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HomeMy WebLinkAboutNC0081370_Speculative Limits_20140212NPDES DOCUMENT :MCANNINO COVER :MEET NPDES Permit: NC0081370 Claremont / McLin Creek WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Additional Information Received Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: February 12, 2014 This document is printed on reuse paper - ignore any content on the re-szerse side A A ioiy spc Lifni ern ThENR North Carolina Department of Environment and Na Division of Water Resources Pat McCrory Thomas A. Reeder Governor Director February 12, 2014 Mr. Guy Slagle, P.E., Project Director Davis & Floyd 1073 13th Street NE Hickory, NC 28602 Secs/416We h rl� ural Resources John E. Skvarla, III Secretary Subject: Speculative Effluent Limits City of Claremont McLin Creek WWTP Permit No. NC0081370 Catawba County Catawba River Basin Dear Mr. Slagle: This letter provides speculative effluent limits for 1.2 MGD at the Claremont McLin Creek WWTP. The Division received the speculative limits request in a letter dated January 21, 2014. Please recognize that speculative limits may change based on future water quality initiatives, and it is highly recommended that the applicant verify the speculative limits with the Division's NPDES Unit prior to any engineering design work. The Division understands that the Claremont North WWTP will be decommissioned upon expansion of the McLin Creek WWTP. Receiving Stream. McLin Creek is located within the Catawba River Basin. McLin Creek has a stream classification of WS-IV;CA, and waters with this classification have a best usage for a source of water supply for drinking, culinary, or food -processing purposes in addition to the uses for aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation and agriculture. McLin Creek has a summer 7Q10 flow of 5 cfs, a winter 7Q10 flow of 9 cfs, and an annual average flow of 26 cfs. McLin Creek is currently listed as an impaired waterbody on the 2012 North Carolina 303(d) Impaired Waters List for biological integrity. There are no specific permitting strategies for McLin Creek in the Catawba River Basinwide Water Quality Plan. Based upon a review of information available from the North Carolina Natural Heritage Program Online Map Viewer, there are not any Federally Listed threatened or endangered 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807.63001 FAX: 919-807-6492 Internet www.ncwateraualitv.orq An Equal Opportunity 1 Affirmative Action Employer No Carolina aurally Mr. Guy Slagle February 12, 2014 Page 2 of 4 aquatic species identified within a 5 mile radius of the proposed discharge location. If there are any identified threatened/endangered species, it is recommended that the applicant discuss the proposed project with the US Fish and Wildlife Service to determine whether the proposed discharge location might impact such species. Speculative Effluent Limits. Based on Division review of receiving stream conditions and the Upper Lyle and McLin Creek Water Quality Modeling Analysis prepared by HydroAnalysis, speculative limits for the proposed expansion to 1.2 MGD are presented in Table 1. A complete evaluation of these limits and monitoring requirements for metals and other toxicants, as well as potential instream monitoring requirements, will be addressed upon receipt of a formal NPDES permit application. Some features of the speculative limit development include the following: • BOD/DO/NH3N Limits. The limits for BOD, DO and NH3N are based on the results of the modeling analysis. The Qua12K model predicted DO concentrations above the water quality standard maintaining the current concentration limits for BOD and ammonia. • Upstream/Downstream Monitoring. Instream monitoring for dissolved oxygen and temperature is recommended to evaluate the increased discharge impact on the watershed. Monitoring locations will be determined when the permit is modified to include the expansion. TABLE 1. Speculative Limits for Effluent Characteristic " Effluent l is ii& Ons Monthly Average ' Weed: y Average 'Daily . ximum Flow 1.2 MGD BOD5 (April 1- October 31) 8.0 mg/L 12.0 mg/L BOD5 (November 1- March 31) 16.0 mg/L 24.0 mg/L NH3 as N (April 1- October 31) 2.0 mg/L 6.0 mg/L NH3 as N (November 1- March 31) 4.0 mg/L 12.0 mg/L Dissolved Oxygen (minimum) 5.0 mg/L TSS 30 mg/L 45 mg/L . TRC 28 ug/1 Fecal coliform (geometric mean) 200/100 ml 400/100 ml Total Phosphorus Monitor Total Nitrogen Monitor Dissolved Oxygen Upstream/Downstream monitoring Mr. Guy Slagle February 12, 2014 Page 3 of 4 Temperature Upstream/Downstream monitoring Chronic Toxicity Pass/Fail (Quarterly test) 27% Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES permit for a new or expanding discharge will be issued with these speculative limits. Final decisions can only be made after the Division receives and evaluates a formal permit application for the new/expanded discharge. In accordance with North Carolina Administrative Code 15A NCAC 2H.0105( c), the most environmentally sound alternative should be selected from all reasonably cost effective options. Therefore, as a component of all NPDES permit applications for new or expanding flow, a detailed engineering alternatives analysis (EAA) must be prepared. The EAA must justify requested flows and provide an analysis of potential wastewater treatment alternatives. A copy of the Division guidance for preparing EAA documents is attached. State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document must be prepared for all projects that: 1) need a permit; 2) use public money or affect public lands; and 3) might have a potential to significantly impact the environment. For new or expanding discharges, significant impact is defined as > 500,000 gpd additional flow. Since the City of Claremenot is proposing an increase in flow >500,000 gpd, the City must prepare a SEPA document that evaluates the potential for impacting the quality of the environment. The NPDES Unit will not accept an NPDES permit application for the expanded discharge until the Division has approved the SEPA document and sent a Finding of No Significant Impact (FONSI) to the State Clearinghouse for review and comment. A SEPA Environmental Assessment (EA) should contain a clear justification for the proposed project. If the SEPA EA demonstrates that the project may result in a significant adverse effect on the quality of the environment, you must then prepare a SEPA EIS (Environmental Impact Statement). For projects that are subject to SEPA, the EAA requirements discussed above will need to be folded into the SEPA document. The SEPA process will be delayed if all EAA requirements are not adequately addressed. If you have any questions regarding SEPA EA/EIS requirements, please contact Jackie Roddy with DWR Planning at (919) 807- 6442. Should you have any questions about these speculative limits or NPDES permitting requirements, please feel free to contact Teresa Rodriguez at (919) 807-6387 or Tom Belnick at (919) 807-6390. Respectfully, atgilittL om Belnick Supervisor, NPDES Complex Permitting Unit Attachment: EAA Guidance Document Mr. Guy Slagle February 12, 2014 Page 4 of 4 Hardcopy: Central Files NPDES Permit File Electronic Copy: US Fish and Wildlife Service, Sara_Ward@fws.gov DWR/Mooresville Regional Office DWR/SEPA, Jackie Roddy DWR/Modeling, Kathy Stecker DWR/Basinwide Planning, Jeff Manning NPDES Server>Specs SePC 144' C/i'ir4if/Mtt"1 j.iidl(' Belnick, Tom CawL " gA,Vri hio From: Belnick, Tom Sent: Wednesday, January 22, 2014 4:22 PM To: Behm, Pamela; Rodriguez, Teresa Cc: Stecker, Kathy Subject: FW: Speculative Limits Request, Claremont, NC Attachments: DENR Speculative Limits Request.pdf Incoming spec request. Claremont is requesting spec for expansion from current 0.3 MGD up to 1.2 MGD. I'm not sure if Ken Hickey's QUAL2K model covered a 1.2 MGD discharge? Teresa- I'm assigning this spec to you. Please coordinate with Pam, who was reviewing the QUAL2K effort. NPDES issued a previous spec to Claremont dated May 4, 2011 for 0.85 MGD, and at that time we just froze the BOD/NH3 loads due to instream DO concerns. But now we should be able to utilize the QUAL2K model results. The previous spec does contain relevant info on receiving stream. Discharge ultimately flows to Lake Norman, so there are no nutrient TMDL considerations. Tom Belnick Supervisor, NPDES Complex Permitting Unit NCDWR/Water Quality Programs 919-807-6390 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties From: Guy Slagle [mailto:gslagleOdavisfloyd.com] Sent: Tuesday, January 21, 2014 4:38 PM To: Belnick, Tom Cc: Doug Barrick; Gene Haynes; Scott Bell; Ken Hickey Subject: Speculative Limits Request, Claremont, NC Tom, Attached is a request for updated Speculative Limits for the McLin Creek WWTP. If you need further information please let me know. Guy Guy E. Slagle, Jr., P.E, R.L.S. Vice President D 18 . Davis & Floyd, Inc. ,. 181 East Evans St., Suite 23, BTC-105 Jo Florence, SC 29506 (843) 519-1050 (office) I (843) 664-2881 (fax) gslagleadavisfloyd.com ( www.davisfloyd.com Guy Slagle, PE, PLS Vice President D I, Davis & Floyd, Inc. 181 East Evans Street, Suite 23 D Florence, SC 29506 (843) 519-1050 (office) I (843) 664-2881 (fax) gslagle(c�davisflovd.com I www.davisfloyd.com CONFIDENTIALITY NOTICE - The information and all attachments contained in this email message are for the use of the intended recipients only. If you are not an intended recipient, please be advised that any use, dissemination, distribution, or copying of this email is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or return email, and delete this email message and all attachments from your system. CONFIDENTIALITY NOTICE - The information and all attachments contained in this email message are for the use of the intended recipients only. if you are not an intended recipient, please be advised that any use, dissemination, distribution, or copying of this email is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or return email, and delete this email message and al! attachments from your system. DIS FL D January 21, 2014 Mr. Tom Belnick Supervisor, NPDES Complex Permitting Unit NCDENR — DWQ 1617 Mail Service Center Raleigh, N.C. 27699-1617 Re: Speculative Limits City of Claremont, N.C. McLin Creek Wastew eatment Plant NPDES Permit No NC0081370 Dear Mr. Belnick: The City of Claremont is considering the upgrade and - . 'on of its McLin Creek Wastewater Treatment Plant from a permitted capacity of 0.3 MGD 1.2 MGD. In anticipation of this expansion the City commissioned HAI, Inc. to perform a water quality mo • e Ing analysis of Lyle and McLin Creek. That analysis has been completed and the study report submitted to NCDENR for review. Attached is a letter of review from Ms. Pam Behm indicating agreement with the study findings. Therefore, on the behalf of the City of Claremont it is requested that NCDENR provide updated Speculative Effluent Limits for the McLin Creek WWTP in consideration the findings of the HAI modeling study. The discharge from the expanded plant would be at its current location as illustrated in the HAI study report. A copy of the HAI study report can be provided to you if required. Coordinates of the discharge point are as follows: Latitude: 35.6956 Longitude: -81.1214 With the upgrade and expansion of the McLin Creek VVWTP the City proposes to decommission its North WWTP (NPDES Permit No. NC0032662) and consolidate all wastewater treatment at the McLin Creek facility. If you have any questions, please do not hesitate to contact us. Sincerely, DAVIS & FLOYD, INC. W‘-777/ Guy E. Slagle, Jr., PE Project Director Cc: Doug Barrick, Claremont City Manager Engineering I Architecture ( Environmental I Laboratory 1073 13th Street NE Hickory, NC 28602 [828] 322 2290 davisfloyd.oam Arca NCDENR North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Programs Pat McCrory Thomas A. Reeder John E. Skvarla, III Govemor Director Secretary January 15, 2014 Mr. Doug Barrick City Manager City of Claremont 3288 East Main Street Claremont, NC 28610 Dear Mr. Barrick, The DWR Modeling and Assessment Branch has reviewed the final report titled "Upper Lyle and McLin Creek Water Quality Modeling Analysis" and modeling files provided by Hydroanalysis, Inc. We agree with the findings detailed in the report, specifically that the Qual2k models developed indicate that there is assimilative capacity to support expansion of the City of Claremont's and City of Conover's facilities. The analysis was performed assuming expansions to Conover NE WWTP (Lyle Creek) of up to twice the currently permitted flow and Claremont McLin WWTP of up to four times the currently permitted flow and closures of Claremont North WWTP (Lyle Creek) and Conover SE WWTP (McLin Creek). At this point, the cities will need to determine how much expansion is actually needed and where. For permitting questions, the best contact is Tom Belnick (tom.belnick@ncdenr.gov). For SEPA questions, the best contact is Harold Brady (harold.m.brady@ncdenr.gov). If you have questions, please let us know. Pam Behm 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 Fax: 919-807-6492 Internet:: www,ncwateroualitv.orq An Equal OpportunilyWffamative Action Employer Cy pia kiwi NPDES Permit NC00813 70 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge through Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: CHARATERISTICS [parameter codes] EFFLUENT LIMITS MONITORING REQUIREMENTS Sample Type Sample Locations Monthly Average Weekly Average Daily Maximum Measurement Frequency [50050] Flow (MGD) 0.300 Continuous Recording I or E [00310] BOD, 5day, 20°C 2 (Apr 1- Oct 31) 8.0 mg/L 12.0 mg/L Weekly Composite E, I [00310] BOD, 5day, 20°C2 (Nov 1- Mar 31) 16.0 mg/L 24.0 mg/L Weekly Composite E, I [50530] Total Suspended Solids (TSS) 2 30 mg/L 45 mg/L Weekly Composite E, I [00610] NH3 as N (Apr 1 - Oct 31) 2.0 mg/L 6 mg/L Weekly Composite E [00610] NH3 as N (Nov 1 - Mar 31) 4.0 mg/L 12 mg/L Weekly Composite E [00300] Dissolved Oxygen3 Weekly Grab E [31616] Fecal Coliform (geometric mean) 200/100 ml 400/100 ml Weekly Grab E [50060] Total Residual Chlorine (TRC) 4 28 µg/L 4 Weekly Grab E [00010] Temperature (°C) Weekly Grab E [00400] pH Not < 6.0 nor > 9.0 standard units Weekly Grab E [01042] Total Copper Monthly Composite E [01092] Total Zinc Monthly Composite E [EPA 1631 E] Total Mercury6 Quarterly Grab E [00625] Total Nitrogen (NO2 + NO3 + TKN) Quarterly Composite E [00665] Total Phosphorus Quarterly Composite E [TGP3B] Chronic Toxicity? Quarterly Composite E [50010] Temperature, °C Weekly Grab U, D [00300] Dissolved Oxygen Weekly Grab U, D Table Footnotes: 1. Sample Locations: E = Effluent; I = Influent; U = Upstream at NCSR 1722 (south of Claremont); D = Downstream at NCSR 1722 (east of Claremont, see map). 2. Monthly average effluent concentrations for Biochemical Oxygen Demand (BODB) and TSS shall not exceed 15% of the respective influent values (i.e. 85% removal required). 3. Daily average dissolved oxygen effluent concentration shall not fall below 5.0 mg/L. 4. Total Residual Chlorine (TRC). The Division shall consider all effluent TRC values reported below 501.tg/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 µg/L. 5. Chronic Toxicity (Ceriodaphnia) at 9 %; quarterly during January, April, July, October; See Special Condition A. (2.) 6. Mercury — the Permittee shall conduct sampling and analyses according to field and laboratory techniques described in test method EPA 1631 E, or equivalently approved low-level testing. Units: mg/L = milligrams per liter ml = milliliter µg/L = micrograms per liter NH3 as N = ammonia nitrogen BOD = biochemical oxygen demand The Permittee shall discharge no floating solids or foam visible in other than trace amounts. Fife kUeMovi1F 44c,L14 CvK wwTP tsJC�O?d370 Draft Modeling Work Plan for Upper Lyle Creek and McLin Creek February 18„ 2013 a� Prepared by: Ken Hickey 481 Great Road, Suite 3 Acton, Massachusetts 01720 (978) 263-1092 Draft Modeling Work Plan for Upper Lyle Creek and McLin Creek Table of Contents 1.0 Introduction 2 2.0 Review of Available Studies 5 2.1 Physical Characterization 5 2.2 Hydrologic Characterization 5 2.3 Water Quality and Biological Characterization 5 2.4 Summary of Observations 7 3.0 Review of 2007 Lyle Creek Water Quality Modeling Analysis 9 3.1 Overview 9 3.2 Field Program 9 3.3 Lower Lyle Creek Model Setup and Application 11 3.4 Summary 13 4.0 Draft Modeling Analysis Work Plan 16 4.1 Conceptual Approach 16 4.2 Model Selection 16 4.3 Physical Model Domain Setup 17 4.4 Hydrologic Model Setup 17 4.5 Water Quality Model Setup 19 4.6 Application of the Water Quality Model 20 5.0 References 24 1 Hydro 1.0 Introduction This report describes a work plan for conducting a simple water quality modeling analysis of Upper Lyle Creek and McLin Creek. The objective of the Upper Lyle-McLin Creek modeling analysis is to support evaluation of the potential for increased wastewater treatment plant (WWTP) wasteload allocations for the Cities of Claremont and Conover. Specifically, the potential for increased wasteloads for Conover's Northeast WWTP situated on Lyle Creek and Claremont's McLin Creek WWTP situated on McLin Creek (Figure 1) will be evaluated. The modeling analysis will focus on evaluating the assimilative capacity of the river system to receive an increased load of oxygen -demanding substances. The Upper Lyle-McLin Creek modeling analysis will build upon and be consistent with an approved Lower Lyle Creek modeling analysis conducted in 2007 (ENSR 2007). The Lyle Creek watershed is situated in the Catawba River basin and drains an area of 74 square miles (Figure 1). The Lyle Creek watershed is home to approximately 34,470 people who reside in Hickory, Conover, Claremont, Catawba, and other municipalities (Davis & Floyd 2011). Figure 1 presents the Lyle Creek watershed with its two largest sub -watersheds, Lyle Creek and McLin Creek. Lyle Creek flows towards the east and drains 47.4 square miles, representing 64% of the total watershed area. Lyle Creek is over 18 miles long (FEMA 2007) and receives flow from several tributaries. The Conover Northeast WWTP is situated on Lyle Creek at river mile 10.3 ("river miles" or RMs are defined as distance upstream from the mouth of a river or creek). McLin Creek is situated south of Lyle Creek, flows toward the east-northeast and joins Lyle Creek 1.4 miles from its confluence with the Catawba River (Figure 2). McLin Creek drains an area of 27.5 square miles, representing more than one-third (36%) of the total Lyle Creek watershed area. McLin Creek is over 10 miles long (FEMA 2007) and the McLin Creek WWTP is situated at river mile 2.5. This draft work plan provides a summary of available physical, hydrologic, water quality, and biological conditions in Lyle and McLin Creeks (Section 2) and an overview of the 2007 Lower Lyle Creek Water Quality Modeling Study (Section 3). The review of available information and of the 2007 modeling analysis are intended to provide readers with background and contextual information relevant to the draft Upper Lyle-McLin Creek modeling work plan described in Section 4. 2 Hydro Analysis Lyle'Qreek Waters 474 sq. allies Lyle and McLin Creek Watersheds �\. Stream /\/ Roads and Highways WWTP Lake, Pond or River Municipal Boundary McUn Creek WWTP Watershed (HUC 12) 1 Lyle Creek McLin Creek Miles 0 0.5 1 NAD83 North Carolina State Plane Feet, Data from National Hydrography Database (NHD) and NC DOT Name' 1_Watersheds Date: 2/14/2013 Figure 1. Lyle Creek watershed with two major sub -watersheds and WWTPs indicated. 3 Hydro Analysis Conover NE f WWTP Lyle Creekatershed 47.4 mlles Claremont us-7c � r 4/010414 O Conover J McLin CreekCreel;aidittied 26.5 sq. miles •16 Newton 'Maiden McLin Creek Watershed Tkv McLin Creek WWTP /\/ Roads and Highways Ell Lake, Pond or River Watershed (HUC 12) '�. Stream `j Municipal Boundary E Lyle Creek L' WWTP i J McLin Creek Catawtiaz','.• . Ww rP� Catawba, Miles 0 0.5 1 NAD83 North Carolina State Plane Feet, Data from National Hydrography Database (NHD) and NC DOT Name: 2 McUnWatershed_021113 Date: 2/14/2013 Figure 2. McLin Creek Watershed with WWTPs indicated. 4 Hydro Analysis 2.0 Review of Available Studies A review of available studies was conducted to enhance understanding of the physical, hydrologic, water quality, and biological characteristics of the Lyle Creek and McLin Creek study area. 2.1 Physical Characterization Three primary sources of information were used to characterize the physical conditions in the Lyle Creek and McLin Creek study area. Two of these sources are a FEMA Flood Insurance Study and Geographic Information System data, described below, and the third source is the 2007 modeling study, described in Section 3. ,2007 FEMA Flood Insurance Study (FIS) of Catawba County A 2007 FEMA FIS was obtained and will be a useful source of physical characteristics of Lyle Creek and McLin Creek (FEMA 2007). The FIS contains flood profiles including streambed elevations throughout Lyle Creek and McLin Creek. These profiles will be used to obtain streambed slope and distances to key locations, including WWTPs, highway overpasses and tributary confluences. Geographic Information Systems (GIS) The National Hydrography Data (NHD) set was utilized as the source of stream, river, pond and lake locations as well as the Hydrologic Unit Code (HUC) 12 watershed delineations for Lyle Creek and McLin Creek. The sub -watersheds within the Lyle Creek watershed were established based on the HUC 12 delineation and the North Carolina Department of Transportation (NCDOT) May 2007 LiDAR data and associated data products including contour intervals. Municipal boundaries, roads and highways data were provided by NCDOT. County boundaries were provided by the North Carolina Geodetic Survey. 2.2 Hydrologic Characterization The FEMA Flood Insurance Study provides estimated flood elevations and associated flows associated with flooding events (i.e., extremely high flows) in Lyle Creek and McLin Creek. The FEMA study predicts flows that are in the upper 10% annual change of occurrence range, but does not evaluate flows outside of this high flow range (FEMA 2007). There appears to be sparse hydrologic information available for average or low flow conditions for the Lyle Creek and McLin Creek watersheds. The field program associated with the 2007 modeling study captured low -flow conditions in Lyle Creek and McLin Creek and is summarized in Section 3 below. 2.3 Water Quality and Biological Characterization The primary source of information regarding water quality conditions in the Lyle Creek watershed is North Carolina Department of Environment and Natural Resources (DENR) Basinwide Water Quality Plans. These plans are published approximately every five years and provide a summary of water quality conditions in watersheds throughout the state. Basinwide Water Quality Plans published in 1995, 1999, 2004, and 2010 were obtained and reviewed for information relative to the Lyle Creek 5 Hydro watershed. These reports and other sources of information are briefly summarized in chronological order below. 1995 Catawba River Basinwide Water Quality Plan The 1995 Catawba River Basinwide Plan recommended that the Lyle Creek watershed implement a management strategy for oxygen -consuming wasteloads from discharge facilities (NC DEM 1995), as described below. The 1995 Plan does not report water quality measurements collected from the Lyle Creek watershed. There was one benthic macroinvertebrate monitoring station reported in Lyle Creek. Benthic macroinvertebrates, especially aquatic insects, are sampled to support evaluation of the biological health and water quality conditions in stream and rivers (NC DENR 2012b). The nature and extent of benthic macroinvertebrate communities have been found to be good indicators of water quality in streams and are used as an efficient method of assessing aquatic health. The Lyle Creek benthic monitoring location at the Highway 70 bridge is situated 3.5 miles upstream of the mouth (Figure 1). Lyle Creek was assigned a biological rating of "Good" based on a 1992 benthic macroinvertebrate survey and the fish community structure of Lyle Creek was assigned a "Good" rating based on a 1993 survey (NC DEM 1995). McLin Creek was not included in the 1995 Basinwide Plan, except that it was listed as a tributary of Lyle Creek. Lyle Creek Watershed Management Strategy The 1995 Basinwide Plan also reported on a water quality modeling study of Lyle Creek conducted by the North Carolina Division of Environmental Management (NC DEM) in 1988 (NC DEM 1995). The 1988 modeling study was reportedly conducted to evaluate a request from the City of Conover for an increased WWTP wasteload allocation. The 1988 modeling study is not provided in the 1995 Plan, but reportedly included the entire Lyle Creek watershed and concluded that oxygen -consuming substances had been "over allocated" under previous wasteload allocation procedures (NC DEM 1995). The 1988 modeling study provided the basis for the Lyle Creek Watershed Management Strategy. Based on the 1988 watershed model findings, a Lyle Creek Watershed Management Strategy was implemented to control oxygen -consuming wasteloads and protect the ambient (i.e., in -stream) dissolved oxygen standard in the creek. Specifically, the watershed management strategy has been applied to expanding WWTPs in the Lyle Creek watershed stating that NPDES discharges will receive BOD5 and ammonia limits that hold their load of oxygen -consuming wasteloads constant (i.e., no increase in BOD5 or ammonia loads will be approved). Effluent discharge limits on oxygen -consuming wasteloads at proposed new facilities in the Lyle Creek watershed were also applied based on the watershed management strategy. 1999 Catawba River Basinwide Water Quality Plan The 1999 Catawba River Basinwide Plan recommended continuing to apply the Lyle Creek Watershed Management Strategy. The 1999 plan does not report water quality measurements collected from the Lyle Creek watershed. The benthic macroinvertebrate monitoring station on Lyle Creek at Highway 70 was re -surveyed in 1997 and was again assigned a "Good" rating. A benthic macroinvertebrate monitoring station was added in McLin Creek at a location 0.2 miles upstream of the Old Catawba Road 6 Hydro Analysis bridge (Figure 2). The McLin Creek station was also assigned a "Good" rating based on the benthic survey in 1997 (NC DENR 1999). 2004 Catawba River Basin wide Water Quality Plan The 2004 Catawba River Basinwide Plan does not report water quality measurements collected from the Lyle Creek watershed, but reports benthic macroinvertebrate survey ratings in tabular form. The 2004 plan lists the benthic ratings of Lyle Creek (monitored at the Highway 70 bridge) as having been "Good -Fair" from each of three surveys conducted in 1992, 1997, and 2002. The 2004 plan lists the benthic rating of McLin Creek (monitored 0.2 miles upstream of the Old Catawba Road bridge) as having been "Good -Fair" from each of two surveys conducted in 1997 and 2002 (NC DENR 2004). 2010 Catawba River Basinwide Water Quality Plan The 2010 Catawba River Basinwide Plan also does not provide water quality measurements, but does provide the results of benthic and fisheries monitoring surveys. The 2010 Plan states that a McLin Creek benthic monitoring survey conducted in 2007 resulted in a rating of "Fair." This benthic rating triggered an impaired status for McLin Creek for not supporting aquatic life (NC DENR 2010). As a result, McLin Creek was placed on a list of impaired waters and is described as requiring mitigation to restore aquatic life support status. The 2010 Plan states that Lyle Creek had been assigned a "Good - Fair" benthic rating based on a 2007 survey and had been assigned an "Excellent" fisheries rating based on a 2004 survey. Due to the impaired aquatic life listing, a restoration opportunities summary was provided for McLin Creek as part of the 2010 Plan. The plan describes lower reaches of McLin Creek as being adjacent to agricultural properties and opines that the "Fair" benthic rating, based on the 2007 survey, was likely due to adverse impacts of agricultural and industrial stormwater runoff. The plan also states that; "Stormwater runoff may have had more of an impact due to drought causing the runoff to be more concentrated. The biological community is expected to improve as normal rainfall levels return." (NC DENR 2010). The 2010 Basinwide Plan does not mention the McLin Creek WWTP as a potential cause of aquatic life impairment in the creek. 2.4 Summary of Observations The review of available Lyle Creek and McLin Creek -related studies and information (excluding the 2007 Lower Lyle Creek study described in Section 3) yields the following observations: 1. There is a paucity of hydrologic information available, with the exception of high -flow (i.e., flood) event conditions. 2. There is also very little water quality information available. 3. NC DENR Basinwide Water Quality Plans developed over the past 20 years do not appear to have included water quality measurements, but do provide biological survey results; 4. Based on a 1988 water -quality model, the Lyle Creek watershed was determined to be over - allocated for oxygen -consuming wasteloads (NC DENR 1995); 7 Hydro Analysis 5. Based on the 1988 water -quality model, a Lyle Creek Watershed Restoration Strategy was implemented to hold wasteloads in the watershed constant (NC DENR 1995); 6. Over the past 20 years, Lyle Creek biological surveys have consistently resulted in ratings of acceptable biological status. 7. In 2010, McLin Creek was listed as impaired for failure to support aquatic life, based on a 2007 benthic macroinvertebrate survey (NC DENR 2010). The DNER 2010 report opined that a drought, combined with stormwater runoff from industrial and agricultural areas were the causes of the non -supporting benthic rating obtained in 2007. The review of available studies enhanced our understanding of the Lyle Creek watershed. 8 Hydro 3.0 Review of 2007 Lyle Creek Water Quality Modeling Analysis 3.1 Overview In 2007, a wasteload allocation (WLA) study was conducted on Lyle Creek in support of the City of Hickory's plan to expand the Catawba WWTP to a discharge flow of 3.0 MGD from 0.225 MGD. The City of Hickory is located at the headwaters of Lyle Creek in the northwestern end of the basin and the Catawba WWTP is situated near the mouth of Lyle Creek (Figure 1). The 2007 study featured a field program and water quality modeling analysis. The study was designed and conducted to provide a scientific basis for increasing the Catawba WWTP's wasteload allocation (ENSR 2007). The 2007 Lyle Creek study area is shown in Figure 3, with green lines across the creeks indicating upstream boundaries and a red line across Lyle Creek indicating the downstream boundary. The Catawba WWTP discharges to Lyle Creek at a location 0.6 miles from the confluence with the Catawba River. The study area was bounded upstream at the Highway 70 bridge (at RM 3.5) and downstream at the mouth of Lyle Creek (RM 0.0), spanning a total of 3.5 miles. McLin Creek is included as a tributary boundary, entering Lyle Creek at RM 1.5. The study focused on determining the Toad of the oxygen -consuming substances BOD5 and ammonia from the Catawba WWTP that Lyle Creek could assimilate while still maintaining ambient dissolved oxygen concentrations (DO) above the minimum water quality standard of 5.0 mg/L. A field data collection program was conducted under drought conditions in July and August 2007. The field program featured six water quality sampling events, several river flow measurements, water level measurements, and a time of travel study (featuring release and tracking of dye in the river). The modeling analysis was conducted using the hydrodynamic model, DYNHYD, and the water quality model, WASP. A partial description of the 2007 field program and water quality modeling analysis is provided below. The reader is referred to the modeling report for a full summary of the 2007 Lower Lyle Creek modeling analysis (ENSR 2007). This review is focused on the overall approach of the 2007 modeling analysis and specification of model upstream and tributary boundaries. 3.2 Field Program The field program conducted in support of the Lower Lyle Creek modeling analysis resulted in several findings including: 1. The field program captured severe drought conditions in July and August 2007 resulting in worst -case conditions in terms of low flow, heat, and lack of rainfall. Specifically, the 7Q10 for Lyle Creek is 16 cfs and is higher than any streamflow measurements collected during the summer of 2007 field program (ENSR 2007). Thus, the 2007 field program captured low flow conditions that were lower than the 7Q10 in the study area. 2. Streamflow and water quality measurements were collected in Lyle Creek and McLin Creek. This may be obvious, but it is important because the measurements obtained from these creeks during the summer of 2007 are the only measurements found in available reports. Streamflow, 9 Hydro DO, BOD5, ammonia, and other parameter concentrations were measured at up to 10 locations during up to 6 sampling events in July and August 2007. 3. The flow of water near the mouth of Lyle Creek was observed to reverse direction intermittently due to dam operations in the Catawba River system. A time of travel study (i.e., dye study) found that the water flowed efficiently out of Lyle Creek (i.e., residence time of water in this area was short) and was not significantly delayed by intermittent flow reversals. The 2007 field program captured hydrologic and water quality conditions during a low -flow summertime period. Field measurements collected at the upstream Lyle Creek and McLin Creek tributary model boundaries are summarized below. Upper Lvle Creek Field Measurements The upstream boundary of the 2007 model was the Highway 70 bridge over Lyle Creek. Table 1 provides measurements collected at the Highway 70 bridge during the summer of 2007. Key flow and water quality measurement values ranged as follows: • Streamflow: 1.9 to 9.0 cfs • BOD5 Concentrations: 2.0 to 9.4 mg/L • Ammonia Concentrations: 0.036 to 0.056 mg/L • DO Concentrations: 7.7 to 9.7 mg/L These field measurements provided the basis for establishing model boundary conditions. Table 1. Field measurements collected at the Lyle Creek upstream boundary Sampling Streamflow cBOD5 BOD5 BOD30 b Ammonia D.O. Tem erature Date (cfs) (mg/L) (mg/L) (mg/L) (mg/L) (mg1L) (deg C) July 5, 2007 9.00 R R - 0.056 9.72 23.24 July 10, 2007 July 31, 2007 8.26 5.74 4.1 U 9.4 4.1 U 2 U 11 0.052 - 0.036 J 9.71 7.74 24.37 23.04 August 1, 2007 3.94 NA NA NA NA NA NA August 15, 2007 1.92 4.4 4.2 U - 0.04 J 8.68 25.6 August 20, 2007 3.52 NA NA NA f NA 8.32 25.6 Notes: Source: ENSR 2007 _ "R" = QC indicates that the data are unusable "U" = Below reporting limit "J" = Estimated value between reporting limit and minumum detection limit "NA" = Not analyzed i 10 Hydro McLin Creek Field Measurements A tributary boundary of the 2007 model was located at the confluence of McLin Creek with Lyle Creek. Field measurements were collected at the Old Catawba Road bridge over McLin Creek and applied as the McLin tributary boundary conditions in the model. Table 2 provides measurements collected at the Old Catawba Road bridge during July and August 2007. Key flow and water quality measurements values ranged as follows: • Streamflow: 1.2 to 9.7 cfs • BOD5 Concentrations: 2.0 to 12 mg/L • Ammonia Concentrations: 0.036 to 0.11 mg/L • DO Concentrations: 7.2 to 9.4 mg/L These field measurements provided the basis for establishing model boundary conditions, as described below. Table 2. Field measurements collected at the McLin Creek tributary boundary Sampling Streamflow cBOD5 (mg/L) BOD5 (mg1L) BOD30 (mg1L) L Ammonia D.O. ;Temperature I (mg1L) (mglL) j (deg C) Date (cfs) July 5, 2007 5.05 R R - 0.06 9.38 22.07 July 10, 2007 5.54 4.1 U 12 9.6 0.06 9.33 23.47 July 31, 2007 9.73 2 2 U - 0.036 J k 7.73 E 21.88 Au_gust 1, 2007 5.40 NA NA NA NA NA NA August 15, 2007 9.21 3 2 U - 0.11 J 7.9 25.46 August 20, 2007 1 = E NA NA NA NA 7.15 24.55 Notes: Source: ENSR 2007 L ! "R" = QC indicates that the data are unusable "U" = Below reporting limit "J" = Estimated value between re "NA" = Not analyzed orting limit and limit minumum detection _ 3.3 Lower Lyle Creek Model Setup and Application The 2007 modeling analysis was focused on determining the load of the oxygen -consuming substances, BOD5 and ammonia, from the Catawba WWTP that Lyle Creek could assimilate while still maintaining ambient dissolved oxygen concentrations (DO) above the minimum water quality standard of 5.0 mg/L. The modeling evaluation was conducted using the hydrodynamic model, DYNHYD, and the water quality model, WASP. These are widely -used, public domain models that were appropriate tools to support the WLA study. 11 Hydro The Lyle Creek water quality model was setup and calibrated using field measurements collected during the summer of 2007 and other available information. The model was then applied to simulate a set of "what if" scenarios using different increased Catawba WWTP effluent discharge conditions during the summer low -flow period. The model was applied to predict ambient water quality conditions, primarily focusing on ambient DO in Lyle Creek. The model predicted ambient water quality conditions associated with each Catawba WWTP effluent discharge scenario. Using this approach, the 2007 modeling analysis sought to identify the largest WLA that the Catawba WWTP could receive without resulting in a violation of the minimum DO standard of 5.0 mg/L in Lyle Creek. The modeling report concluded that "Scenario #3" featuring Catawba WWTP flow of 3.0 MGD, BOD5 of 5 mg/L, ammonia of 2 mg/L and effluent DO of 6.0 mg/L was predicted to result in no exceedances of the ambient DO standard of 5.0 mg/L (ENSR 2007). This scenario represented a significantly increased wasteload allocation compared to the Catawba WWTP's previous NPDES permit conditions of 0.225 MGD and a BOD5 of 30 mg/L. Model upstream and tributary boundaries in the Lower Lyle Creek model are summarized below. Upstream and tributary model boundaries are important because they represent constraints relative to the Upper Lyle Creek and McLin Creek water quality modeling analyses described in Section 4 below. Upstream and Tributary Boundary Conditions The 2007 model specified the upstream Lyle Creek and McLin Creek tributary modeling boundaries based on measurements collected during the summer 2007 field program. Streamflows were specified using regression equations that included measured streamflows and precipitation records for the period of July 31 through August 20 (ENSR 2007). Figure 4 provides daily average streamflows applied to the model at the upstream Lyle Creek boundary (top) and tributary McLin Creek boundary (bottom). Streamflows from Upper Lyle Creek ranged from 3.2 to 5.2 cfs and flows from the McLin Creek tributary ranged from 5.4 to 5.6 (with the exception of higher flows on August 4th) Daily water quality boundary conditions were established by interpolating between field measurements event values during the summer 2007 field program (Tables 1 and 2). In addition, ultimate BOD estimates were calculated, using the ratio of BOD5 to BOD30, known as an f-factor, and were applied to the model. BOD30 laboratory analyses were performed on only one set of water quality samples (collected on July 10, 2007). Based on review of the 2007 report, it is not entirely clear how the f-factor was calculated and applied during the modeled time period of July 31 to August 20, 2007. Through a combination of field data interpolation and ultimate BOD calculations, the following ranges of water quality boundary conditions were applied to represent the upstream Lyle Creek boundary conditions (ENSR 2007). Upstream Lyle Creek Boundary Conditions • Streamflow: 3.2 to 5.2 cfs • Ultimate cBOD Concentrations: 10.8 to 24.7 mg/L • Ammonia Concentrations: 0.036 to 0.056 mg/L • DO Concentrations: 7.7 to 9.7 mg/L 12 Hydro The 2007 report states that BOD5 measurements ranging from 2 to 4.2 mg/L and a BOD30 measurement of 11 mg/L were used to obtain ultimate cBOD concentrations ranging from 10.8 to 24.7 mg/L. It is not clear how the ultimate cBOD estimates were obtained. McLin Creek Model Boundary Conditions McLin Creek tributary boundary conditions were apparently established following the same methodology as described for the Lyle Creek upstream boundary above. The specific values used are not provided in the modeling report. The ranges of McLin Creek tributary boundary conditions can be readily obtained from the daily streamflow figure (Figure 4) and water quality field measurements (Table 2), with the exception of the ultimate BOD values, as follows: • Streamflow: 5.4 to 5.6 cfs • Ammonia Concentrations: 0.036 to 0.11 mg/L • DO Concentrations: 7.2 to 9.4 mg/L 3.4 Summary In summary, the 2007 modeling analysis simulated flow and water quality conditions in the Lower Lyle Creek study area during low -flow, summertime conditions. Under the successful "Scenario #3", ambient DO in Lower Lyle Creek was predicted to be very close to, but not below, the water quality standard of 5.0 mg/L. As a result, there does not appear to be significant assimilative capacity for additional loading of oxygen -demanding substances available in the Lower Lyle Creek study area. Streamflow and water quality measurements and modeled boundary conditions at the Lyle Creek upstream boundary and the McLin Creek tributary boundary were evaluated and provide useful data and information. 13 Hydro / uS:TO Claremont f �� 2007 Water Quality Study Area Upstream Boundaries of 2007 Model \Downstream Boundary of 2007 Model '\. Stream /\/ Roads and Highways Lake, Pond or River WWTP Municipal Boundary Watershed (HUC 12) Lyle Creek McLin Creek Miles 0 0.25 0.5 NADt33 North Carolina State Plane Feet. Data from National Hydrography Database (NHD) and NC DOT Name: 3_2007StudyArea 02123013 Date: 2/14/2013 Figure 3. 2007 Lower Lyle Creek Modeling Study Domain 14 Hydro Analysis Figure 3-2 Calculated daily average flow rate at Lyle Creek upstream model boundary Station t.C1a Figure 34. Calculated deity average lbw rate at AActin Creek tributary model boundary Station MCI 4100 5.00 4,00 aoo. ion 1.:1111111iB 1111 htf://:944"/":44P:fiti :////11/ Figure 4. Daily Average Flows at the Upstream Lyle Creek (top) and McLin Creek tributary (bottom) Applied in the Lower Lyle Creek Model (excerpted from ENSR 2007). 15 Hydro Analysis 4.0 Draft Modeling Analysis Work Plan The proposed simple water quality modeling analysis of Upper Lyle Creek and McLin Creek will focus on determining the assimilative capacity of the creeks to receive additional WWTP wasteloads. The modeling analysis will simulate oxygen -consuming substances, BOD and ammonia, and their effect on ambient (i.e., in -stream) dissolved oxygen (DO) concentrations in McLin Creek and Lyle Creek. The modeling analysis will predict whether specific loadings of oxygen -consuming substances to the stream will result in the reduction of ambient DO concentrations to levels below the water quality standard of 5 mg/L in Lyle Creek or McLin Creek. The objective of the Upper Lyle-McLin Creek modeling analysis is to provide sufficient information to support determination of the acceptability of increasing the WLA to these creeks. Our conceptual approach for conducting a modeling analysis to achieve this objective and a description of the model setup and application process are provided below. 4.1 Conceptual Approach The Upper Lyle-McLin Creek modeling analysis will be consistent with and built -upon the 2007 modeling analysis. The analysis will simulate steady-state, summetime low -flow conditions, based the 2007 conditions. Use of a steady-state model is appropriate for Upper Lyle Creek and McLin Creek because, under low -flow conditions, flows and wasteloads are relatively constant. Also, the steady- state model may be applied to simulate various scenarios (e.g., with different flows and wasteloads) to support evaluation of assimilative capacity under different conditions. The Upper Lyle-McLin Creek model's physical configuration will Zink with the 2007 Lower Lyle Creek model such that the upstream boundaries of the 2007 Lower Lyle Creek model will serve as Upper Lyle-McLin model downstream compliance points. The Upper Lyle-McLin Creek model will simulate the combined flow and water quality characteristics of the ambient river and the VVWTPs discharges and will support comparison of water quality conditions to those obtained in the 2007 model. The modeling analysis will be subject to the following two constraints: 1. The concentrations of oxygen -demanding substances (BOD and ammonia) entering the Lower Lyle Creek reach must be less than or equal to the concentrations used in the 2007 model simulations; and 2. The ambient dissolved oxygen concentration in the model study area must be above the water quality standard of 5.0 mg/L at all times and locations. These constraints were selected to ensure that the conditions simulated in the Upper Lyle-McLin Creek 2013 model are consistent with 2007 drought conditions and comply with the water quality standard. 4.2 Model Selection The QUAL2K model has been tentatively selected for the Upper Lyle-McLin Creek modeling analysis because it is a straightforward, widely -used, public -domain modeling tool. QUAL2K is a water quality model for streams and rivers that is available and supported by the United Stated Environmental 16 Hydro Protection Agency (USEPA) Region 4. The model incorporates many components of water quality including BOD and ammonia effects on ambient dissolved oxygen concentrations, as described in the QUAL2K User's Manual (Chapra 2008). The model requires a number of inputs in order to evaluate water quality as a function of centerline distance. The model is one-dimensional and does not incorporate lateral conditions that may impact flow, current speed, or water quality. QUAL2K simulates hydrology and water quality in streams and contains all of the characteristics required to support Upper Lyle-McLin Creek modeling objectives. Equally importantly, NC DENR staff are familiar with QUAL2K and the model has a relatively easy -to -use interface. These features will facilitate a transparent modeling and model review process. For these reasons, QUAL2K is a good choice to support the Upper Lyle-McLin Creek modeling analysis. 4.3 Physical Model Domain Setup Physical characteristics required to setup the model include stream width, slope, centerline distances (i.e. reach length), and Manning's roughness (n). River slope and centerline distances will be obtained from a recent FEMA Flood Insurance study that includes flood profile sheets with stream distance and streambed elevations throughout the study area (FEMA 2007). Stream widths will be estimated based on site reconnaissance visits and Manning's n will be initially estimated based on site information (e.g., stream substrate) and literature values. Upper Lyle Creek is defined as the portion of Lyle Creek above the Highway 70 bridge, drains a total of 43.6 square miles, and has several large sub -watersheds and tributaries. As shown in Figure 5 and compiled in Table 3, these sub -watersheds were delineated and their drainage areas calculated. A headwaters watershed of 19.9 square miles (46% of the Upper Lyle Creek sub -watershed) drains to a location just above the Conover Northeast WWTP. Bakers Creek, Mull Creek and several other tributaries drain to Upper Lyle Creek as it flows toward the Catawba. These tributaries will be included in the physical specification of Upper Lyle Creek in the model. A conceptual diagram of the physical configuration of the Upper Lyle Creek model domain is provided in Figure 6. This model domain will include several tributary sources and the Conover Northeast WWTP discharge. The conceptual diagram of the physical configuration of the McLin Creek model domain is provided in Figure 7. This model domain is relatively simple because the downstream distance is shorter and there are no large tributaries along the reach of the creek included in this analysis. The City of Claremont's McLin Creek WWTP is situated 2.5 miles upstream of the confluence with Lyle Creek. 4.4 Hydrologic Model Setup The hydrologic model will be setup using the low -flow conditions established in the 2007 model. For Upper Lyle Creek, the total flow at Highway 70 will be distributed proportionately to upstream tributaries based on watershed drainage area (as shown in Figure 5). The sub -watershed area and percent of total drainage area used to estimate proportional flow is provided in Table 3. For model input, a simplified tributary boundary condition scheme will likely be adapted. For example, the Trib. 1 and Mull Creek sub -watersheds may be combined and represented as a single tributary source in the model. 17 Table 3. Upper Lyle Creek Watershed Areas and Flow Proportions Sub -watershed & Tributary Rivermile of Sub -watershed % of Upper Lyle above Highway 70 bridge Confluence area (sq miles) Creek Area & Flow Headwaters 10.3 19.9 46% Bakers Creek 9.7 6.8 16% Unnamed Trib 7.1 2.7 6% Central Watershed NA 4.1 5.0 ' 9% Mull Creek 5.5 11% Trib 1 5.4 1.3 3% Lower Watershed NA 3.8 9% For McLin Creek, the total flow at the Old Catawba bridge was assumed to be the same as the flow above the McLin Creek WWTP (except for the WWTP flow itself). This simplifying assumption appears to be appropriate because of the relatively short distance and small watershed area associated with the McLin Creek reach. Actual flows from the Conover Northeast WWTP and McLin Creek WWTP for August 2007 were obtained from discharge monitoring reports (DMRs) and are presented in Tables 4 and 5, along with NPDES-permitted conditions. As shown in Table 4, the Conover Northeast WWTP was operating at approximately one-third of permitted flow and one -tenth of permitted BOD5 concentration during the August 2007 period. During August 2007, the McLin Creek WWTP was operating at approximately 60% of permitted flow and 90% of permitted BOD5 concentration (Table 5). Table 4. Conover Northeast WWTP Effluent Characteristics Conover Northeast WWTP Parameters Actual Aug. 2007 Existin Effluent NPDES Permit Characteristics 1 Conditions (monthly ave.) (monthly ave.) Flow 0.559 MGD 1.5 MGD BOD5 concentration (summer) 0.7 mg/L 8.0 mg/L NH3 as N concentration (summer) 0.56 mg/L 2.0 mg/L Dissolved Oxygen concentration 7.23 mg/L 5.0 mg/L ' Source: City of Conover 2007 18 Hydro Table 5. McLin WWTP Effluent Characteristics McLin Creek WWTP Parameters Actual Aug. 2007 Existing Effluent NPDES Permit Characteristics 1 Conditions (monthly ave.) 0.174 MGD (monthly ave.) 0.3 MGD Flow BOD5 concentration (summer) 7.1 mg/L 8.0 mg/L NH3 as N concentration (summer) 0.9 mg/L 2.0 mg/L Dissolved Oxygen concentration 7.12 mg/L 5.0 mg/L Source: Woodard & Curran 2007 4.5 Water Quality Model Setup Water quality model set up will feature specification of a suite of water quality parameter values at upstream boundaries, tributary boundaries, and at the WWTP effluent discharge locations. Locations of water quality boundary conditions in Lyle and McLin Creek are shown in schematic Figures 6 and 7. Water quality parameters specified will include: • Temperature • Dissolved oxygen concentration • cBOD concentration • Ammonia concentration Upstream (situated above the Conover Northeast WWTP in Lyle Creek and above the McLin Creek WWTP in McLin Creek) and tributary water quality conditions will be estimated based on available data. Actual WWTP discharge water quality conditions from August 2007 time period are provided in Tables 4 and 5 and will be applied to setup the water quality model. Selection of appropriate water quality rate coefficients is a critical step in the model setup process. Coefficients specifying the rates of several key biological and chemical processes will be selected based on available guidance and literature (e.g., Bowie et al. 1985). These rate coefficients are important because they specify the rates at which reactions controlling the consumption and generation of ambient dissolved oxygen occur. A number of natural processes that occur in a water body have an effect on the availability of DO in the water body. These rates include carbonaceous and nitrogenous oxygen consumption and surface re -aeration rate. Values for these rates will be carefully selected and documented as part of the modeling process. 19 Hydro 4.6 Application of the Water Quality Model The QUAL2K model of Upper Lyle Creek and McLin Creek will be a simple model designed to assess the potential effects of small WWTP wasteloads on ambient water quality. The model will be set up and run using available physical, hydrologic and water quality data and parameter values as described above. Upper Lyle-McLin Creek Model will be applied to simulate two types of scenarios: 1. August 2007 conditions, with creek hydrologic and water quality conditions associated with the 2007 summertime drought period. This type of scenario will be simulated using (a) actual August 2007 WWTP characteristics and (b) NPDES permitted WWTP characteristics, as presented in Tables 4 and 5. These modeling analyses will support evaluation of whether the existing NPDES-permitted WLAs are acceptable in terms of ambient water quality in Lyle Creek and McLin Creek. 2. Auqust 2007 conditions; with various increased wasteload conditions, This type of scenario will support evaluation of assimilative capacity of the river system to receive increased WLA. Increased wasteloads will be specified for the Conover Northeast WWTP and/or the McLin Creek WWTP and the model will be applied to predict the ambient water quality conditions resulting from these increased wasteloads. We will coordinate closely with NC DENR modeling staff in setting up and applying the Upper Lyle Creek and McLin Creek models. 20 Hydro Analysis Headw'ters Watershed t a 19.9 q. mil Lyle and McLin Creek Watersheds Stream Bakers Creek Watershed •6:8\q. mites Unnamed) rib. Watershed 2.7 sq; miles 1 Watershed 1.3�qlmiles Centra Watershed SSr 4.1 sq. miles, J, Conover J _^ NE WWTP -`-1.ao er Water•' 3.8 sq. miles ull Cr 1t Watersh d� 1 Ssq.'1nilW Lake. Pond or River /\/ Roads and Highways n Lyle Creek Watershed draining to U.S. 70 A Miles 0 0.5 1 NADa3 North Groins Stale Plane Feet, Data from National Hydrography Database INFO) Name: 5_VatitershedsDetin Figure 5. Lyle Creek Watershed with sub -watershed delineations 21 Hydro Date: 2/14,2013 Analysis Upper Lvle Creek Headwaters: Q, T, DO, BOD, NH3 77 Conover Northeast WWTP Outfall Q, T, DO, BOD, NH3 G_ Tributary Inflows 77� Representing Bakers Creek, Mull Creek, and other tributaries Q, T, DO, BOD, NH3 10 40 Figure 6. Conceptual Schematic of Upper Lyle Creek Model Domain 22 Hydro McLin Creek: Q, T, DO, BOD, NH3 McLin Creek �� WWTP O utfa II �{O� �c) Q, T, DO, BOD, NH3 C°,> Figure 7. Conceptual Schematic of McLin Creek Model Domain 23 Hydro Analysis 5.0 References Chapra, S.C., Pelletier, G.J. and Tao, H. 2008. QUAL2K: A Modeling Framework for Simulating River and Stream Water Quality, Version 2.11: Documentation and User's Manual. Civil and Environmental Engineering Dept., Tufts University, Medford, MA. City of Conover 2007. Effluent Discharge Log for City of Conover NEWWTP, NPDES Permit No. NC00024252, August 2007. Davis & Floyd 2011. Preliminary Engineering Report for Catawba County, N.C., McLin/Lyle Creek — Basin Study, Catawba County, Newton, NC, Davis & Floyd Job No. 041016.00, December 2011. Bowie, G.L. , Mills, W.B., Porcella, D.B., Campbell, C.L., Pagenkopf, J.R., Rupp, G.L., Johnson, K.M., Chan, P. W.H. 1985, Gherini, S.A. Rates, Constants, and Kinetics Formulations in Surface Water Modeling (Second Edition). Tetra Tech, Inc. for the Environmental Research Laboratory, Office of Research and Development, U.S. Environmental Protection Agency, Athens, GA. EPA/600/3-85/040. ENSR 2007. Wasteload Allocation Study for the Hickory Catawba WWTP, Catawba, North Carolina. Prepared for HSMM, Spartanburg, South Carolina; Prepared by ENSR Corporation, Document No. 12401-001. December 2007. FEMA 2007. Flood Insurance Study. A Report of Flood Hazard in Catawba County, North Carolina. Federal Emergency Management Agency, State of North Carolina, Flood Insurance Study Number 37035CV001A. September 5, 2007. NC DEM 1995. Catawba River Basinwide Water Quality Management Plan. Prepared by: North Carolina Division of Environmental Management, Water Quality Section, Raliegh, NC. July 1995 NC DENR 1999. Catawba River Basinwide Water Quality Plan. North Carolina Department of Environment and Natural Resources, Division of Water Quality, Water Quality Section. December 1999. NC DENR 2004. Catawba River Basinwide Water Quality Plan. Prepared by: Dave Toms, NC Department of Environment and Natural Resources, Division of Water Quality - Planning, September 2004. NC DENR 2010. Catawba River Basinwide Water Quality Plan. North Carolina Department of Environment and Natural Resources, Division of Water Quality, Basinwide Planning Unit, September 2010. NC DENR 2012. Standard Operating Procedures for Benthic Macroinvertebrates. Biological Assessment Unit, North Carolina Department of Environment and Natural Resources, Division of Water Quality, Environmental Sciences Section. October 1, 2012. Woodard & Curran 2007. City of Claremont, North Carolina, Monthly Operating Report, August 2007. 24 Hydro /Y Belnick, Tom From: Behm, Pamela Sent: Friday, February 22, 2013 3:56 PM To: Belnick, Tom; Berry, Ron; Stecker, Kathy Subject: FW: Draft Upper Lyle-McLin Creek modeling work plan Attachments: Draft Upper Lyle-McLin Modeling Work Plan Feb 18 2013.pdf *************************************************************** Pam Behm NC DWQ Modeling and TMDL Unit 1617 Mail Service Center Raleigh, NC 27699 Email: pamela.behm@ncdenr.gov Phone: 919-807-6419 Fax: 919-807-6497 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Ken Hickey[mailto:khickeyCa�hydroanalysisinc.com] Sent: Thursday, February 21, 2013 12:01 PM To: Behm, Pamela Cc: Gene Haynes; Guy Slagle Subject: Draft Upper Lyle-McLin Creek modeling work plan Pam, Please find attached a draft modeling work plan for Upper Lyle and McLin Creek, as previously discussed. Please distribute this document to your team prior to our meeting on Tuesday. I look forward to talking with you about this project. By the way, do you have a projector setup that I could use during our meeting? I would like to present some Powerpoint slides to facilitate the discussion. Thank you, Ken Hickey HydroAnalysis, Inc. 978-501-5111 (mobile) 978-263-1092 (office) 1 CO/C/aAmn,%J -r Z/1//3 ;OM Belnick, Tom • Subject: Location: Mfg with Cities of Claremont and Conover 9th Floor Conference Room Start: Tue 2/26/2013 1:30 PM End: Tue 2/26/2013 3:00 PM Show Time As: Tentative Recurrence: (none) Meeting Status: Not yet responded Organizer: Behm, Pamela Required Attendees: Belnick, Tom; Berry, Ron; Stecker, Kathy Aw lake Notisf CGovvIt.4, Rt. Meeting with Cities of Claremont and Conover to discuss the draft Mclin/Lyle Creek modeling work plan, potential expansion options. Ad aafistwiAficute.4 AC - 65 eiceki4JovkVrejmia t 1 1/(r0-? 64,1 Ablif-4") 014114 €444401,1-1 eAivajd Q\JyL?I( M9 �ri+i^: 'kv7 dllyi✓e� „)on��ievicoY loakt ° QVAL h 441.1ivinelet a Mod Ake Navvi.e T� jf/YL�K Do/ (60116C gu "1-14y"le 5 •.bkA � �7 1 huitisoi lo/zS/W12_. 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Pond or Reservoir A August 20t2 Obsorvabon Points /\/ Roads and Highways Municipal Boundary Stream or RNer n Watershed (HUC 12) IMMO Mies 0 0.5 t NA063 North Carolna Stab Rand Feet Data ham Nabotil Hydrogapay Oatatane (NND1 and NC DOT Name 2_111cL,nWatarahed Dais tOr4r2O12 Figure 2. Map of McLin Creek Watershed 5 Hydro Analysis Lyle and McLin Creek Watersheds 'Th•—• Stream or River Lake, Pond or Reservoir Watershed (HUC 12) Ell Municipal Boundary County Boundary /\/ Major Highway NAD83 North Carolina State Plane Feet, Data from National Hydrography Database (NHD) and NC DOT 0 0.5 1 Name: Watersheds Date: A M' ATA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary May 4, 2011 Mr. Doug Barrick City Manager City of Claremont P. O. Box 446 Claremont, NC 28610 f�tareK-4 LK /Vovwfa•i Pvire tiv ki- n 1 ) u)n / Subject: Speculative Effluent Limits Claremont WWTPs Permits NC0032662 and NC0081370 Catawba County Catawba River Basin Dear Mr. Barrick: This letter provides speculative effluent limits for 0.25 MGD at the Claremont North WWTP, which is currently permitted at 0.10 MGD, and for 0.60 MGD and 0.85 MGD at the Claremont McLin Creek WWTP, which is currently permitted at 0.30 MGD. The Division received the speculative limits request in a letter dated March 2, 2011 from William S. Clayton of Davis & Floyd, Inc. Please recognize that speculative limits may change based on future water quality initiatives, and it is highly recommended that the applicant verify the speculative limits with the Division's NPDES Unit prior to any engineering design work. Receiving Streams. Mull Creek, the receiving stream for Claremont North WWTP, and McLin Creek, the receiving stream for Claremont McLin Creek WWTP, both flow into Lyle Creek and are part of the Lyle Creek watershed within the Catawba River Basin. Lyle Creek discharges into Lake Norman. Mull Creek and McLin Creek have stream classifications of WS-IV and WS-IV CA, respectively. Waters with the WS-IV classification have a best usage as a water supply for drinking, culinary, or food -processing purposes and for aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation and agriculture. The CA classification applies additional Nonpoint Source and Stormwater Pollution Control Criteria. Mull Creek has a summer 7Q10 flow of 1 cfs, a winter 7Q10 flow of 1.6 cfs, and an annual average flow of 5 cfs. McLin Creek has a summer 7Q10 flow of 5 cfs, a winter 7Q10 flow of 9 cfs, and an annual average flow of 26 cfs. Speculative Effluent Limits. Based on Division review of receiving stream conditions, the Lyle Creek Watershed Management Strategy, and other water quality modeling results, speculative limits were developed. The proposed expansion to 0.25 MGD at Claremont North WWTP is presented in Table 1. Page 1 of 3 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.ncwaternualitv.org NoIle Carolina �tura!ly The proposed expansions to 0.60 MGD and 0.85 MGD at Claremont McLin Creek WWTP are presented in Tables 2 and Tables 3, respectively. A complete evaluation of these limits and monitoring requirements for metals and other toxicants, as well as potential instream monitoring requirements, will be addressed upon receipt of a formal NPDES permit application. A feature of the speculative limit development include the following: • BOD/NH3/DO Limits. The Lyle Creek Management Strategy was developed to establish BOD, NH3, and DO limits for new or expanding dischargers in the Lyle Creek watershed so the dissolved oxygen water quality standard would be met in Lyle Creek prior to discharge into Lake Norman. In the case of the Claremont McLin Creek WWTP, the strategy limits had already been applied so any future expansion will be based on freezing current permitted BOD and ammonia loads (i.e., facility will not be allowed to discharge oxygen -consuming waste above what is currently permitted). The resultant limits at expanded flows of 0.25 MGD (Table 1) and 0.60 MGD (Table 2) are considered technologically -feasible. TABLE 1: Speculative Limits for Claremont North WWTP (Proposed Expansion to 0.25 MGD) Effluent Characteristic Effluent Limitations Monthly Average Weekly Average Daily Maximum Flow 0.25 MGD BOD5 summer 8.0 mg/L 12.0 mg/L BOD5 winter 16.0 mg/L 24.0 mg/L NH3 as N summer 2.0 mg/L 6.0 mg/L NH3 as N summer 4.0 mg/L 12.0 mg/L Dissolved Oxygen Not less than 5.0 mg/L, daily average TSS 30 mg/L 45 mg/L TRC 28 ug/L Fecal coliform (geometric mean) 200/100 ml 400/100 ml Chronic Toxicity Pass/Fail (Quarterly test) 28% TABLE 2: Speculative Limits for Claremont McLin Creek WWII' (Proposed Expansion to 0.60 MGD) Effluent Characteristic Effluent Limitations Monthly Average Weekly Average Daily Maximum Flow 0.60 MGD BOD5 summer 4.0 mg/L 6.0 mg/L BOD5 winter 8.0 mg/L 12.0 mg/L NH3 as N summer 1.0 mg/L 3.0 mg/L NH3 as N winter 2.0 mg/L 6.0 mg/L Dissolved Oxygen Not less than 5.0 mg/L, daily average TSS 30 mg/L 45 mg/L TRC 28 ug/L Fecal coliform (geometric mean) 200/100 ml 400/100 ml Chronic Toxicity Pass/Fail (Quarterly test) 16% Page 2 of 3 TABLE 3: Speculative Limits for Claremont McLin Creek WWTP (Proposed Expansion to 0.85 MGD) Effluent Characteristic Effluent Limitations Monthly Average Weekly Average Daily Maximum Flow 0.85 MGD BOD5 summer 2.8 mg/L* 4.2 mg/L BOD5 winter 5.6 mg/L 8.4 mg/L NH3 as N summer 0.7 mg/L 2.1 mg/L NH3 as N winter 1.4 mg/L 4.2 mg/L Dissolved Oxygen Not less than 5.0 mg/L, daily average TSS 30 mg/L 45 mg/L TRC 28 ug/L Fecal coliform (geometric mean) 200/100 ml 400/100 ml Chronic Toxicity Pass/Fail jQuarterly test) 21% *Note: BOD5 limit of 2.8 mg/L are most likely not sustainable and may be considered not technologically -feasible. More detailed review of the final design would be required. Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES permit for an expanded discharge will be issued with these speculative limits. Final decisions can only be made after the Division receives and evaluates a formal permit application for the expanded discharge. In accordance with the North Carolina General Statutes, the practicable wastewater treatment and disposal alternative with the least adverse impact on the environment is required to be implemented. Therefore, as a component of all NPDES permits applications for new or expanding flow, a detailed engineering alternatives analysis (EAA) must be prepared. The EAA must justify requested flows and provide an analysis of potential wastewater treatment alternatives including justification for not connecting to the City of Hickory WWTP. A copy of Division guidance for preparing EAA documents is attached. State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document must be prepared for all projects that: 1) need a permit; 2) use public money or affect public lands; and 3) might have a potential to significantly impact the environment. For existing discharges, significant impact is defined as an expansion of > 500,000 gpd additional flow. Since Claremont is proposing expansions < 500,000 gpd flow, the SEPA document and evaluation are not required. Should you have any questions about these speculative limits or NPDES permitting requirements, please feel free to contact Ron Berry at (919) 807-6396 or Tom Belnick at (919) 807-6390. Respectfully, Tom Belnick Supervisor, NPDES Complex Permitting Unit cc: Mooresville Regional Office/Surface Water Protection Kathy Stecker/Modeling TMDL Unit Central Files NPDES Permit Files/NC0032662 and NC0081370 Page 3 of 3 DIVISION OF ENVIRONMENT MANAGEMENT March 21,1994 MEMORANDUM TO: Ruth Swanek Steve Bevington FROM: Jacquelyn M. Nowell/so,. SUBJECT: Lyle Creek Management Strategy This strategy was developed in 1988 when the Town of Conover -Northeast (discharging into Lyle Creek) requested an expansion to 1.5 MGD. The Lyle Creek watershed has several other municipalities discharging into the system, Pine Ridge Subdivision, Bunker Hill H.S., Claremont North (Huffman Branch), Claremont South (UT McLin Creek), Conover SE (McLin Creek), Witherspoon Crossroads (Hagans Fork), and the Town of Catawba (Lyle Creek ). Level B model results for the Conover expansion showed interaction between the dischargers and predicted a DO minimum of 5 mg/l downstream,below the Town of Catawba near the mouth of Lyle Creek. The limits developed in 7/88 for Conover NE to protect the DO standard were 8/2/5 and 16/4/5. After consultation with supervisors (Trevor Clements and Dave Vogt), it was decided to assign the same limits to proposed and expanding facilities in the Lyle Creek watershed because of the potential for water quality problems in the backwaters of Lake Norman (mouth of Lyle Creek). This strategy has been implemented since 1989 for any expanding or proposed discharger in the basin. Facilities that have received 8/2/5 and 16/4/5 limits based on this strategy are Claremont -Southwest (permit rescinded due to lack of construction), Rock Barn Properties (renewed 2/94) and proposedClaremont-McLin Creek WWTP. In May, 1991, Tech Support responded to Construction Grants that The Town of Claremont - South WWTP upon expansion could receive 1) existing BOD5 loading capacity or 2) limits equivalent to Conover NE WWTP (8/2/5 & 16/4/5). Attached is the original model run for the Conover NE expansion, based on the DO minimum of 5 mg/1 in the last reach just before entering Lake Norman, Tech Support had implemented the 82/5 limit strategy. cc: WLA File inC.LikGyvtif rrlJ // Crrf�' Ly/1e'CveK _(hNui, / Conover NE WWTP 1.5 MGD BOD= 8/16 NH3 =2/4 DO =5 Pine Ridge Subdivision WWTP 0.02 MGD (inactive) BOD=30 NH3=MONITORED DO=NO REQUIREMENTS • C00 0872 UPS Ground (Overnite) WWTP 0.003 MGD (inactive) BOD=30 NH3=MONITORED DO=NO REQUIREMENTS Conover SE WWTP 0.3 MGD BOD=30 NH3=2/5.2 DO=5 Claremont North WWTP 0.1 MGD l I BOD=30 NH3=MONIT fifE—' DO=5 CATAWBA RIVER BASIN, LYLE CREEK SUBBASIN NPDES PERMITS AS OF 4/29/11 Bunker Hill HS WWTP 0.015 MGD BOD=16/30 NH3=4.3/15 DO=6 Catawba WWTP 0.225 MGD BOD=30 NH3=MONITORED DO=NO REQIREMENTS Country Valley WWTP 0.1 MGD BOD=8/16 NH3=5.3/10 DO=MONITORED `r ' _ (ti..` .. i t rr. ,. .0ovtsw e 44 'I Belnick, Tom From: Belnick, Tom ' Sent: Thursday, November 08, 2012 3:58 PM To: Behm, Pamela Cc: Berry, Ron; Parker, Michael Subject: RE: City of Hickory - Lyle Creek Expansion Model Review zu rz,„ Crs 4')I,4&)1» ,ite4- LI(46'mmt Pam- I talked with Claremont's modeler Ken Hickey with HydroAnalysis- told him I was a "middle man" in this process. Relayed your thoughts about submitting a modeling analysis plan, which he thought was good idea. He might call you with questions. Ron- fyi. Modeling Unit will take lead with this possible extension of WASP model to evaluate Claremont expansion. If modeling results are positive, we might need to issue another spec letter down the road. Mike- fyi. Claremont evaluating possibility of expansion, based on impasse with connection to Hickory/Catawba WWTP. Tom Belnick Supervisor, NPDES Complex Permitting Unit NCDENR/Division of Water Quality 919-807-6390 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties Original Message From: Behm, Pamela Sent: Thursday, November 08, 2012 12:02 PM To: Belnick, Tom Subject: FW: City of Hickory - Lyle Creek Expansion Model Review Original MTU comments on Lyle Creek model are attached. The consultant for Claremont has the model and report. I would suggest that you require that Claremont submit a modeling analysis plan to NPDES to describe how they would intend to use the model to evaluate the impact of their discharge. We will review this plan. I expect there may need to be some modification to the model to more explicitly represent McLin Creek in order to evaluate local impact. *************************************************************** Pam Behm NC DWQ Modeling and TMDL Unit 1617 Mail Service Center Raleigh, NC 27699 Email: pamela.behm(tncdenr.gov Phone: 919-807-6419 Fax: 919-807-6497 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. Original Message From: Pam Behm[mailto:pamela.behm(alncmail.net] Sent: Thursday, May 22, 2008 1:45 PM 1 To: Susan Wilson; Sergei Chernikov; Jackie Nowell; Kathy Stecker; Hannah Stallings; dianne.reid Subject: City of Hickory - Lyle Creek Expansion Model Review Hello everyone, Attached is the review of the Lyle Creek Model developed by ENSR to assess the feasibility of an expansion of the Hickory Catawba WWTP from 0.225 MGD to 3.0 MGD. The way this memo is written, you will need to have the report and memorandum submitted by ENSR to refer to specific pages and figures. Hannah and Dianne- I included you on this because.I know you are involved with the EA part of this. Let me know if you have any questions. Thanks. Pam 2 NC Division of Water Quality Planning Section — Modeling & TMDL Unit Technical Memorandum May 22, 2008 TO: Kathy Stecker, Modeling and TMDL Unit FROM: Pam Behm, Modeling & TMDL Unit CC: Susan Wilson, Western NPDES Unit Sergei Chernikov, Western NPDES Unit Jackie Nowell, Western NPDES Unit Dianne Reid, Basinwide Planning Unit Hannah Stallings, Basinwide Planning Unit Trish MacPherson, Biological Assessment Unit RE: Lyle Creek WASP Model Review The Modeling and TMDL Unit (MTU) has reviewed the documentation listed below to evaluate the effect of a 3.0 MGD discharge from Catawba WWTP (NC0025542) on dissolved oxygen (DO) concentrations in Lyle Creek. A summary of the MTU's review is provided below: 1. Documentation: a. Wasteload Allocation Study for the Hickory Catawba WWTP, Catawba North Carolina (ENSR - Dec. 2007) - The initial modeling report submitted to DWQ. b. Memorandum from Ken Heim, ENSR to Pam Behm, DWQ, April 24, 2008, Subject: Comments Regarding the WASP Model of the Catawba River - After initial review of the December 2007 report, MTU reported to the Western NPDES Unit that the report was not complete as submitted and more information was needed to evaluate the model. ENSR responded with the memorandum. c. DVD containing model input files: "Lyle Creek Model DYNHYD/WASP Input files 12401-001 ", ENSR 4/28/08 — Submitted to DWQ with the memorandum in response to an MTU comment that DWQ should have all relevant model files. 2. Limitations and Uncertainty: As always, there is uncertainty associated with interpretation of the model results. Uncertainty results from: (1) limitations within the WASP model framework, (2) assumptions made during model development, and (3) model calibration. Limitations specific to the Lyle Creek Model include: (1) the modeling time period is less than a month, although the time period does represent worst case conditions (August 2007, during a drought), (2) there are limited data points available for calibration, and (3) calibration results were provided for 2 out of the 7 monitoring stations. Pages 3-18 to 3-20 of the December 2007 Report document the results of model calibration, with the DO calibration provided on page 3-20. Model predictions are vertically averaged and represent average DO throughout the water column. The difference between measured and predicted DO is as high as 1.5 mg/L at times. In order to better understand the uncertainty associated with the model predictions, ENSR provided a sensitivity analysis in the memorandum at DWQ's request. ENSR evaluated the sensitivity of model predictions to changes in several key parameter rates. The most sensitive parameter is the sediment oxygen demand rate, which is estimated from ranges found in literature to be 4.0 g/m /day in the model. See Figure 7A in the memorandum for the results of the sensitivity analysis. The MTU recognizes the complexity of the analysis done to develop the Lyle Creek Model. Significant fieldwork was performed to provide site -specific information for model development. This included dye studies, collection of chemical and physical parameters, and flow gages. However, due to the limited number of data points, sufficient conclusion on the accuracy of the calibration and the level of uncertainty cannot be determined. Therefore the interpretation of model results and determination of speculative limits should be viewed carefully in light of this limitation. 3. Results of Loading Scenarios: Three loading scenarios based on possible permit limits for a discharge of 3.0 MGD were evaluated for this effort. Details on the three scenarios are provided in the December 2007 Report on pages 4-1 and 4-2. Results of the three scenarios at monitoring station LC7 (Lyle Creek near mouth) are provided in Figure 4-1 (page 4-3 of the report). As shown in Figure 4-1, Scenarios 1 and 2 both result in DO concentrations below 5.0 mg/L at times during the model runs, while DO remains above 5.0 mg/L for Scenario 3. Therefore, Scenario 3, 3.0 MGD flow with limits consistent with tertiary treatment and effluent aeration, is the most viable option for consideration of an expansion of discharge into Lyle Creek. The December 2007 Report provided modeling results only at station LC7, which is the most downstream monitoring station. The memorandum (mentioned above in bullet lb) resulted from DWQ's initial response that impacts of the discharge should be evaluated throughout Lyle Creek, not just at the most downstream monitoring station. The memorandum contains plots of DO longitudinally (Figure 1A) and as a time -series at each monitoring station (Figures 2A-6A). At no point in the modeling time period does Scenario 3 result in DO below 5.0 mg/L. Figure 1 provided below shows the locations of the monitoring stations and their associated model segments. Figures 2-9 provided below contain additional plots comparing current conditions (referred to as "calibration") with Scenario 3. MTU generated these figures using the model input files provided by ENSR. It should be noted that, as shown in Figure 1 A of the memorandum and in Figures 8-9 below, DO decreases longitudinally to just above 5.0 mg/L at the confluence with the Catawba River. The model predicts downstream DO concentrations will be higher than current conditions for Scenario 3, however the decreasing DO trend remains (see Figures 8-9 below). In addition, reversing flows occur in Lyle Creek due to hydropower dam releases. Because of this, MTU recommends that if speculative limits are issued for this discharge, there should be frequent monitoring at this downstream site to ensure that DO levels do not fall below 5.0 mg/L. 4. The model was not evaluated for nutrients (e.g. total phosphorus (TP) and total nitrogen (TN)). This discharge is not far from the confluence of Lyle Creek with the Catawba River/Lake Norman and the expansion to 3.0 MGD represents a huge increase from the current flow and potential nutrient load coming into Lake Norman from Lyle Creek. Therefore, to protect Lake Norman from degradation, MTU recommends that if speculative limits are issued, the Western NPDES Unit should consider the current and future TP and TN loads, and issue appropriate limits on both TP and TN. 5. MTU is concerned about the effect of the increased discharge on the channel morphology of Lyle Creek and the quality of the benthic community. This expansion will result in a permitted flow that is 13 times greater than what is currently permitted. Flows in Lyle Creek were calculated to be 4.8 cfs on 8/20/07 at Station LC2, which is just upstream of the discharge. This equates to about 3.1 MGD. So, in essence, a permitted discharge at 3.0 MGD will double the in -stream flow under similar flow conditions. DWQ should ensure that such a significant increase in flow does not increase erosion of the stream banks and impact the benthic community. MTU recommends that the DWQ Environmental Sciences Section (particularly Biological Assessment) have the opportunity to comment on the possible effect of the increase in discharge on the stream morphology and the condition of the benthic community. 6. MTU's interpretation of model results is based on model documentation and review of model input files. Specific questions about model development should be directed to ENSR. J �, / f 1, i l \ Upstream Variable Flow,..,. Model Boundary 'LC1 • • Trn Transact 0113100 TI T1/LCIA 0 T2 100 73 200 T4 300 75 400 76 500 77 600 TO 700 79 800 T10 900 711 72 1000 712 1100 113 1200 T14 1300 716 1400 T16 1500 717 1000 T18 1700 T19 1800 720 1900 7 721 73 2000 722 20'.ro T23 2100 724 2150 T25 2200 T26 2250 727 2300 T28 2350 T29 2400 T30 2450 Trn Transact Dlat (11) 731 2600 732 2560 T33 2600 734 2650 735 2700 T36 2750 737 2600 738 2850 739 2000 T40 2960 741 74 2000 742 3050 743 3100 744 3160 745 3200 746 3250 T47 3300 748 3350 749 3400 750 3450 751 3500 752 3560 T53 3600 754 3650 755 3700 766 3760 757 3800 758 3860 T59 3500 760 2650 Trn Transact 01st(It) 1121 711 10000 7122 10100 7123 10200 1124 10300 T126 10400 T126 10500 T127 LC2 10060 7128 10700 7129 10800 T130 10900 T131 T12 11000 T132 11100 T133 11200 T134 11300 7135 LC3 11400 T136 11500 7137 11600 1.130 11700 ` 1 _MC9_ McClin Creek Variable Flow Tributary Boundary ,•' T • Trn Transact 01s1(11) T61 TS 4000 762 4100 T63 4200 764 4300 765 4400 766 4500 T67 4600 T68 4700 769 4800 T70 4900 771 76 5000 772 5100 773 5200 774 5300 775 5400 T76 5500 T77 5600 778 5700 T79 5500 780 5900 Trn Transco 013t(6) 7130 1800 T140 1900 T141 713 2000 7142 2100 T143 2200 7144 2300 7145 LC4 2400 7146 2500 T147 2600 7148 2700 7149 2800 7150 2900 7151 714 3000 T162 3100 7163 LC5 3200 7154 3300 7155 3400 T156 3500 T157 3600 T158 3700 T159 3800 7160 311100 1161 715 4000 7162 4100 7163 420) T164 4300 7165 4400 7166 4500 T167 LC6 4600 T160 4700 T169 4800 T170 4900 Trn Transact DIM(n) T81 77 6000 782 6100 783 6200 784 6300 785 6400 786 0500 T87 6600 T88 6700 789 6800 T90 6900 791 78 7000 792 7100 793 7200 T54 7300 795 7400 T08 7600 797 7600 T98 7700 799 7800 7100 7900 Y0 ) Trn Transact 01s1(11) T171 716 16000 7172 15100 7173 15200 T174 15300 T175 LC7 15400 7176 15500 T177 15600 7178 15700 T179 15800 T180 15500 7181 T17 18000 T182 16100 7183 T18 16200 Trn Tranascl Dlst(It) 7101 Ti 8000 T102 8100 7103 8200 7104 6500 T105 841:0 7106 8544 7107 8600 T108 8700 7109 6000 7110 8900 7111 710 9040 T112 9100 7113 9200 T114 9306 T115 9400 7116 9500 1117 9600 7116 9700 7119 9800 7120 9900 ,•�. '—�;90b?i 4,000 1 •Feet Transects and Sampling Station Locations "Trn" Numbers are Coincident with WASP Segment Numbers Figure 1. Model segmentation and locations of monitoring stations. IP 8.5 8 7.5 ij; 7 O 6.5 6 5.5 5 7/31 DO - Segment 151 (at the discharge) 8/4 8/8 8/12 Date (2007) - Calibrated Scenario 3 8/16 8/20 Figure 2. DO (mg/L) at Segment 151, the location of the discharge. Calibrated refers to conditions as they existed in August 2007 and Scenario 3 represents the expansion to 3.0 MGD with tertiary treatment and DO of 6.0 mg/L. 8.5 8 7.5 7 O 6.5 6 5.5 5 DO - Segment 153 (below the discharge) 7/31 8/4 8/8 8/12 8/16 8/20 Date (2007) - Calibrated Scenario 3 Figure 3. DO (mg/L) at Segment 153, downstream of the discharge. Figure 4. DO (mg/L) at Segment 164. Figure 5. DO (mg/L) at Segment 175, the location of monitoring station LC7. 8.5 8 7.5 7 J 5) 6.5 O 6 5.5 5 4.5 DO -Segment 181 I/ 4 7/31 8/4 8/8 8/12 8/16 8/20 Date (2007) - Calibrated Scenario 3 Figure 6. DO (mg/L) at Segment 181. 8.5 8.0 7.5 7.0 - J 'irn 6.5 O 6.0 0 5.5 5.0 4.5 4.0 DO - Segment 182 (at Catawba R.) JI 7/31 8/4 8/8 8/12 Date (2007) - Calibrated Scenario 3 8/16 8/20 Figure 7. DO (mg/L) at Segment 182, at the Catawba River. 8.5 8.0 7.5 J 7.0 Of E 6.5 0 0 6.0 5.5 5.0 4.5 DO Longitudinal Profile 8/9/07 Hickory WWTP Discharge 1 0 20 40 60 80 100 Segment 120 Calibrated Scenario 3 140 160 180 Figure 8. DO longitudinal profile for 8/9/07 at 10:36. 9.0 8.5 8.0 7.5 J `a) 7.0 E 0 6.5 0 6.0 5.5 5.0 4.5 DO Longitudinal Profile 8/14/07 Hickory WWTP Discharge 0 20 40 60 80 100 Segment 120 Calibrated Scenario 3 140 160 180 Figure 9. DO longitudinal profile for 8/14/07 at 15:24. 7� 11 S'e c Om / AVA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director May 4, 2011 Mr. Doug Barrick City Manager City of Claremont P. O. Box 446 Claremont, NC 28610 Dee Freeman Secretary Subject: Speculative Effluent Limits Claremont WWTPs Permits NC0032662 and NC0081370 Catawba County Catawba River Basin Dear Mr. Barrick: This Ietter provides speculative effluent limits for 0.25 MGD at the Claremont North WWTP, which is currently permitted at 0.10 MGD, and for 0.60 MGD and 0.85 MGD at the Claremont McLin Creek WWTP, which is currently permitted at 0.30 MGD. The Division received the speculative limits request in a letter dated March 2, 2011 from William S. Clayton of Davis & Floyd, Inc. Please recognize that speculative limits may change based on future water quality initiatives, and it is highly recommended that the applicant verify the speculative limits with the Division's NPDES Unit prior to any engineering design work. Receiving Streams. Mull Creek, the receiving stream for Claremont North WWTP, and McLin Creek, the receiving stream for Claremont McLin Creek WWTP, both flow into Lyle Creek and are part of the Lyle Creek watershed within the Catawba River Basin. Lyle Creek discharges into Lake Norman. Mull Creek and McLin Creek have stream classifications of WS-IV and WS-IV CA, respectively. Waters with the WS-IV classification have a best usage as a water supply for drinking, culinary, or food -processing purposes and for aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation and agriculture. The CA classification applies additional Nonpoint Source and Stormwater Pollution Control Criteria. Mull Creek has a summer 7Q10 flow of 1 cfs, a winter 7Q10 flow of 1.6 cfs, and an annual average flow of 5 cfs. McLin Creek has a summer 7Q10 flow of 5 cfs, a winter 7Q10 flow of 9 cfs, and an annual average flow of 26 cfs. Speculative Effluent Limits. Based on Division review of receiving stream conditions, the Lyle Creek Watershed Management Strategy, and other water quality modeling results, speculative limits were developed. The proposed expansion to 0.25 MGD at Claremont North WWTP is presented in Table 1. Page 1 of 3 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.ncwaternuality.orq NorthCarolina Naturally The proposed expansions to 0.60 MGD and 0.85 MGD at Claremont McLin Creek WWTP are presented in Tables 2 and Tables 3, respectively. A complete evaluation of these limits and monitoring requirements for metals and other toxicants, as well as potential instream monitoring requirements, will be addressed upon receipt of a formal NPDES permit application. A feature of the speculative limit development include the following: • BOD/NH3/DO Limits. The Lyle Creek Management Strategy was developed to establish BOD, NH3, and DO limits for new or expanding dischargers in the Lyle Creek watershed so the dissolved oxygen water quality standard would be met in Lyle Creek prior to discharge into Lake Norman. In the case of the Claremont McLin Creek WWTP, the strategy limits had already been applied so any future expansion will be based on freezing current permitted BOD and ammonia loads (i.e., facility will not be allowed to discharge oxygen -consuming waste above what is currently permitted). The resultant limits at expanded flows of 0.25 MGD (Table 1) and 0.60 MGD (Table 2) are considered technologically -feasible. TABLE 1: Speculative Limits for Claremont North WWTP (Proposed Expansion to 0.25 MGD) Effluent Characteristic Effluent Limitations Monthly Average Weekly Average Daily Maximum Flow 0.25 MGD _ BOD5 summer 8.0 mg/L 12.0 mg/L BOD5 winter 16.0 mg/L 24.0 mg/L NH3 as N summer 2.0 mg/L 6.0 mg/L _ NH3 as N summer 4.0 mg/L 12.0 mg/L Dissolved Oxygen Not less than 5.0 mg/L, daily average TSS 30 mg/L 45 mg/L TRC 28 ug/L Fecal coliform (geometric mean) 200/100 ml 400/100 ml Chronic Toxicity Pass/Fail (Quarterly test) 28°r6 TABLE 2: Speculative Limits for Claremont McLin Creek WWTP (Proposed Expansion to 0.60 MGD) Effluent Characteristic Effluent Limitations Monthly Average Weekly Average Daily Maximum Flow 0.60 MGD BOD5 summer 4.0 mg/L 6.0 mg/L BOD5 winter 8.0 mg/L 12.0 mg/L NH3 as N summer 1.0 mg/L 3.0 mg/L NH3 as N winter 2.0 mg/L 6.0 mg/L Dissolved Oxygen Not less than 5.0 mg/L, daily average TSS . 30 mg/L 45 mg/L TRC 28 ug/L Fecal coliform (geometric mean) 200/100 ml 400/100 ml Chronic Toxicity Pass/Fail (Quarterly test) 16% _ Page 2 of 3 TABLE 3: SpecuIative Limits for Claremont McLin Creek WWTP (Proposed Expansion to 0.85 MGD) Effluent Characteristic Effluent Limitations Monthly Average Weekly Average Daily Maximum Flow 0.85 MGD BOD5 summer 2.8 mg/L* 4.2 mg/L BOD5 winter 5.6 mg/L 8.4 mg/L NH3 as N summer 0.7 mg/L 2.1 mg/L " NH3 as N winter 1.4 mg/L 4.2 mg/L Dissolved Oxygen Not less than 5.0 mg/L, daily average TSS 30 mg/L 45 mg/L TRC 28 ug/L Fecal coliform (geometric mean) 200/100 ml 400/100 ml Chronic Toxicity Pass/Fail (Quarterly test) 21% _ ote: BODS limit of 2.8 mg%L are most likely not sustainable and may be considered not technologically -feasible. More detailed review of the final design would be required. Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES permit for an expanded discharge will be issued with these speculative limits. Final decisions can only be made after the Division receives and evaluates a formal permit application for the expanded discharge. In accordance with the North Carolina General Statutes, the practicable wastewater treatment and disposal alternative with the least adverse impact on the environment is required to be implemented. Therefore, as a component of all NPDES permits applications for new or expanding flow, a detailed engineering alternatives analysis (EAA) must be prepared. The EAA must justify requested flows and provide an analysis of potential wastewater treatment alternatives including justification for not connecting to the City of Hickory WWTP. A copy of Division guidance for preparing EAA documents is attached. State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document must be prepared for all projects that: 1) need a permit; 2) use public money or affect public lands; and 3) might have a potential to significantly impact the environment. For existing discharges, significant impact is defined as an expansion of > 500,000 gpd additional flow. Since Claremont is proposing expansions < 500,000 gpd flow, the SEPA document and evaluation are not required. Should you have any questions about these speculative limits or NPDES permitting requirements, please feel free to contact Ron Berry at (919) 807-6396 or Tom Belnick at (919) 807-6390. cc: Mooresville Regional Office/Surface Water Protection Kathy Stecker/Modeling TMDL Unit Central Files NC0032662 and NC0081370 NPDES Permit Files/ Re pectfully, om Belnick Supervisor, NPDES Complex Permitting Unit S-ez_ 9nC®®324L2 --for retu-es-f j-�-�-� 4.c,-VELA1.5-1 ) pp (r.r4 `s Page 3 of 3