NC0021156_SPECULATIVE LIMITS_19991012

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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor NCDENR
Bill Holman, Secretary
Kerr T. Stevens, Director
October 12, 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.
ertive
Belmont (NC0021181) Expand from 5 to`8 MGD Catawba River;WS-IV 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.
A13e fix 1w �
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]
An Equal Opportunity Affirmative Action Employer 50%recycled!10%post-consumer paper

Eastern Gaston County/Regional
Speculative Limits
Page 2
Based on available information and the 1995 Catawba River Basin Management
Strategies 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 t: t `�, eculattve Effluent Ltrruts (Monthl
s:
RBe1rriontMtH611` � ,CrameitonRe`'onalMIN 0700
r
Flow, MGD 8 8 4 35
BOD5,m I 5 5 t0 5
Ammonia, mg/l NH3-N 1 1 4 1
Total Suspended Solids,m 1 30 30 30. 30
Fecal coliform, or s/100 nil 200 200 200 200
Total Residual Chlorine, mg/1 28 28 28 28
PH 6-9 6-9 6-9 6-9
Chronic Toxicity at IWC Yes Yes Yes Yes
Total Phos horus,m I TP 1 1 1 0.5
Total Nitrogen, mg/1 TN 6 (summer) 6 (summer) 6(summer) Equivalent loading*
* It is the Division's intent to maintain the mass of TN loading at the proposed regional facility equivalent to the
mass loading that would be allowed at the three individual facilities following expansion. For planning design
purposes,an effluent concentration equivalent to 4 mg/I TN should be assumed based on a 35 MGD design flow.
The 1995 Lake Wylie nutrient reduction strategy specified limits of I mg/l (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. For the Regional facility, it is the Division's intent to
allow an annual mass-based TN limit in order to provide flexibility in facility operations, while
still protecting Lake Wylie.
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.

Eastern Gaston County/Regional
Speculative Limits
Page 3
In accordance with the North Carolina General Statutes, the practicable waste treatment
and disposal alternative with the least adverse impact on the environment must be implemented.
Non-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 (SIU)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,
6� I'd qp&��
David A. Goodrich
Supervisor, NPDES Unit
Water Quality Section
cc: Mooresville Regional Office
Central Files
NPDES Unit
Darlene Kucken
Gloria Putnam