NC0002071_Draft Fact Sheet_20231122

DEQ/DWR/NPDES
FACT SHEET
NPDES PERMIT RENEWAL
Pamlico Packing Company, Inc. - Permit NC0O02O71
Joe R. Corporon, P.G.
16Nov2023
Table 1 Facility Information
Applicant/Facility Name:
Pamlico Packing Company, Inc.
Applicant Address:
P.O. Box 308 Vandemere, North Carolina 28587
Facility Address:
28 North First, Vandemere, North Carolina 28537
Permitted Flow
Not limited
Type of Waste:
discharge from seafood packing and processing
WW Code Prim. 25; Second.30, Treatment Unit Code 0000
Facility/Permit Status:
Class: WPCS - PCNC, minor /Renewal
County:
Pamlico Count
Miscellaneous
Drainage Basin
Neuse River
Receiving Stream:
Bay River
Regional Office:
Washington
Stream Classification:
SC; Sw; NSW
State Grid /
USGS TooQuad:
G32NW /
Vandemere, NC
303 d Listed?
No
Permit Writer:
Joe R. Corporon, P.G.
Subbasin:
03-04-13
Date:
16Nov2023
Drainage Area mil :
<5 s . mi.
Summer 7Q 10 cfs
Tidal
Winter 7Q10 (cfs):
Tidal
30 2 cfs
Tidal
Average Flow cfs :
Tidal
IWC (%):
N/A
Primary SIC Code:
2092
Application to Renew — The Permittee's application received DWR, tardy by 6 months (22May2023),
makes no estimates of future production. The previous application (2017) states that the site has been
dormant in "the recent past," with "expectations to resume processing in the near future." BIMS
monitoring database shows no record of discharge from this facility since 2015.
FACILITY DESCRIPTION
Permit Renewal. This facility was first permitted in 1980. The most recent permit became
effective February 1, 2014, expiring on May 31, 2018. The Division has received appropriate
documentation to renew on 22May2023. Pamlico Packing wishes to maintain the permit for
continued intermittent use. Therefore, renewal has considered the seafood production estimated
on the renewal application (December 5, 2017). Current DMR records report no discharge from
this facility since August 2016. This facility is registered for eDMR.
Fact Sheet - Permit Renewal — DRAFT Revised 16Nov2023
NPDES NC0002071
Page 1 of 8

Permitting History and Facility Description. Pamlico Packing sits on the north-western shore
of the Bay River where local topography is flat and low-lying (— 0.5 feet above MSL). When
active, the Permittee operates a five -to -six -day per week seafood packing and processing facility
that utilizes both year-round and seasonal processes. Considering all waste streams, total
discharge flow when active averages between 3,000 and 4,000 gallons per day (gpd) via five (5)
outfalls. A previous WaRO Staff Report noted that each of five (5) outfalls discharges from the
same loading dock where all wasteflow discharges within a lateral distance of 10-meters.
A note will be added to the draft cover letter to the effect that, "Based on the renewal application
(received 22May2023), each permitted outfall use will be updated as follows:
Outfall 001 -- ice box discharge (non -process wastewater) General Permit conditions
Outfall 002 -- fish processing (bottom fish) per 40CFR 408.212(b), Subpart U.
Outfall 003 -- shrimp processing per 40CFR 408.122(b), Subpart L,
Outfall 004 -- crab processing per 40CFR 408.22(b), Subpart B.
Outfall 005 -- boiler blowdown (non -process wastewater) General Permit conditions."
Production History —Past peak production (daily -seasonal) for a minor, Class I treatment
facility, has reached 6,000 lbs/day (shrimp), 6,000 lbs/day (fish), and 800 lbs/day (crab), during
summer months. Pamlico removes solids by physical screening through containers called "drain
buckets," disposing solids to trash -bens for off -site landfill disposal. This facility discharges to
the Neuse River estuary and, due to its minor flow rates, is not a member of the Lower Neuse
River Basin Association.
Waste Load Allocation (WLA). The Division prepared the last Waste Load Allocation in 1991.
Effluent limits were based on Guidelines (pH on saltwater guidelines). The Division views this
allocation appropriate for renewal except as noted herein.
Verification of Receiving Stream Conditions. The Division verified discharge to the Bay River,
located within sub -basin 03-04-13 [stream segment 27-150-(1)]. This waterbody has been classified
SC; Sw; NSW where both lunar and wind tides influence stream flow. This waterbody is not listed
as an "impaired" on the Division's 303 (d) list. This facility discharges upstream in proximity, but
not within, a waterbody classified High Quality Waters (SA, HQW; NSW), see map.
PERMIT LIMITS — HISTORY AND APPROACH (2019 - 2023)
Seafood Production. Current BIMS databases show no discharge, and Pamlico Packing's
application to renew provides no estimated seafood production (see DMRs for Outfalls 002, 003
and 004). 40 CFR monitoring for Outfalls 001 (ice -box drainage) and Outfall 005 (boiler
blowdown) are permitted as non -product -contact discharges requiring only Flow, pH, and
Temperature.
The Division used past production data to compare technology -based effluent limits (TBEL) vs.
water -quality based effluent limits (WQBELs) in accord with 40 CFR.408. In December 2017,
the Permittee estimated gross production weights for fish (Table 2), shrimp (Table 3), and
crab (Table 4), as required under §40CFR .408, for respective Subparts U, L and B.
Renewal assigned WQBELs as best professional judgement (BPJ) for Total Suspended Solids
(TSS) and Oil and Grease (O&G) as the protective, and thereby updated permit limits [for
rationale, see tables and CONCLUSIONS].
Fact Sheet - Permit Renewal — DRAFT Revised 16Nov2023
NPDES NC0002071
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Table 2. Fish Processing Subpart U - Parameter Limit Calculations
Outfall 002
40 CFR.408.212 (b)
Renewal Production
Renewal Limits
Renewal Limits
BPT (lbs./1000 lbs.)
(gross weight)
(TBELs in lbs./day)
(WQBELs in mg/L)
For
For
Maximum
Average of Daily
Daily
Monthly
Daily
Monthly
Parameter
Daily
Monthly
Production
Values for 30
Max
Average
Max
Average
Max
Average
Day
Days
TSS
3.6
2.0
18,000 lbs.
1,000 lbs./ day
64.8
2.0
45
30
Oil & Grease
1.0
0.55
18,000 lbs.
1000 lbs./ day
18
0.55
20
15
pH
6.0-9.0
6.0-9.0
-
6.0-9.0
6.0-9.0
6.0-9.0
TBELs TSS: 3.6x 18=64.8/2.0x 1 =2.0
TBELs O&G: 1 x 18 = 18 / 0.55 x 1 = 0.55
WQBELs for TSS = 45 mg/L DM & 30 mg/L MA
WQBELs for O&G = 20 mg/L DM & 15 mg/L MA
Table 3. Shrimp Processing Subpart L - Parameter Limit Calculations
Outfall 003
40 CFR.408.122 (b)
Renewal Production
Renewal Limits
Renewal Limits
BPT (lbs./1000 lbs.)
(gross weight)
(TBELs in lbs./day)
(WQBELs in mg/L)
For
For
Maximum
Average of
Daily
Monthly
Daily
Monthly
Parameter
Daily
Monthly
Production
Daily Values
Max
Average
Max
Average
Max
Average
Day
for 30 Days
TSS
110
38
10,000 lbs.
1,300 lbs./ day
1,100
49.4
45
30
Oil & Grease
36
12
10,000 lbs.
1,300 lbs./ day
3,600
15.6
20
15
H
6.0-9.0
6.0-9.0
-
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
TBELs TSS: 110 x 10 =1,100 / 38 x 1.3 = 49.4
TBELs O&G: 36 x 10 = 3,600 / 12 x 1.3 =15.6
WQBELs for TSS = 45 mg/L DM & 30 mg/L MA
WQBELs for O&G = 20 mg/L DM & 15 mg/L MA
Table 4. Crab Processing Subpart B - Parameter Limit Calculations
Outfall 004
40 CFR.408.22 (b)
Renewal Production
Renewal Limits
Renewal Limits
BPT (lbs./1000 lbs.)
(gross weight)
(TBELs in lbs./day)
(WQBELs in mg/L)
For
For
Maximum
Average of Daily
Daily
Monthly
Daily
Monthly
Parameter
Daily
Monthly
Production
Values for 30
Max
Average
Max
Average
Max
Average
Day
Days
TSS
2.2
0.7
8,000 lbs.
2,400 lbs./ day
17.6
1.68
45
30
Oil & Grease
0.6
0.2
8,000 lbs.
2,400 lbs./ day
4.8
0.48
20
15
pH
6.0-9.0
6.0-9.0
-
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
TBELs TSS: 2.2x8=17.6/0.7x2.4=1.68
TBELs O&G:0.6x8=4.8/0.2x2.4=0.48
WQBELs for TSS = 45 mg/L DM & 30 mg/L MA
WQBELs for O&G = 20 mg/L DM & 15 mg/L MA
CONCLUSIONS: In contrast to the previous draft, DWR feels that WQBELs better protect
Surface Water Quality. It is our best professional judgement (BPJ) that new limits for
production outfalls better protect the environment while continuing to maintain the Permittee's
ease of monitoring, reporting, and lab analyses, [see permit tables for Outfalls 002, 003, and
004].
Fact Sheet - Permit Renewal - DRAFT Revised 16Nov2023
NPDES NC0002071
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Compliance History
BIMS databases show no limit violations - monitoring violations only [Jan202O-Jun2O23].
FACILITY
MONTH
YEAR
VIOL DATE
VIOL TYPE
ACTION
UPDATED
Pamlico Packing
1
2021
03/03/2021
Late/Missing DMR
NOD
pauLmays
Pamlico Packing
2
2020
03/31/2020
Late/Missing DMR
NOV
pauLmays
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Revised Draft Permit to Public Notice:
Permit Issue [estimated]:
Effective Date[estimated]:
NPDES DIVISION CONTACT
November 20, 2023
December 221 2023
February 1, 2024
If you have questions about any of the above information, or on the attached permit, please email
Joe R. Corporon,.Z.G. [e-mail]].
NAME:
109DIN
DATE: 16Nov2023
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as
approved.
Table 2. NC Dissolved Metals Water Oualitv Standards/Aouatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW, µg/l
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Fact Sheet - Permit Renewal — DRAFT Revised 16Nov2023
NPDES NC0002071
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Table 2 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculatiol = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
213.0200 (e.g., arsenic at 10 µg/l for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 3. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A NCAC
02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, 1
Cadmium, Acute
WER*{1.136672-[In hardness] (0.041838){
3.1485{
e^10.9151 [ln hardness]-
Cadmium, Acute Trout
waters
WER* { 1.136672-[ln hardness] (0.041838){
3.62361
e^{0.9151 [ln hardness] -
Cadmium, Chronic
WER*{1.141672-[ln hardness] (0.041838){
4.4451 {
e^{0.7998[1n hardness]-
Chromium III, Acute
WER*0.316 e^{0.8190[ln hardness]+3.7256{
Chromium III, Chronic
WER*0.860 e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 e^{0.9422[1n hardness]-1.700}
Copper, Chronic
WER*0.960 eA f 0.8545[ln hardness]-1.7021
Lead, Acute
WER*{1.46203-[In hardness] (0.145712){
1.460}
eAl1.273[ln hardness]-
Lead, Chronic
WER*{1.46203-[In hardness] (0.145712)}
4.705 )
e^{l.273[ln hardness]-
Nickel, Acute
WER*0.998 e^{0.8460[ln hardness]+2.255)
Nickel, Chronic
WER*0.997 e^{0.8460[ln hardness]+0.0584{
Silver, Acute
WER*0.85 • e^{l.72[ln hardness]-6.59{
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 eA f 0.8473[1n hardness]+0.8841
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Fact Sheet - Permit Renewal - DRAFT Revised 16Nov2023
NPDES NC0002071
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Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) x (s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1 Q 10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
Fact Sheet - Permit Renewal — DRAFT Revised 16Nov2023
NPDES NC0002071
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In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q 10 + Qw) (Cwgs)-(s7Q 10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q 10 may be incorporated as applicable:
IQ 10 = used in the equation to protect aquatic life from acute toxicity
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and chromium
VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
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10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Table 4
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
N/A
No metals monitored
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
N/A
7Q 10 summer (cfs)
N/A
1 Q 10 (cfs)
N/A
Permitted Flow (MGD)
N/A
Fact Sheet - Permit Renewal — DRAFT Revised 16Nov2023
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