NC0063096_Speculative Limits_19991028

NPDES DOCUHENT :MCANNINO COVER !;c1EET
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 28, 1999
Thus document is printed on leelL1LEM paper. - ignore any
content on the resrerse side

r
r
THE TOWN OF
y
SpilSprings
P.O. Box 8
128 S. Main Street
Holly Springs, N.C. 27540
[phone]
Fax: [phone]
Mayor's Office Fax:
[phone]
October 28, 1999
Mr. Tommy Stevens, Director
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Holly Springs Wastewater Treatment Plant Expansion
Dear Mr. Stevens:
I haven't had an opportunity to meet with you since your
promotion to Director of the Division of Water Quality, so let me first
congratulate you. Your previous work in the Fayetteville Regional Office
and as the Deputy Director have drawn praise from many involved with
municipal government. The Town of Holly Springs looks forward to
working with you closely in the years ahead. You have a tough job, but
with your background, experience and expertise we know you will excel
in your new position.
I know that you and staff are very busy working with communities
in the eastern portion of North Carolina, as they recover from the
devastating effects of Hurricane Floyd. Our community has been
assisting various parts of eastern North Carolina with Public Safety,
Public Works, and Engineering volunteers. We are so fortunate not to
have experienced such widespread serious damage. If you are aware of
any way in which we may be able to assist the State or another
community in this area, please let us know.
The Town of Holly Springs is completing work on a current plant
expansion that will be at capacity before we know it. I would like to
resume with you discussions that I had with your predecessor on
wastewater capacity issues facing Holly Springs. I have attached two
pieces of previous correspondence that should provide a good summary
of the actions to date involving our request for expansion of our current
wastewater treatment plant. The first correspondence, dated August 11,
1998 provides a good background as to the issues of growth of our Town
as well as the capacity needs and requirements of our facility in the near
future and for our twenty- year growth projections. This previous letter
was sent to Preston Howard because the Town had not received
speculative limits for wastewater expansion that had been requested back
in January of 1997.

•
The second attachment, dated February 2, 1999, by the Division
of Water Quality, was in response to our August 1998 letter. This
correspondence provided the Town speculative limits for the expansion of
our wastewater facility from 1.SxMGD to 4.88 MGD. We do thank Mr.
Howard, yourself and staff for the preparation of this response, as it is
essential for our consultants as they proceed to prepare the Environmental
Assessment, design and cost projections for the expansion. However,
there are issues that we think warrant additional evaluation and would
request your consideration of these few remaining issues that will be
extremely critical as we proceed with this project.
The letter of February 1999 stressed the staffs concerns about the
impact of our facility on the waters of Harris Lake several miles
downstream. The letter indicated the Division to have significant
concerns about the level of nutrients entering Harris Lake from our
discharge. The letter mentioned that the White Oak arm of Harris Lake
has experienced excessive algal growth, eutrophication problems and fish
kills. It further states that one of the primary goals of the Division.for •
Harris Lake is to maintain or reduce nutrient loads to the lake. The letter
states that since the Holly Springs facility is the only permitted discharge
to the watershed, the Division intends to hold nutrients at existing levels
until additional- data is available to prevent further compromise to an
already impaired system. Please remember that White Oak Creek is 3.5
miles below our discharge and 10 miles to the headwaters of the White
Oak arm of the lake. The drainage area of the lake is over 114 square
miles and the surface area of the lake is over 4150 acres. Our discharge is
now only around 0.5 MGD. The letter then indicates that the expansion
permit would have Total Phosphorus limits of 0.2 mg/1 and Total '
Nitrogen limits of 2.2 mg/1 as monthly averages.
The correspondence indicates that there have been documented
correlation between instream chlorophyll water quality standard
violations and the level of nutrients coming from the wastewater
treatment plant and that forty percent of the instream chlorophyll -a values
from 1997-1998 were above the standard. We too were concerned with
the values being detected and evaluated the situation. Based on
evaluations by our staff and consultants it was determined that much of
the chlorophyll -a data being collected at the downstream site may be
erroneous. The Division of Water Quality Modeling staff selected the
downstream site. This site is located at the outflow of the small
impoundment about 1.2 miles below our discharge. At that point, during
all of our evaluation visits, it was observed that there was a sloughing of
filamentous algae from the rocks just above and within the sample area.
We were advised that samples containing such sloughing or clumps of
filamentous algae would result in erroneous chlorophyll -a determinations

phosphorus or nitrogen concentrations in Harris Lake in 1996.
Professional scientist with CP&L conclude that Harris Reservoir
continues to show characteristics of a typical southeastern biologically
productive reservoir and that the key indicators of environmental quality
were unchanged from the previous five years. The report concludes that
phosphorus levels have remained stable since 1992 with some rise in
nitrogen concentrations. And the report concludes that the frequency and
severity of nuisance algal blooms have continued to lessen in recent years
with no measured chlorophyll -a concentrations within the past two years
exceeding the state standard. It is also worth noting that the data collected
by CP&L indicated the mean values for chlorophyll -a to be the lowest in
the White Oak arm of the lake, and that the temporal trend analysis
indicates a continual reduction in Chlorophyll in the lake as a whole and
its worth noting that the White Oak arm of the lake showed the lowest
chlorophyll results of all the sites routinely sampled by the company.
Mr. Stevens, I have mentioned this information to provide you
justification that the rationale for the very restrictive N&P limits
contained in the speculative limit letter may not be justified. I believe the
Division normally would require such restrictive nutrient limits only in
areas that have been classified as Nutrient Sensitive by the Environmental
., Management Commission. Utley Creek, White Oak Creek nor Harris
r.
Lake are classified as NSW. Also, the Division would normally indicate
which nutrient to be limiting in such a situation. :The staff has provided no
such technical information and I believe that in most inland situations
phosphorus is normally the nutrient of concern. I would question the co -
limiting of both nitrogen and phosphorus in this permit.
I would also like to mention one additional important fact. The
N.C. water quality standard for chlorophyll -a as described in .0211(3)(a)
does not apply to lakes for ponds less that 10 acres in size. Aerosport
Pond which is located about 1.5 miles downstream of the discharge is
only five acres in surface area. I do realize that .0211(3)(a) allows the
Director the ability to limit nutrients in non -NSW waters if there are
water quality standard violations. Since the chlorophyll standard does not
apply in lakes or ponds less that ten acres, I must question the validity of
any nutrient limits being included in our permit. I would hope you would
also take this into consideration as you look at the nutrient requirements
in our permit.
Please know we do want to protect the water resources in and
around Holly Springs. The upgrades now underway at our facility are
projected to reduce the .N and P in our effluent substantially. The
consultants designing and constructing our facility have information from
similar North Carolina municipalities with similar treatment technology,
reducing nitrogen down to less than 3.0 mg/1 and phosphorus to 1.0-2.0
mg/I. We are obligated to spend large amounts of money for the

upgrades and expansion of our system but we also want to do so wisely
and in such a manner that is necessary to protect the water quality
standards of North Carolina. We are not aware of any permit issued to a
municipality in North Carolina;that is as strict as the speculative limits
your staff has recommended for Holly Springs. The Division has
historically viewed 0.5 mg/1 P and 5.0-6.0 mg/l N as the reasonable level
of nutrient treatment technology. You will recall that the speculative
limits provided to us were 0.2 mg/1 P and 2.2 mg/1 N based as monthly
averages. Also, I believe that normally nitrogen limits are set as annual
mass loads not monthly concentrations that are much more stringent.
As you can see, we have concerns that I believe are well founded
and supported by the technical information. We realize the extreme load
of work on your staff and that they may have not been able to review the
available information since our initial request back in 1997. I would
request that the data be assessed and I would also request to meet and
discuss this with you at your earliest convenience. This is very important
to the Town and the taxpayers. We do appreciate your attention to this
issue and look forward to our meeting. Please advise us when you can
meet to discuss these issues.
Sincerely
Stephanie L. Sudan, P.E.
Director of Engineering
CC: Ford Chambliss, The Wooten Company
10848.doc 10/28/99

1�rr•
NCDENR
JAMES B. HUNT JR.
GOVERNOR
WAYNE MCDEVITT
SECRETARY
WI fif*
A. PRESTON HOWARD,
JR., RE.
DIRECTOR
•
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. NC0036r .1179e6
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/l. 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/10% 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,
WI 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/1 and 2.2
mg/I, 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 1-Iowarc r.,
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 nurn "er
001. Such discharges shall be limited and monitored by the Permittee as specified below: �'
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREME T -� f
'I
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sa
I T e-
,1 Sample
Location*
How
4.88 MGD
Conti
u us�7 ,;.
i epordfng
I or E
BOD, 5 day, 20°C (April 1 - October 31)25.0
mg/l
7.5 mg/l
Da
ly, 1 ,
i ;,..Composite
E, 1
BOD, 5 day, 20°C (November 1 - March 31)2
10.0 mg/l
-
15.0 mg/l
Daily.:
Composite
E, I
Total Suspended Residue2
30 mg/l
45 mg/I
-....
' Daily)
Composite
E, I
NH3 as N (April 1 - October 31)
1.0 mg/l
olk ,
. Daily
Composite
E
NH3 as N (November 1 - March 31)
2.0 mg/i
;#
Daily
Composite
E
Dissolved Oxygen3
\j4=
Daily
Grab
E
Dissolved Oxygen3,y
3/Week
Grab
U, D' .
Chlorophyll -a
--
Weekly'
Grab
D
pH4
r•
rr-'� •i !fi,.
,, �s,:
trrAT
,�,.
is ,,,
•01
Dail Y
Grab
E
Fecal Coliform (geometric mean)
200/ 1_ 0 Cn1f
Q0
., 4
ml
Daily
Grab
E
Fecal Coliform (geometric mean)
QC
2Q0 e1 it L
0 / 100 ml
3/Week
Grab
U D'
�E
Temperature
"C
} -
)
Daily
Grab
Temperature
...
;,
3/Week
Grab
U pi
Total Nitrogen (NO2 + NO3 + TKN) «rw:� '
�.,..�'
=
:��
-' � .2 m /l
�-'' 9
Weekly5
kly
Composite
E
iota! Nitrogen (NO2 + NO3 TKN�., Jr %
-I
--
Weekly5
Grab
U, D
otal Phosphorus '''
�-"
mg/I m /l
Weekly5
Co
E
Total Phosphorus , r7
-
Weekly5
Grabite
D
Total Residual-C to ne �r,;-�,/
17 pg/l
Daily
Grab
E
Conductivity�•
-:, � .
Daily
Grab
E
Cond�ictivity :- �,�.,...
....� ::, �-
3/Week
Grab
U, p i
Chtpnjp TOxicityr
.i 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.
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 less than 6.0 mg/I.
4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5 Effluent and Instream monitoring for Total Nitrogen and Total Phosphorous shall be conducted on the same day.
6 Chronic Toxicity (Ceriodaphnia) P/F at 90%; February, May, August, and November See Part III, Condition F.
Chlorophyll -a shall be monitored weekly during the months June through September; during the remaining months of the year, no monitoring is required.
s 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.

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 b'er
001. Such discharges shall be limited and monitored by the Permittee as specified below:
•
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS1 ----
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement.
Frequency
,7Sa nple L,i
r *,. Type 1
Sample
Location"
Flow
4
4.88 MGD
Contiir)uqus;' j
! Recording
I or E
BOD, 5 day, 20°C (April 1 — October 31)2
5.0 mglt
7.5 mg/I
Dally 1 ,
Cbm osite
p
E
BOD, 5 day, 20°C (November 1 - March 31)2
10.0 mg/I
9
15.0 mg/I
9
.'��
Da ly:; Imo,.-
Composite
E, I
Total Suspended Residues
30 mg/I
45 mg/I
,-'
-
Daily.:
Composite
E, I
NH3 as N (April 1 - October 31)
1.0 mg/I'
,�., / .(,,--.1_
,;'
Daily
Composite
E —
NH3 as N (November 1 — March 31)
2.0 mg/I
a
,.,.:
,.
j 'C.:
� / f (: �;
/
Daily
Composite
E
Dissolved Oxygen
,, 1-.%;
\
\,i ; "----'"
Daily
Grab
E
Dissolved Oxygen3
; L1 1.,
1
,\ _ j
31Week
Grab
U, Di
Chlorophyll -a
4
_
_
,
Li � 1 ✓1
Weekly?
Grab
D
pH
, , 1 7<
-�
t ,;; 1
Daily
Grab
E
Fecal Coliform (geometric mean)
200 / 1.,0 nit.'
4
0 /100 ml
Daily
Grab
E
Fecal Coliform (geometric mean)0
"C
I'_' 1C
•
/ T00 mi
3/Week
Grab
U, Di
Temperature
QC
.;__j
Dail Y
Grab
E
Temperature �.,,,�
,'°. i,
3lWeek
Grab
U, pi
Total Nitrogen (NO2 + NO3 + TKN) -,�
A92.2 mg/I
Weekly5
Composite
E
Total Nitrogen (NO2 + NO3 + TKNy...:r f
-
Weekly5
Grab
U, D
Total Phosphorus ,' :.: ,
-
0.2 mgll
Weekly5
Composite
E
Phosphorus_ it,:r- ~~
Total Phosphorus
'
Weekly5Y
Grab
U, D
Total Residua!-Rtloi net \--
-...,.
17 pgli
Daily
Grab -
E
Conducjiyity . (� )')
Daily
Grab
E
Conductivity >
---, , -=
3/Week
Grab
U, p i
Chronic,T3xiaity6
Quarterly
Composite
E
2 3 The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85% removal).
The daily average dissolved oxygen effluent concentration shall no be less than 6.0 mg/I.
4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5 Effluent and Instream monitoring for Total Nitrogen and Total Phosphorous shall be conducted on the same day.
6 Chronic Toxicity (Ceriodaphnia) P/F at 90%; February, May, August, and November; See Part III, Condition F.
8
Chlorophyll -a shall be monitored weekly during the months June through September; during the remaining months of the year, no monitoring is required.
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.
Notes:'
* Sample 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.

THE TOWN OF
I -jolly
rin
P g
S s
P.O. Box 8
128 S. Main Street
Holly Springs, N.C. 27540
l2- S. 1\A1
[phone]
Fax: [phone]
Mayor's Office Fax:
[phone]
October 21, 1998
Mr. David A. Goodrich
NCDEHNR
P. O. Box 29535
Raleigh, NC 27626-0535
Dear Mr. Goodrich:
In follow-up to our meeting last week, this letter is to advise you that the vr 2
Town is proceeding with the preparation of an EA amendment ' support.of
our application for a wastewater treatment plant expansion to\4.88 gd. As
we indicated at the meeting, timing is critical. We hope to exceed the
schedule we prepared last November (1997) by only a couple of months. We
anticipate forwarding our EA amendment to you for approval on or before
November 30, 1998.
Thank you for meeting with us. The meeting was very productive and your
staff was quite helpful.
Sincerely,
Stephanie I., Sudano, P.E.
Town Engineer
cc: Ford Chambliss
!Inca
10568
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ENGINEERING DEPARTMENT [phone] or 557-3938 fax: [phone] or 552-5569

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TN
mg/1
TP
mg11
0
chl a
mg/
11/4/97 21.8 1.6
1/6/97 14.4 4.3
713/97 60.4 4.4 92.0
7/9/97 35.1 3.0 22.0
7/16/97 32.0 3.5 13.0
7/23/97 27.5 3.0 3.7
7/30/97 21.0 2.5 46.1
816/97 26.0 2.9 9.6
8/13/97 26.0 2.9 1.1
8/20/97 35.0 3.8 19.0
8/27/97 32.5 4.0 34.0
9/4/97 41.4 3.9 1.1
9/10/97 37.8 1.6 2.1
9/17/97 2.1 2.9
9/24/97 44.2 3.9 1.6
10/1/97 28.1 3.0 <1
10/8/97 41.4 3.1 4.8
11/5/97 22.5 1.6
12/3/97 38.6 1.1
12/9/97 35.6 2.2
1/7/98 31.0 1.5
2/4/98 25.5 1.4
3/4/98 25.8 0.9
4/1/98 25.2 1.0
5/6/98 31.2 2.8
6/3/98 31.3 2.2 112.0
6/10/98 33.1 2.8 27.2
6/17/98 16.5 2.4 53.8
6/24/98 34.5 3.5 41.7
7/1/98 38.3 3.5 55.8
7/8/98 33.9 2.2 31.4
7/15/98 33.2 3.2 66.7
7/22/98 41.3 1.5 66.7
7/29/98 22.2 0.9 135.0
8/5/98 19.3 3.0 14.9
8/12/98 26.6 1.9 17.9
8/19/98 28.2 2.9 68.3
8/26/98 27.0 3.5 78.9
9/2/98 24.6
9/9/98 29.9
9/16/98 24.6
9/23/98 12.8
9/30/98 27.6
10/7/98 19.1
AVERAGE 2.6 0.9 39
140.0
120.0
100.0
80.0
60.0
40.0
20.0
0.0
Holly Springs: chl-a

45
40
35
30
▪ 25
as
z
▪ 20
15
10
0
Holly Springs : Nitrogen
Effluent
Upstream
Downstream
,940��9 '��9h�� ��99'41)9ti649o�6 a\9N V1%���h�9,�'�� �. �'��A� �f 4•`))9,�ti194•1" ,y�ti��9,p(' ati° ,P y\ti`��y��'�9�,1�`',��4`\,��'�����'�t' of cIP'����h���
6
5
4
2
1
0
Holly Springs : Phosphorus
Effluent
Downstream
•
Upstream
1
IIIIT
L o_ -cr
• (0
CCD CO 00 CO 00 00 CO 00 00 00 CO 00 00 CO 00 CC/00
0,0) 0, rn 0) a1 CT, Cr, Cr, 0) (77) 0, C rn 0 CT, Cr, a) 0) 0, a/ 0) rn 0) rn CT, rn CT/ rn
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
00 ^ Q) N (fl O c- N. to T N co O M f, M Ts... O v 00 N tf7 O M — �r
\ N C.,N \ N \ \ M N N N \ N \ \ • M
CO \C‘l ^ N ^ \ \ N C'V ) M -, -f to LC, • ^ n n. 00 O0 07 0) • O 0 00

Holly Springs Nutrients
NC0063096
CURRENT LOADS (Based on effluent data)
11/19/98
sdp
The Actual Average Daily Toads based on DMR data from May 1995 to August 1998:
Total Nitrogen: 91.7 Ibs/day
Total Phosphorus: 7.3 Ibs/day
FUTURE PERMITTED LOADS
Permitted Loads based on limits as stipulated below:
Qw
MGD
TN
mg/I
TN
Ibs/day
TP
mg/I
TP
Ibs/day
2.50
4.88
6.0
2.3
125.1 -
91.7
0.5
- 0.2
10.4
7.3
Actual future Toads will vary with the future effluent values and are expected to be Tess
than the permitted loads as long as the facility maintains compliance.
Note: A new 1.5 MGD oxidation ditch is expected to come on line in early 1998.

7
�q
12
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u
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NOW( '' �� _� .% 1�\ N i '�� L,, � , ii.„ �aryN�•, j:.✓
ct,
›;a1, 1144,161 f .11:414
2 025 000 FEET
• INTERIOR —GEOLOGICAL SURVEY. RESTON. VIRGINIA-1991
I2050
'0
KILOMETERS 1
0
N
I —I
MILES 1 0
r
1

�LEc1J,
"lava_ auESI
Holly Springs Nutrients
NC0063096
10/20/98
sdp
CURRENT LOADS C Aseh cr. Efcaff, T DATA)
The Actual Average Daily loads based on DMR data from May 1995 to August 1998:
Total Nitrogen: 91.7 Ibs/day
Total Phosphorus: 7.3 Ibs/day
FUTURE PERMITTED LOADS
Permitted Loads based on limits as stipulated in the most recent speculative letterUoa Z.5 An(tp)".
TN Qw TN TP Qw DTP
mg/I MGD Ibs/day mg/I MGD Ibs/day
6.0 2.50 125.1 0.5 2.50 10.4 -- gtiTE St v&e ikicaAS€
Actual future Toads will vary with the future effluent values and are expected to be less
than the permitted loads as long as the facility maintains compliance.
Note: A new 1.5 MGD oxidation ditch is expected to come on line in early 1998.
( / „Idikk(
4w‘AU W161 v
0((Wr AVINV
eete-

chl-a Concentration (mg/L)
I kISTR tAInn DATA
160
140
120
100
80
60
40
20
0
Jul-97
Sep-97
Nov-97
Instream chl-a Concentration
Utley Creek
July '97-August '98
Feb-98
Date
TN TP chl a
mg/I mg/I mg/I
7/3/97 12.6 0.7 92
7/9/97 11.6 0.67 22
7/16/97 10.4 0.67 13
7/23/97 8.8 0.7 3.7
7/30/97 4 0.6 45.1
1/7/98 9.2 0.4
2/4/98 0.7 0.1
3/4/98 6.8 0.4
4/1/98 1.4 0.4
5/6/98 7.8 0.4
6/3/98 7.1 0.59 112
6/10/98 12.2 0.38 27.2
6/17/98 5.9 0.34 53.8
6/24/98 12.5 0.5 41.7
7/1/98 11.2 0.31 55.8
7/8/98 10.1 0.5 31.4
7/15/98 13 0.33 66.7
7/22/98 13 0.8 66.7
7/29/98 11.2 0.09 135
8/5/98 6.8 0.3 14.9
8/12/98 7.2 0.2 17.9
8/19/98 9.5 0.8 68.3
8/26/98 12.3 0.7 78.9
AVERAGE 8.9 0.5 53
Apr-98
Jul-98
®Dwn chl a (mg/L)

E FFLUEr t LATA
Holly Springs Nutrient Data
Mar-95
Jun-95
Jul-95
Oct-95
May-96
Aug-96
Nov-96
Jan-97
Jul-97
Aug-97
Sep-97
Oct-97
Nov-97
Dec-97
Jan-98
Feb-98
Mar-98
Apr-98
May-98
Jun-98
Jul-98
Aug-98
Qw TN # TN TP #TP
MGD mg/I #/day mg/I #/day
0.146 14.5 17.66 2 2.44
0.171 35.6 50.77 4.72 6.73
0.132 0.3 0.33 4 4.40
0.224 25.3 47.26 2.5 4.67
0.288 33.8 81.18 4.7 11.29
0.31 29.32 75.80 2.34 6.05
0.303 21.8 55.09 1.6 4.04
0.318 14.4 38.19 4.3 11.40
0.512 35.200 150.39 3.26 13.95
0.348 29.900 86.85 3.39 9.84
0.352 31.000 90.93 3.06 8.98
0.376 33 103.48 2.5 7.84
0.391 22.5 73.37 1.6 5.22
0.418 37.1 129.34 1.6 5.58
0.607 31 156.93 1.5 7.59
0.595 25.5 126.54 1.4 6.95
0.587 25.8 126.31 0.9 4.41
0.508 25.2 106.77 1 4.24
0.539 31.2 140.25 2.8 12.59
0.42 28.8 100.88 2.7 9.46
0.603 33.8 169.98 2.3 11.57
0.423 25.3 89.25 2.8 9.88
AVE 91.71 7.28 Ibs/day

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Meeting Agenda
Utley Creek Wastewater Treatment Plant Expansion Permit Request
October 13, 1998 @i:00 p 4 w1
1. History of Permit Requests and Permit Issued
o 1993
o 1996
o 1997
❑ 1997
/62
0.5 mgd permit issued (0.5 mgd requested)
1.5 mgd permit issued (4.88 mgd requested)
no permit issued (6.0 mgd requested at White Oak - staff
requested a change in location back to Utley Creek)
4.88 to 6.0 mgd permit application process initiated with
staff- official application target date 12/1/98 (on Utley
Creek per staff)
2. The Town's goals of the pending 4.88 te^mgd Permit Request on Utley Creek
3. Re -visit schedule for permit approval
4. EA Amendment - Issues to address
❑ Population Projections
❑ NC55 corridor community map with growth rates
❑ Historical growth data
o Town's newest Land Use Plan/Service Area Boundaries
o Current approved lots
❑ WWTP Flow Projections
o Lifetime of both existing WWTP & WWTP expansion (under
construction)
❑ Summary: need for long-term planning/financing/upcoming bond
referendum
o Nutrient Issues
❑ Current Holly Springs WWTP - technology & discharge
❑ WWTP Expansion (under construction) - technology & discharge
o Permit limits on discharge
o Expected performance - (voluntary performance limits)
❑ Pending Permit Request - expected limits
5. Other Projects in Town
o Voluntary Seasonal Water Us estriction Ordinance (56°11-5 �u7o I�
o Wetlands Restoration Project
o Potential Re -use Projects (rvyi-4,5 .,, 344- s,!;./,44.4144..... f../uv2
•

Meeting Agenda
Utley Creek Wastewater Treatment Plant Expansion Permit Request
October 13, 1998 @ I:00 vt,
to
1. History of Permit Requests and Permit Issued
❑ 1993
❑ 1996
❑ 1997
❑ 1997
0.5 mgd permit issued (0.5 mgd requested)
1.5 mgd permit issued (4.88 mgd requested) ear i' <-W "J ??
no permit issued (6.0 mgd requested at White Oak - staff
requested a change in location back to Utley Creek)
4.88 to 6.0 mgd permit application process initiated with
staff - official application target date 12/ /98 (on Utley
Creek per staff)
Ne2� earn, l NOV.
2. The Town's goals of the pending 4.88 mgd Permit Request on Utley Creek
C • L _ ahettJa 1L 3ot7a - ?C 25% Judt; ,�b guFp'f/
•
3. Re -visit schedule for permit approval refre�ow-
'\-z-r,sr/
4. EA Amendment - Issues to address
❑ Population Projections
o Nutrient Issues
s Cs+
9 r f C.owrer-4- aw ti 4Qo
`i$'L Soo
2a00 �veoo ❑ NC55 corridor community map with growth rates 9.3L67` $4 F A s „my,
o Historical growth data
❑ Town's newest Land Use Plan/Service Area Boundaries
o Current approved lots
o WWTP Flow Projections
❑ Lifetime of both existing WWTP & WWTP expansion (under
construction)
o Summary: need for long-term planning/financing/upcoming bond
referendum
/DT {Sc,1 « ovT •
❑ Current Holly Springs WWTP - technology & discharge
o WWTP Expansion (under construction) - technology & discharge
to Permit limits on discharge
o Expected performance - (voluntary performance limits)
❑ Pending Permit Request - expected limits
5. Other Projects in Town
❑ Voluntary Seasonal Water Use Restriction Ordinance
o Wetlands Restoration Project .r iL ,,.r will Pd�D
❑ Potential Re -use Projects " 64- °'- 6-r
ddw"s,,tf0%. ,.n.tn CQ
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20 YEAR POPULA 77ON PROJECTIONS
7O 03
60000
socco
POP. 40:-=
C
DXO
1 OCOD
TOWN BOARD/STAFF RETREAT
YEAR
4/1/97
trl
N 0 r) V
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1970 1980 1990‘ 1995 1997
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*1997 = state estimates
`1998 = special census
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I p. 5"r?(1 D

Monday, September 28, 1998
Re: More Information For You! Page: 1
Subject: Re: More Information For You!
Date: Mon, 28 Sep 1998 10:45:20 -0400
From: "Stephanie Sudano" <SLSUDANO@ WORLDNET.ATT.NET>
To: "Ed Buchner" <ed [e-mail]>
Thank you Ed. Now is there anything that you would like to see for/at the
meeting? I am preparing an agenda based on what information we think
various staff members are looking for, but would appreciate any further
direction from you (as the person "in the know" }should you have any.
Thanks, stephanie sudano
> From: Ed Buchner <ed [e-mail]>
> To: [e-mail]
> Subject: More Information For You!
> Date: Friday, September 25, 1998 1:21 PM
> Stephanie:
> I have the meeting place for you...I assume you are familiar with the
> Archdale Bldg., go to the 13th floor conference room, we have it
> reserved for 10AM-3PM. I am also assuming this won't take nearly that
> long but I took a guess. If you need anything else...let me know. Thanks
> for your help.
> Ed
Mailbox://h2o.enr.state.nc.us?fetch>
UID>/INBOX>155

Friday, September 25, 1998
Re: Meeting Time & Place Page: 1
Subject: Re: Meeting Time & Place
Date: Fri, 25 Sep 1998 10:20:45 -0400
From: "Stephanie Sudano" <[e-mail]>
To: "Ed Buchner" <ed [e-mail],state.nc.us>
CC: "Ford Chambliss" <fordc@ gte.net>
OCT,
Yes - we are planning to attend a meeting on the 13th at your place. I
have confirmed it with our consultant. I apologize for not re -confirming
with you. We will have between 3 and 5 people there for the meeting. It
is our hope to receive input on what would like for us to include in our
EA amendment for the 4.88 mgd discharge request. We will also be prepared
to discuss population projections with you and your staff, since this was
an area of concern previously. Please advise if you have any other
specific information/maps/data that you think would be helpful for our
meeting. We will be more than happy to provide them. 'thanks,.stephanie
sudano
> From: Ed Buchner <ed [e-mail]>
> To: [e-mail]
> Subject: Meeting Time & Place
> Date: Thursday, September 24, 1998 4:59 PM
> Stephanie:
> I need to know if you've confirmed with your consultant that 10/13/98 at
> 10AM here in the Archdale bldg is going to be OK. Also, could you please
> specify the approximate number of people in your group that plan on
> attending. It's getting fairly close to the time to schedule a
> conference room. Please let us know what, if any, specific points you
> will want to cover at this meeting. This will help us be prepared to
> answer your concerns. Let me know if changes need to be made.
>
> Thanks,
> Ed
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Mailbox://h2o.enr.state.nc.us?fetch>
UID>/INBOX>148

August 11, 1998
A. Preston Howard, Jr. P.E.
Director, Division of Water Quality
PO Box 29535
Raleigh, NC 2726-0535
Dear Mr. Howard:
41110*
Ate, 14 1998
DIV. OF
()RECTOR'S OAF QUALITY
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 1.5 MGD. 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/1 and we routinely treat to levels of 3.0 mg/1. The
same with our ammonia which was permitted at 2.0 mg/land 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
OFFICE of THE MAYOR
P.O. Box 8.128 S. Main Street • Holly Springs, N.C. 27540 • (919) 557-39
SECTION

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
/lra
cc: Tommy Stevens
Colleen Sullins
Henry Lancaster
Stephanie Sudano

BELOW IS A BRIEF WRITE UP SENT TO ME BY KAREN LYNCH DESCRIBING
ALGAE INFORMALLY SAMPLED IN THE MILL POND ON UTLEY CREEK:
An algal bloom was visible in the Holly Springs Pond below the town of Holly Spring's
WWTP. The bloom consisted of prolific growths of filamentous algae, surface blooming
phytoplankton and duckweed (Lemna species). The bloom was washing out of the pond and
flowing downstream into Utley Creek. Remnants of the bloom could be seen rafted up in slow
places in the creek. The filamentous algae consisted of growths of the green algae, Oedogonium
species (Chlorophyceae).
Oedogonium is always aquatic and is usually found in small permanent bodies of water.
Oedogonium is a common green alga which often proliferates in the spring. The filaments begin
growing attached, but often break off becoming free-floating and form cottony mats near the
water's surface. On smooth substrate, Oedogonium will form simple holdfasts, whereas on rough
surfaces, branched holdfasts are formed. As the algae ages, it appears yellow -.green in color.
Oedogonium is commonly found on old rushes or cattail stalks.
Floating algae or phytoplankton were also collected. High numbers of the green colonial alga,
Scenedesmus quadricauda maximus, were found in the pond. Scenedesmus consists of colonies
of 2, 4 or 8 fusiform, crescent or oblong cells. This genus is probably more widespread than any
other fresh water algae. Often small pools or aquariums are densely populated and discolored by
this genus. Visibly floating on the surface was a bloom of Euglenophytes which consisted of the
alga, Trachelomonas species (Euglenophyceae). Members of the Euglenophyceae are often
found in organically enriched waters. Trachelomonas are free swimming unicellular
phytoplanktors. Species of Trachelomonas can be found throughout the year usually in fresh
water ponds and lakes. Trachelomonas is derived from the Greek words trachelos (neck) and
monas (single organism).

Holly Springs - Utley Creek
NC0063096
Status =
Allowable Waste Concentration
speculative request
P 1A4
SUMMER
Ammonia as NH3
7Q10(cfs) 0.11
Design Flow (MGD) 1.5
Design Flow (cfs) 2.325
Stream Std (mg/I) 1.0
ups Bckgrnd Lvl (mg/I) 0.22
IWC (%) 95.483
Allow Conc. (mg/I) 1.04
LIMIT!
WINTER
Ammonia as NH3
7Q10(cfs) 0.25
Design Flow (MGD) 1.5
Design Flow (cfs) 2.325
Stream Std (mg/I) 1.8
ups Bckgrnd Lvl (mg/I) 0.22
IWC (%) 90.291
Allow Conc. (mg/I) 1.97
LIMIT!
Resdual Chlorine
7Q10(cfs) 0.11
Design Flow (MGD) 1.5
Design Flow (cfs) 2.325
Stream Std (ug/I) 17.0
ups Bckgrnd LvI (ug/I) 0.0
IWC (%) 95.483
Allow Conc. (ug/I) 17.80
limit (ug/I) = 17.80
DILUTION
.05:1
�uT iLt
SUMMER
Ammonia as NH3
7Q10(cfs) 0.11
Design Flow (MGD) 2.5
Design Flow (cfs) 3.875
Stream Std (mg/I) 1.0
ups Bckgrnd LvI (mg/I) 0.22
IWC (%) 97.240
Allow Conc. (mg/I) 1.02
LIMIT!
WINTER
Ammonia as NH3
7Q10(cfs) 0.25
Design Flow (MGD) 2.5
Design Flow (cfs) 3.875
Stream Std (mg/I) 1.8
ups Bckgrnd Lvl (mg/I) 0.22
IWC (%) 93.939
Allow Conc. (mg/I) 1.90
LIMIT!
Resdual Chlorine
7Q10(cfs) 0.11
Design Flow (MGD) 2.5
Design Flow (cfs) 3.875
Stream Std (ug/I) 17.0
ups Bckgrnd Lvl (ug/I) 0.0
IWC (%) 97.240
Allow Conc. (ug/I) 17.48
limit (ug/I) = 17.48
DILUTION
.03:1
6/25/98
SDP
C�r2&`r-- PRAS Z
SUMMER
Ammonia as NH3
7Q10(cfs) 0.11
Design Flow (MGD) 0.5
Design Flow (cfs) 0.775
Stream Std (mg/I) 1.0
ups Bckgrnd Lvl (mg/I) 0.22
IWC (%) 87.571
Allow Conc. (mg/l) 1.11
LIMIT!
WINTER
Ammonia as NH3
7Q10(cfs) 0.25
Design Flow (MGD) 0.5
Design Flow (cfs) 0.775
Stream Std (mg/I) 1.8
ups Bckgrnd Lvl (mg/I) 0.22
IWC (%) 75.610
Allow Conc. (mg/I) 2.31
LIMIT!
Resdual Chlorine
7Q10(cfs) 0.11
Design Flow (MGD) 0.5
Design Flow (cfs) 0.775
Stream Std (ug/I) 17.0
ups Bckgrnd Lvl (ug/I) 0.0
IWC (%) 87.571
Allow Conc. (ug/I) 19.41
limit (ug/I) = 19.41
DILUTION
.14:1
AIIWastConc-NH3 TRC

Holly Springs
Total Phosphorus
6/24/98
sdp
Qw TP # TP mon freq #/ mon U D
MGD mg/I #/day
May-96 0.288 4.7 11.29 1
Jun-96 0.254 0
Jul-96 0.28 0
Aug-96 0.31 2.34 6.05 1
Sep-96 0.333 0
Oct-96 0
Nov-96 0.303 1.6 4.04 1
Dec-96 0.429 0
Jan-97 0.318 4.3 11.40 Quarterly 1
Feb-97 0.382 0
Mar-97 0.367 0
Apr-97 0.37 0
May-97 0.354 0
Jun-97 0.318 0
Jul-97 0.512 3.26 13.95 Weekly 5
Aug-97 0.348 3.39 9.84 4 0.3 0.48
Sep-97 0.352 3.06 8.98 4 0.7 0.62
AVE 9.36 Ibs/day
An equvalent load at a given concentrations:
TP Qw
mg/I MGD
2.25
0.45 2.5
0.4 2.81
0.35 3.21
IBJ 2_ t N 11 Iv s
= I,Isvv\r
I.1rVA(7
2,s1 +mc,b,

Subject: Re: Holly Springs spec request
Date: Tue, 21 Jul 1998 09:14:09 -0400
From: "Steve Pellei" <steve j,[e-mail]> Internal DWQ NCDENR
To: Steve Tedder<[e-mail]>
CC: Dave Goodrich<[e-mail]
Steve,
We discussed this in-house quite extensively prior to the drafting of the spec letter, and feel it was the best decision to
follow this route. If you recall, Utley Creek has some problems with algal growth and has experienced fish kills. The water
quality there is a real concern for us, especially relating to nutrients.
An expansion of 1.0 MGD with nutrient limits will give Holly Springs some room to grow and lower the total nutrient
load reaching the receiving stream too. This expansion does require that Holly Springs continue to evaluate all of its various
options which they are required to do anyway. If, at some future time, Holly Springs needs to request
additional flow, we will reconsider expansions at the Utley Creek WWTP. At that time we will be in a better position to
evaluate options and the results of the reduced nutrient loads to Utley Creek.
So, in short, we haven't closed the door on Utley Creek expansions, but we are keeping the pressure on them (and all
dischargers) to evaluate all of the available options prior to seeking any expansions. It is the most reasonable route to take
and the Town seems satisfied with the approach.
Steve
Steve Tedder wrote:
Thanks again Steve.
I noticed the letter only addressed expansion of an additional 1.0 MGD rather than the 3.38 MGD the Town requested.. This
appears very contrary as to where the Section have been trying to direct the Town over the past 5 years. We, Dave included,
have encouraged them to make the next expansion sufficient to last them 10-20 years and to quit expanding in small amounts
especially with the rapid growth of the town. I am guessing that Dave is still concerned with the growth projections of the
town. According to my quick calculations, this expansion of only 1.0 MGD will only last about 4.5 years based on the 50
plus building permits being issued each month by the town.
Something approaching 3.5 MGD might last them close to 10 years, and 4.88 might get them 15 plus years. I would think
going for the larger expansion would lessen the load on the permitting over the long term, and allow the town the ability to
plan appropriately for the future and install the best technology for waste treatment. To be honest, issuance of a larger flow
might be useful in getting Cary, Apex and others to work together better to consolidate some efforts and maybe some
wastewater.
> Your thoughts?
> Steve Tedder wrote:
> > Thanks Steve. Could you fax me a copy or get Pam to? fax # is 571-4041
> > Steve Pellei wrote:
> > > Our response to this request when out on monday. As I discussed with Ms. Sudano yesterday, these speculative limits
should reduce nutrient loads to the receiving stream and provide sufficient capacity for Holly Springs for the near future.
> > > Steve
» »
> > > Steve Tedder wrote:
> > > > Steve,
> > > > I can't get Dave to respond to my inquiry.I sent him this e-mail on the 6th. Can you give me a status of this997979
Over the past two years we met with the town several times trying to get them to get ahead on the capacity of the facility.
They apparently have seen the light , then the Section delays the progress. Please advise where things stand wit this
requests. Even now, with the delay on this request, I think they will be facing a moratorium by the time the 1.5 MGD facility
is even completed. Thanks
> Steve Tedder wrote:
> > > > > In some discussions I had with the Town recently I understand you and your folks still have not provide them
speculative limits for expansion of the current facility from 1.5 to 3.5 MGD. Dave, I thought we had this all resolved back in
December???? We were going to allow the expansion, and we wanted them to remain at the current location and we were
talking N@ P limits and advanced tert. Bod and Ammonia. As hard as we pushed them to go for the big expansion and stop
the half million increases, I sure hope the Section does not reverse the direction we sent them. At that time you and I were in
agreement on this scenario. What's the problem getting out the Speculative letter to the town999979 I would have thought
this would have been done months ago when they asked, should take someone all of 20 minutes. What's the scoop?
> > > > > Steve Tedder <[e-mail]>

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