HomeMy WebLinkAboutNC0024333_Speculative Limits_20211217DocuSign Envelope ID: D791850B-0E78-43A4-AEB4-4C956A6A3901
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
James Struve, P.E.
Hazen and Sawyer
9101 Southern Pine Blvd, Ste. 250
Charlotte, North Carolina 28273
Dear Mr. Struve:
NORTH CAROLINA
Environmental Quality
December 17, 2021
Subject: Speculative Effluent Limits
Monroe WWTP NC0024333
Union County
Yadkin -Pee Dee River Basin
This letter provides speculative effluent limits for expanding the WWTP serving the City of
Monroe located on Richardson Creek with a proposed flow of 15.4 MGD. The Division cannot
provide speculative limits for the 25 MGD request due to concerns over loading to the Rocky River
downstream. Limits greater than 15.4 MGD will require a site -specific calibrated model. Please
recognize that any future speculative limits requests may change based on future water quality
initiatives, and it is highly recommended that the applicant verify the speculative limits with the
Division's NPDES Unit prior to any engineering design work.
Receiving Streams. Richardson Creek is located within the Yadkin -Pee Dee River Basin.
Richardson Creek has a stream classification of C, and waters with this classification have a best
usage for aquatic life propagation and maintenance of biological integrity, wildlife, secondary
recreation, and agriculture. Richardson Creek has a summer 7Q10 flow of 1.8 cfs, a winter 7Q10
flow of 3.0 cfs, a 30Q2 flow of 4.0 cfs, and an annual average flow of 65.2 cfs.
Richardson Creek is currently listed as an impaired waterbody on the 2020 North Carolina 303(d)
Impaired Waters List for exceeding benthic and copper criteria. There are no specific permitting
strategies or a TMDL for this stream.
Based upon a review of information available from the North Carolina Natural Heritage Program
Online Map Viewer, there are not any Federally Listed threatened or endangered aquatic species
identified within a 5-mile radius of the proposed discharge location, however, there are non -aquatic
threatened or endangered species in the same radius. If there are any identified
threatened/endangered species, it is recommended that the applicant discuss the proposed project
with the US Fish and Wildlife Service to determine whether the proposed discharge location might
impact such species.
NORTH 1:tE
nepertment of Environmental ouat\sjoll.#k"
CAROLINA
North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000
DocuSign Envelope ID: D791850B-0E78-43A4-AEB4-4C956A6A3901
Speculative Effluent Limits. Based on Division review of receiving stream conditions and water
quality modeling results, speculative limits for an expansion to 15.4 MGD are presented in Table
1. A complete evaluation of these limits and monitoring requirements for metals and other
toxicants, as well as potential instream monitoring requirements, will be addressed upon review of
the formal NPDES permit application which is under review. Some features of the speculative
limit development include the following:
• BOD/NH3 Limits. Assimilative capacity to protect the instream dissolved oxygen
standard of 5.0 mg/L is based on a Streeter-Phelp's model and ambient monitoring
station data. The resultant limits are considered technologically feasible.
• Other. Modeling showed sensitivity to dissolved oxygen in the effluent, therefore the
effluent limit was increased to 6 mg/L. TSS mass -loading was held constant to
minimize pollutant loading to the impaired stream segments.
TABLE 1. Speculative Limits for Monroe WWTP proposed expansion.
Effluent Characteristic
Effluent Limitations
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
15.4 MGD
BOD5
5.0 mg/L
7.5 mg/L
NH3 as N (Apr. -Oct.)
1.0 mg/L
3.0 mg/L
NH3 as N (Nov. -Mar.)
1.8 mg/L
5.4 mg/L
Dissolved Oxygen
(minimum daily average)
6.0 mg/L
TSS
24.3 mg/L
36.4 mg/L
TRC
17 µg/L
Fecal coliform
(geometric mean)
200/100 mL
400/100 mL
Chronic Toxicity
Pass/Fail (Quarterly test)
90%
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that
an NPDES permit for a new or expanding discharge will be issued with these speculative limits
Final decisions can only be made after the Division evaluates the formal permit application for
the expanded discharge. In accordance with North Carolina Administrative Code 15A NCAC
2H.0105(c), the most environmentally sound alternative should be selected from all reasonably
cost-effective options. Therefore, as a component of all NPDES permit applications for new
or expanding flow, a detailed engineering alternatives analysis (EAA) must be prepared (in
this case we have this information which is under review). The EAA must justify requested
flows and provide an analysis of potential wastewater treatment alternatives.
State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document
may be required for projects that: 1) involve $10 Million or more of state funds; or 2) will
significantly and permanently impact 10 or more acres of public lands. Please check with the
DWR SEPA coordinator (David Wainwright, 919-707-9045) as to whether your project
requires SEPA review. For projects that are subject to SEPA, the EAA requirements discussed
NORTH
Department of Esmlmnmontel Wally
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000
DocuSign Envelope ID: D791850B-0E78-43A4-AEB4-4C956A6A3901
above will need to be folded into the SEPA document. Additionally, if subject to SEPA, the
NPDES Unit will not finalize an NPDES permit application for a new/expanding discharge
until the Division has approved the SEPA document and sent a Finding of No Significant
Impact (FONSI) to the State Clearinghouse for review and comment.
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact David Hill at david.hill@ncdenr.gov or (919) 707-
3612.
Respectfully,
DocuSigned by:
LI
N AW1A1i"WW
C464531431644FE...
Michael Montebello
Supervisor, NPDES Municipal Permitting Unit
Electronic Copy:
NC Wildlife Resources Commission, shannon.deaton@ncwildlif.org
US Fish and Wildlife Service, sara ward@fws.gov
DWR/Water Quality Regional Office/Moorseville/Corey Basinger
DWR/Basinwide Planning/Jim Hawhee
DWR/Modeling and Assessment Branch/Pam Behm
Hazen and Sawyer: James Struve, jstuve@hazenandsawyer.com
City of Monroe: Russ Colbath, rcolbath@monroenc.org
NORTH
Department of EmImnment.I Wally
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000