NC0063096_Speculative Limits_20001011

NPDES DOCUMENT :SCANNING 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:
October 11, 2000
This document is prizzted on reuse paper - igzore arty
corttertt orz the rezrerse side

World
Class
Region
TRIANGLE J COUNCIL OF GOVERNMENTS
October 11, 2000
Honorable Bill Holman, Secretary
N. C. Department of Environment & Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Dear Bill:
DEE FREEMAN
Executive Director
riti.
(6).
Recently the city and county managers from affected local governments in Region J
met to follow up on the matter of plans for a regional water reclamation facility on
the Cape Fear River. This meeting was in response to our August meeting in Apex
at which both you and I addressed this topic. As a result of our managers meeting,
consensus was reached on a strategy working toward the regional forum mentioned
in Apex, and it was determined that the managers would jointly request from your
office the assistance offered to advance the planning process.
I am currently working with your secretary/assistant to set an appointment whereby
Pat Davis, from my office, and I can visit with you to discuss the managers'
consensus. In order that we might save time, I have enclosed a letter signed by each
of the referenced managers setting forth the local governments' request. Pat and I
look forward to the opportunity to meet with you to discuss the details of this letter
and the need to move ahead with plans for the forum and plans for the new facility.
Thank you for your time and attention to this correspondence. I trust we will be able
to meet soon and that the information contained herein is clear and understandable.
Feel free to give me a call (558-9395) should you have any questions.
Sorely yours,
Dee Freeman
Executive Director
DAF/
REC ;:ua .fE
OCT 1 3 000
TOWN r.:,.,.... ,.,-�
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World
Class
Region
TRIANGLE J COUNCIL OF GOVERNMENTS
October 4, 2000
The Honorable Bill Holman, Secretary
N. C. Department of Environment & Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
4222 Emperor Boulevard • Durham, NC 27703
Mailing Address: P.O. Box 12276
Research Triangle Park, NC 27709
919.549.0551 FAX [phone]
Dear Secretary Holman:
We are writing to jointly express our sincere appreciation to you for participating in the August
22, 2000 meeting concerning the potential Cape Fear regional water reclamation facilities
project. We are also writing to briefly update you on the status of inter -local discussions and to
request your further assistance with this important effort.
As you are aware, several local governments in Region J have near -term needs to develop
additional wastewater treatment capacity in the Cape Fear River Basin to meet the long-term
wastewater service needs of their respective jurisdictions, and to mitigate inter -basin water
transfer concerns. You have expressed your strong support for a collaborative regional approach
to meeting these needs, and stated your commitment that the Department of Environment and
Natural Resources (NCDENR) will provide assistance with such an approach.
Since the August 22nd meeting, we have developed a project work plan that includes the
following major tasks:
1. Development of a discussion paper with your staff that outlines the key environmental issues
to be considered and addressed during the environmental impact evaluation and mitigation
planning phase. It is essential that NCDENR participate actively in this task and agree to the
scope of the environmental impact assessment and mitigation planning effort. A possible
outcome of this task will be a memorandum of understanding between the local government
project partners and NCDENR that describes the scope of the environmental assessment and
mitigation planning effort.
2. Development of a discussion paper that: (a) outlines the institutional structure and control
issues; (b) provides examples of how other regional approaches have successfully addressed
these issues; (c) examines alternative approaches; and (d) possibly includes preliminary
recommendations concerning the structure and control issues.
g��

t
1
Secretary Bill Holman
October 4, 2000
Page Two
3. Facilitated meetings through which local officials will try to reach agreement on the
institutional framework, financing plan, and environmental impact mitigation planning and
implementation strategy. The two discussion papers will provide important supporting
information and serve as a "springboard" for the facilitated discussions.
The Triangle J Council of Governments (TJCOG) will assist the participating local governments
in developing the discussion papers and in arranging for facilitation support services. As we
move forward with this collaborative effort, it is essential to have NCDENR's active
participation and commitment throughout the project. Therefore, we respectfully request that
you:
1. Personally participate throughout the project, if possible.
2. Appoint at least two high-level staff members to represent NCDENR throughout the project.
It is requested that these representatives be fully authorized and responsible for providing
clear and consistent technical and policy -level guidance to the local government project
partners.
3. Inform us of the extent to which NCDENR will commit to providing expedited review,
comment on, and approval of discussion papers, project plans, environmental. impact
assessments and mitigation plans, permit applications, and related matters.
Our respective local governments, along with Triangle J COG, want to emphasize our
commitment to seeking a regional solution to the water/wastewater needs of our communities. It
is our belief that a strong commitment from NCDENR has been expressed in this regard and we
collectively express our interest in working very closely with the state in finding a successful
solution for a regional facility.
Thank you so much for your consideration of this request. In light of the immediate importance
of this issue, we would like to receive your reply by October 1.6, 2000. We look forward to your
reply, and to working with you and your staff to develop and implement an environmentally -
effective, cost-efficient and timely -collaborative solution to the long-term wastewater needs in
the area of concern.
Sincerely yours,
.12:4&%RevrfriesA7N__
Dee A. Freeman
Executive Director
Triangle J Council of Governments
LW'
William Sutton
Town Manager
Town of Apex

Secretary Bill Holman
October 4, 2000
Page Three
illiam Coleman
Town Manager
Town of Cary
Larry Bennett
Town Manager
Town of Fuquay-Varina
710, co.wa�L
William Cowan
County Manager
Lee County
Pe • t
Leonard Barefoot
City Manager
City of Sanford
DAF/et al
CCI 14141)
Charlie Horne
County Manager
Chatham County
Richard Self
Town Manager
Town of Holly Springs
4
David Hodgkins
Town Manager
Town of Morrisville
r
vid Cooke
County Manager
Wake County
cc: Ms. Ellen Reckhow, Chairman, Triangle J COG
Ms. Bert Matthews, Chair, Water Resources Committee, TJCOG
Tommy Stevens, Division of Water Quality
Coleen Sullins, Division of Water Quality

Secretary Bill Holman
October 4, 2000
Page Three
illiam Coleman
Town Manager
Town of Cary
Larry Bennett
Town Manager
Town of Fuquay-Varina
?),
William Cowan
County Manager
Lee County
Pi I
Leonard Barefoot
City Manager
City of Sanford
DAF/et al
)1-0
Charlie Home
County Manager
Chatham County
Richard Self
Town Manager
Town of Holly Springs
David Hodgkins
Town Manager
Town of Morrisville
vid Cooke
County Manager
Wake County
cc: Ms. Ellen Reckhow, Chairman, Triangle J COG
Ms. Bert Matthews, Chair, Water Resources Committee, TJCOG
Tommy Stevens, Division of Water Quality
Coleen Sullins, Division of Water Quality

R
THE TOWN OF
IioIIy
rig
P g
S s
P.O. Box 8
128 S. Main Street
Holly Springs, N.C. 27540
[phone]
Fax: [phone]
Mayor's Office Fax:
[phone]
April 11, 2000
North Carolina Division of Water Quali
Attn: Mr. Tommy Stevens, Director
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: NPDES Permit Request
Holly Springs, North Carolina
Wake County
Dear Mr. Stevens:
The purpose of this letter is to follow up on our meeti,ig v�rtfi you —
and your staff a couple of months ago, and to seek resolution of the
Town's request for a 4.88 MGD discharge permit. I have structured the
letter to address some of the issues that keep arising with respect to our
request - specifically history, growth, regional plans, nutrients, and
summary. Thank you in advance for your efforts to keep our request a
high priority, when I know that you have many issues confrontingyou
and your staff daily.
If you recall, Holly Springs is requesting a permit to increase its
existing discharge at the current discharge location on Utley Creek. Holly
Springs initially put in this request over one year ago, at this specific
location at DWQ staff direction. Timing is becoming critical, as we
project reaching our existing 1.5 MGD permit limit sometime in the year
2002. Even with a very aggressive design, permitting, and construction
schedule starting today, it will be difficult to design and construct the
needed expansion within the time frame remaining.
While reluctant to cloud the main action which the Town is
seeking, we are asking you to consider information on some of the past
actions that have been taken by both the State Office and the Town of
Holly Springs, that have led to the Town's current request. The Town of
Holly Springs first built a wastewater collection and treatment system in
1987. This system was planned and funded solely under the State's 201
Facilities Planning Process with a discharge into Utley Creek. By the late
1980s, the extremely economically -depressed Town of Holly Springs
began experiencing much -needed growth.
Because most of the new growth (and at least half of the original
Town limits) was located in the Middle Creek drainage basin, the Town
originally approached the State in the early 90's seeking permission to

construct a wastewater treatment plant discharging into Middle Creek.
Town officials were told that under no circumstance would a new
discharge into Middle Creek be allowed, on the basis that the State had
already allocated the total assimilative capacity of Middle Creek to the
Towns of Apex and Cary. Both of these communities were given large
discharge permits including enough capacity for multiple future
expansions. In fact, to this day, Cary's permit still has a significant
amount of "un-built" plant capacity. At the time Cary's permit was
issued for a discharge just downstream of Holly Springs, Cary
encompassed no geographic area tributary to Middle Creek.
While it is not in the power of either of us to undo the past and
allocate the Middle Creek assimilative capacity in a more equitable
manner, we do hope that the State
will keep in mind that Holly Springs' present dilemma is due in some part
to these past State permitting actions. State policy forced the Town to
continue with its discharge into Utley Creek when it upgraded its plant to
0.5 MGD and then to a 1.5 MGD
facility. More recently, Holly Springs explored the possibility of shifting
its next wastewater treatment plant downstream. This would better fit in
with the Town's long-range utility service plans. However, the State
instructed Holly Springs to plan for future expansions at its current
location instead.
Holly Springs continues to grow steadily — as it has over the past
seven years. The Town has not adopted a "no growth" policy, however it
has adopted various "smart growth" policies, by studying the fiscal
impact of every residential development that is proposed within the
Town. In addition, the Town has established goals and policies within
it's updated Land Use Plan, adopted in 1998, to require "green"
development. The Town continues to hire additional staff to support those
goals through the development and enforcement of environmentally
sensitive ordinances and procedures.
The Town's growth projections show that our present 1.5 mgd
capacity will be essentially exhausted in 2002. At present, out of 1.5 mgd
of plant,capacity, the Town currently has an average daily flow of around
600,000 gallons per day, with approximately 400,000 gallons per day of
the remaining flow reserved as paper flow. As you can see, we are in
desperate need of moving forward with design of the requested expansion
immediately.
Let me stress that Holly Springs supports the idea of a regional
wastewater solution. In fact, Holly Springs continues to play a leading
role in these discussions at the county level. However, we recognize that

1
t
the complexities of such planning mean that no regional solution will be
available in time to avoid the next expansions of the Town's individual
facility. A regional solution in order to meet the Town's short term needs
within the next ten to fifteen years is not possible. DWQ staff itself
admits that the challenges of permitting a single regional discharge in the
Cape Fear basin (as planned) will be significant.
Holly Springs believes that it will take time and much effort on
the part of individual municipalities working together for a regional
system. The 4.88 MGD permit capacity we have requested should carry
us through ten to fifteen years. It will also allow us to negotiate our role
in the regional system, from a more equal position, with our potential
partners who have been granted generous allowances to discharge into
Middle Creek. In addition, by securing this permit to take care of our
community's needs, we will be able to devote much more staff time to the
implementation of a regional solution. It is our opinion that, in the long
run, a regional discharge will benefit municipalities by minimizing
treatment costs, which are increasing as technologies become available to
better treat effluent.
It may be of interest for you to note that the Wake County
Regional Wastewater Plan actually shows the current Holly Springs
facility remaining in operation as a re -use facility. Therefore, it is likely
that expansion that Holly Springs undertakes in the interim will be of use
in the future, on a regional basis, after minor modifications to the
infrastructure.
We understand that the State staffs reluctance to permit expanded
discharges upstream of Harris Lake centers around eutrophication
concerns for that lake and its tributaries. While CP&L's own monitoring
data appears to show water quality improving in Harris Lake (see letter
dated October 28, 1999 from Stephanie Sudano to Mr. Tommy Stevens),
we understand the State staff's concerns for upstream tributaries to the
lake would remain. We also understand the complexities and limitations
in modeling water quality impacts where nutrients are concerned_
However, we do ask that in establishing the allowable nutrient loads
Holly Springs will be permitted to discharge into Utley Creek that the
State employ methodologies similar to what has been used in other areas
in the Cape Fear Basin where nutrients are of concern and limited
accordingly.
Specifically, we ask that: (1) nutrient loads be given on a mass
basis (2) mass nutrient loads be given on an annual, or at least a seasonal,
basis, (3) that any limits given, whether mass or concentration, not be
less than what is technically achievable, and (4) that only the limiting

/A
nutrient be included in the permit limits. The concentration limits given
to us previously as speculative limits have created much difficulty for us.
The nitrogen removal levels called for are less than what current
technology can reliably achieve.The use of concentration rather than
mass loading means that even if the Town is successful in its efforts to
reuse a portion of its wastewater, that reuse will be of no benefit in
complying with NPDES permit standards. The use of monthly as opposed
to annual or seasonal limits means that even small temporary treatment
process upsets can result in NPDES permit violations, even though water
quality may not have been impacted at all.
Although there are no nutrient limits in our present permit; the
Town voluntarily incorporated nitrogen and phosphorous removal (at
considerable expense) into its recently completed plant. These processes
did not go fully on-line until December of 1999, and we are only now
beginning to fine tune them. If discharge from the Town's plant have
contributed to water quality problems through nutrient discharges, that is
now changing. We hope that the voluntary installation of nutrient
removal processes to our current plant, as well as the additional
downstream monitoring that we have undertaken, will demonstrate our
continued commitment and progressive attitude towards the protection of
water quality in this basin.
We appreciate the time you and your staff have spent meeting
with us, and hope
that you will be able to respond favorably to our request. I look forward
to hearing from you.
Sincerely yours,
TOWN OF HOLLY SPRINGS
Stephanie Sudano, P.E.
Director of Engineering
cc Richard B. Self, Town Manager
Thomas Tillage, Public Utility Director
Ford Chambliss, The Wooten Company
1 1063 be

AM
7PYL`
*4- 5
MEMORANDUM
To: Coleen Sullins
From: Cam McNutt r!M__
Through: Darlene Kuckenc-OC__
Re: Holly Springs Speculative Limits
The information that Holly Springs has provided is from the 1999 Cape Fear River Assessment Report,
including the data from CP&L. Most of this data is based on 1996 data collection from ESB and CP&L.
There are a few things in the report they did not point out.
• Nuisance macrophytes (Hydrilla) were reported in the White Oak Creek Arm of the reservoir.
"... making boat travel into the most upstream portion of this arm exceptionally difficult."
• With regard to the summary of the sampling stations, Holly Springs points out that TP is greatest near
the dam, TN is greatest in upper lake and in the Buckhorn Arm, and Chlorophyll a values are greatest
in the upper lake and Buckhorn Arm. They note that these sampling stations are not associated with
the White Oak Creek arm of the reservoir however, the upper lake sampling station is in the mouth of
the White Oak Creek arm. The CP&L sampling map also indicates a sampling station in upper reaches
of the White Oak Creek arm. There is no data in the assessment report from this station.
• Utley Creek is a zero flow 7Q10 stream. There is a small pond between the discharge and the White
Oak Crek arm of the reservoir. During normal flow the IWC is probably close to 80%. The argument
that the pond (< Sac.) is not covered by chlorophyll a standards is irrelevant to this issue. There is
probably little assimilation of nutrients between the discharge and Harris Lake, except possibly in the
pond.
• It may be that algae are light limited in the White Oak Creek arm from suspended clay (agriculture and
construction on White Oak Creek) and possibly macrophytes. CP&L should have recent data. The
lake is also subject to high periphyton growth because the lake levels are kept constant, unlike the
water supply reservoirs. The bottom DO dynamics will also be different from other reservoirs. This is
not a typical southern reservoir as pointed out by Holly Springs referring to a CP&L report.
• An increase in loading and flow to Utley Creek would not improve water quality in Utley Creek or
Harris Lake. It was recommended in the 1996 Cape Fear River Basinwide plan that Utley Creek be
surveyed below the discharge point because of high IWC (87.5%) and self reporting data indicating
low DO in the Creek.
Harris Lake will experience increased nonpoint source nutrient loading as the land in the watershed is
converted from rural to developed land. The correspondence does not mention CP&L's support of this
project. The NRC may frown on increasing the potential for algal blooms in a lake used for cooling water
for a nuclear power plant.
It appears that Holly Springs is about 3 mi. south of a Cary -Apex WWTP discharge to the Neuse. This
may be a good opportunity to pull a discharge from a zero flow stream. If the discharge cannot be
relocated, then it seems prudent to keep loading at current or lower levels, regardless of flow, until another
option can be found.
NOV 1 1999
SECTION

60, 000
50, 000
40, 000
30,000
20, 000
10.000
Holly Springs Population

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Holly Springs Flow
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TOWN BOARD/STAFF RETREAT
20 YEAR POPULAT-ION PROJECTIONS
4/1 /9 r
ENG B

State Library of N.C. Fax
Aug 20 '98 14:40 P. 03
SYSTEM - N. C. STATE DATA CZY7=
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PAGE
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HOLLY SPRINGS
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1024
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6652 4
5597
YEAR 1960 1970 1980 19902i 7 i,1995 j r 1997 --- 1998
*1995 = special census
(1)1,1 ytnr` ) '1997 = state estimates
'1998 F special census
5°-ems

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TOWN BOARD/STAFF RETREAT
20 YEAR POPULATION PROJECTIONS
YEAR
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c 10000
YEAR
558 697 688
1960 1970 1980
1990, 1995 1997
*1995 = special census
*1997 = state estimates
`1998 = special census
6652
1998

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558 697 688
1960 1970 1980
1990, 1995 1997
*1995 = special census
'1997 = state estimates
*1998 = special census
6652
1998

Feb-92 0.071
Mar-92 0.085
Apr-92 0.084
May-92 0.082
Jun-92 0.126
Jul-92 0.079
Aug-92 0.071
Sep-92 0.079
Oct-92 0.112
Nov-92 0.234
Dec-92 0.196
Jan-93 0.232
Feb-93 0.174
Mar-93 0.234
Apr-93 0.238
May-93 0.197
Jun-93 0.183
Jul-93 0.163
Aug-93 0.198
Sep-93 0.172
Oct-93 0.146
Nov-93 0.12
Dec-93 0.17
Jan-94 0.142
Feb-94 0.123
Mar-94 0.135
Apr-94 0.108
May-94 0.046
Jun-94 0.044
JuI-94 0.119
Aug-94 0.0676
Sep-94 0.068
Oct-94 0.159
Nov-94 0.163
Dec-94 0.17
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Holly Springs Flow Data -Monthly
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