NC0063096_Speculative Limits_19990202

NPDES DOCUMENT :;CANNING COVER SHEET
NC0063096
Holy Springs WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Meeting Notes
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
February 2, 1999
This document is printed oat reuse paper - igrxore ataxy
content on the resrerse side

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
February 2, 1999
Ms. Stephanie Sudano, P.E.
Town Engineer
Town of Holly Springs
P.O. Box 8
Holly Springs, North Carolina 27540
Subject: Speculative Limits for Utley Creek WWTP
NPDES No. NC0036096
Town of Holly Springs
Wake County
Dear Ms. Sudano:
This letter is to transmit speculative effluent limits for a possible expansion at the Utley
Creek wastewater treatment plant. This plant currently has a permit to discharge 1.5
MGD of treated domestic wastewater to Utley Creek in the Cape Fear River Basin in
Wake County. You advised Dave Goodrich of my staff that Holly Springs would
proceed with an amendment to its environmental assessment at 4.88 MGD to reflect a 20-
year flow projection.
The speculative limits presented here are based on our understanding of the proposal and
of present environmental conditions. The Division of Water Quality (DWQ) cannot
guarantee that it will issue the Town an NPDES permit to expand its discharge of treated
wastewater into waters of the State. Nor can we guarantee that the effluent limitations
and other requirements included in any permit will be exactly as presented here. Final
decisions on these matters will be made only after the Division receives and evaluates a
formal permit application for the Town's proposed discharge and provides the public an
opportunity to comment on a proposed permit.
Water Quality Issues Related to Utley Creek and Harris Lake
The Division has significant concerns about the level of nutrients entering Harris Lake
from your discharge. Utley Creek and the White Oak arm of the lake have experienced
excessive algal growth, eutrophication problems, and documented fish kills. Therefore,
one of the Division's primary goals for Harris Lake is to maintain or reduce nutrient
loads to the lake.
There has been a documented correlation between numerous instream chlorophyll -a and
dissolved gases (DO) water quality standard violations and the level of nutrients
discharged to Utley Creek by the Holly Springs WWTP. Forty percent of the instream
chlorophyll -a values collected by the town from 1997 to 1998 were above the water
quality standard of 40 ug/1. While the average value of all data was 39 ug/1, some values
were as high as 112 and 135 ug/1. Upstream and downstream nutrient data confirm that
the WWTP is the main source of the nutrient load. Additionally, eutrophic conditions
exist further downstream in the lake arm as documented by Carolina Power and Light
sampling efforts.
Recognizing that the WWTP is the only discharge in a relatively undeveloped watershed,
the Division intends to hold nutrient loads at existing levels until additional data is
P.O. Box 29535, RALEIGH, NORTH CAROLINA 27626.0535
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50 RECYCLED/1 O% POST -CONSUMER PAPER

Holly Springs 4.88 request
Speculative Limits
Page 2
collected. Additional loading would further compromise an already impaired system. In
addition, continued impairment may force the Division to institute limits that represent
nutrient loads below those currently being discharged.
The rate of growth in and around Holly Springs will exert increasing demands on the
water quality of the lake. Significant growth in Holly Springs will add both point source
and non -point source pressures. The Town should recognize that the present location on
Utley Creek may not be a viable long-term disposal option. The Division will require
continued evaluation of the impacts of this discharge on water quality in Utley Creek and
Harris Lake.
Environmental Assessments of New Projects and Expansions
Please be aware that you will have to evaluate this project for environmental impacts
before applying for a permit modification. Anyone proposing to construct new or
expanded waste treatment facilities using public funds or public (state) lands must first
prepare an environmental assessment (EA) when wastewater flows (1) equal or exceed
0.5 MGD or (2) exceed one-third of the 7Q10 flow of the receiving stream. DWQ will
not accept a permit application for a project requiring an environmental assessment until
the Division has approved the EA and sent a Finding of No Significant Impact (FONSI)
to the state Clearinghouse for review and comment.
The Environmental Assessment should contain a clear justification for the expanded
flow. It should provide a comprehensive analysis of potential alternatives to expansion,
including a thorough evaluation of non -discharge alternatives. Nondischarge alternatives
to expansion, such as spray irrigation, water conservation, and inflow and infiltration
reduction are considered to be environmentally preferable to a surface water discharge.
The following items should be thoroughly investigated and documented:
• Population data, growth, and flow justifications,
• Participation in a regional system, and
• Sharing a common effluent line to the Cape Fear River.
The EA should address effluent reuse, wastewater reduction efforts, land use restrictions,
I/I reduction, urban run off reductions, and wetlands restoration initiatives.
Finally the EA should document the discussions that Holly Springs has had with Cary,
Apex, Fuquay Varina and others with regard to various disposal options.
In accordance with the North Carolina General Statutes, the preferred alternative must be
the practicable waste treatment and disposal alternative with the least adverse impact on
the environment. If the EA demonstrates that the project may result in a significant
adverse impact on the quality of the environment, you must then prepare an
Environmental Impact Statement. The Water Quality Planning Branch can provide
additional information regarding the requirements of the N.C. Environmental Policy Act.
You can contact our EA coordinator, Ms. Gloria Putnam, directly at [phone], ext.
567.

Holly Springs 4.88 request
Speculative Limits
Page 3
Speculative Effluent Limits
Based on the available information, tentative limits for the proposed discharge to Utley
Creek at 4.88 MGD are attached in a draft effluent limits page format. The speculative
limits are explained below.
Flow Limits. The flow will be limited to 4.88 MGD as requested in previous submittals.
Detailed justification for this level of flow must be provided.
Nutrients: Total Phosphorus, Total Nitrogen.
In order to hold the total nutrient load to Utley Creek at existing levels at a flow of 4.88
MGD, monthly limits for Total Phosphorus and Total Nitrogen will be 0.2 mg/land 2.2
mg/1, respectively.
Please note, these concentrations represent a slight increase from total nutrient loads
based on effluent data from May 1996 to September 1997.
NH3-N. The 1.0/2.0 mg/1 (summer/winter) limits were based on the waste assimilating
capacity of the receiving stream at low flow conditions and represent best available
technology for this size facility.
TSS. The limits for total suspended solids are standard for secondary treatment of
municipal wastewater.
Fecal Coliform, pH. The limits for fecal coliform bacteria and pH are derived to protect
water quality in the receiving stream.
I trust this response offers sufficient guidance for the Town's proposed treatment plant
expansion. If you have any additional questions about these limits, feel free to contact
Steve Pellei at [phone], extension 516.
Sincerely,
A. Preston Howar . Jr.,
cc: Raleigh Regional Office
Point Source Branch
Central Files
NPDES Unit Files
Ford Chambliss, P.E.,
The Wooten Company
120 N. Boylan Ave.
Raleigh, NC 27603

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS speculative limits
NC0063096
Permit No.
During the period beginning after expansion to 4.88 MGD and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number
001. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIRE_1)1E • TS '~'-'"
,
)
M
Daily
Maximum
Measurement
Frequency
_<S I
I f :Type
Sample
Location*
.
Flow
4.88 MGD
Conti
uqus1
ReCortlmg
I or E
BOD, 5 day, 20°C (April 1 — October 31)2
5.0 mg/l
7.5 mg/l
Da
ly
�.:: bm osite
E, 1
BOD, 5 day, 20°C (November 1 - March 31)2
10.0 mg/I
15.0 mg/l
Da
lyi
Composite
E, I
Total Suspended Residue2
30 mg/l
45 mg/l
-
:
;;
Dal ,
Composite
E, I
NH3 as N (Apnl 1 - October 31)
1.0 mg/I
(,
j
Daily
Composite
E
NH3 as N (November 1 — March 31)
2.0 mg/l
,,
4,:
/
Daily
Composite
E
Dissolved Oxygen3
l'e .,
Daily
Grab
E
Dissolved Oxygen
°p,.
3/Week
Grab
U, pi
Chlorophyll -a
'=y, ��,
i
Weekly7
Grab
D
pH4�:�
,-:'
.
'
ai� .;:.��.:
Daily
Grab
E
Fecal Coliform (geometric mean)
200 1, 0 f
4
0 i 0O mi
Daily
Grab
E
Fecal Coliform (geometric mean)
uC
0 'I n:1
0 / 100 ml
3/Week
Grab
U, Di
.
Temperature
uC
l -
Daily
Grab
E
.
Temperature
m
.
3/Week
Grab
U, D1
Total Nitrogen (NO2 + NO3 + TKN) ..---- ..
• :.
=
2 2 mg/l
Weekly5
Y
Composite
P
E
Total Nitrogen NO + NO + TKN y-
9 ( 2 s ��
Weekly5
Grab
U, D
Total Phosphorus .--} .. y
0.2 mg/l
Weekly5
Composite
E
'
Total Phosphorusr.
Weekly5
Grab
U, D
Total Residual,C Io ne
17 pg/I
Daily
Grab
E
Conductiyity {_ „)
Daily
Grab
E
Conflict vity - --0 •
3/Week
Grab
U, Di
Chtoiij TTxi4ityg
fw-/ 1....--
Quarterly
Composite
E
Notes.
*ample locations: E - Effluent, I - Influent, U - Upstream in the pool formed immediately upstream of the instream flow weir, D - Downstream on the existing
dam structure in a location so as to avoid contact between the ground and the sample bottle.
Upstream and Downstream samples of Dissolved Oxygen, Temperature, Fecal Coliform, and Conductivity shall be collected three times per week during
the months of June through September and once per week during the remaining months of the year.
7 Chlorophyll -a shall be monitored weekly during the months June through September; during the remaining months of the year, no monitoring is required.
8 Total Residual Chlorine shall be monitored only if chlorine is added to the effluent.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
2 The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85% removal).
3 The daily average dissolved oxygen effluent concentration shall no be Tess than 6.0 mg/I.
4 The pH shall not be Tess than 6.0 standard units nor greater than 9.0 standard units.
Effluent and Instream monitoring for Total Nitrogen and Total Phosphorous shall be conducted on the same day.
e Chronic Toxicity (Ceriodaphnia) P/F at 90%; February, May, August, and November, See Part III, Condition F.

DIVISION OF WATER QUALITY
January 26, 1999
Memorandum
To: Coleen Sullins
Thru: Susan Wilso
r
From: Marcia Lieber - Vk
Subject: Summary of The Town of Holly Springs
SOC request
The Town of Holly Springs WWTP is currently permitted for 0.5 MGD with an expansion
flow to 1.5 MGD. The town requested to relax the permitted flow limit until July 1999,
when plant expansion to 1.5 MGD will be completed. The Town has also requested an
additional 194,400 gpd flow allocation under the order. The Town claims an order is
necessary to prevent the Division from seeking enforcement actions during wet weather
months. The facility did exceed the monthly average flow during the period of January
1998 through May 1998. The Town attributed inflow and infiltration as the significant
cause for violations of the monthly flow limit. However, the application doesn't address a
specific plan to identify and remove sources of I/I.
In spring of 1997, Holly Springs doubled the plant capacity from 0.25 MGD to 0.50
MGD. During a twelve month period (10/97-9/98), the average flow was 0.4759 MGD or
95% of the plant's hydraulic capacity. The flow the Division has issued through new
sewer permits is 0.509 MGD. The portion of flow outstanding is 0.424 MGD. It is likely
that the flow exceedances may be due to the Town's rapid growth rate, rather than I/I
problems. The Town states in the application the plant cannot meet limits for 1.5 MGD
until final construction is completed. The Town's proposed schedule for the order includes
only a proposed schedule for the plant expansion and does not address specific steps to
reduce I/I, other than to maintain its existing I/I control program.
The Regional Office recommends that the SOC application and fee be returned to the Town
and that an SOC not be issued at this time. The region staff have visited the site and
confirmed construction of the secondary filter, cascade aeration and UV disinfection are on
line. Also, the region staff confirmed construction has started on the new oxidation ditch
and the contractor is scheduled to complete his work in July. The PSC/EU recommends
denial of the order.

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HOLLY SPRINGS WWTP NC 0063096
AVERAGE FLOW(MGD) 10/97-9/98= 0.4716
PERMITTED FLOW (MGD) ANT=ALLOCATED BUT
1.5
PROJECT # PROJECT NAME
ceto
NOT TRIBUTARY (MGQ) 5 _�
044
FI.fQ\N(GPD) DATE RUNNING TOTAL(GPD) ANT
12239 SUNSET RIDGE PH 5D 5355 04/09/96 509340 2750
12242 ADVENT ACRES PH VI 28815 04/09/96 21035
12371 VILLAGE A ARBOR CREEK 14280 05/09/96 5269
12608 SUNSET RIDGE PH III 5355 06/28/96 1714
12639 WOODCLIF SUBD 10965 07/09/96 10965
12671 OAKHALL II SEC II 14790 07/22/96 9761
12941 SUNSET FARMS PH II 11475 09/30/96 4131
12974 SUNSET RIDGE N PH I 18360 10/08/96 7344
13069 WATER/SEWER IMP 5400 11/05/96 5400
13123 OAKHALL STORE 500 11/08/96 0
13486 ARBOR CREEK MORENE EXT 4590 03/04/97 0
13575 ARBOR CREEK CREEKSIDE 23205 03/17/97 23205
13681 OAKHALL PH VI&VII 18615 04/03/97 14334
13719 VILLAGE B ARBOR CREEK 28815 04/16/97 28815
13720 ARBOR CREEK PH 1-C 19125 04/16/97 19125
13730 OAKHALL BUSINESS CNT 2160 04/14/97 0
13958 MALMEDY DR ARBOR CR 2040 06/06/97 0-
13913 REMINGTON PH VII 1785 05/26/97 0
13966 VALLEYFIELD PH III 6630 06/09/97 6630
14435 SOMERSET FARM PH III 17595 09/18/97 13724
14317 BLUFF ARBOR SEC K2 22320 09/05/97 17186
14322 SUNSET RIDGE PH VII 20145 08/28/97 18533
14321 SUNSET RIDGE PH 6B 5610 08/28/97 4656
14216 LOT 179 ARBOR CREEK 4980 08/01/97 0
14693 FAIR HILL SUBD 17085 11/19/97 17085
14627 RUTHERFORD PUD PHI 10710 11/06/97 10710
14548 HOLLY GLEN PH V 5610 11/04/97 3086
14547 HOLLY GLEN PH IV 9180 10/29/97 9180
14969 BRAXTON VILLAGE 26265 02/13/98 26265
14938 HOLLY PARK PH 4 4500 02/04/98 2610
14693 FAIRHILL SUBD 17085 11/19/97 17085
14938 HOLLY PARK PH IV 4500 02/09/98 4500
15115 SUNSET RIDGE N PUD PH2 15810 03/19/98 12964
15284 COUNTRY LANE SUBD PH II 2805 05/01/98 2805
15377 LAKESIDE SUBD PH II 3570 05/26/98 3570
* RE • : iL'ED 6/15/98
RUNNING TOTAL FLOW REMAINING(GPD)
423747. 604653
*
Wup,` - \rtYG/ 101/3
7_, tv\l \Ce,PACA-L'AI Y\)

r
15419 TRELLIS POINT APTS 34560 02/12/96
15448 wake co. firearms and rec. 1250 09/14/98
15852 parkside vill. phase 1 5865 09/16/98
15851 valleyfield sub. ph. 4,5,&6 28815 09/15/98
15923 sunset ridge business center 2400 10/07/98
16029 sunset ridge north pud ph3 16320 10/21/98
15973 lot e, arbor creek 5000 10/22/98
16105 lot e arbor creek pud 5100 11/10/98
34560
1250
5865
28815
2400
16320
5000
5100

DIVISION OF WATER QUALITY
December 17, 1998
MEMORANDUM
To: Susan Wilson
NPDES Compliance Group
Through: Ken Schuster
Regional Supe.'isor
From: Kirk Stafford 5
Environmental Chemist
Subject: Town of Holly Springs SOC request
NPDES Permit No. NC0063096
Wake County
The Town of Holly Springs requested an SOC to suspend the subject
permit's flow limit of 0.5 MGD. The Town states that infiltration
and inflow are expected to cause the treatment plant to exceed the
permitted flow during wet weather. A review of the DMR's for the
period November 1997 through October 1998 indicated an average flow
of 0.4759 MGD or 95%. The facility did exceed the monthly flow
during January 1998 through May 1998. The outstanding flow issued
through sewer line permits issued by the Division to the Town
totals 0.423747 MGD. This could possibly cause the facility to
discharge 0.899647 MGD. The facility is currently under expansion
but is not slated for completion for a few years. The Raleigh
Regional Office recommends that the SOC application and fee be
returned to the Town and that an SOC not be issued at this time
because it has not been proven that the SOC would address I&I
alone.

under construction, to be completed.
November 9, 1998
Mr. A Preston Howard, Jr., P.E., Director
NCDENR--Division of Water Quality
PO Box 29535
Raleigh, NC 27626-0535
Re: SOC Application
Town of Holly Springs, Wake County
Dear Mr. Howard:
g° iggt`
0
OF S cOCA-
The Town of Holly Springs requests a Special Order by Consent that would temporarily
suspend our NPDES Permit flow limit. Infiltration and inflow are expected to cause the
Town's wastewater treatment plant flows during wet weather to exceed the NPDES Permit
limit. The Town requests the SOC to allow time for a $4.5 million expansion plan, now
c,
Enclosed please find three (3) copies of the application package along with a $400 check
for the processing fee. The application package includes the following:
(1) Completed SOC Application with attachments
(2) SOC Application Resolution
(3) $400 check to cover the processing fee
If you have any questions regarding this SOC application, please contract the Town (919-
557-3938) or Mr. Eric Tweed of the Wooten Company (919-828-0531). Your assistance
in this matter is appreciated.
Sincerely,
14-‘---
Gerald W. Holleman, ayor/Town Administrator
Enclosures
cc: The Wooten Company
Bob Sledge, DENHR
10583
OFFICE OF THE MAYOR
P.O. Box 8. 128 S. Main Street • Holly Springs, N.C. 27540 • [phone]
try
c•
t(1h i
jGUr-r

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
APPLICATION FOR A SPECIAL ORDER BY CONSENT
(INFORMATION REQUIRED FOR FACILITIES REQUESTING AN SOC)
I. GENERAL INFORMATION:
1. Applicant (corporation, individual, or other): Town of Holly Springs. North Carolina
2. Print or Type Owner's or Signing Official's Name and Title (the person who is legally
responsible for the facility and its compliance): Gerald W. Holleman
Mayor. Town of Holly Springs
3. Mailing Address: PO Box 8.
City: Holly Springs State: NC Zip: 27540-0068
Telephone No.: ( 919 ) 552-6221
4. Facility Name (subdivision, facility, or establishment name - must be consistent with
name on the permit issued by the Division of Environmental Management):
Utley Creek Wastewater Treatment Plant
5. Application Date: October 1998
6. County where project is located: Wake
11. PERMIT INFORMATION FOR THE FACILITY REQUESTING THE SOC:
1. Permit No.: NC0063096
2. Name of the specific wastewater treatment facility (if different from I.4. above):
3. Issuance Date of Permit: March 1. 1997
4. Expiration Date of Permit: March 31. 2001
5. Attach a listing of all effluent parameters addressed in the permit, including
limitations and monitoring requirements.
See ATTACHMENT A for required information
III. COMPLIANCE HISTORY FOR FACILITY REQUESTING THE SOC:
Please attach a listing of all SOC(s) and amendments, judicial Order(s) and amendments, EPA
309 letter(s), EPA Administrative Order(s), civil penalty assessment(s), notices of violations(s),
etc. issued for this facility during the past 5 years. This listing must contain the issue dates,
reasons for issuance, when the facility returned to compliance and actions taken to return the
facility to compliance.
See ATTACHMENT A for required information
FORM: SOCA 10/91 Page 1 of 5

PAGE 2 (10/91)
SOC REQUEST
IV. EXPLANATION AS TO WHY SOC IS NEEDED:
Please attach a very specific detailed explanation as to why the SOC is being requested.
Please address the following issues:
1. Existing or unavoidable future violation(s) of Permit Limitation(s)
2. Existing or unavoidable future violation(s) of Permit Condition(s)
3. Magnitude, duration and date(s) of all existing Violations
4. Explanation for any existing or unavoidable future violation(s) along with any
mitigating factor(s)
5. Expected duration of any existing or unavoidable future violation(s)
See ATTACHMENT A for required information
V. EXPLANATION OF ACTIONS TAKEN BY THE APPLICANT TO MAXIMIZE THE
EFFICIENCY OF THE FACILITY PRIOR TO REQUESTING THE SOC:
Please attach a very specific detailed explanation of the actions taken.
Please address the following issues:
1. Describe the existing treatment process and any modifications that have been made in
an effort to correct and avoid violations of effluent limitations.
2. Changes made to facility operations such as use of polymers, more frequent wasting
of solids, additional aeration, additional operators, etc.
3. Collection system rehabilitation work completed or scheduled (including dates)
4. Coordination with pretreatment facilities for municipalities or production facilities for
industries. Identify any noncompliant significant industrial users and measure(s)
taken or proposed to be taken to bring the pretreatment facilities back into
compliance.
5. If the SOC is being requested for failure to meet permit effluent limitations, the
applicant must submit a report prepared by an independent consultant (a professional
with expertise in wastewater treatment) or by the Municipal Compliance Initiative
program of the Construction Grants and Loans Section of the Division of
Environmental Management. This report must address the following:
a. An evaluation of all existing treatment units, operational procedures and
recommendations as to how the efficiencies of these facilities can be
maximized.
b. A certification that these facilities could not be operated in a manner that would
achieve compliance with final permit limitations.
c. The effluent limitations that the facility could be expected to meet if operated at
their maximum efficiency during the term of the requested SOC (Be sure to
consider interim construction phases listed in section VI.4. of this application).
6. Any other actions taken to correct problems prior to requesting the SOC.
See ATTACHMENT A for required information
FORM: SOCA 10/91 Page 2 of 5

PAGE 3 (10/91)
SOC REQUEST
VI. REQUESTED TIME SCHEDULE TO BRING THE FACILITY INTO COMPLIANCE
WITH ALL PERMIT CONDITIONS AND STATE REGULATIONS/STATUTES:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule must include interim dates as
well as a final compliance date. The schedule should address such activities as:
1. Request any needed permit(s).
2. Submit plans, specifications and appropriate engineering reports to DEM for review
and approval.
3. Begin construction.
4. Occurrence of major construction activities that are likely to effect facility
performance (units out of service, diversion of flows, etc.).
5. Complete construction.
6. Achieve compliance with all effluent limitations.
7. Complete specific Infiltration/Inflow work.
8. Have all pretreatment facilities achieve compliance with their pretreatment permits.
9. Conduct needed toxicity reduction evaluations (TRE).
See ATTACHMENT A for required information
VII. IDENTIFY FUNDING SOURCES TO BE USED TO BRING THE FACILITY INTO
COMPLIANCE:
The applicant must provide an explanation as to the sources of funds to be utilized to
complete the work needed to bring the facility into compliance. Possible funding sources
include but are not limited to loan commitments, bonds, letters of credit, block grants and
cash reserves. This explanation must demonstrate that the funds are available or can be
secured in time to meet the schedule outlined as part of this application.
See ATTACHMENT A for required information
VIII. REQUEST FOR ADDITIONAL FLOW:
Only facilities owned by a unit of government may request to add additional flow to the
treatment system as part of the SOC in accordance with NCGS 143-215.67(b). If a request is
made, it must contain the following information:
1. If domestic wastewater flow is requested for residential and commercial growth, a
justification must be made as to the flow being requested. This flow request must be
based on past growth record, documented growth projections, annexation plans,
specific subdivision commitments, etc. The justification must include a listing of all
proposed development areas and associated flows. The total additional domestic flow
that is needed during the term of this requested order is 194.400 gallons per day.
FORM: SOCA 10/91 Page 3 of 5

PAGE 4 (10/91)
SOC REQUEST
2. If nondomestic flow is requested, a justification must be made based on actual
commitments from the industry. Copies of these commitments (such as building
permits) must be included as part of the application. Nondomestic flow is only
allowable when its strength and volume can be demonstrated to be such as to not
adversely impact the wastewater treatment system, limit the ability to dispose of/utilize
the sludge/residuals and be similar to domestic wastewater for all parameters that are
relaxed as part of the requested SOC. This level of strength can be either prior to
pretreatment or after pretreatment if the applicant is requiring the industry to meet the
pretreated levels. The application must contain a detailed analysis of all parameters
that can reasonably expected to be contained in the proposed industrial wastewater.
The total nondomestic flow that is requested during the term of this order is 0
gallons per day. A completed breakdown of the business/industries and the requested
flow for each must be attached.
3. The total flow requested as part of the SOC application (both domestic and
nondomestic) is 194,400 gallons per day.
See ATTACHMENT A for required information
Please be advised that the actual additional flow, if any, that could be allowed as part of the
requested SOC will be determined by a complete analysis of any projected adverse impact
that could be expected as the result of this additional wastewater on the wastewater
treatment facility and the surface waters.
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF
ENVIRONMENTAL MANAGEMENT UNLESS ALL OF THE APPLICABLE ITEMS
ARE INCLUDED WITH THE SUBMITTAL
Required Items
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments. If the SOC request is for a city/town or
county, the applicant must submit a copy of a resolution (example attached) from the
city council or the county commissioners authorizing the person signing the order to
do so. This resolution must clearly state that the council or commission is aware of
the financial commitment that is necessary to bring the facility into compliance. If
the applicant is a company, the person signing the applications must be an upper
management company official.
FORM: SOCA 10/91 Page 4 of 5

PAGE 5 (10/91)
SOC REQUEST
b. The nonrefundable SOC processing fee of $400.00. The check must be made payable
to The Department of Environment, Health and Natural Resources.
Applicant's Certification:
I, Gerald W. Holleman . attest that this application for an SOC has been
reviewed by me and is accurate and complete to the best of my knowledge. I understand that if all
required parts of this application are not completed and that if all required supporting information
and attachments a not included, this application package will be returned as incomplete.
Ct) Yi/ti
Signature
Date //- 3- 9f
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING
INFORMATION AND MATERIAL, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
FACILITY ASSESSMENT UNIT
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 27626-0535
TELEPHONE NUMBER: 919/733-5083
FORM: SOCA 10/91 Page 5 of 5

ATTACHMENT A
TOWN OF HOLLY SPRINGS, NORTH CAROLINA
SOC Request Attachments
II. PERMIT INFORMATION FOR THE FACILITY REQUESTING THE
SOC:
The Town of Holly Springs Wastewater Treatment Facility operates under NPDES
Permit No. NC 0063096, issued March 1, 1997 and set to expire March 31, 2001.
The effluent parameters that are currently permitted include:
Effluent Parameter
Summer
Permit Limit*
Winter
Permit Limit*
Monitoring
Frequency
Flow***
0.50 MGD
0.50 MGD
Continuous
BOD5
16.0 mg/L
24.0 mg/L
3/Week
TSS
30.0 mg/L
30.0 mg/L
3/Week
NH3-N
2.0 mg/L
4.0 mg/L
3/Week
Dissolved Oxygen
-
-
3/Week
Fecal Coliform
200.0/100 mL
200.0/100 mL
3/Week
Total Residual Chlorine
-
**19 ug/L
3/Week
Total N
-
-
Weekly
Total P
-
-
Weekly
Temperature
-
-
Daily
Chronic Toxicity
-
-
Quarterly
* Monthly Average **Daily Average
*** Note: Permit allows increase to 1.5 MGD upon completion of the plant
expansi. The plant expansion is now under construction. This request asks that the
0.5 limit be suspended until that construction is completed and the 1.5 MGD limit
becomes effective.
III. COMPLIANCE HISTORY FOR FACILITY REQUESTING THE SOC:
The Town has experienced past effluent violations which have led to Notice of
Violations (NOVs) being issued by the NCDENR-DWQ Raleigh Regional Office.
Many of these incidents occurred during periods of inclement weather including
heavy rain.
The following is a chronological list of NOVs given within the previous five years.
NOTICE OF
VIOLATION
5/9/94
5/16/94
Ammonia violation for the month of February 1994.
Ammonia, BOD, TSS, and Fecal Coliform violations given for the
Town of Holly Springs ATTACHMENT A Page 1

month of March 1994.
7/12/94 Ammonia violation for the month of May 1994.
8/29/94 Ammonia violation for the month of June 1994.
10/17/94 Ammonia violation for the month of August 1994.
12/5/94 Ammonia violation for the month of July 1994.
12/19/94 Ammonia violation for the month of October 1994.
2/27/95 Fecal Coliform violation December 1994.
3/13/95 Fecal Coliform violation January 1995.
4/24/95 Fecal Conform, ammonia, and TSS violation for February 1995.
9/5/95 Fecal Coliform violation June 1995.
11/21/95 Ammonia violation for the September 1995.
2/26/96 Fecal Coliform violation November 1995.
3/11/96 Fecal Coliform violation December 1995.
4/22/96 Ammonia violation for February 1996.
6/17/96 Fecal Coliform and ammonia violation for April 1996.
8/12/96 Fecal Coliform and ammonia violation for May 1996.
9/13/96 Fecal Coliform violation for June 1996.
11/19/96 Fecal Coliform violation for August 1996.
1/23/97 Assessment of Civil Penalties for Violation(s) of N.C. General
Statute(s) 143-215.1. Issued for above violations.
3/11/97 Fecal Coliform violation for December 1996.
4/7/97 Fecal Coliform and ammonia violation for January 1997.
9/12/97 NOV given for failure to sign daily logbook prior to August 1997.
9/15/97 Flow violation for July 1997.
10/23/97 Notice of Deficiency for failure to submit August 1997 quarterly
toxicity monitoring report.
3/2/98 - Flow violation for January 1998.
5/4/98 Flow and Fecal Coliform violation for March 1998.
3/30/98 `Flow violation for February 1998.
6/3/98 Flow violation for April 1998.
7/7/98 —Flow violation for May 1998.
The Town of Holly Springs has taken steps to correct these violations. The original
plant was expanded to 0.5 MGD and UV disinfection added. The plant has used
improved maintenance and training on the UV system to control conform violations.
In addition, the Town has conducted more training to better familiarize employees
with all treatment equipment and operations resulting in better overall performance.
Smoke testing of the collection system has been done to try to locate any possible
sources of inflow into the sewers. Town building inspectors have been instructed to
be particularly watchful for sewer line connections and manhole covers left open by
contractors.
The plant expansion, now under construction, will include a large UV system that
should more reliably stop the Fecal Coliform violations. This UV system has been
purposely rushed to be completed and placed online well before the rest of the plant is
finished. Other components of the plant, such as the post aeration and filters were
also designed to be finished earlier so that the plant may fair better against the weather
during the winter months. The expansion will also stop the flow violations as the
permit limits will be increased to 1.5 MGD once the expansion is completed.
The completion of the new secondary clarifier in November 1998 coupled with the
earlier (October 1998) completion of the tertiary filter, UV disinfection, and cascade
Town of Holly Springs ATTACHMENT A Page 2

post aeration units will allow the plant to hydraulically accept higher flows. These
improvements will enable the plant to handle the requested additional flow amounts.
Although the existing plant is obtaining good treatment levels, with BOD loading at
only 19% of the allowable and ammonia nitrogen at 4% of the allowable loading the
additional construction to be completed as of the end of November will allow
increased treatment capabilities. The new limits as contained in the 1.5 MGD
expansion permit cannot be fully achieved until all the construction is completed.
These final construction activities are scheduled to be completed before July 1999.
Until the construction is completed the Town requests that it be allowed to accept up
to 194,400 gallons per day of additional flow under this SOC and that the existing
permit limits apply until the final construction is completed.
IV. EXPLANATION AS TO WHY SOC IS NEEDED:
The Town has experienced flow violations that exceed their permit limits of 0.5 MGD
in wet weather conditions. These violations are expected to reoccur during the winter
season when infiltration and inflow conditions are worst. The Town has begun the
process of expanding its facilities to encompass more flow and will be permitted to
handle 1.5 MGD. This will end the flow violations the plant has been receiving
during the inclement months of winter. However, the plant expansion will not be
completed before this winter and more flow violations of the existing 0.5 MGD plant
are expected this winter.
With this in mind, an SOC, which would waive the permitted flow limit and allow the
Town to accept up to 194,400 gallons of additional flow, is requested in order to
allow the Town time to complete the treatment plant expansion now under
construction. The Town will continue to enforce its infiltration and inflow control
program during (and beyond) the period of the SOC.
V. EXPLANATION OF ACTIONS TAKEN BY THE APPLICANT TO
MAXIMIZE THE EFFICIENCY OF THE FACILITY PRIOR TO
REQUESTING THE SOC:
The Town has already taken action to bring the plant into compliance. Advertisements
for bids has already been posted and the bids received. Construction began on June 3
of this year. The expanded tertiary filters, UV system and post aeration system will
be online before the end of October of this year. The construction of the new clarifier
is being accelerated and should be finished in November. The new unit processess
should enable the plant to accept flows in excess of 0.500 MGD without violating the
present permit limits for parameters other than flow.
VI. REQUESTED TIME SCHEDULE TO BRING THE FACILITY INTO
COMPLIANCE WITH ALL PERMIT CONDITIONS AND STATE
REGULATIONS/STATUTES:
1) Advertisement for bids made December 21, 1997. pn F
2) Bids received February 5, 1998. y L/r
3) Construction began on plant expansion on June 3, 1998.
4) Complete construction of expansion: July, 1999.
Town of Holly Springs ATTACHMENT A Page 3

VII. IDENTIFY FUNDING SOURCES TO BE USED TO BRING THE
FACILITY INTO COMPLIANCE:
The Utley Creek WWTP expansion is being financed through the U.S. Department of
Agriculture RDA grant and loan program.
VIII. REQUEST FOR ADDITIONAL FLOW:
An total additional domestic flow allowance, during the term of this requested order,
of 194,400 gallons per day (gpd) is requested. This figure represents the expected
increase in wastewater flow from residential growth. Usage estimates, broken down
by type, are calculated as follows:
Residential
The residential growth estimated during the time scheduled for the Utley Creek
Plant expansion consists of 60 connections per month. It is estimated that the
average number of bedrooms for these connections is three (3). The standard
wastewater allowance per bedroom is 120 gal/day. The following is the calculation
for additional residential flow.
60 Building Connections/mo. * 3 Bdrms/Building * 120 gal/Bdrm/d * 9 mo.
=194,400 gallons/day of additional flow.
Industrial
There is no expected industrial flow increase.
TOTAL
The total additional domestic flow increase expected during the SOC period is
194,400 gallons/day.
Town of Holly Springs ATTACHMENT A Page 4

TOWN
illy
OF
rings
Resolution No.: 98-34
Date Adopted: Nov. 3, 1998
I certify this to be a
true copy oythe original.
•
ewn Clerk Holly Springs, NC
RESOLUTION FOR A SPECIAL ORDER BY CONSENT
WHEREAS:
WHEREAS:
WHEREAS:
WHEREAS:
WHEREAS:
The Town of Holly Springs has a permit to discharge wastewater to
Utley Creek in the cape Fear River Basin; and
This discharge is allowed under NPDES Permit No. NC0063096
effective 03/1/97, and scheduled to expire on 03/31/01; and
The Utley Creek Wastewater Treatment Plant is expected to
experience flows greater than the amount permitted entering the plant;
and
The Town of Holly Springs has initiated a plant expansion to increase
its capacity to 1.5 MGD; and
It is deemed in the best interests of the Town of Holly Springs to
request and enter into a Special Order by Consent while the expansion
is being constructed; and
WHEREAS: The Town of Holly Springs agrees to maintain and operate the
wastewater treatment system at its maximum level of efficiency during
the interim period of the Special Order and thereafter; and
WHEREAS: The Town of Holly Springs hereby authorizes Gerald W. Holleman,
Mayor, and successors so titled, to have the authority to sign and
execute the Special Order by Consent on behalf of the Town; and
OFFICE OF THE MAYOR
P.O. Box 8.128 S. Main Street • Holly Springs, N.C. 27540 • [phone]

THEREFORE, BE IT RESOLVED that the Town of Holly Springs requests a
Special Order by Consent from the Environmental Management Commission and
the Town hereby authorizes Gerald W. Holleman, Mayor, and successors so
titled, to sign and execute this document on behalf of the Town.
Adopted this 3A day of , 1998.
Gerald W. Holleman, Mayor
(ATTESTED)
ni Smith, Town Clerk

0 FY
THE TOWN OF
7ly prings
August 11, 1998
A. Preston Howard, Jr. P.E.
Director, Division of Water Quality
PO Box 29535
Raleigh, NC 2726-0535
Dear Mr. Howard:
This correspondence is to request your attention and assistance concerning a very
critical issue to the Town of Holly Springs. As you are aware, our area of Wake County is
under enormous growth pressures. The Town's population has grown from less than 2000
in 1988 to over 6600 in 1998. With this substantial increase in our population we are
working hard to ensure adequate wastewater capability exists to meet the growth
demands as well as protect water quality. Over the past five years I have had numerous
meetings with your staff to discuss our wastewater treatment needs for the Town. In
several meetings with Steve Tedder, former Section Chief of the Water Quality Section,
we were encouraged to extend our planning horizons and to tailor our future requests for
wastewater expansions to incorporate at least a 20-year growth projection. As we have
evaluated our current and future needs we have attempted to follow the path we thought
was the recommendation of the Division.
Our community is the fastest growing community (natural growth) in North
Carolina. The current population of Holly Springs is 6600, with a projected population of
25,000 in 10 years, and 70,000 in 20 years.
In January of 1997, we received a permit to expand our current wastewater facility
from 0.5 MGD to 1.51MIGD. As we made the application in 1996 for this expansion, we
requested a flow of 4.88 MGD, which was based on our knowledge of projected growth
in the area. We feel such future planning is appropriate from a long range planning
perspective and does not put us in the position of requesting small expansions on a
routine basis which is costly to the Town and also affects your permitting resources to
handle our applications. As the permit was issued in 1997 for a flow of 1.5 MGD it also
required very restrictive permit limitations of advanced tertiary treatment. We take pride
in our abilities to handle our wastewater effectively and the monitoring will support that
we treat the wastewater to levels far below what has been in our permits. For example,
our BOD limits have been 16.0 mg/l and we routinely treat to levels of 3.0 mg/l. The
same with our ammonia which was permitted at 2.0 mg/1 and yet we routinely treat to
levels of 0.2 mg/1. As you can see, we do take the handling and processing of our
wastewater very serious here in the Town of Holly Springs.
Although we disagreed with the flow limitation of 1.5 MGD at the time of permit
issuance, we were placed in a position of accept due to the diminishing flow availability
at the facility. Our current average flow is around 447,300 gpd and we have allocated an
OFFICE OF THE MAYOR
P.O. Box 8. 128 S. Main Street • Holly Springs, N.C. 27540 • [phone]

additional 411,110 gpd of the future expansion. This, even now, only leaves us with
approximately 640,000 of flow, which at current growth rates will be depleted within
three years. So I hope you can understand our concerns and our need to try and address
the wastewater issues of the Town in a more long-range fashion.
With the flow situation facing us as described previously, we have expedited the
construction of the 1.0 MGD expansion that was approved. Also, in early 1998, we again
requested speculative limits for additional flow expansions up to a total of 4.88 MGD.
These speculative limits were needed to allow our consultants and engineers to plan and
project the cost of such expansion activities. After some considerable delay we received
a letter from David Goodrich dated July 13, 1998, that provided the speculative limits but
only for a total flow of 2.5 MGD. Again, based on our population projections this
additional 1.0 MGD would only serve the town for approximately 4.5 years. To enable
us to obtain financing and to pay off the loans for these activities it is essential that we be
able to plan for a more extended period than five to seven years.
The letter from Mr. Goodrich mentioned that we would need to amend the EA
that we completed only a short time ago and we know that is a requirement. His letter
also stressed clear justification for the expanded flow, which we will and have done
previously and will repeat again. The letter also indicated we must explore alternatives,
which again we have done, to exhaustive lengths over the past four years with no success.
The letter then discusses nutrient concerns as the rationale for the flow limit of 2.5 MGD.
Although the current levels of nitrogen and phosphorus are not as low as we would like to
achieve, the new construction underway will be designed to address these nutrients. The
receiving stream, Utley Creek, is not classified as nutrient sensitive nor is White Oak
Creek which Utley converges with some 3.5 miles below our outfall nor is Harris Lake
some 10.0 miles below our outfall.
A staff report dated January 1997, mentioned that nutrient concerns for Harris
Lake to be the main issue for the Holly Springs WWTP. CP&L monitoring in 1995
indicated a chlorophyll level of 37.6 mg/1 in the White Oak arm of the Lake. White Oak
Creek encompasses over 70 square miles of drainage area at this entrance to Harris Lake.
Based on my understanding from talking to experts, such a measurement could not be
attributed to our discharge some 10 miles upstream and with flows of less than 200,000
gpd in 1995.
Even with our questions as to our impact to Harris Lake, we are taking actions to
reduce the nutrient levels in our effluent. We also see the possibilities of employing some
natural wetland areas downstream to further enhance the removal of nutrients prior to
Harris Lake. As you can see, we are willing to address any reasonable and supportable
concern and will continue to do so in the future.
What we ask, is that we be allowed to incorporate careful land use and growth
planning for the future of Holly Springs. To do that we request again, speculative limits
for a total flow of 4.88 MGD. This will allow our staff and their support folks to

appropriately address the EA amendments, as well as, addressing the application once the
EA amendment is completed.
Mr. Howard, we appreciate your time considering this matter and fully recognize
the excellent work your staff does under situations of intense scrutiny by others and with
staffing limitations that only the legislature can address. We do feel our request is
justified and these actions will dictate the future of the Town of Holly Springs.
Sincerely,
Gerald W. Holleman, Mayor
lira
cc: Tommy Stevens
r
Colleen Sullins
Henry Lancaster
Stephanie Sudano-