NC0086924_Issuance of Permit_20010323

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State of North Carolina
Department of Environment
A . .A .
and Natural Resources V
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary NCDENR
Kerr T. Stevens, Director
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
March 23, 2001
Mr. J.D. Brickhouse. County Administrator
Tyrrell County
108 S. Water Street
Columbia, North Carolina 27925
Subject: NPDES Permit Issuance
Tyrrell County Reverse Osmosis Discharge
Permit No. NC0086924
Tyrrell County
Dear Mr. Brickhouse:
In accordance with the application for discharge permit, the Division is forwarding
herewith the subject NPDES permit. This permit is issued pursuant to the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina
and the U.S. Environmental Protection Agency dated May 9, 1994.
The Division of Water Quality received significant comments from the Division of Marine
Fisheries (DMF) regarding the potential impact of the discharge into Bull Bay. The DMF had
requests for more extensive monitoring to determine the potential impact to the ecosystem. Based
on their concerns and comments, as well as the Division of Water Quality's concerns that limits
can be consistently met, the permit has been modified as follows:
• The predicted salinity of the discharge is a.concern in this area. Predicted values are higher
than current values in the area due to the fresh water inflow from Bunton and Deep Creeks
into Bull Bay and may have an adverse effect on aquatic life. Because there is uncertainty in
predicting the full extent of this type of discharge, instream monitoring for salinity at various
areas in the Bay is required. Special Condition A.4. has been inserted into the permit
indicating the instream monitoring locations and frequencies. Tyrrell County may request that
the Division re-evaluate the instream monitoring requirements after 2 years of data has been
collected.
▪ Another concern regarding the discharge is the elevated value of ammonia as nitrogen in the
deep well sample. This compound can adversely affect aquatic life and deplete oxygen levels in
Bull Bay. Monitoring for ammonia as nitrogen has been included in the permit. Instream
monitoring for dissolved oxygen, along with temperature, will be included as part of the
required monitoring in the special condition discussed previously.
• A settleable solids limit has been added to the permit. Should the county demonstrate that
there are not settleable solids in the effluent, after one year of data has been collected, the
county may request that monitoring for this parameter be reduced or eliminated from the
permit.
• An additional comment submitted by the DMF pertained to a holding basin or lagoon, sized to
• hold all effluent flow "until such times that dilution is maximized and impacts are minimized."
At this time, the Division is unsure of how long those times would be and when they would be,
so this condition has not been added to the permit. However, should the limits given in the
permit not be consistently met, the DWQ may require that a holding lagoon or other type of
treatment be installed at the plant.
• The DMF has requested that they be copied on, at minimum, all instream monitoring data.
Please forward copies of instream monitoring data in care of Sara Winslow, DMF, at the
address listed on the next page of this letter.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617-TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLO'itR-50%RECYCLED/10%POST-CONSUMER PAPER
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VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES ''

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Mr. Brickhouse
Page 2
Please take notice that this permit is not transferable except after notice to the Division of
Water Quality. The Division of Water Quality may require modification or revocation and
reissuance of the permit.
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or
any other federal or local governmental permit.
If you have any questions regarding the final NPDES permit, please contact Susan Wilson
at (919) 733 - 5083, extension 510.
Sincerely, FIP4"----
f €rrT. Stev!
cc: Central Files
Point Source Compliance and Enforcement Unit
Washington Regional Office/Water Quality Section/ Alton Hodge
',ODES Unit$
Aquatic Toxicology Unit
Eric Weatherly, HU&Ass. P.O. Drawer 1929
Nags Head. NC 27959
Robin Peele. DEH/PWS
Sara Winslow, Northern District Manager, DMF
P.O. Box 769
Morehead City. NC 28557

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Permit No. NC0086924
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended,
Tyrrell County
Tyrrell County Reverse Osmosis Water Treatment Plant Discharge
is hereby authorized to discharge wastewater from a facility located at
Tyrrell County RO Plant
Off NCSR 1202
Tyrrell County
to receiving waters designated as Bull Bay in the Pasquotank River Basin
in accordance with the discharge limitations, monitoring requirements, and other conditions set
forth in Parts I, II, III, and IV hereof.
This permit shall become effective May 1, 2001.
This permit and the authorization to discharge shall expire at midnight on December 31, 2002.
Signed this day March 23, 2001.
64,,,„.,L 4 qtd,/,,a,„.
rr T. Stevens, Director
Division of Water Quality
frjfiti
By the Authority of the Environmental Management Commission
Tyrrell County Reverse Osmosis
NPDES Permit No. NC0086924

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Permit No. NC0086924
SUPPLEMENT TO PERMIT COVER SHEET
Tyrrell County Reverse Osmosis Water Treatment Plant
RO Reject Discharge Wastewater
is hereby authorized to:
1. After receiving an Authorization to Construct permit from the Division of Water Quality,
construct outfall and other applicable appurtenances for treatment of reverse osmosis
water treatment plant reject water to be located off NCSR 1202, Tyrrell County, and
2. Discharge reject wastewater from said treatment works at the location specified on the
attached map into Bull Bay which is classified SB waters in the Pasquotank River
Basin.
Tyrrell County Reverse Osmosis
NPDES Permit No. NC0086924

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J atitude' 35°56'16” Sub-Basin' 03-01-53
Facility .
Longitude: 76°21'1E3" Location r # •
Quad G29SW,Columbia West
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Stream Claw BB
geceiving Stream. Bull say, Pasquotank River Basin
.ermittedflow: 0.216 MGG Tyrrell County
Reverse Osmosis Reject Water
N00086924

A(1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall(s) serial number 001- Reverse Osmosis Reject
Water. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT DISCHARGE LIMITATIONS Monitoring Requirements
CHARACTERISTICS
• Measurement Sample
Monthly Average Daily Maximum_ Frequency Sample Type Location'
Flow(MGD) 0.216 MGD Continuous Recording I or E
Total Suspended Solids 30.0 mg/L 45.0 mg/L Monthly Grab E
Turbidity2 Monthly Grab E
Iron Monthly Grab E
Settleable solids 0.1 m1/1 0.2 ml/I Monthly Grab E
Dissolved Oxygen 1 Grab Instream
Temperature 1 Grab Instream
NH3-N Monthly Grab E
pH3 Monthly Grab E
Total Residual Chlorine Monthly Grab E
Aluminum Monthly Grab E
Arsenics 50 ug/L Monthly Grab E
Beryllium5 0.117 ug/L Monthly Grab E
Cadmium5 42 ug/L Monthly Grab E
Chromium (Total)5 Monthly Grab E
Cyanides 1 ug/L Monthly Grab E
Iron Monthly Grab E
Leads 221 ug/1 Monthly Grab E
Mercury5 0.025 ug/L Monthly Grab E
Nickels 75 ug/L Monthly Grab E
Seleniums 71 ug/L Monthly Grab E
Silvers Monthly Grab E
Zinc5 Monthly Grab E
Coppers Monthly Grab E
Salinity Monthly' Grab E&Instream
Chloride Monthly Grab E
TOC Monthly Grab E
Fluorides Monthly Grab E
Total Phosphorus Monthly Grab E
Acute Toxicity4 Quarterly Grab E
NOTES:
1 Sample Locations: I - Influent: E- Effluent. Instream- see Part I. Special Condition A.(4). for locations
and frequencies.
2 The discharge shall not cause the turbidity of the receiving water to exceed 25 NTU. If the turbidity
exceeds this level due to natural background conditions, the discharge level cannot cause any increase in
the turbidity of the receiving water.
3 The pH shall not be less than 6.8 standard units or greater than 8.5 standard units.
4 Acute Toxicity Monitoring (Mysid) 24hr P/F ® 90%, Quarterly: January. April, July, and October. See
Special Condition A(2).
5 Upon sampling for 12 months, the Permittee may request a review of reasonable potential for monitoring
and effluent limitations.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE
AMOUNTS.
Tyrrell County Reverse Osmosis
NPDES Permit No. NC0086924

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A (2). ACUTE TOXICITY PASS/FAIL MONITORING (QRTRLY)
The permittee shall conduct acute toxicity tests on a auarteriu basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute
Toxicity In A Single Effluent Concentration" (Revised-July, 1992 or subsequent versions). The
monitoring shall be performed as a Mysidopsis bahia 24 hour static test. The effluent
concentration defined as treatment two in the procedure document will be 90%. Effluent samples
for self-monitoring purposes must be obtained during representative effluent discharge below all
waste treatment. The tests will be performed during the months of January, April, July, and
October.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed. using the parameter
code TGE3E. Additionally, DWQ Form AT-2 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
is required, the permittee will complete the information located at the top of the aquatic toxicity
(AT) test form indicating the facility name, permit number, pipe number, county, and the
month/year of the report with the notation of"No Flow" in the comment area of the form. The
report shall be submitted to the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a valid test is submitted. Upon
submission of a valid test, this monthly test requirement will revert to quarterly in the months
specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be
re-opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the
month following the month of the initial monitoring.
A (3). DISCHARGE SPECIAL CONDITION
The effluent diffuser must be designed to prevent surface turbulence and bottom scour. Should
the location of the discharge cause visible turbulence within Bull Bay, the Division may require
that the discharge be relocated.
Tyrrell County Reverse Osmosis
NPDES Permit No. NC0086924

A (4). INSTREAM MONITORING REQUIREMENTS
The following parameters shall be monitored within Bull Bay (at the locations indicated) 2/month
year round. Stratified samples [surface (within 1 foot) and bottom) shall be taken for each
parameter.
Parameter Location Frequency Months
Salinity (ppt) B, DPt, Ml, 2/month January through
M2, M3, M4, December (year round)
M5, M6
Temperature(SC) B, DPt, Ml, 2/month January through
M2, M3, M4, December (year round)
M5, M6
D.O. (mg//) B, DPt, Ml, 27month January through
M2, M3, M4, December (year round)
M5, M6
B- Background sample should be taken at or near the mouth of Bunton Creek, in the estuary,
outside the influence of the discharge
DPt- at the discharge point (approximately 100 feet from the shoreline)
M 1 - along a southwest/northeast transect from the discharge point, approximately 50 feet
northeast of the discharge
M2 - along a southwest/northeast transect from the discharge point, approximately 200 feet
northeast of the discharge
M3 - along a north/south transect from the discharge point, approximately 50 feet north of the
discharge •
M4 - along a north/south transect from the discharge point, approximately 200 feet north of the
discharge
M5 - along a north/south transect from the discharge point, approximately 50 feet south of the
discharge
M6- along a northwest/southeast transect from the discharge point, approximately 50 feet
northwest of the discharge
Should instream monitoring indicate little to no effect of the discharge on the salinity or dissolved
oxygen of the receiving water after 2 years of monitoring, the permittee may request that the
monitoring requirements be re-evabinted.
NOTE: Map on the following page is not to scale. The transect attempts to approximate the
optimal sampling points for prevailing winds.
Tyrrell County Reverse Osmosis
NPDES Permit No. NC0086924

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A (4). INSTREAM MONITORING REQUIREMENTS (continued)
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Tyrrell County Reverse Osmosis
NPDES Permit No. NC0086924
I

• State of North Carolina •
Department of Environment
and Natural Resources
Division of Marine Fisheries
Michael F. Easley, Governor
1CDE11R
William G. Ross, Jr., Secretary NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Preston P. Pate, Jr., Director
MEMORANDUM 0 7
r�cu
CV ~
$ti
TO: David A. Goodrich " cc ,
Q n-
NC Division Of Water Quality
FROM: Preston P. Pate, Jr., Director
Division of Marine Fisheries
DATE: 3-2-01
SUBJ: NPDES / Tyrrell County Reverse Osmosis Treatment Plant
# NC 0086924
I have reviewed the comments provided by the District Manager and/or Bio-Supervisor
and concur with their recommendation(s).
- A/
Director, Date
Preston P.Pate, Jr.
Deputy Director, Date
Michael G. Bu
Ad. 3 2
• Habitat -rotection -ection Date
Section Chief,
Michael W. Street
P.O. Box 769, Morehead City, North Carolina 28557-0769 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper

YE
State of North Carolina
Department of EnvironmentA . A
and Natural Resources
Division of Marine Fisheries wit —2 im
Michael F. Easley, Governor } BITAT NCDENR
William G. Ross, Jr., Secretary/ RAF-HABITAT
NORTH CAROLINA DEPARTMENT OF
Preston P. Pate, Jr., Director ENVIRONMENT AND NEURAL RESOURCES
MEMORANDUM:
TO: David A. Goodric NC Division of Water Quality,NPDES Unit Supervisor
THROUGH: Mike St e , f, Habitat Protection Section
FROM: Sara E. Winslow,NC Division of Marine Fisheries,Northern District Manager
DATE: March 1, 2001
SUBJECT: Tyrrell County Reverse Osmosis Treatment Plant,
Draft NPDES Permit#NC0086924
The following comments by the North Carolina Division of Marine Fisheries (NCDMF)
on the subject permit are offered pursuant to G.S. 113-131. The NCDMF objects to the proposed
permit due to the toxic and habitat altering effects that the discharge will have on the biota of
Bull Bay and Albemarle Sound. NCDMF sample data indicate that Bull Bay is an important
nursery and adult foraging area for many commercially and recreationally important fishes (e.g.,
striped bass, white perch, yellow perch, catfish, alewife,blueback herring, American eel,blue
crab, spot, croaker, flounder, menhaden, sunfish(Lepomis sp.) and largemouth bass).
This project will degrade the receiving waters, severely affecting existing uses. Such
degradation is a violation of the federal Clean Water Act, as well as applicable state laws,rules,
and policies. The NCDMF is extremely concerned that the discharge (108,000 GPD initially and
216,000 GPD at design capacity) would even be considered given that the Division of Water
Quality (DWQ) "has concerns that the limits can be consistently met". The limits that may not
be consistently met were not identified in the permit. Therefore, design modifications should be
explored prior to permit issuance to assure: (1) that limits can be met at design capacity; and (2)
that the concerns identified in this correspondence are considered based on design capacity
discharge. It appears therefore that sufficient information exists to support that the discharge as
presented should not be allowed into this very low salinity estuarine (brackish water) system.
The potential toxicity to aquatic resources and habitat altering effects of ammonia(NH4),
a nutrient, in the discharge is a principle concern. The estimated discharge concentration of
ammonia(NH4) is 15.86 mg/l. The ammonia nitrogen(NH3-N) of well-oxygenated waters is
relatively low (Wetzel 1975). Ammonia, while in its ionized form,NH4, is relatively nontoxic to
aquatic life. However, ammonia it its un-ionized form,NH3, is very toxic. As pH increases
above 6.0 ammonia as NH4 readily converts to NH3. Ammonia(NH3) is acutely toxic to aquatic
organisms at 4.0 mg/1 and may stress or cause death in some organisms at much lower levels. As
P.O. Box 769, Morehead City, North Carolina 28557-0769 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper

part of the natural nitrogen cycle, ammonia is oxidized and converted to nitrite(NO2). Nitrite can
be toxic to aquatic species, and the toxicity increases as pH falls below 7.5. Even if the ammonia
and nitrite levels are not toxic or stressful,the discharge will likely produce a net decrease in
dissolved oxygen as oxygen is consumed through nitrification. Reduced oxygen levels may
stress aquatic organisms or cause fish kills. Ammonia/nitrogen is readily utilized in the growth
processes of submerged aquatic vascular plants (SAV)and phytoplankton(algae). The discharge
may contribute to increased growth of SAV and algae in the bay. Algal blooms of some species
can be toxic to aquatic species, cause disruption of the aquatic food chain, and further reduce
oxygen levels.
Another concern is that the salinity of the discharge will be considerably higher than the
receiving waters. If our estimates are correct,the salinity of the discharge will be approximately
14,576 mg/1(ppm)or 14.6 ppt. DMF water quality data(bottom sample 8-9 ft depth) from Bull
Bay(one mile north of the proposed discharge) show that salinity ranged from 0.3 - 6.0 ppt
during July- October of 1996 - 1999. Salinity in this area is normally at its peak level during the
summer-fall season. Salinity(ppt)ranges for each year were: 0.3 - 1.9 in 1996; 1.8 - 3.6 in 1997;
0.5 - 3.5 in 1998; and 0.4 -6.0 in 1999. Due to the influence of fresh water inflows from Bunton
and Deep creeks,natural background salinity at the discharge location should be less than these
sample data levels.
Many of the aquatic organisms endemic to this area are able to tolerate wide fluctuations
in salinity, however some species cannot. Prey items of larval and juvenile fishes could be
destroyed by the proposed discharge, and the eggs and larvae of some species would certainly be
affected. Also, the high salinity discharge will very likely disrupt the movement and migration
patterns of some fish species.
Another problem with the high salinity discharge is that salt water is heavier than fresh
water, and the discharge will likely produce or exacerbate(worsen) stratification of the water
column. A frequently occurring result of fresh water over salt water stratification is a condition
known as"dead water". "Dead water"is water that is hypoxic (low oxygen)or anoxic (no
oxygen). Hypoxic and anoxic conditions result in stress (e.g.,poor body condition,reduced
resistance to disease)or death to most aquatic organisms.
The problems with ammonia as previously discussed can be intensified by anoxic
stratification. Wetzel(1975)noted that where appreciable amounts of organic matter reach the
hypolimnion of stratified lakes,NH3-N tends to accumulate. The accumulation of NH3-N greatly
accelerates under anoxic conditions,resulting in a marked release of NH4 from the sediments.
Bull Bay is an embayment of the Albemarle Sound and has at times significant to little or
no inflow. Based on our knowledge of area waters,wind tides have a significant effect on water
levels and movement in Bull Bay. These wind tides may cause periods of stagnation(no flow or
little movement at times) and reverse flow in the discharge area; thus, significantly reducing
dilution and increasing impacts of the discharge on the aquatic ecosystem. Mixing in the
discharge area of Bull Bay is further restricted by an extensive 3-4 foot shoal that extends across
the bay. The only deep-water(10-15 ft.) inlet/outlet is through a relatively small channel in the
shoal. The dilution factor in the receiving waters will greatly influence the potential impacts of
the salinity and nutrient loading of the discharge. The salinity and nutrient concentrations of the
discharge compared to background levels are sufficient to cause any and all of the situations
described above. When combining the potential effects of salinity and nutrients, it appears they
may complement each other to enhance the cumulative negative impacts on the ecosystem.
P.O. Box 769, Morehead City, North Carolina 28557-0769 Telephone [phone] FAX [phone]
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The NCDMF offers the following recommendations prior to further action on this permit:
1) Alternatives to the proposed discharge to Bull Bay should be fully evaluated(e.g.,
discharge to a deep salt water aquifer,transporting the effluent to a more suitable discharge
point located away from fresh waters).
2) The permittee should be required to do an Environmental Impact Study or Environmental
Assessment to evaluate the impacts of the discharge on water quality and biota in Bull Bay
and Albemarle Sound.
3) All evaluations and testing to assess the impacts of the discharge should be done based on
worst case scenarios for the receiving waters and effluent design capacity of the system.
If the discharge is permitted over our strong objections.the NCDMF requests that the following
conditions be included in the effluent limitations and monitoring requirements.
1) Conduct a weekly biological assessment before and after the discharge begins to document
changes in water quality, fauna, and flora in Bull Bay,both upstream and downstream of the
discharge for a period of at least four years.
2) The effluent should be stored and discharged when conditions are such that dilution is
maximized and impacts are minimized. This will require regular monitoring of the receiving
waters to determine opportune conditions.
3) Add acute toxicity testing of the effluent prior to the initial discharge for aquatic species that
are endemic to Bull Bay for various dilution rates similar to those expected in the bay near the
discharge.
4) Add instream monitoring throughout the bay to include sampling at the surface and bottom of
the water column.
5) Add effluent and instream monitoring for ammonia,nitrite, nitrate, and total nitrogen.
6) Add effluent and instream monitoring for conductivity and salinity and the components that
make up salinity(i.e., Ca, Mg,Na,K, CO3,HCO3,SO4,and Cl).
7) Add instream monitoring for temperature,dissolved oxygen, and pH.
8) Add limits for settleable solids.
Literature Cited
Wetzel,R.G. 1975. Limnology. W.B. Saunders Company. 743 p.
•
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RE:RO PJants
•
• Subject: RE: RO Plants
Date: Tue, 13 Mar 2001 14:20:07 -0500
From: Ed Lawler<[e-mail]>
To: 'Susan Wilson' <[e-mail]>
Ms. Wilson,
Here's our best shot at estimating the costs associated with the containment
structures you requested.
Assumptions:
* shallow water table will require each structure to be built at grade
utilizing berms.
* additional land can be acquired adjacent to each site.
* Stumpy Pt. site is all wetlands and will require additional wetland
and CAMA permits
* The following unit cost estimetes were used:
* lagoon & liner @ $3.00/sq. ft.
* seeding of berm @ $5,000/ acre
* Stumpy Pt. piping @ $6,000, additional pump station @ $100,000
* Tyrrell Co. Piping @$10,000, additional pump station @ $150,000
* Engineering and contingencies @ 30%
Cost estimates are as follows.
* Stumpy Pt. w/ 5-day containment pond $192,000
* Stumpy Pt. w/ 30-day containment pond $375,000
* Tyrrell Co. w/ 5-day containment pond $550,000
* Tyrrell Co. w/ 30-day containment pond $2,047,000
The final assumption is that money is available.
Sincerely,
Ed
Original Message
From: Susan Wilson [mailto:[e-mail]]
Sent: Tuesday, March 13, 2001 12:57 PM
To: Ed Lawler
Subject: Re: RO Plants
How about looking at both a 5 day and 30 day holding time for both plants?
This
is similar to our requirements for spray discharges and will provide some
holding time should upsets or instream problems require. DWQ realizes that
30
day holding may not be an economically feasible option for Tyrrell, but
please
look into them and provide costs for lined basins (concrete or HDPE) .
I'm aware that monitoring at the discharge point is a good place to monitor.
However, DMF (as well as DWQ) would be interested in transects through the
area
to determine the influence of the mixing zone. Likely, from your response,
I'll
put a special condition in stating that we will determine exact locations at
a
later time (and that you or they will work with DMF and our folks to come up
with feasible locations) .
Ed Lawler wrote:
> Susan
>
V443
> An RO plant takes water from the ground and pushes the water through a ,. -
1 of 2 3/15/01 8:55 AM

RE:RO Plants •
> membrane. The membrane is fine enough to allow water to pass through but
> not the impurities in the ground water such as salts. The impurities pass
> straight through and are rejected in the discharge. The discharge during
> plant operation is continuous. A typical amount is that you can utilize 3
> gallons out of 4 gallons of ground water, the other gallon is discharge.
> The ground water impurities that were in the 4 gallons are concentrated
into
> the 1 gallon of discharge. RO treatment removes and discharges impurities
> continuously while conventional treatment removes impurities, concentrates
> them over time and then discharges a much higher concentration.
> Assume we are operating the plant 7/24. That means we are discharging 75
> gpm time 1440 minutes per day equals 108, 000 gal/day. It is impractical
> and has never been done to our knowledge to store the discharge. A lagoon
> sized to hold the discharge volume of varying duration ???? is impossible
to
> design for. What environmental conditions are favorable??? Salinity in
the
> Albemarle sound estuary typically demonstrates wide fluctuations in
salinity
•
> on a seasonable basis. After the water is stored, the discharge rate goes
> up proportionally.
> Regarding instream monitoring, both plants discharge to a bay which opens
to
> a sound. The monitoring locations are unlimited, however one would think
> that the area to monitor would be at the discharge location.
> Thanks
> Ed
> Original Message
> From: Susan Wilson [mailto:[e-mail]]
> Sent: Tuesday, March 13, 2001 11:19 AM
> To: [e-mail]
> Subject: RO Plants
> Ed,
> Here's the exact verbage of the comment regarding the holding basin.
> Please provide me with information as to if or if not the discharge will
> be continuous and the feasibility of a holding basin/lagoon at both
> sites.
> -"The effluent should be stored and discharged when conditions are such
> that dilution is maximized and impacts are minimized. This will require
> regular monitoring of the receiving waters to determine opportune
> conditions. "
> We'll likely add toxicity testing (full range) prior to operation and
> discharge. The permit already requires quarterly toxicity monitoring
> after discharge.
> Another comment ( we will include instream monitoring at both plants)
> was with regard to instream monitoring. If you can, please provide
> possible areas of instream monitoring around the discharge point which
> would provide the best information regarding salinity (to include
> surface and bottom) . It may be that we include this as a special
> condition and work with our folks and Marine Fisheries to assess the
> best areas for instream monitoring.
2012 3/15/01 8:55 AM

RE:Tyr%II Co and Dare Co.RO plants
• Subject: RE: Tyrrell Co and Dare Co. RO plants
Date:Tue, 6 Mar 2001 17:19:56 -0500
From:Ed Lawler<[e-mail]>
To: 'Susan Wilson' <[e-mail]>
Original Message
From: Susan Wilson [mailto:[e-mail]]
Sent: Monday, March 05, 2001 2:42 PM
To: [e-mail]
Subject: Tyrrell Co and Dare Co. RO plants
Ed (and please pass to Eric if necessary) :
I received significant comments from the Div. of Marine Fisheries that
we'll have to resolve prior to issuance. Here's what we are proposing
to try to expedite and resolve their concerns (could you please inform
your client) :
1) NH3-N monitoring will be required (why are the levels elevated in the
groundwater/well tests? - or what is typical) .
2) Salinity values are a concern (freshwater influence in this area and
values are currently fairly low) and instream monitoring will be
required for this parameter and possibly others(do the permittees
currenity have access to or own a boat?) . Also, could you please again
give me your RO concentrate estimates for salinity and how you arrived
at them?
3) Adding the requirement of a holding tank/equalization basin prior to
discharge to provide some opportunity for settling and a more
continuous/even flow. What size basin would you estimate?
Also, the plans and specs that I received recently for Tyrrell Co. - is
the proposed discharge point the same? (I have not yet opened the
plans) .
I'm still planning to submit this for issuance prior to March 15, but
need these items commented on prior to issuance.
Thanks.
Ms. Wilson,
I would like to respond to your concerns mentioned above.
1. )The Tyrrell County NH3 does appear to be high and I have called the
certified lab to check on the reported results. When we did a preliminary
aquifer (Castle Hayne) analysis from a similar deep well located on a fish
farm about a mile away the ammonia level was 1.63 mg/l. Still a bit high but
not 3.4 mg/l. Preliminary design indicates a concentrate (discharge) flow of
75.2 gpm with a TDS of 13,547mg/l.This number is derived from an RO design
program. You put in about 17 raw water elements and depending on what type
of membrane you select it generates the discharge concentration(s) . Thus far
the discharge points for Tyrrell & Dare are the same as what is dipicted on
the plans. I think the relatively shallow water allows for quicker
dispersion of the concentrate. Both sites should be able to supply some sort
of boat if monitoring requires.
The Dare County raw water analysis uses a completely different feed water
source to the membrane (Yorktown) . Their raw water analysis did not call for
an ammonia analysis.However, their projected discharge concentration is 4320
mg/1.TDS
I think items 2&3 refer to a NPDES application we have for a water treatment
I of 2 3/7/01 8:57 AM

• RE:Tyrrell Co and Dare Co.RO plants a
plant in Washington Co. The proposed discharge site is Kendrick Creek. Last
Friday (3/2) we got a list of alternatives from Mr. Goodrich and we are
working on that now. That plant has the backwash holding basin. The RO's
discharge as they process water.
I hope this clears things up but feel free to contact me if I can be of
further assistance.
Regards,
Ed Lawler
2 of 2 3/7/01 8:57 AM

Re:ammpnia
• Subject: Re: ammonia
Date: Mon,05 Mar 2001 11:27:23 -0500
From:Dianne Reid<[e-mail]>
To: Susan Wilson <[e-mail]>
CC: Matt Matthews<[e-mail]>,Jason Wynn <[e-mail]>
We have never had an saltwater ammonia standard, as far as I can tell. The
new EPA criteria is for freshwater only. EPA did promulgate national
criteria for ammonia in saltwater in 1989. However, from what I can tell
there was too much uncertainty around the calculations to give us any
comfort in defending the criteria.
EPA's criteria is in unionized ammonia and is 0.035 mg/L for the chronic
values. To get to total ammonia there are equations that are salinity,
temperature and pH dependent. For temperatures & pHs in the coastal
plain range, the total ammonia chronic standard would be between 5.3 mg/L
and 1.8 mg/L at 10 ppt salinity; 5.6 and 1.9 mg/L at 20 ppt salinity; and
5.9 and 2.0 mg/L at 30 ppt salinity. The lower values are summer time
temperatures. The lowest pH they use is 7.0 which may be a little high
for saltwater.
Susan Wilson wrote:
> Matt, way back when, did NC develop any criteria for ammonia in salt
> waters? i only see coastal plain and sandhills freshwaters (for the
> lower part of the state) - that Larry (or you and Larry) developed way
> back when.
> Dianne - do you have any info on ammonia in salt waters? and. . .i am
> having trouble making heads or tails out of the new proposed fed'l
> criteria (unless i sit here for a couple of hours reading it!) . but i
> also can't find in there its applicability to salt waters.
DIANNE REID
DWQ PLANNING BRANCH
DEPT OF ENVIRONMENT & NATURAL RES
1617 MAIL SERVICE CENTER
RALEIGH NC 27699-1617
(919) 733-5083 ext. 568
(919) 715-5637 (fax)
"At one time, one blade of grass is as effective as a sixteen-foot
golden Statue of Buddha. At another time, a sixteen-foot golden
Statue of Buddha is as effective as a blade of grass. " WU-MEN
1 A1 3/5/01 12:17 PM

•
//0111174111116. NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
North Carolina
MARINE
DIVISION OF MARINE FISHERIES
FISHERIES HABITAT PROTECTION SECTION
POST OFFICE BOX 769
MOREHEAD CITY,NC 28557
•
arc '�` 1-800-682-2632 OR 252-726-7021
FAX:[phone]
�.--,
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From:
amFrom: /(--1) /v-e e Cee f vrc
Date: 2-0-01
Number of Pages Including Cover Sheet: .
Urgent FYI Per Your Instructions Please Reply Please Comment
* * * **.* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * •7t * * * * * * *
7.4
•
•
•
TO'd 00:ZT TO. Z JEN ZZTSZZZZSL:xed S1ti3ddd/SQNd1H(1S JNQ

•
State of North Carolina
Department of Environment AT;14-X
1,14 16\
and Natural ResourcA..s +
Division of Marine Fisheries
Michael F. Easley, Governor WCDENR
William G. Ross, Jr., Secretary N5LINA BERARThENT e�
Preston P. Pate, Jr., Director ENVIRot.iMEtfr AND Nut,REsounCEs
MEMORANDUM:
TO: David A. Goodric NC Division of Water Quality,NPDES Unit Supervisor
THROUGH: Mike S -e , f,Habitat Protection Scetion
FROM: Sara E. Winslow,NC Division of Marine Fisheries, Northern District Manager
DATE: March I,2001
SUBTECT: Tyrrell County Reverse Osmosis Treatment Plant,
Draft NPDES Permit#NC0086924
The following comments by the North Carolina Division of Marine Fisheries (NCDMF)
on the subject permit arc offered pursuant to G.S. 113-131. The NCDMF objects to the proposed
permit due to the toxic and habitat altering effects that the discharge will have on the biota of
Bull Bay and Albemarle Sound. NCDMF sample data indicate that Bull Bay is an important
nursery and adult foraging area for many commercially and recreationally important fishes (e.g.,
striped bass,white perch, yellow perch,catfish, alewife,blueback herring,American eel,blue
crab, spot, croaker, flounder,menhaden, sunfish(Lepomis sp.) and largemouth bass).
This project will degrade the receiving waters, severely affecting existing uses. Such
degradation is a violation of the federal Clean Water Act,as well as applicable state laws, rules,
and policies. The NCDMF is extremely concerned that the discharge(108,000 GPD initially and
216,000 GPD at design capacity) would even be considered given that the Division of Water
Quality(DWQ)"has concerns that the limits can be consistently met". The limits that may not
be consistently met were not identified in the permit. Therefore, design modifications should be
explored prior to permit issuance to assure; (1) that limits can be met at design capacity; and (2)
that the concerns identified in this correspondence are considered based on design capacity
discharge. It appears therefore that sufficient information exists to support that the discharge as
presented should not be allowed into this very low salinity estuarine(brackish water) system.
The potential toxicity to aquatic resources and habitat altering effects of ammonia(NF14),
a nutrient,in the discharge is a principle concern. The estimated discharge concentration of
ammonia(NH4) is 15.86 mg/1- The ammonia nitrogen(NII3-N)of well-oxygenated waters is
relatively low(Wetzel 1975). Ammonia,while in its ionized form,NIL,is relatively nontoxic to
aquatic life. However, ammonia it its un-ionized form,NH3,is very toxic. As pH increases
above 6.0 ammonia as NH4 readily converts to NH3, Ammonia(NH3)is acutely toxic to aquatic
organisms at 4.0 mg/1 and may stress or cause death in some organisms at much lower levels. As
P.O. Box 789, Morehead City, North Carolina 28557-0769 Telephone [phone] FAX [phone]
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•
part of the natural nitrogen cycle, ammonia is oxidized and converted to nitrite(NO2). Nitrite can
be toxic to aquatic species, and the toxicity increases as pH falls below 73. 'Even if the ammonia
and nitrite levels are not toxic or stressful,the discharge will likely produce a net decrease in
ra„wrr�Y.oa entysed em a igen is consumed through nitrification. Reduced oxygen levels may
stress aquatic organisms or cause fish kills. Ammonia/nitrogen is readily utilized in the growth
processes of submerged aquatic vascular plants(SAV) and phytoplankton(algae). The discharge
may contribute to increased growth of SAV and algae in the bay. Algal blooms of some species
can be toxic to aquatic species, cause disruption of the aquatic food chain, and further reduce
oxygen levels.
Another concern is that the salinity of the discharge will be considerably higher than the Nu f, A
receiving waters. If our estimates are correct, the salinity of the discharge will be approximately mice,c:Ee
14,576 mg/I(ppm) or 14.6 ppt. DMF water quality data (bottom sample 8-9 ft depth)from Bull Goon
Bay(one mile north of the proposed discharge) show that salinity ranged from 0.3 -6.0 ppt
during July-October of 1996- 1999. Salinity in this area is normally at its peak level during the Cr ES
summer-fall season. Salinity (ppt)ranges fox each year were: 0.3 - 1.9 in 1996; 1.8 - 3.6 in 1997; tptley,,crE >
0.5 - 3.5 in 1998; and 0.4 - 6.0 in 1999. Due to the influence of fresh water inflows from Bunton prs 68751
and Deep creeks,natural background salinity at the discharge location should be less than these
sample data levels.
Marty of the aquatic organisms endemic to this area are able to tolerate wide fluctuations
in salinity,however some species cannot, Prey items of larval and juvenile fishes could be
destroyed by the proposed discharge, and the eggs and larvae of some species would certainly be
affected. Also, the high salinity discharge will very likely disrupt the movement and migration
patterns of some fish species.
Another problem with the high salinity discharge is that salt water is heavies than fresh
water, and the discharge will likely produce or exacerbate(worsen) stratification of the water
column. A frequently occurring result of fresh water over salt water stratification is a condition
known as"dead water". "Dead water"is water that is hypoxic (low oxygen)or anoxic (no
oxygen). Hypoxic and anoxic conditions result in stress(e.g.,poor body condition, reduced
resistance to disease) or death to most aquatic organisms.
The problems with ammonia as previously discussed can be intensified by anoxic
stratification. Wetzel(1975)noted that where appreciable amounts of organic matter reach the
hypolimnion of stratified lakes, Nld3-N tends to accumulate. The accumulation of N1-13-N greatly
accelerates under anoxic conditions, resulting in a marked release of NH4 from the sediments.
Bull Bay is an embayment of the Albemarle Sound and has at times significant to little or
no inflow. Based on our knowledge of area waters,wind tides have a significant effect on water
levels and movement in Bull Bay. These wind tides may cause periods of stagnation(no flow or
little movement at times)and reverse flow in the discharge area; thus,significantly reducing
dilution and increasing impacts of the discharge on the aquatic ecosystem. Mixing in the
discharge area of Bull Bay is further restricted by an extensive 3-4 foot shoal that extends across
the bay, The only deep-water(10-15 ft) inletloutlet is through a relatively small channel in the
shoal. The dilution factor in the receiving waters will greatly influence the potential impacts of
the salinity and nutrient loading of the discharge, The salinity and nutrient concentrations of the
discharge compared to background levels are sufficient to cause any and all of the situations
described above. When combining the potential effects of salinity and nutrients, it appears they
may complement each other to enhance the cumulative negative impacts on the ecosystem.
P.O. eox 769, Morehead City, North Carolina 28557-0769 Telephone [phone] FAX [phone]
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•
The NCDMF one the following recommendations prix to 's nennit:
1) Adummalvestnifte proposed discharge to Bull Bay should be fully evaluated(e.g.,
discharge to a deep salt water aquifer,transporting the effluent to a more suitable dischalee
point located away from fresh waters).
2) The permittee should be required to do an Environmental Impact Study or Environmental
Assessment to evaluate the impacts of the discharge on water quality and biota in Bull Bay
and Albemarle Sound.
3)All evaluations and testing to assess the impacts of the discharge should be done based on
worst case scenarios for the receiving waters and effluent design capacity of the system.
Ktheitischaegelutimidegjayasematrong objections,the NCDMP requests that the following
conditions be included in the effluent limitations and monitoring requirernen s.
1) Conduct a weekly biological assessment before and after the discharge begins to document
changes in water quality,fauna,and flora in Bull Bay,both upstream and downstream of the
discharge for a period of at least four years.
2) The effluent should be stored and discharged when conditions are such that dilution is
maximized and impacts are minimized. This will require regular monitoring of the receiving •
waters to determine opportune conditions.
3) Add acute toxicity testing of the effluent prior to the initial discharge for aquatic species that
arc endemic to Bull Bay for various dilution rates similar to those expected in the bay near the
discharge.
4) Add instream monitoring throughout the bay to include sampling at the surface and bottom of
the water column.
5) Add effluent and instream monitoring for ammonia,nitrite,nitrate,and total nitrogen.
6) Add effluent and instream monitoring for conductivity and salinity and the components that
make up salinity(i.e., Ca,Mg,Na,K,CO3,HCO3,SO4,and Cl).
7) Add instream monitoring for temperature,dissolved oxygen, and pH.
8) Add limits for settleable solids.
Literature Cited
Wetzel,R.G. 1975. Limnology. W.B. Saunders Company. 743 p.
P.O. Box 769, Morehead City,North Carolina 28557-0769 Telephone [phone] FAX [phone]
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Comments on Tyrrell WTP
Subject: Comments on Tyrrell WTP
Date: Fri,02 Mar 2001 17:40:41 -0500
From:Lynn Henry <[e-mail]>
Organization: NC Division of Marine Fisheries
To: Susan A Wilson <[e-mail]>
Susan,
I sent the Tyrrell Co. RO WTP comments to Morehead for approval and they Faxed them this afternoon
(Friday). I was told they faxed 2 copies. The final copy is the one that has "dissolved oxygen" in Item#7
on the last page. I omitted this on one of the copies.
Thank you in advance for your consideration of these comments.
Thanks for the additional info. on Stumpy Point, I guess it is too late to comment on that permit.
The ammonia level for the Tyrrell Co. raw water is 3.4 mg/I. I don't consider that as low. When U look up
the fed. doc. on ammonia let me know what U find.
LYNN
Lynn Henry < [e-mail]>
Marine Biologist
NC Division of Marine Fisheries
1 of 1 3/5/01 8:20 AM

F01 NC Division of Water Quality may
r e1 decide to hold a public meeting for
NORTH CAROLINA \ the proposed permit should the Divi-
WASHINGTON COUNTY. �' sion receive a significant degree of
public interest.
Copies of the draft permit and •
AFFIDAVIT OF PUBLICATION other supporting information on file
used to determine conditions present
in the draft permit are available upon
Before the undersigned,a Notary Public of said County and request and payment of the costs of
State,duly commissioned,qualified,and authorized by law reproduction. Mail comments and/or
to administer oaths,personally appeared requests for informationto the NC
Division of Water Quality at the.
ivu_si-- it 111 . , above address or call Ms. Christie
• Jackson at(919)7335083,extension
• 538.Please include the NPDES per-
who being first duly sworn,deposes and says:that he is pub- ! mit number (below) in any commu-
fisher of The Roanoke Beacon engaged in the publication of nication_ Interested persons may
a newspaper known as The Roanoke Beacon,published,is- also visit the Division of Water Qual-
sued,and entered as periodical mail in the Town of Plymouth, ity at 512 N. Salisbury Street, Ra-
in said County and State;that he is authorized to make this leigh, NC 27604-1148 between the
affidavit and sworn statement;that the notice or other legal , hours8:00 a.m. and 5:00 p.m. to
review information on file.
advertisement, a true copy of which is attached hereto,was NPDES Permit' Number •
pushed in The Roanoke Beacon on the following dates:
4 NC0086924, Tyrrell County/Tyrrellj
t County Reverse Osmosis Water
Cl o�OG I Treatment Plant, P.O. Box 449, Co
lumbia, NC 27925 has applied for 4.*
new permit for a facility locatbd i ..
Tyrrell County discharging treated YY/
wastewater into Bull Bay in the—C4
Pasquotank River Basin. Currently• r"
and that said newspaper in which such notice,paper,docu some metals parameters are water 'f9
ment,or legal advertisement was published was,at the time quality limited. This discharge may T„
of each and every such publication,a newspaper meeting all affect future allocations in this porgy '4
of the requirements and qualifications of Section 1-597 of lion of the receiving stream.
the General Statutes of North Carolina and was a qualified NPDES Permit Number 4
newspaper within the meaning of Section 1-597 of the Gen t 14.4087009, Washington County
(VP) P'O.Box 1007 Plymouth,N
eral Statutes of North C• - Ma. PUBLIC NOTICE i' 27962 has applied for a new permit ` `
STATE OF NORTH CAROLINA . for'a facility, located in Washington,_
This 1Lday of aNtu.Ck JI.Lc) ,20� ENVIRONMENTAL County discharging-treated wasterw
MANAGEMENT COMMISSIONV water into Kendrick,Creek in they
i,.0".—Z-- __di NPDES UNIT .• Pasquotank River Basin. Currently
1617 MAIL SERVICE CENTER no parameters are water quality limy
Sworn to and subscribed before me,this t k-- i RALEIGH, NC 27699-1617 • iced.This discharge mayaffect future
€ NOTIFICATION OF INTENT TO allocations in this portion of the re- Ma
day of Ct/Vl1..l , 20� t ' ISSUE A NPPERMIASTEWATEI2 ceiving stream. 01/17
On'the basis of.thorough staff;
``���r+"rrr' rr ttt��� review and application of NC Gen-
`.` d(��A•.. 0 ��,�Iotary Public eral Statute 143.21,Public law 92500,
�, -f- ', and other lawful standards and regu-,'•
MiC �••qne%G ireS`� Commission Expires June 2, 2� Cations the North Carolina Environ-''
• , Ql kerb _ mental Management Commission
.a. — • •U - proposes to issue a National Po(lut. ,;
c_• •' = ant Discharge.Elimination System
37. -•, 'U B l,'G : Z (NPDES)wastewater discharge per-
'. �- 4 mit to the person(s) listed below et-
°,
•• t" fective45 days from the publish date
�'0"j�L,i�•�•••'CCI\ �N.``� of this notice.
• 'ii�rrf�i� C'�,��`. Written comments.regarding the
rrtttitt
±r i• proposed permit will be accepted
until 3D days after the publish date
*,_ of this,potice.All comments received
prior to;that date are considered in
`Y•rthe final determinations regarding the
proposed permit.The Director of the

TYRRELL COUNTY RO REJECT WW
NC0086924 ( I
AMMENDMENT TO THE FACT SHEET
(2ti(o
The Division of Water Quality received significant comments from the Division of Marine
Fisheries (DMF) regarding the potential impact of the discharge into Bull Bay. The DMF
had requests for more extensive monitoring to determine the potential impact to the
ecosystem. Based on their concerns and comments, as well as the Division of Water
Quality's concerns that limits can be consistently met, the permit has been modified as
follows:
• The predicted salinity of the discharge is a concern in this area. Predicted values
are higher than current values in the area due to the fresh water inflow from
Bunton and Deep Creeks into Bull Bay and may have an adverse effect on aquatic
life. Because the full extent of this type of discharge cannot be assessed, instream
monitoring for salinity at various areas in the Bay is recommended. Special
Condition A.4. has been inserted into the permit indicating the instream monitoring
locations and frequencies. Tyrrell County may request that the Division re-evaluate
the instream monitoring requirements after 2 years of data has been collected.
• Another concern regarding the discharge is the elevated value of ammonia as
nitrogen in the deep well sample. This compound can adversely affect aquatic life
and deplete oxygen levels in Bull Bay. Monitoring for ammonia as nitrogen has
been included in the permit. Instream monitoring for dissolved oxygen, along with
temperature, will be included as part of the required monitoring in the special
condition discussed previously.
• A settleable solids limit has been added to the permit. Should the county
demonstrate that there are not settleable solids in the effluent, after one year of data
has been collected, the county may request that monitoring for this parameter be
reduced or eliminated from the permit.
• An additional comment submitted by the DMF pertained to a holding basin or
lagoon, sized to hold all effluent flow"until such times that dilution is maximized
and impacts are minimized." At this time, the Division is unsure of how long those
times would be and when they would be, so this condition has not been added to
the permit. However, the Division does have continued concerns that this
wastewater may not consistently meet the limits presented in the permit. Should
the limits not be consistently met, the DWQ may require that a holding lagoon or
other type of treatment be installed at the plant.
• The DMF has requested that they be copied on, at minimum, all instream
monitoring data. Please forward copies of instream monitoring data in care of Sara
Winslow, DMF, at the address listed on the next page of this letter.
- mai& g6 cjE � AY�►A GN _ A RE SASSY pN *KT IG GG e � Su-/- 61
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DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0086924, Tyrrell County RO Plant
Facility Information
Applicant/Facility Name: Tyrrell County/Tyrrell Co. RO Plant Discharge WW
Applicant Address: P.O. Box 449, Columbia, NC 27925
Facility Address: Unknown at this time
Permitted Flow Variable -
Type of Waste: Non domestic
Facility/Permit Status: New
County: Tyrrell
Miscellaneous
Receiving Stream: Bull Bay Regional Office: WaRO
Stream Classification: SB Quad D33NE, Col West
303(d) Listed?: No Permit Writer: S. Wilson
Subbasin: 030153/ Pasq. Date: December 29, 200
Drainage Area (mi2): unknown
Summer 7Q10 (cfs) 0
Winter 7Q10 (cfs)
Average Flow (cfs):
IWC (%): 100
9x
Primary SIC Code:
SUMMARY
Tyrrell County proposes to discharge reject water from its RO plant. The county will tap the
deep Castle Hayne aquifer. The proposed plant is to be built in phases of 300 gpm production
up to 600 gpm production. The reject water is proposed as 75 gpm up to 150 gpm (0.108 to
0.216 MGD) to be discharged to Bull Bay.
Data was collected from the Castle Hayne aquifer and a predictive model was used to determine
the potential parameters of concern and their concentrations.
Due to the elevated chloride levels, the engineer states that land application is not a feasible
option (plus, loading rates would be restrictive). Connection to a POTW is not feasible due to
the distance. Discharge appears to be the most economically feasible, environmentally sound
alternative as long as limits are are attained.
This RO facility proposes no treatment; most other existing ROs have no treatment. The
Division does have concerns about the ability to consistently achieve limits imposed in the
permit. Due to the limited discharge options and the need for potable water in the county,
discharge appears to be the only option at this time.
TOXICITY TESTING:
Based on the ultimate reject flow of 0.216 MGD and current policy for RO plants, Quarterly
Acute Limit, P/F at 90%, mysid 24 hour testing will be required.
INSTREAM MONITORING:
No instream monitoring will be required.
PROPOSED REQUIREMENTS:
Per the Division's current policy regarding RO discharges, for the wasteflow of 0.216 MGD,
monthly monitoring will be required for all parameters of concern.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: January 17, 2001 (est.)
Permit Scheduled to Issue: March 3, 2001 (est.)
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if you any questions on any of the above information or on the attached permit. please
Contact Stieall Wilson at(919)733-5038 ext. 510. - ••
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•
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Tyrrell Co.RO WTP �1
NPDES Renewal
Page'

I Hobbs, Upchurch & Associates, P.A.
Consulting Engineers
2522 S.Croatan Highway • Suite 2A • P.O.Drawer 1929 • Nags Head,North Carolina 27959
November 15, 2000
5),ril___LI
Susan A. Wilson Id 1\ NOV 1 6 FIB
NCDENR
Division of Water Quality �-
NPDES Unit `�
1617 Mail Service Center
Raleigh,NC 27699-1617
RE: NPDES Permit Applications
Information Request/Reverse Osmosis
Tyrrell County RO Plant
NPDES Permit No. NC0086924
HUA No.: TY0001 —Permits
Dear Ms. Wilson:
Reference is made to your letter dated October 26, 2000 requesting additional
information for the above referenced project. The following information is provided in
reference to your comment letter regarding the Tyrrell County project.
Before addressing your specific comments, I wish to provide additional background
information. The original project was conceived in early 1999 and was proposed as a 300
gallon per minute pressure filtration and ion exchange softening plant utilizing waters
from the surficial aquifers. A Preliminary Engineering Report(PER)was written based
on this concept and grant applications were made for the newly passed Clean Water Bond
Funds and the N.C. Rural Economic Development Center. During the funding
application stages and as more and more data was collected in the region, it was the
primary concern of the County Commissioners to not install a conventional treatment
plant utilizing the surficial aquifers but instead to install a reverse osmosis water
treatment plant into the Castle Hayne aquifers. The reasoning was that the surficial
aquifers in the region are very limited in quantity and also tend to deteriorate over time in
quality primarily through upconing of chlorides from the lower aquifers. This is
presently being experienced at the County's existing plant just south of Columbia.
Reverse osmosis treatment technology is the only available technology to treat chlorides
and should be capable of meeting future regulations as they become more strenuous.
Nags Head,NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Southern Pines • Myrtle Beach • Raleigh • Charlotte

Susan A. Wilson
HUA No.: TY0001 —Permits
November 15, 2000
Page 2
The discharge for the conventional treatment process included backwash water from the
pressure filters and a brine solution from backwash of the ion exchange softening vessels.
This discharge was to be into the Scuppernong River. The PER contained in the attached
Engineering Alternatives Analysis (EAA) indicates the location of the original discharge.
Before converting the project to a reverse osmosis treatment technology, discussions with
the Division of Water Quality indicated that the Scuppernong River would not be suitable
for a reverse osmosis discharge and that the Albemarle Sound should be utilized. This
change has been approved by the funding agencies and we have since proceeded with the
application for a discharge into the Albemarle Sound. Additional background
information can be seen in various attachments to the EAA.
In addition to the change from conventional treatment to reverse osmosis treatment,the
Commissioners have asked us to size the plant to allow for future expansion. The first
phase of the plant is to be 300 gallons per minute as is documented in the NPDES permit
application. It is the desire of the Commissioners to allow for a future phase of the plant
for a total of 600 gallons per minute. This will allow the County to supplement the
existing water plant with water. The existing water plant is approximately 30 years old
and the wells are experiencing reduced flows and reduced water quality due to upconing
of chlorides. Secondly,a test well has now been dug at the actual treatment plant site and
samples taken from the aquifers to be utilized for the project. The results indicated that
the plant could be designed for an 80%recovery instead of the 75%recovery in the
original NPDES application. This means that an additional 5%of the water can be used
as potable water and the discharge amount is reduced by 5%. For example,the original
concept of 75%would result in wells that produce 400 gallons per minute with 300
gallons per minute as potable water and 100 gallons per minute as concentrate discharge.
At 80%recovery,the project will now utilize 375 gallons per minute wells with 300
gallons per minute of potable water and 75 gallons per minute of discharge water. In the
future when the plant is expanded, the discharge will increase from 75 gallons per minute
to 150 gallons per minute. :1; 5; '00 G a -->15 c*t a'5
The result of the above discussion is that the NPDES permit needs to be changed from
100 gallons per minute discharge to a 75 gallon per minute discharge with a future
expansion to 150 gallons per minute discharge. Please let us know how we can handle
this change and what information or changes we need to make to the discharge permit
application.
\\HUAKDH\projects\TYRRELL COUNTY\TY0001 Water System lmprovements\300 PERMITS\320 PERMIT APPLICATION-SUBMITTAL INFORMATION\N.C.
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES\WATER QUALITY\NPDES PERMITIEAA\WILSON.doc

Susan A. Wilson
HUA No.: TY0001 —Permits
November 15, 2000
Page 3
1. Item number 1 of your comment letter requests an Engineering Alternatives
Analysis Report. Please find this report attached as requested.
2. As previously discussed, an actual test well has now been performed at the
proposed water treatment plant site. The test well was constructed in early
October 2000, samples were collected on October 4, 2000, and the analysis was
received on October 25, 2000. The test well determined there were two water
bearings stratas in the area and are located at depths of 100-150 feet for the first
bearing strata and a depth of 405-480 feet for the second bearing strata. We
believe these stratas to be the Yorktown aquifer and the Castle Hayne aquifer
respectively. Attached for your use is the laboratory analysis of the constituents
from each aquifer. We propose to utilize the deep well strata or the Castle
Hayne for our reverse osmosis project. This aquifer had better yields and
should meet the future quantity needs of the project. Based on the deep aquifer,
a computerized reverse osmosis design program was utilized to project the
concentrate discharge for the project. Also attached for your use is a copy of
the program that illustrates the quality of the discharge. The results can be seen
on the second page listed under concentrate. The concentration of metals listed
in the raw water analysis can be converted to the discharge parameters by
multiplying by a factor of 5. For example, if copper and zinc were 0.005
milligrams/liter in the raw water,the discharge would be 0.025 milligrams per
liter. However, both copper and zinc were below detectable limts.
3. Item number 3 does not specifically apply to Tyrrell County; however, it is
pointed out that according to the computerized model, the pH of the discharge
will be 7.88.
4. The sounds in northeastern North Carolina are naturally shallow. At the point
of discharge, the depth ranges between 3-4 feet and fluctuates with the wind
tides. From our experience with the same discharge header at the Cape Hatteras
water treatment facility, the discharge header arrangement proposed creates
very little disturbance at the surface even in two feet of water. At the low flows
we are proposing at this water treatment facility, no disturbance would be seen
in two feet of water or greater. The arrangement of the discharge head also is
such to create no scouring to the sound floor.

Susan A. Wilson
HUA No.: TY0001 —Permits
November 15, 2000
Page 4
Please note that the drawings for the discharge contained in the EAA have been
revised to indicate a depth of three feet rather two feet based on actual field
measurements. To reach a depth of six feet of water, the pipeline would have to
be extended 1,600 feet. It is our experience and opinion that this discharge
header in three feet of water would provide adequate dispersion and dissolution
as well as minimize any surface turbulence and sound bottom scouring.
If you have any questions or if additional information is needed, please do not hesitate to
call.
Sincerely,
HOBBS, UPCHURCH& ASSOCIATES, P.A.
Eric T. Weatherly, P.E.
Division Manager
ETW/hb
Attachments
Cc: J.D. Brickhouse, Tyrrell County Administrator
\\HUAKDH\projects\TYRRELL COUNTY\TY000I Water System Improvements\300 PERMITS\320 PERMIT APPLICATION-SUBMITTAL INFORMATIONW.C.
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES\WATER QUALITY\NPDES PERMIT\EAA\WILSON.doc

Oct-25-OO 03 :03P EnviYOchem 910 392 4424 P. 01
envirochem Environmental Chemists, Inc.
. 6602 Windmill Way - Wilmington.north C:,nlina 2840
[phone](Lab) - [phone](Fax 1
CONSULTING Echem W @b0Lcom
CHEMISTS NCDENR: DWQ CERTIFICATE#94,DLS CERTIFICATE#37729
Customer:
SKIPPER'S WELL DRILLING Date of Report: October 25, 2000
P.O. Box 250 RESULTS TO DATE
Leland, N.C. 28480 Purchase Order No.:
Attu: Charlie Skipper •
Report Number: 0-3495
REPORT OF ANALYSES
Date Collected: 10/04/00 Report To: Charlie Skipper
Sampled By; Client Project; Tyrell County Wills
! /
1 WATER : Page 1 of 2
Sample ID Deep Well Shallow Well
• •8366 #8367
P-Alkalinity as CaC4,, mg/L <0.5 <0.5
Total Alkalinity as CaCo, mg/L 434 311
Carbonate, as CO3 mg/L 0 0
Hydroxide as OR nag/L 0 0
Total Hardness as CaCO, n'g/L 411 283
Calcium Hardness as CaCO3 mg/L 138 235
Magnesium as CaCO3 mg/L 273 48
Calcium,Ca smg/I. 55.3
94.0
Color,C.U.(Color Unita) 7 12
Silica as SiO0. mg/I, 18.6 23.3
Conductivity as 13mkos/cm 4522 708
i Irun. Fe mglI_, 0.030
3.28
' Potassium, K nig/L 75.3 ' 9.68
Copper, Cu mg/IL; <0.005 <0.005
Manganese,Mn mg/L. <0.005. 0.076
Phosphate,PO. setgfL <0.02 0.13
Chloride, C7- ingfL 1375 ba75452.9
fluoride,F n> 0.86 0.22
10/25/00 16:32 TX/RX NO.9101 - P.002 III

l u! �.�. �uC..G v-..- ----• -- - .
910 392 4424 P
Oct-25-00 03:03P EnvirDnhem
_02
en�Tirochem EnviEnvironmental Chemists, Inc.
6602 Windmill WAY • Wilmington.North Carolina 21(405
e [phone](Lab) • (910)39:--424(Fax)
Echem W<aol.cam
CONSULTING
CHEMISTS NCDENR: DWQ CERTIFICATE*94,DLS CERTIFICATE*37729
Customer: Skipper's Well Dniling Report 0-3495 Page 2 of 2
WATER:
Deep Well Shallow Well
Sample LD #8366 #8367
Nitrate Nitrogen,NO3-N mg/L 0.045 0.075
Zinc,Zn mg/L <0.005 <0.005
Chlorine(Free C13) mg!L <0.1 <Q.1
Ammonia as NH4 mg/L 3.4 0.6
0.030 0.025
Barium,B.a•:mglL
—
Hydrogen Sulfide as 112S 0.04 <0.01
Temperature as' C 16.7 16.7
Lead as Pb mg/L 0.019 0.014
Corrosiveness + 0.72 + 0.33
pH, units ___ 8.11 ' 7.73
pHs, units 7.39 7.44
Turbidity as N.T.U. 1.75 5.80 f
_Total Suspended Solids,TSS m /L
g
Total Dissolved Solids, TDS mg/L 2674 455
Sulfate as SO, mg/L
63 < 2
Sodium as Na mg/L 828 40.4
Sulfide as S mg/1. 0.4 < 0.01
Total Organic Carbon as TOC aag/L 3.5 6.4
TFLMFP - ..
TSM POTENTIAL a t pH=
Chlorine residual after incubation i
Chloroform µELL _ _
Bromoform µgJL ,
Cblorodibromomethane jtgfL - -
Bromodichloromcthane'AWL
TFPµg/L (as Chloroform)
TFPµMoles/L=TFP j /L as Ch11roform
119
•
•
10/25/00 16:32 TX/RX NO.9101 P.003 •

1-941-488-9400 941 P02 NOV 08 '00 16:09
Fluid Systems Corporation ROP O Ver. 6.1-CF _ Date: 08-1iov-2000
Project: Tyrrell County, NC Description: w/o blend, 80% rec.
Prepared By: Jon Type: Single Pass Design
PROJECT SUMMARY
PROCESS FLOW DIAGRAM
I1}--
13
14 - 0 [17}---�-
. .._- S it
DtSCHAvZGG
Fluid Systems
RO Recevozy [13/43 = 80.0% Overall System Rea (17/(4+15) 1 m B0.0%
Design Temperature m 16.7 Deg C
PASS 1
Array Recovery (13/4] m m 90.0%
Slewent Age = 0.00 Years
Fouling Allowance (FA) as 0.0%
Tubes Slams Avg
Sank Element Type /Bank /Tube Flux
(GTD)
1 ?TC 8822NR-365 8 7 15.0
2 TFC B821ULP-365 4 7 12.3
System/Pass Total 14.1
Pressure Floe Rate TDS 1800 Hardness Chloride
with FA
Stream (Prig) (USGPM) (ag/L) (CaO03) (mg/14
1 0.0 375.0 2745.73 411.1 1375.0
4 0.0 375.0 2745.73 411.1 1375.0
5 215.3 375.0 2763.28 411.1 1375.0
13 0.0 300.0 69.76 2.1 30.5
14 0.0 300.0 69.76 2.1 30.5
16 0.0 300.0 69.76 2.1 30.5
17 0.0 300.0 42.32 2.1 50.5
118 189.3 75.0 13347.49 2046.9 6752.91 DISCHA9-
11/08/00 16:08 TX/RX NO.9244 P.002

. 1-941-488-9400 941 P03 NOV 08 '00 16:09
Fluid Systems Corporation RDPOLO Ver. 6.1-CP Date: 09 Nov--2000
:Project: Tyrrell County, NC Description: w/o blend, 804 roc.
Prepared By: Jen Type: Single Pass Design
ARRAY S ThO RY - PASS 1
Permeate Plow 300.0 080PM Temp (Design/Amy) 16.7/ 16.7 Deg C
Pass Recovery 80.0% Fouling Allowance (TA) 0.04
Inlet Pres w/o PA 215.3 Psig Conc. Pres w/o PA 183.3 Psig
Inlet Pres w/TA 27.5.3 Psig
Tubes Elems Blame Elea Boost Manifold Perm Hank
Bank /element Type /Bank. /Tube /Bank Age Pressure Loss Pressure
(#) (8) (8) (Yr) ()laic') (Psig) (Psig)
1 TTC 862288-365 8 7 56 0.00 0.0 0.0 0.0
2 ?PC 8821ULP-365 4 7 28 0.00 0.0 0.0 0.0
Total Tube Total Tube Avg Inlet Avg Ban Winal
Bank Peed Teed Conc. Conc. Plum Pres NDP DP Slement
(GPO[) (OPIU (GPK) (GPK[) (G*'D) (Psig) (s.i9) (Psig) Beta
1 375.0 46.9 162.7 20.3 15.0 215.3 157.9 17.6 1.097
2 162.7 40.7 75.2 18.8 12.3 197.6 83.2 14.3 1.057
System 14.1 Dtscm • 9.c.
mem Feed RO Inlet Coat. Permeate
Stream NuMber 4 5 -38 13
Concentration (mg/L) (ward) (s9/L) (mg/L)
ca++ 55.30 55.30 275.35 0.29
+ 66.29 66.29 330.08 0.34
Na+ 828.00 828.00 4041.68 24.58
X+ 75.30 75.30 364.98 2.88
NH4+ 3.40 3.40 15.86 0.29
gr++ 0.00 0.00 0.00 0.00
Ha++ 0.03 0.03 0.15 0.00
pe++ 0.03 0.03 0.15 0.00
NM++ 0.00 0.00 0.00 0.00
CO3-- 0.00 0.56 2.80 0.00
8CO3- 529.09 464.43 2241.51 20.24
604-- 63.00 113.74 566.97 0.44
Cl- 1375.00 1375.00 6752.89 30.53
NO3- 0.05 0.05 0.23 0.01
p- 0.86 0.86 4.26 0.01
SiO2 18.60 18.60 91.13 0.47
CO2 7.75 54.01 34.01 53.95
Sum of Ions 3014.95 3001.59 14688.04 80.06
TD9 (180 C) 2745.73 2765.28 13547.49 69.76
pa 8.10 7.20 7.88 5.84
Hardness (as CaCO3) 411.09 411.09 2046.91 2.13
Osm Pressure (Psig') 29.01 28.77 140.78 0.77
Langlier Index 0.03 -0.13 1.95 -5.29
Stiff-Davis Index 0.83 -0.13 1.27 ---
Membrane bradata file version: Jun-12-00
Please review the Design Notes A Warnings page attached.
Concentrate exceeds solubility limit - see warnings sheet.
11/08/00 16:08 TX/RX NO.9244 P.003 II

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•
State of North Carolina
A4•;121s,
Department of Environment •
and Natural Resources y
Division of Water Quality
James B. Hunt,Jr., Governor NCDENR
Bill Holman, Secretary
Kerr T. Stevens, Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
October 26, 2000
Mr. Eric Weatherly
Hobbs, Upchurch &Associates, P.A.
2009 S. Croatan Highway
Kill Devil Hills, North Carolina 27948
Subject: NPDES Permit Applications
Information Request/ Reverse Osmosis
Dare County/ Stumpy Point RO Plant
NPDES Permit No. NC0086932
Tyrrell County RO Plant
NPDES Permit No. NC0086924
Dear Mr. Weatherly:
Letters of regiest for an NPDES permit, along with supporting information and fees, for both
the Dare County/ Stumpy Point and Tyrrell County Reverse Osmosis plants were received June 6,
2000. As these two projects are somewhat similar in scope, the comments below shall apply to both,
unless otherwise stated.
The following items will need to be resolved prior to drafting an NPDES permit for reject water
from the proposed reverse osmosis plants:
1.) Speculative limits were submitted to you May 3, 1999 for several reverse osmosis facilities,
which included both Dare County/ Stumpy Point and Tyrrell County. The Division is aware
that circumstances since that time have changed and the descriptions and speculative limits
given may not be applicable. However, in paragraph 3 of that letter, you were notified that any
permit package should include a summary of alternatives to surface water discharges. Review
of both application packages and supporting information did not reveal that alternatives were
addressed (with the exception of a brief paragraph in the cover letter discussing alternatives to
reverse osmosis water treatment). The Division understands that options in this area may be
limited, however, they must be addressed (ref. 15A NCAC 2H .0105(c)(2), a copy of the
Engineering Alternatives Analysis is attached with this letter].
2.) More information is needed regarding the projected concentrate water discharge at both
plants. Please provide information as to how the projected concentrates were determined.
Also, provide when and at what depth the samples were taken to predict the reject water
concentrates. The total analysis list should be provided: if values that are in the influent
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 919 733-5083,extension 510 (fax)919 733-0719
An Equal Opportunity Affirmative Action Employer [e-mail]

J
Mr. Eric Weatherly
Page 2 of 2
2.) Continued
water are projected to be zero (or below a minimum detection level) in the reject water, they
should be so noted. For example, were copper and zinc projected to be <2 ug/1 in the reject
water from the Tyrrell County plant and so were not listed or were they not tested for? Unless
information can be provided regarding all metal parameters, the permittee will likely be
subject to limitations on those metals until additional data is collected. For Dare County,
what is the projected concentration of the water from the iron filter backwash?
3.) The Division does have concerns with the projected reject water concentrations for copper and
zinc at the Dare County RO plant. Specifically, the project concentrations are listed as 2600
ug/1 for copper and 80 ug/1 for zinc. The county should be aware that North Carolina's action
level water quality standards for copper and zinc are 3 ug/1 and 86 ug/l, respectively. Unless
these concentrations are reduced in some manner, these elevated concentrations may effect
toxicity testing results which would be implemented in the permit. Additionally, North
Carolina's water quality standard for pH into saltwater bodies is 6.8 - 8.5 SU. The projected
pH value is 8.5 - 9.0 for the Dare county plant: instances of non-compliance may result from
this discharge, if not treated in some manner.
4.) The Division recommends that the diffuser be placed at a depth where the discharge would not
cause surface turbulence (the current proposal indicates a depth of 2 feet). Please consult
further with the Division's Washington Regional Office regarding potential location of the
discharge line and placement of the diffuser. Traditionally, the region has recommended a
minimum depth of 6 feet for discharges from diffusers into similar type waterbodies.
You may wish to discuss this further with Alton Hodge, Washington Regional Office, (252) 946-
6481 or me at [phone], ext. 510.
Sincerely,
san A. Wilson
NPDES Unit
cc: Al Hodge, Washington Regional Office/ Water Quality
J.D. Brickhouse, County Administrator Tyrrell County
P.O. Box 449
Columbia, NC 27925
Robert Oreskovich, Director Dare County Water Department
600 Mustian Street
Kill Devil Hills, NC 27948
Sid Harrell, DEH/ Parker Lincoln
NPDES Files

Hobbs, Upchurch & Associates, P.A.
Ili
,j
Consulting Engineers
2522 S.Croatan Highway • Suite 2A • P.O.Drawer 1929 • Nags Head, North Carolina 27959
August 17, 2000D � � � � --
r
David A. Goodrich AUG 2 1 2000 �.
NCDENR—Division of Water Quality
NPDES Unit DENR - WAT':t OUAL IT`S
1617 Mail Service Center FONT sr,:_=` f'' ;rCN
Raleigh,NC 27699-1617 ,;
RE: NPDES Permit Application NC0086924
Tyrrell County Reverse Osmosis WTP
Tyrrell County
HUA No.: TY0001 —Permits
Dear Mr. Goodrich:
Please find attached a letter from Robin Peele of the Public Water Supply Section, State
Revolving Fund Branch, regarding the discharge permit for the above referenced project. The
State Revolving Fund Branch has stipulated a deadline of March 14, 2001 to receive the NPDES
permit or grant funds will be withdrawn. Please contact me if there is any further information
that your staff needs in the evaluation of the discharge application.
Your assistance in this matter is greatly appreciated.
Sincerely,
HOBBS, UPCHURCH & ASSOCIATES, P.A.
Eric T. Weatherly, P.E.
Division Manager
ETW/hb
Attachment
Cc: J.D. Brickhouse, Tyrrell County Administrator
Al Hodge, Division of Water Quality, Washington Regional Office
Susan Wilson,NPDES Unit
II HUAKDHIprojecrs1 TYRRFiL COUNTYI TY000!Water System!mpro emeius1300 PEY.MJTS13I0 PERMIT APPLICATION-SUBMITTAL INFORWATIONW.C.DEPARTMENT OF
EMRONMENT AND NATURAL RESOURCFSIWATER QUALITYWPDES PER II1000DRICH.4.doc
Nags Head,NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Southern Pines • Myrtle Beach • Raleigh • Charlotte

a?. :. P .2 w 113
. i �:�
•_~11 `--" NORTH CAROLINA DEPARTMENT OF
Qi , ENVIRONMENT AND NATURAL RESOURCES
NCDENR DIVISION OF ENVIRONMENTAL HEALTH
PUBLIC WATER SUPPLY SECTION
July 31, 2000
1 7 ~.
JAMES B. HUNT JR. `' r PI ► ;'P��-i-: 1 1
;; The Honorable Thomas W. Spruill I
GOVERNOR .r.� `.
,.f1 Chairman of Board CommissionersA, A 1 r�„� ill
Tyrrell County
• :,�,,1 Post Office Box 449 ---,--:-,---7-: . .
BILL HOLMAN Columbia, North Carolina 27425 1" y�t.! %_ �"L..0
SECRETARY
N: :-,-,'ZZ Re: Water Supply
LINDA G. SEWALLty�t
.c.f� Loan and Grant Program
DIRECTOR ' ',_Project Number DEH-0710
;.1-',.i'<,4, Tyrrell County
7': -;; Dear Chairman Spruill:
JESSICA.G. MILES ,k,'�?
CHIEF '." -
,',.: ;.,i;.1 Your July 7, 2000 provisional plans and specifications approval allowed this project
" to retain its grant award. However, in accordance with G.S.159 G 8(b), G-9(3) and G-11
.---f1-1
= and 15A NCAC 1J .0303(c) and .0901(f), if you have not been issued the necessary
'1 National Pollutant Discharge Elimination System permit by March 14, 2001, your grant
L`�' award will be withdrawn for this round. However,this will not hinder any future consideration
' `• 1 for funding.
--, ;

• State of North Carolina
Department of Environment Al•and Natural Resources pDivision of Water Quality
James B. Hunt, Jr., GovernorI.ICDEIiIR
Bill Holman, Secretary NORTH CAROLINA DEPARTMENT OF
Kerr T. Stevens, Director ENVIRONMENT AND NATURAL RESOURCES
June 12,2000
Mr.J.D.Brickhouse
Tyrrell County Administrator
P.O. Box 449
Columbia,North Carolina 27925
Subject: NPDES Permit application NC0086924
Tyrrell County Reverse Osmosis WTP
Tyrrell County
Dear Mr. Brickhouse:
The Division received your permit application and fee of$715.00 (paid by check# 1090) on June 7,
2000. Thank you for submitting this package.
Ms. Susan Wilson of the NPDES Unit staff will review your application. Ms.Wilson will contact you if
further information is needed to complete the permit. Please note that the NPDES Unit has consistently had at
least 3 (and as many as 5) vacant positions since October 1998. Our remaining permit writers are currently
carrying extremely heavy workloads. While we do not expect severe delays in handling your request,be aware
that your request is one among many that our remaining staff must review.
The construction plans submitted with the application have been returned to your Authorized
Representative (Eric Weatherly of Hobbs,Upchurch&Associates). Plans and specifications for an
Authorization to Construct cannot be reviewed prior to the approval of the permit application. If technical
questions arise during the review of the application,we will handle them with your Authorized Representative.
If you have any additional questions concerning the subject application,please contact Ms.Wilson at
[phone],extension 510.
Sincerely,
r I, )7//' 1704W(17/ -
Charles H. Weaver,Jr.
NPDES Unit
cc: Central Files
la*•Paikeigb Regional Office,Water Quality Section
NPDES File 1
Eric Weatherly/Hobbs,Upchurch&Associates
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 919 733-5083,extension 511 (fax)919 733-0719
Visrr us ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES [e-mail]

964-t"
ll Memorandum
JIM 2 3 2000
June 20, 2000
POINT SOUkFL f; To: Daive Goodrich, S pervisor NPDES Permitting Unit
Thru: Roger K. Thorp , .E.,Permitting Group Leader, WARO
Attn: Mi mpleton,Environmental Engineer
From: Al Hodge,Environmental Engineer, WAROA,L.
Date: June 20, 2000
Re: Reverse Osmosis Discharge, Tyrrell & Dare County
Please find attached a copy of a letter from Mr. Eric T. Weatherly, P.E. of
Hobbs, Upchurch& Associates, regarding the funding and the NPDES permitting of
two proposed water treatment plants. One of the proposed plants is in Tyrrell and the
other in Dare County. Mr. Weatherly indicates that in order for Tyrrell County and
the Stumpy Point Water and Sewer District (SPW&SD)to receive a Clean Water
Bond grant a permit to construct from the Public Water Supply Section (PWSS)
must be issued. In order for PWSS to issue a permit to construct a water treatment
plant a method of disposal of any reject or backwash water is required. In this case,
an NPDES permit would be required. Mr. Weatherly acknowledges that it is
impossible to process the NPDES permit application by the PWSS deadline(July 7,
2000). Mr. Weatherly has contacted Mr. Tony Chen of the Public Water Supply
Section,which has agreed that a letter from the DWQ will be adequate for PWSS to
issue a construction permit. The letter should indicate that "it is possible" for an
NPDES permit to be issued in the aforementioned cases.
I am familiar with both the Tyrrell County and Stumpy Point sites. I believe
that it is not only possible, but also likely that an RO reject water discharge from the
water treatment plants can be permitted. The Tyrrell County site would discharge
directly to Bulls Bay in the Albemarle Sound and the SPW&SD would discharge in
to Stumpy Point Bay in the Pamlico Sound.
It is recommended a letter addressing the possibility of issuing an NPDES
permit for both theses sites be sent to Mr. Weatherly.
1

x r Hobbs, Upchurch & Associates P.A.
• • ' . . Consulting Engineers
,- _> '_ 2522 S.Croatan Highway • Suite 2A • P.O.Drawer 1929 • Nags Head,North Carolina 27959
May 24,2000 ---
L 'J U L1 ^i L 1
i L'n
!vli! JUN 5 2000 `moi
1
David A. Goodrich WASHINGTON REGIONAL OFFICE
NCDENR DWQ
Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh,NC 27699-1617
RE: RO WTP Concentrate Discharges
Tyrrell County and Dare County
HUA No.: TY0001 —Permits
DR0004—Permits
Dear Mr. Goodrich:
Tyrrell County and the Stumpy Point Water and Sewer District (Dare County) are
proposing to construct reverse osmosis water treatment facilities. On March 10, 2000,
both counties received grants from Clean Water Bond—DENR High Unit Cost Grant
Funds to construct their project. A stipulation of the grant is to receive the Public Water
Supply Section (PWSS)permit by July 7, 2000. Per a conversation with Mr. Tony Chen
of the PWSS, an NPDES permit will be required to receive a PWSS permit.
On May 15, 2000,the NPDES permit applications for both projects were submitted to the
NPDES Unit. On May 24, 2000,plans and specifications for both projects were
submitted to the NPDES Unit. Everyone understands that this does not allow the time
required to issue an NPDES permit. Mr. Tony Chen has agreed that a letter received
from your Unit by July 7, 2000 indicatinignainiferrnit will
be sufficient for the PWSS permit. This will allow the necessary time to hold public
hearings and/or address comments, etc.
Mr. Al Hodge of the Division of Water Quality, Washington Regional Office, is also
familiar with the projects and has visited the sites. Mr. Hodge pointed out that the
proposed projects are similar to previous projects with which he has been involved.
Nags Head, NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Southern Pines • Myrtle Beach • Raleigh • Charlotte

•
•
David A. Goodrich
HUA Nos.: TY0001 and DR0004
May 24,2000 •
Page 2
•
The following is a brief outline of the projects:
TYRRELL COUNTY
A grant was received in the amount of$1,874,375 from Clean Water Bond funds for the
construction of a 300 gallon per minute reverse osmosis water treatment facility, a
300,000 gallon ground storage tank,two groundwater wells, 8-inch water transmission
main and discharge.
Water will be supplied by two wells drilled into the Castle Hayne aquifer. Although
there is an ample supply of water in this aquifer,the chlorides are at a level which will
require membrane treatment.
The reverse osmosis concentrate discharge will be approximately 144,000 gallons per day
(100 gallons per minute)at full capacity. The proposed discharge will be into Bull Bay
-- off the Albemarle Sound. The discharge will consist of a 4-inch directionally bored pipe
from the shore into Bull Bay. We propose to locate the discharge approximately 100 feet
from the shoreline. A discharge header will be installed at the end of the pipe on the
bottom of the bay.
STUMPY POINT WATER AND SEWER DISTRICT (Dare County)
A grant was received in the amount of$1,901,845 from Clean Water Bond funds for
construction of a 50 gallon per minute reverse osmosis water treatment facility, 75,000
gallon elevated storage tank,two groundwater wells, 8-inch water mains and discharge to
serve the Stumpy Point Community.
Water will be supplied by two wells drilled into the Yorktown aquifer. Although there is
an ample supply of water in this aquifer,the chlorides are at a level, which will require
membrane treatment. The reverse osmosis concentrate discharge from the facility will be
approximately 38,880 (27 gallons per minute) gallons per day and a filter for iron
removal will have a backwash discharge of approximately 4,320 gallons per day at full
capacity.
We propose to locate the discharge in the Stumpy Point Bay near the intersection of N.C.
Highway 264 and Stumpy Point Road. The discharge will consist of a 4-inch
directionally bored pipe from the shore in the Stumpy Point Bay. The proposed

. ;Y
David A. Goodrich
HUA Nos.: TY0001 and DR0004
May 24, 2000
Page 3
•
discharge will be approximately 100 feet from the shoreline. A discharge header will be
installed at the end of the pipe on the bottom of the bay.
It is our opinion that any specific issues of these projects can be addressed given
sufficient time. However,the funding requirements are unique in that a short time frame
has been allowed by the grantors to receive an NPDES permit. Therefore, it is requested
that after your review of these projects and working through any major issues, letters be
written to the PWSS indicating that receipt of NPDES permits is possible.
The water treatment facilities for Tyrrell County and Stumpy Point are needed and will
not occur without the grant funds. Your assistance in meeting the grant requirements will
be greatly appreciated. If you have any questions or if additional information is needed,
please do not hesitate to contact me.
•
Sincerely,
HOBBS,UPCHURCH&ASSOCIATES, P.A.
Eric T. Weatherly, P.E.
Division Manager
ETW/hb
•
Cc: Tommy Stevens, Director, Division of Water Quality
Coleen Sullins, Chief, Water Quality Section
Tony Chen,Public Water Supply Section
Al Hodge,Division of Water Quality
Robin Peele, Public Water Supply Section
J.D. Brickhouse, Tyrrell County Administrator
Bob Oreskovich, Director, Dare County Water Department
Fred Hobbs,HUA
II HUAKDMProjectsDARE COUNI)IDR0004 Stumpy Point!i"onr&Sewer District CONMIXIMO.Water S :tem'.300 PE..RA4/7SI000DR/CH.3.duc

•
Tyrrell County Board of Commissioners -/t/0 �d
P. O. Box 449 , i5-; �o
Columbia, North Carolina 27925
Telephone[phone]
Thomas W.Spruill,Chairman Durwood M.Cooper,Jr.
Florence E.Bryant,Vice Chairperson Zacharias(Zack)Brickhouse
Nina B.Griswell Connie Hopkins,Clerk
June 2, 2000
Charles H. Weaver, Jr.
NCDENR/Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Permit Application
Tyrrell County Reverse Osmosis WTP
Tyrrell County
Return # 2075
Dear Mr. Weaver:
Tyrrell County wishes to designate Hobbs, Upchurch & Associates, P.A.
as the Authorized Representative for the above referenced project.
Please let me know if further information is needed.
Sincerely,
. D. Brickhouse
County Administrator
Cc: Eric Weatherly, Hobbs, Upchurch, & Associates, P.A. "L U-"c

IjHobbs, Upchurch & Associates, P.A.
Consulting Engineers
2522 S.Croatan Highway • Suite 2A • P.O.Drawer 1929 • Nags Head,North Carolina 27959
June 5, 2000
Charles H. Weaver, Jr.
NCDENR/Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh,NC 27699-1617
Alit:Alit:C
RE: NPDES Permit Application .r i
Tyrrell County Reverse Osmosis WTP 13 , . ` -i0 I
Tyrrell County h ^ r.^
Return#2075 pi ._______J
HUA No.: TY0001 —Permits I r r,° "''ti
m
Dear Mr. Weaver:
As per your comment letter dated May 30, 2000, the following is enclosed regarding the
above referenced project:
• Letter from Tyrrell County designating Hobbs, Upchurch&Associates, P.A. as
the Authorized Representative for this project
• Check#1090 in the amount of$715.00
• The original submittal package (3 sets of plans and specifications)
• The original NPDES Permit application
Please contact me if further information is needed.
Sincerely,
HOBBS, UPCHURCH & ASSOCIATES, P.A.
� ....---)
Eric T. Weatherly, P.E.
Division Manager
Cc: J.D. Brickhouse, Tyrrell County Administrator
II HUAKDHIorojects1 TYRRF1L COUN7YITY000I Waver System Improveme,ls1300 PERMITS 310 PERMIT APPIJCA77ON-SUBMITTAL INFORMATTONINPDES
PERA971WEAVENdoc
Nags Head,NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Southern Pines • Myrtle Beach • Raleigh • Charlotte

NC0086994(Tyrrell County)&NC0086932(Dare County/Stumpy Point)K.O.plants
Subject:NC0086924(Tyrrell County)+&NC0086932(Dare County/ Stumpy Point) R.O.plants
Date:Tue, 13 Jun 2000 14:15:14-0400
From:Charles Weaver<[e-mail]>
To:Susan A Wilson<[e-mail]>,Dave Goodrich<[e-mail]>
CC:Bill Reid<[e-mail]>
Susan,I put these two new applications in your box. They're both from Hobbs,Upchurch&Associates(HUA).
Mark provided spec limits for both plants earlier;however,the applications don't match the specs he provided to HUA.
• The Tyrrell County application is for an R.O.plant,at a different location(further downstream,apparently)from the spec.
request. The spec request was for a conventional WTP. The specs Mark prepared are probably no help for this applicatioif
• The Dare County application is for a plant with much higher reject flow than the specs allow. As the Dare County site
discharges to an SA water,I don't know if the specs Mark prepared can be changed.
According to Eric Weatherly of HUA,Dare County needs a"response" from us by July 7th or they lose$4 million in grant funds to
build the facility. (The grant was awarded on Match 11th and no application was submitted to us until the end of May,but that's a
separate issue). At Eric's behest,I talked to Tony Chen in Public Water Supply. Tony says that we only need to agree(or disagree)
in general terms to the request in order for his folks to either award a construction permit or deny it. We don't need to provide a
(draft or final)NPDES permit,just an indication of whether or not one will be issued. I told him I didn't know if we could do that,
given the lateness of the submission from HUA and the a from the spec limitspxovi4,e4
There is grant money tied to the Tyrrell County request also,but no"deadline"has been communicated to me by the applicant or
Proceed as you see fit-I just wanted to give you what background I have on these.
CHW
1 ofl 6/13/00 2:15 PM

• •
PROJECTED CONCENTRATE WATER DISCHARGE QUALITY
PROPOSED REVERSE OSMOSIS WATER TREATMENT FACILITY
TYRRELL COUNTY,NC
May 3, 2000
yL
• Ca++ 285.79 mg/1
• Mg++ 288.78 mg/1
• Na 4,928.21 mg/1—
• K+ 318.79 mg/1
NH4+ -- 7.6 mg/1
• SR++ 600 mg/1
• Ba++ 2,740 mg/1
• Fe++ 242 mg/1
• Mn++ 22 mg/1
• CO3"" 2.8 mg/I
• HCO3"" 0.6 mg/1
• SO4- <0.1 mg/1
• Cl- 2.6 mg/1 —
• NO3" 0.08 mg/1
• F 50 mg/1
• Si02 8.5 - 9 mg/1
• Sum of Ions 15,284.29 mg/1
• TDS ( 180 C) 14,219.92 mg/1
• pH 7.88 mg/1
• Hardness (as CaCO3) 1,902.90 mg/1
• Langlier Index 1.99 mg/1
• Stiff-Davis Index 1.27 mg/1

To: Point Source Branch SOC Priority Project: Yes No _X_
NPDES Unit
Water Quality Section If "Yes", SOC No.
t U E I
Attn: MiSailftlkilappOWvironmental Engineer
NPDES Unit
Water Quality Section JUL 21
Date: 7-12-00
NPDES STAFF REPORT AND RECOMMENDATION
Tyrrell County DEP''_
Permit No. NC0086924
PART I - GENERAL INFORMATION
1. Facility and Address: Mr. J. D. Brickhouse, County Administrator, P.O.
Box 449, Columbia, North Carolina27925
2. Date of Investigation: site visited on several occasions
3. Report Prepared by: Al Hodge
4. Contact Person and Telephone Number: J.D. Brickhouse-252-796-1371, Eric
T. Weatherly, PE, Hobbs, Upchurch & Associates-252-441-3913
5. Directions to Site: Beginning at the intersection SR 1117 & SR 1200,
which is named Bay, in the northwest section of Tyrrell County, proceed
northeast along SR 1200 for approximately 0.3 miles to a private road on
the north side of the road, the water treatment plant is approximately
0.25 miles down this road; the discharge can be reached by continuing
along SR 1200 to its intersection with SR 1202, proceed along SR 1202 to
the terminus, the discharge line enters Bull Bay through a private lot
approximately 100 feet to the west of the end of SR 1202
6. Discharge Point ✓
Latitude: 35°-56'-16" Longitude: 76°-21-'-18"
Attach USGS map extract and indicate treatment facility site and
discharge point on map.
USGS Quad Name: Columbia West
7. Site size and expansion area consistent with application? Yes X No
If "No", explain:
8. Topography (relationship to flood plain included) : 20 ft. MSL
9. Location of nearest dwelling: Discharge line reaches Bull Bay through a
private lot, the water treatment plant is several hundred feet from a
dwelling
10. Receiving stream or affected surface waters: Bull Bay - Pasquotank River
Basin
a. Classification: SB
b. River Basin and Sub-basin No. 03-01-53
c. Describe receiving stream features and pertinent downstream uses:
full body contact, boating, fishing
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be Permitted: 144,000 gpd

•
b. Description of proposed wastewater treatment facilities: No
treatment proposed. Reject water from a Reverse Osmosis
c. Possible toxic impacts to surface waters: Additional analysis is
to be required. A conclusion can not yet be reached.
2. Residuals Handling and Utilization Disposal Scheme: N/A
3. Treatment Plant Classification (attach completed rating sheet) : N/A
4. SIC Code(s) : 4941
Wastewater Code(s) : 22
Main Treatment Unit Code: 00
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are
any public monies involved (municipals only) ? YES!
2. Special monitoring or limitations (including toxicity) requests:
Toxicity monitoring, Additional monitoring may be requested upon
additional analysis of reject water
PART IV - EVALUATION AND RECOMMENDATIONS: I have reviewed the application and
have the following concerns and questions:
• Please discuss the manner in which the "Projected concentrate discharge"
was arrived at;
1. At what depth was the sample taken for the reject quality
determination?
2. What is the possibility of finding a different aquifer with a
higher quality of raw water?
3. Where is the well located the samples were taken from?
4. Does the absence of several heavy metals in the projected
concentrate mean the parameter was below detection levels or
the parameter was not tested for?
• The location of the proposed discharge is undesirable. The diffuser should
be in a depth of water where the discharge would not cause surface
turbulence. The discharge should also be at a location that offers the best
possible dilution reasonable in the area. It is my opinion that this
discharge does not do this.
• Has the County secured permission from the private land owner through which
the discharge pipe line goes to reach Bull Bay?
I am unable at this time to make a recommendation until additional information
is submitted.
Signature of report preparer
A.-Water Quality Regional Supervisor
Date
NPDES Permit Staff Report
Version 10/92

.. .
.
1 Hobbs, Upchurch & Associates, P.A.
Consulting Engineers
2522 S.Croatan Highway • Suite 2A • P.O.Drawer 1929 • Nags Head,North Carolina 27959
May 24, 2000 Q [ Q W "_
[A
1 JUN - 1 2000 !,ii
it j
CET R - WATER OURMITY
David A. Goodrich FONT sut' ;t E,r_r_
NCDENR A X E
Division of Water Quality/NPDES Unit rn
iffiaffiraw
1617 Mail Service Center
Raleigh,NC 27699-1617
RE: RO WTP Concentrate Discharges
Tyrrell County and Dare County
HUA No.: TY0001 -Permits
DR0004-Permits
Dear Mr. Goodrich:
Tyrrell County and the Stumpy Point Water and Sewer District (Dare County) are
proposing to construct reverse osmosis water treatment facilities. On March 10, 2000,
both counties received grants from Clean Water Bond-DENR High Unit Cost Grant
Funds to construct their project. A stipulation of the grant is to receive the Public Water
Supply Section(PWSS)permit by July 7, 2000. Per a conversation with Mr. Tony Chen
of the PWSS, an NPDES permit will be required to receive a PWSS permit.
On May 15, 2000, the NPDES permit applications for both projects were submitted to the
NPDES Unit. On May 24, 2000, plans and specifications for both projects were
submitted to the NPDES Unit. Everyone understands that this does not allow the time
required to issue an NPDES permit. Mr. Tony Chen has agreed that a letter received
from your Unit by July 7, 2000 indicating it is possible to receive the NPDES permit will
be sufficient for the PWSS permit. This will allow the necessary time to hold public
hearings and/or address comments, etc.
Mr. Al Hodge of the Division of Water Quality, Washington Regional Office, is also
familiar with the projects and has visited the sites. Mr. Hodge pointed out that the
proposed projects are similar to previous projects with which he has been involved.
Nags Head,NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Southern Pines • Myrtle Beach • Raleigh • Charlotte

David A. Goodrich
HUA Nos.: TY0001 and DR0004
May 24, 2000
Page 2
The following is a brief outline of the projects:
TYRRELL COUNTY
A grant was received in the amount of$1,874,375 from Clean Water Bond funds for the
construction of a 300 gallon per minute reverse osmosis water treatment facility,a
300,000 gallon ground storage tank,two groundwater wells, 8-inch water transmission
main and discharge.
Water will be supplied by two wells drilled into the Castle Hayne aquifer. Although
there is an ample supply of water in this aquifer,the chlorides are at a level which will
require membrane treatment.
The reverse osmosis concentrate discharge will be approximately 144,000 gallons per day
(100 gallons per minute)at full capacity. The proposed discharge will be into Bull Bay
off the Albemarle Sound. The discharge will consist of a 4-inch directionally bored pipe
from the shore into Bull Bay. We propose to locate the discharge approximately 100 feet
from the shoreline. A discharge header will be installed at the end of the pipe on the
bottom of the bay.
STUMPY POINT WATER AND SEWER DISTRICT(Dare County)
A grant was received in the amount of$1,901,845 from Clean Water Bond funds for
construction of a 50 gallon per minute reverse osmosis water treatment facility, 75,000
gallon elevated storage tank,two groundwater wells, 8-inch water mains and discharge to
serve the Stumpy Point Community.
Water will be supplied by two wells drilled into the Yorktown aquifer. Although there is
an ample supply of water in this aquifer,the chlorides are at a level,which will require
membrane treatment. The reverse osmosis concentrate discharge from the facility will be
approximately 38,880 (27 gallons per minute) gallons per day and a filter for iron
removal will have a backwash discharge of approximately 4,320 gallons per day at full
capacity.
We propose to locate the discharge in the Stumpy Point Bay near the intersection of N.C.
Highway 264 and Stumpy Point Road. The discharge will consist of a 4-inch
directionally bored pipe from the shore in the Stumpy Point Bay. The proposed

•
•
David A. Goodrich
HUA Nos.: TY0001 and DR0004
May 24, 2000
Page 3
discharge will be approximately 100 feet from the shoreline. A discharge header will be
installed at the end of the pipe on the bottom of the bay.
It is our opinion that any specific issues of these projects can be addressed given
sufficient time. However, the funding requirements are unique in that a short time frame
has been allowed by the grantors to receive an NPDES permit. Therefore, it is requested
that after your review of these projects and working through any major issues, letters be
written to the PWSS indicating that receipt of NPDES permits is possible.
The water treatment facilities for Tyrrell County and Stumpy Point are needed and will
not occur without the grant funds. Your assistance in meeting the grant requirements will
be greatly appreciated. If you have any questions or if additional information is needed,
please do not hesitate to contact me.
Sincerely,
HOBBS,UPCHURCH& ASSOCIATES, P.A.
Eric T. Weatherly, P.E.
Division Manager
ETW/hb
Cc: Tommy Stevens, Director, Division of Water Quality
Coleen Sullins, Chief, Water Quality Section
Tony Chen, Public Water Supply Section
Al Hodge, Division of Water Quality
Robin Peele, Public Water Supply Section
J.D. Brickhouse,Tyrrell County Administrator
Bob Oreskovich, Director, Dare County Water Department
Fred Hobbs, HUA
IIHUAKDHIprojectstDARE COUNIYIDR0004 Stumpy Point Water&Sewer District Community Water Sy+steml300 PERMITSIGOODRJCH.3.doc

A
• • zo 7 jIHobbs, Upchurch & Associates, P.A.
Consulting Engineers
2522 S.Croatan Highway • Suite 2A • P.O.Drawer 1929 • Nags Head,North Carolina 27959
May 15, 2000
r1
J MAY 19 2000 "
David A. Goodrich
NCDENR
Division of Water Quality/NPDES Unit POIN SOURCE BRANC- WATER H
1617 Mail Service Center �'-.
Raleigh. NC 27699-1617
RE: NPDES Permit Application
Tyrrell County Reverse Osmosis Water Treatment Facility
Tyrrell County, NC
HUA No.: TY0001 —Permits
Dear Mr. Goodrich:
Tyrrell County has received a Clean Water Bond Grant for the construction of a new
reverse osmosis water treatment facility. The facility will serve the northwest section of
the County and will be located in the Bull Bay community area. The existing water
treatment facility is near capacity and the proposed treatment facility is needed to meet
the growing demands of the County.
The proposed reverse osmosis treatment facility will have a capacity of 300 gallons per
minute. Water will be supplied by two wells drilled into the Castle Hayne aquifer.
Although there is an ample supply of water in this aquifer, the chlorides are at a level
which will require membrane treatment. The reverse osmosis concentrate discharge from
the facility will be approximately 144,000 gallons per day at full capacity.
The proposed discharge will be into Bull Bay off the Albemarle Sound. The discharge
will consist of a 6-inch directionally bored pipe from the shore into Bull Bay. We
propose to locate the discharge approximately 100 feet from the shoreline into the Bay.
A discharge header will be installed at the end of the pipe on the bottom of the Bay.
The following information is attached:
• U.S.G.S. Quadrangle Map illustrating discharge location
• Anticipated discharge water quality
Nags Head,NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Southern Pines • Myrtle Beach • Raleigh • Charlotte

•
`•. • •
David A. Goodrich
HUA No.: TY0001 —Permits
May 15, 2000
Page 2
Your attention to this matter is greatly appreciated. If you have any questions or if
additional information is needed, please do not hesitate to call.
Sincerely,
HOBBS, UPCHURCH & ASSOCIATES, P.A.
j.
Eric T. Weatherly, P.E.
Division Manager
ETW/hb
Attachments
Cc: J.D. Brickhouse, Tyrrell County Administrator
II HUAKDHIprojectsITYRRELL COUNTYITY0001 Water System lmprovements1300 PERA97SIGOODR1CH.doc

2.....D
•
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State of North Carolina 9°'"
Department of Environment
and Natural Resources ' •
Division of Water Qualitygatiorimogim
f
James B. Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary NORTH CAROLINA DEPARTMENT OF
Kerr T. Stevens, Director ENVIRONMENT AND NATURAL RESOURCES
May 3, 1999
Mr. Eric T. Weatherly. P.E.
Hobbs, Upchurchd`?Associates. P.A.
2009 S. Croatan Highway
P.O. Drawer 429
Kill Devil Hills, North Carolina 27948
Subject: Speculative Limits Request
Proposed Dare County RO
Proposed Camden County RO
Proposed Tyrrell County WTP
Dear Mr. Weatherly:
On April 1. 1999, the Division received three requests for speculative effluent limitations,
one for each of the above referenced facilities.
Based on available information and current Division policy, the speculative effluent limitations
for the above referenced discharges are summarized in the attached tables. These speculative limits
are issued for discharges to waters of the state as summarized below:
• Dare County RO - Stumpy Point Bay
• Camden County RO - Pasquotank River
• Tyrrell County WTP -Scuppernong River
Please note that should the County wish to pursue receipt of NPDES permits, application
packages should include a summary of alternatives to surface water discharge, source water data, and
expected effluent concentrations from each facility.
If you have any questions or comments regarding these speculative limitations, please do not
hesitate to contact Mr. Mark McIntire at telephone number [phone], extension 553.
Sincerely
4,04_4 Vridzwit_„
David A. Goodrich
• NPDES Supervisor
Cc: Central Files
NPDES Permit File
Washington Regional Office, Water Quality
P.O. Box 29535,RALEIGH,NORTH CAROLINA 27626-0535 TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER 50%RECYCLED/10%POST-CONSUMER PAPER

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NCDENR/DIVISION OF WATER QUALITY
Water Quality Section/NPDES Unit
April 28, 1999
MEMORANDUM
To: File
From: Mark McIntire
Subject: WTP Speculative Limits Requests
On April 1, 1999, we received three speculative limits requests from Hobbs, Upchurch dam?
Associates. The requests are summarized below:
• Dare County - 0.015 MGD of RO reject into Stumpy Point Bay
• Camden County - 0.432 MGD of RO reject into the Pasquotank River
• Tyrrell County - Filter and softener backwash into the Scuppernong River
Stumpy Point Bay
• Classified SA waters
• Speculative limits drafted in accordance with the January 12, 1999 policy memo
PasQuotank River
• Classified SB waters
• Speculative limits drafted in accordance with the January 12, 1999 policy memo
Scuppernong River
• Classified C Sw waters
• Speculative limits drafted in accordance with the September 30, 1992 policy memo