NC0024210_Speculative Limits_19950918

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Linwood E. O'Neal, P.E.
Director of Public Utilities
P.O. Box 230
High Point, NC 27261-0230
Dear Mr. O'Neal:
ALT.R?FA
14
IDEHNR
September 11, 199A5
Subject: Speculative Discharge Limits
NPDES Permit No. NCO024210
City of High Point - Eastside WWTP
Guilford County
Reference is made to the requests submitted by James Cramer of Hazen and Sawyer
and Nickie Mills and Randy McNeill of Davis - Martin - Powell & Associates for
speculative limits for the potential expansion of the High Point - Eastside Wastewater
Treatment Plant from 16 MGD to 24 or 26 MGD. The Division of Environmental
Management (DEM) is hereby supplying limits that would presently be applied to the
discharge at its current location in Richland Creek with and without consideration of the
proposed Randleman Lake reservoir, as requested.
At the point of High Point's discharge Richland Creek is a small urban stream with a
7Q10 flow of 1.0 cfs. At 24 MGD, the Eastside WWTP discharge would constitute an
instream waste concentration of 97% during 7Q10 flow conditions (98% at 26 MGD). In
addition, DEM ambient stream monitoring stations located below the outfall have detected
summer occurrences of dissolved oxygen levels below the state standard of 5.0 mg/l. The
Division's modeling efforts have indicated that the discharge will have to meet advanced
tertiary treatment limits in order to adequately protect the receiving stream. For wasteflows
of 24 or 26 MGD, the Eastside WWTP would be required to meet the following limits for
conventional pollutants:
Parameter
Units
Limits (monthly avg.)
BOD5 (Sum/Win)
mg/1
5110
NH3N (Sum/Win)
mg/1
2/4
DO (minimum)
mg/1
6.0
TS S
mg/1
30
pH
SU
6.0-9.0
Fecal Coliform
/100 nil
200
Total Phosphorus
mg/1
1.0
Total Nitrogen
mg/1
6.0
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

_ - Mr. Linwood E. O'Neal, P.E.
City of High Point - Eastside WW'I'P
September 15,1995
Page 2
The following limits for individual toxicants would also be applied to the discharge:
Units
Limits (daily max.)
Cyanide
119/1
5.0
Cadmium
u9/1
2.0
Chromium
119/1
50
Lead
ug/l
25
Nickel
ug/1
88 / 25*
Mercury
u9/1
0.012
Fluoride
m9/1
1.8
Phenols
u9/1
1.0*
*Limit to be applied if Randleman Lake is constructed
In addition to the toxicant limits given above, the facility would be required to monitor
Copper, Zinc and Silver. It should be noted that the toxicant limits and monitoring
provided herein are based on current pretreatment information and effluent data. Increased
pretreatment demands from new industrial users or updated information may cause
additional toxicant limits or may cause limits to be eliminated from future NPDES permits
as deemed appropriate. The discharge will also be required to meet a whole effluent
toxicity test limit. The test will be a Chronic (_C&n�hnia), to be performed quarterly
with a pass/fail limit at a test concentration of 90% for wasteflows of either 24 or 26 MGD.
Under current DEM procedure, dechlorination and chlorine limits are now required for
all new or expanding dischargers proposing the use of chlorine for disinfection. The level
of residual chlorine in your effluent necessary to ensure against chronic toxicity in Richland
Creek is 17 ug/1(daily maximum limit). 'The process of chlorination/dechlorination or an
alternate form of disinfection, such as ultraviolet radiation, should allow the facility to
comply with the total residual chlorine limits.
Recent studies by DEMO conducted in preparation for the Cape Fear River Basinwide
Management Plan, have indicated that water quality in the upper Deep River is adversely
impacted by excess loading of nutrients from point sources. At Coltranes Mill,
downstream from High Point's Eastside WWTP, high concentrations of nutrients occur at
low flows when nonpoint source input is minimal, indicating water quality in this reach is
strongly influenced by point sources. The nutrient loading has lead to persistent and re-
occurring algae blooms in various areas of the river. These eutrophic conditions are
aggravated by the numerous impoundments restricting the river's flow. Our studies have
indicated that the High Point - Eastside WWTP contributes more phosphorus to the Deep
River than all other discharges combined. Upon expansion, the Eastside WWTP will be
required to meet a year round monthly average limit for total phosphorus of 1.0 mg/l. In
addition, studies have shown that reductions in point source loading of nitrogen would
further DEM's efforts to reduce the incidence of water quality violations in the Deep River.
Therefore, the expanded facility will also be required to meet a monthly average limit for
total nitrogen of 6.0 mg/1 during the months of April through October.
Please be advised that response to this request does not guarantee that the Division will
issue an expansion of an NPDES permit to discharge treated wastewater into these
receiving waters. It should be noted that any facility expansion of 0.5 MGD or greater
involving an expenditure of public funds or use of public lands will require the preparation
of an environmental assessment (EA) -by the applicant. DEM will not accept a permit

Jr
Mr. Linwood E. O'Neal, P.E.
City of High Point - Eastside WWI?
September 15,1995
Page 3
application for a project requiring an EA until the document has been approved by the
Department of Environment, Health and Natural Resources and a Finding of No Significant
Impact (FONSI) has been sent to the state Clearinghouse for review and comment. The EA
should contain a clear justification for the proposed facility and an analysis of potential
alternatives which should include a thorough evaluation of non -discharge alternatives. In
addition, an EA should show how water reuse, conservation and inflow/infiltration
reductions have been considered. Nondischarge alternatives, such as spray irrigation,
water conservation or inflow and infiltration reduction, are considered to be
environmentally preferable to an expanded surface water discharge. In accordance with the
North Carolina General Statutes, the practicable waste treatment and disposal alternative
with the least adverse impact on the environment is required to be implemented. If the EA
demonstrates that the project may result in a significant adverse affect on the quality of the
environment, an Environmental Impact Statement would be required. Monica Swihart of
the Water Quality Planning Branch can provide further information regarding the
requirements of the N.C. Environmental Policy Act.
In light of the EA/EIS requirements, it should be noted that DEM staff at the Winston-
Salem Regional Office have expressed concerns over the impact of inflow and infiltration
(I&1) on the hydraulic capacity at the Eastside WWI?. DEM strongly urges the City to
aggressively pursue efforts to identify and reduce areas of I&I at the source, rather than
addressing potential peak flows through construction and operational activities at the
treatment plant. Identification and replacement of delapidated sewer lines may prove to be
significantly more advantageous, economically and environmentally, than large increases in
the hydraulic capacity of the treatment plant proper. Any EA or EIS submitted in support
of a flow increase should include an in depth study and review of this concern.
q y, �
Please also note that these are speculative limits and are not binding unless the limits
are part of an issued NPDES permit. All information pertaining to this request has been
sent to our Central Files for storage. When you are ready to request the increase, please
submit a complete application package including fees appropriate for that point in time.
If you have any questions please contact Jason Doll at [phone] ext. 507.
Sincerely
Steve W. Tedder, Chief
Water Quality Section
cc: Randy L. McNeill, P.E. - Davis - Martin - Powell & Associates
Nickie D. Mills, EIT - Davis - 4aortin - Powell & Associates
James A. Cramer, P.E. - Hazen and Sawyer
Don Safrit - Technical Support Branch
David Goodrich - NPDES Permits Group
Winston-Salem Regional Office
Central Files