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Home My WebLink AboutNC0085359_Permit (Issuance)_20051005NPDES DOCUMENT SCANNINO COVER $MEET NPDES Permit: NC0085839 Twelve Mile Creek WWTP Document Type: Permit Issuance ' .: Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: October 5, 2005 This document is printed on reuse paper - igriore any content on the reYersce side NCDENR Ms. Christie Putnam Union County Public Works 400 North Church Street Monroe, North Carolina 28112 Dear Ms. Putnam: Michael F. Easley Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality October 5, 2005 Subject: NPDES Permit Issuance Permit No. NC0085359 Twelve Mile Creek WWTP Union County Division personnel have reviewed and approved your application for issuance of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended.) This final permit authorizes Union County Public Works Department to discharge 2.5 MGD of treated wastewater from the Twelve Mile Creek WWTP, with an expansion phase to 6 MGD. Discharge limitations and/or monitoring for flow, biochemical oxygen demand (BOD), total suspended solids (TSS), ammonia, fecal coliform bacteria, total phosphorus, pH, total residual chlorine, chromium, copper and zinc are included in the permit. The following modifications included in the draft permit of July 20, 2005 remain in the final permit: • Effluent limitations for copper and zinc have been modified based on the results of the site -specific criteria study that was conducted by Union County. A reasonable potential analysis showed that the discharge had the potential to exceed these site -specific standards. DWQ reviewed the information submitted in the comment letter and re-evaluated the reasonable potential analysis. The analysis still indicated reasonable potential to exceed the site specific standards. Because of Union County's discharge into Twelve Mile Creek and its eventual drainage into South Carolina's waters, it is necessary to protect for the South Carolina water quality standards. At 2.5 MGD, the copper limit is 10.5 ug/1 and the zinc limit is 94 ug/1. At the expansion flow of 6.0 MGD, the copper limit will be 10.3 ug/1 and the zinc limit will be 93 ug/1. These limits will become effective June 1, 2006. N. C. Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 Internet: h2o.enr.state.nc.us Phone: (919) 733-5083 fax: (919) 733-0719 DENR Customer Service Center: 1 800 623-7748 Letter to Ms. Putnam Page 2 • The results of the pending Water Effects Ratio study will be evaluated and the appropriate copper and zinc limitations will be applied as required by DWQ. • Summer and winter weekly average limits for NH3 have been revised at the existing 2.5 MGD wasteflow based on updated DWQ procedure. The new summer and winter weekly average NH3 limits will be 6 mg/1 and 12 mg/1, respectively. • An annual effluent pollutant scan has been added to fulfill EPA's application requirement for major municipal wastewater treatment facilities. Special Condition A. (5.) of this permit details this requirement. Be advised that pollutant scan data are required to be submitted on the Discharge Monitoring Report Form for the appropriate month. Upon renewal of this permit, Union County should reference these data in completing the application. • The Division has reviewed the information submitted regarding the County's request for variance from the 24 hour-7 day per week staffing requirement. The requirement is not effective until Union County submits an engineer's certification for the expansion to 6.0 MGD. In lieu of the recent facility problems and compliance violations, DWQ cannot at this time provide a waiver of the staffing requirement for the expansion flow. We recommend that Union County request a reevaluation of the issue of the waiver of staffing requirement when the facility is closer to reaching the expansion flow. The following modifications will be included in the final permit: • A weekly average limit of 17 ug/1 and a daily average limit of 28 ug/1 for total residual chlorine will be given. These limits will protect against acute and chronic chlorine toxicity. • Monthly monitoring for chromium will be included in the permit. The presence of this parameter was included in your submitted data. If , within 12 months, Union County can demonstrate that this is not a pollutant of concern, you may petition for removal of this monitoring requirement. The following concerns were reviewed by DWQ and no modifications will be made at this time: • A daily maximum limit for fecal conform of 400/ 100m1 will remain in the permit based on the protection of the State of South Carolina's water quality standard. • The request for reduction in stream monitoring to weekly year round cannot be approved. Current North Carolina regulations 15A NCAC 2B .0508 require that Class IV domestic wastewater facilities conduct instream monitoring three times per week in the summer months (June through September) and once per week during the rest of the year. With the low flow of the receiving stream, the pending expansion to a higher flow, and potential water quality impact to downstream waters, DWQ cannot reduce the instream monitoring during the most critical months of the year. NC regulation 15A NCAC 2B .0505 c (4) does allow discontinuation of stream sampling when flow conditions or extreme weather conditions present a risk of injury. Stream sampling shall be resumed at the first opportunity after the risk period has ceased. Union County can also request more appropriate Letter to Ms. Putnam Page 3 downstream sites for safety purposes and, after review; DWQ will determine whether the sites can be changed. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be fmal and binding. Please take notice that this permit is not transferable. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permits may be required. If you have any questions or need additional information, please contact Ms. Jacquelyn Nowell at telephone number (919) 733-5083, extension 512. Sincerely, ORIGINAL SIGNED BY SUSAN A. WILSON Alan W. Klimek, P.E. Attachments cc: Mooresville Regional Office / Surface Water Protection Section Aquatic Toxicology Unit EPA/ Region IV attn. Marshall Hyatt Jeff deBessonet/ Bureau of Water DHEC, 2600 Bull St. Columbia SC 29201 Permit File U.S. Fish and Wildlife Service :Attn: Contaminants Specialist PO Box 33726 Raleigh, NC 27636-3726 NC Wildlife Resources Commission :Division of Inland Fisheries Attn: Shannon Deaton 1721 Mail Service Center Raleigh, NC 27699-1721 Central Files Permit NC0085359 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the Union County Public Works Department is hereby authorized to discharge wastewater from a facility located at the Twelve Mile Creek Wastewater Treatment Plant 3104 Providence Road South Waxhaw Union County to receiving waters designated as Twelve Mile Creek in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II and III hereof. This permit shall become effective November 1, 2005 This permit and authorization to discharge shall expire at midnight on June 30, 2010. Signed this day October 5, 2005 ORIGINAL SIGNED BY SUSAN A. WILSON Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0085359 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. The Union County Public Works Department is hereby authorized to: 1. Continue to operate an existing 2.5 MGD wastewater treatment facility that includes the following components: > Self-cleaning influent filter screen > Vortex grit chamber > pH adjustment > Two oxidation ditch systems > Two final clarifiers > Dual tertiary sand filters > Ultraviolet disinfection > Cascade post aeration ➢ Two sludge storage tanks with diffused aeration ➢ Sludge digester (1.0 MGD) > Alum and polymer feed systems > Stand-by power generator This facility is located at the Twelve Mile Creek Wastewater Treatment Plant off Providence Road South near Waxhaw in Union County. 2. Upon issuance of an Authorization to Construct permit by the Division of Water Quality and submission of the engineers certification for expansion, operate a wastewater treatment facility up to a design flow of 6.0 MGD and, 3. Discharge from said treatment works at the location specified on the attached map into Twelve Mile Creek, a class C stream in the Catawba River Basin. Facility Information LatitrdP: 34°5T01" Longitude: Quad #: rcm Class: Receiving Steam 80°45'44" H15NE C Twelve Mle Creek Sub-B sin: 03-08-38 North Twelve Mile Creek WWTP NC0085359 Union County Permit NC0085359 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -FINAL During the period beginning on the effective date of the permit and lasting until expansion above 2.5 MGD or expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT RACTERISTICS ARA CHA ��4$ LIMITS •�,` MONITORING !REQUIREMENTS ` { Monthly .,s. 3.. Average Weekly * �: i E 1iN 1 ...Z :Average. - Daily f, ^Maximum Measurement wa$%�?::S>�*x ZWS: Frequency..', Sample Type' F s t S'am ple Location' � k C...r�.:� '.. .:..: f Flow 2.5 MGD Continuous Recording Influent or Effluent BOD, 5-day, 209C (April 1 - October 31) 2 5.0 mg/L 7.5 mg/L Daily Composite Influent & Effluent BOD, 5-day, 209C (November 1- March 31) 2 10.0 mg/L 15.0 mg/L ` Daily Composite Influent & Effluent Total Suspended Solids 2 30.0 mg/L 45.0 mg/L Daily Composite Influent & Effluent NH3 as N (April 1— October 31) 2.0 mg/L 6.0 mg/L Daily Composite Effluent NH3 as N (November 1— March 31) 4.0 mg/L 12.0 mg/L Daily Composite Effluent Dissolved 0xygen3 _ Daily Grab Effluent Dissolved Oxygen (June through September) 3/Week Grab Upstream & Downstream' Dissolved Oxygen (October through May) 1/Week Grab Upstream & Downstream' pH4 Daily Grab Effluent Total Residual Chlorine5 17.0 p g/L 28.0 pg/L Daily Grab Effluent Total Nitrogen (NO2+NO3+TKN) , Monthly Composite Effluent Total Phosphorus 6 Monthly Average: 41.70 pounds/day 12 Month average: 20.85pounds/day Monthly Composite Effluent Temperature, 4C Daily Grab Effluent Temperature, °C (June through September) 3/Week Grab Upstream & Downstream' Temperature, °C (October through May) 1/Week Grab Upstream & Downstream' Fecal Coliform (geometric mean) 200/100 ml 400/100 ml Daily Grab Effluent Fecal Coliform (geometric mean) (June through September) 3/Week Grab Upstream & Downstream' Fecal Coliform (geometric mean) (October through May) 1/Week Grab Upstream & Downstream' Conductivity Daily Grab Effluent Conductivity (June through September) 3/Week Grab Upstream & Downstream' Conductivity (October through May) 1/Week Grab Upstream & Downstream' Total Chromium? Monthly Composite Effluent Total Copper 2/month Composite Effluent Total Copper8,9 10.5 p g/I Weekly Composite Effluent Total Zinc 2/month Composite Effluent Total Zinc8'9 94 p g/l Weekly Composite Effluent Chronic Toxicityl0 Quarterly Composite Effluent Pollutant Scan11 Annually See A.(5.) Effluent Notes on following page: Permit NC0085359 1. Upstream: 50 feet upstream from the outfall. Downstream samples shall be collected at two locations. D 1: One quarter mile downstream from the outfall, before confluence with the first tributary. D2: at NCSR 1301. Additional downstream dissolved oxygen monitoring is recommended to provide DO stream profile of Twelve Mile Creek in North Carolina and South Carolina. 2. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Monitoring requirement and limit applies only if chlorine is added for disinfection. 6. Part A. (4.) describes the methodology for calculation of the monthly average and 12-month limits. 7. Monitoring requirement may be deleted upon written notification from the permitting authority. 8. The permittee has been granted a schedule of compliance for copper and zinc based on the previous permit condition: The limits for copper and zinc will become effective eighteen (18) months after completion of the site -specific standards. The Division considered the site -specific standard study complete in January 2005 when EPA concurred with the inclusion of Cladocerans in the National Dataset. The copper and zinc limits will become effective June 2006. 9. The limits stipulated are based on "total recoverable". Alternatively, the permittee may request limits based on total dissolved as allowed under South Carolina standards. 10. Chronic Toxicity (Ceriodaphnia) P/F @ 90% with testing in February, May, August and November (see A. (3.) Special Conditions of the Supplement to Effluent Limitations). 11. See Special Condition A. (5.) There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC0085359 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS- FINAL During the period beginning upon expansion above 2.5 MGD and lasting until expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFF ENT ., r'LUG. ,...a CHARACTERISTICS LIMITS : =MONITORING;REQUIREMENTS � ', 244E F .. , i.: ' '. .. ..i� othl Average Weeki -> Average Dall Maximum Measure`' ent Frequency . ; RSam Ie T' ... Sam Ie Location'• " .: x 6.0 MGD Continuous Recording Influent or Effluent _Flow BOD, 5-day, 20°C (April 1 - October 31) 2 5.0 mg/L 7.5 mg/L Daily Composite Influent & Effluent BOD, 5-day, 20°C (November 1- March 31) 2 10.0 mg/L 15.0 mg/L Daily Composite Influent & Effluent Total Suspended Solids 2 30.0 mg/L 45.0 mg/L Daily Composite Influent & Effluent NH3 as N (April 1- October 31) 1.0 mg/L 3.0 mg/L Daily Composite Effluent NH3 as N (November 1- March 31) 2.0 mg/L 6.0 mg/L Daily Composite Effluent Dissolved 0xygen3 Daily Grab Effluent Dissolved Oxygen (June through September) 3/Week Grab Upstream & Downstream' Dissolved Oxygen (October through May) 1/Week Grab Upstream & Downstream' pH4 Daily Grab Effluent Total Residual Chlorine5 17.0 p g/L Daily Grab Effluent Total Nitrogen (NO2+NO3+TKN) Monthly Composite Effluent Total Phosphorus 6 Monthly Average: 41.70 pounds/day 12 Month average: 20.85 pounds/day Monthly Composite Effluent Temperature, °C Daily Grab Effluent Temperature, 2C (June through September) 3/Week Grab Upstream & Downstream' Temperature, 9C (October through May) 1/Week Grab Upstream & Downstream' Fecal Coliform (geometric mean) 200/100 ml 400/100 ml Daily _ Grab Effluent Fecal Coliform (geometric mean) (June through September) 3/Week Grab Upstream & Downstream' Fecal Coliform (geometric mean) (October through May) 1/Week Grab Upstream & Downstream' Conductivity Daily Grab Effluent Conductivity (June through September) 3/Week Grab Upstream & Downstream' Conductivity (October through May) 1/Week Grab Upstream & Downstream' Total Chromium? Monthly Composite Effluent Total Copper 2/month Composite Effluent Total Copper8'9 10.3 p g/I Weekly Composite Effluent Total Zinc 2/month Composite Effluent Total Zinc8'9 93 p g/I Weekly Composite Effluent Chronic Toxiciity10 Quarterly Composite Effluent Pollutant Scan11 Annually See A.(5.) Effluent Permit NC0085359 Notes on the following page: 1. Upstream: 50 feet upstream from the outfall. Downstream samples shall be collected at two locations. D 1: One quarter mile downstream from the outfall, before confluence with the first tributary. D2: at NCSR 1301. Additional downstream dissolved oxygen monitoring is recommended to provide DO stream profile of Twelve Mile Creek in North Carolina and South Carolina. 2. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Monitoring requirement and limit applies only if chlorine is added for disinfection. 6. Part A. (4.) describes the methodology for calculation of the monthly average and 12-month limits. 7. Monitoring requirement may be deleted upon written notification from the permitting authority. 8. The permittee has been granted a schedule of compliance for copper and zinc based on the previous permit condition: The limits for copper and zinc will become effective eighteen (18) months after completion of the site -specific standards. The Division considered 'the site -specific standard study complete in January 2005 when EPA concurred with the inclusion of Cladocerans in the National Dataset. The copper and zinc limits will become effective June 2006. 9. The limits stipulated are based on "total recoverable". Alternatively, the permittee may request limits based on total dissolved as allowed under South Carolina standards. 10. Chronic Toxicity (Ceriodaphnia) P/F @ 90% with testing in February, May, August and November (see A. (3.) Special Conditions of the Supplement to Effluent Limitations). 11. See Special Condition A.(5). There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC0085359 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (3.) CHRONIC TOXICITY PASS/FAIT, PERMIT LIMIT The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum, auarteriu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of February, May, August, and November. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: NC DENR / DWQ / Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0085359 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (4.) TOTAL PHOSPHORUS (TP) MONITORING The Permittee shall calculate a 12-month rolling average mass loading as the sum of monthly loadings, according to the following equations: (1) Monthly Average (pounds/day) = TP x Qw x 8.34 Where: TP = the arithmetic average of total phosphorus concentrations (mg/L) obtained via composite samples (either daily, weekly, or monthly average values) collected during the month Qw = the average daily waste flow (MGD) for the month 8.34= conversion factor, from (mg/L x MGD) to pounds The 12-month rolling average mass loading is defined as the sum of the monthly average loadings for the previous 12 months inclusive of the reporting month: 12 (2) 12-Month Mass Loading (pounds/day)= E TPma =12 (inclusive of reporting month) Where: TPma is defined as the total phosphorus monthly average mass loading (calculated above). The monthly average and 12-month average mass loadings shall be reported on the attached worksheet and submitted with the Discharge Monitoring Report (DMR) for Twelve Mile Creek WWTP. The first worksheet is due with the DMR 12 months from the effective date of the TP limit (referenced in A. (A). In the period between the effective date and the requirement to submit the attached worksh et, the TP monthly average mass loadings should be reported on the appropriate monthly DMR The Permittee shall report the TP concentration for each sample on the appropriate DMR. Reporting of and compliance with the TP limit shall be done on a monthly basis. Permit NC0085359 • Union County -Twelve Mile Creek WWTP Nutrient Worksheet NPDES Permit NC0085359 Reporting Month: Beginning Month: Ending Month: (Month I) (Month 12) Monthly Average Total Phosphorus lbs/day Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 12-Month Mass Loading _ Note: The TP mass loadings for the current reporting month should be entered for Month 1. Permit NC0085359 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A.(5.) EFFLUENT POLLUTANT SCAN The permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the table below (in accordance with 40 CFR Part 136). The annual effluent pollutant scan samples shall represent seasonal (summer, winter, fall, spring) variations over the 5-year permit cycle. Unless otherwise indicated, metals shall be analyzed as "total recoverable." Additionally, the method detection level and the minimum level shall be the most sensitive as provided by the appropriate analytical procedure. Ammonia (as N) Trans-1,2-dichtoroethylene Bis (2-chloroethyl) ether Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether Dissolved oxygen 1,2-dichtoropropane Bis (2-ethylhexyl) phthalate Nitrate/Nitrite 1,3-dichloropropylene 4•bromophenyl phenyl ether Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate Oil and grease Methyl bromide 2-chloronaphthalene Phosphorus Methyl chloride 4-chlorophenyl phenyl ether Total dissolved solids Methylene chloride Chrysene Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate Antimony Tetrachloroethylene Di-n-octyl phthalate Arsenic Toluene Dibenzo(a,h)anthracene Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene Chromium Trichloroethylene 1,4-dichlorobenzene Copper Vinyl chloride 3,3-dichlorobenzidine Lead Acid -extractable compounds: Diethyl phthalate Mercury P-chloro-m-creso Dimethyl phthalate Nickel 2-chlorophenol 2,4-dinitrotoluene Selenium 2,4-dichlorophenol 2,6-dinitrotoluene Silver 2,4-dimethylphenol 1,2-diphenylhydrazine Thallium 4,6-dinitro-o-cresol Fluoranthene Zinc 2,4-dinitrophenol Fluorene Cyanide 2-nitrophenol Hexachlorobenzene Total phenolic compounds 4-nitrophenol Hexachlorobutadiene Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene Acrolein Phenol Hexachloroethane Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene Benzene Base -neutral compounds: Isophorone Bromoform Acenaphthene Naphthalene Carbon tetrachloride Acenaphthylene Nitrobenzene Chlorobenzene Anthracene N-nitrosodi-n-propylamine Chlorodibromomethane Benzidine N-nitrosodimethylamine Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine 2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene Chloroform 3,4 benzofluoranthene Pyrene Dichlorabromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene 1,1-dichloroethane Benzo(k)fluoranthene 1,2-dichloroethane Bis (2-chloroethoxy) methane Permit NC0085359 Test results shall be reported to the Division in DWQ Form- DMR PPA1 or in a form approved by the Director, within 90 days of sampling. A copy of the report shall be submitted to the NPDES Unit at the following address: Division of Water Quality, Surface Water Protection Section, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0085359 Facility Information Applicant/Facility Name: Union County Public Works/ Twelve Mile Creek WWTP Applicant Address: 400 North Church Street Monroe, N.C. 28112-4804 Facility Address: 3104 Providence Road South Waxhaw, NC 28173-8329 Permitted Flow 2.5 MGD Type of Waste: 100% Domestic Facility/Permit Status: Renewal with expansion request for 6.0 MGD Facility Classification W County: Union Miscellaneous Receiving Stream: Twelve Mile Creek Regional Office: Mooresville Stream Classification: C USGS Topo Quad: H15NE/Catawba NE NC -SC 303(d) Listed?: No Permit Writer: Jackie Nowell Subbasin: 03-08-38 Date: July 12, 2005 Drainage Area (mi2): 76.8 Summer 7Q10 (cfs) 0.1 Winter 7Q10 (cfs): 1.5? Average Flow (cfs): 72.7` IWC (%): 2.5 MGD — 97% 6.0 MGD- 99% Primary SIC Code: 4952 SUMMARY OF FACILITY INFORMATION Union County has requested renewal and modification of the Twelve Mile Creek WWTP for expansion to 6.0 MGD. The existing WWTP with a design flow of 2.5 MGD discharges into Twelve Mile Creek, a class C water, in CTB38 subbasin. All wasteflow is 100% domestic and serves the Towns of Waxhaw, Weddington, and others along with portions of Union County for a total of 23750 people. The facility has a pretreatment program but there are no SIUs or CIUs discharging to the system. Union County received its Finding of No Significant Impact (FONSI) from DENR on August 9, 2004. Request for expansion was received on October 19, 2004. During their request for a loan from Construction Grants and Loans (CG&L), additional review of the expansion project was solicited from several agencies. Several comments on the expansion were received from US Fish and Wildfire in January 2005. A prior review of the same project did not generate the same comments from that agency. The agency believed the expansion project would have considerable secondary and cumulative impacts. Primary comments of US F&W recommended buffers on perennial and intermittent streams, stormwater management, review of the impacts on federally listed species, the Schweinitz's sunflower, and others. CG&L needed a response to the USF&W comments before proceeding further with the loan. Although the expansion request was in-house, NPDES did not proceed with the expansion until the County addressed USF&W comments. During the permitting review process, similar comments could resurface if not adequately addressed. Union County responded to USF&W in May 2005. The County will adopt a Land Use Ordinance that will address the endangered species, the Schweinitz's sunflower, and have proposed a stormwater ordinance that will address riparian buffers. CG&L has determined that positive steps are being taken to address USF&W concerns. Based on the Environmental Assessment/Engineering Alternatives Analysis, direct discharge was found to be the most environmental sound and economically feasible alternative. The Division has determined that the proposed expansion is necessary to accommodate social and economic growth in the area and that it will not result in contravention of surface water quality standards or loss of designated uses in the receiving stream. RECEIVING STREAM Twelve Mile Creek is formed downstream of the convergence of West Fork Twelve Mile Creek and East Fork Twelve Mile Creek. Stream flow information was updated in 2002 by USGS. The stream data was updated at the nearby gaging station at Highway 16 just 2500 ft upstream of the Twelve Mile Creek WWTP discharge point. The flows at the discharge point are noted above. Previously, Twelve Mile Creek was considered a zero flow stream with 7Q10 flow =0 and 30Q2>0 and tertiary limits were assigned for protection of water quality. Union County -Twelve Mile Creek WWTP Fact Sheet NPDES Renewal Page 1 Twelve Mile Creek is not listed in North Carolina's 2002 Impaired Waters 303(d) list. In the Catawba River Basin Use Support categories, Twelve Mile Creek from source to NC -SC state line, is: 1) SUPPORTING in the aquatic life category, basis =monitored 2) NOT RATED in the recreation category, basis =monitored The bioclassification rating is based on three sampling events at NC Highway 16: 1) November 1983 — FAIR. 2) July 1989 — GOOD -FAIR. 3) February 1990 — GOOD -FAIR. The fish community assessment located at the same station was rated FAIR in June 11, 1997. However, in 2001,the scores and classes for evaluating the fish community were revised; the revised ratings are as follows: 6/11/97 -GOOD 5/20/02 —GOOD-FAIR Existing Effluent Limits @ 2.5 MGD Summer Winter Monthly GODS = 5 mg/1 10 mg/I Monthly NH3 = 2 mg/1 4 mg/ Widy Avg.NH3 = 5 mg/1 9 mg/1 (SCDHEC recommended that permit contain weeldy avg. limits for NH3 at 2.5 times the monthly avg. NH3 limits). TSS = 30 mg/1 Dissolved Oxygen = 6 mg/1 Fecal Coliform = 200/100m1 pH = 6-9 SU Chronic Toxicity P/F @ 90%; February May August November Daily monitoring for temperature and conductivity. Monthly monitoring for TN Total Phosphorus 41.70 pounds/day — monthly average 20.85 pounds/day 12 month average *Copper 2.9 ug/1 weekly average 3.8 ug/1 daily maximum *Zinc 37.0 ug/1 daily maximum Facility was granted a schedule of compliance for Cu and Zn. Could develop site specific standards. Limits effective 18 months after completion of site specific standards Instream monitoring for DO, fecal coliform, temperature, and conductivity. TOXICITY TESTING: Current Requirement: Chronic Toxicity P/F @ 90%; February May August November The Twelve Mile Creek WWTP has consistently passed the toxicity test since Feb. 2001. One FAIL in February 2002 followed by a PASS. Have passed 12 toxicity tests since that time. Recommend renewal of existing toxicity test @ 90% at 2.5 MGD and at the expansion flow of 6.0MGD. COMPLIANCE SUMMARY: Review of compliance data from January 2003 through Apri1 2005. Problems with the plant in 2005 are discussed at the end of this section. In 2003, Avg. Qw = 1.6 MGD (approximately 64% of capacity), Avg. BOD5=0.52 mg/1, NH3=0.4 mg/1, TSS=1.18 mg/1. Overall compliance in 2003 is good, Two (2) exceedances of daily max. fecal coliform limit of 400/100m1 in July and Aug. One exceedance of weekly avg. NH3 in August. In 2004, Avg. Qw = 1.89 MGD (approximately 76% of capacity), Avg. BOD5=0.75 mg/1, NH3=0.12 mg/I, TSS=1.96 mg/1, One (1) violation in 2004, pH in February. Three fecal daily max. violations in Feb., July, and Sept. One (1) BOD5 weekly avg. exceedance in July. Through May 2005, Avg. Qw = 2.246 MGD (approximately 89% of capacity), BOD5=32.05 mg/1, NH3=12.8 mg/I, TSS=50.55 mg/1. Several violations of limits in 2005 due to plant problems: Five (5) BOD violations, January through May; Three (3) TSS violations, January, April and May; Five (5) NH3 violations, January through April, One (1) TP violation in January Union County -Twelve Mile Creek WWTP Fact Sheet NPDES Renewal Page 2 In January 2005, the WWTP started having problems meeting limits. Notes on DMRs submitted by the ORC on plant noncompliance indicate " excessive filamentous growth upset plant process early in the month of January. Polymers and alum used to improve settlability, as sodium hypochlorite was used to attack filamentous growth. Construction contractor damaged electrical service, which in turn damaged starter of majority of electrical equipment." The manufacturer of electrical starters was contacted for replacement parts. No starters available for purchase. Found a starter to "fit". Electrical control established to half of treatment process within a day or so. In February, the plant equipment was functioning properly but high turbidity did not allow effective disinfection. Treatment process designer and process consultants contacted to aid in process recovery. Trend is positive." In March and April 2005, DMR notes that the plant process recovery is favorable and improvement is expected as temperatures become warmer. They also noted high fecals, in addition to BOD5, NH3, TSS, and TP 12 month mass load exceeded. DWQ has taken enforcement actions based on the violation and penalties totaling over $20,000 have been assessed for the January and February 2005 permit violations. March and April also had violations, but penalties have not determined as yet. INSTREAM MONITORING: Parameters: Dissolved Oxygen, Fecal Coliform, Temperature, Conductivity Upstream #1 — at Highway 16 Upstream#2 50 ft above the outfall, Downstream #1: One -quarter mile below the outfall, before the confluence with the first tributary, Downstream #2: at NCSR 1301 Downstream #3 — at SC S29-93, 2 miles below the outfall Sampled in 2003 only. Sampling recommended during the last permit renewal because of the instream DO problems upstream of the outfall. Wanted to observe whether DO violations would occur in SC due to WWTP's proximity to stateline. Review of instream data from April thru October 2003: The DO standard of 5 mg/1 was being met at all sites both upstream and downstream of the WWTP. The problem parameter seems to be fecal coliform where at the upstream sites values average well above the standard of 200/100m1. Accordingly, the downstream fecal values also continue to exceed the standard. At downstream #1, immediately downstream of the WWTP, monthly fecal values range from 276/100m1 to over 850/100m1. At downstream2, about 1 mile below the outfall, the instream fecal values range from 209/100m1 to 742/100m1. At the furthest downstream site in South Carolina, the NC fecal coliform standard was still being exceeded with values ranging from 209/100m1 to 541/100m1. Review of instream data from April thru October 2004: Upstream 50 ft above the outfall Downstream: '/ mile below the outfall Downstream2: bridge at SR1301 The fecal coliform standard is still being exceeded both upstream and downstream of the WWTP. The average values seem to be lower, however they are still in the 300-400/100m1 ranges. During the months of June through August, the DO standard was exceeded upstream of the WWTP and at the downstream site 'A mile below the plant. In most cases, the downstream DO violation coincided with the upstream DO violation. However, there were some instances when there were upstream violations, but no corresponding downstream DO violation. At the SR1301 site (downstream 2), there were no instream DO violations, even during the 3 month period of upstream violations and violations at downstreaml. REASONABLE POTENTIAL ANALYSIS The following metal parameters are monitored in the NPDES permit until results of a site -specific study are completed: Copper and Zinc. Proposed copper and zinc limits are to protect South Carolina waters. The Twelve Mile Creek WWTP discharges about 2.5 miles from the SC state line. SC and EPA recommend that Union County must not violate instream standards in SC. Previous permit in December 2002 gave option of conducting a site - specific study for determination of limits. Upon completion of the study and development of site -specific standard, if there is reasonable potential to exceed these standards then limits for copper and zinc will be placed in the permit. Site Specific Study Background information: Union County submitted the site -specific criteria study in September 2003. After an extensive review, consultation between the County, their engineering consultants and the Division, along with input from the EPA, site -specific Union County -Twelve Mile Creek WW1? Fact Sheet NPDES Renewal Page 3 standards for the Twelve Mile Creek were developed. Previously, there was a significant discussion on the County's exclusion of Cladocerans from the National Dataset (September 2004 meeting). The Division presented information to the County and EPA that determined that Cladocerans should be included in developing the site -specific criteria. The EPA, East Standard, Monitoring and TMDL Section, reviewed the data and concurred with the Division (Jan. 2005 letter). The County submitted revised site -specific criteria that included Cladocerans in March 2005. The criteria were as follows Copper = 10.2 ug/l, Zinc = 91.6 ug/1. Subsequent information submitted by the County recommended that reasonable potential (RP) did not exist for copper (after exclusion of copper data based on plant treatment problems) and their intention to conduct a Water Effect Ratio study for copper and zinc. However, after evaluation of the copper data and a RP analysis, the Division concluded that RP did exist for both copper and zinc. Although the Twelve Mile Creek plant had some treatment problems, the Division did not eliminate copper and zinc data submitted during that time, from our analysis. Reasonable potential analysis was conducted based on data from 2003 through April 2005. Results and data analysis are attached. The following results will be added to the Twelve Mile Creek WWTP: At existing wasteflow of 2.5 MGD: • A daily maximum limit for copper of 10.5 ug/1 based on reasonable potential to exceed the site specific standard. There were 123 reported copper values and 73 were below the detection level. Recommend that copper limit become effective June 2006 based on the permit condition from the 2002 permit that allows eighteen months from completion of the site specific study for limits to come into effect. The inclusion of copper limits in NC dischargers is rare and most facilities have not had to treat for this constituent. Recommend this be allowed for Union County to best determine methods and treatment for copper removal. • A daily maximum limit for zinc of 94 ug/1 based on reasonable potential to exceed the site specific standard. There were 120 reported zinc values and 4 were below the detection level. Recommend that zinc limit become effective June 2006 based on the permit condition from the 2002 permit that allows eighteen months from completion of the site specific study for limits to come into effect. The inclusion of zinc limits in NC dischargers is rare and most facilities have not had to treat for this constituent. Recommend this be allowed for Union County to best determine methods and treatment for zinc removal. At expansion flow of 6.0 MGD: • A daily maximum limit for copper of 10.3 ug/1 based on reasonable potential to exceed the site specific standard. Based on same information provided above. • A daily maximum limit for zinc of 93 ug/1 based on reasonable potential to exceed the site -specific standard. Based on same information provided above. PROPOSED CHANGES: The following modifications have been made to the permit: 1. The revision of the summer and winter weekly avg. NH3 limits based on NC procedure that has been developed since the last renewal in 2002. In 2002, DWQ used the weekly avg. multiplier of 2.5 recommended by SCDHEC. Current procedure recommends a 3:1 ratio for the weekly avg. NH3 limit for municipalities. Recommend revision of the summer weekly avg NH3 limit from 5 mg/1 to 6 mg/I, and the winter weekly avg. NH3 limit from 9 mg/1 to 12 mg/l. 2. The revision of copper limit based on site -specific standard study done by Union County and updated 7Q10 stream flows determined by USGS. New copper limit is a daily maximum limit of 10.5 ug/l. 3. The revision of zinc limit based on site -specific standard study done by Union County and updated 7Q10 stream flows determined by USGS. New zinc limit is a daily maximum limit of 94 ug/1. 4. The addition of an effluent page for expansion flow of 6 MGD. Limits are as follows: Summer Winter Monthly BODS = 5 mg/1 10 mg/1 Monthly NH3 = 1 mg/1 2 mg/ Wkly Avg..NH3 = 3 mg/1 6 mg/1 TSS = 30 mg/1 30 mg/1 Dissolved Oxygen 6 mg/1 6 mg/1 Fecal Coliform 200/100m1 200/100m1 Union County -Twelve Mile Creek WWTP Fact Sheet NPDES Renewal Page 4 pH = 6-9 SU 6-9 SU Chronic Toxicity P/F @ 90%; February May August November Daily monitoring for temperature and conductivity. Monthly monitoring for TN Total Phosphorus 41.70 pounds/day — monthly average 20.85 pounds/day 12 month average Note: The total phosphorus limit at 6 MGD is the same as at 2.5 MGD. The existing TP limit is based on the CMU/DWQ/SCDHEC Settlement Agreement for the inclusion of phosphorus limits to dischargers to the mainstem of the Catawba (upstream of Lake Wateree). The limit was equivalent to 1 mg/1 at 2.5 MGD. At 6 MGD, the TP limit is equivalent to 0.4 mg/l. SC is still developing the TMDL for phosphorus, therefore DWQ maintained the existing loading at the expansion flow of 6 MGD. Copper 10.3 ug/1 (daily maximum) Zinc 93 ug/1 (daily maximum) PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: 07/20/2005 (est.) Permit Scheduled to Issue: 09/12/2005 (est.) STATE CONTACT: If you have any questions on any of the above information or on the attached permit, please contact Jackie Nowell at (919) 733-5p83 ext. 512. NAM\ '"" "f DATE: RI3.PrIONAL FFICE COMM NT: 7,724/zeor- / SGAl72:' Gti %.�/ 7 ,2 Di: �'1"e72-- G� /47✓ i•tj'/h w To Co,.s %7C'[/c / -. - - - " Ate-! S re.) �G /I9J6/7 To /re/poA-' v/sf'GZa.c/ Ce/v-17 L/c%7O,t% O f gA-1ANs of 7'//c fwe/G/y /j 4uT/�vg, Z) Tv D/5 c6� ( e M 6 , fed /) 7 ,% /A/ 7; 'i5e/11// NAME:ioc�t ram- DATE: IONAL SUPERVISORS NATURE: i /. • I�/ DATE: )1e--/ -� / e Union County -Twelve Mile Creek \V\VFP Fact Sheet NPI)ES Renewal Page 5 NPDES SUPERVISOR COMMENT: NAME: DATE: ti e Union County -Twelve Mile Creek WWTP Fact Sheet NPDES Renewal Page 6 ADDENDUM TO THE FACTSHEET 9/21 /2005 RESPONSE TO COMMENTS BY UNION COUNTY AND EPA COMMENT #1 - UNION COUNTY REQUESTS THAT LANGUAGE BE ADDED TO THE FINAL PERMIT THAT ALLOWS ADEQUATE TIME FOR UCPW TO SUBMIT WATER EFFECTS RATIO RESULTS • RESPONSE - Effluent limitations for copper and zinc have been modified based on the results of the site -specific criteria study that was conducted by Union County. A reasonable potential analysis showed that the discharge had the potential to exceed these site -specific standards. DWQ reviewed the information submitted in the comment letter and re-evaluated the reasonable potential analysis. Data from January 2003 through April 2005 was used in the analysis. Even omitting the two highest copper values, the analysis still indicated reasonable potential. Because of Union County's discharge into Twelve Mile Creek and its eventual drainage into South Carolina's waters, it is necessary to protect for the South Carolina water quality standards. At 2.5 MGD, the copper limit is 10.5 ug/1 and the zinc limit is 94 ug/1. At the expansion flow of 6.0 MGD, the copper limit will be 10.3 ug/1 and the zinc limit will be 93 ug/1. These limits will become effective June 1, 2006. This is consistent with the previous permit condition that stated that limits would become effective eighteen months after completion of the site specific study. After discussions with DWQ in September 2004 that addressed the omission of Cladocerans from the National Dataset, the revised Recalculation Report was submitted by Union County in November 2004. The June 2006 effective date is eighteen months from that submittal date. • The results of the pending Water Effects Ratio study will be evaluated and the appropriate copper and zinc limitations will be applied as required by DWQ. COMMENT #2 - NO REASONABLE POTENTIAL UNION COUNTY IS CONCERNED THAT UNREASONABLE LOW METALS LIMITS ARE BEING PROPOSED FOR THEIR FACILITY --- See response to comment # 1 ADDITIONAL RESPONSE: THE STRINGENCY OF THE LIMITS IS BASED ON THE DESIGN FLOW OF THE PLANT AND THE LOW FLOW OF THE RECEIVING STREAM AT ALMOST ZERO..The combination of those two things, the protection of water quality standards in Twelve Mile Creek will require limits at or very near to the standard.. DWQ can recommend that after twelve months if Union County has discharged copper at or below detection level, they can request in writing that the limitation be reevaluated. The protection of downstream waters in South Carolina is the driving force in the assignment of copper and zinc limits. COMMENT #3 - WEEKLY AVERAGE VS DAILY MAX. LIMIT -UNION COUNTY REQUESTS THAT WEEKLY AVERAGE COPPER LIMITS BE PLACED IN THE PERMIT, RATHER THAN DAILY MAX. LIMITS. WEEKLY AVERAGE COULD BE DETERMINED BY THE AVERAGE OF DAILY COMPOSITE SAMPLES OR A SINGLE SAMPLE. The site -specific study for copper determined only a chronic value for copper and zinc. When only a chronic value is determined, this limit is given as a Union County -Twelve Mile Creek WWII' Fact Sheet. NII)ES Renewal Page. 7 daily maximum limit. If Union County wants a daily max. limit, an acute site specific value must be determined. COMMENT #4 - Consistency of limits. RESPONSE - The difference in the limits found in A(1) and A(2) effluent pages is based on the design flow of the Union County plant. At the higher design capacity fo 6 MGD, limits for copper and zinc will be slightly more stringent than at 2.5 MGD. COMMENT #5 - TRC daily max. vs. daily average RESPONSE - Union County recommends - Daily average limit of 28 ug/1 and weekly average of 17 ug/1. Response: DWQ concurs with this request. COMMENT #6 - Fecal Coliform- The Fecal coliform limit of 200/ 100m1 monthly average and 400/ 100m1 daily maximum will remain in the permit for protection of SC water quality standard. Per telephone conversation with Mark Tye on 9/30/2005, Union County has agreed to the 400/ 100m1 daily maximum limit. DWQ may consult with SC about giving a higher daily max of 1000/ 100m1, and having 400/ 100m1 as weekly average similar to CMU permits, where SC concurred. The receiving stream is not impaired for DO or fecal coliform. COMMENT #7 - Stream monitoring - The requirement of instream monitoring at the frequency of 3/week in the summer and weekly the remainder of the year must be maintained as part of NC regulations for Class IV domestic dischargers. Although Twelve Mile Creek is not impaired for DO, a review of submitted instream data revealed several days in June, July and August 2004 when the dissolved oxygen standard was less than 5.0 mg/1 downstream of the discharge. On most days, the upstream DO was also below the standard on the same day, however there were days when the upstream DO was above 5 mg/land the downstream DO was less than 5 mg/1. The instream monitoring frequency shall remain the same. COMMENT #8 Staffing requirements - The 24 hour staffing requirement will come into effect when Union County is greater than 5 MGD. The Division will not remove this requirement at this time when the facility has not reached the design capacity. Union County currently has the SCADA system and will have enhancements in the future but recent plant problems do not bode well for a variance at this time. Option offered for one 8 hour shift 7 days a week. Will reevaluate closer to time for expansion to 6 MGD; Union Couni.v•••Tvelve Mile Creek W\TI'P Fact. Sheet. NPI.)ES Renewal Page 8 s FACTSHEET AMENDMENT 9/30/2005 Per draft comment from Marshall Hyatt, EPA. 1. Chromium monitoring needed to be added to the permit based on RPA. Although dataset was small w/ only 2 datapoints, RP was predicted. I talked to Mark Tye of Union C unty, and he agreed to doing Cr monitoring for 12 months and having us reevaluate after 12 months. DATE: % C ttwr Union County -Twelve Mile Creek V4'\Vi'l-' Fact Sheet. iNI'I)ES Renewal Page 9 REASONABLE POTENTIAL ANALYSIS Union County -Twelve Mile Creek < NC0085359 > Time Period Qw (MGD) 7010S (cfs) 7010W (cfs) 3002 (cis) Avg. Stream Flow, QA (cfs) Reeving Stream 01/2003-04/2005 2S 0.1 1.5 3.2 72.7 Twelve Mite Creek WWTP Class 4 /WC (%) ®7Q10S 97.484 ® 7Q10W 72.093 • 3002 54.77 ® QA 5.0604 Stream Class C Outfall 001 Qw = 2.5 MGD PARAMETER TYPE (1} STANDARDS & CRITERIA (2) NCWOS/ C raik fSFAV/ M. POL Units REASONABLE POTENTIAL RESULTS n /DAZ Wu ProdCw AlkwrsleCw RECOMMENDED ACTION Arsenic Beryllium Cadmium Chromium NC NC NC 50 1>< 6.5 2 15 50 1.022 ug/L ug/L ug/L 1 0 NIA Note: n<12 Limited data set 1 0 WA Note: n<12 Limited data set 1 0 N/A Note: nc12 Limited data set 2 1 245.8 Note: ne12 Limited data set Acute: WA Chronic, - 51- Copper Cyanide Fluoride Lead NC NC NC NC 102 AL 7.3 5 N 22 1,800 25 N 33.8 10 uL uglL Kit ug!L 123 50 O 0 O 0 1 0 Note: n<12 Limited data 28.6 set N/A Chronic: 5.1 Acute: 7.3 Shows RP to exceed site specific standard. Recommend weekly avg and daily max. Omit for protection of SC WO std Chronic: 10.5--- •--------- ------•----- Acute: 22 N/A WA Mercury Molybdenum Nickel Phenols Selentum Silver NC A NC A NC NC 0.012 P{ 3,500 88 261 1 N 5.0 56 0.06 AL 1.23 0.0002 uglL ugll uglL ugfL uglL uglL Acute: N/A 2 2 0.0030 ____ Note: n<12 Chronic 0.0123 Limited data set 1 0 WA Note: n<12 Limited data set 1 0 WA Note: ne12 Limited data set 0 0 1 0 Note: nc12 Limited data set WA N/A 1 0 WA Note: ne12 Limited data set Acute: WA Chronic: Olt/Crii#9 - Acute: WA Chronic: 19.8 Acute: 56 Chronic: 5.1 Zinc NC 92 AL 67 uL 120 116 1,260.0 Acute: 67 Shows RP to exceed site specific standard, • Recommend _ daily max. limit for protection of. SC WO standard Chronic: -974 — --- -- — - — —•---_- Legend C = Carcinogenic NC = Non -carcinogenic A a Aesthetic " Freshwater Discharge 85359rpa2005.sssalldata.updfio, rpa 7/13/2005 REASONABLE POTENTIAL ANALYSIS Union County -Twelve Mile Creek < NC0085359 > Time Period 0112003-04/2005 Ow (MGD) 6 WWTP Class 4 7Q10S (cfs) 0.1 IWC (%) 0 7010S 98.936 7Q10W (cfs) 1.5 0 7Q10W 86.111 3002 (cfs) 3.2 0 3002 74.4 Avg. Stream Flow, QA (cfs) 72.7 ® QA 11.341 Reeving Stream Twelve Mile Creek Stream Class C Outfall 001 Qw=fi MGD PARAMETER TYPE is) STANDARDS do CRRERIA (2) NCWQS/ fiMir / Monk Acute POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION n /D.L Ma ProdCw Ailcwsble Arsenic Berytikum Cadmium Chromium NC NC NC 50 6.5 2 15 50 t.022 uL ug/L ug/L u9 1 0 N/A Note: n<12 Limited data set 1 0 N/A Note: ne12 Limited data set 1 0 N/A Note: ne12 Limited data set 2 1 245.8 Note: ne12 Limited data set Acute: N/A Chronic: 51 Acute: NIA Chronic: 8.7 Acute: 15 Chronic: 2.0 Copper NC 102 AL 7.3 ug/L 123 50 28.6 Acute: 7.3 Shows RP to"exceed site specific standard. "Recommend xrs woaklyavg and`daity. max limit for of SC W4'std; Chronic: 10.3 — — — — — — — — Cyanide Fluoride Lead Mercury Molybdenum Nickel Phenols Selenium Silver NC NC NC NC A NC A NC NC 5 N 22 1.600 25 N 33.8 0.012 1 3,500 r>.\ 88 261 1 NC>< 5.0 56 0.06 AL 123 10 0.0002 ugA- ug/L ug/L non- ug/L ug/L ug/L ug/L uWL O 0 0 0 WA WA 1 0 N/A Note: ne12 Limited data set 2 2 0.0030 Note: ne12 Limited data set ' 1 0 WA Note: ne12 Limited data set 1 0 N/A Note: ne12 Unshed data set O 0 N/A 1 0 N/A Note: ne12 Limited data set 1 0 WA Note: n<12 Limited data set Acute: 261 Chronic: 88.9 Acute: WA Chronic 8.8 Acute: 56 Chronic: 5.1 Zino NC 92 AL 67 ug/L 120 116 1.260.0 Acute: 67 Shows;RP to`exceed site specific standard. "Recommend _ _ _ — daily max. Itmit for protecgon of SC WO standard Chronic: �93� -- — — — 'Legend: C Carcinogenic NC = Non -carcinogenic A a Aesthetic " Freshwater Discharge 85359rpa2005.sssalidata6.updtb, rpa 7/14/2005 REASONABLE POTENTIAL ANALYSIS 5 15 Copper Zinc Date Data BDL=1/2DL Results 1 Apr-2005 < 2 1.0 Std Dev. 2.4999 2 < 2 1.0 Mean 2.3878 3 < 2 1.0 C.V. 1.0469 4 8.8 8.8 n 123 5 5.8 5.8 6 4.4 4.4 Mult Factor = 1.5900 7 6 6.0 Max. Value 18.0 ug/L 8 < 2 1.0 Max. Pred Cw 28.6 ug/L 9 < 2 1.0 10 8 8.0 11 6 5.5 12 2 2.1 13 < 2 1.0 14 . < 2 1.0 15 Jan-2005 13 13.0 16 Jan-2005 18 18.0 17 Dec-2004 < 2 1.0 18 < 2 1.0 19 < 2 1.0 20 <, 2 1.0 21 < 2 1.0 22 < 2 1.0 23 < 2 1.0 24 < 2 1.0 25 < 2 1.0 26 < 2 1.0 27 <y 2 1.0 28 <Y 2 1.0 29 <1 2 1.0 30 2 1.0 31 2 1.0 32 <' 2 1.0 33 <. 2 1.0 34 3 3.1 35 6 6.3 36 2 1.0 37 2 1.0 38 3 2.6 39 2 1.0 40 2 1.0 41 2 1.0 42 3 3.0 43 4 4.4 44 7 7.1 45 2 1.0 46 2 1.0 47 2 2.0 48 3 2.9 49 2 1.0 50; 2 1.0 51 2 1.0 52 3 2.5 53 2 2.4 54 3 3.3 55 3 2.9 56 0 2 1.0 57 2 1.0 58 7 2 1.0 59 2 1.0 60 < 2 1.0 61 < 2 1.0 62 4 4.1 Date Data BDL=1/2DL Results 1 Apr-2005 < 10 5.0 Std Dev. 2 < 10 5.0 Mean 3 57 57.0 C.V. 4 12 12.0 n 5 28 28.0 6 14 14.0 Mult Factor = 7 61 61.0 Max. Value 8 13 13.0 Max. Pred Cw 9 < 10 5.0 10 < 10 5.0 11 10 10.0 12 87 87.0 13 67 67.0 14 48 48.0 15 47 47.0 16 Jan-5005 100 100.0 17 Dec-2004 110 110.0 18 50 50.0 19 42 42.0 20 38 38.0 21 43 43.0 22 39 39.0 23 51 51.0 24 50 50.0 25 51 51.0 26 48 48.0 27 62 62.0 28 42 42.0 29 52 52.0 30 72 72.0 31 63 63.0 32 48 48.0 33 60 60.0 34 32 32.0 35 69 69.0 36 71 71.0 37 35 35.0 38 72 72.0 39 56 56.0 40 62 62.0 41 61 61.0 42 66 66.0 43 65 65.0 44 67 67.0 45 69 69.0 46 70 70.0 47 64 64.0 48 Jul-2004 720 720.0 49 60 60.0 50 61 61.0 51 47 47.0 52 66 66.0 53 60 60.0 54 63 63.0 55 49 49.0 56 Apr-2004 430 430.0 57 72 72.0 58 42 42.0 59 52 52.0 60 59 59.0 61 61 61.0 62 70 70.0 85359rpa2005.sssalldata.updflo, data - 3 - 7/13/2005 REASONABLE POTENTIAL ANALYSIS 63 7 7.1 64 2 2.4 65 2 2.1 66 "<.°' 2 1.0 67 6 6.3 68 . 2 1.0 69 < 2 1.0 70 <• 2 1.0 71 Dec-2003 2 2.3 72 3 2.7 73 3 2.8 74 <'? 2 1.0 75 t < 2 1.0 76 d <�"q 2 1.0 77 < 2 1.0 78 <a 2 1.0 79 <,I 2 1.0 80 6 5.6 81 2 2.2 82 <• 2 1.0 83 ' < 2 1.0 84 <; 2 1.0 85 < 2 1.0 86 < 2 1.0 87 4 3.6 88 3 3.4 89 5 5.3 90 2 2.2 91 < 2 1.0 92 < 2 1.0 93 < 2 1.0 94 < 2 1.0 95 < 2 1.0 96 < 2 1.0 97 < 2 1.0 98 < 2 1.0 99 < 2 1.0 100 4 3.6 101 7 7.4 102 < 2 1.0 103 < 2 1.0 104 <; 2 1.0 105 < 2 1.0 106 2 2.3 107 ,<€e 2 1.0 108 ,;; 2 1.0 �I<a 109 < 2 1.0 110 3 2.8 111 2 1.0 112 2 1.0 113 -, 3 2.7 114 4 3.5 115 3 2.5 116 3 3.4 117 5 5.3 118 2 2.1 119 4 3.6 120 4 4.3 121 3 3.4 122 4 4.2 123 3 3.4 124 125 63 120 120.0 64 35 35.0 65 38 38.0 66 52 52.0 67 53 53.0 68 59 59.0 69 60 60.0 70 43 43.0 71 Dec-2003 74 74.0 72 69 69.0 73 48 48.0 74 57 57.0 75 62 62.0 76 69 69.0 77 65 65.0 78 65 65.0 79 36 36.0 80 56 56.0 81 37 37.0 82 61 61.0 83 46 46.0 84 65 65.0 85 61 61.0 86 67 67.0 87 54 54.0 88 14 14.0 89 48 48.0 90 22 22.0 91 65 65.0 92 26 26.0 93 17 17.0 94 20 20.0 95 24 24.0 96 25 25.0 97 15 15.0 98 25 25.0 99 28 28.0 100 25 25.0 101 24 24.0 102 24 24.0 103 29 29.0 104 23 23.0 105 23 23.0 106 13 13.0 107 28 28.0 108 22 22.0 109 17 17.0 110 30 30.0 111 24 24.0 112 260 260.0 113 32 32.0 114 30 30.0 115 27 27.0 116 24 24.0 117 35 35.0 118 43 43.0 119 37 37.0 120 38 38.0 121 122 123 124 125 85359rpa2005.sssalldata.updflo, data - 4 - 7/13/2005 REASONABLE POTENTIAL ANALYSIS Union County -Twelve Mile Creek < NC0085359 > Time Period 01/2003.04/2005 Ow (MGD) 2.5 7.010S (cfs) 0 7010W (cfs) 1.5 3002 (cfs) 2.5 Avg. Stream Flow, QA (cfs) 69 Reeving Stream Twelve Mile Creek WWTP Class 4 /WC(%) ®7010S 100 7010W 72.093 3002 60.784 QA 5.3173 Stream Class C Outfall 001 Qw = 2.5 MGD PARAMETER TYPE Itl STANDARDS & CRITERIA (2) POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION NC WOS/ Chronk SFAV/ Acute n 1DeL Mar Prod Cr, Allowtbl.LW Arsenic NC 50 ug/L 1 0 WA Note: n<12 Limited data set Acute: N/A __ _ ______,_—_—_—_—___—•—_—_—_—_—.—_---•-- Chronic: 50 I><-- Beryllium C 6.5 ug/L 1 0 N/A Note: n<12 Limited data set Acute: N/A —--•—•-------- Chronic: 10.7 ---•—•---—_—_--- Cadmium NC 2 15 ug/L 1 0 WA Note: n<12 Limited data set Acute: 15 Chronic: •--2.0------------------•---•—•—•—•----- Chromium NC 50 1,022 ug/L 2 1 245.8 Note: n<12 Limited data set Acute: 1,022 _ Chronic: 50---------------------•—•—•--------- Copper NC 10.2 AL 7.3 ug/L 65 21 13.3 Acute: 7 __ C_ hroni_c: __ 10.2__n-th_ _ / ,A��/ _ - r-4,Y ! ^ t j A'f u/ c 711-li 3 > E0 .+/r///C.. Cyanide NC 5 N 22 10 ug/L 0 0 WA Acute: 22 — Chronic: 5.0 _—._.—.—_—_—_—_—_—_—.____—.___.— Fluoride NC 1,800 ug/L 0 0 WA Acute: N/A Chronic: 1,800 ------- •—•---------•-----•—•---•— Lead NC 25 N 33.8 ug/L 1 0 WA Note: n<12 Limited data set Acute: 34 Chronic: 25.0—--_--•---_—_—_—_---•-----•—•---•^ Mercury NC 0.012 0.0002 ug/L 2 2 0.0030 Note: n<12 Limited data set Acute: N/A __ _ __ _ ___—_—_—_ Chronic: 0.0120 ---- —_---_—_—_—_—_—•—•--- I>< Molybdenum A 3.500 ug/L 1 0 N/A Note: n<12 Limited data set Acute: N/A _ _ _ _ _ Chronic: 8688888A� •—_—_—_—_—_—_—_—_—_—_—_—_—_—_—_— I>< Nickel NC 88 261 ug/L 1 0 WA Note: n<12 Limited data set Acute: 261 Chronic: 88.0 —.__—•-----_—_—_-----_—_—•—_---•—•— Phenols A 1 N ug/L 0 0 N!A Acute: WA Chronic: 18.8 —_—_—_—_—_—_—_—.—,—•—__•—_—_—_—.— r>< Selenium NC 5.0 56 ug/L 1 0 NIA Note: n<12 Limited data set ACule: 56 ---— Chronic: 5.0 T---_—_—-----—_—•-------_--- Silver NC 0.06 AL 1.23 ug/L 1 0 WA Note: ne12 Limited data set Acute: 1 __ _ _ C• hronic: 0.06—,_—•-------------_— --- —_-----_--- Zinc NC 92 AL 67 ug/L 65 61 119.2 Acute: 67 _ _ _ ---_—__—_—_—_—_—_—_—•—_—•—•_•__—•—•—•— Chronic:92 -Legend: C = Carcinogenic NC = Non.carcinogenic A = Aesthetic Freshwater Discharge 85359rpa2005.v4sss.nooutstss60out. rpa 9/23/2005 REASONABLE POTENTIAL ANALYSIS 5 Copper Date Data BDL=1/2DL Results 1 Apr-2005 < 2 1.0 Std Dev. 2 < 2 1.0 Mean 3 < 2 1.0 C.V. 4 5 6 4.4 4.4 Mult Factor = 7 6 6.0 Max. Value 8 < 2 1.0 Max. Pred Cw 9 < 2 1.0 10 11 6 5.5 12 2 2.1 13 < 2 1.0 14 < 2 1.0 15 Jan-2005 16 Jan-2005 17 Dec-2004 < 2 1.0 18 < 2 1.0 19 < 2 1.0 20 < 2 1.0 21 < 2 1.0 22 < 2 1.0 23 < 2 1.0 24 < 2 1.0 25 < 2 1.0 26 < 2 1.0 27 < 2 1.0 28 < 2 1.0 29 < 2 1.0 30 < 2 1.0 31 < 2 1.0 32 < 2 1.0 33 < 2 1.0 34 3 3.1 35 6 6.3 36 < 2 1.0 37 < 2 1.0 38 3 2.6 39 < 2 1.0 40 < 2 1.0 41 < 2 1.0 42 3 3.0 43 4 4.4 44 7 7.1 45 < 2 1.0 46 < 2 1.0 47 2 2.0 48 3 2.9 49 < 2 1.0 50 < 2 1.0 51 < 2 1.0 52 3 2.5 53 2 2.4 54 3 3.3 55 3 2.9 56 < 2 1.0 57 < 2 1.0 58 < 2 1.0 59 < 2 1.0 60 < 2 1.0 61 < 2 1.0 62 4 4.1 63 7 7.1 64 2 2.4 65 2 2.1 66 < 2 1.0 67 6 6.3 68 < 2 1.0 69 < 2 1.0 70 < 2 1.0 71 n 1.6931 1.9462 0.8700 65 1.8700 7.1 ug/L 13.3 ug/L 85359rpa2005.v4sss.nooutstss60out, data - 1 - 9/23/2005 REASONABLE POTENTIAL ANALYSIS Union County -Twelve Mile Creek < NC0085359 > Time Period 01/2003-04/2005 Ow (MGD) 2.5 7Q10S (cis) 0 7QIOW(cls) 1.5 3002 (cis) 2.5 Avg. Stream Flow, QA (cis) 69 Reeving Stream Twelve Mile Creek WWTP Class 4 IWC (%) C 7Q10S 100 ® 7010W 72,093 ® 3002 60.784 @ QA 5.3173 Stream Class C Outfall 001 Ow = 2.5 MGD PARAMETER TYPE (1) STANDARDS & CRRERIA (2) POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION NC WOs/ !S FAV/ Chronic Acuff n IDot Mar Prodclr AllowabMCw Arsenic NC ug/L Acute: N/A 1 0 WA Note: n<12 i Chronic:---50 Limited data set •---_---_---_—____ 50 V<.. Beryllium C 6.5 ug/L 1 0 WA Note: n<12 Limited data set Acute: NIA 7--•_•—`_. —Chronic-T.— 10._ ---- — Cadmium NC 2 15 ug/L 1 0 WA Note: n<12 Limited data set Acute: 15 Chronlc: 2.0—--------------•—•-------——^ Chromium NC 50 1,022 ug/L 2 1 245.8 Note: n<12 Limited data set Acute: 1,022 l_•_•_•_ _--_•_ Chronic: 50 — Copper NC 10.2 AL 7.3 ug/L Acute: 7 68 24 16.7 Chronic: 102 ,y�}� _ /fT Efr/Kr fn� ilieth$0;2; Cyanide NC 5 N 22 10 ug/L Acute: 22 0 0 WA Chronic: 5.0—�•—•_--._. _.__-_. _.__._. _.___.—__._ Fluoride NC 1,80u1 ug/L 0 0 N/A iChronic: 1 Acute: N/A 1,800 -------------•—•-----•—•--------- Lead NC 25 N 33.8 ug/L Acute: 34 1 0 WA Note: n<12 Chronic: __ 25.0__-----------_-------------------_ Limited data set Mercury NC 0.0002 ug/L Acute: WA 2 2 0.0030 _ _ __ ___--------•_-_-_•_•_•_•_•_•_•—____ Note: n<12 Chronic: 0.0120 Limited data set I` 0.012 <, V Molybdenum A ug1L Acute: WA 1 0 WA __ _ __ _ _ Note: n<12 Chronic: MAMA Limited data set •_•_-_•_•----_-_-_-_-_•_•—•—•_•— 3.500 Pc( Nickel NC 88 261 ug/L Acute: 261 1 0 WA Note: n<12 Chronic: 88.0—_-_•—•—•—•—•------------•—•—•_ Limited data set Phenols A ug/L Acute: N/A 0 0 N/A Chronic: 18.8 ,--•_•_•_•_•_•_•_-_•_•_•___•_-_•_ 1 N >< Selenium NC 5.0 56 ug/L Acute: 56 1 0 WA Note: n<12 Chronic: 5.0 —_-----------------------_-------- Limited data set Silver NC 0.06 AL 1.23 ug/L Acute: 1 1 0 N/A Note: n<12 Chranlc: 0.06—•—•—•—•_•_•—•—•--•—•—•—•—•_•--- Limited data set Zinc NC 92 AL 67 ug/L Acute: 67 65 61 119.2 •Legend: C = Carcinogenic NC = Non•carcinogenic A = Aesthetic Freshwater Discharge 85359rpa2005.v3sss, rpa 9/23/2005 REASONABLE POTENTIAL ANALYSIS 5 Copper Date Data BDL=1/2DL Results 1 Apr-2005 < 2 1.0 Std Dev. 2.0363 2 < 2 1.0 Mean 2.1926 3 < 2 1.0 C.V. 0.9287 4 8.8 8.8 n 68 5 5.8 5.8 6 4.4 4.4 MuIt Factor = 1.9000 7 6 6.0 Max. Value 8.8 ug/L 8 2 1.0 Max. Pred Cw 16.7 ug/L 9 2 1.0 10 8 8.0 11 6 5.5 12 x 2 2.1 13 z' 2 1.0 14 < 2 1.0 15 Jan-2005 16 Jan-2005 17 Dec-2004 < 2 1.0 18 < 2 1.0 19 < 2 1.0 20 < 2 1.0 21 G^ 2 1.0 22 2 1.0 23 2 1.0 24 2 1.0 25 2 1.0 26 2 1.0 27 2 1.0 28 c' 2 1.0 29 < 2 1.0 30 < 2 1.0 31 < 2 1.0 32 < 2 1.0 33 < 2 1.0 34 3 3.1 35 6 6.3 36 2 1.0 37 2 1.0 38 3 2.6 39 C, 2 1.0 40 <+ 2 1.0 41 < 2 1.0 42 3 3.0 43 4 4.4 44 7 7.1 45 < 2 1.0 46 < 2 1.0 47 2 2.0 48 3 2.9 49 < 2 1.0 50 <' 2 1.0 51 2 2 1.0 52 3 2.5 53 2 2.4 54 3 3.3 55 3 2.9 56 <' 2 1.0 57 < 2 1.0 58 < 2 1.0 59 < 2 1.0 60 < 2 1.0 61 < 2 1.0 62 4 4.1 63 7 7.1 64 2 2.4 65 2 2.1 66 <' 2 1.0 67 6 6.3 68 < 2 1.0 69 < 2 1.0 70 < 2 1.0 71 85359rpa2005.v3sss, data - 1 - 9/23/2005 Union County -Twelve Mile Creek WWTP @ 2.5 MGD Residual Chlorine 7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (UG/L) UPS BACKGROUND LEVEL (I IWC (%) Allowable Concentration (ug, Fecal Limit Ratio of 0.0 :1 Ammonia as NH3 (summer) 0.1 7Q10 (CFS) 2.5 DESIGN FLOW (MGD) 3.875 DESIGN FLOW (CFS) 17.0 STREAM STD (MG/L) 0 UPS BACKGROUND LEVEL 97.48 IWC (%) 17.44 Allowable Concentration (m Ammonia as NH3 (winter) 7Q10 (CFS) 200/100m1 DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) UPS BACKGROUND LEVEL IWC (%) Allowable Concentration (m 0.1 2.5 3.875 1.0 0.22 97.48 1.02 1.5 2.5 3.875 1.8 0.22 72.09 2.41 7/14/2005 Union County -Twelve Mile Creek WWTP @ 6.0 MGD Residual Chlorine 7010 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (UG/L) UPS BACKGROUND LEVEL (I IWC (%) Allowable Concentration (ugd Fecal Limit Ratio of 0.0 :1 Ammonia as NH3 (summer) 0.1 7010 (CFS) 6 DESIGN FLOW (MGD) 9.3 DESIGN FLOW (CFS) 17.0 STREAM STD (MG/L) 0 UPS BACKGROUND LEVEL 98.94 IWC (%) 17.18 Allowable Concentration (m Ammonia as NH3 (winter) 7010 (CFS) 200/100ml DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) UPS BACKGROUND LEVEL IWC (%) Allowable Concentration (m 0.1 6 9.3 1.0 0.22 98.94 1.01 1.5 6 9.3 1.8 0.22 86.11 2.05 7/14/2005 UPSTREAM Union County - Twelve Mile WWTP DOWNSTREAM MONTH Temp DO Saturatior Fecal ;onductivity Temp DO Saturatior Fecal :onductivity Oct-04 17 7.5 78% 379 157.8 18 7 74% 402 198.5 Sep-04 20 6.9 76% 312 135.2 21 6.8 76% 324 166.9 Aug-04 22 5.6 64% 309 137.4 23 5.5 64% 341 230.1 Jul-04 23 5 58% 432 146.4 23 5.3 62% 372 253.4 Jun-04 22 5 1 57% 430 153.6 22 5.1 58% 371 242 May-04 19 6 65% 101 174 19 6.2 67% 75 247 Apr-04 15 7.8 77% 119 166.2 15 7.5 74% 113 195.2 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0% 0% Notes 1 - 50 ff.above outfall, Dwn 1- 1/4 mi below outfall UP..S Al/1r 2VUf - �70‘1, n .�a4J L� i.“' '74 0 Ij i/r// /Z j.k✓,% � !f ze-u�- /y *' s 60 ` N <3 pxo . jo 7 a j 6t/� S�x�'/e 7/6//f /9-Zy 20 z& -Z7 ; .5' 4.r ,. — 7/9/S' az 2-4 -27 / fo6t 611•,,..1-, ./.L - 6// J-' 7 9 is 457 z/ 6 a4.r ,r;,,f/L- 6/3Q / /s- /7 o7t—/.Y(4r,r av/7 -/3d� (IPs - `%✓ndd t) — /�afer Dull/ VT/A4- oY - /j/06r NC0085359 7/13/2005 �/s r 8 zi` UPI � � /.e. UPS 2 6d1.i t�.,.� d UPSTREAM Union County - Twelve Mile WWTP DOWNSTREAM MONTH Temp DO 3aturatior Fecal conductivity Temp DO Saturatior Fecal conductivity Oct-04 17 7.5 78% 379 157.8 18 7.34 78% 305 200 Sep-04 20 6.9 76% 312 135.2 21 6.99 78% 366 167.5 Aug-04 22 5.6 64% 309 137.4 23 6.03 70% 503 235.3 Jul-04 23 5 58% 432 146.4 0% Jun-04 22 5 57% 430 153.6 22 5.8 66% 292 248.2 6.08 May-04 19 66% 101 174 19 6.4 69% 64 249.8 Apr-04 15 7.8 77% 119 166.2 15 7.82 78% 112 196.8 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0% 0% Notes psi - 50 ff.above ouffall, Dwn2- Bridge at 1301 NC0085359 7/13/2005 UPSTREAM Union County - Twelve Mile WWTP DOWNSTREAM MONTH Temp DO 3aturatior Fecal Donductivity Temp DO Saturatior Fecal Donductiv4 Oct-03 14 7.7 75% 737 151.2 15 7.4 73% 581 180.6 Sep-03 20 6.5 72% 496 153.4 20 6.31 69% 403 187.1 Aug-03 23 6.45 75% 874 122.6 23 6.4 75% 868 138 JuI-03 23 6.6 77% 705 121.4 23 6.4 75% 582 136.9 Jun-03 21 7 79% 437 128.1 21 6.8 76% 385 139.3 May-03 18 7.9 84% 397 117.8 18 7.4 78% 359 128 Apr-03 16 9 91 % 273 112.8 16 8.7 88% 276 123.4 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0°%° 0 0 0 0 0% 0 0 0 0 0% 0 0 I 0% 0% Notes 1 - 50 ff.above ouffall, Dwn l - 1 /4 mi below ouffall NC0085359 7/13/2005 UPSTREAM Union County - Twelve Mile WWTP DOWNSTREAM MONTH Temp DO Saturatior Fecal conductivity Temp DO Saturatior Fecal Donductivity Oct-03 14 7.6 74% 15 7.4 73% Sep-03 20 6.5 72% 20 6.4 70% Aug-03 23 6.41 75% 23 6.3 73% JuI-03 23 6.5 76% 632 122.2 23 6.5 76% 541 137.6 Jun-03 21 6.8 76% 557 129.3 21 7.06 79% 383 140.3 May-03 18 7.8 82% 429 121.2 18 7.9 84% 316 128 Apr-03 16 8.8 89% 269 116 16 8.9 90% 209 122 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0% 0% Notes .2 - At Highway 16, Dwn2- Bridge at SCS29-93, 2 mi. below outfall NC0085359 7/13/2005 UPSTREAM Union County - Twelve Mile WWTP DOWNSTREAM MONTH Temp DO Saturatior Fecal conductivity Temp DO Saturatior Fecal Donductivity Oct-03 14 7.7 75% 737 151.2 15 7.7 76% 480 183.6 Sep-03 20 6.5 72% 496 153.4 20 6.6 73% 334 191.9 Aug-03 23 6.45 75% 874 122.6 23 6.5 76% 742 139.3 JuI-03 23 6.6 77% 705 121.4 23 6.5 76% 541 137.6 Jun-03 21 7 79% 437 128.1 21 7.06 79% 383 140.3 May-03 18 7.9 84% 397 117.8 18 7.92 84% 316 128.2 Apr-03 16 9 91 % 273 112.8 16 8.9 90% 209 122.2 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 1 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0 0 0% 0 0 0% 0°%° Notes Upsl - 50 ft.above outfall, Dwn3- at SR 1301 NC0085359 7/13/2005 \lEO st4i, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY .5 yw REGION 4 e ATLANTA FEDERAL CENTER 61 FORSYTH STREET PRO ."C' = ATLANTA, GEORGIA 30303-8960 OCT 0 1 i005' Ms. Jackie Nowell North Carolina Department of Environment and Natural Resources Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJ: Draft NPDES Permit Union County Twelve Mile Creek WWTP - Permit No. NC0085359 Dear Ms. Nowell: In accordance with the EPA/NCDENR NPDES MOA, we have completed review of the draft permit specified above. Contingent on the permit containing a daily maximum fecal coliform limit of 400/100 ml, we have no comments or objections to its conditions. We request that we be afforded an additional review opportunity only if significant changes are made to the draft permit prior to issuance or if significant comments objecting to it are received. Otherwise, please send us one copy of the final permit when issued. If you have any questions, please call me at (404) 562-9304. Sincerely, NIAt Marshall Hyatt, Environmental Scientist Permits, Grants, and Technical Assistance Branch Water Management Division ! ^Y OCT 5 2005 Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable o1 Based Inks on Recycled Paper (Mlnimurn 30 % Postconsuhier)' Y %+ SUMMARY OF CMUD/DWQ/SCDHEC SETTLEMENT AGREEMENT INTRODUCTION In the summer of 2001, the South Carolina Department of Health and Environmental Control (SCDHEC) filed a Petition for a Contested Case in the North Carolina Office of Administrative Hearings regarding the renewal of NPDES Permit No. NC0024970, the Charlotte Mecklenburg Utilities Department (CMUD) McAlpine Creek Wastewater Treatment Plant. The primary complaint on the part of SCDHEC has been that the permit was renewed without a phosphorus limit. Nearly all of South Carolina's municipal dischargers to the mainstem Catawba (upstream of Lake Wateree) have been given phosphorus limits, generally equivalent to 1 mg/L. The McAlpine Creek WWTP permit had a phosphorus optimization study special condition that stipulated preparatory requirements for the facility to ready itself for the upcoming phosphorus Total Maximum Daily Load (TMD;!), Since the summer, SCDHEC, the North Carolina Division of Water Quality (NCDWQ) and CMUD have been working towards achieving consensus on an appropriate phosphorus limit for the McAlpine Creek WWTP. The understanding has been that this decision will also affect DWQ's permitting strategy for three additional municipal permits: CMUD - Irwin Creek WWTP, CMUD - Sugar Creek WWTP, and Union County - 12-Mile Creek WWTP. The final settlement agreement includes the terms of the limits for all three CMUD plants. A similar strategy will be used by DWQ to limit phosphorus in the Union County permit. SUMMARY OF SETTLEMENT AGREEMENT Limits at McAlpine Creek WWTP Based upon a construction schedule provided by CMUD during the settlement proceedings, the compliance date for the total phosphorus limit at the McAlpine Creek WWTP is set for February 28, 2006. At this time, the McAlpine Creek WWTP must meet a 534 lbs./day total phosphorus limit. This limit is to be calculated as a 12-month rolling average. It corresponds to a 1 mg/L limit at McAlpine Creek's permitted flow of 64 MGD. This limit, as well as the monthly mass cap described below, shall be incorporated into a major modification to NPDES Permit NC0024970 with special condition language to be included with reference to the Irwin and Sugar Creek WWTPs. Since SCDHEC's stipulation was that any limit come into effect prior to the expiration date of the permit, the permit expiration date will also be modified to February 28t, 2006 (instead of June 30, 2005). This puts the permit out of sync with the Basinwide schedule, but is within the five years allowable for a permit term under federal regulations. Bubble Limit A major point of the settlement agreement is the idea of a bubble limit. This refers to a mass limit for total phosphorus that applies to discharge at the three CMUD plants combined. This type of a limit would give CMUD more operational flexibility with regard to phosphorus removal. The bubble limit, to be calculated as a 12-month rolling average, is 826lbs.day of total phosphorus from all three CMUD plants. This corresponds to a 1 mg/L phosphorus limit at permitted discharge for the three plants. If CMUD conducts construction activities at either the Sugar or Irwin Creek plants, the compliance date for this bubble limit will be February 28, 2007. If CMUD decides not to conduct construction activities at either plant in order to achieve compliance, the bubble limit will come into effect on February 28, 2006. This is identical to the compliance date at the McAlpine Creek plant. Special condition language will be included in the Irwin and Sugar Creek WWTP permits regarding the compliance date. Mass cap In order to be protective of the water quality at the downstream lakes in South Carolina, SCHEC requested that monthly mass caps also be included as part of the total phosphorus limits at the three CMUD plants. This would also ensure optimized operation of the plants at all times. The mass caps at the three plants take the form of a monthly average mass limit and correspond to a concentration limit of 2 mg/L at maximum permitted flow. At McAlpine Creek, this limit is 1,0671bs. /day of total phosphorus beginning February 29, 2006. At the Sugar and Irwin Creek plants, the mass caps only come into effect if construction activities are pursued at each plant. At Sugar Creek WWTP, the limit is 334 lbsiday with compliance commencing on February 28, 2007. At Irwin Creek WWTP, the limit is 250lbs.day with compliance commencing on February 28, 2007. TMDL As part of the settlement agreement DWQ requested a provision for full inclusion in the TMDL process for both DWQ and all affected NC entities (to be provided in a list by DWQ). APPLICABILITY TO PERMITTING PROCESS The three CMUD permits will have the bubble limit included as a special condition. Monitoring for phosphorus will be included in the regular effluent limit pages. Mass caps will also be included in the effluent limit pages, with a footnote specifying applicability (for Sugar and •Erwin Creek plants) and compliance dates. t The Union County - 12 Mile Creek WWTP shall have a mass limit equivalent to 1 mg/L at the permitted flow. As with the three CMUD plants, compliance for this limit is to be judged as a rolling annual average. Special monitoring language is being developed for this situation. It is also recommended that the phosphorus optimization study special condition from the original McAlpine Creek WWTP permit be included in this permit to allow DWQ time to review the County's preparations for the impending phosphorus TMDL. C,,,4� 3"�� ,7fL Re: Fw: comments on Union County Twelve Mile Creek WWTP, N... • Subject: Re: Fw: comments on Union County Twelve Mile Creek WWTP, NC0085359 From: Hyatt.Marshall@epamail.epa.gov Date: Mon, 12 Sep 2005 08:20:30 -0400 To: Jackie Nowell <j ackie.nowell @ ncmail.net> thanks for getting me your responses. here are some followup thoughts.... #1 - I now understand where you are coming from re Cr. However, if you monitor only via annual scan, at the next permit renewal, you will be in the same situation as you are now of a small dataset and a high multiplier. I suggest monthly monitoring for one year and then re-evaluate the data based on 12 data pts or so. what do you think? #3 - 2/month sampling until the limits are effective is fine with me. It just wasn't clear before what, if any, monitoring was required during this timeframe. re fecal coliform - doesn't the permit limit need to be a daily max, rather than weekly avg, to meet SC WQS? 1 of 1 9/29/2005 10:05 AM Re: Fw: comments on Union County Twelve Mile Creek WWTP, N... • Responses to your draft comments. #1 - Regarding the RP for Chromium - There were only two reported values for Chromium (<2 ug/1 and 5.6 ug/1) and both were well below the allowable conc. of 51 ug/1. Because of the low # of observations and the C.V., the multiplier is approx. 44 and a max. pred. of 245 ug/1 is calculated. It is highlighted as a limited dataset and is the reason for using 8-12 values for a "more" valid RPA. Despite the high. max. predicted, it is my judgement that chromium is not a parameter of concern and neither a limit or monitoring should be required. It will sampled in the annual PPA in the future. #2 - Cu limit - This was discussed by Matt Matthews, Susan and myself and it was determined that because in the site specific study Union County only developed a chronic value, we would be conservative and make that value a daily maximum limit. #3 - Cu and Zn will be monitored weekly in the permit, until the limits come into effect. (Since the limit is not in effect until June 2006, should they have 2/month and then weekly when the limit starts?) #4 - I will correct the special condition for the pollutant scan to A(5). #5 - Total nitrogen is not limited and should not be cited in footnote 6. I will modify the nutrient worksheet to include only monthly average total phosphorus lbs/day. #6 - I will correct footnote 6 to read "12 month average limits" instead of "12 month limits".. #7 - I will make the correction in A(4). to reference A(1) instead of A (3). Union County submitted several comments on the draft permit. The following modifications will be made to the permit based on their comments. Total residual chlorine- at the facility's request to ensure results that are more accurate and more representative of their effluent, there will be a weekly average limit of 17 ug/1 and a daily average of 28 ug/1. DWQ concurs with this request. This is the same as CMU requested for both their permits (Irwin, Sugar)and was previously approved by EPA. and DWQ's Aquatic Toxicology Unit. Fecal coliform - A weekly average limit of 400/100m1 will be given instead of a daily maximum limit. The daily maximum limit was given in error. Please contact me if there are any questions. 2 of 2 9/21/2005 11:32 AM Re: Fw: comments on Union County Twelve Mile Creek WWTP, N... .• Subject: Re: Fw: comments on Union County Twelve Mile Creek WWTP, NC0085359 From: Jackie Nowell <j ackie.nowell @ ncmail.net> Date: Thu, 08 Sep 2005 17:23:54 -0400 To: Hyatt.Marshall@epamail.epa.gov CC: Susan Wilson <susan.a.wilson@ncmail.net> Hyatt.Marshall@epamail.epa.gov wrote: got a couple of comments from our enf section... Forwarded by Marshall Hyatt/R4/USEPA/US on 08/15/2005 08:38 AM Marshall Hyatt/R4/USEPA/U S To jackie.nowell@ncmail.net 08/10/2005 05:07 cc PM debessjp@dhec.sc.gov, Lisa-Perras Gordon/R4/USEPA/US@EPA Subject comments on Union County Twelve Mile Creek WWTP, NC0085359 let me know what you think of these 1. I am a little confused. Looking at the RP analyses for chromium, it appears that the max predicted value exceeds the chronic allowable Cw (but not the acute). Why isn't there a limit for chromium? 2. For Cu, the RP analysis comments say that the permit should contain weekly avg and daily max limits to protect for SC WQS. However, the permit only contains daily max limits for each flow. Pls explain. 3. For Cu and Zn, the permit limits for both flows become effective June 2006. Until then, is weekly sampling for each required? 4. In A(1), the pollutant scan sample type refers to A(6). It should refer to A(5) . 5. In A(1), shouldn't total nitrogen cite footnote 6 also? 6. In footnotes 6, shouldn't they say "12 month average limits"? 7. In A(4), second to last paragraph, second sentence, shouldn't it say A(1), rather than A(3)? Marshall, 1 of 2 9/21/2005 11:32 AM UNION COUNTY PUBLIC WORKS Christie L. Putnam, P.E., Interim Director Mr. David Goodrich, Branch Head NC Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJECT: Dear Mr. Goodrich: August 18, 2005 Draft NPDES Permit Permit No. NC0085359 Twelve Mile Creek WWTP Union County, North Carolina itj[(�(�\=7 ! AUG 2 2 2005 DE'r:R - WATE:Z OU LITY POINT SOURCE E .;i RCN Union County Public Works (UCPW) is in receipt of the referenced Draft Permit and understands that the Division is accepting comments on the Draft until August 26, 2005. UCPW would like to take the opportunity to comment on the Draft at this time. UCPW feels that there are some permit requirements that will place undue burdens on UCPW while doing very little to preserve or improve water quality. In general, UCPW has concerns with the metals copper and zinc, chlorine residual, Fecal Coliform, stream monitoring and staffing requirements as currently contained in the Draft. Please find below pertinent background information as well as an explanation of specific concerns for each. Copper and Zinc Background - Timeline for Compliance UCPW was issued a permit that took effect January 1, 2003. The permit contained a Schedule of Compliance (SOC) for copper and zinc. The SOC provided that UCPW would submit a report detailing the development of site specific standards or accept the ultra low limits of Daily Maximum concentrations of 3.8 ug/I for copper and 37 ug/I zinc within 21 months of the permit's effective date. The following timeline as it relates to copper and zinc has occurred: ✓ NPDES Permit effective date ✓ Submission of Technical Study Plan to DWQ ✓ Submission of Recalculation Report to DWQ ✓ Submission of Recalculation Report to SCDEHC ✓ Receipt of DWQ review comments ✓ Meet with DWQ ✓ Submit revised Recalculation Report to DWQ ✓ Receive DWQ Comments ✓ Resubmit Site Specific Criteria to Include Cladocerans in Data Set January 1, 2003 April 27, 2003 August 28, 2003 October 20, 2003 July 26, 2004 September 30, 2004 November 3, 2004 February 9, 2005 March 24, 2005 400 North Church St. • Monroe, North Carolina 28112-4804 • Phone: (704)296-4210 • Fax: (704)296-4232 ✓ Reasonable Potential Analysis for Copper To DWQ ✓ Receive DWQ Comments ✓ Notify DWQ of intent to conduct WER on On Copper and Zinc (e-mail to J. Nowell) Specific — Timeline for Compliance June 2, 2005 July 1, 2005 July 22, 2005 Although UCPW and DWQ have been diligently pursuing resolution of concerns surrounding the metals copper and zinc, this is new territory for both parties, and consequently, the process has not been rushed. Due to these same facts, UCPW is concerned that the Draft states that the copper and zinc limits (10.5 ug/I and 94 ugll respectively) become effective June 2006. UCPW plans to initiate a Water Effect Ratio (WER) study for copper and zinc prior to limits taking effect, however, the WER must be conducted over two seasons in order to comply with EPA guidelines. UCPW anticipates completing the WER by mid to late October and submitting a report to DWQ in November 2005. UCPW respectfully requests that language be added to the final permit that allows adequate time for UCPW to submit (and resubmit as necessary) and DWQ to evaluate and comment on the upcoming WER before limits for copper and zinc become effective. Background — No Reasonable Potential In correspondence dated June 2, 2005 Hazen and Sawyer Environmental Engineers and Scientist (H&S) submitted a Reasonable Potential Analysis for copper to DWQ on behalf of UCPW. The conclusion of the analysis was that under representative operating conditions the Maximum Predicted Concentration of 7.48 ug/I of copper was less than the established Site Specific Concentration of 10.2 ug/I and therefore no limit for copper should be required. Copper data which was collected using clean techniques was evaluated for reasonable potential at the 99% probability level using the 10.2 ug/I total recoverable limit as the evaluation point. The data was edited to adjust for a period of elevated effluent Total Suspended Solids (TSS) and a single outlier. The data editing should be justifiable due to the fact that the elevated solids were the result of a combination of events that culminated into an upset condition and are highly unlikely to reoccur in a similar fashion due to safeguards being implemented as part of the upcoming expansion form 2.5 mgd to 6.0 mgd (please see the attached letter to Ms Susan Wilson for more specific detail). A summary of the events leading up to the upset conditions are as follows: ✓ December 2004: The twelve (12) month average for phosphorous exceeded the 20.85 pound per day limit by a slight amount. All other parameters were well within permit limits. ✓ January 2005: Staff initiated the feeding of aluminum sulfate to enhance phosphorous removal in the treatment facility. An increase in the SVI was also observed, and staff began feeding alum to improve the settling characteristics of sludge in the secondary clarifiers. Later in the month, mixed liquor and foam samples were sent out for evaluation. Results confirmed that the Twelve Mile biomass contained excessive filamentous bacteria. In late January staff began to feed sodium hypochlorite in an effort to combat the filamentous growth and to restore stability to the treatment plant operations. ✓ On January 28, 2005, a catastrophic loss of power occurred. A contractor working in the immediate VVWTP area hit a utility pole, disrupting electrical service to the Page 2 of 6 Twelve Mile Creek Wastewater Treatment Plant. Power was restored fairly promptly; but the plant facilities sustained major damage due to "single phasing" to aerators, mixers, and one clarifier. The loss of treatment components effectively crippled the biological system. ✓ By February 3, 2005, most of the critical equipment components were returned to service. Unfortunately, by this time the biological process was irreversibly upset due to the combination of filamentous bacteria (one abundant strain favored septicity), chemical dosing, the sustained loss of power and low water temperatures. ✓ On April 9, 2005, the VFD's for the RAS pumps failed du to a power surge that occurred as the result of intense storms in the area. Staff was not able to get replacement equipment installed until the 22nd of April. Clarifier underflow was returned to the head of the plant via the drain system in a makeshift effort to balance the biological process. ✓ By May 2005, staff observed a recovery of plant operations, and an improved level of operating efficiencies. ✓ By June 2005 the facility was compliant with all parameters except phosphorous; and staff continued to see recovery and improvements in all aspects of plant performance. ✓ In July 2005 monitoring data was compliant with NPDES limits with the exception of one (1) daily maximum Fecal Coliform and phosphorous. Specific Concern(s) — No Reasonable Potential UCPW is concerned that unreasonably low metal limits are being proposed for the Twelve Mile facility. Under representative operating conditions, statistical evaluation suggests that there is no reasonable potential to exceed the derived site specific copper concentration. It is respectfully requested that due consideration be given to removing copper as a limited pollutant due to the high probability that it will not be present in forms or concentrations likely to adversely impact water quality. It is further requested that, if the inclusion of metal limits is inevitable, language be added in the permit that allows the discontinuance of monitoring for any and all metals after twelve (12) consecutive months of compliance with applicable limits (an additional option could be to conduct a reasonable potential evaluation of the 12 month data using the WER developed site specific alternative standard as a basis for compliance). Background — Daily Max vs. Weekly Average The draft permit for Twelve Mile places Daily Maximum Total Recoverable metal limits of 10.5 ug/I and 94 ug/I on copper and zinc respectively. Specific Concern(s) — Daily Max vs. Weekly Average A single sample may not be representative of the actual quality of the effluent. In addition to collection and analysis techniques, there are a number of variables that will influence the concentration of metals in the complex wastewater matrix. In an effort to better ensure accurate and representative results, it is respectfully requested that Weekly Average concentrations be incorporated into the final permit in lieu of Daily Maximum limits, if in fact, limits are deemed necessary at all. The weekly average could be determined either by the average of daily composite samples or a single sample. Page 3of6 Background - Consistency The draft permit for Twelve Mile inconstantly places concentration limits on copper and zinc. Concentrations differ slightly between Sections A (1) and A (2). Specific Concern(s) - Consistency If metal limits are necessary, which UCPW contends they are not, consistency is necessary to avoid future confusion. In the future, UCPW may exercise the option to request limits based on dissolved metals as opposed to total recoverable metals. The WER study will serve as the catalyst for this decision. UCPW would like to make two (2) closing points as they relate to the presence of copper and zinc in the Twelve Mile Creek WWTP effluent that must be considered if limits are to be assigned. First, there are no known Significant Industrial Users or Categorical Industrial Users contributing flow to the Twelve Mile facility. Any copper or zinc would therefore come from domestic or uncontrollable sources and could not be reduced by reasonable or cost effective means. Second, Twelve Mile is consistently passing chronic WET testing at a 90% dilution factor indicating that any metals present are not in a bioavailable or toxic form. Chlorine Residual Background — Daily Max vs. Average The draft permit for Twelve Mile places a Daily Maximum limit of 17 ug/I on Total Residual Chlorine (TRC); provided chlorine is used for disinfection. Specific Concern(s) — Daily Max vs. Average A single grab sample may not be representative of the actual quality of the effluent. In addition to collection and analysis techniques, there are a number of variables that will influence the concentration of chlorine in the complex wastewater matrix. In an effort to better ensure accurate and representative results, it is respectfully requested that a Daily Average of 28 ug/I and a Weekly Average of 17 ug/I for TRC be incorporated into the final permit. Fecal Coliform Background — Daily Maximum vs. Weekly Average The draft permit for Twelve Mile places a Monthly Average of 200cfu/100m1 and a Daily Maximum limit of 400cfu/100m/I on Fecal Coliform. Specific Concern(s) — Daily Maximum vs. Weekly Average A single grab sample may not be representative of the actual quality of the effluent. In addition to collection and analysis techniques, there are a number of variables that will influence the presence of Fecal Coliform in the complex wastewater matrix. In an effort to better ensure accurate and representative results, it is respectfully requested that a Weekly Average of 400/100 be incorporated into the final permit in lieu of a Daily Maximum. r 7' L" . Page 4 of 6 Stream Monitoring Background — Sampling Frequency Dissolved Oxygen, Temperature, Fecal Coliform and Specific Conductivity are required to be monitored and reported year-round at one (1) point upstream of the WWTP discharge and two (2) points downstream. UCPW field staff monitors the stream three (3) times per week during the summer months and once per week during the winter. UCPW has been collecting and reporting stream data since Twelve Mile began discharging in 1997. Specific Concern(s) — Sampling Frequency Rapid growth in the Twelve Mile Creek service area has resulted in a dramatic increase in vehicular traffic. Although the staff charged with collecting stream samples wears bright/reflective clothing, personal safety is becoming an issue as it relates to sample collection from bridges that are not designed for pedestrian traffic. Inclement weather heightens concerns for the wellbeing of UCPW field staff. It is respectfully requested that the in -stream monitoring frequency be reduced to a maximum of once weekly year-round and that language be incorporated into the permit excluding sampling during periods of inclement weather or when personal safety is at risk. Staffing Requirements Background — 24/7 In a letter dated March 21. 2005, UCPW dispatched a letter (attached) to Ms. Susan Wilson requesting a variance from 15A NCAC 2H .0124 (4) due to the fact that adequate reliability safeguards will exist to ensure the continuous treatment of wastewater without 24-hour staffing. In the Draft cover letter, Jackie Nowell writes "The County's request for variance from the 24- hour seven-day per week staffing as required upon expansion above 5 mgd, cannot be approved at this time. The recent facility problems indicate that a continual presence is best for the Union County WWTP at this time. Upon Union County's request, the Division can reevaluate this requirement in the future." Specific Concern(s) — 24/7 The "problems" that are influencing DWQ's position are based on extenuating circumstances that have been described earlier in this letter (please see Specific Concern(s) under the heading of Copper and Zinc). Although UCPW acknowledges the seriousness of multiple NPDES violations that occurred earlier this year, we do not believe the upsets in the treatment process were influenced by the level of staffing at the plant, nor do we believe the catastrophic power outage and resulting equipment damage in late January 2005 could have been avoided by a higher level of staffing. Although regulations relate staffing requirements to design flow, UCPW contends that flow was not a major contributing factor to the compliance issues since 1) we never exceeded the 2.5 mgd permitted monthly average and 2) flows during the most recent compliant months of June and July were higher than the average flow from December 2004 through May 2005 (2.25 mgd vs 2.22 mgd). UCPW is of the opinion that adding staff solely on the basis of design flow is not prudent and that additional pertinent factors need to be considered. Page5of6 It is respectfully requested that DWQ reconsider it's 24/7 position. Having a certified operator on site 8-hours per day 7-days per week should be considered as an alternative that would provide an extended presence at the facility while avoiding undue burdens on UCPW. If a variance from the rule cannot be granted at this time, target milestones and timetables should be developed and included in the final permit for UCPW to meet in order to remove ambiguity and subjectivity from the staffing issues. In closing, I want to thank you and your staff for working with us on these matters. Union County takes great pride in the management, operation and maintenance of our wastewater facilities and as such UCPW wants to maintain a high standard of operations while practicing fiscal responsibility for our customers. Please feel free to contact me at (704) 296-4215 with any questions or comments. ectfully, hristie L. Putri m, P Interim Public Works Director Attachments CC: Mike Shalati, County Manager Susan Wilson, DWQ Jackie Nowell, DWQ Rex Gleason, MRO - DWQ Page 6of6 UNION COUNTY PUBLIC WORKS DEPARTMENT Jon C. Dyer, P.E., Director March 21, 2005 Susan Wilson NPDES Permits Section Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 SUBJECT: Twelve Mile Creek WVVTP — NC0085359 Variance Request — Staffing Requirements The Union County Public Works Department (UCPWD) has requested a new NPDES Permit for the Twelve Mile Creek WWTP that will increase the permitted discharge from 2.5 to 6.0 MGD. The permit application was submitted in October 2004 and is currently under review by your staff. Since the new permit is being requested for a flow in excess of 5.0 MGD, UCPWD understands that 24-hour, 7 days per week staffing will be required unless it is demonstrated that such staffing is unwarranted. The intent of this letter is to request a variance from 15A NCAC 2H .0124 (4) due to the fact that adequate reliability safeguards will exist to ensure the continuous treatment of wastewater without 24-hour staffing. The Twelve Mile Creek WWTP was placed in service in December 1997. Since activation the facility has been substantially compliant with its NPDES Permit. The existing facility utilizes an uncomplicated and straightforward wastewater treatment process that includes screening, grit removal, oxidation ditches with fermentation and anoxic zones, secondary clarifiers, tertiary filters, UV disinfection and aerobic digesters. The facility currently has stand-by power at the influent lift station and a facility wide Supervisory Control And Data Acquisition (SCADA) system. The upcoming expansion will not significantly increase the complexity of the WVVTP but will enhance control and reliability. The enhancements include Variable Frequency Drive aerators for improved oxygenation and mixing control, complete WVVTP standby power and a "dial -in" SCADA system with the capability to allow operators to view the WWTP process in real-time from remote locations. The SCADA system monitors all vital WWTP unit processes. The status of motors, drives, pumps and blowers is continuously monitored and displayed. Faults such as "failed to start", "over temperature" and "seal failure" trigger alarms that alert WWTP operators. Operating parameters such as dissolved oxygen levels, tank levels and flow rates are monitored, displayed and continually recorded. The SCADA system will notify Page 1 of 2 operators in the event parameters fall outside of preset ranges. The SCADA will manage simple yet important functions such as sludge wasting without an operator being present. Although the current NPDES Permit does not require visitation on weekends or holidays, the'Twelve Mile Creek WWTP is checked 7 days per week 365 days per year. The Twelve Mile Creek VVWTP is typically manned from 8 to 5 Monday thru Friday and visited as necessary (once a day minimum) on Saturday, Sunday and holidays. In addition to checking the facility daily, UCPVVD has a certified WVVTP operator on -call . around the clock. The visitation and on -call practices will continue during/after the expansion. These visitation and on -call practices, coupled with the SCADA capabilities described above, should provide adequate reliability safeguards to ensure the effluent quality is not compromised. The Twelve Mile Creek WWTP is currently operating at approximately 2.0 MGD. UCPWD anticipates a steady increase in flow, but does not anticipate approaching 5.0 MGD for the next five to seven years; and thus the expansion will provide significantly more redundancy and flexibility than is currently available for several years to come. The increased tank volume and number of process units available for activation add to the facilities reliability safeguards. In summary, UCPWD respectfully requests that due consideration be given to granting a variance from the 24/7 staffing rule as it relates to upcoming expansion of the Twelve Mile Creek VVWTP. UCPWD feels the variance is justified based on the following: Twelve Mile Creek WWTP's compliance history is very good. The expansion will not add significant complexity to the facility. Complete WWTP standby power is being added as part of the expansion. Operators will be able to dial into the WWTP SCADA remotely. An operator is on -call around the clock. The facility is checked 7 days per week. Flow does not automatically arrive with the issuance of a new permit. I trust you will review this request favorably and issue the new NPDES Permit without requiring 24-hour per day, seven days per week staffing. If you need additional information or wish to discuss these matters in more detail, please do not hesitate to contact me at (704) 296-4215. Respectfully, Mark = . ye Assist - t Public Works CC: Jackie Nowell — DWQ Jon Dyer — UCPWD Director Page 2 of 2 Draft Permit Reviews (2) Subject: Draft Permit Reviews (2) From: John Giorgino <john.giorgino@ncmail.net> Date: Fri, 29 Jul 2005 15:11:56 -0400 To: Jackie Nowell <Jackie.Nowell@ncmail.net> Jackie, I have reviewed the following: NC0025542 Catawba WWTP NC.Q,Q 35.359 Twelve Mile Creek WWTP4 I have no comments. Thanks for forwarding them. John John Giorgino Environmental Biologist North Carolina Division of Water Quality Environmental Sciences Section Aquatic Toxicology Unit Mailing Address: 1621 MSC Raleigh, NC 27699-1621 Office: 919 733-2136 Fax: 919 733-9959 Email: John.Giorgino@ncmail.net Web Page: http://www.esb.en.r.sta.te.nc.a.as 1 of 1 7/29/2005 3:08 PM cOMtSst� ESUH r ;s, ,,1517YAK • ` "1�tCECENTER.: LEIQM°Nc 27e9941817 �OT NM: INTENT • E`ANPDES. ATER.PgWIT i Nof ., :: andith R c i .s and; s.and�;'rons' ahe `Ncrtlt :: CeuotinaEn l.Man .. etldiherd`: pro.. poses'' to�iasue ;,National , adt#ie: '.; rays ftoir►:iho pu hi date eltlist etioe. �omirretl#s,:. ,tho �x a afi" s nd- lc6 Aq con er•, received prior to ;that datare:consld Bred In tile final determina- , pe 'P a ' ♦ NCDivis on:of Water•Qaalinl ; :lo' Psho ild the :. re. ceive a significant degree of interest. ;fo..s land ` older, `, ° -- � i;ded to.deter- . the • costs;:; el f reproduction. - Mali .ccalnenhk mike re - 'the ttorIniormatlon to the •NC Dieisi* of Water • : rt ethe iabove address of .: th. a, edint $ounce Branch at • a '; 0dension Please. > 'include -' the NPDES mil# number' (at- ' *Fria) „ `hoDi;of.Wa- ; fau y:at2NN.. Sells- ' NC �1 . re4iew infomnttion on �NPDES �: mtit Number OO853 9. •-:Twelve;N:.Mile 1. Creek Wastewater Treatment has applied for:renew- al tent, Of its rmit eo 'C br a tad y'dsargtng tn3at ed Wastewater to the Twelve 0ea !' Mile Creek: in the Catawba ' River Bashi: Currently BOD5, AtFi3,.dissohred oxygen, fecal eolibrrn,:total'residuaLc ilor- M `.r 'e l► &A *M/ 4WJQ/ / /bEs allocations in this portion of the receMng stream: NORTH CAROLINA, UNION COUNTY. AFFIDAVIT OF PUBLICATION Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified, and authorized by law to administer oaths, personally appeared Pat Deese who being first duly sworn, deposes and says: that he is Principal Clerk engaged in the publication of a newspaper known as The Enquirer -Journal, published, issued, and entered as second class mail in the City of Monroe in said County and State; that he is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a true copy of which is attached hereto, was published in The Enquirer -Journal on the following dates: 014 42/o05 and that the said newspaper in which such notice, paper, document, or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning of Section I-597 of the General Statutes of North Carolina. This • 42,Y . day of c•.P�.... zoos Sworn to and subscribed before me, this �! Y. day o. 2005 Notary Public My Commission expires: May 11, 2008 Inches: 8 1 MONROE, N.C. .1,' Ad# 2005 ACCOUNT #: 0.3 /OO a,31 COST: $ 7,3„ —IN ACCOUNT WITH — Otte 3EnqutrEr-1uurn1' P.O. Box 5040 500 W. Jefferson St. i t • Monroe, N.C. 28111-5040 �I !! L 2 9 2005 Important Legal Document, Please Retain .I - Pui'T SOUnCE Union Country - 12-Mile Creek WWTP - Site Specific M... Subject: Union Country - 12-Mile Creek WWTP - Site Specific Metals Development From: "Struve, James N." <jstruve @ hazenandsawyer.com> Date: Fri, 22 Jul 2005 16:41:19 -0400 To: <j ackie.nowell @ ncmail.net> CC: <mtye @ co.union.nc.us>, <lshealy @ shealylab.com>, <lshealy6 @ sc.rr.com>, "Fergen, Robert E." <rfergen@hazenandsawyer.com>, <scubabobf@hotmail.com> Good afternoon Jackie. This is to notify DWQ that the County will commence with the WER Study for determining site specific metal limits for copper and zinc. Preparation for initial sampling will begin next week. In accordance with EPA Guidelines, sampling will be conducted over two seasons. Consequently, we expect to complete the WER by mid to late October of this year and submit a report for your review and comment by the first week of November. Should you have any questions, please do not hesitate to call or email me. Regards, Jim James N. Struve, P.E. Senior Associate Hazen and Sawyer, P.C. 4944 Parkway Plaza Boulevard, Suite 375 Charlotte, NC 28217 Office (704) 357-3150 Direct (704) 940-8911 Fax (704) 357-3152 Email jstruve@hazenandsawver.com 1 of 1 7/25/2005 9:07 AM Michael F. Easley Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality July 1, 2005 Mr. James N. Struve Hazen and Sawyer 4944 Parkway Plaza Blvd. Suite 375. Charlotte, North Carolina 28217 Subject: Union County - Twelve Mile Creek WWTP NPDES Permit No. NC0085359 Site Specific Metals Development Dear Mr. Struve: The Division of Water Quality received vour June 2, 2005 letter on the subject topic and has reviewed the information and data that were submitted. Specifically, we have reviewed the results of the reasonable potential analysis that were submitted. In our analysis, we have included all copper data that were submitted in Union County's discharge monitoring reports from the year 2003 through April. 2005. Our results show reasonable potential for copper to exceed the recalculated limit of 10.2 ug/1. We do not concur with the elimination of copper data points based on the criteria noted in your letter. Regarding the County's decision to conduct a Water Effect Ratio (WER) study for zinc, the Division will review your results at the conclusion of the study. Please be advised that Union County must accept the results of the WER even if limits are shown to be more stringent than the current values. In order to expedite the future modification/renewal permit, the Division intends to use the recalculated copper and zinc values (with approval from South Carolina and EPA Region IV). Should the County choose to perform a WER for both copper and zinc, and subsequently provide information from the study prior to issuance of the modification/renewal permit, the Division will consider these values for incorporation in the permit. Otherwise, Union County will need to request a permit modification to consider alternate limits. lyn M. No' -ell S Western rogran Cc: Mark Tye, Union County Mooresville Regional Office/Surface Water Protection Matt Matthews/Aquatic Toxicology Unit Connie Brower/Planning Branch Central Files NPDES Permit File N. C. Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 Internet: h2o.enr.state.nc.us Phone: (919) 733-5083 fax: (919) 733-0719 DENR Customer Service Center: 1 800 623-7748 IIAZENAND SAWYER Environmental Engineers & Scientists June 2, 2005 Ms. Jackie Nowell NPDES Permit Unit NC Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 3 2005 Df_NR' PC)IkJT SUlikCE BRANCH JUN Re: Union County, NC Twelve Mile Creek WWTP Site -Specific Metals Development H&S Job No. 30873 Dear Ms. Nowell: Hazen and Sawyer, P.C. 4944 Parkway Plaza Blvd. Suite 375 Charlotte, NC 28217 704 357-3150 •fax 704 357-3152 On behalf of the Union County Public Works Department, this correspondence is a follow up to the letter of March 24, 2005 which indicated the County's intention to conduct a Water Effect Ratio (WER) study for copper and zinc. The March 24th letter also presented the proposed NPDES metal limits along with the site -specific limits determined by utilizing the Recalculation Procedure with and without Cladocerans in the analysis dataset. The results are summarized as follows: Metals Parameter Copper Zinc NC DWQ Proposed Daily Maximum Limit 3.8 ug/L 37.0 ug/L Recalculation Procedure excluding Cladocerans t • 12.95 ug/L 257.5 ug/L Recalculation Procedure including Cladocerans 1' 10.2 ug/L 91.6 ug/L Based on "total recoverable" and adjusted for a site -specific hardness of 59 mg/L. As part of the initial WER evaluation, the copper data (which was collected using clean techniques) was evaluated for reasonable potential at the 99% probability level using the 10.2 ug/L total recoverable limit as the evaluation point. The data and calculations are appended. The data was edited to adjust for the periods of high effluent' suspended solids (over 15 mg/L) and a single outlier was excluded from the data set. The data has 39 measurements®which were evaluated using the standard EPA stipulated approach. The results indicate the maximum predicted concentration is 7.4 ug/L of total recoverable copper as summarized on the following page: New York, NY • Armonk, NY • Upper Saddle River. NJ • Raleigh, NC • Charlotte. NC • Vienna, VA • Hollywood, FL • Boca Raton. FL • Fort Pierce, FL • Jupiter, FL • Miami, FL • Bogota, D.E. Colombia Ms. Jackie Nowell June 2, 2005 Page 2 Reasonable Potential Summary Actual Data Standard Deviation 0.584770737 Mean 1.14 Coefficient of Variation 0.511 Number of Samples 39 Predicted Value (99th Percentile) Maximum Concentration 4.4 ug/L Multiplication Factor 1.7 Maximum Predicted Concentration 7.48 ug/L Results Maximum Predicted Concentration (7.48 ug/L) < Site Specific Concentration (10.2 ug/L) This maximum predicted concentration of 7.48 ug/L is well below the 10.2 ug/L site - specific limit developed in the Recalculation Procedure. Therefore, based upon these results and analyses, we request that the total recoverable copper limit and monitoring requirement be removed from the County's NPDES Permit. Additionally, in order to obtain further relief for total recoverable zinc, the County has decided to conduct a Water Effect Ratio study in accordance with the Technical Study Plan previously submitted on April 17, 2003. Pending your concurrence with the copper approach, we would like to start the zinc WER study and request a meeting the week of June 6th to discuss this project. Please give me a call at (704) 357-3150 or email me at jstruve@hazenandsawyer.com to establish a convenient time for the meeting. w would like, we can also teleconference. ' Very truly yours, HAZEN AND SAWYER, P.C. James N. Struve, P.E. Senior Associate JNS/gb Enclosures Cc: Jon Dyer, Union County Mark Tye, Union County Susan Wilson, DWQ — NPDES Permit Unit Matt Matthews, DWQ — Aquatic Toxicology Unit Jeff Manning, DWQ — Classifications and Standards Laura Shealy, Shealy Environmental Bob Fergen, Hazen and Sawyer Union County, North Carolina Twelve Mile Creek WWTP Reasonable Potential Analysis for Copper (Samples were Collected and Analyzed Using Clean Techniques) Parameter = Copper WQ Standard = 10.20 ug/L Sample Date Cu Conc (uq/L) 4/22/2003 1 4/23/2003 1 4/23/2003 1 4/25/2003 1 4/29/2003 1 4/30/2003 1 5/1/2003 1 5/2/2003 1 5/6/2003 1 5/7/2003 1 5/8/2003 1 5/9/2003 1 5/13/2003 1 5/14/2003 1 5/15/2003 1 5/16/2003 1 5/20/2003 1 5/21/2003 1 5/22/2003 1 5/23/2003 1 10/7/2004 1 10/14/2004 2 10/21/2004 1 10/28/2004 1 11/4/2004 1 11 /11 /2004 1 11/18/2004 1 11/23/2004 1 12/2/2004 1 12/9/2004 1 12/21/2004 1 12/28/2004 1 1/6/2005 1 1/13/2005 1 2/10/2005 1 2/24/2005 2.1 3/8/2005 1 3/17/2005 4.4 3/31/2005 1 J'JN 3 PO'Vil SOURCE. C i RESULTS Standard Deviation = 0.584770737 Mean = 1.14 Coefficient of Variation.= 0.511 Number of Samples = 39 Multiplication Factor = 1.7 Maximum Value = 4.4 Max Predicted Conc = 7.48 Union County, North Carolina Twelve Mile Creek WWTP Copper Sampling Data Chronic Toxicity Date Copper (mg/L) TSS (mg/L) Pass/Fail Remarks/Comments 8/19/2004 <.002 1 8/26/2004 <.002 1.2 8-15/8-20 Pass 8/17/2004 ChV=95% 9/2/2004 <.002 1.2 9/9/2004 <.002 3.4 9/16/2004 <.002 <1 9/23/2004 0.0031 <1 9/30/2004 <.002 7.8 10/7/2004 <.002 1.2 Clean Techniques Utilized as Sampled By County Staff 10/14/2004 0.002 1.6 Following September 30, 2004 Meeting with DWQ. 10/21/2004 <.002 <1 10/28/2004 <.002 <1 11/4/2004 <.002 1 11 /11 /2004 <.002 1.2 11/18/2004 <.002 <1 11/23/2004 <.002 <1 11-8/11-12 Pass 11/9/2004 ChV=>100% 12/2/2004 <.002 1.2 12/9/2004 <.002 1 12/21/2004 <.002 1.4 12/28/2004 <.002 4 1/6/2005 <.002 1.4 1/13/2005 <.002 2.4 1/20/2005 0.013 66 12-Mile Creek BOD = 47.55 mg/L, NH3 = 25.8 mg/L 1/27/2005 0.018 182 WWTP was in BOD = 80.06 mg/L. NH3 = 21.5 mg/L 2/10/2005 <.002 16.4 upset condition BOD = 22.70 mg/L, NH3 = 22.4 mg/L 2/10/2005 0.008 63 and exceeded BOD = 28.58 mg/L, NH3 = 28.4 mg/L 2/17/2005 0.0055 17.5 BOD. NH3, and/or BOD = 7.21 mg/L, NH3 = 23.9 mg/L 2/24/2005 0.0021 5.4 TSS NPDES BOD = 4.11 mg/L, NH3 = 22.1 mg/L 3/3/2005 0.0058 60 Permit limits. BOD = 22.07 mg/L, NH3 = 15.8 mg/L 3/8/2005 <.002 6.4 Therefore, Cu BOD 6.30 mg/L, NH3 = 24.6 mg/L 3/17/2005 0.0044 4 measurements BOD = 4.49 mg/L, NH3 = 16.5 mg/L 3/23/2005 0.006 3.6 (indicated in BOD = 6.11 mg/L, NH3 = 18.6 mg/L 3/31/2005 <.002 2.4 orange) were BOD = 9.05 mg/L, NH3 = 4.1 mg/L 4/7/2005 <.002 3.8 excluded from BOD = 12.32 mg/L, NH3 = 13.1 mg/L 4/14/2005 <.002 10.0 reasonable BOD = 10.70, NH3 = 9.5 mg/L 4/21/2005 0.0088 95.0 potential dataset. BOD = 52.73 mg/L, NH3 = 1.6 mg/L 4/28/2005 <.002 2.0 BOD = 3.86 mg/L, NH3 = 4.8 mg/L 5/5/2005 <.002 3.2 BOD = 5.44 mg/L, NH3 = 5.2 mg/L 5/12/2005 <.002 3.4 BOD = 4.72 mg/L, NH3 = 1.0 mg/L 5/19/2005 0.0022 14.2 BOD = 7.06 mg/L, NH3 = <1.0 mg/L 5/26/2005 0.0034 7.8 BOD = 6.15 mg/L, NH3 = <1.0 mg/L Union County, North Carolina Twelve Mile Creek WWTP Copper Sampling Data Date Copper (mg/L) TSS (mg/L) Chronic Toxicity Pass/Fail Remarks/Comments 4/22/2003 4/23/2003 4/24/2004 4/25/2004 4/29/2003 4/30/2003 5/1/2003 5/2/2003 5/6/2003 5/7/2003 5/8/2003 5/9/2003 5/13/2003 5/14/2003 5/15/2003 5/16/2003 5/20/2003 5/21/2003 5/22/2003 5/23/2003 5/1/2003 5/8/2003 5/15/2003 5/22/2003 5/29/2003 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.001 <.002 0.0023 <.002 <.002 <.002 1.8 <1.0 1.6 <1.0 6/5/2003 6/12/2003 6/19/2003 6/26/2003 7/1/2003 7/10/2003 7/17/2003 7/24/2003 7/31/2003 8/7/2003 8/14/2003 8/21/2003 8/28/2003 <.002 0.0036 0.0074 <.002 <.002 <.002 <.002 <.002 <.002 <.002 <.002 0.053 0.0022 <1 3.2 2.6 <1 1 2 <1 1.6 1.2 4.4 1.8 <1 <1 9/4/2003 9/10/2003 9/18/2003 9/25/2003 10/2/2003 10/9/2003 10/16/2003 10/23/2003 <.002 <.002 0.0036 0.0034 0.0056 0.0022 <.002 <.002 2 1.2 <1 <1 1.6 <1 <1 <1 Clean Techniques Utilized as Sampled By Shealy Environmental During Recalculation Procedure Field Work. Union County, North Carolina Twelve Mile Creek WWTP Copper Sampling Data Date Copper (mg/L) TSS (mg/L) Chronic Toxicity Pass/Fail Remarks/Comments 10/30/2003 11/6/2003 11/13/2003 11/20/2003 11/25/2003 11-3/11-7 12/4/2003 12/11/2003 12/18/2003 12/22/2003 12/30/2003 1/8/2004 1/15/2004 1/22/2004 1/29/2004 2/4/2004 2/5/2004 2/12/2004 2/19/2004 2/26/2004 2-3/2-7 3/4/2004 3/11/2004 3/18/2004 3/25/2004 4/1/2004 4/8/2004 4/15/2004 4/22/2004 4/29/2004 5/4/2004 5/13/2004 5/20/2004 5/27/2004 5-17/5-21 5/18/2004 6/3/2004 6/10/2004 6/17/2004 6/24/2004 7/1/2004 7/8/2004 7/15/2004 7/22/2004 7/29/2004 7/30/2004 8/5/2004 8/12/2004 <.002 <.002 <.002 <.002 <.002 0.0023 0.0027 0.0028 <.002 <.002 <.002 <.002 0.0063 <.002 0.0041 0.0071 <.002 0.0024 0.0021 <.002 <.002 <.002 <.002 <.002 0.0024 <.002 0.0033 0.0029 <.002 <.002 0.0025 <.002 <.002 <.002 0.002 0.0029 <.002 <.002 <.002 0.003 0.0044 0.0071 0.0063 0.0026 1.2 <1 1.4 1.6 1.4 <1 <1 <1 <1 <1 <1 <1 1 1.2 1 <1 1.4 1.8 1.2 <1 1.2 <1 1 1.8 <1 <1 <1 <1 <1 <1 <1 <1 <1 1.4 <1 12.4 <1 1.2 <1 <1 <1 <1 <1 1.2 Pass Pass Pass ChV=92,5% 07-01-2005 10:10AM FROM -Construction Grants And Loans 0 Mr. Brian P. Cole, Field Supervisor U. S. ish and Wildlife Service Asheville Field Office 160 Z?llicoa Street Asheville, North Carolina 28801 SUBJECT: Union County Twelve Mile Creek WWTP Project No. CS370370-09 6167156226 T-246 P 003/004 F-313 Michael F. Easlcy, Governor Willinin G. ROffa Jr., Sccrctury North Carolina Department of Environment and Natural Resources Alun W. Klimek. P.G. Director Di vision of Water Quality June 30, 2005 Dear rr. Cole: The Construction Grants and Loans Section of the Division of Water Quality has reviewed Union County's responses to the Service's comments regarding the subject project. Union County has committed to implement modifications to their existing Land Use ordinance to address concerns regarding Schweinitz's sunflower (see attached schedule). We also understand that the implementation process has begun for the County's proposed storm water ordinance to address concerns regarding riparian buffers. It is expected that this ordinance will be adopted by the end of 2005. Based on these positive steps taken by Union County, the August 9, 2004 Finding of No Significant Impact, and previous concurrence from the Wildlife Resources Commission and other review agencies, the Division of Water Quality is satisfied that environmental concerns related to the Twelve Mile Creek project have been adequately addressed. Thank you for your review of the proposed Union County Twelve Mile Creek wastewater treannent plant project. Since ely, 0,ee44;se-et Daniel M. Blaisdell, P.E., Assistant Chief Engineering Branch DM , dr Attachment cc: Union County - Ms. Christie Putnam, P.E. McKim & Creed (Charlotte) Coleen Sullins Bobby Blowe, P.E. Dave Goodrich - Surface Water Protection Section PMB/FEU/SRF Construction Grants and Loans Section 1633 Mall Service Center Raleigh NC 27699-1633 Phone: 919-733.6900 / FAX: 919.715-6229 / Internet: www.nccgLnet An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper 14[hC8I0 lII3 J%)aturallj/� 07-01-2005 10:20AM FROM -Construction Grants And Loans 9197156229 T-246 P 004/004 F-313 UNION COUNTY PUBLIC WORKS DEPARTMENT Christie L. Putnam, P.E., Interim Director Dan Ellaisdell Construction Grants & Loans 1633 Mall Service Center Raleigh, NC 27699-1633 Dear Dan, June 29, 2005 Per our conversation yesterday, 1 am sending you a detailed schedule Union County will follow to move forward with the adoption of language to modify our Land Use Ordinance. This process will address the concerns of US Fish and Wildlife providing protection for the endangered species, the Schweinitz's sunflower, that may occur from development associated with the Twelve Mile Creek WWTP expansion. Exact language will be drafted in coordination with the County's legal and planning departments requiring all Major Subdivision permits, identify and preserve the sunflower habitat prior to any land disturbing activity. July 25 - for support. August 2- Present to UC Planning Board for Approval August Advertise public hearing on land use ordinance change as required for Septr 6 Conduct public hearing and receive comments Sept 119 Present proposed ordinance amendment to the Board of County Commissioners modification Present proposed ordinance amendment to Board of County Commissioners with staff's support for approval Union County is committed to protecting our natural resources. I hope this Schedple of commitment by the Manager's office provides you the assurance your office needs to support our expansion project. If I can provide you with any further information please do not hesitate contact me. I appreciate your efforts on this project. Thank you for your timely consideration of this issue. Si ely, /74.1 hristie Putnam,P.E. Assitant to the County Manager Cc: Coleen Sullins !file • O� v � r LJ1J`J c Mr. Brian P. Cole, Field Supervisor U. S. Fish and Wildlife Service Asheville Field Office 160 Zillicoa Street Asheville, North Carolina 28801 Dear Mr. Cole: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality June 30, 2005 SUBJECT: Union County Twelve Mile Creek WWTP Project No. CS370370-09 The Construction Grants and Loans Section of the Division of Water Quality has reviewed Union County's responses to the Service's comments regarding the subject project. Union County has committed to implement modifications to their existing Land Use ordinance to address concerns regarding Schweinitz's sunflower (see attached schedule). We also understand that the implementation process has begun for the County's proposed storm water ordinance to address concerns regarding riparian buffers. It is expected that this ordinance will be adopted by the end of 2005. Based on these positive steps taken by Union County, the August 9, 2004 Finding of No Significant Impact, and previous concurrence from the Wildlife Resources Commission and other review agencies, the Division of Water Quality is satisfied that environmental concerns related to the Twelve Mile Creek project have been adequately addressed. Thank you for your review of the proposed Union County Twelve Mile Creek wastewater treatment plant project. Sincerely, - cLst� teJ /'�'r[ , Daniel M. Blaisdell, P.E., Assistant Chief Engineering Branch DMB/dr Attachment cc: Union County - Ms. Christie Putnam, P.E. McKim & Creed (Charlotte) Coleen Sullins Bobby Blowe, P.E. Dave Goodrich - Surface Water Protection Section PMB/FEU/SRF 0' J U L 7 2005 - QUALITY POINT SOURCE BRANCH Construction Grants and Loans Section 1633 Mail Service Center Raleigh NC 27699-1633 Phone: 919-733-6900 / FAX: 919-715.6229 / Internet: www.nccgl.net An Fntial (lnnnrilinity/Affirmative Ariinn Fmnlnvar—Sf1°/ Rurvrlorilino! Pnet Cnnctimar Pancr NorthCarolina Natural!& UNION COUNTY PUBLIC WORKS DEPARTMENT Christie L. Putnam, P.E., Interim Director June 29, 2005 Dan Blaisdell Construction Grants & Loans 1633 Mail Service Center Raleigh, NC 27699-1633 Dear Dan, 54StOt osiono\aos ‘,.0004 Per our conversation yesterday, I am sending you a detailed schedule Union County will follow to move forward with the adoption of language to modify our Land Use Ordinance. This process will address the concerns of US Fish and Wildlife providing protection for the endangered species, the Schweinitz's sunflower, that may occur from development associated with the Twelve Mile Creek WWTP expansion. Exact language will be drafted in coordination with the County's legal and planning departments requiring all Major Subdivision permits, identify and preserve the sunflower habitat prior to any land disturbing activity. July 25 - Present proposed ordinance amendment to the Board of County Commissioners for support. August 2- Present to UC Planning Board for Approval August Advertise public hearing on land use ordinance change as required for modification Septr 6 Conduct public hearing and receive comments Sept 19 Present proposed ordinance amendment to Board of County Commissioners with staff's support for approval Union County is committed to protecting our natural resources. I hope this Schedule of commitment by the Manager's office provides you the assurance your office needs to support our expansion project. If I can provide you with any further information please do not hesitate contact me. I appreciate your efforts on this project. Thank you for your timely consideration of this issue. Si erely, /' nstie Putnam, P.E. Assitant to the County Manager Cc: Coleen Sullins file Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality June 30, 2005 Ms. Christie Putnam, P.E., Interim Director Union County Public Works Department 400 N. Church Street Monroe, North Carolina 28112-4804 SUBJECT: Approval - Union County 201 Facilities Plan Amendment Twelve Mile Creek Wastewater Treatment Plant Expansion Project No. CS370370-09 Dear Ms. Putnam: The Construction Grants and Loans Section of the Division of Water Quality has completed its review of the Union County 201 Facilities Plan Amendment Twelve Mile Creek Wastewater Treatment Plant Expansion. The proposed project will expand the capacity of the existing 2.5 million gallon per day (MGD) wastewater treatment plant to 6.0 MGD. The project will include the construction of new headworks with two mechanical screens, odor control, and expanded influent pumping capacity; two additional oxidation ditches; two additional secondary clarifiers with return and waste sludge pumping; two additional tertiary filters; expansion of the ultraviolet light disinfection system by the addition of a second reactor; a 1.0 million gallon additional aerobic sludge digester with blowers and a blower building; and an emergency generator to serve as a source of back-up power. The subject Union County 201 Facilities Plan Amendment Twelve Mile Creek Wastewater Treatment Plant Expansion is hereby approved. If you have any questions concerning this matter, please contact Mr. Larry Horton, P.E. of our staff at (919) 715-6225. Sincerely, pct._John R. Blowe, P.E., Chief Construction Grants and Loans Section RB/dr cc: McKim & Creed, P.A. - Sid Riddick, P.E. DWQ Mooresville Regional Office Daniel Blaisdell, P.E. Robert Brown Hannah Stallings Dave Goodrich - Surface Water Protection PMB/DMU/FEU/SRF If JUL 7 2005 UEHR - WATER QUALITY POINT SOURCE BRArt 'H Construction Grants and Loans Section 1633 Mail Service Center Raleigh NC 27699-1633 Phone: 919-733-6900 / FAX: 919-715-6229 / Internet: www.nccgl.net An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper ne N�orthCarohhn . Naturally NPDES Permit for Union County Twelve Mile Creek ... Subject: NPDES Permit for Union County Twelve Mile Creek WWTP Expansion From: <Bi11.Kreutzberger@CH2M.com> Date: Mon, 6 Jun 2005 03:11:21 -0600 To: <susan.a.wilson@ncmail.net>, <dave.goodrich@ncmail.net>, <j ackie.nowell @ ncmail.net> CC: <chrisp@co.union.nc.us>, <jondyer@co.union.nc.us>, <MTye @co.union.nc.us> Good morning - The purpose of this email is to follow up on a discussion that Susan Wilson and I had last Thursday regarding the Twelve Mile Creek WWTP NPDES Permit. I am going to provide a very brief background and current status update, to frame the issues, and then a recommendation. Background As you are aware, an EA was prepared for the WWTP expansion and a FONSI was received in 2004. This had involved fairly extensive negotiations with the NC Wildlife Resources Commission (WRC) over mitigative measures to address secondary and cumulative impacts (SCI). While no Federally threatened or endangered (T&E) aquatic species were present in the watershed, WRC had extensive comments on buffer and stormwater management requirements that took some time to resolve. Union County then decided to apply for a loan through DWQ Construction Grants and Loans (CG&L). Since Federal $ were involved with the loan, the EA was then subject to additional Federal review. US Fish and Wildlife (F&W) submitted extensive comments in January 2005. Many of these were general comments related to stormwater and buffers that referenced the SCI comments of WRC and WRC's guidelines for addressing these impacts. The only linkage to a T&E species were SCI related to the Schweinitz's sunflower. After discussions with US F&W staff, Union County agreed to require surveys for the sunflower for major developments in the County in a letter dated May 18, 2005. Subsequent discussions with US F&W staff (and additional correspondence that Union County will forward to you) indicates that US F&W still wants broader stream buffers - even though this is not tied to a Federally listed species. They have also made some additional requests to protect the sunflower. Current Status Union County representatives had previously inquired with DWQ regarding dropping the request for a CG&L loan in order to take away the nexus for Federal comments on this project. In discussing this with Jackie Nowell previously and then Susan Wilson last week, the NPDES permit unit's concerns were that the USF&W issues needed to be resolved because they would likely come up again in during the 1 of 2 6/6/2005 9:42 AM NPDES Permit for Union County Twelve Mile Creek ... . NPDES comment process. It is our contention, that without the Federal loan $s, US F&W basis for commenting will be related only to Federally listed species (Schweinitz's sunflower) and not the broader SCI issues that are contained in their letters. Their comments are based on the NC WRC comments and guidance and we have already obtained WRC's acceptance of mitigative measures through the SEPA process resulting in a FONSI. Union County is in critical need to proceed with the expansion of the Twelve Mile Creek WWTP. While the low interest Federal $s would be desirable, our primary need is to proceed as quickly as possible with NPDES permit issuance so that the construction process can proceed. Recommendation Union County requests that DWQ proceed with NPDES permitting of the expansion quickly. If additional USF&W comments arise during the process, we will work closely with you to resolve them. If you have additional questions about this request, we are willing to meet with you on short notice so that we can resolve these issues and move forward. If you have any questions, please contact me at the numbers listed below (mobile number is probably best) or Christie Putnam, Deputy County Manager, at (704)-292-2592. Thank you for your quick attention to this matter. Bill Bill Kreutzberger CH2M HILL - Charlotte Office 4824 Parkway Plaza Blvd. Suite 200 Charlotte, NC 29217-1969 Direct Phone - 704.329.0073 x. 217 Mobile Phone - 704.904.5918 Fax - 704.329.0141 Email Fax - 678.579.8071 Email - bill.kreutzberger@ch2m.com 2 of 2 6/6/2005 9:42 AM union co. Subject: union co. From: Susan Wilson <susan.a.wilson@ncmail.net> Date: Wed, 08 Jun 2005 09:22:27 -0400 To: Jackie Nowell <Jackie.Nowell@ncmail.net> Jackie, fyi - talked to Dave about this one yesterday. I'm trying to call Dan B and find out where things are at on their end (CG&Ls). Dave was inclined not to move forward unless they are (and have them take care of it and discourage union co. from withdrawing the request for funding). stay tuned meanwhile - I'd start getting your ducks so we can have our meeting with Jim S if branch meeting during our scheduled time together afterwards (don't know how late in a row re. that permit, necessary. we'll be at our - but maybe we can get we'll be over there). 1 of 1 6/8/2005 9:43 AM 07-01 1005 10:19AM FROM -Construction Grants�/And Loans 9197156229 DIVISION ISION OF RATER QUALITY -- MAGNA 'AX TRANSMITTAL Date: JLE 1f aims - To: Sack' we Location: NI/i,4on g Atti Fax No. fliCh T)33-- From::Ian le t NI • Nal-5,610U T-248 P 001/004 F-313 Fax No. (919) 715-6229 Te1e: (9191-1 IC - Location: DWQ - Construction Grants & Loans Section Pages to Follow • ; 1,11%/ ' tC-1- , It41/* ti4 6g----- //4-t-.1 Z iv 4 r-,43- . LI? G6, �u A /c/f,tat, �r Glow ai,d/sed fi. a a , oiir f 1 c-i G fir sus- 7fT-a7r9 „dm Sfricifi/ 111#ecd,/11 kv7tict-71,r/fi°� //IP Ok/c4Aies GU ‘t) E ��J41. �/.WMr.a iW. ts.e4444- 24114'v4j-3 71 AVAT/seA (75 /tt -et ki-ort /1104. „ (A6)1 "(7 &6t; 1)4 °Pi Coi C 1/k/ PERMIT NUMBER: NC0085359 FACILITY NAME: Union County - Twelve Mile Creek WWTP CITY: Monroe COUNTY: Union PERIOD ENDING MONTH: 12 - 2003 DMR 12 Month Calculated PAGE 3 OF 5 REGION: Mooresville 31616 #/100m1 Coliform, Fecal MF, M-FC Broth,44.5C 50050 mgd Flow, in conduit or thru treatment plant 50060 mg/1 Chlorine, Total Residual 50060 ug/1 Chlorine, Total Residual TGP3B pass/fail P/F STATRE 7Day Chr Ceriodaphnia 1 -03 2.5 2-03 2.5 3 - 03 2.5 4 - 03 2.5 5-03 2.5 6-03 2.5 7-03 2.5 8-03 2.5 9-03 2.5 10-03 2.5 11-03 2.5 12-03 2.5 06-1672005 11:19AM FROM -Construction Grants And Loans 9197156229 T-222 P 002/004 F-230 United States Department of the Interior FISH AND WILDLIFE SERVICE Asheville Fick! Office 160 Zillicoa Street Asheville, North Carolina 28801 May 31, 2005 M •� Ms. Christie Putnam, P.E. Assistant to the County Manager Office of the Commissioners and Manager Union County 500 N. Main Street, Room 921 Monroe, North Carolina 28112 Dear Ms. Putnam: Subject: Twelve Mile Creek Wastewater Treatment Plant Expansion Project, 201 Facilities Plan and Environmental Assessment, Union County, North Carolina (Project No. CS370370-09) We received your letter of May 18, 2005, regarding our letter of January 5, 2005, about the subject project. Your letter states that its intent is to address concerns in adequate detail to satisfy the U.S. Fish and Wildlife Service (Service) that "... sufficient safeguards will be in place to mitigate any impacts that may be attributed to the expansion of the [subject] facility." Your letter further states that you look forward to a response from us acknowledging our concurrence with your letter. We do not concur with your letter. As stated in your letter, you discussed several topics with Mr_ Allen Ratzlaff of our staff on May 12, 2005, including ways to prevent secondary impacts to Schweinitz's sunflower. Based on your letter, we understand that the Union County (County) staff is now drafting language for the Land Use Ordinance (Ordinance) that will require any applicant for a "Major Development Permit" to have a survey conducted, by a qualified professional, for Schweinitz's sunflower. The County would then consult with the Service. The draft language will go before the County Board of Commissioners this fall for consideration of adoption and subsequent implementation. We cannot concur with the subject project until the Ordinance is adopted. Until we can review what is. actually adopted, we cannot know if the protection offered is sufficient to satisfy our concerns. Limiting surveys for federally listed species to only "Major Development Permits" would not satisfy our concerns. Surveys should be required for all development activities proposed in suitable Schweinitz's sunflower habitat. 06--1672005 11:19AM FROM -Construction Grants And Loans 9197156229 T-222 P 003/004 F-230 Your letter also states that you discussed riparian buffers with Mr. Ratzlaff. During that conversation you indicated that you thought our concems had been addressed (presumably, in the draft Ordinance). Upon our review of your letter and the draft Union County Stonnwater Discharge and Quality Controls Ordinance, it appears that most of our concerns have not been addressed, and those that have, have been addressed inadequately, specifically with regard to riparian buffers. On virtually every project we comment on, including the subject project, we recommend forested riparian buffers of 100 feet on perennial streams and 50 feet on intermittent streams; where listed aquatic species are present, the recommended buffers are doubled. The proposed Ordinance includes only a 30-foot buffer on intermittent streams, and though perennial streams are to have buffers between 50 and 100 feet wide (identical to what was proposed in your earlier letter regarding this project and the reason for our concerns), the exemptions and allowed activities within the buffers negate much of their benefit. Further, our letters regarding this project have detailed our concerns with floodplain alteration (fill) and development, invasive exotic species, and the creation of "edge." These concerns have either not been addressed or are inadequately addressed in the draft Ordinance. Our concems about the need to consider a "no action" alternative have not been addressed. In our January 5, 2005, letter, we stated the following: Of importance when assessing the impacts of the proposed project is the fact that all of the mitigative measures (proposed and current ordinances, permit compliance, best management practices, and zoning) included in the Environmental Assessment (Section F), are not conditional on the expansion of the sewer plant and should thus be implemented with or without sewer plant expansion. If this is the case, then the only factors that should be considered when implementing the proposed project are those that would make water quality better than the current systems that presumably (as the Environmental Assessment does not quantify or qualify) contains failing septic systems and "gray water" discharges. However, because a "no action" alternative was not considered, it is not possible to coxnpare the benefits of the proposed project to allowing current and future development to continue using only septic systems. We strongly encourage you to evaluate and consider this alternative. In su nary, proposing an Ordinance that requires some, but not all, developments to survey for Schwe#nitz's sunflower will not satisfy our concerns with this project. Our January 5, 2005, letter detailed very specific concerns with the subject project that, to date, have not been addressed. It is therefore incorrect to conclude that implementation of the items in your letter will "eliminate the need for further comments" from the Service. Expansion of the Twelve Mile Creek WWTP only for the purpose of accommodating the additional discharge from the treatment plant proposed for the Rocky River and the closing of the Hunley Creek WWTP on Goose Creek are not likely to significantly impact the project area. However, the impacts of providing new sewer service to these areas are not assessed in the Environmental Assessment. 06-16;2005 11:20AM FROM -Construction Grants And Loans 9197156229 T-222 P 004/004 F-230 Please do not hesitate to contact Mr. Allen Ratzlaff of our staff at 828/258-3939, Ext. 229, if you have any questions regarding our comments. We have assigned our Log No. 4-2-05-056 to this project; please refer to it in all future correspondence directed to us concerning this matter. Sincerely, Brian P. Cole Field Supervisor cc: Ms. Shari L. Bryant, North Carolina Wildlife Resources Commission, P.O. Box 129, Sedalia, NC 27522 Ms. Hannah Stallings, Environmental Assessment Coordinator, Construction Grants and Loans Section, North Carolina Department of Environment and Natural Resources, 1633 Mail Service Center, Raleigh, NC 27699-1633 I4 MEMO To: 04-vE Gov o /L/c.v DATE: SUBJECT: U/v toot.) C o o ivr >- /oZ C%ZLe&. 11- f w E %J /,l'G udf 4.0 p.`. S"' - S - o 5, /74-42 E fr' ,F Cc)P'Ty OF vN cO Gou.ve r f 0 7? lea - is.-t /L-,E GR-6-E/C ,D/L o rj€ c_c 7-1,4( S /J' ,' t `r0ure- !N i4o -r 14-1-td •�.a f f 1} /4-5 / r 7-b /j'J chin. Gr• /Q-A) A.) P of J' /PZ i' r C-01- r«4 .raw 7-P. I)4-E-64_1 E ry v. 04 ov }- Q ut friGA,r, to 6 41. I E E P u 0 /9 v 7440 a A.) T- E /OA. 0 G./LP- : •CG = /,4u1- /24wL1' FiLg FROM: af; NORTH CAROLINA DEPARTMENT OF NCDENR ENVIRONMENT AND NATURAL RESOURCES PRINTED ON RECYCLED PAPER OFFICE OF THE COMMISSIONERS AND MANAGER 500 N. Main St., Room 921 ..Monroe, NC 28112 • Phone (704) 283-3810 • Fax (704) 282-0121 May 18, 2005 Brian Cole US Fish and Wildlife United States Department on Interior Asheville Field Office 160 Zillicoa St Asheville, NC 28801 t f . N , � 'i • -CCIOSTRiciel '.Fl ,0 SEfTf, Subject: Twelve Mile Creek Wastewater Treatment Plant Expansion Project, 201 Facilities Plan and Environmental Assessment, Union County, North Carolina (Project No. CS370370-09). Dear Mr. Cole, This letter is written in response to your letter to Hannah Stallings dated January 5, 2005 as well as a subsequent telephone conversation with Alien Ratzlaff regarding US Fish and Wildlife (USFW) concerns related to our Twelve Mile Creek Waste Water Treatment Plant expansion. The intent of this letter is to address concerns in adequate detail to satisfy USFW that sufficient safeguards will be in place to mitigate any impacts that may be attributed to the expansion of the facility. On May 12th, Mr. Ratzlaff and I discussed specific strategies that can be employed to address issues identified in the above referenced letter. These strategies included riparian buffers and surveys for the Schweinitz's sunflower. Each will be discussed below. Union County, USFW and North Carolina Wildlife Resources have discussed the benefits of riparian buffers to water quality and wildlife habitat preservation. The County has proposed a Stormwater Ordinance that includes riparian buffers, as well as stormwater detention requirements to protect water quality. This ordinance will be applicable to the unincorporated areas of the Twelve Mile Creek basin. I have attached a copy for your review. This ordinance is currently under review by legal staff. This ordinance is scheduled to be before the county commissioners this fall for consideration of adoption and subsequent implementation. Pursuant to my conversation with Mr. Ratzlaff on May 12th, Union County staff is drafting language relating to the Schweinitz's sunflower for inclusion in our existing Land Use Ordinance. The County proposes to require any applicant for a Major Development permit to have a field survey conducted by a recognized professional for the Schweinitz's sunflower. The survey would be required prior to any land disturbing activity. County staff will consult with USFW to define a notification and recordation process, as well as look to USFW to help define any potential mitigation options. Again, this is scheduled to be before the Union County Board of Commissioners this fall for consideration of adoption and subsequent implementation. The County acknowledges the concerns of USFW. As I discussed with Mr. Ratzlaff, our implementation of these measures will resolve all issues outlined in your letter and eliminate the need for further comments from USFW with regard to the NPDES permitting of the Twelve Mile Creek Waste Water Treatment Plant expansion. The adoption of these measures is subject to the approval by the Union County Board of Commissioners. We do recognize that if these measures are not implemented by Union County, USFW may initiate further consultation. I look forward you your response acknowledging you concurrence with this letter. Please do not hesitate to contact me if you have any questions. Sincerely, Christie Putnam, P.E. Assistant to the County Manager Cc: Allen Ratzlaff, USFW Hannah Stallings, Construction Grants and Loan Jon Dyer, Public Works Director 6(21 /us- 5fAJ Jackie - Just a follow up on our discussion today: Please call Jim Struve and let him know that they had RP for both Cu/Zn using the recalculated values (it's up to them if they want to proceed forward with the WERs) and that we can't eliminate the various data points. Also - get up with Marshall and tell him what's going on, and see if they can get a 1 year schedule before the recalculated values (10.2 ug/1 Cu, 91.6 ug/1 Zn) kick in. That way - by the time those limits kick in - they will have completed the WER (since Matt says they should have those completed within 5 months or so). If the WER nos. come out better - then Union Co. would have time to request a modification of the permit and include those limits. I think we also need to tell Union Co. the same thing we told CMU - that if they do the WER - they are stuck with that no. (so they do it at risk -the no. may be smaller than the recalculated value, although I doubt it). - at least to the best of my recollection, we told CMU this (Marshall requested that we tell them that). Thanks much. TiQ L (L T' & a7 5. A-,rz o -i j�{t t /2. GDAA Ll 1 ( — (S 5 u C (1`1 /0-7a3 c. So TSh-t-(c 9 Fi f & 3e (-LT 2 `f ifur ` QA 6, c L.-1Atc-0 l7 `/ (T Ara.d a nJ t SeL sJ (14/41; — feei Abii/k 3 ---k,,,4) 1 Ae4.4 . 6, i 2„/ 114- 4 nwi,f,1/-c, a .(,...... G) e-k.. x, E;cf...4.,,t) ti...._ ,,., 4y7..:4 x4"-a.„, --/,4 kw • 4.,.,,i-4 ,:_-7.-aArA - Tye t -76 ice.,_i__ /1 - mi66.14 ci_e_ /Li C/Se74:- --"- 2 .41,t-t- ./,-, 7re,,a. viywcf. Avel ecAilf ..%4„ ,, e4/0 4,-, Ilijfe, itrAf tfof A ' & /a, /1//4-416 Ceo 5C_, ..Anrce-cLc_. ./4 cljeder, 7-14Ze- g c.t (1ti Z11/.1fi ;Ariv44-4,/feirt, f,4 zo,.); 'Y d7v= (juke, zoo_c" fie a-- Zal C/ b.) 6426-Af_ rya_ l 4/( 3/Zaoy dLT�t� [K JTO1-^4✓dl etoz Cc .' 241 -11•r-•� �1�� y goof' //n+.h l -/0oo3 l/i/w a 3 f /2, /` // Lod/ / / Zoo y Matt Matthews/Aquatic Toxicology Unit Connie Brower/Planning Branch Mark Tye, Union County Union Co. Subject: Union Co. From: Susan Wilson <susan.a.wilson@ncmail.net> Date: Wed, 27 Apr 2005 15:24:41 -0400 To: Jackie Nowell <Jackie.Nowell@ncmail.net>, Matt Matthews <matt.matthews @ncmail.net> Jackie/Matt, I spoke with Jim Struve (H&S) re. Union co. He said they are in the process of submitting another letter outlining their future actions with re. to the cu/zn limits (in response to EPAs call on the clad. issue). He said they've done some clean sampling for Cu and hope to submit enough data so that they can get out of the Cu limit (i.e., will have no RP). For Zn, they are planning to do a WER. I told him we'd be talking again after they submitted their letter. I gave him some info. based on Marshall's comments to the CMU permit (and how, if they choose to do the WER - they will be stuck with that as a limit). Also told him we'd have to go back to SC through the process and with whatever the final outcome is. The other thing he wanted to know was the current status of the cu/zn limits with the existing permit (which they are operating under until we renew the permit). Could you confirm this Jackie? - The way he read it to me (didn't have the permit in front of me) was that no limit was imposed with the existing permit - they just have some timelines to do the study, etc.). Since they are proceeding forward (and we are reviewing as they go) - I don't think this is an issue and we would deem them compliant with the permit. I just want to make sure this is correct. Otherwise - i guess we'll be discussing again after their submittal. 1-55 bAmil /t DE r 1 of 1 4/27/2005 3:43 PM UnionCoc12-Mile-RP. x1s Subject: UnionCo 12-Mile-RP.xls From: Matt Matthews <matt.matthews @ncmail.net> Date: Thu, 31 Mar 2005 10:51:01 -0500 To: Jackie Nowell <Jackie.Nowell C ncmail.net>, Susan A Wilson <Susan.A.Wilson@ncmail.net>, Jeff Manning <jeff.manningC ncmail.net> I have looked over Union Co./Hazen & Sawyer's March 24 submittal. As we requested, they have performed the recalculation procedure including Cladocerans. Their final numbers are identical to the ones I calculated in February for Copper (10.2 CMC) and very close to what I calculated for Zinc (91.6 {theirs} vs 91.47 {mine) CMC). I'm looking into the minor Zn discrepancy. They state in their letter that they have decided to conduct WERs "in order to obtain additional relief." Based on the initial RP calculations (attached), neither metal has a reasonable potential to exceed the site -specific criteria. It is VERY close with Zinc (Maximum predicted = 91.2). I have a few questions about this: 1) Would we use the same metals data initially collected to evaluate RP or also include more recent data? 2) Does SC calculate RP the same way we do? 3) If there is no reasonable potential to exceed the site -specific criteria, why would they propose to conduct WERs? Matt Matthews NC DENR/Division of Water Quality Aquatic Toxicology Unit 1621 Mail Service Center Raleigh, North Carolina 27699-1621 v-(919) 733-2136 f-(919) 733-9959 MailTo:Matt.Matthews@ncmail.net http://www.esb.enr.state.nc.us 1 of 1 3/31/2005 11:18 AM