NC0023973_Technical Correction_20151001

NPDES DOCUMENT :;CANNING COVER SHEET
NC0023973
Wilmington Southside WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Technical Correction
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
October 1, 2015
This document is printed on reuse paper - ignore any
content on the resrerse side

Pat McCrory
Governor
North Carolina Department of Environmental Quality
Division of Water Resources
Donald R. van der Vaart
Secretary
October 1, 2015
Mr. Jim Flechtner, PE
Executive Director
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
Subject: Correction to Fact Sheet
NPDES Permit Modification NC0023973
M'Kean Maffitt (Southside) WWTP
New Hanover County
Facility Class IV (SIC 4952)
Dear Mr. Flechtner:
Attached please find a revised Fact Sheet for the M'Kean Maffitt (Southside) WWTP permit modification.
One sentence in the section labeled.Permit Limit Development (Existing Conditions —12.0 MGD) was
incorrect and was only intended to be listed under the permit limit development sections for the expansion
phases. The sentence on Dissolved Oxygen was stricken from the fact sheet in the 12.0 MGD section.
Please note that the final permit sent in the mail and distributed on 08.25.2015 by email with the effective date
of 10.01.2015 is now considered final and in effect.
If you have any questions concerning this correction or permit, please contact Julie Grzyb by email
([e-mail]) or phone at [phone].
Respectfully,
Julie A.
Environmental Engineer, NPDES Wastewater
Division of Water Resources, NCDEQ
cc: NPDES Unit
e-copy: EPA Region IV (SIC 4952)
Wilmington Regional Office / Water Quality Program
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Toll Free Phone: [phone] Internet: www.ncdenr,gov
An Equal Opportunity 4 Affirmative Action Employer — Made in part by recycled paper

DENR / DWR / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NC0023973 Expansion
Facility Information
Applicant/Facility Name:
Cape Fear Public Utility Authority / M'Kean Maffitt (Southside) WWTP
Applicant Address:
235 Government Center Drive, Wilmington, North Carolina 28403
Facility Address:
3436 River Road, Wilmington, North Carolina
Permitted Flow:
12 MGD, 16 MGD, 20 MGD, and 24 MGD
Type of Waste:
Municipal
Facility/Permit Status:
Modification for expansion to 24 MGD
County:
New Hanover
iscenaneous
Receiving Stream:
Stream Classification:
Subbasin:
8-Digit HUC:
Stream Index:
Cape Fear River
SC
03-06-17
03030005
18-(71)
303(d) Listed?
Yes, Cu and DO
Summer 7Q10 (cfs)
Average Flow (cfs):
Tidal
Tidal
IWC (%):
Revised CORMIX model
required after 16 MGD
expansion.
N/A for RPA
For WET test:
3% at 12 MGD
4% at 16 MGD
5% at 20 MGD
6% at 24 MGD
Regional Office:
State Grid / USGS Quad:
Date:
Addendum added:
Permit Writer:
Wilmington
K 27 NW/Wilmington
May 12, 2015
July 31, 2015 and
revised 8/17/15
revised 9/30/15
Julie Grzyb
Lat. 34° 14' 27" N Long. 77° 57' 10" W
Background:
• This permit was originally issued in 1982.
• This is a permit modification for Cape Fear Public Utility Authority (CFPUA, formerly
the City of Wilmington), which owns and operates the M'Kean Maffitt (Southside)
WWTP. The facility proposes phased future expansions to 16 MGD (Phase I), 20
MGD (Phase 2), and 24 MGD (Phase 3).
• This facility is a Major POTW with a full pretreatment program. The WWTP has one
SIU, New Hanover Regional Medical Center, which contributes an average daily flow
of 103,000 gallons per day from laundry, kitchen, and laboratory wastes.
• The current permit expires on 12/31/2016. The facility submitted an application (EPA
Form 2A) for an expansion/modification which was received on 10/27/14. The facility
included three Effluent Pollutant Scans with the submission.
Facility Description:
• The CFPUA was created by the City of Wilmington, NC and New Hanover County,
NC on July 1, 2008 to consolidate provision of water and wastewater services within
their combined service areas. The CFPUA operates and maintains three wastewater
treatment plants and two water treatment plants.
Fact Sheet
Renewal -- NPDES Permit NC0023973
Page 1

• This Southside VVVVTP was originally placed into service in 1972 as a 6 MGD facility
serving the City of Wilmington. It was later expanded to a 12 MGD secondary
treatment level facility to serve New Hanover County and the Town of Wrightsville
Beach as well.
• Annual average wastewater flow was 8.4 MGD (or 70% of permitted flow) for the
period of July 2012 to June 2013. The annual average wastewater flow was 8.92
MGD in 2014.
• Current treatment consists of dual mechanical bar screens, dual grit collectors, a
manual bypass screen which provides redundancy, two treatment trains which
include a primary clarifier and a trickling filter, an aeration basin, dual secondary
clarifiers, chlorine contact tanks and dechlorination. Sludge is sent to the anaerobic
digesters, dewatered using a belt filter press, and land applied off -site.
• The three Phase expansion from 12 MGD to 16 to 20 to 24 MGD will include
capacity expansions to five pump stations, upsizing of approximately 4,200 linear
feet of force main, addition of a mechanical bar screen and a grit collector, two new
115 foot diameter primary clarifiers, six new aeration basins at 1.65 million gallons,
four 160-foot diameter secondary clarifiers, deep bed tertiary filters, UV disinfection,
and installation of a 60 inch diameter effluent disposal pipe to the Cape Fear River.
The existing secondary clarifiers will be used for influent flow equalization storage in
all expansion phases. Three new gravity belt thickeners will be added for WAS
thickening, three new anaerobic digesters will be added, and four belt filter presses.
Receiving Stream:
• The facility discharges treated domestic•wastewater via Outfall 001 to the Cape Fear
River in the Cape Fear River Basin (subbasin 03-0617, HUC 03030005).
• At the outfall location, the receiving stream is classified SC waters (stream
assessment unit 18-(71)a3 which extends from Greenfield Creek (above Hwy 421)
down to Barnards Creek by Silver Lake.
• This segment of the lower Cape Fear River is listed as impaired on the 2014 303(d)
list for copper and low dissolved oxygen. Much of the low DO condition in the lower
Cape Fear River has been attributed to swamp water inputs.
• The Permittee is a member of the Lower Cape Fear River Program (LCFRP), which
conducts water quality monitoring within the basin to gain a broad water quality
perspective. Instream monitoring requirements as part of a NPDES permit are
waived as long as the facility maintains membership within the LCFRP. The MOA
between DWR and the LCFRP was renewed in 7/1/2011.
• There is a LCFRP station (B9795000) located within this stream segment. Data for
2011-2014 confirms the low DO condition during summer months.
Facility Performance/Compliance Review:
• DMR Data. In 2014, effluent monthly averages ranged as follows: flow (8.0-11.2
MGD), BOD (5.4-8.3 mg/L), NH3-N (14.5-28.6 mg/L), TSS (4.0-8.7 mg/L),
enterococci (2.7-10.9/100m1), TN (19-35 mg/L), and TP (2.5-4.8 mg/L). The two
months with minimum monthly average DO values, ranged from 6.1-6.2 mg/L.
• Permit Violations. No permit limit violations have occurred since the issuance of the
existing permit on June 1, 2012.
• Compliance Inspections. A routine Compliance Evaluation was performed on 9-10-
2014 and the facility received a rating of "Extremely Reliable". A Pretreatment
Compliance Inspection was performed on 9-7-2012 and the facility received a rating
of "Very Reliable".
Fact Sheet
Renewal -- NPDES NC0023973
Page 2

• Aquatic Toxicity Testing. Overall the facility has passed 21 of 25 toxicity tests
performed since 2010. Two failures occurred in 2012 and since the facility discharge
had a strong record of compliance the Permittee informally began Toxicity
Identification Evaluation procedures to identify the cause of toxicity. The Permittee
spilt samples with DWR on several occasions and the study results are in a letter
dated March 6, 2015. In conclusion, CFPUA has requested that their acute toxicity
monitoring requirement be changed to chronic with an IWC based on a dilution study
performed by Tetra Tech dated May 2001. The Aquatic Toxicity Branch sent an
email confirming that the toxicity testing requirements should be changed to a 7-day
pass/fail chronic test using Ceriodaphia dubia at the effluent concentration
determined using the modeled dilution.
Permit Limit Development (Existing Conditions — 12.0 MGD):
• Maintain limits for CBOD at 25 mg/L, TSS at 30 mg/L, and Enterococci at 35/100
mL year round based on secondary treatment standards.
• Maintain pH limits at 6.8.8.5 s.u. range. WQS for Class SC waters.
forDO. (edited 9/30/15)
• Reasonable Potential Analysis (RPA): Effluent metals data for As, Cd, Cr, Cu,
CN, Pb, Mo, Ni, Se, Ag, and Zn was reviewed for the period of Dec. 2011
through Jan. 2015. Samples for As, Cd, Cr, Pb, Mo, Ni, and Se were all reported
below detection levels for that time period. A RPA was performed on Cu, CN, Ag,
and Zn
0
be removed from the permit. See the Addendum at the end of the Fact Sheet. A
revised RPA was performed using an IWC of 100%. All the metals listed above •
will continue to be monitored by the CFPUA as part of their Pretreatment LTMP.
• The Aquatic Toxicity monitoring requirement was changed from acute to chronic.
Based on a dilution model performed by Tetra Tech in 2001 an IWC of 3% was
determined for a Permitted flow of 12 MGD from the M'Kean Maffitt WWTP.
Therefore, the toxicity testing will be revised to chronic toxicity testing using an
effluent concentration of 3% and Ceriodaphnia Dubia as the test organism.
Permit Limit Development (Proposed Phased Expansion to 16 MGD, 20 MGD, and
24 MGD):
• SEPA/FONSI Determination. The proposed expansion was subject to review by
governmental agencies under the State of North Carolina Environmental Policy
Act (SEPA EA), and DWR has concluded that the proposed project will not result
in significant impacts to the environment. A Finding of No Significant Impact
(FONSI) was issued on September 13, 2013 and is available for inspection at the
State Clearinghouse.
• Water Quality Loading Evaluation. In consideration of the 303(d)-listed impaired
waters designation for this river segment due to low dissolved oxygen conditions,
an evaluation of oxygen demand from historical loading versus future loading
was conducted (see Attached). The historical Ultimate Oxygen Demand (UOD)
was determined for the period 2009-2010. Over this period, the facility discharge
averaged 8.51 MGD, with satisfactory CBOD5 effluent levels (7.7 mg/I), but there
were no ammonia limits and relatively little nitrification, with resultant effluent
ammonia concentrations averaging 26 mg NH3-N/I. At full expansion to 24
MGD, the facility will need to comply with advanced BODS limits of 5 mg/I
Fact Sheet
Renewal -- NPDES NC0023973
Page 3

summer/10 mg/I winter, and with significant reductions in ammonia to comply
with future limits of 1 mg NH3-N/I summer and 2 mg NH3-N/l winter. From a
loading perspective (attached), there will be a slight increase in CBODu loading
(from 822 lb/d to 1722 lb/d), but a much more significant reduction in NBODu
loading (from 8289 Ib/d down to 1276 Ib/d). Overall, the UOD load will be
decreased from historical averages of 9111 Ib/d down to 3048 Ibld, or a 66%
reduction in ultimate oxygen demand. The conclusion of this loading evaluation is
that the proposed expansion/upgrade will provide a net benefit to instream
dissolved oxygen conditions.
• Antideqradation Review. Per NC Anitdegradation Policy (15A NCAC 2B.0201),
each applicant for an NPDES permit expansion must document an effort to
consider non -discharge alternatives pursuant to 15A NCAC 2H.0105(c)(2). This
alternatives evaluation was submitted as part of the SEPA EA document, and
resubmitted as an Engineering Alternatives Analysis (EAA) for the permit renewal
and modification. DWR staff reviewed both the flow justification as well as the
alternatives analysis. DWR staff concurred with the projected needs based on a
20-year planning horizon. CFPUA's 2007 Wastewater Master Plan determined
an annual growth rate of -4% per year for the entire 20 year planning cycle.
Most of the growth is expected to occur in the southern portion of Wilmington and
New Hanover County. Maximum wastewater flow is expected to increase from
9.4 MGD in 2013 to 24 MGD in 2033.
Likewise, DWR concurred with the alternatives analysis conclusion that
expansion at the current location with a direct discharge to surface water was the
most environmentally sound alternative from the reasonably cost-effective
options (per 15A NCAC 2H.0105). A cost evaluation for a non -discharge spray
irrigation option for the expanded wastewater volume (12 MGD) would require
16,800 acres and a total project cost of $791 Million; the total estimated project
cost for a non -discharge high -rate infiltration option would require 276 acres and
a total project cost of $340 Million; and in comparison, the total estimated project
cost for expanding the current VVWTP with a direct discharge was estimated at
$201.5 Million, representing a 69% cost savings compared to high -rate
infiltration. In addition, this project is likely to provide an alternative for outdated
failing septic systems throughout the County. DWR concludes that the proposed
expansion will provide for public health benefits and social benefits to the
community by providing necessary regional wastewater treatment services to
accommodate future growth.
• Proposed Limits/Monitorinq for 16 MGD, 20 MGD and 24 MGD.
o BOD/NH3-N: Reduce to 5/1 mglL (summer) and 10/2 mg/L (winter) based
on Best Available Technology for this stream segment as recommended
in Chapter 30 of the Cape Fear River Basinwide Plan.
o TSS. Maintain at 30/45 mg/L secondary treatment levels.
o Dissolved Oxygen (DO): a limit of 6 mg/L based on Cape fear River
Basinwide Plan
o Enterococci bacteria. Maintain monthly average limit of 35/100 mL and
Weekly average limit of 276/100 mL.
o Copper. The revised reasonable potential analysis showed reasonable
potential for copper in the effluent wastewaters to violate saltwater
standards. Copper monitoring was maintained throughout the permit.
o Nutrients: There are no nutrient limits proposed in this permit, since the
receiving waterbody is not listed as NSW and/or 303(d) impaired for
Fact Sheet
Renewal -- NPDES NC0023973
Page 4

chlorophyll -a. Monthly nutrient monitoring will continue per 15A NCAC 2B
.0500.
o In accordance with the 2012 Mercury TMDL NPDES Guidance, effluent
mercury data from 2010-2014 was evaluated. The pretreatment data
showed that the annual mean effluent concentrations were below the
Water Quality Based Effluent Limit of 204 ng/L. Only two of the three
effluent pollutant scans reviewed used the low-level mercury detection
test and that data showed that it was below the Technology Based
Effluent Limit of 47 ng/L. The City will be required to continue monitoring
mercury as part of its LTMP and its Effluent Pollutant Scans.
Pretreatment will be notifying Permittees that they must use method 1631
E and the Effluent Pollutant Scan condition in the permit specifies low
level mercury testing. Low level mercury test results will be re-evaluated
upon permit renewal in 2016 and assessed in accordance with 2012
Statewide Mercury TMDL.
Proposed Schedule of Issuance:
Draft Permit to Public Notice: May 19, 2015 (estimate)
Permit Scheduled to Issue: July 13, 2015 (estimate)
NPDES Unit Contact:
If you have questions regarding any of the above information or on the attached permit,
please contact Julie Grzyb at [e-mail] or call [phone].
SIGNATURE:
DATE: (0—
Comments:
Written comments received from EPA on June 4, 2015, June 26, 2015, and August 5, 2015.
Written comments received from the CFPUA on June 2, 2015.
N.C. Division of Coastal Management stated, "Provided that the project is within state water quality,
storm water and waste water treatment standards, I do not have any comments."
ADDENDUM TO FACT SHEET:
EPA review and discussions:
Model and calculated dilution factor:
Informal comments were received from EPA questioning the validity of the 33:1 dilution ratio
used in determining allowable effluent concentrations for toxicant pollutants of concern and the
effluent concentration to be used for chronic toxicity testing. The three-dimensional water
quality model of the Lower Cape Fear River for the City of Wilmington and New Hanover
County was developed by Tetra Tech in 2000 and 2001 using the Environmental Fluid
Dynamics Code (EFDC) model. As stated in Tetra Tech's 2008 Northside WWTP Effluent
Dilution Analysis Memo, "A general analysis of dilution of the Northside and Southside VVWTP
discharges was conducted using EFDC's integrated "jet plume" code (JP-EFDC); although that
analysis was not conducted specifically for establishing dilution ratios for NPDES permit limits,
the modeling tool represents a significant investment already made by what is now the
Fact Sheet
Renewal -- NPDES NC0023973
Page 5

CFPUA." The 2008 study by Tetra Tech was to address dilution at the increased flow of 16
MGD at the Northside WWTP for both the existing and new discharge line diffusers. The dye
study conducted on the Northside VVWTP discharge was used in the 2008 study to validate
near field mixing and far field transport of the existing effluent at the Northside outfall. A 25:1
dilution ratio was determined for Northside in the 2001 report and the 2008 study resulted in a
20.7:1 ratio being used for permit limit development in Northside's 2012 permit renewal.
Currently, the Southside WWTP is performing acute toxicity testing at 90% effluent. CFPUA
would like to receive credit for some dilution and perform chronic toxicity testing on its
wastewaters instead of acute testing at 90%. The DWR Aquatic Toxicity Branch agreed that the
chronic test is a very effective test and approved the Authority's proposal to perform chronic
toxicity tests using the 33:1 (IWC = 3% at 12 MGD) dilution based on the 2001 model. In
discussions with EPA, this decision was found to be acceptable; however, it was agreed that
eventually a more comprehensive study/model should be performed by CFPUA to validate the
dilution factor for the M'Kean Maffitt (Southside) WVVTP's outfall and discharge volume. The
Authority agreed to such a condition with its Northside WVVTP permit and suggested similar
language for the M'Kean Maffitt WWTP. The following Special Condition was added to the
permit:
A.(8.) MODELING REQUIREMENT
The Authority shall submit a CORMIX model (or equivalent) providing additional
information regarding end -of -pipe dilution no later than 12 months after an
engineer's certification for the completion of the 16.0 MGD plant expansion is
issued. The model shall address dilution at the approved 16.0 MGD increased
flow rate into the Cape Fear River for M'Kean Maffitt WVVTP's specific discharge
configuration. The dilution factor determined by the CORMIX model (or
equivalent) shall be used by the permittee for the chronic effluent test
concentration once the model is reviewed and approved by the Division.
The 33:1 dilution factor was tentatively used to determine chronic effluent testing
concentrations for the other phased expansions until a CORMIX model (or equivalent) is
submitted and approved. The Division agreed with EPA that the dilution factor of 33:1 would not
be used in the determination of allowable effluent concentrations for toxicants (RPA). When the
Authority submits an approvable CORMIX model (or equivalent), the revised dilution factor can
be used for toxicant limit development.
RPA Revision: .
The RPA was revised using no dilution. See attached RPA sheet with flows marked as Tidal, IWC
= 100%. Copper was the only parameter showing reasonable potential to violate Water Quality
Standards. Since the copper standard is an action level limit and the facility is currently passing its
Toxicity tests, no limitation was put in the permit. Copper monitoringwas put in the permit at the
same monitoring frequency as the existing permit (quarterly).
Comments from CFPUA:
Comments were received from CFPUA on July 2, 2015. The comments are summarized below
along with Division responses and any changes made to the permit as a result of these comments.
1. Comments 1 and 2: CFPUA is not submitting eDMR's and substitute Authority for City.
The final cover letter will not contain the statement on receiving eDMR submittals
and City will be replaced with the word Authority.
Fact Sheet
Renewal — NPDES NC0023973
Page 6

2. Comment 3 on modeling: The Authority recognized that the EFDC model does provide
some level of support for the dilution factor but is willing to commit to performing a CORMIX
model (or equivalent) providing additional information regarding end -or -pipe dilution at
SSWWTP, if necessary.
The Division agrees that the 2001 EFDC is sufficient to allow the Authority some
temporary dilution credit in the toxicity test. Therefore, the 33:1 dilution ratio at 12
MGD was used in the permit to determine the effluent concentration to be used for
the chronic toxicity test. A more thorough dilution study shall be performed as
described in the special condition outlined above and in Section A. (8.) of the permit.
The 33:1 dilution factor was not used in assessing compliance with Water Quality
Standards.
3. Comments 4,5,6,7, and 8 on the Supplement to Cover sheet: The Authority requested
corrections to the components list.
Corrections to the components list were made as requested.
4. Comment 9 on TRC: The Authority requests that the TRC footnote require the permittee to
report all data below 50 ug/L as "< 50 ug/L".
This request was formally presented by NCWQA to the Division of Water
Resources. CFPUA is a member of this organization. The DWR laboratory staff is
currently evaluating this request. When the evaluation is completed, and if the
outcome affects the wording in this permit, the Authority can request a permit
modification, if desired.
5. Comments 10, 14, 18, 22 on the Coalition MOA verses instream requirements in the permit:
The Authority is concerned between the differences in the Coalition MOA sampling
requirements and the permit instream sampling requirements and does one affect the other.
The MOA between the LCFRP Coalition and the Division is a separate agreement
from the NPDES permit. The NPDES permit states that if the MOA agreement
should be terminated for any reason the permittee should notify the Division and
resume instream sampling as specified in the NPDES permit. This would also apply
if the permittee terminated its membership with the Lower Cape Fear River
Program. The monitoring frequencies and sampling requirements in the MOA and
the permit are not necessarily meant to be the same. If the renewed MOA in 2016 is
different than the existing one it will not affect the instream monitoring requirements
in the permit. The instream monitoring footnote in all sections A. (1.-4.) will remain
the same.
6. Comments 11, 15, and 19 on monitoring frequency reductions: The Authority wants the
monitoring frequency reductions to continue in the phased expansion Effluent Limitations
and Monitoring Requirements sheets A.(2.), (3.), and (4.).
The expansion from 12 to 16 MGD will be a change in treatment going from
secondary to advanced tertiary treatment. The Authority will have to demonstrate
consistent, long-term treatment performance at levels far below the new effluent
limitations (<50%) at 16 MGD to be considered for a reduction in monitoring from
those specified in 15A NCAC 2B .0500. Once consistent compliance is
demonstrated at the tertiary treatment level (16 MGD) the other phased expansions
sheets can be modified to' only require daily sampling for 6 months in order to show
continued consistent compliance at that expanded flow.
7. Comments 12, 16, and 20 are a repeat of comment 9 above (see #4.) and recognition that
chlorination will be replaced with UV disinfection at 16 MGD.
Fact Sheet
Renewal — NPDES NC0023973
Page 7

Same response as discussed in #4 above and wording was added to all the TRC
footnotes in sections A.(2.), (3.), and (4.) that reporting is only required if chlorine or
chlorine derivatives are contained in the wastewaters being discharged.
8. Comments 13, 17, and 21 are to change CBOD to BOD in footnote #3.
The word CBOD in footnote #3 contained in sections A.(2.), (3.), and (4.) was
changed to BOD.
9. Comment 23 on special conditions relating to TMDLs: The Authority requested that special
conditions on Historical Permit Limits and Anti -backsliding be put into the permit similar to
those contained in the Northside VVWTP permit. On August 5, 2015 EPA, Region IV,
requested that the condition on Anti -backsliding be revised in order to be consistent with
federal regulations cited in 40 CFR 122.44(1).
Both of the requested conditions were added to the permit with some modification to
the Anti -backsliding condition per EPA's comment. See sections A. (9.) and A. (10.).
10. Comment 24 on Standard Conditions: There are several references to treatment facilities
and collection system. CFPUA possess separate permits for its WWTPs and its collection
system; they are independent of each other, and while one can reference the existence of
the others it should not incorporate one into the other.
The Standard Conditions get reviewed and revised periodically and are sent to EPA
for approval. Currently the state wastewater rules are under review. Since the
current standard conditions dated Nov. 9, 2011 have been approved by EPA, these
conditions will be added to the Authority's final permit. NPDES will carefully
consider your comment during the next periodic review of the Standard conditions.
Fact Sheet
Renewal — NPDES NC0023973
Page 8

Grzyb, Julie
From: Ken Vogt <[e-mail]>
Sent: Thursday, September 17, 2015 4:12 PM
To: Grzyb, Julie
Subject: RE: CFPUA Southside permit Mod NC0023973 (final permit)
Thx, Julie, I believe your suggestion will be acceptable. Ken.
From: Grzyb, Julie [mailto:[e-mail]]
Sent: Thursday, September 17, 2015 16:10
To: Ken Vogt
Subject: RE: CFPUA Southside permit Mod NC0023973 (final permit)
Ken,
The statement that effluent DO should be maintained at 6 mg/I at 12 MGD is an error. I will strike it from the fact
sheet and send EPA and you a revised copy. I suppose EPA has the right to comment but since it was correct in the
permit - I would be surprised if they did. Again, since it was an error in the fact sheet but correct in the permit, I do
not believe any further action will be required. I will send out the corrected fact sheet next week and send you an
electronic copy at the same time.
Thank you for pointing out the error.
Julie
From: Ken Vogt [mailto:[e-mail]]
Sent: Thursday, September 17, 2015 3:36 PM
To: Grzyb, Julie
Cc: Jim Flechtner; Frank Styers; Beth Eckert; Linda Miles Firm; Carel Vandermeyden; Craig Wilson; Milton Vann; Bryan
Blake ([e-mail]); Nailor, David A. ([e-mail])
Subject: FW: CFPUA Southside permit Mod NC0023973 (final permit)
Julie - CFPUA staff and consultants have reviewed the accompanying final permit and fact sheet for the CFPUA's
SSWWTP permit modification (expansion).
1. In general, you have satisfactorily addressed most of the concerns brought to your attention.
2. On several issues, including the residual chlorine limit, monitoring frequency reduction, and independence of
treatment plant and collection system permits, you've indicated that it might not be the optimal time to
address them now but DWR would reconsider them at appropriate times) in the future. The CFPUA
understands and accepts DWR's position and decision.
3. One new issue, however, has arisen and requires resolution. Page 3 Permit Limit Development for Existing
(12.0 MGD) Conditions indicates that effluent DO should be maintained at 6 mg/I and that this segment of the
Cape Fear River is impaired for DO. While we strive to do our part to improve DO conditions within the
receiving water, the current SSWWTP 12 MGD NPDES contains no such provision. There is currently no such
DO limits specified at the 12 MGD flow capacity nor does it show up on the 12 MGD Effluent Limitations and
Monitoring Requirements on page 3 of the permit. I'm hoping that this is a misunderstanding, that DO should
not be monitored or limited in the permit under 12 MGD conditions, that the Permit Limit Development
document can be revised accordingly as it lies outside the official permit structure, and that this issue can be
resolved without the need for an adjudicatory hearing. Please review this situation and advise as how it might
best be resolved.
Thx. Ken.
From: Grzyb, Julie [mailto:[e-mail]]
Sent: Tuesday, August 25, 2015 17:18
To: Ken Vogt; Frank Styers
Subject: CFPUA Southside permit Mod NC0023973 (final permit)
1

Ken/Frank,
For your records please find the Final Permit and Fact Sheet for the Cape Fear Public Authority's permit modification
(expansion) issued August 25, 2015.
Julie
Julie A. Grzyb, Environmental Engineer
NC DENR / Division of Water Resources / Water Quality Permitting
NPDES Complex Permitting, Wastewater Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6389 (wk)
[e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be
disclosed to third parties.
2