HomeMy WebLinkAboutNC0083551_Permit Issuance_20120503r w� Sri
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
May 3, 2012
Mr. Matthew Hypes, P.E.
Onslow Water & Sewer Authority
P. O. Box 1.415
Jacksonville, NC 28540
Subject: Issuance of NPDES Permit NCO083551
Onslow Water & Sewer Authority -- Dixon WTP
Onslow County
Dear Mr. Hypes:
Dee Freeman
Secretary
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES 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 October 15, 2007 (or as
subsequently amended).
The Division has reviewed the comments regarding the draft, provided on your behalf by Ms. Erica V.T.
Carter, P.E. of Kimley-Horn and Associates, Inc. The following responses are offered to those
comments:
• The North Carolina Administrative Code does not allow NPDES permits to be issued for a period
lasting longer than five years. Therefore, the permit cannot be made effective any earlier than July
1, 2012 and remain in a unified, basinwide permitting schedule. With a July 1, 2012 effective date,
the facility will maintain seamless permit coverage between the existing permit (which expires at
midnight on June 30, 2012) and this permit.
• The Division cannot restrict its authority to reopen NPDES permits to be based only upon the results
of effluent testing. Should other sources of monitoring indicate the facility is yielding a detrimental
impact on the receiving stream, the Division reserves its right to modify the permit based upon those
findings, in order that conditions may be mitigated and resolved.
• The permit is being reissued with the test organism for Whole Effluent Toxicity testing remaining as
mysidopsis hahia (Mysid Shrimp). Discussions regarding any potential change in the test organism
for toxicity testing should be initiated with our Aquatic Toxicology Unit. Questions may be
addressed to Ms. Carol Hollenkamp at (919) 743-8950, or via e-mail at
carol.hollenkamp@ncdenr.gov.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
Location: 512 N. Salisbury St Raleigh, North Carolina 27604 NO Carolina
Phone: 919-807-63001 FAX: 919-807-6492 f�
Internet www.ncwaterquality.org t�'tlilrq`ll� J
An Equal Opportunity 1 Affirmative Action Employer
Mr. Matthew Hypes, P.E.
ONWASA - Dixon WTP Permit Renewal 2012
p. 2
Therefore, this final permit includes no significant changes from the draft permit sent to ONWASA on
March 14, 2012. Although this final permit does not differ in its terms from those in the draft, it
contains a number of terms that differ from those found in the .existing permit. Those changes include:
• The monitoring requirement for flow measurement has been changed from weekly, instantaneous
sampling to continuous, recording measurement. This requirement will not become applicable until
January 1, 2014 (eighteen months after the effective date of the permit), in order to allow you time to
budget for, plan and install a suitable flow measurement device.
• Monitoring of the effluent for Total Arsenic and Turbidity have been added to the permit.
• Monitoring for Total Residual Chlorine and Ammonia Nitrogen have been removed from the permit
because they are not introduced into the facility's wastewater flow.
• Monitoring frequencies for Copper, Lead, Fluoride, Total Nitrogen and Total Phosphorous have
been reduced from monthly to quarterly.
• The footnote regarding a choice in the selection of a Whole Effluent Toxicity test organism has been
removed. Within the permit, the designated test organism is Mysidopsis Bahia (mysid shrimp).
• Because the facility has experienced whole effluent toxicity testing failures during the current permit
cycle, a condition has been added that will allow the Division to reopen the permit to add limits for
whole effluent toxicity or to direct the facility to undertake actions that will both determine the
causes and eliminate the potential for aquatic toxicity as a result of the discharge.
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 (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless
such demand is made, this decision shall be final and binding.
Please note that Stones Creek is listed as an impaired waterbody on the North Carolina 303(d) Impaired
Waters List. Addressing impaired waters is a high priority with the Division, and instream data will
continue to be evaluated. If there is noncompliance with permitted effluent limits' and stream
impairment can be attributed to your facility, then mitigative measures may be required.
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.
Mr. Matthew Hypes, P.E.
ONWASA - Dixon WTP Permit Renewal 2012
p. 3
If you have any questions concerning this permit, please contact Bob Sledge at telephone number (919)
807-6398, or via e-mail at bob.sledge@ncdenr.gov.
S' ,
Cherarles Wakild, P.E.
cc: Central Files
Wilmington Regional Office/Surface Water Protection Section
NPDES File
Aquatic Toxicology Unit
DWR—Public Water Supply Section
Permit NCO083551
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Onslow Water and Sewer Authority
is hereby authorized to discharge wastewater from a facility located at the
Dixon WTP
6661 Wilmington Highway (US Highway 17)
South of Dixon
Onslow County
to receiving waters designated as an unnamed tributary to Stones Creek in the White Oak River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, H, III and IV hereof.
This permit shall become effective July 1, 2012.
This permit and authorization to discharge shall expire at midnight on June 30, 2017.
Signed this day May 3, 2012.
les Wakild, P.E., Director
ivision of Water Quality
By Authority of the Environmental Management Commission
Permit NC0083551 '*
7
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Onslow Water and Sewer Authority
is hereby authorized to:
1. Continue to discharge green sand filter and ion exchange backwash from a water treatment facility,
with three settling basins for wastewater treatment.
The facility is located at the Dixon WTP, 6661 US Highway 17, south of Dixon, in Onslow
County.
2. After construction of new water treatment facilities, discharge reverse osmosis reject wastewater
through the existing wastewater treatment apparatus and outfall;
I. Discharge from said treatment works at the location specified on the attached map into an unnamed
tributary to Stones Creek, classified SA-HQW, PNA waters in the White Oak River Basin.
Permit NCO083551
x
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ONWASA— Dixon WTP Facility
Location -'
Latitude: 34035U7" Stream Class: SA-HQW, PNA
Longitude:77'27'46" Subbasin:030502
Quad# 129SW NPDES Permit NCO0835551
Receiving Stream: UT to Stones Creek
Permit N00083551
7
PeK
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
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Flow (50050)
Weekly
Instantaneous
Effluent
Flow (50050)
Continuous2
Recording
Effluent
Temperature (00010)
Monthly
Grab
Effluent, Upstream,and
Downstream
Salinity (00480)
Monthly
Grab
Effluent, Upstream,
and Downstream
Conductivity (00094)
Monthly
Grab
Effluent, Upstream,
and Downstream
pH' (00400)
2/Month
Grab
Effluent, Upstream,
and Downstream
Dissolved Oxygen (00300)
Monthly
Grab
Effluent, Upstream,
and Downstream
Total Dissolved Solids 70295
Monthly
Grab
Effluent
Total Suspended Solids 00530
10.0 m L
15.0 m /L
2/Month
Grab
Effluent
Turbidity 00070
Monthly
Grab
Effluent
Total Arsenic 01002
Monthly
Grab
Effluent
Total Copper 01042
Quarterly
Composite
Effluent
Total Chloride 00940
Monthly
Composite
Effluent
Total Iron 01045
Monthly
Composite
Effluent
Total Manganese 01055
Monthly
Composite
Effluent
Total Lead 01051
Quarterly
Composite
Effluent
Total Zinc 01092
Monthly
Composite
Effluent
-Fluoride 00951
Quarterly
Composite
Effluent
Total Nitrogen 00600
Quarterly
Composite
Effluent
Total Phosphorus 00665
Quarterly
Composite
Effluent
Whole Effluent Toxicity Monitoring4
Quarterly
Composite
Effluent
GE3E
Footnotes:
1. Upstream = at least 100 feet upstream from the outfall; Downstream = at least 100 feet downstream from the outfall.
2. Continuous, recording monitoring requirement will become effective January 1, 2014 (18 months following the
effective date of the permit).
3. The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units.
4. Acute Toxicity 24-hour Pass/Fail Monitoring using Mysidopsis bahia (Mysid Shrimp) as the test organism. Testing to
be performed in January, April, July, and October. (see A. (2.) below).
All samples collected should be from a representative discharge event.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
14j ,1�
U �(
Permit NCO083551
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 Mysidopsis bahia 24-hour static test. The effluent concentration defined as treatment
two in the procedure document will be 90%. Effluent samples for self -monitoring purposes must be
obtained during representative effluent discharge below all waste treatment. The tests will be .
performed during the months of January, April, July and October.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGE3E. Additionally, DWQ Form AT-2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete 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 Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a valid test is submitted. Upon
submission of a valid test, this monthly test requirement will revert to quarterly in the months specified
above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.
Permit NC0083551 '-
A. (3.) PERMIT RE -OPENER: WHOLE EFFLUENT TOXICITY MONITORING
Whole Effluent Toxicity monitoring results indicating aquatic toxicity failure may result in the
Division of Water Quality re -opening this permit to add a limit for Whole Effluent Toxicity, or
requesting by letter that further action be taken to address toxicity failures. Mitigative actions include
additional testing and/or toxicity identification/reduction evaluations to determine the cause(s) of the
effluent toxicity and measures required to achieve passing effluent toxicity results.
FACT SHEET FOR EXPEDITED PERMIT RENEWALS
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns).
Basic Information for Expedited Permit Renewals
Permit Writer/Date
Bob Sledge 5/3/2012
Permit Number
NCO083551
Facility Name
Dixon WTP
Basin Name/Sub-basin number
White Oak 030502
Receiving Stream
UT to Stones Creek
Stream Classification in Permit
SA-H W-PNA
Does permit need Daily Max NH3 limits?
No
Does permit need TRC limits/language?
No. TRC monitoring removed — Cl added after
wastewater flow established
Does permit have toxicity testing?
Yes
Does permit have Special Conditions?
Toxicity Reo ener Added
Does permit have instream monitoring?
Yes
Is the stream impaired on 303 d list)?
Yes: Loss of Use — Shellfish harvesting prohibited
Any obvious compliance concerns?
Toxicity has been an issue. Expected to improve
with new treatment system added.
Any permit mods since lastpermit?
No
Current expiration date
June 30, 2012
New expiration date
June 30, 2017
Comments received on Draft Permit?
Comment from DMF re PNA
Comment from permittee addressed in cover letter
The Dixon WTP NPDES permit is being reissued with modifications to the terms of the existing
permit. The primary reason for changes to its terms is the introduction of a new, reverse osmosis water
treatment system at the facility. The move to RO has been necessitated by (primarily aesthetic) issues
associated with drinking water rules. Once constructed, upgraded WTP will use the RO system as the
primary producer of potable water. However, its green sand filter and ion exchange systems will
remain in operation, albeit at a reduced capacity. Water generated from those systems will be blended
with that from the RO system to produce a final product with adequate taste characteristics for
consumers. Pilot studies done on an RO product from the source water (wells) indicate concentrations
of pollutants in the wastewater will decrease when the new system comes online and use of the ion
exchange system is reduced.
The addition of the new system only required the additional monitoring of two parameters (Turbidity
and Arsenic) per application of the reverse osmosis provisions of the WTP permitting strategy. The
facility will be required to add a flow measurement device that will account for all volumes of
wastewater that are discharged. This condition will not become effective until January 1, 2014.
Other changes from the terms of the existing permit:
• Monitoring for Total Residual Chlorine and Ammonia Nitrogen were removed from the permit
because they are not introduced into the facility's wastewater flow. The facility does not use
chloramines for disinfection. The facility uses filtered, non -chlorinated water to backwash.
a
• Monitoring frequencies for Copper, Lead, Fluoride, Total Nitrogen and Total Phosphorous were
reduced from monthly to quarterly.
An RPA was initiated regarding the discharge. However, very few of the metals the facility has
collected data for actually have water quality standards associated with them. Data for copper
was all reported as less than the detection level, therefore the monitoring frequency was
reduced (even though RPA calculations would show potential to cause the 3 µg/L action level
to be exceeded). Zinc data also show potential for the action level to be exceeded in the stream,
but most recent data are much improved. The monthly monitoring requirement was retained.
• The footnote regarding a choice in the selection of a Whole Effluent Toxicity test organism was
removed. Based upon the facility's historical preference, the designated test organism is the mysid
shrimp.
• Because the facility has experienced whole effluent toxicity testing failures during the current
permit cycle, a condition was added that will allow the Division to reopen the permit to add limits
for whole effluent toxicity or to direct the facility to undertake actions that will both determine the
causes and eliminate the potential for aquatic toxicity as a result of the discharge.
Upstream and downstream data were reviewed. Downstream conductivity and salinity consistently
appear higher than upstream values. It's inconclusive whether this has been due to the discharge or if
stream conditions change as one moves closer to Stones Bay in the New River. Stones Creek has been
designated as a prohibited area for shellfish harvesting, and therefore is 303d listed. The actual reason
for the designation is based upon surveys conducted by the Shellfish Sanitation Section of DMF, which
has found their bacteriological standards to be exceeded in the stream for many years. Their staff had
very little concern regarding the discharge from this water treatment plant and its potential to impact
shellfish habitat.
The permittee provided comments regarding the draft, requesting:
The effective date be changed;
The text within the toxicity condition be changed, and
The toxicity test organism be changed.
Each of these requests were denied. Explanations were given to the consulting engineer on the phone
and are repeated in the cover letter. The engineer had no problem with the DWQ response.
The Division of Marine Fisheries provided one comment, noting the discharge was to Primary Nursery
Area waters. Follow up was made with DMF. They had no specific concerns regarding the permit;
they just wanted to be sure that conditions associated with PNA (HQW) waters were applied in permit
development (they were; there is little legitimate application of the standards for WTP discharges).
Sledge, Bob
From:
Jenkins, Shannon
Sent:
Thursday, May 03, 2012 10: 00 AM
To:
Sledge,' Bob
Subject:
Stone's Creek
Bob,
It appears that Stone's Creek first closed to shellfish harvest on 9/17/74. It.appears that it was due to high
bacteriological sampling results, likely related to a sewer discharge in Stone's Creek from _Dixon High School and
Elementary. It has remained closed since -that time.
Shannon Jenkins
NCDENR-DMF-Shellfish Sanitation and Recreational Water Quality Section
3441 Arendell St.
Morehead City, NC 28557
Phone: 252-726-6827
shannon.ienkins@ncdenr.eov
Email correspondence to and from this address is subject to the North Carolina Public Records law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
PROHIBITED TERRITORY
NEW RIVER AREA
Area C-3 (Map 40)
Designated A-1 Identifier
Shellfish
Harvesting Boundary
Areas • +
Prohibited Boundary
Areas ® Area
L
i
Locator Map
N
/' NA
---�`f/r- NC Statete Plane
0 05 1
Miles
(Prohibited areas are hatched)
COUNTY: ONSLOW
'�
Rhodes
Point
� 1 L
> �, •� / ,\� I,t_r-> ><��', Grey 't
� r ` S Point . }
// Garfish Hickory Pt
Stones Creek :.Point
HfAES �E'- �1 J
Point
� Z i , 1 Pollocks' V /�
1� Paint/ ' �[a
/ Ferry Jarretts
Paint Point Creels' h
Point «}s'
r J� Everett Creek
?A PovertyPt
Fulchet
anding
G
Map 40 (SEE BACK OF MAP FOR
AREA DESCRIPTIONS.)
NEW RIVER AREA PROHIBITED AREA ONSLOW COUNTY
Area C-3 (Map 40) (Prohibited Areas are Hatched)
(a) Everett Creek - All those waters of Everett Creek and it's tributaries upstream of a straight line
beginning at a point 340 34.2522' N -770 24.8557' W on the west shore; running easterly to a
point 340 34.2359' N -770 24.6818' W on the east shore.
(b) Stones Creek - All those waters of Stones Creek, Muddy Creek and other tributaries upstream
of a straight line beginning at a point 340 36.8738' N -770 26.5163' W on the north shore;
running southerly to a point 340 36.5330' N -770 26.6570 ' W on the south shore near Stones
Landing.
(c) New R_ - All those waters of New River upstream of a straight line beginning at a point 340
38.8205' N -770 22.6757' W on the west shore; running northeasterly near Channel Marker
#42 to a point 340 40.1177' N-771 21.4913'W on the east shore.
(d) Frenchs Creek / Duck Creek- All those waters bounded by a line beginning at a point 340
39.2161' N -770 20.8991' W on the shore north of Frenchs Creek; running southwesterly to a
point 340 39.0036' N -770 21.1486' W; running southerly to a point 340 37.7822' N -770
20.8079' W on the shore south of Duck Creek.
(e) Mill Creek - All those waters in Mill Creek upstream of a straight line across the mouth
beginning at a point 34 37.2371' N -77 25.7025' W on the west shore; running easterly to a
point 34 37.2383' N -77 25.6860' W on the east shore.
NC 2010 Integrated Report Categories 4 and 5 Impaired Waters
All113,123 Waters in NC are in Category 5303(d) List for Mercury due to statewide fish consumption advice for several fish species
AU —Number AU Name
AU_Description
LengthArea AU Units Classification
C neeory Parameter
kcasm for Raving
Ux (;vcgun Collection Year 3,031dbear
White Oak River Basin
New River Watershed 0302030202
Q 19-(11) New River
From Atlantic Coast Line Railroad Trestle to 574.3 S Acres SC;HQW,NS
Mumford Point
W
4b Chlorophylls
Standard Violation
Aquatic Life 2008 2008
5 Copper
Standard Violation
Aquatic Life 2008 2008
5 Enterrococcus
Standard Violation
Recreation 2008 2008
5 High pH
Standard Violation
Aquatic Life 2008 2008
Q. 19-(27)b New River
5 Shellfish Growing Area -Prohibited
Q 19-16-(3.5)a Northeast Creek
4b Chlorophyll a
Q 19-16-(3.5)b Northeast Creek
46 Chlorophylla
From Everett Bay to DEH closure line.
Loss of Use Shellfish Harvesting
From N. C. Hwy.24 to a line crossing
Northeast Creek downstream of NC 24.
Standard Violation Aquatic Life
From a line crossing Northeast Creek 1.8
miles downstream of NC 24 to downstream
side of mouth of Scales Creek
Standard Violation Aquatic Life
2.8 S Acres
SA;HQW
2006
2002
400.3 SAcres
SC;HQW,NS
W
2008
280.0 SAcres
SC;HQW,NS
W
2008
2002
QQ
19-17-(6.5) Southwest Creek
From Mill Run to New River
594.7 S Acres
C;HQW,NSW
4b Chlorophyll
Standard Violation Aquatic Life
2008
QQ
19-3Oa2 Stones Bay
Entire Bay except for the area enclosed by
23.9 S Acres
SA;HQW
the DEH closure at the mouth of Stones
Creek.
'.. 5 Shellfish Growing Area -Prohibited
Loss of Use Shellfish Harvesting
2006
2008 '..
(D
19-30b Stones Bay
From Stones Creek to DEH closure line.
32.6 S Acres
SA;HQW
5 Shellfish Growing Area -Prohibited
Loss of Use Shellfish Harvesting
2006
2002
Q
19-30-3 Stones Creek
From source to Stones Bay
76.9 S Acres
SA;HQW
5 Shellfish Growing Area -Prohibited
Loss of Use Shellfish Harvesting
2006
2002
White
Oak River Basin
New River Inlet Watershed 0302030203
Q
19-39-3a Alligator Bay
Bay south of ICW W
260.2 S Acres
SA;ORW
5 Shellfish Growing Area -Conditionally Appr
Loss of Use Shellfish Harvesting
2008
2002
Q.
19-39-3b1 Alligator Bay
Remainder of bay north of ICW W
22.1 S Acres
SA;ORW
5 Shellfish Growing Area -Conditionally Appr
Loss ofUse Shellfish Harvesting
2008
2002
Q
19-39-3b2 Alligator Bay
DEH closure area at mouth of Mill Creek.
8.4 S Acres
SA;ORW
5 Shellfish Growing Area -Prohibited
Loss of Use Shellfish Harvesting
2006
2002
NC 2010 integrated Report Category 4 and 5 303(d) List EPA Approved Aug 31, 201 9/20/2010 Page 123 of 145
❑�� NmleyHorn
and Associates, Inc.
April 26, 2012
Mr. Robert Sledge
Environmental Specialist
NCDENR DWQ
1601 Mail Service Center
Raleigh, NC 27699-1601
Re: NPDES Response Comments
ONWASA
Dear Bob:
■
501 Independence Parkway
Suite 300
Chesapeake, Va. 23320
On behalf of the Onslow Water and Sewer Authority (ONWASA), Kimley-Horn and Associates,
Inc. is pleased to offer the following comments on the NPDES Permit Renewal for the Dixon
Water Treatment Plant.
1. Request that the permit be effective no later than June 30, 2012. /✓r
2. Under A.(2.) add the red text to the tad to last paragraph to "Should any test data from this
monitoring requirement or tests performed by the North Carolina Division of Water Quality
on the data required on this permit on A.(1.) indicate potential impact to the receiving . I
stream, this permit may be re -opened and modified to include alternate monitoring e
requirements or limits."
3. We would like to discuss the potential change under A. (1.) Footnote 4 to read "Menidia
beryllina (Silverside Minnow)' as the test organism (rather than Mysidopsis bahia (Mysid
Shrimp)). Ida
Please feel free to contact me should you have any questions or comments at 919-247-7297
(cell) or edca.carter@kimley-horn.com, and thank you for your continued partnership on this
project.
Very Truly Yours,
e�K,;7L0
Erica V.T. Carter, P.E.
Vice President
Kimley-Hom and Associates, Inc.
cc: Matthew Hypes, PE, ONWASA
Karen Fergason, ONWASA
Karen Wallace, ONWASA
Sledge, Bob
From: Hardy, Jeanne
Sent: Wednesday, April 04, 2012 3:23 PM
To: Sledge, Bob
Subject: Comments on NPDES permit
Attachments: Jeanne J Hardy.vcf
Dixon WTP, Permit No. NCO083551: This facility discharges into PNA. If you have any questions,
please contact Jessi Baker at jessi.bakera-ncdenr.gov or at 252-808-8064.
Regards,
]eanne'. Hardy
Administrafte.:Asst.
NC.UMS[on 'of Marine Fisheries
Habitai;' Protedon Section
52M Hwy.:70 `lest
Morehead City. NC 28557
(254 86"066 Work
(2,�2j,727 5127;fax
3eanne:hardycderu,gov
Email correspondence to and from this address is subject to the North Carolina Public Records Low
and may be disclosed to third parties unless the content is exempt by statute or other regulation.
1
ONSLOW COUNTY
NORTH CAROLINA
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of County and Stale of said publisher, duly commissioned, qualified
and authorized by law to administer oaths, personally appeared
who being first duly sworn, deposes and says: that he (she) is
Jimmy Williams, Editor
(Owner, partner or other officer or employee authorized to make this affidavit)
of THE CARTERET PUBLISHING CO., INC., Carteret County, N.C., engaged in the publication of a nc
paper known as Tideland News, published, issued, and entered as second class mail in the Town of Swansb
in said County and State; that he (she) is authorized to make this affidavit and sworn statement; that the nc
or other legal advertisement, a true copy of which is attached hereto, was published in Tideland News on
following dates:
3/21/12
and that the said newspa
LEGAL NOTICES
PUBLIC NOTICE
NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT
COM ISSIONINPDES UNIT
1617 MAIL SERVICE
CENTER
RALEIGH, NC 27699-1617
NOTICE OF INTENT TO
I ISSUE A NPDES
WASTEWCSER PERMIT
in which such notice, paper, document, or legal advertisement was published was, at the time of each and eV The North Carolina Envi-
ronmental Management Com-
ublication, a newspaper meetin all of the requirements and qualifications of Section 1-597 of the Gen mission proposes to Issue e
such p$' q q fNPDES wastewater discharge
permit to the person(s) listed
Statues of North Carolina and was a qualified newspaper within the meaning of Section 1-597 of the Geni below
Statues of North Carolina.
This the 18th day of April 2012.
Vv vV
Signature of person making affic
Sworn to and subscribed before me, this 18th day of April
My commission expires August 24, 2014
2012.
Notary Publi
Written comments regard-
ing the proposed permit will be
accepted until 30 days after
the publish date of this notice.
The Director of the NC Divi-
sion of Water Quality (DWQ)
may hold a public hearing
should there be a significant
degree of public interest.
Please mall comments and/or
information requests to DWO
at the above address. Interest-
ed persons may visit the DWQ
at 512 N. Salisbury Street, Ra-
leigh, NC to review information
on file- Additional information
on NPDES permits and this
notice may be found on our
w e b s I t e
http://portal.ncdenr.orgAveb/w
q/swp/ps/npdes/calandar, or
by calling (919)807-6304.
Beacham Associates, Ltd.
has requested renewal of per-
mit NCO028223 for Beacham
Apartments #1 WWTP; On -
slow County. This permitted
facility discharges 0.04 MGD
treated wastewater to an un-
named tributary to Brinson
Creek; White Oak River Basin.
Onslow Water and Sewer
Authority requested renewal of
permit NCO083551 for the Dix-
on WTP in Onslow County;
this permitted discharge is
treated WTP process waste-
water to an unnamed tributary
to Stones Creek In the White
Oak River Basin. M21
ONWASA Dixon WTP REASONABLE POTENTIAL ANALYSIS Outfall 001
AC0083551 Qw = 0.29•MGD
Qw (MGD) = 0.29
WWTP/WTP Class: PC-1
1 Q I OS (cfs) = Tidal, IWC =100%
IWC @ 1 Q l OS = 100.00%
7QIOS (cfs) = Tidal, IWC =100%
IWC @ 7QIOS = 100.00%
7QIOW (cfs) = Tidal, IWC =100%
IWC @ 7Q10W = 100.00%
-30Q2 (cfs) = Tidal, IWC =100%
IWC @ 30Q2 = 100.00%
Avg. Stream Flow, QA (cfs) = Tidal, IWC =100%
IWC @ QA = 100.00%
Receiving Stream: UT to Stones Creek
Stream Class: SA, HQW, PNA
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS HOW OR ORW.
CHRONIC TEST CONCENTRATION = DEFAULT %
=90%
PARAMETER
STANDARDS S CRITERIA (2)
N
REASONABLE POTENTIAL RESULTS
TYPE
(1)
-�
a
�
NC WQS / Applied �/2 FAV /
Cl # Det. Max Pred Allowable Cw
Chronic Standard Acute
Cw
Acute: NO WQS
Arsenic
C
5 HH(Qavg)
ug/L
0 0
N/A
--- _ _ — --- —
Chronic: 5.0 -
- -- - - ---
Acute: 21.0
Cadmium
NC
2.5 SW(7Q10s) 21
ug/L
0 0
N/A
__ _—_—__ _ —
_—_—_—_—_—_ —_—_—_ —
_
Chronic: 2.5
----- --
Acute: NO WQS
Total Phenolic Compounds
NC
150 A(7Q10s)
10.0
ug/L
0 0
N/A
--------------------------
Acute: NO WQS
Chromium
NC
10 SW(30Q2)
ug/L
0 0
N/A
-
-- ---_ _—_ -----:—_
Chronic: 10
--- - -
Acute: 5.8
"A d AL(Cu,Zn,Ag: Ql) .apply Quarterly
Copper (AL)
NC
1.5 SW(7Q l Os) 5.8
ug/L
37 0
6.8
_ _ _ _ — _ — _ _ _ _ —
Montoringin conjunction' with TOX Test
Chronic: 1.5
36 value(s) > Allowable Cw
Acute: 0.5
Cyanide
NC
0.5 SW(7Q10s) 0.5
10.0
ug/L
0 0
N/A
_ _ - — -
_ _—_ — — _—_—___
----- — — ---
Chronic: 0.5
Acute: 110.5
Lead
NC
12.5 SW(7Q1Os) 110.5
ug/L
37 0
7.00
—_—__ __—
_ _ _ _—. ......
Chronic: 12.5
No value > Allowable Cw
Acute: NO WQS
Mercury
NC
12.5 SW)7Q1Os)
0.5
ng/L
0 0
N/A------13
Acute: NO WQS
Molybdenum
NC
1.0 HH(7Q I Os)
mg/L
0 0
N/A
-------------------------------
Acute: 37.5
Nickel
NC
4.15 SW(7QlOs) 37.5
ug/L
0 0
N/A
__—
_— - — -__—_—_—___ —_—
-----
Chronic: 4.2
Dixon WTP 2011 RPA-Saitwater,rpa•
Page 1 of 2 5/3/2012
ONWASA Dixon WTP REASONABLE POTENTIAL ANALYSIS Outfall 001
MCMA12-A-Al Ow = 0.29.MGD
Acute: NO WQS
Selenium
NC
35.5 SW(7Q1Os)
ug/L
0 0
N/A
__—
----------- --------------- +,
_—_—__
Chronic 35.5
Acute: 0.950
Silver (AL)
NC
0.05 SW(7Q1Os) 0.95
ug/L
0 0
N/A
_ _
__ __ ___—_—_—__
Chronic: 0.050
Acute: 48
TtP1s for.AL(Cu;Z0 jg Fe Cl) - remin monthly'
Zinc (AL)
NC
43 S W(7Q 1 Os) 48
ug/L
37 18
422.50
_ _ _ _ — _ — _ _ _ _ —
moriitonn_g
Chronic: 43
3 value(s) > Allowable Cw
Acute: NO WQS
Manganese
37 37
4.0
—_—_—_—_—
_--------------------------
No value > Allowable Cw
Acute: NO WQS
Iron
37 37
413.82
--------------------------
Chronic:---------
No value > Allowable Cw
Acute: NO WQS
Fluoride
0 0
N/A
-------------------------------------
Chronic:
Acute:
0 0
N/A
— — — ---- -- -------
_ _ _
Chronic ---------
—
Acute:
0 0
N/A
----------
- ----------------------- -
Chronic-
Acute:
0 0
N/A
— ------ ------------
_ _
Chronic----------
Acute:
0 0
N/A
---------
--- --- - -
_ _
Chronic:
---
Acute:
0 0
N/A
— — — —
_
Chronic:---------
- ----.-----------
Acute:
0 0
N/A
-- ---------------------
Chronic----------
—
Dixon WTP 2011 RPA-Seltwater,rpa
Page 2 of 2 5/3/2012
Whole Effluent Toxicity Testing Self -Monitoring Summary February 15, 2012
FACILfIY RBQUDtII.¢Nf
YEAR JAN
FEB,
MAR
APR
MAY
JUN
AM
AUG
SEP
OCF
NOV
DEC
Daniel Stave Rarealcal GardN Chu Monin 90%
Cmi]dPF
NO -
-
Fill
-
-
H
-
-
H
-
-
H
NCO088684/001 BeiurMQN$ Fmqucnry:Q Marlun Sep Dec
NonComp:
=9 -
-
Fel
-
-
Fel
-
-
PoI
-
-
Fa
County: Coupon Region: MO Subbases: C037
2010 --
-
FeA
-
-
Fal
-
-
FeA
-
-
Fel
PF: 0.0038 Slrcul
N11 _
-
F.Nam
-
-
Fall
-
-
Far
-
-
Fal
1QI0'. 0 MC(%) IN am:
012
Bare County-A1D3(go)W 241rfJfac.&W.mysid
Myad24PF
Nie Pan
-
-
Pose
-
-
Pau
-
-
Pow
-
-
NC001015T/N2 Begin 2 InM Freglmry: Q lm Apr Jul Oct
NonComp:
NN Pox
-
-
Fell
-
-
Far
-
-
Paw
-
-
Couny Due Region: WARD Subbann: PAS56
Not Peu
-
-
Pere
-
-
per
-
-
paw
-
-
PF:1.42 Slwul
Nil Pow
-
-
Poas
-
--
FN
-
-
Full
-
-
1QIO:Total MC(V.)NA Colo:
2012
Depiction Water Ins. WfP Cbr Monig 90p.
Cm7eF
NO
-
-
-
-
-
-
-
-
-
-
-
NCN84425=1 Begin IVIZZM Frequenry:Q Feb Mey Aug Nov
Noranti:
NN -
-
-
-
-
-
-
-
-
-
-
-
Cooper. Davidson Region: WSRO Subbaan: YADUC
2310 -
Pau
-
-
Invalid
-
-
Fen
-
-
Fell
-
PF:0.3 .,W
nil _
Fen
-
-
Fee
-
-
Fat
-
-
Fell
-
9QI0: MCC%) adm:
M12
Dwmn Inclinational Pmp-Albermarle vhrli.W.
Ceri]dPF
2N6 Pou
-
-
pats
-
-
pas.
-
-
Pare
-
-
NC0(emm7/NI Begin Wl/NDI Frequency:Q Jon Apr Jul Oct
+ NNCamp:Sm le
Not H
X
H
H
Fe1
04.81
31.82
70.37
94.87
Pau
-
-
Cnmry. Sourly Region: MRO Subb®n: YADOB
"In Fell
]Bag
>1N
one
-
H
Pow
-
-
Fel
-IN
-IN
PF: D.03 BISYI
N11 H
-
-
Pep
-
-
New
-
-
FY
>IN
-IN
7QI0: 0.0 IWC(%)IN Dnb:
M12
Drer Clue SOIHA.ian WW'1'P chr lion: Wit,@ 0.05 or 0.11 or 0.22 MOD C.67RF
NO Pon
-
-
Imsld
Fan
>10
PInw-l00
--
-
pass
-
-
NCN63T461NI Begin 6/1RN8 Frequenry:Q IN Apr Jul Oct
+ Non6inp:Single
Not Pose
-
-
Pa.c
-
-
pew
-
-
Pee.
-
-
Comy Wake Region: PRO Subbuin: NEU02
NIO Pau
-
-
Furl
58.1
-IN
Per.
-
-
pew
-
-
PIP: 005 spz61
nit pep
-
-
Pecs
-
-
Pau
-
-
From
-
-
1QI0:00 IWC(%)IN tadw:
N12
Mlm AOpertl dolien 12%
CUTdaV
2008 -
-
Me
-
-
15.6
-
-
15.6
-
-
15A
NCON6190/NI Begin 7/IR009 Frequonry:Q Mu lion SW Du
+ NonComp:Single
Nor -
-
16.5
-
-
15.6
-
-
15.5
-
-
16.07
Count'(2mwba Region. MRO Subbuin=35
N1O -
-
10.97
-
-
10.97
-
-
15,97
-
-
10.07
PF: Ll Spots
2011 _
-
m.91
-
-
18,97
-
-
1697
-
-
16.97
1QI0: 12 MC(%) I I order:
2012
Server du llm:9W.
Cn74PF
2N8 -
Paw
-
-
Fen
>1001P1
>Rm(Pl
Pere
-
-
peas
-
NCN266B9/N1 Repr IO/InN4 Frequnry:Q Feb May Aug Nov
+ NonComp:Single
NN -
Pan
-
-
Fei
94.9
-IN
".t(p).Pne -
-
Pase
-
COonyDevldwn Region: WSRO Subbuin: YADOS
N10 -
Pow
-
-
Pou
-
-
Pose
-
-
Fa
-IN
PF: 0.8 S,cr.l
2011 >100
Pau
-
-
Pou
-
-
Pore
-
-
vase
-
9QIO:0.0 IWC(aA)100 (Xdm:
2012
Denver GWR Chrunt W%
No T.
NO -
-
-
-
-
-
-
-
-
-
-
-
NCN89NI/001 Begin 41VNI1 Fngtmnry:Q Men lion Sep Dec
NonComp:
NO -
-
-
-
-
-
-
-
-
-
--
-
County: Cue"a Region: MO Subbuin:=32
2010 -
-
-
-
-
-
-
-
-
-
-
-
PF: 0.0115 swc61
2011 _
_
_
_
_
_
-
-
-
-
-
H
7010: IWC(%) G4c:
N12
Devils WondYard WTP a, Merit: 90%
flhd24PF-
NCN86N1N1 Begin Vi R011 Frequency:Q 1. Apr Jul Oct
NonComp:-
CoNy Wr,ym Region: WARO Subbuin: Cl
N10 -
-
-
-
-
-
-
-
-
-
-
-
PP e,w61
Nil _
_
_
-
-
-
-
-
-
H
-
-
TQIO: IWC(V.) C,m.
N12 H
Dial. Yarn., I.e. v1trlint 911%
CedTOPF
Nm H
-
-
H
-
-
H
-
-
H
-
-
NCNB3963/0I Be®n1/1R004 Frequenry:Q Jon Apr Jul Oct
+ NonComp:Single
=9 H
-
-
H
-
-
H
--
-
H
-
-
COonySunly Region: NRO Subbuin: YAD12
2010 H
-
-
-
-
-
-
-
-
H
-
-
PF:0On apx
Nil H
-
-
H
-
-
H
-
-
H
-
-
7QI0:0 MC(%) IN anger:
M12
Diva WTP-Onelow Weclr&sewer Aum AcP/FMNi1:W4Myed.Fghd,or RIvenide. Myrd24PF
200e Paw
-
-
Pew
-
-
Pan
-
-
Pep
-
-
NCN83551/NI Begin9/IYdN9 lemcmory:Q Jan Apr Jul Oct
NonComp:
2009 Fill
-
-
peas
-
-
Fe1
-
-
Pou
-
-
Couny Owl" Regius: WIRO Subbuin: WOK%
Will Fal
-
-
Fri
-
-
Fe1
-
-
Pou
-
-
PF: S,. imul
Nil Fel
-
-
Feel
-
-
Fell
-
-
one
-
-
'JQIO: MCC%) Crd^:
W12
LEGEND:
PERM=Pemul Requremont LEf-Admirdmadve Levu-Targm Frnpume,e Monitoring frequmry: Q-Quenedy; M. Monthly; BM- Bimmlthly; SA-Seommully; A- Annually;CIM,y whrn discharging,D- Discontinued monitoring mqubcmmt
Begi=Firnmonlhtequired TQIO-Receiving aaeam tow now ailerion(c@) Monthsthutminemgm oncur-a Ian, Apr, jw.(kt NonComp- Cumin Compliance Requirement
PF-Pomdned ROW(MGD) IWC%=Iuneamwame Nncentmion P/F=PareNail test AC=Acute CULL=Chmic
DrumNotation f-FattAha Kl w,,>.Ccdodaphtdasp.;my-My6dshdmp;ChV-Chronicvale;P-Monalityofmmedp nlagealhighest Nnmmmtim;at-Porfomedby DWQAquOc Toe Unit;bt-Badtest
grooving Notation--- Date not required; NR-Not reposed Facility Activity Stalu: I - lnacnvq N-Newly Issue I(To construct); 11 - Active but not discharging; t-Mom dam ovallable for month in quntion;=ORCsignaturencNed
17
Yetnber Governments
Holly Rulge
Jacksonville
North Topsail Beach
Onslow County
Richlands
Swmuhow
28-Nov-2011
NCDENR/DWQ
NPDES Unit
1617 Mail Service Center
Raleigh NC 27699-1617
0 NwAS
Onslow Water &Sewer Authority
In Re: Renewal and Modification of NPDES Permit NCO083551
Dixon Water Treatment Plant
Onslow County
Eneineering Division
James K (Rod) Butler. P.F.
F.ngineering Director
rburler@mwasa.com
Herewith, please find our NPDES Permit renewal package for our Dixon WTP, as above identified.
910,937.7521 Tel
910,455.5607 Fax
ONWASA has been attempting to move forward with its permitting and installation of reverse osmosis
(RO) treatment at the Dixon plant. The purpose for the is removal of trace organics, to assist in our
compliance with the Stage 2 Disinfection By -Product Rules, and silica, an aesthetic nuisance.
We have been informed that NCDENR/DWR/Public Water Supply Section will not permit the RO project
until such time as our NPDES Permit allows the inclusion of the RO Reject Water as part of our discharge
under the NPDES Permit.
We have been further advised by DWQ that due to the concurrent timeline of Permit Renewal and
Permit Modification that the two should be combined within our Permit Renewal application package,
which is what is exhibited in the enclosure.
The enclosure includes an abundance of analytical data on the reject water from a pilot RO system we
have been operating during the last 6-months, predictive models indicating what the quantity and
quality to be anticipated in the combined waste streams subsequent to the installation of the Ro system,
toxicant data, supporting our application.
Please give me a call or e-mail if you have any questions regarding the enclosed.
Sincerely,
1 mes R. Butler, PE
Engineering Director
228 Georgetown Road • P.O. Box 1415 • Jacksonville. NC 28540 • Tel 910.455.0722 • Fax 910.455.2587 • www.onwasa.com
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number CC 0083561
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Onslow Water & Sewer Authority
Facility Name
Dixon Water Treatment Plant
Mailing Address
228 Georgetown Rd
City
Jacksonville
State / Zip Code
NC/ 28540
Telephone Number
(910)455-0722
Fax Number
(910)455-0115
e-mail Address
rbutler@onwasa.com
2. Location of facility producing discharge:
Check here if same as
above ❑
Street Address or State Road 6661 Wilmington Hwy
City
Holly Ridge
State / Zip Code
NC/ 28445
County
Onslow
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name Onslow Water & Sewer Authority
Mailing Address 228 Georgetown Rd
City Jacksonville no
State / Zip Code NC/28540 D
Telephone Number (910)455-0722 NOV 28 2011
Fax Number (910)455-0115 ►,�,��oa ,.,,,
4. Ownership Status:
Federal ❑ State ❑ Private ❑ Public Z
5. Type of treatment plant:
Page 1 of 3 C-WTP 03/05
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
® Conventional (Includes coagulation, flocculation, and sedimentation, usually followed by
filtration and disinfection)
® Ion Exchange (Sodium Cycle Cationic ion exchange)
® Green Sand Filter (No sodium recharge)
® Membrane Technology (RO, nanofiltration)
Check here if the treatment process also uses a water softener
6. Description of source water(s) (i.e. groundwater, surface water)
Groundwater
7. Describe the treatment process(es) for the raw water:
Aeration -Potassium Permanganate -Contact Basin-Greensand Filtration for Iron &
Managanese-Ion Exchange for Calcium & Magnesium, Reverse Osmosis for trace organics
and silica removal -Chlorine Disenfection-Orthophosphate-Fluoridation
8. Describe the wastewater and the treatment process(es) for wastewater generated by the
facility:
Process waste from greensnad filters & Ion exchange softeners and reject from Reverse
Osmosis filtration. Discharged to a series of sedimentation lagoons, supernate discharge
to receiving stream.
9. Number of separate discharge points: 1
Outfall Identification number(s) 001
10. Frequency of discharge: Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs: 7 Duration: 12hrs
11. Plant design potable flowrate 4.0 MGD
Backwash or reject flow 1..0 MGD
12. Name of receiving stream(s) (Provide a map shouting the exact location of each outfall, including
latitude and longitude):
UT to Stones Creek
13. Please list all water treatment additives, including cleaning chemicals or disinfection
treatments, that have the potential to be discharged.
Page 2 of 3 C-WTP 03/05
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Potassium Permanganate
Hypochlorite
Hydroflourosilic acid
Household Cleaners
Descaling Agent
14. Is this facility located on Indian country? (check one)
Yes ❑ No
15. Additional Information:
> Provide a schematic of flow through the facility, include flow volumes at all points in
the treatment process, and point of addition of chemicals.
Solids Handling Plan
16. NEW Applicants
Information needed in addition to items 1-15:
> New applicants must contact a permit coordinator with the NCDENR Customer
Service Center.
Was the Customer Service Center contacted? ❑ Yes ❑ No
> Analyses of source water collected
> Engineering Alternative Analysis
> Discharges from Ion Exchange and Reverse Osmosis plants shall be evaluated using a
water quality model.
17. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
James R. Butler PE Engineering Director
Printed name of)'�rson Signing Title
Signature
z3
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 3 of 3 C-WTP 03/05
Dixon Water Treatment Plant Receiving Stream
6661 Wilmington Hwy
Holly Ridge, NC 28445
NPDES# NCO083551
915,000 Gallons 915,000 Gallons 915,000 Gallons
Primary
Secondary
1
Tertiary
Estimated 3
Estimateld 3
Days Detention
1
Estimated 3
Days Detention
Time
Days Detention
Time
Time
Influent
Pipe
No Chemical Addition
Max influent flow 1340gpm per greensand
filter backwash.
Effluent vault has 2 - 350gpm pumps.
2 Alternate influent points.
Pump Vault
Plant Waste Flow
Residual Management Plan
Dixon Water Treatment Plant
Effective February, 2006
A pump and haul method of removing solids from the three (3) lagoons
at Dixon will be utilized. Solids will be dewatered to pass the paint test
and transported by truck to the Onslow County Landfill. The lagoons
will be pumped every three (3) years so as not to allow solids
accumulation to interfere with detention time.
Member Govts.
Onslow County
Holly Ridge
Jacksonville
North Topsail Beach
Richlands
Swansboro
OSAS
Onslow Water & Sewer Authority
Email: kwallaced5onwasa.com
Website: www.onwasa.com
Office of the
Water Production Superintendent
Karen Wallace
ONWASA would like to formally request the Division of Water Quality reconsider including the
following parameters when issuing renewal NPDES Permit NCO083551, Dixon Water Treatment
Plant. Copper, Lead, Zinc, Ammonia Nitrogen, Total Phosphorus, Total Nitrogen.
The attached document supports data indicating these parameters are routinely testing at or less
than the level of detection for that method. Process at this Physical/Chemical I plant has not
changed to indicate by- products of biological treatment are present and source water treated at the
plant is absent of the metals currently being monitored in the waste product.
The attached data includes the last 22 months of monitoring results but more can be provided upon
DWQ's request.
228 Georgetown Road. • P.O. Box 1415 • Jacksonville, NC 28540 • Tel 910-455-0722 • Fax 910-347-0793
E
Dixon WTP NC 0083551
Ammonia
Total
Total
Copper
Zinc
Nitrogen
Phosphorus
Nitrogen
mg/I
Lead mg/I
mg/I
mg/I
mg/I
mg/I
Jan-10
<0.010
<0.010
0.031
<0.2
<0.04
<0.5
Feb-10
<0.010
<0.010
0.017
<0.2
<0.04
<0.5
Mar-10
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Apr-10
<0.010
<0.010
0.018
<0.2
<0.04
<0.5
May-10
<0.010
<0.010
0.071
<0.2
<0.04
<0.5
Jun-10
<0.010
<0.010
0.012
<0.2
0.06
<0.5
Jul-10
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Aug-10
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Sep-10
<0.010
<0.010
<0.010
<0.2
<0.04
Oct-10
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Nov-10
<0.010
<0.010
<0.020
<0.2
0.08
<0.5
Dec-10
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Jan-11
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Feb-11
<0.010
<0.010
<0.010
0.4
0.07
<0.5
Mar-11
<0.010
<0.010
0.042
<0.2
<0.04
<0.5
Apr-11
<0.010
<0.010
0.013
<0.2
<0.04
0.5
May-11
<0.010
<0.010
0.015
<0.2
0.19
<0.5
Jun-11
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Jul-11
<0.010
<0.010
<0.010
<0.2
0.08
<0.5
Aug-11
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Sep-11
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
Oct-11
<0.010
<0.010
<0.010
<0.2
<0.04
<0.5
C=I1 Kimley-Hom
and Associates, Inc.
Memorandum
To: Rod Butler
Karen Wallace
From: Erica V.T. Carter
John Potts
Subject:Dixon Water Treatment Plant Toxicity
Date: November 23, 2011
Proiect Description:
The Dixon Water Treatment Plant (WTP) discharges filter backwash wastewater to
tidal waters; in this case, an un-named tributary to Stones Creek in the White Oak
River basin. This un-named tributary to Stones Creek is considered SA-HQW waters
for market shell fishing — saltwater and high quality water. The WTP has an NPDES
permit (NC0083551 dated August 15, 2007) from NCDENR's Division of Water
Quality (DWQ) to allow this discharge (see Appendix A). This permit requires
quarterly testing of the discharge for acute toxicity. For approximately five years,
this toxicity testing has always met regulatory monitoring requirements. Recently,
this testing began to show a pattern of failures on an inconsistent but persistent
basis. Currently, the permit requirement to conduct the toxicity testing is a
monitoring requirement and not a compliance requirement. This means that under
the current permit, this system does not fall out of compliance with the permit when
toxicity requirements are not met. However, the permit is to be renewed in 2012,
and ONWASA must be prepared for toxicity testing to become a compliance
requirement of the renewed permit. This means that the cause of the failure to meet
toxicity requirements must be discovered and resolved.
ONWASA retained Kimley-Horn and Associates, Inc. (Kimley-Horn) to review
available acute toxicity results at the Dixon WTP, review plant operations to
determine if a change over time could be causing the acute toxicity failures, and to
run additional testing of the plant discharge water.
Kimley-Horn
and Associates, Inc.
ONWASA is currently in the pilot study, design, and permitting stages of the addition
of reverse osmosis (RO) membrane treatment trains to upgrade the plant to meet
2012 Disinfection Byproduct requirements (e.g. total organic carbon (TOC) upper
limit of 2 mg/L; current plant produces TOCs of approximately 10 mg/I), equip the
plant to handle saltwater intrusion should that become more prevalent (ONWASA
well 3 currently is showing increased total dissolved solids (TDS)), and remove high
concentrations of reactive silica (currently approximately 50 mg/1) to a concentration
that does not cause plating (approximately 15 mg/I). During permitting activities and
from conversations with DWO staff, it was recommended that the RO pilot unit
discharge, the concentrate, be tested for acute toxicity. The proposed total
discharge to the un-named tributary to Stones Creek is 1 mgd. The current
discharge is approximately 0.5 mgd.
History
The data over the past 5 years of acute toxicity testing from the Dixon WTP
discharge was reviewed for trends and any changes in plant operations. The
compilation of this data is included in Appendix B. Acute toxicity samples are
collected by WTP staff and local Envirochem (a Wilmington -based environmental
testing lab) staff. Envirochem staff ships the samples to ETS Laboratory in
Asheville, NC where the samples are tested in accordance with Parameter Code
TGE3E, North Carolina Methodology for Determining Acute Toxicity in a Single
Effluent Concentration — Revision: September 1994. The species that ETS tests
are the Mysidopsis Bahia. According to the NPDES permit, the permittee could test
using the Fathead Minnow, Mysid Shrimp (Bahia), or Silverside Minnow as the test
organism; however, ONWASA was required to use Mysid Shrimp (Bahia).
Table 1 summarizes the test results over the past 4 years based on information
provided by ETS. Rainfall data was also compiled during the past 4 years to
determine if significant rain events led to passing results (i.e. a diluted discharge).
The acute toxicity tests were only conducted for the Mysid Shrimp species.
Dixon WTP Toxicity, November 23, 2011, Page 2
Ito• Kimley-Hom
ti and Associates, Inc.
Table 1. Dixon WTP Acute Toxicit Results and Rainfall Data
Collection
Date
Pass/Fail
Mean
Mortality
Month Before
Sample
Regional
Rainfall
Data
4/4/2011
Fail
40.0%
3.78
2.70
1/17/2011
Fail
55.0%
2.46
1.53
10/4/2010
Pass
0.0%
12.41
2.14
7/12/2010
Fail
100.0%
4.92
4.73
4/13/2010
Fail
97.5%
3.52
0.81
1/4/2010
Fail
52.5%
7.17
3.94
1015/2009
Pass
0.0%
4.32
2.24
7/6/2009
Fail
37.5%
3.68
5.14
4/6/2009
Pass
0.0%
4.16
2.33
1/5/2009
Fail
82.5%
3.11
2.20
10/6/2008
Pass
0.0%
7.44
2.23
4/7/2008
Pass
0.0%
3.56
4.83
IM2008
pass
0.0%
3.87
2.65
Based on Table 1, there is no correlation between regional rainfall data and passing
results. In year 2008, every sample passed. In 2009, 50% of the samples passed;
while in 2010 only 25% of the samples passed. In 2011, only 25% of the samples
passed.
Several site visits were conducted by Kimley-Horn staff in summer and fall 2011 to
tour the plant facilities and interview WTP operators. Based on WTP operations,
there is no known change in operations that would cause toxicity to routinely fail.
It is notable that the most recent toxicity test dated October 4, 2011 did pass (see
Appendix C). The test results are summarized below in Table 2.
Table 2. October 4, 2012 Dixon WTP Acute Toxicity Survival Data
Replicate
24-hour Survival # of living organisms)
Control
90%
A
10
10
B
10
10
C
10
10
D
10
10
Mean mortality
0.7
0.7
There was not a significant rainfall event prior to the testing or in the month prior to
this test date. WTP operations are unchanged from the previous 3 year 2011 tests
that failed.
Dixon WTP Toxicity, November 23, 2011, Page 3
C=F J KimleyHorn
I and Associates, Inc.
Additional Testing
Kimley-Horn staff initiated two acute toxicity tests to further investigate toxicity:
1. Independent laboratory analysis of current backwash water discharge
2. Independent laboratory analysis of the RO pilot unit concentrate discharge
The current Dixon WTP backwash water was tested in September 2011 by an
independent laboratory, Hydrosphere Research, based on samples collected by
Kimley-Horn staff at the discharge testing location. Table 3 is the summary of the
report for acute toxicity for two species: Mysid shrimp (Bahia) and the Silverside
minnow. The full report is included in Appendix D.
Table 3. Dixon WTP Effluent Acute Toxicity Results, September 2011
% of Effluent
% Final Survival
Mysid Shrimp
Silverside Minnow
Control
100
100
6.25
95
100
12.5
100
100
25
95
100
50
90
100
100
5
100
LC50
64.4
>100
The results indicate that the lowest concentration at which 50% of the species live
(LC50) is 64.4% for the Mysid Shrimp and greater than 100% for the Silverside
Minnow. Based on the results, the Dixon WTP backwash water discharge is toxic to
the Mysid Shrimp but non -toxic to the Silverside Minnow.
Since the discharge with the Dixon RO Improvements project is increasing by 100%,
it was the request of NCDENR DWQ staff that the RO pilot unit concentrate
discharge be tested to determine if the proposed WTP upgrades would help the
acute toxicity. The RO pilot unit concentrate discharge was tested in October 2011,
and the full report is included in Appendix E. A summary of the test results is
included in Table 4.
Dixon WTP Toxicity, November 23, 2011, Page 4
C_FJ KimleyHorn
and Associates, Inc.
Table 4. Dixon RO Pilot Unit Concentrate Acute Toxicitv Results
% of Effluent
% Final Survival
Mysid Shrimp
Silverside Minnow
Control
100
100
6.25
100
100
12.5
100
100
25
100
100
50
100
100
100
100
100
LC50
>100
>100
The results indicate that greater than 100% of both the Mysid Shrimp and Silverside
Minnow species live in a solution that is 100% of the RO concentrate discharge
water. Since the RO concentrate discharge is not toxic to either the Mysid Shrimp or
the Silverside Minnow, the Dixon WTP RO Improvements project not only improves
the WTP's performance with TOCs, saltwater intrusion, and silica plating but also
acute toxicity as it relates to the Mysid Shrimp and Silverside Minnow.
Additionally, the RO Concentrate discharge was sampled for all NPDES elements
with the addition of Arsenic, which was indicated by Linda Willis of DWQ would be
an additional monitoring requirement when the plant add the RO treatment process.
The results of these tests are included in Appendix F, and a summary is included
below and in Table 5. The following elements are below detection limits:
• Arsenic
• Copper
• Lead
• Zinc
• Nitrate+Nitrite-Nitrogen
• Residual Chlorine
• Chlorine
Table 5. RO Concentrate Regulated Elements
Element
NPDES Permitted Limit
Actual
Total Suspended Solids
15.0 mg/L (Daily Max)
13.6 mg/L
Residual Chlorine
13 /L Dail Max
<10 /L not detectable
Based on these results, the RO concentrate discharge meets current NPDES
regulatory requirements and meets the additional Arsenic requirement.
A mass balance was performed using an average of the data provided in Appendix
B for the current Dixon WTP process and the data collected on the RO concentrate
discharge to predict the water quality as it relates to the NPDES permit for the Dixon
Dixon WTP Toxicity, November 23, 2011, Page 5
Kimley-Horn
and Associates, Inc.
WTP when the RO process is operational. A summary of the mass balance is
provided in Table 6.
Table 6. Predicted Future Dixon WTP Discharge Water Quality Data
Parameter
Current
Avera a
RO
Concentrate
Combined
Flow, m d
0.5
0.5
1
Salinity, t
5.7
0.9
3.3
H
7.65
7.58
7.62
Total Dissolved Solids, m /L
7100
1280
4190
Total Suspended Solids,
m /L
3.9
13.6
8.8
Total Residual Chlorine, IL
ND
ND
ND
Total Copper, m /L
0.007
ND
0.007
Total Chloride, m /L
3933
54
1994
Total Iron, m /L
0.061
4.79
2.43
Total Manganese, m /L
0.44
0.432
0.436
Total Lead, m /L
0.007
ND
0.007
Total Zinc, m /L
0.98
ND
0.98
Ammonia -Nitrogen, m /L
0.19
0.8
0.50
Fluoride, m /L
0.9
0.2
0.6
Total Nitrogen, m /L
1
0.5
0.75
Total Phosphorous, m /L
0.16
0.24
0.20
Note: ND = not detectable
Based on this mass balance, the proposed Dixon WTP discharge also meets current
NPDES permitted limits as summarized in Table 7.
Table 7. Pro osed Dixon WTP Discharge Re ulated Elements
Element
NPDES Permitted Limit
Predicted
Total Suspended Solids
15.0 mg/L (Daily Max)
8.8 mg/L
Residual Chlorine
13 /L Dail Max
not detectable
Next Steps
Subsequent to this memorandum, next steps for ONWASA relating to the Dixon
WTP acute toxicity include:
• Continue efforts on the RO Improvements project - anticipated construction
is late Spring 2012
Dixon WTP Toxicity, November 23, 2011, Page 6
KtmleyHom
and Associates, Inc.
• Provide acute toxicity results to DWQ permitting staff regarding the RO
Improvements project (previously provided via email to Gil Vinzani and Tom
Belnick)
• Submit 2012 NPDES permit renewal (consider including a copy of this
memorandum)
Because the only chemical added to the RO pilot unit (and subsequent RO process
after the RO Improvements project is implemented) is scale inhibitor and because
this scale inhibitor is organic (Avista's Vitec 4000), it should not be, and based on
test results is not toxic. The current Dixon WTP process has several chemical
additions. One in particular is the addition of Potassium Permanganate as an
oxidant. It is possible that this chemical could be causing increased susceptibility to
acute toxicity failures. Additional testing may be conducted to further examine this
chemical's effect on acute toxicity.
Dixon WTP Toxicity, November 23, 2011, Page 7
Dixon Water Treatment Plant Data
Total Dispended Solids (TDS)
10000
8000
E 7000
6000
w 5000
4000
3000
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N N N N
\ \ \ \ 0 \ M \ \ \ 0 \ M \ \ M 0 \ \ \ \ \ \ \
N 1� O1 � �-1 M N I� O� � ti M N
Date
Total Suspended Solids (TSS)
30
25
20
ec
E
a
c
15
7
N
10
L5
5
0
0
N
\
m
0
0
N
\
m
0
0
N
\
m
0
0
N
M
m
0
0
N
\
m
00 0o 0
0 0 0 0 0
0 0 0 0 0
N N N N N
\ \ \ \ \
m m m m m
0 0 m m m 0 0
0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N
\ \ M \ \ \ \ \ \ \
m m m m m m m m m m
0
0
N
m
M
0
0
N
\
m
n
0
a
N
\
M
m
0
0
N
\
m
.\i
0
0
N
\
m
\-�
0
0
N
\
m
m
0
0
N
\
m
0
0
N
\
m
Date
f
pH
8.2
8
7.8
x
,°, 7.6
c
v
7.4
AA
w
7.2
7
6.8
n n n n n n oo ro m eo m m m m m m m m o 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N 0 0 a 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N N N N N N N N
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
m m m m m m m m m m m m m m m m m m m m m m m m m m m m
n rn N\i m u\i n m\i .\i m v\i n m \-i ti m m n m \+ ti m m n
Date
Dissolved Oxygen
14
13
12
JAll
io 11
a 10
c
m
g
W
7
6
n n a m ao 0a 00 00 m m m m m m o 0 0 0 0 0 .+ .+ .�+ .-�
0 0 0 0 0 0 0 0 0 0 0 0 0 0 .+ .-� •+
0 0 0 0 0 0 a
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N N N N
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
try I(1 ill N N ll1 In N N t/1 V1 N V1 V1 N lA V1 � N N N N VI ll1
\ \ \ \ \ \ \ m \ \ \ \ \ m \ \ m \ \ \ \ \
T N n m "'� m �/1 n m
t11 n m � �"�
0 m
�
Date
Chloride
10000
-
9000
8000
7000
E
6000
5000
Q)
4000
3000
w
2000
1000
0
0
0
0
0
0
0
000
0
0
0
000
o
O10
o
00
00
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.-i
m
0
n
m
m
m
.�+
.ti
m
m
v�
m
n
m
m
.�+
.�+
m
m
�n
n
m
m
N
.�
m
m
in
0
n
Date
Fluoride
a
5
4
m
E
1
0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N N N
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
rn m m m m m m m m m m m m m m m m m m m m m m
m 0 m \ \ � m m \ \ m \ \ \ \ \ \ \ \ \ \ \ \ \ \
m .-+ vi n m .-i .�+ m n m
N ti ti N
Date
Ammonia Nitrogen
0.45
0.4
0.35
J
ono 0.3
E 0.25
Y
v 0.2
M 0.15
W
0.1
0.05
0
n n w w w w w w M M M M M M 0 0 O 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0. . . ' . .
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
m m rn m m m m rn m rn m m m rn m m m m m m m m rn
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
m� .-+ m In � m� m
Date
Salinity
9
8
7
a6
a
�• 5
c
W q
M: 3
2
1
0
n n w w w w w w rn m rn m rn m o 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N N N N
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
Vl Vl Vl Vl Ill N Vl N Ill ltt 1(1 t!1 Vl N Vl VI V1 N N Ill IA Ill I!1 V1
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
Date
Total
Nitrogen
20
18
16
14
E 12-
10
G
Qj
7 8
.2
6
w
4
2
0
0
0 0 0 0 0 0 0 0 0 0
0 0 0 0
0 0 0 0 0 0 0 0
m rn m m m m m m m m
m m m m
m m m m m m m m m
H m
Date
Total
Phosphorous
5.5
4.5
no
3.5
E
c
2.5
d_
w
1.5
0.5
-0.5 0 0
0
0
0
0
0 0 0
0 0 0 0 0 0
0
0
0
0
0
0
0
0
m m
m
m
m
m
m m m
m rn m m m rn
m
m
m
m
rn
m
m
m
O1
Copper
0.012
0.01
0.008
E
c
0.006
w
3
0.004
w
0.002
0.7
W.
=, 0.5
na
E 0.4
c
v 0.3
3
w
w 0.2
0.1
0
n n w m w w w w m m m m m m 0 0 0 0 0 0...
0 0 0 0 0 0 0 0 0 0 0 0 0 0 H. N ti•. H • '
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
m m m m m m m m m m m m m m m m m m m m m m m
Date
Iron
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 a a� 0 a 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
m m
m m m m m m m m m m m m m m m m m m m m m m m m m m m m
Date
Manganese
2.5
of
0.5
0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 N
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N N N
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
m m m m m m m m m m m m m m m m m m rn m m m m
ti ti ti ti
Date
Lead
0.03
0.025
J
b- 0.02
G
Y 0.015
C
v
0.01
W
W
0.005
0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 a 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N N N
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
rn rn m rn rn m m rn m rn m rn m m o� m m rn rn m m m m
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
mH m
Date
Zinc
0.14
0.12
m
0.1
E 0.O8
Y
y 0.06
1 0.04
W
0
1 n w w w m w w m m m m m m O O O O O O H H H
O O O O O O O O O O O O O O H H
O O O O O O O O O O O O O O O O O O O O O O O
N N N N N N N N N N N N N N N N N N N N N N N
m m rn m m m rn m m m m m m rn m m m m m m m m rn
H H H H H H H H H H H H H H H H H H H H H H H
0
m H H m vi n m 0
H H H H
Date