BRUNSWICK COUNTY — The North Carolina Department of Environmental Quality (DEQ) has issued a sewer line moratorium at Brunswick County’s northern wastewater treatment plant.
The move follows a notice of violation issued by DEQ in December and effectively stunts new development in northern Brunswick County, the fastest-growing region in North Carolina.
Related: Compass Pointe asks for more sewer connections after exceeding its permit for years
No new sewer line extensions will be issued by the DEQ’s Division of Water Resources until the county comes back into compliance with state law. This requires submitting all permits required to expand the plant, which is currently nearing design completion.
DEQ dated its moratorium notice June 14. Brunswick County Manager Ann Hardy said her office received it on June 20. She first became aware of it when contacted by Port City Daily.
On Friday afternoon, Hardy issued the following statement, attributed to Brunswick County Utilities Director John Nichols:
“The NC Division of Water Resources has temporarily suspended the issuance of Sewer Line Extension Permits for sewer flows tributary to the Northeast Brunswick Regional Wastewater Treatment Plant.
This does not affect the issuance of building permits or approvals for sewer connections to parcels already part of an approved subdivision plan. Rather, it will affect the approval of new engineered subdivision plans tributary to the Northeast Brunswick Regional Wastewater Treatment Plant that require an extension of a sewer main.
Sewer Line Extension Permits may again be issued once all necessary permits for the wastewater treatment expansion are acquired.
Brunswick County and its consultants have been working diligently on the design of a 2.5 [million gallons per day] expansion of the Northeast Brunswick Regional Wastewater Treatment Plant and expect all permits to be available no later than the end of September 2019.
Moreover, Brunswick County has already taken steps with its wholesale customers to reduce flows tributary to the plant. Also, due to a more normalized rainfall pattern this year instead of the record rainfalls occurring during calendar year 2018, flows into the plant have dropped dramatically. An action plan is being compiled and will be submitted to the state regulators that outlines justifications for allowing the issuance of sewer extension permits immediately.”
Moratorium
Development in Brunswick County has pushed the Northeast Wastewater Treatment Plant to its limits. According to the North Carolina Department of Environmental Quality (DEQ), the Northeast Wastewater Treatment Plant operated at 92.3% of its treatment capacity in 2018.
Located off Royster Road in Navassa, Northwest Wastewater Treatment Plant is authorized to treat 2.475 million gallons a day (mgd). Navassa, Leland, Brunswick Regional Water and Sewer H2GO — which all maintain their own respective wastewater collection systems — send their flow to be treated at the plant. In 2018, the plant treated an average 2.29 mgd.
Brunswick County currently has plans to double capacity at the plant. The county expects the 2.5 mgd expansion to go online in just over two years, by August 2021.
To come into compliance with 15A NCAC 02T .0118, the moratorium stipulates that the county must: obtain all permits needed for the expansion, submit approvable final plans, specifications, and a construction schedule.
State law requires permittees to obtain all permits needed for expansion — including a construction schedule — before exceeding 90% of its permitted capacity.
Brunswick County’s expansion plans, though underway, are still not complete.
Hardy said the county can provide DEQ with a construction timeline right away. However, the county does not have all permits required to put the project out to bid — a process Hardy said will begin in October. She expects to have all permits in September.
Permitting requires cooperation and reliance on regulatory agencies, which review applications and send drafts prior to actual permits being issued. The most important permit missing, Hardy said, is the county’s National Pollutant Discharge Elimination System Permit, that she expects to have within a couple of weeks in draft form.
Operating near, and above capacity
The state-imposed moratorium comes months after Brunswick County received a violation notice for operating the plant at 110% of its permitted capacity in December 2018.
Part of that comes from H2GO, which maintains its own wastewater plant, located in Belville. While H2GO is permitted to treat 400,000 gallons-of-wastewater-a-day, a legal agreement between H2GO and Brunswick County — signed in 2001 — effectively locks H2GO out of expanding its Belville Wastewater Treatment Plant beyond its existing capacity limits. The agreement won’t expire until 2040.
“Anything we can’t treat at Chapel Loop Road, it gets pumped to the county,” Bob Walker, H2GO’s executive director, said in May.
An April, a Flow Tracking for Sewer Extension Application (FTSE) submitted in conjunction with a permit modification for Compass Pointe indicated flow at the plant was at 81%. Including obligated flow, the plant had reached 167.2% of its permitted capacity.
This doesn’t mean Northeast Wastewater Treatment Plant (NEWWTP) was actually operating at 167.2%. Obligated flow means permitted flow, not yet tributary — or connected — to the greater wastewater system.
“Theoretically it’s supposed to come up with less than what your capacity is,” Walker said. “That’s why the county is expanding their plant so they can correct this over-obligation.”
In May, Walker said obligated flows — of which had reached 2.012 mgd in April — represent already-permitted developments.
“Sometimes those developments will go quickly,” Walker said. But there are also plenty of permitted, not yet tributary (PNYT) connections that won’t connect any time soon. “We have permitted developments on our books that have been hanging around for years because everything kind of crashed in 2008, 2010,” he said.
After five years, those permits expire, and collection system permit holders are given the discretion to renew or purge, Walker said.
“Occasionally we will purge those active permits. Lots of times it’s just easier to keep those on the books,” he said. “It just makes it easier [so we] don’t have to go through the permitting process again.”
When asked specifically whether it was possible for any permitted, not yet tributary units to begin sending flow to either wastewater treatment plant without being required to submit further notification or approval from the collection system or treatment plant, Walker said yes: “Yes, any future connection that is part of an approved permit can connect to and use the system.”
Vulnerable to more flow
Operating at 167.2% capacity leaves the Northwest Wastewater Treatment Plant vulnerable to new flow, sent without notice or further approval (because permitted connections can, in theory, start operating at any time).
On June 5, Port City Daily asked Donald Dixon, Brunswick County’s deputy director of wastewater operations about this scenario. Port City Daily asked:
“If PNYT units can essentially begin using the system anytime, it seems continuing to submit additional FTSE applications is risky, or at the very least, puts NEWWTP in a vulnerable position these upcoming two years (specifically, during the winters). Do you agree? Why or why not?”
Dixon did not specifically respond. He did, however, provide requested flow data, showing the plant operated at 81% in March, 80% in April, and 74% in May. Citing time constraints, Dixon responded to other questions with the following statement:
“Although I do not have adequate time to address all the other questions you have posed due to time restrictions, I believe it is clear from the [average daily flow] over these past several months the impact [inflow and infiltration] has on overall system flows. As has been discussed in our prior correspondence, one of our biggest concerns is [inflow and infiltration]. It continues to be a subject of discussion at each of our regional participant meetings.”
Inflow and infiltration (I&I) is an indicator of leaks in a system, but is prevalent in all wastewater collection systems. According to Dr. Larry Cahoon, a University of North Carolina at Wilmington biology professor who has studied wastewater treatment systems, consistent I&I can be an indicator of a failing or poorly managed system.
I&I peaks in winter months and results in stormwater diluting a wastewater system.
“There’s a lot of I&I into some of the partner’s systems,” Walker said in May. When asked which partners, Walker declined to name names.
For years, the master-planned community, Compass Pointe, operated in violation of its master sewer permit. After Compass Pointe applied to expand its master sewer permit in March, DEQ issued H2GO with a violation notice. According to the violation, H2GO did not accurately keep track of the planned community’s connections. However, according to H2GO, the community had not exceeded its permitted flow.
By the time the development asked DEQ for permission for what it was already doing, it had 904 active connections (10 more connected by the time H2GO responded to the state); at that point Compass Pointe was operating at 205% of its connection limit.
What can go wrong, why it matters
Operating a wastewater treatment plant close to, at, or beyond its permitted capacity design limits puts the public at financial and environmental risk. When flow exceeds design parameters, several things can go wrong.
One, the wastewater plant can only treat so much sewage. When excess sewage enters that system, the plant runs the risk of dumping untreated sewage into public waterways, in violation of the Clean Water Act. In Northeast Wastewater Treatment Plant’s case, the plant operates under a National Pollutant Discharge Elimination System (NPDES) permit, discharging treated wastewater into the already-stressed Cape Fear River.
Sewer system overflows are another environmental consequence of pushing design capacity limits. Too much sewage flowing within wastewater infrastructure can stress lines, creating leaks or breaks. It can also cause manholes to bubble over with untreated sewage, creating a public health risk for humans and the environment at large.
In a remission response to the December 2018 violation, Nichols wrote to the state: “No harm was done to the natural resources of the state, to public health, or to private property and no adverse effects to ground or surface water quantity or quality occurred or on air quality … The violation was not committed willfully but due to record rainfall and was abated as soon as possible.”
Related coverage:
A Brunswick County sewer plant is pushing its permitted capacity. What does that mean?
DEQ issues violation notice after Brunswick sewer treatment plant goes over capacity
Send tips and comments to Johanna Ferebee at johanna@localvoicemedia.com
