NCC000001_Fact Sheet_20181017

sTwrF
,. ...!!!�, Fact Sheet - NPDES Permit
Neuse River Compliance Association
NORTH CAROLINA
Quality Environmental NPDES No. NCC000001
rrt
CY2019-23 Renewal - DRAFT
October 17,2018
PROPOSED ACTION
The Neuse River Compliance Association and its co-permittee members have applied for renewal
of the NPDES group permit governing their discharge of Total Nitrogen to the Neuse River and its
tributaries.The group made application on June 28,2018.
The Division finds the Association's application to be acceptable and has made a tentative
determination to re-issue the permit without modification.
The Division intends to publish a notice of this determination in the principle newspaper for each
county in the river basin on or about October 19,2018,and will accept comments on the draft
permit for 30 days following publication. After the close of the public comment period,the Division
will consider all significant comments and make its final decision regarding this permit action.
INTRODUCTION
The Neuse River basin was classified as Nutrient Sensitive Waters (NSW) in 1988 due to long-term
nutrient impacts from point,nonpoint,and natural sources of pollution on the river's estuary. In
1994,the Division added the basin to the state's 303(d)list of impaired waters due to exceedance of
the chlorophyll a standard at the estuary.
In December 1997,the Environmental Management Commission adopted the Neuse River Basin
Nutrient Sensitive Waters (NSW) Management Strategy,a rules package designed to address these
nutrient impacts and restore water quality in the basin. The Strategy required that Total Nitrogen
(TN) loads to the estuary (1995 baseline)be reduced by 30 percent by the year 2003.
The Division developed a phased Total Nitrogen TMDL for the basin,based upon the NSW
Management Strategy.The USEPA approved the TMDL in 1999 (Phase I) and 2002(Phase II).
Subsequent 303(d) lists and Integrated Reports have reflected that the TMDLs are being
implemented.
One portion of the NSW Management Strategy,the Wastewater Discharge Requirements rule
(T15A NCAC 2B .0234),establishes specific nutrient control requirements for the point source
dischargers in the basin.
• The rule sets forth a system of Total Nitrogen allocations to achieve the stated 30 percent
reduction in point source loads to the estuary.Toward this end,it:
• sets a wasteload allocation(WLA) of 1.64 million pounds TN per year (at the estuary)for
all point source dischargers in the basin.
• further divides the WLA among the existing dischargers.
• requires that large facilities (those with permitted flows equal to or greater than 500,000
gallons per day) meet TN limits based on their individual TN allocations,beginning in
2003.

Neuse River Compliance Association FACT SHEET
NPDES No. NCC000001 DRAFT NPDES PERMIT
• establishes requirements for new and expanding dischargers
• prescribes how allocations will be handled when permitted facilities consolidate
(regionalise) their wastewater discharges.
• The rule also prescribes Total Phosphorus limits for the most significant dischargers in the
basin.
To provide thedischargers some flexibility in meeting their nitrogen control requirements,the rule
provides that interested dischargers can work collectively to achieve nitrogen reductions.Under
this approach,the dischargers form a group compliance association and obtain a group NPDES
permit. The group permit establishes a group TN limit based on the members' combined TN
allocations.The group limit replaces the TN limits in their individual permits.Otherwise,the group
permit does not affect requirements in the individual permits.
The subject permit is a group compliance permit as described above.It first became effective
January 1,2003,and is the only such permit to be developed under the Strategy's Wastewater
Discharge rule.
PERMIT OVERVIEW
The Neuse River Compliance Association("NRCA," or the"Association") is a not-for-profit
corporation established in North Carolina in 2002.The purpose of the Association is to function as a
"group compliance association" as provided in the Wastewater Discharge rule.
Co-Permittees
The Association's members include both public and private entities,all of which discharge treated
wastewater in the Neuse River basin under existing individual NPDES permits.
The Association and each of its members are co-permittees under the group permit. In general,the
Association serves as the contact between the Division and its co-permittee members in matters
pertaining to this permit.
Scope of the Permit
The group compliance permit governs the combined discharge of Total Nitrogen from the co-
permittees to the estuary. Requirements in this permit supplement those in the co-permittee
members' individual NPDES permits but do not replace the requirements in the individual permits
except where specifically stated.
Each member's individual NPDES permit remains in effect and continues to govern the other
parameters of concern for that discharge.
Organization and Content of the Permit
The Division developed effluent limitations and other special conditions for the original(2002)
group permit based on the Neuse River Basin Nutrient Management Strategy,the approved TN
TMDLs,and extensive deliberations with the USEPA Region 4 and with the affected dischargers.
As with individual NPDES permits,the group permit contains Special Conditions governing
wastewater controls (Part I).However,the content of the group permit is unique:
• Definitions of key terms
• Ground rules and general requirements pertaining to the group compliance approach
• Explanation of group and individual TN limits
• Special reporting requirements

Neuse River Compliance Association FACT SHEET
NPDES No. NCC000001 DRAFT NPDES PERMIT
• Compliance standards and procedures in case of limits violations
The selection of standard and general conditions in the permit(Parts II&III) is also tailored to the
specific needs of the group permit. Many do not actually apply to the Association or its co-
permittee members although they are found in the members'individual permits and do apply
there;they are included in the group permit merely for emphasis or a sense of completeness.
Appendix A of the permit contains the definitive list of(1) Co-Permittee Members in the
Association, (2) discharge and equivalent estuary TN allocations for each member,and (3) transport
factors for each.These values are derived from the allocations assigned in the Wastewater
Discharge rule.
The permit establishes TN limits for the Association and for the individual co-permittee members.
Individual TN limits equal the members' individual,active allocations,and the Association's
Estuary TN Limitation equals the sum total of the members' active allocations.All TN limits in
Appendix A are annual mass limits, are expressed in terms of estuary ('delivered') TN,and apply
on a calendar-year basis.The appendix also notes which allocations (if any) are held in'reserve'
status and are,therefore,not included in the group TN limit.
The Association is subject to its Estuary TN Limitation throughout the term of this permit.
The TN allocations of the co-permittee members can change as the result of purchases,sales,trades,
leases,and other transactions.These changes,in turn,affect the Association's TN allocation.
Changes in membership also affect the Association's allocation due to the addition or subtraction of
the discharger's allocation from the group total.
Whenever changes in the allocations or the membership occur,Appendix A of the permit must be
modified in order to formally incorporate those changes and adjust the enforceable limits in the
permit.
The TN allocations and limits are expressed as calendar year values;therefore, any adjustments can
become effective only at the beginning of the calendar year (January 1)following the transaction or
membership change.The Association will notify the Division each year of proposed changes in
Appendix A (see Reporting Requirements,below).
Co-Permittee Members
Table 1 lists the Association's co-permittee members and facilities.
Appendix A of the permit shows in tabular form the original allocations assigned to each member
facility and any transfers or adjustments. It includes discharge and delivered (estuary) values and
lists reserve allocations separately from active allocations.
The Association also holds the TN allocation originally assigned to Burlington Industries (formerly
NC0001376),which the industry deeded to the Association.
Monitoring Requirements
All members of the Association are required under their individual NPDES permits to monitor TN
on a regular basis and report the results in their Discharge Monitoring Reports (DMRs).The group
permit does not duplicate these monitoring requirements or require additional TN monitoring.
Instream monitoring is not required under this permit. However,it is required of the co-permittee
members through their individual NPDES permits and,for most,is conducted by the Lower Neuse
Basin Association,a coalition of dischargers that,by agreement with the Division,conducts
instream monitoring for its members.

Neuse River Compliance Association FACT SHEET
NPDES No. NCCOOOOO1 DRAFT NPDES PERMIT
Reporting Requirements
Each member will continue to report its TN monitoring results on its individual DMRs. The
Association is not required to duplicate these detailed reports.
Under the current permit,the Association submits year-end,mid-year,and 5-year reports on its
activities to the Division.The year-end report includes an accounting of the Association's and'its
members' TN discharges for the previous calendar year for compliance purposes. It also includes a
list of transactions during that period affecting TN allocations,an assessment of progress made,and
planned activities for the coming year.The mid-year report(due August 31 of each year) includes
an updated accounting of TN discharges for informational purposes. It also identifies any changes
in TN allocations or in membership for the following year and serves as a request to modify
Appendix A to incorporate those changes. The 5-year report is intended to ensure that the Division
and the Association agree on the group and individual allocations at the end of the permit term.
Table X.NRCA Members and Discharge Points
Owner Facility Permit Receiving Stream Outfall Latitude Longitude
1 Town of Apex Apex WRF NC0064050 UT Middle Cr.1 001 35°42'30" -78°50'03"
2 Aqua NC Neuse Colony WWTP NC0064564 Neuse River 001 35°38'44" -78°24'20"
3 Town of Benson Benson WWTP NC0020389 Hannah Cr. 001 35°23'21" -78°30'29"
4 Town of Cary
41 North Cary WRF NC0048879 Crabtree Cr. 001 35°50'16" -78°46'50"
4.2 South Cary WRF NC0065102 Middle Cr. 001 35°38'48" -78°45'28"
5 Town of Clayton Little Creek WWTP NC0025453 Neuse River 001 35°39'59" -78°25'26"
6 Contentnea MSD CMSD WWTP NC0032077 Contentnea Cr. 001 35°21'20" -77°24'58"
7 CWS Systems,Inc. Fairfield Harbour WWTP NC0033111 Neuse River 001 35°03'27' -77°57'33"
8 DuPont-Kinston E.I.DuPont-Kinston WWTP NC0003760 Neuse River 001 35°19'30" -77°28'13.7"
9 Town of Farmville Farmville WWTP NC0029572 Contentnea Cr. 001 35°35'11.3" -77°32'31.1"
10 City of Goldsboro Goldsboro WWTP NC0023949 Neuse River 001 35°20'44" -77°59'59"
002 35°20'14" -77°59'53"
11 City of Havelock Havelock WWTP NC0021253 Neuse River 001 34°57'11" 76°52'37"
12 Johnston County Central Johnston Co.WWTP NC0030716 Neuse River 001 35°30'04" -78°22'32"
13 Town of Kenly Kenly Regional WWTP NC0064891 Little River 001 35°34'58" -78°09'32.6"
14 City of Kinston Kinston Regional WRF NC0024236 Neuse River 001 35°17'15" -77°30'41"
15 Town of LaGrange La Grange WWTP NC0021644 UT Moseley Cr.1 001 35°18'35.4" -77°46'31.2"
16 MCAS-Cherry Point Cherry Point WWTP NC0003816 Neuse River 001 34°57'11" -77°53'13"
17 City of New Bern New Bern WWTP NC0025348 Neuse River 001 35°08'20" -77°03'37"
18 Duke Energy Lee Steam Electric Plant NC0003417 Neuse River 001 35°22'45.3" -78°4'6.46"
19 South Granville WASA SGWASA WWTP NC0026824 Knapp of Reed Cr. 001 36°07'39" -78°47'57"
20 City of Raleigh
20.1 Neuse River WWTP NC0029033 Neuse River 001 35°43'04" -78°29'49"
20.2 Smith Creek WWTP NC0030759 Smith Cr. 001 35°54'23" -78°32'15"
20.3 Little Creek WWTP NC0079316 Little Cr. 001 35°48'57" -78°16'20"
21 City of Wilson Wilson WWTP NC0023906 Contentnea Cr. 001 34°40'37" -77°54'51"
22 Craven County Craven WTP NC0084460 Neuse River 001 35°58'35" 76°56'1"
1 UT=Unnamed Tributary
Compliance
The Association is in compliance with its TN limit when the group does not exceed the Estuary TN
Limitation in Appendix A.

Neuse River Compliance Association FACT SHEET
NPDES No. NCC000001 DRAFT NPDES PERMIT
Members are deemed to be in compliance with their individual TN limits in this permit when the
Association as a whole complies with its Estuary TN Limitation. Individual members of the
Association will be subject to individual TN limits only in those years in which the Association
exceeds its limit.In that case,each co-permittee member is subject to its individual TN limit from
Appendix A.
The Association is required by rule to make offset payments to the Wetlands Restoration Fund for
any calendar year in which it exceeds its TN limit.In addition,the Division may take appropriate
enforcement action against the Association or its co-permittee members or both in the event that
they exceed applicable TN limits in the permit.
The Association has not exceeded its TN limit since its formation. The group's combined nitrogen
reduction has been exemplary,reaching approximately 70% reduction from 1995 baseline levels as
compared to the mandated 30% reduction for point source discharges in the basin.
SUMMARY OF CHANGES
The Association's group TN limit was 1,190,831 lb/yr at the previous permit renewal(CY2014).The
permit has been modified twice since that time.
• Craven County Water Treatment Plant was added as a co-permittee member beginning
with CY2015;the County is leasing allocation from the Association for its new discharge.
• A portion of SGWASA's TN allocation was placed in reserve status beginning with CY2016.
Effective in 2016,the facility became subject to a more stringent TN limit under the Falls
Lake Nutrient Management Strategy. Its active allocation was reduced by 3,618 lb/yr
(estuary load) to match the newer limit. The Association's group cap was reduced by the
same amount,to 1,187,213 lb/yr. Appendix A still includes the reserve allocation,but the
reserve does not count toward the group's TN limit.
For this renewal,the NRCA's group TN limit remains at 1,187,213 lb/yr,and no other changes to
the permit are proposed.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: October 19,2018
End of Comment Period: November 19,2018
Permit Scheduled for Issuance: December 14,2018
Permit Effective Date: January 1,2019
-end of fact sheet-