NC0025348_Staff Comments_20140724

Rodriguez, Teresa
From: Templeton, Mike
Sent: Thursday, July 24, 2014 12:14 PM
To: Moore, Tom; Hennessy, John; Belnick, Tom
Cc: Poupart, Jeff; Kinney, Maureen; Rodriguez, Teresa; Manuel, Vanessa
Subject: RE: Town of New Bern
Tom M —
Re: your last sentence: It is not practical to combine the limits for internal outfalls 002 and 003 at the final outfall 001.
Those limits are based on different requirements that apply specifically to discharges from the WWTP and from the
WTP, respectively; and the wide variability of each discharge makes it impossible to calculate limits forthe combined
flows. The only parameter that we can limit at 001 is the toxicity of the combined discharges.
If it turns out that the two discharges are, in fact, separate, the issue goes away but is replaced by the question of how
to measure toxicity of two discharges going to the same point in the river.
I'm pretty sure this isn't the only permit that sets limits at internal outfalls. We need the capability to track compliance
at internal outfalls, not just at final outfalls. (Vanessa was going to see if BIMS already has that capability.)
Tom B —
Another question come up when Vanessa and I discussed this yesterday: When the City is diverting 100% of its WWTP
effluent to the quarry (no discharge to surface waters), which parameters should they have monitor at 002? And which
limits still apply? They need to monitor nutrients and flow, of course; but is there a need to monitor and meet limits for
BOD, TSS, ammonia? For metals? Etc.? It's possible the City will divert all flow to the quarry for months at a time
(they've already shown they can), so we need to consider whether those limits and monitoring costs are necessary.
— Mike T
From: Moore, Tom
Sent: Thursday, July 24, 2014 9:41 AM
To: Hennessy, John; Belnick, Tom
Cc: Templeton, Mike; Poupart, Jeff; Kinney, Maureen; Rodriguez, Teresa; Manuel, Vanessa
Subject: RE: Town of New Bern
Tom/John,
This was prompted by questions regarding how to report in eDMR when flow was diverted from the effluent for reuse
under their non -discharge permit. As we discussed the issue further, it appeared there are some possible issues with
how the outfalls are set up in BIMS as well as in the permit. They expressed frustration with how they have been
instructed to report information on the DMR even though there was no discharge from the effluent.
After looking at the outfalls in BIMS, it does not look like the outfalls reflect the actual operation as described by Ms.
King. Additionally, the main Outfall 001 as reflected in BIMS only has 3 parameters (Flow, PPA Scan and Toxicity) that
are reported as the main discharge to the receiving stream. All other Outfalls are designated as internal outfalls. The
main Outfall 001 should reflect more parameters than 3 if the 002 (WWTP effluent) and 002 (WTP effluent) are truly
combined and discharged via Outfall 001.
Tom
Thomas F. Moore
Business and Technology Application Analyst

Division of Water Resources / Information Technology Branch
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone: [phone]
E-mail correspondence to and from this address may be subject to lire Nortli Carolina Public Records Law and may be
disclosed to third parties.
From: Manuel, Vanessa
Sent: Thursday, July 24, 2014 9:09 AM
To: Hennessy, John; Belnick, Tom
Cc: Templeton, Mike; Poupart, Jeff; Kinney, Maureen; Rodriguez, Teresa; Moore, Tom
Subject: Town of New Bern
John & Tom B.,
After speaking with Tom Moore about the Town of New Bern's permit (NC0025348) and how they are currently
reporting their DMR data, I thought it best to bring certain concerns to the permitting and compliance groups for
resolution, if any is warranted. The following are issues that might require further review and conversations with the
Town and regional office.
1. It appears the facility is reporting parameter data on days they are indicating no flow (see examples below). This
seems contrary ... if no flow is reported on a particular day, then how can the facility collect a sample for that
day? The Town indicated their reporting is based on instructions received from Division staff.
a. May 2014 DMR: outfall 003, no flow on the 6th and 13th but pH results submitted;
b. July 2013 DMR: outfall 002, Waiver (no flow) recorded for flow all days, but analytical results provided
for the other required parameters.
2. The facility has effluent requirements associated with outfall 001, which is the only outfall that is uploaded to
ICIS, but it appears when the Town diverts flow to the quarry (outfall 005), they are not submitting a DMR for
outfall 001... there is no outfall 001 data in BIMS. At a minimum, they should submit the 001 DMR and indicate
No Flow/Discharge for the month. This information would then get uploaded to ICIS with the appropriate no
discharge code and ICIS would not generate any missing data or missing DMR violations.
3. Lastly, Cheryl King (252/639-7559) with the Town indicated to Tom Moore that they do not have a true
combined outfall as indicated in the permit. She indicated that both outfall pipes (002 and 003) discharge
directly to the receiving stream (one on top of the other) and the effluent discharge from each actually combine
into the receiving water. I'm not sure about the validity of her statement... it seems this would have been
noticed by staff during inspections and would have been captured by engineer drawings and plans. But, I
thought it should be brought to staff's attention for further review.
If you have any questions or feel a meeting is needed to help clarify, let me know. Mike and Tom M., if I missed any
pertinent points or failed to capture key information, let me know.
DWR
Mviston of Water Resources
Vanessa E. Manuel, Environmental Senior Specialist
NCDENR / Division of Water Resources / Water Quality Permitting Section
Wastewater Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6392 (wk); 919/807-6489 (fax)

23L
E-mail correspondence to and from this address pray be subject to the North Carolina Public Records law and may be disclosed to third partigs "--
3 8'44
P%A*
r 11-1r,
�, .f--41
001
00
�y�zalt�• �' moneh , /�j�
00/

�n
Aldermen
SEW BERN
Dallas O. Blackiston
Victor J. Taylor
Patricia C. Schaible NORTH C A R O L I N A
Johnnie Ray Kinsey 300 Pollock Street, P.O. Box 1129
Bernard W. White
Jeffrey T. Odham New Bern, NC 28563-1129
[phone]
June 27, 2014
Mr. Tom Belnick
NC Division of Water Resources
NPDES Complex Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: City of New Bern
Water Reclamation Facility Nitrogen Credit Methodology
Permit No. NCO025348
Mr. Belnick,
Dana E. Outlaw
Mayor
Mark A. Stephens
Interim City Manager
Veronica E. Mattocks
City Clerk
Keith M. Fiaschetti
Director of Finance
In accordance with the City of New Bern's NPDES permit effective December 1,
2013 (NC0025348), please find below the conceptual framework for the proposed subsurface
nitrogen load estimate methodology. This methodology was discussed during a meeting with
representatives of Aquifer Protection Section and Surface Water Protection Section on March
14, 2014 in the Washington Regional Office of DWR.
The City will continue to monitor water levels and sample water quality in the lake
and monitoring wells, as well as sample for nitrogen and other constituents in the effluent
being pumped to the lake. The City will also continue annual algae surveys for the lakes.
This sampling and monitoring will be in accordance the requirements of the NPDES and the
Reclaimed Water/Conjunctive Utilization (WQ0017635) permits.
In order to provide a reasonable estimate of the subsurface total nitrogen loading to
the Neuse River, we will work with a hydrogeologist to develop a suitable groundwater flow
model to estimate flow out of the lake and into the Neuse River, based upon known
subsurface data and past studies on transmissivity of the aquifer. This model, along with
monitored water levels in the lake and surrounding lakes, creeks and wells, should provide a
reasonable indication of subsurface flow for use in a transport model. The transport model
will utilize inputs for nitrogen concentration and effluent flow into the lake to determine mass
loading for a given year, assuming effluent is being pumped to the lake 365 days a year at
maximum concentration. Nitrogen utilization within the quarry and along the river bottom
sediments will be accounted for in the model based on utilization rates from existing,
documented research of these processes. This model will then be utilized to predict the time

Mr. Tom Belnick
Page 2 of 2
required_ for nitrogen concentrations to reach the Neuse River, under the projected loading.
We will compare this projected annual loading with the actual annual nitrogen loading, and
make adjustments in the credits requested during each permit renewal, as well as updating the
model. We will continually research ways to improve the transport model, as well as
methods to predict/determine nitrogen uptake in the lake and bottom sediment.
We hope this methodology is acceptable to the Division. Should you have any
questions or wish to discuss this request further, please contact our office at your earliest
convenience.
Respectfully,
Jordan B. Hughes, P.E.
City Engineer
Cc: Jay Zimmerman — DWQ - Section Chief — Aquifer Protection Section
David May — DWQ — Regional Supervisor — Aquifer Protection Section
Matt Matthews — DWQ — Section Chief — Surface Water Protection Section
Mike Templeton — DWQ — Surface, Water Protection Section
Jon Risgaard — DWQ — Aquifer Protection Section
Blaine Humphrey, P.E. — Rivers &.Assoc.
Judy Majstoravich — City of New Bern