NCC000001_Annual Report_20060227

THE NEUSE RIVER COMPLIANCE ASSOCIATION
POST OFFICE Box 1 562
APEX, NORTH CAROLINA 27502
February 27, 2006
Mr. Alan Klimek, P.E., Director
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: NPDES Permit No. NCC000001
Annual Report
Dear Mr. Klimek:
The Neuse River Compliance Association is pleased to submit their third annual report as
required in the referenced permit. As included in the attached report, the co-permittee
members discharged a total of 566,627 pounds of total nitrogen to the Neuse Estuary
during calendar year 2005, about 50% under the permit limit of 1,137,171 pounds. In
2004 the Association discharged 558,553 pounds, with a permitted limit of 1,073,115
pounds (or 48% or the permitted limit.) Due to the addition of two new members to the
NRCA in 2005, our permitted limit and total nitrogen discharged have increased, but we
are gratified that we are still 50% below this new permitted limit.
We are very proud of the accomplishments of the Association and the efforts made by
our members to reduce nitrogen loading to the Neuse River Estuary.
We hope that the enclosed report provides the detailed information that the Division
needs. If you have any questions, or if you need any further information, please contact
our Executive Director, Cindy Finan at 919/387-3478.
Sincer
Y,
�vcod M. Phthisic, III
Chairman
Enclosures: Annual Report

NEUSE RIVER COMPLIANCE ASSOCIATION
2005 ANNUAL REPORT
NPDES PERMIT NCC000001
Co-Permittee Members of the NRCA for Calendar Year 2005
Town of Apex
Town of Benson
Town of Cary -North
Town of Cary -South
County of Johnston
Town of Clayton
Contentnea MSD
DHR-John Umstead Hospital (Town of Butner)
Town of Farmville
City of Goldsboro
Heater Utilities-Neuse Colony
Town of Kenly
City of Kinston -Peachtree
City of Kinston -North
Town of LaGrange
City of New Bern
City of Raleigh
Town of Wake Forest
City of Wilson
Town of Zebulon
Unifi-Kinston LLC
MCAS Cherry Point
2

North Carolina's first basinwide NPDES permit for nitrogen control became effective
January 1, 2003. The permit was issued to the Neuse River Compliance Association, a
nonprofit association of 19 wastewater treatment facilities with permits to discharge
treated wastewater into the Neuse River.
All NPDES permitted dischargers over 0.5 MGD in the Neuse River Basin have received
an annual mass limit for Total Nitrogen (TN) to meet a Total Maximum Daily Load
(TMDL) established for the estuary. Each facility has a "transport factor" assigned to
account for loss of TN in stream travel. Transport factors vary from 10% at the upper
watershed, above Falls Lake Dam, to 100% for facilities discharging directly to the
estuary. By multiplying the "end of pipe" discharge, where monitoring occurs, times the
transport factor, results in estuary loading value.
The State Statute and Administrative Rule include a provision that point sources can meet
individual allocations of TN or they can voluntarily form an association for group
compliance with their aggregate estuary allocation.
The framework for compliance with these requirements includes the following
provisions:
In any calendar year, the Permittee shall be in compliance with the annual TN load limit
in the permit if:
a. The Permittee's annual TN load is less than or equal to the limit in the
permit, or
b. The Permittee is a co-permittee member of a group compliance
association.
All sampling, monitoring and monthly reporting requirements are included in the
individual permits.
The Division of Water Quality issued Permit No. NCC000001 to the Neuse River
Compliance Association and its co-permittee Members, effective January 1, 2003 —
December 31, 2007. This permit applies only to Total Nitrogen. The Total Nitrogen
limit in this permit is measured at the estuary and is the sum of co-permittee members
total nitrogen estuary allocations. Co-permittee members, transport factors and
individual allocations are listed in Appendix A of the permit.
The Reporting Requirements of the Group Permit include:
Year -End Report. No later than February 28, 2004 and each February 28th
thereafter, the Association shall submit a year-end report to the Division. The
report shall include, at a minimum, the following information for the previous
calendar year:
3

1) for the period from January 1 through December 31 of the preceding year, a
Discharge Monitoring Report of each co-permittee member's discharge and
estuary TN loads and the Association's estuary TN load.;
2) a summary of changes in Association membership, including regionalization
of discharges;
3) a detailed summary of all purchases, sales, trades, leases, and other
transactions affecting the TN allocations of the Association or its Co-
Permittee Members;
4) a description of the Association's TN control strategy for the preceding year
and changes for the coming year;
5) a detailed summary of measures taken to control TN discharges;
6) an assessment of progress made, and;
7) a description of efforts planned for the upcoming calendar year(s).
In compliance with the permit, the annual report for 2005 is as follows:
Item 1. The Discharge Monitoring Report of each Co-Permittee Member's Discharge
and Estuary Loads and the Association's Estuary TN Load is attached. Co-permittee
members discharged a total of 566,627 pounds of total nitrogen to the Neuse estuary on
the basis of individual TN discharges and estuary transport factors established by the
Division of Water Quality. The calculated estuary loading is substantially less than the
permitted estuary allocation of 1,137,171 pounds (50% of permitted limit). The 1995 TN
loading from the NRCA members was 1,784,130 pounds with a flow of 83.808 MGD.
The 2005 numbers reflect an average flow of 101.739 MGD and a total loading of
566,627 pounds of TN at the estuary. The NRCA added two new members in 2005,
Unifi-Kinston, LLC and MCAS Cherry Point. Even with the addition of these two
dischargers, the NRCA still has maintained a 69% reduction in TN over the numbers
reported by the original group in 1995. The Neuse River Compliance Association and all
of its co-permittee members are in compliance with permit requirements for total nitrogen
discharge for 2005.
Item 2. Summary of changes in Association membership, including regionalization of
discharges: In Jan. 2005, the association added two new members, Unifi-Kinston-
NC0003760 and MCAS Cherry Point- NC 0003816. The permitted flow from these two
facilities would add 7.1 MGD and 64,056 pounds per year of total nitrogen to the
NRCA's permit. It should be noted that the additional TN loading from the NRCA, as
compared to 2004' a report was only 8151 pounds, even with the addition of these two
members.
Additional details of regionalization are summarized, by facility, below:
North Cary WRF (NC0048879) Approximately 0.425 MGD of mixed
domestic/industrial wastewater from the western regions of Research Triangle Park and
surrounding area was diverted from the North Cary WRF to the Durham County Triangle
Wastewater Treatment Plant (Cape Fear River Basin) in April 2005. That diversion,
intended to be permanent until 2011, is authorized up to 4.0 MGD by an inter-
governmental sewer service agreement between Durham County and the Town of Cary.
4

Full flow to Durham County is expected to occur by 2010 with subsequent diversion
from Durham County to the proposed Western Wake Regional Water Reclamation
Facility in 2011.
Clayton WWTP (NC0025453): The Town of Clayton purchased 150,000 gpd of capacity
from Johnston Co.
New Bern WWTP (NC0025348): The City of New Bern removed the discharges of the
Stately Pines WWTP and the Trent River WWTP from the river.
Town of Wake Forest, Smith Cr. WWTP (NC 0030759): As of July 1, 2005, the Smith
Cr. WWTP changed ownership from the Town of Wake Forest to the City of Raleigh.
Please note that no changes in flow between the Neuse River WWTP and the Smith Cr.
WWTP occurred. In October, 2005, the Smith Cr. WWTP began receiving all flow from
the Jones Dairy Farm WWTP (NPDES # NC0064119). A letter from Mr. H. Dale Crisp,
Raleigh Public Utilities Director, has been sent requesting their nitrogen allocation be
added to the Smith Cr. WWTP permit. This was not done in the NRCA NPDES permit
in 2005.
Item 3. Detailed summary of all purchases, sales, trades, leases and other transactions
affecting the TN allocations of the Association or its Co-Permittee members.
Several short term lease agreements that have been entered into by NRCA members for
2005. At this time these leases are only for the year 2005. The transfers are reflected on
the attached spreadsheet containing the data for the members for 2005. They are
summarized as follows:
The Town of Kenly has leased 1800 estuary pounds of nitrogen from Johnston Co. in
order to allow them to comply with their allocation while they pursue an engineering
review of their facility for possible improvements.
Contentnea MSD has leased 1800 estuary pounds of nitrogen from Unifi-Kinston LLC in
order to comply with their allocation while they are finishing construction on their
collection system. Correction of infiltration and inflow problems in the collection system
should improve treatment at their wastewater treatment facility.
MCAS Cherry Point has leased 20,000 estuary pounds of nitrogen from the NRCA while
they pursue and upgrade to their treatment plant. It should be noted that while Cherry
Point made this agreement and paid the association for the nitrogen, they were able to
comply with their original allocation without this leased nitrogen. The NRCA used the
money from the lease agreement to make a grant to the Town of LaGrange to pursue a
water reclamation project that will effectively remove their discharge from the river
during the summer months.
5

Item 4. Description of the Association's TN control strategy for the preceding year and
changes for the coming year:
The Association continues to monitor member's compliance with TN allocations and
enforces against its members based on the following policy.
The Operating Policy and Procedures Committee of the Association developed and
recommended operating policies and procedures in May of 2003. The NRCA adopted
the following policies and procedures on June 17, 2003.
"Assessment of Penalties Paid by Association for Noncompliance.
The member(s) responsible for reporting violations or other violations not related
to exceedence of the Association's group nitrogen allocation shall pay or share
payment of the entire penalty.
Incentives for Members to reduce their TN discharge and disincentives for
exceeding their individual estuary allocation.
The assessment for an individual member exceeding its estuary allocation shall be
one-fourth of the Wetlands Restoration Fund amount for a member's first annual
exceedence, one-half for the second annual exceedence, three fourths for the third
annual exceedence and 100% afterwards. This assessment shall apply for an
exceedence of an individual allocation in the year(s) in which the Association is
compliant with its allocation and also in years when it exceeds its allocation,
however in years that the Association exceeds its allocation, any amount paid by
the individual discharger as its share of the Association penalty shall be credited
to the assessment.
The assessment will be accounted for separately and made available to the
member that paid it to use for the wastewater treatment plant improvements,
provided that a plan for such improvements is presented to and approved by the
NRCA as being reasonably designed to address the TN exceedence. The
assessment will be repaid to the member once the project is completed and the
member achieves compliance.
There should be an annual progress check by the NRCA to ensure that the project
remains on the approved schedule.
The NRCA should retain 20% of the assessment paid by the member to cover
administrative expenses.
The amount of the assessment should be based on excess pounds delivered to the
estuary by the discharger, not the excess pounds discharged at the end of the pipe,
since the Neuse Rules were written and adopted to protect only the estuary from
nitrogen overload.
The assessment should not become effective until the year 2004. "
6

return activated sludge was rerouted. These changes resulted in the increased plant
efficiency and increased process stability.
Cary (North): The facility was designed to remove nutrients biologically without
chemical addition. The town offsets discharges to Crabtree Cr. By diverting flow to the
reclaimed water system with use as much as 750,000 per day in peak season and a
minimum of 200,000 gpd in the non -peak season.
Cary (North and South) The Town of Cary operates a water reuse program consisting of
reclaimed water treatment, storage and distribution of treated effluent. The distribution
system includes dedicated reclaimed water piping and bulk transport of reclaimed water
off plant premises by certified operators. This water is used for irrigation, in commercial
cooling towers, for dust control, road bed aggregate compaction, and other permitted
non -discharge purposes. The table below summarizes the yearly net effect of this
program as a diversion or offset of treated effluent not entering the Neuse River
watershed.
North Cary Reclaimed Water Program: July — December, North Care WRF
2005
North Cary WRF
Total Flow,
Million Gallons,
MG
Average Total
Nitrogen, from
Effluent Data, mg/L
Calculated Total
Nitrogen
diverted/offset from
NPDES discharge, lbs.
July
11.985
3.57
356.84
August
11.380
3.23
306.56
September
12.852
2.45
262.60
October
7.814
3.34
217.66
November
6.027
3.47
174.42
December
1.860
3.62
56.16
Sum, 2"° half CY 05
50.058 MG
1,374.24 lbs. TN
South Care Reclaimed Water Program: July — December
2005
South Cary WRF
Total Flow,
Million Gallons
Average Total
Nitrogen, from
Effluent Data, mg/L
Calculated Total
Nitrogen diverted
from NPDES
discharLLt.
July
4.619
1.83
70.50
August
4.278
2.18
77.78
September
5.340
2.04
90.85
October
4.681
3.59
140.15
November
4.620
2.87
110.58
December
4.464
3.22
119.88
Sum, 2"" half CY 05--0.-
23.538 MG
609.74 lbs TN
Johnston Co.: The County has continued optimization of deep bed filters operating in the
denitrification mode with very good results. Johnston Co. sprayed a total of 88.572
8

In addition, the Bylaws of the Association allow the group to establish policies and
procedures and establish a framework to encourage the transfer of TN allocation by
members in a manner that is cost effective and that provides incentives for TN reduction
that will be most beneficial to the Neuse Estuary.
Several members have chosen to pay another member for a temporary lease of a portion
of their total nitrogen allocation, to bring them into compliance rather than to risk facing
enforcement from the Association. Only two members, the Town of Kenly and
Contentnea MSD have negotiated lease agreements to bring them into compliance with
their allocation. The Association believes that these members are taking adequate steps
to address nitrogen reduction at their plant at the current time. The MCAS Cherry Point,
negotiated a lease agreement with the NRCA in order to become a member, and paid for
an additional 20,000 lbs of TN during their first month of membership. In the end, the
Base managed to make adjustments to their plant that allowed them to comply with their
original allocation for 2005. The money that was collected for this lease has been
earmarked for the Town of LaGrange to use to fund a reuse project at their facility. This
project will effectively use the entire effluent flow to irrigate a nearby nursery during the
warm months of the year. This should serve as a great help to the Neuse River, by
removing this discharge from the river during warm months.
Policy and/or rulemaking goals that should be pursued.
(1) Point source/non-point source trading may be advantageous and should be
pursued.
(2) The association is in the process of rewriting its bylaws. The Bylaws
committee is in the process of making recommendations to the Board of
Directors that would strengthen the enforcement policy (by increasing the
financial penalty and bringing it in line with what the discharger would
have to pay the EEP for additional nitrogen).
Item 5. Detailed summary of measures taken to control TN discharges:
A summary from each member is provided below:
Apex: The Town has created more anoxic zones in the oxidation ditches by using timers
to turn the rotors on and off.
Benson: The Town has hired an additional wastewater treatment operator to help
maintain enhanced operation of the plant.
Butner: A preliminary study was done by O'Brien and Gere to determine the best
solutions to improve the operation of the treatment process. Based on the their
recommendations and those of the plant staff, the anoxic recycle was reduced and the
7

million gallons of effluent, with an average TN concentration of 2.15 mg/1 through their
reuse/irrigation program. This was a total of 1588 pounds of TN that did not enter the
Neuse River by way of their discharge.
Clayton: The Town of Clayton has operated the facility to optimize nitrogen removal.
Construction has started on a 3.2 million dollar nutrient removal project. This project
includes biological nutrient removal and additional solids handling. The town installed a
25,000 gpd in -plant reuse system. The cost of this system was $109,000.
Contentnea MSD: The replacement of 10,700 If of outfall line is now 50% complete.
The system has contracted with McGill Environmental to remove 1,000,000 gallons of
sludge in FY 2005-2006. The system is also initiating a reuse program utilizing spray
irrigation of reclaimed water.
Goldsboro: The City of Goldsboro WRF uses biological treatment control to reduce the
amount of total nitrogen that is discharged from the plant to the Neuse River. The City
also reduces the amount of total nitrogen that is discharged into the river by using reuse
water for irrigation at a hay farm and at the golf course, as well as a constructed wetlands
polishing project.
Town of Kenly: The Town of Kenly has retained the engineering services of O'Brien
and Gere to complete a detailed study of the facility and it's operations. O"Brien and
Gere will make recommendations to the town regarding ways of reducing TN discharges.
Kinston (Peachtree and Regional): The City is returning nitrate to the anoxic zone to
enhance denitrification.
City of Raleigh: The City is continuing with improvement projects at the wastewater
plant that include replacing diffuser systems in the aeration basins. They are also testing
sugar water as a replacement for methanol as a carbon source for denitrification.
Smith Cr. WWTP: The Town of Wake Forest recently completed a project installing
automatic weir controls on the bioreactors. This should improve their TN reduction.
Wilson WWTP: The City of Wilson is expanding the reclaimed water system by
extending the distribution lines to the US Hwy 301N industrial corridor and to Firestone
Parkway. Modifications have been made in the BNR basins to improve flow from the
aerobic zone into the anoxic zone. There was a problem with backflow from the anoxic
zone prior to the modifications. The aeration pattern at the end of the aerobic zone has
been reduced to improve dissolved oxygen control in the aerobic zone. A new BNR tank
is under construction and is scheduled to begin operation by March 2006. The City
continues to maintain effective and efficient operation of the BNR system.
Zebulon: The town continues to try to operate the plant as efficiently as possible to
control TN. The reclaimed water system was expanded in 2005.
9

Unifi-Kinston, LLC: The operators try to maintain an anoxic zone in the front basin to
aid in denitrification. The system performs well except in cold weather months.
MCAS Cherry Point: The base replaced aging equipment in the existing pilot TN
removal system and began operating it 24 hours per day, 7 days per week, 365 days per
year. All operators on all shifts are being trained to operate the system.
Item 6: An assessment of progress made: We believe the numbers speak for
themselves!
Current members of the compliance association discharge the following flows and
pounds of total nitrogen to the Neuse Estuary in the years shown:
Year
Total Flow
(MGD)
Total Estimated
pounds TN to
Estuary
1995
83.808
1,784,130
1996
85.675
1,741,492
1997
81.444
1,653,262
1998
93.442
1,387,717
_ 1999
94.659
1,123,169
2000
92.582
1,056,202
2001
86.818
907,381
2002
89.926
797,991
2003
107.463
711,398
2004
101.203
558,553
2005
101.757
_ 566,627
The Association is extremely proud of the efforts of its members in removing still more
nitrogen from the Neuse this year and the removal rates that they have been able to
achieve. We are pleased that one of our new members, MCAS Cherry Point, has been
able to use their membership in the Association to assist them in making improvements in
their operations that have brought them into compliance with their original allocation.
We have seen that the commitment, experience and knowledge of our members has
helped the group to minimize nitrogen loading which we hope will further improve water
quality in the Neuse River estuary in the future.
Item 7: Description of efforts planned for the upcoming calendar year(s):
The following details were provided by our members on their plans for 2006 and beyond.
Apex: The town is receiving price quotes for mixers to be installed in the oxidation
ditches to provide a better mix during periods when rotors are off, thus giving longer
detention times for anoxic zones.
Benson: The town will start the reclaim water system and reuse part of the plants
discharge for irrigation.
10

Cary: The Town of Cary commits itself to continued optimal performance of its two
biological nutrient removal water reclamation facilities. An expansion of the reclaimed
water distribution system will increase the amount of treated effluent diverted from the
receiving stream, Crabtree Cr., a tributary to the Neuse River. In CY 2005, the reclaimed
water distribution system for the North Cary Water Reclamation Facility consisted of a
total of approximately 300 customers representing a mix of residential and commercial
connections. An estimated 10-15% increase in additional gallons (50.05 MG for 2" a half
of CY 05) used by those customers, seasonally reflected are anticipated in CY06, as a
result of increased connections to the distribution system. Requirements relative to the
quality of the reclaimed water and its designated uses were consistently achieved in CY
2005.
Johnston Co.: The County plans to expand the reuse system when State approval is
received.
Clayton: The Town of Clayton plans to optimize the system that they now have under
construction.
Contentnea MSD: The system has a 201 update in progress with engineer's
recommendations forthcoming. They continue to pursue I/I control measures.
Goldsboro: The City of Goldsboro WRF will continue the present strategies on the
reduction of the total nitrogen at its water reclamation facility.
Kenly: The Town of Kenly has retained the engineering service of O'Brien and Gere and
will review and possibly follow recommendations made by that firm.
Kinston: The City will open the new water reclamation facility. This facility will have
new BNR basins, denite filters and UV disinfection. A portion of the effluent will be
sprayed on 10 acres of trees as a demonstration project. Approximately 70 acres were
purchased in December 2005 to be used for spray irrigation. The Peachtree plant is
scheduled to close in the late summer of 2006.
New Bern: The City of New Bern will begin its reuse program. The effluent will be
discharged into the Martin Marietta Quarry for reuse on Mackilwean Turf Farm.
Raleigh: The City plans to design a tertiary filter expansion that will reduce our per
square foot loading of the existing filter. The additional capacity should have a positive
impact on the denitrification process that occurs in the tertiary filter.
Wilson: The City of Wilson is actively seeking new customers for reclaimed water.
Plans have been developed to extend the reclaimed water distribution line to the City -
owned soccer complex and to Wilson Country Club. The irrigation system at
Wedgewood Golf Course is being expanded to include additional spray areas.
Zebulon: The town will continue to expand the reclaimed water system in 2006.
11

Unifi-Kinston, LLC: the facility will try to maintain anoxic zones in the front basin for
denitrification.
MCAS Cherry Point: For 2006, Cherry Point intends to finalize plans for the permanent
upgrade to the wastewater treatment plant and to advertise for bids. Cherry Point intends
to lease 10,000 pounds of TN credits from the NRCA for 2006.
12

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Adjusted TN
Allocation 2005
20,274 20,274
16,895 16,895
5,860 5,860
71,623 71,623.
90,105 90,105
33,734 31,934
3,548 5,3481
52,937. 52,937
338,209! 338,2091
33,790 33,790t
78,842 78,8421
11,227 11,227
59,421 I
4,4401
1,137,171 1,137,171
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Member TN
Dischar e
(Lbs/Yr.)
31,622
14,325
31,820
66,603
35,650
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16,460
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40,547
33,790
58,599
143,246
180,211
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TOTAL NITROGEN DISCHAI
NEUSE RIVER COMPLIANCE A
YEAR-END REPORT FOR 2005
2005 - JAN THROUGH DEC
NPDES Permit
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Unifi-Kinston, LLC
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