NC0024881_Other Correspondence_20200716

Reidsville
F 230 W. Morehead Street • Reidsville, North Carolina 27320 • [phone] • Fax [phone]
July 16, 2020
Mr. Jeff Poupart, PE
Water Quality Permitting Section Chief
NCDEQ Division of Water Resources
512 N. Salisbury Street
Raleigh, North Carolina 27604
Re: City of Reidsville Wastewater Permit
NPDES NCO024881
Rockingham County, North Carolina
Dear Mr. Poupart;
Office of the City Manager
JUL 3 0 2020
NCDEQ/DWR/NPDES
As you are aware the City of Reidsville owns and operates a 7.5 MGD wastewater treatment
plant that serves customers within its corporate limits. As a result of the Jordan Lake rules,
nitrogen and phosphorus nutrient limits were included in the City's NPDES (NC0024881) permit.
The plant has remained substantially in compliance, the plant was not designed or built to
specifically achieve nutrient removal.
The plant was designed for 7.5 MGD capacity and equipped with two process trains, including
extended aeration and clarification for managing biological treatment. Currently, the facility
operates at an average daily flow of approximately 2.2 MGD. Due to the lower flows, only one
(1) train of the plant was typically in service. Therefore, several years ago the City modified one
(1) aeration basin by installing diffused aeration and jet blowers.
Because of the ongoing need for the City to upgrade its WWTP to include nutrient reduction, the
City embarked on an effort to develop a plan for adding nutrient removal to its plant. During the
planning for the upcoming nutrient removal project, the most cost-effective strategy was to
upgrade the plant to achieve nutrient removal with 3.75 MGD capacity utilizing one train of the
treatment process. The City applied for State Revolving Fund (SRF) funding for the project to
implement nutrient removal and was awarded funding in the Fall 2017 funding round.
McGill Associates, our consulting engineer, prepared the engineering report for submission to
NCDWI. This evaluation looked at several alternatives to provide effective biological nutrient
removal for at least up to 3.75 MGD of treatment capacity to address the current nutrient
requirements. In consultation with the City, the selected alternative identified in the approved
Engineering Report involves modifying both aeration basins and inserting baffles for staged
nutrient removal to allow increased treatment capacity for up to 5.5 MGD of the overall 7.5 MGD
treatment capacity. The designed modifications are aimed at providing interim nutrient
reduction capability for up to 5.5 MGD of flow. The permitted flow page for 7.5 MGD must
remain in the permit because it reflects the hydraulic capacity of the plant and continues to
"Live Simply. Think Big."

establish that the City retains its ability to go to 7.5 MGD whenever it undertakes efforts to
further upgrade its nutrient reduction capability to 7.5 MGD.
After the design was complete and submitted to NCDWI for approval, the City coordinated
design considerations with McGill Associates. It was determined that the facility improvements,
when completed, would be capable of treating up to 5.5 MGD. At that point, NCDEQ's Division
of Water Resources indicated that the NPDES permit would need to be modified to include a
limits page for 5.5 MGD, in addition to the 7.5 MGD page in the permit.
Therefore, the City of Reidsville hereby requests that its NPDES permit be modified to include
an effluent limits page for 5.5 MGD treatment capacity. This will allow DWI to issue its approval
of the plans and specifications, the City to move forward to undertake efforts to identify an
appropriate contractor and begin construction. Future consistent compliance is dependent on
the City's ability to undertake and complete this project to meet its nutrient removal limits for
nitrogen and phosphorus. The City recognizes that future upgrade efforts will be necessary to
achieve appropriate nutrient treatment capability for 7.5 MGD.
The City further recognizes that it is participating in negotiations with the Division through your
office to secure reductions in the WWTP's effluent levels of 1,4-Dioxane. However, Reidsville
seeks revisions to its NPDES permit to allow the nutrient reduction project to move forward and
requests that the modification to add a 5.5 MGD effluent limits page to the permit be allowed to
proceed as soon as possible. Moving forward with this nutrient treatment project is important to
help address eutrophication concerns in Jordan Lake.
We appreciate your assistance with this matter. Should you have any questions or need
additional information, please do not hesitate to contact me at 336-349-1030 or Forrest Westall
with McGill at 828-231-6840.
Sincerely,
Preston MittilV11141
City Manager
Cc: Chuck Smith, City of Reidsville
Ben Bani, City of Reidsville
Forrest Westall, McGill Associates
Doug Chapman, McGill Associates