HomeMy WebLinkAboutNC0086584_Permit Issuance_19991112State of North Carolina
Town of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens Director
Mr. Tim M. Johnson, Town Manager
Town of Belhaven
P.O. Box 220
Belhaven, North Carolina 27810
Dear Mr. Johnson:
Q��
NCDENR
November 12, 1999
Subject: Issuance of NPDES Pennit NCO086584
Belhaven WTP
Beaufort County
In accordance with your application for discharge permit received on November 17,
1998, we are forwarding herewith the subject discharge 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 December 6, 1983 and as subsequently amended.
If any parts, measurement frequencies or sampling requirements contained in this
permit are unacceptable to you, you have the right to an adjudicatory hearing upon
written request within thirty (30) days following receipt of this letter. This request must be
in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer
27447, Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision
shall be final and binding.
The following items were previously noted in the draft permit sent to you:
• A flow limit approximately equivalent to the maximum possible reject rate has been
installed.
• All parameters shall be monitored monthly, based on the size of the reject stream.
• Monitoring and limits for various parameters of concern have been installed to protect
instream water quality.
• Instream monitoring for Dissolved Oxygen has been included in the permit.
• Although it appears this discharge will not contain any phosphorus, a limit is being
installed in accord with the Phase II Nutrient Sensitive Waters agreement for the basin.
You may request that the Division review the need for the monitoring and limitations
after 12 data points have been collected. A reduction or elimination of monitoring may be
approved based upon the information you provide. As you are aware, the Division has
concerns with the various parameters that may be present in the reject stream and may
require the relocation or elimination of the discharge, based upon the effluent quality or any
adverse impact on instream water quality.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone (919) 733-5083 FAX (919) 733-0719
An Equal Opportunity Affirmative Action Employer VISIT us ON THE INTERNE @ http://h2o.enr.state.nc.us/NPDES
Please note that this permit is not transferable except after notice to the Division.
The Division 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 or permits required by the Division of Land Resources, the
Coastal Area Management Act or any other Federal or Local governmental permit that may
be required.
If you have any questions concerning this permit, please contact the NPDES Unit at (919)
733-5083.
Sincerely,
Original Signed By
David A. Goodrich
Kerr T. Stevens
cc: Central Files
Washington Regional Office/WQ Section
NPDES Unit/Permit Files
Point Source Compliance Enforcement Unit
Aquatic Toxicology Unit
Technical Assistance & Certification Unit
b.
Permit No. NCO086584
STATE OF NORTH CAROLINA
TOWN OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMT
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, the
Town of Belhaven
is hereby authorized to discharge wastewater from a facility located at the
Belhaven WTP
0.4 miles north of U.S. Highway 264
Beaufort County
to receiving waters designated as an unnamed tributary to Pantego Creek in the Tar -Pamlico
River Basin
in accordance with the discharge limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III, and N hereof.
This permit shall become effective December 1, 1999.
This permit and the authorization to discharge shall expire at midnight on November 30, 2004.
Signed this day November 12, 1999.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By the Authority of the Environmental Management Commission
r ;.
SUPPLEMENT TO PERMIT COVER SHEET
Town of Belhaven
is hereby authorized to:
Permit No. NC0086584
1. After receiving an Authorization to Construct from DWQ, operate a conveyance
system for a membrane filtration water treatment plant located at the Belhaven WTP
0.4 miles north of U.S. Hwy 264, Beaufort County, and
2. Discharge reject water from a water treatment plant at the location specified on the
attached map into an unnamed tributary to Pantego Creek which is classified SC -
NSW waters in the Tar -Pamlico River Basin.
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V%6S QVAtS MAP VSC_jS OUAD PIAP
NCO086584
Qu.-O # E32SE
Recei%ing Stmam Ur Pm-ia?go Cit-ek- Town of Belhaven
Stir,un Chm: SC INSW WTP
Subbasi= 30307
L,� Uoaleys Pt
Facility-V W,
'T
Location
North I F_ SCALE I:24000 I
Permit NCO086584
A. (1) . E FFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Upon commencement of the discharge and lasting until expiration, the Permittee is authorized to
discharge from outfall serial number 001 — membrane process reject. Such discharges shall be
limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Location'
Flow
0.22 MGD
Continuous
Recording
Effluent
Total Suspended Solids
30.0 m I
45.0 m I
Monthly
Grab
Effluent
Settleable Solids
0.1 ml/l
0.2 ml/l
Monthly
Grab
Effluent
Turbidity2
See note 2
Monthly
Grab
Effluent
H3
See note 3
Monthly
Grab
Effluent
Arsenic
50 I
Monthly
Grab
Effluent
Beryllium
Monthly
Grab
Effluent
Cadmium
5.0 /I
Monthly
Grab
Effluent
Chromium
20 u /I
Monthly
Grab
Effluent
Copper
Monthly
Grab
Effluent
Cyanide
1.0 /I
Monthly
Grab
Effluent
Lead
25 /I
Monthly
Grab
Effluent
Mercury
0.025 µ /I
Monthly
Grab
Effluent
Nickel
8.3 /I
Monthly
Grab
Effluent
Salinity
Monthly
Grab
Effluent
Selenium
71,u /I
Monthly
Grab
Effluent
Silver
Monthly
Grab
Effluent
Zinc
Monthly
Grab
Effluent
Fluoride
Monthly
Grab
Effluent
Iron
Monthly
Grab
Effluent
Total Residual Chlorine4
Monthly
Grab
Effluent
Total Phos horus5
1.0 mg/I
Quarterly
Grab
Effluent
Acute ToxiCity6
Quarterly
Grab
Effluent
Dissolved Oxygen
Monthly
Grab
Upstream &
Downstream
Notes:
i Samples shall be collected at some point after all treatment units and prior to discharge, unless
otherwise noted.
z The discharge shall not cause the turbidity of the water at the discharge point to exceed 25 NTU. If
the turbidity exceeds these levels due to natural background conditions, the discharge level cannot
cause any increase in the turbidity in the receiving water.
s The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units.
4 Total Residual Chlorine monitoring is only required if chlorine is added.
s Total Phosphorus monitoring shall be increased to monthly if any chemicals containing phosphates
are added during the treatment process.
s Acute Toxicity Monitoring P/F (Mysidopsis bahia) Q 90%, during the months of January, April,
July, and October. See Part I, Condition A. (2.). Further studies will be required to determine the
cause of toxicity, if any. The collection of samples shall coincide with the sampling of other
parameters.
Values reported below quantitation levels shall be considered compliant with the permit.
All samples collected shall be of a representative discharge.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Permit NCO086584
A. (2). ACUTE TOXICITY PASS/FAIL MONITORING (Quarterly)
The permittee shall conduct acute toxicity tests on a quarterly 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 Mysid shrimp (Mysidopsis bahia) 24-hour static test. The effluent concentration at which there may
be at no time significant acute mortality is 90% (defined as treatment two in the procedure document).
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 &
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: NC DENR / DWQ
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 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.
v Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring
will begin immediately until such time that a single test is passed. Upon passing, this monthly test
l' requirement will revert to quarterly in the months specified 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 single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from either these monitoring requirements 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 vvill require
immediate follow-up testing to be completed no later than the last day of the month following the month of
the initial monitoring.
tAo VVASHINGTON DAILY NEWS
WThe Voice of the Pamlico
P.O. BOX 1788
uw "C WASHINGTON, N.C. 27889
CLASSRED
ADVERTISING INVOICE
START DATE
Z.•'9'*
STOP DATE
09l• /%
SMTWTFS
INSERTIONS WORDS
SFP2 �
COOFITE1QQiARGE
D"boN POSTAGE UARANTEED
l ^ c^.c
PAYABLE UPON PLEASE RETURN THIS STUB
AMOUNT DUE PRESENTATION WITH YOUR REMITTANCE
GCt;i`L g;Tt C_.
rn-- -
n
PUBLIC NOTICE
t STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 27626-0535
NOTIFICATION OF INTENT TO ISSUE A
STATE NPDES PERMIT
On the basis of thorough staff review and applica-
tion of Article 21 of Chapter W, General Statutes
of North Carolina, Public Law 92.500 and other.
lawful standards and regulations, the North Caro-
line Environmental Management Commission pro-
poses to issue a permit to discharge to the per-
sons listed below effective 11/8199 and subject to
special conditions.
Persons wishing to comment upon or object to the
proposed determinations are invited to submit
same in writing to the above address no later
than 10/22/99. All comments received prior to
that date will be considered in the formulation of
final determinations regarding the proposed per.
mit. A public meeting may be held where the Di-
rector of the Division of Environmental Manage-
ment finds a significant degree of public interest in
a proposed permit.
A copy of the draft permit is available by writing or
calling the Division of Environmental Manage-
ment, P.O. Box 29535, Raleigh, North Carolina
27626.0535,(919)733.7015.
1
The application and other information may be in-
spected at these locations during normal office
hours. Copies of the information on file are availa-
ble upon request and payment of the costs of re-
production. All such comments or requests re-
garding a proposed permit should make reference
5. to the NPDES permit number listed below.
„,A Date 9-15
" David A. Goodwich
r Ken T Stevens, Director
'} ivision of Environmental Management
!` a- &Olic notice of intent to issue a State NPDES
C' 'Wrrmlttothe f0l
No. The Town of Belhav-
-� a haven, NC 27810 has ap-
plied for a new permit for a facility located at the
Belhaven WTP, Beaufort County. This water treat-
ment facility proposes to discharge 0.22 MGD of
reject water from a membrane filtration process
from 1 oudall into an unnamed tributary to Pants -
go Creek, a Class SC -NSW stream in the Tar -
Pamlico River Basin which has a 7010 flow of 0
cis and a 3002 flow of 0 cfs.
9-22 1tc
NPDES FACILITY AND PERMIT DATA 12/01/98 10:46:41
UPDATE OPTION TRXID 5NU KEY NC0086584
PERSONAL DATA FACILITY APPLYING FOR PERMIT REGION
FACILITY NAME> BELHAVEN, TOWN - WTP COUNTY> BEAUFORT 07
ADDRESS: MAILING (REQUIRED) LOCATION (REQUIRED)
STREET: 301 EAST MAIN STREET STREET: 0.4 MI. NORTH OF U.S. HWY 264
CITY: BELHAVEN ST NC ZIP 27810 CITY: BELHAVEN ST NC ZIP 27810
TELEPHONE 252 493 3055 DATE FEE PAID: 11/17/98 AMOUNT: 400.00
STATE CONTACT> PELLEI PERSON IN CHARGE TIM JOHNSON
1=PROPOSED,2=EXIST,3=CLOSED 1 1=MAJOR,2=MINOR 2 1=MUN,2=NON-MUN 2
LAT: LONG: N=NEW,M=MODIFICATION,R=REISSUE> N
DATE APP RCVD 11/17/98 WASTELOAD REQS 48/3 /Iq
DATE STAFF REP REQS Z / 4 /`i9 WASTELOAD RCVD D / 4 / tq
DATE STAFF REP RCVD C?/10/0.4 SCH TO ISSUE
DATE TO P NOTICE / / DATE DRAFT PREPARED
DATE OT AG COM REQS / / DATE DENIED
DATE OT AG COM RCVD / / DATE RETURNED
DATE TO EPA / / DATE ISSUED / / ASSIGN/CHANGE PERMIT
DATE FROM EPA / / EXPIRATION DATE
FEE CODE ( ) 1=(>10MGD),2=(>lMGD),3=(>O.lMGD),4=(<O.1MGD),5=SF,6=(GP25,64,79),
7=(GP49,73)8=(GP76)9=(GP13,34,30,52)0=(NOFEE) DIS/C CONBILL ( )
COMMENTS: FAX# 252 493-2357/ENG=TYLER HIGHFILL-ARCADIS->782-5511
MESSAGE: *** ENTER DATA FOR UPDATE ***
�.TiCt tv�SD VAT Lpn�G,
s �Lve 5���
DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO086584
Facility Jnibrmation
FacilityName:
Town of Belhaven
Permitted
ow (MGD):County:
Beaufort
Facility
ass:Regional
ice:
WAKU
Facility/PermitStatus:
New
opo Quad:
Summary
This application is for a new discharge for a reject stream from a membrane filtration water
treatment plant for the Town of Belhaven.
The reject water will discharge to local canals that drain to the Pantego Creek, which, in turn, leads
to the Pamlico Sound. It has been listed as support threatened due to occasional coliform problems
fit° f and the presence of nutrients has been linked to the occasional algal blooms. This area is primarily
`y estuarine and has experienced fish kills in the past. The Pamlico Sound itself has experienced
elevated chlorophyll a and several instances of low dissolved oxygen. To address these problem
the basin plan calls for a 30% reduction of TN & TP.
This permit is drafted in accord with the ROMP memo dated January 12, 1998. This memo
JX (�► recommends most monitoring to be monthly and includes monitoring for toxicity.
a
The WARO originally had concerns regarding possibly high concentrations of TOC, NH3-N and
Fluoride being discharged to a possible zero flow stream. The applicant responded to these
concerns with additional information. In a follow up e-mail the WARO requested instream DO
and fluoride monitoring be added to the permit.
Copies of the following are attached to provide additional information on the permit development:
Existing permit effluent sheets with changes noted (existing facilities only)
Draft Permit
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: I)A*#9 ct/Zga9
Permit Scheduled to Issue: Ut09 1 � lvf q q
State Contact
If you have any questions on any of the above information or on the attached permit, please contact
Steve Pellei at (919) 715-6219.
NPDES Recommendation by:I � (
a,T115-t?- i-t.Vt7\ � S "
Regional Office Comments
Regional Recommendation by:
Reviewed By:
Date:
Regional Supervisor:
Date
NPDES Unit:
Author: "Al Hodge" <Al_Hodge@waro.enr.state.nc.us> at Internet
Date: 7/20/99 10:27 AM
Priority: Normal
Receipt Requested
BCC: Steve Pellei at NRDEMCGP
TO: Steve_pellei@h2o.enr.state.nc.us at Internet
Subject: NC0086584-Town of Belhaven-RO Discharge
------------------------------------ Message Contents
------------------------------------
HI Steven:
I raised concerns regarding the possibility of 02 uptake
problems in the proposed zero flow discharge stream in my staff
report of 2-19-99. I also voice concerns regarding fluoride
concentrations as they relate to WQ standards and toxcity. The
response recieved is adequate to assert that my concerns may not
happen. However, it is not conclusive that the problems will not
occur. I have discussed this point with the Town Manager and the
Engineering firm. I informed them that in my opinion the Town was
taking a change; but it was theirs to take.
I recommend that the effluent monitoring incluce up & down
stream monitoring for DO with the points set by the Regional
Office. Also, fluoride monitoring in the-.ef uent. I would also
recommend a condition be placed in the permit establishing that
there was concerns with these parameters "up front" and if WQ
standards are violated the discharge must be relocated or
e 1 imi e d . --_ - - _ .----___---
Al Hodge
Washington Regional Office
A (1). E FFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Permit No. NCO086584
Upon commencement of the discharge and lasting until expiration, the Permittee is authorized to discharge from outfall serial number 001-
membrane process reject. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Monthly
Average
ai y
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
on inuous
Recording
uen
Total Suspended o i s
45.0 mg
on y
ra
uen
settleable o i s
. m
m
on y
ra
uen
Turbidity
ee no a
on y
ra
uen
pH
ee no a
on y
raEffluent
rsenic
µg
Monthly
Grab
---Eff Fu-en-F—
Beryllium
I
Monthly
Grab
Effluent
a mwm
I 6.Tpg7r—on
y—
----G-raF
Effluent
Gh romium
on y
ra
uen
-oppe�
µg
on y
ra
uen
yani e
ti
on y
ra
uen
Lead
µg
on y
ra
uen
ercury
µg
on y
ra
uen
c e
Monthly
ra
uen
a ini
MonthlyUral)
Effluent
e enium
5
on y
ra
uen
ever
µg
on y
ra
uen
inc
on y
ra
uen
uon a
Monthly
ra
uen
ron
Monthly
raEffluent
Total Residual Chlorine
Monthly--
ra
uen
Total Phosphorus
mg
Quarterly
ra
uen
Acute Toxicity
ua ery
ra
uen
DissolvedOxygen
on y
ra
Notes:
iW3 ,,J-(, fD be.. [A.is i S 4cn.i-it
1 Samples shall be collected a oin fter all treatment units, unless otherwise noted. U - Upstream. D - Downstream.
2 The discharge shall not cause the turbidity of the water at the discharge point to exceed 25 NTU. If the turbidity exceeds these levels due to natural
background conditions, the discharge level cannot cause any increase in the turbidity in the receiving water.
a The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units.
4 Total Residual Chlorine monitoring is only required if chlorine is added.
s Total Phosphorus monitoring shall be increased to monthly if any chemicals containing phosphates are added during the treatment process.
e Acute Toxicity Monitoring P/F (Mysidopsis bahia) @ 90%, during the months of January, April, July, and October. See Part I, Condition A(2). Further
studies will be required to determine the cause of toxicity, if any. The collection of samples shall coincide with the sampling of other parameters.
Values reported below quantitation levels shall be considered compliant with the permit.
All samples collected shall be of a representative discharge.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
ARCADIS GERAGHTY&MILLER
'n s
ARCADIS Geraghty & Miller, Inc
2301 Rexwoods Drive
Suite 102
Mr. Charles Weaver Raleigh
NPDES Unit North Carolina 27607-3366
North Carolina Department of Environment and Tel 919 782 5511
Natural Resources Fax 919 782 5905
Post Office Box 29535
Raleigh, North Carolina 27626-0535
WATER AND WASTE
Subject: MANAGEMENT
NPDES Permit Number NCO086584
Town of Belhaven, Beaufort County
ARCADIS Geraghty & Miller Project Number NC039341.0040
Dear Mr. Weaver: Raleigh, NC,
25 June 1999
In response to Steve Pellei's comments faxed via Al Hodge at the Washington
Regional Office on March 26, 1999, for the subject project, please find enclosed the Contact;
NPDES Staff Report and Recommendations and three copies of our Responses to Tyler HighU
NPDES Permit Review Continents.
Please let us ]mow if you need additional information.
Extension:
Sincerely, 138
ARCADIS Geraghty & Miller, Inc.
V/ 2 *//
Tyler W. Highfill, P.E.
Enclosures
/mre
Copies:
Al Hodge with enclosures
Tim Johnson with enclosures
John Maynard
Our ref.:
N0039341.0040/cw-let.doc.doc
RESPONSES TO NPDES PERMIT REVIEW COMMENTS 22 June 1999
WATER TREATMENT SYSTEM IMPROVEMENTS
NPDES APPLICATION NO. NCO086584
TOWN OF BELHAVEN, NC
ARCADIS PROJECT NO. NC039341.0040
Back-up calculations, lab results, cost estimates, etc. for the responses to each comment are
attached at the end of this summary for reference.
COMMENT 1: 1 have concerns regarding a BOD from this discharge. It has come to my attention
that the source water is high in Total Organic Carbon (TOC). The concentrations are potentially
high with the reject water being concentrated four times to source water. I request that the
applicant address this trough testing.
RESPONSE: A concentrate sample is unavailable at this time. We have been unable to
locate a vendor or laboratory that is willing to produce a concentrate sample for a
reasonable costs. A demonstration pilot unit could be brought on -site to test the raw
water source a minimum estimated cost of $33,000.
The Standard Methods procedure of analysis of samples with a high BOD5 includes dilution
of the sample prior to performing the laboratory test. The measured BODS is then
multiplied by the appropriate concentration factor to get the BOD5 of the original waste
sample. Since a sample of the reject stream is not available, we have collected BOD5 data
on the raw water and multiplied by appropriate concentration factors to estimate the BOD5
of the actual reject waste. The result of the BOD5 test indicated oxygen demands below
detectable limits which projects to a concentrate BOD5 below detection limits.
In addition, a raw water sample was concentrated in the lab to a volume 25% of its original
volume to replicate a WTP recovery of 75%. The concentrated sample was tested for BODS
and the results also indicated an undetectable oxygen demand.
Based on these parallel tests we conclude that the reject stream should not impart a
biochemical oxygen demand on the receiving body.
COMMENT 2: 1 also have concerns with an oxygen uptake exerted from the NH4 in the discharge.
The oxidation occurs at a ratio of 1.502 to NH4. The oxidation process requires the autotrophic
organism Nitrosomonas that occurs naturally.
RESPONSE: A summary of the nitrogen cycle is outlined below for reference. The presence
of naturally produced ammonia requires the presence and complete degradation of
proteins and organic matter. The process of manufacturing agricultural fertilizer is also a
source of ammonia nitrogen. Since the Belhaven wells are not under the influence of
surface waters, these surface sources of ammonia should not be present in the source
water.
Nitrogen Cycle:
Protein 4 Organic Nitrogen 4 Ammonia -i Nitrite 4 Nitrate 4 Nitrogen Gas
Page:
11npPm1ltlrtt.Mvwmt393CIdWnaYMp-pTpmmittine\naponu to npd<v mmmenh.tlop 1/3
We have tested 5 samples for nitrate and nitrite which have all returned results below
detection limits. We have tested 7 samples for ammonium ions which have returned 6
results below detection limits and one result at 0.01 ppm above detection limits. The table
below is a summary of samples analyzed.
SAMPLE
CONCENTRATION
SAMPLE LOCATION
DATE
(as NH3-N)
& LAB
1/20/98
<0.2 ppm
Test Well (Oxford Labs)
8/13/98
0.8 ppm (1)
Test Well (Chemical and
Environmental Testing)
4/20/99
<0.2 ppm
Well No. 2 (Oxford Labs)
4/20/99
0.56 ppm (2)
Well No. 2 (Oxford Labs)
425/99
0.11 ppm (3)
Well No. 2 (Oxford Labs)
425/99
<0.10 ppm
Well No. 2 (Oxford Labs)
425/99
<0.10 ppm
Well No. 2 (Oxford Labs)
425/99
<0.10 ppm
Well No. 2 (Oxford Labs)
4/25/99
<0.10 pprn
Well No. 2 (Oxford Labs)
Footnotes:
(1) Apparent outlier (4.9 times higher than test set average)
(2) Sampler dumped out preservative, therefore invalid result
(3) 5 samples taken at 30 minute intervals on 4/25/99
The samples noted with footnotes 1 and 2 in the table above have been excluded in the
analysis of ammonia in the raw water. Of the remaining 7 samples analyzed, only one was
detected with ammonia. The average ammonia concentration is therefore 0.016 ppm NH3-
N.
Our conclusion is that there is not enough ammonium ions in the raw water to impact
the receiving stream.
In case there is concern from the NCDENR, we have performed the following analysis of
reaction kinetics (see also attached back-up calculations):
Theoretical reaction kinetics indicate a cell growth time of 21 days (504 hours)
based on 0.064 ppm NH3-N in the reject stream (expected raw water ammonia
concentration of 0.016 ppm concentrated 4 times). The receiving body has a 1
foot drop over the 5000' distance to Pantego Creek. Using normal depth
procedures on a typical ditch cross section, the average velocity is projected at 0.4
feet per second. The time of travel to the creek is therefore 3.5 hours which is more
than 140 times shorter than the time required for nitrofier bacteria growth (Ref. EPA
Process Design Manual for Nitrogen Control, 1975).
Based on the raw water sampling and nitrofying baceria kinetics, we conclude that
there will not be a significant nitrogenous biochemical oxygen demand on the receiving
body due to discharge of the reject stream.
Page:
�acte�tweewwmvvadtaoknawna-se`oe�minino�meonee to nodes comment. eoc 2/3
COMMENT 3: It appears that Ropers Ditch; the drainage structures name at Pantego Creek is
partially plugged at the mouth. I have concluded this because of the water level in the ditch year
round.
RESPONSE: We incorrectly identified the route from the discharge point to Pantego Creek.
Upon review of this item with the Owner, they have informed us of the actual flow path to
Pantego Creek.
We have modified the USGS map accordingly and it is attached for review.
COMMENT 4: Perform engineering evaluation of alternative that would pump the reject stream to
Pantego Creek.
RESPONSE: An engineering evaluation of this alternative has been performed and is
attached. The analysis shows the estimated total present value to implement this
alternative at $412,000.
The cost of this alternatives makes it cost prohibitive to the Town.
COMMENT 5: The fluoride water quality standard is 1.8 ppm with projected concentrations as
high as 2.1 ppm has been shown to have toxic affects at other Nanofiltration filtration reject
discharges.
RESPONSE: The projection of reject fluoride concentration was based on a combination of
the highest sampling result, worst case rejection modeling, worst case recovery projections,
and a 10% degradation in the water supply quality (compounding worst case scenarios).
Based on multiple samplings, the projected average fluoride concentration in the raw water
is expected to be 0.39 ppm.
In a more realistic estimate using the average raw water fluoride concentration, worst case
rejection estimate for fluoride (i.e. 75% ion rejection) and the planned plant recovery of
75%, the estimated fluoride concentration in the reject is projected to be 1.2 ppm which is
67% below the water quality standard.
Based on sampling and above more realistic modeling we do not expect fluoride to be
a water quality concern at this membrane plant.
Page:
ttnnantN.uwwm�saat+wnWrt.smo•�almo��.00n» to nodes mmmem..aoc 3/3
7
.f2
ARCADIS
GERAGHTY&MILLER
SUBJECT:
JOB NO:
BAC4a#VP Foy
commou"r
PACE
BY: DATE:
CHKD: DATE: SHEET
PHONE CALL SUMMARY
8 APR 99
RE: Concentrate Testing for NPDES Comments
Water Treatment System Improvements
Town of Belhaven, NC
Arcadis Project No. NC039341.0040
TYLER HIGHFILL spoke with STUART McCLELLAN, Applications engineer with FilmTec Membranes
Phone: 561-626-6616
Tyler called to ask if Mr. McClellan knew of any procedures for creating an actual concentrate
sample without a pilot test. Mr. McClellan is very familiar with this project and has been in the
membrane business for 20+ years. He does not know of any way to make a concentrate stream
short of setting up a pilot unit in the field.
He did not know of any correlation between TOC and BOD or similar. He said membrane people
are typically not concerned with TOC and BOD in WTP membrane applications so there is not much
data out there.
He suggested running the BODS on the raw water source and applying a concentration factor. If
the organic carbon is in the volatile form (gas) it will pass through the membrane. If it is not, it will
be rejected at nearly 100%.
Page:
9:Iwwm139341.40gw_pUm-phone.doc 1/1
PHONE CALL SUMMARY
8 APR 99
RE: Concentrate Testing for NPDES Comments
Water Treatment System Improvements
Town of Belhaven, NC
Arcadis Project No. NC039341.0040
TYLER HIGHFILL spoke with ROGER OXFORD of Oxford Labs
Phone: 910-763-9793
Tyler called to ask if Oxford Labs could emulate our membrane process in the lab with a grab
sample. Mr. Oxford has never done such a test and does not think it is possible.
Pa
ge:
g.*mm�9341-40%w_p%m-phone.doc 1 / 1
Analytical and Consulting Chemists
(DXFORD 1316 South Fifth Street
aboratories DATE RECEIVED 0 4 - 21- 9 9 Wilmington, N.C. 28401
DATE REPORTED 0 4- 2 9- 9 9 (910) 763-9793
nc. 9 9 W 2 2 3 6 Fax (910) 343-9688
PAGE 1 OF 1
ARCADI S GERAGHTY & MILLER P.O. # APR 1
2301 REXWOODS DR./SUITE 200 ARC �9g
RALEIGH, NC 27607 ADIS
ATTENTION: TYLER H I GHF I LL hfiuet
SAMPLE DESCRIPTION: WELL 2 4=20-99 BELHAVEN
1. WELL 2 41
2. WELL 2 #2 LAB CONCENTRATED
3. WELL 2 #2
RESULTS
,,, 2
BOD5, as 02, PPM <1 <1 X
pH (Lab) 7.40 10.2 7.30
Total Organic Carbon, as C, PPM 12.2 43.4 X
Ammonia Nitrogen, as NH3-N, PPS[ <0.20 <1.75 0.56
Zoo L 6),
'e200
4KN!MIkTH. SENIOR ANALYST
ChKok
GERAGHTY& MILLER
SUBJECT:
JOB NO:
SACK#VP FOR
Co M M EMT 2
PAGE
BY: DATE:
CHKD: DATE: SKEET
BELHAVEN RAW WATER ANALYSIS SUMMARY
MUM MILL 02 WELL 02 VVELL 02
WELL 02 WELL 02
FHSH
W25199 NW99 4IZM 4W09
4125M CONC.• WELL02 WELL02 TEST WELL
TEST WELL
TEST WELL
WELL4t1
WELL02
VVIELL01
WELL02
WATER
CONETITUANT UNITS 10'.40AM 10:10AM 9A' OAM 9t10AM
&AO AM 4120t99 412m MAW 11fla 8
fifla 8
I12O 9
811201
81014
101m
t&SM
GOAL
AlurRnum ppm
0.1
x A moda ppm as NH3-N <O.1b <0.10 <0.10 <0.10
0.11 <1.75 <0.2 0.50- 0.8
<0.2
An@mony ppm
<0.003
<0.008
Arseric ppm
<0.01
<0.005
<0.005
<0.05
x Bartun Dorn
0.02
017
0.010
0.02
0.02
<LO
"um Ppm
<0.002
<0.004
Bron4de ppm
<0.5
0.070
0.05
0.00
<9.4
<0.4
<0.2
Csdmlun Ppm
<0.001
110.001
<0.001
<0.001
<O.001
<0.005
x Calcium ppm
55
00.9
83
86.5
87.5
ass hard.
x Chwde ppm
14
17
13
12
12
12
11
4200
Chnxd m PPm
<O.005
<0.005
<0.005
<0.1
Copper Ppm
<0.01
<0.003
0.005
41.0
Cyanide ppm
<0.005
<0.2
x F1uorlde ppm
0.3
0.52
0.34
1
x_Hydroxide ton ppm
x Iron PPrn
0.12
0.052
0.07
0.512
0.35
<0.3
x tron as Fein+ ppm
Lead ppm
<0.005
<0.003
0.005
<0.015
x Magnesium ppm
17.4
18.07
19.5
18.5
18
17.5
18.2
see hard.
x Manganese oom
0 008
<O Ot
0.008
<0.05
mercury Ppm
<0.0002
<0.0002
<0.0002
<0.002
Ndcel Ppm
<.0/0
<0.1
x Ntmte ppm
<0.1
<t
<0.1
MO
m4rate ppm as NO3-N
<0.1
<0.1
Mile Dorn
<0.1
<0.02
<0.1
<t
x Phosphate Pfxn
0.04
Phosphorus. Total Ppm
<0.1
x Potasslum PPm
12
10.8
12.5
12.5
13
Selenium ppm
<0.01
<0.005
<0.005
40.05
Silica Ppm
25.8
x Siiaa Dioxide Dorn
54.3
54.8
50.5
48.7
sb WM
<0.05
<O.002
<0.002
<0.1
x Sodium PPm
84.8
69.93
70
58
54
x Strontium ppm
1
0.935
0.96
0.935
0.935
x Sulfite ppm
<10
<5.0
<i
1
2
77
Sutiate TurbldimetrEc ppm as SO4
5
5
Sulfide ppm as H2S-S
0.14
0.18
Thalum ppm
<0.001
<0.002
Zinc Donn
0.026
<0.005
013
<5.0
Acidity. Total ppm as CaCO3
54
18
34
Akalrilty, Bicarbonate ppm as CaCO3
393
385
391
392
x Alkalinity. Phenolphthal ppm as CaCO3
nla
rda
n1a
we
Na
x Allafrtty. Total ppen as CaCO3
388
382
370
391
392
372
407
tnardnite
x Bicarbonate Dom
x Carbonate Ppm
0
0
x Carbon Oloxide, field porn
75.80
>100
x Color units
11
15
12
23
22
<5
x Conductivity ppm
Conductivity umhoslem
1440
872
713
x Hardness, Total ppm as CaCO3
277
279
242
253
302
70-100
x hydrogen Sulfide. field ppm
0.3-0.5
0.".7
<0.05
x Odor
none
Dissolved Oxygen Ppm
0.4-0.0
0.8
x Suspended Solds ppm
2
<1
<0.2 ntu
x SOl
Ngh
1.92
x MS Ppm
517
433
419
477
< $00
x TOC ppm
43.4 12.2 18
102
12 10.8
11.4 18.99
20.83
<2
x Turbld ly rtu
41
0.57
41
6.2
14
<0.2 tlrturs aid.
x PH. Held units
7.0
PH. lab units
10.2 7.4 7.3 7.39
7.4
7.4-7.8
7.7
7.3
8.5 - 7.5
x Tom, field
82 FF17 C
lac
hWr5 (FP) ppb
197.5
430 Proposed Stage 2
rn*A (FP) ppb
127.45
330.7
<40 Proposed Stage 2
BODS PPm
des:
x Specifically requested by DOW
Concentrated to ll4 odpinal volurm
Sampler discarded sample preservative
Page 1
Notes:Gmmrcd
Mathyt Orange indicates PH a 4.5 (003-)
Phenotphthaleln Indicates pH a 8.3 (HCO3-)
Phsnclpfthalein Acidly a Total Acidity
Methyl Orange AtlaM ty a Total Alodttly
Analytical and Consulting Chemists
(DXFORD 1316 South Fifth Street
aboratories DATE RECEIVED 0 4 - 21- 9 9 Wilmington, N.C. 28401
DATE REPORTED 0 4- 2 9- 9 9 (910) 763-9793
ne. 9 9 W 2 2 3 6 Fax (910) 343-9688
ARCADIS GERAGHTY & MILLER
2301 REXWOODS DR./SUITE 200
RALEIGH, NC 27607
ATTENTION: TYLER HIGHFILL
PAGE 1 OF 1
zvxb
P.o. # AP.R tl
1999
ACAbjV g tyMlllcr
SAMPLE DESCRIPTION: WELL 2 4-20-99 BELHAVEN
1. WELL 2 #1
2. WELL 2 #2 LAB CONCENTRATED
3. WELL 2 #2
BOD5, as 02, PPM
pH (Lab)
Total Organic Carbon, as C, PPM
Ammonia Nitrogen, as NH3-N, PPM
RESULTS
1 2 3
<1 <1 X
7.40 10.2 7.30
12.2 43.4 X
ggjzow -ooT
< 0 . 2 0 <1.75 0.56 (SAr- ER DUAPEb
n R.ESERv�-�1 v E�
11
L
N MITH, SENIOR ANALYST
PHONE CALL SUMMARY
18 MAY 99
RE: NPDES Ammonia Sampling
Water System Improvements
Town of Belhaven, NC
Arcadis Project No. NC039341.0040
TYLER HIGHFILL spoke with MILBERT, Town maintenance
Phone: 252-943-3055
TWH called to inquire about the sampling procedure used to collect the 4/20/99 samples. Milbert
said he torched the sample spigot and let it flush about 5 minutes. He collected the samples one
right after the other. None of them overfilled, but Milbert told me that he dumped out the liquid
in one of the sample bottles. When he realized all the other bottles had liquid in them he did not
empty them out. He packaged them in the cooler and shipped them off.
?age:
9.%vwm139341-40tw_pWlbeR-phone.doc 1/1
"(DJ U N 0 7 1999 Analytical and Consulting Chemists
XFORD ARCADIS Geraghty & Miller 1316 South Fifth Street
Wilmington, N.C. 28401
aboratories DATE RECEIVED 0 5- 2 7- 9 9 (910) 763-9793
nc. DATE REPORTED 0 6 - 0 3 - 9 9 Fax (910) 343-9688
99W3052
PAGE 1 OF 1
ARCADIS GERAGHTY & MILLER P.O. # 01313
2301 REXWOODS DR./SUITE 200
RALEIGH, NC 27607
ATTENTION: TYLER HIGHFILL
SAMPLE DESCRIPTION: 5 AMMONIA TOWN OF BELHAVEN
1. WELL 2 5-25-99 0840
2. WELL 2 5-25-99 0910
3. WELL 2 5-25-99 0940
4. WELL 2 5-25-99 1010
5. WELL 2 5-25-99 1040
Ammonia Nitrogen, as NH3-N, PPM
RESULTS
1 2 3 4 5
0.11 <0.10 <0.10 <0.10 <0.10
RCC-4%-e-��
KEN SMITH, SE OR ANALYST
. - TZ,*
A)lTR1 FIC&T1oN KrA�tGS _
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Ta
o- 41
�-
DITCH VELOCITY CALCULATOR
PROJECT NAME: BELHAVEN WTP NPDES PERMITTING
PROJECT NO.: NC039341.0040
NORMAL DEPTH PROCEDURE (Trapazoidal Channel):
Channel A:
Input
Output:
Manning's n:
0.022
Z(req):
0.2715 Z(av): 0.271119
Side Slope:
1 :1
Wet. Per (P):
2.25 ft
Peak Flow (0):
0.26 cis
Hyd Radius (R):
0.28 ft
Channel Slope (s):
0.0002
Depth of Flow (Y):
0.79 ft
B. Width (B):
0 ft
Flow Area (A)
0.63 sq. ft
Velocity (V):
0.41 fps
BY: T. Highfill
DATE: 10-May-99
Z(req)-Z(a 0.0003
Page 1
.va
ARCADIS
GERAGHTY&MILLER
SUBJECT:
JOB NO:
SAC Kw 0 P God
co m 146AJT 3
PACE
BY: DATE:
CHKD: DATE: SHEET
I . Q
ARCADIS
GERAGHTY&MILLER
PAGE
SUBJECT: BY: DATE:
CHKD: DATE: SHEET
JOB NO:
f3A CK or() P Fog
cot4t4evr 4
ol.-I
ARCADIS
GERAGHTY&MILLER
BY: Jr DATE: 3 /7.5 I-R,
CHKD: DATE:
Pl-ESELT PUMP TO pigTr-&O C9,CC4
-� �IDOOL,�'
6 pqc
PAA)TV6.0 Ctc.
FUMP a = zoo Cmin
'PUMP +kP = 15HP
e o sT EST.
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26,000
131 000
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PAGE
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ARCADIS
GERAGHTY&MILLER
SUBJECT:
JOB NO:
FST/)t4 c M Go5TS
BY: DATE:
CHKD: DATE:
PoweiC
C5�\lO) PfuJb�/O IL/DO��I��C bS�= 03Sv0/5✓
MAila r.
Pump t Cav rROL, : �`Z �¢D 0 r
'TOTAL O 1-1 = S-qoolvfl*�
PrcZsWT VAL�vE of -$5,900/� te o4/67Z, 20-res e6%
(s-'CION cl,-il) =-,057,300
-Fo7lrL
� t =19l DOO
boe;S NOT J4GW o 6 SpEGIAL,
MIN. VELOCITY, ETC-..
PAGE
SHEET
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To: Permits and Engineering Unit
Water Quality Section
Attn: Steven Pellei
Date: 02/19/99
SOC Priority Project: Yes
If "Yes", SOC No.
No _x
NPDES STAFF REPORT AND RECOMMENDATION
vo
k_
Town of Belhaven
--n
Nanofiltration Water Treatment Plant Reject Discharge
Permit No. NC0086584
N)
PART
I - GENERAL INFORMATION
-O
1.
Facility and Address: Town of Belhaven, Mr. Tim M. Johnson,
Town.
Manager,301 East Main Street, Belhaven, NC 27810
N_
2.
Date of Investigation:
3.
Report Prepared by: Al Hodge
4.
Contact Person and Telephone Number(s): Tim Johnson 252-493-3055
5.
Directions to Site: Beginning at the intersection US 264 & NC
92,
proceed east along US 264 for approximately 4,000 feet to a gravel
farm
path on the west side of the road, the proposed water treatment plant is
to be located approximately 2,000 feet down the path
E 32
S�
6.
Discharge Point(s); List for all discharge points:
Latitude: Longitude:
Attach USGS map extract and indicate treatment facility site and
discharge point on map.
USGS Quad Name: Pantego
7. Site size and expansion area consistent with application? Yes _ No
If "No", explain: No construction has been performed site size can not
be determined without survey markers and they have not been installed at
this stage
8. Topography (relationship to flood plain included): 5 foot MSL
9. Location of nearest dwelling: 2,000 ft.
10. Receiving stream or affected surface waters: UT to Pantego Creek
a. Classification: SC -NSW
b. River Basin and Sub -basin No.: 03-03-07
C. Describe receiving stream features and pertinent downstream uses:
Proposed discharge is to a zero flow stream which leads to Pantego
Creek. Pantego Creek is use for full body contact, fishing,
boating, drainage, and fish propagation
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be Permitted: 220,000 gpd
b. Current Permitted Capacity: New Project
C. Description of proposed wastewater treatment facilities: No
treatment proposed
d. Possible toxic impacts to surface waters: Fluoride WQ standard 1.8
mg/1 with projected concentrations as high as 2.1 mg/l has been
shown to have toxic affects at other Nanofiltration filtration
reject discharges
2. Residuals Handling and Utilization Disposal Scheme: No residual program
proposed
3. Treatment Plant Classification (attach completed rating sheet): No
treatment system proposed
4. SIC Code(s):
Wastewater Code(s):
Main Treatment Unit Code:
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are
any public monies involved (municipals only)?Funding source is not part
of the submitted information. Given the nature of the project I do not
believe Construction Grants & Loans has funded any portion of the
project
2. Special monitoring or limitations (including toxicity) requests:
Toxicity testing is recommended with the present point of discharge(zero
flow stream). Fluorides, TOC, Ammonia as NH4, BOD5, chloride, iron,
turbidy
3. Alternatives Analysis Evaluation: Has the facility evaluated all of the
non -discharge options available? Provide Regional perspective for each
option evaluated. I have not seen an AAE. However, an AAE will not find
a less expensive alternative to discharge. Agricultural fields surround
the proposed treatment plant and I believe it appropriate to explore the
possibility of using this water for irrigation when possible.
PART IV - EVALUATION AND RECOMMENDATIONS: I am requesting additional
information by which to evaluate this application.
1) I have concerns regarding a BOD from this discharge. It has come to
my attention that the source water is high in Total Organic Carbon(TOC).
The concentrations are potentially high with the reject water being
concentrated four times the source water. I requesting the applicant
address this through testing.
2) I also have concerns with an oxygen uptake exerted from the NH4 in
the discharge. The oxidation occurs at a ratio of 1.502 to NH4. The
oxidation process requires the autotrophic organism Nitrosomonas that
occurs naturally.
3) It appears the Roper Ditch; the drainage structures name at Pantego
Creek is partially plugged at the mouth. I have concluded this because
of the water level in the ditch year round.
�1
Signature'of ort prepare
//_
Wat r qualitRe—gional Supervisor
zI L2(41
Date
NPDES Permit Staff Report
Belhwtpl
2-19-99
ENGINEERING ALTERNATIVES ANALYSIS FOR THE
REJECT STREAM FROM A MEMBRANE WTP
TOWN OF BELHAVEN.) NC
ARCADIS PROJECT NO. NC039341.0040
February 18,1999
The following is a discussion of alternatives reviewed for disposal of the membrane water treatment plant
reject stream. The projected maximum monthly reject flow rate based on the water plant operating at 70%
recovery is 216,000 gpd.
Disposal to POTW:
The local wastewater treatment plant (WWTP) is owned by the Town of Belhaven. The current expansion
to a permitted capacity of 1 MGD is expected to be completed prior to start-up of the water treatment plant
(WTP). Directing the reject stream to the WWTP would consume 22% of it's new capacity. The WTP
reject stream will not have BOD or ammonia loading or fecal content; therefore, directing the stream to the
WWTP will take-up hydraulic capacity without adding food to the treatment system. The WTP reject
volume was not included as anticipated flow to the WWTP so it would need to be expanded again if this
were the Town's only option.
A copy of the letter from the Town Manager stating the unacceptability of directing this flow to the WWTP
is attached.
Disposal to Privately Owned Treatment Works:
There are no privately owned treatment works in the vicinity capable of handling this volume of reject water.
Subsurface Systems:
The high water table and peat soils make subsurface disposal of this quantity of water impossible.
Land Application:
The entire Town limits are within the 100-year flood plain. The fields surrounding the proposed WTP are
approximately 6' above mean sea level. The Belhaven 201 Facilities Plan Update by Cavanaugh &
Associates, P.A. evaluated land application of the WWTP effluent as an alternate to expanding their
permitted discharge capacity. The plan update concluded that the typical depth to groundwater is 1 to 3 feet
below grade which does not suit either rapid or slow rate infiltration methods.
Since the soils near the WTP site are similar to that reviewed for the WWTP, land application of the WTP
reject was evaluated to be an unacceptable disposal alternative and was eliminated from consideration for
this project.
Page 2
Receiving Bodies:
The Town of Belhaven is located along the Pantego
�rek SC -NSW} near it's junction with the Pungo
River SB-NS —
Discharge to the P._ungo_Rfiver would require a 3000 gallon storage tank, two 20 hp transfer pumps,
approximately 2.5 miles of 6" force main, and associated pipeline easements. The present value of this
alternative is estimated at $599,000. A breakdown ,of the estimated capital and O&M costs are attached.
Due to the high cost of dishcharge to the Pungo River it is not an economically viable alternative.
In addition the Pungo River is a higher quality water body than Pantego Creek.
SELECTED ALTERNATIVE: The natural over -land flow at the WTP is toward Pantego Creek. The
agricultural fields that surround the site are drained with a system of ditches that are wet year-round. We
propose directing the reject stream to a primary field ditch that directs water to the Pantego Creek. The
proposed discharge point is shown on the attached map.
Page:
g.•1wwm139341.4ftng1wtp-gftngaltsanal.doc 2/2
Tobin of
f lapar
i9r. cryarled ®. popette
&Inn Manager
CiatOL .Tatnaan
Zahn Clerk
!Marie Y. AEam9. CAC
Mr. Charles Weaver
NCDENR
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Cmbatlbte IB9a
February 22, 1999
Re: NPDES Permit Application No. NCO086584
WTP Project Disposal to POTW ....
Town of Belhaven, Beaufort County
Dear Mr. Goodrich:
;oinn �CouuctT
dearpe R cbran, Yr.. filapar,VraZem
Walt Allen
Albert 52alur
cpntbia 0. I¢eath
Yames AL 300bge9
We have reviewed the possibility of directing the reject water steam produced by the new
membrane water treatment plant (WTP) to our wastewater treatment plant (W WTP). The
estimated reject flow of 216,000 gpd would consume approximately 22% of our permitted
wastewater treatment plant capacity following the expansion currently underway.
The Updated 201 Facilities plan for the W WTP allotted a future flow of 46,000 gallons per day
for residential, commercial, and industrial growth. Directing the WTP reject stream to the
W WTP would consume all of this reserve capacity prohibiting future growth. There are no
service lines in the area for sewer even if we had the capacity.
If we were to direct this flow to our W WTP we would be forced to expand our plant again which
would impose an unnecessary additional financial burden on our rate -payers. Since there is an
alternative feasible method to handle the reject water steam by direct discharge, we believe that
it is unacceptable to accept the reject stream at the W WTP facility.
Sincerely,
�%a-le
tm M Ia on
Tow�anager
xc: Tyler Highfill, Arcadis Geraghty & Miller
Ed Warren, Washington Regi7 $j _ r 999
a7 I�
Voot Office fax 220, �Pelliaben,,florth Carolina 27810 • (252) 943-3055 0 9f'ax (252) 943-2357
ARCADIS
GERAGHTY&MILLER
R.ESECT PoMP Ss'"Oo
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ARCADIS
GERAGHTY&MILLER
PAGE
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AGM Form 30 3.98 ��
Project Narrative November 12,1998
NPDES Permit Application
Nanofiltration Water Treatment Plant
Town of Belhaven, Beaufort County
Description of Plant Discharge Flow Rates
The Town's source of water will be from three groundwater wells. Upon each plant start-up, the
well(s) to be used will be blown -off to the point discharge pipe for a period of approximately 5-15
minutes at a projected rate of up to 500 gpm to clear the turbidity generally suspended during well
start-up. Once the turbidity drops to an acceptable level, the raw water will be directed to the
nanofiltration membrane treatment process, and a constant flow of reject water at a rate up to 150 gpm
will be produced and released to the point of discharge. The remaining 350 gpm will become potable
water.
Projection of Permeate Concentrations
The concentration of various reject (waste water) components depends on many variables and
assumptions made during design and plant construction. These factors and a discussion of their
importance are listed below:
Variable Discussion
Raw water quality Raw water quality has been established from the existing wells and
from a test well that has been installed and monitored. These wells
will give results on the current water available. The water is not
expected to vary appreciably, since the existing wells indicate the
performance of the aquifer over time, but the results may vary
slightly. A 10% water quality degradation has been assumed for the
purpose of this evaluation, and is added at the end of the calculation
as an increase in concentration (see Table I).
Recovery Recovery is the percentage of permeate (treated) water produced. It
is calculated by dividing the quantity of permeate water produced by
the quantity of raw water fed. -
The percentage of recovery selected will affect the concentration of
the constituents in the reject stream by virtue of having a variable
amount of water in which the ions are dissolved. The point at which
an ionic combination reaches saturation in the concentrate and
begins to precipitate on the membrane usually determines the rate of
recovery.
In this case the limiting compound appears to be Silica Dioxide
(SiO2) which will limit the recovery to about 75%. Calculations
have also been run at 75 % plus or minus 5% recovery to determine
Nanoftltration Water Treatment Plant
Town of Belhaven, Beaufort County
ARCADIS Geraghty & Miller Project No. NC039341.0040.00001
November lZ 1998
. rp
worst case scenarios for reject flow rate and reject constituents.
pH adjustment The adjustment of raw water pH may affect the concentrate makeup
in two ways. The pH will affect the carbon dioxide balance of the
water, thus increasing or decreasing alkalinity. In addition, the
chemical added to adjust the pH will increase the quantity of ions in
the feed water and reject water.
A decision has been made to use sulfuric acid as a means of pH
adjustment of the raw water to prevent bicarbonate fouling of the
membranes. A feed rate of 37 mg/L is assumed to reduce the pH to
7.0 in the feed water.
Anti-foulant Agents Often the performance of a membrane system can be enhanced by
adding chemicals to the raw water to prevent scaling and
precipitation of particles in the membrane element. These chemicals
must be NSF approved and are usually proprietary in nature. The
calculations assume that none of these chemicals are added. Since
these chemicals are added in small concentrations, the resulting
reject concentrate is not expected to be significantly affected.
Membrane Selection Membrane characteristics are dependent on the membrane
manufacturer. The membranes will be of the nanofiltration type. Of
particular importance is the rejection rate of each ion by the
membrane. Since the membrane works by repulsion of electrostatic
charges, the valance of the ion is important in determining the rate of
rejection of the ion (i.e. monovalent ions are rejected to a lesser
extent than divalent ions).
Given that the membranes will not actually be determined until after
the bidding process, a range of rejection values must be used to
estimate reject concentrations. It has been assumed that monovalent
ions are rejected at a rate of 55% to 75% and divalent ions at a rate
of 75% to 90%. Trivalent ions are assumed to be removed at 95% to
99%. These values are based on preliminary computer model runs
Membrane Train Different configurations of membrane elements within the
Configuration membrane train will make some difference in the rejection of
specific ions.
The differences between membrane configurations are considered
negligible within the range of concentrate projections for this project.
A two -stage train is be assumed with six elements per vessel.
Concentrate Post Post -treatment of the concentrate is not provided; therefore, the
Treatment projections are based on reject discharged directly from the
membrane train.
Nanofllftation Water Treatment Plant
Town of Belhaven, Beaufort County
ARCADIS Geraghty & Miller Project No. NC039341.0040.00001
November 1 Z 1998
Projections of concentrate water
Variables (see narrative)
- Membrane Used
- Recovery
• Source Water Concentrations
Salt Passage:
Monovalent 55%
75%
Divalent 75°%
90%
Trivalent 90%
100°%
Quadevalent 100%
1004/a
Ionic Constituents:
TABLE 1
It has been assumed that monovalent ions are rejected at a rate of 55°% to 75% and divalent ions at a rate of 75% to 90%. These values are based
on preliminary computer model runs.
In this case the limiting compound appears to be Silica Dioxide (SiO2) which will limit the recovery to about 75%. Concentration calculations have
been run at 80% recovery to determine a worst case scenario for concentrate if it is seen that the recovery can be safely attained.
A 10% water quality degradation has been assumed for the purpose of this evaluation, and is added at the end of the calculation as an increase in
Component
Source Water
Concentration
Min
Max
Absolute
Charge
(Note 1)
Comments
Membrane
Rejection
Minimim
Membrane
Rejection
(maximum)
Reject
Concentration @
80°% Recovery
(Minimum)
Reject
Concentration
80% Recovery
(Maximim)
max. KeJect
Concentration
with 10% Raw
Water
Degradation
Aluminum
ppm 1
0.1
0.1
0.1
3
90%
100%
0.450
0.500
0.550
Ammonia
ppm as NH4
0.8
0.8
0.8
1
55%
75%
2.200
3.000
3.300
Antimony
m
< 0.003
0
0.003
1
As antimonite Sb OH 4
55%
75°%
0.000
0.011
0.012
Arsenic
m
< 0.01
0
0.01
3
As Arsonate AsO4
90°%
100%
0.000
0.050
0.055
Barium
m
0.17
0.17
0.17
2
75%
90%
0.638
0.765
0.842
Beryllium
ppm
< 0.002
0
0.002
2
75°%
90%
0.000
0.009
0.010
Bromide
ppm
< 0.5
0
0.5
1
55%
75%
0.000
1.875
2.063
Cadmium
ppm
< 0.001
0
0.001
2
75%
90%
0.000
0.005
0.005
Calcium
ppm
70 - 88
70
80
2
75%
90°%
263
360
396
Chloride
ppm
12 -17
12
17
1
55%
75°%
33.0
63.8
70.1
Chromium
ppm
< 0.005
0
0.005
3
90%
100°%
0.000
0.025
0.028
Copper
ppm
< 0.01
0
0.01
2
75°%
90%
0.000
0.045
0.050
Cyanide
ppm
< 0.005
0
0.015
1
55°%
75°%
0.000
0.056
0.062
Fluoride
ppm
0.30 - 0.52
0.3
.0.52
1
55°%
75%
0.825
1.950
2.145
Iron
ppm
0.12
0.12
-0.12
2
Reduced
75%
90°%
0.450
0.540
0.594
Lead
ppm
< 0.005
0
0.005
2
75%
90°%
0.00
0.023
0.025
Magnesium
ppm
17.4 -18.7
17.4
18.7
2
75°%
90°%
65.3
84.2
92.6
Manganese
pprn
< 0.01
0
1 0.01
2
75°%
90°%
0.00
0.045
0.050
Mercury
m
< 0.0002
0
0.0002
1
55°%
76 %
0.00
0.001
0.001
Nickel
ppm
< 0.010
0
0.01
1
55%
75°%
0.00
0.038
0.041
Nitrate
ppm
< 0.1
0
0.01
2
75%
90°%
0.00
0.045
0.050
Nitrite
ppm
< 0.02
0
0.02
1
55°%
75°%
0.00
0.075
c 0.083
Phosphorus
ppm
< 0.1
0
0.1
3
As PO4
90%
100%
0.00
0.500
'0.550
Potassium
m
10.8 -13.0
10.8
13
1
55%
75%
29.7
48.8
53.6
Selenium
ppm
< 0.01
0
0.01
2
76 %
90°%
0.00
0.045
0.050
Silica Dioxide
ppm
48.7 - 54.3
48.7
54.3
4
As Silicate SiO4
100°%
100°%
244
272
299
Sliver
m
< 0.05
0
0.05
1
55%75%
0.00
0.188
C0.2
Sodium
ppm
54-70
54
70
1
55°%
75°%
149
263
289
Strontium
ppm
0.94
0.94
0.94
2
75°%
90°%
3.53
4.23
4.65
Sulfate
ppm
< 5.0
0
5
2
75°%
90%1
0.00
22.5
24.8
Thallium
1pprn
I < 0.001
0
0.001
1 1
55°%
75%1
0.001
0.0041
0.004
Zinc
m
0.026
0.026
0.026
2
75°%
90%
0.098
0.117
0.129
pH Projections:
Raw Water = 7.3 - 7.4
Reject Water = 5.8 - 8.0
Note 1: The charge is based on the commonly disolved ionic form, which may be a complex ion.
............................................................ .......................
........ ... .... . .........................................................................
N = 2.400
I .....................................................
LEGEND
UT TO FAIJTECO
NEW DIRT ROAD
NEW GRAVEL
AREA
CLEAR STUMPS FROM
IW
15 CY CLASS A RIPROP
ANCHOR WITH 0.5 Cr OF
3000 PS CONCRETE AT,.
EX. DnCH, 30 LT. EACH
SIDE OF PIPE OUTILET
....... ........
. . ... ........... ............ .... . ........ ................. ............. . ..
............................. ..............
1090 . ....
...............................
..............
...................... .... - ------------ ------
.... ....... ,
................
................ ....
........... ...... -----
. . .
. ... ........... ......
....... . . .
—FIRE"kRANT ASSEMBLY.
SEE 9/W6q�
I I
RUIJL All"
I SEE 1/%40l
:
CHEMICAL CONTAINMENT VAULT NO.
SEE I/WISO3
SEE W301
FILL EX. DITCH
........... x .......
TEPORCHECK)
DAN. E 2=
IS
15 CY CLASS A
RIP -RAP
IS
IS
TEMPORARY CHECK
P 0.AM. SEE 2/W202
...........
NOTE 2
SEE 1/W501 FOR ENLARGED
PPNG THIS AREA
BFV-2
.... .... ....... .. ...... ....................
A.
21
s
TV 28
22
L ........... ... ... ......... ... .
Im
10 ----- SEE IJWICAL CHEMCONTAINMENT VAULT NO.
603
.,.4..r; .... ........... ... ......
\\-FILL EX DfrCH
SEWAGE HOLDING TANK:
SIGN PER NC STATE
SEE 5/W202
kYARQ POST HYDRANT BULDVINC CODE R7-6 SEE 9/W602 ON CALV STEEL POST
GENERATOR AND GENERATORR
PAO BY OWNER
4' . 4- PRECAST FINISHED
WATER METER VAULT W/ ABOVE
GROUND LOCAL DISPLAY PROVIDE
W1 24-0 MANHOLE RIN6 & COVER
INISH WATER
SEE SHEET WSOI INFILTRATION DrTCH
BOTTOM OF EXISTO;G%;�/-
(APPROX. 78' DEEP W/ 2:1 ( -
SIDE SLOPES)
I�� I N
........... ------ ........... ............... .......
. ............................................... .................... N ..................
PLAN - WATER TREATMENT PLANT SITE
W202
GLASS B
STONE
;3
WIDTH OF STOW M
AS REQUIRED
76
f-1-8-1
CLASS 6 STONE
157 WASHED STORE
SECTION
TEMPORARY CHECK DAM
W202 NO SCALE
L " L SEE PLAN 2,-r
YAK UK
fem 7/=2/Fr rFINISH GRADE_
V COMPACTED MISH AND RUN
(-T1 GRAVEL -PARKING AREA.-
W202 NO SCAM
". L SEE PLAN 2'-6'
MIR. Mk /-FIN& MADE
S' COMPACTED SAND OR MAEL
1�1 DIRT ACCESS ROAD
W202 NO SCALE
•-------------------
I I
NQTM,
24' Ikk PING i
I. VAULT AND ALL ACCESSORIES SKI BE
AND COVER -61111
LOADING DESIGN.
7 AN0-FLOTATION
DESIGN VAULT LTTI-FLOTAnON COLLAR(S)
AND THICKENED SLAB TO PREVENT FLOTATION
WHEN TANK 15 EMPTY AND SIR FLOODS TO
ACCESS COVER.
N. , PANEL W1 RED ALARM LIGHT FOR
NIGH LEVEL ALARM. MOUNT ON 2' aALY. POLE
L- - - -
— - - - - - - - - — - -
PLAN
11' Ilk R.1 1, COVER
FINISHED GRADE
/-
'--GRADE PING
SS
4' SEAU-7--
FROM
FLOAT
BUILDING
FLOTATION
COLLAR(S)
6"
SECTION
0. 4' sm 12'
SEWAGE HOLDING
TANK
SCALE IN FEET
W202
a 2V w
SCALE IN FEET
copyright @ 1998
-4m I. ELEVATIONS SHOWN ARE MEAN SEA LEVEL REFERENCE.
2. INSTALL SP-01 D1A8OVE LINE 17 FROM THE
BUILDING TO CONTOUR 7.0,. TERMINATE ABOVE ME
WITH BRONZE CHECK VALVE AND 5 C.F. OF MASS A
RIP -RAP.
J. INSTALL VERTICAL BENDS AS REQUIRED IN YARD PIPING
TO MAIN IN MINIMUM REn COVER
a 11/4/N REGULATORY AGENCY RENEW
KMTH
ID/22/98 PREJUUINARI OWNER REVIEW
CL. DATE REVISION DESCRIPTION
Water
Treatment System
Improvements
Town of Belhaven, NC
WATER TREATMENT PLANT SITE
GRADING, PIPING, AND
EROSION CONTROL PLAN
0
ARCADIS
GERAGHTY&MILLER
2301 R I D6m Pori OHT. B. J13M
11069h. Ndh Ck. 27622-13H
TM: 919/782-5511 F= 219/782-5905
LMgnard _
F. Durso
LEAD DESIGN PROF.
CHECKED
T. Wighrill
L Hi�hfill
DRAWN
DATE
K. Me5de
may 12. 1998
1.00401 W202
02/18/99 15:54 FAX 919 782 5905 ARCADIS Geraslity Miller
10001/001
ARCADIS GERAGHTY&MILLER
TELEFAX
To: Carvo,
Al Hodge Steve Pellei @ 733-0719
DWQ Washington
y„
Data.
252-975-3716
18 February 1999
From:
Total pages:
Tyler W. Highfill
I
Extension;
Du, ref.:
138
NCO39341.0040
Subjets:
Belhaven NPDBS Application No. NCO086584
fil
0 you do not receive all pages. please all to let us know as soon as 00511)111.
Following our conversation earlier today on the Belhaven Membrane Reject:
ARCADIS Geraghty A Miller. Inc.
7301 Rexwoods Drive
Suite 200
Raleigh
North Carolina 27607-3366
Tel 919 782 5511
Fax 919 782 5905
WATER AND WASTE
MANAGEMENT
Total Organic Carbon concentration projection (consistent calculations with that shown in Table 1
attached to permit application)
Source Membrane
Concentration Rejection
10-16 ppm 90-100 %
Max. Reject Cone.
Reject w/10% Source
Concentration Degradation
50-80 ppm 88 ppm
THIS MESSAGE 19 INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT 15 ADDRESSED AND MAY CONTAIN
INFORMATION THAT 15 PRIVILEGED, CONFIDENTIAL. AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW -
If the reader of tnls message Is not the (mended redplcm, or the employer or event responslblo for dellvering the nsessage to the
Intended recipient you are hereby notified that any dissemination,
distribution,
or copying
o telephone hone ni rein ithestrictly
lnas
Prohibited. If you have received this communication in error, p ty y by P 9
message to us at the above addross via the U.S. pastel service.
Eoiin of
IBlapor
;Br. 4CljarlrA O. 30opette
Tobin Alanager
Tim A. 310hnoon
Tohtn Clerk
Marie 3. 2bams, CAC
C¢W6lfobrb 1899
February 22, 1999
Tobin council
George it Cbron, _Tr., Aspor Vro-Zem
3alt agen
MbertJBaker
epnthin JR. *eath
grameo JB. *02eg
Mr. Charles Weaver D
NCDENR _n
m
Post Office Box 29535 °'
Raleigh, North Carolina 27626-0535 W
Re: NPDES Permit Application No. NCO086584
ry
WTP Project Disposal to POTW
w
Town of Belhaven, Beaufort County M1'
Dear Mr. Goodrich:
We have reviewed the possibility of directing the reject water steam produced by the new
membrane water treatment plant (WTP) to our wastewater treatment plant (WWTP). The
estimated reject flow of 216,000 gpd would consume approximately 22% of our permitted
wastewater treatment plant capacity following the expansion currently underway.
The Updated 201 Facilities plan for the WWTP allotted a future flow of 46,000 gallons per day
for residential, commercial, and industrial growth. Directing the WTP reject stream to the
WWTP would consume all of this reserve capacity prohibiting future growth. There are no
service lines in the area for sewer even if we had the capacity.
If we were to direct this flow to our WWTP we would be forced to expand our plant again which
would impose an unnecessary additional financial burden on our rate -payers. Since there is an
alternative feasible method to handle the reject water steam by direct discharge, we believe that
it is unacceptable to accept the reject stream at the WWTP facility.
Sincerely,
im M son
T ana er
g
xc: Tyler Highfill, Arcadis Geraghty & Miller
Ed Warren, Washington Regio 'To _ 1999
ee&kmruq� a4L 100a eat
Voot Office 38ox 220, 36el�aben, Aortlj Carolina 27810 0 (252) 943-3055 • fax (252) 943-2357
ARCADIS GERAGHTY& MILLER
Mr. Charles Weaver
NPDES Unit
North Carolina Department of Environment and
Natural Resources
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Subject:
NPDES Permit Number NCO086584
Town of Belhaven, Beaufort County
ARCADIS Geraghty & Miller Project Number NC039341.0040
Dear Mr. Weaver:
In response to Steve Pellei's letter dated February 4, 1999, requesting additional
documentation on the subject project, please find enclosed our review of alternate
disposal options including a USGS map with discharge location marked and a letter
statement from the local wastewater treatment plant official.
Please let us know if you need additional information.
Sincerely,
(ARCCADIS Geraghty & Miller Inc.
er W. Highfi ,
/ps
Enclosures
Copies:
Tim Johnson
John Maynard
ARCADIS Geraghty & Miller, Inc
2301 Remoods Drive
Suite 200
Raleigh
North Carolina 27607-3366
Tel 919 782 5511
Fax 919 782 5905
WATER AND WASTE
MANAGEMENT
Raleigh, NC,
19 February 1999
Contact:
Tyler Mghfill
Extension:
138
C'l
Our ref.:
NC039341.0040/sp-let. doc. doc
k!
State of North Carolina
' r Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
W'J
A946
• •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 4, 19W `i
Mr. Tim M. Johnson
Town Manager
Town of Belhaven
301 East Main Street
Belhaven, North Carolina 27810
Subject: NPDES Permit Application
Permit No. NCO086584
Town of Belhaven
Beauford County
Dear Mr. Johnson:
The Division acknowledges receipt of your NPDES permit application and a check for $400.00 (#004823).
The permit number highlighted above has been assigned to the subject facility. A review of the submitted
material indicates additional information is needed.
Please submit documentation addressing the following items:
A USGS map with the location marked. The application contained a map with the location of the proposed
P, owever the location o e proposed discharge was not marked. Please indicate the point of
discharge on a USGS map.
Statement from the local WWTP. Please include a statement regarding the acceptability of this wastewater
at tYe-ro-cal wastewater treatment plant.
As the Division proceeds with a more detailed review of the application, additional information may be
required. At this time, by copy of this letter, the Division is requesting that our Washington Regional
Office Water Quality Supervisor prepare a Staff Report containing recommendations regarding this
discharge. The Division will forward any additional information to the Region upon receipt.
This application has been assigned to me for review. If you have any questions regarding this permit, or if
I can be of any further assistance, please do not hesitate to contact me at (919) 733-5083, extension 516.
Please submit the additional information by February 26, 1999. If the required information is not received
by this date, the Division will have no alternative but to return this application as incomplete.
Sincerely,
sr�44T?_ealm
Steven Pellei
cc: Washington Regional Office/Water Quality Section (with attachment)
NPDES Unit/Steve Pellei
Central Files
Tyler Highfill, ARCADIS
2301 Rexwoods Dr., Suite 200
Raleigh, NC 27607
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone (919) 733-5083 FAX (919) 733-0719
Ii M56$6q
# 00913
-yQ,1. cp
ARCADIS GERAGHTY&MILLER
ARCADIS Geraghty 6 Miller, Inc
2301 Remoods Drive
Suite 200
Mr. Dave Goodrich
Raleigh
North Carolina Department of Environment
North Carolina 27607-3366
and Natural Resources
Tel 919 782 5511
Post Office Box 29535
Fax 919 782 5905
Raleigh, North Carolina 27626-0535
WATER AND WASTE
MANAGEMENT
Subject:
NPDES Permit Application
Nanofiltration Water Treatment Plant Reject Discharge
Town of Belhaven, Beaufort County
ARCADIS Geraghty & Miller Project Number 39341.0040
Raleigh, NC,
12 November 1998
Dear Mr. Goodrich:
Contact:
On behalf of the Town of Belhaven we are sending you herewith three copies of the Tyler Highfill
Short Form C, project narrative, scaled site plan, and USGS map for the subject
project.
The new water treatment plant will have an estimated reject discharge of 300,000 gpd. Extension:
A detailed description of the projected waste characteristics and the treatment process 138
are included in the attached project narrative.
We will be pleased to meet with you to discuss this application in person if you would
like; otherwise, call us if you have any questions.
Sincerely,
C
iller, Inc.
W. Hi 11, .E.
fps -
Enclosures
Copies: —� -
J. Maynard
cn -
0
Our ref.:
NC039341.0040idg-let.doc