NC0047384_Modification Request_20200827

RECEIVED
SEP 02 1010
r City
of Greensboro NCDEQ/DWR/NPDES
North Carolina Water Resources Department
August 27, 2020 Certified Mail 7003 1680 0001 0765 9012 Return Receipt Requested
Mr. Mike Montebello, Municipal Permitting Supervisor
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: T. Z. Osborne NPDES Permit NC0047384 Part I-Section A.(4)
Total Nitrogen Reduction Schedule - Modification Request
Mr. Montebello,
The T. Z. Osborne (TZO) NPDES Permit includes a seven-year(2014-2020) Total Nitrogen Reduction
Schedule in Part I-Section A.(4). The Schedule contains annual milestones outlining the Four
Package $120 million Biological Nutrient Removal (BNR) project designed to comply with the Total
Nitrogen (TN) targets in the Jordan Lake Rules.
Package 4 was originally scheduled for completion by December 31, 2020. Although it will be
substantially complete by that date, the "Engineer's Certification" will not be issued by that date.
Delays in the completion date of Package 4 were experienced due to procurement delays, weather-
related events as well as the Covid-19 pandemic. The contractor's contract with the City of
Greensboro provides clauses that allow the contractor to request additional time due to an
epidemic (per EJCDC C-700 Standard General Conditions of the Construction Contract). Compliance
with the TN targets should not be impacted, however, since there will be adequate 5-stage BNR
tankage in place on January 1, 2021 to meet the annual mass/pounds limits. In addition, several of
the unfinished items are not directly related to the BNR treatment processes.
The following items will be finished in the spring of 2021:
• New odor-scrubber system
• Electrical system additions
• Additional control systems upgrades
• Six (6) new 5-stage BNR aeration basins [Note:The retrofit of all 12 existing aeration basins
to BNR basins is scheduled for completion by December 31, 20201
Part I-Section A.(4) of NPDES Permit NC0047384 includes the following:
...Revisions to this schedule may be considered and made provided that by December 31,
2019, the City of Greensboro shall receive an Authorization-to-Construct permit from DWR
for construction, installation, or alteration of the treatment works for purposes of complying
with the TN permit limitation; and, by December 31, 2021 the City of Greensboro shall
comply with the annual total nitrogen targets listed in NPDES Permit NC0047384...

The City of Greensboro Water Resources Department hereby requests a schedule modification for
CY2020 activities to include a 120-day extension (from December 31, 2020 to April 30,2021)of the
completion date of the TZO BNR project.
Currently the TZO plant has three (3) of the existing retrofitted large aeration basins operating in
5-stage BNR mode. These basins are being used for troubleshooting/optimization of the new BNR
processes and equipment, as well as for staff hands-on training purposes. Recent data from the 5-
Stage tanks indicates significant nitrogen reductions already.
Packages 1, 2 and, 3 of the BNR Project were completed on time as noted in the information below:
T. Z. Osborne BNR Project Packages Information
• Construction on Package 1 was completed on October 22, 2018.
• Construction on Package 2 was completed on April 10, 2018.
• Construction on Package 3 was completed on March 29, 2018.
• An Authorization to Construct for Package 4 (which includes treatment processes to comply
with the TN permit limitation) was issued on May 8, 2017.
• Package 4 of the T. Z. Osborne BNR Project was bid on September 28, 2017 and Adams
Robinson was awarded the project by the Greensboro City Council on November 14, 2017. The
Notice to Proceed was issued on January 16, 2018. Construction began in February 2018.
If you have questions or need additional information, please feel free to contact me at
[e-mail] or by phone at 336-362-6416.
Sincerely,
Elijah L. Williams
Water Reclamation Manager
Mike Borchers, Water Resources Director(via email)
Bradley Flynt, TZO Plant Superintendent/ORC(via email)
Martie Groome, Laboratory and Industrial Waste Section Supervisor(via email)
Alicia Goots, Laboratory Coordinator (via email)
Julie Grzyb, NCDEQ DWR Assistant Director(via email)
Lon Snider, NCDEQ, Winston-Salem Regional Office Supervisor(via email)
Jenny Graznak, NCDEQ, Winston-Salem Assistant Regional Office Supervisor(via email)
NCDEQ Jordan Lake Watershed Coordinator(via email)
Aaron Babson, Hazen and Sawyer Engineers (via email)