NC0088340_Fact Sheet_20180924

DEQ / DWR / NPDES
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit NCO088340
Derek Denard, Compliance & Expedited Permitting Unit / 919-807-6307 24Sep2018
FACILITY SUMMARY: This facility is an ion exchange technology water treatment plant with discharge
of wastewaters from media filter backwash and sedimentation basins with a design potable flowrate of
0.432 MGD and a maximum, monthly average wastewater discharge of 0.221 MGD based on data
submitted. Because the waste flow is <0.050 MGD, instantaneous or estimate flow monitoring is allowed.
The facility consists of the following water and wastewater treatment units:
• water supply well system
• two (2) aerators
• two (2) detention tanks
• two (2) ion -exchange water -softeners
• two (2) sand filters
• dechlorination equipment
• chemical usage consists of
o chlorine
o Dechlorination with SO2
o ammonia nitrogen / chloramines
o zinc orthophosphate
o salt brine.
ELIGIBILITY FOR COVERAGE UNDER THE GENERAL PERMIT NCG590000: Mill Pond WTP
is not eligible for the general because of usage of IE technology
Fact Sheet
Renewal 2018 -- NPDES Permit NCO088340
Page 1
Facility Information
Applicant/Facility Name
Pamlico County Water System -
Mill Pond Water Treatment Plant (WTP)
Applicant Address
P.O. Box 158, Bayboro, NC 28515
Facility Address
601 North 3rd Street, Bayboro 28515
Permitted Flow (MGD)
Not limited
Type of Waste
Water Plants and Water Conditioning Discharge — dechlorinated
filter -backwash — Ion Exchange water soft WTP System
Facility Class
PC -1
County
Pamlico
Permit Status
Renewal
Regional Office
WaRO
Stream Characteristics
Receiving Stream
UT to North Prong
Bay River
Stream Classification
SC; Sw, NSW
Stream Segment
[27-150-2]
Drainage basin
Neuse
Summer 7Q10 (cfs)
0.0
Subbasin
HUC
03-04-13
030202040801
Winter 7Q10 (cfs)
0.0
Use Support
No Data
30Q2 (cfs)
0.0
303(d) Listed
Average Flow (cfs)
0.0
State Grid
G31NE
IWC (%)
100%
USGS Topo Quad
Bayboro, NC
FACILITY SUMMARY: This facility is an ion exchange technology water treatment plant with discharge
of wastewaters from media filter backwash and sedimentation basins with a design potable flowrate of
0.432 MGD and a maximum, monthly average wastewater discharge of 0.221 MGD based on data
submitted. Because the waste flow is <0.050 MGD, instantaneous or estimate flow monitoring is allowed.
The facility consists of the following water and wastewater treatment units:
• water supply well system
• two (2) aerators
• two (2) detention tanks
• two (2) ion -exchange water -softeners
• two (2) sand filters
• dechlorination equipment
• chemical usage consists of
o chlorine
o Dechlorination with SO2
o ammonia nitrogen / chloramines
o zinc orthophosphate
o salt brine.
ELIGIBILITY FOR COVERAGE UNDER THE GENERAL PERMIT NCG590000: Mill Pond WTP
is not eligible for the general because of usage of IE technology
Fact Sheet
Renewal 2018 -- NPDES Permit NCO088340
Page 1

RENEWAL SUMMARY: This permit reflects discharge at Outfall 001.
We have made the following changes for the final permit:
1. The facility classification Grade I Physical Chemical WPCS was added to the effluent page.
2. Acute WET testing, Total Phosphorus, Total Nitrogen, Nitrate -Nitrite and TKN monitoring has
been changed to composite in accordance with 15A NACA 02B .0505 (c).
3. Since this facility now has a record of passing Whole Effluent Toxicity (WET) testing, the
Discharge Alternatives Evaluation has been removed for this permit renewal.
We have made the following updates for the permit renewal:
3. The facility map has been updated.
4. Regulatory citations have been added.
5. Concurrent sampling with quarterly WET testing is no longer required for toxicants.
6. Total Manganese monitoring has been removed because the EPA approved removal of this NC aquatic
life standard as part of 2007-2016 Triennial review. Therefore, there are no limits to compare
monitoring data for this parameter.
7. A reasonable potential analysis (RPA) recalculated using the past 20 months (Nov2015 to Jun2018) of
available DMR data for Total Zinc. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i).
The NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2)
assumption of zero background; 3) use of/z detection limit for "less than" values; and 4) streamflows
used for dilution consideration based on 15A NCAC 2B.0206. Results of the RPA indicated a
maximum predicted concentration of 97.82 µg/1. This value is greater than both the Acute allowable
concentration of 95.1 µg/1 and Chronic allowable concentration of 85.6 µg/1. This confirms that there is
reasonable potential to exceed the water quality standards for Total Zinc. Therefore, the Zinc limits as
drafted are applicable.
The NC 2007-2014 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Committee (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016 with some exceptions. The NC Division of Water
Resources NPDES Permitting Unit is required to implement the new dissolved metal standards in all
permits public noticed after April 6, 2016. A reasonable potential analysis of data indicated that limits
are needed for Total Zinc based on the new dissolved metal standards. The following limits have been
applied for this permit renewal with monthly monitoring:
Parameter Monthly Average Daily Maximum Limit
Zinc 85.6 gg/L 95.1 gg/L
8. A compliance schedule has been added for Total Zinc limits in Section A. (2.). The Total Zinc limits
will become effective 48 months from the effective date of the permit.
9. Total Copper data was reported as < 10 µg/L. Therefore, Total Copper has not been given a limit.
However, monthly monitoring has been maintained for the renewal because the dissolved metals
standards for Copper are less than 10 gg/L. For Copper, the dissolved metals standards for saltwater are
3.70 ttg/L for the Chronic value and 5.80 gg/L for the Acute value. Please note that the analytical
method Practical Quantitation Limit (PQL) for Total Copper should be at least 2 µg/1 to demonstrate
compliance with dissolved metals standards. Minimum detection and reporting levels (MDLs & PQLs)
are defined by our Water Sciences Section as follows:
Each analytical procedure has a Practical Quantitation Limit (PQL), which is defined as "the lowest
concentration that can be reliably achieved within specified limits of precision and accuracy during
Fact Sheet
Renewal 2018 -- NPDES NC0088340
Page 2

routine laboratory operating conditions." PQLs are subjectively set at some multiple of typical
Method Detection Limits (MDLs) for reagent water (generally 3 to 5 times the MDL). The PQL for
a procedure may also be defined by: a reporting limit or minimum limit (ML) specified by the
analytical method; sample volume and buret graduations; and/or minimum measurement values that
are method -defined. The established PQL for a procedure serves as a reliable and routinely
achievable reporting limit for a biological or chemical parameter
(hitps://deq.nc. gov/about/divisions/water-resources/water-resources-data/water-sciences-home-
page/microbiolo ggy inorganics-branch/methods-pals-qa).
In accordance with NPDES Standard Conditions Part I1 Section D. 4., the following is required for test
procedures:
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and all
data generated must be reported down to the minimum detection or lower reporting level of the
procedure. If no approved methods are determined capable of achieving minimum detection and
reporting levels below permit discharge requirements, then the most sensitive (method with the
lowest possible detection and reporting level) approved method must be used.
COMPLIANCE HISTORY: Review of compliance records from Ju12013 to Jun2018 did not indicate any
violations generated from monitoring data. There was one permit condition violation NOV-2018-PC-0107 for
failure to submit a Discharge Alternatives Evaluation in accordance with Part I, Condition A. (4.) of the
previous permit. See attached Monitoring Report Violations summary and Other Violations summary.
DISCHARGE ALTERNATIVES EVALUATION: Per the terms of the previous NPDES permit found in
Part I, Condition A. (4.), the permittee was required to submit a Discharge Alternatives Evaluation to the
Division along with the submission of the next permit renewal application due 6 months prior to permit
expiration on June 1, 2017. Non-compliance with this permit condition resulted in the March 29, 2018 Notice of
Violation (NOV-2018-PC-0107). Since this facility now has a record of passing Whole Effluent Toxicity
(WET) testing, the Discharge Alternatives Evaluation has been removed for this permit renewal.
WHOLE EFFLUENT TOXICITY (WET) TESTING: With a tidally influenced discharge that is not
modeled, permit NCO088340 requires Acute Whole Effluent Toxicity (WET) testing using Mysidopsis Bahia to
be performed as 24 -day pass/fail test at 90% effluent concentration, during March, June, September and
December [TGE3E]. This facility has passed 100% of the last 12 WET tests (3 years). See attached data
spreadsheet.
Fact Sheet
Renewal 2018 -- NPDES NCO088340
Page 3

PARAMETERS OF CONCERN: In accordance with the October 14, 2009 WTP Strategy by Julie Grzyb
(as referenced below), Table 2.2 for membrane technology and Table 5.1 for monitoring frequencies, the
following parameters are included for this permit renewal:
Footnotes:
1. The Permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See
Condition A. (4.).
2. For intermittent discharges, instantaneous flow monitoring is required, and the duration of the discharge must be reported
in addition to the total flow.
3. The Division shall consider TRC effluent values reported below 50 gg/L to be compliant with the permit. However, the
Permittee shall continue to record and submit all values reported by a North Carolina -certified laboratory (including field
certified), even if these values fall below 50 gg/L.
4. Compliance with this limit shall commence on November 12022, approximately 48 months from the permit effective date.
See Compliance Schedule Condition A. (2).
5. For a given wastewater sample, TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kjeldahl
Nitrogen, and NO3-N and NO2-N are Nitrate and Nitrite Nitrogen, respectively.
6. Acute Whole Effluent Toxicity (WET) testing - testing of Mysid Shrimp (Mysidopsis Bahia) shall be performed as 24 -day
pass/fail test at 90% effluent concentration, monitoring only, during March, June, September and December [See A. (3.)].
Conditions:
• Samples shall be taken at the outfall but prior to mixing with the receiving waters.
• There shall be no discharge of floating solids or foam in other than trace amounts.
Fact Sheet
Renewal 2018 -- NPDES NCO088340
Page 4
1
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTIC
[PARAMETER CODES)
Monthly
Daily
Measurement
Sample
Sample
Avera e
Maximum
Frequency
Type
Location
Flow (MGD) 2, a
50050
Monitor & Report a
Weekly
Instantaneous
2,b
Effluent
or Estimate
Total Suspended Solids (TSS) (mg/L)
C0530
30.0 mg/Lc
45.0 mg/Lc
Weekly d
Composite e
Effluent
Total Residual Chlorine (gg/L) 3
50060
13 gg/L 3,f
Weekly d
Grab 9
Effluent
pH (su)
00400
Not < 6.8 or > 8.5 h
Weekly d
Grab 9
Effluent
standard units
Total Dissolved Solids (TDS) (mg/L)
70295
Monitor & Report
2/Month I
Composite e
Effluent
Turbidity (NTU)
00070
Monitor & Report
2/Month'
Grab 9
Effluent
Dissolved Oxygen (DO) (mg/L)
00300
Monitor & Report
2/Month'
Grab 9
Effluent
Temperature (°C)
00010
Monitor & Report
2/Month'
Grab 9
Effluent
Salinity (ppth)
00480
Monitor & Report
2/Month'
Composite e
Effluent
Conductivity (umhos/cm)
00094
Monitor & Report
2/Month'
Composite e
Effluent
Ammonia Nitrogen (NH3) (mg/L)
C0610
Monitor & Report
Monthly
Composite e
Effluent
Total Copper (gg/L) k
01042
Monitor & Report k
Monthly
Composite
Effluent
Total Chloride (mg/LI
00940
Monitor & Report I
Monthly
Composite
Effluent
Total Zinc (gg/L) 4'k
01092
85.6 gg/L4'k
95.1 gg/L4'k
Monthly J
Composite e
Effluent
TKN (mg/L) 5, m
00625
Monitor & Report
Quarterly
Composite e
Effluent
NO3-N + NO2-N (mg/L) 5' m
00630
Monitor & Report
Quarterly.
Composite e
Effluent
5, n
TN (mg/L)
C0600
Monitor & Report
Quarterly
Composite e
Effluent
Total Phosphorus (mg/L) n
C0665
Monitor & Report
Quarterly
Composite e
Effluent
Acute WET Testing 6,o
TGE3E
Monitor & Report
Quarterly
Composite e
Effluent
Footnotes:
1. The Permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See
Condition A. (4.).
2. For intermittent discharges, instantaneous flow monitoring is required, and the duration of the discharge must be reported
in addition to the total flow.
3. The Division shall consider TRC effluent values reported below 50 gg/L to be compliant with the permit. However, the
Permittee shall continue to record and submit all values reported by a North Carolina -certified laboratory (including field
certified), even if these values fall below 50 gg/L.
4. Compliance with this limit shall commence on November 12022, approximately 48 months from the permit effective date.
See Compliance Schedule Condition A. (2).
5. For a given wastewater sample, TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kjeldahl
Nitrogen, and NO3-N and NO2-N are Nitrate and Nitrite Nitrogen, respectively.
6. Acute Whole Effluent Toxicity (WET) testing - testing of Mysid Shrimp (Mysidopsis Bahia) shall be performed as 24 -day
pass/fail test at 90% effluent concentration, monitoring only, during March, June, September and December [See A. (3.)].
Conditions:
• Samples shall be taken at the outfall but prior to mixing with the receiving waters.
• There shall be no discharge of floating solids or foam in other than trace amounts.
Fact Sheet
Renewal 2018 -- NPDES NCO088340
Page 4

Permitting Strategy Notes:
a. Flow is not limited.
b. Instantaneous or Estimate flow monitoring is allowed for IE technology (Table 2.2).
c. Technology based effluent standard (TBEL) [40 CFR 133.102].
d. For flow >0.5 MGD, monitoring is weekly for parameters that are limited (Table 5.1).
e. In accordance with 15A NACA 02B .0505 (c), sampling is composite. The design flow is >30,000
MGD and the maximum, monthly average wastewater discharge is 0.050 MGD. Composite sampling is
required for IE technology (Table 2.2).
f. EPA Nationally Recommended Water Quality Criteria for Aquatic Life & Human Health: Acute value
is 13 µg/1.
g. In accordance with 15A NACA 02B .0505 (c), sampling is grab. Grab sampling is required for IE
technology (Table 2.2).
h. Saltwater standard for pH [15A NCAC 02B .0220 (12)].
i. For flow >0.5 MGD, monitoring is 2/month for parameters that are not limited (Table 5.1).
j. Monitoring is monthly in accordance with WTP strategy Table 2.2.
k. See RPA information below.
1. Total Chloride monitoring is required for IE technology but does not have a saltwater standard.
m. Monitoring for TKN and Nitrate & Nitrite is required for the Neuse River Basin.
n. Facilities discharging to nutrient sensitive waters (NSW) should monitor for nutrients (Table 2.2).
o. For saltwater that is tidally influenced without modeling, Acute WET Testing is Mysid Shrimp
(Mysidopsis bahia), 24hr P/F at 90%. [Changes to the Toxicity Testing Requirements in the Water
Treatment Plant Permitting Strategy (October 2009), June 11, 2012].
DATA SUMMARY:
Monthly Average Flow for A r2015-Mar2018 36 months of active discharge):
Parameter Max Min Count UoM
mgd
DMR Daily Parameter Values for Oct2013-Mar2018 4 '/2 ears of active discharge)
Data
0.02
mg/I
50050 - Flow, in conduit or thru treatment
plant 0.22106667
0.005
36
mgd
DMR Daily Parameter Values for Oct2013-Mar2018 4 '/2 ears of active discharge)
Limits
PQL MA DM UoM
deg C
ntu
umhos/cm
_ mg/I
6.8-8.5 su
ppth
0.5
Data
0.02
mg/I
Parameter T
Max
Imin
lAveragelcount
00010 -Temperature, Water Deg. Centigrade
22.9
14.8
_19.0
94
00070 - Turbidity
1.9
0.2
0.5
54
00094 - Conductivity
47300
814
4181.4
54
00300 - Oxygen, Dissolved (DO)
840
5.3
22.7
55
00400 - pH
8.03
6.76
108
00480 - Salinity
30.6
0.4
2.4
54
00625 - Nitrogen, Kjeldahl, Total (as N)
69.5
0.5
4.3
19
00630 - Nitrite plus Nitrate Total (as N)
1.28
0.02
0.74
19
00940 - Chloride (as Cl)
20300
65
2533.2
54
01042 - Copper, Total (as Cu)
10
10
10
42
01051 - Lead, Total (as Pb)
10
10
10
15
01055 - Manganese, Total (as Mn)
42
2
11.6
38
01092 - Zinc, Total (as Zn)
73
10
24.1
42
50050 - Flow, in conduit or thru treatment plant
0.733
0.001
0.015
1596
50060 - Chlorine, Total Residual _
45
10
20.1
108
70295 - Solids, Total Dissolved _
32800
497
2654.4
54
C0530 - Solids, Total Suspended - Concentration
9.5
2.5
2.8
108
C0600 - Nitrogen, Total - Concentration
70.5
0.5
5.5
16
C0610 - Nitrogen, Ammonia Total (as N) - Concentration_
1.8
0.2
-0.3
54
C0665 - Phosphorus, Total as P - Concentration
1.26
0.04
0.16
19
Limits
PQL MA DM UoM
deg C
ntu
umhos/cm
_ mg/I
6.8-8.5 su
ppth
0.5
mg/I
0.02
mg/I
mg/I
10
ug/I
10
ug/I
10
ug/I
10
85.6 95.1 ug/I
mgd
20
13 ug/I
mg/I
2.5
30 45 mg/I
0.5
mg/I
0.2
mg/I
0.04
mg/I
PQL = Practical Quantitation Limit; MA = Monthly Average Limit; DM = Daily Maximum Limit; UoM = Units of Measure
New Limits are in bold I
Fact Sheet
Renewal 2018 -- NPDES NCO088340
Page 5

RPA: The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water
quality standards, a statistical evaluation that is conducted during every permit renewal utilizing the most
recent effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The
NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of
zero background; 3) use of 1/z detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between Oct2013 to
Mar2018. Pollutants of concern included toxicants with positive detections and associated water quality
standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria: Total Zinc.
• Monitoring Only. The following parameters will receive a monitor -only requirement since they did
not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the
maximum predicted concentration was >50% of the allowable concentration: NA
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria and
the maximum predicted concentration was <50% of the allowable concentration: NA.
• Summary of new limits added based on RPA:
Parameter Monthly Average Daily Maximum Limit
Zinc 85.6 gg/L 95.1 gg/L
• Summary of existing limits deleted based on RPA: NA
• Other: Total Copper data was reported as < 10 gg/L. Therefore, Total Copper has not been given a
limit. However, monthly monitoring has been maintained for the renewal because the dissolved
metals standards for Copper are less than 10 gg/L. For Copper, the dissolved metals standards for
saltwater are 3.70 gg/L for the Chronic value and 5.80 µg/L for the Acute value. Please note that
the analytical method Practical Quantitation Limit (PQL) for Total Copper should be at least 2 µg/1
to demonstrate compliance with dissolved metals standards. Total Chloride monitoring is required
but does not have a saltwater standard.
Fact Sheet
Renewal 2018 -- NPDES NC0088340
Page 6

NPDES Implementation of Instream Dissolved Metals Standards — Saltwater Standards
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, metals limits in draft permits out to public notice after April 6, 2016
must be calculated to protect the new standards - as approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, gg/l
(Dissolved)
Acute SW, gg/l
(Dissolved)
Chronic SW, µg/1
(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
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Ca c -u atiror�i = 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/1 for human health
protection; cyanide at 5 gg/L and fluoride at 1.8 mg/L for aquatic life protection).
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
metal standards requires additional consideration in order to establish the numeric standard for each metal of concern
of each individual discharge. Note that none of the saltwater standards are hardness -dependent.
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 conversion factors determined by EPA (more on that below), but it is also possible to consider case -specific
translators developed in accordance with established methodology.
RPA Permitting Guidance — Discharges to Saltwater (Tidal waters)
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 stream
dilution. For discharges to saltwater, no allowance for dilution is given unless a dilution study, such as a CORMIX
model, is performed.
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 using the saltwater dissolved metal standards, the Permit Writer compiles the following
information:
• Permitted flow
• Receiving stream classification
• Instream Wastewater Concentration, if a dilution model has been performed
Fact Sheet
Renewal 2018 -- NPDES NC0088340
Page 7

2. The RPA spreadsheet converts the dissolved numeric standard (SW standards listed in Table 1.) for each
metal of concern to a total recoverable metal, using the EPA conversion factors published in the June, 1996
EPA Translator Guidance Document. This method presumes that the metal is dissolved to the same extent as
it was during EPA's criteria development for metals.
3. The dissolved numeric standard for each metal of concern is divided by the EPA conversion factor (or site-
specific translator) to obtain a Total Recoverable Metal at ambient conditions.
4. If a dilution study was performed on the receiving stream and an Instream Wastewater Concentration (IWC)
determined the RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q10 + Qw) (Cwgs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (gg/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 7Q 10 units)
s7Q10 = summer, critical low flow (cfs)
* Discussions are on-going with EPA on how best to address background concentrations
Assuming no background concentration, this equation can be reduced to:
Ca = (s7Q10 + Qw) (Cwgs) or Ca = Cwgs
Qw IWC
Where: IWC = Qw or 1
Qw+s7Q10 D
and D = modelled dilution factor (unitless)
If no dilution study has been performed Ca, the allowable effluent concentration, is equal to the Total
Recoverable Metal determined at ambient conditions (ie. the dissolved numeric standard divided by the EPA
conversion factor (or site-specific translator) for the metal of concern). See item # 3 above.
Fact Sheet
Renewal 2018 -- NPDES NCO088340
Page 8
Conversion
Factors for Dissolved Metals
Saltwater CMC
Saltwater CCC
Metal
(Acute)
(chronic)
Arsenic
1.000
1.000
Cadmium
0.994
0.994
Chromium VI
0.993
0.993
Copper
0.83
0.83
Lead
0.951
0.951
Mercury
0.85
0.85
Nickel
0.990
0.990
Selenium
0.998
0.998
Silver
0.85
—
Zinc
0.946
0.946
From: US EPA website, National Recommended Water Quality
Criteria - Aquatic Life Criteria Table
hgps://www.epa. og v/wgc/national-recommended-water-
auality-criteria-aquatic-life-criteria-table#a
3. The dissolved numeric standard for each metal of concern is divided by the EPA conversion factor (or site-
specific translator) to obtain a Total Recoverable Metal at ambient conditions.
4. If a dilution study was performed on the receiving stream and an Instream Wastewater Concentration (IWC)
determined the RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q10 + Qw) (Cwgs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (gg/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 7Q 10 units)
s7Q10 = summer, critical low flow (cfs)
* Discussions are on-going with EPA on how best to address background concentrations
Assuming no background concentration, this equation can be reduced to:
Ca = (s7Q10 + Qw) (Cwgs) or Ca = Cwgs
Qw IWC
Where: IWC = Qw or 1
Qw+s7Q10 D
and D = modelled dilution factor (unitless)
If no dilution study has been performed Ca, the allowable effluent concentration, is equal to the Total
Recoverable Metal determined at ambient conditions (ie. the dissolved numeric standard divided by the EPA
conversion factor (or site-specific translator) for the metal of concern). See item # 3 above.
Fact Sheet
Renewal 2018 -- NPDES NCO088340
Page 8

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.
6. 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.
7. The Total Chromium NC WQS was removed and replaced with a hexavalent chromium standard. 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 VI. In these cases, the projected maximum concentration (95th %)
for total chromium will be compared against the water quality standard chromium VI.
PUBLIC NOTICE SCHEDULE:
Permit to Public Notice: May 20, 2018.
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the Director
within the 30 days comment period indicating the interest of the party filing such request and the reasons
why a hearing is warranted.
No public comments were received.
COMMENTS:
Permittee: See attached July 27, 218 letter from Bill Fentress, Finance Director/Assistant County Manager,
Pamlico County. The comments were the following:
The water treatment plant operation is unchanged and records of monitoring over the past three
years demonstrate that it should not be restricted to additional limits than those required by the
current permit. Enclosed are DMRs for the past 20 months. Additionally, we have included
information from the EPA's Echo website for your review (https://echo.epa.gov/effluent-charts).
The sixth bullet in the cover letter states that "A reasonable potential analysis of data indicated that
limits are needed for Total Zinc based [on] the new dissolved metal standards." The DMRs show
that Total Zinc has consistently been less than 40 micrograms per liter (ug/1) with only five (5) of
the 38 most recent test results having Total Zinc greater than 40 ug/1, but less than 75. All test
results are less than the proposed Monthly Average and Daily Maximum Limits. We respectfully
request your office review the available data, and confirm this requirement is applicable.
Response:
A reasonable potential analysis (RPA) recalculated using the past 20 months (Nov2015 to Jun2018)
of available DMR data for Total Zinc. The RPA is conducted in accordance with 40 CFR 122.44
(d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability;
2) assumption of zero background; 3) use of/z detection limit for "less than" values; and 4)
Fact Sheet
Renewal 2018 -- NPDES NC0088340
Page 9

streamflows used for dilution consideration based on 15A NCAC 2B.0206. Results of the RPA
indicated a maximum predicted concentration of 97.82 gg/1. This value is greater than both the
Acute allowable concentration of 95.1 µg/1 and Chronic allowable concentration of 85.6 µg/1. This
confirms that there is reasonable potential to exceed the water quality standards for Total Zinc.
Therefore, the Zinc limits as drafted are applicable.
FACT SHEET ATTACHMENTS:
• Monitoring Report Violations Ju12013 to June2018, 2 pages.
• Other Violations, 1 page.
• Whole Effluent Toxicity Testing and Self -Monitoring Summary, June 2018, p. 74
• RPA spreadsheets
Permittee Comments, 3 pages (attached DMR available on Laserfiche).
Affidavit of Publication
Fact Sheet
Renewal 2018 -- NPDES NC0088340
Page 10

MONITORING REPORT(MR) VIOLATIONS for:
Permit: NCO088340 MRs Between 7 - 2013 and 6 - 2018 Region: %
Facility Name: % Param Name % County: %
Major Minor: % L
Report Date: 09/18/18 Page: 1 of 2
Violation Category% Program Category:
Subbasin:%41 Violation Action: %
PERMIT: NCO088340
FACILITY: Pamlico County- Millpond WTP
COUNTY: Pamlico
REGION: Washington
Limit Violation
MONITORING
OUTFALU
VIOLATION
UNIT OF
CALCULATED
%
REPORT
PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
03-2014
001
Effluent
Chlorine, Total Residual
03/03/14
2 X month
ug/I
13
20
53.8
Daily Maximum
No Action, BPJ
Exceeded
10-2017
001
Effluent
Chlorine, Total Residual
10/26/17
2 X month
ug/I
13
45
246.2
Daily Maximum
No Action, BPJ
Exceeded
12-2017
001
Effluent
Chlorine, Total Residual
12/07/17
2 X month
ug/I
13
15
15.4
Daily Maximum
No Action, BPJ
Exceeded
12-2013
001
Effluent
pH
12/02/13
2 X month
su
6.8
6.76
0.6
Daily Minimum Not
No Action, BPJ
Reached
08-2014
001
Effluent
pH
08/21/14
2 X month
su
6.8
6.76
0.6
Daily Minimum Not
No Action, BPJ
Reached
Monitoring Violation
MONITORING
OUTFALL/
VIOLATION
UNIT OF
CALCULATED
%
REPORT
PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
01-2015
001
Effluent
Copper, Total (as Cu)
01/31/15
Monthly
ug/I
Frequency Violation
No Action, BPJ
02-2015
001
Effluent
Copper, Total (as Cu)
02/28/15
Monthly
ug/I
Frequency Violation
No Action, BPJ
02-2015
001
Effluent
Manganese, Total (as Mn)
02/28/15
Monthly
ug/I
Frequency Violation
No Action, BPJ
06-2014
001
Effluent
Nitrogen, Total -
06/30/14
Quarterly
mg/I
Frequency Violation
No Action, BPJ
Concentration
09-2014
001
Effluent
Nitrogen, Total -
09/30/14
Quarterly
mg/I
Frequency Violation
No Action, BPJ
Concentration
09-2014
001
Effluent
Pass/Fail Static 24hr Acute
09/30/14
Quarterly
pass/fail
Frequency Violation
No Action, Facility
Mysid. Bahia
Reporting Error
06-2015
001
Effluent
Pass/Fail Static 24hr Acute
06/30/15
Quarterly
pass/fail
Frequency Violation
No Action, BPJ
Mysid. Bahia
06-2018
001
Effluent
Pass/Fail Static 24hr Acute
06/30/18
Quarterly
pass/fail
Frequency Violation
None
Mysid. Bahia
01 -2015
001
Effluent
Zinc, Total (as Zn)
01/31/15
Monthly
ug/I
Frequency Violation
No Action, BPJ

MONITORING REPORT(MR) VIOLATIONS for:
Permit: NCO088340 MRs Between 7 - 2013 and 6 - 2018 Region: %
Facility Name: % Param Name % County: %
Major Minor: %
Report Date: 09/18/18 Page: 2 of 2
V7MWiolation Category:% Program Category: %
Subbasin:% Violation Action: %
PERMIT: NCO088340
FACILITY: Pamlico County- Millpond WTP
COUNTY: Pamlico
REGION: Washington
Monitoring Violation
MONITORING OUTFALL/
VIOLATION
UNIT OF
CALCULATED
%
REPORT PPI
LOCATION PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
Over
VIOLATION TYPE VIOLATION ACTION
02-2015 001
Effluent Zinc, Total (as Zn)
02/28/15
Monthly
ug/I
Frequency Violation No Action, BPJ
Reporting Violation
MONITORING OUTFALL/
VIOLATION
UNIT OF
CALCULATED
%
REPORT PPI
LOCATION PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
Over
VIOLATION TYPE VIOLATION ACTION
09-2014
10/31/14
Late/Missing DMR No Action, BPJ

OTHER VIOLATIONS for: Report Date: 09/18/18
Permit: NCO088340 Region: % Violations Category: Other Violations Program Category: %
Facility Name: % County: % Violation Action: %
PERMIT: NCO088340 FACILITY: Pamlico County - Millpond WTP COUNTY: Pamlico REGION: Washington
Other Violation
VIOLATION
DATE VIOLATION TYPE VIOLATION ACTION OPERATOR NAME CERT NUMBER ORC CLASS PERMIT CLASS
3/29/18 Permit conditions violation Proceed to NOV
1

Whole Effluent Toxicity Testing and Self Monitoring Summary
MillpondWTP- Bayboro
NCO088340/001 County: Pamlico
Mysd24PF Begin:
1/1/2015 Ac P/F Monit: 90% M NonComp:
J
F M A
2014
Fail
2015
Fail
2016
Pass
2017
Pass
2018
Pass
Mills River WTP
NCO085511/001 County: Henderson
Fthd24PF Begin:
4/1/2016 Ac P/F Monit: 90% Ft NonComp:
J
F M A
2014
Pass
2015
Pass
2016
Pass
2017
Pass
2018
Pass
Mocksville WTP (Hugh Lagle WTP) NCO089290/001
Region: WARO
County: Davie
7Q10: NA
M
J J
12/1/2013 Chr Cerio PF Monit: 9 NonComp:
Pass
Pass
F
Pass
A
Pass
2014
Pass
>74
Region: ARO
SOC JOC:
7Q10:
M
J J
Pass
Fail
Pass
Pass
Pass
Pass
Fail
Pass
Mocksville WTP (Hugh Lagle WTP) NCO089290/001
NEU13
County: Davie
SOC JOC:
Ceri7dPF
Begin:
12/1/2013 Chr Cerio PF Monit: 9 NonComp:
NA Freq: Q
J
F
M
A
M
2014
D
>74
Pass -
SOC JOC:
Pass
2015
D
Pass
Fail
Pass
2016
Pass
H
Fail
2017
Pass
Fail
FRB02
Feb May Aug Nov
2018
PF:
Pass
Freq: Q
Mocksville WWTP Dutchman's Cr. NCO021491/001
County: Davie
S O
Ceri7dPF
Begin:
11/1/2014 chr lim: 37% @ 0.98
NonComp:
Single
Pass
J
F
M
A
M
2014
Pass
Pass
Pass
2015
Pass
Pass
Pass
2016
Pass
Pass
2017
Pass
-
-
Pass
2018
Fail
52.3
86
Pass
Momentive (formerly Hexion)
NC0003395/002
County: Columbus
Ceri7dPF
Begin:
9/1/2007 Chr Lim: 4.7%
NonComp:
J
F
M
A
M
2014
Pass
Pa
2015
Pass
Pa
2016
Pass
Pa
2017
Pass
Pa
2018
H
F
Region: WSRO
7Q10:
J
Pass
Fail
Fail
Pass
Pass
Basin:
NEU13
Mar Jun Sep Dec
SOC JOC:
PF:
IWC:
NA Freq: Q
Pass
A
S O
N
D
D
>74
Pass -
SOC JOC:
Pass
N
D
Pass
Pass
Pass
Pass
H
Pass
Pass
Pass
Basin:
FRB02
Feb May Aug Nov
SOC JOC:
PF:
IWC:
Freq: Q
A
S O
N
D
Pass
-
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Basin: YAD06 Mar Jun Sep Dec
PF: IWC: Freq: Q
J A S O
Pass -
Pass
Pass Pass
Pass
Region: WSRO Basin: YAD05 Jan Apr Jul Oct
7Q10: 2.54 PF: 0.98 IWC: 37.5 Freq: Q
l J A S O
Pass Pass
Pass Pass Pass
Pass Fail
Pass Pass
Region: WIRO Basin: CPF17 Feb May Aug Nov
7Q10: PF: IWC: Freq: Q
J J A S O
Pass -
Pass
Pass
H
Leeend: P= Fathead minnow (Pimohales oromelas). H=No Flow (facility is active). s = Split test between Certified Labs Page 74 of 125
SOC JOC:
N
D
Fail
Fail
Pass
Pass
SOC JOC:
N
D
>74
>74
SOC JOC:
N
D
Pass
Pass
Pass
H

Table 1
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1 Q10s (cfs)
Saltwater RPA 95% Probablity/95% Confidence
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
ect Information Table 2. Parameters of Concern
❑CHECK IF HQW OR ORW WQS
Pamlico County - Millpond WTP
PC -1
NCO088340
001
0.221
UT to North Prong Bay River
SC;Sw,NSW
Tidal, IWC = 100%
Wr Tidal, IWC = 100%
Tidal, IWC = 100%
Tidal, IWC = 100%
ML Tidal, IWC = 100%
Data Source(s) BIMS parameter data Nov2016 to Jun2018; BIMS
flow data Nov2015 to Mar2018
Saltwater streams are tidal resulting in all IWC % = 100%.
If an approved model is conducted then a chronic dilution
factor is determined and can be applied to a discharge to
calculate its IWC % . If a stream is classified as a SA or
ORINthen its is also classified as a HQ W. The appropriate
IWC % must be defined to properly calculate WQS-based
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Name WQs Type Chronic Modifier Acute PQL Units
Arsenic
Aquatic Life
C
36
SW
69
ug/L
Arsenic
Human Health
C
10
HH
ug/L
Cadmium
Aquatic Life
NC
8.9
SW
40.2
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
10
ug/L
Chromium VI
Aquatic Life
NC
50.4
SW
1107.8
ug/L
Chromium, Total
Aquatic Life
NC
N/A
SW
N/A
ug/L
Copper
Aquatic Life
NC
3.7
SW
5.8
2
ug/L
Cyanide
Aquatic Life
NC
1
SW
1
10
ug/L
Lead
Aquatic Life
NC
8.5
SW
220.8
2
ug/L
Mercury
Aquatic Life
NC
25
SW
0.5
ng/L
Molybdenum
Human Health
NC
2.0
HH
mg/L
Nickel
Aquatic Life
NC
8.3
SW
74.7
ug/L
Selenium
Aquatic Life
NC
71
SW
ug/L
Silver
Aquatic Life
NC
0.1
SW
2.2
ug/L
Zinc
Aquatic Life
NC
85.6
SW
95.1
10
ug/L
NOTE: The aquatic life chronic and acute WQS for several metals are calculated based on EPA conversion factors,
see "Diss. SW stds. As TM" for more details and summary of calculated WQS..
NCO088340 9595 SALTWATER RPA w_diss factors 20167a,input
10/1/2018

REASONABLE POTENTIAL ANALYSIS - DATA
Par07
Par15
Use "PASTE SPECIAL
Use "PASTE SPECIAL
Copper
Values" then "COPY"
Zinc
Values" then "COPY"
. Maximum data
. Maximum data
points = 58
points = 58
Date
Data
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
1
11/3/2016
<
10
5
Std Dev.
0.0000
1
11/3/2016
28
28
Std Dev.
15.5539
2
12/8/2016
<
10
5
Mean
5.0000
2
12/8/2016
25
25
Mean
28.1500
3
1/5/2017
<
10
5
C.V.
0.0000
3
1/5/2017
28
28
C.V.
0.5525
4
2/9/2017
<
10
5
n
20
4
2/9/2017
37
37
n
20
5
3/9/2017
<
10
5
5
3/9/2017
24
24
6
4/6/2017
<
10
5
Mult Factor =
1.0000
6
4/6/2017
73
73
Mult Factor =
1.3400
7
5/4/2017
<
10
5
Max. Value
5.00 ug/L
7
5/4/2017
14
14
Max. Value
73.0 ug/L
8
6/8/2017
<
10
5
Max. Fred Cw
O DETECTS ug/L
8
6/8/2017
37
37
Max. Fred Cw
97.8 ug/L
9
7/6/2017
<
10
5
9
7/6/2017
26
26
10
8/10/2017
<
10
5
10
8/10/2017
59
59
11
9/14/2017
<
10
5
11
9/14/2017
26
26
12
10/12/2017
<
10
5
12
10/12/2017
15
15
13
11/2/2017
<
10
5
13
11/2/2017
24
24
14
12/7/2017
<
10
5
14
12/7/2017
20
20
15
1/11/2018
<
10
5
15
1/11/2018
18
18
16
2/8/2018
<
10
5
16
2/8/2018
12
12
17
3/8/2018
<
10
5
17
3/8/2018
37
37
18
4/12/2018
<
10
5
18
4/12/2018
14
14
19
5/10/2018
<
10
5
19
5/10/2018
35
35
20
6/7/2018
<
10
5
20
6/7/2018
11
11
21
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
NCO088340 9595 SALTWATER RPA w_diss factors 20167a,data
Date}

Pamlico County - Millpond WTP Outfall 001
NCO088340 Saltwater RPA 95% Probablity/95% Confidence Qw = 0.22106667 MGD
MAXIMUM DATA POINTS = 58
Qw (MGD) = 0.22 WWTP/WTP Class: PC -1
1Q10S (cfs)= Tidal, IWC = 100% IWC% @ 1Q10S = 100
7QIOS (cfs)= Tidal, IWC = 100% IWC% @ 7Q10S= 100
7QIOW (cfs) = Tidal, IWC = 100% IWC% @ 7Q10W = 100
30Q2 (cfs) = Tidal, IWC = 100% IWC% @ 30Q2 = 100
Avg. Stream Flow, QA (cfs) = Tidal, IWC = 100% IWC% @ QA = 100
Receiving Stream: UT to North Prong Bay River Stream Class: SC;Sw,NSW
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
(PE
a
z
RECOMMENDED ACTION
Applied
Chronic Acute
n # Det. Max Pred Cw Allowable Cw
Standard
Acute: 5.80
No detects; Allowable Cw < MDL> PQL; -
Copper
NC
3.7 SW(7QIOs) 5.8
2.0
ug/L
20 0
VO DETECTS_
_ _ _ _ _ _ _
maintain_monitoring_ _
ronic: 3.70
_
N
Cho detects; Allowable Cw < MDL> PQL
Max MDL = 10
maintain monitoring
Acute: 95.1
RP shown - apply Monthly Monitoring with
Zinc
NC
85.6 SW(7Q10s) 95.1
10.0
ug/L
20 20
97.82
Limit_
_ _ _ _ _ _ _ _
Chronic: 85.6
_ _ _ _ _ —M_ _ _
RP shown - apply Monthly Monitoring with
No value > Allowable Cw
Limit
NCO088340 9595 SALTWATER RPA w_diss factors 20167a,rpa
Page 3 of 4 10/1/2018

Saltwater - Total Recoverable Metal Standards for Aquatic Life Protection
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.
Table 1. NC 2007-2015 Triennial Review Dissolved Metals Water Quality Standards converted to Total Recoverable Metals For Aquatic Life Protection
1
Parameter
Acute SW, ug/l
(Dissolved)
Chronic SW, ug/l
(Dissolved)
EPA Conversion Factors for
Dissolved Metal S2
Acute SW, ug/1
Chronic SW, ug/1
Saltwater CMC
(Acute)
Saltwater CCC
(chronic)
(Total Metal)
(Total Metal)
Arsenic
69
36
1
1
69
36
Cadmium
40
8.8
0.994
0.994
40.2
8.9
Chromium VI
1100
50
0.993
0.993
1107.8
50.4
Copper
4.8
3.1
0.83
0.83
5.8
3.7
Lead
210
8.1
0.951
0.951
220.8
8.5
Nickel
74
8.2
0.99
0.99
74.7
8.3
Silver
1.9
0.1
0.85
—
2.2
Zinc
90
81
0.946
0.946
95.1
85.6
Table 1 Notes:
1. SW= Saltwater
2. EPA Conversion Factors from US EPA website, National Recommended Water Quality Criteria - Aquatic Life Criteria Table;
https://www.epa.gov/wqc/national-recom mended -water -quality -criteria -aquatic -I ife-criteria-table#a
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.

Board of Commissioners
Chairman
Edward Riggs Jr.
Township #3
Vice -Chairman
Paul Delamar
At Large
Ann Holton
At Large
Pat Prescott
Township #1
Candy Bohmert
Township #2
Carl 011ison
Township #4
Missy Baskervill
Township #5
July 27, 2018
COUNTY OF PAMLICO
POST OFFICE BOX 776
BAYBORO, NORTH CAROLINA
28515
[phone] / 745-5195
FAX [phone]
Mr. Derek Denard
NC DEQ / DWQ — NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
County Manager
Timothy A Buck
Clerk to the Board
Courtney L. Norfleet
County Attorney
Jimmie B. Hicks, Jr.
RECEIVED/DENR/DWR
JUL 31 2018
Water Resources
Permitting Section
RE: Pamlico County Millpond WTP \ Renewal of NPDES Discharge Permit NC
0088340
COMMENT from the PAMLICO COUNTY for DRAFT NPDES PERMIT NCO088340
Dear Mr. Denard:
We received our copy of the Draft NPDES Permit NCO088340 and cover letter
dated June 27, 2018 with nine bullets summarizing the changes proposed for the
above -referenced NPDES Permit. The subsequent review included input from
Jeff Sanders, WTP-ORC and Operations Manager, and our consulting engineer
— Rivers & Associates. As we compare the current permit to the draft permit in
light of the capabilities of our existing WTP, we ask for consideration of
comments and requests regarding the draft permit that follow.
The water treatment plant operation is unchanged and records of monitoring over
the past three years demonstrate that it should not be restricted to additional
limits than those required by the current permit. Enclosed are DMRs for the past
20 months. Additionally, we have included information from the EPA's Echo
website for your review (https:Hecho.epa.gov/effluent-charts).
Pamlico County is an Equal Opportunity Employer and Provider

The sixth bullet in the cover letter states that "A reasonable potential analysis of
data indicated that limits are needed for Total Zinc based [on] the new dissolved
metal standards." The DMRs show that Total Zinc has consistently been less
than 40 micrograms per liter (ug/1) with only two (2) of the 38 most recent test
results having Total Zinc greater than 40 ug/I, but less than 75. All test results are
less than the proposed Monthly Average and Daily Maximum Limits. We
respectfully request your office review the available data, and confirm this
requirement is applicable.
Please call if you have any questions.
Sincere[v,
Bill Fentress, Finance Director/Assistant County Manager
Pamlico County
enclosure
cc: Jeff Sanders, WTPs ORC
Tim Buck, County Manager
Blaine Humphrey, P.E., Rivers and Associates
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. 12/27/2014 7/15/2015 1/31/2016 8/18/201* 3/6/2017 9/22/2017 4/10/2018 10/27/2018
. Date /

STATE OFNORTH CAROLINA
COUNTYOFPAMLICO
AFFIDAVIT OF PUBLICATION
Before the undersigned, a person duly commissioned,
qualified and authorized by law to administer oaths, personally
appeared to Deborah Dickinson, who after being first sworn,
deposes and says she is the Business Manager for THE
PAMLICO NEWS, a newspaper published, issued and
entered as second class mail in the Town of Oriental in
said county and state, and that notice or other legal
advertisement, a true copy of which is attached hereto,
was published in THE PAMLICO NEWS on the following dates
And that said newspaper in which such notice, paper,
document or legal advertisement was published was at the
time of each and every publication, a newspaper meeting
all of the requirements and qualifications of Chapter 1,
Section 597 of the General Statutes of North Carolina and
was a qualified newspaper within the meaning of Chapter
1, Section 597 of the General Statutes of North Carolina.
This U day of -TU L.q 2018
12ARL&n County, North Carolina
Sworn to and subscribed before me this day by
BUSINESS MANAGER
Date: --I ! 9 / f d
.••`••-V I -E E",
••�5�. "
....... ��° lC.��-� Gee myw, , Notary Public
U: ;Z,
'a AIJ130G U . My commission expires:
7
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ra�jiico News
'
WEMESDAY, JULY 4, 2018
agreater risk. In any -case, it's important that
risk tolerance and use it as a guideline for
voices = so it's definitely -an issue to discuss
advisor.
is in my life affect my investment strategy?
j. Over time, you may experience any num-
such as'itiarriage, children, new jobs and so
'with your financial advisor; you will want to
if changes, because they can affect your long-
aquently, your investment decisions.
forces affecting my investment portfolio?
YOU will wantto create an investment strat-
�our goals, risk tolerance and time horizon.
dbove, you may need to adjust your strategy
your -life. But should you also make changes
Os, such'as interest rate movements, political
on:or news affecting industries in which you
atially? Try not to make long-term investment
:sort -term news. Yet, talk with your financial
your investment portfolio is not out of align-
uternal factors.
ad, other inquiries, you can help yourself stay
arall investment picture and what moves, if
e to keep advancing toward your goals. A
mete to provide you with valuable expertise =
e of it.
Litten by Edward Jones for use by your local
dal Advisor.
County, North. Carolina. Hejoined them,
Fprinciples in question here? Penn was speak-
overnment, that people living in a community
A right to help select those who populate
ita1; instihitions. But his personal freedom to
A a natural right, one that the civil authority
Ove been expressed eloquently in English,
R roots.. The Greek philosopher Aristotle, for
td between two conceptions of liberty: a civic
to rule and be ruled in turn" and a personal
old live as he likes."
;were and are important. And, of course, nei-
6tly defended and advanced, including here
4ie of the Founding, most Americans couldn't
vernments imposed a range of restrictions on .
leans, including the moral outrage of slavery.
Ithe.Americans whose representatives gath-
ln 1:776 were inconsistent in their commit,
i self-government is not to deny the si0fi-
40A that.c1imrt+Pr- Thorn or^ wnm^ rime_flao�.
North Carolina Environmental-Managment CommissionlMES Unit
1617 Mail Service Center
Raleigh, NC 276991617
Notice of Intent to Issue a NPDES Wastewater Permit
The North Carolina -Environmental Management Commis-
sion proposes to issue'a NPDES wastewater discharge permit
to the_person(s) listed below. Wriften comments regarding the
proposed permit will be accepted until 36 clays after the publish
date of this notice. The Director of the NC Division of Water
Resources (DWR) may hold a public hearing should there be -a
significant degree=of public interest. Please mail comments and/
or information requests to DWR at the above address. Inter-
ested persons may visit the DWR at 512 N. Salisbury Street,
Raleigh, NC to review information on .file. Additional informa-
tion on NPDES permits'and this notice may be found on our
website: http://deq.nc.gov/about/divisions/water-resources/
water-resources-permits/wastewater=branch/npdes-wastewater/
public-notices,or by calling [phone]. Pamlico. County.
Water System applied to renew NPDES permit for the Vande-
mere WTP [NCO0883581 discharging filter=backwash wastewa-
ter to Smith Creek, Neuse River Basin, Pamlico County Water
System applled to renew NPDES permit for the Mill Pond WTP
[NCO088340] discharging filter -backwash wastewater to North
Prong Bay diver, Neuse River Basin. Pamlico County Water
System applied to renew NPDES permit for the *Crantsboro
WTP [NC00883231 discharging filter -backwash wastewater
to Beard Creek, Neuse River Basin. Pamlico County Water
System applied to renew NPDES permit for the Kershaw WTP
[NCO088331] discharging filter -backwash wastewater -to Tarkiln
Creek, Neuse River Basin.
BROADsT-
CUSTO l! S-IGNAGE
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