NC0024228_Acknowledgement of Comments to Draft Permit_20130404

•
RECEIVED
N.C. Dept. of ENR
��—
NCDENR
APR 1 1 2013
North Carolina Department of Environment and Natural Resources R lg;ooui of e
Division of Water Quality
Pat McCrory Charles Wakild, P. E.
John E. Skvarla, III
Governor Director
Secretary
April 4, 2013
Mr. Phil Sloan
193 Flay Cecil Road
Thomasville, North Carolina 27360
Subject: NPDES Permit Modification
Permit NCO024228
City of High Point
Westside WWTP
Davidson County
Dear Mr. Sloan:
Thank you for your comments on the draft permit for the Westside WWTP in a letter dated March 14,
2013. Your comments will be considered in the final draft of this permit. At this time, the permit is
being reviewed by US EPA, Region IV, in Atlanta, Georgia. The EPA's review may take as long as
90 days. Once we receive their review comments and can proceed forward we will inform you as to
what changes are made to the final permit and respond to your comments.
If you have any questions concerning this permit, please contact me at [phone] or by email
O [e-mail]).
Respectfully,
ulie A. Grzyb
Environmental Engineer, NPDES Complex Permitting Unit
cc: NPDES file
e-copy:
Matt Mathews, SWP
Jeff Poupart, SWP
WSRO, SWP —.,roo ++an s
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.nmaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolina
Adar°allry

March 14, 2013
Julie Grzyb
Environmental Engineer, Complex NPDES Permitting Unit
Subject: City of High Point, WWTP expansion
Dear Ms. Grzyb,
Thank you for sending me a copy of the draft permit for High Point's planned Westside Wastewater
Treatment Plant expansion. As a resident of northeast Davidson County for the past 47 years, I am only
too aware of the ongoing problems that High Point has had with WWTP and am happy that they are
(finally) being required to address them, with odor abatement being at or near the top of the list.
However, I strongly object to the City of High Point (CHP) being allowed additional discharge capacity at
WWTP for the following reasons:
First and foremost, it is NOT NEEDED and CHP's own figures prove it. Under NCDWQ's "80/90" rule,
municipalities are required to plan for wastewater plant expansions when their average daily discharge
amounts reach 80% of their licensed capacity. With a current limit of 6.2 mgd (million gallons/day), High
Point hit this "trip point" of 4.96 mgd at some period around 2004-2008. At this time, they were
operating under a "special order of consent" (SOC) requiring them to replace extensive sections of their
aging, decrepit, and (as it turned out) massively leaking outfall lines. When these lines were replaced,
WWTP's average daily discharge dropped to its current 3.9 to 4.0 mgd, or approximately 65% of its
licensed capacity. And, as anyone with common sense can figure out, if the lines were allowing a million
gallons/day of creek "inflow", during periods of flooding, these same holes/breaks in the outfall lines
were allowing (who knows how much?) untreated sewage to be discharged into Rich Fork Creek and its
tributaries.
Enclosed is a copy of page 2-2 from the November 2010 Hazen and Sawyer study, commissioned by CHP.
Notice that this chart, in the section (at top) "Need for the Project" and used by CHP as justification for
expansion of WWTP, shows a 2010 projected flow of 5.52 mgd, roughly 40% higher than today's actual
flow. In the paragraph below the chart, note that the actual flow for 2009 is listed as "3.6 mgd"; how
and why did they project an increase of almost 2 mgd in flow from 2009 to 2010? 1 live here and I can
assure you that there are no new subdivisions or industries (don't we wish) of any consequence that are
being built; nothing to logically justify such a "pie -in -the -sky" projection, unless you consider the
possibility of bureaucratic pressure to get the desired result from a paid study.
Second, as noted on page two of your 2/13/2013 letter to Chris Thompson (CHP's directo
C
services), Rich Fork Creek is listed as an impaired waterway on the 2012 NC Impaired Wat
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001ist. kwal L!�►�
not aware when the environmental impact public comment period was held for this expai
o: ands;
realize that the FONSI (finding of no significant impact) has already been issued, but I hav
icultg"
believing that Rich Fork can even handle WWTP's current discharge, as the enclosed photl
ow.W-�-
These are from a series of pictures shot in September of 2005 or 2006 (I don't recall whic
theoi
drought" year) and show a basically dry streambed until you get to the WWTP effluent diage
pipe,
where there is so little stream flow that the effluent "flows" both upstream and downstre
nR lluu
noticed that on the bottom of pages 3, 4, and 6 of the draft permit (#NC0024228) are the
shall be no discharge of floating solids or visible foam in other than trace amounts." As you
can see in

the close-up photo of the discharge pipe, foam is literally covering the entire width of the stream surface
opposite the pipe and a considerable amount of the stream surface both up and down stream for fifty to
sixty feet. If this is the situation with a 4 to 5 mgd discharge, how is this waterway expected to handle
flows up to twice that amount (CHP is requesting an eventual licensed limit of 10.2 mgd)?
In closing, I have one suggestion and one observation. The suggestion is that DENR publicize
environmental impact hearings in a broader fashion. DENR's website and the classified ads are not on
most people's regular reading lists; perhaps having small "roadside signs" along major thoroughfares in
the affected area would be a better/more thorough way of getting the word out. I don't know if the
current method is a legislatively mandated or a departmental policy, but the more people are aware of
these hearings, the less the "blow -back" after the FONSI has been issued.
The closing observation is that, while I realize that a city's budget issues aren't typically a major concern
of DENR, in these times of tight budgets, for citizens and government agencies alike, a major outlay for
an unnecessary project is detrimental to all concerned. Case in point: the enclosed article from this past
Sunday's High Point Enterprise quoting the city manager's struggle to balance CHP's budget. His budget
includes the WWTP expansion ($28 million, according to sworn testimony given at the Davidson County
public hearings), but no explanation of why this is prioritized above other expenditures.
High Point has had odor and raw sewage discharge problems from Westside for years, if not decades.
They have a moral and legal obligation to correct these problems and, to a large degree, they seem to
be on the righttrack to doing so. However, to demand that DENR give them increased discharge
capacity, as a condition for doing what they should have done years ago, amounts to blackmail. With
the state annexation law requiring a vote by citizens of the affected area, High Point is not likely to ever
need this increased capacity; as such, this is an unneeded expense with no apparent benefit either to
the citizens of High Point or Davidson County.
Thank you, _Akf *6"_
Phil Sloan, 193 Flay Cecil Road, Thomasville, NC 27360
Cc: Mr. John Skvarla, Secretary of DENR

Environmental Assessment for
Westside Wastewater Treatment
Plant Expansion
Need for the Project
2..2 Wastewater Demand Projections
fbw projections were developed in the EAA using guidelines prepared by DWQ Construction
and Loans Section (CG&L). Residential and commercial flows were estimated using 70 gallons/day
aa (gpcd) and 15 gpcd, respectively. Current industrial flow and inflow/infiltration (1/1) were based on
data Ciected for the PER. Industrial reserve was calculated as 10 percent of the existing industrial and
carnrr�-_l flow. Table 2-2 provides the projected average annual and maximum month wastewater flows
tnm 2Z" u to 2030. The 2030 average annual daily flow for the Westside service area is anticipated to be
-7:99 7,aid. The 2030 maximum month flow is anticipated to be 10.39 mgd. The Westside WWTP will be
aeskred for a maximum month flow of 10 mgd.
,a IV - al -
Tabie 2-2: Wastewater Flow Projections for the City of High Point Westside WWTP Service Area
Average Maximum
Residential Commercial Industrial Infiltration / Annual Flow, Month
Year Flow. mad' Flow. mad' Flow. madInflow, mad' mad' Flow.'
1.50 1.12 0.33
2.57
5.52
7.18
1.84 1.20 0.38
2.57
5.99
7.78
2.26 1.28 0.43
2.57
6.55
8.51
2.80 1.40 0.49
2.57
7.26
9.44
3.35 1.52 0.56
2.57
7.99
10.39 z
=sgineenng Alternatives Analysis (Hazen and Sawyer, 2009).
- _iwW be designed for a maximum month flow of 10 mgd.
r=i5 �%i�s• a.4
i ► � � } F�... �. � {eta tf i.rC
2-3 Ming Facilities
ateT for the entire City of High Point service area is treated at either the Eastside or the Westside
' � --e Eas=.side WWTP is permitted for a NPDES discharge of 26 mgd (NC0024210) to Richland /AV
_ - Cape Fear River Basin. The Westside WWTP is permitted for a NPDES discharge of 6.2 mgd
= - o Rich Fork Creek in the Yadkin -Pee Dee River Basin. The average flow rate through the !
i P was 4.5 mgd for the period from January 2002 to May 2004 and 3.6 mgd in 2009. The
_ :2 was 12.8 mgd. The City of High Point collection syst� oar sists of over 670 miles of
and pressurized force mains and 24 pump stations conveying raw wastewater to the 71
�1c
I% i&1441f
AVilD was originally constructed in 1929 and was expanded to the current capacity of
IWZ- The Westside WWTP consists of primary clarification, aeration basins, secondary
f ers; phosphorus removal via chemical addition, and.ultraviolet disinfection. Solids are
Immamc v js._.*i &d air floatation (DAF), dewatered by centrifuge, and trucked to the Eastside WWTP �I!
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LOCAL, CAROLINAS
THE HIGH POINT ENTERPRISE SUNDAY, MARCH 10, 2013 www.hpe.com, A5
Manager: Budget g'ant%
could reach $3 m' 'on
BY PAT KIMBROUGH
ENTERPRISE STAFF WRITER
HIGH POINT —The city is facing a
budget shortfall that could reach $3 mil-
lion, but officials are trying to ensure
that won't translate into bad news for
taxpayers.
While High Point's major revenue
sources are projected to bring in about
the same amount of money in the.2013-
14 fiscal year, officials have identified
several million dollars the city gets
through the state and Guilford County
that could be cut.
That adds up to a projected gap
between revenues and expenditures of
$2.5 million to $3 million for the budget
year that takes effect July 1, said City
Manger Strib Boynton. The projection
is based on funding everything at cur-
rent levels without adding new initia-
tives.
The city's entire operating budget
totals about $328 million, with an addi-
tional capital budget of about $140 mil-
lion.
The City Council has given Boyn-
ton direction to produce a budget with
no property tag rate increase, so offi-
cials could be faced with making cuts to
make up for a reduction in revenue.
"There are some that would like
to have a budget with a tax decrease.
I'm going to be thrilled if we can come
in flat, without an increase," he said.
"We've got a challenge meeting that
expectation of the council and the com-
munity and still maintaining services."
Officials are projecting water and
sewer and electric rate increases, how-
ever.
Boynton said there are several ongo-
ing projects that will be fully funded in
next year's budget. These include the
expansion of the Westside Wastewa-
ter Treatment Plant, replacement of an
incinerator at the Eastside Wastewater
Treatment Plant to comply with state
standards, and replacement of a convey-
or belt and baler used in the city's recy-
cling program at the Material Recovery
Facility.
The city normally gets $200,000 to
$300,000 in requests from various non-
profits and other outside agencies dur-
ing the budget process. Boynton said
about $1 million worth of such requests
have come in so far, but the city won't
be able to fund near that amount.
"I know in the next 60 to 90 days,
there's several more million coming in
that somehow the city's supposed to
use public dollars to finance this or that
initiative," Boynton said. "Each one is
perfect, it's wonderful in its own right,
but we haven't got the dollars."
pkimbrough@hpecom 1 888-3531