NCC000001_Annual Report 2008_20090226

THE NEUSE RIVER COMPLIANCE ASSOCIATION
POST OFFICE Box 1562
APEX, NORTH CAROLINA 27502
February 26, 2009
Ms. Colleen Sullins, P.E., Director
NCDENR-Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Ms. Sullins:
The Neuse River Compliance Association is pleased to submit their sixth annual report as
required in the referenced permit. As included in the attached report, the co-permittee
members discharged a total of 490,149 pounds of total nitrogen to the Neuse Estuary
during calendar year 2008, about 43%of the permit limit of 1,137,171 pounds.
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 or myself at 919.796.8049.
Sincerely,
1k�
Haywood M. Phthisic, III
Chairman
Enclosure RECEIVED
cc: Cindy Finan
Glenn Dunn
Mike Templeton MAA - 3 2009
DENR - WATER QUALITY
POINT SOURCE BRANCH

NEUSE RIVER COMPLIANCE ASSOCIATION
2008 ANNUAL REPORT
NPDES PERMIT NCC000001
Co-Permittee Members of the NRCA for Calendar Year 2008
Town of Apex
Town of Benson
Town of Cary
North Plant
South Plant
County of Johnston
Town of Clayton
Contentnea MSD
South Granville Water and Sewer Authority
Town of Farmville
City of Goldsboro
Aquaamerica-Neuse Colony
Town of Kenly
City of Kinston-Regional Water Reclamation Facility
Town of LaGrange
City of New Bern
City of Raleigh
Neuse WWTP
Smith Creek WWTP
Little Creek WWTP/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 2008 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 490,149 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 (43% of permitted limit). The 1995 TN
loading from the NRCA members was 1,784,130 pounds with a flow of 83.808 MGD.
The 2008 numbers reflect an average flow of 90.563 MGD and a total loading of 490,149
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 2008 would
indicate that they have reduced the nitrogen loading from these point sources by 72%
over the loading reported in 1995, even while flows have increased.
Item 2. Summary of changes in Association membership, including regionalization of
discharges: The Association permit that was reissued in January of 2009 includes some
allocations that are a result of regionalization that has occurred in the past that was not
included in the last revision of the permit. The members report that no new
regionalization has occurred in 2008. The Association did not add any new members for
the current reporting period. The Association did vote in September, 2008 to add
Progress Energy's Lee Steam Plant to the membership in 2009. This addition was
reported to the Division and it has been included in the reissued permit. Their data will
be included in the 2009 Annual Report.
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.
The following transactions were completed in 2007 and were reported in the 2007
Annual Report. However, the Division has not yet made these additions to the individual
member's permits or to the Association permit when it was reissued. It is included again
in this Annual Report for the sake of continuing documentation. The County of Johnston
4

acquired 1,645 estuary pounds of nitrogen from Unifi-Kinston, LLC in 2007. Johnston
Co. has pursued having this allocation added to their permit and to the Association's
permit when it was reissued. The Town of Clayton also acquired 1,645 estuary pounds
from Unifi-Kinston, LLC. The Town has requested that this allocation be added to their
permit and to their reserve allocation in their new permit and in the Association's permit
when they were reissued. These transactions will reduce the allocation of Unifi-Kinston,
LLC by 3,290 estuary pounds. These changes have not been made to date.
Several short term lease agreements that have been entered into by NRCA members for
2008. These leases are only for the year 2008. The transfers are reflected on the attached
spreadsheet containing the data for the members for 2008. They are summarized as
follows:
The Town of Kenly has leased 2,100 estuary pounds of nitrogen from Johnston Co. in
order to allow them to comply with their allocation while they pursue funding of an
upgrade for their facility. The Town of Kenly was notified that have received funding
commitments from the NC Rural Center and from the Clean Water Management Trust
Fund in 2009. We would anticipate that this funding will result in improvements to the
facility that will bring them into compliance in the future.
Aquaamerica, Inc. leased 3500 estuary pounds from Unifi-Kinston, LLC in 2008 to cover
an upset at their Neuse Colony Plant. The company reports that an odor control
substance that was added to the facility resulted in a drastic increase in Total Nitrogen •
entering the facility in the influent. The plant was not able to treat this incoming nitrogen
which resulted in a extremely high effluent nitrogen values. The facility has discontinued
use of the substance and the influent and effluent levels are returning to normal.
Additional leases are not anticipated.
MCAS Cherry Point had previously leased nitrogen from the Association to assure
compliance with their allocation while their plant was upgraded. The plant construction
is now complete and the facility is in compliance. No further leases are anticipated.
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 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.
Only one member of the association will be assessed a penalty for a nitrogen exceedence
in 2008. South Granville Water and Sewer Authority exceeded their individual nitrogen
allocation for 2008 due to maintenance that was occurring at the facility. Units had to be
taken off line to perform repair and maintenance that was delayed due to problems with
replacement equipment. The facility has all units back on line and no further problems in
meeting the current nitrogen allocation are anticipated. The facility has elected to pay the
assessment to the association rather than to lease nitrogen from another member. The
facility owns an additional nitrogen allocation that is being held in reserve by the
Division until further study of Falls Lake is finalized. South Granville Water and Sewer
6

Authority understands that it cannot use this additional reserve nitrogen and did not want
to give the impression that they were leasing their own nitrogen from the Association or
any other member. The Association concurred that it would be more straightforward for
the facility to pay the assessment to the Association to remove any doubt.
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 were recently updated 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.
(3) The Association believes that a mechanism needs to be created to formally
track nitrogen allocations. The Division is currently only tracking
allocations and sales of allocations using the NPDES permits. Permit
revisions take a long time to complete and a better mechanism is needed to
keep track of exactly what allocations are held and by whom.
Item S. 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 rotors (on/off) in the
aerobic zones to create more anoxic zones. Started feeding chemical Mico CG in the first
anoxic zone in early April to provide a carbon source.
South Granville Water and Sewer Authority: This member has taken steps to repair and
purchase new mixing pumps for the BNR basin.
North Cary Water Reclamation Facility: This is a BNR facility which is equipped to
biologically remove nitrogen. They continue to operate the plant to optimize
nitrogen removal. Reuse facilities allow diversion of flow away from the discharge.
In 2008, 5.4% of the flow was diverted for reuse. This eliminated 3,944 pounds of
TN from the river.
Johnston Co.: The County continued reuse expansion and optimization of denitrification
filters. Sprayed 37 million gallons of reuse water for irrigation.
Clayton: The town has placed a reclaim water system in service.
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
7

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 retained Gene Johnson of O'Brien and Gere to perform a
study of the plant. He is a PE and a Grade IV operator with years of experience in
evaluating plant performance. He made several recommendations that have been put in
place. The Town has held meetings with the Town of Micro and Pine Ridge Foods in the
Town of Micro regarding the industries discharge to the Town of Kenly's plant. The
purpose of the meetings was to notify and work with Pine Ridge Foods in order to bring
their nitrogen discharge under control. The Town was notified that they will receive $1
million dollars in grants from the NC Rural Center and the NC Clean Water Management
Trust Fund in order to address the nitrogen issues at their plant.
Kinston (Regional): Kinston is still fine tuning its new denitrification sand filters.
City of New Bern: The City of New Bern has a non-discharge permit so that the
discharge can be diverted to a quarry and the reused water is used to water a sod farm. In
2008, 724 million gallons or 55.6% of the annual treated wastewater went to the quarry.
This reduced nitrogen loading to the river by 31,489 pounds and phosphorus loading by
7,606 pounds. In addition,the City has worked on reducing nitrogen loading through
operational changes to the biological nutrient removal processes. They have increased
operator training in nutrient removal and laboratory testing to examine the processes and
increase efficiency.
City of Raleigh/Neuse River WWTP: The City of Raleigh tested the use of glycerol as an
alternative carbon source to methanol. In addition,they started construction of 10
additional, deep bed denite filters.
City of Raleigh/Smith Creek WWTP: The City experimented with RAS rates, internal
recycle rates and MLSS concentrations to determine best operational set points. The City
started construction of plant expansion to include additional flexibility in the oxidation
ditch.
Wilson WWTP: The City installed an ammonia nitrogen analyzer probe in the aerobic
zone of the BNR basin to provide on-line monitoring. The unit will improve response
time to potential nitrification problems. The installation of the nitrate nitrogen analyzer
probe will provide on line monitoring of nitrates. Data from this unit will provide
information for adjusting carbon supplement needs in the BNR basins and denitrification
filters. Bridgestone-Firestone, Inc. began using reclaimed water for process cooling. The
completion of the Bert Gillette Soccer/Baseball Complex will significantly increase
demand for reclaimed water. BNR study to optimize BNR is nearing completion.
City of Raleigh-Little Cr.: Designed and began construction of expanded reuse
distribution system.
8

•
Unifi-Kinston,LLC: The operators continue to monitor and control the anoxic zone to
aid in denitrification.
MCAS Cherry Point: The Base completed construction of$14 million BNR upgrade to
the plant.
9

Item 6: An assessment of progress made: We believe the numbers speak for
themselves!
Current members of the compliance association discharged the following flows and
pounds of total nitrogen to the Neuse Estuary in the years shown:
Year Total Average Total Estimated
Flow (MGD) 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
2007 92.994 461,325
2008 90.563 490,149
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 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 2008 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.
South Granville Water and Sewer Authority: The authority has initiated a plant capacity
study in order to determine what can be done to reduce effluent nutrients.
Cary: The Town of Cary commits itself to continued optimal performance of its two
biological nutrient removal water reclamation facilities.
Johnston Co.: The County will continue to plan and expand the reuse facilities.
10

Clayton: The Town plans to look for other end users of reclaimed water.
Contentnea MSD: CMSD has started construction of an upgrade to the facility. They
will add denitrification filters, UV disinfection, headworks upgrade and addition of an
effluent pipeline to replace the effluent canal.
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 will bring Pine Ridge Foods into compliance with the sewer use
ordinance. They will begin design and construction of the needed improvements to the
plant now that funding has been secured.
Kinston: The City is currently under construction of a$1.5 million dollar spray irrigation
project for reclaimed water reuse. This project is for new pumps, piping, sprinklers and
SCADA controls to spray reclaimed water to approximately 40 acres of trees. This
project should be completed by late spring.
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. They will continue their
efforts by changing controls in a step procedure and examine the effect on total nitrogen.
Raleigh/Neuse River WWTP: The City plans to reduce hydraulic loading on tertiary
denite filters by adding 10 more filters to the existing facility. The City will expand reuse
capability.
City of Raleigh/Smith Creek: The City completed construction of expanded facilities
with added flexibility which includes flow equalization and flow diversion to the Neuse
River WWTP.
Wilson: The City will install an irrigation system at the Water Reclamation Facility to
irrigate grounds including 18 acres of turf grass. They will conduct a feasibility study for
disposal of reclaimed water via low rate infiltration basins. Modify existing methanol
pumping system to improve methanol distribution to BNR basins.
City of Raleigh- Little Cr.: The City will start design of plant expansion to include new 5
stage Bardenpho process.
11

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