NC0089630_Speculative Limits_20130628

G
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Acting Director Secretary
June 28, 2013
Mr. Barry Shearin, Chief Engineer
Charlotte Mecklenburg Utilities
5100 Brookshire Blvd.
Charlotte, North Carolina 28216
Subject: Speculative Effluent Limits
Proposed CMU Regional WWTP
Mecklenburg County
Dear Mr. Shearin:
This letter is in response to your request for revised speculative effluent limits for the
proposed Charlotte Mecklenburg Utilities (CMU) Regional WWTP. Speculative limits in
September 2009 included the City of Mount Holly Wastewater Treatment Plant in
partnership with CMU for the proposed CMU Regional WWTP at the wasteflows of 17
MGD and 25 MGD. In January 2010, speculative limits included Mount Holly and Clariant
WWTP in partnership for the proposed CMU Regional Plant at 17 MGD and 25 MGD.
This latest speculative limits request now includes the City of Belmont, the City of Mount Holly,
and Clariant as partners in the CMU Regional WWTP. Limits are requested for wasteflows of
12 MGD and 25 MGD. It should be understood by all entities that these speculative limits are
only applicable if the nutrient allocations from Belmont, Mount Holly, and Clariant are
included in the proposed project. There is no capacity in Lake Wylie for a Charlotte
Mecklenburg Utilities discharge facility on its own, based on the EPA approved 1996 Lake
Wylie nutrient total maximum daily load (TMDL) allocation. In addition, Mount Holly,
Belmont, and Clarialit must all submit formal permit modifications to confirm the transfers of
flow and nutrient loading to the proposed CMU Regional WWTP. Please recognize that
speculative limits may change based on future water quality initiatives, and it is highly
recommended that the applicant verify the speculative limits with the Division's NPDES
Unit prior to any engineering design work.
ReceivingStream. tream. Lake Wylie has a stream classification of WS-IV CA. Waters with this
designation are a source of drinking water supply, culinary or food processing purposes in
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwaterauality.o-m
One
An Equal Opportunity IAffirmative Action Employer NorthCarolina
�atura!!r�

Mr. Barry Shearin
June 28, 2013
Page 2 of 5
addition to the standard uses for waters with a C classification. This segment of the
Catawba River (Lake Wylie) is listed on the North Carolina 2012 Impaired Streams list for
low pH.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are not any Federally Listed threatened or endangered
aquatic species identified within a 5 mile radius of the discharge location. If there are any
identified threatened/endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge might impact such species.
Speculative Limits. The speculative limits were developed based on Division staff
recommendation and consideration of the Lake Wylie TMDL allocation. Based on available
information, speculative effluent limits for the proposed discharge of 12 and 25 MGD to
Lake Wylie are presented in Tables 1 and 2. A complete evaluation of these limits and
monitoring requirements for metals and other toxicants will be addressed upon receipt of a
formal NPDES permit application.
CBOD5/NH3 Limits. The limits for CBOD5 and NH3 are based on best professional
judgment for the protection of instream dissolved oxygen through the assignment of tertiary
treatment limits. The CBOD limits of 4.2 mg/ L in the summer and 8.3 mg/ L in the winter
are effectively equivalent to BOD5 limits of 5 mg/L (summer) and 10 mg/L (winter). The
year-round NH3 limit of 1 mg/ L is assigned based on instream protection against ammonia
toxicity.
Dissolved ONy en. The dissolved oxygen (D.O.) effluent limit of 7 mg/L was based on the
minimum D.O. level used as model input to predict acceptable downstream D.O. levels.
Nutrients. The nutrient loading for the three partner dischargers was combined to
determine the total nutrient allocation for the proposed CMU Regional WWTP. The entire
allocation for Mount Holly and Belmont will be included in the Regional facility. While the
Clariant facility has a total nitrogen (IN allocation of 318.5 lb/ day, only 90 % or 287 lb/ day
will be allocated to the CMU Regional WWTP. The same percentage of total phosphorus
(TP) will be allocated; therefore 36 lb/ day of total phosphorus of 40 lb/ day will be allocated.
The nutrient limitations are consistent with the Lake Wylie nutrient TMDL allocations and
the contributed nutrient allocation for the three dischargers is below :
Discharger
TN Allocation
TP Allocation
Basis
Mount Holly
300 lb/ day
50 lb/ day
TMDL
Belmont
350 lb/ day
58 lb/ day
TMDL
Clariant
287 lb/ day
36 lb/ day
TMDL,
(Nonpoint) BAT
Total
937 lb/day
144 lb/day
200,518 lb/summer
52,560 lb/year
141,487 lb/winter

Mr. Barry Shearin
June 28, 2013
Page 3 of 5
TABLE 1. Speculative Limits for CMU Regional WWTP, Proposed flow of 12.0 MGD
Effluent Characteristic
Effluent
Limitations
Monthly.
Average
'Weekly
Averagee
Daily
Maximum
Flow
12.0 MGD
CBOD5, Summer
4.2 m /L
6.3 m /L
CBOD5, Winter
8.3 m /L
12.5 m /L
TSS
30 m /L
45 m /L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
(minimum)'
7.0 mg/ L
Total Residual Chlorine
17 u / L
Fecal colif orm (geometric
mean
200/ 100 mL
400/ 100 mL
Total Nitrogen (summer)1
200,518 lbs/ summer
Total Nitrogen (winter)1
141,487 lbs/winter
Total Phos horus2
52,560 lbs/ ear
Chronic Toxicity
Pass/ Fail(Quarterly test
90%
1. The total nitrogen limit is equivalent to a 9.4 mg/ L annual average.
2. The total phosphorus limit is equivalent to a 1.4 mg/ L annual average.
TABLE 2. Speculative Limits for CMU Regional WWTP, Proposed flow of 25.0 MGD
Effluent Characteristic
Effluent Limitations
Monthly Average
Weekly
Average
Daily
Maximum
Flow
25.0 MGD
CBOD5, Summer
4.2 mg/ L
6.3 mg/ L
CBOD5, Winter
8.3 m / L
12.5 m / L
TSS
30 m /L
45 m /L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/ L
Total Residual Chlorine
17 u / L
Fecal coliform (geometric
mean)
200/100 mL
400/100 mL
Total Nitrogen (summer)1
200,518 lbs/ summer
Total Nitrogen (winter)1
141,487 lbs/winter
Total Phos horus2
52,560 lbs/ ear
Chronic Toxicity
Pass/ Fail(Quarterly test
90 %
1. The total nitrogen limit is equivalent to a 4.5 mg/ L annual average.
2. The total phosphorus limit is equivalent to a 0.69 mg/L annual average.

Mr. Barry Shearin
June 28, 2013
Page 4 of 5
Monitoring in Lake Wylie will also be required to ensure that the water quality model
predictions were accurate, and to ensure the discharge does not create adverse conditions in
the Lake in the future. CMU will be required to monitor upstream and downstream of the
outfall. The following parameters should be included in sampling: dissolved oxygen,
temperature, conductivity, pH, total phosphorus, total nitrogen and chlorophyll a. Instream
monitoring will be required three times per week during the months of June, July, August
and September and once per week during the rest of the year.
Engineering Alternatives Anal, sis EAA). Please note that the Division cannot guarantee
that an NPDES permit for discharge of up to 25.0 MGD will be issued with these speculative
limits. Final decisions can only be made after the Division receives and evaluates a formal
permit 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 a spray/ drip irrigation or wastewater
reuse are considered to be envitonmentally preferable. A copy of the EAA requirements is
attached to this letter. Permit applications for new or expanding flow will be returned 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 or producing an instream waste concentration of > 33% based on summer 7Q10
streamflow conditions. Since CMU's facility is proposing a discharge of >500,000 gpd flow,
the CMU facility 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 discharge 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 discharge is subject to SEPA, the
EAA requirements discussed above will need to be folded into the SEPA document. The
SEPA process will be delayed if all EAA requirements are not adequately addressed. If you
have any questions regarding SEPA EA/ EIS requirements, please contact Hannah Headrick
with the DWQ Planning Branch at [phone].

Mr. Barry Shearin
June 28, 2013
Page 5 of 5
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact Jackie Nowell at (919) 807- 6386.
Respectfully,
dom. Belnick
Supervisor, Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
Central Files
NPDES Permit File
Barry Gullet, CMUD Director 5100 Brookshire Blvd. Charlotte NC 28216
Brent M. Reuss/ Black & Veatch 8520 Cliff Cameron Drive Suite 210 Charlotte, N.C. 28269
Jeff Debessonet/SCDHEC 2600 Bull Street Columbia, S.C. 29201
Electronic Copy:
NC WRC, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, Sara—[e-mail]
DWQ/SWPS Mooresville Regional Office
DWQ/SEPA, Hannah Headrick
DWQ/Modeling TMDL Unit, Kathy Stecker
DWQ/Basinwide Planning, Jeff Manning
NPDES Server>Specs

Engineering Alternatives Analysis (EAA) Guidance Document
North Carolina Division of Water Quality / NPDES Unit
NOTE: The N.C. Division of Water Quality (DWQ) will not accept an NPDES application for a new or
expanding wastewater treatment plant discharge unless all the required application requirements are
submitted. A complete NPDES application will include the following items:
NPDES Application Form (in triplicate)
Application Fee
Engineering Alternatives Analysis (in triplicate)
Local Government Review Form (non -municipals only)
Failure to submit all of the required information will result in return of the incomplete package. If you have
any questions about these requirements, contact the NPDES Unit staff at 919-807-6300. Application forms,
applicable fees, and guidance documents are available on the NPDES website at
hap://portal.ncdenr.ogg/web/wq/swp/ps/npdes. Completed applications should be mailed to:
NCDENR/DWQ/NPDES Unit,1617 Mail Service Center, Raleigh, NC 27699-1617.
Background
The NPDES permit program was enacted in 1972 as part of the Clean Water Act. The original goal of the program
was to eliminate all point source discharges to surface waters by 1985. Although this goal was not achieved, the
NPDES program continues to strive toward it. In that light, an Engineering Alternatives Analysis (EAA) is
required with any NPDES application for a new or expanding wastewater treatment plant discharge, in
accordance with 15A NCAC 2H.0105(c)(2). In order for an NPDES application to be approved, the E.A.A. must
provide complete justification for a direct discharge to surface water alternative, and demonstrate that direct discharge
is the most environmentally sound alternative selected from all reasonably cost-effective options [per 15A NCAC
2H.0105(c)(2)].
The purpose of this EAA Guidance Document is to provide guidance to the regulated community for the evaluation of
wastewater disposal alternatives. The impetus behind this comprehensive guidance was based on the following. 1) a
majority of new NPDES applications were being returned as incomplete due to inadequate EAA submissions; and 2) a
few recent court cases resulted in unfavorable rulings for the NPDES discharger due in part to inadequate EAAs.
DWQ most frequently returns EAAs as incomplete due to inadequate flow justification, inadequate alternatives
evaluations, and/or lack of documentation/references used to design and cost alternatives.
Please note that this guidance document is designed primarily for domestic wastewater discharges. For other proposed
discharges such as water treatment plant discharges from ion exchange and reverse osmosis units, some alternative
disposal options may not be technologically feasible. Within this guidance document, we have attempted to point out
where such technological limitations may exist. You are urged to review NPDES permitting guidance documents on
the NPDES website, which discuss some of the limited disposal options for some discharges.
Please note that, if a proposed municipal expansion is subject to SEPA Environmental Assessment
(EA)/Environmental Impact Statement (EIS) requirements, the EAA requirements should be incorporated into the
SEPA document. In addition, the NPDES Unit cannot accept an application for a new/expanding NPDES discharge
until departmental review of the SEPA document is complete and a Finding of No Significant Impact (FONSI) has
been submitted to the State Clearinghouse for circulation.
The following step-by-step outline should be used for the preparation of all EAA submissions. If an EAA submission
lacks any of these basic elements, the NPDES application will be returned as incomplete.
EAA Guidance Document Version: June 23, 2005
Page 1 of 8

STEP 1. Determine if the proposed discharge will be allowed
Before beginning any engineering evaluation of alternatives, you must first determine if the proposed wastewater
discharge will be allowed. Otherwise, time and money may be spent needlessly for an EAA preparation that will
ultimately be rejected on the basis of existing water quality restrictions. There are several potential restrictions to a
wastewater discharge to surface waters, including.
■ Zero flow stream restrictions [15A NCAC 2B.0206(d)(2)] apply to oxygen -consuming waste in zero -flow
streams. In order to determine streamflow at the proposed discharge location, contact the U.S.
Geological Survey at 919-571-4000.
■ Receiving stream classification restrictions [e.g., ORW, WS, SA, NSW, and HQ class waters have various
discharge restrictions or require stricter treatment standards]. Stream classifications are available on the
DWQ website and from the DWQ Standards & Classifications Unit at 919-807-6300, while wastewater
discharge restrictions for various stream classifications are presented in state regulations [ 15A NCAC
2B.0200].
■ Basinwide Water Quality Plans. These basin -specific plans list NPDES permitting strategies that may
limit wastewater discharges to particular streams within the basin due to lack of stream assimilative
capacity, etc. Basin plans are available on the DWQ website, or you may contact the DWQ Basinwide
Planning Unit at 919-807-6300.
■ Impaired waters and TMDLs. Certain waterbodies listed as impaired on the 303(d) list and/or subject to
impending TMDLs may have wastewater discharge restrictions. The list of 303(d) impaired waters is
located on the DWQ website, or you may contact the DWQ Modeling/TMDL Unit at 919-807-6300.
■ Presence of Endangered Species. If endangered species are present in the proposed discharge location,
there may be wastewater discharge restrictions. Endangered species information may be included in the
Basinwide Water Quality Plan, or you may contact the U.S. Fish and Wildlife Service (919-856-4520),
N.C. Wildlife Resources Commission (919-733-3633), or the N.C. Natural Heritage Program (919-733-
7701).
Municipal aMlicants.
As a public service, the NPDES Unit will evaluate whether a proposed municipal discharge is considered allowable.
The municipality needs to initiate this review by submitting a letter request for Speculative Effluent Limits to the
NPDES Unit. If the proposed discharge appears to be allowable, the NPDES Unit will prepare speculative effluent
limits for a maximum of 2 flows and 2 discharge locations using water quality models. The municipality can then use
the speculative limits to prepare preliminary engineering design and cost estimates for the direct discharge alternative
within the FAA. In limited instances where complex water quality models are necessary to develop speculative limits
and determine potential water quality impacts, some municipalities have undertaken the modeling effort (with DWQ
review) in order to expedite this portion of the NPDES permit review process.
Non -municipal aRtih� ts.
Due to staff constraints, the NPDES Unit cannot prepare speculative limits for non -municipal applicants. Thus, it is
your responsibility to make your own determination as to whether the proposed discharge n4lit be allowed by the
Division, by evaluating the water quality factors listed above. It is highly recommended that you discuss the proposed
discharge with the applicable DWQ Regional Office and/or NPDES Unit staff, who may be able to provide input on
the likelihood of a new/expanding discharge. As a first step, you must obtain streamflow estimates for the proposed
discharge location to ensure that the receiving stream is not subject to zero flow restrictions. Low flow data
(specifically, the summer 7Q10 and 30Q2 flow statistics) can be obtained for a nominal fee from the U.S. Geological
Survey in Raleigh at 919-571-4000. The low flow data must be submitted with the EAA, and will be used by the permit
writer to develop permit limits. .You must also verify that the proposed action (i.e., construction of a wastewater
treatment plant and its appurtenances) is consistent with local zoning and/or subdivision ordinances. You will need to
request the local government(s) to complete a Local Government Review Form (Attachment A), and include the
signed and notarized form with your NPDES application package.
EAA Guidance Document Version: June 23, 2005
Page 2 of 8

All a�bhr cants. -
If you conclude that the proposed discharge will pass the "allowable discharge" criteria, then begin the EAA
preparation by summarizing the following general information about the proposed project:
■ Provide a description of the proposed project. If the project will be constructed in phases, provide a
schedule for constructing each additional phase, and provide the projected flow per phase (see STEP 2).
■ Applicant name, mailing address, phone number, contact person
■ Facility name, address, county, phone number, contact person
■ EAA preparer's name, mailing address, phone number, contact person -
STEP 2. Provide reasonable projections for population and flow
Residential Pol2ulation Projections.
Facilities requesting an NPDES discharge permit for new or expanding domestic wastewater discharges must
document the population to be served within the service area over a 20-year planning period. The NC State
Demographics unit provides population data for each county and municipality and can be accessed on the Internet at
http://www.demog.state.nc.us. If 20-year population projections for specific areas are not available, a linear
extrapolation of population trends from the past decade should be used. Any deviation from a linear projection
method must be clearly justified. I£ population projections include future annexations, include a proposed annexation
schedule as well as any annexation requirements that must be met.
Municipal Flow Projections.
Justification of flow as well as a demonstration of need shall be provided. Mere speculation is not sufficient. Flow
projections should represent average anticipated flows, since permit flow limits are based on monthly averages.
Peaking factors used to design various components of the wastewater collection system (e.g., collector sewers,
interceptor sewers, pumping stations) should not be used in the justification of the average anticipated flow. For
municipal wastewater dischargers, flow must be justified using the Clean Water State Revolving Fund (CWSRF)
criteria available on the Internet at htM://www.nccgl.net/fap/cwsrf/. Exceptions to these flow criteria may be
approved on a case -by -case basis provided adequate justification is supplied.
■ Current Flow- Provide current flows including residential, commercial, industrial, and non -excessive
infiltration/inflow (I/I) based on actual flow data or water billing records. Current residential flow and
current commercial flow may be based on water billing records minus a 10% consumptive loss. Current
industrial flow may be based on dual metering to determine consumptive losses. Current non -excessive
I/I should also be determined in accordance with CWSRF criteria. If I/I is demonstrated to be above
CWSRF criteria, that infrastructure contributing to excessive I&I must either be repaired or replaced
prior to any request for flow expansion.
■ Future Residential Flow- Provide 20-year residential flows based on projected residential growth.
Multiply the projected growth in residential population by 70 gallons per day per capita.
■ Future Commercial Flow Provide 20-pear commercial flows based on projected residential growth.
Multiply the projected growth in residential population by 15 gallons per day per capita.
■ Future Industrial Flow Provide flow for future documented industrial flow. A nominal allowance for
future unplanned industrial expansions may be considered by the Division, provided the basis is clearly
justified and current land -use plans and local zoning allow for such industrial growth.
■ Future Non -excessive I/I- A nominal allowance for non -excessive I/I for new sewer lines may be
considered by the Division, provided the basis is clearly justified.
Non -Municipal Flow Projections.
Flow may be justified in accordance with 15A NCAC 2H .0219(1) for various activities (e.g., new subdivisions, new
schools, various commercial activities). For other proposed discharges (e.g., groundwater remediation, water
EAA Guidance Document Version: June 23, 2005
Page 3of8

treatment plant filter backwash, industrial facilities), the flow projections will be based on engineering design
considerations and/or production projections rather than population projections.
STEP 3. Evaluate technologically feasible alternatives
Since a goal of the Clean Water Act is to minimize or eliminate point source discharges to surface waters, any
proposal for a new or expanding wastewater discharge must include evaluation of wastewater disposal alternatives in
addition to direct discharge. Particularly for dischargers of domestic wastewater, this evaluation should investigate the
feasibility of the following wastewater disposal alternatives:
■ Connection to an existing wastewater treatment plant (public or private)
■ Land application alternatives, such as individual/community onsite subsurface systems, drip irrigation,
spray irrigation
■ Wastewater reuse
■ Surface water discharge through the NPDES program
■ Combinations of the above
In order for the applicant to eliminate a wastewater disposal alternative, you must either show that the alternative is
technologically infeasible, or that it would be cost prohibitive to implement relative to a direct discharge alternative.
Please note that for some alternatives, it might be easier to prove an alternative is not viable based on high cost rather
than technological feasibility. For example, for a large municipal expansion that would require several hundred acres
for a land application alternative, it might be easier to simply assume that the required acreage could be purchased and
calculate the present value costs (including current market land costs) for this option, rather than evaluating whether
land application is technologically infeasible due to lack of available land and/or poor soil conditions. For those
alternatives identified as technologically feasible, you must develop and compare costs, based on a preliminary level
design effort (see STEP 4).
The Division recognizes that wastewater disposal alternatives may be limited for some non -domestic wastewater
scenarios, and a full alternatives evaluation may not be warranted. If there is some question as to whether an alternative
may be eliminated, contact the NPDES Unit staff. Some scenarios that might not require a full alternatives evaluation
include:
Water Treatment Plant Discharges. Discharges from water treatment plants (WTPs) that utilize a
membrane technology (e.g., reverse osmosis, nanofiltration) or ion exchange system tend to generate
highly concentrated wastestreams. These wastestreams are not amenable to land application and do not
have to be evaluated for this alternative. However, since these wastestreams can also have a toxic impact
on a receiving freshwater system, proposed new discharges from these WTPs to freshwaters will not be
considered for an NPDES permit unless you can demonstrate that the environmental impacts would be
niininial based on dilution modeling. You should investigate whether the wastewater can be piped to a
stream with sufficient dilution, or whether a local WWTP might accommodate this discharge. Please
note that discharges from WI'Ps that utilize greensand filtration or conventional technology produce a
wastestream that is not saline, therefore no disposal alternatives can be automatically ruled out as
infeasible for these other WIPs. Refer to the NPDES website for permitting strategies for reverse
osmosis, ion exchange, greensand filtration, and conventional WTPs.
Groundwater Remediation System Discharges. You will need to evaluate whether WWTP connection,
land application, infiltration galleries, in -situ groundwater remediation wells, or closed -loop groundwater
remediation wells are viable disposal alternatives. While land application might be a feasible alternative in
rural areas, it would not be a feasible alternative in downtown Charlotte, where there is no land available
for wastewater application. In this instance, you may simply state that land application is infeasible based
on land constraints within the city. You will also need to evaluate connection to an existing WWTP (in
accordance with Alternative A), since there are some municipalities that have accepted this wastestream
EAA Guidance Document Version: June 23, 2005
Page 4 of 8

in the past. If the municipality will not accept the wastestream, the connection alternative is also
considered technologically infeasible. Please note that in -situ and closed -loop groundwater remediation
wells are permittable well types and further guidance is available through the Aquifer Protection Section.
Aside from these exceptions, you should proceed with the alternatives evaluation in accordance with the following
requirements. If you have any questions about these requirements, contact the NPDES Unit staff.
Alternative A. Connection to an Existing Wastewater Treatment System.
You must evaluate the feasibility of connecting to an existing wastewater treatment system served by a municipality or
other entity holding a valid NPDES or Non -Discharge Permit. All connection options should include an evaluation
of a gravity line and/or force main with pump station(s).
1. Existing Sewerage System:
(a) Identify whether there are existing sewer lines within a five -mile radius, or consider a greater radius if
cost effective for the project size.
(b) Provide a preliminary indication of flow acceptance from existing municipal or private VIWTPs
under consideration for connection. If a municipal or private WWTP cannot accept the wastewater,
include a letter documenting such and consider this alternative technologically infeasible.
(c) If an existing sewerage system will accept the wastewater, evaluate the piping/pumps/resources
necessary to connect to the existing wastewater treatment plant. Attach a topographic map or a site
drawing showing the physical route of this alternative. Conduct a Present Value Cost Analysis per
STEP 4.
2. Planned Sewerage System Determine if a regional sewerage system within a five mile radius is projected
to be available within the next five years to receive waste from the project site. If applicable, determine
availability date and flow acceptance projection from appropriate authority.
Alternative B. Land Application.
Land application disposal alternatives include individual/community onsite subsurface systems, drip irrigation, and
spray irrigation.
1. Provide an estimate of the best case hydraulic loading rate based on County Soil Surveys or from a soil
evaluation performed by a soil scientist. Include calculations showing the hydraulic loading rate
and the total area of land needed for the land disposal system, including buffers.
2. Assess the availability of land. If insufficient land is available onsite, assume that the necessary land can
be purchased and estimate the land purchase cost based on local real estate prices. Alternatively, provide
documentation to demonstrate that insufficient land is available for sale in the project area (include
letters from adjacent property owners indicating no interest in selling property).
3. Provide a description of the wastewater treatment system and the non -discharge application system.
Include a site plan showing the proposed layout, the application area, any existing structures, proposed
structures, and other uses within the site.
4. Explain the proposed reuse plan if reclaimed water will be used by a third party.
5. Conduct a Present Value Cost Analysis per STEP 4. For the reclaimed water system include the
potential revenue generated by selling the water.
6. Provide all calculations, documentation and maps as necessary to support assumptions and conclusions.
7. Note: The design of land application systems must meet the treatment and design requirements specified
in 15A NCAC 2H.0219 or 15A NCAC 18A.1900.
8. Note: Proposed discharges from groundwater remediation systems must evaluate the potential for an
infiltration gallery treatment alternative.
Alternative C. Wastewater Reuse.
You must evaluate reusing all or a portion of the wastewater generated. Some municipalities are currently reusing
wastewater within the confines of their W TP property for irrigation, toilet flushing, backwashing, etc., while other
municipalities have established progressive reuse programs for residential irrigation. Reuse applications might include
golf course irrigation, crop irrigation (e.g., hardwood or pine plantation, grasses), athletic field irrigation, landscape
uses, and commercial/industrial uses. Some of these reuse applications will be evaluated under Alternative B, Land
EAA Guidance Document Version: June 23, 2005
Page 5 of 8

Application. The design of reclaimed water systems must meet the treatment and design requirements specified in
15A NCAC 2H.0219.
.Alternative D. Direct Discharge to Surface Waters.
1. No new or expanding (additional) discharge of oxygen -consuming waste will be allowed to surface waters
of North Carolina if both the summer 7Q10 and 30Q2 streamflows are estimated to be zero, in
accordance with 15A NCAC 2B.0206(d). Private applicants must contact the Federal USGS in Raleigh at
919-571-4000 and obtain (generally for a nominal fee), the receiving streamflow data (s7Q10, 30Q2,
annual average streamflow) at the proposed discharge location. This information must be included in the
EAA, and will be used to develop permit limits.
2. All direct discharge systems of oxygen -consuming wastes should be evaluated both with tertiary filtration
[BODS= 5 mg/1, NH3-N= 1 mg/]] and without, and assuming a weekly sampling regime.
3. Provide a description of the proposed wastewater treatment facilities, including a schematic diagram of
the major components and a site plan of the treatment facility with outfall line(s).
4. Provide documentation of the availability of required land and/or easement agreements.
5. Conduct a Present Value Cost Analysis per STEP 4.
6. Note: All direct discharge treatment systems must comply with Reliability Requirements specified in 15A
NCAC 2H.0124 as well as Minimum Design Requirements specified in 15A NCAC 2H.0219.
Alternative E. Combination of Alternatives.
You should evaluate the possibility of a combination of wastewater alternatives that would minimize or eliminate a
direct discharge alternative. For example, consider whether the facility can operate a land application system during
the dry season when streamflows are at their lowest and provide less dilution, and operate an NPDES discharge
system during the wet season when soils may not be as amenable to land application and the receiving stream
provides its greatest dilution.
STEP 4. Evaluate economic feasibility of alternatives
To provide valid cost comparisons among all technologically feasible wastewater alternatives identified in STEP 3, a 20-
year Present Value of Costs Analysis (PVCA) must be performed. A preliminary design level effort is considered
appropriate for comparing feasible options and their associated costs. For the PVCA cost comparison, all future
expenditures are converted to a present value cost at the beginning of the 20-year planning period. A discount rate is
used in the analysis and represents the time value of money (the ability of money to earn interest). Present value is also
referred to as "present discounted value" or "present worth".
The PVCA should include all monetary costs associated with construction, startup and annual operation and
maintenance of a facility. All unit cost information must be provided, and costs must be referenced. Costs can be
referenced in paragraph format by summarizing the sources utilized (e.g., vendor quotes, realtor land quotes, past
bids, Means Construction Index, etc). Vender quotes received for treatment units or other components, as well as
realtor land quotes, shall be included as well. For each treatment alternative identified as technologically feasible,
costs should include, but not be limited to, the following:
Capital Costs
■ Land acquisition costs
■ Equipment costs
■ Labor costs
■ Installation costs
■ Design costs
EAA Guidance Document Version: June 23, 2005
Page 6 of 8

Recurring Costs
■ Operation and maintenance costs (with replacement costs)
■ Laboratory costs assuming a weekly monitoring regime for discharge systems and a monthly regime for
non -discharge systems
■ Operator and support staff costs
■ Residual disposal costs
■ Connection fees and subsequent user fees
■ Permit and compliance fees
■ Utility costs (power, water, etc.)
Lost Ounce nity Costs
PVCA Calculation Method.
The following standard formula for computing the present value must be used in all cost estimates made under this
evaluation:
Where:
" C
PV= C +�
+ r}`
PV = Present value of costs.
Co = Costs incurred in the present year.
Ct = Costs incurred in time t.
t = Time period after the present year (The present year is t = 0)
n = Ending year of the life of the facility.
r = Current EPA discount rate. EPA adjusts this rate annually on October 1, and it can be accessed from
the Internet at http:/www.nccgl.net/fap/cwsrf/201gui.html.
If recurring costs are the same in years 1 through 20, then Ct=C and the formula reduces to:
PV= C° + (1.+ r)" —1]
r(1 + r)" I
As an example, assuming capital costs (Co) of $2 million, annual recurring costs (C) of $40,000, and a discount rate (r)
of 5.625%, the 20-year (n=20) present value of costs would equal:
PV= capital costs + recurring costs X
PV= $2,000,000 + $40,000 X
PV= $231000,000 + $471,425
PV= $2,471,428
[(1+0.05625)20 —1] / [0.05625(1+0.05625)20]
[1.98/0.168]
PVCA Summary„ Table:
The EAA must include a Summary Cost Table, which summarizes present worth costs developed for all technologically
feasible wastewater alternatives. The summary should include a breakdown of capital costs and recurring costs. In
some situations, the Division may require the applicant to refine cost estimates for some alternatives, or possibly collect
actual soil data to better characterize the land application alternative. Ultimately, the final determination on cost
effectiveness is made by the Division with consideration of monetary costs as well as potential environmental impacts.
EAA Guidance Document Version: June 23, 2005
Page 7 of 8

Attachment A. Local. Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
■ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
■ If either (or both) local government(s) fails) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
■ As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the
15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government
(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [ ] No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ] No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [ ]
No [ ]
Date
State of , County of
Signature
(City Manager/County Manager)
On this day of personally appeared before me, the said
name to me known and known to me to be the person described in
and who executed the foregoing document and he (or she) acknowledged that he (or she) executed the same and being duly sworn
by me, made oath that the statements in the foregoing document are true.
My Commission expires .(Signature of Notary Public)
Notary Public (Official Seal)
EAA Guidance Document Version: June 23, 2005
Page 8of8

/� - Jcrc�C�
CHARATTE...
March 12, 2013
Mr. Tom Belnick
DENR/Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Request for Speculative Limits for Proposed Long Creek Regional W WTP
Dear Tom:
Charlotte Mecklenburg Utilities is requesting revised speculative limits for the proposed Long Creek
Regional WWTP based on the new partnerships within the basin. Previous speculative limits have
been based on the regional treatment plant partners of Charlotte, Mt. Holly, and Clariant.
As discussed in our meetings with NCDWQ over the past several months, we now have approvals in
place for the partnership to include Belmont in addition to Mt Holly and Clariant.
Therefore, we are requesting a revision to our December 2009 request (copy attached) to include the
nitrogen and phosphorus allocations for the City of Belmont in addition to the Clariant and Mt Holly
allocations. As with Clariant and Mt Holly, the intent is that Belmont would eliminate their discharge
to Lake Wylie and pump their wastewater to CMUD for treatment upon transfer of the nutrient
allocation to the future Long Creek Regional W WTP NPDES permit.
Please let us know if you have any questions or need any additional information and we look forward
to receiving your response.
If you need any additional information please feel free to give me a call at 704-391-5137.
Sincerely,
FVW�_'�
Barry Shearin, PEChief
Engineer
Cc: Brent Reuss, Black and Veatch
Barry Gullet, CMUD Director
CHARLOTTE-MECKLENBURG UTILITIES
Administration Division 5100 Brookshire Boulevard
Charlotte, NO 28216
PH: 704/399-2221
FAX: [phone]

December I4, 2009 C c ,
Mr. Tom Belnick
DENR/Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Request for Speculative Limits
Proposed Long Creek Regional W WTP
Mecklenburg County
Dear Tom,
Thanks for talking with us last Friday about this project. Based on that conversation, we
request your Division to issue revised speculative limits for the proposed Charlotte -Mount
Holly-Clariant Regional WWTP at Long Creek in Mecklenburg County.
Please recall your September 21, 2009, letter that provided speculative limits based on a
partnership between Charlotte and Mount Holly. As we discussed, the existing Clariant
WWTP's discharge to Lake Wylie is also planned to be eliminated through incorporation into
the proposed regional plant. Clariant's NPDES permit allows them to discharge 401bs/day of
total phosphorus and 318.5 lbs/day of total nitrogen measured as a 12-month rolling average.
We request the September 21 speculative limits be revised to reflect the elimination of
Clariant's NPDES discharge and the inclusion of Clariant's permitted nutrient loading in the
proposed regional plant's waste load allocation.
We understand that the speculative limits will be issued contingent upon the elimination of
Mount Holly's and Clariant's NPDES discharges. We expect to submit an Environmental
Impact Statement including a detailed engineering alternatives analysis very soon after
receiving speculative limits.
Please let us know if you have any questions and we look forward to receiving your response.
Sincerely,
tBa1d,.E
Deputy Director
Cc: Eric Davis, Mount Holly City Manager
Chris Barnard, Clariant
Brent Reuss, Black & Veatch
File
CHARLOTTE-MECKLENBURG UTILITIES
Administration Division 5100 Brookshire Boulevard
Charlotte, NC 28216
PH: 704/399-2221
FAX: [phone]

Clariant
Mt. Holly
Belmont
Exist. TN limit (lb/day)
318.5
300
350
90%TN transferred
287
-
-
amt transferred
223
64
Trans Lb/summer
61705
47945
13760 61705
CMU calculation
104755
89357
15398 104755
New TN allocation
31.5
523
414
Ibs/summer
6772.5
112445
89010
Clariant
Mt. Holly
Belmont
Exist. TP limit (lb/day)
40
50
58
90%TN transferred
36
-
-
amt transferred
36
-
Trans Lb/summer
13140
13140
New TP allocation
4
86
58
Ibs/year
1460
31390
21170
-43050

Nowell, Jackie
From: Jarrell, Jackie [JJarrel I @ci. charlotte. n c. us]
Sent: Wednesday, May 22, 2013 9:49 AM
To: Shearin, Barry
Cc: Nowell, Jackie
Subject: Re: Spec Limit Letter
Hi Jackie! How are you? Yes, CBOD, like our other permits. Let me know if you need anything else. Jackie
Jacqueline A. Jarrell, P.E. Supt.
Environmental Management Division
Charlotte Mecklenburg Utility Department
P: 704/336-4460
M: 704/634-5430
j j arrellQ,ci.charlotte.nc.us
On May 22, 2013, at 9:31 AM, "Shearin, Barry" <bshearin e,ci.charlotte.nc.us> wrote:
Jackie J., Jackie Nowell is working on the spec limit letter for the Long Creek WWTP
plant. She was asking me if we preferred to the have the BOD limit expressed as BOD or
CBOD?? I was thinking I had heard you all talk about CBOD but I wasn't sure.
Can you answer that question for Jackie?? Thanks.
Barry Shearin
Chief Engineer
Charlotte - Mecklenburg Utilities
704-391-5137

e
Ter i� d�r�'� 1� � �S N�.� J � ' 1,g • 1 � ����
Mr. Barry Shearin
June xx, 2013
Page 2 of 5
This segment of the Catawba River (Lake Wylie) is listed on the North Carolina 2012
Impaired Streams list for low pH.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are not any Federally Listed threatened or endangered
aquatic species identified within a 5 mile radius of the discharge location. If there are any
identified threatened/ endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge might impact such species.
Speculative Limits. The speculative limits were developed based on Division staff
recommendation and consideration of the Lake Wylie TMDL allocation. Based on available
information, speculative effluent limits for the proposed discharge of 12 and 25 MGD to
Lake Wylie are presented in Tables 1 and 2. A complete evaluation of these limits and
monitoring requirements for metals and other toxicants will be addressed upon receipt of a
formal NPDES permit application.
Nutrients. The nutrient loading for the three dischargers included in the CMU Regional
WWTP was combined to determine the total nutrient allocation for the proposed discharger.
The entire allocation for Mount Holly and Belmont will be included in the Regional facility.
While the Clariant facility has a total nitrogen allocation of 318.5 lb/day, only 90 % or 287
lb/day will be allocated to the CMU Regional WWTP. The same percentage of total
phosphorus will be allocated; therefore 36 lb/day of total phosphorus of 401b/day will be
allocated. The nutrient limitations are consistent with the Lake Wylie nutrient TMDL
allocations and the contributed nutrient allocation for the three dischargers is below:
c
Discharger
Total Nitrogen
Allocation
Total Phosphorus
Allocation
s'
Mount Holly
300 IN day {I89�00--
501b/ day k--
TMDL
Belmont
3501b/ day112..FF50=
58 lb/ day4M7M—
TMDL
Clariant
287 lb/ day
36 lb/ day-#a714-9---
TMDL,
Nonpoint
Total
937 lb/day
144 lb/day fA;568—
C�)

Mr. Barry Shearin
June xx, 2013
Page 3 of 5
TABLE 1. Speculative Limits for CAW Regional W WTP, Proposed flows of 12.0 MGD
Effluent Characteristic
Effluent Limitations
Monthly Average
Weekly
Average
Daily
Maximum
Flow
12.0 MGD
CBOD5, Summer
3.3 mg/1
5.0 mg/1
CBOD5, Winter
6.6 m /l
10.0 m /l
TSS
30 m /L
45 m /L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/L
TRC
17u /1
Fecal coliform (geometric
mean
200/100 ml
400/100 ml//
U -1 l ��
Total Nitrogen
42 0 ear a ent to 9.3 m /1 annual average
Total Phosphorus
52,5601bs/ ear (e4uivalent to 1.4 m / 1 annual avera e
Chronic Toxicity
Pass/Fail(Quarterly test
TABLE 2. Speculative Limits for CMU Regional WWTP, Proposed flows of 25.0 MGD
Effluent Characteristic
Effluent Limitations
Monthly Average
Weekly
Average
Daily
Maximum
Flow
25.0 MGD
CBOD5, Summer
3.3 mg/1
5.0 m /l
CBOD5, Winter
6.6 mg/1
10.0 m /l
TSS
30 m /L
45 m /L
NH3asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/L
TRC
17 u /l
Fecal coliform (geometric
mean
200/100 ml
400/100 ml
-
Total Nitrogen
342,005 lbs/ ear (equivalent to 4.49 mg/1 annual average)
Total Phosphorus
52,5601bs/ ear (equivalent to 0.69 m /l annual average)
Chronic Toxicity
Pass/Fail(Quarterly test
90%
Monitoring in Lake Wylie will also be required to ensure that the water quality model
predictions were accurate, and to ensure the discharge does not create adverse conditions in
the Lake in the future. CMU will be required to monitor upstream and downstream of the
outfall. The following parameters should be included in sampling: dissolved oxygen,
IM

North Carolina Depa
Pat McCrory
Governor
Mr. BarYNau
ef Engineer
Charlog Utilities
5100 Br
Charloina 28216
Dear
x1/ Aq, /HiAl
NCDENR
iron t and Natural Resources
ivision of Wat �uali
Charles Wakild, P. E. John E. Skvarla, III
Director Secretary
May 29, 2013
'5 � a _Gov A� love
Subject: Speculative Effluent Limits
Proposed Long Creek Regional WWTP
Mecklenburg County
This letter-ie response t your req est for revised speculative effluent limits for the
proposed Charlotte Meckle urg Utilitie (CMU) Long Creek Regional WWTP. Speculative
limits in September 2009 in 1 ded the ty of Mount Holly Wastewater Treatment Plant in
partnership with CMU for roposed a ong Creek WWTP at the wasteflows of 17 MGD
and 25 MGD. In January 2010, specul limits included Mount Holly and
Clariant WWTP in partnership for the proposed Long Cree Regional Plant at 17 MGD and
25 MGD. The Clariant facility would be going offline and connecting to the regional plant.
Thy lanes)-_ r MIVWXV 11o44 byspeculative limits include the Ci f Belmont, along with the City of
Mount Holly and Clariant as partners in the Long C ek Regional WWTP. The requested
wasteflows are 12 MGD and 25 MGD. It shoul a understood by all entities that these
speculative limits are only applicable if the rom the City of Mount Holly is
included in the proposed project. There is no capacity in Lake Wylie for a Charlotte
Mecklenburg Utilities discharge facility on its own, based on the EPA approved 1996 Lake
Wy ' MDL allocation. In addition, Mount Holly, Belmont and Clariant must all submit
�y�11 rm permit modifications to confirm the transfers of flow and nutrient loading to the
proposed Long Creek Regional WWTP. Please recognize that speculative limits may change
based on future water quality initiatives, and it is highly recommended that the applicant verify
the speculative limits with the Divisions NPDES Unit prior to any engineering design work.
Receiving So tream. Lake Wylie has a stream classification of WS-IV CA. Waters with this
designation are a source of drinking water supply, culinary or food processing purposes in
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwaterouality.ora One
An Equal Opportunity 1 Affirmative Action Employer N&thCarolina
AMWAY

Mr. Barry Shearin
May 29, 2
Page 2 of 5
Wow fVall e
addition to th�sl:an�,dard�use�sfor waters with �aC classification. It islofthe
nated as acritical areaear lacen water supp y intavoir where
risk associated with pollution is greater than from the remaining portiatershed.North Carolina regulation 15A NCAC 2B .0202 (20) provides a more tfinition of C�critical area. In addition, it is recommended that 15A NCAC 2B.0216 aewed in itsentirety for the water quality standards that are applicable to WS-IV CA
This segment of the' Catawba River (Lake Wylie) is listed on the North Carolina 2012
Impaired Streams list for low pH.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are not any Federally Listed threatened or endangered
aquatic species identified within a 5 mile radius of the discharge location. If there are any
identified threatened/ endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge might impact such species.
Speculative Limits. The speculative limits were developed based on Division staff
recommendation and consideration of the Lake Wylie TMDL allocation. Based on available
information, speculative effluent limits for the proposed discharge of 12 and 25 MGD to
Lake Wylie are presented in Tables 1 and 2. A complete evaluation of these limits and
TV monitoring requirements for metals and other toxicants will be
addressed upon receipt of a formal NPDES permit a plication.
Nutrients. The nutrient loading the three dischargers included in the Long Creek
WWTP was combined to deter . e the total nutrient allocation for the proposed discharger.
The entire allocation for M t Holly and Belmont will be included in the Long Creek
facility. While the Clarianyracility has a total nitrogen allocation of 318.5 lb/ day, only 90 %
or 287 lb/day will be contribute to the Long Creek WWTP. The same percentage of total
be allocatetherefore 36 lb/ day of total phosphorus of 401b/ day will be
contributed nutrient allocation for the three dischargers is below:
Discharger
Total Nitrogen Allocation
Total Phosphorus Allocation
Mount Holly
300 lb/ da 109,500 lb/ r
50 lb/ day 18,250 lb/ r
Belmont
350lb/day 127,7501b/
58 lb/ day 21,170 lb/ r
Clariant
287 lb/ day104,755 lb/
36 lb/ da 13,14 Ib/ r
Total
987 a b/,
144lb/da 52,560lb/
a Ilat4 PCIO(
J
= 3Ybdn)s
M-M IxA 04ti I-- 4v
3,G,s
004 0416, t
av 40111
t,L "J,,4 tltdv)-al
1;4W(ak\Cb Ca

Mr. Barry She in of e
May 29, 201 I.J
Page 3 of 5
0
T E 1. Speculative Limits for Long Creek Regional WWTP, Proposed flows of 12.0
c-n
Effluent Charactexstic
d F
went
Lyy�acutatxous
onthl Averag
to
W ekI
,
Y
...-
Flow
12.0 MGD
ODS, Summer
4 m/ L
6.0 m/ L
CBODS, Summer
3.3 mg/1
5.0 mg/1
BODS, Winter
8 m /L
12 mg/ L
CBOD5 Winter
6.6 m / 1
10.0 m / 1
TSS
30 m / L
45 m / L
NH3 as N
1.0 m/ L
3.0 m/ L
Dissolved Oxygen
minimum
7.0 mg/ L
TRC
17 u / 1
Fecal colif orm (geometric
mean)
200/ 100 ml
400/ 100 ml
Total Phosphorus
52,560 lbs/year
1.4 mg/1)
Total Nitrogen
342,005 Ibs/ year
9.3 m /1
-�'Gi M'C
Chronic Toxicity
Pass/ Fail (Quarterly test)
90%
TABLE 2. Speculative Limits for Long Creek Regional WWTP,'Proposed flows of 25.0
MGD
' f ,;. S • -, .,- t `.•_ • �jnf Y (.,.
Effluenfi Characteristicfflizent
_., i Y f s
�t
d • ^? v. 3 ..f f €19i 1 aF
.Ms s,
xtattons t
r
'�
Monthly Avexa e1Teekiy
F .;✓s^�,:
.:d
��
f,
°. .:::+era e
Flow
25.0 MGD
5, ummer
4 m /L
6.0 m /L
CBODS, Summer
3.3 m / 1
5.0 m / I
BODS, Winter
8 m /L
12 mg/ L
CBODS, Winter
6.6 m / I
10.0 m / 1
TSS
30 m / L
45 m / L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
7.0 mg/ L
(minimum)
TRC
17 u /1
Fecal coliform (geometric
200/ 100 ml
400/ 100 ml
mean
Total Phosphorus
52,560 Ibs/ year
0.69 mg/1)
Total Nitrogen
342,005 Ibs/year
4.49 mg/1)
14040
R✓ti�
vC
T194 444 y Soo 0)4 Tcal/n., C1044014 h fi-I- 0., / ejo(

Mr. Barry Shearin
May 29, 2013
Page 4 of 5
7
00
Chronic Toxicity
9 /o
Pass/Fail(Quarterly test)
Monitoring in Lake Wylie will als a required to ensure that the water quality model
predictions were accurate and ensure the discharge does not create adverse conditions in
the Lake in the futur CM and Mount o y be required to monitor upstream and
downstream of the outf a toflowing parameters should be included in sampling:
dissolved oxygen, temperature, conductivity, pH, total phosphorus, total nitrogen and
chlorophyll a. Instream monitoring will be required three times per week during the
months of June, July, August and September and once per eek during the rest of the year.
s�
Engineering Alternatives Analysis EA ote that the Division cannot guarantee
that an NPDES permit for discharge f 17.0 MGD will be issued with these speculative
limits. Final decisions can only be ma ter ivision receives and evaluates a formal
permit 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 a spray/drip irrigation, wastewater reuse, or
inflow/infiltration are considered to be environmentally preferable. A copy of the EAA
requirements is attached to this letter. Permit applications for new or expanding flow will
be returned 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
streamflow conditions. For existing discharges, i ' icant im act is defined as an
expansion of > 500,000 gpd additional flow. Since C - Mount o y s cility is
propos' >500,000 gpd flow with an instream was a concentration > 33 %,
th CMU- Mount Holly's acility must prepare a SEPA document that evaluates the
potential for impac e quality of the environment. The NPDES Unit will not accept an
NPDES permit application for the proposed discharge 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 discharge
is subject to SEPA, the EAA requirements discussed above will need to be folded into the
SEPA document. The SEPA process will be delayed if all EAA requirements are not
adequately addressed. If you have any questions regarding SEPA EA/ EIS requirements,
please contact Hannah Stallings with the DWQ Planning Branch at [phone].

Mr. Barry Shearin
May 29, 2013
Page 5 of 5
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact Jackie Nowell at (919) 807- 6386.
Respectfully,
Tom Belnick
Supervisor, Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
Central Files
NPDES Permit File
Barry Gullet, CMUD Director 5100 Brookshire Blvd. Charlotte NC 28216
Brent M. Reuss/ Black & Veatch 8520 Cliff Cameron Drive Suite 210 Charlotte, N.C. 28269
Jeff Debessonet/SCDHEC 2600 Bull Street Columbia, S.C. 29201
Electronic Copy:
NC WRC, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, Sara [e-mail]
DWQ/SWPS Mooresville Regional Office
DWQ/SEPA, Hannah Headrick
DWQ/Modeling TMDL Unit, Kathy Stecker
DWQ/Basinwide Planning, Jeff Manning
NPDES Server>Specs

68
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Aq /I
kno
�v
A's
Al
At
At NO
..........

vi
E N T R I X

Mr. Barry Shearin
June xx, 2013
Page 2 of 5
This segment of the Catawba River (Lake Wylie) is listed on the North Carolina 2012
Impaired Streams list for low pH.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are not any Federally Listed threatened or endangered
aquatic species identified within a 5 mile radius of the discharge location. If there are any
identified threatened/endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge might impact such species.
Speculative Limits. The speculative limits were developed based on Division staff
recommendation and consideration of the Lake Wylie TMDL allocation. Based on available
information, speculative effluent limits for the proposed discharge of 12 and 25 MGD to
Lake Wylie are presented in Tables 1 and 2. A complete evaluation of these limits and
monitoring requirements for metals and other toxicants will be addressed upon receipt of a
formal NPDES permit application.
Nutrients. The nutrient loading for the three dischargers included in the CMU Regional
WWTP was combined to determine the total nutrient allocation for the proposed discharger.
The entire allocation for Mount Holly and Belmont will be included in the Regional facility.
While the Clariant facility has a total nitrogen allocation of 318.5 lb/ day, only 90 % or 287
lb/ day will be allocated to the CMU Regional WWTP. The same percentage of total
phosphorus will be allocated; therefore 36 lb/ day of total phosphorus of 40 lb/ day will be
allocated. The nutrient limitations are consistent with the Lake Wylie nutrient TMDL
allocations and the contributed nutrient allocation for the three dischargers is below:
Discharger
Total Nitrogen
Allocation
Total Phosphorus
Allocation
Basis
Mount Holly
300 lb/ day410JAGO
50 lb/ day
TMDL
Belmont
3501b/ day
58 lb/ day
TMDL
Clariant
287 lb/ day tn11,85V
b
36 lb/ day
TMDL,
Nonpoint
Total
9371b/day* 8W
1.44Ib/day,
tof
Odly �IAIZI
73� � X 4rloz= 7,t

Mr. Barry Shearin
June xx, 2013
Page 3 of 5
TABLE 1. Speculative Limits for CMU Regional WWTP, Proposed flows of 12.0 MGD
Effluent Characteristic
Effluent Limitations
Monthly Average
Weekly -
Average
Daily
Maximum
Flow
12.0 MGD
CBODS, Summer
3.3 m /l
5.0 m /l
CBODS, Winter
6.6 mg/1
10.0 m /l
TSS
30 m /L
45 m /L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/L
TRC
17 u /1
Fecal coliform (geometric
mean
200/100 ml
400/100 ml
Total Nitrogen
342,005 lbs/ e e uiv
Total Phosphorus
52,5601bs/ ear a uivalent to 1.4 m l annual
Chronic Toxicity
Pass/Fail(Quarterly test
90%
A -
TABLE 2. Speculative Limits for CMU Regional WWTP, Proposed flows of 25.0 MGD
Effluent Characteristic
Effluent Limitations
Monthly Average
Weekly
Average
Daily
Maximum
Flow
25.0 MGD
CBODS, Summer
3.3 m /1
5.0 mg/1
CBODS, Winter
6.6 mg/1
10.0 m /l
TSS
30 m /L
45 m /L
NH3asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/L
TRC
17 u /l
Fecal coliform (geometric
mean
200/100 ml
400/100 ml
Total Nitrogen
342,005 lbs/ ear uivalent to 4.49 mg/1 annual average)
Total Phosphorus
52,560 lbs/ e e ufv en o vera e
Chronic Toxicity
Pass/Fail(Quarterly test
o
Monitoring in Lake Wylie will also be required to ensure that the water quality model
predictions were accurate, and to ensure the discharge does not create adverse conditions in
the Lake in the future. CMU will be required to monitor upstream and downstream of the
outfall. The following parameters should be included in sampling: dissolved oxygen,
/ZOO5l0 5✓..
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1
7
10.03
5.80
6.74
2.04
56.99
1
7
10.06
5.81
6.73
2.03
57.00
1
7
10.09
5.81
6.72
2.03
57.02
1
7
10.12
5.81
6.71
2.02
57.03
1
7
10.15
5.81
6.70
2.02
57.05
1
7
10.18
5.82
6.69
2.01
57.06
1
7
10.21
5.82
6.68
2.01
57.08
1
7
10.24
5.82
6.68
2.00
57.09
1
7
10.27
5.83
6.67
2.00
57.11
1
7
10.30
5.83
6.66
2.00
57.12
Seg #
Reach #
I Seg Mi
D.O.
CBOD
NBOD
FlOw

Nowell, Jackie
From: Belnick, Tom
Sent: Tuesday, April 09, 2013 3:06 PM
To: Nowell, Jackie; Berry, Ron; Templeton, Mike
Subject: FW: Spec Limit Letter and Permit Modifications
Attachments: Permit Modification Belmont Option 032713.DOCX
They're (CMU/Belmont/Mt Holly/Clariant) back! Much of this involves the nutrient trading/permit mod proposed
language. As far as the spec request with all players included, CMU Barry Shearin is requesting that we continue on with
that effort. I'll set up a meeting to regroup on all this.
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919-807-6390
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: Shearin, Barry [maiIto: bshearin(&ci.charlotte.nc.us]
Sent: Thursday, March 28, 2013 11:55 AM
To: Belnick, Tom
Cc: Gullet, Barry
Subject: Spec Limit Letter and Permit Modifications
Tom, attached are the proposed permit modifications for Clariant, Belmont, and Mt. Holly. We have talked with
Belmont and Clariant and they are good with everything but still working out a couple details with Mt. Holly. As you
can see in my highlights we have proposed something a little different here from the version I gave you at the meeting in
that the permanent allocation would all go to Belmont rather than Mt Holly if the Long Creek plant doesn't move
forward in the future. For the interim, we are still proposing a split of the Clariant allocation between Mt Holly and
Belmont that would allow them both to come into compliance with the TMDL for Lake Wylie.
However under the new scenario with Belmont buying the allocation instead of Mt Holly in the future if the new plant
doesn't happen, Mt. Holly would likely be discharging above their TMDL allocation again, as they are today. I have not
tried to suggest any language here as to how DWQ might want to address that future scenario or not.
I recognize each of the three parties will need to send you an official request letter to move these modifications forward
but wanted you to have this new version so you all could start your internal conversations. I don't believe there will be
changes to the proposed allocation split that I show here.
The Belmont City Council is scheduled to vote on the nutrient buy back agreement on April 1 and Charlotte City Council
on April 8. At this point we don't see a problem with that happening.
Also, the spec limit letter request I sent you recently is still good to go. Mt Holly is still committed to the long term plan
with the regional plant as outlined so we would need to include all 3 allocations in the spec limits.
Thanks and feel free to give me a call after you've reviewed this info.
Barry Shearin
Chief Engineer
Charlotte - Mecklenburg Utilities

Nowell, Jackie
From: Jarrell, Jackie [[e-mail]]
Sent: Wednesday, May 22, 2013 9:49 AM
To: Shearin, Barry
Cc: Nowell, Jackie
Subject: Re: Spec Limit Letter
Hi Jackie! How are you? Yes, CBOD, like our other permits. Let me know if you need anything else. Jackie
Jacqueline A. Jarrell, P.E. Supt.
Environmental Management Division
Charlotte Mecklenburg Utility Department
P: 704/336-4460
M: 704/634-5430
[e-mail]
On May 22, 2013, at 9:31 AM, "Shearin, Barry" <[e-mail]> wrote:
Jackie J., Jackie Nowell is working on the spec limit letter for the Long Creek WWTP
plant. She was asking me if we preferred to the have the BOD limit expressed as BOD or
CBOD?? I was thinking I had heard you all talk about CBOD but I wasn't sure.
Can you answer that question for Jackie?? Thanks.
Barry Shearin
Chief Engineer
Charlotte - Mecklenburg Utilities
704-391-5137

Nowell, Jackie
From: Belnick, Tom
Sent: Tuesday, April 30, 2013 11:21 AM
To: Templeton, Mike; Berry, Ron; Nowell, Jackie
Subject: Full: Permit Modification Language
Attachments: Proposed Belmont Permit Modifications for Clariant - 04-26-13.docx
CMU Regional- this came in on Friday, have nor had a chance to review. Barry Shearin with CMU just called, I discussed
some of the issues that we raised in our last internal meet.
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919-807-6390
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: Shearin, Barry fmailto:bshearinOci.charlotte.nc.us]
Sent: Friday, April 26, 2013 4:56 PM
To: Belnick, Tom
Subject: Permit Modification Language
Tom, I wanted to send this to you as some new permit modification language proposed by Belmont and Mt Holly. The
primary issue is the desire to put the nutrient allocations in terms of a "seasonable limit" as compared to the "daily Ibs"
we've been talking about.
Not sure if that works for you all or not??
I'll try to call you Monday afternoon and see what you think. Thanks.
Barry Shearin
Chief Engineer
Charlotte - Mecklenburg Utilities
704-391-513 7

Permit Modification Lanaune for Nutrient Allocation
Clariant's Current Permit
The reduction in Clariant's nutrient mass limitations reflect a 90% nutrient allocation transfer of
287 pounds/day Total Nitrogen and 36 pounds/day Total Phosphorus to the City of Charlotte's
proposed Regional WWTP. The allocation transfer and subsequent reduction in Clariant's
nutrient mass limitations will become effective upon the Division's receipt of both (a) an
Engineer's Certificate of Construction Completion for the Charlotte Regional WWTP, and (b)
written notification from Clariant authorizing such nutrient transfer. Clariant's reduced mass
nutrient limitations are based on a 12-month rolling average (refer to Section A.(4)).
Clariant's Proposed Permit
The reductions in Clariant's nutrient mass limitations reflect a 90% nutrient allocation transfer of
287 pounds/day (104.755 pounds/summer season) Total Nitrogen and 36 pounds/day (13,140
pounds/year) Total Phosphorus to the City of Mt. Holly and the City of Belmont in the following
amounts:
City of Mt. Holly: 89,357 pounds/summer season 223 pewids/day of Total Nitrogen
and 8,896 pounds/year :i 6 pounds/day of Total Phosphorous
u City of Belmont: 15,398 pounds/summer season 64-peundsk* of Total Nitrogen
and 4.244 pounds/year.8 peunds/day of Total Phosphorous
The allocation transfer and subsequent reduction in Clariant's nutrient mass limitations will
become effective upon the NC Division of Water Quality's receipt of written notification from
Clariant authorizing such nutrient transfer. Clariant's reduced mass nutrient limitations are
based on a 12-month rolling average (refer to Section A.(4)).
Belmont Proposed Permit
The daily limits for Total Nitrogen and Total Phosphorous set forth in this Permit include the
transfer of 15.398 pounds/summer season 64-peuuds/day of Total Nitrogen and 4,244
pounds/year A-peuxds/day of Total Phosphorous from the permit held by Clariant Corporation.
This transfer reflects the terms of an agreement between Clariant and the City of Charlotte to
reduce and transfer a total of 287 pounds/day Total Nitrogen and 36 pounds/day Total
Phosphorus from the Clariant permit in anticipation of the construction and operation of the
Charlotte Regional WWTP, as described in Clariant's permit. Notwithstanding the limits set
forth in this Permit, Belmont agrees to maintain its discharge such that the total allocation of

nitrogen and phosphorus prescribed by the TMDL for Belmont and Mt Holly, including the
allocation previously permitted to Clariant to Lake Wylie, is met.
Upon receipt of both (a) an Engineer's Certificate of Construction Completion for the Belmont
Wastewater Transfer Liftstation, and (b) written notification from Belmont, the entire Total
Nitrogen and Total Phosphorus allocation within this permit shall be transferred to the Charlotte
Regional WWTP permit (90.298 pounds/summer season 414teeaids/day Total Nitrogen and
25,414 pounds/year 3&peeedsklay Total Phosphorus). It is understood that as condition of this
nutrient transfer Belmont will transfer all wastewater flows currently treated under this permit to
Charlotte Mecklenburg Utilities for treatment as described in the Record of Decision for the
Long Creek Regional Wastewater Treatment Plant Environmental Impact Statement and will
cease operation of the facility subject to this permit.
In the event the Charlotte Regional WWTP is not constructed or cannot be constructed, the
nutrient allocations described above and the allocation placed in the Mt Holly permit (89,357
pounds/summer season 2-34bs/day of Total Nitrogen and 8.896 pounds/year 364bs/day of Total
Phosphorus) from the Clariant permit will become a permanent allocation to this permit once
Belmont has reimbursed Charlotte for the Nutrient Allocation as described in the Memorandum
of Agreement and/or Interlocal Agreement and provided proof of such reimbursement to NC
Division of Water Quality.
Mount Holly Proposed Permit
The daily limits for Total Nitrogen and Total Phosphorous set forth in this Permit include the
transfer of 89,357 pounds/summer season''''�y of Total Nitrogen and 8
,896
pounds/year 4&peunds/day of Total Phosphorous from the permit held by Clariant Corporation.
This transfer reflects the terms of an agreement between Clariant and the City of Charlotte to
reduce and transfer a total of 287 pounds/day Total Nitrogen and 36 pounds/day Total
Phosphorus from the Clariant permit in anticipation of the construction and operation of the
Charlotte Regional WWTP, as described in Clariant's permit. Notwithstanding the limits set
forth in this Permit, Mt. Holly agrees to maintain its discharge such that the total allocation of
nitrogen and phosphorus prescribed by the TMDL for Belmont and Mt Holly, including the
allocation previously permitted to Clariant to Lake Wylie, is met.
Upon receipt of both (a) an Engineer's Certificate of Construction Completion for the Charlotte
Regional WWTP, and (b) written notification from Mt Holly, the entire Total Nitrogen and Total
Phosphorus allocation within this permit shall be transferred to the Charlotte Regional WWTP
permit (153.557 pounds/summer season G'7� Total Nitrogen and 27,146 pounds/year
86 peands/day Total Phosphorus). It is understood that as condition of this nutrient transfer Mt
Holly will transfer all wastewater flows currently treated under this permit to Charlotte
Mecklenburg Utilities for treatment as described in the Record of Decision for the Long Creek

Regional Wastewater Treatment Plant Environmental Impact Statement and will cease operation
of the facility subject to this permit.
In the event the Charlotte Regional WWTP is not constructed or cannot be constructed, the
nutrient allocations described above will become a permanent allocation to the Belmont permit
once Belmont has reimbursed Charlotte for the Nutrient Allocation as described in the
Memorandum of Agreement and/or Interlocal Agreement and provided proof of such
reimbursement to NC Division of Water Quality.

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Permit Modification Language for Nutrient Allocation
Clariant's Current Permit
The reduction in Clariant's nutrient mass limitations reflect a 90% nutrient allocation transfer of
287 pounds/day Total Nitrogen and 36 pounds/day Total Phosphorus to the City of Charlotte's
proposed Regional WWTP. The allocation transfer and subsequent reduction in Clariant's
nutrient mass limitations will become effective upon the Division's receipt of both (a) an
Engineer's Certificate of Construction Completion for the Charlotte Regional WWTP, and (b)
written notification from Clariant authorizing such nutrient transfer. Clariant's reduced mass
nutrient limitations are based on a 12-month rolling average (refer to Section A.(4)).
Clariant's Proposed Permit
The reductions in Clan 's nutrient as limitations reflect a 90% nutrient allocation transfer
287 poundXday (104,75 pounds/ Total Nitrogen and 36 pounds/day 1( 3,140
pounds/year) Total Phosphorus to the City of Mt. Holly and the City of Belmont in the following
amounts:
City of Mt. Holly: 89,357 pounds/ -' of Total Nitrogen
an8,896 pounds/year of Total Phosphorous
314v t o475 5" £rA-,/
City of Belmont: 15,398 pounds/ of Total Nitrogen
and 4,244 pounds/,year 9 of Total Phosphorous
The allocation transfer and subsequent reduction in Clariant's nutrient mass limitations will
become effective upon the NC Division of Water Quality's receipt of written notification from
Clariant authorizing such nutrient transfer. Clariant's reduced mass nutrient limitations are
based on a 12-month rolling average (refer to Section A.(4)).
Belmont Proposed Permit
The daily limits for Total Nitrogen and Total Phosphorous set forth in this Permit include the
transfer of 15,398 pounds/summer season of Total Nitrogen and 4,244
pounds/year,G-pounds4lay of Total Phosphorous from the permit held by Clariant Corporation.
This transfer reflects the terms of an agreement between Clariant and the City of Charlotte to
reduce and transfer a total of 287 pounds/day Total Nitrogen and 36 pounds/day Total
Phosphorus from the Clariant permit in anticipation of the construction and operation of the
Charlotte Regional WWTP, as described in Clariant's permit. Notwithstanding the limits set
forth in this Permit, Belmont agrees to maintain its discharge such that the total allocation of

nitrogen and phosphorus prescribed by the TMDL for Belmont and Mt Holly, including the
allocation previously permitted to Clariant to Lake Wylie, is met.
Upon receipt of both (a) an Engineer's Certificate of Construction Completion for the Belmont
Wastewater Transfer Liftstation, and (b) written notification from Belmont, the entire Total
Nitrogen and Total Phosphorus allocation within this permit shall be transferred to the Charlotte
Regional WWTP permit (90,298 pounds/summer season 414-p Total Nitrogen and
25,414 pounds/, Total Phosphorus). It is understood that as condition of this
nutrient transfer Belmont will transfer all wastewater flows currently treated under this permit to
Charlotte Mecklenburg Utilities for treatment as described in the Record of Decision for the
Long Creek Regional Wastewater Treatment Plant Environmental Impact Statement and will
cease operation of the facility subject to this permit.
In the event the Charlotte Regional WWTP is not constructed or cannot be constructed, the
nutrient allocations described above and the allocation placed in the Mt Holly permit (89,357
pounds/summer season of Total Nitrogen and 8,896 pounds/ of Total
Phosphorus) from the Clariant permit will become a permanent allocation to this permit once
Belmont has reimbursed Charlotte for the Nutrient Allocation as described in the Memorandum
of Agreement and/or Interlocal Agreement and provided proof of such reimbursement to NC
Division of Water Quality.
Mount Holly Proposed Permit
The daily limits for Total Nitrogen and Total Phosphorous set forth in this Permit include the
transfer of 89,357 pounds/summer season �petmdsM of Total Nitrogen and 8,896
pounds/year of Total Phosphorous from the permit held by Clariant Corporation.
This transfer reflects the terms of an agreement between Clariant and the City of Charlotte to
reduce and transfer a total of 287 pounds/day Total Nitrogen and 36 pounds/day Total
Phosphorus from the Clariant permit in anticipation of the construction and operation of the
Charlotte Regional WWTP, as described in Clariant's permit. Notwithstanding the limits set
forth in this Permit, Mt. Holly agrees to maintain its discharge such that the total allocation of
nitrogen and phosphorus prescribed by the TMDL for Belmont and Mt Holly, including the
allocation previously permitted to Clariant to Lake Wylie, is met.
Upon receipt of both (a) an Engineer's Certificate of Construction Completion for the Charlotte
Regional WWTP, and (b) written notification from Mt Holly, the entire Total Nitrogen and Total
Phosphorus allocation within this permit shall be transferred to the Charlotte Regional WWTP
permit (153,557 pounds/summer season Total Nitrogen and 27,146 pounds/year
86 petinds/day Total Phosphorus). It is understood that as condition of this nutrient transfer Mt
Holly will transfer all wastewater flows currently treated under this permit to Charlotte
Mecklenburg Utilities for treatment as described in the Record of Decision for the Long Creek

Regional Wastewater Treatment Plant Environmental Impact Statement and will cease operation
of the facility subject to this permit.
In the event the Charlotte Regional WWTP is not constructed or cannot be constructed, the
nutrient allocations described above will become a permanent allocation to the Belmont permit
once Belmont has reimbursed Charlotte for the Nutrient Allocation as described in the
Memorandum of Agreement and/or Interlocal Agreement and provided proof of such
reimbursement to NC Division of Water Quality.

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Nowell, Jackie
From:
Belnick, Tom
Sent:
Tuesday, May 21, 2013 6:19 PM
To:
Nowell, Jackie
Cc:
Templeton, Mike
Subject:
CMU Regional Spec for ?? MGD/25 MGD
Jackie- let me know if my summary of TN/TP loads looks correct. If yes, let's move forward with spec with annual mass
load limits for TN/TP, and calculate what average effluent concentrations would be needed to meet these load limits at
the phased flows. The spec letter needs to clearly state how we derived the TN/TP loads. We know they want 25 MGD
ultimate, please call Barry Shearin (704-391-5137) to see if they have decided on Phase 1 as 10 MGD, 12 MGD, or 17
MGD. Tell Barry we will send him pre -draft spec to run through the numbers before we mail out official spec. We can
meet before then to review. Thanks.
Mike- please also take a look at numbers. Anything that needs to be changed in numbers or approach?
Mt Holly
300 Ib/d TN
50 Ib/d TP
Belmont
350 Ib/d TN
58 Ib/d TP
Clariant
287 Ib/d TN
36 Ib/d TP
Total:
937 Ib/d TN
144 Ib/d TP
Total:
342,005lb/yr
52,560lb/yr
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919-807-6390
(assumes 90% transfer of 318.5 Ib/d TN and 40 Ib/d TP)
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

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Table 6.2 Comparison of 1992 and 1995 Point Source Phosphorus Reduction
Strategies for Lake Wylie
1992 STRATEGY
Upon expansion, all facilities must most BAT Omits
(defined as 0.5 mgA TP, 4 mg/l summertime TN and 8
mgA wintertime TN)
All industrial discharges will be handled on a case -by -
case basis because best available technology (BAT) is
not dearly defined for them. The Division will require
the industries in the management area to reduce TP
and TN to BAT levels.
By 1998, all facilities must most BAT limits (defined as
0.5 mg/l TP, 4 mgA summertime TN and 8 mgA
wintertime TN)
By 1998, all fac�rties must most BAT Hmhs (defined as
0.5 mg/I TP, 4 mg/l summertime TN and-8 mg/l
wintertime TN)
By 1998, all facilities must meet BAT Omits (defined as
0.5 mg/l We 4 mg/l summertime TN and 8 mg/l
wintertime TN)
1995 STRATEGY
z 1 MGD, all new and expanding facilities must meet
limits of 1 mg/l (TP) and 6 mgA (TN - summer only).
<1 MGD, but >0.05 MGD, all new and expanding
11
facilities trust meet a 2 mg/l TP limit.
No change
By 2001, all facilities must meet a 1 mg/l TP limit and 6
mgA summertime TN limit. By 2006, all facilities must
most a 0.5 mg/l TP limit and TN limits of 4 mg/l in the
summertime and 8 mgA In the wintertime.
. : : • 11� : : =OIAMI 11 lei
MEW
By 2001, all facilities must meet limits of 1 mgA (TP)
and 6 mgA (TN - summer only).
a 1 MGD, all new and expanding facilities must meet
limits of 1 mgA (TP) and 6 mg/l (TN - summer only).
<1 MGD, but >0.05 MGD, all new and expancrmg .
facilities must meet a 2 mgA TP limit.
*Defined as the Catawba River and its tributaries (unless otherwise noted) from the Mountain Island Lake dam to
the Lake Wyile dam. .

Gastonia 16.0 MGD
W Catawba
Lon Creek TP -133 lbs/d 0.0 mg/I)
9 TN - 801 Ibs/d (6.0 mgA)
lit. [stand River
_ ,
lake Dam
Mt. molly
JPS 4.0 MGD
4.0 MGD
TP - 90 Ibs/d (2.7 mg/I)
Tp - 110 Ibs/d
S TN - 293 Ibs/d (8.8 mgA)
(3.3 m9A)
O`
TN - 304 Ibs/d
(9.1 mgA)
BelmontMGD
`F��B
Cd1c ���
801 bs/d
7346 Ibs/d
TP -�� 345 Ibs/d
(8.3 mgA)
6 a �
60%
TN - 624 Ibs/d
Gastonia 9.0 MGD
TP - 38 Ibs/d (.5 mg/I)
TN - 300 Ibs/d (4.0 mg/I)
Catawba Creek
Crowders Creek
LAKE WYUE
Nutrient loadings ([bs/dam
Nutrient Loadings'
TP - 569 TN - 337
i Pre-9_ :35 ug/I
1 12%
i TP - 1077 Ibs/d
' TN - 9289 Ibs/d
Predicted average
Chl-S: 17.2 ug/i
Nutrient loadngS
�, ....1
ITP - 829 TN - 520
12%
Pre& A _chl-_33
Bessemer City 1.5 MGD Gastonia 6.0 MGD
TP -13 lbs/d (1.0 mgA) TP - 50 lbs/d (1.0 mgA) To Lake Wylie Dam
TN - 75 Ibs/d (6.0 mg/I) TN - 300 bs/d (6.0 mgA)
FLegend/Explanation of terms
• Major NPDES Discharger kmdons with faciiity name and predicted avg. daily nutrient loads for total nitrogen
(TN) and phosphorus (TP) based on permitted flow and recommended nutrient concentrations.
r Nutrient sensitive lake areas.
Note: Daisy nutrient loadings in the 4 lake arms are based on 89-90 measured badcgrourid levels plus actual
average 93-94 loadings from dischargers. Nutrient loading in the main lake is based on percentages of the
lake arm loadings that are thought to reach the lake based on a field -calibrated in -lake rwtient transport
model.
Figure 6.1 Schematic Diagram of Lake Wylie Showing Nutrient Loadings and Predicted
Chlorophyll -a Concentrations in the 4 Major Arms and the Mainstem of the Lake
Under the 1995 1ake Wylie Nutrient Management Strategy

Long Creek
Gastonia 16.0 MGD
\-d
mg/I)
0 mgA)
4.0 MGD
90 lbs/d (2.7 mg/l)
293 lbs/d (8.8 mg/I)
JJ:/SN*4,
,jI� Catawba
Mt Wand River
Lake Din Mt. Holly
6.0 MGD
TP - 50 Ibs/d -
(1.0 mgA)
TN - 300 bs/d
(6.0 mg/I)
Ce�1 - Fsr9�i
40%
Nutrient
lea
TP-455 lbs/d
TN-7068 1W
60%
Belmont
7.0 MGD
TP - 58 lbs/d
0.0 mg/I)
TN - 350 lbs/d
(6.0 mg/I)
LAKE WYLIE
Gastonia 9.0 MGD
TP - 38 lbs/d* (.5 mg/I) r
TN - 300 Ibs/d (4.0 mgA)
1 Nutrient loadin^ l�bs� /dav). I 1
1 TP - 569 TN • 337 1'—� � TP - 825 lbs/d
Catawba Creek 1 Pred. a �.:35 u9 1 12% TN - -8885 lbs/d �
1 Predicted average
1 Chl-a: 15.5 ug/I 1
1 Nutrient loadings [lbs/dam: t �. � J
Crowders Creek I'm 82 TN SZo 1
Bessemer City 1.5 MGD
TP -13 lbs/d (1.0 mg/q
TN - 75 lbs/d (6.0 mg/I)
1 Pr .Aw, Ch 33 ug/I 112%
----------
Gastonia 6.0 MGD
TP - 50 lbs/d (1.0 mgA) To Lake Wylie Dam
TN - 300 lbs/d (6.0 mg/I)
i
Legend/Explanation of terms `
• Major NPDES Discharger locations with facility name and predated avg. daily nutrient loads for total nitrogen
(TN) and phosphorus (TP) based on permitted flow and recommended nutrient concentrations.
1 NuWexnt saultive lake areas.
Note: Daily nutrient loadings In the 4 lake arms are basest on 89-90 measured background levels plus actual
average 93-94 loadings from dischargers. Nutrient loading in the main lake is based on percentages of the
lake arm loadings that are thought to reach the lake based on a field -calibrated Make nutrent transport
model.
Figure 6.2 Schematic of Lake Wylie Showing Nutrient Loadings and Predicted
Chlorophyll -a Concentrations in the 4 Major Arms and the Mainstem of the Lake
Under the 1995 Lake Wylie Nutrient Management Strategy with Mt. Holly and Belmont
Expanded by 2.0 MGD

Chapter 6 - Basinwide Goals, Water Quality Concerns and Recommended Management Strategies"
Catawba Creek
All existing surface water discharges in these watersheds with a permitted design flow of
greater than or equal to 0.05 MGD should be required to apply state -of -art nutrient removal
technology. Existing facilities have been notified of this strategy and will be required to meet
permit limits of 0.5 mg/l TP and TN limits of 4 mg/1 in the summer and 8 mg/l in the winter by
2006. Interim limits of 1.0 mg/l TP and. 6.0 mg/l TN (summer) will become effective January
1, 2001. Based on a comparison between Figure 3.4, in Chapter 3, and Figure 6.1, it can be
seen that these recommendations would result in reducing the predicted chlorophyll a
concentration in Catawba creek from 74 ug/l (Figure 3.4) to 35 ug/l (Figure 6.1).
Crowders Creek
By January 1, 2000, it is recommended that all facilities with a permitted design flow of greater
than or equal'to 1 MGD will be required to meet limits of 1.0 mg/l TP and 6.0 mg/l TN. The
nitrogen limits would apply for the months of April through October only. Based on a
comparison between Figure 3.4, in Chapter 3, and Figure 6.1, it can be seen that these
recommendations would result in reducing the predicted chlorophyll a concentration in the
creek from 43 ug/l to 33 ug/l.
Non point sources
All tributaries to Lake Wylie should be targeted by the NC Division of Soil and Water
Conservation for cost share funds for use in implementation of best management practices
(BMPs). When possible, resources should be targeted toward implementation of BMPs in the
Catawba Creek, Crowders Creek, and the South Fork Catawba River watersheds since a
significant amount of the nutrients reaching these streams is from non -point sources. Since the
South Fork Catawba River provides by far the largest nutrient load of any tributary to Lake
Wylie, the South Fork should be considered the highest priority for implementation of BMPs.
6.4.2 Mountain Island Lake
DEM and Mecklenburg County are completing a two-year cooperative study of nutrient loading in
the McDowell Creek watershed and the eutrophic response in Mountain Island Lake. Preliminary
data suggest that the CMUD McDowell Creek WWTP discharge is the largest source of nutrients to
the McDowell Creek arm of Mountain Island Lake. This facility will be required to implement
nutrient removal upon major modification or expansion.
6.4.3 Rhodhiss Lake and Lake Hickory
The WPCOG and the USGS in conjunction with DEM are presently performing a three-year water
quality study of Rhodhiss Lake and Lake Hickory. The objectives of this study include an effort to
quantify nutrient loading to the lakes and to evaluate eutrophic response to nutrient enrichment.
Both lakes receive significant nutrient loading from point and non -point sources.
When compared to other major lakes in the Catawba river basin, Rhodhiss Lake and Lake Hickory
have relatively fast velocities and short retention times (see Table 2.1 in Chapter 2). This suggests
that these lakes may be less sensitive to nutrient enrichment than other lakes in the Catawba river
basin, as mixing and limited retention time in the reservoirs may limit algal growth. Specific
management plans for point and/or non -point source pollution sources to Rhodhiss Lake and Lake
Hickory will be developed after completion of the WPCOG, USGS, DEM study and incorporated
into the second edition of the Catawba basinwide plan.
6-16

The City of
Wb
c�,OTTB
Charlotte -Mecklenburg Utilities / Mount Holly Mount Holly
Charlotte Mecklenburg Utilities and the City of Mount Holly
Long Creek Regional Wastewater Treatment Plant
Scoping Document for
Environmental Impact Statement
1. Introduction
Continued economic development and growth within the Charlotte Metropolitan Area is
projected to require additional wastewater treatment capacity in northwest Mecklenburg
County and the eastern portion of Gaston County. Charlotte -Mecklenburg Utilities
(Utilities) and the City of Mount Holly (Mount Holly) are working together on a project
to evaluate how the growing wastewater demands in both service areas can be met. In
2006, Utilities and Mount Holly cooperated in a feasibility and preliminary planning
study for regional wastewater treatment (Black & Veatch, 2006). The study identified a
number of alternatives that could satisfy future wastewater treatment projections. The
report found that several regional treatment scenarios are conceptually feasible and
favored the construction of a new facility. Scenarios identified in the study included a
new regional wastewater treatment plant (WWTP) adjacent to the existing Long Creek
Pump Station in western Mecklenburg County as well as combinations of expansion and
new construction on the Gaston side of the Catawba. Mount Holly's existing WWTP is
located directly across the Catawba River (Lake Wylie) from the confluence of Long
Creek on the Mecklenburg side and the existing Long Creek wastewater lift station as
shown in Figure 1. A new regional wastewater treatment plant could potentially provide
a single discharge of high quality effluent that would replace the existing discharge.
Utilities and Mount Holly have decided to continue this project by evaluating the
identified alternatives through an Environmental Impact Statement Process (EIS). The
purpose of this scoping document is to present information related to the proposed project
and solicit feedback for preparation of the draft EIS. The EIS will also evaluate the
direct, secondary, and cumulative impacts throughout the two service areas related to the
construction of a new regional WWTP. The alternatives in the proposed project include
construction of a force main across the Catawba River.
2. Purpose and Need
The project area is located in eastern Gaston County and western Mecklenburg County
along the Catawba River. The western Mecklenburg County portion of Utilities' service
area includes the Long Creek, Gar Creek, Catawba Creek, and Lower Mountain Island
Creek watersheds. Utilities will also evaluate the potential to pump wastewater produced
in the Paw Creek watershed to a new WWTP in the project area in the future. The Mount
Holly service area includes wastewater flows from within Mount Holly, its extraterritorial
jurisdiction (ETJ), and a portion of the Town of Stanley. The total service area is shown
in Figure 2.
Black & Veatch International Company
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Charlotte-Meck/enbung Ufflif es / Mount Holly 6
jurisdiction (ETJ), and a portion of the Town of Stanley. The total service area is shown _
in Figure 2.
For the Utilities service area, including Paw Creek, the population is projected to grow to
approximately 75,000 in 2020, increasing to approximately 115,000 by 2030. For the
Mount Holly service area, the population is projected to grow to approximately 25,000 in
2020, increasing to approximately 40,000 by 2030. Including industrial wastewater
flows, the 2030 maximum month wastewater flow projections are 17 million gallons per
day (mgd) and 8 mgd for Utilities and Mount Holly, respectively (Table 1).
Table 1
Long Creek Regional WWTP Project Area
Maximum Month Wastewater Flow Projections
Population Served
Wastewater Flows
(mgd)
2000 2010
2020
2030
2000 2010 2020 2030
Utilities Service Area
23,297 43,371 74,098 115580
3.34 6.47
10.90
16.86
Mt Holly Service Area
. 9,000 14,515 24,382 39,322
3.32 4.10
5.50
7.62
6.66 10.57
16.40
24.48
Total 32,297 57,886 98,480 154,902
Figure 3 illustrates the flow projections for the combined service areas. The proposed
project is a key element in Utilities' plan to provide system -wide municipal wastewater
treatment and is compatible with planned and anticipated growth. Based on population
growth and wastewater flow projections, the capacity of the existing 4-mgd Mount Holly
WWTP will be exceeded by 2020. Utilities' transmission line to the McAlpine WWTP is
limited by the capacity of the Coffey Creek interceptor where it crosses Runway 2 at the
Charlotte -Douglas International Airport. The Coffey Creek interceptor is currently
nearing its maximum capacity.
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Charlotte -Mecklenburg Udlides / Mount Holly
25
20
V 15
0
E
3
0
a- 10
5
0
PROJECTED MAXIMUM
MONTH FLOWS `
1
2000 2005 2010 2015 2020 2025 2030
Year
Figure 3. Combined Wastewater Flow Projections
3. Proposed Project and Proposed Project Site
The planning study (Black & Veatch, 2006) describes the initial evaluation of potential
alternatives for the municipalities to accommodate their combined wastewater treatment
needs, including continuing to operate separately. The study evaluated six possible
alternatives (see Section 5 below) and included a preliminary recommended alternative.
The preliminary recommended alternative was selected based on the most favorable
combination of minimizing environmental impacts and maximizing the cost effectiveness
of permitting, construction, and operation. The 2006 study was based on conceptual and
high-level analysis. The EIS process will provide more detailed evaluation of these
alternatives and could result in the same or a different conclusion.
Portions of several of the potential sites associated with these alternatives involve
property along Lake Wylie within the area covered by the Shoreline Management Plan
(Catawba Wateree SMP) for Duke Energy's Catawba Wateree Hydro Project (FERC
Project No. 2232) and approval through Duke's Catawba Wateree SMP Conveyance
Program will be required. The project is consistent with existing zoning and the
surrounding land use. The proposed facility would be constructed outside of the 100-year
floodplain and aligned on the property to avoid impacting site wetlands and required
buffers.
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Charlotte -Mecklenburg Utilities / Mount Holly
Though the specific details of the proposed project have yet to be determined, Figure 4
provides a conceptual site plan for Alternative 5 described below (at 25 mgd). The
facility would be designed to be constructed in phases as flows increase over time. The
first phase would be designed for a capacity of 11 to 17 mgd in 2020 followed by
expansions in approximately 2030. Site improvements that would be made during
construction of the project include earthwork, landscaping, construction of roads,
operations and maintenance facilities, and permanent stormwater management facilities.
A new regional WWTP would be expected to consist of the following facilities:
• Headworks (screening and grit removal)
• Flow equalization
• Primary clarifiers
• Biological nutrient removal (BNR) basins
• Secondary clarifiers
• Deep bed denitrification filters
• UV Disinfection
• Reaeration
• Solids Handling
• Influent pumping
• Piping to transport flow across the Catawba River
• Outfall structure in Long Creek or the Catawba River
4. Project Alternatives Considered
Various alternatives for a new regional facility or continuing to operate separate
wastewater facilities were considered in the 2006 planning study. The study identified
multiple reasons for focusing on a single regional facility. These included:
1) The State of North Carolina and the Division of Water Quality (DWQ, 2004)
favor a regional approach to wastewater treatment and may be more supportive
of a new regional plant over other alternatives.
2) Placement of a single WWTP is preferable to other alternatives in terms of
compatibility with existing and future land uses, establishment and protection of
riparian buffers, and minimization of impacts to critical areas such as wetlands.
3) The proposed project provides regional wastewater treatment with a single
discharge, efficiency in planning, design, and permitting, minimizes shoreline
and wetland impacts, and cost-effectively achieves project goals.
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Charlotte-Mecklenbury Utilities / Mount Holly
A summary of alternatives considered in the 2006 planning study included:
• Alternative 1 — Continue to operate separately and with existing facilities. This
scenario requires Mount Holly to upgrade to and expand their existing plant to 8
mgd and Utilities to provide conveyance and treatment capacity for 17 mgd at
McAlpine Creek WWT? and/or at Irwin Creek WWTP.
• Alternative 2 — Continue to operate separately with additional facilities. This
scenario requires Mount Holly to upgrade and expand their existing plant to 8
mgd and Utilities to construct a new 17-mgd plant located at Long Creek to treat
wastewater from within Mecklenburg County.
• Alternative 3 — Provide treatment for Mount Holly and Utilities flows at the
Mount Holly WWTP site by upgrading and expanding the existing plant to 25
mgd. Utilities flows would be pumped across the Catawba River.
• Alternative 4 — Provide treatment for Mount Holly and Utilities flows in Mount
Holly by constructing a new 25-mgd WWTP on land adjacent to the existing
Mount Holly WWTP. Utilities flows would be pumped across the Catawba
River.
• Alternative 5 — Provide treatment for Mount Holly and Utilities flows on the
Mecklenburg side of the Catawba River by constructing a new 25 mgd WWTP on
vacant land surrounding the Long Creek Pump Station. Mount Holly flows would
be pumped across the Catawba River.
• Alternative 6 — Continue to operate the Mount Holly WWTP at 4 mgd. Provide
treatment for Mount Holly and Utilities flows on the Mecklenburg side of the
Catawba River by constructing a new 21 mgd WWTP on vacant land surrounding
the Long Creek Pump Station. Dutchman's Creek (Mount Holly) flows would be
pumped across the Catawba River.
These alternatives will be further evaluated and addressed in the EIS, in addition to the
Non -Discharge and No Action alternatives. Non -discharge options will also be evaluated
according to NC DWQ guidelines. Under the No Action alternative, Utilities and Mount
Holly would not expand municipal wastewater treatment capacity to serve the growing
population of western Mecklenburg County and Mount Holly. The population of the area
would continue to grow necessitating the implementation of on -site wastewater treatment
practices such as septic tank systems or smaller package wastewater treatment plants.
Such systems would not achieve the level of reliability, advanced treatment levels, or
monitoring required of the alternatives being considered.
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5. Environmental Analysis & Regulatory Compatibility
The potential environmental effects related to the proposed project include direct and
secondary and cumulative impacts (SCI). These impacts will be addressed in the EIS.
The categories of potential impacts that will be addressed in the EIS include:
• Topography
• Soils
• Land Use and Land Cover
• Wetlands
• Floodplains
• Prime or Unique Agricultural Lands
• Public lands and Scenic Recreational and Significant Natural Areas
• Areas of Archeological or Historic Value
• Air Quality
• Noise Levels
• Water Resources (Surface Water and Groundwater)
• Forest Resources
• Shellfish or Fish and Their Habitats
• Wildlife and Natural Vegetation
• Introduction of Toxic Substances
The environmental analysis to be conducted during the EIS process will include site -
specific surveys, review of existing environmental data and ordinances, water quality
monitoring and modeling, consultation with agencies, and other means to evaluate the
potential environmental impacts and mitigation. The secondary and cumulative impacts
will be analyzed using available information primarily from Mecklenburg County's Land
Use and Environmental Services Agency (LUESA), Charlotte Storm Water Services,
Mount Holly, and others. Future land use information developed for previous studies will
be the basis for the SCI analysis. Specific attention will be directed towards water quality
because of the complexity of water quality issues within the Catawba River system.
Water Quality
Water bodies present in the vicinity of the potential regional project sites include the
Catawba River downstream of the Mountain Island Lake Dam, and Long Creek near its
confluence with the Catawba River. In these areas, both waterbodies are classified as
critical areas (CA) within WS-IV water supply waters (WS-IV; CA) (DWQ BIMS
Database, May 14, 2007). Water supplies in moderately to highly developed watersheds
are classified as WS-IV waters. Watershed areas within one-half mile of a water supply
and waters within one-half mile of a water supply intake are designated as critical areas.
Discharges are allowed in WS-IV; CA areas, but effluent must meet standards established
by the North Carolina Department of Environmental Health (DEH). Expanded
wastewater discharges to water supply waters must be approved by NC DEH. Within
water supply watersheds, the North Carolina Department of Environment and Natural
Resources (NC DENR) also requires minimum buffer widths as well as control of
nonpoint sources and stormwater discharges.
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Charlotte -Mecklenburg W111 ies / Mount Holly
As part of this project, water quality modeling will be performed to support the
evaluation of water quality effects and the development of speculative NPDES limits by
NC DWQ for the plant discharge into Lake Wylie. Already developed for the Catawba
River by Duke Energy for the FERC relicensing process, the CE-QUAL-W2 water
quality model will be used. DWQ indicated their support of the use of the Duke CE-
QUAL-W2 model and provided recommendations for additional sampling for model
calibration. Additional water quality monitoring within Lake Wylie and other project
areas has already been initiated by Utilities and Mecklenburg County (LUESA). This
supplemental water quality data will be used along with existing LUESA, Duke Energy
and DWQ data for model calibration. In this area of Lake Wylie, flow conditions, current
velocities, and circulation are dependent upon the amount of water being released at the
Mountain Island Lake Dam and the elevation of the Lake Wylie.
Endanctered or Threatened Species
According to the NC DENR Natural Heritage Inventory Database, May 14 2007, there
are records of a few endangered or threatened species currently within the USGS
quadrangle areas of Mountain Island Lake and Mount Holly near the proposed regional
facility locations. The endangered species include Smooth coneflower (Echinacea
laevigata), Schweinitz's sunflower (Helianthus schweinitzii) and Michaux's sumac (Rhus
michauxia). These three species are also federally listed endangered species. Threatened
species include the Georgia aster (Symphyotrichum georgianum).
The United States Fish and Wildlife Service (USFWS) list, May 15, 2007, for Gaston
County mentions the following protected species with threatened status, the bald eagle
(Haliaeetus leucocephalus) and the bog turtle (Clemmys muhlenbergii). The USFWS list
for Mecklenburg County includes the bald eagle as threatened. Surveys will be performed
to confirm the presence or absence of these species on all of -the regional wa-�: :rater
facility alternative sites.
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Charlotte -Mecklenburg Udlides / Mount Holly _
6. Draft EIS Outline
Executive Summary
Section 1— Proposed Project Description
Section 2 — Project Purpose and Need
Section 3 — Alternatives Evaluation
1. Operate separately with existing facilities
2. Operate separately with new Utilities Long Creek WV'VTP
3. Regionalize — Upgrade and expand existing Mount Holly WWTP
4. Regionalize — New WWTP adjacent to existing Mount Holly WWTP
5. Regionalize — New WWTP adjacent to existing Long Creek Pump Station
6. Regionalize — Maintain existing Mount Holly WWTP and construct new
WWTP adjacent to existing Long Creek Pump Station
7. Non -Discharge Alternatives including reuse and alternative disposal options
8. No Action Alternative
Section 4 — Wastewater Treatment Plant Facilities
Section 5 — Existing Environment
Section 6 — Environmental Consequences
Section 7 — Mitigation
Section 8 — List of Preparers
Section 9 — Literature Cited
Section 10 —Appendices
Appendix A — Supporting Documents
Appendix B — Agency Involvement
Appendix C — Local Ordinances and Information
7. Public Involvement
As part of the EIS process, Utilities and Mount Holly will hold at least two public
meetings to discuss the project and EIS with the public. These meetings will provide a
forum to receive public comments on the project, discuss alternatives to be considered,
environmental issues, and other comments regarding the scope and content of the EIS.
To supplement these meetings, Utilities and Mount Holly plan to assemble a Steering
Group and a Stakeholders' group that will identify major issues and public values and
help to anticipate and address community issues and reaction to the proposed alternatives.
The Stakeholders' group will include members representing local environmental, land,
regulatory, and economic development interests. This stakeholder group will meet
periodically beginning in August of 2007. There will be a separate effort to provide
regular updates and project information to local homeowner associations, Catawba
Regional Council of Governments, and media.
The Steering Group will be formed by Utilities and Mount Holly to assist in carrying out
the study. It will consist of Utilities staff, Mount Holly staff, and consultants working on
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Charlotte -Mecklenburg Udlides / Mount Holly
the study. The Steering Group will combine the input of the Stakeholders' Group with the
technical data produced by the study to form recommendations.
The Stakeholders' Group is planned to include a wide range of individuals with diverse
community visions. The Stakeholders' Group will provide the Steering Group with
feedback on the study as it progresses. The feedback or reaction to the information
presented will reflect the various visions and thoughts of the group. The Steering Group
will incorporate this feedback into its recommendations, balancing community visions,
technical feasibility and economic reality.
8. State and Federal Permits Required
Several state and federal permits are required for activities associated with this project.
The following permits and actions need to be completed -prior to commencement of
construction activities:
• State Environmental Policy Act review and Record of Decision (ROD);
• Clean Water Act Section 404 Permit from U. S. Army Corps of Engineers
(USACE) Regulatory Branch (required for construction in jurisdictional wetlands
and streams);
• Clean Water Act Section 401 Certification from DWQ Wetlands/401 Permitting
Unit (required for construction in jurisdictional wetlands and streams);
• Air Emissions Permit from NCDAQ (may be required for emergency generators);
• A Sediment and Erosion Control Plan (must be approved by NCDENR
Mooresville Regional Office, Land Quality Supervisor);
• Abandonment of wells, if applicable, (must be in accordance with 15A
NCAC2C.0100).
• National Pollutant Discharge Elimination System (NPDES) Permit for new
wastewater discharge to state surface waters.
• Land disturbance permits
In addition to state and federal permits, Utilities and Mount Holly need to obtain approval
from Duke Energy for non -project use of project lands through Duke's Catawba Wateree
SMP Conveyance Program for a new outfall to either Long Creek or the Catawba River,
if located within the Catawba Wateree project boundary and a transmission line across
the Catawba River.
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Charlotte -Mecklenburg Utilities/ Mount Holly
9. References
Black & Veatch. August 2006. Mount Holly/ Charlotte -Mecklenburg Utilities. Feasibility
and Preliminary Planning Study for Regional Wastewater Treatment.
Duke, 2001. Shoreline Management Plan (SMP). Duke Energy, Lake Management
Division, Charlotte, NC.
North Carolina Division of Water Quality (DWQ). May 14, 2007. North Carolina Stream
Classification Schedules from BIMS Database. Online database.
http://h2o.enr.state.nc.us/bims/reports/reportsWB.html
North Carolina Natural Heritage Program. May 15, 2007. Database of North Carolina's
Endangered and Threatened Species. Online Database.
http://www.ncnhp.org/Pages/heritagedata.html
United States Fish and Wildlife North Carolina Ecological Services. May 15, 2007. North
Carolina's Threatened and Endangered Species. Online database.
http://www.fws.gov/nc-es/es/es.html
10. Figures
The following figures are attached.
Figure 1— Proposed Regional Wastewater Treatment Plant Vicinity Map
Figure 2 — Service Area for Proposed Regional Wastewater Treatment Plant
Figure 4 — Proposed Regional Wastewater Treatment Plant Site Plan
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Figure 1. Proposed Regional Wastewater
Treatment Plant Vicinity Map N
Legend NNJW+E
® CMU TPs City Limits —Streams and Rivers
County Boundary — Primary Roads S
11,000 5,500 0 11,000 Feel

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Clariant -current TN limits
Jan 1 Dec 31
318.5lb/day = 116,253 lb/yr TN
Clariant - current TN limits - seasonal equivalents
Jan 1 Dec 31
318.5 lb/day x 214 = 68,159 lb TN (5)
318.5 lb/clay x 151 = 48,094 lb TN (W)
Clariant - TN transfers 90%x 318.51b/day = approx. 2871b/day TN
Jan 1 Dec 31
287 lb/day x 214 = 61,418 lb TN (S)
(318.5 - 287) lb/day x 365 = 11,498 Ib/yrTN remaining for Clariant
(Not applied in limits: 287 x 151 days = 43,370 Ib/yr TN)
Clariant - current TP limits
Jan 1 Dec 31
40.0 Ib/day = 14,600 Ib/yr TP
Clariant - TP transfers
Jan 1 Dec 31
36 lb/day x 365 = 13,140lbTP
(40.0 - 36.0) lb/clay x 365 = 1,460 Ib/yr TP remaining for Clariant
lake wylie nutrient allocations.xlsx, Sheetl
1/1 Printed 5/10/2013, 11:07 AM

DRAFT
CMUD Long Creek
MTU considerations
1. Lake Wylie TMDL
There is an existing TMDL for Lake Wylie with allocations for both TN and TP. The TMDL
includes separate loads for each major lake arm, and was calculated for a dry year during the
growing season (April through October) to represent critical conditions.
The TMDL, as submitted and approved in 1996, did not require TN and TP load reductions
for Belmont and Mt. Holly WWTPs until they expanded. Pre- and post -expansion loads are
shown below in Table 1. It is important to note that the TMDL for this arm of the lake is
based on the post -expansion load limits (see Table 2), not the pre -expansion load estimates.
Table 1. Lake Wylie "TMDL Wasteload Allocation Strategy" for Mt. Holly and Belmont
(1996)
WWTP
FlowD)
TN - lb/day
TP - lb/day
Notes
4.0
304
110
Existing condition estimated at permitted flow
Mt. Holly
300
50
TMDL Allocation — post -expansion, these will be
6.0
6 m )
1 mpermit
limits.
5.0
624
345
Existing condition estimated at permitted flow
Belmont
350
58
TMDL Allocation — post -expansion, these will be
7.0
6 m
1 mpermit
limits.
Table 2. Catawba River Arm loads
TN - lb/day
TP - lb/da
TMDL Allocation (WLA+LA)
7068
455
Estimated Loads w/ 1996 Existing
Conditions (PS+NPS)
7346
801
Mt. Holly & Belmont at permitted flows
TMDL Allocation (WLA only)
650
108
Estimated Loads w/ 2006 Existing
Conditions (range, PS only)
731-1745
112-1446
Mt. Holly & Belmont at permitted flows
TMDL Allocation LA only)
6418
346
Estimated Loads w/ 2002 Existing
1529
104
Conditions (NPS only)
To date, neither Mt. Holly nor Belmont has expanded. In other words, the TMDL has not
been fully implemented in this arm of the lake.

Table 3 below summarizes loading analysis results. The proposed new discharge in
combination with the Belmont WWTP 1996 "existing condition" estimate violates the
TMDL for this arm of the lake.
Table 3. Lake Wylie TMDL Loading Analysis.
TN Load
TP Load
Notes
(lbs/day)
(lbs/day)
Point Sources (PS)
New Discharge Load
Assumes that Mt. Holly will merge with this
(CMUD Long Creek)
730
104
facility and no longer have a separate discharge.
Assumes discharge of 25 MGD with limits of 0.5
m TP and 3.5 m /L TN.
See TMDL approval document page 3. Note
Belmont 1996 existing condition
624
345
these are loads before TMDL implementation
estimated at permitted flow
(page 4) and are not consistent with the actual
TMDL allocations.
Nonpoint Sources (NIPS)
2002 Nonpoint Load
1529
104
Calculated from model inputs for 2002 (note that
(TMDL NPS Allocation)
(6418)
(346)
estimated 2002 loads are much less than TMDL
NPS allocation).
Total Load = PS + NPS
2884
553
Note: Mt. Holly is assumed to have merged with
new discharge.
Compare to TMDL
TMDL Allocation for Catawba
7068
455
Page 4 of TMDL Approval Document
Arm
Difference:
4184
-98
A negative value indicates total load is greater
TMDL Allocation - Total Load
than TMDL and therefore violates the TMDL.
YES
There are 6 lbs/day available for a "new
Violates TMDL?
No
(by 98
discharge" and these would immediately be used
lbs/day)
by what Mt. Holly already discharges.
2. Chlorophyll -a Analysis Scenarios
The Modeling and TMDL Unit ran several model scenarios to test the relative impact of the
WWTPs on chlorophyll -a levels. The four scenarios are summarized in Table 4 and results
for Layer 3 are provided in Table 5. Model layer 3 is at or near the surface, depending on the
lake level. Note that the model typically under -predicts chlorophyll -a in this arm of the lake
by as much as 14 ug/L; therefore, number of days chlorophyll exceeds 35ug/L is presented.
Scenario 1 represents current conditions (2002 weather, streamflow, and Belmont and Mt.
Holly DMRs) in the lake and show that maximum chlorophyll -a concentrations do not
exceed 30 ug/L.
2

Table 4. Scenario Reference Table
Scenario
Belmont WWTP
Mt. Holly WWTP
Long Creek WWTP
1
Measured discharge concentrations and measured
None
flow
2
Measured discharge concentrations and max
None
permitted flow
3
1996 pre -expansion load estimate referenced in
None
TMDL
1996 pre -expansion
25 MGD, 3.5 mg/L TN,
4
load estimate
None
0.5 mg/L TP
referenced in TMDL
Table 5. Chlorophyll-a.(ug/L) Scenario Summaries for 2002 Layer 3
Maximum
odel
Segment*
Scenario 1
Scenario 2
Scenario 3
Scenario 4
6
29.6
44.4
37.7
40.1
7
27.5
46.0
35.6
37.0
8
27.3
44.2
33.8
36.5
9
27.7
40.6
32.1
33.9
# of Days Chlorophyll a (ug/L) greater than 35 ug/L
6
0
10
2
5
7
0
14
1
1
8
0
3
0
1
9
0
2
0
0
* Model segments 6-9 are shown. Segment 6 is where Belmont WWTP discharges into the
lake and 7-9 follow sequentially downstream of segment 6.
The results of scenario 2 suggest that if Belmont and Mt. Holly continue to discharge at
existing measured concentrations (as reported in DMRs) and flow increases up to maximum
permitted, the chlorophyll -a concentrations will exceed 40 ug/L. This is especially important
because these two facilities do not currently have nutrient permit limits. Lake Wylie could
become impaired again if there are no limits established for these facilities.
The results of scenario 3 suggest that if Belmont and Mt. Holly operate under the "pre -
expansion" loads referenced in the TMDL, chlorophyll -a will reach a maximum value of
37.7 ug/L. While this value is not higher than 40 ug/L, it is important to note that the model
typically under -predicts chlorophyll -a in this arm of the lake.
Finally, scenario 4 provides information on the impact of both Belmont WWTP operating
under the "pre -expansion" loads referenced in the TMDL, and the new Long Creek Regional
WWTP operating under 25 MGD with permit limits of 0.5 mg/L for TP and 3.5 mg/L for
TN. The assumption for scenario 4 is that Mt. Holly would have merged with the new
facility and would not have a separate discharge. The results of this scenario suggest that
there will be violations of the chlorophyll -a standard.

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Belnick, Tom
From: Nowell, Jackie
Sent: Friday, May 24, 2013 1:45 PM
To: Belnick, Tom; Berry, Ron; Templeton, Mike
Subject: CMUMTHOLLYBELMONTCLAR2013
Attachments: CMUMTHOLLYBELMONTCLAR2013.docx
First draft of Long Creek WWTP spec letter. I think we should meet to confirm that TN will be given as a year round limit
and will still meet the Lake Wylie TMDL. After things settle down from EPA visit.

Aor�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E. Skvarla, III
Governor Director Secretary
May 29, 2013
Mr. Barry Shearin, Chief Engineer
Charlotte Mecklenburg Utilities
5100 Brookshire Blvd.
Charlotte, North Carolina 28216
Subject: Speculative Effluent Limits
Proposed Long Creek Regional WWTP
Mecklenburg County
Dear Mr. Gullett:
This letter is in response to your request for revised speculative effluent limits for the
proposed Charlotte Mecklenburg Utilities (CMU) Long Creek Regional WWTP. Speculative
limits in September 2009 included the City of Mount Holly Wastewater Treatment Plant in
partnership with CMU for proposed the Long Creek WWTP at the wasteflows of 17 MGD
and 25 MGD. In January 2010, speculative limits were given that included Mount Holly and
Clariant WWTP in partnership for the proposed Long Creek Regional Plant at 17 MGD and
25 MGD. The Clariant facility would be going offline and connecting to the regional plant.
These new revised speculative limits now include the City of Belmont, along with the City of
Mount Holly and Clariant as partners in the Long Creek Regional WWTP. The requested
wasteflows are 12 MGD and 25 MGD. It should be understood by all entities that these
speculative limits are only applicable if the wastewater from the City of Mount Holly is
included in the proposed project. There is no capacity in Lake Wylie for a Charlotte
Mecklenburg Utilities discharge facility on its own, based on the EPA approved 1996 Lake
Wylie TMDL allocation. In addition, Mount Holly, Belmont and Clariant must all submit
formal permit modifications to confirm the transfers of flow and nutrient loading to the
proposed Long Creek Regional WWTP. Please recognize that speculative limits may change
based on future water quality initiatives, and it is highly recommended that the applicant verify
the speculative limits with the Division's NPDES Unit prior to any engineering design work.
Receiving Stream. Lake Wylie has a stream classification of WS-IV CA. Waters with this
designation are a source of drinking water supply, culinary or food processing purposes in
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwatemualitv.om We
An Equal opportunity 1 Affirmative Action Employer North Carolina
Naturally

Mr. Barry Shearin
May 29, 2013
Page 2 of 5
addition to the standard uses for waters with a C classification. It is also designated as a
critical area (CA) which means the area adjacent to a water supply intake or reservoir where
risk associated with pollution is greater than from the remaining portions of the watershed.
North Carolina regulation 15A NCAC 2B .0202 (20) provides a more thorough definition of
critical area. In addition, it is recommended that 15A NCAC 2B .0216 also be reviewed in its
entirety for the water quality standards that are applicable to WS-IV CA streams.
This segment of the Catawba River (Lake Wylie) is listed on the North Carolina 2012
Impaired Streams list for low pH.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are not any Federally Listed threatened or endangered
aquatic species identified within a 5 mile radius of the discharge location. If there are any
identified threatened/ endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge might impact such species.
Speculative Limits. The speculative limits were developed based on Division staff
recommendation and consideration of the Lake Wylie TMDL allocation. Based on available
information, speculative effluent limits for the proposed discharge of 12 and 25 MGD to
Lake Wylie are presented in Tables 1 and 2. A complete evaluation of these limits and
monitoring frequencies and monitoring requirements for metals and other toxicants will be
addressed upon receipt of a formal NPDES permit application.
Nutrients. The nutrient loading for the three dischargers included in the Long Creek
WWTP was combined to determine the total nutrient allocation for the proposed discharger.
The entire allocation for Mount Holly and Belmont will be included in the Long Creek
facility. While the Clariant facility has a total nitrogen allocation of 318.5 lb/day, only 90 %
or 287 lb/day will be contributed to the Long Creek WWTP. The same percentage of total
phosphorus will be allocated; therefore 36 lb/ day of total phosphorus of 40 lb/ day will be
contributed. The contributed nutrient allocation for the three dischargers is below:
Discharger
Total Nitrogen
Allocation
Total Phosphorus Allocation
Mount Holly
300 lb/ da
109,500 Ib/ r
50 lb/ da
18,250 lb/ r
Belmont
350 lb/ day
127,750 lb/ r
58 lb/ da
21,170 lb/ r
Clariant
287 lb/ day
104,755 lb/
36 lb/ da
13,140 lb/ r
Total
987lb/da
342,005lb/
144lb/da
52,560lb/
TABLE 1. Speculative Limits for Long Creek Regional WWTP, Proposed flows of 12.0
MGD
Effluent Characteristic Effluent Limitations
Monthly Average Weekly Daily
Average Maximum
Flow 12.0 MGD

Mr. Barry Shearin
May 29, 2013
Page 3 of 5
BODS, Summer
4 m/ L
6.0 m/ L
CBODS, Summer
3.3 m / 1
5.0 m / 1
BODS, Winter
8 m/ L
12 m/ L
CBODS, Winter
6.6 m /I
10.0 m /l
TSS
30 m /L
45 mg/ L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/ L
TRC
17 u /I
Fecal coliform (geometric
mean
200/ 100 ml
400/ 100 ml
Total Phosphorus
52,560 lbs/ year
1.4 mg/1)
Total Nitrogen
342,0051bs/ year
9.3 mg/1)
Chronic Toxicity
Pass/ Fail(Quarterly test
90%
TABLE 2. Speculative Limits for Long Creek Regional WWTP, Proposed flows of 25.0
MGD
Effluent Characteristic
Effluent
Limitations
Monthly Average
Weekly
Average
Daily
Maximum
Flow
25.0 MGD
BODS, Summer
4 m/ L
6.0 m/ L
CBODS, Summer
3.3 m / 1
5.0 m / 1
BODS, Winter
8 m/ L
12 m/ L
CBODS, Winter
6.6 m / 1
10.0 m / 1
TSS
30 m / L
45 m / L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
(minimum)
7.0 mg/ L
TRC
17 u / 1
Fecal colif orm (geometric
mean
200/ 100 ml
400/ 100 ml
Total Phosphorus
52,560 lbs/ year
0.69 mg/1)
Total Nitrogen
342,005 lbs/year
4.49 m / 1
Chronic Toxicity
Pass/Fail(Quarterly test
90%
Monitoring in Lake Wylie will also be required to ensure that the water quality model
predictions were accurate, and to ensure the discharge does not create adverse conditions in
the Lake in the future. CMU and Mount Holly will be required to monitor upstream and

Mr. Barry Shearin
May 29, 2013
Page 4 of 5
downstream of the outfall. The following parameters should be included in sampling:
dissolved oxygen, temperature, conductivity, pH, total phosphorus, total nitrogen and
chlorophyll a. Instream monitoring will be required three times per week during the
months of June, July, August and September and once per week during the rest of the year.
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee
that an NPDES permit for discharge of 17.0 MGD will be issued with these speculative
limits. Final decisions can only be made after the Division receives and evaluates a formal
permit 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 a spray/drip irrigation, wastewater reuse, or
inflow/infiltration are considered to be environmentally preferable. A copy of the EAA
requirements is attached to this letter. Permit applications for new or expanding flow will
be returned 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
streamflow conditions. For existing discharges, significant impact is defined as an
expansion of > 500,000 gpd additional flow. Since CMU- Mount Holly's facility is
proposing a discharge of >500,000 gpd flow with an instream waste concentration > 33 %,
the CMU- Mount Holly's facility 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 discharge 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 discharge
is subject to SEPA, the EAA requirements discussed above will need to be folded into the
SEPA document. The SEPA process will be delayed if all EAA requirements are not
adequately addressed.. If you have any questions regarding SEPA EA/ EIS requirements,
please contact Hannah Stallings with the DWQ Planning Branch at [phone].
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact Jackie Nowell at (919) 807- 6386.
Respectfully,

Mr. Barry Shearin
May 29, 2013
Page 5 of 5
Tom Belnick
Supervisor, Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
Central Files
NPDES Permit File
Barry Gullet, CMUD Director 5100 Brookshire Blvd. Charlotte NC 28216
Brent M. Reuss/ Black & Veatch 8520 Cliff Cameron Drive Suite 210 Charlotte, N.C. 28269
Jeff Debessonet/SCDHEC 2600 Bull Street Columbia, S.C. 29M
Electronic Copy:
NC WRC, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, [e-mail]
DWQ/SWPS Mooresville Regional Office
DWQ/SEPA, Hannah Headrick
DWQ/Modeling TMDL Unit, Kathy Stecker
DWQ/Basinwide Planning, Jeff Manning
NPDES Server>Specs

A .A.�5 V/
b�
4J
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor - Acting Director Secretary
Mr. Barry Shearin, Chief Engineer
Charlotte Mecklenburg Utilities
5100 Brookshire Blvd.
Charlotte, North Carolina 28216
Dear Mr. Shearin:
June xx, 2013
(Ycwjm:'ar-e.
NA0411 (60
Subject: Speculative Effluent Limits
Proposed CMU Regional WWTP
Mecklenburg County
This letter is in response to yo request for revised speculative effluent limits for the
proposed Charlotte Mecklenburg tilities (CMU) Regional WWTP. Speculative limits in
September 2009 included the Ci of Mount Holly Wastewater Treatment Plant in
partnership with CMU for the propo ed CMU Regional WWTP at the wasteflows of 17
MGD and 25 MGD. In January 2010, s culative limits included Mount Holly and Clariant
WWTP in partnership for the proposed C Regional Plant at 17 MGD and 25 MGD.
This latest speculative limits request now inc des the City of Belmont, along with the City of
Mount Holly and Clariant as partners in the C Regional WWTP. The requested wasteflows
are 12 MGD and 25 MGD. It should be underst d by all entities that these speculative limits
are only applicable if the nutrient allocation from included in the
proposed project. There is no capacity in Lake Wylie for a Charlotte Mecklenburg Utilities
discharge facility on its own, based on the EPA approved 1996 Lake Wylie nutrient total
maximum daily load (TMDL) allocation. In addition, Mount Holly, Belmont and Clariant must
all submit formal permit modifications to confirm the transfers of flow and nutrient loading to
the proposed CMU Regional WWTP. Please recognize that speculative limits may change
based on future water quality initiatives, and it is highly recommended that the applicant
verify the speculative limits with the Division's NPDES Unit prior to any engineering design
work.
ReceivingS. Lake Wylie has a stream classification of WS-IV CA. Waters with this
designation are a source of drinking water supply, culinary or food processing purposes in
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.nmaterclualitv.oro
An Equal Opportunity ual 0 ortuni 1 Affirmative Action Employer NorthCarohna
atura y

Mr. Barry Shearin
June xx, 2013
Page 2 of 5
addition to the standard uses for waters with a C classification. This segment of the
Catawba River (Lake Wylie) is listed on the North Carolina 2012 Impaired Streams list for
low pH.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are not any Federally Listed threatened or endangered
aquatic species identified within a 5 mile radius of the discharge location. If there are any
identified threatened/ endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge might impact such species.
Speculative Limits. The speculative limits were developed based on Division staff
recommendation and consideration of the Lake Wylie TMDL allocation. Based on available
information, speculative effluent limits for the proposed discharge of 12 and 25 MGD to
Lake Wylie are presented in Tables 1 and 2. A complete evaluation of these limits and
monitoring requirements for metals and other toxicants will be addressed upon receipt of a
formal NPDES permit application.
CBOD5/NH3 Limits. The limits for CBOD5 and NH3 are based on best professional
judgment for the protection of instream dissolved oxygen through the assignment of tertiary
treatment limits. The CBOD limits of 4.2 mg/1 in the summer and 8.3 mg/1 in the winter are
effectively equivalent to BOD5 limits of 5 mg/I (summer) and 10 mg/1(winter). The year-
round NH3 limit of 1 mg/ 1 is assigned based on instream protection against ammonia
toxicity. fer9 .• %— - : --'.J
The dissolved oxygen effluent limit of 7 mg/l was
Nutrients. The nutrient loading for the three dischargers included in the CMU Regional
WWTP was combined to determine the total nutrient allocation for the proposed discharger.
The entire allocation for Mount Holly and Belmont will be included in the Regional facility.
While the Clariant facility has a total nitrogen (TN) allocation of 318.5 Ib/ day, only 90 % or
287 lb/day will be allocated to the CMU Regional WWTP. The same percentage of total
phosphorus (TP) will be allocated; therefore 36 Ib/ day of total phosphorus of 40 lb/ day will
be allocated. The nutrient limitations are consistent with the Lake Wylie nutrient TMDL
allocations and the contributed nutrient allocation for the three dischargers is below:
Discharger
TN Allocation
TP Allocation
Basis
Mount Ho ll
300 lb/ day
50 lb/ day
TMDL
Belmont
350 lb/ day
58lb/day
TMDL
Clariant
287 lb/ day
361b/ day
TMDL,
Nonpoint, BAT
Total
9371b/da
1441b/da
200,518 lb/summer
5 60lb/year
141,487 lb/winter
0-e* I Jl l vt�dvh
&IGlrl3 }'v,Pd dK
a A do tell c � a
0- U. I -eve IS',
Ue

Mr. Barry Shearin
June xx, 2013
Page 3 of 5
TABLE 1. Speculative Limits for CMU Regional WWTP, Proposed flow of 12.0 MGD
Effluent Characteristic
Effluent
Limitations
Monthly
Average
Weekly
Average
Daily
Maximum
Flow
12.0 MGD
CBODS, Summer
4.2 m /l
6.3 m /I
CBODS, Winter
8.3 mg/ 1
12.5 m /l
TSS
30 m /L
45 mg/ L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/L
Total Residual Chlorine
17 u / I
Fecal coliform (geometric
mean
200/ 100 ml
400/ 100 ml
Total Nitrogen (summer)1
200,518 lbs/ summer
Total Nitrogen (winter)1
141,487 Ibs/winter
Total Phos horus2
52,560 Ibs/ ear
Chronic Toxicity
Pass/ Fail(Quarterly test
90 %
1. The total nitrogen limit is equivalent to a 9.4 mg/ I annual average.
2. The total phosphorus limit is equivalent to a 1.4 mg/1 annual average.
TABLE 2. Speculative Limits for CMU Regional WI7P, Proposed flow of 25.0 MGD
Effluent Characteristic
Effluent Limitations
Monthly Average , ,X
Weekly
Avera e : "
Daily
Maximum
Flow
25.0 MGD
CBODS, Summer
4.2 m / I
6.3 m / I
CBODS, Winter
8.3 mg/1
L! •12.5 m /I
TSS
30 m / L
45 m / L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
minimum
7.0 mg/ L
Total Residual Chlorine
17 u /1
Fecal coliform (geometric
mean
200/ 100 ml
400/ 100 ml
Total Nitrogen (summer)1
200,5181bs/ summer
Total Nitrogen (winter)1
141,487 lbs/winter
Total Phos horus2
52,560 lbs/ ear
Chronic Toxicity
Pass/ Fail(Quarterly test
90 %
1. The total nitrogen limit is equivalent to a 4.5 mg/1 annual average.
2. The total phosphorus limit is equivalent to a 0.69 mg/1 annual average.

Mr. Barry Shearin
June xx, 2013
Page 4 of 5
Monitoring in Lake Wylie will also be required to ensure that the water quality model
predictions were accurate, and to ensure the discharge does not create adverse conditions in
the Lake in the future. CMU will be required to monitor upstream and downstream of the
outfall. The following parameters should be included in sampling: dissolved oxygen,
temperature, conductivity, pH, total phosphorus, total nitrogen and chlorophyll a. Instream
monitoring will be required three times per week during the months of June, July, August
and September and once per week during the rest of the year.
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee
that an NPDES permit for discharge of up to 25.0 MGD will be issued with these speculative
limits. Final decisions can only be made after the Division receives and evaluates a formal
permit 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. ki
Therefore, as a component of all NPDES permit applications for new or ex ding flow, a
detailed engineering alternatives analysis (EAA) must be prepared. The AA must justify
requested flows, and provide an analysis of potential wastewater trea ent alternatives.
Alternatives to a surface water discharge, such as a spray/drip irrigation wastewater reuse,
are considered to be environmentally preferable. A copy of the EAA
requirements is attached to this letter. Permit applications for new or expanding flow will
be returned 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
O� lands; and 3) might have a potential to significantly impact the environment. For new
waste er discharges, significant impact is defined as a proposed discharge of >500,000
gp roducing an instream waste concentration of > 33 % based on summer 7Q10
stre ow conditions.
Since CMU's facility is proposing a discharge
of >500,000 gpd flow the CMU facility 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 discharge 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 discharge is subject to SEPA, the
EAA requirements discussed above will need to be folded into the SEPA document. The
SEPA process will be delayed if all EAA requirements are not adequately addressed. If you
have any questions regarding SEPA EA/ EIS requirements, please contact Hannah Headrick
with the DWQ Planning Branch at [phone].

Mr. Barry Shearin
June xx, 2013
Page 5 of 5
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact Jackie Nowell at (919) 807- 6386.
Respectfully,
Tom Belnick
Supervisor, Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
Central Files
NPDES Permit File
Barry Gullet, CMUD Director 5100 Brookshire Blvd. Charlotte NC 28216
Brent M. Reuss/ Black & Veatch 8520 Cliff Cameron Drive Suite 210 Charlotte, N.C. 28269
Jeff Debessonet/SCDHEC 2600 Bull Street Columbia, S.C. 29201
Electronic Copy:
NC WRC, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, [e-mail]
DWQ/SWPS Mooresville Regional Office
DWQ/SEPA, Hannah Headrick
DWQ/Modeling TMDL Unit, Kathy Stecker
DWQ/Basinwide Planning, Jeff Manning
NPDES Server>Specs

Pat McCrory
Governor
4�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Thomas A. Reeder John E. Skvarla, III
Acting Director Secretary
June xx, 2013
Mr. Barry Shearin, Chief Engineer
Charlotte Mecklenburg Utilities
5100 Brookshire Blvd.
Charlotte, North Carolina 28216
Subject: Speculative Effluent Limits
Proposed CMU Regional WWTP
Mecklenburg County
Dear Mr. Shearin:
This letter is in response to your request for revised speculative effluent limits for the
proposed Charlotte Mecklenburg Utilities (CMU) Regional WWTP. Speculative limits in
September 2009 included the City of Mount Holly Wastewater Treatment Plant in
partnership with CMU for the proposed CMU Regional WWTP at the wasteflows of 17
MGD and 25 MGD. In January 2010, speculative limits included Mount Holly and Clariant
WWTP in partnership for the proposed CMU Regional Plant at 17 MGD and 25 MGD.
This latest speculative limits request now includes the City of Belm t, -alamr ud the City of
Mount Holly and Clariant as partners in the CMU Regional WWTP. requestecw steflows
,are 12 MGDand25 MGD. ese speculative limits
are only applicable if the nutrient allocation from 441f 1s included in the
proposed project. There is no capacity in Lake Wylie for a Charlotte Mecklenburg Utilities
discharge facility on its own, based on the EPA approved 1996 Lake Wylie nutrient total
maximum daily load (TMDL) allocation. In addition, Mount Holly, Belmont and Clariant must
all submit formal permit modifications to confirm the transfers of flow and nutrient loading to
the proposed CMU Regional WWTP. Please recognize that speculative limits may change
based on future water quality initiatives, and it is highly recommended that the applicant
verify the speculative limits with the Division's NPDES Unit prior to any engineering design
work.
ReceivingS. Lake Wylie has a stream classification of WS-IV CA. Waters with this
designation are a source of drinking water supply, culinary or food processing purposes in
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwaterguality.oro One
An Equal Opportunity l Affirmative Action Employer NorthCarolina
Nahmalloff

Mr. Barry Shearin
June xx, 2013
Page 2 of 5
addition to the standard uses for waters with a C classification. This segment of the
Catawba River (Lake Wylie) is listed on the North Carolina 2012 Impaired Streams list for
low pH.
Based upon a review of information available from the North Carolina Natural Heritage
Program Online Map Viewer, there are not any Federally Listed threatened or endangered
aquatic species identified within a 5 mile radius of the discharge location. If there are any
identified threatened/ endangered species, it is recommended that the applicant discuss the
proposed project with the US Fish and Wildlife Service to determine whether the proposed
discharge might impact such species.
Speculative Limits. The speculative limits were developed based on Division staff
recommendation and consideration of the Lake Wylie TMDL allocation. Based on available
information, speculative effluent limits for the proposed discharge of 12 and 25 MGD to
Lake Wylie are presented in Tables 1 and 2. A complete evaluation of these limits and
monitoring requirements for metals and other toxicants will be addressed upon receipt of a
formal NPDES permit application.
CBOD5/NH3 Limits. The limits for CBODS and NH3 are based on best professional
judgment for the protection of instream dissolved oxygen through the assignment of tertiary
treatment limits. The CBOD limits of 4.2 mg/1 in the summer and 8.3 mg/1 in the winter are
effectively equivalent to BOD5 limits of 5 mg/1(summer) and 10 mg/1(winter). The year-
round NH3 limit of 1 mg/1 is assigned based on instream protection against ammonia
toxicity.
Dissolved Oxygen. The dissolved oxygen effluent limit of 7 mg/I was based on the results
of the model run for the proposed Lake Wylie discharge. The model predicted effluent
dissolved oxygen of greater than 7 mg/1 at a wasteflow of 25 MGD.
p�
Nutrients. The nutrient loading for the three disc chargers_4neluded the MU Re 'on
P as combined to determine the total nutrient allocation for the proposed disel°rarger-
The entire allocation for Mount Holly and Belmont will be included in the Regional facility.
While the Clariant facility has a- total nitrogen (TN) allocation of 318.5 lb/day, only 90 % or
287 lb/day will be allocated to the CMU Regional WWTP. The same percentage of total
phosphorus (TP) will be allocated; therefore 36 lb/ day of total phosphorus of 40 lb/ day will
be allocated. The nutrient limitations are consistent with the Lake Wylie nutrient TMDL
allocations and the contributed nutrient allocation for the three dischargers is below :
Discharger
TN Allocation
TP Allocation
Basis
Mount Holly
300 lb/ da
50 lb/ day
TMDL
Belmont
350 lb/ day
58lb/day
TMDL
Clariant
287 lb/ day
361b/ day
TMDL.
Non oint BAT
Total
937 lb/da
144 lb/day
200,518 lb/summer
52560lb/year
141,487 lb/winter

Mr. Barry Shearin
June xx, 2013
Page 3 of 5
c
TABLE 1. Speculative Limits for CMU Regional WWTP, Proposed flow of 12.0 MGD
j �Sr ii" 3 K
rt s tt M yF�■ µ i
n
s 1 �Dazl3
...? >� +'^ f.4� t}r'�A� 3 •--t
S� � Y�� Q ��; �3X. �� f
...i t Qryt ^^.�S'�.'�+�yj�;y{S§?+.� �{
'�.
z �
..
� it'�'.
Flow
12.0 MGD
CBODS, Summer
4.2 m /l....
6.3 m /te-
CBODS, Winter
8.3 m /lL
12.5 m /L.--
TSS
30 m /L
45 m /L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
7.0 mg/ L
(minimum)
Total Residual Chlorine
17 u /I
Fecal coliform (geometric
200/ 100 nit..-
400/ 100 mt..-
mean)
Total Nitrogen (summer)1
200,518 lbs/ summer
Total Nitrogen (winter)1
141,487 lbs/winter
Total Phos horus2
52,560 lbs/ year
Chronic Toxicity
90 %
Pass/ Fail(Quarterly test
1. The total nitrogen limit is equivalent to a 9.4 mg/ 1 annual average.
2. The total phosphorus limit is equivalent to a 1.4 mg/I annual average.
TABLE 2. Speculative Limits for CMU Regional WW'I'P, Proposed flow of 25.0 MGD
�4�..J.L � f<A,.4� �..11•—.t ..
...:. " 4, � 32 { 3�T.
.at rFi 7 .fit st' .�'-i-
�,4§ i";s ! �t z ate n r
r—. i f
Mon
;s s i :t:;j r pp t ;dlx7
f 4-.x r -'s y.0
(,.' L x t s«
�::�:�f�a�a
� �-.- � T--- .,� ♦ �t -...�,- i, t ^3
R• it z
�n
! i�' a€'• �tF"�r, t Sts is 1 ,YY s.
h t,
_._ ".= a#
1 . ,.'�,��� �`
z
»�?p?� �4 ».f • i. "'°'i" t.
;t'?,", ti,3Y ;R"
,
}.r€°i . :r4{tn.:r' S
i
..
Flow
25.0 MGD
CBODS, Summer
4.2 m /I
6.3 mg/1
CBODS, Winter
8.3 m /l
12.5 m /l
TSS
30 m /L
45 mg/ L
NH3 asN
1.0m /L
3.0m /L
Dissolved Oxygen
7.0 mg/ L
minimum
Total Residual Chlorine
17 u /I
Fecal coliform (geometric
200/ 100 ml
400/ 100 ml
mean
Total Nitrogen (summer)1
200,518 Ibs/ summer
Total Nitrogen (winter)1
141,487 lbs/winter
Total Phosphorus-2
52,560 lbs/ year
Chronic Toxicity
90 %

Mr. Barry Shearin
June xx, 2013
Page 4 of 5
Pass/ Fail(Quarterly test)
1. The total nitrogen limit is equivalent to a 4.5 mg/l annual average.
2. The total phosphorus limit is equivalent to a 0.69 mg/1 annual average.
Monitoring in Lake Wylie w' o be required to ensure that the water quality model
predictions were accurat , d to ensure the discharge does not create adverse conditions in
the Lake in the future. CMU will be required to monitor upstream and downstream of the
outfall. The following parameters should be included in sampling: dissolved oxygen,
temperature, conductivity, pH, total phosphorus, total nitrogen and chlorophyll A. Instream
monitoring will be required three times per week during the months of June, July, August
and September and once per week during the rest of the year.
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee
that an NPDES permit for discharge of up to 25.0 MGD will be issued with these speculative
limits. Final decisions can only be made after the Division receives and evaluates a formal
permit 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 a spray/drip irrigation, wastewater reuse,
or inflow/infiltration are considered to be environmentally preferable. A copy of the EAA
requirements is attached to this letter. Permit applications for new or expanding flow will
be returned 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
streamflow conditions. For existing discharges, significant impact is defined as an
expansion of > 500,000 gpd additional flow. Since CMU's facility is proposing a discharge
of >500,000 gpd flow with an instream waste concentration > 33%, the CMU facility 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 discharge 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 discharge is subject to SEPA, the
EAA requirements discussed above will need to be folded into the SEPA document. The

Mr. Barry Shearin
June xx, 2013
Page 5 of 5
SEPA process will be delayed if all EAA requirements are not adequately addressed. If you
have any questions regarding SEPA EA/ EIS requirements, please contact Hannah Headrick
with the DWQ Planning Branch at [phone].
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact Jackie Nowell at (919) 807- 6386.
Respectfully,
Tom Belnick
Supervisor, Complex Permitting Unit
Attachment: EAA Guidance Document
Hardcopy:
Central Files
NPDFS Permit File
Barry Gullet, CMUD Director 5100 Brookshire Blvd. Charlotte NC 28216
Brent M. Reuss/ Black & Veatch 8520 Cliff Cameron Drive Suite 210 Charlotte, N.C. 28269
Jeff Debessonet/SCDHEC 2600 Bull street Columbia, S.C. 2M
Electronic Copy:
NC WRC, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, Sara,[e-mail]
DWQ/SWPS Mooresville Regional Office
DWQ/SEPA, Hannah Headrick
DWQ/Modeling TMDL Unit, Kathy Stecker
DWQ/Basinwide Planning, Jeff Manning
NPDES Server>Specs