20061203 Ver 2_Alt Discharge Locations DRAFT_20100222

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of Elie: --eers
M;1niinytun District
DRAFT
Western Wake Regional Wastewater Management Facilities
Alternative Wastewater Discharge Locations
Before the planning studies that lead to the formation of the Western Wake
Partners, several of the communities were involved with efforts to site a potential
discharge in the Cape Fear River Basin. Prior to 2000, the Towns of Cary and
Apex had consultants examining potential sites and evaluating potential discharge
locations in the Haw River below Jordan Lake and in the Cape Fear River. In
September 2001, the Town of Cary met with representatives of DENR to discuss
the formation of a workgroup to explore options for returning reclaimed water to
the Cape Fear. This workgroup included agency, university research and local
government representatives and met six times between December 2001 and May
2002 (CH2M HILL, 2002a). The Town of Holly Springs had numerous interactions
with DWQ regarding expansion of their discharges into Utley Creek even prior to
2000. Also beginning in 2001, the Town of Cary and the City of Fayetteville Public
Works Commission (PWC) initiated a modeling study to update and combine the
QUAL 2E models for the Cape Fear River between Buckhorn Dam and Lock and
Dam No. 1 and evaluate a potential new discharge immediately below Buckhorn
Dam as well as increased water withdrawals and discharges by the City of
Fayetteville (CH2M HILL, 2002b).
In consideration of the regulatory mandates issued by the North Carolina
Environmental Management Commission (EMC) and the North Carolina Division
of Water Quality (DWQ), the Western Wake Partners (Partners) conducted an
evaluation of alternative wastewater discharge locations during their early planning
studies. Beginning, January 2003, the Partners initiated consultations with
representatives from DWQ to identify and evaluate alternative wastewater
discharge location options. The alternative discharge locations reviewed with
DWQ included the following:
Western Wake Regional Wastewater Management Facilities 8/23/07
DRAFT Alternative Wastewater Discharge Locations
Page 1
1) Cape Fear River below Buckhorn Dam
2) New Hope Arm of Jordan Lake (above Jordan Lake Dam and below US 64)
3) Cape Fear River/Haw River above Buckhorn Dam
4) Harris Lake/Utley Creek
Each of these alternatives is described further below.
Alternative 1: Cape Fear River below Buckhorn Dam
DWQ representatives indicated that the most favorable discharge option for the
Partners is the Cape Fear River below Buckhorn Dam. The Cape Fear River
below Buckhorn Dam was considered most favorable because water quality
modeling suggested that this segment of the Cape Fear River can accommodate
additional wastewater effluent loadings without creating unacceptable water quality
conditions (CH2M HILL, 2002b). Available data indicate that excessive algal
growth is occurring behind the lock and dam structures. DWQ evaluated data
collected on the Middle Cape Fear River immediately above Buckhorn Dam and
behind Lock & Dam No. 3 as part of the Cape Fear River Basinwide Water Quality
Management Plan update. Data indicate that there are exceedances of the
chlorophyll a standard in these locations and these locations were included on the
2006 303(d) list submitted to EPA (DWQ, 2006). However, investigations by the
Middle Cape Fear River Basin Association (MCFRBA) indicate that inappropriate
sampling may have been a contributor to the elevated observation of chlorophyll a
and that recent data collected appropriately does not indicate impairment
(MCFRBA, 2007).
On May 24, 2004, the Project Partners submitted to DWQ a request for
speculative effluent limits for a discharge to the Cape Fear River below Buckhorn
Dam (Attachment 1). Because of the concerns regarding nutrient loading, DWQ
requested in a meeting in August 2004 (Attachment 2) that the Project Partners
develop an interim nutrient management strategy to address these issues until the
TMDL requirement is further evaluated. Based on the interim nutrient strategy that
was developed by the Partners and presented to DWQ in a meeting in November
2004 (Attachment 3), DWQ issued speculative effluent loading limits on December
15, 2004 including annual mass limits for nutrients based on 6 mg/L total nitrogen
and 2 mg/L total phosphorus. In addition, DWQ issued speculative limits for
oxygen-consuming wastes of 5/10 mg/L (Summer/Winter BOD5) and 1/2 mg/L
Western Wake Regional Wastewater Management Facilities 8/23/07
DRAFT Alternative Wastewater Discharge Locations
Page 2
(Summer/Winter NH3-N). Attachment 4 includes the original speculative limits
letter issued in December 2004, and a letter to correct a typographical error in the
earlier letter issued in December 2005.
Alternative 2: New Hope Arm of Jordan Lake (above Jordan Lake Dam and
below US 64)
The Partners requested that DWQ review information regarding a discharge to the
New Hope Creek arm of Jordan Lake. The Partners determined that there are a
number of benefits associated with discharging water reclamation facility effluent
to Jordan Lake. The benefits include, but are not limited to, the following:
• Maintaining water supply and water quality pools during extended droughts.
• Keeping water reclamation and conveyance facilities in close proximity to
western Wake County local government service areas to encourage additional
reuse.
• Reducing facilities required by eliminating longer conveyance to the Cape Fear
River below Buckhorn Dam.
• Minimizing the potential and/or perceived water quality impacts downstream of
Jordan Lake to downstream users and other interested parties.
• Continuing western Wake County local government efforts toward sound water
resources and environmental management.
In addition, the results of the Regional Wastewater Treatment Studies Project
Phase I Study indicated that the potential savings in the cost of pumping and
conveyance facilities for a Jordan Lake discharge versus a Cape Fear River
discharge is on the order of $15 to $20 million.
The upper New Hope Creek arm of Jordan Lake was placed on the 2002 303(d)
list for nutrients based on exceedance of the chlorophyll a standard of 40 pg/L.
DWQ updated a water quality model for the lake upon which to base a TMDL for
nutrients. The Partners applied this model to determine the impact of a proposed
discharge on chlorophyll a in the lake; the results indicated that there was little
difference in the frequency of predicted chlorophyll a standard violations. This
information was presented to DWQ.
Western Wake Regional Wastewater Management Facilities 8/23/07
DRAFT Alternative Wastewater Discharge Locations
Page 3
In a meeting in April 2004 (Attachment 5), DWQ indicated that the Environmental
Protection Agency (EPA) would not allow DWQ to permit an increased pollutant
load to an impaired water body if it will exacerbate the water quality impairment.
Although the modeling results indicated that predicted water quality is virtually
identical with a new discharge achieving state-of-the-art nutrient removal, DWQ
indicated that it could not permit an increase in nutrient loading to the lake
because the water quality modeling and water quality sampling indicates that
Jordan Lake is an impaired water body based on the percentage of exceedances
of the chlorophyll a standard. DWQ indicated that if the Partners could purchase a
nutrient allocation from another discharger in the watershed, then an NPDES
permit could be attained. DWQ also indicated that the Partners would need to
fund a study which evaluated the impacts of trading with an NPDES facility
upstream of Jordan Lake since some loss of nutrients will occur as a nutrient load
from an upstream source travels downstream. [This meeting led the Partners to
submit their request for speculative limits mentioned above as Attachment 1 ].
Alternative 3: Cape Fear River/Haw River above Buckhorn Dam
In earlier studies, some of the Partners evaluated the potential to discharge to
either the Haw or Cape Fear Rivers upstream of Buckhorn Dam. DWQ advised
them that they should pursue a discharge downstream of Buckhorn Dam based on
observed chlorophyll a exceedances and unusual variation in dissolved oxygen
levels behind Buckhorn Dam. DWQ continues to maintain this position.
Alternative 4: Harris Lake/Utley Creek
The Partners also evaluated discharging to Harris Lake. The Town of Holly
Springs Utley Creek WWTP currently discharges to Utley Creek, a tributary of
Harris Lake. DWQ has informed the Town that it must remove its discharge from
Utley Creek because of nutrient-related water quality concerns downstream on
Utley Creek and in the White Oak Creek arm of Harris Lake. DWQ encouraged
them to evaluate regional wastewater treatment and disposal alternatives.
Selected Discharge Location
Because Alternative Discharge Locations 2, 3, and 4 were determined by DWQ to
be infeasible, the only feasible discharge location is Alternative 1 (Cape Fear River
below Buckhorn Dam). Therefore, the alternatives analysis for the Western Wake
Western Wake Regional Wastewater Management Facilities 8/23/07
DRAFT Alternative Wastewater Discharge Locations
Page 4
Regional Wastewater Treatment Facilities will focus only on alternatives that
include discharging treated effluent to the Cape Fear River below Buckhorn Dam.
References
CH2M HILL, 2002a. Meeting Summaries and Presentations from the Pre-scoping
Work Group for Discharge Options for the Town of Cary. June 2002.
CH2M HILL, 2002b. Cape Fear River QUAL 2E Model Development and
Application. Prepared for the Town of Cary and City of Fayetteville Public Works
Commission. March 2002.
DWQ, 2006. Final North Carolina Water Quality Assessment and Impaired Waters
List (2006 Integrated 305(b) and 303(d) Report). Approved May 17, 2007.
MCFRBA, 2007. ANNUAL REPORT (January 2006 - December 2006). Prepared
by the Middle Cape Fear River Basin Association to summarize basinwide
monitoring information. April 2007.
Attachments
Attachment 1 - Speculative Limits Request Letter, May 24, 2004
Attachment 2 - DWQ/ Western Wake Partners Meeting Summary, August 31,
2004
Attachment 3 - DWQ/Western Wake Partners/MCFRBA Meeting Summary,
November 18, 2004
Attachment 4 -Speculative Limits Letter and Corrected Letter, December 15, 2004
and December 5, 2005
Attachment 5 - DWQ/Western Wake Partners Meeting Summary, April 12, 2004
Western Wake Regional Wastewater Management Facilities 8/23/07
DRAFT Alternative Wastewater Discharge Locations
Page 5
Attachment 1
Speculative Limits Request Letter, May 24, 2004
Western Wake Regional Wastewater Management Facilities 8/23/07
"' DRAFT Alternative Wastewater Discharge Locations
CH2M HILL
4824 Parkway Plaza Boulevard
Suite 200
Charlotte, NC
28217-1968
Tel [phone]
Fax [phone]
May 24, 2004
Mr. Dave Goodrich
NPDES Unit Supervisor
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Speculative Limits Request for a Proposed Regional Water Reclamation Facility to
Serve Western Wake County
Dear Mr. Goodrich:
As you are aware, CH2M HILL, CDM and Hazen & Sawyer are working with the Towns of
Apex, Cary, Holly Springs, and Morrisville, and Wake County, (Project Partners) on a
regional plan to serve the communities' wastewater treatment needs and to return
reclaimed water to the Cape Fear River Basin. While the exact location of a new treatment
facility has not been determined, the proposed facility will discharge to the Cape Fear River
downstream of Buckhorn Dam. A map indicating the approximate point of discharge is
provided in Attachment A. We are requesting speculative limits for flows of 14 MGD, 23
MGD, and 31 MGD based on expected capacity needs in 2010, 2020, and 2030 respectively.
CH2M HILL, in cooperation with the Division of Water Quality (DWQ) and Division of
Water Resources (DWR), completed a QUAL2EU model for the Cape Fear River from
Buckhorn Dam to Lock and Dam 1. The Town of Cary and the Public Works Commission
(PWC) of the City of Fayetteville jointly funded this project. The final report for this effort
was submitted on April 30, 2002, after comments from DWQ and DWR were addressed.
Several scenarios were evaluated in an effort to assess the potential effect on instream DO
which may result from either an increase in withdrawal and discharge by PWC or a new
wastewater discharge below Buckhorn Dam. Table 1 summarizes the input conditions and
predicted DO immediately upstream of the three Lock and Dam structures for model runs
with and without phytoplankton productivity. Figure 1 illustrates the predicted instream
DO for the various modeling scenarios.
The model results indicate that summer limits of 5 mg/L BOD5 and 1 mg/L NH3-N will
protect instream DO for the proposed discharge. Based on these modeling results, you
provided speculative limits for 28 mgd in your letter of June 2003 for PWC's Rockfish Creek
WRF (see Attachment B). In your transmittal letter, you indicated that speculative limits of
5 mg/L BOD5 and 1 mg/L NH3-N were also considered appropriate for a hypothetical
discharge of 30 mgd to the Cape Fear River below Buckhorn Dam. You also indicated
concern regarding nutrient loading. Hence, the future Western Wake County WRF design
will include flexibility to remove nutrients to levels similar to the North Cary Water
Reclamation Facility.
The Project Partners are developing an EIS to examine the impacts of the proposed WRF.
The draft EIS will be completed in the second quarter of 2005 in order to allow meeting the
January 1, 2011 deadline to begin returning water to the Cape Fear River established by the
Environmental Management Commission in the Interbasin Transfer Certificate issued to the
Towns of Cary, Apex, and Morrisville and Wake County. The speculative limits you
provide will be included in the EIS.
If you have any questions concerning this matter, please contact me at [phone], ext.
217 or Ruth Swanek at 875-4311, ext. 16.
Sincerely,
CH2M HILL
William A. Kreutzberger
Michelle Woolfolk/DWQ
Coleen Sullins/DWQ
Bobby Blowe/DWQ
Phil Stout, Wake County
Kim Fisher, Town of Cary
Leila Goodwin, Town of Cary
Tim Donnelly, Town of Apex
Dan Lamontagne, Town of Apex
Stephanie Sudano, Town of Holly Springs
Blake Mills, Town of Morrisville
Jose Martinez, Town of Morrisville
Tommy Esqueda, CDM
Bob Berndt, Hazen & Sawyer
Bob DiFiore, Hazen & Sawyer
Ruth Swanek, CH2M HILL
Enclosure
TABLE 1A
Summary of Input Parameters, Predicted Instream Dissolved Oxygen(DO), and Change in DO for Scenarios Assuming Phytoplankton Productivity

Headwater

Predicted DO Change in DO Relative to

Baseline
Conditions LID 3 LID 2 LID 1 LD 3 LD 2 LID 1

Scenario
Description Chia
(pg/L) Q
(cfs) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.)
1A Base scenario 20 622 6.50 5.96 6.22 0.00 0.00 0.00
2A New wastewater discharge (12 mgd) below Buckhorn 20 614 6.47 5.92 6.18 -0.03 -0.04 -0.04
3A New wastewater discharge (30 mgd) below Buckhorn 20 603 6.41 5.86 6.12 -0.09 -0.1 -0.10
4A Increase PWC wastewater discharge (53 mgd) 20 622 6.50 5.96 6.22 0.00 0.00 0.00
5A New wastewater discharge (30 mgd) below Buckhorn and Increase PWC
wastewater discharge (53 mgd) 20 603 6.38 5.83 6.09 -0.12 -0.13 -0.13
6A Increase Fayetteville PWC withdrawal to 80 mgd; WWTP discharge 69 mgd 20 622 6.32 5.76 6.06 -0.18 -0.20 -0.16
TABLE 1B
Summary of Input Parameters, Predicted Instream Dissolved Oxygen(DO), and Change in DO for Scenarios Assuming No Phytoplankton Productivity

Headwater
Predicted DO Change in DO Relative
to Baseline
Conditions LD 3 LID 2 LID 1 LID 3 LID 2 LID 1

Scenario
Description Chi a
(pg/L) Q
(cfs) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.) DO
(mg/L.)
1B Base scenario 0.00 622 5.76 4.87 5.08 0.00 0.00 0.00
2B New wastewater discharge (12 mgd) below Buckhorn 0.00 614 5.70 4.82 5.04 -0.06 -0.05 -0.04
3B New wastewater discharge (30 mgd) below Buckhorn 0.00 603 5.63 4.75 4.97 -0.13 -0.12 -0.11
4B Increase PWC wastewater discharge (53 mgd) 0.00 622 5.76 4.87 5.10 0.00 0.00 0.02
5B New wastewater discharge (30 mgd) below Buckhorn and Increase PWC
wastewater discharge (53 mgd) 0.00 603 5.60 4.72 4.94 -0.16 -0.15 -0.14
6B Increase Fayetteville PWC withdrawal to 80 mgd; WWTP discharge 69 mgd 0.00 622 5.57 4.66 4.90 -0.19 -0.21 -0.18
8
7
6
° s
E
c
m
a
O 4
a
0 3
0
2
1
0
I PREDICTED DO
Dissolved Oxygen • OBSERVED DO
Scenario 1B - Base line

0.00
8
7
6
m
E 6
c
m
a
O 4
a
0 3
0
2
1
0
20.00 40.00 60.00 80.00 100.00 120.00 140.00
River Mile
Dissolved Oxygen PREDICTED DO
Scenario 2B - New wastewater discharge (12 mgd) A OBSERVED DO

0.00
8
7
6
m
E s
c
m
4
O
a
0 3
0
2
1
0
20.00 40.00 60.00 80.00 100.00 120.00 140.00
River Mile
Dissolved Oxygen PREDICTED DO
Scenario 3B - New wastewater discharge (30 mgd) A OBSERVED DO

0.00 20.00 40.00 60.00 80.00 100.00 120.00 140.00
River Mile
Figure 1a. Buckhorn Dam to Lock and Dam 1
Predicted Dissolved Oxygen for Select Scenarios
without Phytoplankton Productivity
PREDICTED DO
Dissolved Oxygen • na.¢FRVFn nn
Scenario 4B - Increase PWC wastewater discharge (53 mgd)
8
7
s
m
E 5
c
m
4
O
a
0 3
0
2
1
0
0.00
20.00 40.00 60.00 80.00 100.00 120.00 140.00
River Mile
Dissolved Oxygen PREDICTED DO
Scenario 5B - New wastewater discharge (30 mgd) • OBSERVED DO
and Increase in PWC wastewater discharge(53 mgd)
8
T
6
E 5
a
O 4
3
O
2
1
0

0.00
20.00 40.00 60.00 80.00 100.00 120.00 140.00
River Mile
Dissolved Oxygen PREDICTED DO
Scenario 6B - Increase PWC withdrawal (80 mgd) and • OBSERVED DO
wastewater discharge (69 mgd)
8
7
6
m
E 5
c
m
a
X q
O
a
N 3
0
2
1
0

0.00 20.00 40.00 60.00 80.00 100.00 120.00
River Mile
Figure 1b. Buckhorn Dam to Lock and Dam 1
Predicted Dissolved Oxygen for Select Scenarios
without Phytoplankton Productivity
140.00
Attachment A
Map, Proposed Point of Discharge
1,000 500 0 1,000 Feet N
Attachment A
Proposed Discharge Point for Western Wake WRF
Speculative Limits Reauest
Attachment B
Letter from NCDENR to City of Fayetteville
June 27, 2003

State of North Carolina
Department of Environr
and Natural Resources
Division of Wafter Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Direptor

ON HILL RDU
June 27, 2003
Mr. Mick Noland, COO Water Resources
City of Fayetteville PWC
P.O. Bok 1089
Fayetteville, North Carolina. 28302-1089.
Subject Speculative Effluent Limits
Rockfish Creek WRF -
NPDES Permit #NCO050105
Cumberland County
Dear Mr. Noland:
This letter is in response to your request for speculative effluent limits for a proposed expansion to 28
MGD at the Rockfish Creek WRF. Currently, this facility has phased limits of 16, 21, and 24 MGD. This
facility, discharges to the Cape Fear River, approximately 58 miles downstream of Buckhorn Dana, and 12
miles upstream of Lock and Dam #3. The Cape Fear River in this segment classifed C waters.
The speculative limits were develop&0based - on our review of" the Cape Fear QUAL2E Model
Development and Application report prepared by CH2M Hill (April 30, 2002). This model evaluated
discharge scenarios in the Cape Fear Rivet from Buckhorn Dam to Lock and Dam #1, and was based on
two existing DWQ models. CH2M Hill followed DWQ's standard modeling procedures to develop
headwater DO and temperature conditions, and productivity was addressed by including the algal routine
in the QUAL2E model. This modeling effort, was sponsored by the City of Fayetteville PWC and the
Town of Cary.
Based on available information, speculative effluent limits for the proposed discharge of 28 MGD to the
Cape Feat River are presented in Table L A complete evaluation of these limits and monitoring
frequencies in addition to monitoring requirements for metals and other toxicants will be addressed upon
receipt of a formal NPDES permit modification request. These speculative limits of 5 mg/l BODS and 1
mg/l NH3-N are also considered appropriate for a hypothetical discharge of 30 MGD to the Cape Fear
River below Buckhorn Dam. [Note: permit limits expressed as CBOD5 may be more stringent than
BOD5 limits]. The model results do not show any significant impact on predicted instteam dissolved
oxygen levels from these proposed discharges, assuming the speculative limitations for BOD5 and NH3
presented in Table 1. However, the Division does have concerns regarding nutrient loading. The' Cape
Fear River above Lock and Dam #3 has experienced chlorophyll-a levels far exceeding the standard of 40
ug/1 based on DWQ and MCFRBA data. The Division plans to conduct algal assays during Summer 2003
to determine what nutrient is controlling algal growth in this river segment. Future data will be reviewed
1617 Flail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled t 10% post-consumer paper
* Speculative Limits
NC0050105- Rockfish Creek WRF
Page 2
and it Use Support Assessment will be completed in 2005. It is recommended that future wastewater
planning include flexibility in design to accoimsx odate any potential nutrient removal requirements.
TABLE 1. Spec ative Limits for Rockfish Creek WRF, NCO050105
?dt'Ghnt Ep y
"lJi«t. 'tuC` ?• t k??? ?? t ?.?7?'. ,?,V?'Lh1't- _ ?d1?}_11?:L171lifi]
Flow 28 MGD
BOD5, Summer 5.0 /l 7.5 fng/1
BOD5, Winter 10.0 /1 15.p 11
T SS 30.0 rag/1 45.0 m /l
-
NH3 as N, Summer 1.0 m 1 .3.0 tng/1
NH3 as Nf, WWiti€er 2.0 rng/l 6.0 ru /l
TRC 28 u l
Fecal colifonn Cgeoractric mean 200/]00 td 400/100 ml
Please note that the Division cannot guarantee that an NPDES permit modification for 28 MGD will be
issued with these speculative limits. Final decisions can only be made after the Division receives and
evaluates a formal permit application for the City's proposed discharge. In accordance with the North
Carolina General Statutes, the practicable wastewater treatment and disposal alternative with the least
adverse impact on the environment is requited to be implemented Therefore, prior to submittal of an
NPDES major permit modification, a detailed alternatives analysis must be prepared to assure. that the
requested flow is justified and an environmentally sound alternative is selected from the reasonable cost
effective options.. This alternatives analysis'needs to be incorporated into the State Environmental Policy
Act (SEPA) submission.
Should you have any questions about these speculative limits or if you need any additional information
about restarting the SEPA process, please feel free to contact Tord Belnick at [phone], extension
543.
Sincerely,
David A. Goodrich
Supervisor, NPDES Unit
cc: Town of Cary, Kim Fisher'
CH2M Hill, Bill Kreutzberger
DWR, Torn Fransen
Fayetteville Regional Office, Water Quality
Raleigh Regional Office, Water Quality
Modeling/TMDL Unit.
Central Files
NPDES Permit File, NCO050105
Attachment 2
DWQ/ Western Wake Partners Meeting Summary, August 31, 2004
Western Wake Regional Wastewater Management Facilities 8/23/07
"' DRAFT Alternative Wastewater Discharge Locations
Meeting Summary Memorandum No. 005
To: Technical Advisory Committee
From: Western Wake Consultant Team
Meeting Date: August 31, 2004
Subject: Western Wake WRF Speculative Limits Meeting with DWQ
Meeting Attendees:
Coleen Sullins/DWQ
Michelle Woolfolk/DWQ
Dave Goodrich/DWQ
Larry Horton/DWQ-CG&L
Kim Fisher/Cary
Tim Donnelly/Apex
Leila Goodwin/Cary
Steve Brown/Cary
Chad Ham/MCFRBA and PWC
Ron Taylor/H&S
Bob Berndt/H&S
Tommy Esqueda/CDM
Kelly Boone/CDM
Ruth Swanek/CH2M HILL
Bill Kreutzberger/CH2M HILL
Bob DiFiore/H&S
Ed Powell/Davis-Martin-Powell (Holly
Springs)
Meeting Agenda
1. Introductions
2. Purpose of the meeting (Bill Kreutzberger)
3. Status of the Project (Tommy Esqueda, CG&L representative)
4. Request for Speculative Limits
• Review modeling conducted for Cary and PWC
• Discuss impairment status for Cape Fear River
• Discuss strategies for nutrients including implications for other Middle Cape
Fear River facilities
5. Summarize Action Items and Next Steps
Summary
The purpose of the meeting was to follow up on a written request for speculative limits for
a discharge to the Cape Fear River below Buckhorn dam. This written request was
submitted to DWQ on May 24, 2004, and was based on meeting discussed conducted with
DWQ in April 2004 between DWQ and the municipal partners/ consultants. At the April
2004 meeting, DWQ strongly discouraged any consideration of a discharge to Jordan Lake,
and the municipal partners agreed to pursue a discharge to the Cape Fear River.
The consultants began the August 31, 2004 meeting with a brief status update. It was stated
that this project had started as a planning process led by Wake County. The Town of Cary
has now been identified as the lead agency and an interlocal agreement has been exceuted
with the project particpants being Cary, Apex, Morrisville, Holly Springs and Wake County.
The process to evaluate secondary and cumulative impacts is underway and includes a
mussel survey. The secondary and cumulative impact analysis process is scheduled to be
completed the first quarter of 2005.
CG&L has been engaged in a process since November 2003, and the CG&L Section is
working with the Municipal Partners to provide a $5 million planning loan and a $60
million construction loan for the project. In order to secure the proposed loans, the CG&L
Section will require the preparation of an EIS/201 Facility Plan.
Return of reclaimed water to Jordan Lake has been evaluated and the communities have
elected to pursue a Cape Fear discharge. A site for the WRF will be selected in the next 30 to
60 days. Each Municipal Partner is currently working to finalize their respective flow
projections, and that should be completed by October 2004. Holly Springs is currently
planning for 4 mgd of discharge to remain in Utley Creek and 4 mgd to be discharged to
the Cape Fear River via the regional facility outfall. Speculative limits are required so that
the Municipal Partners can begin to determine processes and the facility layout. The
following summarizes major discussion items.
1. Coleen indicated that there are a number of local governments planning either new
facilities or expanded discharges for the Middle portion of the Cape Fear River
including the new discharges by Western Wake communities and Harnett County and
an expansion by PWC for the Rockfish Creek WRF.
2. Dave Goodrich asked whether the facility was still on schedule. The Municipal Partners
responded that the schedule was dictated by the EMC requirement and has not slipped.
The Municipal Partners also indicated that the process had actually gained a little time
on the schedule from the meeting with CG&L and DENR staff in the morning. The
schedule requires that the Municipal Partners have an NPDES permit application
submitted no later than January 1, 2007.
The speculative limits request included flows of 14, 23, and 31 mgd which could vary
+/-10% as flow projections are updated through the 201/EIS process. It was mentioned
that CH2M HILL - working jointly for Cary and PWC - had updated the QUAL2E
model for the Cape Fear by linking the two previous models, adding algal growth as a
process that impacted DO (but not as a nutrient response model), and doing some
recalibration. The revised model indicated the river could assimilate new discharges
near Buckhorn Dam as well as increases by PWC. Michelle indicated that DWQ had run
the 31 mgd request and determined that limits of 5 mg/L for BOD5 and 1 mg/ for NH3-
N would be protective of dissolved oxygen..
4. Michelle went on to indicate that DWQ has determined through analyses being done for
the basinwide plan update that the areas behind Buckhorn Dam and Lock and Dam 3
had in excess of 10% exceedance of the chlorophyll-a standard. She indicated that at
L&D 3, even when winter months were assumed to have values less than the standard,
the results indicated 11% violations. Michelle indicated that this assessment would
result in these areas of the Cape Fear being on the 303(d) list in 2006 and thus a TMDL
analysis would be required. She indicated that money would be requested from EPA to
do the TMDL analysis after listing in 2006, several years of data collection would be
required, then the modeling analysis would be performed, followed by TMDL
development. She indicated that the results of this TMDL would probably result in
NPDES permit limits for nutrients (based on the TMDL) in 2016. There was considerable
discussion of this information.
Dave Goodrich indicated that they had gotten EPA in Athens, GA to do an algal growth
potential test (AGPT) which indicated that nitrogen was probably the controlling
nutrient. It was indicated that the Middle Cape Fear River Basin Association (MCFRBA)
has funded two studies by Dr. Steve Whalen of UNC where he has examined algal
growth behind the locks and dams on the river - particularly the rate of productivity,
determination of limiting conditions, and targets for nutrient reduction. Chad Ham
indicated that the first report was completed and that the second report was due in the
next 30 days. It was also indicated that light and hydraulic residence time were critically
important to algal productivity. Coleen asked whether this was due to elevated turbidity
levels. It was indicated that turbidity levels in the Cape Fear are typically quite low -
less than 10 NTU - and that the river begins to pick up some of the dark color even
above Fayetteville.
DWQ indicated they were pleased that the MCFRBA had funded the research. They
requested that the Western Wake communities work with the MCFRBA to develop an
interim nutrient management strategy for use prior to the development of a TMDL.
They indicated that this strategy would be required by Thanksgiving 2004 so that it
could be included in the draft Basinwide Plan being presented to the EMC WQ
Committee in February 2005. The following action items were identified.
• Send previous reports and presentations on the algal productivity to DWQ - week of
9/6
• Develop draft interim nutrient management strategy - by week of 10/4
• Meet with DWQ and stakeholders regarding draft strategy - by week of 10/18
• Time for second meeting - by week of 11/1
• Submit revised interim strategy - by week of 11/21
7. The 80/90 rule was brought up relative to maximizing flows to the North Cary WRF.
We wanted to know whether we could view the entire system in interpreting this rule.
DWQ confirmed that this was appropriate and that they had done this in Charlotte and
Greensboro.
This concluded the meeting.
Attachment 3
DWQ/Western Wake Partners/MCFRBA Meeting Summary, November 18,
2004
Western Wake Regional Wastewater Management Facilities 8/23/07
"' DRAFT Alternative Wastewater Discharge Locations
HANDOUT C
Meeting Summary Memorandum No. 013
To: Technical Advisory Committee
From: Western Wake Consultant Team
Meeting Date: November 18, 2004
Subject: Interim Nutrient Management Strategy for the Middle Cape
Fear River (Buckhorn Dam to L/ D 3)
Meeting Attendees:
Coleen Sullins/DWQ Gary Averitte/Harnett County
Dave Goodrich/DWQ, NPDES Rodney Tart/ Harnett County Public Utilities
Michelle Woolfolk/DWQ, Modeling Don Freeman/Cape Fear River Assembly
Rob Brown/DWQ, Construction Grants Ed Powell/Davis, Martin and Powell
Ken Schuster/DWQ, Raleigh Region Hiram Marziano/Marziano & Minier
Paul Rawls/DWQ, Fayetteville Region Tommy Esqueda/CDM
Kim Fisher/Cary Kelly Boone/CDM
Leila Goodwin/Cary Bob Berndt/H&S
Steve Cahoon/Progress Energy Bob DiFiore/H&S
Mick Noland/PWC - Fayetteville Bill Kreutzberger/CH2M HILL
Chad Ham/PWC - Fayetteville Ruth Swanek/CH2M HILL
Meeting Summary
The purpose of the meeting was to present the consensus-based interim nutrient strategy
that the Western Wake Partners and dischargers in the Middle Cape Fear Basin developed
and obtain feedback on it from the Division of Water Quality (DWQ). DWQ will use the
interim strategy to develop speculative nutrient limits for the proposed Western Wake
Regional Water Reclamation Facility (WRF) and for proposed expansions in the Cape Fear
River upstream of Lock and Dam 3 (L/D 3).
Bill Kreutzberger presented the proposed nutrient management strategy. He summarized
the monitoring that the Middle Cape Fear River Basin Association (MCFRBA) is performing.
The MCFRBA data indicate that the Cape Fear River behind L/D 3 is impaired due to
chlorophyll a (chl a) standard violations. Correlations of chl a with flow and turbidity
indicate that chl a typically spikes when flow and turbidity are low. The highest chl a values
were observed in 2002 when flows were well below the target at Lillington. Other high
concentrations were observed in 1998 when flows were also below the target at Lillington,
but not nearly as low as those observed in 2002.
Bill indicated that the MCFRBA collects samples for chl a at the surface, and that the DWQ
standard operating procedure (SOP) is to collect samples as a depth-integrated composite
through the photic zone (twice the Secchi depth). During the low flow periods when high
chl a is observed, the limited data available indicate that the water behind L/D 3 is slightly
stratified (MCFRBA and Dr. Steve Whalen's 2000 study). Super-saturated dissolved oxygen
(DO) concentrations exist at the surface under these conditions, and it is probable that the
chl a that were measured are higher than what would occur if DWQ's SOP had been
followed.
Bill also presented 2003 research by Dr. Whalen in which nutrient dilution assays were
conducted. This research indicates that irradiance is the limiting factor rather than
nutrients. The irradiance is a factor of turbidity and whether algae are at the top of the
water column. Increased water clarity resulted in higher phytoplankton biomass. Dr.
Whalen also noted that higher light in combination with a reduced NY ratio resulted in a
greater likelihood of blue-green algal blooms. There was some discussion around this point;
Dr. Whalen has not yet submitted his final paper, and the MCFRBA will ask for further
clarification on the blue-green potential.
Bill presented the following timeline for the middle Cape Fear Basin which was confirmed
by DWQ:
• February 2005 - Status presented to EMC in draft Basinwide Plan
• April 2006 - Portion of Cape Fear River included on 303(d) list due to nutrient
enrichment
• 2007-2009 - DWQ request funding from EPA for additional monitoring, modeling and
TMDL development
• 2011-2014 - TMDL developed
• 2016 - Compliance required in NPDES permits
An interim strategy for the Cape Fear watershed upstream of L/D 3 was presented.
Consensus was achieved on the strategy by dischargers within the Middle Cape Fear Basin
as well as the Western Wake Partners. The strategy includes components for new
dischargers, expanding dischargers, and nonpoint sources as follows:
New Discharges - critical period (Apr. - Sep.) loads based on permitted flow and:
- TN=6.Omg/L
- TP = 2.0 mg/ L
Expanding Discharges - Optimization - No load increases (based on permitted/ allocated
flow and current TN/TP levels) but not less than limits for new discharges
NPS - Request DWQ to begin dialog on developing nonpoint source reduction strategy
DWQ asked how the watershed was defined for this strategy. The watershed is defined as
the Cape Fear River between Buckhorn Dam and L/D 3. Facilities above Buckhorn Dam
and in the Deep River watershed were not contacted. It is really DWQ's decision on
whether to use the strategy in these areas.
DWQ indicated that the Project Partners had completed what DWQ had requested. They
indicated that maintaining the load for existing dischargers was consistent with prior
strategies they have implemented. For the new dischargers, they noted a concern in how
the season was defined. DWQ believed that October should be included.
For the new discharger strategy, DWQ had concerns about the phosphorus threshold; they
thought it was high compared to what has been necessary in other systems. The rationale
for using the 2 mg/L target is that it can be achieved without chemical addition. At lower
phosphorus levels, chemical precipitation will be required, and there were questions
whether the additional sludge generated through this process is justified without further
analysis of the system. The Town of Cary noted that a 2 mg/L limit actually requires the
WRF to be operated at approximately 1.5 mg/L to ensure compliance. Fayetteville PWC
also noted that extremely low levels of nitrogen and phosphorus could encourage growth of
nuisance algae.
There was some discussion regarding the expanding discharges. There is one industry in
the watershed that has an allocated flow (1.25 mgd) that is beyond its NPDES permitted
flow (0.5 mgd) which is why the selected wording for expanding discharges was used.
Dave Goodrich noted that DWQ is involved in separate, ongoing discussions regarding
alternatives with this industry.
There was some discussion regarding nonpoint source controls. DWQ indicated that the
mitigation needs were high in Cape Fear Subbasins 03 and 04. There was also recognition
that the basin is urbanizing and that cities need to focus on stormwater controls and not just
look to agriculture to reduce their loadings.
DWQ also indicated that EPA is reviewing nutrient criteria. Since North Carolina has a chl a
standard, the state has not yet had to develop nitrogen and phosphorus criteria. However,
EPA is pushing states, including North Carolina, to develop a proactive stance in
addressing nutrients, even in free-flowing streams. Even if the MCFRBA modifies its chl a
monitoring to follow DWQ's SOP, and the data indicate that 9.9 percent violations are
occurring (10 percent is the threshold for impairment), something should be done with
nutrients. Meeting participants agreed, but also noted that it takes the strategy out of the
TMDL arena, and more flexibility may be allowed.
Next Steps
1. DWQ will review the strategy internally and determine whether they need to make
changes to it (changing the critical period range; phosphorus; other); they would also
like to evaluate the expanding dischargers strategy with compliance data to
determine what the impacts of the strategy are; they would also like to review the
allocated/ permitted flow issue further for the expanding dischargers strategy.
2. DWQ will issue a speculative limits letter to the Western Wake Partners. It was
stressed that this letter is needed by December 15 in order for the project to remain
on schedule to meet the EMC's deadline of January 1, 2011 for the WRF to be on-line.
3. DWQ will review the information provided by PWC and Harnett County regarding
their pending expansions and get decisions to them.
4. Bill Kreutzberger will contact Dr. Whalen to request him to address blue-green algal
bloom potential in his paper.
5. Bill Kreutzberger will provide DWQ with slides of the presentation for use in
presenting the strategy to EPA.
Attachment 4
Speculative Limits Letter and Corrected Letter, December 15, 2004 and
December 5, 2005
Western Wake Regional Wastewater Management Facilities 8/23/07
"' DRAFT Alternative Wastewater Discharge Locations
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P .? Alan W. Klimek. P.E., Director
Division of Water Quality
December 15, 2004
Mr. William Kreutzberger
CH2M HILL
3824 Parkway Plaza Boulevard/Suite 200
Charlotte, North Carolina 28217-1968
Subject: Speculative Effluent Limits
Proposed Western Wake Regional Wastewater Management Facilities
Dear Mr. Kreutzberger:
This letter is in response to your request for speculative effluent limits for a proposed water
reclamation facility (WRF) that will serve communities in western Wake County and return
reclaimed water to the Cape Fear River Basin. The proposed discharge will be located in the Cape
Fear River below Buckhorn Dam. The Cape Fear River in this segment is classified as WS-V waters.
This letter also serves as a response to your letter of November 29, 2004 in which you requested
clarification regarding the compliance monitoring location for dissolved oxygen and other issues
related to the outfall configuration.
Oxygen-Consuming Waste
The speculative limits for oxygen-consuming wastes were developed based on our review of the
Cape Fear River QUAL2E Model Development and Application report prepared by CH2M HILL
(April 30, 2002). This model evaluated discharge scenarios in the Cape Fear River from Buckhorn
Dam to Lock and Dam #1. Based on these findings, speculative limits of 5 mg/L (summer B0135)
and 1 mg/L (summer NH3) should protect dissolved oxygen in the river.
Nutrients
As we have discussed in previous meetings, the Division has concerns about nutrient loading in this
section of the Cape Fear River. Water quality data collected by the Middle Cape Fear River Basin
Association indicate that the water quality standard for chlorophyll a is exceeded for more than 10
percent of the samples collected behind Lock & Dam #3. Therefore, the Division will likely include
a portion of the Cape Fear River upstream of this structure on the 2006 303(d) list of impaired
waters.
The Western Wake Regional Water Reclamation Facilities (WRF) Project Partners developed an
interim nutrient management strategy for the middle Cape Fear River to address these concerns until
a TMDL has been developed and implemented. An interim strategy is necessary based on the
timing of various planned projects that must move forward in the absence of such an analysis. The
nutrient speculative limits outlined in this letter are based on this interim nutrient management
strategy and the potential changes that were discussed during a meeting on November 18, 2004.
Future monitoring and modeling may indicate that more restrictive nutrient controls than those
outlined in this letter are needed to protect water quality. Thus, the Division recommends that all
future wastewater planning include flexibility in design to accommodate further nutrient removal
requirements that may be necessary in the future.
Table 1 summarizes the speculative effluent limits for a proposed discharge of 30 MGD to the Cape
Fear River from the Western Wake Regional WRF; limits for an interim flow of 18 MGD, as
North Carolina Division of Water Quality [phone], Ext.517
1617 Mail Service Center FAX [phone]
Raleigh, North Carolina 27699-1617 On the Internet at http://h2o.enr.state.nc.us/
Kruetzberger Letter
Western Wake County
Page 2
requested in your letter of November 29, 2004, will be similar, but nutrient loading limits would be
reduced consistent with the permitted flow. Similarly, Table 2 outlines speculative limits for the
Town of Holly Springs discharge of 8 MGD to the Cape Fear River; limits for an interim flow of 6
MGD will be similar, but nutrient loading limits would be reduced consistent with the permitted
flow. A complete evaluation of these limits and monitoring frequencies for both NPDES permits,
in addition to monitoring requirements for metals and other toxicants, will be addressed upon
receipt of a formal NPDES permit application.
TABLE 1
Speculative Limits for Western Wake Regional Water Reclamation Facility
- - -
Effluent Limitation
Monthly Weekly Average Daily Seasonal
Effluent Average Maximum Average (April
Characteristics - October)
Flow 30 MGD
BOD5, Summer 5.0 mg/L 7.5 mg/L
BOD.5, Winter 10.0 mg/L 15.0 mg/L
TSS 30.0 mg/L 45.0 mg/L
NH, as N, 1.0 mg/L 3.0 mg/L
Summer
NH3 as N, 2.0 mg/L 6.0 mg/L
Winter
DO' 6.0 mg/L
TRC4 28 ug/L
Fecal coli£orm 200 /100 ml 400 /100 ml
(geometric mean)
TPz 500 lb/day
TN' 1501 lb/day
' Compliance for DO will be measured at the WRF compliance point and evaluated as a daily
average concentration
z Limit based on 2 mg/L TP. For lower flow limits, limit would be based on 2 mg/L and the lower
permitted flow
'Limit based on 6 mg/L TN. For lower flow limits, limit would be based on 6 mg/L and the lower
permitted flow
'Limit to be applied only if chlorine is used for disinfection
2
Kruetzberger Letter
Western Wake County
Page 3
TABLE 2
Speculative Limits for HollV Springs Water Reclamation Facility
Effluent Limitations

Effluent
Characteristics Monthly
Average Weekly Average Daily
Maximum Seasonal
Average (April
-- October)
Flow S MGD
BOD5; Summer 5.0 mg/L 7.5 mg/L
BODS, Winter 10.0 mg/L 15.0 mg/L
TSS 30.0 mg/L 45.0 mg/L
NH3 as N,
Summer 1.0 mg/L 3.0 mg/L
NH3 as N,
Winter 2.0 mg/L 6.0 mg/L
DOS 6.0 mg/L
TRC4 28 ug/L
Fecal coliform
(geometric mean) 200 /100 mL 400 /100 mL
TPZ 400 lb/day
TN3 133 lb/day
Compliance for DO will be measured at the WRF compliance point and evaluated as a daily
average concentration
'Limit based on 2 mg/L TP. For lower flow limits, limit would be based on 2 mg/L and the lower
permitted flow
'Limit based on 6 mg/L TN. For lower flow limits, limit would be based on 6 mg/L and the lower
permitted flow
'Limit to be applied only if chlorine is used for disinfection
Issues Related to Compliance Points
The compliance monitoring location for DO will be the same location as other parameters at the
plant. Your letter of November 29, 2004 indicated that effluent DO is expected to remain above 5
mg/L at the discharge point based on conservative travel time assumptions and decay rates included
in the QUAL2E model cited above. Specifically, you estimated a maximum decrease in D.O. of 0.8
mg/L in the pipe. Please submit the details of this analysis to the Division at your earliest
convenience. The QUAL2E model indicates that the Cape Fear River is not sensitive to the effluent
DO assumption, and including an effluent limit of 6 mg/L at the WRF compliance points, prior to
combining the two discharges, will protect the DO water quality standard in the river.
3
Kruetzberger Letter
Western Wake County
Page 4
You also point out that the Western Wake County WWTP outfall will not have a diffuser. The
Division will not object to this at present, but would ask that a dye study be performed as part of the
Preliminary Engineering Report so that mixing can be taken into account and dilution can be
accurately calculated. Such a study would not be necessary for a diffuser design since mixing models
would be employed to aid the design of such a structure. These models yield accurate dilution rates
without the need for field work related to dye studies.
Please note that the Division cannot guarantee that NPDES permits for a total of 38 MGD will be
issued with these speculative limits. Final decisions can only be made after the Division receives and
evaluates a formal permit application for the Western Wake and Town of Holly Springs Water
Reclamation Facility's proposed discharges. In accordance with the North Carolina General
Statutes, the practicable wastewater treatment and disposal alternative with the least adverse impact
on the environment is required to be implemented. Therefore, prior to submittal of an NPDES
permit application, a detailed alternatives analysis must be prepared to assure that the requested flow
is justified and an environmentally sound alternative is selected from the reasonable cost effective
options. This alternatives analysis needs to be incorporated into the State Environmental Policy Act
submission.
Should you have any questions about these speculative limits, please contact me at [phone],
extension 517.
Sincerely,
?C7?v? vvv
David A. Goodrich
Supervisor, Point Source Branch
cc: Town of Cary, Kim Fisher
Town of Apex, Tim Donnelly
Town of Morrisville, Blake Mills
Town of Holly Springs, Stephanie Sudano
EDM, Tommy Esqueda
Hazen and Sawyer, Bob Berndt
Fayetteville Regional Office, Water Quality
Raleigh Regional Office, Water Quality
Modeling/TMDL Unit, Michelle Woolfolk
Coleen Sullins/Alan Klimek
Mark McIntire
4
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
December 5, 2005
Mr. William Kreutzberger
CH2M HILL
3824 Parkway Plaza Boulevard/Suite 200
Charlotte, North Carolina 28217-1968
Subject: Correction to Speculative Effluent Litnits
Proposed Western Wake Regional Wastewater Management Facilities
Dear Mr. Kteumberger:
This letter is to provide a formal correction to an error in our letter of December 15, 2004 regarding
speculative effluent limits for the subject facilities. Table 2 in that letter regarding Speculative Limits for the
Holly Springs Water Reclamation Facility had an error regarding the limitations for Total Nitrogen and
Total Phosphorus. While the footnote for these limitations was correct, the mass load in the table for these
two parameters was reversed. The attached Table 2 includes a correction to these limits.
There were no other errors in the December 15, 2004 letter. Should you have any questions about this
change, please contact me at [phone], extension 517.
Sincerely,
David A. Goodrich U
Point Source Branch Chief
cc: 'Town of Holly Springs, Stephanie Sudano
CDM, Tommy Esqueda
Hazen and Sawyer, Bob Berndt
Fayetteville Regional Office, Surface Water Protection Section
Raleigh Regional Office, Surface Water Protection Section
Modeling/TMDL Unit, Michelle Woolfolk
NorthCarolina
?Natur?lly
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer- 50% Recycler1110% Post Consumer Paper
TABLE 2 (REVISED)
Speculative Limits for Holly Springs Water Reclamation Facility
Effluent LimitatiOns

Effl
Effluent
Characteristics Monthly
Average Weekly Average Daily
Maximum Seasonal
Average (April

O
October)
Flow 8 MGD
BOD5, Summer 5.0 mg/L 7.5 mg/l,
BODS, Winter 10.0 mg/L 15.0 mg/L
TSS 30.0 mg/L 45.0 mg/L
NH3 as N,
Sumner 1.0 mg/L 3.0 mg/L
NH3 as N,
Winter 2.0 mg/L 6.0 mg/L
DO' 6.0 mg/L
TRC4 28 ug/L
Fecal coliform
(geometric mean) 200 /100 mL 400 /100 mL
TPZ 133 lb/day
TN3 400 lb/day
' Compliance for DO will be measured at the WRF compliance point and evaluated as a daily
average concentration
2 Limit based on 2 mg/L TP. For lower flow limits, limit would be based on 2 mg/L and the
lower permitted flow
3 Limit based on 6 mg/L TN. For lower flow limits, limit would be based on 6 mg/L and the
lower permitted flow
'Limit to be applied only if chlorine is used for disinfection
Attachment 5
DWQ/Western Wake Partners Meeting Summary, April 12, 2004
Western Wake Regional Wastewater Management Facilities 8/23/07
"' DRAFT Alternative Wastewater Discharge Locations
MEETING SUMMARY
Western Wake County Regional WRF - Discharge
Option to Jordan Lake
ATTENDEES: Alan Klimek, DWQ
Coleen Sullins, DWQ
Dave Goodrich, DWQ
Michelle Woolfolk, DWQ
Todd Kennedy, DWQ
Mark McIntire, DWQ
Phil Stout, Wake County
Tim Donnelly, Town of Apex
Stephanie Sudano, Town of
Holly Springs
Bob DiFiore, Hazen & Sawyer
Tommy Esqueda, CDM
Bill Kreutzberger, CH2M HILL
Ruth Swanek, CH2M HILL
FROM: CH2MHILL
MEETING DATE: April 12, 2004
The following major issues were discussed during the meeting.
303(d) Listing Process and Decisions
• DWQ typically lists waters on the 303(d) list if they show exceedances of the standard in
at least 10 percent of the water quality samples. In the case of Jordan Lake, the standard
is 40 ug/L chlorophyll a. This process is based on EPA guidance on determining use
support.
• The upper New Hope Creek arm of Jordan Lake was placed on the 2002 303(d) list for
nutrients based on the chlorophyll a standard. This segment of Jordan Lake was
originally listed based on the modeling (calibrated to monitoring data) completed by
Tetra Tech in 2002. Updated modeling results from Tetra Tech in 2003 indicate that the
40-ug/L standard is currently being exceeded on the order of 14- to 15-percent of time
(in the Haw Arm) and in excess of 30 percent of the time in the Upper New Hope Arm
during the growing season. Chlorophyll a monitoring data also support this frequency
of exceedance. DWQ intends to place the Haw Arm of the lake on the 303(d) list in the
future.
• EPA will not allow DWQ to permit an increased pollutant load to an impaired
waterbody if it will exacerbate the water quality impairment.
• In addition to the Haw River Arm, the 2006 303(d) list will likely include the Cape Fear
River above Buckhorn Dam.
TMDL on Jordan Lake
• Jordan Lake can be considered as three individual segments: the Upper New Hope,
Lower New Hope, and Haw River arms. The upper New Hope arm is impaired, and
data indicate that the Haw River arm should also be considered as impaired. The lower
New Hope needs to be managed to protect this heavily used portion of the lake.
DWQ MTG SUMMARY V3.DOC
WESTERN WAKE COUNTY REGIONAL WRF - DISCHARGE OPTION TO JORDAN LAKE
• DWQ is currently completing a TMDL for Jordan Lake, and the TMDL will address both
point and non-point sources of TN and TP for the entire lake. At one time, it was
anticipated that there would be a TMDL established for the upper New Hope Arm of
Jordan Lake, and a Nutrient Management Strategy for the Haw River Arm of Jordan
Lake. However, based on water quality and modeling analyses, DWQ has determined
that it will be necessary to establish a TMDL for TN and TP for the Haw River Arm as
well. DWQ plans to present a proposed Nutrient Management Strategy for the entire
lake to the Water Quality Committee of the Environmental Management Commission in
July 2004, and then to the full Environmental Management Commission in September
2004.
• The target for the Haw River watershed is a 5% reduction in TN and a 20% reduction in
TP. For the Upper New Hope Creek arm, a 35% reduction in TN and a 5% reduction in
TP is targeted.
• If the modeling data, and water quality data, indicated that current chlorophyll a
exceedances were occurring at or below the 10-percent threshold, then DWQ would be
proposing a TN and TP cap, as opposed to a reduction in existing loadings. The TN and
TP cap would be based on estimates of TN and TP loads from existing point and non-
point sources.
• With regard to point sources of TN and TP, the TMDL will recommend that existing
POTWs in the Haw River Arm achieve TP and TN reductions based on discharge
concentrations observed during the 1997 to 2001 period. Under the currently proposed
strategy for TN and TP, existing POTWs in the Haw River watershed will be allowed to
discharge a mass loading of TN and TP equal to the permitted flow of the facility
discharging at 5.1 mg/ L and 0.24 mg/ L, respectively, assuming forested land achieves
reductions. For the New Hope arm, the reductions are to about the equivalent of 2.6
mg/ L TN and about 0.15 mg/ L TP. These analyses are ongoing, and values cited here
are subject to change. The NPDES Unit has the lead on these analyses.
• DWQ indicated plans to allow for TN and TP load trading within the TMDL, purchasing
and selling within an organized framework of existing and potential dischargers.
However, DWQ indicated that the value of the TN and TP allocations will be different
based on the proximity of the source relative to Jordan Lake. For example, 11b of TN
purchased from Greensboro might equate to 0.3 lb of TN allocation for a new Jordan
Lake discharge, while 11b of TN from the City of Durham might equate to 11b of TN for
a new Jordan Lake discharge.
• Since DWQ has established TN and TP mass-loading reductions for Jordan Lake, it will
be necessary for the Western Wake County communities to purchase TN and TP
capacity (lbs/year) from one, or more, of the existing dischargers in order to secure a
new NPDES permit. DWQ cannot increase the proposed TN and TP allocations because
the water quality modeling and water quality sampling indicates that Jordan Lake is an
impaired water body based on the rate of exceedances of the chlorophyll a standard.
• If the Western Wake County communities desire to pursue the purchase of TN and TP
loads from existing facilities, it will be necessary to conduct additional water quality
DWQ MTG SUMMARY V3.DOC
WESTERN WAKE COUNTY REGIONAL WRF - DISCHARGE OPTION TO JORDAN LAKE
modeling to evaluate the impact of changing the location of the TN and TP load from
the existing sources to a new Jordan Lake discharge. Currently, DWQ does not have
sufficient funds to conduct this analysis; so if it is desired by the Western Wake County
communities, then it will be necessary for these communities to provide the additional
funding.
Jordan Lake Modeling
• Updated modeling results from Tetra Tech indicate that the 40-ug/L standard is
currently being exceeded on the order of 14- to 15-percent of time (in the Haw Arm) and
in excess of 30 percent of the time in the Upper New Hope Arm during the growing
season. DWQ staff indicate that water quality sampling for Jordan Lake supports this
modeling analysis.
• The model developed by Tetra Tech has a large amount of uncertainty associated with
its chlorophyll a predictions. However, DWQ's position is that while the model
predictions of chlorophyll a exceedances are subject to some uncertainty, the predicted
increase in chlorophyll a exceedances associated with increased TN and TP loads from a
new discharge is less uncertain. They also state that on average the model predicts
chlorophyll a reasonably well.
• Although Tetra Tech's model shows very similar percent exceedances for a discharge of
highly treated wastewater to Jordan Lake compared to current conditions, DWQ will not
permit additional load of nutrients to the lake.
Jordan Lake Water Supply Issues
• DWR's regulations require that 50 percent of the water withdrawn from Jordan Lake as a
water supply be returned to the lake's watershed.
• The Project Partners desire to protect the water quality in Jordan Lake. However, if
significant differences are not predicted with a discharge from a state-of-the-art
treatment facility to Jordan Lake, they would prefer to discharge to the lake to maximize
the lake's long term potential as a water supply source.
• The Project Partners have spent a large amount of resources developing Jordan Lake as
their water supply source. The Partners are concerned that they may be denied
allocations of water from Jordan Lake in the future if they do not return wastewater to
the lake's watershed.
DWQ MTG SUMMARY V3.DOC