NC0047384_Speculative Limits_20101220

ATA
F1thENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Govemor Director Secretary
December 20, 2010
Mr. Allan Williams
Director of Water Resources
City of Greensboro
2199 White Street
Greensboro, NC 27405
Subject: Speculative Limits for Greensboro WWTP
Consolidation to T.Z. Osborne/ 56 MGD
Guilford County
Dear Mr. Williams:
This letter is in response to your request for speculative effluent limits for a proposed consolidation of Greeensboro's
North Buffalo WWTP (NC0024325) into an expanded T.Z. Osborne WWTP (NC0047384). The proposed consolidation
includes closing the North Buffalo WWTP (currently permitted at 16 MGD), and expanding the T.Z. Osborne WWTP
from 40 to 56 MGD. The discharge will be to South Buffalo Creek through existing outfall 001. The expanded facility
would be located at Greensboro's T.Z. Osborne Wastewater Treatment Plant on Huffme Mill Road west of McLeansville,
Guilford County, in the Cape Fear River Basin. North Carolina Regulation 15A NCAC 2B .0203 states "...effluent
limitations ...for direct discharges of waste ...will be developed ...such that the water quality standards and the best
usage of receiving waters and all downstream waters will not be impaired."
South Buffalo Creek at the expanded 56 MGD discharge site is classified C, NSW. Class C waters are protected for
secondary recreation, aquatic life propagation and maintenance of biological .integrity (including fishing and fish),
wildlife, agriculture and any other usage except for primary recreation or as a source of water supply for drinking,
culinary or food processing purposes. The Nutrient Sensitive Water (NSW) designation is for waters that are
experiencing or are subject to excessive growths of microscopic or macroscopic vegetation that impair the use of the
water for its best usage. The term "nutrient" includes total nitrogen and total phosphorus. Both North Buffalo and South
Buffalo Creeks are listed as impaired for ammonia, copper, ecological/ biological integrity, and zinc on the 2010 303(d)
list.
Nutrients:
The City holds total nitrogen and total phosphorus allocations for the T.Z. Osborne and the North Buffalo WWTPs
pursuant to the Wastewater Discharge Requirements rule (T15A NCAC 02B .0270) of the Jordan Water Supply Nutrient
Strategy.
1617 Mail Service Center, Ra!eigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
No°rthCarolina
Naturally

At the City's request, the Division modified both NPDES permits in November 2010 to combine the limits for nitrogen
and for phosphorus for the two facilities. The resulting limits are 401,073 lb/yr TN and 49,299 lb/yr TP, both expressed as
delivered loads rather than discharge loads. Ultimately, the Jordan Wastewater rule governs nutrient contributions to
ordan Lake. However, due to differences in the facilities' transport factors, similar loads of nitrogen or phosphorus
discharged from both facilities would contribute slightly different loads to the lake. Thus, it becomes necessary to convert
lues measured at each point of discharge and work in terms of delivered loads.
wastewater flows are consolidated and discharged at the T.Z. Osborne plant's Outfall 001, the same combined load
units would apply, that is, 401,073 lb/yr TN and 49,299 lb/yr TP as delivered loads. However, because the combined
ows would be discharged at a single outfall, it would again be possible to express the nutrient limits as discharge loads.
sing the transport factors for the T.Z. Osborne plant, the combined delivered limits translate to combined discharge
imits of 891,272 lb/yr TN and 112,044 lb/yr TP. These are equivalent to 5.23 mg/L TN and 0.66 mg/L TP at the
ombined permitted flow of 56 MGD.
Table 1. Total Nutrient Allocations
Total Nitrogen Allocations Total Phosphorus Allocations
Facility
Discharge
(lb/yr)
Transport
Factor
Delivered
(lb/yr)
Discharge
(lb/yr)
Transport
Factor
Delivered
(lb/yr)
T.Z. Osbome
WWTP
645,277
45%
290,375
81.156
44`;%
35,708
North Buffalo
WWTP
257,438
43%
110,698
32,359
42%
13,591
Totals
401,073
49,299
/Under the rule, the total phosphorus limit is already in effect, and the total nitrogen limit will become effective January 1,
2016.
peculative Limits for Expanded T.Z. Osborne WWTP (56.0 MGD):
ased on available information, speculative effluent limits for the proposed discharge of up to 56 mgd to the South
uffalo Creek in the Cape Fear River Basin are presented in Table 2. These speculative limits were developed in
ccordance with the Jordan Water Supply Nutrient Management Strategy (T15A NCAC 02B.0270) for Total Nitrogen and
otal Phosphorus.
Flow Limits. The flow will be limited to 56.0 MGD as requested by the City. Detailed justification for this level of flow
?rust be provided.
Oxygen Consuming Waste. In order to protect for instream dissolved oxygen, the BOD ultimate loading was frozen by
lowering the ammonia limits to 0.82 mg/ L NH3-N (Summer) and 1.64 mg/ L NH3-N (Winter). The CBOD5 limits remain
the same at 4.0 mg/ L (Summer) and 8.0 mg/ L (Winter).
TSS. The limits for total suspended solids are standard for secondary treatment of municipal wastewater (30 mg/L
monthly average).
Fecal Coliform, pH. The limits for fecal coliform bacteria (200/100 ml) and pH (6.0-9.0) are derived to protect water
quality in the receiving stream, classified "C".
Total Residual Chlorine (TRC). To protect the receiving stream from high concentrations of chlorine, a TRC limit of 17
µg/L would be required at this site.
Total Nitrogen. See the Nutrient section above.
Total Phosphorus. See the Nutrient section above.
Whole Effluent Toxicity Test. The Whole Effluent Toxicity test will remain capped at 90%.

i
,Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES permit will be
issued with these speculative limits. Final decisions can only be made after the Division receives and evaluates a formal
4ermit application for the proposed 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 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. Alternatives to a surface water discharge, such as spray/ drip
irrigation, wastewater reuse, or inflow/ infiltration reduction, are considered to be environmentally preferable. A copy of
tie EAA requirements is attached to this letter. Permit applications for new or expanding flow will be returned as
incomplete if all EAA requirements are not adequately addressed.
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 wastewater discharges, significant impact is defined as a proposed discharge of
>500,000 gpd and producing an instream waste concentration of > 33% based on summer 7Q10 flow conditions. For
existing discharges, significant impact is defined as an expansion of > 500,000 gpd additional flow. Since your proposed
facility is for > 500,000 gpd flow, you 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 proposed
POTW 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). Since your proposed facility is subject to
SEPA, the EAA requirements discussed above will need to be folded into the SEPA document. The SEPA process
• be delayed if all EAA requirements are not adequately addressed. If you have any questions regarding SEPA
EIS requirements, please contact Hannah Stallings with the DWQ Planning Branch at [phone]. If you have
y additional questions about these limits or NPDES permitting requirements, feel free to contact Jim McKay at (919)
07-6404.
Sincerely,
Belnick
Supervisor, Complex NPDES Permitting
Attachment: EAA Guidance Document
cc: (without attachment)
• Winston-Salem Regional Office/Surface Water Protection Section
•
Central Files
• NPDES Permit Files
• Hannah Stallings — Via email
• Jennie Atkins, Ph.D. — Via email
• Robert DiFiore, Hazen and Sawyer Engineers — [e-mail]

A complete evaluation of these limits and monitoring frequencies in addition to monitoring requirements for metals and
other toxicants will be addressed upon receipt of a formal NPDES permit application.
Table 2. SPECULATIVE EFFLUENT LIMITATIONS
Greensboro T.Z. Osborne WWTP
EFFLUENT
CHARACTERISTICS
SPECULATIVE EFFLUENT
LIMITATIONS
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
56.0 MGD
CBOD, 5-day, 20°C
(Summer)
4.0 mg/L
6.0 mg/L
CBOD, 5-day, 20°C (Winter)
8.0 mg/L
12.0 mg/L
Total Suspended Solids
30.0.mg/L
45.0 mg/L
NH3 as N (Summer)
0.82 mg/L
2.46 mg/L
NH3 as N (Winter)
1.64 mg/L
4.92 mg/L
Fecal Coliform
(geometric mean)
200/ 100mL
400/ 100mL
Dissolved Oxygen
The daily effluent dissolved oxygen
concentration shall not be less than
6.0 mg/L.
pH
a 6.0 S.U. / s 9.0 S.U.
Total Residual Chlorine
17.0 µg/L
TN Load 1
Monitor & Report (ib/mo)
891,272 lb/yr TN
TP Load
Monitor & Report (lb/mo)
112,044 lb/yr TP
Quarterly Chronic Toxicity (Ceriodaphnia) at 90%
Footnotes:
(Summer): April 1- October 31
(Winter): November 1 - March 31
(Daily): every day on which a wastewater discharge occurs except Saturdays, Sundays, and legal holidays unless otherwise specified by the Director.
Annual TN and TP load limits (lb/ year) equal concentrations of 5.23 mg/ L TN and 0.66 mg/ L TP at full
permitted flow of 56 MGD.

ToSbaf ilc0413V
Pro loin) kb exec 1coll 0146-0-s, 561/46-6
74
I 2/17,Za t o
goboimai-e = csoaeowitil gavitokpem4m7
fa.o?10 eqs, .® -I 0 /461 G 9i dt iev„,/, (10r1 CmY,hatr
J
,,4,tf -7
,vii0l4
sbrn6-0.
lll/r 8t ,1 t 'Ol&P
nlCG04 0600
2S CQ40
LiOM x 6.3 - 32.02._5J
Ib'8o6
I 1 rvt ��- 4; / 67 u4e r
'fM�.J�CBvI�: X 2a x z x s6 xs,'?y = yyg3.s6v
It AO bus /ha_
•. e� inCr R» rn Ci0�,, 2�1�� Ihla�`�
eviriAA4 M-J J) wti+ \-o m fu-i
„,, 1),//1
AiW3 -/'' Li S1 `f 0 M C- x �. s Y - 3O D 2_ . YO
NI30111 //a()
idad a Ala deuetoe Nr)Ohu 11E02_1 boM
(1a
�i..e 56 x e6.3Y = I72/.37‘ i0)aon:1
[Surn►/1-M

cutimituf Suto4616.4j-
coM-
Y1i9
t
CfrJDv:32e2..Sb/6/�,( /Y3t58y /ih(
AA6ti:z 3oD2/o IWI Iw:k =1711.376
--160-grfr-z 42oy96 //(
ttDU Jo�tV1'
s-c F a• 8Z1 N6 -n!' Fifeho,t)

jN/ft'r✓I /?D
0
x 51/46-0 ec 3.3r .2 gqb7168 )14(
2rCo ofiv
Ai-e-fl` CeUu CLZ--. 0Y6 114
Ag-t) N n f�.� x two 60Uy.6o l�%Y
A114061)//
Lu4c nrJd-widota fiXoi? 01 is- bz.oys*?
•
110-13--N K Y.s x s6 x g.3Y = '3 yYZ .7sz iw
NBz
rid/P NHa-n/(w�46)
o JUD
iYYZ, 7sz
12'f�y�yy0

Mckay, James
From: Belnick, Tom
Sent: Friday, November 19, 2010 10:52 AM
To: Mckay, James
Subject: FW: Request for Speculative Limits
Attachments: TZO Spec Limits 56 MGD to DWQ FINAL.docx
Jim- fyi... looks like Dina assigned this one to you, and you probably have the hardcopy request.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
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: Matthews, Matt
Sent: Friday, November 19, 2010 9:55 AM
To: Poupart, Jeff; Belnick, Tom
Subject: FW: Request for Speculative Limits
FYI
Matt Matthews
NC DENR/Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
v-[phone]
f-[phone]
Matt. Matthews@ ncden r.gov
http://portal.ncdenr.org/web/wq/swp
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: Tedder, Steve
Sent: Friday, November 19, 2010 8:56 AM
To: Matthews, Matt
Cc: Wakild, Chuck
Subject: FW: Request for Speculative Limits
wanted you to know that I support this request 100%. This is a smart move by Greensboro and they have thoroughly
evaluated their situation and the cost to meet NPDES requirements. This will not result in any additional loading but will
combine two majors into one outfall and one WWTP. The TZ Osborne plant is newer, has more capabilities and available
land for expansion and or upgrades to treatment.
I know they have to make some quick decisions and substantial amount of money involved so I would hope the Division
can expedite their request for Spec limits based on the standards currently in place. We need to use this as an
opportunity to show the regulated community that we react in a positive manner to good planning and reasonable and
justifiable requests. This can be a Win -Win for both the Division and the City.
Thanks
Tedder
1

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.
Steve Tedder
[e-mail]
NC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
(336)-771-4950
Fax [phone]
From: Groome, Martie[mailto:Martie.Groome(agreensboro-nc.govl
Sent: Tuesday, November 16, 2010 11:12 AM
To: Wakild, Chuck; Matthews, Matt; Poupart, Jeff; Tedder, Steve
Cc: Williams, Allan - Water Resources; Howard, Don; Kling, Walter; Bob DiFiore
Subject: Request for Speculative Limits
Gentlemen:
Attached please find a request for speculative limits for the T. Z. Osborne WWTP at 56 MGD. As explained in the letter, this request
is extremely time sensitive and we respectfully ask for an expedited response.
Allan Williams
City of Greensboro Director of Water Resources
Martie Groome, Laboratory and Industrial Waste Section Supervisor
Water Resources Department
City of Greensboro
Phone: [phone] Fax: [phone]
Box 3136, Greensboro NC 27402-3136
www.greensboro-nc.gov
Please note that email sent to and from this address is subject
to the North Carolina Public Records Law and may be disclosed to
third parties.
2

Table 5 CAPE FEAR Subbasin 03-06-02
AU Number Classification Length/Area
Description
Aquatic Life Assessment Recreation Assessment
Year/
AL Rating Station Result Parameter % Exc REC Rating Station Result
Stressors Sources
Jordan Creek
16-14-6-(0.5)
Ws -II HQW 10.6 FW Miles 5
From source to a point 0.7 mile upstream of mouth
Moadams Creek (Latham Lake)
16- 1 8-7 C NSW
From source to Back Creek
4.6 FW Miles
BA70 NCE
BB214 GF 2003
BF46 GF 2003
S t BA70 NCE
NR
BA87 NCE
BA88 NCE
BB342 NR '1999
BB9 NR '1999
NR*
BA87 NCE
BA88 NCE
Muddy Creek
16-11-14-1-3 C NSW
From source to North Buffalo Creek
North Buffalo Creek
16-11-14-lal CNSW
From source to Philadelphia Lake
3.7 FW Miles
BA748 NCE
7.5 FW Miles
BF36 P '1999
BF64 P '1999
NR*
NR*
BA748 NCE
Fecal Coliform Bacteria Unknown
BA750 NCE
BA751 NCE
Habitat Degradation
Unknown
16-I1-14-1a2 CNSW 1.6 FW Miles S
From Philadelphia Lake to North Buffalo Creek WWTP
BFI1 P '1999
BF11 GF 2003
BA42 NCE
BA742 CE
Fecal Coliform Bacteria MS4 NPDES
16-1 1-14-ib C NSW 8.1 FW Miles I BA44 NCE Turbidity 7.4 NR* BA44 NCE
BA45 NCE
BA747 NCE
BA45 NCE
From North Buffalo Creek WWTP to Buffalo Creek BB407 P 2003
Philadelphia Lake (Buffalo lake, and White Oak Lake)
16-1 I-14-1-2b C NSW 18.0 FW Acres S
White Oak Lake
Habitat Degradation MS4 NPDES
Fecal Coliform Bacteria MS4 NPDES
Turbidity MS4 NPDES
BA749 NCE Turbidity IC
NR*
BA749 NCE
Fecal Colifonn Bacteria MS4 NPDES
Turbidity
MS4 NPDES
CAPE FEAR Subbasin 03-06-02

Table 5 CAPE FEAR Subbasin 03-06-02
AU Number Classification Length/Area
Description
Reedy Creek
16-1I-(1)a
WS-III NS
From source to UT 0.7 miles downstream of SR 2128
Aquatic Life Assessment Recreation Assessment
Year/
AL Rating Station Result Parameter % Exc REC Rating Station Result
8.1 FW Miles S BA760 NCE
BB362 GF 2003
BB362 G 2001
BB386 GF 2003
S BA760 NCE
Stressors Sources
Habitat Degradation Impervious Surfac.
16-11-(1)b WS-III NS 4.2 FW Miles I
From SR 2128 to a point 0.4 mile downstream of Moores
Creek
ND
BF54 F '1999
Habitat Degradation Impervious Surfaa
Reedy Fork (Hardys Mill Pond)
16-1 I-(9)al C NSW 6.7 FW Miles
From Lake Townsend Dam to UT at SR 2782
BA757 NCE
$ BA757 NCE
I6-11-(9)a2 C NSW 2.2 FW Miles
From UT at SR 2782 to UT at SR 2778
BB404 F '2003
BF65 G 2003
ND
16-11-(9)a3 C NSW 3.0 FW Miles S
From Ut at SR 2778 to Buffalo Creek
BA38 NCE
S BA38 NCE
16-11-(9)b C NSW
From Buffalo Creek to Flaw River
8.6 FW Miles S
BA58 NCE
Reedy Fork(including Lake Brandt and Lake Townsend below nor
I6-1 I-(3.5)a
Lake Brandt
WS-111 NS
760.0 FW Acres S
BL2 NCE
16-11-(3.5)b WS-III NS 1,404.7 FW Acres S
Lake Townsend
Richland Creek (Richland Lake)
16-1I-7-(I)a WS-1I1NS
3.1 FW Miles S
From source to backwaters of Richland Lake
BL3 NCE
BA758 NCE
BA58 CE
BA58 NCE
ND
Fecal Coliform Bacteria Urdcnown
ND
NR*
BA758 NCE
Ryan Cree
16-11-14-2-3
C NSW
From source to South Buffalo Creek
4.2 FW Miles
BA754 CE Turbidity 14
NR"
BA754 NCE
Fecal Coliform Bacteria Unknown
Fecal Coliform Bacteria MS4 NPDES
Turbidity MS4 NPDES
CAPE FEAR Subbasin 03-06-02

Table 5 CAPE FEAR Subbasin 03-06-02
AU Number Classification Length/Area
Description
Aquatic Life Assessment Recreation Assessment
Year/
AL Rating Station Result Parameter % Exc REC Rating Station Result
Stressors Sources
South Buffalo Creek
16-I1-14-2a C NSW
From source to McConnell Rd
15.4 FW Miles
BA50 NCE Turbidity 7.3
BA752 CE Turbidity 14
BA756 NCE
BB406 P 2003
NR*
BA50 NCE
BA752 NCE
BA753 NCE
1111111111111111111111
Habitat Degradation MS4 NPDES
Fecal Coliform Bacteria MS4 NPDES
Turbidity MS4 NPDES
I6-11-14-2b C NSW
From McConnell Rd to US 70
4.7 FW Miles 1
BF73 P 2003
ND
Habitat Degradation MS4 NPDES
16-11-14-2c C NSW
From US 70 to Buffalo Creek
Stony Creek (Lake Burlington)
I6-14-(1)a Ws -II HQW
From source to Benton Branch
4,8 FW Miles
4.3 FW Miles
BA54 CE Turbidity 10.5
ND
BA54 NCE
Turbidity
MS4 NPDES
BF26 GF '2003
ND
Habitat Degradation
16-I4-(1)b Ws -II HQW 2.7 FW Miles S
From Benton Branch to backwaters of Lake Burlington
BB231 GF 2003
ND
Habitat Degradation
16-14-(1)c Ws-11 HQW
Lake Burlington
738.0 FW Acres NR
BL5 NCE Chlor a 33
ND
Chlorophyll a
Agriculture
Stony Creek (Stony Creek Reservoir)
I6-14-(5.5) WS-II HQ 118.0 FW Acres
From Buttermilk Creek to dam at Stony Creek Reservoir
Town Branch
I6-17
C NSW
From source to Haw River
4.2 FW Miles
Unnamed Tributary at Guilford College
16-I1-5-I-(2)
WS-III NS 1.3 FW Miles
From dam at Guilford College bathing lake to Horsepen
Creek
BL6 NCE
BA78 NCE
ND
BB68 P 2001
ND
BA78 NCE
BA78 CE
Fecal Coliform Bacteria MS4 NPDES
CAPE FEAR Subbasin 03-06-02

limits during the last two years of the assessment period as well. The schools are under a special
order of consent (SOC# S91039) that expires in June 2005. The schools are expected to be
connected to the City of Greensboro collection system and cease discharging by March 2005.
Segment 16-11-(9)a3 is Supporting aquatic life because no criteria were exceeded at site BA38.
Reedy Fork [16-11-(9)b] from Buffalo Creek to the Haw River (8.6 miles) is Impaired for
recreation because the fecal coliform bacteria standard was violated at site BA58. This segment
is Supporting aquatic life because no criteria were exceeded at site BA58.
2005 Recommendations
DWQ will continue to monitor this segment of Reedy Fork to identify stressors to the fish
community. This portion of the watershed could experience growth in the next few years. Every
effort should be made to minimize impacts to Reedy Fork. Flow conditions should be
maintained below Lake Townsend to minimize adverse impacts to the downstream benthic
community (Chapter 32). DWQ recommends that the City of Greensboro (Appendix V)
continue to monitor water quality at sites on Reedy Fork. The NPDES compliance process will
be used to address the significant permit violations noted above. Further recommendations to
protect streams in urbanizing areas and to restore streams in existing urban areas are discussed in
Chapter 31.
Segments 16-11-(9)a2 will be added to the 303(d) list of Impaired waters and 16-11-(9)b will
remain on the list because of the recreation impairment and because of past biological
impairment. TMDLs (Chapter 35) will be developed for identified stressors within 8-13 years of
listing.
2.3.7 Ryan Creek [AU # 16-11-14-2-3]
Current Status
Ryan Creek was Not Rated in the 2000 basin plan; however, Ryan Creek [16-11-14-2-3] from
source to South Buffalo Creek (4.2 miles) is currently Impaired for aquatic life because the
turbidity standard was violated at site BA754 in 14 percent of samples. Ryan Creek is Not Rated
for recreation because fecal coliform bacteria screening criteria were exceeded at site BA754.
2005 Recommendations
DWQ recommends that the City of Greensboro (Appendix V) continue to monitor water quality
in Ryan Creek and submit these data to DWQ. DWQ will determine if intensive sampling is
needed to assess the fecal coliform bacteria standard in this creek (Appendix X). Further
recommendations to protect streams in urbanizing areas and to restore streams in existing urban
areas are discussed in Chapter 31.
Ryan Creek will be added to the 303(d) list of Impaired waters because of the turbidity
violations. TMDLs (Chapter 35) will be developed for identified stressors within 8-13 years of
listing.
Chapter 2 — Cape Fear River Subbasin 03-06-02 26

2.3.8 South Buffalo Creek [AU# 16-11-14-2a, b and c]
2000 Recommendations
The 2000 basin plan recommended that South Buffalo Creek be resampled and that TMDLs be
developed for identified stressors, and that the City of Greensboro stormwater program work to
improve water quality in this creek.
Current Status
South Buffalo Creek [all segments] from source to Buffalo Creek (24.9 miles) is Impaired for
aquatic life because the turbidity standard was violated in 14 and 11 percent of samples at sites
BA752 and BA54, Fair and Poor benthic community ratings at sites BB444 and BB406, and Fair
and Poor fish community ratings at sites BF 18 and BF73. The stream is filled with debris and
has undercut banks. Periphyton covered rocks at the site below the Metro WWTP. The Metro
WWTP (NC0047384) also had significant violations of cyanide permit limits, which could have
adversely impacted aquatic life in the creek. The facility is conducting a cyanide study to
determine the source of the violations. South Buffalo Creek is Not Rated for recreation because
fecal coliform bacteria screening criteria were exceeded at sites BA50, BA752 and BA753.
2005 Recommendations
DWQ recommends that the City of Greensboro (Appendix V) continue to monitor water quality
on South Buffalo Creek and submit these data to DWQ. DWQ will continue to work with the
City of Greensboro to identify measures that can be used to reduce stormwater impacts to the
creek. The NPDES compliance process will be used to address the significant permit violations
noted above. DWQ will determine if intensive sampling is needed to assess the fecal coliform
bacteria standard in this creek (Appendix X). Further recommendations to protect streams in
urbanizing areas and to restore streams in existing urban areas are discussed in Chapter 31.
All three segments will remain on the 303(d) list of Impaired waters. TMDLs (Chapter 35) will
be developed for identified stressors within 8-13 years of listing.
Water Quality Initiatives
In 1997, Greensboro received a $800,000 CWMTF (Chapter 34) grant to acquire 40 acres to
construct a stormwater wetland along South Buffalo Creek. In 2002, Greensboro received a
$570,000 CWMTF grant to construct a 20-acre stormwater wetland along South Buffalo Creek
treating runoff from 13 square miles of urban land.
NCEEP has completed 1,752 linear feet of stream restoration in Benbow Park, 2,748 linear feet
in Brown Park, 5,963 linear feet in Hillsdale Park and 1,776 linear feet in Price Park. Also
completed were 5,963 linear feet of stream restoration and 1,200 linear feet of stream
enhancement at Gillespie Golf Course (Chapter 34).
2.3.9 Town Branch [AU# 16-17]
2000 Recommendations
Town Branch was Impaired in the 1996 basin plan, but limited sampling resulted in a Not Rated
status in the 2000 basin plan. The 2000 plan recommended that Town Branch be resampled.
Chapter 2 — Cape Fear River Subbasin 03-06-02 27

NC 2010 Integrated Report Categories 4 and 5 Impaired Waters
All 13,123 Waters in NC are in Category 5-303(d) List for Mercury due to statewide fish consumption advice for several fish species
AU_Number AU Name AU_Description LengthArea AU_Units Classification
Category' Parameter Reason for Rating
Use Category Collection Year 30 3(d)year
Cape Fear River Basin Reedy Fork Watershed 0303000201
Cape Fear River Basin Haw River Subbasin 03030002
Cape Fear River Basin Reedy Fork Watershed 0303000201
0 16-11-4-(1)a1 Brush Creek From source to UT at SR 2085 2.4 FW Miles WS-III;NSW
5 Ecological/biological Integrity Benthos Fair Bioclassification Aquatic Life 2003 1998
16-11-4-(1)a3 Brush Creek
5 EcologicaUbiological Integrity Benthos
From UT 0.3 miles downstream of SR 3820
to a point 0.5 mile downstream of Guilford
County SR 2190
Fair Bioclassification Aquatic Life
1.6 FW Miles WS-III;NSW
2003 1998
5 EcologicaUbiological Integrity FishCom
Fair Bioclassification Aquatic Life
2004 1998
Q 16-11-5-(0.5)a Horsepen Creek
5 EcologicaUbiological Integrity Benthos
From source to Ballinger Road 1.8 FW Miles WS-III;NSW
Poor Bioclassification Aquatic Lifc
2001 1998
Q 16-11-5-(0.5)b Horsepen Creek
5 EcologicaUbiological Integrity Benthos
From Ballinger Road to U.S. Hwy 220 3.2 FW Miles WS-III;NSW
Poor Bioclassification Aquatic Lifc
2000 2000
Q 16-11-5-(2)
Horsepen Creek From U.S. Hwy 220 to Lake Brandt, Reedy 1.8 FW Miles WS-
Fork III;NSW,CA
5 EcologicaUbiological Integrity Benthos
Fair Bioclassification Aquatic Life
2008 2000
5 EcologicaUbiological Integrity FishCom
Fair Bioclassification Aquatic Life
2004 2000
Q 16-11-14-1a1 North Buffalo Creek
5 Ecological/biological Integrity Benthos
From source to Philadelphia Lake
Poor Bioclassification Aquatic Life
7.5 FW Miles C;NSW
1997 1998
5 EcologicaUbiological Integrity FishCom
Poor Bioclassification Aquatic Life
2004 1998
4t Fecal Coliform (recreation)
Standard Violation Recreation
2008 1998
Q 16-11-14-1a2
North Buffalo Creek From Philadelphia Lake to North Buffalo 1.6 FW Miles C;NSW
Creek WWTP
5 Ecological/biological Integrity Benthos
Poor Bioclassification Aquatic Life
1998 2008
4t Fecal Coliform (recreation)
Standard Violation Recreation 2008 2008
0 16-11-14-1b
4b Ammonia
North Buffalo Creek From North Buffalo Creek WWTP to Buffalo 8.1 FW Miles C;NSW
Creek
Data Inconclusive Aquatic Life 2000 2000
5 Copper
Standard Violation Aquatic Life 2008 2008
4s Ecological/biological Integrity Benthos
Fair Bioclassification Aquatic Life
2008 2008
4s Ecological/biological Integrity FishCom
Poor Bioclassification Aquatic Lifc
2003 2008
5 Zinc
Standard Violation Aquatic Lifc 2008 2008
NC 2010 Integrated Report Category 4 and 5 303(d) List EPA Approved Aug 31, 201 9/20/2010 Page 3 of 145

NC 2010 Integrated Report Categories 4 and 5 Impaired Waters
All 13,123 Waters in NC are in Category 5-303(d) List for Mercury due to statewide fish consumption advice for several fish species
AU_Number AU Name AU_Description LengthArea AU_Units Classification
Category Parameter
Reason for Rating Use Category Collection Year 303(d)ycar
Cape Fear River Basin
Q 16-11-(1)b
Reedy Fork
5 Ecological/biological Integrity FishCom
From SR 2128 to a point 0.4 mile
downstream of Moores Creek
Reedy Fork Watershed 0303000201
4.2 FW Miles WS-III;NSW
Fair Bioclassification Aquatic Life
2004 2006
Q 16-11-(9)b Reedy Fork (Hardys
Mill Pond)
5 Fecal Coliform (recreation)
From Buffalo Creek to Haw River
Standard Violation Recreation
8.6 FW Miles C;NSW
2008 2004
5 Zinc
Standard Violation Aquatic Life
2008 2008
Q 16-11-14-2a South Buffalo Creek
From source to McConnell Rd
4s EcologicaUbiological Integrity Benthos Fair Bioclassification
Aquatic Life
15.4 FW Miles C;NSW
2008 2008
Q 16-11-14-2b South Buffalo Creek
5 Ecological/biological Integrity FishCom
From McConnell Rd to US 70
Poor Bioclassification Aquatic Life
4.7 FW Miles C;NSW
2003 1998
Q 16-11-14-2c South Buffalo Creek
4b Ammonia
From US 70 to Buffalo Creek
Data Inconclusive Aquatic Life
4.8 FW Miles C;NSW
2000 2000
5 Copper
Standard Violation Aquatic Life
2008 2008
4s Ecological/biological Integrity FishCom
Poor Bioclassification Aquatic Life
1994 2008
5 Zinc
Standard Violation Aquatic Lifc
2008 2008
Q 16-11-5-1-(2) Unnamed Tributary
at Guilford College
5 Ecological/biological Integrity Benthos
From dam at Guilford College bathing lake
to Horsepen Creek
Poor Bioclassification Aquatic Life
1.3 FW Miles WS-III;NSW
2001
2006
Cape Fear River Basin
16-(1)a
HAW RIVER
5 EcologicaUbiological Integrity Benthos
From source to SR 2109
Fair Bioclassification Aquatic Life
Headwaters Haw River Watershed 0303000202
7.8 FW Miles C;NSW
1998 2000
C) 16-(1)b HAW RIVER
5 Copper
From SR 2109 to SR 2426
Standard Violation Aquatic Life
12.5 FW Miles C;NSW
2008 2008
Q 16-7a Little Troublesome
Creek
5 EcologicaUbiological Integrity Benthos
From source to Reidsville WWTP
Fair Bioclassification Aquatic Lifc
3.5 FW Miles C;NSW
1994 2000
Q 16-6-(3) Troublesome Creek
5 Low Dissolved Oxygen
From dam at Lake Reidsville to Haw River
Standard Violation Aquatic Life
1.8 FW Miles C;NSW
2008 2010
Cape Fear River Basin
Big Alamance Creek Watershed 0303000203
NC 2010 Integrated Report Category 4 and 5 303(d) List EPA Approved Aug 31, 201 9/20/2010
Page 4 of 145

IWC Calculations
Facility: Greensboro TZ Osborne WWTP Spec Limits
NC0047384
Prepared By: Jim McKay
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
56
2.1
4.7
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/l)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
2.1 s7Q10 (CFS)
56 DESIGN FLOW (MGD)
86.8 DESIGN FLOW (CFS)
17.0 STREAM STD (MG/L)
0 Upstream Bkgd (mg/I)
98 IWC (%)
17 Allowable Conc. (mgll)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100mI DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
1.02 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I
4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter)
5. BAT for Major Municipals: 1 mg/I (year-round)
2.1
56
86.8
1.0
0.22
98
1.0
4.7
56
86.8
1.8
0.22
95
1.9
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)
NPDES Server/Current Versions/WLA; TB 1/16/2009

Nutrients:
The City holds total nitrogen and total phosphorus allocations for the T.Z. Osborne and the North
Buffalo Creek WWTPs pursuant to the Wastewater Discharge Requirements rule (T15A NCAC
02B .0270) of the Jordan Water Supply Nutrient Strategy. The current allocations, including
those acquired from regionalized facilities, are as follows:
Total Nitrogen Allocations
Total Phosphorus Allocations
Facility
Discharge
(Ib/yr)
Transport
Factor
Delivered
(Ib/yr)
Discharge
(Ib/yr)
Transport
Factor
Delivered
(Ib/yr)
T.Z. Osborne WWTP
645,277
45%
290,375
81,156
44%
35,708
N. Buffalo Cr. WWTP
257,438
43%
110,698
32,359
42%
13,591
Totals
401,073
49,299
At the City's request, the Division modified both NPDES permits in November 2010 to combine
the limits for nitrogen and for phosphorus for the two facilities. The resulting limits are 401,073
lb/yr TN and 49,299 lb/yr TP, both expressed as delivered loads rather than discharge loads.
Ultimately, the Jordan Wastewater rule governs nutrient contributions to Jordan Lake. However,
due to differences in the facilities' transport factors, similar loads of nitrogen or phosphorus
discharged from both facilities would contribute slightly different Loads to the lake. Thus, it
becomes necessary to convert values measured at each point of discharge and work in terms of
delivered loads.
If wastewater flows are consolidated and discharged at the T.Z. Osborne plant's Outfall 001, the
same combined load limits would apply, that is, 401,073 lb/yr TN and 49,299 lb/yr TP as
delivered loads. However, because the combined flows would be discharged at a single outfall, it
would again be possible to express the nutrient limits as discharge loads. Using the transport
factors for the T.Z. Osborne plant, the combined delivered limits translate to combined discharge
limits of 891,272 lb/yr TN and 112,044 lb/yr TP. These are equivalent to 5.23 mg/L TN and 0.66
mg/L TP at the combined permitted flow of 56 MGD.
Under the rule, the total phosphorus limit is already in effect, and the total nitrogen limit will
become effective January 1, 2016.

�c,orI fA'
City of Greensboro
North Carolina
November 16, 2010 [via email -Hard copies to follow by U.S. Mail]
Mr. Chuck Wakild
Mr. Matt Matthews
Mr. Jeff Poupart
NC Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh NC 27699-1617
Water Resources Department
RE: Request for Speculative NPDES Limits for T. Z. Osborne WWTP
[NPDES Permit #NC0047384] At Permitted Flow of 56 MGD
Gentlemen:
The City of Greensboro Water Resources Department hereby requests speculative NPDES permit limits
for the T. Z. Osborne WWTP at a permitted flow of 56 MGD. Time is of the essence for this request,
since the design and construction of our BNR processes must be completed by CY 2016 in order to
comply with the total nitrogen targets in the Jordan lake Rules.
Background Information on City of Greensboro WWTPs
• Permitted Flows: North Buffalo = 16 MGD T. Z. Osborne = 40 MGD
• Unique Situation with existing Wastewater Transfer Station between North Buffalo WWTP
[NC0024325] and T. Z. Osborne WWTP [NC0047384] and capability to pump entire North Buffalo 16
MGD permitted flow to T. Z. Osborne WWTP
• Both WWTPs discharge into the same basin (Cape Fear River Basin)
• City of Greensboro would like to decommission the North Buffalo WWTP and consolidate all
treatment processes at the T. Z. Osborne WWTP
• Detailed BNR design study by Hazen and Sawyer/CDM team
o One Year Pilot IFAS Study Completed at T. Z. Osborne WWTP ($2.5 Million)
o Various BNR treatment scenarios for both WWTPs
• Included one scenario that decommissioned North Buffalo WWTP
• Parts of the current North Buffalo WWTP were built in the 1930's and retrofitting
this facility would require extensive equipment replacement in order to operate
efficient BNR processes
• All biosolids treatment for both WWTPs is already conducted at the T.Z. Osborne Plant (Fluidized
Bed Incinerator)
• Current Greensboro NPDES permits have "bubble provision" for total phosphorus
• Neither North Buffalo Creek nor South Buffalo Creek are listed on the 303(d) list for low dissolved
oxygen concentrations

Benefits/Advantages of North Buffalo WWTP Decommission
■ Environmental Benefit: Using current NPDES permit limits for both WWTPs, eliminating the North
Buffalo WWTP and transferring the flow to the T. Z. Osborne WWTP would result in a 50% reduction
in the current NPDES permitted loading for the North Buffalo WWTP for CBOD and ammonia
nitrogen since the T. Z. Osborne WWTP CBOD and ammonia nitrogen limits are more stringent as
indicated below:
North Buffalo WWTP Current Permitted Loadings at 16 MGD Permitted Flow
Parameter
Summer Permitted Load
Winter Permitted Load
Annual Permitted Load
CBOD
228,449 pounds
322,391 pounds
550,840 pounds
Ammonia
114,225 pounds
161,196 pounds
275,420 pounds
T. Z. Osborne WWTP Current Permitted Loadings for 16 MGD of Flow
Parameter
Summer Permitted Load
Winter Permitted Load
Annual Permitted Load
CBOD
114,225 pounds
161,196 pounds
275,420 pounds
Ammonia
57,112 pounds
80,598 pounds
137,710 pounds
■ Cost Reduction for DWQ: DWQ has historically encouraged regional WWTPs and the removal of one
discharge/NPDES permit would eliminate the related permit issuance, inspection and oversight
burden on DWQ (as well as the City of Greensboro)
• Economic Benefit to the City of Greensboro: From resulting reduction in staff and Tess costly
installation of BNR processes at only one WWTP.
This request is extremely time -sensitive as we are currently in the process of making the final design
decisions on the BNR processes. DWQ's response to the City's request for speculative limits is a critical
component of the decision -making process. The City of Greensboro and our consulting engineers have
scrutinized every available option for BNR processes and have concluded that expanding T. Z. Osborne
to 56 MGD is the best option for the environment, the City and DWQ. Millions of dollars are at stake
and thus, we feel an expedited speculative limits request is warranted.
If you have any questions, or need additional information, please do not hesitate to contact me via
email or at 336-373-2050.
Sincerely,
Auaw W alia w, k
Allan Williams
Director of Water Resources
cc: Don Howard, Water Reclamation Manager [via email]
Martie Groome, Laboratory and Industrial Waste Section Supervisor [via email]
Walter Kling, Operations Superintendent [via email]
Robert DiFiore, Hazen and Sawyer Engineers [via email]
Steve Tedder, NCDENR-DWQ Winston-Salem Regional Office [via email]