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HomeMy WebLinkAboutNC0021121_Instream Assessment_19900712NPDBS DOCUMENT SCANNING COVER SHEET NPDES Permit: NC0021121 Mount Airy WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Speculative Limits Staff Report Instream Assessment (67B) Environmental Assessment (EA) Permit History Document Date: July 12, 1990 This documesat is printed oa reuse paper - ignore any content oa the reverae aide DIVISION OF ENVIRONMENTAL MANAGEMENT July 12, 1990 Memorandum To: Larry Coble From: Susan A—Wilsoni Through: Trevor Clements Carla Sanderson (� Subject: Instream Assessment City of Mt. Airy WWTP NPDES Permit No. NC0021121 Surry County SOC No. 89-67 Summary and Recommendations Technical Support has received the request for an instream assessment for the City of Mount Airy and has completed the review for the City's Wastewater Treatment Plant. Mount Airy wishes to increase their flow by one million gallons per day, not to exceed a flow of 5 MGD. The flow increase will consist primarily of industrial discharge from Cross Creek Mills (formerly Quality Mills). The City also requests that their BODS limit and their current toxicity limit be modified. A Level-B analysis was performed to assess the impact of the additional flow and relaxed BODS limits. The modeling analysis for this assessment indicates that the additional wasteflow under the proposed interim limits will not cause a violation of EMC 67 (b). Instream water quality standards should be met at both the pre- and post-SOC conditions. The facility must be able to meet the limits specified in their permit, for flow exceeding 4 MGD, at the end of the order. Since the additional wastewater will consist of pretreated industrial process waste, Technical Support suggests that the facility perform Scute toxicity testing on a monthly basis and show no acute toxicity at their updated instream waste concentration of 34% (based on an SOC flow of 5 MGD and updated 7Q10 flow of 14.9 cfs). While a toxicity limit is often waived by DEM during SOC periods, we feel that the City should be held to a minimum requirement of maintaining no acute toxicity since industrial wastewater additions are being permitted rather than DEM's typical exclusion of all but domestic strength wastewater. Technical Support also suggests that Mount Airy perform chronic quarterly monitoring at the IWC (or preferably over a full range of dilutions) during the life of the Order. This will allow the facility to track their progress toward achieving final limits prior to expiration of the SOC. It maybe wise to increase the frequency toward the end of the SOC if the target is not consistently being met. The Draft Environmental Assessment study prepared and submitted to DEM in March, 1990, indicated high levels of cadmium (average = 12 ug/l, maximum = 78 ug/1) and copper (average = 356 ug/l, maximum = 810 ug/1). In light of these results, Technical Support recommends weekly monitoring for cadmium and copper during the Order. In addition to monitoring these metals, we recommend that the City note the letter sent January 24, 1990, from the Winston-Salem Regional Office requesting monitoring for banned surfactants. The requirement for monitoring surfactants should be acknowledged or further detailed in the Order. Substantial recommendations regarding pretreatment comments are attached with this instream assessment. Technical Support recommends appropriate milestones be established for the attached comments in the Order. Backeround Information The City of Mount Airy discharges into the Ararat River, which is a class "C" stream in the Yadkin River Basin. The drainage area at the point of discharge is 75.2 square miles. The 1988 USGS flows used in the most recent wasteload allocation are as follows: 7Q10 = 14.9 cfs (summer), average stream flow = 90.0 cfs. Except for wasteflow, Mount Airy WWTP is currently in compliance with their pre -expansion permit limitations. However, whole effluent toxicity has been a problem for the facility in the past. The City is required to conduct the chronic toxicity test at an IWC of 32% for the pre -expansion flow of 4 MGD. Test results of "pass" have been reported by Mount Airy during each quarterly reporting month for the past year. Because Mount Airy wishes to add primarily industrial flow during their SOC to a plant which will be in the process of expansion, the Division stipulated that certain conditions be met before the City could apply for the Special Order. Specifically in regard to toxicity, the City had to show that their bench scale effluent could pass the chronic toxicity test at an instream waste concentration corresponding to the expansion flow of 5 MGD. Also, the bench scale effluent had to show no acute toxicity at the increased IWC for the interim treatment to be provided during the SOC period. The City's May report met these conditions. The May report by Mount Airy's consulting firm, Hazen and Sawyer, showed that the current BOD5 limit could not be met while the facility was under expansion. Although the facility could average 50 mg/l BOD5, the City requested 60 mg/l BOD5 during the life of the SOC. Analysis and Discussion The Level-B model was run with the region's requested effluent limit of 60 mg/l BOD5 and the pre-SOC flow of 3.921 MGD. To accomodate the ammonia evident in the last year's effluent monitoring data, the highest recorded monthly ammonia average, 8.91 mg/l NH3-N, was added to the model. An effluent DO restriction of 5.0 mg/l was also used in the analyisis. The BOD5 and NH3-N parapieters were input to the model as CBOD and NBOD using multipliers of 2.0 for BOD5 and 4.5 for NH3-N (see Table 1). When these effluent characteristics were input to the model with the pre-SOC flow, the predicted DO sag was 5.10 mg/1 at milepoint 0.26 (see Table 2) The model was then run with the same inputs for BOD5 and NH3-N using the post-SOC flow of 5.0 MGD, so that the 67 (b) criteria could be evaluated. The Level-B modeling analysis predicted that the requested flow and limits (5.0 MGD with 60.0 mg/1 BOD5, 5.0 mg/1 DO, and no NH3-N limit) will meet the EMC 67 (b) criteria for the allowable degradation during an SOC. Specifically, the DO sag drops to 5.00 mg/l, a decrease of 0.10 mg/l, which is within the criteria. cc: Steve Tedder Kent Wiggins Doug Finan Ken Eagleson TABLE 1. INSTREAM ASSESSMENT MODEL INPUT SUMMARY FOR MOUNT AIRY Wasteflow Assumptions Design Capacity 4.000 MGD Pre-SOC 3.921 MGD Additional SOC Flow Requested 1.000 MGD Maximum Allowable SOC Flow 5.000 MGD Model Input Summary Headwater Conditions (summer) : 7Q10 (cfs) 14.9 Qavg (cfs) 90.0 Design Temperature (°C) 25.0 CBOD (mg/1) 2.0 NBOD (mg/1) 1.0 DO (mg/1) 5.55 Waste Inputs: Flows Pre-SOC Flow (year avg) 3.9210 MGD Post-SOC Flow 5.0000 MGD CBOD (2.0 * 60 mg/l BOD5) 120.0 mg/l NBOD (4.5 * 8.91 mg/l N113-N) 40.0 mg/l TABLE 2. INSTREAM ASSESSMENT MODEL OUTPUT SUMMARY FOR MOUNT AIRY SOC Evaluation Summer Model Results Limits: Pre-SOC SOC Wasteflow = 3.921 MGD Wasteflow = 5.000 MGD BOD5 = 60 mg/l = 60 mg/l NH3-N = no limit = no limit DO = 5.0 mg/1 = 5.0 mg/1 DO Minumum Net Change (mid) (mg/1) ------------------ ------------------ Pre-SOC 5.10 na Post-SOC 5.00 0.10 8/89 I Facility Name ( /� ,t Q Ot kl, A�Yq, I U uJTP Permit # IUC400 �a ACUTE TOXICITY TESTING REQUIREMENT (MONTHLY) Fathead Minnow 24hr - No Significant Mortality The pemtittee shall conduct acute toxicity tests on a monthly basis using protocols defined in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration'. The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test, using effluent collected as a 24 hour composite. The effluent concentration at which there may be at no time significant acute mortality in any two consecutive toxicity tests is 34% (defined as treatment two in the North Carolina procedure document). Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment. The fast test will be performed within thirty days from issuance of this permit. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE6C. Additionally, DEM Form AT-2 (original) is to be sent to the following address: Attention: Environmental Sciences Branch North Carolina Division of Environmental Management P.O. Box 27687 Raleigh, N.C. 27611 Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of.the waste stream. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute noncompliance with monitoring requirements. 7Q10 /J�. � cfs Permitted Flow S MGD Recommended by: IWC% .34 Basin & Sub -Basin ( 0 0 Receiving,Streamyo-m-t FiVgr Pho County JUYYU. Date 13 0 "Acute Toxicity(Fathead Minnow 24 hr) No Significant Mortality at 34%, See Part _, Condition . DIVISION OF ENVIRONMENTAL MANAGEMENT July 11, 1990 MEMORANDUM To: Trevor Clements From: Doug Finan5� A Subject: Pretreatment Language for the Mt. Airy SOC Asper -your request, the pretreatment staff has reviewed the Town of Mt. Airy current status regarding their pretreatment program and below is the pretreatment language recommended for possible inclusion in Mt. Airy's SOC:. :. 1. Submita planY:for.a long-term monitoring program for the collection of site specific data needed to complete a headworks analysis -(note: guidance on this was provided in the 1990 pretreatment coordinator's workshop notebook). 2,. Revise the monitoring program (based on DEM comments received within 90.days of monitoring program submission). 3. upon completion of the upgrade, implement the long-term monitoring programasrevised based on DEM comments. 4. Develop and submit to DEM for approval an enforcement management strategy (EMS). ' 5. Revise the EMS (based on DEM comments received within 45 days of EMS submission). .6. Implement the EMS as revised based on DEM comments. 7. Modify the City's SUO as necessary to allow for implementation of the EMS. 8. Require the City to establish plan for developing an inventory of industrial chemicals which could reasonably be expected to be discharged to the wastewater treatment plant. This plan must include procedures for: obtaining an initial inventory; determining the treatability of those chemicals identified in the inventory; requiring the industries to continually tracking chemical use; and, requiring industries to provide prior notification to the City when new chemicals are being added to the inventory. I have included a few additional comments in red on the draft SOC: If you have any questions on this matter or require any further information, please let me know. st Form for In -stream Assessment for 67B NAME OF FACILITY �_���/�� /j/� _ 1'/D___ SUBBASZN�n D D%03 - COUNTY SjaYZ- / REGION�Z .jam ILA DESIGN FLOW RECEIVING STREAM BACKGROUND DATA .: A. Why is SOC needed? (Facility is out of complianc with which effluent limits?) P �sli/ri%�is SuSic�iii/,QP/0�1S�ii�S�P�S� f0 Fi�f'an f/o �D/Y6v. �P Prfs��� tt�rAl/iOr7 syslr'� t.",..{{Y/ S� �o��rov� slrvrYP /:r '9/- 9� .P�rivc4Yghorr� �iP �oc�/'/y �4 ro.��v/�/n.rtrs< i lusr�r< 3tJ,�� B. History of SOC requests- �'5' !!� ryr(r�'7i+re- 02 D.O.uM.,seFSAT >c�Myp ;I/O% 1. Monthly Average waste flow prior to any SOC /n O mgd Time period averaged X Y/ thru� 2. Previously approved SOC's�7���� Date: flow: mgd Date: flow:- mgd total of previously approved SOC flow: — mgd 3. Flows lost from plant (facilities that have gone off line) 4. Current SOC request 5. Total plant flow post-SOC (sum of original flow and SOC flow minus losses) flow: —' mgd x flow: �Dmgd ii�li^PosYs ��y o��vr flow:0 mgd '�Sanr t!5 Gl�� 6. Is this an accurate flow balance for plant? Why/why not? Y5', rrP arP Ile? r4 �14Wl- 4Yo.J, a l� I'lle e�' C. Please attach DMR summary for past year for all permitted parame- ters. If possible, include reports from previous years if facility has been under SOC for morethana year. lope CURRENT SOC_REQUEST : A. Request is for domestic or industrial waste? If it is a combin- ation, please specify percentages. B. What type of industry? Please attach any pertinent data. ;'� S1.7rr/nfr �O/le�i iiYJi1S LJl/ � Avr'- Or I. 71"YKlMe C. The region proposes the following SOC limits: J BOD5 �p0. (� mg/1 NH3 mg/l DO_ O mg/1 TSSO _mg/l fecal coliform 0 #/100m1 pH ��7 SU other parameters_ D. What is the basis for these Jimits? / ao7' *-7 .lam M'e071— w���� ADS 4rafiorrLri�n�,e-f 7-o II Agg Alkpp )Plv6e yAwltl 03o703 I I i(hn tali 4 Gn hl, L. A ; gA✓o = �iSck .Th/c = 3 2- 3�, II i�i5 = 30 I I D.A. ' 65.71%; Z it II Itcows Fog 7L,4l> E76P,4a*o/\l (160) YAda ' qo C4 J.wc I I I 7Q(04 ` l9 9 c6 I I -I IrACICITY U/kIJTS TNPU57P14t- (C4055 62K• I� 16scu aj7O,P Tu�Y -I I y -WE DArs-t Vr,194 -d* CvA b /1,1To Cv1Q) ukkk6 WlW 72X/c/rY l%5 NAD IWAIJ/ Nei�or(ATN Ah; 4Ji 2 CEAMQAL WG C (siOi�(N I , I(oNDI i/o�/5 r M� 6eFo2� s0r— ) Mss 6-�amc ;EST 47- lG cop4ec5Po/✓P/�J4 T 5oc izow of KZJ eJ 3¢� us/NS 79105 = l¢. 9) -MEcY PIP 7ESr FIT 3&7 z> l�/Ns 4' NiM aLl/iE -j'rsr Ar -TJC II3� ST2L(ci C,45CAA� A�2%�ii ^I 6 50C_ NA✓_� I i T lks6r D.O. Ar FLD uD %o Nkdc %/- II w � A r;2AiI0lJ gA-sl,U is Sflw� �r��l - I tj o /k4X 90DS U,ul r aO,LI d59,& alT/ /PAK= 75Ze- I - I gt4n /koNlr DRrk O•k. - I CeKTu�NGdVAM IIV21C,47cvWhs l3E'U 0-5, T4elytS II Nw"(? Io 46r-rwc-l2 Q/e6�tirb,/7 I/l GlNE 4VP II wIG, &3 p /c Sorl wrc- Ale;,— (,,=r 7f4g�„ � I nr pi 2l I liczi-) M i Ai P? /7) nnnnr--i > ha- "igt,; ! / ll?aO PMS AM,-Yl PltOT Mrnl I ---------- MODEL RESULTS Discharger : CITY OF MOUNT AIRY Receiving Stream : ARARAT RIVER --------------------------------------------- The End D.O. is 6.67 mg/l. The End CBOD is 8.57 mg/l. The End NBOD is 2.58 mg/l. --------------------------------------------- Segment 1 Reach 1 Reach 2 Reach 3 Reach 4 Reach 5 Reach 6 Reach 7 Reach 8 Segment 2 Reach 1 Segment 3 Reach 1 DO Min (mg/1) Milepoint Reach # 5.10 0.26 1 5.34 0.00 6.46 0.00 SUMMER fORflEsr Man �`1 BOD5=60, NH3-N=8.91 h/G. ivKFASTVC. FLOW=3.921 MGD WLA CBOD (mg/1) 120.00 0.00 0.00 0.00 45.00 0.00 0.00 0.00 WLA NBOD (mg/1) 40.00 0.00 0.00 0.00 90.00 0.00 0.00 0.00 1 60.00 13.50 1 0.00 0.00 WLA DO Waste Flow (mg/1) (mgd) 5.00 3.92100 0.00 0.00000 0.00 0.00000 0.00 0.00000 0.00 0.01800 0.00 0.00000 0.00 0.00000 0.00 0.00000 0.00 1.50000 0.00 0.00000 *** MODEL SUMMARY DATA *** Discharger Receiving Stream Summer 7Q10 Design Temperature CITY OF MOUNT AIRY ARARAT RIVER 14.9 25.0 Subbasin : 030703 Stream Class: C Winter 7Q10 : 31.0 ILENGTHI SLOPEI VELOCITY I DEPTHI Kd I Kd I Ka I Ka I KN I -------------------------------------------------------------------------------- I mile I ft/mil fps I ft Idesignl @201,� Idesignl @203,� Idesignl Segment 1 I I 1 0.261 I 8.201 0.463 I 1 1.74 I I 1 0.32 1 0.25 I I 1 4.27 1 I 3.831 I 0.44 1 Reach -------------------------------------------------------------------------------- 1 1 1 1 1 1 1 1 1 1 1 Segment 1 I I 1 0.721 I 8.201 0.527 I 1 1.95 I I 1 0.32 1 0.26 I I 1 3.85 1 I 3.451 I 0.44 1 Reach -------------------------------------------------------------------------------- 2 1 1 1 1 1 1 1 1 1 1 Segment 1 I I 1 1.201 I 8.201 0.675 I 1 2.30 I I 1 0.33 1 0.26 I I 1 3.38 1 I 3.031 I 0.44 1 Reach -------------------------------------------------------------------------------- 3 1 1 1 1 1 1 1 1 1 1 Segment 1 I I 1 2.201 I 8.201 0.679 I 1 2.33 I I 1 0.33 1 0.26 I I 1 3.33 1 I 2.981 I 0.44 1 Reach -------------------------------------------------------------------------------- 4 1 1 1 1 1 1 1 1 1 1 Segment 1 I I 1 1.651 I 8.201 0.688 I 1 2.34 I I 1 0.33 1 0.26 I I 1 3.33 1 I 2.991 I 0.44 1 Reach -------------------------------------------------------------------------------- 5 1 1 1 1 1 1 1 1 1 1 Segment 1 I I 1 2.101 I 10.501 0.744 I 1 2.28 I I 1 0.35 1 0.28 I I 1 3.61 1 I 3.241 I 0.44 1 Reach -------------------------------------------------------------------------------- 6 1 1 1 1 1 1 1 1 1 1 Segment 1 I I 1 2.001 I 10.501 0.759 I 1 2.31 I I 1 0.35 1 0.28 I I 1 3.57 1 I 3.201 I 0.44 1 Reach -------------------------------------------------------------------------------- 7 1 1 1 1 1 1 1 1 1 1 Segment 1 I I 1 2.501 I 6.501 0.686 I 1 2.51 I I 1 0.31 1 0.25 I . I 1 4.37 1 I 3.921 I 0.44 1 Reach -------------------------------------------------------------------------------- 8 1 1 1 1 1 1 1 1 1 1 Segment 2 I I 1 3.601 I 11.831 0.343 I 1 1.30 I I 1 0.34 1 0.27 I I 1 8.15 1 I 7.311 I 0.44 1 Reach -------------------------------------------------------------------------------- 1 1 1 1 1 1 1 1 1 1 1 Segment 3 I I 1 2.301 I 6.501 0.740 I 1 2.65 I I 1 0.31 1 0.25 I I 1 4.72 1 I 4.231 I 0.44 1 Reach -------------------------------------------------------------------------------- 1 1 1 1 1 1 1 1 1 1 1 I Flow I CBOD I NBOD I D.O. I I cfs I mg/l I mg/l I mg/l I Segment 1 Reach 1 Waste 1 6.078 1120.000 1 40.000 1 5.000 Headwatersl 14.900 1 2.000 1 1.000 1 5.550 Tributary 1 0.000 1 2.000 1 1.000 1 7.440 * Runoff 1 0.080 I 2.000 1 1.000 1 7.440 Segment 1 Reach 2 Waste I 0.000 I 0.000 1 0.000 1 0.000 Tributary 1 8.900 I 2.000 I 1.000 1 7.440 * Runoff 1. 0.080 I 2.000 I 1.000 I 7.440 Segment 1 Reach 3 Waste I 0.000 1 0.000 1 0.000 1 0.000 Tributary 1 23.600 1 2.000 1 1.000 1 7.440 * Runoff 1 0.380 1 2.000 1 1.000 1 7.440 Segment 1 Reach 4 Waste I 0.000 I 0.000 1 0.000 1 0.000 Tributary 1 0.800 1 2.000 1 1.000 1 7.440 * Runoff I 0.580 I 2.000 I 1.000 I 7.440 Segment 1 Reach 5 Waste 1 0.028 145.000 190.000 1 0.000 Tributary 1 0.000 I 2.000 1 1.000 1 7.440 * Runoff 1 0.580 I 2.000 1 1.000 1 7.440 Segment 1 Reach 6 Waste 1 0.000 1 0.000 1 0.000 1 0.000 Tributary 1 0.380 1 2.000 1 1.000 1 7.440 * Runoff 1 0.380 I 2.000 I 1.000 1 7.440 Segment 1 Reach 7 Waste I 0.000 1 0.000 I 0.000 I 0.000 Tributary I 0.770 I 2.000 1 1.000 1 7.440 * Runoff I 1.700 I 2.000 1 1.000 1 7.440 Segment 1 Reach 8 Waste 1 0.000 I 0.000 I 0.000 1 0.000 Tributary 1 0.000 1 2.000 1 1.000 1 0.000 * Runoff 1 1.700 1 2.000 1 1.000 1 7.440 Segment 2 Reach 1 Waste 1 2.325 160.000 113.500 1 0.000 Headwatersl 5.930 I 2.000 I 1.000 1 7.440 Tributary I 0.000 I 2.000 I 1.000 1 0.000 * Runoff I 0.260 1 2.000 1 1.000 1 7.440 Segment 3 Reach 1 Waste 1 0.000 1 0.000 1 0.000 1 0.000 Headwatersl 0.000 1 2.000 1 1.000 1 0.000 Tributary 1 0.000 1 2.000 1 1.000 1 0.000 * Runoff 1 1.700 1 2.000 1 1.000 1 7.440 SUMMER BOD5=60, NH3-N=8.91 FLOW=3.921 MGD Seg # I Reach # I Seg Mi I D.O. I CBOD I NBOD I Flow I 1 1 0.00 5.39 36.19 12.30 20.98 1 1 0.02 5.37 36.15 12.28 20.98 1 1 0.04 5.34 36.12 12.27 20.98 1 1 0.06 5.32 36.09 12.25 20.98 1 1 0.08 5.29 36.05 12.24 20.98 1 1 0.10 5.27 36.02 12.22 20.99 1 1 0.12 5.25 35.99 12.21 20.99 1 1 0.14 5.23 35.96 12.19 20.99 1 1 0.16 5.20 35.92 12.18 20.99 1 1 0.18 5.18 35.89 12.16 20.99 1 1 0.20 5.16 35.86 12.15 20.99 1 1 0.22 5.14 35.82 12.13 21.00 ' 1 1 0.24 5.12 35.79 12.12 21.00 1 1 0.26 5.10 35.76 12.10 21.00 1 2 0.26 5.79 25.71 8.80 29.90 1 2 0.30 5.76 25.67 8.78 29.90 1 2 0.34 5.73 25.63 8.76 29.90 1 2 0.38 5.70 25.59 8.74 29.91 1 2 0.42 5.67 25.55 8.72 29.91 1 2 0.46 5.65 25.51 8.70 29.91 1 2 0.50 5.62 25.47 8.69 29.92 1 2 0.54 5.59 25.43 8.67 29.92 1 2 0.58 5.56 25.38 8.65 29.92 1 2 0.62 5.54 25.34 8.63 29.93 1 2 0.66 5.51 25.30 8.61 29.93 1 2 0.70 5.49 25.26 8.59 29.93 1 2 0.74 5.46 25.22 8.58 29.94 1 2 0.78 5.44 25.18 8.56 29.94 1 2 0.82 5.41 25.14 8.54 29.94 1 2 0.86 5.39 25.10 8.52 29.95 1 2 0.90 5.37 25.06 8.50 29.95 1 2 0.94 5.35 25.02 8.48 29.95 1 2 0.98 5.33 24.99 8.47 29.96 1 3 0.98 6.26 14.86 5.18 53.56 1 3 1.18 6.19 14.75 5.13 53.63 1 3 1.38 6.13 14.65 5.08 53.71 1 3 1.58 6..07 14.54 5.04 53.78 1 3 1.78 6.02 14.44 4.99 53.86 1 3 1.98 5.97 14.34 4.95 53.94 1 3 2.18 5.93 14.23 4.90 54.01 1 4 2.18 5.95 14.06 4.84 54.81 1 4 2.38 5.91 13.95 4.80 54.93 1 4 2.58 5.88 13.84 4.75 55.04 1 4 2.78 5.84 13.74 4.71 55.16 1 4 2.98 5.81 13.63 4.66 55.28 1 4 3.18 5.78 13.53 4.62 55.39 1 4 3.38 5.76 13.42 4.57 55.51 1 4 3.58 5.73 13.32 4.53 55.62 1 4 3.78 5.71 13.22 4.49 55.74 1 4 3.98 5.69 13.12 4.44 55.86 1 4 4.18 5.68 13.02 4.40 55.97 1 4 4.38 5.66 12.92 4.36 56.09 1 5 4.38 5.66 12.94 4.40 56.12 1 5 4.43 5.66 12.91 4.39 56.14 1 5 4.48 5.65 12.89 4.38 56.17 1 5 4.53 5.65 12.86 4.37 56.20 . 5 5 5 5 5 5 5 5 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 7 7 7 7 7 7 4.58, 5.65 12.84 4.36 56.23 4.63 5.65 12.82 4.35 56.26 4.68 5.64 12.79 4.34 56.29 4.73 5.64 12.77 4.33 56.32 4.78 5.64 12.74 4.32 56.35 4.83 5.63 12.72 4.31 56.38 4.88 5.63 12.70 4.30 56.41 4.93 5.63 12.67 4.29 56.43 4.98 5.63 12.65 4.28 56.46 5.03 5.63 12.62 4.27 56.49 5.08 5.62 12.60 4.26 56.52 5.13 5.62 12.58 4.25 56.55 5.18 5.62 12.55 4.24 56.58 5.23 5.62 12.53 4.23 56.61 5.28 5.62 12.51 4.22 56.64 5.33 5.61 12.48 4.21 56.67 5.38 5.61 12.46 4.20 56.70 5.43 5.61 12.44 4.19 56.72 5.48 5.61 12.41 4.18 56.75 5.53 5.61 12.39 4.17 56.78 5.58 5.61 12.37 4.16 56.81 5.63 5.61 12.34 4.15 56.84 5.68 5.60 12.32 4.14 56.87 5.73 5.60 12.30 4.13 56.90 5.78 5.60 12.27 4.12 56.93 5.83 5.60 12.25 4.11 56.96 5.88 5.60 12.23 4.10 56.99 5.93 5.60 12.20 4.09 57.01 5.98 5.60 12.18 4.08 57.04 6.03 5.60 12.16 4.07 57.07 6.03 5.61 12.09 4.05 57.45 6.13 5.61 12.05 4.04 57.49 6.23 5.61 12.01 4.02 57.53 6.33 5.62 11.97 4.00 57.57 6.43 5.62 11.93 3.99 57.60 6.53 5.62 11.89 3.97 57.64 6.63 5.62 11.85 3.95 57.68 6.73 5.62 11.81 3.94 57.72 6.83 5.63 11.77 3.92 57.76 6.93 5.63 11.73 3.91 57.79 7.03 5.63 11.69 3.89 57.83 7.13 5.63 11.65 3.87 57.87 7.23 5.64 11.61 3.86 57.91 7.33 5.64 11.57 3.84 57.95 7.43 5.64 11.53 3.83 57.98 7.53 5.64 11.49 3.81 58.02 7.63 5.65 11.45 3.80 58.06 7.73 5.65 11.41 3.78 58.10 7.83 5.65 11.37 3.76 58.14 7.93 5.66 11.33 3.75 58.17 8.03 5.66 11.29 3.73 58.21 8.13 5.66 11.26 3.72 58.25 8.13 5.69 11.14 3.68 59.02 8.23 5.69 11.08 3.66 59.19 8.33 5.70 11.02 3.64 59.36 8.43 5.71 10.96 3.62 59.53 8.53 5.71 10.91 3.60 59.70 8.63 5.72 10.85 3.58 59.87 8.73 5.72 10.80 3.56 60.04 8.83 5.73 10.74 3.54 60.21 1 7 8.93 5.74 10.69 3.52 60.38 1 7 9.03 5.74 10.63 3.50 60.55 1 7 9.13 5.75 10.58 3.48 60.72 1 7 9.23 5.76 10.53 3.46 60.89 1 7 9.33 5.76 10.47 3.44 61.06 1 7 9.43 5.77 10.42 3.43 61.23 1 7 9.53 5.78 10.37 3.41 61.40 1 7 9.63 5.78 10.31 3.39 61.57 1 7 9.73 5.79 10.26 3.37 61.74 1 7 9.83 5.80 10.21 3.35 61.91 1 7 9.93 5.80 10.16 3.33 62.08 1 7 10.03 5.81 10.11 3.31 62.25 1 7 10.13 5.82 10.06 3.30 62.42 1 8 10.13 5.82 10.06 3.30 62.42 1 8 10.38 5.89 9.94 3.25 62.85 1 8 10.63 5.95 9.81 3.20 63.27 1 8 10.88 6.01 9.69 3.16 63.70 1 8 11.13 6.07 9.58 3.11 64.12 1 8 11.38 6.12 9.46 3.07 64.55 1 8 11.63 6.17 9.35 3.02 64.97 1 8 11.88 6.21 9.23 2.98 65.40 1 8 12.13 6.25 9.12 2.94 65.82 1 8 12.38 6.29 9.01 2.90 66.25 1 8 12.63 6.32 8.91 2.86 66.67 2 1 0.00 5.34 18.34 4.52 8.25 2 1 0.30 6.04 17.86 4.38 8.33 2 1 0.60 6.49 17.40 4.25 8.41 2 1 0.90 6.80 16.95 4.12 8.49 2 1 1.20 7.00 16.52 4.00 8.57 2 1 1.50 7.13 16.09 3.88 8.64 2 1 1.80 7.23 15.68 3.76 8.72 2 1 2.10 7.30 15.29 3.65 8.80 2 1 2.40 7.35 14.90 3.54 8.88 2 1 2.70 7.39 14.52 3.44 8.96 2 1 3.00 7.43 14.16 3.34 9.03 2 1 3.30 7.46 13.81 3.24 9.11 2 1 3.60 7.48 13.46 3.15 9.19 3 1 0.00 6.46 9.46 2.89 75.86 3 1 0.23 6.49 9.36 2.86 76.25 3 1 0.46 6.52 9.27 2.83 76.64 3 1 0.69 6.54 9.18 2.79 77.03 3 1 0.92 6.56 9.09 2.76 77.43 3 1 1.15 6.58 9.00 2.73 77.82 3 1 1.38 6.60 8.91 2.70 78.21 3 1 1.61 6.62 8.82 2.67 78.60 3 1 1.84 6.64 8.74 2.64 78.99 3 1 2.07 6.65 8.65 2.61 79.38 3 1 2.30 6.67 8.57 2.58 79.77 I Seg # I Reach # I Seg Mi I D.O. I CBOD I NBOD I Flow MODEL RESULTS Discharger : CITY OF MOUNT AIRY Receiving Stream : ARARAT RIVER --------------------------------------------- The End D.O. is 6.53 mg/l. The End CBOD is 10.06 mg/l. The End NBOD is 3.02 mg/l. --------------------------------------------- Segment 1 Reach 1 Reach 2 Reach 3 Reach 4 Reach 5 Reach 6 Reach 7 Reach 8 Segment 2 Reach 1 Segment 3 Reach 1 DO Min (mg/1) Milepoint Reach # ---------------------- 5.00 0.26 1 5.34 0.00 6.28 0.00 SUMMER BOD5=60, NH3-N 8. 91J "'41Esr MONI L4 FLOW=5 . 0 MGD AW' FOR �/Kt 'f�• WLA CBOD (mg/1) 120.00 0.00 0.00 0.00 45.00 0.00 0.00 0.00 WLA NBOD (mg/1) 40.00 0.00 0.00 0.00 90.00 0.00 0.00 0.00 1 60.00 13.50 1 0.00 0.00 WLA DO Waste Flow (mg/1) (mgd) 5.00 5.00000 0.00 0.00000 0.00 0.00000 0.00 0.00000 0.00 0.01800 0.00 0.00000 0.00 0.00000 0.00 0.00000 0.00 1.50000 0.00 0.00000 *** MODEL SUMMARY DATA *** Discharger : CITY OF MOUNT AIRY Receiving Stream : ARARAT RIVER Summer 7Q10 : 14.9 Design Temperature: 25.0 Subbasin : 030703 Stream Class: C Winter 7Q10 : 31.0 ILENGTHI SLOPEI VELOCITY I DEPTHI Kd I Kd I Ka I Ka I KN I -------------------------------------------------------------------------------- I mile I ft/mil fps I ft Idesignl @2014 Idesignl @201h Idesignl Segment 1 I I 1 0.26I I 8.20I 0.491 I 1 1.75 I I 1 0.32 1 0.26 I I 1 4.33 1 I 3.891 I 0.44 1 Reach -------------------------------------------------------------------------------- 1 1 1 I I I I I I I 1 Segment 1 I I 1 0.72I I 8.201 0.549 I 1 1.96 I I 10.32 1 0.26 I I 1 3.89 I I 3.481 I 0.44 1 Reach -------------------------------------------------------------------------------- 2 I 1 I 1 1 I I I 1 1 Segment 1 I I I 1.201 I 8.201 0.691 I 1 2.31 I I 10.33 10.26 I I 13.40 I I 3.051 I 0.44 1 Reach -------------------------------------------------------------------------------- 3 I I I 1 I I I I I 1 Segment 1 I I 1 2.20I I 8.201 0.695 I 1 2.34 I I 1 0.33 1 0.26 I I 1 3.35 1 I 3.001 I 0.44 1 Reach -------------------------------------------------------------------------------- 4 I I I I I I I I 1 1 Segment 1 I I 1 1.651 I 8.201 0.704 I 1 2.35 I I 10.33 10.26 I I 13.35 I I 3.00I I 0.44 1 Reach -------------------------------------------------------------------------------- 5 I I I 1 I 1 I I I I Segment 1 I I I 2.101 I 10.501 0.761 I 1 2.28 I I 10.35 1 0.28 I I 1 3.63 I I 3.261 I 0.44 1 Reach -------------------------------------------------------------------------------- 6 I I I I I I I I I 1 Segment 1 I I 1 2.001 I 10.501 0.775 I 12.32 I I 1 0.35 10.28 I I 1 3.59 I I 3.221 I 0.44 1 Reach -------------------------------------------------------------------------------- 7 I 1 1 1 1 1 1 1 1 1 Segment 1 I I I 2.501 I 6.501 0.699 I 1 2.51 I I 1 0.31 10.25 I I 1 4.46 1 I 4.001 I 0.44 1 Reach -------------------------------------------------------------------------------- 8 I I I I I I I I I 1 Segment 2 I I 1 3.601 I 11.831 0.343 I 1 1.30 I I 10.34 1 0.27 I I 1 8.15 1 I 7.311 I 0.44 1 Reach -------------------------------------------------------------------------------- 1 1 I 1 1 1 1 1 1 1 1 Segment 3 I I 1 2.301 I 6.501 0.752 I 1 2.66 I I 10.31 1 0.25 I I 14.79 1 I 4.301 I 0.44 1 Reach -------------------------------------------------------------------------------- 1 1 I I I 1 1 I I I 1 I Flow I CBOD I NBOD I D.O. I I 'cfs I mg/l I mg/l I mg/1 I Segment 1 Reach 1 Waste 1 7.750 1120.000 1 40.000 1 5.000 Headwatersl 14.900 1 2.000 1 1.000 1 5.550 Tributary I 0.000 I 2.000 I 1.000 I 7.440 * Runoff I 0.080 I 2.000 I 1.000 I 7.440 Segment 1 Reach 2 Waste 1 0.000 1 0.000 1 0.000 1 0.000 Tributary I 8.900 I 2.000 1 1.000 I 7.440 * Runoff 1 0.080 I 2.000 I 1.000 I 7.440 Segment 1 Reach 3 Waste I 0.000 I 0.000 I 0.000 I 0.000 Tributary 1 23.600 I 2.000 I 1.000 I 7.440 * Runoff 1 0.380 I 2.000 I 1.000 1 7.440 Segment 1 Reach 4 Waste I 0.000 I 0.000 1 0.000 1 0.000 Tributary I 0.800 I 2.000 1 1.000 1 7.440 * Runoff I 0.580 1 2.000 1 1.000 1 7.440 Segment 1 Reach 5 Waste I 0.028 145.000 1 90.000 I 0.000 Tributary I 0.000 1 2.000 1 1.000 I 7.440 * Runoff I 0.580 1 2.000 1 1.000 1 7.440 Segment 1 Reach 6 Waste I 0.000 I 0.000 I 0.000 I 0.000 Tributary I 0.380 I 2.000 I 1.000 1 7.440 * Runoff I 0.380 I 2.000 I 1.000 1 7.440 Segment 1 Reach 7 Waste I 0.000 I 0.000 1 0.000 1 0.000 Tributary I 0.770 I 2.000 I 1.000 1 7.440 * Runoff I 1.700 I 2.000 I 1.000 I 7.440 Segment 1 Reach 8 Waste I 0.000 I 0.000 I 0.000 I 0.000 Tributary 1 0.000 I 2.000 I 1.000 1 0.000 * Runoff I 1.700 I 2.000 I 1.000 I 7.440 Segment 2 Reach 1 Waste 1 2.325 1 60.000 1 13.500 1 0.000 Headwatersl 5.930 1 2.000 1 1.000 1 7.440 Tributary I 0.000 1 2.000 1 1.000 1 0.000 * Runoff I 0.260 1 2.000 1 1.000 1 7.440 Segment 3 Reach 1 Waste 1 0.000 1 0.000 1 0.000 1 0.000 Headwatersl 0.000 1 2.000 1 1.000 1 0.000 Tributary l 0.000 I 2.000 I 1.000 1 0.000 * Runoff 1 1.700 I 2.000 I 1.000 1 7.440 SUMMER BOD5=60, NH3-N=8.91 FLOW=5.0 MGD I Seg # I Reach # I Seg Mi I D.O. I CBOD I NBOD I Flow I 1 1 0.00 5.36 42.38 14.34 22.65 1 1 0.02 5.33 42.34 14.33 22.65 1 1 0.04 5.30 42.30 14.31 22.65 1 1 0.06 5.27 42.26 14.29 22.65 1 1 0.08 5.25 42.23 14.28 22.66 1 1 0.10 5.22 42.19 14.26 22.66 1 1 0.12 5.19 42.15 14.24 22.66 1 1 0.14 5.16 42.12 14.23 22.66 1 1 0.16 5.13 42.08 14.21 22.66 1 1 0.18 5.11 42.04 14.19 22.66 1 1 0.20 5.08 42.01 14.18 22.67 1 1 0.22 5.05 41.97 14.16 22.67 1 1 0.24 5.03 41.93 14.15 22.67 1 1 0.26 5.00 41.90 14.13 22.67 1 2 0.26 5.69 30.65 10.43 31.57 1 2 0.30 5.65 30.60 10.41 31.57 1 2 0.34 5.61 30.56 10.39 31.58 1 2 0.38 5.58 30.51 10.36 31.58 1 2 0.42 5.54 30.46 10.34 31.58 1 2 0.46 5.51 30.42 10.32 31.59 1 2 0.50 5.47 30.37 10.30 31.59 1 2 0..54 5.44 30.32 10.28 31.59 1 2 0.58 5.41 30.28 10.26 31.60 1 2 0.62 5.37 30.23 10.24 31.60 1 2 0.66 5.34 30.18 10.22 31.60 1 2 0.70 5.31 30.14 10.19 31.61 1 2 0.74 5.28 30.09 10.17 31.61 1 2 0.78 5.25 30.04 10.15 31.61 1 2 0.82 5.22 30.00 10.13 31.62 1 2 0.86 5.19 29.95 10.11 31.62 1 2 0.90 5.17 29.91 10.09 31.62 1 2 0.94 5.14 29.86 10.07 31.63 1 2 0.98 5.11 29.81 10.05 31.63 1 3 0.98 6.11 17.93 6.18 55.23 1 3 1.18 6.03 17.80 6.13 55.30 1 3 1.38 5.95 17.68 6.07 55.38 1 3 1.58 5.89 17.56 6.02 55.46 1 3 1.78 5.82 17.43 5.97 55.53 1 3 1.98 5.76 17.31 5.91 55.61 1 3 2.18 5.71 17.19 5.86 55.68 1 4 2.18 5.73 16.97 5.79 56.48 1 4 2.38 5.68 16.85 5.74 56.60 1 4 2.58 5.64 16.72 5.68 56.72 1 4 2.78 5.60 16.59 5.63 56.83 1 4 2.98 5.56 16.47 5.58 56.95 1 4 3.18 5.53 16.34 5.52 57.06 1 4 3.38 5.49 16.22 5.47 57.18 1 4 3.58 5.47 16.10 5.42 57.30 1 4 3.78 5.44 15.98 5.37 57.41 1 4 3.98 5.42 15.86 5.32 57.53 1 4 4.18 5.40 15.74 5.27 57.64 1 4 4.38 5.38 15.62 5.22 57.76 1 5 4.38 5.37 15.64 5.26 57.79 1 5 4.43 5.37 15.61 5.25 57.82 1 5 4.48 5.37 15.58 5.24 57.85 1 5 4.53 5.36 15.55 5.23 57.88 1 1 1 1 1 1 4.58 5.36 15.52 5.21 57.90 4.63 5.35 15.49 5.20 57.93 4.68 5.35 15.46 5.19 57.96 4.73 5.35 15.43 5.18 57.99 4.78 5.34 15.41 5.16 58.02 4.83 5.34 15.38 5.15 58.05 4.88 5.34 15.35 5.14 58.08 4.93 5.33 15.32 5.13 58.11 4.98 5.33 15.29 5.12 58.14 5.03 5.33 15.26 5.11 58.17 5.08 5.33 15.23 5.09 58.19 5.13 5.32 15.21 5.08 58.22 5.18 5.32 15.18 5.07 58.25 5.23 5.32 15.15 5.06 58.28 5.28 5.32 15.12 5.05 58.31 5.33 5.31 15.09 5.04 58.34 5.38 5.31 15.07 5.02 58.37 5.43 5.31 15.04 5.01 58.40 5.48 5.31 15.01 5.00 58.43 5.53 5.31 14.98 4.99 58.46 5.58 5.30 14.95 4.98 58.48 5.63 5.30 14.93 4.97 58.51 5.68 5.30 14.90 4.95 58.54 5.73 5.30 14.87 4.94 58.57 5.78 5.30 14.84 4.93 58.60 5.83 5.30 14.82 4.92 58.63 5.88 5.29 14.79 4.91 58.66 5.93 5.29 14.76 4.90 58.69 5.98 5.29 14.73 4.89 58.72 6.03 5.29 14.71 4.87 58.75 6.03 5.31 14.63 4.85 59.13 6.13 5.31 14.58 4.83 59.16 6.23 5.31 14.53 4.81 59.20 6.33 5.31 14.48 4.79 59.24 6.43 5.31 14.43 4.77 59.28 6.53 5.31 14.38 4.75 59.32 6.63 5.31 14.33 4.73 59.35 6.73 5.32 14.28 4.71 59.39 6.83 5.32 14.24 4.70 59.43 6.93 5.32 14.19 4.68 59.47 7.03 5.32 14.14 4.66 59.51 7.13 5.32 14.09 4.64 59.54 7.23 5.33 14.05 4.62 59.58 7.33 5.33 14.00 4.60 59.62 7.43 5.33 13.95 4.58 59.66 7.53 5.33 13.91 4.56 59.70 7.63 5.34 13.86 4.55 59.73 7.73 5.34 13.81 4.53 59.77 7.83 5.34 13.77 4.51 59.81 7.93 5.35 13.72 4.49 59.85 8.03 5.35 13.67 4.47 59.89 8.13 5.35 13.63 4.46 59.92 8.13 5.38 13.48 4.41 60.69 8.23 5.39 13.41 4.39 60.86 8.33 5.40 13.34 4.36 61.03 8.43 5.40 13.27 4.34 61.20 8.53 5.41 13.21 4.31 61.37 8.63 5.42 13.14 4.29 61.54 8.73 5.42 13.07 4.27 61.71 8.83 5.43 13.01 4.24 61.88 1 1 1 1 2 2 2 2 2 2 2 2 2 2 2 2 2 3 3 3 3 3 3 3 3 3 3 3 I Seg # 7 8..93 5.44 12.94 4.22 62.05 7 9.03 5.45 12.87 4.19 62.22 7 9.13 5.45 12.81 4.17 62.39 7 9.23 5.46 12.74 4.15 62.56 7 9.33 5.47 12.68 4.13 62.73 7 9.43 5.48 12.62 4.10 62.90 7 9.53 5.48 12.55 4.08 63.07 7 9.63 5.49 12.49 4.06 63.24 7 9.73 5.50 12.43 4.04 63.41 7 9.83 5.50 12.36 4.01 63.58 7 9.93 5.51 12.30 3.99 63.75 7 10.03 5.52 12.24 3.97 63.92 7 10.13 5.53 12.18 3.95 64.09 8 10.13 5.53 12.18 3.95 64.09 8 10.38 5.61 12.03 3.89 64.52 8 10.63 5.69 11.88 3.83 64.94 8 10.88 5.76 11.74 3.78 65.37 8 11.13 5.82 11.60 3.73 65.79 8 11.38 5.88 11.46 3.67 66.22 8 11.63 5.94 11.32 3.62 66.64 8 11.88 5.99 11.18 3.57 67.07 8 12.13 6.04 11.05 3.52 67.49 8 12.38 6.08 10.92 3.47 67.92 8 12.63 6.12 10.79 3.42 68.34 1 0.00 5.34 18.34 4.52 8.25 1 0.30 6.04 17.86 4.38 8.33 1 0.60 6.49 17.40 4.25 8.41 1 0.90 6.80 16.95 4.12 8.49 1 1.20 7.00 16.52 4.00 8.57 1 1.50 7.13 16.09 3.88 8.64 1 1.80 7.23 15.68 3.76 8.72 1 2.10 7.30 15.29 3.65 8.80 1 2.40 7.35 14.90 3.54 8.88 1 2.70 7.39 14.52 3.44 8.96 1 3.00 7.43 14.16 3.34 9.03 1 3.30 7.46 13.81 3.24 9.11 1 3.60 7.48 13.46 3.15 9.19 1 0.00 6.28 11.10 3.39 77.53 1 0.23 6.31 10.99 3.35 77.93 1 0.46 6.34 10.88 3.31 78.32 1 0:69 6.37 10.78 3.27 78.71 1 0.92 6.40 10.67 3.23 79.10 1 1.15 6.42 10.56 3.20 79.49 1 1.38 6.45 10.46 3.16 79.88 1 1.61 6.47 10.36 3.12 80.27 1 1.84 6.49 10.26 3.09 80.66 1 2.07 6.51 10.16 3.05 81.05 1 2.30 6.53 10.06 3.02 81.44 I Reach # I Seg Mi I D.O. I CBOD I NBOD I Flow INSTREAM SELF -MONITORING DATA MONTHLY AVERAGES Discharger: /bt;, ji2y Permit No.: NC00 Receiving Stream: A"AizA-r P-v,2. Sub -basin: Upstream Location: u5 uw4 52 Fx_xe Downstream Location S2 1,77,a DrAo Fvy DATE DEC-90 NOV- 90 OCT-90 SEP-90 AUG-90 JUL-90 JUN-90 MAY-90 APR-90 MAR- 90 FEB-90 JAN-90 DEC-89 NOV- 89 OCT-89 SEP-89 AUG-89 JUL-89 JUN-89 MAY-89 APR-89 MAR-89 FEB-89 JAN-89 DEC-88 NOV- 88 OCT-88 SEP-88 AUG-88 JUL-88 JUN-88 MAY-88 APR-88 MAR- 88 FEB-88 JAN-88 DEC-87 NOV-87 OCT-87 SEP-87 AUG-87 JUL-87 JUN-87 MAY-87 APR-87 MAR-87 FEB-87 JAN-87 Upstream Downstream TEMP D.O. BOD5 COND TEMP D.O. zon FFIA I- p6CAL Zo•Ig �Z/ys� 242 /9.`I 267&0 300 l6. 1 0, (6,5) Zd7 JG• Z Z¢7(G.9) Zs 6 9 22 0, (9.Q-) ZZfi q.d%a).344 b.72(1) it, 5 94R 17,17 n, ss / 3 , i3.3 9,W7 13.4¢ 8.%1'7,4) Z96 i7. Z 00-7.0) 7-35- 17.7 R-'3 � 07(:StJ 316.4 /q.7 �•iS/S>? /2� 2z.7_ a r>.*(-3) 90� 7. Z •0) 213 /10 7. 2 (6.0) 2� �� COND �- No Mq, —nl a2D/Z -p", CorL, .L S 3 — -7r 5 Z ......u..r .•. iuu Il, IYYV REQUIREMENT ... ...i.. rc' MDESN: PERMITCHRONIC LIMR:94%FEB MAR A 'R MAY .. AN NPDFSA: N�6'/28 OD040M &9in:4A/89 Q P/P a P1Moo� '86 . y Coonry: IREDE1L Ragim:MRO : MmW: FEB MAY AUG NOV •g8 (PASS) - (FAIL) - PP:310 SOCpOC Rcq: QrgR,) _ - <-) FAIL - _ p'AR)" 7Q1P.03 IWC(A):94.15 F FAIL - PASS PASS NR - PASS NR PASS M00.pANR$RG PERMAi CHRONICLIMR;99% 90 PASS - _ _ PASS - fiRDESX: NC006W4] &gum 10'1/88 Q .1 '61 Cowry: HARNE3T Regim: FRO M. o: N MmW: lAN APR lUL OCT '89 PP:0.026 SOCnOC Rom: 7Q10: 0.00 IWC{%):I0000 NR NR FAIL U7H PASS 90 NR PASS - NR - M FAIL FAIL MO W PERMIT CHRONIC LIMIT9AA ESN: NCN NI'DESA: NC0026573 73 Begm 12/1/87 Preq'rny, Q P/P 16 Cuvnry: BURR Regim; MRO JAN APR JUL OCT illFAIL - - - _ _ PP: amMmW: SOCDOC Req: 'H9 PASS - (-) -; PASS (-) PASS - - PASS - _ (hR) 7Q10:126.00 IWC(%):8.96 - - PASS - PASS - _ 90 PASS - - PASS - PASS - _ MORR W WIP ERROR FOUND W/SAMPLE COILEC170N '86 h-PDPSN: A: N0]CNCDO d0938 Bcgm OQW/D0 P1O n D . Cncvry: WAKE Region: PRO Manm011 8J '88 PP:0.15 : SOp10C Rio,: '89 7Q10: 0.00 RVC(%)100.00 ,90 MORRISVd1E WWIP-CRABTREE LLTTERCHRONICTARGEP:38% '86 NPDESA: U41 Reg6c3/l/88 R-R"Y M P/F 87 Cowry: WAKE AKE W Rceim:RRO MmW: PP:0.20 SOCJIOC Req: '89 PASS NR " NR HE NR NR 7Q10: o.30 IWC(%):78.27 NR NR NR NR HE NR NR NR NR NR NR 90 NR PASS NR NR NR NR NR W. AIRY WWTP PERMITCHRLIMMJ2%,42%@d MGD&COMPLIANT NPDPSA: Nm021121 &gW 5/1E189 Q P/P d V'8615.S •87 NR M 26.2 13.19 39.i- 21.47 NONE P30 NONE NO NE/)' P151F Cowry: SORRY Regim: WSRO MmW: JUL OCPIAN APR '88 J],P NONHP P40 89.99 (PASS) - - (PASS) NONE/P PP; SOC/IOC Rcq: - '89 (PAIL) PASS - 'PASS - (PASS) 7Q10: 13.0 13. RVC(%):3L2 FAIL - - PAR. FAIL PAd FAIL PASS PASS - FAR, 90 PASS _ _ P,P PASS b� _ q'R.HOILYWWIE PERMIT CHRONIC LIMlr:6.1% WDRSA: NC0021156 BegW a/I/g8 F" q^,r Q 9/F '86 .1 Cowry: GASTON Regim: MRO MmW: MAY AUG NOV FEB 188 PF: 4.00 SOCROC Req; - '89 - PASS (NR) - NONE (-) NONE PASS - PASS 7QI0: 93.00 IWC(%):6.10 - - PASS - - PASS 90 - PASS - - PASS - - PASS - dDESP:NPIGKLE PERMITCHItONIC LIMIT:99A '86- 1PDESA: N(A0010]4 Begin I/I/88 Regm¢y- Q PIP '87 19 _ _ - - - - - - - Cavmy: WAYNE Regim: WARD MmW: FEB MAYAUO NOV .88 (16) 10 27 NR 23 RP 18 14 15 13 NR <5.0 10.5 PF:0.40 SOC130C Re, 32 - (Igo - - (-) - NR NR 7QI0.0.00 BVC(%):100.00 89 _ NR _ 21.9 NR - 37.6 NR _ .49 90 58.7 47.2 - _ _ fr. OLIVE WVF- PERMIT CHRONIC LI.MrE:99% '96 fPDESX: NN0203]5 PDESN:NOD0= BcgW 2/1/88 Prague Q P/F '8] Canty: WAYN'E Region: WARD MmW:MAR IIIN SEP DEC -88- (PASS) PP: 1.0 7Q10:0.000 IWC(%):I00.00 SOGJOC Pcq: SOC:1027.7/88 NO TO%REQ 189 - - PASS - - (PASS) - _ PASS - - - - Na PASS - - PASS 90 - - M PAIL LATE _ _ PASS NRN(Y MEDICAL CF_v7PR RESCNUED II/89 PDESA: NCDM8857 &girt I/1I88 H'^9 D '86 Cowry: (}BROKFP ftcgim:ARO M-do: mW:FEB MAY AUG NOV '98 '88 (NIT) NONE- PP:0.05 SOCAOC Req: '89 - NODE (_) - (-) Z3• _ - NR NONE 7QI0:62.0 BVC(%):0.12 - - NONE - - 39.6 90 - - NR 0 2cmxm6vchd.x..,Wr mt nmmnpUwm Y 19836u.vd.bl. LEGEND: PPwPemdmd flow (MOD). 7Q10=Remiving room low now ai m(c[.),BVC%.Wae.mwun m00000'oim,Begin-F1m mmN xquixd. FmquorcyKMmlmrmg fxgrcrry): IQ.Qu. ,,,M-Min r,BM-BWaWdr, SA-semi.rmu,vy; A-gnvWly; OWWD Ywl�n P gin Nohow 'eCeriode to,iPB mY oo oIo. I.C.M, V�Urmm l�cvo '1-.NuWi P..ncdc ookb 1.y, Aw ., Chr-Coo ic.A-qv ymmiwayk .x.mn ,upm ooy, SA- (Repoti gNm6m): I._wD.n mt required, NR.Nm xpo d,( )wBag"e 9 of Qvurerl. IF.cdiry Aaivi�y5 n.); I I.Wniw, NwNewlyl ucd(Taccorve a).HrActi,�� Wt.0DRMd q &, p, bo-B.d xrtJ. 28 E HAZEN AND SAWYER, P.c. CONSULTING ENGINEERS May 22, 1990 Mr. M. Steven Mauney Water Quality Supervisor N.0 Division of Environmental Management 8025 North Point, Suite 100 Winston-Salem Regional Office Winston Salem, NC 27106 Re: Confirmation of Discussion on SOC for Mount Airy Wastewater Treatment Plant Expansion H&S No. 3975 Dear Steve: This letter is to confirm our conversations with yourself and Trevor Clements concerning the items to be incorporated into the SOC under discussion relative to expansion of the Mount Airy wastewater treatment plant. We discussed the following points relative to the SOC: 1. We are continuing to pursue data collection from the Bench Scale Pilot Plant to model plant performance with increased flow from Cross Creek (Quality Mills). Results to date suggest no difficulty in satisfying the acute toxicity limit. However, we have not yet been successful in meeting the proposed chronic toxicity requirement. At this point, we are inclined to believe that our problem with the chronic toxicity test is more than likely related to the instability of the bench scale plant and not necessarily an indication of effluent toxicity. We are in the process of completing a third laboratory analysis scheduled for completion on May 23rd. The stability of the bench scale plant was much improved prior to taking this sample, and we are hopeful that we can demonstrate satisfactory compliance with the proposed chronic limit. We understand that we must demonstrate the capability to comply with the chronic limit as a precondition to the SOC. We further understand that a single passing test will be acceptable to DEM. 2. We discussed the period to be covered by the SOC and agreed that the SOC would cover that period required for construction of the proposed plant expansion. We anticipate an acute toxicity limit for the period of the SOC, and we understand that DEM will also propose monthly chronic toxicity monitoring for the period of the SOC. This monitoring will serve as an indicator of possible plant performance after the expansion is complete and would allow for preparation on the part of the City should it become clear that the completed plant might have an ongoing chronic toxicity problem. 4= W/ESTCHASE SCULEVARD . SUrrE 550 . RAIEIGH, NC 27607 . (919) 833-7152 FAX (919) 833-1828 R4.6GH. NC CHNLOTTE. NC NEWPORT NEWS. VA HOLLYWOOD, R NEW YOR, NY Mr. M. Steven Mauney May 22, 1990 Page Two 3. We have previously discussed the desirability of temporarily discontinuing service to the existing aeration basin during the plant expansion. The current bench scale work will produce data on anticipated plant performance without the benefit of the aeration system. Your previous letter of January 24, 1990 suggested a seven -month allowable window from September 1, 1990 to April 1, 1991 for that portion of the construction that must be completed with the aeration basin off-line. We have discussed this proposal both internally and with the City and offer the following comments and suggestions: a. A 7-month construction period is tight for the work required but should be attainable if normal weather conditions prevail. The specifications would require that the contractor restore service to one cell of the proposed two -cell aeration basin during the stipulated time frame. Half of the proposed aeration tank volume will be adequate for the initial flows expected at the treatment plant. b. Given the present status of the plans and specifications (submitted for Division approval on May 4, 1990), it is doubtful if not unlikely that we can have a contractor in place and prepared to undertake construction of a major structure by September 1 of this year. Even assuming the most optimistic of schedules, September 1 would be at the very beginning of the construction process, and we are reluctant to require that such a major effort be forced into the start-up of the project. Given the desirability and the Division's preference for shutting down the aeration system during the cooler months of the year, we suggest that the allowable window be moved into the second winter season of construction or September 1, 1991 to April 1, 1992. Such a time frame should be much more amenable to the anticipated pace of the construction. c. Relative to the above comment on schedule, there is also a need to consider the effort required for sludge removal from the existing aeration basin. Based on limited field sampling by the operating staff, we estimate that as much as 2.5 million gallons of sludge exist within the existing basin and must be removed prior to construction of the new aeration system. Given our previous comment on the length of time required to construct the new aeration system, we do not believe it is practical to remove the sludge within the same 7-month window allowed for the new construction. We have identified two alternatives that provide for sludge removal. These alternatives are as follows: (i) Alternative 1 - Increase the allowable window for decommissioning of the aeration basin to 9 months (September 1, 1991 to June 1, 1992) to allow additional time for sludge removal. HAZEN AND SAWYER PC Mr. M. Steven Mauney May 22, 1990 Page Three (ii) Alternative 2 - Allow the aeration basin to be taken off-line for up to 60 days during the initial 7-month window (September 1, 1990 to April 1, 1991) to allow for sludge removal. The existing aeration basin would be returned to service no later than April 1, 1991. Decommission the basin a second time beginning on September 1, 1991 to allow for new basin construction. Since some additional sludge would be expected to accumulate in the basin, we recommend that the window be increased to 8 months, or May 1, 1992 to allow for removal of any additional accumulated sludge as well as the necessary construction. Under this alternative, the basin would be out of service for a total of 10 months. Since Alternative 1 minimizes the length of time that the aeration basin would be out of service and only requires that the basin be dewatered on a single occasion, we would prefer to handle the sludge in this fashion. We require comment from the Division before we can make final provision for sludge removal. In addition to the above items, the City would also request that the SOC provide for an interim flow increase up to 5.0 mgd as opposed to the 4.8 mgd previously discussed The increase in permitted flow is desired to assure continued economic growth in Mount Airy - We will provide additional information on the results from the bench scale plant and toxicity sampling as it becomes available. We would appreciate any comments from the Division relative to our suggestions for items to be addressed in the SOC. Very truly yours, HAZEN AND ,� YER, P.C. Oe(Donald L. Cordell, P.E. Vice President DLC:er cc: Mr. Jerry E. Cox Mr. Steve Tedder Mr. Trevor Clements HAZEN AND SAWYER, a.c. ® North Carolina Wildlife Resources Commission 512 N. Salisbury Street, Raleigh, North Carolina 27611, 919-733-3391 Charles R. Fullwood, Executive Director MEMORANDUM TO: Melba McGee, Planning and Assessment Dept. of Environment, Health & Natural Resources Resources FROM: W. Don Baker, Program Manager a/'9 � Division of Boating and Inland Fisheries DATE: April 18, 1990 SUBJECT: Renewal and Modification of NPDES Permit and Finding of No Significant Impact (FONSI) for City of Mount Airy Wastewater Treatment Plant Expansion to 7 MGD, Surry County, North Carolina. We have reviewed the subject Environmental Assessment (EA) and Finding of No Significant Impact (FONSI) regarding the proposed improvements and permit renewal for the City of Mount Airy wastewater treatment plant facility. Proposed upgrading of the wastewater treatment plant includes the following: 1) influent pump station modifications, 2) screening and preliminary treatment facilities, 3) upgrade of trickling filters, 4) intermediate pump station modifications, 5) aeration basins, 6) new final clarifiers with distribution box, 7) an additional chlorine contact chamber and dechlorination and 8) post aeration facilities. Sludge treatment facilities include a gravity belt thickener, anaerobic digester modifications and a belt filter press for sludge dewatering. Proposed treated wastewater discharges will increase from approximately 4 MGo to 7 MGD by the year 2000. Our comments are provided in accordance with the State Environmental Policy Act (G.S. 113-A through 10). An onsite inspection was not conducted for this report. The Ararat River below the treated wastewater discharge is a Class C stream containing both cool and warmwater fish species. The FONSI notes that the receiving waters below the current and proposed discharge at the confluence of Lovills Creek and the Ararat River have a high assimilative capacity which could handle the proposed 7 MGD discharge. Due to the degraded water quality of Lovills Creek from permitted wastewater discharges, storm water runoff, Memo Page 2 April 18, 1990 nonpoint source discharges and improper land use practices, it is doubtful that the Ararat River can assimilate as much treated wastewater as proposed under the NPDES permit without further degradation of downstream aquatic resources. The high proportion of industrial waste versus residential and commercial flows has the potential to increase the presence of toxic materials, especially metals, in the. Ararat River. The FONSI notes that concentrations for cadmium, chromium, and copper, the metals considered most significant in terms of potential impact on the treatment plant and receiving waters are all within the range considered acceptable for biological systems. This may be true for this one facility, however, the cumulative effects of toxic material discharges from additional point and nonpoint sources needs to be addressed before allowing an increase in wastewater discharges from this plant. Nutrient input from treated sewage discharges on benthic producer communities can alter their composition. Algae populations, the base of the food chain, can be changed from beneficial to harmful forms below nutrient loading discharges, impacting consumer organisms. Ammonia nitrogen and phosphates increase dramatically below treated sewage discharges. These effluents reduce benthic algae communities, often resulting in a shift away from diatoms, the preferred food of many invertebrate grazers. Biological changes at the base of the food chain which occur below effluent discharges often lead to corresponding changes (reductions) in the populations of consumer organisms (invertebrates and fish). These changes in aquatic habitats are often subtle and can go unnoticed to the casual observer. Additional nutrient loading on an already degraded aquatic resource, the Ararat River, needs to be addressed. The. Division of Environmental Management should seriously consider the impacts of this facility on the aquatic community downstream and strive to improve the water quality of the river and aquatic resources. The Ararat River, if its water quality were to improve, could once again become a high quality smallmouth bass stream. The Ararat River is considered a cool water stream in the vicinity of the treatment plant capable of supporting smallmouth bass. The issue of temperature increases on receiving waters and aquatic resources below the effluent discharge has not been addressed. The FONSI does not address the color of the permitted wastewater discharge. Due to numerous textile mills in the area, effluent from this plant is usually a dark dye color. This color discharge can interfere with light penetration through water, thereby reducing natural biological processes and aquatic resources even further. Memo Page 3 April 18, 1990 The FONSI (Figure 1) alludes to the proposed construction of a gravity outfall transmission line, regional sewage lift station, and forcemain transmission line paralleling Stewarts Creek and the Ararat River. No plans were given for their construction or mention made on their impacts on wildlife, fishery resources, or wetlands. The construction of these items will impact wetlands, floodplain areas, stream riparian zones, and possibly bottomland hardwood forests. This phase of the project has the potential to impact species considered endangered, threatened, or of special concern under the State Endangered Species Act (G.S. 113 Article 25). Species found in the area include the mole salamander, four -toed salamander and bog turtle. Based on review of the plans submitted and WRC concerns listed above, we approve of the plans with the following modifications: 1. Further study be given to cumulative effects on NPDES discharges and nonpoint discharges on the Ararat River and Lovills Creek water quality. The proposed treatment plant nearly doubles (4 MGD to 7 MGD) the permitted wastewater discharge. Just how much waste can the Ararat River assimilate before irreversible damage to aquatic resources occurs needs to be addressed. 2. The issue of water temperature increases from this plant on cool water habitats needs to be addressed. 3. The color of the effluent discharge should not alter the water color of the receiving stream (Ararat River). 4. WRC approval of the enclosed plan does not constitute endorsement of construction of the gravity outfall transmission line, regional sewage lift station, or forcemain transmission line. We will need to review these plans upon their completion. 5. Plans submitted for item four above should address mitigation to off -set impacts to wildlife and fishery resources, note wetlands to be impacted, and address the issue of endangered species. Thank you for the opportunity to review and comment on this project. If we can provide further assistance, please call on us. DB/lp cc: Don Hayes, District 7 Wildlife Biologist Joe Mickey, District 7 Fisheries Biologist John Fridell, USFWS, Asheville C; HAZEN AND SAWYER, P.c. NIAR 3 0 199r, 0 CONSULTING ENGINEERS • ltt:t ,:ti .j: s 'u",; 1 March 2r; 1990 MAR' 0s Mr. Steve Tedder_" e ¢a��^ Qa 199r Chief of Water Quality Section � 1! i_ � �;��,_•,; ;� Division of Environmental.Management Department of Environment, Health MAR 3 0 i990 '^ and Natural Resources P.O. Box 27687 Iti,i,lpvgl;li fU�( iS�hP,CH Raleigh, NC 27611-7687 n Dear Mr. Tedder: I We have been corresponding with Steve Mauney in the Water Quality Section of the DEM Winston-Salem office regarding a schedule for compliance for the City of Mount Airy Wastewater Treatment Plant Expansion. A specific area which we are trying to resolve in the near future is_a proposed requirement for a treatability study to evaluate conditions of future operation. We have discussed these conditions and proposed testing approaches with Steve Mauney and, at his suggestion, have summarized our recommendations in this letter as follows. Condition during construction for interim increase in flow from Cross Creek Mills (formerly Quality Mills) when aeration -basin is removed from service for modification to an activated sludge configuration. During this period, secondary treatment will be provided by existing trickling filters which will remain in service. It is anticipated that polymer feed can be provided during this period in order to improve settleability and offset the loss of the aeration basin. An interim limit for acute toxicity has been proposed for an In -stream Waste Concentration of 36 percent at a plant flow of 4.8 mgd. General Testing Approach: The existing plant has capability for varying flow split between trickling filters and has even successfully operated at higher loadings that occur with one filter out of service. This capability will be used to increase loading on one of the trickling filters to simulate the interim loading condition. Bench -scale evaluations of polymers will then be performed on the effluent from this trickling filter to evaluate the need for supplemental treatment. Future condition when Cross Creek Mills has completed its expansion, thereby increasing its percentage of wastewater input. This will be the most critical condition that should cover the full range of incremental changes anticipated for Cross Creek Mills. 4000 WESTCHASE BOULEVARD . SURE 550 . RAL.EIGH, NC 276D7 . (919) 833-7152 FAX (919) 833.1828 RALErK NC CKVXDTrF NC NEWPORT NEWVA HOLLYWOOD. FL NEW YORK NY Mr. Steve Tedder March 22, 1990 Page Two General Testing Approach: Because of difficulties in satisfactory pilot testing and logistical problems in obtaining the large volume of feed flow from Cross Creek Mills as would be needed for simulating an adequately sized trickling filter pilot plant, we have recommended an approximation of the future condition using effluent from the existing trickling filters to simulate the background flow to which additional Cross Creek Mills effluent will be added. The added increment of Cross Creek Mills effluent will be collected and fed to the pilot plant as a supplemental feed stream without the benefit of prior treatment by trickling filters. Therefore, a somewhat conservative condition will be represented in these tests and actual plant performance should be better than this simulation. However, significant variation is not anticipated since most of the pilot plant influent will be comprised of base flow that has received trickling filter treatment. The pilot —scale unit is a basic activated sludge system that simulates future operating conditions, particularly with respect to detention time and sludge age. Testing will be performed to determine the effects of future treatment conditions. In the case of the interim condition during construction, acute toxicity will be evaluated. Chronic toxicity will be evaluated for the future condition with increased Cross Creek Mills effluent. Both sets of toxicity tests will be performed for a range of dilutions so that the effects of treatment can be more clearly delineated than with pass/fail tests at fixed dilutions. Other parameters to be evaluated at the influent and effluent of testing include: BOD5 SS pH Temperature Ammonia Dissolved oxygen. We will contact you in the near future to see if there are any additional comments. In the meantime, if we can answer any questions, please let us know. Very truly yours, HAZEN AND SAWYER, P.C. George C. Budd, Ph.D., P.E. Associate GCB:er cc: Mr. Steve Mauney HAZEN AND SAWYER, P.c a State of North Carolina Department of Natural Resources and Community Development Winston-Salem Reg onal Office James G. Martin, Governor William W Cobev Jr, Secretary DIVISION OF ENVIRONMENTAL MANAGEMENT January 24, 1990 030­103 Suva+�vev Mr. Jerry E. Cox, City Manager City of Mount Airy P. O. Box 70 Mount Airy, NC 27030 `J2N ', i 1990 SUBJECT: Preliminary Schedule of Compliance Outline TEGPti ,;, City of Mount Airy WWTP Expansion", -n1 NPDES No. NCO021121 i Surry County �? L Dear Mr. Cox: As you are aware, the Water Quality Section of the Winston-Salem Regional Office was directed to provide the City with certain conditions which are expected to be contained in any formal Schedule of Compliance which mav be submitted to the Environmental Management Commission for approval. The majority of the conditions were discussed in Raleigh at the meetings on December 6, 1989 between agents of the City and D.E.M. The specific issues which are likely to be incorporated into the Order are as follows: 1) Toxicity - During the period within which the S.O.C. is in effect, an interim limit for acute toxicity will be established. This limit will be set at the projected In -stream Waste Concentration, which is 36% at 4.8 million gallons per day, The effluent must exhibit no acute effect at the I.W.C. The tests must be done monthly, such that any failing trend can be quickly identified, and appropriate steps to address the problem can be initiated. 8025 North Point Boulevard, Suite 100, Winston-Salem, N.C. 2710G3295 • Telephone 919-761-2351 An Equal Opportunity Affirmative Action Employer Jerry E. Cox Page �,2 January 24, 1990 Additionally, influent sampling for the presence of previously banned surfactants should be initiated immediately. The sample ,should be of the composite type, and should be collected weekly. Reduction of this frequency:will be considered upon confirmation of the absence of banned surfactants. Should the sampling confirm the presence of surfactants, steps listed as "Phase I" on page 2 of the October 3, 1989 Hazen and Sawyer letter should be initiated in order to pin -point the offending Industrial User. It is also relevant to note that construction of dechlorination facilities may favorably impact the toxicity problem. 2) Treatability Study Because the projected (and in fact, current) volume of industrial flow contributed to the plant is substantial in comparison to the sanitary waste flow, and because textile waste has been shown to have contributed to past effluent toxicity at the plant, treatability studies should be submitted with each request for incremental flow increases, including the initial request. The treatability studies should reflect the conditions anticipated during the interim period of plant expansion, such as decreased oxygen values when the aeration basin is taken out of service. The management of Quality Mills should be required to furnish precise information as to the quantity of waste -water flow including anticipated flow patterns both daily and weekly, waste -water characteristics with anticipated hourly and daily variations from the norm, and any proposed pretreatment facilities. When the treatability studies during interim conditions have been completed, simulating anticipated circumstances as closely as possible, a study can then be performed which simulates as -built conditions. Mr. Jerry E. Cox Page #3 January 24, 1990 3) Construction phasing As you are aware, the Division would prefer that any activity resulting in a temporary decrease in oxygen transfer to the waste -water (such as circumventing the aeration basin) be carried out in cold -weather months, due to increased flows and higher ambient D.O. levels in the receiving stream. The basin should not be taken out of service prior to September 1, 1990, thus delaying this period of potential plant upset beyond the critical stream flows of the summer season. It must be back on line no later than April 1, 1991, so that the modifications will be accomplished prior to the addition of a majority of the inndustrial flow. Regardless of the timing of construction, certain steps can, and and should, be taken to minimize the effects of loss of the aeration basin. These steps should include construction of an effluent aeration unit at the outfall, or an alternative means of providing supplemental oxygen to the waste -water. If the City does not choose to construct the post aeration facilities in the initial phases of construction ,then data should be provided to support any short-term alternatives which may be considered, such as placement of a mechanical aerator or aerators in existing units. Additionally, due to anticipated regulatory changes relative to disinfection, it would likely be economically favorable for the City to initiate construction of the dechlorination units while modifications to the chlorination units are underway. 4) Interim (S.O.C.) Limits and Schedules Until data is produced from the treatability study, any limits proposed for Biochemical Oxygen Demand would be arbitrary, since the critical problem involves the ability to provide oxygen transfer while the existing aeration basin is out of service. Mr. Jerry E. Cox Page #4 January 24, 1990 Other limits which can be anticipated in the S.O.C. are as follows: A. Dissolved Oxygen - 5 mg/l B. Fecal Coliform - 1000 colonies/100 ml C. Toxicity - No acute effect at 360 D. Total Suspended Solids - limit will be established based on data from treatability studies. Likewise, the dates in the Schedule can be better arrived at following finalization of construction plans. Please provide the treatability and construction information as soon as possible, so details of the S.O.C. can be arrived at with minimum impact on construction start-up. Should you have questions on this matter, please contact me at (919) 761-2351. Sincerely, M. Steven Mauney Water Quality Supervisor MSM/vm CC: Hazen and Sawyer Steve Tedder %Trevor;Clem'erits Central Files WSRO s � - _G. Pl. - — iL✓G✓J•t-Ci for y�-�2�(n.vv - — - !, v- i -- `� -if ----- � _ �jte--� S we U' S+- 60 lv I I Lw—E9�i� 4 Pse�11 • N --fit ��- --w��� � �_ - - -- -QAbU W� T �P "VIV cl./� pp--� cf - a-j �� DIVISION OF ENVIRONMENTAL MANAGEMENT December 7, 1989 MEMORANDUM To: Mount Airy WLA File From: Trevor Clements Subject: December 6 Meeting with Mount Airy Representatives DEM Water Quality staff from the Winston-Salem Regional Office and Central Headquarters met with representatives of the City of Mount Airy (see attached attendance list) to discuss issues surrounding the expansion of the City's existing wastewater treatment plant (WWTP). Discussion centered around the steps that Mount Airy must take in order to receive approval from DEM for the addition of industrial sources of wastewater during the expansion process while under a Consent Order. The Division is concerned with numerous toxicity test failures that have occurred at the Mount Airy facility within the past year, and the additional effect that increased wasteflow from Quality Mills (a Significant Industrial User within the City's sewer system) may have on the facility's Pffluent toxicity. During the meeting, the City and their consultant (Hazen & Sawyer) were asked to explain what actions were being taken to address the toxicity problem. The City replied that increased testing had been performed, including split sampling with independent certified toxicity laboratories. However, no toxicity reduction efforts had taken place since the City had passed its last 3 tests. Regional DEM staff presented Mount Airy with data collected by DEM showing test failures for two samples collected in late October and November of this year. Staff from each party agreed to share data for further examination of whether a problem continues to exist with regard to effluent toxicity. The City's consultant indicated they hoped to begin construction of their new facility in July of 1990. During construction, the City plans to take their aeration basin out of service for about six months while plant renovations occur. At this time, treatment will consist only of trickling filters. DEM expressed a preference to delay this action until September to avoid the warmest summer months, as plant BODS is expected to be between 50 and 60 mgil during this interim phase. Also, DEM recommended that measures be implemented to obtain an effluent DO of at least 5.0 mgil prior to decommissioning of the aeration basin. Mount Airy will likely construct a stepped, cascading outfall to fulfill this requirement. { Other items discussed included performance of a treatability study on Quality Mills' existing effluent, and the implementation of dechlorination. The Section chief also mentioned that the City of Mount Airy should seriously consider providing sewer service to nearby residential areas that are experiencing subsurface system failures. DEM staff generally concurred that the additional domestic waste source may benefit plant operation given that the influent is dominated by industrial sources. The Winston-Salem Regional Office agreed to follow up the meeting with a letter to Mount Airy detailing the Division's position and outlining the necessary components of the warranted Consent Order. Technical Support will assist the region by performing an instream assessment as soon as the appropriate information is submitted. TCiam CC: Steve Tedder Steve Mauney Ken Eagleson ^nun� n SUBJECT PROJECT: ¢" I.J PROJECT NO. CONFERENCE DATE: 12./(o 69 —I I BRIEF PURPOSE OF CONFERENCE: ATTENDEES: REPRESENTING zZ Ace s7sGl�/4 kY/y1iR/� A) `2T`�, Al a �, Nate : `TGAC-1f, (Z� P by 5� � � -7-Year- Cla . State of North Carolina Department of Natural Resources and Community Development Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor R. Paul Wilms William W. Cobey, Jr., Secretary October 24, 1989 Director Mr. Gordon C. Ruggles, P.E. Senior Vice President Hazen & Sawyer, Consulting Engineers 4000 West Chase Blvd. Suite 550 Raleigh, NC 27607 SUBJECT: City of Mount Airy WWTP NPDES Permit NCO021121 Surry County Dear Mr. Ruggles: This correspondence is in regard to your letter of October 3, 1989. As you are aware, the City of Mount Airy failed its toxicity tests for January, April, May and June 1989. The toxicity tests passed in July, August and October, but the July test was apparently conducted during a shut down period for some of the indirect sources, and would therefore not be representative. A review of the capacity of the treatment units indicates that the existing facility should have the capability to meet secondary limits at 4.8 MGD with a domestic strength influent. However, for the period beginning September '88 until August 189 the effluent BOD of 21 mg/l and TSS of 20 mg/l were achieved while the flows only averaged 3.3 MGD. Admittedly, the plant performed slightly better than this during June and July '89 when the flow was 4.1.MGD, but the data shows this plant does not operate as well during the colder months of the year. Also the addition of 0.5 MGD or more of industrial wastewater could change the strength of your influent waste and degrade the effluent quality. It appears that portions of the first phase upgrading identified on page 17 of the "Supplemental Report, Water and Wastewater Systems Evaluations" dated November 1988, would Pollution Prevention Pays P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer Gordon C. Ruggles Page #2 October 24, 1989 be necessary to insure compliance at 4.8 MGD. An item that certainly will be important at this higher flow is the upgrading of the aeration basin. It is suggested that Mt. Airy authorize your firm to proceed to finalize plans for this first phase upgrading and submit them in the near future. This should be done quickly so that, upon approval of plans, this portion of the project can proceed. Any other portions of the first phase upgrading that you feel are essential to achieving compliance at 4.8 MGD should be included in the plans. The request for Special Order dated October 11, 1989, from Mr. Jerry Cox, City Manager, Mount Airy has been received. We plan to direct our Winston-Salem Regional Office to proceed in developing a short term Special Order by Consent. The Order will not allow any industrial waste increase unless it is shown to be equivalent to domestic wastewater. Mt. Airy must provide a schedule to renovate the aeration basin initially. While the SOC is being processed, Mt. Airy should submit a NPDES modification request for an interim flow of 4.8 MGD or that flow which will be needed until the upgrading to 7.0 MGD is completed. We can verify what limits will apply at that flow and reissue the permit with the revised limits which will be slightly less stringent than at the permitted flow of 7.0 MGD. When renovation of the aeration basin is completed and the City achieves final limits that apply at the interim flow, the SOC could be voided. At that point, Mount Airy can accept additional industrial flows that are compatible. The toxicity limit will be in effect and enforced except for the life of the SOC. It is suggested that the City begin immediately to conduct a toxicity treatability study on the type of additional wastewater flow expected from Quality Mills. You indicated that Mount Airy would need about 6 months to conduct a phase 1 data compilation of a toxicity reduction evaluation. It is felt that four (4) toxicity failures in 1989 are enough reason to proceed with that study now. With regard to the permit condition on expansion to 7.0 MGD and compliance with whole effluent toxicity limitations, I must add to my comments in the letter dated August 28, 1989, to Mr. Jerry Cox. My decision to withdraw the permit clause will be based on the city's commitment to submit a treat - ability study on Quality Mills additional waste data compilation for toxicity reduction. The SOC will have a schedule for these item. Gordon C. Ruggles Page #2 October 24, 1989 Your suggestions for an SOC schedule appreciated. If you have any questions on not hesitate to contact Trevor Clements at Steve Mauney at (919) 761-2351. Sincerely, will be this matter, do (919) 733-5083 or R. Paul Wilms Director cc: Mr. Jerry Cox Mr. Trevor Clements Mr. Dale Overcash Mr. Steve Mauney Central Files HAZEN AND SAWYER, P.c. O CONSULTING ENGINEERS t October 3, 1989 �. RU„ 4 L Mr. R. Paul Wilms OU 13A989, Director North Carolina Division of TECHNICAL SUPPORT BRANCH Environmental Management P.0_ Box 27687 Raleigh, NC 27611-7687� Re: City of Mount Airy WWTP ttt NPDES Permit No. NCO021121 Whole Effluent Toxicity Limits Dear Mr. Wilms: We have been authorized by the City of Mount Airy to present technical approaches for resolving whole effluent toxicity and other issues related to expansion of the Mount Airy Wastewater Treatment Plant. The City has an interest in working with the Division of Environmental Management in resolving these issues under an alternative that does not pre —condition a permit for plant expansion on achieving compliance with whole effluent toxicity. Although it is concerned about the potential for whole effluent toxicity at its wastewater treatment plant, the City will need time for further study to allow it to deal with the problem. In the meantime, decisions must be made relative to commitments for substantial industrial expansion within the City. Given the circumstances, the City feels that a Special Order of Consent approach would be a more suitable alternative for dealing with this issue. In the past, the Mount Airy Wastewater Treatment Plant has experienced several distinct trends in effluent toxicity as indicated by the Ceriodaphnia chronic effluent bioassay procedure. From February, 1987 through July 1988, the effluent passed 6 of 7 quarterly tests. The single failed test occurred in March, 1988. Three quarterly tests in a row were then failed for a period from October, 1988 through April, 1989 when monthly testing was initiated. Monthly tests for May and June also failed. However, the most recent tests in July and August suggest that a passing trend may have been re—established. Reasons for the variations in trends have not been determined and will require monitoring before assessments can be made. Additionally, proposed plant modifications will improve treatment and may alter these trends. To address these two aspects of effluent toxicity, the following steps can be taken by the City under the Special Order of Consent: 400D WESTCHASE BOULEVARD . SURE 550 . RALEIGH, NC 27607 . )919) 833-7152 FAX )919) B33-1828 RALBGK NC CHAiLOTTE NC NEWPORT NEWS VA HOLLYWOOD, FL NEW YONK NY Mr. R. Paul Wilms October 3, 1989 Page 2 Perform a follow—up monitoring program as a continuation of toxicity evaluations originally performed by Burlington Research, Inc. in May, 1986. Perform pilot plant testing to assess the effect of proposed plant modifications on effluent toxicity. If a failing trend becomes re—established, additional steps can be taken under a phased toxicity reduction evaluation that could be initiated upon notification of the City by the Division of Environmental Management of a need to proceed with this program. Phase 1, the initial data compilation phase of the program, could proceed immediately upon notification and could be completed within 6 months of the notification date. This phase would consist of data collection of chemical usage by industries with assessment of potential toxicological properties and detailed review of possible relationships between operating/performance characteristics at the WWTP and effluent toxicity. Based on the results of Phase 1, tasks and schedules for any subsequent phases of evaluation will be developed for review and approval by the Division of Environmental Management. If the proposed pilot testing program indicates a potential for substantial improvement in effluent toxicity upon completion of the proposed plant upgrade, toxicity reduction evaluations would be deferred until the upgrade has been completed. Under this condition, there would be limited value to performing toxicity evaluations for the interim conditions that would occur prior to upgrade. Under the Special Order of Consent, the City of Mount Airy would also need variances from the existing permit limitation of 4.0 mgd on a maximum monthly basis to a revised interim limit of 4.8 mgd until the plant can be fully upgraded. These increases are needed to accommodate ongoing industrial expansion that is vital to economic growth both within the City and this region of North Carolina. To date, the plant has treated maximum monthly flows up to 4.1 mgd in conformance with effluent requirements of the existing permit. It was originally designed for a much higher organic loading (375 mg/l BOD5 for design vs. existing BOD5 of 224 mg/1) than is presently being experienced and evaluations of unit hydraulic loadings indicate they can also be maintained within desirable ranges as indicated by the following: Unit Process Hydraulic Loading at 4.8 mqd Primary Clarifiers 600 gpd/sq.ft. (with 3 mgd recycle) Aeration Basin 2.1 days detention Secondary Clarifiers 630 gpd/sq.ft. Chlorine Contact Basins 41 min. detention HAAZENN AND SAWYER P.c Mr. R. Paul Wilms October 3, 1989 Page 3 If necessary, polymer feed can be added to the aeration basin effluent to improve settleability in the secondary clarifiers. Hydraulic improvements, primarily in the form of increased capacity for the raw sewage and intermediate pump stations, would be required to accommodate the increased flow for this interim time period. Also, as a part of the Special Order of the Consent, planned modifications for upgrade of the aeration basin can proceed most efficiently if the existing basin can be removed from service for an interim construction period (perhaps 4-6 months). During this period effluent would still receive secondary treatment on the trickling filters and settleability could be enhanced by polymer addition. However, some excursion in effluent quality beyond permit limits may occur under this interim construction condition. Interim limits based on the treatment levels obtainable with trickling filters would be appropriate. Please let us know if we can answer any questions. Sincerely, HAZEN AND SAWYE P.C. d G rdon Cice— resiRu es, P.E. Senior Vdent GCB:er cc: Mr. Jerry Cox Mr. Trevor Clements Mr. Dale Overcash Mr. Steve Mauney HAZEN AND SAWYER PC J DIVISION OF ENVIRONMENTAL MANAGEMENT September 26, 1989 MEMORANDUM TO: Steve Tedder FROM: Trevor Clements S SUBJECT: Meeting with City of Mount Airy A meeting was conducted on September 20th with representatives of the City of Mount Airy and their consultant, Hazen & Sawyer, to discuss the City's con- cern over the condition in their NPDES permit that requires compliance with the whole -effluent toxicity requirement prior to expansion of their wasteflow. The City of Mount Airy plans to expand from 4.0 to 7.0 MGD, with the major source of additional wasteflow expected to come from Quality Mills, a textile corporation. Mount Airy officials would like to have the toxics condition deleted from their NPDES permit. The City would also like to have DEM increase the design capacity rating to handle first phase expansions of Quality Mills (approx. 0.5 MGD) using the existing treatment facility. DEM staff want assurances that appropriate steps are being taken by Mount Airy to address their current toxicity problem (testing record attached) before potentially adding to this problem with expanded sources of industrial wasteflow. Available options to Mount Airy were discussed. DEM staff recommended that Mount Airy perform a treatability study on the additional wastestream to be added by Quality Mills. It was also recommended that the City begin testing at their future instream waste concentration (IWC) to determine whether the City can expect to be in compliance upon expansion. Mount Airy was advised to submit the necessary information for DEM to evaluate a change in the design flow capacity rating as soon as possible. Alternatively, the City was told it could pursue a Special Order for this interim flow increase to provide legal relief from the toxicity permit requirement. However, DEM staff pointed out the poten- tial for the State to withhold approval of a flow increase for industrial type waste during the effective period of the Order unless it could be demonstrated that the toxic substance concentrations of the additional industrial wastewater were not significantly different from those associated with domestic wastewater. It was made clear that Mount Airy would like an administrative answer to this latter issue. If industrial source flow increases would not be allowed under an Order, then the City will probably not want to pursue this avenue. You, Dennis Ramsey, Steve Mauney, and myself should discuss this matter at your earliest convenience. Please let me know if further information is required. cc: Tom-Stockton-1 Ken Eagleson Dennis Ramsey Steve Mauney WHOLE FJTLUl�_,OXICITY 7FSTL\G 0jSELr-N10Nrr0RRJGSUMMARYj h1on,Sep18,1989 NPDE9I: N'COW3]19 PERMfTAe LNPNa Ac(Q),SAMON-Md 85 Cowry: CUMBERI.AN'D Rcgio.: FRO Begrc 1011/87 F1O -.. Q. SA - 86 - _ PF:0.73 SOC/JDC Reel: Mmt c 87 - _ 7Q10:791.0 MCI%):1.40 88 (34,4) _ MOOKEIDE59 COVNCD[u750a p Ir:RMIT CIMONIC I,Ml 40.6V. 89 NONE Ce-1Y: MOORE 08 Cowry: MOIRE IktinS/1/tl] I _ 83 PP:6JU R<[im: FRO M-O :JU SEP DEC MAR 87 - SOC/IOC Re, 7Q]0: 11.2 IWC(R):40.N 89 - MOORESVILLE WWPP PERMIT O2MON1C LIME%% 89 - NPDESY:N(AM6778 Cowry: IIFDELL &ti.4/1/89 A<grenry. Q P/P A 85 PP; 5 Ratim: MRO O M-: FEB MAY AUG NOV 86 87 _ A SOCJ10C Req:' _ 7Q I0: 03 IWCM):94.I5 88 - _ MORGANfIE, INC -PS 89 PAR _ NFDESY: Nc)06Ql47 CIMONIC IJMIT:99i 85 Covey: IIARNTJ, Retim: PRO &tve IO'V88 Q P/P 86 PP: O.Om Mmfh.: JAN APR JUL OCf SOCOOC Rey: 87 7010:0.00 IWC(%):100.00 88 40RGANION WM-ry 89 PASS _ FOE . NO S[: MW7] PERMIT CHRONIC LLMIT:9.m 85 CowBVRI(E ry: Rctim: MRO Bcte 17/IR7 86 PP; 600 JAN APR JUL OCT 87 - SQ�QC �� - ]QIO:Im.00 IWC(A):8.96 88 PAB, _ 40RRISVI3E WW 89 PASS _ YOFS4: 9]8 ERROR POUND W/ SAMPLE COLLEC7DON WAKE 7W Rcgim: RAO Bcg� 008)gg0 "ry'D 85 86 PP: PP: 0. Ov Mm: SOXOC �;oo.Bo 87 7QIo: o.00 oo Iwc(%)a T° - - W Wry.CRABTBPE 89 NO)OS0IETPFR CT IRONIC TARGFT:]89: EMORRWSVILLE WAKE Resrm: RRO Oeti.c 5/1/88 Fiagrc- M PA' 86 PF: 0.w Mmfh[: SOg10C Req: 8] 7010:0.50 fWC(A ):JA.2) 88 _ 89 NR PERMIT CIM LI.NIP:32%.42R r�[ �4 MGD d IT Pegim:WSRO Iktirc]/I"9 F'M.rc QL 6 85 eb 15.69 ,: MmJrl: /Ul, OCT IAN APR SOCnOC Re, NR0 87 NR.9 N!C(9: ):42.09 88 - ME. MOLLY W W p 89 FAR, NP 156 PERMIT CHRONIC LI,MIT:6.1 % .ly: GASTONCImi Cowry: GASTON Regim: MRO Retire 4/1/88 �9rc^cY: Q PIP 83 86 PF: LIp MmJu: MAY AUG NOV PER 87 7Q10: 95.W IWC(R):6.10 SOCAOC Req. 88 - W.OLNEPICRLE 89 _ SPDFSA: NC) I074 PERM IT CIMON IC UMIT:99G Cowry: WAYN'E Rcgim: WARD Nzin 111AS �9"cnn' Q P/P 85 86 PF:O. M-J': FED MAY AUG NOV SQC/IOC Re, 87 19 7Q10: 0.W00 M'C(R):100.p0 88 (I6) TO _ - x0.a 19.9 40.8- NR (34,1) - - 68.7 - - PAR. _ (FAO.) (.-) PASS br ( ) ... FAIT. (FAIL) _ NR - PASS FAO, _ FAO, b-) TAIL - FAIL SR (PAIL) _ _ (PASS) _ - PASS _ P-) FAO. _ NR FAIL _ NTR PASS PASS PASS - _ R WAIa PASS x) - PASS - NR NM PASS NR NR NR NlR NR NR NR Nx NR NR NR - - m2 52.9 13.19 55.99 39.07 90 2143 4L8 I'4N SS.A 16 7331 43.89 77,P NO.NEF P40 89.99 (PASS) NONE _ P30 NOSI;F 1'IS/i° - (PAIL) PASS _ I- I, PASS - _ (PA." (PASS) _ _ mv:t) - - PAIL FAIL PAII. PASS - I71I1. - - PASS _ NR ) NGSIi ("') NONE PASS _ NR - - PASS10 _ 32 22 hR 23 RP 19 14 - NR 10.5 (IAS) 13 U 3.0 NIt NR - NR _ 6-) - \R NR _ 9 2<uuc<c 6.<faJwe.. Jgni6<uv nm.aml.•.. ILGf%m 1'F•Rr ON, dl,G,7Q10=Rc<civine.�unlo.0o. vi¢rim(cf.), IWc%-I cunvulc cm cent.fim,8etin.FinlmmOr rcy.ir.J. 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C7eM-ACNAiT.Xfcvlob`t ?33-Z13� 1f is ii II i I, fi I Ant *its CA� (T3$ i • II `G crf ROA4A�� - %/eq j 1_^t\ p�, (/tv uou� CA a 4-, o G C7 V do 1 444 State of North Carolina Department of Natural Resources and Community Development Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor R. Paul Wilms William W. Cobey, Jr., Secretary Director August 28, 1984 Mr. Jerry Cox, City Manager City of Mt. Airy P.O. Box 70 Mt. Airy, North Carolina 27030 Subject: City of Mt. Airy WWTP NPDES Permit No. NCO021121 Whole Effluent Toxicity Limits I am writing in response to your letter sent June 7, 1,989, concerning the NPDES permit conditions regarding design capacity expansion and compliance with whole - effluent toxicity limitations. Efforts.i.n resolving your facilities effluent toxicity are evident. The qualifying condition in Limitation Chart A was not intended to preclude expansion of the facility, but rather, states that upon expansion of the facil- ity, the City must demonstrate progress in toxicity reduction prior to accepting increased flow. The Division will consider deleting the qualifying phrase on the permit if the City agrees to enter into a Consent Order with a schedule for compliance with the whole -effluent toxicity limits. Under the order, flow addi- tions will be restricted to domestic wastewater until compliance with whole - effluent toxicity limit is consistently achieved. For the purpose of evalua- tion, this will mean achieving a "pass" result on 3 consecutive toxicity tests taken not less than one month apart. I hope that this letter adequately addresses your concerns. However, if the above decisions are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statues, and filed with the Office of Administrative Hearings, Post Office Drawer 11666, Raleigh, North Carolina 27604. Unless such a request is made, this decision is final and binding. Pollution Prevention Pays P.O. Box 27697, Raleigh, North Carolina 27611-7687 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer If.you have any questions or comments regarding this matter please contact Mr.Trevor Clements or Mr. Dale Overcash from my staff at (919) 733-5083. inc e , R. Paul Wilms cc: r-Trevor--Clements Dale Overcash Steve Mauney Central Files NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES bFI5 COMMUNITY DEVELOPMENT' DIVISION OF ENVIRONMENTAL MANAGEMENT �ECEI Dt-j¢ Winston-Salem Regional Office 04 JUL 1989 July 10, 1989 PERMITS &EN�,RINL=,_RI M E M O R A N D U M TO: Arthur Mouberry, Permits & Engineering THROUGH: Steve Mauney, WSRO Water-Quality.Supervisor FROM: Abner Braddy, Environmental Technician SUBJECT: City of Mt. Airy 89/06/07 Letter to Paul Wilms Draft NPDES #NC0021121 (Expansion) Mt . , Airy WWTP Su.rry County We have reviewed the subject letter and offer the following comments:. 1. The subject permit application requested modification to the existing permit for upgrading and expansion of the facility from its•present"4.0 MGD capacity to an eventual capacity of 7.0 MGD. It is our understanding that the bulk of any permitted flow increase would be -to accommodate a local textile manufacturer, Quality Mills, Inc., with expansion plans which would result in an additional 2.0 MGD of influent"to the P.O.T.W: It is also our.understanding that Quality Mills, Inc. is at present the largest Industrial User tributary to the facility, supplying.approximately 1.1 MGD of the 3.1 MGD average daily flow currently treated by the facility 2. The facility failed the last three (3) chronic toxicity tests, in January, April, and May of 1989. Since the proposed increase in flow would raise the facility's In -Stream Waste Concentration from 32% to 420, any existing impact to the receiving waters would be magnified, given a static percentile of plant efficiency. The Region feels that it would be imprudent to allow a major increase of industrial flow to become tributary to the plant prior to resolving the current toxicity problem. a f d f' `a Arthur Mouberry Page _# 2 July 10, 1989 3. We do not dispute the city's contention that past actions on their part have resulted in apparent toxicity reductions. As noted previously, however,,the problem, has begun to recur. The past successes achieved"do`arot have a direct bearing on the current problem.. 4. The wording in Limitation Chart A does not state that the "proposed expansion project is hinged upon'resolution of the chronic toxic situation.' Nothing in the wording precludes expansion of the facility, but rather�,.-states that upon expansion of the facility,"the City must demonstrate progress in't�oxicity reduction,rprior, to accepting increased. flow.. As "ther-,life of the project is estimated` by the City' sv, engineers" to be. thirty to t*hi rty`''six:months, we see`no reason that 'a thorough T.R'E: cannot proceed jointly>w th the plant expansion.,- During the expansion,.when components 'of the .plarit become functional, incremental flow increases 'could be considered if' toxicity;. -reduction.: is. demonstrated.,,_ 5. As,toxicity monitoring requirements are contained in s the ' facility' s current.. NPDES­:tpermit ( reopened June 1, 1987), and as the facility'is not meeting conditions which constitute a successful test, the facility is technically in non-compliance with its existing permit. Issuance of the draft permit. as is, therefore, would not impact the facility's compliance status: CITY OF MOUNT AIRY o. &. 70 Cnrolint( 27030 Mr. R. Paul Wilms, Director Water Quality Section NC Department of NRCD, DEM 512 North Salisbury Street Raleigh, NC 27611 Dear Mr. Wilms: June 7, 1989 I am in receipt of NPDES Permit NNCO021121 and after reviewing it with nw staff, I respectfully make comment on the following: Limitation Chart A: It appears that our proposed expansion project is hinged upon reso ution of the chronic toxic situation at our facility. Mount Airy has been involved for some time with toxic reduction evaluations. We were one of the first municipalities to have substantial reduction in static toxicity due to the deletion of certain compounds from our waste system (LC50 21.43% on June 26, 1986 to LC50 90% on July 31, 1986.) Volun- tary chronic toxicity testing was started on October 29, 1986 and continued through June 17, 1987 with five (5) evaluations passing and two (2) evalua- tions failing. In July 1987, quarterly testing was added to our permit. Since that time, nine evaluations have been conducted with four (4) passing and five (5) failing. Given the above information, I think that .the City's stance on the toxics issue is clearly defined. We intend to exercise every option available, as before, to clear up any problem that we may encounter in the future. In light of these facts and after consulting with plant personnel, our consulting engineering firm, and the commercial laboratories involved.with chronic toxicity TRE's, we7�:rerpectfullly-request--that the: word ing>with, :regard.,_to:,:the- toxicityjss&e_be'structured:'in`a:.way.,:that will not::require-it'to be=resolved prior to plant expansion ---nor 'placethe=City 1 ninon -compliance as="long'as' efforts=are'berng`made to-resolve`th'is issue;. Thank you for your assistance and consideration in this matter. JEC/db xc: Mr'. Arthur Mouberry Mr. Steve Mauney, Regional Mr. Abner Braddy, Regional Mr. Gordon Ruggles, Hazen Sincerely, ry E . 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