NCC000001_Annual Report_20070227

THE NEUSE RIVER COMPLIANCE ASSOCIATION
POST OFFICE BOX 1562
APEX, NORTH CAROLINA 27502
7.001
February 27, 296 i7'
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 fourth annual report
as required in the referenced permit. As included in the attached report, the co-permittee
members discharged a total of 542,205 pounds of total nitrogen to the Neuse Estuary
during calendar year 2006, about 48% of the permit limit of 1,137,171 pounds. In 2005
the Association discharged 566,627pounds, with a permitted limit of 1,137,171 pounds
(or 50% or the 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,
Sincerely,
�rl :I
Haywttd M. Phthisic
Chairman
Enclosures: Annual Report
EPA Blue Ribbon Award Nomination

NEUSE RIVER COMPLIANCE ASSOCIATION
2006 ANNUAL REPORT
NPDES PERMIT NCC000001
Co-Permittee Members of the NRCA for Calendar Year 2006 j jji
L
d�
-- f
Town of Apex
Town of Benson
Town of Cary
North Plant
South Plant
County of Johnston
Town of Clayton
Contentnea MSD
DHR-John Umstead Hospital (Town of Butner)/South Granville WSA
Town of Farmville
City of Goldsboro
Heater Utilities-Neuse Colony
Town of Kenly
City of Kinston
Peachtree
North/Kinston Regional Water Reclamation Facility
Town of LaGrange
City of New Bern
City of Raleigh
Neuse WWTP
Smith Creek WWTP
Little Creek WWPT/Formerly Town of Zebulon
City of Wilson
Unifi-Kinston LLC
MCAS Cherry Point
2

Background
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 2006 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 542,205 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 (48% of permitted limit) The 1995 TN
loading from the NRCA members was 1,784,130 pounds with a flow of 83.808 MGD.
The 2006 numbers reflect an average flow of 102.970 MGD and a total loading of
542,205 pounds of TN at the estuary. The NRCA has added 3 new members since the
original group reported their baseline loading in 1995. Still, their loading reported in
2006 would indicate that they have reduced the nitrogen loading from these point sources
by 70% over the loading reported in 1995, even while flows have increased.
Item 2. Summary of changes in Association membership, including regionalization of
discharges: The only change to the Association's membership that was reflected in the
NPDES permit in 2006 was the transfer of the City of Wake Forest's Smith Creek Plant
(NC0064149) to the City of Raleigh. Additional changes that were experienced in 2006
that will be reflected in the modified permit in 2007 are: the transfer of the permit NC
DHHS, John Umstead Hospital (NC0026824) to South Granville Water and Sewer
Authority; the transfer of the Town of Zebulon's Little Creek WWTP (NC0079316) to
the City of Raleigh; and the addition of the allocation from Jones Dairy Farm WWTP
(NC0064149) to the allocation for the City of Raleigh's Smith Creek WWTP
(NC0064149.) Additional issues regarding the permit modification have yet to be
resolved.
Additional details of regionalization are summarized, by facility, below:
4

Town of Benson: The Town has partnered with Johnston Co. to take approximately
140,000 GPD from Four Oaks.
City of Kinston: The new Kinston Regional Water Reclamation Facility (KRWRF)
began discharging on August 23, 2006. The last day of flow from the old Peachtree
Wastewater Treatment Plant was September 1, 2006.
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.
South Granville Water and Sewer Authority (SGWSA) sold 3,668 lbs/yr. of estuary
allocation to the Town of Clayton. SGWSA holds in reserve 2,445 lbs/yr. of estuary
allocation. This amount is the remainder of the 6,113 lbs/yr. of TN purchased from Bay
River MSD in 2003.
Several short term lease agreements that have been entered into by NRCA members for
2006. At this time these leases are only for the year 2006. The transfers are reflected on
the attached spreadsheet containing the data for the members for 2006. They are
summarized as follows:
The Town of Kenly has leased 3000 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 5000 estuary pounds of nitrogen from Unifi-Kinston LLC in
order to comply with their allocation while they are finishing work 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 10,000 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 in both 2005 and
2006, they were able to comply with their original allocation without this leased nitrogen.
The NRCA is using the money from the lease agreement to pursue nitrogen removal
projects in the Neuse Estuary.
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.
5

"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."
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
6

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
10,000 lbs of TN in 2006. In the end, the Base managed to make adjustments to their
plant that allowed them to comply with their original allocation for 2005 and again in
2006. The money that was collected for this lease in 2005 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. The addition funds that were collected
from the lease agreement in 2006 will be used to fund additional nitrogen removal
projects to benefit the Neuse Estuary.
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 still constantly reviewing and rewriting its bylaws. The
Association's enforcement policy was originally based on the offset fees
required to be paid to the Ecosystem Enhancement Program. While these
fees are under review by the legislature, the association continues to revisit
their enforcement policy in order to strengthen it in an effort to encourage
members to treat to the lowest levels possible.
Item 5. Detailed summary of measures taken to control TN discharges:
A summary from each member is provided below:
Town of Apex: The Town is continuing with manipulation of ditch rotor motors (on/off)
in the aerobic zones, creating more anoxic zones.
Butner/SGWSA: Intermediate pump station operation was adjusted to minimize flow
changes within the anaerobic and anoxic basin.
Cary: The North Cary facility was designed to remove nutrients biologically without
chemical addition. The nitrogen discharges to Crabtree Creek, a tributary to the Neuse
River in the 50% transport zone. The town diverts flow to the reclaimed water system
with use as much as 907,000 gallons per day in peak season and a minimum of 116,000
gallons in the non -peak. The South Cary facility was also designed to remove nutrients
biologically without chemical addition. The plant discharges to Middle Creek, a tributary
to the Neuse River, and diverts flow to a reclaimed water system with use as much as
260,000 gallons per day in peak season to a minimum of 80,000 gallons in the non -peak
season. The town operates the water reuse program consisting of reclaimed water
treatment, storage and distribution of treated and disinfected 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
7

cooling towers, dust control, road bed aggregate compaction and other permitted non -
discharge purposes. The tables below summarize 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: Jan - December, North Cary WRF
2006
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.
January
3.00
4.25
106.34
February
2.66
4.46
98.47
March
3.85
4.28
137.43
April
6.48
3.22
174.02
May
10.23
4.20
358.34
June
9.89
3.65
301.06
July
13.66
2.87
326.9
August
19.79
3.4
561.2
September
11.18
3.21
299.3
October
8.82
3.52
258.9
November
4.41
3.53
129.8
December
6.86
3.31
189.5
um
100.83 MG
2941.27 lbs. TN
South Cary Reclaimed Water Program: Jan - December
2006
South Cary WRF
Total Flow,
Million Gallons
Average Total
Nitrogen, from
Effluent Data, mg/L
Calculated Total
Nitrogen diverted
from NPDES
discharge
January
5.02
3.09
129.37
February
4.79
2.47
98.67
March
5.08
2.12
89.82
April
5.16
2.61
112.32
May
5.21
2.50
108.63
June
4.28
1.86
66.39
July
4.15
2.15
74.8
August
5.15
2.08
89.3
September
4.95
1.99
82.2
October
4.96
2.10
86.9
November
3.96
1.93
63.7
December
3.99
2.14
71.4
um, CY 06
56.7MG
1073.5 lbs TN
8

Johnston Co.: The County conducted a pilot project to enhance denitrification filter
operations. During the last quarter of 2006 the filters were hydraulically loaded (2.5 to
3.0 gal./sq. ft.) The average TN concentration for the last quarter is 1.30 mg/l. The
county sprayed 57.8 million gallons of effluent on reuse fields, keeping that loading from
entering the Neuse River.
Clayton: The town currently has a major BNR project underway that is 75% complete at
a cost of $3.2 million.
Contentnea MSD: The three towns that make up CMSD are working to control
infiltration and inflow. This is a slow and expensive task for small towns. They have
made major improvements to the collection system, however I&I is still a major priority.
The board has been presented with a plan which includes an upgrade and expansion of
this facility. A decision should be made in the next 6+ months. During 2006, the facility
experimented with "Kenaf' to assist in TN reduction. The regional office of DWQ was
aware of this test and other facilities have used this product with some degree of success.
The facility ran the study for 6 months using this product and determined that it was
detrimental to the treatment process and did not accomplish any nitrogen removal. They
discontinued the study in August of 2006.
Goldsboro: The City of Goldsboro WRF used biological treatment control to reduce the
amount of total nitrogen that is discharged from the plant into the Neuse River. The City
also reduces the amount of total nitrogen that is discharged into the Neuse by using reuse
water for irrigation at a hay farm and at the golf course, as well as a constructed wetlands
polishing project, which is performing very well.
Town of Kenly: The Town is utilizing various control measures that were recommended
by their engineering firm and has been able to reduce their TN discharge by 28% despite
a 10% increase in influent flow. The engineering firm that is assisting the town is
currently working on an engineering study that will likely recommend automation of the
treatment plant including the installation of timers on the aerators in the aeration basins.
Kinston (Peachtree and Regional): The new Kinston Regional Water Reclamation
Facility (KRWRF) began discharging on August 23, 2006. The last day of flow from the
old Peachtree WWTP was September 1, 2006. The components of the new KRWRF are
as follows: Primary Treatment- fine filter screening and grit removal; three trains of
BNR with three methods of computer controlled oxygen input; three secondary clarifiers
with individual RAS pumps and controls; four new denitrification filters with methanol
feed and I V disinfection.
City of New Bern: The City of New Bern began discharging into the Martin Marietta
Quarry under permit #WQ0017635. The water was used to irrigate a sod farm.
Approximately 13,013.20 pounds were applied to the land that did not enter the river. In
August- 3,154.44 pounds were diverted, in September- 3,415.23 pounds, in October-
4,046.05 pounds and in November- 2,397.47 pounds.
9

City of Raleigh/Neuse River WWTP: During 2006, all six aeration basins and mixed
liquor distribution channels were upgraded with new diffuser systems. In addition,
testing was completed using sugar water as an alternative to methanol.
Wilson WWTP: funding was obtained to extend the reclaimed water distribution pipe to
Bridgestone Firestone (BF) and Bert Gillette Soccer Complex. BF will use reclaimed
water in their cooling towers. This project should be completed by the end of the year.
Additional spray areas for reclaimed water were added at Wedgewood Golf Course. A
new BNR basin was put on line in February, 2006. The City continues to seek ways to
improve operation of the BNR system and denitrifying filters to further reduce TN.
Zebulon/City of Raleigh -Little Cr.: The facility continues to work to control the amount
of TN discharged through proper operation of the facility.
Unifi-Kinston, LLC: The operators continue to maintain an anoxic zone in the front
basin to aid in denitrification.
MCAS Cherry Point: The Base began construction of a $13 million plant upgrade to
remove TN at the facility.
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
2006
102.970
542,205
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
10

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 continuing with manipulation of ditch rotor motors in the aerobic
zones to create more anoxic zones. If the nitrogen levels rise too much, the town has
plans to divert some of the flow to the City of Raleigh.
Benson: The town will pursue a plant upgrade for flow in 2007.
South Granville Water and Sewer Authority: The authority will continue to resolve
hydraulic issues and to further investigate intermediate pump station operation- duration
and sequencing.
Cary: The Town of Cary commits itself to continued optimal performance of its two
biological nutrient removal water reclamation facilities.
Johnston Co.: The County plans to continue their filter optimization project.
Clayton: The Town of Clayton plans to complete the current BNR project along with a
reuse water system. Both systems should be completed by the end of the year.
Contentnea MSD: CMSD plans to 1) Continue with I&I reduction. 2) Install
denitrification filters and piping of their effluent to meet NCDWQ requirements for
effluent channels. They will submit a grant application to the NCCWMTF to aid in the
funding this project. 3) Continue with plant upgrade/expansion plans.
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
anticipates completion of an engineering study by the summer of 2007. The town is
required to submit this study to the NRCA and will proceed to implement the study's
recommendations.
Kinston: Approximately 83,000 pounds of TN was discharged from the two plants in
2006. The target discharge of TN for 2007 will be 63,000. The City's NPDES permit
allows for 126,710 pounds, therefore, they hope to achieve a 50% reduction for 2007. A
ten acre effluent (reuse water) spray field in currently under construction. Seventy more
acres are planned for completion in late 2007-2008.
11

New Bern: The City of New Bern will continue to operate its land application/reuse
program and will strive to improve operation. The effluent will be discharged into the
Martin Marietta Quarry for reuse on Mackilwean Turf Farm.
Raleigh/Neuse River WWTP: In 2007, the aeration blowers will be replaced and an
automatic dissolved oxygen control system will be installed to better control dissolved
oxygen levels in the aeration basins. Also, additional tertiary filtration will be installed.
This additional filtration will reduce loading on the existing filters and provide for better
denitrification before final discharge.
City of Raleigh/Smith Creek: the Smith Creek WWTP is scheduled to be upgraded and
expanded from 2.4 MGD to 3.0 MGD beginning in 2007. Upgrades that may have an
impact on nitrogen performance include: aeration system modifications, additional
tertiary filter capacity and the ability to divert flow to the Neuse River WWTP for flow
equalization.
Wilson: The City plans to upgrade the dissolved oxygen control process in the BNR
system including installation of new DO probes to improve BNR efficiency.
Construction to expand the reclaimed water system to Bridgestone Firestone and Bet
Gillette Soccer Complex will begin in early summer.
Zebulon/City of Raleigh- Little Cr.: The City is planning stages of expanding the
reclaimed water system. The expansion will take reclaimed water to several industries in
town and increase the system use up approximately 100,000 gallons per day.
Unifi-Kinston, LLC: the facility will try to maintain anoxic zones in the front basin for
denitrification.
MCAS Cherry Point: The base will continue with construction of the TN removal system
upgrade. The project should be complete in summer 2008.
The NRCA was nominated for an EPA Blue Ribbon Water Quality Trading Award in
January, 2007. We have included a copy of the nomination that was submitted at the
conclusion of this report. The winning programs will be announced in May/June 2007.
We believe that the reductions in nitrogen loading that have been eperienced by the
NRCA are deserving of national attention!
12

TOTAL NITROGEN DISCHARGE MONITORING REPORT
NEUSE RIVER COMPLIANCE ASSOCIATION
,YEAR-END REPORT FOR 20061
j2008JAfHRouGH DEC
NPDES PERMIT NO: NCC000001 END OF PIPE
FACILITY
Permit
NPDES Permit Flow'
(MGD)
Town of Apex IVC0064050
Town of Benson NC0020389
Butner/SGWSA NC0026824
Cary North NC0048879
Cary South NC0065102
County of Johnston. NC0030716
Town of Clayton NC0025453
Contentnea MSD NC0032077
PAGE 1 OF 4
2006 Member TN
Avg Flow Allocation
(MGD) (lbslYr.)
3-60 2.343
3.00 1.192
40,547
Februa
25, 2006
Member TN
Discharge Transport
(Lbs/Yr_) Factor
33,790
31,076 50%
13,178 50%
3.50 2.100 58,599 42,924 10%
12.00 6.989 143,246 77,357 50%
16.00 4.824 180,211 33,247 50%
4.99 4.233 67,467 24,560 50%
2.50+ 1.469 21,400 17,680 50%
2.85 1.9941- 32,100 32,330 70%
Town of Farmville NC0029572 3.50 2.076 42,211
City of Goldsboro 01 & 02 NC0023949
Town of Kenly NC0064891
City of Kinston (Peachtree) NC0020541 6.75 2.114 76,026 33,055 70%
City of Kinston (North) NC0024236 4.50 3.161 50,684 50, f , , 70%
Town of LaGrange NC0021644 0.75 0.535 _ 8,447 5,83• 70%
Neuse Colony 'NC0064564 0.75 0.109 8,447 5,386 50%
City of New Bern NC0025348 6.50, 3.349 52,937 37,033 100%
City of Raleigh NC0029033 60.00 44.798 676,417 313,508 50%
City of Raleigh -Smith Cr. NC0030759 6.00 1.026 67,579
Cly of Wilson NC0023906 14.00 8.490
Town of Zebulon/Raleigh Little Cr NC0079316 1.85 0.591
Unifi-Kinston, LLC NC0003760 3.60, 0.420
ESTUARY
Temporary Original Adjusted TN 2006 TN
Lease Estuary Allocation 2006 Discharge
Agreement Allocation (ibs/Yr.) (Lbs/Yr.)
20,274 20,274
16,895 16,895
5,860
71,623
90,105
15,538.0
6,589.0
5,860! 4,292.4
71,623 38,678.5
90,105 16,623.5
-3000 33,7341 30,734 12,280.0
10,700! 10,700 8,840.0
5000 22,470 27,470 22,631.0
21,18 50% 21,106 21,106j 10,592.0
16.80 7.742 198,118 83,34 70% 138,5211 138,521 58,343.6
0.952 8,48lI
50% 3000 3,548 6,543T 4,240.0
53,218 53,218 23,138.5
MCAS Cherry Point NC0003816
Association Allocatior#
NRCA TOTALS
157,684
22,455
35,479 35,479
5,913 5,913
4,224
9,,386 50%
100,857 50%
6,238 50%
52,937
338,209
33,790 r
78,842
52,937
338,209
33,790
35,030.8
4,087.3
2,693.0
37,033.0
156,754.0
4,693.0
78,842 50,428.5
11,227. 11,227 3,119.0
35,193 12,140 70% -5000 24,635j 19,635 8,498.0
3.50 2.059 39,421 18,082 100% 10000 39,421' 49,421 18,082.0
48,879 0 50% -10000 24 440i 14,440 0.0
102.970 � �� Net 0 1,437,171 1,137,171 542,205,
177.57
THIS MONITORING REPORT HAS BEEN COMPILED FROM CO-PERMITTEE MEMBERS MONTHLY DISCHARGE MONITORING
REPORTS. I CERTIFY THAT IT IS ACCURATE AND COMPLETE TO THE BEST OF Lld1Y KNOWLED ` E.
HAYWO D M. PHTHISIC, CHAIRMAN, NEUSE RIVER •' t "�A ' S F• Is SATE
1. Flow 1Yom Nutrient Management Strategy with subsea nt char es. 2. Goldsboro Pipe 02 is from Constructed Wetland
3. Formerly Burlington Industries
Temporary lease agreements between UnE-Kinston LLC and Contentnea MSD, Kenly and Johnston Co. and MCAS Cherry Point and NRCA are reflected in the estuary allocations above.
TN discharge is calculated from DMR monthly flow and TN concentration. The product is rounded to whole number.
r 1
THIS REPORT PREPARED BY CINDY FINAN, NRCA EXECUTIVE DIRECTOR

TOTAL NITROGEN DISCHARGE MONITORING REPORT
l l i
NEUSE RIVER COMPLIANCE ASSOCIATION
YEAR-END REPORT FOR 2006
2006 - JAN THROUGH DEC
FACILITY
Town of Apex
Town of Benson
Butnerr/SGWSA
Cary North
Cary South
County of Johnston.
Town of Clayton
Contentnea MSD
Town of Farmville
City of Goldsboro Pipe 01
City of Goldsboro Pipe 02
Town of Kenly
City of Kinston (Peachtree)
City of Kinston (North)
Town of LaGrange
Neuse Colony
City of New Bern
City of Raleigh
City of Raleigh- Smith Cr.
City of Wilson
Town of Zebulon/Raleigh, LittIe
Unifi-Kinston, LLC
MCAS Cherry Point
Association Allocation
TOTALS
Flow
(mg)
72.975
37.775
63.289
205.220
165.726
117.804
41.954
78.870
71.658
222.600
30.400
14.800
122.014
60.967
11.720
2.920
138.620
1388.137
30.471
314.790
18.573
13.456
66.824
3291.563
DATA FROM CO-PERMITTEE MEMBERS
Jan-06
TN Conc.
(mg/I)
4.95
4.05
3.86
4.25
3.09
2.60
8.95
3.99
1.63
4.10
2.29
13.10
7.00
7.43
3.03
31.68
2.48
4.04
TN Disch
(Ibs)
3,013
1,276
2,037
7,274
4,271
2,554
3,132
2,625
974
7,612
581
1,617
7,123
3,778
296
Flow
(mg)
63.494
29.333
57.792
184.800
146.944
109.623
36.836
59.610
58.057
162.320
41.630
10.800
97.635
51.084
10.228
771 2.382
Feb-06
TN Conc.
(mg/I)
4.96
3.54
5.43
4.46
2.47
1.58
3.97
3.18
1.93
5.02
3.46
9.4
6.97
6.86
3.14
28.38
2,867 113.489 3.33
46,771 1253.720 3.49
2.03 516 27.048 2.49
2.76
2.69
3.10
5.12
11.09
4.04
AVERAGE CONCENTRATION
4.06
111,517
15.98
3.46
2856.038
3.74
2,627 65.076
866 29.956 6.29
2,617 54.932
7.16
6,874 194.370 4.28
3,027 151.342 2.12
1,445 153.585 1.62
1,220 44.995 3.95
1,581 50.300 4.53
934 56.620 2.35
6,796 189.810 5.36
1,201 2.830 2.32
847 11.700 4.4
5,676 106.710 5.37
2,923 35.950 12.56
268 11.311 3.86
564 2.790 14.73
3,152 123.418 4.38
36,492 1386.498 1.94
562 29.615 2.56
5,839 243.620 2.97
332 14.982 3.05
1,501
12.245 10.77
1,717 66.265 2.21
89,061
3038.920
3.08
3,280
6,938
2,676
2,075
1,482
1,900
1,110
8,485
55
429
4,779
3,766
364
343
4,508
PAGE 2 OF 4
February 25, 2006
Apr-06
Flow TN Conc. TN Disch.
31.043 7.78 2,014
54.270
8.20 3,711
195.300 3.22 5,245
147.240 2.61 3,205
132.745 2.38 2,635
45.451
2.83
1,073
45.910 6.67 2,554
49.120 2.76 1,131
178.170 3.30 4,904
10.570 1.57 138
10.700 8.70 776
99.596 4.72 3,921
26.337 21.02 4,617
8.928 2.52 188
2.862 7.64 182
124.089 3.90 4,036
22,433 1305.886 1.880 20,475
632 28.197 3.08 724
6,034 205.140 3.08 5,269
381 15.426 4.45 573
1,100 10.788 10.71 964
1,221 58.570 _ 2.96 1,446
78,183 2850.383 72,526
3.05

TOTAL NITROGEN DISCHARGE MONITORING REPORT
I 1 1 i - --
NEUSE RIVER COMPLIANCE ASSOCIATION
YEAR-END REPORT FOR 2006
2006 - JAN THROUGH DEC
DATA FROM CO-PERMITTEE MEMBERS
FACILITY
Town of Apex
Town of Benson
Butner/SGWSA
Cary North
Flow
(mg)
70.948
May-06
TN Conc.
(mg/I)
5.140
TN Disch.
(Ibs)
Flow
(mg)
Jun-06
TN Conc.
(mg/I)
TN Disch.
(Ibs)
Flow
(mg)
3,041
81.592
4.220
Cary South
County of Johnston.
Town of Clayton
Contentnea MSD
Town of Farmville
City of Goldsboro Pipe 01
City of Goldsboro Pipe 020
Town of Kenly
City of Kinston (Peachtree)
City of Kinston (North)
Town of LaGrange
Neuse Colony
City of New Bern
40.098
57.337
192.820
148.893
112.454
44.259
59.380
65.195
224.170
City of Raleigh
City of Raleigh -Smith Cr.
City of Wilson
Town of Zebulon/Raleigh-Little
Unifi-Kinston, LLC
MCAS Cherry Point
Association Allocation
TOTALS
0.000
11.500
103.273
24.366
11.082
3.289
1.98
8.3
4.20
2.50
2.41
662
3,974
6,754
3,104
2,260
3.77 1,392
4.231- 2,095
6.81 3,703
3.36 6.282
0.00
8.50
3.9900
16.53
4.41
20.91
0
815
3,437
3,359
408
37.713
69.667
251.100
142.200
135.489
46.949
62.280
74.103
246.030
12.390
11.800
92.840
40.412
10.448
3.91
6.68
3.65
1.86
2.36
1.97
8.70
1.04
3.14
1.70
4.57
2.880
8.96
3.60
574
3.331
123.004 3.350 3,437
1342.059 1.46 16,341
28.566 3.01
227.870
17.781
11.680
59.101
3.43
4.21
11.68
3.00
717
113.062
1478.998
32.981
12.52
2,872
1,230
3,881
7,644
2,206
2,667
67.60
37.13
66.51
216.38
127.81
111.85
771
4,519
643
6,443
176
450
2,230
3,020
314
42.71
55.57
61.86
254.32
35.48
9.80
93.24
51.61
16.93
348
3.443
3.240 3,055
2.21 27,260
3.19 877
139.441
1350.16
30.82
6,518
624'
1,138
1,479
0
235.050
21.369
14.291
67.006
4.05 7,939
3.11 554
14.29
2.39
1,703
1,336
0
232.52
14.943
12.960
61.778
AVERAGE CONCENTRATION
2.90
72,114
3,281.101
3.00
82,138
3,094.913
PAGE3OF4
February 25, 2006
Jul-06
Aug-06
TN Conc.
TN Disch.
Flow
TN Conc.
TN
(mg/I)
(Ibs)
(mg)
(mg/I)
Disch.
(Ibs) _
3.08
1,737
65.514
2.94
1,606
1.63
505
34.466
2.18
627
6.15
3,411
60.391
7.94
2.87
_ 5,179
205.840
3.40
3,999
5,837
2.16
2,302
121.799
2.08
2,113
1.70
1,586
102.561
2.26
1,933
2.78
990
42.086
1.81
8.72
4,041
47.650
9.54
635
2.92
1,506
3,791
47.570
5.35
2,123
2.37
5,027
210.380
1.17
4,825
5.30
433
9.500
2.70
277
214
5.59
4,347
56.383
3.28
1,542
2.06
887
44.353
5.39
1,994
3.76
531
20.201
4.57
770
12.43
357
3.413
10.01
285
3.35
3,896
34.736
3.58
1,037
1.54
17,341
1353.532
1.94
21,900
3.57
918
29.252
3.89
949
4.08
7,912
182.430
5.58
8,490
3.94
491
15.637
4.26
556
1,012
11.08
1,198
13.060
9.29
2.78
1,432
60.427
2.69
1,356'
0
_
0
66,231
2,789.521
67,871
2.57
_
2.92

Town of Apex
Town of Benson
Butner/SGWSA
Cary North
Cary South
County of Johnston.
Town of Clayton
Contentnea MSD
Town of Farmville
City of Goldsboro Pipe 01
City of Goldsboro Pi • e 02
Town of Kenly
City of Kinston (Peachtree)
Cit of Kinston North
Town of LaGrange
Neuse Colon
City of New Bern
City of Raleigh
Cit of Raleigh -Smith Cr.
City of Wilson
Town of Zebulon/Raleigh-Littl=
Unifi-Kinston, LLC
TOTAL NITROGEN DISCHARGE MONITORING REPORT
L
NEUSE RIVER COMPLIANCE ASSOCIATION
YEAR-END REPORT FOR 2006 February 25, 2006
2006 - JAN THROUGH DEC
DATA FROM CO-PERMITTEE MEMBERS
Sep-06 Oct-06 Nov-06 Dec-06
FACILITY _ Flow TN Conc._ TN Disch. _ Flow
Ibs (mg
PAGE 4 OF 4
65.108 4.65
33.386
65.935
217.200
122.250
115.602
70.070
75.980
293.390
41.020
13.100
207.203
27.775
51.098
1326.619
30.273
297.100
17.246
13.040
MCAS Cherry Point 62.430
Association Allocatiorl
TOTALS 3,193.958
AVERAGE CONCENTRATION
2,525
6,533
26,775
3.40 1,770
0
81,169
69.401
31.426
65.828
215.760
147.126
42.605
49.500
51.730
192.560
48.640
11.600
0.000
154.595
16.337
3.642
0.000
1345.279
31.702
223.460
15.430
62.037
TN Conc.
Flow
Ibs (mg) (mg/I) (Ibs) (mg)
4.15 2,402 3.85
4.70 1 7
7.70
3.52
2.10
0.00
4.68
3.90
2.81
3.01
4.87
2.42
TN Disch.
1,232
4,227
6,334
2,577
1,043
1,219
1,891
6,034
31,527
796
9,076
311
77,794
90.079
47.822
84.227
235.800
181.650
179.337
55.739
81.180
79.490
335.330
51.570
16.200
0.000
232.840
23.250
100.831
1437.713
39.725
346.570
27.100
TN Conc.
1.93
1.30
3.09
2.88
2.41
3.66
4.33
3.50
TN Disch.
2,892
1,264
5,198
6,942
2,924
1,944
1,436
1,950
28,897
1,213
12,515
93,507
79.282
44.896
66.485
236.220
157.635
162.315
48.100
67.630
66.530
316.620
15.800
224.170
27.063
160.699
1382.556
35.682
336.660
22.432
17.937
TN Conc.
(mg/I)
2.14
1.49
6.34
3.41
1.50
3.02
4.68
TN Disch.
6,521
2,813
2,017
2,543
1,923
2,386
10,721
17,296
899
13,140

2007 Blue Ribbon Water Quality Trading
Awards
Nomination:
Neuse River Compliance Association
North Carolina
Contact Information:
Neuse River Compliance Association
PO Box 1562
Apex, NC 27502-3562
919/387-3478
Cindy Finan, Executive Director
Email: cfinan�7u,nc.rr.com
Program created by:
The Lower Neuse Basin Association
and the
NC Department of Environment, Health and Natural Resources -
Division of Water Quality

Background
The Neuse River is approximately 150 miles long with its basin encompassing 6,192
square miles. The basin covers all or part of 19 counties and has a population of 1.3
million people. (See Figure 1.) The Neuse River Estuary is a shallow estuary that feeds
directly into the Albemarle -Pamlico Sound system which is the United States' second
largest estuarine complex and a key fisheries nursery for the mid -Atlantic coastal region.1
The estuary has experienced major eutrophication issues since the early 1970's. The
increased nutrient loading to the estuary has caused major algae blooms and fish kills.
The publication of the book "And the Waters Turned to Blood" by Rodney Barker in
1997 brought considerable attention to the plight of the Neuse River Estuary. When
initial research indicated that phosphorus was the problem, the State of North Carolina
initiated a phosphorus detergent ban in 1987. Problems in the estuary continued and
further research pointed the finger at nitrogen as the limiting factor.
The management strategy for the Neuse River Estuary included a Total Maximum Daily
Load (TMDL) that was adopted in 1999. Studies showed that a reduction of 30% was
necessary in the Total Nitrogen loading, with a deadline of 2003. The point source
dischargers in the basin were given an allocation of 1,640,000 pounds of Total Nitrogen
in order to meet this reduction. There was no allocation reserved for new or expanding
facilities. Allocations were given based on the permitted flows that existed in the permits
in 1995. This caused a great inequity in the distribution of the Total Nitrogen allocations,
' Paerl, Hans W., Lexia M. Valdes, Alan R. Joyner and Michael F. Piehler; University of North Carolina at
Chapel Hill, Institute of Marine Science. Martin E. Lebo, Weyerhauser Corp. "Environmental Science and
Technology", 2004, 38, 3068-3073
Page 2of16

where some dischargers had permits for much more flow than they would ever need and
others were caught at or near capacity, with little or no room for growth.
Figure 1.
Falls Lake
Durha
Cary �
1640.
Raleigh
r. i,
Smithfield
Goldsboro
Kinston New Bern
Wilson
Neuse River
Havelock
Pamlico Sound
A river basin group called the Lower Neuse Basin Association existed at the time that the
TMDL was developed. This group was primarily a basin coalition that conducted
comprehensive basin -wide monitoring of the river and it's tributaries in order to comply
with their individual NPDES permits. Due to the inequities caused by the distribution of
the allocations, the "Neuse Rules" that were developed by the State, allowed for the
formation of compliance groups by the major point source dischargers. The concept of
the compliance group was to allow a group of dischargers to meet a collective limit, thus
allowing them to pursue reduction strategies where the most benefit could be enjoyed at
the lowest cost. In 1996, the General Assembly of the State of North Carolina
appropriated 2 million dollars for the Lower Neuse Basin Association, to provide grants
Page 3 of 16

to dischargers in the basin to help them pursue nitrogen reduction strategies at their
plants, or to remove wastewater discharges from the river.
From the members of the Lower Neuse Basin Association came an altruistic group of
dischargers who became the Neuse River Compliance Association (NRCA). The NRCA
is a non-profit, 501 c (3) organization. They worked with the State and were given the
first permit issued to a compliance association in the United States in December, 2002.
The members of the NRCA and their respective allocations are listed in the excerpt of the
Annual Report for 2005 which is included in AppendixA. For clarification purposes, the
members of the Lower Neuse Basin Association and the Neuse River Compliance
Association are essentially the same, but the State required that a new non-profit be set up
to receive the permit. The NPDES permit, NCC000001, applies only to Total Nitrogen
and gives the group a collective limit for the number of pounds of TN that can be
discharged by the members in a year. Each member has an allocation for TN that is
expressed in two ways; 1) pounds of Total Nitrogen at the point of discharge and 2)
pounds of Total Nitrogen at the estuary (which is the discharge pounds multiplied by the
transport factor.) Under the group permit, if the group complies with the collective TN
limit, then all of the members are deemed by the State to be compliant with their TN
limit. If the NRCA were to violate its TN limit for the year, the group would be subject
to enforcement from the State and the bylaws of the Association would reflect that
violation back to the member(s) who were in noncompliance with their individual
allocation. Under the NRCA Bylaws, the fine paid by the group would ultimately be
charged back to the offending members.
Page 4 of 16

Accomplishments of the NRCA
To date the members of the Neuse River Compliance Association have spent in excess of
50 million dollars on nutrient reduction at their plants. The deadline of a 30% reduction
by 2003 was met and exceeded by more than three years. The Total Nitrogen loading
from the group in 2000 showed a reduction of 46% over the 1995 levels. By the end of
2001, the group had reduced their nitrogen loading by 53%. As of 2005, the reduction
reported by the group was up to 68%! It should be noted that in 2005 the group took on
two new members, Unifi-Kinston, LLC and the Marine Corps Air Station at Cherry
Point. The collective discharge data for the NRCA is shown in Table 2. A comparison
of the discharge from the original group of members and with the addition of the two new
members in 2005 is reflected in the table.
Table 2: NRCA Total Nitrogen Discharge by Year
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
2005*
98.837*
522,171*
*Loading in pounds from the original members, if you exclude values for new 2005
members: MCAS Cherry Point and Unifi-Kinston, LLC.
Total permitted allocation w/o new members:
Estuary Discharge w/o new members:
% of permitted discharge
1,073,115
522,171 pounds
48.66%
Page 5 of 16

Total permitted allocation w/ new members: 1,137,171
Estuary Discharge w/ new members: 566,627
% of permitted discharge: 49.83%
Mandated Reduction by 2003: 30%
Reduction Demonstrated by NRCA over 1995 Loading: 68%
Reduction Demonstrated by Original NRCA Members: 70%
NRCA Trading Dynamics
The Neuse Rules allow dischargers that need more allocation to acquire it from others
who have excess allocation. The rules for the Neuse Basin do not allow for point sources
to trade with non -point sources at this time. No discussion of point source/non-point
source trading is contained in this nomination package. Trading among point sources
encourages economic efficiency in meeting the overall nitrogen limit in the Neuse, based
on the assumption that dischargers will make trades to benefit both parties while still
meeting the required reduction. The NRCA has no authority over trades at this time,
other than the fact that the bylaws prohibit the selling of nitrogen to a non-member
(nitrogen allocation cannot leave the group). However, members are free to buy nitrogen
from non-members (nitrogen may be brought in from non-members.) One of the keys to
achieving benefits from trading is that there is a "transport factor" for nitrogen assigned
to each discharger. The State established Nutrient Management Zones with associated
transport factors to the various sub -basins of the Neuse. (See Figure 2.) The concept of
the transport factor is not unique to the NC strategy, but works on the premise that
nitrogen gradually diminishes as it travels down the Neuse to the estuary. A discharger
located further upstream may discharge more nitrogen without having an adverse effect
on the estuary. For example, one pound of nitrogen discharged directly into the estuary is
assumed to have the same effect as two pounds discharged in the Raleigh area. It would
Page 6 of 16

follow that rather than spending a certain amount to reduce its nitrogen in the Raleigh are,
that same amount would be better spent to reduce a discharge directly into the Neuse
estuary and would achieve twice the benefit. In exchange, a discharger in the Raleigh
area who provides funds to reduce a discharge at the estuary would receive the nitrogen
allocation that the discharger in the estuary was no longer discharging.
Figure 2: Nutrient management zones for the Neuse River basin.
The State of North Carolina has encouraged the NRCA to conduct trading only in the
permanent sale of nitrogen that can be reflected in the individual permits of the
dischargers. Due to the fact that nitrogen allocation is a scarce commodity in North
Carolina and the management strategy did not reserve any allocation for growth in the
basin, dischargers are simply not going to sell nitrogen permanently. There have been
Page 7 of 16

only two official sales/trades, involving allocation that was purchased from a system that
went to land application of the wastewater. The sales have been controversial, have been
highlighted by considerable media attention and the State has not allowed the acquired
nitrogen to be added to the NRCA permit as of this date. As a complicating factor, the
environmental groups that advocate for the Neuse River do not understand the concept of
trading and want any and all reductions to be experienced by the river. They put constant
pressure on the State to limit trading, even though it is provided for in the rules, and fight
to have every pound of nitrogen that is removed from the river to be removed forever.
These groups fail to recognize the significant achievements of the NRCA and the
extraordinary reductions that have been achieved by these point sources. The 30%
reduction that was identified was mandated for non -point sources as well, but there is
little or no pressure on the non -point sources to accomplish the required reductions and
there is little data to document what reductions have taken place from non -point sources.
Due to the limitations that have been discussed previously, the NRCA has had to been
extremely innovative in managing nitrogen within the group. The NRCA has specific
bylaws and enforcement policies that prevent members from gaining the protection of the
group permit if they are not making necessary improvements to their plant and
operations. The enforcement policy requires members who exceed their individual
allocation to pay an assessment to the group that doubles each year. The monetary basis
for the assessment is the amount that the discharger would pay the State of NC to
purchase nitrogen from the Ecosystem Enhancement Project. The first year, the member
would pay 25% of this amount, 50% the second year, up to the full amount. If the
Page 8 of 16

member is reluctant to make necessary improvements to the plant or fails to pay the
assessment, the group can vote to remove them from membership, which would subject
them to enforcement from the State of NC for violation of their allocation. In this way
the group uses peer pressure to encourage continuous improvement among the
membership. In the same way, the group provides technical assistance to members who
could benefit from improved operational strategies. Due to the diversity of the
membership in terms of size and resources, the larger members who have more resources,
assist the smaller members who may be lacking in knowledge or funds. The best aspect
of the enforcement policy as an incentive for compliance, is that any assessments
collected from the members are held in escrow and are returned (in the amount of 80%)
to the member once compliance is achieved. The group does retain 20% of these funds
as an administrative cost. This seems far more palatable to the dischargers than paying
fines to the State without hope of getting any of it back!
A good example of the effectiveness of the group compliance approach is the situation
that was experienced with a new member to the NRCA in 2005. The Marine Corps Air
Station at Cherry Point had been exceeding its nitrogen allocation for some time before
joining the NRCA. The base joined the NRCA in order to lease nitrogen for a three to
five year period to allow them to comply with their permit while the plant was upgraded.
The terms of their membership and their agreement to lease nitrogen, showed a major
commitment on the part of Cherry Point to make the improvements needed to meet their
allocation. The lease agreement called for the cost of the lease to increase each year,
providing an incentive for them to make improvements in a timely manner. With these
Page 9 of 16

incentives in place, the Marine base began a comprehensive training program for its
operators and made some substantial operational improvements to optimize their
treatment process. In the end, Cherry Point never did violate their individual allocation
and did not need the allocation they had leased. They continued to pay their lease
payments, in good faith and have pursued the necessary improvements to their plant.
One important feature of this lease agreement, was that the membership determined that
the funds paid by Cherry Point would be earmarked for projects that would directly
benefit the Neuse River and nutrient management. The group voted to use the funds to
partially fund a reuse project for another member that will essentially divert that
member's entire wastewater discharge to a nursery operation during the summer months,
thus removing this loading from the river when the stress is the greatest. If Cherry Point
were not a member of the NRCA, it is doubtful that any regulatory agency could have
compelled it to pay a penalty assessment, and even if a penalty was paid, the funds would
not have been used to benefit the Neuse.
Two smaller members of the NRCA are still pursuing funding for necessary capital
improvements to their plants in order to meet their nitrogen allocations. In the mean
time, the group monitors their progress, requires them to make regular reports to the
group and provides short term leases opportunities for them to avoid the enforcement
assessments that the group's enforcement policy requires. In some respects, the members
would rather negotiate a short-term lease for needed nitrogen, rather than to fall subject to
"enforcement" by the group. Even though lease costs cannot be recouped by the member
Page l0 of 16

(as they can from the enforcement policies), it is often cheaper and better to be
considered "in compliance."
Accounting Procedures and Evaluation of the Program
The NRCA is required to report to the State of NC, Division of Water Quality every six
months. The group is required to submit two reports to the State each year that include
the total loadings from each member, to determine compliance with the permit, along
with other aspects of the group's activities. The Midyear Report is due on Aug. 31 of
each year, which includes the last 12 months of Total Nitrogen data for each member,
reported as Total Monthly Flow, Monthly Average Total Nitrogen and the loading
expressed as pounds for each month and totaled for the period. This report is not used for
compliance purposes, but is used to give the State a running 12 month snapshot of the
group's loading. The Annual Report is required to be submitted by February 28th of each
year and includes all data (as described above) for the calendar year along with a survey
of member's activities. This report includes information regarding regionalization, a
summary of all purchases, sales, trades, leases or other transactions affecting the
allocations of the members, enforcement updates, changes in membership, control
strategies for the coming year, a summary of measures taken to control TN for the last
year (for each member),and an assessment of progress made and a description of other
efforts or projects for the coming year(s). The fact that all of the activities of the
association are governed and reported under an NPDES permit make this program fairly
unique. This type of reporting and its subsequent review by the State provides
transparency for all activities of the NRCA and any leases or trades that might take place.
The State discourages temporary leases and encourages permanent trades that then can be
Page 11 of 16

reflected in the individual NPDES permits. The State uses the NRCA permit as a means
of tracking and accounting for all Total Nitrogen Allocations of the members. The
NRCA reports are submitted under the conditions of the NPDES permit and are therefore,
public information and subject to public scrutiny as well. A copy of the data portion of
the 2005 Annual Report is included in Appendix A. The narrative portion of the report is
too lengthy to be included here. The Executive Committee and Executive Director of the
NRCA are in contact with the staff of the Division of Water Quality on a continuing basis
and meetings are held periodically to discuss issues that affect the permit and the group.
The uniqueness of this program necessitates constant communication and the utmost
cooperation between the NRCA and the State. We are essentially making this up as we
go along, so communication and cooperation are essential to the success of the program
and to the development of future strategies to enhance membership in the NRCA and the
benefit to the Neuse River.
Collaboration and stakeholder involvement have always been a part of the NRCA. By its
very nature, it includes representatives from 20 members (large municipalities, small
towns, a private utility, industry and a military base.) The diversity of the membership
and the various representatives and elected officials who serve as the delegates, deliver a
variety of opinions and viewpoints. Due to the state -issued permit, there are
opportunities for public input, notice and hearing involving most association activities.
The association has kept the conservation groups informed of their efforts and has
supplied them with copies of the annual reports. The group is actively involved with two
different universities in the North Carolina University System to participate in research
Page 12 of 16

and the sharing of data on the Neuse Estuary and to draw on the expertise of academia.
These research efforts are explained in a subsequent section of the nomination.
Actual or Anticipated Environmental Improvement
To reiterate the actual environmental improvement that has been experienced by the
Neuse River, thanks to the NRCA: in 1995 the point sources who make up the current
membership of the NRCA discharged 1,784,130 pounds to the Neuse River Estuary. The
permit that was in force in 2003 and 2004, permitted the group to discharge 1,073,115
pounds of Total Nitrogen. The group reported a discharge of just 722,374 pounds or 67%
of the permitted load. In 2004, the members decreased this amount by 163,821 pounds,
discharging 558,553 pounds of nitrogen (52% of the permitted limit.) In 2005 the group
discharged 566,627 pounds of TN, or 50% of its permitted limit (which increased to
1, 137,171 due to the addition of two new members and their allocations.) The total
impact on the Neuse was the reduction of the Total Nitrogen load by 68% or a total of
1,217,503 pounds in 2005 over what was discharged in 1995. If you look at the
cumulative reduction since 1996, the NRCA has kept 7,337,508 pounds of TN out of the
Neuse River from what was being discharged during the baseline year of 1995. One can
only imagine the benefits to the river and estuary from a reduction of this magnitude.
Actual or Expected Economic Benefits
The economic benefits that have been realized by the Neuse River and its estuary and the
State of North Carolina thanks to the efforts of the NRCA are difficult to quantify. A
great deal of money has been spent by the municipalities and industries that hold
membership in the NRCA. It is estimated that over fifty million dollars has been spent
Page 13 of 16

on upgrades to wastewater facilities and to construct new facilities to remove nitrogen
from the receiving waters. The conditions in the Neuse River and the estuary have
greatly improved, and the NRCA is now participating in research being conducted by the
University of North Carolina at Chapel Hill, Institute of Marine Science to further
document the recovery of the estuarine system. The NRCA is supporting this research, in
the amount of $65,000 per year, to assist in this effort. In addition to the economic
benefits that have undoubtedly been experienced by the aesthetic improvements and
public perception of the river and the coast, the other major economic benefit is the
growth that the NRCA has now provided for in the eastern part of North Carolina. The
development of the TMDL for the Neuse, mandated a 30% reduction in nitrogen loading
from point sources. As mentioned previously, there were no provisions for growth in
terms of new or expanding wastewater facilities. The 68% reduction that has been
realized by the NRCA has bought the State of North Carolina some room to grow, in a
part of North Carolina that is trying to grow very rapidly.
The improvements made by NRCA members and the fact that many of our members are
treating well below what is accepted as Best Available Technology, have provided an
excess allocation that stands to allow some growth in the basin that otherwise would have
been impossible. The NRCA is currently participating in negotiations with the State that
might allow the members of the NRCA to leverage some additional flows for their
facilities, based on their ability to treat below BAT levels and based on the unused
portion of the allocation that they group holds. The group shares information and
promotes reuse projects that will also remove flow and nitrogen from the wastewater
Page 14of16

discharges, that could allow for more growth for the towns and cities of eastern North
Carolina. The NRCA is anxious to pursue point source, non -point source trading as a
way of providing additional reductions from agriculture and non -point sources that could
help their town provide more growth, while protecting the river and the estuary. The
group is currently supporting research by North Carolina State University into alternative
methods of providing nutrient offsets, that might allow municipalities to expand buffers
within the basin, purchase conservation easements and construct stormwater retrofit
projects that would benefit the river and the estuary. The group hopes that by conducting
this research and showing the benefit and cost of other alternatives, that the
Environmental Management Commission of NC could be persuaded to add some
additional measures to provide for this type of non -point source, point source trading.
Conclusion
This group has had to been innovative, cooperative and altruistic in their struggle to
reduce nitrogen loadings to protect the Neuse, while meeting the pressures of growth and
economic development. The have proven their ability to meet the challenge of a
mandated reduction in nitrogen loading, by working together and sharing information and
resources and accomplishing what no one though was possible. They take their
obligation to the Neuse very seriously and conduct additional research and monitoring to
look for new ways to improve the estuary and to optimize nitrogen removal at their
plants. Their efforts have gone unnoticed and unappreciated by the citizens of North
Carolina, thanks to conservation groups that fail to acknowledge the effort and
commitment they have demonstrated. The NRCA has not simply used nutrient trading in
Page 15 of 16

its most traditional sense, but has looked for innovative ways to bring new tools to the
trading tool box. To be a member of the NRCA is a much bigger commitment than just
agreeing to buy some nitrogen when you need it. This group constantly strives to bring
all its members up to a standard of excellence that provides the best treatment and the
cleanest reclaimed water to protect the Neuse River and its estuary.
Appendix A- Excerpt from the NRCA Annual Report for 2005
See Appendix A -File Attached
Page 16 of 16

TOTAL NITROGEN DISCHARGE MONITORING REPORT
NEUSE RIVER COMPLIANCE ASSOCIATION
YEAR-END REPORT FOR 2005
2005 - JAN THROUGH DEC
NPDES PERMIT NO: NCC000001
PAGE 1 OF 4
February 22, 2006
FACILITY
END OF PIPE
Permit
2005
Member TN
Member TN
Town of Apex
Town of Benson
DHHS Umstead Hosp. (Butner)
Cary North
Cary South
NPDES Permit
NC0064050
NC0020389
NC0026824
NC0048879
NC0065102
County of Johnston.
Town of Clayton
Contentnea MSD
Town of Farmville
City of Goldsboro 01 & 02
NC0030716
NC0025453
NC0032077
NC0029572
NC0023949
Flow'
(MGD)
3.60
3.00
3.50
12.00
16.00
4.99
2.50
2.85
3.50
16.80
Avg Flow
(MGD)
2.260
0.978
1.935
6.451
5.045
3.467
1.342
1.981
2.060
6.092
Allocation
(Ibs/Yr.)
40,547
33,790
58,599
143,246
180,211
67,467
21,400
32,100
42,211
198,118
Discharge
(Lbs/Yr.)
31,622
14,325
31,820
66,603
35,650
22,299
11,452
34,602
18,804
61,776
Transport
Factor
50%
50%
10%
50%
50%
50%
50%
70%
50%
70%
Temporary
Lease
Agreement
-1800
1800
Original
Estuary
Allocation
Town of Kenly
City of Kinston (Peachtree
City of Kinston (North)
Town of LaGrange
Neuse Colony
City of New Bern
City of Raleigh
Wake Forest
Cit of Wilson
Town of Zebulon
NC0064891
NC0020541
NC0024236
NC0021644
NC0064564
NC0025348
NC0029033
NC0030759
NC0023906
NC0079316
0.63
6.75
4.50
0.75
0.75
6.50
60.00
6.00
14.00
1.85
Unifi-Kinston, LLC
MCAS Cherry Point
Association Allocatiot
NC0003760
NC0003816
3.60
3.50
NRCA TOTALS
0.910
0.364
3.516
1.607
0.427
0.072
4.318
46.178
0.710
8.543
0.580
7,096
76,026
50,684
8,447
8,447
52,937
676,417
67,579
157,684
22,455
0.756
2.146
35,193
39,421
48,879
10,617
53,191
37,421
4,639
5,564
37,156
358,074
5,463
105,181
50%
70%
70%
70%
50%
100%
50%
50%
50%
9,751 50%
16,460 70%
32,9241 100%
0
50%
1800
-1800
20000
-20000
20,274
16,895
5,860
71,623
90,105
33,734
10,700
22,470
21,106
138,521
ESTUARY
Adjusted TN
Allocation 2005
(lbs/Yr.)
2005 TN
Discharge
20,274
(Lbs/Yr.)
15,811.0
3,548
53,218
35,479
5,913
4,224
52,937
338,209
16,895
5,860
71,623
90,105
31,934
10,700
24,270
21,106
138,521
5,348
53,218
33,790
78,842
11,227
24,635
39,421
24,440
35,479
5,913
4,224
52,937
338,209
33,790
78,842
11,227
7,162.5
3,182.0
33,301.5
17,825.0
11,149.5
5,726.0
24,221.4
9,402.0
43,243.2
5,308.5
37,233.7
26,194.7
3,247.3
2,782.0
37,156.0
179,037.0
2,731.5
52,590.5
4,875.5
22,835
59,421
4,440
11,522.0
32,924.0
0.0
1,137,171
THIS MONITORING REPORT HAS BEEN COMPILED FROM CO-PERMITTEE MEMBERS MONTHLY DISCHARGE MONITORING
REPORTS. I CERTIFY THAT IT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
177.571 101.739
Net 0
HAYWOOD M. PHTHISIC, CHAIRMAN, NEUSE RIVER COMPLIANCE ASSOCIATION
1. Flow from Nutrient Management Strategy with subsequent changes
3. Formerly Burlington Industries
Temporary lease agreements between Una -Kinston LLC and Contentnea MSD, Kenly
1,137,171 566,627
DATE
2. Goldsboro Pipe 02 is from Constructed Wetland
I -
and Johnston Co. and MCAS Cherry Point and NRCA are reflected in the es uary allocation
TN discharge is calculated from DMR monthly flow and TN concentration. The product is rounded to whole number.
THIS REPORT PREPARED BY CINDY FINAN, NRCA EXECUTIVE DIRECTOR
above.

TOTAL NITROGEN DISCHARGE MONITORING REPORT
NEUSE RIVER COMPLIANCE ASSOCIATION
YEAR-END REPORT FOR 2005
2005 - JAN THROUGH DEC
FACILITY
Town of Apex
Town of Benson
Flow
(mg)
68.511
33.263
DHHS Umstead Hos. (Butner) 58.757
Cary North 212.351
Cary South 163.649
County of Johnston. 117.804
Town of Clayton 42.089
Contentnea MSD
Town of Farmville
54.850
61.358
City of Goldsboro Pipe 01 186.200
City of Goldsboro Pipe 02 29.560
Town of Kenly
8.900
City of Kinston (Peachtree) 92.093
City of Kinston (North)
Town of LaGrange
Neuse Colony
City of New Bern
City of Raleigh
Wake Forest
City of Wilson
Town of Zebulon
Unifi-Kinston, LLC
MCAS Cherry Point
Association Allocatiori�- 0
45.833
12.072
1.695
117.280
1461.151
19.723
308.400
21.015
23.760
DATA FROM CO-PERMITTEE MEMBERS
Jan-05
TN Conc. TN Disch
(mg/I) (Ibs)
5.20 2,971
4.84 1,343
6.75 3,308
4.40 7,792
2.53 3,453
2.60 2,554
3.39 1,190
5.28
2,415
3.36 1,719
3.72 5,777
2.90 715
10.30 765
4.36 3,349
6.81 2,603
5.43 547
23.70 335
2.75 2,690
2.84 34,608
2.36 388
9,774
3.80
3.33 584
3.48 690
TOTALS
AVERAGE CONCENTRATION
70.060 7.53 4,400
3210.374
3.51
Flow
(mg)
65.567
28.308
60.575
192.081
153.972
109.623
35.152
48.860
58.495
164.870
23.430
11.300
89.335
35.283
10.961
107.070
1320.211
16.902
270.210
18.109
20.370
67.011
93,970 2909.658
Feb-05
TN Conc.
5.00
2.96
2.15
1.58
2.69
5.02
3.38
4.74
3.46
15.40
4.96
11.99
4.28
10.70
PAGE 2 OF 4
Mar-05 Apr-05
TN Disch. Flow TN Conc. TN Disch. Flow TN Conc. TN Disch.
(Ibs) (mg) (mg/I) (Ibs) (mg) (mg/I) (Ibs)
3,204 84.207
1,523 35.836
2,526' 74.064
4,742 229.422
2,761 181.133
1,445 153.585
789 42.109
2,046
70.920
1,649 80.333
6,518 244.680
676 20.000
1,451 14.400
3,695 134.278
3,528 32.411
309 16.399
2,000 133.380
33,913 1536.333
369 22.432
9,645
1.6
6
354.350
26.895
1,408 24.190
3,046 70.563
89,435 3584.208
5.90
6.64
4.10
3.31
1.93
1.62
1.74
17.46
2.77
3.24
1.76
12.80
5.12
2.60
4.06
5.48
4,143 73.061: 4.41 2,687
1,985 34.270 3.73 1,066
2,533 61.740 4.21 2,168
6,333 210.602 3.57 6,270
2,916 163.710
2,075 132.745
611 42.763
10,327 70.200
1,856 76.870
6,612 212.270
294 26.590
1,537 12.900
5,734 146.835
2,657 52.679
607 17.600
691 2.062
3,259 128.050
34,083
1428.711
486 18.795
11,998 345.330
1,229 22.861
2,199 24.040
3,507, 66.930
2.08 2,840
2.38 2,635
2.55 909
8.94 5,234
3.39 2,173
2.99 5,293
1.40 310
6.10 656
6,196
7.88 3,462
3.28 481
17.33 298
2.39 2,552
2.26 26,929
2.78 436
5.88 16,935
3.01 574
14.98 3,003
6.13 3,422
0
107,672 3371.614 96,529
3.69 3.601 3.43

TOTAL NITROGEN DISCHARGE MONITORING REPORT
NEUSE RIVER COMPLIANCE ASSOCIATION
YEAR-END REPORT FOR 2005
2005 - JAN THROUGH DEC
DATA FROM CO-PERMITTEE MEMBERS
PAGE 3 OF 4
February 22, 2006
FACILITY
Town of Apex
Town of Benson
DHHS Umstead Hos. (Butner;
Cary North
Cary South
County of Johnston.
Town of Clayton
Contentnea MSD
May-05 Jun-05
Jul-05
Flow
(mg)
69.106
25.544
52.446
189.103
149.017
112.454
35.505
61.680
Town of Farmville 69.645
City of Goldsboro Pipe 01 219.030
City of Goldsboro Pipe 020
Town of Kenly
City of Kinston (Peachtree)
City of Kinston (North)
0.000
12.300
116.165
55.141
Town of LaGrange 17.293
Neuse Colony 1.961
City of New Bern 111.770
City of Raleigh 1403.102
Wake Forest 18.940
TN Conc. TN Disch. Flow TN Conc.
(mg/I) _ (Ibs) (mg) (mg/I)
4.17 2,403 64.262 4.09
4.09 871 21.276 4.38
7.40 3,237 53.430 5.26
2.75 4,337 180.075 3.82
1.97 2,448 142.376 1.36
2.41 2,260 86.285 2.40
6.04 1,789 34.984 2.49
3.12 1,605 50.920 2.32
2.95 1,713 54.620 3.70
3.24 5,919 172.910 2.13
0.00 0 0.000 0.00
5.40 554 9.760 3.33
3.18
3,081 86.173 5.39
3.79 1,743 43.856 5.27
3.68 531 12.472 1.81
31.78 520 2.018 16.76
3.05 2,838 130.790 3.38
2.02 23,638 1346.857 2.72
3.20 505 17.746 2.19
City of Wilson 271.200
Town of Zebulon 19.061
4.31 9,748 211.690
2.91 463 16.219
Unifi-Kinston, LLC
21.130
MCAS Cherry Point 72.067
Association Allocation
11.95 2,106 22.030
3.60
TN Disch.
(Ibs)
2.192
777
2,344
5,737
1,615
1,727
726
985
1,685
3,072
0
271
3,874
1,928
188
282
3,689
30,553
324
6,356
Flow
(mg)
66.303
29.406
56.048
185.690
143.561
96.616
39.190
49.156
55.109
154.110
31.040
10.300
110.800
47.104
11.408
2.232
132.070
1392.265
17.546
218.270
6.61
5.04
5.02 3,017 64.227 3.68
0
894
926
1,971
0
TOTALS 3103.660
AVERAGE CONCENTRATION
2.91
75,326 2,824.976
3.06
15.229
26.588
56.019
72,116 2,946.060
TN Conc.
(mg/I)
4.35
5.72
5.00
3.57
1.83
1.80
0.91
5.04
3.09
2.06
2.38
2.70
5.68
9.41
1.11
Aug-05
TN Disch. Flow TN Conc. TN Disch.
(lbs) (mg) (mg/I) (lbs)
2,405 66.946 3.68 2,055
1,403 30.479 4.19 1,065
2,337 54.777 5.20 2,376
5,529 189.720 3.23 5,111
2,191 148.428 2.18 2,699
1,450 93.135 2.12 1,647
297 43.885 2.95 1,080
2,066 56.712 4.22 1,996
1,420 55.257 2.92 1,346
2,648 163.340 2.25 3,065
616 40.840 1.40 477
232 11.100 4.20 389
5,249 _ 98.669 4.31 3,547
3,697 43.239 13.67 4,930
106 12.950 4.00 432
26.75
1.94
1.59
1.78
3.44
2.91
4.42
4.12
498 2.319 9.62 186
2,137 117.210 2.85 2,786
18,462 1401.674 2.20 25,718
260 22.359 1.94 362
6,262 214.270 3.76 6,719
370 13.147 2.42 265
980 25.152 5.32 1,116
1,925 55.800 3.88 1,806
0 0
2.55
62,540
2,961.408 71,173
2.88

TOTAL NITROGEN DISCHARGE MONITORING REPORT
1
NEUSE RIVER COMPLIANCE ASSOCIATION
YEAR-END REPORT FOR 2005
2005 - JAN THROUGH DEC
PAGE 4 OF 4
DATA FROM CO-PERMITTEE MEMBERS
Sep-05
Oct-05
February 22, 2006
Nov-05
FACILITY
Town of Apex
Town of Benson
DHHS Umstead Hos. (Butner
Cary North
F,Cp_Dr South
County of Johnston.
Town of Clayton
Contentnea MSD
Town of Farmville
City of Goldsboro Pipe 01
City of Goldsboro Pipe 02
Town of Kenly
City of Kinston (Peachtree)
City of Kinston (North)
Town of LaGrange
Neuse Colony
City of New Bern
City of Raleigh
Flow
(mg)
59.909
24.301
49.590
172.200
132.210
69.095
40.027
40.720
50.613
138.730
33.220
8.520
TN Conc.
(mg/I)
4.17
6.01
4.07
2.45
2.04
2.23
1.53
4.44
2.87
2.88
1.03
9.00
77.720[ 5.82
41.6681 10.09
9.970 3.75
1.936 25.26
126.750
1361.500
Wake Forest
City of Wilson
Town of Zebulon
Unifi-Kinston, LLC
MCAS Cherry Point
Association Allocation
20,645
194.880
12.061
21.472
55.094
TOTALS 2,742.831
2.49
2.31
2.30
4.01
2.82
7.69
5.90
TN Disch.
(Ibs)
2,084
1,218
1,683
3,519
2,249
1,285
511
1,508
1,211
3,332
285
640
3,772
3,506
312
408
2,632
26,230
396
6,517
284
1,377
2,711
0
Flow
(mg)
65.950
26.278
54.839
192.200
146,816
76.361
42.631
77.020
63.753
173.660
43.880
9.630
118.384
65.154
10.972
2.274
187.790
1417.174
24.263
209.530
13.626
24.443
72.856
TN Conc. TN Disch.
(mg/I) (Ibs)
3.80
3.29
4.17
3.34
3.59
2.77
2.54
2.39
2.48
3.03
1.28
8.10
5.70
6.92
4.09
16.35
3.45
2.70
3.22
3.75
13.60
4.46
3.50
2,090
721
1,907
5,354
4,396
1,764
903
1,535
1,319
4,388
468
651
5,628
3,760
374
310
5,403
31,912
652
6,553
1,546
909
2,127
0
Flow
(mg)
TN Conc.
(mg/I)
61.592 5.08
26.175 3.43
54.990 5.59
185.700 3.47
144.960 2.87
84.576 2.10
42.091 3.37
59.050 3.47
54.861 3.32
164.030 2.75
39.490 1.66
9.470 19.00
89.136 4.58
TN Disch.
(Ibs)
2,609
749
2,564
5,374
3,470
1,481
1,183
1,709
Dec-05
Flow TN Conc. TN Disch.
(mg) (mg/I) (Ibs)
79.524
41.726
75.033
215.450
171.740
133.109
49.451
82.970
4.19 2,779
4.61 1,604
7.73 4,837
3.62 6,505
3.22' 4,612
1.78, 1,976
3.55 1,464
4.59 3,176
1,519
3,762
547
1,501
3,405
70.875
229.580
44.270
14.400
123.864
2.02 1,194
3.36 6,433
1.54 569
16.40 1,970
5.48 5,661
52.501 4.85
10.446 3.71
2.479 35.22
137.640 3.14
1388.540 3.05
26.178 2.44
2,124
323
728
3,604
35,320
533
71.759
13.218
2.941
146.430
1397.274
212.580 2.88
12.670 4.58
20.704 4.04
5,106
484
698
33.761
5.82 3,483
3.89 429
29.83 732
2.92 3,566
3.15 36,708
2.67 752
307.570
3.73
20.833 8.30
21.936 5.73
63.502_ 5.37
2,844
0
69.250 3.72
9,568
1,442
1,048
2,148
0
AVERAGE CONCENTRATION 2.96
67,670
3,119.484
3.25
84,670 2943.361
3.33
81,637
3416.964
3.60
102,656