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HomeMy WebLinkAboutNC0026441_Performance Summary_20221107TOWN OF SILER CITY WWTP TREATMENT PERFORMANCE EVALUATION TOWN OF SILER CITY CHATHAM COUNTY, NORTH CAROLINA David L. Honeycutt, PE tl1i1eC I COI,,, �i L 034999 = I GI NEE GJ a S o��`�`°°°° I Fir m CgiliTogether Shaping Communities 5 Regional Circle, Suite A Pinehurst, North Carolina 28374 910.295.3159 Firm License No.: C-0459 NOVEMBER 2022 Siler City WWTP TREATMENT PERFORMANCE EVALUATION TABLE OF CONTENTS 1. Introduction 2. Existing Influent Parameters and Facility Performance 3. Pretreatment Program 4. Existing Wastewater Treatment Facilities 5. Potential Effluent Limits APPENDIX 1. Town OF Siler City NPDES Permit 2. Mountaire Farms Industrial User Permit 3. MTS Design Data Sheet (1992) 1.0 Introduction This evaluation is prepared for the Town of Siler City Wastewater Treatment Plant (WWTP) to review the existing treatment system and operation to evaluate facility performance as required for the Special Order by Consent process. The Town currently operates the WWTP under NPDES Permit No. NC0026441 at a capacity of 4.0 MGD. The WWTP effluent has exceeded permit limits numerous times in the past two years and the facility has been placed under a Moratorium by the North Carolina Department of Environmental Quality (NCDEQ). The Town is seeking to enter a Special Order by Consent (SOC) to define a plan to address the deficiencies in the facilities and bring the plant back into consistent compliance with the NPDES permit. There are a number of factors that appear to be impacting the plant performance. These factors include, high strength influent wastewater, toxicity and inhibition, solids management and significant industrial users. This report is formatted to provide a summary of the current influent and effluent data for the facility, Pretreatment Program, evaluation of the treatment components included in the facility, and an estimate of the effluent limits the facility could be expected to meet during the term of the SOC. Siler City WWTP Treatment Performance Evaluation Page 1 2.0 Existing Influent Parameters and Facility Performance Influent and effluent data from January 2021 through September 2022 was reviewed for the purposes of this evaluation. A summary of the data is provided in Table 2.1 and 2.2 below. Averages for each year and 95th percentiles of the data were utilized for comparison. It is noted that the average influent BOD rose approximately 15% from 299 to 345 mg/I from 2021 to 2022. TN and ammonia values were slightly lower in 2022 than 2021. Table 2.1 Siler City WWTP Influent Data Siler City WWTP Influent Measurements Flow (MGD) BOD (mg\L) TSS (mg\L) TN (mg\L) NH3 (mg\L) TP (mg\L) 2021 Average 2.77 299.31 207.98 40.09 31.9 4.52 2022 Average 2.65 345.23 232.28 38.02 24.32 4.82 2 Year Average 2.72 323.74 220.91 17.16 10.86 4.66 2-Year Maximum Month Average 4.65 393.70 332.25 46.70 35.09 11.7 2021-951h Percentile I 4.41 428.00 485.80 19.52 21.69 7.55 2022-951h Percentile I 4.28 491.00 498.00 51.79 38.96 7.82 *Based on DMR data from January 1, 2021 - September 30, 2022 The plant is currently operating under the 4.0 MGD permit with the modification became effective on November 1, 2022. Table 2.3 is an excerpt from A.(1.) of the NPDES permit. Siler City WWTP Treatment Performance Evaluation Page 2 Table 2.2 — Siler City WWTP Effluent Limitations and Monitoring at 4.0 MGD EFFLLT—NT CFLARACTERISTIC LLiiITS NIONZTORTNG REQLIREhiENIS Parametff Code hionthh- Weeur Daih- Measurement Sample Sample Lxadon Average Aver:ti}e Varimum Frequeno- Tspe Flow 50050 4.0 MGD CoBunuous Recording Influent Effiuentt Total Monthly Flow 52220 Monitor and Report Monthly Recording Influent or (qG-o) or Calculated Fiffiueat BOD, 5-day, 20°C i 5.0 mg.L 7.5 mglL Daily Composite Tulluent and -April 1— October 31 CO3I0 Fiffiueat BOD, 5-*, 20°C 2 .g1L 104 m 15.4mgIL Daily Composite Influent and November 1 —March 31 Effiuent Total Suspended Solids I C0530 30.0 mg1L 45.0 mgiL Dailti• Composite hitluent and (TSS) Effiuent -Ammonia p4$s as Nj 1.0 mgfL 3.0 mglL Dailti• Composite Effiu at -April 1 — October 31 CQ62 0 AmD14°ia as N) 2.0 mgfL 6.0 mg1L Dailti Composite Effiuent November 1 — March 31 Fecal Coliform (geometrx mean) 31616 2001100 mL 4OR400 niL Daily Grab Effluent T�C�Residual Chlorine 50050 17.0 µpL Daily Grab Effiuent Temperature CC) 00010 Monitor and Report Daily Grab Fiffiueat Dissolved Oxygen (DO) 00300 Daily Average > 6.0 m&L Daily Grab Effiuent pH 00400 Between 6.0 and 9.0 Standard Units Day Grab E.ffiumt C'onducti%.* (mihoslca� 00094 Monitor and Report Daily Grab Effiuent NOS N +NOON (mgQ 00630 Monitor and Report Weekly Composite Effiuent Tffi4 (mg1L) 00625 Monitor and Report weekly Composite Effluent Total Nitrogen CM, mg1L 4 C0600 Monitor and Report Weekly Calculated Effiuent Qtid600 Momtoi and Deport Wmo) (permit cyde) Monthly OI600 182,646 b'yr (efE ibar * 1.2l3112022) Annually IN Load OI600 146,1171bipr(eff. Ulf2023-12131f2423) Annually Calculated E:ffiBmt OI600 115,675lbiyr (eff. 11U202412131t2424) 7 ?annually O1600 54,WO lbdyi (eff: 11112025) t Annually Total Phosphorus CM a -April 1 — October 31 C0665 4.5 nrglL (quarterly average) Weekty Composite Effiueat Total Phosphorus CM s C 0665 2.0 mg-IL[quarterly average) tiLreel L}' Composite Effiuent November 1 — March 31 T� Hardness (as CaCO3), 00900 Mourtar and Report Quarterly Grab Effiuent Total Cadmium (as Cd) 01027 1.61iF/L I I 142 ug+L Monthly Composite E lumt fatal Capper (as Cu) 01042 Monitor and Report Monthly Composite Effiuent fatal Selemt= (as Se) 01147 Monitor and Report Quarterly Composite Effiuent Total Silver (as Ag) 01077 Monitor and Report Quarterly Composite Effluent C'hloaide (as Cl) 00940 233 mgiL Monthly Composite Effluent Total Zinc (as Zu) 01092 Monitor and Repoat Quarterly Composite Effiuent Bis (2--thylhesyU phthalate 39100 Monitor and Report Quartelty Grab Effiuent l,d-DioBane H 8238$ Monitor and Report Monthly Grab Effiuent PFAS various Footnote 12 Footnote 12 Grab Effluent ChronicTofficityii TGP31i PassrFail Catsadaphraa dtrbia at 90°fo effiuent Quarterly Composite Effluent Effiuent Pollutant Scan AVOi Monitor and Report Footnote 14 Footnote 14 Effiuent Siler City WWTP Treatment Performance Evaluation Page 3 Table 2.3 WWTP Effluent Data Siler City WWTP Effluent Data Flow BOD TSS TN NH3 TP (MGD) (mg\L) (mg\L) (mg\L) (mg\L) (mg\L) 2.77 8.98 5.00 8.35 4.93 0.28 2021 Average 2022 Average 2.65 9.36 7.90 10.94 5.35 0.36 2 Year Average 2.72 9.19 6.54 9.11 5.11 0.32 2-Year Maximum 4.65 51.69 39.91 26.78 19.49 1.06 Month Average 2021-95th 4.41 27.39 17.41 19.52 21.75 0.73 Percentile 2022-95th 4.28 34.39 12.50 30.16 21.38 1.90 Percentile *Based on DMR data from January 1, 2021 - September 30, 2022 Effluent data from WWTP indicate that the plant has had significant challenges meeting limits for BOD and Ammonia during this period. Total Nitrogen on average has been relatively as the plant is typically operating at a very low DO level. Ammonia that reaches nitrification is then de -nitrified typically resulting in good TN removal. When oxygen levels in the WWTP are too low to provide adequate removal of the BOD and achieve nitrification these constituents pass through to the effluent. Inhibition is also suspected of contributing to this performance issue due to high iron content and chlorine in the influent. At over 24 hours the plant has more than adequate retention time in the oxidation ditches however the effluent performance is being impacted by other factors. Further discussion on the plant components is included in Section 4.0. Siler City WWTP Treatment Performance Evaluation Page 4 3.0 Pretreatment Program 3.1 Current Industrial Users The Town of Siler City currently has two permitted Significant Industrial Users (SIU), Mountaire Farms and Brookwood Farms. Both are meat processing facilities however, Mountaire Farms is a substantially higher wastewater production than Brookwood Farms. Mountaire Farms started operations at the beginning of 2019 and holds a permit to discharge up to 1.25 MGD. Brookwood Farms has a permit to discharge up to 0.035 MGD. Effluent data was reviewed for the two industrial users from 2021 to 2022 and compared to permit limits as shown below. Table 3.1 Mountaire Farms Permit Limits Parameter Daily Max Monthly Average Flow MGD 1.65 1.25 BOD m /I 540 450 TSS m /I 180 150 TN (mg/1) 100 75 NH3 m /I 50 40 TP m /I 7.2 6 Until May 2022 Monitoring was completed weekly by Mountaire and Monthly by the Town. In 2022 monitoring frequency was increased to 5 days per week by the Town per NCDEQ requirements. Mountaire flows are approximately 35% of the total average flow to the Town's WWTP and therefore are a very heavy influence on the influent loading seen by the Town's Wastewater Treatment Plant. There have been significant discrepancies between the data recorded by the Towns sample information and Mountaire Farms self -monitoring. The Town and Mountaire have looked into this issue and utilized split samples with 3rd party laboratories as well to try to determine the source of these discrepancies, but it has not been determined at this time. As shown in the following table the Town's data shows that the 2021 average effluent BOD was 561 and is a similar 560 mg/I to date in 2022. These values are approximately 24% above the monthly average permit limit of 450 mg/I for BOD. The average influent BOD to the Town's WWTP was 323 mg/I which is a strong wastewater for a municipal facility. Impacts of high BOD are discussed further in Part 4.0 with the oxidation ditch performance. Town operators have also noted that the Mountaire Facility has sent wastewater containing significant chlorine residual. Limited data is Siler City WWTP Treatment Performance Evaluation Page 5 available to include details of this information, but it is likely that chlorine residual can cause both inhibition and toxicity at the WWTP. Mountaire's pretreatment system was designed to include de -chlorination to remove chlorine residual prior to discharge. Once this issue was discovered the Town notified Mountaire and de -chlorination has resumed. The chlorine residual likely has impacted the Town's WWTP performance in the past year, however it is anticipated that these impacts should be reduced or eliminated with Mountaire's operational correction. Table 3.2 Mountaire Farms Effluent Data Mountaire Pre -Treatment Flow BOD TSS TN NH3 TP (MGD) (mg\L) (mg\L) (mg\L) (mg\L) (mg\L) Self Town Self Town Self Town Self Town Self Town 2021 Average 0.979 283.92 561.00 23.65 20.74 15.59 68.47 5.84 41.48 0.83 5.18 2022 Average 0.930 251.67 559.66 1 28.07 47.23 12.60 70.82 6.19 35.41 0.65 3.80 2 Year Average 0.957 269.63 559.84 25.63 43.57 14.27 70.51 5.99 36.20 0.75 3.90 2-Year Maximum 1.242 362.00 745.00 38.50 78.50 21.68 98.20 13.58 75.60 1.38 9.30 Month Average 2021-95th 1.192 388.80 717.50 38.51 38.08 27.20 95.89 9.66 68.29 1.52 6.68 Percentile 2022-95th 1.076 360.60 806.70 44.64 111.90 18.06 88.08 16.53 57.62 1.11 6.84 Percentile Brookwood Farms also has the potential to discharge high concentrations of BOD and TN, Ammonia and TP to the Town's WWTP. The data for Brookwood for 2021 and 2022 was reviewed as well to determine potential for impact from their discharges to the Town's performance. Although the permit allows discharge up to 800 mg/I BOD, the average BOD over the past two years has only been 58 mg/I and 28 mg/I respectively. The TN concentration is higher at 116 and 137 mg/I however it is noted that the flow from Brookwood is only 20,000 to 30,000 gallons per day and nitrogen load is therefore less than 5% of the plant influent loading. Therefore it does not appear that Brookwood Farms wastewater is a significant contributor to the violations at the Town of Siler City WWTP. Table 3.3 Brookwood Permit Limits Parameter Daily Max Flow MGD 0.035 BOD (mg/1) 800 TSS (mg/1) 450 TN m /I 150 TP m /I Monitor Siler City WWTP Treatment Performance Evaluation Page 6 Table 3.4 Brookwood Effluent Data Brookwood Pre -Treatment Flow (MGD) BOD (mg\L) TSS (mg\L) TN (mg\L) NH3 (mg\L) TP (mg\L) Permit Limit 0.035 800 450 150 2021 Average 0.0216 57.83 135.24 115.79 23.10 10.77 2022 Average 0.0292 27.55 102.96 136.78 14.70 13.65 3.2 Water Treatment Plant The Town of Siler City Water Treatment Plant is a 4.0 MGD plant which currently utilizes conventional treatment consisting of coagulation, flocculation, sedimentation, and filtration. The plant produces process wastewater from backwash of the filters, cleaning the sedimentation basins and other miscellaneous uses. This water is initially sent to a circular equalization tank and then pumped to a sludge lagoon where solids are both settled and stored. Water is then drained from the end of the lagoon to a lift station with duplex submersible pumps which pumps the wastewater to the Town's sewer collection system and eventually the WWTP. Effluent from the lagoon is frequently high in solids due to inadequate settling in the lagoon, surges in flow from frequent backwashes, and basin cleaning required to keep the water treatment plant in operation. The plant uses Ferric Chloride as the primary coagulant and therefore these solids are very high in iron. The iron content measured at the influent to the WWTP has varied substantially and reached values of over 200 mg/I. Iron is not specially listed as a pollutant of concern for inhibition in a WWTP within Pretreatment Program spreadsheets however literature values list a range of potential inhibition levels. EPA guidance lists a range of 5-500 mg/I. Iron accumulates in the mixed liquor at the WWTP and creates challenges for operations and biological activity in the plant. The Town has begun collecting samples influent regularly and should utilize this data in conjunction with performance data to determine the level of iron that causes interference specific to the Siler City WWTP. A cursory review indicates a target influent value of 50 mg/I or less is likely appropriate. The Town has already installed baffles in the lagoon which are improving the settling efficiency. They should continue to remove sludge frequently to prevent slug loads of sludge from being washed out of the lagoon to the pump station and WWTP. Siler City WWTP Treatment Performance Evaluation Page 7 4.0 Existing Wastewater Treatment Facilities 4.1 Influent Pump Station Influent pump station includes 4 duty and 1 standby self -priming suction lift pumps. Each pump has a capacity of 3,250 gpm or 4.68 MGD. This gives the pump station a firm capacity of 14.04 MGD with one pump out of service. There is not a flow meter at the pump station and the configuration of the wetwell is not conducive to drawdown testing. Influent pumps have not been reported to have failed to keep up with the influent flow or otherwise contributed to the issue so no further evaluation of these facilities appears to be necessary at this time. 4.2 Flow Equalization The plant has four (4) flow equalization zones, with capacities as follows: FLOW EQ ZONE BASIN QUAN., SHAPE TOTAL VOLUME GAL 1 1, RECT. 159,070 2 1, RECT 951,550 3 2, ROUND 507,580 4 1, RECT. 396,365 TOTAL: 2,014,565 These zones are connected such that they are capable of receiving flow from multiple points in the treatment process from after the headworks all the way to the backwash from the tertiary sand filters. Flow equalization tankage noted above is functional and aeration systems are in working order. A second rectangular tank in Zone 4 is not in service due to structural issues. The performance of flow equalization tanks does not appear to be contributing significantly to the systems failure to provide adequate treatment. 4.3 Oxidation Ditches The plant has parallel oxidation ditches, each with a volume of approximately 2.2 MG. Both basins provide approximately 26.4 hours of detention time at the 4.0 MGD design flow. Each basin is equipped with jet aerators to supply oxygen to the ditch. Three blowers are operational, each with 150 hp motor. According to data sheets from MTS per the original design the plant is designed to run with two duty blowers and one standby. The aeration Siler City WWTP Treatment Performance Evaluation Page 8 system is sized to provide treatment for a BOD5 of 350 mg/I and influent ammonia of 45 mg/I with effluent of 5 mg/I and 1 mg/I respectively. This design is based on an oxygen transfer efficiency of 28.6% for the jet aeration system. Per visual observations of the bubble pattern and surface flow patterns in the oxidation ditches the aeration system does not appear to be functioning properly. It is suspected that the jets are deteriorated to the extent that they are not providing the directional mixing and air entrainment that is intended for this system. Therefore, the transfer efficiency is substantially reduced. Further evidence of this is noted in the operators DO measurements for the oxidation ditches which are conducted both manually and via four (4) online DO meters in the oxidation ditch basins. Although the facility is designed to run with 2 of the 3 blowers in service, operators have been running with all 3 blowers in service to try to maintain DO levels to the extent feasible. The DO values vary, however, the average is typically less than 0.5 mg/I within the basins. Based on the performance of the plant this value is adequate to meet the BOD and provide nitrification under the current average conditions. At higher peak BOD and ammonia conditions the plant the DO levels have been depressed to the extent that BOD removal is inadequate and nitrification is not complete. This results in violations of the NPDES permit for BOD and Ammonia. Elevated ammonia values are also suspected to be a significant contributor to effluent toxicity and failure of toxicity testing required by the permit. As noted above, operators are typically running all three blowers to attempt to maintain DO levels in the oxidation ditches. Repair of the jet aerators is impractical as it requires an oxidation ditch to be removed from service. At current flows both basins are needed to provide adequate treatment volume. Solids levels within the oxidation ditch are also likely contributing to the issues with maintaining DO levels. The system was designed to run at 4,000 mg/I per the MTS data sheets and MLSS concentrations have varied up to 6,000 to 7,000 mg/I. These high values cause additional endogenous respiration which consumes DO and can reduce transfer efficiency by depressing the alpha value of the mixed liquor. It is recommended for operators to keep MLSS levels to less than 5,000 mg/I and target operation near 4,000 mg/I to minimize the impacts of high solids concentrations. Siler City WWTP Treatment Performance Evaluation Page 9 4.4 Clarifiers A clarifier splitter box directs flow to the two existing 90-foot diameter clarifiers. The splitter box has the ability of mixing Lime or alum to the wastewater prior to entering the secondary clarification stage. Mixed liquor suspended solids (MLSS) are divided into two (2) secondary clarifiers for sludge settling. The clarifiers have suction tube -type sludge removal mechanisms with full surface skimmers. The clarifier loading rate is 314.4 gpd/sf based on a 90-foot diameter handling 2 MGD average daily flow. This value is within the range recommended by Metcalf and Eddy, Wastewater Engineering 4th edition pg 687 (300-500 gpd/SF) Check solids loading at 4,000 mg/I MLSS. At a RAS flowrate of 75%, solids loading for each clarifier is calculated as follows: (2.0 MGD (design flow) + 1.5 MGD RAS) * 8.34 * 4,000 mg/I = 116,760 Ibs/day = 4865 Ibs/hr 4,865 Ibs/hr / 6,372 SF = 0.76 Ibs/hr/sf at average condition. Metcalf and Eddy4th edition pg. 687 recommends 1-1.5 for BNR, OK at average with 4,000 mg/I (2.0 MGD (design flow) + 1.5 MGD RAS) * 8.34 * 7,000 mg/I = 204,330 Ibs/day = 8513.75 Ibs/hr 8,513.75 Ibs/hr / 6,372 SF = 1.34 Ibs/hr/sf at average flow with high solids. Metcalf and Eddy4th edition pg. 687 recommends 1-1.5 for BN., Based on this calculation the solids loading rate is acceptable with the high MLSS value of 7,000 mg/I however it is noted that with higher flows the value is more likely to cause issues with efficient settling in the clarifiers. 4.5 Filters The plant utilizes Greenleaf sand filters with four (4) zones. The gravity - based sand filter is used to filter any suspended solids remaining after the clarification process. The filters have a total area of 2304 SF which gives a loading rate of 1.2 GPM per square foot at the plant ADF of 4 MGD and 3 GPM per square foot at peak flow. These loading rates are within current design parameters for similar equipment. Filter media has been replaced in 2021 and is therefore understood to be in good condition. Siler City WWTP Treatment Performance Evaluation Page 10 4.6 Chlorine Disinfection The plant has two (2) chlorine contact basins. Chlorine feed is supplied from one -ton cylinders maintained on site. After the wastewater has been disinfected it flows to a de -chlorination basin where Sulfur dioxide is added for de -chlorination. Chlorine contact basin is approximately 84,000 gallons and provides 30 minutes detention time at 4.0 MGD average daily flow. 4.7 Post Aeration Disinfected water flows via gravity to the 23 feet long cascade aerator. The cascade aerator generates utilizes the fall to induce turbulent flow and introduce air into the treated effluent. The post -aeration mechanism appears to be working effectively and the effluent DO concentrations are consistently in compliance with permit requirements. 4.8 RAS/WAS Pump Station The RAS/WAS Pump Station contains three (3) RAS/WAS pumps, each rated 15 HP, 1,200 gpm at 25 ft of total dynamic head (TDH). Valves are utilized to direct sludge flow to waste or return per operator selection. RAS/WAS pumping capacities are meet typical design criteria and are adequate for sludge removal from the clarifiers. 4.9 Sludge Holding and Digestion Facilities Waste sludge is directed to two aerobic digester tanks, previously secondary clarifiers, where it is able to settle and thicken prior to storage in the aerated thickened sludge storage tanks. Decant pumps can remove additional water from the thickened sludge storage tanks which is returned to the head of the plant. Each aerobic digester provides a volume of 280,000 gallons. The sludge holding tanks include a volume of approximately 1,350,000 gallons for a total sludge storage volume of 1,910,000 gallons. The Town can also utilize flow eq zone 4 for sludge storage when needed which provides an additional 396,000 gallons. 4.10 Sludge Disposal The Town has a contract with Synagro land apply sludge under Land Application permit WQ0003226. The capacity of the permitted fields is 1,325 dry tons per year. In 2020 a total of 617.13 dry tons was applied. In Siler City WWTP Treatment Performance Evaluation Page 11 2021 a total of 467.34 dry tons was applied. The Town has adequate disposal capacity in the land application permit for the sludge produced. Due to wet weather and freezing temperatures land application is limited during the winter months and the Town is unable to store solids adequately at the WWTP for the extended period to control sludge levels in the treatment basins. The Town has utilized a dewatering belt press recently to better control those levels and is expected to need to continue to do so until a permanent dewatering or alternative disposal system is in place. 5.0 Potential Effluent Limits Based on the historical data reviewed and current facilities, the plant performance is anticipated to continue to fall short of consistently meeting the final effluent limits. There are expected to be periods of time where the facility meets effluent limits but when the facility is inhibited due to influent iron, and chlorine concentrations, receives excessive BOD or 1/1 these factors are likely to continue to cause the plant to exceed the effluent limits. These issues are outside of the operations staff control and may vary throughout the year. Based on the ongoing efforts previously discussed it is anticipated that the periods of violation will continue to be shortened to minimize impacts of these exceedances of the effluent limits. Per review of the performance over the past two years and the improvements that have been completed to date the plant is expected to meet the following effluent limits prior to completion of the expansion to 6.0 MGD. Performance does not vary substantially from winter to summer and therefore a single value is indicated below. It is noted that occasional exceedances of these levels may still occur due to extraordinarily high 1/I, influent loading, or plant upsets. Parameter W ekly Avg Monthly Avg BOD5 15 10 NH3-N 10 5 Note: Parameters not included are expected to be in compliance with the final effluent limit for the 4.0 MGD flow (Part A. (1)). The plant has also had several toxicity failures in recent sampling. Due to the complexity of toxicity testing and inconsistency within the plant's performance a compliance level for toxicity has not been estimated. It is however anticipated that some failures of toxicity will continue, particularly during abnormal conditions for influent flows or loading. Siler City WWTP Treatment Performance Evaluation Page 12 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES 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 Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the Town of Siler City is hereby authorized to discharge wastewater from a facility located at the Siler City WWTP 198 Utility Drive Siler City, NC 27344 Chatham County to receiving waters designated as Loves Creek in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective November 1, 2022. This permit and authorization to discharge shall expire at midnight on May 31, 2027. Signed this day September 28, 2022. Do'c'fu.Si-gne'Id byy:� A A E Nl/�/�'�N A'WKhJstVfJ C464531431644FE... for Richard E. Rogers, Jr., Director Division of Water Resources By Authority of the Environmental Management Commission DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issuedpermit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. The Town of Siler City is hereby authorized to: 1. Continue to operate an existing 4.0 MGD wastewater treatment system consisting of the following: • Automatic and manual bar screens • Grit collection unit • Influent pump station • Influent Equalization Basin (Zone 2) • Dual oxidation ditches with surface jet aeration • Flow Splitter Box o Alum feed station o Lime feed station • Dual secondary clarifiers • Dual Aerobic digesters • Return Activated Sludge • Sludge Transfer Station • Dissolved Air Flotation Unit (Used as needed) • Sludge Thickener Basin • Influent equalization or Sludge Storage Basins (Zone 3 A & B used as needed) • Four (4) tertiary filters • Filter Backwash Basin • Gaseous Chlorine Disinfection • Chlorine contact chamber • Gaseous Sulfur Dioxide Dechlorination • Step -Aeration The facility is located at the 198 Utility Drive, Siler City, in Chatham County; 2. After receiving an Authorization to Construct from the Division, construct a 6.0 MGD wastewater treatment system; and after the Division receives the Engineer Certification of construction completion, operate above system. The draft upgraded system includes the following upgraded/additional components: • Upgraded headworks including duplex mechanical bar screens and grit removal • Upgraded influent pump station (firm capacity 18 MGD) • Two (2) 100 hp blowers • One additional oxidation ditch with baffles, aeration and mixing equipment to create aerobic, anaerobic and anoxic zones • One additional clarifier • Effluent denitrification filters • UV disinfection system • Solids handling facility with filter press 3. Discharge from said treatment works at the location specified on the attached map into Loves Creek, classified C waters in the Cape Fear River Basin. Page 2 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 PART I A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (4.0 MGD) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] Grade IV Biological Water Pollution Control System [15A NCAC 08G .0302] a. During the period beginning on the effective date of the permit and lasting until expansion to 6.0 MGD (and receipt of the Engineer's Certificate of completion) or until expiration, the Permittee is authorized to discharge treated domestic and industrial wastewater from Outfall 001. Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Weekly Daily Measurement Sample Sample Location Parameter Code Average Average Maximum Frequency Type Flow 50050 4.0 MGD Continuous Recording Influent or Effluent Total Monthly Flow 82220 Monitor and Report Monthly Recording Influent or (MG/mo) or Calculated Effluent BOD, 5-day, 20°C 2 5.0 mg/L 7.5 mg/L Daily Composite Influent and April 1 — October 31 C0310 Effluent BOD, 5-day, 20°C 2 10.0 mg/L 15.0 mg/L Daily Composite Influent and November 1 — March 31 Effluent Total Suspended Solids (TSS) C0530 30.0 mg/L 45.0 mg/L Daily Composite Influent and Effluent Ammonia (NH3 as N) 1.0 mg/L 3.0 mg/L Daily Composite Effluent April 1 — October 31 C0610 Ammonia (NH3 as N) 2.0 mg/L 6.0 mg/L Daily Composite Effluent November 1 — March 31 Fecal Coliform 31616 200/100 mL 400/100 mL Daily Grab Effluent (geometric mean) Total Residual Chlorine (TRC) 50050 17.0 µg/L Daily Grab Effluent Temperature (°C) 00010 Monitor and Report Daily Grab Effluent Dissolved Oxygen (DO) 00300 Daily Average > 6.0 mg/L Daily Grab Effluent pH 00400 Between 6.0 and 9.0 Standard Units Daily Grab Effluent Conductivity (µmhos/cm) 00094 Monitor and Report Daily Grab Effluent NO2-N +NO3-N (mg/L) 00630 Monitor and Report Weekly Composite Effluent TKN (mg/L) 00625 Monitor and Report Weekly Composite Effluent Total Nitrogen (TN), mg/L 4 C0600 Monitor and Report Weekly Calculated Effluent QM600 Monitor and Report (lb/mo) (permit cycle) Monthly QY600 182,6461b/yr (eff. through 12/31/2022) Annually TN Loads QY600 146,1171b/yr (eff. 1/1/2023-12/31/2023) 6 Annually Calculated Effluent QY600 115,6781b/yr (eff. 1/l/2024-12/31/2024) Annually QY600 54,800 lb/yr (eff. 1/l/2025) s Annually Total Phosphorus (TP) 9 April 1 — October 31 C0665 0.5 mg/L (quarterly average) Weekly Composite Effluent Total Phosphorus (TP) 9 November 1 — March 31 C0665 2.0 mg/L (quarterly average) Weekly Composite Effluent Total L Hardness (as CaCO3), 10 00900 Monitor and Report Quarterly Grab Effluent Page 3 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 EFFLUENT CHARACTERISTICS Parameter Code LIMITS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Total Cadmium (as Cd) 01027 1.6 µg/L 10.2 µg/L Monthly Composite Effluent Total Copper (as Cu) 01042 Monitor and Report Monthly Composite Effluent Total Selenium (as Se) 01147 Monitor and Report Quarterly Composite Effluent Total Silver (as Ag) 01077 Monitor and Report Quarterly Composite Effluent Chloride (as Cl) 00940 233 mg/L Monthly Composite Effluent Total Zinc (as Zn) 01092 Monitor and Report Quarterly Composite Effluent Bis (2-ethylhexyl) phthalate 39100 Monitor and Report Quarterly tGrab Effluent 1,4-Dioxane 11 82388 Monitor and Report Monthly Grab Effluent PFAS various Footnote 12 Footnote 12 Grab Effluent Chronic Toxicity 13 TGP3B Pass/Fail Ceriodaphnia dubia at 90% effluent Quarterly Composite Effluent Effluent Pollutant Scan NCO] Monitor and Report Footnote 14 1 Footnote 14 Effluent Footnotes: 1. Submit discharge monitoring reports electronically using NC DWR's eDMR application system. See Section A. (15.). 2. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The facility shall monitor TRC when using chlorination for disinfection. The Division shall consider all effluent total residual chlorine values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field -certified), even if these values fall below 50 µg/L. 4. Total Nitrogen (TN) is defined as NO3-N+NO2-N + TKN, where NO3-N is nitrate nitrogen, NO2-N is nitrite nitrogen, and TKN is total Kjeldahl Nitrogen. 5. TN Load is the mass quantity of Total Nitrogen discharged in a given period of time. See Section A. (7.), Calculation of Total Nitrogen Loads. 6. Limit to be applied if the facility does not complete upgrade to 6.0 MGD by 12/31/2023. 7. Limit is the combined mass of the interim load limit of 146,117 lb/yr from 1/l/2024-8/31/2024 and final load limit of 58,800 lb/yr from 9/l/2024-12/31/2024, to be applied for calendar year 2024 only. 8. The Permittee shall follow the schedule to upgrade the facility to 6.0 MGD. See A. (9.). 9. Compliance with the Total Phosphorus limits shall be based on a calendar -quarter average of weekly samples. 10. Effluent Total Hardness sampling should be performed in conjunction with testing for hardness -dependent metals (cadmium, copper, lead, nickel, silver, and zinc). 11. Samples must be reported to a minimum of PQL < 1 µg/L using EPA Method 624.1. 12. See Special Condition A. (14.). 13. Whole Effluent Toxicity will be monitored using the Pass/Fail Ceriodaphnia dubia at 90% effluent. Samples shall be taken in March, June, September and December. See Section A. (5.). 14. The Permittee shall perform three Effluent Pollutant Scans during the term of this permit. See Section A. (6.). b. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 4 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (6.0 MGD) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] Grade IV Biological Water Pollution Control System [15A NCAC 08G .0302] a. During the period beginning upon receipt of the Engineer's Certificate of completion for expansion to 6.0 MGD and lasting until expiration, the Permittee is authorized to discharge treated domestic and industrial wastewater from Outfall 001. Such discharges shall be limited and monitored 1 by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Weekly Daily Measurement Sample Sample Location Parameter Code Average Average Maximum Frequency Type Flow 50050 6.0 MGD Continuous Recording Influent or Effluent Total Monthly Flow 82220 Monitor and Report Monthly Recording Influent or (MG/mo) or Calculated Effluent BOD, 5-day, 20°C 2 5.0 mg/L 7.5 mg/L Daily Composite Influent and April 1 — October 31 C0310 Effluent BOD, 5-day, 20°C 2 10.0 mg/L 15.0 mg/L Daily Composite Influent and November 1 — March 31 Effluent Total Suspended Solids (TSS) C0530 20.0 mg/L 30.0 mg/L Daily Composite Influent and Effluent Ammonia (NH3 as N) 1.0 mg/L 3.0 mg/L Daily Composite Effluent April 1 — October 31 C0610 Ammonia (NH3 as N) 1.9 mg/L 5.7 mg/L Daily Composite Effluent November 1 — March 31 Fecal Coliform 31616 200/100 mL 400/100 mL Daily Grab Effluent (geometric mean) Total Residual Chlorine (TRC) 50050 17.0 ❑g/L Daily Grab Effluent Temperature (°C) 00010 Monitor and Report Daily Grab Effluent Dissolved Oxygen (DO) 00300 Daily Average > 7.0 mg/L Daily Grab Effluent pH 00400 Between 6.0 and 9.0 Standard Units Daily Grab Effluent Conductivity (µmhos/cm) 00094 Monitor and Report Daily Grab Effluent Total Organic Nitrogen 00605 3.0 mg/L 4.5 mg/L Weekly Composite Effluent April 1 — October 31 NO2-N +NO3-N (mg/L) 00630 Monitor and Report Weekly Composite Effluent TKN (mg/L) 00625 Monitor and Report Weekly Composite Effluent Total Nitrogen (TN), mg/L a C0600 Monitor and Report Weekly Calculated Effluent QM600 Monitor and Report (lb/mo) Monthly TN Load' QY600 115,6781b/yr (efi 1/l/2024) 6 Annually Calculated Effluent QY600 54,800 lb/yr (efi 1/l/2025) Annually Total Phosphorus (TP) 7 C0665 0.5 mg/L (quarterly average) Weekly Composite Effluent April 1 — October 31 Total Phosphorus (TP) 7 C0665 2.0 mg/L (quarterly average) Weekly Composite Effluent November 1 — March 31 Tmot L Hardness (as CaCO3), 00900 Monitor and Report Quarterly Grab Effluent Page 5 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 EFFLUENT CHARACTERISTICS Parameter Code LIMITS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Total Cadmium (as Cd) 01027 1.6 µg/L 10.2 µg/L Monthly Composite Effluent Total Copper (as Cu) 01042 Monitor and Report Monthly Composite Effluent Total Selenium (as Se) 01147 Monitor and Report Quarterly Composite Effluent Total Silver (as Ag) 01077 Monitor and Report Quarterly Composite Effluent Total Zinc (as Zn) 01092 Monitor and Report Quarterly Composite Effluent Chloride (as Cl) 00940 232 mg/L Monthly Composite Effluent Bis (2-ethylhexyl) phthalate 39100 Monitor and Report Quarterly Grab Effluent 1,4-Dioxane v 82388 Monitor and Report Monthly Grab Effluent PFAS various Footnote 10 Footnote 10 Grab Effluent Chronic Toxicity 11 TGP3B Pass/Fail Ceriodaphnia dubia at 90% effluent Quarterly Composite Effluent Effluent Pollutant Scan NC01 Monitor and Report Footnote 12 Footnote 12 Effluent Footnotes: 1. Submit discharge monitoring reports electronically using NC DWR's eDMR application system. See Section A. (15.). 2. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The facility shall monitor TRC when using chlorination for disinfection. The Division shall consider all effluent total residual chlorine values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field -certified), even if these values fall below 50 µg/L. 4. Total Nitrogen (TN) is defined as NO3-N+NO2-N + TKN, where NO3-N is nitrate nitrogen, NO2-N is nitrite nitrogen, and TKN is total Kjeldahl Nitrogen. 5. TN Load is the mass quantity of Total Nitrogen discharged in a given period of time. See Section A. (7.), Calculation of Total Nitrogen Loads. 6. Limit is the combined mass at the interim load limit of 146,117 lb/yr (i.e., 97,411 lb) from 1/ 1/2024-8/3 1/2024 and final load limit of 58,800 lb/yr (i.e., 18,267 lb) from 9/l/2024-12/31/2024, to be applied for calendar year 2024 only. 7. Compliance with the Total Phosphorus limits shall be based on a calendar -quarter average of weekly samples. 8. Effluent Total Hardness sampling should be performed in conjunction with testing for hardness -dependent metals (cadmium, copper, lead, nickel, silver, and zinc). 9. Samples must be reported to a minimum of PQL < 1 µg/L using EPA Methd 624.1. 10. See Special Condition A. (14.). 11. Whole Effluent Toxicity will be monitored using the Pass/Fail Ceriodaphnia dubia at 90% effluent. Samples shall be taken in March, June, September and December. See Section A. (5.). 12. The Permittee shall perform three Effluent Pollutant Scans during the term of this permit. See Section A. (6.). b. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 6 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (3.) INSTREAM MONITORING REQUIREMENTS [15A NCAC 0213.0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee shall conduct instream monitoring as specified below: PARAMETER SAMPLE TYPE LOCATION' MEASUREMENT Parameter Code FREQUENCY' Total Hardness (as CaCO3), mg/L3 00900 Grab LCU 1/Quarter Dissolved Oxygen (DO), mg/L 00300 Grab LCU, LCD, RRU, RRD 3/Week (June — September), 1/Week (October -May) Temperature (°C) 00010 Grab LCU, LCD, RRU, RRD 3/Week (June — September), 1/Week (October -May) Fecal Coliform (cfu/100 mL) 31616 Grab LCU, LCD, RRU, RRD 1/Month Conductivity (µmhos/cm) 00094 Grab LCU, LCD, RRU, RRD 3/Week (May — September), 1/Week (October —April) Total Phosphorus (mg/L) C0665 Grab LCU, LCD, RRU, RRD 3/Week (June — September), 1/Week (October -May) TKN (mg/L) 00625 Grab LCU, LCD, RRU, RRD 3/Week (June — September), 1/Week (October -May) NO2 + NO3 (mg/L) 00630 Grab LCU, LCD, RRU, RRD 3/Week (June — September), 1/Week (October -May) Ammonia (NH3 as N) C0610 Grab LCU, LCD, RRU, RRD 3/Week (June — September), 1/Week (October -May) pH 00400 Grab LCU, LCD, RRU, RRD 3/Week (June — September), 1/Week (October -May) Footnotes: 1. LCU = Loves Creek, upstream of the discharge; LCD = Loves Creek, downstream of the discharge and above the confluence with the Rocky River; RRU = Rocky River, upstream of the confluence with Loves Creek; RRD = Rocky River, downstream of the confluence with Loves Creek. 2. All monitoring is required to be performed at the above -mentioned monitoring locations. 3. The Permittee shall sample instream Total Hardness, upstream of the facility's discharge. The sample shall be representative of the hardness in the receiving stream. Page 7 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (4.) INSTREAM ASSESSMENT OF BIOLOGICAL INTEGRITY (Annual) [15A NCAC 02B .0200 et seq.] a. By April 30, 2023 (180 days after the permit effective date), the Permittee shall submit a study plan to annually assess biological integrity in the receiving water via benthic macroinvertebrate (benthos) sampling and analysis. The study plan shall include methodologies consistent with DWR-approved assessment methodologies' and propose an annual assessment schedule and sampling location(s). The study plan shall be submitted to the Division at the address listed under (d.) of this section. Once DWR- NPDES approves the study plan, it shall be used for all assessments unless a study plan modification is approved/recommended by the Division. Instream biological integrity assessments shall be conducted by a laboratory or entity that is NC -certified for the procedure. b. By November 1, 2023 (one year from the permit effective date) and November 1 of every subsequent year until permit expiration, the Permittee shall conduct an instream benthos assessment annually. c. With each planned assessment, the Permittee shall provide the Division sufficient notice of sampling so that Division personnel may attend and share samples collected. d. The Permittee shall submit instream biological integrity assessment reports within 60 days of completion. All reports shall include the owner's name, NPDES permit number and Permittee contact person, and shall be submitted to: (1) NCDEQ / Division of Water Resources NPDES Permitting — Municipal Branch 1617 Mail Service Center Raleigh, NC 27699-1617 (2) NCDEQ / Division of Water Resources Raleigh Regional Office - WQRO 3800 Barrett Drive Raleigh, NC 27604 e. If it is determined by the Division that the permitted discharge from the facility is not causing stream degradation resulting in water quality standards violations, including narrative standards, the Permittee may request that the instream assessments be terminated. f. The addition of instream biological integrity assessment requirement does not preclude the Division from taking any action necessary to resolve any ongoing compliance activity or effluent violations. Footnote. 1. NC Department of Environmental Quality. 2016. Standard Operating Procedures for the Collection and Analysis of Benthic Macroinvertebrates. Division of Water Resources. Raleigh, North Carolina. February 2016. Page 8 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NC0026441 A. (5.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) [15A NCAC 02B .0200 et seq.] The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90% at 4.0 MGD and 6.0 MGD. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," (Revised December 2010, or subsequent versions) or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised December 2010, or subsequent versions). The tests will be performed during the months of March, June, September, and December. These months signify the first month of each three-month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010, or subsequent versions). All toxicity testing results required as part of this permit condition will be entered electronically using the Division's eDMR system for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3 (original) is to be sent to the following address: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, NC 27699-1621 Or, results can be sent to the email, ATForms.ATB@ncdenr.gov. Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. 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 Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three-month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. Page 9 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NC0026441 NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, 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. Page 10 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (6.) EFFLUENT POLLUTANT SCAN AND SECOND SPECIES TOXICITY TESTING [G. S. 143-215.1(b)] The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below. One scan must be performed in each of the following years: 2024, 2025, and 2026. Analytical methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether parameters are present in concentrations greater than applicable standards and criteria. Samples should be collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total recoverable." Ammonia (as N) C0610 Trans-1,2-dichloroethylene 34546 Bis (2-chloroethyl) ether 34273 Chlorine (total residual, TRC) 50060 1, 1 -dichloroethylene 34501 Bis (2-chloroisopropyl) ether 34283 Dissolved oxygen 00300 1,2-dichloropropane C0541 Bis (2-ethylhexyl) phthalate CO100 Nitrate / Nitrite 00630 1,3-dichloropropylene 77163 4-bromophenyl phenyl ether 34636 Kjeldahl nitrogen 00625 Ethylbenzene 34371 Butyl benzyl phthalate 34292 Oil and grease 00556 Methyl bromide 34413 2-chloronaphthalene 34581 Phosphorus C0665 Methyl chloride 34418 4-chlorophenyl phenyl ether 34641 Total dissolved solids 70295 Methylene chloride 34423 Chrysene 34320 Hardness 00900 1,1,2,2-tetrachloroethane 81549 Di-n-butyl phthalate 39110 Antimony 01097 Tetrachloroethylene 34475 Di-n-octyl phthalate 34596 Arsenic 01002 Toluene 34010 Dibenzo(a,h)anthracene 34556 Beryllium 01012 1, 1, 1 -trichloroethane 34506 1,2-dichlorobenzene 34536 Cadmium 01027 1,1,2-trichloroethane 34511 1,3-dichlorobenzene 34566 Chromium C0034 Trichloroethylene 39180 1,4-dichlorobenzene 34571 Copper 01042 Vinyl chloride 39175 3,3-dichlorobenzidine 34631 Lead 01051 Acid -extractable compounds: Diethyl phthalate 34336 Mercury (Method 1631E) COMER P-chloro-m-cresol 34452 Dimethyl phthalate 34341 Nickel 01067 2-chlorophenol 34586 2,4-dinitrotoluene 34611 Selenium 01147 2,4-dichlorophenol 34601 2,6-dinitrotoluene C0626 Silver 01077 2,4-dimethylphenol 34606 1,2-diphenylhydrazine 34346 Thallium 01059 4,6-dinitro-o-cresol 34657 Fluoranthene C0376 Zinc 01092 2,4-dinitrophenol 34616 Fluorene 34381 Cyanide 00720 2-nitrophenol 34591 Hexachlorobenzene C0700 Total phenolic compounds 32730 4-nitrophenol 34646 Hexachlorobutadiene C0702 Volatile ormanic compounds: Pentachlorophenol 39032 Hexachlorocyclo-pentadiene 34386 Acrolein 34210 Phenol 34694 Hexachloroethane 34396 Acrylonitrile 34215 2,4,6-trichlorophenol 34621 Indeno(1,2,3-cd)pyrene 34403 Benzene 34030 Base -neutral compounds: Isophorone 34408 Bromoform 32104 Acenaphthene 34205 Naphthalene 34696 Carbon tetrachloride 32102 Acenaphthylene 34200 Nitrobenzene 34447 Chlorobenzene 34301 Anthracene CO220 N-nitrosodi-n-propylamine 34428 Chlorodibromomethane 34306 Benzidine 39120 N-nitrosodimethylamine 34438 Chloroethane 85811 Benzo(a)anthracene C0526 N-nitrosodiphenylamine 34433 2-chloroethyl vinyl ether 34576 Benzo(a)pyrene 34247 Phenanthrene 34461 Chloroform 32106 3,4 benzofluoranthene 34230 Pyrene 34469 Dichlorobromomethane 32101 Benzo(ghi)perylene 34521 1,2,4-trichlorobenzene C0551 1,1-dichloroethane 34496 Benzo(k)fluoranthene 34242 1,2-dichloroethane 32103 Bis (2-chloroethoxy) methane 34278 Reporting. Test results shall be reported electronically using the Division's eDMR system or on DWR Form DMR-PPA-1(or on a form approved by the Director) by December 3 1 " of each designated sampling year. The Page 41 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NC0026441 Permittee must at least report completion of the test in the eDMR system by entering "1" or "Y" for parameter code NCO - Annual Pollutant Scan. If utilizing the DWR Form submit to the following address: NC DEQ / DWR / NPDES Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. Or the form may be uploaded at: https://edocs.deq.nc.gov/Forms/NPDES_WW-EDMR-Supplemental-Form Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that Municipal facilities that are subject to the Effluent Pollutant Scan requirements listed above are also subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.210)(5). The US EPA requires four (4) toxicity tests for a test organism other than the test species currently required in this permit. The multiple species tests should be conducted either quarterly for a 12-month period prior to submittal of the permit renewal application, or four tests performed at least annually in the four and one half year period prior to the application. Samples should be collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not sample in the same quarter every year]. These tests shall be performed for acute or chronic toxicity, whichever is specified in this permit. The multiple species toxicity test results shall be filed with the Aquatic Toxicology Branch at the following address: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Or, results can be sent to the email: ATFonns.ATBkncdenr.gov. Contact the Division's Aquatic Toxicology Branch at 919-743-8401 for guidance on conducting the additional toxicity tests and reporting requirements. Results should also be summarized in Part E (Toxicity Testing Data) of EPA Municipal Application Form 2A, when submitting the permit renewal application to the NPDES Permitting Unit. Page 12 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (7.) CALCULATION OF TOTAL NITROGEN LOADS [G.S. 143-215.1(b)] a. The Permittee shall calculate monthly and annual TN Loads as follows: i. Monthly TN Load (lb/mo) = TN X TMF X 8.34 where: TN = the average Total Nitrogen concentration (mg/L) of the composite samples collected during the month; TMF = the Total Monthly Flow of wastewater discharged during the month (MG/mo); and 8.34 = conversion factor, from (mg/L X MG) to pounds Annual TN Load (lb/yr) = Sum of the 12 monthly TN Loads for the calendar year. b. The Permittee shall report monthly Total Nitrogen results (mg/L and lb/mo) in the appropriate discharge monitoring report for each month and shall report each calendar year's results (lb/yr) with the December report for that year. A.(8.) NITROGEN OPTIMIZATION INCLUDING PRETREATMENT PROGRAM UPDATES [G.S. 143-215.1(b)] Nitrogen Removal Optimization Requirements a. By January 30, 2023 (90 days after the permit effective date), the Permittee shall: i. Implement recommendations outlined in the Total Nitrogen Removal Optimization report, submitted to the Division in November 2020. ii. Submit a quarterly report to the Division documenting implementation of the optimization report recommendations and describing expected results. The Permittee shall report any noncompliance events as required by Standard Conditions (Part II). iii. This requirement will terminate upon receipt of the Engineer's Certificate of completion for expansion to 6.0 MGD. b. Reports shall be submitted to: NCDENR / DWQ / NPDES Permitting 1617 Mail Service Center Raleigh, NC 27699-1617 Pretreatment Program Updates [15A NCAC 021-1.09001 a. By December 1, 2022 (30 days after the permit effective date), the Permittee shall: i. Update and submit for Division approval any draft Industrial User Permit(s) (IUPs) and any future IUP(s) including nutrient limits to be aligned with the NPDES compliance schedule [See A. (9.)]. ii. Issue the above IUP(s) within 30 days of Division approval. iii. Issue an IUP to the Town's Water Treatment Plant with TSS, Total Iron and any other applicable limits to address pass through and interference with the WWTP. iv. Submit all SIU permit changes as required in Special Conditions for Municipal Facilities Part IV Section C — Municipal Control of Pollutants from Industrial Users. Page 43 of 49 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (9.) COMPLIANCE SCHEDULE FOR FACILITY EXPANSION TO 6.0 MGD AND TOTAL NITROGEN LOAD LIMITATIONS [G.S. 143-215.1(b)] 1. By November 30, 2022, the Permittee shall complete design and submit an Authorization to Construct (AtC) Permit application to the Division for expansion to 6.0 MGD. 2. By February 1, 2023, the Permittee shall submit a report to the Division summarizing actions taken since the permit effective date through December 2022 toward expansion construction and compliance with the TN Load limitations. 3. By December 31, 2023, the Permittee shall achieve compliance with the interim TN limit of 146,117 lb/yr (for the 2023 calendar year). 4. By February 1, 2024, the Permittee shall submit a report to the Division summarizing actions taken during the 2023 calendar year toward expansion construction and compliance with the TN Load limitations. 5. By August 31, 2024, the Permittee shall complete construction of the third treatment train with a capacity of 2 MGD. 6. By December 31, 2024, the Permittee shall complete construction of the 6.0 MGD expansion and submit to the Division an Engineer's Certificate of completion. 7. By December 31, 2024, the Permittee shall achieve compliance with the weighted TN limit of 115,678 lb/yr [combined mass of an eight -month load at 146,117 lb/yr (i.e., 97,411 lb) from 1/l/2024-8/31/2024 and a four -month load at 58,800 lb/yr (i.e., 18,267 lb/yr) from 9/l/2024-12/31/2024]. 8. The Permittee shall achieve compliance with the final TN Load limit of 54,800 lb/yr by December 31, 2025 (for the 2025 calendar year). All reports shall include the owner's name, NPDES permit number and Permittee contact person, and shall be submitted to: (1) NCDEQ / Division of Water Resources NPDES Permitting 1617 Mail Service Center Raleigh, NC 27699-1617 A. (10.) NUTRIENT REOPENER [G.S. 143-215.1(b)] (2) NCDEQ / Division of Water Resources Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27604 In the event that Permittee proposes to accept future industrial process wastewater, including additional wastewaters from Mountaire Farms, and that wastewater is expected to contain concentrations of Total Nitrogen (TN) and/ or Total Phosphorus (TP) greater than typical domestic wastewater concentration (i.e. greater than 40.0 mg/L TN or greater than 5.0 mg/L TP), the Permittee shall notify the NPDES Municipal Permitting Unit of the Division at 1617 Mail Service Center, Raleigh, NC 27699 and the Raleigh Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 within 30 days of knowledge that the Town is considering accepting new industrial process wastewater containing excess nutrients. The notification shall contain information regarding the proposed discharge flow, composition, and amenability to treatment at the Siler City WWTP. Changes in effluent characteristics may require a permit modification, so notification should be at least 180 days prior to the start of the proposed discharge. Based on information provided by the Town regarding a potential new industrial process wastewater with high nutrient concentration, and pursuant to N.C. General Statute Section 143-215.1 and the implementing rules found in Title 15A of the North Carolina Administrative Code, Subchapter 2H, specifically, 15A NCAC 2H.0112(b) (1) and 2H.0114(a), and Part II, Conditions B-12 and B-13 of this permit, the Director of DWR may then reopen this permit to require supplemental nutrient limits for Total Nitrogen and/or Total Phosphorus in accordance with the current Basin Plan for the Cape Fear River Basin. Page 14 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (11.) NUTRIENT WATER QUALITY MODELING REOPENER [G.S. 143-215.1(b)] Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II sections B-12 and B-13 of this permit, the Director of DWR may reopen this permit to require supplemental nutrient monitoring of the discharge. The purpose of the additional monitoring will be to support water quality modeling efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan developed jointly by the Division and affected stakeholders. In addition, the results of water quality modeling may require that limits for total nitrogen and total phosphorus be imposed or modified in this permit upon renewal. A. (12.) MERCURY MINIMIZATION PLAN (MMP) [G.S. 143-215.1 (b)] The Permittee shall maintain and continue to implement the Mercury Minimization Plan (MMP) developed in the previous permit term. The MMP shall continue to be available for inspection on -site. The MMP should place emphasis on identification of mercury contributors and goals for reduction. Results shall be summarized and submitted with the next permit renewal. Performance of the MMP will meet the requirements of the TMDL (Total Maximum Daily Load) for mercury approved by USEPA on October 12, 2012, unless and until a Waste Load Allocation specific to this facility is developed and this NPDES permit is amended to require further actions to address the Waste Load Allocation. A. (13.) 1,4-DIOXANE RE -OPENER [NCGS 143-215.1 (b)] Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II, Sections B-12 and B-13 of this permit, the Director of DWR may reopen this permit to modify permit requirements to address 1,4-Dioxane monitoring, treatment and/or compliance upon evaluation of collected monitoring data for potential effluent limits. A. (14.) PFAS MONITORING REQUIREMENT [G.S. 143-215.l(b.)] This reporting requirement for the per- and polyfluoroalkyl substances (PFAS) parameters listed under Table 1 of the Final Method 1633 takes effect the first full calendar quarter following six (6) months after EPA publishes a 40 CFR part 136 Final PFAS Method for wastewater in the Federal Register. Monitoring will be at a quarterly frequency. Find the current parameters listed under Table 1 of the August 2021 Draft Method 1633 Analysis of Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous, Solid, Biosolids, and Tissue Samples by LC-MS/MS at: https://www.epa.gov/system/files/documents/2021-09/method_1633_draft_aug 2021.pdf Page 45 of 49 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 A. (15.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting • Section D. (6.) Records Retention • Section E. (5.) Monitoring Reports 1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1 The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted monthly electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit monthly DMRs electronically using the internet. The eDMR system may be accessed at: https:Hdeq.nc.gov/about/divisions/water-resources/edmr. If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the following address: NC DEQ / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 See "How to Request a Waiver from Electronic Reporting" section below. Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2025, the Permittee must electronically report the following compliance monitoring data and reports, when applicable: Sewer Overflow/Bypass Event Reports; Pretreatment Program Annual Reports; and Clean Water Act (CWA) Section 316(b) Annual Reports. The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). Page 16 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NC0026441 2. Electronic Submissions In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each electronic submission. The Permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: https://www.federalre ig s�gov/documents/2015/10/22/2015-24954/national-pollutant-discharge- elimination-system-nodes-electronic-renorting-rule. Electronic submissions must start by the dates listed in the "Reporting Requirements" section above. 3. How to Request a Waiver from Electronic Reporting The Permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed five (5) years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the Permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: http://deq.nc.gov/about/divisions/water-resources/edmr 4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1 All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://deq.nc. gov/about/divisions/water-resources/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: 7 certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, Page 17 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " 5. Records Retention [Supplements Section D. (6.)] The Permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least three (3) years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.4 1]. Page 18 of 19 DocuSign Envelope ID: BE4B49F0-FCB3-4935-8395-089B8438A007 Permit NCO026441 r • ' 5C u LO 'tN - - aIL 0- o, LL J c cj n N J J Rm L Ir �+ N V z Y I�Inn zao a a _ co in M u` E j �cno 0 o N R r O W O O a LL E �� m Ex O U O �• 1 N m LL LL j 6' H L O o U ro U Erl r z Qy m -te_� cm h A -- lC'st1 ,_•ice.--i`li ,�' '!l 3 t Page 19 of 19 o° MASS TRANSFER SYSTEMS, INC. 100 Waldron Road, Fall River, MA 02720-4732 MT7_7�'s Tel. (508) 679-6770 ® Fax (508) 672-5779 JET AERATION AND MIXING SYSTEM SUBMITTAL DATA FOR TOWN OF SILER CITY, NORTH CAROLINA WASTEWATER TREATMENT PLANT EXPANSION SRF NO. CS370427-04 SPECIFICATION SECTION 12 -OXIDATION DITCHES- -SLUDGE HOLDING TANKS- -FLASH MIXING TANK- MTS#M91-143 JUNE 2, 1992 ENGINEER: HOBBS, UPCHURCH & ASSOCIATES 290 S.W. BROAD STREET SOUTHERN PINES, NC 28388 CONTRACTOR: STATE UTILITY CONTRACTORS, INC. MONROE, NC MTS REPRESENTATIVE: COMBS & ASSOCIATES, INC. P. O. BOX 32185 CHARLOTTE, NC 28232-2185 (704) 376-0450 I W.1 Iola offU 1► I Diem 9 I. SYSTEM DESCRIPTION 11. MATERIAL SPECIFICATION III .DRAWINGS AND DETAILS as 11 will a na V to)g OXIDATION DITCHES The Mass Transfer Systems, Inc. Jet Aeration System is designed to provide oxygen transfer and mixing for the specified application described in the following design parameters located in this section. The aeration equipment supplied for each oxidation ditch consists of three (3) MT2JM-30 jet aeration manifolds. Refer to Scope of Supply provided in this section for additional information about material being supplied by MTS for this project. Each jet aeration manifold system recirculates the liquid contents of the oxidation ditch. The liquid is recirculated through each jet aeration manifold using a recirculation pump. As the liquid enters the jet aeration manifold it pressurizes, and is then dispersed into the jet aeration nozzles which consist of a primary (inner) and secondary (outer) jet nozzle. As the liquid passes through the primary nozzle it comes in contact with the low pressure air that is passing through the secondary jet nozzle. The result is a fine bubble stream discharged horizontally across the bottom of the basin or tank at equally spaced intervals. This provides oxygen transfer and mixing throughout the oxidation ditches. Refer to MTS Design Parameters provided in this section for additional design criteria. SILER CITY, NORTH CAROLINA DESIGN PARAMETERS --OXIDATION DITCHES Process Number of Basins Basin Dimensions (ft.) Overall Length Channel Width S.W.D. Basin Volume (Mil. Gallons) Design Flow Rate (m.g.d.) Design Influent BODE (mg/l) Design Effluent BOD5 (mg/1) Design Influent NH3-N (mg/1) Design Effluent NH3-N (mg/1) lb 02/lb BOD Removed lb 02/lb NH3-N Removed Alpha Beta Residual D.O. (mg/1) Theta Temp. (°C) Elevation (ft.) SRT (days) F/M Design MLSS Concentration (mg/1) Influent Alkalinity (mg/1) Stoichiometric Alkalinity Required (mg/1) Net Alkalinity Requirement (mg/1)l Domestic Wastewater - Oxidation Ditch 2 200 40 20 2.2 4.0 350 5 45 1 1.3 4.6 0.70 0.95 2.0 1.024 20 600 17 0.085 4000 105 321 112 1 Assumes 40-50 mg/l in effluent and denitrification regain SILER CITY, NORTH CAROLINA MTS DESIGN SUMMARY OXIDATION DITCHES Actual Oxygen Required (lbs/d) per Basin 10,857 Total 21,714 Standard Oxygen Required (lbs/hr) per Basin 866 Total 1732 MTS Jet Aerators Required per Basin 3@MT2JM-30 Jet Manifolds Total 6@MT2JM-30 Jet Manifolds Airflow Required (SCFM) per Aerator 869/11851 per Basin' 2923 Total 5846 Approximate Compressor Discharge Pressure (psig)(2) 9.0 Oxygen Absorption Efficiency (%) 28.6 Liquid Recirculation Required (gpm) per Aerator 5490 per Pump 5490 per Basin 16,470 Total Power Required (BHP) Compressors(3) 315 Pumps(4) 200 Total 515 Oxygen Transfer Efficiency (lbs Std. 02/BHP-hr) 3.4 Power Density (BHP/MG) 117 Horizontal Bulk Fluid Velocity (ft/sec) 1.2 (1) 2 headers @ 869 SCFM, 1 header @ 1185 SCFM (2) Assumes 1.0 psig loss -compressor inlet to basin edge (3) Assumes 900F, 600 ft. elevation (4) Assumes 2 ft. losses from pump suction to aerator, 75% efficiency