NC0024210_Speculative Limits_19990224

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 24, 1999
Mr. Thomas P. Gore, Plants Division Manager
City of High Point
Public Services Department
P.O.Box 230
High Point, North Carolina 27261
Dear Mr. Gore:
e rn
NCDENR
Subject: Updated Speculative Discharge Limits
NPDES No. NCO024210
High Point Eastside WWTP
Guilford County
This letter is in response to the request submitted by James Cramer of Hazen and Sawyer
for updated speculative limits for the proposed expansion of the subject facility from 16 MGD to
26 MGD. The Division of Water Quality (DWQ) previously provided speculative limits in
September 1995. These limits are being updated to incorporate the Hearing Officers'
recommendations for point source controls for the proposed Randleman Reservoir, based on the
public hearing in September 1998. Specific updates to the speculative limits include: 1)
relocation of the High Point-Eastside discharge point from the present location on Richland
Creek to a point downstream of Freeman Mill Dam; 2) effluent limits for phosphorus at the
outfall relocation point will be set at a monthly average of 0.5 mg/I at a maximum flow of 26
MGD; and 3) waters of the proposed Randleman Reservoir be reclassified as a water supply.
The updated speculative limits for the proposed expansion to 26 MGD with the relocated
discharge are presented in the attached Table A(1). These speculative limits are based on our
understanding of the proposed expansion and of present and anticipated fixture environmental
conditions. These speculative limits are not binding unless they become part of an issued
NPDES permit. Response to a speculative limit request does not guarantee that the Division will
issue an expansion of an NPDES permit to discharge treated wastewater into these receiving
waters, or that the effluent limitations and other requirements included in any permit will be
exactly as presented here. For example, the speculative limits do not include monitoring other
than influent and effluent samples. However, additional instream, reservoir, and/or end -of -pipe
monitoring will likely be added when the permit is drafted. In addition, updated information
may cause the toxicant limits to be eliminated or added as deemed appropriate.
It has previously been noted that the proposed expansion requires the preparation of an
environmental assessment (EA) by the applicant. DWQ will not accept a permit application for a
project requiring an EA until the document has been approved by the Department of
Environment and Natural Resources and a Finding of No Significant Impact (FONSI) has been
sent to the state Clearinghouse for review and comment.
P.O. Box 29535. Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

Town of High Point
Speculative Limits- Eastside WWTP
February 24, 1999
Page 2
All information pertaining to this request has been sent to our Central Files for storage.
When you are ready to request the expansion, please submit a major modification request
including appropriate fees ($860 per January 1, 1999 Fee Schedule). If you have any additional
questions about these limits or the NPDES modification process, please contact Tom Belnick at
[phone], extension 543.
Sincerely, /•
David A. Goodrich V
Supervisor, NPDES Unit
Water Quality Section
cc: Winston-Salem Regional Office, Water Quality
Central Files
NPDES Unit
Jason Doll
James Cramer, Hazen and Sawyer, 4011 Westchase Blvd, Raleigh NC 27606

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS- SPECULATIVE
Permit No. NCO024210
During the period beginning upon expansion above 16 MGD and lasting until expiration, the Permittee is authorized to discharge from outfall serial number 001.
Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
easurement
Frequency
Sample
Type
Sample
Location"
Flow
26.0 MGD
Continuous
Recording
I or E
BOD, 5 day, 20°C (April 1 to October3l)1
5.0 mg/I
7.5 mg/I
Daily
Composite
I,E
BOD, 5 day, 200C (November 1 to March 31)1
10.0 mg/I
15.0 mg/I
Daily
Composite
1,E
Total Suspended Residuel
30.0 mg/I
45.0 mg/I
Daily
Composite
1,E
NH3 as N (April 1 to October 31)
1.0 mg/I
Daily
Composite
E
NH3 as N (November 1 to March 31)
2.0 mg/I
Daily
Composite
E
Total Residual Chlorine2
17 ug/I
Daily
Grab
E
Temperature °C
Daily
Grab
E
PH3
Daily
Grab
E
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Daily
Grab
E
Dissolved Oxygen4
Daily
Grab
E
Conductivity
Daily
Grab
E
Total Nitrogen (April 1 to October 31)
6.0 mg/I
Monthly
Composite
E
Total Nitrogen (November 1 to March 31)
Monthly
Composite
E
Total Phosphorus
0.5 mg/I
Monthly
Composite
E
ChronicToxicity5
Quarterly
Composite
E
Phenols
1.0 ug/l
Weekly
Grab
E
Cadmium
2.0 ug/I
Weekly
Composite
E
Cyandide
5.0 ug/l
22.0 ug/I
Weekly
Grab
E
Fluoride
1.8 ug/I
Weekly
Composite
E
Lead
25 ug/l
Weekly
Composite
E
Mercury
0.012 ug/I
Weekly
Composite
E
Nickel
25 ug/I
Weekly
Composite
E
Copper
2/Month
Composite
E
Silver
2/Month
Composite
E
Zinc
2/Month
Composite
E
Notes:
Sample locations: E - Effluent, I - Influent
1 The monthly average effluent BOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal).
2 Effluent limit and monitoring applies only if chlorine is used for disinfection.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
5 Chronic Toxicity (Ceriodaphnia) P/F at 90%.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Re: randlernan dam question
Subject: Re: randleman dam question
Date: Wed, 10 Feb 1999 15:28:20 -0500
From: "Boyd Devane" <boyd [e-mail]> Internal
To: Tom Belnick <[e-mail]>
the permit is not tied to the reservoir being built except that the recommendation to move the discharge
1.5 miles was based on the need to protect the reservoir's upper arms. If there were no reservoir, hiigh
point could argue that they did not need to move the discharge.
Tom Belnick wrote:
Boyd- I'm revising the spec limits for the High Point-Eastside WWTP. My
question is- could this expansion occur without the reservoir being
built? When I read the spec letter issued in 1995 the answer would be
"yes", since it stated that the spec limits would be applied with and
without consideration of the proposed reservoir. However, when I look
at the recent Hearing Officers Recommendations, the agreed upon TP limit
of 0.5 mg/1 is based on relocation of the discharge, and WS
classification of the reservoir, which implies that the expansion will
be tied in with the reservoir.
Mail To: [e-mail]
N.0 DENR-DWQ/NPDES Unit
P.O.Box 29535, Raleigh NC 27626-0535
Work: [phone] ext. 543
Fax: [phone]
-re o ,S t _ 2 A.,,< J ki�)� 7/4 //,W l 't, j Q"r/,V I . ,
1 of 1 2/10/99 3:29 PM

Project Phone Log
Tom Belnick, NPDES Unit
NPDES NC00 2 Y,21
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JAN-11-99 MON 02;12 PM HAZEN & SAWYER FAX NO, 9198331828 P, 02/02
HAZEN AND SAWYER Nano and Sawyer,
4011 WostChase Blvd,
Environmental Engineers & Scientists 9198�7152607
Felt: 919 833-1826
January 11, 1999
Me, Coleen Sullins
Division of Water Quality
State of North Carolina Department
of Environment and Natural Resources
Post Office Box 29535
Raleigh, North Carolina 27626-0535
0,5 VY 7P
RE: Request for Updated Speculative NPDES Permit Limits
Eastside Wastewater Treatment Plant S
High Paint, North Carolina btiti
Dear Ms. Sullins:
On behalf of the City of High Point, this to request updated
Eastside Wastewater Treatment Plant to a permitted caps
needed to confirm detailed design of facilities for 26 mgd c
conditions that may be included in the permit such as monit
26 mgd, and hydraulic ca ao city requirement for the effluer
appreciate receiving up ad ted speculative limits as soon as I
design and to expedite completion of the upgrade of the I
project. Please call if any information is needed.
Very truly yours,
,�,g lMc .IIS
Ative limits for expansion of the
'26 mgd. Speculative limits are
ty. Please describe any special
provisions for expansion beyond
D sta`ion/force main We would
le to verify facilities planning and
de Wastewater Treatment Plant
HAZEN AND SAWYER, P.C.
J��
s A. Cramer, P.E.
President
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Meeting with High Point
,. . 96J 2
Subject: Meeting with High Point
Date: Fri, 08 Jan 1999 13:38:23 -0500
From: "Dave Goodrich"<[e-mail]> Internal
To: Tom Belnick <tom [e-mail]>
CC: Boyd DeVane<[e-mail]>
Tom - Please note the last paragraph. They are requesting that someone
meet officials from High Point at the proposed discharge site. We
should probably discuss at Office hours (next Tuesday morning), but I'd
like you to represent permitting in this effort. Thanks,
Dave
Subject: Meeting with High Point
Date: Fri, 08 Jan 1999 12:05:54 -0500 �1
From: 'Boyd DeVane"<[e-mail]>
To: Coleen Sullins <coleen [e-mail]>
CC: Greg Thorpe<[e-mail]> ,
Ruth Swanek <ruth [e-mail]> ,
Dave Goodrich<[e-mail]> ,
Jason Doll<[e-mail]> , o R
LARRY COBLE <LARRY [e-mail]> , �V
Steve Zoufaly<[e-mail]> ,
Bradley Bennett <[e-mail]> ,
Dave Goodrich<[e-mail]> , J
John Dorney<[e-mail]> ,
Bobby Blowe <[e-mail]> , \ ��
Steve Mauney <[e-mail]>
As you know, Bradley, Steve Z, Lin, Preston and I met with Streb\�1
Boynton, Lee Burnette, and Wendy Fuscoe about what the Randleman rules •�
would require them to do regarding stormwater. John Kime also sat in.
The meeting went smoothly and High Point seemed pleased with our `
positions. Basically they were unsure of what a comprehensive
stormwater plan would be. They were afraid it would be a detailed Y
engineering plan to control all stormwater. We explained we basically
wanted to see evidence that they were going to have a viable stormwater
program which would demonstrate progress on all the areas we listed in
the rules, such as planning, education, illegal discharge and etc. They\
also wanted to know how we would consider their future requests to allow +_
above 50% impervious in the lower parts of their jurisdiction. We \
explained we wanted their ordinances to contain criteria needed to
approve projects such that we could approve the ordinance and they could
review projects. We emphasized we did not want to be reviewing
individual projects - unless they were for a major variance. Of course,
they showed their leanings toward regional ponds and we tried to point
out to them that that alternative was not the total solution and it was
frought with problems. They said they would be getting back with k
Bradley with some proposals.
There was some discussion about what was a stream. Preston a
explained that they should try to wait until the General Assembly came
up with options on the Neuse before going too far in that area. I r\ "y`11,
should also note that there was confusion on whether to use either the
soil maps or the USGS maps to define a stream. John Kime said most (1
thought the rules said that either applied. They actually say that in
deciding what is a stream, its a stream if it's one either of the maps.
�i
High Point wants to find out exactly where the discharge point is
so they can do the engineering analyses. We suggested that a modeller,
and probably someone from permitting, go out to the field with our field
office staff and High Point staff and find the site that best fits our
1 of2 J 1/8/99 1:49 PM

e
Meeting with High Point
needs. They also had questions about the design of the discharge pipe
and size. They said they thought you had talked to someone already
about these issues and they would pursue those same channels. _
2 of 2 1 /8/99 1:49 PM

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