NC0024228_Report_20050720

NPDES DOCUHENT SCANNING COVER :MEET
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)
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
July 20, 2005
This document is printed on reuse paper - igxzore any
content on the reYerse side

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agencies of water quality concerns regarding these waters and work with them to conduct further
monitoring and to locate sources of water quality protection funding. In addition, Davidson
County as well as High Point, Trinity and Thomasville are required to obtain an NPDES permit
for municipal stormwater systems under the Phase II stormwater rules. Refer to page 37 of
Section A, Chapter 2 for details.
7.3 Status and Recommendations for Newly Impaired Waters
Rich Fork, North Hamby Creek, Swearing Creek, Lake Thom-A-Lex and a portion of Abbotts
Creek are Impaired based on recent DWQ monitoring (1998-2001). This section outlines the
potential causes and sources of impairment and provides recommendations for improving water
quality.
7.3.1 Rich Fork (20.7 miles from source to Abbotts Creek)
1998 Recommendations
Rich Fork was not rated in 1998, but problems associated with low dissolved oxygen were
discussed in the basin plan. The plan stated that predictions from the model used to determine
NPDES permit limits overestimated the ability of the stream to handle oxygen -consuming
wastes. The plan recommended that no additional loading of oxygen -consuming wastes be
permitted into Rich Fork.
Status of Progress
Biological surveys were conducted at two locations along Rich Fork in 2001 and water chemistry
measurements were collected at four sites over the five-year assessment period. The biological
community in Rich Fork is currently Impaired. Although the riparian vegetation was good at .
both biological monitoring locations, instream habitat was severely degraded. The stream
bottom was almost completely filled with sediment and indicators of organic enrichment and
toxicity were present.
Water chemistry samples revealed significant problems with low dissolved oxygen
concentrations. Turbidity is only slightly elevated, but nutrient concentrations are high. In
addition, the geometric means of fecal coliform samples collected om one sta ion etween 1996
and 2001 and two stations between 1998 and 2001 in Rich Fork (254, 330 and 236
colonies/100m1) indicate that the stream may not be suitable for primary recreation. In addition,
fecal coliform concentrations were greater than 400 colonies/100m1 in more than 20 percent of
sam_ 1� es from each site. Rich Fork is not currently cFssified for primary recreation (Class B).
However, the stream was historically placed on the 303(d) list for fecal coliform and a TMDL is
currently being developed by DWQ.
Over the most recent review period (2000-2001), High Point-Westside WWTP was in significant
noncompliance for BOD and fecal coliform. Currently, the NPDES permit for the High Point-
Westside WWTP contains a 2.0 mg/1 discharge limit for total phosphorus. The permit also
outlines mass -based summer and winter discharge limits for total phosphorus which will be
required beginning in 2004 as part of a point source nutrient reduction strategy for High Rock
Lake. This strategy is outlined in Section A, Chapter 4, beginning on page 107.
Section B: Chapter 7 — Yadkin -Pee Dee River Subbasin 03-07-07 (1 QACl/1 6'00185

2002 Recommendations
DWQ will continue to monitor Rich Fork as strategies to reduce nutrient concentrations in High
Rock Lake are implemented (refer to the discussion beginning on page 107 of Section A for
details). DWQ will also continue to work with High Point-Westside WWTP to regain and
maintain compliance with its NPDES permit. If dissolved oxygen problems downstream do not
improve when the facility regains compliance, more modeling will likely be needed in order to
further reduce sources of oxygen -consuming wastes. DWQ is currently velo ing a TMDL for
fesaLcoliformin the Rich Fork watershed and will work with local agencies to implement it over _rt4D
the next five-year basinwide planning cycle.
Although problems with point sources have been identified in Rich Fork, there are habitat
degradation issues as well. Development in the headwaters of Rich Fork west of High Point
continues to increase, and control of stormwater from construction sites and these new developed
areas is imperative. Davidson County, Randolph County and the City of High Point are required
to obtain NPDES permits for municipal stormwater systems under the Phase II stormwater rules.
Refer to page 37 of Section A, Chapter 2 for details.
7.3.2 North Hamby Creek (5.8 miles from source to Hamby Creek)
Current Status
North Hamby Creek is the largest tributary to Hamby Creek in the Rich Fork watershed and is
almost completely developed. Benthic macroinvertebrates received a Poor bioclassification in
2001 and the stream is rated Impaired. Data from 1987 and 1985 also indicated Poor conditions.
Despite the developed watershed, instream habitat was available; however, there was little
riparian vegetation. The water had a reddish tinge. There are no permitted point source
discharges in the watershed.
2002 Recommendations
Biologists report that flow and habitat are not likely to be limiting the benthic macroinvertebrate
community of North Hamby Creek. Therefore, further investigation into the causes and sources
of these water quality impacts is needed before recommendations to improve water quality can
be made. Thomasville is required to obtain an NPDES permit for municipal stormwater systems
under the Phase II stormwater rules. Refer to page 37 of Section A, Chapter 2 for details.
7.3.3 Swearing Creek (14.3 miles from source to High Rock Lake)
Current Status
The Swearing Creek watershed is primarily in agricultural land uses, but there is some
development near Lexington. The stream has received Good -Fair or Fair bioclassifications over
six collections at five locations since the 1980s. In 1996, the stream received a Good -Fair score.
However, in 2001 the bioclassification declined to Fair. A decline in habitat over the five-year
period was also observed. Because of the historical fluctuation in bioclassification, the stream
was resampled in 2002. The benthic community again received a Fair bioclassification.
Swearing Creek is currently rated Impaired. Severe habitat degradation was noted including
sedimentation and bank erosion. Dissolved oxygen was slightly depressed, and turbidity was
slightly elevated in water chemistry samples. There are no permitted point source discharges in
the watershed.
Section B: Chapter 7 — Yadkin -Pee Dee River Subbasin 03-07-07 186

FW: High Point Westside
0
rn o nb
r ` IW
• Subject: FW: High Point Westside
From: "Mike Slusher" <[e-mail]>
Date: Mon, 18 Jul 2005 13:36:40 -0400
To: "'teresa rodriguez"' <[e-mail]>
CC: "Terry Houk" <[e-mail]>, "'PERRY KAIRIS"'
<[e-mail]>, "Bart Hepler" <[e-mail]>, "'Stone, Alan L.'" ,1
<[e-mail]>
Teresa, ��u� �� "
k° The intent of our Study is to determine the current condition of the stream for comparison to earlier work with the
,goal of proceeding with design of the WWTP expansion / upgrade this fall. As discussed in our meeting, we feel
that the upstream overflows which may have contributed to the low DOs have been corrected. Also, part of the 5
year period of analysis included two drought years (2001 & 2002). We are hoping that the inclusion of this
summer's data will drop the low DO percentage to below 10 percent and the impaired status of the stream be
removed. We can then proceed with design of the expansion of Westside plant after receiving speculative limits.
0„g► We need to know if this is your understanding of our intent.
Historically the periods of lower DO has been during the summer months, which is why we concentrated the
sampling for this period. The City has funded and hired temporary interns through September 30, and would like
to sample 3 times per week for this period. They could possibly continue on a weekly basis until June 2006 if it —
will be of benefit.
We did not include pH in the initial scope, since DO was the primary concern, but will include pH if you request.
The recording forms will include date and time of the samples.
We will submit a QAPP for review as soon as possible.
/The 109 site (road construction) is very close to WWTP, and accessing a point in between would be difficult. We
can delete this site, as previous results indicate the sag point is farther downstream.
Mike Slusher
Davis -Martin -Powell
[phone] x349
Fax [phone]
www.dmp-inc.com
Original Message
From: teresa rodriguez[mailto:[e-mail]]
Sent: Monday, July 18, 2005 9:22 AM
To: Mike Slusher
Subject: High Point Westside
- Mike, our modeling group looked at the proposal and offered the following comments:
- To answer questions regarding the status of the stream, versus the impact of the
WWTP, less frequent monitoring is acceptable. We assume that the written purpose of
the study, to evaluate conditions of the stream and determine if DO standards are
still violated, is the goal.
- High Point may consider submitting this data to DWQ for use support purposes during
the basinwide planning cycle. If so, then a Quality Assurance Project Plan (QAPP)
will be needed. The easiest guidance for developing a QAPP is the volunteer
monitors guidance.
http://www.epa.gov/owow/monitoring/volunteer/gappcovr.htm) The QAPP for this
project does not need to be any larger than this guidance document (in fact, it can
be smaller). This needs to be in place ASAP if monitoring began on July llth.
1 of 2 7/18/2005 1:46 PM

FW: High Point Westside
- The inclusion of temperature and pH are critical when interpreting DO data. High
Point has correctly included these in the study design.
Date and time of sample must also be recorded and stored with the data.
- No comments on the locations, although the site with construction is problematic.
It may be prudent to walk further upstream of the construction, if possible, or
remove this site completely.
- The monitoring frequency is adequate. However, the length of the study (July -
Sept 05) is very short in terms of use support monitoring. As a result, this
dataset may be rejected when DWQ determines use support during the basinwide
planning process. Are they planning to repeat this study next summer? Why does
this not include winter monitoring? Use support for Rich Fork was performed using
DO data from year-round sampling. The current design of this study is biased
towards summer.
One potential suggestion, reduce monitoring frequency to weekly and extend the study
to next June.
If you have any questions please give me a call, Teresa
Teresa Rodriguez, P.E.
Division of Water Quality
NPDES Unit
919-733-5083
2 of 2 7/18/2005 1:46 PM

Re: [Fwd: High Point Westside WWTP]
Subject: Re: [Fwd: High Point Westside WWTP]
From: Michelle Woolfolk <[e-mail]>
Date: Fri, 15 Ju12005 11:51:28 -0400
To: teresa rodriguez <[e-mail]>
CC: Dave Toms <[e-mail]>
I'm a bit confused on the purpose of the study since the written purpose and the monitoring design seem
to be at odds. This design seems closer to the monitoring required in the NPDES permit (3x/week
instream monitoring), which is designed specifically to determine the impact of the WWTP. To answer
questions regarding the status of the stream, versus the impact of the WWTP, less frequent monitoring is
acceptable. My comments assume that the written purpose, to evaluate conditions of the stream and -
determine if DO standards are still violated, is the goal:
My comments:
• I assume that High Point may consider submitting this data to DWQ for use support purposes
during the basinwide planning cycle. If so, then a Quality Assurance Project Plan (QAPP) will be
needed. The easiest guidance for developing a QAPP is the volunteer monitors guidance. (
http://www.epa.gov/owow/monitoring/volunteer/qappcovr.htm) The QAPP for this project does
not need to be any larger than this guidance document (in fact, it can be smaller). This needs to be
in place ASAP if monitoring began on July 1 lth.
• The inclusion of temperature and pH are critical when interpreting DO data. High Point has
correctly included these in the study design. Date and time of sample must also be recorded and
stored with the data.
• No comments on the locations, although the site with construction is problematic. It may be
prudent to walk further upstream of the construction, if possible, or remove this site completely.
• The monitoring frequency is adequate. However, the length of the study (July - Sept 05) is very
short in terms of use support monitoring. As a result, this dataset may be rejected when DWQ
determines use support during the basinwide planning process. Are they planning to repeat this
study next summer? Why does this not include winter monitoring? Use support for Rich Fork
was performed using DO data from year-round sampling. The current design of this study is
biased towards summer. One potential suggestion, reduce monitoring frequency to weekly and
extend the study to next June.
Those are my quick comments.
Thanks
Michelle
teresa rodriguez wrote:
Michelle, can you take a look at High Point's proposal and let me know if you have any comments.
thanks
Teresa
Original Message
Subject:High Point Westside WWTP
Date:Thu, 14 Jul 2005 13:38:37 -0400
From:Mike Slusher <MSlusherRdmp-inc.com>
1 of 2 7/15/2005 1:34 PM

Re: [Fwd: High Point Westside WWTP]
Organization:Davis-Martin-Powell & Associates
To:<teresa.rodriguezRncmail.net>
CC:Terry Houk <terry.houk ahighpointnc.gov>
Teresa,
Attached is a proposed DO sampling plan and site location map for Rich Fork Creek, as discussed at our May
meeting. Please look this over and let us if know if it is acceptable, or if you have any comments and we will
proceed with a formal submittal if needed.
If you have any questions please feel free to contact me.
Mike Slusher
Davis -Martin -Powell
[phone] x349
Fax [phone]
www.dmp-inc.com
Teresa Rodriguez, P.E.
Division of Water Quality
NPDES Unit
919-733-5083
Michelle Woolfolk <[e-mail]> 7
Modeling & TMDL Unit
NC Division of Water Quality •
2 of 2 7/15/2005 1:34 PM

Rich Fork Creek
Dissolved Oxygen Monitoring Plan
The City of High Point (CHP) proposes to conduct additional monitoring of the DO levels in Rich Fork
Creek to determine if conditions in the drainage basin have improved since the stream was listed as
"impaired". This listing has been based on in -stream sampling conducted by CHP and the Yadkin
River Coalition.
The monitoring period is proposed to begin July 11, 2005 and end September 30, 2005
❑ Each site will be monitored at least 3 times per week
o Sites will be monitored one time each day
o Sampling shall adhere to DWQ Standard Operating Procedure Manuals.
❑ CHP will develop a procedure for calibration and recording of data, including date, time,
temperature, meter, and DO reading
o Temperature Methods: EPA 170.1, SM 2550-B, USGS 1975
❑ DO Methods: EPA 360.1, EPA 360.2, SM 4500-0-C, SM 4500-0-G
o Other approved methods may be used as long as similar detection limits can be achieved
❑ Results reported to the nearest 0.1 mg/L (deg Celsius)
o The DO meter(s) used will be one of the following:
o HACH HQ10 (LDO probe)
o Oakton 300
o YSI50B
❑ Monitoring sites shall be as follows, and as shown on the attached map
Site ID
Description
Notes
Q5750000
Lexington Avenue Bridge, SR 1755
Coalition Site
CHP-1
Off pier at WWTP
Original Upstream Site
CHP-2
At WWTP effluent pipe
CHP-3
NC Highway 109, downstream of bridge
Note: ongoing highway 0
construction may impact
suitability of this site
Q5780000
Midway School Road bridge, SIB 1800 -
State Ambient site i- f
CHP-4
Ball Road bridge, SR 1790
/ Q5785000
. Kanoy Road bridge, SR 1787
Coalition Site
CHP-5
Evans Road bridge, SR 1797> —
DOt'`�''`"��'� "�� "
p,..ixtt. fi d, -sal - Cid 2a, lox a )
Q5790000
Old Highway 29 bridge, SR 2123
a ad
Coalition Site
C� monc:7
.s4-rur1

DAVIS-MARTIN-POWELL & ASSOCIATES
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Use Support Ratings for Monitored Waters in the Upper Yadkin -Pee Dee River Basin (2003)
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1 of 1 5/18/2005 5:19 PM

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Use Support Ratings for Monitored Waters in the Upper Yadkin -Pee Dee River Basin (2003)
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County Boundary
Municipality
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1 of 1
5/18/2005 8:08 AM

Figure J3-8 Yadkin -Pee Dee River Subbasin 03-07-07
•
FORSYTH Winston-
Salem
Lexington
AVA
NCDENR
Planning Branch
Basinwide Planning Pro&am-thilt7
— -
March 21, 2003
5
Kernersville
'op
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//
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4 Benthic Station
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© Fish Tissue Station
NPDES Discharges
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Use Support Rating
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AtImpaired
Not Rated
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County Boundary
Primary Roads
Municipality

YADKIN RIVER SUBBASIN 07
Description
This subbasin contains primarily the Abbotts
Creek watershed (Figure 39). Abbotts Creek
starts just south of Kernersville, flows south
through Lexington, and empties into High Rock
Lake. Smaller streams in the watershed are Rich
and Hunts Forks and Swearing and Hamby
Creeks, which drain High Point, Thomasville, and
the west side of Lexington.
The subbasin is located primarily in Davidson
County and is dissected by the industrial and
commercial US 64 and 1-85 corridors. The largest
municipalities in the subbasin are the cities of
Lexington, Thomasville, and Highpoint. The
largest discharger is the City of High Point's
VWVTP with a permitted flow of 6.2 MGD into Rich
Fork. Other large municipal WVVTP dischargers
are Thomasville (4 MGD to Hamby Creek) and
Lexington (5.5 MGD to Abbotts Creek).
Land use is primarily forest and pasture (Table
18). However, this subbasin contains the greatest
percentage of urban areas than any other
subbasin in the entire basin.
Table 18. Landuse in Subbasin 07. Based upon
CGIA coverage 1993 -1995 (total area =
151,888 Ac).
Landuse Percent
Water
Cultivated crop
Pasture
Urban
Forest
0.8
3.0
31.8
7.8
56.5
Overview of Water Quality
Bioclassifications in 2001 based upon benthic
macroinvertebrates, ranged from Good at Brushy
Fork to Poor at North Hamby Creek. Although
flow was very low in 2001, all the streams were
turbid at the time of benthos sampling even though
there had been no recent rainfall event. The many
large WVVTP dischargers in this subbasin are
reflected in widespread water quality problems.
These problems are compounded by nonpoint
source pollutant and sediment inputs.
Table 19.
The fish communities sampled also reflected the
troubled water quality.
Ambient monitoring data indicated high nutrient
levels in Rich Fork and Hamby's Creek. Copper
exceeded its standard in 73 percent of the
samples collected form Hamby's Creek.
Lake Tom-A-Lex has been consistently eutrophic
since first monitored in 1981. Secchi depths were
typical of piedmont reservoirs (<1 m).
Waterbodies monitored in Subbasin 07 in the Yadkin River basin for basinwide
assessment, 1996 - 2001.
1
Map #' Waterbody County
B-1
B-2
B-3
B-4
B-5
B-6
B-7
Swearing Cr
Abbotts Cr
Brushy Fork
Abbotts Cr2
Rich Fork2
Hamby Cr2
Leonards Cr
F-1 Abbotts Cr
F-2 Rich Fork Cr
Davidson
Davidson
Davidson
Davidson
Davidson
Davidson
Davidson
Davidson
Davidson
L-1 Lake Thom-A-Lex Davidson
Location
NC 47
SR 1755
SR 1810
SR 1243
SR 2005
SR 20173
SR 18444
SR 1800
NC 109
1996 2001
Good -Fair
Good -Fair
Fair
Fair
Poor
Good -Fair
Good -Fair
Poor
Fair
Good -Fair
Good
Fair
Fair
Fair
Good -Fair
Good -Fair
Poor
Eutrophic
B = benthic macroinvertebrate monitoring sites; F = fish community monitoring sites; and L = lake assessment sites.
2Data are available prior to 1996, refer to Appendix 7.
3Sampled two bridges upstream at SR 2025 in 1996.
4Sampled at Leonard Creek Farm Road in 2001.
NCDENR, Division of Water Quality
Basinwide Assessment Report - Yadkin River Basin - June 2002
91

f3-5
Amk
8.6
;ieiIngton
I i'
a
r•- Ir
J"
b :ttr-{ rf
O Liai,cirr,elet rale C)mCr f > :i• •enl
* F:nt=r.•rrnntrr'•.-:e:zrurrlSSalrn:: • LLCU
rQ Lake Rl:bur 13O')1- •9r
• .it en:Mtee Icnno _tal s ▪ Fat
vttr6, Effluent Ur' itrt. 1r 1rjPOOP
Nrit RA crt
Figure 39. Sampling sites in Subbasin 07 in the Yadkin River basin.
River and Stream Assessment
Swearing Creek, NC 47
Swearing Creek at NC 47 was shallow and five
meters wide (wetted width) at the time of
sampling. This stream was estimated to be 12
meters wide in 1996 under higher flow conditions.
Since 1996, the amount of available instream
habitat has decreased (from abundant to limited),
riffle areas have disappeared, and bank erosion
has increased. The substrate is predominately
sand with infrequent riffle areas. The banks were
stable with plenty of vegetative cover in 1996, but
now have sparse vegetation with poor soil binding
capabilities. The riparian zone is still intact. The
habitat score in 1996 was 82, but only 49 in 2001.
Swearing Creek at NC 47 Davidson County
NCDENR, Division of Water Quality
Basinwide Assessment Report - Yadkin River Basin - June 2002
92

This site decreased from a Good -Fair rating in
1996 (16 EPT) to a Fair (13 EPT) in 2001. The
latest sample missed receiving a Good -Fair rating
by one EPT taxa. Stoneflies were not collected in
the 2001 survey.
Abbotts Creek, SR 1755
Abbotts Creek at SR 1755 is north of Highway
109. This upstream site is small (six meters wide).
The substrate contains some gravel and rubble,
but is mostly sand. Habitat here is generally good
(score of 74) and the site received a
bioclassification of Good -Fair (15 EPT) based on
the macroinvertebrate fauna. This site also was
Good -Fair (16 EPT) in 1996.
Abbotts Creek at SR 1755, Davidson County
Abbotts Creek, SR 1800
The upper Abbotts Creek watershed includes the
extreme southeastern corner of Forsyth and the
northeastern corner of Davidson counties.
Upstream view of Abbotts Creek at SR 1800,
Davidson County.
The fish community in 2001 was rated Good -Fair,
the same rating it received in 1996. In both years,
the bluehead chub was the dominant species
representing 42% of all the fish collected. The
only difference between sampling periods was in
2001 when two additional species of suckers were
collected.
Brushy Fork, SR 1810
Brushy Fork, located north of Lexington, is a
tributary to Tom-a-Lex Lake (water supply for the
cities of Lexington and Thomasville). This is a
small, shallow stream, about five meters width.
Instream habitat was very limited, the substrate
was nearly all sand, and riffle areas and pools
were absent. The riparian zone was large and
intact, filtering some of the effects of nonpoint
runoff.
Brushy Fork at SR 1810, Davidson County.
This site received a bioclassification of Good in
2001, based on a full scale benthos sample (this
was a borderline Good/ Good -Fair). This was up
from a Fair rating (based on an EPT sample) in
1996, although the habitat here was actually a bit
better in 1996 (there were still some riffle areas).
There was an increase in EPT taxa collected (from
13 to 20). Many intolerant taxa increased in
abundance: Hexagenia, Serratella deficiens,
Pteronarcys, and Oecetis persimillis. These
factors suggest that this stream fairs better in a
low flow year when nonpoint source impacts are
limited.
Abbotts Creek, SR 1243
Prior collections from this section of Abbots Creek
have been at 1-85, but for reasons concerning
safety, accessibility, and wadeable flow, the site
was moved about one mile upstream to the
NCDENR, Division of Water Quality
Basinwide Assessment Report - Yadkin River Basin - June 2002
93

gauging station at Center Street in Lexington (SR
1243) in 1996.
Abbotts Creek at this site was approximately 20
meters wide. It was shallow and turbid at the time
of sampling. Instream habitat is fairly abundant
and the substrate consists of gravel and sand.
Riffle areas are infrequent, but extensive, and the
banks are unstable. The riparian zone is wide but
breaks are common, allowing potential nonpoint
runoff into the stream.
Abbotts Creek at SR 1243, Davidson County.
This downstream stretch has consistently been
rated Fair since 1985. The City of Lexington
WWTP is permitted to discharge 5.5 MGD to
Abbotts Creek. Several taxa known to be tolerant
of toxic conditions have been found in abundance
here over the years: Cricotopus bicinctus,
Dicrotendipes neomodestus, Polypedilum
convictum, and Limnodrilus hoffmeisteri.
Rich Fork Creek, NC 109
The upper reaches of Rich Fork Creek drain the
western and southwestern urban areas of the City
of High Point. In 2001, as in 1996, the stream was
sampled upstream from a sand dipping operation
and downstream from the City of High Point's
West Side WWTP (6.2 MGD). The stream had the
highest conductivity (433 pmhos/cm) of any site
fish community site monitored in 2001.
Rich Fork Creek at NC 109, Davidson County.
The fish community was rated Poor in 1996 and
2001 (NCIBI = 34). In 2001, the bluehead chub,
redbreast sunfish, and the spottail shiner were the
dominant species. In 1996, the dominant species
was the redbreast sunfish. Rich Fork Creek was
one of the few waterbodies monitored in 2001
where darters were absent. No intolerant species
were collected and the trophic structure was
skewed towards omnivores and herbivores.
Rich Fork, SR 2005
This site is the most downstream bridge crossing
before Rich Fork enters Abbotts Creek. The
substrate at this seven meter wide site was
predominately sand with a small amount of gravel.
The water had a slight reddish tinge, instream
habitat was limited, but the riparian zone was
intact and extensive.
Rich Fork at SR 2005, Davidson County.
This site has consistently been rated Fair based
on benthic macroinvertebrate data since 1985.
NCDENR, Division of Water Quality
Basinwide Assessment Report - Yadkin River Basin - June 2002
94

However, EPT taxa richness increased slightly in
2001 (from 13 to 15). Organic/ enrichment and
toxic indicator taxa found in abundance here
include: Conchapelopia, Polypedilum illinoense,
and Lumbriculidae.
Hamby Creek, SR 2017
Hamby Creek flows from Thomasville into Abbotts
Creek north of Lexington. This creek receives
effluent from the City of Thomasville's WWTP (4
MGD).
This stream was sampled at SR 2025 in 1996,
resulting in a bioclassification of Poor based on an
EPT sample (EPT = 6). For reasons concerning
flow and accessibility, in 2001, the stream was
sampled two bridges further downstream at SR
2017. At this site, the stream was rated Fair (EPT
= 12). The EPT abundance also increased from
14 in 1996 to 56 in 2001.
The water at this site was clear with a reddish
tinge and a distinct effluent odor was prominent.
Instream habitat was good, riffle areas were
frequent, and the banks were stable with a wide
intact riparian zone. These favorable habitat
conditions support the assumption that the
discharger is adversely impacting the stream.
Hamby Creek at SR 2017, Davidson County.
Leonards Creek, Leonard Creek Farm Road
In 2001, due to size and accessibility concerns,
this site was moved from the 1996 location to a
site one-half mile upstream, off Leonard Creek
Farm Road. This stream is a small (three meter
wide) tributary to Abbotts Creek. Its headwaters
are north of the Town of Welcome and the stream
flows southeasterly to Abbotts Creek just above
Lexington.
Leonards Creek, off Leonard Creek Farm Road,
Davidson County.
This site received a Good -Fair bioclassification at
SR 1844 in 1996 and Good -Fair at the alternate
site in 2001. Instream habitat at both sites was
abundant and riffles were infrequent, but wide.
There are only two access points to this stream
below City Lake. One is at SR 1844 and the other
is off Leonard Creek Farm Road on private
property. Because of its size and accessibility
problems, this stream should be dropped from the
basinwide monitoring list.
SPECIAL STUDIES
303 (d) Streams
Hunts Fork, above SR 1787
This stream was sampled to determine if it should
remain on the impaired streams list. The site was
three meters wide with a substrate composed
primarily of sand and silt. Root mats were rare;
macrophytes, leaf packs, and snags were
common; and the riparian zone was not intact.
Hunts Fork at SR 1787, Davidson County.
NCDENR, Division of Water Quality
Basinwide Assessment Report - Yadkin River Basin - June 2002
95

Appendix 41. Summary of the water quality parameters from Rich Fork at SR 1800 near
Thomasville (Q5780000; C) collected between September 03, 1996 and August 13,
2001.
< or > Eval.
Num. Eval. Level Percentiles
Parameter N < R.L. Level n % Min. 10 25 50 75 90 Max.
Field
Dissolved
Oxygen 47 NA <4 0 0.0 4.0 4.9 5.9 7.8 9.5 10.8 13.0
(DO; mg/L) <5 6 12.8
Conductivity 48 NA
Temperature (C) 49 NA
82 157 223 299 452 481 528
3 8 12 16 23 26 28
pH (s.u.) 49 NA <6 0 0.0 6.2 6.5 6.7 7.0 7.2 7.2 7.4
>9 0 0.0
Other (mg/L)
Total Residue 1 0 . . . 330 330 330 330 330 330 330
TSS 47 0 >10 20 42.6 1 3 5 8 18 29 260
>20 9 19.1
Chloride 0 0
Turbidity (NTU) 56 0 >50 2 3.6 2 4 6 8 15 25 120
>25 6 10.7 .
>10 20 35.7 .
Nutrients (mg/L)
NH3 as N 55 3 . 0.01 0.02 0.07 0.11 0.20 0.36 2.30
TKN as N 54 0 . . . 0.20 0.40 0.63 0.90 1.20 1.60 5.40
NO2+NO3 as N 55 0 >10 1 1.8 0.37 1.10 1.85 3.50 6.40 8.10 12.00
Total Phosphorus 55 0 0.05 55 100.0 0.13 0.25 0.41 0.62 1.10 2.18 3.30
Metals (pg/L)
Aluminum (Al) 49 1 . . 50 180 300 470 920 2100 9200
Copper (Cu) 49 7 >7 7 14.3 2 2 3 4 6 7 22
Iron (Fe) 49 0 >1000 13 26.5 77 440 580 750 1100 192010000
Manganese (Mn) 0 0 >200 0 .
Zinc (Zn) 49 1 >50 17 34.7 10 16 29 42 57 66 4000
Arsenic (As) 49 49 >50 . Most all samples collected for these metals
Cadmium (Cd) 49 49 >2 . have concentrations below the reporting level.
Chromium (Cr) 49 48 >50 . . Samples that have concentrations above
Lead (Pb) 49 48 >25 . . reporting and reference levels are too few in
Mercury (Hg) 48 48 >0.012 . . number to provide any confidence for
Nickel (Ni) 49 49 >88 . . interpretation.
Abbreviations: N or n = number, Num. < R.L. = number < Reporting Level; < or > refers to "less than or greater than"; TSS =
Total Suspended Solids; Conductivity measured as pmhos/cm; NA = not applicable.
Evaluation Levels (Eval. Level or EL) are presented to facilitate review. Some levels refer to water quality standards; others may
be used for ecological or Action Level review. Measurements should not exceed the range (< or >) indicated by the EL.
NCDENR, Division of Water Quality
Basinwide Assessment Report - Yadkin Basin - June 2002
294

Station ID
Date
Time
Depth
Temp_C_1(
Temp_rmk
Oxygen _3C
)/) 17
�dJI UVULA.' UI. J I UVO
LU.:)U
I .'iU
Q5750000 6/10/1998
19.50
7.30
Q5750000 6/18/1998
21.00
7.00
Q5750000
6/25/1998
24.00
7.10
Q5750000
7/1/1998
24.00
6.20
Q5750000
7/8/1998
24.00
8.60
Q5750000
7/14/1998
21.00
7.20
Q5750000
7/21/1998
25.50
6.40
Q5750000
7/28/1998
25.00
6.60
Q5750000
8/6/1998
22.00
5.40
Q5750000
8/11/1998
23.50
6.60
Q5750000
8/19/1998
24.50
7.30
Q5750000
8/28/1998
24.00
5.20
Q5750000
9/8/1998
23.00
5.50
Q5750000
9/9/1998
22.50
5.40
Q5750000
10/8/1998
20.40
5.80
Q5750000
10/16/1998
12.00
6.70
Q5750000
11/18/1998
10.00
7.40
Q5750000
12/1/1998
8.50
8.80
Q5750000
1/5/1999
9:10
0.01 1.00
9.30
Q5750000
2/2/1999
8:45
0.01
6.00
11.70
Q5750000
3/12/1999
8:50
0.01
2.50
12.40
Q5750000
4/9/1999
8:35
0.01
16.20
9.70
Q5750000
5/5/1999
8:03
0.01
14.40
8.50
Q5750000
5/14/1999
10:49
0.01
15.90
8.20
Q5750000
5/18/1999
12:42
0.01
17.10
9.50
Q5750000
5/24/1999
13:00
0.011
20.00
7.60
Q5750000
6/4/1999
13:22
0.01
18.50
6.20
Q5750000
6/10/1999 7:37
0.01
21.10
5.40
Q5750000
6/14/1999
12:35
0.01
21.00
6.50
Q5750000
6/21/1999
13:05
0.01
17.60
8.20
Q5750000
7/1/1999
10:10
0.01
22.70
6.30
Q5750000
7/9/1999
9:19
0.01
21.00
5.30
Q5750000
7/13/1999
8:37
0.01
18.10
8.20
Q5750000 7/19/1999
12:51
0.01
23.50
6.70
Q5750000 7/26/1999
11:57
0.01
24.20
6.60
Q5750000_1 8/5/1999
8:24
0.01
23.70
5.70
1_95750000
Q5750000
Q5750000
Q5750000
8/13/1999
11:31
13:26
12:43
11:45
11:06
0.01
0.01
0.01
0.01
23.00
4.60
8/16/1999
23.70
6.00
8/23/1999
18.001
6.40
8/30/1999
18.00
6.80
Q5750000
9/10/1999
0.01
18.00
7.20
Q5750000
9/14/1999 8:471 0.01
14.00
7.00
Q5750000
9/20/1999 13:501 0.01
14.00
8.40
yl 750000
,tZ' /7.5c
; J cvvr ' o rrn I l (
GUS Ck c4/1-5sc .
• L(L

Q5750000
9/29/1999
11:39
0.01
18.00
8.40
O5750000
10/15/1999
8:22
0.01
12.90
9.00
Q5750000
11/5/1999
8:07
0.01
6.60
8.60
Q5750000
12/3/1999
8:15 0.01
3.30
12.40
Q5750000
1/14/2000
8:43 0.01
4.10
12.30
Q5750000
2/16/2000
13:05
12:30
14:00
0.01
8.50
11.70
Q5750000
Q5750000
Q5750000
3/21/2000
4/18/2000
0.01
10.30
9.90
0.01
14.40
6.50
5/5/2000
5:15
0.01
15.70
3.30
Q5750000
5/12/2000
5:00
0.01
17.10
9.60
Q5750000
5/18/2000
15:25
0.01
19.90
8.00
Q5750000
5/25/2000
11:45
0.01
20.20
6.80
Q5750000
6/2/2000
13:55
0.01
21.00
E
6.90
Q5750000
6/9/2000
4:00
0.01
17.60
12.80
Q5750000
6/16/2000
6:00
0.01
20.30
7.20
Q5750000
6/22/2000
17:15
0.01
23.70
E
6.60
Q5750000
6/30/2000
15:15
0.01
22.50
E
6.90
Q5750000
7/8/2000
10:31
0.01
24.30
6.90
Q5750000
7/14/2000
15:45
0.01
23.60
7.00
Q5750000
7/21/2000
9:10
0.01
21.80
5.00
Q5750000
7/24/2000
11:52
0.01
21.10
7.60
Q5750000
8/3/2000
12:45
0.01
22.60
6.50
Q5750000
8/11/2000
14:50
0.01
24.10
6.70
Q5750000
8/16/2000
11:32
0.01
21.50
6.50
Q5750000
8/23/2000
15:30
0.01
20.70
7.20
Q5750000
9/1/2000
12:48
0.01
23.50
6.20
Q5750000
9/5/2000
12:16
0.01
21.20
7.20
Q5750000
9/13/2000
18:05
0.01
21.50
7.40
Q5750000
9/22/2000 11:48
0.01
19.60
7.70
Q5750000
9/25/2000 13:50
0.01
20.60
6.90
Q5750000
10/17/2000
12:56
0.01
14.10
5.20
Q5750000
11 R/2000
11:31
0.01
11.10
8.00
Q5750000
12/13/2000
12:54
0.01
5.20
12.00
Q5750000
1/4/2001
15:16 0.01
1.10
12.90
Q5750000
2/13/2001
14:52 0.01
6.10
12.40
Q5750000
3/6/2001
14:54 0.01
7.00
12.80
Q5750000
4/4/2001
13:02 0.01
10.70
11.20
Q5750000
5/1/2001
13:51 0.01
16.90
9.10
Q5750000
5/7/2001
14:51
0.01
17.80
7.60
Q5750000
5/16/2001
9:31
14:45
18:11
15:13
0.01
0.01
0.01
17.10
7.20
Q5750000
Q5750000
5/24/2001
5/30/2001
19.80
7.30
19.70
7.10
Q5750000
6/4/2001
0.01.
19.80
20.80
6.70
Q5750000
6/11/2001
11:01
0.01
6.40
Q5750000
6/21/2001
15:32
0.011
25.90
6.40

Q5750000
6/27/2001
16:25
0.01
24.00
6.70
05750000
7/2/2001
16:42
0.01
23.10
5.60
Q5750000
7/17/2001
10:52
0.01
20.60
5.10
Q5750000 7/24/2001
9:51
0.01
21.60
4.60
Q5750000
Q5750000
7/30/2001
9:25
0.01
20.00
6.80
8/7/2001
0.01
22.90
4.40
Q5750000
8/13/2001
9:33
0.01
23.90
4.80
Q5750000
8/21/2001
10:06
10:11
0.01
0.01
21.80
22.80
20.90
5.00
Q5750000
8/27/2001
5.00
Q5750000
9/4/2001
9:26
0.01
5.10
Q5750000
9/11/2001
10:19 0.01
21.10
5.00
Q5750000
9/17/2001
9:36 0.01
19.80
5.60
Q5750000
9/25/2001
9:49
0.01
18.70
6.10
Q5750000
10/9/2001
10:55
0.01 9.80
4.60
Q5750000
11/13/2001
9:57
0.01 6.10
6.50
Q5750000
12/4/2001
10:12
0.01
8.20
5.50
Q5750000
1/15/2002
10:09
0.01
2.80
8.90
Q5750000
2/12/2002
10:00
0.01
6.20
8.10
Q5750000
3/5/2002
9:52
0.01
3.50
8.90
Q5750000
4/9/2002
9:58
0.01
13.70
8.90
Q5750000
5/7/2002
9:33
0.01
15.40
6.90
Q5750000
5/14/2002
15:03
0.01
17.70
7.40
Q5750000
5/21/2002
15:10
0.01
13.80
7.50
Q5750000 5/29/2002
14:43
0.01
19.80
6.00
Q5750000
6/4/2002
14:47
0.01
23.10
5.20
Q5750000
6/11/2002
9:42
0.01
19.90
5.90
Q5750000
6/20/2002 9:42
0.01
19.80
5.80
Q5750000
6/27/2002
14:37
0.01
22.70
5.30
Q5750000
7/1/2002
15:04
0.01
25.10
5.20
Q5750000
7/9/2002
9:36
0.01
22.00
5.50
Q5750000
7/16/2002
14:48
0.01
25.10
5.20
Q5750000
7/25/2002
13:14
0.01
22.90
5.40
Q5750000
8/6/2002
9:43
0.10
23.80
5.30
Q5750000
8/13/2002
15:03
0.10
24.20
5.20
Q5750000
8/21/2002
13:12
0.10
23.60
4.00
Q5750000
8/27/2002
14:16
0.10
22.70
4.30
Q5750000
9/3/2002
14:40
0.10
21.60
4.60
Q5750000
9/10/2002
8:53
0.10
19.20
5.20
Q5750000
9/19/2002
9:40
0.10
21.90
5.50
Q5750000
9/24/2002
10:04
0.10
19.30
5.70
10/8/2002
9:57
0.01
0.01
0.01
17.30
6.20
[95750000
Q57500001
Q5750000
Q5750000
11/5/20021
9:43`
9:44
11.60
6.00
12/3/2002
5.20
8.30
1/7/2003
9:35 0.10
4.50
8.60
Q5750000 2/11/2003
9:281 0.10
4.60
9.60

Q5750000
3/18/2003 9:58
0.10
11.90
9.90
Q5750000
4/8/2003
10:12
14:16
0.10
13.70
9.60
Q5750000
5/6/2003
0.10
16.50
9.40
Q5750000
5/13/2003
9:08 0.10
18.10
7.60
Q5750000
5/20/2003
13:54 0.10
16.40
7.40
Q5750000
5/28/2003
16:23 0.10
18.30
9.40
Q5750000
6/3/2003
13:50
0.10
17.50
8.60
Q5750000
Q5750000
6/10/2003
9:04
0.10
18.80
8.20
6/17/2003
14:05
0.10
19.70
8.30
Q5750000
6/24/2003
8:32
0.10
19.50
8.60
Q5750000
7/15/2003
9:29
0.10
22.30
7.30
Q5750000
7/29/2003
8:04
0.10
24.20
7.10
Q5750000
8/12/2003
8:20
0.10
21.60
9.00
Q5750000
8/26/2003
9:11
0.10
23.60
6.40
Q5750000
9/9/2003
8:14
0.10
19.50
7.10
Q5750000
9/23/2003
9:04
0.10
20.20
7.50
Q5750000
10/28/2003
9:28
0.10
14.40
8.70
Q5750000
11/18/2003
9:31
0.10
12.70
9.60
Q5750000
12/9/2003
9:33
0.10
3.90
11.80
Q5750000
1/13/2004
9:42
0.10
4.20
9.70
Q5750000
2/10/2004
9:22
0.10
4.60
10.60
Q5785000
6/3/1998
22.00
5.00
Q5785000
6/10/1998
19.50
5.60
Q5785000
6/18/1998
21.50
5.40
Q5785000
6/25/1998
26.00
5.20
Q5785000
7/1/1998
24.50
6.50
Q5785000
7/8/1998
25.001
6.40
Q5785000
7/14/1998
23.001
5.60
Q5785000
7/21/1998
26.00
4.90
Q5785000
7/28/1998
26.00
5.60
Q5785000
8/6/1998
23.00
5.80
Q5785000
8/11/1998
24.50
5.50
Q5785000 8/19/1998
26.00
5.10
Q5785000 8/28/1998
25.00
4.60
Q5785000 9/8/1998
24.50
5.50
Q5785000 9/9/1998
24.00
5.70
Q5785000
05785000
Q5785000
10/8/1998
10/16/1998
22.30
4.90
13.00
4.60
11/18/1998
12.00
5.90
Q5785000
Q5785000
12/1/1998'
1/5/1999
2/2/1999
3/12/1999
11.00
8.10
9:45
9:15
9:15
9:00
0.01
1.50
11.00
Q5785000
0.01
6.00
10.00
Q5785000
0.01
6.00
11.20
Q5785000
4/9/1999
0.01
17.80
6.80
Q5785000
5/5/1999 8:33i 0.01
15.90
6.60,
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Q5785000
5/14/19991 11:03
0.01
18.20
6.20
Q5785000
5/18/1999
13:00
0.01
18.10
7.80
Q5785000
5/24/1999
13:15
0.01
21.40
6.00
Q5785000
6/4/1999
13:06
0.01
20.00
5.60
Q5785000
6/10/1999
8:02
0.01
22.80
4.10
Q5785000
6/14/1999
12:50
0.01
22.10
5.40
Q5785000
6/21/1999
13:20
0.01
18.30
6.80
Q5785000
7/1/1999
10:25
0.01
23.10
4.70
Q5785000
7/9/1999 8:43
0.01
21.50
5.30
Q5785000
7/13/1999 9:07
0.01
19.70
6.70
Q5785000
7/19/1999 13:08
0.01
24.70
5.00
Q5785000
7/26/1999
12:11
0.01
25.50
5.10
Q5785000 8/5/1999
8:52
0.01
21.70
5.00
Q5785000
8/13/1999
11:45
0.01
24.30
4.90
Q5785000
8/16/1999
13:40
0.01
24.80
4.80
Q5785000
8/23/1999
12:57
0.01
19.00
5.80
Q5785000
8/30/1999
12:00
0.01
19.50
5.80
Q5785000 9/10/1999
11:21
0.01
19.00
6.00
Q5785000
9/14/1999
9:14
0.01
16.00
5.60
Q5785000
9/20/1999
14:11
0.01
16.00
6.40
Q5785000
9/29/1999
11:54
0.01
18.00
6.80
Q5785000
10/15/1999
8:47
0.01
15.30
6.90
Q5785000
11/5/1999
8:37
0.01
9.30
5.80
Q5785000
12/3/1999
8:40
0.01
5.70
9.60
Q5785000
1/14/2000
9:15
0.01
6.40
9.20
Q5785000
2/16/2000
13:37
0.01
8.00
9.10
Q5785000
3/21/2000
13:00
0.01
10.90
8.80
Q5785000
4/18/2000 14:25
0.01
15.30
7.70
Q5785000
5/5/20001 5:35
0.01
17.40
2.90
Q5785000
5/12/2000 5:10
0.01
18.60
6.50
Q5785000
5/18/2000
15:40
0.01
20.30
7.60
Q5785000
5/25/2000
12:00
0.01
21.40
4.40
Q5785000
6/2/2000
14:05
0.01
22.10
E
5.30
Q5785000
6/9/2000
4:25
0.01
19.00
7.20
Q5785000
6/16/2000
6:10
0.01
19.70
7.00
Q5785000
6/22/2000
17:35 0.01
24.70E
6.00
Q5785000
6/30/2000
15:40 0.01
23.70
E
6.10
Q5785000
7/8/2000
10:45 0.01
23.20
7.10
Q5785000
7/14/2000 16:02
0.01
24.10
5.60
Q5785000
7/21/2000
7/24/2000
9:40
0.01
23.00
5.10
Q5785000
Q5785000
Q5785000
12:12
13:00
15:05
11:52
0.01
21.60
6.70
8/3/2000
8/11/2000
8/16/2000r
0.01
23.70
5.00
0.01
25.10
5.00
Q5785000
0.01 23.10
4.40
Q5785000
8/23/2000
15:50, 0.01 22.40
5.20

Q5785000
Q5785000
9/1/2000 13:00
9/5/2000 12:27
Q5785000
Q5785000
9/13/2000 18:20
9/22/2000 12:01
Q5785000
9/25/2000 14:15
Q5785000 10/17/2000 13:18
Q5785000
Q5785000
11/7/2000 11:52
12/13/2000
13:17
0.01 24.30
0.01 22.30
0.01
0.01
0.01
0.01 l
0.01
0.01;
23.40
20.50
21.70
16.20:
13.10
6.10
4.40
4.90
5.00
6.60
5.10
6.10
7.10
11.00
Q5785000
Q5785000
1/4/2001 15:37
2/13/2001
15:10
Q5785000
3/6/2001 15:13
Q5785000
4/4/2001 13:21
Q5785000
Q5785000
Q5785000
5/1/2001
5/7/2001
5/16/2001
Q5785000
14:04
15:12
9:44
0.011
0.01
0.01
0.01
0.01
0.01
0.01
2.70
10.50
7.30
10.80
7.70
11.40
11.40
9.30
18.60
6.10
19.30
18.30
5.60
5.00
5/24/2001
14:55
0.01
22.30
5.60
Q5785000
5/30/2001
18:27
Q5785000
Q5785000
Q5785000
Q5785000
Q5785000
Q5785000
Q5785000
Q5785000
Q5785000
6/4/2001
15:32
6/11/2001
6/21/2001
6/27/2001
7/2/2001
7/17/2001
7/24/2001
7/30/2001
11:11
15:44
16:34
17:02
10:27
10:16
0.01
0.01
0.01
0.01
0.01
21.30
21.60
22.20
5.20
5.20
5.00
27.90
5.60
24.80
5.80
0.01
0.01
0.01
24.20
22.20
23.00
4.60
4.70
4.70
9:41
0.01
21.30
4.70
8/7/2001
Q5785000 8/13/2001
Q5785000 8/21/2001
11:22
9:47
10:20
Q5785000
8/27/2001
10:26
Q5785000 9/4/2001 9:39
Q5785000 9/11/2001 10:40
Q5785000 9/17/2001 9:53
Q5785000 9/25/2001 10:05
Q5785000 10/9/2001 11:23
Q5785000 11/13/2001 10:18
Q5785000 12/4/2001
Q5785000 1/15/2002
Q5785000 . 2/12/2002
Q5785000 3/5/2002
Q5785000 4/9/20021
Q5785000 5/7/2002
Q5785000 5/14/2002
Q5785000 5/21/2002
Q5785000 5/29/2002
Q5785000 6/4/2002
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
24.20
24.40
22.50
22.00
21.40
23.00
18.60
19.40
11.00
7.70
4.20
4.20
3.80
4.00
3.40
4.10
5.20
4.50
5.40
6.20
11:01 0.01, 8.20
10:31 0.01 2.70
10:19 0.01 6.00
10:11 0.01 4.00
10:16 0.01 14.70
9:52 . 0.01 16.10
15:20 0.01 18.80
15:26 0.01 15.00
15:01 0.01 20.60
14:59, 0.01 24.30
7.60
9.80
8.50
8.70
7.60
5.20
5.90
5.80
5.30
4.10

Q5785000
6/11/2002
10:01
0.01
20.80
5.10
Q5785000
6/20/2002
10:00
0.01
20.60
5.30
Q5785000
6/27/2002
14:20
0.01
23.30
5.30
Q5785000
7/1/2002
15:21
0.01
25.60
4.20
Q5785000
7/9/2002
9:55
0.01
22.90
3.90
Q5785000
7/16/2002
15:03
0.01
25.70
3.80
Q5785000
7/25/2002
13:31
0.01
23.70
5.10
Q5785000
8/6/2002
10:03
15:20
0.10
24.60
3.80
Q5785000
8/13/2002
0.10
25.10
3.40
Q5785000
8/21/2002
12:57
0.10
24.30
3.20
Q5785000
8/27/2002
14:34
0.10
23.40
3.70
Q5785000
9/3/2002
14:57
0.10
22.10
3.70
Q5785000
9/10/2002
9:11
0.10
20.40
4.50
Q5785000
9/19/2002
9:54
0.10
22.20
5.20
Q5785000
9/24/2002
10:25
0.10
20.20
5.10
Q5785000
10/8/2002
10:19
0.01
18.10
5.30
Q5785000
11/5/2002
10:06
0.01
12.70
6.20
Q5785000
12/3/2002
10:08
0.01
5.00
8.80
Q5785000
1/7/2003
9:57
0.10
4.40
8.90
Q5785000
2/11/2003
9:49
0.10
4.30
9.70
Q5785000
3/18/2003
10:20
0.10
12.50
8.70
Q5785000
4/8/2003 10:32
0.10
13.90
9.30
Q5785000
5/6/2003 14:31
0.10
16.80
9.00
Q5785000
5/13/2003 9:30
0.10
18.40
7.40
Q5785000
5/20/2003
14:09
0.10
16.50
7.00
Q5785000
5/28/2003
16:09
0.10
18.50
9.10
Q5785000
6/3/2003
14:04
0.10
17.90
8.30
Q5785000
6/10/2003
9:25
0.10
19.20
8.00
Q5785000
6/17/2003
14:20
0.10
20.00
19.90
8.00
Q5785000
6/24/2003
8:50
0.10
7.80
Q5785000 7/15/2003
9:39
0.10
22.60
6.80
Q5785000
7/29/2003
8/12/2003
8/26/2003
8:19
0.10
24.50
6.20
Q5785000
Q5785000
8:39
0.10
21.90
7.90
9:31
0.10
24.10
5.60
Q5785000
9/9/2003
8:31
0.10
19.90
6.40
Q5785000
9/23/2003
9:26
0.10
20.80
6.70
Q5785000
10/28/2003
9:48
0.10
14.80
7.80
Q5785000
11/18/2003 9:53
0.10
13.30
8.40
Q5785000
12/9/2003 9:55
0.10
4.40
11.30
Q5785000
Q5785000
1/13/2004
2/10/2004
10:01
0.10
4.00
10.40
9:41
0.10
4.30
10.00

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1997-01-06 10:nn
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1997-02-04 13:nn
0.1
300
10.2
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Q5780000
1997-03-03 12:nn
0.1
300
9.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1997-04-03 10:nn
0.1
300 10
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1997-05-01 10:nn
0.1
3001 9.6
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1997-06-02 10:nn
0.1
300
6.6
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1997-07-01 13:nn
0.1
3001 6.2
OXYGEN DISSOLVED MG/L
NCAMBNT '
Q5780000
1997-08-13 12:nn
0.1
3001 5.6
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1997-09-03 14:nn
0.1
300; 4.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1997-10-02 10:nn
0.1
3001 5.6
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1997-11-04 14:nn
0.1
300T
7.4
OXYGEN DISSOLVED MG/L
NCAMBNT
05780000
1997-12-02 13:nn
0.1
300
9.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-01-13 12:nn
0.1
3001 8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-02-04 13:nn
0.1
300 11.4
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-03-11 11:nn
0.1
3001 12.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-04-01 12:nn
0.1
3001 10.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-05-05 09:nn
0.1
300i 8.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-06-03 14:nn
0.1
300; 7.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-07-07 13:nn
0.1
300 7.4
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-08-06 10:nn
0.1
3001 5.4
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-09-03 11:nn
0.1
3001 4.9
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-10-01 11:nn
0.1
3001 6.5
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-11-03 12:nn
0.1
1
300; 5.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1998-12-30 12:nn
0.1
300 9.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1999-01-14 12:nn
0.1
3001 8.6
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
' 1999-02-11 13:nn
0.1
300 9
4OXYGEN
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NCAMBNT
Q5780000
1999-09-01 12:nn
0.1
300
6
9.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
1999-12-13 13:nn
0.1
300
OXYGEN DISSOLVED MG/L
NCAMBNT
05780000
2000-01-04 12:nn
0.1
300 8.3
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2000-02-02 12:nn
0.1
300 13
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2000-03-06 12:nn
0.1
300
11.3
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2000-04-10 13:nn
0.1
300
9.8
OXYGEN DISSOLVED MG/L
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Q5780000
2000-05-15 11:nn
0.1
300
6
OXYGEN DISSOLVED MG/L
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Q5780000
2000-06-19 12:nn
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Q5780000
2000-07-18 13:nn
0.1
300
5.3
5.9
OXYGEN DISSOLVED MG/L
Q5780000
2000-08-21 13:nn
0.1
300
OXYGEN DISSOLVED MG/L
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Q5780000 2000-09-05 13:nn
0.1
300 7.3
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Q5780000 2000-10-19 13:nn
0.1
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Q5780000 2000-12-13 13:nn
0.1
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0.1
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0.1
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2001-07-23 14:nn
0.1
300
4.6
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2001-08-13 12:nn
0.1
300
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2001-09-12 13:nn
0.1
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6.4
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Q5780000
2001-10-16 12:nn
0.1
300
8.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2001-11-14 13:nn
0.1
300
10.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2001-12-13 13:nn
0.1
300
7.3
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2002-01-08 12:nn
0.1
300
11.5
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2002-02-12 14:nn
0.1
300
9.4
OXYGEN DISSOLVED MG/L
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Q5780000
2002-03-21 12:nn
0.1
300
9
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NCAMBNT
Q5780000
2002-04-30 13:nn
0.1
300
6.9
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NCAMBNT
Q5780000
2002-05-30 13:nn
0.1
300
6.8
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Q5780000
2002-06-25 16:nn
0.1
300
4.9
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NCAMBNT
Q5780000
2002-07-18 15:nn
0.1
300
6.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2002-08-14 12:nn
0.1
300
4.8
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NCAMBNT
Q5780000
2002-09-23 13:nn
0.1
300
5.4
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NCAMBNT
Q5780000
2002-10-17 13:nn
0.1
300
8
OXYGEN DISSOLVED MG/L
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Q5780000
2002-11-20 16:nn
0.1
300
8.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2002-12-18 16:nn
0.1
300
10
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NCAMBNT
Q5780000
2003-01-22 12:nn
0.1
300
12.3
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Q5780000
2003-02-20 13:nn
0.1
300
11.5
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Q5780000
2003-03-24 14:nn
0.1
300
9.2
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NCAMBNT
Q5780000
2003-04-08 15:nn
0.1
300
9.6
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NCAMBNT
Q5780000
2003-05-29 12:nn
0.1
300
7.6
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NCAMBNT
Q5780000
2003-06-26 09:nn
0.1
300
5.3
OXYGEN DISSOLVED MG/L
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Q5780000
2003-07-17 08:nn
0.1
300
5.4
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2003-08-14 09:nn
0.1
300
5.7
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2003-09-15 13:nn
0.1
300
6.4
OXYGEN DISSOLVED MG/L
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Q5780000
2003-10-15 14:nn
0.1
300
8.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2003-11-01 16:nn
0.1
300
8.8
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2003-12-08 15:nn
0.1
300
11.5
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-01-07 14:nn
0.1
300
11.4
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-02-03 10:nn
0.1
300
13.5
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-03-04 13:nn
0.1
300
9.8
OXYGEN DISSOLVED MG/L
NCAMBNT IQ5780000
2004-04-06 10:nn
0.1 300
8.4
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-05-20 10:nn
0.1
300
5.5
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-06-28 10:nn
0.1
0.1
300
5.5
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-07-28 12:nn
300
6.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-08-2411:nn
0.1
300
4.7
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-09-16 12:nn
0.1
300
5.9
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-10-25 15:nn
0.1
300
7.7
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-11-08 11:nn
0.1
300
7.2
OXYGEN DISSOLVED MG/L
NCAMBNT
Q5780000
2004-12-07 10:nn
0.1
300
8.9
OXYGEN DISSOLVED MG/L

http://www.epa.gov/storpubl/modern/downloads/SDR20050518_104249.txt
Station ID -Activity Start -Zone -Activity Type -Activity Depth -Activity Depth Unit-Characte
Q5780000 -2002-04-30 13:25:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-05-01 10:15:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-04-03 10:30:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2001-11-14 13:15:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-01-13 12:30:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2002-12-18 16:20:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-06-19 12:30:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-02-02 12:50:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-05-05 09:05:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-01-22 12:55:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-12-13 13:50:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-01-06 10:35:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-09-03 11:15:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2002-01-08 12:55:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-07-01 13:45:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2004-11-08 11:00:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-10-19 13:00:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-08-06 10:20:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2004-07-28 12:30:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-03-24 14:45:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-04-10 13:30:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-11-03 12:15:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-06-03 14:45:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-12-08 15:20:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-05-29 12:40:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-07-18 13:00:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1999-02-11 13:00:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-10-02 10:05:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2002-05-30 13:10:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2002-09-23 13:00:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2002-07-18 15:45:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-01-04 12:15:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-12-30 12:35:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-12-02 13:10:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2004-06-28 10:10:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-09-15 13:30:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-07-17 08:35:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-03-11 11:00:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2004-03-04 13:30:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-08-13 12:20:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-11-01 16:00:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2002-08-14 12:30:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2004-10-25 15:20:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-02-20 13:30:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2001-12-13 13:40:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2002-03-21 12:25:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2000-05-15 11:00:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2004-01-07 14:00:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2001-06-11 14:05:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-03-03 12:45:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -2003-04-08 15:40:00-EDT-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1997-02-04 13:30:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
Q5780000 -1998-04-01 12:30:00-EST-Field Msr/Obs-0.1 -m -Dissolved oxygen
ristic Name -Sample Fraction -Value Type -Result•
(DO) -Dissolved -Actual -6.9-6.9-mg/]
(DO) -Dissolved -Actual -9.6-9.6-mg/]
(DO) -Dissolved -Actual -10-10-mg/1
(DO) -Dissolved -Actual -10.2-10.2-mgi
(DO) -Dissolved -Actual -8-8-mg/1
(DO) -Dissolved -Actual -10-10-mg/1
(DO) -Dissolved -Actual -4.8-4.8-mg/]
(DO) -Dissolved -Actual -13-13-mg/1
(DO) -Dissolved -Actual -8.8-8.8-mg/]
(DO) -Dissolved -Actual -12.3-12.3-mg/
(DO) -Dissolved -Actual -8.7-8.7-mg/]
(DO) -Dissolved -Actual -9.4-9.4-mg/]
(DO) -Dissolved -Actual -4.9-4.9-mg/]
(DO) -Dissolved -Actual -11.5-11.5-mg/
(DO) -Dissolved -Actual -6.2-6.2-mg/]
(DO) -Dissolved -Actual -7.2-7.2-mg/]
(DO) -Dissolved -Actual -4.9-4.9-mg/]
(DO) -Dissolved -Actual -5.4 -5.4 -mg/]
(DO) -Dissolved -Actual -6.2-6.2-mg/]
(DO) -Dissolved -Actual -9.2-9.2-mg/J
(DO) -Dissolved -Actual -9.8-9.8-mg/]
(DO) -Dissolved -Actual -5.8-5.8-mg/]
(DO) -Dissolved -Actual -7.8-7.8-mg0
(DO) -Dissolved -Actual -11.5-11.5-mgi
(DO) -Dissolved -Actual -7.6-7.6-mg/]
(DO) -Dissolved -Actual -5.3-5.3-mg/]
(DO) -Dissolved -Actual -9-9-mg/1
(DO) -Dissolved -Actual -5.6-5.6-mg/]
(DO) -Dissolved -Actual -6.8-6.8-mg/]
(DO) -Dissolved -Actual -5.4-5.4-mg/]
(DO) -Dissolved -Actual -6.8-6.8-mg/]
(DO) -Dissolved -Actual -8.3-8.3-mg/]
(DO) -Dissolved -Actual -9.2-9.2-mg/]
(DO) -Dissolved -Actual -9.2-9.2-mg/J
(DO) -Dissolved -Actual -5.5-5.5-mg/J
(DO) -Dissolved -Actual -6.4-6.4-mg/]
(DO) -Dissolved -Actual -5.4-5.4-mg/]
(DO) -Dissolved -Actual -12.2-12.2-mg,
(DO) -Dissolved -Actual -9.8-9.8-mg/]
(DO) -Dissolved -Actual -5.6-5.6-mg/]
(DO) -Dissolved -Actual -8.8-8.8-mg/]
(DO) -Dissolved -Actual -4.8-4.8-mg/]
(DO) -Dissolved -Actual -7.7-7.7-mg/]
(DO) -Dissolved -Actual -11.5-11.5-mg/
(DO) -Dissolved -Actual -7.3-7.3-mg/]
(DO) -Dissolved -Actual -9-9-mg/1
(DO) -Dissolved -Actual -6-6-mg/1
(DO) -Dissolved -Actual -11.4-11.4-mgi
(DO) -Dissolved -Actual -5-5-mg/1
(DO) -Dissolved -Actual -9.2-9.2-mg/]
(DO) -Dissolved -Actual -9.6-9.6-mg/]
(DO) -Dissolved -Actual -10.2-10.2-mgi
(DO) -Dissolved -Actual -10.2-10.2-mgi
1 of 2 5/18/2005 10:49 AM

http://www.epa. gov/storpubl/modern/downloads/SDR20050518_ 104249. txt
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
Q5780000
-2004-02-03
-2001-08-13
-1999-12-13
-1997-06-02
-1998-10-01
-2001-07-23
-2002-11-20
-2004-09-16
-2004-05-20
-1997-11-04
-2003-10-15
-1999-01-14
-2004-08-24
-2000-08-21
-2000-03-06
-1997-09-03
-2002-02-12
- 1998-07-07
- 2004-04-06
-2001-01-04
-2003-06-26
-2002-10-17
- 1998-02-04
-2003-08-14
-2001-10-16
-2002-06-25
-2000-09-05
-2004-12-07
-2001-09-12
-1999-09-01
10:45:00-EST-Field
12:30:00-EDT-Field
13:30:00-EST-Field
10:10:00-EDT-Field
11:15:00-EDT-Field
14:15:00-EDT-Field
16:25:00-EST-Field
12:00:00-EDT-Field
10:15:00-EDT-Field
14:00:00-EST-Field
14:30:00-EDT-Field
12:45:00-EST-Field
11:00:00-EDT-Field
13:30:00-EDT-Field
12:45:00-EST-Field
14:00:00-EDT-Field
14:00:00-EST-Field
13:00:00-EDT-Field
10:00:00-EDT-Field
13:30:00-EST-Field
09:35:00-EDT-Field
13:20:00-EDT-Field
13:35:00-EST-Field
09:08:00-EDT-Field
12:45:00-EDT-Field
16:25:00-EDT-Field
13:25:00-EDT-Field
10:30:00-EST-Field
13:15:00-EDT-Field
12:05:00-EDT-Field
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
Msr/Obs-0.1
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-m
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
-Dissolved
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
oxygen
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved -Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved-Actual
(DO) -Dissolved -Actual
(DO) -Dissolved -Actual
(DO) -Dissolved-Actual
-13.5
-4
-9.8
-6.6
-6.5
-4.6
-8.8
-5.9
-5.5
-7.4
-8.8
-8.6
-4.7
-5.9
-11.3
-4.8
-9.4
-7.4
-8.4
-12.6
-5.3
-8
-11.4
-5.7
-8.2
-4.9
-7.3
-8.9
-6.4
-6
-13.5-mg/
-4-mg/1
-9.8 -mg/3
-6.6 -mg/3
- 6.5 -mg/3
-4.6 -mg/3
-8.8 -mg/3
--5.9-mg/ ]
-5.5-mg/3
-7.4-mg/3
-8.8-mg/3
-8.6-mg/3
-4.7 -mg/J
-5.9-mg/3
-11.3-mg/
-4.8-mg/3
-9.4-mg/3
-7.4 -mg/3
- 8.4-mg/3
-12.6-mg/
-5.3-mg/3
-8-mg/1
-11.4-mg/
- 5.7 -mg/3
- 8.2 -mg/3
-4.9-mg/3
-7.3--mg/3
-8.9-mg/3
-6.4-mg/]
-6-mg/1
2 of
5/18/2005 10:49 AM

Total Phosphorus
lb
Summer 5533 0.5 mg/I
Winter 7808 1.0 mg/I
Equivalent concentrations
Flow Summer Winter
MGD mg/I mg/I
7.2 0.43 0.86
8 0.39 0.78
9.3 0.33 0.67
9.8 0.32 0.63
10 0.31 0.62

BOD 5 mg/I NH3N 2mg/I
Flow Equivalent concentrations Flow Equivalent concentrations
MGD mg/I MGD mg/I
7 4.4 7 1.8
7.2 4.3 7.2 1.7
8 3.9 8 1.5
9.3 3.3 9.3 1.3
9.8 3.2 9.8 1.3
10 3.1 10 1.2

Yadkin River Basin
Subbasin: 30707
Waters with impaired biological integrity.
Assessment
Waterbody and Description Unit (AU)
Year
Class Subbasin lmpairedUse Listed Category and Reason for Listing Potential Source(s) Miles Acres
Swearing Creek
12-113 C 30707 2004 6
14.4
From source to High Rock Lake, Yadkin River Aquatic Life 1. 2004 6 Impaired biological integrity: 1. Urban Runoff/Storm Sewers
stressors not identified
2. Agriculture
Abbotts Creek Arm of High Rock 12-118.5
Lake
WS-V&B 30707 2004 5 855.7
From source at 1-85 to Davidson County SR 2294
Aquatic Life 1. 2004 5 Standard violation: Low
Dissolved Oxygen
2. 2004 5 Standard violation: Turbidity
1. Major Municipal Point Source
2. Source Unknown
Abbotts Creek 12-119-(6) C 30707 2004 6 8.0
From upstream side of culvert at U.S. Hwys. 29 & 70 to Abbotts Creek Arm of High Rock Aquatic Life 1. 2004 6 Impaired biological integrity: 1. Source Unknown
Lake, Yadkin River (At 1-85 bridge) stressors not identified
Rich Fork 12-119-7 C 30707 1998 5
20.6
From source to Abbotts Creek Aquatic Life 1. 2004 5 Standard violation: Low
Dissolved Oxygen
2. 1998 6 Impaired biological integrity:
stressors not identified
3. 1998 5 Standard violation: Fecal
Coliform
Hunts Fork 12-119-7-3 C 30707 1998 6
1. Major Municipal Point Source
2. Urban Runoff/Storm Sewers
3. Urban Runoff/Storm Sewers
7.5
From source to Rich Fork
Hamby Creek
Overall 1. 1998 6 Impaired biological integrity: 1. Construction
stressors not identified
12-119-7-4 C 30707 1998 5
2, Urban Runoff/Storm Sewers
From source to Rich Fork
North Hamby Creek 12-119-7-4-1 C 30707
Aquatic Life 1. 5 Action level violation: Copper
2. 5 Historical listing decision:
Nutrients
3. 1998 6 Impaired bio!ogical integrity:
stressor study complete
1. Source Unknown
2. Major Municipal Point Source
1998 6 5.8
From source to Hamby Creek Aquatic Life 1. 1998 6 Impaired biological integrity: 1. Source Unknown
stressor study complete
Monday, April 26, 2004 North Carolina 303(d) Impaired Waters List-2004
Page 106 of 112
River Basin: Yadkin
Subbasin: 30707

Forest/Wetland
62%
The Division of Air Quality (DAQ) evaluates mercury levels in rainwater on a regular basis
through the EPA Mercury Deposition Network. EPA continues to focus on nationwide mercury
reductions from stack emissions and through pollution prevention efforts. Pollution prevention
efforts are being investigated on a state and federal level to reduce mercury emissions.
4.9 Management Strategy and Recommendations for the High Rock Lake
Watershed
Located on the mainstem of the Yadkin River in Rowan and Davidson counties, High Rock Lake
is the largest and most upstream of the Yadkin -Pee Dee chain lakes. Completed in 1929, the
reservoir was constructed to provide hydroelectric power and is owned and operated by Yadkin
Division of APGI. The 3,850-square mile watershed lies within seven subbasins (03-07-01
through 03-07-07). Figure C-4 on page 279 presents a map of the entire High Rock Lake
watershed. Water quality concerns for High Rock Lake date back to the mid-1970s, and the need
for nutrient reduction strategies to address problems due to accelerated eutrophication has been
apparent since the mid-1990s.
4.9.1 Watershed Overview
The High Rock Lake watershed had an estimated population of 723,100 in 1990. Winston-
Salem is the largest urban area; however, significant amounts of population are also located in
Thomasville, Lexington and Salisbury along I-85, and in Statesville. Portions of 11 counties and
34 municipalities are located in the watershed. Although more than 60 percent of the High Rock
Lake watershed is forested, 30 percent is described as pasture or managed herbaceous land and
nearly three percent is urban (Figure A-20).
Satellite -Generated Land Cover for the High
Rock Lake Watershed (1993-1995)
Water
1.1%
'%/ice •ir%//,,,
I
Cultivated
4.2%
Ire/Managed
,rbaceous
30.1%
Urban
2.6%
Figure A-20 Percentages within Major CGIA Land Cover Categories in the High Rock Lake
Watershed (Subbasins 03-07-01 through 03-07-07) (1993-1995)
Although numerous tributaries enter the lake, the Yadkin and South Yadkin Rivers account for
more than 90 percent of the total inflow. Average daily flows in the Yadkin River mainstem
Section A: Chapter 4 - Water Quality Issues Related to Multiple Watersheds in the Yadkin -Pee Dee River Basin 107
r.il oA& oo3

above the lake normally exceed 3,000 cubic feet per second. Detention time is relatively short,
with estimates ranging from about 15 to 30 days (EPA, 1975; Weiss et al., 1981; NCDENR-
DWQ, 1997a). These estimates exclude periods of extended low flow, such as those experienced
in the basin in recent years.
The waters of the lake are classified WS-V upstream of a line connecting the downstream sides
of Crane Creek and Swearing Creek. Below this line, the lake is classified as WS-IV & B,
except for the upper half of the Abbotts Creek arm (above SR 2294), which is classified as WS-V
& B. Additionally, the area within 0.6 miles of the dam is classified as CA due to the presence
of the water supply intake for the Town of Denton a short distance below the dam. No drinking
water is withdrawn directly from the reservoir, although Salisbury's water supply intake is
located at the confluence of the Yadkin and South Yadkin Rivers, just upstream of the
headwaters of the reservoir. In addition, Color/Tex Finishing and Duke Power's Buck Steam
Station withdraw process and cooling water from the upper portion of the lake.
The watershed contains 76 registered animal operations; 68 of them (89 percent) are cattle
facilities. A large percentage of the state's total capacity for dairy production (both registered
and unregistered facilities) is found within the High Rock Lake watershed, mostly in Iredell
County. However, dairy production in the watershed fell 27 percent between 1994 and 1998 and
continues to decline. Poultry production increased 13 percent over the same four-year period.
There are 155 individual NPDES permitted dischargers in the watershed, 23 of which are major
facilities that have a permitted flow of one million gallons per day (MGD) or more. Of the 126
MGD discharge capacity in the watershed, about 93 percent, or 117 MGD, is from the major
facilities presented in Table A-40. Eight facilities discharge directly to the lake or to streams in
the immediate proximity. The City of Salisbury WWTP and ColorTex Finishing discharge to the
Yadkin River at the head of High Rock Lake. Additionally, Duke Power's Buck Steam Station
discharges cooling water into the upper portion of the reservoir. Lexington's discharge to
Abbotts Creek and Salisbury's Sowers Ferry Road WWTP (minor) on Grants Creek are in close
proximity to the lake. Other minor discharges in close proximity are the Hilltop Living Center,
Norfolk Southern Corp. and PPG Industries, Inc.
4.9.2 Summary of Historical Monitoring and Modeling Studies
Studies by DWQ (NRCD-DEM, 1974, 1975) and the EPA (EPA, 1975) in the mid-1970s
documented eutrophic conditions in High Rock Lake for the first time. The EPA -sponsored
research, conducted as part of the National Eutrophication Survey, indicated that High Rock
Lake was the most eutrophic of the 16 North Carolina lakes studied in 1973. In 1981, a study by
the University of North Carolina at Chapel Hill (Weiss et al., 1981) documented high nutrient
loading to the lake as well as high levels of chlorophyll and in -lake nutrients. An intensive
investigation of the lake by DWQ in 1989 and 1990 (NCDEHNR-DEM, 1993) provided
additional data to allow a detailed evaluation of the reservoir and to support water quality
modeling. On -going monitoring (e.g., NRCD-DEM, 1988, 1989; NCDEHNR-DEM, 1992a;
NCDENR-DWQ, 1997b, June 2002) indicates that the lake continues to exhibit eutrophic
conditions.
Section A: Chapter 4 - Water Quality Issues Related to Multiple Watersheds in the Yadkin -Pee Dee River Basin 108

Table A-40 Major NPDES Permitted Dischargers in the High Rock Lake Watershed (2001)
NPDES
Permit No.
Company/Facility
Name
County
Type of
Discharge
Receiving
Stream
MGD
Subbasin
NC0005266
Louisiana Pacific
ABT Co. Mill
Wilkes
Industrial
Process
Yadkin River
1.0
03-07-01
NC0020761
Town of North
Wilkesboro WWTP
Wilkes
Municipal
Yadkin River
2.0
03-07-01
NC0021717
Town of Wilkesboro
WWTP
Wilkes
Municipal
Yadkin River
4.9
03-07-01
NC0005312
West Point Stevens
Surry
Industrial
Process
Yadkin River
4.0
03-07-02
NC0020338
Town of Yadkinville
WWTP
Yadkin
Municipal
North Deep Creek
2.5
03-07-02
NC0020567
Town of Elkin WWTP
Surry
Municipal
Yadkin River
1.8
03-07-02
NC0021121
City of Mount Airy
WWTP
Surry
Municipal
Ararat River
7.0
03-07-03
NC0026646
Town of Pilot Mountain
WWTP
Surry
Municipal
Ararat River
1.5
03-07-03
NC0037834
City of Winston-Salem
Archie Elledge WWTP
Forsyth
Municipal
Salem Creek'
30.0
03-07-04
NC0050342
City of Winston-Salem
Muddy Creek WWTP
Forsyth
Municipal
Yadkin River
21.0
03-07-04
NC0005487
Color/Tex Finishing
Corporation
Rowan
Industrial
Process
High Rock Lake'
4.25
03-07-04
NC0023884
City of Salisbury
Grants Creek WWTP
Rowan
Municipal
High Rock Lake'
7.5
03-07-04
NC0004774
Duke Energy Corp.
Buck Steam Station
Rowan
Industrial
Process
High Rock Lake'
No
Limit
03-07-04
NC0004286
Fieldcrest Cannon
Rowan
Industrial
Process
Grants Creek'
03-07-04
NC0004944
Arteva Specialties
KOSA
Rowan
Industrial
Process
Second Creek
2.3
03-07-06
NC0005126
Tyson Foods Inc.
Harmony Plant
Iredell
Industrial
Process
Hunting Creek
1.7
03-07-06
NC0024872
Davie County
Cooleemee WWTP
Davie
Municipal
South Yadkin River'
1.5
03-07-06
NC0020591
City of Statesville
Third Creek WWTP
Iredell
Municipal
Third Creek'
4.0
03-07-06
NC0031836
City of Statesville
Fourth Creek WWTP
Iredell
Municipal
Fourth Creek'
4.0
03-07-06
NC0024112
City of Thomasville
Hamby Creek WWTP
Davidson
Municipal
Hamby Creek'
4.0
03-07-07
NC0024228
City of High Point
Westside WWTP
Davidson
Municipal
Rich Fork'
6.2
03-07-07
NC0055789
City of Lexington WWTP
Davidson
Municipal
Abbotts Creek'
5.5
03-07-07
A portion of this waterbody is currently rated Impaired.
Section A: Chapter 4 - Water Quality Issues Related to Multiple Watersheds in the Yadkin -Pee Dee River Basin 109

The nutrient response model BATHTUB was applied to High Rock Lake in the mid-1990s.
BATHTUB was developed by the US Army Corps of Engineers (Walker, 1986, 1985a, 1985b) to
simulate eutrophication in spatially segmented reservoirs. BATHTUB is a steady state empirical
lake model which predicts average in -lake nutrient and algal levels based upon phosphorus and
nitrogen loading, turbidity and detention time.
The objectives of DWQ's modeling effort were: 1) to estimate nutrient loading to High Rock
Lake; 2) to assess the assimilative capacity of the reservoir for phosphorus and nitrogen; and 3)
to develop a predictive tool that could be used to evaluate the potential impacts of alternative
management strategies on nutrient and algal levels in the lake.
The modeling effort focused on growing season (May -September) loading and algal response
and yielded extensive information regarding nutrient loads to the lake. However, attempts to
develop an adequately calibrated nutrient response model were less successful. While the model
adequately predicts phosphorus levels in key areas of the lake, such as the mainstem and the
Abbotts Creek Arm, chlorophyll a levels are predicted very poorly throughout the lake. Potential
reasons for this are discussed in the modeling report (NCDENR-DWQ, 1997a).
4.9.3 Management Strategy and Recommendations from the 1998 Basin Plan
Phosphorus is the limiting nutrient in most freshwater systems. Nitrogen generally becomes
limiting in freshwaters only under extremely eutrophic conditions (Welch, 1992). Under
nitrogen limiting conditions, N-fixation by blue-green algae may encourage the dominance of
blue-green algae over other algal groups and stimulate the growth of noxious blooms. For this
reason, where lakes have elevated levels of both nitrogen and phosphorus, reductions in
phosphorus rather than nitrogen have generally been recommended (Welch, 1992; Thomann and
Mueller, 1987). While both nitrogen and phosphorus are routinely present in High Rock Lake in
concentrations high enough to support algal blooms, management strategies focus on reducing
phosphorus concentrations in order to limit algal growth. The main body of High Rock Lake
was rated Support Threatened at the time of the 1998 basin plan. Therefore, priority was placed
on tributary watersheds that were rated Impaired.
Abbotts Creek Arm
The 1998 basin plan recommended that each of the three major dischargers in the Abbotts Creek
watershed (High Point, Thomasville and Lexington) receive summer mass Total Phosphorus
limits based upon current permitted flow capacity and a Total Phosphorus concentration of 0.5
mg/l. The limits would go in effect for the permit cycle that begins in 2004. In order to reduce
phosphorus loading in the shorter term, facilities were required to conduct an operation and
maintenance assessment in order to identify methods of optimizing phosphorus removal with
existing facilities. The plan also recommended that existing minor facilities be required to
monitor total phosphorus and nitrogen concentrations and that no additional phosphorus loading
would be permitted (individual NPDES permits for discharges containing phosphorus).
Other Arms
The only major NPDES discharges into the Grants Creek and Crane Creek arms were the two
WWTPs operated by the City of Salisbury. The 1998 basin plan discusses Salisbury's plans to
build a new outfall on the Yadkin River mainstem and the elimination of the two discharges into
Section A: Chapter 4 - Water Quality Issues Related to Multiple Watersheds in the Yadkin -Pee Dee River Basin 110

Town and Grants Creeks when the new outfall became operational. The management strategy
states that these facilities would not receive nutrient limits as long as the City of Salisbury was
proceeding in good faith with construction of the new outfall. Other recommendations were for
the Town of Spencer to connect to a regional WWTP. Spencer was required to conduct an
engineering assessment to identify ways of optimizing phosphorus removal with current
facilities.
Main Body of Lake
The 1998 basin plan also strongly recommends that the local governments (Davidson and Rowan
County health departments) work with the Division of Environmental Health to identify failing
on -site systems and to develop or strengthen outreach and education efforts regarding the
operation and maintenance of these systems. Additionally, lake shore property owners were
encouraged to establish and maintain adequate riparian buffers. The plan also expresses support
for the efforts of Yadkin Division of APGI to maintain vegetated areas around High Rock Lake
as recommended in its Shoreline Management Plan. DWQ planned to investigate the feasibility
of developing a nutrient reduction strategy for the watershed and consider reclassifying the lake
as Nutrient Sensitive Waters.
4.9.4 Current Status
Eight stations on High Rock Lake were monitored by DWQ in 1999, 2000 and 2001. Surface
dissolved oxygen concentrations were elevated at most of the sampling sites, and the associated
percent dissolved oxygen saturation ranged from 148 to 157 percent; the water quality standard is
110 percent. Surface pH values were also elevated, suggesting increased algal productivity.
Decreased transparency due to suspended sediments in the water column is also common in High
Rock Lake. Turbidity concentrations in the Abbotts Creek and Crane Creek arms, as well as the
main body of the lake, were greater than water quality standards in more than 10 percent of
samples collected. In addition, transported sediment has reduced the depth of the upper end of
the lake such that at low flow periods, the uppermost sampling site can no longer be reached by
boat. In addition to reducing the clarity of the lake water, these sediments also contribute
nutrients.
High Rock Lake was determined to be eutrophic again in 2001. Blue-green algae species,
commonly found in eutrophic waters and often associated with taste and odor problems in
drinking water, dominated samples collected in July and August 1999. As has been observed in
previous years, total phosphorus and total organic nitrogen concentrations were high. These
nutrients continued to support increased algae productivity as evidenced by chlorophyll a values
greater than the state water quality standard of 40 ug/1.
Increased monitoring of High Rock Lake over the most recent assessment period has allowed
DWQ to determine that the lake is Impaired. The decision is based on high levels of nutrients,
combined with chlorophyll a, turbidity and percent dissolved oxygen saturation in excess of state
standards. Low dissolved oxygen and high turbidity in the Abbotts Creek and Town Creek Arms
are also contributing to aquatic life impairment.
Section A: Chapter 4 - Water Quality Issues Related to Multiple Watersheds in the Yadkin -Pee Dee River Basin 111

Phosphorus limits, as outlined in the 1998 management strategy summary above, were placed in
the most recent NPDES permits issued to the Lexington, Thomasville and High Point WWTPs in
the Abbotts Creek watershed to become effective at the time of renewal in 2004. As a result of
this strategy, summer point source loads of total phosphorus to the Abbotts Creek arm are
projected to decline to one fifth of 1994-96 levels. Ambient phosphorus levels are projected to
decline by 30 to 40 percent in the upper portion of the Abbotts Creek arm and by 20 to 25
percent in the middle portion of the arm. It is anticipated that this will lessen the incidence and
severity of nuisance conditions in the lake, but these actions may not completely resolve
eutrophication issues in the Abbotts Creek arm.
The Town of Spencer connected to the City of Salisbury WWTP, eliminating one discharge to
Grants Creek. The City of Salisbury constructed a new WWTP which discharges to the Yadkin
River in the upper reaches of High Rock Lake, eliminating one discharge to Grants Creek and
one discharge to Town Creek. In addition, steps have already been taken to prioritize the High
Rock Lake watershed for nonpoint source pollution reduction measures.
4.9.5 2002 Recommendations and Management Strategies
The current NPDES permits for the High Point Westside WWTP, Thomasville WWTP and
Lexington WWTP outline mass -based summer and winter discharge limits for total phosphorus,
which will be required beginning in 2004. No new NPDES permitted discharges will be
permitted into the Abbotts, Swearing, Grants and Crane Creek arms of High Rock Lake. No
increase in loading will be permitted for existing NPDES discharges into these same arms. Other
existing discharges (in addition to the three major discharges mentioned above) will receive
notification that discharge limits for total phosphorus may be required in the future.
A percent DO saturation TMDL for High Rock Lake will require the development of both a
nutrient response model and a watershed loading model. DWQ staff will begin review of
existing monitoring locations, frequency and parameters in preparation for designing a TMDL
field study for High Rock Lake and the upper Yadkin River basin. DWQ will focus on
developing and conducting the field study during this basinwide planning cycle. The field study
will likely require 18 months to complete. The Yadkin -Pee Dee River Basin Association (details
on page 296) has expressed interest in modeling the High Rock Lake watershed. DWQ will
continue to work with the association to understand and manage this complex watershed.
DWQ will continue to place priority on developing TMDLs for streams in the High Rock Lake
watershed. TMDLs for fecal coliform in the Fourth Creek and Grants Creek watersheds have
been approved by the USEPA; and in the case of Fourth Creek, plans to implement the TMDL
are being developed. Fecal coliform TMDLs are underway in the Salem Creek and Rich Fork
watersheds as well. Strategies used to reduce fecal coliform concentrations in these watersheds
will also help reduce nutrient and sediment loading to the upper portion of the basin, and
ultimately High Rock Lake.
In addition, DWQ will work more closely with other agencies that set priorities for nonpoint
source pollution reduction in the Yadkin -Pee Dee River basin, such as the NC Wetlands
Restoration Program, NC Division of Soil and Water Conservation, and USDA Natural
Section A: Chapter 4 - Water Quality Issues Related to Multiple Watersheds in the Yadkin -Pee Dee River Basin 112

Re: High Point Spec limits
Subject: Re: High Point Spec limits
From: Steve Tedder <[e-mail]>
Date: Tue, 25 Jan 2005 09:12:50 -0500
To: Teresa Rodriguez <[e-mail]>
CC: Mark Mcintire <[e-mail]>, Dave Goodrich <[e-mail]>
Teresa,
I realize that Rich Fork has has some historical DO problems. I believe the work to
date indicates the problems to be associated with upstream areas of the watershed.
Form most situations in smaller streams like this, especially one that responds so
drastically to rainfall, DO increases with increased flow.
The bigger picture is that we have been working with High Point for some time to
substantially upgrade the Westside WWTP and to do major repair and replacement on the
collection system. They are at a point where they are ready to spend over $20M on
the sewers rehab and that much on the upgrade of the facility. To keep them moving
the right direction they need additional flow to allow payment on the expenditures
for the repairs.
I hope we will look at the big picture. Its real easy to see a stream problem,
mention it in a basin report, even put it on a 303d list and not really have to deal
with the consequences of real life. I hope we will look everything before we decide
not to allow expansion.
Steve
On 1/24/2005 11:20 AM, Teresa Rodriguez wrote:
{
Steve, I started working with the High Point request and I found a letter sent to
them in 1996 regarding a similar request for speculative limits (9.3 MGD and 12
MGD). At the time a QUAL2E model was developed and it showed that Rich Fork Creek
had no assimilative capacity for additional waste flow even if they treated to
advance tertiary limits. I also reviewed recent instream data and the creek still
has low DO problems and is rated as impaired for DO. We can't give them speculative
limits for 10 MGD if the same conditions prevail.
Teresa
Steve Tedder <Steve.Tedder a,NCmail.net>
NC DENR
WSRO
1 of 1 2/8/2005 7:35 AM

Re: High Point
Subject: Re: High Point
From: Steve Tedder <[e-mail]>
Date: Wed, 12 Jan 2005 07:39:50 -0500
To: Teresa Rodriguez <[e-mail]>
CC: [e-mail], Dave Goodrich <[e-mail]>
Thanks Teresa,
It is very important that we assist in getting this request out. Alan and Coleen have
all been involved concerning EPA on this facility regarding issued 308 and 309
letters from EPA. We have been working closely with them for some time regarding
upgrading the plant and expansion to handle ww flows.
Anything you can do to bump this one up some would be appreciated. The town and their
consultants can do little more relating to design until these spec limits are
received. Please cc me when the spec limits letter goes out.
Thanks
Steve
On 1/11/2005 2:18 PM, Teresa Rodriguez wrote:
The High Point project was recently reassigned to me. I am finishing another
speculative limits request and will move on to the High Point request soon.
Teresa
Steve Tedder <Steve.Tedder u,NCmail.net>
NC DENR
WSRO
1 of 1 2/8/2005 7:35 AM

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dmp
DAVIS-MARTIN-POWELL & ASSOCIATES, INC.
ENGINEERING • LAND PLANNING • SURVEYING
6415 Old Plank Road, High Point, NC 27265
[phone] • Fax [phone] • www.dmp-inc.com
November 17, 2004
Re: City of High Point, N.C.
Westside Wastewater Treatment Plant
NPDES Permit No. NC0024228
DMP Project E-3647 "` -..,-. ,....,:r
Mr. Dave Goodrich
NPDES Permit Unit
N.C. Dept. of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Goodrich:
This past July Ed Powell, on behalf of the City of High Point, sent a letter to .you requesting
speculative discharge limits be prepared for the expansion and upgrade of the City's Westside
Wastewater Treatment Plant. At that time the City was also in the process of applying for a Special
Order by Consent for relaxed effluent discharge limits in the interim to assist in easing the violations
that had been occurring at the Westside Plant.
Since that time the Westside WWTP has returned to compliance with their current NPDES permit and
Winston-Salem Regional Office has determined that an SOC is not needed. In addition, due to the
delay in the issuing of the City's new NPDES permit until later this year the WSRO has indicated that
the City should continue to operate the facility under the existing expired NPDES permit until the new
permit is issued.
The City of High Point's concern and one of the main reasons for applying for an SOC is their inability
to meet the new proposed mass limits for phosphorus. As indicated in the attached letter from the
City of High Point, a phosphorus removal system was designed and constructed at the Westside
WWTP and put into service in 1998. The purpose of the phosphorus removal system was to provide
a means of achieving less than 2 mg/L of effluent phosphorus.
A recent study has been completed analyzing the phosphorus numbers back through the summer of
1999 utilizing mass limit calculations. As the attached spreadsheet shows, when mass limit numbers
are applied the City would not have been able to meet the phosphorus effluent limit for any of the
summer periods from 1999 through 2004 and would have not been able to meet the phosphorus
mass limit for one of the winter periods during that same time period.
Based on this study the City of High Point is requesting that the current method for tracking
phosphorus effluent limits (monthly mg/L) continue to be applied to the speculative discharge limits

Mr. Dave Goodrich
NPDES Permit Unit October 4, 2004 Page 2
during the Westside Plant expansion. This would provide the City the opportunity to continue to
monitor and meet the existing phosphorus monthly effluent limit of 2.0 mg/L. Based on review of
monthly discharge reports for the Westside WWTP from January 2002 through May 2004 the City
feels confident in meeting this effluent limit versus the proposed mass limit for phosphorus. Once the
plant expansion is complete in late 2008, the City feels it would be able to be in complete compliance
with changes to effluent monitoring for phosphorus when their permit is renewed in 2009.
Davis -Martin -Powell & Associates and the City of High Point appreciate your cooperation with this
matter and we look forward to working with you on this project.
If you have questions or if we can provide additional information regarding this process, please let us
know.
Sincerely,
DAVIS-MARTIN-POWELL & ASSOCIATES, INC.
iii,ei,,./.°„34i1,
Michael P. Goliber, PE
MPG/mpg
C: Mr. Perry Kairis
Mr. Terry Houk
Mr. Steve Mauney
File
P:IPROJEC7lE3647IDOCIWestsideWWTP-Goodrich Phosphorus.doc

Phosphorus Mass Loadings
Summer 1999
Summer 2000
Summer 2001
Summer 2002
Summer 2003
Summer 2004
Winter 99-00
Winter 00-01
Winter 01-02
Winter 02-03
Winter 03-04
8,083
9,695
9,156
9,834
11,921
4,907
J
6,777
5,017
5,125
4,871
E. 8,085
Summer
0.5 mg/L
6.2 MGD Permitted Flow
8.34 Ibs of water
25.854 Ibs per day of phosphorus
214 number of days in Summer months
Does not inlcude Aug, Sept or Oct 5,533 Lbs., Mass Limit
Winter
1 mg/L
6.2 MGD Permitted Flow
8.34 Ibs of water
51.708 Ibs per day of phosphorus
151 number of days in Winter months
7,808 Lbs., Mass Limit
Davis -Martin -Powell Associates
Westside Phosphorus.xls - Sheetl E-3647 - 10/27/2004

CITY OF HIGH POINT
NORTH CAROLINA
Terry Houk
Assistant Public Services Director
City of High Point
Tim Fitzgerald
Westside WWTP
City of High Point
RECEIVED
OCT 13 2004
DIRECTOR OF PUBLIC SERVICES
Subject: Westside Phosphorus
Removal Improvements
In 1996 Davis -Martin -Powell & Associates, Inc. completed a Plant design study at
Westside. The design improvements included a phosphorus removal system using liquid
alum. The alum feed facility construction began in 1997 and was put into service in 1998.
The alum feed facility consists of a precast concrete building housing three Pulsa Feeder
variable speed chemical feed pumps. These are positive displacement diaphragm type
with a SCR drive control using a 4-20 mA signal. The system automatically starts and
stops pumps and varies flow rates based on changes in plant flow rates through the use of
an Allen-Bradley SLC 500 PLC.
The alum is stored in two 13,150 gallon cylindrical tanks with heat tracing on the lower
quarter of each tank to maintain the tank contents at 40 degrees F at ambient temperatures
of-10 F.
Liquid alum is fed into the diversion box at the effluent end of the aeration basin with the
intent to achieve less than 2mg/L of effluent phosphorus.
The most recent studies on phosphorus and phosphorus removal are included with this
data.
10/ 11 /04
PUBLIC SERVICES DEPARTMENT, P.O. Box 230, 211 S. HAMILTON STREET, HIGH POINT, NORTH CAROLINA 27261 TELEPHONE [phone] FAX [phone] TDD 336-883-8517

Sample Location:
CITY OF HIGH POINT
NORTH CAROLINA
Central Laboratory Services
U..\csv.s,4 e -o S-9lnoroUS c. > a
L.)
Date of Sample: - f --�" Time: d'a:t..) s us By: Terri ' L
Sample Type:
W as�•¢wa}��
Received in Lab by:
CL- 5
Results reported by:
Special Handling Instructions:
To: t' F I --r F
Grab: Composite: •'�
Date: `—r Time:
Date: °1- a - `1g
ANALYSES
Y/N
DATE
ANALYZED
ANAL
VALUE
UNITS
_
ANALYSES
Y/N
DATE
ANALYZED
ANAL
VALUE
UNITS
BOD
AAS - ALUMINIUM
SUS. SOUDS
MS - CALCIUM
TOT. SOLIDS
MS - CADMIUM
DIS. SOLIDS
AAS - CHROMIUM
DISSOLVED OXYGEN
-
MS - COPPER
MF FECAL COLIFORM
AAS - IRON
MF TOTAL COUFORM
AAS - LEAD
HPC •
AAS - MAGNESIUM
COULERT
AAS-MANGANESE
ODOR & TASTE
•
MS - NICKEL
i'EMPERATURE
MS - POTASSIUM
RESIDUDAL Cl2
_
MS - SODIUM
PH
AAS - ZINC
COD
AAS - SILVER
ALKALINITY
GFAAS - CADMIUM
HARDNESS
•
GFAAS - CHROMIUM
CONDUCTIVITY
GFAAS - COPPER
•
SPECIFIC GRAVITY '
GFAAS - LEAD
BULK CHEMICAL
GFAAS - NICKEL
,
TURBIDITY
GFAAS - SILVER
FLUORIDE
_
GFAAS - ARSENIC
GFAAS - SELENIUM
SETTLEABLE MATTER
TOC •
TOTAL PO4-P
j
5 is
c.1C
----�-
mil&
GCIMS - TTHMS
Ortho PO4-P
GC/MS 624 1
TKN
NH3-N
ACUTE BIOASSAY
NO3 + NO2
CHRON. BIOASSAY
NO2
•
PLANKTON
LAKE PROFILE
,
PUBLIC SERVICES DEPARTMENT, PO Box 230, High Point. North Carolina, 27261
Telephone [phone] FAX [phone] TDD (° 10) 883-8517

Criteria
Westside WWTP Phosphorus - Design Criteria
Required Effluent Phosphorus 2.00 mg/L
Average Influent
Maximum Influent
6.15 mg/L
8.69 mg/L
Design for Worst Case 9.54 mg/L P
Average Effluent
Maximum Effluent
Remove 7.54 mg/L, or 79.0% Removal
At Design flow of 6.2 MOD = 390 lb/d P
per MOP-8 use 16:1 Alum to P ratio
or 6,239 lb/d Alurn
or 562 gpd Alum Solution
or 23.4 gph Alum Solution
4.08 mg/L
9.54 mg/L
Phosphorus Removed, mg/L
Flow, mgd
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
4.0
8.3
12.5
16.7
20.9
25.0
29.2
33.4
37.5
5.0
10.4
15.6
20.9
26.1
31.3
36.5
41.7
46.9
6.0
12.5
18.8
25.0
31.3
37.5
43.8
50.0
56.3
7.0
14.6
21.9
29.2
36.5
43.8
51.1
58.4
65.7
8.0
16.7
25.0
33.4
41.7
50.0
58.4
66.7
75.1
9.0
18.8
28.1
37.5
46.9
56.3
65.7
75.1
84.4
10.0
20.9
31.3
41.7
52.1
62.6
73.0
83.4
93.8
11.0
22.9
34.4
45.9
57.3
68.8
80.3
91.7
103.2
12.0
25.0
37.5
50.0
62.6
75.I
87.6
100.1
112.6
13.0
27.1
40.7
54.2
67.8
81.3
94.9
108.4
- -' '1220
14.0
29.2
43.8
58.4
73.0
87.6
102.2
116.8
131,4:
15.0
31.3
46.9
62.6
78.2
93.8
109.5
125.1
1407
16.0
33.4
50.0
66.7
83.4
100.1
116.8
133.4
150_1:
17.0
35.4
53.2
70.9
88.6
106.3
124.1
141.8
159.5
18.0
37.5
56.3
75.1
93.8
112.6
131.4':
150.1
168.9
19.0
39.6
59.4
79.2
99.0
118.8
138.7
. 158.5
178.3
20.0
41.7
62.6
83.4
104.3
125 1
146.0,
166,8
t 87.7
21.0
43.8
65.7
87.6
109.5
131.4
153.2
175.1
197.0
22.0
45.9
68.8
91.7
114.7
137.6
160.5
183.5
206.4
23.0
48.0
71.9
95.9
- 119.9
143.9
167.8
191.8
215.8
24.0
50.0
75.1
100.1
125.1
150.1
175.1
200.2
225.2
One Feed Pump @ 58.3 gph
Two Feed Pumps
Three Feed Pumps
Impossible to Feed. •
Page 1

BLACK & VEATCH
8520 Cliff Cameron Drive
Suite 350
Charlotte, North Carolina 28269
Tel: [phone]
Fax [phone]
Mr. Tim Fitzgerald
Westside WWTP
P.O. Box 230
High Point, North Carolina 27261
Dear Mr. Fitzgerald:
Black & Veatch International Company
September 15, 2003
Enclosed please find one copy of the paper we discussed last week, "Strategies for
Meeting Decreasing Phosphorus Limits: Survey and Case Studies of WWTPs Operating
for Phosphorus Removal". Thank you for participating in the survey and providing
information about your facility. The paper will be presented at the annual NC
AWWA/WEA conference in Greensboro this November.
Please contact me at [phone] if you have any questions.
Very truly yours,
BLACK & VEATCH
INTERNATIONAL COMPANY
Enclosure
ONPP-DiAdeatipg6
Mary P. Bonislawsky
Project Engineer
the imagine • build company"'

STRATEGIES FOR MEETING DECREASING PHOSPHORUS LIMITS: SURVEY AND
CASE STUDIES OF WWTPs OPERATING FOR PHOSPHORUS REMOVAL
Chris deBarbadillo and Mary Bonislawsky, Black & Veatch
Pete Goins, Charlotte -Mecklenburg Utilities
Steve Geary, Cobb County Water System
ABSTRACT
In response to water quality concerns, a number of wastewater treatment plants (WWTPs) in North Carolina, South
Carolina and Georgia have undergone upgrades for total phosphorus (TP) removal. In North Carolina, five of the
seventeen River Basins are highlighted due to nutrient sensitive waters (NSW) including the Catawba, Yadkin, Cape
Fear, Neuse, and Tar -Pamlico river basins.
Considering the South Carolina in -stream phosphorus standards of 0.06 mg/L, the North Carolina in -stream
phosphorus standards of 0.05 mg/L, and the ongoing water quality and total maximum daily load (TMDL) work, the
ability to produce lower WWTP effluent phosphorus is an important area of study for plants in the region. As TP
limits drop below 1 mg/L, filters are often included as part of the treatment scheme. To meet very low limits of less
than 0.2 mg/L, a final polishing step such as tertiary clarification with lime addition or ballasted flocculation is
sometimes incorporated. However, with increased operating experience at low phosphorus limits, many plants are
achieving excellent results without tertiary facilities.
The focus of this paper is to survey North Carolina WWTPs currently operating for phosphorus removal to obtain
information on the phosphorus removal processes utilized and typical process performance. Case studies presenting
the current operation of two WWTPs operating for phosphorus removal also will be discussed. The Northwest
Cobb WRF in suburban Atlanta, Georgia is successfully achieving phosphorus removal to <0.2 mg/L through
chemical precipitation while the McDowell Creek WWTP in Charlotte, North Carolina operates a biological
phosphorus removal process to achieve similar effluent quality. The reliability of the phosphorus removal process,
operational challenges, and chemical addition strategies will be presented.
KEYWORDS
Wastewater treatment, Phosphorus, Biological Nutrient Removal (BNR), Nutrient Sensitive Waters (NSW)
INTRODUCTION
In the late 1980s, North Carolina established a water quality management program focused on each of the State's 17
river basins. DWQ updates the management plan for each river basin every 5 years based on extensive data from
water quality sampling. The plans contain available information on basin characteristics, current water quality, and
management strategies for protecting or improving water quality. Five NC River Basins are highlighted in this paper
due to NSW. They are the Catawba River basin, Yadkin River basin, Cape Fear River basin, Neuse River basin, and
Tar -Pamlico River basin. Summary information taken from the Water Quality Plan for each basin (NCDENR,
1999; 2000; 2001; 2003) is included in the following sections.

Catawba River Basin
The Catawba River basin, along with the Broad River basin, forms the headwaters of the Santee -Cooper River
system. This river system begins on the eastern slopes of the Blue Ridge Mountains in NC, flows through the NC
piedmont to the NC -SC border near Charlotte, and continues to flow through SC to the Atlantic Ocean. The basin
contains the Linville River, one of only four state designated Natural and Scenic Rivers. The mainstem of the
Catawba River is regulated by a series of seven hydropower reservoirs.
With the tremendous growth occurring within this basin, there are significant challenges ahead in balancing growth
with the restoration and protection of water quality in this basin. Point source impacts to the surface waters of the
basin are measured and addressed through basinwide planning. A number of WWTPs in the lower Catawba River
Basin have been issued TP limits to reduce nutrient loading to the reservoirs.
Nonpoint sources of pollution can be identified through basinwide planning, but actions to address these impacts
must be taken at the local level. According to State basinwide planning, such actions should include: development
and enforcement of water supply watershed ordinances more stringent than state requirements; development and
enforcement of buffer ordinances along tributaries, shorelines and the Catawba River; requirement of stormwater
best management practices for existing and new development; development and enforcement of local erosion
control ordinances; and land use planning that assesses impacts on natural resources. The basinwide plan presents
many water quality initiatives and accomplishments that are underway within the basin. These actions provide a
foundation on which future initiatives and successes can be built.
Yadkin River Basin
The Upper Yadkin Basin is the most densely populated portion of the basin, and includes Winston-Salem,
Statesville, Salisbury, Lexington, and the western portion of High Point. The Upper Yadkin Basin also has the most
significant .industrial dischargers. The Upper Yadkin Basin has several reservoirs, with High Rock Lake being the
largest reservoir. High Lock Lake has high nutrient levels, and eutrophication of High Rock Lake is the primary
focus of nutrient strategies in this basin. The current NPDES permits for the High Point Westside WWTP,
Thomasville WWTP, and Lexington WWTP outline mass -based summer and winter discharge limits for total
phosphorus, which will be required beginning in 2004. No new or expanded NPDES discharges will be permitted
into the Abbotts, Swearing, Grants and Crane Creek arms of High Rock Lake. Other permitted discharges, in
addition to the three above, will receive notification that discharge limits for total phosphorus may be required in the
future.
The Lower Yadkin Basin is mush less densely populated and much more forested than the Upper Yadkin. The
Lower Yadkin includes sprawl from Charlotte in Concord, Kannapolis, Mint Hill and Monroe.
Cape Fear River Basin
The Cape Fear River Basin is the state's largest river basin. The most populated regions of the basin are in and near
the Triad area (Greensboro -Burlington -High Point), the Durham -Chapel Hill area and Fayetteville. Nutrient over
enrichment is a continuing potential source of impairment to the waters in the Jordan Reservoir watershed. The
Clean Water Responsibility Act (House Bill 515) was enacted in 1997 to further address ongoing problems
associated with waters classified as NSW. The Act sets limits for TP and TN to NSW waters. The limits apply to
facilities discharging more than 0.5 mgd that were in operation or had authorization to construct prior to July 1, 1997
and all facilities issued authorization to construct after that date.
In November 1998, waters in the proposed Randleman Reservoir watershed were reclassified to WS-1V CA. Rules
have been adopted (15A NCAC 2B .0248 through .0251) to help prevent potential water quality problems in the
proposed reservoir. The rules address point source discharges by not allowing new or expanding discharges into the
watershed except for High Point Eastside WWTP. This facility will have to relocate its outfall and meet stringent
phosphorus limits established to protect water quality standards. The rules also address nonpoint source pollution in

the Randleman Reservoir watershed with management strategies that maintain and protect riparian areas and require
urban stormwater programs to be developed by local governments having land use authority in the watershed.
Neuse River Basin
Water quality has been an issue in the Neuse River Basin for over a century. Eutrophication became a major
concern during the 1970s. In 1983, the EMC classified the Falls Lake watershed as NSW. As a result of this
reclassification, all new and expanding facilities greater than 0.05 mgd discharge in the Falls Lake watershed
received effluent limits of 2 mg/L total phosphorus (TP) and existing facilities were given until January 1, 1990 to
comply. In 1988, the EMC classified the remainder of the Neuse River Basin as NSW. As a part of the new
classification, point source discharges greater than 0.5 mgd and new facilities were given total phosphorus limit of 2
mg/L. Facilities were also put on notice that more stringent controls may be required in the future. DWQ specified
that nitrogen loading from nonpoint sources should be controlled through the Agricultural Cost Share Program.
In December 1997, the EMC adopted the Neuse River Basin NSW Management Strategy. Most of the rules that are
part of the strategy became effective in August 1998. For the first time in the state history, mandatory controls•are
applied not only on point source pollution but also on nonpoint source pollution in the Neuse River basin. The
strategy is aimed at reducing the average annual load of nitrogen delivered to the Neuse River Estuary from point
and nonpoint sources by a minimum of 30 percent of the average annual load from the period 1991 through 1995 by
the year 2004.
Tar -Pamlico River Basin
Following a record -setting year of reported fish kills in 1989, the EMC classified the Tar -Pamlico River Basin as
NSW. In 1989, the EMC approved a NSW Implementation Strategy for the basin. As a part of this strategy an
association of the dischargers in the basin, the Tar -Pamlico Basin Association (the Association), agreed to fund a
nutrient reduction trading program. Members of the Association included the following facilities: Belhaven, Bunn,
Enfield, Franklin Water and Sewer Authority, Greenville, Louisburg, Oxford, Pine Tops, Rocky Mount, Spring
Hope, Tarboro, Warrenton, Washington, and National Spinning. The Nutrient Reduction Trading Program allows
association facilities the option to achieve DWQ's nutrient reduction goal by funding other more cost-effective
nutrient reduction measures rather than paying for costly expansions and upgrades to their waste water treatment
facilities.
WASTEWATER TREATMENT PROCESS CONSIDERATIONS
There are a number of process options for phosphorus removal. Some particulate phosphorus is removed during
primary settling. Hydrolysis of much of the remaining particulate phosphorus and utilization of some soluble
phosphorus for bacterial growth occurs in conventional biological treatment processes. To further reduce
phosphorus, chemical precipitation or biological phosphorus removal are normally implemented.
With a good quality secondary effluent, tertiary filtration provides a margin of safety but is generally not required to
meet a phosphorus limit of 1 mg/L. However, as phosphorus limits decrease, filters are often included as part of the
treatment scheme. To meet very low limits of less than 0.2 mg/L, a final polishing step such as tertiary clarification
with lime addition or ballasted flocculation is often incorporated.
As phosphorus limits decrease, it becomes increasingly difficult to meet the average effluent limit with even one day
of higher phosphorus discharge. Although a number of plants can achieve low phosphorus concentrations without a
tertiary treatment step, it is often desirable to incorporate one for reliability and to provide a margin of safety.
However, the cost can be substantial. Therefore, the ability to achieve low effluent phosphorus concentrations
reliably without a tertiary treatment step is an area of development as more plants gain experience with phosphorus
removal.

SURVEY OF NORTH CAROLINA WWTPs OPERATING FOR PHOSPHORUS
REMOVAL
In order to gain a better understanding of the current approach toward phosphorus removal in North Carolina, a
telephone survey of plants was conducted. The state does not currently keep a database searchable by type of limit,
so plants included in the survey were selected on the basis of capacity and discharge location. Of the more than
1,500 NPDES permitted dischargers in North Carolina, it is estimated that 146 are municipal plants that have a
capacity of greater than 1 mgd. Since phosphorus limits are normally implemented for receiving waters that have
been classified as nutrient impaired, the list of 146 WWTPs was further screened to include those plants that
discharge to the Catawba River basin, Upper Yadkin River basin, Upper Cape Fear River basin, Neuse River basin,
and Tar-Pamilico River Basin. In addition, other major WWTPs either known to have phosphorus limits, or with
capacity greater than 5 mgd also were included in the survey.
The survey questions were geared toward confirming the plant capacity and current flow rates, phosphorus limit and
averaging period, phosphorus removal process, other major liquid stream processes, and typical effluent phosphorus.
In total, 87 plants were surveyed. Of these, twenty-eight currently have phosphorus limits, five are part of the Tar
Pamlico Association and operate for a target effluent phosphorus of 1 mg/L, and three are currently under
construction to upgrade for phosphorus removal. The results are summarized in Table 1.
Table 1
North Carolina WWTPs Operating for Phosphorus Removal
Summary Survey Results
Plant Rated
Capacity
(87 total)
36 were
greater than
1 mgd but
less than 5
mgd
22 were
greater or
equal than 5
mgd but less
than 10 mgd
29 were greater or
equal to 10 mgd
Phosphorus
removal process
(33 total)
10 use
chemical
precipitation
only
13 use bio-P
only
10 use a
combination of bio-
P and chemical
precipitation
Biological
Phosphorus
removal
(23 total)
3 operate for
bio-P only,
without
nitrogen
removal
11 operate a
3-stage BNR
process
(includes
anoxic zones)
18 operate without
VFA
supplementation to
the anaerobic zones
1 uses chemical
VFA
supplementation
4 use
fermentate or
other
"internal"
source of VFA
Chemical
Precipitation
(20 total, including
use of chemical as
a backup to bio-P)
1 added
metal salt for
odor control
13 use alum
2 use polyaluminum
chloride
2 use sodium
aluminate
2 unconfirmed
•
Major liquid stream
processes
(33 total)
18 operate
primary
clarifiers
33 operate an
activated
sludge process
0 operate a fixed
film process
17 have UV
disinfection
25 have filters
Phosphorus limits
(or target)
_
20 have a
limit of 2
mg/L
8 have a limit
of 1 mg/L
5 have a limit of 0.5
to 1 mg/L
2 have speculative
limits of <0.5 mg/L
Current Effluent
Phosphorus
Concentration
9 achieve an
effluent TP
of I to 2
mg/L
4 achieve an
effluent TP of
0.5 to 1 mg/L
10 achieve an
effluent TP of 0.2 to
0.5 mg/L
3 achieve an
effluent TP of 0.2
mg/L or lower
Of 13 plants
with effluent
TP of 0.5
mg/L or lower,
11 have filters

CASE STUDY — CHEMICAL PHOSPHORUS REMOVAL
The Northwest Cobb WRF, located northwest of Atlanta, Georgia is owned and operated by the Cobb County Water
System (CCWS). The plant was expanded from 4-mgd to 8-mgd in 1998, and consists of an influent pumping
station, bar screens, aerated grit chambers, primary clarifiers, activated sludge system, secondary clarifiers, traveling
bridge filters, ultraviolet disinfection and cascade post aeration. Primary and waste activated sludge can be
aerobically digested and dewatered with belt filter presses. The current operation for solids handling includes using
a section of the aerobic digesters for sludge holding, and dewatering the raw sludge for landfill disposal. Northwest
Cobb has the capability to operate in several biological nutrient removal configurations but found that the most
optimal mode is operation of the activated sludge system for nitrification only, with ferrous chloride and/or alum
addition for phosphorus precipitation. The plant is currently treating approximately 7-mgd average daily flow.
After commissioning of the 8-mgd expanded plant, operation for biological phosphorus removal was tested.
However, it was necessary to add chemical to the dewatering filtrate and/or at the plant headworks for odor control
reasons. Since metal salts such as ferrous chloride were being used for this purpose, significant phosphorus
precipitation also was being achieved making biological phosphorus removal unnecessary. Therefore, Northwest
operates the activated sludge system for BOD removal and nitrification only, and removes phosphorus through
chemical precipitation. A schematic and typical operating profile of phosphorus concentrations are shown in Figure
Figure 1. Northwest Cobb WRF Chemical Phosphorus Removal Schematic
Plant Influent
OP = 1.5 to 2 mg/L
TP = 6 to 8 mg/L
--t—i."
Influent
Raw PS
Primary Effluent
OP = 0.5 to 1 mg/L
TP=3to4mg/L
WAS
Final Effluent
TPeff = <0.15 mg/L
Filters
Effluent
Northwest Cobb has had excellent performance over the past five years, including AMSA gold awards in 2001 and
2002. By feeding the ferrous chloride to the plant headworks with alum trim to the secondary clarifiers, effluent
phosphorus concentrations have averaged well below 0.2 mg/L for the past several years. Ferrous chloride and
alum are normally targeted at approximately equal dosages (in gallons), but are varied depending on activated
sludge settling characteristics and the current cost of ferrous chloride and alum. Average chemical dosages for the
past several years are summarized in Table 2.

Table 2
Northwest Cobb WRF Chemical Dosages for Phosphorus Removal
Year
Average Flow
(mgd)
Average Effluent
Phosphorus
(mg/L)
Chemical
Dose
(gal/day)
2001
6.2
0.13
Ferrous Chloride
250
Alum
265
2002
6.4
0.16
Ferrous Chloride
400
Alum
75
2003
7.1
0.08
Ferrous Chloride
200
Alum
430
Notes:
1) Ferrous chloride strength is 1 lb/gal as Fe`+
2) Alum strength is 49% as alum
During 2002 Cobb County implemented a supplemental sampling program to provide additional characterization of
the influent wastewater and decide whether the plant expansion to 12 mgd would incorporate chemical or biological
phosphorus removal. These additional data revealed the following:
• The influent readily biodegradable COD is relatively low at 12% of total COD (typical value is about
20%).
• There is little volatile fatty acid (VFA) material in the influent wastewater or primary effluent. VFAs are
the carbon substrate utilized in biological phosphorus removal.
• The influent OP/TP ratio is about 0.2 (OP averaged less than 2 mg/L). Typically the OP represents at least
half the TP. With this low OP/TP ratio, Northwest Cobb has lower than average soluble phosphorus and
higher than average particulate phosphorus concentrations. With a low influent OP, good TSS (and
particulate P) removal in the primary clarifiers, and some OP removal resulting from the ferrous chloride
addition, very little phosphorus remains in the primary effluent for biological phosphorus removal.
Northwest Cobb WRF plans to continue operation for nitrification with chemical phosphorus removal. Because of
the low influent OP and lack of VFAs, conditions for biological phosphorus removal are not favorable, and chemical
addition had the lowest present worth cost for phosphorus removal for the expansion to 12-mgd.
As part of two recent revisions to the NPDES permit, the effluent phosphorus limit for Northwest Cobb was reduced
from 0.6 mg/L to 0.23 mg/L monthly average. To optimize and ensure reliable operation at this low phosphorus
limit, as well as obtain additional information on plant performance, CCWS installed a Chemscan online analyzer in
April 2003 to obtain real-time measurements of effluent phosphorus and ammonia. In combination with tracking of
chemical dosages through the plant SCADA system, the plant staff can follow phosphorus trends and make
adjustments more quickly if needed. The plant is operated for a target effluent phosphorus concentration of 0.1
mg/L. Since much of the historical data shows effluent phosphorus concentrations at the method detection limit of
0.1 mg/L, the laboratory lowered the method detection limit to 0.05 mg/L in November 2002. Since that time,
effluent phosphorus concentrations below 0.1 mg/L have frequently been recorded (Figure 2).

1
0.9
0.8
0.7
"Eh
E
ui 0.6-
a
0
a 0.5
0
a 0.4
H 0.3
0.2
0.1
0
0 a 0 0 a a a .- v- .-
O A O 0 0 0 O 0 0 0 O a
O CD 00 f, f0 sr grf tt M
O 0 el N N N N N N N CV
a=CI
d CO CO O hD co OD O
0 0 0 0 0 .- .- 0 0 0 0 .-
Figure 2. Northwest Cobb WRF Effluent Phosphorus
January 2000 through June 2003
•
•
FY 2001 Average = 0.13 mglL TP
— FY 2002 Average = 0.16 mglL TP
FY 2003 Average = 0.10 mg/L TP
♦
Monthly Average TP Limit = 0.6 mg/L
r 1
• mglL
-30 per. Mov. Avg. (mglL)
!--
•
-+
•
•
--4- -.- ---*-- •
•
•
♦ -•—
t
•
•
•
•
•♦♦•4•
•• ♦;.•*• •
• • • •♦ • ••
• • •
• •
7..• _
•
Monthly Average
TP Limit = 0.23
mglL
4•
•
0 0 0 0 0 0 0 0 0 0
N e0- 0
40 1
!- 0 0 0 0 ? O 0 0
CASE STUDY — BIOLOGICAL PHOSPHORUS REMOVAL
The McDowell Creek WWTP is owned and operated by Charlotte -Mecklenburg Utilities (CMU). In 1999, the plant
was upgraded to BNR to reduce nutrient loads to Mountain Island Lake, one of the City of Charlotte's drinking
water supplies. McDowell can operate several three -stage BNR processes for total nitrogen and total phosphorus
removal, including UCT, modified OWASA, and the CNC processes. Other treatment units include preliminary
treatment facilities, primary clarifiers, deep -bed denitrification filters, ultraviolet disinfection, and cascade aeration.
Primary sludge and WAS are anaerobically digested and dewatered with belt filter presses.
Since BNR operation began in 1999, the plant staff have experimented with the different BNR modes. The TN limit
of 10 mg/L was easily met, but achieving reliable biological phosphorus removal was initially more difficult.
McDowell had several operating challenges related to phosphorus removal process performance, including a
relatively "fresh" wastewater (no VFA), high phosphorus levels in the dewatering filtrate stream, and co -settling of
waste activated sludge with primary sludge because WAS thickening facilities were constructed later in a separate
project. However, using an optimized combination of chemical addition, dewatering filtrate equalization, and a
unique supplemental carbon source, this plant has maintained an average of 0.2 mg/L effluent phosphorus for the
past two years and won AMSA gold awards for 2001 and 2002.
Impact of Dewatering Filtrate and Co settling of WAS in Primary Clarifiers
As discussed above, McDowell operates anaerobic digesters for biosolids stabilization and solids reduction. The
filtrate produced during dewatering of the digested sludge is high in both ammonia and orthophosphorus. Since
dewatering is carried out on a weekday shift basis, this resulted in very high phosphorus loads to the BNR process
during the day. To equalize the phosphorus load, the filtrate is directed to an equalization basin and pumped back to
the plant over a 24-hour period.

Until construction was completed for separate thickening facilities, it was necessary to co -settle the WAS with the
influent wastewater in the primary clarifiers prior to directing it to the digesters. Solids removal efficiencies in the
primary clarifiers were as high as 79 percent. However, because WAS is mixed with influent wastewater, it is
suspected that uptake of readily biodegradable carbon material (rbCOD) and subsequent release of orthophosphorus
was occurring (Table 3), also contributing to very high loads to the BNR process. Gravity belt thickeners were
commissioned in August 2002 and co -settling was discontinued at that time.
Table 3
Impact of Dewatering Filtrate and Co -settling of WAS
on McDowell WWTP BNR Influent Phosphorus
Location
Flow
Phosphorus
Concentration
Phosphorus Load
Plant Influent
4.68 mgd average
6.5 mg/L as TP
3.68 mg/L as OP
253 lbs/day
Dewatering Filtrate
45,000 gpd to 65,000 gpd
75 to 150 mg.L
28 to 81 lbs/day
Observed Primary Effluent
4.68 mgd average
12 mg/L
476 lbs/day
Calculated Primary Effluent based
on filtrate only
N/A
7.2 to 9 mg/L
281 to 354 lbs/day
Estimated OP Release from WAS
N/A
3 to 5 mg/L
122 to 195 lbs/day
Optimization of Chemical Dosages
McDowell has very little influent VFA, and it is necessary to supplement VFA to the anaerobic zones. However,
even with significant acetic acid addition, the BNR process effluent TP could creep above 1 mg/L at times. The
plant experimented with chemical dosing locations and found on the basis of operations reliability and cost, that
addition of alum to the primary clarifiers to reduce the phosphorus load from the filtrate and co -settled WAS is the
most economical solution (Table 4).
Table 4
McDowell Creek WWTP Comparison of Chemical Dosage Requirements and
Costs for Phosphorus Removal
Dosage Location
Chemical
Quantity
Cost •
Anaerobic Zones
Acetic Acid
1,200 to 2400 gal/day
$985/day
(full scale testing)
BNR Effluent Mixed
Liquor
Alum
400 gal/day
$125/day
(full scale testing)
Plant Influent
Alum
300 gal/day
$93/day
(full-scale testing)
Dewatering Filtrate
Alum
200 gal/day
$62/day
(based on jar testing)
To further reduce chemical costs, CMU decided to test a soft drink bottling waste sugar water as an alternate VFA
source. From November 2000 to February 2001, sugar water addition was piloted in one full-scale treatment train,
while acetic acid addition was continued in the second treatment train. Nearly equal operating results were observed
for both chemicals (Wagoner and Goins, 2001). McDowell has continued to use the waste sugar water as a

supplemental VFA source with excellent results. Currently, the available sugar water supply does not quite meet the
total VFA requirement at the plant, so the balance is made up with acetic acid as needed. The net savings is
approximately $150,000 per year (Goins, 2002).
In summary, the McDowell Creek WWTP has overcome some unique operating challenges with respect to
phosphorus removal, and consistently produces an effluent of excellent quality. Although the plant operates filters,
it is noted that there is no chemical addition to the filter influent, and the secondary effluent and fmal effluent quality
are similar. The McDowell effluent phosphorus concentration has been well under the permit limit of 1 mg/L
monthly average, and averaged Tess than 0.26 mg/L from July 2000 to June 2001 and less than 0.14 mg/L from July
2001 to June 2002 (Figure 3). It is noted that there are many values less than or equal to the laboratory method
detection limit of 0.1 mg/L. The plant is likely frequently below this value.
CMU plans to expand the plant to 12-mgd in the next few years. Speculative permit limits issued in early 2003
reflect a dramatic decrease in the effluent phosphorus limit, reducing it from 1 mg/L monthly average to 0.27 mg/L
monthly average during summer months, and 0.32 mg/L monthly average during the winter season. Because of the
plant's excellent performance with respect to phosphorus removal, it is expected that McDowell will meet these
limits without additional processes for phosphorus removal.
Phosphorus, mg/L
1.6
1.4
1.2
1
0.8
0.6
0.4
0.2
0
a-.
0
c1
r
a~"
SUMMARY
Figure 3. McDowell Creek WWTP Effluent Phosphorus
January 2001 through December 2002
•
• Effluent TP (mg/L)
2001 Average = 0.20 mg/L
--30 per. Mov. Ayg. (Effluent TP
2002 Average = 0.14 mg/L
•
(mg/L))
♦ •
Current Monthly Average P Limit =1
•
•
•
• •
•
• •
• •
• • •
•• • • •
• •
• • •
12 mgd Speculative Avg. P Limit = 0.27 mg/L
* .I A •
• A,‘",s,
:411
✓
0
0
N
ti
r N
0 0
N N
✓ • r
r
N
0
N
r
M
N
a
N
0
0
N
T.
ti
N
0
N
r
s.
M
N
The reliability of the phosphorus removal process to achieve lower WWTP effluent phosphorus is an important area
of study in light of regional water quality concerns. Of 33 North Carolina plants with phosphorus limits surveyed,
15 have limits of 1 mg/L and lower, and several anticipate limits below 0.5 mg/L. The plants are equally divided
with respect to the selected phosphorus removal process, with 10 operating for chemical phosphorus removal only,
13 operating for biological phosphorus removal only, and 10 operating with a combination of biological and

chemical phosphorus removal. One plant selected chemical phosphorus removal due to concurrent use of metal salts
for odor control in the collection system or plant headworks.
The plant influent characteristics play an important role in determining whether chemical precipitation or biological
phosphorus removal are the most economical. For plants such as Northwest Cobb, where the influent OP is low and
little VFA is available as substrate for biological phosphorus removal, chemical precipitation is likely the best
choice. In addition, if a metal salt is added for odor control reasons, the plant likely will obtain some phosphorus
precipitation as an additional benefit.
Although there were some initial challenges during startup of the McDowell plant after its BNR upgrade in 1999,
the biological phosphorus removal process performance and operating costs have been successfully optimized.
Although there is little influent VFA, approximately 55% of the influent phosphorus is in the form of OP, and if
phosphorus were removed by chemical means only, the dosages would be much higher than observed for the
Northwest Cobb plant. By dosing alum in an optimal location and making use of an inexpensive, innovative carbon
source, this plant achieves reliable and economical phosphorus removal.
REFERENCES
Goins, P., 2002. "A Sweet Alternative", Proceedings of Water Environment Federation Pre -Conference Seminar —
Carbon Augmentation for BNR, Chicago, IL, September 2002.
North Carolina Department of Environment and Natural Resources (NCDENR). 1999. "Tar -Pamlico River
Basinwide Water Quality Plan", Division of Environmental Management, Raleigh.
North Carolina Department of Environment and Natural Resources (NCDENR). 1999. "Catawba River Basinwide
Water Quality Plan", Division of Environmental Management, Raleigh.
North Carolina Department of Environment and Natural Resources (NCDENR). 2000. "Cape Fear River Basinwide
Water Quality Plan", Division of Environmental Management, Raleigh.
North Carolina Department of Environment and Natural Resources (NCDENR). 2001. "Neuse River Basinwide
Water Quality Plan", Division of Environmental Management, Raleigh.
North Carolina Department of Environment and Natural Resources (NCDENR). 2003. "Yadkin River Basinwide
Water Quality Plan", Division of Environmental Management, Raleigh.
Wagoner, D.L. and Goins, P., 2001. "Soft -Drink Solution for Biological Phosphorus Removal", Proceedings of
Annual Meeting of the NC AWWA/WEA, Pinehurst, NC, November 2001.

CITY OF HIGH POINT
lJU
6 1
NOV
NOV 6 20 1 2004
DENR - WATER QUALITY
POINT SOURCE BRANCH
November 12, 2004
Re: Westside Wastewater Treatment Plant
NPDES Permit No. NC0024228
DMP Project E-3647
Mr. Dave Goodrich
NPDES Permit Unit
NCDENR — DWQ
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Goodrich:
As you may be aware, the City is moving forward with the planning and design of an upgrade and
expansion to the Westside Wastewater Treatment Plant. Recently, in July 2004, Davis -Martin -Powell
& Associates requested, on our behalf, speculative limits for this upgrade and expansion.
In September, the City selected the team of Hazen and Sawyer, PC and Davis -Martin -Powell &
Associates to perform the planning and design of this project. After meeting with our Engineers, we
would like to again request speculative limits based upon an expanded capacity of 10.0 MGD.
The City has experienced compliance problems at this facility and has put together an aggressive
schedule for this upgrade. It is our intent to complete design in the summer of 2005 and immediately
go to construction thereafter. The City has also issued revenue bonds for the design and construction
of this wastewater treatment plant.
As you know, receiving the speculative limits is critical to meeting this schedule, and we really need
your department's assistance in expediting this request so the design is not delayed any longer.
If you have questions, or need additional information, please let us know.
Sincerely,
PerA. Kairis, PE
Director Public Services
Cc: Michael L. Slusher, DMP
Steve Tedder, DWQ
P.O. Box 230, 211 S. HAMILTON STREET, HIGH POINT, NORTH CAROLINA 27261 FAX [phone] TDD 336-883-8517

[Fwd: Re: High Point]
AJCo2'I22'K
Subject: [Fwd: Re: High Point]
From: Steve Tedder <[e-mail]>
Date: Mon, 08 Nov 2004 09:39:34 -0500
To: Charles Weaver <[e-mail]>
Not sure what EPAs problem is but here is my response to Alan on the 309
Original Message
Subject:Re: High Point
Date:Thu, 28 Oct 2004 07:30:08 -0400
From: Steve Tedder <Steve.Tedder@ ncmail.net>
Organization:NC DENR - Division of Water Quality, Water Quality Section
To:Alan Klimek <alan.klimek@ ncmail.net>
CC:Steve Mauney <[e-mail]>
References:<[e-mail]>
Alan,
Below is a response I sent Bob Sledge on 9/3 concerning High Point Westside. The
bottom line is that the Westside plant is now compliant and we have relayed that
message to EPA for the past couple months. At our urging in August, they did
develop an SOC request and requested relaxed limits on everything in their permit
until their upgraded facility is complete. By that time the facility was compliant and to
get an SOC you need to be violating the permit conditions. We returned the SOC
request to them and they agreed it was not necessary. I think EPA is working off old
information and for whatever reason, they are on they 308/309 track and can;t seem to
understand that the facility is compliant.
Steve
Bob,
High Point Westside has had some problems lately but about a month ago Steve
Mauny and I paid them a visit and talked about the possibility of a moratorium. I
think it got their attention. They brought in Sonja and Dwight Lancaster to help do
some technical assistance and operational trouble shooting and I'm told they have
been compliant for July and August. They have not requested an SOC yet and
personally I do not think one is justified. They are planning an expansion from 6.3
to 9.2 and are interviewing firms this week. Once they get their new permit (goes to
Abbotts) they will have a "P" limit for the first time. this will be true whether they
were to expand or not as per the TMDL on Abbotts Creek. They would need an
SOC for the Phos limit as they will require construction to meet that limit. The
1 of 3 11/8/2004 9:57 AM

[Fwd: Re: High Point]
permits for this area of the state will probably be issued between now and
December 2003 or sometime after that (who knows when). My suggestion would
be to include two sets of limits in the permit if they are far enough along with their
expansion request. If they are not far enough along with the expansion then we
could go with an SOC for phos at that time.
In summary I think progress has been made on the compliance end and that an SOC
is not the answer. As for the Watch List ?? not sure we can alter EPAs thoughts.
AS far as I'm concerned I think swift enforcement is the key and if they go back to a
stretch of non-compliance we need to consider a moratorium. Steve
On 9/2/2004 9:37 AM, Bob Sledge wrote:
Hi Steve,
Lisa Uhl from Region IV is trying to reconcile the latest Watch List prepared by the
EPA and asked about High Point Westside. When we replied to them last time, we
told EPA we would be in discussions with the City regarding the potential for a
SOC. Has any progress been made on this front and do we expect to see a SOC for
the facility in the future?
Thanks for any information you can provide that can be passed on to our friends in
Atlanta.
On 10/27/2004 4:08 PM, Alan Klimek wrote:
Jim Giattina called me today to give me a heads up that they are sending a letter to
have High Point come in and talk to them at a show cause meeting as a follow-up to
their 309 letter. He asked me if we've entered into an SOC. I said I thought one was
in the works but I wasn't aware that it had been finalized (at least I don't remember
signing one for them). If one is in the works, perhaps they'll bring a draft to their
meeting.
Steve Tedder
NC DENR Winston-Salem Regional Office
Division of Water Quality, Water Quality Section
585 Waughtown Street
Winston-Salem, NC 27107
2 of 3 11/8/2004 9:57 AM

DWQ POINT SOURCE Fax: [phone]
T ranam i -t Conf. Report *�c
Nov 8 2004 9:39
**
P. 1
Fax/Phone Number
Mode
Start
Time
Page
Result
Note
[07] WSRO
NORMAL
8, 9:39
0'51"
4
1 0 lE
/V ,cA. Wra4fek at cry. ej 4e pia
flkS UNr U Ltr STATES ENVIRONMENTAL ,ROTfc 1ION AGENCY(
MErit4N a �ty off rw arr.
lV/L ATI ANTA FEDERAL CENTER it 1�f� f / l
s 6 I FORSYTH NI HLE f "� )
rrl nuirc.` ATLAN i A. ornnr;IA io,z,-sseo
CERTIFECD MAD -NUMBER 7004 1160 0002 5174 7566
RPM /RN RECEIPT REQUESTED
City of High Point
c/o Mr. Perry A. k aids, P E , Director of Z'ublic Services
Putt Office Buy 2301
H.tghi Point, North CarnlinA 77.761
i
SUBJ: Noticc of Sbiow Cause
City of High Point - We.rside WWTP
NPDES Permit No. NCU024228
t c u Mi. Kama.
Nov 0 ' 200*
my. OF WATER QUALITY
. 'TOR'S OFFI''C
ET i= f 2134
toi?),„\vialea
•
! .
/19'''5/-
f/d
Oct July 16, 2:004,. the United Statcs Lnvironuicntal Protection Agency (LYA) notified the
City of iTigh Point (the City), pursuant to Secdon 309 of the Clean Water Act, 31 U.S.C. 4 1319,
of EPA's findings lli fl the City had violated ita Naticuaal Pollutant Discharge Eliuvuatton System
(Nl'1.1LS)1'rnniT Niiimher NC002422R for the We!:tside Wastewater Treatment Pilaw (WWTP).
Additionally, EPA it yti csted i» a sepaiate July 16. 2004 conicspondence that tiae City, pursuant
to Section 308 of the Clean Warm Act, 31 T.1 S !' § 111 S, provide information concerning the
Wcgtsidc WWTP um' the City'a weatcwatct culloutiui, system. '1.hc (.'ity responded to IliPA's
infutivauoli recluent n Aiigust 3, 2004.
EPA has nnmrlered it., review of the City'u August 3, 2004 ccaponse which coufirtwcd
vinlntions of the NPDES permit for tlic sWestside WWTP. Sut h vinlntinnn Are stihject to
cam:meat action piirmant to Section 309 of the Clean Water Act (CWA) which tinovidcs for
thc issuAnrc nf.compliance orders, adirtuDisttative ar,ttous to a$%res penalties, and$or thc initiation
of civil ur urittuna►l towns.
EPA's July 14, 20114 Notice of Violation also informed you that EPA irtsy teh,C
tmlurcrarent action in the event the violatioxit :ire nut apytupiiatcly scsolved thrrugb a0
enforcement actiun by thc State ot.North Carolina within thirty (30) dar. it iu EPA'a
understanding that, tp date, the State of Nuiilr Carolina has not taken netinn to ruldre s the
viniationt. Ab + result, LI'A is offrrinp,1hr. (^.iry an opportunity tv dier:uas the violation; and to
show cause why F.PA should nut initialc au cAturccullcnt action. EPA rcirpirssta that
representatives uI tJtc City nnme.. Tn nur office in Atlanta on'Iuetalay, Duxilibai. 7, 2004 at fir„
:00 p.m. (EST) to discue6 the violations and EPA's possible cnforcr-ment action. In licu of
�- sppenring in EPA's ofticc for this meeting, a trlrphone conference maybe scheduled. The City
should provide all information wit h,dncument:itiun tcicvatat to any position thc City may take
Intorna: t dd e3e (ur .) • hap.//www..ara onv
iitI.TI I ►i�it�� 1bj,It •MIa.tDJ wth Velma*::14 Rasar. tn, n : for ria i•Moi s+oitn.mue i . . ✓caeonarl it
•

rr, q4 ju.iv(. Wi4roje4- a cry•
r C4
Tha' co/vt- / nt. t
UNITED STATES ENVIRONMENTAL PROTECTION AOENC ;'/ ,; ,.nay moor'..�.
',r /2/7)
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-896C)
CERTIFIED MAIL NUMBER 7004 1160 0002 5174 7566
RETURN RECEIPT REQUESTED
City of High Point
c/o Mr. Perry A. Kairis, P.E., Director of Public Services
Post Office Box 230
High Point, North Carolina 27261
SUBJ: Notice of Show Cause
City of High Point - Westside WWTP
NPDES Permit No. NC0024228
Dear Mr. Kairis:
NOV 0 -) 2004
D1V. OF 'WATER QUAUT'(
Ofi,FCTORS OFFICE
rOCT 2$2CM
On July 16, 2004, the United States Environmental Protection Agency (EPA) notified the
City of High Point (the City), pursuant to Section 309 of the Clean Water Act, 33 U.S.C. § 1319,
of EPA's findings that the City had violated its National Pollutant Discharge Elimination System
(NPDES) Permit Number NC0024228 for the Westside Wastewater Treatment Plant (WWTP).
Additionally, EPA requested in a separate July 16, 2004 correspondence that the City, pursuant
to Section 308 of the Clean Water Act, 33 U.S.C. § 1318, provide information concerning the
Westside WWTP and the City's wastewater collection system. The City responded to EPA's
information request on August 3, 2004.
EPA has completed its review of the City's August 3, 2004 response which confirmed
violations of the NPDES permit for the Westside WWTP. Such violations are subject to
enforcement action pursuant to Section 309 of the Clean Water Act (CWA) which provides for
the issuance of compliance orders, administrative actions to assess penalties, and/or the initiation
of civil or criminal actions.
EPA's July 16, 2004 Notice of Violation also informed you that EPA may take
enforcement action in the event the violations are not appropriately resolved through an
enforcement action by the State of North Carolina within thirty (30) days. It is EPA's
understanding that, to date, the State of North Carolina has not taken action to address the
violations. As a result, EPA is offering the City an opportunity to discuss the violations and to
show cause why EPA should not initiate an enforcement action. EPA requests that
representatives of the City come to our office in Atlanta on Tuesday, December 7, 2004 at
1:00 p.m. (EST) to discuss the violations and EPA's possible enforcement action. In lieu of
appearing in EPA's office for this meeting, a telephone conference may be scheduled. The City
should provide all information with documentation relevant to any position the City may take
err.`•+
Intemsi f•dares< ft'=.�; Y's :rv:r'. .bC ,
RecyciedTtecyciabie . Prime[ WF;i1 Veg iatie Oil Ease Inks or: F,6c;... c• ,r. as sr 3C`,i Pes:consumerj

2
during this meeting. Such relevant information and documentation may include any financial
information which may reflect the City's ability to pay a penalty. You have the right to be
represented by legal counsel. Please contact Ms. Yvonne Martin at [phone] within ten
(10) days of receipt of this letter to confirm this meeting or to set up a telephone conference.
Enclosed is a document entitled U.S. EPA Small Business Resources -Information Sheet
for your use and to assist you in understanding the compliance assistance resources and tools
available to you. However, any decision to seek compliance assistance at this time does not
relieve you of your obligation to EPA or the State, does not create any new rights or defenses,
and will not affect EPA's decision to pursue enforcement action. In addition, the Securities and
Exchange Commission (SEC) requires its registrants to periodically disclose environmental legal
proceedings in statements filed with the SEC. To assist you, EPA has also enclosed a document
entitled Notice of Securities and Exchange Commission Registrants' Duty to. Disclose
Environmental Legal Proceedings.
If you have any questions regarding this notice, please feel free to contact Ms. Martin.
David Y. Parker, Chief
Eastern Enforcement Section
Water Programs Enforcement Branch
Water Management Division
cc: Ms. Coleen Sullins
North Carolina Department of Environment and Natural Resources
Enclosures (2)

United States
-EPAEnvironmental Protection
Agency
Office of Enforcement and Compliance Assurance (2201A)
EPA 300-F-99-004 September 1999
EPASmall Business
f you own a small business, the United States Environmental Protection Agency (EPA) offers
a variety of compliance assistance and tools to assist you in complying with federal and State
environmental laws. These resources can help you understand your environmental obligations,
improve compliance and find cost-effective ways to comply through the use of pollution prevention
and other innovative technologies.
EPA Websites
EPA has several Internet sites that provide useful
compliance assistance information and materials for
small businesses. Many public libraries provide ac-
cess to the Internet at minimal or no cost.
EPA's Small Business Home Page (http://
www.epa.gov/sbo) is a good place to start because it
links with many other related websites. Other useful
websites include:
EPA's Home Page
http://www.epa.gov
Small Business Assistance Programs
http://www.epa.gov/ttn/sbap
Compliance Assistance Home Page
http://www.epa.gov/oeca/oc
Office of Site Remediation Enforcement
http://www.epa.gov/oeca/osre
Hotlines, Helplines and •
Clearinghouses
EPA sponsors approximately 89 free hotlines and
clearinghouses that provide convenient assistance
on environmental requirements.
EPA's Small Business Ombudsman Hotline can pro-
vide a list of all the hot lines and assist in determining
the hotline best meeting your needs. Key hotlines
include:
EPA's Small Business Ombudsman
[phone]
Hazardous Waste/Underground Tanks/
Superfund
[phone]
National Response Center
(to report oil and hazardous substance spills)
[phone]
Toxics Substances and Asbestos Information
[phone]
Safe Drinking Water
[phone]
Stratospheric Ozone and Refrigerants
Information
[phone]
Clean Air Technical Center
[phone]
Wetlands Hotline
[phone]
Recycled/Recyclable
�co Printed with Soy/Canola ink on paper that contains et least 30 % post consumer fiber

NOTICE OF SECURITIES AND EXCHANGE COMMISSION REGISTRANTS' DUTY TO DISCLOSE
ENVIRONMENTAL LEGAL PROCEEDINGS
Securities and Exchange Commission regulations require companies registered with the SEC (e.g..
publicly traded companies) to disclose, on at least a quarterly basis, the existence of certain
administrative or judicial proceedings taken against them arising under Federal, State or local provisions
that have the primary purpose of protecting the environment. Instruction 5 to Item 103 of the SEC's
Regulation S-K (17 CFR 229.103) requires disclosure of these environmental legal proceedings. For
those SEC registrants that use the SEC's "small business issuer" reporting system, Instructions 1-4 to
Item 103 of the SEC's Regulation S-B (17 CFR 228.103) requires disclosure of these environmental
legal proceedings.
If you are an SEC registrant, you have a duty to disclose the existence of pending or known to be
contemplated environmental legal proceedings that meet any of the following criteria (17 CFR
229.103(5)(A)-(C)): -
A. Such proceeding is material to the business or financial condition of the registrant;
B. Such proceeding involves primarily a claim for damages, or involves potential monetary
sanctions, capital expenditures, deferred charges or charges to income and the amount •
involved, exclusive of interest and costs, exceeds 10 percent of the current assets of the
registrant and its subsidiaries on a consolidated basis; or
C. A governmental authority is a party to such proceeding and such proceeding involves
potential monetary sanctions, unless the registrant reasonably believes that such
proceeding will result in no monetary sanctions, or in monetary sanctions, exclusive of
interest and costs, of less than S 100,000; provided, however, that such proceedings
which are similar in nature may be grouped and described generically.
Specific information regarding the environmental legal proceedings that must be disclosed is set
forth in Item 103 of Regulation S-K or, for registrants using the "small business issuer" reporting system,
Item 103(a)-(b) of Regulation S-B. If disclosure is required, it must briefly describe the proceeding,
"including the name of the court or agency in which the proceedings are pending, the date instituted, the
principal parties thereto, a description of the factual basis alleged to underlie the proceedings and the
relief sought."
You have been identified as a party to an environmental legal proceeding to which the United States
government is, or was, a party. If you are an SEC registrant, this environmental legal proceeding may
trigger, or may already have triggered, the disclosure obligation under the SEC regulations described
above. .
This notice is being provided to inform you of SEC registrants' duty to disclose any relevant
environmental legal proceedings to the SEC. This notice does not -create, modify or interpret any existing
legal obligations, it is not intended to be an exhaustive description of the legally applicable requirements
and it is not a substitute for regulations published in the Code of Federal Regulations. This notice has
been issued to you for information purposes only. No determination of the applicability of this reporting
requirement to your company has been made by any governmental entity. You should seek competent
counsel in determining the applicability of these and other SEC requirements to the environmental legal
proceeding at issue, as well as any other proceedings known to be contemplated by governmental
authorities.
If you have any questions about the SEC's environmental disclosure requirements, please contact
the Office of Chief Counsel in the SEC's Division of Corporation Finance. The phone number is (202)
942-2900.

Re: City of High Point (Westside)
Subject: Re: City of High Point (Westside)
From: Dave Goodrich <[e-mail]>
Date: Tue, 07 Sep 2004 13:22:26 -0400
To: Steve Tedder <[e-mail]>
CC: Coleen Sullins <[e-mail]>, Steve Mauney <[e-mail]>,
Susan Wilson <susan.a.wilson©ncmail.net>
Steve -
I agree with your approach. Let's see what justification they have for the delay and go from
there.
Dave
Steve Tedder wrote:
In March of 2000 High Point was issued an NPDES permit for the Westside WWTP. This
permit expired in April of 2004 and is not scheduled to be reissued until at least December
2004. The 2000 permit explicitly states that upon re- issuance of this permit in 2004, the
facility shall meet a Total P mass limit of 5533 pounds during the summer (April -October)
and 7808 pounds during the winter (November -March) But, as we all know things can
change and the 2004 permit has not been issued to date.
The City has approached us about an SOC as they evidently will not be able to achieve
the P limit when the permit is issued (assuming issuance in late 2004). My position is that
you have to be violating something to quality for an SOC and as of now they are not
violating the permit because its not even issued. The other option would be to include a
schedule in the permit for meeting the P limit and then some could argue they have had
over four years to get ready to meet that limit and that a schedule is not supportable.
That would then leave only the senario of issuing the permit, end enforcing the permit
when they violate the condition (since its Winter and Summer limits that means only two
compliance determinations per year) and after a period of non-compliance(which could be a
couple years) then we could entertain a request for an SOC.
My first suggestion is that we let them request the P limit be delayed via a schedule in the
permit and for them to justify in writing why this delay is justified and what they have done
over the last four years to meet the limit that is to be in the next permit. If they can justify,
to the Director, then to include as a schedule in the permit,
If the first suggestion is not appropriate, then I would suggest we just monitor compliance
with the new limit when the permit is issued and if noncompliance is an issue at that point,
take appropriate enforcement and then if the data suggest, we could entertain an SOC
request possibly a year of two after issuance.
I would not recommend an SOC for the P limit until such time as there are violations to
support a request for an SOC.
Any thoughts or guidance would be appreciated so I can forward to the City. This facility is
on the proposed EPA Watch List and it appears that past complianc issues have been
resolved and the facility compliant for July and August. The previous discussions
regarding and SOC were in relation to past compliance issues with BOD and TOX and
hopefully they are resolved. The SOC for Phos has been something the City has mentioned
in the past few weeks.
Thanks
Steve
Thanks
Steve
1 of 2 9/8/2004 4:58 PM

[Fwd: Re:.City of High Point (Westside)]
AicooLiy11-8
Subject: [Fwd: Re: City of High Point (Westside)]
From: Steve Tedder <[e-mail]>
Date: Wed, 15 Sep 2004 10:10:21 -0400
To: Dave Goodrich <[e-mail]>, Charles Weaver
<[e-mail]>
fYi
Original Message
Subject:Re: City of High Point (Westside)
Date:Mon, 13 Sep 2004 13:48:31 -0400
From: Steve Tedder <[e-mail]>
Organization:NC DENR - Division of Water Quality, Water Quality Section
To:perry Kairis <[e-mail]>
CC: Steve Mauney <Steve.MauneyAncmail.net>
References:<[e-mail]>
Perry,
During the last couple weeks Steve Mauney has been talking to Terry Houk and it was
my understanding that the facility is now compliant (July and August) and that
Technical Assistance work from Sonja Williams and Dwight Lancaster assisted in
addressing problems at the facility. Steve informed me that there were some recent
discussions about the upcoming P limit and the fact that there would be problems
meeting the new limit.
My recent correspondence to Raleigh was to inform them of the compliance situation
in an effort to get the City off the EPA Watchlist.
Today I received a request for an SOC from DMP that would relax the limits for BOD
(Winter and Summer), NH3 (Winter and Summer) DO, Fecal, Phos, and tox until the
upgrade is completed.
I think you can see my concern. On one hand I have argued the improvements in
addressing the compliance issue at the Westside facility to remove you from the EPA
watchlist because of the recent months of compliance. Then, I get an SOC request
after the facility has finally become compliant. Supporting this will be difficult. I
think my e-mail below explains my position. The response I received back was an
agreement that the City needed to ask for a schedule in the new permit for a delayed P
limit and to justify in that request why the delay is needed and what has been done
since the current permit was issued to meet the limits that would be included in the
new permit. I think getting a delayed limt for P has a better chance than an SOC
especially when the facility is compliant.
1 of 3 9/15/2004 10:22 AM

[Fwd: Re: City of High Point (Westside)]
I'm going to sit on the SOC application and $400 till later in the week so you guys can
have a chance to discuss among yourselves. Then I would suggest we discuss on Wed
or Thursday as to the direction you want to head.
Steve
On 9/7/2004 12:01 PM, Steve Tedder wrote:
In March of 2000 High Point was issued an NPDES permit for the Westside
WWTP. This permit expired in April of 2004 and is not scheduled to be reissued
until at least December 2004. The 2000 permit explicitly states that upon re -
issuance of this permit in 2004, the facility shall meet a Total P mass limit of 5533
pounds during the summer (April -October) and 7808 pounds during the winter
(November -March) But, as we all know things can change and the 2004 permit has
not been issued to date.
The City has approached us about an SOC as they evidently will not be able to
achieve the P limit when the permit is issued (assuming issuance in late 2004). My
position is that you have to be violating something to quality for an SOC and as of
now they are not violating the permit because its not even issued. The other
option would be to include a schedule in the permit for meeting the P limit and then
some could argue they have had over four years to get ready to meet that limit and
that a schedule is not supportable.
That would then leave only the senario of issuing the permit, end enforcing the
permit when they violate the condition (since its Winter and Summer limits that
means only two compliance determinations per year) and after a period of
non-compliance(which could be a couple years) then we could entertain a request
for an SOC.
My first suggestion is that we let them request the P limit be delayed via a
schedule in the permit and for them to justify in writing why this delay is
justified and what they have done over the last four years to meet the limit that
is to be in the next permit. If they can justify, to the Director, then to include as
a schedule in the permit.
If the first suggestion is not appropriate, then I would suggest we just monitor
compliance with the new limit when the permit is issued and if noncompliance
is an issue at that point, take appropriate enforcement and then if the data
suggest, we could entertain an SOC request possibly a year of two after
issuance.
I would not recommend an SOC for the P limit until such time as there are
violations to support a request for an SOC.
2 of 3 9/15/2004 10:22 AM

[Fwd: Re: City of High Point (Westside)]
Any thoughts or guidance would be appreciated so I can forward to the City. This
facility is on the proposed EPA Watch List and it appears that past complianc issues
have been resolved and the facility compliant for July and August. The previous
discussions regarding and SOC were in relation to past compliance issues with BOD
and TOX and hopefully they are resolved. The SOC for Phos has been something
the City has mentioned in the past few weeks.
Thanks
Steve
Thanks
Steve
Steve Tedder
NC DENR Winston-Salem Regional Office
Division of Water Quality, Water Quality Section
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone] ext 290
FAX: [phone]
Steve Tedder
NC DENR Winston-Salem Regional Office
Division of Water Quality, Water Quality Section
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone] ext 290
FAX: [phone]
3 of 3 9/15/2004 10:22 AM

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DAVIS-MARTIN-POWELL & ASSOCIATES, INC. `ttt'c
ENGINEERING • LAND PLANNING • SURVEYING 1/V/ 16f
6415 Old Plank Road, High Point, NC 27265
[phone] • Fax [phone] • www.dmp-inc,com
Mr. Dave Goodrich
NPDES Permit Unit
N.C. Dept. of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Dave:
July 28, 2004
Re: City of High Point, N.C.
Westside Wastewater Treatment Plant
N - ES Permit No. NC00 "7
647
jec
AUG 3 2004
L
DENR - WATER OtIAEITY
POINT SOURCE BRANCH
As you may be aware the High Point Westside Wastewater Treatment Plant has experienced more
and more difficultly meeting permit limits over the last 12 to 18 months resulting in significant
numbers of violations and fines. Anticipating that expansion upgrade of this facility will be required,
the City of High Point has recently included the design and construction of the Westside Wastewater
Treatment Plant Upgrade in its Capital Project Ordinance and has funded design services in third
quarter of 2004 with construction anticipated to begin in late 2005 - early 2006.
In January of 1998, our firm prepared a Preliminary Engineering Report for the Westside Wastewater
Treatment Plant expansion upgrade including a plant evaluation. At that time flow problems were
more serious than any treatment violations at this facility and they were addressed by increased
rehabilitation of the sewer system contributing to the Westside Treatment Plant. As a result of this
increased efforts in the Westside system, flow violations have become less severe, however,
biological violations have begun to occur. In this original Preliminary Engineering Report it was
determined that this plant, with a permitted flow of 6.2million gallons per day, would be expanded in
the next normal increment to a capacity of 9.3 million gallons per day.
Based upon the results of this original Preliminary Engineering Report and the current status of
violations for this facility and the need to proceed with the expansion upgrade of this plant, we are,
on behalf of the City of High Point, are requesting that speculative discharge limits be prepared for
the expansion of this facility to a capacity of 9.3 million gallons per day.
In anticipation of this expansion, we have met with the City of High Point and the Winston Salem
Regional Office and discussed the possibilities of applying for a Special Order of Consent for the
facility during this interim period while the expansion and upgrade is being designed and
constructed. Therefore, this project has become very critical and the City has opted to move it ahead

Mr. Dave Goodrich
- NPDES Permit Unit July 28, 2004 Page 2
very rapidly! As stated, its design and construction have been included in the Capital Improvement
Program and in a Revenue Bond Issue which hopefully will take place later in this year.
We therefore, request your cooperation in securing these speculative limits for the expanded facility
as quickly as possible.
If you have questions or if we can provide additional information regarding this process, please let us
know.
Very truly yours,
DAVIS-MARTIN-POWELL & ASSOCIATES, INC.
Pa
Charles E. Powell, PE
CP/dd
C: Mr. Perry Kairis
Mr. Terry Houk
File
P: IPROJECTI E36471DOCIWestsideWWTP-Goodrich.doc