NC0021211_SPECULATIVE LIMITS_19980518

NPDES DOCUWENT SCANNING COVER SHEET
NPDES Permit: NC0021211
Graham WWTP
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
201 Facilities Plan
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: May 18, 1998
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State of North Carolina
Department of Environment
AA
and Natural Resources , / • e
Division of Water Quality
James B. Hunt, Jr., Governor 40�OT
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
May 18, 1998
Mr. Chris Rollins, City Engineer
City of Graham
P.O.Box 357 -
Graham, North Carolina 27253-0357
Subject: Speculative Discharge Limits
City of Graham WWTP
NPDES Permit No. NCO021211
Alamance County
Dear Mr. Rollins:
As follow-up to our March 31,1998 meeting,I would like to offer a correction to the speculative limits described in
the Division's March 27, 1998 letter. Also,the City of Graham asked us to comment on the first phase of a two-phase
proposal to upgrade and, eventually, expand the wastewater treatment facility.
Based on the implementation of House Bill 515 (the Clean Water Responsibility Act), nutrient limits will be given
as an average of daily values over a calendar year. Therefore, the appropriate total nitrogen and total phosphorus
limits for the City of Graham are 161 pounds per day and 58 pounds per day, respectively. It should be noted that the
City of Graham will have to meet these limits by January 1,2003 even if there is no expansion in permitted flow. A
letter is being drafted to all discharges into nutrient-sensitive waters which will explain this. This correspondence
will be sent in the near future.
Graham also described the need for improvements to the existing treatment system including eliminating a
hydraulic restriction caused by the final clarifier design as well as the need for additional solids processing
capability. As presented in the March 31, 1998 meeting,these upgrades would not necessitate a request for permit
limits above the currently permitted 3.5 MGD. This being the case, there will not be a need for the re-opening of this
permit based on the described work. Once permitted capacity needs to be increased beyond the permitted flow,then a
permit modification will be required. Please note that any application for such an expansion must be made after the
Division issues a Finding of No Significant Impact (FONSI)for the project as mandated by the State Environmental
Policy Act. For more information on these requirements,please contact Mary Kiesau at(919)-733-5083,ext.567.
I apologize for the confusion in providing you with speculative limits for nutrient restrictions in the past. If you
would like to discuss this matter,please don't hesitate to contact me at telephone number (919)-733-5083,ext. 517.
Respectfully,
David A. Goodrich
NPDES Unit Supervisor
cc: Central Files
Jim Johnston,Winston-Salem Regional Office
Mary Kiesau
NTPDES_Uf ifl?ermit-Files
P.O.Box 29535,Raleigh,North Carolina 27626-0535 Telephone [phone] FAX [phone] .
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State of North Carolina
Department of Environment "j
and Natural Resources AT
Division of Water Quality
James B. Hunt, Jr., Governor �®
Wayne McDevitt, Secretary N
A. Preston Howard, Jr., P.E., Director
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-COMM. JOURNAL- ******** DATE MAR-27-1998 ***** TIME 14:56 **** P.1
MODE=TRANSMISSION START=MAR-27 14:53 END=MAR-27 14:56
FILE NO.= 445
NO. COM RBBR.NO. STATION NAME/ PAGES PRG.NO. PROGRAM NAME
TELEPHONE NO.
01 OK 93368555648 04/04
-DEM WATER QUALITY SECTION-
919 733 9919- ***********

State of North Carolina
Department of Environment
and Natural Resources / • •
Division of Water Quality
1�V�
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary C) E N F1
A. Preston Howard, Jr., P.E., Director
Facsimile Cover Sheet
To:
Fax: --�
From: - $ 6/'
Phone: [phone] extension
Fax: [phone]
pages, including this cover sheet.
Comments:
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*********************** * -COMM. JOURNAL- ******** DATE MAR-27-1998 ***** TIME 15:09 **** P. 1
MODE=TRANSMISSION START=MRR-27 15;05 END=MAR-27 15:09
FILE NO.= 447
NO. COM RBBR.NO. STATION NAME/ PAGES PRG.NO. PROGRAM NAME
TELEPHONE NO.
01 OK 93362289362 04/04
-DEM WATER QUALITY SECTION-
919 733 9919- ***********

NORTH CAROLINA DEPARTMENT OF
' ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
March 27, 1998
NC®ENR
Mr. Chris Rollins
JAMES B.HUNT JR. City Engineer
GOVERNOR P.O. Box 357
Graham,NC 27253-0357
Subject: Speculative Discharge Limits
WAYNE MCDEVITT City of Graham WWTP
SECRETARY
NPDES No. NC0021211
Alamance County
A.PRESTON HOWARD,
JR.,PE. Dear Mr. Rollins:
DIRECTOR
Reference is made to the request, submitted by David A. Hamilton, P.E. of
Finkbeiner, Pettis & Strout, Inc., for speculative limits for the proposed expansion
of the City of Graham wastewater treatment plant (WWTP). We are hereby
supplying limits that would currently be assigned to the WWTP if the plant
capacity were increased from 3.5 to 5.0 MGD at the current discharge point in the
Haw River.
The current Haw River discharge site has a drainage area of 614 square miles
and a corresponding 7Q10 flow of 39.1 cubic feet per second, according to the
most recent estimate from the U.S. Geological Survey (USGS). The discharge
location is within the Jordan Lake watershed, which is classified as Nutrient
Sensitive Waters (NSW). In 1983, the Environmental Management Commission
adopted an NSW strategy which included total phosphorus limits for all new and
expanding discharges in order to reduce nutrient loading to Jordan Lake and
prevent nuisance algal blooms. More recently, in August, 1997 the North
Carolina General Assembly passed HB515 which provides for controls on total
phosphorus and total nitrogen. The bill requires that facilities discharging greater
than 0.5 MGD to surface waters of the State which are classified NSW to meet
total phosphorus and total nitrogen annual mass load limitations based on
concentrations of 2.0 mg/I and 5.5 mg/l, respectively. The Graham WWTP will
Llq� fall under the jurisdiction of HB515 and will be assigned annual mass load limits
of 21,300 Ibs/yr for total phosphorus-and 58.600 lbs/yr for total nitrogen at
3 �V® permitted waste flows of 3.5 or 5.0 MG. I
J R�
G VIA The remaining limits, applicable to the Graham WWTP discharge, would be
i assigned as follows:
P.O.BOX 29535, RALEIGH,NORTH CAROLINA 29626-0535
PHONE [phone] FAX 919-J33-9919
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-5050' RECYCLED/1 Oq POST-CONSUMER PAPER
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Parameter Units Limits (30 day ave.l
BOD5 (Sum/Win) mg/1 8/16
NH3N (Sun/Win) mg/1 3/6
DO (minimum) mg/1 5.0
TSS mg/1 30
pH SU 6.0-9.0
Fecal Coliform /100 ml 200
Residual Chlorine ug/1 28 (daily max)
A whole effluent toxicity test (WET) requirement with quarterly monitoring will
remain a condition of the NPDES permit. As in the existing permit, the WET test
required will be a 7 day chronic (Ceriodaohnia) test with a pass/fail limit at a test
concentration of 17% for a design flow of 5.0 MGD. In addition, a complete evaluation
of limits and monitoring requirements for metals and other toxicants will have to be
addressed at the time of formal NPDES application.
Under current DWQ procedure, dechlorination and chlorine limits are now required
for all new or expanding dischargers proposing the use of chlorine for disinfection. The
level of residual chlorine in your effluent necessary to ensure against acute toxicity in the
Haw River is given above. The process of chlorination/dechlorination or an alternate
form of disinfection, such as ultraviolet radiation, should allow the facility to comply
with the total residual chlorine limits.
As you may know, DWQ has adopted a whole river basin approach to water quality
management and protection, and the current Cape Fear Basin Plan was completed in
October 1996. The plan indicates that DWQ will be developing a field calibrated water
quality model for the Haw River from Reedy Fork to Jordan Lake. At this time data
collected on the River are insufficient to calibrate the model. The area of the Haw River
watershed in question has several major wastewater treatment facilities with a combined
discharge volume of 75 MGD, which results in a cumulative instream waste
concentration of about 59% during 7Q 10 low flow conditions at Saxapahaw. However,
all available data indicates that the instream dissolved oxygen (DO) levels in the
Burlington/Graham area of the river are typically well above the North Carolina
(minimum) daily average standard of 5.0 mg/l. As a result of these conditions, the limits
given herein for oxygen demanding parameters are based on no net increase in pollutant
loading from the current wasteload allocation for the Graham WWTP.
Once completed, the Haw River model will address the cumulative impacts of
oxygen demanding wastewater discharges in this area of the watershed. As a result, more
stringent limits than those presented in this letter may be required for Haw River
discharges in order to maintain water quality standards for dissolved oxygen levels
instream. The City of Graham may want to consider the possibility of more stringent
limits for oxygen demanding wastes when planning its WWTP design.

Please be advised that response to this request does not guarantee that the Division
will issue an NPDES permit to discharge treated wastewater into these receiving waters.
It should be noted that a new facility involving an expenditure of public funds or use of
public (state) lands and having a design capacity of 0.5 MGD or greater (or a facility
proposing an expansion of 0.5 MGD or greater), or exceeding one-third of the 7Q]0 of
the receiving stream will require the preparation of an environmental assessment (EA) by
the applicant. DWQ will not accept a permit application for a project requiring an EA
until the document has been approved by the Department of Environment, Health and
Natural Resources, and a Finding of No Significant Impact (FONSI) has been sent to the
state Clearinghouse for review and comment. The EA should contain a clear justification
for the proposed facility and an analysis of potential alternatives, which should include a
thorough evaluation of non-discharge alternatives. In addition, an EA should show how
water reuse, conservation and inflow/infiltration reductions have been considered.
Nondischarge alternatives, such as spray irrigation, water conservation, inflow and
infiltration reduction or connection to a regional treatment and disposal system, are
considered to be environmentally preferable to a surface water discharge. In accordance
with the North Carolina General Statutes, it will be required that the practicable waste
Ytreatment and disposal alternative with the least adverse impact on the envirorunent be
lemented. If the EA demonstrates that the project may result in a significant adverse
jafect on the quality of the environment, an Environmental Impact Statement would be
uired. Michelle Suverkrubbe of the Water Quality Planning Branch can provide
further information regarding the requirements of the N.C. Environmental Policy Act.
Please note that the limits given herein are speculative and are not binding unless
they are part of an issued NPDES permit. All information pertaining to this request has
been sent to our Central Files for storage. If it becomes necessary to request an NPDES
permit, please submit a complete application package including fees appropriate for that
point in time.
If you have any questions, please contact Jason Doll at [phone], extension
507.
qaLLces
Water Quality Section
cc: David A. Hamilton, P.E. —Finkbeiner, Pettis & Strout, Inc.
Winston-Salem Regional Office
David Goodrich -NPDES Unit
Lisa Martin—Local Government Assistance Unit
Central Files