NC0024228_Correspondence_20161011

nlol-C � i��ir�r�- hl* �N��Zk2Zv
r1,"/h i i ✓'e neW
Belnick, Tom
From: Belnick, Tom
Sent: Tuesday, October 11, 2016 11:44 AM
To: TERRY HOUK ([e-mail])
Cc: Grzyb, Julie; Poupart, Jeff; Hennessy, John; Behm, Pamela; Knight, Sherri; Smith, George
Subject: NPDES/High Point Westside Mod Request NCO024228
Mr Houk:
In a letter dated October 4, 2016 (attached) you requested a permit modification to eliminate the requirement for
stream restoration prior to expansion to 10 MGD. Since this permit is currently expired, we cannot consider a
modification at this time. Your modification request will be evaluated during permit renewal. This renewal is currently
assigned to Julie Grzyb, who is familiar with this project and was the permit writer for your 2013 expansion
modification. It appears your current flows are generally less than 40% of your current permitted flow of 8.2 MGD. If
you have any questions, feel free to contact either Julie Grzyb or myself.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
[e-mail]
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
c Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

P"d61l Nc-FVZgZZg
�oM4- Wei fAie
—2Va)\gI( rZ urj
If{
October 4, 2016
Mr. Jay Zimmerman, Director
Water Resources Division
NC Dept. of Environmental Quality
1611 Mail Service Center
Raleigh, NC 27699-1611
twig
NORTH CAROLINNS INTERNATIONAL CIT)'"
Subject: Request for Special Condition Modification to NPDES Permit No. NCO024228
City of High Point Westside Facility
Dear Mr. Zimmerman,
OCT 10 2f;�
t ermifina Section
The City of High Point Westside WWTP is permitted to discharge 8.2 MGD of advanced tertiary treated effluent to the Rich
Fork Creek receiving water (NPDES No. NC0024228). The City was authorized to construct expansion of the facility to 10
MGD, but special conditions must be met before discharge of 10 MGD will be authorized by your department per our
current NPDES permit requirements. Some circumstances have changed since receiving the current NPDES permit and the
City is requesting a change to the permit "Special Conditions" requirements to reflect the existing state of affairs.
Specifically, the City requests that all references to stream restoration be struck from the Westside facility's NPDES permit.
Our suggestions for modification to the existing special conditions are provided in the attached mark-up of that permit
language. The original offer for the City to conduct stream restoration for segments of Rich Fork Creek modified by sand
mining activity was made in concert with the DWR regional office commitment to have the sand mining activities stopped
on the stream by not renewing the general permit application for those operations. The subsequent decision by the DWR
Raleigh headquarters' Compliance & Expedited Permitting Unit to not remove those sand mining privileges changes the
City's position regarding this offer. Because the stream is not listed as impaired for dissolved oxygen, the restoration is not
needed to meet water quality standards. Therefore, the City cannot commit to spending ratepayer money to fix a
problem that the facility discharge did not cause, that the Department of Environmental Quality does not recognize as a
problem, and for which the repairs would likely be undone quickly by continued sand mining activity.
The City remains committed to conducting water quality studies to demonstrate that the DO water quality standard will
continue to be maintained following further increase in discharge to 10 MGD. It is the City's position that the requirement
for additional monitoring and modeling studies be disconnected from a requirement for stream restoration. We would be
glad to meet with you and your staff to discuss the request further if you believe that would help you to make a more
informed decision.
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax:[phone] Phone:[phone] TDD:336.883.8517

NORTH CAROLINA'S INTERNATIONAL CITY'
We look forward to hearing from you on this request, and working together on next steps needed for NPDES permit
modification.
Sincerely,
t rk
Terry L. H
Director of Public Services
City of High Point
Cc:
Sherrie Knight, Regional Water Quality Supervisor
Jeffrey Poupart, Water Quality Permitting Section Program Manager
Tom Belnick, Complex Permitting Unit Supervisor
John Hennessy, Compliance & Expedited Permitting Unit
Pamela Behm, Modeling & Assessment Branch Supervisor
Todd Johnson, Hazen & Sawyer
Trevor Clements, Tetra Tech
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fox.336.883.1675 Phone:[phone] TDD:336.883.8517

z SPECIAL CONDITIONS IN ACCORDANCE WITH THE SEPA FINDING OF NO SIGNIFICANT IMPACT AND
ENVIRONMENTAL ASSESSMENT FOR THE CITY OF HIGH POINT- WESTSIDE WASTEWATER TREATMENT
PLANT EXPANSION BEYOND 8.2 MGD:
peFFAits.
Via. Submit a summer in -stream monitoring plan, on the proposed intensive monitoring in
Rich Fork Creek, to be performed following stream rertaratiencompletion of construction of the
expanded facility. Submit 2 copies of the plan toQDWR' nS Complex Permitting Unit
Supervisor and one copy to the ssessment Branch
Supervisor for approval at least 3 months prior to planned implementation.
e:b.The City of High Point shall implement the DWQ approved in -stream monitoring plan.
d:c.Following the intensive monitoring survey, after the stream rester- `ie pr9j .et is
the receiving_ water quality model for Rich Fork Creek will be
assessed for accuracy. If the need is determined by DWR, the model will be
recalibrated for the approximately 12 mile segment between the High Point
Westside outfall and the confluence of Abbotts Creek, to reae�d
pr,....ieal eendi..ienr e f thp. sure .._ due to the _„ste fatten p ee address noted
areas of model deficiency. The recalibrated model will be rerun with existing
flow, 8.2 MGD, and 10 MGD to analyze the impact of the discharge. Model
results will be compared with previous predictions and observed profiles to
determine the level of impact on dissolved oxygen concentrations. The results of
the modeling analyses and the recalibrated models at 8.2 MGD and10 MGD
shall be submitted to DWQ for review. Submit 2 copies of the modeling report
and all associated modeling files to the DWR Complex Permitting Unit
Supervisor ^"'^ S-and one copy to the DWQDWR Modeling and
Assessment Branch '"'^ITT Supervisor for review. An electronic copy of the
model should be included with the copy sent to DWQ/M 41the DWR Modeling
and Assessment Branch for a proper review. The City of High Point will be
allowed to proceed with an expansion or an Authorization to Operate request at
10 MGD upon DWQ-DWR approval, based upon validation of model predictions
that in -stream dissolved oxygen water quality standards will be maintained in
the -esterea segment e f the receiving stream.
e.d.If the recalibrated models or in -stream DO data in the restered segment of Rich
F4Fk-GFeek-do not show sufficient assimilative capacity, the City of High Point
shall submit a plan outlining efforts to maximize DO in the WWTP's effluent to
ensure in -stream DO water quality standards are not violated due to the
discharge from the Westside WWTP. Three copies of the DO optimization plan
shall be submitted to DWQ/ NPPRS;the DWR Complex Permitting Unit
Supervisor. A compliance schedule to address the DO deficiency may be added
to this permit and an Authorization to Operate at a capacity of 10 MGD will not
be allowed until the City demonstrates that the receiving stream has sufficient
assimulative capacity to support an expansion.
All submitals to PWQ A Tn and nm^ inronc QWR should be sent to:
161.7 Mail Service Center
Raleigh, NC 27699-1617