HomeMy WebLinkAboutNC0026662_Speculative Limits_20230131DocuSign Envelope ID: 46F350B4-58BF-45E4-A4A8-994657E88AA2
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Michael King, Town Administrator
Town of Princeton
P.O. Box 67
Princeton, NC 27569
Dear Mr. King:
NORTH CAROLINA
Environmental Quality
1/31/2023
Subject: Speculative Effluent Limits
Town of Princeton WWTP
NPDES Permit No. NC0026662
Johnston County
Neuse River Basin
Draper Aden Associates submitted a speculative limits request on behalf of the Town of Princeton on October 13,
2022. The Town of Princeton is considering expanding the existing wastewater discharge to the Little River.
Speculative limits were requested for flows of 0.6 MGD and 0.95 MGD.
Receiving Stream. The Little River is located within the Neuse River Basin. Little River has a stream classification
of WS-IV, NSW, and waters with this classification are used as sources of water supply for drinking, culinary, or
food processing purposes as well as for aquatic life propagation and maintenance of biological integrity, wildlife,
secondary recreation and agriculture. The USGS responded to a low flow request with the following revised flows:
the Little River has a summer (annual) 7Q10 flow of 1.1 cfs, a winter 7Q10 flow of 13.2 cfs, a 30Q2 flow of 23.3
cfs, and an annual average flow of 280 cfs.
The Little River at Outfall 001 [stream segment 27-57-(20.2), from Spring Branch to a point 0.6 mile downstream of
Smith Mill Run] is not currently listed as an impaired waterbody on the 2022 North Carolina 303(d) Impaired Waters
List. There are no specific permitting strategies or TMDLs for this section of the river.
Based upon a review of information available from the North Carolina Natural Heritage Program Online Map Viewer,
there are no Federally Listed threatened or endangered aquatic species identified within a 5-mile radius of the proposed
discharge location. If there are any identified threatened/endangered species, it is recommended that the applicant
discuss the proposed project with the US Fish and Wildlife Service to determine whether the proposed discharge
location might impact such species.
Speculative Effluent Limits. Based on Division review of receiving stream conditions and specific proposed
discharge location, speculative limits for the proposed expansion to 0.6 MGD and 0.95 MGD WWTP are presented
in Tables 1 and 2. A complete evaluation of these limits and monitoring requirements for metals and other toxicants,
as well as potential instream monitoring requirements, will be addressed upon receipt of a complete NPDES permit
application.
Every applicant shall also submit documentation of any additional pollutants for which there are certified methods
with the permit application if their discharge is anticipated. These pollutants may be found in 40 CFR Part 136, if
� _ DEQ�
NORTH CAROLINA
oeo.meei of Environmental Want-
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000
DocuSign Envelope ID: 46F350B4-58BF-45E4-A4A8-994657E88AA2
there are additional pollutants with certified methods to be reported, please submit the Chemical Addendum to
NPDES Application and, if applicable, list the selected certified analytical method used.
TABLE 1. Speculative Limits for Town of Princeton WWTP (Proposed Expansion to 0.6 MGD)
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITS
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
0.6 MGD
BOD5, 20°C — Summer *
5.0 mg/L
7.5 mg/L
BOD5, 20°C — Winter *
10.0 mg/L
15.0 mg/L
NH3 as N - Summer *
1.0 mg/L
3.0 mg/L
NH3 as N - Winter *
2.0 mg/L
6.0 mg/L
Dissolved Oxygen (minimum)
Daily average > 6.0 mg/1
TSS
30 mg/L
45 mg/L
Total Residual Chlorine
28 ug/L
Fecal coliform (geometric mean)
200/100 mL
400/100 mL
Total Phosphorus
Monitor & Report
Total Nitrogen
5,561 lb/yr
Chronic Toxicity Pass/Fail (Quarterly test)
46%
*Summer: April 1 — October 31 * Winter: November 1 — March 31
TABLE 2. Speculative Limits for Town of Princeton WWTP (Proposed Expansion to 0.95 MGD)
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITS
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
0.95 MGD
BOD5, 20°C — Summer *
3.0 mg/L
4.5 mg/L
BOD5, 20°C — Winter *
6.0 mg/L
9.0 mg/L
NH3 as N - Summer *
1.0 mg/L
3.0 mg/L
NH3 as N - Winter *
2.0 mg/L
6.0 mg/L
Dissolved Oxygen (minimum)
Daily average > 6.0 mg/L
TSS
30 mg/L
45 mg/L
Total Residual Chlorine
28 ug/L
Fecal coliform (geometric mean)
200/100 mL
400/100 mL
Total Phosphorus
Monitor & Report
Total Nitrogen
5,561 lb/yr
Chronic Toxicity Pass/Fail (Quarterly test)
57%
*Summer: April 1 — October 31 * Winter: November 1 — March 31
Some features of the speculative limit development include the following:
D_E
NORTH CARCLINA
gaparhneM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000
DocuSign Envelope ID: 46F350B4-58BF-45E4-A4A8-994657E88AA2
• BOD Limits. The Division evaluates expanding discharges using a Level B model intended to assess
protection of the water quality standard for dissolved oxygen. The model used by the Division predicted
instream dissolved oxygen below the water quality standard of 5.0 mg/1 under both flow scenarios. Based on
the results of the model the Division recommends increasing the dissolved oxygen effluent limit to a daily
average greater than 6.0 mg/L. With this change, the model predicts the effluent concentrations will not
cause exceedances in the dissolved oxygen instream standard for both proposed flow scenarios. In accordance
with 15A NCAC 02B .0404 (c), the winter oxygen -consuming wasteload allocation shall not exceed two times
the summer oxygen -consuming wasteload limitations nor shall it be less restrictive than minimum treatment
requirements.
• NH3 Limits. In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution
considerations for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q10 streamflow
(chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow
(carcinogen, HH). Limitations for ammonia are based on protection of aquatic life utilizing an Ammonia
chronic criterion of 1.0 mg/1 (summer) and 1.8 mg/1 (winter). For municipals the Acute Ammonia limit
(Weekly Average) is derived by multiplying the Chronic limit (Monthly Average limit) multiplied by 3.
Using a Level B model, the summer ammonia limit was adjusted down to 1.0 mg/L to protect the water
quality standard for dissolved oxygen. In accordance with 15A NCAC 02B .0404 (c), the winter
oxygen -consuming wasteload allocation shall not exceed two times the summer oxygen -consuming
wasteload limitations nor shall it be less restrictive than minimum treatment requirements.
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES permit for
a new or expanding discharge will be issued with these speculative limits. Final decisions can only be made after the
Division receives and evaluates a formal permit application for the expanded discharge.
In accordance with North Carolina Administrative Code 15A NCAC 2H.0105(c), the most environmentally sound
alternative should be selected from all reasonably cost-effective options. Therefore, as a component of all NPDES
permit applications for new and expanding flow includes a detailed engineering alternatives analysis (EAA) that must
be prepared. The EAA must justify the requested design flow and provide an analysis of potential wastewater treatment
alternatives. A copy of the Division guidance for preparing EAA documents is attached and/or can be found online
at:
https://files.nc.gov/ncdeq/Surface%20Water%20Protection/NPDES/permits/eaa-guidance-20140501-
dwr-swp-npdes_ 13.pdf.
State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document may be required for
projects that: 1) involve $10 Million or more of state funds; or 2) will significantly and permanently impact 10 or
more acres of public lands. Please check with the DWR SEPA coordinator (David Wainwright, 919-707-9045) as to
whether your project requires SEPA review. For projects that are subject to SEPA, the EAA requirements discussed
above will need to be folded into the SEPA document. If required, a FONSI must be issued prior to issuance of the
NPDES permit for the expansion. Details related to FONSI can be found on-line at: https://deq.nc.gov/permits-
regulations/sepa/review-process and at: https://deq.nc.gov/about/divisions/water-infrastructure/documents/cdbgi-
fonsiea
We understand this expansion project is moving forward rapidly; however, we would expect that any request for
NPDES permitting action for the expansion be taken within a five-year period from the date of this letter, or the
noted speculative limits in Tables 1 & 2 would be subject to reassessment and review.
Should you have any questions about these speculative limits or NPDES permitting requirements, please feel free to
contact Kristin Litzenberger at (919) 707-3699 / kristin.litzenberger@ncdenr.gov or Michael Montebello at
Michael. Montebello@ncdenr. gov.
D_E
NORTH CARCLINA
gaparhneM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000
DocuSign Envelope ID: 46F350B4-58BF-45E4-A4A8-994657E88AA2
Respectfully,
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AAD'o''c''u..Siwwgne''d by:
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Michael Montebello
NPDES Program Branch Chief
Attachment: Link to EAA Guidance Document, Chemical Addendum Form, and NPDES application information:
http s : //deq.nc. gov/about/divisions/water-resources/water-quality-permitting/npdes-wastewater/npdes-permitting-process/npdes-individual-
permit-applications
ec: NPDES Files [Laserfiche]
Town of Princeton / Michael King [m.king@myprincetonnc.com]
Draper Arden Associates / Ethan Gartin, P.E. [egartin@trccompanies.com]
TRC / Steven Gandy, P.E. [sgandy@trccompanies.com]; Alison McLuckie [amcluckie@trccompanies.com]
DWR / Doug Dowden [doug.dowden@ncdenr.gov]; Derek Denard [derek.denard@ncdenr.gov]; Bradley Bennett
[bradley.bennett@ncdenr.gov]
RRO / Scott Vinson [scott.vinson@ncdenr.gov]; Vanessa Manuel [vanessa.manuel@ncdenr.gov]
NC WRC / Gabriela Garrison [gabriela.garrison@ncwildlife.org]
US FWS / Sarah McRae [sarah_mcrae@fws.gov]; Sara Ward [sara_ward@fws.gov]
DWR/Basinwide Planning, Francis Oggeri [francis.oggeri@ncdenr.gov]; Nora Deamer [nora.deamer@ncdenr.gov]
D_E
NORTH CARCLINA
gaparhneM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000