NC0024937_Draft Permit_19900731

NPDES DOCUMENT SCANNING COVER SHEET
NC0024937
Sugar Creek WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Draft Permit
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
July 31, 1990
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Govemor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
April 5, 1990
Joe C. Stowe, Jr., Director
Charlotte -Mecklenburg Utility Department
5100 Brookshire Boulevard
Charlotte, NC 28216
Subject: Sugar Creek WWTP
NPDES No. NC0024937
Mecklenburg County
Dear Mr. Stowe:
You recently received a revised NPDES permit for the Sugar
Creek WWTP that has been prepared by the Division of Environmental
Management (DEM) in light of your letter of January 4 requesting
several changes: The permit as written reflects DEM's final deci-
sion on each of the issues raised in your letter. You should note
that the Environmental Protection Agency (EPA) is still reviewing
the draft permit for the Sugar Creek WWTP, and may be requiring
changes before the permit is issued.
The more stringent fecal coliform limit included in the draft
permit is based on the revised standards. If the facility will not
be able to comply with the limit, the City should enter into an SOC
to address the problem.
The requirement that there shall be no discharge of floating
solids or visible foam in other than trace amounts is included in
all NPDES permits per standard operating procedure in light of 15
NCAC 2B.0211 (b) (3) (C and F) . The City of Charlotte has accepted
this in its past permits.
You also requested a compliance schedule for the Sugar Creek
WWTP to allow time to construct a generator to prevent discharges
of inadequately treated wastewater. The City should handle this
through an SOC.
You should note that the NPDES permit expires in August, 1991
due to DEM's new basin permitting schedule. The second paragraph
Poludon Prcvendon Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
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of the attached letter explains the reasons behind this permitting
strategy.
If you believe that your concerns have not been adequately
addressed through the revised permit which you recently received,
you have the right to an adjudicatory hearing upon written request
within thirty (30) days following receipt of the final permit.
This request must be in the form of a written petition,' conforming
to Chapter 150B of the North Carolina General Statutes, and filed
with the Office of Administrative Hearings, Post Office Drawer
11666, Raleigh, North Carolina 27604. Unless such a request is
received by this Division, the requirements contained in the issued
permit shall be final and binding.
If you have any questions, please contact Dale Overcash or
Trevor Clements of my staff at [phone].
Sincerely,
Steve W. Tedder, Chief
Water Quality Section
Attachment
cc: Dale Overcash
Trevor.Clements
Rex Gleason
Central Files

State of North Carolina
Department of Environment, Health and Natural Resources'
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
January 22, 1990
R. Paul Wilms
Director
Dear Applicant:
Please find attached a DRAFT Permit and a public notice that have been prepared for
your facility by the Division of Environmental Management (DEM). I encourage you to review
these documents very carefully to ensure thorough understanding of the information, conditions,
and requirements contained therein. In completing your review, please be aware of the two
procedure changes described below that become effective on February 1, 1990.
The subject permit expiration date may reflect a period of less than five years. The
DEM has implemented a new NPDES permitting schedule that is directed toward organizing
permit issuance and review by major river basins within the State. The revised schedule will
allow the DEM to focus its resources on more efficient and effective NPDES permitting, and
allow for greater consistency in developing pollutant discharge limitations throughout each
river basin. In order to place the subject NPDES Permit within the proper cycle for its
corresponding river basin, it may be necessary to shorten the life of the permit to less than the
maximum allowable five year term as defined by North Carolina General Statute 143-215.1
(c) (5). In most cases, once a permit has been brought into the proper basin cycle, future
permits will be issued for the maximum five year period.
All questions or comments pertaining to any portion of the DRAFT Permit should be
directed to Mr. Dale Overcash of the NPDES Permits Group at the address or telephone number
listed below prior la the "Schedule to Issue" date in the public notice. Once a permit is issued,
except for typographical or technical errors, the permit may be appealed only through the legal
process. Such appeal would need to be made in the form of a written petition in accordance with
Chapter 150B of the North Carolina General Statutes and filed with the Office of Administrative
Hearings, PO Drawer 11666, Raleigh, NC 27611 within 30 days of permit issuance.
Thank you in advance for your cooperation in these matters.
Sincerely,
Steve W. Tedder, Chief
Water Quality Section
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

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clILOTTE
January 4, 1990
VIA HAND DELIVERY
Mr. Chuck Wakild, Acting Director
Division of Environmental Management
North Carolina Department of Environment,
Health and Natural Resources
Post Office Box 27687
Raleigh, North Carolina 27611-7687
Subject: Comments on Draft NPDES Permits Renewal
Mallard Creek WWTP, NPDES No. NC0030210
Sugar Creek WWTP, NPDES No. NC0024937
Mecklenburg County
Dear Mr. Wakild:
The City of Charlotte (hereinafter "City" or "Charlotte") provides these
comments in response to the respective draft NPDES Permits indicated in the
above subject. The City reserves its rights to supplement these comments and
provide additional comments prior to EHNR final administrative decision on the
permits.
The City remains committed to ensuring compliance with applicable federal
and state environmental requirements. To the extent the draft permit
implements appropriate standards, the City has no objections. The City,
however, objects to the imposition of requirements through the permit process
resulting in liability based upon permit conditions which are unsupported by
federal and state law.
To the extent that the draft permit requirements for both the Mallard
Creek and Sugar Creek Wastewater Treatment Plants are the same as those in the
draft permit issued to the McAlpine Creek Wastewater Treatment Plant on
April 24, 1989, the City hereby incorporates by reference our comments to the
Division of Environmental Management in the letter of June 13, 1989 which was
addressed to Mr. R. Paul Wilms, Director.
The City objects to the more stringent Fecal Coliform (geometric mean)
discharge limitation to both treatment plants without the inclusion of a
reasonable schedule of compliance to allow the City to study, design and
construct a disinfection system which will achieve the draft permit limitation
without causing conditions that contribute to the violation of the effluent
chronic toxicity requirement. When the Division of Environmental Management
(DEM) agrees to a compliance schedule for both treatment plants, the City will
provide information to DEM regarding appropriate dates.
Administration Division 5100 Brookshire Boulevard Charlotte, NC 28216 704/399-2221
Charlotte -Mecklenburg Utility Department

a
Mr. Chuck Wakild - 2 - January 4, 1990
The City objects to the inclusion in both draft permits of the
requirement that there shall be no discharge of floating solids or visible
foam in other.than trace amounts unless floating solids, visible foam, and
trace amounts are found in the NCAC T15: 02B .0211 as basic standards.
The City objects to the more stringent effluent limits which have been
assigned to the Mallard Creek Wastewater Treatment Plant beginning after
expansion above 3.0 MGD.
The City requests a compliance schedule in the Sugar Creek Wastewater
Treatment Plant permit to allow study, design and construction of adequate
standby generator systems to prevent discharges of inadequately treated wastes
during electrical power failures due to the interruption of essential
treatment units.
As the respective draft permits, which were mailed to the City with the
Public Notice copies, did not include the standard boilerplate conditions; the
City reserves the right to object to any part of the issued permit that was
not disclosed to the City by that process.
The City respectfully requests a meeting with DEM to discuss these
comments and to address other legal concerns regarding the draft permits. The
City believes that this approach may obviate the need for an adjudicatory
hearing or other formal legal procedures.
If you have any questions please feel free to call.
Very truly yours,
J•e C. Stowe, J, Director
Charlotte -Mecklenburg Utility Department
/vc
Enclosure
cc: Mike Boyd, Esq.
Henry Forrest

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W. Cobey, Jr., Secretary Director
January 11, 1990
Mr. Darryl Williams, Environmental Engineer
North Area Permits Unit
Facilities Performance Branch
Water Management Division
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Subject: CMUD Sugar Creek WWTP
NPDES No. NC0024937
Mecklenburg County
Dear Mr. Williams:
I am writing in response to your letter of December 21 regarding the
Charlotte -Mecklenburg Sugar Creek WWTP. Per your request, I have enclosed
ambient data (Attachment 1) collected by the Division of Environmental
Management (DEM) at Archdale Road, approximately 0.3 miles downstream of the
facility, as well as the facility's instream self monitoring data (Attachment
2). The ambient data at this station do not show any dissolved oxygen (DO)
violations. However, modeling analyses and past field studies indicate that
the DO sag point occurs further downstream. The self -monitoring data show
violations in June, July, and August, 1987, but these violations occurred
while the facility was out of compliance with its ammonia limit.
The draft NPDES permit limits for BOD5 and NH3-N (Attachment 3) are
identical to the subject facility's existing limits. Due to the inadequacy
and suspected unreliability of the original models used to develop the NPDES
permit limits for the three Charlotte facilities in the Sugar Creek Basin
(Sugar Creek, Irwin Creek, and McAlpine Creek WWTPs - schematic in Attachment
4), DEM has begun developing a QUAL2E-UNCAS basin model of Sugar Creek which
will incorporate all three discharges. To date, we have completed time -of -
travel (TOT) and water quality studies on McAlpine Creek. In addition, one
TOT study under moderate low flow conditions was completed on Sugar Creek and
Little Sugar Creek last summer. Unfortunately, due to uncooperative weather
conditions, we were unable to obtain additional data during critical low flow
periods. We are hoping to gather this data in the upcoming intensive survey
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

period along with water quality data for the remainder of the basin.
DEM has completed a preliminary QUAL2E model (Attachment 5) for the Sugar
Creek Basin using the available data in order to provide the City of Charlotte
with speculative limits for future wastewater disposal alternatives. (Attach-
ment 6 outlines the model calibration). The preliminary model indicated that
the current effluent limits assigned to the facilities will result in DO stan-
dard violations, and that effluent limits of 5 mg/1 BOD5, 2 mg/1 NH3, and
7 mg/1 DO are needed at the Sugar Creek plant in order to protect the stream
DO standard. However, substantial uncertainty exists regarding the current
model assumptions for hydraulics and SOD which have a large impact on instream
DO predictions. Therefore, the facility was assigned existing limits until
DEM has a valid field -calibrated model.
When the Sugar Creek Basin model is completed, DEM will reopen all of the
CMUD permits to revise the limits and/or monitoring requirements if this
action is determined necessary to protect water quality in the receiving
waters. In the interim, DEM will substantially increase the instream monitor-
ing requirements for the Sugar Creek plant. I have enclosed the proposed
monitoring requirements for your review (Attachment 7). A specific reopener
clause will be added to the permit to ensure our ability to modify the efflu-
ent limits when the basin model and our permitting strategies are completed.
DEM used the permit renewal period as an opportunity to evaluate toxicity
in the Sugar Creek WWTP effluent. The metals limits and instream monitoring
requirements were added to the permit based upon effluent monitoring (Attach-
ment 8) and pretreatment headworks information (Attachment 9). A whole efflu-
ent toxicity limit (chronic Ceriodaphnia at 87%) was also added to the draft
permit. DEM will use the subsequent results of this monitoring to evaluate
ammonia and chlorine toxicity until these issues are addressed during this
triennial review period.
I hope this response adequately addresses your needs. If you need any
other data or have questions about the modeling analysis, please contact Ruth
Swanek. If you have questions regarding our wasteload allocations policy,
please contact Trevor Clements. Both Ruth and Trevor can be reached at
[phone].
Sincerely,
e Tedder, Chief
Watbr Quality Section
Attachments
cc: Allen Hardy, MRO
Trevor Clements
Dale Overcash
Central Files

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
DEC 2 1 1989
REF: 44a4-FP
Steve Tedder, Chief
Water Quality Section
Division of Environmental Management
NC Dept. of Natural Resources
and Community Development
P. 0. Box 27687
Raleigh, North Carolina 27611-7687
RE: Facility - Charlotte-Mecklenburg/Sugar Creek INTP
NPDES Number - NC0024937
Dear Mr. Tedder:
Dtc 2I 1959
In accordance with 40 CFR 124.44(d)(2), comments on the draft permit are
being withheld until we receive the following supporting material(s) which
will facilitate our timely review:
Fact Sheet and/or rationale (with calculations)
For revised draft
Application
Draft permit
Water quality summary sheet
X Modeling data
Production data
X Other and water quality monitoring data
Our review time will not start until the requested information is received.
Please contact me at [phone] if you have any questions.
Sincerely yours,
Darryl Williams
Environmental Engineer
North Area Permits Unit
Facilities Performance Branch
Water Management Division
DEC 2 9 1989