NC0025453_correspondence_20140430

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From: Lynch, TJ [[e-mail]]
Sent: Wednesday, April 30, 2014 9:45 AM
To: Templeton, Mike
Cc: Belnick, Tom
Subject: RE: Phosphorous
Attachments: ATT00001.c; ATT00002.htm
Hello again Mike. I know I said yesterday that no new doors opened for me from your response but sometimes my door
is a little slow. After thinking about it last night, I was just curious if there is any monitoring data for the downstream
pond that supports continuing to treat it as a local hot spot. My understanding of the pond issue is that the
eutrophication problem existed when Zebulon was operating their old plant(pre-BNR) which was roughly 20 years ago.
The reduction in nutrients in Little Creek's discharge have been significant so I am just wondering whether the hot spot
is really still a hot spot. I know you are not the permit writer for this permit so I really appreciate your willingness to
discuss this issue with me.
Thanks,
_�;F41myx
Assistant Director
Public Utilities Dept.
City of Raleigh
Office-[phone]
ti.lynch(@ raleighnc.gov
www.raleighnc.gov
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From: Templeton, Mike [mailto:mike.templeton()ncdenr.gov] —
Sent: Tuesday, April 29, 2014 3:24 PM
To: Lynch, TJ
Cc: Belnick,Tom
Subject: RE: Phosphorous
Hi,TJ -
It appears you are still of sound mind—those requirements do exist.You will find those—and more—in the Neuse WW
rule, 2B .0234:
• Existing downstream facilities>=0.5 MGD get a 2.0 mg/L quarterly average TP limit; see sub-item (6)(b)(ii).This
includes both members and non-members of the association.
• New facilities get a 1.0 mg/L monthly average limit; see sub-item (7)(f).

• Expanding facilities get a 1.0 mg/L monthly average TP limit unless they belong to an association, in which case they
keep the 2.0 mg/L Qtr Avg limit, sub-item (8)(g).
• The rule also preserves the director's ability to establish more stringent limits to protect local impacts ('hot spots');
see (6)(c), (7)(g), and (8)(h).
Our files show that the 1.0 mg/L limit for the Little Creek WWTP dates back to about 1990 and was set to protect against
nutrient impacts in the Taylors Mill Pond,just a few miles downstream.So you are right, in part: as an NRCA member
facility,the Little Creek plant would normally get a 2.0 mg/L Qtr Avg limit. However,the potential for local impacts just
downstream calls for the more stringent limit you see in the permit.
I suspect this isn't the answer you were looking for, but I hope it sheds some light on Little Creek's limit. Does it raise any
other questions?
- Mike T
Michael E.Templeton, P.E.
Wastewater Branch
Water Quality Permitting Section
NCDENR• DWR Raleigh, NC
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Lynch, TJ [mailto:TJ.Lynch @raleighnc.gov]
Sent: Tuesday, April 29, 2014 1:22 PM
To: Templeton, Mike
Subject: Phosphorous
Hello Mike,
I hope this email finds you doing well. I have what is hopefully a quick question. I seem to remember reading
somewhere that all members of the NRCA had a 2.0 mg/I quarterly limit for Total Phosphorous because they were
members of the compliance association but I cannot seem to put my hands on that language. Am I crazy or did that
language exist? Be honest O. I ask this in the context of the Little Creek WWTP. They are an NRCA/LNBA member and
we just got our NPDES permit for Little Creek which has a 1.0 mg/I quarterly TP limit. This is not a change from the
previous cycle but 2.0 would still be better than 1.0 if the condition I am thinking of exists.
Thanks,
_�74�
Assistant Director
Public Utilities Dept.
City of Raleigh
Office- [phone]
tj.lynchna raleighnc.gov
www.raleighnc.gov