NC0024228_Environmental Assessment_20200127

Banihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Monday, January 27, 2020 9:27 AM
To: Banihani, Qais
Cc: Grzyb, Julie; Terry Houk ([e-mail]); Derrick Boone; Glenn Dunn
([e-mail]); Yonce, Hillary
Subject: [External] WLA Table Correction
Attachments: Tt Memo -High Pt _Rich Fork Channel Changes_1-27-2020rev.pdf
or
Good Morning Qais,
Terry Houk relayed your message that the EA supplemental memo was deemed sufficient, with the exception of a typo
in the WLA summary table (1). Our apologies for the transposition of the winter BOD and summer NH3 limits from the
modeling report that used a different table format. Per Terry's request, we have corrected Table 1 and are resubmitting
the memo for your record and to use with proceeding with permit renewal. We've re -dated the memo with today's date
for ease of tracking. Please let me know if you need anything further in this regard.
Regards,
Trevor
Trevor Clements I Principal/Program Manager
Direct: 919.485.2058 1 Main: 919.485.8278 1 Fax: [phone]
trevor.clements(EDI etratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.00m
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NTETRA TECH
MEMORANDUM
To: Terry Houk, Director of Public Services
City of High Point
From: Trevor Clements, Principal
HillaryYonce, P.H.
Date: January27, 2020
Subject: Documentation of Physical Changes to the Rich
Fork Creek Stream Channel
Tetra Tech Engineering, P.C.
One Park Drive, Suite 200 • PO Box 14409
Research Triangle Park, NC 27709
Tel [phone] • Fax [phone]
The content of this memorandum was compiled by Tetra Tech on behalf of the City of High Point to
document changes to the Rich Fork Creek receiving stream for the Westside Water Reclamation Facility
(WRF) (National Pollutant Discharge Elimination System [NPDES] Permit No. NC0024228) since the
Environmental Assessment for the facility's expansion was completed.
Previous permit conditions for the expansion of the Westside WRF required stream restoration based on
environmental studies at the time to support assimilative capacity of the receiving waterbody in meeting
the water quality standard (WQS) for dissolved oxygen (DO). Westside WRF is located outside of High
Point, NC, in Davidson County and discharges near the headwaters of Rich Fork Creek, which flows
southbound for about 12 miles before reaching a confluence with Abbotts Creek. When the previous
permit conditions were identified as a requirement for the WRF expansion to allow Rich Fork Creek to
meet the instream WQS for DO (5.0 milligrams per liter [mg[I]), conditions along Rich Fork Creek were
significantly different than they are today, which this memo documents and clarifies in detail.
Recent extensive monitoring and modeling efforts conducted by Tetra Tech have shown that the
significant changes along Rich Fork Creek have improved hydraulics and represent a much different
stream condition than existed over a decade ago and upon which the original expansion permit conditions
were based. Specifically, the channel profiles in portions of Rich Fork Creek observed in 2006-7 as
impacted by sand mining have improved naturally, and areas of the stream previously noted by Tetra
Tech as having excessive treefall, including large tree debris dams, are now exhibiting more natural
levels. Based on the weight of evidence provided herein, it is our recommendation that the previous
permit condition requiring stream restoration be removed from the City's Westside NPDES permit. It is our
professional opinion that the restoration requirement is no longer warranted as conditions instream have
improved, and the newly calibrated and corroborated QUAL2K stream model verifies that the expanded
Westside WRF discharge can be assimilated under existing channel conditions with a substantial margin
of safety. A summary of these documented changes is provided herein.

Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
Results from the intensive 2017 monitoring studies and subsequent modeling studies show that the
observed physical channel changes documented in this memorandum have led to increased assimilative
capacity in Rich Fork Creek. For specific information related to the monitoring, model development, and
application, please refer to the Model Evaluation for Rich Fork Creek: New Data and Analyses Report
(Tetra Tech, 10-26-18), and the Westside WRF Wasteload Allocation Scenario Result and Proposed
Permit Limits memorandum (Tetra Tech, 7-26-2019). The results of these combined efforts reveal that
under critically low flow conditions (7Q10) during both summer and winter periods, the WQS of 5.0 mg/l
DO is not violated when the Westside WRF effluent flow and water quality are simulated at proposed
permitted maximums. Specifically, the proposed permit limits for effluent flow and key water quality
constituents are shown below in Table 1, alongside the associated instream minimum DO concentration
predicted by the updated and enhanced QUAL2K model. Note that the model scenario application
includes a margin of safety (MOS) of 5 percent to ensure that the WQS protection more conservatively.
Table 1. Rich Fork Creek QUAL2K model WLA scenarios results: instream DO and NH3.
2 J� 10.0 1.0 4.0 5.27
5.25
3 8.2 2.0 10.0 5.81
Winter 7.0
4 10.0 1.8 8.0 6.03
FLOW DATA
Stream flow can have a powerful influence on stream channel hydraulics. Although there is not a long-
term flow monitoring gage located along Rich Fork Creek, a U.S. Geological Survey (USGS) gage located
on the adjacent Abbotts Creek (USGS 021201500 Abbotts Creek at Lexington, NC) has been used to
approximate flow conditions along Rich Fork Creek throughout the monitoring and modeling work
conducted since 2006. Data from that USGS gage indicate that some very high flows have occurred in
the past decade that could be a primary factor in the changes in stream channel hydraulics observed over
the past ten years and described in greater detail below.
Flow records along Abbotts Creek since 2007 to the present time (i.e., that follow the initial intensive
stream surveys of Rich Fork Creek performed by Tetra Tech) reveal an average daily flow of
approximately 168 cubic feet per second (cfs) and a median daily flow of 73 cfs. The maximum flow
recorded and validated at the Abbotts Creek gage was 8,000 cfs measured in 2003. Since fall 2007, three
flows approaching the maximum (above 7,500 cfs) have been recorded. Additionally, eight flows have
been measured above 6,000 cfs. The 95th percentile of flow reported by USGS is 600 cfs, so Abbotts
Creek has experienced eight events since our 2007 studies that are more than 10 times the 95th
percentile flow.
The Abbotts Creek flow gage has been used effectively to estimate flows in Rich Fork Creek via a
demonstrated strong relationship between gaged flows in Abbotts Creek and point measurements of flow
along Rich Fork Creek. Using drainage area analyses at three points along Rich Fork Creek at locations
of historical sand mining operations, we can roughly estimate flow using Abbotts Creek flow data in two
ways:
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
1. Using a drainage area ratio relative to the Abbotts Creek USGS gaging station, and
2. Using an empirical relationship between observed flows along Abbotts Creek and along Rich Fork
Creek during field monitoring investigations (empirical linear regression equation has an R-square
of 0.85).
Those two methods result in the following Rich Fork Creek flow approximations at Highway 109, Ball
Road, and Kanoy Road crossings during those eight highest flow events along Abbotts Creek:
1. Drainage area ratio method: flow range of 860-1,390 cfs
2. Empirical regression method: flow range of 1,750-2,830 cfs
The range of flows likely to have occurred along Rich Fork Creek during the eight largest events in
Abbotts Creek is approximately 35-90 times greater than the average annual flow in Rich Fork Creek
depending on location. High -flow events so far above average can create shear velocities that move
sediment and debris, change channel shape, and are capable of reforming stream banks as was
observed during the 2017 monitoring studies.
CROSS -SECTIONAL AND HYDRAULIC MEASUREMENTS
Due in part both to the cessation of sand mining activities in the vicinity of Ball Road and Kanoy Road and
to the large flow events that have helped reshape Rich Fork Creek, significant changes have occurred in
channel geometry over the past decade. This section discusses the areas identified a decade ago as
having active sand mining and pools, with specific details about how those areas have changed over
time. Changes can be observed in channel geometry, aerial imagery, and time -of -travel (TOT) studies. In
2009, subcontractor team Davis, Martin, and Powell & Associates (DMP) measured extensive pool cross
sections that were compared to more recent measurements from 2017-2019. The more recent studies
show how a more traditional thalwag forming in the stream channel and flow no longer extending from
bank to bank under low flow conditions.
Ball Road
Downstream of Ball Road active sand mining occurring in the 2007-2009 period was ceased at some
point between observations during the 2017-2019 field studies. DMP conducted extensive surveys in late
January 2009 across the Ball Road pool area (Figure 1). The widest portion of the pool was measured at
cross-section K to be 56.6 feet (ft), and the deepest portion of the pool was measured at cross-section J
to be 5.5 ft, with an average depth through the pool of approximately 3 ft. Based on flow at the Abbotts
Creek USGS gage, flow at Ball Road at the time of those surveys was approximately 13 cfs.
In the area of cross -sections L, J, and K identified as the pool extent in 2009, new cross -sections were
measured on August 6, 2019, immediately downstream of Ball Road. Flow conditions were approximately
11 cfs at Ball Road based on the Abbotts Creek gage, similar to conditions observed during the 2009
surveying. Average water depth observed in 2019 was around 0.8 ft (more than a 70 percent reduction),
and the maximum water depth observed was 1.5 ft (also more than a 70 percent reduction). Bank -to -bank
channel width observed in 2019 was approximately 38 ft, with an average wetted width of 25 ft.
Sand and silt deposits have filled in the old Ball Road pool since the cessation of sand mining activities,
and the creek has returned to a more natural geometry with a clear thalweg and highly vegetated banks
(Figure 2 and Figure 3). In Figure 4, note the differences in both width and depth at the cross -sections
taken at approximately the same location under similar flow conditions. The cross -sectional shape
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
difference (narrower with a thalwag directing flow pattern) is representative of the magnitude of change
observed throughout this segment of the receiving stream.
Additionally, between April 2013 and April 2014, the Ball Road bridge crossing of Rich Fork Creek was
updated and replaced by the North Carolina Department of Transportation from a bridge with wooden
posts and rails to a fully concrete bridge. That change might also have had an impact on stream and
sediment hydraulics.
On August 28, 2007, a Rhodamine WT dye release was used to conduct a TOT study upstream of the
Ball Road pool. Based on the relationship of flow between Abbotts Creek and Rich Fork Creek, flow at
Ball Road on that date was estimated at approximately 9.5 cfs and the velocity was observed in the dye
study to be about 0.3 feet per second (ft/s). A TOT study conducted on June 2, 2017, in the same vicinity
of Ball Road found a velocity of 0.6 f Is best represents the existing velocity through that segment, which
is much greater than was observed and estimated in the vicinity in 2007. Flow conditions on that day
were approximately 14.4 cfs at Ball Road. The doubling of velocity can be largely attributed to the
narrower portion of stream in which the volume of water was flowing.
Figure 1. Aerial imagery of cross sections measured in the vicinity of Ball Road observed in 2009.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
Figure 2. Water -level photo of the Ball Road pool, looking upstream at the old bridge (January 2009).
Figure 3. Water -level photo of the former Ball Road pool, looking downstream (August 6, 2019).
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
05
= 1
3 25
35
Waters Edge to Waters Edge (ft)
0.0 10.0 20.0 30.0 40.0 50.0 60.0
--Feb 09 —Aug-19
Figure 4. Representative 2009 vs 2019 water depth cross section across the former Ball Road pool.
Figure 5. Ball Road sand mining impacts and vertical banks as observed on March 1, 2010.
Figure 6. Ball Road images from August 6, 2019 showing revegetation of banks and reshaping of channel
after the cessation of sand mining activities.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January27, 2020
Kanoy Road
The pool created by sand mining at Kanoy Road was observed in 2007 to begin above the bridge and
extend well downstream of the bridge, measuring about 80 ft at its widest point downstream of the bridge
(Figure 7). Between 2007 and 2017, the sand mining permitted at Kanoy Road ceased (exact timing
unknown). Field measurements from 2017 showed the previously widest location to be about 18-22 ft
(more than a 70 percent reduction), and aerial imagery from February 3, 2018, suggests the widest part
of the pool might now be located upstream of Kanoy Road, measuring around 68 ft across upstream of
the bridge with sand bars visible (Figure 7). Conditions depicted in Figure 7 are representative of field
measurements taken by DMP January 22-25, 2009, and Tetra Tech August 6, 2019 , when flow
conditions at Kanoy Road were approximately 13.6 cfs and 11.5 cfs, respectively.
Figure 7. Aerial imagery of sand mining pool downstream of Kanoy Road observed in 2007 (left). Aerial
imagery of sand mining pool downstream of Kanoy Road observed on 2/3/2018 (right).
DMP conducted extensive surveys January 22-25, 2009, across the Kanoy Road pool area (Figure 8).
The widest portion of the pool was measured to be 84.2 ft at cross-section K, and the deepest portion of
the pool was measured to be 6.1 ft at cross-section N. On August 6, 2019, in the area of cross -sections G
through O identified as the pool extent in 2009, Tetra Tech measured new cross -sections where flow
conditions at Kanoy Road were approximately 12.3 cfs.
The entire extent of the old Kanoy Road pool has in -filled with extensive sand and silt, resulting in a far
shallower channel (see Figure 9 compared with Figure 10). Average channel width between cross -
sections G and O in 2009 was approximately 57.6 ft, and the average depth was approximately 2 ft. The
average channel width observed around Kanoy Road in 2019 was 37 ft (more than a 35 percent
reduction) and, at its widest, it was 53 ft (more than a 37 percent reduction). A representative channel
depth was observed to be 1 ft (an approximately 50 percent reduction), and the maximum observed depth
was approximately 2 ft (an approximately 67 percent reduction). A representative comparison of channel
shapes between the earlier and current conditions is shown in Figure 11, illustrating the substantial
changes that have occurred over the past decade. As was the case for Ball Road, the photos and cross-
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
sections demonstrate a narrowing of the portion of channel carrying water under low flow conditions, with
a thalwag reestablishing itself in these previously pooled regions.
Figure B. Aerial imagery of cross sections measured in the vicinity of Kanoy Road in 2009.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
Figure 9. Kanoy Road pool on downstream end of bridge (January 2009).
Figure 10. Old Kanoy Road pool looking downstream from under bridge (August 6, 2019).
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
0.5
� 1.5
L 2
C
G
p 2.5
3
m
Qrs
4.5
Waters Edge to Waters Edge (ft)
D 10 20 30 40 50 60
— Feb-09 — Aug-19
Figure 11. Representative 2009 vs 2019 water depth cross-section across the former Kanoy Road pool.
Highway 109
All field work conducted between 2007-9 and 2017-19 in the vicinity of Highway 109 found stream
geometry being shaped by active sand mining (see representative photos in Figure 12 and Figure 13).
DMP conducted extensive surveys in 2009 beginning upstream of the sand mining areas and extending
downstream of Highway 109 (Figure 14). Tetra Tech measured several cross -sections in 2017 within the
same zone and made additional field observations in 2019. The deepest area observed in 2009 was
measured at 5.1 ft at cross-section T in a pool located downstream of Highway 109, while upstream of
Highway 109 the water was considerably shallower. During field work conducted from 2017 to 2019,
Tetra Tech field staff found that no pool existed downstream of Highway 109, but that a large pool
extended from the sand mining location upstream of Highway 109 to the highway crossing. The channel
proportions of the Highway 109 pool as measured in 2017 were incorporated into the updated QUAL2K
model completed by Tetra Tech and delivered to DWR to account for the continued influence of sand
mining at this location.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January27, 2020
Figure 12. Active sand -mined pool upstream of Highway 109 (January 22, 2009).
Figure 13. Active sand -mined pool upstream of Highway 109 (August 6, 2019).
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
Figure 14. Aerial imagery of cross sections measured in the vicinity of Highway 109 in 2009.
TREEFALL DEBRIS DAMS
Areas with excessive tree -fall debris can influence stream velocity significantly at low flows and during
storm flows causing localized scour pools, which further decrease stream velocity during summer low -flow
conditions and subsequently lower DO concentrations instream. Tetra Tech field personnel took
photographs and recorded locations of treefall debris and logjams during a field visit to Rich Fork Creek in
2007, 2009, and 2010. The differences field crews observed between instream treefall in 2007-2010 and
in a 2017 monitoring study suggest that far fewer logjams existed than a decade ago. The large number
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
of significant regional Flow events are likely responsible for breaking up the excessive number of logjams
observed a decade ago. A photograph of the treefall debris dam significantly impeding flow downstream
of Ball Road in 2009 is shown in Figure 15. That debris dam was no longer present at the site when it was
visited in 2017.
Figure 15. Facing downstream at a major debris dam below Ball Road pool January 24, 2009.
Downstream of Ball Road there were a series of large downed trees and debris dams which are easily
visible from Google Earth aerial imagery dated in July 2010 (Figure 16). The same extent shown updated
with aerial imagery downstream of Ball Road from February 2019 reveals that these debris locations have
been cleared out over time due to natural phenomena and channel morphological changes (Figure 17).
Figure 16. Major debris dams and treefalls seen from July 2010 Google Earth aerial imagery immediately
downstream of Ball Road.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January27, 2020
Figure 17. Lack of debris dams and treefalls seen from February 2019 Google Earth aerial imagery
immediately downstream of Ball Road.
Treefall data were compiled in 2009 based on aerial photography captured by Spatial Data Consultants
over the entirety of Rich Fork Creek. Tetra Tech generated a corresponding shapefile that resulted in an
estimate of between 300 and 500 individual treefall sites between Highway 109 and Kanoy Road. At that
time, the frequency of cross -stream treefall occurrence in that zone was approximately double the
frequency observed downstream of that point.
Not all treefall areas result in compromising stream hydraulics, so primarily large-scale debris dams are of
interest for potential removal to improve stream conditions. An example of a debris dam downstream of
Highway 109 observed by the 2009 flyover imagery and seen in ground -level photography is shown in
Figure 18 and Figure 19. That debris dam also can be seen to have changed over time using Google
Early aerial imagery from 2012 and 2013 (Figure 20). The logjam can be observed in February 2012 but
is no longer present in April 2013. In the intervening period, there were 3 days with flow in Abbotts Creek
greater than 1,000 cfs, which likely translated to flows in Rich Fork Creek that helped break up the debris
dam.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
Figure 18. Treefall logjam from chartered flight aerial imagery downstream of Highway 109 (2009).
Figure 19. Ground -level photos of the large treefall logjam downstream of Highway 109 (2009).
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Memo Documenting Changes to Rich Fork Creek Stream Channel
January 27, 2020
Figure 20. Treefall logjam visible in Google Earth aerial imagery in February 2012 (left) no visible treefall
logjam in the same location in April 2013 (right).
These examples illustrate the extent of change that contribute to the improved hydraulics summarized
above in the hydraulic measurements discussion.
WATER QUALITY DATA
Yadkin Pee Dee River Basin Association (YPDRBA) operates three long-term water quality sampling sites
located along Rich Fork Creek (Table 2). YPDRBA water quality data is available online to account users
(such as the City of High Point) and is generally uploaded to the online system within about 3 months of
the sampling time.
Table 2. Water quality sampling sites along Rich Fork Creek (YPDRBA)
Q5745000 rocn ront t:reeK at bn i fbr (cnesmut bireet) near 2010-2019 b.L 5.8
High Point (one sample)
Q5785000 Rich Fork Creek at SR 17902 (Kanoy Road) near
High Point
05790000 Rich Fork Creek at SR 2123 (Old Highway 29) near
High Point and Lexington
Q5750000 Rich Fork Creek at SR 1755
1998-2019 2.9 5.1
1998-2019 3.2 5.5
1998-2009 3.3 No Data
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
Water quality data results show that over the past 9 years (since 2011), minimum DO concentrations
have not been observed below the WQS (5.0 mg/1) along Rich Fork Creek. Average DO concentrations
have remained relatively constant from 2000 to 2019 at all gages along Rich Fork Creek; however, the
improvement in minimum DO concentrations is clear in recent years.
CONCLUSIONS AND RECOMMENDATIONS
In summary, the physical properties of Rich Fork Creek have changed over the past decade, likely
attributable to large flow events shaping stream hydraulics along with the cessation of sand mining
activities at both Ball Road and Kanoy Road. The recent wasteload allocation QUAL2K modeling efforts
and model calibration report associated with the Westside WRF plant expansion demonstrate that Rich
Fork Creek has improved assimilative capacity over conditions existing in 2007. Results of the modeling
effort have shown that under both future effluent flow conditions, Rich Fork Creek is capable of
assimilating these new effluent flow scenarios under critically low 7Q10 conditions. Previous
recommendations to perform stream restoration at multiple locations are no longer needed to increase
assimilative capacity to maintain DO levels above the WQS. We recommend that the City request of the
North Carolina Division of Water Resources that those previous requirements for discharge expansion be
removed from future NPDES permit documents.
The City had acknowledged to Tetra Tech that it recognizes the importance of Rich Fork Creek remaining
hydraulically stable and able to naturally assimilate the expanded effluent discharge from Westside WRF
over time. Therefore, we recommend that the City commit to taking reasonable steps to monitor water
quality conditions and identifying potential threats to stream assimilative capacity associated with stream
hydraulics. Given that sand mining activities are no longer permitted near Ball and Kanoy roads, a greater
threat to Rich Fork Creek hydraulics may now be associated with any future significant treefall debris
dams that have the potential to slow water velocity significantly and decrease natural channel reaeration
rates. Therefore, we recommend the following strategy:
As part of its NPDES Permit monitoring requirements, the City will review YPDRBA water quality
data annually for any trends in reduction in DO concentration that could be indicative of changes
to channel hydraulics that could threaten assimilative capacity. If water quality data suggest
potentially reduced assimilative capacity (DO concentrations below the WQS at any of the
sampling sites along Rich Fork Creek), the City will conduct additional investigation as to potential
causes that could be contributing to degraded stream water quality conditions. For example, if
there is a DO concentration violation of the WQS observed at downstream YPDRBA station
Q578500 at Kanoy Road and/or station Q5790000 at Old Highway 29, the City will analyze
YPDRBA water quality data upstream of the outfall at station Q5745000 at SR1757 to ascertain
whether the low DO condition may be indicative of a system -wide DO decline or may be isolated
to a specific stream segment. When review determines that DO decline is confined to portions of
the receiving waters downstream of the Westside outfall, the City will review effluent water quality
data prior to the period of the low DO observation to see if there may be an issue with plant
operation which could have triggered the WQS violation. Findings of such investigations shall be
communicated to the DWR regional office for further review.
If YPDRBA and/or DWR monitoring personnel observe excessive treefall or have due cause to
suspect streamflow obstruction in conjunction with observed low DO concentrations, the City will
perform additional reconnaissance activities to identify potential treefall debris dams which may
be causing changes to stream hydraulics which are negatively impacting the assimilative capacity
® TETRA TECH 17

Memo Documenting Changes to Rich Fork Creek Stream Channel January 27, 2020
of Rich Fork Creek. Reconnaissance activities might include reviewing readily available streaming
aerial imagery (from Google Earth, ArcMap, or Davidson County) and brief field investigations at
key locations subject to debris obstruction such as those areas near Ball Road, Kanoy Road,
Midway School Road, and Highway 109 crossings. Where access may not be feasible or
practical, the City may choose to conduct fly -over investigations of Rich Fork Creek (ideally
during the winter months when there is low leaf -cover and clear imagery of the channel) in lieu of
manual field inspection to identify potentially problematic treefall debris dams. Findings of such
investigations shall be communicated to the DWR regional office for further review.
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Banihani, Qais
From: Wainwright, David
Sent: Monday, January 06, 2020 9:43 AM
To: Banihani, Qais
Subject: RE: [External] Revised Memo Supplementing High Point Westside WRF Rich Fork Creek
EA
Qais,
I have reviewed the revised memo - thanks for sending it.
They have done a better job referencing the QUAL2K modeling report, which I feel better supports the statements made
in the memo. They have also expanded the discussions on the DO and flows. The proposed monitoring plan seems more
complete. I think they have addressed my comments.
Thanks,
David
From: Banihani, Qais
Sent: Thursday, January 2, 2020 11:13 AM
To: Behm, Pamela <[e-mail]>; Wainwright, David <[e-mail]>
Subject: FW: [External] Revised Memo Supplementing High Point Westside WRF Rich Fork Creek EA
Happy New Year Pam and David,
Traver from Tetra Tech just submitted revised version of the memo supplementing the previous EA for the High Point
Westside facility and its impact on Rich Fork Creek (see email below). Could you please review it and let me know if you
have any comments.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
a a i s. ba n i h a n i@ n cd e n r.aov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
En vlron men ta!
Qualtt y

From: Clements, Trevor <[e-mail]>
Sent: Thursday, January 02, 2020 10:46 AM
To: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Terry Houk ([e-mail]) <[e-mail]>; Derrick Boone
<derrick.boone@high pointnc.gov>; Yonce, Hillary <[e-mail]>; Glenn Dunn
([e-mail]) <[e-mail]>; Crabtree, Taylor <[e-mail]>
Subject: [External] Revised Memo Supplementing High Point Westside WRF Rich Fork Creek EA
Good Morning Julie and Qais,
Happy New Year. To get 2020 off to a good start, I'm pleased to submit on behalf of the City of High Point the attached
revised version of the memo supplementing the previous EA for the High Point Westside facility and its impact on Rich
Fork Creek.
The revised memo reflects the conversation that I had on 12/13/19 with Julie that reinforced what Qais had told me
earlier in the month. In summary, DWR asked the City to address the following three concerns to meet agency
expectations:
1. Increase photo documentation in the memo
2. Incorporate expanded text regarding the citation of the updated modeling
3. Provide a few more specifics in the proposed monitoring strategy
In the attached revised version, these concerns were addressed as follows:
1. New figures 5 and 6 were input to show the dramatic change at Ball Road regarding thalwag re-establishment
and narrowing of channel in which flow occurs during low flow periods. Figures 16 and 17 were inserted to
clearly show how three of the largest debris dams observed in 2010 are completely gone under current aerial
imagery. Figures 18 — 20 were also inserted to reinforce similar evidence at one of the other main debris dams
previously observed between HWY 109 and Kanoy Road. While these photos provide visual evidence, we ask
you to not lose sight that the most overall compelling evidence is in the time of travel data collected through
dye studies which clearly demonstrate considerable increases in stream velocity that may be attributed to the
collective impact of a restored thalwag and narrower channels of flow in the previously pooled segments. Text
was added in these sections to further emphasize the re-establishment of a thalwag and more natural low flow
channelshape.
2. The memo introduction was modified to incorporate model results including a table showing the predictions for
minimum DO using the updated and enhanced QUAL2K model. The text also makes note of the margin of safety
(MOS) incorporated with the proposed WLA/updated NPDES permit limits.
3. More specifics were added to the recommended monitoring strategy to identify what will be done to track the
relationship between DO and channel condition.
We trust that you will find that these revisions address your concerns and provide the scientific documentation
necessary to proceed with permit renewal and permitting of the expanded flow as previously discussed with the City.
Terry Houk, Director of Public Services for the City, has requested that you communicate with him as soon as possible on
next steps for issuing the updated permit. Please do not hesitate to call if you have any further questions.
Thank you,

Trevor
Trevor Clements I Principal/Program Manager
Direct: 919.485.2058 1 Main: 919.485.8278 1 Fax: [phone]
trevor.clem entsCa)tetratech. com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
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Banihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Thursday, January 02, 2020 10A6 AM
To: Grcyb, Julie; Banihani, Qais
Cc: Terry Houk ([e-mail]); Derrick Boone; Yonce, Hillary; Glenn Dunn
([e-mail]); Crabtree, Taylor
Subject: (External] Revised Memo Supplementing High Point Westside WRF Rich Fork Creek EA
Attachments: Tt Memo -High Pt _Rich Fork Channel Changes -Revised 1-2-2020.pdf
Good Morning Julie and Qais,
Happy New Year. To get 2020 off to a good start, I'm pleased to submit on behalf of the City of High Point the attached
revised version of the memo supplementing the previous EA for the High Point Westside facility and its impact on Rich
Fork Creek.
The revised memo reflects the conversation that I had on 12/13/19 with Julie that reinforced what Qais had told me
earlier in the month. In summary, DWR asked the City to address the following three concerns to meet agency
expectations:
1. Increase photo documentation in the memo
2. Incorporate expanded text regarding the citation of the updated modeling
3. Provide a few more specifics in the proposed monitoring strategy
In the attached revised version, these concerns were addressed as follows:
1. New figures 5 and 6 were input to show the dramatic change at Ball Road regarding thalwag re-establishment
and narrowing of channel in which flow occurs during low flow periods. Figures 16 and 17 were inserted to
clearly show how three of the largest debris dams observed in 2010 are completely gone under current aerial
imagery. Figures 18 — 20 were also inserted to reinforce similar evidence at one of the other main debris dams
previously observed between HWY 109 and Kanoy Road. While these photos provide visual evidence, we ask
you to not lose sight that the most overall compelling evidence is in the time of travel data collected through
dye studies which clearly demonstrate considerable increases in stream velocity that may be attributed to the
collective impact of a restored thalwag and narrower channels of flow in the previously pooled segments. Text
was added in these sections to further emphasize the re-establishment of a thalwag and more natural low flow
channelshape.
2. The memo introduction was modified to incorporate model results including a table showing the predictions for
minimum DO using the updated and enhanced QUAL2K model. The text also makes note of the margin of safety
(MOS) incorporated with the proposed WLA/updated NPDES permit limits.
3. More specifics were added to the recommended monitoring strategy to identify what will be done to track the
relationship between DO and channel condition.
We trust that you will find that these revisions address your concerns and provide the scientific documentation
necessary to proceed with permit renewal and permitting of the expanded flow as previously discussed with the City.

Terry Houk, Director of Public Services for the City, has requested that you communicate with him as soon as possible on
next steps for issuing the updated permit. Please do not hesitate to call if you have any further questions.
Thank you,
Trevor
Trevor Clements I Principal/Program Manager
Direct: 919.485.2058 1 Main: 919.485.8278 1 Fax: [phone]
trevocclementsCalletratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
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MEMORANDUM
To: Terry Houk, Director of Public Services
City of High Point
From: Trevor Clements, Principal
Hillary Yonce, P.H.
Date: January 2, 2020
Subject: Documentation of Physical Changes to the Rich
Fork Creek Stream Channel
Tetra Tech Engineering, P.C.
One Park Drive, Suite 200 • PO Box 14409
Research Triangle Park, NC 27709
Tel [phone] • Fax [phone]
The content of this memorandum was compiled by Tetra Tech on behalf of the City of High Point to
document changes to the Rich Fork Creek receiving stream for the Westside Water Reclamation Facility
(WRF) (National Pollutant Discharge Elimination System [NPDES] Permit No. NC0024228) since the
Environmental Assessment for the facility's expansion was completed.
Previous permit conditions for the expansion of the Westside WRF required stream restoration based on
environmental studies at the time to support assimilative capacity of the receiving waterbody in meeting
the water quality standard (WQS) for dissolved oxygen (DO). Westside WRF is located outside of High
Point, NC, in Davidson County and discharges near the headwaters of Rich Fork Creek, which flows
southbound for about 12 miles before reaching a confluence with Abbotts Creek. When the previous
permit conditions were identified as a requirement for the WRF expansion to allow Rich Fork Creek to
meet the instream WQS for DO (5.0 milligrams per liter [mg/1]), conditions along Rich Fork Creek were
significantly different than they are today, which this memo documents and clarifies in detail.
Recent extensive monitoring and modeling efforts conducted by Tetra Tech have shown that the
significant changes along Rich Fork Creek have improved hydraulics and represent a much different
stream condition than existed over a decade ago and upon which the original expansion permit conditions
were based. Specifically, the channel profiles in portions of Rich Fork Creek observed in 2006-7 as
impacted by sand mining have improved naturally, and areas of the stream previously noted by Tetra
Tech as having excessive treefall, including large tree debris dams, are now exhibiting more natural
levels. Based on the weight of evidence provided herein, it is our recommendation that the previous
permit condition requiring stream restoration be removed from the City's Westside NPDES permit. It is our
professional opinion that the restoration requirement is no longer warranted as conditions instream have
improved, and the newly calibrated and corroborated QUAL2K stream model verifies that the expanded
Westside WRF discharge can be assimilated under existing channel conditions with a substantial margin
of safety. A summary of these documented changes is provided herein.

Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
Results from the intensive 2017 monitoring studies and subsequent modeling studies show that the
observed physical channel changes documented in this memorandum have led to increased assimilative
capacity in Rich Fork Creek. For specific information related to the monitoring, model development, and
application, please refer to the Model Evaluation for Rich Fork Creek: New Data and Analyses Report
(Tetra Tech, 10-26-18), and the Westside WRF Wasteload Allocation Scenario Result and Proposed
Permit Limits memorandum (Tetra Tech, 7-26-2019). The results of these combined efforts reveal that
under critically low flow conditions (7Q10) during both summer and winter periods, the WQS of 5.0 mg/I
DO is not violated when the Westside WRF effluent flow and water quality are simulated at proposed
permitted maximums. Specifically, the proposed permit limits for effluent flow and key water quality
constituents are shown below in Table 1, alongside the associated instream minimum DO concentration
predicted by the updated and enhanced QUAL2K model. Note that the model scenario application
includes a margin of safety (MOS) of 5 percent to ensure that the WQS protection more conservatively.
Table 1. Rich Fork Creek QUAL2K model WLA scenarios results: instream DO and NH3.
Summer - 7.0
U�
2 10.0 1.0 10,0 5.27
3 Winter 8.2 7.0 2.0 4.0 5.25 5.81
4 10.0 1.8 8.0 6.03
FLOW DATA
Stream flow can have a powerful influence on stream channel hydraulics. Although there is not a long-
term flow monitoring gage located along Rich Fork Creek, a U.S. Geological Survey (USGS) gage located
on the adjacent Abbotts Creek (USGS 021201500 Abbotts Creek at Lexington, NC) has been used to
approximate flow conditions along Rich Fork Creek throughout the monitoring and modeling work
conducted since 2006. Data from that USGS gage indicate that some very high flows have occurred in
the past decade that could be a primary factor in the changes in stream channel hydraulics observed over
the past ten years and described in greater detail below.
Flow records along Abbotts Creek since 2007 to the present time (i.e., that follow the initial intensive
stream surveys of Rich Fork Creek performed by Tetra Tech) reveal an average daily flow of
approximately 168 cubic feet per second (cfs) and a median daily flow of 73 cfs. The maximum flow
recorded and validated at the Abbotts Creek gage was 8,000 cfs measured in 2003. Since fall 2007, three
flows approaching the maximum (above 7,500 cfs) have been recorded. Additionally, eight flows have
been measured above 6,000 cfs. The 95th percentile of flow reported by USGS is 600 cfs, so Abbotts
Creek has experienced eight events since our 2007 studies that are more than 10 times the 95th
percentile flow.
The Abbotts Creek flow gage has been used effectively to estimate flows in Rich Fork Creek via a
demonstrated strong relationship between gaged flows in Abbotts Creek and point measurements of flow
along Rich Fork Creek. Using drainage area analyses at three points along Rich Fork Creek at locations
of historical sand mining operations, we can roughly estimate flow using Abbotts Creek flow data in two
ways:
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Memo Documenting Changes to Rich Fork Creek Stream Channel January2, 2020
1. Using a drainage area ratio relative to the Abbotts Creek USGS gaging station, and
2. Using an empirical relationship between observed flows along Abbotts Creek and along Rich Fork
Creek during field monitoring investigations (empirical linear regression equation has an R-square
of 0.85).
Those two methods result in the following Rich Fork Creek flow approximations at Highway 109, Ball
Road, and Kanoy Road crossings during those eight highest flow events along Abbotts Creek:
1. Drainage area ratio method: flow range of 860-1,390 cfs
2. Empirical regression method: flow range of 1,750-2,830 cfs
The range of flows likely to have occurred along Rich Fork Creek during the eight largest events in
Abbotts Creek is approximately 35-90 times greater than the average annual flow in Rich Fork Creek
depending on location. High -flow events so far above average can create shear velocities that move
sediment and debris, change channel shape, and are capable of reforming stream banks as was
observed during the 2017 monitoring studies.
CROSS -SECTIONAL AND HYDRAULIC MEASUREMENTS
Due in part both to the cessation of sand mining activities in the vicinity of Ball Road and Kanoy Road and
to the large flow events that have helped reshape Rich Fork Creek, significant changes have occurred in
channel geometry over the past decade. This section discusses the areas identified a decade ago as
having active sand mining and pools, with specific details about how those areas have changed over
time. Changes can be observed in channel geometry, aerial imagery, and time -of -travel (TOT) studies. In
2009, subcontractor team Davis, Martin, and Powell & Associates (DMP) measured extensive pool cross
sections that were compared to more recent measurements from 2017-2019. The more recent studies
show how a more traditional thalwag forming in the stream channel and flow no longer extending from
bank to bank under low flow conditions.
Ball Road
Downstream of Ball Road active sand mining occurring in the 2007-2009 period was ceased at some
point between observations during the 2017-2019 field studies. DMP conducted extensive surveys in late
January 2009 across the Ball Road pool area (Figure 1). The widest portion of the pool was measured at
cross-section K to be 56.6 feet (ft), and the deepest portion of the pool was measured at cross-section J
to be 5.5 ft, with an average depth through the pool of approximately 3 ft. Based on flow at the Abbotts
Creek USGS gage, flow at Ball Road at the time of those surveys was approximately 13 cfs.
In the area of cross -sections L, J, and K identified as the pool extent in 2009, new cross -sections were
measured on August 6, 2019, immediately downstream of Ball Road. Flow conditions were approximately
11 cfs at Ball Road based on the Abbotts Creek gage, similar to conditions observed during the 2009
surveying. Average water depth observed in 2019 was around 0.8 ft (more than a 70 percent reduction),
and the maximum water depth observed was 1.5 ft (also more than a 70 percent reduction). Bank -to -bank
channel width observed in 2019 was approximately 38 ft, with an average wetted width of 25 ft.
Sand and silt deposits have filled in the old Ball Road pool since the cessation of sand mining activities,
and the creek has returned to a more natural geometry with a clear thalweg and highly vegetated banks
(Figure 2 and Figure 3). In Figure 4, note the differences in both width and depth at the cross -sections
taken at approximately the same location under similar flow conditions. The cross -sectional shape
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
difference (narrower with a thalwag directing flow pattern) is representative of the magnitude of change
observed throughout this segment of the receiving stream.
Additionally, between April 2013 and April 2014, the Ball Road bridge crossing of Rich Fork Creek was
updated and replaced by the North Carolina Department of Transportation from a bridge with wooden
posts and rails to a fully concrete bridge. That change might also have had an impact on stream and
sediment hydraulics.
On August 28, 2007, a Rhodamine WT dye release was used to conduct a TOT study upstream of the
Ball Road pool. Based on the relationship of flow between Abbotts Creek and Rich Fork Creek, flow at
Ball Road on that date was estimated at approximately 9.5 cfs and the velocity was observed in the dye
study to be about 0.3 feet per second (ft/s). A TOT study conducted on June 2, 2017, in the same vicinity
of Ball Road found a velocity of 0.6 fUs best represents the existing velocity through that segment, which
is much greater than was observed and estimated in the vicinity in 2007. Flow conditions on that day
were approximately 14.4 cfs at Ball Road. The doubling of velocity can be largely attributed to the
narrower portion of stream in which the volume of water was flowing.
Figure 1. Aerial imagery of cross sections measured in the vicinity of Ball Road observed in 2009.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January2, 2020
Figure 2. Water -level photo of the Ball Road pool, looking upstream at the old bridge (January 2009).
Figure 3. Water -level photo of the former Ball Road pool, looking downstream (August 6, 2019).
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
4= 1
3 2.5
3.5
Waters Edge to Waters Edge (ft)
0.0 10.0 MO 30.0 40.0 50.0 60.0
—Feb-09 —Aug-19
Figure 4. Representative 2009 vs 2019 water depth cross section across the former Ball Road pool.
Figure 5. Ball Road sand mining impacts and vertical banks as observed on March 1, 2010.
Figure 6. Ball Road images from August 6, 2019 showing revegetation of banks and reshaping of channel
after the cessation of sand mining activities.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
Kanoy Road
The pool created by sand mining at Kanoy Road was observed in 2007 to begin above the bridge and
extend well downstream of the bridge, measuring about 80 ft at its widest point downstream of the bridge
(Figure 7). Between 2007 and 2017, the sand mining permitted at Kanoy Road ceased (exact timing
unknown). Field measurements from 2017 showed the previously widest location to be about 18-22 ft
(more than a 70 percent reduction), and aerial imagery from February 3, 2018, suggests the widest part
of the pool might now be located upstream of Kanoy Road, measuring around 68 it across upstream of
the bridge with sand bars visible (Figure 7). Conditions depicted in Figure 7 are representative of field
measurements taken by DMP January 22-25, 2009, and Tetra Tech August 6, 2019 , when flow
conditions at Kanoy Road were approximately 13.6 cfs and 11.5 cfs, respectively.
Figure 7. Aerial imagery of sand mining pool downstream of Kanoy Road observed in 2007 (left). Aerial
imagery of sand mining pool downstream of Kanoy Road observed on 2/3/2018 (right).
DMP conducted extensive surveys January 22-25, 2009, across the Kanoy Road pool area (Figure 8).
The widest portion of the pool was measured to be 84.2 ft at cross-section K, and the deepest portion of
the pool was measured to be 6.1 It at cross-section N. On August 6, 2019, in the area of cross -sections G
through O identified as the pool extent in 2009, Tetra Tech measured new cross -sections where flow
conditions at Kanoy Road were approximately 12.3 cfs.
The entire extent of the old Kanoy Road pool has in -filled with extensive sand and silt, resulting in a far
shallower channel (see Figure 9 compared with Figure 10). Average channel width between cross -
sections G and O in 2009 was approximately 57.6 ft, and the average depth was approximately 2 ft. The
average channel width observed around Kanoy Road in 2019 was 37 ft (more than a 35 percent
reduction) and, at its widest, it was 53 ft (more than a 37 percent reduction). A representative channel
depth was observed to be 1 ft (an approximately 50 percent reduction), and the maximum observed depth
was approximately 2 ft (an approximately 67 percent reduction). A representative comparison of channel
shapes between the earlier and current conditions is shown in Figure 11, illustrating the substantial
changes that have occurred over the past decade. As was the case for Ball Road, the photos and cross-
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
sections demonstrate a narrowing of the portion of channel carrying water under low flow conditions, with
a thalwag reestablishing itself in these previously pooled regions.
Figure 8. Aerial imagery of cross sections measured in the vicinity of Kanoy Road in 2009.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
Figure 9. Kanoy Road pool on downstream end of bridge (January 2009).
Figure 10. Old Kanoy Road pool looking downstream from under bridge (August 6, 2019).
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
0.5
1
x 1.5
o.
2
p 2.5
3
3 3.5
4
4.5
Waters Edge to Waters Edge (ft)
0 10 20 30 40 50
—Feb-09 —Aug-19
it
Figure 11. Representative 2009 vs 2019 water depth cross-section across the former Kanoy Road pool.
Highway 109
All field work conducted between 2007-9 and 2017-19 in the vicinity of Highway 109 found stream
geometry being shaped by active sand mining (see representative photos in Figure 12 and Figure 13).
DMP conducted extensive surveys in 2009 beginning upstream of the sand mining areas and extending
downstream of Highway 109 (Figure 14). Tetra Tech measured several cross -sections in 2017 within the
same zone and made additional field observations in 2019. The deepest area observed in 2009 was
measured at 5.1 ft at cross-section T in a pool located downstream of Highway 109, while upstream of
Highway 109 the water was considerably shallower. During field work conducted from 2017 to 2019,
Tetra Tech field staff found that no pool existed downstream of Highway 109, but that a large pool
extended from the sand mining location upstream of Highway 109 to the highway crossing. The channel
proportions of the Highway 109 pool as measured in 2017 were incorporated into the updated QUAL2K
model completed by Tetra Tech and delivered to DWR to account for the continued influence of sand
mining at this location.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
Figure 12. Active sand -mined pool upstream of Highway 109 (January 22, 2009).
Figure 13. Active sand -mined pool upstream of Highway 109 (August 6, 2019).
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
Figure 14. Aerial imagery of cross sections measured in the vicinity of Highway 109 in 2009.
TREEFALL DEBRIS DAMS
Areas with excessive tree -fall debris can influence stream velocity significantly at low flows and during
storm flows causing localized scour pools, which further decrease stream velocity during summer low -flow
conditions and subsequently lower DO concentrations instream. Tetra Tech field personnel took
photographs and recorded locations of treefall debris and logjams during a field visit to Rich Fork Creek in
2007, 2009, and 2010. The differences field crews observed between instream treefall in 2007-2010 and
in a 2017 monitoring study suggest that far fewer logjams existed than a decade ago. The large number
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
of significant regional flow events are likely responsible for breaking up the excessive number of logjams
observed a decade ago. A photograph of the treefall debris dam significantly impeding flow downstream
of Ball Road In 2009 is shown in Figure 15. That debris dam was no longer present at the site when it was
visited in 2017.
Figure 15. Facing downstream at a major debris dam below Ball Road pool January 24, 2009.
Downstream of Ball Road there were a series of large downed trees and debris dams which are easily
visible from Google Earth aerial imagery dated in July 2010 (Figure 16). The same extent shown updated
with aerial imagery downstream of Ball Road from February 2019 reveals that these debris locations have
been cleared out over time due to natural phenomena and channel morphological changes (Figure 17).
Figure 16. Major debris dams and treefalls seen from July 2010 Google Earth aerial imagery immediately
downstream of Ball Road.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
Figure 17. Lack of debris dams and treefalls seen from February 2019 Google Earth aerial imagery
immediately downstream of Ball Road.
Treefall data were compiled in 2009 based on aerial photography captured by Spatial Data Consultants
over the entirety of Rich Fork Creek. Tetra Tech generated a corresponding shapefile that resulted in an
estimate of between 300 and 500 individual treefall sites between Highway 109 and Kanoy Road. At that
time, the frequency of cross -stream treefall occurrence in that zone was approximately double the
frequency observed downstream of that point.
Not all treefall areas result in compromising stream hydraulics, so primarily large-scale debris dams are of
interest for potential removal to improve stream conditions. An example of a debris dam downstream of
Highway 109 observed by the 2009 flyover imagery and seen in ground -level photography is shown in
Figure 18 and Figure 19. That debris dam also can be seen to have changed over time using Google
Early aerial imagery from 2012 and 2013 (Figure 20). The logjam can be observed in February 2012 but
is no longer present in April 2013. In the intervening period, there were 3 days with flow in Abbotts Creek
greater than 1,000 cfs, which likely translated to flows in Rich Fork Creek that helped break up the debris
dam.
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
1 I
Fallen Tree
Debris Danwith
Deeper Water
on Upstream
and Shallow Water
Downstream
Side
Figure 18. Treefall logjam from chartered flight aerial imagery downstream of Highway 109 (2009).
F
J4
Figure 19. Ground -level photos of the large treefall logjam downstream of Highway 109 (2009).
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Memo Documenting Changes to Rich Fork Creek Stream Channel
January 2, 2020
Figure 20. Treefall logjam visible in Google Earth aerial imagery in February 2012 (left) no visible treefall
logjam in the same location in April 2013 (right).
These examples illustrate the extent of change that contribute to the improved hydraulics summarized
above in the hydraulic measurements discussion.
WATER QUALITY DATA
Yadkin Pee Dee River Basin Association (YPDRBA) operates three long-term water quality sampling sites
located along Rich Fork Creek (Table 2). YPDRBA water quality data is available online to account users
(such as the City of High Point) and is generally uploaded to the online system within about 3 months of
the sampling time.
Table 2. Water quality sampling sites along Rich Fork Creek (YPDRBA)
Q5745000 Rich Fork Creek at SR 1757 (Chestnut Street) near 2010-2019 6.2 5.8
High Point (one sample)
Q5785000 Rich Fork Creek at SR 17902 (Kanoy Road) near
High Point
Q5790000 Rich Fork Creek at SR 2123 (Old Highway 29) near
High Point and Lexington
Q5750000 Rich Fork Creek at SR 1755
1998-2019 2.9 5.1
1998-2019 3.2 5.5
1998-2009 3.3 No Data
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
Water quality data results show that over the past 9 years (since 2011), minimum DO concentrations
have not been observed below the WQS (5.0 mg/1) along Rich Fork Creek. Average DO concentrations
have remained relatively constant from 2000 to 2019 at all gages along Rich Fork Creek; however, the
improvement in minimum DO concentrations is clear in recent years.
CONCLUSIONS AND RECOMMENDATIONS
In summary, the physical properties of Rich Fork Creek have changed over the past decade, likely
attributable to large flow events shaping stream hydraulics along with the cessation of sand mining
activities at both Ball Road and Kanoy Road. The recent wasteload allocation QUAL2K modeling efforts
and model calibration report associated with the Westside WRF plant expansion demonstrate that Rich
Fork Creek has improved assimilative capacity over conditions existing in 2007. Results of the modeling
effort have shown that under both future effluent flow conditions, Rich Fork Creek is capable of
assimilating these new effluent flow scenarios under critically low 7010 conditions. Previous
recommendations to perform stream restoration at multiple locations are no longer needed to increase
assimilative capacity to maintain DO levels above the WQS. We recommend that the City request of the
North Carolina Division of Water Resources that those previous requirements for discharge expansion be
removed from future NPDES permit documents.
The City had acknowledged to Tetra Tech that it recognizes the importance of Rich Fork Creek remaining
hydraulically stable and able to naturally assimilate the expanded effluent discharge from Westside WRF
over time. Therefore, we recommend that the City commit to taking reasonable steps to monitor water
quality conditions and identifying potential threats to stream assimilative capacity associated with stream
hydraulics. Given that sand mining activities are no longer permitted near Ball and Kanoy roads, a greater
threat to Rich Fork Creek hydraulics may now be associated with any future significant treefall debris
dams that have the potential to slow water velocity significantly and decrease natural channel reaeration
rates. Therefore, we recommend the following strategy:
As part of its NPDES Permit monitoring requirements, the City will review YPDRBA water quality
data annually for any trends in reduction in DO concentration that could be indicative of changes
to channel hydraulics that could threaten assimilative capacity. If water quality data suggest
potentially reduced assimilative capacity (DO concentrations below the WQS at any of the
sampling sites along Rich Fork Creek), the City will conduct additional investigation as to potential
causes that could be contributing to degraded stream water quality conditions. For example, if
there is a DO concentration violation of the WQS observed at downstream YPDRBA station
Q578500 at Kanoy Road and/or station Q5790000 at Old Highway 29, the City will analyze
YPDRBA water quality data upstream of the outfall at station 05745000 at SR1757 to ascertain
whether the low DO condition may be indicative of a system -wide DO decline or may be isolated
to a specific stream segment. When review determines that DO decline is confined to portions of
the receiving waters downstream of the Westside ouffall, the City will review effluent water quality
data prior to the period of the low DO observation to see if there may be an issue with plant
operation which could have triggered the WQS violation. Findings of such investigations shall be
communicated to the DWR regional office for further review.
If YPDRBA and/or DWR monitoring personnel observe excessive treefall or have due cause to
suspect streamflow obstruction in conjunction with observed low DO concentrations, the City will
perform additional reconnaissance activities to identify potential treefall debris dams which may
be causing changes to stream hydraulics which are negatively impacting the assimilative capacity
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Memo Documenting Changes to Rich Fork Creek Stream Channel January 2, 2020
of Rich Fork Creek. Reconnaissance activities might include reviewing readily available streaming
aerial imagery (from Google Earth, Arclvap, or Davidson County) and brief field investigations at
key locations subject to debris obstruction such as those areas near Ball Road, Kanoy Road,
Midway School Road, and Highway 109 crossings. Where access may not be feasible or
practical, the City may choose to conduct fly -over investigations of Rich Fork Creek (ideally
during the winter months when there is low leaf -cover and clear imagery of the channel) in lieu of
manual field inspection to identify potentially problematic treefall debris dams. Findings of such
investigations shall be communicated to the DWR regional office for further review.
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Banihani, Qais
From: Behm, Pamela
Sent: Monday, December 09, 2019 4:05 PM
To: Banihani, Qais; Wainwright, David
Cc: Kebede, Adugna; Hong, Bongghi
Subject: RE: High Point WWTP SEPA Issue
I don't think that the modelers wanted a tree fall model scenario, this comment is derived from reviewing the EA
addendum which stated that channel conditions appear to have improved because high flow events have cleared out
the tree fall. However, one of the primary reasons the original EA was written with restoration included was because
the tree fall was so significant, it altered water quality and caused low DO conditions.
So, what language is needed in the permit to show that Ions will be monitored and acknowledge that permit limits
may need to be altered if conditions deteriorate again. There has been no restoration, no streambank stabilization or
anything that would lead us to believe that these conditions could not come back. Again, this is because the original EA
was so heavily focused on the tree fall and the impacts. Otherwise, I think the response is the same for any permit, tree
fall happens everywhere.
This comment is really for permitting to address, not the permittee. If you are good with the recommendation provided
in the report that looking at the YPDRBA water quality data and perform investigation if the stream condition appears
deteriorated is sufficient, then that's fine. We just needed to go on record with this concern.
Thanks,
Pam
From: Banihani, Qais <[e-mail]>
Sent: Tuesday, December 03, 2019 7:50 AM
To: Behm, Pamela <[e-mail]>; Wainwright, David <[e-mail]>
Cc: Kebede, Adugna <[e-mail]>; Hong, Bongghi <[e-mail]>
Subject: RE: High Point WWTP SEPA Issue
Good morning Pam,
I am not quite clear on how to address your second comment 2.b in my response to the Permittee. Are you asking that
the Permittee needs to rerun the QUAL2K model to simulate the effects of the treefall? I personally do not think this will
be an easy task.
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihaniCdncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617

11E
En vit YJrt rriPn t (r/
Quulit v
From: Behm, Pamela <[e-mail]>
Sent: Thursday, November 14, 2019 1:23 PM
To: Banihani, Qais <[e-mail]>; Wainwright, David <[e-mail]>
Cc: Kebede, Adugna <[e-mail]>; Hong, Bongghi <[e-mail]>
Subject: RE: High Point WWTP SEPA Issue
We have not had time to do a thorough review. Initial thoughts:
1. Document does not include photographic evidence to show that previously demonstrated tree fall areas have
been cleared out.
2. The WLA estimation by the latest QUAL2K model is done under the "existing channel conditions" as the EA
document states. In addition, in contrast to the original model, the updated model developed in support of this
request was developed to represent 7410 + discharge conditions. No simulation has been made under the
possible deteriorated channel conditions. There are two factors that could contribute to the potential future
deterioration: sand mining and treefall debris.
a. Regarding sand mining, the permit does not allow for deteriorated stream conditions, and any future
permitted sand mining activities should be evaluated under an individual permit condition, rather than
the general permit currently in place.
b. With regards to treefall, slowing down of the stream's velocity due to treefall debris, as observed in this
stream in the past, should certainty be regarded as a recurring condition. The EA document states that
the channel conditions appear to have improved due to very high stream flows that probably occurred
sometime after 2012. There will be continuous treefalls in the future even if the current channel is
mostly clear, and we cannot rely on high storm events clearing the flow paths once in a while. The
recommended commitments by the City suggested in the EA document seems inadequate. With the
stream restoration requirement removed, all it promises is to look at the YPDRBA water quality data and
perform investigation if the stream condition appears deteriorated. Without the means to enforce the
stream restoration activities when it deteriorates due to treefall debris, there may not be much choice
other than to reduce the permitted effluent limits further (the magnitude of which could be estimated
from the latest QUAL2K model).
From: Banihani, Qais <[e-mail]>
Sent: Wednesday, November 06, 2019 7:34 AM
To: Wainwright, David <[e-mail]>; Behm, Pamela <[e-mail]>
Subject: High Point WWTP SEPA Issue
Good morning,
If you have any comments regarding the submitted EA for the City of High Point, please send it to me by next
Wednesday (11/13). 1 am planning on sending all comments to the Permittee by the end of next week.

Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
aais.banihani@ncdenr.¢ov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
F_nvlronmenfca/
Quality

Banihani, Qais
From: Behm, Pamela
Sent: Thursday, November 14, 2019 1:23 PM
To: Banihani, Qais; Wainwright, David
Cc: Kebede, Adugna; Hong, Bongghi
Subject: RE: High Point WWTP SEPA Issue
We have not had time to do a thorough review. Initial thoughts:
Document does not include photographic evidence to show that previously demonstrated tree fall areas have
been cleared out.
2. The WLA estimation by the latest QUAL2K model is done under the "existing channel conditions" as the EA
document states. In addition, in contrast to the original model, the updated model developed in support of this
request was developed to represent 7Q10 + discharge conditions. No simulation has been made under the
possible deteriorated channel conditionAhere are two factors that could contribute to the potential future
p ✓ ��'I
deterioration: sand mining and treefall debris. hce
l�
91 Regarding sand mining, the permit does not allow for deteriorated stream conditions, and any future
permitted sand mining activities should be evaluated under an individual permit condition, rather than
the general permit currently in place.
b. With regards to treefall, slowing down of the stream's velocity due to treefall debris, as observed in this
stream in the past, should certainty be regarded as a recurring condition. The EA document states that
the channel conditions appear to have improved due to very high stream flows that probably occurred
sometime after 2012. There will be continuous treefalls in the future even if the current channel is
mostly clear, and we cannot rely on high storm events clearing the flow paths once in a while. The
recommended commitments by the City suggested in the EA document seems inadequate. With the
stream restoration requirement removed, all it promises is to look at the YPDRBA water quality data and
perform investigation if the stream condition appears deteriorated. Without the means to enforce the
stream restoration activities when it deteriorates due to treefall debris, there may not be much choice
other than to reduce the permitted effluent limits further (the magnitude of which could be estimated
from the latest QUAL2K model). f ��iv `L 1
From: Banihani, Qais <[e-mail]>
Sent: Wednesday, November 06, 2019 7:34 AM
To: Wainwright, David <[e-mail]>; Behm, Pamela <[e-mail]>
Subject: High Point WWTP SEPA Issue
Good morning,
If you have any comments regarding the submitted EA for the City of High Point, please send it -to me by next
Wednesday (11/13). 1 am planning on sending all comments to the Permittee by the end of next week.
Thanks,
Qais Banihani
Environmental Engineer

NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihani (lncdenr.gov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
E'»vAwnma»ta/
Qtuct/tt y

Banihani, Qais
From: Banihani, Qais
Sent: Tuesday, November 19, 2019 9:17 AM
To: Grzyb, Julie
Cc: Wainwright, David
Subject: RE: High point- Westside permit
I am planning on summarizing David and Pam comments and send it to the Permittee along with my comments. I will
copy everyone on the email.
I already called Trevor and he is expecting to receive our comments after Thanksgiving Holiday.
I will be using my 40-hr bonus for my time off.
Qals Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
9197073607 office
a a i s. b a n i h a n i@ n cd e n r. ¢o v
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
11E
En vrt-on nr en rci r
Q«cu11r v
From: Grzyb, Julie <[e-mail]>
Sent: Tuesday, November 19, 2019 8:56 AM
To: Banihani, Qais <[e-mail]>
Cc: Wainwright, David <[e-mail]>
Subject: Re: High point- Westside permit
Qais,
Are you stating that the comments on the revised EA from David and Pam need to be summarized and sent to the
permittee along with your review?
If so, I don't see a need for a meeting unless you want clarification on their comments.
Your choice.
Please copy me on the letter when it is sent.
Also, your email is not clear - are you taking The next three days as approved leave?Thanks,
Julie

On Nov 19, 2019, at 8:42 AM, Banihani, Qais <[e-mail]> wrote:
Hi Julie,
David and Pam submitted their comments which I already forwarded to you in two separate emails. I
will go over the comments next week since I am taking this Wednesday — Friday off.
I am ok with having a meeting but we should also include Pam and I am planning to send our comments
to the Permittee after our internal meeting if we are planning to have one.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
gais.banihani(&ncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
<image001.jpg>
From: Grzyb, Julie <[e-mail]>
Sent: Monday, November 18, 2019 3:58 PM
To: Banihani, Qais <[e-mail]>
Cc: Wainwright, David <[e-mail]>
Subject: High point- Westside permit
Qais,
Last Friday I received a call from Trevor Clements inquiring about the status of the High point Westside
Permit. Can you please bring me up-to-date.
Is David Wainwright satisfied with the revised EAA. Should we have a meeting between David, Drew,
you and I to discuss how to move this permit forward? 1`
Thanks,
Julie
Julie A Grzyb
Supervisor
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3605 office
919 707 9000 main office
iulie.grzvb(o)ncdenr.gov
Physical Address: 512 North Salisbury St., Raleigh, NC, 27604

Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Banihani, Qais
From: Wainwright, David
Sent: Tuesday, November 12, 2019 9:00 AM
To: Banihani, Qais
Subject: RE: High Point WWTP SEPA Issue
Qais,
Thanks for sending the WLA report, it helps a lot. After considering the WLA and reviewing the memo again, I just think
the DO discussion is not supported in the memo. The discussion appears to be based on the results of the WLA report,
but the report is not referenced or tied to the WLA report and needs to be. One way to do this would be to include the
WLA report as an attachment to the memo and include a discussion in the memo about the results of the WLA report.
Thanks,
David Wainwright
David Waimiright
SEPA Coordinator, Division of Water Resources
North Carolina Department of Environmental Quality
D' r� 919.707.9045 (Office)
David.NVainiN right dncdenr.goti-
From: Banihani, Qais
Sent: Wednesday, November 06, 2019 7:34 AM
To: Wainwright, David <[e-mail]>; Behm, Pamela <[e-mail]>
Subject: High Point WWTP SEPA Issue
Good morning,
If you have any comments regarding the submitted EA for the City of High Point, please send it to me by next
Wednesday (11/13). 1 am planning on sending all comments to the Permittee by the end of next week.
Thanks,
Qais Banihani

Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihani(n)ncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En v(tnnmen ta!
Qucal(t y

Banihani, Qais
From: Banihani, Qais
Sent: Wednesday, October 30, 2019 8:56 AM
To: Wainwright, David; Grzyb, Julie
Cc: Crabtree, Taylor, Poupart, Jeff, Gregson, Jim
Subject: RE: [External] High Point WWTP SEPA Issue
Attachments: Westside WLA Memo 7-26-2019.pdf
David,
The City of High Point -West Side submitted WLA back in July 2019 and the Modeling and Assessment branch are ok with
their WLA. Attached is the WLA.
The report is missing discussion on the WLA.
Qais
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihaniCalncdenr.eov
Physical Address: S12 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, INC, 27699-1617
Environmental
Quality
From: Wainwright, David <[e-mail]>
Sent: Wednesday, October 30, 2019 8:35 AM
To: Grzyb, Julie <[e-mail]>
Cc: Banihani, Qais <[e-mail]>; Crabtree, Taylor <[e-mail]>; Poupart, Jeff
<[e-mail]>; Gregson, Jim <[e-mail]>
Subject: RE: [External] High Point WWTP SEPA Issue
Julie and Qais,
I have looked over the memo. Based on the lack of information provided in the memo, is there additional
documentation that has been submitted; most notably the results from the QUAL2K modeling?
I have a few comments with the memo:

I'm concerned about the lack of supporting DO data. They present a table that only has minimum DO
observations. The data is said to be from the YPDRBA but is not properly referenced. It states that "Average DO
concentrations have remained relatively constant from 2000-2019 at all gages along Rich Fork Creek..."
However, no data whatsoever is presented to support this statement, and again, no reference as to where this
data can be found is included. Furthermore, they present a single DO observation from sometime between
either 2000-2010 or 2011-2019 for each of three sites and declare that "Water quality results show that over the
past nine years (since 2011), minimum DO concentrations have not been observed below the WQS (5.0 mg/L)
along Rich Fork Creek." I don't agree that one observation, which isn't stated when it was taken, is sufficient
enough to support this statement, and again, no proper reference is included to get additional information. I
can't agree with "...the improvement in minimum DO concentrations is clear in recent years" based on the
information provided.
As with the DO, it is claimed that the flows have increased since 2007 but other than what is discussed in the
text, no data is presented to confirm this. I realize that there is not a stream gage on Rich Fork Creek, but they
surrogate the information from the Abbots Creek gage, which is fully acceptable provided it can be shown that
the two are comparable (and they do). A graph or flow data table from the Abbots Creek gage comparing
historical data to data from 2007— present should be included to support the statements that flows have indeed
increased. Actual data comparing these two time frames should be compared and discussed to support that
flows have actually increased and not just base the conclusion on three high flow events.
The cover letter from High Point states that "DWR requested that High Point submit with the study of changed
stream conditions in Rich Fork Creek, a proposal to monitor conditions of the Creek in the future to ensure that
adequate assimilative capacity is maintained to continue meeting applicable water quality standards." Have
they submitted a proper monitoring plan? If one has been submitted, does the NPDES agree with the monitoring
plan? Has the Intensive Survey Unit had a chance to review the monitoring plan?
• In past comments, the NCWRC has been rather vocal about the restoration plan. Has their input been sought
with the updated plans? I know they will have a chance to comment on whatever is sent out for
review/comment, but I think it would be proper to include them earlier in the process rather than later.
They cite the QUAL21K modeling results, but again, the results are not referenced in the proper way. If someone
wanted to review the results, how would they? This is critical since the whole document and assumptions are
based on these results.
I'm not convinced based on the scant information provided in the memo that "...the restoration requirement
is no longer warranted as conditions instream have improved, and the newly calibrated and corroborated
QUAL21K stream model verifies that the expanded Westside WRF discharge can be assimilated under existing
channel conditions with a substantial margin of safety." As we have discussed, I will need to send something
out for agency review prior to modifying the FONSI. I strongly feel that if we send this memo out it would be
insufficient to satisfy some of the concerns reviewing agencies would likely have.
Thanks,
David
From: Grzyb, Julie
Sent: Friday, October 25, 2019 5:05 PM
To: Wainwright, David <[e-mail]>
Cc: Banihani, Qais <[e-mail]>; Crabtree, Taylor <[e-mail]>; Poupart, Jeff

<[e-mail]>; Gregson, Jim <[e-mail]>
Subject: RE: [External] High Point WWTP SEPA Issue
High Point's revised SEPA— David have you had a chance to look at it?
Qais will be looking at it this coming week — please contact Qais if you need a copy.
After you both have a chance to look at it —and you both get any revisions you believe are needed to make it adequate
- let's have a meeting between NPDES, David and Taylor to discuss how best to move forward.
Thanks,
Julie
From: Crabtree, Taylor [mailto:[e-mail]
Sent: Tuesday, August 20, 2019 9:09 AM
To: Wainwright, David <david.wainwri¢[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>
Subject: [External] High Point WWTP SEPA Issue
ATTORNEY CLIENT COMMUNICATION — TRIAL PREPARATION — NOT A PUBLIC RECORD
Hi David,
I'd like to set up a meeting with you regarding a SEPA issue at an NPDES facility. Can you please give me your availability
next Monday (8/26), Tuesday (8/27) and Thursday (8/29)? 1 will provide additional information in advance of the
meeting.
Thanks,
Taylor
Taylor Crabtree
Assistant Attorney General
Environmental Division
Phone: [phone]
[e-mail]
114 W. Edenton St., Raleigh, NC 27603
ncdoj.gov
Please note messages to or from this address may be public records.

Banihani, Qais
From:
Wainwright, David
Sent:
Wednesday, October 30, 2019 8:35 AM
To:
Grzyb, Julie
Cc:
Banihani, Qais; Crabtree, Taylor, Poupart, Jeff; Gregson, Jim
Subject:
RE: [External) High Point WWTP SEPA Issue
Julie and Qais,
I have looked over the memo. Based on the lack of information provided in the memo, is there additional
documentation that has been submitted; most notably the results from the QUAL2K modeling?
I have a few comments with the memo:
✓ I'm concerned about the lack of supporting DO
observations. The data is said to be from the YI
concentrations have remained relatively cons ti
However, no data whatsoever is presented toy
data can be found is included. Furthermore,
either 2000-2010 or 2011-2019 for each of hre
past nine years (since 2011), minimum D910
along Rich Fork Creek." I don't agree that one
t . They present a table that only has minimum DO
A but is not properly referenced. It states that "Average DO
from 2000-2019 at all gages along Rich Fork Creek..."
port this statement, and again, no reference as to where this
present a single DO observation from sometime between
, es and declare that "Water quality results show that over the
itr ions have not been observed below the WQS (5.0 mg/L)
ervat'ii�on, which isn't stated when it was taken, is sufficient
enough to support this statement, and again, no ,o rkeference is included to get additional information. I
can't agree with "..Ahc ;oiprovement in minimum DO concentrations ;s dear in recent years" baseu'un the
information provided.
• As with the DO, it is claimed that the flows have in eased since 2007 but other than what is discussed in the
text, no data is presented to confirm this. I reali that there is not a stream gage on Rich Fork Creek, but they
surrogate the information from the Abbots Creek gage, which is fully acceptable provided it can be shown that
the two are comparable (and they do). A graph or flow data table from the Abbots Creek gage comparing
historical data to data from 2007 — present should be included to support the statements that flows have indeed
increased. Actual data comparing these two time frames should be compared and discussed to support that
flows have actually increased and not just base the conclusion on three high flow events.
r The cover letter from High Point states that "DWR requested that High Point submit with the study of changed
stream conditions in Rich Fork Creek, a proposal to monitor conditions of the Creek in the future to ensure that
adequate assimilative capacity is maintained to continue meeting applicable water quality standards." Have
they submitted a proper monitoring plan? If one has been submitted, does the NPDES agree with the monitoring,
plan? tensiv�U�it-ha?1-a-chanceio-review the monitoring plan?
• In past comments the NCWRC has been rather vocal about the restoration plan. Has their input been sought
with the updated plans? I know they will have a chance to comment on whatever is sent out for
review/comment, but I think it would be proper to include them earlier in the process rather than later.
• They -cite the QUAL2K modeling results, but again, the results are not referenced in the proper way. If someone
wanted'tQreview tN&re ults, haw would they? This is critical since the whole document and assumptions are
based on these,results. �'

I'm not convinced based on the scant information provided in the memo that "...the restoration requirement
is no longer warranted as conditions instream have improved, and the newly calibrated and corroborated
QUAL2K stream model verifies that the expanded Westside WRF discharge can be assimilated under existing
channel conditions with a substantial margin of safety." As we have discussed, I will need to send something
out for agency review prior to modifying the FON51. I strongly feel that if we send this memo out it would be
insufficient to satisfy some of the concerns reviewing agencies would likely have.
Thanks,
David
\ v
From: Grzyb, Julie
w
Sent: Friday, October 25, 2019 5:05 PM
To: Wainwright, David <[e-mail]>
Cc: Banihani, Qais <[e-mail]>; Crabtree, Taylor <[e-mail]>; Poupart, Jeff
<[e-mail]>; Gregson, Jim <[e-mail]>
Subject: RE: [External] High Point WWTP SEPA Issue
High Point's revised SEPA— David have you had a chance to look at it?
Qais will be looking at it this coming week— please contact Qais if you need a copy.
After you both have a chance to look at it —and you both get any revisions you believe are needed to make it adequate
- let's have a meeting between NPDES, David and Taylor to discuss how best to move forward.
Thanks,
Julie
From: Crabtree, Taylor [mailto:[e-mail]
Sent: Tuesday, August 20, 2019 9:09 AM
To: Wainwright, David <david.wainwri¢[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>
Subject: [External] High Point WWTP SEPA Issue
ATTORNEY CLIENT COMMUNICATION — TRIAL PREPARATION — NOT A PUBLIC RECORD
Hi David,
I'd like to set up a meeting with you regarding a SEPA issue at an NPDES facility. Can you please give me your availability
next Monday (8/26), Tuesday (8/27) and Thursday (8/29)? 1 will provide additional information in advance of the
meeting.
Thanks,
Taylor

Banihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Tuesday, October 08, 2019 2:19 PM
To: Banihani, Qais
Cc: Terry Houk ([e-mail]); Yonce, Hillary, Glenn Dunn
([e-mail]); Grzyb, Julie, Crabtree, Taylor, Gregson, Jim
Subject: [External] RE: City of High Point West Side (NC0024228)
Attachments: Supplemental EA Letter from City to DEQ.pdf, Tt Memo -High Pt _Rich Fork Channel
Changes_08-27-2019.pdf
Hello Qais,
It appears that there may be some confusion that I'm hoping we can help clear up. Terry submitted a letter to Linda back
on August 29 with the supplement to the EA as we all discussed after finalizing the model and WLA. I'm wondering if
that has not been distributed, thus I'm sending a scanned copy to you, Julie, and Taylor for review. Given that the scan is
in B&W, I've attached a color copy of our original memo on the channel changes to supplement the EA for your use.
Please let us know if you have already received this and if you have questions or wish to discuss further.
Thank you,
Trevor
Trevor Clements I Principal/Program Manager
Direct: 919.485.2058 1 Main: 919.485.8278 1 Fax: [phone]
trevor.clements(),tetratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the Intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Monday, October 7, 2019 7:59 AM
To: Terry Houk ([e-mail]) <[e-mail]>
Cc: Clements, Trevor <[e-mail]>; Yonce, Hillary <[e-mail]>
Subject: City of High Point West Side (NC0024228)
Good morning Terry,
This email is to follow up regarding submission status for supplemental EA documentation for the subject facility.
Thanks,
Qais Banihani
Environmental Engineer

NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihaniCa ncdenr.¢ov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
11E
Environmental
Quality

Public Services Department
Terry Houk
DIRECTOR
NORTH CAROLINA'S INTERNATIONAL CITY'"
August 29, 2019
Linda Culpepper, Director
Division of Water Resources
N.C. Department of Environmental Quality
1611 Mail Service Center
Raleigh, NC 27699-1611
RE: City of High Point — Update of Environmental Assessment for the City of High Point
Westside Water Reclamation Facility Expansion (NPDES Permit No, NC0024228)
Dear Ms. Culpepper:
With this letter the City of High Point is submitting the report prepared by Tetra Tech (the
"Report") documenting the physical changes to the Rich Fork Creek stream channel that have changed
the stream hydraulics and improved the Creek's assimilative capacity since the NPDES Permit No.
NC0024228 (the "NPDES Permit") for the Westside Water Reclamation facility was issued. The Report
is based on Tetra Tech's study of stream conditions according to discussions with the Division of Water
Resources ("DWR") to determine whether the special condition in the NPDES Permit requiring a
restoration project on Rich Fork Creek (the "Restoration Condition") is still necessary given the changed
conditions. The Restoration Condition was based on environmental studies regarding the Creek's
assimilative capacity given its condition in 2006-7 and an Environmental Assessment ("EA") which
resulted in a Finding of No Significant Impact conditioned upon performance of the required restoration
project.
As stated in the enclosed Report, Tetra Tech's study confirms that the conditions that existed in
2006-7 on which the Restoration Condition was based have changed substantially and describes in detail
those conditions and how they have changed. Consequently, the Report concludes that the restoration
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax:[phone] Phone:[phone] TDD:336.883.8517

Public Services Department
Terry Houk
DIRECTOR
NORTH CAROLINNS INTERNATIONAL CITY'"
project is no longer necessary to ensure that the discharge permitted by the NPDES Permit has no
significant impact.
DWR requested that High Point submit with the study of changed stream conditions hi Rich Fork
Creek, a proposal to monitor conditions of the Creek in the future to ensure that adequate assimilative
capacity is maintained to continue meeting applicable water quality standards. High Point's proposal to
perform such monitoring is included in the Conclusion and Recommendations of the Report.
High Point appreciates the opportunity to have the study done and believes that it has
unequivocally shown that the condition of the NPDES Permit requiring the restoration project is no
longer necessary to ensure the permitted discharge has no significant impact. Consequently, High Point
requests that DWR issue a supplement to the FONSI and remove the Restoration Condition from High
Point's NPDES Permit.
Sincerely,
Terry L. Hdiik
cc: Randy McCaslin
Derrick Boone
Glemi Dunn
Meghan Maguire
Enclosures
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

OTETRA TECH
MEMORANDUM
To: Terry Houk, Director of Public Services
City of High Point
From: Trevor Clements, Principal
Hillary Yonce, P.H.
Date: August 27, 2019
Subject: Documentation of Physical Changes to the Rich
Fork Creek Stream Channel
Tetra Tech Engineering, P.C.
One Park Drive, Suite 200 • PO Box 14409
Research Tdangie Park, NC 27709
Tel [phone] - Fax [phone]D
The content of this memorandum was compiled by Tetra Tech on behalf of the City of High Point to
document changes to the Rich Fork Creek receiving stream for the Westside Water Reclamation Facility
(WRF) (National Pollutant Discharge Elimination System [NPDES] Permit No. NC0024228) since the
Environmental Assessment for the facility's expansion was completed.
Previous permit conditions for the expansion of the Westside WRF required stream restoration based on
environmental studies at the time to support assimilative capacity of the receiving waterbody In meeting
the water quality standard (WQS) for dissolved oxygen (DO). Westside WRF is located outside of High
Point, NC, in Davidson County and discharges near the headwaters of Rich Fork Creek, which flows
southbound for about 12 miles before reaching a confluence with Abbotts Creek. When the previous
permit conditions were identified as a requirement for the WRF expansion to allow Rich Fork Creek to
meet the instream WQS for DO (5.0 milligrams per liter (mgA% conditions along Rich Fork Creek were
significantly different than they are today, which this memo documents and clarifies in detail.
More recent monitoring and modeling efforts conducted by Tetra Tech have shown that the significant
changes along Rich Fork Creek have Improved hydraulics and represent a much different stream
condition than existed over a decade ago and upon which the original expansion permit conditions were
based. Specifically, the channel profiles in portions of Rich Fork Creek observed in 2006-7 as impacted
by sand mining have improved naturally, and areas of the stream previously noted by Tetra Tech as
having excessive treefell, including large tree debris dams, are now exhibiting more natural levels. Based
on the weight of evidence provided herein, it Is our recommendation that the previous permit condition
requiring stream restoration be removed from the City`s Westside NPDES permit. It is our professional
opinion that the restoration requirement is no longer warranted as conditions instream have improved,
and the newly calibrated and corroborated QUAL2K stream model verifies that the expanded Westside
WRF discharge can be assimilated under existing channel conditions with a substantial margin of safety.
A summary of these documented changes Is provided herein.

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
FLOW DATA
Stream flow can have a powerful influence on stream channel hydraulics. Although there is not a long-
term flow monitoring gage located along Rich Fork Creek, a U.S. Geological Survey (USGS) gage located
on the adjacent Abbotts Creek (USGS 021201500 Abbotts Creek at Lexington, NC) has been used to
approximate flow conditions along Rich Fork Creek throughout the monitoring and modeling work
conducted since 2006. Data from that USGS gage Indicate that some very high flows have occurred in
the past decade that could be a primary factor in the changes in stream channel hydraulics observed over
the past ten years and described in greater detail below.
Flow records along Abbotts Creek since 2007 to the present time (i.e., that follow the initial intensive
stream surveys of Rich Fork Creek performed by Tetra Tech) reveal an average daily flow of
approximately 168 cubic feet per second (cfs) and a median daily flow of 73 cfs. The maximum flow
recorded and validated at the Abbotts Creek gage was 8,000 cfs measured In 2003. Since fall 2007, three
flows approaching the maximum (above 7,500 c(s) have been recorded. Additionally, eight flows have
been measured above 6,000 cfs. The 95th percentile of flow reported by USGS is 600 cfs, so Abbotts
Creek has experienced eight events since our 2007 studies that are more than 10 times the 95th
percentile flow.
The Abbotts Creek flow gage has been used effectively to estimate flows in Rich Fork Creek via a
demonstrated strong relationship between gaged flows In Abbotts Creek and point measurements of flow
along Rich Fork Creek. Using drainage area analyses at three points along Rich Fork Creek at locations
of historical sand mining operations, we can roughly estimate flow using Abbotts Creek flow data in two
ways:
1. Using a drainage area ratio relative to the Abbotts Creek USGS gaging station, and
2. Using an empirical relationship between observed flows along Abbotts Creek and along Rich Fork
Creek during field monitoring investigations (empirical linear regression equation has an R-square
of 0.85).
Those two methods result in the following Rich Fork Creek flow approximations at Highway 109, Ball
Road, and Kanoy Road crossings during those eight highest flow events along Abbotts Creek:
1. Drainage area ratio method: flow range of 860-1,390 cfs
2. Empirical regression method: flow range of 1,750 2,830 cfs
The range of flows likely to have occurred along Rich Fork Creek during the eight largest events in
Abbotts Creek is approximately 35-90 times greater than the average annual flow In Rich Fork Creek
depending on location. High -flow events so far above average can create shear velocities that move
sediment and debris, change channel shape, and are capable of reforming stream banks as was
observed during the 2017 monitoring studies.
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TETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
CROSS -SECTIONAL AND HYDRAULIC MEASUREMENTS
Due in part both to the cessation of sand mining activities In the vicinity of Ball Road and Kanoy Road and
to the large flow events that have helped reshape Rich Fork Creek, significant changes have occurred in
channel geometry over the past decade. This section discusses the areas identified a decade ago as
having active sand mining and pools, with specific details about how those areas have changed over
time. Changes can be observed In channel geometry, aerial Imagery, and time -of -travel (TOT) studies. In
2009, subcontractor team Davis, Martin, and Powell & Associates (DMP) measured extensive pool cross
sections that were compared to more recent measurements from 2017--2019.
Ball Road
Downstream of Ball Road active sand mining occurring in the 2007-2009 period was ceased at some
point between observations during the 2017-2019 field studies. DMP conducted extensive surveys In late
January 2009 across the Ball Road pool area (Figure 1). The widest portion of the pool was measured at
cross-section K to be 56.6 feet (ft), and the deepest portion of the pool was measured at cross-section J
to be 5.5 ft, with an average depth through the pool of approximately 3 ft. Based on flow at the Abbotts
Creek USGS gage, flow at Ball Road at the time of those surveys was approximately 13 cfs.
In the area of cross -sections L, J, and K Identified as the pool extent in 2009, new cross -sections were
measured on August 6, 2019, immediately downstream of Ball Road. Flow conditions were approximately
11 cfs at Bail Road based on the Abbotts Creek gage, similar to conditions observed during the 2009
surveying. Average water depth observed in 2019 was around 0.8 ft (more than a 70 percent reduction),
and the maximum water depth observed was 1.6 ft (also more than a 70 percent reduction). Bank4o-bank
channel width observed in 2019 was approximately 38 ft, with an average wetted width of 25 ft.
Sand and slit deposits have filled In the old Ball Road pool since the cessation of sand mining activities,
and the creek has returned to a more natural geometry with a clear thalweg and highly vegetated banks
(Figure 2 and Figure 3). in Figure 4, note the differences in both width and depth at the cross -sections
taken at approximately the same location under similar flow conditions. The cross -sectional shape
difference Is representative of the magnitude of change observed throughout this segment of the
receiving stream.
Additionally, between April 2013 and April 2014► the Ball Road bridge crossing of Rich Fork Creek was
updated and replaced by the North Carolina Department of Transportation from a bridge with wooden
posts and rails to a fully concrete bridge. That change might also have had an impact on stream and
sediment hydraulics.
On August 28, 2007, a Rhodamine WT dye release was used to conduct a TOT study upstream of the
Ball Road pool. Based on the relationship of flow between Abbotts Creek and Rich Fork Creek, flow at
Ball Road on that date was estimated at approximately 9.6 cfs and the velocity was observed In the dye
study to be about 0.3 feet per second (ft/s). A TOT study conducted on June 2, 2017, In the same vicinity
of Ball Road found a velocity of 0.6 ft/s best represents the existing velocity through that segment, which
Is much greater than was observed and estimated In the vicinity in 2007. Flow conditions on that day
were approximately 14.4 cfs at Ball Road.
N
TETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 1. Aerial imagery of cross sections measured in the vicinity of Ball Road observed in 2009.
Figure 2. Water -level photo of the Ball Road pool, looking upstream at the old bridge (January 2009).
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 3. Water -level photo of the former Ball Road pool, looking downstream (August 6, 2019).
0.0
0
0.5
4r 1
3
3.5
Waters Edge to Waters Edge (ft)
10.0 20.0 30.0 40.0 50.0
—reb-03 —Aug-19
60.0
i
Figure 4. Representative 2009 vs 2019 water depth cross section across the former Ball Road pool.
Kanoy Road
The pool created by send mining at Kandy Road was observed in 2007 to begin above the bridge and
extend well downstream of the bridge, measuring about 80 it at its widest point downstream of the bridge
(Figure 5). Between 2007 and 2017, the sand mining permitted at Kanoy Road ceased (exact timing
unknown). Field measurements from 2017 showed the previously widest location to be about 18-22 ft
OTETRA TECH 5

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
(more than a 70 percent reduction), and aerial Imagery from February 3, 2018, suggests the widest part
of the pool might now be located upstream of Kanoy Road, measuring around 68 It across upstream of
the bridge with sand bars visible (Figure 5). Conditions depicted in Figure 5 are representative of field
measurements taken by DMP January 22-25, 2009, and Tetra Tech August 6, 2019 , when flow
conditions at Kanoy Road were approximately 13.6 cis and 11.5 cfs, respectively.
Figure 5. Aerial Imagery of sand mining pool downstream of Kanoy Road observed in 2007 (left). Aerial
imagery of sand mining pool downstream of Kanoy Road observed on 2/3/2018 (right).
DMP conducted extensive surveys January 22-25, 2009, across the Kanoy Road pool area (Figure 6).
The widest portion of the pool was measured to be 84.2 ft at cross-section K, and the deepest portion of
the pool was measured to be 6.1 ft at cross-section N. On August 6, 2019, in the area of cross -sections G
through 0 identified as the pool extent in 2009, Tetra Tech measured new cross -sections where flow
conditions at Kanoy Road were approximately 12.3 cfs.
The entire extent of the old Kanoy Road pool has in -filled with extensive sand and silt, resulting in a far
shallower channel (see Figure 7 compared with Figure 8). Average channel width between cross -sections
G and O in 2009 was approximately 57.6 ft, and the average depth was approximately 2 ft. The average
channel width observed around Kanoy Road In 2019 was 37 ft (more than a 35 percent reduction) and, at
its widest, it was 53 ft (more than a 37 percent reduction), A representative channel depth was observed
to be 1 ft (an approximately 50 percent reduction), and the maximum observed depth was approximately
2 ft (an approximately 67 percent reduction). A representative comparison of channel shapes between the
earlier and current conditions is shown in Figure 9, Illustrating the substantial changes that have occurred
over the past decade.
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 6. Aerial Imagery of cross sections measured in the vicinity of Kanoy Road in 2009.
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 7. Kanoy Road pool on downstream end of bridge (January 2009).
Figure 8. Old Kanoy Road pool looking downstream from under bridge (August 6, 2019).
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
0
i
' O.S
1
s .
Ls
..
t a 2
0 2.5
` 3
i M
i 2 3.5
4
t
4.5
5
Waters Edge to Waters Edge (ft)
0 10 20 30 40 50 60
i
Feb-09 —Aug-19
t
Figure 9. Representative 2009 vs 2019 water depth cross-section across the former Kanoy Road pool.
Highway 109
All field work conducted between 2007-9 and 2017--19 in the vicinity of Highway 109 found stream
geometry being shaped by active sand mining (see representative photos in Figure 10 and Figure 11).
DMP conducted extensive surveys in 2009 beginning upstream of the sand mining areas and extending
downstream of Highway 109 (Figure 12). Tetra Tech measured several cross -sections In 2017 within the
same zone and made additional field observations in 2019. The deepest area observed in 2009 was
measured at 5.1 ft at cross-section T in a pool located downstream of Highway 109, while upstream of
Highway 109 the water was considerably shallower. During field work conducted from 2017 to 2019,
Tetra Tech field staff found that no pool existed downstream of Highway 109, but that a large pool
extended from the sand mining location upstream of Highway 109 to the highway crossing. The channel
proportions of the Highway 109 pool as measured In 2017 were Incorporated into the updated QUAL2K
model completed by Tetra Tech and delivered to DWR to account for the continued Influence of sand
mining at this location.
N
TETRA TECH 9

�
-'I♦(t t
y � �

Memo Documenting Changes to Rich Fork Creek Stream Channel
August 27, 2019
Surveyed CwwSectl= at NC Hwy 108 Pool °o
is
TETRATECH
OWN IN IN
Figure 12. Aerial imagery of cross sections measured in the vicinity of Highway 109 in 2009.
OTETRA TECH 11

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
TREEFALL DEBRIS DAMS
Areas with excessive tree -fall debris can Influence stream velocity significantly at low flows and during
storm flows causing localized scour pools, which further decrease stream velocity during summer low -flow
conditions and subsequently lower DO concentrations Instream. Tetra Tech field personnel look
photographs and recorded locations of treefall debris and logjams during a field visit to Rich Fork Creek in
2007, 2009, and 2010. The differences field crews observed between instream treefall in 2007-2010 and
in a 2017 monitoring study suggest that far fewer logjams existed than a decade ago. The large number
of significant regional flow events are likely responsible for breaking up the excessive number of logjams
observed a decade ago. A photograph of the treefall debris dam significantly impeding flow downstream
of Ball Road in 2009 Is shown in Figure 13. That debris dam was no longer present at the site when it was
visited in 2017.
Figure 13. Facing downstream at a major debris dam below Ball Road pool January 24, 2009
Treefall data were compiled in 2009 based on aerial photography captured by Spatial Data Consultants
over the entirety of Rich Fork Creek. Tetra Tech generated a corresponding shapefile that resulted in an
estimate of between 300 and 500 individual treefall sites between Highway 109 and Kanoy Road. At that
time, the frequency of cross -stream treefall occurrence in that zone was approximately double the
frequency observed downstream of that point.
Not all treefall areas result in compromising stream hydraulics, so primarily large-scale debris dams are of
Interest for potential removal to improve stream conditions. An example of a debris dam downstream of
Highway 109 observed by the 2009 flyover imagery Is shown In Figure 14. That debris dam also can be
seen to have changed over time using Google Early aerial Imagery from 2012 and 2013 (Figure 15). The
logjam can be observed in February 2012 but Is no longer present in April 2013. In the intervening period,
there were 3 days with flow in Abbotts Creek greater than 1,000 cfs, which likely translated to flows In
Rich Fork Creek that helped break up the debris dam.
O TETRATECH
12

Memo Documenting Changes to Rich Fork Creek Sbearn Channel August 27, 2019
Figure 14. Treefall logjam from chartered flight aerial imagery downstream of Highway 109 (2009).
Figure 15. Treefall logjam visible In Gaogle Earth aerial Imagery In February 2012 (left) no visible treefall
logjam in the same location in April 2013 (fight).
QTETRA TECH 13

Memo Documenting Changes to Rich Fork Creek Stream Channel
August 27, 2019
WATER QUALITY DATA
Yadkin Pee Dee River Basin Association (Y ) o M ' ...e l
PDRBA operates three long-term water quality sampling sites
located along Rich Fork Creek (Table 1).
Table 1. Water quality sampling sites along Rich Fork Creek (YPDRSA)
05745000 Rich Fork Creek at SR 1757 (Chestnut Street) near
High Point
Q5785000 Rich Fork Creek at SR 17902 (Kanoy Road) near
High Point
05790000 Rich Fork Creek at SR 2123 (Old Highway 29) near
Hlgh Point and Ledngton
Q5750000 Rich Fork Creek at SR 1755
2010-2019
6.2
5.8
(one sample)
1998-2019
2.9
5.1
1998-2019
3.2
5.5
1998-2009
3.3
No Data
Water quality data results show that over the past 9 years (since 2011), minimum DO concentrations
have not been observed below the WQS (5.0 mgA) along Rich Fork Creek. Average DO concentrations
have remained relatively constant from 2000 to 2019 at all gages along Rich Fork Creek; however, the
Improvement in minimum DO concentrations Is clear in recent years.
O TETRA TECH
14

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
CONCLUSIONS AND RECOMMENDATIONS
In summary, Rich Fork Creek's physical properties have changed over the past decade, likely attributable
to large flow events shaping stream hydraulics along with the cessation of sand mining activities at Ball
and Kanoy roads. The recent wasteload allocation QUAL2K modeling efforts and model calibration report
associated with the Westside WRF plant expansion demonstrate that Rich Fork Creek has Improved
assimilative capacity over conditions existing in 2007. Previous recommendations to perform stream
restoration at multiple locations are no longer needed to increase assimilative capacity to maintain DO
levels above the WQS. We recommend that the City request of the North Carolina Division of Water
Resources that those previous requirements for discharge expansion be removed from future NPDES
permit documents.
The City had acknowledged to Tetra Tech that it recognizes the Importance of Rich Fork Creek remaining
hydraulically stable and able to naturally assimilate the expanded effluent discharge from Westside WRF.
Therefore, we recommend that the City commit to taking reasonable steps to monitor water quality
conditions and identifying potential threats to stream assimilative capacity associated with stream
hydraulics. Given that sand mining activities are no longer permitted near Ball and Kanoy roads, a greater
threat to Rich Fork Creek hydraulics may now be associated with any future significant treefall debris
dams that have the potential to slow water velocity significantly and decrease natural channel reaeration
rates. Therefore, we recommend the following strategy:
As part of preparing Its NPDES Permit Renewal application, the City will review YPDRBA water
quality data for any trends in reduction in DO concentration that could be indicative of changes to
channel hydraulics that could threaten assimilative capacity. If water quality data suggest
potentially reduced assimilative capacity, the City will commit to performing reconnaissance
measures to Identify potential channel obstructions that could be contributing to degraded stream
water quality conditions. Examples of reconnaissance activities might include reviewing readily
available streaming aerial imagery (from Google Earth, ArcMap, or Davidson County) and brief
field investigations at key locations subject to debris obstruction such as those areas near Ball
Road, Kanoy Road, Midway School Road, and Highway 109 crossings.
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TETRA TECH 15

NTETRA TECH
MEMORANDUM
To: Terry Houk, Director of Public Services
City of High Point
From: Trevor Clements, Principal
Hillary Yonce, P.H.
Date: August 27, 2019
Subject: Documentation of Physical Changes to the Rich
Fork Creek Stream Channel
Tetra Tech Engineering, P.C.
One Park Drive, Suite 200 • PO Box 14409
Research Triangle Park, NC 27709
Tel 91948"278 • Fax [phone]
The content of this memorandum was compiled by Tetra Tech on behalf of the City of High Point to
document changes to the Rich Fork Creek receiving stream for the Westside Water Reclamation Facility
(WRF) (National Pollutant Discharge Elimination System [NPDES] Permit No. NC0024228) since the
Environmental Assessment for the facility's expansion was completed.
Previous permit conditions for the expansion of the Westside WRF required stream restoration based on
environmental studies at the time to support assimilative capacity of the receiving waterbody in meeting
the water quality standard (WQS) for dissolved oxygen (DO). Westside WRF is located outside of High
Point, NC, in Davidson County and discharges near the headwaters of Rich Fork Creek, which flows
southbound for about 12 miles before reaching a confluence with Abbotts Creek. When the previous
permit conditions were identified as a requirement for the WRF expansion to allow Rich Fork Creek to
meet the instream WQS for DO (5.0 milligrams per liter [mg/I]), conditions along Rich Fork Creek were
significantly different than they are today, which this memo documents and clarifies in detail.
More recent monitoring and modeling efforts conducted by Tetra Tech have shown that the significant
changes along Rich Fork Creek have improved hydraulics and represent a much different stream
condition than existed over a decade ago and upon which the original expansion permit conditions were
based. Specifically, the channel profiles in portions of Rich Fork Creek observed in 2006-7 as impacted
by sand mining have improved naturally, and areas of the stream previously noted by Tetra Tech as
having excessive treefall, including large tree debris dams, are now exhibiting more natural levels. Based
on the weight of evidence provided herein, it is our recommendation that the previous permit condition
requiring stream restoration be removed from the City's Westside NPDES permit. It is our professional
opinion that the restoration requirement is no longer warranted as conditions instream have improved,
and the newly calibrated and corroborated QUAL2K stream model verifies that the expanded Westside
WRF discharge can be assimilated under existing channel conditions with a substantial margin of safety.
A summary of these documented changes is provided herein.

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
FLOW DATA
Stream flow can have a powerful influence on stream channel hydraulics. Although there is not a long-
term flow monitoring gage located along Rich Fork Creek, a U.S. Geological Survey (USGS) gage located
on the adjacent Abbotts Creek (USGS 021201500 Abbotts Creek at Lexington, NC) has been used to
approximate flow conditions along Rich Fork Creek throughout the monitoring and modeling work
conducted since 2006. Data from that USGS gage indicate that some very high flows have occurred in
the past decade that could be a primary factor in the changes in stream channel hydraulics observed over
the past ten years and described in greater detail below.
Flow records along Abbotts Creek since 2007 to the present time (i.e., that follow the initial intensive
stream surveys of Rich Fork Creek performed by Tetra Tech) reveal an average daily flow of
approximately 168 cubic feet per second (cfs) and a median daily flow of 73 ofs. The maximum flow
recorded and validated at the Abbotts Creek gage was 8,000 cfs measured in 2003. Since fall 2007, three
flows approaching the maximum (above 7,500 cfs) have been recorded. Additionally, eight flows have
been measured above 6,000 cfs. The 95th percentile of flow reported by USGS is 600 cfs, so Abbotts
Creek has experienced eight events since our 2007 studies that are more than 10 times the 95th
percentile flow.
The Abbotts Creek flow gage has been used effectively to estimate flows in Rich Fork Creek via a
demonstrated strong relationship between gaged flows in Abbotts Creek and point measurements of flow
along Rich Fork Creek. Using drainage area analyses at three points along Rich Fork Creek at locations
of historical sand mining operations, we can roughly estimate flow using Abbotts Creek flow data in two
ways:
1. Using a drainage area ratio relative to the Abbotts Creek USGS gaging station, and
2. Using an empirical relationship between observed flows along Abbotts Creek and along Rich Fork
Creek during field monitoring investigations (empirical linear regression equation has an R-square
of 0.85).
Those two methods result in the following Rich Fork Creek flow approximations at Highway 109, Ball
Road, and Kanoy Road crossings during those eight highest flow events along Abbotts Creek:
1. Drainage area ratio method: flow range of 860-1,390 cfs
2. Empirical regression method: flow range of 1,750-2,830 cfs
The range of flows likely to have occurred along Rich Fork Creek during the eight largest events in
Abbotts Creek is approximately 35-90 times greater than the average annual flow in Rich Fork Creek
depending on location. High -flow events so far above average can create shear velocities that move
sediment and debris, change channel shape, and are capable of reforming stream banks as was
observed during the 2017 monitoring studies.
aTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
CROSS -SECTIONAL AND HYDRAULIC MEASUREMENTS
Due in part both to the cessation of sand mining activities in the vicinity of Ball Road and Kanoy Road and
to the large flow events that have helped reshape Rich Fork Creek, significant changes have occurred in
channel geometry over the past decade. This section discusses the areas identified a decade ago as
having active sand mining and pools, with specific details about how those areas have changed over
time. Changes can be observed in channel geometry, aerial imagery, and time -of -travel (TOT) studies. In
2009, subcontractor team Davis, Martin, and Powell & Associates (DMP) measured extensive pool cross
sections that were compared to more recent measurements from 2017-2019.
Ball Road
Downstream of Ball Road active sand mining occurring in the 2007-2009 period was ceased at some
point between observations during the 2017-2019 field studies. DMP conducted extensive surveys in late
January 2009 across the Ball Road pool area (Figure 1). The widest portion of the pool was measured at
cross-section K to be 56.6 feet (ft), and the deepest portion of the pool was measured at cross-section J
to be 5.5 ft, with an average depth through the pool of approximately 3 ft. Based on flow at the Abbotts
Creek USGS gage, flow at Ball Road at the time of those surveys was approximately 13 cfs.
In the area of cross -sections L, J, and K identified as the pool extent in 2009, new cross -sections were
measured on August 6, 2019, immediately downstream of Ball Road. Flow conditions were approximately
11 cfs at Ball Road based on the Abbolts Creek gage, similar to conditions observed during the 2009
surveying. Average water depth observed in 2019 was around 0.8 ft (more than a 70 percent reduction),
and the maximum water depth observed was 1.5 ft (also more than a 70 percent reduction). Bank -to -bank
channel width observed in 2019 was approximately 38 ft, with an average wetted width of 25 ft.
Sand and silt deposits have filled in the old Ball Road pool since the cessation of sand mining activities,
and the creek has returned to a more natural geometry with a clear thalweg and highly vegetated banks
(Figure 2 and Figure 3). In Figure 4, note the differences in both width and depth at the cross -sections
taken at approximately the same location under similar flow conditions. The cross -sectional shape
difference is representative of the magnitude of change observed throughout this segment of the
receiving stream.
Additionally, between April 2013 and April 2014, the Ball Road bridge crossing of Rich Fork Creek was
updated and replaced by the North Carolina Department of Transportation from a bridge with wooden
posts and rails to a fully concrete bridge. That change might also have had an impact on stream and
sediment hydraulics.
On August 28, 2007, a Rhodamine WT dye release was used to conduct a TOT study upstream of the
Ball Road pool. Based on the relationship of flow between Abbotts Creek and Rich Fork Creek, flow at
Ball Road on that date was estimated at approximately 9.5 cfs and the velocity was observed in the dye
study to be about 0.3 feet per second (ft/s). A TOT study conducted on June 2, 2017, in the same vicinity
of Ball Road found a velocity of 0.6 ft/s best represents the existing velocity through that segment, which
is much greater than was observed and estimated in the vicinity in 2007. Flow conditions on that day
were approximately 14.4 cfs at Ball Road.
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 1. Aerial imagery of cross sections measured in the vicinity of Ball Road observed in 2009.
Figure 2. Water -level photo of the Ball Road pool, looking upstream at the old bridge (January 2009).
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
f,
r
' 4
r
Figure 3. Water -level photo of the former Ball Road pool, looking downstream (August 6, 2019).
0.0
0
0.5
s_ 1
L
G i.S
N
2
d
3 25
3
3.5
Waters Edge to Waters Edge (ft)
10.0 20.0 30.0 40.0 50.0 60.0
— Feb-09 —Aug-19
Figure 4. Representative 2009 vs 2019 water depth cross section across the former Ball Road pool.
Kanoy Road
The pool created by sand mining at Kanoy Road was observed in 2007 to begin above the bridge and
extend well downstream of the bridge, measuring about 80 ft at its widest point downstream of the bridge
(Figure 5). Between 2007 and 2017, the sand mining permitted at Kanoy Road ceased (exact timing
unknown). Field measurements from 2017 showed the previously widest location to be about 18-22 ft
DTETRA TECH 5

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
(more than a 70 percent reduction), and aerial imagery from February 3, 2018, suggests the widest part
of the pool might now be located upstream of Kanoy Road, measuring around 68 ft across upstream of
the bridge with sand bars visible (Figure 5). Conditions depicted in Figure 5 are representative of field
measurements taken by DMP January 22-25, 2009, and Tetra Tech August 6, 2019 , when flow
conditions at Kanoy Road were approximately 13.6 cfs and 11.5 cfs, respectively.
Figure 5. Aerial imagery of sand mining pool downstream of Kanoy Road observed in 2007 (left). Aerial
imagery of sand mining pool downstream of Kanoy Road observed on 2/3/2018 (right).
DMP conducted extensive surveys January 22-25, 2009, across the Kanoy Road pool area (Figure 6).
The widest portion of the pool was measured to be 84.2 ft at cross-section K, and the deepest portion of
the pool was measured to be 6.1 ft at cross-section N. On August 6, 2019, in the area of cross -sections G
through 0 identified as the pool extent in 2009, Tetra Tech measured new cross -sections where flow
conditions at Kanoy Road were approximately 12.3 cfs.
The entire extent of the old Kanoy Road pool has in -filled with extensive sand and silt, resulting in a far
shallower channel (see Figure 7 compared with Figure 8). Average channel width between cross -sections
G and 0 in 2009 was approximately 57.6 ft, and the average depth was approximately 2 ft. The average
channel width observed around Kanoy Road in 2019 was 37 ft (more than a 35 percent reduction) and, at
its widest, it was 53 ft (more than a 37 percent reduction). A representative channel depth was observed
to be 1 ft (an approximately 50 percent reduction), and the maximum observed depth was approximately
2 ft (an approximately 67 percent reduction). A representative comparison of channel shapes between the
earlier and current conditions is shown in Figure 9, illustrating the substantial changes that have occurred
over the past decade.
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel
SUNVYed Cm4sec eRy Rd Pool . a �I -- _—__
�u surawn ®TEf11 CH
w4 Wpv�4YYmL��l� �M
August 27, 2019
Figure 6. Aerial imagery of cross sections measured in the vicinity of Kanoy Road in 2009.
OTETRA TECH 7

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 7. Kanoy Road pool on downstream end of bridge (January 2009).
Figure 8. Old Kanoy Road pool looking downstream from under bridge (August 6, 2019).
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
[i"
4.5
Waters Edge to Waters Edge (ft)
0 10 20 30 40 50 60
— Feb-09 — Aug-19
Figure 9. Representative 2009 vs 2019 water depth cross-section across the former Kanoy Road pool.
Highway 109
All field work conducted between 2007-9 and 2017-19 in the vicinity of Highway 109 found stream
geometry being shaped by active sand mining (see representative photos in Figure 10 and Figure 11).
DMP conducted extensive surveys in 2009 beginning upstream of the sand mining areas and extending
downstream of Highway 109 (Figure 12). Tetra Tech measured several cross -sections in 2017 within the
same zone and made additional field observations in 2019. The deepest area observed in 2009 was
measured at 5.1 ft at cross-section T in a pool located downstream of Highway 109, while upstream of
Highway 109 the water was considerably shallower. During field work conducted from 2017 to 2019,
Tetra Tech field staff found that no pool existed downstream of Highway 109, but that a large pool
extended from the sand mining location upstream of Highway 109 to the highway crossing. The channel
proportions of the Highway 109 pool as measured in 2017 were incorporated into the updated QUAL2K
model completed by Tetra Tech and delivered to DW R to account for the continued influence of sand
mining at this location.
OTETRA TECH

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 10. Active sand -mined pool upstream of Highway 109 (January 22, 2009).
Figure 11. Active sand -mined pool upstream of Highway 109 (August 6, 2019).
OTETRA TECH 10

Memo Documenting Changes to Rich Fork Creek Stream Channel August27, 2019
Figure 12. Aerial imagery of cross sections measured in the vicinity of Highway 109 in 2009.
OTETRA TECH 11

Memo Documenting Changes to Rich Fork Creek Stream Channel August27, 2019
TREEFALL DEBRIS DAMS
Areas with excessive tree -fall debris can influence stream velocity significantly at low flows and during
storm flows causing localized scour pools, which further decrease stream velocity during summer low -flow
conditions and subsequently lower DO concentrations instream. Tetra Tech field personnel took
photographs and recorded locations of treefall debris and logjams during a field visit to Rich Fork Creek in
2007, 2009, and 2010. The differences field crews observed between instream treefall in 2007-2010 and
in a 2017 monitoring study suggest that far fewer logjams existed than a decade ago. The large number
of significant regional flow events are likely responsible for breaking up the excessive number of logjams
observed a decade ago. A photograph of the treefall debris dam significantly impeding flow downstream
of Ball Road In 2009 is shown in Figure 13. That debris dam was no longer present at the site when it was
visited in 2017.
Figure 13. Facing downstream at a major debris dam below Ball Road pool January 24, 2009.
Treefall data were compiled in 2009 based on aerial photography captured by Spatial Data Consultants
over the entirety of Rich Fork Creek. Tetra Tech generated a corresponding shapefile that resulted in an
estimate of between 300 and 500 individual treefall sites between Highway 109 and Kanoy Road. At that
time, the frequency of cross -stream treefall occurrence in that zone was approximately double the
frequency observed downstream of that point.
Not all treefall areas result in compromising stream hydraulics, so primarily large-scale debris dams are of
interest for potential removal to improve stream conditions. An example of a debris dam downstream of
Highway 109 observed by the 2009 flyover imagery is shown in Figure 14. That debris dam also can be
seen to have changed over time using Google Early aerial imagery from 2012 and 2013 (Figure 15). The
logjam can be observed in February 2012 but is no longer present in April 2013. In the intervening period,
there were 3 days with flow in Abbotts Creek greater than 1,000 cfs, which likely translated to flows in
Rich Fork Creek that helped break up the debris dam.
® TETRA TECH 12

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
Figure 14. Treefall logjam from chartered flight aerial imagery downstream of Highway 109 (2009).
Figure 15. Treefall logjam visible in Google Earth aerial imagery in February 2012 (left) no visible treefall
logjam in the same location in April 2013 (right).
aTETRA TECH 13

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
WATER QUALITY DATA
Yadkin Pee Dee River Basin Association (YPDRBA) operates three long -tens water quality sampling sites
located along Rich Fork Creek (Table 1).
Table 1. Water quality sampling sites along Rich Fork Creek (YPDRBA)
Q5745000 Rich Fork Creek at SR 1757 (Chestnut Street) near 2010-2019 6.2 S.8
High Point (one sample)
Q5785000 Rich Fork Creek at SR 17902 (Kanoy Road) near 1998-2019 2.9 5.1
High Point
Q5790000 Rich Fork Creek at SR 2123 (Old Highway 29) near 1g98-2019 3.2 5.5
High Point and Lexington
Q5750000 Rich Fork Creek at SR 1755 1998-2009 3.3 No Data
Water quality data results show that over the past 9 years (since 2011), minimum DO concentrations
have not been observed below the WQS (5.0 mgA) along Rich Fork Creek. Average DO concentrations
have remained relatively constant from 2000 to 2019 at all gages along Rich Fork Creek; however, the
improvement in minimum DO concentrations is clear in recent years.
OTETRA TECH 14

Memo Documenting Changes to Rich Fork Creek Stream Channel August 27, 2019
CONCLUSIONS AND RECOMMENDATIONS
In summary, Rich Fork Creek's physical properties have changed over the past decade, likely attributable
to large flow events shaping stream hydraulics along with the cessation of sand mining activities at Ball
and Kanoy roads. The recent wasteload allocation QUAL2K modeling efforts and model calibration report
associated with the Westside WRF plant expansion demonstrate that Rich Fork Creek has improved
assimilative capacity over conditions existing in 2007. Previous recommendations to perform stream
restoration at multiple locations are no longer needed to increase assimilative capacity to maintain DO
levels above the WQS. We recommend that the City request of the North Carolina Division of Water
Resources that those previous requirements for discharge expansion be removed from future NPDES
permit documents.
The City had acknowledged to Tetra Tech that it recognizes the importance of Rich Fork Creek remaining
hydraulically stable and able to naturally assimilate the expanded effluent discharge from Westside WRF.
Therefore, we recommend that the City commit to taking reasonable steps to monitor water quality
conditions and identifying potential threats to stream assimilative capacity associated with stream
hydraulics. Given that sand mining activities are no longer permitted near Ball and Kanoy roads, a greater
threat to Rich Fork Creek hydraulics may now be associated with any future significant treefall debris
dams that have the potential to slow water velocity significantly and decrease natural channel reaeration
rates. Therefore, we recommend the following strategy:
As part of preparing its NPDES Permit Renewal application, the City will review YPDRBA water
quality data for any trends in reduction in DO concentration that could be indicative of changes to
channel hydraulics that could threaten assimilative capacity. If water quality data suggest
potentially reduced assimilative capacity, the City will commit to performing reconnaissance
measures to identify potential channel obstructions that could be contributing to degraded stream
water quality conditions. Examples of reconnaissance activities might include reviewing readily
available streaming aerial imagery (from Google Earth, ArcMap, or Davidson County) and brief
field investigations at key locations subject to debris obstruction such as those areas near Ball
Road, Kanoy Road, Midway School Road, and Highway 109 crossings.
OTETRA TECH 15

Sanihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Friday, July 26, 2019 1:22 PM
To: Banihani, Qais; Grzyb, Julie; Behm, Pamela; Crabtree, Taylor
Cc: Yonce, Hillary, Terry Houk ([e-mail]); Glenn Dunn
(gdunn@ poynerspruill.com)
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
Attachments: Westside WLA Memo 7-26-2019.pdf
Qais and Pam,
Thank you for your call yesterday to go over the outstanding issues. It was helpful to get the clarification first hand. The
attached revised memo is provided for your review. We reorganized the front portion of the memo to incorporate the
discussion of sand mining as agreed to and made a few additional refinements to the text and document formatting. Per
our discussion we will move forward with preparing the letter to document the change in stream channel conditions
that has been observed since the previous studies that were referenced in the EA for the Westside facility expansion.
Please provide any additional direction for that letter as required.
Thank you,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clementsCdtetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the Intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Clements, Trevor
Sent: Friday, July 19, 2019 3:26 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <H ilia [e-mail]>; Terry Houk (terry.houk@high pointnc.gov)
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Qais,
This is in follow up to our conversation today. I recognize now that while you, Pam, Hillary and I discussed the resolution
of the sand mining model configuration over the phone prior to submitting the WLA modeling files, the brief memo does

not explicitly address the matter. However, you will note in the model configuration, that the short reach number 2 in all
scenarios represents the sand mining pool above HWY 109. The documentation is provided in the revised modeling
report dated 10-24-18, and this same mine configuration is assumed in the QUAL2K WLA scenarios. As noted below, we
believe that per the sand mining permit requirements, this is a conservative assumption. We look forward to our follow
up discussion with you and Pam upon her return to determine if any further concerns remain.
Thank you,
Trevor
From: Clements, Trevor
Sent: Friday, July 19, 2019 1:57 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Hi Qais,
Would you please clarify your request? We checked the general permit requirements and the only thing specific to
stream channel is that the sand mining activities cannot cause unstable stream banks. The HWY 109 sand mining
operation is likely out of compliance in this regard as they have caused what appears to be a very significant level of
streambank instability essentially disconnecting the floodplain from the stream channel. We have incorporated the HWY
109 sand mining area into the model even though technically it appears out of compliance, thus it would appear that our
model is more conservative than required. The previous sand mining operations are no longer permitted and the model
assumptions reflect the actual surveyed conditions of those areas. Given these circumstances, we are not clear on DEQ
expectations. Would you please state specifically what the model assumptions should be for WLA consideration of sand
mining operations and provide the appropriate citation for reference?
Much appreciated,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.82781 Cell: 919.328.0175
treyor.clementsrd)fetratech corn
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <gais.banihani@ncdenr.¢ov>
Sent: Friday, July 19, 2019 1:43 PM
To: Clements, Trevor<[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<pamela.behm@ncdenr.¢ov>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit

Trevor,
In outlast joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL21K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 10 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihani(lncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
Environmental
Quality
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 2019 11:03 AM
To: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>; Behm, Pamela
<pamela.behm@ncdenr.¢ov>; Crabtree, Taylor <tcrabtree@ncdoi.¢ov>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail]_)
<[e-mail]>; Glenn Dunn ([e-mail]) <gdunn povnerspruill.com>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the W LA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.

a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
The revised WIA and effluent limits should be summarized including the new margin of safety incorporated.
A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.20581 Main: 919,485.8278 1 Fax: [phone]
trevocdements()tetratech oom
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <oais.banihaniCcDncdenr.eov>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor <Trevor.ClementsCeDtetratech.com>; Behm, Pamela <pamela.behm(ancdenr.gov>
Cc: Grzyb, Julie <iulie.grzvb(ancdenr.eov>; Yonce, Hillary <Hillary.Yonce(@tetratech.com>; Terry Houk
(terry.houk0highpointnc.eov) <terrv.houk0hiehpointnc.aov>
Subject: RE: [External] QUAL21K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL2K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
aais.banihani (dncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617

11E
Environmental
Quality
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <[e-mail]>; Terry Houk
([e-mail]) <[e-mail]>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clem ents(c)tetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

N
TETRA TECH
One Park Drive, Suite 200
PO Box W09
Research Triangle Park, NC 27709
Tel [phone] • Fax [phone]
MEMORANDUM
To: Julie Gryzb, NCDWR
Date: July 26, 2019
Pam Behm, NCDWR
Subject: City of High Point Westside Water
CC: Terry Houk, City of High Point
Reclamation Facility Wasteload
From: Hillary Yonce, Tetra Tech
Allocation Scenario Results and
Proposed Permit Limits
Trevor Clements, Tetra Tech
This memo summarizes modeling methods and recommendations for a wasteload allocation (WLA) and
proposed effluent limits for the Westside Water Reclamation Facility (WRF)' for consideration by the
North Carolina Division of Water Resources (NCDWR). The Westside WRF has undergone treatment
upgrades to improve effluent water chemistry and is seeking to expand its existing permit from 6 MGD to
8.2 MGD in the near -term (intermediate), and 10 MGD in the long-term (full capacity). This memo
documents the modeling methodology and assumptions used to assess the assimilative capacity of Rich
Fork Creek to meet existing water quality standards within a margin of safety.
The calibrated and corroborated QUAL2K model developed for Rich Fork Creek (Tetra Tech, 2018)1 was
used as the basis for analyzing assimilative capacity to establish an appropriate W LA. For additional
details on the model, please review the modeling report. The calibrated and corroborated Rich Fork
Creek QUAL2K model was accepted by NCDWR, and the contents covered in this memo include the
WLA recommendations and proposed effluent limits for the Westside WRF.
For this model application, key anthropomorphic impacts to the stream were considered. Specifically, that
includes the existing permitted facilities and activities that impact Rich Fork Creek:
• Westside WRF near the upstream end of Rich Fork Creek
• Thomasville Wastewater Treatment Plant (WWTP) located on Hamby Creek
• Active permitted in -stream sand mining along Rich Fork Creek
Note that the preferred facility name is the Westside Water Reclamation Facility reflecting the advanced
treatment and the ability to reuse the water for indirect uses and low flow augmentation.
Y Report "Model Evaluation for Rich Fork Creek: New Data and Analyses" prepared by Tetra Tech for the
City of High Point Public Services, October 26, 2018.
OTETRA TECH

High Point Westside WRF WLA Modeling Memo July26, 2019
When incorporating the active sand mining into the model environment, field conditions from 2017 were
used to best approximate reach conditions and revise the original QUAL2E model conditions based on
changes in'sand mining locally. Areas previously impacted by sand mining along Rich Fork Creek were
located near Ball Road, Kandy Road, and Highway 109. Sand mining activities at Ball and Kanoy Roads
have ceased since the original modeling work was completed in 2007, and the model reflects this
condition instream, such that the stream banks have stabilized and the channel profile is more typical of
the adjacent upstream and downstream conditions. The continuing active sand mining occurring
upstream of Highway 109 is simulated in the model as having a smaller impact zone than was observed
in 2007 and is represented based on conditions observed in 2017. The general permit for in -stream sand
mining applicable along Rich Fork Creek (General Permit No. NCG520000, effective October 1, 2015)
indicates that any permittee activities shall "ensure that impacts to the surface waters are minimized", and
"ensure that stream banks are stabilized".
1.1 CRITICAL CONDITIONS SIMULATION
The calibrated and corroborated Rich Fork Creek QUAL2K model was first adjusted to simulate critical
summer and winter conditions required for use in WLA analyses. For the critical conditions baseline
simulation, the following modifications were made to the calibrated QUAL21K model:
1. Removal of point sources (Westside WRF) to represent natural critical conditions
2. Seasonal 7-day minimum flow with a recurrence interval of 10 years (7Q10) at headwaters and
tributaries
3. Seasonal 90th percentile air and dew point temperatures
These modifications support the prediction of how Rich Fork Creek is expected to behave under
critically warm and low -flow conditions during both the summer and winter periods in the absence
of any effluent discharges. The seasonal model input modifications made for the critical condition
models are summarized in Table 1.
Table 1. Summary of critical condition QUAL2K baseline model Inputs.
Simulation Date
August 31, 2017
November 16, 2017
Air Temperature, °C
27.5
16.7
Dew Point Temperature,°C
23.6
12.8
Headwater Flow, cis (cros)
0.67 (0.019)
1.90 (0.054)
Kennedy Mill Flow, cis (cros)
0.25 (0.0071)
0.70 (0.020)
Hunts Fork Flow, cis (cros)
0.42 (0.012)
1.18 (0.33)
Hamby Creek Flow, cis (cros)
1.05 (0.030)
2.97 (0.084)
Water Temperature, °C
24.5
13.0
Dissolved Oxygen', mg/I
6.6
8.5
Ammonia', mg/I
0.08
0.04
Organic Nitrogen', mg/I
0.33
0.12
Nitrate and Nitrite', mg/1
0.22
0.44
Slow Carbonaceous Biochemical Oxygen Demand', mg/I 2.0 2.0
'Water chemistry assigned to both headwaters and tributaries.
OTETRA TECH

High Point Westside WRF WLA Modeling Memo July26, 2019
The results of these two scenarios are shown below in Figure 1; indicating that the dissolved oxygen (DO)
water quality standard (WQS) for Rich Fork Creek of 5.0 mg/I in the absence of the Westside WRF
discharge is not predicted to be maintained under the most critical conditions. The minimum daily average
DO concentration during the summer is estimated as 0.00 mg/I (anoxic conditions), and during winter is
estimated as 4.93 mg/I.
--Was
—Scenano
1: Summer7010(no effluent)
—Scenario2 Winter 7010(no effluent)
WertsK
Midway
Ball Kenoy Il_r Evans
Old 29 Hamby Creek
Kennedy
Kennedy
Road
Road Road -"-. Road
Il
Mill Crcek
I
I
111 1
10.0
9.0
8.0
— —
7.0
6.0
0
E
5.0
g
4.0
3.0
2.0
Pool
1.0
0.0
kb
O R, 1 O O
M 9 ry a O
Distance from outlet )mi)
Figure 1. QUAL2K results: average longitudinal DO for natural seasonal critical conditions.
The seasonal critical conditions QUAL2K models were used to simulate the addition of point sources to
ensure that the permitted maximum effluent limits can be assimilated during the most critical conditions
instream while allowing for a reasonable margin of safety (MOS) for aquatic health. For the wasteload
allocation (WLA) scenario development, the existing wastewater treatment facility located on Hamby
Creek (Thomasville Hamby Creek WWTP, National Pollution Discharge Elimination System [NPDES] ID
NC0024112) was included in the simulation to incorporate potential interaction between the discharges
for WLA purposes. The Thomasville WWTP is located on Hamby Creek approximately six miles upstream
of the confluence, so it is likely that a large amount of assimilation will occur along Hamby Creek before
the confluence with Rich Fork Creek. To be conservative in the simulation of potential interactions
however, the Thomasville Hamby Creek WWTP is assumed to discharge directly into Rich Fork Creek at
the point of the Hamby Creek confluence to represent maximum potential impact of permitted flows and
water chemistry on Rich Fork under critical conditions.
Seasonal QUAL2K model scenarios for WLA purposes were developed under the following conditions:
• Seasonal critical conditions (seasonal 7Q10 flows and temperatures)
• Thomasville WWTP on Hamby Creek set to permit limits for flow and water chemistry
• Westside WRF flow set to 10 MGD
OTETRA TECH

High Point Westside WRF WLA Modeling Memo
July 26, 2019
Under these conditions, the model was run iteratively to identify what combination of Westside WRF
effluent permit limits would allow for assimilative capacity to be met instream along Rich Fork Creek. To
identify what effluent permit limits are reasonably attainable for the facility, data analysis was conducted
on existing effluent flow and water chemistry data at both Thomasville WWTP and Westside WRF.
2.1 ANALYSIS OF EFFLUENT FLOW AND WATER CHEMISTRY DATA
The existing flow and water chemistry data for the effluent discharging from Westside WRF and
Thomasville Hamby Creek WWTP can be used to inform the model parameterization and
providing insight into system performance. The Thomasville Hamby Creek WWTP seasonal
effluent data for the period 2014 — 2019 are summarized in Table 2.
Table 2. Existing monthly average permit limits and average seasonal effluent for Thomasville
Hamby Creek WWTP.
Summer 4.0 1.83
BOD5 (mg/1)
Winter
6.0
2.04
Summer
1.0
0.24
NH3(mg/1)
Winter
3.0
0.48
Summer
2.72
TN (mg/1)
None
Winter
6.89
Summer
7.77
DO (mg/1)
6.0
Winter
8.80
Summer
24.54
Temperature (°C)
None
Winter
17.47
In October of 2013 the City of High Point received authorization from NCDEQ to construct a Water
Reclamation Facility (WRF) at the Westside facility with a capacity of 10 MGD incorporating the following
modifications to the existing 6.2 MGD facility (NCDWR, 20133):
New Biological Nutrient Removal (BNR) system consisting of four parallel trains with total
volumes of 0.50 MG anaerobic zone, 0.91 MG 15' stage anoxic zone, 4.95 MG aerobic zone, 1.48
MG 2nd stage anoxic zone, 0.29 MG re -aeration zone, including fine bubble diffusers and 40
vertical mixers; new blower/NRCY Building including two (2) 6,074 ICFM blowers, two (2) 4,050
ICFM blowers, and four (4) 6,944 gpm NRCY pumps; a new final clarifier distribution box; new
130-foot diameter, 15-foot side -water depth final clarifier; two (2) 3,550 gpm RAS pumps; a new
3 Letter to Terry Houk, City of High Point, from Thomas A. Reed, Director of NCDWR providing
authorization to construct an expanded facility, October 9, 2013.
OTETRA TECH

High Point Westside WRF WLA Modeling Memo
July 26, 2019
process drain pump station, including one (1)1,100 gpm pump; a new clarifier drain pump station
including one (1) 800 gpm pump; two (2) 150 gpm non -potable water pumps; associated
electrical and control/SCADA work, sitework, and yard piping, in conformity with the project plans,
specifications, and other supporting data subsequently filed and approved by the Department of
Environment and Natural Resources.
The upgrades to the Westside WRF came online in March 2018 which had an immediate impact
on improved effluent water quality, particularly related to seasonal total nitrogen and ammonia
concentrations which decreased on average by about approximately 70 percent and 90 percent,
respectively (Table 3). Typical system performance reveals that average effluent conditions meet
existing permit limits within a relatively large margin of safety.
Table 3. Existing monthly average permit limits and average seasonal effluent for Westside WRF.
Flow(MGD) Winter 6.2 3.19 3.59
Summer
5.0
1.55
0.35
BOD5(mg/1)
Winter
10.0
2.38
0.46
Summer
2.0
0.26
0.03
NH3(mg/1)
Winter
4.0
0.29
0.01
Summer
17.71
5.45
TN (mg/1)
Winter
None
18.20
4.42
Summer
6.27
7.37
DO (mg/1)
Winter
6.0
7.32
8.10
Summer
24.41
25.26
Temperature (°C)
Winter
None
18.51
18.10
'Note that starting on March 2018, a new system of nitrification was brought online at the Westside WRF which improved water
chemistry in effluent relative to TN and NH3.
2.2 MODEL PARAMETERIZATION OF EFFLUENT DISCHARGE
The only change from the seasonal critical condition model applications to the WLA scenarios are the
additional inputs from Thomasville WWTP and the Westside WRF. QUAL2K model inputs for Thomasville
WWTP were based on permitted limits (Table 4).
By assuming that the Thomasville WWTP discharges directly into Hamby Creek (rather than six miles
upstream after which some instream assimilation would occur), these inputs reflect a conservative model
application. Note that while simulation results are presented for Thomasville WWTP operating at
maximum permitted flows, additional scenarios were run with the facility operating at average flow (2.43
MGD) with results indicating a similar DO profile and slightly lower instream ammonia levels under the
existing wasteflow average. In all cases, Instream water quality criteria of 5.25 mg/I (reflecting a margin of
safety) and seasonal levels of ammonia of 1 mg/I in the summer and 1.8 mg/I in the winter were met.
QTETRA TECH

High Point Westside WRF WLA Modeling Memo July 26, 2019
Estimated concentrations for organic nitrogen or nitrate + nitrite provided by Hazen & Sawyer are 1.0 mg/l
and 3.0 mg/l respectively for the Westside WRF were also applied to conditions at the Thomasville
WWTP given similar treatment levels. Average observed total nitrogen concentrations at Thomasville
WWTP from 2014 -2019 are 2.72 mg/l and 6.89 mg/l in the summer and winter respectively, so model
inputs which result in a total nitrogen concentration of at least 5.0 mg/l and 7.0 mg/I seasonally is a
reasonable approximation (Table 4). Effluent water temperature and pH model inputs were estimated
based on average observed seasonal data.
Table 4. Thomasville WWTP model inputs for all WLA scenarios.
Flow (MGD) 6.0
DO (mgA)
Fast CBOD (mgA)'
Organic N (mg/1)
Ammonia (mgA)
Nitrate + Nitrite (mg/1)
pH
8.0 (based on BODs = 4.0 mg/1)
1.0
6.0
12.0 (based on BODs = 6.0 mg/1)
1.0
3.0
7.0
3.0
Temperature (°C) 25 18
' Recall from the previous modeling report that assumed relationship between BODs:fastCBOD is 1:2
QUAL21K model inputs for the Westside WRF are presented in
Table 5 alongside model inputs used for the calibration and corroboration scenarios presented in the
previous report. Seasonal model inputs for Ammonia, fast CBOD, and DO concentrations were developed
based on iterative W LA analyses to ensure the following conditions were met, and are presented in
Section 3.0 WIA Scenario Results:
• Instream DO concentrations must not fall below the water quality standard (5.0 mg/1) with an
additional 5% margin of safety (5.25 mg/1) either upstream or downstream of the Thomasville
WWTP input location.
• Instream water quality must not cause ammonia toxicity which refers to the protection of aquatic
life against high instream ammonia concentrations. Instream ammonia concentrations must not
exceed 1.0 mg/l in the summer and 1.8 mg/l in the winter based on NCDEQ Standard Operating
Procedures for Ammonia Toxicity Evaluation.
Model inputs for the Westside WRF (Table 5) related to organic nitrogen, nitrate + nitrite, pH, and water
temperature were based on the same reference materials as presented in Table 4.
Table 5. Westside WRF model inputs for calibration, corroboration, and WIA scenarios.
Flow (MGD) 2.5 2.9 2.1 8.2 and 10.0
OTETRA TECH

High Point Westside WRF WLA Modeling Memo July26, 2019
DO (mg/I) 7.5 6.9 7.2 Determined by WLA analysis
Fast CBOD (mg/1) 2.4 (BOD5 1.2)
Organic N (mg/1) 0.055
Ammonia (mg/1) 0.04
Nitrate + Nitrite (mg/l)l 17.6
pH 7.1
Temperature (°C) 19.9
3.4 (BODs 1.7)
2.0 (BOD5 1.0)
Determined by WLA analysis
0.630
0.342
1.0
0.30
0.31
Determined by WLA analysis
16.5
13.7
3.0
6.9
6.9
7.0
21.9
24.7
25 18
'Calibration and corroboration models were developed for observed conditions in 2017 prior to the plant
improvements coming online which particularly decreased nitrate concentrations.
Below is a summary of all WLA model scenarios developed for the variety of seasonal and flow conditions
from the effluent dischargers that needed to be reviewed (Table 6).
Table 6. Rich Fork Creek QUAL21K model WLA scenario descriptions.
1 Summer Critical Conditions, Westside WRF at 8.2 MGD
2 Summer Critical Conditions, Westside WRF at 10 MGD
3 Winter Critical Conditions, Westside WRF at 8.2 MGD
4 Winter Critical Conditions, Westside WRF at 10 MGD
The results of these scenarios are used to produce a recommendation of Westside WRF permit limits for
DO, BOD5, and NH3 which are supportive of the DO water quality standard with a margin of safety, and
instream ammonia toxicity limits under both 8.2 MGD and 10 MGD flow scenarios.
The WLA scenarios for both summer and winter seasons and permitted flow rates of 8.2 and 10 MGD
were used to develop a suite of water quality permit limits for Westside WRF for DO, NH3, and BOD5. The
proposed water quality limits for Westside WRF effluent are:
• DO: daily average > 7.0 mgA year-round for both flow conditions
• NH3: monthly average of 1.0 and 2.0 mg/I for summer and winter respectively for the 8.2 MGD
flow, and a monthly average of 1.0 and 1.8 mgA for summer and winter respectively for the 10.0
MGD flow
• BOD5: monthly average of 5.0 and 10.0 mgA for summer and winter respectively for the 8.2 MGD
flow, and monthly average of 4.0 and 8.0 mg/I for summer and winter respectively for the 10.0
MGD flow
Using these proposed effluent permit limits, the results instream for minimum DO concentration and NH3
toxicity are presented below (Table 7 and Figure 2). Instream water quality criteria are met under all WLA
scenarios. Note that existing summer BOD5 and NH3 permit limits of 5 and 1 mgA respectively allow for
aTETRA TECH 7

High Point Westside WRF WLA Modeling Memo July 26, 2019
the WQ criteria for DO to be met under the 8.2 MGD flow scenario within a 5% margin of safety, however
those summer limits are modified to 4 and 1 mg/I respectively under the 10 MGD flow scenario to ensure
the margin of safety is maintained. Similarly, the existing winter BOD5 and NH3 limits of 10 and 2 mg/I
respectively allow for the WQ criteria for DO to be met under the 8.2 MGD flow scenario within a 5%
margin of safety, however those winter limits are modified to 8 and 1.8 mg/I respectively under the 10
MGD flow scenario to ensure the margin of safety is maintained. All scenario results presented in Table 7
and Figure 2 reveal minimum DO concentrations that meet the water quality criteria within a margin of
safety, and do not exceed the maximum instream concentration for NH3 toxicity.
Table 7. Rich Fork Creek QUAL2K model WLA scenarios results: instream DO and NH3.
1
Summer Critical, Westside
WRF at 8.2 MGD
5.54
1.0
2
Summer Critical, Westside
1.0
WRF at 10 MGD
5.27
1.0
5.25
3
Winter Critical, Westside
WRF at 8.2 MGD
5 81
1 8
4
Winter ritical,Westside
1.8
WRF at at 10 MGD
6.03
1.7
- - WQS (5.00 mg/1) - - Wt]S + 5% MOS (5.25 D)g/) -Summer, Westside 8.2 MGD
-Summer, Westside 10 MGD-Wnter, Westside 8.2 MGD - Wnter, Westside 10 MGD
10.0
9.0
6.0
7.0
6.0
J
E
5.0
O
O
4.0
3.0
2.0
1.0
0.0
,°° °°° °° 8 °° 8 0° °° °° 8 °° 8
Distance from headwaters 1b )
OTETRA TECH 8

High Point Westside WRF WLA Modeling Memo July26, 2019
Figure 2. QUAL2K simulation results: average longitudinal DO for WLA scenarios
Based on the WLA scenario model results, the recommended permit limits for the Westside WRF oxygen
demanding wastes are included in Table 8. The Westside WRF should be able to comply with these
modified permit limits for the specified seasons for expanded flows of both 8.2 and 10 MGD.
Table 8. Westside WRF proposed water quality permit limits for expanded 8.2 and 10 MGD flows.
Monthly Average BON
(mg/1) 10 MGD " \ 4.0 .> 8.0
Monthly Average NH3 8.2 MGD 1.0 2.0!i
(mg/1) 10 MGD 1.0 v 1.8
Daily Average DO 8.2 and 10 MGD > 7.0
(mg/1) —
OTETRA TECH 9

Banihani, Qais
From: Banihani, Qais
Sent: Tuesday, July 30, 2019 2:17 PM
To: Clements, Trevor; Grzyb, Julie; Behm, Pamela; Crabtree, Taylor
Cc: Yonce, Hillary; Terry Houk ([e-mail]); Glenn Dunn
(gdunn@ poynerspruill.com)
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
Traver,
Thank you for submitting the revised WLA memo and we are looking forward to receiving the letter providing
supplemental EA documentation for the City of High Point Westside permit (NC0024228).
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
gais.banihani(@ncdenceov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
En vJron m en ta!
Qucr!!t y
From: Clements, Trevor <[e-mail]>
Sent: Friday, July 26, 2019 1:22 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Qais and Pam,
Thank you for your call yesterday to go over the outstanding issues. It was helpful to get the clarification first hand. The
attached revised memo is provided for your review. We reorganized the front portion of the memo to incorporate the
I

discussion of sand mining as agreed to and made a few additional refinements to the text and document formatting. Per
our discussion we will move forward with preparing the letter to document the change in stream channel conditions
that has been observed since the previous studies that were referenced in the EA for the Westside facility expansion.
Please provide any additional direction for that letter as required.
Thank you,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.82781 Cell: 919.328.0175
trevor.dements0tetmtech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Clements, Trevor
Sent: Friday, July 19, 2019 3:26 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <Iulie.grzyb(@ncdenr.gov>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary<[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Qais,
This is in follow up to our conversation today. I recognize now that while you, Pam, Hillary and I discussed the resolution
of the sand mining model configuration over the phone prior to submitting the WLA modeling files, the brief memo does
not explicitly address the matter. However, you will note in the model configuration, that the short reach number 2 in all
scenarios represents the sand mining pool above HWY 109. The documentation is provided in the revised modeling
report dated 10-24-18, and this same mine configuration is assumed in the QUALM WLA scenarios. As noted below, we
believe that per the sand mining permit requirements, this is a conservative assumption. We look forward to our follow
up discussion with you and Pam upon her return to determine if any further concerns remain.
Thank you,
Trevor
From: Clements, Trevor
Sent: Friday, July 19, 20191:57 PM
To: Banihani, Dais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Hi Qais,

Would you please clarify your request? We checked the general permit requirements and the only thing specific to
stream channel is that the sand mining activities cannot cause unstable stream banks. The HWY 109 sand mining
operation is likely out of compliance in this regard as they have caused what appears to be a very significant level of
streambank instability essentially disconnecting the floodplain from the stream channel. We have incorporated the HWY
109 sand mining area into the model even though technically it appears out of compliance, thus it would appear that our
model is more conservative than required. The previous sand mining operations are no longer permitted and the model
assumptions reflect the actual surveyed conditions of those areas. Given these circumstances, we are not clear on DEQ
expectations. Would you please state specifically what the model assumptions should be for WIA consideration of sand
mining operations and provide the appropriate citation for reference?
Much appreciated,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.82781 Cell: 919.328.0175
trevor. clem entstetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.letratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, July 19, 2019 1:43 PM
To: Clements, Trevor <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <Hilia [e-mail]>; Terry Houk ([e-mail])
<terry.houk@high pointnc.eov>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Trevor,
In out last joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL2K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 10 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihani@ncdenr.¢ov

Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
Environmental
Quality
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 201911:03 AM
To: Grzyb, Julie <][e-mail]>; Banihani, Qais <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WLA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WLA and effluent limits should be summarized including the new margin of safety incorporated.
3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.20581 Main: 919.485.82781 Fax: [phone]
trevor.clem ents(cDtetratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.telratech.com

PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the Intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor<[e-mail]>; Behm, Pamela <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <Hilia [e-mail]>; Terry Houk
([e-mail]) <[e-mail]>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL21K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
gais.banihani @ncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Envtronmen ta/
Quczlit y
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <lulie.¢rzvb@ncdenr.¢ov>; Yonce, Hillary <[e-mail]>; Terry Houk
([e-mail]) <terrv.houk@high pointnc.sov_>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL21K
models set up for WIA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA

analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clem enlsCa).tetratech.mm
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Behm, Pamela
Sent: Tuesday, July 23, 2019 10:30 AM
To: Banihani, Qais
Cc: Hong, Bongghi; Grzyb, Julie
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
I'm not sure a meeting is required here. We had discussed this at the last meeting. We were told 2 of the sand mining
permits were rescinded (or expired and they just hadn't applied for a new permit). We were told the one site still has an
active permit. Under the requirements of the general permit, they can not alter the conditions of the stream. But we
have seen in the past that the conditions of the general permit were violated previously, therefore anyone who applies
for a general permit for sand mining in Rich Fork Creek needs to get an individual permit. The most important point
here is that we can't hold High Point responsible for modeling stream conditions that represent violations for permits
they are not responsible for. We (DEQ) are responsible for holding those with sand mining permits responsible and
ensuring that those violations do not occur again and it looks like we may need to crack down on the existing site, but
that is our responsibility, not High Point's. The model represents current conditions, which includes the sand mining
conditions at the one active site. This is what was agreed to during our last conference call with Trevor.
All of this will need to be discussed in detail in the addendum they will prepare to document the changes. The
model/documentation does indicate that the permit should have strider limits for the 10 MGD expansion.
From: Banihani, Qais <[e-mail]>
Sent: Tuesday, July 23, 2019 9:44 AM
To: Behm, Pamela <[e-mail]>; Hong, Bongghi <[e-mail]>
Subject: FW: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Just realized that I did not send it to Bongghi, Sorry Bongghi.
Bongghi — Please see my email below.
Have a good day,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
gais.banihani(@ncdenr.gov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617

En vlrvntnen tal
Quality
From: Banihani, Qais
Sent: Tuesday, July 23, 2019 7:47 AM
To: Behm, Pamela ([e-mail]) <[e-mail]>
Subject: FW: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Good morning Pam,
I would like to meet with you and Bongghi if possible this week to talk about the revised QUAL2K/WLA for City of High
Point (NC0024228). In particular I would like to know if the submitted model incorporated the mining sites and how the
model approached such sites. Traver is expecting us to talk to him about it this week so he can move forward with the
EA (email below). Let me know what is the best day and time to talk about it.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En vlran mental
Quality
From: Clements, Trevor <[e-mail]>
Sent: Friday, July 19, 2019 3:26 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn (Rdunn(cDpovnerspruill.com) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit

Qais'
This is in follow up to our conversation today. I recognize now that while you, Pam, Hillary and I discussed the resolution
of the sand mining model configuration over the phone prior to submitting the WLA modeling files, the brief memo does
not explicitly address the matter. However, you will note in the model configuration, that the short reach number 2 in all
scenarios represents the sand mining pool above HWY 109. The documentation is provided in the revised modeling
report dated 10-24-18, and this same mine configuration is assumed in the QUAL2K WLA scenarios. As noted below, we
believe that per the sand mining permit requirements, this is a conservative assumption. We look forward to our follow
up discussion with you and Pam upon her return to determine if any further concerns remain.
Thank you,
Trevor
From: Clements, Trevor
Sent: Friday, July 19, 2019 1:57 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <Hilia [e-mail]>; Terry Houk ([e-mail])
<terry.houk hiehaointnc.eov>; Glenn Dunn (adunn(cDDovnersaruill.com) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Hi Qais,
Would you please clarify your request? We checked the general permit requirements and the only thing specific to
stream channel is that the sand mining activities cannot cause unstable stream banks. The HWY 109 sand mining
operation is likely out of compliance in this regard as they have caused what appears to be a very significant level of
streambank instability essentially disconnecting the floodplain from the stream channel. We have incorporated the HWY
109 sand mining area into the model even though technically it appears out of compliance, thus it would appear that our
model is more conservative than required. The previous sand mining operations are no longer permitted and the model
assumptions reflect the actual surveyed conditions of those areas. Given these circumstances, we are not clear on DEQ
expectations. Would you please state specifically what the model assumptions should be for WLA consideration of sand
mining operations and provide the appropriate citation for reference?
Much appreciated,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.82781 Cell: 919.328.0175
trevor.clem ents(ciitehatech.00m
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, July 19, 2019 1:43 PM
To: Clements, Trevor<[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>

Cc: Yonce, Hillary <[e-mail]>; Terry Houk (terry.houk@highJ)ointnc.gov)
<[e-mail]>; Glenn Dunn (gdunn(@povnerspruill.com) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Trevor,
In outlast joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL2K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 10 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
En v1mnmen tca/
Quall►y
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 2019 11:03 AM
To: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk (terry.houkCdhighpointnc.gov)
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WLA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:

1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WLA and effluent limits should be summarized including the new margin of safety incorporated.
3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.20581 Main: 919.485.82781 Fax: [phone]
trevor. clem ents(a)tetra tech. com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor <[e-mail]>; Behm, Pamela <pamela.behm@ncdenr.¢ov>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <Hillary.Yonce tetratech.com>; Terry Houk
([e-mail]) <terry.houk hiahpointnc.ftov>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL2K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihani @ncdenr.¢ov-
Physical Address: 512 North Salisbury St.,Raleigh, INC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617

Environmental
Quality
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 201910:40 AM
To: Behm, Pamela <pamela.behm@ncdenr.¢ov>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <[e-mail]>; Terry Houk
(terry.houk(ciihifthpointnc.sov) <[e-mail]>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models setup for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.82781 Cell: 919.328.0175
trevocclements(a)tetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetralech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Hong, Bongghi
Sent: Saturday, July 20, 2019 2:18 PM
To: Grzyb, Julie; Banihani, Qais
Cc: Behm, Pamela
Subject: Re: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
Hi Julie and Qais,
Below are some things I considered regarding the sand mining issue:
- Just to make it clear, the stream configuration parameters for Rich Fork Creek were not changed from the
initial QUAL2K model setup (May 2018) in the subsequent revisions (October 2018 and June 2019).
- In our comments to the initial modeling report (May 2018), Modeling and Assessment Branch asked
to include scenarios considering the "previously observed pools caused by sand mining activities".
- Based on the recently surveyed conditions of sand mining area, Tetra Tech claims that the current model
setup adequately considers the current (not previous) sand mining activities (October 2018 report and below
email).
- Tetra Tech plans to address the "previous issues of sand mining and excessive treefall" through supplemental
EA documentation to be submitted.
- The most recently revised model (June 2019) includes 5% margin of safety, acquired by lowering the effluent
BOD concentrations from the initial setup. This should at least provide some "wiggle room".
In my opinion, one possible way to go from here could be to accept the modeling work as is (i.e., recently
surveyed condition only) and wait for the EA documentation. If the EA fails to demonstrate that the historic
sand mining condition doesn't need to be considered for the current permit, we can then ask to do additional
scenarios. (Also, I believe the modeling branch is capable of doing this assessment, if it really comes to that.)
From: Grzyb, Julie
Sent: Friday, July 19, 2019 6:17 PM
To: Banihani, Qais
Cc: Hong, Bongghi
Subject: FW: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Qais,
So will need to ask Pam and Bongghi is the agree that it was addressed give Trevor's statement below.
Thanks,
Julie
From: Clements, Trevor[mailto:[e-mail]]
Sent: Friday, July 19, 2019 3:26 PM

To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Qais,
This is in follow up to our conversation today. I recognize now that while you, Pam, Hillary and I discussed the resolution
of the sand mining model configuration over the phone prior to submitting the WLA modeling files, the brief memo does
not explicitly address the matter. However, you will note in the model configuration, that the short reach number 2 in all
scenarios represents the sand mining pool above HWY 109.Ehe documentation is provided in the revised modeling
report dated 10-24-18, and this same mine configuration is assumed in the QUAL2K WLA scenariosyAs noted below, we
believe that per the sand mining permit requirements, this is a conservative assumption. We look forward to our follow
up discussion with you and Pam upon her return to determine if any further concerns remain.
Thank you,
Trevor
From: Clements, Trevor
Sent: Friday, July 19, 2019 1:57 PM
To: Banihani, Qais <gais.banihan'[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <Hillary.YoncePtetratech.com>; Terry Houk ([e-mail])
<terry.houk(@high gointnc.aov>; Glenn Dunn (gdunn(&oovnersoruill.com) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Hi Qais,
Would you please clarify your request? We checked the general permit requirements and the only thing specific to
stream channel is that the sand mining activities cannot cause unstable stream banks. The HWY 109 sand mining
operation is likely out of compliance in this regard as they have caused what appears to be a very significant level of
streambank instability essentially disconnecting the floodplain from the stream channel. We have incorporated the HWY
109 sand mining area into the model even though technically it appears out of compliance, thus it would appear that our
model is more conservative than required. The previous sand mining operations are no longer permitted and the model
assumptions reflect the actual surveyed conditions of those areas. Given these circumstances, we are not clear on DEQ
expectations. Would you please state specifically what the model assumptions should be for WLA consideration of sand
mining operations and provide the appropriate citation for reference?
Much appreciated,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.82781 Cell: 919.328.0175
trevor.dementsitinetratech com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetmtech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this

communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, July 19, 2019 1:43 PM
To: Clements, Trevor<[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Trevor,
In outlast joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL2K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 10 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
aais.banihani@ ncden r.gov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
Environmental
Quality
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 2019 11:03 AM
To: Grzyb, Julie <iulie.grzvb ncdenr.gov>; Banihani, Qais <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit

Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WLA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 30 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WLA and effluent limits should be summarized including the new margin of safety incorporated.
3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.2058 1 Main: 919.485.8278 1 Fax: [phone]
trevor.clem ents(Mtetratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <oais.banihaniCdncdenr.Rov>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor <Trevor.ClementsCotetratech.com>,, Behm, Pamela <pamela.behm(@ncdenr.gov>
Cc: Grzyb, Julie <iulie.arzvb(dncdenr.eov>; Yonce, Hillary <Hillary.Yonce([e-mail]>; Terry Houk
(terry.houkPhigh pointnc.aov) <terry.houk(ahigh oointnc.aov>
Subject: RE: [External] QUAL21K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL21K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani

Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
A =_;_
EnvlronmentW
Qucel/ty
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <[e-mail]>; Terry Houk
([e-mail]) <terry.houk@high pointnc.gov>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0176
trevocclem enlsCcDtetratech.com

Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Friday, July 19, 2019 3:26 PM
To: Banihani, Qais; Grzyb, Julie; Behm, Pamela; Crabtree, Taylor
Cc: Yonce, Hillary; Terry Houk ([e-mail]); Glenn Dunn
([e-mail])
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
Qais,
This is in follow up to our conversation today. I recognize now that while you, Pam, Hillary and I discussed the resolution
of the sand mining model configuration over the phone prior to submitting the WLA modeling files, the brief memo does
not explicitly address the matter. However, you will note in the model configuration, that the short reach number 2 in all
scenarios represents the sand mining pool above HWY 109. The documentation is provided in the revised modeling
report dated 10-24-18, and this same mine configuration is assumed in the QUAL2K WLA scenarios. As noted below, we
believe that per the sand mining permit requirements, this is a conservative assumption. We look forward to our follow
up discussion with you and Pam upon her return to determine if any further concerns remain.
Thank you,
Trevor
From: Clements, Trevor
Sent: Friday, July 19, 2019 1:57 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Hi Qais,
Would you please clarify your request? We checked the general permit requirements and the only thing specific to
stream channel is that the sand mining activities cannot cause unstable stream banks. The HWY 109 sand mining
operation is likely out of compliance in this regard as they have caused what appears to be a very significant level of
streambank instability essentially disconnecting the floodplain from the stream channel. We have incorporated the HWY
109 sand mining area into the model even though technically it appears out of compliance, thus it would appear that our
model is more conservative than required. The previous sand mining operations are no longer permitted and the model
assumptions reflect the actual surveyed conditions of those areas. Given these circumstances, we are not clear on DEQ
expectations. Would you please state specifically what the model assumptions should be for WLA consideration of sand
mining operations and provide the appropriate citation for reference?
Much appreciated,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager

Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevocclements0tetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, INC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, July 19, 2019 1:43 PM
To: Clements, Trevor<[e-mail]>; Grzyb, Julie <iulie.¢[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<terry.houk@high pointnc.gov>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Trevor,
In out last joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL2K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 30 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En vtron men tca!
Quality
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 2019 11:03 AM
To: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>; Behm, Pamela
2

<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<terry.houk@high pointnc.gov>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WLA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WLA and effluent limits should be summarized including the new margin of safety incorporated.
3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.2058 1 Main: 919.485.8278 1 Fax: [phone]
trevor dements(-tetratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor<[e-mail]>; Behm, Pamela <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <[e-mail]>; Terry Houk
(terry.houk(@hi¢hpointnc.aov) <terry.houk@high pointnc.¢ov>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,

Thanks for sending QUAL21K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
K,
En v/rvri nl en ra/
Quu //r y
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <oais.banihaniCCDncdenr.gov>
Cc: Grzyb, Julie <iulie.¢[e-mail]>; Yonce, Hillary <Hillary.YonceCdtetratech.com>; Terry Houk
(terry.houkCa highpointnc.eov) <terrv.houkhighpointnc.aov>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models set up for WIA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WIA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor

Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevocclements(clitetratech com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.00m
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the Intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Friday, July 19, 2019 1:57 PM
To: Banihani, Qais; Grzyb, Julie; Behm, Pamela; Crabtree, Taylor
Cc: Yonce, Hillary, Terry Houk ([e-mail]); Glenn Dunn
([e-mail])
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
Hi Qais,
Would you please clarify your request? We checked the general permit requirements and the only thing specific to
stream channel is that the sand mining activities cannot cause unstable stream banks. The HWY 109 sand mining
operation is likely out of compliance in this regard as they have caused what appears to be a very significant level of
streambank instability essentially disconnecting the floodplain from the stream channel. We have incorporated the HWY
109 sand mining area into the model even though technically it appears out of compliance, thus it would appear that our
model is more conservative than required. The previous sand mining operations are no longer permitted and the model
assumptions reflect the actual surveyed conditions of those areas. Given these circumstances, we are not clear on DEQ
expectations. Would you please state specifically what the model assumptions should be for WLA consideration of sand
mining operations and provide the appropriate citation for reference?
Much appreciated, (� / 4-
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175 J
trevor.clem ents(n)tetratech.wm
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, July 19, 2019 1:43 PM
To: Clements, Trevor<[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Trevor,

In outlast joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL2K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 10 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
F. n vlronmen ral
Quallry
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 2019 11:03 AM
To: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <tcrabtree@ncdoi.¢ov>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk (terry.houk6Dhighpointnc.gov)
<[e-mail]>; Glenn Dunn (Rdunn(apovnerspruill.com) <[e-mail]>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WIA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WLA and effluent limits should be summarized including the new margin of safety incorporated.

3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919,485,2058 1 Main: 919.485.82781 Fax: [phone]
trevocclements0tetratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor <[e-mail]>; Behm, Pamela <[e-mail]>
Cc: Grzyb, Julie <][e-mail]>; Yonce, Hillary <Hillary.Yonce([e-mail]>; Terry Houk
([e-mail]) <[e-mail]>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL2K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Environmental
Quallry

From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <Hilia [e-mail]>; Terry Houk
([e-mail]) <[e-mail]>
Subject: (External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WIA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
n. o
Best, C 1�
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 : Main: 919.485.8278 1 Cell: 919.328.0175
trevocclements(av)tetratech mm
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 I www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Hong, Bongghi
Sent: Saturday, July 20, 2019 2:18 PM
To: Grzyb, Julie; Banihani, Qais
Cc: Behm, Pamela
Subject: Re: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
Hi Julie and Qais,
Below are some things I considered regarding the sand mining issue:
- Just to make it clear, the stream configuration parameters for Rich Fork Creek were not changed from the
initial QUAL2K model setup (May 2018) in the subsequent revisions (October 2018 and June 2019).
- In our comments to the initial modeling report (May 2018), Modeling and Assessment Branch asked
to include scenarios considering the "previously observed pools caused by sand mining activities".
- Based on the recently surveyed conditions of sand mining area, Tetra Tech claims that the current model
setup adequately considers the current (not previous) sand mining activities (October 2018 report and below
email).
- Tetra Tech plans to address the "previous issues of sand mining and excessive treefall" through supplemental
EA documentation to be submitted.
- The most recently revised model (June 2019) includes 5% margin of safety, acquired by lowering the effluent
BOD concentrations from the initial setup. This should at least provide some "wiggle room".
In my opinion, one possible way to go from here could be to accept the modeling work as is (i.e., recently
surveyed condition only) and wait for the EA documentation. If the EA fails to demonstrate that the historic
sand mining condition doesn't need to be considered for the current permit, we can then ask to do additional
scenarios. (Also, I believe the modeling branch is capable of doing this assessment, if it really comes to that.)
Bongghi
From: Grzyb, Julie
Sent: Friday, July 19, 2019 6:17 PM
To: Banihani, Qais
Cc: Hong, Bongghi
Subject: FW: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Qais,
So will need to ask Pam and Bongghi is the agree that it was addressed give Trevor's statement below.
Thanks,
Julie
From: Clements, Trevor [mailto:[e-mail]]
Sent: Friday, July 19, 2019 3:26 PM

To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Qais,
This is in follow up to our conversation today. I recognize now that while you, Pam, Hillary and I discussed the resolution
of the sand mining model configuration over the phone prior to submitting the WLA modeling files, the brief memo does
not explicitly address the matter. However, you will note in the model configuration, that the short reach number 2 in all
scenarios represents the sand mining pool above HWY 109. The documentation is provided in the revised modeling
report dated 10-24-18, and this same mine configuration is assumed in the QUAL2K WLA scenarios. As noted below, we
believe that per the sand mining permit requirements, this is a conservative assumption. We look forward to our follow
up discussion with you and Pam upon her return to determine if any further concerns remain.
Thank you,
Trevor
From: Clements, Trevor
Sent: Friday, July 19, 2019 1:57 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <Hillary.YonceCcDtetratech.com>; Terry Houk ([e-mail])
<terrv.houk@high pointnc.gov>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Hi Qais,
Would you please clarify your request? We checked the general permit requirements and the only thing specific to
stream channel is that the sand mining activities cannot cause unstable stream banks. The HWY 109 sand mining
operation is likely out of compliance in this regard as they have caused what appears to be a very significant level of
streambank instability essentially disconnecting the floodplain from the stream channel. We have incorporated the HWY
109 sand mining area into the model even though technically it appears out of compliance, thus it would appear that our
model is more conservative than required. The previous sand mining operations are no longer permitted and the model
assumptions reflect the actual surveyed conditions of those areas. Given these circumstances, we are not clear on DEQ
expectations. Would you please state specifically what the model assumptions should be for WLA consideration of sand
mining operations and provide the appropriate citation for reference?
Much appreciated,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clementsnc tetratech.mm
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this

communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, July 19, 20191:43 PM
To: Clements, Trevor<[e-mail]>; Grzyb, Julie <iulie.¢[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor < [e-mail]>
Cc: Yonce, Hillary <Hilia ry.Yonce@tetratech. com>; Terry Houk (terry.houk@high pointnc.sov)
<terry.houk@high pointnc.aov>; Glenn Dunn (f dunn(apovnerspruill.com) <[e-mail]>
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit
Trevor,
In out last joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL2K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 10 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
En vtronmen tat
Quottt y
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 2019 11:03 AM
To: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<terry.houk@high pointnc.eov>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit

Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WLA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WIA and effluent limits should be summarized including the new margin of safety incorporated.
3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.20581 Main: 919.485.82781 Fax: [phone]
trevocclements(atetratech com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the Intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <Qais.banihani(dncdenr.gov>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor<[e-mail]>; Behm, Pamela <pamela.behm0Dncdenr.gov>
Cc: Grzyb, Julie <julie.¢rzvbCancdenr.eov>; Yonce, Hillary <Hillary.YonceCa)tetratech.com>; Terry Houk
(terry.hou0)high oointnc.gov) <[e-mail]>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL2K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani

Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
gais.banihani (d ncdenr.gov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En vrron men ta/
Quafrry
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <Hilia rv.Yonce(@tetratech.com>; Terry Houk
(terry.houk@high pointnc.gov) <terry.houk@high pointnc.aov>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.82781 Cell: 919.328.0175
trevor. Clem ents(cMetratech.com

Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the,intended recipient, please notify
the sender by replying to this message and then delete it from your system.
0
I
co
I
v
Z
6

Banihani, Qais
From: Banihani, Qais
Sent: Friday, July 19, 2019 1:43 PM
To: Clements, Trevor, Grzyb, Julie; Behm, Pamela; Crabtree, Taylor
Cc: Yonce, Hillary; Terry Houk ([e-mail]); Glenn Dunn
(gdunn@ poynerspruill.com)
Subject: RE: [External] Preparing Letter to Supplement EA for the City of High Point Westside
NPDES Permit
Trevor,
,gut
In owf last joint meeting dated April 26, 2019, the City of High Point Westside agreed on submitting a revised QUAL2K
model for Rich Fork Creek that incorporates the impact of sand mining activity on the assimilative capacity of the
receiving stream at the expanded flows 8.2 and 10 MGD. Per your request, we also had a phone conversation back in
June 24, 2019 in which one of the main points we discussed was how to build the sand mining into the revised model.
The revised model that the Division received in June 27 does not incorporate the impact of sand mining. The Division
cannot proceed with the permit modification until the revised model include a scenario that represent active sand
mining at both 8.2 and 10 MGD.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihani@ncdenr.¢ov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
E'n vtron rnen t at
Qttattt y
From: Clements, Trevor <[e-mail]>
Sent: Thursday, July 18, 2019 11:03 AM
To: Grzyb, Julie <[e-mail]>; Banihani, Qais <[e-mail]>; Behm, Pamela
<[e-mail]>; Crabtree, Taylor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; Terry Houk ([e-mail])
<[e-mail]>; Glenn Dunn ([e-mail]) <[e-mail]>
Subject: [External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES Permit

Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WIA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WIA and effluent limits should be summarized including the new margin of safety incorporated.
3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.2058 1 Main: 919.485.82781 Fax: [phone]
trevor.clements0tetratech.com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <oais.banihani9ncdenr.eov>
Sent: Friday, June 28, 2019 2:30 PM
To: Clements, Trevor <Trevor.Clements o)tetratech.com>; Behm, Pamela <pamela.behmCai)ncdenr.gov>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <Hillarv.Yonce(oltetratech.com>; Terry Houk
(terry.houk( highoointnc.¢ov) <terry.houkCcDhigh pointnc.eov>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL2K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting

NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En vlr r�ri rr: en t ul
Qucrl/t y
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <Hilia [e-mail]>; Terry Houk
(terry.houk@high nointnc.sov) <[e-mail]>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our lastjoint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clem ents(Metratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 w Aetratech.com

a
a
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Behm, Pamela
Sent: Thursday, July 18, 2019 11:33 AM
To: Banihani, Qais; Grzyb, Julie
Subject: FW: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside
Facility
Julie and Qais,
See model review comments from Bongghi below.
From: Hong, Bongghi <[e-mail]>
Sent: Tuesday, July 16, 2019 12:52 PM
To: Behm, Pamela <[e-mail]>; Kebede, Adugna <[e-mail]>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
I looked at the memo and modeling files. Changes made in the modeling files from the October 2018 update are
relatively small, as listed below:
(1) In the previous October 2018 update, Westside WRF effluent BODS concentration under the 10 MGD scenario was
set at 5 mg/L in the summer and 10 mg/L in the winter. The minimum DO predicted to occur in Rich Fork Creek was 5
mg/L, raising concerns that with so little assimilative capacity left, any adverse change in the system (such as sand
mining activities) could result in the violation of the 5 mg/L DO standard. In the revised modeling files, the effluent BODS
concentration under the 10 MGD scenario was reduced to 4 mg/L in the summer and 8 mg/L in the winter, increasing
the predicted minimum DO in Rich Fork Creek to slightly above 5.25 mg/L (providing 5% margin of safety). However, it
should be noted that the possible impact of sand mining activities is not directly assessed in this analysis.? N,a
(2) Similarly, the effluent NH3 concentration was adjusted to make sure that Rich Fork Creek will not exceed the
instream ammonia toxicity limit. This exercise actually led to an increase, not a decrease, of the wintertime NH3 limit
from 1.8 mg/L to 2 mg/L under the 8.2 MGD scenario (compared to the October 2018 update). This seems worth noting
in the memo, though the suggested final limits don't appear to be less stringent than the existing permit limits
(#NC0024228... perhaps the NDPES Complex Permitting Branch can verify this?)
(3) Previous versions of the model did not have Thomasville WWTP discharging to Hamby Creek, a tributary of Rich Fork
Creek. Instead of adding Hamby Creek as a reach and then discharging to Hamby Creek, the revised model adds the
permitted Thomasville WWTP effluent directly to Rich Fork Creek (at the Hamby Creek -Rich Fork Creek confluence). It
could be regarded as a simplified representation of the system on the conservative side. Adding the Thomasville W WTP
discharge appears to have only a small impact on the simulation results.
Some inconsistencies noted in the original modeling work (May 2018 report) were fixed in the October 2018 update and
correctly transferred to this analysis. This memo (not the modeling files) has a number of minor typos as listed below.
We might as well have them fixed, so that we retain a version of the memo consistent with the modeling files:
Table 1:
Winter Hunts Fork flow: 0.33 cros => 0.033 cros
Winter organic nitrogen concentration: 0.12 mg/L => 0.44 mg/L
Winter nitrate and nitrite concentration: 0.44 mg/L => 0.12 mg/L

Bongghi
From: Behm, Pamela <[e-mail]>
Sent: Tuesday, July 02, 2019 1:02 PM
To: Hong, Bongghi <[e-mail]>; Kebede, Adugna <[e-mail]>
Subject: FW: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Files saved in: O:\Planning\Modelling-TMDL\NPDES and MS4\Spec Limit Evaluations\Rich Fork Creek\High Point
Westside WRF\Jun20l9Update
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <[e-mail]>; Terry Houk
(terrv.houk@highpointnc gov) <terry.houk@high pointnc.gov>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our lastjoint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WIA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WIA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.82781 Cell: 919.328.0175
trevocGementsti tetratech com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From:
Clements, Trevor <[e-mail]>
Sent:
Thursday, July 18, 2019 11:03 AM
To:
Grzyb, Julie; Banihani, Qais; Behm, Pamela; Crabtree, Taylor
Cc:
Yonce, Hillary; Terry Houk ([e-mail]); Glenn Dunn
(gdunn@ poynerspruill.com)
Subject:
[External] Preparing Letter to Supplement EA for the City of High Point Westside NPDES
Permit
Julie and Qais,
We'd like to get started on the letter providing supplemental EA documentation for the City of High Point Westside
permit if you have no objection. At our last meeting, Taylor suggested getting the modeling done for the WLA as the first
step. I don't know if you've had a chance to look at what was submitted, but do you see any problem with proceeding
on the letter providing the supplemental information? At this time, based on our discussion at the last meeting, the
t.
letter would provide the following:
1. A summary of how the results of recent monitoring and modeling studies demonstrate substantive change from
the monitoring and modeling studies 10 years earlier.
a. Address previous issues of sand mining and excessive treefall, providing photo and other documentation
of changes.
2. The revised WLA and effluent limits should be summarized including the new margin of safety incorporated.
3. A strategy for how the City plans to monitor stream channel condition including periodic analysis of treefall.
Taylor, is there anything else that you would suggest to include to address SEPA considerations?
Our staff have availability to work on this next week so please let us know as soon as possible if there are concerns or if
you have any additional direction or clarification on the needed elements of the letter.
Thank you for your consideration in this matter.
Sincerely,
Trevor
Trevor Clements I President
Direct: 919.485.2058 1 Main: 919.485.8278 1 Fax: [phone]
trevocclements(cDtetratech. com
Tetra Tech Engineering P.C. I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.letratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Friday, June 28, 2019 2:30 PM

To: Clements, Trevor <[e-mail]>; Behm, Pamela <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <[e-mail]>; Terry Houk
([e-mail]) <[e-mail]>
Subject: RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good afternoon Trevor,
Thanks for sending QUAL2K modeling files. The Division will review the model and get back to you
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oais.banihaniCla ncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
Env/ronmen ta/
Quality
From: Clements, Trevor<Trevor.ClementsC�tetratech.com>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela <pamela.behmCdncdenr.eov>; Banihani, Qais <gais.banihanilancdenr.gov>
Cc: Grzyb, Julie <julie.arzvbCancdenr.zov>; Yonce, Hillary <Hillarv.Yonce(a�tetratech.com>; Terry Houk
(terrv.houkCa highpointnc.gov) <terrv.houk0hiahpointnc.Rov>
Subject: [External] QUAL21K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the

next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clementsra)tetratech com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetralech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From:
Banihani, Qais
Sent:
Friday, June 28, 2019 2:30 PM
To:
Clements, Trevor, Behm, Pamela
Cc:
Grzyb, Julie; Yonce, Hillary; Terry Houk ([e-mail])
Subject:
RE: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside
Facility
Good afternoon Trevor,
Thanks for sending QUAL2K modeling files. The Division will review the model and get back to you.
Have a great weekend,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Env/ronmentcr!
Quorrr y
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 201910:40 AM
To: Behm, Pamela <[e-mail]>; Banihani, Qais <[e-mail]>
Cc: Grzyb, Julie <[e-mail]>; Yonce, Hillary <[e-mail]>; Terry Houk
([e-mail]) <[e-mail]>
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our last joint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the

Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919,485.8278 1 Cell: 919.328.0175
trevocclements(oitetratech.00m
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the Intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Yonce, Hillary <[e-mail]>
Sent: Thursday, June 27, 2019 11:54 AM
To: Behm, Pamela; Banihani, Qais
Subject: [External] Yonce, Hillary shared the folder "RichForkCreek-For_Delivery" with you.
External email. Do not
Hello all, here is a link to the PDF memo and four modeling files for your review for
Rich Fork Creek WLA scenarios. Thanks all, and please be in touch if you have any
questions! - Hillary
t% This link only works for the direct recipients of this message.
0 Rich ForkCreek_For_Delivery
Ei Microsoft OneDrive
Microsoft respects your privacy. To learn more, please read our Privacy Statement.
Microsoft Corporation, One Microsoft Way, Redmond, WA 98052

Banihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Thursday, June 27, 2019 10:40 AM
To: Behm, Pamela; Banihani, Qais
Cc: Grzyb, Julie; Yonce, Hillary; Terry Houk ([e-mail])
Subject: [External] QUAL2K Modeling for Rich Fork WLA Analysis for High Point Westside Facility
Attachments: Westside WLA Memo 6-27-2019.pdf
CAUTIOIWirt.
Good morning Pam and Qais,
In follow up to our conversation and the direction outlined during our lastjoint meeting, we are transferring the QUAL2K
models set up for WLA analysis for the expanded flows of the City of High Point Westside Water Reclamation Facility.
The attached pdf provides a summary of how the previously calibrated and corroborated model was set-up for WLA
analysis and the corresponding recommendations for limits that will protect the water quality standard with a 5 percent
margin of safety. The analyses include very conservative assumptions accounting for potential interaction with the
Thomasville discharge into Hamby Creek as it flows into Rich Fork Creek, increasing confidence that water quality
standards will be attained.
Given the size of the four QUAL2K modeling files to be transferred, Hillary will send a link for Qais to download those
files directly. Please let us know if you have any questions or would like to discuss modeling assumptions or analyses
further (please email both Hillary and me with any correspondence as each of us will be out at different times over the
next 2 weeks but the person here can respond accordingly). Per Taylor Crabtree's consultation at our last meeting, once
the Division has confirmed the WLA we can then provide the supplemental document documenting the changes in Rich
Fork Creek since the last EA was conducted to support decisions regarding NPDES permit requirements. We look forward
to working through this process with you.
Best,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clem ents()tetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.letmtech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

N
TETRA TECH
To: Julie Gryzb, NCDWR
Pam Behm, NCDWR
CC: Terry Houk, City of High Point
From: Hillary Yonce, Tetra Tech
Trevor Clements, Tetra Tech
5700 Lake Wright Drive Suite 102
Norfolk, Virginia 23502
Tel [phone] • Fax [phone]
MEMORANDUM
Date: June 27,2019
Subject: City of High Point Westside Water
Reclamation Facility W asteload
Allocation Scenario Results and
Proposed Permit Limits
This memo summarizes modeling methods and recommendations for a wasteload allocation (WLA) and
proposed effluent limits for the Westside Water Reclamation Facility (WRF) for consideration by the North
Carolina Division of Water Resources (NCDWR). The Westside WRF has undergone treatment upgrades
to improve water chemistry of its effluent and is seeking to expand its existing permit from 6 MGD to 8.2
MGD in the near -term (intermediate), and 10 MGD in the long-term (full capacity). This memo documents
the modeling methodology and assumptions used to assess the assimilative capacity of Rich Fork Creek
to meet existing water quality standards within a margin of safety. 5Y. ° t- s' *il
The calibrated and corroborated QUAL2K model developed for Rich Fork Creek (Tetra Tech, 2018)1 was
used as the basis for analyzing assimilative capacity to establish an appropriate WLA. This model was
first adjusted to simulate critical summer and winter conditions which included the following modifications:
1. Removal of point sources (Westside WRF) to represent natural critical conditions
2. Seasonal 7-day minimum flow with a recurrence interval of 10 years (7Q10) at headwaters and
tributaries
3. Seasonal 90'^ percentile air and dew point temperatures
These modifications support the prediction of how Rich Fork Creek is expected to behave under
critically warm and low -flow conditions during both the summer and winter periods in the absence
of any effluent discharges. The seasonal model input modifications made for the critical condition
models are summarized in Table 1.
1 Report "Model Evaluation for Rich Fork Creek: New Data and Analyses" prepared by Tetra Tech for the
City of High Point Public Services, October 26, 2018.
OTETRA TECH

High Point Westside WRF WLA Modeling Memo
Table 1. Summary of critical condition QUAL2K model Inputs.
June 27, 2019
Simulation Date
August 31, 2017
November 16, 2017
Air Temperature, aC
27.5
16.7
Dew Point Temperature, °C
23.6
12.8
Headwater Flow, cfs (cros)
0.67 (0.019)
1.90 (0.054)
Kennedy Mill Flow, cls (cros)
0.25 (0.0071)
0.70 (0.020)
Hunts Fork Flow, ofs (cros)
0.42 (0.012)
1.18 (0.33)
Hamby Creek Flow, cfs (cros)
1.05 (0.030)
2.97 (0.064)
Water Temperature, aC
24.5
13.0
Dissolved Oxygen', mgA
6.6
8.5
Ammonia', mg/1
0.06
0.04
Organic Nitrogen', mg/I
0.33
0.12
Nitrate and Nitrite', mg/i
0.22
0.44
Slow Carbonaceous Biochemical Oxygen Demand', mgA
2.0
2.0
'Water chemistry assigned to both headwaters and tributaries
The results of these two scenarios are shown below in Figure 1, indicating that the dissolved oxygen (DO)
water quality standard (WQS) for Rich Fork Creek of 5.0 mg/I in the absence of the Westside WRF
discharge is not predicted to be maintained under the most critical conditions. The minimum daily average
DO concentration during the summer is estimated as 0.00 mg/I (anoxic conditions), and during winter is
estimated as 4.93 mg/l.
--Was -Scenario
1: Summer7010(no effluent)
- scenarlo2 Winter 7010(no effluent)
wealaHeW MldweY
Kennedy Road
Bell Kenoy Hunts Ewa
Road Road Creek Road
a0 Z9 Hamby Creek
Mill Creek
1 11
1
10.0
9.0
8.0
7.0
2
E
6.0
0
0.0
4.0
ao
109
2.0
Pool
1.0
0.0
Distance from outlet (Rd)
Figure 1. QUAL2K results: average longitudinal DO for natural seasonal critical conditions.
® TETRA TECH 2

High Point Westside WRF WLA Modeling Memo June 27, 2019
The seasonal critical conditions QUAL2K models were used to simulate the addition of point sources to
ensure that the permitted maximum effluent limits can be assimilated during the most critical conditions
instream while allowing for a reasonable margin of safety (MOS) for aquatic health. For the wasteload
allocation (WLA) scenario development, the existing wastewater treatment facility located on Hamby sM`'
Creek (Thomasville Hamby Creek Wastewater Treatment Plant [WWTP], National Pollution Discharge
Elimination System [NPDES] ID NC0024112) was included in the simulation to incorporate potential
interaction between the discharges for WLA purposes. The Thomasville WWTP is located on Hamby
Creek approximately six miles upstream of the confluence, so it is likely that a large amount of v\ fZ^ck
assimilation will occur along Hamby Creek before the confluence with Rich Fork Creek. To be crm k
conservative in the simulation of potential interactions however, the Thomasville Hamby Creek WWTP is
assumed to discharge directly into Rich Fork Creek at the point of the Hamby Creek confluence to
represent maximum potential Impact of permitted flows and water chemistry on Rich Fork under critical .c 0%j) tP
conditions.
Seasonal QUAL2K model scenarios for W LA purposes were developed under the following conditions:
• Seasonal critical conditions (seasonal 7Q10 flows and temperatures)
�Z . Thomasville WWTP on Hamby Creek set to permit limits for flow and water chemistry
• Westside WRF flow set to 10 MGD
Under these conditions, the model was run iteratively to identify what combination of Westside WRF
effluent permit limits would allow for assimilative capacity to be met instream along Rich Fork Creek. To
identify what effluent permit limits are reasonably attainable for the facility, data analysis was conducted
on existing effluent flow and water chemistry data at both Thomasville WWTP and Westside WRF.
2.1 ANALYSIS OF EFFLUENT FLOW AND WATER CHEMISTRY DATA
The existing flow and water chemistry data for the effluent discharging from Westside WRF and
Thomasville Hamby Creek WWTP can be used to inform the model parameterization and
providing insight into system performance. The Thomasville Hamby Creek WWTP seasonal
effluent data for the period 2014 —2019 are summarized in
OTETRA TECH

High Point Westside WRF WLA Modeling Memo
Table 2.
OTETRA TECH
June 27. 2019

High Point Westside WRF WLA Modeling Memo
June 27, 2019
Table 2. Existing monthly average permit limits and average seasonal effluent for Thomasville
Hamby Creek WWTP.
Parameter Season i Permit Limit I Average in Effluent (2014-2019)
Summer 2.19
Flow (MGD)
6.0
Winter
Summer
4.0
BOD5 (mg/1)
Winter
6.0
Summer
1.0
NH3 (mg/1)
Winter
3.0
Summer
TN (mg/1)
None
Winter
Summer
DO (mg/1)
6.0
Winter
Summer
Temperature ("C)
None
Winter
2.57
1.83
2.04
0.24
0.48
2.72
6.89
7.77
8.80
24.54
17.47
In October of 2013 the City of High Point received authorization from NCDEQ to construct a Water
Reclamation Facility (WRF) at the Westside facility with a capacity of 10 MGD incorporating the following
modifications to the existing 6.2 MGD facility (NCDWR, 20132):
New Biological Nutrient Removal (BNR) system consisting of four parallel trains with total
volumes of 0.50 MG anaerobic zone, 0.91 MG 181 stage anoxic zone, 4.95 MG aerobic zone, 1.48
MG 2nd stage anoxic zone, 0.29 MG re -aeration zone, including fine bubble diffusers and 40
vertical mixers; new blower/NRCY Building including two (2) 6,074 ICFM blowers, two (2) 4,050
ICFM blowers, and four (4) 6,944 gpm NRCY pumps; a new final clarifier distribution box; new
130-foot diameter, 15-foot side -water depth final clarifier; two (2) 3,550 gpm RAS pumps; a new
process drain pump station, including one (1)1,100 gpm pump; a new clarifier drain pump station
including one (1) 800 gpm pump; two (2)150 gpm non -potable water pumps; associated
electrical and control/SCADA work, sitework, and yard piping, in conformity with the project plans,
specifications, and other supporting data subsequently filed and approved by the Department of
Environment and Natural Resources.
The upgrades to the Westside WRF came online in March 2018 which had an immediate impact
on improved effluent water quality, particularly related to seasonal total nitrogen and ammonia
concentrations which decreased on average by about approximately 70 percent and 90 percent,
respectively (Table 3). Typical system performance reveals that average effluent conditions meet
existing permit limits within a relatively large margin of safety.
2 Letter to Terry Houk, City of High Point, from Thomas A. Reed, Director of NCDWR providing
authorization to construct an expanded facility, October 9, 2013.
® TETRA TECH

High Point Westside WRF WLA Modeling Memo June 27, 2019
Table 3. Existing monthly average permit limits and average seasonal effluent for Westside WRF.
Summer
2.69
2.89
Flow (MGD)
6.2
Winter
3.19
3.59
Summer
5.0
1.55
0.35
BODe(mg/1)
Winter
10.0
2.38
0.46
Summer
2.0
0.26
0.03
NH3 (mg/1)
Winter
4.0
0.29
0.01
Summer
17.71
5.45
TN (mg/1)
None
Winter
18.20
4.42
Summer
6.27
7.37
DO (mg/1)
6.0
Winter
7.32
8.10
Summer
24.41
25.26
Temperature (°C)
None
Winter
18.51
18.10
'Note that starting on March 2018, a new system of nitrification was brought online at the Westside WRF which improved water
chemistry in effluent relative to TN and NH3.
2.2 MODEL PARAMETERIZATION OF EFFLUENT DISCHARGE
The only change from the seasonal critical condition model applications to the WLA scenarios are the
additional inputs from Thomasville WWTP and the Westside WRF. QUAL2K model inputs for Thomasville
WWTP were based on permitted limits (
OTETRA TECH 6

High Point Westside WRF WLA Modeling Memo June 27, 2019
Table 4). By assuming that the Thomasville W WTP discharges directly into Hamby Creek (rather than six
miles upstream after which some instream assimilation would occur), these inputs reflect a conservative
model application. Note that while simulation results are presented for Thomasville W WTP operating at
maximum permitted flows, additional scenarios were run with the facility operating at average flow (2.43
MGD) with results indicating a similar DO profile and slightly lower instream ammonia levels under the
existing wasteflow average. In all cases, instream water quality criteria of 5.25 mg/I (reflecting a margin of
safety) and seasonal levels of ammonia of 1 mg/I in the summer and 1.8 mg/I in the winter were met.
Estimated concentrations for organic nitrogen or nitrate + nitrite provided by Hazen & Sawyer are 1.0 mg/I
and 3.0 mg/I respectively for the Westside WRF were also applied to conditions at the Thomasville
WWTP given similar treatment levels. Average observed total nitrogen concentrations at Thomasville
W WTP from 2014 -2019 are 2.72 mg/I and 6.89 mg/I in the summer and winter respectively, so model
inputs which result in a total nitrogen concentration of at least 5.0 mg/I and 7.0 mgfl seasonally is a
reasonable approximation (
® TETRA TECH

High Point Westside WRF WLA Modeling Memo
June 27, 2019
Table 4). Effluent water temperature and pH model inputs were estimated based on average observed
seasonal data.
OTETRA TECH

High Point Westside WRF WLA Modeling Memo
June 27, 2019
Table 4. Thomasville WWTP model inputs for all WLA scenarios.
Flow (MGD) 6.0
DO (mg/1)
Fast CBOD (mg/I)'
Organic N (mgA)
Ammonia (mgA)
Nitrate + Nitrite (mg/I)
pH
8.0 (based on BOD5 = 4.0 mg/1)
1.0
[nr1
12.0 (based on BOD5 = 6.0 mg/1)
1.0
3.0
3.0
7.0
Temperature (°C) 25 18
Recall from the previous modeling report that assumed relationship between BOD5:fastCBOD is 1:2
QUAL21K model inputs for the Westside WRF are presented in Table 5 alongside model inputs used for
the calibration and corroboration scenarios presented in the previous report. Seasonal model inputs for
Ammonia, fast CBOD, and DO concentrations were developed based on iterative WLA analyses to
ensure the following conditions were met, and are presented in Section 3.0 WLA Scenario Results:
• Instream DO concentrations must not fall below the water quality standard (5.0 mg/1) with an C) 5 aT
additional 5% margin of safety (5.25 mg/1) either upstream or downstream of the Thomasville ^, / L
WWTP input location.
• Instream water quality must not cause ammonia toxicity which refers to the protection of aquatic (NA7 N�
life against high instream ammonia concentrations. Instream ammonia concentrations must not
exceed 1.0 mg/I in the summer and 1.8 mgA in the winter based on NCDEQ Standard Operating \ k`; - N t g
Procedures for Ammonia Toxicity Evaluation.
Model inputs for the Westside WRF (Table 5) related to organic nitrogen, nitrate + nitrite, pH, and water
temperature were based on the same reference materials as presented in
aTETRA TECH

High Point Westside WRF WLA Modeling Memo
Table 4.
June 27, 2019
Table 5. Westside WRF model inputs for calibration, corroboration, and WLA scenarios.
Flow (MGD) 2.5 2.9 2.1 8.2 and 10.0
DO (mg/1)
7.5
6.9
7.2
Determined by WLA analysis
Fast CBOD (mgA)
2.4 (BODs 1.2)
3.4 (BODs 1.7)
2.0 (BODs 1.0)
Determined by WLA analysis
Organic N (mg/1)
0.055
0.630
0.342
1.0
Ammonia (mgA)
0.04
0.30
0.31
Determined by WLA analysis
Nitrate + Nitrite (mg/I)'
17.6 ii
16.5
13.7
3.0
PH
7.1
6.9
6.9
7.0
Temperature (°C)
19.9
21.9
24.7
25 18
'Calibration and corroboration models were developed for observed Conditions in 2017 prior to the plant
improvements coming online which particularly decreased nitrate concentrations.
Below is a summary of all WLA model scenarios developed for the variety of seasonal and flow conditions
from the effluent dischargers that needed to be reviewed (Table 6).
S''J)LX
Table 6. Rich Fork Creek QUAL2K model WLA scenario descriptions.
1 Summer Critical Conditions, Westside WRF at 8.2 MGD
2 Summer Critical Conditions, Westside WRF at 10 MGD
3 Winter Critical Conditions, Westside WRF at 8.2 MGD
4 Winter Critical Conditions, Westside WRF at 10 MGD
Vv = The results of these scenarios are used to produce a recommendation of We id WRF 't I' ' f
s sa perms emits or
DO. BODs, and NH3 which are supportive of the DO water quality standard with a margin of safety, and
instream ammonia toxicity limits under both 8.2 MGD and 10 MGD flow scenarios.
The WLA scenarios for both summer and winter seasons and permitted flow rates of 8.2 and 10 MGD
were used to develop a suite of water quality permit limits for Westside WRF for DO, NH3, and BOD5. The
proposed water quality limits for Westside WRF effluent are:
• DO: minimum of 7.0 mg/I year-round for both flow conditions
• NH3: maximum of 1.0 and 2.0 mg/I for summer and winter respectively for the 8.2 MGD flow, and
a maximum of 1.0 and 1.8 mg/I for summer and winter respectively for the 10.0 MGD flow
• BODs: maximum of 5.0 and 10.0 mg/I for summer and winter respectively for the 8.2 MGD flow,
and maximum of 4.0 and 8.0 mg/I for summer and winter respectively for the 10.0 MGD flow
sicmmner +I/1nFe(
DO
FigTETRA TECH
�IL_
�o lvo�D - - 8 r-} I
noo 4 ^J(I'

High Point Westside WRF WLA Modeling Memo
June 27. 2019
Using these proposed effluent permit limits, the results instream for minimum DO concentration and NH3
toxicity are presented below (
OTETRA TECH 11

High Point Westside WRF WLA Modeling Memo
June 27, 2019
Table 7 and Figure 2). Instream water quality criteria are.met under all WLA scenarios. Note that existing
summer BOD5 and NHa permit limits of 5 and 1 mg/I respectively allow for the WQ criteria for DO to be
met under the 8.2 MGD flow scenario within a 5% margin of safety, however,those summer limits are
modified to 4 and 1 mgA respectively under the 10 MGD flow scenario to ensure the margin of safety is
maintained. Similarly, the existing winter BOD5 and NHa limits of 10 and 2 mgA respectively allow for the
WQ criteria for DO to be met under the 8.2 MGD flow scenario within a 5% margin of safety, however
those winter limits are modified to 8 and 1.8 mg/I respectively under the 10 MGD flow scenario to ensure
the margin of safety is maintained. All scenario results presented in
ExiSk��
\o MUV=j "aaD
S "]
S I `"
\• B
-7 w3 A,
y
GNS�kS� /noS
qU
4�-�S�[ ��j-4 � ,de(.d'4-mod
VI- �p Y�✓re d -�vl�w �� 111' i G wile- �e " i
C-aMlle "i7
C7 G -
QTETRA TECH 12
IY

High Point Westside WRF WLA Modeling Memo
June 27, 2019
Table 7 and Figure 2 reveal minimum DO concentrations that meet the water quality criteria within a
margin of safety, and do not exceed the maximum instream concentration for NH3 toxicity.
OTETRA TECH 13

High Point Westside WRF WLA Modeling Memo June 27, 2019
Table 7. Rich Fork Creek QUAL2K model WLA scenarios results: instream DO and NH3.
1
Summer Critical, Westside
WRF at8.2MGD
5.54
1.0
1.0
2
SummerCdtical, Westside
WRF at 10 MGD
5.27
1.0
5.25
3
Winter Critical, Westside
5.81
1.8
WRF at 8.2 MGD
1.8
4
Winter Critical, Westside
6.03
1.7
WRF at 10 MGD
— — WQS (5.00 mg/I) — — WQS + 5% MOS (5.25 mg/) —Summer, Westside 8.2 MGD
—Summer, Westside 10 MGD —Winter, Westside 8.2 MGD —Winter, Westside 10 MGD
10.0
1 Westside WRF 1 Hamby Creek
9A
1
eA
7A
5A
E 5.0
p
________——__�______________------------ -- — — ——
--------------------------------------------------
CD
U
3A
2.0
sA
0.0
qq qPq q4, qPq PP 4q 9q 4q 9q 9q 8 dt 8 tj? 3s tP cA
q4q
'Aw ♦' w ♦ wr+ wb 4 wM1 ww wq q' P' 1• 6� •r M 9N '.q
Distance from headwaters (Ion)
Figure 2. QUAL2K simulation results: average longitudinal DO for WLA scenarios.
OTETRA TECH 14
Sm1I L-t
s S.dSmy1 �

High Point Westside WRF WLA Modeling Memo
June 27.2019
Based on the WLA scenario model results, the recommended permit limits for the Westside WRF oxygen
demanding wastes are included in Table 8. The Westside WRF should be able to comply with these
modified permit limits for the specified seasons for expanded flows of both 8.2 and 10 MGD.
Table 8. Westside WRF proposed water quality permit limits for expanded 8.2 and 10 MGD flows.
Maximum BODs (mg/1)
Maximum NHs (mg/1)
Minimum DO (mg/1)
8.2 MGD
5.0
10.0
10 MGD
4.0
8.0
8.2 MGD
1.0
2.0
10 MGD
1.0
1.8
8.2 and 10 MGD
OTETRA TECH 15
7.0

Banihani, Qais
From:
Yonce, Hillary <[e-mail]>
Sent:
Friday, June 14, 2019 11:06 AM
To:
Banihani, Qais; Behm, Pamela
Cc:
Clements, Trevor
Subject:
RE: [External] Check -in call
Hello Qais and Pam,
Thank you for the call this morning Qais, great to touch base with you. As you requested, here is a short recap of what
we discussed:
• Related to the existing permit limits for the 10 MGD effluent condition, the summer and winter ammonia
concentration limits are 1.0 and 1.8 mg/I respectively. We have requested that DEQ let us know how these were
developed (model output vs. EPA guideline for ammonia toxicity).
• In general, please share with us the DEQ approach for interpreting the EPA guideline for calculating ammonia
toxicity.
• As I mentioned, High Point and Hazen & Sawyer have been exploring new effluent limit options and how they
relate to achievable system performance. Modeling of future performance is being conducted and there should
be a delivery of model files and accompanying memo in the near future.
• Based on direction from Taylor Crabtree, we were instructed to move forward with the WLA element, and he is
planning to advice on the documentation related to supplemental information related to the sand mining
activities. As I mentioned, the sand mining general permit has stated that activities "may not impact channel and
bank stability". Our current plan is to complete the WLA piece, then as a supplemental piece: explore existing
data, photographic evidence, and propose monitoring if tree fall as a way for the City to the move forward. We
would like to discuss this further on the phone with Pam when possible. Pam: when is the best time for Trevor
and I to touch base with you over the phone?
Thanks again, and feel free to be in touch if you have any questions.
Hillary Yonce, P.H. I Professional Hydrologist, Environmental Scientist
Direct: 919.485.2077 1 Main: 919.485.8278 I Fax: [phone]
H illarv.Yonce()tetratech.00m
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200, Research Triangle Park, NC 27709 1 www.tetrateoh.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Thursday, June 13, 2019 2:44 PM
To: Yonce, Hillary <H ilia [e-mail]>
Subject: RE: [External] Check -in call

A CAUTION: This email originated from an external sender. Verify the source before opening links or attachments. Q
Hi Hillary,
Feel free to contact me tomorrow between 10 am —12 pm.
Thanks,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
E'n vlron tnen tu/
Quu/!ty
From: Yonce, Hillary <[e-mail]>
Sent: Thursday, June 13, 2019 2:12 PM
To: Banihani, Qais <gais.banihani@ncdenr.¢ov>
Subject: [External] Check -in call
Hello Qais,
I am working with Trevor Clements on the City of High Point Westside Water Reclamation Facility (NC0024228) project.
would love to touch base with you on the phone anytime tomorrow if you are available for a quick call? I'd like to
provide you with a brief update on the project and also ask you a question or two. If email is preferred, I can also
provide the update/questions via email. Thanks!
Hillary Yonce, P.H. I Professional Hydrologist, Environmental Scientist
Direct: 919.485.2077 1 Main: 919.485.8278 1 Fax: [phone]
Hillary.Yoncentetratech. corn
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200, Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

Banihani, Qais
From: Behm, Pamela
Sent: Thursday, June 13, 2019 11:09 AM
To: Banihani, Qais
Subject: High Point
My notes match yours for High Point. The town was going to see if they could meet lower limits at the new facility and
then run the model with the new lower limits. We also are not going to require they represent all 3 sand mines, as 2 of
those permits have been rescinded. But 1 remains and needs to be represented as best as they can. I also mentioned
during the meeting that it would be helpful if they could provide before/after photos for some of the places they
showed in the SEPA documents as being blocked by fallen trees. Not necessary, but would go a long way towards
showing that there has been an improvement.
Pam Behm
Branch Chief
Modeling and Assessment Branch, Planning Section, Division of Water Resources
Department of Environmental Quality
PLEASE NOTE NEW PHONE NUMBER:
919 707 3687 office
[e-mail]
1611 Mail Service Center
Raleigh, NC 27699-1611
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.

Banihani, Qais
From:
Terry Houk <[e-mail]>
Sent:
Tuesday, January 15, 2019 10:10 AM
To:
Clements, Trevor; Banihani, Qais
Cc:
Behm, Pamela
Subject:
[External] RE: Follow up on NC0024228 Model
Thanks Trevor,
terry
From: Clements, Trevor <[e-mail]>
Sent: Tuesday, January 15, 2019 8:08 AM
To: Banihani, Qais <[e-mail]>
Cc: Behm, Pamela <[e-mail]>; Terry Houk <[e-mail]>
Subject: RE: Follow up on NCO024228 Model
Hello Qais,
Your response has been communicated with the City. At this time, we are awaiting the City response.
Thank you,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
„rcy;::;cd 147.;cr 114anagement
Direct: 919.435.120581 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clem ents(a)tetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Su : 14409 I 1 Park Drive, Suits 200 1 Research Triangle Park, NC 27709 1 www.tetratech.wm
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the Intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Tuesday, January 15, 2019 7:41 AM
To: Clements, Trevor <[e-mail]>
Cc: Behm, Pamela <[e-mail]>
Subject: Follow up on NCOO24228 Model
Dear Mr. Clements,

I just want to follow up on my previous email dated December 17, 2018 regarding including scenario that represents
active sand mining at 8.2 and 10 MGD for the City of High Point's Westside reclamation Facility
(NC0024228). Please feel free to contact Ms. Behm or myself with any questions you might have.
Sincerely,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
oa is. ba n Than i @ ncden r.aov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En v(ronmen ra!
QUC111 ry
From: Banihani, Qais
Sent: Monday, December 17, 2018 7:23 AM
To: 'Clements, Trevor' <[e-mail]>
Subject: Cape Fear Model NCO024228
Dear Mr. Clements,
The Division of Water Resources NPDES unit has reviewed your response to our comments regarding the
modeling report entitled "Model Evaluation for Rich Fork Creek: New data and Analysis" submitted to the
Division in support of the permit condition's change request for the City of High Point's Westside reclamation
Facility (NC0024228). The Division still has the following comments:
1. Since the use of monthly limits is consistent with NPDES Permitting practices, the Division is
withdrawing its comment regarding the use of monthly versus weekly limits in Qua12K analysis.
2. Rich Fork Creek is a unique case where permitted sand mining is documented through the SEPA process
for this expansion as having impacts on assimilative capacity when deep pools are formed from the mining
activities. In order to agree to a major permit modification, the Division will need to demonstrate that
concerns identified in the SEPA process have been evaluated. As would be required for any known
permitted source, there needs to be a demonstration that the creek has assimilative capacity in the presence
of sand mining activities. The model should include a scenario that represents active sand mining where
permitted.
3. The revised report and modeling files should be included in the final delivery.
Please provide the requested information to Ms. Pamela Behm in the Modeling and Assessment Branch and
myself. It is unnecessary to set up a meeting at this time, but please feel free to contact Ms. Behm or myself with
any questions you might have.

Happy Holidays,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
aais.banihani(oncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En v/ronm en tcal
QU[tl/t y

Banihani, Qais
From: Clements, Trevor <[e-mail]>
Sent: Tuesday, January 15, 2019 8:08 AM
To: Banihani, Qais
Cc: Behm, Pamela; Terry Houk ([e-mail])
Subject: [External] RE: Follow up on NCO024228 Model
Hello Qais,
Your response has been communicated with the City. At this time, we are awaiting the City response.
Thank you,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.2058 1 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clementsr&tetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.
From: Banihani, Qais <[e-mail]>
Sent: Tuesday, January 15, 2019 7:41 AM
To: Clements, Trevor <[e-mail]>
Cc: Behm, Pamela <[e-mail]>
Subject: Follow up on N00024228 Model
Dear Mr. Clements,
I just want to follow up on my previous email dated December 17, 2018 regarding including scenario that represents
active sand mining at 8.2 and 10 MGD for the City of High Point's Westside reclamation Facility
(NC0024228). Please feel free to contact Ms. Behm or myself with any questions you might have.
Sincerely,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office

aais. banihaniCEDncdenr.¢ov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En vrr-on m en rn!
Qucilrry
From: Banihani, Qais
Sent: Monday, December 17, 2018 7:23 AM
To: 'Clements, Trevor' <Trevor.ClementsCattetratech.com>
Subject: Cape Fear Model NCO024228
Dear Mr. Clements,
The Division of Water Resources NPDES unit has reviewed your response to our comments regarding the
modeling report entitled "Model Evaluation for Rich Fork Creek: New data and Analysis" submitted to the
Division in support of the permit condition's change request for the City of High Point's Westside reclamation
Facility (NC0024228). The Division still has the following comments:
1. Since the use of monthly limits is consistent with NPDES Permitting practices, the Division is
withdrawing its comment regarding the use of monthly versus weekly limits in Qual2K analysis.
2. Rich Fork Creek is a unique case where permitted sand mining is documented through the SEPA process
for this expansion as having impacts on assimilative capacity when deep pools are formed from the mining
activities. In order to agree to a major permit modification, the Division will need to demonstrate that
concerns identified in the SEPA process have been evaluated. As would be required for any known
permitted source, there needs to be a demonstration that the creek has assimilative capacity in the presence
of sand mining activities. The model should include a scenario that represents active sand mining where
permitted.
3. The revised report and modeling files should be included in the final delivery.
Please provide the requested information to Ms. Pamela Behm in the Modeling and Assessment Branch and
myself. It is unnecessary to set up a meeting at this time, but please feel free to contact Ms. Behm or myself with
any questions you might have.
Happy Holidays,
Qals Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
aais.banihaniCdncdenr.eov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617

Banihani, Qais
From: Banihani, Qais
Sent: Monday, December 17, 2018 7:23 AM
To: 'Clements, Trevor'
Subject: Cape Fear Model NCO024228
Dear Mr. Clements,
The Division of Water Resources NPDES unit has reviewed your response to our comments regarding the
modeling report entitled "Model Evaluation for Rich Fork Creek: New data and Analysis" submitted to the
Division in support of the permit condition's change request for the City of High Point's Westside reclamation
Facility (NC0024228). The Division still has the following comments:
1. Since the use of monthly limits is consistent with NPDES Permitting practices, the Division is
withdrawing its comment regarding the use of monthly versus weekly limits in Qua12K analysis.
2. Rich Fork Creek is a unique case where permitted sand mining is documented through the SEPA process
for this expansion as having impacts on assimilative capacity when deep pools are formed from the mining
activities. In order to agree to a major permit modification, the Division will need to demonstrate that
concerns identified in the SEPA process have been evaluated. As would be required for any known
permitted source, there needs to be a demonstration that the creek has assimilative capacity in the presence
of sand mining activities. The model should include a scenario that represents active sand mining where
permitted.
3. The revised report and modeling files should be included in the final delivery.
Please provide the requested information to Ms. Pamela Behm in the Modeling and Assessment Branch and
myself. It is unnecessary to set up a meeting at this time, but please feel free to contact Ms. Behm or myself with
any questions you might have.
Happy Holidays,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
aais.banihaniCn ncdenr.Rov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
E.-virc�,rmanta/
Quurtt y

}
Banihani, Qais
From:
Behm, Pamela
Sent:
Tuesday, November 20, 2018 11:14 AM
To:
Grzyb, Julie
Cc:
Banihani, Qais; Kebede, Adugna; Hong, Bongghi
Subject:
Rich Fork Creek Qual2k review
Julie, ,
With regards to the City of High Point's remodeling of Rich Fork Creek, the majority of our comments and concerns
appear to have been addressed. We will need to see the revised report to ensure report revision comments have been rc y ��•
incofp,Qrat, ed, Mecially where justification was requested. Based on your suggestion, because the use of monthly limits
is consistent with NPDES Permitting practices, we are withdrawing our comment regarding the use of monthly versus
weekly limits in a Qual2k analysis.
One concern remains unaddressed. Typically, to evaluate a model and resulting scenarios for a new or expanding
discharge, one scenario that we must evaluate is to include all permitted sources at maximum permitted Iimits.during
critical flow periods, This allows us to fully assess the assimilative capacity of a stream. This usually applies to other
W WTPs in a watershed. However, Rich Fork Creek is a unique case where permitted sand mining is noted as having
impacts on assimilative capacity when deep pools are formed from the mining activities. Because this was a major
component of the original expansion request and was incorporated into SEPA and the resulting FONSI, which was
heavily reviewed by the local environmental groups, it is essential to document for the public that this source was
accounted for in a scenario. Before agreeing to a major permit modification, which will remove stream restoration, we
need to be able to demonstrate to the public that all of the original concerns have been fully evaluated.
I don't think a meeting is necessary at this time.
Thanks,
Pam
Pam Behm
Branch Chief
Modeling and Assessment Branch, Planning Section, Division of Water Resources
Department of Environmental Quality
PLEASE NOTE NEW PHONE NUMBER:
919 707 3687 office
[e-mail]
1611 Mail Service Center
Raleigh, NC 27699-1611
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.

Banihani, Qais
From:
Clements, Trevor <[e-mail]>
Sent:
Friday, October 26, 2018 2:05 PM
To:
Banihani, Qais; Behm, Pamela
Cc:
Yonce, Hillary; [e-mail]; Grzyb, Julie
Subject:
[External] RE: City of High Point Rich Fork Creek modeling review (NC0024228)
Attachments:
TT Responses to October 2018 NC DWR Comments.pdf
Qais,
Thank you so much for your thorough review of the report and modeling files for the Rich Fork Creek project for the City
of High Point. I'm pleased to say that most of the items covered in your comments were reporting errors on our part for
which we apologize for not catching earlier. As you know all too well, there are so many items to address in modeling
efforts so it is very helpful to have a fresh set of eyes — again thank you for your thoroughness. For ease of tracking,
we're providing the attached memo that provides a response for each of the items in your original memo. Most were
very straight forward and have already been corrected in the report and modeling files. Hillary Yonce, the lead modeler
on this project, will be sending you a link in a separate email to be able to download the revised report and modeling
files so that you have all of the latest at your disposal.
Pam,
I thank you for your time yesterday as it was helpful regarding the outstanding policy questions. If you are ok with our
basic responses on the modeling report and model files, then I would like to schedule a time when we can discuss follow
up to the two policy issues of concern: (1) Basing the WLA on other than permitted monthly averages, and (2) Using
other than measured physical features to represent the receiving stream with regard to third party mining activities in
Rich Fork Creek. I realize this is more of a question with the Permitting Unit so I've copied Julie here as well. Per our last
meeting, we should be at the point where we need to discuss the permit condition (which has not yet gone into effect)
regarding stream restoration. At that time, Julie was going to seek an opinion from the agency's legal team. It will be
important that we continue that discussion. We look forward to hearing back from you or Julie.
Thank you,
Trevor
Trevor Clements I Mid -Atlantic Regional Manager
Integrated Water Management
Direct: 919.485.20581 Main: 919.485.8278 1 Cell: 919.328.0175
trevor.clements(a),tetratech.com
Tetra Tech I Complex World, Clear Solutions
P.O. Box 14409 11 Park Drive, Suite 200 1 Research Triangle Park, NC 27709 1 www.tetratech.com
PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this
communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify
the sender by replying to this message and then delete it from your system.

From: Banihani, Clais <[e-mail]>
Sent: Wednesday, October 17, 2018 3:40 PM
To: Clements, Trevor <[e-mail]>
Cc: Yonce, Hillary <[e-mail]>; [e-mail]; Behm, Pamela
<pamela.behm @ ncdenr.gov>
Subject: City of High Point Rich Fork Creek modeling review (NC0024228)
Dear Mr. Clements,
The Division of Water Resources NPDES Branch has reviewed the modeling report entitled "Model Evaluation
for Rich Fork Creek: New data and Analysis" submitted to the Division in support of the permit condition's
change request for the City of High Point's Westside reclamation Facility (NC0024228). Attached please find the
review comments on the modeling. You need to address such comments and send you response to Ms. Pamela
Behm in the Modeling and Assessment Branch and myself.
Sincerely,
Qals Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
Environ men ra!
Qua/(f y

NTETRA TECH
Memo
To:
Pamela Behm, Qais Banihani (NC DENR)
Cc:
Terry Houk (High Point)
From:
Trevor Clements, Hillary Yonce (Tetra Tech)
Date:
October 25, 2018
Subject:
Response to Comments from NC DWR
Below are responses to comments received from NC DWR on 10/17/2018 from Qais Banhihani. We appreciate
NC DWR taking the time to review our modeling work. NC DWR comments are as -provided in black text, while
Tetra Tech responses are embedded after in blue text.
(1) Discrepancies between what's reported and what's found in the model files:
a. Section 4.1.4: reports headwater and Kennedy Mill Creek water temperature used during
calibration was 15.3 degrees C; different values were found in the model files. Similar issues with
Hamby Creek water temperature (Section 4.1.4) and headwater and tributary water temperatures
during first corroboration (Section 6.1.3). Numbers found in the report seem to be correct since
they match with YPDRBA data (Appendix C).
We have reviewed all model inputs and updated the model to reflect the YPDRBA
data for water temperature inputs associated with headwaters and tributaries.
While these temperatures do not represent daily averages, they are a reasonable
approximation for boundary condition inputs which match the basis of inputs
associated with water chemistry.
b. Section 7.1.3: winter organic N for headwaters and tributaries was reported to be 0.44 mg/L,
whereas 0.22 mg/L was used. Values found in the report seem to be correctly calculated (TKN -
NH3 = 0.48 - 0.04 = 0.44). Also, the report notes that the winter NO3 concentration used was
0.12 mg/L, but what's found in the model file is 0.44 mg/L.
We have reviewed all model inputs and corrected the model input to reflect the
correct calculation which was present in the report.
c. Appendix F: nitrification rate of 0.08/d was used for all simulations according to the report, but
looking at the model files, 0.1/d seems to have been used for the second corroboration. Running
critical condition scenarios with 0.1/d didn't make much difference, although DO did go below 5
mg/L at the end of the system.
All rates and parameters within the "rates" model tab should have been held
consistent between all model runs and scenarios. We reviewed all inputs and
verified that rates are the same in all simulations. At this time, there is not a DO
violation simulated during the critical condition scenarios for this revised
simulation.
Tetra Tech
One Park Drive, Suite 200 • PO Box 14409
Research Triangle Park, NC 27709
Tel[phone] tetratech.com

Memo: Response to Comments from NC DWR
10/25/18
d. Table 6-3: reports fast CBOD is 10.7 mg/L for headwaters and tributaries, which should be 0.
Slow CBOD numbers in the table are a bit off from what's found in the model files.
Correct, this was a typo in the report which has been corrected. There is no fast
CBOD concentration associated with headwaters and tributaries.
e. Section 5.2.2: slopes for reaches 5 to 9 were reported to be 0.00011 m/m, whereas values found
in the model are 0.001.
Correct, this was a typo in the report which has been corrected. The model slope
input for reaches 5 and 9 In the report should have been 0.001 m/m in the report.
(2) The following need clarification/justification:
a. Section 5.2.2: a clear justification for why the slope was modified to match observed DO data
should be provided.
The text in the report was modified to better explain our approach which is based
on the fact that the reaeration equation is a function of both velocity and slope. We
have high confidence in our velocity measurements but limited data to inform
slopes (no surveying currently, and no stream bed elevations or LIDAR or fine -
resolution DEM data). Therefore, the slope term is the best possible calibration
factor in the absence of a built-in escape coefficient for the reaeration formula in
QUAL2K.
b. Section 7.2.1: WIA scenarios are based on monthly limits. The simulation needs to be based on
weekly limits.
We are unfamiliar with the requirement to use other than the monthly limits for
WI -As. Since the monthly limits are lower and must be complied with, the facility is
designed to operate at levels well below the permit limits to avoid noncompliance.
Therefore, assuming maximum permitted monthly limits is already quite
conservative. The difference between the weekly values is even higher and would
be even more conservative. Would the agency please provide the written policy
that this is based on and confirm whether this is standard practice for all water
quality -based wasteload allocations.
c. Section 6.1.3: It seems that June YPDRBA data was used to set up the headwater and tributary
conditions for the second corroboration instead of using the September data. Please clarify why
the June data is used.
QAQC was conducted on all headwater and tributary model inputs. You are correct
that September data should have been used. This is likely an artifact of the initial
setup period for this model which occurred prior to receiving the September data.
These inputs have been revised and reflect the September YPDRBA data.
d. Section 7.1.3: During scenario runs, slow CBOD in headwater and all tributaries was set to 2
mg/L, whereas it was about 10 mg/L during calibration and two corroborations (running critical
condition scenarios with 10 mg/L didn't make much difference, although minimum DO dropped
slightly below 5 mg/L).
The higher concentrations of BOD used in the calibration and subsequent
corroboration runs reflect the samples taken during the tail of a storm hydrograph
that provided flows instream to evaluate stream depth, width, velocity and DO
profiles at a streamflow level representing the proposed maximum wasteflow, plus
7Q10. To calibrate and corroborate the model at these higher flows, we used the
water quality data associated with the observed conditions. However, when we
apply the model to a 7Q10 condition, we need to reflect a critical drought
condition. As such, we do not expect there to be labile CBOD in the headwater
flow. Under a 7010 condition, we expect the CBOD to be refractory and largely
degraded to background unless there is an upstream discharge interacting with
Tetra Tech

Memo: Response to Comments from NC DWR
10/25/18
the segment (which is not the situation in this case). As such, we have applied the
same assumption that has been used in recent wasteload allocations adopted by
DEQ.
(3) Miscellaneous comments not related to model parameterization:
a. Table 4-2: 1 don't think what is reported is observed stream depth and width as the table caption
says. Stream width must not have been 0.28 feet, for example. Please confirm.
This typo has been corrected in the report.
b. Section 5.1.5 Reaeration: Tsivoglou-Neal equation for the flow range 15-3000 cfs should be
15308xUxS, not 31183xUxS?
This typo has been corrected in the report.
c. Appendix D: Note that there is an "Error! Reference source not found'. Please correct.
This typo has been corrected in the report.
(4) Given that the sand mining permits are active, the model report should include a WWTP expansion
scenario that includes the previously observed pools caused by sand mining activities.
The model physical representation of the stream is based on recent cross -sectional
measurements. Previous channel measurements are over 10 years old and no longer
applicable. By regulatory definition, sand mining activities allowed under a general permit
have a de minimis impact or they are required to have individual NPDES permits. Neither
the City nor Tetra Tech have any control over mining activities permitted by the State. We
have modeled actual conditions in the stream and believe that this is the most
scientifically defensible approach.
In summary, we have revised the report and modeling files to address the discrepancies noted in DWR's review.
Due to size, the revised files will be shared via a separately emailed link. Items that we cannot address should be
further discussed between the City and DWR. Thank you again for your thorough review, and please do not
hesitate to call if you have any questions or would like further explanation.
Tetra Tech

NTETRA TECH
Memo
To:
Pamela Behm, Qais Banihani (NC DENR)
Cc:
Terry Houk (High Point)
From:
Trevor Clements, Hillary Yonce (Tetra Tech)
Date:
October 25, 2018
Subject:
Response to Comments from NC DWR
Below are responses to comments received from NC DWR on 10/17/2018 from Qais Banhihani. We appreciate
NC DWR taking the time to review our modeling work. NC DWR comments are as -provided in black text, while
Tetra Tech responses are embedded after in blue text.
(1) Discrepancies between what's reported and what's found in the model files:
a. Section 4.1.4: reports headwater and Kennedy Mill Creek water temperature used during
calibration was 15.3 degrees C; different values were found in the model files. Similar issues with
Hamby Creek water temperature (Section 4.1.4) and headwater and tributary water temperatures
during first corroboration (Section 6.1.3). Numbers found in the report seem to be correct since
they match with YPDRBA data (Appendix C).
We have reviewed all model inputs and updated the model to reflect the YPDRBA
data for water temperature inputs associated with headwaters and tributaries.
While these temperatures do not represent daily averages, they are a reasonable
approximation for boundary condition inputs which match the basis of inputs
associated with water chemistry.
b. Section 7.1.3: winter organic N for headwaters and tributaries was reported to be 0.44 mg/L,
whereas 0.22 mg/L was used. Values found in the report seem to be correctly calculated (TKN -
NH3 = 0.48 - 0.04 = 0.44). Also, the report notes that the winter NO3 concentration used was
0.12 mg/L, but what's found in the model file is 0,44 mg/L.
We have reviewed all model inputs and corrected the model input to reflect the
correct calculation which was present in the report.
c. Appendix F: nitrification rate of 0.08/d was used for all simulations according to the report, but
looking at the model files, 0.1/d seems to have been used for the second corroboration. Running
critical condition scenarios with 0.1/d didn't make much difference, although DO did go below 5
mg/L at the end of the system.
All rates and parameters within the "rates" model tab should have been held
consistent between all model runs and scenarios. We reviewed all inputs and
verified that rates are the same in all simulations. At this time, there is not a DO
violation simulated during the critical condition scenarios for this revised
simulation.
Tetra Tech
One Park Drive, Suite 200 • PO Box 14409
Research Triangle Park, NC 27709
Tel[phone] tetratech.com

Memo: Response to Comments from NC DWR
fU7pWil.
d. Table 6-3: reports fast CBOD is 10.7 mg/L for headwaters and tributaries, which should be 0.
Slow CBOD numbers in the table are a bit off from what's found in the model files.
Correct, this was a typo in the report which has been corrected. There is no fast
CBOD concentration associated with headwaters and tributaries.
e. Section 5.2.2: slopes for reaches 5 to 9 were reported to be 0.00011 m/m, whereas values found
in the model are 0.001.
Correct, this was a typo in the report which has been corrected. The model slope
input for reaches 5 and 9 in the report should have been 0.001 m/m in the report.
(2) The following need clarification/justification:
a. Section 5.2.2: a clear justification for why the slope was modified to match observed DO data
should be provided.
The text in the report was modified to better explain our approach which is based
on the fact that the reaeration equation is a function of both velocity and slope. We
have high confidence in our velocity measurements but limited data to inform
slopes (no surveying currently, and no stream bed elevations or LiDAR or fine -
resolution DEM data). Therefore, the slope term is the best possible calibration
factor in the absence of a built-in escape coefficient for the reaeration formula in
QUAL2K.
b. Section 7.2.1: WLA scenarios are based on monthly limits. The simulation needs to be based on
weekly limits.
We are unfamiliar with the requirement to use other than the monthly limits for
WLAs. Since the monthly limits are lower and must be complied with, the facility is
designed to operate at levels well below the permit limits to avoid noncompliance.
Therefore, assuming maximum permitted monthly limits is already quite
conservative. The difference between the weekly values is even higher and would
be even more conservative. Would the agency please provide the written policy
that this is based on and confirm whether this is standard practice for all water
quality -based wasteload allocations.
c. Section 6.1.3: It seems that June YPDRBA data was used to set up the headwater and tributary
conditions for the second corroboration instead of using the September data. Please clarify why
the June data is used.
QAQC was conducted on all headwater and tributary model inputs. You are correct
that September data should have been used. This is likely an artifact of the initial
setup period for this model which occurred prior to receiving the September data.
These inputs have been revised and reflect the September YPDRBA data.
d. Section 7.1.3: During scenario runs, slow CBOD in headwater and all tributaries was set to 2
mg/L, whereas it was about 10 mg/L during calibration and two corroborations (running critical
condition scenarios with 10 mg/L didn't make much difference, although minimum DO dropped
slightly below 5 mg/L).
The higher concentrations of BOD used in the calibration and subsequent
corroboration runs reflect the samples taken during the tail of a storm hydrograph
that provided flows instream to evaluate stream depth, width, velocity and DO
profiles at a streamflow level representing the proposed maximum wastellow plus
7Q10. To calibrate and corroborate the model at these higher flows, we used the
water quality data associated with the observed conditions. However, when we
apply the model to a 7Q10 condition, we need to reflect a critical drought
condition. As such, we do not expect there to be labile CBOD in the headwater
flow. Under a 7Q10 condition, we expect the CBOD to be refractory and largely
degraded to background unless there is an upstream discharge interacting with
Tetra Tech

Memo: Response to Comments from NC DWR
10/25/18
the segment (which is not the situation in this case). As such, we have applied the
same assumption that has been used in recent wasteload allocations adopted by
DEQ.
(3) Miscellaneous comments not related to model parameterization:
a. Table 4-2: 1 don't think what is reported is observed stream depth and width as the table caption
says. Stream width must not have been 0.28 feet, for example. Please confirm.
This typo has been corrected in the report.
b. Section 5.1.5 Reaeration: Tsivoglou-Neal equation for the flow range 15-3000 cfs should be
15308xUxS, not 31183xUxS?
This typo has been corrected in the report.
c. Appendix D: Note that there is an "Error! Reference source not found". Please correct.
This typo has been corrected in the report.
(4) Given that the sand mining permits are active, the model report should include a WWTP expansion
scenario that includes the previously observed pools caused by sand mining activities.
The model physical representation of the stream is based on recent cross -sectional
measurements. Previous channel measurements are over 10 years old and no longer
applicable. By regulatory definition, sand mining activities allowed under a general permit
have a de minimis impact or they are required to have individual NPDES permits. Neither
the City nor Tetra Tech have any control over mining activities permitted by the State. We
have modeled actual conditions in the stream and believe that this is the most
scientifically defensible approach.
In summary, we have revised the report and modeling files to address the discrepancies noted in DWR's review.
Due to size, the revised files will be shared via a separately emailed link. Items that we cannot address should be
further discussed between the City and DWR. Thank you again for your thorough review, and please do not
hesitate to call if you have any questions or would like further explanation.
Tetra Tech

Banihani, Qais
From: Behm, Pamela
Sent: Wednesday, October 17, 2018 10:42 AM
To: Banihani, Qais
Subject: RE: City of High Point Rich Fork Creek modeling review
Hi Qais,
You can send to Trevor Clements ([e-mail]) and Hilary Yonce ([e-mail]).
would also copy the permittee and put a copy in the permit folder. I'm not finding the name of the High Point
representative who attended the meeting we had. I think Julie made a copy of the sign -in sheet?
Thanks,
pam
From: Banihani, Qais
Sent: Wednesday, October 17, 2018 7:12 AM
To: Behm, Pamela <[e-mail]>
Subject: RE: City of High Point Rich Fork Creek modeling review
Good morning Pam,
I am wondering if you have the Tetra Tech's contact person info so I can forward your comments to him. I'll copy you on
the email once I send it.
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
En vtron men taI
Qucr!!ty
From: Behm, Pamela
Sent: Wednesday, October 03, 2018 12:12 PM
To: Banihani, Qais <[e-mail]>; Grzyb, Julie <[e-mail]>
Cc: Hong, Bongghi <bon¢[e-mail]>; Kebede, Adugna <[e-mail]>
Subject: City of High Point Rich Fork Creek modeling review
Hi Julie and Qais,

Please see attached for modeling review of the Rich Fork Creek Qual2k model files and report. We typically submit
these reviews to NPDES as an internal memo. You can feel free to forward on to the permittee if you agree with the
recommendations.
Please let us know if you have any questions.
Thanks,
Pam
Pam Behm
Branch Chief
Modeling and Assessment Branch, Planning Section, Division of Water Resources
Department of Environmental Quality
PLEASE NOTE NEW PHONE NUMBER:
919 707 3687 office
oamela.behm (oncdenr.aov
1611 Mail Service Center
Raleigh, NC 27699-1611
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.

NC Division of Water Resources
Planning Section
Modeling and Assessment Branch
Memorandum
September 27, 2018
To: Julie Grzyb and Qais Banihani, NPDES Branch
From: Bongghi Hong and Adugna Kebede, Modeling and Assessment Branch
Subject: Review of Model Evaluation for Rich Fork Creek: New Data and Analysis
The Modeling and Assessment Branch has reviewed the modeling report entitled, "Model
Evaluation for Rich Fork Creek: New Data and Analysis" submitted to the Division of Water
Resources NPDES Branch in support of the permit conditions change request for the City of
High Point's Westside reclamation Facility. The Rich Fork Creek QUAL2K model was developed
and calibrated reasonably well and thorough documentation is provided. We provide the
following review comments:
(1) Discrepancies between what's reported and what's found in the model files:
a. Section 4.1.4: reports headwater and Kennedy Mill Creek water temperature
used during calibration was 15.3 degrees C; different values were found in the
model files. Similar issues with Hamby Creek water temperature (Section 4.1.4)
and headwater and tributary water temperatures during first corroboration
(Section 6.1.3). Numbers found in the report seem to be correct since they
match with YPDRBA data (Appendix Q.
b. Section 7.1.3: winter organic N for headwaters and tributaries was reported to
be 0.44 mg/L, whereas 0.22 mg/L was used. Values found in the report seem to
be correctly calculated (TKN - NH3 = 0.48 - 0.04 = 0.44). Also, the report notes
that the winter NO3 concentration used was 0.12 mg/L, but what's found in the
model file is 0.44 mg/L.
c. Appendix F: nitrification rate of 0.08/d was used for all simulations according to
the report, but looking at the model files, 0.1/d seems to have been used for the
second corroboration. Running critical condition scenarios with 0.1/d didn't
make much difference, although DO did go below 5 mg/L at the end of the
system.
d. Table 6-3: reports fast CBOD is 10.7 mg/L for headwaters and tributaries, which
should be 0. Slow CBOD numbers in the table are a bit off from what's found in
the model files.
e. Section 5.2.2: slopes for reaches 5 to 9 were reported to be 0.00011 m/m,
whereas values found in the model are 0.001.
1

(2) The following need clarification/justification:
a. Section 5.2.2: a clear justification for why the slope was modified to match
observed DO data should be provided.
b. Section 7.2.1: WLA scenarios are based on monthly limits. The simulation needs
to be based on weekly limits.
c. Section 6.1.3: It seems that June YPDRBA data was used to set up the headwater
and tributary conditions for the second corroboration instead of using the
September data. Please clarify why the June data is used.
d. Section 7.1.3: During scenario runs, slow CBOD in headwater and all tributaries
was set to 2 mg/L, whereas it was about 10 mg/L during calibration and two
corroborations (running critical condition scenarios with 10 mg/L didn't make
much difference, although minimum DO dropped slightly below 5 mg/L).
(3) Miscellaneous comments not related to model parameterization:
a. Table 4-2:1 don't think what is reported is observed stream depth and width as
the table caption says. Stream width must not have been 0.28 feet, for example.
Please confirm.
b. Section 5.1.5 Reaeration: Tsivoglou-Neal equation for the flow range 15-3000 cfs
should be 15308xUxS, not 31183xUxS?
c. Appendix D: Note that there is an "Error! Reference source not found" _> "Table
D-1". Please correct.
(4) Given that the sand mining permits are active, the model report should include a WWTP
expansion scenario that includes the previously observed pools caused by sand mining
activities.
Most of these comments appear to have minor impacts on the reported simulation, however
the report and modeling files should be consistent, include justification, and include the
additional scenarios noted above.
2

Banihani, Qais
From:
BILL FRAZIER <[e-mail]>
Sent:
Thursday, September 13, 2018 9:43 AM
To:
Banihani, Qais
Cc:
CARRIE HYLER, DAWN MOLNAR; DERRICK BOONE; SUZAN MARTIN
Subject:
[External] FW: Bench Sheets & Lab Reports
Attachments:
Meritech Report 01022017.pdf, CN 07152015 sample Benchsheet.pdf; CN 01062016
sample Benchsheet.pdP; CN 10262016 sample Benchsheet.pdf, 4Q 2016 UCR.PDF; CN
10182017 sample Benchsheet.pdf; Meritech Report 01182017.pdf; Zn 02022018 Lab
Bench Sheet.pdf; Meritech Report 04201S INF.PDF; Meritech Report 042015 EFF.PDF;
Meritech Report 07262017.pdf
From: CARRIE HYLER
Sent: Thursday, September 13, 2018 9:05 AM
To: BILL FRAZIER <[e-mail]>
Subject: Bench Sheets & Lab Reports
Attached are the bench sheets or Meritech Reports requested by the State (For what was listed in the email). During the
course of this data gathering we discovered errors on the DMRs during the LTMP months, specifically Cyanide (ie: units
shown as pg/L when value entered was in mg/L) or data being entered under "Phenol" instead of Phenol — total
recoverable. Those eDMRs have been revised with the exception of ES 4/2015 and 4/2016, WS 1/2016 and 4/2016.
There is not an option to revise these eDMRs (ES 7/16, WS 1/2016) or there was not an electronic version of the DMR
on the website. Those DMRs have been printed out and changes highlighted. The final summary table is also attached.
I'm sending the table to Pam so she can let ES and WS know there are revised DMRs to validate/certify.
I included the UCR for October 2016 in which ES had detectable CN in INF and EFF, the bench sheet indicates suspected
interference but that information was not entered on the UCR or on the DMR.
If you have questions or need clarification, let me know.
CARRIE HYLER
BS, ECI-II
CITY OF HIGH POINT
PRETREATMENT SUPERVISOR, LABORATORY SERVICES
PO Box 2301 High Point, NC 27261
336.883.3090 1 m: 336.442.5208 fax: [phone]
carrie.hvler@hiahoointnc.¢ov I www•highpointnc.gov
Please be aware that e-mail and attachments sent to and from this address are subject to the North Carolina
Public Records taw and may be disclosed to third parties.

Banihani, Qais
From:
Hill, Tammy
Sent:
Wednesday, August 22, 2018 1:26 PM
To:
Banihani, Qais
Subject:
RE: Ambient station data
Attachments:
RichForkResults 2012to2016.xlsx
Hello Qais! I am well, and hope you are too.
I have attached data from the 4 monitoring stations along Rich Fork Creek from 2012-2016. For more recent data, I'll
have to refer you to the monitoring coordinators for the respective programs:
mown
AMv
Q5780000 — DWR AMS station, Brian Pointer, [e-mail]
zQ574P5000, Q578600, and Q5790000 — Coalition stations, Mark Vander Borgh, [e-mail]
C CC �
Feel free to contact me if there's anything else I can do to help. Have a great afternoon. O
Tammy Hill
DWR — Water Sciences Section
919-743-8412
From: Banihani, Qais
Sent: Tuesday, August 21, 2018 12:14 PM
To: Hill, Tammy <[e-mail]>
Subject: Ambient station data
(�5�ul5un�--Z*CSK1�7S5
(�S 4L SKI--7g7
Hi Tammy, d �n iX wwTO
Hope my email sees you well. rya cow ter✓ s R Z I Z3
Could you please send me the data for the ambient station Q5780000 from 2014 to 2018. cZ P o-f
Pb6ca4.
crK
Thanks, k
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
Environmental
QuaINY

Banihani, Qais
From: TERRY HOUK <[e-mail]>
Sent: Wednesday, August 22, 2018 11:44 AM
To: Banihani, Qais
Subject: RE: [External] RE: Requesting lab sheet
❑N1 FYtprnal pmall_ ❑n not rllrk nnkS nr nnpn arrarnments unlpss vprli@o. ]pn❑ 2
10-4. will send your request to lab manager
Terry
From: Banihani, Qais <[e-mail]>
Sent: Wednesday, August 22, 2018 11:42 AM
To: TERRY HOUK <[e-mail]>
Subject: RE: [External] RE: Requesting lab sheet
Dear Mr. Houk,
I also would like to have the three pollutants scans that were used to summarize Part D (Expanded Effluent Testing Data)
in your 2A renewal application dated October 24, 2013.
Thanks
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources/ Water Quality Permitting
919 707 3607 office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617
En viron m en ral
Qucalir v
From: TERRY HOUK fmailto:[e-mail]
Sent: Tuesday, August 21, 2018 11:52 AM
To: Banihani, Qais <[e-mail]>
Subject: [External] RE: Requesting lab sheet

Thanks I will forward to the lab manager.
Terry
From: Banihani, Qais <[e-mail]>
Sent: Tuesday, August 21, 201811:46 AM
To: TERRY HOUK <[e-mail]>
Subject: Requesting lab sheet
Dear Mr. Houk,
Upon reviewing the High Point's DMRs, I have noticed that some results for metals are off several orders of
magnitude when compared to other sampling data. For the same metal, the results are sometimes reported in
mg/L and sometimes in µg/L. The Division of Water Resources recommends using unified units to avoid
discrepancies. In order to perform an assessment of your influent and effluent data and determine if limitations
are necessary in the permit renewal, NPDES needs to verify your reported results. Please send me the actual lab
report for the following months, days and years:
Copper: 1/2/2017
Cyanide: 7/15/2015, 1/6/2016, 10/26/2016, 10/18/2017
Beryllium: 1/18/2017
Cadmium: 1/6/2016 & 1/18/2017
Lead: 1/18/2017
Thallium: 1/18/2017
Nickel: 1/18/2017
Zinc: 2/12/2018
Antimony: 1/18/2017
Total Phenolic recoverable: 4/15/2015
Phenols: 1/18/2017 and 7/26/2017
Please submit all the requested information to me by September 21, 2018.
Sincerely,
Qais Banihani
Environmental Engineer
NPDES Complex Permitting
NC DEQ/ Division of Water Resources / Water Quality Permitting
919 707 3607 office
gais.banihani@ncdenr.2ov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address:1617 Mail Service Center, Raleigh, NC, 27699-1617

N
TETRA TECH
July 18, 2018
Trevor Clements, Tetra Tech
Hillary Yonce, Tetra Tech

Meeting Purpose
Aa-
Rich Fork Creek 2

OTETRA TECH
• 2006 - 2011 City of High Point
sponsored monitoring and modeling
studies in Rich Fork Creek to
support NPDES permitting
• 2012 DWR issued permit with
authorization to construct 10 MGD
facility with interim 8.2 MGD flow
• Studies required before 10 MGD
flow can be authorized
• Highly informative monitoring and
modeling studies completed in
2017 to discuss today

OTETRA TECH
1. What is the applicability of the existing QUAL2E Model for
expanded discharge evaluation?
2. What do stream channel profiles look like under higher flow?
3. What are stream velocities under the higher flow conditions?
4. Are current stream SOD rates similar to those measured in 2006?
5. What is the reaeration rate at higher flows?
6. What are existing BOD kinetics under higher flow conditions?
[More details in Monitoring Plan document attachment to Report]

Highway 109 sand mining
OTETRA TECH
• Field Recon Trip: April 4, 2017
• Field Results Obtained:
Observation that sand mining
near Ball Road and Kanoy Road
have ceased, channel returning to
more natural -like conditions
Observation that sand mining
near Highway 109 continues
r Corroboration of flow relationship
between Abbotts Creek (gaged)
and point measurements along
Rich Fork Creek

OTETRA TECH
• Channel geometry and velocity observations under higher flow conditions
• Cross-section measurements
Time of travel (TOT) studies
• Dissolved oxygen (DO) profile sampling
• Supplemental water quality sampling
NOx, TKN, NH3, TDS, TOC, BOD5, BOD20, CBOD5, CBOD20
• Sediment oxygen demand (SOD) studies

OTETRA TECH
• May 10 - 12 (Q -18 cfs)
• Channel geometry
Longitudinal water temperature and DO sampling
a WQ grab sampling
SOD sampling/monitoring
• May 17, June 1 - 2 (Q -16 cfs)
• Channel geometry
• TOT dye studies
• Longitudinal water temperature and DO sampling
• WQ grab sampling
• September 19 (Q -5 cfs)
Channel geometry
Longitudinal water temperature and DO sampling

OTETRA TECH
• Generally over -estimates of depth and width
• Velocity under -estimated upstream, and over -estimated
downstream
• D0:
• Observed DO: AM
• Observed 00: PM — — Wi]5
—OUAL2E May 10-12 2017 Corroboration
Midway
Mow Evans
Old 29 Mamby Creek
J
[A
E
O
O
ameewae w "a
Kennedy Mlll Bond Creek
Creek
Old Old
Ball Pool Kanoy Pool
HIM
109
Pool
o° o° o° o° o° o° f
Distance (nni)

OTETRA TECH
• Improved stream physical representation
• Incorporation of new channel geometry data (depth, width)
Incorporation of new TOT and velocity data
• Improved model performance downstream of Kanoy Road
Previously limited data existed prior
• Improved thermal simulation
• Improved water quality and oxygen dynamics simulations
• Ease of use and updated user-friendly interface

NTETRA TECH
• Model Calibration Data (May 10 - 12) [Q -18 cfs]
• Channel geometry
• Longitudinal water temperature and DO sampling
WQ grab sampling
SOD sampling/monitoring
• First Corroboration Model Data (May 17, June 1 - 2) [Q ~16 cfs]
Channel geometry
. TOT dye studies
Longitudinal water temperature and DO sampling
WQ grab sampling
• Second Corroboration Model Data (September 19) [Q -5 cfs]
Channel geometry
Longitudinal water temperature and DO sampling

OTETRA TECH
—Calibration (May 12, 2017) ■ Time of Travel Studies 2017
1.00
Westside WRF
0.90
Kennedy Ball Kanoy Hunts Evans
Mill Creek Road Old 29
Road
0.80
HWY 109
Hamby Creel;
Pool Midway
0.70
Road
0.60 y
0.50
O
0.40 >O
0.30
0.20
0.10
0.00
Distance from outlet (mi)

Westside WFF _Calibration (May 12, 2017)
Kennedy
Mill Creek Midway Ball Kanoy Hunts
OTETRA TECH
■ Calibration Data — — Calibration: Min/Max Temp
Evans
Harnbv Creek 25.00
HWY 109ROad Road -- Road
Creek Road Old 29
pool
-- 1 1
1
___________- ,
_
�'L ^^ ^O O 4 1 ro O b 'S Y N O
Distance from outlet (mi)
20.00
U
d
15.00 2
d
a
10.00 F
d
m
5.00
0.00

OTETRA TECH
■ NOx Data (May 10-12, 2017)
—Cal: NH4
—Cal: NOX
B
7
6
5
c
E
c
0
4
m
c
v
3
U
c
U
2
1
0
^ry ^^
,moo �
m
e
0
Distance from outlet (mi)
Westslde WRF
Kennedy
Evans
Mill Creek
HI 10
Road
Road Creek
Road Old 29
Hamby Creek
Road
■

OTETRA TECH
- -Was (5 mgll) —Calibration
(May 12, 2017) •
Calibration Data: AM
O Calibration Data:
PM
Wes side WRF
Kennedy Midway
Mill Creek Road
gall
Road Kenoy Hunts
Road Creek
Evans
Road
Hamby Creek
Old 29
9.0
9.0
7.0
6.0
a
O
HWY 109
SA
Pool
4.0
3.0
2.0
1.0
0.0
11% 'I^ ^O
O 0 A O
h t•
9 ti ^
O
Distance (mi)

OTETRA TECH
—Corrboration
1 (June 2, 2017)
—Corrboration 2 (Sept 19, 2017)
•
Corroboration1 Data
■ Corroboration2 Data
Westside WRF
1.50
Kennedy
Ball Kanoy Hunts
Evans
Mill Creek
Rnafd
Road Old 29
1.30
HWY 109
I
Hamby Creek
Pool Midway
+I
1.10
oa
0.90
�
�
N
C
0.70
V
O
0.50
d
0.30
0.10
Distance from outlet (mi)

OTETRA TECH
—Corrboration 1 (June 2, 2017)
-- -Corroboration 1 Min/Max
-- Corrboration 2 (Sept 19, 2017)
- - - Corroboration 2 Min/Max
• Corroborationl Data
■ Corroboration2 Data
Westslde WRF
Kennedy Midway Ball
Mill Creek Road Kanoy Hunts
HambyCreek
Evans Old 29
Road Road Creek
Road
1
30.0
25.0
20.0
_
L
'HWY
log15.0
0
Pool
�
n
F
10.0
m
5.0
0.0
�L �^ NCJ 9 0 1 to
0 D '3 ti o
Distance from outlet (mi)

OTETRA TECH
■ NOx Data (Cor 1)
- - - Cor 1:
NH4
- - - Cor 2: NH4 —Cor
1: NOx —Cor 2:
NOx
14
Creek
12
10
m
E
g
c
o
m
c
a
6
�
C
O
U
4
2
0
11 Ilk ^O of
0
It
ro h
Distance
from outlet (mi)
Weststde WRF
Kennedy
Mill Creek
gall Kanoy Hunts Evans
Road Road Old 29
j, HWY lOMidway
1 Pool
Road
�
I 1
I 1
Hamby Creek
■
■
---------------------
--- ---
---------------- ---

OTETRA TECH
— —Was (5 mg/l)
—Corrboration
1 (June 2, 2017)
—Corrboration 2 (Sept 19, 2017)
• Corroborationl Data: AM
O
Corrborationl Data: PM
■ Corroboration2 Data: AM
❑ Corrboration2 Data: PM
Westslde WRF
Kennedy Midway gall
Mill Creek Road
Road
Kandy
Road
Hunt; Evans
Creek Road
Hamby Creek
Old 29
9.0
8.0
IV
7.0
6.0
a
E
5.0
�
p
HWY 109
Pool
4.0
3.0
2.0
1.0
0.0
a
o
A ro 5 b
n ry s o
Distance (mi)

OTETRA TECH
Existing Permit Limits, Monthly Averages (Permit# NC0024228, 2013)
Flow
BOD5 (April 1— October 31)
BOD5 (November 1 — March 31)
NH3 (April 1— October 31)
NH3 (November 1— March 31)
8.2 MGD
10 MGD
4.9 mg/I
5.0 mg/I
9.8 mg/I
10.0 mg/I
1.0 mg/I
1.0 mg/I
2.0 mg/I
1.8 mg/I
Dissolved Oxygen (daily average) >_ 7.0 mg/I >_ 7.0 mg/I
Total Suspended Solids
30.0 mg/I
30.0 mg/I

OTETRA TECH
Summer Critical Conditions, no effluent present
Winter Critical Conditions, no effluent present
Summer Critical Conditions, WRF at 8.2 MGD (permitted effluent concentrations)
Summer Critical Conditions, WRF at 10 MGD (permitted effluent concentrations)
Winter Critical Conditions, WRF at 8.2 MGD (permitted effluent concentrations)
Winter Critical Conditions, WRF at 10 MGD (permitted effluent concentrations)
Summer Critical Conditions, WRF at 8.2 MGD (median effluent nutrient concentrations)
Summer Critical Conditions, WRF at 10 MGD (median effluent nutrient concentrations)

NTETRA TECH
• No discharge critical conditions do not meet WQS (5 mg/I)
• WQS predicted to be met with 8.2 and 10 MGD discharges
Summer Critical Conditions (no effluent)
Winter Critical Conditions (no effluent)
no
Ere
Summer Critical, WRF at 8.2 MGD (permitted concentrations)
5.5
Summer Critical, WRF at 10 MGD (permitted concentrations)
5.0
Winter Critical, WRF at 8.2 MGD (permitted concentrations)
5.8
Winter Critical, WRF at 10 MGD (permitted concentrations)
5.9
Summer Critical, WRF at 8.2 MGD (median concentrations)
5.8
Summer Critical, WRF at 10 MGD (median concentrations)
5.6

OTETRA TECH
• Under no discharge critical conditions,
instream conditions do not meet WQS
• All WRF scenarios meet the WQS
instream improving DO concentrations
• Under typical effluent concentrations
during summer critical conditions, both
effluent options meet the WQS with MOS
• There is assimilative capacity instream to
support addition WRF discharge, and in
general additional effluent improves
instream WQ under critical conditions.

OTETRA TECH
• Questions?
• Next Steps in Permitting Process?

Banihani, Qais
Subject: Canceled: High Point (Westside) -TetraTech
Location: DENR Archdale-Conf Rm-917- 20 seats
Start: Thu 6/21/2018 9:30 AM
End: Thu 6/21/2018 12:30 PM Tw.l i
Show Time As: Free
Recurrence: (none)
Meeting Status: Not yet responded
Organizer: Grzyb, Julie
Required Attendees: Banihani, Qais; Behm, Pamela; Poupart, Jeff; Hennessy, John
Optional Attendees: Hong, Bongghi
Importance: High
Due to some changes in schedules this meeting is being cancelled. Please try to hold the following times free until I
hear back from Trevor on when High Point can meet.
July 13 from 10:30 -12:30
July 17`h from 1-3 PM
July 181h 10-12 or 1-3PM
Thanks,
Julie
TetraTech collected instream data and wants to report on modelled results in Abbotts Creek by the Westside
WWTP. Please hold this time, it will not take this long, I will revise time length after I hear back from TetraTech.
An EIS and a model were performed for the flow expansion put in the last permit contingent upon High Point reassessing
the model after stream restoration and expansion to 8.2 MGD.
The plant expansion to 8.2 MGD is complete but no stream restoration occurred; however, according to Trevor at
TetraTech the model showed positive results.
It is still High Point's desire to proceed to the 10 MGD expansion, so it will be important to review their results and
decide if they have successfully shown the stream has the assimilative capacity to handle up to 10 MGD without the
steam restoration.
Pam —Your Branch assisted in reviewing the original model, hoping you and other staff, as needed, can attend.
Jeff and John — you may want to attend, this could prove to be controversial and enforcement may be necessary. High
Point did not proceed with the stream restoration as required in their permit (wording from EIS) because the Sand
Mining operation downstream was not terminated (DWR had committed to not issuing the GP -long story). HP will want
to be given permission to operate at 10 MGD. Davidson Co. —the County the POTW is in (yes, the POTW is not in its
own service area!)- did not want to allow the expansion. Allowing the expansion without the required restoration will be
controversial and Davidson County may argue it's in non-compliance with the approved EIS and permit regardless of
what the model shows.
Qais — please review the file on NCO024228 before the end of June and let's discuss.

This meeting will be about hearing the rerun model results but all the other questions will inevitably follow— not that
we will have to answer them at this meeting but the Division may be forced to decide if the restoration is still required
even if the model shows enough assimilative capacity.
Thanks,
Julie

Model Evaluation for Rich Fork Creek:
New Data and Analyses
May 18, 2018
PREPARED FOR
City of High Point Public Services
211 S Hamilton Street, Suite 206
High Point, NC 27261
we Me
Sueta IIIIIu2'j11nv1 \l InC \I 07
PREPARED BY
Tetra Tech
One Park Drive, Suite 200
PO Box 14409
Research Triangle Park, NC 27709
Tel [phone]
Fax [phone]
tetratech.com
N
TETRA TECH

(This page was intentionally left:blank.)

Model Evaluation for Rich Fork Creek
EXECUTIVE SUMMARY
May 18, 2018
An NPDES permit was issued to the City of High Point by the North Carolina Division of Water Resources
authorizing the City to construct expanded facilities for treating up to 10 MGD at its Westside Reclamation
Facility (WRF) but with interim flow limited to 8.2 MGD. Permitting of discharge of up to 10 MGD was
made contingent in the permit on two conditions: (1) stream restoration be performed where sand mining
activities by third party entities had impacted channel hydraulics, and (2) additional monitoring and
modeling studies be performed demonstrating assimilative capacity exists for the additional wasteflow.
Intensive monitoring studies were completed in Rich Fork Creek by Tetra Tech on behalf of the City
during the summer of 2017. Flow conditions in Rich Fork Creek were tracked closely so that time -of -travel
dye studies could be conducted to accurately reflect stream channel conditions representing
approximately a 10 MGD discharge at 7Q10 conditions. Additionally, sediment oxygen demand and water
quality sampling was performed to support evaluation of the existing QUAL2E model performance and
subsequent recalibration efforts.
The new monitoring and modeling studies show that although the existing QUAL2E model performs
reasonably well in predicting dissolved oxygen in Rich Fork Creek, channel shape has changed over the
10-year period from the original model setup. Additionally, more data is now available for the lower
portion of Rich Fork Creek that indicates that previous modeling assumptions could be improved to better
simulate the receiving stream. The decision was made to convert the QUAL2E model to the more modern
QUAL2K version which is more robust and easier and more efficient to apply.
The previously observed pools caused by sand mining activities at Kanoy Road and Ball Road crossings
have largely refilled with sediment, so the model hydraulics for those segments were modified accordingly
during the QUAL2K setup for model recalibration. The sand mining pool at Hwy 109 was still present,
although it was observed to be half the length as it had been in previous years and the model
configuration was modified accordingly. Calibration results for the updated QUAL2K model (Figure ES-1)
demonstrate improved performance over the previous QUAL2E model, and corroboration analyses
(Figure ES-2) indicate strong performance for the QUAL2K model under varying stream conditions.

Model Evaluation for Rich Fork Creek
May 18, 2018
— —WOS (5 milli) —Calibration
(May 12, 2017( •
Calibration Data: AM
O Calibration Data: PM
Wes Ida WRr
Kennedy Midway
Mill Creek Road
Bell
Road Kandy Hunts
Road Creek
Ekans
Road
Hamby Creek
Old 29
8.0
8.0
7.0
6.0
IS
Z
0
HWY 109
ftol
5.0
4.0
3.0
2.0
1.0
0.0
O O a1 0
6 1,
A ry q o
Distance (ml)
Figure ES-1: Updated QUAL2K model calibration results for dissolved oxygen.
— — WQS (6 mgn)
—Corrboration
1 (June 2, 2017)
—Corrboration 2 (Sept 16, 2017)
• Corraborationt Data: AM
O
Corrborationt Data: PM
■ Corroboration2 Data: AM
❑ Corrboration2 Data: PM
WesUlde WRr
Kennedy Midway Ball
Mill Creek Road d Randy
Red
Ev4nS
Hunt P
Creek
Old 29 Hamby Creek
8.0
6.0
7.0
6.0
a
0
c
HWY log
R al—
5.0
4.0
3.0
2.0
1.0
0.0
A O 6
t. -b ry w o
Distance (MI)
Figure ES-2: QUAL2K model corroboration results for dissolved oxygen.

Model Evaluation for Rich Fork Creek
May 18, 2018
Following demonstration of strong model performance, the updated QUAL2K model was applied to
evaluate various discharge scenarios representing no discharge, the existing permitted 8.22 MGD WRF
discharge, and an expanded discharge of 10 MGD. Model results indicate an expectation for water quality
standards to be met under summer and winter low flow conditions for both the 8.2 and 10 MGD
discharges. Although the model indicates some additional decrease in DO could occur during summer
conditions from expansion of the flow from 8.2 to 10 MGD (Figure ES-3), model predictions also show
that DO under expected performance levels (i.e., below maximum permitted levels) is expected to be
substantially higher than current conditions and above the water quality standard (Figure ES-4).
- -was
Scenario 3: Summer WLA 8.2 MGD
Westslde WRi Midway gall KanOy Hunts
i
—Scenario 1: Summer 7010 (no effluent)
--- Scenario 4: Summer WLA 10 MGD
Evans Old 29 Xamby Creek
Kennedy
dl Creek
1
10.
9.0
-
8.0
7.0
6.0
-------------------------------
-"'
5.0
4.0
3.0
2.0
1.0
Pool
nn
O O 1 6 6 b a,
Distance from outlet (ml)
Figure ES-3: QUAL2K predicted DO for No discharge, 8.2 MGD and 10 MGD at maximum permit limits.

Model Evaluation for Rich Fork Creek
May 18, 2018
— —wQS
—Scenario
1: Summer 7Q10 (no efnuenp
— Scenario 7: Summer WLA 82 Median - -
- Scenario 8: Summer WLA 10 Median
Midway
WRF Road
Sall Kandy Runts Evans
Road Road Creek Road
Old 29 Hamby Creek
jWesbide
Kennedy
1 1
Mill Creek
+
10.0
8.0
8.0
7.0
0
5.0
O
4.0
3.0
2.0
R 10
Pool
1.0
0.0
o 1 to o
► ry ry o
Distance from outlet (ml)
Figure ES-4. QUAL2K predicted DO for 8.2 and 10 MGD at median observed conditions.
The combination of additional intensive monitoring data and updated QUAL2K modeling provide a
compelling basis for removing the modified NPDES permit requirement for stream restoration of the sand -
mined areas, and for approving the wasteload allocation for an increased effluent flow limit of 10 MGD.
iv

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Page 1
Contact: Dawn Molnar
Report Date:
8/10/2017
Client: High Point, City of
PO Box 230
Proejct:
3Q LTMP
High Point NC 27261
Date Sample Rcvd:
7/27/2017
Meritech Work Order #
07271726 Sample: ES Effluent Composite
7/26-27/17
Parameters
Rgsull
Analysis Date
Reporting Limi
Method
Total Dissolved Solids
568 mg/L
8/1/17
10.0 mg/L
SM 2540C
Antimony, total
<0.025 mg/L
8/4/17
0.025 mg/L
EPA 200.7
Beryllium, total
<0.005 mg/L
8/4/17
0.005 mg/L
EPA 200.7
Thallium, total
<0.020 mg/L
8/4/17
0.020 mg/L
EPA 200.8
Meritech Work Order #
07271727 Sample: ES Effluent Grab
7/26/17
Parameters
Resul
Analysis Date
Reporting Limi
Metbo
Phenols, total
0.012 mg/L
8/2/17
0.010 mg/L
EPA 420.1
EPA 624+TB
Attached
8/1/17
-
624
EPA 625
Attached
8/3/17
625
Meritech Work Order #
0727172E Sample: ES Aeration Basin Grab
7/26/17
Parameters
Result
Analysis Date
Reporting Limit
Method
Mercury, total
0.0008 mg/L
8/1/17
0.0002 mg/L
EPA 245.1
Meritech Work Order #
07271729 Sample: ES Primary Clarifier Effluent Composite
7/26-27/17
Parameters
Re ul
Analysis Date
Reporting Lim
Method
Mercury, total
<0.0002 mg/L
8/1/17
0.0002 mg/L
EPA 245.1
642 Tarnco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Page 2
Contact: Dawn Molnar
Report Date:
8/10/2017
Client: High Point, City of
PO Box 230
Proejct:
3Q LTMP
High Point, NC 27261
Date Sample Rcvd:
7/27/2017
Meritech Work Order # 07271730 Sample: WS Effluent Grab
7/26/17
Parameters
Result Ana sis Date
Reporting Limlt
Method
Phenols, total
0.451 mg/L 8/2/17
0.010 mg/L
EPA 420.1
EPA 624 + TB
Attached 8/1/17
-
624
EPA 625
Attached 8/3/17
625
Meritech Work Order #
07271731 Sample: WS Aeration Basin Grab
7/26/17
Parameters
Result
Analysis Date
Reo_^rtingLirnitMethod
Mercury, total
0.0004 mg/L
8/1/17
0.0002 mg/L
EPA 245.1
Meritech Work Order #
07271732 Sample: WS Effluent Composite
7/26-27/17
Parameters
Result
Analysis Date
Reporting Limit
Method
Total Dissolved Solids
360 mg/L
8/1/17
10.0 mg/L
SM 2540C
Antimony, total
<0.025 mg/L
8/4/17
0.025 mg/L
EPA 200.7
Beryllium, total
<0.005 mg/L
8/4/17
0.005 mg/L
EPA 2003
Thallium, total
<0.020 mg/L
8/4/17
0.020 mg/L
EPA 200.8
Meritech Work Order # 07271733 Sample: WS Primary Clarifier Composite 7/26-27/17
Parameters Result Analysis Date Reporting Unit Method
Mercury, total <0.0002 mg/L 8/1/17 0.0002 mg/L EPA 245.1
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Dawn Molnar
Client High Point, City of
PO Box 230
High Point, NC 27261
Report Date:
Proejct:
Date Sample Rcvd:
Page 3
8/10/2017
3Q LTMP
7/27/2017
Meritech Work Order # 07271734 Sample: ES Sludge Cake Grab
7/26/17
Parameters
Result
An&gkDat
Reporting Limi
method
%Solids
21.3 %
7/28/17
0.2 %
SM 2540B
Arsenic, total
<2.35 mg/kg
8/4/17
2.35 mg/kg
EPA 200.7
Beryllium, total
<1.17 mg/kg
8/4/17
1.17 mg/kg
EPA 200.7
Cadmium, total
<D.469 mg/kg
8/4/17
0.469 mg/kg
EPA 200.7
Chromium, total
62.9 mg/kg
8/4/17
0.250 mg/kg
EPA 200.7
Copper, total
375 mg/kg
8/4/17
1.00 mg/kg
EPA 200.7
Lead, total
17.1 mg/kg
8/4/17
0.500 mg/kg
EPA 200.7
Mercury, total
0.235 mg/kg
8/1/17
0.02 mg/kg
EPA 245.1
Nickel, total
14.1 mg/kg
8/4/17
2.0 mg/kg
EPA 200.7
Phosphorus, total
28,310 mg/kg
8/4/17
2.00 mg/kg
EPA 200.7
Silver, total
5.68 mg/kg
8/4/17
0.965 mg/kg
EPA 200.7
Zinc, total
822 mg/kg
8/4/17
0.500 mg/kg
EPA 200.7
Cyanide, total
<2.35 mg/kg
8/2/17
2.35 mg/kg
EPA 335.4
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

MERI TECH, INC.
Environmental Laboratories
' Laboratory Certification #165
Client: City of High Point Meritech LD#: 07271727
Project: 3Q LTMP Analysis: 08/01/17
Client SamplelD. ES Effluent Analyst: VWV
Sample Collection: 07/26/17 Dilution Factor: 1
Report Date: 08/02/17
EPA 624 VOLATILE ORGANICS
Parameter
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
Methyl Bromide
< 5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L.
Chlorobenzene
< 1.00 ug/L
Chloroethane
<5.00 ug/L
2-Chloroethyl vinyl ether
<5.00 ug/L
Chloroform
1.55 ug/L
Methyl Chloride
< 5.00 ug/L
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
l,l-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
I,1-Dichloroethylene
<1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
Tetrachloroethylene
< 1.00 ug/L
Toluene
< 1.00 ug/L
1,1,1-Trichloroethane
< 1.00 ug/L
1,1,2-Trichloroethane
< 1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
< 5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Comnounds
Acrolein
<50.0 ug/L
AcryloniWle
<10.0 ug/L
I hereby certify that I have reviewed and approve these data
[�. ��
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

Client:
Project:
Client Sample ID:
Sample Collection:
Parameter
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranlhene
Benzo(k)fluoranthene
Benzo(gh,i)perylene
Benzyl butyl phthalate
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
B is(2chloroisopropyl )ether
Bis(2-ethylhexyl)phthaste
4-Bromophenyl phenyl ether
2-Chloronaphtltalene
4-Chloropllenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,Y-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
1,2-Diphenyl hydrazi ne
6 ii1 ERI 6 C , INC.
Environmental Laboratories
Laboratory Certificate #165
City of High Point Meritech ID#: 07271727
30 LTMP Analysis: 08/03/17
ES Effluent Extraction: 07/31/17
07/26/ 17
Analyst: PM
Dilution Factor: 1
EPA 625 SEMIVOLATILE ORGANICS
Result Parameter
<10 ug/L
Fluoranthene
<10 ug/L
Fluorene
<10 ug/L
Hexachlombenzene
<50 ug/L
Hexachlorobutadiene
<10 ug/L
Hexachlorocyclopentadiene
<10 ug/L
Hexachloroethane
<10 ug/L
indeno(1,2,3-cd)pyrene
<10 ug/L
Isophorone
<10 ugfl
2-Methylnaphthatene
<10 ug/L
Naphthalene
<10 ug/L
Nitrobenzene
<10 ug/L
N-Ninmodimethylamine
<10 ug/L
N-Nitrosodi-n-propylamine
<10 ug/L
N-Nilrosodiphenylamine
<10 ug/L
Phenanthrene
<10 ug/L
Pyrene
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
<10 ug/L
4-Clrloro-3-methylphenol
<10 ug/L
2-Chlorophenol
<10 ug/L
2,4-Dichlorophenol
<10 ug/L
2,4-Dimethylphenol
<50 ug/L
2,4-Dinitrophenol
<10 ug/l,
4,6-Dinitro-2-methylphenol
<10 ug/L
2-Nitrophenol
<10 ug/L
4-Nitrophenol
<10 ug(L
Pentachlorophenol
<10 ug/L
Phenol
<10 ug/L
2,4,6-Trichlorophenol
<10 ug(L
1 hereby certify that I have reviewed and approve these data.
Result
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug/L
<50 ug/L
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<50 ug/L
<50 ug/L
<10 ug/L
<50 ug/L
<50 ug/L
<10 ug/L
<10 ug/L
l♦ s� 14
Laboratory Representative
642 Tatnco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MERITECH, INC.
Environmental
Laboratories
y�
Laboratory Certification #165
Client:
City of High Point
Meritech ID#:
07271730
Project:
3Q LTMP
Analysis:
09/01/17
Client SampleED:
WSEftluent
Analyst:
VWV
Sample Collection:
07/26/17
Dilution Factor:
10
Report Date:
08/02/17
EPA 624 VOLATILE ORGANICS
Parameter
Result
Benzene
< 10.0 ug/L
Dichlorobromomethane
< 10.0 ug/L
Bromofonn
< 10.0 ug/L
Methyl Bromide
<50.0 ug/L
Carbon Tetrachloride
< 10.0 ug/L
Chlorobenzene
< 10.0 ug/L
Chloroethane
<50.0 ug/L
2-Chloroethyl vinyl ether
<50.0 ug/L
Chloroform
< 10.0 ug/L
Methyl Chloride
<50.0 ug/L
Chlorodibromomethane
< 10.0 ug/L
1,2-Dibromoethane
< 10.0 ug/L
I,I-Dichloroethane
< 10.0 ug/L
1,2-Dichloroethane
< 10.0 ug/L
1,4-Dichlorobenzene
< 10.0 ug/L
1,2-Dichlorobenzene
< 10.0 ug/L
1,3-Dichlorobenzene
< 10.0 ug/L
I,]-Dichloroethylene
< 10.0 ug/L
trans-1,2-Dichloroethylene
< 10.0 ug/L
1,2-Dichloropropane
<10.0 ug/L
cis-1,3-Dichloropropylene
< 10.0 ug/L
trans-0-Dichloropropylene
< 10.0 ug/L
Ethyl benzene
< 10.0 ug/L
Methylene chloride
< 10.0 ug/L
1,1,2,2-Tetrachloroethane
< 10.0 ug/L
Tetrachloroethylene
< 10.0 ug/L
Toluene
< 10.0 ug/L
1,1,1-Trichloroethane
<10.0 ug/L
1,1,2-Trichloroethane
< 10.0 ug/L
Trichloroethylene
< 10.0 ug/L
Trichlorofluoromethane
<50.0 ug/L
Vinyl chloride
< 50.0 ug/L
Additional Compounds
Acrolein
<500 ug/L
Acrylonitrile
< 100 ug/L
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

Client:
Project:
Client Sample ID:
Sample Collection:
Parameter
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Benzyi butyl phthalate
Bis(2-chloroelhoxy)tnethane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyhphthalate
4-Bromophenyl phenyl ether
2-Chloronaphthalene
4-Chlorophenylphenyl ether
Chrysene
Dibenzo(a,h)anthmcene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,T-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
1,2-Diphenylltydra7ine
MERITECH, INC.
Environmental Laboratories
Laboratory Certificate #166
City of High Point Meritech ID#: 07271730
3Q LTMP Analysis: O8/03/17
WS Effluent Extraction: 07/31/17
07/26/ 17
Analyst: PM
Dilution Factor: I
EPA 625 SEMIVOLATILE ORGANICS
Result Parameter
<10 ug/L
Fluoranthene
<10 ug/L
Fluorene
<10 ug/L
Hexachlorobenzene
<50 ug/L
Hexachlorobutadiene
<10 ug/L
Hexachiorocyclopentadiene
<10 ug/L
Hexachloroethane
<10 ug/L
Indeno(1,2,3-cd)pyrene
<10 ug/L
Isophorone
<10 ug/L
2-Mohylnaphthalene
<10 ug/L
Naphthalene
<10 ug/L
Nitrobenzene
<10 ug/L
N-Nitrosadimethylemine
<10 ug/L
N-Nitrosodi-n-propylamine
<10 ug/L
N-Nitrosodiphenylamine
<10 ug/L
Phenanthrene
<10 ug/L
Pyrene
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
<10 ug/L
4-Chloro-3-methyiphenol
<10 ug/L
2-Chlorophenol
<10 ug/L
2,4-Dichlorophenol
<to ug/L
2,4-Dimethylphenol
<50 ug(L
2,4-Dinitropitenol
<10 ug/L
4,6-Dinilro-2-methylphenol
<10 ug/L
2-Nitrophenol
<10 ug/L
4-Nitrophenol
<10 ug/L
Pentachlorophenol
<10 ug/L
Phenol
<10 ug/L
2,4,6-Tricltlorophenol
<10 ug/L
1 hereby certify that I have reviewed and approve these data.
Result
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<50 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug(L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<10 ug/L
<50 ug/L
<50 ug/L
<10 ug/L
<50 ug/L
<50 ug/L
<10 ug/L
<10 ug/L
Id -
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

s, d. Chain of Custody Record (COQ
NPDES#:
Client: �l"( t }ii �, r>Oi�� Phone:
Address: P? Box Fax:
i-II['a�� \ P�t�',-h. NC: �)`IEmail: �! V�
Project: -' mvlp
P.O.#:
Attention.-L/t.oyl PACAI,l r wtmAroune7iora
HOWwould oull 7 "RUSH work needs prior approval.
y your report sent.
Circle all that apply: Email(ptefe'dl, Fax, Mail Std 0 a ) z
MERITECH INC.
{ /
,i.` ..
ENVIRONMENTAL LABORATORIES
642 Tamco Rd. Phone: [phone]
Reidsville NC 27320 Fax: [phone]
Email: [e-mail]
www.meritechlabs.com
Sample Location and/or ID #
Sampling Dates & Times'.
Person Taking Sample Sign/Pr
�� �� rzti'it4.l )2 Cc
Lab Use only
Start
End
Comp?
Grab?
# of
Cont
Test(s) Required
On Ice?
/No
pH OK?
CI OK?
Date
Time
Date
Time
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Temperature Upon Receipt:
v `L
Method of
"` Dechlorfnadon (<0.5 ppm) of Ammonia, Cyanide, Phenol and TKN samples must be done in the field prior to preservation. "•"
Shipment:
Comments:
Compositor #
UPS
Fed Ex
Ar these results for regulatory purposes?
Yes 13 No
rJJuug#
Report results in: mg/L mg/kg ❑ ug/L
Hand Delive
elfin d b
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(. 6
Time:
Z-
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Time:
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Received bC ate:
Time:
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Relinquishli
Date:
Time:
Received by La
Time:

I�Nzl Chain of Custody Record (COC)
NPDES#:
Address: lYl 1 CPhone:
>t Fax:
HlgI�, NC- 9 l :)+c1 Email:
Project: -�,C L'i kP
P.O.#:
Attention: -1)�,Iwy) 1 oty) ar Turn Around Time'
How would you like your report sent? *RUSH work needs prior approval.g� pays
Circle all that apply. Email(prefemed, Fax, Mail S
~•®•s �,••_•�
;. MERITECH, INC.
ENVIRONMENTAL LABORATORIES
642 Tamco Rd. Phone: [phone]
Reidsville NC27320 Fax: [phone]
Email; [e-mail]
www.meritechlabs.com
Sample Location and/or IDIt
Sampling Dates & Times
Person Taking SamplelSign' t:
ly /P)FSPr1h `, C
Lab Use Only
Start
End
Comp?
Grab?
#of
Cont.
Test(s)
Required
On Ice?
/No
pH OK?
Cl OK?
Date
Time
Date
Time
Qti tTii In kN )'X1Sl ✓t
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Temperaturel.1 nRecelpt
Method of
"' Dechlorination <0.5 m) of Ammonia, Cyanide Phenol and TKN samples must be done in the field priorto preservation. ""•
Shipment:
Comments:
Compositor #
Jug #
UPS
Fed Ex
Are. ults forregulatory purposes? Yes ❑ No
Report results in: mg/L J ug/i.
Hand Delivery
ellnq y: I
.i... at : _ Time:
(- , 2- 4
Rec a by: te: Time:
7 Z, q
Other
Relinq h d by
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Rece ved by. Date: Time:
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Relinquished by: Date: Tme:
Re VYLa •
11

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
RECEIVED
MAY 0 1 2015
Public Services
Contact: Dawn Molnar Report Date: 4/29/2015
Client: High Point, City of
PO Box 230 Project: 2Q LTMP
High Point, NC 27261 Date Sample Rcvd: 4/16/2015
Meritech Work Order # 04161542 Sample: ES Effluent Composite 4/15-16/15
Parameters Resul Analysis Date Reporting Li4ni Method
Total Dissolved Solids
380 mg/L
4/21/15
10.0 mg/L SM 2540C
Antimony, total
<25 ug/L
4/29/15
25 ug/L EPA200.7
Beryllium, total
<5 ug/L
4/29/15
5 ug/L EPA 200.7
Thallium, total
<20 ug/L
4/29/15
20 ug/L EPA 200.7
Meritech Work Order # 04161543 Sample: ES Effluent Grab 4/15/15
Parameters
Result
Analysis Date ReportingLintit
Method
EPA 624+Trip Blank
Attached
4/22/15
624
EPA 625
Attached
4/24/15
625
Phenols, total
<10 ug/L
4/28/15 10 ug/1.
EPA 420.1
Meritech Work Order #
04161544 Sample: WS Effluent Composite
4/15-16/15
Parameters
Result
Analysis Date
Reporting Limit
Method
Total Dissolved Solids
912 mg/L
4/21/15
10.0 mg/L
SM 2540C
Antimony, total
<25 ug/L
4/29/15
25 ug/L
EPA 200.7
Beryllium, total
<5 ug/L
4/29/15
5 ug/L
EPA 200.7
Thallium, total
<20 ug/L
4/29/15
20 ug/L
EPA 200.7
Meritech Work Order #
04161545 Sample:
WS Effluent Grab
4/15/15
Parameters
Result
Analysis Date
RenortingLimi[
Method
EPA 624+Trip Blank
Attached
4/22/15
624
EPA 625
Attached
4/24/15
625
Phenols, total
<10 ug/L
4/28/15
10 ug/L
EPA420.1
I hereby certify that I have reviewed and approve these data.
(a, tlu
642 Tanuo [load, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

M RI TECH, INC.
Environmental Laboratories
` A Division of Water Technology and Controls, Inc.
Client:
City of High Point Meritech IDq:
04161543
Project:
2Q LTMP Analysis:
04/22/15
Client Sample ID:
ES Effluent Analyst:
vWv
Sample Collection:
04/15/15 Dilution Factor:
I
Report Date:
04/27/15
EPA 624 VOLATILE ORGANICS
RECEIVED
NIM 0 1 2015
Public Services
Faramete
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
Methyl Bromide
< 5.00 ug/L
Carbon Tetrachloride
< 1,00 ug/L
Chlorobenzene
< 1.00 ug/L
Chlomethane
<5.00 ug/L
2-Chloroethyl vlayl ether
<5.00 ug/L
Chloroform
1.95 ug/L
Methyl Chloride
<5.00 ug/L
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
1,1-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Diclrlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
1,1-Dichloroethylene
< 1.00 ug/L
trans-1,2-Dichloroethylcne
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
<1,00ug/L
Tetrachloroethylene
< 1.00 ug/L
Toluene
< 1.00 ug/L
1,1,1-Tiichloroethane
<1,00ug/L
1,1,2-Trichloroethane
<1.00ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Comnoands
Acrolein
<50.0 ug/L
Acrylonitrile
<10.0 ug/L
I hereby certify that 1 have reviewed and approve these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MERI TECH, INC.
Environmental Laboratories
° A Division of Water Technology and Controls, Inc.
Client:
City of High Point Meritech ID#:
04161543tb
Project:
2Q LTMP Aunlysis:
04t22/15
Client Sample ID:
Trip Blank Analyst:
VWV
Sample Collection-
04/15/15 Dilution Factor:
1
Report Date:
04/27/15
Ei PA 624 VOLATILE ORGANICS
RECEIVED
MAY 0 1 2015
Public Services
r me er
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
Mefhyl Bromide
<5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
<5.00 ug/L
2-Chloroethyl vinyl ether
<5.00 ug/L
Chloroform
< 1.00 ug/L
Methyl Chloride
<5.00 ug/L
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
1,1-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Diclilorobenzene
< 1.00 ug/L
1,3-Dichlorobenzeue
< 1.00 ug/L
1,1-Dichloroethylene
< 1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
<1.00ug/L
cis4,3-Dichloropropylene
< 1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.01) ug/L,
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
Tetmchloroethylene
< 1.00 ug/L
'
Toluene
< 1.00 ug/L
1,1,1-Tichloroethane
<1.00 ug/L
1,1,2-Trichloroethane
<1.00ug/L
Trichloroethylene
< 1.00 ug/L
Triehiorofluoromethane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Compounds
Acrolein
<50.0 ug/L
Acrylonitrile
I hereby certify that 1 have reviewed and approve these date.
<10.0 6g/L
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

Client:
Project:
Client Samplo ID:
Sample Collection:
Pommeler
Acenaphthene
Acenaphthylene
Ant scene
Benzidine
Benzo(a)anthmcene
Benzo(a)pyrene
Benzo(b)fluomnthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Benzyl butyl phthalate
Bis(2-chloroelhoxy)nhethane
Bis(2-chloroelhyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-e1hylhexyi)phthalate
4-Bromophenyl phenyl ether
2-Chloronaphthalene
4-Chlorophenylphenyl ether
Chrysene
Dibenzo(a,h)aulluacene
1,2-Dicldorobenzene
1,30ehlorobenzene
1,4-Dichlorobenzene
3,T-Dichloroberzidine
Diethyl phthalate
Dimet yl phthalate
Di-n-butyl phthalate
2,4-Dinitrotoluehe
2,6-Dinitrotoluehe
Di-n-octyl phthalate
1,2-Dipheny1hydmzi ne
M EWITECH, INC.
Environmental Laboratories
Laboratory CertiOcale #165
City of High Point
Me•itech Ift
04161543
2Q LTMP
Analysis:
04/24/15
ES Effluent
Extraction:
04/20/15
04/15/15
Analyst:
PM
Dilution Factor: 1
EPA 625 SEMIVOLATILI; ORGANICS
Result
P ranhe a
Result
<10 ug/L
Fluoranthene
<10 ug/L
<10 ug/l,
Fluorene
<10 ug/L
<10 ag/L
Hexachlorobenzene
<10 ug/L
<50 ug/L
Hexachlorobutadlene
<10 ug/L
<10 ug/L
Hexachlorocyclopentadiene
<50 ug/L
<10 ug/L
Hexacldoroethane
<10 ugIL
<10 ug/L
Indeno(1,2,3-Apyrene
<10 ug/L
<10 ug/L
Isophorono
<10 ug/L
<10 ug/L
2-Methyinaphthalere
<10 ug/L
<10 ug/L
Naphthalene
<10 ug/L
<10 ug/L
Nitrobenzene
<10 ug/L
<10 ug/L
N-Ninosodimelbylamine
<10 ug/L.
<10 ug/L
N-Nitrosodi-n-propylamine
<10 ug/L
<10 ug/L
N-Nitrosodiphenylamine
<10 ug/L
<10 ug/L
Phenanthrene
<10 ug/L
<10 ug/L
Pyrene
<I0 ug/L
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
<10 ug/L
<10 ug/L
4-Chloro-3-methylphenol
UO ug/L
<10 ug/L
2-Chlorophenol
<10 ug/L
<10 ug/L
2,4-Dichlorophenol
<10 ug/L
<10 ug/L
2,4-Dinadbylphenol
<10 ug/L
<50 ug/L
2,4-Dini1ropherol
<50 ug/L
<10 ug/l,
4,6-Dinilro-2-methylphenol
<50 ug/4
<10 ug2
2-Nitrophenol -
<10 ug/L
<10 ug/L
4-Nitrophenol
<50 ug/L
<10 ug/L
Pentachlorophenol
<50 ug/L
<10 ug/L
Phenol
<10 ug/L
<10 ug/L
2,4,6-Trichlorophenol
<10 ug/L
<10 ug/L
I hereby certify that I have reviewed and approve these data,
Labomlory Representative
642 Tamco Road" Reidsville, NC 27320
[phone] Ph " [phone] Fax
RECEIVED
MAY 0 j 201E
Public Services

RECEIVED
ME141TECH, INC.
MAY 01 2015
Environmental Laboratories
Public Services
A Division of Water Technology and Controls, Inc.
Industrial Pretrealrr
Client:
City of High Point Meritech IDNr 04161545
Project:
2Q LTMP Analysis: 04/22/15
Client Sample ID:
WSEfiluent Analyst: VWV
Sample Collection:
04/15/15 Dilution Factor: 10
Report Date: 04/27/15
EPA 624 VOLATILE ORGANICS
ramete Result
Benzene < 10.0 ug/L
Dichlorobromomethane < 10.0 ug/L
Bromoforn ' < 10.0 ug/L
Methyl Bromide < 50.0 ug/L
Carbon Tetrachloride <10.0ug1L
Chlorobenzene < 10.0 ug/L
Chloroethane <50.0 ug/L
2-Chloroethyl vinyl ether <50.0 ug/L
Chloroform < 10.0 ug/L
Methyl Chloride <50.0 ug/L
Chlorodibromomedrane < 10.0 ug/L
1,2-Dibromoethane < 10.0 ug/L
1,1-Dichloroethane < 10.0 ug/L
1,2-Dichloroethane < 10.0 ug/L
1,4-Dichlorobenzene < 10.0 ug/L
1,2-Dichlorobenzene < 10.0 ug/L
1,3-Dichlorobenzene < 10.0 ug/L
1,1-Dichloroethylene <10.0ug/L
trans-L,2-Dichloroethylene <10.0ug/L
1,2-Diclrloropropane < 10.0 ug/L
cis-1,3-Dichloropropylene < 10.0 ug/L
trans-1,3-Dichloropropylene < 10.0 ug/L
Ethyl benzene < 10.0 ug/L
Methylene chloride < 10.0 ug/L
1,1,2,2-Tetrachloroethane < 10.0 ug/L
Tetraclrioroethylene < 10.0 ug/L
Toluene < 10.0 ug/L
1,1,1-Trichloroethane < 10.0 ug/L
1,1,2-Trichloroethane <10.0ug/L
Trichloroethylene < 10.0 ug/L
Troblorofluoromethane <50.0 ug/L
Vinyl chloride <50.0 ug/L
Additional Comnounds
,
Acrolein <500 ug/L
Acrylonitrife < 100 ug/L
I hereby certify that
I have reviewed and approve these data.
yD%�
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MCHI TECH, INC.
r _
Environmental Laboratories
"
A Division of Water Technology and Controls, Inc.
f
Client:
City of High Point Meritech IDtt: 04161545tb
Project:
2Q LTMP Analysis: 04/22/15
Client Somple ID:
Trip Blank Analyst; VWv
Sample Collection:
04/15/15 Dilution Factor: I
Report Date: 04/27/15
EPA 624 VOLATILE ORGANICS
RECEIVED
MAY 0 1 1015
Public Services
aram ter
Result
Benzene -
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
Methyl Bromide
<5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
<5.00 ug/L
2-Chloroethyl vinyl ether
< 5.00 ug/L .
Chloroform
< 1.00 ug/L
Methyl Chloride
<5.00 ug/L
Chlorodibromomethane
<1.00 ug/L
1,2-Dibromoethaue
< 1.00 ug/L
1,1-Dichloroethane
<1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzeile
< 1.00 ug/L
1,3-Dlchlorobenzone
< 1.00 ug/L
l,l-Dichloroethylene
< 1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
Tetrachloroethylene
< 1.00 ug/L
Toluene
< 1.00 ug/L
1,1,1-Trichloroetbane
<1,00'ug/L
1,1,2-Trichloroethane
< 1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoro:netlhane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Cornuouuds
Acrolein
<50.0 ug/L
Achylonitrile
<10.0 ug/L
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

s
MERITECH, INC.
Environmental Laboratories RECEIVED
Laboratory Certificate #165
MAY 0 1 2015
Public Services
Client: City of High Paint Meritech ID#: 04161545 Industrial Pretreatir
Project: 2Q LTMP Analysis: 04/24/15
Client Santplc ID: WS Effluent Extraction: 04/20/15
Sample Collection: 04/15/15 Analyst: PM
Dilution Factor: I
EPA 625 SEMIVOLATILE ORGANICS
Parameter Result Parameter Result
Acenaphthene
<10 ug/l,
Pluoranthene
<10 ug/L
Acenaphthylene
<10 ug/L
Fluorene
<10 ug/L
Anthracene
<10 ug/L
Hexaehlorobcnzene
<10 ug/L
Benzidine
<50 ug/L
Hexachlorobutadierte
<10 ug/L
Benzo(a)andtmcene
<10 ug/L
Hexachlorocyclopentadiene
<50 ug/L
Benzo(a)pyrene
<10 ug/L
Hexacldoroethane
<10 ug/L
Benzo(b)fluoranthene
<10 ug/L
hldeno(1,2,3-cd)pyrene
<10 ug/L
Beazo(k)fluoranthene
<10 ug/L
fsophorone
<10 ug/L
Benzo(g,hJ)perylene
<10 ug/L
2-Methy1taphthalene
<10 ug/L
Benzyl butyl phthalate
<10 ug/L
Naphthalene
<10 ug/L
Bis(2-chloroelhoxy)methane
<10 ug/L
Nitrobenzene
<10 ug/L
Bis(2-cldoroethyl)ether
<10 ug/L
N-Mtrosodimethylamine
<10 ug/L
Bis(2-chloroisopropyl)ether
<10 ug/L
N-Nitrosodi-n-propylamine
<10 ug/L
Bis(2-ethylhexyl)phthalale
<10 ug/L
N-Nitrosodiphenylamine
<10 ug/L
4-Brontopltonyl phenyl ether
<10 ug/L
Phenanthrene
<10 ug/L
2-Chloronsphthalene
<10 ug/L
Pyrene
<10 ug/L
4-Chlorophenyl phenyl ether
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
Cbrysene
<10 ug/L
Dibenzo(a,h)anthracene
<10 ug/L
4-Cldoro-3-methylphenol
<10 ug/L
1,2-Dichlorobenzene
<10 ug/L
2-Chlorophenol
<10 ug/L
1,3-Dioitlorobenzene
<10 ug/L
2,4-Dichloropltenol
<10 ug/L
1,4-Dichlorobenzene
<10 ug/L
2,4-Dimethylphenol.
<10 ug/L
3,T-Dichlorobenzidine
<50 ug/L
2,4-Dinitrophenol
<50 ug/L
Diethyl plitltalate
<10 ug/L
4,6-Diuitro-2-methylphenol
<50 ug/L
Dhnethyl phthalate
<10 ug/L
2-Nitrophenol
<I0 ug/L
Di -a -butyl phthalate
<10 ug/L
4-Nitrophenol
<50 ug/L
2,4-Dinitrotoluene
<10 ug/L
Pentachlorophenol
<50 ug/L
2,6-Dinitrotoluene
<10 ug/L
Pbenol
<10 ug2
Di-n-octyl phthalate
<10 ug/L
2,4,6-Trichlorophenol
<10 ug/L
I,2-Dipheny1hydrazine
<10 ug/L
I hereby certify that I have reviewed and approve these data. J(,j
Laboratory Representatives
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

y
Chain
of Custody Record (COC)
NPDES#
MERITECH, INC.
Client: G114 or 141GV4 Pol JT
Phone:
Fax:
ENVIRONMENTAL LABORATORIES
Address: PO �DX ��
�`I:
Project# � L-TMP
A Division of Water Techno%gyand Controls,/nc.
!-� 1G-H7 I NT WC Di �01'
P.O.#
Phone: �-336-342-4748
642 Tamco Rd. Fax: [phone] 'f
"urn Around Time*'
*Rrapproval.522 *USH wok must have prior
Reidsville, NC 27320
Email: snnrtechQbellsouth.net
Web Site: www.meritech-labs.com
Attention: DRAW N MD1._N AFL
Sw 10 y
3 5 Day
2a - Hr
�
Sample
Sampling Dates
& Times
PersonTakin
Sam
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Required
LaUse
ly
1_ocation/t D #
START
END
Comp?
crab?
# of
coats.
Tests Required
200•$ / 2D0.7
pH OK?
pH OK
Data
Time
Date
Time
cs
G
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ESP 1a2.
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compositor#
'''"`Dechlorination (40.5 ppm) of Ammonia, Cyanide, Phenol or TKN samples must be done in the field prior to preservation."**
Jug #
Comments:
Method of Shipment:
Are these results for regulatory pu ?
Report results to
Cl UPS
YES ❑
rng/L
❑ mg/Kg ❑ On lee?
Temperature On Receipt
�r ~
❑ Fed Ex
Reis hed by% Date Time
Reoe d by
Date Time
❑ Hand Delivery
R
Other
Date
rime
Received by
Date Time
rtkLu�,U,}, �`
Relinquished by Date Time
p
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U
Author. Lechat Instruments � ��2nF d [
]dews
Original Run Filename: OM 7-24-2015_02-50-02PM.OMN Cre 42015 2:50:02 PM
Original Run Author's Signature: [Lachat Instruments]
Current Run Filename: OM_7-24-2015_02-50-02PM.OMN Last Modified: 7/24/2015 3:32:12 PM
Current Run Author's Signature: [Lachat Instruments]
Description: Default New Run
Sample
Rep.
Channel 1
MDF
Cyanide
Conc. (mg Area
CN-IL) (Vs
0.500 ppm standard
1
0.500
9.820
2
0.500
9.787
0.250 ppm standard
1
0.250
5.3 50
2
0.250
5.33232
0.100 ppm standard
1
0.100
2.333
2
0.100
2.320
0.050 ppm standard
1
0.050
1.193
2
0.050
1.190
0.010 ppm standard
1
0.010
0.246
2
0.010
0.249
Blank
1
0.000
-0.011
2
0.000
-0.003
CCV 0.250 ppm
1
0258
5.247
Known
Cone:
0.250
DQM Test: > + Percent Relative Difference
Result
13.4 < 10.0 _
Messa a
Pass
Action
DQM Test: < - Percent Relative Difference
Result:
3.4 < 10.0
Message
Pass
Action
Calibration:
Table/Fig.: 1
CVB 1 1
-0.008
0.018
Known Cone:
0.000
DQM Test: > + Concentration Limit
Result:
-0.008 < 0.010
Message
Pass
Action
Digested Blank 724
1
n -0.008
0.017
Digested CCV 724
1
0.241
4.91
Digested NSI April 2015
1
0.885
8.862
2.00
Eastside Effluent 7115
1
kow
0.083
Eastside Effluent LFM 7/15
1
0.050
1.162
Eastside Effluent LFM Du 7/15
1
0.051
1.173
S ikin
one:
1 100.000
Eastside Influent 7/13
1
o.o i
0.127
Westside Influent 7/13
1
o.a, -0--BW
0.049
Eastside Aer. MLSS 7/15
1
0.0
0.345
Eastside Prim Clar 7/15
1
o.w GRW
0.087
CCV 0.250 DPm
1
0.260
5.269
Known Conc:
0.250
DQM Test: > + Percent Relative
Difference
Resutt:
_
Messa a
Pass
Action
DQM Test: <- Percent Relative Di ference
OK
Cal,a t-F M
I CIO /.
L1"m�
�, osos

�—
Author. Lachat Instruments Cyanide m reviewed bV:.a ddO:LW(il(V iPYi®W@G rIY: e7/2016
Result: 3.8 < 10.0
Message Pass
Action
CVB 1 1 -0.008
0.012
Known Cone: 0.000
DQM Test: > + Concentration Limit
Result:
-0.008 < 0.010
Message
Pass
Action
Westside Effluent 7/15
1
<0.0 t
0.088
Westside Effluent LFM 7/15
1
0.052
1.191
Westside Effluent LFM Du 7/15
1 1
0.050
1.159
S ikin Conc:
100.000
Westside Aeration 7/15
1
a o
0.094
Westside Tower Eff 7/15
1
a .J t A,0 5"
0.275
Westside Prim Clar Eff 7115
1
eo.c3l -0 96s
0.080
Jamestown 7115
1
zo.3 ) -DAN
0.059
Archdale 7/15
1
i
0.054
Sed efield 7/15
1
a,o i -0,967-
0.026
CCV 0.250 ppm
1
0.261
5.296
Known
Conc:
0.250
DQM Test > + Percent Relative Difference
Result
_
4.4 < 10.0
Messa a
Pass
Action
DQM Test: <. Percent Relative Difference
Result
4.4 < 10.0
Message
Pass
Action
CVB 1
-0.008
0.021
Known Conc:
0.000
DQM Test•. >+ Concentration Limit
Result:
-0.008 < 0.010
Pass
Message
Action
Analyte Properties Table for : OM_7-24-2015_02-50-02PM.OMN
Property
Channell
snide
Concentration Units
mg CN-/L
Calibration Fit Type
First Order
Clear Calibration
Yes
Force through
Zero
No
Calibration
Weighting
None
Auto Dilution Trigger
No
of HI
h Standard
100
Quik Chem
Method
10-204-00-1-A
Chemist
Direct/Bi olar
Calibration by Height
No
Inject to Peak Start
23
Peak Base Width
44
-2- of, 1
Q"
ca1� Ll`'rn
Cox q]Co.S x.ro� = o
�a R4D = a •05 a . o .��fao ,

1�
Author: Lachat Instruments Cyanide Date : 1 /20/2016
Original Run Filename: OM 1-17-2016_02-20-28PM.OMN Created: 1/17/2016 2:20:28 PM
Original Run Author's Signature: [Lachat Instruments] r
Current Run Filename: OM 1-17-2016_02-20-28PM.OMN Last Modified: 1/17/2016 2:59:15 PM
Current Run Authors Signature: [Lachat Instruments]
Description: 10-204-00-1-A j Jt
Sample
Rep.
Channel 1
MDF
Cyanide
_
Conc. (mg
CN-/L)
Area
(V.s
0.500 ppm standard
1
0.500
7.411
2
0.500
7.444
0.250 ppm standard
1
0.250
4.177
2
0.250
4.164
0.100 ppm standard
1
0.100
1.810
2
0.100
1.836
0.050 ppm standard
1
0.050
0.919
2
0.050
0.898
0.010 ppm standard
1
0.010
0.216
2
0.010
0.217
Blank
1
O.ODO
-0.018
2
0.000
-0.036
DCS 0.250 ppm
1
0.272
4.225
Known
Conc:
0.250
DQM Test: > + Percent Relative
Difference
Result:
9.0 < 10.0
Message
Pass
Action
DQM Test: <- Percent Relative Difference
Result:
9.0 < 10.0
Message
I Pass
Action
Calibration:
Table/Fig. : 1
Blank I 1
-0.010
0.010
Known Conc:
0.000
DQM Test: > + Concentration Limit
Result:
1 -0.010<0.010
Message
I Pass
Action
Digested
Blank 1/17
1
a -0.006
0.055
Digested
DCS 1/17
1
0.184
2.903
Digested
NSI Nov 2015
1
0.859
6.572
2.00
Eastside Effluent 1/6
1
0 o1 = -0.005
0.080
Eastside Eff LFM1 1/6
1
0.037
0.702
Eastside Eff LFM2116
1
0.036
0.685
S ikin Conc:
100.000
Eastdside Influent 1/4
1
wzp =-0.004
0.089
Eastside Prim Clarifier Eff 1/6
1
0.01 < -0.007
0.048
Eastside Aeration
MLSS 1/6
1
0.049
0.886
Westside Effluent
1/6
1
o.o, _ -0.006
0.067
DCS 0.250 ppm
1
0.258
4.005
Known Conc:
0.250
DQM Test: > + Percent Relative
Difference
Result:
3.1 < 10.0
Messa a
Pass
Action
DQM Test: <- Percent Relative Difference
Result:
3.1 < 10.0
Messa a
Pass
Action
Blank 1
-0.008
0.031
for �ro 1 i1i Mi i s Ory)
1 Id+/� 41
LFrr)� = 0.o3�/cS.oS
LFmz= 0.036�o.os
1-°P5
,
0,05
X im < -:�-'a

I bv.j+af@
Author: Lachat Instruments Cyanide, C10}@: Date :1/20/2U16
Known Cone:
1 0.000
DQM Test. > + Concentration
Limit
Result
1 -0.008 < 0.010
Message
Pass
Action
Westside Influent 1/4
1
o,a 1= -0.006
0.067
Westside Influent LFM1
1/4
1 1
0.033
0.641
Westside Influent LFM2114
1 1
0.031
0.616
Spiking
one.,
100.000
Westside
Prim Clarifier Eff 1/6
1
0,01 --0.006
0.059
Westside
Aeration Basin 1/6
1
e a.o1 _ -0.002
0.119
Westside Tower Filter Eff 1/6
1
0.014
0.360
DOS 0250 m
1
0.262
4.073
Known
Conc:
0.250
DQM Test: > + Percent
Relative Difference
Result
4.9 < 10.0
Massa a
Pass
Action
DQM Test <- Percent Relative Difference
Result
4.9 < 10.0
Message
Pass
Action
Blank 1
-0.011
-0.005
_
Known Cone:
0.000
DQM Test: > + Concentration
Limit
Result
-0.011 <0.010
Message
Pass
Action
Analyte Properties Table for: OM_1-17-2016_02-20-28PM.OMN
Property
Channel
CVanide
Concentration
Units
mg CN-/L
Calibration Fit
Type
First Order
Clear Calibration
Yes
Force
through Zero
No
Calibration
Weighting
None
Auto
Dilution Trigger
No
% of High
Standard
100
Quik Chem
Method
10-204-00-1-A
Chemistry
Direct/Bipolar
Calibration by Height
No
Inject to Peak Start
24
Peak Base Width
38
C,alc L-Frh =
(o x-`I)(0.S K-16)= a-oS
O-033 /o.05 CGS /.
O,D3Z
2 1C�����
\' ` 1

Author. Lachat Instruments Cyanide Date: 11/8/2016
�1
Original Run Filename: OM_11-8-2016_03-23-34PM.OMN Created: 11/8/2016 3:23:34 PM
Original Run Author's Signature: [Lachat Instruments]
Current Run Filename: OM_11-8-2016_03-23-34PM.OMN Last Modified: 11/8/2016 4:04:50 P
Current Run Author's Signature: [Lachat Instruments]
Description: Default New Run 1s2 C dewed by:_ Date:
Sample
Rep.
Channel 1
MDF
Cyanide
Conc. (mg Area
CN4L) (V.s
0.500 ppm standard
1
0.500
15.587
2
0.500
15.640
0.250 ppm standard
1
0.250
8.567
w
2
0.250
8.346
0.100 ppm standard
1
0.100
3.369
A.
2
0.100
3.480
0.050 ppm standard
1
0.050
1.7 56
2
0.050
1.77272
0.010 ppm standard
1
0.010
0.537
-�
2
0.010
0.590
Blank
1
0.000
0.167
2
0.000
1.070
CCV 0.250 ppm
1
0.264
8.603
Known
Conc:
0.250
DQM Test: > + Percent Relative Difference
Result
5.5 < 10.0
Message
Pass
Action
DQM Test < - Percent Relative Difference
Result:
15.5 < 10.0
Message
Pass
Action
Calibration:
Table/Fig.: 1
CVB 1 1
-0.025
-0.359
Known Conc:
0.000
DQM Test: > + Concentration Limit
Result
-0.025 < 0.010
Message
Pass
Action
Digested Blank 11/8
1
0.015
0.876
Digested CCV 11/8
1
bb' 2,A80
12.083
OSS October 2016
1
p K 1 77
12.335
2.00
Westside Effluent 10/26
1
0.010
0.114
Westside Effluent LFM1 10126
1
-0.020
-0.200
"
Westside Effluent LFM2 10/26
1
0.020
1.029
S
Spiking Canc:
100.000
Westside Prim. Clar. 10/26
1
LOWS -0.012
0.040
Westside Influent 10/24
1
1,eov 1 -0.013
0.023
Westside Tower Filter 10/26
1
1 0•O -0.008
0.160
Westside Aeration Bas. 10/26/16
1
o •U -0.008
0.171
CCV 0.250 m
1
0.270
8.684
Known
Conc:
1 0.250
DQM Test > + Percent Relative Difference
Result
7.8 < 10.0
Massa a
Pass
Action
DQM Test: < - Percent Relative Difference
2naii viewfti by: fie:
U�
" cty
6�Q
JJ�+g[P
a, �P LF a ib
'� � r

!�,O(q*
j,Pj%W
Author: Lachat Instruments Cyanide
Date: 11/8/2016
Date: ±5�
Result.
Message
7.8 < 10.0
Pass
i reviewed by:
4reviewed by:
Cadh c sP� /
Action
CVB --__ - 1
-0.012
0.030
Known Conc:
0.000
DQM Test > + Concentration
Umit
Result
-0.012 < 0.010
Message
Pass
`/� 073� � /
�y•�J�'/
FM 2
��/0, p 7 �j jl
V • D
} o• a 7�
pp9�
pX)Av D,bSUIb
c5E t�
Action
Inns ec 10/19
1
0.026
1.212
Innos c LFM1 10/19
1
0.050
1.947
Innos ecLFM210/19
1
0.076
2.748
Spiking
Con:
100.000
Eastside Pnma Clar 1026
1
0.014
0.839
Eastside
1
0.011
0.764
Eastside Aeration Bas. 1026
Eastside Effluent 192E
1
1
0.022
0.045
1.102
1.788�rp
Westside Eff LFM1 1026
1
-0.008
0.171
WestsideLFM21021
1
" -0.012
0.044
CCV 0.250 ppm
1
0.258
8.338
Known
Cone:
0.250
DQM Test: > + Percent Relative
Difference
Result
13.3 < 10.0
Message
I Pass
Action
ItW
DQM Test < _ Percent Relative
Difference
/� X
l
Iva
f r �`^ '• ce
Result
3.3 < 10.0
Messa a
Pass
Action
CVB 1
-0.014
-0.028
Known Cone:
0.000
DQM Test > + Concentration
Limit
Result
-0.014 < 0.010
Messa e
i Pass
Action
Analyte Properties Table for: OM_11-8-2016 03-23-34PM.OMN
Property
Channel
Cyanide
Concentration Units
mg CN4L
Calibration Fit Tye
First Order
Clear Calibration
Yes
Force through Zero
No
Calibration Weighting
None
Auto Dilution
Trigger
No
% of High
Standard
100
Quik Chem Method
10-204-00-1-A
Chemistry
DlrecNBi lar
Calibration by Height
No
Inject to Peak Start
11
Peak Base Width
44
by
6•a7•�
00 = (g!O
1/00 = 109%
Z-= c.o4-3
0(0 3 = <// %
,r-�crartcG
�VrF)b

SAMPLE INFORMATION
ANALYTICAL
INFORMATION
OBSERVED
REPO -!
SAMPLE DATE
LOCATION
POINT
ANALYSIS
VALUE
UNIT
ANALYST
CONDITION OF SAMPLE
REPURTEOTo:
At setup (10.14.2016) the sample
unknown at
appeared vilm n0y purple in
To DM, BF
10/13/2016
Westside
Influent
BOD/COD
time of UCR
m IL
GEJ
mlor.10-18-2016 for COD
From Gel
only the 2.0 % dlutioin met the
uptake of at least 2.0 mg& and the
10-12-2016 (WS inf
residual O2 of at least 1.0mg/L.
To DM, BE
ONLY)
Westside
Influent
BOD
195
moll.
GEJ
Date will need to be qualified
From Ge'
Value below the minimum
requirement for gga with seed
To DM, BF
10/172016
QA/QC
GGA with Seed
BOD
166
me
JL
es/CY
198+/-30.5=167.5
From CV
Both water blanks exceeded the
To DM, BF
1021/16
CA/QC
Blank
BOD
0.40 0.39
m /L
nei, CY
</=0.2 criteria
From CY
10/31/2016(W S
Value below the minimum
INF/EFF)& 11/12016
requirement for gga with seed
To DM, BF
WS&ES INF/EFF
QA?QC
GGA with Seed
bod
159
m
GEJ
198+/-30.5=167.5
From GEJ
by time of Initial DO readings
(11:15) the calibration had drifted
some 1.2mg/L lower. Probe was
cleaned in Ammonium Hydroxide
and recalibratred at (12:14). more
than 1 hour and 25 minutes
passed since seed was added to
samples befre initial DO's were
taken. The OG specifies this data
111142016(WS
must be collected within 30 mins
INFIEFF) & 11/15/2016
8.4 followed by
of seed addition. Data will need to
To DM, BF
ESIWS INF/EFF
QA/QC
Calibration
BOD
7.2
mq1L
I GEJ
be qualified
From GEJ
the only sample dilution to meet
the residual oxygen criteria of>1.0
mg/L was the 0.6% dilution as
such the data needs to be
qualified as the value presented is
net an average but an
11/102016 (WS INF
approximation based on one data
To DM, BF
ONLY)
Westside
Influent
BOD
1017
m
net
point.
From GEJ
Samples were overlooked and not
To DM, BF
10/20/2016 (ESANS Efiftl
Eastside & Westside
Effluent
COD
N/A
m L
GEJ
analyzed.
From GEJ
To DM, BF, CB
102NM16
Eastside
Effluent
Cyanide
0.011
Ingn.
AF
Sample results higher than usual.
From AF
To DM, BF, CB
101242016
Eastside
Influent
Cyanide
0.045
AF
Sample results Mother than usual.
From AF
11/30/16 (WS INF/EFF)
& 1211/16 (ES & WS
Blanks exceed the maximum
to DM BE From
INF/EFF)
Blank
BOD
0.89 & 0.81
MAIL
Gel
ante table Wake of 0.2 m
GEJ
Blanks exceed the maximum
To: DM, BF
12J2/2016
Blank
BOD
0.46 0.42
mq1L
TL
acceptable uptake of 0.2 m /L
From: TL
GGA with seed below the
To: DM, BE
12/22/i6
GGA with SEED
SOD
166
m L
Gel
acceptance criteria.
From: GJ
Blanks exceed the maximum
12116/16
Westside
Inf/E8
BOD
0.49&0.47
m
as
acceptable uptake of 0.2 mall.
o DM BF From
Seeded blank not within +/. 0.2
to DM BF from
12/19/16
Seeded Blank
BOD
moll.
as
seed value
as
First blank exceeded the 0.2
To DM, BF
12/12/16
Blank
BODm
AF
u ke rule.
From AThecalculatedseedvaluewas
FO.73
0.8, but the reduction of the
To DM, BF
12JI2116
Seeded Blank
BODm
AF
seeded blank was 0.2.
From AF

1st reviewed bY'� ate:<<�
_
Author. Lachat Instruments CYANIDE 2nd reviewed t)y, state:Date: 11=017
Original Run Filename: OM_11-2-2017 0942-23AM.OMN Created: IUM017 9:4223 AM
Original Run Authors Signature: [Lachat Instruments]
Current Run Filename: OM_11-2-2017 0942-23AM.OMN Last Modified: 11/2/2017 10:18:16 AM
Current Run Authors Signature: [Lachat Instruments]
Description: 10-204.00-1-A
Sample
Rep.
Cup No.
Channell
MDF
Cyanide
Conc. (mg CN-
/L)
Area
(V.s
0.600 porn standard
1
1
0.500
20
2 1
1
0.500
20A.4
0.250 ppm standard
1
2
0.250
10.
2
2
0.250
10.7
0.100 ppm standard
1
3
0.100
4. 40
2 1
3
0.100
4.3939
0.050 ppm standard
1
4
0.0500
2.24
2
4
0.0500
2.23
0.010 ppm standard
1
5
0.0100
0.467
2
5
0.0100
0.457
Blank
1
6
0.00
-2.74e3
2
6
0.00
0.0241
CCV 0.250 m
1
2
0.255
10.9
Knoxm Conn
0.250
DOM Test: > +percent Relative
D'rfference
Result:
22 < 10.0
Mess a
Passed
Action jContlnue
DOM Test: <- Percent Relative
Difference
Result:
122 < 10.0
Message
I Pass
Action
Calibration:
TablelF .:1
Blank 1 1 6
5.79e4
0.0393
Known Conc:
0.00
DOM Test: > + Concentration
Limit
Result:
5.79e4 < 0.0100
Massacre
Pass
Action
Di esled Blank 1 V2
1
1 7
4.44e4
0.0332
0.25 m CCV Di es 11/2
1
8
0.246
10.5
OSS JULY 2017
11
9
0.257
11.0
ES Effluent 10118
1
10
o.cl , 1.56e-3
0.0831
ES Effluent LFMt 10f18
1
1 11
0.0494
221
ES Effluent LFM210/18
1
1 12
0.0474
2.12
Spiking
Conc:
100
DOM Test Maximum Relative Percent
Difference
Result:
4.3 < 10.9
Message
Pass
Action
ES Prim Clarifier 10/18
11
13
= 1.05e-3
0.0602
ES Aeration Basin 10/18
1
14
! 5.01e-3
0.238
ES Influent 10/16
1
15
mod.!%1 = 1.0Oa3
0.0583
CCV 0.250 m
1
2
0.257
10.9
Known Conc:
0.250
DOM Test: > + Percent Relative
D'dferenoe
Result
1 2.7 < 10.0
Message
Passed
Action
I Continue
DOM Test: < - Percent Relative
Difference
Result:
12.7 < 10.0
Messy a
Pass
Action
1,%-, tj,
t�i'�' �
IA
7 FY -/ oG .i
�� � OIL-`r� .�•i\ L v u\
p.'0"Ry

1 St reviewed by date; i /i //�
,
Author. Lechat Instruments CYANIDE 2nd reviewed by.date.
Date: 11/2/2017
Blank 1 6
1.09"
0.0182
Known Cono:
100
WS Effluent 10/18
1
16
'o•o=1.19e-3
0.0668
WS Effluent LFM1 10/18
1
17
0.0482
2.15
WS Effluent LFM210/78
1
18
0.0487
2.18
_
S l
no Conc:
100
WS Prim Clarifier 10/18
1
19
I s 1.03e3
0.0597
WS Aeration Basin 10118
1
20
lowI c 5.67e-3
0.268
WS Influent 10116
1
21
d.o 1-1.80e4
5.21e-3
CCV 0.250 m
1 1
2
0.2511
10.7
Known
Conc:
100
Blank 1
1 6
I
0.0268
Known Cone
.-3.02e.41
0.00
DQM Test > + Concentration
Limit
Result
3.02e4<0.0100
Massa a
Pass
Action
Analyte Properties Table for: OM_11-2-2017_0942-23AM.OMN
Property
Channel
Cyanide
Concentration Units
ma CN-/L
Calibration Fit Type
Seoond Order
Clear Calibration
Yes
Force through Zero
No
Calibration Weighting
None
Auto Dilution Trigger
No
% of Hi h Standard
100
Quik Chem Method
10-204-00-1-A
Chemistry
Direct/Bipolar
Calibration by Height
No
Inject to Peak Start
22
Peak Base Width
44
Channel 1 (Cyanide) - Set: 1 / 4
euc I �0 •971 ..T-G.Q�• p.t/�
o.uYS?- / oxSo re'"
o.�4`d115
'2 E
m m
v
c c
E
'2
E E
n a
a
E
E
E
a
o
m
m
ai Yi n
0 0
0.500 mg 00.5W mg Co/L
n
N
E
n
E
n
a
c
a
c
n
a
o.
n
o c
0.250 mg C0.250 mg CWL
m 0.100
0
o 6 c
mg C0.100 mg CO'0500
o
o
2.
0
0
—A—A—
_100
mg 0.0500
mg 0
mg 0.0100 mg CN

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Dawn Molnar
Client: High Point, City of
PO Box 230
High Point, NC 27261
Report Date:
Date Sample Rcvd:
Page 1
2/1/2017
1/19/2017
Meritech Work Order #
01191733 Sample: Eastside Effluent Composite
1/18-19/17
Parameters
Result
Analysis Date
Reporting Limit
Method
Total Dissolved Solids
460 mg/L
1/23/17
10.0 mg/L
SM 2540C
Antimony, total
<0.025 mg/L
1/25/17
0.025 mg/L
EPA 200.7
Beryllium, total
<0.005 mg/L
1/25/17
0.005 mg/L
EPA 200.7
Cadmium, total
<0.002 mg/L
1/25/17
0.002 mg/L
EPA 200.7
Chromium, total
<0.005 mg/L
1/25/17
0.005 mg/L
EPA 200.7
Copper, total
0.002 mg/L
1/25/17
0.002 mg/L
EPA 200.7
Lead, total
<0.010 mg/L
1/25/17
0.010 mg/L
EPA 200.7
Nickel, total
<0.010 mg/L
1/25/17
0.010 mg/L
EPA 200.7
Silver, total
<0.005 mg/L
1/25/17
0.005 mg/L
EPA 200.7
Thallium, total
<0.020 mg/L
1/25/17
0.020 mg/L
EPA 200.7
Zinc, total
0.044 mg/L
1/25/17
0.005 mg/L
EPA 200.7
Meritech Work Order #
01191734 Sample: Eastside Effluent Grab
1/18/17
Parameters
Result
Analysis Date
Reporting Limit
Method
Phenols, total
0.029 mg/L
1/20/17
0.010 mg/l.
EPA 420.1
EPA 624+TB
Attached
1/29/17
624
EPA 625
Attached
1/19/17
625
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Dawn Molnar
Client: High Point, City of
PO Box 230
High Point, NC 27261
ReportDate:
Date Sample Rcvd:
Page 2
2/1/2017
1/19/2017
Meritech Work Order #
01191735 Sample: Westside Effluent Composite.
1/18-19/17
Parameters
ResuJI
Analysis Date
Reporting Limit
Method
Total Dissolved Solids
416 mg/L
1/23/17
10.0 mg/L
SM 2540C
Antimony, total
<0.025 mg/L
1/25/17
0.025 mg/L
EPA 200.7
Beryllium, total
<0.005 mg/L
1/25/17
0.005 mg/L
EPA 200.7
Cadmium, total
<0.002 mg/L
1/25/17
0.002 mg/L
EPA 200.7
Chromium, total
<0.005 mg/L
1/25/17
0.005 mg/L
EPA 200.7
Copper, total
0.003 mg/L
1/25/17
0.002 mg/L
EPA 200.7
Lead, total
<0.010 mg/L
1/25/17
0.010 mg/L
EPA 200.7
Nickel, total
<0.010 mg/L
1/25/17
0.010 mg/L
EPA 200.7
Silver, total
<0.005 mg/L
1/25117
0.005 mg/L
EPA 200.7
Thallium, total
<0.020 mg/L
1/25/17
0.020 mg/L
EPA 200.7
Zinc, total
0.041 mg/L
1/25/17
0.005 mg/L
EPA 200.7
Meritech Work Order #
01191736 Sample: Westside Effluent Grab
1/18/17
Parameters
Result
Analysis Date
Reporting Limit
Method
Phenols, total
0.050 mg/L
1/20/17
0.010 mg/L
EPA 420.1
EPA 624 + TB
Attached
1/24/17
624
EPA 625
Attached
1/30/17
625
I hereby certify that I have reviewed and approve these data. it- �3<�
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

MERI TECH, INC.
- Environmental Laboratories
w- .d Laboratory Certification #165
Client:
City of High Point Meritech ID#:
01191734
Project:
IQ LTMP Analysis:
OVUM
Client Sample ID:
Eastside Effluent Analyst:
V W V
Sample Collection:
01/18/17 Dilution Factor:
1
Report Date:
01/25/17
EPA 624 VOLATILE ORGANICS
Parameter
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
Methyl Bromide
< 5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chlomethane
< 5.00 ug/L
2-Chloroethyl vinyl ether
< 5.00 ug/L
Chloroform
3.26 ug/L
Methyl Chloride
<5.00 ug/L
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
1,1-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
<1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
1,1-Dichloroethylene
< 1.00 ug/L
huns-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
Tetrachloroethylene
< 1.00 ug/L
Toluene
< 1.00 ug/L
1,1, 1 -Trichloroethane
<1.00 ug/L
1,1,2-Trichloroethane
< 1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Compounds
Acrolein
<50.0 ug/L
Acrylonitrile
<10.0 ug/L
I hereby certify that 1 have reviewed and approve these data.
(!.
Laboratory Representative
642 Tarnco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MERITECH, INC.
Environmental Laboratories
Laboratory Certification #185
Client: City of High Point Meritech iD#; 01191734tb
Project: IQ LTW Analysis: 01/24/17
Client Sample ID: Trip Blank Analyst: VWV
Sample Collection; O1/18/17 Dilution Factor: 1
Report Date: Ol/25/17
EPA 624 VOLATILE ORGANICS
Parameter
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoforrn
< 1.00 ug/L
Methyl Bromide
<5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlombenzene
< 1.00 ug/L
Chloroethane
<5.00 ug/L
2-Chloroethyl vinyl ether
<5.00 ug/L
Chloroform
< 1.00 ug/L
Methyl Chloride
< 5.00 ug/L
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
<1.00 ug/L
I,1-Dichloroethane
< 1.00 ug/L
1,2-Dichlomethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
1,1-Dichloroethylene
<1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
<1.00 ug/L,
cis-1,3-Dichloropropylene
<1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
Tetrachloroethylene
< 1.00 ug/L,
Toluene
< 1.00 ug/L
l,l,l-Trichloroethane
< 1.00 ug/L
1,1,2-Trichloroethane
<1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Compounds
Acrolein
<50.0 ug/L
Acrylonitrile
<I0.0 ug/L
1 hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tarnco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MERI TECH, INC.
Environmental Laboratories
Laboratory Certificate #165
Client:
City of High Point Meritech ID#:
01191734
Project:
IQ LIMP
Analysis:
O1/30/17
Client Sample ID:
ES Effluent
Extraction:
O1/23/17
Sample Collection:
01/18/17
Analyst:
PM
Dilution Factor:
I
EPA 625 SEMIVOLATILE ORGANICS
Parameter
Result
Parameter
Result
Acenaphthene
<10 ug/L
Fluoranthene
<10 ug/L
Acenaphthylene
<10 ug/L
Fluorene
<10 ug/L
Anthracene
<10 ug/L
Hexachlorobenzene
<10 ug/L
Benzidine
<50 ng/L
Hexachlorobutadiene
<10 ug/L
Benzo(a)anthracene
<10 ug/L
Hexachlorocyclopentadiene
<50 ug/L
Benzo(a)pyrene
<10 ug/L
Hexachloroethane .
<10 ug/L
Benzo(b)fluoranthene
<10 ug/L
Indeno(1,2,3-cd)pyrene
<10 ug/L
Benzo(k)fluoranthene
<10 ug/L
Isophorone
<10 ug/L
Benzo(g,h,i)perylene
<10 ug/L
2-Methylnaphthalene
<10 ug/L
Benzyl butyl phthalate
<10 ug/L
Naphthalene
<10 ug/L
Bis(2-chloroethoxy)methane
<10 ug/L
Nitrobenzene
<10 ug/L
Bis(2-chloroethyl)ether
<10 ug/L
N-Nitrosod methylamine
<10 ug/L
Bis(2-chloroisopropyl)ether
<10 ug/L
N-Nitrosodi-n-propylanilne
<10 ug/L
Bis(2_ethylhexyl)phthalate
<10 ug/L
N-Nitrosodiphenylamine
<10 ug/L
4-Bromophenyl phenyl ether
<10 ug/L
Phenanthrene
<10 ug/L
2-Chlomnaphthalene
<10 ug/L
Pyrene
<10 ug/L
4-Chlorophenyl phenyl ether
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
Chrysene
<10 ug/L
Dibenzo(ah)enthracene
<10 ug/L
4-Chloro-3-methylphenol
<10 ug/L
I,2-Dichlorobenzene
<10 ug/L
2-Chlorophenol
<10 ug/L
1,3-Dichlorobenzene
<10 ugIL
2,4-Dichlorophenol
<10 ug/L
1,4-Dichlorobenzene
<10 ug/L
2,4-Dimethylphenol
<10 ug/L
3,3'-Dichlorobenzidine
<50 ug/L
2,4-Dinitrophenol
<50 ug/L
Diethyl phthalate
<10 ug/L
4,6-Dinitro-2-methylplrenol
<50 ug/L
Dlmethyl phthalate
<10 ug/L
2-Nitrophenol
<10 ug/L
Di-n-butyl phthalate
<10 ug/L
4-N'nrophenol
<50 ug/L
2,4-Dinitrotoluene
<10 ug/L
Pentachlorophenol
<50 ug/L
2,6-Dinitrotoluene
<10 ug/L
Phenol
<10 ug/L
Di-n-octyl phthalate
<10 ug/L
2,4,6-Trichlorophenol
<10 ug/L
1,2-Diphenylhydmzine
<10 ug/L
I hereby certify that I have reviewed and approve these data. 4, 1y�
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MERITECH, INC.
Environmental Laboratories
Laboratory Certification #165
Client City of High Point Meritech lID#: 01191736
Project: 1 Q LTMP Analysis: O1/24/17
Client Sample ID: WestsideEBluent Analyst: VWV
Sample Collection: 01/18/17 Dilution Factor. 1
Report Date: O1/25/17
EPA 624 VOLATILE ORGANICS
arameter
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
<1.00 ug/L
Bromoform
< 1.00 ug/L
Methyl Bromide
<5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
<5.00 ug/L
2-Chloroethyl vinyl ether
<5.00 ug/L
Chloroform
< 1.00 ug/L
Methyl Chloride
<5.00 ug/L
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
1,1-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
I,1-Dichloroethylene
<1.00ug/L
trans-1,2-Dichloroethylene
< 1.00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
<1.00 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug7L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
<1.00 ug/L
Tetrachloroethylene
< 1.00 ug/L
Toluene
< 1.00 ug/L
1,1,1-Trichloroethane
< 1.00 ug/L
1,1,2-Trichloroethane
< 1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Compounds
Acrolein
<50.0 ug/L
Acrylonitrile
<I0.0 ug/L
I hereby certify that I have reviewed and approve these data.
k.
&=9
Laboratory Representative
642 Tamco Road " Reidsville, NC 27320
[phone] Ph " [phone] Fax

MERITECH, INC.
Environmental Laboratories
'
Laboratory Certificate #165
Client:
City of High Point Meritech ID#: 01191736
Project:
IQ LTMP Analysis: 01/30/17
Client Sample ID:
WS Effluent Extraction: 01/23/17
Sample Collection:
O1118/17 Analyst: PM
Dilution Factor: I
EPA 625 SEMIVOLATILE ORGANICS
Parameter
Result
Parameter
Result
Acenaphthene
<10 ug/L
Fluoranthene
<10 ugtL
Acenaphthylene
<10 ug/L
Fluorene
<10 ug/L.
Anthracene
<10 ug/L
Hexachlorobenzene
<10 ug/L
Benzidine
<50 ug/L
Hexachlorobutadiene
<10 ug/L
Benzo(a)anthracene
<10 ug/L
Hexachlorocyclopentadiene
<50 ug/L
Benzo(a)pyrene
<10 ug/L
Hexachloroethane
<10 ug/L
Benzo(b)fluoranthene
<10 ug/L
Indeno(1,2,3-cd)pyrene
<10 ug/L
Benzo(k)flucranthene
<10 ug/L
Isophorone
<10 ug/L
Benzo(g,h,i)perylene
<10 ug/L
2-Methylnaphthalene
<10 ugIL
Benzyl butyl phthalate
<10 ug/L
Naphthalene
<10 ug/L
Bis(2•chloroethoxy)methane
<10 ug/L
Nitrobenzene
<10 ug/L
Bis(2-chloroethyl)ether
<10 ug/L
N-Nitrosodimethylamine
<10 ug/L
Bis(2-chloroisopropyl)ether
<10 ug/L
N-Nitrosodi-n-propylamine
<10 ug/L
Bis(2-ethylbexyl)phthalate
19.7 ug/L
N-Nitrosodiphenylamine
<10 ug/L
4-Bromophenyl phenyl ether
<10 ug/L
Phenanthrene
<10 ug/L
2-Chloronaphthalene
<10 ug/L
Pyrene
<10 ug/L
4-Chlorophenylphenyl ether
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
Chrysene
<10 ug/L
Dibenzo(a,h)anthrecene
<10 ug/L
4-Chloro-3-methylphenol
<10 ug/L
1,2-Dichlorobenzene
<10 ug/L
2-Chlorophenol
<10 ug/L
1,3-Dichlorobenzene
<10 ug/L
2,4-Dichlorophenol
<10 ug/L
1,4-Dicblorobenzene
<10 ug/L
2,4-Dirnethylphenol
<10 ug/L
3,T-Dichlorobenzldine
<50 ug/L
2,4-Dinitrophenol
<50 ug/L
Diethyl phthalate
<10 ug/L
4,6-Dinitro-2-methylphenol
<50 ug/L
Dimethyl phthalate
<10 ug/L
2-Nitrophenol
<10 ug/L
Di-n-butyl phthalate
<10 ug/L
4-Nitrophenol
<50 ug/L
2,4-Dinitrotoluene
<10 ug/L
Pentachlorophenol
<50 ug/L
2,6-Dinitrotoluene
<10 ug/L
Phenol
<10 ug/L
Di-n-octyl phthalate
<10 ug/L
2,4,6-Trichlorophenol
<10 ug/L
1,2-Dipheny1hydrazine
<10 ug/L
I hereby certify that I have reviewed and approve these data. b. 9c,
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

Chain of Custody Record (COC)
NPDES#:
,aroma
1
Client: Cj+l4 PC)
MERITECH, INC.
Address:
PC <eX a--1LJI Faxne:
ENVIRONMENTAL LABORATORIES
1-AIA
PL^try{ , We - ;Ylae 1 Email:
642 TamcoRd. Phone: [phone]
Project: J
Cp L11yt P
Reidsville NC 27320 Fax: [phone]
P.O.#:
Email: [e-mail]
Attention:
LCUL*It Me�VLL�
Turn Around Time*
How would you like your report sent? 'RUSH
work needs prior approval.
www.meritech-labs.com
Circle all that apply: E ail(pret 'd), Fax, Mail Std 0
) 33 5Daays Z
.Sampling Dates & Times
Person Takingsaitplign/PrDnt>.
Lab Use Only,
Sample Location and/or ID #
Start
End
Comp ,
ifdf
Test(s) Required
ce?
No
pH 01C?
;-
Date
Time
Date
Time
Grab.
Cont.
es
CI OK.
At�iSIDE E FLL av
--
'llol,
°a3 7
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1=�.STSiDE f':FFLUEnIT
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tllg�ll
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Cs{;Cr,at, pbi TTl'AJ$gib;P5�"tl
3 j
�STSiDS
EFFLLA&NT'
FlEitS1DE
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t/19/Il
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loos
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EfA I<25/
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wtsTsinc
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Vis 1'l
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I/ia/iI
Gfil
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D1` LLVED sCul�S
Temperature. Upon
Dechlorination
(<0-5
m) of Ammonia, Cyanide,
Phenol
and TKN
samples must be done in the field prior to reservation.
Method of
Comments:
Composftor#-
Shipment:
Jug # ..
UPS
Fed Ex
Are a resul for regulatory purposes? Yes
-iin
No
Report results in: mg/L a
mg/kg a ug/L
Hand Delive
i i 71me:
: 0
d J s12�/
Date:
Ti SD
Other
i
Received by:
Date:
Time:
R by is
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Relinquished by: Date: Time:

-ZjA. cq0eljs
SamplelD Analyte Mean
AutozeroRead------- -------------- ------- — —
Zn 213.86 ], rarirrtd rlQjdq 1$'
CVB---- ----- ------------ ----- ---�------_ UC},�f1t%
Zn 213.86
High Standard
Mid Standard
Low Standard
Zn 213.86 [1.000] mg/L k,
1, `Q.6
Zn 213.86 10.5001 mg/L
Zn 213.86 [0.025] mg/L
0.50 ppm CCV
3/2/2018 11:04:49AM All aualyte(s) passed QC.
Zn 213.86 0.5 mg/L
3=018 11:04:49AM QC value within limits for Zn 213.86 Recovery = 98.520/6
CVB
3R/2018 11:05:40AM All analyte(s) passed QC.
Zn 213.86 0.0 mg/L
3/2/2018 11:05:40AM QC value within limits for Za 213.86 Recovery = Not calculated
OSS Oct 2017
Zn 213.86 0.430 mg/L
Lab Rea at Blank
5- \ 116 030:2As u
7o 213.86 O.O1K.m¢/L * (p
Lab Fort Blk 90/10 5� - ` � —
Zn 213.86 0.511 mg/L 0
Westside Effluent 2-12-18 v1 = ]. 02Z Ind n OlL
WS Eff LFM "All 5�a 2-12
WS Eff LFM 90110 dup W
Westside Effluent 2-14-18
Ingleside Outfall #1
Ingleside Outfall #2
Ingleside Outfall #3
Zn 213.86
Zn 213.86
Zn 213.86
0.170 mg/L r p, 17 0
0.533 mg/L
'L Ya ,
Zn 213.86 0.062mg/L
Zn 213.86 0.061 mg/L = 0, U (p
Zn 213.86 0.099 mg/L - v, 0
Zn 213.86 0.033 mg/L % 0.03

1
SamplelD Analyte Mean
0.50 ppm CCV
3/2/2018 11:14:23AM All analyte(s) passed QC.
�r i�-::isi,►.! 1�: �.-_ems-_�: itt: __._.__.._ ��
't c
Zn 213.$6 0.5 mg/L
3/2/2018 11:14:23AM QC value within limits for Zn 213.86 Recovery = 99.89%
CVB
3/2/2018 11:15:14AM All analyte(s) passed QC.
Zn 213.86 0.0 mg/L d.
3/2/2418 11:15:14AM QC value within limits for Zn 213.86 Recovery = Not calculated
InglesideUutfall #4 -------------- ------------------------- -------___--__---------- —------ ----------- ------------
Zn 213.86 0.069 mg/L s 0 7
KV Pump Station 2-19-18
Zn 213.86 0.021 mg/L ()� 0-15
KV PS LFM 90/10 5
Zn 213.86 0.509 mg/L KV PS LFM 90/10 dup 5�jlob%
A,,�I2� 1
Zn 213.86 0.510 mg/L �) a rU
Reagent Blank-_-_--_�_____________________�___-_1xa ��� ____lea `�u 2--
Lab
REIZUK) Zn 213.86 0.010 mg/L — 0.
n cn nv%m rry --- - - - w ��-- ---------- -- -
3/2/2018 11:20:02AM All analyte(s) passed QC.
Zn 213.86 0.5 mg/L
3/2/2018 11:20:02AM QC value within limits for Zn 213.86 Recovery = 102.49% V
rv1 --
.....---------------
3/2/2018 11:20:53AM All analyte(s) passed QC.
Z-UUS,
Zn 213.86 0.0 mg/L
3/2/2018 11:20:53AM QC value within limits for Zn 213.86 Recovery = Not calculated

Method: Zn Method Page i 16 Date: 3/2/2018 11:02:48 AM
Sequence No.: 1 Autosampler Location:
Sample ID: AutozeroRead Date Collected: 3/2/2018 11:00:17 AM
,Analyst: Data Type: Original
--------- ------ ------------- ------------------------------ --------------f------- ------
Replicate Data: Data: AutozeroRead o Anaayte: Zn 213.86
Repl SampleConc StndConc B1nkC rr Time Signal
# mg/L mg/L Signal Stored 7 reviewed bY:
1 [0.001 0.011 11:00:18 AM Yes
Auto -zero performed.
Analysis Begun
Logged In Analyst: Administrator Technique: AA Flame
Spectrometer: AAnalyst 400, SIN 201S14081701 Autosampler: AS-93plus
Sample Information File: C:\Users\Public\PerkinElmer\AA\Data\Sample Information\SampleList.sif
Batch ID:
Results Data Set: Zn030218a
Results Library: C:\Users\Public\PerkinElmer\AA\Data\Results\Results.mdb
�.'Zar."...C^-•^C==� CCS�^-- �^-- .-..-.=Cc.^�C �9�' �� C -.-^- �C^^`��-"'""...CCCC�-L•'�".-'C=-�-'"'.C=CCG=S.."C=BLS.
Sequence No.: 1 Autosampler Location: 1
Sample ID: CVB Date Collected: 3/2/2018 11:00:32 AM
Analyst: Data Type: Original
----------------------------------------------------------
Replicate Data: CVB
Analyte:
Repl SampleConc StndConc
B1nkCorr
Time Signal
# mg/L mg/L
Signal
Stored
1 [0.001
0.247
11:00:53 AM Yes
2 [0.001
0.245
11:00:57 AM Yes
3 [0.001
0.250
11:01:01 AM Yes
Mean: (0.00]
0.247
SD: 0.0000
0.0027
%RSD: 0.00%
1.08
Auto -zero performed.
Zn 213.86
Sequence No.: 2 Autosampler Location: 2
Sample ID: High Standard Date Collected: 3/2/2018 11:01:22 AM
Analyst: Data Type: Original
Replicate Data: High Standard
Repl SampleConc StndConc B1nkCorr
# mg/L
mg/L
Signal
1
(1.000]
0.285
2
[1.0001
0.292
3
[1.000]
0.293
Mean:
[1.000]
0.290
SD:
0.00000
0.0041
%RSD:
0.00%
1.40
000
•Analyte: Zn 213.86
Time Signal
Stored
11:01:43 AM Yes
11:01:48 AM Yes
11:01:52 AM Yes
Standard number 1 applied. [1. 1
Correlation Coef.: 1.000000 Slope: 0.28989 Intercept: 0.00000
Sequence No.: 3
Sample ID: Mid Standard
Analyst:
Autosampler Location: 3
Date Collected: 3/2/2018
Data Type: Original
-------------------------------------------------------------------------
Replicate Data: Mid Standard
Analyte: Zn 213.86
Repl SampleConc
StndConc
B1nkCorr
Time Signal
# mg/L
mg/L
Signal
Stored
1
[0.5001
0.148
11:02:35 AM Yes
2
[0.5001
0.151
11:02:39 AM Yes
3
[0.5001
0.151
11:02:43 AM Yes
Mean:
[0.5001
0.150
11:02:13 AM

in
Method: Zn Method Page 05 Date: 3/2/2018 11:03:57 AM
SD: 0.00000 0.0019
%RSD: 0.00% 1.27
Standard number 2 applied. [0.500]
Correlation Coef.: ].'000000 Slope: 0.31093 Intercept: 0.00000
Sequence No.: 4 Autosampler Location: 4
Sample ID: Low Standard Date Collected: 3/2/2018 11:03:05 AM
Analyst: Data Type: Original
------------------------------------------------------------------------------•----------------------
Replicate Data: Low Standard
Analyte:
Zn 213.86
Repl SampleConc
StndConc BlnkCorr Time
Signal
# mg/L
mg/L Signal
StoredC-
1
[0.025] O.008
11:03:27 AM Yes
' `` ��'"`_. _ __ c•: ..__`�...
2
[0.0251 0.007
11 :03:31 AM Yes
:` «.•ir�; h� - -
3
(0.0251 0.009
11: 03 : 36 AM Yes
Mean:
[0.025] 0.008
SD:
0.00000 0.0009
%RSD:
0.00% 10.82
Standard number 3
applied. :0.0251
Correlation Coef.:
1.000000 Slope:
0.33057
Intercept:
0.00000
- ---------------------------------------------------------------------------------------------------
Calibration data for.Zn 213.86
Equation: Nonlinear Through Zero
Entered
Calculated
Mean Signal
Conc.
Conc. Standard
ID
(Abs)
mg/L
mg/L Deviation
$RSD
CVB
0.000
0
0.000
0.00
1.08
High Standard
0.290
1.000
1.000
0.00
1.40 ✓
Mid Standard
0.150
0.500
0.500
0.00
1.27
Low Standard
0.008
0.025
0.025
0.00
10.82
Correlation Coef-.:
1.00000O V' Slope:
0.33057
Intercept:
0.00000

U
Method: Zn Method
Page` Date: 3/2/2018 11:07:10 AM
Analysis Begun
�, 11`I'ji; �Y,•�� Ili,. G��_-�,�_ .'.t, �_._ :....._..
Logged In Analyst:
Administrator
Technique: AA Flame
Spectrometer: AAnalyst
400,
SIN 201S14081701 Autosampler: AS-93plus
Sample Information
File: C:\Users\Public\PerkinElmer\AA\Data\Sample Information\SampleList.sif
Batch ID:
Results Data Set:
Zn030218a
Results Library: C:\Users\Public\PerkinElmer\AA\Data\Results\Results.mdb
==caca..a.. �caaaa==a- r_a..aa=_�.o-___a_-_= ssscac====aacccc=ac
Autosampler Location: 3
-asaaa==aaaacc-aaaasac====cacccaa===ccc
Sequence No.: 1
Sample ID: 0.50 ppm CCV
Date Collected: 3/2/2018 11:04:15 AM
Analyst:
Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate Data: 0.50
ppm CCV
Analyte: Zn 213.86
Repl SampleConc
StndConc
B1nkCorr
Time Signal
# mg/L
mg/L
Signal
Stored
1 0.486
0.486
0.146
11:04:36 A-M Yes
2 0.496
0.496
0.149
11:04:40 AM Yes
3 0.496
0.496
0.149
11:C4:45 AM Yes
Mean: 0.493
0.493
0.148
SD: 0.0058
0.0058
0.0017
%RSD: 1.19%
1.19%
1.13
QC value within
limits for
Zn 213.86
Recovery = 98.52% �
All analyte (s) passed
QC.
Autosampler Location: 1
Sequence No.: 2
Sample ID: CVB
Date Collected: 3/2/2018 11:05:06 AM
Analyst:
Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate Data: CVB
Analyte: Zn 213.86
Repl SampleConc
StndConc
B1nkCorr
Time Signal
# mg/L
mg/L
Signal
Stored
1 0.010
0.010
0.003
11:05:27 AM Yes
2 0.007
0.007
0.002
11:05:31 AM Yes
3 0.013
0.013
0.004
11:05:35 AM Yes
Mean: 0.010
0.010
0.003
SD: 0.0031
0.0031
0.0010
%RSD: 30.80%
30.80%
30.69
QC value within
limits for
Zn 213.86
Recovery = Not calculated
All analyte(s) passed
QC.
Autosampler Location: 9
Sequence No.: 3
Sample ID: OSS Oct
2017
Date Collected: 3/2/2018 12:05:56 AM
Analyst:
Data Type: Original
-----------------------------------------------------------------------------------------------------
Replicate Data: OSS
Oct 2017
Analyte: Zn 213.B6
Repl SampleConc
StndConc
B1nkCorr
Time Signal
# mg/L
mg/L
Signal
Stored
1 0.416
0.416
0.126
11:06:18 AM Yes
2 0.444
0.444
0.134
11:06:22 AM Yes
Mean: 0.430
0.430
0.130
SD: 0.0193
0.0193
0.0055
%RSD: 4.49%
4.49%
4.27
4 1U
Sequence No.: 4
Autosampler Location: 10
Sample ID: Lab Reagent Blank
Date Collected: 3/2/2018 11:06:44 AM
Analyst:
Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate Data: Lab Reagent Blank
Analyte: Zn 213.86
Repl SampleConc
StndConc
B1nkCorr
Time Signal
# mg/L
mg/L
Signal
Stored

Zn
11:11:09 AM
1
2
0. 015
0.
0.015
0.005
11: 07:06 AM Yes
• �akuc nat leLssn
Mean:
0.016
0.016
0.005
7:10 AM Yes
SI'2 ltjw 57 `( �GO,UIZS
SD:
0.0012
0.0012
0.0004
,
$RSD:
7.75%
7.75%
7.70
/(6
Mfg
=�L
Sequence No. 5Autosampler
Location 11
Sample
ID: Lab Fort.
Blk 90/10 50%
Date Collected: 3/2/2018 11:07:32 AM
Analyst:
-Z�
Data Type: Original
___________________________________________________________________________________ _
Replicate Data: Lab Fort. Blk 90/10 5� Analyte: Zn 213.86 ( J
S ��� Jy
Repl
SampleConc
StndConc
H1iilcCorr
Time Signal :`I::'4 d'."S ;;; .: .-
#
mg/L
mg/L
Signal
Stored
1
0.511
0.511
0.153
11:07:54 AM Yes--_- - _, -----
2
0.512
0.512
0.153
11:07:58 AM Yes
Mean:
SD:
0.511
0.0005
0.511
0.0005
0.153,
0.002
$RSD:
0.11$
0.11$
0.10
/, oax/ I.w f xiav = loa sec.
x a -
Sequence No.: 6
Autoaampler Location: 12
Sample
ID: Westside Effluent
2-12-18
Date Collected: 3/2/2018 11:08:20 AM
Analyst:
Data Type: Original
____________________________________________________________________________________________________
Replicate Data: Westside
Effluent 2-12-18 Analyte: Zn 213.86
Repl
SampleConc
StndConc
B1nkCorr
Time Signal
#
mg/L
mg/L
Signal
Stored
1
0.199
0.199
0.062
11:08:42 AM Yes
2
0.141
0.141
0.045
11:08:47 AM Yes
Mean:
0.170
0.170
0.053
$RSD:
24.34%
24.34%
23.486
,, n jj
�WLC LF� (t7•i�o)(o•�I)i-j_U'
Sequence No.: 7
Autosampler Location: 13
Sample
ID: WS Eff
LFM 90/10
50% 2-12
Date Collected: 3/2/2018 11:09:09
AM
Analyst:
%
Data Type: Original
_______________________________________________________________________________________
Replicate Data: WS Eff LFM 90/10 50%
2-12 Analyte: Zn 213.86
Repl
SampleConc
StndConc
B1nkCorr
Time Signal
#
mg/L
mg/L
Signal
Stored
1
0.542
0.542
0.162
11:09:31 AM Yes
2
0.543
0.543
0.162
11:09:35 AM Yes
Mean:
$RSD:
0.5430A
0.19%
0.543
0.19$0
0.162
0.
0.1803
C 2
/• 09'6 / I. 5 J `F i�0'
xa-
I, ow,
Sequence No.: 8
Autosampler Location: 14
Sample ID: WS Eff
LFM 90/10 dup 5iA
Date Collected: 3/2/2018
11:09:58 AM
Analyst:
:a-�
Data Type: Original
___________________________________
_____________
______________-___-____
____
Replicate Data: WS
Eff LFM 90/10 dup 50%
Analyte: Zn 213.06
Repl SampleConc
StndConc B1nkCorr
Time Signal
# mg/L
mg/L Signal
Stored
1 0.528
0.528 0.158
11:10:18 AM Yes
2 0.539
0.539 0.161
11:10:23 AM Yes
Mean: 0.533
SD: 0.0073�
0.533 0.160
.0073 0.0021
�1
X woi
$RSD: 1.37$
1.37$ 1.30
0• R-x(.V �'_o
Sequence No.: 9
Autosampler Location: 15
Sample ID: Westside Effluent 2-14-18
Date Collected: 3/2/2018
11:10:44 AM
Analyst:
Data Type: Original

Method: Zn Method Page 4-7 Date: 3/2/2018 11:14:40 AM
Replicate Data: Westside Effluent 2-14-18 Analyte: Zn
213.86
Repl
SampleConc
StndConc
B1nkCorr
Time Signal
#
mg/L
mg/L
Signal
Stored
1
0.058
0.058
0.019
11:11:04 AM Yes
���� �;jj101
�'
2
0.065
0.065
0.021
11:11:09 AM Yes
i'r ?•�,:%' ;,°: • _
Mean:
0.062
0.062
0.020
t.
SD:
0.0048
0.0048
0.0015-
%RSD:
7.69%
7.69%
7.55
-.._.-... a_._..-.____....aa�aac_-'-------_�._.-...__�---_....-__-.-.==aa=aaa-_--=---_...-.....___._---._a•-_-•-.�----,-.-..-...�_..__======as
Sequence No,: 10 Autosampler Location: 16
Sample ID: Ingleside Outfall #1 Date Collected: 3/2/2018 11:11:30 AM
Analyst: Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate Data: Ingleside Outfall #1 Analyte: Zn 213.86
Repl SampleConc StndConc B1nkCorr Time Signal
# mg/L mg/L Signal Stored
1 0.054 0.054 0.018 11:1-1:51 AM Yes
2 0.068 0.069, 0.022 11:11:55 AM Yes
Mean: 0.061 0.061 0.020
SD: 0.0096 0.0096 0.0030
%RSD: 15.65% 15.65% 15.36
���--�-.��a�aas�^-_� ��s3CGc�c��=�a=��-_-.-��.���C��-_.-.�_ �csaa�....--•_•...............'3C��--_=���a�ac�.:.�==-�•--..--..--.._. �..--.._..-..--••--•�
Sequence No.: 11 Autosampler Location: 17
Sample ID: Ingleside Outfall #2 Date Collected: 3/2/2018 11:12:17 AM
Analyst: Data Type: Original
---------------------------------------------------------------------------------------------------
Replicate Data: Ingleside Outfall #2 Analyte: Zn 213.86
Repl SampleConc StndConc B1nkCorr Time Signal
# mg/L mg/L Signal Stored
1 0.097 0.097 0.031 11:12:37 AM Yes
2 0.101 0.101 0.032 11:12:42 AM Yes
Mean: 0.099 0.099 0.032
SD: 0.0030 0.0030 0.0009
%RSD: 3.07% 3.07% 2.99
Sequence No.: 12 Autosampler Location: 18
Sample ID: Ingleside Outfall ##3 Date Collected: 3/2/2018 11:13:03 AM
Analyst: Data Type: Original
--------------------------------------------------------------------------- -------------------------
Replicate Data: Ingleside Outfall #3 Analyte: Zn 213.86
Repl SampleConc StndConc B1nkCorr Time Signal
# mg/L mg/L Signal Stored
1 0.028 0.028 0.009 11:13:23 AM Yes
2 0.037 0.037 0.012 11:13:28 AM Yes
Mean: 0.033 0.033 0.011
SD: 0.0066 0.0066 D.0021
%RSD: 19.96% 19.96% 19.74
Sequence No.: 13 Autosampler Location: 3
Sample ID: 0.50 ppm CCV Date Collected: 3/2/2018 11:13:49 AM
Analyst: Data Type: Original
------------------------------------------------------------------------------------------------------
Replicate Data: 0.50 ppm CCV
Analyte:
Zn 213.86
Repl
SampleConc
StndConc
B1nkCorr
Time
Signal
#
mg/L
mg/L
Signal
Stored
1
0.497
0.497
0.149
11:14:10 AM
Yes
2
0.501
0.501
0.150
11:14:14 AM
Yes
3
0.500
0.500
0.150
11:14:19 AM
Yes
Mean:
0.499
0.499
0.150
SD:
0.0018
0.0018
0.0005
%RSD:
0.35%
0.35%
0.33
/
QC
value within
limits for Zn 213.86
Recovery =
99.89%
All analyte(s) passed QC.

Method: Zn Method Pa eDate: 3/2/2018 11:18:18 AM
Sequence No.: 14 Autosampler Location: 1
Sample ID: CVB Date Collected: 3/2/2018 11:14:40 AM
Analyst: Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate Data: CVB
Analyte: Zn 213.86
Repl
#
SampleConc
mg/L
StndConc
mg/L
B1nkCorr
Signal
Time
Signal
Stored
'!�j �} ! :)
1
0.010
0.010
0.003
11:15:01 AM
Yes
2
0.004
0.004
0.001
11:15 : 05 AM
Yes'
fi;i��,i; .� �'� "; ':::�':.:-_•:.:.:. --:.
3
0.012
0.012
0.004
11:15:09 AM
Yes
�� �T =
Mean:
0.009
0.009
0.003
SD:
0.0041
0.0041
0.0013
%RSD:
46.60%
46.60%
46.50
QC
value within
limits for
Zn 213.86
Recovery -
Not calculated
All analyte(s) passed QC.
--------=_____------
Sequence No.: 15 Autosampler Location: 19
Sample ID: Ingleside Outfall #4 Date Collected: 3/2/2018 11:15:30 AM
Analyst: Data Type: Original
----------------------------- -----------------------------------------------------------------------
Replicate Data: Ingleside Outfall #4 Analyte: Zn 213.86
Repl SampleConc StndConc B1nkCorr Time Signal
# mg/L mg/L Signal Stored
1 0.065 0.065 0.021 11:15:51 AM Yes
2 0.073 0.073 0.023 11:15:56 AM Yes
Mean: 0.069 0.069 0.022
SD: 0.0051 0.0051 0.0016
%RSD: 7.39% 7.39% 7.24
Sequence No.: 16 Autosampler Location: 20
Sample ID: KV Pump Station 2-19-18 Date Collected: 3/2/2018 11:16:17 AM
Analyst: Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate Data: KV Pump Station 2-19-18 Analyte: Zn 213.86
Repl SampleConc StndConc B1nkCorr Time Signal
# mg/L mg/L Signal Stored
1 0.014 0.014 0.005 11:16:38 AM Yes
2 0.028 0.028 0.009 11:16:43 AM Yes
Mean: 0.021 0.021 0.003 �-A I� h
%RSD: 47.36% 47.36% 47.043 Cake.. L1 (0V - 2•1 (O.q 4- 1. .0
_•�---_.�-.-______._____________caa. =_
Sequence No.: 17 Autosampler Location: 21
Sample ID: KV PS LFM 90/10 50% Date Collected: 3/2/2018 11:17:04 AM
Analyst: % Data Type: Original
-----------------------------------------------------------------------------------------------------
Replicate Data:
KV PS LFM 90/10 50%
Analyte: Zn 213.86
Repl
SampleConc StndConc B1nkCorr
Time Signal
#
mg/L
mg/L
Signal
Stored
1
0.498
0.498
0.149
11:17:26 AM Yes
2
0.519
0.519
0.155
11:17:30 AM Yes
Mean:
SD:
%RSD:
0.509-
2.97%
2.97$
0.509
2.0151
2.97$
0.152
2.0093
2.82
( V D l J i� V
]''yl�y /I ` G� X / 0 �U
LAj
xa-- f,a14�
Sequence No.: 18 Autosampler Location: 22 > gpY)
Sample ID: KV PS LFM 90/10 dup 50% Date Collected: 3/2/2018 11:17:52 AM
Analyst: Data Type: Original D, 3-.%
----------------------------------------------------------------------------------------------------
Replicate Data: KV PS LFM 90/10 dup 50% Analyte: Zn 213.86
Repl SampleConc StndConc B1nkCorr Time Signal
# mg/L mg/L Signal Stored

Method: Zn Method
Date: 3/2/2018 11:21:09 AM
1
0.506 0.506
0.152
11:18:13 AM Yes
2
0.514 0.514
0.154
11:18:18 AM Yes
Mean:
SD:
0.510 0.510
0.0050.0057
0.153
0.0016
V/VV) -
lsptll-otgq
10690 A
%RSD:
1.11% 1.11%
1.05
Sequence No.: 19
Autosampler Location: 10
Sample ID: Lab Reagent Blank
Date Collected: 3/2/2018 11:18:40 AM
Analyst: Pee ,ft)
Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate-------------- ----------------------------------------------------------------------------------------------------
Replicate-------------------------------------------------------------------------------------
Replicate Data: Lab Reagent Blank
Analyte: Zn 213.86
Repl
SampleConc StndConc
B1nkCorr
Time Signal
#
mg/L mg/L
Signal
Stored
O G
(� �
1
0.010 0.010
0.003
11:19:01 AM Yes g'teyie�Or
'J `l0
2
0.011 0.011
0.004
11:19:05 AM Yes �.
Mean:
0.010 0.010
0.003��
SD:
0.0007 0.0007
0.0002
%RSD:
7.23% 7.23%
7.20
Sequence No.: 20 Autosampler Location: 3
Sample ID: 0.50 ppm CCV Date Collected: 3/2/2018 11:19:27 AM
Analyst: Data Type: Original
-----------------------------------------------------------
Replicate Data: 0.50 ppm CCV
Analyte:
Repl
SampleConc
StndConc
B1nkCorr
Time
Signal
#
mg/L
mg/L
Signal
Stored
1
0.496
0.496
0.149
11:19:49 AM
Yes
2
0.521
0.521
0.156
11:19:53 AM
Yes
3
0.521
0.521
0.156
11:19:57 AM
Yes
Mean:
0.512
0.512
0.154
SD:
0.0147
0.0147
0.0042
%RSD:
2.86%
2.86%
2.72
QC
value within
limits for
Zn 213.86
Recovery =
102.49%
All analyte(s) passed QC.
Sequence No.: 21
Sample ID: CVB
Analyst:
-----------------------------------------
Zn 213.86
Autosampler Location: 1
Date Collected: 3/2/2018 11:20:19 AM
Data Type: Original
----------------------------------------------------------------------------------------------------
Replicate Data: CVB
Analyte: Zn 213.86
Repl
SampleConc
StndConc
B1nkCorr
Time
Signal
#
mg/L
mg/L
Signal
Stored
1
0.008
0.008
0.003
11:20:39 AN
Yes
2
0.018
0.018
0.006
11:20:44 AM
Yes
3
0.006
0.006
0.002
11:20:48 AM
Yes
Mean:
0.011
0.011
0.004
SD:
0.0066
0.0066
0.0022
%RSD:
61.70%
61.70%
61.43
QC
value within
limits for
Zn 213.86
Recovery =
Not calculated
All analyte(s) passed QC.

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
RECEIVED
MAY 01 2015
Public Services
Contact: Dawn Molnar Report Date: 4/29/2015
Client: High Point, City of
PO Box 230 Project: 2Q LTMP
High Point, NC 27261 Date Sample Rcvd: 4/16/2015
Meritech Work Order # 04161538 Sample: ES Influent Composite 4/13-14/15
Parameters
Result
Analysis Date
ReportingUmit
Method
Antimony, total
<25 ug/L
4/29/15
25
ug/L
EPA 200.7
Beryllium, total
<5 ug/L
4/29/15
5
ug/L
EPA 200.7
Mercury, total
<0.2 ug/L
4/17/15
0.2
ug/L
EPA 245.1
Thallium, total
<20 ug/L
4/29/15
20
ug/L
EPA 200.7
Meritech Work Order it
04161939 Sample:
ES Influent Grab
4/13/15
Parameters
Result
Analysis Date
Reporting Limit
Method
EPA 624+Trip Blank
Attached
4/22/15
624
EPA 625
Attached
4/24/15
625
Phenols, total
<10 ug/L
4/28/15
10
ug/L
EPA420.1
Merltech Work Order #
04161540 Sample: WS Influent Composite
4/13-14/15
Parameters
Resul
Analysis Date
ReportingLimit
ha
Antimony, total
<25
ug/L
4/29/15
25 ug/L
EPA 200.7
Beryllium, total
<5
ug/L
4/29/15
5 ug/L
EPA 200.7
Mercury, total
<0.2
ug/L
4/17/15
0.2 ug/L
EPA 245.1
Thallium, total
<20
ug/L
4/29/15
20 ug/L
EPA 200.7
Meritech Work Order # 04161541 Sample: WS Influent Grab 4/13/15
Parameters Result Analysis Date Reepm•tingUrnit Method
EPA 624+Trip Blank Attached 4/22/15
EPA 625 Attached 4/24/15
Phenols, total 70 ug/L 4/28/19 10 ug/L
1 hereby certify that 1 have reviewed and approve these data. !
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]
624
625
EPA 420.1

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Dawn Molnar
Client: High Point, City of
PO Box 230
High Point, NC 27261
Meritech Work Order # 04161542 Sample: ES Effluent Composite
RECEIVED
MAY 0 1 2015
Public Services
Report Date: 4/29/2015
Project: 2Q LTMP
Date Sample Rcvd: 4/16/2015
4/15-16/15
Parameters
Resul
Analysis Date
Reporting Limi
Method
Total Dissolved Solids
380 mg/L
4/21/15
10.0 mg/L
SM 2540C
Antimony, total
<25 ug/L
4/29/15
25 ug/L
EPA 200.7
Beryllium, total
<5 ug/L
4/29/15
5 ug/L
EPA 200.7
Thallium, total
<20 ug/L
4/29/15
20 ug/L
EPA 200.7
Meritech Work Order #
04161543 Sample:
ES Effluent Grab
4/15/15
Parameters
Result
Analysis Date
Reporting Linri
Method
EPA 624+Trip Blank
Attached
4/22/15
624
EPA 625
Attached
4/24/15
625
Phenols, total
<10 ug/L
4/28/15
10 ug/L
EPA 420.1
Meritech Work Order #
04161544 Sample:
WS Effluent Composite
4/15-16/15
Parameters
Result
Analysis Date
Reporting Lim!
Method
Total Dissolved Solids
912 mg/L
4/21/15
10.0 mg/L
SM 2540C
Antimony, total
<25 ug/L
4/29/15
25 ug/L
EPA 200.7
Beryllium, total
<5 ug/L
4/29/15
5 ug/L
EPA 200.7
Thallium, total
<20 ug/L
4/29/15
20 ug/L
EPA 200.7
Meritech Work Order #
04161545 Sample:
WS Effluent Grab
4/15/15
Parameters
Result
Analysis Date
ReportingL_ imit
Method
EPA 624+Trip Blank
Attached
4/22/15
624
EPA 625
Attached
4/24/15
625
Phenols, total
<10 ug/L
4/28/15
10 ug/L
EPA 420.1
1 hereby certify that 1 have reviewed and approve these data.
642 Tanico Road, Reidsville, North Carolina 27320
tel.[phone] fax. [phone]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
F- -
RECEIVED
Public Services
Contact: Dawn Molnar
Report Date:
4/29/2015
Client: High Point, City of
PO Box 230
Project:
2Q LTMP
High Point, NC 27261
Date Sample Rcvd:
4/16/2015
Meritech Work Order #
04161542 Sample: ES Effluent Composite
4/15-16/15
Parameters
Resul
Analysis Date
Reporting Lim!
Method
Total Dissolved Solids
380 mg/L
4/21/15
10.0 mg/L
SM 2540C
Antimony, total
<25 ug/L
4/29/15
25 ug/L
EPA 200.7
Beryllium, total
<5 ug/L
4/29/15
5 ug/L
EPA 200.7
Thallium, total
<20 ug/L
4/29/15
20 ug/L
EPA 200.7
Meritech Work Order #
04161543 Sample: ES Effluent Grab
4/15/15
Parameters
Resul
Analysis Date
Reportin Linii
Method
EPA 624+Trip Blank
Attached
4/22/15
624
EPA 625
Attached
4/24/15
625
Phenols, total
<10 ug/L
4/28/15
10 ug/L
EPA 420.1
Meritech Work Order #
04161544 Sample: WS Effluent Composite
4/15-16/15
Parameters
Result
Analysis Date
Reporting Lim!
Method
Total Dissolved Solids
912 mg/L
4/21/15
10.0 mg/L
SM 2540C
Antimony, total
<25 ug/L
4/29/15
25 ug/L
EPA 200.7
Beryllium, total
<5 ug/L
4/29/15
5 ug/L
EPA 200.7
Thallium, total
<20 ug/L
4/29/15
20 ug/L
EPA 200.7
Merltech Work Order it 04161545 Sample: WS Effluent Grab 4/15/15
Parameters Result Analysis Date ReuortingLimit Method
EPA 624+Trip Blank Attached 4/22/15 624
EPA 625 Attached 4/24/15 625
Phenols, total <10 ug/L 4/28/15 10 ug/L EPA420.1
I hereby certify that I have reviewed and approve these data.
642 Tanico Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

`
RITE "' INC.
Environmental Laboratories
Controls, Inc.
A Division of Water Technology and
r
Client:
City of High Point Meritecl:ID#: 04161543
Project:
2Q LTMP Analysis: 04/22/15
Client Sample ID:
ES Effluent Analyst: VWV
Sample Collection:
04/15/15 Dilution Factor: 1
Report Date: 04/27/15
EPA 624 VOLATILE ORGANICS
RECEIVED
MV 0 1 2015
Public Services
ramete
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromofonn
< 1.00 ug/L
Methyl Bromide
<5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
<5.00 ug/L
2-Chloroethyl vinyl ether
<5.00 ug/L
Chloroform
1.95 ug/L
Methyl Chloride
<5.00 ug/L
Cldorodibromomethane
< 1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
I,I-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
1,1-Dichloroethylone
< 1.00 ug/L
trans-1,2-Dichloroethyiene
< 1.00 ug/L
1,2-Dichioropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
<1.00 ug/L
hens-1,3-Dicliloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloroethane
< 1.00 ug/L
Tetrachloroethylene
<1.00 ug/L
Toluene
< 1.00 ug/L
1,1,1-Trichloroethane
< 1.00 ug/L
1,1,2-Trichloroethane
<1.00ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorolluoromethane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Compounds
Acrolein
<50.0 ug/L
Acrylonitrile
<10.0 ug/L
I hereby certify that 1 have reviewed and approve these data.
Laboratory Representative
642 Tatnco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MERITECH, INC.
_
Environmental Laboratories
°
x
A Division of Water Technology and Controls, Inc.
Client: City of High
Point Meritech ID#: 04161543tb
Project: 2Q LTMP
Analysis: 0422/15
Client Semple ID: Trip Blank
Analyst: VWV
Sample Collection: 04/15/15
Dilution Factor: 1
Report Date: 0427/15
EPA 624 VOLATILE ORGANICS
RECEIVED
MAY 0 1. 2015
Public Services
Parameter
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
Methyl Bromide
<5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
< 5.00 ug/L
2-Chlomethyl vinyl ether
<5.00 ug/L
Chloroform
< 1.00 ug/L
Methyl Chloride
<5.00 agfi,
Chlorodibromomethane
< 1.00 ug/L
1,2-Dibromoetltane
<1.00 ug/L
l,l-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
1,1-Dichloroethyleno
< 1.00 ug/L
bans-1,2-Dichloroethylene
< 1,00 ug/L
1,2-Dichloropropane
< 1.00 ug/L
cis.1,3-Dichloropropylene
< 1.00 ug/L
bans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetrachloro6thane
< 1.00 ug/L
Tetrachloroethylene
< 1.00 ug/L
Toluene
< 1.00 ug/L
l,l,l-Trcchooroethane
<1.00 ug/L
i,1,2-Trichloroethane
< 1.00 ug/L
Trichloroethylene
< 1.00 ug/L
Trichlorofluoromethane
<5.00 ug/L
Vinyl chloride
<5.00 ug/L
Additional Compounds
,
Acrolein
<50.0 ug/L
Acrylonitrile
I hereby that I have these data.
<I0.0 6g2
N3 GfG
certify reviewed and approve
Laboratory Representalive
642 Talnco Road " Reidsville, NC 27320
[phone] Ph' [phone] Fax

Client:
Project:
Client Sample ID:
Sample Collection:
Paramel
Acenaphthene
Acenaphthylene
Andnracene
Benzidine
Benzo(a)ardhraceue
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(g,h,i)perylene
Benzyl butyl phthalate
Bis(2ch loroelhoxy)methane
Bis(2-chloroelhyl)ether
B is(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
2-Chloronaplubalene
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,T-Dichlorobeuzidine
Diedryl phthalate
Dimedryl phthalete
Di-n-butyl pluhalale
2,4-13initrotoluene
2,6-Dinitrotoluene
Di-n-oc(yl phthalate
1,2-D Iphenylhydmzine
MERITECH, INC.
Environmental Laboratories
Laboratory Certificate #166
City of High Point Meritech ID#: 04161543
2Q LTMP Analysis: 04/24/15
ES Effluent Cxtracttolu 04/20/15
04/15/15
Analyst: PM
Dilution Factor: 1
EPA 625 SEMIVOLATILE ORGANICS
,
Result Fararucte Result
<10 ug/L
Fluorantheno
<10 ug/L
<10 ug/L
Fiuorene
<10 ug/L
<10 ug/L
Hexacidorobenzene
<10 ug/L
<50 ug/L
Hexachlorobutadiene
<10 ug/L
<10 ug2
Hexacldorocyclopentadiene
<50 ug/L
<10 ng/L
Hexacldoroethane -
<10 ug/L
<10 ug/L
1ndeno(1,2,3-ed)pyrcne
<10 ug/L
<10 ug/L
Isophorone
<10 ug/L
<I0 ug/L
2-Methyinaphthalene
- <10 ug/L
<10 ng/L
Naphthalene
<10 ug/L
<10 ug/L
Nitrobenzene
<10 ug/L
<10 ug/L
N-Nilrosodimelhylamine
<10 ug/L
<10 ug/L
N-Nitrosodi-n-propylamine
<10 ug/L
<10 ug/L
N-Nitrosodlphenylamine
<10 uglL
<I0 ug/L
Phenanthrene
<10 ug/L
<10 uglL
Pyrene
<10 ug/L
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
<I0 ug/L
<10 ug/L
4-Chloro-3-methylphenol
- <10 ug/L
<10 ug/L
2-Chloroplrenol
<10 ug/L
<10 ug/L
2,4-Dichlorophenol
<10 ug/L
<10 ug/L
2,4-Dinnethylphenol
<10 ug/L
<50 ug/L
2,4-Dinlirophenol
<50 ug/L
<10 ug/L
4,6-Dinilro-2-methylphenol
<50 ug/L
<10 ug/L
2-Nitrophenol
<10 ug/L
<10 ug/L
4-Nitrophenol
<50 ug/L
<10 ug/L
Pentachlorophenol
<50 ug/L
<10 ug/L
Phenol
<10 ug/L
<10 ug/L
2,4,6-Trichlorophenol
<10 ug/L
<10 ug/L
t hereby certify that 1 have reviewed and approve these data.
t4, VC
- Laboratory Representative
642 Tatnco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax
RECEIVED
MAY 0 1 2015
Public Services

MERI TECH, INC.
Environmental Laboratories
A Division of Water Technology and Controls, Inc.
Client: City of High Point Meritech IDM: 04161545
Project: 2Q LTMP Analysis: 04/22/15
Client Sample ID: WSEffluent Analyst: VWV
Sample Collection: 04/15/15 Dilution Factor: 10
Report Date: 04/27/15
EPA 624 VOLATILE ORGANICS_
RECEIVED
MAY 0 1 2015
Public Services
Poramete
Result
Benzene
< 10.0 ug/L
Dichlorobromomethane
< 10.0 ug/L
Bromofonn
< 10.0 ug/L
Methyl Bromide
<50.0 ug/L
Carbon Tetrachloride
< 10.0 ug/L
Chlorobenzene
< 10.0 ug/L
Chloroethane
< 50.0 ug/L
2-Chloroethyl vinyl ether
<50.0 ug/L
Chloroform
< 10.0 ug/L
Methyl Chloride
< 50.0 ug/L
Chlorodibromomethane
< 10.0 ug/L
1,2-Dibromoethane
< 10.0 ug/L
I,I-Dichloroelhane
< 10.0 ug/L
1,2-Dichloroethane
< 10.0 ug/L
1,4-Dichlorobenzene
< 10.0 ug/L
1,2-Dichlorobenzene
< 10.0 ug/L
1,3-Dichlorobenzene
< 10.0 ug/L
1, 1 -Dichloroethyleno
<10.Oug/L
trans-1,2-Dichloroethylene
< 10.0 ug/L
1,2-Dichloropropane
< 10.0 ug/L
cis-1,3-Dichloropropylend
< 10.0 ug/L
trans-1,3-Dichloropropylene
< 10.0 ug/L
Ethyl benzene
< 10.0 ug/L
Methylene chloride
< 10.0 ug/L
1,1,2,2-Tetrachloroethane
<10.0ug/L
Tetrachloroethylene
< 10.0 ug/L
Toluene
< 10.0 ug/L
1,1,1-Trichloroethane
< 10.0 ug/L
1,1,2-Trichloroethane
< 10.0 ug/L
Trichloroethylene
< 10.0 ug/L
Trichlorofluoromethane
<50.0 ug/L
Vinyl chloride
<50.0 ug/L
Additional Compounds
Acrolein
<500 ug/L
Acrylonitri[e
< 100 ug/L
I hereby certify that 1 have reviewed and approve these data.
Laboratory Representative
642 Tarnco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

MERI TECH, INC.
`
Environmental Laboratories
°R a•
A Division of Water Technology and Controls, Inc.
Client:
City of High Point Meritech IDM 04161545tb
Project;
2Q LTMP Analysis; 04/22/15
Client Sample ID:
Trip Blank Analyst; VWV
Sample Collection;
04/15/15 Dilation Factor: I
Report Date: 04/27/15
EPA 624 VOLATILE ORGANICS
1030114
MAY 0 i 2015
Public Services
Parameter
Result
Benzene
< 1.00 ug/L
Dichlorobromomethane
< 1.00 ug/L
Bromoform
< 1.00 ug/L
Methyl Bromide
<5.00 ug/L
Carbon Tetrachloride
< 1.00 ug/L
Chlorobenzene
< 1.00 ug/L
Chloroethane
<5.00 ug/L
2-Chloroethylvinyl ether
<5.00 ug/L
Chloroform
< 1.00 ug/L
Methyl Chloride
<5.00 ug/L
Chlorodibromomethane
<1.00 ug/L
1,2-Dibromoethane
< 1.00 ug/L
1,1-Dichloroethane
< 1.00 ug/L
1,2-Dichloroethane
< 1.00 ug/L
1,4-Dichlorobenzene
< 1.00 ug/L
1,2-Dichlorobenzene
< 1.00 ug/L
1,3-Dichlorobenzene
< 1.00 ug/L
1, 1 -Dichloroethylene
< 1.00 ug/L
trans-1,2-Dichloroethylene
< 1.00 ag/L
1,2-Dichloropropane
< 1.00 ug/L
cis-1,3-Dichloropropylene
< 140 ug/L
trans-1,3-Dichloropropylene
< 1.00 ug/L
Ethyl benzene
< 1.00 ug/L
Methylene chloride
< 1.00 ug/L
1,1,2,2-Tetachloroethane
<1.00ug/L
Tetrachloroethylene
< 1.00 up/L
Toluene
< 1.00 ug/L
1, 1, 1 -Trichloroethane
<1.00'ug/L,
1,1,2-Trichloroettrane
<1.00Ug/L
Trichloroethylene
< 1,00 ug/L
Trielrlorofluoromethane
<5,00 up/L
Vinyl chloride
<5.00 ug/L
Additional Cmnoounds
Acrolein
<50.0 ug/L
Acrylonitrile
<10.0 ugfL
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

4: MERITECH, INC.
6n..
Environmental Laboratories RECEIVED
a= Laboratory Certificate #165
MAY 0 j 2W5
Public Services
Client: City of High Point Me•ltech ID#:. 04161545 LLndustrial Pretreatrn
Project: 2Q LTMP Analysis: 04/24/15
Client Sample ID: WS Effluent Extraction: 04/20/15
Sample Collection: 04/15/15 Analyst: PM
Dilution Factor: I
EPA 625 SEMIVOLATILB ORGANICS
Parameter a nit Parameter Result
Acenapbthene
<10 ug/L
Fluoranthene
<10 ug/L
Acenaphthylene
<10 ug/L
Fluorene
<10 ug/L
Anthracene
<10 ug/L
Hexachlorobanzene
<10 ug/L
Benzidine
<50 ug/L
Hexachlorobutadiene
<10 ug/L
Benzo(a)nnthmcene
<10 ng/L
Hexachlorocyclopentadiene
<50 ug/L
Beazo(a)pyrena
<10 ug/L
Hexaddoroethane
<10 ug/L
Benzo(b)fluoranthene
<10 ng/L
Lldeno(1,2,3-cd)pyrene
<10 ug/L
Benzo(k)fluomnthene
<10 ug/L
Isophorone
<10 ug/L
Benzo(g,11,i)perylene
<10 ug/L
2-Methylnaphthalene
<10 ug/L
Benzyl butyl phthalate
<10 uglL
Naphthalene
<10 ug/L
Bis(2-chloroe(boxy)tnethane
<10 ug/L
Nitrobenzene
<10 ug/L
Bis(2-chloroethyl)ether
<10 ug/L
N-Nitrosodimethylamine
<10 ug/L
Bis(2-ohlomisopropyl)ether
<10 ug/L
N-Nitrosodi-n-propylanline
<10 ug/L
Bis(2-ethylhexyl)phthalate
<10 ug/L
N-Nitrosodiphenylnmine
<10 ug/L
4-Bromophanyl phenyl ether
<10 ug/L
Phenanthrene
<10 ug/l,
2-Chloronaphlhalene
<10 ug/L
Pyrene
<10 ugtL
4-Chlorophenylphenyl ether
<10 ug/L
1,2,4-Trichlorobenzene
<10 ug/L
Chrysene
<10 ug/L
Dibenzo(a,h)anthracene
<10 ug/L
4-Chloro-3-methylphenol
<10 ug(L
1,2-Dichlorobenzene
<10 ug/L
2-Chlorophenol
<10 ug/L
1,3-Dichlorobenzene
<10 ug/L
2,4-Dichlamphenol
<10 ug/L
1,4-Dichlorobenzene
<10 ug/L
2,4-Dimethylphenol.
<10 ug/L
3,T-Dichlorobenzidine
<50 ug/L
2,4-Dinilrophenol
<50 ug/L
Diethylplltllalate
<10 ug/L
4,6-Dinitro-2-methylphenol
<50 ug/L
Dinnethyl phthalate
<10 ug/L
2-Nitrophelol
<10 ug/L
Di-ll-butyl P11111alate
<10 ug/L
4-Nitrophenol
<50 ug/L
2,4-Dinitrololuene
<10 ug/L
Pentachlorophenol
<50 ug/L
2,6-Dinilrotoluene
<10 ug/L
Phenol
<10 ug/L
Dl-n-octyl phthalate
<10 ug/L
2,4,6-Trichlorophenol
<10 ug/L
1,2-Dipheny1hydrazine
<10 ug/L
I hereby certify that I have reviewed and approve these data, �' &�f-
Laboratory Representative
642 Tatneo Road * Reidsville, NC 27320
[phone] Ph * [phone] Fax

•
LA
Chain of Custody Record (COC)
Client: CI-N OF kt& -E Pcq t JT
NPDES#
Phone:
Fax:
MERITECH, INC.
ENVIRONMENTAL LABORATORIES
Address: PO 60X �;L5o
Emai,:
Project 22 L� Q
' A DiYision of W.Ne� Techno%gyand Contro/s, //7c.
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W�.�.t (�j I- 1V G �-7 2 b 1
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Phone: [phone]
642 Tamco Rd. Fax: [phone]
P
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'!"um Around Times`'
*RUSH work must have prior
approval.
Reidsville, NC 27320
Email: [e-mail]
Web Site: www.meritech-labs.com
Attention: DAWN MDI..N AiZ.
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3 - S Day
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Method
Lab use
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LOCation/i D #
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Jug #
Comments:
Method of Shipment:
Are these results for regulatory pu ses?
Report results in
Cl UPS
YES ❑ O mg/� ❑ mg/}(g ❑ On Ice?
Temperature On Receipt �r
❑ Fed Ex
Date Tune Rene by
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❑ Hand Delivery
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