly Ave.
of 3.0 mg/L; added limits Winter Monthly Ave. 2.0 mg/L and Weekly Ave. 6.0 mg/L.
TRC
Updated TRC footnote in accordance with current permitting strategy. TRC readings < 50
ug/ L are considered to be compliant with the permit limits..
Copper
Yes
Action Level Standard, no TOX problem therefore no limits; keep monitoring 2/Month
Mercury
Yes
Calculated new limits for 10 MGD discharge using instream background concentration of
3.72 ng/ L and 7Q10. Limits are monthly average and daily max set as the same value of
20.1 ng/ L. Monitoring by EPA Method 1631 E.
Silver
Yes
Action Level Standard, no TOX problem therefore no limits; continue monitoring 2/Month
Zinc
Yes
Action Level Standard, no TOX problem therefore no limits; continue monitoring 2/Month
*RP = "Reasonable Potential" to exceed instream Water Quality Standard.
Instream Monitoring
Previous Requirements:
For Renewal:
Dissolved Oxygen (DO)
Temperature
No changes recommended.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
September, 2010
November, 2010
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Jim McKay at [phone].
NAME:
DATE:
DRAFT Fact Sheet
Renewal/ Expansion -- NPDES NC0037508
Page 5

REGIONAL OFFICE COMMENTS
NAME:
DATE:
REGIONAL SUPERVISOR: DATE:
NPDES SUPERVISOR: DATE:
DRAFT Fact Sheet
Renewal; Expansion -- NPDES NC0037508
Page 6

Beverly Eaves Perdue
Governor
ATA
ThENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
July 30, 2010
Dennis Brobst
Moore County Public Works Director
PO Box 1927
Carthage, North Carolina 28327-1927
Dear Mr. Brobst:
Dee Freeman
Secretary
Subject: EAA Review NPDES Permit
NC0037508
Moore County Water Pollution Control Plant
Expansion
Moore County
An Engineering Alternatives Analysis (EAA) is required with any NPDES application for a new or expanding
wastewater treatment plant discharge, in accordance with 15A NCAC 2E1.0105(c)(2). In order for an NPDES
application to be approved, the EAA must provide complete justification for a direct discharge to surface water
alternative, and demonstrate that direct discharge is the most environmentally sound alternative selected from all
reasonably cost- effective options [per 15A NCAC 2R0105(c) (2)].
Today the NPDES Complex Permits unit reviewed your EAA. We found that the Net Present Value (NPV) for
option 1 (Direct Discharge) is close to the NPV for Option 3 (Non -Discharge via Land Application). Non -Discharge°
where economically feasible is much preferred to a Direct Discharge to Waters of the State
Please further evaluate the non -discharge option to verify that it really is feasible, that the tract of land mentioned is
obtainable, or if another suitable tract is available. Please respond back to me with this information within one month
to the address below.
Sincerely,
4 / ; -
Jim McKay
Complex NPDES Permitting Unit
cc: Fayetteville Regional Office/Surface Water Protection - va e'rail
Hobbs, Upchurch & Associates, P.AJ 8262 Market Street, Suite 201/ Wilmington, NC 28411/ Attn. Mr. BarryKing, P.E.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
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