Loading...
HomeMy WebLinkAboutNC0024325_Permit (Modification)_20101105NPDES DOCUMENT :;CANNING COVER SHEET NC0024325 North Buffalo Creek WWTP NPDES Permit: Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Staff Report Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: November 5, 2010 This document is printed on reuse paper - izore arty content on the reYerse side ern NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue . Coleen H. Sullins Dee Freeman Governor Director Secretary November 5, 2010 Mr. Allan Williams, Director of Water Resources City of Greensboro 2199 White Street Greensboro, NC 27405 Subject: Issuance of NPDES Permit Modifications Permits NC0024325 and NC0047384 North Buffalo and T.Z. Osborne WWTPs Guilford County Dear Mr. Williams: Consistent with the Director's October 1, 2009, letter of intent to modify NPDES permits affected by the Jordan Reservoir Nutrient Management Strategy rules and Greensboro's subsequent request for further permit modification, and in consideration of public comments on the draft permits, the Division is forwarding herewith the revised NPDES permit for the North Buffalo and T.Z. Osborne WWTPs. This permit modification is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007. The Division received no comments other than those provided by the City. The enclosed permits include the following changes as proposed: • Total Phosphorus (TP) Limits. Phosphorus limits have been removed from Condition A.(1.) of each permit. A new Condition A.(2.) describes the combined TP limit for the two facilities and how it will be administered. Other nutrient -related conditions of the permit have been modified as necessary. Each facility will continue to monitor and report its nutrient discharges individually, and we propose that the City report the combined load once each year, with the December monitoring report for one plant. Phosphorus limits in the Jordan Lake watershed became effective January 1, 2010, according to the wastewater rule. • Standard Permit Conditions. Several minor errors have been corrected, and all changes from Part IV that are not supported by existing state or federal ru,Jes have been reversed. • Treatment Process Description. The process descriptions on the Supplement to Cover Pages for both plants have been modified as the City requested. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64921 Customer Service:1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer 1V�o e Carolina �turu!!ff Mr. Allan Williams, Director of Water Resources Issuance of NPDES Permit Modifications November 5, 2010 • Nitrogen Optimization. The previous draft permit included a new condition pertaining to nitrogen optimization requirements from the wastewater rule. That compliance date has passed, and the proposed condition has been deleted from the permit. • Nutrient Re -opener. The nutrient monitoring re -opener from the previous permit pertained to monitoring in preparation for the Jordan Lake study. It is no longer necessary and has been deleted from the permit. • Total Residual Chlorine Footnote. A footnote has been added to Condition A.(1.) indicating that the Division considers the compliance level for TRC to be 50 ug/ L. All lab values must still be reported but, for compliance purposes, values below 50 ug/L meet the facility's TRC limit. In the most recent review, the City noted an improper citation on page 16 of the standard conditions, and that citation has also been corrected. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. This permit is not transferable except after notice to the Division of Water Quality. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other federal or local governmental permit. If you have any questions concerning this permit, please contact Mike Templeton at (919) 807-6402 or at mike:templeton@ncdenr.gov. far Sincerely, Coleen H. Sullins Enclosure: Final permit modifications, NC0024325 and NC0047384 Copies: Chief, NPDES and Biosolids Permits Section, Region IV, EPA Winston-Salem Regional Office, Surface Water Protection Aquatic Toxicity Unit NPDES Files Central Files Permit No. NC0024325 • STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the City of Greensboro is hereby authorized to discharge wastewater from a facility located at the North Buffalo WWTP 2199 White Street, Greensboro Guilford County to receiving waters designated as North Buffalo Creek in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11, III, and IV hereof. ' • This permit shall become effective December 1, 2010. This permit and authorization to discharge shall expire at midnight on June 30, 2011. Signed this day November 5, 2010. oleen H. Sullins, Director x Division of Water Quality By Authority of the Environmental Management Commission Permit No. NC0024325 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no Ionger effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, " terms, and provisions included herein. The City of Greensboro is hereby authorized to: 1. Continue to operate an existing 16.0 MGD activated sludge wastewater treatment facility located at the North Buffalo Creek WWTP (2199 White Street, Greensboro, Guilford County). This facility includes the following treatment components: • Mechanical bar screens • Influent flow measurement (Parshall flume and magnetic flow meter) • Aerated grit removal • Four primary settling tanks • 80 MGD flow transfer pump station to TZ Osborne From here the flow continues through one of the following treatment trains: Original Train • Two trickling filters (currently not in use) • Activated sludge with nitrification (4 aeration basins with fine bubble diffusers) • Step feed process (optional) • Chemical addition for phosphorus removal • Five secondary clarifiers #2 Train Activated sludge with nitrification (1) Secondary clarifiers (2) The flows from the two separate trains come together and continue through the following treatment processes: • Four tertiary sand filters • Effluent flow measurement (Parshall flume) • Chlorination ,y • Effluent aeration 2. Discharge from said treatment works (via Outfall 001) into North Buffalo Creek, a Class C-NSW stream in the Cape Fear River Basiri, at the location specified on the attached map. • ii USGS Quad #: C20SW Lat. 36° 06' 34" Long. -79° 44' 53" SCALE 1:24,000 (1" = 2000') City of Greensboro — North Buffalo WWTP NC0024325 County: Guilford Receiving Stream: North Buffalo Creek Stream Classification: C NSW River Basin: Cape Fear Sub -Basin #: 03-06-02 111 Permit No. NC0024325 A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Outfall 001 During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge treated wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: FFLUENT CHARACTERISTICS EFFLUENT'LIMITATIONS _ = MONITORINGREQUIREMENTS -F _ _ __ _ _____-=. _ _ _ _ Monthly Avera9e _ .: _� Weekly Average ; _ t Daily { Maximum Measurement Frequency $ample Type: , f� i t r �. 1 = Sample Loca#lon Flow 16.0 MGD Continuous Recording Influent or Effluent Total Monthly Flow (MG) Monitor & Report Monthly Rec. or Calc. Influent or Effluent CBOD, 5-day, 20°C (Summer)2 8.0 mg/L 12.0 mg/L Daily Composite Influent & Effluent CBOD, 5-day, 20°C (Winter)2 16.0 mg/L 24.0 mg/L Daily Composite Influent & Effluent Total Suspended Solids2 30.0 mg/L 45.0 mg/L Daily Composite Influent & Effluent NH3 as N (Summer) 4.0 mg/L 12.0 mg/L Daily Composite Effluent NH3 as N (Winter) 8.0 mg/L 24.0 mg/L Daily Composite Effluent Fecal Coliform (geometric mean) 200/100mL 400/100mL Daily Grab Effluent Dissolved Oxygen 3 Daily Grab Effluent Temperature (°C) Daily Grab Effluent pH 4 Daily Grab Effluent Total Residual Chlorine 5 17.0 pg/L Daily Grab Effluent TKN Monitor & Report (mg/L) Weekly Composite Effluent NO3-N + NO2-N Monitor & Report (mg/L) Weekly Composite Effluent Total Nitrogen, TN 6 Monitor & Report (mg/L) Weekly Composite Effluent TN Load's Monitor & Report (Ib/mo) Monitor & Report (Ib/yr) Monthly Annually Calculated Effluent Total Phosphorus, TP Monitor & Report (mg/L) Weekly Composite Effluent TP Load's$ Monitor & Report (Ib/mo) Monitor & Report (Ib/yr) Monthly Annually Calculated Effluent Total Cyanide 9 5.2 pg/L 22.0 pg/L Weekly Grab Effluent Total Mercury 10 0.012 pg/L Weekly Grab Effluent Total Chromium 51.0 pg/L 1022.0 pg/L Weekly Composite Effluent Total Nickel 91.0 Ng/L 261.0 pg/L Weekly Composite Effluent Fluoride* 1.9 mg/L Weekly Composite Effluent Total Copper 2/Month Composite Effluent Total Zinc 2/Month Composite Effluent Total Iron Monthly Composite Effluent Total Selenium Quarterly Composite . Effluent Chloride Quarterly Composite Effluent Chronic Toxicity 11 Quarterly Composite Effluent Effluent Pollutant Scan See Special Condition A.(4.) Annually Grab/Comp. Effluent Dissolved Oxygen 12 12 Grab U, Di, D2, D3 Fecal Coliform 12 12 Grab U, Di, D2, D3 Temperature (°C) 12 12 Grab U, Di, D2, D3 Conductivity 12 12 Grab U, Di, D2, D3 All footnotes are listed on the following page. PART I, Page 1 of 8 Permit No. NC0024325 Footnotes: (Summer): Apri11- October 31 (Winter): November 1- March 31 (Daily): every day on which a wastewater discharge occurs except Saturdays, Sundays, and legal holidays unless otherwise specified by the Director. 1. U: Upstream at the influent conduit. D1: Downstream at the unimproved road 0.8 miles east of White/Nealtown Road intersection. D2: Downstream at Rankin Mill Road. D3: Downstream in Buffalo Creek at McCleansville Road. 2. The monthly average effluent CBOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The daily effluent dissolved oxygen concentration shall not be less than 6.0 mg/L. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. The Division shall consider all effluent TRC values reported below 50 ug/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 ug/L. 6. TN is Total Nitrogen = TKN + NO3-N + NO2-N, where TKN is Total Kjeldahl Nitrogen, NO3-N and NO2-N are Nitrate and Nitrite Nitrogen, respectively. 7. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period of time. See Special Condition A.(7.), Calculation and Reporting of Nutrient Loads. 8. The facility is subject to nutrient limitations as specified in Special Condition A.(2.), Combined Limitations for Nutrients. 9. The quantitation limit for cyanide shall be 20 µg/L; levels reported below 20 µg/L shall be considered zero for compliance purposes. 10. Effluent samples must be analyzed by an EPA -approved low level mercury analysis method. 11. Chronic Toxicity (Ceriodaphnia) at 90% with testing in January, April, July and October (see Special Condition A. (3.)). 12. Instream monitoring requirements are waived as long as facility retains membership in the UCFRBA. If membership is cancelled, facility will monitor 3/Week (June -September) and 1/Week (October -May). Stream sampling may be discontinued at such times as flow conditions in the receiving waters or extreme weather conditions will result in a substantial risk of injury or death to persons collecting samples. Upon such discontinuance, stream sampling shall be resumed at the first opportunity after the risk period has ceased. * The limit might be removed if the facility submits 12 month of data that shows no reasonable potential to exceed the water quality standard. There shall be no discharge of floating solids or visible foam in other than trace amounts. PART I, Page 2 of 8 Permit No. NC0024325 A.(2.) COMBINED LIMITATIONS FOR NUTRIENTS — Outfall CO1 (a.) During the period beginning on the dates specified below and lasting until permit expiration, the Permittee is further authorized to discharge Total Nitrogen and Total Phosphorus from the T.Z. Osborne WWTP (NC0047384, Outfall 001) and the North Buffalo Creek WWTP (NC0024325, Outfall 001) subject to the following combined, delivered load limitations: Total Nitrogen, Delivered (Ib/yr)1 Total ;Phosphorus, Delivered (Ib/yr)1 Permit Facility Active Allocations Combined Limit Active Allocations Combined Limit NC0047384 T.Z. Osborne WWTP 290,375 35,708 NC0024325 North Buffalo Creek WWTP 110,698 13,591 401,073 (effective 1/1/2016) Footnote: 49,299 (effective 1/1/2010) 1 Allocations and limits in this table are expressed as delivered loads. See Condition A.(7.) regarding calculation of delivered loads from discharge loads. (b.) Compliance with these limits shall be determined in accordance with Special Conditions A.(6.), Annual Limits for Total Nitrogen and Total Phosphorus, and A.(7.), Calculation and Reporting of Nutrient Loads. (c.) Nutrient monitoring and reporting requirements are specified in Special Conditions A.(1.), Effluent Limitations and Monitoring Requirements, and A.(7.), Calculation and Reporting of Nutrient Loads. (d.) Pursuant to N.C. General Statute Section 143-215.1 and the implementing rules found in Title 15A of the North Carolina Administrative Code, specifically, 15A NCAC 02B.0270, and Part II, Sections B-12 and B-13 of this permit, the Division of Water Quality (Division) may reopen the permits listed above and establish more stringent nutrient limits upon finding that such limits are necessary to prevent the discharges from causing localized water quality impacts in the receiving streams. (e.) The Permittee may request that its permits be modified to rescind these combined limits and establish individual mass discharge limits for each facility. The Division may, after written notification to the Permittee, rescind these combined limits and establish individual mass discharge limits for each facility if it determines that the combined limits do not support the objectives of the Jordan Lake Nutrient Management Strategy. The Division shall provide for public review of the proposed permit modifications and include in the permit an appropriate schedule of compliance for the proposed nutrient limits. PART I, Page 3 of 8 Permit No. NC0024325 A.(3.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July, and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT- 3 (original) is to be sent to the following address: NCDENR/ DWQ/ Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. PART I, Page 4 of 8 Permit No. NC0024325 A.(4.) EFFLUENT POLLUTANT SCAN The Permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the attached table (using a sufficiently sensitive detection level in accordance with 40 CFR Part 136). The Permittee shall perform 3 Effluent Pollutant Scans prior to submitting the permit renewal application. Samples shall represent seasonal variations. Unless otherwise indicated, metals shall be analyzed as "total recoverable." Ammonia (as N) Chlorine (total residual, TRC) Dissolved oxygen Nitrate/Nitrite Total Kjeldahl nitrogen Oil and grease Total Phosphorus Total dissolved solids Hardness Antimony Arsenic Beryllium Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Thallium Zinc Cyanide Total phenolic compounds Volatile organic compounds: Acrolein Acrylonitrile Benzene Bromoform Carbon tetrachloride Chlorobenzene Chlorodibromomethane Chloroethane 2-chloroethylvinyl ether Chloroform Dichlorobromomethane 1,1-dichloroethane 1,2-dichloroethane Trans-1,2-dichloroethylene 1,1-dichloroethylene 1,2-dichloropropane 1,3-dichloropropylene Ethylbenzene Methyl bromide Methyl chloride Methylene chloride 1,1,2,2-tetrachloroethane Tetrachloroethylene Toluene 1,1,1-trichloroethane 1,1,2-trichloroethane Trichloroethylene Vinyl chloride Acid -extractable compounds: P chloro-m-cresol 2-chlorophenol 2,4-dichlorophenol 2,4-dimethylphenol 4,6-dinitro-o-cresol 2,4-dinitrophenol 2-nitrophenol 4-nitrophenol Pentachlorophenol Phenol 2,4,6-trichlorophenol Base -neutral compounds: Acenaphthene Acenaphthylene Anthracene Benzidine Benzo(a)anthracene Benzo(a)pyrene 3,4 benzofluoranthene Benzo(ghi)perylene Benzo(k)fluoranthene Bis (2-chloroethoxy) methane Bis (2-chloroethyl) ether Bis (2-chloroisopropyl) ether Bis (2-ethylhexyl) phthalate 4-bromophenyl phenyl ether Butyl benzyl phthalate 2-chloronaphthalene 4-chlorophenyl phenyl ether Chrysene Di-n-butyl phthalate Di-n-octyl phthalate Dibenzo(a,h)anthracene 1,2-dichlorobenzene 1,3-dichlorobenzene 1,4-dichlorobenzene 3,3-dichlorobenzidine Diethyl phthalate Dimethyl phthalate 2,4-dinitrotoluene 2,6-dinitrotoluene 1,2 diphenylhydrazine Fluoranthene Fluorene Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclo-pentadiene Hexachloroethane Indeno (1,2,3-cd)pyrene Isophorone Naphthalene Nitrobenzene N-nitrosodi-n-propylamine N-nitrosodimethylamine N-nitros o diphenylamine Phenanthrene Pyrene 1,2,4-trichlorobenzene Test results shall be reported to the Division in DWQ Form- DMR-PPA1 or in a form approved by the Director within 90 days of sampling. The report shall be submitted to the following address: NCDENR/ DWQ/ Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 PART I, Page 5 of 8 Permit No. NC0024325 A.(5.) NUTRIENT ALLOCATIONS (a.) The following table lists the Total Nitrogen (TN) and Total Phosphorus (TP) allocations assigned to, acquired by, or transferred to the Permittee in accordance with the Jordan Lake nutrient management rule (T15A NCAC 02B .0270) and the status of each as of permit issuance. For compliance purposes, this table does not supersede any TN or TP limit established elsewhere in this permit or in the NPDES permit of a compliance association of which the Permittee is a Co- Permittee Member. Total Nitrogen Allocation ALLOCATION . TYPE SOURCE ; - DATE:: ALLOCATION AMOUNT 1`• 'STATUS ,{ Delivered (Ib/yr) Discharge '(iti/yr) Base Assigned by Rule (T15A NCAC 02B .0270) 8/11/09 110,698 257,438 Active TOTAL 110,698 257,438 Active Footnote: 1 Nitrogen Transport Factor = 43% Total Phosphorus Allocation c. ALLOCATION" TYPE ALLOCATION .AMOUNT.1 Base Assigned by Rule (T15A NCAC 02B .0270) 8/11/09 13,591 32,359 Active TOTAL 13,591 32,359 Active Footnote: 1 Phosphorus Transport Factor = 42% (b.) Any addition, deletion, or modification of the active allocation(s) listed above (other than to correct typographical errors) or any change of allocation to 'active' status shall be considered a major modification of this permit and shall be subject to the public review process afforded such modifications under state and federal rules. PART I, Page 6 of 8 Permit No. NC0024325 A.(6.) ANNUAL LIMITS FOR TOTAL NITROGEN AND TOTAL PHOSPHORUS (a.) Total Nitrogen (TN) and Total Phosphorus (TP) allocations and load limits for NPDES dischargers in the Jordan Lake watershed are annual loads and apply on a calendar year basis. (b.) For any given calendar year, the Permittee shall be in compliance with the annual TN (or TP) Discharge Load limit in this Permit if: (i.) the Permittee's annual TN (or TP) Discharge Load is not greater than the effective limit, or (ii.) the Permittee is a Co-Permittee Member of a compliance association. (c.) The TN (or TP) limit in this Permit may be modified as the result of allowable changes in the Permittee's allocation. (i•) Allowable changes include those resulting from purchase of TN (or TP) allocation from an authorized mitigation banker, the Ecosystem Enhancement Program, or other source allowed under applicable regulations; purchase, sale, trade, or lease of allocation between the Permittee and other dischargers; regionalization; and other transactions approved by the Division. The Permittee may request a modification of the TN (or TP) limit in this Permit to reflect allowable changes in its allocation(s). (A) Upon receipt of timely and proper application, the Division will modify the permit as appropriate and in accordance with state and federal program requirements. (B) Changes in TN (or TP) limits become effective on January 1 of the year following permit modification. The Division must receive application no later than August 31 for changes proposed for the following calendar year. Any requests for modification should be sent to: NCDENR/ DWQ/ NPDES Programs Attn: Jordan Lake Watershed Coordinator 1617 Mail Service Center Raleigh, NC 27699-1617 (d.) If the Permittee is a member and co-permittee of an approved compliance association on January 1 of a given year, its TN and TP discharges during that year are governed by that association's group NPDES permit and the limits therein. The Permittee shall be considered a Co-Permittee Member for any given calendar year in which it is identified as such in Appendix A of the association's group NPDES permit. Association roster(s) and members' TN and TP allocations will be updated annually and in accordance with state and federal program requirements. If the Permittee intends to join or leave a compliance association, the Division must be notified of the proposed action in accordance with the procedures defined in the association's NPDES permit. (A) Upon receipt of timely and proper notification, the Division will modify the permit as appropriate and in accordance with state and federal program requirements. (B) Membership changes in a compliance association become effective on January 1 of the year following modification of the association's permit. (e.) The TN and TP monitoring and reporting requirements in this Permit remain in effect throughout the term of the Permit and are not affected by the Permittee's membership in a compliance association. PART I, Page 7 of 8 Permit No. NC0024325 A.(7.) CALCULATION AND REPORTING OF NUTRIENT LOADS The Permittee shall calculate and report monthly and annual nutrient loads for the T.Z. Osborne (NC0047384) and North Buffalo Creek (NC0025325) WWTPs as follows: (a.) Calculation of Discharge Loads: The Permittee shall calculate monthly and annual discharge loads for each facility as follows: (i.) Monthly Discharge Load (lb/ mo, TN or TP) = TN (or TP) x TMF x 8.34 where: TN (or TP) = the average Total Nitrogen (or Total Phosphorus) concentration (mg/L) of the composite samples collected during the month TMF = the Total Monthly Flow of wastewater discharged during the month (MG/mo) 8.34 = conversion factor, from (mg/L x MG) to pounds (ii.) Annual Discharge Load (lb/yr, TN or T13) = Sum of the 12 Monthly TN (or TP) Loads for the calendar year Calculation of Delivered Loads: (i.) The Permittee shall calculate delivered loads as follows: (A) Individual, Annual Delivered Load (1b/ yr, TN or TP) = Annual Discharge Load (lb/yr, TN or TP) x TF where TF = Transport Factor, as follows: PERMIT FACILITY TFTM TFrp NC0047384 T.Z. Osbome WWTP 45% 44% NC0024325 North Buffalo Creek WWTP 43% 42% (A) Combined Annual Delivered Load (lb/yr) = Sum of the facilities' Individual Annual Delivered TN (or TP) Loads for the calendar year (c.) Reporting of Nutrient Discharges: The Permittee shall report each facility's monthly TN and TP discharge loads in that facility's discharge monitoring report. (d.) Reporting of Combined Delivered Loads: The Permittee shall report each calendar year's combined delivered loads with the T.Z. Osborne WWTP's December report for that year and shall append the report with a summary of monthly loads and calculations. PART I, Page 8 of 8 Final Permits, 11/5/2010 Narrm CJ.ROUNA DEPARTMENT OF ENVIRONMENT AND NRIAAI Reso. Mces Ar,„;A Fact Sheet - NPDES Permit NCDENR Jordan Lake NPDES Dischargers 4 NPDES Permits PROPOSED PERMIT ACTION The Division proposed to modify four (4) NPDES permits for municipal wastewater treatment facilities in the Jordan Lake watershed of the Cape Fear River Basin. The purpose of the modifications is to set Total Phosphorus discharge limits in accordance with the Jordan Lake Nutrient Management Strategy: Wastewater Discharge Requirements, T15A NCAC 02B .0270. The Division first proposed related modifications for these permits in November 2009 and then modified the draft permits in response to comments from the Permittees. FACILITY INFORMATION The affected facilities are as follows: Permit Owner Facility Receiving Stream County NC0047384 City of Greensboro T.Z. Osborne WWTP South Buffalo Creek Guilford NC0024325 City of Greensboro North Buffalo Creek WWTP North Buffalo Creek Guilford NC0023868 City of Burlington Eastside WWTP Haw River Alamance NC0023876 City of Burlington Southside WWTP Big Alamance Creek Alamance JORDAN LAKE NUTRIENT MANAGEMENT STRATEGY The Jordan Lake Nutrient Management Strategy is a comprehensive set of rules and Session Law that became effective August 11, 2009. The Strategy aims to restore and maintain water quality, protect the lake's classified uses, and maintain or enhance protections currently implemented by local governments in existing water supply watersheds. The Strategy calls for improvements in stormwater management (existing and new development), agricultural practices, fertilizer application management, riparian buffers protection, and wastewater treatment. The Strategy establishes nitrogen and phosphorus allocations for all existing wastewater dischargers that treat nutrient -bearing wastes. For point sources, it specifies that facilities with a permitted flow of 0.1 MGD or greater must meet nutrient limits based on these allocations. The limits for both nitrogen and phosphorus are to be given as annual mass limits. The phosphorus limits become effective in CY2010, the nitrogen limits in CY2016. The figure below shows the watershed and the three subwatersheds. The strategy sets nutrient reduction targets for each subwatershed. PROPOSED MODIFICATIONS The Division proposes to incorporate the new phosphorus limits and related conditions into the affected permits. It intends to add nitrogen limits during the 2011 permit renewals. The proposed permit modifications go beyond adding the phosphorus limits, which were first proposed for the Greensboro and Burlington facilities in November 2009. The revised draft permits propose to apply combined TP limits for each City's wastewater facilities. In each case, the combined limit equals the sum of the City's individual allocations. In order to account for differences in transport losses in transit to Jordan Lake, the combined limits are expressed as delivered (as opposed to discharge) loads. Other nutrient -related conditions in the permits have been modified to reflect this arrangement. The modifications include minor changes as well. Out-of-date Special Conditions (for example, for requirements now completed) have been deleted. PUBLIC COMMENTS Greensboro noted one additional correction in the standard permit conditions, which was corrected. FINAL ACTION The four permits are being issued as proposed, except for the one correction in the standard conditions. < end of text > _ % tpJpMf ("a.k.a.�;'� • �. Haw Subw tershed • B. EVERETT JORDAN LAKE WATERSHED • Slap nepu.a Naemb.r a MOS ,lJpper_New Hope ''Sth5w6tershed OR NOE r J WAKE Lov ve.r: Nei/ Hope S Obate rs hed NUTRIENT ALLOCATIONS - INITIAL ASSIGNMENTS JORDAN RESERVOIR NUTRIENT MANAGEMENT STRATEGY August 2009 UPPER NEW HOPE ARM TMDL Targets: 35% TN reduction 5% TP reduction Transport Allocations - TN Allocations - TP Permit NC0047597 NC0025241 NC0026051 NC0056413 NC0051314 NC0043257 NC0042803 NC0074446 NC0048429 Owner City of Durham Orange Water & Sewer Authority Durham County Whippoorwill LLC North Chatham Water & Sewer Company, LLC Nature Trails Association, CLP Birchwood Mobile Home Park Hilltop Mobile Home Park Cedar Village Apartments Facility South Durham WRF Mason Farm WWTP Triangle WWTP Carolina Meadows WWTP Cole Park Plaza Nature Trails Mobile Home Park WWTP Birchwood Mobile Home Park Hilltop Mobile Home Park Cedar Village Apartments QPmt (MGT)) 20.0 14.5 12.0 0.35 0.050 0.040 0.018 0.012 0.005 TN TP 75% 67% 63% 47% 96% 97% 63% 47% 81% 84% 81% 84% 70% 64% 70% 64% 100% 100% IN at EOP Avg Conc TN to Lake (Ib/yr) EOP(mg/L) (Ib/yr) 185,345 134,375 111,207 3,244 1,826 1,461 658 438 183 3.04 3.04 3.04 3.04 12.00 12.00 12.00 12.00 12.00 139,009 84,656 106,759 2,043 1,479 1,184 460 307 183 TP at EOP (Ib/yr) 14,053 10,188 8,432 246 304 244 110 73 30 Avg Conc TP to Lake EOP (mg/L) (Ib/yr) 0.23 0.23 0.23 0.23 2.00 2,00 2.00 2.00 2.00 9,415 4,789 8,179 116 256 205 70 47 30 46.98 438,736 PS Alloc'n, Ib/yr EOP 3.04 mg/ L TN, Lg 12.00 mg/LTN, Sm PS Alloc'n, Ib/yr at Lake: 336,079 Ib/yr TN, Lg: 332,467 Ib/yr TN Sm: 3,613 Calc'd redxn at Lake: 35.0% 33,680 PS Alloc'n, Ib/yr EOP 0.23 mg/LTP, Lg 2.00 mg/LTP, Sm PS Alloc'n, Ib/yr at Lake: 23,106 Ib/yr TP, Lg: 22,498 Ib/yr TP, Sm: 608 Calc'd redxn at Lake: 5.0% LOWER NEW HOPE ARM Nutrient Reduction Targets: Maintain 1997-2001 baseline loads for TN and TP (0% reduction required, 0% increase allowed). Permit Owner Facility Qpmt (MGD) NC0043559 Fearrington Utilities, Inc. Fearrington Utilities WWTP 0.5 Transport TN TP 84% 88% 0.5 Allocations - TN Allocations - TP TN at EOP Avg Conc TN to Lake (Ib/yr) EOP (mg/L) (Ib/yr) TP at EOP Avg Conc TP to Lake (Ib/yr) EOP (mg/L) (Ib/yr) 8,138 5.35 6,836 566 0.37 498 8,138 PS Alloc'n, Ib/yr EOP 566 PS Alloc'n, Ib/yr EOP 5.35 mg/LTN, Lg N/A ng/ L TN, Sm 0.37 mg/LTP, Lg N/A mg/ L 7P, Sm PS Alloc'n, ib/yr at Lake: 6,836 PS Alloc'n, Ib/yr at Lake: 498 Ib/yr TN, Lg: 6,836 Ib/yrTNSm: N/A lb/yr TP, Lg: Ib/yr7P,Sm: 498 N/A Cak'd redxn at Lake: 0.00/0 Calc'd redxn at Lake: 0.0% M.strient Reduction Targets: 8% TN reduction 5% TP reduction Transport Allocations - TN Allocations - TP Permit Owner Facility Qp (MGD) TN TN at EOP Avg Conc TN to Lake (lb/yr) EOP (mg/L) (Ib/yr) TP at EOP Avg Conc TP to Lake (Ib/yr) EOP (mg/L) (Ib/yr) NC0047384 City of Greensboro T.Z. Osborne WWTP 40.0 45% 44% 643,595 5.29 289,618 80,899 0.66 35,595 NC0024325 City of Greensboro North Buffalo Creek WWTP 16.0 43% 42% 257,438 5.29 110,698 32,359 0.66 13,591 NC0023868 City of Burlington Eastside WWTP 12.0 77% 69% 193,078 5.29 148,670 24,270 0.66 16,746 NC0023876 City of Burlington Southside WWTP 12.0 80% 73% 193,078 5.29 154,463 24,270 0.66 17,717 NC0024881 City of Reidsville Reidsville WWTP 7.5 66% 560/0 120,674 5.29 79,645 15,169 0.66 8,494 NC0021211 City of Graham Graham WWTP 3.5 81% 71% 56,315 5.29 45,615 7,079 0.66 5,026 NC0021474 City of Mebane Mebane WWTP 2.5 56% 55% 40,225 5.29 22,526 5,056 0.66 2,781 NC0020354 Town of Pittsboro Pittsboro WWTP 2.25 76% 82% 36,202 5.29 27,514 4,551 0.66 3,731 NC0066966 Quarterstone Farm Homeowners Assoc. Quarterstone Farm WWTP 0.20 50% 43% 3,218 5.29 1,609 404 0.66 174 NC0003913 Glen Raven Inc Altamahaw Division plant 0.15 58% 49% 2,413 5.29 1,400 303 0.66 149 NC0022691 Chateau Communities, Inc. Autumn Forest Manuf. Home Community 0.082 52% 46% 2,995 12.00 1,558 499 2.00 230 NC0001210 Monarch Hosiery Mills Inc Monarch Hosiery Mills Incorporated 0.050 58% 49% 1,826 12.00 1,059 304 2.00 149 NC0022675 Country Club Communities LLC Birmingham Place 0.043 55% 52% 1,571 12.00 864 262 2.00 136 NC0042285 Traits Property Owners Assoc Trails WWTP 0.040 84% 76% 1,461 12.00 1,227 244 2.00 185 NC0046043 Oak Ridge Military Academy Oak Ridge Military Academy 0.040 46% 41% 1,461 12.00 672 244 2.00 100 NC0077968 Horners Mobile Home Park Horners Mobile Home Park 0.040 58% 49% 1,461 12.00 847 244 2.00 119 NC0042528 B Everett Jordan & Son-1927 LLC B Everett Jordan 1927 LLC 0.036 84% 76% 1,315 12.00 1,105 219 2.00 167 NC0038156 Guilford County Schools Northeast Middle & Senior High WWTP 0.032 52% 46% 1,169 12.00 608 195 2.00 90 NC0073571 Mervyn R. King Countryside Manor WWTP 0.030 42% 38% 1,096 12.00 460 183 2.00 69 NC0029726 NC Department of Correction Guilford Correctional Center WWTP 0.025 36% 34% 913 12.00 329 152 2.00 52 NC0001384 Burlington Industries, Inc Williamsburg plant 0.025 48% 47% 913 12.00 438 152 2.00 72 NC0035866 County of Chatham Bynum WWTP 0.025 84% 76% 913 12.00 767 152 2.00 116 NC0065412 REA Enterprises, LLC Pleasant Ridge WWTP 0.0235 51% 45% 858 12.00 438 143 2.00 64 NC0046809 Pentecostal Holiness Church Pentecostal Holiness Church 0.020 46% 41% 731 12.00 336 122 2.00 50 NC0060259 Willow Oak Mobile Home Park Willow Oak Mobile Home Park 0.0175 51% 45% 639 12.00 326 107 2.00 48 NC0031607 Alamance-Burlington School System Western Alamance Middle School 0.015 64% 58% 548 12.00 351 91 2.00 53 NC0046019 Episcopal Diocese of North Carolina The Summit WWTP 0.015 46% 41% 548 12.00 252 91 2.00 37 NC0045161 Alamance-Burlington School System Altamahaw/Ossipee Elementary School 0.012 58% 49% 438 12.00 254 73 2.00 36 NC0045144 Alamance-Burlington School System Western Alamance High School 0.0115 64% 58% 420 12.00 269 70 2.00 11 NC0038172 Guilford County Schools Mcleansville Middle School WWTP 0.0113 36% 34% 413 12.00 149 69 2.00 23 NC0022098 Cedar Valley Communities LLC Cedar Valley WWTP 0.010 55% 52% 365 12.00 201 61 2.00 32 NC0045152 Alamance-Burlington School System Jordan Elementary School 0.0075 84% 76% 274 12.00 230 46 2.00 35 NC0055271 Shields Mobile Home Park Shields Mobile Home Park 0.006 64% 58% 219 12.00 140 37 2.00 21 NC0048241 Staley Hosiery Mills Staley Hosiery Mills 0.005 74% 65% 183 12.00 135 30 2.00 20 NC0038164 Guilford County Schools Nathanael Greene Elementary School WWTP 0.0045 75% 66% 164 12.00 123 27 2.00 18 NC0036994 Rockingham County Board of Education Monroeton Elementary School 0.0042 42% 38% 153 12.00 64 26 2.00 10 NC0066010 Rockingham County Board of Education Williamsburg Elementary School 0.004 51% 45% 146 12.00 75 24 2.00 11 NC0045128 Alamance-Burlington School System Sylvan Elementary School 0.003 84% 76°/o 110 12.00 92 18 2.00 14 96.74 1,569,542 PS Alloc'n, Ib/yr EOP 198,243 PS AHoc' n, Ib/yr EOP 5.29 mg/ L TN, Lg 0.66 mg/ L TP, Lg 12.00 mg/LTT, Sm 2.00 mg/LTP, Sm PS Alloc'n, Ib/yr at Lake: 895,127 PS Alloc'n, lb/yr at Lake: 106,001 lb/yrTN, Lg: 881,757 Ib/yrTP, Lg: 104,004 Ib/yr TN, Sm: 13,370 Ib/yr TP, Sm: 1,996 Calc'd redxn at Lake: 8.0% Calc'd redxn at Lake: 5.0% Cityr of Greensboro North Carolina October 1, 2010 [via email] Mr. Mike Templeton NCDENR- DWQ Point Source Branch 1617 Mail Service Center Raleigh, N.C. 27699-1617 RE: Comments on NPDES Permit Modifications: NC0024325 North Buffalo WWTP NC0047384 T. Z. Osborne WWTP Dear Mr. Templeton, Water Resources Department The City of Greensboro appreciates the opportunity to comment on the permit modifications to the above listed NPDES permits. Page numbers and section citations are from the draft permits provided via mail and dated 9-1-2010, including Standard Conditions version 7/23/2010. Thank you for your time and effort in developing the combined total phosphorus limit for the two Greensboro POTWs. This flexibility will allow the City to optimize current treatment processes for the reduction of total phosphorus. It will also allow us to transfer additional flow to the facility that provides the greatest incidental removal of total nitrogen. The Industrial Waste Section reiterates our concerns regarding the North Carolina NPDES Industrial Waste Survey language vs. the Federal language/requirements that were detailed in our 1-15-2010 correspondence to your office [Page 16, Section D. 2.] However, these concerns may be more appropriately addressed through the North Carolina Water Quality Association, of which we are a member. We are also including a previous comment from 1-15-2010 about a confusing/incorrect citation: • The requirement that, "The IWS submission shall include a summary of any investigations conducted under paragraph B,2, c, of this Part" does not make sense and evidently has an incorrect citation. There is no paragraph B. 2. c. in the old version or the new version of the NPDES Standard Conditions [Page 16, Section D. 2.] At a future date, we would very much like to discuss the option of a Group Compliance Association, as mentioned in your cover letter. Greensboro has had preliminary discussions with our fellow Haw River dischargers and several are interested in pursuing such an organization. PO Box 3136 , Greensboro, NC 27402-3136 www.greensboro-nc.gov • 336-373-CITY (2489) • TTY# 333-6930 Letter to Mr. Mike Templeton re: NPDES Permit Modifications 10-1-2010 Page 2 If you have any questions or need additional information, please do not hesitate to contact me. We look forward to receiving the final NPDES permit modification documents. Sincerely, Mc rfte, Qroro-wte' Martie Groome Laboratory and Industrial Waste Section Supervisor cc: Allan Williams, Water Resources Director (via email) Don Howard, Water Reclamation Manager (via email) Walter Kling, Operations Superintendant (via email) Ed Osborne, ORC North Buffalo POTW (via email) Sharon Miller, Pretreatment Coordinator (via email) Jeff Poupart, DWQ (via email) Matt Matthews, DWQ (via email) Templeton, Mike From: Hyatt.Marshall@epamail.epa.gov Sent: Tuesday, September 28, 2010 2:43 PM To: Templeton, Mike Subject: NC0024325, North Buffalo WWTP NPDES permit EPA has no comments on this draft permit. AVA RECEIVED N.C. Dent. of ENR NCD NR SEP 0 7 2010 Winstcn•Salem North Carolina Department of Environment and Natural Resources Regional Office Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director MEMORANDUM To: September 1, 2010 Lee Spencer NC DENR / DEH / Public Water Supply Section Regional Engineer Winston-Salem Regional Office From: Mike Templeton Point Source Branch/ NPDES Dee Freeman Secretary L71 LT1 Subject: Review of Draft Permit NC0024235 SE P 2 2r Greensboro - North Buffalo Creek WWTP 1 ........,:ir:A: Guilford County Please indicate below your agency's position or viewpoint on the draft permit and return this form October 4, 2010. If you have any questions on the draft permit, please contact me at 919-807-6402 or mike. ternpleton@ncden r.gov. ****************************************************** RESPONSE: (Check one) Concurs with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Concurs with issuance of the above permit, provided the following conditions are met: Opposes the issuance of the above permit, based on reasons stated below or attached: Signed 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64921 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity \ Affirmative Action Employer Date 7/2-(//u NorthCarol ina Naturally News & Record Name Published by News & Record, Inc. Greensboro, North Carolina North Carolina, Guilford County Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to administer oaths, personally appeared the Publisher's Representative who being first duly sworn, deposed and says: AFFIDAVIT OF 1. That he/she is the Publisher's Representative of the Greensboro News & Record, Inc. a corporation, engaged in the publication of newspapers known as "News & Record", published, issued and entered as second class mail in the City of Greensboro in said County and State. 2. That he/she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a copy of which is attached hereto, was published in the News & Record on the dates listed below. 3. That the said newspaper (or newspapers) in which such notice, paper, document, or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1-597 of the General Statutes of North C of the General Statutes of' North Carolina. Publisher's Representative Sworn to and subscribed before me, thisv day of Cle UbectAm,(16Wi Notary Public Ad # Date Edition Class PO Ad Copy rolinalified newspaper within the meaning of Section 1-59; .�```P P,NNEr, ''i N./\OTA,4 y ', My Comm. Exp. 6/15/2014 U= PUBLIC NCDENR DWQ NPDES 33968650 09/04/10 News & Record 400 Jordan Lake PUBLIC NOTICESTATE OF NORTH CAROLIN Ad ID '33968650 Date 09/02/2010 Time 12:24 PM PUBLIC NOTICE STATE OF NORTH CAROUNA ENMRONMENTAL MANAGEMENT COMMISSION/ NPDES UNIT 1617 MAIL SERVICE CENTER RALECH, NC 27699-1617 NOTIFICATION OF INTENT TO MODFY NPDES WAST WATER PERMITS N THE JORDAN LAKE WATERSHED On the basis of through staff review and applicaton of NC General Statute 143.21, Public law 92-500, and other lawful stardards and regulations, the North Carolina Environ rre rrtal Corrrrissiion proposes to modiy National Pollutant Dkcharge Elmination System (NPDES) wastewater discharge pe rmits to the persons listed below effective 45 days fromthe pub lkh date of this notice. The purpose of these modtcatbrs is to set Total Phosphorus discharge limits in accordance wth the Jordan Lake Nutrient ManagerrentStratew: Wastewater Discharge Requirerrrents, T15A NCAC 028.0270. The four (4) affected faciities discharge treated wastewater in the Jordan Lake watershed of the Cape Fear River Basin: NPDES Permit Na NC0047384, Gty of Greensboro -T,Z Osbome VWVrP, discharging to South Buffalo Creek in Guilford County, NPDES Permit Na NCD024325, City of Greensboro - North Buffalo Creek WWTP, discharging to North Buffalo Creek in Guilford County NPDES Permit Na NC002386F City of Burlington - Eastside WWTP, discharging to Haw River n Atarrence County, NPDES Permit Na NC0023876, City of Burlington-Southside WWI?, discharging to Big Alanence Creek in Alamance County, Written convrents regarding the proposed penritwil be accepted until 30 days after the publsh date of this notice. All comments recehred prior to that date are considered in the final deterninations regarding the proposed permits. The Director of the NC Division of Water Quality rrey decide to hob a public rreetng for the proposed pen-rits should the Diviion receive a signficant degree of public interest. Copies of the draft perrrit and other supporting information on file wed to deterrrine condtbrs present in the draft permits are arvailabb upon request and payment of the costs of reproduden Main comments and'or requests for information to the NC Divsion of Water Quality at the above addressor call Ms, Dina Sprnkle at (919) 807-6304. Please indude the NPDES permit number (attached) in anycorrrrunication Interested persons rrey also visit the Division of Water Quality at 512 N. Salsbury Street, Raleigh, NC 276041148 between the hours of 890am and 500pmto review information on file. Ad shown is not actual print size WATER Resources is i 4=g City of Greensboro Certified Mail 7005 3110 0003 4792 7986 Return Receipt Requested December 15, 2009 [Emailed: 12-15-2009] Mr. Michael E. Templeton North Carolina Department of Environment and Natural Resources Point Source Branch-NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699 Re: Comments on Draft Modification to NPDES Permit NC0024325 North Buffalo WWTP-Guilford County Dear Mr. Templeton, This purpose of this correspondence is to document the City of Greensboro Water Resources Department comments on the draft NPDES Permit for the North Buffalo Water Reclamation Facility. The final corrected draft was received via email on November 13, 2009. The City of Greensboro comments are as follows: Part A. (1) Effluent Limitations and Monitoring Requirements Total Phosphorus Annual Load: 32,359 pounds per year As previously discussed with you, the City of Greensboro would like to request a total phosphorus annual mass "bubble permit" for the two Greensboro facilities. This approach is particularly appropriate since flow can be transferred from the North Buffalo Plant to the T. Z. Osborne Plant. In your cover letter of November 4, 2009 you stated: "The draft permits do not include (bubble permit) alternate limits; however, we are considering the request and are willing to discuss the concept further." We are ready to begin the discussions. A.(5.)(d.) Annual Limits for Total Nitrogen or Total Phosphorus The City of Greensboro would also like to explore the concept of an umbrella permit/compliance association for several Haw River dischargers, but the current draft NPDES permit language would preclude establishing such a compliance association this year since a municipality would have to be a member on January 1 of the calendar year per A.(5.)(d.). DWQ would not have time to issue such a permit and the municipalities would not have time to form an association before January 1, 2010. We request that DWQ allow a one-time extension of the January 1 date to allow several cities, along with DWQ, to investigate the possibility of forming such an association during calendar year 2010. We would, of course, all agree to be held to our individual annual permitted Letter to Mr. Michael E. Templeton re: NPDES Permit NC0024325- December 15, 2009 phosphorus loads prior to the formation of any compliance association and the applicable CY 2010 phosphorus loads could be "prorated" if a compliance association were formed during the year. Supplement to Permit Cover Sheet - Treatment Component Updates Please make the following changes, indicated in italics, to the North Buffalo treatment components listed on the Supplement To Permit Cover Sheet: • Influent flow measurement (Parshall flume and Mag meter) • 80 MGD flow transfer pump station to TZ Osborne • Trickling Filters (currently not in use) Clarification of definition of "Daily Maximum" (Page 2 of Standard Conditions) Please clarify the following section/statement: Daily Maximum - The highest "daily discharge" for conventional and other non -toxicant parameters. NOTE: Permittees may not submit a "daily average" calculation [for determining compliance with permit limits] for toxicants. See the relevant Federal effluent guideline[s] for the appropriate calculation interval. The North Buffalo NPDES permit contains a daily maximum concentration limit for residual chlorine, total mercury and total cyanide, all of which require grab sampling. Please confirm that this defmition/statement does not prevent us from taking several grab samples in one day and averaging them for compliance with the "daily maximum" limit for these parameters. The definition makes mention of the "Federal effluent guidelines" which leads me to believe it is actually for parameters regulated under Federal categorical standards. A review of the definition of "Daily Discharge" merely confuses the issue further. We look forward to your response. Thank you for the opportunity to comment on the draft North Buffalo NPDES permit. If you have any questions or need additional information, please do not hesitate to contact me at 336-433-7229 or by email at martie.groome@ci.greensboro.nc.us Sincerely, Mart e'Grp Agicra te-mt Martie Groome cc: Allan Williams, Director of Water Resources [via email] Don Howard, Water Reclamation Manager [via email] Walter Kling, ORC-T. Z. Osborne POTW [via email] Ed Osborne, ORC-North Buffalo POTW [via email] Steve Tedder, Supervisor Winston-Salem DWQ Regional Office [via email] A71 NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Mitchell Johnson, City Manager City of Greensboro PO Box 3136 Greensboro, North Carolina 27402-3136 Dear Mr. Johnson: Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary October 1, 2009 Subject: Notification of Intent to Modify NPDES Permits NC0047384 and NC0024325 to Incorporate Jordan Lake Nutrient Requirements T.Z. Osborne and North Buffalo Creek WWTPs Guilford County Governor Bev Perdue recently signed legislation to complete passage of rules for the Jordan Lake Nutrient Management Strategy. The Strategy includes a Wastewater Discharge rule (T15A NCAC 02B .0270) that applies to your wastewater treatment facilities. Pursuant to Sub -Item (6)(d) of that rule, I am writing to notify you of (1) the nutrient allocations assigned to your facilities and (2) the Division of Water Quality's intent to modify the subject NPDES permits to include nutrient limits as provided in the rule. I also wish to remind you of other provisions of the rule that require your prompt attention. This letter addresses only certain provisions of the Jordan Lake Wastewater Discharge rule. I encourage you to familiarize yourself with the remainder of the rule. Nutrient Allocations. The Wastewater Discharge rule establishes the maximum loads of nitrogen and phosphorus that can be released from wastewater treatment facilities into the Jordan Lake watershed. The rule specifies that these wasteload allocations are to be divided among the existing facilities in proportion to their 2001 permitted flows (with certain exceptions). Your facilities have been assigned nitrogen and phosphorus allocations. The allocations are expressed as annual mass loadings delivered to the lake. Due to foreseeable losses between the discharge point and the lake, they are also expressed as the equivalent discharge loads at the point of discharge. The delivered and the corresponding discharge allocations assigned to the City of Burlington are as follows: 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919.807-63001 FAX: 919-807-64921 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer NorthCarolina ,naturally Mitchell Johnson, City Manager Notification of Intent to Modify NPDES Permits NC0047384 and NC0024325 October 1, 2009 NC0047384 - T.Z. Osborne WWTP NC0047384 Delivered Allocation (lb/ yr) Transport Factor (%) Discharge Allocation (lb/yr) Total Nitrogen 289,618 45 643,595 Total Phosphorus 35,595 44 80,899 2001 Permitted Flow: 40 MGD (as defined in Wastewater Discharge rule) NC0024325 - North Buffalo Creek WWTP NC0024325 Delivered Allocation (lb/yr) Transport Factor (%) Discharge Allocation (lb/yr) Total Nitrogen 110,698 43 257,438 Total Phosphorus 13,591 42 32,359 2001 Permitted Flow: 16 MGD Intent to Modify Permit. The new rule specifies that facilities with permitted flows at or above 0.1 MGD, including yours, will be subject to effluent limits for nitrogen and phosphorus. The effluent limits will equal the facility's discharge allocations. The new phosphorus limits become effective beginning with calendar year 2010. Nitrogen limits become effective beginning with calendar year 2016. It is the Division's intent to modify the affected permits by the end of 2009 to include the new phosphorus limits. We will draft permit modifications for the affected facilities in the coming weeks. As with any such permit action, the proposed modifications will be subject to public review, and we will provide you with a copy of the draft permit at that time. The Division will add nitrogen limits during the 2011 permit renewals, with a compliance date of 2016. Process Optimization. The rule specifies that no later than six months after its effective date, each discharger with a permitted flow greater than or equal to 0.5 MGD must "evaluate its treatment facilities and operations and identify further opportunities to improve and minimize nitrogen reduction in the existing facilities...; and submit a report to the Division documenting its findings, proposing optimization measures, and describing expected results." Please provide three copies of your report to the Division at the following address no later than February 11, 2010: Division of Water Quality Surface Water Protection Section, Point Source Branch Attn: Jordan Lake Coordinator 1617 Mail Service Center Raleigh, NC 20699-1617 2 Mitchell Johnson, City Manager Notification of Intent to Modify NPDES Permits NC0047384 and NC0024325 October 1, 2009 Each discharger must implement the proposed measures no later than six months after the Division accepts the report and continue until such time as the facility is upgraded for nitrogen removal. The affected dischargers must also submit annual progress report to the Division for a period of five years. If you have any questions regarding these requirements, please contact Mike Templeton at (919) 807- 6402 or at mike.templeton@ncdenr.gov. Sincerely, cc: Allan Williams, Director of Water Resources - 2199 White Street, Greensboro, NC 27405 Winston-Salem Regional Office NDPES Files Central Files 3 City of Greensboro J North Carolina Water Resources Department February 11, 2010 [vial email] Hard Copy to Follow by Certified U. S. Mail 7005 3110 0003 4792 7993 NCDENR Division of Water Quality Surface Water Protection Section, Point Source Branch Attn: Jordan Lake Coordinator 1617 Mail Service Center Raleigh, NC 27699-1617 Dear Mr. Templeton: Q FEB 1. 7 2O 10 DENR-WATER QUALITY POINT SOURCE BRANCH Re: Nitrogen Optimization Plan City of Greensboro T. Z. Osborne POTW NPDES # NC0047384 North Buffalo POTW NPDES #NC0024325 This letter is in response to the draft NPDES Permit modifications for the above named POTWs dated November 4, 2009. Part A.(7.) of the draft NPDES permits includes a new special condition requiring the City to submit a Nitrogen Optimization Plan that, upon acceptance by the Division, is to be implemented until the total nitrogen limits become effective in 2016. This submittal constitutes the City of Greensboro Nitrogen Optimization Plan in fulfillment of this special condition in the draft NPDES permit. This correspondence shall serve as the plan for both City of Greensboro POTWs. Background The City of Greensboro owns and operates two water reclamation facilities that ultimately discharge to the Haw River arm of Jordan Lake. The North Buffalo POTW has a permitted design capacity of 16 MGD and is currently discharging an average of 5.85 MGD (CY 2009). The T. Z. Osborne POTW has a permitted design capacity of 40 MGD and is currently discharging an average of 23.6 MGD (CY 2009). Both NPDES permits expire on June 30, 2011. Under the Jordan Lake Nutrient Management Strategy and new conditions/limits of the NPDES permits, the City of Greensboro POTWs will have to control nitrogen to meet the following annual total nitrogen (TN) mass loadings by the year 2016: Jordan Lake Rules End -of -Pipe Target Total Nitrogen Annual Mass Loadings POTW Permitted Flow Annual Mass Load Concentration North Buffalo 16.0 MGD 257,438 pounds 5.29 mg/1 T. Z. Osborne 40.0 MGD 645,277 pounds 5.29 mg/1 City of Greensboro Nitrogen Optimization Plan Letter to DWQ 2-11-2010 Page 2 Optimization Efforts The City of Greensboro has evaluated operational modifications in an effort to optimize nitrogen removal with our current treatment processes. The following modifications/actions have been taken: (1) T. Z. Osborne - Rerouted centrate from sludge centrifuges used for dewatering, to influent wet well. This recycle stream was previously routed to the primary effluent/activated sludge influent. This is a permanent modification. (2) T. Z. Osborne - Modification of existing activated sludge tank drain pumps to provide limited form of nitrate recycle within activated sludge system providing recycle flow of 6-8 MGD. This is a permanent modification. (3) North Buffalo — Additional flow from North Buffalo is being pumped via transfer station to the T.Z. Osborne facility, since the T. Z. Osborne POTW has had a consistently lower total nitrogen effluent concentration and theoretically higher total nitrogen removal efficiency. This is a permanent operational modification as long as it continues to result in a lower mass of total nitrogen discharged. (4) T. Z. Osborne — The City of Greensboro spent over $2 million dollars to pilot test the integrated fixed film activated sludge (IFAS) process for nitrogen removal. One activated sludge basin and clarifier were isolated for the one year pilot project, which recently ended. This pilot project will continue for approximately 12 more months to further fine tune the process/test by creating an additional denitrification area in the basin. The affected activated sludge basin will be returned to normal conditions after that time in order to have full treatment capabilities during high flow events (one additional clarifier had to be taken out of service for the pilot project in order to "completely isolate" the train). Plant Performance Neither one of the City of Greensboro POTWs was originally designed as a BNR facility. Thus any nitrogen removal from existing treatment processes is incidental. Additional reductions of total nitrogen would not be expected without making significant capital investments in nitrogen removal technologies. However, since 2006 the Greensboro POTWs have made some progress in reducing the total pounds of nitrogen discharged as evidenced by the chart below: Year NB TN pounds/year TZO TN pounds/year TN Total pounds/year NB Eff Flow MG/Year TZO Eff Flow MG/Year Total Flow MG/Year TN Avg mg/1 2009 300,366 749,998 1,050,364 2134.1 8616.1 10,750.1 11.7 2008 361,745 644,784 1,006,259 2438.2 8060.7 10,498.9 11.5 2007 702,900 401,842 1,104, 742 4133.2 6613.8 10,747.2 12.3 2006 690,385 509,394 1,199, 779 4085.9 6509.4 10,595.3 13.6 City of Greensboro Nitrogen Optimization Plan Letter to DWQ 2-11-2010 Page 3 Summary The City of Greensboro POTWs currently reduce total nitrogen to the extent possible with the available existing infrastructure and treatment processes. The City of Greensboro will continue to evaluate its treatment facilities and operational processes to make reasonable efforts to reduce nitrogen discharges until process improvements are completed in 2016. If you have questions or need additional information please do not hesitate to contact either of us. S;ncerely, Don Howard Water Reclamation Manager h/totrt)t) Martie Groome Laboratory and Industrial Waste Section Supervisor cc: Allan Williams, Water Resources Director [via email] Kenney McDowell, Water Resources Deputy Director [via email] Wally Kling, Plant Superintendent [via email] Ed Osborne, ORC-North Buffalo [via email]