NC0006033_Speculative Limits_19991006

State of North Carolina
►��°� �P� L I wl ri
Department of Environment
and Natural Resources A
�
Division of Water Quality
James B. Hunt, Jr.,Governor NCDENR
Bill Holman, Secretary
Kerr T. Stevens, Director
October 6, 1999
Mr. Gerald Hatton
Finkbeiner, Pettis & Strout, Inc.
One Woodlawn Green
200 East Woodlawn Road, Suite 124
Charlotte, North Carolina 28217
Subject: Speculative Limits
Eastern Gaston County Regional WWTP
Gaston County
Dear Mr. Hatton:
This letter is in response to your request (dated June 23, 1999) for speculative effluent
limits for the wastewater treatment alternatives summarized below. These alternatives are
grouped into existing facilities and proposed regional facilities.
I. Alternatives for Existin W WTPs
FacilityAlternative
Recevin Stream
Belmont (NC0021181)
Expand from 5 to 8 MGD
Catawba River; WS-W B;
030834
Mount Holly (NC0021156)
Expand from 4 to 8 MGD
Catawba River; WS-IV CA;
030833
Cramerton (NC0055948) and
Eliminate Cramerton discharge
S.Fork Catawba River, WS-V;
Collins&Aikman (NC0006033)
(0.25 MGD) and consolidate at
030836
Collins&Aikman with existing 4
MGD capacity.
IL Alternatives for New Re Tonal WWTP
New Regional WWTP
New 35 MGD plant adjacent to
Catawba River; WS-IV B;
existing Belmont WWTP, using
030834
same discharge point.
New Regional WWTP
New 35 MGD plant north of
Catawba River; WS-V B;
Duke Power Allen Steam Station
030834
New Regional WWTP
New 35 MGD plant on CMUD
Catawba River, WS-V B;
site located on east side of river.
030834
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
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stem Gaston County/Regional
eculative Limits
ge 2
Based on available information and the 1995 Catawba River Basin Management
rategies for new and expanding facilities, the proposed wastewater alternatives would receive
the speculative effluent limits listed below. Note that the three Regional Alternative sites would
receive the same speculative limits.
Parameter
Effluent Limits (Month) Average)
Holly
Cramerton
Re tonal
Flow, MGD
4
35
BOD5,m 1
10
5
Ammonia, 1 NH3-N
W6-96-9
4
1
Total Suspended Solids,m
30
30
Fecal coliform, or s/100 nil
200
200
Total Residual Chlorine, m
28
28
PH
6-9
6-9
Chronic Toxicity at 1WC
Yes
Yes
Yes
Yes
Total Phos horus,m 1 TP
1
1
1
0.5
Total Nitrogen, mg/l TN
6 (summer)
6 (summer)
6 (summer)
429,647 (lbs/ ear)*
* Annual mass limit based on a concentration of 4.09 mg/l TN at a design flow of 35 MGD.
The 1995 Lake Wylie nutrient reduction strategy specified limits of 1 mg/1(TP) and 6
mg/l (TN -summer only) for all new and expanding facilities greater than 1 MGD. This strategy
was applied to the proposed individual expansions. However, more stringent nutrient limits were
applied to the proposed 35 MGD regional facility based on the following factors: 1) maintaining
no net increase in nutrient load above what the strategy would allow for the individual
expansions; 2) the sensitivity of the receiving waterbody to both nitrogen and phosphorus inputs;
3) progress in nutrient reduction technologies since the 1995 strategy was developed; and 4) the
significant size of the proposed expansion. An annual total nitrogen mass load is proposed for
the Regional facility, in recognition of potential seasonal variations and limits of current
treatment technologies.
Under the current Division policy, dechlorination and chlorine limits are now required for
all new or expanding dischargers proposing the use of chlorine for disinfection. An alternate
form of disinfection, such as ultraviolet radiation, would allow the facility to comply with fecal
coliform limits without the use of chlorine.
The speculative limits presented here are based on our understanding of the proposal and
of present environmental conditions. These speculative limits are not binding unless they
become part of an issued NPDES permit. Response to a speculative limit request does not
guarantee that the Division will issue the individual entities an NPDES permit to discharge
treated wastewater into waters of the State. Nor can we guarantee that the effluent limitations
and other requirements included in any permit will be exactly as presented here. A complete
evaluation of limits and monitoring requirements for metals and other toxicants will have to be
addressed at the time of formal NPDES application.

stem Gaston County/Regional
sculative Limits
;e 3
In accordance with the North Carolina General Statutes, the practicable waste treatment
d disposal alternative with the least adverse impact on the environment must be implemented.
m-discharge alternatives, such as spray irrigation or connection to a regional wastewater
treatment facility, are considered to be environmentally preferable to a discharge. Therefore,
prior to submittal of an NPDES application, a detailed alternatives analysis must be prepared to
assure that the environmentally sound alternative was selected from the reasonably cost-effective
options. A guidance document to assist you or your consultant in preparing an engineering
alternatives analysis (EAA) is enclosed.
It should be noted that an expansion of more than 0.5 MGD for an existing facility will
require that an environmental document be prepared by the applicant_ The North Carolina
Environmental Policy Act and its associated rules require that an Environmental Assessment
(EA) and Finding of No Significant Impact (FONSI) be prepared before the permit for expansion
is issued. If deemed appropriate, there is a possibility that an environmental impact statement
(EIS) might be necessary.
Finally, color in the Catawba River Basin is a concern, and the Division is currently
developing strategies to address this issue. If significant industrial users (SRD contribute color to
the WWTPs, the facilities may wish to begin building a database for color.
All information pertaining to this request has been sent to our Central Files for storage. If
it becomes necessary to request an NPDES permit, please submit a complete application package
including the appropriate fees. If you have any additional questions about these limits or the
NPDES application process, please contact Tom Belnick at [phone], extension 543.
Sincerely,
David A. Goodrich
Supervisor, NPDES Unit
Water Quality Section
cc: Mooresville Regional Office
Central Files
NPDES Unit
Darlene Kucken
Gloria Putnam