NC0026611_Monitoring (Information)_20240913

R O NMI D CITY
TH,CAROLINA
RECEIVED
September 3, 2024 NCDEO/--`''"`P/NPDES
Mr. Nick Coco
NC DEQ/Division of Water Resources
Water Quality Permitting
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Permit Renewal —Reduced Monitoring
NPDES NC0026611
Town of Morehead City
Carteret County, NC
Dear Mr. Williams:
Please accept this letter as the Town's request to continue "reduced monitoring" requirements
in the Town's renewed NPDES Permit. The following criteria, taken from the document entitled
"DWQ Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits for
Exceptionally Performing Facilities" dated October 22, 2012, are addressed in support of the
Town's request for "reduced monitoring":
The facility has no more than one civil penalty asses smentforpermit limit violations for each
target parameter during the previous three years.
The W WTP does not have more than one civil penalty assessment for permit limit violations for
each target parameter during the previous three years.
Neither the permittee nor any ofits employees have been convicted of criminal violations of
the Clean Water Act within the previous five years.
The permittee nor any of its employees have been convicted of criminal violations of the Clean
Water Act within the previous five years.
The facility is not currently under an SOCfor target parameter effluent limit no«complialice.
The above statement is correct.
The facility is not on EPA's Quarterly Noncompliance Reportfor target parameter limit
violations.
The above statement is correct.
DD1 11i-100!�5i/TFVTUt�2I0t�274 1 240903
Morehead City�rs-c2tt1cateaTo'rU1xHJ9A$4 service with a warm coastal smile.
1100 Bridges Street I Morehead City, North Carolina 28557 1 Phone [phone] www.moreheadcitync.org

For BODS, NH3 N and TSS, the three year arithmetic mean of effluent data must be less than
fifty percent of the monthly average permit limit Forfecal coliform or enterococci, the three
yeargeometric mean must be less than 50 percent of the monthly average permit limit For
parameters with summer and winter limits, an annual arithmetic mean of the seasonal limits
may be used in the calculation.
• The three-year arithmetic mean ofBODSduring the period between 2021-2023for the
summer months (April 1 — October 30) was 1.43 mg/L. This is less than 50% of the
monthly limit of 5.0 mg/L forthe summer months. The three-year arithmetic mean of
BODS during the periodbetween 2021-2023 for winter months (November 1 — March
31) was 0.92 mg/L. This value is less than 50% of the monthly limit of 10 mg/L for
winter months.
• The three-year arithmetic mean of NH3-Nduringthe periodbetween 2021-2023 for the
summermonths (April 1 — October 30) was 0.24 mg/L. This value is less than 50% of
the monthly limit of 1.0 mg/L for the summer months. The three year arithmetic mean of
NH3-N during the period between 2021-2023 for the winter months (November 1 —
March 31) was 0.26 mg/L. This value is less than 50"/o of the monthly limit of 2.0 mg/L
for the winter months.
• The three-year arithmetic mean of TSS during the period between 2021-2023 was 1.75
mg/L. This value is less than 50% of the monthly limit of 10 mg/L.
• The three-year geometric mean of Enterococci during the period between 2021-2023
was 5.53 cfu/100 ml. This is less than 50% of the monthly limit of 35 cfu/100 ml for
enterococci.
With the exception offecal coliform or enterococci, no more than 15 daily sampling results
over the 3-year review period can be over 200% of the monthly average limit for BODS,
CBODS, TSS, or NH3-N. Values associated with documented impacts of extreme weather or
events beyond the control of the permittee will not be included.
There were no samples greater than 200% of the monthly limit of 5.0 mg/L during the
review period between 2021-2023 for BOD5.
There were no samples greater than 200% of the monthly limit of 10 mg/L during the
review period between 2021-2023 for TSS.
There were ten (10) samples that were greater than 200% of the monthly limit of 1.0
mg/L during the review period between 2021-2023 for NH3-N.
For fecal coliform or enterococci, no more than 20 daily sampling results may be over 200%
of the weekly average limit Values associated with documented impacts ofextreme weather or
events beyond the control of the permittee will not be included.
There were four (4) samples greater than 200% of the weekly limit of 276 cfu/l00 ml during the
review period between 2021-2023 for Enterococci.
D 1005/FTL/2024 1 240903
MH CITY-W WTP NPDES- Renewal Application-2024-LTR.docx

For the four targetparameters, sampling results shall not show more than two non -monthly
average limit violations during the previous year.
The above statement is not clear as to the meaning of "two non -monthly average limit
violations". Previous references to "Monthly Average", "Weekly Average" and "Daily
Sampling Results" are all understandable terms. Since the term "two non -monthly average limit
violations" is not understood, commenting on the above criteria is not possible. Please provide
the definition of"two non -monthly average limit violations" and a response will be prepared to
indicate compliance or non-complicance.
Reduced effluent monitoring must not impair assessment of sensitive downstream uses, such
as endangered species.
Reduced monitoring will not impair any sensitive downstream uses
DMR reports for calendar years 2021, 2022 and 2023 were used for the three year period
addressed in the above comments. Spreadsheets for these three years are attached illustrating
additional information. Copies ofall monthly DMR's will be provided upon request, ifneccessary.
There are no significant deviations in the 2024 data available to date from the data reported
for calendaryears 2021— 2023. A spreadsheet illustrating data for the first six months of 2024 is
also attached.
If you have any questions concerning this, please do not hesitate to contact me.
Sincerely,
(:�J� /
Daniel Williams
Public Services Director
FTL:
Attachments
D 1005/FTL/2024 1 240903
MH CITY-WWTP NPDES- Renewal Application-2024-LTR.docx

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MOREHEAD CITY WWTP EFFLUENT MONITORING DATA - 2024
*Geometric Mean
2024
BOD
*Fecal Coliform (Enterococci)
FLOW
TSS
Ammonia (NH3)
January
0.91
1.91
1.460
1.10
0.07
February
0.72
5.22
1.290
1.38
0.07
March
0.80
12.92
1.500
1.29
0.07
April
0.88
3.26
1.400
1.03
0.61
May
1.71
12.04
1.370
1.74
0.04
June
1.71
11.11
1 1.350
1 1.35
0.10
AVERAGE
1.12
1 6.19
1 1,395�—i
1.321
1 0.16
\\G-G10S\D1012\FTL\2024
MHC WWTP Effluent - 2024 - Reduced Monitoring.AsAle
240125