NC0025712_Wasteload Allocation_19931123

NPDES DOCUMENT !;CANNING COVER SHEET
oak
NPDES Permit:
NC0025712
Hookerton WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Report
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
November 23, 1993
This document is printed on reuse paper - ignore any
content on the rezrerse side

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NC0025712
PERMITTEE NAME: Town of Hookerton
FACILITY NAME: Town of Hookerton WWTP
Facility Status: Existing
Permit Status: Renewal
Major Minor -Nl
Pipe No.: 001
Design Capacity: 0.06 MGD
Domestic (% of Flow): 100 %
Industrial (% of Flow): 0 %
Comments:
Facility currently under and SOC. Files are being circulated, will
forward effluent sheets when received.
RECEIVING STREAM: Contentnca Creek
Class: C-Swamp NSW
Sub -Basin: 03-04-07
Reference USGS Quad: F28NE (please attach)
County: Greene
Regional Office: Washington Regional Office
Previous Exp. Date: 00/00/00 Treatment Plant Class:
Classification changes within three miles:
None. Will forward treatment plant class when 5T4-* F V&WI L5
Requested by:
Prepared by: _
Reviewed by: d�
Sea ►i Goris Date: 9/21/93
Date:
Date:
23
Modeler
Date Rec.
#
FK
4/2.219 3
74,0o
Drainage Area (mil ) ?)
Avg. Streamflow (cfs):
7Q10 (cfs) 3; Winter 7Q10 (cfs) 30Q2 (cfs)
Toxicity Limits: IWC % Acute/Chronic
Instream Monitoring:
Parameters c ,* v . riA6,,, c1tsJr-tea 3 . CAI")u �v,t
L1'4 to ,00Above
-116411s ( (t(i')
Upstream ✓ Location xtw,� la alit e n. hT.:a c`i
Downstream Location N u, ?.3
Effluent
Characteristics
BOD5 (mg/1)
3 0
NH3-N (mg/1)
monr rtorc
D.O. (mg/1)
rn 0Nt7.17
TSS (mg/1)
i n
F. Col. (/100 ml)
z 0
pH (SU)
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WASH NGTONEOFFICE
Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
FACT SHEET FOR WASTELOAD ALLOCATION
Town of Hookerton W
NC0025712
Domestic - 100%
Existing
Renewal
Contetnea Creek
C - Swamp NSW
03-04-07
Greene
Washington
Goris
9/22/93
F 28 N E
NOV 0 51993
D. E. M.
Request # 9 %
aste Water Treatment Pt,�
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
14OV 8 1G° 3
TECHNICAL sUPPORi ORANCH
Stream Characteristic;
USGS #
Date:
Drainage Area (m12): 733
Summer', Q10 (cfs): 31
Winter 7Q10 (cfs):
Average Flow (cfs):
30Q2 (cfs):
IWC (%):
This area is water quality impacted, but the sources and causes of the problems are not fully understood. The
management strategy is pending further investigation and will be targeted for the 1998 Neuse Basin Plan update. In
the interim, wasteloads will be evaluated on a case -by -case basis.
Instream data review indicates high dissolved oxygen conditions up / downstream during May and Aptil '93
Letter to Town from Meares [WaRO], dated 6/23/93, very informative as, to current approaches and status of
facility's attempts to remedy problems. Hobbs, Upchurch, and Associates, P.A. also retained to look into possible
alternatives and/or upgrades.
Special Schedule Requirements and additional comments fro eviewers:
•
;RRJ'ICH.
Recommended by:
Reviewed by
Instream Assessment:
Regional Supervisor:
Permits & Engineering:
Farrell Keough
Date: 7-2- ocrce w. 199 S
Date: 10 ID -1(cj3
Date: //t 57q 7
Date: (fig b3
RETURN TO TECHNICAL SERVICES BY: NOV 2 6 1993

2
Existing Limits:
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1):
TSS (mg/1):
Fecal Col. (/100 ml):
pH (SU):
Residual Chlorine 4g/1):
Oil & Grease (mg/1):
TP (mg/1):
TN (mg/1):
Recommended Limits:
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1):
TSS (mg/1):
Fecal Col. (/100 ml):
pH (SU):
Residual Chlorine (µg/l):
Oil & Grease (mg/1):
TP (mg/1):
TN (mg/1):
CONVENTIONAL PARAMETERS
Monthly Average
Summer Winter
0.060
30
monitor
monitor
90 lagoon
200
nr
nr
nr
monitor
nr
Monthly Average
Summer Winter
0.060
30
monitor
monitor
90 lagoon
200
monitor
monitor
nr
monitor
monitor
WQ or EL
EL
EL
Limits Changes Due To: Parameter(s) Affected
Change in 7Q10 data
Change in stream classification
Relocation of discharge
Change in wasteflow
Other (onsite toxicity study, interaction, etc.)
Instream data
New regulations/standards/procedures
New facility information X pH, Residual Chlorine, T-nitrogen
Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
OR
x_ No parameters are water quality limited, but this discharge may affect future allocations.

f
3
INSTREAM MONITORING REQUIREMENTS
Upstream Location: Hwy 13 / 258 bridge, or Hwy 13 bridge [whichever is safer]
Downstream Location: Hwy 123 bridge
Parameters: Temperature, dissolved oxygen, Conductivity
Special instream monitoring locations or monitoring frequencies:
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Adequacy of Existing Treatment
Has the facility demonstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes No
If no, which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate? Yes No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
Special Instructions or Conditions
Wasteload sent to EPA? (Major) (Y or N)
(If yes, then attach schematic, toxics spreadsheet, copy of model, or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
Additional Information attached? (Y or N) If yes, explain with attachments.

Facility Name:
Permit Number:
Engineer:
Subbasin:
Recieving Stream:
USGS quad #:
Request Number:
Date:
Expiration date:
Town of Hookerton Waste Water Treatment Plant
NC0025712
Goris
03-04-07
Contetnea Creek
F28NE
7600
9/22/93
00/00/00
Existing WLA checked: x
Staff Report:
Topo checked:
USGS Flows confirmed:
PIRF / APAMS:
IWC Spreadsheet:
Stream Classification:
Nutrient Sensitivity:
Instream Data: .
x refer attached
nr
x
x
x
x
Strategy Pending [ Fact Sheet Language ]
This area is water quality impacted, but the sources and causes of the problems are not
fully understood. The management strategy is pending further investigation and will be
targeted for the 1998 Neuse Basin Plan update. In the interim, wasteloads will be
evaluated on a case -by -case basis.
Facility currently under SOC, [ issued early in 1993].due to an inability to meet BOD5 and TSS limits. "In spite of
efforts by the Town to bring the lagoon systems into regular compliance, it has become obvious that these
violations cannot be avoided by normal maintenance and operational attention. There is no known explanation for
the non-compliance which began in May of 1991. Consequently, there is no reason to believe that the system will
come back into compliance on a regular basis.
As you know, the operation of a facultative lagoon system has a low potential for operational corrective action."
[ Supplement to Application for a Special Order by Consent ]
SOC limits requested are BOD5 : 65.0 mg/I and TSS : 180 mg/I. Unfortunately, model does not reflect TSS
[algae] effects on stream, as indicated by instream data review, (attached). I will follow the suggested approach,
per letter from Juan Mangles, May 19,1993 (attached).
DMR's
As noted in SOC, BOD5 and TSS have many violations.
* Instream data reveals events of high dissolved oxygen, [highlighted] which may be a function contributing to
algal growths... there are many extraneous factors which should be considered during the study of this area. This
is a rocky area with lower ambient temperatures and high nutrients.
Central Files
Excellent letter to Gene Hill, Mayor Town of Hookerton, [June 23, 1993] from Marjorie Meares [WaRO] (excerpt):
"Since the beginning of this year there has been a remarkable improvement in BOD and TSS concentrations
in the Hookerton effluent. This improvement may be due, in part, to some experimentation that Mr. Taylor [ORC]
has conducted. I am aware that he has taken the Number 3 lagoon off line to shorten hydraulic detention time
through the system and that he has then dosed the lagoon on at least two occasions with chlorine. Also, Mr.
Taylor reported that he has run a 3/4-inch line directly from the water treatment plant to the wastewater treatment
plant.
Mr. Taylor has reported that the chlorine in the third lagoon appears to has significantly reduced algae
growth. Furthermore, he believes the addition of the added flow directly from the water plant is decreasing
stagnation in the lagoons and is introducing some level of chlorine to the operating system and is thereby
improving effluent quality.

uonventionai wisdom suggests mat a level of cniorine tnat will ettectiveiy manage algae growfn will
negatively effect the biological activity of the lagoon system. It is this commonly held belief that makes me
skeptical of the wisdom of chlorinating the lagoons. However, I am interested in pursuing any avenue that might
improve effluent quality. If experimentation on the lagoon is to be conducted, it must be done in a slow and
careful manner. The only way to know what effect might be being achieved is to be sure that the only one
variable is changed at a time. I have asked Mr. Taylor to contact me before taking any of the lagoons off line,
adding any chemicals to the system or making other temporary modifications to the treatment system. The Town
is reminded that permanent changes to the treatment system require prior approval from DEM and might require
permitting activity. I have requested Mr. Taylor and the Town's consulting engineer Ron Huff develop a written
plan for further experimentation to submit to me for review prior to any more changes. It seems important that if
the Town of Hookerton is going to go to expense and effort of this type of experimentation that it be done in a
way that the results are meaningful.
Since the beginning of 1993, when the BOD and TSS concentrations decreased, there has been a
corresponding increase in the ammonia concentration. Ammonia is toxic to aquatic life, particularly at a pH of
eight units or greater. Chlorine is also toxic. Thus, the current situation makes me concerned that your effluent
is more toxic, even though BOD and TSS concentrations have decreased. If the addition of chlorine becomes a
part of your treatment regime then I would think both a chlorine monitoring requirement and a toxicity limit would
be in order..."
Staff Report
Facility currently under SOC and negotiating remedies for inability to meet limits, (should be complete in two
months). WaRO recommends reissuance in coordination with Basin Plan.
* "Much of the site is subject to flooding."
* "Lagoons are built up so that the sides are above the 100 year flood plain. Site frequently floods during
heavy rains so that access to lagoons is only possible by boat."
* "Solids have never been removed from system. Given system capacity residuals handling plan not
required at this time."
Submission of Final Engineering Report December 1, 1993
Submission of Plans and Specifications March 1, 1994
Begin Construction November 1, 1994
Complete Construction August 1, 1995
Comply with Final Effluent Limits October 1, 1995

Town of Hookerton Waste Water Treatment Plant [CBNC.Inc] NC0025712
Upstream: z riney uU°ve
Month Temp DO
Saturation Fecal Conductivity
Jun-93
May-93
Apr-93
Mar-93
Feb-93
Jan-93
Dec-92
Nov-92
Oct-92
Sep-92
Aug-92
Jul-92
25
22
15
11
8
9
10
14
15
23
25
26
8.1
9.1
10.1
9.1
10.6
9.2
11.3
9.9
9.2
7.4
6.5
6.2
98%
104%
100%
839%°
89%
79%
100%
96%
91%
86%
79%
76%
107
88.7
75.3
75
91.8
81
86.8
102.5
113.5
90.8
70
72
Downstream: .r.>
Temp DO
25 7.4
Saturation Fecal Conductivity
90%
112
22 9.3
16 10.4
106%
105%
89.7
75.5
11
8
9
10
14
15
23
25
26
8.7
10.6
8.9
11.0
9.3
9.0
6.7
5.5
5.6
79%
89%
77%
98%
90%
89%
78%
67%
69%
76.4
92
81
88
103.7
127.5
91.8
63.8
68
Ammonia [2 / 4 mg/I] - Residual Chlorine - Fecal Coliform
Instream Waste Concentrations
Residual Chlorine
7Q10 (cfs)
Design Flow (mgd)
Design Flow (cfs)
Stream Std (mgA)
Upstream bkgrd level (mgA)
IWC (%)
Allowable Concentration (mgA)
Fecal Limit
Ratio of 333.3 :1
Ammonia as NH3
(summer)
31.0 31.0 7Q10 (cfs)
0.06 0.06 Design Flow (mgd)
0.093 0.093 Design Flow (cfs)
17 2 Stream Std (mg/I)
0 0.22 Upstream bkgrd level (mg/I)
0.3% 0.3% IWC (%)
5683.7 595.3 Allowable Concentration (mgA)
Not Required
0.0
0.06
0.093
4
0.22
100.0%
4.0
Ammonia as NH3
(winter)
7Q10 (cfs)
Design Flow (mgd)
Design Flow (cfs)
Stream Std (mgA)
Upstream bkgrd level (mgA)
IWC (%)
Allowable Concentration (mgA)
9/23/93

Turkey Creek at SR 1128 [headwaters of Buck orne Reservoir)
Contentnea Creek at 301, below Wiggins Mil Reservoor Dam (headwaters below reservior)
Contentnea Creek at SR 1622 (pt of DO sag in model)
Contentnea Creek at NC 58, near Stantonsburg
Contentnea Creek at US 13 / 258 [Proposed Ambient Station]
Contentnea Creek at NC 123 [Ambient Station 02.0915.0000]
Contentnea Creek at SR 1004
Contentnea Creek at Hwy 118 [Ambient Station 020917.6890]
Contentnea Greek at mouth
()tie Contentnea at SR 1218 [Interaction]
Lille Contentnea at US 264 [Interaction: Ambient Station 020917.0000]
Little Contentnea at SR 1110 [mouth] h4ocassin Creek at SR 1131; mouth [Proposed Ambient Station, headwaters of Buckhome Reservoir]
Nahunta Swamp at NC 58 [mouth]
(major tributary
Toisnot Swamp at NGSR 1539 [mouth] (ma or tributary
Taylors Mill Pond impacts

•
To: Permits and Engineering Unit SOC Priority Project: Yes X No _
Water Quality Section If "Yes," SOC No. 9 2- 2 Y
Attn: Sean Goris
Date: October 8, 1993
NPDES STAFF REPORT AND RECOMMENDATION
Greene County
Permit No. NC0025712 `
Or 1 2 1993
PART I - GENERAL INFORMATION
rimi,HNtCfL SUPPORT BRANCH
1. Facility and Address:
k
Town of Hookerton, P.O. Box 396, Hookerton NC28538
2. Date of Investigation: July 12, 1993
3. Report Prepared by: Marjorie L. Meares
4. Person(s) Contacted and Telephone Number(s):
Cecil Taylor, ORC/Public Works Director [phone]
5. Directions to Site:
From the Hookerton Town Hall travel North on NC Hwy 123. Go 0.3 miles past the
Contentnea Creek Bridge and turn left (west) on private, gated, road to the facility.
6. Discharge Point(s), List for all discharge points:
Latitude: 35 0 25' 42" N Longitude: 77 ° 35' 35" W
Attach USGS map extract and indicate treatment facility site and discharge point on map.
USGS Quad No. USGS Quad Name: Hookerton. NC
7. Site size and expansion area consistent with application? Yes _. No X If "No,"
explain:
Application contains no information concerning expansion. There is very little usable
space on site. Much of the site is subject to flooding.
8. Topography (relationship to flood plain included)
Lagoons are built up so that sides are above the 100 year flood plain. Site frequently
floods during heavy rains so that access to lagoons is only possible by boat.
9. Location of nearest dwelling:
Nearest dwelling is approximately .5 miles and is on the other side of Contentnea Cr.

10. Receiving stream or affected surface waters: Contentnea Creek
a. Classification:
b. River Basin and Subbasin No.:
Class C - Swamp
03-04-07
c. Describe receiving stream features and pertinent downstream uses:
Contentnea Cr. has a 7Q10 of 31 cfs and problems with summertime low DOs.
Pertinent uses are those associated with Class C streams: aquatic life propagation
and survival, fishing, wildlife, secondary recreation and agriculture.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be Permitted: 0.06 MGD (Ultimate Design Capacity)
b. Current permitted capacity: 0.06 MGD
c. Actual Treatment Capacity: 0.06 MGD (Current Design Capacity)
d. Date(s) and construction allowed by Authorizations to Construct issued in past two
years:
e. Description of existing or substantially constructed wastewater treatment facilities:
Influent barscreen, manually raked, three lagoons with adjustable effluent baffles
and the capacity to discharge directly from the second lagoon.
f. Description of proposed wastewater treatment facilities:
g.
N/A
Possible toxic impacts to surface waters:
100% domestic sewage
h. Pretreatment Program (POTWs only):
In development Approved
Should be required Not needed _ _
2. Residuals Handling and Utilization/Disposal Scheme
a. If residuals are being land applied, specify DEM permit number:
Residuals Contractor:
Telephone Number:
b. Residuals Stabilization: PSRP _. PFRP r Other
c. Landfill:
d. Other disposal/utilization scheme (specify):
Solids have never been removed from system. Given system capacity residuals
handling plan not required at this time.
NPDES Permit Staff Report
Version 10/92 Page 2

3. Treatment Plant Classification (attach completed rating sheet):
4. SIC Code(s): 4952
Wastewater Code(s): Primary 01 Secondary none
Main Treatment Unit Code: 300-0
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)?
No
2. Special monitoring or limitations (including toxicity) requests:
None
3. Important SOC, JOC, or Compliance Schedule dates (indicate):
Activity Date
Submission of Final Engineering Report 12/1/93
Submission of Plans and Specifications 3/1/94
Begin Construction 11 / 1 /94
Complete Construction 8/ 1 /95
Comply with Final Effluent Limits 10/1/95
4. Alternatives Analysis Evaluation: Has the facility evaluated all of the non -discharge
options available? Provide Regional perspective for each option evaluated.
Spray Irrigation:
Connection to Regional Sewer System:
Subsurface Disposal:
Other Disposal Options:
5. Other Special Items:
NPDES Permit Staff Report
Version 10/92 Page 3

PART IV - EVALUATION AND RECOMMENDATIONS
Town of Hookerton operates a lagoon system that has trouble meeting limits for BOD and
Suspended Solids. They are currently under an SOC to develop system improvements that
will allow them to meet limits. They are currently in the process of obtaining an A. to C.
for a flow measuring device. Depending on what is proposed and executed through the SOC
process several changes will be required to this permit. However it will be at least two
months before there is any further action on the SOC. Therefore, it is the recommendation
of the Washington Regional Office that this permit be renewed in keeping with the basin -
wide permitting cycle.
gc"-10/--&- L
Signature of report preparer
Water Quality Regional Supervisor
1v/y/q 3
Date
NPDES Permit Staff Report
Version 10/92 Page 4

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
May 19,1993
Mr. Ron Huff, P.E.
Hobbs, Upchurch and Associates, P.A.
P.O. Box 1737
Southern Pines, North Carolina 28388
E I-1 NI Fl
Subject: Town of Hookerton WWTP
NPDES Permit No. NC0025712
Greene County
Dear Mr. Huff:
The North Carolina Division of Environmental Management (NCDEM) is in receipt of your
letter addressed to me and dated April 16,1993, concerning the subject facility. Our response is as
follows:
The renewed NPDES permit in 1994 should contain similar oxygen consuming effluent
limitations to those existing limitation unless there is an increase in wasteflow. However, disinfection
facilities and a total residual chlorine limitation may be required. This NPDES permit should be
effective for a period of five years.
The slow moving nature of Contentnea Creek results in substandard instream dissolved oxygen
(DO) concentrations during critical conditions (i.e. warm weather/low flow periods). Substandard DO
concentrations have been documented at all three NCDEM ambient stations located in Contentnea Creek
(i.e. near Lucama, at Hookerton, and at Grifton). Also, modeling analyses, work by the Research
Triangle Institute, non point source data, and field observations have indicated that the assimilative
capacity of the lower Contentnea Creek is severely compromised.
Therefore, the Contentnea Creek basin has been targeted for a comprehensive evaluation within
the next four years. This office will develop a field calibrated QUAL2E model to determine the
assimilative capacity of oxygen consuming wastes in the subbasin. Non point source and groundwater
studies will also be performed by NCDEM.
In light of the assimilative capacity of the receiving waters, it is very likely that if the facility
increases its wasteflow, more stringent effluent limitations will be required. Furthermore, any set of
NPDES permit limitations assigned prior to the completion of the Contentnea Creek subbasin study may
be modified in the future to comply with effluent limitations derived from the study results.
f NCDEM Technical Support Branch anticipates that effluent limitations that would approach
1 state-of-the-art technology (i.e. BOD5 = 5 mg/land NH3-N = 2 mg/1) may be required for new and
expanding facilities. Scheduling for compliance of these limits for existing facilities may be determined
on a case -by -case basis depending on the facility's size, current treatment levels, feasibility, plans for
expansion, and other factors. Also, the findings of the nutrient loading study may indicate a need for
Ltd
further nutrient reductions in the subbasin. Therefore, it is recommended that you consider this in your
ans and allow for flexibility to comply with more stringent NPDES permit limitations in the future.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 O% post -consumer paper .

Mr. Ron Huff, P.E.
Page Two
If you have any questions concerning this matter, please contact me or Mr. Juan C. Mangles of
my staff at [phone].
Sincerel
teve W. Tedder, Section Chief
Water Quality Section
cc: Don Safrit
Roger Thorpe
WLA Files
Central Files

Hobbs, Upchurch & Associates, P.A.
Consulting Engineers
Post Office Box 1737 • Southern Pines, NC 28388
April 16, 1993
Mr. Steve Tedder
Water Quality Section
Division of Environmental Management
Archdale Building
512 N. Salisbury Street
Raleigh, NC 27611
FAPR
RE: Town of Hookerton Wastewater Discharge Compliance
NPDES Permit No. NC0025712
HUA No. HK9201
Dear Mr. Tedder:
ifo°
The Town of Hookerton in Green County presently operates a three cell facultative lagoon
system with a permitted flow of 60,000 gallons per day. The Town has experienced
compliance difficulties believed to be caused by algae growth in the lagoons. Hobbs,
Upchurch & Associates is working with the Town to comply with an SOC and to provide
a solution to their wastewater problems.
The existing NPDES permit expires on February 28, 1994. Of primary concern is the
accurate projection of future discharge limits. It is presently believed that the existing
lagoon system can be modified to meet the existing limits of 30 milligrams per liter BOD
and 90 milligrams per liter total suspended solids. There is, however, concern that the
benefit received from such expenditures would be short lived should the Town experience
a tightening of discharge limits in the near future that would require treatment which could
not be adequately provided by a lagoon system.
It is my understanding that Contentnea Creek, the receiving waters, is low in dissolved
oxygen and will be undergoing water quality studies including nutrient levels in the near
future.
Hookerton upgraded the existing lagoon system in the early 80's to add two additional
treatment lagoons. They have a large capital investment in the existing system and would
certainly like to obtain as much use from this facility as possible. They would, however,
prefer to implement a solution which will be long term rather than spend substantial money
on a system which might soon be obsolete.
290 S.W. Broad Street • Telephone [phone] • Fax [phone]

Mr. Steve Tedder
Page 2
April 16, 1993
The existing plant flow is approximately one-half the design flow, and there is no expectation
of significant growth in the area which would use up the hydraulic capacity of the existing
facility.
Although I realize that it is difficult, if not impossible to project discharge limits, I would
like to request your best answers to the following questions:
1. The existing NPDES permit expires February 28, 1994. Is it likely that a new permit
will contain limits similar to the existing limits?
2. Will the permit issued in 1994 be of short duration because of the basin -wide
planning strategy? If so, when will the next permit expire?
3. In the event that studies of the receiving waters indicate that an across the board
reduction in the discharge of oxygen consuming waste and/or nutrients is called for,
will exceptions be made for small dischargers with lagoon systems such as
Hookerton?
4. Should the Town of Hookerton apply for an increased flow of any magnitude, will
this automatically trigger new limits which would require mechanical treatment?
We presently anticipate that the Town can comply with the existing permit limit with an
expenditure of less than $100,000.00. An expenditure of this magnitude for a community
of this size of necessity must buy them a reasonable period of compliance. Assurance that
existing limits will be maintained for a minimum of five years would assist the Town in
making a decision as to their best course of action.
I look forward to your comments regarding this situation. As the warm season approaches,
we anticipate compliance problems to occur quickly. Our strategy is to experiment with
techniques such as flow partitioning of existing lagoons in an effort to prevent non-
compliance. We are already at a critical point where expenditure for improvements must
be made in the near future. Your guidance on the above questions will be appreciated.
Sincerely,
HOBBS, UPCHURCH & ASSOCIATES, P.A.
Ron Huff, P.E.
cc: Gene Hill, Mayor/Town of Hookerton
RH/rjp/apr16