NC0024210_Fact Sheet_20131206

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NC0024210
Facility Information
Applicant/Facility Name:
City of High Point / High Point Eastside WWTP
Applicant Address:
P.O. Box 230, High Point, NC 27261
Facility Address:
5898 Riverdale Rd., Jamestown, NC 27282
Permitted Flow
26 MGD
Type of Waste:
Domestic / Industrial
Facility/Permit Status:
Class IV / Renewal
County:
Guilford County
Regional Office:
Winston-Salem
Discharge Information
Receiving Stream:
Richland Creek (SI 17-7-(4))
Deep River (SI 17-(4))
Stream Classification:
WS IV
WS IV
303(d) Listed/TMDL
Yes, Fecal Coliform TMDL
No
S u b bas i n
03-06-08
03-06-08
Drainage Area (mi2)
16
96.3
Summer 7Q10 (cfs)
1.0
6.9
Winter 7Q10
2.6
2.6
30Q2
2.9
Average Flow (cfs)
15.0
96.3
IWC (%):
96
85
Latitude/Longitude
35° 56' 16" / 79° 53' 26"
35° 56' 11" / 79° 53' 22"
State Grid / USGS Quad:
D19NW / High Point East
D19NW / High Point East
Summary
The City of High Point requested renewal of the permit for the High Point Eastside WWTP. The
renewal application was received on February 24, 2011. The High Point Eastside permit expired on
August 30, 2011 and has been administratively extended. The Eastside facility serves the City of
High Point, the Town of Archdale, and Jamestown/Sedgefield for a total population of 86,639
persons.
The treatment system consists of three mechanical bar screens, vortex grit removal system, five
primary clarifiers, equalization basin, two aerated equalization basins, two equalization/sludge
storage tanks, four anaerobic/anoxic/aerobic aeration tanks, four secondary clarifiers, six effluent
filters (two deep bed, four dual media), UV disinfection, three Parshall flumes, effluent pump station,
post aeration channel.
Per the 2011 application, before May 2008, the Eastside WWTP discharged into Richland Creek,
Outfall 001. After completion and testing of the effluent pump station, the plant began to discharge
into the channel of the Deep River in the Randleman Reservoir through Outfall 002. Outfall 001
remains as a permitted outfall, but is used only on rare occasions that the effluent pump station is
taken out of service for maintenance.
There are currently 8 Significant Industrial Users and 12 Categorical Industrial Users discharging to
the Eastside WWTP with a total permitted flow of 1.11 MGD. They have a full pre-treatment program.
The last pretreatment compliance evaluation in September 2012 rated the program as compliant and
Fact Sheet
Renewal -- NPDES Permit NC0024210
Page 1

extremely reliable. This permit recommends that High Point continue to operate its approved pre-
treatment program.
Waste Load Allocation (this info submitted in the 2006 factsheet)
A Waste Load allocation was developed in 1999 for the expansion to 26 MGD. BOD5, NH3N, DO,
total nitrogen and total phosphorus are water quality limited. Limits for total phosphorus and total
nitrogen were established in 1998 under the Randleman Lake Watershed Nutrient Reduction Strategy
and approved by the Environmental Management Commission. Based on a nutrient response model
for the proposed lake a total phosphorus limit of 0.5 mg/L as a monthly average and total nitrogen of
6 mg/L during the summer was determined appropriate to protect water quality. As indicated in the
Hearing Officer's Summary from September 1998, the phosphorus limit was implemented as a
monthly average not as a quarterly average because due to the size and hydrology of the reservoir
and the availability of the phosphorus for algal growth, having quarterly limits would enable
excursions of phosphorus levels, especially during the growing seasons, which could result in algal
bloom conditions at unaccepted levels. The rule originally proposed a total phosphorus limit of 0.1
mg/L; the limit was increased to 0.5 mg/L when the proposed discharge location was moved to the
Deep River at Freeman Mill. The Hearing Officer's Summary also proposed that the rule do not
include numeric limitations and that the Environmental Management Commission be involved in any
future decision which may increase phosphorus above the mass loading at 26 MGD and 0.5 mg/L.
Rule 15 A NCAC 02B.0249 requires mass and concentration limits for phosphorus and nitrogen.
TMDL only applies to discharge into Richland Creek since it is listed on the NC 2012 303d list for
impaired streams. Note that the discharge into Richland Creek from Outfall 001 is periodic and only
during emergency situations. From the 2006 factsheet - A TMDL was approved in 2004. Data
collected indicates that urban source contributions, such as leaking sewer -pipes and septic systems,
are a significant source of much of the fecal coliform impairment. Additional fecal coliform loading
from nonpoint sources such as stormwater runoff also appear to contribute to instream
concentrations. The TMDL reductions for fecal coliform should be sought through identification and
repair of aging sewer and septic systems and removal of SSOs. Implementation should also target
storm -driven sources such as runoff from residential areas and agricultural land. The City of High
Point has completed several sewer rehabilitation projects.
Notices of Violation (NOVs) Since February 2007, the overall compliance has been good,
however there have been some NOVs and one enforcement case. There was a NOV for ammonia in
April 2008. There have been several NOVs issued for exceedances of the monthly total phosphorus
limit. These occurred in September and October 2011, June 2012, and March 2013. The most
recent facility inspection was in November 2012 and the facility was rated compliant for compliance
evaluation and rated as satisfactory in the facility evaluation.
Whole Effluent Toxicity (WET) Test
Existing limits: Outfall 001 @ Richland Creek Chronic limit at 90% (Ceriodaphnia Pass/Fail);
Outfall 002 @ Deep River Chronic limit at 85% (Ceriodaphnia Pass/Fail);
Quarterly testing conducted in January, April, July, and October.
Prior to the 2008 relocation, the Eastside facility discharged into Richland Creek with a chronic
toxicity limit of 90%. From the permit effective date of February 2007 to May 2008, there were five
chronic toxicity tests. There were failures in July and October 2007. The facility passed in January
and April 2008 before the relocation to Deep River was completed.
The relocation to Outfall 002 was completed in May 2008, therefore the chronic test with a limit of
85% became effective. Since May 2008, there have been twenty (20) toxicity tests and the facility
has passed all twenty (20).
Recommendation: Continuation of Chronic toxicity limit at 85% (Deep River discharge),
quarterly testing in January, April, July and October.
Fact Sheet
Renewal -- NPDES NC0024210
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Instream Data Review
Current Parameters: Dissolved Oxygen, Temperature, Fecal Coliform, Conductivity, Total Nitrogen
and Total Phosphorus
Recommended Parameters: Dissolved Oxygen, Temperature, Fecal Coliform, Conductivity, Total
Nitrogen and Total Phosphorus
-Deep River discharge
Upstream: Deep River at NCSR 1129
Downstream: Deep River at NCSR 1921
-Richland Creek discharge
Upstreaml: Richland Creek at least 100 feet above outfall
Upstream2: Deep River at NCSR 1113
Downstreaml: Deep River at NCSR 1129
Downstream2: Deep River at NCSR 1921
City of High Point is a member of the Upper Cape Fear River Basin Association (UCFRBA) and
therefore individual instream monitoring requirements are waived as long as the City is a member.
The memorandum of agreement between the UCFRBA and DWQ was renewed May 1, 2010 and is
effective until April 30, 2015. The UCFRBA conducts instream monitoring for its membership and
compiles data for review and evaluation.
A review of data sampled from January 2006 to December 2010 for Association stations for Richland
Creek and Deep River that corresponded to the sites in the permit. Station B435000- Deep River at
SR1113 showed some violations of the dissolved oxygen standard. All other field parameters, metals
and nutrients were below water quality standards. Station B4614500 — Randleman Lake at SR 1921
B1350000- the only water quality standard exceedences were for turbidity, all other parameters were
below the water quality standards.
Reasonable Potential Analysis (RPA)
A RPA was completed using the data from January 2007 through December 2011.
Parameter
Chronic
standard
(Ng/L)
Acute
standard
(Ng/L)
Maximum predicted
(Ng/L) for 001 & 002
Comments/Modifications to permit
Cadmium
2
15
1.3
No RP shown, no monitoring required,
Monitor in LTMP only
Copper
7
7
395
RP, No limit b/c NC action level standards
not limited. Quarterly monitoring in
conjunction with toxicity test.
Cyanide
5
22
5.0
All values below detection, o monitoring
required. Monitor in LTMP only.
Lead
26
33.8
7.4
No RP shown, no monitoring required,
Monitor in LTMP only
Mercury
* Evaluated per TMDL procedure, see
below.
Nickel
25.6
261
22.3
No RP, max. pred. value <50% of
allowable. Limit removed,quarterly
monitoring recommended.
Total
Phenolic
Compounds
300
47.6
No RP shown, no monitoring required,
Monitor in LTMP only
Zinc
51
67
190.7
RP, No limit b/c NC action level standards
not limited. Quarterly monitoring in
conjunction with toxicity test.
Mercury data evaluation
Fact Sheet
Renewal -- NPDES NC0024210
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A mercury TMDL was approved by US EPA in October 2012 and has been implemented for this draft
permit. The table below summarizes the available mercury data to determine whether limit or
monitoring is required.
High Point Eastside
Mercury Data Statistics (Method 1631E
2008
2009
2010
2011
2012
# of Samples
52
50
52
47
52
Annual Average, ng/L
1.8
1.8
1.8
1.2
1.0
Maximum Value, ng/L
9.00
6.00
5.00
4.00
4.00
TBEL, ng/L
47
WQBEL, ng/L
12.3
Per the mercury TMDL guidance, if there are no exceedances of the technology based effluent limit
(TBEL) or water quality based effluent limit (WQBEL) as in this case, then mercury monitoring (using
Method 1631E) conducted in the three (3) required effluent pollutant scans is sufficient.
In addition, because there are multiple mercury measurements above 1 ng/L, and this is a major
municipal facility with a permitted flow greater than 2.0 MGD, a special condition requiring that the
facility develop a mercury minimization plan (MMP) has been added in the draft permit.
PROPOSED MODIFICATIONS
• The numerical address of the facility on Riverdale Road is denoted on the supplement to
permit cover sheet.
• The Deep River outfall 002 is listed first on the supplement to permit cover sheet and the
phrase about construction of Randleman Reservoir has been removed.
• Twice per month monitoring for total cadmium, total lead, phenols, and cyanide has been
removed from the permit based on results of the reasonable potential analysis that
indicated that monitoring is no longer required. The data showed no potential to exceed the
water quality standards in Deep River or Richland Creek.
• The footnotes regarding chlorinated phenolic compounds and cyanide were removed from
A.(1.) and A.(2.) based on these parameters no longer being monitored in the permit.
• Footnote 5 in A.(1.) and A.(2.) now states that toxicity monitoring shall coincide with copper
and zinc monitoring.
• The weekly average limit for total mercury was removed based on the results of the mercury
evaluation analysis. Based on the NC approved mercury TMDL and an evaluation of data
from 2008 through 2012, it was determined that no limit was required for the protection of
the NC water quality standard or the technology based effluent limit. It was determined that
the facility would have to conduct a mercury minimization plan (MMP) based on the number
of detectable values above 1 ng/I. A special condition was added requiring the completion
of the MMP (See A.(8.)).
• The weekly average and daily maximum limit for total nickel was removed based on the
results of the reasonable potential analysis which indicated no potential to exceed the water
quality standard in the Deep River or Richland Creek. However based on current DWQ
procedure, quarterly monitoring for lead will be required based on the predicted
concentration being greater than 50% of the allowable concentration. (per DWQ
memorandum 7/15/2010 re: Monitoring Frequency for Toxic Substances).
• Minor language changes to the chronic toxicity conditions A.(5.) and A.(6.) have been made
to reflect updates.
• In Special Condition A.(7.). Effluent Pollutant Scan, the language has been updated to note
three scans must be completed during the permit cycle, mercury must be sampled using
Fact Sheet
Renewal -- NPDES NC0024210
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EPA Method 1631E and DWQ Water Quality Section has been corrected to the Surface
Water Protection Section.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: June 3, 2013
Permit Scheduled to Issue: September 1, 2013
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Jackie Nowell at [phone].
NAME: DATE:
Regional Office Comments:
NAME:
RO SUPERVISOR
DATE:
Fact Sheet
Renewal -- NPDES NC0024210
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DATE: