NC0021636_Fact Sheet_20230727

Fact Sheet
NPDES Permit No. NCO021636
Permit Writer/Email Contact Nick Coco, [e-mail]:
Date: 7/10/2023
Division/Branch: NC Division of Water Resources/NPDES Municipal Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑ Renewal
❑X Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Harnett Regional Water/North Harnett Regional Wastewater Treatment Plant
(WWTP)
Applicant Address:
P.O. Box 1119, Lillington, North Carolina 27546
Facility Address:
607 Edwards Drive, Lillington, North Carolina 27546
Permitted Flow:
7.5 MGD with proposed expansion to 16.5 MGD
Facility Type/Waste:
MAJOR Municipal; 99.8% domestic, 0.2% industrial*
Facility Class:
Grade IV Biological Water Pollution Control System
Treatment Units:
Influent pump station, Aerated flow equalization, Mechanical and manual bar
screens, Grit classifier with auger, Instrumented influent and effluent flow
measurement, Dual oxidation ditches, Three centrifugal blowers, Two
434,000 gallon non -aerated tanks with submersible mixers, Dual clarifiers,
Four traveling bridge tertiary filters and four stainless steel disc filters,
Ultraviolet disinfection facility, Cascade post aeration, Backup generator
facility, Septage receiving station, Lime storage facility, Sludge lagoon
Pretreatment Program (Y/N)
Y
County:
Harnett
Region
Fayetteville
*Based on permitted flows.
Briefly describe the proposed permitting action and facility background.- Harnett Regional Water applied
on April 25, 2022 for an NPDES permit renewal at 7.5 MGD for the North Harnett Regional WWTP,
with a request for a proposed expansion tier at 16.5 MGD. The newly proposed 16.5 MGD expansion
project is receiving funding via the American Rescue Plan Act (ARPA). An Engineering Alternatives
Analysis was submitted with the application. Flow projections and engineering alternatives are discussed
in detail below in Antidegradation Review. This facility serves a population of approximately 47,000
residents, as well as 2 significant industrial users (SIUs), including one categorical industrial user (CIU),
Page 1 of 20

via an approved pretreatment program and one industry under a local permit. Treated domestic and
industrial wastewater is discharged via Outfall 001 into the Cape Fear River, a class WS-IV waterbody in
the Cape Fear River Basin.
The facility was originally purchased from the Town of Lillington in 1999 as a 0.75 MGD facility. Since
that time, the facility has been upgraded from the 0.75 MGD secondary treatment facility to a 7.5 MGD
tertiary treatment facility. The NPDES permit for 7.5 MGD was initially issued on November 1, 2017,
and expired July 31, 2021.
The North Regional WWTP utilizes advanced wastewater treatment processes to treat the wastewater to
tertiary levels including denitrification via anoxic zones in the oxidation ditch for biological nutrient
removal. Recent upgrades at the WWTP included the installation of mixers located in the oxidation ditch
to increase the anoxic zone and the installation of stainless steel mesh, disc filters to supplement the
traveling bridge filters. The new disc filters have the capacity to treat the plant design flow.
The permit reissued in 2017 contained two flow tiers: 5.6 MGD and 7.5 MGD. The Division issued
Authorization to Operate 021636A03 and the facility began discharging under the expanded 7.5 MGD
flow tier in February 2018. In June of 2021, a request was made to the Division for speculative limits for
two flows, 15 MGD and 20 MGD. Speculative limits were provided on October 1, 2021 with limits
provided for the 15 MGD flow only. The Division was unable to develop limits at the 20.0 MGD flow
while holding mass loading constant as the resulting limits may not be achievable on a consistent basis
using current treatment technologies. During the period from the request for speculative limits and the
receipt of speculative limits, the actual expansion requirements for the North facility were determined,
with Harnett Regional Water landing on 16.5 MGD. MBD Consulting Engineers, P.A. (MBD) contacted
the Division on behalf of Harnett Regional Water in December 2021 and requested that a speculative
limits letter be issued based on a total flow of 16.5 MGD. The Division provided speculative limits for the
16.5 MGD flow tier on January 7, 2022.
The proposed improvements to the facility as part of the upgrade to 16.5 MGD include the expansion of
the headworks facility, construction of a new secondary treatment system, expansion of the existing filters
system, expansion of the existing UV system, utilization of the existing post aeration, and installation of a
new sludge digestion and treatment system.
Sludge disposal: Currently sludge is removed from the treatment process and stored in a lagoon adjacent
to the facility. The sludge is removed from the facility currently using a floating dredge that has
capabilities to cross back and forth across the lagoon. Sludge that is removed from the existing lagoon is
transferred to a 600,000-gallon holding tank where it is continuously mixed before being pumped using
rotary lobe pumps to a centrifuge where it is dewatered. The proposed process will include the
modification of the existing secondary treatment process including the oxidation ditch and clarifiers to be
used for sludge handling. The existing oxidation ditches will be used for sludge digestion using a system
that will minimize the phosphorus return to the treatment train. The existing clarifiers will be used for
thickening and sludge holding. Sludge from the clarifier/sludge holding tanks will be transferred via new
rotary lobe pumps directly to the centrifuge for dewatering. Sludge is currently composted at McGill
Composting. Harnett Regional Water has the ability to send sludge to the Sampson County Landfill.
Page 2 of 20

2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 - Cape Fear River
Stream Segment:
18-(16.7)
Stream Classification:
WS-Iv
Drainage Area (m12):
3464a
Summer 7Q10 (cfs)
283a
Winter 7Q10 (cfs):
304a
30Q2 (cfs):
506a
Average Flow (cfs):
3172a
IWC (% effluent):
4.0% at 7.5 MGD; 8.3% at proposed 16.5 MGDa
2022 303(d) listed/parameter:
Not listed
Subject to TMDL/parameter:
Yes- State wide Mercury TMDL implementation
Basin/Sub-basin/HUC:
Cape Fear River/03-06-07/HUC: 03 03 0004
USGS Topo Quad:
F23NE
aBased on updated USGS stream statistics provided on June 23, 2021 (attached).
bThe stream segment of the Cape Fear River is not listed as impaired for any parameter in the 2022 Integrated
Report. However, due to chlorophyll a concerns in the Cape Fear River from nutrient enrichment and low dissolved
oxygen, nutrient criteria development and modeling are currently underway and may affect future permit limits.
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of June 2018 through January 2023.
Table 1. Effluent Data Summary Outfall 001
Parameter
Units
Average
Max
Min
Permit Limit
Flow
MGD
4.8
22.456
2.228
MA 7.5
WA 7.5
BOD summer
mg/l
2.5
12
< 2
MA 5.0
WA 15.0
BOD winter
mg/l
4.2
55
< 2
MA 10.0
WA 3.0
NH3N summer
mg/l
1.0
5.39
< I
MA 1.0
WA 6.0
NH3N winter
mg/l
1.4
14.2
< I
MA 2.0
WA 45.0
TSS
mg/l
2.7
21
0.9
MA 30.0
pH
SU
7.2
7.59
6.53
6.0 > pH < 9.0
(geometric)
(ge an)
Fecal coliform
9/100 ml
673
< 1
WA 400
2
MA 200
DO
mg/l
8.8
11.24
5.94
DA > 5.0
Monitor &
Conductivity
umhos/cm
518
774
222
Report
Monitor &
Temperature
° C
20.3
27
12
Report
TN`
mg/l
/,.7
17.9
1.66
Monitor &
Report
Page 3 of 20

TN Load
lb/mo
6807
13174
4309
Monitor &
Report
TN (summer mass) Load
lb/season
47,002
58,262
37,353
59,968
TP*
mg/l
2.0
5.28
0.07
Monitor &
Report
TP Load
lb/mo
2116
2987
1298
Monitor &
Report
TP (summer mass) Load*
lb/season
14,330
17,491
12,469
19,989
Total Silver
ug/l
< 1
< 1
< I
Monitor &
Report
Monitor &
Total Hardness
mg/l
133
182.4
72
Report
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
* TN and TP effluent concentration monitoring is conducted 3/week in the summer and monthly in the winter. TN
and TP loading limitations are for summer mass loadings.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/l of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): YES
Name of Monitoring Coalition: Middle Cape Fear River Basin Association
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The current permit requires instream monitoring for dissolved oxygen, temperature and
conductivity upstream at the US Highway 401 Bridge and 1.3 miles downstream at the boat ramp. As the
permittee is a member of the Middle Cape Fear River Basin Association (MCFRBA) instream monitoring
requirements are provisionally waived. The nearest upstream MCFRBA monitoring station is B6370000,
located approximately 1 mile upstream of the outfall. The nearest downstream MCFRBA monitoring
station is B6840000, located approximately 10 miles downstream of the outfall. Confluences with
Poorhouse Creek, Buies Creek, Thorntons Creek, the Upper Little River and Juniper Creek, as well as the
outfall for the City of Dunn's water treatment plant (NC0078955) exist between the outfall and
downstream MCFRBA station B6840000. As such, a review of downstream data at B6840000 is not
considered representative of the natural characteristics downstream of the North Harnett Regional
WWTP. Upstream data from January 2017 through June 2022 from B6370000 has been summarized
below in Table 2.
Table 2. Upstream Monitoring Data Summary
Parameter
Units
Upstream
Effluent
Average
Min
Max
Average
Min
Max
Temperature
° C
20.6
32.2
4.4
20.5
27
12
DO
mg
8.1
12.3
5.7
8.7
11.24
5.94
Conductivity
µmhos/cm
140
272
64
516
774
222
Page 4 of 20

Temperature is a parameter of concern for aquatic life. Upstream temperature was greater than 32 degrees
Celsius [per 15A NCAC 02B .0211 (18)] on one occasion during the period reviewed. Effluent
temperature did not appear to differ significantly from upstream temperature.
Dissolved oxygen is a parameter of concern for aquatic life. Upstream DO did not drop below 5 mg/L
[per 15A NCAC 02B .0211 (6)] during the period reviewed.
As the facility receives influent flow from several industrial users via an approved pretreatment program,
instream conductivity is tracked. Effluent conductivity was observed at levels higher than the upstream
sampling location during the period reviewed.
Based on discussions with the Division's Basin Planning Branch, instream monitoring for TP, TKN,
NO2+NO3, and ammonia have been added to the permit at a monthly frequency. As the facility is
pursuing expansion that would over double its capacity, tracking downstream impact is critical. As such,
the provisional waiver for instream monitoring downstream of the facility has been revised and is only
applicable if the MCFRBA activates a downstream station and collects samples. Downstream sampling is
to be conducted by Harnett Regional Water in the event that MCFRBA not activate a downstream station.
Downstream sampling should be conducted at Wildlife Road, approximately 1.5 miles downstream of the
outfall.
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported three
weekly average BOD5 exceedances, one weekly average ammonia exceedance and one monthly average
ammonia exceedance, each resulting in enforcement cases in 2018. In 2019, the facility reported two
weekly average BOD exceedances and one monthly average BOD exceedance, and two weekly average
ammonia exceedances and one monthly average ammonia exceedance, each resulting in a notice of
violation (NOV). The facility reported one weekly average BOD5 exceedance, one monthly average BOD
exceedance, one weekly geomean fecal coliform exceedance, two monthly average flow exceedances, one
weekly average ammonia exceedance and one monthly average ammonia exceedance, each resulting in an
enforcement case in 2021.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 21 of 21 quarterly chronic toxicity tests, as well as all 5 second species
chronic toxicity tests conducted from January 2018 to October 2022. The facility conducted chronic
toxicity testing at 1.6% effluent based on the 5.6 MGD flow through their April 2018 testing. However, as
the facility had begun operating at the 7.5 MGD flow tier in February 2018, this test should have been
conducted using the 2.1% effluent specified in the permit. Harnett Regional Water began conducting
toxicity testing at 2.1% effluent in the following quarter (July 2018), which resulted in a pass, and has
conducted their necessary testing at the appropriate percent effluent since.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in February 2020 reported that the facility was compliant. The last pretreatment inspection conducted in
July 2021 reported that the facility was compliant.
Page 5 of 20

6. Water Quality -Based Effluent Limitations (WQBELs)
The Division provided speculative limits for the 16.5 MGD expanded flow tier on January 7, 2022. These
limits, shown below, are proposed to be implemented in the permit.
Table 3. Speculative Limits for 16.5 MGD Expansion Tier
Effluent Characteristic
Effluent Limitations
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
1 .5 MGD
BOD5
2.1 m /L
3_ 1 m /L
NHS as N (Apr. -Oct.)
0.5 m F/I_
L5 m /l_
NH3 as N (Nov, -Mar.)
0.9 in ,'L
1 2.7 in /L
Dissolved Oxygen
minimurn daily average)
>5.0 mg/L
Total Nitrogen Load
(Apr. -Oct.)
59,968 lbslseason
Taal Phosphorus Load
A .-Oct.
19,9 Ibs/sea n
TSS
15 mgAL
22.5 rn L
TRC
28 pgfL
Fecal coil -form
(geometric mean
21 / 100 rnL
/ 100 rnL
Chronic Toxicity
Pass/Fail Quarter] test
7.5%
Please note that percent effluent at which chronic toxicity testing shall be conducted as identified in the
January 7, 2022 letter has not been adopted. More information regarding the 16.5 MGD expanded flow
tier chronic toxicity testing requirement may be found below in Toxicity Testing Requirements.
Dilution and MixingZones
ones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed.- The current permit
limitations for BOD at the 7.5 MGD flow tier are based on a 2008 revised Qual2E model. No changes are
proposed for the 7.5 MGD flow tier BOD limits.
Page 6 of 20

With current modeling of the Cape Fear River underway, no new models are being evaluated to develop
limits for facilities in the modeled segments. Therefore, mass -loading of oxygen consuming wastes have
been frozen based on current permit limits for the proposed 16.5 MGD expanded flow tier resulting in
monthly average and weekly average BOD limits of 2.1 mg/L and 3.1 mg/L, respectively. These limits
can be re-evaluated once current modeling is finished. These limits are expected to require advanced
treatment technologies.
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1(summer) and 1.8 mg/1(winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1(acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: The permit does
not currently set limits or monitoring requirements for TRC due to the facility employing UV treatment
for disinfection. However, in the event of an emergency where chlorination is required as a backup or
temporary means of disinfection at the facility, a TRC limit and monitoring requirement have been added
to the permit based on the review in the attached WLA spreadsheet. Please note that TRC monitoring is
only required in the event that chlorine is used at the plant and as part of the regular Effluent Pollutant
Scans.
The current permit limitations for ammonia at the 7.5 MGD flow tier are based on a 2008 revised Qual2E
model. No changes are proposed for the 7.5 MGD flow tier ammonia limits. The 7.5 MGD flow tier
ammonia limits have been reviewed in the attached WLA for toxicity and have been found to be
protective. No changes are proposed.
With current modeling of the Cape Fear River underway, no new models are being evaluated to develop
limits for facilities in the modeled segments. Therefore, mass -loading of oxygen consuming wastes have
been frozen based on current permit limits for the proposed 16.5 MGD expanded flow tier. This results in
monthly average and weekly average summer ammonia limits of 0.5 mg/L and 1.5 mg/L, respectively,
and monthly average and weekly average winter ammonia limits of 0.9 mg/L and 2.7 mg/L, respectively.
These limits can be re-evaluated once current modeling is finished. These limits are expected to require
advanced treatment technologies.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
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 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 213.0206. 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 June 2018 and
January 2023. Pollutants of concern included toxicants with positive detections and associated water
Page 7 of 20

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: None
• 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: None
• 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: Total Arsenic, Total Cadmium, Total Chromium, Total Copper, Total Lead, Total
Molybdenum, Total Nickel, Total Selenium, Total Silver, Total Zinc, Nitrate
• POTW Effluent Pollutant Scan Review: Four effluent pollutant scans (2017, 2018, 2019 and
2020) were evaluated for additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: None
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: None
o 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: Total
Beryllium, Total Cyanide
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
As this facility discharges to WS-IV waters, analysis of the parameters listed in 15A NCAC 02B .0216
was conducted. No chlorinated phenolic compound was reported as detected in the effluent pollutant
scans. Total dissolved residue was not reported at levels greater than 500 mg/L in the effluent pollutant
scans. Effluent hardness was greater than 100 mg/L on 57 occasions during the period reviewed. Average
upstream hardness data from MCFRBA monitoring station B6370000 from January 2017 through June
2022 was reported as 29.3 mg/L (range 20 mg/L — 44 mg/L). While effluent hardness is generally higher
than the standard listed for WS-IV surface waters in 15A NCAC 02B .0216, combined hardness, as
calculated in the attached RPA, is considerably lower than the standard. As such, it does not appear that
effluent hardness is influencing the hardness of the stream to an extent where excursions above the stream
hardness standard would be observed.
Toxicitv Testina Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Major POTW, chronic WET testing will continue
on a quarterly frequency. However, based on updated stream statistics provided by USGS, the percent
effluent specified for the 7.5 MGD toxicity testing has been revised from 2.1% effluent to 4.0% effluent.
Page 8 of 20

Additionally, while the 2022 speculative limits propose chronic toxicity testing be conducted at 7.5%
effluent for the 16.5 MGD expanded flow tier, based on the instream wastewater concentration percentage
at the summer 7Q10, chronic toxicity testing shall be conducted at 8.3% effluent at the 16.5 MGD
expanded flow tier. Chronic toxicity testing shall be conducted during the months of January, April, July
and October for both flow tiers.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1
Table 4. Mercury Effluent Data Summary
2018
2019
2020
2021
2022
2023
# of Samples
2
4
4
4
4
1
Annual Average Conc. n /L
0.5
0.7
1.5
0.95
1.175
0.5
Maximum Conc., n /L
0.5
1.1
3.9
2.3
2.4
0.5
TBEL, n /L
47
WQBEL, n /L
304.13 g 7.5 MGD & 144.79 g 16.5 MGD
Describe proposed permit actions based on mercury evaluation: Since no annual average mercury
concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury
limit is required. Since the facility is > 2.0 MGD and reported quantifiable levels of mercury (> 1 ng/1),
the mercury minimization plan (MMP) condition has been maintained.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TNDDLs/Nutrient Management Strategies and their implementation
within this permit: The Division is continuing to work towards the development of a nutrient
management strategy, permitting strategy, TMDL, and/or criteria for nutrients in the Cape Fear River
Basin. Strategies were implemented in the current permit based on the 2005 Cape Fear River Basinwide
Water Quality Plan, which addresses nutrients and oxygen -demanding wastewater discharges in this
basin, and includes monitoring and reporting of total nitrogen (TN), monthly mass TN load, total
phosphorous (TP) and monthly mass TP load. In addition, new summer (April -October) TN and TP
seasonal load limits were calculated and implemented in the current limit based on allowable
concentrations of 6 mg/1 TN and 2 mg/1 TP, resulting in summer mass limits of 59,968 lbs for TN and
19,989 lbs for TP. To address nutrients load limits for the previous expansion to 7.5 MGD, the Division
froze the summer TN and TP mass load limits for this expansion, which resulted in the equivalent
concentration of TN of 4.48 mg/1 and of TP of 1.49 mg/l.
On January 31, 2023, Harnett Regional Water submitted a letter (attached) to the Division requesting a
transfer of 55,582 lbs/year of total nitrogen loading and 18,525 lbs/year of total phosphorous loading from
the South Harnett Regional WWTP (NC0088366) to the North Harnett Regional WWTP to accommodate
for the increase in treated flow at the North Harnett Regional WWTP. The proposed transfer of loading is
summarized below in Table 5.
Page 9 of 20

Table 5. Nutrient Transfer Request
TM
TP
FLOW
N
CURRENT
PROPOSED
CURRENT
PROPOSED
NORTH
16-5 M6 D
52.4%
59,968 L65
115,550 LBS
191989 LBS
38,517 LBS
SOUTH
15-0 MGO
47.6%
160.628 LBS
165,046 LBS
53 543 L55
35 015 LOS
TOTAL
31.5 MGD
1.000
220,596 Le$
220.596 LRS
73,532 LBS
73532 LBS
The transfer of loading has been included in the permit as effective upon expansion to the 16.5 MGD flow
tier. NCO088366 is up for renewal and will be issued with the same effective date so that the nutrient
loading transfer is completed with this renewal.
The permit will be reopened if the Division requires additional monitoring or limitations to support its
water quality protection and restoration efforts in the Cape Fear River Basin.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: In 2019, based on the
EPA's Third Unregulated Contaminant Monitoring Rule indicating elevated concentrations of PFAS and
1,4-dioxane in the Cape Fear River Basin, the Division required facilities in the basin with pretreatment
programs to conduct investigative monitoring of their influents for PFAS and 1,4-dioxane.
Harnett Regional Water participated in this investigation and found the presence of PFAS in their North
Harnett Regional WWTP influent samples. As such, monitoring of PFAS chemicals will be added to the
permit at a frequency of quarterly. Since an EPA method for sampling and analyzing PFAS in wastewater
is not currently available, the PFAS sampling requirement in the Permit includes a compliance schedule
which delays the effective date of this requirement until the first full calendar quarter beginning 6 months
after EPA has a final wastewater method in 40 CFR136 published in the Federal Register. This date may
be extended upon request and if there are no NC -certified labs.
Harnett Regional Water also found the presence of 1,4-dioxane in their North Harnett Regional WWTP
influent samples, with a maximum reported influent concentration of 11.7 µg/L. As only 3 influent
samples from 2019 are available for this parameter, further investigation into the concentrations of 1,4-
dioxane present in the facility's effluent is required to better characterize the waste. Influent concentration
is anticipated to reflect effluent concentrations based on existing components at the treatment facility. As
the maximum reported influent concentration of 1,4-dioxane was observed at a concentration greater than
10 µg/L but less than 35 µg/L, and the facility discharges to WS waters, this facility is considered Action
Level Tier 3 based on the 2022 DWR NPDES Strategy for 1,4-dioxane. As such, Monthly monitoring has
been added to the permit. Please note that chronic allowable discharge concentrations have been
calculated for this facility's two effluent flow tiers based on a 1 X 10-6 risk level Instream Target Value
(ITV) for water supply waters of 0.35 µg/L and an annual average flow (AAF) of 3172 cfs. These
calculations resulted in chronic allowable discharge concentrations of 95.8 µg/L and 43.7 µg/L for the 7.5
MGD and 16.5 MGD flow tiers, respectively. Limits may be necessary after effluent data is collected and
a reasonable potential analysis is conducted. As such, a 1,4-dioxane reopener condition has been added to
the permit.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H 0107( c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA
Page 10 of 20

If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Municipals (if not applicable, delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/1
BODS/TSS for Monthly Average, and 45 mg/l for BODS/TSS for Weekly Average). YES
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BODS/TSS included in the permit? YES
If NO, provide a justification (e.g., waste stabilization pond). NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: The proposed expansion is funded via the
American Rescue Plan Act (ARPA) and is not subject to review under the National Environmental Policy
Act (NEPA). As this project is not receiving more than $10 million in funds at this time, the State
Environmental Policy Act (SEPA) does not apply.
An Engineer's Alternatives Analysis (EAA) was submitted by MBD Consulting Engineers, P.A. (MBD),
the consulting firm hired by Harnett Regional Water (HRW), on April 25, 2022. In their EAA, MBD
noted that Harnett Regional Water has contractual agreements with three municipal systems for treatment
of wastewater at the North Harnett Regional WWTP including Fuquay-Varina, Angier, and Lillington.
MBD provides background information related to the flows tributary to the facility from these contracts:
The North Regional WWTP began with the acquisition of the existing Lillington WWTP and has
expanded through growth in the HRW service area and through agreements for capacity in the
collection and treatment system from the municipal partners. To address the need for wastewater
treatment capacity, HRW constructed the 5.6 MGD North Regional WWTP adjacent to the
existing facility, and then expanded the facility to 7.5 MGD in 2017 to accommodate the
completion of a 20-inch force main that resulted in the addition of flows from the Town of Erwin
and the Swift Industrial WWTP. The role and capacity of each of the participants in the system is
discussed below.
In 1999, HRW purchased the existing Lillington WWTP from the Town. At that time, the facility
had a capacity of 0.75 MGD. Included with the treatment facility was the 52-acre site, providing
area for future expansions. In exchange for the WWTP and the 52-acre site, the Town of
Lillington received 1.2 MGD in capacity in the new WWTP and sewer revenue credits.
In 2000, Fuquay-Varina and Harnett County agreed to the joint construction of the
Harnett/Fuquay-Varina wastewater interceptor following Kenneth/Neills Creek to a new regional
5.6 MGD WWTP. At that time, Fuquay-Varina purchased 2.6 MGD of capacity in the new
wastewater treatment facility.
In 2006, the Town of Angier agreed to purchase 1.08 MGD of wastewater capacity in the plant
and 1 MGD of transmission capacity in the wastewater interceptor line. HRW and Angier also
Page 11 of 20

agreed to jointly participate in the construction of a wastewater transmission line along
Chalybeate Springs Road. Angier extended the line to Highway 55, near the Wake County line.
• MBD notes that the towns of Lillington, Fuquay-Varina and Angier have each requested
additional flows be added to their contractual agreements with Harnett Regional Water for the
North Harnett Regional WWTP (see attached requests).
In their EAA, MBD noted that based on data from the NC Office of State Budget and Management
(OSBM), Harnett County grew at a rate of 16.4% from April 1, 2010 to April 1, 2020. MBD has noted the
belief that growth experienced in this area was impacted by the growth in the neighboring Wake County,
which grew at a rate of 38% in the same period.
Based on a 20-year growth projection at 16.4%, MBD projects the population of Harnett County will
increase by over 47,000 residents by 2042. MBD also notes that it is anticipated that the majority of
growth experienced will occur in planned communities that provide water and sewer service. MBD
assumed that 40% of the population growth will occur in the northern Harnett Regional Water service
area, handled by the North Harnett Regional WWTP, and projects that based on a household population
of 2.3 residents per service, the service area will likely expand by at least 8,000 connections.
MBD provides a snapshot of estimated flow projections for Fuquay-Varina, Lillington, Angier, and
Harnett Regional Water, including current contracted capacity in the North Regional WWTP facility and
the requested additional allocation in the WWTP, in the table below.
NORTH HAR'ti ETT 1111117P
CURRENT USAGE AND NEED
PARTNER/SYSTEM
CURRENT
CAPACITY
CURRENT
USAGE
COMMITITEI]
NOT YET
TRIBUTARY
TOTAL USAGE
PLUS
COMMITTED
FUQUAY-VARINA
2.60 MOD
1.50 MGD
0.65 MGD
2.15 MGD
LILLINGTON
1.20 MOD
0.85 MGD
0.02 MGD
0.87 MGD
ANGIER
1.08 MOD
0.75 MGD
0.55 MGD
1.30 MGD
HARNETT REGIONAL
WATER
2.62 MOD
2.50 MGD
0.50 MGD
3.00 MGD
TOTAL.
7.501IGD
5.60 XIGD
1.72 -IIGD
7.32 -%IGD
NORTH HAR. ETT AN7%111`TP
C t-RRE T AND REQUIRED CAPACITY
PARTNER/SYSTEM
CURRENT
CAPACITY
REQUESTED
ALLOCATION
TOTAL
CAPACITY
FU UA-VARINA
2_0 MGD
3.40 MOD
6.00 MGD
T.Tf,T NGTON
1.20 MOD
0.50 MGD
1.70 MOD
ANGLER
1.08 MGD
1.25 MGD
2.33 MGD
HARETT REc_TIc=�N L
WATER
2_2 MGD
3.85 MGD
6.47 MGD
TOTAL
7.50 -I-IGD
9.00 -1TOI)
16.50 ST D
Page 12 of 20

NC OSBM population growth data was reviewed by Division staff to accompany the submitted
information. Review of Harnett County echoed the population growth of 16.6% indicated by MBD.
Review of population growth from April 2010 to April 2020 for the Towns of Lillington (48.5%), Angier
(9.2%), and Fuquay-Varina (89.2%) reported significant growth. The NC OSBM projects the population
of Harnett County to reach approximately 182,000 residents by 2040, representing a roughly 36% growth
rate from 2020 (134,000 residents). Based on the existing 7.5 MGD flow tier, and the projected growth of
service population, a flow rate of 70 gallons per person per day, and a 15% reserve flow for potential
industrial and commercial users, the Division concurs with the proposal of a facility upgrade to 16.5
MGD.
The following alternatives were evaluated for the proposed discharge:
Alternative Description
20-year Net Present Value'
Connection to an Existing
WWTP
$92,000,000
Land Application
$106,000,000
Wastewater Reuse
Deemed infeasible
Surface Discharge NPDES
$65,000,000
Combination of Alternatives
$98,000,000
*Shown costs do not include operation and maintenance costs provided in the analysis — based on 2022 estimates
Connection to an Existing WWTP: The alternative of connecting to an existing WWTP for treatment
would require the construction of a new raw sewage pump station and force main to transfer the untreated
wastewater from the North Regional WWTP to another treatment plant for treatment and disposal. There
are two systems downstream from the North Regional WWTP that have discharges into the Cape Fear
Basin: the HRW South Regional WWTP and the two City of Fayetteville WWTPs (Cross Creek WWTP
and Rockfish Creek WWTP). In order to transfer flow to either of these facilities, an additional pipeline
would need to be constructed and additional capacity would be required in the treatment facilities.
The closest plant and most likely facility to receive flow from the North facility would be the HRW South
Regional WWTP. The South Regional WWTP is a 15 MGD facility that serves southern Harnett County
along the border with Cumberland County and also provides wastewater treatment for Fort Liberty. The
15 MGD capacity is committed to existing systems including 10 MGD dedicated to Fort Bragg. Any
additional flow would require an expansion of the NPDES permit and a capital expansion of the WWTP.
Two evaluations were performed including an expansion of 5 MGD (or roughly half the flow needed) and
an expansion of 10 MGD to accommodate the two options for addressing the additional flows from the
North facility. Evaluation of expansion of the South Regional WWTP by 5 MGD is discussed below in
Combination of Alternatives. The construction cost to upgrade the South Regional WWTP to accept a
flow of 9 MGD would be approximately $55 million. The construction cost for the pump station and
pipeline to transfer up to 4.5 MGD of flow to the South facility would be approximately $28 million. The
total cost for transferring 9.0 MGD from the North Regional WWTP to the South Regional WWTP for
treatment and discharge would be approximately $87 million not including all soft costs.
Land Application: Harnett Regional Water previously utilized a portion of the existing WWTP site for
land application of treated wastewater. The permit has since been rescinded but the loading rates for the
site provide useful data in discussing this option. The previous site was approximately 8 acres and the
permit allowed for the application of up to 20,000 gpd of treated wastewater. This equated to
approximately 2,500 gpd of discharge per acre of available land or a discharge rate of 0.65 inches per acre
per week. Based on a 0.65 inches per acre per week application rate, the application of 9 MGD would
Page 13 of 20

require approximately 3,600 acres not including buffers. Thirty days of storage for wet periods would also
be required. Based on a depth of 15 feet, the storage pond would have a surface area of 36 acres. Some
assumptions made with regard to pricing this alternative include the assumption that suitable application
sites will be located 15,000 Linear Feet from the WWTP, the property will be contiguous (to reduce
application costs), and the cost for the property would be $2,500 per acre. Based on these assumptions,
the cost was generated considering the construction of a pump station and force main, the purchase of
land and storage, installation of irrigation equipment and the planting land cover crops. The total
construction cost for increasing the treatment capacity of the North WWTP to16.5 MGD and land
applying 9.0 MGD from the North Regional WWTP would be $88 million without soft costs and the cost
for land which is estimated to be $10 million.
Wastewater Reuse: Wastewater reuse was deemed an infeasible option since there are no reuse options
available (no customers) for the treated effluent from the North Regional WWTP.
Direct Discharge to Surface Waters: The total construction cost to expand the North treatment process
to 16.5 MGD is $61 million not including soft costs associated with the project.
Combination of Alternatives: The total construction cost to upgrade the South Regional WWTP to
accept half the proposed upgrade to the North Regional WWTP (4.5 MGD) would be approximately $34
million. The construction cost for the pump station and pipeline to transfer up to 4.5 MGD of flow to the
South facility would be approximately $28 million. The North Regional WWTP would also require an
expansion by 4.5 MGD with an estimated construction cost of $36 million for a total construction cost of
$98 million not including all soft costs.
The most economically feasible and chosen option was the expansion of the North Harnett Regional
WWTP. The Division has reviewed the alternatives and concurs with this decision.
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(l) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YESINO): NO; However, as all data
reported for total silver were non -detect at the lowest PQL identified by DWR (PQL < 1 ug/L) during the
period reviewed, the monitoring requirement for total silver has been removed from the permit.
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
Harnett Regional Water was granted 2/week monitoring for BOD, ammonia, TSS and fecal coliform
based on 2012 DWR Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits
Page 14 of 20

for Exceptionally Performing Facilities during their 2017 renewal. Harnett Regional Water has requested
continuation of this monitoring frequency reduction as part of their renewal application. The last three
years of the facility's data for these parameters have been reviewed in accordance with the criteria
outlined in the guidance. Based on this review, 2/week monitoring frequency has been maintained for
BOD, ammonia, TSS and fecal coliform at the 7.5 MGD flow tier. Upon expansion to 16.5 MGD, BOD,
ammonia, TSS and fecal coliform shall be monitored daily in accordance with 15A NCAC 02B .0508 to
appropriately monitor these parameters during the startup phase of the upgraded facility. Once the 16.5
MGD limits page has been placed into effect and after six (6) consecutive months of daily sampling, the
Permittee may request a reduction in the monitoring frequency to twice per week sampling for any of the
four parameters (BOD5, TSS, NH3-N and Fecal coliform) for which no effluent permit limit violations
have occurred. Twice per week sampling must occur on any two non-consecutive days during the
calendar week. This future change in monitoring frequency for these parameters would be considered a
minor permit modification.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. While NPDES regulated facilities would initially be required to submit additional
NPDES reports electronically effective December 21, 2020, EPA extended this deadline from December
21, 2020, to December 21, 2025. The current compliance date, effective January 4, 2021, was extended as
a final regulation change published in the November 2, 2020 Federal Register. This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
12.Summary of Proposed Permitting Actions:
Table 6. Current Permit Conditions and Proposed Changes 7.5 MGD flow tier
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 7.5 MGD
No change
15A NCAC 2B .0505
TMF
No requirement
Monitor and Report
For calculation of TN and TP loadings
Monthly
BOD5
Summer:
No change
WQBEL. 2008 Qual2E model, Surface
MA 5.0 mg/1
Water Monitoring, 2012 DWR
WA 7.5 mg/1
Guidance Regarding the Reduction of
Winter:
Monitoring Frequencies in NPDES
MA 10.0 mg/1
Permits for Exceptionally Performing
WA 15.0 mg/1
Facilities
Monitor and report
2/Week
NH3-N
Summer:
No change
WQBEL. 2008 Qual2E model, 2023
MA 1.0 mg/1
WLA review; Surface Water
WA 3.0 mg/1
Monitoring, 2012 DWR Guidance
Winter:
Regarding the Reduction of Monitoring
MA 2.0 mg/1
Frequencies in NPDES Permits for
WA 6.0 mg/1
Exceptionally Performing Facilities
Monitor and report
2/Week
TSS
MA 30.0 mg/1
No change
WQBEL. 2008 Qual2E model, Surface
WA 45.0 mg/1
Water Monitoring, 2012 DWR
Monitor and report
Guidance Regarding the Reduction of
2/Week
Monitoring Frequencies in NPDES
Page 15 of 20

Permits for Exceptionally Performing
Facilities
Fecal coliform
MA 200 /100ml
No change
WQBEL. State WQ standard, 15A
WA 400 /100ml
NCAC 2B .0200; Surface Water
Monitor and report
Monitoring, 2012 DWR Guidance
2/Week
Regarding the Reduction of Monitoring
Frequencies in NPDES Permits for
Exceptionally Performing Facilities
DO
> 5.0 mg/l
No change
WQBEL. 2008 Qual2E model; Surface
Monitor and report Daily
Water Monitoring, 15A NCAC 2B.
0500
pH
6 — 9 SU
No change
WQBEL. State WQ standard, 15A
Monitor and report Daily
NCAC 2B .0200; Surface Water
Monitoring, 15A NCAC 2B. 0500
Conductivity
Monitor and report Daily
No change
Surface Water Monitoring, 15A NCAC
2B. 0500
Temperature
Monitor and report Daily
No change
Surface Water Monitoring, 15A NCAC
2B. 0500
Total Residual
No requirement
DM 28 ug/L
WQBEL. 2023 WLA review and
Chlorine
Monitor and report
Surface Water Monitoring, 15A NCAC
Daily (only when
2B. 0500
chlorine is used)
Total Nitrogen
Monitor and report 3/week
No change
Nutrient protection for Cape Fear River
in summer
Basin; Surface Water Monitoring, 15A
Monitor and report
NCAC 2B. 0500
Monthly in winter
TN Loading
Monitor and report
No change
WQBEL. Nutrient protection for Cape
lb/month Monthly
Fear River Basin; Surface Water
Summer mass loading
Monitoring, 15A NCAC 2B. 0500
59,968 lb/season; Monitor
and report annually
TKN
No requirement
Monitor and report
For calculation of Total Nitrogen
3/week in summer;
monthly in winter
NO3+NO2
No requirement
Monitor and report
For calculation of Total Nitrogen
3/week in summer;
monthly in winter
Total
Monitor and report 3/week
No change
Nutrient protection for Cape Fear River
Phosphorous
in summer
Basin; Surface Water Monitoring, 15A
Monitor and report
NCAC 2B. 0500
Monthly in winter
TP Loading
Monitor and report
No change
WQBEL. Nutrient protection for Cape
lb/month Monthly
Fear River Basin; Surface Water
Summer mass loading
Monitoring, 15A NCAC 2B. 0500
19,989 lb/season; Monitor
and report annually
Page 16 of 20

Total Hardness
Quarterly monitoring
No change
Hardness -dependent dissolved metals
Upstream and in Effluent
water quality standards approved in
2016
Total Silver
Monitor and report
Remove requirement
Based on results of RPA; All values
Quarterly
non -detect < 1 ug/L - no monitoring
required
Monitor and Report
Based on 2019 Investigation —1,4-
1,4-dioxane
No requirement
Monthly and
dioxane present in influent and 2022
reo ener condition
DWR NPDES Strategy for 1,4-dioxane
Add Quarterly
Based on 2019 Investigation —PFAS
PFAS
No requirement
monitoring with
present in influent; Implementation
delayed
delayed until after EPA certified
implementation
method becomes available.
Add monthly
Monitor DO, conductivity
monitoring for TKN,
Surface Water Monitoring, 15A NCAC
and temperature 3/Week
NO2+NO3, TP and
2B. 0500; Based on discussion with
during June, July, August
ammonia; Provisional
basin planning branch; instream data
Instream
and September and
waiver for
necessary for tracking impact of
monitoring
1/Week the remainder of
downstream
expanding facility; instream
the year; Provisional
monitoring further
monitoring waiver maintained if
waiver of instream
conditioned upon
MCFRBA activates a downstream
monitoring due to
activation of
station; instream monitoring waiver
membership in MCFRBA
downstream station
maintained for upstream sampling
by MCFRBA
Toxicity Test
Chronic limit, 2.1%
Chronic limit, 4.0%
WQBEL. No toxics in toxic amounts.
effluent
effluent
15A NCAC 213.0200 and 15A NCAC
213.0500; Updated USGS stream
statistics
Effluent
Three times per permit
No change;
40 CFR 122
Pollutant Scan
cycle
conducted in 2025,
2026, 2027
Mercury
MMP Special Condition
No change; revise
WQBEL. Consistent with 2012
Minimization
wording towards its
Statewide Mercury TMDL
Plan (MMP)
maintenance
Implementation.
Electronic
Electronic Reporting
No change
In accordance with EPA Electronic
Reporting
Special Condition
Reporting Rule 2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Table 7. Proposed Permit Conditions 16.5 MGD flow tier
Parameter
Proposed Condition
Basis for Condition
Flow
MA 16.5 MGD
15A NCAC 2B .0505
TMF
Monitor and Report Monthly
For calculation of TN and TP loadings
BOD5
MA 2.1 mg/1
WQBEL. 2008 Qual2E model and frozen load of
WA 3.1 mg/1
oxygen consuming waste in expectation of current
Monitor and report Daily
modeling efforts, 2022 speculative limits; Surface
Water Monitoring, 15A NCAC 02B .0508; 2012
Monitor and report 2/week if no
DWR Guidance Regarding the Reduction of
effluent limit violation occurs during
Monitoring Frequencies in NPDES Permits for
first 6 months of 16.5 MGD flow tier
Exceptionally Performing Facilities
Page 17 of 20

NH3-N
Summer:
WQBEL. 2008 Qual2E model and frozen load of
MA 0.5 mg/l
oxygen consuming waste in expectation of current
WA 1.5 mg/l
modeling efforts, 2022 speculative limits; Surface
Winter:
Water Monitoring, 15A NCAC 02B .0508; 2012
MA 0.9 mg/l
DWR Guidance Regarding the Reduction of
WA 2.7 mg/l
Monitoring Frequencies in NPDES Permits for
Monitor and report Daily
Exceptionally Performing Facilities
Monitor and report 2/week if no
effluent limit violation occurs during
first 6 months of 16.5 MGD flow tier
TSS
MA 15.0 mg/l
WQBEL. 2008 Qual2E model and frozen load in
WA 22.5 mg/l
expectation of current modeling efforts, 2022
Monitor and report Daily
speculative limits; Surface Water Monitoring, 15A
NCAC 02B .0508; 2012 DWR Guidance Regarding
Monitor and report 2/week if no
the Reduction of Monitoring Frequencies in NPDES
effluent limit violation occurs during
permits for Exceptionally Performing Facilities
first 6 months of 16.5 MGD flow tier
Fecal coliform
MA 200 /100ml
WQBEL. State WQ standard, 15A NCAC 2B .0200;
WA 400 /100ml
Surface Water Monitoring, 15A NCAC 02B .0508;
Monitor and report Daily
2012 DWR Guidance Regarding the Reduction of
Monitoring Frequencies in NPDES Permits for
Monitor and report 2/week if no
Exceptionally Performing Facilities
effluent limit violation occurs during
first 6 months of 16.5 MGD flow tier
DO
> 5.0 mg/l
WQBEL. 2008 Qual2E model; Surface Water
Monitor and report Daily
Monitoring, 15A NCAC 2B. 0500
pH
6 — 9 SU
WQBEL. State WQ standard, 15A NCAC 2B .0200;
Monitor and report Daily
Surface Water Monitoring, 15A NCAC 2B. 0500
Conductivity
Monitor and report Daily
Surface Water Monitoring, 15A NCAC 2B. 0500
Temperature
Monitor and report Daily
Surface Water Monitoring, 15A NCAC 2B. 0500
Total Residual
DM 28 ug/L
WQBEL. 2023 WLA review and Surface Water
Chlorine
Monitor and report Daily (only when
Monitoring, 15A NCAC 2B. 0500
chlorine is used)
Total
Monitor and report 3/week in summer
Nutrient protection for Cape Fear River Basin;
Nitrogen
Monitor and report Monthly in winter
Surface Water Monitoring, 15A NCAC 2B. 0500
TN Loading
Monitor and report lb/month Monthly
WQBEL. Nutrient protection for Cape Fear River
Summer mass loading 115,550
Basin; Surface Water Monitoring, 15A NCAC 2B.
lb/season upon revision and reissuance
0500
of South Harnett WWTP loadings
(NC88366); Monitor and report
annually
TKN
Monitor and report 3/week in summer;
For calculation of Total Nitrogen
monthly in winter
NO3+NO2
Monitor and report 3/week in summer;
For calculation of Total Nitrogen
monthly in winter
Total
Monitor and report 3/week in summer
Nutrient protection for Cape Fear River Basin;
Phosphorous
Monitor and report Monthly in winter
Surface Water Monitoring, 15A NCAC 2B. 0500
TP Loading
Monitor and report lb/month Monthly
WQBEL. Nutrient protection for Cape Fear River
Summer mass loading 38,517 lb/season
Basin; Surface Water Monitoring, 15A NCAC 2B.
upon revision and reissuance of South
0500
Page 18 of 20

Harnett WWTP loadings (NC88366);
Monitor and report annually
Total
Quarterly monitoring Upstream and in
Hardness -dependent dissolved metals water quality
Hardness
Effluent
standards approved in 2016
Monit or
Monitor and Report Monthly and
Based on 2019 Investigation —1,4-dioxane present in
1,4-dioxane
condition
reopedioxane
influent and 2022 DWR NPDES Strategy for 1,4-
Quarterly monitoring with delayed
Based on 2019 Investigation —PFAS present in
PFAS
implementation
influent; Implementation delayed until after EPA
certified method becomes available.
Monitor DO, conductivity and
temperature 3/Week during June, July,
August and September and 1/Week the
Surface Water Monitoring, 15A NCAC 2B. 0500;
remainder of the year; monitoring for
Based on discussion with basin planning branch;
Instream
TKN, NO2+NO3, TP and ammonia;
instream data necessary for tracking impact of
monitoring
Provisional waiver of instream
expanding facility; instream monitoring waiver
requirements
monitoring due to membership in
maintained if MCFRBA activates a downstream
MCFRBA; Provisional waiver for
station; instream monitoring waiver maintained for
downstream monitoring further
upstream sampling
conditioned upon activation of
downstream station by MCFRBA
Toxicity Test
Chronic limit, 8.3% effluent
WQBEL. No toxics in toxic amounts. 15A NCAC
213.0200 and 15A NCAC 213.0500; Updated USGS
stream statistics
Effluent
Three times per permit cycle; conducted
40 CFR 122
Pollutant Scan
in three following years after expansion
occurs
Mercury
MMP Special Condition
WQBEL. Consistent with 2012 Statewide Mercury
Minimization
TMDL Implementation.
Plan (MMP)
Electronic
Electronic Reporting Special Condition
In accordance with EPA Electronic Reporting Rule
Reporting
1 2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
13. Public Notice Schedule:
Permit to Public Notice: 5/26/2023
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.
14. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit, please
contact Nick Coco at [phone] or via email at [e-mail].
15. Fact Sheet Addendum (if applicable):
The draft was submitted to Harnett Regional Water, MBD Consulting Engineers, EPA Region IV, and the
Division's Fayetteville Regional Office, Aquatic Toxicology Branch, Pretreatment Program, Monitoring
Coalition Coordinator and Operator Certification Program for review.
Page 19 of 20

Comments were received from the DWR Monitoring Coalition Coordinator on June 6, 2023 requesting
the addition of fecal coliform, total suspended residue and turbidity to the suite of instream parameters
required in the permit.
The Southern Environmental Law Center (SELC) provided comment to the Division on June 26, 2023
requesting implementation of more restrictive requirements regarding 1,4-dioxane and PFAS, including
increased monitoring and permit limitations for both as well as require pretreatment actions to maintain
toxins introduced from the Sampson County Landfill. Please note, the North Harnett Regional WWTP
does not receive any wastewater from the Sampson County Landfill. As only data available for 1,4-
dioxane and PFAS come from influent sampling efforts conducted in 2019 and the discharge is in WS-IV
waters, sampling has been required at a monthly and quarterly frequency for each respective parameter(s)
to gather more data. Additionally, a reopener condition has been incorporated into the permit for 1,4-
dioxane and the Division may reopen the permit upon receipt of sufficient data to demonstrate cause for
concern. The monitoring requirements have been maintained for both PFAS and 1,4-dioxane.
However, out of the concerns raised and the continual industrial growth of the area, PFAS monitoring
will be increased to monthly upon the facility's receipt of any new significant industrial user, to be
applied to the effluent and industrial user discharge, the latter through the facility's pretreatment program.
After 12 months of monitoring, the Permittee may request reduction of monitoring to quarterly based on
evaluation of gathered data. The PFAS monitoring special condition has been modified to include this
change. Additionally, the Permittee shall review pollutants of concern (POCs) and update the Long Term
Monitoring Plan (LIMP) to reflect pollutants in industrial user permits (IUPs) and the sludge
management permit. Quarterly monitoring for PFAS chemicals shall be added to the LTMP and all IUPs,
to become effective six months after EPA publishes a 40 CFR Part 36 Method for wastewater in the
Federal Register. The review and revisions shall be submitted to the Division within 180 days of the
effective date of the permit.
No comments were received from any other party.
Were there any changes made since the Draft Permit was public noticed (Yes/No): YES
If Yes, list changes and their basis below:
• Per discussion with the Division's Monitoring Coalition Coordinator, instream monitoring for
fecal coliform, TSS and turbidity have been added to the permit [See A.(1.) and A.(2.)].
• In the event that any new Significant Industrial User (SIU) discharges to the North Harnett
Regional WWTP, the monitoring frequency shall be increased to monthly with the option for
Harnett Regional Water to request reduction of monitoring after 12 months of data collection and
the data are evaluated for presence and concentrations of PFAS chemicals [See A.(7.)].
16. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards
• NH3/TRC WLA Calculations
• BOD & TSS Removal Rate Calculations
• Mercury TMDL Calculations
• WET Testing and Self -Monitoring Summary
• MFR spreadsheet
• Compliance Inspection Report
• Chemical Addendum
Page 20 of 20

AFFP
HARNETT REGIONAL WATER
Affidavit of Publication
STATE OF NC) SS
COUNTY OF HARNETT )
The Undersigned, being duly sworn, says:
North Carolina Environmental Management Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES Wastewater Permit NCO021636 North Harnett Regional
WWTP, and NCO088366 South Harnett Regional WWTP The North Carolina Environmen-
tal Management Commission proposes to issue a NPDES wastewater discharge permit
to the person(s) listed below. Written comments regarding the proposed permit will be
accepted until 30 days 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 de-
gree of public interest. Please mail comments and/or information requests to DWR at the
above address. Interested persons may visit the DWR at 512 N. Salisbury Street, Raleigh,
NC 27604 to review the information on file Additional information on NPDES permits
and this notice may be found on our website: tlttps.//dea.nc.aoylic-notices-hearinos,or
by calling [phone] Harnett Regional Water [P.O. Box 1119 Lillington, NC 275461
has requested renewal and expansion of NPDES permit NCO021636 for its North Harnett
Regional WWTP, located in Harnett County. This permitted facility discharges treated mu-
nicipai and industrial wastewater to the Cape Fear River, a class WS-IV water in the Cape
Fear River Basin. Currently BOD, ammonia, fecal coliform, dissolved oxygen, total residual
chlorine, pH, and summer total nitrogen and total phosphorous loading are water quality
limited. This discharge may affect future allocations in this segment of the Cape Fear Riv-
er. Harnett Regional Water (P.O. Box 1119, Lillington, NC 27546) has requested renewal
of NPDES permit NCO088366 for its South Harnett Regional WWTP, located in Harnett
County. This permitted facility discharges treated municipal and industrial wastewater to
the Lower Little River, a class C water in the Cape Fear River Basin. Currently BOD, ammo-
nia, fecal coliform, dissolved oxygen, total residual chlorine, pH, and summer total nitrogen
and total phosphorous loading are water quality limited. This discharge may affect future
allocations in this segment of the Cape Fear River. 5/26/2023
That she is Representative of the The Daily Record, a
daily newspaper of general circulation, printed and
published in Dunn, Harnett County, NC; that the
publication, a copy of which is attached hereto, was
published in the said newspaper on the following dates:
May 26, 2023
This newspaper is qualified for legal advertising in
accordance with N.C.G.S. 1-597 AND 1-598
That said newspaper was regularly issued and circulated
on those dates.
SIG
Representative U/
Subscribed to and sworn to me this 26th day of May 2023.
ON AN 7/
•QF'
Harnett County, NC
; ,y\�Nr,o zo; • (��, :�
My commission expires: July 23, 2027
0):o4
"OTARY
PUBLIC, -
'�ONr49�9 ,•' �.•
00030975 00072418 733 0719
�'•.�FrT....
•�
NCDENR- DEO-DIVISION OF WATER RESOURCES
ATTN: WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617

ROY COOPER
ELIZABETH S. BISER
RICHARD E. RODGFFRS. JR.
July 10, 2023
MEMORANDUM
To: Heidi Cox
NC DEQ / DWR / PWS Regional Engineer
Fayetteville Regional Office
From; Nick Coco, PE
919-707-3609
NPDES Permitting / Municipal Unit
Subject: Review of Draft NPDES Permit NC0021636
North Harnett Regional WWTP
Harnett County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by July 14, 2023.
If you have any questions on the draft permit, please feel free to contact me at the telephone number shown above.
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properl\, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water dualit\
standards.
1-1 Concurs with issuance of the above permit, provided the following conditions are met:
F-1
Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signeduxv Date: K.PD3
state or North Carolina! Fnvirwirnental Quzilily
1611 Mail service Center 1 Raleigh. Noah Carolina 27699-161 1
919-707-9000

fl-
p8 2�
}t�vq,. m
A%gg
Water Resources
July 10, 2023
MEMORANDUM
To: Heidi Cox
NC DEQ 1 DWR 1 PWS Regional Engineer
Fayetteville Regional Office
From: Nick Coco, PE
919-707-3609
NPDES Permitting / Municipal Unit
Subject: Review of Draft NPDES Permit NCO021636
North Harnett Regional WWTP
Harnett County
ROY COOPER
t ",.;:Pi,, ;
ELIZABETH S. BISER
RiCHARD I!- ROI)GI RS. _1R.
Please indicate below your agency's position or viewpoint on the draft permit and return this form by July 14, 2023.
If you have any questions on the draft permit, please feel free to contact me at the telephone number shown above.
RESPONSE; (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water yualiq
standards.
1-1 Concurs with issuance of the above permit, provided the following conditions are met:
F-1 Opposes the issuance of the above permit, based on reasons stated below, or attached:
.r
Signed r

Coco, Nick A
From: Vander Borgh, Mark
Sent: Tuesday, June 6, 2023 11:58 AM
To: Coco, Nick A
Cc: Hill, Tammy
Subject: RE: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952
and South Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
Hi Nick,
In regard to the requirement for the reactivation of the downstream monitoring station B6400000 in the NCO021636
permit, I would recommend adding fecal, suspended residue, and turbidity to the instream parameters list to align with
the parameters collected at the other MCFBA Cape Fear River monitoring stations.
Please contact me if you have any questions.
Regards
Mark Vander Borgh
Sr. Environmental Biologist/Monitoring Coalition Coordinator
NC DEQ/ DWR / Water Sciences Section / Ecosystems Branch
Office: [phone]
[e-mail]
Physical Address: 4401 Reedy Creek Rd. Raleigh, NC. 27607
Mailing Address: 1621 MSC Raleigh, NC. 27699-1621
tf::�,-
NORTH CAPOUNAD_E Q��
oevart M m e���.o�me�wi o-fity
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Coco, Nick A <[e-mail]>
Sent: Friday, May 19, 2023 11:21 AM
To: Vander Borgh, Mark <[e-mail]>
Subject: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952 and South
Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
Hi Mark,
I hope all is well.
Please see the following links to review the draft permits and cover letters and draft fact sheets for NPDES permits
NCO021636 for the North Harnett Regional WWTP and NCO088366 for the South Harnett Regional WWTP. I have also
provided a link to the NPDES Standard Conditions for your reference. You have a 30-day period ending on 6/19/2023 to
comment, ask questions, or request an extension to review this draft permit. Please contact me with any comments you
might have.

NCO021636 Draft
Permit: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2789033&dbid=0&repo=WaterResources
NPDES Standard Conditions: https://bit.ly/3k5NFaL
NCO021636 Draft Fact Sheet:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2802020&dbid=0&repo=WaterResources
NCO088366 Draft
Permit: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2789031&dbid=0&repo=WaterResources
NPDES Standard Conditions: https://bit.ly/3k5NFaL
NCO088366 Draft Fact Sheet:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2802171&dbid=0&repo=WaterResources
Thanks, and have a nice day.
Best,
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ/ Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
.. ��D, E
IWI-0)
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Coco, Nick A
From:
Pohlig, Ken
Sent:
Tuesday, May 23, 2023 9:30 PM
To:
Coco, Nick A; Desai, Trupti A
Cc:
Ajami, Ali; Evans, Tony V; Montebello, Michael J; Hargrove, Andrew D; Wainwright, David
Subject:
RE: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952
and South Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
Follow Up Flag: Follow up
Flag Status: Flagged
Nick:
I will go ahead and answer your question:
Yes, all the Sources of ARPA funds (Town of Angier, Town of Lillington, and Harnett County) are from Earmark ARPA
funds which are routed through GS 159G (which means through the Wastewater Reserve Fund).
And so... Yes, I think you have answered our questions: Since this is true, they are exempt from SEPA.
As far as we currently know, there are no more Federal or State funds involved in this project, other than the ARPA
funds we just mentioned.
Ken
From: Coco, Nick A <[e-mail]>
Sent: Tuesday, May 23, 2023 8:19 PM
To: Desai, Trupti A <[e-mail]>
Cc: Ajami, Ali <[e-mail]>; Evans, Tony V <[e-mail]>; Pohlig, Ken <[e-mail]>;
Montebello, Michael J <[e-mail]>; Hargrove, Andrew D <[e-mail]>;
Wainwright, David <[e-mail]>
Subject: Re: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952 and South
Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
Hi Trupti,
I just wanted to get some clarification on this. Are these all funded through ARPA? What are the sources of funding? Are
all funds via the Wastewater Reserve, Drinking Water Reserve and/or the Viable Utility Reserve? The origin of the
funding will dictate SEPA requirements.
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ/ Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but I am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604

Malline Address:
-1
From: Desai, Trupti A <[e-mail]>
Sent: Tuesday, May 23, 2023 3:30:31 PM
To: Coco, Nick A <[e-mail]>
Cc: Ajami, Ali <[e-mail]>; Evans, Tony V <[e-mail]>; Pohlig, Ken <[e-mail]>
Subject: RE: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952 and South
Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
Nick,
Just now I had a discussion with Ken, Tony and Adrian on Harnett County's project.. Here are three towns putting ARPA
money in this $63 million project. The total of NC money is over $10 million. Please discuss this matter with SEPA
coordinator or your supervisor to determine if SEPA is applicable in this case or not.
Thank You.
Trupti Desai P.E.
Project Manager
Division of Water Infrastructure
North Carolina Department of Environmental Quality
919-707-9166 (Office)
919-208-8465 (Mobile)
NEW EMAIL WILL REPLACE ALL MEMBERS OF DEQ-DWI on 15MAY2023
Current: trupti.desai()ncdenr.gov
NEW: trupti.desai(cdeg.nc.gov
512 North Salisbury St.,Raleigh, NC, 27604
1633 Mail Service Center, Raleigh, NC, 27699-1633
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Coco, Nick A <[e-mail]>
Sent: Tuesday, May 23, 2023 2:44 PM
To: Desai, Trupti A <[e-mail]>
Subject: FW: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952 and South
Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
From: Coco, Nick A
Sent: Friday, May 19, 2023 11:33 AM
To: Pohlig, Ken <[e-mail]>; Ajami, Ali <[e-mail]>
Subject: FW: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952 and South
Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
Just FYI
Thanks,
Nick
From: Coco, Nick A
Sent: Friday, May 19, 2023 11:19 AM
To: Kenny Fail <[e-mail]>; Ward, Steve
Cc: Joseph McGougan <[e-mail]>; Montebello, Michael J <Michael.Montebello @deg.nc.gov>
Subject: Draft Permits North Harnett Regional WWTP, NPDES Permit Number NC0021636, SIC Code 4952 and South
Harnett Regional WWTP, NPDES Permit Number NC0088366, SIC Code 4952
Hi Kenny and Steve,
I hope all is well.
Please see the following links to review the draft permits and cover letters and draft fact sheets for NPDES permits
NCO021636 for the North Harnett Regional WWTP and NCO088366 for the South Harnett Regional WWTP. I have also
provided a link to the NPDES Standard Conditions for your reference. Harnett Regional Water has a 30-day period
ending on 6/19/2023 to comment, ask questions, or request an extension to review this draft permit. Please contact me
with any comments you might have.
NCO021636 Draft
Permit: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2789033&dbid=0&repo=WaterResources
NPDES Standard Conditions: https://bit.ly/3k5NFaL
NCO021636 Draft Fact Sheet:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2802020&dbid=0&repo=WaterResources
NCO088366 Draft
Permit: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2789031&dbid=0&repo=WaterResources
NPDES Standard Conditions: https://bit.ly/3k5NFaL
NCO088366 Draft Fact Sheet:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2802171&dbid=0&repo=WaterResources
Thanks, and have a nice day.
Best,

Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ/ Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
NORTH CAROLINA -
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

SOUTHERN 601 West Rosemary Street, Suite 220 Telephone [phone]
ENVIRONMENTAL Chapel Hill, NC 27516 Facsimile 919-929-9421
LAW
CENTER
June 26, 2023
Nick Coco
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
nick. cocoAdeq.nc.gov
Re: Southern Environmental Law Center Comments on NPDES Wastewater
Draft Permit NCO021636 North Harnett Regional WWTP
Dear Mr. Coco:
The Southern Environmental Law Center offers the following comments regarding the
draft renewal National Pollutant Discharge Elimination System ("NPDES") Permit NC0021636,
issued by the North Carolina Department of Environmental Quality ("the Department") to the
Harnett Regional Water ("Harnett Regional") for the operation of its North Harnett wastewater
treatment plant. I Harnett Regional discharges wastewater into a portion of the Cape Fear River
protected as a water supply.2 Approximately 10 river miles downstream, the city of Dunn pulls
its drinking water from the Cape Fear River. Harnett Regional is proposing to expand its
discharges from 7.5 million gallons per day ("MGD") to 16.5 MGD.3
Harnett Regional's wastewater contains 1,4-dioxane and per- and polyfluoroalkyl
substances ("PFAS,,),4 chemicals known to cause cancer. The PFAS and 1,4-dioxane flowing
into the wastewater plant are likely from the Sampson County Landfill, which sends leachate to
Harnett Regional's North Harnett wastewater plant and South Harnett wastewater plant. s As the
Department is aware, the Sampson County Landfill accepts PFAS contaminated sludge from The
Chemours Company, a PFAS manufacturer in Fayetteville,6 North Carolina, as well as 1,4-
' N.C. Dep't of Env't Quality, Draft NPDES Permit NCO021636 (May 16, 2023) [hereinafter "North Harnett Draft
Permit"] .
2 North Harnett Draft Permit, supra note 1 at 2.
s N.C. Dep't of Env't Quality, Draft Fact Sheet NPDES Permit No. NCO021636 (May 16, 2023), at 1 [hereinafter
"North Harnett Draft Fact Sheet"].
4Id. at 14-15; N.C. Dep't of Env't Quality, Cape Fear Municipal PFAS & 1,4-dioxane Monitoring (2020),
Attachment 1 [hereinafter "Cape Fear Municipal PFAS & 1,4-dioxane Sampling"].
5 Harnett Regional Water, 2020 Pretreatment Annual Report (Feb. 27, 2023), at 2 [hereinafter "Harnett Regional
Pretreatment Reporf']; see also Hart & Hickman, Collective Study of PFAS and 1,4-dioxane in Landfill Leachate
and estimated Influence on Wastewater Treatment Plant Facility Influent (Mar. 10, 2020), at Table 2,
https://perma.cc/TL5E-XPEO [hereinafter "2020 Landfill Leachate Study"].
6 See Steve DeVane, Sludge From Chemours Plant Dumped in Sampson County Landfill, THE FAYETTEVILLE
OBSERVER (Oct. 20, 2018), h tps://www.fayobserver.com/stoa/news/2018/10/20/sludge-from-chemours-plant-
dumped-in-sampson-county-landfill/9501213 007/.
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

dioxane contaminated sludge from DAK Americas, a resins manufacturer also in Fayetteville.
This industrial pollution from the sludge flows into the landfill's leachate and, because
wastewater plants cannot remove the chemicals, are reflected in the wastewater plants' effluent.8
Despite knowing about the concentrations of PFAS and 1,4-dioxane in the landfill's
leachate and the wastewater plant's effluent,9 the Department did not impose limits or conditions
on the facility's discharge of either chemical, opting instead to continue studying pollution it
already knows exists.10 The U.S. Environmental Protection Agency ("EPA") has made clear
state permitting agencies have existing authority to control PFAS through NPDES permits. I I
This past December, EPA issued guidance to state agencies "describ[ing] steps permit writers
can implement under existing authorities to reduce the discharge of PFAS." 12 EPA's guidance
describes tools within the Clean Water Act that should be used to control PFAS from wastewater
plants like Harnett Regional, including effluent limits and pretreatment conditions. Those tools
should be used for 1,4-dioxane as well.
L Harnett Regional discharges 1,4-dioxane and PFAS, chemicals linked to cancer.
The Cape Fear River Basin and those who rely upon it suffer from some of the highest
levels of PFAS and 1,4-dioxane in the entire country.13 In 2019, the Department directed
wastewater plants in the river basin, including Harnett Regional, to sample their wastewater
plants for these chemicals in order to understand the scope of pollution.14 The results of that
sampling confirmed that Harnett Regional receives waste laden with toxic chemicals.
a. Harnett Regional discharges 1, 4-dioxane, a human carcinogen.
Harnett Regional receives wastewater containing 1,4-dioxane, a chemical likely to cause
cancer." 1,4-dioxane is a clear, man-made chemical that is used in or created as a byproduct of
many industrial processes.16 The chemical is toxic to humans,17 causing liver and kidney damage
at incredibly low levels.18 As a result of the harms caused by 1,4-dioxane, EPA established a
DAK Americas, Permit Renewal and Modification NPDES Permit No.: NC0003719 (May 3, 2022), at PDF pg. 14.
s See 2020 Landfill Leachate Study, supra note 5 at Table 2.
9 North Harnett Draft Fact Sheet, supra note 3 at 14-15.
10 North Harnett Draft Permit, supra note 1 at 4.
11 Memorandum from Radhika Fox, Assistant Administrator, U.S. Env't Prot. Agency, Addressing PFAS
Discharges in NPDES Permits and Through the Pretreatment Program and Monitoring Programs (December 5,
2022) (emphasis added) [hereinafter "EPA's PFAS NPDES Guidance"], Attachment 2.
12 See generally id.
13 Data Summary of The Third Unregulated Contaminant Monitoring Rule, U.S. ENV'T PROT. AGENCY,
hlWs://www.epa.gov/dwucmr/data-summary-third-unregulated-contaminant-monitoring-rule (last visited June 25,
2023); N.C. Div. of Water Res., 1, 4-Dioxane in the Cape Fear River Basin of North Carolina: An Initial Screening
and Source Identification Study 2 (2016), available at hlWs://www.deg.nc.gov/water-quality/environmental-
science s/eco/dioxanereport-yrl final-20160127/download.
14 Letter from Linda Culpepper, N.C. Dep't of Env't Quality (Apr. 30, 2019), Attachment 3.
is Cape Fear Municipal PFAS & 1,4-dioxane Sampling, supra note 4.
16U.S. Env't Prot. Agency, Technical Fact Sheet —1,4-Dioxane 1-2 (2017),
https://www.epa.gov/sites/default/files/2014-03/documents/ffrro factsheet_contaminant _14-
dioxanejanuary2014_final.pdf [hereinafter"EPA, Technical Fact Sheet 1,4-Dioxane"].
17 Id. at 1.
18 Id.; U. S. Env't Prot. Agency, Integrated Risk Information System, Chemical Assessment Summary: 1, 4,-dioxane 2
https://iris.epa.gov/static/pdfs/0326_sununM.pdf (Aug. 11, 2010).
2

drinking water health advisory with an associated lifetime cancer risk of one -in -one -million at a
concentration of 0.35 parts per billion (" ppb").19 The State of North Carolina has similarly
determined that 1,4-dioxane is toxic and poses a cancer risk at levels higher than 0.35 ppb.20
In 2019, Harnett Regional reported that its influent (water flowing into the wastewater
plant) contains 1,4-dioxane at concentrations as high as 11.7 ppb.21 Despite this sampling,
Harnett Regional did not disclose that it receives and likely discharges 1,4-dioxane into the Cape
Fear River.22
b. Harnett Regional discharges PFAS, a class of chemicals known to cause harm to
human health and the environment.
The same sampling event that informed the Department about Harnett Regional's 1,4-
dioxane pollution also confirmed that the utility's influent contains PFAS at levels exceeding
240 parts per trillion (,,ppt,,).23 PFAS are a group of man-made chemicals manufactured and used
broadly by industry since the 1940s.24 PFAS pose a significant threat to human health at
extremely low concentrations. Two of the most studied PFASperfluorooctanoic acid
(" PFOA") and perfluorooctane sulfonate ("PFOS")—are bioaccumulative and highly persistent
in humans.25 PFOA and PFOS have been shown to cause developmental effects to fetuses and
infants, kidney and testicular cancer, liver malfunction, hypothyroidism, high cholesterol,
ulcerative colitis, obesity, decreased immune response to vaccines, reduced hormone levels,
delayed puberty, and lower birth weight and size.26 Because of its impacts on the immune
19 2018 Edition of the Drinking Water Standards and Health Advisories, EPA OFFICE OF WATER 4 (2018),
https://www.epa.gov/Vstem/files/documents/2022-01/dwtable2Ol8.pdf; EPA, Technical Fact Sheet —1,4-Dioxane,
supra note 16 at 3.
20 N.C. Div. of Water Res., 1, 4-dioxane Monitoring in the Cape Fear River Basin of North Carolina: An Ongoing
Screening, Source Identification, and Abatement Verification Study (2017), at 2,
https://files.nc.gov/ncdeg/Water`/`20Quality/Environmental%20 Sdences/Dioxane/DioxaneYear2ReportWithMemo
_20170222.1)df (affirming EPA's conclusions); see also N.C. Dep't of Env't Quality, Div. Water Res., Surface
Water Quality Standards, Criteria & In -Stream Target Values (2019) (stating that the one -in -one million cancer risk
for 1,4-dioxane is 0.35 ppb), Attachment 4.
21 Cape Fear Municipal PFAS & 1,4-dioxane Sampling, supra note 4.
22 See generally MBD Consulting Engineers, North Regional WWTP Expansion NPDES Permit Application (Apr.
19, 2022).
23 Cape Fear Municipal PFAS & 1,4-dioxane Sampling, supra note 4.
24 Lifetime Drinking Water Health Advisories for Four Perfluoroalkyl Substances, 87 Fed. Reg. 36,848, 36,849
(June 21, 2022); Our Current Understanding of the Human Health and Environmental Risks of PFAS, U. S. ENV T
PROT. AGENCY, https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas
(last visited Jan. 24, 2023).
25 87 Fed. Reg. at 36,849; U.S. Env't Prot. Agency, Interim Drinking Water Health Advisory: Perfluorooctanoic
Acid (PFOA) CASRN 335-67-1 (June 2022), at 3-4, available at
https://www.epa.gov/Vstem/files/documents/2022-06/interim-pfoa-2022.pdf, U.S. Env't Prot. Agency, Interim
Drinking Water Health Advisory: Perfluorooctane Sulfonic Acid (PFOS) CASRN 1763-23-1 (June 2022), at 3-4,
available athlWs://www.epa.gov/Vstem/files/documents/2022-06/interim-pfos-2022.pdf.
26 Arlene Blum et al., The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs), 123 ENv'T. HEALTH
PERSP. 5, A 107 (May 2015); U.S. Env't Prot. Agency, Drinking Water Health Advisories for PFAS: Fact Sheet for
Communities, at 1-2 (June 2022), available at https://www.epa.gov/Vstem/files/documents/2022-06/drinking-
water-ha-pfas-factsheet-communities.pdf.

system, PFAS can also exacerbate the effects of Covid-19.27 Studies show that exposure to
mixtures of different PFAS can worsen these health effects.2' Given these harms, EPA in June
2022 established interim updated lifetime health advisories for PFOA and PFOS in drinking
water of 0.004 ppt and 0.02 ppt, respectively.29
Epidemiological studies show that many of the negative health outcomes associated with
PFOA and PFOS can result from exposure to other PFAS, including, but not limited to,
perfluorohexane sulfonic acid ("PFHxS,,),30 perfluorobutanesulfonic acid (" PFBS,,),31
perfluorobutanoic acid ("PFBA"),32 perfluorohexanoic acid (`PFHxA"),33 perfluorononanoic
acid ("PFNA"),34 perfluorodecanoic acid ("PFDA"),35 and hexafluoropropylene oxide dimer acid
("GenX Chemicals,,).36
While the harms to human health are extreme, PFAS are also detrimental to wildlife and
the environment. The chemicals have been shown to cause damaging effects in fish,37
21 See Lauren Brown, Insight: PFAS, Covid-19, and Immune Response Connecting the Dots, BLOOMBERG LAw
(July 13, 2020, 4:00 AM), https://news.bloomberglaw.com/environment-and-energy/insight-pfas-covid-l9-and-
immune-response-connecting-the-dots?context=article-related.
28 Emma V. Preston et al., Prenatal Exposure to Per- and Polyfluoroalkyl Substances and Maternal and Neonatal
Thyroid Function in the Project Viva Cohort: A Mixtures Approach, 139 ENV'T INT'L 1 (2020),
https://perma.cc/DJK3-87SN.
29 87 Fed. Reg. at 36,848-49.
so U.S. Env't Prot. Agency, DRAFT Systematic Review Protocol for the PFBA, PFHxA, PFHxS, PFNA, and PFDA
(anionic and acid forms) IRIS Assessments (updated Jan. 2021), at 2-22, https://perma.cc/32DL-AAQK [hereinafter
"DRAFT Toxicological Data PFBA, PFHxA, PFHxS, PFNA, and PFDA"] (explaining that studies indicate that
PFHxS is associated with developmental, endocrine, hepatic, immune, reproductive, and urinary effects); Minn.
Dep't of Health, Toxicological Summary for: Perfluorohexane sulfonate (Aug. 2020), at 7 hlWs://penna.cc/4CWG-
9UQB (stating that exposure to PFHxS has been associated with detrimental endocrine and reproductive impacts).
31 U.S. Env't Prot. Agency, Drinking Water Health Advisory: Perfluorobutane Sulfonic Acid (CASRN 375-73-5)
and Related Compound Potassium Perfluorobutane Solfonate (CASRN 29420-49-3) (June 2022),
https://penna.cc/X74T-EQ83 (explaining that literature confirms exposure to PFBS impacts to thyroid, reproductive
systems, development, kidneys, liver, and lipid and lipoprotein homeostasis).
32 U.S. Env't Prot. Agency, IRIS Toxicological Review of Perfluorobutanoic Acid (PFBA, CASRN 375-22-4) and
Related Salts (Dec. 2022), at xii, hops://perma.cc/HD3F-78VJ (explaining "available evidence indicates that
developmental, thyroid, and liver effects in humans are likely caused by PFBA exposure in utero or during
adulthood").
33 DRAFT Toxicological Data PFBA, PFHxA, PFHxS, PFNA, and PFDA, supra note 30 at 2-22.
34Id.; N.J. Drinking Water Quality Inst., Health -Based Maximum Contaminant Level Support Document:
Perfluorononanoic acid ("PFNA"), at 35 (June 22, 2015), h1Ws://perma.cc/JCT9Z-AG9T (explaining exposure to
PFNA has been associated with developmental issues, including neonatal mortality, and liver functions).
35 DRAFT Toxicological Data PFBA, PFHxA, PFHxS, PFNA, and PFDA, supra note 30 at 2-22.
36 U.S. Env't Prot. Agency, Drinking Water Health Advisory: Hexafluoropropylene Oxide (HFPO) Dimer Acid
(CASRN 13252-13-6) and HFPO Dimer Acid Ammonium Salt (CASRN 62037-80-3), Also Known as "GenX
Chemicals" (June 2022), at vii, https://perma.cc/9F6H-5BBY (explaining that exposure to GenX increases harms to
liver, reproductive, and developmental functions).
31 Chen et al., Perfluorobutanesulfonate Exposure Causes Durable and Transgenerational Dysbiosis of Gut
Microbiota in Marine Medaka, 5 ENv'T SCI. & TECH LETTERS 731-38 (2018); Chen et al., Accumulation
of Perfluorobutane Sulfonate (PFBS) and Impairment of Visual Function in the Eyes ofMarine Medaka After
a LifeCycle Exposure, 201 AQUATIC TOXICOLOGY 1-10 (2018); Du et al., Chronic Effects of Water -Borne PFOS
Exposure on Growth, Survival and Hepatotoxicity in Zebrafish: A Partial Life -Cycle Test, 74 CHEMOSPHERE 723-29
(2009); Hagenaars et al., Structure Activity Relationship Assessment o f Four Perfluorinated Chemicals Using a
Prolonged Zebraflsh Early Life Stage Test, 82 CHEMOSPHERE 764-72 (2011); Huang et al., Toxicity, Uptake
rd

amphibians,38 reptiles,39 mollusks,40 and other aquatic invertebrates 41resulting in
developmental and reproductive impacts, behavioral changes, adverse effects to livers, disruption
to endocrine systems, and weakened immune systems.42
PFAS are extremely resistant to breaking down in the environment.43 Once released, the
chemicals can travel long distances and bio-accumulate in organisms.44 PFAS have been found
in fish tissue across all 48 continental states,45 and PFOS—a particularly harmful PFAS
compound —is one of the most prominent PFAS found in freshwater fish.46 As a result, the
primarily low-income and minority communities that rely heavily on subsistence fishing have
been found to have elevated PFAS levels in their blood.47 In fact, researchers conclude that
"[w]idespread PFAS contamination of freshwater fish in surface waters in the U.S. is likely a
Kinetics and Behavior Assessment in Zebrafish Embryos Following Exposure
to Perfluorooctanesulphonicacid (PFOS), 98 AQUATIC TOXICOLOGY 139-47 (2010); Jantzen et al., PFOS, PFNA,
and PFOA Sub -Lethal Exposure to Embryonic Zebrafish Have Different Toxicity Profiles in terms of
Morphometrics, Behavior and Gene Expression, 175 AQUATIC TOXICOLOGY 160-70 (2016); Liu et al., The Thyroid -
Disrupting Effects ofLong-Term Perfluorononanoate Exposure on Zebrafish (Danio rerio),
20 ECOTOXICOLOGY 47-55 (2011); Chen et al., Multigenerational Disruption of the Thyroid Endocrine System in
Marine Medaka after a Life -Cycle Exposure to Perfluorobutanesulfonate, 52 ENV'T SCI. & TECH. 4432-39
(2018); Rotondo et al., Environmental Doses of PerfluorooctanoicAcid Change the Expression of Genes in Target
Tissues of Common Carp, 37 ENV'T TOXICOLOGY & CHEM. 942-48 (2018).
38 Ankley et al., Partial Life -Cycle Toxicity and Bioconcentration Modeling of Perfluorooctanesulfonate in the
Northern Leopard Frog (Rana Pipiens), 23 ENV'T TOXICOLOGY & CHEM. 2745 (2004); Cheng et al., Thyroid
Disruption Effects of Environmental Level Perfluorooctane Sulfonates (PFOS) in Xenopus Laevis,
20 ECOTOXICOLOGY 2069-78 (2011); Lou et al., Effects of Perfluorooctanesulfonate and Perfluorobutanesulfonate
on the Growth and Sexual Development ofXenopus Laevis, 22 ECOTOXICOLOGY 1133-44 (2013).
39 Guillette et al., Blood Concentrations of Per- and Polyfluoroalkyl Substances Are Associated with Autoimmune-
like Effects in American Alligators From Wilmington, North Carolina, FRONTIER TOXICOLOGY 4:1010185 (Oct. 20,
2022).
40 Liu et al., Oxidative Toxicity ofPerfluorinated Chemicals in Green Mussel and Bioaccumulation Factor
Dependent Quantitative Structure -Activity Relationship, 33 ENV'T TOXICOLOGY & CHEM. 2323-32 (2014); Liu et
al., Immunotoxicity in Green Mussels under Perfluoroalkyl Substance (PFAS) Exposure: Reversible Response and
Response Model Development, 37 ENV'T TOXICOLOGY & CHEM. 1138-45 (2018).
41 Houde et al., Endocrine -Disruption Potential of Perfluoroethylcyclohexane Sulfonate (PFECHS) in Chronically
Exposed Daphnia Magna, 218 EN V'T POLLUTION 950-56 (2016); Liang et al., Effects of Perfluorooctane Sulfonate
on Immobilization, Heartbeat, Reproductive and Biochemical Performance of Daphnia Magna,
168 CHEMOSPHERE 1613-18 (2017); Ji et al., Oxicity ofPerfluorooctane SulfonicAcid and Perfluorooctanoic Acid
on Freshwater Macroinvertebrates (Daphnia Magna and Moina Macrocopa) and Fish (Oryzias Latipes), 27 ENV'T
TOXICOLOGY & CHEM. 2159 (2008); MacDonald et al., Toxicity of Perfluorooctane Sulfonic Acid and
Perfluorooctanoic Acid to Chironomus Tentans, 23 ENV'T TOXICOLOGY & CHEM. 2116 (2004).
41 See supra notes 37-41.
43 Carol F. Kwiatkowski, et al., Scientific Basis for Managing PFAS as a Chemical Class, ENV'T SCL & TECH.
LETTERS 8-9 (2020).
44 See What are PFAS?, AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY,
https://www.atsdr.cdc.gov/pfas/health-effects/overview.html (last visited June 25, 2023); see also Our Current
Understanding of the Human Health and Environmental Risks of PFAS, supra note 24.
41 Nadia Barbo, et al., Locally Caught Freshwater Fish Across the United States Are Likely A Significant Source of
Exposure to PFOS and Other Perfluorinated Compounds, 220 ENV'T RES. 115165 3 (2023), available at
https://perma.cc/SB8F-C3Y6.
46 Id. at 4.
4' Patricia A. Fair et al., Perfluoralkyl Substances (PFASs) in Edible Fish Species from Charleston Harbor and
Tributaries, South Carolina, United States: Exposure and Risk Assessment, 171 ENV'T. RES. 266, 273-75 (April
2019), https://berma.cc/7976-XAVLT; Chloe Johnson, Industrial chemicals in Charleston Harbor taint fish and
those who eat them, POST & COURIER (June 4, 2022), htt2s://perma.cc/Z5TM-MB83.

significant source of exposure to PFOS and potentially other perfluorinated compounds for all
persons who consume freshwater fish, but especially for high frequency freshwater fish
consumers."48 Other states have adopted health advisories for fish consumption49 and it is
reasonable to believe that North Carolina will soon because of the high levels of PFAS that have
been recorded in the Cape Fear River. 50
As mentioned, sampling conducted in 2019 confirmed that Harnett Regional discharges
PFAS at concentrations ranging between 104 ppt and 240 ppt. 51 Like 1,4-dioxane, despite this
sampling, Harnett Regional did not disclose its PFAS pollution in its permit application.
IL Harnett Regional receives toxic leachate from the Sampson County Landfill.
The toxic pollution flowing to the utility is likely from the Sampson County Landfill.
Harnett Regional has a contract to treat leachate from the Sampson County landfill, 52 which
accepts sludge from known sources of PFAS and 1,4-dioxane. For instance, Chemours sends the
sludge created from its onsite wastewater treatment processes to the landfill for disposal.53
Additionally, DAK Americas, a resins manufacturer, sends some of the sludge produced during
its wastewater treatment process to the landfill. 54
In 2020, the Department sampled leachate from major landfills across the state as well as
the influent from wastewater plants that accepted the respective leachate. The results of that
sampling confirm that leachate from the Sampson County landfill contains 1,4-dioxane at
concentrations as high as 184 ppb.55 PFOA and PFOS were detected in the leachate at 1,790 and
222 ppt, respectively.56 And GenX (another harmful PFAS) was detected at 10,800 ppt.57
The concentration of PFAS and 1,4-dioxane in the Sampson County landfill's leachate
may have increased over the past several years. DAK Americas has increased its production,
thereby increasing the amount of the chemical it has released into the environment.58 Similarly,
4s Barbo, supra note 45 at 9.
49 See, e.g., PFAS in Fish, MICH. PFAS ACTION RESPONSE TEAM,
https://www.micMgan og_v/pfasresponse/fishandwildlife/fish (last visited May 23, 2023); Fish Consumption
Advisories, MASS.GOV, hltps://www.mass.gov/lists/fish-consuMption-advisories (last visited May 23, 2023); Maine
CDC Issues Additional Advisories on Eating Freshwater Fish Due to PFAS Contamination, ME. DEP'T OF HEALTH
AND HUMAN SERVS. (Apr. 27, 2023), hlWs://www.maine.gov/dhhs/news/maine-cdc-issues-additional-advisories-
eating-freshwater-fish-due-pfas-contamination-thu-04272023-1200.
50 See Frannie Nilsen, N.C. Dep't of Env't Quality, Summer 2022 Water and Fish Collection Event (Aug. 1, 2022),
at slide 2, available at https://www.deg.nc.gov/science-advisoa-panel/mecting-documents/water-and-fish-work-
summary_presentation-ssab-august-1-2022/download?attachment (explaining that sampling collected over the past
year was, in part, to inform fish consumption advisories).
51 Cape Fear Municipal PFAS & 1,4-dioxane Sampling, supra note 4.
5' Harnett Regional Pretreatment Report, supra note 5 at 2.
53 DeVane, supra note 6.
54 DAK Americas, supra note 7 at PDF pg. 14.
55 2020 Landfill Leachate Study, supra note 5 at Table 8.
56 Id.
51 Id. (listing PFPrOPrA, which is another chemical name for GenX).
58 See TRI Toxics Tracker, U.S. ENV 'T PROT. AGENCY,
hlWs:HedU.epa.gov/public/extensions/'fRIToxicsTracker/'fRIToxicsTracker.html#continue (last visited June 25,
2023); see also Dak Americas, 2012-2021 TRI Water Releases Summary (2023), Attachment 5 (spreadsheet pulled
from TRI Toxics Tracker on May 2, 2023 summarizing DAK's releases of 1,4-dioxane by poundage per year).
31

the amount of PFAS-laden sludge produced by Chemours has likely increased. In 2020
Chemours sent 182,460 pounds of sludge for disposal off-site.59 But since that year, the facility
has started to pump and treat heavily contaminated groundwater from the facility increasing the
amount of flow into its treatment system and the sludge produced. Increased amounts of
contaminated sludge sent to the landfill may have led to an increased concentration of both
PFAS and 1,4-dioxane in the landfill's leachate, suggesting that the pollution flowing into
Harnett Regional's wastewater plant could be more severe than previously understood. In
recognition that landfills, such as the Sampson County Landfill are dumping grounds for harmful
industrial chemical pollution, the Department has required that all landfills begin sampling for
PFAS at regular intervals.60 This required sampling will present a fuller picture of the scope of
toxic pollution flowing to the plant.
III. Harnett Regional should be controlling pollution from the landfill through its
pretreatment program.
While Harnett Regional receives PFAS and 1,4-dioxane laden leachate from the Sampson
County landfill, the utility does not appear to regulate the leachate flowing to its facility through
its pretreatment program. Harnett Regional references the contract in its pretreatment annual
report but does not appear to have given the landfill a pretreatment permit nor regularly disclosed
any pollution that the landfill sends to the utility. 61 As a result, the landfill is not mentioned in
any of the Department's permitting materials accompanying this draft permit.
The Clean Water Act requires wastewater plants like Harnett Regional to control
pollutants, including PFAS and 1,4-dioxane, through their pretreatment program. The
pretreatment program governs the discharge of industrial wastewater to wastewater treatment
plants and is intended to place the burden of treating polluted discharges on the entity that creates
the pollution, rather than on the taxpayers that support municipal wastewater plants. Landfills
including landfills with toxic leachate—should be incorporated into pretreatment programs.62
Under the pretreatment requirements, utilities are required to know what waste they
receive from their "Industrial Users."63 EPA has confirmed that this requirement extends to
pollutants that are not conventional or listed as toxic, like PFAS.64 The same is true for 1,4-
dioxane. Utilities like Harnett Regional must instruct their industries, including the landfill, to
identify their pollutants in an industrial waste survey65 and then to apply for a pretreatment
permit by disclosing "effluent data," including information on internal waste streams, necessary
59 Chemours Fayetteville Works, NPDES Permit Application Update NC003573 (June 2021), at PDF pg. 119.
60 Memorandum from Ed Mussler, N.C. Div. of Waste Mgmt., Re: PFAS Monitoring Requirements for Solid Waste
Sanitary Landfills (Mar. 13, 2023), https://penna.cc/X7HN-Q2K3.
61 See generally Harnett Regional Pretreatment Report, supra note 5.
61 See e.g., U.S. Env't Prot. Agency, Effluent Guidelines Program Plan 15 (Jan. 2023), at 6-13,
hUs://www.epa.gov/Vstem/files/documents/2023-01/11143_ELG%20P1an%2015_508.pdf (explaining that
landfills are already part of the effluent guidelines program and that the category should be amended to address
PFAS discharges into surface waters or wastewater plants).
63 40 C.F.R. § 403.8(f)(2).
64 See U.S. Env't Prot. Agency, PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024 14 (Oct.
2021), available at https://perma.cc/LK4U-RLBH; EPA's PFAS NPDES Guidance, supra note 11 at 4.
65 40 C.F.R. § 403.8(f)(2)(ii); U.S. Env't Prot. Agency, Introduction to the National Pretreatment Program, at 4-3
(June 2011), available at hlWs://www.evansvillegov.org/egov/documents/1499266949_62063.pdf.
7

to evaluate pollution controls.66 Significant industrial users are further required to provide
information on "[p]rincipal products and raw materials ... that affect or contribute to the
[significant industrial user's] discharge."67
A utility is required to regulate its industries so that industries do not cause "pass
through" or "interference," or otherwise violate pretreatment laws.68 "Pass through" is when an
industrial discharge causes the wastewater plant to violate its own NPDES permit,69 including
standard conditions such as the one requiring permittees to "take all reasonable steps to minimize
or prevent any discharge or sludge use" that has a "reasonable likelihood of adversely affecting
human health or the environment."70 Industries are also not permitted to interfere with publicly -
owned treatment works operations. "Interference" occurs when a discharge disrupts the treatment
works' operation or its sludge use or disposal and violates the facility's NPDES permit or other
applicable laws.71 Violating the prohibitions on pass through or interference constitutes a
violation of the Clean Water Act's pretreatment standards and requirements.72 Utilities must also
act "immediately and effectively to halt or prevent any discharge of pollutants to the [treatment
works] which reasonably appears to present an imminent endangerment to the health or welfare
of persons."73
These rules are how the Clean Water Act "assures the public that [industrial] dischargers
cannot contravene the [Clean Water Act's] objectives of eliminating or at least minimizing
discharges of toxic and other pollutants simply by discharging indirectly through [wastewater
treatment plants] rather than directly to receiving waters."74 The laws governing the program
ensure that municipally owned wastewater plants do not become dumping grounds for
uncontrolled industrial waste.
IV. The Department has the authority and obligation to set limits for PFAS and 1,4-
dioxane in this NPDES permit.
In December 2022, EPA released guidance instructing state agencies how to address
PFAS through existing NPDES authorities.75 The same tools embodied in the guidance exist for
1,4-dioxane. Federal and state law, as well as EPA's guidance make clear that if the landfill is
66 U.S. Env't Prot. Agency, Industrial User Permitting Guidance Manual (2012), at 4-2 to 4-3, available at
https://www.epa.gov/sites/default/files/2015-10/documents/industrial_user permitting_ manual_full.pdf.
67 40 C.F.R. § 122.210)(6)(ii)(C).
68Id. §§ 403.8(a), 403.5(a)(1).
69 Pass through is defined as "a discharge which exits the [treatment works] into waters of the United States in
quantities or concentrations which, alone or in conjunction with a discharge or discharges from other sources, is a
cause of a violation of any requirement of the [treatment works'] NPDES permit (including an increase in the
magnitude or duration of a violation)." Id. § 403.3 (p).
70Id. § 122.41(d).
71 Id. § 403.3(k).
72 40 C.F.R. § 403.5(a)(1).
73Id. § 403.8(f)(1)(vi)(B).
74 General Pretreatment Regulations for Existing and New Sources, 52 Fed. Reg. 1586, 1590 (Jan. 14, 1987)
(codified at 40 C.F.R. § 403).
75 EPA's PFAS NPDES Guidance, supra note 11.

continuing to send PFAS and 1,4-dioxane laden sludge to the facility, the Department must
consider effluent limits to control Harnett Regional's pollution.
The Clean Water Act requires permitting agencies to, at the very least, incorporate
technology -based effluent limitations on the discharge of pollutants.76 When EPA has not issued
a national effluent limitation guideline for a particular industry,77 permitting agencies must
implement technology -based effluent limits on a case -by -case basis using their "best professional
judgment."78 North Carolina water quality laws further state that utilities must be treated like an
industrial discharger if an industrial user "significantly impact[s]" a wastewater treatment
system.79 In this situation, the agency must consider technology -based effluent limits for the
utility, even if effluent limits and guidelines have not been published and adopted.80
Effective treatment technologies for PFAS are available. Relevant here, a reverse osmosis
treatment system installed at the Seneca Meadows Landfill in New York has virtually eliminated
PFAS discharges from the landfill sent to the Seneca Falls wastewater plant.81 The reverse
osmosis plant costs the landfill approximately three cents per gallon suggesting that the treatment
is not only effective, but also affordable.82 Like reverse osmosis, granular activated carbon is a
cost-effective and efficient technology that can reduce PFAS concentrations to virtually
nondetectable levels. A granular activated carbon treatment system at the Chemours' facility, for
example, has reduced PFAS concentrations as high as 345,000 ppt from a creek contaminated by
groundwater beneath the facility to nearly nondetectable concentrations.83 The Department must
consider the feasibility of using these technologies or similarly effective technologies to control
Harnett Regional's PFAS discharges —either at the point of the discharge or at the landfill.
As with PFAS, treatment technologies for 1,4-dioxane are available. For instance, the
chemical can be removed using advanced oxidation processes, such as using ultraviolet light in
combination with hydrogen peroxide. 84 Such a process has been used at the Tucson International
76 40 C.F.R. § 125.3(a) ("Technology -based treatment requirements under section 301(b) of the Act represent the
minimum level of control that must be imposed in apermit..." (emphasis added)); see also 33 U.S.C. § 1311; see
also EPA's PFAS NPDES Guidance, supra note 11 at 3.
77 33 U.S.C. § 1314(b).
78 40 C.F.R. § 125.3; see also 33 U.S.C. § 1342(a)(1)(B); 15A N.C. Admin. Code 2B.0406.
79 15A N.C. Admin. Code 2B.0406(a)(1).
80 Id.
81 See David Shaw, Two Area Landfills Show High PFAS Levels in Leachate, Finger Lakes Times (Apr. 9, 2022),
https://www.fltimes. com/news/two-area-landfills-show-high-pfas-levels-in-leachate/article_8lf25f53-4c2a-58ee-
a378-8c35c5bcf872.htm1; Cornerstone Engineering and Geology, Seneca Meadows Landfill 2022 Annual Report
209-4233133 (Mar. 1, 2023), at 3-1 available ath1Ws://perma.cc/LTQ2W-7CZW.
82 Seneca Meadows Landfill 2022 Annual Report, supra note 81 at 7-3.
ss See Parsons, Engineering Report — Old Outfall 002 GAC Pilot Study Results (Sept. 2019), available at
https://www.chemours.com/ja/-/media/files/corporate/ 12e-old-outfa11-2-gac-pilot-report-2019-09-
30.pdf?rev=6el242091aa846f888afa895eff8Oe2e&hash=040CAA7522E3D64B9E5445ED6F96BOFB; see also
Chemours Outfall 003, NPDES No. NCO089915 Discharge Monitoring Reports (2020-2022), available at
hUs://perma.cc/8YND-XT5M.
" Amie C. McElroy, et al., 1, 4-Dioxane in drinking water: emerging for 40 years and still unregulated, 7 CURRENT
OPINION IN ENV'T SCIENCE & HEALTH 117, 119 (2019), available at https://agris.fao.org/agris-
search/search. do?recordID=U S201900256076.
0J

Airport Area Superfund Site to remove legacy 1,4-dioxane contamination.85 That treatment
system can remove over 97 percent of the chemical from polluted water. 86 Treatment technology
for 1,4-dioxane has also been installed at industries in North Carolina that discharge into
municipal sewer systems.87 The Department must assess treatment technology available to
control Harnett Regional's 1,4-dioxane waste.
If technology -based limits are not enough to ensure compliance with water quality
standards, the Department must include water quality -based effluent limits in the permit.88 North
Carolina's toxic substances standard protects the public from the harmful effects of toxic
chemicals, like PFAS and 1,4-dioxane.89 For instance, the toxic substances standard mandates
that the concentration of cancer -causing chemicals shall not result in "unacceptable health risks,"
defined as "more than one case of cancer per one million people exposed."90 In order to comply
with the Clean Water Act, therefore, the Department must analyze appropriate treatment
technology and then determine if a discharger's pollution has the "reasonable potential to cause,
or contribute" to pollution at levels that could harm human health.91
In acknowledgement of this requirement, the Department has already calculated effluent
limits for 1,4-dioxane using this water quality standard43.7 ppb for the expanded wastewater
plant.92 The Department, however, did not set limits in the draft permit citing a need for more
information.93 If the Department truly needs more information to know if the utility will exceed
the calculated limits, it needs to demand that information during the application process. It
cannot ask communities downstream to wait an undetermined amount of time for the Department
to reopen the permit.
While the Department has calculated possible limits for 1,4-dioxane, it has neglected to
do the same for PFAS. This is particularly worrisome when the concentrations of PFAS in the
landfill's leachate are so high. The Department must evaluate the utility's PFAS discharges and
limit them appropriately.
85 See Advanced Treatment for 1, 4-Dioxane Tucson Removes Contamination Through UV -oxidation, TROJANUV
CASESTUDIES (2019), available at hlWs://www.resources.trojanuv.com/wp-content/uploads/2018/05/Treatment-of-
Groundwater-Contaminated-with-14-Dioxane-Tucson-Arizona-Case-Study-Environmental-Contaminant-
Treatment.pdf.
86 Id. at 2; see also Educational Brochure, TUCSON AIRPORT AREA REMEDIATION PROJECT, available at
https://www.tucsonaz.gov/files/water/docs/AOP TARP educational_signs.pdf.
81 See City of Greensboro, EMC SOC WQ S19-010 Year One Report: May 1, 2021 — April 30, 2022 4 (June 13,
2022), available at https://www.greensboro-nc.gov/home/showpublisheddocument/53017/637908166316270000.
88 40 C.F.R. § 122.44(d)(1)(i); see also 33 U.S.C. § 13 1 l(b)(1)(C); 15A N.C. Admin. Code 2H.0112(c) (stating that
Department must "reasonably ensure compliance with applicable water quality standards and regulations").
19 15A N.C. Admin. Code 2B.0208.
90 Id. at 2B.0208(a)(2)(B).
91 40 C.F.R. § 122.44(d)(1)(i).
92 North Harnett Draft Fact Sheet, supra note 3 at 15.
93 Id.
10

V. The Department has the authority and obligation to set conditions requiring
Harnett Regional to control any PFAS and 1,4-dioxane coming from the landfill.
In addition to using effluent limits to control PFAS and 1,4-dioxane pollution, the
Department has tools and obligations under the Clean Water Act's pretreatment program.94 Just
last December, EPA recognized that incorporating PFAS into the pretreatment program is an
important tool for state agencies to utilize when faced with wastewater treatment plants that are a
source of PFAS contamination.95 The same is true for 1,4-dioxane.
Utilities like Harnett Regional have broad authority to control their industries so that
municipally owned treatment works can comply with the pretreatment laws discussed in Section
III. They can "deny or condition" pollution permits for industries, control industrial pollution
"through Permit, order or similar means," and "require" "the installation of technology."96
Utilities can also implement local limits to control industrial pollution sent to treatment works in
the first place.97 In recognition of that authority, EPA's PFAS NPDES Guidance explicitly
directs that permits issued to wastewater treatment plants, like Harnett Regional, "contain
requirements to identify and locate all possible [industrial users]" that is "expected or suspected
for PFAS discharges."98 This directive is all the more important here because Harnett Regional
has not previously reported information about the landfill in its annual reports.99 Once sources
are identified, EPA recommends that utilities develop local limits for PFAS or impose best
management practices to control the pollution at the source.100
The Department, as the approval authority of Harnett Regional's pretreatment program
should incorporate similar directives here. The Department should therefore include conditions
in Harnett Regional's permit to require the town to: (1) add the Sampson County landfill to its
industrial user survey, (2) determine all industrial sources of PFAS and 1,4-dioxane, and (3)
control any industrial sources of the chemicals "through Permit, order," "the installation of
technology," 101 local limits,102 or other means under the Clean Water Act pretreatment program.
As stated in EPA's NPDES Permit Writers' Manual, "NPDES permits drive the
development and implementation of pretreatment programs." 103 They do so by requiring "control
mechanisms issued to significant industrial users," "compliance monitoring activities," and
"swift and effective enforcement." 104 The Department must impose the above conditions in
Harnett Regional's permit for PFAS and 1,4-dioxane.
94 40 C.F.R. § 403.8.
95 EPA's PFAS NPDES Guidance, supra note 11 at 4.
96 40 C.F.R. § 403.8(f)(1).
97 Id. § 403.5.
9s Id.
99 See Harnett Regional Pretreatment Report, supra note 5.
100 EPA's PFAS NPDES Guidance, supra note 11 at 4.
101 40 C.F.R. § 403.8(f)(1) (emphasis added).
102Id. § 403.5.
10s U.S. Env't Prot. Agency, NPDES Permit Writers' Manual 9-10 (2010), available at
https://www.epa.gov/sites/default/files/2015-09/documents/Twm 2010.pdf.
104 Id
11

VL Conclusion.
In summary, the Department must use this NPDES permit to control PFAS and 1,4-
dioxane waste being released into the Cape Fear River upstream of a city's water supply. The
Department should impose the permit limit it has already calculated for 1,4-dioxane and
calculate a similar limit for PFAS. In addition, because this contamination is likely coming from
the Sampson County landfill, which does not appear to be presently controlled through Harnett
Regional's pretreatment program, the Department must include conditions instructing the utility
to add the landfill to its pretreatment program and control the toxic waste at the source —before it
reaches the wastewater treatment plant. Because the draft permit fails to meet these
requirements, it should be amended.
Thank you for considering these comments. Please contact me at 919-967-1450 or
hnelsonAselcnc. org if you have any questions regarding this letter.
Sincerely,
4"V,J�-)"Nv
Hannah M. Nelson
SOUTHERN ENVIRONMENTAL LAW CENTER
601 W. Rosemary Street, Suite 220
Chapel Hill, NC 27516
12

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ATTACHMENT 2

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FS. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
°y OFFICE OF WATER
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December 5, 2022
MEMORANDUM
SUBJECT: Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program
and Monitoring Programs
FROM: Radhika Fox
Assistant Administrator
TO: EPA Regional Water Division Directors, Regions 1-10
The National Pollutant Discharge Elimination System (NPDES) program is an important tool
established by the Clean Water Act (CWA) to help address water pollution by regulating point sources
that discharge pollutants to waters of the United States. Collectively, the U.S. Environmental Protection
Agency (EPA) and states issue thousands of permits annually, establishing important monitoring and
pollution reduction requirements for Publicly Owned Treatment Works (POTWs), industrial facilities,
and stormwater discharges nationwide. The NPDES program interfaces with many pathways by which
per -and polyfluoroalkyl substances (PFAS) travel and are released into the environment, and ultimately
impact water quality and the health of people and ecosystems. Consistent with the Agency's
commitments in the October 2021 PFAS Strategic Roadinap: EPA's Commitments to Action 2021-2024
(PFAS Sh ategic Roadinap), EPA will work in cooperation with our state -authorized permitting
authorities to leverage the NPDES program to restrict the discharge of PFAS at their sources. In addition
to reducing PFAS discharges, this program will enable EPA and the states to obtain comprehensive
information on the sources and quantities of PFAS discharges, which can be used to inform appropriate
next steps to limit the discharges of PFAS.
This memorandum provides EPA's guidance to states and updates the April 28, 2022 guidance' to EPA
Regions for addressing PFAS discharges when they are authorized to administer the NPDES permitting
program and/or pretreatment program. These recommendations reflect the Agency's commitments in the
PFAS Strategic Roadmap, which directs the Office of Water to leverage NPDES permits to reduce
PFAS discharges to waterways "at the source and obtain more comprehensive information through
tnonitoring on the sources of PFAS and quantity of PFAS discharged by these sources." While the
Office of Water works to revise Effluent Limitation Guidelines (ELGs) and develop water quality
criteria to support technology -based and water quality -based effluent limits for PFAS in NPDES
permits, this memorandum describes steps permit writers can implement under existing authorities to
reduce the discharge of PFAS.
Addressing PFAS Discharges in EPA -Issued NPDES Permits and Expectations Where EPA is the Pretreatment Control
Authority, littys://www.eya.eov/system/tiles/documentsl2O22-04/npdes pfas-memo.pdf.

This memorandum also provides EPA's guidance for addressing sewage sludge PFAS contamination
more rapidly than possible with monitoring based solely on NPDES permit renewals. States may choose
to monitor the levels of HAS in sewage sludge across POTWs and then consider mechanisms under
pretreatment program authorities to prevent the introduction of PFAS to POTWs based on the
monitoring results,
EPA recommends that the following array of NPDES and pretreatment provisions and monitoring
programs be implemented by authorized states and POTWs, as appropriate, to the fullest extent available
under state and local Iaw. NPDES and pretreatment provisions may be included when issuing a permit
or by modifying an existing permit pursuant to 40 CFR 122.62.
A. Recommendations for Applicable Industrial Direct Dischargers
1. Applicability: Industry categories known or suspected to discharge PFAS as identified on page 14
of the PFAS Strategic Roadmap include: organic chemicals, plastics & synthetic fibers (OCPSF);
metal finishing; electroplating; electric and electronic components; landfills; pulp, paper &
paperboard; leather tanning & finishing; plastics molding & forming; textile mills; paint formulating,
and airports. This is not an exhaustive list and additional industries may also discharge PFAS. For
example, Centralized Waste Treatment (CWT) facilities may receive wastes from the
aforementioned industries and should be considered for monitoring. There may also be categories of
dischargers that do not meet the applicability criteria of any existing ELG; for instance, remediation
sites, chemical manufacturing not covered by OCPSF, and military bases.
EPA notes that no permit may be issued to the owner or operator of a facility unless the owner or
operator submits a complete permit application in accordance with applicable regulations, and
applicants must provide any additional information that the permitting authority may reasonably
require to assess the discharges of the facility (40 CFR 122,21(e), (g)(13)).2 The applicant may be
required to submit additional information under CWA Section 308 or under a similar provision of
state law.
2. Effluent -and wastewater residuals monitoring: In the absence of a final 40 CFR Part 136 method,
EPA recommends using CWA wastewater draft analytical method 1633 (see 40 CFR
122.21(e)(3)(ii) and 40 CFR 122.44(i)(1)(iv)(B)). EPA also recommends that monitoring include
each of the 40 PFAS parameters detectable by draft method 1633 and be conducted at least quarterly
to ensure that there are adequate data to assess the presence and concentration of PFAS in
discharges. All PFAS monitoring data must be reported on Discharge Monitoring Reports (DMRs)
(see 40 CFR 122.41(1)(4)(i)). The draft Adsorbable Organic Fluorine CWA wastewater method 1621
can be used in conjunction with draft method 1633, if appropriate. Certain industrial processes may
generate PFAS-contaminated solid waste or air emissions not covered by NPDES permitting and
permitting agencies should coordinate with appropriate state authorities on proper containment and
disposal to avoid cross -media contamination. EPA's draft analytical method 1633 may be
appropriate to assess the amount and types of PFAS for some of these wastestreams.3
2 For more, see NPDES Permit Writer's Manual Section 4.5.1.
3 See https://www.epa.gov/water-research/pfas-analytical-metliods-development-and-sampling-research for a list of EPA -
approved methods for other media.
2

3. Best Management Practices (BMPs) for discharges of PFAS, including product substitution,
reduction, or elimination of PFAS, as detected by draft method 1633: Pursuant to 40 CFR
122.44(k)(4), EPA recommends that NPDES permits for facilities incorporate the following
conditions when the practices are "reasonably necessary to achieve effluent limitations and standards
or to carry out the purposes and intent of the CWA."4
a. BMP conditions based on pollution prevention/source reduction opportunities, which may
include:
i. Product elimination or substitution when a reasonable alternative to using PFAS is available
in the industrial process.
ii. Accidental discharge minimization by optimizing operations and good housekeeping
practices.
iii. Equipment decontamination or replacement (such as in metal finishing facilities) where
HAS products have historically been used to prevent discharge of legacy PFAS following
the implementation of product substitution.
b. Example BMP permit special condition language:
i. PFAS pollution prevention/source reduction evaluation: Within 6 months of the effective
date of the permit, the facility shall provide an evaluation of whether the facility uses or has
historically used any products containing PFAS, whether use of those products or legacy
contamination reasonably can be reduced or eliminated, and a plan to implement those steps.
ii. Reduction or Eliinination: Within 12 months of the effective date of the permit, the facility
shall implement the plan in accordance with the HAS pollution prevention/source reduction
evaluation.
iii. Annual Report: An annual status report shall be developed which includes a list of potential
PFAS sources, summary of actions taken to reduce or eliminate PFAS, any applicable source
monitoring results, any applicable effluent results for the previous year, and any relevant
adjustments to the plan, based on the findings.
iv. Reporting: When EPA's electronic reporting tool for DMRs (called "NetDMR') allows for the
permittee to submit the pollution prevention/source reduction evaluation and the annual
report, the example permit language can read, "The pollution prevention/source reduction
evaluation and annual report shall be submitted to EPA via EPA's electronic reporting tool
for DMRs (called "NetDMR").
4. BMPs to address PFAS-containing firefighting foams for stormwater permits: Pursuant to
122.44(k)(2), where appropriate, EPA recommends that NPDES stormwater permits include BMPs
to address Aqueous Film Forming Foam (AFFF) used for firefighting, such as the following:'
a. Prohibiting the use of AFFFs other than for actual firefighting.
b. Eliminating PFOS and PFOA -containing AFFFs.
c. Requiring immediate clean-up in all situations where AFFFs have been used, including
diversions and other measures that prevent discharges via storm sewer systems.
5. Permit Limits: As specified in 40 CFR 125.3, technology -based treatment requirements under
CWA Section 301(b) represent the minimum level of control that must be imposed in NPDES
permits. Site -specific technology -based effluent limits (TBELs) for PFAS discharges developed on a
best professional judgment (BPJ) basis may be appropriate for facilities for which there are no
applicable effluent guidelines (see 40 CFR 122.44(a), 125.3). Also, NPDES permits must include
water quality -based effluent limits (WQBELs) as derived from state water quality standards, in
4 For more on BMPs, see NPDES Permit Writer's Manual Section 9.1 and EPA Guidance Manual for Developing Best
Management Practices.
'Naval Air Station Whidbey Island MS4 perinit incorporates these provisions.

addition to TBELs developed on a BPJ basis, if necessary to achieve water quality standards,
including state narrative criteria for water quality (CWA Section 301(b)(1)(C); 40 CFR 122.22(d)).
If a state has established a numeric criterion or a numeric translation of an existing narrative water
quality standard for PFAS parameters, the permit writer should apply that numeric criterion or
narrative interpretation in permitting decisions, pursuant to 40 CFR 122.44(d)(1)(iii) and
122.44(d)(1)(vi)(A), respectively.
B. Recommendations for Publicly Owned Treatment Works
f. Applicability: All POTWs, including POTWs that do not receive industrial discharges, and
industrial users (IUs) in the industrial categories above.
2. Effluent, influent, and biosolids monitoring: In the absence of a final 40 CFR Part 136 method,
EPA recommends using CWA wastewater draft analytical method 1633 (see 40 CFR
122.21(e)(3)(ii) and 40 CFR 122.44(i)(1)(iv)(B)). EPA also recommends that monitoring include
cacti of the 40 PFAS parameters detectable by draft method 1633 and be conducted at least quarterly
to ensure that there are adequate data to assess the presence and concentration of HAS in
discharges. All PFAS monitoring data must be reported on DMRs (see 40 CFR 122.41(1)(4)(i)). The
draft Adsorbable Organic Fluorine CWA wastewater method 1621 can be used in conjunction with
draft method 1633, if appropriate.
3. Pretreatment program activities:
a. Update IU Inventory: Permits to POTWs should contain requirements to identify and locate all
possible IUs that might be subject to the pretreatment program and identify the character and
volume of pollutants contributed to the POTW by the IUs (see 40 CFR 403,8(0(2)). As EPA
regulations require, this information shall be provided to the pretreatment control authority (see
40 CFR 122.440) and 40 CFR 403.8(f)(6)) within one year. The IU inventory should be revised,
as necessary, to include all IUs in industry categories expected or suspected of PFAS discharges
listed above (see 40 CFR 403.12(i)).6
b. Utilize BMPs and pollution prevention to address PFAS discharges to POTWs. EPA
recommends that POTWs:
i. Update IU permits/control mechanisms to require quarterly monitoring. These IUs should be
input into the Integrated Compliance Information System (ICIS) with appropriate linkage to
their respective receiving POTWs. POTWs and states may also use their available authorities
to conduct quarterly monitoring of the IUs (see 40 CFR 403.8(f)(2), 403.10(e) and (f)(2)).
ii. Where authority exists, develop IU BMPs or local limits. 40 CFR 403.5(c)(4) authorizes
POTWs to develop local Iimits in the forth of BMPs. Such BMPs could be like those for
industrial direct discharges described in A.3 above.
iii. Li the absence of local limits and POTW legal authority to issue IU control mechanisms, state
pretreatment coordinators are encouraged to work with the POTWs to encourage pollution
prevention, product substitution, and good housekeeping practices to make meaningful
reductions in PFAS introduced to POTWs.
s ELG categories of airport deicing, landfills, textile mills, and plastics molding and forming do not have categorical
pretreatment standards, and therefore small -volume indirect dischargers in those categories would not ordinarily be
considered Significant Industrial Users (SIUs) and may not be captured on an existing IU inventory. IUs under the Paint
Formulating category are only subject to Pretreatment Standards for New Sources (PSNS), and existing sources may need to
be inventoried.
4

C. Recommended Biosolids Assessment
1. Where appropriate, states may work with their POTWs to reduce the amount of PFAS
chemicals in biosolids, in addition to the NPDES recommendations in Section B above,
following these general steps:?
a. EPA recommends using draft method 1633 to analyze biosolids at POTWs for the presence of 40
HAS chemicals.$
b. Where monitoring and IU inventory per section B.2 and B.3.a above indicate the presence of
PFAS in biosolids from industrial sources, EPA recommends actions in B.3.b to reduce PFAS
discharges from IUs.
c. EPA recommends validating HAS reductions with regular monitoring of biosolids. States may
also use their available authorities to conduct quarterly monitoring of the POTWs (see 40 CFR
403.10(f)(2)).
D. Recommended Public Notice for Draft Permits with PFAS-Specific Conditions
1. In addition to the requirements for public notice described in 40 CFR 124.10, EPA
recommends that NPDES permitting authorities provide notification to potentially affected
downstream public water systems (PWS) of draft permits with PFAS-specific monitoring,
BMPs, or other conditions:
a. Public notice of the draft permit would be provided to potentially affected PWS with intakes
located downstream of the NPDES discharge.
b. NPDES permit writers are encouraged to collaborate with their drinking water program
counterparts to determine on a site -specific basis which PWS to notify.
i. EPA's Drinking Water Mapping Application to Protect Source Waters D( WMAPS) tool may
be helpful as a screening tool to identify potentially affected PWS to notify.
e. EPA will provide instructions on how to search for facility -specific discharge monitoring data
in EPA's publicly available search tools.
I EPA is currently evaluating the potential risk of PFOA and PFOS in biosolids and supporting studies and activities to
evaluate the presence of PFOA and PFOS in biosolids. This recommendation is not meant to supersede the PFOA and PFOS
risk assessment or supporting activities. The conclusions of the risk assessment and supporting studies may indicate that
regulatory actions or more stringent requirements are necessary to protect human health and the environment.
B While water quality monitoring activities (including monitoring of PFAS associated with NPDES permit or pretreatment
requirements) at POTWs are generally not eligible for Clean Water State Revolving Fund (CWSRF), monitoring for the
specific purpose of project development (planning, design, and construction) is eligible. Monitoring in this capacity, and
within a reasonable timeframe, can be integral to the identification of the best solutions (through an alternatives analysis) for
addressing emerging contaminants and characterizing discharge and point of disposal (e.g., land application of biosolids).
Though ideally the planning and monitoring for project development would result in a CWSRF-eligible capital project, in
some instances, the planning could lead to outcomes other than capital projects to address the emerging contaminants.
5

ATTACHMENT 3

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
PT_ Contacts _Formal_Name»
PT Contacts —Title »
«WWTP Name»
PT Contacts B 1 Addr 1»
City, NC « PT Contacts B 1 Zip»
Dear « PT Contacts Formal Name»,
NORTH CAROLINA
Environmental Quality
April 30, 2019
Several emerging compounds have been found in North Carolina waters, specifically, 1,4-dioxane and a
group of chemicals known as perfluoroalkyl and polyfluoroalkyl substances (PFAS, also referred to as
PFCs). Data reviewed as part of the UCMR (Unregulated Contaminant Monitoring Rule) has indicated
elevated concentrations for these compounds in the Cape Fear River Basin. In addition, ambient
monitoring performed by DWR's Water Sciences Section have confirmed the presence of these
compounds in the Cape Fear River Basin (https:Hdeq.nc.gov/about/divisions/water-resources/water-
resources-data/water-sciences-home-page/ 1-4-dioxane).
Background
1,4-dioxane is a clear liquid that is highly miscible in water. It has historically been used as a solvent
stabilizer and is currently used for a wide variety of industrial and manufacturing purposes. The
compound can be found in industrial solvents, paint strippers, and varnishes and is often produced as a
by-product of chemical processes to manufacture soaps, plastics, and other consumer products.
The U.S. EPA has not established a maximum contaminant level for 1,4-dioxane in drinking water but
has characterized it as "likely to be carcinogenic to humans" and has established a drinking water health
advisory of 35 ug/L. North Carolina has a calculated human health surface water criterion with an
associated estimated lifetime cancer risk of one in one million at a concentration for 1,4-dioxane of 0.35
ug/L in water supplies and 80 ug/L in all other waterbodies (15A NCAC 02B .0208).
PFAS compounds are most often associated with nonstick coatings, plating operations, firefighting foams,
and stain- and water-resistant treatments for clothing, furniture and carpeting.
PFAS has been found to have adverse effects in laboratory animals and humans when ingested. To
provide Americans with a margin of protection from a lifetime of exposure to PFAS from drinking water,
EPA has established the health advisory levels of 70 ng/L individually and combined for two of the most
common PFAS compounds: PFOA (perfluorooctanoic acid) and PFOS (perfluorooctane sulfonate).
Required Actions
To assess the levels of these compounds throughout the Cape Fear and to assist DWR in developing a
Management Strategy to address and reduce levels of these emerging compounds, POTWs with approved
Pretreatment Programs are hereby required to perform investigative monitoring at the treatment plant
influent for 1,4-dioxane and total PFAS monthly for three consecutive months starting in July 2019. Such
investigative actions can be required under 15A NCAC 02B .0508 (b)(2) and G.S. 143-215.66.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
to: �-512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTM C-OLINA
o.�memmE.A­WQ�.ifly /"� 919.707.9000

Samples collected should be representative of the typical wastewater flow to your facility. Sufficiently
sensitive test methods shall be used.
To locate a lab capable of performing the PFAS analysis, please visit
https://www.denix.osd.mil/edqw/accreditation/accreditedlabs/and search by method "PFAS
by LCMSMS Compliant with Table B-15 of QSM 5.1 or Latest Version".
■ Grab samples are required to avoid cross -contamination and ensure consistency.
■ Please refer to Attachment B for the analyte list. Each facility shall provide results for as
many of the PFAS compounds as possible, specifically including PFOA and PFOS.
To locate a lab certified to perform 1,4-dioxane analysis using EPA Method 624.1, please
visit https:Hdeq.nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-
home-page/laboratory-certification-branch/certified-laborator l�g_s. Be sure to specify
1,4-dioxane by EPA method 624.1 when contacting the labs.
All sample results shall be submitted to PERCS by October 31, 2019 and shall be sent to the
following email address (please include the lab sheets with the test results):
[e-mail]. Please include your NPDES permit number in your
subject heading.
Attachment A outlines recommended actions on how to assess potential sources, monitor, and work with
your industries to reduce potential sources of these compounds. You are not required to implement these
actions until you have received notification from the Division to do so. However, if your influent samples
exceed the human health surface water criteria for 1,4-dioxane pertaining to your receiving stream
classification, contact your DWR Pretreatment Program coordinator to discuss your facility's allowable
discharge concentration. If your influent levels exceed your facility's allowable discharge concentration,
you should take proactive steps to begin reducing or eliminating 1,4-dioxane discharges to your facility.
The PFAS drinking water health advisory of 70 ng/L is the target concentration for the sum of sample
results for PFOA and PFOS. Therefore, actions to reduce these compounds will be required for facilities
with influent levels greater than a total PFAS value of 70 ng/L if there are water supply intakes
downstream of your facility's discharge. Again, you are not required to implement actions in Attachment
A until you have received notification from the Division to do so. Please be aware that criteria are being
developed for PFAS compounds and are likely to be lower than the current drinking water advisory level.
Results for PFAS that do not currently require action may trigger reduction activities in the future.
More Information
DWR will be holding a technical informational session on May 21, 2019 from 10 am to 3 pm at the
Herbert C. Young Community Center, 101 Wilkinson Ave., Cary, NC. At this time registration for this
workshop is limited to approved Pretreatment Program POTW staff due to space limitations. Please
register at http://tinyurl.com/NCECTIS.
The Department looks forward to working closely with you on this important public health issue. Data
from the UCMR and other sources will continue to be evaluated to determine next steps to reduce the
discharge of 1,4-dioxane and PFAS throughout the State.
Please contact the appropriate PERCS staff member if you have any questions or concerns: Deborah
Gore 919-707-3624, Monti Hassan 919-707-3626 or Vivien Zhong 919-707-3627 or via email
(firstname .lastname &ncdenr. gov).
Sincerely,
Linda Culpepper, Director
Division of Water Resources, NCDEQ
Cc: Dana Satterwhite, WSS

Attachment A
<due dates for activities will be added on a case -by -case basis>
Conduct Initial Screening: Conduct a review of your industrial users to identify industrial users
that may be potential significant sources of 1,4-dioxane and/or PFAS. The following types of
industrial users may be potential significant sources for these chemicals:
Potential Sources of PFOA & PFOS for POTWs:
• Platers/Metal Finishers
• Paper and Packaging Manufacturers
• Tanneries and Leather/Fabric/Carpet Treaters
• Manufacturers of Parts with PTFE (polytetrafluoroethylene, Teflon type) Coatings (i.e., Bearings)
• Landfill Leachate
• Centralized Waste Treaters
• Contaminated Sites
• Firefighting Foam
• Any other known or suspected sources of PFAS
Potential Sources of 1,4-dioxane for POTWs:
• Paints, Varnishes and Lacquers Manufacturers
• Cosmetics, Deodorants, Cleaning and Detergent Manufacturers
• Pharmaceutical Manufacturers
• Organic and Inorganic Chemical Manufacturers
• Plastics manufacturers or recyclers
• Rubber Manufacturers
• Centralized Waste Treaters
• Photographic Film, Paper and Plate Manufacturers, Commercial Printing
• Electroplating/ Polishing, Semiconductors and Electronic Components Manufacturers
• Pesticide and Agriculture Manufacturers
• Solid Waste Combustors and Incinerators
• Cement Manufacturers
• Abrasive Product Manufacturers
• Roofing, Siding, and Insulation Material Merchant Wholesalers
• Scintillating Fluids Manufacturers
• Dyes and Fiber Manufacturers
• Any other known or suspected sources of 1,4-dioxane
2. Develop a Monitoring Plan: Once you have developed a list of potential 1,4-dioxane and PFAS
sources, you will need to evaluate each one to determine whether it is a probable source of 1,4-
dioxane or PFAS and develop a strategy for sampling these probable sources. You will likely need to
review records and interview your contacts to find out which sources use/have used or accept/have
accepted 1,4-dioxance or PFAS containing materials or wastes.
Once you have a list of probable sources, develop a plan to monitor them. Your plan will most likely
include your commitment to monitor all your probable sources, when and where you will sample,
how you will conduct sampling, transport your samples and analyze them at your chosen laboratory.
You may be able to eliminate several probable sources located near one another with one downstream
collection system sample. If you have many probable sources, you may also need more time to

conduct monitoring. No pre -approval of your plan is required. You should submit your plan to
PERCS by DATE.
Perform Source Monitoring: Sample the discharge from each probable source identified in your
monitoring plan for 1,4-dioxane or PFAS depending on your identification as a probable source
following the sampling procedures your chosen labs recommended. Begin this sampling no later
than DATE.
4. Reduce/Eliminate Sources: If significant sources of 1,4-dioxane or PFAS are found through source
monitoring, you are required to follow-up with the source(s) to reduce and/or eliminate 1,4-dioxane
or PFAS in their effluent. Source reduction and elimination efforts may include product substitution,
operational controls, pretreatment and clean-up of historical contamination.
Submit an Interim Report: Summarize the list of potential sources and your determination
regarding whether they are a probable source, sampling data collected, and evaluation conducted to -
date for items 1 — 4 above to the PERCS Unit by DATE.
6. Evaluate Impacts: If you find sources discharging 1,4-dioxane or PFAS to your WWTP from this
monitoring, you are required to monitor your WWTP influent and effluent for the chemicals detected
at the sources for three consecutive months beginning DATE. If effluent results are found to be
greater than the applicable criterion you are required to continue working with those sources to
achieve further reductions.
7. Submit a Summary Report: Submit the results of any additional monitoring data (WWTP
influent, effluent, or source monitoring) and summary of 1,4-dioxane and PFAS source reduction
and/or elimination effort to DWR/PERCS by DATE. Staff will review the information reported and
will contact you about any required follow-up actions.

Attachment B
To locate a lab capable of performing the PFAS analysis, please visit
https://www.denix.osd.mil/edqw/accreditation/accreditedlabs/and search by method "PFAS by LCMSMS
Compliant with Table B-15 of QSM 5.1 or Latest Version". Grab samples are required to avoid cross -
contamination and ensure consistency.
It is the Division's understanding that this test method is capable of providing results for the listed PFAS
compounds listed below. The Division recognizes that there may be variations from lab to lab. Each
facility shall provide results for PFOA, PFOS, and shall include as many of the following PFAS
compounds as possible:
Analyte Name
Acronym
Fluorinated
Carbon Chain
Length
Molecular
Formula
CAS
Number
Perfluorotetradecanoic acid
PFTeA
C14
C131727COOH
376-06-7
Perfluorotridecanoic acid
PFTriA
C13
C121725COOH
72629-94-8
Perfluorododecanoic acid
PFDoA
C12
Ci,1723COOH
307-55-1
Perfluoroundecanoic acid
PFUnA
C„
CIOF2,COOH
2O58-94-8
Perfluorodecanoic acid
PFDA
CIO
C91719COOH
335-76-2
Perfluorononanoic acid
PFNA
C9
C81717COOH
375-95-1
Perfluorooctanoic acid
PFOA
C8
C71715COOH
335-67-1
Perfluorohe tanoic acid
PFH A
C7
C61713COOH
375-85-9
Perfluorohexanoic acid
PFHxA
C6
C51711COOH
307-24-4
Perfluoropentanoic acid
PFPeA
C5
C4179COOH
2706-90-3
Perfluorobutanoic acid
PFBA
C4
C3177COOH
375-22-4
Perfluorodecanesulfonic acid
PFDS
CIO
CjoF21SO3H
335-77-3
Perfluorononanesulfonic acid
PFNS
C9
C9F,9SO3H
68259-12-1
Perfluorooctanesulfonic acid
PFOS
C8
C8F17SO3H
1763-23-1
Perfluoroheptanesulfonic acid
PFHpS
C7
C7FI5SO3H
375-92-8
Perfluorohexanesulfonic acid
PFHxS
C6
C6F,3SO3H
355-46-4
Perfluoro entanesulfonic acid
PFPeS
C5
C5F„SO3H
2706-91-4
Perfluorobutanesulfonic acid
PFBS
C40MG
C4F9SO3H
375-73-5
Perfluorooctanesulfonamide
PFOSA
C8
C8F17SO2NH2
754-91-6
2-(N-Ethylperfluorooctanesulfonamido)
acetic acid
N-EtFOSAA
C8
C8F„SO2N(C2H5)
CHzCOOH
2991-50-6
2-(N-Methylperfluorooctanesulfonamido)
acetic acid
N-McFOSAA
C8
C8F„SO2N(CH3)C
HCOOH
2355-31-9

ATTACHMENT 4

North Carolina In -Stream Target Values for Surface Waters
Established pa language in 15A NCAC O2B.O2O2 &.0206. Contact DVVR staff for further information.
Freshwater Fresh & Salt Saltwater
OasB wa ers [das C& All waters CYass SB loss SA Supplemental
AOasC lass SC Oasiflatlons
SCAl—Life
Pollutant er Paramxer
Cnstt
creaue
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11q cLife'&
condary
Pizb Conzumptions
&
mndary
emless
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High
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gpnonymz&Otber
Information
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PP h,
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AS32-1
60
20
29
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(no arc PAH)
NA
ECOTOX I/07
e[aldebyde
c Aldehyde, Ethanal
NA
ECOTOX
ceph.t.
ROXTTS & RA2/07
cemd,mr
25b
N.
IRIS 1/07, HIT SEA
89 & 1994
A[ophenone
RIS & ECOTOX 1/07
9A AN 2
3500
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7/16
amlde
79-06-1
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ry otnle
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uminum
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1912-24-9
640
B200
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anum
1 7440-39-3
21000
200000(t)
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IRIS & ECOTOX 1/07
IRIS & ECOTOX 10/10
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6-55-
0.1
Al,. see the NCO2B Standards
tab le for To tal PAHs
NA
ECOTOX 7/16
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5032-A
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table for Total PAH,
NA
ECOTOX 7/16
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n 91 1
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NA
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RIS & ECOTOX 7/11
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5000(S)
eu Hvd,oa,bon
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10000(S)
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eu Hvd,oa,hon
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ECOTOX 1/07
Chloathaloml
IRIS & COTOX 10/10
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10
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4
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Seethe Supporting Info tab for information on a I I footnotes, notes, and a bbreviat ions

ATTACHMENT 5

Year
Chemical
Water Releases (lb)
2012
1,4-Dioxane
722
2013
1,4-Dioxane
494
2014
1,4-Dioxane
382
2015
1,4-Dioxane
968
2016
1,4-Dioxane
401
2017
1,4-Dioxane
1,053
2018
1,4-Dioxane
9,133
2019
1,4-Dioxane
3,758
2020
1,4-Dioxane
1,892
2021
1,4-Dioxane
2,611

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REASONABLE POTENTIAL ANALYSIS
H1
Effluent Hardness
Use "PASTE SPECIAL
Values" then "COPY"
H2
.Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
11/22/2021
180.9
180.9
Std Dev.
18.4445
1
2
11/29/2021
179
179
Mean
143.4897
2
3
12/6/2021
162.4
162.4
C.V.
0.1285
3
4
12/13/2021
179.9
179.9
n
58
4
5
12/20/2021
168.1
168.1
10th Per value
118.91 mg/L
5
6
12/28/2021
162.8
162.8
Average Value
99.00 mg/L
6
7
1/3/2022
150
150
Max. Value
180.90 mg/L
7
8
1 /10/2022
140
140
8
9
1 /11 /2022
150
150
9
10
1 /18/2022
116
116
10
11
1 /24/2022
130
130
11
12
1 /31 /2022
136
136
12
13
2/7/2022
158
158
13
14
2/14/2022
160
160
14
15
2/21/2022
165
165
15
16
2/28/2022
172
172
16
17
3/7/2022
117.3
117.3
17
18
3/14/2022
108
108
18
19
3/21/2022
114.4
114.4
19
20
3/28/2022
131.9
131.9
20
21
4/4/2022
133.8
133.8
21
22
4/5/2022
138
138
22
23
4/11/2022
131.1
131.1
23
24
4/18/2022
131.8
131.8
24
25
4/25/2022
109.3
109.3
25
26
5/2/2022
122.5
122.5
26
27
5/9/2022
143.9
143.9
27
28
5/16/2022
163.6
163.6
28
29
5/23/2022
143.3
143.3
29
30
5/31/2022
147.6
147.6
30
31
6/6/2022
146.1
146.1
31
32
6/13/2022
154.7
154.7
32
33
6/20/2022
159.6
159.6
33
34
6/27/2022
163.8
163.8
34
35
7/5/2022
136.9
136.9
35
36
7/11/2022
125
125
36
37
7/12/2022
134
134
37
38
7/18/2022
144.4
144.4
38
39
7/25/2022
147.7
147.7
39
40
8/2/2022
121.4
121.4
40
41
8/8/2022
149.2
149.2
41
42
8/15/2022
144.8
144.8
42
43
8/22/2022
158.9
158.9
43
44
8/29/2022
147.1
147.1
44
45
9/6/2022
140.7
140.7
45
46
9/12/2022
138.3
138.3
46
47
9/19/2022
150.7
150.7
47
48
9/26/2022
145.7
145.7
48
49
10/3/2022
119.6
119.6
49
50
10/10/2022
135
135
50
51
10/11 /2022
141
141
51
52
10/18/2022
144.4
144.4
52
53
10/24/2022
146.2
146.2
53
54
10/31 /2022
153.6
153.6
54
55
11/7/2022
90.7
90.7
55
56
11 /14/2022
136.2
136.2
56
57
11 /23/2022
150.5
150.5
57
58
11 /28/2022
149.6
149.6
58
Use "PASTE SPECIAL
Upstream Hardness Values"then "COPY"
. Maximum data
points = 58
Date Data
BDL=1/2DL
Results
7/16/2018
44
44
Std Dev.
6.0222
10/16/2018
24
24
Mean
28.0000
1/21/2019
24
24
C.V.
0.2151
4/17/2019
24
24
n
16
7/11/2019
36
36
10th Per value
22.00 mg/L
10/21/2019
28
28
Average Value
28.00 mg/L
1/14/2020
28
28
Max. Value
44.00 mg/L
4/15/2020
28
28
7/21/2020
24
24
10/27/2020
32
32
1/27/2021
28
28
4/21/2021
28
28
7/7/2021
32
32
10/13/2021
28
28
1/19/2022
20
20
4/18/2022
20
20
21636 rpa, data
1 - 5/9/2023

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE SPECIAL
Arsenic
Values" then "COPY"
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
7/10/2018
<
5
2.5
Std Dev.
0.0000
10/2/2018
<
5
2.5
Mean
2.5000
1/10/2019
<
5
2.5
C.V.
0.0000
4/1/2019
<
5
2.5
n
18
7/9/2019
<
5
2.5
10/8/2019
<
5
2.5
Mult Factor =
1.00
1/8/2020
<
5
2.5
Max. Value
2.5 ug/L
4/7/2020
<
5
2.5
Max. Pred Cw
2.5 ug/L
7/7/2020
<
5
2.5
10/6/2020
<
5
2.5
1/14/2021
<
5
2.5
4/8/2021
<
5
2.5
7/20/2021
<
5
2.5
10/12/2021
<
5
2.5
1/11/2022
<
5
2.5
4/5/2022
<
5
2.5
7/12/2022
<
5
2.5
10/11/2022
<
5
2.5
21636 rpa, data
- 2 - 5/9/2023

REASONABLE POTENTIAL ANALYSIS
Par03
Beryllium
Use"PASTE SPECIAL
Values" then "COPY"
Paf04
.Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
Date
Data
1
8/8/2017
< 1
0.5
Std Dev.
0.0000
1
7/10/2018
<
2
11/8/2018
< 1
0.5
Mean
0.5000
2
10/2/2018
<
3
2/1/2019
< 1
0.5
C.V. (default)
0.6000
3
1/10/2019
<
4
5/7/2020
< 1
0.5
n
4
4
4/1/2019
<
5
5
7/9/2019
<
6
Mult Factor =
2.59
6
10/8/2019
<
7
Max. Value
0.50 ug/L
7
1/8/2020
<
8
Max. Pred Cw
1.30 ug/L
8
4/7/2020
<
9
9
7/7/2020
<
10
10
10/6/2020
<
11
11
1/14/2021
<
12
12
4/8/2021
<
13
13
7/20/2021
<
14
14
10/12/2021
<
15
15
1/11/2022
<
16
16
4/5/2022
<
17
17
7/12/2022
<
18
18
10/11/2022
<
19
19
20
20
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
Cadmium
BDL=1/2DL
Results
1 0.5
Std Dev.
1 0.5
Mean
1 0.5
C.V.
1 0.5
n
1 0.5
1 0.5
Mult Factor =
1 0.5
Max. Value
1 0.5
Max. Pred Cw
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
0.5000
0.0000
18
1.00
0.500 ug/L
0.500 ug/L
21636 rpa, data
-3- 5/9/2023

Par10
Date Data
1 7/10/2018 <
2 10/2/2018 <
3 1/10/2019 <
4 4/1/2019 <
5 7/9/2019 <
6 10/8/2019 <
7 1/8/2020 <
8 4/7/2020 <
9 7/7/2020 <
10 10/6/2020 <
11 1/14/2021 <
12 4/8/2021 <
13 7/20/2021 <
14 10/12/2021 <
15 1/11/2022 <
16 4/5/2022
17 7/12/2022 <
18 10/11/2022 <
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
Pall
Use"PASTE SPECIAL
Chromium, Total
Values" then "COPY"
Copper
.Maximum data
points = 58
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
5
2.5
Std Dev.
3.8891
1
7/10/2018
4
4
Std Dev.
5
2.5
Mean
3.4167
2
10/2/2018
6
6
Mean
5
2.5
C.V.
1.1383
3
1/10/2019
8
8
C.V.
5
2.5
n
18
4
4/1/2019
10
10
n
5
2.5
5
7/9/2019
4
4
5
2.5
Mult Factor =
1.76
6
10/8/2019
5
5
Mult Factor =
5
2.5
Max. Value
19.0 pg/L
7
1/8/2020 <
2
1
Max. Value
5
2.5
Max. Pred Cw
33.4 pg/L
8
4/7/2020
5
5
Max. Pred Cw
5
2.5
9
7/7/2020
5
5
5
2.5
10
10/6/2020
3
3
5
2.5
11
1/14/2021
2
2
5
2.5
12
4/8/2021
3
3
5
2.5
13
7/20/2021
3
3
5
2.5
14
10/12/2021
3
3
5
2.5
15
1/11/2022
3
3
19
19
16
4/5/2022
16
16
5
2.5
17
7/12/2022
3
3
5
2.5
18
10/11/2022
2
2
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
4.7778
0.7445
18
1.51
16.00 ug/L
24.16 ug/L
-4-
21636 rpa, data
5/9/2023

REASONABLE POTENTIAL ANALYSIS
Par12
Cyanide
Use"PASTE SPECIAL
Values" then "COPY"
Paf14
.Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
Date
1
8/8/2017
<
5
5
Std Dev.
0.0000
1
7/10/2018 <
2
11/8/2018
<
5
5
Mean
5.00
2
10/2/2018 <
3
2/1/2019
<
5
5
C.V. (default)
0.6000
3
1/10/2019 <
4
5/7/2020
<
5
5
n
4
4
4/1/2019 <
5
5
7/9/2019 <
6
Mult Factor =
2.59
6
10/8/2019 <
7
Max. Value
5.0 ug/L
7
1/8/2020 <
8
Max. Pred Cw
13.0 ug/L
8
4/7/2020 <
9
9
7/7/2020 <
10
10
10/6/2020 <
11
11
1/14/2021 <
12
12
4/8/2021 <
13
13
7/20/2021 <
14
14
10/12/2021 <
15
15
1/11/2022 <
16
16
4/5/2022 <
17
17
7/12/2022 <
18
18
10/11/2022 <
19
19
20
20
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
Lead
BDL=1/2DL
Results
5 2.5
Std Dev.
5 2.5
Mean
5 2.5
C.V.
5 2.5
n
5 2.5
5 2.5
Mult Factor =
5 2.5
Max. Value
5 2.5
Max. Pred Cw
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
2.5000
0.0000
18
1.00
2.500 ug/L
2.500 ug/L
21636 rpa, data
-5- 5/9/2023

Par16
Date Data
1 7/10/2018 <
2 10/2/2018 <
3 1/10/2019 <
4 4/1/2019 <
5 7/9/2019 <
6 10/8/2019 <
7 1/8/2020 <
8 4/7/2020 <
9 7/7/2020 <
10 10/6/2020 <
11 1/14/2021 <
12 4/8/2021 <
13 7/20/2021 <
14 10/12/2021 <
15 1/11/2022 <
16 4/5/2022 <
17 7/12/2022 <
18 10/11/2022 <
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
Use "PASTE Par17 & Par18
SPECIAL -Values"
Molybdenum then "COPY". Nickel
Maximum data
points = 58
BDL=1/2DL
Results
10 5
Std Dev.
0.0000
10 5
Mean
5.0000
10 5
C.V.
0.0000
10 5
n
18
10 5
10 5
Mult Factor =
1.00
10 5
Max. Value
5.0 ug/L
10 5
Max. Pred Cw
5.0 ug/L
10 5
10 5
10 5
10 5
10 5
10 5
10 5
10 5
10 5
10 5
Date Data
1 7/10/2018 <
2 10/2/2018 <
3 1/10/2019 <
4 4/1/2019 <
5 7/9/2019 <
6 10/8/2019 <
7 1/8/2020 <
8 4/7/2020 <
9 7/7/2020 <
10 10/6/2020 <
11 1/14/2021 <
12 4/8/2021 <
13 7/20/2021 <
14 10/12/2021 <
15 1/11/2022 <
16 4/5/2022
17 7/12/2022 <
18 10/11/2022 <
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
BDL=1/2DL
Results
10 5
Std Dev.
10 5
Mean
10 5
C.V.
10 5
n
10 5
10 5
Mult Factor =
10 5
Max. Value
10 5
Max. Pred Cw
10 5
10 5
10 5
10 5
10 5
10 5
10 5
28 28
10 5
10 5
Use"PASTE
SPECIAL -Values"
then "COPY".
Maximum data
points = 58
6.2778
0.8635
18
1.59
28.0 pg/L
44.5 pg/L
-6-
21636 rpa, data
5/9/2023

REASONABLE POTENTIAL ANALYSIS
Par19
Use"PASTE
Par20
SPECIAL -Values"
Use "PASTE SPECIAL
Selenium
then "COPY".
Silver
Values" then "COPY"
Maximum data
. Maximum data
points = 58
points = 58
Date
Data
BDL=1/2DL
Results
Date
Data
BDL=1/2DL
Results
1
7/10/2018
<
10
5
Std Dev.
0.0000
1
7/24/2018
<
1
0.5
Std Dev.
0.0000
2
10/2/2018
<
10
5
Mean
5.0000
2
10/23/2018
<
1
0.5
Mean
0.5000
3
1/10/2019
<
10
5
C.V.
0.0000
3
1/8/2019
<
1
0.5
C.V.
0.0000
4
4/1/2019
<
10
5
n
18
4
4/1/2019
<
1
0.5
n
18
5
7/9/2019
<
10
5
5
7/8/2019
<
1
0.5
6
10/8/2019
<
10
5
Mult Factor =
1.00
6
10/17/2019
<
1
0.5
Mult Factor =
1.00
7
1/8/2020
<
10
5
Max. Value
5.0 ug/L
7
1/8/2020
<
1
0.5
Max. Value
0.500 ug/L
8
4/7/2020
<
10
5
Max. Pred Cw
5.0 ug/L
8
4/7/2020
<
1
0.5
Max. Pred Cw
0.500 ug/L
9
7/7/2020
<
10
5
9
7/8/2020
<
1
0.5
10
10/6/2020
<
10
5
10
10/6/2020
<
1
0.5
11
1/14/2021
<
10
5
11
1/12/2021
<
1
0.5
12
4/8/2021
<
10
5
12
4/6/2021
<
1
0.5
13
7/20/2021
<
10
5
13
7/20/2021
<
1
0.5
14
10/12/2021
<
10
5
14
10/11/2021
<
1
0.5
15
1/11/2022
<
10
5
15
1/11/2022
<
1
0.5
16
4/5/2022
<
10
5
16
4/5/2022
<
1
0.5
17
7/12/2022
<
10
5
17
7/12/2022
<
1
0.5
18
10/11/2022
<
10
5
18
10/11/2022
<
1
0.5
19
19
20
20
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
21636 rpa, data
-7- 5/9/2023

REASONABLE POTENTIAL ANALYSIS
Par21
Date Data
1 7/10/2018
2 10/2/2018
3 1/10/2019
4 4/1/2019
5 7/9/2019
6 10/8/2019
7 1 /8/2020
8 4/7/2020
9 7/7/2020
10 10/6/2020
11 1 /14/2021
12 4/8/2021
13 7/20/2021
14 10/12/2021
15 1 /11 /2022
16 4/5/2022
17 7/12/2022
18 10/11 /2022
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE SPECIAL Par22
Zinc Values" then "COPY"
.Maximum data
points = 58
BDL=1/2DL
Results L
30 30
Std Dev.
13.9916
33 33
Mean
36.6667
34 34
C.V.
0.3816
39 39
n
18
30 30
38 38
Mult Factor =
1.26
40 40
Max. Value
86.0 ug/L
44 44
Max. Pred Cw
108.4 ug/L
43 43
36 36
23 23
33 33
35 35
38 38
35 35
86 86
23 23
20 20
Use "PASTE SPECIAL
Nitrate Values" then "COPY"
. Maximum data
points = 58
Date Data
BDL=1/2DL
Results i
1
8/27/2018
8.44
8.44
Std Dev.
1.4300
2
8/28/2018
7.08
7.08
Mean
8.2929
3
8/29/2018
8.36
8.36
C.V.
0.1724
4
9/4/2018
7.72
7.72
n
55
5
10/8/2018
12.1
12.1
6
10/9/2018
9.4
9.4
Mult Factor =
1.00
7
10/10/2018
7.26
7.26
Max. Value
13.800000 mg/L
8
11/5/2018
13.8
13.8
Max. Pred Cw
13.800000 mg/L
9
11/13/2018
8.32
8.32
10
2/4/2019
7.49
7.49
11
5/22/2019
7.33
7.33
12
6/10/2019
7.39
7.39
13
8/26/2019
7.21
7.21
14
9/3/2019
7.5
7.5
15
9/4/2019
7.26
7.26
16
9/16/2019
7.7
7.7
17
9/23/2019
9.24
9.24
18
9/30/2019
11.94
11.94
19
10/7/2019
9.18
9.18
20
10/8/2019
8.4
8.4
21
10/9/2019
8.06
8.06
22
10/ 14/2019
12.16
12.16
23
10/15/2019
7.18
7.18
24
10/21/2019
8.96
8.96
25
10/23/2019
8.46
8.46
26
11/14/2019
7.15
7.15
27
12/9/2019
7.44
7.44
28
2/12/2020
7.34
7.34
29
2/19/2020
7.34
7.34
30
2/24/2020
7.86
7.86
31
3/9/2020
8.64
8.64
32
3/11/2020
7.1
7.1
33
7/1/2020
7.22
7.22
34
7/6/2020
8.14
8.14
35
7/13/2020
7.3
7.3
36
7/15/2020
8.96
8.96
37
8/26/2020
7.16
7.16
38
9/8/2020
7.29
7.29
39
9/9/2020
8.06
8.06
40
9/10/2020
9.6
9.6
41
9/14/2020
7.43
7.43
42
9/16/2020
9.22
9.22
43
11/12/2020
7.17
7.17
44
12/16/2020
8.56
8.56
45
12/23/2020
7.22
7.22
46
9/13/2021
7.2
7.2
47
9/15/2021
9.2
9.2
48
9/20/2021
7.3
7.3
49
12/1/2021
7.9
7.9
50
5/16/2022
7.74
7.74
51
5/17/2022
7.51
7.51
52
5/18/2022
7.38
7.38
53
6/13/2022
9.04
9.04
54
6/14/2022
9.1
9.1
55
6/20/2022
9.6
9.6
56
57
58
-8-
21636 rpa, data
5/9/2023

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Permit No. NC0021636
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater 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, metal 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 Q ality Standards/A uatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/1
(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:
FW= Freshwater, SW= Saltwater
Calculation = Hardness dependent standard
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 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER* 11.136672-[ln hardness](0.041838)} eA10.9151 [In hardness]-3.1485}
Cadmium, Acute Trout waters
WER* {1.136672-[ln hardness](0.041838)} of 0.9151[In hardness]-3.6236}
Cadmium, Chronic
WER* {1.101672-[ln hardness](0.041838)} e^{0.7998[ln hardness]-4.4451}
Chromium III, Acute
WER*0.316 e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 e^{0.9422[ln hardness]-1.7001
Copper, Chronic
WER*0.960 e^{0.8545[In hardness]-1.7021
Lead, Acute
WER*{1.46203-[ln hardness](0.145712)1 • of 1.273[ln hardness]-1.4601
Lead, Chronic
WER* {1.46203-[ln hardness](0.145712)1 • of 1.273[ln hardness]-4.705}
Nickel, Acute
WER*0.998 e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 e-10.8460[ln hardness]+0.0584}
Page 1 of 4

Permit No. NCO021636
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^{0.8473[ln hardness]+0.8841
Zinc, Chronic
WER*0.986 e-10.8473[ln hardness]+0.8841
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 and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
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 default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
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 critical low -flow values for the receiving stream.
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 on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

Permit No. NCO021636
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + WOW, cfs *Avg. Upstream Hardness, ma/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
_Cdiss - I
Ctotal I + f [Kpo] [ss(i+a)] [10 6]
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (le. silver), 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. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. 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 (µg/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 s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
IQIO = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0021636
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
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.
7. 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.
The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. 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 III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
143.49
Average from November 2021 to
November 2022 samples
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25
Default value used
7Q10 summer (cfs)
283
2021 USGS Stream Stats
1Q10 (cfs)
229.33
Calculated in RPA
Permitted Flow (MGD)
7.5 & 16.5
NPDES Files
Date: 1/25/2023
Permit Writer: Nick Coco
Page 4 of 4

1 ®B3.)
CONSULTING
ENGINEERS, P.A.
Design Memorandum
Date: Thursday, March 31, 2022
Project: 321001— North Regional WWTP Expansion NPDES No. NC 0021636
321022 — South Regional WWTP Expansion NPDES No. NC 0088366
To: Michael Montebello, Supervisor, Municipal Permitting Unit
Doug Dowden, Environmental Program Supervisor II
From: Joseph W. McGougan, P.E.
Subject: Nutrient Sharing — North Regional and South Regional WWTPs
The North Regional WWTP (North) and the South Regional WWTP (South) are reviewing options for
increasing the treatment capacity. The North facility has proposed to expand the NPDES discharge from
7.5 MGD to 16.5 MGD to address growth in northern Harnett County and southern Wake County. An
EAA was submitted on February 17, 2022, for this project. The South facility has proposed to expand the
existing NPDES discharge from 15 MGD to 17.5 MGD to address the need to accept flow from the existing
Spring Lake WWTP. An EAA is currently being prepared.
The North and South NPDES permits were issued with seasonal nutrient limits for total nitrogen (TN)
and total phosphorus (TP). The North NPDES permit includes 59,968 lbs. TN and 19,989 lbs. TP for the
period between April 1 and October 31. The South NPDES permit includes 160,628 lbs. TN and 53,543 lbs.
TP for the same period. With the decommissioning of the Spring Lake WWTP, additional nutrients
should be available to be transferred to the South facility.
North Carolina has allowed nutrient sharing between facilities, in effect, allowing multiple wastewater
treatment plants to combine the permitted discharge (pounds) and split the amount between the different
facilities. The goal being for the combined discharge to meet the total TN and TP limit. A similar approach
is requested for the Harnett North and South facilities.
The total allowable seasonal nutrient discharge for North and South combined is 220,596 lbs. TN and
73,532 lbs. TP. This does not include the loading that may be transferred from the Spring Lake WWTP
when that facility is decommissioned. The total proposed discharge between the North and South facilities
would be 34 MGD. Based on the design capacity of both facilities, the calculated concentration for each
facility would be 3.65 mg/1 TN and 1.22 mg/1 TP. The North and South facilities currently have the required
treatment technology to achieve the seasonal limits for TN and TP at the expanded capacity.
MBD Consulting Engineers, P.A.
911 Norman Alley
Conway, SC 29526
843.488.0124

Design Memorandum
March 31, 2022
Page 2
SUMMARY
Nutrient sharing between the North and South facility will not increase the nutrient loading on the Cape
Fear River and will provide Harnett Regional Water with flexibility in the design and operation of the two
wastewater treatment plants. The ability to share the nutrients will reduce the technological requirements
that would be required for the North facility, reducing overall construction cost. Nutrient sharing will
also reduce total operational costs between the two facilities.
The South EAA and cover letters for the submittal of the North and South NPDES permits will include
this request The South EAA and NPDES permit application will also include a request to transfer the
nutrient loading from the Spring Lake plant to the South Regional facility.
MBD Consulting Engineers, P.A.
911 Norman Alley
Conway, SC 29526
843.488.0124

NH3/TRC WLA Calculations
Facility: North Harnett Regional WWTP
PermitNo. NC0021636
Prepared By: Nick Coco
Enter Design Flow (MGD): 7.5
Enter s7Q10 (cfs): 283
Enter w7Q10 (cfs): 304
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
283
s7Q10 (CFS)
283
DESIGN FLOW (MGD)
7.5
DESIGN FLOW (MGD)
7.5
DESIGN FLOW (CFS)
11.625
DESIGN FLOW (CFS)
11.625
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
3.95
IWC (%)
3.95
Allowable Conc. (ug/1)
431
Allowable Conc. (mg/1)
20.0
Cap at 28 ug/L.
Less stringent than current limit. Maintain lim
Apply limit.
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
304
Monthly Average Limit:
2001100-
DESIGN FLOW (MGD)
7.5
(If DF >331; Monitor)
DESIGN FLOW (CFS)
11.625
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
25.34
Upstream Bkgd (mg/1)
0.22
IWC (%)
3.68
Allowable Conc. (mg/1)
43.1
Less stringent than current limit. Maintain lim
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

NH3/TRC WLA Calculations
Facility: North Harnett Regional WWTP
PermitNo. NC0021636
Prepared By: Nick Coco
Enter Design Flow (MGD): 16.5
Enter s7Q10 (cfs): 283
Enter w7Q10 (cfs): 304
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
283
s7Q10 (CFS)
283
DESIGN FLOW (MGD)
16.5
DESIGN FLOW (MGD)
16.5
DESIGN FLOW (CFS)
25.575
DESIGN FLOW (CFS)
25.575
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
8.29
IWC (%)
8.29
Allowable Conc. (ug/1)
205
Allowable Conc. (mg/1)
9.6
Cap at 28 ug/L.
Less stringent than speculative limit. Maintain
Apply limit.
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
304
Monthly Average Limit:
2001100-
DESIGN FLOW (MGD)
16.5
(If DF >331; Monitor)
DESIGN FLOW (CFS)
25.575
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
12.07
Upstream Bkgd (mg/1)
0.22
IWC (%)
7.76
Allowable Conc. (mg/1)
20.6
Less stringent than speculative limit. Maintain
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

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EPA Identification Number NPDES Number Facility Name OutFall Number
NC 0021636 N. Harnett Reg. WWTP 001
Method Number Estimated Concentration (if
Pollutants I Required) CAS number if A liable Reason Pollutant Believed Present in Diischar Known
No Additional Pollutants Sampled
Signed:
Kenneth W. Fail, W istewater Sup arintendent, Harr ieft Regional Water

Weaver, John C
From: Weaver, John C
Sent: Wednesday, June 23, 2021 12:13 PM
To: [e-mail]
Cc: Hill, David A; [e-mail]; Montebello, Michael J; Albertin, Klaus P; Weaver, John C
Subject: USGS response to DWR USGS Low Flows request # 2021-126 (dated 2021/06/15) for Cape Fear River
Harnett County ... RE: [EXTERNAL] Low -flow request approval
Mr. Bromby,
In response to your inquiry about the low -flow characteristics for the USGS continuous -record streamgage on the Cape
Fear River at Lillington (station id 02102500, NWIS drainage area 3,464 sqmi) in central Harnett County, the following
information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (SAWSC, Raleigh office) indicates two
previous low -flow determinations recently completed for the point of interest, identified by the lat/long coordinates
(35.40611,-78.81333) provided via email dated 06/15/2021 from the DWR USGS Low Flow portal following your request
submission. Completed in October and November 2019, the low -flow characteristics for the point of interest (station id
02102500, NWIS drainage area 3,464 sqmi) were estimated based on a provisional low -flow analysis completed for this
streamgage in early October 2019. Responses to these two previous low -flow requests were provided via emails dated
10/07/2019 and 11/25/2019.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(https://streamstats.usgs.gov/ss/) indicates the drainage area for the point of interest (StreamStats adjusted 35.40687, -
78.81292 NAD83) is 3,470 sqmi.
For streams in Harnett County, low -flow characteristics published by the USGS are provided in the following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available at
http://pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sqmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources
Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear
River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of the report is available
through http://nc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The
report also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and
selected tributaries within the basin.
(3) The third is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001, "Low -
flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in North
Carolina through 2012" (Weaver, 2015). The report is available online at http://pubs.usgs.gov/sir/2015/5001/. The
report provides updated low -flow characteristics and flow -duration statistics for 266 active (as of 2012 water year) and
discontinued streamgages across the state where a minimum of 10 climatic years discharge records were available for
flow analyses.

Low -flow characteristics for USGS Sta. 02102500 Cape Fear River at Lillington
Streamflows in the Cape Fear River at this point of interest have been regulated since September 1981 by B. Everett
Jordan Lake, located upstream on the Haw River upstream of its confluence with the Deep River (Weaver and McSwain,
2012).
Please note low -flow characteristics for this and two other USGS streamgages on the Cape Fear River were not published
in the recent statewide low -flow update for selected continuous -record streamgages across North Carolina (Weaver,
2015). The statistics were not published because of changes during the 2000's in the operational guidance used by U.S.
Army Corps of Engineers for its operation of B. Everett Jordan Lake during drought periods. Between 1998 and 2006,
there were deviations in the flow releases used to maintain target flows at the Lillington streamgage, all of which
resulted in refinement of the Drought Contingency Plan (DCP). Formally approved in 2008, the final adjustments to the
flow deviations to be used for drought periods were in effect during the 2007 climatic year. This information is
documented on pages 15-16 of the recent statewide low -flow update (Weaver, 2015).
Going forward, the new periods for low -flow analyses for the USGS streamgages on the Cape Fear begin with the 2007
climatic year. As a historical note and reference, previous low -flow analyses completed for the Cape Fear streamgages
prior to the updated DCP began with the 1982 climatic year, reflective of regulated flow releases from Jordan Lake
(Weaver and Pope, 2001).
At the present time, provisional low -flow analyses at this streamgage are available for the 2007-20 climatic years (period
of analysis). Please note this is a short-term period of record for low -flow analyses, with potential positive (upward)
trends noted in the series of annual 7-day annual minimums (via Kendall tau trend tests).
Annual 7Q10
= 283 cfs (with 95% confidence intervals between 168 and 354 cfs)
Annual 30Q2
= 506 cfs (with 95% confidence intervals between 405 and 619 cfs)
Winter 7Q10
= 305 cfs (with 95% confidence intervals between 203 and 389 cfs)
Annual 7Q2 =
446 cfs (with 95% confidence intervals between 358 and 530 cfs)
Average annual discharge = 3,172 cfs, based on provisional period of analysis since 2008
Internal notes, for follow-up as needed:
Provisional analyses completed 06-21-2021 using the USGS SW Toolbox (version 1.0.5)
Internal note: Output files available in C: USGS-SWToolbox�data�03030004�Sta 02102500 asof-20210621
Please note:
(1) The estimated flows are provided in units of cubic feet per second (cfs).
(2) The climatic year is the standard period used for low -flow analyses at USGS continuous -record streamgages. The
climatic year is from April 1 through March 31, designated by the year in which the period begins. For example, the
2020 climatic year is from April 1, 2020, through March 31, 2021.
(3) The information provided in this message is based on a preliminary assessment and considered provisional, subject
to revision pending collection of future data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between the
USGS and the N.C. Department of Environmental Quality, Division of Water Resources.
Hope this information is helpful.

Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email: [e-mail]
USGS South Atlantic Water Science Center Online: httys://www.usas.aov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Tuesday, June 15, 2021 10:43 AM
To: [e-mail]
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; [e-mail];
Weaver, John C <[e-mail]>; Montebello, Michael J <[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 - 10 business
days.
Request Flow Statistic Approval
Request ID: 126
Requestor: William Bromby
Requestor e-mail: [e-mail]
Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant: Jacobs Engineering
Contact: William Bromby
Reason: for concentration calculations
River/Stream: Cape Fear River

Drainage Area (sq. mi.): 3440
Latitude: 35.40611
Longitude:-78.81333
Other Information: USGS station 02102500 CAPE FEAR RIVER AT LILLINGTON, NC
Statististics: ["7Q10"]
Approved by: Hill, David A

DocuSign Envelope ID: BED91BF99-81364-4593-BE52-6921 E7737BOC
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Joseph W. McGougan, P.E.
MBD Consulting Engineers, PA
1300 Second Ave., Suite 211
Conway, South Carolina 29526
Dear Mr. McGougan:
NORTH CAROLINA
Environmental Quality
January 7, 2022
Subj ect:
Speculative Effluent Limits
N Harnett Regional WWTP
NCO021636
Harnett County
Cape Fear River Basin
This letter provides speculative effluent limits for expanding the NE Regional WWTP located on
the Cape Fear River with a proposed flow of 16.5 MGD. These speculative limits supplement
those offered on October 1, 2021 for a proposed flow of 15.0 MGD. Speculative limits for 20
MGD were also requested, but the Division is unable to develop limits at that flow while holding
mass -loading constant as the resulting limits may not be achievable on a consistent basis for
current treatment technologies. Please recognize that speculative limits may change based on
future water quality initiatives.
Receiving Streams. The Cape Fear River at the outfall has a stream classification of WS-IV, and
waters with this classification have a best usage for aquatic life propagation and maintenance of
biological integrity, wildlife, secondary recreation, agriculture, and potable water use. The Cape
Fear River has a summer 7Q10 flow of 283 cfs, a winter 7Q10 flow of 304 cfs, a 30Q2 flow of
506 cfs, and an annual average flow of 3,172 cfs.
This segment of the Cape Fear River is not listed as an impaired waterbody on the 2020 North
Carolina 303(d) Impaired Waters List. The Cape Fear River does have downstream impairments
of chlorophyll a from nutrient enrichment and low dissolved oxygen. Nutrient criteria
development and modeling are currently underway to address these impairments and may affect
future permit limits.
Based upon a review of information available from the North Carolina Natural Heritage Program
Online Map Viewer, there are Federally Listed threatened or endangered aquatic species
identified within a 5-mile radius of the proposed discharge location. If there are any identified
threatened/endangered species, it is recommended that the applicant discuss the proposed project
with the US Fish and Wildlife Service to determine whether the proposed discharge location
might impact such species.
DNorth Carolina Department of Environmental Quality Division of Water Resources
EQ:> 512 North Salisbury Street 11617 Mail Service Center Raleigh, North Carolina 27699-1617
NORTH GAROLINA +
919.707.9000

DocuSign Envelope ID: BED91BF99-81364-4593-BE52-6921 E7737BOC
Speculative Effluent Limits. Based on Division review of receiving stream conditions,
speculative limits for an expansion to 16.5 MGD are presented in Table 1. A complete
evaluation of these limits and monitoring requirements for metals and other toxicants, as well as
potential instream monitoring requirements, will be addressed upon review of the formal NPDES
permit application which is under review. Some features of the speculative limit development
include the following:
• BOD/NH3/Nutrient Limits. With current modeling of the Cape Fear River underway,
no new models are being evaluated to develop limits for facilities in the modeled
segments. Therefore, mass -loading of oxygen consuming wastes have been frozen
based on current permit limits. These speculative limits can be re-evaluated once
current modeling is finished. These limits are expected to require advanced treatment
technologies.
TABLE 1. Speculative Limits for North Harnett Regional WWTP proposed expansion.
Effluent Characteristic
Effluent Limitations
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
16.5 MGD
BOD5
2.1 mg/L
3.1 mg/L
NH3 as N (Apr. -Oct.)
0.5 m /L
1.5 m /L
NH3 as N (Nov. -Mar.)
0.9 mg/L
2.7 mg/L
Dissolved Oxygen
minimum daily average)
>5.0 mg/L
Total Nitrogen Load
(Apr. -Oct.)
59,968 lbs/season
Total Phosphorus Load
(Apr. -Oct.)
19,989 lbs/season
TSS
15 mg/L
22.5 m /L
TRC
28 g/L
Fecal coliform
(geometric mean
200/100 mL
400/100 mL
Chronic Toxicity
Pass/Fail(Quarterly test
7.5%
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee
that an NPDES permit for a new or expanding discharge will be issued with these speculative
limits. Final decisions can only be made after the Division evaluates the formal permit
application for the expanded discharge. In accordance with North Carolina Administrative
Code 15A NCAC 2H.0105(c), the most environmentally sound alternative should be selected
from all reasonably cost-effective options. Therefore, as a component of all NPDES permit
applications for new or expanding flow, a detailed engineering alternatives analysis (EAA)
must be prepared (in this case we have this information which is under review). The EAA
NORr�A E QIA
naPaftffaM or Emlranma W Ouaury
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

DocuSign Envelope ID: BED9BF99-8B64-4593-BE52-6921 E7737BOC
must justify requested flows and provide an analysis of potential wastewater treatment
alternatives.
State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document
may be required for projects that: 1) involve $10 Million or more of state funds; or 2) will
significantly and permanently impact 10 or more acres of public lands. Please check with the
DWR SEPA coordinator (David Wainwright, 919-707-9045) as to whether your project
requires SEPA review. For projects that are subject to SEPA, the EAA requirements
discussed above will need to be folded into the SEPA document. Additionally, if subject to
SEPA, the NPDES Unit will not process an NPDES permit application for a new/expanding
discharge until the Division has approved the SEPA document and sent a Finding of No
Significant Impact (FONSI) to the State Clearinghouse for review and comment.
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact me at michael.montebello(c�r�,ncdenr.gov
or [phone].
Respectfully,
EDocuSigned by'.
C464531431644FE...
Michael Montebello
Supervisor, NPDES Municipal Permitting Unit
Electronic Copy:
NC WRC, Eastern Piedmont Coordinator, gabriela.garrison(2ncwildlife.org
US Fish and Wildlife Service, sara_ward(cr�,fws.gov
DWR/Water Quality Regional Office/Fayetteville
DWR/Basinwide Planning
DWR/Modeling and Assessment Branch
D E Q ✓� North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
newhneM of 919.707.9000

Attachment A. Local Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with
the ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
ins tru tions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
■ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
■ If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to.
the NPDES Unit.
■ As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within
the 15-day period.
Instructions t the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government Ha ett N
(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [ ] No [ X ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ] No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [ ]
No [ ] GG V
11
Date 'G /k,9 ZOLZ Signature
(City Manager/County Manager)
State of A6411 4,qLA & , County of 1 ■Q.r n e,
On this day of APXL, personally appeared before me, the said
name to me known and known to me to be the person described in
and who executed the foregoing document and he (or she) acknowledged that he (or she) executed the same and being duly sworn
by me, made oath that the statements in the foregoing document are true.
My Commission expires 8 (Signature of Notary Public)T= A 11r)�
Notary Public (O` fi jWi$rpj� ���'
NO N• M' F"'•.
r�'rP?•.pTq •q���
)9i.
EAA Guidance Document Revision: October 2019 a
Page 1 of 1 '•,''�'-_�_..' �±...��`�'�``a

Attachment A. Local Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with
the ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
■ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
■ If either (or both) local government(s) fails) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
■ As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within
the 15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government Town of Lillington, NC
(City/County)
Does the city/cou have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [VT No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [V'No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes LVJ
No[ ]
Date 2 1 202 Signature
(C;anger/County Manager)
State of ' ` or+h C o l i n G , Countyof -c L
On this] 1 V ' —' y day ofS-JM�� impersonally appeared before me, the said
name V US C �� 1Y [ _CS to me known and known to me to be the person described in
and who execAcd the foregoing document and he (or she) acknowledged that he (or ) executed the same and being duly sworn
by me, made oath that the statements in the foregoing ' ,J '
My Commission
W
9y PUBOG�
C0%3.
Notary Public (OfficUl Seal)
EAA Guidance Document Revision: October 2019
Page 1 of 1

HARNETT
REGIONAL
r WATER
February 1, 2023
NC Department of Environmental Quality
Water quality Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Attention: Nick Coco
Re: NPDES NCO021636
North Harnett Regional WWTP
Request to continue Reduced Monitoring
Mr. Coco,
www.harnettwater.org
PO Box 1119
700 McKinney Parkway
Ullington, NC 27546
ph: 910-893-7575
fax: [phone]
Harnett Regional Water respectfully requests to continue reduced monitoring as part of the ongoing
renewal process. 1 have included a copy of the original DWQ correspondence granting the permit
modification from back in 2015 along with a spreadsheet showing effluent monitoring results for these
parameters for the full compliance period 2017-2022. This data can be verified against NCDMR data
already in RIMS.
Please do not hesitate to contact me with any questions regarding this application or needs for
additional information.
Respectfully,
-14"'6-�- �/U J-4�1
Kenneth W. Fail
Wastewater Supt.
Harnett Regional Water
910-814-6470 (office)
[e-mail]

HARN ETT
REGIONAL
50j
January 31, 2023
Ms. Kristen Litzenberger
NCDEQ
Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699
RE: Harnett Regional Water
North Regional WWTP NPDES No. NCO021636
South Regional WWTP NPDES No. NCO088366
Nutrient Sharing Request
Dear Ms. Litzenberger:
www.harnettwater.org
PO Box 1119
700 McKinney Parkway
Lillington, NC 27546
ph: 910-893-7575
fax: [phone]
The North Regional WWTP and South Regional WWTP NPDES permits include seasonal nutrient limits in
total pounds during the winter months. The North Regional WWTP currently has a discharge volume of
7.5 MGD and the permit includes 59,968 lbs. of TN and 19,989 lbs. of TP for the period between April 1
through October 31 of each year. The South Regional WWTP permit has a discharge volume of 15 MGD
and the permit includes 160,629 lbs. of TN and 54,543 lbs. of TP for the same period of April 1 through
October 31. HRW has recently submitted a request to expand the North Regional WWTP permit from 7.5
MGD to 16.5 MGD. The speculative limits that were provided to HRW included the same poundage for TN
and TP as is currently listed in the NPDES permit.
In May 2022, HRW requested that the South Regional WWTP NPDES permit be expanded from 15 MGD
to 17.5 MGD but HRW recently withdrew that request and now requests that the permit be renewed for
a discharge volume of 15 MGD.
HRW is requesting that a nutrient sharing agreement be established between the two facilities where the
facilities have the ability to share a total of 220,596 lbs. TN and 75,532 of TP as a seasonal total poundage
limit for the two facilities.
Alternatives for sharing the nutrient load between the two facilities have been discussed with NCDEQ.
While the initial request would be for the ability to completely share between the two facilities, if that is
not possible at this time, HRW requests that a portion of the South Regional WWTP nutrient allocation be
transferred to the North Regional WWTP NPDES permit. The allocation would be based on the percentage
of flow as shown in the table below.

HARNETT REGIONAL WATER
NORTH REGIONAL WWTP NPDES NO. NC 0021636
SOUTH REGIONAL WWTP NPDES NO. NC 0088366
NUTRIENT TRANSFER REQUEST
FLOW %
TN _
CURRENT PROPOSED
TP
CURRENT
PROPOSED
NORTH
16.5 MGD
52.4%
59,968 LBS
115,550 LBS
19,989 LBS
53,543 LBS
38,517 LBS
35,015 LBS
SOUTH
15.0 MGD
47.6%
160,628 LBS
105,046 LBS
TOTAL
31.5 MGD
1.000
220,596 LBS 220,596 LBS
73,532 LBS
73,532 LBS
HRW requests that 55,582 lbs. of TN and 18,525 lbs. of TP be transferred from the South Regional WWTP
NPDES permit to the North Regional WWTP NPDES permit.
HRW appreciates the assistance from NCDEQ on this project. If we can provide any additional information,
please contact me at this office.
Sincerely,
Steve Ward
Director
cc: Michael Montebello, NCDEQ
Ken Pohlig, NCDEQ
Joe McGougan, MBD
www.harnettwater.org

®B1)
CONSULTING
ENGINEERS, P.A.
February 8, 2023
Mr. Nick Coco, P.E.
NCDEQ
Division of Water Resources
512 North Salisbury Street
Raleigh, NC, 27604
RE: North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis
MBD Project No. 321001/300
Dear Mr. Coco:
We are in receipt of your comments on the above referenced project. I wanted to provide our response and
determine how you wanted these incorporated into the EAA.
Renewal Application
Please provide a narrative description of the process flow diagram/schematic for item 2.4 of the
application.
The existingNorth Harnett Regional WWTPis currentlya 75MGD extended aeration wastewater
treatment facility with tertiary treatment. The facility currently has a headworks that includes one
manual bar screen and one automatic step screen, an automaticgritremoval system utilizing vortex
grit removal and flow metering. Return activated sludge is returned back to the inlet for the
oxidation ditches prior to an influent splitter box. Flow is then divided between two oxidation
ditches each having a capacity of roughly 3.5 million gallons. Mixed liquor is discharged into a
splitter box that was divided between two existing clarification units each having a capacity of
roughly12MGD. The sludge from the basingoestoanexistingRAS/WASpumpstation thatreturns
it to the oxidation ditch and discharges into the existingsludge storage lagoon. The clarified effluent
from the two clarifiers is discharged to tertiary filters. In a recent upgrade, existing traveling bridge
filters were paralleled with the use of four new stainless steel disc filters. The combination of the
two units provides tertiary treatment for the discharge. Tertiary treated effluent ispiped to the UV
system which currentlyincludes two channels of UV bulbs, through a flowmeter, andinto a cascade
aeratorfor post aeration prior to discharge to the Cape Fear River. The sampling system is provided
at the base of the cascade aerator. Sludge is currently dewatered onsite using an in lagoon dredge
system to remove the sludge and pump it into a 600, 000gallon storage tank onsite where it is mixed
prior to being dewatered using a centrifuge.
The proposed improvements include:
• Expansion of the headworks facility
• Construction ofa new secondary treatment system
• Expansion of the existing filters system
• Expansion of the existing UV system
MBD Consulting Engineers, P.A.
911 Norman Alley
Conway, SC 29526
843.488.0124

Mr. Nick Coco, P.E.
February 8, 2023
Page 2
• Utilization of existingpost aeration
• Installation ofa new sludge digestion and treatment system
There have been some design changes since the NPDES permit was submitted last spring. The
description below reflects the latest update. A revised schematic is provided with this letter.
A new parallel headworks is being designed that will include two new automatic screens similar to
the existing automatic screen. System flow will be balanced between the two. The existingmanual
bar screen will remain in service. A parallel grit removal system will be installed as will a parallel
discharge flo w meter.
The discharge from the existing headworks gravity feeds into a new secondary treatment system
using sequencing batch reactor (SBR) technology. The flowgoes into the primary splitter box that
splits itinto six new 2.7SMGD SBR treatment systems. The facilityis able be expandedin the future
to add two more 2.75MGD treatment trains. Decant from the SBR treatment system is collected in
a surge tank where low lift pumps will transfer the flow to anew tertiary filter facility. Returned
sludge from each of the SBR basins will be piped to the new sludge digestion system described later.
The low lift pump station located in the surges tanks consists of six new vertical turbine pumps
designed to pump the peak flow to the new tertiary treatment system. The existing disc filters will
be relocated and combined with new similar designed disc filters to provide treatment for the 16.5
MGD design capacity. The traveling bridge filters will not be utilized at all as apart of this design.
The UV system will be expanded with two additional channels, including new UV disinfection
systems. The existing channels will be modified to include a trough style level control device to be
similar to the new design. The Cascade aeratoris adequately sized for the peak flow capacity for the
treatment facility and will not be modified.
The sludge treatment system will consist of utilizing the two existing oxidation ditches as sludge
digestors. A sludge digestion system designed to minimize the return of phosphorus to the
treatment train is being designed The decant from the sludge digestors will be piped to a drain
pump station that will pump the flow back to a location downstream of the headworks and flow
metering. Sludge removed from the two sludge digestors will be thickened and aerated continuously
in the existing clarifiers. The thickened sludge from the two existing clarifiers will be pumped via
new rotary lobe pumps directly to the sludge dewatering system. The existing 600, 000gallon tank
presently used for wastewater sludge holding will be used for processing the water treatment plant
sludge. It should be noted that the existing lagoon will be dredged, and the sludge stabilized or
removed. The lagoon will be filled in using material excavated for the new secondary treatment
system (SBR).
2. Please provide the pass/fail result sheets for the 5 additional species chronic toxicity tests conducted in
April 2018, April 2019, January 2020, January 2021, and April 2022.
All of the pass/fail results for toxicity for 2018, 2019, 2020, 20121, and 2022 are attached
3. Please provide the documentation for the ownership name change. We have this permit owned and
operated in the system by Harnett County Public Utilities, but it appears a name change occurred to move
to Harnett Regional Water.
The documentation showing the request for ownershipchange for the North WWTPandtheSouth
Regional WWTPare attached.
MBD Consulting Engineers, P.A.
911 Norman Alley
Conway, SC 29526
843.488.0124

Mr. Nick Coco, P.E.
February 8, 2023
Page 3
4. Harnett Regional Water (HRW) was granted 2/week monitoring for BOD, ammonia, fecal coliform and
TSS during the 2017 renewal for the North Harnett Regional WWTP based on 2012 DWR Guidance
Regarding the Reduction of Monitoring Frequencies in NPDES Permits for Exceptionally Performing
Facilities. The renewal application does not include a request for continuation of this monitoring
frequency reduction. If this is a mistake, and HRW would like to continue 2/week monitoring for these
parameters, please submit a request to continue this requirement and include confirmation of the approval
criteria outlined in the attached guidance document.
A request to continue the reduced monitoring is attached
5. Please describe how sludge is managed at this facility.
Currently sludge is removed from the treatment process and stored in a lagoon adjacent to the
facility. The sludgeisremovedfromthefacilitycurrentlyusingafloatingdredgethathascapabilities
to cross back and forth across the lagoon. Sludge that is removed from the existing lagoon is
transferred to a 600, 000gallon holding tank where it is continuously mixed before being pumped
using rotary lobe pumps to a centrifuge where it is dewatered. The proposed process will include
the modification of the existing secondary treatment process including the oxidation ditch and
clarifiers to be used for sludge handling. The existing oxidation ditches will be used for sludge
digestion using a system that will minimize the phosphorus return to the treatment train. The
existing clarifiers will be used for thickening and sludge holding. Sludge from the clarifier/sludge
holding tanks will be transferred via new rotary lobe pumps directly to the centrifuge for
dewatering.
6. Please submit the Mercury Minimization Plan developed for this facility. I am not aware of the plan.
A Mercury Minimization Plan was submitted previously. A copy of the plan will be forwarded to
your office under separate cover.
7. As required by Session Law 2018-5, Senate Bill 99, Section 13.1(r), every applicant shall now submit
documentation of any additional pollutants for which there are certified methods with the permit
application if their discharge is anticipated. The list of pollutants may be found in 40 CFR Part 136, which
is incorporated by reference. If there are additional pollutants with certified methods to be reported,
please submit the Chemical Addendum to NPDES Application table with your application and, if
applicable, list the selected certified analytical method used. If no additional sampling was conducted
and/or there are no additional pollutants to report, please note as much on the form itself. This
requirement applies to all NPDES facilities. The Chemical Addendum to NPDES Application will be
required for any type of facility with an NPDES permit, depending on whether those types of pollutants
are found in your wastewater. Please fill out, sign and submit the Chemical Addendum to NPDES
Application.
The Chemical Addendum will be signed and submitted
S. Please provide the letter of request for a nutrient adjustment for transfer of loading from the South Harnett
Regional WWTP to the North Harnett Regional WWTP. MBD on behalf of HRW.
The letter ofrequest for nutrient adjustment has been forwarded to NCDEQ. A copy of the letter is
attached
Expansion Request
1. In section 2.2 of the EAA, you note that Lillington, Fuquay-Varina and Angier have all made requests for
additional flows to be added to their contractual agreements with Harnett Regional Water. Please provide
these requests.
The letter request from each one of the participants in the system (Lillington, Fuquay Varina, and
Angier) are attached
MBD Consulting Engineers, P.A.
911 Norman Alley
Conway, SC 29526
843.488.0124

Mr. Nick Coco, P.E.
February 8, 2023
Page 4
2. In section 2.3 of the EAA, please provide growth rates for the towns of Lillington, Fuquay-Varina and
Angier, and explain the implications of the growth of these towns on the service area/provide context for
the future flow needs outlined in Table 2.2. Additionally, please provide a 2042 projected population for
the county and service area. MBD with some discussions with Lillington, FV, and Angier.
Response for this item is included with response for Item #3 below.
In section 2.4 of the EAA, please provide the calculated flow estimates for the service area. At this point,
the requested allocations are provided from each town, but a true flow calculation based on growth
projections is not provided.
In the expansion request items in the email that we received, there was a discussion about the
growth rates for the town of Lillington, Angier, and Fuquay Varina, and population projection as
well as information about Harnett County. In the original EAA document, MBD reviewed the
current contract flow allocation foreach ofthe entities and the currentaverage usage from each one
of the entities, as well as committed flow that is not yet tributary for each. This provided a total
current demand for each of the systems.
Fach of the entities (Lillington, Fuquay Varina, and Angier) provided a letter of request for
additional flow into the North Regional wastewater treatment. Copies of those requests are
attached Each of the entities and their request for flow, as well as theirprojectedgrowth demand
is discussed below.
Town ofFuquay Varina
As is indicated in the chart enclosed in the original EAA document, Fuquay Varina's current usages
plus committed flowis 215 or 83% of their current allocation of2.6MGD. In their letter to HR W,
Fuquay Varina requested an additional3.4 MGD of capacity increasing their total capacity to 6. 0
MGD.
According to OSW data a vailable, as ofAprih, 2020, the population for Fuquay Varina was 34,152.
Projected growth rates for Fuquay Varina are currently growing at a rate in excessive of 4% and
continuing togrow through 2029at approximately35% Using growth rate of3.5% over the next
20 years, the current flow of2.15MGD will increase to 4.28 MGD or 70% of the requested 6. 0 MGD
total capacity. Due to the rapid growth rate and the volatility of this area of Wake and Harnett
County, we feel that the requested expansion capacity is justified.
Town ofAn
In Angier's letter to HR W requesting additional flo w, they provided details as to the projects under
development and the current flow within their system and provided justification in their letter for
the additional capacity. We request that you refer to the letter of request to Mr. Steve Ward from
July15,, 2021 from the Town ofAngier to validate their request for capacity.
Town ofLillinton
Data from the Town of Lillington shows that the Town is curren tlygro wing a t a rate of sligh tly o ver
3% annually. The current average usage for the Town of Lillington plus flow not tributary to this
system is .87MGD or 72.5% of the current capacity allocated to Lillington. Using a growth rate of
ZS% which is the projectedgrowth rate for Lillington in the future, this increases the flow from .87
MGD to 114 MGD or 67% of the requested capacity ofJ.7MGD. Once again, we feellike the request
from Lillington is justified by the growth rates and their current capacity.
MBD Consulting Engineers, P.A.
911 Norman Alley
Conway, SC 29526
843.488.0124

Mr. Nick Coco, P.E.
February 8, 2023
Page 5
Harnett County
The HRW allocation in the North Regional WWTP is currently 2.6 MGD with their current
demand plus committed non -tributary at over 3 MGD. The HRW capacity has been and will
continue to be the buffer for all of the systems, as well as the remaining service area for the North
Regional WWTP. This area includes a very volatile area ofnorthern Harnett County and southern
Wake County. Data available states that the co un ty is gro wing a t a rate of138%and currentlyhas
a population of135,,986. In data available from 2014 to 2021, Harnett County grew approximately
9%for a rate of1.6S%.
Asa countywide system, HRW has the ability to continue to expand their service area especially in
the northern area of the county where there are a number of open tracts that are not within the
jurisdiction of any of the cities or towns listed above. These undeveloped tracts area potential for
growth in the future.
When calculating the demand for the county in the next 20 years, a growth rate of1S% was used
For this are of the county we believe the rate is lower than the potentialgrowth rate for this area
over the next 20 years. Based on 1 S% the flow would increase to 4. 04 MGD or 62 % of the requested
capacity. As is currently the case, reserve capacity needs to be available in the HR W allotment for
potential industrial growth, residential growth, and any increase in the needs from any of the
remaining entities. Based on the current and projectedgrowth for Harnett County, the need to ha ve
reserve industrial capacity in the system, and their requirement to be a buffer for the growth of
volatile areas such as Angier and Fuquay Varina, the requested allocation of 6.47MGD is justified
4. Is there any industrial growth that the County is aware of for this service area?
There is no known industrial growth proposed for the areas of the county; however, the county
should retain a reserve capacity for both water and wastewater to facilitate anyindustrial expansion
in the county. Industrial reserve is included in the Harnett County request for capacity.
5. Please provide the permit number for the rescinded land application permit mentioned in section 3.2.2.
The permit numberfor the rescinded land application permit is WQ0028562.
We appreciate working with you on this project. If you have any questions or need additional information,
please contact this office.
Sincerely,
oseph W. McGougan, P.E.
President
MBD Consulting Engineers, P.A.
911 Norman Alley
Conway, SC 29526
843.488.0124

North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis Comments
ATTACHMENTS
Renewal Application
1. Updated Schematic
2. Pass/Fail Documentation
3. Ownership Change
4. Reduced Monitoring Change
5. NA
6. NA
7. NA
S. Nutrient Request
Expansion Request
1. Participant Requests
2. NA
3. NA
4. NA
5. NA

North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis Comments
RENEWAL REQUEST 1. UPDATED SCHEMATIC

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North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis Comments
RENEWAL REQUEST 2. PASS/FAIL DOCUMENTATION

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 01/21/21
Facility: HARNETT CO. REGIONAL WWTP NPDES#: NCO021636 Pipe#: 001 County: HARNETT
.aboratory er�qr,�'l�J�.ng Test: MERITECH LASS, INC.
Comments;
X
5ignaoure pz uperaror in xesponszn..e unarge
Signature of a oratory Supervisor * PASSED: 1.19% Reduction
Work Order: Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Water Quality
N.C. DENR
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
North Carolina Ceriodaphnia
Chronic Pass/Fail Reproduction Toxicity Test Chronic Test Results
Calculated t = 0.162
Tabular t = 2.508
CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 % Reduction = 1.19
# Young Produced 1124121123117117121125125123120115122
Adult (L)ive (D)ead JAL IL IL IL IL IL IL IL IL IL IL IL
Effluent %: 2.1%
TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 24 19 24 24 L23.[1]722 14 13 26 23 21
Adult (L) ive (A) ead JIL L IL IL IL L L L L L{ L L
1st sample 1st sample 2nd sample
pH
Control 8.00 7.98 8.02 8.16 8.15 8.02
Treatment 2 7.94 8.02 7.69 8.10 8.13 8.06
s s s
t e t e t e
a n a n a n
r d r d r d
t t t
1st sample 1st sample 2nd sample
D.O.
Control 8.22 7.93 8.14 7.91 8.05 7.88
Treatment 2 7.73 7.88 8.14 7.94 8.12 7.90
LC50/Acute Toxicity Test
(Mortality expressed as %s, combining replicates)
% Mortality
Avg.Reprod.
0.00
21.08
Control
Control
0.00
20.83
Treatment 2
Treatment 2
Control CV
15.595% PASS FAIL
control orgs X
producing 3rd
brood Check One
1000
Complete This For Either Test
Test Start Date: 01/13/21
Collection (Start) Date
Sample 1: 01/11/21 Sample 2: 01/13/21
Sample Type/Duration 2nd
1st P/F
Grab Comp. Duration D
z S S
Sample 1 X 24.0 hrs L A A
U M M
Sample 2 X 24.0 hrs T P P
Hardness (mg/1) 44 ........ .........
Spec. Cond.(pmhos) 154 374 361
Chlorine(mg/1) <0.1 c0.1
Sample temp. at receipt(°C) ........ 0.-1 0.6
Note: Please
Concentration Complete This
Section Also
Mortality
start/end start/end
LC50 = % Method of Determination
95% Confidence Limits Moving Average _ Probit
PC -- % Spearman Karber Other
Control
High
pH
Organism Tested: Ceriodaphnia dubia Duration(hrs):
M •
Copied from DWQ form A1'-1 (3/87) rev. 11/95 (DUBIA ver. 4.41)

Effluent Toxicity Report Form -Chronic Fathead Minnow Multi -Concentration Test DateA/22/2021
Facility: North Harnett Regional NPDES # NC00 21636 Pipe #: County: Harnett
,..yauio Ui 4auvicituiy oupervisor
MAIL ORIGINAL TO: Water Sciences Section
Aquatic Toxicology Branch
Division of Water Resources
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Test Initiation Date/Time
% Eff. Repl,
Control Surviving #
Original #
Wt/original (mg)
D.525 Surviving #
Original #
Wt/original (mg)
1.05 Surviving #
Original #
Wtloriginal (mg)
2.1 Surviving #
Original #
Wt/original (mg)
4.2 Surviving #
Original #
Wt/original (mg)
8.4 Surviving #
Original #
Wtloriginal (mg)
Water Quality Data
Control
PH (SU) InitlFin
DO (mg/L) Init/Fin
Temp (C) Init/Fin
High Concentration
PH (SU) Init/Fin
DO (mg/L) Init/Fin
Temp (C} Init/Fin
Sample
Collection Start Date
Grab
Composite (Duration)
Hardness (mg/L)
Alkalinity (mg/L)
Conductivity (umhos/cm)
Chlorine(mg1L)
,-,Temp. at Receipt ("C)
1/12/2021
1
2:27 PM Avg Wt/Surv. Control 0.530
2 t a
10
10
10
10
10
E]fE-
10
0.528
0.557
U.470
10
10
10
10
10
10
10
10
0.519
0.504
0.544 1
0.6D5
9
101
10
g
10
10
10
10
0.474
0.561
0.484
0.504
10
10 10
10
10
10 10
10
0.562
0.521 0.531
0.479
8
10
10 9
10
14
10 10
0.505
D.536
0.537 0.41 D
10
10
10 10
E51
10
10 10
4
0.483
0.542 0.563
u
Day
% Survival 97.5
Avg Wt (mg) 1 0.517
% Survival 100.0
Avg Wt (mg) 0.543
% Survivall 95.0
Avg Wt (mg) 0.506
% Survival 100A
Avg Wt (mg) 0.523
% Survival 92.5
Avg Wt (mg) 0.497
% Survival 100.0
Avg Wt (mg) 0.526
2 3 4 5
7.70 / 7.83
7.55 1 7.71
7.79 / 7.72
7.80 ! 7.77
8.02 17.68
7.90 1 7.72
7.89 1 7,29
1 7.72
E26
8.10 1 7.51
8.15 / 7.55
7.82 1 7.60
8.02 1 7.47
8.04 17.80
8.08 1 7.03
24.0
24.2 / 24.2
25.0 1 24.4
24.3 1 24.3
24.6 1 24.2
24.3 1 24.4
24.2 1 24.8
0 1 9
7.80 1 7.67
7.83 1 7.71
7.77 1 7.74
7.82 1 7.80
17.85 1 7.69
17.81 1 7.78
1 7.81 1 7.47
8.13 1 7.62
25.3 -;24.1
8.04 ! 7.50
1 24.3 1 24.1
7.99 1 7.22
25.2 1 24.1 1
7.79 17,63
25.9 / 25.1
7.96 1 7.51
1 24.7 / 24.7 125.1
1 8.03 1 7.72
1 24.7
1 8.13 1 7.24
1 2 1
1110/2021
1 /12/2021
1 /14/2021
24.0
24.0
24.0
86
92
100
95
108
1 85
355
402
328
<0. i
<0.1
<0.1
0.4
0.2
0.5
udution H2O Batch # 1535 1536 1537 1538
Hardness (mg/L) 44 42 44 44
Alkalinity (mg lL) 32 30 30 33
;onductivity (umhos/cm) 167 167 158 167
Test Organisms
7 Cultured In -House
F Outside Supplier
Hatch Date: 1/11121
Hatch Time: 3:00400 pm CT
Survival
Growth Overall Result
Normal
F-11
Fi ChV >8.4
Hom. Var,
F-I,
!rl
NOEC
8.4
8.4
LOEC
>8.4
>8.4
ChV
>8.4
>8.4
Method
Steel'S
Dunnett's
Scats
Survival
Growth
Conc.
Critical Calculated
Critical Calculated
0.525
10 20
2.41-0,8842
1.05
10 16
2.41 0.3587
2.1
10 20
2.41-0.2252
4.2
10 15.5
2.41 0.6506
8.4
10 20
2,41-0.3003
AT-5 (1104)

117,
a�vi�or�.�w.uir..m,osoude.wY,c,
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LCsa
PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
Date: May 20, 2021
Fad itY: Environment 1, Inc. NPDES #: NC 0021636 Pipe #: 001 County: Harnett
North Harnett County Regional W VVTP
Laboratory Performing Test: Environmental Testing Solutjqns,4qc., Certificate 4037 Comments
Signature of Operator in Responsible Charge (ORO:
ORC Phone / E-mlillb A Protect 4; ISM
Signature of Laboratory Supervisor: Sample M 210512.10, 210514A9
e-Mall to: ATForms.ATB@ncdenr..go�
Or Mail Original to: North Carolina Division of Water Resources
Water Sciences Section / Aquatic Toxlcology Branch
1621. Mail Service Center
Raleigh, NC 27699-1621
North Carolina Cerioda Chronic Pass/Fail Reproduction Toxicity Test
Control Organisms 1 2 3 4 5 6 7 8 9 10 11 12
ier of Young Produced
Survival: Wive, (D}ea
Effluent PercentagE 2.196
.►.j n .....i1 ') R A 5 G 7 8 9 10 11 12
Number of Young ProducedM
24�
25 27
26
28
28
27
28
25
27
Adult Survival: L ive, D Cad
I
L L
L
L
L
L
L
L
L
Chronic Test Results
t-Stat / Rank Sum 1.545 _
t-Tailed Critical 2.508
% Reduction: 3.6
Percent
Average
Mortelity
Reproduction
Control
Control
0.0
27.7
Treatment 2
Treatment 2
0.0
26.7
Control CV
6.4
PASS FAIL
%<ervtl aranlnmpradix4q
100.0
—L-�
2
PH (S.U.) 1st Sample 2nd yarn le 2nd Sam le Test Start Date: May 12, 2021
Control 7.93 8,2$ 804 9.25 8.16 8.11
Treatment 2 17.9318.271 8.15 8.23 8.15 8.15 Collection (Start) Date:
c � Sample 1 05-10-21 Sample 2 05-12-21
U w
D.O. (mg/L) 1st Sara fie 2nd Sample 2nd Sample Sample Type/Duration
Control E7.5
7.8 17.718.0 7.6 7,6 Grab Comp. Duration
Treatment 2 7.6 7.6 8.1 7.718.01 sample 1 X'b ; d d
m E E.
Sample 2 x 244 La 12 .n 2 3
A6te.Toxic! tji i'esi .:: Alkalinity (mg CaCOdl.)
(Mat tality�x}aressed a§ %, 4ombining replicatt's j Hardness (mg caca31i 1
Colductivity (µmhos/cm)
Total Residual Chlorine (mg/I.)
ilAortalitVf%) - SampleTemp. at Receipt Iqc}
DWR Report Form AT-1
54
41
V.
310, 314, 312
594
633
40.10
<0.10
1.9
0.6

E-ironnee.nl Rseing sdl.dt 1-
PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date. July 31, 2021
Facility: Environment 1, Inc. NPDES#: NC 0021636 Pipe#. 001 County: Harnett
North Harnett County Regional WWTP
Laboratory Performing Test., Environmental Testing Soluti _ s, In , Certificote # 037 Comments
Signature of Ope to in Responsible Charge (ORC):
�.
ORC Phone / E-mai : ( i - - 4 � ° � ' - Project #: 16147
Signature of Laboratory Supervisor: r jy " sample #: 210721.ii, 210323.11
e-Mai! to: ATForms.AT6 nc enr- ov hv-4ei .Mja
Or Mail Original to: North Carolina Division of Water Resources
Water Sciences Section / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Ceriodaphnio Chronic Pass/Fail Reproduction Toxicity Test
r. #--i nro-i- 1 Z q 4 5 ti 7 St q 1 n 11 12
Number of Young Produced
128
129
28
30
29
28
28
29
28
29
29
32
Adult Survival: (L)ive, (D)ead
I L
I L
L
L
L
L
L
L
L
L
L
L
Effluent Percentage EE
Traefnnant 7 nranneernc 1 2 - 4 S 6 7 R 9 1.f1 11 12
Number of YoungProduced
29
30
33
29
31128
32
33
31
31
32
30
Adult Survival: (L)jve, (D)ead
ILI
LILILILILI
LILI
LILI
Ll
L
pH (S.LI.) 1st Sam le
2nd Sample
2nd Sample
Control
17.921
8.07
8.03 8.15
18.07 7.95
Treatment 2
7.99
8.09
17.9818-141
8.10 7.98
ro
t
a
D.O. (mg/L)
Control
Treatment 2
Test Start Date:
Collection (Start) Date:
Sample 1 07-19-21
Chronic Test Results
t-Stat / Rank Sum -3.206
i-Tailed Critical 2.508
% Reduction: -6.3
Percent
Average
Mortality
Reproduction
Control
Control
0.0
28.9
Treatment 2
Treatment 2
0.0
30.8
Control CV
4.0
PASS FAIL
organisn¢ prodvcng
z W_4
y
100.0
^
July 21, 2021
1st Sample 2nd Sample 2nd Sam le Sample Type/Duration
7-7 8.0 8.0 8.2 7.8 7.7 Grab Comp. Duration
8.1 8.0 $,0 8.1 8.0 8.2 Sample 1 X z4-h g a
Sample 2 x za-n
-o
Sample 2 07-21-21
LC,,/Acute Toxicity Test Alkalinity (mg CaCO3/1-I
(Mortality expressed as %, combining replicates.) Hardness (mgCaCO3/Lj
Conductivity (µmhos/cm)
Concentration N Total Residual Chlorine (mg/L)
mortality(Y-) Sample 7emp. at Receipt (°C)
LCSO = Method of Determination
d a
a c.
Ln in
58
83
321, 303, 3o4
518
496
<0.10
<0.10
1-7
1 2.0
95% Confidence Limits Trimmed Spearman Karber t! t
to Probit
Other: Control
Nigh Conc.
Organism Tested: Duration: pH (S.U.) DO (mg/L)
DWR Report Form AT-1

PO Box 7565
Asheville, NC 28802
Phone: [phone]
E.1—ftug k5thig So 144(m. Inc Fax: [phone]
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LCso Date: October 25, 2021
Facility: -Environment 1, Inc. NPDES M NC 0007684 Pipe 001 County: Harnett
Harnett County Regional WTP
Laboratory Performing Test: Environmental Testing Solutions, 1pj:., Certificate# 037 Comments
—7
Signature of Operator in Responjklble. Charge (ORC);
ORC Phone/ E-mail: pr9ject N: 16384
Sample N. 211013.06 21-1015-06
2U��
Signature of Laboratory Supervisor:
e-Mail to- ATForMSAT-8@J19d9-n-F--92-V-
Or Mail Original to: North Carolina Division of Water Resources
Water Sciences Section / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina CEdedRaftafl? Chronit Pass Fall Reproduction TdA9V —Test
A r r- -7 Q a in 11 17
Number of Young Produced 133731132
132
1 33j
34
1 35 1
30
33 34
29 30 1
Adult Survival: _(L)iy,e (D) ad I L
I L
I
=
L
I L
I L
I L
L I L
I L I L
--j
Effluent Percentage F13%
—Acr-7001n1117
I FCAU
Number of Young Produced
132 1371
IS
2K2LL—i3—
-37-
40
.3 3J
3736
1
34
11 35�
Adult Survival; (Qive,(V)ead
I Lj
L
I LT
L
L
I L
I L I L
I L I L I L I L I
Chronic Test Results
t-Stak I Rank Sum -4,611
1-Tailed critical 2.508
% Reduction: -12.4
Percent
Average
Mortality
Reproduction
Control
control
0.0
32.2
Treatment 2
Treatment 2
0.0
3&2
Control CV
5.8
PASS FAIL
%WVW"CW— VlddM
3,,JbMpd
100.0
pH (S.U.) 1st Sample 2nd Sam le 2nd Sam le Test Start Date: October 13, 2021
Control 17.6517,831 7.81 7.73 7.72 7.86
7.60 7.79 7.71 7.7-5
Treatment 2 ra Collection (Start) Date*
t: V Sample 1 10-12-21 Sample 2 10-14-21
;X U9
D.O. (rng/L) 1st Sam le 2nd Sam le 2nd Sam le Sample Type/Du ration
Control [777 17.5 7.6 7.9 7.7 7.9 Grab COMP. DuratlO" C4
Treatment 2 0 0 Samples w
E71�] s.1 8.2 9.0 8.1 '9 CL
Sample 2 X 3:
Alkalinity (mg CaC08/0
LC-'dkdie,TDXlcll:y-Tes1.,
Martali. ex rested as 96, le ambiningTephcates i Hardness (mg CaCO3/Q
Conductivity filmhos
71 Total Residual Chlorine (mg/L)
F
KA-i-04�: iqLj Sample Temp. at Receipt rQ
63
323,317,3167
A
160
<o. 10
<0. 10
0.7
0.7
DWR Report Form AT-1

Environmental Testing Sclntiom, Inc.
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LCso
Facility: Environment 1, Inc. NPDES #: NC 0021636 Pipe #: 001
North Harnett County Regional WWTP
Laboratory Performing Test: Environmental Testing Soluti s, IFICA Cer ' ' to # 037
Signature of Operator in Responsible Charge (ORC):
ORC Phone / E-mail -'2 a .pa
Signature of Laboratory Supervisor:
e-Mail to: [e-mail]
Or Mail Original to: North Carolina Division of Water Resources
Water Sciences Section / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Ceriodophnia Chronic Pass/Fail Reproduction Toxicity Test
Control Organisms 1 2 3 4 5 6 7 9 9 10 11 12
Number of Young Produced 33 29
34
29
34
35
30
32
33 31
30
30
Adult Survival: (L)ive, (Il L L
L
L
L
L
L
L
L L
I L
I L
Effluent Percentage EE
Treatment 2 Organisms 1 2 3 4 5 6 7 8 9 10 11 12
Number of Young Produced
38
34
35
32
30
36 34
30
36
38
37
35
Adult Survival: (L)ive, (D)ead
L
L
L
L
L
L L
L
L
L
L
I L
PH (S.U.) 1st Sample
2nd Sample
2nd Sample
Control 7.83 7.61
7.56
7.78
7.83 7.70
Treatment 2 1 7.63 7.63 1
7.6117.751
17.73 7.71
If
t
w
V
D.O. (il
Control
Treatment 2
est Start Date:
PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
Date: January 31, 2022
County: Harnett
Comments
Project #: 16649
Sample #: 220119.07, 220121.07
Collection (Start) Date:
Sample 1 01-17-22
Chronic Test Results
t-Stat / Rank 5um -2.921
1-Tailed Critical 2.508
% Reduction: -9.2
Percent
Average
Mortality
Reproduction
Control
Control
0.0
31.7
Treatment 2
Treatment 2
0.0
34.6
Control CV
6.6
PASS FAIL
%[o�tr01 organisms producing
3,d brood
100.0
�/
X
January 19, 2022
1st Sample 2nd Sample 2nd Sample Sample Type/Duration
7.9 7.8 7.6 7.8 1 7.8 1 7.7 1 Grab Comp. Duration
7.9 8.0 1 7.9 1 8.2 $.2 8.0 Sample 1 X 14" o
Sample 2 X za-n
0
Sample 2 01-19-22
LC,,/Acute Toxicity Test Alkalinity (mg CaCO3/L)
(Mortality expressed as %, combining replicates.) Hardness (mg Cac03/L)
Conductivity (µmhos/cm)
Concentration (%} Total Residual Chlorine (mg/L)
Mortality (%) Sample Temp. at Receipt (°C)
LC50 = Method of Determination
60
88
293, 303, 325
452
454
<0.10
<0.10
0.8 1
0.6
95% Confidence Limits Trimmed Spearman Karber b t
to Probit W 17;Hw
Other: Control
High Conc.
Organism Tested: Duration: pH (S.U.) DO (mg/L)
ll Report Form AT-1

Environmental Tesdng Solutions, Inc
EffluentToxicity Report Form - Chronic Pass/Fail and Acute LC,,
Facility: Environment 1, Inc. NPDES #: NC 0021636
North Harnett County Regional WWTP
PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
Date:
Pipe #: 001 County:
Laboratory Performing Test: Environmental Testing Soluti ns, Inc., Certificate # 037
Signature of Operator in Responsible Charge
L(ORC):
ORC Phone / E-mail: fk,7Mq _ e.12 - C)
Signature of Laboratory Supervisor: I1ik��
e-Mail to: ATForms.ATB ncdenr. ov
Or Mail Original to: North Carolina division of Water Resources
Water Sciences Section / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Ceriodaphnia Chronic Pass/Fail Reproduction Toxicity Test
rn +-i nrnnn;cmc 1 7 4 5 6 7 8 9 10 11 12
Number of Young Produced
31
33
30
32
29 30
33
31
30
30
34
132
Adult Survival: (L)ive, (D)ead
L
L
L
L
L L
L
L
L
L
L
Effluent Percentage 2.1%
Tranfmnnt 7 Arvanitme 1 7 4 5 6 7 8 9 10 11 12
Number of Young Produced
38
1 38
1 32
134
134
136
134
1 38 1 32
138 136
134
Adult Survival: (L)ive, (D)ead
ILI
LIQL11-1
LILILI
L
l
11
L
pH (S.U.)
1st Sample
2nd Sample
2nd Sample
Control
7.68 7.80
7.67
7.82
LE9
Treatment 2
7,73 7.90
7.91
7.$3
t o
ro
71
t'
D,O. (mg/L)
1st Sample
2nd Sample
2nd Sample
Control
7.7 7.8
7.8
7.8
7.8 7.8
Treatment 2
7.9 7.8
8.1
7.8
7.8 7.9
Test Start Date:
April 19, 2022
Harnett
Comments:
Project #: 16856
Sample #: 220406.04, 220408.03
Collection (Start) Date:
Sample 1 04-04-22
Chronic Test Results
t-Stat / Rank Surn -5.091
1-Tailed Critical 2.508
% Reduction: -13.1
Percent
Average
Mortality
Reproduction
Control
Control
0.0
31.3
Treatment 2
Treatment 2
0.0
35.3
Control Cv
4.9
PASS FAIL
%antral organisms producros
3rd brood
v
100.0
n
Sample Type/Duration
Grab Comp, Duration
X 24-h
X 24-h
LC50/Acute Toxicity Test Alkalinity (mg CaCO3/L;
(Mortality expressed as %, combining replicates.) Hardness (mg CaCO3/L]
Conductivity (µmhos/cm;
Concentration (%) Total Residual Chlorine (mg/L;
Mortality (%) Sample Temp. at Receipt (,C;
Sample 1
Sample 2
ril 06, 2022
Sample 2 04-06-22
p W 2 al
ro a CL
E E
Q V, n
63, 63, 58
90, 86, 86
316, 305, 303
480
575
<0.10
<0.10
1.5
0.8
LC50 = Method of Determination
95% Confidence Limits Trimmed Spearman Karber t _C t
to Probit
Other: Control
High Conc.
Organism Tested: Duration: pH (S.U.) DO (mg/L)
DWR Report Form AT-1

rmr co
PO Box 7565
Asheville, INC 28802
Phone: [phone]
Fax: [phone]
r' Environmental Testin4 SelutivnilM.
Effluent Toxicity Report Form - Chronic Fathead Minnow Multi -Concentration Test Date: April 20, 2022
Facility: Environment 1, Inc.
NPDES#: NC
0021636 Pipe 4: 001 County: Harnett
North Harnett County Regional WWTP
Laboratory Performing Test: Environmental Testing SDlut' s, I c., i icate # 037
Comments:
Signature of Operator in Responsiblle harge (ORC):
ORC Phone /Email: �• 1 4` ��
Project #: 15825
Signature of Laboratory Supervisor:
Sample p: 220405.04, 220407.06, 220409.07
e-Mail to: [e-mail]
Test Organisms: Almephales promelas
Or Mail Original to: North Carolina Div7sion of Water
Resources
Supplier
Water Sciences Section / Aquatic
Toxicology Branch
In-house Culture
1621 Maii Service Center
Begin hatch: 04-04-22 1458
Raleigh, NC 27699-1621
End hatch: 04-05-22 0507
Test Start Date: April 05, 2022
Replicate
number
1
2
3
4
Control Isurviving number of larvae
1 10
1 10
10
10 survival)%) 100A
Organisms originalnumberoflarvae
1 10
1 10
10
10 Average wt (mg) 0.872
Weight/original (mg/larvae)
0,936
1 0.812
0,859
0.980 Average wt / 0.872
surviving Img)
% Effluent Isurviving number of larvae
10
1 10
10
10
0.525% Original number of larvae
10
1 10
10
10 Survival (%) 100.0
weight/criginal (mg/larvae)
_0-935__L
0.955 1
0.998
0.915 Average wt (mg) 0.951
96 Effluent Surviving number of larvae
10
10
10
1.05% Original number of larvae
10
10
10
Survival (%) 100.0
V
Weight/original (mg/larvae)
0.94b
0.970
1.015
Average wt (mg) 0.991
%Effluent ISurvivTng number oflarvae
10
10
10
10
2.1% Original number of larvae
10
10
10
10 survival (%) 100.0
Weight/original (mg/larvae)
1 0.860
0.950 1
0.954 1
0.952 Average wt (mg) 0.929
• Effluent surviving number of larvae
10
10
10
10
Original number of larvae
10
10
10
10 Survival (%) 100.0
Weight/original (mg/larvae)
0.870
0,935
1,000
0.962 Average wt (mg) 0.942
• Effluent 15urviving number of larvae
10
10
10
10
8.4% original number larvae
10
10
10
10 Survival (%) 100.0
weight/original (mg/larvae)
0.910
1 0.899
0.976
0.847 Average wt (mg) 0.908
Water Quality Data
Day 0 Day }
Day 2
Day 3
Day 4 Day 5 Day 6
Initial I Final Initlal I Final
Initial I
Final Initial I Final
Initial I Final fnitiaE I Final Initial Final
Control
PH(SU):
DO (mg/L]:
Temp. (°C):
High Concentration
pH (SU):
DO (mg
Temp. (°C):
7.75
7.70
7.68
7.55
7.47
7.54
7.67 7.69
2.53
7.42
7.66
7.61
7.67
7.24
7.7
7.8
7.7
1 7.7
1 7.9
7.2
7.8 7.0
7.7
7.0
7.9
7J
AS
6.5
1 24.8
24.8
24.8
1 24.6
1 24.7
24.6
24.9 24.5
24.8
24.7
24.7
24.6
24.7
24.8
7.64
7.64
7.77
7.46
7.68
7.47
7,84
7,53
7.78
7.36
7.84
7.56
7.79
7.18
8,1
8.0
8.1
7.9
7.6
7.4
8.1
7.2
7.6
6.8
7S
7.6
8.2
6.4
24.7
24.9
24.8
24.7
24.9
24.5
25.0
24.7
25.0
24.6
24.9
24.8
24.9
24.7
Sample Information
Collection start date:
Grab:
Composite duration:
Alkalinity jmg/L CaCO3):
Hardness (mg/L CaCO3):
conductivity (µmhos/cm):
Total residual chlorine (mg/L):
Sample Temp. at Receipt (°C):
Analyses
Normal:
Ham. Var.
NOEC:
LOEC:
Chv:
Method:
Overall Analysis:
Result: PASS LOEC: >8.4% NOEC: 8.4% ChV: >8.4%
DWR Report Form AT-5
Survival
Growth
Yes
Yes
Yes
Yes
8.4%
8.4%
>8.4%
>8.41/
>8.4%
>8.4%
Visual lnsp.
Durrett`s
Survival
Growth
%Effluent
Critical
Calculated
Critical
Calculated
0.525%
2,410
-2.150
2.410
-3,221
2.1%
2.410
-1.553
4.2%
2A10
-1.899
&4%
2.410
-0.977

Environmental Testing Solutions, Inc.
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50
PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
Date: July 28, 2022
Facility: Cameron Testing Services NPDES #: NC 0021636 Pipe #: 001 County:
North Harnett County Regional WWTP
Harnett
Laboratory Performing Test: Environmental Testing Soluti s Inc., Certificate # 037 Comments
Signature of Operator in Responsible Charge (ORC):
ORC Phone / E-mail: urn-s' �-Adboeaj Project #: 17166
Signature of Laboratory Supervis( Sample #: 220719.03, 220721.03
e-Mail to:
Or Mail Original to: North Carolina Division of Water Resources
Water Sciences Section / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Ceriodaphnia Chronic Pass Fail Reproduction Toxicity Test
r...-0-1 r%. 1 7 1 4 S 6 7 R 9 10 11 12
Number of Young Produced
35
28
29
34
29
32
30
29
33
32
32
31
Adult Survival: (L)ive, (D)ead
L
L
L
L
I L
L
L
L
L
L
L
L
Effluent Percentage 2.1%
T..,.,F.,,.,.,. ') n.r.­t­ 1 7 R 4 5 6 7 8 9 10 11 12
Number of Young Produced 135
134
32
31
130
1 28
31
30
32
34
29
32
Adult Survival: (L)ive, (D)ead
I L
I L
I L
I L
I L
I L
L
L
L
L
L
L
PH (S.U.) 1st Sample
Control
7.46
7.70
Treatment 2
7.67
7.83
r �
m s=
D.O. (mg/L)
1st Sample
Control
7.7
1 7.7
Treatment 2 1 7.6 1 8.3
2nd Sample
2nd Sample
7.45 7.89
7.53 7.64
7.801 7.77
7.721 7.87
r a
2nd Sample
2nd Sample
7.6
7.7
17.7 1 7.7
8.3
1 7.9
17.8 1 7.7
LCso/Acute Toxicity Test
(Mortality expressed as %, combining replicates.)
Concentration N
Mortality (%)
LCSO = Method of Determination
95% Confidence Limits Trimmed Spearman Karber
to Probit
Other:
Organism Tested:
Duration:
Test Start Date
Collection (Start) Date:
Sample 1 07-18-22
Chronic Test Results
t-5tat / Rank Sum -0.378
1-Tailed Critical 2.508
% Reduction: -1.1
Percent
Average
Mortality
Reproduction
Control
Control
0.0
31.2
Treatment 2
Treatment 2
0.0
31.5
Control CV
7.1
PA55 FAIT.
%control organisms producing
z hro9d
X
100.0
.
July 20, 2022
Sample Type/Duration
Grab Comp. Duration
Sample 1 X za-n
Sample 2 X za-n
Alkalinity (mg CaCO3/Q
Hardness (mg CaCO3/L)
Conductivity (mhos/cm)
Total Residual Chlorine (mg/L)
Sample Temp. at Receipt (°C)
Sample 2 07-20-22
om m as
cL o
E E
59
86
300, 307, 299
584
583
<0.10
<0.10
0.5
1 1.7
� t±
m
Control
High Conc.
pH (S.U.) DO (mg/L)
DWR Report Form AT-1

Ern.iranmemal TesoPg SnSutions, Irsc.
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LCsc
Facility: Cameron Testing Services NPDES #: INC 0021636
North Harnett County Regional WWTP
Laboratory Performing Test: Environmental Testing Solutio Infj, Certifi ate
Signature of Operator in Responsible Charge (ORQ:
ORC Phone / E-mail: 9 10 -39QY44•
Signature of Laboratory Supervisor:
PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
Date: October 21, 2022
Pipe #: 001 County: Harnett
# 037
e-Mail to: ATForms.ATBPncdelir.gov
Or Mail Original to: North Carolina Division of Water Resources
Water Sciences Section / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Ceriodaphnia Chronic Pass/Fail Reproduction Toxicity Test
rnntrnl flronnicmc 1 2 3 4 5 6 7 8 9 10 11 12
Number of Young Produced
32
35
33
29
29
28
31
30
31
33
31
32
Adult Survival: Wive, (D)ead
L
L
L
L
L
L
L
L
L
L
L
I L
Effluent Percentage Z.1%
'rr *. ant 7 neannicmc 17 4 5 6 7 8 9 10 11 12
Number of Young Produced
34
38
36
39
36
32
36
32
31
33
30
32
Adult Survival: (L)ive, (D)ead
L
L
L
L
L
L
L
L
L
L
L
L
pH (S.U.) 1st Sample
2nd Sample
2nd Sample
Control
7.40
7.19
7.14 7.31
7.30 7.33
Treatment 2
17.3217.271
17.1617.38
17.2817.161
t
D.O. (mg/L)
Control
Treatment 2
Test Start Date
Comments:
Project #: 17376
Samp[e #: 221011.24, 221014.03
Collection (Start) Date:
Sample 1 10-10-22
Chronic Test Results
t-Stat / Rank Sum -2.889
1-Tailed Critical 2.508
% Reduction: -9.4
Percent
Average
Mortality
Reproduction
Control
Control
0.0
31.2
Treatment 2
Treatment 2
0.0
34.1
Control CV
6.4
PASS FAIL
%control Organisms Praducros
3M brood
v
100.0
n
.
October 12, 2022
Sample 2 10-12-22
1st Sample 2nd Sample 2nd Sample
Sample Type/Duration
7.6
7.9
7.7 7.9
7.6 7.7
7.6 7.9
7.5 8.0
Grab Comp. Duration
sample 1
8.1
7.8
X 24-h
. X as-h
LCso/Acute Toxicity Test Alkalinity (mg CaCO3/L
(Mortality expressed as %, combining replicates.) Hardness (mg Caco3/L
Conductivity (µmhos/cm
Concentration {%) Total Residual Chlorine {mg/Lm
Mortality (%) Saple Temp. at Receipt (°C
sa
87
312, 303,307 530 591
<0 14 <0.10
1.1 1.2
LC50 = Method of Determination
95%Confidence Limits Trimmed Spearman Karber a
_
_
to Probit w
Other: Control
High Conc.
Organism Tested: Duration: pH (S.U.) DO (mg/L)
DWR Report Form AT-1
LC50 = Method of Determination
95%Confidence Limits Trimmed Spearman Karber a
_
_
to Probit w
Other: Control
High Conc.
Organism Tested: Duration: pH (S.U.) DO (mg/L)
DWR Report Form AT-1

North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis Comments
RENEWAL REQUEST 3. OWNERSHIP CHANGE

NORTH CAROLINA
Environmental Quality
NC DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NPDES PERMITTING
PERMIT NAME OWNERSHIP CHANGE FORM
CURRENT PERMIT INFORMATION:
Permit Number: NCOO 8/8/3/6/6 or NCGS_/_f_/_/_
1. Facility Name: South Harnett Waste Water Treatment Plant
NEW OWNER/NAME INFORMATION:
1. This request for a name change is a result of:
a. Change in ownership of property/company
—X b. Name change only
c. Other (please explain): _
2. New owner's name (name to be put on permit):
Harnett Regional Water _
3. New owner's or signing official's name and title: Brent Trout
(Person legally responsible for permit)
Harnett County Manager
(Title)
4. Mailing address: 455 McKinney Parkway, PO Box 759 _ City: Ullington
State: NC Zip Code:. 27546 Phone: [phone]
E-mail address: btroutci�,harnetts _
FACILITY AND DISCHARGE INFORMATION
1. Will the waste stream for the facility remain the same as under the previous owner? Yes ❑ No ❑
2. Will the treatment system and discharge location remain the same? Yes ❑ No ❑
"No Responses"
If either or both of these questions are answered "No" then more information will be needed to review the
request. Please attach documentation to describe and explain the changes to the facility activities, waste
stream, treatment process or outfall location. The Division may not be able to process the Permit
Name/Ownership Change request and may require that the new owner file a new permit application.
Almh6N� North Carolina Department of Environmental quality I Division of Water Quality
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

NPDES Name and Ownership Change
Page 2 of 2
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION UNLESS ALL OF THE
APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a property deed, articles of
incorporation, or sales agreement)
3. Information to document facility, waste stream, treatment system or outfall changes as noted in
item III above (if appropriate)
Applicant's Certification:
I, Brent Trout _ _ attest that this application for
a name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that if all
required supporting information and attachments are not included, this application package will be
returned as incomplete. I understand that Permit Name/Ownership Change can only take place through
action taken by the Division of Water Resources and that no actions on my part or the part of my
company result in the automatic transfer of permit coverage.
Signature:
Date:. 3 - 23
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION & MATERIALS,
SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DEQ / DWR / NPDES
1627 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 07/2021

NORTH CAROLINA
Ebvlronmental Quality
NC DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NPDES PERMITTING
PERMIT NAME; OWNERSHIP CHANGE FORM
CURRENT PERMIT INFORMATION:
Permit Number: NCOO 2/1/6/3/6 or NCGS_/—I—I_/
1. Facility Name:. North Harnett Waste Water Treatment Plant
NEW OWNER/NAME INFORMATION:
1. This request for a name change is a result of:
a. Change in ownership of property/company
_X_b. Name change only
c. Other (please explain):. _
2. New owner's name (name to be put on permit):
Harnett Regional Water _
3. New owner's or signing official's name and title: Brent Trout
(Person legally responsible for permit)
Harnett County Manager
(Title)
4. Mailing address: 455 McKinney Parkway, PO Box 759 City: Lillington
State: NC Zip Code:. 27546 Phone: [phone] _ _ _
E-mail address: btrout(,�harnett.org
FACILITY AND DISCHARGE INFORMATION
1. Will the waste stream for the facility remain the same as under the previous owner? Yes ❑ No 0
2. Will the treatment system and discharge location remain the same? Yes ❑ No C7
"No Responses"
If either or both of these questions are answered "No" then more information will be needed to review the
request. Please attach documentation to describe and explain the changes to the facility activities, waste
stream, treatment process or outfall location. The Division may not be able to process the Permit
Nome/Ownership Change request and may require that the new owner file a new permit application.
North Carolina Department of Environmental Quality I Division of water Quality
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
�` " f 929,707.9000

NPDES Name and Ownership Change
Page 2 of 2
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION UNLESS ALL OF THE
APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a property deed, articles of
incorporation, or sales agreement)
3. Information to document facility, waste stream, treatment system or outfall changes as noted in
item III above (if appropriate)
Applicant's Certification:
I, Brent Trout _ _ . attest that this application for
a name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that if all
required supporting information and attachments are not included, this application package will be
returned as incomplete. I understand that Permit Name/Ownership Change can only take place through
action taken by the Division of Water Resources and that no actions on my part or the part of my
company result in the automatic transfer of permit coverage.
Signature: Date:_ - - - 2 3
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION & MATERIALS,
SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DEQ/ DWR / NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 07/2021

North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis Comments
RENEWAL REQUEST 4. REDUCED MONITORING CHANGE

HARNETT
REGIONAL
r WATER
February 1, 2023
NC Department of Environmental Quality
Water quality Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Attention: Nick Coco
Re: NPDES NCO021636
North Harnett Regional WWTP
Request to continue Reduced Monitoring
Mr. Coco,
www.harnettwater.org
PO Box 1119
700 McKinney Parkway
Ullington, NC 27546
ph: 910-893-7575
fax: [phone]
Harnett Regional Water respectfully requests to continue reduced monitoring as part of the ongoing
renewal process. 1 have included a copy of the original DWQ correspondence granting the permit
modification from back in 2015 along with a spreadsheet showing effluent monitoring results for these
parameters for the full compliance period 2017-2022. This data can be verified against NCDMR data
already in RIMS.
Please do not hesitate to contact me with any questions regarding this application or needs for
additional information.
Respectfully,
-14"'6-�- �/U J-4�1
Kenneth W. Fail
Wastewater Supt.
Harnett Regional Water
910-814-6470 (office)
[e-mail]

North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis Comments
RENEWAL REQUEST 8. NUTRIENT REQUEST

HARN ETT
REGIONAL
50j
January 31, 2023
Ms. Kristen Litzenberger
NCDEQ
Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699
RE: Harnett Regional Water
North Regional WWTP NPDES No. NCO021636
South Regional WWTP NPDES No. NCO088366
Nutrient Sharing Request
Dear Ms. Litzenberger:
www.harnettwater.org
PO Box 1119
700 McKinney Parkway
Lillington, NC 27546
ph: 910-893-7575
fax: [phone]
The North Regional WWTP and South Regional WWTP NPDES permits include seasonal nutrient limits in
total pounds during the winter months. The North Regional WWTP currently has a discharge volume of
7.5 MGD and the permit includes 59,968 lbs. of TN and 19,989 lbs. of TP for the period between April 1
through October 31 of each year. The South Regional WWTP permit has a discharge volume of 15 MGD
and the permit includes 160,629 lbs. of TN and 54,543 lbs. of TP for the same period of April 1 through
October 31. HRW has recently submitted a request to expand the North Regional WWTP permit from 7.5
MGD to 16.5 MGD. The speculative limits that were provided to HRW included the same poundage for TN
and TP as is currently listed in the NPDES permit.
In May 2022, HRW requested that the South Regional WWTP NPDES permit be expanded from 15 MGD
to 17.5 MGD but HRW recently withdrew that request and now requests that the permit be renewed for
a discharge volume of 15 MGD.
HRW is requesting that a nutrient sharing agreement be established between the two facilities where the
facilities have the ability to share a total of 220,596 lbs. TN and 75,532 of TP as a seasonal total poundage
limit for the two facilities.
Alternatives for sharing the nutrient load between the two facilities have been discussed with NCDEQ.
While the initial request would be for the ability to completely share between the two facilities, if that is
not possible at this time, HRW requests that a portion of the South Regional WWTP nutrient allocation be
transferred to the North Regional WWTP NPDES permit. The allocation would be based on the percentage
of flow as shown in the table below.

HARNETT REGIONAL WATER
NORTH REGIONAL WWTP NPDES NO. NC 0021636
SOUTH REGIONAL WWTP NPDES NO. NC 0088366
NUTRIENT TRANSFER REQUEST
FLOW %
TN _
CURRENT PROPOSED
TP
CURRENT
PROPOSED
NORTH
16.5 MGD
52.4%
59,968 LBS
115,550 LBS
19,989 LBS
53,543 LBS
38,517 LBS
35,015 LBS
SOUTH
15.0 MGD
47.6%
160,628 LBS
105,046 LBS
TOTAL
31.5 MGD
1.000
220,596 LBS 220,596 LBS
73,532 LBS
73,532 LBS
HRW requests that 55,582 lbs. of TN and 18,525 lbs. of TP be transferred from the South Regional WWTP
NPDES permit to the North Regional WWTP NPDES permit.
HRW appreciates the assistance from NCDEQ on this project. If we can provide any additional information,
please contact me at this office.
Sincerely,
Steve Ward
Director
cc: Michael Montebello, NCDEQ
Ken Pohlig, NCDEQ
Joe McGougan, MBD
www.harnettwater.org

North Regional WWTP Expansion
Harnett Regional Water
Engineering Alternatives Analysis Comments
EXPANSION REQUEST 1. PARTICIPANT REQUESTS

Town of Angier
www.an=ier.or
Robert K. Smith Gerry Vincent Veronica Hardaway
Mayor Town Manager Town Clerk
July 15, 2021
Mr. Steve Ward
HRW Director
Harnett Regional Water
P.O. Box 1119
Lillington, NC 27546
Reference: NHWWTP Capacity Commitment
Dear Mr. Ward:
In response to your letter of April 23, 2021 regarding capacity commitments for a planned expansion to
the NHWWTP, the Town of Angier is requesting an additional 1.25 MGD of treatment capacity.
Furthermore, the Town of Angier is requesting that we amend the July 2006 Wastewater Agreement to
include language that sets parameters for the Town to purchase an additional 1.0 MGD of treatment
capacity within the next 5 to 10 years. As per our recent discussion, we are tracking 0.579 MGD of not
yet tributary wastewater flow via 12 active developments. We are also tracking another 0.091 MGD of
not yet tributary wastewater flow via 3 additional developments that are in the engineering phase but have
not submitted for permits. Including the 15 projects and our current average daily flow we are at 1.352
MGD without accounting for any new developments going forward. The additional 1.25 MGD of
capacity allocation puts the Town at 2.258 MGD of treatment capacity in the NHWWTP. Based on these
current flow totals and our internal assessment of growth patterns over the next 5 to 10 years, we believe
having a structure in place for the purchase of additional treatment capacity beyond our 1.25 MGD
commitment to be critical in our planning process. Please advise as to how we can move forward with
developing a structure for future capacity purchase and amending our 2006 Agreement.
Sincerely,
TOWN OF ANGIER, NC
a--- 1
Gerry Vincent
Town Manager
Post Office Box 278 • Angier, North Carolina 27501-0278 • [phone]

i�
FJ0J/-"(-\//- R 11 Nn
north coro(ino
May 21, 2021
Mr. Steve Ward, Director
Harnett Regional Water
PO Box 1119
700 McKinney Parkway
Lillington, NC 27546
Re: Letter of Intent - NHRWWTP Treatment Capacity
Dear Mr. Ward,
In response to your April 23, 2021 letter, and under the Agreement dated November 9, 2000, this
notice is to confirm the Town of Fuquay-Varina's decision to participate in the expansion of the
North Harnett Regional Wastewater Treatment Plant (NHRWWTP).
Currently, the Town is contracted with Harnett County to receive 2.6 MGD of treatment capacity
from the NHRWWTP. This notice is to affirm the Town's request to increase our capacity by 3.4
MGD for a total of 6.0 MGD of treatment capacity. Following the November 9, 2000 Agreement,
this written notice serves as the Town's statement regarding our decision to participate in the
facility expansion. Upon completing this project's preliminary engineering reports, on the
condition that additional treatment capacity may be available for allocation, the Town would like
to discuss securing additional treatment capacity beyond its 4.0 MGD entitled treatment capacity
allotment.
We look forward to working with Harnett Regional Water on this very important project. In the
future, please coordinate this project's activities with Jim Seymour, Assistant Town Manager
(Development Services), jseymour2fuquay-varina.org 1 [phone].
Sincere ,
Adam Mitchell
Town Manager
Cc: Jim Seymour, Asst. Town Manager
Jay Meyers, Public Utility Director
James Adcock, Town Attorney
OFFICE OF THE TOWN MANAGER
Town of Fuquay-Varina =134 N Main Street, Fuquay-Varina, NC 27526 = [phone]=fuquay-varina.org

TOWN OF LILLINGTON
July 9, 2021
Mr. Steve Ward, Director
Harnett Regional Water
PO Box 1119
700 McKinney Parkway
Lillington, NC 27546
Re: Letter of Intent — NHRWWTP Treatment Capacity
Dear Mr. Ward,
In response to your letter dated April 23, 2021, please accept this response as the Town of
Lillington notice of confirmation of participation in the expansion of the North Harnett
Regional Wastewater Treatment Plant (NHRWWTP).
This notice is to affirm the Town's request for up to 2 MGD treatment capacity. This written
notice serves as the Town's statement regarding the decision to participate in the facility
expansion. Also, the Town would like the option to secure additional treatment capacity from
the NHRWWTP in the future.
The Town looks forward to continuing the strong working relationship with Harnett Regional
Water for years to come.
Sincerely,
J eph Jeffrie
Town Manager
Cc: Lisa Young, Assistant Town Manager
Alicia Gregory, Management Analyst
Ashley Wimberly, Public Works Director
102 East Front Street • P.O. Box 296 • Lillington, North Carolina 27546
Phone: [phone] • Fax [phone] • www.lillingtonnc.org

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� 11
i rCC6
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
May 1, 2015
Mr. Kenneth Fail, Wastewater Manger
Harnett County Public Utilities
P. O. Box 1119
Lillington, NC 27546
Subject: NPDES Permit Modification
Permit Number NCO021636
North Harnett Regional WWTP
Harnett County
Dear Mr. Fail:
Donald R. van der Vaart
Secretary
Division personnel have reviewed and approved your application for minor modification of the subject
permit. Accordingly we are forwarding the attached modified permit page. Please remove the existing
"Effluent Limitations and Monitoring Requirements" page and replace it with the one attached to this
letter.
This modification reduces the effluent monitoring frequencies for Biochemical Oxygen Demand
(BOD5), Total Suspended Solids (TSS), Fecal Coliform and Ammonia Nitrogen (NH3-N) from daily
(5/week) to 2/week monitoring. The modification was based upon an evaluation of three years of
facility effluent monitoring data. The facility's performance satisfies the criteria established in the
"DWQ Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits for
Exceptionally Performing Facilities" as approved by the Director of the Division of Water Resources on
October 22, 2012, and justifies reduced monitoring for these parameters. The modified monitoring
frequencies will become effective as of the date of this letter.
This modification 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).
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 Resources 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.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] \Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer — Made in part by recycled paper

Mr. Kenneth Fail
NC0021636 Monitoring Frequency Reduction
p. 2
If you have any questions concerning this permit, please contact Bob Sledge at telephone number (919)
807-6398 or via e-mail at [e-mail].
Sin ely,
S. Jay Zimmerman, Dir or ;
Division of Water Resources
attachment
cc: Central Files
Fayetteville Regional Office - DWR/Water Quality
NPDES Permit File
cc: EPA Region 4

Permit NCO021636
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on May 1, 2015 and lasting until expiration, the Permittee is authorized to discharge treated
wastewater from outfall 001 subject to the following effluent limitations and monitoring requirements.
EFFLUENT
LIMITS
MONITORING REQUIREMENTS'
CHARACTERISTICS
Monthly
Weekly
Daily
Measurement
Sample Type
Avera a
Average
Maximum
Frequency.
Sample Location
Flow
5.6 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20°C
(April 1 -October 3 1 ) z
5.0 mg/L
7.5 mg/L
2/Week
Composite
Influent & Effluent
BOD, 5-day, 20°C
z
(November 1 -March 31
10.0 mg/L
15.0 mg/L
2/Week
Composite
Influent & Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
2/Week
Composite
Influent & Effluent
NH3 as N
(April 1— October 31
1.0 mg/L
3.0 mg/l
2/Week
Composite
Effluent
NH3 as N
November 1— March 31
2.0 mg/L
6.0 mg/1
2/Week
Composite
Effluent
Dissolved Oxygen
Daily
Grab
Effluent
4
Dissolved Oxygen
See Footnote 4
Grab
Upstream & Downstream
Temperature, °C
Daily
Grab
Effluent
4
Temperature, °C
See Footnote 4
Grab
Upstream & Downstream
pH
6.0 — 9.0 standard units
Daily
Grab
Effluent
Total Nitrogen 5
Monitor & Report (mg/L)
3/Week
Composite
(April 1 - October 31)
Monitor & Report (lb/mo)
Monthly
Calculated
Effluent
59,9681b/ summer mass loading)
Annually
Calculated
Total Nitrogen
(November 1 - March 31
Monitor & Report
Monthly
Composite
Effluent
Total Phosphorus 6
Monitor & Report (lb/mo)
3/Week
Composite
(April 1 - October 31)
Monitor & Report (lb/mo)
Monthly
Calculated
Effluent
19,989 lb/ (summer mass loading)
Annually
Calculated
Total Phosphorus
(November 1 - March 31
Monitor & Report
Monthly
Composite
Effluent
Fecal Coliform
(geometric mean)
200 / 100 nil
400 / 100 nil
2/Week
Grab
Effluent
Chronic Toxicity
Quarterly
Composite
Effluent
Effluent Pollutant Scan 8
Monitor and Report
Footnote 8
Footnote 8
Effluent
N ores:
1. Upstream = at the US Highway 401 Bridge. Downstream = 1.3 miles downstream at the boat ramp. Instream monitoring is
provisionally waived in light of the permittee's participation in the Middle Cape Fear River Basin Association. Instream
monitoring will be immediately reinstated should the permittee end its participation in the Association.
2. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective
influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
4. Monitoring is to be conducted three times per week during June, July, August, and September, and once per week
during the rest of the year.
5. TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kj eldahl Nitrogen, and NO3-N and NO2-N
are Nitrate and Nitrite Nitrogen, respectively. See A.(3)
6. Total Phosphorus, see A.(4)
7. Chronic Toxicity (Ceriodaphnia) P/F @ 1.6%; January, April, July, and October. See Special Condition A. (2.)
8. The permittee shall perform three Effluent Pollutant Scans during the term of this permit [see A. (7)].
There shall be no discharge of floating solids or visible foam in other than trace amounts.

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UPDATED:1-28-2019 1 G•5

January 30, 2023
NCDENR,
Non -Discharge Permitting Unit
1617 Mail Service Center
512 North Salisbury Street
Raleigh, NC 27699-1617
Subject: Sludge Management Narrative
North Harnett Regional WWTP
NPDES # NCO021636
Dear Sir or Madam:
North Harnett Regional WWTP currently utilizes a 26 million gallon facultative lagoon for sludge
digestion and storage. Harnett Regional Water completed sludge handling upgrades in April 2020 that now
allows us to dewater our bio-solids. These upgrades included a new lagoon dredge, 600k gallon holding
tank, pumpstation, sludge building and shelter. The sludge is dewatered through a 21 foot Centrysis
centrifuge producing a 26% cake product.
In an effort insure Harnett Regional Water has a reliable conduit for sludge disposal, we have signed
disposal agreements in place with Sampson Disposal (Sampson County Landfill) and McGill Composting.
Harnett Regional Water is not currently utilizing land application but did have its permit #WQ0007066
renewed as a third option for sludge disposal. This permit was issued May 27, 2022 and has been included
with other additional information requested.
If you require any further information or clarification in this matter, please feel free to contact me.
Z:7ly,w
Kenneth W. Fail
Wastewater Superintendent
Harnett Regional Water
[e-mail]
910.814.6470

United States Environmental Protection Agency
Form Approved.
E PA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 IS I 3 I NCO021636 I11 121 20/02/27 I17 18 n 191 S I 201
21111111111111111111111111111111111111111111 f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 71 I I 72 I n, I 73 LLI74 79 I I I I I I I80
70 Iu ty LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 20/02/27
17/11/01
North Harnett Regional WWTP
607 Edwards Dr
Exit Time/Date
Permit Expiration Date
Lillington NC 27546
01:OOPM 20/02/27
21/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Billy J Thomas/ORC/910-890-1493/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Billy J Thomas,PO Box 1119 Lillington NC 275461119/Backup ORC/910-814-3042/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispos Facility Site Review Effluent/Receiving Wate
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Hughie White DWR/FRO WQ/910-433-3300 Ext.708/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Mark Brantley DWR/FRO WQ/910-433-3300 Ext.727/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
31 NC0021636 I11 12I 20/02/27 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
All records and log books were very well organized and maintained. A copy of the current NPDES
permit and the previous years annual report were available for review. The ORC visitation log
appeared to be complete and current. Calibration records appeared to be properly documented.
Laboratory data was reviewed and all data appeared to be correct as reported on the DMR's.
Construction is currently going on at this facility that inlcudes adding additional tertiary filters for
increased flow. Also the facility is in the process of bringing a newly installed belt press and
associated solids handling equipment on line. This facility appeared to be operated and maintained
satisfactorily. The effluent was very clear and appeared to be free of any visible solids.
Page#

Permit: NCO021636
Inspection Date: 02/27/2020
Owner - Facility: North Harnett Regional VVVVTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
0
❑
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
❑
(If the facility is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified
❑
❑
❑
operator on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility
❑
❑
❑
classification?
Page# 3

Permit: NCO021636 Owner - Facility:
Inspection Date: 02/27/2020 Inspection Type:
North Harnett Regional WWTP
Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
0
❑
❑
❑
Comment:
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Grit Removal
Yes
No
NA
NE
Type of grit removal
a.Manual
❑
b.Mechanical
Is the grit free of excessive organic matter?
0
❑
❑
❑
Is the grit free of excessive odor?
0
❑
❑
❑
# Is disposal of grit in compliance?
0
❑
❑
❑
Comment:
Oxidation Ditches
Yes
No
NA
NE
Are the aerators operational?
❑
❑
0
❑
Are the aerators free of excessive solids build up?
❑
❑
0
❑
# Is the foam the proper color for the treatment process?
0
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
0
❑
❑
❑
Are settleometer results acceptable (> 30 minutes)?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
0
❑
❑
❑
Are settelometer results acceptable?(400 to 800 ml/I in 30 minutes)
❑
❑
❑
Comment: This facility uses diffused air not surface aerators
Page# 4

Permit: NCO021636 Owner - Facility: North Harnett Regional WWTP
Inspection Date: 02/27/2020 Inspection Type: Compliance Evaluation
Oxidation Ditches Yes No NA NE
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
0
❑
❑
❑
Comment:
Filtration (High Rate Tertiary)
Yes
No
NA
NE
Type of operation:
Is the filter media present?
❑
❑
❑
Is the filter surface free of clogging?
❑
❑
❑
Is the filter free of growth?
❑
❑
❑
Is the air scour operational?
❑
❑
❑
Is the scouring acceptable?
❑
❑
❑
Is the clear well free of excessive solids and filter media?
❑
❑
❑
Comment:
Disinfection - UV
Yes
No
NA
NE
Are extra UV bulbs available on site?
0
❑
❑
❑
Are UV bulbs clean?
0
❑
❑
❑
Is UV intensity adequate?
0
❑
❑
❑
Is transmittance at or above designed level?
0
❑
❑
❑
Is there a backup system on site?
❑
❑
❑
Is effluent clear and free of solids?
0
❑
❑
❑
Comment:
Page# 5

Permit: NCO021636 Owner - Facility: North Harnett Regional WWTP
Inspection Date: 02/27/2020 Inspection Type: Compliance Evaluation
Disinfection - UV Yes No NA NE
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
0
❑
❑
❑
Are there adequate spare parts and supplies on site?
❑
❑
❑
■
Comment:
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
■
❑
❑
❑
Is the generator tested under load?
0
❑
❑
❑
Was generator tested & operational during the inspection?
❑
❑
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
0
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up
❑
❑
❑
power?
Is the generator fuel level monitored?
0
❑
❑
❑
Comment:
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
❑
❑
❑
Is sample collected above side streams?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
0
❑
❑
❑
degrees Celsius)?
Is sampling performed according to the permit?
0
❑
❑
❑
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
❑
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
Page# 6

Permit: NCO021636 Owner - Facility: North Harnett Regional WWTP
Inspection Date: 02/27/2020 Inspection Type: Compliance Evaluation
Effluent Sampling Yes
No
NA
NE
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 ■
❑
❑
❑
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type ■
❑
❑
❑
representative)?
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑
and sampling location)?
Comment: Sampling is performed by the Middle Cape Fear Basin Association.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment:
Page# 7

United States Environmental Protection Agency
Form Approved.
E PA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 IS I 3 I NCO021636 I11 121 21/07/22 I17 18I D I 19 L s j 201
21111111111111111111111111111111111111111111 f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
70 L�� J � 71 I tyI 72 L Ln, � 73 LLI74 79
J 1 1 1 1 L L j80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:30AM 21/07/22
17/11/01
North Harnett Regional WWTP
607 Edwards Dr
Exit Time/Date
Permit Expiration Date
Lillington NC 27546
12:30PM 21/07/22
21 /07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Kenneth Wayne Fail/ORC/910-893-2424/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Billy J Thomas,PO Box 1119 Lillington NC 275461119/Backup ORC/910-814-3042/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Stephanie Zorio DWR/FRO WQ/910-433-3322/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
31 NCO021636 I11 12I 21/07/22 117 18 I p
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

Permit: NCO021636
Inspection Date: 07/22/2021
Other
Comment:
Owner - Facility: North Harnett Regional VVVVTP
Inspection Type: Pretreatment Compliance
Yes No NA NE
Page#

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