NC0056863_Speculative Limits_20080103

wAr,
0r �VA William G. Ross, Jr., Secretary
> NCDENR North Carolina Department of Environment and Natural Resources
=l
Q -C Coleen H. Sullins, Director
Division of Water Quality
January 3, 2008
Dr. Shankar R. Mistry, Ph.d., P.E.
The Wooten Company
120 North Boylan Avenue
Raleigh, NC 27603-1423
Michael F. Easley
Governor
Subject: Speculative Limits
Town of Rose Hill WWTP
NPDES Permit NC0056863
Duplin County
Dear Dr. Mistry:
We have reviewed your application for Speculative Limits on behalf of the Town of Rose Hill to
expand their existing Wastewater Treatment Plant permit NC0056863 to 0.75 MGD and 0.9
MGD from 0.45 MGD. This wastewater treatment plant discharges to Reedy Branch in the Cape
Fear River Basin. Our records indicate that Reedy Branch at the discharge location is a zero
flow stream, both 7Q10 (summer and winter) and 30Q2 are zero. According to the Division of
Water Quality Administrative Code Section 15A NCAC 02B.0206 (d) (2), "If the 30Q2 and
7Q10 flows are both estimated to be zero, no new or expanded (additional) discharge of oxygen
consuming waste will be allowed."
Division. of Water Quality policies do not allow an increased flow to this stream. We do not
impose mass limits on municipalities, as you have requested.
The Town of Rose Hill must explore other options, such as non -discharge or discharge to a
different stream with positive 30Q2 and 7Q10 flows.
Please contact Jim McKay of my staff at [phone], ext. 595, email:
[e-mail] if there are any questions or comments.
Sincerely,
Gil Vinzani, Supervisor
Eastern NPDES Program
CC: NPDES files
WIRO/ Surface Water Protection
Mr. Thomas Drum, Administrator/ Town of Rose Hill/ P.O. Box 8/ Rose Hill, NC 28458
N. C. Division of Water Quality / NPDES Unit Phone: [phone] ext. 595
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center..1800 623-7748

THE
WOOTEN
COMPANY
ENGINEERING
PLANNING
ARCHITECTURE
120 North Boylan Avenue
Raleigh NC 27603-1423
919.828.0531
fax [phone]
December 28, 2007
Mr. Gil Vinzani, P.E.
Supervisor, Eastern NPDES Program
NC. Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Speculative Limits
Town of Rose Hill WWTP
NPDES Permit NC0056863
Duplin County
Dear Mr. Vinzani:
Reference is made to your December 18, 2007 letter concerning the
response to our request for Speculative Limits for expansion of the Town
of Rose Hill's WWTP from 0.45 MGD to 0.75 MGD. It is recognized that
the Reedy Creek, at the discharge location, has zero 7Q10 (summer and
winter) and 30Q2 stream flows and in accordance with the Division of
Water Quality Administration Code Section 15A NCAC 02B.0206 (d)
(2),no new or expanded (additional) discharge of oxygen consuming waste
will be allowed.
As per the current NPDES Permit the effluent limits on discharge of the
oxygen consuming waste (BOD5 and Nh3-N) at the permitted flow of 0.45
MGD are listed as follows:
BOD5, Summer months (April -October) = 10 mg/L
Winter months (November —March) = 18 mg/L
NH3-N, Summer months (April —October) = 2 mg/L
Winter months (November —March) = 4 mg/L
Considering the limiting summer months effluent limits on BOD5 and
NH3-N (oxygen consuming wastes) of 10 mg/L and 2.0 mg/L, respectively,
the total permitted discharge of BOD5 and NH3-N to the receiving stream
(Reedy Branch) are estimated to be 37.53 lb BOD5/day and 7.506 lb NH3-
N/day, respectively. If we expand the plant to 0.9 MGD to comply with the
effluent BOD5 and NH3-N limits of 5.0 mg/L and 1.0 mg/L, respectively,
we will be able to maintain the currently permitted oxygen consuming
BOD5 and NH3-N waste loadings of 37.53 lb BOD5/day and 7.506 lb NIH3-
N/day, respectively.
Rose Hill is experiencing residential, commercial and industrial growth and
the current capacity will not be able to support the anticipated growth.
Please note that the proposed plant expansion(s) will not increase the

discharge of currently permitted oxygen consuming wastes into Reedy
Branch. Accordingly, it is requested to provide Speculative Effluent Limits
for expansion of the Rose Hill WWTP to 0.75 MGD and 2/MGD
capacities.. 0 3
Your and Mr. Jim McKay assistance in this matter will be greatly
appreciated. If you have any questions concerning this matter, please call
me or Dan Boone at 919-828-0531.
Sincerely,
151o•4Wow' P . r tIS44
Shankar R. Mistry, Ph. D., P.E.
Cc: Mr. Thomas Drum, Administrator, Town of Rose Hill

AVA
NCDENR
Dr. Shankar R. Mistry, Ph.d., P.E.
The Wooten Company
120 North Boylan Avenue
Raleigh, NC 27603-1423
Dear Dr. Mistry:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
December 18, 2007
ilEUVO0
DEC 2 7 2007
THE WOOTEN COMPANY
Subject: Speculative Limits
Town of Rose Hill WWTP
NPDES Permit NC0056863
Duplin County
We have reviewed your application for Speculative Limits on behalf of the Town of Rose Hill to
expand their existing Wastewater Treatment Plant permit NC0056863 to 0.75 MGD from 0.45
MGD. This Wastewater Treatment plant discharges to Reedy Branch in the Cape Fear River
Basin. Our records indicate that Reedy Branch at the discharge location is a zero flow stream,
both 7Q10 (summer and winter) and 30Q2 are zero. According to the Division of Water Quality
Administrative Code Section 15A NCAC 02B.0206 (d) (2), "If the 30Q2 and 7Q10 flows are
both estimated to be zero, no new or expanded (additional) discharge of oxygen consuming
waste will be allowed."
We cannot allow any increased discharge of oxygen consuming waste to Reedy Branch. The
Town of Rose Hill must explore other options, such as non -discharge or discharge to a different
stream with positive 30Q2 and 7Q10 flows.
Please contact Jim McKay of my staff at [phone], ext. 595, email:
[e-mail] if there are any questions or comments.
CC: NPDES files
N. C. Division of Water Quality ! NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Sincerely,
Gil Vinzani, Supervisor
Eastern NPDES Program
Phone: [phone] ext. 595
fax: [phone]
DENR Customer Service Center: 1 800 623-7748

9 QUA
r_ NCDENR
Dr. Shankar R. Mistry, Ph.d., P.E.
The Wooten Company
- 120 North Boylan Avenue
Raleigh, NC 27603-1423
Michael F. Easley
Govemor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
December 18, 2007
Subject: Speculative Limits
Town of Rose Hill WWTP
NPDES Permit NC0056863 •
Duplin County
Dear Dr. Mistry:
We have reviewed your application for Speculative Limits on behalf of the Town of Rose Hill to
expand their existing Wastewater Treatment Plant permit NC0056863 to 0.75 MGD from 0.45
MGD. This Wastewater Treatment plant discharges to Reedy Branch in the Cape Fear
River
Basin. Our records indicate that Reedy Branch at the discharge location is a zero flow stream,
both 7Q10 (summer and winter) and 30Q2 are zero. According to the Division of .Water Quality
Administrative Code Section 15A NCAC 02B.0206 (d) (2), "If the 30Q2 and 7Q10 flows are
both estimated to be zero, no new or expanded (additional) discharge of oxygen consuming
waste will be allowed."
We cannot allow any increased discharge of oxygen consuming waste to Reedy Branch. The
Town of Rose Hill must explore other options, such as non -discharge or discharge to a different
stream with positive 30Q2 and 7Q10 flows.
Please contact Jim McKay of my staff at [phone], ext. 595, email:
[e-mail] if there are any questions or comments.
CC: NPDES files %� fs�'���•
wiM/ S�ffAcG ���r
N. C. Division of Water Quality 1 NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet h2o.enr.state.nc.us
Sincerely,
Gil Vinzani, Supervisor
• Eastern NPDES Program
Phone: [phone] ext. 595
fax: [phone]
DENR Customer Service Center. 1 800 623-7748

ZERO -FLOW POLICY
The following NPDES permitting policies apply to discharges to zero -flow streams:
• New and Expanding Discharge to Zero Flow Streams ( both 7Q10 and 30Q2 = 0).
Regulation 2B .0206 disallows new discharges of oxygen consuming wastewater to streams
which have no flow under both 7Q10 and 30Q2 conditions.
• New and Expanding Discharge to Zero Flow Streams (7Q10= 0; 3002 >0). Regulation 2B
.0206 sets effluent limitations at BOD5 = 5 mg/1, NH3-N= 2 mg/1, and DO = 6 mg/1 to
streams with no 7Q10 flow, but positive 30Q2 flow, unless it is determined that these limits
will not protect water quality standards.
• Existing Dischargers. Regulation 2B .0206 also states that existing dischargers to zero -flow
streams should be handled on a case -by -case basis. For many years, permits for the existing
discharges to so-called "zero -flow streams" did not contain any special requirements.
However, since 1990, three different requirements have been somewhat randomly placed in
NPDES permits. These requirements were:
1. Require an alternatives analysis be done and give summer limits of 5 mg/L (BOD5) and 1
mg/I (NH3-N) and winter limits of 10 mg/L (BOD5) and 1.8 mg/L (NH3-N) after a three-
year period, if the discharge continued.
2. Require an alternatives analysis to meet the above limits, but renew the permit without a
change in limits (i.e., no 3-year compliance schedule to meet limits) during that permit
cycle.
3. Require an alternatives analysis to meet summer limits of 5 mg/L (BOD5) and 2 mg/L
(NH3-N) and winter limits of 10 mg/L (BOD5) and 4 mg/L (NH3-N) without a change in
limits during that permit cycle.
If alternative #1 was implemented in a previous permit, then these limits should be maintained
with the exception of ammonia limits which should be changed to reflect current BAT for
facilities with permitted flows of less than 1.0 MGD (2 mg/L and 4 mg/L in the summer and
winter, respectively). An altemative analysis is not necessary for these discharges.
If a facility has never been required to submit an alternatives analysis, then the permit should be
renewed with existing limits and a requirement to perform an alternatives analysis during the next
permit cycle. The permit holder will be required to send in the alternatives analysis six months
prior to the expiration date and should be notified of this requirement in the cover letter to permit
issuance.
If a facility has been required to submit an alternatives analysis, but has not done so or has
concluded that discharge is the only option, ammonia limits of 2 mg/L (summer) and 4 mg/L
(winter) should be given with a compliance schedule (when deemed necessary by regional office
staff). This schedule should not exceed three years. In lieu of these ammonia limits, the facility
may choose to sample for toxicity using a chronic WET test, pass/fail at 90% using Ceriodaphnia
as the test organism. Existing BOD5 limits should be maintained unless instream data indicates a
potential violation of the dissolved oxygen water quality standard.
If the facility does not discharge into a zero -flow stream, ammonia limitations should be checked
against the Division's Ammonia Toxicity Policy.
Zero -Flow Policy
5/12/99
Page 1 of 1

November 27, 2007
Mr. Gil Vinzani, P.E. .1 1 NOV 2 9 2007
THESupervisor, Eastern NPDES Program
WOOTEN NC Division of Water Quality
1617 Mail Service Center
CO M PANY Raleigh, North Carolina 27699-1617
ENGINEERING
PLANNING Subject: Request for Speculative Effluent Limits
Rose Hill Wastewater Treatment Plant
ARCHITECTURE NPDES Permit No. NC 0056863
Duplin County
Dear Mr. Vinzani:
The Town of Rose Hill operates a 0.45 mgd wastewater treatment plant
which discharges its effluent into Reedy Branch in accordance with the
NPDES Permit No NC0056863. In order to accommodate the projected
residential, commercial and industrial (Carolina By -Products, Duplin
Winery and Murphy Farm) growth in the Rose Hill planning area, the
estimated Rose Hill wastewater treatment plant expansion need is 0.75
mgd. Accordingly, we will appreciate your assistance in providing
Speculative Effluent Limits for expansion of the plant to 0.75 mgd.
Should you have any questions concerning this matter, please call me at
919-828-0531.
Sincerely,
Shankar R. Mistry, Ph.D., P.E.
Cc: Mr. Thomas Drum, Administrator, Town of Rose Hill
Mr. Jerry James, Director of Public Works, Town of Rose Hill
120 North Boylan Avenue
Raleigh NC 27603-1423
919.828.0531
fax [phone]