NC0044440_Speculative Limits_20000511

NPDES DOCUMENT 5CANNINO COVER SHEET
NC0044440
Cherryville WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Technical Correction
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
May 11, 2000
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:'-'',B-ILL HOLMAN
',_ EGR ETARY
ve
- illlki kL'r..
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.ate •k't•st
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
May 11, 2000
Ms. Janice Hovis
City Manager
City of Cherryville
116 South Mountain Street
Cherryville, NC 28021
Subject: Speculative Limits Request
Town of Cherryville WWTP
NPDES Permit No. NC0044440
Gaston County
Dear Ms. Hovis:
The Division of Water Quality has completed its evaluation of your request
for speculative limits for Town of Cherryville's wastewater treatment facility
discharging to the Indian Creek. You specifically requested speculative limits for
a wasteflow of 4.0 MGD.
Based on available information, the tentative effluent limitations are as
follows for a 4.0 MGD discharge at this location:
BOD5 (mg/L)
NH3-N (mg/L)
DO (mg/L)
TSS (mg/L)
Fecal Coliform (#/100 ml)
pH (SU)
Chlorine (µg/L) (daily max)
Copper (µg/L) (daily max)
Zinc (µg/L) (daily max)
Cadmium (µg/L) (daily max)
Nickel (µg/L) (daily max)
Lead (µg/L) (daily max)
Cyanide (µg/L) (daily max)
Chromium (µg/L) (daily max)
Summer Winter
30 30
1.8 5.9
5 5
30 30
200 200
6-9 6-9
28 28
Quarterly Monitoring
Quarterly Monitoring
Quarterly Monitoring
Quarterly Monitoring
Quarterly Monitoring
Quarterly Monitoring
Quarterly Monitoring
The specified ammonia limits are necessary to protect the Indian Creek
from toxic effects. Following current EPA guidance, DWQ is using instream
ammonia criteria of 1 mg/L during the summer and 1.8 mg/L during the winter,
under 7Q10 flow conditions. The 7Q10 estimate used by the DWQ for this
location on the Indian Creek is 6.1 cfs based on flow data from the downstream
gage. Flows from this gage include effects from both the current water
withdrawal and wastewater discharge. To determine the final effluent limitations
the 7Q10 flow may be adjusted to consider the effect of additional water
withdrawal by the City of Cherryville from Indian Creek. Please notify the
DWQ of any change in water withdrawal from Indian Creek.
A C 1 C M = O l a
1 1
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617
website: h2o.enr.state.nc.us PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

This speculative analysis includes monitoring requirements for metals or
other toxicant parameters included in the current permit. If an NDPES permit is
requested, a new evaluation of the constituents present in the discharge would be
necessary. The instream waste concentration (IWC) at which limits for toxic
substances will be calculated is 50% for a 4.0 MGD discharge. The facility will
be required to meet a whole effluent toxicity test limit. A chronic (Ceriodaphnia)
test must be performed quarterly with a pass/fail limit at a test concentration of
50%.
Under current DWQ procedure, dechlorination and chlorine limits are
recommended for all new or expanding dischargers proposing the use of chlorine
for disinfection. An acceptable level of residual chlorine in the effluent of this
plant in order to protect against acute toxicity is 28 µg/L. If the facility utilizes
UV disinfection with a backup chlorine system, the chlorine limit will apply only
when the backup chlorine disinfection system is in operation.
Any future permits will include monitoring requirements for the limited
parameters. The permit will also require monitoring for parameters without
specified effluent limitations, and monitoring of both the effluent and the
receiving stream, as does the current permit. Instream monitoring requirements
will be modified to reflect applicable monitoring agreements with the Division.
Additional Considerations
The speculative limits presented here are based on our understanding of
the proposal and of present environmental conditions. Over time these conditions
may change or additional information may become available. Please be aware
that response to this request for speculative limits does not guarantee that the
Division of Water Quality will issue an NPDES permit for an expansion to a 4.0
MGD discharge to the location. Nor can we guarantee that the effluent
limitations and other requirements included in any permit will be exactly as
presented here. Final decisions on these matters will be made only after the
Division receives and evaluates a formal permit application for the proposed
discharge.
Environmental Assessments of New Projects and Expansions
The environmental impacts of the proposed discharge must be evaluated
prior to the filing of a permit application. Anyone proposing to construct new or
expanded waste treatment facilities using public funds or public (state) lands
must first prepare an environmental assessment (EA) when wastewater flows (1)
equal or exceed 0.5 MGD or (2) exceed one-third of the 7Q10 flow of the
receiving stream. The Division will not accept a permit application for a project
requiring an environmental assessment until the Division has approved the EA
and sent a Finding of No Significant Impact (FONSI) to the state Clearinghouse
for review and comment.
The Environmental Assessment should contain a clear justification for
the flow. It should provide a comprehensive analysis of potential alternatives to
relocation, including a thorough evaluation of non -discharge alternatives.
2

Nondischarge alternatives to relocation --such as spray irrigation, water
conservation, and inflow and infiltration reduction --are considered to be
environmentally preferable to a surface water discharge.
In accordance with the North Carolina General Statutes, the preferred
alternative must be the practicable waste treatment and disposal alternative with
the least adverse impact on the environment is required to be implemented. If the
EA demonstrates that the project may result in a significant adverse effect on the
quality of the environment, you must then prepare an Environmental Impact
Statement. Gloria Putnam of the Water Quality Planning Branch can provide
additional information regarding the requirements of the N.C. Environmental
Policy Act. You can contact Ms. Putnam directly at [phone], ext. 567.
The above limits are to assist you in your planning and engineering
analyses and are speculative. Please note that prior to any DWQ approval of the
expansion, you will need to demonstrate compliance with the speculative limits.
Final NDPES effluent limitations will be determined after a formal permit
application has been submitted to the Division. If there are any additional
questions concerning this matter, please feel free to contact either Adugna
Kebede (ext. 515) or me (ext. 517) at [phone].
Sincerely,
David A. Goodrich
Supervisor, NPDES Unit
Water Quality Section
cc: Mooresville Regional Office, Water Quality Section
Central Files
NPDES Permit Files
Adugna Kebede

VA
NCDENR
JAMES B. HUNT. J R:
GOVERNOR.
BILL HOLMAN
SECRETARY
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
December 10, 1999
MEMORANDUM �'� s TO: Recil Wright,Wrightht, Wri & Associates Q, eLe
�
FROM: Jim Mead, Division of Water Resources ,`\.\ 03L''(\l°0;w1/4,k°
SUBJECT: City of Cherryville Gaston County
Proposed Water Withdrawal Expansion from Indian Creek
P P
This memo summarizes the background information and Division of Water
Resources' concerns regarding the City of Cherryville's proposal to increase their
existing withdrawal from Indian Creek. The habitat rating developed for Indian
Creek by the Division of Water Resources (DWR) and the Wildlife Resources
Commission (WRC) is also described, along with how it applies to minimum flow
requirements downstream of the intake.
The City of Cherryville ("the City") has an existing intake on Indian Creek at a
drainage area of 39 square miles. The intake is located at a low weir, with
• minimal on -stream storage. The existing water supply withdrawal is presently
limited to a capacity of 3.2 million gallons per day (mgd). According to the 1997
Local Water Supply Plan information, the'City's average water use is 1.6 mgd,
with a maximum daily use of 2.485 mgd. The City is exploring the possibility of
expanding their withdrawal from Indian Creek to between 4.8 and 5.0 mgd.
The 7-day, 10-year low flow (7Q10) at the water supply intake is estimated to be
between 5.0 and 6.8 cubic feet per second (cfs) , or between 3.2 and 4.4 mgd.
This means that the existing withdrawal capacity of 3.2 mgd is approximately
73% to 100% of the 7Q10. A new withdrawal of this size relative to the 7Q10
flow would not be permitted without an environmental study to evaluate instream
flow concerns. Minimum criteria subject to 15A NCAC 1 C.0504(3)(b) require
this level of environmental documentation for any withdrawal greater than or
equal to 20% of the 7Q10 low flow. In other words, if there was no existing
intake on Indian Creek and this was a proposal for a new withdrawal, its size
would be limited to between 0.64 and 0.88 mgd in the absence of additional
environmental studies and review.
1
2 • - 0 I •-a0,-a:3
MAILING ADDRESS: 1611 MAIL SERVICE CENTER, RALEIGH. NC 27699-161 1
PHYSICAL ADDRESS: 512 N. SALISBURY STREET, RALEIGH, NC 27604
PHONE [phone]F,4 FAX L 19-733-3559
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 5O% RECYCLED/1O% POST -CONSUMER PAP,'

Memorandum from Jim Mead to Recil Wright, 12/10/99
City of Cherryville Intake, Page 2
The proposed expansion to between 4.8 and 5.0 mgd amounts to 109% to 155% of the
7Q10 (depending on the water supply amount and the range of 7Q10 estimates). DWR has
informed the City that this will not be permitted without additional study and review to address
instream flow concerns. The first step in this process was to see if a desktop approach could be
applied to determine a minimum flow to maintain aquatic habitat downstream of the intake.
WRC and DWR staff conducted a site visit on October 14, 1999 to evaluate habitat quality
according to procedures described in 15A NCAC 2K O501. Based on field data collected during
that visit, instream cover was rated "moderate" and substrate was rated "poor." Existing data on
stream macroinvertebrates is available for Indian Creek from the Division of Water Quality's
Biological Monitoring Ambient Network that indicates the macroinvertebrate rating is "good."
Therefore the overall habitat rating for the section of Indian Creek affected by the
withdrawal is "moderate."
Since this site is located in the piedmont region and has a moderate habitat rating, the regression
formula described in 15A NCAC 2K 0502 (c) (2) (C) can be applied to determine the minimum
flow to maintain aquatic habitat. Using flow statistics from the U.S. Geological Survey (USGS)
gaging station on Indian Creek (station 02143500) ratioed by drainage area to the intake site, the
minimum flow determined by the regression formula is 15.4 cubic feet per second, or about
10 mgd.
Because the existing 3.2 mgd capacity is existing infrastructure in which the City has invested
and planned for, this amount of withdrawal will not be subject to any new instream flow
requirements; even though it greatly exceeds 20% of the 7Q10 flow. However, any increase
above 3.2 mgd would only be permitted. when a minimum flow requirement can be met
downstream of the intake. For example, suppose the City chose to expand the withdrawal
capacity to 4.8 mgd and water demand reached 3.5 mgd. A withdrawal of 3.2 mgd could
continue without restrictions, but the remaining 0.3 mgd of the total demand would only be
available from Indian Creek when a flow of 15.4 cfs could be maintained downstream of the
intake. In other words, inflows upstream of the intake would have to be at or above 13.5 mgd
(3.5 mgd withdrawal plus 10 mgd minimum flow -by).
During times when flows in Indian Creek could not satisfy both an expanded water supply
withdrawal and the instream flow requirement, the withdrawal would be restricted. Some
portion of the new increment of water withdrawal would have to be met by other means,
including: water conservation measures; supplemental withdrawals from offstream storage; an
additional source of water, such as well(s) or another surface water source; purchase of water
through an interconnection with another water system; or some combination of the preceding
alternatives.

Memorandum from Jim Mead to Recil Wright, 12/10/99
City of Cherryville Intake, Page 3
Nearly half of the City's water use is industrial, with a large percentage going to a single textile
plant. If there are ways for this plant to use less water, this would greatly extend the City's water
supply. The Division of Pollution Prevention and Environmental Assistance offers free
consulting services to see if such savings are possible. They can be contacted at 800/763-0136,
or visit their Internet site at http://www.p2pays.ore/. The City could also evaluate the amount of
unaccounted for water in its system to see if a significant portion is being lost. Reducing such
losses is another approach to extending the life span of a given amount of water supply. DWR's
Water Supply Planning Section can offer assistance in this kind of effort.
Using the minimum flow determination of 15.4 cfs, the City should have sufficient information
to evaluate the flow available for water supply use in Indian Creek and the viability of various
water supply options. For example, by using the USGS stream gage record a drought analysis
could be performed to determine how much water might need to be stored offstream to satisfy
water demands during a period when withdrawals from the creek would be restricted. The
Wooten Company recently performed a similar analysis and we have attached a page of their
spreadsheet as an example.
Another option available at this point is a more complex field study to determine if the desktop
minimum flow of 15.4 cfs can be reduced. This would require use of the Instream Flow
Incremental Methodology (IFIM) to evaluate the relationship between instream flows and habitat
for selected aquatic species in Indian Creek. Such a study would be performed by a consultant
with IFIM training and would require at least three field visits to collect data at flows ranging
from low to the higher side of moderate. Obtaining suitable flow conditions in an unregulated
stream depends on precipitation, and can result in such a study taking a year or more to complete.
DWR can provide a list of consultants with IFIM training upon request.
Lastly, the City should be aware that there are other concerns associated with this proposed
intake expansion beyond maintaining downstream physical habitat. The Division of
Environmental Health's Public Water Supply Section (PWS) will consider whether the available
source(s) of water are sufficient to meet the demand of any expanded capacity. The
Environmental Assessment required for a water supply expansion project is submitted for review
through that agency.
3

Memorandum from Jim Mead to ReciI Wright, 12/10/99
City of Cherryville Intake, Page 4
There are also potential concerns regarding how the proposed expansion of the withdrawal from
Indian Creek would affect the proper assimilation of treated effluent discharged farther
downstream by the City. The intake is located at a drainage area of 39 square miles and the
outfall is at 46.4 square miles. The 7Q10 flow used by the Division of Water Quality (DWQ) to
set effluent limits for the City's wastewater treatment plant' is 6.1 cfs. It is possible that this
assumed dilution flow did not account for the City's existing withdrawal capacity of 3.2 mgd
upstream. Expanding the withdrawal and reducing the assimilative flow could result in more
stringent limits on effluent quality and the associated increase in wastewater treatment costs.
This would also depend on whether the City's present level of wastewater treatment has a
"cushion" that would allow technological improvements in effluent quality.
We encourage you to contact DWQ regarding this water quality issue before proceeding too far
with plans and studies for any withdrawal expansion from Indian Creek. The modeler for the
Catawba basin is Michelle Woolfolk, who can be reached at 919/733-5083.
We are pleased that the City is considering its future water supply options before a crisis level
has been reached. The current average demand is about 50% of the capacity and the maximum
daily demand is about 78% of capacity. Now is a good time to plan for future water needs so
that there is time to identify and develop the best alternative. Contact me at 919/715-5428 if you
have questions regarding instream flow concerns. Ken Ashe in DWR's Water Supply Planning
Section (919/715-5443) can address questions regarding water supply yields and drought
analysis.
attachment
cc: Tony Young, Ken Ashe, and John Sutherland - DWR
Doug Besler and Ron Linville - WRC
Michelle Woolfolk and Ruth Swanek - DWQ
Jessica Miles - PWS
Britt Setzer - Mooresville Regional Office, PWS
Janice Hovis - Cherryville City Manager
4

-Inn 1, 1954 • Sool 25. 11958
r-t./ems •
r•'cit_•ra'.
- VMnno of Resenuk Is 22 m9. gel-
- Maximum withdrawal from creek le 2.4 mgd when minimum release of 4.9 rood befog met.
• WLnn mkdnnrm wt./rd.-All Is mot, additional wafer can be used to rolW resarv0k.
• 5Vlmn mkdmrm w'Ordr00l Is nod met and demand Is len Than 1.6 mgd, additional walor can be used to relit resorvok.
• When 'Milkmen retort, of 4.9 rogd carrot bo mol and Resorvok Is greater Ilan half full- 1.6 mgd Is maximum wklxlrawal,
• Minn minimum retea:.n o14.9 mgd carrot be mel and lleservok Is less Man hall lull but gassier than 0, 2.0 mg) Is maximum withdrawal.
- When minimum rnloa^•e of 4.9 mod cannot be mol and Reservoir empty, 2.4 mod Is maximum withdrawal.
- 30 Day low Flow M Sept 10, 1054 • October 10, 1054 w411 hove a daily demand d 2.4 mod.
- Demand Includes .tin 1, 1997 8w Dec 31, 1997 and Sopl 1, 1998 • Aug 31, 1999
• fn a closer a its n' the derivation u1 Tom's Crook Flow sae 61e AVERAGE.XLS.
(J) _
Dale
of Flow
fom's Creek Flow
In mgd'
WII Minimum
Relents be Mel7
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Demand
Waler Demand
M mod
Withdrawal
8 Reservoirs 1 1
Withdrawal
6 Reservoir .0
Withdrawal' ,
8 Reservoir . 0
Withdrawal Dom
Crook.
Withdrawal from
Creek to Reservoir
Wi drawal:ran
Creek to Oomard
Withdrawal Iran
Reservoir to Demand
Amami Available
l01111 Reservoir
Amami Noricum
10 1111 Reservoir
A.naau In
Reservoir
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24Jan-54
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26•Jon.54
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27.Jen.54
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10.34
yos
17•Fob'97
FALSE
FALSE
FALSE
0.000
1.450
0.000
0.000
0.403
0.000
22.000
I01'e'7.54
9.10
yos
16.Feb-97
FALSE
FALSE
FALSE
0.000
1.997