NC0024210_Permit Modification_20030227

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
February 27, 2003
Mr. Perry A. Kairis, P.E.
Director of Public Services
City of High Point
P.O. Box 230
High Point, North Carolina 27261
NCDF.wH-.-R
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Modification Issuance
High Point Eastside WWTP
NPDES Permit No. NCO024210
Guilford County
Dear Mr. Kairis:
Attached to this letter is the Baal NPDES permit for the City of High Point's Eastside
Wastewater Treatment Plant, NPDES Permit No. NC0024210. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9,
1994.
Based on your letter dated December 9, 2002, the following changes (and clarifications) have been
made to the permit from the draft permit:
„+- _Weekly average ammonia limits were added based on the requirement in the Code of Federal
egulations (140 CFR 122.45(d)] and a subsequent agreement between the Division of Water
Quality and EPA Region IV [Implementation Policy for Permits with Monthly Average NH3-N
Limts, dated October 15, 20021. In summary, the regulation states that for each monthly
average limit, a corresponding weekly average (POTWs) or daily maximum (non-POrIWs) limit is
required in the permit. The ratio of 3x the monthly average limit for the NH3-N weekly average
value was based on data analyses of municipal facilities that were designed to nitrify,
essentially, the weekly average limit is a treatment technology based limit. Analyses of High
Point's data indicated a need for a Limit.
• The reopener clause for NH3-N has been removed (since weekly average NH3-N limits have
been implemented). Weekly average limits are imposed for both the 16 MGD and 26 MGD
flows.
Many of the other questions in your letter pertain to requirements that were not modified (and
these should have been addressed prior to the renewal permit issued May 15, 2002). The
following brief comments are offered in response:
• The cyanide limit cannot be changed as it is based on the state's water quality standard. \
However, the Division has given some flexibility with regard to compliance evaluation of
cyanide, which is reflected in the footnotes for cyanide.
1617 Mai! Service Center, Raleigh, North Carolina 27699.1617 919 733-SM, extension 510 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer SusanAWilson®ncmail.net

• The dissolved oxygen limits for both the 16 MGD and 26 MGD flows are correct (they are
different due to the impact of the different flows on the receiving stream).
• Due to the different permitted flows (16 MGD and 26 MGD), the instream waste concentrations
are slightly different. Because the effluent metal concentrations are based on the instream
waste concentrations, they vary with the effluent flow, as well as with the stream flow (this is
the reason for the slight difference in effluent metal concentrations).
• The phenols limit at 26 MGD is correct. High Point was given the flexibility of monitoring at
the current flow with a limit for the expansion flow (due to the water supply classification).
• The second downstream monitoring point is NCSR 1921 (and this has been specified in the
permit issued in 2000, as well as the permit issued in 2002). Instream monitoring points are
generally based on locations near the predicted point of impact (usually the predicted point of
lowest dissolved oxygen based on the water quality model). We encourage the city to work
with the regional office if there is a justifiable reason to move the instream monitoring point. If
so, the permit may be modified to better accommodate High Point, while still obtaining
appropriate fnstream data.
• The removal efficiencies for BOD5 and TSS are a federal requirement for POTWs Iref. 40 CFR
1331 and cannot be modified.
You may wish to refer to the issuance letter dated May 25, 2000, as well as the issuance
letter dated May 15. 2002: many questions raised in your letter are addressed in more detail
through those letters.
If any parts, measurement frequencies, or sampling requirements contained in this
modification are unacceptable to you, you have the right to an adjudicatory hearing upon written
request within thirty (30) days following receipt of this letter. This request must be in the form of
a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed
with the office of Administrative Hearings, Mail Service Center 6714. Raleigh, North Carolina
27699-6714. Unless such a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division of
Water Quality. The Division of Water Quality may require modification or revocation and
reissuance of the permit.
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or
any other federal or local governmental permit.
If you have any questions regarding the NPDES permit, please contact Susan Wilson at
(919) 733 - 5083. extension 510.
Sincerely,
Gi / !" ��
Alan W. Klimek, P.E.
cc: Winston-Salem Regional Office/Water Quality Section
Central Files
NPDES Unit
EPA Region IV, Roosevelt Childress

Permit NCO024210
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATUR.AI. RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Water Quality Commission, and the Federal Water
Pollution Control Act, as amended, the
City of High Point
is hereby authorized to discharge municipal wastewater from a facility located at the
High Point East Side WWTP
5898 Riverdale Road
Jamestown
Guilford County
to receiving waters designated as Richland Creek in the Cape Fear River Basin in accordance with the
discharge limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV
hereof.
This permit shall become effective April 1, 2003.
This permit and the authorization to discharge shall expire at midnight on August 31, 2006.
Signed this day February 27, 2003.
Alan W. Klimek, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit NCO024210
SUPPLEMENT TO PERMIT COVER SHEET
The City of High Point is hereby authorized to:
1. Continue to operate a 16.0 MGD wastewater treatment facility consisting of
screening, grit removal, primary sedimentation, flow equalization, trickling filters [to
be decommissioned with upgrade], aeration basins, secondary sedimentation,
residuals thickening devices, filtration, incinerator and time stabilization for
residuals, and effluent LTV disinfection. This facility is located at the High Point
Eastside Wastewater Treatment Plant on Riverdale Road in Guilford County.
2. Discharge wastewater from said treatment works at the location specified on the
attached map into Richland Creek, classified WS-IV CA waters in the Cape Fear
River Basin [refer to Part I, A. (1)].
3. Construct treatment facilities not to exceed 26.0 MGD design flow according to
Authorization to Construct permit 0024210 ACE
4. After expansion to 26.0 MGD is completed, discharge wastewater from the approved
treatment works at the location specified on the attached map into
1) Richland Creek [refer to Part I, A. (2)], or
2) The Deep River, if the Randleman Reservoir is constructed [refer to Part I, A. (3.)]
Both Richland Creek and The Deep River are classified as WS-IV CA waters in
the Cape Fear River Basin.

f
I
1.
0 ON
1

Permit NCO024210
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (16.0 MGD)
During the period beginning on the effective date of the permit and lasting until expansion above 16.0 MGD, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frnuency
Sample
Type
Sample Locationl
Flow
16.0 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day (204C)2
[April 1- October 31
8.0 mg/L
12.0 mg/L
Daffy
Composite
Influent & Effluent
BOD, 5 day (20'C)2
[November 1-March 31
16.0 mg/L
24.0 mg/L
Daily
Composite
Influent & Effluent
Total Suspended Residue2
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent &Effluent
NH3 as N Aril 1- October 311
3.0 m
9.0 mg1L
Daily
Composite
Effluent
NH3 as N November 1- March 31
6.0 m
18.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Dissolved Oxygen
3/Week
Grab
Upstream &
Downstream
Fecal Coliform(geometric mean
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
3Meek
Grab
Upstream &
Downstream
Total Residual Chlorine4
3/Week
Grab
Effluent
Total Nitrogen NO2+NO3+TKN
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Temperature °C
Daily
Grab
Effluent
Temperature (2C)
3/Week
Grab
Upstream &
Downstream
Conductivity
Daily
Grab
Effluent
Conductivity
31Week
Grab
Upstream &
Downstream
Chronic Toxicity,
Quarterly
Composite
Effluent
Total Cadmium
2.1 /igtL
15 L
Weekly
Composite
Effluent
Total Lead
25 N L
33.8 L
Weekly
Composite
Effluent
Total Nickel
25 L
261
Weekly
Composite
Effluent
Total Copper
21Month
Composite
Effluent
Total C anide6
5 /rg/L
22 Ng/L
Weekly
Grab
Effluent
Total Mercury
Quarterly
Composite
Effluent
Phenois7
Quarterly
Grab
Effluent
Total Silver
Quarterly
Composite
Effluent
Total Zinc
2/1VIonth
Composite
Effluent
PH8
Daily
Grab
Effluent
Footnotes:
Upstream (2 locations): (1) Richland Creek at least 100 feet above outfall, (2) Deep River at NCSR 1113. Downstream (2
locations): (1) Deep River at NCSR 1129, (2) Deep River at NCSR 1921. Stream samples shall be grab samples collected
3/Week during June — September and 1 /Week during the remaining months of the year. Asa participant in the Cape Fear
River Basin Association, the instream monitoring requirements as stated above are waived. Should your membership in the
agreement be terminated, you shall notify the Division immediately and the instrearn monitoring requirements specified in
your permit shall be reinstated.
(continued on next page)

Permit NCO024216 '
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (16.0 MGD)
Footnotes (continued
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
4. Monitoring for total residual chlorine is required only if chlorine is used as a back-up disinfection method.
5. Chronic Toxicity (Ceriodaphnia dubia) P/F at 90%: January, April, July, and October [see Part I, A. (4.)]. Toxicity
monitoring shall coincide with metals and cyanide monitoring.
6. The quantitation limit for cyanide shall be 10 µg/L (10 ppb). Levels reported at less than 10 µg/L shall be
considered zero for compliance purposes.
7. Phenols are defined as chlorinated phenolic compounds. Specifically, 4-chloro-3-methylphenol, 2-chlorophenol,
2,4-dichlorophenol, 2,4-dimethylphenol, 2,4-dinitrophenol, 2-methylphenol, 4,6-dimethylphenol, 2-nitrophenol,
4-nitrophenol, pentachlorophenol, phenol, and 2,4,5-trichlorophenol should be monitored.
8. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO024210
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (26.0 MGD)
(Expansion and discharge to Richland Creek)
During the period beginning upon expansion above 16.0 MGD and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below.
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Locationl
Flow
26.0 MGD
Continuous
Recordin
Influent or Effluent
BOD, 5 day (209C)2
[April 1- October 31 ]
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent & Effluent
BOD, 5 day (209C)2
[November 1- March 31 ]
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent & Effluent
Total Suspended Residue2
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent & Effluent
NH3 as N ril 1- October 311
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
NH3 as N November 1- March 31
2.0 m
6.0 mg/L
Daily
composite
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Dissolved Oxygen
3/Week
Grab
Upstream &
Downstream
Fecal Coliform(geometric mean
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
31Week
Grab
Upstream &
Downstream
Total Residual Chlorine4
18 pg/L
3/Week
Grab
Effluent
Total Nitrogen (NO2+NO3+TKN)
[April 1- October 31 ]
6.0 mgtL
1301pounds/day
Weekly
Composite
Effluent
Upstream &
Downstream
Total Nitrogen (NO2+NO3+TKN)
[November 1- March 31 ]]
Weekly
Composite
Effluent
Upstream &
Downstream
Total Phosphorus
0.5 mg/L
108pounds/day
Weekly
Composite
Effluent
Upstream &
Downstream
Temperature °C
Daily
Grab
Effluent
Temperature CC)
3/Week
Grab
Upstream &
Downstream
Conductivity
Daily
Grab
Effluent
Conductivity
3/Week
Grab
Upstream &
Downstream
Chronic Toxicity5
Quarterly
Composite
Effluent
Total Cadmium
2.0 /L -
15 /L
Weekly
Composite
Effluent
Total Lead
25
33.8 /L
WeeklyCom
oswu
Effluent
Total Mercury
0.012 /L
Weekly
Composite
Effluent
Total Nickel
25 L
261 /L
Weekly
Composite
Effluent
Phenols6
1.1 pg/L
Weekly
Grab
Effluent
Total Copper
2/Month
Composite
Effluent
Total C anide7
5 pg/L
22 pg/L
Weekly
Grab
Effluent
Total Silver
Quarterly
Composite
Effluent
Total Zinc
2/Month
Composite
Effluent
H8
Daily
Grab
Effluent
(Footnotes on next page)

Permit NCO024216
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (26.0 MGD)
(Expansion and discharge to Richland Creek)
(Continued)
Footnotes:
1. Upstream (2 locations): (1) Richland Creek at least 100 feet above outfall, (2) Deep River at NCSR 1113.
Downstream (2 locations): (1) Deep River at NCSR 1129, (2) Deep River at NCSR 1921. Stream samples shall
be grab samples collected 3/Week during June — September and 1/%Veek during the remaining months of the
year. As a participant in the Cape Fear River Basin Association, the instream monitoring requirements as stated
above are waived. Should your membership in the agreement be terminated, you shall notify the Division
immediately and the instream monitoring requirements specified in your permit shall be reinstated
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L.
4. The chlorine limit and monitoring are required only if chlorine is used as a back-up disinfection method.
5. Chronic Toxicity (Ceriodapbnia dubia) P/F at 90%: January, April, July, and October [see Part I, A. (4.)]. Toxicity
monitoring shall coincide with metals and cyanide monitoring.
6. Phenols are defined as chlorinated phenolic compounds.. Specifically, 4-chloro-3-methylphenol, 2-chlorophenol,
214-dichlorophenol, 2,4-dimethylphenoi, 2,4-dinitrophenol, 2-methylphenol, 4,6-dirnethylphenol, 2-nitrophenol,
4-nitrophenol, pentachlorophenol, phenol, and 2,4,5-trichlorophenol should be monitored.
7. The quantitation limit for cyanide shall be 10 µg/L (10 ppb). Levels reported at less than 10 µg/L shall be
considered zero for compliance purposes.
8. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO024210
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (26.0 MGD)
(Expansion and relocation of discharge to Deep River)
During the period beginning upon expansion above 16.0 MGD and relocation to the Deep River and lasting
until expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Locationl
Flow
26.0 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day (20°C)2
[April 1- October 31 J
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent & Effluent
BOD, 5 day (202C)2
[November 1- March 311
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent & Effluent
Total Suspended Residue2
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent & Effluent
NH3 as N Aril 1- October 311
1.0 m
3.0 mg/L
Daily
Composite
Effluent
NH3 as N November 1- March 31
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
Dissolved OxYgen3
Daily
Grab
Effluent
Dissolved Oxygen
3/Week
Grab
Upstream &
Downstream
Fecal Coliform(geometric mean
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
3/Week
Grab
Upstream &
Downstream
Total Residual Chlorine4
20 µg/L
3/Week
Grab
Effluent
Total Nitrogen (NO2+NO3+TKN)
[April 1. - October 31]
6.0 mg/L
1301pounds/day
Weekly
Composite
Effluent
Upstream &
Downstream
Total Nitrogen (NO2+NO3+TKN)
[November 1- March 311
Weekly
Composite
Effluent
Upstream &
Downstream
Total Phosphorus
0.5 mg/L
108pounds/day
Weekly
Composite
Effluent
Upstream &
Downstream
Temperature °C
Daily
Grab
Effluent
Temperature CC)
3/Week
Grab
Upstream &
Downstream
Conductivity
Daily
Grab
Effluent
Conductivity
3/Week
Grab
Upstream &
Downstream
Chronic Tox1city5
Quarterly
Composite
Effluent
Total Cadmium
2.3 L
15 /L
Weekly
Composite
Effluent
Total Lead
29 /L
33.8 /L
Weekly
Composite
Effluent
Total Mercury
0.014 /L
Weekly
Composite
Effluent
Total Nickel
29 L
261 /L
Weekly
Composite
Effluent
Phenols6
1.4 pg/L
Weekly
Grab
Effluent
Total Copper
2/Month
Composite
Effluent
Total Cyanide7
5 pg/L
22 pg/L
Weekly
Grab
Effluent
Total Silver
Quarterly
Composite
Effluent
Total Zinc
2/Month
Composite
Effluent
H8
Daily
Grab
Effluent
(Footnotes on next page)

Permit NCO024210
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (26.0 MGD)
(Expansion and relocation of discharge to Deep River)
(Continued)
Footnotes:
1. Upstream = Deep River at NCSR 1129. Downstream = Deep River at NCSR 1921. Stream samples shall be
grab samples collected 3/Week during June — September and 1/Week during the remaining months of the year.
As a participant in the Cape Fear River Basin Association, the instream monitoring requirements as stated above
are waived. Should your membership in the agreement be terminated, you shall notify the Division immediately
and the instream monitoring requirements specified in your permit shall be reinstated.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L.
4. The chlorine limit and monitoring are required only if chlorine is used as a back-up disinfection method.
5. Chronic Toxicity (Ceriodaphnia dubia) P/F at 85%: January, April, July, and October [see Part I, A. (5.)J. Tonicity
monitoring shall coincide with metals and cyanide monitoring.
6. Phenols are defined as chlorinated phenolic compounds. Specifically, 4-chloro-3-methylphenol, 2-chlorophenol,
2,4-dichlorophenol, 2,4-dimethylphenol, 2,4-dinitrophenol, 2-methylphenol, 4,6-dimethylphenol, 2-nitrophenol,
4-nitrophenol, pentachlorophenol, phenol, and 2,4,5-trichlorophenol should be monitored.
7. The quantitation limit for cyanide shall be 10 µg/L (10 ppb). Levels reported at less than 10 µg/L shall be
considered zero for compliance purposes.
8. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO024210
A. (4.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (Quarterly)
RICHLAND CREEK discharge
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of January, April, July, and October. Effluent sampling for
this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,
then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: NC DENR DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility
name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the
comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited
above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival,
minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring.

Permit NCO024210
A. (5.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (Quarterly)
DEEP RIVER discharge
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 85 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of January, April, July, and October. Effluent sampling for
this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,
then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: NC DENR DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility
name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow' in the
comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited
above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival,
minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring.

FE6:14-2003 14:26 FROM:NC DIVISION OF WATER 3367714630
TO:69197339612 P:1/8
^FjiVIpDNMElIT AND NATURAL RFjOURCFS
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rNonn 33r; lidWo FAR 536771.4030
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FAX TRANSMITTAL
'Vyater Quality Section FEB 14 2003
N- inston-Salem Regional Office
;Ss �Y2ughtoNv-n Street
NVinston-Salem. N.C. 27107
phone: [phone]
Fax: [phone]
TO:
FROM:
D:L E:
C0�9%IE\`Tti:_�

FM-14-2003 14:27 FROM:NC DIVISION OF WATER 3367714630 T0:89197339612 P:2/8
M1ir►tnr.'1 t . �ooi.Y....u.....`..
V4A4,q WigiRra G. Ross Jr.. Secretary
0� North Caroling Departrnstn of F-frAronmCni and Natural Resources
Alan W. Klimek, P.E. Director
4
0 7 pension of Water Quality
?
p �
November 14, 2002
Mr. Perry A. Kairis, P.E., Director of Public Services
City of High Point
P. Q. Box 230
14igh Point, NC 27261
SUBJECT: Deep River Outfall Rcpair/Replacement
City of High Point
Guilford County
Mr. Kairis:
As you may be aware, Staff of the Division of Water Quality (Division), Winston-Salem Regional
with pal
Office, met with members of your staff on October 30, 2002. Specifically, Abner �yupon portions of
Hepler and Bill Bethea to make an on -Site assessment of the emergency pon-going
the Deep River Outfall aerials.
A portion n of the recently replaced outfall near Gordon Road was inspected. No obvious problems
,were noted with respect to this portion of the collection system.
A onion of the outfall line from Deep River Road to the Dogwood Circle area was also inspected.
so the outfall
Pinspection of that
This section includes an aerial span across Bouiding Branch. �xhe visible on the line. Additionally, an on -
revealed numerous past line leaks, as evidenced by anti -leak collars
sin leak was discovered on this aerial, just east of Boulding Branch. 'there was also
evidence
id oles.f You
on-
going
manhole overflows on this portion of the line. Debris was observed around each of those l you You
should note that, when issued, your Collection System Permit will contain a Condditio requiring
ea uirind ln store the
among other things, "...remove visible solids and paper, sanitize any group
surroundings" after any sanitary sewer overflows. You should also note that this was merely a cursory
inspection, in that there may well be other sections of the outfall which have similar problems.
Subsequcnt to the on -Site inspection, Mr. Joey Mooney, Superintendent of Water and Sewer Mains,
was contacted. Mr. Mooney indicated that he had recently been informed that City funds wereavailable
to make emergency repairs to all sections of the outfall where problems have been
problematic documented. i s our
within
understanding that Mr. Mooney and his staff have been charged with S
the outfall, and ranking those sections hierarchically, such that those areas most in Heed of addressing immediate
ese
attention are promptly addressed. The Division appreciates the City s commitment to la t
problems.
As you know, staff of the Winston-Salem Regional Office are responsible for evaluating requests
for additional flows to, not only Wastewater Treatment Plants over which the Division
has permitting
authority, but aIso to file coll�ctio>1 sys.�t� � � �re mbutar to those aciliticS. In vie of this fact and,
again, acknowledging, the repair work which is currently underway, we request that you pr fudu a us
following information such that we may make a more informed decision with respect to
allocation requests pertaining to t1lis segment of the City's collection System:
A rlv_ A
t�cal"r�H
N. C. Division of Water auniityMatcr Quality Section SB5 Waugfmwn Street w►n�con•salsm. NC 27107 [phone] Gui soo S T748

FEB,-14-2003 14:28 FROM:NC DIVISION OF WATER 3367714630 TO:89197339612 P:3/8
Mr. Perry A. Kairis
November 14, 2002
Page #2
A. With respect to the identification and repair of e.�isting sections of the outfa�ll:
1, What is the projected time frame for inspection of the entire outfalI
and subsequent repair prioritisation?
2. Realizing that the schedule for completion of emergency repairs is
somewhat dependent on #1 above, does City staff have a preliminary
estimate of completion of repairs?
3. Again, acknowledging that the ultimate costs of the repairs will be in part
dictated by the number and scope of the individual jobs, does City staff
have a preliminary estimate of the costs of the repairs?
B. With respect to the rehabilitation/replacement of the entire Eastside Outfall:
1, is the project Still considered to consist of 6 distinct phases, and if so, what is the
status of each of the phases?
2. What portion of funding does the City have on hand for the project?
Please provide a written response to the letterhead address as quickly as possible. While we realize
that it may take some time to assemble the requested information, you should be aware that our
Office is increasingly hesitant to approve additional flows to this portion of your collection system
without assurances that every effort is being made to eliminate these leaks/overflows. In addition
to the requested informational items, please feel free to forward any other information to us which
you feel is relevant to this situation.
We trust that you understand our position in this matter. Should you have questions, please
contact.our Office at [phone].
Sincerely,
Steve Mauncy
Acting Water Quality Supervisor
cc: Davis, Martin and Powell
jocy Mooncy, City of High Point
Non -Discharge Compliance/Enforcement Unit
Central Files WSRO

F5.A-14-2003 14:28 FROM:NC DIVISION OF WATER 3367714630 TO:89197339612 P:4/8
1'tr: High Paint Visit
Subject: Re: High Point Visit
Date: Thu, 07 .tun 2001 16:44:23 -0400
From: Abner Braddy <[e-mail]>
Organization: NC DENR Water Quality
To: [e-mail]
Greetings Marie. I visited High point on April 25 & 26, 2001. My principal contact during the visit was
with Mark Bullins, whose title is Supervisor, Water & Sewer Mains. I also subsequently had a phone
conversation with Joey Mooney, Superintendent, Water & Sewer Mains, to clarify certain issues raised
during the visit, First, I'll attempt to answer the questions you posed in your email to me, and then I'll add
anything else I ]earned that may be relevant. Rather than repeating your questions, I'll just try to answer in
the same numerical order they were posed:
1- As you and I discussed by phone during the inspection, I made them aware of their 3 options w1 respcct
to properly signing the application (resubmit w1 City Manager or above's signature, letter delegating
authority to sign this application, or letter delegating authority to sign all DWQ applications). If they have
not already resubmitted to you, I guess we need to prompt them in the add. info. letter.
2- You are correct, the flow figures provided are NPDES permitted capacity of the two WWTPs. As I read
paragraph "E" of the CSA Instuctions, I'm assuming that is sufficient. If it is not, what type of figure are we
looking for? Would we rather have average flow through the system, and if so, an average over what period
of time? As you know, the 80\90 % reg. is based on a calendar year's flow, but for many other things, like
P4 reviews. we (WSRO) use the most recent 12 mos. data (Note: These are my questions, not theirs).
3- I have verified that their industrial flow is indeed 5% by checking w\ the WSRO staff who oversee the
pretreatment program for us (BTW, I would have thought their industrial flow was higher than that, but
apparently not). That 5% is all process water. They have an approved pretreatment program.
4- You arc right, they left off the second page of their pump station list in Attachment III of their
application. Further confusing matters, when I asked them to print a complete list, page i showed 24 pump
stations. The page that you have in their application shows 22. As soon as I send you this e-mail, I will fax
you a copy of the revised list provided to me ( pages 1&2), which shows 27 pump stations total. I guess you
just need to trash the one page they sent you in the application, and replace it with the two pages I fax you.
5- They used the term" vacuum" on section fll -7 of the standard application form, and used the term
"siphon" in attachment III-11. It is my understanding that these refer to the same line, which is the siphon
line noted as "Johnson St. @ Hartley Drive". There is also a discrepancy in the length of the line, with the
application stating it's 600', and the attachment saying 700'. I have a call in
to them to clear this up. I will try to get you the correct length.
6- They did not have pump station signage prior to my visit, but they actually dispatched a crew to begin
fabricating signs at their sign shop while I was still there. All stations are now equipped w1 signs. Those
that do not have fences ( see # 7 below) have the signs in the most conspicuous place possible, according to
City personnel. The signs have the 24 hr. customer service number on them.
7- All pump station equipment is locked, and the majority (15 of the 27) are fenced. ,Additionally, each of
the 27 stations is tied in to SCADA, and their particular system includes intruder alarms.
8- City personnel indicated that they had no bypass piping that they were aware of.
9- With respect to High Priority Lines, they will need to resubmit this. Their original application submittal
included lines contacting surface waters, but not sub -waterway crossings. They also need to identify lines
parallel to streambanks which are subject to erosion. Additionally, they indicated that they had identified
additional aerials and one other siphon which -were not included in attachment II.I-11 to the application. The
siphon flows under Oak Hollow Lake which is the City's principal water supply source, so it will definitely
be high priority. Probably need to prompt them on this in add. info. letter.
10- Capacity issues: I'm not sure how many of these are really literally capacity issues ( e.g., pipes too
small ), but review of our spill database, conversation w1 them, and observations made during my
inspection indicate the following problematic areas, where they may need a compliance schedule:
i of 5 ")A-- ) 6/7/2001 4.46 PM

FEB-14-2003 14:29 FROM:NC DIVISION OF WATER 336771400 TO:89197339612 P:S/B
Higb POWE Visit
A) -Line in vicinity of 3211 Flanders Court. When reviewing our database prior to the inspection, this
showed up as having multiple overflows. When questioned, City personnel indicated this line was
undersized, and needed to be replaced. I'm not sure what length of schedule would be appropriate, maybe
just mention it by name in the add. info. letter and tell them we're willing to negotiate a schedule based on
their providing justification of need, and a reasonable time frame.
B) -Line in vicinity of 1609 West Lexington Ave. Review of the database indicates that this line has also
had multiple overflows. City personnel said that the problem on this line is not capacity per so, but rather,
roots. They indicated that they are in the process of trying to acquire easements to replace the line. Again,
not sure what time frame would be involved.
Q -The Deep River Outfall. This line is briefly mentioned in Attachments V (3) & (5). It is referred to in
Attach. V (3) as "hazy Lane @ Herron Pt.". I'm not sure what to say about this line. I looked at portions of
it on day 2 of the site visit. Its, a 16 mile long outfall, and has had some massive spills in the past due to
pipe failure. The line contains many aerial sections that are 19" steel pipe. Upstream subsurface sections of
the outfall are R.C.P. Apparently, crown corrosion has occurred in the concrete sections over a number of
years. As a result, some of the concrete sections have had their tops disintegrate, with the resulting concrete
debris moving down -line into the steel sections (when you stand beneath the aerial sections, it sounds like
someone is rolling marbles through the pipe). The abrasive action of the concrete debris is in turn eating
away at the bottom sections of the steel pipe. Numerous clamps are visible along the aerials, placed to deal
with past leaks. I noted several pin -prick leaks during my inspection. Attach. V (3) notes that replacement
of the line is underway (they were replacing a section during my inspection), but the project is to be done in
6 phases, with their C.I.P. (Attach. IV (3) ) showing the final phase to be completed in FY '02-'03. I would
make two observations here: 1- even private sewer line construction projects rarely meet proposed start or
completion date., public projects never do. 2- I'm not at all sure the line will last another 2-3 years. BTW,
they are trying to chemically control hydrogen sulfide (Biox (sp?), I think), and the replacement steel
sections are to be 36 with a resin inner coating. Anyway, this outfall definitely (in my opinion) needs to be
under a compliance schedule as short as we can possibly make it.
11- Departmental coordination. This is even more fragmented than the application indicates. Sewer
Maintenance deals w\ the pump stations; Sewer Mains deals w\ the gravity & force main lines; Engineering
deals w\ mapping & line replacement issues; Industrial Pretreatment is\will be handling the grease program.
It seems that the chief concern of the personnel I spoke with w\ respect to coordination was their ability to
meet the mapping requirement of having newly eonstucted lines added to their maps w\in one year of
construction completion. I suggested that they approach whatever level of City management high enough
up the hierarchy to have some control over all entities involved, and ask that person to write a memo\
policy dictating the responsibilities of each unit, and specifying those areas where proper communication
must take place in order to comply w\ all conditions of the Permit.
12- C.I.P. As I wrote in an earlier e-mail to Sue H., I'm rather shaky on the Capital Improvement Flan stuff
in general. Basically, I just figure "If you're replacing a pump at an existing pump station, that belongs in
the O & M budget. If you're totally replacing a pump station, that's Capital Improvement." With respect to
what's required in the plans, I can't find anything in HB 1160, the application instuctions, the application
itself, or the Permit that says they have to identify funding sources (the Permit says, @ I-5, designate
funding but it seems to me that you can say "We're gonna spend X dollars", and you've designated funding
w\out identifying the source of the funds). Regardless, I told them they did need to identify the source of
the funds and it is my understanding that they are assembling that information for their anticipated
resubmittal. While the majority of their project list involves replacement\ upgrade projects, project #4 is
extension of sewer lines to new service areas. Is "expansion" really reinvestment as noted in the Permit, or
does it take funding away from reinvestment, which to me, means spending money to rehabilitate\ improve
stuff you've already got (hence, the "re" in reinvestment). It also seems like expansion projects not only
potentially take money from reinvestment in existing portions of the system, but may also exacerbate any
pre-existing downstream sewer problems. Lastly, the application instuctions say that the life expectancy of
the collection system should be included in the C.I.P., and I don't see that in theirs, nor have 1 seen it in
anyone else's. How do you arrive at life expectancy for the system as a whole? Wouldn't it vary from
6 12001 4:46 P;
2of5

Fi=R-14-2003 14:30 FROM:NC DIVISION OF WATER 3367714630 TO:89197339612 P:6/8
R ,: f ligh Point Visit
section to section according to when it was constucted, materials used, etc.? Any thoughts you can give on
C.I.P.s in general would be appreciated.
13- O.&M. Agree that this needs to be morespecific. * Note: When I initially mentioned this on my visit,
they weren't even sure whether this figure was for the collection system only, indicating that it may be for
sewer and water. I have subsequently been told it was for sewer only, but I would prefer to sec some further
breakdown.
14- The grease ordinance is a part of the City's Sewer Use Ordinance. 'Their S.U.O. contains a standard
limit of 100 mgl1, which sounds reasonbablc to me.
15- Grease inspection and enforcement: With respect to inspections, new installations are inspected by the
City Inspections Dept. They are about to begin a program of inspection for existing grease traps (inspection
of existing facilities was not done in the past). This program will be carried out by the City's Industrial
Pretreatment personnel. With respect to enforcement, they initially send a Notice of Violation. They also
have the authority to assess Civil Penalties or discontinue water service. Interestingly, they say that one of
their more effective means of enforcing the code is to bill the violators for labor & materials the City
expends in correcting traceable blockages (1 heard the same thing from Greensboro personnel). They feel
that direct billing is more straightforward and ultimately more punitive than fines.
16- They have an educational program for businesses, in the form of informational letters (see Attach. IV
(5)). They do not have a plan geared to residential users as of yet, but indicated they are going to send out
fliers in the mail. Not sure whether they'll need a schedule on this one. Maybe ask them how long it'll take
in your add. info. letter.
17- See # 15 above.
l 8- New line inspection: At present the City does the inspections, but they plan to contract this out to a 3rd
party. (Either way, they do not take the contractor's word for it).
19- bump reliability: I specifically asked if each duplex station was capable of pumping 2.5x avg. daily
flow w\ either pump out of service and, after they did some checking (Artie Chilton, head of maintenance)
the answer came back "ycs".
20- Of the 27 pump stations, 7 are not equipped with a generator quick -connect. Personnel indicated they
believe some of these 7 may have alternate power circuits, but I have received no confirmation of this.
21- The City has a sophisticated (to me, anyway) SCADA system. The system operates via microwave, all
27 stations are tied in, and, according to staff, the system maintains continuous contact w\ all stations
simultaneously. As noted previously, each station is equipped with an intruder alarm through the system, as
well as the usual high water, pump out, etc. alarms.
22- Currently, their maps don't have approximate pipe age, pump station capacity, or (surprisel) number of
active service taps (as I noted to Sue previously, I have yet to inspect anyone who has the service tap info.)
It is my understanding that we arc not proposing compliance schedules for this condition, as the Permit
already has the built-in 10 year time frame. See comment # 11 for mapping of new construction.
23- City penonnel are keeping records of reportable and non -reportable spills.
24- They have a generic plan, but T've been suggesting to permittees in my inspection letters that they be
more site -specific. As an example, break out to things like "Generator #2 is compatible w\ pump stations B
& E", and identification of the proper replacement pump or parts compatible w\ a specific station and any
equipment needs specific to a particular station (as an example, if there is not a permanently mounted
tripod and hoist for a station, the written plan for that station should say " Bring tripod and hoist").
25- The emergency\standby equipment tests and maintenance are prompted by inputs & outputs via the
SCADA system. They have asset maintenance schedule, and the systems are tested under load.
26- Preventive maintenance logs are reviewed daily (today, would review yesterday's logs); the computer
generates work orders, which are done on 30-90 day cycles; they begin at 90 days, and once a work order is
generated at the same location in 30 days, that location gets an increase in attention to try to eliminate the
source of the problem; the cycles are triggered by blockages. To simplify, a location w\ no problems
entered into the computer will be maintained every 90 days, unless the manufacturer's specs call for greater
frequency. Problem areas will have their frequency increased until the computer indicates that it is being
done every 30 days, at which time more scut iny is given. Complaint response logs are reviewed daily.
3 of 5 6n12001 4:46 PM

FER,-14-2003 14:30 FROM:NC DIVISION OF WATER 3367714630 TO:89197339612 P:7/8
Ri:: High point Visit
27- They subcontract R.O.W. maintenance and have records showing footage mowed (invoiceAreceipts)
but the records don't indicate what areas were mowed, nor when. I told them they need date and location
info. They indicated to me that they could get to all locations w1 a rodder truck, but perhaps not w1 a jct
truck. I'm not sure whether a schedule is needed for this condition or not.
28- Cleaning: As you and I discussed by phone during the inspection, they were somewhat confused about
this ( as, obviously, was I ). They took the question to mean what percentage of discrete, non--repetetive
cleaning was done. If , as we discussed, they should count the total footage of line cleaned (i.e. including
sections that arc done more than once in a calendar year) they feel that they will make the 10%
requirement. I cautioned them that, even though the Permit states that the selection of lines is at the
O.R.C.'s discretion, the purpose of the requirement is to be preventive. Should they have an overflow, and
we determine that the line had not been cleaned within a reasonable amount of time, just being able to
produce documentation that they met the 10% condition is not going to prevent possible enforcement if
they're cleaning the same sections of line time after time.
29- All 27 pump stations are inspected twice weekly, and records are being kept. As previously noted, all
are on SCADA.
30- They are not meeting the Permit requirement to inspect high priority lines every 6 months. I do not
think we should go with any typo of a schedule on this, they should have the resources to accomplish it.
With respect to the yearly general observation of the entire system, it is my understanding that we're giving
them credit for thoso highly visible sections like manholes in the street just by virtue of their daily travels
in the performance of other duties. What do we want in terms of documentation for this (my question)?
Here's some other miscellaneous junk that Ifm not sure who to send to, so, we have a winner, and her
name's Marie !!!
- In the cover letter to the Permits, the word "superscdcs" is spelled incorrectly at line 1.0.
-In line 12 of the cover letter, "determined he considering" should be "by"
and "compliance with the all" should have "the" stricken.
In Conditions 1.2 a, 1.2 b and Condition II 1. in some cases the word is spelled "back-up" and in other
cases "backup".
- In Condition 1.5, "forcasted" should be "forecasted".
- InCondition I.6," waste water" should be "wastewater".
- In Condition I.11, one spelling is "corrosion resistant" and one is "corrosion -resistant'
- In Condition I.17, "in accordance with the 15A" needs to have "the" stricken (I think).
In condition VA one spelling -is "high priority" and one iR "high -priority". Also, doesn't "A list of
high -priority lines are incorporated" need to be "is incorporated" since "list" is the subject (singular)?
How's that for a list of completely inane observations? Call me if you need any other questions asked of
High Point.
M- rie Doklovic wrote:
Hi Ab,
Attached are the topics about Thigh Point's collection system application
that I need more information about in order to compile a formal
additional information request to them. If you have time to tackle
these during your visit, I would appreciate it. If you could let me know
which topics to ask for compliance schedules, at a minimum.
Basically, via my general collection system update message sent earlier,
a of 5 617/2001a:as PM

FEB-14-2003 14:31 FROM:NC DIVISION OF WATER 3367714630 TO:89197339612 P:8/8
P.e.- Higb Point Visit
we have revised our checklist. I did this by going through the permit
shell and application so many questions you see are items that you would
cover on your inspection regularly. So don't be scared!
However you want to touch base after your visit is fine with me. I can
call you, you could Email or fax me the topics that still need addressed
in my formal letter, etc. Thank you so much and call me if you have any
questions!
Have fun,
uric
rr
Marie boklovic, EIT
Environmental Engineer
Division of Water Quality
Nan -Discharge Permitting Unit
........1+wrr------------- wwrrwwrrr--rMwwwwwwwrrrrr------- -..----wr---
Name: Permit Questions for Ab.doc
Permit Questions for Ab.doc Type: Winword File (application/msword)
Encoding: base64
Download Status: Not downloaded with message
5 of 5 It 6f7 MA 4:46 PM

Time to Renew Your Free Subscription!
Stormwater Magazine
Account #: 55061
ROBERT FARMER
NC DEPT ENR - DIVISION OF WQ
1617 MAIL SERVICE CTR
RALEIGH, NC 27699-
Phone:
Fax:
E-Mail:
Please print this form, check the box and sign at the bottom.
If necessary, please make corrections to above information.
(9 Yes, I would like to Renew (Check Box)
o No, Thank You
x
Date
Fax Back To: 413-513-6380

CITY OF HIGH POINT
NORTH CAROLINA
December 9, 2002 DEC 1 6 2002
Ms. Christie R. Jackson
NPDES Permit Unit
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Draft NPDES Permit Modification
Permit,NL C002421_QJ
City of High Point
Eastside WWTP
Guilford County
Dear Ms. Jackson:
I apologize for not submitting comments earlier, but the severity of the ice storm has kept
us from responding any sooner. After reviewing the draft permit, the following are items
that require further clarification.
1. Weekly limits have been added for ammonia on both the 16 MGD and 26 MGD SurM!0
permitted flows. What is the State's basis for the addition? �ot,�
2. Footnote 3 of the 26 MGD permit reads: "The division may reopen this permit to j- ?A a o" r
require weekly average limits for ammonia etc." The permit already includes srATa,tN
weekly limits (3 summer, 6 winter). Perhaps weekly limits should not be in the 3- LQwa I�j
26 MGD permit.
H
The cover letter states, "Based on an agreement between the State of North
Carolina and the Environmental Protection Agency, this permit is being re -opened
to require weekly average limits for ammonia. After calculating allowable I
concentrations and analyzing past ammonia data, the Division has set this limit at / AW7/ L
three times your monthly average concentration (not to exceed 35 mg/1)." How is air, ;
this limit determined on both permits? 'jr
O _
QNC-A,%
Weekly and daily max limits for cyanide (5 ug/l weekly and 22 ug/I daily) have
been added to both the 16 and 26 MGD permits. Footnote 6 states: "The
quantitation limit of cyanide shall be 10 ug/I (10 ppb). Levels reported at less than
10 ug/l shall be considered zero for compliance purposes." Please clarify this
i lE5 /Z,�WAr5. AIC12E /V07 (WAA'17C /3,W/7A115 /v a D1F1C,471a Al
P.O. BOX 230, 211 S. HAMILTON STREET, HIGH POINT. NORTH CAROLINA 27261 FAX [phone] TDD 336-883-8517

statement. The limit needs to be changed to 10 ug/1 to reflect Footnote 6. As you
know, due to the limits of technology, anything below 10 ug/I is non -deductible
and creates false positives.
5. The 16 MGD permit shows in the footnotes: "The daily average dissolved oxygen
effluent concentration shall not be less than 5.0 mg/1." The 26 MGD permits
show in the footnotes: "The daily average dissolved oxygen effluent
concentrations shall not be less than 6.0 mg/l. " Are both these values correct?
yes �� s �, w� ,4OP61.
6. Several of the effluent metals on the 26 MGD plant show slight variations in the
limits of only a few ppb depending on the location of the discharge. How is this
determined?
AfAT�/�
orFfFvir��7-
FLoNS
Based on reading the new permit, the 16 MGD train has no limit for phenols
monitoring only, however the 26 MGD train has permit limits for phenols. Is this
interpretation correct? Is it possible for the phenol limits to follow the same
language as the cyanide limit?
8. What is our final downstream monitoring point to be? In the permit, it is SR 1921
(Coltrane Mill). How was this location determined? There will be many
logistical problems (including sampling) that make this location undesirable for
our point of compliance for all parameters other than dissolved oxygen. /
9. Can the 85% removal for BOD and TSR be amended to include a clause that if
the permit limit is met the removal rate requirement shall be waived?
No-rr:(Irl u zz- MW
If possible, I would request that a meeting be coordinated to discuss these items in detail
to make sure we have a clear understanding of our permits. Please contact me at (336)
883-3166 to discuss this possibility or to discuss any questions or comments.
Sincerely,
rry A. Kairis, P. E.
Director of Public Services
Cc: Terry Houk
Steve Price
File

Asheboro & High Point renewals
Subject: Asheboro & High Point renewals
Date: Tue, 03 Dec 2002 11:45:00 -0500
From: Corey Basinger <[e-mail]>
Organization: NC DENR Water Quality
To: Christie Jackson <[e-mail]>
CC: [e-mail]
Christie,
This email summarizes our phone conversation regarding the permit renewals for
Asheboro (NC0026123) and High Point Eastside (NC0024210).
ASHEBORO (NC0026123)
1) Effluent conductivity monitoring was not required in the previous NPDES permit
(1996-2001). It was required in the permit issued in July 2002. I must have missed it
when I reviewed the draft for the 2002 permit renewal. I don't not see a need for
effluent conductivity monitoring.
HIGH POINT EASTSIDE"'(NC0024210)
1) Footnote #3 needs to be removed from the effluent limits page for "expansion above
16.0 MGD".
2) Are the dual limits for total nitrogen and total phosphorous (mg/1 and lbs/day)
equivalent based on design flow of 26.0 MGD? If so, is there a specific reason for dual
limits? Which form will the facility be required to report, mg/1 or lbs/day?
Other than those items mentioned above, the permits appear to be ready for renewal.
If I discover any further issues, I'll forward them ASAP. Thanks for your assistance
with these.
Have a great day!
Corey
1 of 1 12/3/02 1:43 PN

'Soleo sr4%
A >W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
o <
ATLANTA FEDERAL CENTER
14 PRO, E04\O2
ATLANTA, GEORGIA 30303-8960
November 26, 2002
Ms. Christie Jackson
NPDES Unit
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: Review of NPDES Permit Modifications
Weekly Average Ammonia Limits
Dear Ms. Jackson:
In accordance with the EPA/NCDENR MOA, we have completed our review of the draft
permit modifications to include weekly average ammonia limits. The permits that were reviewed
and have no comment are listed below.
Facility
City of Gastonia WWTP
City of Graham WWTP
City of Fayetteville/Cross Creek WWTP
City of High Point/East Side WWTP
OWASA/Mason Farm WWTP
City of Asheboro WWTP
Town of Siler City WWTP
Johnston County Regional WWTP
City of Hickory/Henry Fork WWTP
City of Dunn/Black River WWTP
Town of Robbins WWTP
Town of Holly Springs WWTP
NPDES Permit No.
NCO020184
NCO021211
NCO023957
*g0024210
NCO025241
NCO026123
NCO026441
NCO030716
NCO040797
NCO043176
NCO062855
NCO063096
Two draft permit modifications, Fuquay-Varina/Kenneth Creek WWTP (NC0028118) and
the City of Burlington/South Burlington WWTP (NC0023876) are not correct. The Fuquay-
Varina draft modification does not have the weekly average limit for the summer months in the
table and the Burlington draft modification does not have the summer and winter weekly average
limits in the table. This no comment letter is conditional for these two permits until the
appropriate corrections are made.
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable 00 Based Inks on Recycled Paper (Minimum 30% Postconsumer)

We request that we be afforded an additional review opportunity only if significant
changes are made to the draft permit modification prior to issuance, or if additional significant
comments to this modification are received. Otherwise, please send us one copy of the final
permit modification when issued. If you have any questions, please feel free to contact me at
[phone] or at [e-mail].
ZSin erely,
Mado n S. Dominy
NPDES & Biosolids Section
Permits, Grants and Technical Assistance Branch
Water Management Division

draft permit modification reviews
Subject: draft permit modification reviews
Date: Wed, 13 Nov 2002 10:55:48 -0500
From: John Giorgino <[e-mail]>
To: Christie Jackson <[e-mail]>
CC: Matt Matthews <[e-mail]>,
Kevin Bowden <[e-mail]>
Hi Christie,
Thank you for sending our unit the following draft permit modifications
for our review:
0020184
0CF-4210
0023957
0021211
0026123
0063096
0025241
0028118
0040797
0062855
0023876
0026441
0030716
Concerning NCO026441 r I noticed sections,A(2) and A(3) were not attached
to the document.
Concerning NCO030716: IWC's are not calculated consistently with
permitted flows. I believe the problem lies with the 7Q 10. Our data
base has it listed at 184 and the permit has it at 170. Can you review
the calculations and forward the correct 7Q 10 for our records?
I have no comments with the other facilities at this time. Thanks for
allowing us to participate in the review process.
Best Regards,
John Giorgino
Aquatic Toxicology Unit
Office: 919 733-2136
Fax: [phone]
1 of 2 1 1 / 14/02 2:19 PiV

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
MEMORANDUM
To
From:
Subject:
Lee Spencer
NC DENR / DEH / Regional En
Winston-Salem Regional Office
Christie Jackson
NPDES Unit
Review of Draft NPDES Permit NCO024210
East Side WWTP
Guilford County
e
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
RECEIVED
C. Dept. of EHNR
NOV 0 7 21002
Winston-Salern
Regional Office
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
November 29, 2002. If you have any questions on the draft permit, please contact me at the telephone
number or e-mail address listed at the bottom of this page.
RESPONSE: (Check one)
❑Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality
standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Nl /r 4 /-m. me C O H H r T T -r-o AA/ .4 6 6 X LS s/ ✓E_
❑ Opposes the issuance of the above permit, based on reasons stated below, or attached:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919733-5083, extension 538 (fax) 919 733-0719
VISIT US ON THE INTERNET 0 httpl/h2o.enr.state.nc.us/NPDES [e-mail]

I Is
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