NC0026441_director's_addendum_20190430

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
LINDA CULPEPPER
Dirrmr
MEMORANDUM
NORTH CAROLINA
Environmental Quality
April 30, 2019
TO: Jeff Poupart
Section Head, Water Quality Permitting Section
FROM: Linda Culpepper C
Director
SUBJECT: Addendum to April 25 Hearing Officer Report
Siler City WWTP, NCO026441
I agree with the approach recommended in the April 25 Hearing Officer report except that it
would allow nitrogen loads from the Siler City W WTP to exceed historic levels.
Historically, Siler City's nitrogen discharge contributed significantly to the deterioration of
water quality in Loves Creek and the Rocky River. This condition led to their being added to the
state's 303(d) list of impaired waters. When the previous poultry facilities ceased operations,
nitrogen loads dropped, and water quality has improved noticeably.
In January, 2019, Mountaire Farms opened a new poultry facility and began discharging process
wastewaters to the Towri s treatment plant. As production increases, the Towri s nitrogen load
will rise substantially and is expected to exceed historic high levels well before Mountaire
Farms reaches full production.
The draft permit includes a nitrogen limit that requires the Town to reduce its load to current
("no poultry") levels by 2023, and the Town has tentatively secured funding for treatment plant
upgrades to meet the limit. To offset increases in nitrogen load in the first 34 years, the permit
also requires the Town to evaluate and optimize its operations. However, we have no guarantee
that this interim measure will be successful.
Allowing the Towri s nitrogen load to rise for the next 3-4 years is less than ideal. Allowing it to
exceed historic levels is not acceptable.
Generally, when a permittee applies to increase its discharge to impaired waters and the
Division has no TMDL or other basis for setting water quality -based limits, we can approve its
flow increase but will hold its pollutant loads at current levels to ensure the added discharge
does not contribute further to the waters' impairment. Although Siler City is not expanding its
discharge beyond its current permitted capacity, we cannot ignore the predicted increases in
nitrogen loads, and it is appropriate to follow this approach to limit the impacts until upgrades
at the Siler City W WTP can be completed.
North Carolina Department of Environmental Quality I Dii-ision of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

Addendum to April 25 Hearing Officer Report
Siler City WWTP, NC0026441
April 29, 2019
Therefore, the Siler City permit should be revised to incorporate the following changes and
submitted for my signature:
• An interim nitrogen limit equivalent to the Towns 2004-2008 nitrogen loads should be
added to Condition A.(1.) of the permit.
• Conditions A.(10.) Compliance Schedule and A.(11.) Treatment Optimization should be
removed. Optimization may still be useful in the Towns nitrogen control efforts, but with
the addition of the interim nitrogen limit, the steps specified in the draft permit no longer
serve a useful purpose.