NC0050342_Staff Comments_19940912

NPDES DOCUWENT SCANNING COVER SHEET
NPDES Permit:
NC0050342
Muddy Creek WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
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%Jar WAV4 rI
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 12, 1994
Whim documeut is printed on reuse paper - ignore any
coritent on the reYerse side

DIVISION OF ENVIRONMENTAL MANAGEMENT
MEMORANDUM
To:
From:
Subject:
September 12, 1994
Steve Mauney, Water Quality Supervisor
Winston-Salem Regional Office
Greg Nizich (-,' i )
NPDES Permits Unit
Draft Permit Comments
NPDES Permit #NC0050342
Muddy Creek WWTP
Forsyth County
Attached is a copy of the City of Winston-Salem's comments on their draft permit.
Please provide input on their requests for changes to the permit.
Attachment
cc: Instream Assessment Unit
Permit File

ekV
CITY OF \VINSTON-SALEM
PUBLIC WORKS DEPARTMENT
RO. BOX 2511, WINSTON-SALEM, NORTH CAROLINA 27102
September 7, 1994
Mr. Dave Goodrich
North Carolina Department of Environment,
Health and Natural Resources
512 North Salisbury Street
Post Office Box 29535
Raleigh, NC 27604
SUBJECT: Comments on Draft Permit
Muddy Creek WWTP (NC0050342)
Winston-Salem, NC
Dear Mr. Goodrich:
The City of Winston-Salem wishes to submit the following comments
regarding the draft NPDES permit for our Muddy Creek WWTP. This
permit is scheduled for final issue on September 26, 1994.
I. Implementation of the 21 MGD Permitted Flow
The draft permit prohibits the plant from discharging a flow
greater than its current 15 MGD limit until an authorization is
received from DEM to construct the facilities necessary to meet
limits at a 21 MGD flow.
Hazen and Sawyer, P. C. has completed an evaluation of the plant's
treatment capacity and has concluded that, with the exception of .-,
the residual chlorine limit, the plant's existing facilities can,-:
meet the limits proposed for a 21 MGD flow. A capacity certifica- =;
tion to this effect has been prepared by Hazen and Sawyer and is
attached.
Winston-Salem requests that the 21 MGD limits for CBOD5, TSS, Am-
monia, and fecal coliform be implemented as of the permit's effec-
tive date.

Mr. Dave Goodrich
September 7, 1994
Page 2
II. Total Residual Chlorine Limit
The draft permit includes a 28 ug/1 residual chlorine limit.
Winston-Salem is opposed to the implementation of this limit for
two major reasons.
Our primary opposition to this limit is based on our feeling that
limits on specific toxicants, such as residual chlorine, are un-
necessary because their purpose is provided for by biomonitoring
provisions.
The permit's effluent toxicity limit is much more effective in
protecting the receiving stream because biomonitoring tests will
detect toxicity caused by any agent.
Winston-Salem asks that this limit be deleted from the final per-
mit because an unnecessary redundancy will occur if we are re-
quired to comply with a toxicity limitation and a residual chlo-
rine limit.
The Muddy Creek Plant does not currently have the facilities nec-
essary to meet the proposed chlorine limit. The cost to construct
these facilities is approximately $2,000,000.
We are aware that EPA is currently considering a ban on the use of
chlorine as a disinfectant. Given the uncertain future of chlo-
rine use, Winston-Salem feels that it would be unwise to invest
millions of dollars in a dechlorination facility that would be
rendered useless if EPA imposes the ban.
Winston-Salem feels that both of the reasons discussed above are
sufficient cause for DEM to delete the proposed residual chlorine
limit from the final permit.
III. CBOD5 Monitoring on Receiving Stream
The draft permit requires that CBOD5 analyses be performed daily
on upstream and downstream samples. We feel that weekly monitor-
ing of stream samples for this parameter is adequate to track
stream conditions.

Mr. Dave Goodrich
September 7, 1994
Page 3
We request that the monitoring frequency for stream CBOD5 be
changed to weekly.
IV. Monitoring Provisions for Ammonia
The draft permit requires that ammonia analyses be performed daily
on effluent and stream samples during the summer and three times
per week during the winter.
Given that the plant's permitted discharge is only 5.5% of the
Yadkin 7Q10 flow, Winston-Salem feels that year round monitoring
of ammonia levels in stream samples on a weekly basis is adequate.
We request that the final permit provide for weekly ammonia
monitoring of streams.
Winston-Salem also feels that year round daily monitoring of ef-
fluent ammonia levels is appropriate. We also request that this
frequency of monitoring be stipulated by the final permit.
V. Effluent Dissolved Oxygen Monitoring Provisions
The draft permit requires daily monitoring of effluent dissolved
oxygen levels. The draft permit also stipulates that the average
daily effluent oxygen level not be less than 5.0 mg/l.
Winston-Salem requests that the monitoring frequency for effluent
D. O. to be reduced to twice per month.
The location at which the plant discharges into the Yadkin River
is five miles from the plant and one mile from an all weather ac-
cess road. The site is in a flood way area and it is not readily
accessible.
Winston-Salem cannot meet the daily monitoring requirement pro-
posed in the draft permit because we cannot gain access to the
discharge site on a daily basis.

Mr. Dave Goodrich
September 7, 1994
Page 4
Winston-Salem does not feel that the receiving stream will be en-
dangered by reducing the monitoring frequency for effluent D. D.
from daily to twice monthly. The plant's discharge flow is a
small percentage of the river's flow and the plant has an excel-
lent compliance history.
We also request that DEM delay the implementation of the proposed
5.0 mg/1 average daily effluent dissolved oxygen limit until July
1, 1996.
This delay is needed to provide us the time to evaluate whether or
not we can meet the proposed limit with existing facilities and,
if not, design and construct the post aeration chamber required to
achieve compliance.
VI. Flow Limitations on the 002 Discharge Point
The draft permit requires that a discharge via the 002 outfall
shall occur only when the USGS gauge at Highway 64 exceeds 5000
cfs.
It is impossible for us to comply with this requirement because we
have no control over the point at which an 002 discharge occurs.
When flood stage in the Yadkin River rises high enough to sur-
charge the 001 outfall, the plant's effluent automatically over-
flows into the outfall leading to the 002 discharge on Muddy
Creek.
Winston-Salem objects to this permit requirement because it re-
quires that we perform an impossible function. We request that
the wording in this area of the permit be deleted.
The draft permit also imposes a 21 MGD monthly average flow for
the 002 discharge. We request that this limit be deleted.
Discharges only occur at the 002 site during flood conditions. At
these times the plant will be discharging at rates well in excess
of the proposed 21 MGD limit as we attempt to avert flood damage
at our headworks.
The nature of an 002 discharge is such that an automatic permit
violation will occur unless we shut off pumps and allow the
headworks and influent outfalls to flood.

Mr. Dave Goodrich
September 7, 1994
Page 5
Winston-Salem feels that it is not appropriate for DEM to assign a
flow limit to the 002 discharge. We request that this limit be
deleted.
VII. Conductivity Monitoring
The draft permit proposes that conductivity analyses be performed
daily on effluent and stream samples.
Winston-Salem feels that daily monitoring for this parameter is
eccessive and would tax our ability to perform the monitoring
needed to protect our system.
We request that DEM reduce the monitoring frequency for conductiv-
ity to monthly.
Winston-Salem would welcome the opportunity to review the final
version of this permit before the September 26, 1994 issue date.
Such a review may allow us to jointly resolve problems with the
final document without having to deal with the ad j udi ca tory pro-
cess.
Winston-Salem appreciates the opportunity to comment on this draft
permit. If you have any questions regarding this matter, please
feel free to contact me at 910/784-4700.
Sincerely,
0,1
Stanley _ B . W b
Wastewater 'reatment Plant Superintendent
pc: Tom Griffin, Utilities Superintendent
Barry Shearin, Utility Plants Engineer
Chris Shamel, WTP Supervisor/Muddy
Steve Mauney, DEHNR Winston-Salem Regional Office
It

HAZEN AND SAWYER
Environmental Engineers & Scientists
September 2, 1994
Mr. Stan Webb
Muddy Creek Plant Superintendent
P.O. Box 2511
Winston-Salem, North Carolina 27102
Dear ,Mr: Webb:
Hazen and Sawyer, P. C.
4011 WestChase Blvd.
Raleigh, NC 27607
919 833-7152
Fax: [phone]
Re: Certification of Plant Capacity
Process and Hydraulic Evaluation of
Muddy Creek WWTP
We have completed the process and hydraulic review of the Muddy Creek
Wastewater Treatment Plant and in our best engineering opinion the Muddy
Creek Treatment Plant is fully capable of meeting CBOD5, total suspended solids,
and ammonia nitrogen summer limits of 25 mg/I, 30 mg/I, and 14 mg/I,
respectively (and corresponding winter limits) at a revised permitted flow of 21
mgd. Disinfection system modifications may be required to comply with the
residual chlorine limit of 28 ug/I. Please call if you need additional information.
JAC/wp
cc: Robert S. DiFiore
Very truly yours,
HAZEN AND SAWYER, P.C.
rameLA-
s A. Cramer, P.E.
Senior Associate
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