NC0024228_Permit (Modification)_20130620

NPDES DOCIMENT !;CANNING COVER SHEET
NPDES Permit:
NC0024228
High Point Westside WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification `'`,
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
June 20, 2013
This document is printed on reuse paper - ignore any
content on the rezrerse side

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder
Governor Acting Director
June 20, 2013
Mr. W. Chris Thompson, P.E.
Director of Public Services
The City of High Point
P.O. Box 230
High Point, NC 27261
John E. Skvarla, III
Secretary
Subject: Issuance of NPDES Permit Modification
NC0024228
High Point Westside WWTP
Davidson County
Facility Class IV
Dear Mr. Thompson:
Division personnel have reviewed and approved your application for your facility's proposed expansion,
which is conditioned upon successful stream restoration activities to improve assimilative capacity.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as
subsequently amended).
Thank you for your comment letter on the draft NPDES permit. Since the laboratory did indeed provide
the appropriate supporting quality control for the sample taken on February 3, 2010 a mercury limit will
remain in the permit. In accordance with anti -degradation rules and the Implementation of the statewide
Mercury TMDL, US EPA has identified that WWTP's with existing mercury limits based on 12 ng/L,
showing potential to exceed the Technology Based Effluent Limitation (TBEL) of 47 ng/L, are required
to continue complying with their existing limit as an annual average limitation. EPA contested that giving
a TBEL of 47 ng/L could result in violations of the state water quality standard. Mercury limitations in
Sections A.(1), A.(2.), and A.(3.) were corrected to Water Quality Based limitations to be complied with
on an annual average.
Additional changes made to the draft permit sent to you on February 13, 2013 include:
• The address on the Cover page and Supplement to cover was corrected to 1044 West Burton
Road.
• The stream classification listed on the map was corrected to C.
• The Monitoring Frequency Reduction guidance has been clarified to primarily apply to existing
permitted flows and sampling data. Facilities with flow expansions associated with treatment
modifications shall resume sampling in accordance with 15A NCAC 2B .0500 until sufficient
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwaterauality.orq
An Equal Opportunity t Affirmative Action Employer
NorthCarolina
Naturally

Page 2 of 3
data is collected to demonstrate consistent, long-term treatment performance under modified
conditions. Therefore, sampling for TSS, NH3-N, and Fecal Coliform has been changed to daily
in Section A.(2). Three years of data will be needed to demonstrate consistent, long term
treatment performance under the modified conditions to qualify for a reduction in sampling.
Facilities requesting an expansion with no changes to treatment will be granted previous
monitoring reductions. Therefore, any reductions granted to Westside WWTP under 8.2 MGD
will be continued in the 10 MGD effluent requirements if no significant treatment modifications
are made prior to issuance of the 10 MGD Authorization To Operate. Section A.(3.) was revised
to reflect sampling requirements in Section A.(2.).
• The Mercury Minimization Plan in Section A.(7.) was revised to allow for implementation of the
MMP during the next permit cycle since this modified permit will expire on April 30, 2014.
Results shall be summarized and submitted with the renewal application submitted for the permit
expiring on April 30, 2019.The MMP shall be developed as originally stated (within 180 days of
the effective date of this permit).
As identified previously, this permit modification contains the following changes from your current
permit:
• The Supplement to Cover page was revised to include a revised treatment components list and to
address the phased expansions from 6.2 to 8.2 MGD and 8.2 to 10 MGD.
• Phased expansion Effluent Limitations and Monitoring Requirements for 8.2 MGD and 10 MGD
were added under Sections A.(2) and A.(3). Special Conditions under footnote #8 were added to
Section A.(3) outlining the actions cited or necessary as part of the SEPA Findings of No
Significant Impact and Environmental Assessment dated Nov. 19, 2010.
• In accordance with the NPDES Monitoring Frequency Reduction Review Guidance, monitoring
for TSS, NH3-N, and fecal coliform were reduced from daily to twice per week under the existing
permitted conditions in Section A.(1.).
• As part of the Statewide TMDL for mercury, a Mercury Minimization Plan must be developed for
your facility. See Special Condition A. (7) Mercury Minimization Plan (MMP). The requirements
are posted on the NPDES website: http://portal.ncdenr.org/web/wq/ps/npdes. You have until
January 28, 2014 (180 days from the effective date of the permit) to develop the plan.
• Copper, silver, and zinc all showed reasonable potential to violate water quality standards. Since
these parameters have action level standards, quarterly monitoring in conjunction with the Whole
Effluent Toxicity test will be required. See Sections A.(1), A.(2) and A.(3).
• Nickel and cyanide effluent samples did not show reasonable potential to violate water quality
standards and were removed from the permit but will continue to be monitored as part of the
WWTP's Pretreatment LTMP.
• Aluminum effluent samples did not show reasonable potential to violate the Human Health
standard based on fish consumption so aluminum monitoring was removed from the permit.
Monitoring for aluminum will continue as part of the WWTP's Pretreatment LIMP.
• Footnote Number 3 was modified under Section A (1.) to include the following statement: TRC
limit and monitoring requirement only apply if chlorine is used for disinfection. The Permittee
shall report all effluent TRC values reported by a NC -certified laboratory [including field -
certified]. Effluent values below 50 .µg/L will be treated as zero for compliance purposes.
• As stated in the Speculative Effluent Limits letter dated 11/10/2009, in the interim prior to the
finalization of the nutrient TMDL for High Rock Lake, current permit TP mass loads were
maintained in the phased expansions. TN limitations were added in the phased expansion Effluent
Limitations pages which freeze the actual TN mass load based on the historical loadings from the
Westside WWTP from January 2007 through August 2009. See Sections A.(2) and A.(3).
• The wording in Section A. (8.)Chronic Toxicity Permit Limit has been changed and the following
paragraph added: If the Permittee monitors any pollutant more frequently than required by this
permit, the results of such monitoring shall be included in the calculation and reporting of the

Page 3 of 3
4 ,
data submitted on the Discharge Monitoring Report and all AT Forms submitted. This wording
has also been added to the New 2011 Standard Conditions: Part II, Section E. 5.b.
• Effluent pollutant scans have been reduced from annually to three times during the term of the
permit cycle. See Section A. (9.).
Please note that the receiving stream, Rich Fork Creek, is listed as an unpaired waterbody on the 2012
North Carolina 303(d) Impaired Waters List. Impairment is for ecological/biological integrity benthos.
Addressing impaired waters is a high priority with the Division and instream data will continue to be
evaluated. If there is noncompliance with permitted effluent limits and stream impairment can be
attributed to your facility, then mitigative measures may be required.
If any parts, measurement frequencies or sampling requirements contained in this permit 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 Statutes, and filed with the Office of Administrative
Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is
made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or
Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Julie Grzyb by email
(julie.grzyb@,ncdenr.gov) or phone at [phone].
Sin erely,
Oda—
&rt./
Enclosure: NPDES Permit NC0024228
cc: NPDES Unit
Winston-Salem Regional Office / Surface Water Protection Section
e-copy:
EPA Region IV, Ben Gosh
PERCS Unit
ESS/ Aquatic Toxicity Unit, Susan Meadows
ESS/ Ecosystems Unit, Carrie Ruhlman
Wildlife Resources Commission, Habitat Conservation Program, Shari Bryant,
US Army Corps of Engineers, [e-mail]
homas A. Reeder

r-
:i
L
A
Permit No. NC0024228
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended,
City of High Point
is hereby authorized to discharge wastewater from a facility located at
High Point/ Westside Wastewater Treatment Plant
1044 West Burton Road
Davidson County
to receiving waters designated as Rich Fork Creek in the Yadkin -Pee Dee River Basin
in accordance with the discharge limitations, monitoring requirements, and other conditions set
forth in Parts I, II, III, and IV hereof.
This permit modification shall become effective August 1, 2013.
This permit and the authorization to discharge shall expire at midnight on April 30, 2014.
Signed this day June 20, 2013.
Thomas A. Reeder, Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

• 4
Permit NC0024228T
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and provisions included herein.
The City of High Point is hereby authorized to:
1. Continue to operate an existing 6.2 MGD wastewater treatment facility that
includes the following components:
> VFD Solids Handling Vertical Turbines influent pumps
> Mechanical Bar Screens (course and fine screen)
> Stirred Vortex Grit chambers
> Dual primary clarifiers
> Roughing filter (bio-filter)
> Three aeration basins
> Dual secondary clarifiers
> Tertiary filters
> Alum phosphorus removal facilities
> Rotary Drum Thickener
> Dual train UV disinfection
> Effluent Pumps
This facility is located at the High Point Westside WWTP, 1044 West Burton Road,
Thomasville, in Davidson County.
2. After receiving the proper Authorization to Construct a 10 MGD WWTP and the
Authorization to Operate an 8.2 MGD WWTP from the Division of Water Quality,
construct the facilities 'and operate the Westside WWTP at a permitted flow of 8.2
MGD, and,
3. After receiving the proper Authorization to Operate a 10 MGD WWTP from the
Division of Water Quality, as well as Division approval based on positive
demonstration of sufficient assimilative capacity in the receiving stream, operate
facilities giving Westside WWTP a treatment capacity of 10 MGD.
4. Discharge wastewater from said treatment works at the location specified on the
attached map into Rich Fork Creek, currently classified C waters in the Yadkin -Pee
Dee River Basin.
Page 12

• _ 4
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City of High Point - NC0024228
USGS Quad Name: D18NE
Receiving Stream: Rich Fork Creek
Stream Class: C
Subbasin: 03-07-07
Lat.: 3556'14"
Long.: 80°06'42"
Basin: Yadkin
HUC: 03040103

a
Permit NC0024228
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration
or expansion, the Permittee is authorized to discharge from outfall 001. Such discharges
shall be limited and monitored by the Permittee as specified below:
PARAMETER
• .
• LIMITS
MONITORINGREQUIREMENTS ;,
Monthly :
Average ;
:Weekly ' .
;Average..:
Daily
Maximum
Measurement'
Frequency ,
Sample
Type
Sample Location••.
*low
6.2 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day, 20°C2
(April 1- October 31)
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent & Effluent
BOD, 5 day, 20°C2
(November 1- March 31)
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent & Effluent
Total Suspended Solids2
30.0 mglL
45.0 mg/L
2/week
Composite
Influent & Effluent
NH3 as N
(April 1 - October 31)
2.0 mg/L
6.0 mg/L
2/week
Composite
Effluent
NH3 as N
(November 1- March 31)
4.0 mg/L
12.0 mg/L
2/week
Composite
Effluent
pH
> 6.0 and < 9.0 standard units .
Daily
Grab
Effluent
Dissolved Oxygen
Daily average > 6.0 mg/L
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 mL
400/100 mL
2/week
Grab
Effluent
*la! Residual Chlorine3
17 Ng1L
Daily
Grab
Effluent
Temperature °C
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 + TKN)
Weekly
Composite
Effluent
Total Phosphorus4
(April 1— October 31)
5,533 pounds
Seasonal total
Weekly
Composite
Effluent
Total Phosphorus4
(November 1— March 31)
7,808 pounds
Seasonal total
Weekly
Composite
Effluent
Chronic Toxicity5
Quarterly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Total Mercury6
Annual average limit of 14 ng/L
Quarterly
Grab
Effluent
Total Silver
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
Effluent Pollutant Scan
Monitor & Report
3 scans over five
year period
Footnote 7
Effluent
Footnotes:
i See Section A. (4.) for Instream Monitoring Requirements.
2 The monthly average effluent GODS and Total Suspended Solids concentrations shall not exceed
15% of the respective influent value (85% removal).
3 TRC limit and monitoring requirement only apply if chlorine is used for disinfection. The Permittee
shall report all effluent TRC values reported by a NC -certified laboratory [including field -certified].
Effluent values below 50 µg/ L will be treated as zero for compliance purposes.
4 The facility shall meet a Total Phosphorus mass limit of 5,533 pounds during the summer (April -
October) and 7,808 pounds during the winter (November -March). See A. (5.) for reporting details.
5 Chronic Toxicity (Ceriodaphnia) P/F at 90% January, April, July, and October [see A. (8.)].
TOXICITY MONITORING SHALL COINCIDE WITH METALS MONITORING.
6 Effluent samples must be analyzed by EPA Method 1631E. A Mercury Minimization Plan is
required, see Special Condition A.(7).
7 See A. (9.) of this permit.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 14

Permit NC002422&
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning upon receipt of an Authorization to Operate or the Engineer's Certification upon
completion of the 8.2 MGD expansion and lasting until issuance of an Authorization to Operate
at 10 MGD or permit expiration, the Permittee is authorized to discharge from outfall 001. Such
discharsres shall be limited and monitored by the Permittee as specified below:
PARAMETER
'LIMITS "
. MONITORING: REQUIREMENTS
Monthly,
Average
Weekly
Average
Daily
Maximum
Measurement "
Frequency
Sample
Type
Sample-Location1
Flow
8.2 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day, 20°C2
(April 1- October 31)
4.9 mg/L
7.4 mglL
Daily
Composite
Influent & Effluent
BOD, 5 day, 20°C2
(November 1- March 31)
9.8 mglL
14.8 mg/L
Daily
Composite
Influent & Effluent
Total Suspended Solids2
30.0 mg/L
45.0 mglL
Daily
Composite
Influent & Effluent
NH3 as N
(April 1- October 31)
1.0 mglL
3.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1- March 31)
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
pH
> 6.0 and < 9.0 standard units
Daily
Grab
Effluent
Dissolved Oxygen
Daily average > 7.0 mg/L
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 mL
400/100 mL
Daily
Grab
Effluent
albtal Residual Chlorine3
17 pg/L
Daily
Grab
Effluent
Temperature °C
Daily
Grab
Effluent •
Total Nitrogen 4
(NO2 + NO3 + TKN)
159,870 pounds/year
(annual load)
Weekly
Composite
Effluent
Total Phosphorus4
13,341 pounds / year
(annual Toad)
Weekly
Composite
Effluent
Chronic Toxicity5
Quarterly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Total Mercury6
Annual average limit of 13 nglL
Quarterly
Grab
Effluent
Total Silver
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
Effluent Pollutant Scan
Monitor & Report
3 scans over five
year period
Footnote 7
Effluent
Footnotes:
i See Section A.- (4.) for Instream Monitoring Requirements.
2 The monthly average effluent BODS and Total Suspended Solids concentrations shall not exceed
15% of the respective influent value (85% removal).
3 TRC limit and monitoring requirement only apply if chlorine is used for disinfection. The Permittee
shall report all effluent TRC values reported by a NC -certified laboratory [including field -certified].
Effluent values below 50 µg/ L will be treated as zero for compliance purposes.
4 See A. (6.) CALCULATION AND REPORTING OF NUTRIENT LOADS for details.
5 Chronic Toxicity (Ceriodaphnia) P/F at 90% January, April, July, and October [see A. (8.)].
TOXICITY MONITORING SHALL COINCIDE WITH METALS MONITORING.
6 Effluent samples must be analyzed by EPA Method 1631E. A Mercury Minimization Plan is
required, see Special Condition A.(7).
7 See A. (9.) of this permit.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 15

•
Permit NC0024228
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
After satisfying the Special Conditions in footnote 8 and begining upon receipt of an Authorization
to Operate at 10 MGD and lasting until permit expiration, the Permittee is authorized to
discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly ...
Average
Weekly
Average
Daily
Maximum
Measurement;
Frequency .
Sample
Type
Sample Location"
Flow
10 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day, 20°C2
(April 1- October 31)
5 mg/L
7.5 mg/L
Daily
Composite
Influent & Effluent
BOD, 5 day, 20°C2
(November 1- March 31)
10 mg/L
15.0 mg/L
' Daily
Composite
Influent & Effluent
.
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent & Effluent
NH3 as N
(April 1- October 31)
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1- March 31)
1.8 mg/L
5.4 mg/L
Daily
Composite
Effluent
pH
> 6.0 and < 9.0 standard units .
Daily
Grab
Effluent
Dissolved Oxygen
Daily average > 7.0 mg/L
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 mL
400/100 mL
Daily
Grab
Effluent
.fal Residual Chlorine3
17 pg/L
Daily
Grab
Effluent
Temperature °C
Daily
Grab
Effluent
Total Nitrogen4
(NO2 + NO3 + TKN)
159,870 pounds/year
(annual load)
Weekly
Composite
Effluent
Total Phosphorus4
13,341 pounds / year
(annual load)
Weekly
Composite
Effluent
Chronic Toxicity5
Quarterly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Total Mercury6
Annual average limit of 13 ng/L
Quarterly
Grab
Effluent
Total Silver
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
Effluent Pollutant Scan
Monitor & Report
3 scans over five
year period
Footnote 7
Effluent
Footnotes:
i See Section A. (4.) for Instream Monitoring Requirements.
2 The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed
15% of the respective influent value (85% removal) .
3 TRC limit and monitoring requirement only apply if chlorine is used for disinfection. The Permittee
shall report all effluent TRC values reported by a NC -certified laboratory [including field -certified].
Effluent values below 50 µg/ L will be treated as zero for compliance purposes.
4 See A. (6.) CALCULATION AND REPORTING OF NUTRIENT LOADS for details.
5 Chronic Toxicity (Ceriodaphnia) P/F at 90% January, April, July, and October [see A. (8.)].
TOXICITY MONITORING SHALL COINCIDE WITH METALS MONITORING.
6 Effluent samples must be analyzed by EPA Method 1631E. A Mercury Minimization Plan is
required, see Special Condition A.(7).
7 See A. (9.) of this permit.
Page 16

Permit NC0024228J
s SPECIAL CONDITIONS INACCORDANCE WITH THE SEPA FINDING OF NO SIGNIFICANT IMPACT AND
ENVIRONMENTAL ASSESSMENT FOR THE CITY OF HIGH POINT — WESTSIDE WASTEWATER TREATMENT
PLANT EXPANSION BEYOND 8.2 MGD:
a. Perform the stream restoration project on Rich Fork Creek after acquiring the necessary
permits.
b. Submit a summer in -stream monitoring plan, on the proposed intensive monitoring in Rich
Fork Creek, to be performed following stream restoration. Submit 2 copies of the plan to
DWQ/ NPDES and one copy to the DWQ/MTU/Unit Supervisor for approval at least 3 months
prior to planned implementation.
c. The City of High Point shall implement the DWQ approved in -stream monitoring plan.
d. Following the intensive monitoring survey, after the stream restoration project
is completed, the receiving water quality model for Rich Fork Creek will be
recalibrated for the approximately 12 mile segment between the High Point
Westside outfall and the confluence of Abbotts Creek, to reflect the revised
physical conditions of the stream due to the restoration project. The
recalibrated model will be rerun with existing flow, 8.2 MGD, and 10 MGD to
analyze the impact of the discharge. Model results will be compared with
previous predictions and observed profiles to determine the level of impact on
dissolved oxygen concentrations. The results of the modeling analyses and the
recalibrated models at 8.2 MGD and 10 MGD shall be submitted to DWQ for
review. Submit 2 copies of the modeling report and all associated modeling files
to DWQ/ NPDES and one copy to the DWQ/MTU/Unit Supervisor for review.
An electronic copy of the model should be included with the copy sent to •
DWQ/MTU for a proper review. The City of High Point will be allowed to
proceed with an expansion or an Authorization to Operate request at 10 MGD
upon DWQ approval, based upon validation of model predictions that in -stream
dissolved oxygen water quality standards will be maintained in the restored
segment of the receiving stream.
e. If the recalibrated models or in -stream DO data in the restored segment of Rich
Fork Creek do not show sufficient assimilative capacity, the City of High Point
shall submit a plan outlining efforts to maximize DO in the WWTP's effluent to
ensure in -stream DO water quality standards are not violated due to the
discharge from the Westside WWTP. Three copies of the DO optimization plan
shall be submitted to DWQ/ NPDES. A compliance schedule to address the DO
deficiency may be added to this permit and an Authorization to Operate at a
capacity of 10 MGD will not be allowed until the City demonstrates that the
receiving stream has sufficient assimulative capacity to support an expansion.
All submitals to DWQ/MTU and DWQ/NPDES should be sent to:
1617 Mail Service Center
Raleigh, NC 27699-1617
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 17

•
Permit NC0024228
0
A. (4.) INSTREAM MONITORING REQUIREMENTS
Parameter
:MeasurementFrequency
:Sample Type -,
•. Sample:Locationl
Fecal Coliform
June -Sept.
3/week
Grab
Upstream &
Downstream 1 & 2
October -May
1 /week
Dissolved Oxygen
June -Sept.
3/week
Grab
Upstream &
Downstream 1 & 2
October -May
1 /week
Temperature
June -Sept.
3/week
Grab
Upstream &
Downstream 1 & 2
October -May
1/week
Conductivity
June -Sept.
3/week
Grab
Upstream &
Downstream 1 & 2
October -May
1 /week
Total Phosphorus
June -Sept. 1/month
Grab
Upstream &
Downstream 1 & 2
Total Nitrogen
(NO2 + NO3 + TKN)
June -Sept. 1/month
Grab
Upstream &
Downstream 1 & 2
Footnotes:
1. Upstream = Rich Fork Creek at NCSR1757 - Chestnut Street above the outfall.
2. Downstream (2 locations): (1) at NCSR 1 , (2) at NCSR 2123 upstream of Abbotts Creek.
Instream monitoring is waived as long as this facility is a member of the Yadkin Pee Dee
River Basin Association and the Association continues to monitor these three stations.' If the
facility ends its membership in the Yadkin Pee Dee River Association or the Association
discontinues monitoring any of these three stations, instream monitoring requirements, for
each station not being monitored as specified in this permit, take effect immediately.
A. (5.) CALCULATION OF TOTAL PHOSPHORUS LOADS (seasonal)
a. The Permittee shall calculate monthly and seasonal TP Loads as follows:
i. Monthly TP Load (pounds/month) = TP x TMF x 8.34
where:
TP = the average Total Phosphorus concentration (mg/L) of the
composite samples collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the month
(MG/mo)
8.34 = conversion factor, from (mg/L x MG) to pounds
u. Seasonal TP Load (pounds/year) = Sum of the Monthly TP Loads for the season
b. The Permittee shall report monthly Total Phosphorus results (mg/L and
pounds/mo) in the appropriate discharge monitoring report for that month and the
total load for each season in the following month after the last month of the season.
Page 18

Permit NC0024228`'
i
A. (6.) CALCULATION AND REPORTING OF NUTRIENT LOADS (monthly & annual)
The Permittee shall calculate and report monthly and annual nutrient loads for the Westside WWTP
as follows:
(a.) Calculation of Discharge Loads: The Permittee shall calculate monthly and annual
discharge loads as follows:
(i.)
Monthly Discharge Load (lb/mo, TN or TP) = TN (or TP) x TMF x 8.34
where:
TN (or TP) = the average Total Nitrogen (or Total Phosphorus) concentration
(mg/ L) of the composite samples collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the
month (MG/mo)
8.34 = conversion factor, from (mg/ L x MG) to pounds
(ii.) Annual Discharge Load (lb/yr, TN or TP) = Sum of the 12 Monthly TN (or TP)
Loads for the calendar year
(b.) Reporting of Nutrient Discharges: The Permittee shall report each facility's monthly
TN and TP discharge loads in that facility's discharge monitoring report. The monthly
reporting parameter codes for TN and TP are QM600 and QM665, respectively.
(c.) The Permittee shall report each calendar year's loads with the December report for
that year and shall append the report with a summary of monthly loads and
calculations. The annual reporting parameter codes for TN and TP are QY600 and
QY665, respectively.
A. (7). MERCURY MINIMIZATION PLAN (MMP).
The permittee shall develop and implement a Mercury Minimization Plan (MMP). The MMP
shall be developed within 180 days of the NPDES Permit Effective Date, and shall be
available for inspection on -site. A sample MMP was developed through a stakeholder
review process and has been placed on the Division website for guidance
(http: / /portal.ncdenr.org/web/wq/swp/ps/npdes, under Model Mercury Minimization
Plan) . The MMP should place emphasis on identification of mercury contributors and goals
for reduction. Implementation shall occur during the next permit cycle and the results
shall be summarized and submitted with the permit renewal application submitted for the
permit expiring on April 30, 2019.
A. (8.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to .Ceriodaphnia dubia at an effluent concentration of 90 %.
The permit holder shall perform at a minimum, quarterlu monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
January, April, July, and October. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
Page 19

Permit NC0024228
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ
Form AT-3 (original) is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the
report with the notation of "No Flow" in the comment area of the form. The report shall be submitted
to the Environmental Sciences Branch at the address cited above. Should the permittee fail to
monitor during a month in which toxicity monitoring is required, monitoring will be required during
the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of
such monitoring shall be included in the calculation & reporting of the data submitted on the DMR &
all AT Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate environmental
controls, shall constitute an invalid test and will require immediate follow-up testing to be completed
no later than the last day of the month following the month of the initial monitoring.
Page 110

Permit NC0024228,
A. (9.) EFFLUENT POLLUTANT SCAN
The Permittee shall perform three annual Effluent Pollutant Scans between 7/10/2009 and 4/30/2014 for all
parameters listed in the attached table (using a sufficiently sensitive detection level in accordance with 40 CFR
Part 136). Samples shall represent seasonal variations. Unless otherwise indicated, metals shall be analyzed
as "total recoverable."
Ammonia (as N) Trans-1,2-dichloroethylene Bis (2-chloroethyl) ether
Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether
Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Phosphorus Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1, 1,2 ,2 -tetrachloroethane Di-n-butyl phthalate
Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1, 1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid -extractable compounds: Diethyl phthalate
Mercury (Method 1631E) P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc . 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene
Acrolein Phenol Hexachloroethane
Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene
Benzene Base -neutral compounds: Isophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1,1-dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane Bis (2-chloroethoxy) methane
Test results shall be reported to the Division in DWQ Form- A MR-PPA1 or in a form approved
by the Director within 90 days of sampling. The report shall be submitted to the following
address: NC DENR / DWQ / Central Files, 1617 Mail Service Center, Raleigh, NC 27699-1617.
Page 111

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit NC0024228
Facility Information
Applicant/Facility Name:
City of High Point/Westside WWTP
Applicant Address:
P.O. Box 230, High point, North Carolina 27261
Facility Address:
1044 W. Burton Road, Thomasville, North Carolina 27360
Permitted Flow
6.2 MGD, proposed exp. to 8.2 MGD and 10 MGD
Type of Waste:
Domestic (97%) and industrial (3%) with pretreatment program
Facility/Permit Status:
Class IV /Active; Major Modification - expansion
County:
Davidson County
Miscellaneous
Receiving Stream:
Rich Fork Creek
Regional Office:
WSRO
Stream Classification:
C
State Grid / USGS Quad:
D18NE
303(d) Listed?
Yes
Permit Writer:
Julie Grzyb
Subbasin:
03-07-07 Yadkin
Date:
5/31/13 and 6/10/13
Drainage Area (mi2):
19.1
Summer 7Q10 (cfs)
0.67
Winter 7Q10 (cfs)
1.9
30Q2 (cfs)
Average Flow (cfs):
2.2
17
IWC (%) at 6.2, 8.2, and 10
MGD:
93% , 95%, and
96%
AARIPP
Latitude 35° 56' 14" N Longitude 80°06' 42" W
BACKGROUND
The City of High Point -Westside WWTP is a Class IV facility with a permitted flow of 6.2 MGD. The
last permit renewal was issued on July 10, 2009 and is set to expire on April 30, 2014. In an effort to
upgrade the WWTP, in 2009 the City installed a new preliminary treatment facility with odor control. In
2012 the City completed installation of new tertary filters with a filter feed pump station, additional
ultraviolet disinfection facilities, a new stormwater effluent pump station, solids handling improvements,
and a flood control retaining wall and berm. This application is for a rnajor expansion of the Westside
WWTP from its current capacity of 6.2 mgd to a two-part phased expansion going first to 8.2 mgd followed
by a total capacity of 10 mgd. Expanding to 8.2 mgd will include improvements consisting of converting
the 3 aerations tanks into a 5-stage biological nitrogen removal process and adding a fourth for TN and TP
removal. It will also include the addition of a new nitrified recycle pump station, new clarifier mechanisms
in both primary and secondary clarifiers, the construction of a new secondary clarifier, and supplemental
carbon storage and feed facilities.
The City of High Point negotiated with DWQ to perform a 12 mile stream restoration project as part of the
upgrade and expansion project in order to provide additional receiving stream assimilative capacity for the
expanded discharge in Rich Fork Creek. The stream restoration project vw ill be bid with the 8.2 mgd plant
improvements. The City will perform an intensive monitoring survey of Rich Fork Creek in the summer
following the completion of the stream restoration project. The data collected will be used to recalibrate the
water quality model and then used to validate the DO predictions for the 10 mgd expansion. If the DO
predictions of concentration levels greater than 5 mg/L for the 10 mgd model can not be verified the data
will be used to verify or confirm the DO predictions in the stream model at 8.2 mgd. The January 2008
report titled, "Results of Phase I Monitoring and Model Updates for Rich Fork Creek" by Tetra Tech stated
that the DO concentrations are predicted to remain above 5 mg/L under the restored scenario, even under
permitted discharge concentrations of 5 mg/L of BOD5 and 1 mg/L-N/L of ammonia.
If the modeling or in -stream data does not show sufficient assimilative capacity, the City of High Point will
be required to submit a plan outlining efforts to maximize DO in the WWTP's effluent to ensure in -stream
DO standards are not violated due to the increased discharge from the Westside WWTP. A compliance
Fact Sheet
NPDES NC0021601 Renewal
Page 1

schedule to address the DO deficiency may be added to permit and an expansion to 10 MGD will not be
allowed until sufficient assimilative capacity is available in Rich Fork Creek.
The City of High Point has 1 non -categorical industrial user and 3 categorical industrial users and a full
pretreatment program with the Division of Water Quality's Pretreatment Unit. The City will be required to
continue to implement this program.
STREAM CONDITIONS :
This facility discharges to Rich Fork Creek in subbasin 03-07-07 of the Yadkin River Basin. Rich Fork
Creek is currently classified as C waters and is biologically impaired; it also experiences low dissolved
oxygen conditions, and elevated fecal coliform concentrations. Rich Fork Creek ultimately drains into High
Rock Lake, which is impaired for chlorophyll a and turbidity. TetraTech is under contract for both the
watershed and nutrient response model development. The Modeling and TMDL Unit is scheduled to seek
EMC approval for the High Rock Lake model in 2013. The Stakeholders process will follow.
Instream monitoring is waived as long as this facility is a member of the Yadkin Pee Dee
River Basin Association (YPDRBA). If the facility ends its membership in the Yadkin -Pee
Dee River Association, instream monitoring requirements as specified in this permit take
effect immediately.
The YPDRBA conducts instream monitoring on one station above the WWTP discharge and two stations
below. An Ambient Monitoring Station is also located about one mile downstream of the WWTP discharge.
During the past three years two DO samples were below the minimum instantaneous value of 4 mg/L (3.4
mg/L on 7/27/2010 and 3.9 mg/L on 9/21/2011). The instream DO data is attached.
REASONABLE POTENTIAL ANALYSIS:
Reasonable potential analyses were conducted for: As, Al, Cr, Cd, Cu, CN, Pb, Hg, Mo, Ni, Se, Ag, and Zn
(please see attached).
TOXICITY TESTING:
Type of Toxicity Test: Chronic P/F
Existing Limit: 001: Chronic P/F @ 90%
Recommended Limit: 001: Chronic P/F @ 90%
Monitoring Schedule: January, April, July, October
A review of the last five years of Whole Effluent Testing, Jan. 2008 through Oct. 2011, shows the facility
has consistently passed all 18 WET tests.
COMPLIANCE SUMMARY:
DMRs have been reviewed for the period January 2008 through January 2012. The facility has a mixed
compliance record. During the review period, the following NOVs (notices of violation) have been issued:
May 2008 — BOD; Feburary 2010 — Mercury; April 2011 — BOD; June 2011 — BOD; July 2011 — BOD;
January 2012 — Ammonia-N.
Compliance evaluation inspections conducted on 01/27/2011 and May 2011 found the facility to be in
compliance.
PERMIT LIMIT DEVELOPMENT:
In September 2009 the City of High Point requested speculative limits to increase its current permitted flow
at its Westside WWTP from 6.2 MGD to 10 MGD. In conjunction with the proposed plant upgrade, the City
proposed a stream restoration project to ultimately improve instream dissolved oxygen levels. The City
contracted withTetra Tech Inc. to perform extensive stream sampling and water quality modeling, in order
to predict the water quality impacts in Rich Fork Creek following the proposed plant expansion combined
with the proposed stream restoration activities. Downstream of the WWTP discharge, Rich Fork Creek has
three areas that have been impacted by sand dredging. In these areas, the water tends to pool in the deep
holes that were mined. One of the primary goals of the stream restoration is to fix these holes. While the
model does predict an improvement in downstream DO following the proposed activities, there was
recognized uncertainty in the model, particularly with regard to predictions based on stream restoration
benefits. In light of this uncertainty, DWQ responded with a phased approach in a speculative letter dated
Fact Sheet
NPDES NC0021601 Renewal
Page 2

November 10, 2009. Speculative limits were provided for an initial 2 MGD expansion to 8.2 MGD, with
the understanding that proposed stream restoration activities would be implemented and the model
predictions verified during this initial phase. If stream improvements in DO fall short of the model
projections, the Speculative lettter stated that the City should consider the addition of DO augmentation to
the effluent as an alternative strategy. Speculative limits were provided for an expansion to 10 MGD, which
would only be allowed to proceed pending positive stream improvements.
Water Quality Modeling Results: BOD5/NH3-N Limits: Given the low instream DO levels reported in Rich
Fork Creek, speculative limits for BOD5 and NH3-N were based on freezing current permitted BOD ultimate
loadings. As a result the facility will not be allowed to discharge additional oxygen consuming wastes and
the resultant limits at the expanded flow were considered technologically -feasible. At a flow of 8.2 MGD,
monthly average speculative limits for BOD5 and NH3- N were 4.9 mg/L and 1 mg/L, respectively. Tetra
Tech conducted Qual2e models with summer and winter Waste Load Allocations for BOD5 and NH3-N at
8.2 MGD prior to stream restoration. The model demonstrated that the DO water quality standard would be
maintained under winter conditions with a BOD5 loading of 9.8 mg/L and NH3-N at 2 mg/L. As a result,
seasonal BOD5 and NH3-N limits were given for the 8.2 MGD expansion as follows:
PARAMETER
LIMITS
Monthly
Average
Weekly
Average
Flow
8.2 MGD
BOD, 5 day, 20°C
(April 1 - October 31)
4.9 mg/L
7.4 mg/L
BOD, 5 day, 20°C
(November 1 - March 31)
9.8 mg/L
14.8 mg/L
NH3 as N
(April 1 - October 31)
1.0 mg/L
3.0 mg/L
NH3 as N
(November 1 - March 31)
2.0 mg/L
6.0 mg/L
Dissolved Oxygen
Daily average > 7.0 mg/L
At a flow of 10 MGD, monthly average speculative limits for BOD5 and NH3-N were 4.0 mg/L and 0.8
mg/L, respectively. Again these were based on freezing current permitted BOD ultimate loadings. Tetra
Tech conducted Qual2e models with summer and winter Waste Load Allocations for BOD5 and NH3-N at
10 MGD after stream restoration. These models demonstrated that the DO water quality standard would be
maintained under summer and winter conditions with a BOD5 loading of 5 / 10 mg/L (summer/winter) and
NH3-N loadings of 1 / 1.8 mg/L (summer/winter). Since the City is required to perform an intensive stream
survey after restoration and to recalibrate the model to validate model predictions prior to receiving an
Authorization to Operate at 10 MGD, the seasonal loadings modeled by Tetra Tech are in the permit for 10
MGD. All limitations are subject to modification if the model predictions are not verified.
Effluent dissolved oxygen is expected to be maintained at greater than or equal to 7.0 mg/L under 8.2 and 10
MGD. •
Nutrients: TN and TP Limits: As stated in the Speculative Effluent Limits letter dated 11/10/2009, in the
interim prior to the finalization of the nutrient TMDL for High Rock Lake, Total Phosphorus limits based on
the September 23, 1997 memo from Steve Tedder to Preston Howard were maintained in the phased
expansions. Total Nitrogen limits were frozen at actual loadings between Jan. 2007 and Aug. 2009 and
added in the phased expansion Effluent Limitations pages. The annual load per year was calculated at
159,870 lbs for TN and 13,341 lbs for TP. These limits will remain in the permit until the TMDL or
nutrient management strategies are completed for High Rock Lake.
SEPA/FONSI Determination: The proposed expansion was subject to review by governmental agencies
under the State of North Carolina Environmental Policy Act (SEPA EA), and DWQ has concluded that the
proposed project will not result in significant impacts to the environment. A Finding of No Significant
Impact (FONSI) was issued on November 19, 2010 and is available for inspection at the State
Clearinghouse.
Fact Sheet
NPDES NC0021601 Renewal
Page 3

Antidegradation Review: Per NC Antidegradation Policy (15A NCAC 2B.0201), each applicant for an
NPDES permit expansion must document an effort to consider non -discharge alternatives pursuant to 15A
NCAC 2H.0105(c)(2). This alternatives evaluation was submitted as part of the SEPA EA document, and
resubmitted as an. Engineering Alternatives Analysis (EAA) for the permit review and modification. DWQ
staff reviewed both the flow justification as well as the alternatives analysis. DWQ staff concurred with the
projected flow needs based on a 20-year planning horizon. The service area population is expected to
increase from 30,557 (in 2010) to 47,787 (in 2030). A cost discharge for non -discharge spray irrigation
option for the expanded wastewater volume (3.8 MGD) would require 1,250 acres and a total
project cost of $104 Million; in comparison, the total estimated project cost for expanding the
current WWTP and performing stream restoration for approximately 12 miles was $88 Million,
representing a 18% cost savings. Likewise, DWQ concurred with the alternatives analysis conclusion
that expansion at the current location with a direct discharge to surface water and performing the stream
restoration was the most environmentally sound alternative from all reasonably cost-effective options (per
15A NCAC 2H.0105).
Mercury LimitationDevelopment:
Effluent Mercury Data
Year
2008
2009
2010
2011
2012
# Samples
24
24
23
24
22
Annual Avg.
Concentration (ng/L)
3.9
4.1
7.3
2.6
3.2
Max Annual
Concentration (ng/L)
10
<56
77
10
7
Per the Division guidelines for implementing the mercury TMDL, five years of mercury effluent data was
evaluated. Annual averages for all five years were less than the allowable Water Quality Based Effluent
Limitation of 13 ng/L. One sample value was greater than the Technology Based Effluent Limitation
(TBEL) of 47 ng/L. Per Division guidelines, the City will be given an annual average TBEL of 47 ng/L at a
monitoring frequency of quarterly. The facility will also be required to implement a Mercury Minimization
Plan.
PROPOSED CHANGES:
Supplement to Cover -updated treatment component list
-added ATC requirement to expand to 8.2MGD
-added ATC and demonstration of sufficient assimilative capacity to expand to
10MGD
Section A.(1.) -changed mercury limit from a weekly average to an annual average limit of 0.047
ug/L and added a requirement for a Mercury Minimization Plan (NPDES
Permitting Guidance for 2012 Mercury TMDL).
- reduced TSS, NH3-N, and fecal coliform monitoring frequency from daily to
2/week based on 2012 Monitoring Reduction Frequency Guidance.
- removed cyanide and nickel monitoring, no reasonable potential shown. Facility
will continue to sample for both parameters as part of the permittee's
pretreatment program.
-monitoring for copper, mercury, silver, and zinc were reduced from
2/Month to quarterly
- aluminum did not show reasonable potential to violate the HH fish consumption
std. and as a result, aluminum monitoring was removed from the permit.
-Modified footnote #3 under Section A.(1) with standard TRC language.
Section A.(2.) -added Effluent page for the phased expansion to 8.2 MGD
-TN limits were frozen at actual loadings between Jan. 2007 and Aug.
2009. Seasonal TP limits based on the 9/23/97 memo were combined to
determine an annual mass loadings limitation. Annual limits for TN and
TP were set at 159,870 lbs/yr and 13,341 lbs/yr, respectively.
Fact Sheet
NPDES NC0021601 Renewal
Page 4

Section A(3.)
Section A.(6.)
Section A.(7.)
These limits will remain until the TMDL or nutrient management
strategies are completed.
-added Effluent page for the expansion to 10 MGD contingent upon the stream
restoration project meeting all model predictions that the DO will be
>_ the water quality standard in the restored segment of the receiving
stream. Footnote 8 specifies the conditions to be met prior to an
expansion to 10 MGD, otherwise, if the modeling or in -stream data does
not show sufficient assimilative capacity, the City of High Point shall
submit a plan outlining efforts to maximize DO in the WWTP's effluent
to ensure in -stream DO standards are not violated due to the increased
discharge from theWestside WWTP. In addition, a compliance schedule
to address the DO deficiency may be added to the permit and a
wastewater expansion to 10 MGD will not be allowed.
- added an additional section on calculation and reporting for monthly and annual
TN and TP loads as required in Sections A.(2.) and A.(3.).
- added an additional section on requirements for the MMP
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: Feb. 12, 2013 (est.)
Permit Scheduled to Issue: April 8, 2013 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact Julie
Grzyb at [phone].
NAME:
REGIONAL OFFICE COMMENT:
WSRO concurred with the issuance of this permit.
Shari Bryant of NC Wildlife Resources Commission reviewed the draft and had no comments. 3/12/2013
US EPA COMMENTS:
On March 15, 2013, EPA requested additional time to complete its review of the draft permit because the
fact sheet, application, draft permit and supporting documents did not provide sufficient information;
however, no comments or requests for additional information were received from EPA by the review
deadline of May 20, 2013.
ADDENDUM (6-1-2013)
Changes made to the draft permit sent on February 13, 2013 include:
• The address on the Cover page and Supplement to cover was corrected to 1044 West Burton Road.
• The stream classification listed on the map was corrected to C.
• In accordance with anti -degradation rules and the Implementation of the statewide Mercury TMDL,
US EPA has identified that WWTP's with existing mercury limits based on 12 ng/L, showing
potential to exceed the Technology Based Effluent Limitation of 47 ng/L, are required to continue
complying with their existing limit as an annual average limitation. The effluent sheets in Sections
A.(1), A.(2.), and A.(3.) were corrected accordingly.
• The Monitoring Frequency Reduction guidance has been clarified to primarily apply to existing
permitted flows and sampling data. Facilities with flow expansions associated with treatment
modifications shall resume sampling in accordance with 15A NCAC 2B .0500 until sufficient data
Fact Sheet
NPDES NC0021601 Renewal
Page 5

is collected to demonstrate consistent, long-term treatment performance under modified conditions.
Therefore, sampling for TSS, NH3-N, and Fecal Coliform has been changed to daily in Section
A.(2). Three years of data will be needed to demonstrate consistent, long term treatment
performance under the modified conditions to qualify for a reduction in sampling. Facilities
requesting an expansion with no changes to treatment will be granted previous monitoring
reductions. Therefore, any reductions granted to Westside WWTP under 8.2 MGD will be
continued in the 10 MGD effluent requirements if no significant treatment modifications are made
prior to issuance of the 10 MGD Authorization To Operate. Section A.(3.) was revised to reflect
sampling requirements in Section A.(2.).
Fact Sheet
NPDES NC0021601 Renewal
Page 6

'Coalition Data for DO Upstream and Downstream of Westside WWTP 6/10 - 6/12
date
6/25/2012
6/6/2012
5/30/2012
5/7/2012
4/23/2012
3/26/2012
2/20/2012
1/23/2012
12/5/2011
11/7/2011
10/10/2011
9/26/2011
9/7/2011
8/29/2011
8/9/2011
7/18/2011
7/6/2011
6/27/2011
6/7/2011
5/24/2011
5/2/2011
4/4/2011
3/14/2011
2/14/2011
1/30/2011
12/6/2010
11/8/2010
10/18/2010
9/28/2010
9/14/2010
8/24/2010
8/10/2010
7/27/2010
7/13/2010
6/29/2010
6/15/2010
Q5745000 Q5785000
upstream Downstream
7.4
7.8
7.6
7.4
7.8
8
11.1
10.7
9.6
8.5
7.9
7.6
7.8
7.5
7.4
7.5
7.7
7.3
6.9
8.2
7.5
8.7
8.9
10.4
10
10.4
8.8
8.5
7.7
7.3
6.7
6.8
6.4
6.8
6.2
6.3
upstream downstrm
Q5790000 AMS station ^' 1 mi Q5780000
3.8 mi ^' 9 mi DWSTRM
6.3 6.6
6.3 6.9 WQS - not Tess than a daily average of 5.0
6.4 6.7 mg/L with a minimum instantaneous value
5.8 6.6 of not Tess than 4.0 mg/L.
6.5 7.2
6.7 7.3
9.4 9.7
9.1 9.3
7.5 8
6.7 7.2
6.3 6.8
6.2 6.8
6.3 6.7
6 6.7
5.7 6.3
6.3 6.9
6.2 6.9
5.6 6.3
5.7 6.2
7 7.5
7 7.4
7.9 8.1
8.6 8.4
9.8 10.2
9.7 10.4
7.5 8
6.9 7.3
6.1 6.5
6.6 6.8
6.1 6.4
5.2 5.6
4.6 5.3
3.4 4.1
5.6 5.8
5.3 5.2
5.4 5.8
12/14/2011 13:02
11/7/2011 14:40
10/11/2011 15:30
9/21/2011 15:00
9.4
12.1
5.3
3.9
8/4/201115:30 5.2
7/7/2011 14:45 4.6
6/22/2011 13:11 4.9
5/23/2011 13:30 6.3
4/7/2011 14:20
3/8/2011 15:05
2/8/2011 15:40
1/20/2011 14:45
12/9/2010 14:35
11/3/2010 15:30
10/14/2010 17:00
9/9/2010 15:00
8.6
11.2
10.3
11.5
10.6
6.4
7.4
4.8
8/26/2010 15:00 5.3
7/22/2010 14:30 5.1
6/3/2010 15:20 6.8

City of High Point, West side REASONABLE POTENTIAL ANALYSIS
NC0024228
Qw (MGD) = 6.20
IQ10S(cfs)= 0.59
7Q l OS (cfs) = 0.70
7QIOW(cfs)= 1.90
30Q2 (cfs) = 2.20
Avg. Stream Flow, QA (cfs) = 17.00
Receiving Stream: Rich Fork Creek
WWTP/WTP Class: IV
IWC @ 1QIOS = 94.22%
IWC @7Q10S= 93.21%
IWC @ 7Q1OW = 83.49%
IWC @ 30Q2 = 81.37%
IWC@QA= 36.11%
Stream Class: C
()Lift!' I-
Qw=6.2 MGD
CHRONIC TEST CONCENTRATION = DEFAULT %
= 90
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
PQL
UNITS
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS / Applied V2 FAV /
Chronic Standard Acute
Max Pred
n " Det. CNN'Allowable Cw
Arsenic
Arsenic
C
C
50 FW(7Q10s)
10 HH/WS(Qavg)
ug/L
ug/L
8 0
Note: n < 9
Limited data se
8 0
Note: n <_ 9
16.7
Default C.V.
16.7
Default C.V.
Acute: NO WQS
_ _____ ____
Chronic: 53.6
No o value > Allowable Cw_
Chronic: 27.7-------------------------
No value > Allowable Cw
all samples < 10 ug/L
_________________________
— —
Cadmium
NC
2 FW(7Q10s) 15
ug/L
121 0
1.2
Acute: 15.9
_ ---- _ ---
Chronic:—2.1
No value > Allowable Cw
_
all samples <2, <1, <0.15, and <0.1 ug/L
-----------------------
--- --
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
8 5
Note: n < 9
Limited data set
89.9
Default C.V.
Acute: NO WQS
Chronic: 368.7
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
— -
Chromium
NC
50 FW(7Q10s) 1022
ug/L
119 16
4.3
Acute: 1,084.7
---- -------------------------------
Chronic: 53.6
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw- No
Monitoring required
Copper (AL)
NC
7 FW(7QI0s) 7
ug/L
110 99
231
Acute: 7.7
-------
Chronic:75
57 valueO > Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
----------------------------
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
30 0
5.0
Acute: 23.3
__ _ ---- _ ---
Chronic:—5.4
No value > Allowable Cw
all samples <10 ug/L
----------------------—-----
Lead
NC
25 FW(7QI0s) 33.8
a /L
I I y .-•
18.8
Acute: 35.9
Chronic — — 26.8 --
No value > Allowable Cw
_
No RP , Predicted Max ? 50 % of Allowable Cw -
defer to LTMP
----------------------------
Mercury
NC
12 FW(7Q10s)
0.5
ne/L
t > Ir,
,.e' A
Acute: NO WQS
Chronic:---- ---------------------------------
12.9
I value(s)> Allowable Cw
_
RP for non -AL - apply Monthly Monitoring with Limit
Molybdenum
NC
2000 HH(7QI0s)
ug/L
8 0
Note: n <— 9
Limited data set
8.3
Default C.V.
Acute: NO WQS
Chronic: 2,145.7
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Page 1 of 2
Final NC0024228 high_point west RPA10.xlsm, rpa
2/13/2013

City of High Point, West side
NC0024228
REASONABLE POTENTIAL ANALYSIS
Outfall 1
Qw = 6.2 MGD
Nickel
NC
88 FW(7QIOs) 261
ug%I.
119 19
5.7
Acute: 277.0
---- ---------------------------------
Chronic: 94.4
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Selenium
NC
5 FW(7Q10s) 56
ug/L
7 0
Note: n < 9
Limited data set
17.7
Default C.V.
Acute: 59.4
_ _ ___ _ ____
Chronic: 5.4
No value > Allowable Cw
all samples <10 ug/L
_ __________________________
Silver (AL)
NC
0.06 FW(7QIOs) l.'_3
u,/L
118 1
7.380
Acute: 1.305
_ _____ _ ___
Chronic: 0.064
118 value(s) > Allowable CNN.
all samples < PQL except one = 6 ug/L
_ _ _ _ _ _ _ _ _ _ ______
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
Zinc (AL)
NC
50 FW(7Q10s) 67
uc/L
I 1 1 99
1 1 1.4
Acute: 71.1
---- ---^---------------------------
Chronic: 53.6
26 value(s) > Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
Aluminum
NC
8000 HH(7QIOs)
uu/L
112 95
5,824.0
Acute: NO WQS
---- ---------------------------- Chronic:8,582.8
No value > Allowable Cw
No RP , Predicted Max >_ 50% of Allowable Cw -
defer to LTMP
Page 2 of 2
Final NC0024228 high_point west RPA10.xlsm, Taw
2/13/2013
•

City of High Point, West side REASONABLE POTENTIAL ANALYSIS
NC0024228
Qw (MGD) = 8.20
IQ10S(cfs)= 0.59
7Q1 OS (cfs) = 0.70
7QI OW (cfs) = 1.90
30Q2 (cfs) = 2.20
Avg. Stream Flow, QA (cfs) = 17.00
Receiving Stream. Rich Fork Creek
WWTP/WTP Class: IV
IWC @ 1QIOS = 95.56%
IWC @ 7Q10S = 94.78%
1WC @ 7QI OW = 87.00%
IWC @ 30Q2 = 85.24%
IWC @ QA = 42.78%
Stream Class: C
Outfall 1.
Qw = 8.2 MGD
CHRONIC TEST CONCENTRATION = DEFAULT %
= 90
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)co
PQL
Z
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS / Applied '/2 FAV /
Chronic Standard Acute
Max Fred
1-1 4 Det. Cw Allowable Cw
Arsenic
Arsenic
C
C
50 FW(7Q10s)
10 HH/WS(Qavg)
ug/L
ue/L
8 0
Note: n < 9
Limited data set
8 0
Note: n <_ 9
16.7
Default C.V.
16.7
Default C.V.
Acute: NO WQS
_ _ _____ ____
Chronic: 52.8
N_o value > Allowable Cw
Chronic: 23.4
No value> Allowable Cw
all samples < 10 ug/L
_________ - - - - _ _ - - -
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Cadmium
NC
2 FW(7Q10s) 15
ug/I.
121 0
1.2
Acute: 15.7
_ _______ __------_-_-----------------_--
Chronic: 2.1
No value > Allowable Cw
all samples <2, <1, <0.15, and <0.1 ug/L
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
8 5
Note:n<9
Limited data set
89.9
DcfaultC.V.
Acute: NO WQS
Chronic:---_ 351.9---_-_---------------_-_-----.
No value> Allowable Cw
No RP, Predicted Max < 50"/ of Allowable Cw - No
Monitoring required
Chromlum
NC
50 FW(7Q10s) 1022
a /I.
119 16
4.3
Acute: 1,069.5
---- ---�----------------------------
Chronic: 52.8
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Copper (AL)
NC
7 FW(7Q10s) 7
ug/L
110 99
231
Acute: 7.6
--------
Chronic:7.4
57 value(s)> Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
---
---------------- --------,
Cyanide
NC
5 FW(7QIOs) 22
10
ug/L
50 0
5.0
Acute: 23.0
_ ______ __--
Chronic:5.3
No value > Allowable Cw
all samples <10 ug/L
_---_----------------_-_---.
Lead
NC
25 FW(7Q10s) 33.8
ug/L
119
18.8
Acute: 35.4
Chronic:---- _-__-
26.4
No value > Allowable Cw
No RP , Predicted Max a 50% of Allowable Cw -
defer to LTMP
____________________________
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
49 -16
282.6
Acute: NO WQS
_ _____ __--
Chronic:12.7
1 value(s)> Allowable Cw
RP for non -AL - apply Monthly Monitoring with Limit
_-----------_------_--------
Molybdenum
NC
2000 HH(7Q10s)
ug/L
8 0
Note: n < 9
Limited data set
8.3
Default C.V.
Acute: NO WQS
Chronic: 2,110.1
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required -
Page 1 of 2
Final NC0024228_high_point_west RPA10.xlsm, rpa
2/13/2013

City of High Point, West side
NC0024228
REASONABLE POTENTIAL ANALYSIS
Outfall 1
Qw = 8.2 MGD
Nickel
NC
88 FW(7Q10s) 261
ug/L
119 19
5.7
Acute: 273.1
_
_ —_—_ _
Chronic_ 92.8
No value> Allowable Cw
No RP, Predicted Max <50% of Allowable Cw - No
Monitoring required _ _ _ — — —
Selenium
NC
5 FW(7Q10s) 56
ug/L
7 0
Note: n < 9
Limited data sel
17.7
Dclaul7C.V.
Acute: 58.6
----- -_-
Chronic: 5.3
No value > Allowable Cw
an samples <10 ug/L
_-------_-_-----------------
Silver(AL)
NC
0.06 FW(7Q10s) 1.23
ug/L
118 1
7.380
Acute: 1.287
_ _______ _ __
Chronic:0.063
118 value(s) > Allowable Cw
all samples < PQL except one = 6 ug/L
_ _ _ _ _ _ _ _ _ _ _ ______
RP for AL(Cu,Zn,Ag,Fe,CI) apply Quarterly
Monitoring in conjunction with TOX Test
Zinc (AL)
NC
50 FW(7Q10s) 67
ug/L
III 99
I 11.4
Acute: 70.1
---- ------------------------------
Chronic:52.8
26 value(s)> Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
Aluminum
NC
8000 1-HH(7Q10s)
ug/L
112 95
5.824.0
Acute: NO WQS
---------------------------------
Chronic:8,44IA
No value > Allowable Cw
No RP , Predicted Max a. 50% of Allowable Cw -
defer to LTMP
Page 2 of 2
Final NC0024228_high_point_west RPA10.xlsm, rpa-
2/13/2013

City of High Point, West side REASONABLE POTENTIAL ANALYSIS
NC0024228
Qw (MGD) = 10.00
IQ10S(cfs)= 0.59
7QIOS (cfs) = 0.70
7QIOW(cfs)= 1.90
30Q2 (cfs) = 2.20
Avg. Stream Flow, QA (cfs) = 17.00
Receiving Stream: Rich Fork Creek
WWTP/WTP Class: IV
IWC rQ 1Q1OS = 96.33%
IWC eQ 7QIOS = 95.68%
IWC Q 7Q 1OW = 89.08%
IWC Q 30Q2 = 87.57%
IWC @ QA = 47.69%
Stream Class: C
Outfall '!
Qw=10MGD
CHRONIC TEST CONCENTRATION = DEFAULT %
=90i„
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
J
a
F
z
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS / Applied V2 FAV /
Chronic Standard Acute
Max Pred
tl Det. Cw Allowable Cw
Arsenic
Arsenic
C
C
50 FW(7Q10s)
10 HI-I/WS(Qavg)
ug/L
ug/L
8 0
Note: n < 9
Limited data se
8 0
Note: n <_ 9
16.7
Default C.V.
16.7
Dcfault C.V.
Acute: NO WQS
_ _ _____ ____
Chronic: 52.3
N_ o value _> Allowable Cw —
Chronic: — 21.0
No value > Allowable Cw
all samples < 10 ug/L
___________________________
— — — — — — — — — — — — —
Cadmium
NC
2 FW(7Q10s) 15
ug/L
121 0
1.2
Acute: 15.6
_ _ ----- _ ---
Chronic:-2.1
No value > Allowable Cw
at samples <2, <1, <0.15, and <0.1 ug/L
-------------------------- --
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
8 5
Note: n < 9
Limited data set
89.9
Dcfault C.V.
Acute: NO WQS
Chronic: 342.6
No value> Allowable Cw
No RP, Predicted Max < 50 % of Allowable Cw - No
Monitoring required
Chromium
NC
50 FW(7Q10s) 1022
--
nil.
119 16
4.3
Acute: 1,060.9
Chronic:---- 52.3------------------------------�
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Copper (AL)
NC
7 FW(7Q10s) 7
ug/L
110 99
231
Acute: 7.6
--------
Chronic:7.3
57 value(s) > Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
---------------------------
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
50 0
5.0
Acute: 22.8
_
_ ---- ---
Chronic:—5.2
No value > Allowable CW
all samples <10 ug/L
------------------------- ---
Lead
NC
25 FW(7Q10s) 33.8
ug/L
119 5
18.8
Acute: 35.1
----- ------------------------------
Chronic: 26.1
No value > Allowable Cw
No RP , Predicted Max a 50% of Allowable Cw -
defer to LTMP
Mercury
NC
12 FW(7Q1Os)
0.5
ng/l.
49 -{6
2S'6
Acute: NO WQS
_ _ _
Chronic: ---- 12.5---
1 value(s)> Allowable Cw
RP for non -AL - apply Monthly Monitoring with Limit
----------------------------
Molybdenum
NC
2000 HH(7Q10s)
u,vl
8 0
Note: n<9
Limited data set
8.3
Default C.V.
Acute: NO WQS
hronic-----2,090.3--
Chronic:_____2,090.3__
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
----------------------------
Page 1 of 2
Final NC0024228_highj,oint_west RPA10.xlsm, rpa
2/13/2013

City of High Point, West side
NC0024228
REASONABLE POTENTIAL ANALYSIS
Outfall 1
Qw = 10 MGD
Nickel
NC
88 FW(7Q10s) 261
ua/L
119 19
5.7
Acute: 270.9
---- -------------------------------
Chronic: 92.0
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Selenium
NC
5 FW(7Q10s) 56
ug/L
7 0
Note: n < 9
Limited data set
17.7
Default C.V.
Acute: 58.1
Chronic: 5.2
No value > Allowable Cw
all samples <10 ug/L
Silver (AL)
NC
0.06 FW(7Q10s) 1.23
ug/L
118 1
7.380
Acute: 1.277
Chronic: 0.063
118 value(s) > Allowable Cw
all samples < PQL except one = 6 ug/L
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
Zinc (AL)
NC
50 FW(7Q10s) 67
ug/L
Ill 99
111.4
Acute: 69.6
---- ---
Chronic: 52.3
26 value(s)> Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
-----------------•----------
Aluminum
NC
8000 HH(7Q10s)
utz/L
112 95
5,824.0
Acute: NO WQS
---- -
Chronic:8,361.2No value > Allowable Cw
No RP , Predicted Max >_ 50% of Allowable Cw -
defer toLTMP
--
-----------------------
Page 2 of 2
Final NC0024228_high_point west RPA10.xtsm, rpa-
2/13/2013

REASONABLE POTENTIAL ANALYSIS
1
Arsenic - FW Standard
Date Data
2/1/2010
10/1/2009
10/1/2009
7/1/2009
6/1/2011
4/1/2011
4/1/2009
1/1/2009
BDL=1/2DL Results
5 Std Dev. 0.0000
5 Mean 5.0000
5 C.V. (default) 0.6000
5 n 8
5
5 Mult Factor =
5 Max. Value
5 Max. Pred Cw
10
10
10
10
10
10
10
10
USE ONLY
"PASTE
SPECIAL -
Values" W1TH
"COPY"
3.33
5.0 ug/L
16.7 ug/L
4
Cadmium
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 1
17 0.075
18 1
19 1
20
21 7/1/2011 0.15 0.075
22 0.15 0.075
23 1 0.5
24 0.15 0.075
25 0.15 0.075
26 6/1/2011 1 0.5
27 1 0.5
28 1 0.5
29 1 0.5
30 1 0.5
31 5/1/2011 1 0.5
32 1 0.5
33 1 0.5
34 1 0.5
35 1 0.5
36 4/1/2011 1 0.5
37 1 0.5
38 1 0.5
39 1 0.5
40 1 0.5
41 3/1/2011 1 0.5
42 1 0.5
43 1 0.5
44 1 0.5
45 1 0.5
46 2/1/2011 1 0.5
47 1 0.5
48 1 0.5
49 1 0.5
50 1 0.5
51 1/1/2011 1 0.5
52 1 0.5
53 1 0.5
54 1 0.5
55 1 0.5
56 12/1/2010 1 0.5
57 1 0.5
58 1 0.5
59 1 0.5
Date
11/1/2011
10/1/2011
Data
0.15
0.15
0.15
0.15
BDL=1/2DL Results
0.075 Std Dev.
0.075 Mean
0.075 C.V.
0.075 n
9/1/2011
8/1/2011
0.15
0.15
0.15
0.15
0.15
2
2
2
0.1
2
0.15
2
2
0.075
0.075
0.075
0.075
0.075
1
1
1
0.05
Mult Factor =
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values"
WITH
0.1856
0.4719
0.3934
121
1.23
1.0 ug/L
1.2 ug/L
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 1 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
11/1/2010
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1/1/2010
12/1/2009
11 /1 /2009
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 2 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
Total Phenolic Compounds
Date
Data
11/1/2011
10/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
1/1/2011
16
27
25
25
22
27
25
26
BDL=1/2DL
16
27
12.5
12.5
22
27
12.5
26
Results
Std Dev.
Mean
C.V. (default)
n
Mult Factor =
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
6.7635
19.4375
0.6000
8
3.33
27.0 ug/L
89.9 ug/L
8
Chromium
Date
Data
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1/2010
11 /1 /2010
5
5
5
5
5
5
5
5
5
5
5
5
5
5
BDL=1/2DL
3
2
1
2
3
3
3
2
2.5
2.5
2.5
4
4
3
2.5
2
3
3
3
3
3
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
0.2923
2.5378
0.1152
119
1.07
4.0 ug/L
4.3 ug/L
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 1 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1/1/2010
12/1/2009
11 /1 /2009
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 2 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
Copper (AL)
Date Data
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1/2010
11/1/2010
7
4
4
5
19
4
10
88
15
4
4
21
10
6
3
4
4
2
19
4
6
3
4
5
4
7
6
4
4
2
14
5
8
11
7
14
21
10
34
20
15
12
20
14
8
8
5
24
6
12
6
6
39
7
5
11
17
7
BDL=1/2DL
7
4
4
5
19
4
10
88
15
4
4
21
10
6
3
4
4
1
19
4
6
3
4
5
4
7
6
4
4
2
14
5
8
11
7
14
21
10
34
20
15
12
20
14
8
8
2.5
24
6
12
6
6
39
7
2.5
11
17
7
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
21.9801
16.3545
1.3440
110
1.82
127.0 ug/L
231.1 ug/L
10
Cyanide
Date
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1/2010
11/1/2010
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1 /2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1/1/2010
12/1/2009
11/1/2009
Data
BDL=1/2DL
10 5
Results
Std Dev.
Mean
C.V.
n
Mult Factor=
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
0.0000
5.00
0.0000
50
1.00
5.0 ug/L
5.0 ug/L
-1-
Final NC0024228_high_point_west RPA10ver2.xlsm, data
3/15/2013

REASONABLE POTENTIAL ANALYSIS
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1 /1 /2010
12/1/2009
11/1/2009
5
6
5
5
6
5
6
7
6
6
14
43
54
6
12
9
5
5
15
11
37
12
29
5
20
14
18
25
15
7
9
83
127
85
7
6
5
6
11
7
33
5
10
20
9
18
9
88
52
47
96
31
2.5
6
2.5
5
6
2.5
6
7
6
6
14
43
54
6
12
9
2.5
2.5
15
11
37
12
29
2.5
20
14
18
25
15
7
9
83
127
85
7
6
2.5
6
11
7
33
2.5
10
20
9
18
9
88
52
47
96
31
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 2 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
Lead
Date Data
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1/2010
11/1/2010
0.5
0.5
0.5
0.5
0.8
0.5
4
0.7
0.5
10
10
10
0.5
10
12
10
10
10
0.5
10
10
0.5
0.5
0.5
0.5
2.5
0.5
0.5
0.5
0.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
BDL=1/2DL
0.25
0.25
0.25
0.25
0.8
0.25
4
0.7
0.25
5
5
5
0.5
5
12
5
5
5
0.25
5
5
0.25
0.25
0.25
0.25
1.25
0.25
0.25
0.25
0.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
1.4785
1.5063
0.9815
119
13
Mercury
1.57
12.0 ug/L
18.8 ug/L
Date
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1/2010
11/1/2010
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1/1/2010
12/1/2009
11 /1 /2009
Data
Cw
3
3
1
2
2
2
1
3
1
1
3
3
3
2
10
3
4
2
5
5
3
1
4
5
3
4
3
10
2
4
3
4
6
6
2
6
4
5
2
5
4
77
3
3
4
5
4
4
2
BDL=1/2DL
3
3
1
2
2
2
1
3
1
1
3
3
3
2
10
3
4
2
2.5
2.5
3
0.5
4
5
3
4
3
10
2
4
3
4
6
6
2
6
4
5
2
5
4
77
3
3
4
5
4
4
2
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Value?' WITH
"COPY"
10.6815
4.9286
2.1673
49
3.67
77.0 ng/L
282.6 ng/L
-1-
Final NC0024228_highpoint_west RPA10ver2.xlsm, data
3/15/2013

REASONABLE POTENTIAL ANALYSIS
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1 /1 /2010
12/1/2009
11 /1 /2009
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 2 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
14
Molybdenum
Date
oil/ZU1 I
4/1/2011
1/1/2010
10/1/2009
10/1/2009
7/1/2009
4/1/2009
1 /1 /2009
Data
5
5
5
5
5
5
5
5
BDL=1/2DL Results
2.5 Std Dev.
2.5 Mean
2.5 C.V. (default)
2.5 n
2.5
2.5 Mult Factor =
2.5 Max. Value
2.5 Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
0.0000
2.5000
0.6000
8
15
Nickel
3.33
2.5 ug/L
8.3 ug/L
Date Data BDL=1/2DL Results
1 11/1/2011 2 2 Std Dev.
2 2 2 Mean
3 2 2 C.V.
4 2 2 n
5
7
8
9
10
11
12
13
14
15
16 8/1/2011 J,a 10 5
17 10 5
18 r 10 5
19 10 5
20
21 7/1/2011 10 5
22 2 2
23 10 5
24 10 5
25
26 6/1/2011 1.5 1.5
27 2.3 2.3
28 10 5
29 1.8 1.8
30 2.1 2.1
31 5/1/2011 2.2 2.2
32 2 2
::
33 �.,�� 1.8 1.8
34 :_ 1.9 1.9
35
36 4/1/2011 ' 10 5
37 ,, 10 5
38 10 5
39 10 5
40 10 5
41 3/1/2011 10 5
42 10 5
43 10 5
44 10 5
45 10 5
46 2/1/2011 10 5
47 10 5
48 10 5
49 10 5
50 10 5
51 1/1/2011 10 5
52 10 5
53 10 5
54 10 5
55 10 5
56 12/1/2010 10 5
57 10 5
58 10 5
59 10 5
60 10 5
61 11/1/2010 10 5
62 10 5
63 10 5
64 10 5
6 10/1/2011
9/1/2011
3
3
3
3
2
10
10
10
3
3 Mult Factor =
3 Max. Value
3 Max. Pred Cw
3
2
5
5
5
3
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
1.0325
4.5597
0.2265
119
1.13
5.0 ug/L
5.7 ug/L
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 1 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1/1/2010
12/1/2009
11/1/2009
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 2 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
16
Selenium
Date
4/1/2011
1/1/2010
10/1/2009
10/1/2009
7/1/2009
4/1/2009
1 /1 /2009
Data
10
10
10
10
10
10
10
BDL=1/2DL Results
5 Std Dev.
5 Mean
5 C.V. (default)
5 n
5
5 Mult Factor =
5 Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
0.0000
5.0000
0.6000
7
3.54
5.0 ug/L
17.7 ug/L
17
Silver (AL)
Date
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1/2010
11/1/2010
Data
BDL=1/2DL
0.5 0.25
0.5 0.25
0.5 0.25
0.5 0.25
O F
0.5
0.5
0.5
C
5
0.5
0.5
0.5
5
0.5
O.E.
0.5
0.5
0.5
0.5
0.25
0.25
0.25
0.25
6
2.5
2.5
2.5
0.25
2.5
0.25
2.5
2.5
0.25
2.5
2.5
2.5
0.25
2.5
0.25
2.5
0.25
0.25
0.25
0.25
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
0.8676
2.2055
0.3934
118
1.23
6.000 ug/L
7.380 ug/L
-1-
Final NC0024228_high_point_west RPA10ver2.xlsm, data
3/15/2013

REASONABLE POTENTIAL ANALYSIS
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
10/1/2010
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1 /1 /2010
12/1/2009
11 /1 /2009
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 2 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
18
Zinc (AL)
Date Data
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1 /2010
11/1/2010
32
28
31
30
28
29
31
26
22
30
41
57
24
41
38
37
38
42
25
38
39
26
26
27
25
25
26
21
22
19
44
28
33
35
25
59
69
56
69
49
65
52
61
64
55
62
48
68
57
72
72
73
68
78
60
58
80
57
BDL=1/2DL Results
32 Std Dev.
28 Mean
31 C.V.
30 n
28 Mult Factor =
29 Max. Value
31 Max. Pred Cw
26
22
30
41
57
24
41
38
37
38
42
25
38
39
26
26
27
25
25
26
21
22
19
44
28
33
35
12.5
59
69
56
69
49
65
52
61
64
55
62
48
68
57
72
72
73
68
78
60
58
80
57
USE ONLY
"PASTE
SPECIAL -
Values" WITH
"COPY"
19
Aluminum
17.6575
40.1712
0.4396
111
1.28
87.0 ug/L
111.4 ug/L
Date
11/1/2011
10/1/2011
9/1/2011
8/1/2011
7/1/2011
6/1/2011
5/1/2011
4/1/2011
3/1/2011
2/1/2011
1/1/2011
12/1/2010
11/1/2010
Data
BDL=1/2DL Results
610 610 Std Dev.
306 306 Mean
464 464 C.V.
318 318 n
322 322 Mull Factor =
713 713 Max. Value
505 505 Max. Pred Cw
4160 4160
863 863
1260 1260
1160 1160
1230 1230
797 797
1150 1150
967 967
1620 1620
1810 1810
1230 1230
1180 1180
1210 1210
1630 1630
1030 1030
648 648
1190 1190
1090 1090
1330 1330
1400 1400
977 977
1020 1020
899 899
812 812
1110 1110
920 920
750 750
730 730
760 760
1120 1120
1320 1320
930 930
1110 1110
680 680
980 980
840 840
1920 1920
1490 1490
1040 1040
2060 2060
1280 1280
1380 1380
1200 1200
1490 1490
1303 1303
1030 1030
960 960
990 990
1470 1470
820 820
1370 1370
990 990
USE ONLY
"PASTE SPECIAL -
Values" WITH
"COPY"
COMMAND
581.8561
899.5893
0.6468
112
1.40
4160.000000 ug/L
5824.000000 ug/L
10/1/2010
46
51
46
51
10/1/2010
500 250
1730 1730
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 1 - 3/15/2013

REASONABLE POTENTIAL ANALYSIS
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
9/1/2010
8/1/2010
7/1/2010
6/1/2010
5/1/2010
4/1/2010
3/1/2010
2/1/2010
1/1/2010
12/1/2009
11/1/2009
•a
43
47
25
25
25
29
25
25
35
46
38
46
49
61
46
38
42
47
46
39
25
25
28
25
35
38
43
46
25
70
87
66
66
34
36
31
39
43
42
40
33
36
42
36
33
25
25
36
31
28
25
43
47
12.5
25
12.5
29
12.5
12.5
35
46
38
46
49
61
46
38
42
47
46
39
12.5
12.5
28
12.5
35
38
43
46
12.5
70
87
66
66
34
36
31
39
43
42
40
33
36
42
36
33
12.5
12.5
36
31
28
12.5
68 1670 1670
69 870 870
70
71 9/1/2010 500 250
72 %< 500 250
73 630 630
74 720 720
75 920 920
76 8/1/2010 r a 910 910
77 500 250
78 610 610
79 ° 500 250
80
81 7/1/2010 710 710
82 1130 1130
83 '=` 3520 3520
84 760 760
85 800 800
86 6/1/2010 ti° 890 890
87 530 530
88 r 930 930
89 640 640
90
91 5/1/2010 500 500
92 510 510
93 500 250
94 500 500
95
96 4/1/2010 r t 500 250
97 500 250
98 1130 1130
99 n 670 670
100 650 650
101 3/1/2010 500 250
102 500 250
103 730 730
104 1040 1040
105
106 2/1/2010 500 250
107 700 700
108 x 540 540
109 500 500
110
111 1/1/2010 610 610
112 500 250
113 600 600
114 690 690
115 850 850
116 12/1/2009 720 720
117 500 250
118 500 250
119500 250
120
121 11/1/2009 500 250
122 ; 610 610
123 `-3 500 250
124 510 510
125 ;€ 530 530
Final NC0024228_high_point_west RPA10ver2.xlsm, data
- 2 - 3/15/2013

Ev-
1/29/13 WQS = 12 ng/L MERCURY WQBEL/TBEL EVALUATION V:2012-4
Facility City of High Point, Westside WWTP I Annual Limit 13 ng/L with
Name: I Quarterly Monitoring
Total Mercury 1631E PQL = 0.5 ng/L 7410s = 0.700 cfs WQBEL = 12.87 ng/L
Date Modifier Data Entry Value Permitted Flow= 6.200 MGD TBEL = 47 ng/L
1/4/2010
1/19/2010
2/3/2010
2/16/2010
3/2/2010
3/16/2010
4/6/2010
4/20/2010
5/4/2010
5/25/2010
6/7/2010
7/6/2010
7/20/2010
8/2/2010
8/17/2010
9/7/2010
9/21/2010
10/5/2010.
10/19/2010
11/2/2010.
11/23/2010
12/7/2010
12/21/2010
1/19/2011.
1/31/2011 <
2/15/2011 <
2/22/2011 <
3/8/2011
3/21/2011
4/12/2011 iiiii
4/28/2011
5/2/2011
5/24/2011
6/6/2011
6/21/2011
7/12/2011
7/19/2011
8/2/2011
8/17/2011
9/13/2011
9/28/20110_
1O/6/2011 it
10/18/2011
11/4/2011
11/18/2011...
12/14/2011
12/28/2011
1/6/2012
1/25/2012`
0.
2/9/2012
2/28/2012
3/9/2012
3/21/2012.
3 3
4 4
77
3
5
4
5
2 2
e 6
4
2
6
6
3 3
4 4
2 2
4 4
3 3
+0 10
3 3
a 4
4
5 5
3 3
1 0.5
5 2.5
5 2.5
4 4
2 2
10 10
3 3
3 3
2
3 3
3 3
1 1
1 1
1 1
3 3
2 2
2 2
1 1
2 2
3 3
3 3
2 2
2 2
7 7
3 3
2 2
2 2
3 3
5 5
]7
7.3 ng/L - Annual Average for 2010
2.6 ng/L -Annual Average for 2011
4/4/2012 5 5
4/18/2012 7 7
5/10/2012 4 4
5/23/2012 2 2
6/15/2012 2 2
6/28/2012 2 2
7/11/2012 3 3
7/25/2012 4 4
8/9/2012 2 2
8/21/2012 2 2
9/4/2012 2 2
9/20/2012 2 2
10/3/2012 2 2
10/18/2012 2 2
11/6/2012 4 4
11/29/2012 3 3
1/7/2008 2 2
1/22/2008 4 4
2/4/2008 2 2
2/18/2008 4 4
3/3/2008 3 3
3/17/2008 2 2
4/8/2008 3 3
4/28/2008 3 3
5/5/2008 5 5
5/19/2008 10 10
6/2/2008 3 3
6/16/2008 7 7
7/15/2008 3 3
8/4/2008 < 1 0.5
7/28/2008 3 3
8/18/2008 8 8
9/2/2008 2 2
9/15/2008 5 5
10/7/2008 4 4
10/20/2008 3 3
11/3/2008 2 2
11/17/2008 3 3
12/1/2008 6 6
12/15/2008 5 5
1/5/2009 4 4
1/20/2009 5 5
2/2/2009 4 4
2/16/2009 4 4
3/2/2009 5 5
3/16/2009 4 4
4/6/2009 2 2
4/14/2009 3 3
5/4/2009 2 2
5/18/2009 3 3
6/1/2009 2 2
6/15/2009 2 2
7/6/2009 2 2
7/14/2009 3 3
8/3/2009 2 2
8/17/2009 2 2
9/23/2009 2 2
9/1/2009 < 56 28
3.2 ng/L- Annual Average for 2012
3.9 ng/L - Annual Average for 2008

10/8/2009 2
10/19/2009 3
11/2/2009 4
11/16/2009 2
12/7/2009 5
12/21/2009 4
2
3
4
2
5
4
4.1 ng/L - Annual Average for 2009
Annual Averages < allowable WQBEL- No WQBEL needed
One value > 47 so Annual Avg. limit of 47 ng/L plus a MMP
will be added to the permit.
Quarterly monitoring using 1631E analysis

NC032422 ( City of Iligh Point-1Vestside WWII'
, MONITORING FREQUENCY REDUCTION REVIEW
BOD
1) Requirement: mean < 50% of monthly average
Calc. weighted monthly average
(7/12 ' 5) + (5/12 ' 10 7.08 mg/L wt. monthly average Three year mean 4.42 mg/L
50%= 7.08/2= 3.54 4.42 mean > 3.54 or 50% of the weighted monthly average limitation
Also NOTE: 3.61 > 2.5 or 50% of theSummer Monthly average Three year summer mean 3.61 mg/L
5.67 > 5.0 or 50% of the winter monthly average Three year winter mean 5.67 mg/L
2) No more than 15 daily samples can be > 200% of the weekly summer(7.5 mg/L) or winter (15 mg/L) average limit
only two daily samples > summer or winter weekly average
3) Sampling results shall not show more than two non -monthly avg. limit violations in past year
Not more than 2 samples > 7.5 mg/L in the summer or 15 mg/L in the winter during the past year
1 sample > winter weekly limit in the past year
Reduced monitoring not allowed for BOD
TSS
1) Requirement: mean < 50% of monthly average
50% of Monthly average limit of 30 mg/L
=15 mg/L
Three year mean 5.16 mg/L
5.16 mg/L < 15 mg/L or 50% of the monthly average
2) No more than 15 daily samples can be > 200% of the weekly average limit
200/100` 45= 90 mg/L
No samples > 90 mg/L
3) Sampling results shall not show more than two non -monthly avg. limit violations in past year
Not more than 2 samples > 45 mg/L in past year
No values > 45 mg1L in last year
Statistically analysis shows TSS sampling frequency can be reduced
NH3-N
1) Requirement: mean < 50% of monthly average
Calc. weighted monthly avg. (7/12'2)+(5/12'4)= 2.83 mg/L
50% of Monthly wt. monthly average limit of 2.83 mg/L Three year mean 1.08 mg/L
=1.415 mg/L
1.08 mg/L < 1.415 mg/L or 50% of the wt. monthly average
2) No more than 15 daily samples can be > 200% of the weekly summer(6 mg/L) or winter (12 mg/L) average limit
No daily summer or winter values > 200% of the seasonal weekly limits
3) Sampling results shall not show more than two non -monthly avg. limit violations in past year
Not more than 2 wkly avg limit > 6 mg/I in the summer and 12 mg/L in the winter during the past year
One wkly avg. winter limit violation in Nov. 2012
Statistically analysis shows NH3-N sampling frequency can be reduced
Fecal Coliform
1) Requirement: geomean < 50% of monthly average limit
50% of Monthly average limit of 200/100 mL
= 100/100 mL
Three year mean 3.42 / 100 mL
3.42 < 100 or 50% of monthly avg.limit
2) No more than 20 daily samples can be > 200% of the weekly average limit
200/100 * 400/100 mL = 800/100 mL
Eight samples > 200% of the weekly average limit
3) Sampling results shall not show more than two non -monthly avg. limit violations in past year
Not more than 2 samples > 400/100 mL in past year
2 samples > 400/100 mL in last year
Statistically analysis shows Fecal Coliform sampling frequency can be reduced

NPDES/Aquifer Protection Permitting Unit Pretreatment Information Request Form
PERMIT WRITER COMPLETES THIS PART:
PERMIT WRITERS - AFTER you get this form back
Check that
f
from PERCS:
all apply
Notify PERCS if LTMP/STMP data we said should be
Date of Request
12/8/2011
municipal renewal
on DMRs is not really there, so we can get it for you
Requestor
Julie Grzyb
new industries
(or NOV POTW).
Facility Name
High Point Westside
WWTP expansion
v
- Notify PERCS if you want us to keep a specific POC
Permit Number
NC0024228
Speculative limits
in LTMP/STMP so you will have data for next permit
ReRegion
9
WSRO
stream reclass.
renewal.
-Email PERCS draft permit, fact sheet, RPA.
Basin
Yadkin
outfall relocation
- Send PERCS paper copy of permit (w/o NPDES
7Q10 change
boilerplate), cover letter, final fact sheet. Email RPA if
other
changes.
other
check
applicable PERCS staff:
Other Comments to PERCS:
BRD, CPF, CTB, FRB, TAR - Sarah Morrison (807-6310)
'/
CHO, HIW, LUM, LTN, NES, NEW, ROA, YAD - Monti
Modification is from 6.2 MGD to 8.2 MGD and up to 10 MGD if the City
Hassan (807-6314)
demonstrates sufficient assimilative capacity in the receiving stream
after stream restoration.
PERCS
Status
PRETREATMENT STAFF COMPLETES THIS PART:
of Pretreatment Program (check all that apply)
1) facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE
2) facility has no SIU's, does not have Division approved Pretreatment Program
v
3) facility has Sills and DWQ approved Pretreatment Program (list "DEV" if program still under development)
v
3a) Full Program with LTMP
3b) Modified Program with STMP
4) additional conditions regarding Pretreatment attached or listed below
Flow, MGD
Permitted
Actual
Time period for Actual
STMP time frame:
Industrial
0.559
0.26
Jan 09-Apr 2011
Most recent:
Uncontrollable
n/a
3.44
Jan 09-Apr 2011
Next Cycle:
POC in LIMP/
STMP
Parameter of
Concern (POC)
Check List
POC due to
NPDESI Non-
Disch Permit
Limit
Required by
EPA*
Required
by 503
Sludge**
POC due
to SIU"'
POTW POC
(Explain
below)""
STMP
Effluent
Freq
LTMP
Effluent
Freq
1
BOD
q
4
M
-1
TSS
d
4
M
Q = Quarterly
-/
NH3
v`
M
M = Monthly
Arsenic
-
Cadmium
4
M
4
Chromium
4
M
4
Copper
41
'1
M
4
Cyanide
-4
M
is all data on DMRs?
d
Lead
NI
-I
M
YES
4
Mercury
4
M
NO (attach data)
Molybdenum
J
Nickel
4
M
V
Silver
M
Selenium
4
Zinc
4
41
M
Is data in spreadsheet?
NI
Total Nitrogen
M
YES (email to writer)
4
Phosphorus
d
M
NO
Al
Phenols
M
'
Organics
'l
M
i
Aluminum
M
*Always in the LTMP/STMP
" Only in LTMP/STMP if sludge and app or composte (dif POCs for incinerators)
"" Only in LTMP/STMP while SIU still discharges to POTW "" Only in LIMP/STMP when pollutant is still of concern to POTW
Comments to Permit Writer (ex., explanation of any POCs; info you have on IU related investigations into NPDES problems):
All
sludge from the Westside Plant is transported to the Eastside Plant for incineration. There is no sampling of sludge for the Westside
Long-
term monitoring plan. Method 624 and 625 organics are sampled at the influent and effluent and at the 2 industries categorized under 40
CFR 414- OCPSF. Al and phenols are sampled in the effluent only.
High Point Westside NPDES request Feb 2013.x1sx
Revised- July 24, 2007

2012 North Carolina 303(d) List -Category 5
Yadkin -Pee Dee River Basin
> AU Number
'Jame
10-digit Watershed 0304010302
Length or Area
Abbotts Creek
Units Classification
Category Rating Use Reason for Rating Parameter
Year
> 12-119-7-3
Hunts Fork
From source to Rich Fork
7.1 FW Miles C 5
5 Impaired Aquatic Life
Fair Bioclassification Ecological/biological Integrity Benthos
1998
1
> 12-119-7a
Rich Fork
From source to Payne Creek
8.5 FW Miles C
5 Impaired Aquatic Life
Standard Violation Turbidity
2012
5
> 12-119-7b1
Rich Fork
From Payne Creek to SR1790
3.8 FW Miles C
5 Impaired Aquatic Life
Poor Bioclassification Ecological/biological Integrity FishCom
1998
5
12-digit Subwatershed
030401030202
Tom-A-Lex Lake-Abbotts Creel
> 12-119-(1)
Abbotts Creek
From source to a point 0.5 mile upstream of Davidson County SR 1810 18.8
FW Miles
WS-HI 5
5 Impaired Aquatic Life
Fair Bioclassification Ecological/biological Integrity FishCom 2008
Yadkin -Pee Dee River Basin
10-digit Watershed 0304010303
High Rock Lake
12-digit Subwatershed
030401030302
Crane Creek -High Rock LakE
> 12-(108.5)b2
YADKIN RIVER
(including upper
portion of High Rock
Lake below normal
operating level)
From Buck Steam Plant to a line across High Rock Lake at the downstrearr 2,927.9
side Swearing Creek Arm
FW Acres WS-V 5
5 Impaired Aquatic Life Standard Violation Chlorophyll a
2008
Friday, August 24, 2012
Approved by EPA August 10, 2012
Page 159 of 170

IWC Calculations
Facility: Westside VVWTP
NC0024228
Prepared By: Julie Grzyb
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
6.2
0.67
1.9
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
0.67
6.2
9.61
17.0
0
93.48
18
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
1.07 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I
4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter)
5. BAT for Major Municipals: 1 mg/I (year-round)
0.67
6.2
9.61
1.0
0.22
93.48
1.1
1.9
6.2
9.61
1.8
0.22
83.49
2.1
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)
NPDES Server/Current Versions/WLA; TB 1/16/2009

Grzyb, Julie
FroIn: Bryant, Shari L.
Sent: Tuesday, March 12, 2013 9:51 AM
To: Grzyb, Julie
Subject: RE: draft permit modification for the High Point Westside WWTP expansion
Julie,
Thank you for sending a copy of the draft permit. We have reviewed it and have no comments.
Shari Bryant
N.C. Wildlife Resources Commission
P.O. Box 129
Sedalia, NC 27342-0129
336.449.7625
[e-mail]
Get NC Wildlife Update -- news including season dates, bag limits, legislative updates and more -- delivered to your Inbox from
the N.C. Wildlife Resources Commission.
From: Grzyb, Julie
Sent: Monday, February 18, 2013 11:39 AM
To: Hassan, Monti; Meadows, Susan; Reid, Steve; Bryant, Shari L.
Subject: draft permit modification for the High Point Westside WWTP expansion
Attached please find the draft permit modification for the High Point Westside WWTP expansion (NC0024228).
Please review and comment by the end of the Public Notice period — March 22, 2013.
Thanks,
Julie
Julie A. Grzyb, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
NPDES Complex Permitting, Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6389 (wk); 919/807-6495 (fax)
julie.Rrzyb(d»zcdenr jov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be disclosed
to third parties.
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
1

City of High Point
Public Services Department
ADMINISTRATION DIVISION
NORTH CAROLINA'S INTERNATIONAL CITY
March 15, 2013
Mr. Jeff Poupart, Point Source Branch Supervisor
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1671 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Draft NPDES Permit Modifications
Permit NC0024228
High Point Westside WWTP
Facility Class IV
Davidson County
Dear Mr. Poupart:
The City of High has received and reviewed the draft permit for the Westside WWTP dated February 13, 2013. The only
issue that the City would like to discuss is the mercury annual limit of 47 ng/L.
A mercury sample was taken and the results were abnormal on September 1, 2009. The commercial laboratory provided
additional information specifying the reported <0.056 ug/L result was not defensible and the data was then qualified as
unreliable when the DMR was signed and submitted on October 30, 2009. This <0.056 ug/I was not used in the Reasonable
Potential Analysis (RPA). The proposed mercury permit limit is a result of one sample that occurred on February 3, 2010.
The result entered on the DMR was 0.077 ug/L. A second sample taken on February 16, 2010 resulted in a number of 0.003
ug/L, which is below the current permit limit. (See Attachment 1)
On February 3, 2010, a result similar to the September 1, 2009 result was reported but was not disqualified by the
commercial laboratory. The commercial laboratory provided the appropriate supporting quality control that did not indicate
any issues with the February 3, 2010 sample. However it is the City of High Point's belief the following issues may have
contributed to the higher than normal result:
(a) Throughout the 10 day period surrounding the positive result in February 2010, the plant experienced
severe disruptions. Data was qualified for multiple analyses other than mercury performed during the period that
could not meet appropriate QC criteria due to the disruptions in the plant which caused analytical interferences. One
disruption was unusual foaming similar to the event in September 2009. (See Attachment 2)
(b) On the commercial laboratory's bench sheet, only one sample is noted as "foamy". As 1
the sample is from another client. Due to the clear issues we documented in the plant, we suspe
on the bench sheet may have been mislabeled.
P.O. 230. High Point. NC 27261 USA
Phone: [phone] Fax: [phone] TDD: 336.883.8517

(c) One of the other significant issues noted concerning the February 2010 sample was a prolonged and mixed
wet and frozen weather event. While we make every effort not to sample during wet weather events, this sampling
event could not be avoided. Given the clearly documented evidence of excessive atmospheric mercury levels, if the
result is valid and was not inadvertently mislabeled on the bench sheet, it is unlikely that the high mercury reading
is from the actual waste stream and much more likely to be from atmospheric contamination. (See Attachment 3)
(d) We believe this is further supported by the fact that none of the other individual metals or polyatomic ion
contaminants were above average levels nor was there non-compliance for any other parameter. In other words, the
plant was experiencing issues causing analytical interference but not disrupted treatment or non-compliance. (See
Attachment 4)
We have also reviewed mercury accumulation levels in our sludge analysis reports. There are indications of higher levels in
some months more than others but data does not suggest that they were higher during the months when either of these
results was reported.
We also respectfully request that DWQ consider that the Westside plant was under construction when the September 2009
and February 2010 samples were taken. When we discovered this connection, we made every effort to coordinate with the
project construction superintendent to terminate construction activities completely during mercury sampling in case an
unknown contamination had occurred.
The City of High Point would like to meet and discuss this issue with you and your staff to help explain why the mercury
limit should be removed from our permit.
Thank you,
(_..m4_,_
Terry L. Houk
Assistant Director of Public Services
City of High Point
Cc: W. Chris Thompson P.E., Public Services Director
John Hodges, Wastewater Plants Manager
Bill Frazier, Laboratory Manager
Tim Fitzgerald, Wastewater Superintendent
Mike Swan, Westside WWTP ORC
Dawn Molnar, Laboratory Supervisor
Carrie Boyd, Industrial Pretreatment Supervisor
Charles Wakild, P.E. Director (NCDENR)
Julie A. Grzyb, Environmental Engineer (NCDENR)
File

ATTACHMENT 1
0.1000
0.0900
0.0800
0.0700
0.0600
uup
0
t 0.0500
(11
C
c
0
u 0.0400
0.0300
0.0200
0.014
Westside 5-yr Mercury Discharge Summary
<0.0560
i
0.0100
n.onsn
•
See Snapshot for Week of 2/1/10
WS EFF Hg+
Mercury Average
WS Limit
Linear (WS EFF Hg+)
0.0100 0.0100
o°\ ,6 ,§;\ co e o°� e e e e e e e oti° e oti° otiti otiti otiti otiti
�\ti \�\ti \�\ti ti�\�\� y\�\ti \��ti \�\ti yo\%\ co' R ti \cb\ti yo\q,\ y\�\ti R\R\ti \�\' yo\e�ti y\�\ti ' RP' ti�\4\�
Date
Prepared by Carrie Boyd March 2013

ATTACHMENT 2
WS EFF Snapshot
Week of February 1, 2010
12.0 18
10.0
8.0
6.0 -
4.0
2.0
0.0
7
<2.5
L61
16
Flir sample Collected
0.077 p0/L
1.5
5.7
13.4
12
75
5.1
3
<2.5
1.24
7
13.5
11.4
4
2/1/10 2/2/10 2/3/10 2/4/10 2/5/10
Date
16
14
12
10
8
6
4
2
Concentration (mg/L)
1BOD
I ITSS
® Ammonia
—1,— FLOW
Permitted Flow
— — - Avg FLOW
Prepared by Came Boyd March 2013

ATTACHMENT 3
WEATHER CONDITIONS — WESTSIDE WWTP
WEEK PRIOR TO FEBRUARY 1, 2010
On January 27th, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 46.4F
Low Temp: 26.6F
Average Temp: 36.6F
Dewpoint: 20F
Wind Speed: 7.6 Knots
Precipitation Amount: 0 Inches
Snow Depth: n/a
Observations: n/a
On January 28th, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 61F
Low Temp: 27F
Average Temp: 41.4F
Dewpoint: 24F
Wind Speed: 6.7 Knots
Precipitation Amount: 0 Inches
Snow Depth: n/a
Observations: n/a
On January 29th, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 52F
Low Temp: 28.4F
Average Temp: 39.8F
Dewpoint: 15.6F
Wind Speed: 7.3 Knots
Precipitation Amount: n/a
Snow Depth: n/a
Observations: Snow/Ice Pellets
Source: htto://www.farmersalmanac.com/weather-history
1

ATTACHMENT 3
WEATHER CONDITIONS — WESTSIDE WWTP
WEEK PRIOR TO FEBRUARY 1, 2010
On January 30th, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 28.9F
Low Temp: I9.4F
Average Temp: 24.1 F
Dewpoint: 20. I F
Wind Speed: 10.1 Knots
Precipitation Amount: 0.45 Inches
Snow Depth: 3.1 Inches
Observations: Fog, Rain/Drizzle, Snow/Ice Pellets
On January 3I st, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 37.4F
Low Temp: 12.2F
Average Temp: 23.4F
Dewpoint: 13.3F
Wind Speed: 2.7 Knots
Precipitation Amount: 0.21 Inches
Snow Depth: 3.1 Inches
Observations: Snow/Ice Pellets
Source: htto://www.farmersalmanac.com/weather-history
2

ATTACHMENT 3
WEATHER CONDITIONS — WESTSIDE WWTP
WEEK OF FEBRUARY 1, 2010
On February 1st, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 46.9F
Low Temp: 15.1 F
Average Temp: 29.7F
Dewpoint: I4F
Wind Speed: 2 Knots
Precipitation Amount: 0 Inches
Snow Depth: 2 Inches
Observations: n/a
On February 2nd, 2010, the closest available weather station to 'Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 46.9F
Low Temp: 15. I F
Average Temp: 33.9F
Dewpoint: 25F
Wind Speed: 3 Knots
Precipitation Amount: 0.32 Inches
Snow Depth: 2 Inches
Observations: Rain/Drizzle
On February 3rd, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 46.4F
Low Temp: 28.4F
Average Temp: 37F
Dewpoint: 30.6F
Wind Speed: 4.4 Knots
Precipitation Amount: 0.15 Inches
Snow Depth: 2 Inches
Observations: Fog, Rain/Drizzle
Source: http://www.farmersalmanac.com/weather-history
3

• ATTACHMENT 3
WEATHER CONDITIONS — WESTSIDE WWTP
WEEK OF FEBRUARY 1, 2010
On February 4th, 2010, the closest available weather station to Thomasville, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 48.9F
Low Temp: 30.2F
Average Temp: 36F
Dewpoint: 23.7F
Wind Speed: 3.5 Knots
Precipitation Amount: 0 Inches
Snow Depth: n/a
Observations: n/a
On February 5th, 2010, the closest available weather station to Thomas% ille, NC (GREENSBORO PIEDMONT TRIAD INT, NC), reported the
following conditions:
High Temp: 41F
Low Temp: 31.1 F
Average Temp: 35F
Dewpoint: 29.5F
Wind Speed: 9.1 Knots
Precipitation Amount: 0.21 Inches
Snow Depth: 1.2 Inches
Observations: Rain/Drizzle,
Snow/Ice Pellets
Source: http://www.farmersalmanac.com/weather-history
4

ATTACHMENT 4
0.1600
0.1400
0.1200
0.1000
J
E
0
m 0.0800
C
m
C
0
u
0.0600
0.0400
0.0200
0.0000
0. o
2 i rn z
Westside
5yr Metals Avg Summary
0,0800
0.0700
J
oa 0.0600
E
0.0500
0
m
0.0400
C 0.0300
v
C 0.0200
0
v
0.0100
0.0000
lan-10
February 2010
Feb
Month
Mar
in Z • v- °1i Z c 0) ro z • '° Z
co m H (0
Month
Cd
Cr
Cu
Pb
NI
Ag
Zn
Hg
Cd
Cr
Cu
Pb
Ni
Ag
Zn
Hg
Prepared by Carrie Boyd March 2013

42008346 J000423358
AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA LEXINGTON, NC February 15, 2013
DAVIDSON COUNTY
I, Lynn Bowers OF THE DISPATCH, A NEWSPAPER PUBLISHED IN THE CITY OF LEXINGTON, COUNTY AND STATE
AFORESAID, BEING DULY SWORN, SAYS THE FOREGOING LEGAL OF WHICH THE ATTACHED IS A TRUE COPY,
WAS PUBLISHED IN SAID NEWSPAPER ONCE, BEGINNING THE 15th DAY OF February, 2013.
PUBLICATION FEE: $ 87.00
SWOR
AND SUBSCRIBED EFORE ME, THIS /7 DAY OF
MY COMMISSION EXPIRES
Ad Copy:
Public Notice
North Carolina
Environmental Management
Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
The North Carolina
Environmental Management
Commission proposes to issue
a NPDES wastewater
discharge permit to the
person(s) listed below. Written
comments regarding the
proposed permit will be
accepted until 30 days after the
publish date of this notice. The
Director of the NC Division of
Water Quality (DWQ) may hold
a public hearing should there
be a significant degree of
public interest. Please mail
comments and/or information
requests to DWQ at the above
address. Interested persons
may visit the DWQ at 512 N.
Salisbury Street, Raleigh, NC
to review information on file.
Additional information on
NPDES permits and this notice
may be found on our website:
http://portal. ncdenr.orq/web/wq/
swp/ps/npdes/calendar, or by
calling [phone]. The
City of High Point requested a
permit modification for an
expansion of its Westside
WWTP (NC0024228) in
(2-1(p-coi(D
Davidson County; this
permitted discharge is treated
municipal wastewater to Rich
Fork Creek, Yadkin -Pee Dee
River Basin.
February 15, 2013
\\��\\gO N L MYF ////'�i
Notary Public
Davidson County ::
My Commission Empties=_

AwA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E. Skvarla, III
Governor Director Secretary
Mr. W. Chris Thompson, P.E. Director
The City of High Point, Public Services
P.O. Box 230
High Point, NC 27261
February 6, 2013
Subject: Response to City's comments on Pre -Draft NPDES
Permit modification (NC0024228)
High Point Westside WWTP
Davidson County
Dear Mr. Thompson,
In response to the City of High Point's comments dated 8/31/2012, regarding the Pre -draft permit modification
and the modeling information submitted on 11/9/2012, 12/14/2012, and 1/9/2013 by Mr. Trevor Clements, the
Division offers the following changes to the proposed draft permit modification for the phased expansions.
1. Paragraphs 2 and 3 in the Supplement to Cover Sheet will be revised to read as follows:
After receiving the proper Authorization to Construct a 10 MGD WWTP and the
Authorization to Operate an 8.2 MGD WWTP from the Division of Water Quality,
construct the facilities and operate the Westside WWTP at a permitted flow of 8.2
MGD, and,
After receiving the proper Authorization to Operate a 10 MGD WWTP from the
Division of Water Quality, as well as Division approval based on positive
demonstration of sufficient assimilative capacity in the receiving stream, operate
facilities giving Westside WWTP a treatment capacity of 10 MGD.
2. Provide justification of the ammonia -nitrogen limitation of 0.8 mg/L
Dissolved oxygen concentrations below the water quality standard have been measured
in Rich Fork Creek. To protect the receiving stream, BOD and ammonia -nitrogen limits
in the Speculative limits letter were based on freezing the 2009 permitted BOD ultimate
loading. This loading was calculated to be 9821b/day. Therefore, at 10 MGD the BODu
is calculated to be 11.8 mg/L [982 lb/d T(10 MGD x 8.34)]. Thus, BOD5 was set at 4
mg/L and ammonia -nitrogen at 0.8 mg/L to freeze the BOD ultimate at 11.8 mg/L
(BOD5 of 4 x 2=8 mg/L plus NH3 of 0.84 x 4.5= 3.8 mg/L for a total of 11.8 BOD
ultimate). These speculative limits were revised based on subsequent modeling
projections.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone]
Internet www.ncwateroualitv.oro
An Equal Opportunity \ Affirmative Action Employer
One Na
Naturally

Page 2 of 5
3. In response to the City of High Point's request for seasonal ammonia -nitrogen and BOD
limits in Sections A(2) and Section A(3):
Section A.(2.) at 8.2 MGD prior to stream restoration:
The Qual2e modeling analysis submitted to the Division on Dec. 14, 2012 with the
scenarios: summer and winter WLA runs for an 8.2 MGD discharge to the existing
channel should the plant expansion be completed prior to the stream channel restoration,
demonstrated that until the stream restoration is completed the minimum dissolved
oxygen water quality standard is not likely to be achieved in the receiving stream,
downstream of the WWTP. This supports the need for the stream restoration and
justifies the need to freeze the 2009 BOD ultimate loading. The winter scenario did
show that the minimum dissolved oxygen water quality standard would be maintained
prior to restoration. Therefore, seasonal limits for Section A.(2) will be listed as follows
in the draft Hermit:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
WeeklyMeassurement
Average
Frequency
Sample
Type
Sample Locatiron 1
Flow
8.2 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day, 20°C
(April 1- October 31)
4.9 mg/L
7.4 mg/L
Daily
Composite
Influent & Effluent
BOD, 5 day, 20°C
(November 1- March 31)
9.8 mglL
14.8 mglL
Daily
Composite
Influent & Effluent
NH3 as N
(April 1- October 31)
1.0 mglL
3.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1- March 31)
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen
Daily average > 7.0 mg/L
Daily
Grab
Effluent
Section A.(3.) at 10 MGD after stream restoration and Division approval to expand:
The Qual2e modeling analysis submitted to the Division on Nov. 9, 2012 with the
scenarios: summer and winter WLA runs for 8.2 MGD and 10 MGD discharges to the
existing channel after stream restoration is completed, demonstrated that the minimum
dissolved oxygen water quality standard is likely to be achieved in the receiving stream,
downstream of the WWTP. Since the City will have to demonstrate that DO water
quality standards are being achieved in the receiving stream before receiving an
Authorization to Operate a 10 MGD WWTP from the Division of Water Quality,
Section A.(3) will be revised in the draft permit as follows:
PARAMETER
LIMITS . ; .
MONITORING REQUIREMENTS .:.
Monthly
Average
. - Weekly
Average ..
Measurement
Frequency
Sample
Type
SampleLocationl
Flow
10 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day, 20°C
(April 1- October 31)
5 mg/L
7.5 mglL
Daily
Composite
Influent & Effluent
BOD, 5 day, 20°C
(November 1- March 31)
10 mg/L
15.0 mg/L
Daily
Composite
Influent & Effluent
NH3 as N
(April 1- October 31)
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
•
NH3 as N
(November 1- March 31)
1.8 mg/L
5.4 mg/L
Daily
Composite
Effluent
Dissolved Oxygen
Daily average > 7.0 mglL
Daily
Grab
Effluent

•
• Page 3 of 5
If the City shows that there is sufficient assimilative capacity at 8.2 MGD, after the
stream restoration project is completed, and the City does not intend to proceed to
request an ATO for 10 MGD as planned, the City can request a minor permit
modification to insert the modeled BOD and ammonia -nitrogen seasonal limits that
demonstrated sufficient assimilative capacity at 8.2 MGD.
4. The draft permit has been revised to reflect the NPDES Permitting Strategy for the 2012
Statewide Mercury TMDL as follows:
The past five years of mercury data were reviewed and annual averages for 2008
through 2012 were less than the Water Quality Based Effluent Limitation determined for
the Westside WWTP. One sample was greater than the Technology Based Effluent
limitation of 47 ng/L (2/3/2010 sample at 77 ng/L). Therefore, an annual average
mercury limitation of 47 mg/L will be added to the permit with quarterly monitoring
using EPA Method 1631. Major POTW's receiving an annual average limit are also
required to develop and implement a Mercury Minimization Plan (MMP). A special
condition was added to the permit on the MMP requirements.
5. The final permit will include the Nov. 2011 standard conditions.
If the City would like to review these conditions they can be found on the DWQ
website under NPDES - Hot Topics: *NEW* NPDES Standard Conditions
(November 2011).
6. The City requested that the Annual Pollutant scan be changed to require three scans within
the five year permit cycle to be consistent with federal NPDES requirements.
Effluent pages and Section A.(8.) were revised accordingly.
7. The City requested that monitoring be reduced in accordance with the new DWQ Guidance
regarding the Reduction of Monitoring Frequencies in NPDES Permits dated October 22,
2012.
As required by the Guidance, the past three years of monitoring data was reviewed for
BOD5, TSS, NH3-N, and Fecal Coliform. The statistical analysis determined that
reduced monitoring for TSS and fecal coliform to 2 times per week (2/week) could be
granted. Reduced monitoring for BOD5 and NH3-N could not be granted. Attached is
a sheet containing details on the results of the analysis. The effluent sheets in Sections
A. (1), (2), and (3) were revised accordingly.
8. The City requested specific revisions to Footnote 8(d) in Section A(3).
Requested language revisions were inserted into the paragraph, if appropriate.
Please note, Dissolved Oxygen(DO) concentrations in the receiving stream
downstream of the Westside WWTP have been reported at concentrations below the
NC water quality standard. The Division has agreed to allow the City of High Point to
proceed with the first part of the expansion (to 8.2 MGD) given that the model
predictions submitted by the City show that the stream restoration will result in
improved DO, in the restored segment, at concentration levels equal to or above the
water quality standard. If the recalibrated model predictions or in -stream DO data,
performed and collected after stream restoration, do not validate that the NC DO water
quality standard is being maintained than additional mitigative action by the permittee
will be required and the Authorization to Operate at 10 MGD will not be approved by
the Division.

Page 4 of 5
Footnote 8(d) and (e) were revised as follows:
8.(d)Following the intensive monitoring survey, after the stream restoration project is
completed, the receiving water quality model for Rich Fork Creek will be
recalibrated for the approximately 12 mile segment between the High Point
Westside outfall and the confluence of Abbotts Creek, to reflect the revised physical
conditions of the stream due to the restoration project. The recalibrated model will
be rerun with existing flow, 8.2 MGD, and 10 MGD to analyze the impact of the
discharge. Model results will be compared with previous predictions and observed
profiles to determine the level of impact on dissolved oxygen concentrations. The
results of the modeling analyses and the recalibrated models at 8.2 MGD and10
MGD shall be submitted to DWQ for review. Submit 2 copies of the modeling
report and all associated modeling files to DWQ/ NPDES and one copy to the
DWQ/MTU/Unit Supervisor for review. An electronic copy of the model should be
included with the copy sent to DWQ/MTU for a proper review. The City of High
Point will be allowed to proceed with an expansion or an Authorization to Operate
request at 10 MGD upon DWQ approval, based upon validation of model
predictions that in -stream dissolved oxygen water quality standards will be
maintained in the restored segment of the receiving stream.
8.(e) If the recalibrated models or in -stream DO data in the restored segment of Rich Fork
Creek do not show sufficient assimilative capacity, the City of High Point shall
submit a plan outlining efforts to maximize DO in the WWTP's effluent to ensure
in -stream DO water quality standards are not violated due to the discharge from the
Westside WWTP. Three copies of the DO optimization plan shall be submitted to
DWQ/ NPDES. A compliance schedule to address the DO deficiency may be added
to this permit and an Authorization to Operate at a capacity of 10 MGD will not be
allowed until the City demonstrates that the receiving stream has sufficient
assimulative capacity to support the increased discharge.
9. The City requested that footnote 8(e) in Section A(3) be deleted.
For reasons discussed above, footnote 8(e) will remain in the permit with some
minor revisions.
10. The City requested that the TN and TP monitoring frequency under Section A(4) Instream Monitoring
Requirements, be reduced to once per month.
The TN and TP instream monitoring frequency of 2/month was an error and the permit was
corrected to 1/month.
11. The City requested that DWQ clarify whether the metals sample should be taken with the first or
second 24-hour composite sample for toxicity testing.
The DWQ Aquatic Toxicity Unit stated that both composite samples are expected to be
representative wastewater samples; therefore, testing for the metals using either composite
sample is adequate.
12. The City requested a specific footnote be added to each effluent page.
The requested footnote can be found in the *NEW* NPDES Standard Conditions
(November 2011) on page 11 under Section E, 5. b.

• Page 5 of 5
If you should have any questions concerning the responses to your comments, please contact me by
e-mail (julie.grzyb@a,ncdenr.gov) or call me at [phone]. The draft permit modification for
the High Point Westside WWTP is completed and will be Public Noticed and sent to you on Feb.
13, 2013. The City will have 30 days from receipt of the permit to submit comments.
Respectfully,
Julie A. Grzyb
Environmental Engineer, NPDES Complex Permitting Unit
cc: NPDES
Winston-Salem Regional Office / Surface Water Protection Section
Mr. Timothy Fitzgerald, WWTP Superintendent, City of High Point, PO Box 230, High Point, NC 27261
Mr. Terry Houk, Assistant Director, Water & Sewer, City of High Point (e-copy)

NC0024228 City of High Point - Westside WWTP
• MONITORING FREQUENCY REDUCTION REVIEW
BOD
1) Requirement: mean < 50% of monthly average
Cate. weighted monthly average
(7/12 * 5) + (5/12 * 10) 7.08 mg/L wt. monthly average Three year mean 4.42 mglL
50%= 7.08/2= 3.54 4.42 mean > 3.64 or 50% of the weighted monthly average limitation
Also NOTE: 3.61 > 2.6 or 50% of theSummer Monthly average Three year summer mean 3.61 mg/L
5.67 > 5.0 or 50% of the winter monthly average Three year winter mean 5.67 mg/L
2) No more than 15 daily samples can be > 200% of the weekly summer(7.5 mglL) or winter (15 mglL) average limit
only two daily samples > summer or winter weekly average
3) Sampling results shall not show more than two non -monthly avg. Limit violations in past year
Not more than 2 samples > 7.5 mg/L In the summer or 15 mg/L In the winter during the past year
1 sample > winter weekly limit In the past year
Reduced monitoring not allowed for BOD
TSS
1) Requirement: mean < 50% of monthly average
50% of Monthly average limit of 30 mg/L
=15 mg!L
Three year mean 5.16 mg!L
5.16 mg/L < 15 mg/L or 50% of the monthly average
2) No more than 15 daily samples can be > 200% of the weekly average limit
200/100 * 45= 90 mg/L
No samples > 90 mg/L
3) Sampling results shall not show more than two non -monthly avg. limit violations In past year
Not more than 2 samples > 45 mglL in past year
No values > 45 mg/L In last year
Statistically analysis shows TSS sampling frequency can be reduced
NH3-N
1) Requirement: mean < 50% of monthly average
Calc. weighted monthly avg. (7/12*2)+(5/12*4)= 2.83 mglL
50% of Monthly wt. monthly average limit of 2.83 mg/L Three year mean 1.08 mg/L
=1.415 mg/L
1.08 mg/L < 1.415 mg/L or 50% of the wt. monthly average
2) No more than 15 daily samples can be > 200% of the weekly summer(6 mglL) or winter (12 mglL) average limit
No daily summer or winter values > 200% of the seasonal weekly limits
3) Sampling results shall not show more than two non -monthly avg. limit violations In past year
Not more than 2 samples > 6 mgll in the summer and 12 mglL In the winter during the past year
Three samples > 6 mg/I In the summer or 12 me/L in the winter during the past year
Reduced monitoring not allowed for NH3-N
Fecal Coliform
1) Requirement: geomean < 50% of monthly average limit
50% of Monthly average limit of 200/100 mL Three year mean 3.42 / 100 mL
= 100/100 mL
3.42 < 100 or 50% of monthly avg.iimit
2) No more than 20 daily samples can be > 200% of the weekly average limit
200/100 *400/100 mL = 800/100 mL
Eight samples > 200% of the weekly average limit
3) Sampling results shall not show more than two non -monthly avg. Emit violations In past year
Not more than 2 samples > 400/100 mL to past year
2 samples > 400/100 mL In last year
Statistically analysis shows Fecal Coliform sampling frequency can be reduced

High Point Westside WWTP Expansion Qual2e Modeling Analysis
January 10, 2013
The tables below summarize the differences in the Summer 7Q10 Existing Channel Model and the
Summer 7Q10 Restored Channel Model:
Table 1. Channel Velocity and Depth
Existing (summer 7Q10)
Restored (summer 7Q10) _
Reach
Velocity
Depth
Velocity
Depth
1
1.310
0.95
0.710
1.03
2
0.180
3.52
0.710
1.03
3
0.285
1.57
0.710
1.03
4
0.285
1.73
0.710
1.03
5
0.580
1.10
0.710
1.03
6
0.565
1.07
0.710
1.03
7
0.400
1.77
0.710
1.03
8
0.180
3.52
0.710
1.03
9
0.580
1.10
0.710
1.03
10
0.100
3.52
0.710
1.03
11
0.639
0.89
0.710
1.03
12
0.639
0.89
0.710
1.03
13
0.639
0.89
0.710
1.03
14
0.639
0.89
0.710
1.03
15
0.639
0.89
0.710
1.03
16
0.639
0.89
0.710
1.03
Table 2. BOD Decay Rate, Sediment Oxygen Demand
Existing (summer 7Q10)
Restored (summer 7Q10)
Reach
BOD Decay
Rate
SOD
BOD Decay
Rate
SOD
1
0.320
0.149
0.202
0.149
2
0.300
0.145
0.202
0.145
3
0.280
0.140
0.202
0.140
4
0.200
0.130
0.202
0.130
5
0.130
0.119
0.202
0.119
6
0.130
0.111
0.202
0.111
7
0.100
0.100
0.202
0.100
8
0.100
0.093
0.202
0.093
9
0.100
0.083
0.202
0.083
10
0.100
0.075
0.202
0.075
11
0.100
0.075
0.202
0.075
12
0.100
0.075
0.202
0.075
13
0.100
0.075
0.202
0.075
14
0.100
0.075
0.202
0.075
15
0.100
0.075
0.202
0.075
16
0.100
0.075
0.202
0.075
1

Table 3. Initial Conditions: Temperature, DO, BOD
Existing (summer 7Q10)
Restored (summer 7Q10)
Reach
Temperature
DO
BOD
Temperature
DO
BOD
1
76.64
7
0.75
75.7
7
2.00
2
75.56
6
0.75
75.7
7
2.00
3
75.02
5
0.75
75.7
7
2.00
4
74.66
5
0.75
75.7
7
2.00
5
74.30
5
0.75
75.7
7
2.00
6
73.76
4
0.75
75.7
7
2.00
7
73.22
4
0.75
75.7
7
2.00
8
72.68
4
0.75
75.7
7
2.00
9
72.68
4
0.75
75.7
7
2.00
10
72.68
4
0.75
75.7
7
2.00
11
72.68
4
0.75
75.7
7
2.00
12
72.68
4
0.75
75.7
7
2.00
13
72.68
4
0.75
75.7
7
2.00
14
72.68
4
0.75
75.7
7
2.00
15
72.68
4
0.75
75.7
7
2.00
16
72.68
4
0.75
75.7
7
2.00
Table 4. Westside WWTP Effluent Characteristics
Flow
Temp
DO
BOD
Ammonia
Existing
Channel
7Q10
12.69
77.0
7.0
145/
9y1
1.00 S
I.
Restored
Channel
7Q10
12.69
77.0
7.0
12.35 Si
a q.1 W
1.00 5/
ow
Summary:
It is not clear why the existing and restored scenarios used different ultimate BOD concentrations for
the expanded discharge. They should be the same. All other discharge characteristics were the same
(8.2 MGD, DO of 7 mg/L, etc.). The impact of 12.35 vs. 14 mg/L for ultimate BOD is minimal, as shown
below in Figure 3.1
Note the highly uncertain conditions used to represent the restored channel. Same velocities, depths,
BOD decay rates, etc. used to represent the entire length of the stream channel. This highlights the
need for monitoring post -restoration to provide more realistic inputs for the restored channel model.
1. Update: MTU emailed the consultant to inquire about the different CBODu numbers. The response is as follows: Email from Trevor
Clements, 1/9/13: My apologies, but the input should have been 12.35 mg/L CBOD ultimate rather than the 14 listed. I had been looking
at the previous file representation of the non -restored stream channel to support runs 5 and 6, and missed that summer effluent
concentration change. I just reran the model (input and output files attached) and as we might suspect, there's not much change in the
results as the DO is more sensitive to velocity, reaeration, and SOD. The sag point is 0.13 mg/L higher (4.55 mg/L as opposed to 4.42
mg/L) with the correct input.
The 2.47 multiplier is recommended as it can be technically defended based on the lab tests on multiple municipal effluents from the
Thomann and Mueller reference. The 5 is a highly conservative assumption that reflects the upper end of what is seen for highly
refractory effluents. By assuming 5 mg/L BOD5 in the summer and 10 mg/L in the winter for effluent concentrations, we would expect a
less refractory nature instream than that conservative assumption (5 multiplier).
2

The table below summarize the differences in the September 2007 Existing Conditions Model and the
Summer 7Q10 Existing Conditions Model:
Table 5. Channel Velocity and Depth
Existing (Sept 2007)
Existing (Summer 7Q10)
Reach
Velocity
Depth
Velocity
Depth
1
1.000
0.61
1.310
0.95
2
0.140
2.59
0.180
3.52
3
0.220
1.34
0.285
1.57
4
0.220
1.48
0.285
1.73
5
0.430
0.69
0.580
1.10
6
0.420
0.67
0.565
1.07
7
0.300
1.11
0.400
1.77
8
0.140
2.59
0.180
3.52
9
0.430
0.69
0.580
1.10
10
0.140
2.59
0.100
3.52
11
0.300
0.71
0.639
0.89
12
0.300
0.71
0.639
0.89
13
0.300
0.71
0.639
0.89
14
0.300
0.71
0.639
0.89
15
0.300
0.71
0.639
0.89
16
0.300
0.78
0.639
_
0.89
Table 6. BOD Decay Rate
BOD Decay Rate
Reach
Existing (Sept 2007)
Existing (Summer 7Q10)
1
0.285
0.320
2
0.207
0.300
3
0.187
0.280
4
0.147
0.200
5
0.160
_
0.130
6
0.154
0.130
7
0.061
0.100
8
0.035
0.100
9
0.166
0.100
10
0.035
0.100
11
0.087
0.100
12
0.087
0.100
13
0.083
0.100
14
0.087
0.100
15
0.092
0.100
16
0.077
0.100
3

Headwater and Tributary Characteristics
Table 7. Existing Channel, Sept 2007 Conditions
Flow
Temp
DO
BOD
Ammonia
Headwater
0.25
69.08
3.2
0.75
0.1
Kennedy Mil
0.11
69.1
3.2
0.75
0.1
Hunts Fork
0.19
69.1
3.2
0.75
0.1
Hamby Creek
0.57
69.1
3.2
0.75
_
0.1
Table 8. Existing Channel, Summer 7Q10 Conditions
Flow
Temp
DO
BOD
Ammonia
Headwater
0.67
75.7
6.8
2.00
0.07
Kennedy Mil
0.25
75.7
6.8
2.00
0.1
Hunts Fork
0.42
75.7
6.8
2.00
_
0.1
Hamby Creek
1.05
75.7
6.8
2.00
0.1
Summary:
In general, there are higher velocities, increased depths, and higher BOD decay rates in -stream with the
7Q10 model. Recall that September 2007 was an extreme drought period, so these changes to the 7Q10
model seem reasonable. Headwater and tributary characteristics in the 7Q10 model reflect increased
flow and increased DO which will improve DO predictions compared to the September 2007 model, but
increased temperature and increased BOD in the 7Q10 model would have a negative impact on DO
predictions.
4

Comparisons of model based on Sept. 2007 conditions and model based on Summer 7Q10 conditions:
7
6
5
E4
0
3
2
1
Sept 2007 vs 7Q10
.ni N N N neen ni et et T N en N 0 0 00 n n O O o h 0 0 0 0 n n N N
—5ept07_ExIst — 7010_Exkt
7
6
a S7 5
Ea
0
03
2
0
8
7
6
E4
0
03
2
1
0
Sept 07 Expansion vs. 7Q10 Expansion
n
0 «. n n 0 as m n
n n N N N n, 0
n a n n to n n
Q R T N O 0 0 0 n n O O W O1 0 0 0 O -1 n n N N
.... n n n
u, m .n
—Sept07_Exlst—Sept07_8.2--7010_Edst—7010_8.2MGD_BOD 14
BOD Analysis for 8.2 MGD
n~ P n .ni N N N n m e, T N N 0 0 0 n n W W W a 0 0 0 O n n N N
—7010_8.2MGD_BOD 14—7010_8.2MGD_BOD_12.35—7010_8.2MGD BOD_8
Figure 1. Same discharge
characteristics, different in -stream
information (initial conditions,
headwater conditions, velocities,
depths)
r1 LA(
Figure 2. Comparing existing
discharge (flow and quality) and the
expansion discharge impacts
predicted by the old model based on
Sept. 2007 data and the new model
based on Summer 7Q10. What you
can see by looking at this figure is
that the expansion doesn't impact
water quality in the creek so much as
the hydraulic characteristics of the
creek.
Figure 3. Comparing varying effluent
ultimate BOD concentrations for the
expansion. Reducing ultimate BOD to
8 mg/L almost brings all DO above 5
mg/L, but there really isn't much
change between the 3 scenarios.
5

10
9
8
7
6
OD
5
a 4
3
2
1
0
Summer 7Q10 - expansion changing effluent DO
111 Q1 !'n N. eel al M I. I-1 LA G5 M % -1 LP% C1 M N. "1 " "
e--I eti N N N m m � ^t et Ln Ln ;� :� l� 00 00 • co o Q1 O c▪ o • O ei • e—I N N
ti ei ri ei ei ei r 1
7010_8.2MGD D07 70.10_8.2MGD_D08 7Q10_8,2MGD_D09
S:I
6

High Point Westside WWTP Expansion Qual2e Modeling Analysis
December 21, 2012
The tables below summarize the differences in the Summer 7Q10 Existing Channel Model and the
Summer 7Q10 Restored Channel Model:
Table 1. Channel Velocity and Depth
Existing (summer 7Q10)
Restored (summer 7Q10)
Reach
Velocity
Depth
Velocity
Depth
1
1.310
0.95
0.710
1.03
2
0.180
3.52
0.710
1.03
3
0.285
1.57
0.710
1.03
4
0.285
1.73
0.710
1.03
5
0.580
1.10
0.710
1.03
6
0.565
1.07
0.710
1.03
7
0.400
1.77
0.710
1.03
8
0.180
3.52
0.710
1.03
9
0.580
1.10
0.710
1.03
10
0.100
3.52
0.710
1.03
11
0.639
0.89
0.710
1.03
12
0.639
0.89
0.710
1.03
13
0.639
0.89
0.710
1.03
14
0.639
0.89
0.710
1.03
15
0.639
0.89
0.710
1.03
16
0.639
0.89
0.710
1.03
Table 2. BOD Decay Rate, Sediment Oxygen Demand
Existing (summer 7Q10)
Restored (summer 7Q10)
Reach
BOD Decay
Rate
SOD
BOD Decay
Rate
SOD
1
0.320
0.149
0.202
0.149
2
0.300
0.145
0.202
0.145
3
0.280
0.140
0.202
0.140
4
0.200
0.130
0.202
0.130
5
0.130
0.119
0.202
0.119
6
0.130
0.111
0.202
0.111
7
0.100
0.100
0.202
0.100
8
0.100
0.093
0.202
0.093
9
0.100
0.083
0.202
0.083
10
0.100
0.075
0.202
0.075
11
0.100
0.075
0.202
0.075
12
0.100
0.075
0.202
0.075
13
0.100
0.075
0.202
0.075
14
0.100
0.075
0.202
0.075
15
0.100
0.075
0.202
0.075
16
0.100
0.075
0.202
0.075

Table 3. Initial Conditions: Temperature, DO, BOD
Existing (summer 7Q10)
Restored (summer 7Q10)
Reach
Temperature
DO
BOD
Temperature
DO
BOD
1
76.64
7
0.75
75.7
7
2.00
2
75.56
6
0.75
75.7
7
2.00
3
75.02
5
0.75
75.7
7
2.00
4
74.66
5
0.75
75.7
7
2.00
5
74.30
5
0.75
75.7
7
2.00
6
73.76
4
0.75
75.7
7
2.00
7
73.22
4
0.75
75.7
7
2.00
8
72.68
4
0.75
75.7
7
2.00
9
72.68
4
0.75
75.7
7
2.00
10
72.68
4
0.75
75.7
7
2.00
11
72.68
4
0.75
75.7
7
2.00
12
72.68
4
0.75
75.7
7
2.00
13
72.68
4
0.75
75.7
7
2.00
14
72.68
4
0.75
75.7
7
2.00
15
72.68
4
0.75
75.7
7
2.00
16
72.68
4
0.75
75.7
7
2.00
Table 4. Westside WWTP Effluent Characteristics
Flow
Temp
DO
BOD .:
Ammonia
Existing
Channel
7010
12.69
77.0
7.0
14
1.00
Restored
Channel
7Q10
12.69
77.0
7.0
12.35
1.00
Summary:
It is not clear why the existing and restored scenarios used different ultimate BOD concentrations for
the expanded discharge. They should be the same. All other discharge characteristics were the same
(8.2 MGD, DO of 7 mg/L, etc.). The impact of 12.35 vs. 14 mg/L for ultimate BOD is minimal, as shown
below in Figure 3.
Note the highly uncertain conditions used to represent the restored channel. Same velocities, depths,
BOD decay rates, etc. used to represent the entire length of the stream channel. This highlights the
need for monitoring and post -restoration to provide more realistic inputs for the restored model.
2

The table below summarize the differences in the September 2007 Existing Conditions Model and the
Summer 7Q10 Existing Conditions Model:
Table 5. Channel Velocity and Depth
Existing (Sept 2007)
Existing (Summer 7Q10)
Reach
Velocity
Depth
Velocity
Depth
1
1.000
0.61
1.310
0.95
2
0.140
2.59
0.180
3.52
3
0.220
1.34
0.285
1.57
4
0.220
1.48
0.285
1.73
5
0.430
0.69
0.580
1.10
6
0.420
0.67
0.565
1.07
7
0.300
1.11
0.400
1.77
8
0.140
2.59
0.180
3.52
9
0.430
0.69
0.580
1.10
10
0.140
2.59
0.100
3.52
11
0.300
0.71
0.639
0.89
12
0.300
0.71
0.639
0.89
13
0.300
0.71
0.639
0.89
14
0.300
0.71
0.639
0.89
15
0.300
0.71
0.639
0.89
16
0.300
0.78
0.639
0.89
Table 6. BOD Decay Rate
BOD Decay Rate
Reach
Existing (Sept 2007)
Existing (Summer 7Q10)
1
0.285
0.320
2
0.207
0.300
3
0.187
0.280
4
0.147
0.200
5
0.160
0.130
6
0.154
0.130
7
0.061
0.100
8
0.035
0.100
9
0.166
0.100
10
0.035
0.100
11
0.087
0.100
12
0.087
0.100
13
0.083
0.100
14
0.087
0.100
15
0.092
0.100
16
0.077
0.100

Headwater and Tributary Characteristics
Table 7. Existing Channel, Sept 2007 Conditions
Flow
Temp
DO
BOD
Ammonia
Headwater
0.25
69.08
3.2
0.75
0.1
Kennedy Mil
0.11
69.1
3.2
0.75
0.1
Hunts Fork
0.19
69.1
3.2
0.75
0.1
Hamby Creek
0.57
69.1
3.2
0.75
0.1
Table 8. Existing Channel, Summer 7Q10 Conditions
Flow
Temp
DO
BOD
Ammonia
Headwater
0.67
75.7
6.8
2.00
0.07
Kennedy Mil
0.25
75.7
6.8
2.00
0.1
Hunts Fork
0.42
75.7
6.8
2.00
0.1
Hamby Creek
1.05
75.7
6.8
2.00
0.1
Summary:
In general, there are higher velocities, increased depths, and higher BOD decay rates in stream with the
7Q10 model. Recall that September 2007 was an extreme drought period, so these changes to the 7Q10
model seem reasonable. Headwater and tributary characteristics in the 7Q10 model reflect increased
flow and increased DO which will improve DO predictions compared to the September 2007 model, but
increased temperature and increased BOD in the 7Q10 model would have a negative impact on DO
predictions.
4

Comparisons of model based on Sept. 2007 conditions and model based on Summer 7Q10 conditions:
a
7
6
5
E
E4
0
0
2
1
0
Sept 2007 vs 7Q10
... N O 14 eni M N N fMll M< C O N N b .Ne 00 h^ m W W a 0, 0 0 O OM4Y 01 M N
—Sept07 Exist —7010 Exist
8
7
6
$5
E4
83
2
1
0
Sept 07 Expansion vs. 7Q10 Expansion
n N 01 A A M N N M< 4 4 N N b �N0 d h h EO ENO a O^i O G O .M1 M N
'1 rl '1 H 11 ''1 r1 f'1
—Sept07 Exist—Sept07 B.2 —7010 Exist —7010 8.2MGD BOD 14
8
7
6
Ea
0
0 3
2
o�
BOD Analysis for 8.2 MGD
n N N 0 N N N N M M Y e! N .n V 0 h n EO m m 0, ET 0 0 0 .1 •9 N N
—7010_8.21,1GD BOD_14—7010_8.2M60 800_12.35 —7010 8.2MGD800_8
5
Figure 1. Same discharge
characteristics, different in -stream
information (initial conditions,
headwater conditions, velocities,
depths)
Figure 2. Comparing existing
discharge (flow and quality) and the
expansion discharge impacts
predicted by the old model based on
Sept. 2007 data and the new model
based on Summer 7Q10. What you
can see by looking at this figure is
that the expansion doesn't impact
water quality in the creek so much as
the hydraulic characteristics of the
creek.
Figure 3. Comparing varying effluent
ultimate BOD concentrations for the
expansion. Reducing ultimate BOD to
8 mg/L almost brings all DO above 5
mg/L, but there really isn't much
change between the 3 scenarios.

EIiNR - ENVIRONMENTAL MANAGEMENT T15A: 02B .0400
(i) complete mix, in which sufficient energy is imparted to the wastewater to prevent deposition
of solids in the pond; or
(ii) partial -mix, in which only sufficient energy is used to dissolve and mix oxygen in the waste-
water. Solid materials settle in the partial -mix pond and are decomposed anaerobically. There
will be algae in the partial -mix aerated"pond, but usually far fewer than in a photosynthetic
pond.
This definition does not include polishing or holding ponds which are preceded by other bio-
chemical or physical/chemical secondary treatment processes and designed to increase their effi-
ciency. The pond may be single -cell or multi -cell.
(11) The term "best waste stabilization pond technology" shall mean a monthly average effluent
suspended solids concentration of 90 mg/1 and a weekly maximum average effluent suspended
solids concentration of 135 mg/1 for those waste stabilization ponds that are achieving the level of
effluent quality established for biochemical oxygen demand in .0406(a)(2) of this Section.
(12) The term "minimum.treatment requirements" means the effluent limitations required to comply
with the designations secondary treatment as defined in 15'A NCAC 2B .0406, BPWTT,
BPCTCA, BCT, BAT and/or BAT/BMP's as required of a specific wastewater discharge. Mini-
mum treatment requirements must be met even if the receiving waters affected can or are expected
to be able to accept higher pollutant -load levels and still meet applicable water quality standards.
(13) The term "water quality limited segment" means a- segment where it is known that water quality
does not meet applicable water quality standards or is not expected to mect them even after the
application of minimum treatment requirements.
(14) • The term "effluent limited segrnent" means a segment where it is known that water quality is
meeting and will continue to meet applicable water quality standards or where there is adequate
demonstration that water quality will meet applicable water quality standards after the application
of minimum treatment requirements.
(15) The term "settleable solids" means the volumetric measurement of solids after a specified settling
time. The determination of settleable solids shall be made in the following manner: one liter of
the wastewater is placed in a standard Imhoff cone and allowed to settle for 45 minutes. After 45
minutes settling, the liquid layer is gently stored and allowed to settle for 15 additional minutes.
The volume of solids is immediately read in milliliter per liter (m1/1).
(16) The term "oxygen consuming wastes" means those wastewater discharge components recognized
as being oxygen demanding in the aquatic environment. These arc generally limited by BOD(5)
and NI-1(3)-N.
llistory Note: Statutory Authority G.S. 143-215; 143-215.1; 143-215.3(a)(1); I L1,3111-
Eff February 1, /976; 1411i
Amended Eff. August 12, 1979; November 1, 1978; December 1, 1976.
ft INS
.0404 EFFLUENT LIMITATIONS IN WATER QUALITY LIMITED SEGMENTS t�
(a) Effluent limitations more stringent than minimum treatment requirements shall be develope''d h.1N1
the staff and approved by the Director for all existing or proposed dischargers to water quality limited
segments of the surface waters of the state. The basis of these water quality effluent limitations shall 101it
be maintenance of water quality standards.
(b) The staff shall also provide on a case -by -case basis for seasonal variation in the discharge of ox-
ygen -consuming wastes. In order to be considered eligible for seasonal effluent Iunitations, a request
must be submitted to the Director along with a rationale as to the need for such limitations. Permit
rcissuance or modification during the remaining time of an existing permit will be considered on the
basis of demonstrated 'need. In no case shall this variation cause or be expected to cause a receiving
water body to violate applicable water quality standards.
(c) For the purpose of determining seasonal effluent limitations, the year shall consist of a summer
and a winter discharge period. The summer period will begin April 1 and extend through October 31.
The winter period shall be that portion of the year from November 1 to March 31. The summer ox-
ygen -consuming wastcload allocation shall be developed using the flow criteria specified in 15A NCAC
2B .0206. The winter oxygen -consuming wasteload allocation shall in no case be less stringent than
two times the summer oxygen -consuming waste Load limitations nor shall it be less restrictive than
minimum treatment requirements.
history Note: Statutory Authority G.S. 143-215; 143-215.1; 143-2/5.3(a) (1);
;VORTII C.•AROLIN l .•II).1iI.\7STR» TI1'E CODE 02/22/90
Page 2

City of High Point, Westside WWTP Draft NPDES Permit Comments from MTU
,vf17ES fzsp�'-3
Page 3 - Not sure why TN limits aren't included for this permitted flow limit.
Current facility is not designed or capable of treating the wastewater to reduce TN.
Expansion will include BNR.
Page 4 - TP footnote of 3 appears to be mislabeled, think it should be 4? Corrected.
Pages 3-5 - I'm concerned about the pounds/year choice for setting the TN and TP
limits without including the protection of a daily maximum concentration. How does
this protect for summer critical conditions? To date, we have only been concerned
with the long-term accumulation of nutrients. No modelling was performed to
determine the TN and TP allocations in this permit. The average TN and TP mass
loadings that occurred between Jan. 2007 and Aug. 2009 at Westside were calculated
and the facility is expected to not exceed these loadings (under both expansion flow
numbers) until a TMDL is completed and stream protective limits can be put in the
permit.
Page 5 - 8a - who will review/approve/do follow-up inspections on the stream
restoration plan? Not sure that MTU as lead is appropriate, we don't have the
appropriate experience with on the ground restoration. However, review/coordination
needs to be included in the permit. This would help alleviate the risk of implementing
a plan that is not sufficient and, in the end, would end up costing the permittee more
money to correct. The Army Corp is responsible for the review of the restoration
project. If the Corp requires the City to get 401 certification, MTU should contact that
group to corrdinate their review. John Thomas of the Army Corp is responsible for
Davidson Co. - I left a message to see if a 401 certification would be required - Julie
Below are the comments I made concerning the restoration plan when we reviewed the
EA. At the time, I was told that these would be taken of through the permit, not
through the EA. I don't think this text needs to be explicitly included in the permit,
but these are the considerations I would like to see addressed in the plan.
The plan should include discussion about the jurisdiction of restoration
areas. How will additional impacts on the stream be prevented post -
restoration, will there be any kind of regular, required maintenance post -
restoration, any potential impacts that could result from the restoration?
The City of High Point have addressed some of these concerns in their
responses to DWQ's comments:... High Point would evaluate the restored
stream sections and tree fall removal areas twice a year. High Point will repair
substantive problems (i.e., that may impact water quality and channel stability)
with the restored segments, and will take appropriate actions to address
additional tree fall that may impact stream hydraulics negatively with regard to
maintaining sufficient DO levels in the stream.
My understanding is that jurisdictional issues are not resolved and they are
working on them as they continue to pursue restoration. Again, NPDES
believes these issues are beyond our purview and inappropriate to put in the
wastewater permit. Perhaps these issues can be addressed in the 401
certification, if required.

Also, there should be more discussion of the sand -mining that is occurring
in Rich Fork Creek and contributing to water quality problems. Will the
sand -mining continue? Are there any measures in place to prevent future
sand -mining?
WSRO staff only knows of one sand dredging operation on Rich Fork Creek -
NCG520091. This General Permit expires on July 31, 2012 and will not be
renewed. The Expedited Permitting Unit has been notified about the restoration
project and asked not to issue dredging permits for operations in Rich Fork
Creek that can affect the DO assimilative capacity. Note: only the Director can
deny a permit.
Page 5 - 8b - monitoring plan should go to NPDES and copy MTU. This is to ensure
collaboration between MTU and NPDES and thatNPDES maintains the necessary files
for this discharge permit.
Fixed wording so 2 copies (one for NPDES files and one for Regional files) are sent to
DWQ/NPDES and one copy to DWQ/MTU so proper coordination will occur. It will be
necessary for the reviewers to respond within a timely manner (permit states that the -
monitoring plan shall be submitted 3 months prior to planned implementation.
Assuming this allows enough time for MTU to comment and several weeks for the City
to revise the plan?
A sentence should be added to 8b that indicates that not only should a monitoring
plan be developed; it must also be implemented by the permittee. While it is implied
that the permittee must implement the monitoring plan, we need to be explicit to avoid
confusion.
Added a sentence stating: The City of High Point shall implement the DWQ approved
in -stream monitoring plan.
Page 5 - 8c - "The rerun models at 10 MGD and, if necessary, at 8.2 MGD shall be
submitted to DWQ for review. Submit 3 copies of the plan to the DWQ/ Modeling/
Unit Supervisor for approval." • Suggest changing the word "plan" to "modeling report
and all associated modeling files." Fixed
We don't really need 3 copies, what we need is for the report and the modeling files to
be submitted electronically. Otherwise, we won't be able to properly review the revised
model. Added wording that an electronic copy of the model be sent to DWQ/MTU.
Page 6 - 8d - I'm curious what will happen if they can't show how they will maximize
DO in the WWTP's effluent to meet in -stream standards. This scenario does not seem
to be addressed as the permit is written. See footnote 8D.
a. Additional stream restoration? No expansion to 10 MGD allowed? Wording was
added to clarify no expansion allowed until assimilative capacity is available in
Rich Fork Creek.

Grzyb, Julie
From: Clements, Trevor [Trevor. [e-mail]]
Sent: Friday, December 14, 2012 4:19 PM
To: Belnick, Tom; Grzyb, Julie
Cc: Terry Houk ([e-mail]); Behm, Pamela
Subject: RE: High Point Westside WLA Modeling Results - Supplement
Attachments: High Pt Westside WLA memo_Tt_12-14-12 supplement.pdf
Tom and Julie,
Per Julie's recent inquiry, I have attached a supplement to the previous memo with two additional scenarios: summer and
winter WLA runs for an 8.2 MGD discharge to the existing channel should the plant expansion be completed prior to the stream
channel restoration projects. Please let me know if you have any questions about the analyses or other related modeling issues.
Regards,
Trevor
Trevor Clements I Director, Water Resources — RTP
Direct: 919.485.2058 I Main: 919.485.8278 I Fax: [phone]
[e-mail]
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 I 1 Park Drive, Suite 200 I Research Triangle Park, NC 27709 I www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender
by replying to this message and then delete it from your system.
From: Clements, Trevor
Sent: Monday, November 12, 2012 2:09 PM
To: Belnick, Tom (tom.belnick(ancdenr.gov); [e-mail]
Cc: Terry Houk ([e-mail]); Pam Behm (pamela.behm(ancdenr.gov)
Subject: High Point Westside WLA Modeling Results
Tom and Julie,
At our last meeting with the City of High Point (September 28, 2012), you indicated that it would be helpful to have specific
wasteload allocation (WLA) model runs to review in determining draft NPDES permit limits (including seasonal limits) for the
High Point Westside expansion requests. Previous QUAL2E model submittals were restricted to model calibration results,
sensitivity results, and prediction of DO profiles under restored conditions. The attached memo provides a description of model
setup and application for four WLA modeling scenarios: summer and winter runs for an effluent discharge of 8.2 MGD, and
summer and winter runs for a discharge of 10 MGD. Conservative assumptions are summarized, and an additional margin of
safety (DO above the water quality standard) is predicted for all four scenarios.
After you have had a chance to review this information, please let me know if you have any questions or would like to discuss
the WLA modeling analyses further. I look forward to hearing back from you.
Thank you,
Trevor
Trevor Clements 'Director, Water Resources — RTP
Direct: 919.485.2058 I Main: 919.485.8278 I Fax: [phone]
trevor. [e-mail]
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 I 1 Park Drive, Suite 200 I Research Triangle Park, NC 27709 I www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender
by replying to this message and then delete it from your system.
1

TETRA TECH
Memorandum
One Park Drive, Suite 200 • PO Box 14409
Research Triangle Park, NC 27709
Tel [phone] • Fax [phone]
To: Tom Belnick, Julie Grzyb Date: December 14, 2012
From: Trevor Clements Subject: High Point Westside Facility
WLA Analysis - Supplement
cc: Pam Behm, Terry Houk Proj. No. 100-RTP-T17031
In a previous memo dated November 9, 2012, I provided the documentation of Tetra Tech's waste load
allocation (WLA) modeling analysis for expansion of the City of High Point Westside discharge. That
analysis cover four scenarios that represented conditions expected for a restored Rich Fork Creek channel
with regard to addressing existing problems associated with legacy sand mining and excessive tree fall.
The Division of Water Quality (DWQ) and the City have determined that completion of the next phase of
facility upgrade and expansion could potentially occur prior to completion of the stream restoration
projects (which will require easement acquisition and multiple environmental permits or approvals).
Therefore, DWQ requested that Tetra Tech provide additional WLA analysis to cover that set of
circumstances within the NPDES permit.
This supplemental memo summarizes the additional model setup, application, and results for a waste load
allocation (WLA) analysis for expansion of the High Point Westside discharge to 8.2 MGD prior to
completion of planned stream channel restoration activities.
1. ADDITIONAL MODEL SET-UP
For this supplemental analysis, the QUAL2E model (configured for the existing unrestored channel) was
setup to support WLA development for the following two additional scenarios per request by DWQ:
5. WWTP flow of 8.2 MGD for summer conditions
6. WWTP flow of 8.2 MGD for winter conditions
Descriptions of the modeling assumptions for these two additional scenarios are provided herein,
organized by key model parameter categories. Where available, assumptions reflect Level C modeling
guidance provided in the Waste Load Allocation Standard Operating Procedures Manual (DWQ, 1990).
The modifications required to set the model up for WLA application runs included input of critical flows,
permitted wasteflows, and estimates of velocity and depth for each scenario's flow regime.
[1] TETRA TECH
1

High Point Westside WLA Analysis - Supplement December 14, 2012
Flow and Hydraulics Parameters
Headwater Flow
DWQ policy is to use 7Q10 statistics for headwater flow assumptions in steady-state BOD/DO modeling.
The statistics are estimated by the USGS upon request, and two periods are distinguished: summer (Apr -
October) and winter (Nov - Mar) related to DWQ seasonal periods for NPDES permitting. Tetra Tech
confirmed with DWQ (email correspondence 10/15/12 between Trevor Clements and Julie Grzyb) that
current estimates applied for the Westside permit should be used for consistency, which are as follows:
Summer 7Q10: 0.67 cfs (applies to modeling scenarios 1 and 3 and 5)
Winter 7Q10: 1.90 cfs (applies to modeling scenarios 2 and 4 and 6)
Incremental Base -Flow and Tributary Flow
USGS (email from Curtis Weaver, 10/12/12) indicated that the drainage area for the Westside outfall
location is 19.1 square miles. Incremental baseflow can be estimated for summer and winter 7Q10
conditions by dividing the flows by the drainage area as follows:
Summer 7Q10 incrementalflow rate: 0.67 cfs/19.1 sq.mi. = 0.035 cfs/sq.mi. (scenarios 1 and 3 and 5)
Winter 7Q10 incrementalflow rate: 1.90 cfs/19.1 sq.mi. = 0.099 cfs/sq.mi. (scenarios 2 and 4 and 6)
These values correspond well with the range of flow yield estimated by USGS (email from Curtis
Weaver, 10/12/12) as 0 to 0.8 cfs/sq.mi. for the summer and 0.04 to 0.17 csf/sq.mi. for the winter period
based on Low flow characteristics of streams in North Carolina (USGS Water -Supply Paper 2403).
Much of the drainage area downstream of the outfall is contributed by significant tributaries (Kennedy
Mill, Hunts Fork and Hamby Creek). Therefore, incremental flow will be input through the tributary
junctions as relative point sources, and baseflow along the Rich Fork Creek channel will conservatively
be assumed to be zero. Using the tributary drainage area (from HEC modeling watersheds) and yields
(incremental flow rates) estimated above, the tributary flow inputs were calculated as follows:
Kennedy Mill: DA = 7.1 sq.mi.; Summer 7Q10 = 7.1 *0.035 = 0.25 cfs;
Winter 7Q10 = 7.1 *0.099 = 0.70 cfs
Hunts Fork: DA = 11.9 sq.mi.; Summer 7Q10 = 11.9*0.035 = 0.42 cfs;
Winter 7Q10 = 11.9*0.099 = 1.18 cfs
Hamby Creek: DA = 30 sq.mi.; Summer 7Q10 = 30*0.035 = 1.05 cfs;
Winter 7Q10 = 30*0.099 = 2.97 cfs
Wastewater Flow
Scenarios 5 and 6:
8.2 MGD = 12.69 cfs
Velocity and Depth
Channel velocity and depth values will be associated with existing channel conditions and the amount of
water flowing through the channel. Total flow in the main channel will be driven by headwater flow,
wastewater flow at the outfall point, and flow in Kennedy Mill Creek immediately below the outfall.
Thus, for the two additional scenarios, flow driving velocity and depth through the DO sag portion of the
stream was estimated as follows:
Scenario 5: Headwater 7Q10 (0.67 cfs) + Effluent (12.69 cfs) + Kennedy Mill 7Q10 (0.25 cfs)
= 13.61 cfs
Scenario 6: Headwater 7Q10 (1.9 cfs cfs) + Effluent (12.69 cfs) + Kennedy Mill 7Q10 (0.70 cfs)
= 15.29 cfs
El) TETRA TECH
2

•
High Point Westside WLA Analysis - Supplement December 14, 2012
HECRAS results (Tetra Tech, 2009) were available for existing channel surveys through the Kanoy Road
Pool (reach 10), so that information provided input values for velocity and depth through reach 10. For
reaches 11 — 16 that would be unaffected by the planned stream restoration, the previous assumed average
velocity and depth values were applied but prorated to scenario 5 and 6 streamflow conditions.
Water Quality Parameters
Effluent Conditions
Scenario 5:
BOD5 = 5 mg/L
NH3N = 1 mg/L
DO=7mg/L
Scenario 6:
BOD5 = 10 mg/L
NH3N = 1.8 mg/L
DO=7mg/L
Conversion of BOD5 to CBOD ultimate concentration was estimated using the Thomann and Mueller F-
ratio value of 2.47 (1987, Principles of Surface Water Quality Modeling and Control based on facility
studies). Kd was conservatively maintained at the same values for the calibrated model. With increased
flow and velocity, we would expect lower Kd values, so this assumption is considered conservative.
Based on previous modeling data, the effluent will be assumed to have a summer temperature of 25 C and
winter temperature of 15 C.
Headwater Water Quality Conditions
Quality assured water quality data have been collected upstream of the High Point Westside outfall by the
Yadkin Pee -Dee River Basin Association (YPDRBA) since 1998. Station Q5745000 is located on Rich
Fork Creek at the Chestnut Street crossing. These data were used to establish headwater water quality
conditions. These assumptions were also applied to incremental baseflow for summer and winter,
respectively.
Summer Temperature: The 90t percentile of temperature monitored between the months of July through
October was calculated to provide the summer headwater temperature condition for the model. For 114
observations recorded between July 1998 and July 2012, the 90`" percentile was calculated at 24.3 C.
Winter Temperature: The 90`" percentile of temperature monitored during the month of November was
calculated to provide the winter headwater temperature condition for the model. For 12 observations
recorded between 1998 and July 2011, the 90`" percentile was calculated at 13.6 C.
Summer DO: The median percent saturation for DO for the most recent five years of YPDRBA data
collected at Q5745000 for the summer period was 82 percent. At 24.3 C, this converts to a headwater DO
concentration for the model of 6.8 mg/L (i.e., 82 percent of 8.31 mg/L).
Winter DO: The median percent saturation for DO for the most recent five years of YPDRBA data
collected at Q5745000 for the winter period was 79 percent. At 13.6 C, this converts to a headwater DO
concentration for the model of 8.2 mg/L (i.e., 79 percent of 10.38 mg/L).
Summer Nitrogen: Upstream summer concentrations observed by YPDRBA for ammonia (NH3N) and
TKN have remained relatively consistent with period of record and last five year record being essentially
the same (0.07mg/L NH3N and 0.4 mg/L TKN). Summer headwater organic nitrogen concentration is
therefore assumed to be 0.33 mg/L (i.e., 0.4 mg/L TKN minus 0.07 mg/L NH3N).
IDTETRA TECH
3

High Point Westside WLA Analysis - Supplement December 14, 2012
Winter Nitrogen: Similar to the summer observations, upstream winter concentrations observed by
YPDRBA for ammonia (NH3N) and TKN have remained relatively consistent with period of record and
last five year record being essentially the same (0.06mg/L NH3N and 0.25 mg/L TKN). Winter headwater
organic nitrogen concentration is therefore assumed to be 0.19 mg/L (i.e., 0.25 mg/L TKN minus 0.06 mg/L
NH3N).
A complete record of all inputs can be found in the model input files for each scenario provided in
supplemental Attachments E and F (to distinguish them from Attachments A — D for the original
November 9 memo).
2. MODEL APPLICATION RESULTS
Model predictions for How, DO, CBOD, and NH3N are shown in Figures 1 through 4, respectively
(model output for all four scenarios is provided in Attachments E and F).
Flow Predictions
Figure 1 shows flow assumptions for scenarios 5 and 6. This information helps in further understanding
predicted water quality results. Tributary flows change main stem water quality concentrations in Rich
Fork Creek, which can be seen in the line graphs for Figures 2 — 4 where the flow changes occur.
25
20
—
— Run
5: 8.2 MGD Summer
— —
Run 6:
8.2 MGD Winter
/
-••-----•
_ _
LL15
U
010
s
/
J
5
0
........................,...,.,,
0 5
N
h
R.
h'S
............,.,..,.,...........,.....
h
t.
h
h
....................
h co h '1 h o h
Distance (mi)
0,
... ,..........................,
h ,,o
h ,,,.
5
,.,1,
Figure 1. Assumed Critical Flow Levels for Scenarios 5 and 6
DO Predictions
The DO profiles in Figure 2 illustrate that in both the summer and winter conditions, the lowest DO
sagpoint is expected to occur around mile 3.5 (i.e., at the Ball Road pooling area).
TETRA TECH
4

High Point Westside WLA Analysis - Supplement
December 14, 2012
9
— —
Run 5: 8.2 MGD Summer
— —
Run 6: 8.2 MGD Winter
8
i
_
67
/� N.
\---—�.a—
e
AN.___
s.-- —
-----
E5
4
-- —`r
O
0
3
2
1
O o.
^ N. rt. el,. 'b '5. b b�
'
yh 6 CO. 'l A •
Distance (mi)
0y
A q.
^o ^oy N ^^h N
Figure 2. Model Predicted DO Concentration for Scenarios 5 and 6
CBOD Predictions
Figure 3 provides the CBOD ultimate profiles for scenarios 5 and 6. As was the case for Scenarios 1 — 4,
the predicted concentrations reflect conservative estimates since intermediate baseflow other than
tributary flow was not included in the model. Additionally, actual effluent concentrations will be
considerably less than permitted values in order to maintain compliance.
25
20
5
0
— — Run 5: 8.2 MGD Summer — — Run 6: 8.2 MGD Winter
I� — —
I
1
1
1--—.
L
1
I
— — —
1
I
0 oh i. ^h iv,tih 'S ,6h 4, by h by 6 0y A10 0 0y �, oh ,�o ^oh P%
Distance (mi)
Figure 3. Model Predicted CBOD Ultimate Concentrations for Scenarios 5 and 6
OTETRA TECH
5

High Point Westside WLA Analysis - Supplement December 14, 2012
NH3N Predictions
Figure 4 provides the model predicted ammonia concentrations for scenarios 5 and 6. Model output
shows that decay of organic nitrogen to ammonia is partially off -setting the impact of ammonia decay in
the model. This explains the relatively shallow decline evidenced in the plots of NH3N concentration,
particularly in the summer. Again, these would be considered conservative estimates of NH3N since
intermediate baseflow other than tributary flow was not included in the model. Also once again, actual
effluent concentrations will be expected to be less than permitted values in order to maintain compliance.
.lo
—
—
Run 5: 8.2 MGD Summer — —
Run 6: 8.2 MGD Winter
I3N (mg!L)
n W O N A Oi C
r
e
--
II
1
1
V.1.Ile
ii•4)
4)
t
aG
<o<-)h0 �� AA� 0�43 0.NO
Distance (mi)
N�c.) t ..............
Figure 4. Model Predicted NH3N Concentration for WLA Scenarios 5 and 6
3. REFERENCES
NCDENR, 1990. NCDEM Wasteload Allocations Standard Operating Procedures Manual, Division of
Environmental Management, Water Quality Section.
NCDWQ. 10/15/12 email correspondence between Trevor Clements (Tetra Tech) and Julie Grzyb
(DWQ) regarding USGS low flow statistics and values to apply to WLA scenarios.
Tetra Tech, January 2008. Results of Phase I Field Monitoring and Model Updates for the High Point
Westside Discharge to Rich Fork Creek. Prepared for the City of High Point and and Hazen & Sawyer, P.C.
Thomann and Mueller. 1987. Principles of Surface Water Quality Modeling and Control.
USGS. 10/12/12 email from Curtis Weaver (USGS) to Trevor Clements (Tetra Tech) regarding USGS
low flow statistics for Rich Fork Creek.
USGS. 1993. Low flow characteristics of streams in North Carolina (USGS Water -Supply Paper 2403).
OTETRA TECH
6

Sett
t-e..-F-4)to 44- c..C, ,e,' re „r4 lbw
TETRA TECH
Memorandum
To: Tom Belnick, Julie Grzyb
From: Trevor Clements
cc: Pam BChnl, Terry Houk
Date:
Subject:
Proj. No.
One Park Drive, Suite 200 • PO Box 14409
Research Triangle Park, NC 27709
Tel [phone] • Fax [phone]
November 9, 2012
High Point Westside Facility
WLA Analysis
100-RTP-T17031
1. BACKGROUND
The City of High Point Westside Wastewater Treatment Plant (WWTP) discharges to Rich Fork Creek,
which flows into Abbotts Creek before entering High Rock Lake (Figure 1). In July 2004, the City
requested of the North Carolina Division of Water Quality (DWQ) to receive speculative effluent limits to
expand the City's discharge to Rich Fork Creek. However, DWQ indicated at that time that monitoring
data showed a lack of assimilative capacity downstream of the facility. Data collected previously by the
City, the Yadkin Pee Dee River Basin Association (YPDRBA), and DWQ and evaluated in 2005 showed
that dissolved oxygen (DO) levels downstream of the facility occasionally dropped below the state water
quality standard of 5 mg/L during the warm summer months. However, neither DWQ nor the City
believed at the time that they fully understood why DO levels were as low as occasionally observed.
Because the existing DWQ model did not predict DO violations, the agency believed that the model was
not reliable to support decision -making.
Tetra Tech was contracted by the City and its engineering consultant, Hazen & Sawyer, to provide third
party expert services to evaluate existing data on assimilative capacity in Rich Fork Creek and to examine
whether more detailed modeling would help shed light on available assimilative capacity and discharge
impacts. A field reconnaissance of Rich Fork Creek in January 2006 revealed altered hydrology due to
instream sand mining at three locations between the City of High Point WWTP outfall and the confluence
with Hamby Creek. The Modeling Scoping Analysis for the High Point Westside Discharge to Rich Fork
Creek (Tetra Tech, March 2006) indicated that the presence of three mined pools was likely exacerbating
DO problems and that physically restoring the channel in these sections could potentially result in
significant improvements in DO concentration patterns in the restored segments.
Tetra Tech then conducted field measurements of the key modeling parameters (DO profiles, sediment
oxygen demand, reaeration rates, and flow -velocity relationships) during the summers of 2006 and 2007
to confirm whether or not the scoping modeling assumptions were valid and further assess whether
restoring the pools to free flowing conditions would improve the DO profile throughout the creek. The
results were used to field calibrate a QUAL2E model that further corroborated the expectation of
increased DO in the restored segments and that removing the discharge from Rich Fork Creek would
likely result in poorer water quality during summer low flow periods due to limited baseflow conditions
(Tetra Tech, January 2008).
Th
TETRA TECH
1

High Point Westside WLA Analysis
November 9, 2012
Legend
YPDRBA Station
QUAL2E Model Extent
Major Road
O. County Boundary
DModel Watershed
Water
Municipalities
Abbotts
Creek
DAVIDSON
COUNTY
Q5745000
Rich Fork
Creek
Hunts
Fork
Jimmys
Creek
Rich Fork Creek
Model Area, High Point, NC
"D_t9A1_Sv:uPlaro r:ari Grout FIP$ 3200_Fl
Mop p, & d 1l.}1-2012 H Ned
Payne
Creek
Kennedy
Mill Creek
Thomasville
125 25
5
Wiomexrs
a
Auks
N
ii
City of
High Point
GUILFORD
COUNTY
RANDOLPH
COUNTY
TETRA TECH
Figure 1. Rich Fork Creek Watershed and Receiving Stream for High Point Westside
TETRA TECH
2

f
High Point Westside WLA Analysis November 9, 2012
In January — February of 2009, Tetra Tech worked with subcontractors to obtain aerial imagery of the
stream channel corridor and physical stream channel survey cross sections. The aerial imagery provided
insight into the amount and pattern of tree fall along the 12 mile stretch of Rich Fork Creek between the
WWTP outfall and mouth of the stream. The surveyed cross -sections supported the channel restoration
design process and provided more detailed channel information elevation and profile data for HEC
modeling and QUAL2E modeling assumptions. HEC modeling was conducted to support channel
restoration design (Tetra Tech, September 2009).
In October 2009, Tetra Tech delivered the QUAL2E modeling files for both existing conditions and
projected restored conditions to DWQ to provide for agency use and application (10/19/09 memorandum
from Trevor Clements and Alix Matos to Kathy Stecker, Tom Belnick, and Pam Behm). During review of
draft NPDES permit conditions at a meeting of the City and DWQ on September 28, 2012, DWQ
representatives indicated that they would need additional modeling information to finalize effluent limits
for the multiple flow conditions for summer and winter seasons. This memo summarizes the model setup,
application, and results for a waste load allocation (WLA) analysis for expansion of the High Point
Westside discharge.
2. MODEL SET-UP
The QUAL2E model (configured for the restored channel, see Tetra Tech, January 2008 and 10/19/09
memorandum to DWQ) was setup to support WLA development for the following four scenarios per
request by DWQ:
1. WWTP flow of 8.2 MGD for summer conditions
2. WWTP flow of 8.2 MGD for winter conditions
3. WWTP flow of 10 MGD for summer conditions
4. WWTP flow of 10 MGD for winter conditions
Descriptions of the modeling assumptions for these four scenarios are provided herein, organized by key
model parameter categories. Where available, assumptions reflect Level C modeling guidance provided in
the Waste Load Allocation Standard Operating Procedures Manual (DWQ, 1990). The model reach
configuration is provided in Figure 2.
The modifications required to set the model up for WLA application runs included input of critical flows,
permitted wasteflows, estimates of velocity and depth for each scenario's flow regime, and modification
of CBOD decay using the Bosco equation which is correlated to stream velocity and depth.
C:1 TETRA TECH
3

High Point Westside WLA Analysis
November 9, 2012
Legend
QUAL2E Model Reaches
Major Road
MICounty Boundary
oModel Watershed
1111 Water
Municipalities
f
Rich Fork Creek
QUAL2E Model Reaches, High Point. NC
NAD_1%3 Sl Plam_N ,11 Cmolrc, FIPS ]:00_FI
L1,IP prod<e0 11 d1 :012 - N N¢fwNa
0 o.s 1
Kdcmolers
0 045 D.9 1.8
kbles
TETRA TECH
Figure 2. Rich Fork Creek QUAL2E Model Reach Configuration
TETRA TECH
4

High Point Westside WLA Analysis November 9, 2012
Flow and Hydraulics Parameters
Headwater Flow
DWQ policy is to use 7Q10 statistics for headwater flow assumptions in steady-state BOD/DO modeling.
The statistics are estimated by the USGS upon request, and two period are distinguished: summer (Apr -
October) and winter (Nov - Mar) related to DWQ seasonal periods for NPDES permitting. Tetra Tech
confirmed with DWQ (email correspondence 10/15/12 between Trevor Clements and Julie Grzyb) that
current estimates applied for the Westside permit should be used for consistency, which are as follows:
Summer 7Q10: 0.67 cfs (applies to modeling scenarios 1 and 3)
Winter 7Q10: 1.90 cfs (applies to modeling scenarios 2 and 4)
Incremental Base -Flow and Tributary Flow
USGS (email from Curtis Weaver, 10/12/12) indicated that the drainage area for the Westside outfall
location is 19.1 square miles. Incremental baseflow can be estimated for summer and winter 7Q10
conditions by dividing the flows by the drainage area as follows:
Summer 7Q10 incremental flow rate: 0.67 cfs/19.lsq.mi. = 0.035 cfs/sq.mi. (scenarios 1 and 3)
Winter 7Q10 incremental flow rate: 1.90 cfs/19.lsq.mi. = 0.099 cfs/sq.mi. (scenarios 2 and 4)
These values correspond well with the range of flow yield estimated by USGS (email from Curtis
Weaver, 10/12/12) as 0 to 0.8 cfs/sq.mi. for the summer and 0.04 to 0.17 csf/sq.mi. for the winter period
based on Low flow characteristics of streams in North Carolina (USGS Water -Supply Paper 2403).
Much of the drainage area downstream out the outfall is contributed by significant tributaries (Kennedy
Mill, Hunts Fork and Hamby Creek). Therefore, incremental flow will be input through the tributary
junctions as relative point sources, and baseflow along the Rich Fork Creek channel will conservatively
be assumed to be zero. Using the tributary drainage area (from HEC modeling watersheds) and yields
(incremental flow rates) estimated above, the tributary flow inputs were calculated as follows:
Kennedy Mill: DA = 7.1 sq.mi.; Summer 7Q10 = 7.1 *0.035 = 0.25 cfs;
Winter 7Q10 = 7.1 *0.099 = 0.70 cfs
Hunts Fork: DA = 11.9 sq.mi.; Summer 7Q10 = 11.9*0.035 = 0.42 cfs;
Winter 7Q10 = 11.9*0.099 = 1.18 cfs
Hamby Creek: DA = 30 sq.mi.; Summer 7Q10 = 30*0.035 = 1.05 cfs;
Winter 7Q10 = 30*0.099 = 2.97 cfs
Wastewater Flow
Scenarios 1 and 2: 8.2 MGD = 12.69 cfs
Scenarios 3 and 4: 10.0 MGD = 15.47 cfs
Velocity and Depth
Channel velocity and depth values will be associated with restored channel conditions and the amount of
water flowing through the channel. Total flow at the outfall point for the four scenarios will be as follows:
Scenario 1: Headwater 7Q10 (0.67 cfs) + Effluent (12.69 cfs) = 13.36 cfs
Scenario 2: Headwater 7Q10 (1.9 cfs cfs) + Effluent (12.69 cfs) = 14.59 cfs
Scenario 3: Headwater 7Q10 (0.67 cfs) + Effluent (15.47 cfs) = 16.14 cfs
Scenario 4: Headwater 7Q10 (1.9 cfs) + Effluent (15.47 cfs) = 17.37 cfs
TETRA TECH
5

High Point Westside WLA Analysis November 9, 2012
To be conservative, velocity and depth estimates for the restored channel will be based on the headwater
and effluent flows only. Adding tributary flows would increase velocity and depth slightly, but make the
reach calculations more complex without necessity.
Previous dye study and HEC-RAS model results for existing conditions in portions of the stream where
hydraulics are not impaired by the sand mining and excessive tree fall were used to estimate stream
channel velocity and depth. The July 2007 dye study for the portion of Rich Fork Creek between the
outfall and Hwy 109 sand mined pool showed a velocity of 0.85 fps for an estimated instream flow of
approximately 6 cfs. Average depth was measured at about 7 to 8 inches. HEC modeling results for a
restored channel throughout the sand mined areas for flows ranging from 10 cfs to 16 cfs produced
velocities ranging from 0.97 to 1.16 fps with depths ranging from 7 to 9 inches. However, sensitivity
analysis showed that as depth increased to over 12 inches, velocity would be expected to decrease. For
example, at a flow of 16 cfs and an average 1.1 ft depth, velocity averaged 0.79 fps.
Given some uncertainty about post -restoration channel conditions, lower velocities were input to the
model reflecting depths over 1 ft to provide for conservative assumptions. Using proportional
relationships between flow, velocity and depth from the HEC modeling the following input values were
estimated for each scenario:
Scenario 1: Velocity = 0.70 fps Average Depth = 1.02 ft
Scenario 2: Velocity = 0.74 fps Average Depth = 1.06 ft
Scenario 3: Velocity = 0.79 fps Average Depth = 1.10 ft
Scenario 4: Velocity = 0.83 fps Average Depth = 1.14 ft
Water Quality Parameters
Effluent Conditions
Scenario 1:
BODS = 5 mg/L
NH3N = 1 mg/L
DO=7mg/L
Scenario 2:
BOD5=10mg/L
NH3N = 1.8 mg/L
DO=7mg/L
Scenario 3:
BOD5=5mg/L
NH3N = 1 mg/L
DO = 7 mg/L
Scenario 4:
BODS = 10 mg/L
NH3N = 1.8 mg/L
DO=7mg/L
rj TETRA TECH
6

High Point Westside WLA Analysis November 9, 2012
Conversion of BOD5 to CBOD ultimate concentration was estimated using the Thomann and Mueller F-
ratio value of 2.47 (1987, Principles of Surface Water Quality Modeling and Control based on facility
studies). Kd was estimated using the Bosco equation for the defined velocities and depths for each
scenario (USEPA, 1985). Based on previous modeling data, the effluent will be assumed to have a
summer temperature of 25 C and winter temperature of 15 C.
Headwater Water Quality Conditions
Quality assured water quality data have been collected upstream of the High Point Westside outfall by the
Yadkin Pee -Dee River Basin Association (YPDRBA) since 1998. Station Q5745000 is located on Rich
Fork Creek at the Chestnut Street crossing. These data were used to establish headwater water quality
conditions. These assumptions were also applied to incremental baseflow for summer and winter,
respectively.
Summer Temperature: The 90`'' percentile of temperature monitored between the months of July through
October was calculated to provide the summer headwater temperature condition for the model. For 114
observations recorded between July 1998 and July 2012, the 90th percentile was calculated at 24.3 C.
Winter Temperature: The 90th percentile of temperature monitored during the month of November was
calculated to provide the winter headwater temperature condition for the model. For 12 observations
recorded between 1998 and July 2011, the 90th percentile was calculated at 13.6 C.
Summer DO: The median percent saturation for DO for the most recent five years of YPDRBA data
collected at Q5745000 for the summer period was 82 percent. At 24.3 C, this converts to a headwater DO
concentration for the model of 6.8 mg/L (i.e., 82 percent of 8.31 mg/L).
Winter DO: The median percent saturation for DO for the most recent five years of YPDRBA data
collected at Q5745000 for the winter period was 79 percent. At 13.6 C, this converts to a headwater DO
concentration for the model of 8.2 mg/L (i.e., 79 percent of 10.38 mg/L).
Summer Nitrogen: Upstream summer concentrations observed by YPDRBA for ammonia (NH3N) and
TKN have remained relatively consistent with period of record and last five year record being essentially
the same (0.07mg/L NH3N and 0.4 mg/L TKN). Summer headwater organic nitrogen concentration is
therefore assumed to be 0.33 mg/L (i.e., 0.4 mg/L TKN minus 0.07 mg/L NH3N).
Winter Nitrogen: Similar to the summer observations, upstream winter concentrations observed by
YPDRBA for ammonia (NH3N) and TKN have remained relatively consistent with period of record and
last five year record being essentially the same (0.06mg/L NH3N and 0.25 mg/L TKN). Winter headwater
organic nitrogen concentration is therefore assumed to be 0.19 mg/L (i.e., 0.25 mg/L TKN minus 0.06 mg/L
NH3N).
A complete record of all inputs can be found in the model input files for each scenario provided in
Attachments A - D.
3. MODEL APPLICATION RESULTS
Model predictions for DO, flow, CBOD, and NH3N are shown in Figures 3 through 6, respectively
(model output for all four scenarios is provided in Attachments A - D).
Flow Predictions
Figure 3 shows flow assumptions for the four modeled scenarios. This information helps in further
understanding predicted water quality results. Tributary flows change main stem water quality
concentrations in Rich Fork Creek, which can be seen in the line graphs for Figures 4 — 6 where the flow
changes occur.
i:i
TETRA TECH
7

High Point Westside WLA Analysis
November 9, 2012
1: 8.2 MGD Summer 2: 8.2 MGD Winter
—Run —Run
— — Run 3: 10 MGD Summer — — Run 4: 10 MGD Winter
25
20
1
LL15
1
O
010
J
u-
5
0
1111..11111/11111ilal•III ...n, ..f ,n., .. , .,.... .. . „n ...... .........I,,,...,,r,,.n,,,.,,n.. .,..,.,
O 43 0' NN. ti ti� 9R . 0h „ b be h 0'' 00' '1 'X' 0 to 9 9h ^O ^0h N �Nh N
Distance (mi)
Figure 3. Assumed Critical Flow Levels for the Four Modeled Scenarios
DO Predictions
The DO profiles in Figure 4 illustrate that in the summer, while the higher effluent DO temporarily
increases instream DO above background, a combination of lower baseflow DO, sediment oxygen
demand (SOD), CBOD decay, and reaeration are anticipated to achieve a rough equilibrium such that
relatively little change occurs after the sagpoint (miles 5 through 11.5 for summer conditions, and miles
0.2 to 5 in the winter).
a
1: 8.2 MGD Summer
Run 2: 8.2
Run 4: 10
MGD Winter
MGD Winter
—Run
— — Run 3: 10 MGD Summer
—
—
DO (mg/L)
D -x N W A Cis C) 1 CO G
t
1 '
_
_
—
�.,1111
I., 1111111.11iiI111111r11.1(11,11111.1111,,I,1,41111i111111111
O h P.. h ti b 0 h 0. h h h 0 b 1
Distance (mi)
43
0
0
of
h
0•
ti0 h
^0'
,�N N.
^N
ti%
Figure 4. Model Predicted DO Concentration Downstream of the High Point Westside Outfall
for Summer and Winter WLA Model Application Scenarios
OTETRA TECH
8

High Point Westside WLA Analysis November 9. 2012
The relatively smooth shape of the DO profiles is a reflection of the uniform assumption of depth and
velocity associated with restoration design goals. Actual depth and velocity will be expected to vary once
the stream channel adjusts to the restored stream channel segments and reduced number of treefall dams.
This in turn will be expected to produce more noise (variation) in the DO profile around this current
central tendency prediction. A quick check on model sensitivity was conducted using an across the board
reduction in velocity of 20 percent for Scenario 1(summer conditions); this reduced the sagpoint DO
concentration from 5.6 mg/L to 5.1 mg/L.
For the winter runs, the sagpoint is largely influenced by the effluent DO concentration. The permit
assumption of 7 mg/L DO in the effluent mixing with the 8.2 mg/L winter critical stream DO results in a
temporary sag of 1.2 mg/L. In reality, the effluent DO is likely to be closer to the stream DO because of
colder temperatures. However, the instream DO below the outfall is expected to stay well above the DO
standard (daily average of 5 mg/L) at the effluent limits of 10 mg/L BOD5 and 1.8 mg/L NH3N for both
8.2 and 10 MGD effluent flows. A quick check on model sensitivity was conducted using an across the
board reduction in velocity of 20 percent for Scenario 2 (winter conditions); this reduced the sagpoint DO
concentration from 7.0 mg/L to 6.8 mg/L between model milepoints 3 and 5, still well above the daily
average requirement of 5 mg/L.
CBOD Predictions
Figure 5 provides the CBOD ultimate profiles for the four modeled scenarios. The concentrations reflect
conservative estimates since intermediate baseflow other than tributary flow was not included in the
model. Additionally, actual effluent concentrations will be considerably less than permitted values in
order to maintain compliance.
25
20
�15
E
0110
0
5
Run 1: 8.2 MGD Summer
—Run 2: 6.2 MGD Winter
— — Run 3: 10 MGD Summer Run 4: 10 MGD Winter
o h 0. h ti h" h IN h 5 5 o h A 5 m hc5 ,�0 0 ,�N h �ti
Distance (mi)
Figure 5. Model CBOD Ultimate Concentration Predictions for WLA Scenarios
NH3N Predictions
Figure 6 provides the model predicted ammonia concentrations for the four WLA scenarios. Model output
shows that decay of organic nitrogen to ammonia is partially off -setting the impact of ammonia decay in
the model. This explains the relatively shallow decline evidenced in the plots of NH3N concentration.
Again, these would be considered conservative estimates of NH3N since intermediate baseflow other than
lb
TETRA TECH
9

Nigh Point Westside WLA Analysis
November 9, 2012
tributary flow was not included in the model. Also once again, actual effluent concentrations will be
considerably less than permitted values in order to maintain compliance.
1.8
1:8.2MGD
Summer
10 61GD Summer
2: 8.2 f.1GD Winter
—Run
— — Run 3:
—Run
— — Run 4: 10 MGD Winter
1.6
1.4
,... 1.2
13 1.0
0.8
Z
2 0.6
z
0.4
0.2
% 4
N.
rt.ti�
X
A ay
h yh o 6h 1 A-
Distance (mi)
%
gy
o or N^ h N ^Nh k1.
Figure 6. Model NH3N Concentration Predictions for WLA Scenarios
4. REFERENCES
NCDENR, 1990. NCDEM Wasteload Allocations Standard Operating Procedures Manual, Division of
Environmental Management, Water Quality Section.
NCDWQ. 10/15/12 email correspondence between Trevor Clements (Tetra Tech) and Julie Grzyb
(DWQ) regarding USGS low flow statistics and values to apply to WLA scenarios.
Tetra Tech, March 2006. Water Quality Modeling Scoping Analysis for the High Point Westside
Discharge to Rich Fork Creek. Prepared for the City of High Point and Hazen & Sawyer, P.C.
Tetra Tech, January 2008. Results of Phase I Field Monitoring and Model Updates for the High Point
Westside Discharge to Rich Fork Creek. Prepared for the City of High Point and and Hazen & Sawyer, P.C.
Tetra Tech, September 2009. Hydrology and Hydraulic Modeling Report for Rich Fork Creek, NC.
Prepared for the City of High Point and and Hazen & Sawyer, P.C.
Tetra Tech, October 19, 2009 Memorandum to DWQ from Trevor Clements and Alix Matos regarding
QUAL2E Modeling for Rich Fork Creek: Input Files.
Thomann and Mueller. 1987. Principles of Surface Water Quality Modeling and Control.
USEPA. 1985. Rates, Constants, and Kinetics Formulations in Surface Water Quality Modeling (second
edition). EPA/600/3-85/040.
USGS. 10/12/12 email from Curtis Weaver (USGS) to Trevor Clements (Tetra Tech) regarding USGS
low flow statistics for Rich Fork Creek.
USGS. 1993. Low flow characteristics of streams in North Carolina (USGS Water -Supply Paper 2403).
Th
TETRA TECH
10

High Point Westside WLA Analysis November 2, 2012
ATTACHMENT A. QUAL2E Model Input and Output for Scenario 1
TETRA TECH
11

WLAScenl.inp
TITLE01 Scenario 1 - Restored channel; Summer Critical Conditions
TITLE02
mgd
TITLE03 NO
TITLE04 NO
TITLE05 NO
TITLE06 NO
TITLE07 YES
TITLE08 NO
TITLE09 NO
TITLE10
TITLE11 YES
TITLE12
TITLE13 YES
TITLE14 NO
TITLE15 NO
ENDTITLE
LIST DATA INPUT
WRITE OPTIONAL SUMMARY
NO FLOW AUGMENTATION
STEADY STATE
NO TRAPEZOIDAL CHANNELS
PRINT SOLAR/LCD DATA
PLOT DO/BOD
FIXED DNSTRM CONC (YES=1) 0
INPUT METRIC (YES=1) 0
NUMBER OF REACHES 16
NUM OF HEADWATERS 1
TIME STEP (HOURS) 1
MAXIMUM SSTATE ITERATIONS 30
LATITUDE OF BASIN (DEG) 35
STANDARD MERIDIAN (DEG) 75
EVAP. COEFF. (AE) 0.00103
ELEV OF BASIN (ELEV) 680
ENDATA1
O UPTAKE BY NH3 OXID(MG 0/MG N) 3.43
O PROD BY ALGAE (MG 0/MG A) 1.6
N CONTENT OF ALGAE (MG N/MG A) 0.085
ALG MAX SPEC GROTH RATE(1/DAY) 2
N HALF SATURATION CONST (MG/L) 0.2
LIN ALG SHADE CO (1/H-UGCHA/L) 0.0027
LIGHT FUNCTION OPTION (LFNOPT) 1
DAILY AVERAGING OPTION (LAVOPT) 1
NUMBER OF DAYLIGHT HOURS (NDLH) 11.2
ALGY GROWTH CALC OPTION (LGROPT) 1
ALG/TEMP SOLR RAD FACTOR (TFACT) 0.45
ENDATA1A
ENDATA1B
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
STREAM
REACH
REACH
REACH
REACH
REACH
REACH
REACH
REACH
REACH
REACH
REACH
REACH
REACH
REACH
1 WWTP to 109 pool
2 through 109 pool
3 to Bedrock Knoll
4 to MS Rd
5 to confluence
6 to breakpoint
7 to ball road
8 through ball pool
9 to Kanoy Road
10 through kanoy pool
11 to shuler road
12 to utility easement
13 to below evans road
14 to below business 85
Rich Fork Creek from WWTP to mouth; High Pt discharge Q = 8.2
CONSERVATIVE MINERAL I
CONSERVATIVE MINERAL II
CONSERVATIVE MINERAL III
'TEMPERATURE
BIOCHEMICAL OXYGEN DEMAND
ALGAE AS CHL-A IN UG/L
PHOSPHORUS CYCLE AS P IN MG/L
(ORGANIC-P; DISSOLVED-P)
NITROGEN CYCLE AS N IN MG/L
DISSOLVED(ORGANIOXYGENC-N; MINNMG/L; NITRITE-N, NITRATE-N)
FECAL COLIFORMS IN NO./100 ML
ARBITRARY NON -CONSERVATIVE
5D-ULT BOD CONV K COEF
OUTPUT METRIC (YES=1) 0
NUMBER OF JUNCTIONS 0
NUMBER OF POINT LOADS 4
LNTH COMP ELEMENT (DX) 0.1
TIME INC. FOR RPT2 (HRS) 1
LONGITIUDE OF BASIN (DEG) 80
DAY OF YEAR START TIME 248
EVAP COEF. (BE) 0.0000094
DUST ATTENUATION COEF. 0.06
O UPTAKE BY NO3 OXID(MG 0/MG N)
O UPTAKE BY ALGAE (MG 0/MG A)
P CONTENT OF ALGAE (MG N/MG A)
ALGAE RESPIRATION RATE (1/DAY)
P HALF SATURATION CONST (MG/L)
NLIN SHADE (1/H-(UGCHA/L)**2/3)
LIGHT SATURATION COEF (INT/MIN)
LIGHT AVERAGING FACTOR (AFACT)
TOTAL DAILY SOLAR RADTN (INT)
ALGAL PREF FOR NH3-N (PREFN)
NITRIFICATION INHIBITION COEF
FROM
FROM
FROM
FROM
FROM
FROM
FROM
FROM
FROM
FROM
FROM
FROM
FROM
FROM
Page 1
12.5 TO
12.2 TO
12.0 TO
11.7 TO
10.9 TO
10.4 TO
9.9 TO
9.2 TO
9.0 TO
8.0 TO
7.9 TO
6.4 TO
5.6 TO
4.5 TO
1.14
1.9
0.013
0.1
0.04
0.0165
0.03
0.92
400
0.5
10
12.2
12.0
11.7
10.9
10.4
9.9
9.2
9.0
8.0
7.9
6.4
5.6
4.5
2.8

�.k-
The revision will be made.
Response to HP comments 8-31-2012
4- A_ J s. c`c-11.
Modification to Supplement to Cover Sheet:
Please revise item 03 on the Supplement to Cover Sheet to the following:
After receiving the proper Authorizations to Construct from the Division of Water Quality, as well as
Division approval based on positive demonstration of sufficient assimilative capacity, construct and
operate facilities giving the Westside WWTP a treatment capacity of 10 MGD_
.) /
i'
,t
T 1f14hCSL- S'C."r'L
11. e1,1 "O
4 1�
Regarding #2 on the Supplement: need to clarify if HP plans to construct to 10 MGD and operate at 8.2
MGD. If so, first HP would get an ATC for 10 and an ATO for 8.2 MGD. Than after Division approval, HP
will only need to aquire an ATO to operate at 10 MGD.
2. Monthly Average Effluent Limitation of 0.8 ms+l for Ammonia:
DWQ has not provided a justification for a 0.8 mg1 ammonia limit or justification for removing the
seasonal ammonia limits. It appears that DWQ has applied the 1999 instream criteria of 1 mgL to a flow
of 8.2 mgd and then held the load constant at 10 mgd resulting in a concentration of 0.8 mgl The
WWTP will have difficultly achieving a monthly average limit of 0.8 mg/1, particularly in the winter
months. Since 1999, North Carolina has used a stmmmer instream ammonia criteria concentration of 1.0
mg1 and a winter instream ammonia criteria concenaation of 1.8 mt1 for major dischargers in low flow
streams. The basis of the 1999 criteria is instream concentration; therefore, we believe the limit should
remain at 1 mill for the 10 mgd flow in the summer months and 1.8 mg'1 in winter months. The City has
passed all WET tests over the past several years, so therefore there are no toxicity issues associated with
the effluent. Furthermore, the QU_AL.2E model output (after stream restoration) shows a favorable
outcome for dissolved oxygen concentration in Rich Fork Creek. U S
According to the Speculative limits letter BOD/NH3 limits were based on freezing the current
(2009)permitted BOD ultimate loading. This loading was calculated to be 982 lb/day. Therefore, at 10
MGD the BODu is calculated to be 11.8 mg/L [982 Ib/d =(10 MGD x 8.34)]. Hence BOD5 was set at 4 and
NH3 at 0.8 (BOD5 of 4 x 2=8 mg/L plus NH3 of 0.84 x 4.5= 3.8 mg/L for a toatl of 11.8 BOD ultimate).
Seasonal Ammonia and BOD Limits in Section A(2) and Section A(3):
We request that seasonal limits for ammonia and BOD be added to Section A(2) and Section A(3).
4. Mercury:
We request an annual average mercury limit of 0.012 ug1 in lieu of a monthly average limit in accordance
with the DWQ mercury permitting strategy.
This methodology has not been approved by the EMC or EPA. We can put a re -opener clause in the
permit allowing the Permittee to request a modification when the Hg permitting strategy is approved
and adopted by the state.

Standard Conditions:
Please include the revised standard conditions with our permit, dated November 2011.
The final permit will include the Nov. 2011 standard conditions. The drafts will not include the standard
conditions; however they can be found on the DWQ/Surface Water/NPDES Hot Topics website.
' Effluent Pollutant Scan (effluent limits pages and Section A(8):
The draft permit states that an effluent pollutant scan must be performed annually. Please revise to three
scans required every five years to be consistent with federal NPDES permit requirements per DWQ's
letter dated September 19, 2011.
This change can be made, however, since this permit is to be renewed in April 2014 a scan from 2013
would be helpful. Is it 3 in 5 years or the last 3 yrs before permit renewal?
7. Reduction in Monitoring Frequency
k(i It is our understanding that the North Carolina Water Quality Association is working with DWQ on
0 revised monitoring frequency requirements for BOD, TSS, ammonia, fecal coliform. etc. We respectfully
request twice a week monitoring for BOD, TSS, fecal coliform, and winter ammonia.
This policy is being developed and the Permittee is welcome to request a permit modification,to make
these changes when it is approved. f -citG".
'b r c,� y y C/4%.4*N
8. Footnote 8(d) in Section A(3):
We request that Footnote 8(d) in Section A(3) be revised as follows:
Following the intensive modeling survey, after the stream restoration project is completed, the receiving
water quality model for Rich Fork Creek will be recalibrated for the approximately 12 mile segment
between the High Point Westside ouriall and the confluence with Abbotts Creek, to reflect the revised
physical conditions of the sneam due to the restoration project. The recalibrated model will be rerun with
existing flow, 8.2 mgd, and 10 mgd to analyze the impact of the discharge. Model results will be
compared with previous predictions and observed profiles to determine the level of impact on dissolved
oxygen concentrations. Based on previous modeling studies conducted by the City, it is anticipated that
(1) dissolved oxygen concentrations will generally be higher than pre -restoration profiles, particularly for
the segments previously impacted by sand mining activities, and (2) that increases in Westside discharge
rates will further increase dissolved oxygen concentrations above those under the existing and no flow
scenarios. The results of the modeling analyses will be submitted to DWQ for review: 1) submit two
copies of the modeling report and all associated electronic modeling files to DWQNPDES and 2) one
copy of the report and all associated electronic modeling files to the DWQrMTU.tnit Supervisor. The
City of High Point can proceed with an expansion to 10 MGD upon DWQ approval, based upon
validation of no negative impact to dissolved oxygen concentration from the increased discharge rate.
c (,( .••n ✓Cto, c / � � � ci et (� � � : � ,, . _ I ,,, HP has not been allowed to proceed with an expansion because downstream samples have been below
the state water quality std. Model predictions projected that the restoration would improve DO
downstream to meet water quality stds. If after restoration and expansion, downstream DO continues
to not meet state water quality stds. than an even larger expansion will not be permitted. However,
there are new techniques to improve oxygenation to significantly high levels that might enable
downstream DO levels to consistently meet 5 mg/L. If this was achieved, DWQ would allow the
expansion to 10 MGD.

i
ot .1 4, ".1-,/Z
9. Footnote 8(e) in Section A(3):
We request that Footnote 8(e) in Section A(3) be deleted The City has already optimised and maximized
DO in the effluent by installing diffusers in the effluent pump station to meet a 7 mg.L DO limit and
undertaking the stream restoration project to improve velocity and re -aeration in Rich Fork Creek. We
feel that the revised Footnote 8(d) in Section A(3) addresses the issue of the QUAL2E model with respect
to the 10 mgd expansion.
CWA - Boader goal of restoring and maintaining the chemical, physical, and biological
ntegrity of the nation's waters so that they can support "the protection and propagation
of fish, shellfish, and wildlife and recreation in and on the water."
No, every effort should be made to achieve the dissolved oxygen, in -stream state water
quality std. of 5 mg/L before an expansion can occur. First to expand to 8.2 MGD a
restoration project is being allowed with model predictions to raise the DO to meet the
state WQS. Second, after an expansion of 8.2 MGD is completed, if state WQS's are not
being achieved DO augmentation will be required in order to obtain an in -stream DO of
5 mg/L before an adiitional expansion to 10 MGD will be considered.
10. Section A(4) Instream Monitoring Requirements:
The instream monitoring requirements have increased from once a month in the previous permit to twice
per month in the current draft permit. The watershed is already targeted for a mrtrient TMDL due to
mrtrient loading_ We are unclear as how an increased monitoring burden would facilitate providing new
information to DWQ. We request that the monitoring frequency for nitrogen and phosphorus be reduced
to monthly.
Check with Mike, will corre i no reason.
11. Footnote 5 m Section A(2) and Section A(3):
Two 24-hour composite samples are taken for each quarterly chronic toxicity test. We request DWQ
clarify whether the metals sample should be taken with the first or second 24-hour composite sample.
It does not matter, as long as it is in conjunction with the toxicity test and the samples
are representative of the permitted discharge.
7 12. Footnote Addition to Sections A(1), A(2), and A(3):
We request that the following footnote be added to each effluent limits page:
If the Permittee monitors any pollutant more frequently than required by this permit, u¢iny, approved
analytical methods, the results of such monitoring shall be included in the calculation and reporting of the.
data submitted on the Discharge Monitoring Report and all Aquatic Toxicity forms submitted
Check std. conditions Q ' I() °' c
( (-�148
1s
Se-/J-N"

Monthly average effluent limitation of 0.8 mg/I for ammonia:
DWQ has not provided a justification for a 0.8 mg/L ammonia limit or justification for removing the
seasonal ammonia limits. It appears that DWQ has applied the 1999 instream criteria of 1 mg/L to a flow
of 8.2 mgd and then reduced the held the load constant at 10 mgd. The WWTP will have difficultly
achieving a monthly average limit of 0.8 mg/I, particularly in the winter months. Since 1999, North
Carolina has used a summer instream ammonia criteria concentration of 1.0 mg/I and a winter instream
ammonia criteria concentration of 1.8 mg/I for major dischargers in low flow streams. The basis of the
1999 criteria is instream concentration; therefore, the limit should remain at 1 mg/I for the 10 mgd flow
in summer months and 1.8 mg/I in winter months. The City has passed all WET tests over the past
several years, so therefore there are no apparent toxicity issues associated with the effluent.
Furthermore, the QUAL2E model output (after stream restoration) shows a favorable outcome for
dissolved oxygen concentration in Rich Fork Creek.
Mercury:
The permit does not contain any provision for re -opening the permit to accommodate the Post-TMDL
permitting strategy. We request that footnote 6 be revised to reflect a possible future change in the
mercury limit.
Standard Conditions:
Please include the revised standard conditions with our permit, dated November 2011.
Effluent Pollutant Scan (effluent limits pages and Section A(8)):
The draft permit states that an effluent pollutant scan must be performed annually. Please revise to
three scans required every five years to be consistent with federal NPDES permit requirements per
DWQ's letter dated September 19, 2011.
Reduction in Monitoring Frequency:
It is our understanding that the North Carolina Water Quality Association is working with DWQ on
revised monitoring frequency requirements for BOD, TSS, ammonia, fecal coliform, etc. We respectfully
request that a re -opener clause be added to our permit to consider monitoring frequency reductions
once a strategy is approved by DWQ.

Footnote 8(d) in Section A(3):
We request that Footnote 8(d) in Section A(3) be revised as follows:
Following the intensive modeling survey, after the stream restoration project is completed, the receiving
water quality model for Rich Fork Creek will be recalibrated for the approximately 12 mile segment
between the High Point Westside outfall and the confluence with Abbotts Creek, to reflect the revised
physical conditions of the stream due to the restoration project. The recalibrated model will be rerun
with existing flow, 8.2 mgd, and 10 mgd to analyze the impact of the discharge. Model results will be
compared with previous predictions and observed profiles to determine the level of impact on dissolved
oxygen concentrations. Based on previous modeling studies conducted by the City, it is anticipated that
(1) dissolved oxygen concentrations will generally be higher than pre -restoration profiles, particularly for
the segments previously impacted by sand mining activities, and (2) that increases in Westside discharge
rates will further increase dissolved oxygen concentrations above those under the existing and no flow
scenarios. The results of the modeling analyses will be submitted to DWQ for review: 1) submit two
copies of the modeling report and all associated electronic modeling files to DWQ/NPDES and 2) one
copy of the report and all associated electronic modeling files to the DWQ/MTU/Unit Supervisor. The
City of High Point can proceed with an expansion to 10 MGD upon DWQ approval, based upon validation
of no negative impact to dissolved oxygen concentration from the increased discharge rate."
Footnote 8(e) in Section A(3):
We request that Footnote 8(e) in Section A(3) be deleted. The City has already optimized and maximized
DO in the effluent by installing diffusers in the effluent pump station to meet a 7 mg/L DO limit and
undertaking the stream restoration project to improve velocity and re -aeration in Rich Fork Creek. We
feel that revised Footnote 8(d) in Section A(3) addresses the issue of the QUAL2E model with respect to
the 10 mgd expansion.
Section A(4) Instream monitoring requirements:
The instream monitoring requirements have increased from once a month in the previous permit to
twice per month in the current draft permit. The watershed is already targeted for a nutrient TMDL due
to nutrient loading. We are unclear as how an increased monitoring burden would facilitate providing
new information to DWQ. We request that the monitoring frequency for nitrogen and phosphorus be
reduced to monthly.

Public Services Department
W. Chris Thompson, P.E.
DIRECTOR
August 31, 2012
Ms. Julie Grzyb
NPDES Unit, Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina, 27699-1617
RE: Renewal of NPDES Permit Number NC0024228
Westside Wastewater Treatment Plant
City of High Point
Dear Ms. Grzyb,
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SEP 05 2012
DENR-WATERouALIT
POINT SOURCE BRANCH
The City of High Point received the draft National Pollutant Discharge Elimination System (NPDES)
permit for the referenced facility on July 31, 2012. We have reviewed this draft permit and respectfully
request the following changes or modifications:
1. Modification to Supplement to Cover Sheet:
Please revise item #3 on the Supplement to Cover Sheet to the following:
After receiving the proper Authorizations to Construct from the Division of Water Quality, as well as
Division approval based on positive demonstration of sufficient assimilative capacity, construct and
operate facilities giving the Westside WWTP a treatment capacity of 10 MGD.
2. Monthly Average Effluent Limitation of 0.8 mg/I for Ammonia:
DWQ has not provided a justification for a 0.8 mg/L ammonia limit or justification for removing the
seasonal ammonia limits. It appears that DWQ has applied the 1999 instream criteria of 1 mg/L to a flow
of 8.2 mgd and then held the load constant at 10 mgd, resulting in a concentration of 0.8 mg/1. The
WWTP will have difficultly achieving a monthly average limit of 0.8 mg/1, particularly in the winter
months. Since 1999, North Carolina has used a summer instream ammonia criteria concentration of 1.0
mg/1 and a winter instream ammonia criteria concentration of 1.8 mg/1 for major dischargers in low flow
streams. The basis of the 1999 criteria is instream concentration; therefore, we believe the limit should
remain at 1 mg/1 for the 10 mgd flow in the summer months and 1.8 mg/1 in winter months. The City has
passed all WET tests over the past several years, so therefore there are no toxicity issues associated with
the effluent. Furthermore, the QUAL2E model output (after stream restoration) shows a favorable
outcome for dissolved oxygen concentration in Rich Fork Creek.
City of High Point, P.O. 230, 211 South Hamilton Street, High Point, NC 27261 USA
Phone [phone] Fax: [phone] TDD 336.883.8517

3. Seasonal Ammonia and BOD Limits in Section A(2) and Section A(3):
We request that seasonal limits for ammonia and BOD be added to Section A(2) and Section A(3).
4. Mercury:
We request an annual average mercury limit of 0.012 ug/1 in lieu of a monthly average limit in accordance
with the DWQ mercury permitting strategy.
5. Standard Conditions:
Please include the revised standard conditions with our permit, dated November 2011.
6. Effluent Pollutant Scan (effluent limits pages and Section A(8):
The draft permit states that an effluent pollutant scan must be performed annually. Please revise to three
scans required every five years to be consistent with federal NPDES permit requirements per DWQ's
letter dated September 19, 2011.
7. Reduction in Monitoring Frequency:
It is our understanding that the North Carolina Water Quality Association is working with DWQ on
revised monitoring frequency requirements for BOD, TSS, ammonia, fecal coliform, etc. We respectfully
request twice a week monitoring for BOD, TSS, fecal coliform, and winter ammonia.
8. Footnote 8(d) in Section A(3):
We request that Footnote 8(d) in Section A(3) be revised as follows:
Following the intensive modeling survey, after the stream restoration project is completed, the receiving
water quality model for Rich Fork Creek will be recalibrated for the approximately 12 mile segment
between the High Point Westside outfall and the confluence with Abbotts Creek, to reflect the revised
physical conditions of the stream due to the restoration project. The recalibrated model will be rerun with
existing flow, 8.2 mgd, and 10 mgd to analyze the impact of the discharge. Model results will be
compared with previous predictions and observed profiles to determine the level of impact on dissolved
oxygen concentrations. Based on previous modeling studies conducted by the City, it is anticipated that
(1) dissolved oxygen concentrations will generally be higher than pre -restoration profiles, particularly for
the segments previously impacted by sand mining activities, and (2) that increases in Westside discharge
rates will further increase dissolved oxygen concentrations above those under the existing and no flow
scenarios. The results of the modeling analyses will be submitted to DWQ for review: 1) submit two
copies of the modeling report and all associated electronic modeling files to DWQ/NPDES and 2) one
copy of the report and all associated electronic modeling files to the DWQ/MTU/Unit Supervisor. The
City of High Point can proceed with an expansion to 10 MGD upon DWQ approval, based upon
validation of no negative impact to dissolved oxygen concentration from the increased discharge rate.
9. Footnote 8(e) in Section A(3):
We request that Footnote 8(e) in Section A(3) be deleted. The City has already optimized and maximized
DO in the effluent by installing diffusers in the effluent pump station to meet a 7 mg/L DO limit and

undertaking the stream restoration project to improve velocity and re -aeration in Rich Fork Creek. We
feel that the revised Footnote 8(d) in Section A(3) addresses the issue of the QUAL2E model with respect
to the 10 mgd expansion.
10. Section A(4) Instream Monitoring Requirements:
The instream monitoring requirements have increased from once a month in the previous permit to twice
per month in the current draft permit. The watershed is already targeted for a nutrient TMDL due to
nutrient loading. We are unclear as how an increased monitoring burden would facilitate providing new
information to DWQ. We request that the monitoring frequency for nitrogen and phosphorus be reduced
to monthly.
11. Footnote 5 in Section A(2) and Section A(3):
Two 24-hour composite samples are taken for each quarterly chronic toxicity test. We request DWQ
clarify whether the metals sample should be taken with the first or second 24-hour composite sample.
12. Footnote Addition to Sections A(1), A(2), and A(3):
We request that the following footnote be added to each effluent limits page:
If the Permittee monitors any pollutant more frequently than required by this permit, using approved
analytical methods, the results of such monitoring shall be included in the calculation and reporting of the
data submitted on the Discharge Monitoring Report and all Aquatic Toxicity forms submitted.
We very much appreciate the time and effort of the NPDES Unit to consider our requests for this permit
modification. Please do not hesitate to call me (336-883-3215) if you have any questions.
Sincerely,
City of High Point
W. Chris Thompson, P.E.
Director of Public Services
cc: Terry Houk, Assistant Director, Public Services Department
Tim Fitzgerald, ORC, Westside Wastewater Treatment Plant
Alan Stone, Hazen and Sawyer
Todd Johnson, Hazen and Sawyer
Trevor Clements, Tetra Tech
Mary Sadler, Hazen and Sawyer

o • •
Grub,.Julie
From: Sadler, Mary [[e-mail]]
Sent: Tuesday, April 03, 2012 9:40 AM
To: Grzyb, Julie
Cc: TERRY HOUK; DAWN WILSON
Subject: RE: questions on Westside's permit modification
Attachments: EPA-Form-2a-20090710-DWQ-SWP-NPDESI_REV Parts D and E.pdf
Good morning Julie,
Attached are the completed Parts D and E of High Point's NPDES permit application. In the process
of filling part D out with the three recent PPA data sets, we found a typo for zinc in the January
2010 PPA. Dawn is going to be sending you an amended PPA in the mail by tomorrow.
Mary
Original Message
From: Grzyb, Julie [mailto:[e-mail]]
Sent: Monday, April 02, 2012 10:09 AM
To: Sadler, Mary
Subject: RE: questions on Westside's permit modification
Mary,
Thanks, I received your revised comment. Do you have Parts D and E finished? I will need them
before I can move forward with this permit.
Julie
Original Message
From: Sadler, Mary [mailto:[e-mail]]
Sent: Monday, April 02, 2012 9:36 AM
To: Grzyb, Julie
Cc: TERRY HOUK
Subject: RE: questions on Westside's permit modification
Hi Julie,
We realized late last week that we gave you incorrect information in response to your question #1.
During the design of the stream restoration project, the length of restoration was reduced. At the
upstream end of Rich Fork Creek, restoration will be 975 feet. At the creek crossing with Ball
Road, restoration will be 1,295 feet. At the creek crossing with Kanoy Road, the restoration length
is 805 feet. The total restoration length is 3,075 feet spanning a creek length of 4.17 miles.
Please let me know if you have any questions. I apologize for the miscommunication on our end!
Mary
Original Message
From: Sadler, Mary
Sent: Monday, March 26, 2012 9:19 AM
To: Julie Grzyb ([e-mail])
Cc: 'TERRY HOUK'
Subject: RE: questions on Westside's permit modification
Good morning Julie,
Terry has asked me to send you responses to your questions on the NPDES permit modification for
Westside, as he is at a conference this week:
1

1) 'lease specify the length of Rich Fork Creek in which the restoration project is to occur?
Please describe the starting point location and the ending point location as accurately as
'posible.
The restoration of Rich Fork Creek will occur in three different locations in the creek. Starting
at the upstream end of Rich Fork Creek, restoration will occur at approximately 1,637 feet at the
creek crossing with NC 109, approximately 1,709 feet at the creek crossing with Ball Road, and
approximately 1,406 feet at Kanoy Road. The total stream restoration length is 4,752 feet. The
Westside WWTP outfall is less than a half mile upstream of NC 109.
2) In some of the comment letters there is a statement stating that -The City has agreed to work
with DWQ on alternative strategies if the stream improvement in DO is lower than the model
projections. Than it says that the applicant indicates the WWTP will be constructed with side
stream oxygen capabilities to ensure that dissolved oxygen in the permit limits are met. Please
describe what is meant by "side stream oxygen capabilities" (if known) and is this being added
initially or down the road if needed?
The City will construct a post aeration system at the discharge point for the entire effluent
discharge via air diffusers in the effluent pump station. The City will maintain a dissolved oxygen
concentration of 7.0 ppm in the effluent.
3) My understanding is there will be two separate monitoring programs occurring in relationship to
the restoration project. First, the summer following completion of the stream restoration, High
Point's consultant (Tetra Tech) will perform stream monitoring and measurements in an effort to re -
calibrate and re -run the QUAL2E model to assess the validity of the model predictions. Second,
ambient monitoring through the City of High Point's membership to the YPDRBA. Is this correct and
is there any other monitoring I should be aware of?
Yes, there will be two separate monitoring activities association with the plant expansion. The
first activity is intensive data collection and monitoring at the three stream restoration sites
for QUAL2E model calibration and validation. The stream restoration monitoring will be performed
the summer after the restoration project is finished. The second monitoring activity is the long-
term stream monitoring in association with the Yadkin Pee Dee River Basin Association (YPDRBA).
4) There are three stations currently performing ambient monitoring through the City of High
Point's membership to the YPDRBA, they are- Q574500O (Rich Fork Creek at SR1757 - Chestnut St.)
Q5750000 referred to in the Hazen & Sawyer letter dated 1-13-2010 to NC Wildlife Resources
Commission (Rich Fork Creek at SR1755) was discontinued on 11/2009 and replaced with Q5745000.
Q5785000 (Rich Fork at SR1787, downstream of the Westside WWTP), and Q5790000 (Rich Fork Creek at
SR2123, upstream of Abbotts Creek
The YPDRB Association is currently renegotiating its MOA with DWQ and several of these sites are
proposed for removal. Can you confirm that they will not be removed from the YPDRBA MOA?
We have confirmed that Stations Q5745000, Q5785000, and Q5790000 will remain active as part of the
YPDRBA ambient monitoring (per email correspondence with Tim Fitzgerald on March 19, 2012).
4) Please supply the river distance (approximately) from the Westside WWTP's point of discharge to
each of the three ambient stations listed above.
Q5785000 - located approximately 3.8 miles downstream of the Westside WWTP outfall.
Q5790000 - located approximately 9.0 miles downstream of the Westside WWTP outfall (5.2 miles from
Q5785000).
Q5745000 - located approximately 11.2 miles downstream of the Westside WWTP outfall (2.2 miles from
Q5790000).
Also, Part D. and Part E. of the permit modification NPDES From 2A need to be completed and
submitted. I told Todd Johnson this several weeks ago so he may already be working on it.
We will send you completed parts D. and E. within the next two weeks.
2

thank you Julie. If anything still seems confusing, please give me a call.
Mary
Original message
From: "Grzyb, Julie" <[e-mail]>
To: TERRY HOUK <[e-mail]>
Sent: Tue, Mar 13, 2012 21:57:13 GMT+00:00
Subject: questions on Westside's permit modification
March 13, 2012
Subject: Permit
Modification Request NC0024228
City of High Point
Westside WWTP
Davidson Counnty
Dear Mr. Terry Houk,
Can you clarify a few items for me regarding the High Point Westside modification
1) Please specify the length of Rich Fork Creek in which the restoration project is to occur?
Please describe the starting point location and the ending point location as accurately as
possible.
2) In some of the comment letters there is a statement stating that -The City has agreed to work
with DWQ on alternative strategies if the stream improvement in DO is lower than the model
projections. Than it says that the applicant indicates the WWTP will be constructed with side
stream oxygen capabilities to ensure that dissolved oxygen in the permit limits are met. Please
descibe what is meant by "side stream oxygen capabilities" (if known) and is this being added
initially or down the road if needed?
3) My understanding is there will be two separate monitoring programs occurring in relationship to
the restoration project. First, the summer following completion of the stream restoration, High
Point's consultant (Tetra Tech) will perform stream monitoring and measurements in an effort to re -
calibrate and re -run the QUAL2E model to assess the validity of the model predictions. Second,
ambient monitoring through the City of High Point's membership to the YPDRBA. Is this correct and
is there any other monitoring I should be aware of?
4) There are three stations currently performing ambient monitoring through the City of High
Point's membership to the YPDRBA, they are- Q5745000 (Rich Fork Creek at SR1757 - Chestnut St.)
Q5750000 referred to in the Hazen & Sawyer letter dated 1-13-2010 to NC Wildlife Resources
Commission (Rich Fork Creek at SR1755) was discontinued on 11/2009 and replaced with Q5745000.
Q578500 (Rich Fork at SR1787, downstream of the Westside WWTP), and Q5790000 (Rich Fork Creek at
SR2123, upstream of Abbotts Creek
The YPDRB Association is currently renegotiating its MOA with DWQ and several of these sites are
proposed for removal. Can you confirm that they will not be removed from the YPDRBA MOA?
3

4) Yeasd supply the river distance (approximately) from the Westside WWTP's point of discharge to
each of'the three ambient stations listed above.
Also, Part D. and Part E. of the permit modification NPDES From 2A need to be completed and
submitted. I told Todd Johnson this several weeks ago so he may already be working on it.
Your assistance in addressing these questions is appreciated. If you have any questions, please
contact me at 919-807-6389 or on my email address at
[e-mail]<mailto:[e-mail]>.
Respectfully,
Julie A. Grzyb
Environmental Engineer, NPDES Complex Permitting
[cid:image001.jpg@01CD0142.8602C450]
4

Grzyb, Julie
From:
Sent:
To:
Cc:
Subject:
Hi Julie,
Sadler, Mary [[e-mail]]
Monday, April 02, 2012 9:36 AM
Grzyb, Julie
TERRY HOUK
RE: questions on Westside's permit modification
We realized late last week that we gave you incorrect information in response to your question #1. During the design of the stream
restoration project, the length of restoration was reduced. At the upstream end of Rich Fork Creek, restoration will be 975 feet.
At the creek crossing with Ball Road, restoration will be 1,295 feet. At the creek crossing with Kanoy Road, the restoration
length is 805 feet. The total restoration length is 3,075 feet spanning a creek length of 4.17 miles.
Please let me know if you have any questions. I apologize for the miscommunication on our end!
Mary
Original Message
From: Sadler, Mary
Sent: Monday, March 26, 2012 9:19 AM
To: Julie Grzyb ([e-mail])
Cc: 'TERRY HOUK'
Subject: RE: questions on Westside's permit modification
Good morning Julie,
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40k
Terry has asked me to send you responses to your questions on the NPDES permit modification for Westside, as he is at a conference
this week:
1) Please specify the length of Rich Fork Creek in which the restoration project is to occur? Please describe the starting point
location and the ending point location as accurately as possible. s' a $ a
4%;:\e—
The restoration of Rich Fork Creek will occur in three different locations in the creek. Starting at the upstream end of Rich Fork
Creek, restoration will occur at approximately 1,637 feet at the creek crossing with NC 109, approximately 1,709 feet at the creek
crossing with Ball Road, and approximately 1,406 feet at Kanoy Road. The total stream restoration length is 4,752 feet. The
Westside WWTP outfall is less than a half mile upstream of NC 109.
2) In some of the comment letters there is a statement stating that -The City has agreed to work with DWQ on alternative
strategies if the stream improvement in DO is lower than the model projections. Than it says that the applicant indicates the
WWTP will be constructed with side stream oxygen capabilities to ensure that dissolved oxygen in the permit limits are met.
Please describe what is meant by "side stream oxygen capabilities" (if known) and is this being added initially or down the road
if needed?
1

The City will construct a post aeration system at the discharge point for the entire effluent discharge via air diffusers in the
effluent pump station. The City will maintain a dissolved oxygen concentration of 7.0 ppm in the effluent.
3) My understanding is there will be two separate monitoring programs occurring in relationship to the restoration project.
First, the summer following completion of the stream restoration, High Point's consultant (Tetra Tech) will perform stream
monitoring and measurements in an effort to re -calibrate and re -run the QUAL2E model to assess the validity of the model
predictions. Second, ambient monitoring through the City of High Point's membership to the YPDRBA. Is this correct and is there
any other monitoring I should be aware of?
Yes, there will be two separate monitoring activities association with the plant expansion. The first activity is intensive data
collection and monitoring at the three stream restoration sites for QUAL2E model calibration and validation. The stream
restoration monitoring will be performed the summer after the restoration project is finished. The second monitoring activity is
the long-term stream monitoring in association with the Yadkin Pee Dee River Basin Association (YPDRBA).
4) There are three stations currently performing ambient monitoring through the City of High Point's membership to the YPDRBA,
they are- Q5745000 (Rich Fork Creek at SR1757 - Chestnut St.) Q5750000 referred to in the Hazen & Sawyer letter dated 1-13-2010 to
NC Wildlife Resources Commission (Rich Fork Creek at SR1755) was discontinued on 11/2009 and replaced with Q5745000.
Q5785000 (Rich Fork at 5R1787, downstream of the Westside WWTP), and Q5790000 (Rich Fork Creek at SR2123, upstream of Abbotts
Creek
The YPDRB Association is currently renegotiating its MOA with DWQ and several of these sites are proposed for removal. Can you
confirm that they will not be removed from the YPDRBA MOA?
We have confirmed that Stations.Q5745000, Q5785000, and Q5790000 will remain active as part of the YPDRBA ambient monitoring (per
email correspondence with Tim Fitzgerald on March 19, 2012).
4) Please supply the river distance (approximately) from the Westside WWTP's point of discharge to each of the three ambient
stations listed above.
Q5785000 - located approximately 3.8 miles downstream of the Westside WWTP outfall.
Q5790000 - located approximately 9.0 miles downstream of the Westside WWTP outfall (5.2 miles from Q5785000).
Q5745000 - located approximately 11.2 miles downstream of the Westside WWTP outfall (2.2 miles from Q5790000).
Also, Part D. and Part E. of the permit modification NPDES From 2A need to be completed and submitted. I told Todd Johnson this
several weeks ago so he may already be working on it.
We will send you completed parts D. and E. within the next two weeks.
Thank you Julie. If anything still seems confusing, please give me a call.
Mary
2

_----Original message
From: "Grzyb, Julie" <[e-mail]>
To: TERRY HOUK <[e-mail]>
Sent: Tue, Mar 13, 2012 21:57:13 GMT+00:00
Subject: questions on Westside's permit modification
March 13, 2012
Dear Mr. Terry Houk,
Subject: Permit Modification Request NC0024228
City of High Point
Westside WWTP
Davidson Counnty
Can you clarify a few items for me regarding the High Point Westside modification -
1) Please specify the length of Rich Fork Creek in which the restoration project is to occur? Please describe the starting point
location and the ending point location as accurately as possible.
2) In some of the comment letters there is a statement stating that -The City has agreed to work with DWQ on alternative
strategies if the stream improvement in DO is lower than the model projections. Than it says that the applicant indicates the
WWTP will be constructed with side stream oxygen capabilities to ensure that dissolved oxygen in the permit limits are met.
Please descibe what is meant by "side stream oxygen capabilities" (if known) and is this being added initially or down the road if
needed?
3) My understanding is there will be two separate monitoring programs occurring in relationship to the restoration project.
First, the summer following completion of the stream restoration, High Point's consultant (Tetra Tech) will perform stream
monitoring and measurements in an effort to re -calibrate and re -run the QUAL2E model to assess the validity of the model
predictions. Second, ambient monitoring through the City of High Point's membership to the YPDRBA. Is this correct and is there
any other monitoring I should be aware of?
4) There are three stations currently performing ambient monitoring through the City of High Point's membership to the YPDRBA,
they are- Q5745000 (Rich Fork Creek at SR1757 - Chestnut St.) Q5750000 referred to in the Hazen & Sawyer letter dated 1-13-2010 to
NC Wildlife Resources Commission (Rich Fork Creek at SR1755) was discontinued on 11/2009 and replaced with Q5745000.
Q578500 (Rich Fork at SR1787, downstream of the Westside WWTP), and Q5790000 (Rich Fork Creek at SR2123, upstream of Abbotts Creek
The YPDRB Association is currently renegotiating its MOA with DWQ and several of these sites are proposed for removal. Can you
confirm that they will not be removed from the YPDRBA MOA?
4) Please supply the river distance (approximately) from the Westside WWTP's point of discharge to each of the three ambient
stations listed above.
3

Also; Part D. and Part E. of the permit modification NPDES From 2A need to be completed and submitted. I told Todd Johnson this
several weeks ago so he may already be working on it.
Your assistance in addressing these questions is appreciated. If you have any questions, please contact me at 919-807-6389 or on
my email address at [e-mail]<mailto:[e-mail]>.
Respectfully,
Julie A. Grzyb
Environmental Engineer, NPDES Complex Permitting
[cid:image001.jpg@01CD0142.8602C450]
4

Grzyb, Julie
From: Ruhlman, Carrie
Sent: Friday, February 24, 2012 8:12 AM
To: Grzyb, Julie
Cc: Belnick, Tom
Subject: RE: High Point Westside WWTP permit modification request
Attachments: J.Grzyb_HighPoint2.24.12.xlsx; YPDRBA 2008-2013 MOA.pdf; YPDAmend#1.pdf; YPDRBA MOA Revision 1 - 4.13.2009.pdf; YPDRBA MOA
Revision#3 9.2010.pdf; YPDRBA MOA Revision#2.pdf
Julie,
I've attached the YPDRBA's current MOA and revisions (we've had quite a few over the years). I've also attached a station list for Rich Fork Ck.
1. Station Q5750000 was active 6/1/1998 —11/1/2009. We discontinued this station b/c it was chronically dry. It was replaced by station Q5745000. So the
answer to your question is no, High Point's consultant did NOT correctly identify the station that is currently being sampled.
2. We agreed (internally) not to remove these stations b/c of High Point's expansion. All three coalition stations currently being sampled on Rich Fork Ck will
remain active. I already conveyed this to the Association.
3. I'm not sure what their, or our definition of extensive is, but it doesn't include metals at the moment. In fact, none of the Rich Fork Ck stations were ever
monitored for metals. All of the other parameters listed (DO, nutrients and turbidity) are sampled at all stations except for Q5745000. No turbidity is sampled
there. That can always be changed if you need it though. The attached station list details the parameters sampled and the frequency.
The YPDRBA has requested that their MOA be renewed when we finalize the new monitoring plan. I'm not exactly sure when that will be b/c I haven't received a
request to modify any of the parameters yet (we were reviewing the current monitoring in two stages: a) station locations; b) parameters). I'll be sending around
another internal request for comments when I receive that. Their MOA is up for renewal in July of next year anyhow.
If you have any questions about the attachments, or what we can add/modify based on their current monitoring, please let me know. Thanks for the heads -up!
Carrie Ruhlman
NC Division of Water Quality
Phone: [phone]
[e-mail]
http: / / portal.ncdenr.org/web /wai /ess/eco /coalition
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
A Please consider the environment before printing this e-mail.
From: Grzyb, Julie
Sent: Thursday, February 23, 2012 5:47 PM
To: Ruhlman, Carrie
Cc: Belnick, Tom
Subject: High Point Westside WWTP permit modification request
1

Carrie,
I On working on a permit modification for an expansion of the High Point Westside WWTP. DWQ is allowing the City to expand from 6.2 to 8.2 if they agree to perform
stream restoration. After stream restoration, they state the City has committed to an extensive monitoring program as part of the YPDRBA MOA. The three stations
they refer to are:
Q5750000 (Rich Fork Creek at SR1755) I do not see this station on Tedder's or DWQ's lists, just Q5745000 at (Rich Fork Creek at SR1757 — Chestnut St.)
Q578500 (Rich Fork at SR1787, downstream of the Westside WWTP), and
Q5790000 (Rich Fork Creek at SR2123, upstream of Abbotts Creek
First, can you help me clarify the first station; did High Point's consultant correctly identify a different site then what we had on pprevious lists?
Second, I can not have High Point claim extensive monitoring will occur at these stations if any of these sites are to be removed from the MOA, therefore, do you know if
these sites going to remain in the MOA?
Third, the City claims monitoring for dissolved oxygen, nutrients (TN and TP), turbidity, and metals will be performed. a) What parameters does the current MOA require
and how often and b) what will the next MOA require and how often. Also, since this permit may require a Public Hearing can you send me a copy of the current MOA.
1 appreciate your help on this, conditions requiring High Point to follow through on this sampling, if the YPDRBA does not, may need to be added to the permit but I need
to know where things currently stand.
FYI, after High Point completes the stream restoration and re -calibrates and re -runs the QUAL2E model they will have to verify that improvements to DO were made as
predicted before expansion to 10 mgd can be puursued. However, the modified permit will have two additional effluent sheets — 8.2 and 10 MGD with all sorts of
conditions.
Thanks,
Julie
Julie A. Grzyb, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
NPDES Complex Permitting, Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6389 (wk); 919/807-6495 (fax)
**Please note, my email address has changed to /ulie.Rrzvb(a)J,cdenr.Rov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be disclosed to third parties.
2

EfPc
Environmental Assessment for
Westside Wastewater Treatment
Plant Expansion
Executive Summary
EXECUTIVE SUMMARY
This project consists of a State Environmental Policy Act (SEPA) Environmental Assessment (EA) to allow
the City of High Point's Westside Wastewater Treatment Plant (WWTP) to apply for a discharge permit for
an increased capacity from 6.2 mgd to 10 mgd (phased from 6.2 to 8.2 mgd and 8.2 to 10 mgd). Pursuant
to the North Carolina State Environmental Policy Act (SEPA), expansion of an existing discharge facility by
500,000 gallons per day (gpd) or greater requires an EA to be completed and a Finding of No Significant
Impact (FONSI) to be issued before the Division of Water Quality (DWQ) will issue permits and approvals.
The City of High Point is proposing this project to solve projected wastewater needs in the service area for
the 20-year planning period. In addition, a stream restoration project has been negotiated with DWQ as part
of the proposed project. Modeling efforts have indicated that the stream restoration project is a feasible
option for providing additional assimilative capacity for the expanded discharge in Rich Fork Creek.
The majority of the City of High Point is located in the southwest corner of Guilford County but also
expands into parts of Davidson, Forsyth, and Randolph Counties. The Westside WWTP service area
consists of 47.7 square miles and currently includes the Yadkin -Pee Dee River Basin portions of the City of
High Point. The majority of the undeveloped Westside WWTP service area is in the rural, unincorporated
areas of Davidson County. The service area located west of Oak Hollow Lake, is bounded by NC 109 to the
west, and follows most of US Route 311 to the north and east and 1-85 to the south. The service area also
includes unincorporated portions of northeastern Davidson County and western areas of the City of High
Point.
Direct impacts may be caused by construction and operation of the project. Direct impacts will be mitigated
with erosion and sedimentation control measures and BMPs. Although most of the Westside service area is
not located within the city limits of High Point, the City requires all development that utilizes the Westside
WWTP infrastructure to adhere to the ordinances detailed in the "High Point Development Ordinance" and
to adhere to the City of High Point administrative approval process.
The water quality impact to Rich Fork Creek as a result of the expanded discharge was addressed by
intensive water quality modeling and field work. Tetra Tech conducted water quality modeling and
evaluations to support an expanded Westside WWTP discharge into Rich Fork Creek. The modeling
results determined that the removal of the low velocity pools in Rich Fork Creek, in conjunction with the
process upgrades in the Westside WWTP expansion project, should result in attainment of the dissolved
oxygen standard. Tetra Tech performed modeling of the proposed restored stream areas with and without
the discharge expansion. Tetra Tech concluded that stream restoration is a feasible option for providing
additional assimilative capacity for the expanded discharge.
DWQ issued a speculative limits letter on November 10, 2009 for the 6.2 to 10 mgd expansion after the
submittal of an Engineering Alternatives Analysis (EAA). The letter granted speculative limits for a two-part
phasing of the expansion. DWQ agreed to grant a plant capacity increase from 6.2 mgd to 8.2 mgd to allow
for a better prediction of effects incurred by the Rich Fork Creek stream restoration. The stream restoration
Hazen and Sawyer Project No. 3460-012
HAZENAND SAWYER
Envi,onmental Engineers 8 Scientists

Environmental Assessment for
Westside Wastewater Treatment
Plant Expansion
Executive Summary
project will be bid with the Phase 3 plant improvements. The City will perform an intensive monitoring
survey of Rich Fork Creek in the summer following the completion of the stream restoration project. Data
collected from the summer monitoring survey will be used to re -calibrate the water quality model. The re -
calibrated water quality model will then be used to add a scenario for the 10 mgd expansion. Upon
completion of the restoration project, monitoring, and model yalidation,the City will be authorized to
increase the Westside WWTP capacity from 8.2 to 10 mgd. The City will have completed all obligations as
outlined by DWQ in the speculative effluent limits letter.
Secondary and cumulative impacts resulting from the proposed project will be minimized with the City of
High Point's Secondary and Cumulative Impacts Management Plan (SCIMP). The Memorandum of
Agreement between the Department of Environment and Natural Resource (DENR) and the City of High
Point regarding the use of the SCIMP has been in effect since January 2010 and the Record of Decision,
prepared by DWQ, was issued on March 16, 2010. The SCIMP was a formal review process, including
scoping, whereby all agencies were asked to comment on the material presented in the draft documents.
The SCIMP addresses secondary and cumulative impacts and corresponding mitigative measures for
topography, floodplains, soils, land use, wetlands, prime or unique agricultural land, public lands and
recreational areas, cultural and historic resources, air quality, noise, surface and groundwater resources,
forest resources, shellfish and fish, wildlife and vegetation, and toxic substances.
Hazen and Sawyer Project No. 3460-012
HAZENAND SAWYER
Environmental Engineers a. Scientists

•
Environmental Assessment for
Westside Wastewater Treatment
Plant Expansion
Table of Contents
Executive Summary i
1. Proposed Project Description 1-1
1.1 Introduction 1-1
1.2 Proposed Project Scope 1-1
1.3 Project Description 1-2
2. Need for the Project
2.1 Growth Trends and Population Projections
2.2 Wastewater Demand Projections
2.3 Existing Facilities
2-1
2-1
2-2
2-2
3. Discharge Alternatives Analysis 3-1
3.1 Discharge Alternative 1 — No Action 3-1
3.2 Discharge Altemative 2 — Land Application 3-1
3.3 Discharge Alternative 3 — Reuse Spray Irrigation 3-3
3.4 Discharge Alternative 4 — Surface Water Discharge (Selected Alternative) 3-4
4. Project Alternatives Analysis 4-1
4.1 No -Action Altemative 4-1
4.2 Eastside Wastewater Treatment Plant Expansion 4-1
4.3 Westside Wastewater Treatment Plant Expansion (Selected Altemative) 4-3
5. Existing Environmental Characteristics 5-1
5.1 Topography 5-1
5.2 Soils 5-2
5.3 Land Use 5-3
5.4 Wetlands 5-3
5.5 Prime or Unique Agricultural Lands 5-4
5.6 Public Lands and Scenic, Recreational and State Natural Areas 5-4
5.7 Areas of Archaeological or Historical Value 5-5
5.8 Air Quality 5-5
Hazen and Sawyer Project No. 3460-012
HAZINAND SAWYER
iii
Environmental Engineers it Scientists

•
41
Environmental Assessment for
Westside Wastewater Treatment
Plant Expansion
Table of Contents
5.9 Noise Levels 5-6
5.10 Water Resources 5-6
5.11 Forest Resources 5-10
5.12 Shellfish or Fish and Their Habitats 5-10
5.13 Wildlife and Natural Vegetation 5-11
6. Predicted Environmental Effects 6-1
6.1 Topography 6-1
6.2 Soils 6-2
6.3 Land Use 6-2
6.4 Wetlands 6-2
6.5 Prime or Unique Agricultural Lands 6-3
6.6 Public Lands, Scenic and Recreational Areas 6-3
6.7 Areas of Archaeological or Historical Value 6-3
6.8 Air Quality 6-4
6.9 Noise Levels 6-4
6.10 Water Resources 6-5
6.11 Forest Resources 6-6
6.12 Shellfish or Fish and Their Habitats 6-6
6.13 Wildlife and Natural Vegetation 6-7
6.14 Introduction of Toxic Substances 6-15
7. Mitigative Measures
7.1 Direct Impacts
7.2 Secondary and Cumulative Indirect Impacts
8. State and Federal Permits Required
9. Literature Cited
10. Qualifications of Preparers
7-1
7-1
7-1
8-1
9-1
10-1
Hazen and Sawyer Project No. 3460-012
HAZENAND SAWYER
iv
Environmental Eopineert S Scientists

s
4
I
Environmental Assessment for
Westside Wastewater Treatment
Plant Expansion
Table of Contents
Figures
Figure 1-1: Westside WWTP Service Area 11-2
Figure 41: Proposed Upgrade and Expansion Improvements to Westside WWTP 11-3
Figure 5-1: Floodplains in Westside Service Area 11-4
Figure 5-2: National Wetlands Inventory Wetlands in Westside Service Area 11-5
Figure 5-3: Watersheds in Westside Service Area 11-6
Figure 5-4: Surface Waters in Westside Service Area 11-7
Figure 5-5: U.S. Geological Service Map 11-8
Tables
Table 2-1: Population Projections for Westside WWTP Service Area 2-1
Table 2-2: Wastewater Flow Projections for the City of High Point Westside WWTP Service Area 2-2
Table 3-2: Current and Speculative Effluent NPDES Permit Limits for Westside Wastewater Treatment
Plant 3-5
Table 3-3: Present Worth Analysis for Altemate Discharge Location to Abbots Creek 3-6
Table 4-1: Present Worth Analysis for Wastewater Diversion to Eastside WWTP 4-2
Table 4-2: Present Worth Analysis for the Proposed Upgrade and Expansion of Westside WWTP to
10 mgd 4-4
Table 5-1: Westside Service Area Surface Water Classifications 5-7
Table 5-2: Protected Species Listed for Forsyth, Guilford, Davidson, and Randolph Counties, North
Carolina 5-14
Table 6-1: Summary of impacts to Threatened and Endangered Species 6-8
Hazen and Sawyer Project No. 3460-012
EnvLronmantal Engineers E Sclsatists

Environmental Assessment for
Westside Wastewater Treatment
Plant Expansion
State and Federal Permits Required
8. State and Federal Permits Required
• State Environmental Policy Act (SEPA) Environmental Assessment (EA) review and issuance of a
Finding of No Significant Impact (FONSI).
• Authorization to Construct (ATC) from the Division of Water Quality (DWQ).
• Air Emissions Permit from Division of Air Quality (DAQ) for emergency back-up generator.
• Erosion and Sedimentation Control Plan approval from the Division of Land Resources.
• DWQ State Stormwater Permit for Construction.
• National Pollutant Discharge Elimination System (NPDES) permit from DWQ.
• Land -disturbing permit from City of High Point.
• Site plan approval from Davidson County.
Hazen and Sawyer Project No. 3460-012
HAZENAND SAWYER
Environmental Engineers & Scientists
8-1

•
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02-21-2012 PZ MINUTES 3
plant couldn't change tomorrow because of growth, either. The sand rock and poor soils were
common along the creek areas. High Point City Council would work with the County on the
higher density areas.
Guy Cornman concurred with Mr. Thompson on better coordinating with City of High Point
with long range planning and city agreements. More study and work would be done with the
City as far as the Mutual Growth Area Agreement and County wished to go to the table with
this. He understood historically situations had occurred, concerning density and steps will be
taken for the best interest of the citizens; good faith efforts working with municipalities and
growth.
John Hedgecock stated that he had worked on a recommendation for several weeks, since the
last meeting of the Planning Board and as a farmer in the Abbotts Creek area; he respected
the concerns of the Friends of Rich Fork Creek. With the County Attorney's review, Mr.
Hedgecock expressed:
"I move that this Board recommend approval of this Special Use request with the following
conditions:
1) the project be completed as described in the submitted plans;
2) from the evidence submitted at its hearing, the Board of Commissioners under Standard E
(THE PROPOSED USE WILL SERVE AND BENEFIT DAVIDSON COUNTY AND ITS
CITIZENS) specifically address the following concerns:
a) Should the DENR permitted treatment capacity ever be raised beyond 8.2 mgd (a
55% increase from the currently usage of 3.69 mgd and which should be sufficient to
service the City of High Point and the Rich Fork service area);
b) Has sufficient and reliable analysis and study of the effects of the expansion on the
Abbotts Creek watershed been completed by the petitioner and or independent
sources (NCDENR, etc.);
c) How will the expansion affect the flooding of the Abbotts Creek Watershed which
has increased with growth in the area?
d) Since the Abbotts Creek Watershed contains a large amount of farmland, how
would this expansion and the possible increased flooding and addition of a sewer line
affect agricultural production especially in light of the increased EPA regulations on
farm products to meet GAP (Good Agricultural Practices) regulations if an overflow
of sewer happened in the area? Would there be liability issues for farmers and
possibility the City of High Point;
e) Since Abbotts is a rural area with no industry in need of additional sewer services,
how would residents of Abbotts Creek benefit economically or from a service
prospective?
While the City of High Point has met its initial burden of addressing the conditions in the
Ordinance for the purposes of our recommendation, it is the opinion of this Board that the
fact fmding Board, the Board of Commissioners, should examine these and other related
issues regarding this Special Use closely before making its determination.
Kelly Smith seconded the motion subject to the conditions stated by Mr. Hedgecock.
The vote stood at 4 to 0.
Chairman Long asked the concerned parties to attend the Public Hearing scheduled for the
first Monday in April, the 2nd, at 7:00 PM in this same meeting room. The Board of
Commissioners would make their decision at that time.

• V 02-07-2012 PZ Minutes 2
'VV. SPECIAL U SE PERMIT. CLASS A REQUEST
A. City of High Point
Request by the City of High Point for a Special Ue Permit, Class A,
Sanitary Sewage Plant (Capacity Expansion) in Thomasville
Township, Tax Map 308, Lot 3 containing 42.0 acres more or less
and is in a RA-3, Rural Agricultural District. Said property is
located at the end of West Burton Road approximately .8 mile west of
the Burton Road intersection.
Guy Comman introduced the application by the City of High Point in regards to their
progression in the improvements of the facility on Burton Road. The Public Hearing for this
item was scheduled for March 5 th, 2012. Mr. Cornman introduced Chris Thomson and his
staff and asked them to present their testimonies concerning the proposed enhancements. Mr.
Cornman noted that Mike Slusher from Davis Martin and Powell was present as the
consulting engineer on the project as well as High Point City's staff Attorney Joanne Carlisle.
He asked the Board to consider, referring to Exhibit A in the packet, the information the city
provided in support of the four general standards. Also, there were several exhibits, Mr.
Cornman explained, that would be viewed throughout the City's presentation including the
current improvement history, the plant location, site plan, the different phases, all color coded
on the screen.
Joanne Carlisle stated that they City relied on the consulting engineers for their expertise and
she would answer any further questions the Board, Staff, or audience might have concerning
the request.
Chris Thompson, the Public Works Director for the City of High Point, referred to Exhibit A
and explained, briefly, the history of the WWTP and referred to the views of the topography,
as displayed on the screen. He explained the annexation agreement and location and he said
that this was not part of any annexation by the City of High Point. He stated that the main
construction components of Phase III were identified on the attached Exhibits I, and 2. He
further pointed out the service areas and the gravity flows for those areas. The modification
would help the capacity capabilities for the next 20 years, down the road and would assist in
the wastewater treatment for Ledford Downs, Friendship Elementary, and Ledford Middle
School and High school.
Guy Cornman asked about the policy for sewer service on request.
Chris Thompson stated that inside the annexed area there was a cheaper rate for customers.
Some customers came in for voluntary annexation. Outside the annexed area the customers
paid an outside rate which typically ran double the rate. It was a case by case basis and goes
to the City Council for final approval. Special approvals, for example, came to us, such as
Ledford Oaks, and Ledford Downs. Mr. Thompson referred to slides one and two. The
project would increase the WWTP's treatment capacity from the current 6.2 MGD to 8.2
MGD upon the completion of Phase 3. Upon the completion of stream restoration work in
Rich Fork Creek, the State would increase the permitted treatment capacity to 10.0 MGD. He
explained the improvements with Phase I and II which fixed the fixed dilapidated
infrastructure and reduced collection system's overflow (SSO). New pumps were installed
and there was the capability of more grit removal. A protective berm was built along Rich
Fork Creek, a concrete affluent channel was built as well with new filters and many of the
many of the violations of the past came from the faulty filters. Flooding was prevented on site
and pumps brought storm water to the creek. Early 2000 there were major improvements and

• City of High Point Westside WWTP Upgrades SUP Class A
City of High Point Vilestside WWTP Upgrades
Special Use Perini; Applioation - Januar" 2012
Exhibit A Pg. 1
GENERAL STANDARD #1
The improvements to the Westside WWTP will promote public health, safety and welfare, in that they will
enhance the quality of wastewater treatment for the area being served, to the standards established by the
State of North Carolina. The improvement will also minimize its impacts on the neighboring properties by
including odor control facilities. The WWTP improvements are being constructed in multiple phases as
described herein (refer to attached exhibits EX-1 & EX-2 for illustrations):
Phase 1 was completed in 2009. The goals of Phase 1 were to replace aging process equipment and
improve treatment efficiency. The main components of Phase 1 were as follows:
Improved Preliminary Treatment Facilities by constructing a new structure which replaces the
existing influent pumps, screening equipment, and grit collection equipment. New screening and grit
collection equipment will be enclosed to minimize objectionable odors.
✓ Im proved the sludge storage facilities by retrofitting both existing tanks with aeration and corers to
m inim ize objectionable odors.
Sludge handling process im proved by providing the flexibility to haul liquid or dew atered sludge to
the Eastside VINO? for ultim ate disposal.
/ O dor Control is provided for both the Prelim inary Treatm ent Facility and Sludge Storage Tanks to
m inim ize objectionable odors.
Phase 2 is substantially complete and w ill be fully completed in spring 2012. The objectives of Phase 2
w ere to replace aging process equipm ent, im prove treatment capabilities and reliability, and provide
protection from flooding. The main components of Phase 2 w ere as follows:
New effluent filtration structure including low lift pum ps, air scour blowers, electrical equipment, and
new sludge pumps.
' Additional disinfection equipm ent by adding a second UV disinfection unit in the spare channeland
replacing the control system . The UV system w ill be covered to facilitate operations and
m aintenance.
✓ to prore solids tlitbtiitp fitilitits Iy iisItIlieg i it, rotary Iroe tiicltrtr iol iecilliry wile ell
Hilt tie etistiig Mils Naidlitg liiiliig.
flood priofiig of tit silt to protect agaiesl flood die igt ty coistrictiil Toro iloig tit tisteri
aid i esters Aerie Her to ae tlerotiii of 111. i its store i aler pie p stitioo i is iestille1 to
pin I nit store i filer and lulled efilieil dirk! periods of big1 OMB floc .
telinills 'of ririois milli If egiipe tit
Tiest in prone tits tibaice tit orerallgealhp 0f let tfflieet Iy prorilieg a eft effective eel reliable
fiitrelioi eel 1isieftctio1, ail II lire a side ize le pacts to tit sirfact i aters o I tt e slate.
Laostrectioe of phase 1 is aeticipatel to belie io see a er of 1111 eel It coo plettl ael operitioiilo dish
l b r t t tears (s t t attached schedule, EX-3). The goals of Phase 3 are to replace aging process equipment,
provide improved treatment capabilities, and provide biological nitrogen and phosphorus removal capability.
Hazen and Sawyer and Davis -Martin -Powell & Associates Page 1
DPP Project 100033

1
City of High Point Westside WWTP Upgrades
V1.44/7? Exhibit A
Use Permit A DD.C.7;aik . n , iFnuar 012
SUP Class A
Pg . 2
Pending approval by NC Division of Water Quality this project will increase the WWTP's permitted treatment
capacity from the current 6.2 MGD to 8.2 MGD upon completion of Phase 3. Upon completion of stream
restoration work in Rich Fork Creek and demonstration of improved water quality parameters for DO, the
State will increase the permitted treatment capacity to 10.0 MGD (refer to EX4, Speculative Limits Letter).
The main construction components of Phase 3 are identified on the attached exhibits (EX 1, EX2) and
described as follows:
v Additional aeration basins for wastewater treatment
• Additional treatment basins for biological nutrient removal
• Additional final clarifier basin and retrofits to existing clarifiers
New Recycle Pump Station and Blower Building
V Retrofits of various auxiliary equipment
d' Auxiliary dissolved oxygen enhancement at effluent
These improvements will enhance the overall quality of the effluent by reducing the amount of nutrients
(nitrogen and phosphorus) discharged into Rich Fork Creek and High Rock Lake. This in turn minimizes
impact to the surface waters of the state.
GENERAL STANDARD #2
The Phase 3 Improvements to the Westside WWTP will comply with all required regulations and standards
as follows (refer to EX I & EX2):
• Lot size is greater than 3 acres
v Lot coverage is less than 30%
• Lot width is greater than 125 feet
• Front, side and rear setbacks are greater than 30, 15, and 20 feet, respectively
v All new structures will be less than 35 feet tall. The new Recycle Pumping and Blower Building; is
the tallest structure in this Phase with a roof height of approximately 24 feet.
V Site security is provided in the form of perimeter security fencing and controlled gate access.
GENERAL STANDARD #3
The Phase 3 Improvements to the Westside WWTP will maintain or increase the value of contiguous
property, in that it will improve the facilities appearance, operational quality, and control of noxious odors,
while also increasing the building value of the property. The use petitioned herein is a public necessity in
that the service area's wastewater treatment needs will continue to be met.
GENERAL STANDARD #4
The Phase 3 Improvements to the Westside WWTP are in compliance with the general plans for physical
development of the county in that they will enhance the service areas development by providing necessary
wastewater treatment services.
Hazen and Sawyer and Davis -Martin -Powell & Associates Page 2
DMP Project 100033

gbitpl-,41€ 4e ill -11 ) Z/UP/
Belnick, Tom
From: Belnick, Tom
Sent: Friday, December 02, 2011 12:13 PM
To: Grzyb, Julie
Cc: Matthews, Matt; Poupart, Jeff; Basinger, Corey •
Subject: High Point Westside expansion
Julie- I noticed that an NPDES permit mod request for expansion of High Point Westside came in 11/22 and was assigned
to you. It already received a FONSI determination, but there are several conditions associated with the proposed
phased expansion. This may be a contentious permit mod with likely public hearing. Please set up a meeting with me in
the next few weeks to review history. Thanks.
Corey- let me know if you want to be voiced into this meeting. NPDES will send WSRO a pre -draft before going out to
public notice.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
1

Public Services Department
November 18, 2011 NORTH CAROLINA'S INTERNATIONAL CITYTH
Mr. Jeff Poupart
Point Source Branch Chief
N.C. Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: City of High Point
Westside Wastewater Treatment Plant
NPDES Permit Modification, Permit No. NC0024228
Dear Mr. Poupart,
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Enclosed are three (3) copies of the NPDES permit modification package for the City of High Point
Westside Wastewater Treatment Plant (WWTP) Expansion Project. This application is for the major
expansion of the Westside WWTP from its current capacity of 6.2 mgd to a two-part expanded capacity of
8.2 mgd followed by a capacity of 10 mgd. The application package includes the following information:
• This cover letter
• An application fee for $1,030.00, Check No. 596704
• Completed NPDES Permit Application — Form 2A
• Speculative Limits for WWTP Expansion to 10 mgd — Letter provided by DWQ on November 10,
2009
• Engineering Alternatives Analysis (EAA)
• Finding of No Significant Impact (FONSI)
An Engineering Alternatives Analysis (EAA) was submitted in March 2009 by Hazen and Sawyer to the
Division of Water Quality (DWQ) prior to issuance of speculative effluent limits. The EAA concluded that
the most feasible and cost effective effluent discharge option was the expansion of the effluent discharge
into Rich Fork Creek. A final Environmental Assessment and FONSI was sent to the Department of
Administration Environmental Clearinghouse in December 2010 by DWQ. The project cleared on
January 4, 2011.
The project was divided into three phases to balance the debt service. The City is currently in the
process of construction of Phase 2 and design of Phase 3 of the expansion project.
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax: [phone] Phone: [phone] TDD: 336.883.8517

Public Services Department
NORTH CAROLINA'S INTERNATIONAL CITYTM
The City respectfully requests a revised NPDES permit for phased limits for 8.2 and 10 mgd per DWQs
speculative limits letter. A stream restoration project has been negotiated with DWQ as part of the
upgrade and expansion project to provide additional assimilative capacity for the expanded discharge in
Rich Fork Creek. DWQ agreed to grant a plant capacity increase from 6.2 mgd to 8.2 mgd to allow for a
better prediction of effects incurred by the Rich Fork Creek stream restoration. The stream restoration
project will be bid with the Phase 3 plant improvements. The City will perform an intensive monitoring
survey of Rich Fork Creek in the summer following the completion of the stream restoration project. Data
collected from the summer monitoring survey will be used to re -calibrate the water quality model. The re -
calibrated water quality model will then be used to validate the 10 mgd expansion. Upon completion of
the restoration project, monitoring, and model validation, the City will be authorized to increase the
Westside WWTP capacity from 8.2 to 10 mgd. The City will have completed all obligations as outlined by
DWQ in the speculative effluent limits letter.
If after your review you have any questions or comments concerning this permit modification package,
please do not hesitate to contact us.
Sincerely,
Terry Houk
Assistant Director of Public Services
Enclosures:
Please see above list.
cc: Chris Thompson, P.E., High Point
John Hodges, High Point
Timothy Fitzgerald, High Point
Alan Stone, P.E., Hazen and Sawyer
Mary E. Sadler, P.E., Hazen and Sawyer
File
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax: [phone] Phone: [phone] TDD: 336.883.8517

City of High Point Westside WWTP
NPDES Permit No. NC0024228
Outfall 001
Additional Information
B.2 Topographic Map
Refer to Figure 1 for topographic map and Figure 2 for Plant site map.
B.3 Process Flow Description
The Westside Wastewater Treatment Plant (WWTP) provides advanced biological nutrient
removal wastewater treatment to meet effluent limits for discharge to Rich Fork Creek. The
major processes at the WWTP include coarse and fine screening, influent pumping, grit removal,
primary clarification, activated sludge system including secondary clarification, tertiary filtration,
alum phosphorus removal facilities, ultraviolet disinfection, and solids handling.
To balance the debt service over the life of the project, a three-phase project was
recommended to upgrade and expand the Westside WWTP from the current permitted flow
capacity of 6.2 mgd to 10 mgd to meet the 20-year planning period projected flows. Phase 1,
completed in 2009, consisted of a new preliminary treatment facility (PTF) with odor control.
Phase 2, currently in construction, consists of new tertiary filters with a filter feed pump station,
ultraviolet disinfection improvements, a new stormwater effluent pump station, solids handling
improvements, and a flood control retaining wall and berm. Phase 3 is in the final design phase.
It is expected that plans and specifications will be submitted in the 4th Quarter of 2011 for an
authorization to construct (ATC), and the project will bid in early 2012. Phase 3 will consist of
improvements to aeration equipment (converting to a 5-stage biological nitrogen removal
process), a new nitrified recycle (NRCY) pump station, new clarifier mechanisms in both primary
and secondary clarifiers, the construction of a new secondary clarifier, and supplemental carbon
storage and feed facilities.
Figure 3 illustrates the process flow diagram and includes a water balance through the plant.
The following is a narrative describing each treatment process including modifications in Phase 2
and 3 of the upgrade and expansion project.
Coarse Screening
Raw wastewater enters the plant via two interceptors (a 36-inch diameter interceptor from the
east and a 48-inch interceptor from the north) that combine in a manhole upstream of the PTF
influent channel. Influent gravity flows to the PTF via a 48-inch diameter line. A single
mechanical coarse bar screen removes accumulated screenings and prevents clogging of the
influent pumps. Bypass weirs are provided in the event of screen clogging or high plant influent
flow that direct wastewater to the influent pump wet well.
1

6
City of High Point Westside WWTP
NPDES Permit No. NC0024228
Outfall 001
Influent Pumping
In order to maintain gravity flow through the plant, four influent pumps lift the wastewater to a
higher elevation and discharge it into the preliminary treatment influent channel for fine
screening, flow metering, and grit removal. Four vertical turbine solids handling pumps with
VFDs are provided (one at 7.5 mgd, two at 15 mgd, and one at 4 mgd) for a total capacity of
26.5 mgd. When peak flows approach 26.5 mgd, the 4 mgd pump will be replaced with a second
7.5 mgd pump providing a firm capacity of 30 mgd. The 7.5-mgd pumps with turndown provide
the minimum flow pumping requirement of 2.3 mgd. Wetwell elevation setpoints are
controlled by an ultrasonic level sensor.
Fine Screening
Fine screening consists of two mechanically -cleaned step screens each equipped with a
screenings press and one manually -cleaned screen for backup. The screens remove rags, sticks,
and other large objects to prevent clogging and interference with operation of downstream
pumps and other process equipment. The screening facilities are designed for a peak flow of
30 mgd with two screens operating. A Parshall Flume is provided at the downstream end of
each screen channel to measure influent flow. The screenings presses wash, compact, and
transport the screenings to a dumpster for later disposal in a landfill.
Grit Removal
Following fine screening and influent flow measurement, wastewater is routed through two
channels to the grit collectors. Two vortex grit collectors operate in parallel for removal of sand
and other heavy inorganic particles. Grit removal is provided to reduce abrasion on
downstream equipment and to minimize reductions in process efficiency due to accumulation of
inorganic material in process units. Grit cyclones and grit classifiers are provided to remove
organic material from the settled grit. The grit is then deposited in a dumpster for ultimate
disposal in a landfill.
Primary Clarification
Two 70-foot diameter primary clarifiers have been in service since 1983. The clarifiers have a
maximum capacity of 24 mgd. It was determined that additional primary clarification capacity
was not needed to meet the proposed limits for the plant expansion. However, a bypass around
the primary clarifiers will be provided to pass approximately 6 mgd directly to the BNR tanks to
meet the expected plant peak flow of 30 mgd. Settleable solids are concentrated and then
pumped to the sludge holding tank. The existing clarifier mechanisms will be replaced in Phase
3 due to age.
2

8
City of High Point Westside WWTP
NPDES Permit No. NC0024228
Outfall 001
Activated Sludge System
The purpose of the activated sludge system is to achieve BOD removal, phosphorus removal,
and nitrification/de-nitrification necessary to comply with the stringent effluent requirements.
The activated sludge system is comprised of aeration tanks, secondary clarifiers, and return
activated sludge (RAS) and waste activated sludge (WAS) conveyance.
Aeration
Secondary influent will enter the aeration tank influent channel combined with RAS from the
secondary clarifiers. In the Phase 3 upgrade and expansion project, the existing three (3)
aeration tanks will be converted into a 5-stage biological nutrient removal. The existing tanks
will be expanded and a fourth aeration basin will be constructed to remove TP and TN required
to meet permit limits. A fine bubble aeration system and jet mixing system will be installed to
provide the dissolved oxygen and mixing necessary for operation of the activated sludge
process. A new nitrified recycle (NRCY) pump station and blower building will also be required
in this phase.
Secondary Clarification
Effluent from the aeration tanks flows by gravity via two 36-inch diameter lines from the
aeration tanks to each of two 90-foot diameter secondary clarifiers. The clarifiers are suction
header type clarifiers. A new 120-foot clarifier will be required for the plant expansion to
10 mgd and will be constructed in Phase 3. This third clarifier will have suction header type
mechanisms consistent with current equipment at the Westside WWTP. The clarifier
mechanisms in the existing two secondary clarifiers will be replaced due to age in Phase 3.
RAS and WAS Conveyance
Sludge is removed from the secondary clarifiers using three RAS pumps housed in the existing
RAS pump station. A new WAS pump station is being constructed in the Phase 2 project in the
Filter building, and two new RAS pumps will also be provided in the same location for additional
RAS capacity with the construction of the new secondary clarifier in Phase 3. WAS is removed
from the system via a branch line off of the common discharge header from the existing RAS
pumps. New RAS and WAS flow meters and a WAS throttling pinch valve located downstream
of the flow meters were provided in Phase 2 to control flow rates.
Tertiary Filtration
Tertiary filters remove additional suspended solids from the secondary clarifier effluent. New
filters are being constructed in Phase 2 of the upgrade and expansion project to replace the
existing two traveling bridge filters. New filter feed pumps are also included in Phase 2 to lift
the secondary effluent for gravity flow through the filters, UV disinfection, and to discharge to
Rich Fork Creek. A 48-inch diameter pipeline conveys secondary clarifier effluent by gravity
3

d
City of High Point Westside WWTP
NPDES Permit No. NC0024228
Outfall 001
immediately to the filter feed pumps (vertical turbine solids handling pumps. Five deep bed
filters are being provided and designed with the ability to convert to denitrification filters.
Adequate space adjacent to the existing filters is provided in the event that additional filter
capacity is required. The underdrain system collects the filtered effluent and directs it to a 48-
inch pipe for gravity flow to the UV disinfection facilities. Backwash water is drained do the
backwash waste storage tank, and from there is returned to the preliminary treatment facility
influent wet well.
Ultraviolet Disinfection
Disinfection is accomplished via ultraviolet (UV) disinfection technology. UV modifications will
be made in the existing UV facility to meet a peak design flow of 30 mgd by replacing the
current UV equipment in the two (2) channels with similar equipment capable of handling the
additional capacity.
Effluent Pump Station
A new effluent pump station is being constructed in Phase 2 to pump plant effluent along with
storm water into a single outfall pipe. During normal operation, effluent will be discharged by
gravity to Rich Fork Creek via a 54-inch diameter effluent pipeline. In the event of flood
conditions, check valves will prevent flood waters from backing up into this structure. Three
vertical propeller pumps will direct effluent and storm water over the berm and through a Tined
channel into the creek.
Post Aeration
To meet a minimum of 7 mg/L of dissolved oxygen required by the speculative limits for the
expanded plant capacity, post aeration facilities will need to be provided to prevent permit
violation. Post aeration options that are being reviewed include fine bubble diffusers. The post
aeration facility will be located in the effluent pump station in Phase 3.
Solids Treatment
With the Phase 2 upgrades, primary sludge and WAS will be pumped directly to the new rotary
drum thickener. Thickening is accomplished with polymer addition prior to pumping by the
thickened waste activated sludge (TWAS) pumps to one of two sludge holding tanks. Thickened
solids are pumped from the sludge holding tanks to the centrifuge for dewatering. Dewatered
solids are trucked to the Eastside WWTP for incineration. Refer to the Residuals Management
Plan for more details.
4

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410

KLa Systems
Scope, Budget Price and Delivery
t �tcc
Scope bk, i vt-s
ing zone
Upstream 5 Systems Model K2BJ (16-in. liquid x 8-in .air) Bi-Directional Jet Mixer/Aerators
Eight (8) KL8 vinyl ester resin FRP with horizontal jets located 18-in. off the basin floor, 16-in.
fabricated o ipe 16_in_ liquid suction pipe, 8-in. air downcomer pipe.10-in. diameter back flush
liquid supply flanged connections, with all required in -basin supports (304 SS) and hardware (18-
riser pipe, all diners (EPDM) warranty, and documentation.
8 SS), GIamP
Downstream swing
Sygterns Model K2DJA-4 (10-in. liquid x4-in.air) Directional Jet Mixer/Aerators
Twenty (20)f vinyl ester resin FRP with horizontal jets located 18-in. off the basin floor, 10-in.
fabricated o iPe 10 in. liquid suction i e, 4-in. air downcomer pipe, 6-in. diameter back flush
liquid supply P ed connections, with all required in -basin supports (304 SS) and hardware (18-
riser pipe, all fll?Iners (EPDM), warranty, and documentation.
8 SS), CIaMP
�oxZsx tS
Price
price for the above scope and services is: $ 634.000
Estimated
fora period of 90 days from the date of this proposal. After this date, the price is
Price
subject ricis v change' and a re -quote is recommended.
o
Freight not included
Gan be offered at a cost of $650 per day plus travel and expenses.
Field service
DEL_ IVY
schedule is based upon current availability of materials. This schedule can be
The delivery time of an order.
confirmed at the
Approval 4 weeks after order acceptance
Drawings for Basin equipment 16 weeks after release to manufacture
Shipment of in
6

ATA
NCDENR
North.Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Govemor Director Secretary
SEP 1 .9 2011
Subject: NPDES Annual Effluent Pollutant Scan Reporting Requirement
Reduction in Monitoring Frequency
Dear NPDES Permittee:
The purpose of this letter is to notify you that, effective immediately, the Division of Water Quality is
modifying the Effluent Pollutant Scan requirements in all municipal NPDES wastewater permits that contain
them. The effect is to reduce the required frequency of the scans from once per year to three times per 5-year
permit cycle, consistent with the federal NPDES permit application requirements (40 CFR 122.21) and Form
2A. The Division's intent is to help affected permittees reduce monitoring expenditures associated with their
wastewater discharges.
Rational for Existing Effluent Pollutant Scan Monitoring Requirement
As a municipal wastewater treatment facility' that discharges effluent to surface waters of the state, you are
required to provide expanded effluent testing data for the pollutants listed within Part D of the NPDES permit
application. Part D requires evaluation of the listed effluent pollutants based on at least three pollutant scans
that are no more than four and one-half years old at the time of application submittal. To ensure Part D of the
NPDES application requirement is met and to further validate the effluent waste stream characteristics have
not changed significantly, your NPDES permit currently requires an Effluent Pollutant Scan to be performed
annually and submitted to the Division.
Rational for Changes to the Monitoring Requirement
Given that three pollutant scans are needed to satisfy the requirements of Part D of the NPDES permit
application, the Division has reduced the annual monitoring requirement. Permittees, at a minimum, must
conduct and submit Effluent Pollutant Scans to the Division for at least the last three years of the permit's
cycle. Permittees will need to ensure samples taken for the pollutant scans are representative of the effluent
waste stream and are representative of seasonal variations. Please refer to your NPDES permit for specific
instructions.
To satisfy the annual reporting requirement specified in your NPDES permit, you must either submit the data
from the Effluent Pollutant Scan or submit the new NCDWQ NPDES Effluent Pollutant Scan Waiver Form.
This form may be submitted in lieu of performing the Effluent Pollutant Scan if no significant changes in your
facility's effluent waste stream characteristics occurred within the reporting year and if you will still be able to
meet the three pollutant scan requirement in time for the next NPDES application submittal.
1. Municipal wastewater treatment facilities with a design flow greater than or equal to 1.0 MGD or having (or required to have) a pretreatment
program, or are otherwise required by the Division to provide additional effluent data.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquafity.org
An Equal opportunity 1 Affirmative Action Employer
Notte Carolina
�tura!ly

This form acts as a placeholder to bridge the reporting requirement from annual to three times per 5-year
permit cycle and will be available from the Division's website on the Compliance Forms tab under Reporting
Forms (http://portal.ncdenr.org/web/wq/swp/ps/npdes/appforms) for download and completion. If applicable,
the form should be completed and submitted to the Division postmarked no later than December 31 st to meet
the reporting requirement for a particular reporting year.
Affected NPDES permits will be modified upon renewal to reflect the monitoring frequency change for the
Effluent Pollutant Scan.
If you have any questions regarding the contents above, please contact Vanessa Manuel at 919/807-6392 or
via email at Vanessa.Manuel@a,ncdenr.gov.
Sincerely,
Jeffrey Poupart
Point Source Branch Chief
Cc: DWQ SWP Section Regional Office Supervisors
Michele Scott, IPU Supervisor

• r
NCDWQ NPDES EFFLUENT POLLUTANT SCAN WAIVER FORM
In lieu of performing the required annual Effluent Pollutant Scan and to satisfy the NPDES reporting
requirement, a municipal wastewater treatment facility may complete and submit this form to NCDWQ if
the following criteria are met:
> The facility can still meet the requirement to perform three pollutant scans for its next NPDES
permit application; and
> Has a design flow greater than or equal to 1.0 MGD; or
> Is required to have. a pretreatment program (or has one in place); or
> Is otherwise required by the NCDWQ to conduct an annual effluent pollutant scan.
Facility Name:
NPDES Permit Number:
Outfall Number:
Effective Date:
(Complete form for each outfall discharging effluent to waters of
the state and requiring an annual Effluent Pollutant Scan.)
Expiration Date:
Owner Information
Person Certifying the Form
Title (if applicable):
Title or Position with facility:
Mailing Address:
Mailing Address:
Telephone:
Telephone:
By completing and submitting this form, I, , (printed name) certify
that the effluent waste stream for the facility and outtall indicated above has not significantly changed
within the past year in a manner that would cause any of the listed parameters to be present or present in
concentrations.greater than previously reported and I hereby submit this completed form to satisfy the
NPDES annual Effluent Pollutant Scan reporting requirement for calendar year
I also attest that the facility can still meet the requirement to perform three pollutant scans for the next
NPDES permit application.
Certified by (signature):
Position or title of certifier:
Date certified:
This completed form shall be submitted along with the Discharge Monitoring Report to the following address: Division
of Water Quality/Surface Water Protection Section / Central Files, 1617 Mail Service Center, Raleigh, North Carolina
27699-1617.

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Annual Monitoring and Pollutant Scan
Permit No.: NC0024228
Outfall: 001
Facility Name: City of High Point - Westside POTW
Date of sampling:
ORC: Mike Swan
Phone: 336 - 822 - 4782
Analytical Laboratory: Water Quality Laboratory - City of High Point
Meritcch - Reidsville
Month : April
Year: 2011
Parameter
Sample
Type
Analytical
Method
Quantitation
' Level •
Sample
Result
Units of
Measurement
Number of
samples
Ammonia (as N)
Composite
SM4500NH3G
0.01
0.62
mg/L
1
Dissolved oxygen
Composite
SM4500-0 G
0.01
9.1
mg/L
1
1
Nitrate/Nitrite
Composite
SM4500NO3F
0.01
8.5
mg/L
Total Kjeldahl nitrogen
Composite
SM4500NorgC
0.095
2.12
mg/L
1
Total Phosphorus
Composite
SM4500PF
0.01
0.31
mg/L
1
Total dissolved solids
Composite
SM 2540C
10
388
mg/L
1
Hardness
Composite
2340 C
2
78
mg/L
1
Chlorine (total residual, TRC)
Grab
4500C1 D
7
35
ug/L
1
Oil and grease
Grab
SM 5520 B
5
<5
mg/L
1
•
Metals (total recoverable), cyanide and total phenols
Antimony
Composite
EPA 200,7
0.025
<0.025
mg/L
1
Arsenic
Composite
SM it 3113 B
10
<10
ug/L
1
Beryllium
Composite
EPA 200.7
0.005
<0.005
mg/L
1
Cadmium
Composite
SM # 3113 B
1.0
<1.0
ug/L
1
Chromium
Composite
SM # 3113 B
5
<5
ug/L
1
Copper
Composite
SM # 3113 B
5
8
ug/L
1
Lead
Composite
SM # 3113 8
2.5
<2.5
ug/L
1
Mercury
Composite
EPA 1631
0.001
0.01
ug/L
1
Nickel
Composite
SM # 3113 B
10
<10
ug/L
1
Selenium
Composite
SM if 3113 B
10
<10
ug/L
1
Silver
Composite
SM # 3113 B
5
<5
ug/L
1
Thallium
Composite
EPA 200.7
0.020
<0.020
mg/L
1
Zinc
Composite
SM # 3113 B
0.025
0.033
mg/L
1
Cyanide
Grab
EPA 335.2
0.01
<0.01
mg/L
1
Total phenolic compounds
Grab
EPA 604
25 _
<25
ug/L
1
Volatile organic compounds
Acrolein
Grab
EPA 624
1000
<1000
ug/L
1
Acrylonitrile
Grab
EPA 624
200
<200
ug/L
1
Benzene
Grab
EPA 624
20.0
<20.0
ug/L
1
Bromoform
Grab
EPA 624
20.0
<20.0
ug/L
1
Carbon tetrachloride
Grab
EPA 624
20.0
<20.0
ug/L
1
Chlorobenzene
Grab
EPA 624
20.0
<20.0
ug/L
1
Chlorodibromomethane
Grab
EPA 624
20.0
<20.0
ug/L
1
Chloroethane
Grab
EPA 624
100.0
<100.0
ug/L
1
2-chloroethylvinyl ether
Grab
EPA 624
100.0
<100.0
ug/L
1
Chloroform
Grab
EPA 624
20.0
<20.0
ug/L
I
Dichlorobromomethane
Grab
EPA 624
20.0
<20.0
ug/L
1
1,1-dichloroethane
Grab
EPA 624
20.0
<20.0
ug/L
1
1,2-dichloroethane
Grab
EPA 624
20.0
<20.0
ug/L
1
Trans-1,2-dichloroethylene
Grab
EPA 624
20.0
<20.0
ug/L
1
Form - DMR- PPA-1
Page 1

Annual Monitoring and Pollutant Scan
Permit No.: NC0024228
Outfall: 001
Month : April
Year: 2011
Parameter
S.axnple
Type
-
Volatile organic compounds (Coat.)
1,1-dichloroethylene
Grab
EPA 624
20.0
<20.0
ug/L
1
1,2-dichloropropane
Grab
EPA 624
20.0
<20.0
ug/L
1
1,3-dichloropropylene
Grab
EPA 624
20.0
<20.0
ug/L
1
Ethylbenzene
Grab
EPA 624
20.0
<20.0
ug/L
1
Methyl bromide
Grab
EPA 624
100.0
<100.0
ug/L
1
Methyl chloride
Grab
EPA 624
100.0
<100.0
ug/L
1
Methylene chloride
Grab
EPA 624
20.0
<20.0
ug/L
1
1,1,2,2-tetrach]oroethane
Grab
EPA 624
20.0
<20.0
ug/L
1
Tetrachloroethylene
Grab
EPA 624
20.0
<20.0
ug/L
1
Toluene
Grab
EPA 624
20.0
<20.0
ug/L
1
1,1,1-trichloroethane
Grab
EPA 624
20.0
<20.0
ug/L
1
1,1,2-trichloroethane
Grab
EPA 624
20.0
<20.0
ug/L
1
Trichloroethylene
Grab
EPA 624
20.0
<20.0
ug/L
1
Vinyl chloride
Grab
EPA 624
100.0
<100.0
ug/L
1
Acid -extractable compounds
P-chloro-m-creso
Grab
EPA 625
10
<10
ug/L
1
2-chlorophenol
Grab
EPA 625
10
<10
ug/L
1
2,4-dichlorophenol
Grab
EPA 625
10
<10
ug/L
1
2,4-dimethylphenol
Grab
EPA 625
10
<10
ug/L
1
4,6-dinitro-o-cresol
Grab
EPA 625
50
<50
ug/L
1
2,4-dinitrophenol
Grab
EPA 625
50
<50
ug/L
1
2-nitrophenol
Grab
EPA 625
10
<10
ug/L
1
4-nitrophenol
Grab
EPA 625
10
<10
ug/L
1
Pentachlorophenol
Grab
EPA 625
50
<50
ug/L
1
Phenol
Grab
EPA 625
10
<10
ug/L
1
2,4,6-trichlorophenol
Grab
EPA 625
10
<10
ug/L
1
Base -neutral compounds
Acenaphthene
Grab
EPA 625
10
<10
ug/L
1
Acenaphthylene
Grab
EPA 625
10
<10
ug/L
1
Anthracene
Grab
EPA 625
10
<10
ug/L
1
Benzidine
Grab
EPA 625
50
<50
ug/L
1
Benzo(a)anthracene
Grab
EPA 625
10
<10
ug/L
1
Benzo(a)pyrene
Grab
EPA 625
10
<10
ug f L
1
3,4 benzofluoranthene
Grab
EPA 625
10
<10
ug/L
1
Benzo(ghi)perylene
Grab
EPA 625
10
<10
ug/L
1
Benzo(k)fluoranthene
Grab
EPA 625
10
<10
ug/L
1
Bis (2-chloroethoxy) methane
Grab
EPA 625
10
<10
ug/L
1
Bis (2-chloroethyl) ether
Grab
EPA 625
10
<10
ug/L
1
Bis (2-chloroisopropyl) ether
Grab
EPA 625
10
<10
ug/L
1
Bis (2-ethylhexyl) phthalate
Grab
EPA 625
10
<10
ug/L
1
4-bromophenyl phenyl ether
Grab
EPA 625
10
<10
ug/L
1
Butyl benzyl phthalate
Grab
EPA 625
10
<10
ug/L
1
2-chloronaphthalene
Grab
EPA 625
10
<10
ug/L
1
Form - DMR- PPA-1
Page 2

Permit No.: NC0024228_
Outfall: 001
Annual Monitoring and Pollutant Scan
Month : April
Year: 2011
4-chlorophenyl phenyl ether
Grab
EPA 625
10
<10
ug/L
1
• • .Sample ••
Parameter ' • :: Type- •
Anal$!t4oal
:: Metlio l.': �
:Qiiantifatioii
: -; -• Levol•
. $ample: '
• leant: •. •
•. . 'Uniteiof:::,•.
• iii u eiii . i ..
Nuaii_ser of
: samp
. Base -neutral. compounds-(cont4 • . • : ; • .- • ::. .; ...
Chrysene
Grab
EPA 625
10
<10
ug/L
1
Di-n-butyl phthalate
Grab
EPA 625
10
<10
ug/L
1
Di-n-octyl phthalate
Grab
EPA 625
10
<10
ug/L
1
Dibenzo(a,h)anthracene
Grab
EPA 625
10
<10
ug/L
1
1,2-dichlorobenzene
Grab
EPA 625
10
<10
ug/L
1
1,3-dichlorobenzene
Grab
EPA 625
10
<10
ug/L
1
1,4-dichlorobenzene
Grab
EPA 625
10
<10
ug/L
1
3,3-dichlorobenzidine
Grab
EPA 625
50
<50
ug/L
1
Diethyl phthalate
Grab
EPA 625
10
<10
ug/L
1
Dimethyl phthalate
Grab
EPA 625
10
<10
ug/L
1
J
2,4-dinitrotoluene
Grab
EPA 625
10
<10
ug/L
1
2,6-dinitrotoluene
Grab
EPA 625
10
<10
ug/L
1
1,2-diphenylhydrazine
Grab
EPA 625
10
<10
ug/L
1
Fluoranthene
Grab
EPA 625
10
<10
ug/L
1
Fluorene
Grab
EPA 625
10
<10
ug/L
1
Hexachlorobenzene
Grab
EPA 625
10
<10
ug/L
1
Hexachlorobutadiene
Grab
EPA 625
50
<50
ug/L
1
Hexachlorocyclo-pentadiene
w
Grab
EPA 625
10
<10
ug/L
1
Hexachloroethane
Grab
EPA 625
10
<10
ug/L
1
Indeno(1,2,3-cd)pyrene
Grab
EPA 625
10
<10
ug/L
1
Isophorone
Grab
,
EPA 625
10
<10
ug/L
1
Naphthalene
Grab
EPA 625
10
<10
ug/L
1
Nitrobenzene
Grab
EPA 625
10
<10
ug/L
1
N-nitrosodi-n-propylamine
Grab
EPA 625
10
<10
ug/L
1
N-nitrosodimethylamine
Grab
EPA 625
10
<10
ug/L
1
N-nitrosodiphenylamine
Grab
EPA 625
10
<10
ug/L
1
Phenanthrene
Grab
EPA 625
10
<10
ug/L
1
Pyrene
Grab
EPA 625
10
<10
ug/L
1
1,2,4,-trichlorobenzene
Grab
EPA 625
10
<10
ug/L
1
I certify under penalty of law that this document and all attachments were prepared under my direction
and supervision in accordance with a system to design to assure that qualified personnel properly
gather and evaluate the information submitted. Based on my inquiry of the person or persons that
manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am
aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing vio at ans.
razier
Lab & Pretreatment Manager
Autl died Repres ve_name
Signature
5-- /- //
Date
Form - DMR- PPA-1
Page 3

HAIDI AND S4SWER
Environmental Engineers & Scientists
November 2, 2010
Shari Bryant
Piedmont Region Coordinator
Wildlife Resources Commission, Habitat Conservation Program
1721 Mail Service Center
Raleigh, NC 27699-1721
Hazen and Sawyer, P.C.
4011 WestChase Blvd.
Raleigh, NC 27607
919-833-7152
RE: Response to DENR Internal Review — Additional Comments dated October 20, 2010
Westside Wastewater Treatment Plant Expansion
Project No. 1541
City of High Point Public Services Department
Dear Ms. Bryant,
The following are our responses to the North Carolina Wildlife Resources Commission (WRC) additional
review comments:
1. Following the intensive monitoring survey in the summer after the stream restoration project is
completed, the water quality model should be calibrated and the 10 mgd modeling scenario rerun to
validate previous predictions. If the 10 mgd modeling scenario shows that sufficient assimilative
capacity does not exist in Rich Fork Creek, then the 8.2 mgd scenario also should be run to validate
that these is sufficient assimilative capacity at this discharge level. In addition, the model should be
used to predict dissolved oxygen levels farther downstream (e.g. 5 and 10 miles).
The water quality model will be run to validate assimilate capacity at 8.2 mgd if the 10 mgd modeling
scenario shows insufficient assimilative capacity. The model available includes calibration for a total
distance below the outfall of 12.6 miles, as stated in our October 12, 2010 correspondence.
2. Develop a contingency plan that includes measures to ensure the dissolved oxygen standard is met
downstream of the discharge. The plan should be implemented immediately should any monitoring or
sampling indicated the dissolved oxygen standard is not being met following plant expansion and
restoration of the three instream sand mining sites and removal of excessive tree fall. The applicant
indicates the WWTP will be constructed with side stream oxygen dissolved
oxygen in the permit limits are met. While this would allow the discharge to meet permit limits for
dissolved oxygen, it does not ensure that the downstream dissolved oxygen standard is maintained.
The water quality model indicates that the stream standard for dissolved oxygen will be met with the
implementation of the stream restoration project. However, the design will include efforts to maximize
New York, NY • Armonk, NY • Woodbury, NY • Detroit, MI • Raleigh, NC • Charlotte, NC • Atlanta, GA • Fairfax, VA • Hollywood, FL • Boca Raton, FL • Fort Pierce, FL • Sarasota, FL • Miami, FL • Philadelphia, PA

HAZENAND S1VYYFR
Ms. Shari Bryant
Page 2
dissolved oxygen in the effluent, if necessary, to ensure stream dissolved oxygen standards are not
violated due to the discharge wastewater from the Westside Facility.
3. An annual instream monitoring program should be developed to measure dissolved in Rich Fork
Creek during the summer months (e.g., May 1 to October 31) above the discharge, immediately
downstream of the discharge; as wells as above, within, and below each of the stream restoration
sites, within areas where excessive tree fall has been removed, and at 5 miles and 10 miles
downstream. The applicant states that there are three monitoring sites along Rich Fork Creek as part
of the Yadkin Pee -Dee River Basin Memorandum of Agreement. Monitoring parameters include
dissolved oxygen, nutrients, turbidity, and metals. One site is located upstream and two sites are
located downstream of the WWTP. We continue to believe a more extensive monitoring program
should be developed. However, we will not object to only the three monitoring sites provided that if
dissolved oxygen does not meet the standard at either one of the downstream monitoring sites that a
more extensive monitoring program and contingency plan (as described above) are implemented.
The City concurs.
4. Twice each year evaluate the restored stream sections and tree fall removal areas. Any issues (e.g.,
collapsed stream banks, lack of riparian vegetation, pooling water, etc.) should be addressed
immediately and these areas should be returned to their restored conditions.
The City agrees to monitor the restored stream sections and tree fall removal areas twice per year.
The City will repair substantive problems (i.e., that may impact water quality and channel stability)
with the restored segments, and will take appropriate actions to address additional tree fall that may
impact stream hydraulics negatively with regard to maintaining sufficient dissolved oxygen levels in
the stream.
We hope that this correspondence resolves any remaining issues to allow the Final EA to be circulated
through the Department of Administration Clearinghouse.
Sincerely,
HAZEN AND SAWYER,.-R.C.
Mary E. Sadler, PE
Associate
Copies:
Chris Thompson, City of High Point
Terry Houk, City of High Point
Alan Stone, Hazen and Sawyer
Pamela Behm, Division Water Quality
Todd Johnson, Hazen and Sawyer
Trevor Clements, Tetra Tech
Hannah Stallings, Division of Water Quality
Steve Tedder, Division of Water Quality

Annual Monitoring and Pollutant Scan
Permit No.: NC0024228
O u tfal l: 001
Facility Name: City of High Point - Westside POTW ORC: Mike Swan
Date of sampling: Phone: 336 - 822 - 4782
Analytical Laboratory: Water Quality Laboratory - City of High Point
Meritech - Reidsville
Month : Janua
Year: 2010
Parameter
Sample
Type
Analytical
Method
Quantitation
Level
Sample
Result
Units of
Measurement
Number of
samples
Ammonia (as N)
Composite
SM 4500-N113
0.01
1.07
mg/L
1
Dissolved oxygen
Composite
SM 4500-0 G
0.01
9.6
mg/L
1
Nitrate/Nitrite
Composite
SNI 4500-NO3- F
0.01
9.58
mg/L
1
Total Kjeldahl nitrogen
Composite
SM4500-Norg
0.095
2.653
mg/L
1
Total Phosphorus
Composite
SM 4500-P
0.01
1.13
mg/L
1
Total dissolved solids
Composite
EPA 160.1
10
293
mg/L
1
Hardness
Composite
SM 2340-C
2
90
mg/L
1
Chlorine (total residual, TRC)
Grab
4500CI D
<12
<12
ug/L
1
Oil and grease
Grab
SM 5520B
5
<5
mg/L
1
Metals (total recoverable), cyanide and total phenols
Antimony
Composite
EPA 200.7
0.025
<0.025
mg/L
1
Arsenic
Composite
SM # 3113 B
10
<10
ug/L
1
Beryllium
Composite
EPA 200,7
0.005
<0.005
mg/L
1
Cadmium
Composite
SM # 3113 B
1,0
<1.0
ug/L
1
Chromium
Composite
SM # 3113 B
5
<5
ug/L
1
Copper
Composite
SM # 3113 B
5
33
ug/L
1
Lead
Composite
SM # 3113 B
5,0
<5.0
ug/L
1
Mercury
Composite
EPA 1631
0.001
0.004
ug/L
1
Nickel
Composite
SM # 3113 B
10
<10
ug/L
1
Selenium
Composite
SM II 3113 B
10
<10
ug/L
1
Silver
Composite
SM # 3113 B
5
<5
ug/L
1
Thallium
Composite
EPA 200.7
0.020
<0.020
mg/L
1
Zinc
Composite
SM # 3113 B
0.025
40
mg/L
1
Cyanide
Grab
EPA 335.2
0.01
<0.01
mg/L
1
Total phenolic compounds
Grab
EPA 604
1,0
<1.0
ug/L
1
Volatile organic compounds
Acrolein
Grab
624
50.0
<50.0
ug/L
1
Acrylonitrile
Grab
624
10.0
<10.0
ug/L
1
Benzene
Grab
624
1.00
<1.00
ug/L
1
Bromoforrn
Grab
624
1.00
<1.00
ug/L
1
Carbon tetrachloride
Grab
624
1.00
<1,00
ug/L
1
Chlorobenzene
Grab
624
1.00
<1.00
ug/L
1
Chlorodibromomethane
Grab
624
1.00
<1.00
ug/L
1
Chloroethane
Grab
624
5.00
<5.00
ug/L
1
2-chloroethylvinyl ether
Grab
624
5.00
<5.00
ug/L
1
Chloroform
Grab
624
1.00
<1.00
ug/L
1
Dichlorobromomethane
Grab
624
1.00
<1.00
ug/L
1
1,1-dichloroethane
Grab
624
1.00
<1.00
ug/L
1
1,2-dichloroethane
Grab
624
1.00
<1.00
ug/L
1
Trans- 1 ,2-dichloroethylene
Grab
624
1.00
<1.00
ug/L
1
Form - DMR- PPA-1
Page 1

Annual Monitoring and Pollutant Scan
Permit No.: NC0024228
Outfall: 001
Month : Jan uar,'
Year: 2010
Parameter . .
Sample•
Type
• .
Volatile organic compounds (Cont.)
1,1-dichloroethylene
Grab
624
1.00
<1.00
ug/L
1
1,2-dichloropropane
Grab
624
1.00
<1.00
ug/L
1
1,3-dichloropropylene
Grab
624
1.00
<1.00
ug/L
1
Ethylbenzene
Grab
624
1.00
<1.00
ug/L
1
Methyl bromide
Grab
624
5.00
<5.00
ug/L
1
Methyl chloride
Grab
624
5.00
<5.00
ug/L
1
Methylene chloride
Grab
624
1.00
<1.00
ug/L
1
1,1,2,2-tetrachloroethane
Grab
624
1.00
<1.00
ug/L
1
Tetrachloroethylene
Grab
624
- 1.00
<1.00
ug/L
1
Toluene
Grab
624
. 1.00
<1.00
ug/L
1
1,1,1-trichloroethane
Grab
624
1.00
<1.00
ug/L
1
1,1,2-trichloroethane
Grab
624
1.00
<1.00
ug/L
1
Trichloroethylene
Grab
624
5.00
<5.00
ug/L
1
Vinyl chloride
Grab
624
5.00
<5.00
ug/L
1
Acid -extractable compounds
P-chloro-m-creso
Grab
625
10
<10
ug/L
1
2-chlorophenol
Grab
625
10
<10
ug/L
1
2,4-dichlorophenol
Grab
625
10
<10
ug/L
1
2,4-dirnethylphenol
Grab
625
10
<10
ug/L
1
4,6-dinitro-o-cresol
Grab
625
50
<50
ug/L
1
2,4-dinitrophenol
Grab
625
50
<50
ug/L
1
2-nitrophenol
Grab
625
10
<10
ug/L
1
4-nitrophenol
Grab
625
50
<50
ug/L
1
Pentachlorophenol
Grab
625
50
<S0
ug/L
1
Phenol
Grab
625
10
<10
ug/L
1
2,4,6-trichlorophenol
Grab
625
10
<10
ug/L
1
Base -neutral compounds
Acenaphthene
Grab
1 625
10
' <10
ug/L
1
Acenaphthylene
Grab
625
10
<10
ug/L
1
Anthracene
Grab
625
10
<10
ug/L
1
Benzidine
Grab
625
_
50
<50
ug/L
1
Benzo(a)anthracene
Grab
625
_
10
<10
ug/L
1
Benzo(a)pyrene
v
Grab'
625
10
<10
ug/L
1
3,4 benzofluoranthene
Grab
625
10
<10
ug/L
1
Benzo(ghi)perylene
Grab
625
10
<10
ug/L
1
Benzo(k)fluoranthene
Grab
625
10
<10
ug/ L
1
Bis (2-chloroethoxy) methane
Grab
625
10
<10
ug/L
1
Bis (2-chloroethyl) ether
Grab
625
10
<10
ug/L
1
Bis (2-chloroisopropyl) ether
Grab
625
10
<10
ug/L
1
Bis (2-ethylhexyl) phthalate
Grab
625
10
<10
ug/L
1
4-bromophenyl phenyl ether
Grab
' 625
10
<10
ug/L
1
Butyl benzyl phthalate
Grab
625
10
<10
ug/L
1
2-chloronaphthalene
Grab
625
10
<10
ug/L
1
Form - DMR- PPA-1
Page 2

Annual Monitoring and Pollutant Scan
Permit No.: NC0024228
Outfall: 001
Month : Januai'
Year: 2010
4-chlorophenyl phenyl ether
Grab
625
10
<10
ug/L
1
Parameter.
Sample •
Type
Analytical
Method .
Quantitation
Level'
Sample
Result
• Units of •
Measurement
Number of
samples .
Bade-aoutial coinpounds (Cont.)•
Chrysene
Grab
625
10
<10
ug/L
1
Di-n-butyl phthalate
Grab
625
10
<10
ug/L
r 1
Di-n-octyl phthalate
Grab
625
10
<10
ug/L
1
Dibenzo(a,h)anthracene
Grab
625
10
<10
ug/L
1
1,2-dichlorobenzene
Grab
625
10
<10
ug/L
1
1,3-dichlorobenzene
Grab
625
10
<10
ug/L
1
1,4-dichlorobenzene
Grab
625
10
<10
ug/L
1
3,3-dichlorobenzidine
Grab
625
50
<50
ug/L
1
Diethyl phthalate
Grab
625
10
<10
ug/L
1
Dimethyl phthalate
Grab
625
10
<10
ug/L
1
2,4-dinitrotoluene
Grab
625
10
<10
ug/L
1
2,6-dinitrotoluene
Grab
625 -
10
<10
ug/L
1
1,2-diphenylhydrazine
Grab
625
10
<10
ug/ L
1
Fluoranthene
Grab
625
10
<10
ug/L
1
Fluorene
Grab
625
10
<10
ug/L
1
Hexachlorobenzene
Grab
_625
10
<10
ug/L
1
Hexachlorobutadiene
Grab
625
10
<10
ug/L
1
Hexachlorocyclo-pentadiene
Grab
625
50
<50
ug/L
1
Hexachloroethane
Grab
625
10
<10
ug/L
1
[ndeno(1,2,3-cd)pyrene
Grab
625
10
<10
ug/L
1 a
lsophorone
Grab
625
10
<10
ug/L
1
Naphthalene
Grab
625
10
<10
ug/L
1
Nitrobenzene
Grab
625
10
<10
ug/L
1
N-nitrosodi-n-propylamine
Grab
625
10
<10
ug/L
1
N-nitrosodimethylamine
Grab
625
10
<10
ug/ L
1
N-nitrosodiphenylamine
Grab
625
10
<10
ug/L
1
Phenanthrene
Grab
625
10
<10
ug/L
1 .
Pyrene
Grab
625
10
<10
ug/L
1
1,2,4,-trichlorobenzene
Grab
625
10
<10
ug/L
1
I certify under penalty of law that this document and all attachments were prepared under my direction
and supervision in accordance with a system to design to assure that qualified personnel properly
gather and evaluate the information submitted. Based on my inquiry of the person or persons that
manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate and complete. l am
aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations.
Authorized Representative name
Signature
Date
Form - DMR- PPA-1
Page 3