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Home My WebLink AboutNC0085359_Report_20050324NPDES DOCUHENT SCANNING COVER SHEET 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 cIfefor f Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: March 24, 2005 Thies document iw printed on reuwe paper - more any content on the reirez-oece wide HAZENAI\D SAWYER Environmental Engineers & Scientists March 24, 2005 Ms. Jackie Nowell NPDES Permit Unit NC Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Hazen and Sawyer, P.C. 4944 Parkway Plaza Blvd. Suite 375 Charlotte, NC 28217 704 357-3150 Fax: 704 357-3152 MAR 2 9 2005 DENR - WATER QUALITY POINT SOURCE BRANCH Re: Union County, NC Twelve Mile Creek WWTP Site -Specific Metals Development H&S Job No. 30873 Dear Ms. Nowell: On behalf of the Union County Public Works Department, this correspondence is in response to the Division of Water Quality's letter dated February 9, 2005, requesting that "the County re -submit its proposal for site -specific copper and zinc criteria with Cladoceran data included in the dataset used to conduct the recalculation procedures." Pursuant to your request, the recalculation procedure was performed with Cladocerans included in the analysis dataset. Please refer to Attachment A for revised calculations. For comparison purposes, we have tabulated 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 1. 12.95 ug/L 257.5 ug/L Recalculation Procedure including Cladocerans 1' 10.2 ug/L 91.6 ug/L 1. Based on "total recoverable" and adjusted for a site -specific hardness of 59 mg/L. However, in order to obtain additional relief, the County has decided to conduct a Water Effect Ratio (WER) study in accordance with the Technical Study Plan submitted on April 17, 2003. In accordance with EPA recommendations, WER field sampling should occur over two seasons to obtain representative sampling during low and high stream flow events. Therefore, contingent upon weather conditions, it is anticipated that WER field sampling will occur between May and September 2005. The final WER study report will be submitted for your review and comment by mid -October 2005. The table below summarizes the project milestones to date and the anticipated milestone dates. 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 March 24, 2005 Page 2 Project Milestones Description Date Issuance of NPDES Permit with Metal Limits December 17, 2002 Submission of Technical Study Plan to DWQ April 27, 2003 Submission of Recalculation Procedure Report to DWQ August 28, 2003 Receipt of DWQ Review Comments July 26, 2004 Meeting with DWQ September 30, 2004 Submission of Revised Recalculation Procedure Report to DWQ/EPA November 3, 2004 Receipt of DWQ/EPA Review Comments February 9, 2005 WER Field Sampling May to September 2005 Submission of WER Report to DWQ mid -October 2005 Unless we should hear otherwise from the Division of Water Quality, we will begin WER field sampling in May. Please give me a call at (704) 357-3150 or email me at jstruve@hazenandsawyer.com should you need additional information or further clarification. Very truly yours, HAZEN AND SAWYER, P.C. qw- il. James N. Struve, P.E. Senior Associate JNS/gb Enclosures Cc: Jon Dyer, Union County Mark Tye, Union County Matt Matthews, DWQ — Aquatic Toxicology Unit Jeff Manning, DWQ — Classifications and Standards Laura Shealy, Shealy Environmental Bob Fergen, Hazen and Sawyer Attachment A SECTION 4.0 RESULTS 4.1 Recalculation of the Zinc Water Quality Criteria 4.1.1 The Deletion Process For Zinc Table 4-1 provides the results from the deletion process for zinc. The far right column denotes the code, which represents the reason for retaining or deleting a specie. A key to the code is provided below. Highlighted rows represent circled species that are resident to the site. All species mean acute values (SMAV) are given at a hardness of 50 mg/L. Key to the Code for the Deletion Process S=The species exists at the site. G=The genus exists at the site. F=The family exists at the site. 0=The order exists at the site. C=The class exists at the site. D=Deleted TABLE 4-1: THE DELETION PROCESS FOR THE ZINC ACUTE NATIONAL DATA SET Species Family Order Class Phylum SMAV (ugll) Code Lumbriculus variegatus Lumbriculidae Lumbriculida Oligochaeta Annelida 9712 F Limnodrilus hoffmeisteri Tubificidae Haplotaxida Oligochaeta Annelida >1264 S Nais sp. Naididae Haplotaxida Oligochaeta Annelida 18400 S Amnicola sp. Amnicolidae Mesogastropoda Gastropoda Mollusca 16820 0 Helisoma campanulatum Planorbidae Mesogastropoda Gastropoda Mollusca 1578 G Physa heterostropha Physidae Limnophilia Gastropoda Mollusca 1088 F Physa gyrina Physidae Limnophilia Gastropoda Mollusca 1683 F Corbicula fluminea Corbiculidae Veneroida Bivalvia Mollusca 4900 S Ceriodaphnia dubia Daphnidae Cladocera Crustacea Arthropoda 174.1 F Ceriodaphnia reticulata Daphnidae Cladocera Crustacea Arthropoda 50.70 F Daphnia magna Daphnidae Cladocera Crustacea Arthropoda 355.5 F Daphnia pulex Daphnidae Cladocera Crustacea Arthropoda 252.9 F Asellus bicrenata Asellidae Isopoda Crustacea Arthropoda 5731 G Asellus communis Asellidae Isopoda Crustacea Arthropoda 11610 G Lirceus alabamae Asellidae Isopoda Crustacea Arthropoda 3265 G Crangonyx pseudogracillis Asellidae Isopoda Crustacea Arthropoda 19800 G Gammarus sp. Gammaridae Amphipoda Crustacea Arthropoda 8100 S Argia sp. Coenargridae Odonata Insecta Arthropoda 88960 S Pectinatella magnifica Pectinatelcidae Cheilostoma Phylactolaemata Ectoprocta 1307 S Lophopodella carteri Lophopodidae Cheilostoma Phylactolaemata Ectoprocta 1707 D Plumatella emarginata Plumatellidae Cheilostoma Phylactolaemata Ectoprocta 1607 S TABLE 4-1: THE DELETION PROCESS FOR THE ZINC ACUTE NATIONAL DATA SET Species Family Order Class Phylum SMAV (ug!I) Code Xenopus lavis Pipidae Anura Amphibia Chordata 19176 0 Anguilla rostrata Anguillidae Anguilliformes Osteichthyes Chordata 13630 D ` Oncorhynchus kisutch Salmonidae Salmoniformes Osteichthyes Chordata 1628 0 Oncorhynchus nerka Salmonidae Salmoniformes Osteichthyes Chordata 1502 0 Oncorhynchus tshawytsha Salmonidae Salmoniformes Osteichthyes Chordata 446.4 0 Salmo gairdneri Salmonidae Salmoniformes Osteichthyes Chordata 689.3 0 Salmo salar Salmonidae Salmoniformes Osteichthyes Chordata 2176 0 Salvelinus fontinalis Salmonidae Salmoniformes Osteichthyes Chordata 2100 0 Agosia chrysogaster Cyprinidae Cypriniformes Osteichthyes Chordata 227.8 F Carassius auratus Cyprinidae Cypriniformes Osteichthyes Chordata 10250 S Cyprinus carpio Cyprinidae Cypriniformes Osteichthyes Chordata 7233 S Notemigonus crysoleucas Cyprinidae Cypriniformes Osteichthyes Chordata 6000 S Pimephales promelas Cyprinidae Cypriniformes Osteichthyes Chordata 3830 F Ptychocheilus oregonensis Cyprinidae Cypriniformes Osteichthyes Chordata 6580 F Catostomus commersoni Catostomidae Cypriniformes Osteichthyes Chordata 5228 S Fundulus diaphanous Cyprinidontidae Atheriniformes Osteichthyes Chordata 17940 0 Jordanelia floridae Cyprinidontidae Atheriniformes Osteichthyes Chordata 1672 0 Poecillia reticulata Poeciliidae Atheriniformes Osteichthyes Chordata 6053 F Xiphophorus maculatus Poeciliidae Atheriniformes Osteichthyes Chordata 4341 F Morone americana Percichthyidae Perciformes Osteichthyes Chordata --- D Morone saxatilis Percichthyidae Perciformes Osteichthyes Chordata 119.4 D Lepomis gibbosus Centrarchidae Perciformes Osteichthyes Chordata 18790 S _ Lepomis macrochirus Centrarchidae Perciformes Osteichthyes Chordata 5937 S Tilapia mossambica Cichlidae Perciformes Osteichthyes Chordata 790.0 D Acute Data Set Requirements Requirement 1 - Carassius auratus (Class Osteichthyes) Requirement 2 - Lepomis macrochirus (Bluegill, recreationally important species) Requirement 3 - Fundulus diaphanus (Family Cyprinidontidae; third family of Phylum Chordata) Requirement 4 - Asellus bicrenata (crustacean) Requirement 5 - Crangonyx pseudogracillis (crustacean) Requirement 6 - Argia sp. (an insect) Requirement 7 - Nais sp. (Annelida - a phylum other than chordata or Anthropoda) Requirement 8 - Helisoma campanulatum (Mesogastopoda - an order not already represented) 4.1.2 Determination of Four Most Sensitive Species for Zinc The deletion of the striped bass, Morone saxitilis, was a primary reason for the change in the four most sensitive species. This fish inhabits coastal waters and are commonly found in bays but may enter rivers in the spring to spawn. Although this species does exist in North and South Carolina, it is not possible for it to travel up to the Twelve Mile Creek due to the presence of several intervening dams. Furthermore, the SC Wildlife and Marine Resources has never collected this species outside of coastal counties. The other main reason for the change in the four most sensitive species was the deletion of the Daphnids. Daphnids are not going to exist in free -flowing streams and, therefore, were deleted from the data set. Once the deletion process was completed and the minimum data requirements verified, the final acute value (FAV) and final chronic value (FCV) were calculated. The four most sensitive species from EPA's Original Data Set were the following: #1 Ceriodaphnia (reticulata and dubia) GMAV = 93.95 ugll #2 Morone saxatilis SMAV = 119.4 ug/I #3 Agosia chrysogaster SMAV = 227.8 #4 Daphnia (magna and pulex) GMAV = 299.8 ug/I After the deletion process was applied the four most sensitive species became the following: #1 Ceriodaphnia (reticulata and dubia) GMAV = 93.95 ug/I #2 Agosia chrysogaster SMAV = 227.8 ug/1 #3 Daphnia (magna and pulex) GMAV = 299.8 ug/I #4 Oncorhynchus (nerka, kisutch and tshawytsha) = GMAV=1030 ug/I 4.1.3. Calculation of FAV and FCV for Zinc The Calculations used to obtain the Site -Specific Final Acute Value and Criterion Maximum Concentration For Zinc are as follows from EPA-822-B-94-001: S2 = E [(In GMAV)2] - [(E (In GMAV))2 /4] E (P) - [((ENP))2] /4 L = [(E(In GMAV) - S (E(IP))] /4 A = S(4.05) + L FAV = eA Table 4.2 ZINC RANKING TABLE MAV 1030 299.8 227.8 93.95 InMAV 6.937 5.703 5.428 4.543 22.61 130.8....... 0:3032 (InMAV)2 48.13 32.53 29.47 20.64 P=R/N+1 0.1212 0.0910 0.0607 0.0303 412 0.3482 0.3015 0.2462 0.1741 N = 32 (the number of total GMAV's in the data set) S2 =130.8-22.612/4 = 176.4 0.3032-1.072/4 S = 13.28 L = [22.61-(13.28)(1.07)]/4 = 2.1001 A = (13.28)(40.05) + 2.1001 = 5.070 FAV = e(5.074) = 159.2 The CMC is calculated by obtaining the FAV and dividing it by two. RECALCULATED CRITERION MAXIMUM CONCENTRATION = 79.6 ug/I Zinc (at hardness of 50 mg/L) The CCC is calculated by dividing the FAV by the final acute -chronic ratio (ACR). The ACR for zinc is 2.0 (EPA-820-B-96-001). RECALCULATED CRITERIA CONTINUOUS CALCULATION = 79.6 ug/I Zinc (at hardness of 50 mg/L) 4.2 Recalculation of the Copper Water Quality Criteria 4.2.1 The Deletion Process For Copper Table 4-3 provides the results from the deletion process for copper. The far right column denotes the code which represents the reason for retaining or deleting a specie. A key to the code is provided below. Highlighted rows represent circled species that are resident to the site. All species mean acute values (SMAV) are given at a hardness of 50 mg/L. Key to the Code for the Deletion Process S=The species exists at the site. G=The genus exists at the site. F=The family exists at the site. 0=The order exists at the site. C=The class exists at the site. D=Deleted TABLE 4-3: THE DELETION PROCESS FOR THE COPPER ACUTE NATIONAL DATA SET Species Family Order Class Phylum SMAV (ug/I) Code Lumbriculus variegatus Lumbriculidae Lumbriculida Oligochaeta Annelida 242.7 F Limnodrilus hoffmeisteri Tubificidae Haplotaxida Oligochaeta Annelida 53.08 S Nais sp. Naididae Haplotaxida Oligochaeta Annelida 90.00 S Campeloma decisum Viviparidae Mesogastropoda Gastropoda Mollusca 1877 G Amnicola sp. Amnicolidae Mesogastropoda Gastropoda Mollusca 900.0 0 Goniobasis livescens Pleuroceridae Mesogastropoda Gastropoda Mollusca 166.2 F Gyraulus circumstriatus Planorbidae Mesogastropoda Gastropoda Mollusca 56.21 F Physa heterostropha Physidae Limnophilia Gastropoda Mollusca 35.91 F Physa integra Physidae Limnophilia Gastropoda , Mollusca 43.07 F Corbicula manilensis Corbiculidae Veneroida Bivalvia Mollusca >7184 D Ceriodaphnia reticulata Daphnidae Cladocera Crustacea Arthropoda 18.77 F Daphnia magna Daphnidae Cladocera Crustacea Arthropoda 21.17 F Daphnia pulex Daphnidae Cladocera Crustacea Arthropoda 25.42 F Daphnia pulicaria Daphnidae Cladocera Crustacea Arthropoda 9.263 F Gammarus pseudolimnaeus Gammaridae Amphipoda Crustacea Arthropoda 22.09 G Orconectes rusticus Astacidae Decapoda Crustacea Arthropoda 1397 F Procambarus clarkii Astacidae Decapoda Crustacea Arthropoda 1900 S Crangonyx pseudograacilis Crangonidae Decapoda Crustacea Arthropoda 1290 S Damselfly -- Odonata Insecta Arthropoda 4600 S Acroneuria lycorias Perlidae Plecoptera Insecta Arthropoda 10240 S Caddisfly -- Tricoptera Insecta Arthropoda 6200 S Chironomus decorus Chironomidae Diptera Insecta Arthropoda 834 G Chironomus tetans Chironomidae Diptera Insecta Arthropoda 197.2 G Chironomus sp. Chironomidae Diptera Insecta Arthropoda 30.00 S TABLE 4-3: THE DELETION PROCESS FOR THE COPPER ACUTE NATIONAL DATA SET Species Family Order Class Phylum SMAV (ug/I) Code Pectinate/la magnifica Pectinatelcidae Cheilostoma Phylactolaemata Ectoprocta 135.0 S Lophopodella carteri Lophopodidae Cheilostoma Phylactolaemata Ectoprocta 37.05 D Plumatella emarginata Plumatellidae Cheilostoma Phylactolaemata Ectoprocta 37.05 S Anguilla rostrata Anguillidae Anguilliformes Osteichthyes Chordata 4305 D Oncorhynchus kisutch Salmonidae Salmonifonmes Osteichthyes Chordata 70.25 0 Oncorhynchus nerka Salmonidae Salmoniformes Osteichthyes Chordata 233.8 0 Oncorhynchus tshawytsha Salmonidae Salmoniformes Osteichthyes Chordata 42.26 0 Oncorhynchus clarki Salmonidae Salmoniformes Osteichthyes Chordata 66.26 0 Salmo gairdneri Salmonidae Salmoniformes Osteichthyes Chordata 42.50 0 Salmo salar Salmonidae Salmonifonnes Osteichthyes Chordata 196.6 0 Salvelinus fontinalis Salmonidae Salmoniformes Osteichthyes - Chordata 110.4 0 Acrocheilus alutaceus Cyprinidae Cypriniformes Osteichthyes Chordata 133.0 F Campostoma anomalum Cyprinidae Cypriniformes Osteichthyes Chordata 78.55 F Carassius auratus Cyprinidae Cyprinifonnes Osteichthyes Chordata 157.1 S Cyprinus carpio Cyprinidae Cypriniformes Osteichthyes Chordata 156.8 S Notropis crysocephalus Cyprinidae Cypriniformes Osteichthyes Chordata 331.8 S Pimephales notatus Cyprinidae Cypriniformes Osteichthyes Chordata 72.16 F Pimephales promelas Cyprinidae Cypriniformes Osteichthyes Chordata 115.5 F Ptychocheilus oregonensis Cyprinidae Cypriniformes Osteichthyes Chordata 16.74 F Rhinichthys atratulus Cyprinidae Cypriniformes Osteichthyes Chordata 86.67 F Semotilus atromaculatus Cyprinidae Cypriniformes Osteichthyes Chordata 83.97 S Ictalurus nebulosus Ictaluridae Siluriformes Osteichthyes Chordata 69.81 S Fundulus diaphanous Cyprinidontidae Atheriniformes Osteichthyes Chordata 790.6 D Gambusia afhnis Poeciliidae Atheriniformes Osteichthyes Chordata 196.1 S Poecillia reticulata Poeciliidae Atheriniformes Osteichthyes Chordata 124.6 D Morone americana Percichthyidae Perciformes Osteichthyes Chordata 5860 D Morone saxatilis Percichthyidae Perciformes Osteichthyes Chordata — D Lepomis gibbosus Centrarchidae Perciformes Osteichthyes Chordata 640.9 S Lepomis macrochirus Centrarchidae Percifonnes Osteichthyes Chordata 1017 S Etheostoma caeruleum Percidae Perciformes Osteichthyes Chordata 86.67 G Etheostoma spectabile Percidae Perciformes Osteichthyes Chordata 230.2 G Tilapia mossambica Cichlidae Perciformes Osteichthyes Chordata 684.3 D Acute Data Set Requirements Requirement 1 - Gambusia affinis(Class Osteichthyes) Requirement 2 - Lepomis macrochirus (Bluegill, recreationally important species) Requirement 3 — Etheostoma caeruleum (Family Percidae; Phylum Chordata) Requirement 4 — Oronectes rusticus (crustacean) Requirement 5 - Gammarus pseudolimnaeus (crustacean) Requirement 6 - Acroneuria lycorias (an insect) Requirement 7 - Nais sp. (Annelida - a phylum other than chordata or Anthropoda) Requirement 8 — Campeloma decisum (Mesogastopoda - an order not already represented) 4.2.2 Determination of Four Most Sensitive Species for Copper The deletion of the Daphnids was a primary reason for the change in the four most sensitive species for copper. Daphnids are not going to exist in free -flowing streams and, therefore, were deleted from the data set. Once the deletion process was completed and the minimum data requirements verified, the final acute value (FAV) and final chronic value (FCV) were calculated. The four most sensitive species from EPA's Original Data Set were the following: #1 Ptychocheilus oregonensis SMAV = 16.74 ug/I #2 Daphnia (magna, pulex and pulicaria) GMAV = 17.08 ug/I #3 Ceriodaphnia reticulata SMAV = 18.77 ug/I #4 Gammarus pseudolimnaeus SMAV = 22.09 ug/I The deletion process did not change the four most sensitive species, but did change the total number of MAV's from 41 to 36. 4.2.3. Calculation of FAV and FCV for Copper The Calculations used to obtain the Site -Specific Final Acute Value and Criterion Maximum Concentration For Copper are as follows from EPA-822-B-94-001: S2 = E [(In GMAV)2] - [(E (In GMAV))2 /4] E (P) - I((E(IP))2] /4 L = [(E(In GMAV) - S (E(JP))] /4 A = S(4.05) + L FAV = eA Table 4-4 COPPER RANKING TABLE RANK 4 3 2 1 SUM MAV 22.09 18.77 17.08 16.74 InMAV 3.095 2.932 2.838 2.818 11.61 (InMAV)2 9.580 8.598 8.054 7.940 P=R/N+1 0.1081 0.0811 0.0541 0.0271 O. 'JP 0.3288 0.2847 0.2325 0.1644 N = 36 (the number of total GMAV's in the data set) S2 = 34.17-11.682/4 = 0.0644 = 4.293 0.2704-1.01042/4 0.0150 S = 2.072 L = [11.68-(2.072)(1.0104)]/4 = 2.40 A = (2.072)(1/0.05) + 2.40 = 2.863 FAV = e(2.863) = 17.5 The CMC is calculated by obtaining the FAV and dividing it by two. RECALCULATED CRITERION MAXIMUM CONCENTRATION = 8.70 ug/I Copper (at hardness of 50 mg/L) The CCC is calculated by dividing the FAV by the final acute -chronic ratio (ACR). The ACR for copper is 2.823 (EPA-820-B-96-001). RECALCULATED CRITERIA CONTINUOUS CALCULATION = 6.199 ug/I Copper (at hardness of 50 mg/L) 4.3 Hardness Adjustments For this site, the mixed stream (effluent and receiving waters) hardness was determined to be 59 mg/L so it was necessary to adjust the recalculated criteria for hardness (the EPA SMAV data are adjusted to a hardness of 50 mg/L). The limiting hardness was determined to be approximately 59 mg/L by using the following information: • Low flow data from a nearby USGS gauging station of Twelve Mile Creek in Waxhaw, NC was obtained. The State of North Carolina has determined the appropriate 7Q10 for permitting purposed to be 0 cfs. Using these data it was determined that an appropriate mixed stream concentration under design flow conditions was 100 percent effluent. Therefore, the upstream flow and analytical data are not necessary for the determination of the site -specific criteria. It is important to recognize additional background flow above 0 cfs will provide additional dilution and hence there is a significant safety factor associated with this approach. • Hardness data for 20 effluent samples collected during April and May 2003 indicated an average effluent hardness of 59 mg/L (see Table 2-1). Maximum and minimum concentrations were 80 and 50 mg/L, respectively. All 20 effluent samples for copper were below the detection limit of 2 pg/L. The effluent zinc concentration averaged 32.55 pg/L with a maximum value of 57 pg/L and a minimum value of 24 pg/L. • With an average effluent hardness of 59 mg/L, under design flow conditions including a background 7Q10 flow rate of 0 cfs, the appropriate hardness for limit development is 59 mg/L. The calculation used for hardness adjustment are provided in Appendix B of EPA-822-R-01-005, and is the following: SMAVat site hardness = SMAVat hardness50 1- - slope Site Hardness 50 mg/L From the 1995 Water Quality Criteria Documents manual, the zinc CCC and CMC limits are related to hardness using the slope of 0.8473. At a hardness of 59 mg/L, the appropriate site -specific criterion for total recoverable zinc is 91.6 pg/L. From the 1995 Water Quality Criteria Documents manual, the copper CCC limit is related to hardness using the slope of 0.8545. At a hardness of 59 mg/L, the appropriate site -specific CCC for total recoverable copper is 7.14 pg/L. The slope for the copper CMC is 0.9422, therefore the site -specific CMC is 10.2 pg/L. REFERENCES USED FOR PROJECT Brandlova, J. A., Brandl and C.H. Fernando. 1972. The cladocera of Ontario with remarks on some species and distribution. Can J. Zool. 50: 1373-1403. Brinkhurst, R.O. 1986. Guide to the Freshwater Aquatic Microdrile Oligochaetes of North America. Can. Spec. Publ. Fish. Aquat. Sci. 84:259 p. Bulak, James S. Distribution of Fishes in South Carolina. Study Completion Report WC-8. South Carolina Wildlife and Marine Resources Department. Columbia, South Carolina. Edmonds, Jr., G.F., S.T. Jenson and L. Berner. 1979. The Mayflies of North and Central America, University of Minnesota Press, Minneapolis. Hobb, Horton Jr. 1981. The Crayfish of Georgia. Smithsonian Contributions to Zoology #318. Smithsonian International Press. Lee, D.S. et. al. 1980. Atlas of North American Freshwater Fishes. North Carolina Museum of Natural History. Menhinick, Edward F. 1991. The Freshwater Fishes of North Carolina. The Delmar Company. Pennak, Robert W. 1978. Freshwater Invertebrates of the United States. Second Edition. John Wiley and Sons. New York. Stephan, C.E. et. al. 1985. Guidelines for Deriving Numerical National Water Quality Criteria for the Protection of Aquatic Organisms and Their Uses. National Technical Information Service, Springfield, VA. Stewart, K.W. and Bill P. Stark. 1988. Nymphs of North American Stonefly Genera (Plecoptera). Entomological Society of America. USEPA. 1982. Freshwater Snails (Mollusca: Gastropoda) of North America. EPA-600/3- 82/026. USEPA. 1993. Methods for measuring the Acute Toxicity of Effluents and Receiving Waters to freshwater and Marine Organisms. Fourth Edition. EPA/600/4-90/027F. USEPA. 1994. Interim Guidance on Determination and Use of Water Effect Ratios for Metals. EPA-822-B-94-001. USEPA. 1996. 1995 Updates: Water Quality Criteria Documents for the Protection of Aquatic Life in Ambient Water. EPA-820-B-96-001. USEPA. 2001. Streamlined Water -Effect Ratio Procedure for Discharges of Copper. EPA-822-R-01-005. Vainio, Jouni K., KrzysztafJazdzewski and Risto Vainola. 1995. Biochemical Systematic Relationships Among The Freshwater Amphipods Gammarus varsoviensis, G. Lacustris and G. pulex. CRUSTACEA, 68 (6):587-694. Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Coleen H. Sullins. Deputy Director Division of Water Quality February 9, 2005 Mr. Jon C. Dyer, P.E., Director Union County Public Works Department Twelve Mile Creek WWTP 400 North Church Street Monroe, North Carolina 28112-4804 Subject: Site Specific Criteria for Copper and Zinc Union County Twelve Mile Creek WWTP NPDES No. NC0085359 Union County Mr. Dyer: During our review of Union County's 10/16/04 submittal of follow-up materials regarding the subject site -specific criteria, we noted that Cladocerans were not included in the dataset used for EPA's recalculation procedure. Per our previous written comments and face-to-face conversations, the North Carolina Division of Water Quality (DWQ) has indicated that Cladoceran data must be included in this analysis. Given that DWQ and Union County had reached an impasse regarding this issue and that EPA Region 4 personnel would be approving the site -specific criterion, the Division requested guidance from Mr. Andrew Bartlett, Chief of the East Standards, Monitoring, and TMDL Section of EPA Region 4 (see enclosed letter dated 11/3/04). His response is enclosed and concurs with DWQ's position on this matter. We request that the County re -submit its proposal for site -specific Copper and Zinc criteria with Cladoceran data included in the dataset used to conduct the recalculation procedure. Thank you for your patience with this process. As you may be aware, DWQ will likely be evaluating similar requests in the near future; it is critical that we establish procedures for these evaluations that are scientifically defensible and in compliance with the Clean Water Act. If you have any questions regarding this issue, please contact Matt Matthews at (919) 733-2136 or Jeff Manning at (919) 733- 5083, ext. 579. Respectfully, ) avid A. Goodrich, Supervisor, Point Source Branch Enclosures cc: Mooresville Regional Office Mark E. Tye: 400 North Church Street, Monroe, North Carolina 28112-4804 Joel Hansel: US EPA, Atlanta Federal Center, 61 Forsyth St, SW, Atlanta, GA 30303 Marshall Hyatt: US EPA, Atlanta Federal Center, 61 Forsyth St, SW, Atlanta, GA 30303 Matt Matthews: DWQ — Aquatic Toxicology Unit Jeff Manning: DWQ - Classifications and Standards Jackie Nowell: DWQ - NPDES Permitting Mike Montebello: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 Jeff deBessonet: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 Gina Kirkland: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 No a Carolina Naturally North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-2496 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper ( .r UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 JAN 2 0 '-`ma's Mr. Dave Goodrich, Supervisor Point Source Branch North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Re: Site Specific Criteria for Copper and Zinc Union County Public Works, NPDES No. NC0085359 Dear Mr. Goodrich: l5 IJ U JAN252005 ...� :....... Y t; CuALITY POT : ;;r i! R JCH The Environmental Protection Agency (EPA) has reviewed the updated proposal for site - specific criteria for copper and zinc prepared for the Union County Public Works Department, forwarded by your office and received by EPA on November 15, 2004. This review was conducted using the Interim Guidance on Determination and Use of Water -Effect Ratios for Metals (EPA-823-B-94-001, February 1994). EPA concurs with the position of the State of North Carolina in this matter, as discussed below. Union County's Twelve Mile Creek Wastewater Treatment Plant (WWTP) (NPDES No. NC0085359) was issued a discharge limit for total recoverable copper of 3.8 µg/1 and a discharge limit of total recoverable zinc of 37 µg/l. These limits were based on the water quality standards of the State of South Carolina, which is less than 10 miles downstream of the point of discharge. Union County chose to follow the "Recalculation Procedure". as set out in Appendix B of the Interim Guidance, in order to attempt to develop site specific criteria allowing for higher permit limits while fully protecting the environment. EPA guidance on conducting Recalculation Procedures allows for deletions from the National Dataset for species, genera, families, orders, classes, and phyla that do not "occur at the site". The definition of "occur at the site" applies to those taxa that are "usually present at the site" or which are "present intermittently because they periodically return to or extend their range into the site" (Interim Guidance, pg. 90). Intermittent species may appear at times when habitat conditions change during seasonal variations in the waterbody conditions. All information which is collected to determine which taxa may be deleted must be considered, including habitat evaluations made at different times and seasons. In April 2003, the facility's consultant conducted an on -site habitat evaluation and determined that the habitat was not suitable to support Cladocerans (Ceriodaphnia dubia, Ceriodaphnia reticulata, Daphnia magna, Daphnia pulux, Daphnia pulicaria). The consultant subsequently removed these species from the National Dataset for the recalculation. The Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oa Based Inks on Recycled Paper (Minimum 30% Postconsumer) consultant's report for the initial site evaluation includes the notation that heavy rains had occurred within 7 days prior to the visit (Appendix B, "Habitat Assessment Field Data Sheet"). These high flow conditions appear to be reflected in the photographs provided in the original report. It is to be expected that after heavy rains you may not observe conditions which fully represent seasonal variations that may occur during periods of lower flow. A second series of photographs, taken in October 2003, did appear to represent conditions where pool, riffle and run sequences could be established in the channel, potentially creating habitat suitable for Cladocerans. Based on EPA's review of all of the presented data, we are unable to concur with the consultant's deletion of these organisms from the National Database for copper based on the conflicting nature of the data and therefore concur with the analysis of North Carolina Division of Water Quality. EPA will consider additional information from the facility and/or their consultant if such information becomes available. If you have any questions, please do not hesitate to call Lisa Perras Gordon (404-562- 9317) or Joel Hansel (404-562-9274) of my staff. Sincerely, Andrew Bartlett, Chief • East Standards, Monitoring and TMDL Section Re: NC0085359 Subject: Re: NC0085359 From: Jackie Nowell <jackie.nowell@ncmail.net> Date: Mon, 07 Feb 2005 17:12:57 -0500 To: MTye@co.union.nc.us, Rex Gleason <Rex.Gleason@ncmail.net> Hello Mark, DWQ concurs with Union County's request to relocate the second downstream sampling site from NCSR 1301 to South Carolina SR529-93, effective immediately until road construction has been completed at the site. Sampling frequencies shall remain the same. Hard copy letter to follow within a week. Jackie Nowell MTye@co.union.nc.us wrote: Hi Jackie. We recently spoke about temporarily moving the Downstream II sampling point for the Twelve Mile Creek WWTP. We are requesting the move as a result of increased traffic caused by a NCDOT detour. Due to the high volume of traffic on the "country bridge", sample collection is not safe for our technician. In the past we have used a point approximately 2 miles downstream (current point is approximately 1 mile) located at South Carolina SR 529-93. It is respectfully requested that effective immediately, permission be granted to move our Downstream II sampling point to the Bridge on SR 529-93 until NCDOT discontinues the detour (approximately 1 yr). Thank you. Please contact me if we need to discuss. Mark Tye Assistant Public Works Director (phone) 704 296-4215 (fax) 704 296-4232 Forwarded by Mark Tye/UnionCounty on 01/28/2005 01:18 PM Mark Tye/UnionCounty 01/20/2005 11:12 AM To iackie.nowell © ncmail.net cc Subject NC0085359 1 of 2 2/7/2005 5:13 PM Re: NC0085359 Hi Jackie, I hope all is well. Thank you for returning the call I had in to Susan Wilson. I have three (3) basic things I need your help with today: 1. Our 12 Mile Creek WWTP is being expanded from 2.5 to 6.0 MGD. We are making significant upgrades to our Supervisory Control and Data Acquisition (SCADA) system as a part of the expansion. To whom do I send a letter requesting consideration for a variance on the 24/7 rule that kicks in at 5.0 MGD. Name, Title and Address please. 2. NCDOT has routed a large volume of traffic across our 12 Mile Creek WWTP Downstream II bridge as part of a detour. The detour may last up to a year. Due to the volume of traffic on the "country bridge", it is now very unsafe to get stream samples. The banks are too steep to safely traverse. What do I need to do to get Downstream II suspended or moved asap? 3. Is there any "new news" on the 12 Mile Creek WWTP copper & zinc issue? That's all for now. As always, thank you for your time and support. Mark Tye Assistant Public Works Director (phone) 704 296-4215 (fax) 704 296-4232 2 of 2 2/7/2005 5:13 PM NC0085359 • 01/20/2005 11:12 AM Subject: NC0085359 From: MTye@co.union.nc.us Date: Fri, 28 Jan 2005 13:29:40 -0500 To: jackie.nowell@ncmail.net Hi Jackie. We recently spoke about temporarily moving the Downstream II sampling point for the Twelve Mile Creek WWTP. We are requesting the move as a result of increased traffic caused by a NCDOT detour. Due to the high volume of traffic on the "country bridge", sample collection is not safe for our technician. In the past we have used a point approximately 2 miles downstream (current point is approximately 1 mile) located at South Carolina SR 529-93. It is respectfully requested that effective immediately, permission be granted to move our Downstream II sampling point to the Bridge on SR 529-93 until NCDOT discontinues the detour (approximately 1 yr). Thank you. Please contact me if we need to discuss. Mark Tye Assistant Public Works Director (phone) 704 296-4215 (fax) 704 296-4232 Forwarded by Mark Tye/UnionCounty on 01/28/2005 01:18 PM Mark Tye/UnionCounty To jackie.nowell@ncmail.net cc Subject NC0085359 Hi Jackie, I hope all is well. Thank you for returning the call I had in to Susan Wilson. I have three (3) basic things I need your help with today: 1. Our 12 Mile Creek WWTP is being expanded from 2.5 to 6.0 MGD. We are making significant upgrades to our Supervisory Control and Data Acquisition (SCADA) system as a part of the expansion. To whom do I send a letter requesting consideration for a variance on the 24/7 rule that kicks in at 5.0 MGD. Name, Title and Address please. 2. NCDOT has routed a large volume of traffic across our 12 Mile Creek WWTP Downstream II bridge as part of a detour. The detour may last up to a year. 1 of 2 1/28/2005 2:13 PM NC0085359 Due to the volume of traffic on the "country bridge", it is now very unsafe to get stream samples. The banks are too steep to safely traverse. What do I need to do to get Downstream II suspended or moved asap? 3. Is there any "new news" on the 12 Mile Creek WWTP copper & zinc issue? That's all for now. As always, thank you for your time and support. Mark Tye Assistant Public Works Director (phone) 704 296-4215 (fax) 704 296-4232 2 of 2 1/28/2005 2:13 PM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY s ��r w REGION 4 i �r%% (. ATLANTA FEDERAL CENTER ;�yrREET q<oroa ATLANTA, 61 OGEORGIARSYTH T 0303 8960 J\\tev srgTFs A Y� %IAN20?r; Mr. Dave Goodrich, Supervisor Point Source Branch North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Re: Site Specific Criteria for Copper and Zinc Union County Public Works, NPDES No. NC0085359 Dear Mr. Goodrich: J A N 2 5 2005 !)_`,,;- QUALITY P01,il S0iZE BRANCH The Environmental Protection Agency (EPA) has reviewed the updated proposal for site - specific criteria for copper and zinc prepared for the Union County Public Works Department, forwarded by your office and received by EPA on November 15, 2004. This review was conducted using the Interim Guidance on Determination and Use of Water -Effect Ratios for Metals (EPA-823-B-94-001, February 1994). EPA concurs with the position of the State of North Carolina in this matter, as discussed below. Union County's Twelve Mile Creek Wastewater Treatment Plant (WWTP) (NPDES No. NC0085359) was issued a discharge limit for total recoverable copper of 3.8 µg/1 and a discharge limit of total recoverable zinc of 37 µg/1. These limits were based on the water quality standards of the State of South Carolina, which is less than 10 miles downstream of the point of discharge. Union County chose to follow the "Recalculation Procedure" as set out in Appendix B of the Interim Guidance, in order to attempt to develop site specific criteria allowing for higher permit limits while fully protecting the environment. EPA guidance on conducting Recalculation Procedures allows for deletions from the National Dataset for species, genera, families, orders, classes, and phyla that do not "occur at the site". The definition of "occur at the site" applies to those taxa that are "usually present at the site" or which are "present intermittently because they periodically return to or extend their range into the site" (Interim Guidance, pg. 90). Intermittent species may appear at times when habitat conditions change during seasonal variations in the waterbody conditions. All information which is collected to determine which taxa may be deleted must be considered, including habitat evaluations made at different times and seasons. In April 2003, the facility's consultant conducted an on -site habitat evaluation and determined that the habitat was not suitable to support Cladocerans (Ceriodaphnia dubia, Ceriodaphnia reticulata, Daphnia magna, Daphnia pulux, Daphnia pulicaria). The consultant subsequently removed these species from the National Dataset for the recalculation. The Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) consultant's report for the initial site evaluation includes the notation that heavy rains had occurred within 7 days prior to the visit (Appendix B, "Habitat Assessment Field Data Sheet"). These high flow conditions appear to be reflected in the photographs provided in the original report. It is to be expected that after heavy rains you may not observe conditions which fully represent seasonal variations that may occur during periods of lower flow. A second series of photographs, taken in October 2003, did appear to represent conditions where pool, riffle and run sequences could be established in the channel, potentially creating habitat suitable for Cladocerans. Based on EPA's review of all of the presented data, we are unable to concur with the consultant's deletion of these organisms from the National Database for copper based on the conflicting nature of the data and therefore concur with the analysis of North Carolina Division of Water Quality. EPA will consider additional information from the facility and/or their consultant if such information becomes available. If you have any questions, please do not hesitate to call Lisa Perras Gordon (404-562- 9317) or Joel Hansel (404-562-9274) of my staff. Sincerely, Andrew Bartlett, Chief East Standards, Monitoring and TMDL Section SOC PRIORITY PROJECT: No To: Permits and Engineering Unit Water Quality Section Attention: Carolyn Bryant Date: January 18, 2005 NPDES STAFF REPORT AND RECOMMENDATIONS County: Union NPDES Permit No.: NC0085359 MRO No.: 04-108 PART I - GENERAL INFORMATION 1. Facility and address: Twelve Mile Creek WWTP Union County Public Works Department 400 North Church Street Monroe, N.C. 28112 2. Date of investigation: January 13, 2005 3. Report prepared by: Samar Bou-Ghazale, Env. Eng. I 4. Person contacted and telephone number: John Hohn, (704) 506-0462. L d�v 2 5 �nn� J A N 5 2005 i; 3 - . QUALITY PutfiT Sub,:CE BRANCH 5. Directions to site: From the jct. of Hwy 485 and Hwy 16 in Union County, travel south on Hwy16 approximately 6 miles to the intersection with Cuthbertson Road (SR 1321). Turn right on Cuthbertson Road and travel approximately 0.2 miles to the WWTP located on the left. 6. Discharge point(s), List for all discharge points: Latitude: 80° 45' 44" Longitude: 34° 57' 01" Attach a USGS Map Extract and indicate treatment plant site and discharge point on map. USGS Quad No.: H 15 NE U.S.G.S Name: Catawba NE, S.C.-N.C. 7. Site size and expansion area consistent with application: Yes. There is sufficient area available for expansion, if necessary, 8. Topography (relationship to flood plain included): The site has gently rolling topography (3-5% slopes) and is not located in a flood plain. 9. Location of nearest dwelling: Approx. 500+ feet from the WWTP site. Page Two 10. Receiving stream or affected surface waters: a. Classification: C b. River Basin and Subbasin No.: Catawba 030838 c. Describe receiving stream features and pertinent downstream uses: The receiving stream appeared to be 20-25 feet across and 2-3 feet deep with a sandy bottom. Good flow observed during the site inspection. No other known dischargers exist on this channel below the point of discharge before the stream enters South Carolina. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS L a. Volume of wastewater: 2.5 MGD (Design Capacity) b. What is the current permitted capacity: 2.5 MGD c. Actual treatment capacity of current facility (current design capacity): 2.5 MGD d. Date(s) and construction activities allowed by previous ATCs issued in the previous two years: N/A. e. Description of existing or substantially constructed WWT facilities: The existing WWT facilities consist of an influent pump station followed by an automatic self- cleaning influent filter screen, a vortex grit chamber, pH adjustment (caustic feed), two (2) carrousel type oxidation ditch systems (each basin has a fermentation basin with two mixers and an anoxic basin with one mixer), two (2) final clarifiers, dual tertiary sand filters, ultra -violet disinfection, cascade post aeration, two sludge storage tanks with diffused aeration, a 1.0 MG sludge digester, alum and polymer feed systems, and a stand-by power generator for the pump station. f. Description of proposed WW1' facilities: There are no proposed facilities at this time. g• Possible toxic impacts to surface waters: None at this time. h. Pretreatment Program (POTWs only): Inactive. 2. Residual handling and utilization/disposal scheme: a. If residuals are being land applied specify DWQ Permit No. WQ0007486 Residuals Contractor: EMA, Inc., Tel# 336-751-1441. Screenings are removed and transported by Republic Waste Services (tel# 704- 596-2077) to the County Landfill. 3. Treatment plant classification: Class IV (no change from previous rating). 4. SIC Code(s): 4952 Wastewater Code(s): 01 MTU Code(s): 10103 Page Three PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? Public monies were used in the construction of this facility. 2. Special monitoring or limitations (including toxicity) requests: None at this time. 3. Important SOC/JOC or Compliance Schedule dates: N/A 4. Alternative analysis evaluation: N/A PART IV - EVALUATION AND RECOMMENDATIONS The Union County Public Works Department has requested renewal of the subject permit. The facility is experiencing poor settling at the clarifier. There has also been elevated Fecal Coliform and TSS levels recently. Mr. Hahn was referred to the Division's Technical Assistance unit if he needed assistance regarding the above noted problems. No other problems were noted during the site investigation. Pending receipt and approval of the P & E, it is recommended that the permit be renewed as requested. Signature of Repo " ' reparer Date /9%/7 /e„ Water Quality Regional Supervisor Date Facility Information Latitude: Loneitudc: Quad r : Stream Class: C Receivine Stream: 34°57'01" 80°45'44" H15N£ Twelve Mile Creek Permitted Flow: 2.5 MGD Sub -Basin: 03-08-38 Facility Location Twelve Mile Creel: WWTP NC00S5359 Union County C53-O3�d��1 United States Department of the Interior FISH AND WILDLIFE SERVICE Asheville Ficld Office 160 Zillicoa Street Asheville, North Carolina 28801 January 5, 2005 Post-lt' Fax Note 7671 DaUe p 3(W lc)ciae60. 1 Z From 1. _ —}(� To Co/Do0I Co. Phone q Phone k Fax It Fax i) Construction Grants and Loans Section North Carolina Department of Environment and Natural Resources 1633 Mail Service Center Raleigh, North Carolina 27699-1633 Dear Ms. Stallings: **la 04 s0111 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 a copy of the subject documents with your letter dated December 2, 2004. Also included with your letter was a copy of the North Carolina Division of Water Quality's "Finding of No Significant Impact" (FONSI) for the subject project. The following comments arc provided in accordance with the provisions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e), the Migratory Bird Treaty Act, as amended (16 U.S.C. 703) (MBTA); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act). According to the information provided, Union County is proposing to expand the Twelve Mile Creek Wastewater Treatment Plant (WWTP) from its current capacity of 2.5 million gallons per day (MGD) to 6.0 MGD. This alternative was chosen over constructing a land application system or attaching to the Charlotte/Mecklenburg system because it offered the lowest capital and present value costs. The current plant, constructed in 1996, is located on an 88-acre parcel about 400 feet west of NC 16 along Twelve Mile Creek in the Town of Waxhaw. Twelve Mile Creek flows into the Catawba River below Lake Wylie near Van Wyck, South Carolina. The plant will serve an area of about 93 square miles, including the towns of Waxhaw, Mineral Springs, and Wesley Chapel; a portion of the towns of Stallings, Indian Trail, and Weddington; and the unincorporated portions of the basin. Additionally, a portion of the proposed expansion is necessary to receive discharge from the Rocky River and Goose Creek areas of northern Union County in order to avoid the construction of a treatment plant on the Rocky River and to shut down an existing plant (Hunley Creek WWTP) on Goose Creek. All construction associated with the proposed expansion will occur immediately adjacent to the existing facility. BE5-d lDO d DEB-1 BZZ9511818 SUED] puy uoilanJ1su00_1N0ad WYBD:01 500Z-01-E0 Based on the finding of the subject Environmental Assessment, the Water Quality Section of the North Carolina Division of Water Quality issued the FONSI. Union County has since decided to' seek federal funding for this project through the North Carolina Clean Water State Revolving Fund, necessitating a review of the Environmental Assessment by federal agencies. General Comments: According to the Environmental Assessment, Union County directly controls 54.5 percent of the basin and 64 percent of the developable land within the project service area. Union County's decisions concerning the proposed project, and any mitigative measures, will determine the future water quality for the aquatic life that inhabits the more than 455 miles of "regulated" streams in the project area and the people that depend on that water. The Environmental Assessment lists a number of potential environmental impacts that could occur as a result of the proposed project. However, it repeatedly contends that current and proposed ordinances, storm -water -control measures, and riparian buffers will mitigate for expected project impacts. Further, though the Environmental Assessment states that "It is reasonable that the Project will contribute to some increased development within the Project's service area," it concludes that the "impacts and extent of development on individual septic tanks or private package plants might not be significantly different than impacts resulting from implementation of the Project." If the difference between development with or without project implementation is not "significantly different," theionly rationale for implementing the proposed project would be to improve water quality; the economics of future development would not be a consideration (the stated purpose of the project is simply predicted as "growth"). 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 system' that presumably (as the Environmental Assessment does not quantify or qualify) contains failing septic _ ystems and "gray water" discharges. However, because a "no action" alternative was not considered, it is not possible to compare the benefits of the proposed project to allowing current and future evelopment to continue using only septic systems. J If development will truly occur with only insignificant differences between implementing the project and not implementing the project, the principal impact of the proposed project will be the placement of the connecting sewer lines to developing areas. Therefore, to accomplish the proposed project goal of improving water quality, the placement of these lines cannot affect water quality beyond the expected gains in water quality that will be made by providing sewer to the project area. Because the Environmental Assessment does not quantify the current or predicted future impacts of septic system failure or "gray water" discharge, it is not possible to assess the gains that will be made in water quality by providing a public sewer system. Expansion of the Twelve Mile Crcek 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 subject Environmental Assessment. 2 9E5-d ZOO d PE8-1 OZZ9511618 sueol puy s1uei5 uoilDnJlsu00-INOdd 1NY6p:O1 5OOZ-01-£0 We disagree with the Environmental Assessment's contention that current and proposed ordinances, storm -water -control measures, and riparian buffers will mitigate for the impacts of the proposed project. And while we concur with the Environmental Assessment's assertion that the direct impacts appear to be minimal, we believe the secondary and cumulative impacts of the proposed project could be considerable. Most notable are the proposed, under construction, and completed trunk lines to the Twelve Mile Creek WWTP and the associated current and future development. The availability of municipal sewer service will promote new development in areas that are presently rural residential, agricultural, or forested and would not necessarily be developed without the availability of sewer, service, particularly nonresidential development. In addition, infill at higher densities will occur in developing areas where sewer service is available. Throughout the Environmental Assessment, statements such as the following are made: "The measure of difference between secondary and cumulative impacts related to the Project versus impacts that would occur were the Project not implemented is impossible to quantify, but it does not seem significant." Such statements are made as a rationale for minimizing the potential secondary and cumulative impacts of the proposed project. We do not believe statements such as these are justified, and nothing in the Environmental Assessment provides substantial evidence to support such statements. In a letter from the North Carolina Wildlife Resources Commission (Commission) sent to Ms. Melba McGee, Environmental Coordinator for the North Carolina Office of Legislative and Intergovernmental Affairs (dated June 27, 2002, and included as Appendix H-1 in the Environmental Assessment) regarding this project, the Commission details numerous secondary and cumulative' impacts that can be expected from the proposed project and provides recommended measures they believe are necessary to avoid or minimize those impacts. Rather than reiterate the specific points, we simply state that we support the Commission's assessment of this project (and the supporting documentation), particularly with regard to secondary and cumulative impacts and what is necessary to control erosion and storm water and to protect floodplains, streams, and wetlands. Unfortunately, very few of their concerns or recommendations are addressed in the Environmental Assessment, and in some instances the opposite occurs. For example, the Commission recommends that "sewer lines ... be kcpt out of riparian buffer areas," and they go on to describe the many impacts of not doing so. Yet the Environmental Assessment states that "Taking advantage of the Project's additional capacity, new gravity sewer lines that lead to the WWTP would typically be constructed near existing stream channels." Stream and Wetland Buffers The draft "Union County Stormwater Discharge and Quality Control Ordinance" (Ordinance) currently contains provisions for riparian buffers that range from 30 feet along intermittent streams with a drainage area of less than 1 square mile to 100 feet, plus 85 percent of the flood fringe2 in basins greater than 1 square mile for perennial streams. In the letter to Ms. McGee (mentioned above), the Commission stated the following: 2 As defined in the draft Ordinance, the flood fringe is "The land area located between the floodway encroachment lines and the line depicting the maximum elevation subject to inundation by the base flood (100-year flood). Floodway elevations arc to be based upon existing Federal Emergency Management Agency (FEMA) studies or new studies developed where FEMA mapping is not available." 3 9E9-d EOO d 7E8-1 BZZ9911618 sueol pry slueJ9 uoitonitsuo3-MOdd 087:01 500Z-01-E0 We recommend the maintenance or establishment of a minimum 100-foot native forested buffer along each side of perennial streams and 50-foot native buffers along each side of intermittent streams and wetlands throughout the present and future service areas of the entire municipal jurisdiction (EPA 2000; Stewart et al 2001). We additionally encourage the implementation of buffers on ephemeral streams due to the important functions that they provide as headwater streams (Alexander et al. 2000; Peterson et al. 2001). Buffers should be measured horizontally from the edge of the streambank (Knutson and Naef 1997), which may result in wider buffers at higher gradients, and must be provided over the entire length of the stream, including headwater streams. Further, we recommend Ieaving 30% of the development area as greenspace, which would include buffers and wetlands and ensure that the greenspace is connected to natural resources. Wide, contiguous riparian buffers have greater and more flexible potential than other options to maintain biological integrity (Horner et al. 1999) and could ameliorate many ecological issues related to land use and environmental quality (Naiman et al. 1993) ... riparian buffers serve to protect water quality by stabilizing the stream banks, filtering capacity of stormwater runoff, and provide habitat for aquatic and fisheries resources. We strongly support this recommendation by the Commission and believe the recommended buffer widths represent the minimum necessary to protect water quality.3 Though we applaud the efforts of the draft Ordinance (the proposed buffer widths are considerably better than current conditions), we do not believe they go far enough (the buffers are too narrow) to protect aquatic ecological integrity. Of particular concern is the fact that the Environmental Assessment states that "Taking advantage of the Project's additional capacity, new gravity sewer lines that lead to the WWTP would typically be constructed near existing stream channels," and the Ordinance gives specific exemption to gravity sewer lines for their construction in the "streamside zone."4 If the sewer lines that connect to the expanded WWTP are placed within 100 feet of perennial streams or within 50 feet of intermittent streams, the water quality benefits of providing the sewer service could be negated by the impacts to the stream of having an inadequate buffer zone. Additionally, if sewer lines are constructed within the 50-foot and 100-foot buffer zones, it is likely that adjacent development will be placed similarly closer to streams or wetlands. We also remind you that Executive Order 11988 requires federal agencies to consider and protect floodplain functions. As illustrated in Figure 5 of the Environmental Assessment, a considerable portion of the project area is within the 100-year floodplain. We believe the recent examples of flooding throughout North Carolina highlight the importance of avoiding the "long- and short-term impacts associated with the occupancy and modification of floodplains" and that we should "avoid direct and indirect support of floodplain development." The Environmental Assessment does not specifically address floodplain development (beyond riparian buffers). To help prevent floodplain development, development within the floodplain should be discouraged by not allowing any residential, commercial, or industrial facility built within 100 feet of a stream or within 3 These buffer widths should be doubled on streams known to contain, or influence waterways that contain, federally protected species. As defined in the draft Ordinance, the streamside zone "shall consist of an undisturbed strip of land measured horizontally away from the top of the steam (channel) bank and perpendicular to the stream centerline (or from the edge of contiguous sensitive areas; e.g., wetlands)." 4 9E5-d Z10/1/00 d PE6-1 BZZ9512818 SUED] puy slueJD uoilonmump-Hold V6109:01 500Z-01-E0 the 100-year floodplain (whichever is greater) to connect to current or new sewer lines (this does not preclude existing residences or businesses from connecting). Storm -water Management The adequate treatment of storm water in development areas is essential to the protection of water quality and aquatic habitat in rapidly developing landscapes. The expansion of urban areas is creating more impervious surfaces (such as roofs, roads, and parking lots), which collect pathogens, metals, sediment, and chemical pollutants and quickly transmit them to receiving waters. According to the Environmental Protection Agency, this nonpoint-source pollution is one of the major threats to water quality in the United States and is linked to chronic and acute illnesses from exposure through drinking water, seafood, and contact recreation. Impervious surfaces also lead to the pooling of Storm water, which can cause an increase in the number of breeding areas for mosquitoes, the vectors for many serious diseases. Best management practices can reduce, but not eliminate, the loading of common storm -water pollutants. Designs that collect runoff and allow it to infiltrate the soil have the highest documented pollutant -removal efficiency, eliminating nearly all lead, zinc, and solids and more than 50 percent of total phosphorous. Ponds and wetlands, which allow contaminants to settle out of the water column or to be broken down by sunlight and biological activity, can remove more than 70 percent of bacteria. The Commission has developed a "Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water Quality" that we support and encourage you to use; it can be accessed via the Internet as follows: http://www.ncwildlife.org/pg07 wildlifespeciescon/pg7c3_impacts.pdf. Federally Listed Endangered and Threatened Species The Environmental Assessment states that "Neither the federally -protected species of Union County nor any species of concern, should suffer any significant impacts as a distinct consequence of tho Project." While acknowledging in the Environmental Assessment that "there is potential for secondary and cumulative impacts to wildlife and natural vegetation due to the construction of new developments that would tie in their sewer lines to the WWTP," no efforts have been made to account for the impacts of secondary development to federally listed species, particularly Schweinitz's sunflower (Helianthus schweinitzii). Furthermore, because these impacts (or the potential for these impacts) are not acicnowledged, no efforts have been made to avoid or minimize any impacts. We remind you that when you are assessing the potential impacts of this project, secondary (i.e., housing developments, commercial development) and cumulative impacts must be taken into account. More than a dozen sites in the Twelve Mile Creek basin are currently known to contain Schweinitz's sunflower and/or Georgia aster (Aster georgianus), a candidate for federal listing. Therefore, the statement in the Environmental Assessment that "Neither the federally -protected species of Union County (already discussed) nor any species of concern, should suffer any significant impacts as a distinct consequence of the Project" is not justified without measures in place to ensure that the ; species are not impacted. Unless the associated sewer lines will be constructed regardless of whether additional connections (and thus development) will be added, the U.S. Fish and Wildlife Service considers the sewer lines that will connect to the Twelve Mile Creek WWTP an interrelated/interdependent activity. An interrelated activity is an activity that is a part of the proposed 5 9E5—d Z10/500 d PE8-1 6ZZ9511816 sueo7 puy slueij uoil3nilsumj-110dd VV05:01 500Z—01—E0 action and depends on the proposed action for its justification. An interdependent activity is an activity that has no independent utility apart from the action under consultation. A determination, of whether other activities are interrelated to, or interdependent with, the proposed action under consultation is made by applying a "but for" test. That is, it must be determined that the other activity under question would not occur "but for" the proposed action under consultation.5 In the context of the Twelve Mile Creek WWTP expansion, the construction of new sewer lines (that will connect to the expanded Twelve Mile Creek WWTP) is an action that would not occur without the expansion of the WWTP. Thus, the construction of these lines is an interdependent activity, and the impacts of these new lines must be analyzed with the effect of the Twelve Mile Creek WWTP expansion. In turn, the availability of municipal sewer is a prerequisite for some development projects. Consequently, because these projects depend on the construction of sewer lines, which must be connected to the Twelve Mile Creek WWTP, these developments are interrelated to the original -- proposed action --the expansion of the WWTP--and must also be analyzed in conjunction with the action. Therefore, before we can conclude section 7 consultation under the Act, you must either provide us with information showing that the sewer lines arc not interrelated to, or interdependent with, future development, or you must provide us with more information regarding the impacts of the sewer lines and any secondary impacts (i.e., housing developments, commercial development) associated with their construction. Statements such as the following are not sufficient: "The measure of difference between secondary and cumulative impacts related to the Project versus impacts that would occur were the Pro ect not implemented is impossible to quantify, but it does not seem significant." For examplesthe paths of the connecting sewer lines, commercial development, and impacts to any sites t are currently known to harbor federally listed species can and should be addressed. Similarluture developments that plan to connect to new sewer lines should be surveyed for federally listed species before any ground-dis riling activities occur (before being allowed to connect to the subject sewer lines). Additionally ie following statement in the Environmental Assessment is not accurate: "The federally -protected sunflower Helianthus schweinitzii prefers edge habitats." Schweinitz's sunflower is a prairie species that prefers open habitats, not ecotone (edge). The species is often found in edge habitats, as it mimics the open habitats in which it evolved. / In addition, if the proposed project is to include the additional discharge from the treatment plant /!/ proposed for the Rocky River and the closing of the Hunley Creek WWTP on Goose Creek, any impacts (direct, secondary, or cumulative) in the Goose Creek watershed that are a result of the proposed project must be assesses: their potential impacts on the federally endangered Carolina heelsplitter (Lasmigona decorat. t'.' e are concerned that by providing additional sewer to the Goose Greek watershed_(an area that currently.is ineligible for additional discharge permitssadditional growth and/or higher -density growth is likely to occur that could negatively affect this critically gered mus reation of "Edge" The Environmental Assessment appears to tout the beneficial effects of the connecting sewer lines by statements such as the quote in the preceding paragraph relating to Schweinitz's sunflower and by statements such as "New sewerline corridors would prove to be wildlife corridors offering edge I 5U.S. Fish and Wildlife Service and National Marine Fisheries Service. 1998. Endangered Species Consultation Handbook — Procedures for Conducting Consultation and Conference Activities under Section 7 of the Endangered Species Act. Washington, D.C. 6 9E5-d Zl0/900 d PEB-.L BZZ9512616 sueol puy sluel uoilonulsuo0-viodd MVy05:01 500Z-01-EO habitats with natural vegetation," While it is true that the sewer line rights -of -way will probably be used as wildlife corridors, the species likely to use them are not likely to be desirable to native biological communities or the people living in the area. Further, it is very improbable that "natural vegetation" will be found in the corridors unless actively managed for (see paragraph below for more on exotic species). The creation of "edge" can dramatically and adversely affect adjacent biological communities. An increase in "edge" typically increases the amount of wind and light penetration into adjacent habitat, often altering the plant community. The creation of "edge" also increases nest parasitism by the brown -headed cowbird and increases predation by such opportunistic predators as rats, raccoons, skunks, and domestic cats, an effect that is generally more pronounced in urban areas. An abundance of edge can even cause reproductive failure, restriction of range, loss of genetic variability, and mortality for species that have very specific habitat requirements. Utility rights -of -way and the edge created by them can also be major vectors for the transport of invasive exotic species. These factors (among others) can have significant negative impacts on species dependent on adjacent interior habitats. Invasive Exotic Species As previously mentioned, we are concerned with the introduction and spread of invasive exotic species in association with the secondary and cumulative impacts of the proposed project, The contention in the Environmental Assessment that "New sewerline corridors would prove to be wildlife corridors offering edge habitats with natural vegetation" is, as we previously stated, not likely unless the corridors are actively managed for native plants. Without active management, including the revegetation of disturbed areas with native species, these corridors will likely only be sources of (and corridors for) the movement of invasive exotic plant species. Exotic species are a major contributor to species depletion and extinction, second only to habitat loss. Exotics are a factor contributing to the endangered or threatened status of more than 40 percent of the animals and plants on the Federal List of Endangered and Threatened Wildlife and Plants. It is estimated that at least 4,000 exotic plant species and 2,300 exotic animal species are now established in the United States, costing more than $130 billion a year to control. Additionally, the U.S. Government has many programs and laws in place to combat invasive species (see www.invasivespecies.gov) and thus cannot spend money to counter these efforts. Specifically, Section 2(a)(3) of Executive Order 13112 - Invasive Species (February 3, 1999) directs federal agencies to "not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere." Despite their short-term erosion -control benefits, many exotic species used in soil stabilization seed mixes are persistent once they are established, thereby preventing the reestablishment of native vegetation. Many of these exotics plants are also aggressive invaders of nearby natural areas, where they are capable of displacing already established native species. Therefore, we strongly recommend that only native plant species be used in association with all aspects of this project, including secondary impacts (i.e., sewer lines). Further, if the Environmental Assessment's intent is to show that native plants will be at least a significant component of the sewer line rights -of -way, a maintenance plan that is conducive to native species will be necessary. We have enclosed a list of sources of native plant material and some general guidelines for the establishment of native warm -season grasses. 6 Lists of invasive exotic plants can be found at httpltwww.nzeppc.org/ hnp://www.invasive.org/eastern/srs/on the Internet. 7 9£9-d ZIO/100 d b£8-1 8ZZ99I18I8 sueol puy slueJ9 uoilonilsum iUld Wy0s=01 900Z-01-£0 The following statement is made in the Environmental Assessment: "... a well -managed public wastewater treatment plant is the most effective means of protecting water quality from sewage impacts, compared to septic systems and package plants." We agree, in principle, with this statement, particularly as it relates to areas with problematic soils types. However, unless direct impacts to streams, wetlands, and riparian areas are minimized and secondary and cumulative impacts are addressed, these gains in water quality could easily be negated. 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, ri Brian P. Cole Field Supervisor Enclosure cc: Ms. Shari Bryant, Piedmont Region Coordinator, Falls Lake Office, North Carolina Wildlife Resources Commission, 11421-85 Service Road, Creedmoor, NC 27522 8 9ES—d Z10/800 d PE6-1 6ZZ9S11618 sueo7 puy slueJD uoilofJlsu03-10d VVOS O 1 900Z-01—£0 Sources of Seeds of Native Forbs (Wildflowers) for the Southeastern United States — 07/08/03 Compiled by Robert Giennon, U.S. Fish and Wildlife Service? Edenton, North Carob'ba Species — Connor Name (Scientific Name) Cultivaur' - (Oriiin State, PHZ) Sources ( , Implies Lower Prices) PHZ = USDA Plant Hardiness Zones (cultivars Arc Generally Well Adapted OAe Plant Hardiness Zone North and South of Origin Legumes Deervetch, Sointvetch Aeschynorneae americana) Common 5,7(G),18 . Partridge Pea (Cassia 1asciculata) Common 1,2,4,5,12,13,23,24,25,26-all G,5,18-not G • Partxidge Pea (Cassia fasciculaata) Comanche (Texas, 7a) - 6,7,8-QII G, 5-not G ' . Partridge Pea (Cassia fasciculata) _ Lark (Arkansas, 7b) 19„20,21--all G Illinois bundlcflowcr (Dcsmanthus illinoensis) Common 1,2,4,6,1011,12,13,16,23,24,25,26, 27-all G, 5-not G 1 Illinois bundleflower (Desmanthus'tlliooevsis) Sabine (Toms, 8a) 7,8-all G - • Non --Legumes Tickseed Sunflower (Bideos aristosa) Commoni _ 1,4-all G Lanceleaf Coreopsis (Coreopsis lanceolasa) Common 1,2,4,6,9,10,14,16,17,22,25,26-all G, 15-not G Plains Coreopsis (Coreopsis tinctoria) Common 1,2,3,4,9,10,13,14,16,17,22,24,26-all G Purple Cou:efower purpurea) Common 1,2,3,4,6,10,13,14,17,22,25,26-all G, 1542ot G Indian Blanket (Gaillardiapulchella) Common _ 1,2,4,6,10,14,16,17,26-a l G Maximillian Sunflower (Hcl iandthas m ' i) Common 1,2,4,6,7,8,10,11,16,17,23,25,26-all G, 5-not G Evening Primrose (Oenothera biennis) Common I,2,4,6,9,10,16,17,26-all G Blackeyed Susan (Rudbecicia hirta) _ Common ' 1,2,4,6,9,10,13,14,16,17,22,25,26-all G, 15-not G Most forbs arc only available as common grower. If the area of adaptaiion has not Materials Program or University Agricultural more than one plant hardiness zone north seed. Common seed is been proven by an independent usually collected from an area close to the seed organization such as the USDA, NRCS Plant Experiment Stations, common seed should not be assumed to be adapted or south of the seed jrower. . Vendor List on Reverse Side 9E5—d Z10/010 d PE6-1 6ZZ95126I6 sueol puy slueJ! uoilonJlsu00.110ad AVIS:01 500Z-01—E0 WARM SEASON GRASS ESTABLISHMENT A1® UMNAGEMENT XX TBE WORT CAROLINA AND WERGX hIA (Revised on April 28, 2003 by Robert Glennon, UBFRS, Edenton, North Carolina) BENEFITS - provide summer forage for livestock and wildlife (200-400 animal unit days, or 3-5 tons of hay per acre) -provide forage, seed, and cover for wildlife at a different time of the year than cool season grasses do - survive with less moisture and fertility than cool season grasses -tolerate more acidity (lower pH) than cool season grasses Species and Cu.ltivar Selection (Select to match local Plant Hardiness Zones - Carolina and Virginia Plant Hardiness Zones (PHZ) 6a to 8a West to East) Species Switchgras s Big Bluestem Indiangrass Little Bluestein Eastern Gamagrass Coastal eanicgrass'Atlantic' Deertongue 'Tioga' Cultivar State PHZ Depth of of of Origin Origin Seeding 'Alamo' TX 'Kanlow' OK 'Carthage' NC 'Blackwell' OK 'Shelter' WV 'Cave--in--Rock' IL 'Earl' TX 'Kaw' KS 'Roundtree IA 'Lometa' TX 'Cheyenne' OK 'Osage' KS ' Rums ey IL 'Aldous' OK 'Cimarron' OK 'Pete' KS 'Iuka' OK VA PA 9a 7a lb 6b 6a 5b 7a 5b 5a 7b 6b 6b 6a 5b 6a 6a 7a 8a 6a North Single Mix Mix Species Seeding Seeding Seeding Rate Rate Rate With With With 7-8" 28-32" 7-8" Drill Drill Drill Spacing Spacing (#PLS/AC) 1/8-1/4" 6-8 2 1/2 1/4-1/2" 8-12 1/4-1/2" 8-12 1/4-1/2' 8-12 3/4-1" 16-20 1/2-1' 15-20 1/2-3/4' 15-20 4 1 4 1 Time of Establishment - Fresh seed of most species must be sown after December L and before the date of the last killing frost (April 15 in western Virginia and North Carolina [Winchester, VA to Mount Airy, NC to Henderson, NC and west], April 1 for central Virginia and North Carolina [Winchester, VA to Mount Airy, NC to Henderson, NC to Norfolk, VA to Gatesville, NC to Wilmington, NC) to March 15 for eastern Virginia and North Carolina [Norfolk, VA to Gatesville, NC to Wilmington, NC and east)) to insure the cold, moist seed treatment (stratification) necessary for optimum germination and the earliest possible germination for drought survival. Seed of eastern gamagrass must be sown in November to get stratification or artificially stratified by the grower/seller for an extended period of time and sown just after the date of last frost. Seed of coastal panicgrass does not require stratification, but must be sown before May 1 to germinate early enough to survive summer drought. - Seed more than 2 years old has less seed dormancy and may germinate adequately until June 1, but will still be susceptible to summer droughts 9E9-d Z10/110 d 1/6-1 6ZZ9S11616 sun, puy slum uo i l vu l su03-rQad RV I S:01 900Z-01-£0 SEEDING RATE RATIONALE Drilled Restoration Seeding Rates (like Conservation Reserve Program) Are Set at 50 Seeds per Square Foot (2,178,000 Seeds Per Acre) Drilled Forage and Erosion Control Seeding Rates (e.g., Pastures, Filter Strips) Are Set a's B"iigh as 100 Seeds per Square Foot (4,356,000 Seeds Per Acre) Due to Variable Germination and Purity, All Seed Specified, Bought, and Sold by the Pounds ofPure Live Seed (PLS) Pounds of Pure live Seed (PLS) = Pounds of Bulk Seed/ Germination (as a Decimal X Purity (as a Decimal) • Example, if you want to sow 10 pounds of PLS per acre that is 50% pure and has 50% germination, you need 10/ .5 X .5 = 10/.25 = 40 pounds of bulk seed per acre Common Native Warm Season Grass Seed Counts per Pound Species Seeds per Pound PLS Seeds per 2 Pounds PIS Example Seed Mix 1 (#PLS/AC) Seeds/Accre in Sample Mix 1 Example Seed Mit 2 (#PLS/AC) Seeds/Acre in Sample Mix. 2 Switchgrass' 389,000 778,000 1 389,000 ; Indiangrass 175,000 350,000 2 350,000 3 525,000 Big Bluestem 165,000 330,000 2 330,000 3 495,000 Little Bluestem 260,000 520,000 2 520,000 2 5201000 Coastal Panicgrass* , 300,000 600,000 , Eastern Gramagrass' 7,500 152000 , Total for Mix , 7 1,589,000 _ 8 _ 1,540,000 *Not Tolerant of Plateau Herbicide, Example Seed Mix 2 Tolerant of Plateau Inexpensive (<S30/Pound of PLS) Ford Seed Countsyer Pound Species • Seeds per PLS Pound Pound of PLS Seed/Acre to Get 500,000 Seeds/Acre and Make Total Mix of < 2,173,000 Seeds/Acre Tickseed Sunflower (Annual) 125,000 4.0, Use 1 Pound Partridge Pea (Annual) 65,000 _ 7.7, Use 1 Pound Lanceleaf Coreopsis (Perennial) 221,000 • 2.3, Use 1 Pound Plains Coreopsis (Annual) 1,400,000 0.3 = 5 ounces Illinois Bundleflower (Perennial) 85,000 _ 5.9, Use 1 Pound Blackeyed Susan (Annual) 1,710,000 0.3 = 5 ounces _ Evening Primrose (Annual) 1,500,000 _ 0.3 = 5 ounces Maxinnillian Sunflower (Perennial) 225,000 2.2, Use 1 Pound Indian Blanket (Annual) 153,000 , 3.3, Use 1 Pound Tolerance to Plateau Varies by Species and Whether Applied Pre -emergence or Post -emergence 9£9-A Zl0/Zl0 d tE0-1 6ZZ9911816 sueoi puy men uoimilsu00.4 .J AVIS:01 5O Z-01-E0 03-10-2005 10:51AM FROM -Construction Grants And Loans 9197156229 T-934 P 001/003 F-537 BSTABiIZAMEBT -no-till grilling best in herbicide -killed cool season sod to minimize weeds -conventional tillage okay into firm seedbed following cropland without weeds - conventional tillage may facilitate the warning and drying of poorly drained soils to facilitate germination and minimize seed diseases -Roundup or Paraquat herbicide may be used for weed control before seeding -Plateau herbicide may be used for pre -emergence or post -emergence weed control on all species except switchgrass or eastern gamagrass -cultipacking after seeding imperative -adjust pH to 5.5-6.5 for best survival and growth -fertilize to moderate levels of phosphorus and potassium (as for 100 bushel corn) -apply no,nitrogen until the stand is established and above weeds- late summer of establishment year or June of the year following establishment 20-40 pounds per acre for half season, 40-80 pounds per acre for whole season MANAGEMENT -maintain moderate levels of phosphorus and potassium (as -maintain!pH of 5.5-6.5 for best survival and growth -fertilize with 40-80 (40 for wildlife and reclamation, 8 nitrogen:per acre split in two applications: as growth b - graze at!8-12 inches down to 4-6 inches - do not lower grazing height during the year -burn stands not grazed or mowed every third year - control Oroadleaf weeds with 2,4-D and dicaxpba - control cool season grasses with roundup, paraquat, or or eastefn gamagrass) in the spring or fall when the warm season grasses are dormant,,or.with severe grazing until April 1 -control annual weeds by clipping tops after flowering and before seed production SOURCES or SD'»PLY - Sharp Brothers Seed Rt.4, Bob 237A Clinton,. MO 64735 816-885-7551 - Stock Seed Farms RR 1, Box 112 Murdock,. NE 68047 402-867-3771 - Ernst Conservation Seeds RD 5, Box 806 Meadville, PA 16335 814-425-7276 -Shephargs Farm Route 1,, Box 3 Clifton ;Hall, MO 65244 816-261-4567 - Turner need Company Highway!183 South Breckenridge, TX 76424 254-55912065 -Bamert Seed Company Route 3,i Box 1120 Muleshoe, TX 79347 806-27245506 for 100 bushel corn) 0 for forage) pounds of egins and mid -summer plateau (not on switchgrass Co. `Alamo', `Cave -in -Rock', 'Blackwell', `Earl', `Roundtree' Big Bluestem `Ramsey' Indiangrass `Aldous', `Cimarron' Little Bluestem Common Eastern Gamagrass `Cave -inn -Rock', 'Blackwell' Switchgrass `Roundtree' Big Bluestem `Rumsey' Indiangrass `Aldous', `Cimarron' Little Bluestem `Pete' Eastern Gamagrass `Carthage', `Cave -in -Rock', 'Blackwell', `Shelter' `Niagara', `Roundtree' Big Bluestem `Rwnsey' Indiangrass `Aldous', `Cimarron' Little Bluestem Common Eastern Gamagrass `Tioga' Deertongue `Atlantic' Coastal Panicgrass 'Pete' Eastern Gamagrass `Alamo', `Blackwell' Switchgrass `Kaw' Big Bluestem `Cheyenne', `Lameta' Indiangrass `Alamo', `Blackwell', Cave -in --Rock' Switchgrass `Earl', `Kaw', `Roundtree' Big Bluestem `Cheyenne', `Osage', `Ramsey', `Lometa' Indiangras `Aldous', `Pastura' Little Bluestem `Shelter' Switchgrass E 0 I 0 U co Posl it' Fax Note r 0 03-10-2005 10:51AM FROM -Construction Grants And Loans • 9197156229 T-934 P 002/003 F-537 1.Sharp Brothers Seed Co. 396 S.W Davis Street Clinton, MO 64735 816-885-7551 800451-3779 1516-885-8647 FAX cmail:sharpbros isprintrnaiLoom www.sharpseed.cot n 4. Ernst Conservatiop Seeds 9006 Mercer Px7cc: Meadville, PA 16335 814-336-2404 800-873-3321 814-336-5191 FAX ernstsales@ernstseed.00m ww.anstseed.coi* 7, Douglass King Seed Co. P. O. Box 200320. San Antonio, TX 78220-0320 512-661-4191 ' 512-661-8972 FAX www.dkseeds.com 10. Grassland West Co. P.O. Box 1604 • Greely, CO 80632 800-782-5947 970-356-7002 970-356-7263 FAX 13. Osenbaugh Seedif 16. Granite Seed , 1697 West 2100 North Lehi, UT 84043 801 768-4422 801-531-1456 , 801-768-3967 FAX 19. Sims Brothers Route 2, Box 73 Union Springs, AL 334-738-2619 22. Mark Seed Co. P.O. Box 67 Perry,1A50223 515-465-2122 , www.miarkseed.com Sources of Seeds of Forbs (Wildflowers) for the Southeastern Compiled by Robert Glennon, U.S. Fish and Wildlife Service, 2. Stock Send Farms 28008 Mill Road Murdock, NE 68401-2350 402-867-3771 800-759-1520 402-867-2442 FAX cmai[:stockseed a lavixnet www.stockcsoedcom 5. Adams Briscoe Seed Co. P.O. Box 19 Jackson, GA 30233-0019 770 77S 7826 770-775-7122 FAX email:abseed@juno.com www.abseed.onm 8. Turner Seed Company Route 1, Box 292 Breckenridge TX 76024 817-559-2065 800-225-4137 11. Casterline Sends P.O. Box 1377 Dodge City, KS 67801 316-225.4137 800-225.4137 14. Applewood Seed Company 5380 Vivan Stint Arvada, CO 80002 303-431-7333 303-431-7981 FAX 17. Wildsced Farms P.O. Box 3000 Fredticksburg, TX 78624-3000 800-348 0078 830-990-8000 FAX www.wildscedfarms.com 20. Steve Payne 105 Church Street Scnatobia, MS 38668 601-562-9405 United States — 07/08/03 Edenton, North Carolina 3. Ranier Seed Co. P.O. Box 1064 Davenport, WA 99122-1064 509-725-1235 800-828-8873 509-725-7015 FAX 6. Hamm Seed Co. Route 3, Box 1120 Muleshoe, TX 79347 806-272-5506 800-262-9892 806-272-3114 FAX .• anail;natives@baraertseed.com www.bamertseed.com 9. Curtis & Curtis Star Route Box 8A Clovis, NM 88I01 505-762-4759 505-763-4213 FAX 12. Melot's 8900 W. Memorial Road Oklahoma City, OK 73142 405-7214394 15.1Cester's Nurseries, Inc_ P.O. Box 516 Omro,Wr 54963 920-685-2927 920-685-6727 FAX www.kestasnursery.com 18. C.P. Daniels P.O. Box 119 Waynesboro, GA 30830 800-822-5681 706-554-4424 FAX www.burke.net/cpdaniel 21. Mile Bradley 650 Jake Link Road Conontown, TN 37048 615-325-2838 25. Hamilton Seeds 16786 Brown Road Elk Creek, MO 65464 417-967-2190 417-967-5934 www. hamiiltonseed.com 23. Lorenz O.K. Seeds 101 North Main Okeeae, OK 73763 580-822-3655 580-822-3630 FAX 26. Native American Seed 127 North 16th Street Juucaon, TX 76849 800-728-4043 800-728-3943 www.scodsouroe.com 24. Grasslander Rt. 1, Box 56 Hanaesscy, OK 73742 405-853-2607 27. Pogue Seed Company P.O. Drawer 389 Ke>nody, TX 78119 830-583-3456 830-583-9843 Species List and Number, of Dealers That Sell the Simla; on Reverse Side 03-10-2005 10:51AM FROM -Construction Grants And Loans 9197156229 T-934 P 003/003 F-537 Sources of Seeds of Native Grasses and Legumes for the Southeastern United States — 08/16/02 Compiled by Robert Glennon, 'U.S. Fish and Wildlife Service, Edenton, North Carolina l.Sbaxp Brothers Seed Co. 396 S.W Davis Suyet Clinton, MO 64735 816-885-7551 800-451-3779 816-885-8647 FAX anaik.sharpbros@isprintmail.com pintmail.com www.sbarpseed.cop'r 4. Ernst Conservatiop Scads 9006Mercer Pike! Meadville, PA 16335 814-336-2404 800-873-3321 814-336-5191 FA/X ernstsales@anstleed.com ww.ernstseed_com 7. Douglass King Sped Co. P. O. Box 200320 San Antonio, TX178220-0320 512-661-4191 888-DK-SEEDS 512-66143972 F,4X sales(a'dkseeds.com www.ceds.00gn 10. Grassland WestjCo. P.O. Box 1604 Grady, CO 80632 800-782-5947 970356-7002 • 970-356-7263 FAX 2. Stack Seed Farms 28008 Mill Road Murdock, NE 68401-2350 402 867-3771 800-759-1520 402-867-2442 FAX email:stockseed@aavix.net www.stockseC .com 5. Adams Briscoe Seed Co. P.O. Box 19 Jackson, GA 30233-0019 770-775-7826 770-775-7122 FAX ernailabseed@luno.com www.abseed.com 8. Turner Seed Company Route 1, Box 292 Breckenridge, TX 76024 817-559-2065 800-225-4137 1 3, Ranier Seal Co, P.O. Box 1064 Davenport, WA 99122-1064 509-725-1235 800-828-$873 509 725 7015 FAX 6. Bamen Seed Co_ Route 3, Box 1120 Muleshoe, TX 79347 806-272-5506 800-262-9892 806-272-3114 FAX emaitnatives@bamertseed.com www.bamertseed.aom 9_ Curtis & Curtis Star Route Box 8A Clovis, NM 88101 505 762-4759 505-763-4213 FAX 11. Casterline Seeds P.O. Box 1377 Dodge City, KS 67801 316-225-4137 800-225-4137 12. Melot's 8900 W. Manurial Road Oklahoma City, OK 73142 405-721-4394 13. Shepherd Farms Route 1, Box 7 Clifton Hall, Mp 65244 816-261-4567 16. Granite Seed ' 1697 West 2100 North Lehi, UT 84043 801-768-4422 801-531-1456 801-768-3967 FAX 19. Sims Brothers Route 2, Box 73 Union Springs; AL 334-738-2619 22. Don Huermann 808 Rue Cbiartes Meta ie;, LA 504-833 24731 25. Hamilton Seed's 16786 Brown Road Elk Creels, M9 65464 417-967-2190 417-967 5934. exoailBamiltoj a@orain.Missouri.oxg www.hamiltonseed.com 14. Moat's Ranch Route 1, Box 79 Iuka„ KS 67066 620-546-2575 620-546-2250 17. Central Garden Supply 2901 West 60' Street Little Rock, AR 72209 501-562-4763 501-562-5718 FAX 20. Steve Payne 105 Church Street Scnatobia, MS 38668 601-562-9405 23. Riverland Agra Farms 221 Foster Road Orangeburg, SC 29114 803-534-4650 26. Native American Seed 127 North le Sul= Juwction, TX 76849 800-728-4043 800-728-3943 arww.seedsouxcs.00m 15. Ga=nagrass Seed Co. Route 1, Box 111A Falls City, NE 68355 402 245-5842 402-245-4639 18. C.P. Daniels P.O. Box 119 Waynesboro, GA 30830 8004322 5681 706-554-4424 FAX www.burke.nct/cpdaniel 21. Mike Bradley 650 Jake Link Road • Cottontown, TN 37048 615-325-2838 24. Sunaoast Native Plants P.O. Box 248 Palmetto. FL 33561 813-729- 5035 27. Pogue Seed Company P.O_ Drawer 389 Kenedy, TX 78119 830-583-3456 830-583-9843 email:pokuG c d(cbpogue eed.com pogueseed.cvm Species List and Numbers of Dealer That Sell the Species on Reverse Side Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources November 3, 2004 Mr. Andrew Bartlett Chief, East Standards, Monitoring and TMDL Section USEPA Region 4 61 Forsyth Street, S.W. Atlanta, GA 30303-8960 Subject: Site Specific Criteria for Copper and Zinc Mr. Bartlett: Alan W. Klimek, P.E., Director�z .it'o3r:.a:.y.,e.. • •g• n of-ir�f' Uyik- .;,;1 i�'�!� .yam..............._._......... NOV 1 0 2004 NOV 1 0 2004 DENR - WATER QUALITY POINT SOURCE BRANCH • `7s-e•:a.v.....r+...-+rwn..harra.a►a+n.w�www The Union County Public Works Department has requested the State of North Carolina to review its updated proposal dated October 26, 2004 (enclosed) for site -specific criteria for Copper and Zinc at its Twelve Mile Creek WWTP (NPDES permit NC0085359). The original "Final Report, Site -Specific Metals Development" dated August 2003 was forwarded to both the US EPA Region IV and The State of South Carolina for comment. `At the core of this issue is our firm desire to address both the needs of our state as well as the needs of the State of South Carolina. The NC NPDES unit issued a discharge limit for Total Recoverable Copper of 3.8 and a discharge limit for Total Recoverable Zinc of 37 ug/L. These discharge limits were based on the South Carolina standards, as the effluent is conveyed by Twelve Mile Creek into South Carolina. The County elected to follow the "Recalculation Procedure" as a means of obtaining some relief from the proposed NC effluent limit. The results of that recalculation were presented in the August 2003 report. On July 26, 2004, The State of North Carolina submitted to Union County (Mr. Jon C. Dyer) a request for additional information and clarification, before making our final decision on the approval/disapproval of the site -specific study (enclosed, dated July 26, 2004). The relief sought in the NPDES permit limit centers on the deletion of Cladocerans (Ceriodaphnia dubia, Ceriodaphnia reticulata, Daphnia magna, Daphnia pulex, Daphnia pulicaria) from the National Dataset. The State of North Carolina contends that the stretch of stream in question does indeed have the proper habitat characteristics to support these species. While much of the stream does appear to be free flowing, observations during a site visit by an NC DWQ staff member indicated there were areas where water pools and remains stagnant and are capable of supporting these species. Pictures from the site visit are enclosed and were presented to the affected parties at a meeting held in Raleigh on September 30, 2004. The professionals representing Union County indicated that during their initial review of the site, the water body did not appear to have any areas of pooling and the decision to delete Cladocerans from the National Dataset was based on that visit. They concurred that the photographs, taken in October 2003, showed significantly different stream flow conditions than those encountered during their visit in April 2003. The State of North Carolina is facing additional requests for site -specific criteria. In accordance with the Clean Water Act, we feel it our obligation to carefully review all aspects of the request and be able to JVatN r Cural4'aro Ana North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-2496 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50°% Recycled/10% Post Consumer Paper Mr. Andrew Bartlett Page 2 November 2, 2004 defend our position for each and every water body. We respectfully request that EPA Region IV staff review the recalculation dataset and provide us with their professional opinion as to the acceptability of the deletion of Cladocerans. Sincerely, Dave Goodri i, Supervisor Point Source Branch North Carolina Division of Water Quality Enclosures cc: Lisa Perras-Gordon, EPA Region IV Marshall Hyatt, EPA Region IV Gina Kirkland, SC Bureau of Water Mike Montebello, SC Bureau of Water Vernon Beaty, SC Bureau of Water Jon C. Dyer, Union County James N. Struve, Hazen And Sawyer Jeff Manning, Classifications and Standards Unit Matt Matthews, Aquatic Toxicology Unit - Susan Wilson, Western NPDES Program Unit Union County Twelve Mile Creek WWTP - Site Specific Metals Dev... Oct. 26, 2004 SUBMITTAL Subject: Union County Twelve Mile Creek WWTP - Site Specific Metals Development From: "Struve, James N." <jstruve@hazenandsawyer.com> Date: Tue, 26 Oct 2004 17:03:37 -0400 To: <Jeff.Manning@ncmail.net>, <Matt.Matthews@ncmail.net> CC: <mtye@co.union.nc.us>, <JonDyer@Co.Union.NC.US>, <1shealy@shealylab.com>, 4shealy6@sc.rr.com>, "Fergen, Robert E." <rfergen@hazenandsawyer.com>, <gsatcher®shealylab.com> Jeff, As we discussed this morning, Union County/Hazen and Sawyer met with the Division of Water Quality on September 30, 2004 to discuss the above referenced site specific metals development at the Union County, NC Twelve Mile Creek WWTP. Those in attendance included Susan Wilson, Jackie Nowell, Matt Matthews,Connie Brower and Dawn Jeffries of DWQ; Jon Dyer and Mark Tye of Union County; Laura Shealy of Shealy Environmental; and, Bob Fergen and myself of Hazen and Sawyer. The study was initiated as a result of new metal limits for copper (3.8 ug/L) and zinc (37 ug/L) in Union County's renewed NPDES permit. A recalculation procedure was performed as an initial step to provide relief from the metals in question. The procedure recalculated the copper and zinc site specific limits to be 13.22 ug/L and 258.9 ug/L, respectively. However, a review of the calculations revealed an error such that the revised copper and zinc limit was actually 7.85 ug/L and 223.8 ug/L, respectively (please refer to attachment entitled "Attachment No 1.doc"). The recalculation procedure was based on the deletion of Daphnids from the most sensitive species data set based upon our assessment and observation that Daphnids would not exist in a free flowing stream such as that portion of Twelve Mile Creek in which the plant's outfall is located. The deletion of Daphnids from the most sensitive species data set was also posed to Mr. Vernon Beatty of SC DHEC (please refer to attachment entitled "Attachment No 2..doc). Mr. Beatty's response is included for your information (please refer to attachment entitled "Attachment No 3.pdf). The site specific metals development report was submitted to DWQ on August 28, 2003. Review comments were received on July 26, 2004 (please refer to attachment entitled "Attachment No 4.pdf"). The meeting with DWQ was scheduled to present our responses to DWQ's review comments in person and in written form. The attachment entitled "Attachment No 5.doc" includes our initial responses to DWQ's review comments. The last attachment entitled "Attachment No 6.doc" is supplemental information based on our September 30, 2004 meeting with DWQ. I understand that this is a lot of information to digest at one sitting, especially since Connie Brower is no longer involved with this project. However, I know that Matt is still involved and has a great understanding of the details of this project. Please do not hesitate to call me at (704) 357-3150 or email me at istruveahazenandsawver.com should you require additional information or clarification. We look forward to your assistance in obtaining approval of this report, and ultimately, in resolving the site specific metal limits that will both safeguard the environment and cause no undue hardship on Union County. 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 jstruvec hazenandsawver.com •AIA MAA• -/ Al Attachment No 1.doc SECTION 4.0 RESULTS 4.1 Recalculation of the Zinc Water Quality Criteria 4.1.1 The Deletion Process For Zinc Table 4-1 provides the results from the deletion process for zinc. The far right column denotes the code, which represents the reason for retaining or deleting a specie. A key to the code is provided below. Highlighted rows represent circled species that are resident to the site. All species mean acute values (SMAV) are given at a hardness of 50 mg/L. Key to the Code for the Deletion Process S=The species exists at the site. G=The genus exists at the site. F=The family exists at the site. 0=The order exists at the site. C=The class exists at the site. D=Deleted TABLE 4-1: THE DELETION PROCESS FOR THE ZINC ACUTE NATIONAL DATA SET Species . } : Family Order Class Phylum : SMAV (ugh) Code Lumbriculus variegatus Lumbriculidae Lumbriculida Oligochaeta Annelida 9712 F Limnodrilus hoffineisteri . Tubiflcidae ,;; :.. , ': Haplotaxida .....< . : Oligochaeta =: ; ' 2Annelida >1264' . ; S' Naffs sp. Naididae : ' Haplotaxida Oligochaeta Armada ::.18400 , ' S Amnicola sp. Amnicolidae Mesogastropoda _ Gastropoda Mollusca 16820 0 Helisoma campanulatum Planorbidae Mesogastropoda Gastropoda Mollusca 1578 G Physa heterostropha Physidae Limnophilia Gastropoda Mollusca 1088 F Physa gyrina Physidae Limnophilia Gastropoda Mollusca 1683 F Corblcula fluminea ; Corbiculidae = Veneroida ` ` Bivalvia ' ; ; - Mollusca 4900 . - S Ceriodaphnia dubia Daphnidae Cladocera Crustacea Arthropoda 174.1 D Cerlodaphnia reticulata Daphnidae Cladocera Crustacea Arthropoda 50.70 D Daphnia magna Daphnidae Cladocera Crustacea Arthropoda 355.5 D Daphnia pulex Daphnidae Cladocera Crustacea Arthropoda 252.9 D Asellus blcrenata Asellidae Isopoda Crustacea Arthropoda 5731 G Asellus communis Asollidae Isopoda Crustacea Arthropoda 11610 G Lirceus alabamae Asellidae Isopoda Crustacea Arthropoda 3265 G Crangonyx pseudogracillis Asellidae Isopoda Crustacea Arthropoda 19800 G Gammarus sp. Gammaridae Amphipoda Crustacea Arthropoda 8100 S Argla sp. Coenargridae Odonata Insecta Arthropoda 88960 S Pectinate&a magniflca Pectinatelcidae Cheilostoma Phylactolaemata Ecto . rocta 1307 S Lophopodella carter/ Lophopodidae Cheilostoma Phylactolaemata Ectoprocta 1707 D Plumatella emarginata Plumatellidae Cheilostoma Phylactolaemata Ectoprocta 1607 S TABLE 4-1: THE DELETION PROCESS FOR THE ZINC ACUTE NATIONAL DATA SET Species Family Order Class Phylum SMAV (ugll) Code Xenopus lavis Pipidae Anura Amphibia Chordata 19176 _ 0 Anguilla rostrata Anguillidae Anguilliformes Osteichthyes Chordata 13630 D Oncorhynchus kisutch Salmonidae Salmoniformes Osteichthyes Chordata 1628 0 Oncorhynchus nerka Salmonidae Salmoniformes Osteichthyes Chordata 1502 0 Oncorhynchus tshawytsha Salmonidae Salmoniformes Osteichthyes Chordata 446.4 0 Salmo gairdneri Salmonidae Salmoniformes Osteichthyes Chordata 689.3 0 Salmo salar Salmonidae Salmoniformes Osteichthyes Chordata 2176 0 Salvelinus font/nails Salmonidae Salmoniformes Osteichthyes Chordata 2100 0 Agosia chrysogaster Cyprinidae Cypriniformes Osteichthyes Chordata 227.8 F Carassius auratus Cyprinidae Cypriniformes Osteichthyes Chordata 10250 S Cyprinus carplo, Cyprinidae , Cypriniformes Osteichthyes Chordata 7233 S Notemigonus crysoleucas Cyprinidae ' Cypriniformes : ; Osteichthyes Chordata 6000 S Plmephales promelas Cyprinidae Cypriniformes Osteichthyes Chordata 3830 F Ptychochellus oregonensis Cyprinidae Cypriniformes Osteichthyes Chordata 6580 F Catostomus commersoni Catostomidae Cypriniformes Osteichthyes Chordata 5228 S Fundulus diaphanous Cyprinidontidae Atheriniformes Osteichthyes Chordata 17940 0 Jordanella florldae Cyprinidontidae Atheriniformes Osteichthyes Chordata 1672 0 Poecillia reticulate Poeciliidae Atheriniformes Osteichthyes Chordata 6053 F Xiphophorus maculatus Poeciliidae Atheriniformes Osteichthyes Chordata 4341 F Morone americana Percichthyidae Perciformes Osteichthyes Chordata — D Morone saxatilis Percichthyidae Perciformes Osteichthyes Chordata 119.4 D Lepomisgibbosus Centrarchidae Perciformes Osteichthyes Chordata 18790 S Lepomis macrochlrus Centrarchidae` Perciformes Osteichthyes Chordata 5937 S Tilapia mossambica Cichlidae Perciformes Osteichthyes Chordata 790.0 D Acute Data Set Requirements Requirement 1 - Carassius auratus (Class Osteichthyes) Requirement 2 - Lepomis macrochirus (Bluegill, recreationally important species) Requirement 3 - Fundulus diaphanus (Family Cyprinidontidae; third family of Phylum Chordata) Requirement 4 - Asellus bicrenata (crustacean) Requirement 5 - Crangonyx pseudogracillls (crustacean) Requirement 6 - Argia sp. (an insect) Requirement 7 - Nais sp. (Annelida - a phylum other than chordata or Anthropoda) Requirement 8 - Helisoma campanulatum (Mesogastopoda - an order not already represented) 4.1.2 Determination of Four Most Sensitive Species for Zinc The deletion of the striped bass, Morone saxitilis, was a primary reason for the change in the four most sensitive species. This fish inhabits coastal waters and are commonly found in bays but may enter rivers in the spring to spawn. Although this species does exist in North and South Carolina, it is not possible for it to travel up to the Twelve Mile Creek due to the presence of several intervening dams. Furthermore, the SC Wildlife and Marine Resources has never collected this species outside of coastal counties. The other main reason for the change in the four most sensitive species was the deletion of the Daphnids. Daphnids are not going to exist in free -flowing streams and, therefore, were deleted from the data set. Once the deletion process was completed and the minimum data requirements verified, the final acute value (FAV) and final chronic value (FCV) were calculated. The four most sensitive species from EPA's Original Data Set were the following: #1 Ceriodaphnia (reticulate and dubia) GMAV = 93.95 ug/I #2 Morone saxatilis SMAV = 119.4 ug/I #3 Agosia chrysogaster SMAV = 227.8 #4 Daphnia (magna and pulex) GMAV = 299.8 ug/I After the deletion process was applied the four most sensitive species became the following: #1 Agosia chrysogaster SMAV = 227.8 ug/1 #2 Oncorhynchus (nerka, kisutch and tshawytsha) = GMAV=1030 ug/l #3 Salmo (gairdneri and salar) GMAV=1224 ug/I #4 Pectinatella magnifica SMAV=1307 ug/I 4.1.3. Calculation of FAV and FCV for Zinc The Calculations used to obtain the Site -Specific Final Acute Value and Criterion Maximum Concentration For Zinc are as follows from EPA-822-B-94-001: S2 = E [(In GMAV)2] - [(E (In GMAV))2 /4] E (P) - [((E(IP))2] /4 L = [(E(In; GMAV) - S (E(IP))] /4 A = S(4.05) + L FAV = eA Table 4.2 ZINC RANKING TABLE RANK MAV InMAV (InMAV)2 P=R/N+1 'IP 4 1307 7.175 51.48 0.1290 0.3592 3 1224 7.110 50.55 0.0968 0.3111 2 1030 6.937 48.13 0.0645 0.2540 1 227.8 5.428 29.46 0.0323 0.1797 SUM 26.65 179.6 0.3226 1.104 N = 30 (the number of total GMAV's in the data set) Sz = 179.6-26.652/4 = 113.6 0.3226-1.1042/4 S = 10.66 L = [26.65-(10.66)(1.104)]/4 = 3.720 A = (10.66)(I0.05) + 3.720 = 6.104 FAV = e(6.104) = 447.6 The CMC is calculated by obtaining the FAV and dividing it by two. RECALCULATED CRITERION MAXIMUM CONCENTRATION = 223.8 ug/I Zinc (at hardness of 50 mg/L) The CCC is calculated by dividing the FAV by the final acute -chronic ratio (ACR). The ACR for zinc is 2.0 (EPA-820-B-96-001). RECALCULATED CRITERIA CONTINUOUS CALCULATION = 223.8 ug/I Zinc (at hardness of 50 mg/L) 4.2 Recalculation of the Copper Water Quality Criteria 4.2.1 The Deletion Process For Copper Table 4-3 provides the results from the deletion process for copper. The far right column denotes the code which represents the reason for retaining or deleting a specie. A key to the code is provided below. Highlighted rows represent circled species that are resident to the site. All species mean acute values (SMAV) are given at a hardness of 50 mg/L. Key to the Code for the Deletion Process S=The species exists at the site. G=The genus exists at the site. F=The family exists at the site. O=The order exists at the site. C=The class exists at the site. D=Deleted TABLE 4-3: THE DELETION PROCESS FOR THE COPPER ACUTE NATIONAL DATA SET Species Family Order ; Class Phylum SMAV (ug/I) Code Lumbriculus variegatus Lumbriculidae Lumbriculida Oligochaeta Annelida 242.7 F Limnodrilus hoffineisteri Tubificidae Haplotaxida Oligochaeta Annelida 53.08 S Naffs sp. Naididae `Haplotaxida • Oligochaeta Annelida 90.00 S Campeloma decisum Viviparidae Mesogastropoda Gastropoda Mollusca 1877 G Amnicola sp. Amnicolidae Mesogastropoda Gastropoda Mollusca 900.0 0 Gonlobasis livescens Pleuroceridae Mesogastropoda Gastropoda Mollusca 166.2 F Gyraulus circumstriatus Planorbidae Mesogastropoda Gastropoda Mollusca 56.21 F Physa heterostropha Physidae Limnophilia Gastropoda Mollusca 35.91 F Physa Integra Physidae Limnophilia Gastropoda Mollusca 43.07 F Corblcula manilensis Corbiculidae Veneroida Bivalvia Mollusca >7184 D Ceriodaphnia reticulata Daphnidae Cladocera Crustacea Arthropoda 18.77 D Daphnia magna Daphnidae Cladocera Crustacea Arthropoda 21.17 D Daphnia pulex Daphnidae Cladocera Crustacea Arthropoda. 25.42 D Daphnia pulicaria Daphnidae Cladocera Crustacea Arthropoda 9.263 D Gammarus pseudolimnaeus Gammaridae Amphipoda Crustacea Arthropoda 22.09 G Orconectes rusticus Astacidae Decapoda Crustacea Arthropoda 1397 F Procambarus clarkil Astacidae Decapoda Crustacea Arthropoda 1900 S Crangonyx pseudograacllls Crangonidae Decapoda Crustacea Arthropoda 1290 S Damselfly Odonata Insects Arthropoda _ 4600 S Acroneuria lycorias Perlidae Plecoptera lnsecta Arthropoda 10240 S Caddisfly -- Tricoptera Insecta Arthropoda 6200 S Chlronomus decorus Chironomidae Diptera Insecta Arthropoda 834 G Chlronomus tetans Chironomidae Diptera Insecta Arthropoda 197.2 G Chlronomus sp. Chironomidae Diptera lnsecta Arthropoda 30.00 S TABLE 4-3: THE DELETION PROCESS FOR THE COPPER ACUTE NATIONAL DATA SET Species Family Order Class Phylum SMAV (ugll) Code Pectinatella magnifica Pectinatelcidae Cheilostoma Phylactolaemata Ectoprocta 135.0 S Lophopodella carters Lophopodidae Cheilostoma Phylactolaemata Ectoprocta 37.05 D Plumatella emarginata Plumatellidae Cheilostoma Phylactolaemata Ectoprocta 37.05 S Anguilla rostrata Anguillidae Anguilliformes Osteichthyes Chordata 4305 D Oncorhynchus kisutch Salmonidae Salmoniformes Osteichthyes Chordata 70.25 0 Oncorhynchus nerka Salmonidae Salmoniformes Osteichthyes Chordata 233.8 0 Oncorhynchus tshawytsha Salmonidae Salmoniformes Osteichthyes Chordata 42.26 0 Oncorhynchus clarkl Salmonidae Salmoniformes Osteichthyes Chordata 66.26 0 Salmo gairdneri Salmonidae Salmoniformes Osteichthyes Chordata 42.50 0 Salmo salar Salmonidae Salmoniformes Osteichthyes Chordata 196.6 0 Salvelinus fontinalis Salmonidae Salmoniformes Osteichthyes Chordata 110.4 0 Acrochellus alutaceus Cyprinidae ► Cypriniformes Osteichthyes Chordata 133.0 F Campostoma anomalum Cyprinidae Cypriniformes Osteichthyes Chordata 78.55 F Carassius auratus .. Cyprinidae : Cypriniformes, ` :Osteichthyes : Chordata 157.1 S Cyprinus carpio Cyprinidae Cypriniformes Osteichthyes Chordata , 156.8 S :. Notropis crysocephalus Cyprinidae " Cypriniformes: :r ..:Osteichthyes: -.. Chordata ::: 331.8 S Pimephales notatus Cyprinidae Cypriniformes Osteichthyes Chordata 72.16 F Pimephales promelas Cyprinidae Cypriniformes Osteichthyes Chordata 115.5 F Ptychocheilus oregonensis Cyprinidae Cypriniformes Osteichthyes Chordata 16.74 F Rhinichthys atratulus Cyprinidae _ Cypriniformes = Osteichthyes Chordata 86.67 F Semotilus atromaculatus Cyprinidae Cypriniformes; ..: ,,:;; :.Osteichthyes . :. Chordata 83.97 S Ictalurus nebulosus ." Ictaluridae- . Siluriformes `. `, `;Osteichthyes"' > . ' 'Chordata `: 69.81 S Fundulus diaphanous Cyprinidontidae Atheriniformes Osteichthyes Chordata 790.6 D Gambusia affinis Poeciliidae . Atheriniformes , ..; _:,-:Osteichthyes :: Chordata 196.1 : S Poecillia reticulata Poeciliidae Atheriniformes Osteichthyes Chordata 124.6 D Morone americana Percichthyidae Perciformes Osteichthyes Chordata 5860 D Morone saxatilis Percichthyidae Perciformes Osteichthyes Chordata — D Lepomis gibbosus Centrarchidae, Perciformes ':`; . Osteichthyes'' Chordata . 640.9 S Lepomis macrochirus Centrarchidae ; Perciformes - Osteichthyes . Chordata ` 1017 S Etheostoma caeruleum Percidae Perciformes Osteichthyes Chordata 86.67 G Etheostoma spectablle Percidae Perciformes Osteichthyes Chordata 230.2 G Tilapia mossambsca Cichlidae Perciformes Osteichthyes Chordata 684.3 D Acute Data Set Requirements Requirement 1 - Gambusia affinis(Class Osteichthyes) Requirement 2 - Lepomis macrochirus (Bluegill, recreationally important species) Requirement 3 — Etheostoma caeruleum (Family Percidae; Phylum Chordata) Requirement 4 — Oronectes rusticus (crustacean) Requirement 5 - Gammarus pseudolimnaeus (crustacean) Requirement 6 - Acroneuria lycorias (an insect) Requirement 7 - Nais sp. (Annelida - a phylum other than chordata or Anthropoda) Requirement 8 — Campeloma decisum (Mesogastopoda - an order not already represented) 4.2.2 Determination of Four Most Sensitive Species for Copper The deletion of the Daphnids was a primary reason for the change in the four most sensitive species for copper. Daphnids are not going to exist in free -flowing streams and, therefore, were deleted from the data set. Once the deletion process was completed and the minimum data requirements verified, the final acute value (FAV) and final chronic value (FCV) were calculated. The four most sensitive species from EPA's Original Data Set were the following: #1 Ptychocheilus oregonensls SMAV = 16.74 ug/I #2 Daphnia (magna, pulex and pulicaria) GMAV = 17.08 ug/I #3 Ceriodaphnia reticulata► SMAV = 18.77 ugll #4 Gammarus pseudolimnaeus SMAV = 22.09 ug/I After the deletion process was applied the four most sensitive species became the following: #1 Ptychocheilus oregonensis SMAV = 16.74 ug/I #2 Gammarus pseudolimnaeus SMAV = 22.09 ug/I #3 Plumatella emarginata SMAV = 37.05 ug/I #4 Physa (heterostropha and integra) GMAV=39.33 ug/I 4.2.3. Calculation of FAV and FCV for Copper The Calculations used to obtain the Site -Specific Final Acute Value and Criterion Maximum Concentration For Copper are as follows from EPA-822-B-94-001: S2 = E [(In GMAV)2] - [(E (In GMAV))2 /4] E (P) - [((E(IP))2] /4 L = [(E(In GMAV) - S (E(JP))] /4 A = S(4.05) + L FAV = eA Table 4-4 COPPER RANKING TABLE MAV 39.33 37.05 22.09 16.74 N = 34 (the number of total GMAV's in the data set) S2 = 44.05-13.202/4 = 0.4900 = 31.01 0.2857-1.0392/4 0.0158 S = 5.569 L = [13.20-(5.569)(1.039)]/4 = 1.853 A = (5.569)(/0.05) + 1.853 = 3.098 FAV = e(3.098) = 22.16 The CMC is calculated by obtaining the FAV and dividing it by two. iJp 0.3381 0.2927 0.2390 0.1690 RECALCULATED CRITERION MAXIMUM CONCENTRATION = 11.08 ug/I Copper (at hardness of 50 mg/L) The CCC is calculated by dividing the FAV by the final acute -chronic ratio (ACR). The ACR for copper is 2.823 (EPA-820-B-9.6-001). RECALCULATED CRITERIA CONTINUOUS CALCULATION = 7.850 ug/I Copper (at hardness of 50 mg/L) 4.3 Hardness Adjustments For this site, the mixed stream (effluent and receiving waters) hardness was determined to be 59 mglL so it was necessary to adjust the recalculated criteria for hardness (the EPA SMAV data are adjusted to a hardness of 50 mg/L). The limiting hardness was determined to be approximately 59 mg/L by using the following information: • Low flow data from a nearby USGS gauging station of Twelve Mile Creek in Waxhaw, NC was obtained. The State of North Carolina has determined the appropriate 7Q1O for permitting purposed to be 0 cfs. Using these data it was determined that an appropriate mixed stream concentration under design flow conditions was 100 percent effluent. Therefore, the upstream flow and analytical data are not necessary for the determination of the site -specific criteria. It is important to recognize additional background flow above 0 cfs will provide additional dilution and hence there is a significant safety factor associated with this approach. • Hardness data for 20 effluent samples collected during April and May 2003 indicated an average effluent hardness of 59 mg/L (see Table 2-1). Maximum and minimum concentrations were 80 and 50 mg/L, respectively. All 20 effluent samples for copper were below the detection limit of 2 pug/L. The effluent zinc concentration averaged 32.55 pg/L with a maximum value of 57 pg/L and a minimum value of 24 erg/L. • With an average effluent hardness of 59 mg/L, under design flow conditions including a background 7Q1O flow rate of 0 cfs, the appropriate hardness for limit development is 59 mg/L. The calculation used for hardness adjustment are provided in Appendix B of EPA-822-R-01-005, and is the following: SMAVat site hardness = SMAVat hardness50 C slope Site Hardness 50 mg/L J From the 1995 Water Quality Criteria Documents manual, the zinc CCC and CMC limits are related to hardness using the slope of 0.8473. At a hardness of 59 mg/L, the appropriate site -specific criterion for total recoverable zinc is 257.5 dug/L. From the 1995 Water Quality Criteria Documents manual, the copper CCC limit is related to hardness using the slope of 0.8545. At a hardness of 59 mg/L, the appropriate site -specific CCC for total recoverable copper is 9.04 pglL. The slope for the copper CMC is 0.9422, therefore the site -specific CMC is 12.95 erg/L. REFERENCES USED FOR PROJECT Brandlova, J. A., Brandt and C.H. Fernando. 1972. The cladocera of Ontario with remarks on some species and distribution. Can J. Zool. 50: 1373-1403. Brinkhurst, R.O. 1986. Guide to the Freshwater Aquatic Microdrile Oligochaetes of North America. Can. Spec. Publ. Fish. Aquat. Sci. 84:259 p. Bulak, James S. Distribution of Fishes in South Carolina. Study Completion Report WC-8. South Carolina Wildlife and Marine Resources Department. Columbia, South Carolina. Edmonds, Jr., G.F., S.T. Jenson and L. Berner. 1979. The Mayflies of North and Central America, University of Minnesota Press, Minneapolis. Hobb, Horton Jr. 1981. The Crayfish of Georgia. Smithsonian Contributions to Zoology #318. Smithsonian International Press. Lee, D.S. et. al. 1980. Atlas of North American Freshwater Fishes. North Carolina Museum of Natural History. Menhinick, Edward F. 1991. The Freshwater Fishes of North Carolina. The Delmar Company. Pennak, Robert W. 1978. Freshwater Invertebrates of the United States. Second Edition. John Wiley and Sons. New York. Stephan, C.E. et. al. 1985. Guidelines for Deriving Numerical National Water Quality Criteria for the Protection of Aquatic Organisms and Their Uses. National Technical Information Service, Springfield, VA. Stewart, K.W. and Bill P. Stark. 1988. Nymphs of North American Stonefly Genera (Plecoptera). Entomological. Society of America. USEPA. 1982. Freshwater Snails (Mollusca: Gastropoda) of North America. EPA-600/3- 82/026. USEPA. 1993. Methods for measuring the Acute Toxicity of Effluents and Receiving Waters to freshwater and Marine Organisms. Fourth Edition. EPA/600/4-90/027F. USEPA. 1994. Interim Guidance on Determination and Use of Water Effect Ratios for Metals. EPA-822-B-94-001. USEPA. 1996. 1995 Updates: Water Quality Criteria Documents for the Protection of Aquatic Life in Ambient Water. EPA-820-B-96-001. USEPA. 2001. Streamlined Water -Effect Ratio Procedure for Discharges of Copper. EPA-822-R-01-005. Vainio, Jouni K., Krzysztaf Jazdzewski and Risto Vainola. 1995. Biochemical Systematic Relationships Among The Freshwater Amphipods Gammarus varsoviensis, G. Lacustris and G. pulex. CRUSTACEA, 68 (6):587-694. • Attachment No 2.doc ATTACHMENT II September 23, 2004 Mr. Vemon Beatty SCDHEC Toxicology Department Re: Previous telephone conversations regarding deletion of the Cladocerans for Twelve Mile Creek WWTP recalculation study Dear Mr. Beatty, The following information pertains to a zinc recalculation study performed by Shealy for the Twelve Mile Creek WWTP located in Union County, North Carolina. After reviewing this information, we would appreciate your comments in regards to deleting the Cladocerans (i.e. Ceriodaphnia dubia) from the national data set. BACKGROUND Union County, North Carolina, received an NPDES permit for the Twelve Mile Creek WWTP, which had total recoverable zinc limits of 37 ug/1. This limit is based on the SC Standards as the effluent is conveyed by Twelve Mile Creek into SC. Twelve Mile Creek merges with the much larger Catawba River about 9 miles from the NC/SC border. SITE DESCRIPTION The receiving stream at Twelve Mile Creek WWTP is a free moving stream with no visible pools or stagnant areas. The stream is 30-45 feet wide at the effluent discharge vicinity. The depth varies from 0-3 feet deep. CLADOCERANS DELETION As you know, Daphnids or Cladocerans are found in ponds, lakes and stagnant pools of water. They are not found in free -flowing streams such as Twelve Mile Creek (see attached monthly stream flows from USGS gauging site #02146900). Per our telephone conversation this morning, Shealy Environmental Services deleted the Cladocerans (i.e. Ceriodaphnia dubia) from the national data set in recalculating the zinc limits for the Twelve Mile Creek area specific to the WWTP discharge point (site - specific study). It is our understanding that you would have deleted the Ceriodaphnia dubia species also, due to the free -flowing characteristics of this stream. We would greatly appreciate your response to this deletion issue. Thank you, Grady Satcher Shealy Environmental Services, Inc. GJGS DocumentslBeatty.doc Attachment No 3.pdf Struve .James N. From: Sent:. To: Subject: Beetty,dac ( 2 KB) Grady Sather [gsatoher©siealylab.com] Friday, September 24, 2004 4:34 PM Struve, James N. Fw: 12 Mlle Creek Recalculation Study Original Message. .From: "Vernon Beaty" <BEATYVR@dhoc. t.gc :v> To: <gsatohereshealyiab.coin> �$on Friday, September 2 4 204 Si»'14 : AM subject: Re: 12 Mile Creak R ca,ci ation. $turfy > Z have reviewed a nwtker of recalculations t_ hat' have .been appro d;by• • E0A and .used to set permit. limits, ::�' i`as consistantlf agre dV that l,ertic..arganisms sucks as ;c? adocerans a be ;delete'd .in.: a re00.lcv.l4ton., .> In the' situation. wou on. you : described, :we ld 'atiprove : acd .deaf t a \'permit:.: > based On °a ,recalculation that was arrived' at:by deleting 3:•entic • organisms; 1119,141w Outgoing. mail is certified Virus Free. . , Checked by- WWGr anti virus system {h t:gxisoft. comb Version: 6.0.768 / Virus Database: 61$ - Release Dater 9/22120'04= . Attachment No 5.doc September 23, 2004 Mr. Jim Struve Hazen and Sawyer, P.C. 4944 Parkway Plaza Blvd. Suite 375 Charlotte, NC 28217 Dear Mr. Struve, The purpose of this letter is to address the technical questions posed by North Carolina's Division of Water Quality regarding the Union County Public Works Department Twelve Mile Creek WWTP Site -Specific study for zinc and copper. The issues were stated in the July 26, 2004, letter from Mr. David A. Goodrich of the NC DWQ to Mr. Jon C. Dyer of Union County. Corrected copies of the zinc and copper recalculations are included as Attachment 1. Information included as Attachment 2 addresses the exclusion of Daphnids from the zinc and copper data sets. Zinc 1. (Page 4-3) We are unable to verify the calculated N, A, and FAV's. Please provide the source and documentation of each with the resubmitted proposal. Reply: The attached corrected recalculation report for zinc contains the values for N, A, and the FAV with the appropriate calculations. The corrected recalculation report also reflects changes to the species list to reflect the 1995 Updated EPA Water Quality Criteria document (EPA-820-B-96-001, September 1996). The `N' value of 30 is correct for this data set, as only the Genus Mean Acute Values (GMAV) are counted. Several species belonging to one genus would count as one GMAV. The 'A' value has been changed to 6.104, and the FAV becomes 447.6. The calculations used to obtain these values have been included in the corrected report. September 23, 2004 Page 2 2. (Page 4-3) we will not support the removal of the Cladocerans from the National Data Set. Reply: See Attachment 2. 3. (Page 4-4) The calculated Criterion Continuous Concentration (CCC) states, in text, the correct Acute Chronic Ratio for Zn in 2.208. The CCC, by calculation, uses an incorrect ACR of 2.088. Reply: According to the 1995 Updates, the updated ACR for zinc is 2.0. We have recalculated the CCC with the correct ACR value. 4. The recalculated 234.5 µg/L CCC does not fulfill the obligations of the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water -Effect Ratios for Metals". (Page 4-4) Reply: The corrected CCC using the updated values as mentioned above, is 223.8 µg/L zinc for a hardness of 50 mg/L. With the above changes, this value should meet the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water - Effect Ratios for Metals". The hardness -adjusted value is 257.5 µg/L zinc, and the calculations are provided in the corrected report. 5. PQL of 10 ug/L for Zinc. Reply: A PQL of 20 ug/L was reported, but a PQL of 10 ug/L should have been reported for zinc analyses. The current MDL value for zinc is 4.5 ug/L. In April, 2003, the MDL value for zinc was 10 ug/L. If the samples had zinc "hits" above the reported PQL of 20 ug/L (as in the effluent samples), the 10 ug/L PQL is a mute point. For the reported data, the PQL for zinc may be lowered down to 10 ug/L, but only after review of the QC data (method blanks, CCB, etc.) for those analytical batches. Copper 1. (Page 4-8) We are unable to verify the calculated N, A, and FAV's. Please provide the source and documentation of each with the resubmitted proposal. September 23, 2004 Page 3 Reply: The attached corrected recalculation report for copper contains the values for N, A, and the FAV with the appropriate calculations. The corrected recalculation report also reflects changes to the species list to reflect the 1995 Updated EPA Water Quality Criteria document (EPA-820-B-96-001, September 1996). 2. (Page 4-7) we will not support the removal of the Cladocerans from the National Data Set. Reply: See Attachment 2. 3. The recalculated copper 9.2j µg/L CCC does not fulfill the obligations of the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water -Effect Ratios for Metals". (Page 4-8) Reply: The corrected CCC is 7.85µg/L copper, and the CMC is 11.08 µg/L copper for a hardness of 50 mg/L. With the above changes, this value does meet the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water -Effect Ratios for Metals". The hardness adjusted CCC is 9.04 µg/L copper, and the CMC is 12.95µg/L copper. All calculations are provided in the corrected report. 4. PQL's and MDL's for Copper analyses. Reply: The PQL of 5 ug/L shown on the analytical reports (Appendix B) is correct. The correct MDL for copper during this study was I ug/L and not 2 ug/L. We apologize for any inconvenience that these issues have caused. Please contact me or Grady Satcher if you have further questions or need clarification on any of the points. Thank you. Sincerely, Elizabeth W. Thompson Toxicity Department Shealy Environmental Services Attachment No 6.doc October 26, 2004 Mr. Jim Struve Hazen and Sawyer, P.C. 4944 Parkway Plaza Blvd. Suite 375 Charlotte, NC 28217 Dear Mr. Struve, This is to follow-up response to the initial response addressing the technical questions posed by North Carolina Division of Water Quality regarding the Union County Public Works Department Twelve Mile Creek WWTP Site -Specific Study for zinc and copper. The issues were stated in the July 26, 2004, letter from Mr. David A. Goodrich of the North Carolina Division of Water Quality to Mr. Jon C. Dyer of Union County. Zinc 1) Regarding a reported PQL of 20 ug/L for zinc analyses. South Carolina Department of Health and Environmental Control requires a PQL of 10 ug/L to be used for NPDES reporting to South Carolina. For the referenced report, a PQL of 20 ug/L was reported for the zinc analyses. The method detection limit (MDL) for zinc during the time of these analyses was 10 ug/L. After discussing this issue on October 19, 2004, with Mr. Matt Matthews of North Carolina Division of Water Quality, he contacted Ms. Connie Brower of North Carolina Division of Water Quality for her clarification of this issue. Since the effluent zinc analyses all had values greater than 20 ug/L, Mr. Matthews said his department may note in the final report the use of the 20 ug/L PQL for zinc, but this issue would not prohibit their approval of the standards as proposed. Habitat Assessment On April 23, 2003, Shealy Environmental Services traveled to Twelve Mile Creek WWTP located in Union County, North Carolina. The purpose of this trip was .to access the physical habitat quality of the stream directly above and below the point of discharge. October 26, 2004 Mr. Jim Struve Hazen and Sawyer Figure 3-1 in the report provides four pictures of Twelve Mile Creek at the WWTP outfall. The receiving stream at this location is a swiftly moving stream with no visible pools or stagnant areas. The stream is 30-45 feet wide at the effluent discharge vicinity. The depth was approximately 0-3 feet deep when measured by Shealy personnel on April 24, 2003. The bottom, inorganic substrate, is predominantly igneous sand and gravel. Very little organic matter (detritus or mud) was observed on the stream bed. The stream habitat was comprised of aquatic vegetation, snags/wood, leaf packs, root banks and rifle/run areas. A Habitat Assessment Field Data Sheet may be found in Appendix B which documents the GPS coordinates of the stream, physical characteristics of the stream, water chemistry of the site (pH, DO), water sled features, and types of vegetation. Also, two copies of fish collection data "obtained from the SC Wildlife and Marine Resources Department" was given to Mr. Matthews at the meeting last month. I hope this resolves all issues with the referenced report. If you need additional information, please call me at 803-794-3008. Sincerely, Grady Satcher Shealy Environmental Services ATA NCDENR Attachment No 4 North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director Mr. Jon C. Dyer, P.E., Director Union County Public Works Department Twelve Mile Creek WWTP 400 North Church Street Monroe, North Carolina 28112-4804 Dear Mr. Dyer: July 26, 2004 RECEIVED JUL 27 2004 F.nviraeunanal ScienoesBranch The Division of Water Quality (DWQ) has reviewed the proposed site -specific standards technical assistance document prepared by Hazen and Sawyer for the Twelve Mile Creek WWTP (Permit NC0085359). We acknowledge the significant effort that was put into the report and recognize that this was uncharted territory for DWQ as well as Union County. DWQ has, however, identified many issues within the document that prohibit our approval of the standards as proposed. While not a complete listing, the following items will require attention before further action by DWQ can be undertaken: • We disagree that the habitat of Twelve Mile Creek is incapable of supporting Cladocerans. The removal of Ceriodaphnia dubia, Ceriodaphnia reticulata, Daphnia magna and Daphnia pulex from the US Environmental Protection Agency's (EPA) original national acute data set for both Zinc and Copper is therefore not supported. • Fish collection data "obtained from the SC Wildlife and Marine. Resources Department" (page 3-1) was not provided for review. • The `Technical Study Plan for the Site -Specific Development for Copper and Zinc at the Union County, North Carolina Twelve Mile Creek. Wastewater Treatment Plant" (hereafter referred to as the "T.S. Plan") indicated that both a "habitat assessment performed by Shealy (Environmental Services, Inc.) in April 2003 at the study site" and 'Fish collection data obtained from the NC Department of Health and Environmental Management" may be used for this study. (Section 2.2, page 3 of the T.S. Plan) No information from either source was provided. Zinc • Errors noted in the calculation of the proposed Zinc criterion are not limited to the following: 1. (Page 4-3) We are unable to verify the calculated N, A, and FAV's. Please provide the source and documentation of each with the resubmitted proposal. 2. (Page 4-3) as noted above — we will not support the removal of the Cladocerans from the National Data Set. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 N. Salisbury St., Raleigh, North Carolina 27604 Planning Branch — Phone: 919 733-5083 / FAX: 919-715-5637 An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper N O e Cai'O11Ila �tura!!y Mr. Jon Dyer, P.E. Union County Public Works Department Page 2 of 3 July 26, 2004 3. (Page 4-4) The calculated Criterion Continuous Concentration (CCC) states, in text, the correct Acute Chronic Ratio for Zn at 2.208. The CCC, by calculation, uses an incorrect ACR of 2.088. 4. The recalculated 234.5 µg/L CCC does not fulfill the obligations of the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water -Effect Ratios for Metals". (Page 4-4) • In accordance with SC DHEC policy for PQLs (Practical Quantitation Limits), a PQL of 10 µg/L must be used for NPDES reporting to South Carolina. This comes from SC Regulation 61-68. The stated Zinc 20 µg/L "method detection limit'(Page 2-2) does not meet the requirement for SC DHEC Laboratory Certification and we do not believe that data to support agreement with the SC standard for zinc would be valid without proper levels of reporting. The State of North Carolina currently reports and supports the reporting quantity for Zn at 10 µg/L. • When revisions are made to the Zinc CCC as noted above, provide calculations for the Hardness adjustment to the resubmitted!CCC. Copper • Errors noted in the calculation of the proposed Copper criterion are not limited to the following: 1. (Page 4-8) We are unable to verify the calculated N, A, and FAV's. Please provide the source and documentation of each with the resubmitted proposal. 2. (Page 4-7) as noted above — we will not support the removal of the Cladocerans from the National Data Set for Copper. 3. The recalculated Copper 9.23 µg/L CCC does not fulfill the obligations of the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water - Effect Ratios for Metals". (Page 4-8) • The submitted supporting Shealy Environmental Laboratory, Inc. data (Appendix B) for Copper lists a PQL of 5 µg/L (0.005 mg/L) on all data sheets. The Final Report incorrectly states the PQL as 2 µg/L on Pages 2-2, 4-9 and 4-10 (incorrectly identified as the Method Detection Limit). Please clarify with the laboratory the PQL used for the data sets submitted. • When revisions are made to the Copper CCC as noted above, provide calculations for the Hardness adjustment to the resubmitted CCC. Our review cannot be finalized until the above requests are completed. In addition, the US EPA Region IV office and SC DHEC must also have an opportunity to review the request before making final decisions on the requested standard revisions. Please contact Connie Brower at 919-733-7015, extension 572 for questions regarding the specific requests, or Jackie Nowell at extension 512 for permitting issues. Respectfully,, -Daduilk A- ..ieroco David A. Goodrich NPDES Unit Supervisor Mr. Jon Dyer, P.E. Union County Public Works Department Page 3 of 3 July 26, 2004 cc: Mooresville Regional Office Mark E. Tye: 400 North Church Street, Monroe, North Carolina 28112-4804 Joel Hansel: US EPA, Atlanta Federal Center, 61 Forsyth St, SW, Atlanta, GA 30303 Marshall Hyatt: US EPA, Atlanta Federal Center, 61 Forsyth St, SW, Atlanta, GA 30303 M i1t Matthews: DWQ — Aquatic Toxicology Unit Connie Brower: DWQ - Classifications and Standards Jackie Nowell: DWQ - NPDES Permitting Mike Montebello: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 Jeff deBessonet: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 Gina Kirkland: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 RECEIVED JUL 27 20O4 Twelve Mile Creek October 21, 2003 Outfall Area Downstream Sampling Point UNION COUNTY PUBLIC WORKS DEPARTMENT .'a Jon C. Dyer, P.E., Director { October 15, 2004 Mr. David Goodrich NCDENR DWQ — NPDES Permits Section 1617 Mail Service Center Raleigh, North Carolina 27699-1617 o s � OCT �r�'n Liu., OCT � L..------ pOT SUBJECT: NPDES Permit Application Twelve Mile Creek WWTP Expansion — NC0085359 Union County, NC Dear Mr. Goodrich: Enclosed are three (3) copies of the NPDES Permit Application package and a $860.00 check for the expansion of Union County's Twelve Mile Creek VVWTP. The expansion will take the facility form 2.5 MGD to 6.0 MGD. The Environmental Assessment covering this project has been reviewed through the NC Clearinghouse and a Finding of No Significant Impact has been issued. Expansion of this treatment facility is critical to Union County's ability to meet the needs of the rapidly growing service area within the westem portion of the county. Plans and specifications for expansion of the facility are being submitted to DWQ for technical review in the next two (2) weeks. We understand the NPDES Permit will be issued in approximately 180 days. We plan to aggressively pursue the technical review process so that an Authorization to Construct can be issued soon after the NPDES Permit is issued. We plan to bid the project in a timely fashion in order to begin construction on this critical project by May 2005. Please contact me at (704) 296-4212 if you have any questions concerning this application package. Thank you in advance for your assistance with these matters. Respectfully, C. Dyer, PE erector of Public Works CC: Sid Riddick, Mckim & Creed 400 North Church St. . Monroe, North Carolina 28112-4804 . Phone: (704) 296-4210 . Fax: (704) 296-4232 JA-04 le V William G. Ross Jr., Secretary 5 r�aL P i...`r 9lorth Carolina Department of Environment and Natural Resources September 17, 2004 Mr. Jon C. Dyer, P.E., Director Union County Public Works Department 400 N. Church Street Monroe, NC 28112-4804 Michael F. Easley, Governor Al�n�y_K1im�k:: Director *1' 4;" Division of Water Quality DENR _ ViATER QUALITY POINT SOURCE ERMNCH .,, . \\J Subject: Environmental Assessment; Twelve Mile Creek Wastewater Treatment Plant Expansion Dear Mr. Dyer: The NC Environmental Policy Act review for the subject project is complete. Comments were received during the course of the State Clearinghouse review (see attached letter from the Clearinghouse); however, due to the nature of the comments no further review action is required. Permit applications covering activities associated with this project may now proceed. The applications should be consistent with the Finding of No Significant Impact issued by the Division of Water Quality on August 9, 2004 (attached). If there is anything else I can assist you with, please give me a call at 919.733.5083 ext. 555. Sincerel ,;Alex • arks, AICP Environmental Specialist cc: ✓Dave Goodrich Melba McGee Sid Riddick, PE Nose Carolina �tcrrallg North Carolina Division of Water Quality/Planning Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-5083 http//www.h2o.enr.state.nc.us 512 North Salisbury St. Raleigh, NC 27604 FAX (919) 715-5637 DENR Customer Service 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer North Carolina Department of Administration Michael F. Easley, Governor Gwynn T. Swinson, Secretary September 14, 2004 Mr. Alex Marks DENR, Water Quality 1617 MSC Raleigh, NC 27699-1617 Dear Mr. Marks: Re: SCH File # 05-E-4300-0040; Environmental Assessment/Finding of No Significant Impact; Expansion of the 12 Mile Creek Wastewater Treatment Plant in Waxhall , N.C. The above referenced environmental impact information has been reviewed through the State Clearinghouse under the provisions of the North Carolina Environmental Policy Act. Attached to this letter are comments made by agencies in the course of this review. Because of the nature of the comments, it has been determined that no further State Clearinghouse review action on your part is needed for compliance with the North Carolina Environmental Policy Act. The attached continents should be taken into consideration in project development. Best regards. Sincerely, (AA'0-)A* st-1 • Ms. Chrys Baggett -Environmental Policy Act Coordinator Attachments cc: Region F Mailing Address: Telephone: (919)807-2425 Location Address: 1301 Mail Service Center Fax (919)733-9571 116 West Jones Street Raleigh, NC 27699-1301 State Ceviicr #51-01-00 Raleigh, North Carolina e-mail Chrys.Baggett@ncmail.net An Equal Opportunity/Affirmative Action Employer M1 MR PHIL LETSINGER CLEARINGHOUSE COORD CC&PS - DEM, NFIP MSC # 4716 RALEIGH NC NORTH CAROLINA STATE CLEARINGHOUSE DEPARTMENT OF ADMINISTRATION INTERGOVERNMENTAL REVIEW REVIEW DISTRIBUTION CC&PS - DEM, NFIP CENTRALINA COG DENR LEGISLATIVE AFFAIRS DEPT OF CUL RESOURCES DEPT OF TRANSPORTATION oJw STATE NtJNBER: 05-E-4300-0040 H03 DATE RECEIVED: 08/11/2004 AGENCY RESPONSE: 09/08/2004 REVIEW CLOSED: 09/13/2004 PROJECT INFORMATION APPLICANT: DEnr, Water Quality TYPE: State Environmental Policy Act ERD: Environmental Assessment/Finding of No Significant Impact DESC: Expansion of the 12 Mile Creek Wastewater Treatment Plant in Waxhall , N.C. CROSS-REFERENCE NUMBER: 03-E-4300-0009 The attached project has been submitted to the N. C. State Clearinghouse for intergovernmental review. Please review and submit your response by the above indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301. If additional review time is needed, please contact this office at (919)807-2425. AS A RESULT OF THIS REVIEW THE FOLLOWING IS SUBMITTED: EllNO COMMENT EIMMENT CHE SIGNED BY: DATE: North Carolina Department of Crime Control and Public S Division of Emergency Management Floodplain Management Branch Michael F. Easley, Governor Bryan E. Beatty, Secretary Division of Emergency Management National Flood Insurance Program STATE NUMBER: 05-E-4300-0040 APPLICANT: DENR, Water Quality DESC: Expansion of 12-Mile-Creek Wastewater Treatment Plant in Waxhall, NC Given the rough location provided in the final EA, the plant proposed to be expanded may be located in a Base Flood (AE) Zone. Before commencement of any work on the structure, a detailed determination of the specific location in relation to the Union County FIRM (Panel 70, dated July 5, 1994) must be made. If the project is determined to be located in the AE zone, flood protection measures must be taken. Because the proposed project would be a substantial improvement of the existing structure, all new construction and existing construction must meet current construction standards outlined in the Union County Flood Damage Prevention Ordinance, even if the original structure was grandfathered. Please contact the local Floodplain Administrator to determine the floodplain designation and to find out specific regulations, if applicable. ave Lentzne Division of Emergency Management — NFIP 919-715-8000 extension 351 MAILING ADDRESS: Disaster Recovery Operations Center (DROC) 4713 Mail Service Center Raleigh, NC 27699-4713 Fax: (919) 715-5408 www.ncem.org NC Division of Emergency Management OFFICE LOCATION: 1830-B Tillery Place Raleigh, NC 27604 Telephone: (919)715-8000x351 An Equal Opportunity/Affirmative Action Employer NORTH CAROLINA STATE CLEARINGHOUSE DEPARTMENT OF ADMINISTRATION INTERGOVERNMENTAL REVIEW STATE NUMBER: DATE RECEIVED: AGENCY RESPONSE: REVIEW CLOSED: MS MELBA MCGEE CLEARINGHOUSE COORD DENR LEGISLATIVE AFFAIRS ARCHDALE BLDG - MSC # 1601 RALEIGH NC REVIEW DISTRIBUTION CC&PS - DEM, NFIP CENTRALINA COG DENR LEGISLATIVE AFFAIRS DEPT OF CUL RESOURCES DEPT OF TRANSPORTATION PROJECT INFORMATION APPLICANT: DEnr, Water Quality TYPE: ERD: Environmental Assessment/Finding of No Significant Impact DESC: Expansion of the 12 Mile Creek Wastewater Treatment Plant State Environmental Policy Act CROSS-REFERENCE NUMBER: 03-E-4300-0009 05-E-4300-0040 08/11/2004 09/08/2004 09/13/2004 in Waxhall , N.C. The attached project has been submitted to the N. C. State Clearinghouse for intergovernmental review. Please review and submit your response by the above indicated date to 1301 Mail Service Center, Raleigh NC 27659-1301. If additional review time is needed, please contact this office at (919)807-2425. AS A RESULT F THIS REVIEW THE FOLLOWING IS SUBMITTED: NO COMMENT COMMENTS ATTAHED SIGNED BY: DATE: d' /3/0y FINDING OF NO SIGNIFICANT IMPACT Environmental Assessment for the Twelve Mile Creek Wastewater Treatment Plant Expansion Project Union County Public Works Department August 9, 2004 Pursuant to the requirements of the North Carolina Environmental Policy Act (N.C.G.S. § 113A- 1, et seq.), an environmental assessment (EA) has been prepared for the expansion of the existing Twelve Mile Wastewater Treatment Plant (WWTP) in Union County. The proposed project will expand the plant's existing permitted capacity of 2.5 million gallons per day (MGD) to 6.0 MGD. Growth in the Twelve Mile Basin area of the County has been rapid. The plant is currently operating at 40% of its rated capacity and Union County has issued non -discharge permits committing 100% of the available capacity. These factors, plus planning projections, show a need for the project. The plant, constructed in 1996 is located on an 88-acre parcel, approximately 4,000 feet west of NC 16 along Twelve Mile Creek in the Town of Waxhaw. Beyond the WWTP, Twelve Mile Creek flows directly into the Catawba River downstream from Lake Wylie near Van Wyck, SC. The creek is in the Catawba River sub -basin 03-08-38. The plant will serve an area of approximately 93 square miles, which includes the towns of Waxhaw, Mineral Springs, and Wesley Chapel, portions of the towns of Stallings and Indian Trail, much of the town of Weddington, and unincorporated portions of the basin. Union County provides sewer and water services to the entire basin. Alternatives analyzed for the EA include constructing a land application system and discharging wastewater to the Charlotte -Mecklenburg Utility System. The selected alternative, expansion of the existing plant capacity, was chosen as it offers the lowest capital and present value costs. All construction associated with the proposed expansion will occur immediately adjacent to the existing facility on land already disturbed. Following required federal and state permit conditions will minimize potential direct impacts. An Erosion and Sedimentation Control Plan will be submitted to DENR for approval before construction commences. Secondary and cumulative impacts associated with land development occurring within the service area may result from the project. Various town ordinances and land development regulations of the municipalities within the project's service area as well as Union County will mitigate many of these impacts. These regulations include various smart growth provisions, open space, and riparian buffer protection regulations. Based on the findings of the EA, review by governmental agencies, and the impact avoidance/mitigation measures contained therein, it is concluded that the proposed project will not result in significant impacts to the environment. This EA and Finding of No Significant Impact are prerequisites for the issuance of an NPDES Discharge Permit by the Division of Water Quality. Pending approval by the State Clearinghouse, the environmental review for this project will be concluded. An environmental impact statement will not be prepared for this project. North Carolina Division of Water Quality, Water Quality Section August 9, 2004 ATA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director July 26, 2004 Mr. Jon C. Dyer, P.E., Director Union County Public Works Department Twelve Mile Creek WWTP 400 North Church Street Monroe, North Carolina 28112-4804 Dear Mr. Dyer: The Division of Water Quality (DWQ) has reviewed the proposed site -specific standards technical assistance document prepared by Hazen and Sawyer for the Twelve Mile Creek WWTP (Permit NC0085359). We acknowledge the significant effort that was put into the report and recognize that this was uncharted territory for DWQ as well as Union County. DWQ has, however, identified many issues within the document that prohibit our approval of the standards as proposed. While not a complete listing, the following items will require attention before further action by DWQ can be undertaken: • We disagree that the habitat of Twelve Mile Creek is incapable of supporting Cladocerans. The removal of Ceriodaphnia dubia, Ceriodaphnia reticulate, Daphnia magna and Daphnia pulexfrom the US Environmental Protection Agency's (EPA) original national acute data set for both Zinc and Copper is therefore not supported. • Fish collection data "obtained from the SC Wildlife and Marine Resources Department" (page 3-1) was not provided for review. • The "Technical Study Plan for the Site -Specific Development for Copper and Zinc at the Union County, North Carolina Twelve Mile Creek Wastewater Treatment Plant" (hereafter referred to as the "T.S. Plan") indicated that both a "habitat assessment performed by Shealy h� r�"� 3- (Environmental Services, Inc.) in April 2003 at the study site" and 'Fish collection data dei4 obtained from the NC Department of Health and Environmental Management' may be used for this study. (Section 2.2, page 3 of the T.S. Plan) No information from either source was provided. Zinc • Errors noted in the calculation of the proposed Zinc criterion are not limited to the following: 1. (Page 4-3) We are unable to verify the calculated N, A, and FAV's. Please provide the source and documentation of each with the resubmitted proposal. 2. (Page 4-3) as noted above — we will not support the removal of the Cladocerans from the National Data Set. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 N. Salisbury St., Raleigh, North Carolina 27604 Planning Branch — Phone: 919-733-5083 / FAX: 919-715-5637 An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper one NCarolina Nature, Mr. Jon Dyer, P.E. Union County Public Works Department Page 2 of 3 July 26, 2004 3. (Page 4-4) The calculated Criterion Continuous Concentration (CCC) states, in text, the correct Acute Chronic Ratio for Zn at 2.208. The CCC, by calculation, uses an incorrect ACR of 2.088. 4. The recalculated 234.5 µg/L CCC does not fulfill the obligations of the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water -Effect Ratios for Metals". (Page 4-4) • In accordance with SC DHEC policy for PQLs (Practical Quantitation Limits), a PQL of 10 µg/L must be used for NPDES reporting to South Carolina. This comes from SC Regulation 61-68. The stated Zinc 20 µg/L "method detection limit"(Page 2-2) does not meet the requirement for SC DHEC Laboratory Certification and we do not believe that data to support agreement with the SC standard for zinc would be valid without proper levels of reporting. The State of North Carolina currently reports and supports the reporting quantity for Zn at 10 µg/L. • When revisions are made to the Zinc CCC as noted above, provide calculations for the Hardness adjustment to the resubmitted:CCC. Copper • Errors noted in the calculation of the proposed Copper criterion are not limited to the following: 1. (Page 4-8) We are unable to verify the calculated N, A, and FAV's. Please provide the source and documentation of each with the resubmitted proposal. 2. (Page 4-7) as noted above — we will not support the removal of the Cladocerans from the National Data Set for Copper. 3. The recalculated Copper 9.23 µg/L CCC does not fulfill the obligations of the EPA procedure as outlined by the "Interim Guidance on Determination and Use of Water - Effect Ratios for Metals". (Page 4-8) • The submitted supporting Shealy Environmental Laboratory, Inc. data (Appendix B) for Copper lists a PQL of 5 µg/L (0.005 mg/L) on all data sheets. The Final Report incorrectly states the PQL as 2 µg/L on Pages 2-2, 4-9 and 4-10 (incorrectly identified as the Method Detection Limit). Please clarify with the laboratory the PQL used for the data sets submitted. • When revisions are made to the Copper CCC as noted above, provide calculations for the Hardness adjustment to the resubmitted CCC. Our review cannot be finalized until the above requests are completed. In addition, the US EPA Region IV office and SC DHEC must also have an opportunity to review the request before making final decisions on the requested standard revisions. Please contact Connie Brower at 919-733-7015, extension 572 for questions regarding the specific requests, or Jackie Nowell at extension 512 for permitting issues. Respectfully, t21) DoucQ A- Qieyolfrccck David A. Goodrich NPDES Unit Supervisor Mr. Jon Dyer, P.E. Union County Public Works Department Page 3 of 3 July 26, 2004 cc: Mooresville Regional Office Mark E. Tye: 400 North Church Street, Monroe, North Carolina 28112-4804 Joel Hansel: US EPA, Atlanta Federal Center, 61 Forsyth St, SW, Atlanta, GA 30303 Marshall Hyatt: US EPA, Atlanta Federal Center, 61 Forsyth St, SW, Atlanta, GA 30303 Matt Matthews: DWQ — Aquatic Toxicology Unit Connie Brower: DWQ - Classifications and Standards Jackie Nowell: DWQ - NPDES Permitting Mike Montebello: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 Jeff deBessonet: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 Gina Kirkland: Bureau of Water, SC DHEC, 2600 Bull St. Columbia, SC 29201 Facility Name = NPDES # = Qw (MGD) = 7QIOs (cfs)= IWC (%) = Union County Twelve Mile Creek NC0085359 2.5 0 100.00 FINAL RESULTS Copper Max. Pred Cw Allowable Cw 22.0 7.0 RESULTS Std Dev. Mean C.V. Number of data points Mult Factor = Max. Value Max. Pred Cw Allowable Cw 1.7447 2.1 0.8278 13 3.66 6.0 µg/1 22.0 µg/1 7.0 µg/1 Parameter = Standard = Copper 7.0 Date n < Actual Data BDL=1/2DL Aug-02 1 2.3000 2.3000 Aug-02 2 3.7000 3.7000 Aug-02 3 5.1000 5.1000 Aug-02 4 < 2.0000 1.0000 Aug-02 5 6.0000 6.0000 Sep-02 6 < 2.0000 1.0000 Sep-02 7 < 2.0000 1.0000 Sep-02 8 < 2.0000 1.0000 Sep-02 9 < 2.0000 1.0000 Sep-02 10 < 2.0000 1.0000 Jan-00 11 < 2.0000 1.0000 Oct-00 12 < 2.0000 1.0000 Mar-02 13 2.3000 2.3000 Facility Name = NPDES # = Qw (MGD) = 7Q10s (cfs)= IWC (%) _ Union County Twelve Mile Creek NC0085359 2.5 0 100.00 FINAL RESULTS Zinc Max. Pred Cw Allowable Cw Allowable #/day 79.5 50.0 0.0 RESULTS Std Dev. Mean C.V. Number of data points Mult Factor = Max. Value Max. Pred Cw Allowable Cw 9.3198 40.8 0.2286 13 1.50 53.0 µg/1 79.5 pg/1 50.0 µg/1 Parameter = Standard = Zinc 50.0 Date n < Actual Data BDL=1/2DL Jan-00 1 40.0 40.0 Oct-00 2 52.0 52.0 Mar-02 3 48.0 48.0 Aug-02 4 45.0 45.0 Aug-02 5 42.0 42.0 Aug-02 6 45.0 45.0 Aug-02 7 42.0 42.0 Aug-02 8 48.0 48.0 Sep-02 9 31.0 31.0 Sep-02 10 26.0 26.0 Sep-02 11 25.0 25.0 Scp-02 12 33.0 33.0 Sep-02 13 53.0 53.0 ‘fr MCKIM & CREED July 7, 2004 00771.0023 (42) NC Department of Environment and Natural Resources Division of Water Quality Attention: Mr. Mark McIntire 1617 Mail Service Center Raleigh, NC 27699-1617 Fit) r:" i I L_ WI J IJ L 9 2004 RE: Revised Engineering Alternatives Analysis Union County Twelve Mile Creek Wastewater Treatment Plant Expansion NPDES Permit NC0085359 Gentlemen: In December, 2003, we received an email communication from Alex Marks regarding the review of the Environmental Assessment for expansion of Union County's Twelve Mile Creek Wastewater Treatment Plant. Since that time we have been working with the County to resolve all comments resulting from this review. One of the issues contained in the correspondence concerns the Engineering Alternatives Analysis, and the fact that the difference in the 20-year present value cost between expanding the Twelve Mile Creek plant and discharging to the Charlotte -Mecklenburg Utility (CMU) system was less than 10%. Upon review, the Capital Cost Estimate and Present Worth Analysis for discharge to the CMU system have been adjusted to account for two significant increases in cost: 1. The existing contract between Union County and CMU allows for the purchase of 2 mgd of capacity, at a cost to be determined based on a number of improvements planned or completed by CMU at the McAlpine Creek WWTP. In late 2003, the projected cost of these improvements was increased by $355,000 per mgd, to a total of $4.3 million per mgd, reflecting updated cost estimates for improvements to the CMU system. 2. The purchase of the additional one million gallons of capacity (for a total of 3 mgd) must be made based on future projected costs of expansion. This revised number is $7.9 million per mgd. The result of these two changes increases the capital cost to purchase 3 mgd of capacity in CMU from $1 1.865 million, to $16.526 million. The Present Worth Analysis has also been adjusted to account for the capital cost differences, and the Present Worth Cost Differential between expanding Twelve Mile Creek and pumping to CMU has increased to approximately $6.1 million, or a differential of 16.6%. 2300 SARDIS ROAD NORTH, SUITE A, CHARLOTTE, NORTH CAROLINA 28227 TEL 704.841.2588 FAx 704.841.2567 www.mckimcreed.com AA0002667 Please review the revised document related to the Engineering Alternatives Analysis. We look forward to your concurrence in the analysis. Respectfully, McKIM & CREED, PA G.(hc,f6— William S. Riddick, Jr., PE Vice President pc: Mr. Mark Tye, Assistant Director, Union County Public Works Mr. Alex Marks 4McK1M&CREED C. ALTERNATES ANALYSIS 1. BACKGROUND Union County has utilized land based disposal, connections to other publicly owned treatment works (POTW's), and development of its own POTW's with surface discharge to meet the capacity/treatment needs of the growing customer base. The selection of alternates has historically been made based on available options, feasibility, and cost. The existing Twelve Mile Creek WWTP was designed and permitted for a flow of 2.5 mgd. Past performance and actual wastewater characteristics confirm that the existing facility is capable of meeting current NPDES Permit limits. (See Table 3)`. Table 3 FY 2000 - 2001 Performance Summary Twelve Mile Creek WWTP Parameter NPDES Limit Actual Value Flow, mgd 2.50 0.925 BOD5, Summer, PPM 5.0 0.61 BOD5, Winter, PPM 10.0 0.64 NH3-N, Summer, PPM 2.0 0.17 NH3-N, Winter, PPM 4.0 0.19 TSS, PPM 30.0 0.04 Total Phosphorous, #/day 20.85 15.57 Fecal Coliform, per 100 ml 200 8.08 DO, PPM >_ 6.0 7.93 The NPDES Permit for the Twelve Mile Creek WWTP has been renewed, effective January 1, 2003. The new permit has two (2) major new requirements: a. Establishes new discharge limit and monitoring requirements for total phosphorous, expressed as a total mass daily load (TMDL). Permit limits set the TMDL at 20.85 lbs./day (12 month average). This is equivalent to a concentration value of 1 mg/I at a flow of 2.5 mgd. The existing Twelve Mile Creek WWTP was designed to achieve a 1 mg/I effluent total phosphorous, utilizing BNR technology. The biological capability was further enhanced by the addition of alum feed and effluent filters. The chemical addition has not been used, since the County has not been required to meet the TMDL under its old permit. b. Establishes limits for total copper and zinc, and provides a schedule of compliance to achieve required limits. To address these requirements, the County has completed a study which concludes that the "reasonable potential" for copper and zinc does not warrant regulation under the NPDES permit. Past performance of the Twelve Mile Creek WWTP illustrates that significant reduction in total phosphorous occurs in the process, even though plant operations have not focused specifically on maximizing phosphorous reduction. Union County does not anticipate undue problems meeting the current TMDL for phosphorous using the BNR process plus physical chemical treatment, if necessary. 2. RE -RATING THE TWELVE MILE CREEK WWTP As a part of its strategy to provide additional capacity, Union County plans to request a modification of the NPDES Permit to increase the capacity of the existing facilities by 0.5 mgd to a capacity of 3.0 mgd. An engineering analysis of the existing facilities indicates that on the basis of past performance, wastewater characteristics, and present NPDES Permit limits, this capacity can be attained. Critical observations include: a. The Carrousel@ oxidation ditches can meet design requirements at a projected flow of 3.1 mgd. b. The UV disinfection system is capable of meeting disinfection requirements at peak flows of about 8.0 mgd, or 3.2 mgd average daily flow. Application for the NPDES modification for the additional capacity has not been made. However, for the purposes of this analysis, it is assumed that the existing facilities will be re -rated to a flow of 3.0 mgd. Alternates discussed below are based on providing an additional 3.0 mgd of capacity by 2005. 3. NPDES SPECULATIVE LIMITS As a part of the NPDES permitting procedures, speculative limits associated with increasing the discharge at the existing facility were requested from the Division of Water Quality. A copy of the Speculative Limits Letter is enclosed in Section H.2 "Exhibits." The speculative limits are consistent with the renewal of the NPDES permit for the Twelve Mile Creek WWTP, which was received in 2003. The main impact of the speculative limits is total phosphorous. In conjunction with the South Carolina Department of Health and Environmental Control (DHEC) and the United States Environmental Protection Agency (EPA), total phosphorous discharge is limited to 20.85 pounds per day, or a concentration value of 0.4 mg/I at a 6 mgd flow. 4. ALTERNATES Wastewater flow projections presented in Section B (Table 2) show that by 2010 the average daily flow at Twelve Mile Creek will be about 5.15 mgd. For planning purposes, Union County should have an available capacity of about 6.0 mgd, which is about 15% above the projected average flow. The alternates being considered in this analysis would provide 6.0 mgd of capacity by about 2005. Alternates evaluated herein are based on continued operation of the existing Twelve Mile Creek facility, at a re -rated capacity of 3.0 mgd. The evaluation of alternates to provide an additional 3.0 mgd in capacity considers the facility capital cost, plus operations and maintenance, to identify the "present -value -of - cost" of each option. Additional capacity would be provided 3.0 mgd increments by one of the three options described below. a. Alternate 1 - Expand the existing surface discharge facility from 3.0 to 6.0 mgd by 2005. This alternate will provide for the following modifications/additions to the existing treatment plant: 1. New headworks/pumping with fine mechanical screens and odor control. The existing influent pump station will be modified to provide a rated capacity of 6.0 mgd (15.0 mgd peak) . A new 750 kW emergency generator will be provided. 2. A new 3.0 mgd "liquid process" line consisting of parallel Carrousel® oxidation ditches, new parallel 75-foot diameter secondary clarifiers, new recycle/ waste sludge pumping, parallel effluent filter, parallel UV disinfection system, and related process piping. 3. New 1.0 mg aerobic sludge digester with diffusers and new blower building. 4. New 750 kW emergency generator with primary switchgear for the liquid process facilities, and all other site electrical and instrumentation. b. Alternate 2 - Construct a land -based treatment system. 1. This alternate would utilize the existing Twelve Mile Creek WWTP at a capacity of up to 3.0 mgd. The additional capacity would be provided by constructing a land application system, rated at 3.0 mgd. 2. New headworks with fine screens and odor control would be constructed ahead of the existing influent pump station. A new influent station and force main will be constructed to convey wastewaters to a remote stabilization lagoon site. 3. Construct stabilized waste holding basin(s) and pumping facilities to individual land treatment sites. 4. Construct land stabilization sites consisting of piping and fixed spray nozzles. c. Alternate 3 - Connect to Charlotte -Mecklenburg Utilities System (CMU) at Six Mile Creek. Union County currently has a contract with CMU for sewer service in the Six Mile Creek basin. The contract provides for up to 3.0 mgd of capacity. The County has exercised its rights for 1.0 mgd in capacity to serve Six Mile Creek. This analysis assumes that the existing agreement would be applicable for additional capacity in this system. Required facilities include: 1. Construct new headworks with fine screening and odor control, and a new influent pump station dedicated to pumping flow to the Six Mile Creek trunk sewer. The station would be rated for an average daily flow of 3.0 mgd. 2. Construct a 24-inch diameter force main from the pump station at Twelve Mile Creek to the Six Mile Creek basin. The force main discharges to a 36-inch gravity sewer connection to the Six Mile Creek line. 3. Purchase an additional 3.0 mgd of capacity in the CMU system in accordance with existing contracts. Under these arrangements, Union County "purchases" capacity in all applicable components, and then pays a treatment charge for operation of the conveyance and treatment components. The County is responsible for all future costs related to new permit requirements or improved operations or reliability. 5. PRESENT WORTH ANALYSIS The alternates described above will eacr provide wastewater treatment capacity needs of 6.0 mgd by the year 2005. The alternates have been evaluated on the basis of present worth or present value of cost in accordance with prescribed criteria. Present worth is a method of economic analysis that considers capital costs, operations and maintenance costs, and residual or salvage value over a predetermined period (in this case, 20 years) at a specified discount rate (i = 6.125%) for each alternate. The alternate with the lowest present value of cost or present worth is considered to be the most cost effective of those being considered. The procedures for determining present worth are described in "Guidance Document to Evaluate Wastewater Disposal Alternates," published by NCDENR, June 9, 2000. Each alternate is further described in the following sections. Capital cost estimates, along with applicable operations and maintenance estimates for each alternate have been prepared. It should be noted that the present worth analyses assume that the existing Twelve Mile Creek WWTP will be an integral part of any wastewater solution. The present worth analyses represent the costs above/beyond current costs that will be required to meet long term needs. a. Alternate 1. EXPAND THE EXISTING TWELVE MILE CREEK WWTP This option was envisioned when the current facility was permitted/constructed in 1996-1998. The existing site layout was prepared to easily double the system rated capacity. Space was provided in the site plan for new oxidation ditches, clarifiers, filters, and disinfection units. Much of the process piping was installed to facilitate new process tanks. In addition, the existing treatment process utilizes Carrousel® oxidation ditch technology to achieve biological removal of phosphorous down to concentrations of 1.0 ppm. Alum addition was also included in the original design to promote solids flocculation/removal during process upsets. Alum is traditionally employed to reduce phosphorous concentrations below 1.0 ppm. In 2001, Union County constructed another aerobic digester (1.0 million gallons) to improve solids stabilization and provide sludge storage for periods such as wet/cold weather, when land application of sludge cannot be done routinely. Expansion of the Twelve Mile Creek WWTP will require the following improvements: 1. New headwork with "fine" mechanical screens (2) and space for a future unit. 2. Upgrade influent pump station by replacing three (3) new 280 Hp units, sized so that any two pumps can meet peak capacity of 2.5 times6.0 mgd, or 15 mgd. 3. Provide odor control system at headworks and influent pump station, along with a new electrical switchgear building and a 705 kW generator set. 4. Parallel the existing 16-inch force main with a new 24-inch force main to meet pumping needs. 5. Provide two (2) additional Carrousel® oxidation tanks, two (2) additional secondary clarifiers with a new RAS/WAS pump station, new automatic backwash filters, and a new parallel UV disinfection unit. 6. Sludge processing will require another 1.0 mg digester with blower facilities. 7. Other improvements include an odor control system for the existing grit facilities, a new influent splitter box, upgraded in -plant pumping, and numerous piping changes. 8. New 750 kW standby generator with automatic transfer switch and primary switchgear building. The proposed expansion will cost an estimated $12.3 million. Operations and maintenance costs have been estimated taking into account chemicals and electricity, maintenance, laboratory operations, labor, management, and sludge disposal. The estimated cost of operations is estimated at about $1.77/1000 gallons in 2005. The unit treatment charge is estimated at $0.84/1000 gallons by 2014, adjusted for increased flow but not inflation of costs. The 20-year present worth of this alternate is approximately $26.0 million. b. Alternate 2. CONSTRUCT LAND APPLICATION SYSTEM This altemate will require operating "parallel" treatment systems to meet capacity needs. The existing WWTP will be re -rated and will operate at a maximum capacity of 3.0 mgd. The land application system will be patterned after the system formerly operated by Union County at Waxhaw, with the following modifications: 1. The Waxhaw site was permitted at a net flow of 25,000 gallons per acre of sprayfields. To achieve the rated flow of 250,000 gpd, about 100 acres of sprayfields were used. Topography, buffers, and unusable land resulted in Union County purchasing a 250 acre site. For the proposed land application alternate, it has been assumed that each 1.0 mgd of capacity will require 333 acres of sprayfields, and an additional 333 acres for buffers. 2. Land in the proximity of the existing Twelve Mile Creek WWTP has increased dramatically in price over the past decade, and is estimated at $35,000 to $40,000 per acre. Development and resulting high land costs between Waxhaw and western Union County essentially eliminates the availability of suitable sites. East of Waxhaw, however, open land is available, and there are numerous "large scale" farming operations. For this analysis, it was assumed that wastewater would be pumped up to ten miles to find suitable acreage for the lagoons and sprayfields. Considering the above, the following facilities are required for a parallel land application system: 1. New headworks with fine mechanical screens. 2. New influent pump station with standby generator to pump from the Twelve Mile Creek site to the lagoon/spray site. 3. Odor control system for headworks. 4. Approximately ten miles of 24-inch force main. 5. Waste stabilization and treated effluent storage system. 6. Effluent disinfection system. 7. 1,000 acres of active sprayfields with piping, sprinklers, and controls; and an additional 1,000 acres for buffers, etc. 8. Laboratory facilities. The project cost to provide the facilities and land for the 3.0 mgd system is estimated to be $47.1 Million. The projected 20-year present worth of this alternate is $57.2 Million. c. Alternate 3. DISCHARGE TO THE CHARLOTTE-MECKLENBURG UTILITY (CMU) SYSTEM This alternate will require construction of a major pump station at the Twelve Mile Creek site, and a 34,000-foot-long force main to transport wastewater to the CMU system along Six Mile Creek. Union County would purchase an additional 2.0 mgd of capacity in the CMU system under the terms of an existing agreement for service in the Six Mile Creek basin. Under this agreement, Union County has already purchased 1.0 mgd of capacity at a total cost of $1,765,000 for the Six Mile Creek interceptor and pumping system; and $1,050,000 for capacity in the McAlpine Creek WWTP. In addition, the County is responsible for its share of treatment reliability and process improvements. There are currently three (3) major projects underway at McAlpine (digesters, influent pumping, phosphorous removal) which will increase the treatment capital charge by an estimated $1,491,500; bringing the total estimated capital cost to purchase capacity from CMUD to $4,306,500 per mgd. The capacity purchase agreement stipulates that the purchase of additional capacity would be based on the actual cost of the expansion of the McAlpine Creek WWTP. This capacity is estimated to cost $6,148,000 per mgd. The total cost for conveyance and treatment of the additional 1.0 mgd is estimated to be $7,913,000. Facilities required to implement this alternate include: 1. New headworks with fine mechanical screens and space for a future unit. 2. New pump station with standby generator to pump to the Six Mile Creek Interceptor. 3. Odor control system for headworks. 4. Purchase a total of 3.0 mgd of capacity from CMUD at a cost of $16,526,000. The project cost to provide the facilities for 3.0 mgd of capacity, including the pump station and force main to Six Mile Creek, are estimated at approximately $26.0 Million. This includes current and anticipated capital charges to CMU. The 20-year present worth of this alternate is $43.9 Million. 6. EVALUATION The three alternates have been evaluated on the basis of capital cost and present value of cost. The basis for the evaluations and results are discussed below. Capital cost estimates were developed for each alternate, taking into account the appropriate improvements and facilities which will be required. Key considerations include: a. The cost of expansion at the Twelve Mile Creek site was estimated by considering all items needed to parallel the existing process units. There were no improvements needed to meet current NPDES limits. b. O&M costs were estimated considering both fixed and variable costs. Current O&M is estimated at about $1.77 per thousand gallons, exclusive of debt repayment. By 2014, as flows increase, the treatment cost will be reduced to about $0.84 per 1,000 gallons. c. The capital cost to use land application will be highly dependent on actual land costs. Land in the immediate vicinity of the treatment plant has sold for nearly $45,000 per acre. This analysis assumes that land can be purchased at $10,000 per acre within ten (10) miles of the site. The estimated capital cost is about $41.1 Million. d. The capital cost to discharge into the CMU system includes the cost to construct the pumping system ($9.44 Million), plus the purchase of capacity in the CMU system, which is estimated at about $16.53 Million. The current treatment charge is $0.66 per 1,000 gallons. The capital costs of each alternate are summarized in Table 4. Table 4 Estimated Capital Costs Alternate Phase 1 1. Expand Twelve Mile Creek WWTP $12,289,000 2. Land Application $47,119,000 3. Pump to CMU $25,970,000 The capital costs range from $12.3 Million to $47.1 Million, and the alternate with the lowest capital cost is expansion of the Twelve Mile Creek WWTP. The "present value of cost" includes capital costs, O&M, and salvage values, all expressed as 20-year present worth. The present worth of these alternates is shown in Table 5. Table 5 20-Year Present Value of Costs Alternate Amount 1. Expand Twelve Mile Creek WWTP $36,749,000 2. Land Application $57,247,000 3. Pump to CMU $43,851,000 The present value of costs ranges from $36.7 Million to $57.2 Million, with expansion of the Twelve Mile Creek WWTP having the lowest capital cost and 20- year present value. Land application has the highest present value due largely to the high cost of land and the distance from the current treatment facility to suitable sites. There are significant differences in the capital cost between plant expansion and pumping into the CMU system. In addition, CMU is currently making major improvements to its McAlpine Creek WTP, which will result in higher O&M costs to Union County. Since the impact of these added costs are not yet determined, the present worth analysis is based on current data. Thus, as O&M for treatment by CMU increases, the differential in present worth will also increase, further validating the option of plant expansion. Based on the numerical "spread" in the present value of each alternate, minor refinements of capital and O&M costs will not change the ranking of the alternates. Clearly, expansion of the Twelve Mile Creek WWTP is the most cost effective alternate available to Union County. 7. SELECTED ALTERNATE The selected alternate to meet the treatment capacity needs is to expand the existing Twelve Mile Creek treatment plant. This alternate has the lowest capital costs and present value of cost of the three alternates evaluated. This alternate will involve the following construction: a. New headworks with fine mechanical screening and odor control facilities. Two (2) screens will initially be installed, and space for a third future unit provided. Modifications to the influent pumps will include replacing three (3) existing pumps, sized so that any two (2) can meet the peak hydraulic rate of 15 mgd. A new 24-inch force main will parallel the existing 16-inch pipeline. An odor control system will be provided for the headworks and pumping station; and a 'new 750 kW standby generator will provide backup power. b. Expansion of the biological treatment system will require construction of two (2) Carrousel® A2C oxidation ditch systems, which include a fermentation zone, an anoxic zone, and an aerobic oxidation ditch. The configuration of the Carrousel® reactors will duplicate the existing two units. The biological system is sized to meet NPDES limits for BOD reduction, effluent NH3-N, and effluent total phosphorous. c. Improvements also include two (2) secondary clarifiers with return and waste sludge pumping, and two (2) shallow bed automatic backwash effluent filters. UV disinfection will be expanded with the addition of a second reactor. d. Waste sludge facilities will include an additional 1. million gallon aerobic digester. Land application of stabilized sludge will be used. e. Other site improvements include a flow distribution structure ahead of the Carrousel® reactors and piping intended to facilitate uninterrupted operations and future expansion. A 750 kW emergency generator will allow uninterrupted of all critical process units. Finally, the existing grit removal system will be retrofitted with an odor control system. These improvements are shown in Section H.12 "Exhibits" on Figure 5, a proposed site plan for the Twelve Mile Creek WWTP expansion. 8. WASTEWATER REUSE Union County operates two (2) wastewater facilities capable of producing "reuse quality" wastewater on a consistent basis, although the County does not have permits for or the ability to provide reuse water. Union County recognizes the benefits of providing reuse water when opportunities exist. To identify potential opportunities, the Union County Public Works Department has formed a Reuse Committee consisting of the Assistant to the County Manager, the Public Works Director, and an Assistant Public Works Director. The Reuse Committee is currently exploring the possibility of providing reuse water to a mixed use development project for a site adjacent to the Twelve Mile Creek wastewater treatment plant. Potential uses would be for irrigation of landscaped areas, and common open spaces. This application would require Union County to obtain a "Reuse Water Permit" from NCDENR. While the actual quantity of reuse water would initially be very limited, establishing an ongoing program to promote reuse is a positive initiative. North Carolina Wildlife Resources Commission Charles R. Fullwood, Executive Director MEMORANDUM TO: Alex Marks, SEPA Coordinator Diyission of Water Quality 4 FROM: Shari L. Bryant, Piedmont Region Coordinator Habitat Conservation Program DATE: 1 July 2004 SUBJECT: Twelve Mile Creek Wastewater Treatment Plant Expansion Project, Waxhaw, Union County, North Carolina, DENR Project No. 1250 Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject document and we are familiar with the habitat values of the area. Our comments are provided in accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.), the North Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; 1 NCAC 25), and the North Carolina General Statutes (G.S. 113-131 et seq.). Union County Public Works Department is proposing to expand their Twelve Mile Creek Wastewater Treatment Plant (WWTP) in Waxhaw, NC. The WWTP is currently permitted to discharge 2.5 MGD and the proposed expansion will increase the total capacity of the plant to 6.0 MGD. Secondary and cumulative impacts resulting from future growth in the area have the potential to be even more significant than direct im acts. Union County is developing a Stormwater Discharge and Quality Control r inance t at wi meet the requirements of EPA Phase II requirements. The ordinance includes a requirement for riparian buffers for all perennial and intermittent streams, ponds, wetlands and lakes in the county. However, the table in the draft ordinance did not provide specific information regarding proposed riparian buffer widths. Union County is proposing the following "Countywide" (not including the US 74 Bypass area or Goose/Duck/Waxhaw Creeks) riparian buffers. Drainage Area Stream Type Streamside Upland Total <640 acres Intermittent Perennial 30 feet 30 feet 0 feet 20 feet 30 feet 50 feet >640 acres 50 feet 50 feet + 85% of remaining flood fringe 100 feet + 85% of remaining flood fringe The coun is .ro.osin_ a 30-foot wide streamside undisturbed forested buffer ra . - than a 35- foot bu er (20- oot streamside and 15- oot upland) for intermittent streams as outlined in our previous Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721 'Telephone: (919) /33-3633 ext. 281 • 1-ax: (919) /15-/643 Page 2 I July 2004 Twelve Mile Creek WWTP Project No. 1250 correspondence (Bryant, 4 March 2004). Additionally, the county has agreed to on -site stream type determination by a professional. The County anticipates the ordinance to be in effect this summer pending approval of the County Board of Commissioners Additionally, as outlined in our correspondence to Ms. Christie Putnam (19 April 2004), these riparian buffers should apply to all new development within the Twelve Mile Creek WWTP service area as follows: 1. Development plans that have not been submitted for review prior to the adoption of these riparian buffers would be required to include the riparian buffers outlined above. 2. New development plans that have been approved by the County, but for which construction has not begun within two years following adoption of these riparian buffers. In this instance, these development plans would need to be resubmitted to the County for approval and would be required to include the riparian buffers outlined above. We appreciate the effort the County has put forth to develop riparian buffers to protect aquatic and terrestrial habitat within the Twelve Mile Creek WWTP service area. While we still feel that there are wildlife, fisheries and aquatic habitat issues that need to be resolved regarding the proposed riparian buffer widths for the Transportation Corridor (U.S. 74 Bypass area) and for Goose, Duck and Waxhaw Creek watersheds, these riparian buffers do not apply to the service area of the proposed expansion of the Twelve Mile Creek WWTP. Therefore, we have no further comments on this project. We are encouraged by the proactive measures that Union County is taking to protect aquatic and terrestrial wildlife habitat. However, we encourage the County to consider integrating additional meas to address issues of dev,s12pment and its impact on fish and wildlife habitat. opting s that protect wide forested riparian corridors and the 100-year fibVplitithatad uately treat stormwater in develo ment areas in and outside of water supply areas are essential to ro ton of water uali aquatic habitat in deve opmg an cap . easures to mitigate secondary an cumulative impacts can be found m the ui ce emorandum to Address and Mitigate Secondary and Cumulative lmpacts to Aquatic and Terrestrial Wildlife Resources and Water Quality (NCWRC 2002). Thank you for the opportunity to provide input in the early planning stages for this project. If we can be of further assistance, please contact our office at (336) 449-7625. Literature cited NCWRC (North Carolina Wildlife Resources Commission). 2002. Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water Quality. NCWRC, Raleigh. Available: http://www.ncwildlifc.org/pg07 WildlifeSpccicsCon/pg7c3_impacts.pdf. (accessed May 2004). cc: Christie Putnam, PE, Union County Melba McGee, OLIA Mark Cantrell, USFWS E-mail: Sarah McRae, NHP Ryan Heise, WRC Rob Nichols, WRC Stream Classifications for FPG Compliance The FPGs define a stream as "a body of concentrated flowing water in a natural low area of the land surface" (15A NCAC1I.O101-.0209). The FPGs further define three types of streams as follows. Ephemeral Streams An ephemeral stream is defined as "a stream that flows only during and for short periods following precipitation and flows in low areas that may or may not have a well-defined channel." Some commonly used names for ephemeral streams include: stormwater channel, drain, swale, gully, hollow, or saddle. Ephemeral streams do not require an SMZ and usually do not have a defined channel. However, it is strongly encouraged that skid trails, roads, site -prep, and other soil -disturbing activities be minimized in the ephemeral streams to avoid erosion and sedimentation of stormwater runoff that will flow downstream into streams or waterbodies. Intermittent Streams An intermittent stream is defined as "a stream that flows only during wet periods of the year (30% - 90% of the time) and flows in a continuous well-defined channel." During dry periods, especially in summer months, intermittent streams may go down to a trickle of water and make it appear dry, when in fact there is water flowing through the stream bottom or "substrate". This is usually caused by the seasonal changes of the local soil water table or during periods of long term drought. Perennial Streams Perennial streams are streams "that flow throughout a majority of the year (greater than 90% of the time) and flow in a well-defined channel." However, perennial streams can still 'dry up', particularly during extended periods of drought. Therefore when classifying stream type, it is important to check appropriate map resources and seek assistance from a professional who has been trained in stream determination. Ecotone: A habitat created by the juxtaposition of distinctly different habitats; an edge habitat; a zone of transition between habitat types (Ricklefs 1979:869) or adjacent ecological systems having a set of characteristics uniquely defined by space and time scales and by the strength of the interactions (Hansen and diCastri 1992:6) (see Boundary). Edge effect: (1) Changes in a community due to the rapid creation of abrupt edges in large units of previously undisturbed habitat (Reese and Ratti 1988:127); (2) Tendency for increased variety and density of organisms at community or habitat junctions (Odum 1971:157). Edge species: Species preferring the habitat created by the abutment of distinctive vegetation types (Ricklefs 1979:869). Page 1 of 2 Sid Riddick From: Alex Marks [alex.marks@ncmail.net] Sent: Friday, December 12, 2003 3:22 PM To: Sid Riddick Subject: 12 Mile EA Sid, Good to speak with you this morning. As we discussed, please find below additional Division of Water Quality comments/notes on the 12 Mile WWTP Expansion draft EA. Additional comments from the Division's NPDES permitting unit are at the bottom of the page. I suggest contacting Mark McIntire directly should you have any questions regarding his comments. 1. Within Section A or a new section provide a detailed description of the governmental jurisdictions to be served by the project, including Union County inluding the size of each jurisdiction and population statistics (current and future projection). 2. Section D: Amend so that each characteristic includes a discussion of the characteristics of the entire project area not just the project site. Under Water Resources include a list and description of all waterbodies within the service area. Under "Land Use" a discussion pertaining to the amount of vacant, developable land would be helpful if data is available. 3. Page 30: How will wetlands not associated with stream channels be protected under the Union County stormwater ordinance? 4. Section F: In order for the Division of Water Quality to reach a conclusion that the project will not have a significant impact on the environment, mitigation measures to be employed by all governmental jurisdictions served by the project must be described. Include a discussion of any or all local government programs to protect/conserve open space, restrict development within floodplains, protect or enhance water quality, etc. Describe all measures in detail and provide excerpts from ordinances and codes as applicable in the appendix. Additionally, please provide more specific descriptions of the local government smart growth regulations already included. For example, additional detail about the cluster development and open space provisions of the Weddington and Union County ordinances is needed - How is development clustered within a development? How is open space defined and located? 5. Provide figures which illustrate the water resources and conservation areas within the service area 6. Figure 4: Illustrate boundaries of the municipalities to receive service from the project. Focus should be the 12 Mile WWTP service area, suggest illustrating but not highlighting other areas. Please include a copy of this and all correspondence generated in the document's Appendix. Please contact me at 919-733-5083 ext. 555 or by email at Alex.Marks@ncmail.net if you need any further assistance or have questions. I look forward to our meeting next week. Sincerely, Alex Marks 7/6/2004 Page 2 of 2 ************** Alex, I've reviewed the 12 Mile Creek EA and have one major comment pertaining to the alternatives analysis. As you know, we require folks proposing new facilities or expansions to existing facilities to evaluate alternatives to a surface water discharge. All other things being equal, the 20-year present value cost analysis becomes the deciding factor in determining whether or not we'll issue an NPDES permit. In this case, connection to the CMU collection system is less than 8% more than expansion of the 12 Mile Creek facility. Our rule of thumb is generally 10%. In other words, where a non -discharge alternative is less than 10% more than the proposed discharge, we push the non -discharge option...in this case the "non -discharge" option is in fact a discharge, but a regionalized one. These folks need to go back to their analysis and refine the costs for the expansion alternative and the CMU connection alternative so that we can get a better feel for the difference in cost between these two options. I'll also say that we'll need to make some sort of judgement as to where we'd rather have these folks discharging. There's little question that spray irrigation is out because of the volume of wastewater we're talking about and the price of land in that part of the state. The growth figures seem reasonable given the proximity to Charlotte. Because the costs are so close, we'll need to decide if we'd rather have them discharging to the CMU collection system and ultimately to the McAlpine Creek WWTP or operating an expanded facility and discharging to 12 Mile Creek. Let me know if you need anything else. Mark 7/6/2004 t, 0 Subject: RE: union county, 12 mile creek From: "Sid Riddick" <SRiddick@mckimcreed.com> Date: Thu, 2 Oct 2003 16:14:08 -0400 To: "Mike Templeton" <mike.templeton@ncmail.net> Mike, Initially I didn't see any problem with your suggestion to do a 20-yr PW for the expansion to 6 MGD. However, the projected flows in 20 yrs exceed 6 MGD. For the purpose of the PW analysis, we could estimate the O&M for a flow of 6 MGD and apply that in the series gradient to whatever year we hit 6 MDG (year 2018 or 14 years from now) and assume for the purpose of this PW that the flow and resulting O&M remains constant from then until the end of the 20-yr planning period. I agree, no matter what alt is selected now, it won't just go away in 14 or 15 years, so the approach above should be valid. Comments? Sid R Original Message From: Mike Templeton[mailto:mike.templeton©ncmail.net] Sent: Thursday, October 02, 2003 11:26 AM To: Sid Riddick Subject: Re: union county, 12 mile creek Sid - My inclination is to run a 20-year analysis. I'm trying to catch Dave in case we've dealt with this same issue elsewhere. I'll let you know what I find but, unless you would argue for the 10-year, go ahead with the 20. Let me know if you have any particular points I should share with Dave. I'm assuming that, once the expansion to 6 MGD is completed (whichever alternative is chosen), the new facility will remain in service for the 20-year planning period and not be removed at the 10-year point. We would then handle any expansion beyond 6 MGD separately. We normally do not like to break down projects within the same planning period, but I don't see a way around it in this case. Is my assumption a fair one? How does the project life affect the relative costs of the County's alternatives? - Mike T Sid Riddick wrote: >Mike, > >With regards to your instructions that we must limit the discussion of alts in the EAA to a total capacity of 6 MGD, what should we do with the present worth analysis? Since 6 MGD is really only a 10-yr solution, do we do a 10-yr PW analysis as well? > >We are starting the changes, so a quick response would be appreciated. > >Thanks, >Sid > oFwar,4 O ' QG >� r Michael F. Easley, Govemor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality May 29, 2003 Mr. William S. Riddick, Jr., P.E. McKim and Creed, PA 2300 Sardis Road North, Suite A Charlotte, NC 28227 D1 { ( _11 __S 1 t5 � , L MAY 3 0 2003 Subject: Draft Environmental Assessment: 12 Mile Creek Wastewater Treatment Plant Expansion (May 2003) DWQ# 13283 Dear Mr. Riddick: The Division of Water Quality (Division) has concluded its completeness review of the subject document. In July 2002, scoping documents for the project were received and subsequently commented on by the Division and other agencies within the North Carolina Department of Environment and Natural Resources (DENR). Copies of the resulting agency comments are attached for inclusion in the appendix of the Environmental Assessment (EA). Please review them and revise the document as necessary. Although the Division requested its inclusion (see Division's scoping letter), a copy of the NPDES unit's speculative waste limits (SWL) response is not in the appendix. Furthermore, the SWL response indicated that the Division would only provide limits for 6.0 MGD. The EA on page three states that the current proposal is for the plant to increase its operating capacity to 12.0 MGD. Please contact and work with the Division's NPDES unit to resolve permitting issues and the plant's SWL prior to submitting a revised EA. The unit can be reached at (919) 733-5083 ext. 520. Please find a copy of the SWL letter attached. Additionally, please revise the EA to address the items identified below: 1. Although raised in the SWL and Division's scoping comments, the EA does not discuss the project's discharge impacts to waters in the South Carolina. 2. What is the size of the project's service area? 3. What are the local governments served by the project? 4. Section D: In addition to the project site, address and clearly distinguish existing resources throughout the service area. Within the "Land Use" discussion provide a description of land use types and percentages for each local government in the project's service area. The discussion of streams in the "Water Resources" discussion focuses only on streams that will receive discharges from the WTPP. N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 isICDENIt Customer Service 1 800 623-7748 12 Mile Page 2 5. Section E: Considering its size, indirect secondary and cumulative impacts associated with growth and development may result from this project. In general, this section of the document considers only the direct environmental impacts of the project. Revise the document to address indirect impacts throughout the project's service area. 6. Section F: Mitigation measures for a majority of the natural resources and features have been left out. Note that adequate mitigation of significant impacts must be provided to support a Finding of No Significant Impact and that compliance with existing state regulations may not equate to insignificant impacts. In the event that existing state and local programs do not provide adequate mitigation, additional local protection may need to be considered at both the city and county level. Emphasis should be placed on actual implementation of mitigation measures. 7. Section H: Illustrate the actual boundaries of the project's service area on Figures One and Two. As noted in the Division's scoping letter, streams at the project site and within the service area need to be identified. Figure Three does not show the location of the WWTP or the boundaries of the property. 8. Add a section describing any permits to be obtained for the project. 9. Include this letter and all future agency correspondence in the Appendix. After NPDES unit's issues have been resolved and the EA has been revised accordingly, submit ten copies to me for internal review by the Department of Environment and Natural Resources. Issues identified during the Departmental review will need to be addressed prior to State Clearinghouse circulation. Feel free to contact me at 919.733.5083 x555 or by email at Alex.Marks@ncmail.net if you need any further assistance. Sincerely, Alex Marks, AICP Environmental Specialist cc: Dave Goodrich — DWQ (w/o attachments) Attachments UNION COUNTY PUBLIC WORKS DEPARTMENT Jon C. Dyer, P.E., Director March 31, 2003 APR - 1 2003 Mr. David A. Goodrich NPDES Supervisor NC DENR Division of Water Quality 1617 Mail Service Center Raleigh, N. C. 27699-1617 RE: NPDES Permit Modification Permit No. NC 0085359 Twelve Mile Creek Wastewater Treatment Plant Dear Mr. Goodrich: This will confirm our discussions regarding Union County's intent to increase the Twelve Mile Creek Wastewater Treatment Plant Permit Flow from 2.5 mgd to 6.0 mgd. The County has authorized McKim & Creed, PA to assist with the NPDES Permit activities, and the preparation of contract documents for the expanded plant. McKim & Creed has submitted the Engineering Alternatives Analysis for the permit expansion. We respectfully request that your staff review this document promptly, and provide questions or comments so that our engineer may respond in a timely fashion. If you have any questions regarding their authorization to perform these services or the Engineering Alternatives Analysis, please contact me at 704-296- 4212. Respctfully, C. Dyer, PE (Datector of Publ. Works cc: William S. Riddick, Jr., PE Senior Project Manager McKim & Creed, PA 704-841-2588 400 North Church St. . Monroe, North Carolina 281 12-4804 . Phone: (704) 296-4210 . Fax: (704) 296-4232